IR 05000293/1997006

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/97-06
ML20216H215
Person / Time
Site: Pilgrim
Issue date: 09/10/1997
From: Meyer G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Boulette E
BOSTON EDISON CO.
References
50-293-97-06, 50-293-97-6, NUDOCS 9709160178
Download: ML20216H215 (3)


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September 10, 1997 l

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I E. Thomas Boulette, PhD i Senior Vice Presideat Nucleer  !

Boston Edison Company i Pil9tim Nuclear Power Station 600 Rocky Hill Road Plymouth, Massachusetts -02360 5599 l SUBJECT: NAC INSPECTION No._50 293/97-06 (REPLY)

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Dear Dr. Boulettei

This. letter refers to your August 18,1997 correspondence, in response to our July 18,1997 lette i'

Thank you for informing us of the corrective and preventive actions documented in your letter to assure that applicants for initial operator examinations will have properly  ?

performed the required five significant control manipulations. These actions will be  ;

i examined during your next licensed operator examinatio Your cooperation with un is appreciate

Sincerely, i

S Glenn W. Meyer, Chief ,

Operator Licensing and Human Performance Branch ,

Division of Reactor Safety Docket No. 50 293 ,

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E. Thomas Boulette -2 l

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L. Olivier, Vice President . Nuclear and Station Director +

T. Sullivan, Plant Department Manager  :

N. Desmond, Regulatory Relations >

D. Tarantino, Nu: lear Information Manager i

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R. Hallisey,- Department of Public Health, Commonwealth of Massachusetts j i The Honorable Therese Murray  !

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The Honorable Joseph Gallitano i B. Abbenet, Departmont of Public Utilities

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Chairman, Plymouth Board of Selectmen

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Chairman, Duxbury Board of Selectmen'  :

Chairman, Nuclear Matters Committee  !

Plymouth Civil Defense Director _ _ -

P. Gromer, Massachusetts Secretary of Energy Resources  !

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_ ~J. Milier, Senior issues Manager

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- J. Fleming -.

A. Nogee,- MASSPIRG >

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Office of the Commissioner, Massachusetts Department of Environmental Quality Engineering i Office of the Attorney General, Commonwealth of Massachusetts

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T. Rapone, Massachusetts Executive Office of Public Safety i Chairman, Citizens Urging Responsible Energy l 1 Commonwealth of Massachusetts, SLO Designee ,

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E. Thomas Boulette 3 Distribution w/ encl:

Region I Docket Room (with concurrences)

PUBLIC Nuclear Safety Information Center (NSIC)

NRC Resident inspector  ;

R. Conte, DRP M. Conner, DRP C. O'Daniell, DRP P. Milano, NRR A. Wang, NRR W. Dean, OEDO c

DOCDESK Inspection Program Branch, NRR (IPAS)

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DOCUMENT NAME: A: PILG9706. REP

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To reeche a copy or this dorpment lascate la the bott 'C' = Copy without attachment / enclosure T = Copy whh attachmenvenclosure 'N' = No copy OFFICE - @lgRjM l Al/DRS l Rl/ Rl/ l Ri/

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GMeyer (, ,

DATE QF/27/97 09/8)/97 "j" 08/ /97 08/ /97 08/ /97

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OFFICIAL RECORD COPY i

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Pdyrn Nuc a P w Staten Plymouth. Massachusett 02360 L J. 00 Met vu Ps wwa Nuom ope'etens August 18, 1997

"'8 8 *" D""'" BECo Ltr. 2.97. 084 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 License DPR 35 Docket 50-293

- SUBJECT:- REPLY TO NOTICE OF VIOLATION (REFERENCE NRC INSPECTION REPORT N /97 06)

Enclosed is Boston Edison Company's reply to the Notice of Violation contained in the subject inspection repor The following commitments are made in this letter:

. Prior to the present class of license candidates beginning their on shift training phase, additional guidance will be incorporated into the license candidate shift qualification book. This guidance will

