Discusses Insp Repts 50-293/97-05,50-293/97-12 & 50-293/97-13 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $165,000ML20217N535 |
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Pilgrim |
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Issue date: |
04/27/1998 |
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From: |
Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
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To: |
Olivier L BOSTON EDISON CO. |
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Shared Package |
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ML20217N541 |
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References |
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50-293-97-05, 50-293-97-12, 50-293-97-13, 50-293-97-5, EA-97-482, EA-97-525, EA-98-052, EA-98-52, NUDOCS 9805050361 |
Download: ML20217N535 (7) |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20195K3071999-06-15015 June 1999 Forwards Safety Evaluation Granting Licensee Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Water Sys Piping for Plant ML20195K3851999-06-11011 June 1999 Forwards Copy of Notice of Consideration of Approval of Application Re Proposed Corporate Merger & Opportunity for Hearing.Application Seeks Approval of Proposed Indirect Transfer of FOL for Plant ML20196K9921999-06-0404 June 1999 Informs That NRC Ofc of NRR Reorganized Effective 990328.As Part of Reorganization,Division of Licensing Project Mgt Created ML20207E7351999-05-27027 May 1999 Responds to Requesting Reduction in IGSCC Insp Frequency Per GL 88-01 to Be Performed During Upcoming RFO 12.Forwards SE Re Reduction of IGSCC Insp of Category D Welds Due to Implementation of H Water Chemistry ML20207B6341999-05-26026 May 1999 Informs That Licensee 990415 Submittal Re Financial Position of Entergy Intl Ltd,Llc Will Be Marked as Proprietary & Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act ML20207B7391999-05-24024 May 1999 Forwards from Kc Goss of FEMA to Cl Miller Forwarding FEMA Analysis of Prompt Alert & Notification Sys for Pilgrim Nuclear Power Station.Based on Review,No Significant Problems Exist with Alert & Notification Sys ML20207B0701999-05-24024 May 1999 Responds to Sent to Ofc of Congressional Affairs Requesting Info on Concerns Raised by One Constituent,J Riel Re Y2K Compliance of Pilgrim NPP in Plymouth,Ma ML20207C0321999-05-18018 May 1999 Forwards Fifth Rept Which Covers Month of Apr 1999. Commission Approved Transfer of TMI-1 Operating License from Gpu to Amergen & Transfer of Operating License for Pilgrim Station from Beco to Entergy Nuclear Generating Co ML20206U7501999-05-17017 May 1999 Forwards Insp Rept 50-293/99-02 on 990308-0418.Two Severity Level 4 Violations Occurred & Being Treated as NCVs ML20206M1891999-05-11011 May 1999 Forwards SE of 980826 Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Sys Piping for Plant ML20206E0551999-04-29029 April 1999 Discusses Bulletin 96-03 Issued on 960506 & Beco Responses ,970207,981230,990121 & 990309 for Pilgrim Npp. Determined That Actions Taken Should Minimize Potential for Clogging of ECCS Suction Strainers ML20206B3031999-04-20020 April 1999 Forwards Insp Rept 50-293/99-01 on 990125-0307.Two Violations of NRC Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy.Security Program Was Also Inspected ML20205Q9491999-04-0909 April 1999 Informs That on 990225 NRC Staff Completed PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Develop an Integrated Understanding of Safety Performance ML20205B9391999-03-24024 March 1999 Forwards Second Request for Addl Info Re GL 95-07, Pressure-Locking & Thermal-Binding of Safety-Related Power-Operated Gate Valves ML20204C7871999-03-17017 March 1999 Informs That Application Submitting Transfer of Facility Operating License & Matls License & Proposed Amend, Will Be Marked as Proprietary & Be Withheld from Public Disclosure Pursuant to 10CFR2.709(b)(5) ML20199K8321999-01-22022 January 1999 Forwards Request for Addl Info Re Transfer of Facility Operating License for Plant ML20199H5811999-01-20020 January 1999 Submits Exemption Withdrawal of 10CFR70.24(a) Re Criticality Accident Monitoring Requirements ML20198L7781998-12-22022 December 1998 