IR 05000293/2009006
| ML090860037 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/27/2009 |
| From: | Racquel Powell NRC/RGN-I/DRP/PB7 |
| To: | Bronson K Entergy Nuclear Operations |
| powell, rj | |
| References | |
| IR-09-006 | |
| Download: ML090860037 (17) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION rch 27, 2009
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000293/2009006
Dear Mr. Bronson:
On February 26, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Pilgrim Nuclear Power Station (PNPS). The enclosed report documents the inspection results, which were discussed on February 26, 2009, with you and other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commission=s rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
There were no findings of significance identified during this inspection. On the basis of the samples selected for review, the inspectors determined that Entergy was effective in identifying, evaluating and resolving problems. The team determined that Entergys staff identified problems and entered them into the corrective action program at a low threshold. Entergys staff generally prioritized and evaluated issues commensurate with their safety significance and implemented timely, effective corrective actions. The team did, however, identify several examples of minor safety significance involving less than adequate evaluation or documentation of issues within the corrective action program.
In accordance with Title 10 of the Code of Federal Regulations Part 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 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 Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Raymond J. Powell, Chief Technical Support & Assessment Branch Division of Reactor Projects Docket No. 50-293 License No. DPR-35 Enclosure: Inspection Report No. 05000293/2009006 w/ Attachment: Supplemental Information cc w/encl:
Vice President, Operations, Entergy Nuclear Operations Vice President, Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety & Licensing, Entergy Nuclear Operations Senior Vice President and COO, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations R. Walker, Director, Radiation Control Program, Commonwealth of Massachusetts W. Irwin, Chief, CHP, Radiological Health, Vermont Department of Health 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 Electric Power Division, Commonwealth of Massachusetts R. Shadis, New England Coalition Staff D. Katz, Citizens Awareness Network W. Meinert, Nuclear Engineer J. Giarrusso, MEMA, SLO Commonwealth of Massachusetts, Secretary of Public Safety
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SUMMARY OF FINDINGS
IR 05000293/2009-006; 02/09/2008 - 02/26/2009; Pilgrim Nuclear Power Station; Biennial
Baseline Inspection of the Identification and Resolution of Problems.
This team inspection was performed by three NRC regional inspectors and one resident inspector. The NRC=s program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, AReactor Oversight Process,@ Revision 4, December 2006.
Identification and Resolution of Problems The team concluded that Entergy was effective in identifying, evaluating, and resolving problems. Pilgrim personnel identified problems and entered them into the Corrective Action Program (CAP) at a low threshold, and had taken actions to address previous NRC findings.
The team determined that Entergy generally screened issues appropriately for operability and reportability, and prioritized issues commensurate with the safety significance of the problems.
Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. The team determined that corrective actions addressed the identified causes and were typically implemented in a timely manner. However, the team noted several examples of minor safety significance involving less than adequate evaluation or documentation of issues within the corrective action program and one minor issue where corrective actions had not been successful in resolving an issue. These issues were entered into Entergys CAP for resolution during the inspection.
Entergys audits and self-assessments reviewed by the inspectors were sufficiently thorough and probing. The team concluded that Entergy adequately identified, reviewed, and applied relevant industry operating experience. Based on interviews, observations of plant activities, and reviews of the CAP and the Employees Concerns Program (ECP), the team determined that site personnel were willing to raise safety issues and to document them in the CAP.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution (PI&R)
.1 Assessment of the Corrective Action Program (CAP)
a. Inspection Scope
The team reviewed the procedures that describe Entergys CAP at the Pilgrim Nuclear Power Station. Entergy personnel identified problems by initiating condition reports (CRs)for conditions adverse to quality, plant equipment deficiencies, industrial or radiological safety concerns, or other significant issues. Condition reports are subsequently screened for operability, categorized by significance level (A most significant, through D, less significant), and assigned to personnel for evaluation and resolution or trending.
The team evaluated the process for assigning and tracking issues to ensure that issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the team interviewed plant staff and management to determine their understanding of, and involvement with, the CAP.
The team reviewed CRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process (ROP) to determine if site personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution. The team selected items from functional areas that included chemistry, emergency preparedness, engineering, maintenance, operations, physical security, radiation safety, and oversight programs to ensure that Entergy appropriately addressed problems identified in these functional areas. The team selected a risk-informed sample of CRs that had been issued since the last NRC PI&R inspection conducted in June 2007. Risk insights from the stations risk analyses were considered to focus the sample selection and plant walkdowns on risk-significant systems and components. The corrective action review was expanded to five years for evaluation of identified concerns within CRs relative to the residual heat removal (RHR) system and the Standby Liquid Control (SLC) system.
