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| {{Adams | | {{Adams |
| | number = ML20154F934 | | | number = ML20197F525 |
| | issue date = 05/17/1988 | | | issue date = 06/06/1988 |
| | title = Insp Rept 50-293/88-11 on 880314-18.No Violations or Deviations Noted.Major Areas Inspected:Emergency Operating Procedures,Including Comparison of Plant Specific Guidelines & BWR Owners Group Guidelines with Emergency Procedures | | | title = Forwards Safety Evaluation Accepting Util 871120 & 1214 Submittals of Facility Procedures Generation Package as Required by Suppl 1 to NUREG-0737.Unresolved Items Noted in Insp Rept 50-293/88-11 Must Be Resolved |
| | author name = Lange D | | | author name = Mcdonald D |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | | | author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR) |
| | addressee name = | | | addressee name = Bird R |
| | addressee affiliation = | | | addressee affiliation = BOSTON EDISON CO. |
| | docket = 05000293 | | | docket = 05000293 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-293-88-11, NUDOCS 8805240135 | | | case reference number = RTR-NUREG-0737, RTR-NUREG-0800, RTR-NUREG-0899, RTR-NUREG-737, RTR-NUREG-800, RTR-NUREG-899 |
| | package number = ML20154F931 | | | document report number = GL-82-33, TAC-44328, NUDOCS 8806140014 |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | package number = ML20197F530 |
| | page count = 17 | | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | | page count = 2 |
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| {{#Wiki_filter:____ -________ | | {{#Wiki_filter:' |
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| | , June 6, 1988 Docket No. 50-293 Mr. Ralph ' |
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| | Senior Vice President . Nuclear Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 |
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| U.S. NUCLEAR REGULATORY COMMISSION
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| ==REGION I==
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| Report No. 50-293/88-11 Docket No. 50-293 License No. DPR-35 l
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| Licensee: Boston Edison Corpany ECO Boylston Street Toiifo~n, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plyrouth, Massachusetts, _
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| Inspection Conducted: March 14-18, 1988 Inspectors:
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| W. Kennedy, NRR Team Leader D. Florek, Sr. Operations Engineer, DRS, RI C. Sisco, Operations Engineer, DRS, RI G. Thomas, Nuclear Engineer, NRR R. Gruel, Operator Licensing Examiner, PNL L. Meyers, Research Psycholegist, BCL Approved by:
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| D.' Lange, Chi gTd / 3
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| SKR 5ection
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| / de e hspection Sumary: Inspection on March 14-18, 1988 (Report No. 50-293/88-11)
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| Aress Inspected: Special announced team inspection by 2 regional inspectors, H eadquarters personnel and 2 centractors of the emergency operating pro <:edures (EOPs) and quality assurance measures. This included a cerparison of the Plant Specific Guidelines and BWR Owners Group Energency Procedure Guidelines (EPGs) with the E0Ps; cor.parison of Pilgrim Writer's Guide with the E0Ps; walkthrough of selected E0Ps and Satellite Procedures; E0P evaluation using simulator scenarios; qualifications of E0P responsible individuals, review of ECP training progran; review of E0P verification and validation, and review of E0P Quality Measure PDR 880517 O
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| ADOCK 05000293 DCD
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| | ==Dear Mr. Bird:== |
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| | SUBJECT: PILGRIM PROCEDURES GENERATION PACKAGE . SAFETY EVALUATION REFERENCE: TAC # 44328 By letters dated November 20, 1987 and December 14, 1987 you submitted the Pilgrim Procedures Generation Package (PGP) which +;as revised by a letter dated April 6, 1988. Enclosed is the staff's safety evaluation of the Pilgrim PGP required by Supplement 1 to NUREG-0737, "Requirements for Emergency Response Capability" (Generic Letter 82-33). The review was conducted in conjunction with the Emergency Operating Procedure (EOP) |
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| | inspection the week of March 14. The results of the inspection are documented in Inspection Report No. 50-293/88 11, dated May 17, 1988. Four unresolved itects in relation to the implementation of the E0Ps are noted in the inspection report. |
| 2-Results: No violations or deviations were identified in the inspection. The inspection concluded that the E0Ps were implerrented in acccrdance with the Revision 4 of the BWR Owners Group EPGs and the plant's Procedures Generation Program; however, 4 unresolved items were identified. One unresolved item involved a sequence of actions in an E0P different from that specified in the EPG (See Section 4). A second unresolved item concerned the inspectors'
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| inability te evaluate the adequacy of the procedures supporting the E0Ps, called satellite procedures, due to the incerrplete status of the facility walktitrough (See Section 8). The third unresolved item concerned procedures and training associated with containment venting (See Section 4 and 8). The fourth item concerned the lack of continued involvement of QA in the E0P procedures program (See Section 11).
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| | Based on our review, we conclude that, the revised Pilgrim PGP adequately addresses the requirements stated in Generic Letter 82-33 (Supplement 1 to , |
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| | NUREG.0737) and provides acceptable methods for accomplishing the objectives stated in NUREG-0899 in accordance with the guidance provided in the Standard |
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| | ReviewPlan(NRUEG.0300). |
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| | Inis completes our action related to the above referenced TAC number. The unresolved items noted in the inspection report referred to above must be resolved. |
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| DETAILS Persons Contacted BEco and BEco Contractors
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| * J. Alexander, Operations Section Manager
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| * H. Balfour, License Training Section Manager
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| * F. Barresi, Nuclear Training Development R. Barrett, Operations Department Manager
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| * R. Bird, Senior Vice President, Nuclear
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| * C. Brennion, Senior S&SA Engineer
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| * R. Brune, Human Factors, HPT
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| * M. Davis, Consultant, Engineer, Ciel Consultants In J. Fulton, Assistant Vice President Engineering
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| * J. Gerety, Senior S&SA Engineer
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| * R. Grazio, Field Engineering and Regulatory Affairs Manager
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| * R. Hamilton, Compliance Division, Manager
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| * K. Highfill, Station Director B. Horsman, Reactor Operator
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| * J. Howard, Vice President, Nuclear Engineering and QA
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| * G. Humes, Reactor Operator C. Leonard, Nuclear Operations Supervisor
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| * P. Mastrangelo, Chief Operations Engineer J. Mattici, QA Audit Division Manager
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| * W. Olsen, Nuclear Watch Engineer T. Phipps, Reactor Operator S. Powers, Reactor Operator S. Rogers, Executive Consultant OEI M. Santiago, Senior Training Specialist
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| ! * F. Sche 11inger, Quality Engineering Division Manager