Forwards Insp Rept 50-293/98-10 on 981020-1208.No Violations Noted.Nrc Regional Specialists Reviewed EP & Fire Protection Programs.Ep Program Was Found to Be Well Implemented ML20198J0891998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Senator Kerry Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20198J1041998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Congressman Markey Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20137T2211998-12-17017 December 1998 Responds to to Chairman Jackson Re Concerns About Possible Sale of Pilgrim Station & Waste Disposal Issues.No Application for License Received Nor Contract of Sale Between Beco & Entergy.Record Copy ML20198J1161998-12-17017 December 1998 Responds to to Chairman Jackson in Which Recipient Expressed Concern About Possible Sale of Pilgrim Station & About Waste Disposal Issues.Nrc Has Not Received Application for Transfer of License to Date ML20198P2781998-12-17017 December 1998 Final Response to FOIA Request for Documents.Forwards App a Records Being Released in Entirety.App B Records Being Withheld in Entirety (Ref FOIA Exemption 4) ML20198B2021998-12-0909 December 1998 Advises of Planned Insp Effort Resulting from Licensee Irpm Review.Details of Insp Plan for Next 6 Months & Historical Listing of Plant Issues Encl ML20197H8521998-12-0909 December 1998 Responds to Ltr Sent to Chairman SA Jackson on 981028 Re Concern That NRC Will Not Perform Environ Assessment in Connection with Consideration of Approval of Transfer of License for Plants to Permit Sale ML20196J1201998-12-0404 December 1998 Ack Receipt of 971217 & 30 & 980112,0309,0423 & 0630 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-293/97-02,50-293/97-11,50-293/97-13, 50-293/97-80 & 50-293/98-01.Actions Found Acceptable ML20196B5421998-11-24024 November 1998 Forwards Plant SRO & RO Initial Exam Rept 50-293/98-301OL During Wk of 981016-23 ML20196F7631998-11-24024 November 1998 Forwards Insp Rept 50-293/98-203 on 980928-1023.No Violations Noted.Three Issues Identified Re Containment Flooding,Surveillance Testing Criteria & Protection for RBCCW System from High Energy Line Break Inside Drywell ML20196C1191998-11-20020 November 1998 Forwards Insp Rept 50-293/98-08 on 980907-1019.No Violations Noted.During Insp Period,Chemical Decontamination of Residual Heat Removal Sys Was Well Planned & Implemented Which Reduced Radiation Doses in Heat Removal Quadrants ML20195H7361998-11-16016 November 1998 Informs of Individual Exam Results for Applicants on Initial Exam Conducted on 981016 & 981019-23 at Facility.Nine Applicants Were Administered Exam & Nine Passed.Licenses Issued & Individual Test Results Encl.Without Encl ML20155C4781998-10-29029 October 1998 Forwards RAI Re Resoultion to GL 96-06 Issues at Plant,Unit 1.Response Requested by 981130 ML20154J7881998-10-0808 October 1998 Authorizes Mb Santiago to Administer Initial Written Exams to Applicants Listed (Except Applicants Redlined), on 981016.NRC Region I Operator Licensing Staff Will Administer Operating Tests During Week of 981019 1999-09-30
[Table view] |
Inspection Report - Pilgrim - 1997005 |
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+ g UNITED STATES
[ g NUCLEAR REGULATORY COMMISSION ti j REGION i S c 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406-1415
% * * * * * ,8 April 27,1998 EAs97-482; 97-525;98-052 Mr. Leon Vice President - Nuclear Boston Edison Company Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, Massachusetts 02360-5599 SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
- $165,000; AND EXERCISE OF ENFORCEMENT DISCRETION (NRC Inspection Report Nos. 50-293/97-05,97-12 and 97-13)
Dear Mr. Olivier:
This letter refers to the three subject NRC inspections conducted between May 14,1997,and January 6,1998, at the Pilgrim Nuclear Power Station in Plymouth, Massachusetts, the findings of which were discussed with Mr. H. V. Oheim and members of your staff during several exit meetings, the last of which was held on January 30,1998. The first of these inspections examined the corrective actions associated with the findings from a January 1995 self-assessment of the Pilgrim safety-related cooling water systems and other related issues.
