IR 05000293/2011008
| ML111050174 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/15/2011 |
| From: | Diane Jackson NRC/RGN-I/DRP/PB5 |
| To: | Rich Smith Entergy Nuclear Operations |
| Jackson D RGN-I/DRP/PB2/610-337-5306 | |
| References | |
| IR-11-008 | |
| Download: ML111050174 (21) | |
Text
UNITED STATES ril 15, 2011
SUBJECT:
PILGRIM NUCLEAR POWER STATION'NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT O5OOO293/201 1OO8
Dear Mr. Smith:
an on March 4,2011, the United states Nuclear Regulatory commission (NRC) completed the inspection ,i you1. Pilgrim Nuclear Power Station (PNpS). fne enclosed report documents inspection results which were discussed on March 4,2011 with you and other members of your staff.
relate to identification This inspection examined activities conducted under your license as they rules and regulatio-ns and and resolution of probt"rr and compliance with the iommission's examination of selected conditions of your license. within these areas, the inspection involved with procedures and ,epresentative records, observations of activities, and interviews personnel.
Entergy Nuclear Based on the samples selected for review, the inspectors concluded that resolving Op"i"tionr, lnc. (dntergy) was generally etfective in identifying, evaluating, and into the corrective p,bor"r, prup's. ent6igy peisonnel identified problems and entered them
"i at a low thieshob. Entergy prioriiized and evaluated issues commensurate with action program generally implemented in a the safety significance of the problems aid corrective actions were timely manner.
(Green). The This report documents two NRC-identified findings of very low safety significance requirements'
inspectors determined that one of these findings involved.a violation of NRC signiflcance and because it was entered into your However, because of tn" very low safety violation (NCV)'
corrective action program, th; NRc is treati-ng this finding.as a non-cited Policy. lf you contest this NCV, you consistent with Sect'6 n z.s.zof the NRC Enforcement this inspection with the basis for should provide r"rponr" within 30 days of the date-of leport,
" Nuclear Regulatory Commission, ATTN: Document your denial, to the Control Desk'
Region l; the Director, washington, DC 20555-000t, with copies to the Regional Administrator, Washington, DC 20555-Office of Enforcement, United States irluclear negulatory Commission, 0001; and the NRC Senior Resident lnspector at ptrlpS. addition, if you disagree with the... .
.ln provide a response, within cross-cutting aspect assigned to any finding in this report, you should for your disagreement, to the 30 days of the date of thii inspectioh reportl with the basis at PNPS'
RegionalAdministiaior, Region l, and the NRC Senior Resident lnspector ln 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 website at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).
Projects Branch 5 Division of Reactor Projects Docket Nos.: 50-293 License Nos.: DPR-35
Enclosure:
lnspectionReport05000293/2011008 w/Attachment: Supplemental Information
REGION I Docket No: 50-293 License No: DPR-35 Report No: 05000293/2011008 Licensee: Entergy Nuclear Operations, Inc.
Facility: Pilgrim Nuclear Power Station (PNPS)
Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: February 14 through March 4,2011 Team Leader: D. Werkheiser, Senior Resident Inspector, Division of Reactor Projects (DRP)
Inspectors: C. Bickett, Senior Project Engineer, DRP B. Smith, Resident lnspector, DRP J. DeBoer, Reactor Engineer, DRP Approved By: Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
f R 05000293120110Q8;0211412011
- 0310412011; Pilgrim Nuclear Power Station; Biennial Baseline lnspection of Problem ldentification and Resolution. The inspectors identified one finding in the area of problem identification and one finding in the area of prioritization and evaluation of issues.
This NRC team inspection was performed by two resident and two regional inspectors. The inspectors identified two findings of very low safety significance (Green) during this inspection with one finding classified as a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (lMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. 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.
Problem ldentification and Resolution The inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Entergy personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. However, the inspectors identified one finding which was not a violation of regulatory requirements, in the area of problem identification. In most cases, Entergy appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences.
However, the inspectors identified one finding that was a violation of NRC requirements, in the area of effectiveness of prioritization and evaluation of issues. The inspectors also determined that Entergy typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner.
The inspectors concluded that, in general, Entergy adequately identified, reviewed, and applied relevant industry operating experience to Pilgrim Nuclear Power Station operations. ln addition, based on those items selected for review, the inspectors determined that Entergy's self-assessments and audits were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues, nor did they identify any conditions that could have had a negative impact on the site's safety conscious work environment.
Cornerstone: Mitigating Systems
.
- Green.
