IR 05000293/2011009
| ML111310008 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/13/2011 |
| From: | Doerflein L Engineering Region 1 Branch 2 |
| To: | Rich Smith Entergy Nuclear Operations |
| Shared Package | |
| ML111300168 | List: |
| References | |
| IR-11-009 | |
| Download: ML111310008 (26) | |
Text
UNITED STATES N UCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD KING OF PRUSSTA. PA 19406-1415 May 13, 2011 Mr. Robert G. Smith Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 PILGRIM NUCLEAR POWER STATION - NRC TEMPORARY INSTRUCTION 2515t183 TNSPECTlON REPORT 05000293/201 1009 Dear Mr.
On April 15,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS), using Temporary Instruction 2515/183, "Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection report documents the inspection results which were discussed on April 1 5,2011, with you and other members of your staff.
The objective of this inspection was to promptly assess the capabilities of Pilgrim to respond to extraordinary consequences similar to those that have recently occurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, along with the results from this inspection performed at other operating commercial nuclear plants in the United States will be used to evaluate the United States nuclear industry's readiness to safely respond to similar events. These results will also help the NRC to determine if additional regulatory actions are warranted.
All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process willfurther evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter.
R. Smith In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencyruide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.qovireadinq-rmiadams.html (the Public Electronic Reading Room).
Sincerely, b[^"t -r^-
Lawrence T. Doerflein, Chief Engineering Branch 2 Division of Reactor Safety Docket No.: 50-293 License No.: DPR-35
Enclosure:
Inspection Report No. 05000293/201 1009
REGION I Docket No.: 50-293 License No.: DPR-35 Report No.: 05000293/201 1009 Licensee: Entergy Nuclear Operations, lnc.
Facility: Pilgrim Nuclear Power Station (PNPS)
Location: 600 Rocky Hill Road Plymouth, MA 02360 lnspection Period: April 11 - 15,2011 Inspectors: J. Richmond, Senior Reactor Inspector, Division of Reactor Safety Approved By: Lawrence T. Doerflein, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
lR 0500029312011009; 0411112011 - 0411512011; Pilgrim Nuclear Power Station; Temporary lnstruction 25151183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.
This report covers an announced Temporary lnstruction (Tl) inspection. The inspection was conducted by a senior region based inspector. 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.
INSPECTION SCOPE
The intent of the Tl is to provide a broad overview of the industry's preparedness for events that may exceed the current design basis for a plant. The focus of the Tl was on
- (1) assessing the licensee's capability to mitigate consequences from large fires or explosions on site,
- (2) assessing the licensee's capability to mitigate station blackout (SBO) conditions,
- (3) assessing the licensee's capability to mitigate internal and external flooding events accounted for by the station's design, and
- (4) assessing the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. lf necessary, a more specific followup inspection will be performed at a later date.
INSPECTION RESULTS
All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report.
03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section 8.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection Procedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. lf lP 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:
Licensee Action Describe what the licensee did to test or inspect equipment.
Verify through test or Entergy performed equipment inspections, inventory of necessary tools and materials, and an inspection that operational test of a portable diesel powered pump to verify B.S.b equipment readiness and equipment is available ensure that the equipment was available and functional. Entergy walked down equipment storage and functional. Active and staging locations to verify the adequacy of the required inventories. In addition, implementing equipment shall be procedure walkdowns were performed to verify that necessary equipment, tools, and materials tested and passive specified for use within the procedures were available.
equipment shall be walked down and inspected. lt is not Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed expected that test results, discussed actions, reviewed records, etc.).
permanently installed equipment that is tested under an existing The inspector evaluated the adequacy of installed and portable equipment staged explicitly for regulatory testing implementation of the mitigation strategies. The types of equipment examined included: interior program be retested.
fire water supply piping and hose stations; portable pump and associated suction and discharge hoses, adapters, and tools; portable DC power supplies; portable radios and communications This review should be devices; and equipment lockers and associated tools. The inspector's review included field done for a reasonable verification and inventory checks of standby and staged equipment, and compatibility of the sample of mitigating portable equipment with installed systems. In addition, the inspector evaluated the staging and strateg ies/eq uipment.
storage locations of B.5.b related equipment to ensure the survivability and availability of equipment. The inspector also reviewed test results of the portable diesel powered pump. The inspector observed a walk-throuqh demonstration of selected mitioatino strateoies to independently evaluate the adequacy and functionality of the available equipment, and interviewed licensed and non-licensed operators to further assess equipment functionality.
