IR 05000293/2014005
| ML15037A163 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/04/2015 |
| From: | Raymond Mckinley NRC/RGN-I/DRP/PB5 |
| To: | Dent J Entergy Nuclear Operations |
| McKinley R | |
| References | |
| IR 2014005, IR2014003, ISFSI Report 07201044/2014003 | |
| Download: ML15037A163 (35) | |
Text
bruary 4, 2015
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2014005 and INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) REPORT 07201044/2014003
Dear Mr. Dent:
On December 31, 2014, 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 January 21, 2015, 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 violation of a NRC requirement, which was of very low safety significance (Severity Level IV). However, because of the very low safety significance, and because it is entered into your corrective action program, the NRC is treating the finding as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violation in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at PNPS.
In accordance with Title of the Code of Federal Regulations (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 NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-293 License No. DPR-35
Enclosure:
Inspection Report 05000293/2014005 w/Attachment: Supplementary Information
REGION I==
Docket No. 50-293 License No. DPR-35 Report No. 05000293/2014005 Licensee: Entergy Nuclear Operations, Inc. (Entergy)
Facility: Pilgrim Nuclear Power Station Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: October 1, 2014 through December 31, 2014 Inspectors: E. Carfang, Senior Resident Inspector B. Scrabeck, Resident Inspector G. Bjorkman, Senior Level Advisor for Structural Mechanics B. Dionne, Health Physicist T. Dunn, Operator Licensing Examiner E. Love, Safety Inspection Engineer J. Nicholson, Health Physicist S. Rutenkroger, Senior Resident Inspector J. Schoppy, Senior Reactor Inspector J. Tapp, Transportation and Storage Safety Inspector Approved By: Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
IR 05000293/2014005; 10/01/2014 - 12/31/2014; Pilgrim Nuclear Power Station (Pilgrim); Other
Activities.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified one Severity Level IV non-cited violation (NCV). The significance of most findings is indicated by their color (i.e.,
greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Barrier Integrity
Severity Level lV. The inspectors identified a Severity Level lV NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.59 in that Entergy did not obtain a license amendment prior to implementing a change to the plant that required a change to technical specifications (TS). Specifically, Entergy removed the energy absorbing pad described in TS 4.3.4.b,
Design Features, and Updated Final Safety Analysis Report (UFSAR) section 10.3.6,
Consequences of a Dropped Fuel Cask, without receiving prior NRC approval. Entergy submitted a License Amendment Request (LAR) supplement to the NRC on September 11, 2014, to remove the energy absorbing pad language from TS, and performed an extent of condition review on previous engineering changes and prohibited placing a cask in the spent fuel pool (SFP) until receiving NRC approval for a change to TS 4.3.4.b.
The inspectors determined that Entergy did not perform an adequate 10 CFR 50.59 evaluation and obtain a license amendment prior to removing the SFP energy absorbing pad. The inspectors determined this was a performance deficiency that was within Entergys ability to foresee and correct and should have been prevented. Because the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using the Enforcement Manual, the inspectors determined that the violation was a Severity Level IV (a 10 CFR 50.59 violation that resulted in conditions that required NRC approval before implementation) violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B. (Section 4OA5)
REPORT DETAILS
Summary of Plant Status
Pilgrim began the inspection period at 100 percent power. On October 24, Pilgrim reduced power to 50 percent to perform a condenser thermal backwash and returned to 100 percent power the same day. On October 27, Pilgrim reduced power to 85 percent to perform a control rod pattern adjustment and returned to 100 percent power on the same day. On December 26, Pilgrim reduced power to 45 percent to perform a thermal backwash and returned to 100 percent power the following day. On December 28, Pilgrim reduced power to 85 percent to perform a control pod pattern adjustment and returned to 100 percent power the following day and continued to operate at 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of Entergys readiness for the onset of seasonal cold temperatures. The review focused on the auxiliary boiler heating system. The inspectors reviewed the UFSAR, TS, control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Entergy personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Entergys seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather 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
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
B residual heat removal train during maintenance on the A residual heat removal train on October 7, 2014 Emergency diesel generators (EDGs) X-107A and X-107B with 345 kilovolt (KV) Line 342 out of service to support line maintenance on November 12, 2014 EDG X-107A with 345 KV Line 355 out of service to support line maintenance and with EDG X-107B out of service for testing on December 18, 2014 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 UFSAR, TS, work orders, condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify 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 staff 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 Full System Walkdown
a. Inspection Scope
On November 22 through December 5, 2014, the inspectors performed a complete system walkdown of accessible portions of the high pressure coolant injection (HPCI)system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, 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, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems.
