IR 05000293/1998004: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot change)
(StriderTol Bot change)
 
Line 1: Line 1:
{{Adams
{{Adams
| number = ML20153F210
| number = ML20237A299
| issue date = 09/16/1998
| issue date = 08/06/1998
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/98-04 on 980806
| title = Discusses Insp Rept 50-293/98-04 on 980427-0515 & Forwards Notice of Violation Re Failure to Properly Implement Maint Rule
| author name = Conte R
| author name = Wiggins J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name = Olivier L
| addressee name = Olivier L
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-293-98-04, 50-293-98-4, EA-98-277, NUDOCS 9809290042
| document report number = 50-293-98-04, 50-293-98-4, EA-98-277, NUDOCS 9808130253
| title reference date = 08-28-1998
| package number = ML20237A301
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 3
| page count = 4
}}
}}


Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:- . _ _ _ _ _ _ _ _ _ _   _ _ _ . _ _ _ . _ . _ _ _ _ . . _ . _ _ _ . _ -
{{#Wiki_filter:- _ _ _ - - _ _ _ _ _ _ _ - - - _ _ _ - _ _ __. - - _ _ _ - _
I
l.
        '
. . ,


1
l i
 
l l
I September 16, 1998 l
l      August 6, 1998
l EA 98-277 Mr. Leon Senior Vice President - Nuclear BEC Energy -
!
4  Pilgrim Nuclear Power Station 600 Rocky Hill Road     {
l EA 98-277 Mr. Leon i Senior Vice President - Nuclear BEC Energy Pilgrim Nuclear Power Station 600 Rocky Hill Road l Plymouth, Massachusetts 02360-5599 l
        ;
SUBJECT:   NOTICE OF VIOLATION AND EXERCISE OF ENFORCEMENT D!SCRETION (NRC INSPECTION REPORT NO. 50-293/98-04)
Plymouth, Massachusetts 02360-5599     l l
SUBJECT: PILGRIM INSPECTION REPORT NO. 50-293/98-04(REPLY)


==Dear Mr. Olivier:==
==Dear Mr. Olivier:==
This letter refers to the NRC inspection conducted at the Pilgrim Nuclear Power Station from April 27,1998 to May 1,1998 (onsite), and from May 4-15,1998 (in-office). The purpose of the inspection was to review Pilgrim's maintenance rule implementation in
,
'
accordance with 10 CFR 50.65. During the inspection, apparent violations were identified related to the failure to properly implement the maintenance rule. The findings of the l Inspection were discussed with members of your staff at the conclusion of the onsite inspection on May 1,1998, and the inspection report addressing these issues was ser;t to j you on June 29,1998. Our letter indicated that we were still making a decision on enforcement matters and the purpose of this letter is to provide you with the results of our
'
deliberations.


This letter refers to your August 28,1998 correspondence, in response to our notice of violation dated August 6,1998 and our integrated inspection report dated June 29,1998.
- Based on the results of this inspection, the NRC has determined that violations of NRC requirements occurred._ Three 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. The violations involved: (1) f ailure to demonstrate effective preventive maintenance as required by 10 CFR 50.65 (a)(2) because you did not establish
This inspection focused on the maintenance rule baseline program (April 27,1998 to May 1,1998 onsite, and from May 4-15,1998 in-office) at the Pilgrim Nuclear Power Station, Plymouth, Massachusetts. We have reviewed this matter in accordance with NRC
; an unavailability performance measure for the anticipated transient without scram (ATWS)
'
!
  - Inspection Manual Procedure 92902," Maintenance." We concur with your assessment of the root causes and corrective actions as summarized below and we note a common cause
function of the control rod drive system; (2) failure to include in the scope of the
*
< . Maintenance Rule program, as required by 10 CFR 50.65(b), the heating, ventilation and air ( conditioning (HVAC) system for the reactor building 480V switchgear environmental i enclosures and for the firewater system function of providing a backup (and supplemental)
for all three violations being human error that resulted from your initial incomplete understanding of the requirements and initial inability to remain current in evolving NRC expectations in this area.
 