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| * J. Schilder, Senior Consulting Engineer, OEI R. Swanson, NED Manager K. Taylor, Nuclear Watch Engineer
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| * T. Trepanier, Senior Operations Engineer
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| * E. Ziemianski, Nuclear Training Manager U.S. Nuclear Regulatory Commission
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| * T. Kim, Resident inspector
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| * D. Mcdonald, Project Manager, NRR
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| * C. Warren, Senior Resident Inspector
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| * denotes those present at the exit meeting held on March 18, 1988. The inspectors also contacted licensed operators, engineers, technicians, and other personnel in the course of the inspectio . Inspection Objective / Approach This inspection was performed to determine whethe*, the Pilgrim Emergency Operating Procedures (EOPs) had been prepared in accordance with the current Procedure Generation Package (PGP) and whether the E0Ps and associated
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| | Sincerely, Original signed by: |
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| | Daniel G. Mcdonald, Senior Project Manager l Project Directorate I-3 ' |
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| | Division of Reactor Projects I/II i |
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| satellite procedures had been adequately implemented in the plan The specific areas inspected include the following:
| | 1. Safety Evaluation ; |
| - Review of the technical qualifications of E0P developers
| | 8806140014 880606 3 I cc: w/ enclosures: PDR ADOCK 050 See next page P 1 Distribution: Docket FilefNRC & Local PDRs, PDI-3 r/f, RWessman, RBoger, l |
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| | .Vushbrook, DMcDonald, OGC, EJordan, JPartlow Tech Branch, ACRS (10), ' |
| Comparison of the EPG, PSTG technical basis with the E0Ps
| | JWiggins Region I, WKennedy, WRegan, WHodges, JCraig, TMurley, AThadani |
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| Comparison of the writer's guide with the E0Ps
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| Review of the E0P verification and validation
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| Walkthrough of selected procedures in the plant
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| Review of training on the E0Ps
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| - Exercising Procedures in the simulator
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| Review of the E0P quality assurance measures 3. Qualifications of Individuals Responsible for E0P Development A review was conducted to determine if the E0Ps were developed and reviewed by a multidisepline team of technically qualified individual The licensee development team consisted of BEco personnel from the Engineering an Training organization, augmented with consultants from Operations Engineering, Inc. (0EI), Human Performance Technology (HPT),
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| and Ciel Consultants, Inc. OIE, as consultants to the BWR Owners Group on the development of the EPGs, provided engineering expertise in the development of the plant specific technical guidelines (PSTGs) and the validation effort. HPT provided Human Factors consulting and CIE assisted in the verification proces A review of the technical background of the team as well as interviews with the team members determined that the members were well qualified and a multidisciplined tea The inspector reviewed the Onsite Review Committee meeting minutes #87-136 and determined that the E0Ps were reviewed in accordance with Technical Specification . Comparison of Plant Specific Technical Guidelines, BWR Owners Group Emergency Guidelines and E0Ps This review included a comparison of the plant-specific technical guidelines (P-STGs) with Revision 4 of BWR Owners Group Energency Procedure Guidelines (EPGs) and a comparison of the E0Ps with the P-STGs. Plant specific values in the E0Ps were also assesse .1 EPG/P-STG Review No safety-significant deviations were found between Revision 4 of the EPGs and the P-STGs. However, since Revision 4 has not been formally reviewed
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| -5-by the NRC, the future Safety Evaluation Report on Revision 4 may indicate the need for licensee action on the P-STGs and the E0P .2 P-STG/EOP Review All E0Ps and those portions of satellite procedures which contained steps based on the P-STGs were compared to the P-ST The following differences were note The licensee's review process had also identified some of these findings as indicate E0P-1: RPV Control Severai action steps within the RPV Level and F sure sections of this procedure had not been linked by appropriate marking to the appropriate note. The licensee stated that this concern had been previously identified and was under revie E0P-2: Failure to Scram A decision step (presented in a box) within the RPY Level section of this procedure regarding reactor power level did not provide direction for the condition of power level not being able to be determine Such direction is provided in an "override" statement which pertains to the next ste The licensee stated that this concern had been previously identified and was under revie Inconsistencies were noted in procedure branchin The licensee stated that those inconsistencies had been identified and were under revie E0P-3: Primary Containment Control Primary containment venting was allowed by procedure after torus pressure exceeds 11 psig but before reaching the Primary Containment Pressure Linit (PCPL; 48 psig) irrespective of resultant reactivity release rate. Procedure 5.4.6 stated that venting, irrespective of resultant reactivity release rate, was appropriate only when the primary containment pressure is above the PCPL (or when drywell or torus hydrogen concentration was above 6%). The licensee stated that they will revise the procedures to remove the inconsistency and instruct operators to vent before_ reaching the PCP PSTG steps PC/H-2.1 (suppression chamber spray), 2.2 (torus or drywell vent), 2.3 (purge), and 2.4 (drpell spray) were reordered in the E0P in the order of: 2. 2, 2. 3, 2.1, 2. The licensee had not previously identified this potential safety-significant deviation. Either analysis of the acceptability of E0P sequence or procedure revision to match the PSTGs is require This is an unresolved item (50-293/88-11-01).
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| -6-4.3 Satellite Procedures Review 5.3.23: Alternate Rod Insertion ;
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| An instruction regarding reset of alternate rod insertion was missing from this procedure. The licensee stated that this omission had been previously noted and is under revie .4.6: Post Accident Containment Control (Venting)
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| The procedure directed using both a small vent path (1 or 2 inch valves) and a large path (through 8 inch valves) for containrent ,
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| ventin In some scenarios it may not be necessary to open both sets of valves if after opening only the 2 inch or the 1 inch valves the the containment pressure is controlled appropriately. The licensee agreed to revise the procedure or justify not revising i A caution contained the words "If at all possible, ... shall ...".
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| This statement did not provide clear direction to the SR The licensee agreed to revise the procedure or justify not revising i Step 2 of Attachment A of this procedure stated that the E0P is applicable when primary containnent pressure reaches 2.5 psig, as opposed to above 2.5 psi The licensee agreed to revise this statemen The caution statement about rupture of the ductwork with venting did not include notification of health Physic The licensee agreed to rovise the procedure or justify not revising i Step 2 of Attachment A of this procedure was missing a statement regarding opening the appropriate valves as necessary to perform the ste The licensee agreed to consider revising this stateren !