The inspectors performed field walkdowns of accessible portions of the systems 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 CRs 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 - 4 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 and suppression equipment was available for use as specified in the area pre-fire plan, and 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.
Hydrogen seal supply oil unit and truck lock area on October 10, 2014 Battery rooms A and B on November 23, 2014 Fuel pool cooling pumps and heat exchanger area on December 16, 2014 Reactor building 23 level on December 29, 2014
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the internal flooding in A5 and A6 emergency 4160 volt switchgears to assess susceptibilities involving internal flooding. The inspectors also reviewed the corrective action program to determine if Entergy identified and corrected potential flooding problems and whether operator actions for coping with flooding were adequate. The inspectors also focused on the component cooling water pump room areas to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the A and B reactor building component cooling water (RBCCW) heat exchangers to determine its readiness and availability to perform its safety functions on November 2, 2014. The inspectors reviewed the design basis for the component and verified Entergys commitments to NRC Generic Letter 89-13. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left conditions. The inspectors verified that Entergy initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training during emergency planning drill on October 22, 2014, which included a loss of all offsite power followed by a loss of the one available EDG followed by a loss of the station blackout (SBO) diesel generator necessitating notice of unusual event, alert, and site area emergency declarations. After a planned shift turnover, a seal on the B recirculation pump catastrophically failed causing a small break loss of coolant accident. The HPCI system failed, and the break size exceeded the capacity of the reactor core isolation cooling (RCIC) system causing reactor pressure vessel water level to lower and be unable to be restored and maintained above the top of active fuel necessitating a general emergency declaration.
The operators performed an emergency depressurization of the reactor and lined up the diesel fire pump as a source of injection into the reactor vessel which restored reactor water level. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed control rod scram time testing and portions of the power ascension on October 24, 2014. The inspectors observed infrequently performed test or evolution briefings and reactivity control briefings to verify that the briefings met the criteria specified in Entergys administrative procedure EN-OP-116, Infrequently Performed Tests or Evolutions, Revision 12. Additionally, the inspectors observed crew performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
b. Findings
No findings were identified.
.3 Annual Review of Licensed Operator Requalification Testing
a. Inspection Scope
On November 4, 2014, a region-based inspector conducted an in-office review of results of the licensee-administered comprehensive written examinations and annual operating tests. The inspection assessed whether pass rates were consistent with the guidance of IMC 0609, Appendix I, Licensed Operator Requalification Significance Determination Process (SDP). The inspector verified that:
All licensed operators were administered a requalification examination.
The individual pass rate on the dynamic simulator test was greater than 80 percent. (Pass rate was 100 percent.)
The individual pass rate on the job performance measures of the operating examination was greater than 80 percent. (Pass rate was 100 percent.)
The individual pass rate on the comprehensive written examinations was greater than 80 percent. (Pass rate was 94.9 percent.)
More than 75 percent of the individuals passed all portions of the operating examination. (Pass rate was 94.9 percent.)
The crew pass rate was greater than 80 percent. (Pass rate was 100 percent.)
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the August 16, 2014, E-103B feedwater heater failure to assess the effectiveness of maintenance activities on structure, system, and component (SSC)performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Entergy was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Entergy staff was reasonable. Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
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 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 work controls and risk assessment due to unscheduled maintenance on the RCIC system on October 1, 2014 Elevated risk due to heavy lift in the reactor building during the week of October 12, 2014 Elevated risk due to 345 KV Line 342 out of service to support line maintenance and the 208B salt service water (SSW) pump out of service for maintenance on November 12, 2014
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Failure of HPCI flow instrument on August 12, 2014, and subsequent retraction of 10 CFR 50.72 event notification 50356 Minor steam leak from the packing of the 2301-5 HPCI pump steam inlet on September 26, 2014 Impact of degraded voltage condition on X-107A EDG governor on September 26, 2014 Rod block monitor alarm during weekly control rod exercise on December 2, 2014 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 Entergys 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.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
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 procedure to verify that the procedure 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 witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
RCIC Agastat relay installation testing on September 18, 2014 Replacement of scram discharge instrument volume (SDIV) level switch 83A and 83E circuit cards on October 3, 2014 SSW pump P-208B impeller adjustment on November 14, 2014
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and Entergy 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:
Functional test of SDIV high water level instrumentation on October 3, 2014 Control rod scram insertion time evaluation on October 24, 2014 EDG X-107B monthly surveillance testing on December 18, 2014 RBCCW pump P-202F biennial comprehensive test on December 19, 2014 (in-service test)
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine Entergy emergency drill simulating a SBO on October 22, 2014, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities.
