IR 05000293/2003003
| ML030650850 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/06/2003 |
| From: | David Lew NRC/RGN-I/DRS/PEB |
| To: | Bellamy R Entergy Nuclear Operations |
| References | |
| IR-03-003 | |
| Download: ML030650850 (16) | |
Text
rch 6, 2003
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 50-293/03-003
Dear Mr. Bellamy:
On January 31, 2003, the US Nuclear Regulatory Commission (NRC) completed an inspection at the Pilgrim Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on January 31, 2003, with you and members of your staff.
The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspection involved examination of selected procedures and representative records, observation of activities, and interviews with personnel.
On the basis of the sample selected for review, the NRC concluded that the implementation of the corrective action program was adequate. In general, problems were properly identified, evaluated, and corrected. However, the team identified some instances in which the evaluations were not thorough or timely. These evaluations, some of which were associated with Category A condition reports, were not sufficiently detailed to address all underlying issues.
The team identified one finding of very low safety significance (Green) involving a failure to follow procedure, which resulted in a control rod being left in the wrong position. This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Pilgrim.
Robert In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
David C. Lew, Chief Performance Evaluation Branch Division of Reactor Safety Docket Nos: 50-293 License Nos: DPR-35 Enclosure: Inspection Report 50-293/03-03 cc w/encl:
M. Krupa, Director, Nuclear Safety & Licensing W. Riggs, Director, Nuclear Assessment Group D. Tarantino, Nuclear Information Manager B. Ford, Regulatory Affairs Department Manager J. Fulton, Assistant General Counsel R. Hallisey, Department of Public Health, Commonwealth of Massachusetts The Honorable Therese Murray The Honorable Vincent deMacedo Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Committee Plymouth Civil Defense Director D. OConnor, Massachusetts Secretary of Energy Resources J. Miller, Senior Issues Manager Office of the Commissioner, Massachusetts Department of Environmental Protection Office of the Attorney General, Commonwealth of Massachusetts Chairman, Citizens Urging Responsible Energy S. McGrail, Director, Commonwealth of Massachusetts, SLO Designee Electric Power Division Commonwealth of Massachusetts, Secretary of Public Safety R. Shadis, New England Coalition Staff
Robert
SUMMARY OF FINDINGS
IR 05000293/02-003; 01/13 - 01/31/2003; Pilgrim Nuclear Power Station; routine biennial baseline inspection of Problem Identification and Resolution.
The inspection was conducted by four regional inspectors. One Green non-cited violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using IMC 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
Identification and Resolution of Problems Based on the sample selected for review, the inspection team concluded that the implementation of the corrective action program at Pilgrim was adequate. In general, personnel identified problems at an appropriate threshold and initiated a Condition Report (CR) to enter them into the corrective action program. Audits and self-assessments identified adverse conditions and negative trends, and the results were entered into the corrective action program.
The licensees evaluations were generally adequate to reasonably identify the causes of problems and provide for corrective actions. However, the team identified some instances in which the evaluations were not thorough or timely. These evaluations, some of which were associated with Category A CRs, were not sufficiently detailed to address all underlying issues. One instance, regarding a failure to follow a procedure that resulted in a control rod being left in the wrong position, was determined to be a finding of very low safety significance (Green). The finding was also determined to be a violation of NRC requirements.
Inspector Identified Findings
Cornerstone: Barrier Integrity
C
- Green.
A non-cited violation of 10CFR50, Appendix B, Criterion V, was identified for a failure to follow a surveillance test procedure for control rod timing that resulted in a control rod being left in the wrong position.
This finding is greater than minor because, if left uncorrected, it could lead to reactivity control issues that can result in core thermal limits being exceeded. This finding affected the Barrier Integrity cornerstone. This finding was of very low significance (Green) because issues affecting the fuel barrier screen to Green in Phase 1 of the Significance Determination Process for Reactor At-Power Situations. (Section 4OA2.b(2))
REPORT DETAILS
OTHER ACTIVITIES (OA)
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Occupational Radiation Safety, Public Radiation Safety, Physical Protection
4OA2 Identification and Resolution of Problems (IP 71152)
a. Effectiveness of Problem Identification
- (1) Inspection Scope The team reviewed the procedures describing Entergys corrective action process and determined that the Pilgrim Nuclear Power Station (PNPS) identified problems primarily through the initiation of condition reports (CRs). The site recently changed to the Entergy computer-based Paperless Condition Reporting System (PCRS). The team noted that PNPSs process required the initiation of maintenance requests (MRs) for CRs associated with equipment deficiencies and engineering requests (ERs) for CRs requiring engineering support. To aid the inspectors in understanding PNPSs threshold for identifying and entering problems into their corrective action process, team members attended the daily CR Screening meeting, where CRs were reviewed for initial significance category and assignment. Team members also attended the daily management meeting, the Condition Report Group (CRG) meeting where managers review each CR, and the MR review meeting.