The team selected items from various processes at Pilgrim to verify that they were appropriately considered for entry into the CAP. Specifically, the team reviewed a sample of engineering requests, both open and closed, operator workarounds, operability determinations, system health reports, equipment problem lists, work orders (WOs), and issues entered into the employee concerns program (ECP). In addition, the team reviewed a sample of plant log entries to determine whether problems described in the logs were entered into the CAP.
The team reviewed CRs listed in the Attachment to this report to assess whether Entergy personnel adequately evaluated and prioritized identified issues. The CRs reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and common cause analyses. A sample of CRs that were assigned lower levels of significance which did not include formal cause evaluations were also reviewed by the team to ensure they were appropriately classified. The teams review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The team assessed whether the evaluations identified likely causes for the issues and identified appropriate corrective actions to address the identified causes. As part of this review, the team interviewed various station personnel to fully understand details within the evaluations and proposed and completed corrective actions. The team observed several condition review group (CRG) meetings in which Entergy personnel reviewed new CRs for prioritization and assignment. Further, the team reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected CRs to verify these specific reviews adequately addressed equipment operability, reporting of issues to the NRC, and the extent of problems.
The teams review of CRs also focused on the associated corrective actions in order to determine whether the actions addressed the identified causes of the problems. The team reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The team reviewed Entergys timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. Lastly, the team reviewed CRs associated with selected non-cited violations (NCVs) and findings since the last PI&R inspection in June 2007 to determine whether Entergy personnel properly evaluated and resolved the issues. Specific documents reviewed during the inspection are listed in the to this report.
b. Assessment Identification of Issues Based on the selected samples reviewed, plant walkdowns, and interviews of site personnel, the team determined that Entergy personnel identified problems and entered them into the CAP at a low threshold. For the issues reviewed, the team noted the problems or concerns had been appropriately documented in enough detail to understand the issues. The team observed managers and supervisors at CRG meetings appropriately questioning and challenging CRs to ensure clarification of the issues. The team determined that Entergy trended equipment and programmatic issues and CR descriptions appropriately included reference to repeat occurrences of issues. The team concluded that personnel were identifying trends at low levels. The team did not identify issues or concerns that had not been appropriately entered into the CAP for evaluation and resolution.
Prioritization and Evaluation of Issues The team determined that, in general, Entergy personnel appropriately prioritized and evaluated issues commensurate with the safety significance of the problem. CRs were screened for operability and reportability, categorized by significance, and assigned to a department for evaluation and resolution. The CR screening review process considered human performance issues, radiological safety concerns, repetitiveness, and adverse trends during the conduct of reviews.
Condition report issues were categorized for evaluation and resolution commensurate with the significance of the issues. Based on the sample of CRs reviewed, the guidance provided by the Entergy implementing procedures appeared sufficient to ensure consistency in categorization of the issues. Operability and reportability determinations were performed when conditions warranted and the evaluations generally supported the conclusions. Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. During this inspection, the team noted that Entergys root cause analyses were thorough, and corrective and preventive actions addressed the identified causes. Additionally, the identified causes were well supported.
However, there were several examples of less than adequate evaluation or documentation of evaluations within the CRs reviewed. The team identified several minor issues or concerns, for example:
- Condition Report 2007-04724 documented a problem with a capacitor within the High Pressure Coolant Injection (HPCI) system automatic flow controller. The failure had resulted in the inability to automatically control the flow to its setpoint.
In this case the flowrate during a system run had indicated a nominal 2200 gpm with actual flowrate later determined to be estimated around 5400 gpm. The team determined the past operability review had not adequately evaluated how the excessive flowrate would have impacted net positive suction head requirements, vortexing limitations and operation in the manual control mode given the unreliability of flowrate indication. Additionally, a UFSAR postulated transient had not been considered for the adverse impact on minimum critical power ratio (MCPR) margins for the inadvertent HPCI initiation at power event. The team considered the incomplete evaluation to be a minor performance deficiency because it was determined that there was no impact on the capability of the system to perform its required functions. Notwithstanding, the team determined that the past operability evaluation of the capacitor failure had been less than adequate with respect to implementation of EN-OP-104, which requires evaluations to be sufficient to address the capability of equipment to perform their function. Entergy entered this issue into their CAP as CR-PNP-2009-00496.
- Condition Report 2005-00341 documented a condition where the B loop of RHR had elevated temperatures near the injection valve compared to the A loop. The evaluation within the CR credited non-safety related keepfill pressure when determining the margin available to saturation temperature. This did not appear to be well justified considering the keepfill system pressure was not evaluated with respect to its capability to maintain pressure when postulating an accident where keepfill pressure may be lost prior to RHR pump start. The team considered this to be a performance deficiency of minor significance since margin was still available and there was no impact on system function. Entergy entered the issue into their CAP as CR-PNP-2009-00651.