Entergy effectively performed a turnover of the emergency response organization between the red and green teams. The inspectors observed emergency response operations in the simulator and the technical support center 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 Entergy staff was properly identifying weaknesses and entering them into the corrective action program.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety and Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
Inspection Scope During November 3 - 6, 2014, the inspectors reviewed Entergys performance in assessing the radiological hazards and exposure control in the workplace. The inspectors used the requirements in 10 CFR 20 and guidance in Regulatory Guide (RG)8.38, TS, and the Pilgrim procedures required by TS as criteria for determining compliance.
Radiological Hazard Assessment The inspectors reviewed two radiological surveys from the Reactor Water Cleanup Rooms, the Transverse In-core Probe Room, and the Spent Resin Tank Cubicle.
There were no samples available to review work in potential airborne radioactivity areas during the inspection period.
Instructions to Workers The inspectors reviewed electronic personal dosimeter alarm events.
Contamination and Radioactive Material Control The inspectors reviewed the following:
Performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures Sensitivity and alarm set-points of radiation monitoring instrumentation used for equipment release and personnel contamination surveys Accountability and testing of five sealed sources from the Entergy inventory records Recent transactions involving nationally tracked sources Radiological Hazards Control and Work Coverage The inspectors conducted independent radiation measurements during walk-downs of the facility and reviewed associated radiological postings, surveys, radiation work permits (RWPs), and worker briefings.
Risk-Significant High Radiation Area and Very High Radiation Area Controls The inspectors reviewed the controls and procedures for high-risk high radiation areas and very high radiation areas and transient areas with the potential to become very high radiation areas.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
During November 3 - 6, 2014, the inspectors reviewed the gaseous and liquid effluent processing systems and radiological discharges including calculations of effluent releases and public doses.
The inspectors used the requirements in 10 CFR 20; 10 CFR 50.35(a); 10 CFR 50, Appendix A, Criterion 60; 10 CFR 50, Appendix I; 10 CFR 50.75(g); 40 CFR 141; 40 CFR 190; RG 1.109; RG 1.21; NUREG-1302; applicable Industry standards; and Entergy procedures required by TS/Offsite Dose Calculation Manual (ODCM) as criteria for determining compliance.
Groundwater Protection Initiative The inspectors reviewed reported groundwater monitoring results and changes to Entergys written program for identifying and controlling contaminated spills/leaks to groundwater.
b. Findings and Observations
No findings were identified.
One non-conformance was observed with implementation of the Nuclear Energy Institute (NEI) 07-07 Groundwater Protection Initiative (GPI), specifically, acceptance criteria 1.4.c, evaluate and document the decommissioning impact from residual byproduct material left in the ground (see Section 4OA5).
Currently, no further discharges are being made from the leaking neutralizer sump discharge line. Entergys investigation is continuing to determine if there are any other piping system leaks associated with the neutralizer sump discharge piping and catch basins.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance Index (2 samples)
a. Inspection Scope
The inspectors reviewed Entergys submittal of the Mitigating Systems Performance Index for the following systems for the period of October 1, 2013, through September 30, 2014:
Emergency alternating current Power System Cooling Water Systems To determine the accuracy of the performance indicator (PI) data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed Entergys operator narrative logs, CRs, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Occupational Exposure Control Effectiveness
a. Inspection Scope
The inspectors sampled Entergy submittals for the occupational exposure control effectiveness PI for the period from October 1, 2013 through September 30, 2014. The inspectors used PI definitions and guidance contained in NEI 99-02, Revision 7, to determine the accuracy of the reported PI data. The inspectors reviewed electronic personal dosimetry accumulated dose alarms, dose reports, and dose assignments for any intakes; and discussed with radiation protection staff potential PI events that occurred during the time period. The inspectors also conducted walk-downs of numerous locked high and very high radiation area entrances.
b. Findings
No findings were identified.
