Text

IR 05000293-12-002; Entergy Nuclear Operations, Inc; 01/01/2012 - 03/31/2012; Pilgrim Nuclear Power Station, Maintenance Effectiveness and NRC Integrated Inspection Report
	ML12116A289
Person / Time
Site:	Pilgrim
Issue date:	04/25/2012
From:	Bellamy R; NRC/RGN-I/DRP/PB5
To:	Rich Smith; Entergy Nuclear Operations
References
	IR-12-002
	Download: ML12116A289 (33)
	v • d • e

UNITED STATES ril 25, 2012

SUBJECT:

PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2012002

Dear Mr. Smith:

On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents the inspection results, which were discussed on April 25, 2012 with you and other members of your staff.

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

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one NRC-identified finding of very low safety significance (Green). This finding was determined to be a violation of NRC requirements. However, because of its very low safety significance, and because it has been entered into your corrective action program (CAP), the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the non-cited violation in this report, you should provide a written 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 copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at PNPS. In 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 I, 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 NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ronald R. Bellamy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 50-293 License Nos.: DPR-35

Enclosure:

Inspection Report 05000293/2012002 w/Attachment: Supplemental Information

REGION I==

Docket Nos.: 50-293 License Nos.: DPR-35 Report No.: 05000293/2012002 Licensee: Entergy Nuclear Operations, Inc.

Facility: Pilgrim Nuclear Power Station (PNPS)

Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: January 1, 2012 through March 31, 2012 Inspectors: M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP)

B. Smith, Resident Inspector, DRP T. Setzer, Senior Project Engineer, DRP K. Dunham, Nuclear Safety Professional Development Program, DRP T. Moslak, Health Physicist, Division of Reactor Safety (DRS)

Approved By: Ronald R. Bellamy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

TABLE OF CONTENTS 1. REACTOR SAFETY .............................................................................................................. 4 1R01 Adverse Weather Protection ...................................................................................... 4 1R04 Equipment Alignment ................................................................................................. 4 1R05 Fire Protection ........................................................................................................... 5 1R07 Heat Sink Performance .............................................................................................. 6 1R11 Licensed Operator Requalification Program .............................................................. 6 1R12 Maintenance Effectiveness ........................................................................................ 7 1R13 Maintenance Risk Assessments and Emergent Work Control .................................. 9 1R15 Operability Determinations and Functionality Assessments .................................... 10 1R18 Plant Modifications ................................................................................................... 10 1R19 Post-Maintenance Testing ....................................................................................... 11 1R22 Surveillance Testing ................................................................................................ 12 1EP6 Drill Evaluation ......................................................................................................... 12 2. RADIATION SAFETY (RS) .................................................................................................. 13 2RS01 Radioactive Hazard Assessment and Exposure Controls ..................................... 13 2RS02 Occupational ALARA Planning and Controls ........................................................ 15 4. OTHER ACTIVITIES ............................................................................................................ 16 4OA1 Performance Indicator (PI) Verification .................................................................... 16 4OA2 Identification and Resolution of Problems ............................................................. 17 4OA3 Follow-Up of Events and Notices of Enforcement Discretion .................................. 17 4OA6 Meetings, Including Exit ........................................................................................... 19 ATTACHMENT: SUPPLEMENTARY INFORMATION................................................................ 19 SUPPLEMENTARY INFORMATION ........................................................................................ A-1 KEY POINTS OF CONTACT .................................................................................................... A-1 LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ..................................... A-1 LIST OF DOCUMENTS REVIEWED ........................................................................................ A-2 LIST OF ACRONYMS ............................................................................................................. A-11 Enclosure

SUMMARY OF FINDINGS

IR 05000293/2012002; 01/01/2012 - 03/31/2012; Pilgrim Nuclear Power Station; Maintenance

Effectiveness.

This report covered a three-month period of inspection by the resident inspectors and announced inspections performed by regional inspectors. The inspectors identified one finding of very low safety significance (Green), which was a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect for the finding was determined using IMC 0310, Components Within the Cross-Cutting Areas.