The NRC identified a finding of very low significance for Entergy's failure to follow their corrective action process in the identification, documentation, and evaluation of a degraded condition. Specifically, Entergy failed to recognize, fully document, and evaluate in their corrective action process that an installed diaphragm in the High Pressure Coolant lnjection (HPCI) System exceeded its manufacturer-recommended service life. Entergy entered this issue in their corrective action process (CR-PNP-2011-0917) to evaluate and determine corrective actions to address this issue.
The inspectors determined the finding was more than minor because it is similar to example 4(a) of NRC Inspection Manual Chapter (lMC) 0612, Appendix E, 'Minor Examples,' in that Entergy did not perform an evaluation that was later determined to adversely affect safety-related equipment. The inspectors determined the finding was of very low safety significance (Green) using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings" in that the finding involved a qualification deficiency not resulting in the loss of operability of HPCI.
The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program because Entergy did not identify that exceeding the service life of the PCV-2301-238 diaphragm was a condition adverse to quality. IP.1(a)l (Section 4OA2.1.c.(1 ))
- Green.
The NRC identified a NCV of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," paragraph (a)(2), for Entergy's failure to adequately demonstrate primary containment system (aX2) performance was effectively controlled through performance of appropriate preventive maintenance.
Specifically, as evidenced by repeat functional failures of torus air temperature indication during the fall of 2009 and January 2010, the (a)(2) performance demonstration was no longer justified in accordance with Entergy's maintenance rule implementing procedure guidance. Entergy entered this issue in their corrective action process (CR-PNP-201 1-00880) to evaluate corrective actions needed to address this issue.
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 objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Specifically, failures of torus air temperature indication present a challenge to operators who rely on the indication to diagnose and respond to initiating events. Per the guidance provided in Inspection Procedure711l1.12,"Maintenance Effectiveness," issued 1111612009, inspectors considered this performance deficiency to be a Category lll finding since a historical review revealed a continuing declining trend in performance of the instrument, as indicated by additionalfunctionalfailures. Because this issue was classified as Category lll, the inspectors determined the significance of this finding using IMC 0609.04,
"Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined that this finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk significant due to external initiating events.
The inspectors determined that this finding has a cross cutting aspect in the area of problem identification and resolution. Specifically, Entergy did not properly evaluate and classify the torus air temperature indication failures with respect to the maintenance rule. tP.1(c)]
(Section 4OA2.1 .c.(2))
REPORT DETAILS
4. OTHER ACTTVTTTES (OA)
4OA2 Problem ldentification and Resolution (711528)
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Proqram Effectiveness
a.
lnspection Scope The inspectors reviewed the procedures that described Entergy's corrective action program at Pilgrim Nuclear Power Station (PNPS). To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas:
problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and Entergy procedure EN-LI-102, "Corrective Action Process." For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple operational-focus, Station Advisory Review Board (SARB), and Condition Review Group (CRG) meetings. The inspectors selected items from the following functional areas for review: operations, engineering, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.
- (1) Effectiveness of Problem ldentification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as HPCI, emergency diesel generators (EDGs), and standby liquid control (SLC). Additionally, the inspectors reviewed a sample of condition reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Entergy entered conditions adverse to quality into their corrective action program as appropriate.
- (2) Effectiveness of Prioritization and Evaluation of lssues The inspectors reviewed the evaluation and prioritization of a sample of condition reports issued since the last NRC biennial Problem ldentification and Resolution inspection completed in February 2009. The inspectors also reviewed condition reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions The inspectors reviewed Entergy's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed condition reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Entergy's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of condition reports associated with selected NCVs and findings to verify that Entergy personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Entergy's actions related to HPCI system deficiencies.
b.
Assessment
- (1) Effectiveness of Problem ldentification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Entergy identified problems and entered them into the corrective action program at a low threshold. The inspectors observed managers and supervisors at the CRG appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Entergy trended equipment and programmatic issues, and appropriately identified problems in condition reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. The inspectors identified one example where ineffective problem identification contributed to a more than minor finding (section 4O42.1.c.(1)). ln response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Entergy personnel initiated condition reports and/or took action to address the issues prior to the inspection conclusion.
- (2) Effectiveness of Prioritization and Evaluation of lssues The inspectors determined that, in general, Entergy appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.
Entergy screened condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
Based on the sample of condition reports reviewed, the inspectors noted that the guidance provided by Entergy corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. The inspectors concluded the trending and evaluation of prior issues at a quarterly SARB meeting was criticaland thorough. However, the inspectors identified one example where ineffective prioritization and evaluation of issues contributed to a more than minor finding (section 4OA2.1.c.(2)).