The first vblation involved failure to establish an unavailability performance measure for the anticipated transient without scram (ATWS) function of the control rod drive system.
 
; The corrective actions involved re-evaluation by your Expert Panel, and this function was determined to be risk significant. Accordingly, unavailability criterion was established and
;  the bases document was revised and approved by your Expert Panel.
 
.
The second violation involved failure to include in the scope of the Maintenance Rule program, the heating, ventilation and air conditioning (HVAC) system for the reactor
        [
building 480V switchgear environmental enclosures and for the firewater system function . /
of providing a backup (and supplemental) Supply to the screenwash system. The corrective actions involved re-evaluation by your Expert Panel, development of performance criteria, revision of the respective bases document and approval by the Expert Panel.
 
The third violation involved failure to complete the periodic evaluation required to be performed for refueling cycle 11, which ended April 1997. The corrective actions included
;
  ~ completing the (a)(3) periodic assessment for refueling cycle number 11 and a planned
;  revision to your program requirements that will require the (a)(3) periodic assessments to
;  be completed at the end of each refueling outage, not to exceed two years.
 
.0 0]?A 9809290042 980916 PDR
-
G ADOCK 05000293 pg
__ - _ -
 
.
Mr. Leon The effectiveness of your corrective actions will be reviewed in a future inspection after the completion of your comprehensive self-assessment in which you indicated is expected to be completed by April 15,1999. We appreciate your cooperation.
 
Sincerely, ORIGINAL SIGNED BY:
Richard J. Conte, Chief Operator Licensing and Human Performance Branch Division of Reactor Safety Docket No.: 50-293 License No.: DPR-35 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 The Honorable Joseph Gallitano T. MacGregor, Mass. Dept. of Public Comm. & Energy Chairman, Plymouth Board of Selectmen  .
' Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Committee Plymouth Civil Defense Director P. Gromer, Massachusetts Secretary of Energy Resources J. Miller, Senior lasues 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
__ _ -
 
  . - . . - .- . . - . . . . . . - . - . , - . , , . . - . . .
f#'
'.'[.
        -
l" Mr. Leon l l. '
l. Distribution w/ encl:    ,
: Region 1 Docket Room (with concurrences)    -
i Nuclear Safety information Center (NSIC)      j PUBLIC :        ;
        '
NRC Resident inspector
- J. Wiggins, DRS L. Nicholson, DRS    .
        ..
R. Conte, DRS      9'
l J. Caruse, DRS      ,
C. Cow 0ill, DRP      ]
R. Sunmre, DRP      l C. O'Daniell, DRP .      j l H. M!Iler, RA/W. Axelson, DRA
! ,
OE (2)
; D. Holody, ORA
, DRS File
'
'
B. McCabe, OEDO
supply to the screenwash system; and (3) failure to complete the periodic evaluation required to be performed for refueling cycle 11, which ended April 1997, as required by 10 CFR 50.65 (a)(3). The violations were identified by the NRC and have been categorized l individually at Severity Level IV in accordance with the " General Statement of Policy and Ij Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, Revision 1,  /
! C. Thomas, NRR (COT)
May 1998.
'.A. Wang, NRR      !
R. Correia, NRR      -1 F. Talbot, NRR      l
: R. Zimmerman, ADPR, NRR F. Davis, OGC A. Nicosia, OGC .
l J. Lieberman, OE (OEMAIL)
i DOCDESK        ;
. inspection Program Branch, NRR (IPAS)
l
        )
l i
[ DOCUMENT NAME: G:\OLHP\CARUSO\PIL9804. REP To receive a copy of this document, indicate b @.c box: "C" = Copy without attachment / enclosure "E" = Copy with attach nent/
_  _
    . enclosure "N" = No copy OFFICE , ,Rl/DRS E Rl/DRp / p_\A pn] l L l' NAME 7JCaruso /RCgWpf  c_hwh , J
[- DATE F 9F0/98 9/ /98 7/ Pi/d OFFICIAL RECORD COPY
!
k
 
4 e
;
)
 
      -
        ,.