The second inspection reviewed various engineering activities, including the replacement and subsequent modification of two 480/120 volt safeguard control transformers. The third inspection was a routine integrated inspection which, in part, reviewed an issue related to the reliability of the salt service water (SSW) pump operation. The inspection reports were sent to you previously on October 21,1997, December 17,1997, and February 6,1998.
On November 21,1997, a predecisional enforcement conference (conference) was conducted with you and members of your staff, to discuss the violations related to the first two inspections, their causes, and your corrective actions. The apparent violations identified in NRC inspection Report 97-12, issued on December 17,1997, related to the 480/120 voit transformers, were discussed at the conference, even though the inspection report had not been issued at the time of that conference. On December 16,1997, Mr. Oheim of your staff informed Mr. Wiggins of my staff that another conference was not needed to further discuss those issues.
Based on the findings of the inspections and information provided during the conference, two Seventy Level lil violations and one Severity Level lli problem (consisting of multiple violations) ,
are being cited and are described in the enclosed Notice of Violation and Proposed Imposition 1 of Civil Penalty (Notice). These violations involved a number of failures to either promptly I identify conditions adverse to quality and/or failures to promptly and effectively correct the conditions once they were identified, contrary to 10 CFR Part 50, Appendix B, Criterion XVI, as well as violations of design control requirements, and 10 CFR 50.59.
Odh3 !
PDR l f \% \
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Boston Edison Company 2 The first Severity Level lli violation involved an unreviewed safety question (USO) resulting from a modification involving insulation on recirculation loop piping located in the drywell performed in 1984. The design change involved a USQ in that the probability of a malfunction of the emergency core cooling system (ECCS) pumps (i.e., residual heat removal (RHR) and core spray) was increased due to the potentially higher line pressure losses caused by the collection of insulation debris on the pump suction strainers. To alleviate this, the design change took credit for post-accident containment overpressure to assure adequate ECCS pump net positive suction head (NPSH). Crediting of containment overpressure was inconsistent ,
with the plant licensing basis as described in the Updated Final Safety Analysis Report ]
(UFSAR). However, you failed to recognize that crediting containment overpressure increased the probability of a malfunction of the ECCS pumps, and the safety evaluation performed to support the modification incorrectly concluded that the change did not involve a USO.
Consequently, the change was made without NRC approval. In addition, this issue was not appropriately addressed until January 20,1997 (when you requested NRC review and approval for including containment pressure as a component of NPSH margin in the Pilgrim i
'
licensing basis) even though there were prior opportunities to identify and correct the problem, namely: (1) the 1995 service water system operational performance inspection (SWSOPI) self-assessment that identified that the 1984 safety evaluation may have improperly credited containment overpressure in the NPSH calculations; (2) a subsequent safety evaluation completed on March 25,1996 which also incorrectly concluded that the 1984 plant modification did not involve a USO; and (3) the report of an independent review of the containment overpressure issue performed by Yankee Atomic Electric Company in 1996 that concluded that containment overpressure was not credited in the Pilgrim licensing basis.
The second Severity Level 111 violation involves a design deficiency which introduced an unintended trip function in the microprocessors that control the transformers which supply 120 Vac power to safety-related instrument busses. Following an event on April 1,1997 in which the unintended trip function caused a common mode malfunction of two transformers, the safety evaluation performed to support replacement of the microprocessors failed to ,
recognize the existence of a USO. ]
The Severity Level lli problem consisting of seven violations involved cond;tions adverse to quality that were not identified and/or corrected including: (1) operation of the plant with salt service water (SSW) system inlet temperatures higher than designed; (2) a single failure vulnerability in the SSW system design; (3) failure to translate, into procedures, the design requirement to isolate non-essential reactor building closed cooling water (RBCCW) system ;
loads during accident conditions; (4) failure to adequately translate, into procedures, residual l heat removal (RHR) system design flow rates for containment heat removal; (5) deficiencies )
'
in emergency diesel generator (EDG) loading calculations and procedures; (6) operation of the EDGs at ambient temperatures higher than the design limit; and (7) inaccuracies in the !
environmental qualification (EO) drywell temperature profile for electric equipment important l to safety.