.3 Radiological Effluent TS/ODCM Radiological Effluent Occurrences
a. Inspection Scope
The inspectors sampled Entergy submittals for the radiological effluent TS/ODCM radiological effluent occurrences PI for the period from October 1, 2013 through September 30, 2014. The inspectors used PI definitions and guidance contained in the NEI 99-02, Revision 7, to determine if the PI data was reported properly during this period.
The inspectors reviewed Entergys corrective action report database to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous and liquid effluent summary data and the results of associated public dose calculations for selected dates during the review period.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergys entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended CR screening meetings.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Entergy outside of the corrective action program, such as trend reports, PIs, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed Entergys corrective action program database for the third and fourth quarters of 2014 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed Entergy quarterly trend report for the second and third quarters of 2014, conducted under EN-LI-121, Trending and Performance Review Process, Revision 15, to verify that Entergy personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.
b. Findings and Observations
No findings were identified.
The inspectors evaluated a sample of departments that are required to provide input into the quarterly trend reports, which included operations, maintenance, engineering, and performance improvement. This review included a sample of issues and events that occurred over the course of the past two quarters to objectively determine whether issues were appropriately considered or ruled as emerging or adverse trends, and in some cases, verified the appropriate disposition of resolved trends. The inspectors verified that these issues were addressed within the scope of the corrective action program, or through department review and documentation in the quarterly trend report for overall assessment.
The inspectors noted that CR quality closure continues to be an adverse trend identified by Entergy. In the second quarter report, 20 CRs identified quality closure issues associated with corrective actions. Eleven of the 20 CRs were associated with corrective actions associated with root causes that impacted NRC PIs (Unplanned Scrams per 7000 Critical Hours and Unplanned Scrams with Complications). In the third quarter of 2014, closure quality issues were identified with 32 corrective actions associated with 16 CRs. The inspectors reviewed 55 CRs in the fourth quarter of 2014 that identified corrective action quality closure issues, which resulted from an Entergy focus on quality closure of corrective actions by an internal screening committee.
Entergy instituted a cross-functional closure review board for corrective action quality, resulting in a higher number of closure quality issues being identified and new CRs being entered into the corrective action program. Entergy continues to implement the corrective action plan recovery plan outlined in CR-PNP-2014-2740.
.3 Annual Sample: Follow-Up for Untimely Corrective Actions for SBO Diesel Fuel Oil
Transfer System Design Control
a. Inspection Scope
The inspectors performed an in-depth review of Entergys apparent cause analysis associated with CR-PNP-2013-6906, untimely corrective actions for resolving the design aspects of the fuel transfer strategy of the design basis for the seven day fuel supply for the EDGs. This CR was also referenced in NCV 05000293/2013004-01, Failure to Complete a Design Control Review for the SBO Fuel Oil Transfer System in a Timely Manner, and was selected for review as a follow-up to this NCV.
The inspectors assessed Entergys problem identification threshold, cause analysis, extent of condition review, compensatory actions, and the prioritization and timelines of Entergys corrective actions to determine whether Entergy was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Entergys corrective action program and 10 CFR 50, Appendix B. In addition, the inspectors performed field walkdowns and interviewed Entergy personnel to assess the effectiveness of the implemented corrective actions.
b. Findings and Observations
No findings were identified The inspectors found that Entergy took adequate action to identify the apparent causes of the failure to implement timely corrective actions. Entergy identified apparent causes were periodic and interim reviews and corrective action due date extensions did not adequately address risk, based on timeliness. Additionally, a second apparent cause was identified in which there existed no mechanism to make safety and regulatory risk prioritization decisions visible to the site groups that could provide risk inputs and challenges to those decisions. Corrective actions included the revision of specific guidance given to Entergy personnel performing corrective action interim and periodic reviews, as well as additional training on such reviews. Moreover, Entergy implemented a regulatory assurance status report as a mechanism of regularly informing station management of key issues requiring timely resolution.
