IR 05000293/1998004

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/98-04 on 980806

ML20153F210
Person / Time
Site:	Pilgrim
Issue date:	09/16/1998
From:	Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Olivier L BOSTON EDISON CO.
References
50-293-98-04, 50-293-98-4, EA-98-277, NUDOCS 9809290042
Download: ML20153F210 (3)

Text

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I September 16, 1998 l

l EA 98-277 Mr. Leon Senior Vice President - Nuclear BEC Energy -

4 Pilgrim Nuclear Power Station 600 Rocky Hill Road {

Plymouth, Massachusetts 02360-5599 l l

SUBJECT: PILGRIM INSPECTION REPORT NO. 50-293/98-04(REPLY)

Dear Mr. Olivier:

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.

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

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- 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

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.

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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

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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

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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

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l" Mr. Leon l l. '

l. Distribution w/ encl: ,

Region 1 Docket Room (with concurrences) -

i Nuclear Safety information Center (NSIC) j PUBLIC :  ;

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NRC Resident inspector

- J. Wiggins, DRS L. Nicholson, DRS .

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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

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D. Holody, ORA

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B. McCabe, OEDO

! C. Thomas, NRR (COT)

'.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)

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. inspection Program Branch, NRR (IPAS)

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[ 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/

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. 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

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10 CFR 2.201

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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)

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.

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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

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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.

' Contrary to the above. from July 10,1996 to April 27,1998, the licensee had failed to include in

' 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.

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

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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).

. 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.

. 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.

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

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with the requirements of 10CFR50.65. This will be completed by April 15,1999.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved en June 29,1998.

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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.

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.

T This is a Severity LevelIV violation Supplement I.

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.

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