. specify that continuous, significant control manipulation by a common mechanism (e.g.,

recirculation flow or control rod movement) will count as a single significant manipulation, regardless of the size of the overall plant power change. This action will be completed by January 1,199 . A requirement for specific leview of each license candidate's significant control manipulations by training department personnel will also be added to the candidate shift qualification book prior to the present class of !icense candidates beginning the on shift phase of their training. This action will be completed by January 1,199 Please do not hesitate to contact me if there are any questions regarding the enclosed repl ~

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1 J. Olivier RLC/dmc/vio97 06 Enclosure 1: _ Reply to Notice of Violation-

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,' Pilgrim Nuclear Power Station cc: Mr. Alan Wang, Project Manager Project Directorate 13 Office of Nuclear Reactor Regulation Mall Stop: OWF 1402 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockvillo Pike Rockvillo, MD 20852 U. S. Nuclear Regulatory Commission Region 475 Allendalo Road King of Prussla, PA 19400 Senior NRC Resident inspector Pilgrim Nuclear Power Station

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,' Boston Edison Docket N3. 50 293 Pilgrim License No. DPR 35 Enclosure 1 Reply to Notice of Violation During the Initiallicensing examination conducted by the MC the week of May 5 9.1997, the lead cxaminer identified some of the reactivity manipulations performed by our applicants may not have satisfied the NRC's expectations. This resulted in the following violation of NRC requirements (VIO 50-293/97 06-01):

NOTICE OF VIOLATION

  • 10 CFR 55.31(a)(5) requires, in part, that applicants for operator licenses must have performed five significant control manipulations on the plant that affects reactivity or power level, Contrary to the above, as identified on May 5,1997, two senior reactor operator applications, dated April 18,1997, and submitted to the NRC, had documented five manipulations based on credit taken for multiple manipulations due to the extent of the power change when one manipulation should have been credited. When multiple manipulations due to extended power changes were removed, one applicant had two significant control manipulations, and the other appilcant had three significant control manipulations, This lo a severity level IV violation (Supplement Vil)"

REASON FOR THE VIOLATION An incorrect assessment of conditions substantiating a license candidate's required reactivity manipulations resulted in this violation. The factors that led to this incorrect assessment are discussed in detail in the following paragrap An interpretation of what constituted a "significant control manipulation" was based on reviews of NUREG 1202, " Answers to Questions at Public Meeting Regarding implementation of Title 10, Code of Federal Regulations, Part 55 on Operator Licenses", Regulatory Guide 1.8, " Qualification and Training of Personnel for Nuclear Power Plants",10 CFR 55.59, "Requalification", and 10 CFR 55.31(a)(5).

Following this review, we established an "in-house' listing of examples in the candidate shift qualification book. The listing would provide examples that would satisfy the requirement for a single reactivity manipulation for licensing purposes; this list of examples does not, however, provide limiting conditions describing how the manipulations are to be conducted or counte CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED To ensure the license applicants in question had met the NRC's minimum requirement for reactivity manipulations, those two candidates performed additional reactivity manipulations while the NRC was cvaluating the validity of the challenged manipulations. Following the satisfactory performance of two additional reactivity manipulations for one of the license candidates and three additional reactivity manipulations for the other license candidate, updated licenso applications for those two candidates i

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wera submitted to the NRC on June 16,1997 (r:f:r:nce BECo lett:r 2.97.062). The id:ntift:d viol: tion

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was entered into our corrective action process by the generation of Problem Report (PR) 97.255 CORRECTIVE STEPS THAT WILL BE TAKEN TO AVolD FURTHER VIOLATIONS Prior to the present class of license candidates beginning their on shift training phase, additional j guidance will be incorporated into the license candidate shift qualification book. This guidance will specify that continuous, significant control manipulation by a cominon mechanism (e.g., recirculation

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flow or control rod movement) will count as a single significant manipulation, regardless of the size of i the overall plant power chang ,

A requirement for specific review of each licenso candidate's significant control manipulations by l

l training department personnel will also be added to the candidate shift qualification book prior to the present class of license candidains beginning the on shift phase of their training, i

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Those actions will be completed by January 1,199 DATE WHEN FULL COMPLIANCE WAC ACHIEVED

Full compliance was achloved on June 7,1997, when all required significant reactivity manipulations i h9d been completed for both candidates Following completion of the last significant reactivity manipulation, updated license applications for those two candidates were submitted to the NRC.

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