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| Step 3 of Attachment A of this precedure did not provide cicar direction to the operator on the value of primary containment pressure to terminate torus ventin The licensee agreed to revise the procedure or justify not revising i The items concerning containment venting will be collectively included as part of unresolved items 50-293/88-11-0 See Section 8 for additional containment venting item ,
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| 5. Comparison of E0P Writer's Guide With E0P All E0Ps were reviewed to determine if they fc11 owed the guidance provided
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| in the licensee's Writer's Guide. The licensee verbally committed to evaluate the following comrents, and to rodify the E0Ps or the Writer's Guide at, appropriat l
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| -7-5.1 Cautions, Notes and supplemental Information
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| - Blocks of supplemental information are used in E0Ps 01, 02, 06, and 09. The Pilgrim Writer's Guide does not provide guidance as to what information is to be placed within supplemental information block .2 Logic Terms and Conditional Statements In E0P-03, Drywell Temperature, second action block, the BEFORE statement does not follow the format stated in the writer's guide. This also occurs in E0P-0 The term EXCEPT is used several times in E0P-04 and 0 The use of this term places exceptions after an action step. In these statements, the operator is told do something which he or she may go ahead and do before reading the rest of the statement which includes the exception .3 Action Steps Throughout the procedures there are action steps which state something "IS REQUIRED." However, this construct, its format and use are not addressed in the writer's guid Some of the steps in the sample flowcharts are long and complicate For example, in E0P-04, "Reset the secondary containment isolation and restart reactor building H & V, defeating high drywell pressure and 1cw RPV water level isolation interlocks if necessary." This step contains many action Furthermore, this step does not explain under what conditions it would be necessary to defeat the high drywell pressure and 1cw RPV water level isolation interlocks. Another example of a step that is too long is from E0P-01, "Irrespective
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| of whether adequate core cooling is assured, terminate injection l into the RPV from sources external to the primary containment UNTIL primary containment water level and torus pressure can be
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| maintained below the MPCWLL." In E0P-02, near the end of Reactor Power, there is a BEFORE statenent whose action reads, "BORON INJECTION IS REQUIRED."
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| This action statenent does not follow the format for BEFORE statenents, In E0P-02, in the next instruction block, the two numbered actions are prefaced with the word "either". The word "either" implies that the operator can perform either step 1 or step However, this may not be the cas This construction is not addressed in the writer's guid , _ - - - - - - _ - - - - - - - - - - . - - - - - - - -
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| 5.4 Referencing and Branching Throughout the procedures the phrase "appropriate section of Procedure..." is used to refer the operator to another procedure. More specific directions appear necessary, The writer's guide specifies a number of methods to refer the operator to other procedure However, there are reference statements which do not follow any of the methods in the Writer's Guide. For example, in E0P-01 the phrase "enter and concurrently execute Procedure 2.6.1..." is used. In E0P-02 the phrase "Insert control rods using one or more of the methods detailed in Procedure 5.3.2.3..." is use .5 Flow of Information In E0P-02, path A is difficult to follow and some method is needed to help indicate the direction of flo .6 Miscellaneous In E0P-03 Torus Water Level, in the first action step, the acronym PASS is used; this acronym is not defined in the Pilgrim Writer's Guid In E0P-03, Drywell Temperature, the first six-Sided symbol does not contain a ccma after the IF or AND statements. Also, in the last two BEFORE symbols a coma is not placed after the before statement, In E0P-03, Hydrogen and Oxygen Concantrations, when Hydrogen concentrations are referred to the format is inconsistent. The first instance a decimal is used, i.e., 1.0% and in the remainder instances no decimals are used, i.e., 5% and 6%.
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| 5.7 Satellite Procedures The Attachments to 5.7.3.2 are very difficult to rea . E0P Verification The verification program at Pilgrim was reviewed and compared to the E0P Verification Program description submitted in the PGP. Tha contractor who performed the verification, and cognizant plant personnel, were interviewe A variety of documents were reviewe The documentation included:
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| - Completed and signed verification forms
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| - Interim report on discrepancies
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| - List of open verification items
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| - Operator comments
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| . The documentation appeared thorough and complete and the licensee's discrepancies were well defined and describe . E0P Validation The validation program at Pilgrim was reviewed and compared to the Validation Program Description submitted in the PG To perform this review the contractors (Ciel Inc. and Human Performance Technologies Inc.) | |
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| who performed the validation were interviewe A variety of documents were reviewe The documentation included:
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| - Completed and signed validation forms, checklists, and questionnaires
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| - Resumes of participants
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| - Scenarios used during the validation process
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| - Copies of E0Ps showing which paths / steps were validated For each scenario the paths / steps for each E0P used were traced on copies of the E0Ps using a color cod At the end of validation this method showed how much of each E0P had been validated both through the simulator exercises and the talkthroughs. An examination of a sample of these E0Ps showed that all paths / steps had apparently been validate The documentation appeared thorough and complete and the licensee's discrepancies were well defined and describe . Walkthrough of Emergency Operating Procedures and Satellite Procedures Inspectors, with facility licensed operators, walked through portions of the following procedures in the Control Room and in the plant to assess whether the procedures were capable of being perforced when required. The procedures walked through included both the E0Ps and the satellite procedure E0P-02 RPV Control E0P-03 Primary Containment Control 5.3.26 RPV Injection During Emergencies 5. Primary Containment Venting and Purging 5.3.23 Alternate Rod Insertion The inspectors assessed the consistency of terminology between the plant labels and procedures, access to the equipment, clarity of instructions, availability of information to conclude the action should be taken and overall useability of the procedur During the walkthrough the inspectors identified several items that needed facility actions to correc These are detailed in Attachment C and summarized belo The inspectors identified concerns relctive to plant labeling (either missing, inadequate or not consistent with procedure nomenclature), the availability / control of jumpers / tools required to perform selected E0P actions, the clarity of procedures to direct operators to a specific location to perforn the required task, accessibility of equipment, and completeness of procedur _ _ _ _ - _ - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ ____ _______ _-_____
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| A number of the E0P-related items identified by the inspectors had also been identified by the facility review process and actions were being taken to address the observed problems. However, the facility review of the satellite procedures was still in progress even though the procedures '
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| were approved and issued, i.e., they had not yet finished their own walkthrough of the satellite procedures. Furthermore, the operations management agreed to assure that the plant labeling was consistent with the E0Ps and satellite procedures. Therefore, pending further NRC review folicwing completion of the facility walkthrough of the satellite procedures and the licensee actions to correct the identified deficiencies, this item will retain unresolved (50-293/88-11-02).
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| One item identified during the walkthrcugh of the E0Ps was an apparent need for additional training on when to initiate and when to terminate venting of the containment in accordance with the intent of the EPGs and the procedures. Items concerning centainment venting will be considered
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| an unresolved item (50-293/88-11-03). See section 4 for additional '
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| containment venting item . E0P TRAINING A representative of the Pilgrira Training Center (a lead instructor, heading up the Phase II E0P trainirg) was interviewed to determine if the
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| current E0P training program matched that described in the Training
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| Program Description in the PG A nutber of training related documents were also reviewe This *
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| - Scenarios used during siculator training l All docurentatien appeared ccrplete and thoroug Hewever, the training I program description included in the PGP is no longer applicable. This .
