IR 05000293/2008007

IR 05000293-08-007, on 04/28/2008 - 06/16/2008, Pilgrim Nuclear Power Station, Component Design Bases Inspection

ML082130006
Person / Time
Site:	Pilgrim
Issue date:	07/30/2008
From:	Doerflein L Engineering Region 1 Branch 2
To:	Bronson K Entergy Nuclear Operations
References
IR-08-007
Download: ML082130006 (40)

Text

uly 30, 2008

SUBJECT:

PILGRIM NUCLEAR POWER STATION - NRC COMPONENT DESIGN BASES INSPECTION REPORT 05000293/2008007

Dear Mr. Bronson:

On June 16, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents the inspection results. The preliminary inspection results were discussed with you and other members of your staff on May 22, 2008. Following in-office review of additional information, the final results of the inspection were provided via telephone to Mr. T. White and other members of your staff on June 17, 2008.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

In conducting the inspection, the team examined the adequacy of selected components and operator actions to mitigate postulated transients, initiating events, and design basis accidents.

The inspection involved field walkdowns, examination of selected procedures, calculations and records, and interviews with station personnel.

This report documents four NRC-identified findings which were of very low safety significance (Green). All of these findings were determined to involve violations of NRC requirements.

However, because of the very low safety significance of the violations and because they were entered into your corrective action program, the NRC is treating the violations as non-cited violations (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any 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 U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, Region 1; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspectors at PNPS. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for the public inspection in the NRC Public Docket Room or from the Publicly Available Records component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Lawrence T. Doerflein, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-293 License No. DPR-35 Enclosure: Inspection Report 05000293/2008007 w/Attachment: Supplemental Information

SUMMARY OF FINDINGS

IR 05000293/2008007; 04/28/2008 - 06/16/2008; Pilgrim Nuclear Power Station; Component

Design Bases Inspection.

The report covers the Component Design Bases Inspection conducted by a team of four NRC inspectors and two NRC contractors. Four findings of very low risk significance (Green) were identified, which were also considered to be non-cited violations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (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 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The team identified a finding of very low safety significance involving a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, in that, Entergy did not promptly correct deficiencies with the B 125 Vdc battery charger supply circuit breaker. Specifically, Entergy did not properly evaluate and take adequate corrective actions for a condition adverse to quality associated with elevated temperatures on the circuit breaker terminals; and subsequently, the circuit breaker failed when recharging the B 125 Vdc battery.

Entergy entered the issue into their corrective action system, completed an operability assessment, and reviewed installed circuit breakers to ensure a similar condition did not exist.

The finding is more than minor because the degraded condition represented reasonable doubt on the operability of the B 125 Vdc charger and its associated breaker. The finding is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance (Green) because it did not result in the loss of system safety function. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program Component, because Entergy did not adequately evaluate the condition adverse to quality, which they originally identified in January 2006 (IMC 0305, Aspect P.1(c)).

(1R21.2.1.1)

Green.

The team identified a finding of very low safety significance involving a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, in that, Entergy did not properly evaluate and take adequate corrective actions for a condition adverse to quality associated with an intake de-watering event on September 14, 2007. Specifically, a fish intrusion event resulted in a significant lowering of intake level and challenged the continued availability of the A loop of ii

salt service water (SSW). Entergys issue prioritization, operability review, and subsequent evaluation did not adequately assess and correct the plant response relative to the safety-related SSW design and licensing bases. Entergy entered the issue into their corrective action system, implemented short-term corrective actions, and completed an operability assessment for the affected equipment.

This finding is more than minor because it is associated with the external factors attribute (loss of heat sink) for the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences.

The team determined the finding was of very low safety significance (Green)because it did not result in the loss of system safety function. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution,

Corrective Action Program Component, because Entergy did not adequately evaluate a condition adverse to quality, including properly classifying, prioritizing, and evaluating for operability (IMC 0305, Aspect P.1(c)). (1R21.2.1.2)

Green.

The team identified a finding of very low safety significance involving a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, in that, Entergy did not perform a calculation to demonstrate that the switchyard voltage used in procedures was adequate. Such a calculation was necessary to ensure that a spurious loss of the preferred offsite power source during transient conditions would not occur. Entergy entered this issue into their corrective action system, and demonstrated there was sufficient margin to assure operability of the preferred offsite power source.

This finding is more than minor because the deficiency represented reasonable doubt on the operability of the preferred offsite power system. The finding is associated with the design control attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance (Green) because it was a design deficiency confirmed not to result in a loss of the preferred offsite power source. (1R21.2.1.9)

Green.

The team identified a finding of very low safety significance involving a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, in that, Entergy did not properly translate design basis parameters into specifications and procedures for the salt service water (SSW) system.

Specifically, the system hydraulic analysis did not establish a system leakage limit, and the plant operating procedures allowed alignments that could have led to a condition where system leakage could have been in excess of the available margin. Entergy entered this issue into their corrective action system and instituted immediate corrective actions.

iii

This finding is more than minor because the deficiency represented reasonable doubt on the operability of the SSW system. The finding is associated with the design control attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

The team determined the finding was of very low safety significance (Green)because it was a design deficiency confirmed not to result in a loss of the SSW system. (1R21.2.1.11)

B. Licensee-Identified Violation None iv

REPORT DETAILS

1R21 Component Design Bases Inspection (IP 71111.21)

.1 Inspection Sample Selection Process

The team selected risk significant components and operator actions for review using information contained in the Pilgrim Nuclear Power Station (PNPS) Probabilistic Risk Assessment (PRA) and the U. S. Nuclear Regulatory Commissions (NRC) Standardized Plant Analysis Risk (SPAR) model. Additionally, the PNPS Significance Determination Process (SDP) Phase 2 Notebook, Revision 2, was referenced in the selection of potential components and operator actions for review. In general, the selection process focused on components and operator actions that had a Risk Achievement Worth (RAW)factor greater than 1.3 or a Risk Reduction Worth (RRW) factor greater than 1.005. The components selected were located within both safety related and non-safety related systems, and included a variety of components such as pumps, breakers, heat exchangers, generators, transformers, and valves.

The team initially compiled a list of components and operator actions based on the risk factors previously mentioned. Additionally, the team reviewed the previous component design bases inspection report (05000293/2006006) and excluded those components previously inspected. The team then performed a margin assessment to narrow the focus of the inspection to 18 components, three operator actions and three operating experience items. The teams evaluation of possible low design margin included consideration of original design issues, margin reductions due to modifications, or margin reductions identified as a result of material condition/equipment reliability issues.

