IR 05000293/2015001
| ML15133A169 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/11/2015 |
| From: | Raymond Mckinley NRC/RGN-I/DRP/PB5 |
| To: | Dent J Entergy Nuclear Operations |
| McKinley R | |
| References | |
| IR 2015001, ISFSI Report 07201044-15-001 | |
| Download: ML15133A169 (42) | |
Text
May 11, 2015
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2015001 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) REPORT 07201044/2015001
Dear Mr. Dent:
On March 31, 2015, 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 16, 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 NRC identified violation of NRC requirements which was of very low safety significance (Green). However, because of the very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the NCV 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 addition, if you disagree with the cross-cutting aspect assigned to any 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 Resident Inspector at PNPS. In accordance with Title 10 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 Nos. 50-293 and 72-1044 License No. DPR-35
Enclosure:
Inspection Report 05000293/2015001 and 07201044/2015001 w/Attachment: Supplementary Information
REGION I==
Docket Nos. 50-293 and 72-1044 License Nos. DPR-35 Report Nos. 05000293/2015001 and 07201044/2015001 Licensee: Entergy Nuclear Operations, Inc. (Entergy)
Facility: Pilgrim Nuclear Power Station Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: January 1, 2015 through March 31, 2015 Inspectors: E. Carfang, Senior Resident Inspector E. Miller, Acting Senior Resident Inspector B. Scrabeck, Resident Inspector N. Floyd, Reactor Inspector B. Dionne, Health Physicist E. Burket, Emergency Preparedness Inspector E. Love, Safety Inspection Engineer O. Masnyk Bailey, Health Physicist J. Schoppy, Senior Reactor Inspector S. Barr, Senior Emergency Preparedness Inspector Approved By: Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000293/2015001; 01/01/2015 - 03/31/2015; Pilgrim Nuclear Power Station (PNPS); Other Activities.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one non-cited violation (NCV) of very low safety significance (Green). 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, 2012. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 5.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified an NCV of very low safety significance (Green) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, Test Control, because Entergy did not establish requirements in accordance with their test program for safety-related 4160 volt (V) degraded voltage relays in accordance with Updated Final Safety Analysis Report (UFSAR) Section 8.4.7. Specifically, 4160V switchgear relays 127-509/1 & 2 undervoltage setpoints were not tested for the first time until March 2015, which identified the relays were out of calibration by 22 percent. This impacted operators ability to perform alarm response procedure ARP-C3L, which directs operators to trip the X107A emergency diesel generator (EDG) when the alarm for relay 127-509/1 & 2 is received. Entergy entered condition report (CR)-PNP-2015-1614 and CR-PNP-2015-1623 into the corrective action program (CAP) to address the degraded condition. Corrective actions included an immediate operability determination and re-calibration of the relays to their required set points prior to restoration of the X107A EDG.
This finding is more than minor because it impacted the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, the finding is similar to example 1.a in Appendix E of IMC 0612, because no record of testing had ever been recorded or performed; and that testing in 2015 determined that relays 127-509/1 & 2 were degraded and would have impacted the operators ability to take alarm response procedure actions. In accordance with IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because it did not represent a loss of a safety system, did not represent a loss of a safety function of a system or a single train greater than its allowed outage time, and did not screen as potentially risk significant due to external events. Specifically, although testing was not being performed to ensure proper relay response, inspectors confirmed relay protection was available to ensure that at a minimum emergency core cooling system (ECCS) injection valves would not have been impacted if the X107A EDG voltage regulator failed during a loss of offsite power (LOOP)/loss of coolant accident (LOCA). This finding had a cross-cutting aspect in the area of problem identification and resolution related to identification because Entergy did not implement the CAP with a low threshold for identifying issues. Specifically, Entergy had multiple opportunities to identify that relays 127-509/1 & 2 undervoltage dropout settings were not being tested during establishment of the test setup or through periodic trending against similar relays in other systems [P.1]. (Section 1R15)