.    .-  -. - . .
/(0
*
        >
,
9808130253 980806 PDR
10 CFR 2.201
      "
,
,
O Boston Edloon Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, Massachusetts 02360 August 28, 1998 L Senior Vice Presidect Nuclear    BECo Ltr. #2.98.120 U.5. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Docket No 50-293 License No. DPR-35 REPLY TO THE NOTICE OF VIOLATION. DATED AUGUST 6.1998 (NRC INSPECTION REPORT NO. 50-293/98-04)
G  ADOCK 05000293 PDR
Enclosed is Boston Edison Company's reply to the Notice of Violation dated August 6,1998 (Inspection Report No. 50-293/98-04).
      ,,


This letter includes the following commitments.
* A comprehensive self-assessment of the effectiveness of the Maintenance Rule improvement Program is being developed and will be performed to further ensure the continued full compliance with the requirements of 10CFR50.65. This will be completed by April if,1999.
. Nuclear Engineering Procedure 16.03, "10 CFR 50.65 NRC Maintenar.ce Rule" will be revised to include the schedule for 10 CFR 50.65(a)(3) evaluation at the end of each refueling outage, not to exceed two years. This revision will be completed by December 31,1998.
Please do not hesitate to contact me if there are any questions regarding the enclosed reply.
- 8J@
L. Enclosure: Reply to the Notice of Violation 298120 WGU vlO98-04-01,04 &OS cc: ' Mr. Alan B. Wang, Project Manager  Region I, Project Directorate 1-3  U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation  475 Allendale Road USNRC, Mail Stop: OWFN 1482  King of Prussia, PA 19406 1 White Flint North 11555 Rockville Pike  Senior Resident inspector Rockville, MD 208S2  Pilgrim Nuclear Power Station-Wo908wat
,
-
  .
  .
'
      )
, .
O Mr. Leon Further, during your self-assessment of your maintenance rule program, you identified significant performance weaknesses and inadequacies which indicated an apparent organizational ineffectiveness in implementing the maintenance rule. The identified deficiencies included examples of failure to demonstrate effective preventive maintenance and failure to include structures, systems and components (SSCs)in the ccope of the maintenance rule program, as well as failure to place systems into an (a)(1) status in a timely manner when it was evident that preventive maintenance was not effective. For example, you identified that the feedwater system and the primary containment system were not placed into an (a)(1) status in May 1997 and July 1996, respectively, it was apparent that your organization was not in compliance with the maintenance rule as of July 10,1996 when the rule became effective. The NRC recognizes that considerable progress was made in the months prior to the subject inspection. Nonetheless, these violations collectively represented an initial programmatic breakdown in the development and implementation of the Rule.
Boston Edison Company    Docket No. 50-293 Pilgrim Station    License No. DPR-35 EA 98--277 ENCLOSURE NOTICE OF VIOLATION VIOLATION: EA 98-277 A. 10 CFR 50.65(a)(1) requires, in part, that orolders of an operating license shall monitor the performance or condition of structures, systems and components (SSCs),within the scope of the monitoring program, as defined by 10 CFR 50.65(b), against licensee established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety and, where practical, take into account industry-wide operating experience. When the performance or condition of a SSC does not meet established goals, appropriate corrective action shall be taken.
 
10 CFR 50.65(a)(2), requires, in part, that the monitoring as specified in 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance or condition of a SSC is being effectively controlled by performing appropriate preventive maintenance, such that the SSC remains capable of performing its intended function.
 