The team reviewed a sample of CRs to determine whether PNPS was identifying, accurately characterizing, and entering problems into the corrective action process at an appropriate threshold. The CRs selected covered the period from the last NRC problem identification inspection in June 2001 to the present. The team selected the CRs to cover the seven cornerstones of safety identified in the NRC Reactor Oversight Process (ROP). In addition, the team considered risk insights from PNPSs probabilistic risk assessment (PRA) to focus the CR sample on risk significant plant equipment. The to this Inspection Report lists the CRs selected for review.
The team also interviewed selected plant staff to understand the other processes used to address problems. The team conducted walkdowns of the control room and selected areas of the plant, to independently assess whether problems were identified and were being adequately addressed. The team toured the security alarm stations and interviewed guards, and walked down the protected area perimeter to assess securitys identification of problems.
The team selected items from PNPSs maintenance, operations, engineering, health physics, emergency preparedness, and oversight processes to verify that PNPS appropriately considered problems identified in these sources for entry into the corrective action program. Specifically, the team reviewed a sample of MRs, ERs, operator log entries, control room deficiency and work-around lists, operability determinations, engineering system health reports, procurement related deficiencies, completed surveillances, installed temporary modification packages, quality assessment reports, and departmental self-assessments. The documents were reviewed to ensure that underlying problems associated with each issue were appropriately considered for identification and resolution via the corrective action process. The documents reviewed are listed in the Attachment.
- (2) Findings Based on the sample reviewed, the team concluded that PNPS was adequately identifying problems and entering them into their corrective action process. The CRs reviewed generally described and characterized the problems and, as appropriate, identified prior similar occurrences. In addition, the team concluded that personnel initiated corrective action CRs for problems identified in other PNPS processes that met the CR threshold. The inspectors considered the quality assurance audits and department self-assessments reviewed to be generally effective in identifying adverse conditions and negative trends.
b. Prioritization and Evaluation of Issues
- (1) Inspection Scope The team reviewed the CRs listed in the Attachment to determine whether PNPS adequately evaluated and prioritized problems. The review included the appropriateness of the assigned significance, the timeliness of resolutions, and the scope and depth of the causal analysis. The CRs reviewed encompassed the full range of PNPS evaluations, including root cause analysis and apparent cause evaluations.
The team selected the CRs to cover the seven cornerstones of safety identified in the NRC ROP. The team considered risk insights from PNPSs PRA to help focus the CR sample. Additionally, the team attended the CRG meetings to observe the review process and to understand the basis for assigned significance - Category A (highest) to D (lowest).
The team reviewed the CRs associated with the NRC non-cited violations (NCV), issued since the last PI&R inspection, to determine whether PNPS evaluated and resolved the problems associated with compliance to applicable regulatory requirements. The team reviewed PNPSs evaluation of industry operating experience information for applicability to their facility. The team also reviewed the PNPS assessment of equipment operability, reportability requirements, and the potential extent of the problem. The team further reviewed equipment performance results and assessments recorded in completed surveillance procedures, operator log entries, and system engineer trending data to determine whether PNPSs evaluation of equipment performance was technically adequate to identify degrading or non-conforming equipment.
- (2) Findings The inspectors determined that the CRs reviewed were properly classified as to significance level (A through D). Significant conditions adverse to quality were classified as Category A and received a formal root cause analysis (RCA), and an extent-of-condition review. The Category B CRs usually received an apparent cause evaluation (ACE). The quality of the RCAs and ACEs reviewed was mixed; however, the team noted that the causal determinations performed in the last six months were generally more detailed and thorough, with better correlation between the causes and the corrective actions, and with corrective actions to preclude recurrence. The backlog of issues appeared reasonable and properly evaluated for risk, both individually and collectively. The majority of the CRs were for minor issues and were classified as Category C or D - corrected and closed to trending.
