ML20237A303

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Notice of Violation from Insp on 980427-0515.Violation Noted:From 960710-970427,licensee Elected Not to Monitor Performance or Condition of Control Rod Drive Sys Against Established Goals
ML20237A303
Person / Time
Site: Pilgrim
Issue date: 08/06/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237A301 List:
References
50-293-98-04, 50-293-98-4, NUDOCS 9808130258
Download: ML20237A303 (3)


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l NOTICE OF VIOLATION l

Boston Edison Electric Company Docket No. 50-293 l

Pilgrim Nuclear Power Plant License No. DPR-35 EA 98-277 During an NRC inspection conducted from April 27 to May 15,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, Revision 1, the violations are listed below:

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A.

10 CFR 50.65(a)(1) requires, in part, that holders 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

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a SSC does not meet established goals, appropriate corrective action shall be taken.

l 10 CFR 50.65(a)(2), requires, in part, that the monitoring as specified in 10 CFR l

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 l

preventive maintenance, such that the SSC remains capable of performing its intended function.

j 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 the 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 maintenance pursuant to the requirements of Section (a)(2). Specifically, the licensee failed to establish unavailability measures for the anticipated transient 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. (01014)

This is a Severity Level IV 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 components (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 emergency operating procedures, or, or whose failure could cause a reactor scram or actuation of a safety-relattd system.

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Notice of Violation 2

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 (failure of this system could result in a plant trip in the event of a loss of normal system supply to screenwash system concurrent with grass intrusion and screen clogging). (02014)

This is a Severity Level IV violation (Supplement 1).

C.

10 CFR 50.65(a)(3) requires, in part, that performance and condition monitoring activities and associated goals and preventive 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 27,1998, the licensee had failed to complete the periodic evaluation for the refueling cycle No.11 which ended April 1997. (03014)

This is a Severity Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Boston Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: ('i) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not j

l received within tne time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why l

such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to I

the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

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9 Notice of Violation 3

i Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information, if you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of l

protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania this 6 th day of August,1998 i

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