Contrary to 10 CFR 50.65(a)(2), from July 10 1996 to April 27,1998, the licensee had elected not to monitor the performance or condition of thc control rod drive system against established goals pursuant to the requirements of Section (a)(1), and failed to demonstrate that the performance or condition of the SSCs, within the scope of 10 CFR 50.65, had been effectively controlled by performing appropriate preventive maintenanco pursuant to the requirements of Section (a)(2).
 
l Specifically, the licensee failed to establish unavailability measures for the anticipated transient i without scram (ATWS) function of the control rod drive system. Without an unavailability measure, the ATWS function could be out-of-service for an excessive period of time rendering it
  [ incapable of performing it's intended function.
 
This is a Severity LevelIV violation (Supplement 1).


B. 10 CFR 50.65(b) established the scope of the monitoring program for selection of safety-related and nonsafety-related structures, systems or componcats (SSCs) to be included within the maintenance rule program. The monitoring program shall include, in part, non-safety related SSCs that are relied upon to mitigate accidents or transients, or are used in the plant ernergency operating procedures, or, or whose failure could cause a reactor scram or actuation of a safety-related system.
These violations were considered for escalated enforcement action in accordance with the Enforcement Policy; 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 (for the violations identified by your organization) in accordance with the provisions provided in Section Vll.B.6 of the Enforcement Policy. The decision to exercise discretion was made in consideration of the facts that: (1) your self-assessment identified the deficiencies in your maintenance rule program; (2) your corrective actions to address the weaknesses were reasonably prompt and comprehensive after identification; and (3) there was no actual adverse impact on system performance as a result of the deficiencies in your program. At the time of the inspection, your maintenance rule program and implementation were in compliance with 10 CFR 50.65 with some exceptions as noted above. Although the NRC identified several violations during the inspection, these deficiencies were not indicative of a continuing programmatic breakdown.


' Contrary to the above. from July 10,1996 to April 27,1998, the licensee had failed to include in
Rather, it appeared that you had not had a chance to review your corrective actions for effectiveness.
  ' the scope of the Maintenance Rule program the heating, ventilation, and air conditioning system (HVAC) for the reactor building 480V switchgear environmental enclosures, which were designed to protect the switchgear from the consequences of high energy line breaks in the secondary containment (failure of this system could result in loss of safety significant loads) and the firewater system function of providing a backup (and supplemental) supply to the screenwash system l s(failure creenwash ofsystem this system concurrentcould resultintrusion with grass in a plant trip inclogging).


and screen the event of a loss of normalsystem sup This is a Severity LevelIV violation Supplement I.
You are required to respond to this letter and should follow the instructions in the enclosed Notice. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.


REASON FOR THE VIOLATIONS The reason for the above violations was human error. The failure to include, as of July 10, 1996, the unavailability performance criterion for the ATWS function of CRD, the HVAC motor
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).
 
,


m_
l l


- - _ _ - _ _ - - _ - - - _ - _ - _ - _ _ _  __ . _ _ - _ -
  .
  .
-
9-Mr. Leon Your cooperation with us is appreciated.
.
~
. .
control c:nt:r enclosura function, and tha firewater system back up to ths screenwash function in the Maintenance Rule was the result-oLoutinitiaLincomplete-understanding of the requirements of the rule and_our_initiaLinability._to_remairLcurrenLFh_ evolving _NRC expentations. Itiese deficiencies were also not discovered during the overhaul of the Maintinance Rule Program in response to OA audit 97-08 because the self-imposed, aggressive schedule we established for the overhaul activities, in some cases, may not have allowed sufficient engineering assessment time to identify the deficiencies. A critical self-
. assessment is now in progress to ensure our upgraded Maintenance Rule Program fully incorporates the requirements of the rule and is complete and accurate (PR 98.0919).


CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED e OA audit 97-08 was completed in September 1997 to determine the extent of compliance with 10 CFR 50.05. A Maintenance Rule improvement Program was developed to provide effective corrective and preventive actions to resolve OA audit findings. A complete overhaul of Pilgrim's Maintenance Rule Program to correct the programmatic weakness was accomplished in May 1998 (PR 97.2869).
Sincerely, ORIGINAL SIGNED BY:  .l
        )
I i
James T. Wiggins, Director i Division of Reactor Safety.