The assessment also included items such as failed performance test results, corrective action history, repeated maintenance, maintenance rule (a)(1) status, operability reviews for degraded conditions, NRC resident inspector insights, system health reports, and industry operating experience. Finally, consideration was also given to the uniqueness and complexity of the design and the available defense-in-depth margins. The margin review of operator actions included complexity of the action, time to complete the action, and extent of training on the action.

The inspection performed by the team was conducted as outlined in NRC Inspection Procedure (IP) 71111.21. This inspection effort included walkdowns of selected components, interviews with operators, system engineers and design engineers, and reviews of associated design documents and calculations to assess the adequacy of the components to meet design basis, licensing basis, and risk-informed beyond design basis requirements. Summaries of the reviews performed for each component, operator action, operating experience sample, and the specific inspection findings identified are discussed in the subsequent sections of this report. Documents reviewed for this inspection are listed in the Attachment.

.2.1.1 B 125 Volt DC Battery

a. Inspection Scope

The team reviewed the design, testing and operation of the B 125 Vdc station battery to verify that it could perform its design function of providing a reliable source of DC power to connected loads under operating, transient and accident conditions. The team reviewed design calculations to assess the adequacy of the battery sizing to ensure the battery could power the required equipment for a sufficient duration, and at a voltage above the minimum required for the equipment operation. The team reviewed the last performance of battery tests, including the battery discharge tests, to ensure the testing was sufficient and was in accordance with plant technical specifications; and that the results confirmed acceptable performance of the battery. The team interviewed design and system engineers regarding the design, operation, testing and maintenance of the battery. The team performed a walkdown of the A and B batteries, the battery chargers and associated distribution panels to assess the material condition of the battery cells and associated electrical equipment. Finally, a sample of condition reports (CR) were reviewed to ensure Entergy was identifying and properly correcting issues associated with the batteries and associated DC system components.

b. Findings

Introduction:

The team identified a finding of very low safety significance (Green)involving a non-cited violation of 10 CFR 50, Appendix B, Criteria XVI, Corrective Action, in that Entergy did not properly evaluate and take adequate corrective actions for a condition adverse to quality. Specifically, elevated temperatures were identified on the B 125 Vdc battery charger supply circuit breaker terminals during the performance of infrared thermographic surveys (thermography); however, adequate corrective actions were not taken, and the breaker subsequently failed while recharging the B 125 Vdc battery.

Description:

On January 4, 2006, Entergy identified an elevated temperature on a load side electrical connection of the B battery charger 480 Vac supply circuit breaker (BRK 1413). The temperature on the connection was approximately 27 °F higher than the measured reference temperature and CR 2006-0038 was initiated to address the issue.

That CR was subsequently closed after the issue was included in CR 2006-0037, which had been written to document an elevated temperature on a different breaker within the same motor control center. The corrective action in CR 2006-0037 that was opened to address BRK 1413 was closed after a corrective work order was initiated, which in turn, was closed to a planned preventive maintenance (PM) task.

The PM work on BRK 1413 was performed in August 2006, with no deficiencies identified. There was no followup thermography performed following the PM, and during routine thermography surveys in January 2007, the original area of overheating was not evident. However, at that time, a line side connection on BRK 1413 was found to be approximately 19 °F above the reference temperature. The team found that because procedure 3.M.3-60, Infrared Thermography, specifies that for temperatures rises between 10 °F and 25 °F the initiation of a CR should be considered, no CR was initiated and no corrective actions were taken for the 19 °F temperature rise. On April 27, 2007, BRK 1413 tripped on over-current while recharging of the B battery following performance of the battery discharge test.

The team noted that the temperatures recorded during these events were obtained when the AC current through the breaker was approximately 10 amps because the charger was only supplying a small amount of current to maintain the battery fully charged.

During accident loading or following a significant discharge of the battery the current could be significantly higher (approximately 60 amps at full load). Condition Report 2006-0038 did not include an assessment of the potential effects of the heating on the circuit breaker operability. In particular, Entergy failed to consider the effects of the low current levels on the thermography results and assess the potential temperatures that could be present at design battery charger loading.

Entergy entered the issue into the corrective action program (CR 2008-01729) and took actions to obtain thermography data on the backup battery charger to confirm there were no indications of overheating of the connections. In order to assess the extent of condition, the team reviewed the thermography results for the A 125 Vdc battery charger to verify it did not have evidence of a similar degraded condition; none were identified.

Analysis:

The team determined that the failure to properly evaluate and correct the hot spots on the circuit breaker in a timely manner was a performance deficiency that was reasonably within Entergys ability to foresee and correct. The finding was more than minor because it was similar to NRC Manual Chapter 0612, Appendix E, Examples of Minor Issues, Example 3.j, in that, when assessing the impact of the elevated temperatures at higher current levels, there was a reasonable doubt on the operability of the battery charger. The finding was associated with the equipment performance attribute of the Mitigating Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In response, Entergy performed additional assessment on the impact of operability (during the period prior to replacing the circuit breaker in April, 2007) and concluded that the actual battery loading profile, and the resultant loading on the battery charger, would not have resulted the circuit breaker tripping during transient or accident conditions. Traditional enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRCs regulatory function, and was not the result of any willful violation of NRC requirements. In accordance with NRC Inspection Manual Chapter 0609, 4, "Phase 1 - Initial Screening and Characterization of Findings," a Phase 1 SDP screening was performed and determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.

The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program Component, because Entergy did not adequately evaluate this condition adverse to quality, including classifying, prioritizing, and evaluating for operability when it was identified in January 2006, and again, in January 2007. (IMC 0305, Aspect P.1(c))

Enforcement:

10 CFR 50, Appendix B, Criteria XVI, Corrective Action, requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, between January 2006 and April 2007, the B 125 Vdc battery charger supply circuit breaker was found to have hot spots that were not adequately evaluated and corrected. Because this violation is of very low safety significance and has been entered into Entergys corrective action program, this violation is being treated as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000293/2008007-01, Inadequate Corrective Actions for B Battery Charger Circuit Breaker)

.2.1.2 Traveling Water Screens (X-108 A/B/C/D)

a. Inspection Scope

The safety-related salt service water (SSW) system is designed to function as the ultimate heat sink for all the systems cooled by the reactor building closed cooling water (RBCCW) and turbine building closed cooling water (TBCCW) systems. The five SSW pumps (two pumps per loop with a swing pump) and two non safety-related seawater pumps (circulating water cooling to the main condensers) take a suction on Cape Cod Bay through four parallel flow traveling water screens (TWS). The A and B TWS supply water to the west seawater bay, and the C and D TWS supply the east seawater bay. Downstream of the TWS, the west seawater bay provides water to the A, B and C SSW pump bay via a sluice gate opening. Similarly, the east seawater bay supplies water to the D and E SSW pump bay. A rear sluice gate connecting the two SSW bays is normally closed, and is only opened to facilitate closure of the east or west sluice gate to support condenser backwash or diving operations. The TWS and associated spray wash system are non-safety related.