Entergy performed an extent of condition review of interim and periodic reviews to ensure that risk was considered during original performance. This extent of condition review did reveal weaknesses in the performance of interim and periodic reviews, and new corrective actions were assigned under the applicable CRs to ensure new risk informed reviews were performed.
The inspectors determined that Entergys overall response to the issue was commensurate with the safety significant, was timely, and the actions taken and planned are reasonable to resolve the failure to take timely corrective actions for the design and implementation of the SBO Fuel Oil Transfer System. The original condition, referenced in NCV 05000293/2012005-01, Failure to Verify the Adequacy of the Design of the SBO Fuel Oil Transfer System, has since been corrected.
4OA5 Other Activities
.1 Preoperational Testing of Independent Spent Fuel Storage Installations at Operating
Plants (60854, 60854.1, 60856, and 60856.1)
a. Inspection Scope
The inspectors evaluated Entergy and contractor performance during NRC-observed pre-operational dry run activities associated with Entergys planned operation of an independent spent fuel storage installation (ISFSI) at Pilgrim. The inspectors observed dry fuel storage (DFS) activities at Pilgrim on December 2 - 5, 2014 (Dry Run No. 3), and DFS activities on December 29 - 30, 2014 (Dry Run No. 4). During the dry runs, the inspectors observed pre-job briefs, field activities, and reviewed RWPs and Entergy DFS procedures to independently verify that Entergy and Holtec personnel used adequate radiological controls, incorporated relevant industry operating experience, and developed and implemented adequate procedures. The inspectors verified that work instructions and procedures appropriately captured the commitments and requirements contained in the Holtec Final Safety Analysis Report, Revision 9; Certificate of Compliance (CoC) No. 1014, Amendment 7 (issued to Holtec International); and 10 CFR Part 72. The inspectors also reviewed DFS-related corrective action CRs and Entergys associated follow-up actions to ensure that Entergy prioritized, evaluated, and corrected issues commensurate with their safety significance.
During Dry Run No. 3, the inspectors observed placement of the mating device onto the top of the HI-STORM in the reactor building. The inspectors observed Entergys use of the reactor building crane to lift and transport the mating device, HI-TRAC, and simulated multi-purpose canister (MPC). The inspectors verified that Entergy installed and adequately shimmed the calibrated support pedestals alongside the low profile transporter (LPT) during the stack up of the HI-STORM and HI-TRAC. The inspectors observed operation of the inner and outer reactor building doors and verified that the doors functioned properly and opened to the appropriate height to allow for passage of the loaded HI-STORM. The inspectors observed the operation of the winch to transport the HI-STORM on the LPT from inside the reactor building truck bay to outside the reactor building via the rail system. The inspectors observed Entergys movement of rail sections with a mobile crane to facilitate placement of the vertical cask transporter (VCT)next to the HI-STORM. In addition, the inspectors observed Entergys placement of the HI-STORM lid on the HI-STORM with the VCT and the VCT lift and transport of the HI-STORM to its designated spot on the ISFSI pad.
During in-office reviews, the inspectors reviewed the methodology, assumptions, acceptance criteria, analysis, and results of Holtec Report No. HI-2146087, Calculation Package on the Seismic Stability Analysis of Pilgrim HI-STORM/HI-TRAC Stack Using NRC Concurred Methodology, Revision 5, to assess the response of the HI-TRAC and HI-STORM when in a freestanding stack up configuration during a design basis seismic event.
During Dry Run No. 4, the inspectors observed Entergys Wet Operations. The inspectors observed heavy load handling of the HI-TRAC/MPC from the cask decontamination area (CDA) to the SFP and placement on the leveling pad. The inspectors observed the simulated loading/unloading of dummy fuel assemblies into designated MPC cells within the SFP, placement of the drain line on the MPC lid, placement of the lid on the MPC, and transfer of the HI-TRAC/MPC from the SFP back to the CDA. During the HI-TRAC transfers into and out of the SFP, the inspectors verified that operators properly monitored and controlled the SFP water level. The inspectors also reviewed the MPC slings and lift yolk CoC and inspection documentation. The inspectors performed a visual inspection of the slings and lift yolk to verify that the lifting equipment was adequately rated, inspected, and maintained. In addition, the inspectors reviewed a sample of reactor building crane operator and rigger qualification records to verify that DFS workers were qualified for the tasks that they performed and that their required training was current.
