IR 05000293/2011002

IR 05000293/2011002; 01/01/2011-03/31/2011; Pilgrim Nuclear Power Station; Post-Maintenance Testing

ML111250379
Person / Time
Site:	Pilgrim
Issue date:	05/05/2011
From:	Diane Jackson NRC/RGN-I/DRP/PB5
To:	Rich Smith Entergy Nuclear Operations
Jackson, D E RI/DRP/PB5/610-337-5306
References
IR-11-002
Download: ML111250379 (35)

Text

UNITED STATES N UCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

SUBJECT:

PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/20r OA2

Dear Mr. Smith:

On March 31,2Q11, the U.S. Nuclear Regulatory Commission (NRC) completed an insPection at your Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents the results, which were discussed on April 14, 2011, with you and other members of your staff.

The inspection examined activities performed under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one self-revealing finding of very low safety significance (Green). This finding was determined to be a violation of NRC requirements. However, because of the very tow sJfety significance and because it has been entered into your corrective action program, the NRC is tieating the finding as a non-cited violation (NCV) consistent with Section 2.3.2'a of the NRC's Enforcement Policy. lf you contest any NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the_Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001, with cop-ies to ine RegionalAdministrator, Region l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001;and the NRC Senior Resident lnspectoiat PNPS. ln addition, if you disagree with the cross-cutting aspect assigned to the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region l, and the NRC Senior Resident Inspector at PNPS. The information you provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with 10 CFR 2.390 of the NRC's "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 NRC's 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,

/1 n A

/l r' t tttt 4 I \ I /

,ra,-r,AW Vl-v N aww\ '/ ./

Donald E. Jackslrf Chief Projects Branch 5 Division of Reactor Projects Docket No. 50-293 License No. DPR-35 Enclosure: InspectionReport05000293/2011002 w/Attachment: Supplemental lnformation cc: w/encl: Distribution via ListServ

SUMMARY OF FINDINGS

lR 0500029312011002;0110112011-0313112011; Pilgrim Nuclear Power Station; Post-

Maintenance Testing.

The report covered a three-month period of inspection by the resident and regional-based inspectors. One self-revealing non-cited violation (NCV) of very low sbfety significance (Green)was identified. The significance of most findings is indicated by their color (Green, White,

Yellow, Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process." Cross-cutting aspects associated with findings are determined using IMC 0310,

"Components Within the Cross-Cutting Areas." The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Gornerstone: Mitigating Systems

Green.

A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVl,

"Corrective Action," was identified for Entergy's failure to correct a condition adverse to quality. Entergy did not correct a Reactor Core lsolation Cooling (RCIC) torus suction valve which had failed to close during testing on October 4,2010. On January 5,2011, the same valve again failed to close during testing. Pilgrim's corrective actions included cleaning and replacing circuit breaker contacts and revising maintenance procedures to perform periodic resistance checks on motor control center circuit breaker cubicle secondary disconnects. Entergy has entered this issue into the corrective action program (CR-PNP-201 0-3486 and CR-PNP-2011-0046).

The inspectors determined that the finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone's objective to ensure the reliability and availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the RCIC torus suction valve failure to close affected the reliability of the RCIC system, and the RCIC system was made unavailable during system troubleshooting and repairs in January 2011. The inspectors determined the significance of the finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The finding was determined to be of very low safety significance (Green) because the finding did not involve a design or qualification deficiency resulting in a loss of operability or functionality, did not result in a loss of system safety function of a single train for greater than its Technical Specification outage time, and did not screen as potentially risk significant due to external initiating events.

The capability of RCIC to perform its function was not lost since the torus suction valve would have been able to be cycled open in the event RCIC needed to be aligned to the torus. This finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Entergy did not thoroughly evaluate the problem with the RCIC torus suction valve such that the resolution in October 2010 addressed the causes and corrected the problem. P.1(c)

(Section 1R19)

REPORT DETAILS

Summarv of Plant Status Pilgrim Nuclear Power Station (PNPS) began the inspection period operating at 100 percent power. On January 6,2011, operators reduced power to 62 percent to perform a control rod sequence exchange and control rod testing. Pilgrim returned to 100 percent power on January 7,2011. On February 5,2011, operators reduced power to 60 percent to perform control rod testing, and returned to 100 percent power later the same day. On February 20, 2011 , operators shut down the plant to perform a forced outage due to a Reactor Building Closed Cooling Water heat exchanger leak, and returned to '100 percent power on February 24,2A11. On February 24, 2011, operators reduced power to 65 percent to perform a control rod adjustment, and returned to 100 percent power on February 25,2011. Operators reduced powerto 73 percent on March 8,2011, to recovertwo control rods, and returned to 100 percent power on March 9, 2011. The plant ended the inspection period at approximately 90 percent power due to a plant power coast-down for a refueling outage.

1. REACTOR SAFEW

Cornerstones: Initiating Events, Mitigating Systems, and Barrier lntegrity

1R01 Adverse Weather Protection

lmpendinq Storm lnspection Scope (1 sample)

On the evening of January 11,2011, a significant winter storm was tracking to impact the Pilgrim plant. The inspectors reviewed Entergy's preparations for the high winds expected to accompany the storm. The inspectors reviewed Entergy's severe weather procedures including operations during severe weather and coastal storm preparations.