- (3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Entergy identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective. The inspectors did identify an example of ineffective corrective actions:
A review of security section condition reports (CRs) over the past three years revealed over 100 CRs regarding security section challenges or inability to support the expected two positions on the five-person fire brigade. The majority of the CRs documented the inability for security to support the fire brigade manning, requiring the operations section to provide the full staffing. Entergy properly conducted an evaluation and established corrective actions. The inspectors identified that Entergy had performed three causal evaluations (CRs 2008-2439,2009-3383 , 2010-4336) with essentially the same corrective actions. The challenge continues to exist based on CRs and interviews which documented that corrective actions were not effective. The inspectors'concern is that there is a potential for the fire brigade to be understaffed if resources are not adequate.
Entergy continues to address this concern under apparent cause evaluation CR-PNP-2010-4336.
The inspectors independently evaluated this issue for significance in accordance with IMC 0612, Appendix B, "lssue Screening," and IMC 0612, Appendix E, "Examples of Minor lssues." Although there is an apparent jeopardy to fire brigade manning based on condition report reviews, the inspectors did not identify any occurrence where fire brigade was not adequately staffed, and therefore did not have a significant impact on plant operations. The inspectors consider this issue to be of minor significance, and, as a result, it is not subject to enforcement action in accordance with the NRC's Enforcement Policy.
c.
Findinqs
- (1) Failure to Follow Corrective Action Process for HPCI Diaphraqm Deqraded Condition
Introduction:
The NRC identified a finding of very low significance (Green) for Entergy's failure to follow their corrective action process in the identification, documentation, and evaluation of a degraded condition. Specifically, Entergy failed to recognize and capture in their condition report process that a diaphragm in the HPCI system exceeded its service life.
Description:
On March 22,2Q10, GE Hitachi issued a Safety Information Communication in conjunction with the 10 Code of Federal Regulations (CFR) Part21 Report titled, "Failure of HPCI Turbine Overspeed Reset ControlValve Diaphragm." The failure of this diaphragm would result in a loss of the HPCI turbine lube and control oil and could ultimately result in a failure of the HPCI system. Entergy identified that a 'like' diaphragm was installed in Pilgrim's HPCI system pressure controlvalve (PCV-2301-238) and evaluated the 10 CFR Part 21 Report on July 20, 2010 in CR-PNP-2010-2500.
Entergy concluded that the manufacturing defect in the diaphragm described in the Part 21 evaluation was not directly applicable to Pilgrim because the report specified a manufacturing year of 1984 or later. Pilgrim's PCV-2301-238 diaphragm was manufactured in 1981, however it was the same design (2-ply fabric-reinforced BUNA-N material) as specified in the Part2l evaluation. Since the diaphragm was installed and could not be completely inspected to verify reinforcing-fiber continuity, Entergy appropriately scheduled the diaphragm to be replaced during the next HPCI maintenance window, as recommended by the manufacture.
During review of this issue, the inspectors identified another degraded condition that Entergy documented in CR-PNP-2010-2500, specifically that the vendor specified this diaphragm design has a recommended service life of five years. The diaphragm currently installed in the HPCI system has been in service for seven years. This condition had not been identified or documented in a separate condition report, and therefore had not been evaluated in an operability evaluation or for additional corrective actions. In accordance with Entergy procedure EN-LI-102, "Corrective Action Process",
"A degraded condition is one in which the qualification of a system or component's functional capability is reduced. Examples of conditions that can reduce the capability of a system are aging, erosion, corrosion, improper operation, and maintenance." In addition, EN-LI-102, Section 5.2, "Condition Report Initiation" specifies the requirement to initiate a condition report for adverse conditions and Section 5.3 outlines the operability evaluation to be performed once the condition report has been initiated. The HPCI system was degraded due to the diaphragm exceeding its vendor recommended service life and warranted a condition report to address potential diaphragm aging effects.
Entergy entered this issue into their corrective action program as CR-PNP-2011-0917 and concluded that HPClwas still operable based on a material action request report, which evaluated operation of the pressure control valve diaphragm past its vendor-recommended service life. Entergy plans to replace the pressure control valve diaphragm during the next HPCI maintenance window in February 2012.