Findings for which the SDP does not apply may be Green, or may be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified an NCV of very low safety significance (Green) of 10 CFR Part 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," because Entergy did not include the Rod Worth Minimizer (RWM) system into the scope of Maintenance Rule (MR) systems. Specifically, Entergy did not include the RWM system into the scope of the MR monitoring program as required by 10 CFR 50.65 (b)(2)(i) as a non-safety related system that is relied upon to mitigate accidents or transients. Entergy entered this issue in the corrective action program (CR-PNP-2012-0394).

The inspectors performed a review of IMC 0612, Appendix E, Examples of Minor Issues, and determined the issue was more than minor because it was similar to example 7.d; in that, the RWM system was not within the scope of the Maintenance Rule and that equipment performance problems were such that effective control of performance could not be demonstrated. The finding was also determined to be more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the availability of the RWM to provide its mitigation function for a control rod drop accident (CRDA). This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Self Assessment component, because previous assessments performed by Entergy did not include Maintenance Rule scoping attributes nor did they identify scoping issues such as the RWM system. P.3(a) (Section 1R12)

REPORT DETAILS

Summary of Plant Status

Pilgrim Nuclear Power Station began the inspection period during a power ascension to 100 percent reactor power following a December 2011 forced outage. On January 1, Pilgrim returned to 100 percent reactor power. On February 23, operators reduced reactor power to 47 percent to perform a thermal backwash of the main condenser and to perform repairs on main steam isolation valve 2B. On February 24, Pilgrim returned to 100 percent reactor power. On February 25, operators reduced power to 90 percent to perform a control rod pattern adjustment. Pilgrim returned to 100 percent reactor power later that same day. On March 14, operators reduced power to 65 percent to perform deep and shallow control rod testing, and a subsequent control rod pattern adjustment. Pilgrim returned to 100 percent reactor power later that same day and operated at or near 100 percent reactor power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

Readiness for an Impending Storm

a. Inspection Scope

The inspectors performed a review of Pilgrims readiness for an impending storm on January 12. The review focused on the stations emergency diesel generators, condensate storage tank, and the intake structure. The inspectors reviewed station procedures including Pilgrims coastal storm and hurricane procedures. The inspectors performed walkdowns of the selected systems to ensure that station personnel had identified issues that could challenge the operability of the systems during high wind conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

Main article: IP 71111.04Q

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

B emergency diesel generator with a temporary modification installed on the 24 VDC power supply

K-110 air compressor with a degraded condition on the K-111 and K-117 air compressors

Salt service water (SSW) pumps C, D, and E during A SSW LOOP testing.

The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications (TS), work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance or their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify that system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Entergy had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Complete System Walkdown

Main article: IP 71111.04S

a. Inspection Scope

On January 23 and 24, the inspectors performed a complete system walkdown of accessible portions of the reactor core isolation cooling system to verify the line-up was correct. The inspectors reviewed operating procedures, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, equipment cooling, and hanger and support functionality. The inspectors performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Entergy appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified.

1R05 Fire Protection

Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Entergy controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection identification and suppression equipment was available for use as specified in the area pre-fire plan, and that passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out-of-service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

Fire Area 1.9, Fire Zone 1.20, Refueling Floor

Fire Area 1.10, Fire Zone 1.10, Reactor Core Isolation Cooling Pump Quadrant

Fire Area 1.10, Fire Zone 1.10B, B Residual Heat Removal & High Pressure Coolant Injection Pipe Room

Fire Area 1.10, Fire Zone 1.28, Reactor Recirculation Pump Motor Generator Sets Room

Fire Area 1.10, Fire Zone 4.1, B Train Diesel Generator Room

b. Findings

No findings were identified.

1R07 Heat Sink Performance (711111.07A - 1 sample)

a. Inspection Scope

The inspectors reviewed one sample of Entergys 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 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 A Turbine Building Component Cooling Water Heat Exchanger was selected for detailed review by the inspectors.

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12Q

a. Inspection Scope

The inspectors reviewed the 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 paragraphs (a)(1) or (a)(2); and (8)appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as paragraph (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as paragraph (a)(1).