Notwithstanding the above, the team identified several occurrences where the PNPS staff did not perform a thorough or timely evaluation of the problems. Some of the evaluations were associated with Category A CRs; the Pilgrim station initiates about 25 Category A CRs each year. Examples of these weak evaluations, including one which was dispositioned as a Green finding, include:
C In January 2001, during bench testing of safety-related relays for a temporary modification, a PNPS technician noted that the relays did not conform to the required design specification. The extent of condition review identified two other non-conforming relays, that had been purchased at the same time, that were installed in the plant. Specifically, the relays were in the safety-related automatic bus transfer power supply scheme for the valves in the B train of the low pressure coolant injection system (LPCI) since April 2000. PNPS initiated CR-2001-09004.
The resident inspectors reviewed the event and documented in NRC Inspection Report 50-293/2001-02 a licensee-identified NCV against 10CFR50, Criterion VII, Control of Purchased Material, Equipment, and Services.
During this inspection, the team reviewed the RCA associated with the CR and concluded that the licensees evaluation was weak. While the team concluded that the overall corrective actions should be adequate to prevent recurrence, the licensees review of the event was not thorough. Specifically, the team noted that PNPS did not determine why the pre-installation bench test did not identify the non-conforming relays in April 2000, while the test was able to identify that the second set of relays were non-conforming in January 2001. Further, the licensee initiated a corrective action task to evaluate the bench test procedures; however, the action was closed with the belief that the procedures were acceptable as-is. During this inspection, PNPS re-issued the original task because the intent of the review was not understood; i.e., to evaluate the existing procedure or develop a new procedure for other relay types used in the plant.
C In July 2002, during an emergency preparedness (EP) drill, an EP manager raised a concern as to whether the main stack high range effluent radiation monitor would remain on scale if significant fuel damage occurred. It was noted in the CR that the monitor was operable, but an engineering request (ER #02113994) was submitted to verify that the range of the monitor was adequate. The CR was closed before the ER was completed. The high range monitor is a requirement of NUREG 0737, Clarification of TMI Action Plan Requirements, it is described in the PNPS Updated Final Safety Analysis Report (UFSAR), and it is listed in the PNPS Technical Specifications (TSs).
During this inspection, the team discovered that the ER had not yet been completed - a period of six months since the initiation of the ER. Subsequently, a draft engineering evaluation was performed by the licensee at the end of the inspection. However, the basis for the evaluation appeared invalid. An NRC effluents specialist in Region I confirmed that the basis for the draft engineering evaluation was improper. However, the NRC specialist was able to describe the flowpath from the main stack to the monitor, and why the dilution of the flowpath would assure that the monitor would be on scale for all postulated accidents. The specialist and team leader discussed this issue with PNPS staff, who acknowledge that their original evaluation was not valid.
Mis-Positioned Control Rod
Introduction:
A Green Non-Cited Violation (NCV) was identified for failure to comply with 10CFR50, Appendix B, Criterion V, related to a mis-positioned control rod.
Description:
In November 2002, CR-2002-12550 was initiated for a mis-positioned control rod following the performance of a surveillance test for control rod timing and adjustment. The CR was classified as Category A, with a RCA required.
The surveillance test being performed was Procedure 2.2.87.3, Control Rod Drive Venting, Timing, and Adjustment, a detailed operation involving multiple valve manipulations, numerous control rod timings, and frequent documentation by the operator performing the evolution and a second operator verifying the activity. The shift crew decided to time one control rod while concurrently adjusting another control rod.
Specifically, the reactor operator moved control rod 34-47 from position 48 to 44 to measure the insertion time; at the same time, an in-plant operator informed the control room that control rod 06-43 was adjusted and ready to be timed again. Instead of returning control rod 34-47 to its original position, the reactor operator became distracted and selected control rod 06-43 for timing.
The specific steps required for adjustment of the control rods were detailed in 4A to the procedure. When no further adjustments were required, the attachment required the operator to record the as-left position in Attachment 4B and initial the entry; the procedure also required a 2nd operator to verify the position and initial. The mis-positioning was identified after about 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, at which time the rod was returned to the appropriate position.
The team reviewed the licensees evaluation associated with the level A CR and determined that the licensees evaluation was not thorough and was not sufficiently detailed to address the underlying issues. The evaluation attributed the cause of the event to the crews deviation from the intended sequence for performing the surveillance test, and further states that the procedure did not specifically preclude the approach.