REPORT DETAILS
Summary of Plant Status
PNPS began the inspection period at 100 percent power. On January 27, 2015, during a severe winter storm, operators reduced reactor power to 52 percent due to degrading switchyard conditions when an automatic reactor scram occurred with the loss of 345 kilovolt (kV) offsite electrical power sources (line 355 and line 342). The operators took the unit to cold shutdown that same day and remained in that condition for restoration of the 345kV offsite electrical power sources, replacement of the 3A and 3C safety relief valves (SRVs), and repairs to the Y2 vital instrument bus. Operators commenced a reactor startup on February 6, 2015, and returned the unit to 100 percent power on February 8, 2015. Operators reduced reactor power to 55 percent on February 9, 2015, to perform a rod pattern exchange, and returned to 100 percent power that same day. On February 14, 2015, the operators performed a controlled shutdown and proceeded to cold shutdown based on procedural requirements during blizzard conditions. Operators performed a reactor startup on February 17, 2015. On February 18, 2015, after achieving 20 percent power, troubleshooting of the main condenser was performed due to condenser tube leaks. Following repair of the condenser tube leaks, operators proceeded with power ascension on February 19, 2015. Operators returned the unit to 100 percent power on February 20, 2015. On February 21, 2015, operators reduced reactor power to 60 percent to perform a rod pattern adjustment. Operators returned the unit to 100 percent the same day. On March 18, 2015, operators reduced power to 70 percent to perform a rod pattern adjustment. The unit was returned to 100 percent power the same day and remained 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 Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed Entergys preparations for an impending winter storm on January 23, 2015. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition.
The review focused on Entergys preparations for the storm. The inspectors reviewed station procedures, including Entergys coastal storm, high wind, and severe weather procedures. The inspectors performed walkdowns of the site to ensure that station personnel had identified issues that could challenge the operability of systems during high wind and winter storm conditions. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.
Documents reviewed for each section of this inspection report are listed in the
.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial System Walkdowns (71111.04 - 4 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
The X-107A EDG during testing on the X-107B EDG on January 12, 2015 Restoration of the B control rod drive pump after maintenance on January 14, 2015 Station blackout EDG during X107A EDG A preventative maintenance on March 6, 2015 Restoration of X-107B EDG following cylinder head replacement on March 23, 2015 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, technical specifications, 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 CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 6 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.
A6 4.16kV switchgear and load center room on January 8, 2015 X107A and X107B EDG rooms on January 28, 2015 Reactor Building (RB) elevation 51 ft. inside secondary containment, west, on February 25, 2015 Standby gas treatment system room on March 2, 2015 Radioactive chemical laboratory on March 6, 2015 High pressure coolant injection (HPCI) pump and turbine room on March 12, 2015
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 on January 21, 2015, which included main steam isolation valve failure leading to a Failure-To-Scram requiring an alternate rod insertion. Operators also responded to the loss of the start-up transformer, loss of an emergency 4160V bus, and a steam leak. 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.
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 the main control room activities listed below. The inspectors observed control room briefings to verify that the briefings met the criteria specified in Entergy procedure EN-OP-116, Infrequently Performed Tests and Evolutions, Revision 6. Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
Initiation of shutdown cooling following a reactor scram due to the loss of 345kV offsite electrical power sources, line 355 and line 342, on January 27, 2015 Transfer of the A5 4.16kV switchgear from the X-107A EDG to offsite power line 342 on January 29, 2015 Control room testing of the 3A and 3C SRVs on February 7, 2015 Reactor shutdown activities on February 14, 2015
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP 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.