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| progran freferred to as Phase I) was executed, but had seme difficulties which the licensee believed may have contributed to an original unsuccess- ,
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| ful validation. As a result, the licensee revarped the training progra The licensee needs to prepare a revised Training Progran Description fer i their current ECP training and submit this description as a part of a revised PG The training representative stated that they were preparing i
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| -11-The training program, Phase II (80 hours), was a combination of classroom and simulator training. As of the inspection, about 50% of the operators had been trained in Phase II. Pilgrim plans to have all operators trained by May 198 . E0P Evaluation Using Simulator Scenarios A shift operatiag crew in the fine' stage of operator training on E0Ps was observed in the Pilgrim simulator to determine if 1) the operators are familiar with their responsibilities and required actions during an emergency, 2) the E0Ps and E0P satellite procedures can be performed by the minimum staff 3) operators do not physically interfere with each other while performing the E0P, and 4) transitions from one procedure to others are appropriately directed by the E0P The shift operating crew consisted of 2 SR0s, 3 R0s, an STA and a shift clerk. This crew size is larger that that required by the Pilgrim Techni-cal Specifications, but specified in the administrative procedures. The crew was exposed to three NRC generated evaluation scenarios which required entry into several E0Ps (i.e. E0P-1, 2, 3, 4, 6 and 7) and their apprcpriate satellite procedures ( .1.5, 2.1.6, 5.3.21, 5.3.23, 5.3.26,5.4.6,5.7.3.2).
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| Operators did not physically interfere with each other during their conduct of the scenarios, and transitions were appropriately designate Some procedural usage problems were encountered during the conduct of the scenarios, but these problems were attributed to the level of operating training (i.e., the operators had not completed their E0P training).
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| The inspector concluded that the E0Ps and E0P satellite procedures could be performed by the crew.
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| l 11. E0P Quality Assurance Measures
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| A review was conducted to determine if Quality Assurance Measures are adequate to ensure that high quality E0Ps are developed, implemented and maintained, i The QA measures associated with the development of the E0Ps were found to be acceptable, based on discussions with the Quality Engineering Division Manager and Senior Quality Engineer. However, it was concluded that a programatic approach to ensure the continued quality of the E0Ps through aud,ts of the maintenance of the E0Ps did not exist in the area of auditing of the E0P progra In subsequent discussions with the Vice President, Nuclear Engineering Division and Quality Assurance management BEco comitted to revise the
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| 1988 Internal Audit Schedule to include an annual audit of the E0P l progra This audit will be performed as a Safety Syster Audit in the I fourth quarter of 198 The procedura11 ration of continued quality l assurance measures is an Unresolved Item (50-293/88-11-04).
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| l 12. Exit Interview An exit meeting was held on March 18, 1988 to discuss the inspection scope ;
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| and findings as detailed in this report (see paragraph-1.0 for attendees).
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| Written inspection findings were not given to the licensee. The facility i did not indicate that proprietary information was utilized during this !
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| Attachment A i i
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| Documents Reviewed
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| Plant Procedures Pilgrim Nuclear Power Station Plant Specific Technical Guidelines, Revision 3 l Appendix to the Pilgrim Nuclear Power Station Plant Specific Technical Guidelines .
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| Procedure 1.3.4-10 Writers Guide For Emergency Operating Procedures, ,
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| Revision 2, Dated October 15, 1987 !
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| Procedure 1.3.4-13 E0P Verification Program, Revision 1 Dated October 16, 1987 Procedure 1.3.4-14 E0P Validation Program, Revision 0. Dated July 10, 1987 Pilgrim Nuclear Power Station E0P Training Program Surmiary Description Attachment 4 to BECo 1.etter 87-185 E0Ps E0P-01 RPV Control, Revision 0. Dated November 18, 1987 E0P-02 Failure to Scram, Revision 0, Dated November 18, 1987 E0P-03 Primary Containment Control, Revision 0, Dated November 18, 1987 i
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| E0P-04 Secondary Containment Control, Revision 0, Dated November 18, 1987 ,
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| l E0P-05 Radioactivity Release Control, Revision 0, Dated November 18, 1987 '
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| I E0P-06 RPV Flooding, Revision 0, Dated November 18, 1987 l E0P-07 Alternate RPV Depressurizaticn, Revision 0, Dated November 18, 1987 ;
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| E0P-08 Steam Cooling, Revision 0, D ned November 18, 1987 ;
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| E0P-09 Prinary Containment Flooding, Revision 0. Dated November 18, 1987
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| i E0P Satellite Procedures Procedure 5. Primary Containment Venting and Purging Under Emergency Conditions, Revision 17 Dated September 3, 1987 Procedure 5.3.21 Bypassing Selected Interlocks, Revision 4 Dated October 14, 1987 '
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| Procedure 5.3.23 Alternate Rod Insertion, Revision 1 .
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| Dated December 4, 1987 ;
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| Procedure 5.3.26 RPV Injection During Emergencies, Revision 0 Dated August 30, 1987 i
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| ' | | Mr. Ralph Boston Edison Company Pilgrim Nuclear Power Station |
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| Attachment B Coments with Respect to the Pilgrim Proce$ ires. Writer's Guide Note: These comments were a result of a comparison of the Writer's Guide ,
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| with guidanco given in NUREG-089 ; Cautions and Notes Cautions and notes provide operators with critical and useful information concerning steps or sequences of steps in E0Ps. The discussion of cautions and notes in the Writer's Guide lack some specific (a) Section III.A.13 states that "notes shall be ... placed within the !
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| respective flowchart element, located innediately preceding or following the associated text." Notes should be read and comprehended by the operator prior to the step (s) they refer to, not after. Notes should only be placed immediately prior to the step, not following it, as suggested in the guidanc The phrase "following the associated text." should be delete (b) Section III.A.12 discusses "supplemental information". However, the writer's guide does not define supplemental information or how it .
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| differs from notes. The writer's guide does not tell the writer when !