B Emergency Diesel Generator Kilowatt Swings

Neutron Monitoring System

Rod Worth Minimizer

b. Findings

Introduction.

The inspectors identified an NCV of very low safety significance (Green)of 10 CFR Part 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," because Entergy did not include the RWM system into the scope of MR systems. Specifically, Entergy did not include the RWM system into the scope of the MR monitoring program as required by 10 CFR 50.65 (b)(2)(i) as a non-safety related system that is relied upon to mitigate accidents or transients.

Description.

During low power operations, Pilgrims RWM enforces specific control rod sequences designed to mitigate the consequences of the CRDA by providing control rod blocks to the reactor manual control system. Per Pilgrims Technical Specification (TS)

Basis document, the RWM enforces the banked position withdrawal sequence below 20 percent reactor thermal power to ensure enthalpy addition due to a potential CRDA does not exceed 280 cal/gm, which is the threshold for fuel damage. Furthermore, Pilgrims Final Safety Analysis Report (FSAR), Section 14.5, Postulated Design Basis Accidents, assumes the reactor is to be at a control rod pattern corresponding to the maximum incremental worth. It credits a functional RWM in this assumption. The inspectors identified, however, that the RWM was not included within the scope of the MR at Pilgrim. The inspectors also reviewed previous MR assessments, including the prior cycle 10 CFR 50.65 paragraph a(3) assessment, and identified that the evaluation of MR scoping was not an attribute included in these assessments. Additionally, the RWM has had a history of extended unavailability from June to December 2011 and January to March 2012. This history of equipment unavailability does not show effective system performance or condition monitoring through appropriate preventive maintenance activities. Entergy generated CR-PNP-2012-0394 to identify that the RWM system is not scoped in the MR under the consideration of non-safety related systems relied upon to mitigate accidents or transients, utilizing procedure EN-DC-204, Maintenance Rule Scope and Basis.

Analysis.

The inspectors identified a performance deficiency in that Entergy personnel did not recognize the need to include the RWM system in the MR when it was credited to mitigate the consequences of a CRDA. Traditional enforcement does not apply since there were no actual safety consequences, impacts on the NRCs ability to perform its regulatory function, or willful aspects of the finding. The inspectors performed a review of IMC 0612, Appendix E, Examples of Minor Issues, and determined the issue was more than minor because it was similar to example 7.d; in that, the RWM system was not within the scope of the Maintenance Rule and that equipment performance problems were such that effective control of performance could not be demonstrated. The finding was also determined to be more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the availability of the RWM to provide its mitigation function for a CRDA.

The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency that did not result in loss of operability, did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its TS allowed outage time, did not represent an actual loss of safety function of one or more non-technical specification trains of equipment designated as risk significant per 10 CFR 50.65, and did not screen as risk significant due to a seismic, flooding, or severe weather initiating event.

This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Self Assessment component, because previous assessments performed by Entergy did not include MR scoping attributes nor did they identify scoping issues such as the RWM system. P.3(a)

Enforcement.

10 CFR Part 50.65, Requirements for Monitoring the Effectiveness of Maintenance of Nuclear Power Plants," requires, in part, that the scope of the monitoring program include non-safety related structures, systems, or components that are relied upon to mitigate accidents or transients. Contrary to the above, Entergy did not scope the RWMs function to mitigate a CRDA into the Maintenance Rule.

Entergys corrective actions included evaluating the RWM for inclusion into the Reactor Manual Control System Maintenance Rule Basis Document. Because this finding is of very low safety significance, and Entergy has entered it into their corrective action program (CR-PNP-2012-0394), this violation is being treated as an NCV, consistent with the NRCs Enforcement Policy. (NCV 05000293/2012002*01, Failure to Scope the Rod Worth Minimizer into the Maintenance Rule)

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Entergy performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Entergy personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Entergy performed emergent work, the inspectors verified that Operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst and Operations personnel to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Emergent Orange Risk with both the Station Blackout Diesel Generator and the B Emergency Diesel Generator Unavailable