As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
K-117 diesel powered air compressor on February 27, 2015 HPCI system on March 9 - 13, 2015
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 technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Elevated risk with the X-107B EDG inoperable for logic system functional testing on January 12, 2015 Elevated risk due to unavailability of offsite power lines 355 and 342 during the forced outage on January 29, 2015 Elevated risk for emergent maintenance on K-117 diesel powered air compressor with K-111 electric air compressor out of service and low pressure coolant injection (LPCI) break logic functional testing on February 19, 2015 Elevated risk for the K-111 electric air compressor out of service and performance of testing on the X-107A EDG on February 26, 2015 Elevated risk with the K-111 electric air compressor and the X-107A EDG out of service for maintenance on March 2, 2015 Normal risk for the K-111 electric air compressor out of service and performance of undervoltage and degraded voltage testing on emergency busses A5 and A6 on March 11, 2015
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:
HPCI pump after gland seal condenser overflow on February 4, 2015 P-215B core spray (CS) motor multiple starts within seven hours on February 4, 2015 P-215B CS injection system cycling impact on fatigue analysis on February 4, 2015 3B and 3D SRV continued use after 3C SRV did not fully open on February 6, 2015 Undervoltage relay 127-509/2 for X107A EDG found out of tolerance on March 6, 2015 C904 jet pump flow total loop A indication failed high on March 23, 2015 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 technical specification 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 technical specifications 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
Introduction.
The inspectors identified an NCV of very low safety significance (Green) of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, because Entergy did not establish requirements in accordance with their test program for safety-related 4160V degraded voltage relays in accordance with UFSAR Section 8.4.7. Specifically, 4160V switchgear relays 127-509/1 & 2 undervoltage setpoints were not tested for the first time until March 2015, which identified the relays were out of calibration by 22 percent. This impacted operators ability to perform alarm response procedure ARP-C3L, which directs operators to trip the X107A EDG when the alarm for relay 127-509/1 & 2 is received.
Description.
4160V undervoltage relays 127-509/1 & 2 are designed to provide an alarm to the control room operators in the event of an undervoltage and overvoltage condition on 4160V safety-related electrical bus A5. In 1989, problem report PR-1989-2244 was issued regarding a degraded voltage scenario that was identified from operating experience at other boiling water reactors (BWRs). The scenario specifically looked at the potential for a voltage regulator failure of the operating EDG during a simultaneous LOOP and LOCA. Given that the LPCI valves are powered from 480V electrical bus B6, which receives power from 4160V Bus A5 and A6, a failure of the EDG voltage regulator during a LOOP/LOCA would cause the LPCI valves to fail to open or fail in place and not fully open. This would prevent the ECCS from injecting at low pressures and potentially lead to core damage. The corrective action to this scenario included two parts that were implemented at different times. First, in 1989, to ensure this event did not impact the ECCS injection function, a step was added in alarm response procedure ARP-C3L to trip the operating EDG to protect the 4160V bus and other associated electrical equipment.
Second, in 1997, relays were installed to protect respective electrical feeds to the B6 480V electrical bus; preventing potential damage to the LPCI injection valves if the EDG were to fail during a LOOP/LOCA.
On March 6, 2015, Entergy staff performed 4160V electrical bus A5 relay testing in accordance with work order 52425333 and procedure 3.M.3-1, A5/A6 Buses 4kV Protective Relay Calibration/Functional Test and Annunciator Verification - Critical Maintenance, Revision 140. In preparation for this testing, Entergy staff noted a change in the drawing which contains the acceptance criteria for the 127-509/1 and 127-509/2 relays. The Entergy staff appropriately updated their relay testing equipment with the proper acceptance criteria; however, did not recognize that the relays had not been tested for the undervoltage dropout setting prior to this date. Testing of the undervoltage dropout setting for relays 127-509/1 & 2 revealed the as-found set point to be at 82V compared to the requirement of 106V. Upon inspectors request for information regarding past performance of relays 127-509/1 & 2, Entergy staff discovered that no prior testing for the undervoltage dropout setting had ever been performed. Given that Entergy had not tested these relays over the life of the plant, there was no method to effectively track and trend relay drift from required setpoints which impacted operators ability to carry out actions in alarm response procedures. Entergy entered CR-PNP-2015-1614 and CR-PNP-2015-1623 into the CAP to address the degraded condition.
An immediate operability determination was performed and the relays were re-calibrated to their required set points successfully prior to restoration of the X107A EDG.