Analvsis: The performance deficiency is that Entergy did not identify and evaluate a condition adverse to quality in accordance with their Corrective Action Process. A review of NRC Inspection Manual Chapter (lMC) 0612, Appendix E, "Minor Examples,"
identified that the issue is similar to Example 4(a) in that Entergy did not perform an evaluation that was later determined to adversely affect safety-related equipment. In addition, it affected the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined the significance of the finding using IMC 0609.04, "Phase 1 -
lnitial Screening and Characterization of Findings." The finding was determined to be of very low safety significance (Green) because the finding involved a qualification deficiency not resulting in the loss of operability of HPCI.
l The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program because Entergy did not identify that exceeding the service life of the PCV-2301-238 diaphragm was a condition adverse to quality. P.1(a)
Enforcement:
Enforcement action does not apply because the performance deficiency did not involve a violation of regulatory requirements. Because this finding does not involve a violation, has very low safety significance, and Entergy entered this issue into the corrective action process for resolution (CR-PNP-2011-0917), it is identified as a finding. (FlN 0500029312011008-01, Failure to Follow Corrective Action Process for HPGI Diaphragm Degraded Gondition).
- (2) Torus Air Temperature 10 CFR 50.65(aX2) Performance Demonstration Not Met
Introduction.
The inspectors identified a Green NCV of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," paragraph (a)(2),for Entergy's failure to adequately demonstrate primary containment system (aX2)performance was effectively controlled through performance of appropriate preventive maintenance. Specifically, as evidenced by repeat functional failures of torus air temperature indication during the fall of 2009 and January 2010, the (a)(2) performance demonstration was no longer justified in accordance with Entergy's maintenance rule implementing procedure guidance.
Description.
The primary containment system is a safety-related, risk significant system that is scoped within the maintenance rule because it is a structure, system, or component required to mitigate accidents/transients, and components of this system are utilized in emergency operating procedures. Torus air temperature indication is part of the primary containment system as defined in Entergy's maintenance rule basis document. The primary maintenance rule function of the torus air temperature indication is to ensure that temperature during normal operations is maintained within the range of initial conditions assumed in Section 14 of the Final Safety Analysis Report. To this end, loss of torus temperature indication such that minimum technical specification requirements are not met is considered a maintenance rule functional failure of the system. Additionally, the performance criterion for the torus air temperature indication is not more than one functionalfailure in a two-year period. lf this criterion is exceeded, the station is required to evaluate the system for (aX1) classification per EN-DC-206, "Maintenance Rule (aX1) Process."
During the inspection, the inspectors identified three separate instances where failures of torus air temperature indication components were not properly evaluated under the maintenance rule. Entergy procedure EN-DC-205, "Maintenance Rule Monitoring,"
requires that failures of systems scoped into the maintenance rule program be evaluated for potential classification as a maintenance rule functional failure. The inspectors identified a condition report (CR-PNP-2009-04533) from October 2009 documenting that the temperature difference between the two torus air temperature monitoring trains exceeded the limit required by technical specifications and that operators declared the failed indication (TRU-9045) inoperable. Entergy did not perform a maintenance rule functionalfailure determination for this failure. The inspectors also identified a second condition report (CR-PNP-2009-05323) from December 2009 that documented another failure of the torus air temperature monitoring system because the recorder was I
oscillating. Even though the operators declared TRU-9045 inoperable, Entergy did not perform a functional failure determination for the indication.
The inspectors also reviewed a condition report (CR-PNP-2010-00080) from January 7, 2010, where the same torus air temperature indication failed downscale and the operators declared the indication inoperable. On this occasion, Entergy performed a maintenance rule functional failure determination and concluded that it met the criteria to be a functional failure since the minimum technical specification requirements for torus air temperature indication were not met. The station performed minor maintenance and a successful channel check on the indication and operators declared TRU-9045 operable on January 7,2010. On January 30,2010, Entergy wrote another condition report (CR-PNP-2010-00407), which described a condition where TRU-9045 failed downscale again. Operators declared the indication inoperable and the station performed another maintenance rule functional failure determination. However, Entergy concluded that the issue was not another maintenance rule functionalfailure, but rather a continuation of the same failure documented in CR-PNP-2010-00080. This was based on the determination that the system was in a post-work test window even though the indication remained operable from January 7,2010 until January 30, 2010.
The inspectors determined that the issues described in condition reports CR-PNP-2009-04533 and CR-PNP-2009-05323 should have been considered failures of the indication based on unreliable temperature indication and failure to meet the requirements for technical specification operability. Additionally, the inspectors concluded that both of these conditions, along with the failure described in CR-PNP-2O10-00407, should have been evaluated and classified as functionalfailures, similar to the issue described in CR-PNP-2010-00080. The inspectors further determined that repeat failures of the torus air temperature indication showed that Entergy was ineffectively monitoring and controlling the performance of this system such that the system's (a)(2) performance demonstration was no longer justified. Entergy documented this issue in condition report CR-PNP-201 1-00880.