Discuss general results including corrective actions by licensee.
Entergy did not identify any deficiencies of significance as part of their equipment checks. Entergy identified several minor issues which they entered into their correction action program.
One minor deficiency was identified by the inspector. The portable DC power supplies consisted of a 12 volt lead acid battery and a DC to DC converter. Based on a previous NRC observation, CR-PNP-2O1 1-00341 documented a corrective action to create a preventive maintenance task for the battery. During this inspection, Entergy added an additional action to evaluate the addition of a functional test for the battery and DC to DC converter. The inspector determined this was a minor issue because there was a reasonable expectation of functionality for the portable DC power supplies based on battery voltage checks performed during the inspection period and pre-installation checks performed on the DC to DC converters. The inspector verified these checks by direct observation and interview. Entergy entered this issue into their corrective action program as CA-24 to CR-PN P -201 I -00341 .
Based on the results of the reviews, walkdowns, and interviews described above, the inspector concluded that the required equipment was available and functional.
Describe the licensee's actions to verify that procedures are in place and can be executed (e.g.
Licensee Action walkdowns, demonstrations, tests, etc.)
b. Verify through Entergy validated procedure adequacy by using operators or engineers to perform 8.5.b walkdowns or procedure reviews and walkdown demonstrations of selected 8.5.b procedures. In addition, demonstration that selected procedures were actually performed to verify both equipment readiness and procedure procedures to implement adequacy, such as equipment inventory and inspection, emergency alarms and radios testing, and the strategies associated portable pump functional testing. The B.5.b and severe accident management guideline (SAMG)with 8.5.b and 10 CFR procedures were verified current and staged in the appropriate locations.
50.54(hh) are in place and are executable.
Licensees may choose Describe inspector actions and the sample strategies reviewed. Assess whether procedures were not to connect or in place and could be used as intended.
operate permanently installed equipment during this verification. The inspector independently evaluated selected Entergy B.5.b mitigating strategy implementing procedures to verify procedure adequacy. ln addition, the inspector reviewed the interface or This review should be transition between the Emergency Operating Procedures (EOPs), off-normal procedures, and the done for a reasonable mitigating strategy procedures. The inspector performed walkdowns with licensed and non-sample of mitigating licensed operators and other Entergy staff to assess: the adequacy and completeness of the strateg ies/eq uipment.
procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.
As a result of the NRC inspection, one finding of very low safety significance was identified, involving procedural deficiencies that challenged a spent fuel pool cooling strategy. Entergy entered this issue into their corrective action program as CR-PNP-2011-01505 and CR-PNP 2011-01075 CA-24. Details on this finding will be documented in Pilgrim Inspection Report 05000293/201 101 1 .
Discuss general results including corrective actions by licensee.
Entergy did not identify any deficiencies of significance as part of their check to verify that procedures were in-place and executable. Entergy identified several minor issues which they entered into their correction action proqram.
Entergy immediately evaluated the NRC identified finding, briefed operations personnel, and, based on the updated briefing information, verified the strategies could be reasonably implemented within the credited time limits. The inspector reviewed Entergy's immediate and proposed actions, including their assessment and prioritization, and concluded they were reasonable.
Based on the results of the reviews and walkdowns described above, with the exception of one finding to be documented in a separate report, the inspector determined that the procedures to implement the strategies associated with 8.5.b and 10 CFR 50.54(hh) were in place and were executable.
Describe the licensee's actions and conclusions regarding training and qualifications of operators Licensee Action and support staff.
Verify the training and Entergy audited training records for operations, security, fire fighters, engineering, and emergency qualifications of response organization (ERO) personnel to verify that all staff members within a designated group operators and the were current with their initial and requalification training requirements. ln addition, Entergy also support staff needed to verified that there was a sufficient number of trained personnel on-site and on each operating shift implement the to implement the severe accident management guidelines. Entergy also verified that off-site local procedures and work fire department members were current in their training.
instructions are current for activities related to Security Order Section Describe inspector actions and the sample strategies reviewed to assess training and B.5.b and severe qualifications of operators and support staff.
accident management guidelines as required by 10 cFR 50.54 (hh).