The inspectors performed a tour of the plant grounds and the switchyard to determine if loose debris or other material could become airborne in the presence of high winds and thereby potentially impact safety related equipment. The documents reviewed are listed in the Attachment.

b.

Findinqs No findings were identified.

1R04 Equipment Aliqnment (71 1 1 1.04)

.1 Partial Svstem Walkdowns

a. lnspection Scope (4 samples)

The inspectors performed four partial system walkdowns during this inspection period.

The inspectors performed a partial walkdown of each system to determine if the critical portions of the selected systems were correctly aligned in accordance with procedures, and to identify any discrepancies that may have had an effect on operability. The walkdowns included selected controlswitch position verifications, valve position checks, and verification of electrical power to critical components. In addition, the inspectors evaluated other elements, such as material condition, housekeeping, and component labeling. The documents reviewed are listed in the Attachment. The following systems were reviewed based on their risk significance for the given plant configuration:

'A' Reactor Building Closed Cooling Water (RBCCW) system with a leak in the

'B' RBCCW heat exchanger;

'A' Core Spray system and Automatic Depressurization system with High Pressure Coolant Injection system out-of-service for maintenance; a 'B' RBCCW train following maintenance and realignment; and a 'A' Residual Heat Removal (RHR) System with'B' RHR System out-of-service, b.

Findinos No findings were identified.

.2 Complete Svstem Walkdowns (7 1 1 11 .04S)

a. Inspection Scope

(1 sample)

The inspectors completed a detailed review of the Standby Gas Treatment (SBGT)

System to assess the functional capability of the system. The inspectors performed a walkdown of the system to determine whether the critical components, such as valves, dampers, and circuit breakers were aligned in accordance with operating procedures, and to assess the material condition of duct work, valves, and other supporting equipment. The inspectors discussed system health with the system engineer, reviewed the system's Maintenance Rule status, and performed a review of outstanding maintenance work orders to determine whether the deficiencies significantly affected the SBGT system function. The inspectors also reviewed condition reports from the past year to determine whether SBGT equipment problems were being identified and appropriately resolved. The documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

1R05 Fire Protection

Fire Protection - Tours (71111.05O)

a. Inspection Scope

(5 samples)

The inspectors performed walkdowns of five fire protection areas during the inspection period. The inspectors reviewed Entergy's fire protection program to determine the fire protection design features, fire area boundaries, and combustible loading requirements for the selected areas. The inspectors walked down these areas to assess Entergy's control of transient combustible material and ignition sources. In addition, the inspectors evaluated the material condition and operational status of fire detection and suppression capabilities and fire barriers. The inspectors then compared the existing condition of the areas to the fire protection program requirements to determine whether all program requirements were met. The documents reviewed are listed in the Attachment, The fire protection areas reviewed were:

a Fire Area 3.2, Fire Zone 3.2, Cable Spreading Room; a Fire Area 1

.10 , Fire Zone 3.11 , Former Control Room Annex;

a Fire Area 1.21, Fire Zone 1.27, Condensate Transfer and Plant Heating Pumps Room; a Fire Area 1.9, Fire Zone 1.6, Control Rod Drive Pump Quadrant; and a Fire Area 1.9, Fire Zone 1.13, Fuel Pool Cooling Pumps and Heat Exchanger Area.

b. Findinqs No findings were identified.

1R06 Flood Protection Measures (71 11 1.06)

===Internal Floodinq Inspection

a. Inspection Scope

(1 sample)===

The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and site flooding calculations to determine the design flood level for the Control Rod Drive (CRD)room. The inspectors also walked down the CRD Pump Quadrant and associated flood propagation pathways to assess the effectiveness of Entergy's internalflood control measures. The documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

1R07 Heat Sink Performance (71 11 1.07)

a. Inspection Scope

(1 sample)

The inspectors reviewed one sample of Entergy's program for maintenance, testing, and monitoring of risk significant heat exchangers (HXs) to assess the capability of the HXs to perform their design functions. The inspectors assessed whether the HX program conformed to Entergyls commitments at Pilgrim related to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment." In addition, the inspectors evaluated whether potential common cause heat sink performance problems could affect multiple HXs in mitigating systems or result in an initiating event. Based on risk significance and performance history, the 'B' RBCCW Heat Exchanger was selected for detailed review by the inspectors.

b. Findinqs No findings were identified.

1R1 1 Licensed Operator Requalification Proqram (71 1 1 1 ,1 1 )

.1 Biennial Review (71111.1 1B)

a. Inspection Scope

On January 18, 2011, one NRC region-based inspector performed an in-office review of the results of licensee-administered annual operating tests and comprehensive written exams ior 2010. The inspection assessed whether pass rates were consistent with the guidance of NRC Inspection Manual Chapter 0609, Appendix l, "Operator Requalification Human Performance Significance Determination Process (SDP)." The inspector verified that:

.

Crew pass rates were greater than 80%. (Pass rate was 100%);

.