Analvsis. The inspectors determined that failure to adequately demonstrate that torus air temperature indication (a)(2) performance was effectively controlled through performance of appropriate preventive maintenance was a performance deficiency within Entergy's ability to foresee and correct and should have been prevented. 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 objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failures of torus air temperature indication present a challenge to operators who rely on the indication to diagnose and respond to initiating events.
Per the guidance provided in Inspection Procedure 71111.12, "Maintenance Effectiveness," issued 11116120A9, inspectors considered this performance deficiency to be a Category lllfinding since a historical review revealed a continuing declining trend in performance of the instrument, as indicated by additional functional failures. Because this issue was classified as Category lll, the inspectors determined the significance of this finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined that this finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk significant due to external initiating events.
The inspectors determined that this finding has a cross cutting aspect in the area of problem identification and resolution. Specifically, Entergy did not properly evaluate and classify the torus air temperature indication failures with respect to the maintenance rule.
tP.1(c)l
Enforcement.
10 CFR 50.65(a)(1) requires, in part, that licensees shall monitor the performance or condition of systems, structures, and components within the scope of the monitoring program, as defined in 10 CFR 50.65(b), against licensee-established goals in a manner sufficient to provide reasonable assurance that the systems, structures and components are capable of fulfilling their intended safety functions. 10 CFR 50.65(a)(2)requires, in part, that monitoring as specified in paragraph (aX1) is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function. Contrary to the above, since January 2010, Entergy failed to demonstrate that the performance of the torus air temperature indication continued to be effectively controlled through the performance of appropriate preventive maintenance as evidenced by continued functional failures of the system. Entergy failed to properly evaluate these failures and, as a result, did not place the primary containment system under 10 CFR 50.65(a)(1) for establishing goals and monitoring against those goals. However, because this violation was of very low safety significance and Entergy has entered this issue into their corrective action program as condition report CR-PNP-2011-00880, the inspectors are treating this as a non-cited violation, consistent with the NRC Enforcement Policy. (NCV 05000293/2011008-01, Torus Air Temperature 10 CFR 50.65(a)(2) Performance Demonstration Not Met).
.2 Assessment of the Use of Operatinq Experience
Inspection Scope The inspectors reviewed a sample of condition reports associated with review of industry operating experience to determine whether Entergy appropriately evaluated the operating experience information for applicability to PNPS and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Entergy adequately considered the underlying problems associated with the issues for resolution via their corrective action program. ln addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
b. Assessment The inspectors determined that Entergy appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of operational focus and condition report review group meetings, and pre-job briefs.
c. Findinqs No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. lnspectors performed these reviews to determine if Entergy entered problems identified through these assessments into the corrective action program, when appropriate, and whether Entergy initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.
b. Assessment The inspectors concluded that self-assessments, audits, and other internal Entergy assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Entergy personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Entergy completed these audits and self-assessments to a sufficient depth to identify issues that were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
c. Findinos No findings were identified.
.4 Assessment of Safetv Conscious Work Environment
a. Inspection Scooe During interviews with station personnel, the inspectors assessed the safety conscious work environment (SCWE) at PNPS. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.
The inspectors reviewed the Employee Concerns Program files to ensure that Entergy entered issues into the corrective action program when appropriate.
b. Assessment During interviews, PNPS staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors 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 corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
c. Findinqs No findings were identified.