UFSAR Section 8.4.7 for the auxiliary power distribution system establishes a testing frequency for non-technical specification, safety-related 4160V relays in Table 8.4-3 for every four years. These relays are typically tested in accordance with Entergys preventive maintenance program and implementation of procedure 3.M.1-1. However, Entergy did not establish testing requirements or a testing frequency to ensure that the undervoltage dropout relay was properly being maintained and functional. Entergy entered CR-2014-1898 into the CAP to address this issue. The immediate operability determination noted that the 480V electrical bus relays installed in 1997 would have performed a similar function to protect the ECCS injection equipment; however, it would not have protected other safety-related equipment in the event of a voltage regulator failure during a LOOP/LOCA. The inspectors confirmed that the 480V electrical bus relays were properly tested and within acceptance criteria as of 2013 to ensure it could have prevented LPCI injection failure.
The inspectors also requested information regarding extent of condition for potential impact on other undervoltage relays. Extent of condition reviews revealed the overvoltage relay setting for relay 127-509/2 was found out of tolerance and not able to be re-calibrated within acceptance limits. Inspectors identified that an immediate operability determination was not performed. The inspectors also identified that by leaving the relay outside of its acceptance limit after declaring the system operable, a review for applicability to 10 CFR 50.59 should have been performed in accordance with EN-LI-100, Process Applicability Determination, Revision 16. Entergy staff generated CR-2015-1899 to address this issue. The extent of condition review also revealed that Entergy staff failed to identify that the X107B EDG undervoltage and overvoltage relays 127-609/1 & 2 did not meet acceptance criteria in January 2014. Entergy staff generated CR-2015-2336 to evaluate the condition and address immediate operability.
Entergy determined that the non-conforming conditions did not impact operability of the safety-related 4160V electrical buses with which they are associated.
Analysis.
The inspectors determined that not ensuring requirements and testing were established for 4160V safety-related relays 127-509/1 & 2 in accordance with 10 CFR 50, Appendix B, Criterion XI was a performance deficiency that was reasonably within Entergys ability to foresee and correct. This finding is more than minor because it impacted the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability and capability of systems that respond to initiating events to prevent undesirable consequences.
Additionally, the finding is similar to example 1.a in Appendix E of IMC 0612, because no record of testing had ever been recorded or performed; and that testing in 2015 determined that relays 127-509/1 & 2 were degraded and would have impacted the operators ability to take alarm response procedure actions.
In accordance with IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because it did not represent a loss of a safety system, did not represent a loss of a safety function of a system or a single train greater than its allowed outage time, and did not screen as potentially risk significant due to external events. Specifically, although testing was not being performed to ensure proper relay response, inspectors confirmed relay protection was available to ensure that at a minimum ECCS injection valves would not have been impacted if the X107A EDG voltage regulator failed during a LOOP/LOCA.
The inspectors determined this finding had a cross-cutting aspect in the area of problem identification and resolution related to identification because Entergy did not implement the CAP with a low threshold for identifying issues. Specifically, Entergy had multiple opportunities to identify that relays 127-509/1 & 2 undervoltage dropout settings were not being tested during establishment of the test setup or through periodic trending against similar relays in other systems [P.1].
Enforcement.
10 CFR Part 50, Appendix B, Criterion XI, Test Control, states, in part, that a test program shall be established to assure that all testing required to demonstrate that SSCs will perform satisfactorily in service is performed in accordance with written test procedures, and test results are documented and evaluated to assure that test requirements have been satisfied. Contrary to the above, test requirements for relays 127-509/1 & 2 were not incorporated into 3.M.3-1 to ensure that specified test program requirements were established and implemented. Specifically, by not testing the undervoltage setpoints for relays 127-509/1 & 2, the relays drifted 22 percent below their required setpoint and impacted operators ability to implement established alarm response procedures during a degraded voltage event and a LOOP/LOCA. Entergys immediate corrective actions included entering the issue into their CAP as CR-PNP-2015-1614 and CR-PNP-2015-1623, conducting an immediate operability determination, and re-calibrating the relays to their required setpoints prior to restoration of the X107A EDG. Because this violation was of very low safety significance (Green) and was entered into Entergys CAP as CR-2015-1614 and CR-2015-1623, this violation is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000293/2015001-01, Failure to Perform Testing of Safety Related Undervoltage Alarm Relays)
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety.