The team reviewed the TWS design bases, operating limits, engineering analyses, modifications, and maintenance history to verify that the TWS would support the SSW system to function as designed during accident and transient conditions. The review included vendor specifications, Pilgrim and industry operating experience, operating and alarm response procedures, control room and in-field instrumentation, sluice gate design and operation, SSW surveillance results, CRs, and system health reports. In addition, the team performed several detailed walkdowns of the intake structure to directly observe system operations in various configurations (with and without TWS operating, swing pump in service, during storms preps, during diving operations, and single sluice gate operation). The team walked down the intake systems with the system engineer and interviewed operators and design engineers concerning TWS and SSW system performance.

b. Findings

Introduction:

The team identified a finding of very low significance (Green) involving a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, in that Entergy did not properly evaluate and take adequate corrective actions for a condition adverse to quality. Specifically, following an intake de-watering event on September 14, 2007, Entergys issue prioritization, operability review, and subsequent evaluation did not adequately assess and correct the plant response relative to the safety-related SSW design and licensing bases.

Description:

At approximately 6:30 AM on September 14, 2007, a large school of fish (approximately 5,000 small Atlantic Juvenile Menhaden) impinged upon the stationary intake TWS (the TWS are normally not in service and have no auto-start feature).

Control room operators received high differential pressure (D/P) alarms on the TWS and dispatched equipment operators to the intake. Due to the high fish loading, the A and B TWS tripped on a manual start attempt (sheer pin failure per design); however, the operators successfully placed the C and D TWS in service. As the D/P across the west bay TWS continued to increase (eventually exceeding the 8 feet TWS design D/P),the west bay intake level continued to lower. Operators promptly entered procedure 2.4.154, Intake Structure Fouling, reduced reactor power to 50 percent, and stopped the west bay seawater pump. Stopping the seawater pump caused the seawater and SSW bay levels to immediately return to the existing tide level (as the seawater pump was no longer drawing down the west bay level at 155,000 gpm). Entergy initiated CR 07-03978 to evaluate the event. On October 17, 2007, Entergy completed the associated apparent cause evaluation (ACE). Entergys ACE noted that the west seawater bay level lowered to approximately -12 feet and the east seawater bay level lowered to approximately -7 feet. Entergys ACE determined that the operators secured the seawater pump based on the low intake level in accordance with procedures and that it was inevitable given the unavoidable presence of thousands of small fish at the intake. The ACE stated that there were no barriers that failed, no feasible methods of prevention, and no outstanding questions or concerns resulting from the evaluation.

The Technical Specification (TS) Bases and Updated Final Safety Analysis Report (UFSAR) stated that during normal power operation, it is only necessary that the SSW pumps maintain adequate submergence to operate without vortexing, air ingestion, or cavitation. The SSW pumps can maintain rated performance, based on suction head, net positive suction head (NPSH) required, and submergence down to a water level of 13.75 feet below mean sea level (MSL). Technical Specification 3/4.5.B.4 states that the operability of the ultimate heat sink is based on having a minimum water level in the pump well on the intake structure of greater than 13 feet 9 inches below MSL. Based on a review of design bases documents and CRs (CR 04-3832, in particular), the team noted that Entergy credited operator action and procedure guidance to trip the seawater pump before exceeding -10 feet MSL to ensure continued SSW and ultimate heat sink operability. To independently verify that the September 14 event did not challenge ultimate heat sink operability or any of the intake system, structure, and component design limits, the team requested complete level instrument data and operating logs for the period before and following the event. In response to the teams request, Entergy reviewed the complete intake level trace for both the seawater and SSW bays and identified that the indicated SSW bay level, in fact, had dropped significantly lower than previously analyzed. On May 6, 2008, Entergy initiated CR 08-01527 to evaluate the following adverse conditions:

(1) the seawater pump low level limit was exceeded by approximately 2 feet,

(2) the TWS D/P limit was exceeded by approximately 1 foot, (3)the SSW bay level decreased well below the minimum submergence water level of -

13.75 feet (the indicator went off scale low at -15.5), and

(4) the seawater and SSW bays levels diverged (water flow rate out of the SSW bay was much greater than flow rate in from the seawater bay via the sluice gate opening).

The team noted that these conditions called into question the operability of the A and B SSW pumps (operating during the level excursion), the functionality of the A and B TWS, the adequacy of the operator actions and procedure guidance to ensure trip of the seawater pump before -10 MSL, and the hydrodynamic affects associated with the unexpected SSW/seawater bay level divergence (appeared to start to diverge at approximately -8.5 vice the expected -13.4 level at the sluice gate location).

On May 21, 2008, Entergy completed an operability determination for the affected equipment. Engineering determined that the SSW pumps remained fully operable based on the limited duration of the low water event (less than two minutes below -13.75 MSL),the robust single-stage vertical pump design, and satisfactory quarterly pump in-service test results since September 2007. Based on a review of the TWS maintenance history, engineering determined that the A and B TWS had four and five screen baskets with damaged screen reinforcement bars, respectively. The damaged TWS were subsequently repaired in December 2007. Engineering determined that additional actions should be proceduralized to protect the SSW pumps from operating below -

13.75 MSL (CR 08-01527). On May 22, the Operations Manager issued interim guidance to operators via a Night Order to protect the SSW pumps. In addition, Entergys short-term corrective actions included initiation of a Category A root cause evaluation (CR 08-01527). The team reviewed the above actions and determined that they were acceptable based on independent review of the available data and in-field walkdowns.

Analysis:

The team determined that Entergys failure to properly evaluate and take timely and appropriate corrective action to address the plants response to an intake de-watering event on September 14, 2007, was a performance deficiency that was reasonably within Entergys ability to foresee and correct prior to May 2008. In addition to Entergys evaluation under CR 07-03978, Entergy initiated CR 07-04268 on October 18, 2007, to evaluate the effectiveness of actions previously taken and any lessons learned. The team noted that Entergys response to both of these CRs represented missed opportunities to identify the conditions adverse to quality in the Fall of 2007.