40A6 Meetinqs. lncludinq Exit On March 4, 2011, the inspectors presented the inspection results to Mr. Robert Smith, Site Vice President and other members of the PNPS staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT: SUPPLEMENTARY I NFORMATION SUPPLEMENTARY IN FORMATION KEY POINTS OF CONTACT Licensee Personnel S. Bethay Director, Nuclear Safety Assurance G. Becshan Plant Engineering D. Burke Security Manager K. Burke OE Coordinator B. Chenard System Engineering Manager G. Choquette System Engineer K. Cook ECP Coordinator W. Cook Supervisor, Balance of Plant Engineering J. Dreyfuss General Manger of Plan Operations V. Fallacara Engineering Director P. Harizi Senior Mechanical Engineer M. Landry Fire Marshal W. Lobo Licensing Engineer J. Lynch Licensing Manager K. Keyes CA&A Manager P. Kristian Maintenance Rule Program Coordinator J. MacDonald Assistant Operations Manager-Shift M. Mandefidl Plant Engineering M. McDonnell Assistant Operations Manager T. McElhinney Chemistry Manager K. McGilvery Non Licensed Operator C. McMoram Fire Brigade Leader R. Morris System Engineer D. Mortimer Senior Operations Specialist M. O'Meara Senior Engineer, System Engineering D. Noyes Operations Manager J. Priest Radiation Protection Manager R. Pierson Security Systems Supervisor S. Purdy Security Supervisor S. Reininghaus Training and Development Manager D. Rydman System Engineer J. Scheffer Chemistry Supervisor K. Sejkora Staff Chemist R. Smith Site Vice President J. Taormina Maintenance Manager M. Wilson EP Manager S. Wollman Supervisor, Balance of Plant Engineering NRC Personnel C. Cahill, Senior Reactor Analyst, Region I M. Schneider, Senior Resident Inspector, PNPS LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED Opened and Closed 05000293/201 1008-01 FlN Failure to Follow Corrective Action Process for HPCI Diaphragm Degraded Condition (Section 4042.1.c.(1))05000293/2011008-02 NCV Torus Air Temperature 10 CFR 50.65(aX2)
Performance Demonstration Not Met (Section 4oA2.1.c.(2))
LIST OF
DOCUMENTS REVIEWED
Section 4OM: Problem ldentification and Resolution
Audits and Self-Assessments
2009 - 2010 QA Audit Summaries
LO-PNPLO-2009-00008, CAP - Cause Analysis Assessment
LO-PNPLO-2009-00066, OE Self Assessment
LO-PNPLO-2009-00131, CR Due Date Extensions
LO-PN PLO -201 0-00021, Trending
LO-PNPLO-201 0-00029, Assessments
LO-PNPLO-2010-00065
LO-PNPLO-201 0-00096, Pre-Pl&R
LO-HQNLO -201 0-0023, OE Self Assessment
Condition Reports (* indicates that condition report was generafed as a result of fhis inspection)
cR-PNP-2004-02533 cR-PNP-2009-02516 CR-PNP-2010-00080
cR-PNP-2007-00201 cR-PNP-2009-02526 CR-PNP-2010-00103
cR-PNP-2007-01570 cR-PNP-2009-02530 cR-PNP-2010-00361
cR-PNP-2007-01783 cR-PNP-2009-02563 cR-PNP-2010-00407
cR-PNP-2007-04724 cR-PNP-2009-02578 cR-PNP-2010-00576
cR-PNP-2008-02439 cR-PNP-2009-02590 cR-PNP-2010-00595
cR-PNP-2008-02627 cR-PNP-2009-02967 cR-PNP-2010-00599
cR-PNP-2009-00043 cR-PNP-2009-03088 CR-PNP-2010-00617
cR-PNP-2009-00360 cR-PNP-2009-03383 CR-PNP-2010-00619
cR-PNP-2009-00502 cR-PNP-2009-03527 cR-PNP-2010-00966
cR-PNP-2009-00562 cR-PNP-2009-03535 cR-PNP-2010-00967
cR-PNP-2009-00620 cR-PNP-2009-04106 cR-PNP-2010-00968
cR-PNP-2009-00651 CR-PNP-2009-04167 CR-PNP-2010-01060
cR-PNP-2009-00862 cR-PNP-2009-04533 CR-PNP-2o10-01 143
cR-PNP-2009-00863 cR-PNP-2009-04630 cR-PNP-2010-01203
CR-PNP-2009-01488 CR-PNP-2009-04715 CR-PNP-2010-01250
cR-PNP-2009-01743 CR-PNP-2009-04752 CR-PNP-2010-01619
cR-PNP-2009-01920 cR-PNP-2009-04976 cR-PNP-2010-01632
cR-PNP-2009-02157 cR-PNP-2009-05323 CR-PNP-2010-01698
cR-PNP-2009-02502 GR-PNP-2010-00019 CR-PNP-2010-01738
I
I
CR-PNP-2010-01893 cR-PNP-2010-03264 CR-PNP-2011-00631
CR-PNP-2O10-02190 CR-PNP-2010-03423 CR-PNP-201 1-00657
cR-PNP-2010-02212 CR-PNP-2010-03440 CR-PNP-201 1-00670.
CR-PNP-2010-02313 cR-PNP-2010-04097 cR-PNP-2011-00685
cR-PNP-2010-02316 cR-PNP-2010-04102 CR-PNP-2011-00748
cR-PNP-2010-02500 cR-PNP-2010-04104 cR-PNP-201 1-00759
CR-PNP-2010-02594 CR-PNP-2010-04118 oR-PNP-2011-00767
CR-PNP-2010-02615 cR-PNP-2010-04267 cR-PNP-201 1-00788.
cR-PNP-2010-02698 cR-PNP-2010-04336 CR-PNP-201 1-00880.
cR-PNP-2010-02870 CR-PNP-2010-04466 cR-PNP-201 1-00889.