Individual pass rates on the written exam were greater than 80%. (Pass rate was 100%);

r lndividual pass rates on the job performance measures of the operating exam were greater than 80%. (Pass rate was 96.6%);

e lndividual pass rates on the dynamic simulator test were greater than 80%. (Pass rate was 100%); and r Overall pass rate among individuals for all portions of the exam was greater than or equal to 80%. (Overall pass rate was 96.6%o).

b. Findinqs No findings were identified.

.2 Resident Inspector Quarterlv Review (7 1111.1 1 O)

a.

Insoection Scope (1 sample)

The inspectors observed licensed operator performance during a licensed operator requalification training simulator exercise on February 28,2011. The inspectors observed crew response to an anticipated transient without scram scenario. The inspectors assessed the licensed operators' performance to determine if the training evaluators adequately addressed observed deficiencies. The inspectors reviewed the applicable training objectives from the scenario to determine if they had been achieved.

ln addition, the inspectors performed a simulator fidelity review to determine if the arrangement of the simulator instrumentation, controls, and tagging closely paralleled that of the control room. The documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

1 R12 Maintenance Effectivenegs (71 1 1 1

.12 Q)

a. Inspection Scope

(2 samples)

The inspectors reviewed the two samples listed below for items such as:

(1) appropriate work practices;

(2) identifying and addressing common cause failures;

(3) scoping in accordance with 10 CFR 50.65 paragraph

(b) of the Maintenance Rule; (4)characterizing reliability issues for performance;

(5) trending key parameters for condition monitoring;

(6) charging unavailability for performance;

(7) classification and reclassification in accordance with 10 CFR 50.65 paragraph (aX1) or (aX2); and (8)appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as paragraph (aX2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as paragraph (a)(1). The documents reviewed are listed in the Attachment. ltems reviewed included the following:

o Line 342 Exceeding Unavailability Criteria for (a)(1) Evaluation; and

.

(a)(1) Evaluation of K-1 11 Air Compressor Exceeding Functional Failure Performance Criteria and Repeat Functional Failures.

b. Findinqs No findings were identified.

1R13 Maintenance Risk Assesgments and Emeroent Work Control (71 11 1.13)

a. lnspection Scope (5 samples)

The inspectors evaluated five maintenance risk assessments for planned testing and maintenance activities. The inspectors reviewed maintenance risk evaluations, work schedules, and control room logs to determine if concurrent maintenance or surveillance activities adversely affected the plant risk already incurred with out-of-service components. The inspectors evaluated whether Entergy took the necessary steps to controlwork activities, minimized the probability of initiating events, and maintained the functional capability of mitigating systems. The inspectors assessed Entergy's risk management actions during plant walkdowns. The documents reviewed are listed in the

. The inspectors reviewed the conduct and adequacy of maintenance risk assessments for the following maintenance and testing activities:

.

Green Risk for Reactor Core lsolation Cooling Torus Suction Valve MO-1300-26 Out-of-service; r Orange Risk for'B' Emergency Diesel Generator Out-of-service and Station Blackout Diesel Generator Emergent Failure; o Forced Outage Shutdown Risk Assessment;

.

Risk Assessment During Inoperability of 'B' Reactor Building Closed Cooling Water System at Power and Following Shutdown; and

.

Green Risk for'A' Residual Heat Removal Low Pressure Coolant Injection Testing.

b. Findinqs No findings were identified.

1R15 Operabilitv Evaluations (71 11 1.15)

a. Inspection Scope

(6 samples)

The inspectors reviewed six operability determinations associated with degraded or non-conforming conditions to determine if the operability determination was justified and if the mitigating systems or barriers remained available such that no unrecognized increase in risk had occurred. The inspectors reviewed Entergy's performance against related Technical Specifications (TS) and UFSAR requirements. The documents reviewed are listed in the Attachment. The inspectors reviewed the following degraded or non-conforming conditions:

CR-PNP-2011-0046, Reactor Core lsolation Cooling Torus Suction Valve Stopped Mid-Stroke; CR-PNP-2O11-0235, 'B' Emergency Diesel Generator 125V Hard Ground During Surveillance;

.

CR-PNP-2011-2421245, 'B' Reactor Building Closed Cooling Water (RBCCW)

Heat Exchanger Leak;

.

CR-PNP-2011-576, Anticipated Transient Without Scram (ATWS) Division 1 Pressure Indicator Out of Calibration;

.

CR-PNP-2011-1013, Standby Gas Treatment (SBGT) Heater Relay Trip Indicator Lit while the SBGT System Was Not Running; and

.

CR-PNP-2011-272, Rod Position Indication System Failure.

b.

Findinqs

Introduction:

An unresolved item (URl)was identified because additional information regarding the operability of control rods after control rod position indication was lost at PNPS is required to determine whether a performance deficiency exists, Control rod position indication was restored shortly after it was lost. The inspectors will review additional information when it is submitted by Entergy to determine if TS 3.3.8.1, "Control Rod Operability," should have been entered when control rod position indication was lost.