Green Risk during Planned Condensate Storage Tank Surveillance Testing with Increased Trip Risk

Green Risk for the Shutdown Transformer being fed from Line 71 and MSIV 2B DC solenoid out-of-service

Green Risk due to a Degraded Power Supply to the Shutdown Transformer

Qualitative Yellow Risk Associated with Removing Both Trains of the Standby Gas Treatment System

Yellow Risk for Analog Trip System Testing

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

Drywell to Torus differential pressure could not be established while performing Vacuum Breaker Operability Test

High Pressure Coolant Injection Room Coolers powered off the same AC electrical bus

Reactor Core Isolation Cooling System Pre-Alarm Low Set Point Actuation

Reactor Core Isolation Cooling Steam Supply Drain Valve and/or Strainer not Functioning Properly

Station Blackout Diesel Generator Breaker Failure to Open The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to Entergy evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Entergy. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedures to verify that the procedures adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

B Emergency Diesel Generator KW Swings and Troubleshooting

Main Steam Safety Relief Valve SV-203-3D Replacement

Motor Replacement and Testing for the Residual Heat Removal A Pump

Repairs to the Rod Worth Minimizer

Replacement of the DC Coil on the Solenoid to the Main Steam Isolation Valve AO-203-2B

Replacement of the B Emergency Diesel Generator Motor Operated Potentiometer

Station Blackout Emergency Diesel Generator Troubleshooting

Troubleshooting and Repair of a 125VDC Ground on the B Emergency Diesel Generator

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant structures, systems, and components (SSCs) to assess whether test results satisfied TS, the UFSAR, and Entergys procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests.

B and D Residual Heat Removal Pump Quarterly In-service Testing (IST)

Emergency Diesel Generator A Initiation by Core Spray Logic

Main Steam Containment Isolation Valve (CIV) Operability Test

Reactor Coolant System (RCS) Leakage Detection Surveillance

Reactor Core Isolation Cooling Valve IST

Station Blackout Diesel Generator Surveillance

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness)

1EP6 Drill Evaluation

Main article: IP 71114.06

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of an emergency drill on February 29 to identify any weaknesses and deficiencies in the classification and notification of emergency action levels. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification and notifications were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Entergy staff in order to evaluate Entergys critique and to verify whether Entergys staff was properly identifying weaknesses and entering them into the corrective action program.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Occupational and Public Radiation Safety

2RS0 1 Radioactive Hazard Assessment and Exposure Controls

Main article: IP 71124.01

a. Inspection Scope

During the period of February 13 - 16, the inspector conducted the following activities to verify that Entergy was evaluating, monitoring, and controlling radiological hazards for work performed in locked high radiation areas (LHRA) and other radiological controlled areas, and that workers were adhering to these controls when working in these areas.

Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, Technical Specifications, and Entergys procedures.

Radiological Hazards Control and Work Coverage The inspector identified exposure significant work areas. The inspector reviewed radiation survey maps and radiation work permits (RWPs) associated with these areas to determine if the associated controls were acceptable. The inspector attended the pre-job and RWP briefings and interviewed selected workers to determine if the workers were informed of the radiological conditions at the job site, electronic dosimeter alarm set points, and actions to be taken if a dosimeter alarms. Specific work activities observed included a High Pressure Coolant Injection (HPCI) pump surveillance test during full power operations.

The inspector toured the accessible radiological controlled area, including the reactor building, turbine building, and radwaste building, and performed independent surveys of selected areas to confirm the accuracy of survey data and the adequacy of postings.

During this tour, the inspector verified that selected LHRAs were properly secured and posted.

In evaluating the RWPs, the inspector reviewed electronic dosimeter dose/dose rate alarm set points to determine if the set points were consistent with the survey indications and plant policy. The inspector verified that workers were knowledgeable of the actions to be taken when the dosimeter alarms, or malfunctions, for tasks being performed under selected RWPs.

The inspector reviewed Entergys procedure for measuring personnel exposure using the effective dose equivalent method. The inspector confirmed that the method was approved by the NRC and that the implementing procedure appropriately specified the placement of whole body and extremity dosimeters on the worker.