The inspector interviewed selected licensed and non-licensed operators, and non-operations plant staff to evaluate the adequacy of their training and the completeness of Entergy's training audit. In addition, the inspector interviewed a licensed operator simulator instructor regarding simulator and job performance measure training scope and schedules.
Discuss general results including corrective actions by licensee.
Entergy did not identify any training deficiencies of significance.
Based on the inspecto/s review of formal training, interviews, and observations of plant staff during walkdowns of mitigating strategies in the field, the inspector concluded that the overall B.5.b training was appropriate and consistent with industry guidelines.
Describe the licensee's actions and conclusions regarding applicable agreements and contracts Licensee Action are in place.
d. Verify that any Entergy verified the agreements with off-site localfire departments were in place and active. In applicable agreements addition, Entergy also verified that required off-site equipment was available.
and contracts are in place and are capable of meeting the conditions For a sample of mitigating strategies involving contracts or agreements with offsite entities, needed to mitigate the describe inspector actions to confirm agreements and contracts are in place and current (e.9.,
consequences of these confirm that offsite fire assistance agreement is in place and current).
events.
This review should be The inspector verified through interviews with plant staff that necessary agreements were in-place done for a reasonable and current with off-site flre departments, and that equipment which was expected to be available sample of mitigating to implement the mitigating strategies was, in fact, available.
strategies/eq uipment.
Discuss general results including corrective actions by licensee.
Entergy did not identify any deficiencies of significance.
The inspector concluded that sufficient agreements and contracts were in place and capable of meeting the conditions necessary to mitigate the consequences of 8.5.b events, as required by Entergy's licensing and design basis.
Document the corrective action report number and briefly summarize problems noted by the Licensee Action licensee that have significant potential to prevent the success of any existing mitigating strategy.
e. Review any open The inspector reviewed numerous corrective action documents during this inspection, which are corrective action listed in the Attachment to this report. In addition, NRC Resident Inspectors conduct daily reviews documents to assess of newly issued condition reports. The NRC Senior Resident Inspector and the NRC Tl-183 problems with mitigating inspector discussed whether potential deficiencies, identified within Entergy's corrective action strategy implementation program, could result in a significant adverse impact to mitigating strategy implementation. In identified by the addition, the inspector reviewed all condition reports identified by Entergy during their recent self licensee. Assess the assessments of B.5.b mitigating strategies. The inspector evaluated Entergy's immediate impact of the problem on corrective actions for the associated condition reports, and concluded that the actions appeared to the mitigating capability be reasonable.
and the remaining capability that is not As discussed above in section 03.01.b, the inspector identified one finding of very low safety impacted.
significance. No other significant impacts were identified.
03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline. lt is not intended that Tl 25151120 be completely reinspected.
The inspection should include, but not be limited to, an assessment of any licensee actions to:
Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO Licensee Action event.
a. Verify through Entergy conducted walkdowns of the SBO diesel generator (DG), SBO control stations, walkdowns and associated switchgear, and related equipment to verify the equipment was adequate and properly inspection that all staged. Entergy also reviewed associated procedures to identify any necessary temporary required materials are equipment, and verified that such items were available and pre-staged.
adequate and properly staged, tested, and maintained.
Describe inspector actions to verify equipment is available and useable.
The inspector independently walked down the SBO DG, control stations, associated switchgear, and station batteries to independently verify material conditions and equipment readiness. The walkdowns were conducted with licensed and non-licensed operators, an electrical design engineer, and the responsible system engineer. The inspector also interviewed operations and engineering personnel regarding typicalfunctional test results and reviewed selected test results to further assess equipment availability and readiness. In addition, the inspector reviewed DC system design calculations to verify that the station battery capacity discharge test acceptance criteria included necessary SBO loads and load durations.
Discuss general results including corrective actions by licensee.
Entergy did not identify any deficiencies of significance as part of their equipment checks.
