ML15306A497

Pilgrim - Reply to a Notice of Violation, Per Problem Identification and Resolution Inspection Report 05000293/2015010

ML15306A497
Person / Time
Site:	Pilgrim
Issue date:	10/30/2015
From:	Calabrese D Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.15.077, IR 2015010
Download: ML15306A497 (5)

See also: IR 05000293/2015010

Text

SEn tergyEntergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station600 Rocky Hill RoadPlymouth, MA 02360October 30, 2015U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT: Reply to a Notice of ViolationPilgrim Nuclear Power StationDocket No. 50-293License No. DPR-35REFERENCE:NRC Letter to Entergy, "Pilgrim Nuclear Power Station -ProblemIdentification and Resolution Inspection 05000293/201 5010 andNotices of Violation," dated October 1, 2015LETTER NUMBER: 2.15.077

Dear Sir or Madam,

This letter provides the information requested in the Notice of Violation received at PilgrimNuclear Power Station in the above referenced letter. The requested information is provided inthe Attachment to this letter.This letter contains no commitments.Should you have any questions concerning the content of this letter or require additionalinformation, please contact me at (508) 830-8227.

Sincerely,Manager, Emergency PreparednessDC/me

wAttachment:

Reply to a Notice of Violation (2 Pages)

PNPS Letter 2.15.077Page 2 of 2Cc:Mr. Daniel H. DormanRegional Administrator, Region IU.S. Nuclear Regulatory Commission2100 Renaissance Boulevard, Suite 100King of Prussia, PA 19406-1 415NRC Senior Resident InspectorPilgrim Nuclear Power Station AttachmentToPNPS Letter 2.15.077Reply to a Notice of Violation(2 Pages)

Attachment to PNPS Letter 2.15.077Page 1 of 2Reply to Notice of ViolationDuring an NRC inspection conducted from August 3 through 20, 2015, a violation of NRCrequirements was identified. The violation is associated with the following requirement:Violation No. Description201 5010-02 10 CFR 50.54(q)(2) requires, in part, that a holder of a nuclear powerreactor operating license shall follow and maintain the effectiveness ofan emergency plan that meets the requirements in Appendix E to thispart, and the planning standards of 10 CFR 50.47(b).10 CFR 50.47(b) (8) requires, in part, that adequate equipment tosupport the emergency response are provided and maintained.Contrary to the above, since December 2011, Entergy did not followand maintain the effectiveness of the Pilgrim Emergency Plan to meetthe requirement that adequate equipment to support the emergencyresponse was provided and maintained. Specifically, in December2011, Entergy cancelled preventive maintenance of the 160' back-upmeteorological tower, and that tower became non-functional. As aresult, on eight occasions between March 18, 2012, and August 15,2015, when the 220' primary meteorological tower was also non-functional for various reasons, Pilgrim did not have instrumentationavailable on either tower for continuous reading of the wind speed, winddirection, air temperature, and delta air temperature.

Attachment to PNPS Letter 2.15.077Page 2 of 2VIOLATION 201 5010-02 -Failure to Maintain Station Meteorological TowersReason for the ViolationDuring the 2015 NRC Problem Identification and Resolution (PI&R) Inspection a Green Noticeof Violation (NOV) was issued for failure to follow and maintain the effectiveness of the PilgrimEmergency Plan to meet the requirement that adequate equipment to support the emergencyresponse was provided and maintained. The failure to properly maintain the 220' tower andrestore or replace the 160' tower was previously identified in Non-Cited Violation (NCV)2013008-02 issued for violation of 10 CFR 50.54(q)(2). The 2015 PI&R inspection determinedEntergy did not address the adverse condition within a reasonable period of time after the NRCdocumented the initial Green NOV.An organizational performance gap existed in that the meteorological towers performancemonitoring and issue resolution did not have a single point of ownership, such that the priority toresolve issues was not properly evaluated to ensure timely resolution. As a consequence,previously identified corrective actions were untimely with inadequate organizationalengagement to monitor performance or resolve issues.Corrective steps' that have been taken and the results achievedThe Emergency Preparedness Department (EPD) has taken ownership of the meteorologicaltowers. The EPD obtained the necessary project funding, engineering design support, andinstallation support to install the replacement 160' tower. The tower structure is in place. Themeteorological instruments have been installed. Post installation testing of the instruments anddata communication system is in progress.The Regulatory Assurance Weekly Report was modified to include a "deadline" date forcompletion of corrective actions associated with regulatory findings. Additionally, a RegulatoryAssurance review has been incorporated as a required element for corrective actionsassociated with NRC Findings.Corrective steps that will be takenPost installation testing of the new 160' tower will be completed and the tower placed in service.Date when full compliance will be achievedThe current schedule for resolution is on or before December 16, 2015, at which time fullcompliance to the NRC requirements will be achieved.