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| to use supplemental information instead of notes or vice vers (c) There is no guidance provided as to the use of capitalization in ,
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| (d) When cautions and notes contain multiple topics the importance of any i one topic is obscure l
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| . Logic Statements Logic statements are used in E0Ps to describe a set of conditions or a i sequence of actions. Because logic statements can be confusing, it is ,
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| important to provide explicit guidance for their us [
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| (a) Table 1 includes the word EXCEP In logic statements using EXCEPT, the conditions follow the actions which may lead operators to perform i the actions before reading the conditions. An approach should be used where all conditiers are read prior to the actions such as in a :
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| Note or Caution (which ever would apply); or word the statement to c specify only the actions to be taken and not exceptions. For i example, in Example 11 on Page 11 of the Writer's Guide, the 1
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| | Mr. K. L. Highf111 Boston Edison Company Station Director ATTN: Mr. Ralph Pilgrim Nuclear Power Station Senior Vice President - Nuclear RFD #1 Rocky Hill Road 800 Boylston Street Plymouth, Massachusetts 02360 Boston, Massachusetts 02199 Resident inspector's Office Mr. Richard N. Swanson, Manager U. S. Nuclear Regulatory Comission Nuclear Engineering Department Post Office Box 867 Boston Ed! son Company Plymouth, Massachusetts 02360 25 Braintree Hill Park Braintree, Massachusetts 02184 Chairman, Board of Selectmen 11 Lincoln Street Ms. Elaine D. Robinson Plymouth, Massachusetts 02360 Nuclear Information Manager Pilgrin Nuclear Power Station Office of the Comissioner RFD #1, Rocky Hill Road Massachusetts Dopartment of Plymouth, Massachusetts 0?360 Environmental Ouality Engineering One Winter Street Charles V. Berry Boston, Massachusetts 02108 Secretary of Public Safety Executive Office of Public Safety Office of the Attorney General One Ashburton Place 1 Ashburton Place Roston, Massachusetts 0?108 20th Floor Boston, Massachusetts 02108 Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of |
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| -2- Attachment B (b) Using the logic term THEN at the end of an action to instruct the operator to perform another action in the same step runs actions together which may be overlooked or may be confused with logic statements. For example: "Do A. THEN B. THEN C, THEN D." should not be used. The writers' guide sheuld state that THEN will not be used to run action steps together. Further, the word "then" should not be used other than as a logic term to avoid operator confusion as to its meanin In the following example, "If A. THEN B and THEN C" the
| | i Public Health i 150 Tremont Street 2nd Floor l Boston, Massachusetts 02111 1 I |
| "and" and second "then" should not be use . Flow charts Flow charts can be a valuable means of presenting important information to operators and nust be formatted and written efficiently and effectivel The writer's guide states that concurrent flows of steps shor.1d be spaced to "achieve a balanced presentation." This is ambiguous guilance. For example, it could mean that a short flowpath containing a foi steps should be stretched out to balance out a concurrent long flow conk ;ning many steps for appearance sake. As another example, it could mean that certain symbols in cuncurrent flows should be placed side by side to achieve overall visual balanc . Emphasis Techniques The proper use cf emphasis techniques rekes the procedures easier to understand. The use of uppercase letters i; discussed on page 20 of the Writer's Guide, but the use of all caps versus the use of initial caps and lower case is somewhat ambiguous. For example, it is clear that the word START is all caps, and section designators are upper and lower case, because examples are given. But, the writer's guide does not make it clear for each application whether all caps are to be used, or initial caps onl . Divisions, Headings, Numbering It is important that a consistent method of section heading and step numbering be used throughout E0Ps. The use of overall headings and an alpha-numeric numbering systen for each step is usually needed so that operators can keep track of where they are in the procedure and know how to move easily and quickly to other parts of the procedur The flow charts have a system of titles and a numbering system to identify procedures and overall headings for flow sequences. However, there is no alpha-numeric numbering system for sections or syrbols within the flow chart. This makes it difficult to refer to a section or symbol and an operator may not be able to keep track. For example, if one operator wants to indicate a particular step to another operator there is no easy to way to verbally refer to the section or syrbol.
| | Regicnal Administrator, Region I U. S. Nuclear Regulatory Comission - |
| | | 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. James D. Keyes 3 Regulatory Affairs and Programs Group Leader Boston Edison Company 25 Braintree Mill Park ! |
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| -3- Attachment B
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| ' Tables / Figures / Printed Aids Figures and tables assist operators to make decisions and to locate informatio (a) The writer's guide states that the units used on the axes of graphs on page 15 should correspond to those of associated control room instruments, but the same guidance is not given for tables discussed on page 1 (b) Because unnecessary information may clutter figures and tables and confuse operators, all figures and tables should contain only information that is needed by operators and is relevant to the tex . Location Information for Equipment, Controls, Displays It is important that the operators know where to find all of the instrumentation and controls that are referenced in the E0P The writer's guide (on page 29) provides criteria to determine if
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| location information should be put in a step. However, this guidance does not state the basic format for the information statement er provide an exampl . Formatting Writers should be given sufficient information in the writer's guide to produce procedures that are consistently formatte The writer's guide states that for boldface type a slightly larger type size should be used. This larger type size should be specified. The guide also mentions varying thicknesses of lines to be used in the flow chart The guide should provide guidance on thickness size .
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| Attachment C NRC Observations in Walkthrouch of E0Ps and Satellite Procedures Control Rocm Indicator TI-9019 did not have a label to indicate it was for drywell temperature. The facility was in process of correctin . Relays in general (and specifically RPWP1) had labels which were masking tape with information written on it. These labels were inadequat Facility operations management agreed to assure all labels fe E0Ps/
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| satellite procedures were correct and consisten . Relay Terminals used as jumpering locations in panel C170 v v e not clearly marke . Procedure 5.4.6 did not direct evacuation of the reactor building prior to initiating containment venting although it did contain a caution that venting may result in rupturing some lines in the reactor buildin . Procedures have no description or different word description than plant labels. Several examples were noted. A few examples were: E0Ps refer to torus temperature whereas plant label refers to bulk torus temperatur .3.23 referred to "l10-302-8" with no description. Whs a the plant label has a clear description of this valve. In procedure e.4.6 the 2" drywell vent valve A0-5043A was referred to in the plant label as 2" drywell vent exhaust valve f2 A0-5043A. (Facility actions are discussed in coment 2 above.)