The finding was more than minor because it was associated with the External Factors attribute (loss of heat sink) for the Mitigating System cornerstone and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, a fish intrusion event resulted in a significant lowering of intake level and challenged the continued availability of the A loop of SSW. Traditional enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRC's regulatory function, and was not the result of any willful violation of NRC requirements. In accordance with NRC IMC 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," a Phase 1 SDP screening was performed and determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.

The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program Component, because Entergy did not adequately evaluate a condition adverse to quality, including classifying, prioritizing, and evaluating for operability. (IMC 0305, Aspect P.1(c))

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, from September 14, 2007, to May 6, 2008, Entergy failed to properly evaluate and take adequate corrective action for a condition adverse to quality involving an intake de-watering event. Specifically, Entergy did not thoroughly evaluate the adverse impact on the TWS, the unexpected SSW and seawater bay level divergence, and any potential consequence to the SSW pump operability. Because this violation is of very low safety significance and has been entered into Entergys corrective action program (CR-08-01527), it is being treated as a non-cited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000293/2008007-02, Inadequate Corrective Actions in Response to an Intake De-Watering Event)

.2.1.3 Reactor Core Isolation Cooling Lube Oil Cooler (E-204)

a. Inspection Scope

The team inspected the reactor core isolation cooling (RCIC) lube oil cooler to ensure that RCIC could meet its design basis requirements. The inspection included a review of turbine and governor cooling, including associated instrumentation and alarms, to determine if the manufacturer range for the lube oil pressures was maintained during all operating conditions. The team performed a walkdown of the turbine and associated support features; interviewed system and design engineers; and reviewed RCIC system health reports, operating and alarm response procedures, and CRs to assess Entergys configuration control and the material condition of the RCIC components. The team also reviewed the technical specifications, design and licensing bases documents, and design basis calculations to determine the required flows, pressures, and operating conditions for various system configurations. Finally, the team reviewed applicable technical evaluations, lube oil analyses, corrective action documents, modifications, and inservice test (IST) data to ensure that Entergy maintained and operated the system within the design and licensing bases.

b. Findings

No findings of significance were identified.

.2.1.4 RBCCW to RHR Heat Exchanger Inlet Valve, 4060B

a. Inspection Scope

The team inspected the reactor building closed loop cooling water (RBCCW) to the reactor heat removal (RHR) heat exchanger inlet valve, 4060B, to verify that it was capable of meeting its design basis requirements. This alternating current (AC) motor-operated valve supplies cooling water to the RHR heat exchanger and has a function to remote manually open to provide cooling water to the RHR system during transient events. The team reviewed system calculations and motor-operated valve calculations to verify appropriate thrust and torque limits, and actuator settings. Inservice testing results were reviewed to verify that the stroke time acceptance criteria were in accordance with the UFSAR and accident analysis assumptions; and that the valve could perform its design basis function under transient conditions. The team reviewed AC load flow and valve voltage calculations to determine whether adequate motive power was available during worst case degraded voltage and service conditions; and reviewed motor control center voltage drop calculations to determine whether motor-operated valve contactors had adequate voltage to pick up when required. The team reviewed elementary wiring diagrams to determine whether control logic was in conformance with the design bases. The team also interviewed engineers and reviewed correspondence related to NRC Generic Letter 95-07, Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves, to ensure the valve would not be susceptible to the pressure locking or thermal binding phenomena.

Walkdowns of accessible areas were performed to assess the material condition of the valve. Finally, the team reviewed condition reports and system health reports to determine the overall health of the system.

b. Findings

No findings of significance were identified.

.2.1.5 RCIC Turbine-Driven Pump, P-206

a. Inspection Scope

The team inspected the RCIC turbine-driven pump, P-206, to verify it was capable of meeting its design basis requirement of automatically providing high pressure cooling water to the reactor vessel under transient conditions, including station blackout events.

This review included various RCIC system calculations, instrument setpoint calculations, summaries of inservice testing results, and condition reports related to the pump and turbine. The team verified the capability of the RCIC pump to provide its design flowrate to the reactor vessel. In addition, the team verified the basis for the pump inservice testing acceptance criteria, the basis of various setpoints associated with the pump and turbine, and the availability of adequate net positive suction head (NPSH) during RCIC pump operation. Walkdowns of accessible areas were performed to assess the material condition of the pump. Finally, the team reviewed condition reports and system health reports to determine the overall health of the system, and to determine if issues entered into the corrective action program were appropriately addressed.

b. Findings

No findings of significance were identified.

.2.1.6 RCIC Injection Valve, MOV-49

a. Inspection Scope

The team inspected RCIC injection valve, MOV-49, to verify that it was capable of meeting its design basis requirements. This direct current (DC) motor-operated valve (MOV) has a function to automatically open to provide RCIC injection during postulated accident events. The review included system and motor operated valve calculations to verify that thrust and torque limits and actuator settings were correct. The team also interviewed engineers and reviewed correspondence related to NRC Generic Letter 95-07, Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves, to ensure the valve would not be susceptible to the pressure locking or thermal binding phenomena. Inservice testing results were reviewed to verify that the stroke time acceptance criteria were in accordance with the UFSAR and accident analysis assumptions. Additionally, condition reports related to the valve were reviewed to ensure conditions did not exist which would invalidate design assumptions for the capability of the valve. The team verified the system operating conditions and terminal voltage values used in the valve analyses were bounding. Walkdowns of accessible areas were performed to assess the current condition of the valve. Finally, the team reviewed corrective action program documents and system health reports to determine the overall health of the system, and to determine if issues entered into the corrective action program were appropriately addressed.

b. Findings

No findings of significance were identified.

.2.1.7 RCIC Flow Controller, 1340-1

a. Inspection Scope

The team inspected the RCIC system flow controller, 1340-1, to verify that it was capable of meeting its design basis requirements. This controller regulates the RCIC control valve position in order to automatically maintain a constant pump discharge flowrate over the pressure range of the RCIC system operation. The review included system calculations and calibration settings to verify proper system response during design basis events. The team also reviewed the control logic associated with this controller to verify it would perform its design basis functions. Walkdowns of accessible areas were performed to assess the current condition of the flow controller. Finally, the team reviewed condition reports and system health reports to determine the overall health of the system, and to determine if issues entered into the corrective action program were appropriately addressed.

b. Findings

No findings of significance were identified.