Description:

On January 20,2011, at 5:19 p.m., PNPS lost control rod position indication for all control rods. Instrumentation and control (l&C) technicians began troubleshooting the Rod Position Indication System (RPIS) and identified that the power supply feeding RPIS was inoperable. Operators determined that TS surveillance 4.3.8.1.5, "Control Rod Operability," had been completed successfully just prior to losing RPIS and therefore they concluded that they had 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the surveillance completion before they would consider the surveillance not met. The inspector's review of Pilgrim's TS Bases identified the following statement:

"The OPERABILITY of an individual control rod is based on a combination of factors, primarily the scram insertion times, the associated control rod scram accumulator status, the control rod coupling integrity, and the ability to determine control rod position."

When control rods are determined to be inoperable, TS 3.3.8.1, "Control Rod Operability," requires the control rod to be fully inserted into the core within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. In addition, the associated Control Rod Drive for each control rod is required to be disarmed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

l&C technicians repaired the power supply. RPIS was restored at 9:53 p.m., and control room personnel observed that there had been no change in control rod position.

Condition Report (CR) CR-PNP-2O11-0272 was written to address the power supply failure and CR-PNP-2011-0511 was subsequently written to address Entergy's interpretation and administration of TS 3.3.8.1. URI 05000293/2011002-01, Application of TS 3.3.B.1 when Control Rod Position Indication is Lost.

1R18 Plant Modifications

.1 Temporarv Modification to Install Boundarv Valve Downstream olFxistinq Salt Service

Walgl (SSW) lsoldion Valve 29-HO-3871A a. lnspection Scope (1 sample)

The inspectors reviewed temporary modification EC 26697, "lnstall Boundary Valve Downstream of Existing SSW lsolation Valve 29-HO-3871A," to determine whether the performance capability of the SSW system had been degraded through the modification.

The inspectors reviewed Control Room drawings, relevant condition reports, and work orders to ensure the temporary modification did not adversely affect the SBGT system.

The inspectors reviewed the annotated drawings to determine whether they properly reflected the temporary modification. The inspectors also walked down the heat exchangers in the Auxiliary Bay to review the installed modification. The documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

.2 Temporarv Modification to Supplement the 'B' RBCCW Water Supply

a. lnspection Scope (1 sample)

The inspectors reviewed temporary modification Engineering Change (EC) 27108, "Supplemental RBCCW Water Supply," to determine whether the performance capability of the 'B' RBCCW system had been degraded through the modification. The inspectors reviewed Control Room Drawings, condition reports, design documents, and an operability evaluation to ensure the temporary modification did not adversely affect the

'B'RBCCW system. The inspectors reviewed the annotated drawings to determine whether they properly reflected the temporary modification, The inspectors also walked down the RBCCW system as well as temporary equipment to review the installed modification. The documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

.3 Permanent Modification for lnstallinq Hiqh Point Vent Valves on Hiqh Pressure Coolant

Iniection (HPCI) Torus Suction Pipinq a. lnspection Scope (1 sample)

The inspectors reviewed permanent modification EC 12422, Revision 0, 'Add High Point Vent for HPCI Torus Suction and Core Spray Loop 'A' Discharge ldentified in Report PNP-ME-O8-QA2," and the associated 10 CFR 50.59 screening, to determine whether the licensing bases and performance capability of the HPCI system had been degraded through the modification. A walkdown was performed to determine whether the components inside the room were as described in the permanent modification documentation. The documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

1 R19 Post-Maintenance Testinq (71 1 1 1

.19 )

a. Inspection Scope

(6 samples)

The inspectors reviewed six samples of post-maintenance tests during this inspection period. The inspectors reviewed these activities to determine whether the post-maintenance test adequately demonstrated that the safety-related function of the equipment was satisfied given the scope of the work performed, and that operability of the system was restored. In addition, the inspectors evaluated the applicable test acceptance criteria to verify consistency with the associated design and licensing bases, as well as Technical Specification requirements. The inspectors also evaluated whether conditions adverse to quality were entered into the corrective action program for resolution. The documents reviewed are listed in the Attachment. The following maintenance activities and their post-maintenance tests were evaluated:

Reactor Core lsolation Cooling Torus Suction Valve Test Following Actuator and Breaker Maintenance; Replace Snubbers and Switch for Recirculation Loop Differential Pressure Instrument for Low Pressure Coolant Injection Loop Selection; a Weld Repair of 'A' Residual Heat Removal Loop Vent Line; o Repair Tube Leaks on 'B' Reactor Building Closed Cooling Water Heat Exchanger; a Core Spray Discharge Loop 'A'Vent Valves Installation; and a High Pressure Coolant Injection Valve Maintenance and Torus Suction Piping Vent Valve lnstallation.

Findinos

Introduction:

A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," was identified for Entergy's failure to correct a condition adverse to quality. Entergy did not correct a Reactor Core lsolation Cooling (RCIC) torus suction valve which had failed to close during testing on October 4,2Q10. On January 5, 2011, the same valve again failed to close during testing.

Description:

On October 4,2Q10, Entergy performed diagnostic testing on a RCIC torus suction valve (MO-1301-26) as part of a planned maintenance activity on the RCIC system. MO-1301-26 was electrically stroked open and then stroked closed. During its close stroke, MO-1301-26 failed to close. CR-PNP-2010-3486 was written, a troubleshooting plan was developed, and subsequently, an apparent cause evaluation was performed. The troubleshooting plan specified several activities that maintenance was to undertake including examining the valve actuator and the circuit breaker cubicle.