The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
Temporary power to the B22 motor control center during a LOOP Temporary air supply to the reactor water cleanup system reject flow control valve during loss of instrument air Temporary alternate connection point for the temporary instrument air compressor while the K-117 diesel air compressor is in service
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.
The X-107B EDG turbo assisting air receiver T-150D inlet check valve failure to close on January 13, 2015 HPCI gland seal blower and gland seal condensate pump motor following inspections on January 30, 2015 K-117 diesel powered air compressor following corrective maintenance on February 1, 2015 P-215B CS inspection and testing following operation during plant cooldown on February 3, 2014 Vital motor generator set following troubleshooting and repair on February 6, 2015 Source range monitor B following troubleshooting and repair on February 5, 2015 3A and 3C SRV following replacement on February 7, 2014
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
.1 Forced Outage 20-06
a. Inspection Scope
The inspectors reviewed the stations work schedule and outage risk plan for the PNPS forced outage (20-06), which was conducted January 27 through February 5, 2015. The outage was performed following a scram due to a loss of both 345 kV lines. In addition to plant cooldown and startup, inspectors observed the following activities:
Monitoring of decay heat removal operations Shutdown risk assessment and risk management implementation Cold and hot shutdown temperature control Plant restart readiness meetings Identification and resolution of problems related to forced outage activities
b. Findings
No findings were identified.
.2 Forced Outage 20-07
a. Inspection Scope
The inspectors reviewed the stations work schedule and outage risk plan for the PNPS forced outage (20-07), which was conducted February 14 through February 17, 2015.
The outage was performed due to an approaching blizzard in accordance with procedure 2.1.42, Severe Weather Conditions, Revision 23. In addition to plant cooldown and startup, inspectors observed the following activities:
Monitoring of decay heat removal operations Shutdown risk assessment and risk management implementation Cold and hot shutdown temperature control Identification and resolution of problems related to forced outage activities
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 technical specifications, 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:
Quarterly operability test and stroke timing of the drywell equipment and floor drains isolation valves on January 23, 2015 (containment isolation valves)
HPCI pump quarterly surveillance test on February 7, 2015 (in-service test)
Undervoltage testing on the A5 and A6 emergency switchgear on February 9, 2015 LPCI break detection logic functional test for division B on February 19, 2015 X107A EDG Initiation by LOOP logic system functional test on February 26, 2015 Salt service water pump A surveillance test on March 3, 2015 (in-service test)
Reactor Coolant System (RCS) sample and analysis on March 6, 2015 RCS leakage surveillance on March 12, 2015
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation
a. Inspection Scope
An onsite review was conducted to assess the maintenance and testing of the alert and notification system (ANS). During this inspection, the inspectors conducted a review of the PNPS siren and tone alert radio testing and maintenance programs. The inspectors reviewed the associated ANS procedures and the Federal Emergency Management Agency (FEMA) approved ANS Design Report to ensure compliance with design report commitments for system maintenance and testing. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 2. 10 CFR 50.47(b)(5)and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03 -
1 sample)
a. Inspection Scope
The inspectors conducted a review of the PNPS Emergency Response Organization (ERO) augmentation staffing requirements and the process for notifying and augmenting the ERO. The review was performed to verify the readiness of key Entergy staff to respond to an emergency event and to verify Entergys ability to activate their emergency response facilities (ERFs) in a timely manner. The inspectors reviewed the PNPS Emergency Plan for ERF activation and ERO staffing requirements, the ERO duty roster, applicable station procedures, augmentation test reports, the most recent drive-in drill reports, and corrective action reports related to this inspection area. The inspectors also reviewed a sample of ERO responder training records to verify training and qualifications were up to date. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 3. 10 CFR 50.47(b)(2) and related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Entergy implemented various changes to the PNPS Emergency Action Levels (EALs),
Emergency Plan, and Implementing Procedures. Entergy had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50 Appendix E.
The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by Entergy as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.
b. Findings
No findings were identified.