.2.1.8 Shutdown Transformer X-13

a. Inspection Scope

The team reviewed AC load flow calculations to determine whether the shutdown transformer had sufficient capacity to support its required loads under worst case accident loading and grid voltage conditions. The team reviewed operating procedures to determine whether adequate controls were in place to ensure transformer operability.

The team reviewed transformer loading tests to determine whether it was capable of starting loads required in an emergency. Transformer protective relaying was reviewed to determine whether there was adequate protection and whether there were any adverse interactions that could reduce system reliability. The team reviewed maintenance procedures to determine whether tasks and acceptance criteria were consistent with vendor recommendations. A visual inspection of the transformer and its associated switchgear was completed by the team in order to assess material condition.

Finally, the team reviewed maintenance records and corrective action documents to determine whether there was an adverse equipment operating trend.

b. Findings

No findings of significance were identified.

.2.1.9 Motor for Salt Service Water (SSW) Pump P206A

a. Inspection Scope

The team reviewed AC load flow and voltage calculations to determine whether offsite power was available and of sufficient quality to provide motive power to the pump during worst case degraded voltage and service conditions. The team reviewed protective relaying drawings and setpoints to determine whether the motor was protected and immune from spurious tripping during runout conditions. The team reviewed equivalency evaluations for the SSW pump motors to determine whether the replacement motors preserved the original design bases. The team reviewed ampacity calculations to determine whether motor feeder cables were applied within their ratings, and reviewed elementary wiring and logic diagrams to determine whether motor control logic was in conformance with the design bases. Finally, the team reviewed maintenance and corrective action documents to determine whether the equipment has exhibited adverse performance trends.

b. Findings

Introduction:

The team identified a finding of very low significance (Green) involving a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, in that, Entergy did not perform a calculation to demonstrate that the switchyard minimum operating voltage criteria used in plant procedures was adequate.

Description:

UFSAR Section 8.2.2.2 defines the Safety Design Basis of the Preferred Power Supply as follows: The preferred AC power source is capable of supplying all emergency loads of the auxiliary power distribution system necessary for the safe shutdown of the reactor, as a result of anticipated operational occurrences or postulated accidents. The team noted an analysis of switchyard voltage criteria is necessary to ensure the minimum electrical system operating voltage is adequate to prevent the inadvertent loss of the preferred source following a plant trip, including a plant trip that occurs during an accident.

The team noted this type of analysis is typically accomplished by comparing post-accident 4 kV safety bus voltages with the degraded voltage relay reset value to ensure bus voltages recover sufficiently to prevent inadvertent separation of the safety buses from an operable offsite power source. To ensure the post-accident voltages at the 4 kV buses will be adequate, the analysis must establish the minimum normal operating voltage that must be supplied by the preferred AC power source.

The team found that the Pilgrim electrical system normal operating voltage was administratively controlled above a minimum of 342 kV. The team also noted that the existing load flow calculation provided sufficient data to determine the corresponding 4kV post-accident voltage by interpolation. However, this interpolation was not performed in the load flow calculation and consequently, it was not compared to the degraded voltage relay reset value determined in the set point accuracy calculation. A rough calculation performed by the team showed that the minimum normal operating voltage criteria for PNPS (342 kV) provided very little margin relative to the calculated relay reset value. In addition, the adequacy of margin was questionable since the field test specified in NRC Generic Letter 79-36 to validate the results of the load flow study had not been performed.

In response to the teams concern, Entergy reviewed recent surveillance records for the degraded voltage relays and determined that the actual as-left reset value was below the maximum allowed by procedures, thus providing approximately 0.25% margin. The team concluded that this margin, in addition to the generally conservative methodology used to calculate the reset set point, afforded reasonable assurance of operability of the offsite (preferred) power supply. This item has been entered into the licensees corrective action program as CR-PNP-2008-01669.

Analysis:

The team determined that failure to evaluate the adequacy of the criteria for offsite power operability was a performance deficiency that was reasonably within Entergys ability to foresee and prevent. Specifically, Entergy did not perform a calculation to determine the adequacy of switchyard minimum voltage criteria to ensure the operability of the preferred startup power source. Consequently, there was the potential that inadequate voltage criteria could result in the inadvertent loss of the preferred offsite power supply during a design basis event.

The finding was more than minor because it was similar to NRC Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, Example 3j, in that the lack of a formal calculation or a validating test resulted in a condition where there was a reasonable doubt on the operability of the offsite power supply. The finding was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Analysis of switchyard voltage criteria is necessary to prevent the inadvertent loss of the preferred source following a plant trip, including a plant trip that occurs during an accident.

Traditional enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRC's regulatory function, and was not the result of any willful violation of NRC requirements. In accordance with NRC IMC 0609, 4, "Phase 1 - Initial Screening and Characterization of Findings," a Phase 1 SDP screening was performed and determined the finding was of very low safety significance (Green) because it was a design deficiency confirmed not to result in a loss of preferred power operability.

Enforcement:

10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, as of April 26, 2008, Entergy did not ensure that the design basis, as defined in UFSAR Section 8.2.2.2, was correctly translated into procedures. Specifically, Entergy had not performed a calculation to demonstrate that the switchyard minimum operating voltage criteria used in plant procedures was adequate. Because this violation is of very low safety significance and has been entered into Entergys corrective action program (CR-PNP-2008-01669), it is being treated as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000293/2008007-03, Inadequate Design Control for Switchyard Voltage Criteria)

.2.1.1 0 Reactor Building Closed Cooling Water (RBCCW) Heat Exchanger Outlet Isolation

Valves SSW-MOV-OC-V3800/V3806

a. Inspection Scope

The team inspected the RBCCW heat exchanger outlet motor-operated isolation valves SSW-MOV-OC-V3800/V3806 to verify they would operate during design basis events.

The inspection included interviews with system and design engineers, and reviews of drawings and calculations to determine the assumptions used in the analyses to confirm valve operation. The team verified that the valve analyses used the maximum differential pressure expected across the valves during worst case operating conditions.

The team reviewed AC load flow and valve voltage calculations to determine whether adequate motive power was available during worst case degraded voltage and service conditions. The team reviewed motor control center voltage drop calculations to determine whether the motor-operated valve contactors had adequate voltage to pick up when required. The team reviewed periodic verification test results and valve stroke time testing to verify that these motor-operated valves were capable of performing their safety function and that torque switch settings were correct and in accordance with NRC Generic Letter 89-10 guidance. Additionally, the team reviewed performance tests to verify that changes in valve performance due to degradation were properly identified and that test frequency was appropriate. Finally, the team reviewed condition reports and system health reports to determine the overall health of the system, and to determine if issues entered into the corrective action program were properly addressed.

b. Findings

No findings of significance were identified.