The initial examination of the actuator discovered hardened grease on the torque switch which Entergy cleaned. They subsequently stroked the valve open and closed several times and restored the RCIC system to service concluding that the hardened grease was the cause of the valve failure.

On January 5, 2011 , MO-1301-26 was stroked open and then stroked closed during its quarterly surveillance, however, the valve again failed to close. Troubleshooting performed by electrical maintenance included examining the limit and torque switches to verify no mechanical binding was occurring, and examining circuit breaker and cubicle components. Entergy identified that resistance in certain contacts exceeded industry values. Contacts were either cleaned or replaced and the valve was restored to service.

Analvsis: The performance deficiency was that Entergy did not correct a condition adverse to quality; in that, the RCIC torus suction valve twice failed to stroke closed during testing. The inspectors determined that the corrective actions following the first failure were not effective in identifying and addressing the excess contact resistance later identified in the breaker cubicle following the second failure. Traditional Enforcement does not apply; as the issue did not have actual safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

The inspectors determined that the finding was more than minor because the finding was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone's objective to erisure the reliability and availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the RCIC torus suction valve failure to close affected the reliability of the RCIC system and the RCIC system was made unavailable during system troubleshooting and repairs in January, 2011.

A review of NRC Inspection Manual Chapter (lMC) 0612, Appendix E, "Minor Examples,"

revealed that no minor examples were applicable to this finding. The inspectors determined the significance of the finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The finding was determined to be of very low safety significance (Green) because the finding did not involve a design or qualification deficiency resulting in loss of operability or functionality, did not result in a loss of system safety function of a single train for greater than its Technical Specifications allowed outage time, and did not screen as potentially risk significant due to external initiating events. The capability of RCIC to perform its function was not lost since MO-1301-26 would have been able to be cycled open in the event RCIC needed to be aligned to the torus.

This finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Entergy did not thoroughly evaluate the problem with the RCIC torus suction valve such that the resolution in October 2010 addressed the causes and corrected the problem. P.1(c)

Enforcement:

10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires in part that measures shall be established to assure that conditions adverse to quality, such as defective material and equipment are promptly identified and corrected.

Contrary to the above, Entergy did not correct an October 2010 condition adverse to quality which led to the RCIC torus suction valve failing to close in January 2Q11.

Pilgrim's corrective actions included cleaning and replacing circuit breaker contacts and revising maintenance procedures to perform periodic resistance checks on motor control center cubicle secondary disconnects. Entergy has entered this issue into the corrective action program (CR-PNP-2010-3486 and CR-PNP-2011-0046). Because this finding is of very low safety significance and has been entered into the corrective action program, it is being treated as an NCV, consistent with the NRC's Enforcement Policy. NCV

===05000293/2011002-02, Inadequate Corrective Actions for RGIC Torus Suction Valve.

1R20 Refuelinq and Other Outaoe Activities

Inspection Scope ===

The inspectors reviewed the outage plan and shutdown risk assessments for a forced, non-refueling outage performed from February 20,2011, through February 23,2011.

The outage was conducted following a plant shutdown due to a 'B' RBCCW heat exchanger leak. The documents reviewed during the inspection are listed in the

. During this outage, the inspectors observed plant shutdown and start-up activities including the outage activities listed below:

.

Hot and Cold Shutdown Cooling Control; o Shutdown Risk Assessment and Risk Management; o lmplementation of Technical Specifications; o Outage Control Center Activities; o Plant Startup; and

.

Licensee identification and resolution of problems during, and related to outage activities.

b. Findinqs No findings were identified.

1R22 Surveilfance Testinq (7 I 111

.22 )

a. Inspection Scope

(6 samples)

The inspectors witnessed six surveillance activities and/or reviewed test data to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety-related functions. The inspectors reviewed selected prerequisites and precautions to determine if they were met, and if the tests were performed in accordance with the procedural steps.

Additionally, the inspectors evaluated the applicable test acceptance criteria for consistency with associated design bases, licensing bases, and Technical Specification requirements. The inspectors also evaluated whether conditions adverse to quality were entered into the corrective action program for resolution. The documents reviewed are listed in the Attachment. The following surveillance tests were evaluated:

a 'B' Emergency Diesel Generator Operability Run; a Low Pressure Coolant Injection and Containment Cooling Motor Operated Valve Operability and In-Service Test (lST);

Control Rod Testing of Rods 06-39 and 46-39;

.

'B' Salt Service Water Pump Quarterly Operability Test (lST);

.

Reactor Coolant System (RCS) Leakage Detection Surveillance; and

.

Core Spray'A' In-Service Test (lST).

b. Findinqs No findings were identified.

lEPO Drill Evaluation (71114.06)

a. Inspection Scope

(1 drill observation sample)

The inspectors observed a licensed operator requalification training simulator exercise on February 28,2011. The inspectors evaluated performance in the simulator, for an Anticipated Transient Without Scram (ATWS) scenario which escalated to a Site Area Emergency. The inspectors assessed the implementation of Emergency Action Level classification and notification decisions for the ATWS event. The inspectors also assessed whether Pilgrim's critique of the exercise assessed all observations and findings.

b.