One minor deficiency was identified by the inspector. Entergy had not implemented industry standard or vendor recommendations for battery performance discharge testing on the SBO switchgear 125 volt battery since initial installation to 2005. The inspector determined this was a minor issue because there was a reasonable expectation of functionality for the battery because a factory acceptance test discharge had been performed on 11122105 prior to initial installation, float current was checked weekly, and individual cell voltages and intercell terminations were checked quarterly. IEEE 1106-2005, "Recommended Practice for Installation, Maintenance, Testing, and Replacement of Vented Nickel-Cadmium Batteries for Stationary Applications," recommended a performance test discharge within the first two years of service and every five years thereafter.
The vendor service life for this battery was 20 years, and the factory acceptance test satisfied the IEEE recommendations. Since a performance test was only a few months overdue, and in this instance, the battery was within the first six years of a 2O year service life, and did not have any identified degraded trends, the inspector concluded that a performance test would be reasonably expected to pass. The inspector walked down the battery to independently verify material condition, reviewed the results from the last four quarterly battery checks and the factory acceptance test results, and interviewed the system engineer to assess battery performance trends. Entergy entered this issue into their corrective action program as CR-PNP-2011-01548 and CR-PNP-2011 -01 075 CA-17 .
The inspector identified a beyond design basis and beyond licensing basis vulnerability, in that the SBO DG cooling radiator is potentially susceptible to damage from high wind generated flying debris. Entergy entered this issue into their corrective action program as CR-PNP-201 1-01503 and CR-PNP-2011 -01 075 CA-1 1 .
The inspector identified a beyond design basis and beyond licensing basis vulnerability, in that the SBO DG switchgear battery was not restrained within a battery rack and was potentially susceptible to movement during a seismic event. Entergy entered this issue into their corrective action program as CR-PNP-2011-01551 and CR-PNP-2011-01075 CA-18.
Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.
Demonstrate through Entergy performed table top demonstration reviews and walkdowns of procedures required for walkdowns that response to a SBO event to verify that the procedures were executable. ln addition, Entergy also procedures for response verified that licensed operator training included appropriate training tasks for SBO activities in to an SBO are initial and requalification training.
executable.
Describe inspector actions to assess whether procedures were in place and could be used as intended.
The inspector reviewed SBO related procedures, including DC load shedding procedures, and observed a table top demonstration of plant response to an SBO (e.9., SBO DG starting and loading) performed by licensed operators. The inspectofs review also included licensed operator job performance measures for local and remote start and operation of the SBO DG. In addition, the inspector interviewed a licensed operator simulator instructor and reviewed crew critical task time results for simulator scenarios to independently verify that the SBO DG could be started and loaded within the design basis time of 10 minutes.
Discuss general results including corrective actions by licensee.
Entergy did not identify any deficiencies of significance.
Based on the results of the reviews, walkdowns, and interviews described above, the inspector found the procedures for an SBO were executable.
03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design. Refer to lP 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.
Describe the licensee's actions to verify the capability to mitigate existing design basis flooding Licensee Action events.
a. Verify through Entergy walked down and inspected accessible flood protection barriers, penetration seals, and walkdowns and room or sump high level alarm instruments that were credited or relied upon to mitigate internal inspection that all and external flooding events. The walkdowns and inspections included breakwaters, jetties, and required materials are revetments. In addition, Entergy reviewed procedures used to prepare for severe weather or adequate and properly inspect plant structures post severe weather.
staged, tested, and maintained.
Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.
The inspector walked down selected plant areas to independently assess the adequacy of flood protection barriers. The walkdown was conducted with a structural engineer and utilized a structural monitoring surveillance procedure table which listed flood barriers routinely inspected.
Selected plant areas included reactor building emergency core cooling system (ECCS) pump rooms, reactor core isolation cooling (RCIC) room, and control rod drive (CRD) room; turbine building 4kV switchgear and battery rooms; EDG rooms; intake structure, including service water pump rooms, and diesel driven fire water pump room; and the SBO DG enclosures.
Discuss general results including corrective actions by licensee.
Entergy did not identify any deficiencies of significance.