However, PNPS did not look at the past occurrences of mis-positioning for similarities and overall corrective action effectiveness. The team noted during the inspection that numerous mis-positioning events occurred last year. Many were associated with equipment issues, but several were the result of human errors.
Additionally, the inspectors learned that Attachment 4A was not used for this occurrence of the surveillance, and that the as-left section of Attachment 4B had not been completed for multiple control rods. During discussions with operations management, the inspectors were informed that the operators were not required to use Attachment 4A, as it was a place-keeping aid. However, PNPS Procedure 1.3.34, Conduct of Operations, step 6.8[3], stated that surveillance tests and procedures, which required initials for verification of step performance, shall be present and followed verbatim while the task is being performed. The team concluded that these were issues regarding procedural adherence that should have been addressed in the evaluation.
Analysis:
The failure to follow the control rod surveillance test was a performance deficiency which involved reactivity control. This finding is greater than minor because, if left uncorrected, it can lead to reactivity control issues that can result in core thermal limits being exceeded. This finding affects the Barrier Integrity cornerstone. Using Phase I of the Significance Determination Process (SDP) for Reactor At-Power Situations, the inspectors determined that this finding is of very low significance (Green)because issues affecting the fuel barrier screen to Green.
Enforcement:
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality be prescribed by written procedures of a type appropriate to the circumstances and be accomplished in accordance with the procedures. Contrary to the above, control rod drive venting, timing, and adjustment was not accomplished in accordance with procedures and resulted in a mis-positioned control rod. Because the mis-positioning is of very low safety significance and is in the PNPS corrective action program (CR-2003-00398), this violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy.
NCV 50-293/2003-003-01, Failure to Follow Procedures, Resulting in a Control Rod Mis-Positioning During Surveillance Testing c. Effectiveness of Corrective Actions
- (1) Inspection Scope The team reviewed the CRs listed in the Attachment to determine whether the actions addressed the identified causes of the problems. The team reviewed PNPSs timeliness in implementing corrective actions and their effectiveness in preventing recurrence of significant conditions adverse to quality.
- (2) Findings No significant findings were identified in this area. The licensees actions were generally effective in correcting the identified deficiency and preventing recurrence. However, as noted in Section 4OA2.b, the team noted a number of control rod mis-positioning events.
d.
Assessment of Safety Conscious Work Environment
- (1) Inspection Scope Team members interviewed plant staff, observed various activities throughout the plant, and attended a cross section of meetings to determine if conditions existed that would result in personnel being hesitant to raise safety concerns to their management and/or the NRC.
- (2) Findings No findings of significance were identified.
4OA6 Meetings, Including Exit
The team presented the inspection results to Mr. R. Bellamy, Site Vice-President, and other members of the PNPS staff on January 31, 2003. PNPS management acknowledged the results presented. No proprietary information was retained after the inspection.
On February 6, 2003, the inspection team leader clarified the NRCs position relative to concerns associated with the main stack high range effluent radiation monitor. PNPS participants included B. Ford, Licensing Manager, and D. Landeche, Corrective Action Manager
- Key Points of Contact Items Opened, Closed, and Discussed Documents Reviewed Abbreviations Used
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
A. Battikha Procurement Engineer
R. Bellamy Site Vice President
S. Bethay Engineering Director
A. Bordan Quality Assurance Receipt Inspector
W. Coady Radiation Protection Technician
M. Dagnello Electrical Maintenance Supervisor
P. Dietrich General Manager Plant Operations
B. Ford Licensing Manager
W. Grieves Quality Assurance Manager
J. Haley Licensing Engineer
J. Hurley Radiation Protection Supervisor
J. Keyes Corrective Action Superintendent
D. Landeche Corrective Action Manager
B. Lyons Operations Support Superintendent
G. McCarthy Work Week Manager
B. Riggs Director Nuclear Safety & Assessment
R. Rose Security Manager
K. Sejkora Senior HP/Chem Specialist
B. Sholler Mechanical Maintenance Supervisor
T. Sowden Emergency Preparedness Manager
N. Walo Employee Concerns Program Coordinator
NRC Personnel
D. Lew Branch Chief
W. Raymond Senior Resident Inspector
C. Welsh Resident Inspector
ITEMS OPENED and CLOSED
Opened & Closed
50-293/003-03-01 NCV Failure to Follow Procedures, Resulting in a Control Rod Mis-
Positioning During Surveillance Testing.
(Section 4OA2.b(2)