.2.1.1 1 Salt Service Water (SSW) Pumps P-208A/B/C/D/E

a. Inspection Scope

The team reviewed design basis documents, including hydraulic calculations, technical specifications, accident analyses and drawings to verify that the SSW pumps were capable of meeting system functional and design basis requirements. The heat transfer calculations for the associated RBCCW heat exchangers E-209A/B were reviewed to verify that the design flow rate used in hydraulic calculations was sufficient to remove the design heat load. The team also reviewed SSW pump surveillance test results, system health reports, and corrective action documents to determine whether SSW pump design margins were adequately maintained; and to verify that Entergy entered problems that could affect system performance into their corrective action program.

Additionally, the team evaluated technical evaluations, pump curves, and inservice test data. The review assessed whether technical specification and design basis requirements could be achieved; NPSH, vortex limits, and minimum flow requirements were met; and inservice acceptance criteria were appropriate. The team reviewed operating and emergency procedures to assess whether the minimum bay level was sufficient to prevent the onset of vortexing. To assess the general condition of the pumps, the team performed walkdowns of the SSW pump area. The team also reviewed SSW pump and motor cooling systems to assess the ability of the SSW pumps to operate under design basis conditions. Finally, the team reviewed condition reports and system health reports to determine the overall health of the system.

b. Findings

Introduction:

The team identified a finding of very low safety significance (Green)involving a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," in that Entergy did not properly translate design basis parameters into specifications and procedures for the SSW system. Specifically, the system hydraulic analysis did not establish a system leakage limit, and the plant operating procedures allowed alignments that could have led to a condition where system leakage could have been in excess of the available margin.

Description:

The team reviewed SSW hydraulic calculation M-630, SSW System Hydraulic Analysis, and identified that although the system had an inherent margin of approximately 365 gpm (flow through the turbine building cooling water heat exchanger that operators could isolate based on monitoring of the RBCCW temperature limits), this system had several additional potential leakage paths. As discussed below, the estimated flowrates through some of these paths could have exceeded the available margin; furthermore, these paths were not being verified for leak tightness.

• Use of SSW system as a backup to city water system for seawater pumps lubrication. Review of procedure 2.2.94, Seawater System indicated that section 7.7.5, Swapping Seawater Pump Lube Water Supply, calls for both Loop A (29-HO-3882) and Loop B (29-HO-3884) to be open when the SSW is used as a source of seawater pump lubrication. Valves 29-HO-3882/3884 are normally closed 2-inch butterfly valves and provide a class boundary between the safety related and non-safety related portions of the SSW system. Following a postulated design basis event, the non-safety related piping downstream of these valves cannot be credited.

Entergys estimate of these flows indicated that a flow through each of these valves is comparable to the value of the available system margin (365 gpm). Entergy initiated CR-PNP-2008-01619 to add administrative controls in procedure 2.2.94 when these valves are open.

• Leakage through the screen wash isolation valves AO-3915 and AO-3925. The potential for this leakage was discussed in Step 3 of Sections 8.1 and 8.2 of procedure 8.5.3.2.1, Salt Service Water Pump Quarterly and Biennial (Comprehensive) Operability and Valve Operability Tests. It directed the closure of a manual isolation valve if boundary leakage past AO-3915/AO-3925 appeared excessive. Entergy initiated CR-PNP-2008-01641 to address this item (e.g., to provide guidance if closure of these valves is required during the test).

Analysis:

The team determined that the failure to establish the appropriate maximum allowable SSW leakage limit and translate this limit in operating procedures was a performance deficiency that was reasonably within Energys ability to foresee and correct. Entergy's design control measures were not adequate to ensure that a minimum required SSW pump flow was assured, in that, 1) the SSW pump hydraulic analysis did not include explicit leakage limit allowance; and 2) the SSW operating procedures did not preclude alignments where a leakage in excess of available margin could have taken place.

The finding was more than minor because it was similar to NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, Example 3.j, in that the deficient hydraulic analysis resulted in a condition where there was a reasonable doubt with respect to operability of the SSW system. The finding was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Traditional enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRC's regulatory function, and was not the result of any willful violation of NRC requirements. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," a Phase 1 SDP screening was performed and determined the finding was of very low safety significance (Green) because it was a design deficiency that was confirmed not to result in a loss of SSW pump operability.

Enforcement:

10 CFR 50, Appendix B, Criterion III, "Design Control," requires, in part, that design basis parameters be translated into specifications and procedures. Contrary to the above, as of May 15, 2008, Entergy did not properly translate design basis parameters into specifications and procedures for the SSW system. Specifically, the SSW hydraulic analysis (calculation M-630, Rev. 3) did not include a leakage margin allowance across the SSW system pressure boundary and the system operating procedures 2.2.94 and 8.5.3.2.1 allowed alignments that could have led to an unacceptable SSW system leakage. As a result, the hydraulic analysis was non-conservative. Because this violation was of very low safety significance and was entered into Entergy's corrective action program (CR-PNP-2008-01619 and CR-PNP-2008-01641), this violation is being treated as a non-cited violation (NCV),consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000293/2008007-04, Non-Conservative Calculation for SSW Pump Minimum Flow Rate)

.2.1.1 2 High Pressure Coolant Injection System (HPCI) Turbine, 23-X-203

a. Inspection Scope

The team inspected the HPCI turbine lubrication system to verify that the turbine would meet the design basis requirements. The inspection included a review of turbine and governor cooling, including associated instrumentation, and control and annunciator logic to determine if the manufacturer and industry recommended range for the lube oil pressures were maintained during all operating conditions. The team performed a walkdown of the turbine, pump and associated support features; interviewed system and design engineers; and reviewed HPCI system health reports and conditions reports to assess the material condition of the component. The team also reviewed design and licensing bases documents to determine the required flows, pressures, and operating conditions for various system configurations. Additionally, the team evaluated calculations, technical evaluations, and inservice test data to assess whether design basis requirements could be achieved. Finally, the team reviewed condition reports and system health reports to determine the overall health of the system, and determine if issues entered into the corrective action program were appropriately addressed.

b. Findings

No findings of significance were identified.