Problem Identification and Resolution A review of Nuclear Oversight (NO) field observation reports, related Condition Reports (CRs), and an audit report (No.QA-14/15-2011-PNP-1) was conducted to determine if identified problems and negative performance trends were entered into the corrective action program and evaluated for resolution.

Relevant CRs, associated with radiation protection control access, initiated between October 2011 and February 2012, were reviewed and discussed with Entergy staff to determine if the follow up activities were being conducted in an effective and timely manner, commensurate with their safety significance.

High Radiation Area and Very High Radiation Area Controls Procedures for controlling access to High Radiation Areas (HRA) and Very High Radiation Areas (VHRA) were reviewed to determine if the administrative and physical controls were adequate. The inspector also reviewed the physical and procedural controls for securing and removing highly contaminated/activated materials stored in the spent fuel pool. The inspector discussed with radiation protection management the adequacy of current LHRA/VHRA controls, including prerequisite communications and authorizations, and verified that any changes made to relevant procedures did not substantially reduce the effectiveness and level of worker protection. The inspector conducted an inventory of LHRA/VHRA keys to verify accountability.

Radiation Worker Performance and Radiation Protection Technician Performance The inspector observed and questioned radiation workers and radiation protection technicians regarding radiological controls applied to various tasks, including a HPCI test run and various maintenance tasks. The inspector determined that the workers were aware of current RWP requirements, radiological conditions, access controls, and that the skill level was appropriate with respect to the potential radiological hazards and the work being performed.

The inspector attended a Radiation Protection Department daily planning meeting to assess the level of detail provided to workers regarding planned work activities.

The inspector reviewed CRs related to radiation worker and radiation protection technician errors, and personnel contamination event reports to determine if an observable pattern traceable to a similar cause was evident.

Contamination and Radioactive Material Control At the radiological controlled area (RCA) control point, the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use. The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured.

The inspector reviewed Entergys procedures for storing, issuing, and inventorying sealed radioactive sources. The inspector toured plant areas where sealed sources were stored. During this tour, the inspector conducted spot checks of various radioactive sealed sources to verify their presence. Through this review, the inspector determined that sources were properly tested for possible leaks, all sources were appropriately accounted for, and that the storage containers were properly secured and labeled.

b. Findings

No findings were identified.

2RS0 2 Occupational ALARA Planning and Controls

Main article: IP 71124.02

a. Inspection Scope

During the period of February 13 - 16, the inspector conducted the following activities to verify that Entergy was properly implementing operational, engineering, and administrative controls to maintain personnel exposure As Low as Reasonably Achievable (ALARA) for tasks performed during 2011 and in performing ongoing activities. Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, applicable industry standards, and Entergys procedures.

Radiological Work Planning The inspector reviewed pertinent exposure information regarding the spring 2011 refueling outage (RFO), current exposure trends, and ongoing activities to assess ALARA performance. A review of 2011 outage dose was conducted to compare actual exposures with forecasted estimates to determine if differences were properly addressed in Work-In-Progress and Post-Job ALARA reviews.

The inspector evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems. The evaluation was accomplished by attending an ALARA Managers Meeting for an entry into a steam affected area to troubleshoot a main steam isolation valve (MSIV-203-2B); reviewing the refueling outage post-job ALARA reviews, reviewing the post-job ALARA review for replacing a residual heat removal motor, and reviewing past ALARA Managers Committee meeting minutes, and NO audit/field observations, and interviewing the site Radiation Protection Manager.

Verification of Dose Estimates The inspector reviewed the assumptions and basis for the annual (2012) site collective dose, exposure projections and actual exposure data for the 2011 spring outage, and for routine power operations. The inspector evaluated in detail projects whose dose exceeded five person-rem. The inspector reviewed the effectiveness of initial job planning measures and Entergys efforts in monitoring and controlling dose during job completion by the ALARA Managers Committee.