. The ATWS function of CRD was re-evaluated by the Expert Panei and determined to be risk significant. An appropriate unavailability performance criterion was established for the ATWS function of the CRD system and the CRD bases document revised and approved by the Exped Panel on June 18,1998.
Docket No.: 50-293
  - License No.: DPR-35 Enclosure: Notice of Violation cc w/ encl:
R. Ledgett, Executive Vice President - Operations C. Goddard, Plant Department Manager . l N. Desmond, Regulatory Relations D. Tarantino, Nuclear Information Manager R. Hallisey, Department of Public Health, Commonwealth of Massachusetts The Honorable Therese Murray The Honorable Joseph Gallitano T. MacGregor, Mass. Dept. of Public Comm. & Energy
  ' Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Cornmittee Plymouth Civil Defense Director P. Gromer, Massachusetts Secretary of Energy 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 L
L L
r-


. The Reactor Building 480V switchgear environmental enclosure safety-re:ated HVAC function and the firewater system function to provide a backup to the screenwash system l were both added to the scope of the Maintenance Rule Program. Performance criteria ;
    . _ _ _ _ _ .
were developed for these functions and the respective bases documents revised. The l Expert Panel approved the revision to the screenwash system bases document on May 8, j 1998, and the revision to the HVAC system bases document on June 29,1998.
I
        ;
lt
!- Notice of Violation    4  !
Distribution w/ encl:
Region i Docket Room (with concurrences)
Nuclear Safety information Center (NSIC)
PUBLIC NRC Resident inspector J. Wiggins, DRS L. Nicholson, DRS R. Conte, DRS J. Caruso, DRS      ;
C. Cowgil, DRP R. Summers, DRP C. O'Daniell, DRP      1 H. Miller, RA/W. Axelson, DRA      I OE (2)
D. Holody, ORA DRS File        j Distribution w/enci (VIA E-MAIL):
B. McCabe, OEDO C. Thomas, NRR (COT)
A. Wang, NRR R. Correia, NRR F. Talbot, NRR R. Zimmerman, ADPR, NRR F. Davis, OGC A. Nicosia, OGC J. Lieberman, OE (OEMAIL)
DOCDESK inspection Program Branch, NRR (IPAS)
,        ,


CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS  l A comprehensive self-assessment of the effectiveness of the Maintenance Rule improvement Program is being developed and will be performed to further ensure continued full compliance l
I DOCUMENT NAME: G:\OLHP\CARUSO\PROPILR1.MR
      '
  . To receive a copy of this document, indicate in the box: "C" = Copy without
with the requirements of 10CFR50.65. This will be completed by April 15,1999.
!
 
attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE Rl/ ORA  Rl/DRS [t OE  l Rl/DRP /p l Rl/DRS [
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved en June 29,1998.
NAME TW  er 'JCarusQ' 74 MS  s CCowgill/CRehb JWiggins V
 
  ,
  . _ _ _- _ - . . . _ -
v RContd/  f
=
! DATE 7/f(98  7p98 V (#(/98' #~L  7/5(98 5/[,/98
  . .
[Cc pr tiU 6d ')/pdfWFFICIA    RECORD COPY S
-
Q
. .
    '
J VIOLATION C. 10 CFR 50.65(a)(3) requires, in part, that performance and condition monitoring activities and associated goals andpreventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months.
g      ,
 
fo% M  }di
Contrary to the above, as of April 27,1990, the licensee had failed to complete the periodic evaluation for the refueling cycle No.11 which ended April 1997.
,p we3
 
>
T This is a Severity LevelIV violation Supplement I.
TsW/
 
_- _ - - - - - - - - - -  - - - -  - -- -- -- - -
REASON FOR THE VIOLATION-The reason for the violation was human error. The current NRC position for the completion of the 10 CFR 50.65(a)(3) periodic assessment requirement was misinterpreted (PR 98.0919).
 
The extent of this problem is limited to this one incident. The next (a)(3) evaluation is due at the end of refueling oJtage 12.
 