The inspector identified one minor deficiency, in that piping penetrations between the torus room and ECCS rooms, which were credited flood barriers, had not been included in Entergy's flood barrier structural monitoring surveillances. Entergy performed an initial review which determined that all of the pipe penetrations were equipped with water tight seal assemblies and that previous inspection of similar seals in other plant areas had not identified any significant degraded trends.
Entergy entered this issue into their corrective action program as CR-PNP-2011-01530 and CR-PNP-2011-01075 CA-20. The inspector reviewed the condition reports, and determined that Entergy's initial responses, including their assessment and prioritization, were appropriate.
Based on the results of the reviews and walkdowns described above, the inspector concluded that Entergy's capabilities to mitigate internal and externalflood events adequately satisfied design basis requirements. On a sampling basis, the inspector also verified that accessible doors, barriers, and penetration seals were functional.
03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assess the licensee's development of any new mitigating strategies for identified vulnerabilities (e.9., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use lP 71111.21, "Component Design Basis lnspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the licensee's walkdowns and inspections.
Describe the licensee's actions to assess the potential impact of seismic events on the availability Licensee Action of equipment used in fire and flooding mitigation strategies.
Verify through Entergy identified equipment utilized or required for mitigation of fire and flood events, including walkdowns that all both permanent and temporary equipment, conducted walkdowns, and documented the results.
required materials are Prior to the walkdowns, guidelines were established to govern the conduct of walkdowns and adequate and properly inspections. Entergy determined whether the system, structure, and component (SSC) was staged, tested, and seismically qualified or seismically rugged. For non-seismically rugged SSCs, Entergy evaluated maintained.
whether a mitigating strategy was needed to perform the function after a safe shutdown earthquake.
Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.
The inspector reviewed the scope of Entergy's walkdowns, and the results of Entergy's inspections and assessments to evaluate the thoroughness of Entergy's actions. The inspector walked down selected risk significant plant areas to independently assess beyond design basis seismic vulnerabilities to equipment needed to mitigate fire and flood events. This equipment included, but was not limited to:
.
8.5.b contingency response equipment; o portions of the installed fire protection and suppression equipment in various plant areas;
.
diesel and electric fire pumps and their controls; and e watertight doors, roof hatches and floor plugs at the plant's intake structure.
Based on the results of the reviews and walkdowns described above, the inspector concluded that Entergy satisfied the current licensing and design bases for B.5.b, fire protection, and flooding.
Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.
Entergy did not identify any deficiencies of significance.
The inspector concluded Entergy's reviews were comprehensive. The inspector noted that the majority of the flood protection SSCs were either seismically rugged or seismically qualified. In reviewing these beyond design basis seismic interactions with fire or flood mitigation SSCs, Entergy identified several potential enhancements that could improve fire fighting capabilities following an earthquake. The identified seismic vulnerabilities, including storage locations and fire headers, were entered into the corrective action program. Resolution and/or mitigating strategies for the identified vulnerabilities were under evaluation.
Meetinqs 4OAO Exit Meetinq The inspector presented the inspection results to Mr. R. Smith and other members of Entergy management at the conclusion of the inspection on April 15,2011. The inspectors asked Entergy whether any materials examined during the inspection should be considered proprietary. The inspectors confirmed that any proprietary information was returned to the licensee.
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SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Enterqv Personnel
Pace, Supervisor Mechanical Design
Doody, Mechanical Design Engineer
McDonnell, Assistant Operations Manager
Macdonald, Assistant Operations Manager-Shift
Lynch, Site Licensing Manager
Noyes, Operations Manager
Bracken, Senior Reactor Operator
Fratassio, Senior Reactor Operator
Berkland, Electrical Design Engineer
Ahern, System Engineer
Burke, Fire Protection Engineer
Berne, Licensing Engineer
NRC Personnel
- C. Cahill, Senior Reactor Analyst, Division of Reactor Safety
- W. Cook, Senior Reactor Analyst, Division of Reactor Safety
Commonwealth of Massachusetts (Observers)
John Giarrusso, Jr., Planning and Preparedness Division Manager, Massachusetts
Suzanne Condon, Associate Commissioner, Department of Public Health, Massachusetts