ML15306A497

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 tergy Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 October 30, 2015 U.S. Nuclear Regulatory

Commission

ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT: Reply to a Notice of Violation Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 REFERENCE:

NRC Letter to Entergy, "Pilgrim Nuclear Power Station -Problem Identification

and Resolution

Inspection 05000293/201

5010 and Notices of Violation," dated October 1, 2015 LETTER NUMBER: 2.15.077 Dear Sir or Madam, This letter provides the information

requested

in the Notice of Violation

received at Pilgrim Nuclear Power Station in the above referenced

letter. The requested

information

is provided in the 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/mew Attachment:

Reply to a Notice of Violation

(2 Pages)

PNPS Letter 2.15.077 Page 2 of 2 Cc: Mr. Daniel H. Dorman Regional Administrator, Region I U.S. Nuclear Regulatory

Commission

2100 Renaissance

Boulevard, Suite 100 King of Prussia, PA 19406-1 415 NRC Senior Resident Inspector Pilgrim Nuclear Power Station

Attachment

To PNPS Letter 2.15.077 Reply to a Notice of Violation (2 Pages)

Attachment

to PNPS Letter 2.15.077 Page 1 of 2 Reply to Notice of Violation During an NRC inspection

conducted

from August 3 through 20, 2015, a violation

of NRC requirements

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 power reactor operating

license shall follow and maintain the effectiveness

of an emergency

plan that meets the requirements

in Appendix E to this part, and the planning standards

of 10 CFR 50.47(b).10 CFR 50.47(b) (8) requires, in part, that adequate equipment

to support the emergency

response are provided and maintained.

Contrary to the above, since December 2011, Entergy did not follow and maintain the effectiveness

of the Pilgrim Emergency

Plan to meet the requirement

that adequate equipment

to support the emergency response was provided and maintained.

Specifically, in December 2011, Entergy cancelled

preventive

maintenance

of the 160' back-up meteorological

tower, and that tower became non-functional.

As a result, 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, wind direction, air temperature, and delta air temperature.

Attachment

to PNPS Letter 2.15.077 Page 2 of 2 VIOLATION

201 5010-02 -Failure to Maintain Station Meteorological

Towers Reason for the Violation During the 2015 NRC Problem Identification

and Resolution (PI&R) Inspection

a Green Notice of Violation (NOV) was issued for failure to follow and maintain the effectiveness

of the Pilgrim Emergency

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 and restore 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 NRC documented

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 to resolve 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 achieved The Emergency

Preparedness

Department (EPD) has taken ownership

of the meteorological

towers. The EPD obtained the necessary

project funding, engineering

design support, and installation

support to install the replacement

160' tower. The tower structure

is in place. The meteorological

instruments

have been installed.

Post installation

testing of the instruments

and data communication

system is in progress.The Regulatory

Assurance

Weekly Report was modified to include a "deadline" date for completion

of corrective

actions associated

with regulatory

findings.

Additionally, a Regulatory

Assurance

review has been incorporated

as a required element for corrective

actions associated

with NRC Findings.Corrective

steps that will be taken Post installation

testing of the new 160' tower will be completed

and the tower placed in service.Date when full compliance

will be achieved The current schedule for resolution

is on or before December 16, 2015, at which time full compliance

to the NRC requirements

will be achieved.