CR-PNP-2010-02935 cR-PNP-2010-04492 CR-PNP-201 1-00917.
cR-PNP-2010-02948 CR-PNP-2011-00086 CR-PNP-2011-00919
cR-PNP-2010-02993 CR-PNP-201 1-00205
oR-PNP-2010-03021 cR-PNP-201 1-00366.
Operating Experience
0 CFR Part 21 Communication, Failure of HPCITurbine Overspeed Reset ControlValve
Diaphragm, Hitachi
0 CFR Part 21 Communication -2010-37-00 - Reverse Polarity on HPCI Turbine EG-R
Hydraulic Actuators
RIS 2010-07 Regulatory Requirements for Application of Weld Overlays and Other Mitigation
Techniques in Piping Systems Approved for Leak-Before-Break
lN 2010-25, Inadequate Electrical Connections
lN 2010-12, Containment Liner Corrosion
lN 2008-02, Findings ldentified During Component Design Bases lnspections
lN 2008-09, Turbine-Driven Auxiliary Feedwater Pump Bearing lssues
lN 2008-11, Service Water System Degradation at Brunswick Steam Electric Plant Unit 1
lN 2009-02, Biodiesel in Fuel Oil Could Adversely lmpact Diesel Engine Performance
lN 2009-04, Age-Related Constant Support Degradation
lN 2007-28, Potential Common Cause Vulnerabilities in Essential Service Water Systems Due
to Inadequate Chemistry Controls
lN 2007-29, Temporary Scaffolding Affects Operability of Safety-Related Equipment
lN 2006-22, New Ultra-Low-Sulfur Diesel Fuel Oil Could Adversely lmpact Diesel Engine
Performance
NCVs and Findinqs
05-293/2009-002-01: Failure to Establish and Maintain Adequate Design Measures for EDG Air
Start System
05-29312009-002-02: Failure to lmplement Scaffolding Procedure Requirements
05-29312009-003-01: Refuel Bridge Mast Damage During Core Alterations
05-29312009-004-01: Failure to Include Security Diesel Generator into MRule
05-293/2009-004-02: RBCCW/ SSW Performance Test Procedure
05-29312009-004-03: Failure of the "A" Standby Liquid Control Train
05-29312009-004-04: Inadvertent HPCI lsolation During Surveillance Testing
05-293/2009-005-03: Inadequate Surveillance Procedure resulting in failed Standby Liquid
ControlTrain
05-29312009-007-01: Failure to Establish Adequate Procedures to Prevent Adverse lmpact due
to Spurious Valve Closure Caused by Fire Damage
05-29312009-403-01 : Potential PA Barrier Adequacy
05-293/2009-4Q2-02: Failure to Withdraw Unescorted Access
l
05-29312009-403-02: Unavailable OCA Tour
05-29312010-002-01: Loss of Secondary Containment - Torus Trough
05-29312010-002-02: EDG 'A" Snubber Valve Failure
05-29312010-003-01 : Maintenance of Underground Medium Voltage Cable
05-29312010-004-01: Failure to Manage a Yellow Risk Condition for an Unplanned Half Scram
05-29312010-005-01 : lnadequate Risk Assessment Process
05-29312010-005-02/03: Failure to Ensure Required QC Verifications were completed
05-293 l 201 0-4Q2-01 : Security Access Control lssues
05-29312010-403-01: Failure to ldentify Firearms During a PA Search
Licensee Event Reports
05-29312009-001: Target Rock Relief Valves' Test Pressure Exceeded Limit Due to Setpoint
Variance
05-2932009-002-00/01: Failure to Meet Technical Specification Requirement for Secondary
Containment
05-2932010-001: Single Train of Reactor Building Closed Cooling Water System Inoperable for
Time Period Exceeding Technical Specification
05-2932010-002: Standby Gas Treatment Declared Inoperable after Discovery of Open
Demister Door
05-2932010-003: Unintentional lntroduction of Contraband into the Protected Area
Cause Evaluations
PNP-2009-0031 PNP-2009-2502 PNP-2010-1079
PNP-2009-0069 PNP-2009-2804 PNP-2010-1562
PNP-2009-0732 PNp-2009-3298 PNP-2010-2291
PNP-2009-1086 PNP-2009-4129 PNP-2010-3423
PNP-2009-2083 PNP-2009-4976 PNP-2010-3635
Procedures
1.5.22, Risk Assessment Process, Revision 12
2.1.14, Station Power Changes, Revision 104
2.1.15, Pilgrim Nuclear Power Station Daily Surveillance Log, Revision 204
2.1.35, Control Room Readings, Revision 52
