ML15306A497

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

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

See also: IR 05000293/2015010

Text

SEn tergyEntergy Nuclear Operations,

Inc.Pilgrim Nuclear Power Station600 Rocky Hill RoadPlymouth,

MA 02360October 30, 2015U.S. Nuclear Regulatory

Commission

ATTN: Document

Control DeskWashington,

DC 20555-0001

SUBJECT:Reply to a Notice of Violation

Pilgrim Nuclear Power StationDocket No. 50-293License No. DPR-35REFERENCE:

NRC Letter to Entergy,

"Pilgrim

Nuclear Power Station -ProblemIdentification

and Resolution

Inspection 05000293/201

5010 andNotices of Violation,"

dated October 1, 2015LETTER NUMBER: 2.15.077Dear Sir or Madam,This letter provides

the information

requested

in the Notice of Violation

received

at PilgrimNuclear Power Station in the above referenced

letter. The requested

information

is provided

inthe Attachment

to this letter.This letter contains

no commitments.

Should you have any questions

concerning

the content of this letter or require additional

information,

please contact me at (508) 830-8227.

Sincerely,

Manager,

Emergency

Preparedness

DC/mewAttachment:

Reply to a Notice of Violation

(2 Pages)

PNPS Letter 2.15.077Page 2 of 2Cc:Mr. Daniel H. DormanRegional

Administrator,

Region IU.S. Nuclear Regulatory

Commission

2100 Renaissance

Boulevard,

Suite 100King of Prussia,

PA 19406-1 415NRC Senior Resident

Inspector

Pilgrim Nuclear Power Station

Attachment

ToPNPS Letter 2.15.077Reply to a Notice of Violation

(2 Pages)

Attachment

to PNPS Letter 2.15.077Page 1 of 2Reply to Notice of Violation

During an NRC inspection

conducted

from August 3 through 20, 2015, a violation

of NRCrequirements

was identified.

The violation

is associated

with the following

requirement:

Violation

No. Description

201 5010-02 10 CFR 50.54(q)(2)

requires,

in part, that a holder of a nuclear powerreactor operating

license shall follow and maintain

the effectiveness

ofan emergency

plan that meets the requirements

in Appendix

E to thispart, and the planning

standards

of 10 CFR 50.47(b).

10 CFR 50.47(b)

(8) requires,

in part, that adequate

equipment

tosupport the emergency

response

are provided

and maintained.

Contrary

to the above, since December

2011, Entergy did not followand maintain

the effectiveness

of the Pilgrim Emergency

Plan to meetthe requirement

that adequate

equipment

to support the emergency

response

was provided

and maintained.

Specifically,

in December2011, Entergy cancelled

preventive

maintenance

of the 160' back-upmeteorological

tower, and that tower became non-functional.

As aresult, on eight occasions

between March 18, 2012, and August 15,2015, when the 220' primary meteorological

tower was also non-functional

for various reasons,

Pilgrim did not have instrumentation

available

on either tower for continuous

reading of the wind speed, winddirection,

air temperature,

and delta air temperature.

Attachment

to PNPS Letter 2.15.077Page 2 of 2VIOLATION

201 5010-02 -Failure to Maintain

Station Meteorological

TowersReason for the Violation

During the 2015 NRC Problem Identification

and Resolution

(PI&R) Inspection

a Green Noticeof Violation

(NOV) was issued for failure to follow and maintain

the effectiveness

of the PilgrimEmergency

Plan to meet the requirement

that adequate

equipment

to support the emergency

response

was provided

and maintained.

The failure to properly

maintain

the 220' tower andrestore or replace the 160' tower was previously

identified

in Non-Cited

Violation

(NCV)2013008-02

issued for violation

of 10 CFR 50.54(q)(2).

The 2015 PI&R inspection

determined

Entergy did not address the adverse condition

within a reasonable

period of time after the NRCdocumented

the initial Green NOV.An organizational

performance

gap existed in that the meteorological

towers performance

monitoring

and issue resolution

did not have a single point of ownership,

such that the priority

toresolve issues was not properly

evaluated

to ensure timely resolution.

As a consequence,

previously

identified

corrective

actions were untimely

with inadequate

organizational

engagement

to monitor performance

or resolve issues.Corrective

steps' that have been taken and the results achievedThe Emergency

Preparedness

Department

(EPD) has taken ownership

of the meteorological

towers. The EPD obtained

the necessary

project funding,

engineering

design support,

andinstallation

support to install the replacement

160' tower. The tower structure

is in place. Themeteorological

instruments

have been installed.

Post installation

testing of the instruments

anddata communication

system is in progress.

The Regulatory

Assurance

Weekly Report was modified

to include a "deadline"

date forcompletion

of corrective

actions associated

with regulatory

findings.

Additionally,

a Regulatory

Assurance

review has been incorporated

as a required

element for corrective

actionsassociated

with NRC Findings.

Corrective

steps that will be takenPost installation

testing of the new 160' tower will be completed

and the tower placed in service.Date when full compliance

will be achievedThe current schedule

for resolution

is on or before December

16, 2015, at which time fullcompliance

to the NRC requirements

will be achieved.