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| l Procedure 5.3.23 required the operator to increase flow using valve FCV-302-6A(B). Actual o>erator practice was to use controller FC-340-1 to increase system flow witiout any procedure direction to this controlle . At the RPS test channel switches, in one channel the switches were located above the labels and the other channel the switches were located below the label . A label was missing on the 8" drywell purge exhaust valve ( . In procedure 5.3.26, the location of the spool piece to be inserted is between two valve The valves are located on two plant elevations (different rcoms) and were not within eyesight. The location in the plant is not specified in the procedure. Instruction was not provided in the procedure or 1ccally on how to install the spool piece or the additionally necessary step to connect the local instrumentatio . The location of vent valve 3/4 YT-120 was abeut 20 ft overhead and use cf a ladder was required to operate the valve. The facility reportedly evaluated the need to operate this valve and had initiated actions to change the procedure to not use this valv _ . . _ _ _ - . _ . . _ . _ _ . . _ . . . . . . | | l i |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 1999-09-09
[Table view] Category:NRC TO UTILITY
MONTHYEARML20062E0071990-11-14014 November 1990 Forwards List of Unimplemented GSIs at Facility,Per Generic Ltr 90-04 ML20062D6651990-11-0808 November 1990 Ack Receipt of Forwarding Util Evaluation of NRC Inspector General Rept 90N-02 Re Offsite Emergency Planning ML20058G9761990-11-0707 November 1990 Forwards Safety Insp Rept 50-293/90-20 on 900816-1008 & Notice of Violation ML20058C5501990-10-26026 October 1990 Requests Written Policies & Procedures Needed for NRC Preparation for Planned fitness-for-duty Insp ML20062B4311990-10-17017 October 1990 Advises That 901012 Response to Generic Ltr 90-03 Re Vendor Interface for safety-related Components,Acceptable ML20062B7161990-10-12012 October 1990 Extends Invitation to Attend 910220-21 Util Symposium/ Workshop in King of Prussia,Pa Re Engineering Role in Plant Support.Interest to Participate,Intent to Attend & Approx Number of Representatives to Attend Requested by 901115 ML20062B6281990-10-12012 October 1990 Forwards Insp Rept 50-293/90-21 on 900905-07.Insp Conducted to Review Event of 900902-03 Which Involved Number of Component Malfunctions & Operational Complications Following Shutdown ML20059N7251990-10-0101 October 1990 Requests That Matls Listed in Encl Be Furnished to Assist Maint Program Team Insp Scheduled for 901105-16 ML20059K6901990-09-11011 September 1990 Forwards Transcript of 900906 Public Meeting in Plymouth,Ma W/State & Local Officials Re Emergency Planning.W/O Encl ML20059H5871990-09-0101 September 1990 Advises That Reactor Operator & Senior Reactor Operator Exams Scheduled for 901203.Encl Listed Ref Matl Requested ML20059J6521990-08-29029 August 1990 Forwards Safety Insp Rept 50-293/90-09 on 900806-10.No Violations Noted.Concludes That Engineering & Technical Support Organizations Continue to Provide Strong Station Support ML20059A1481990-08-17017 August 1990 Forwards 900816 Summary of 900807 Meeting Re Inservice Testing Program ML20058P0471990-08-0909 August 1990 Forwards Safety Insp Rept 50-293/90-18 on 900709-13.No Violations Noted ML20058N0401990-08-0606 August 1990 Discusses Licensee Engineering Initiatives.Power Reactor Licenses in Region 1 Should Initiate Similar Program to Provide Sharing of Info & Experiences Involving Engineering Initiatives & Solution to Problems Common to All ML20056A4801990-07-30030 July 1990 Forwards Safeguards Insp Rept 50-293/90-16 on 900625-29.No Violations Noted.One Unresolved Item Identified ML20058L7051990-07-27027 July 1990 Forwards Safety Insp Rept 50-293/90-17 on 900625-29.No Violations Noted ML20055F2461990-06-29029 June 1990 Forwards Safety Insp Rept 50-293/90-13 on 900501-0611.No Violations Noted.Repetitive Failures of Diesel Driven Fire Pump Noted,Requiring Increased Mgt Attention ML20059M8421990-06-13013 June 1990 Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl ML20247R8071989-09-21021 September 1989 Forwards SALP Rept 50-293/88-99 for 880516-890630.Instances of Deviation from Approved Practices & Lack of Attention to Detail Which Led to Challenges to Plant Equipment & Personnel Noted ML20247K6661989-09-0707 September 1989 Forwards Insp Rept 50-293/89-07 on 890525-0710 & Notice of Violation ML20246K5091989-08-24024 August 1989 Accepts Summary of QA Program Description Changes for 1989, Forwarded by ML20246L7821989-08-23023 August 1989 Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000.Failures to Properly Plan, Supervise & Inspect Tagout of Circuit Breakers Directly Contributed to Event ML20246D7261989-08-18018 August 1989 Submits Response to Re Plant Power Ascension Program.Util Proposal to Defer Phase 2 of Shutdown from Outside Control Room Test to Planned Fall 1989 mid-cycle Outage Accepted IR 05000293/19890071989-08-18018 August 1989 Approves Reactor Operation Up to 75% of Full Power Per Licensee Power Ascension Test Program.Nrc Findings Docketed in Insp Repts 50-293/89-07 & 50-293/89-08 & Status of Emergency Preparedness for Communities Encl ML20246J4811989-08-18018 August 1989 Clarifies NRC Position Re Definition of Extremity for Purposes of Setting Occupational Exposure Limits.Due to Misunderstanding,No Enforcement Action Planned If Licensee Procedures Incorporated Misunderstanding ML20246G1861989-08-18018 August 1989 Approves Reactor Operation Up to 75% of Full Power Per Licensee Power Ascension Test Program.Nrc Findings Docketed in Insp Repts 50-293/89-07 & 50-293/89-08 & Status of Emergency Preparedness for Communities Encl ML20245F1781989-07-31031 July 1989 Forwards Insp Rept 50-293/89-06 on 890411-0524.No Violations Noted.Licensee Actions W/Respect to 890503 Turbine Trip/Reactor Scram Demonstrated Excellent Approach to Problem Investigation & Resolution ML20247D0181989-07-18018 July 1989 Ack Receipt of Re Response to NRC Bulletin 89-003, Inadequate Latch Engagement in Hfa Type Relays Mfg by Ge. Necessary Actions Performed to Address Issues in Bulletin ML20246N3921989-07-14014 July 1989 Forwards Safety Insp Rept 50-293/89-09 on 890619-22.No Violations Noted ML20246D4961989-07-0606 July 1989 Advises That 880713 Response to NRC Bulletin 88-004, Potential Safety-Related Pump Loss Acceptable ML20246A7561989-06-26026 June 1989 Approves Reactor Operation Up to 50% Full Power,Per Util Power Ascension Test Program & Confirmatory Action Ltr 86-10.Assessment of Licensee Readiness for Release from NRC Approval Point 3 & Related Info Encl ML20246B5961989-06-22022 June 1989 Forwards,For Info,Nrr Ack Receipt of Petition Filed by Ecology Ctr of Southern CA & Stating That Petition Being Treated Under 10CFR2.206 of Commission Regulations