5.2.1, Earthquake Revisions 33 & 34
8.4.1, Standby Liquid Control Pump Quarterly and Biennial Capacity and Flow Rate Test,
Revision 73
8.9.1 , Emergency Diesel Generator and Associated Emergency Bus Surveillance, Revision 1 17
EN-DC-203, Maintenance Rule Program, Revision 1
EN-DC-204 Rev. 2
EN-DC-205, Maintenance Rule Monitoring, Revision 2EN-DC-206 Rev. 1
EN-DC-207 Rev. 2
EN-Ll-102, Revision 16, Corrective Action Process
EN-Ll-104, Revision 6, Self-Assessment and Benchmark Process
EN-Ll-121, Revision 8, Entergy Tending Process
EN-OE-100, Revision 1 1, Operating Experience Program,
EN-OP-1 04, Revision 4, Operability Determination Process
EN-QV-109, Revision 19, Audit Process EN-WM-100, Work Request (WR) Generation,
Screening, and Classification, Revision 5
EN-WM-101, On-Line Work Management Process, Revision 7
NOP83FP1, Revision 10, Fire Protection Plan
Station Procedure 8.5.2.10
Station Procedure 8.5.2.12
Station Procedure 8.5.2.1 5
Work Requests and Work Orders
211227 221599 MR 5108375 wR 186376
20479 52301426 wR 179017 wR 187241
ECP Proqram Review
EN-EC-100, Guidelines for lmplementation of the Employee Concerns Program, Rev. 5
EN-EC-100-01, Employee Concerns Coordinator Training Program, Rev. 0
lndependent Self-Assessment of PNPS ECP Program, October 2Q10
2009 Nuclear Safety Culture Assessment, Pilgrim Station
Effectiveness Review for 2009 NSCA Pilgrim Station, December 13,2010
Various ECP case files and corrective action summaries
Various ECP communication literatures
cR-PNP-2011-00670.
Miscellaneous
Calculation M-1276, "EDG X-107N8 Design Basis Thermal Operating Limits, Revision 0
CRG Summary Agenda Report dated 0211712011
Document Revision Notice DRN-1 1-001 10
Emergency Diesel Generator Design Basis Document, Revision 1
Emergency Plan Lessons Learned from November 2010 FEMA Graded Exercise
Fitness-for-Duty Program Annual Performance Data Report For the Period January 2010 -
December 2010
Graphs of turbine control valve position (0210312011 - 0210812011, 0510112007 - 0211612011)
HPCI Air Operated Valve Diaphragm MAR 03-0527lPurchase Order PS03-11685
HVAC Maintenance Rule 41 Action Plan
List of non-outage control room deficiencies
MAR 03-0673
NRC RIS 2007-001, Adherence to Licensed Thermal Power Limits, Revision 1
Operational Focus Meeting Agenda dated 0211712011
Pilgrim Control Room Log dated 0712312010 - 0713112010
Pilgrim Nuclear Power Station Plant Specific Technical Guidelines and Severe Accident
Technical Guidelines, Revision 7
Pilgrim Nuclear Power Station Technical Specifications
PNP CRG Summary Agenda Report 2l15l2Af
PNP CRG Summary Agenda Report 211712011
PNP Morning Report 2115111
Primary Containment Cooling System Reference Text, Revision 2
RHR Piping pressure and temperature monitoring data sheet
SRV Maintenance Rule A1 Action Plan SENG'APL-05-001
System Health Report - System 61, Emergency Diesel Generators and Fuel, Q4-2010
Tactical Range Qualification SECI-JPM-27 .2
TDBD-105, Revision 1, Design Basis.Document for Fire Protection/Appendix R Program
Work Screening Package 12202
LIST OF ACRONYMS
ADAMS Agency-wide Documents Access and Management System
CFR Code of Federal Regulations
CR Condition Report
CRG Condition Review Group
DRP Division of Reactor Projects
ECP Employee Concerns Program
EDG Emergency Diesel Generator
HPCI High Pressure Coolant Injection
IMC Inspection Manual Chapter
NCV Non-Cited Violation
NRC Nuclear Regulatory Commission
PARS Publicly Available Records System
Pl&R Problem ldentification and Resolution
PNPS Pilgrim Nuclear Power Station
RBCCW Reactor Building Closed Cooling Water
SCWE Safety Conscious Work Environment
SDP Significance Determination Process
SARB Station Advisory Review Board
SSC Structure, System or Component
TS Technical Specifications
WO Work Order
Attachment