Effectiveness of Corrective Actions The team concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, corrective actions were identified to prevent recurrence. The team concluded that corrective actions to address the sample of NRC NCVs reviewed since the last PI&R inspection were timely and effective. The team did identify one example where corrective actions were not effective in addressing an issue. The team determined that ineffective corrective actions have been implemented with respect to ensuring reliability of the emergency diesel generator (EDG) ventilation damper position indication. The team noted that the EDG outside air engine cooling dampers and secondary outside damper position switches have resulted in six alarms since the end of 2007 during EDG surveillance runs. The alarm is common to both EDGs and indicates a damper out of position. The team noted that these position indication switches are not safety-related and have not resulted in any loss of EDG availability and therefore the performance deficiency was of minor safety significance. Notwithstanding this, the team was concerned that if a switch failed to indicate correctly during an unplanned EDG start in response to an event, it would create an additional burden for operators responding to the event. Entergy planned to address this concern within their CAP as CR-PNP-2009-00360.
c. Findings
No findings of significance were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The team selected a sample of CRs associated with the review of industry operating experience (OE) issues to confirm that Entergy personnel appropriately evaluated the OE information for applicability to Pilgrim and had taken appropriate actions, when warranted.
The team reviewed CR evaluations of OE documents associated with a sample of NRC generic letters and information notices to ensure that Entergy adequately considered the underlying problems associated with the issues for resolution via their CAP. The team also observed plant activities to determine if industry OE was considered during the performance of routine activities. A list of the documents reviewed is included in the to this report.
b. Assessment The team determined that Entergy appropriately considered industry OE information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The team determined that OE was appropriately applied and lessons learned were communicated and incorporated into plant operations.
The team observed that industry OE was routinely discussed and considered during the performance of plant activities. For example, during shift briefing activities, relevant industry OE was reviewed and discussed before the commencement of shift activities.
Additionally, OE was routinely discussed at CRG review meetings.
c. Findings
No findings of significance were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The team reviewed a sample of Quality Assurance (QA) audits, including a review of several of the findings from the most recent audit of the CAP, and a variety of self-assessments focused on various plant programs. These reviews were performed to determine if problems identified through these assessments were entered into the CAP, when appropriate, and whether corrective actions were initiated to address identified deficiencies. The effectiveness of the audits and assessments was evaluated by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection. A list of documents reviewed is included in the to this report.
b. Assessment The team concluded that self-assessments, QA audits, and other assessments were sufficiently critical, thorough, and effective in identifying issues. The team observed that these audits and self-assessments were completed in a thorough manner by personnel knowledgeable in the subject. The audits and self-assessments were completed to a sufficient depth to identify issues that were entered into the CAP for evaluation.
Corrective actions associated with the issues were implemented commensurate with their safety significance. Entergy managers evaluated the results and initiated appropriate actions to focus on areas identified for improvement.
c. Findings
No findings of significance were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with many station personnel, the team assessed the safety conscious work environment (SCWE) at Pilgrim. Specifically, the team interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The team also interviewed the station ECP coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regard to raising concerns. The team reviewed the ECP files to ensure that issues were entered into the CAP when appropriate. The team also reviewed a sample of anonymous CRs to gain insights into the SCWE.
b. Assessment During interviews, plant staff expressed a willingness to use the CAP to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The team noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the CAP and ECP. Based on these limited interviews, the team concluded that there was no evidence of an unacceptable SCWE and no significant challenges to the free flow of information.
c. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
On February 26, 2009, the team presented the inspection results to Mr. Kevin Bronson, Site Vice President, and to other members of the Pilgrim staff. The team verified that no proprietary information was documented in the report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
B. Barrus Control Rod Drive System Engineer
G. Bradley SRV Component Engineer
K. Bronson Site Vice President
D. Burke Security Manager
R. Byrne Sr. Licensing Engineer
B. Carroll PM Engineer
G. Choquette RBCCW System Engineer
K. DiMascio Employee Concerns Program Coordinator
P. Doody Design Engineer
S. Hudson EDG System Engineer
J. Keyes Corrective Action and Assessment Manager
W. Lobo Sr. Licensing Engineer
L. Loomis Senior Health Physics/Chemistry Specialist
J. Lynch Licensing Manager
J. Macdonald Assistant Operations Manager
W. Mauro Radiation Protection Supervisor
F. Mulcahy HPCI System Engineer
J. Priest Radiation Protection Manager
L. Rayle Chemistry Supervisor
D. Rydman RHR System Engineer
T. Sowdon Emergency Preparedness Manager
T. White Design Engineering Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
None