During in-office reviews and an onsite review on December 29 - 30, 2014, the inspectors evaluated Entergys compliance with the requirements of 10 CFR 72.212. The inspectors verified that Entergys written evaluations were in accordance with 10 CFR 72.212(b)(5) and confirmed that the conditions set forth in the CoC had been met prior to initial use by Entergy and that the radiological requirements of 10 CFR 72.104 were properly considered. The inspectors verified that applicable reactor site parameters, such as fire and explosions, tornadoes, wind-generated missile impacts, seismic qualifications, lightning, flooding, and temperature had been evaluated for acceptability against the bounding values specified in the storage cask final safety analysis report and the NRC Safety Evaluation Report. The inspectors reviewed Entergys 10 CFR 50.59 evaluations related to the construction and operation of the ISFSI. In addition, the inspectors performed an ISFSI storage pad and haul path walk down to verify that those areas did not contain fire or explosion hazards beyond those analyzed in the storage cask final safety analysis report.
b. Findings
Introduction.
The inspectors identified a Severity Level IV NCV of 10 CFR 50.59, Changes, Tests and Experiments, when Entergy did not obtain a license amendment prior to implementing a change to the plant that required a change to TS. Specifically, Entergy removed the energy absorbing pad described in TS 4.3.4.b, Design Features, and UFSAR section 10.3.6, Consequences of a Dropped Fuel Cask, without receiving prior NRC approval.
Description.
During the NRC review of Entergys LAR for a TS change to support moving the dry fuel storage cask lid over the spent fuel in the cask on August 18, 2014, the NRC identified that Entergy had removed the energy absorbing pad from the SFP without submitting a TS revision to remove or modify TS 4.3.4.b. TS 4.3.4.b states, No fuel which has decayed for less than 200 days shall be stored in racks within an arc described by the height of the cask around the periphery of the energy absorbing pad.
UFSAR section 10.3.6 states that analysis has demonstrated that with the spent fuel pool energy absorber in place, damage to the SFP floor will not result in a SFP leakage rate greater than the pool makeup capacity due to a dropped cask. By removing the energy absorbing pad, Entergy altered the plant configuration from the condition stated in TS 4.3.4.b without prior NRC approval.
EN-LI-100, Process Applicability Determination, Revision 15, requires, in part, that activities be screened to determine any impact on licensing basis documents, which include the TSs and UFSAR. During Entergys engineering change review, the SFP energy absorbing pad was not listed as a topic for review in the TSs and UFSAR, despite being designated for replacement with a cask leveling pad. The energy absorbing pad was not identified as requiring inclusion in the LAR submitted on November 26, 2013, to the NRC for review.
The energy pad itself is not a TS requirement; however, its position is used to define the position of a cask relative to the fuel racks in TSs. Prior to removing the energy absorbing pad, the site installed a single failure-proof crane on December 11, 2013, which removed the necessity of the energy absorbing pad. Also, Entergy had installed the cask leveling pad, which was designed to provide protection for the SFP floor liner during cask handling with a single failure-proof crane, prior to beginning dry storage cask handling activities. However, the site did not request approval prior to taking actions that altered the plant from the stated TS condition. When the pad was removed on June 25, 2014, all spent fuel within the area of concern was greater than 200 days old and no cask was inserted into the SFP from June 25, 2014 to October 31, 2014. Entergy entered this issue into the corrective action program as CR-PNP-2014-04109. Entergy submitted a LAR supplement to the NRC on September 11, 2014, to remove the energy absorbing pad language from TS, and performed an extent of condition review on previous engineering changes. Entergy also prohibited placing a cask in the SFP until receiving NRC approval for a change to TS 4.3.4.b, which occurred on October 31, 2014.
Analysis.
The inspectors determined that Entergy did not perform an adequate 10 CFR 50.59 evaluation and obtain a license amendment prior to removing the SFP energy absorbing pad. The inspectors determined this was a performance deficiency that was within Entergys ability to foresee and correct and should have been prevented.
Because the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using the Enforcement Manual, the inspectors determined that the violation was a Severity Level IV (a 10 CFR 50.59 violation that resulted in conditions that required NRC approval before implementation) violation. The inspectors evaluated the performance deficiency under the Reactor Oversight Process and determined that the associated Reactor Oversight Process finding was minor because Entergy had installed a single failure-proof crane prior to removing the energy absorbing pad and installed the cask leveling pad prior to beginning dry storage cask handling activities. As such, no cross-cutting aspect was assigned to this finding.