ML20245A5371989-06-0909 June 1989 Forwards Insp Rept 50-293/89-05 on 890311-0410.Weaknesses Noted Re Evaluation of Failure Rate & Root Causes for Failures of Airlock Doors & Interlocks ML20244C2121989-06-0707 June 1989 Responds to Util 881011 Response to Generic Ltr 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. Implementation Schedule Contingent Upon Resolution of Procedure ML20244C2751989-06-0606 June 1989 Forwards Draft Safety Evaluation Re Plant Compliance W/ 10CFR50.62, ATWS Rule. Requests Response to NRC Concerns Re Diversity & Testability of Alternate Rod Injection & Reactor Pump Trip Sys NUREG-1275, Informs That Util Fulfilled Requirements of Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety Related Sys1989-06-0202 June 1989 Informs That Util Fulfilled Requirements of Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety Related Sys ML20247P5501989-06-0101 June 1989 Forwards Request for Addl Info on Proposed Tech Specs Change Re Visual Insp of High Energy Piping.Listed Concerns Based on Review of Bechtel Calculation 17322-S5,Rev 1 ML20247M2661989-05-26026 May 1989 Forwards Director'S Decision,Ltr of Transmittal & Fr Notice in Response to Ocre 2.206 Petition Expressing Concerns Re 880309 Power Oscillation Event at LaSalle Unit 2 & Request to Reopen Rulemaking on ATWS Issue.W/O Encls ML20246P6051989-05-15015 May 1989 Forwards Notice of Withdrawal of Application for Amend to License DPR-35.Amend Would Modify Tech Specs Re ECCS Surveillance Requirements ML20247D5481989-05-0808 May 1989 Forwards Augmented Insp Team Rept 50-293/89-80 on 890413-19 & 17-26.Team Concluded That Safety Significance of 890412 Pressurization Transient Was Minor,Though Event Raised Concerns Re Proximate Human Factors & Equipment ML20246N7951989-05-0404 May 1989 Forwards Mgt Meeting Rept 50-293/89-04 on 890328-30 W/Commonwealth of Ma & Local Officials ML20247A6911989-05-0303 May 1989 Extends Invitation to Attend Power Reactor Operator Licensing Seminar on 890531 in King of Prussia,Pa.Agenda & Info Re Lodging Arrangements Encl ML20245H8371989-04-26026 April 1989 Forwards SAIC-89/1121, In-Progress Audit Rept of Dcrdr at Boston Edison Co Pilgrim Nuclear Power Station & SAIC-89-1119, In-Progress Audit Rept for Boston Edison Co Pilgrim Nuclear Poser Station Spds ML20245H9551989-04-26026 April 1989 Forwards Insp Rept 50-293/89-01 on 890206-0310 & Notice of Violation ML20245J1441989-04-25025 April 1989 Advises That 880921 & 890302 Responses to NRC Bulletin 88-007 & Suppl 1, Power Oscillations in BWRs Meet Requirements of Both Bulletins ML20244E4611989-04-14014 April 1989 Requests Prompt Review & Reporting of Status of Implementation of TMI Action Plan Items at Facility.Printout of All TMI Items Annotated Where Tracking Sys Indicates That Implementation Not Complete Encl ML20244C2771989-04-10010 April 1989 Informs of Completion of Followup on Plant Regulatory Effectiveness Review Effort & Activities Re TAC 56995. Previous Compensatory Measures Removed as Result of Implementing Corrective Action ML20244A6931989-04-0707 April 1989 Forwards Mgt Meeting Rept 50-293/89-43 on 890309 to Discuss Util Followup Actions to 890304 Reactor Scram ML20244A6281989-04-0303 April 1989 Forwards Insp Rept 50-293/88-37 on 881227-890205.Violation Noted Re Failure to Control Locked High Radiation Area Access ML20236A8451989-03-0303 March 1989 Approves Reactor Operation Up to 25% of Full Power Per Util Power Ascension Test Program & Confirmatory Action Ltr 86-10.Urges Util to Cooperate W/Commonwealth of Ma & Local Govts to Further Improve State of Emergency Preparedness 1990-09-11
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20195K3071999-06-15015 June 1999 Forwards Safety Evaluation Granting Licensee Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Water Sys Piping for Plant ML20195K3851999-06-11011 June 1999 Forwards Copy of Notice of Consideration of Approval of Application Re Proposed Corporate Merger & Opportunity for Hearing.Application Seeks Approval of Proposed Indirect Transfer of FOL for Plant ML20196K9921999-06-0404 June 1999 Informs That NRC Ofc of NRR Reorganized Effective 990328.As Part of Reorganization,Division of Licensing Project Mgt Created ML20207E7351999-05-27027 May 1999 Responds to Requesting Reduction in IGSCC Insp Frequency Per GL 88-01 to Be Performed During Upcoming RFO 12.Forwards SE Re Reduction of IGSCC Insp of Category D Welds Due to Implementation of H Water Chemistry ML20207B6341999-05-26026 May 1999 Informs That Licensee 990415 Submittal Re Financial Position of Entergy Intl Ltd,Llc Will Be Marked as Proprietary & Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act ML20207B7391999-05-24024 May 1999 Forwards from Kc Goss of FEMA to Cl Miller Forwarding FEMA Analysis of Prompt Alert & Notification Sys for Pilgrim Nuclear Power Station.Based on Review,No Significant Problems Exist with Alert & Notification Sys ML20207B0701999-05-24024 May 1999 Responds to Sent to Ofc of Congressional Affairs Requesting Info on Concerns Raised by One Constituent,J Riel Re Y2K Compliance of Pilgrim NPP in Plymouth,Ma ML20207C0321999-05-18018 May 1999 Forwards Fifth Rept Which Covers Month of Apr 1999. Commission Approved Transfer of TMI-1 Operating License from Gpu to Amergen & Transfer of Operating License for Pilgrim Station from Beco to Entergy Nuclear Generating Co ML20206U7501999-05-17017 May 1999 Forwards Insp Rept 50-293/99-02 on 990308-0418.Two Severity Level 4 Violations Occurred & Being Treated as NCVs ML20206M1891999-05-11011 May 1999 Forwards SE of 980826 Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Sys Piping for Plant ML20206E0551999-04-29029 April 1999 Discusses Bulletin 96-03 Issued on 960506 & Beco Responses ,970207,981230,990121 & 990309 for Pilgrim Npp. Determined That Actions Taken Should Minimize Potential for Clogging of ECCS Suction Strainers ML20206B3031999-04-20020 April 1999 Forwards Insp Rept 50-293/99-01 on 990125-0307.Two Violations of NRC Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy.Security Program Was Also Inspected ML20205Q9491999-04-0909 April 1999 Informs That on 990225 NRC Staff Completed PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Develop an Integrated Understanding of Safety Performance ML20205B9391999-03-24024 March 1999 Forwards Second Request for Addl Info Re GL 95-07, Pressure-Locking & Thermal-Binding of Safety-Related Power-Operated Gate Valves ML20204C7871999-03-17017 March 1999 Informs That Application Submitting Transfer of Facility Operating License & Matls License & Proposed Amend, Will Be Marked as Proprietary & Be Withheld from Public Disclosure Pursuant to 10CFR2.709(b)(5) ML20199K8321999-01-22022 January 1999 Forwards Request for Addl Info Re Transfer of Facility Operating License for Plant ML20199H5811999-01-20020 January 1999 Submits Exemption Withdrawal of 10CFR70.24(a) Re Criticality