Findinqs No findings were identified.

4OA1 Performance Indicator Verification

(71 151) Mitigating Systems and Barrier Integrity

a. Inspection Scope

(3 samples)

The inspectors reviewed Performance Indicator (Pl) data to determine the accuracy and completeness of the reported data. The review was accomplished by comparing reported Pl data to confirmatory plant records and data available in plant logs, CRs, Licensee Event Reports (LERs), and NRC inspection reports, The acceptance criteria used for the review included Nuclear Energy Institute (NEl) 99-02, Revision 6, "Regulatory Assessment Performance lndicator Guidelines, " and NU REG-1 022, Revision 2, "Event Report Guidelines 10 CFR 50.73." The documents reviewed are listed in the Attachment. The following performance indicators were reviewed:

.

Mitigating System Cornerstone, Safety System Functional Failures from the first quarter of 2010 though the fourth quarter o'12010;

.

Barrier lntegrity Cornerstone, Reactor Coolant System (RCS) Activity from the first quarter of 2010 through the fourth quarter of 2010; and

.

Barrier Integrity Cornerstone, RCS Leakage from the first quarter of 2010 through the fourth quarter of 2010.

b.

Findinqs No findings were identified.

4c42 ldentification and Resolution of Problems (71152)

,1 Review of ltems Entered into the Corrective Action Proqram (CAP)

a. Inspection Scope

The inspectors performed a screening of each item entered into Entergy's corrective action program. This review was accomplished by reviewing printouts of each CR, attending daily screening meetings, and accessing Entergy's CR database. The purpose of this review was to identify conditions, such as repetitive equipment failures or human performance issues that might warrant additional follow-up.

b. Findinqs No findings were identified.

Control Blade Pq( 21 Observations (2 samples)

a. Inspection Scopg The following inspection activities were performed using NRC inspection procedure 711S2, "ldentification and Resolution of Problems," Section 03.02.

A review was conducted of the CRs related to fuel and core component movement performance at Pilgrim Nuclear Power Station generated for the past two years. A review of the CRs associated with core component movement errors associated with the 2009 refueling outage and recent CRs involving the refueling bridge was performed. A review of the corrective actions, status of the corrective actions, and associated root cause evaluation was performed and reviewed with members of the Pilgrim staff.

Interviews were conducted with members of the training, operations, maintenance, and licensing departments regarding the root cause and corrective actions.

In addition, the General Electric\Hitachi (GEH), "Part 21 Reportable Condition Notification: Design Life of D and S Lattice Marathon Control Blades, February 15, 2011," for the Pilgrim Nuclear Power Station, and applicable Entergy procedure EN-RE-211, "Control Blade Life," Revision 0, was reviewed. The review included incorporation of the updated GEH control rod blade (CRB) boron depletion limits, reactor coolant system (RCS) chemistry data used to monitor for CRB tube cracking, and the Entergy short term and long term correction actions related to the Marathon CRBs.

b. Findinqs and Observations No findings were identified.

Fuel and Core Component Movement Observations:

The inspector performed a detailed walkdown of the refuel floor to evaluate the refuel equipment improvements that were implemented in response to prior refuel activity errors and equipment deficiencies. The most notable upgrade was the overhaul of the refueling platform and support equipment that is used to perform fuel bundle and core component manipulations. The inspector accessed the platform and observed multiple component manipulations by plant operators using the new equipment. The refuel machine computer interface was updated to include additional interlocks that are designed to significantly reduce the probability of a human error when performing refueling manipulations. Recent upgraded communication equipment, additional high resolution cameras, and the addition of new computer monitors provide a more user friendly operator work station. The inspector noted that management support for refuel floor continuous improvement was evident, and actions to resolve prior problems were thorough and effective.

The inspector observed a proactive approach to eliminating fuel and core component errors during the 2011 refueling outage. Pilgrim personnel attended 'Just-in-time" training at the refueling vendor's site in San Jose, CA, where they practiced incore fuel movement using Pilgrim site specific procedures in conjunction with vendor personnel and vendor refueling equipment. Emphasis on standard communication and critical steps for fuel and core component movement was emphasized. A strong commitment from Pilgrim management was also observed as this training was attended by the Pilgrim Assistant Operations Manager.

General Electric Hitachi Marathon Control Blade Part2l Observations:

The inspector reviewed the General Electric\Hitachi (GEH), "Part2l Reportable Condition Notification: Design Life of D and S Lattice Marathon Control Blades, February 15, 2011." The review included the Pilgrim Nuclear Power Station and applicable Entergy procedure EN-RE-211, "Control Blade Life," Revision 0.