.2.1.1 3 Motor for Reactor Building Closed Cooling Water Pump P202F

a. Inspection Scope

The team reviewed AC load flow and voltage calculations to determine whether adequate motive power was available during worst case degraded voltage and service conditions. The team reviewed protective relaying drawings and setpoints to determine whether the motor was protected and immune from spurious tripping during runout. The team reviewed modification documents for the RBCCW motors to determine whether the replacement motors preserved the original design bases. The team reviewed ampacity calculations to determine whether motor feeder cables were applied within their ratings.

Elementary wiring and logic diagrams were also reviewed to determine whether motor control logic was in conformance with the design bases. Finally, the team reviewed maintenance and corrective action documents to determine whether the equipment has exhibited adverse performance trends.

b. Findings

No findings of significance were identified.

.2.1.1 4 250 Volt DC Bus D-10

a. Inspection Scope

The team reviewed design calculations for DC bus D-10 to verify its capability to perform its design function to provide power from the 250 Vdc station battery to the various loads supplied from the bus. The review included equipment interrupting capabilities and voltage drop calculations as well as associated design drawings. The team performed a walkdown of the bus and other portions of the 250 Vdc systems, including the battery and associated battery charger, to assess the material condition of the equipment. The team also reviewed CRs for the system to verify problems were being identified and properly corrected. Finally, the team reviewed the associated system operating procedure to ensure the system was operated in accordance with its design.

b. Findings

No findings of significance were identified.

.2.1.1 5 RBCCW Pumps P-202A/B/C/D/E/F and Surge Tanks T-201A/B (2 samples)

a. Inspection Scope

The team reviewed design basis documents, including hydraulic calculations, technical specifications, accident analyses and drawings to verify that the RBCCW pumps and the surge tank were capable of meeting system functional and design basis requirements.

The team reviewed RBCCW pump surveillance test results, system health reports, and corrective action documents to determine whether RBCCW pump design margins were adequately maintained, and to verify that Entergy entered problems that could affect system performance into their corrective action program. A similar review was done for the surge tanks. The surge tank design was reviewed to assure that its level and elevation was sufficient to assure a safe operation of the RBCCW pumps and to prevent onset of vortexing. Additionally, the team evaluated calculations, technical evaluations, pump curves, and inservice test data to assess whether design and licensing bases were maintained. The team reviewed operating and emergency operating procedures to assess whether the temperature limits could be maintained. To assess the general condition of the pumps and the surge tank, the team performed walkdowns of the RBCCW pump and tank areas. The team also reviewed RBCCW pump and motor cooling systems to assess the ability of the RBCCW pump to operate under design basis conditions. Finally, the team reviewed corrective action program documents and system health reports to determine the overall health of the system.

b. Findings

No findings of significance were identified.

.2.1.1 6 Reactor Core Isolation Cooling Steam Line Isolation Instrumentation

a. Inspection Scope

The team reviewed the design, calibration and testing of instrumentation that close the RCIC turbine steam supply line isolation valve in the event of a break of the piping or when reactor pressure decreases to the point where RCIC cannot be operated. The specific instruments reviewed were differential pressure indicating switches DPIS 1360-1A & B (actuate on a high steam line flow indication), temperature switches TS 1360-15A & B and 17A & B (actuate on high room temperatures), and pressure switches PS 1360-9A, B, C & D (actuate on low steam line pressure). The team reviewed the instrumentation setpoints to verify the system isolation would occur as necessary to accomplish the safety function and to ensure the setpoints provided sufficient operating margin to prevent spurious isolation (i.e., as a result of transients during RCIC starts or high ambient temperatures in the associated reactor building rooms). The team performed a walkdown of accessible instrumentation to assess the material condition of the components and reviewed a sample of recent condition reports to verify the licensee was appropriately identifying and correcting instrumentation problems.

b. Findings

No findings of significance were identified.

.2.1.1 7 Containment Electrical Penetration X-105A

a. Inspection Scope

The team reviewed the design, qualification, testing and maintenance for the 480 Vac power electrical penetration X-105A to verify it could perform its design function to provide electrical power to equipment inside the primary containment while maintaining the containment pressure boundary under all accident conditions. Specific reviews included the vendor qualification and testing reports, plant drawings and the results of pressure tests performed on the penetration. The team also reviewed the adequacy of over-current protection for the electrical circuits utilizing the penetration to ensure an electrical fault on the circuit would not challenge the penetration integrity.

b. Findings

No findings of significance were identified.

.2.2 Detailed Operator Action Reviews (3 samples)

The team assessed manual operator actions and selected a sample of three operator actions for detailed review based upon risk significance, time urgency, and factors affecting the likelihood of human error. The operator actions were selected from a probabilistic risk assessment (PRA) ranking of operator action importance based on risk reduction worth (RAW) and risk achievement worth (RRW) values. The non-PRA considerations in the selection process included the following factors:

$ Margin between the time needed to complete the actions and the time available prior to adverse reactor consequences;

$ Complexity of the actions;

$ Reliability and/or redundancy of components associated with the actions;

$ Extent of actions to be performed outside of the control room;

$ Procedural guidance to the operators; and

$ Amount of relevant operator training conducted.

.2.2.1 Operators Align the Backup 125 Vdc Battery Charger

a. Inspection Scope

The team inspected the operator action to align the backup 125 Vdc battery charger using operating procedure 2.2.14, 125 Vdc Battery Systems. The team reviewed Entergys PRA and Human Reliability Analysis (HRA) studies to determine when and how quickly operators should align the backup charger for PRA success. The team interviewed licensed operators, reviewed associated operating and alarm response procedures, walked down applicable panels in the main control room and in the plant, and observed an equipment operator simulate the in-field portions of the procedure to evaluate the ability of the operators to perform the required actions. In addition, the team independently assessed Entergys configuration control and the material condition of the associated panels, breakers, battery chargers, and motor control centers.

b. Findings

No findings of significance were identified.

.2.2.2 Operators Provide Makeup to the Condensate Storage Tank from the Demineralized

Water Storage Tank

a. Inspection Scope

The team inspected the operator action to provide makeup to the condensate storage tank (CST) from the demineralized water storage tank (DWST) using operating procedure 2.2.35, Condensate Storage and Transfer System. The team reviewed Entergys PRA and HRA studies to determine when and how quickly operators should provide CST makeup via the DWST for PRA success. The team interviewed licensed operators, reviewed associated operating and alarm response procedures, walked down applicable panels in the main control room and the tanks in the plant, and observed an equipment operator simulate the in-field portions of the procedure to evaluate the ability of the operators to perform the required actions. In addition, the team independently assessed Entergys configuration control and the material condition of the associated tanks, valves, level indicators, and panels.

b. Findings

No findings of significance were identified.

