ML20239A114
| ML20239A114 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/28/1998 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Olivier L BOSTON EDISON CO. |
| Shared Package | |
| ML20239A116 | List: |
| References | |
| 50-293-98-06, 50-293-98-6, EA-98-337, EA-98-365, EA-98-387, EA-98-411, NUDOCS 9809080230 | |
| Download: ML20239A114 (5) | |
See also: IR 05000293/1998006
Text
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August 28,1998
EA 98-337
EA 98-365
EA 98-387
EA 98-411
Mr. Leon J. Olivier
Senior Vice President - Nuclear
BEC Energy
Pilgrim Nuclear Power Station
600 Rocky Hill Road
Plymouth, Massachusetts 02360-5599
SUBJECT:
NRC INTEGRATED INSPECTION REPORT NO. 50-293/98-06, NOTICE OF
VIOLATION, AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Olivier:
This report transmits the findings of the safety inspection conducted by NRC inspectors at
the Pilgrim Nuclear Power Station from June 9,1998 to July 25,1998. At the conclusion
of this inspection, these findings were discussed with you and members of your staff.
During the seven weeks covered by this inspection period, your staff operated the plant
safely. Based on the results of this inspection, the NRC has determined that violations of
NRC requirements occurred. Two of these violations are cited in the enclosed Notice of
.
Violation (Notice) and the circumstances surrounding them are described in detail in the
subject inspection report. Specifically, the violations involve aspects of your fire protection
- program. The first violation involved the NRC identification of a defect in an Appendix R
electrical raceway enclosure. The second violation involved inadequate corrective actions
in response to the findings from a 1996 fire piotection program quality assurance audit.
These violations are of concern because they reflect a lack of critical self-assessment by
the line organization; however, we did note that subsequently your corrective actions to
address these equipment and testing issues were prompt and thorough.
The NRC has concluded that an adequate description of the root cause analysis and
corrective action information has been provided in Licensee Event Reports 98-12 and 98-
13, NRC Inspection Report 50-293/98-05,and in this report. Therefore, you are not
required to respond to this letter unless the description therein does not accurately reflect
your corrective actions or position. In that case, or if you choose to provide additional
information, you should follow the instructions specified in the enclosed Notice.
We also reviewed several issues identified by your staff that are violations of NRC
requirements. Contrary to 10 CFR 50 Appendices A and B, members of your staff
identified four issues of inadequate design. These included: (1) the inadequate design of
the 4.16kV degraded voltage time delay relay setting; (2) the incorrect use of seismic
damping factors; (3) the incorrect plant system configuration during torus inerting
operations with the potential for suppression pool bypass leakage; and (4) on inadequate
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10 CFR50 Appendix R, Section lil.G control circuit configuration subject to a " hot short"
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L.' Olivier
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failure. The identification of these subtle design deficiencies demonstrated a rigorous
effort on the part of your staff. Corrective actions were comprehensive in addressing the
deficiencies. These issues are violations of NRC requirements, which could be considered
for escalated enforcement and be subject to a civil penalty. However, after consultation
with the Director, Office of Enforcement and the Regional Administrator, I have been
authorized to not issue a Notice of Violation and not propose a civil penalty in accordance
with the provisions provided in Section Vll.B.3 of the NRC's Enforcement Policy. This
decision for not citing the four design deficiencies was made after consideration that: (1)
the violations were identified by your staff's good questioning attitudes during voluntary
initiatives; (2) corrective actions, both taken and planned, were comprehensive and timely;
(3) the conditions were subtle in nature and not likely to be disclosed through routine
surveillance or quality assurance activities; and (4) the violations were not reasonably
linked to current performance. The exercise of discretion acknowledges your good effort
to identify and correct subtle violations, that would not be identified by routine efforts,
before the degraded safety systems are called upon.
Within the area of plant support, we found that you continued to implement effective
~
Radiological Environmental Monitoring and Meteorological Monitoring Programs. Your
contract environmental laboratory for sample analyses and quality assurance / quality control
continued to demonstrate excellence in laboratory practices. You conducted thorough
surveillance assessments for quality assurance of the Radiological Environmental
Monitoring Program and Meteorological Monitoring Program.
The responses directed by this letter and the enclosed Notice are not subject to the
clearance procedures of the Office of Management and Budget as required by the
Paperwork Reduction Act of 1980, Pub. L. No. 96.511. In accordance with 10 CFR 2.790
of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in
the NRC Public Document Room (PDR).
Your cooperation with us is appreciated.
Sincerely,
Original Signed By R. Crienjak for:
Charles W. Heh!, Director
Division of Reactor Projects
Docket No.
50-293
License No. DPR-35
!
Enclosures: -
2. NRC Inspection Report No. 50-293/98-06
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L. Olivier
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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
i
The Honorable Joseph Gallitano
T. MacGregor, Mass. Dept. Of Public Comm. & Energy
Chairman, Plyrnouth Boat'd of Selectmen
Chairman, Duxbury Board of Selectmen
Chairman, Nuclear Matters Committee
Plymouth Civil Defense Director
P. Gromer, Massachusetts Secretary of Ener0y Resources
J. Miller, Senior issues 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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L. Olivier
4
Distribution w/ encl:
Region i Docket Room (with concurrences)
PUBLIC
Nuclear Safety information Center (NSIC)
NRC Resident inspector
H. Miller, RA/W. Axelson, DRA
C. Cowgill, DRP
R. Summers, DRP
C. O'Daniell, DRP
R. Zimmerman, ADPR, NRR
J. Goldberg, OGC
J. Lieberman, OE
D. Holody, EO, RI -
T. Walker, ORA
Distribution w/enci (VIA E-MAIL):
B. McCabe, OEDO
C. Thomas, NRR (COT)
A. Wang, NRR
R. Correia, NRR
F. Talbot, NRR
DOCDESK
Inspection Program Branch, NRR (IPAS)
DOCUMENT NAME: G:\\ BRAN CH 5\\2-PG\\t N S PECT\\PIL9806.RV 1
To recohre e copy of this document, indicate in the bos: "C" = Copy without attachment / enclosure
'E' = Copy with attachment / enclosure
"N" = No copy
OFFICE
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DATE
8/6/98
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Distribution w/ encl:
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Region i Docket Room (with concurrences)
PUBLIC
Nuclear Safety information Center (NSIC)
NRC Resident inspector
H. Miller, RA/W. Axelson, DRA
C. Cowgill, DRP
R. Summers, DRP
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C. O'Daniell, DRP
R. Zimmerman, ADPR, NRR
J. Goldberg, OGC
J. Lieberman, OE
D. Holody, EO, RI
T. Walker, ORA
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D. Vito, ORA (Section E2.2, F1)
distribution w/ encl (VIA E-MAIL):
B. McCabe, OEDO ~
C Thomas, NRR (COT)
A. Wang, NRR
R. Correia, NRR
F. Talbot, NRR
DOCDESK
inspection Program Branch, NRR (IPAS)
DOCUMENT NAME: G :\\ BRAN CH 5\\2-PG\\lN SPECT\\PIL9806.RV 1
To receive a copy of this document. Indicate in the box: "C" = Copy without attachment / enclosure
Copy with attachment / enclosure
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- N* = No copy
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OFFICE
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