Pilgrim has 21 susceptible Marathon Control Rod Blades (CRBs) on-site. Prior to the April 2011 refueling outage, eighteen CRBs were in use in the reactor core, and three were not installed in the reactor and were stored on-site in a warehouse. Pilgrim performed a detailed evaluation of the core exposure and in-service life of the 18 CRBs installed in the reactor. The evaluation implemented the more stringent criteria for limiting the CRBs total in-service life to a boron depletion value of 54 percent for the 'D' Lattice plants, including Pilgrim. Using the revised boron depletion limit, Pilgrim determined that one CRB would exceed the new GEH limit during the upcoming two year reactor operating cycle. As a result, Pilgrim removed this CRB from the reactor during the April 2Q11 refueling outage, and replaced it with one of the CRBs stored in the warehouse. Additionally, Pilgrim took the two remaining spare CRBs and replaced two additional CRBs that had the second and third most limiting CRB boron depletion values.

The inspector reviewed the Pilgrim corrective actions related to the updated GEH Marathon CRB Part 21 issue. Pilgrim's Marathon CRB life expectancy calculations were comprehensive and the planned removal of the three most limiting CRBs will substantially reduce the likelihood of in-service CRB cracking during reactor operation.

The implementation of the GEH limits will ensure the Marathon CRBs in the reactor core will perform their required safety function to shutdown the reactor for postulated plant events. The Pilgrim site procedures were updated to incorporate the new CRB boron depletion limit. In addition, a corrective action item related to the revision of Entergy corporate procedure EN-RE-211, "Control Blade Life," Revision 0, was scheduled to include the most recent GEH Marathon CRB limits in April 2011.

The inspector reviewed the Pilgrim RCS boron chemistry data for the past three years to determine if the 100 parts per billion (ppb) CRB tube cracking threshold was exceeded.

The RCS boron readings have averaged between 40 to 70 ppb; below the 100 ppb value from 2008 to the present. An RCS boron concentration greater than 100 ppb would be indicative of potential Marathon CRB tube cracking. CR-PNP-2010-03755 documented revision to chemistry procedure No. 7.8.1 to include specific RCS boron limits and increase the RCS sampling frequency from monthly to weekly.

The inspector determined that the Pilgrim Station and Entergy corporate short term and long term correction actions related to the Marathon CRBs were comprehensive and effectively addressed the General Electric\Hitachi Part 21 Reportable Condition Notification, dated February 15, 2011.

Examination (1 sample)

a. Inspection Scope

A Problem ldentification and Resolution (Pl&R) sample inspection was performed during the period January 3,2Q11 through January 12,2011. The purpose of this inspection was to review the status of Entergy's non-destructive examination activities focused on the condensate storage tank (CST) and buried piping area of Pilgrim station as this location was identified as a potential source of contamination of groundwater at the Pilgrim site. The inspector reviewed Entergy's efforts to define locations that could be a potential source of discharge of contaminants to the ground water in the event of piping failure. The inspector reviewed a sample of condensate piping drawings selected based on their potentialfor providing fluid to groundwater pathways and that were inaccessible for conventional examination (visual, surface or volumetric non-destructive test). Also, piping segments selected were those conveying contaminated fluid(s) and were at locations without structural protection and containment (tunnel, vaults, buildings, enclosed in guard pipe, etc). The inspector reviewed the technical report which described the inspection process, results, conclusions and planned corrective action.

The inspector interviewed cognizant engineering and non-destructive test specialists to review and discuss the use of the guided wave ultrasonic test (UT) and the interpretation of the test results for characterization of noted anomalies.

The inspector reviewed the non-destructive test (NDT) procedure, test equipment, and process used for the performance of the guided wave test (GWT). Also, the inspector reviewed all CRs, operability, reportability and planned sample expansion (extent of condition) and subsequent corrective actions. The inspector assessed the use of this inspection methodology as undertaken by Entergy as an "inspection" or "screening" tool to confirm the integrity of the condensate transfer piping (CTP).

b. Findinqs and Observations This non-destructive test inspection was conducted to examine the pipe for the presence of indications (anomalies) and, if they are detected, to identify and characterize the conditions noted. This NDT was used to examine selected inaccessible piping segments for general corrosioniwastage and other forms of degradation including through wall penetration at any location.

The guided wave technology uses ultrasonic sound waves to screen long lengths of pipe for the purpose of detecting wall thickness irregularities as associated with corrosion and erosion processes. This examination technique enables the screening of large areas from a single transducer (sound generator) location which is possible using guided waves which propagate along the pipe. In this manner the performance of a single test will screen a number of feet of pipe from both sides of the transducer location. The interpretation of test results provides for classification of the signal reflections but cannot be used to give precise "sizing" or orientations of anomalies detected or provide accurate estimations of remaining wall thickness particularly if the configuration of the pipe being examined is unknown.

Entergy selected twelve piping segments for guided wave testing totaling approximately 270 feet of inaccessible (buried) piping in the condensate piping system. The non-destructive testing was performed during the period July 27 - 28,2010, and included 4, 8, 10, 16 and 18 inch diameter, seam welded type 304 stainless steel piping (specification M300 pipe class HA). Twelve guided wave tests were performed.

As stated earlier, the guided wave technology and the test results it produces have limitations in which the precise sizing or orientation of anomalies detected is unknown.

The inspector reviewed and noted that Entergy appropriately recognized these limitations in their performance of the operability determination. Entergy engaged independent third party engineering review of data acquisition, evaluation and interpretation for development of the operability determination, and subsequent corrective action. The inspector reviewed the guided wave report and noted no new information or insights related to the anomalies.