.2.2.3 Operators Transfer Swing Bus D6 from A to B 125 Vdc Battery

a. Inspection Scope

The team inspected the operator action to transfer swing bus D6 from the A to the B 125 Vdc battery when directed by emergency procedure 5.3.31, Station Blackout. The team reviewed Entergys PRA and HRA studies to determine when and how quickly operators should transfer swing bus D6 for PRA success. The team interviewed licensed operators, observed several simulator scenarios, reviewed associated operating and alarm response procedures, walked down applicable panels in the main control room and in the plant, and observed an equipment operator simulate the in-field portions of the procedure to evaluate the ability of the operators to perform the required action. In addition, the team independently assessed Entergys configuration control and the material condition of the associated panels, switches, batteries, and battery chargers.

b. Findings

No findings of significance were identified.

.2.3 Review of Industry Operating Experience and Generic Issues (3 samples)

a. Inspection Scope

The team reviewed selected operating experience issues for applicability at Pilgrim. The team performed a detailed review of the operating experience issues listed below to verify that Entergy had appropriately assessed potential applicability to site equipment and initiated corrective actions when necessary.

.2.3.1 Operating Experience Smart Sample FY 2008-01 - Negative Trend and

Recurring Events Involving Emergency Diesel Generators NRC Operating Experience Smart Sample (OpESS) FY 2008-01 is directly related to NRC Information Notice (IN) 2007-27, Recurring Events Involving Emergency Diesel Generator Operability and NRC IN 2007-36, Emergency Diesel Generator Voltage Regulator Problems. The team reviewed Entergys evaluation of IN 2007-27 and IN 2007-36 and the associated corrective actions. The team reviewed Entergys emergency diesel generator (EDG) system health reports, EDG CRs and work orders, leakage database, and surveillance test results to verify that Entergy appropriately dispositioned EDG concerns. Additionally, the team independently walked down the A and B EDGs on several occasions to inspect for indications of vibration-induced degradation on EDG piping and tubing and for any type of leakage (e.g., air, fuel oil, lube oil, jacket water). The team also directly observed the B EDG monthly surveillance run on May 19, 2008, and performed pre- and post-run walkdowns to ensure Entergy maintained appropriate configuration control and material condition. During the May 19 B EDG run, the team independently inspected all 18 fuel injection pumps for excessive leakage and configuration control while Entergy personnel performed their detailed inspections in response to fuel oil leakage concerns and a 10 CFR Part 21 snubber valve issue (NRC21-44059).

.2.3.2 NRC Information Notice 2005-021, Switchyard Breaker Maintenance

The team reviewed the station response to NRC IN 2005-021 to determine whether adequate provisions were made to assure the availability and reliability of the offsite power supply. The team reviewed Entergys evaluation of fleet, vendor, and industry recommendations for sulfur hexafluoride circuit breaker maintenance. The team reviewed preventive maintenance tasks, procedures, schedules and records to determine whether adequate routine maintenance was performed. The team reviewed corrective maintenance and corrective action documents for switchyard circuit breakers to determine whether planned preventive maintenance measures were appropriate. The team reviewed maintenance procedures to determine whether appropriate vendor maintenance recommendations and criteria had been incorporated; and performed a walkdown of the switchyard, including the relay house, to assess material condition and the presence of hazards.

.2.3.3 NRC Information Notice 2002-06, Design Vulnerability in BWR Reactor Vessel Level

Instrumentation Backfill Modification The team performed a detailed review of Entergys evaluation of NRC IN 2002-06, Design Vulnerability in BWR Reactor Vessel Level Instrumentation Backfill Modification. This IN discussed the potential for leakage past check valves in the reference leg backfill system which resulted draining of the reference leg following a reactor scram at Pilgrim and resultant erroneous reactor vessel level indication. The team verified that Entergy had appropriately assessed the operational experience had taken actions to ensure the same issues would not recur at Pilgrim. The team noted that Entergys response included the installation of a passive vent system to reduce the buildup of and migration of non-condensable gases down the reference legs. The team also verified that plant operating procedures have been revised to maintain isolation of the backfill system during power operation to prevent inadvertent reference leg drain down.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (IP 71152)

The team reviewed a sample of problems that Entergy had previously identified and entered into their corrective action program. The team reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions. In addition, condition reports written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the corrective action system. The specific corrective action documents that were sampled and reviewed by the team are listed in the attachment.

b. Findings

No findings of significance were identified in addition to the corrective action deficiencies identified separately in this inspection report.

4OA6 Meetings, including Exit

The team presented the preliminary inspection results to Mr. Kevin Bronson, and other members of Entergy staff, at an exit meeting on May 22, 2008. Additional in-office inspection activities continued following the preliminary exit meeting through June 16, 2008. The team presented the final inspection results to Mr. T. White and other Entergy staff members during a telephone conference call on June 17, 2008. The team verified that none of the information in this report is proprietary.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Ahern System Engineer

D. Berkland Design Engineer

J. Bonner Design Engineer

S. Das Senior Lead Engineer

P. Doody Mechanical Engineer

N. Eisenmann Design Engineering Supervisor

J. Gaedtke System Engineer

P. Harizi Design Engineer

C. Littleton Lead PSA Engineer

W. Lobo Licensing Engineer

J. Macdonald Assistant Operations Manager

P. Manderino System Engineer

J. Martin Electrical Maintenance Superintendent

F. Mulcahy System Engineer

D. Noyes Operations Manager

R. Pace Mechanical Systems Supervisor

D. Richard Design Engineer

D. Smith System Engineer

T. White Design Engineering Manager

J. Yingling System Engineer

LIST OF ITEMS

Opened and Closed

NCV

05000293/2008007-01 Inadequate Corrective Actions for B Battery Charger Circuit Breaker. (Section 1R21.2.1.1)

NCV

05000293/2008007-02 Inadequate Corrective Actions in Response to an Intake De-watering Event. (Section 1R21.2.1.2)

NCV

05000293/2008007-03 Inadequate Design Control for Switchyard Voltage Criteria (Section 1R21.2.1.9)

NCV

05000293/2008007-04 Non-Conservative Calculation for SSW Pump Minimum Flowrate (Section 1R21.2.1.11)