Several of these adverse conditions resulted from failure to properly translate the design bases of the plant into specifications, procedures, and instr"ctions. For example, the RHR system design flow rate of 5100 gpm used in design basis containment heat transfer and pressure / temperature calculations was not properly translated into procedures in that the flow
.
.
Boston Edison Company 3 rates specified in the system operating procedure were not supported by calculations that considered the effects of instrument accuracy. Specifically, the RHR operating procedure specified a flow range of 4800 to 5100 gpm for containment cooling during accident conditions. There was no analysis to confirm that adequate heat removal would be provided at the lower flow rate specified in the operating procedure, including the effects of instrument error. Similarly, there was no analysis to demonstrate that flows greater than 5100 gpm (which, after considering the effects of instrument error, could occur) would not exceed the design limitations of the RHR heat exchangers.
In some cases, you identified the design deficiency, but failed to take prompt action to correct the deficiency once it was identified. For example, during the service water system operational performance inspection (SWSOPI) self-assessment in 1995, you identified that no procedural guidance existed to isolate the non-essential RBCCW system heat loads during an accident, an action assumed in the licensing bases for the plant. However, at the time of the NRC inspection in 1997, no action had been taken to address the identified deficiency. The NRC is concerned that, although you identified inconsistencies between the safety analyses and plant specifications and procedures, you apparently failed to recognize the significance of the conditions in that prompt action was not taken to correct the discrepancies. You also failed to recognize that some of these conditions resulted in the plant being operated outside of the design basis as evidenced by the fact that the conditions were not reported to the NRC pursuant to 10 CFR 50.72 and 50.73.
Additionally, in some cases, your corrective actions to address the deficiencies after they were identified, were inadequate because you either failed to perform required safety evaluations, or performed safety evaluations that failed to identify unreviewed safety questions (USQs).
In a number of cases, you limited your formal evaluations to operability determinations and often relied upon engineering judgement rather than formal analyses to support your actions.
For example, although you identified as early as July 1994, that a design basis change was needed to support operation of the plant with SSW inlet temperatures above the design limit of 65'F specified in Updated Final Safety Analysis Report (UFSAR), a safety evaluation to support a change to the licensmg basis was not performed until March 1996 even though you operated the plant during the interim with SSW temperatures in excess of 65'F. In the interim, you relied on an operability determination that concluded that the RBCCW system was operable with elevated SSW temperatures, and you used engineering judgement to support the use of " rolling averages" to justify operation of the plant with SSW temperatures above 65'F. When a formal safaty evaluation was performed, the evaluation was inadequate because post-accident containment overpressure was inappropriately credited in ECCS pump NPSH margin calculations contrary to the plant's licensing basis.
The NRC is concerned that the plant was operated outside of the NRC approved licensing bases because of an apparent fundamental misunderstanding of what constitutes a change to the design and licensing bases. While there were no resultant adverse safety consequences in any of these cases, the potential existed that, had a design basis accident occurred, safety-related equipment and systems were not assured of accomplishing their design functions.
Additionally, the failure to identify and/or correct these conditions adverse to quality is of significant regulatory concern because the NRC relies upon licensees to operate the plant within the approved licensing basis and to correctly assess changes to the plant or its operations to assure that unreviewed safety questions do not exist.
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Boston Edison Company 4 The violations represent a failure to take corrective actions to resolve programmatic weaknesses in your design control and safety evaluation processes. The violations associated
' with inappropriately crediting containment overpressure in calculations of ECCS pump NPSH margin, and a design deficiency in the microprocessors that control the transformers which supply 120 Vac power to safety-related instrument busses, are each categorized as separate Severity Level !ll violations in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600,in that each involved the creation of a USQ. The remainder of the violations are classified in the aggregate as a Severity Level 111 problem because they represent a failure to implement corrective actions in a number of different areas.
in accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000is
, considered for each Severity Level 111 violation or problem. Since Pilgrim has been the subject of escalated enforcement actions within the last two years,' the NRC considered whether credit was warranted for /dentification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy for each, Severity Level 111 violation and the Severity Level 111 problem. While you identified some of the technical issues, no credit is warranted for identification because the NRC identified the USQs and your failure to promptly identify and resolve these conditions adverse to quality. Your corrective actions, once you were put on notice by the NRC, included: 1) procedure revisions; 2)
performance of the necessary safety evaluations; 3) broad scope UFSAR and licensing basis documentation reviews; 4) revision of the guidance for evaluating conditions for reportability; and 5) increased management attention to the corrective action process. Since these corrective actions appear comprehensive, credit is warranted for corrective actions.
Therefore, to emphasize the importance of timely identification and comprehensive correction of problems and in recognition of your previous escalated enforcement actions, I have been authonzed, after consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed imposition of Civil Penalty in the amount of $165,000. This is comprised of a base civil penalty of $55,000 for each Severity Level ill violation and for the Seventy Level til problem in Section I of the Notice. j l
Four separate Severity Level IV violations for failure to make timely notifications and reports ;
to the NRC in accordance with 10 CFR 50.72 and 10 CFR 50.73 for some of the situations described in Section I of the Notice are described in Section 11.
Additionally, during your follow-up review of EDG loading, conducted as a result of the violations identified during the NRC SWSOPl follow-up inspection, you identified a design deficiency associated with the thermal cverload relay trip settings for the SSW pumps that j could have resulted in an inadvertent trip of the pumps and a loss of all SSW cooling. This I issue was identified as an apparent violation of 10 CFR Part 50, Appendix B, Criterion ill in NRC Inspection Report 97-13. The NRC has determined that the failure to assure that the SSW design bases were correctly translated into the overload trip settings constituted a
e.g., A Notice of Violation without a civil penalty was issued on October 21,1996 for a Severity level HI problein involving a violation of containmant integrity Technical Specification requirements and failure to correct deficiencies in electrical penetrations (EA 96-271).
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Boston Edison Company 5 violation of NRC requirements which could be considered for escalated enforcement and subject to civil penalties. However, after consultation with the Director, Office of Enforcement, I have been authorized to not issue a Notice of Violation and not propose a civil penalty for this issue in accordance with the provisions provided in Section Vll.B.4 of the Enforcement Policy. This decision was made after consideration that: (1) the violation was identified by your staff as part of corrective action for violations that were subject to escalated enforcement action; (2) the violation has a similar root cause as the other design deficiencies for which escalated action is being issued; (3) it does not substantially change the safety significance or the character of the regulatory concern arising from the initial violations; (4)
immediate corrective action was taken to reset the trip setpoints; and (5) you have planned long term corrective actions to address the root cause of the violation. The exercise of discretion acknowledges your effort to perform comprehensive actions to identify and correct similar violations to those for which escalated enforcement action was issued.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. Due to the programmatic nature of these violations, the NRC expects that your response will address not only the specific violations cited, but will also include the results of any extent of condition reviews that you have performed in the areas of design control, safety evaluations, and reportability. 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, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely, H ert J. Miller Regional Administrator Docket No. 50-293 License No. DPR 35 Enclosure: Notice of Violation and Proposed imposition of Civil Penalty
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Boston Edison Company 6 cc w/enci:
R. Ledgett, Executive Vice President - Operations C. Goddard, Plant Department Manager 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 B. Abbanat, Department of Public Utilities 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 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 I
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Boston Edison Company DISTRIBUTION:
PUBLIC SECY CA LCallan, EDO AThadani, DEDE JLieberman, OE HMiller, RI FDavis, OGC
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SCollins, NRR RZimmerman, NRR Enforcement Coordinators Rl, Ril, Rlli, RIV BBeecher, GPA/PA GCaputo, Ol DBangart, OSP HBell, OlG TMartin, AEOD OE:Chron OE:EA DCS NUDOCS DScrenci, PAO-Ri NSheehan, PAO-RI
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LTremper, OC Nuclear Safety Information Center (NSIC)
NRC Resident inspector - Pilgrim cis0004
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