Enforcement.
10 CFR 50.59, Changes, Tests, and Experiments, states, partially, in subsection (c)(1) that A licensee may make changes in the facility as described in the FSAR (as updated), make changes in the facility as described in the FSAR (as updated)without obtaining a license amendment pursuant to Sec 50.90 only if:
- (i) A change to the TSs incorporated in the license is not required. Contrary to this, from June 25, 2014 to October 31, 2014, Entergy made changes to the plant that impacted TS 4.3.4.b without obtaining a license amendment pursuant to 10 CFR 50.90. In accordance with the NRC Enforcement Manual 2.1.3, Enforcement of 10 CFR 50.59 and Related FSAR, the violation was characterized as Severity Level IV because the underlying technical issue required NRC approval prior to implementation. Since this violation was of minor significance, was not repetitive or willful, and was entered into Entergys corrective action program as CR-PNP-2014-04109, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000293/2014-001, Modification to the Spent Fuel Pool Cask Area without Prior NRC Approval)
.2 Groundwater Protection Initiative
a. Inspection Scope
During November 3 - 6, 2014, the inspectors reviewed implementation of the GPI and changes to Entergys written program for identifying and controlling contaminated spills/leaks to groundwater. The objective of the review was to determine if Entergy has effectively implemented the GPI in light of the recent groundwater contamination from the leak in the neutralizer sump discharge line and catch basins.
b. Findings and Observations
No findings were identified.
One non-conformance was observed with implementation of the NEI 07-07 GPI, specifically, acceptance criteria 1.4.c, to evaluate and document the decommissioning impact from residual byproduct material left in the ground surrounding the neutralizer sump discharge line.
CR-PNP-2014-01321 has been written to document the need to perform a cost-benefit analysis for the various remediation options including the natural attenuation option.
4OA6 Meetings, Including Exit
On January 21, 2015, the inspectors presented the quarterly baseline inspection results to Mr. John Dent, Site Vice President, and other members of the Pilgrim staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Dent Site Vice President
G. Blankenbiller Chemistry Manager
T. Bordelon Performance & Improvement Manager
D. Brugman Supervisor ALARA/Technical Support
D. Burke Security Manager
R. Byrne Licensing Engineer
D. Calabrese EP Manager
B. Chenard Engineering Director
F. Clifford Operations Support Manager
S. Brewer Radiation Protection Supervisor
S. Burke Senior Staff Engineer
S. Cook Chemistry Supervisor
J. Cotter Operations Training Supervisor
J. Cox Radiation Protection Operations Supervisor
B. Deevy System Engineer
W. Grieves Quality Assurance
P. Harizi Design Engineer
J. House Operations Training Supervisor
K. Kampschneider Senior System and Components Engineer
J. Keene System Engineer
- L. Kinney Project Manager, Holtec
- P. Kristian Project Manager, Dry Fuel Storage
J. Macdonald Senior Operations Manager
V. Magnetta Senior Operations Instructor
W. Mauro Supervisor Radiation Protection Support
C. McDonald Training Manager
F. McGinnis Licensing Engineer
C. Minott Project Manager
R. Morris Senior System and Components Engineer
- J. Moylan Manager, Project & Maintenance Services
D. Noyes Director of Regulatory & Performance Improvement
J. ODonnell Senior System and Components Engineer
J. Ohrenberger Senior Maintenance Manager
E. Perkins Regulatory Assurance Manager
J. Priest Emergency Preparedness Manager
- B. Rancourt Senior Lead Engineer, Design Engineering
N. Reece System and Components Engineer
- J. Shumate Manager, PS&O
D. Sitkowski Design Engineer
M. Thornhill Radiation Protection Supervisor
G. Vazquez Quality Assurance Supervisor
S. Verrochi General Manager Plant Operations
T. White Design & Program Engineering Manager
M. Williams Nuclear Safety Licensing Specialist
A. Zelie Radiation Protection Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000293/2014005-01 NCV Modification to the Spent Fuel Pool Cask Area without Prior NRC Approval (Section 4OA5)