The inspector reviewed those portions of piping segments selected for remote non-destructive testing and noted that they were not accessible for examination (either during plant operation or during an outage), and could not be inspected using accepted ASME code approved inspection techniques. Also, the locations selected presented a potential source of tritium contaminated water that could possibly travel to site groundwater. The locations selected were buried directly in soil and covered with concrete and/or bituminous paving materials. A small portion of this piping that was inspected did extend into the auxiliary building and was accessible for conventional non-destructive testing. A sample butt weld within this portion was examined using a manual ultrasonic test technique and no recordable indications or wall thinning was reported.

Introduction:

An unresolved item (URl) was identified because additional information is needed to determine if a performance deficiency exists regarding a discrepancy between various piping and instrumentation drawings (P&lDs) for the condensate and demineralized water storage/transfer systems, and the associated in-service inspection (lSl) drawings for the High Pressure Coolant Injection (HPCI) and Reactor Core lsolation Cooling (RCIC) piping and their related ASME Code safety classification.

Description:

During this review the inspector noted a lack of clear description in assignment of piping safety classification shown on plant drawings for the aforementioned systems. The inspector observed that symbol convention used on the drawings was not reconciled with the requirements presented in the piping specification (M300, Rev 107, Section 3.0, ltem 1.0, Classification of Piping Components), and the P&lD legend.

Entergy initiated CR PNP-2011-0127, which identified the need for a definition of the safety classification of the HPCI and RCIC suction piping from the condensate storage tanks to the first isolation valve within the auxiliary building. Appropriate code safety classification is necessary to ensure accurate in-service inspection requirements.

Entergy's actions with regard to the resolution of the HPCI and RCIC piping safety classification (and boundary class changes) as shown on the referenced drawings remain to be reviewed and assessed to ascertain conformance with the applicable ASME Code (Section Xl) and NRC regulatory requirements. While the discrepancy may be related to a drawing error, it is possible that the subject piping is ASME Class 2 (or other), and should have been subject to ASME Code Class 2 (or other) design and testing requirements. URI 05000293/2011002-03, Need For Clarification on Condensate Storage Tank Suction Piping ASME Classification 40A3 Event Follow-up (71 153)

'B' RBCCW Svstem Leakaqe Exceeds Operabilitv Limit a.

Inspection Scope (1 sample)

On January 19,2011, Entergy identified that the 'B' RBCCW system experienced a leak when observing the head tank overflowing during a walkdown. Entergy sampled the 'B' RBCCW system and identified chlorides, which was indicative of a leak from the salt service water system into the RBCCW system. Entergy reviewed the maximum allowed leakage for RBCCW and determined that during a Loss of Coolant Accident coincident with a Loss of Offsite Power that RBCCW would exceed its allowed limit. Entergy entered the appropriate Technical Specifications and then exited when compensatory measures were implemented and a modification was installed that could make-up water to RBCCW in the event of an accident. The inspectors reviewed Entergy's actions, proced u res, Techn ical Specifications, com pensatory measures, and temporary modifications.

b. Findinqs No findings were identified.

40A6 Meetinqs. Includinq Exit On January 12,2011, the regional inspector presented the results of the Selected lssue Follow-up Inspection of Condensate Storage Tank and Buried Piping examination to Mr.

J. Lynch, Licensing Manager. The inspectors confirmed that no proprietary information was provided during the inspection.

The Operating Licensing inspector presented the inspection results to Mr. Joseph Lynch, Manager, Licensing, and members of his staff via a telephone call on April 12, 2011.

On April 14,2011, the resident inspectors conducted an exit meeting and presented the preliminary inspection results to Mr. Robert Smith, and other members of the Pilgrim staff. The inspectors confirmed that proprietary information provided or examined during the inspection was controlled and/or returned to Entergy, and that the content of this report includes no proprietary information.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy personnel:

S. Bethay Director, Nuclear Safety Assurance

R. Byrne Sr. Licensing Engineer, Licensing

B. Chenard System Engineering Manager

J. Dreyfuss General Manager, Plant Operations

V. Fallacara Engineering Director

D. Fountain Instructor, Operations Training

R. Helms Instructor, Mechanical Maintenance Training

W, Lobo Licensing Engineer

J. Lynch Licensing Manager

J. Macdonald Assistant Operations Manager-Shift

T. McElhinney Chemistry Manager

D. Noyes Operations Manager

J. Priest Radiation Protection Manager

S. Reininghaus Training and Development Manager

J. Scheffer Chemistry Supervisor

B. Sheridan Instructor, Operations SRO Training

R. Smith Site Vice President

J. Taormina Maintenance Manager

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Ooened and

Closed

NCV

0500029312011002-02 Inadequate Corrective Actions for RCIC Torus Suction Valve (Section 1R19)

Opened

URI

0500029312011002-01 Application of TS 3.3.8.1 When Control Rod Position Indication is Lost (Section 1R15)

URI

0500029312011002-03 Need For Clarification on Condensate Storage Tank Suction Piping ASME Classification (Section 4OA2)