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The periodic evaluation required by 10 CFR 65(a)(3) was completed, approved, and issued on May 5,1998. A copy of the evaluation report was sent to the NRC's Mr. John Caruso on May 5, 1998.
 
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Nuclear Engineering Procedure 16.03, "10 CFR 50.65 NRC Maintenance Rule" will be revised to include toe schedule for 10 CFR 50.65(a)(3) evaluation at the end of each refueling outage, not to exceed two years. This revision will be completed by December 31,1998.
 
DATE widen FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on May 5,1998, when we completed the refueling cycle No.11 evaluation.
 
i 3
}}
}}

Latest revision as of 04:03, 17 December 2021

Discusses Insp Rept 50-293/98-04 on 980427-0515 & Forwards Notice of Violation Re Failure to Properly Implement Maint Rule
ML20237A299
Person / Time
Site: Pilgrim
Issue date: 08/06/1998
From: Wiggins J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Olivier L
BOSTON EDISON CO.
Shared Package
ML20237A301 List:
References
50-293-98-04, 50-293-98-4, EA-98-277, NUDOCS 9808130253
Download: ML20237A299 (4)
v • d • e


Text

- _ _ _ - - _ _ _ _ _ _ _ - - - _ _ _ - _ _ __. - - _ _ _ - _

l.

l i

l l

l August 6, 1998

!

l EA 98-277 Mr. Leon i Senior Vice President - Nuclear BEC Energy Pilgrim Nuclear Power Station 600 Rocky Hill Road l Plymouth, Massachusetts 02360-5599 l

SUBJECT: NOTICE OF VIOLATION AND EXERCISE OF ENFORCEMENT D!SCRETION (NRC INSPECTION REPORT NO. 50-293/98-04)

Dear Mr. Olivier:

This letter refers to the NRC inspection conducted at the Pilgrim Nuclear Power Station from April 27,1998 to May 1,1998 (onsite), and from May 4-15,1998 (in-office). The purpose of the inspection was to review Pilgrim's maintenance rule implementation in

,

'

accordance with 10 CFR 50.65. During the inspection, apparent violations were identified related to the failure to properly implement the maintenance rule. The findings of the l Inspection were discussed with members of your staff at the conclusion of the onsite inspection on May 1,1998, and the inspection report addressing these issues was ser;t to j you on June 29,1998. Our letter indicated that we were still making a decision on enforcement matters and the purpose of this letter is to provide you with the results of our

'

deliberations.

- Based on the results of this inspection, the NRC has determined that violations of NRC requirements occurred._ Three 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. The violations involved: (1) f ailure to demonstrate effective preventive maintenance as required by 10 CFR 50.65 (a)(2) because you did not establish

an unavailability performance measure for the anticipated transient without scram (ATWS)

!

function of the control rod drive system; (2) failure to include in the scope of the

< . Maintenance Rule program, as required by 10 CFR 50.65(b), the heating, ventilation and air ( conditioning (HVAC) system for the reactor building 480V switchgear environmental i enclosures and for the firewater system function of providing a backup (and supplemental)

'

supply to the screenwash system; and (3) failure to complete the periodic evaluation required to be performed for refueling cycle 11, which ended April 1997, as required by 10 CFR 50.65 (a)(3). The violations were identified by the NRC and have been categorized l individually at Severity Level IV in accordance with the " General Statement of Policy and Ij Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, Revision 1, /

May 1998.

/(0

>

9808130253 980806 PDR

"

,

G ADOCK 05000293 PDR

,,

.