The inspector reviewed Entergys procedures associated with monitoring and re-evaluating dose estimates when the forecasted cumulative exposure for tasks differed from the actual exposure received. The inspector reviewed the dose/dose rate alarm reports, post-job ALARA reviews, and exposure data for selected individuals receiving the highest Total Effective Dose Equivalent (TEDE) for 2011, to confirm that no individual exposure exceeded the regulatory limit or met the performance indicator reporting guideline.

Jobs-In-Progress The inspector observed a job-in-progress to evaluate the effectiveness of dose and contamination control measures. The job observed was a surveillance test run of a HPCI pump during full power operations. As part of this evaluation, the inspector attended the pre-job and RWP briefing, reviewed the RWP and associated survey maps, and evaluated contamination control measures.

Declared Pregnant Workers The inspector reviewed the implementing procedure for processing, monitoring, and limiting the exposure of personnel who are Declared Pregnant Workers (DPW). The inspector determined that no DPWs were recently employed who were assigned to perform work within the RCA.

Problem Identification and Resolution The inspector reviewed elements of Entergys corrective action program related to implementing ALARA program controls, including condition reports, NO field observation reports, audits, and dose/dose rate alarm reports, to determine if problems were being entered at a conservative threshold and resolved in a timely manner.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

Main article: IP 71151

Cornerstone: Initiating Events

a. Inspection Scope

The inspectors reviewed Performance indicator (PI) data to determine the accuracy and completeness of the reported data. The review was accomplished by comparing reported PI data to confirmatory plant records and data available in plant logs, Condition Reports (CRs), Licensee Event Reports (LERs), and NRC Inspection reports. The acceptance criteria used for the review was Nuclear Energy Institute (NEI) 99-02, Revision 6, Regulatory Assessment Performance Indicator Guidelines. The following performance indicators were reviewed.

Unplanned SCRAMs per 7000 Critical Hours

Unplanned SCRAMs with Complications

Unplanned Power Changes per 7000 Critical Hours

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

Main article: IP 71152

Review of Items Entered into the Corrective Action Program (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 condition report, attending daily screening meetings and/or accessing Entergy's 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. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Main article: IP 71153

.1 Replacement of A Residual Heat Removal (RHR) Pump Motor

On April 25, 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 the content of this report includes no proprietary information.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Entergy Personnel

G. Blankenbiller Chemistry Manager

G. Bradley Component Engineering

D. Brugman Supervisor, ALARA/Technical Support

B. Chenard System Engineering Manager

B. Clow Radiation Protection Technician

S. Colburn Supervisor Access Authorization and Fitness for Duty

J. Cox Supervisor, Radiation Protection Operations

J. Dent Plant General Manager

A. Dodds Director, Nuclear Safety Assurance

V. Fallacara Engineering Director

A. Felix Auxiliary Operator

J. Fitzsimmons Radiation Protection Supervisor

J. House Superintendent, Initial Operations Training

W. Lobo Licensing Engineer

J. Lynch Licensing Manager

J. Macdonald Assistant Operations Manager-Shift

T. McElhinney Training Manager

W. Mauro Supervisor, Radiation Protection Support

A. Muse Superintendent, Operations Training

D. Noyes Operations Manager

J. Priest Radiation Protection Manager

R. Smith Site Vice President

J. Taormina Maintenance Manager

M. Thornhill Radiation Protection Supervisor

J. Whalley Operations Shift Manager

T. White Emergency Planning Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

NCV

05000293/2012002-01 Failure to Scope the Rod Worth Minimizer into the Maintenance Rule (Section 1R12)

Closed

LER

05000293/2011005-00 Technical Specification Required Shutdown Due To Inoperable Feedwater Check Valve (Section 40A3)

LER

05000293/2011006-00 HPCI Turbine Governor Control Valve Failure (Section 4OA3)

LIST OF DOCUMENTS REVIEWED

v t e Inspection Report - Pilgrim - 2012002
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \|
2012 Quarterly Integrated 1Q (0) 2Q (1) 3Q (1) 4Q (4) Assessments Mid Cycle End of Cycle 7(0) 8(0) 9(0) Security 403(3) Operator Exams Emergency Planning 501(0) 503(0) Other