Accident Monitoring Requirements ML20198L7781998-12-22022 December 1998 Forwards Insp Rept 50-293/98-10 on 981020-1208.No Violations Noted.Nrc Regional Specialists Reviewed EP & Fire Protection Programs.Ep Program Was Found to Be Well Implemented ML20198J0891998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Senator Kerry Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20198J1041998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Congressman Markey Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20137T2211998-12-17017 December 1998 Responds to to Chairman Jackson Re Concerns About Possible Sale of Pilgrim Station & Waste Disposal Issues.No Application for License Received Nor Contract of Sale Between Beco & Entergy.Record Copy ML20198J1161998-12-17017 December 1998 Responds to to Chairman Jackson in Which Recipient Expressed Concern About Possible Sale of Pilgrim Station & About Waste Disposal Issues.Nrc Has Not Received Application for Transfer of License to Date ML20198P2781998-12-17017 December 1998 Final Response to FOIA Request for Documents.Forwards App a Records Being Released in Entirety.App B Records Being Withheld in Entirety (Ref FOIA Exemption 4) ML20198B2021998-12-0909 December 1998 Advises of Planned Insp Effort Resulting from Licensee Irpm Review.Details of Insp Plan for Next 6 Months & Historical Listing of Plant Issues Encl ML20197H8521998-12-0909 December 1998 Responds to Ltr Sent to Chairman SA Jackson on 981028 Re Concern That NRC Will Not Perform Environ Assessment in Connection with Consideration of Approval of Transfer of License for Plants to Permit Sale ML20196J1201998-12-0404 December 1998 Ack Receipt of 971217 & 30 & 980112,0309,0423 & 0630 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-293/97-02,50-293/97-11,50-293/97-13, 50-293/97-80 & 50-293/98-01.Actions Found Acceptable ML20196B5421998-11-24024 November 1998 Forwards Plant SRO & RO Initial Exam Rept 50-293/98-301OL During Wk of 981016-23 ML20196F7631998-11-24024 November 1998 Forwards Insp Rept 50-293/98-203 on 980928-1023.No Violations Noted.Three Issues Identified Re Containment Flooding,Surveillance Testing Criteria & Protection for RBCCW System from High Energy Line Break Inside Drywell ML20196C1191998-11-20020 November 1998 Forwards Insp Rept 50-293/98-08 on 980907-1019.No Violations Noted.During Insp Period,Chemical Decontamination of Residual Heat Removal Sys Was Well Planned & Implemented Which Reduced Radiation Doses in Heat Removal Quadrants ML20195H7361998-11-16016 November 1998 Informs of Individual Exam Results for Applicants on Initial Exam Conducted on 981016 & 981019-23 at Facility.Nine Applicants Were Administered Exam & Nine Passed.Licenses Issued & Individual Test Results Encl.Without Encl ML20155C4781998-10-29029 October 1998 Forwards RAI Re Resoultion to GL 96-06 Issues at Plant,Unit 1.Response Requested by 981130 ML20154J7881998-10-0808 October 1998 Authorizes Mb Santiago to Administer Initial Written Exams to Applicants Listed (Except Applicants Redlined), on 981016.NRC Region I Operator Licensing Staff Will Administer Operating Tests During Week of 981019 1999-09-30
[Table view] |
Inspection Report - Pilgrim - 1988011 |
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, June 6, 1988 Docket No. 50-293 Mr. Ralph '
Senior Vice President . Nuclear Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199
Dear Mr. Bird:
SUBJECT: PILGRIM PROCEDURES GENERATION PACKAGE . SAFETY EVALUATION REFERENCE: TAC # 44328 By letters dated November 20, 1987 and December 14, 1987 you submitted the Pilgrim Procedures Generation Package (PGP) which +;as revised by a letter dated April 6, 1988. Enclosed is the staff's safety evaluation of the Pilgrim PGP required by Supplement 1 to NUREG-0737, "Requirements for Emergency Response Capability" (Generic Letter 82-33). The review was conducted in conjunction with the Emergency Operating Procedure (EOP)
inspection the week of March 14. The results of the inspection are documented in Inspection Report No. 50-293/88 11, dated May 17, 1988. Four unresolved itects in relation to the implementation of the E0Ps are noted in the inspection report.
Based on our review, we conclude that, the revised Pilgrim PGP adequately addresses the requirements stated in Generic Letter 82-33 (Supplement 1 to ,
NUREG.0737) and provides acceptable methods for accomplishing the objectives stated in NUREG-0899 in accordance with the guidance provided in the Standard
,
ReviewPlan(NRUEG.0300).
Inis completes our action related to the above referenced TAC number. The unresolved items noted in the inspection report referred to above must be resolved.
Sincerely, Original signed by:
Daniel G. Mcdonald, Senior Project Manager l Project Directorate I-3 '
Division of Reactor Projects I/II i
Enclosures:
1. Safety Evaluation ;
8806140014 880606 3 I cc: w/ enclosures: PDR ADOCK 050 See next page P 1 Distribution: Docket FilefNRC & Local PDRs, PDI-3 r/f, RWessman, RBoger, l
.Vushbrook, DMcDonald, OGC, EJordan, JPartlow Tech Branch, ACRS (10), '
JWiggins Region I, WKennedy, WRegan, WHodges, JCraig, TMurley, AThadani
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OFFICIAL RECORD COPY
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Mr. Ralph Boston Edison Company Pilgrim Nuclear Power Station
cc:
Mr. K. L. Highf111 Boston Edison Company Station Director ATTN: Mr. Ralph Pilgrim Nuclear Power Station Senior Vice President - Nuclear RFD #1 Rocky Hill Road 800 Boylston Street Plymouth, Massachusetts 02360 Boston, Massachusetts 02199 Resident inspector's Office Mr. Richard N. Swanson, Manager U. S. Nuclear Regulatory Comission Nuclear Engineering Department Post Office Box 867 Boston Ed! son Company Plymouth, Massachusetts 02360 25 Braintree Hill Park Braintree, Massachusetts 02184 Chairman, Board of Selectmen 11 Lincoln Street Ms. Elaine D. Robinson Plymouth, Massachusetts 02360 Nuclear Information Manager Pilgrin Nuclear Power Station Office of the Comissioner RFD #1, Rocky Hill Road Massachusetts Dopartment of Plymouth, Massachusetts 0?360 Environmental Ouality Engineering One Winter Street Charles V. Berry Boston, Massachusetts 02108 Secretary of Public Safety Executive Office of Public Safety Office of the Attorney General One Ashburton Place 1 Ashburton Place Roston, Massachusetts 0?108 20th Floor Boston, Massachusetts 02108 Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of
,
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i Public Health i 150 Tremont Street 2nd Floor l Boston, Massachusetts 02111 1 I
Regicnal Administrator, Region I U. S. Nuclear Regulatory Comission -
475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. James D. Keyes 3 Regulatory Affairs and Programs Group Leader Boston Edison Company 25 Braintree Mill Park !
Braintree, Massachusetts 02184
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