)

O Mr. Leon Further, during your self-assessment of your maintenance rule program, you identified significant performance weaknesses and inadequacies which indicated an apparent organizational ineffectiveness in implementing the maintenance rule. The identified deficiencies included examples of failure to demonstrate effective preventive maintenance and failure to include structures, systems and components (SSCs)in the ccope of the maintenance rule program, as well as failure to place systems into an (a)(1) status in a timely manner when it was evident that preventive maintenance was not effective. For example, you identified that the feedwater system and the primary containment system were not placed into an (a)(1) status in May 1997 and July 1996, respectively, it was apparent that your organization was not in compliance with the maintenance rule as of July 10,1996 when the rule became effective. The NRC recognizes that considerable progress was made in the months prior to the subject inspection. Nonetheless, these violations collectively represented an initial programmatic breakdown in the development and implementation of the Rule.

These violations were considered for escalated enforcement action in accordance with the Enforcement Policy; 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 (for the violations identified by your organization) in accordance with the provisions provided in Section Vll.B.6 of the Enforcement Policy. The decision to exercise discretion was made in consideration of the facts that: (1) your self-assessment identified the deficiencies in your maintenance rule program; (2) your corrective actions to address the weaknesses were reasonably prompt and comprehensive after identification; and (3) there was no actual adverse impact on system performance as a result of the deficiencies in your program. At the time of the inspection, your maintenance rule program and implementation were in compliance with 10 CFR 50.65 with some exceptions as noted above. Although the NRC identified several violations during the inspection, these deficiencies were not indicative of a continuing programmatic breakdown.

Rather, it appeared that you had not had a chance to review your corrective actions for effectiveness.

You are required to respond to this letter and should follow the instructions in the enclosed Notice. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

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).

l l

- - _ _ - _ _ - - _ - - - _ - _ - _ - _ _ _ __ . _ _ - _ -

.

9-Mr. Leon Your cooperation with us is appreciated.

Sincerely, ORIGINAL SIGNED BY: .l

)

I i

James T. Wiggins, Director i Division of Reactor Safety.

Docket No.: 50-293

- License No.: DPR-35 Enclosure: Notice of Violation cc w/ encl:

R. Ledgett, Executive Vice President - Operations C. Goddard, Plant Department Manager . l N. Desmond, Regulatory Relations D. Tarantino, Nuclear Information Manager R. Hallisey, Department of Public Health, Commonwealth of Massachusetts The Honorable Therese Murray The Honorable Joseph Gallitano T. MacGregor, Mass. Dept. of Public Comm. & Energy

' Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Cornmittee Plymouth Civil Defense Director P. Gromer, Massachusetts Secretary of Energy 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 L

L L

r-

. _ _ _ _ _ .

I

lt

!- Notice of Violation 4  !

Distribution w/ encl:

Region i Docket Room (with concurrences)

Nuclear Safety information Center (NSIC)

PUBLIC NRC Resident inspector J. Wiggins, DRS L. Nicholson, DRS R. Conte, DRS J. Caruso, DRS  ;

C. Cowgil, DRP R. Summers, DRP C. O'Daniell, DRP 1 H. Miller, RA/W. Axelson, DRA I OE (2)

D. Holody, ORA DRS File j Distribution w/enci (VIA E-MAIL):

B. McCabe, OEDO C. Thomas, NRR (COT)

A. Wang, NRR R. Correia, NRR F. Talbot, NRR R. Zimmerman, ADPR, NRR F. Davis, OGC A. Nicosia, OGC J. Lieberman, OE (OEMAIL)

DOCDESK inspection Program Branch, NRR (IPAS)

, ,

I DOCUMENT NAME: G:\OLHP\CARUSO\PROPILR1.MR

. To receive a copy of this document, indicate in the box: "C" = Copy without

!

attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE Rl/ ORA Rl/DRS [t OE l Rl/DRP /p l Rl/DRS [

NAME TW er 'JCarusQ' 74 MS s CCowgill/CRehb JWiggins V

,

v RContd/ f

! DATE 7/f(98 7p98 V (#(/98' #~L 7/5(98 5/[,/98

[Cc pr tiU 6d ')/pdfWFFICIA RECORD COPY S

Q

'

g ,

fo% M }di

,p we3

>

TsW/

_- _ - - - - - - - - - - - - - - - -- -- -- - -

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000293/1998004&oldid=3381958"