1EP5 Maintaining Emergency Preparedness
a. Inspection Scope
The inspectors reviewed a number of activities to evaluate the efficacy of Entergys efforts to maintain the PNPS emergency preparedness program. The inspectors reviewed: memorandums of agreement with offsite agencies; the 10 CFR 50.54(q)
Emergency Plan change process and practice; PNPSs maintenance of equipment important to emergency preparedness; records of evacuation time estimate population evaluation; and provisions for, and implementation of, primary, backup, and alternative ERF maintenance. The inspectors also verified Entergys compliance at PNPS with NRC emergency preparedness regulations regarding: EALs for hostile action events; protective actions for on-site personnel during events; emergency declaration timeliness; ERO augmentation and alternate facility capability; evacuation time estimate updates; on-shift ERO staffing analysis; and ANS back-up means.
The inspectors further evaluated Entergys ability to maintain PNPSs emergency preparedness program through their identification and correction of emergency preparedness weaknesses, by reviewing a sample of drill reports, self-assessments, and 10 CFR 50.54(t) reviews. Also, the inspectors reviewed a sample of emergency preparedness-related CRs initiated at PNPS from October 2013 through March 2015.
The inspection was conducted in accordance with NRC Inspection Procedure 71114.05.
10 CFR 50.47(b) and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine Entergy emergency drill on January 21, 2015, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, operational support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Entergys staff in order to evaluate Entergys critique and to verify whether the Entergy staff was properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational and Public Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors reviewed Entergys performance in assessing and controlling radiological hazards in the workplace. The inspectors used the requirements contained in 10 CFR 20, technical specifications, applicable Regulatory Guides (RGs), and the procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the performance indicators for the occupational exposure cornerstone, radiation protection program audits, and reports of operational occurrences in occupational radiation safety since the last inspection.
Radiological Hazard Assessment The inspectors reviewed recent plant radiation surveys and any changes to plant operations since the last inspection to identify any new radiological hazards for onsite workers or members of the public.
Instructions to Workers The inspectors observed several containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with requirements.
The inspectors reviewed several occurrences where a workers electronic personal dosimeter alarmed. The inspectors reviewed Entergys evaluation of the incidents, documentation in the CAP, and whether compensatory dose evaluations were conducted when appropriate.
Contamination and Radioactive Material Control The inspectors observed the monitoring of potentially contaminated material leaving the radiological control area and inspected the methods and radiation monitoring instrumentation used for control, survey, and release of that material. The inspectors selected several sealed sources from inventory records and assessed whether the sources were accounted for and were tested for loose surface contamination. The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with requirements.
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
The inspectors assessed Entergys performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements contained in 10 CFR 20, applicable RGs, technical specifications, and procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors conducted a review of PNPSs collective dose history and trends; ongoing and planned radiological work activities; radiological source term history and trends; and ALARA dose estimating and tracking procedures.
Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the current annual collective dose estimate, basis methodology, and measures to track, trend, and reduce occupational doses for ongoing work activities.
Source Term Reduction and Control The inspectors reviewed the current plant radiological source term and historical trend, plans for plant source term reduction, and contingency plans for changes in the source term as the result of changes in plant fuel performance or changes in plant primary chemistry.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Safety System Functional Failures (1 sample)
a. Inspection Scope
The inspectors sampled Entergys submittals for the Safety System Functional Failures performance indicator for the period of January 1, 2014, through December 31, 2014.
To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed Entergys operator narrative logs, CRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 RCS Specific Activity and RCS Leak Rate (2 samples)
a. Inspection Scope
The inspectors reviewed Entergys submittal for the RCS specific activity and RCS leak rate performance indicators for the period of January 1, 2014, through December 31, 2014. To determine the accuracy of the performance indicator 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 RCS sample analysis and control room logs of daily measurements of RCS leakage and compared that information to the data reported by the performance indicator. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing an RCS sample.
b. Findings
No findings were identified.
.3 Drill/Exercise Performance, ERO Drill Participation, and ANS Reliability (3 samples)
a. Inspection Scope
The inspectors reviewed data for the following three Emergency Preparedness performance indicators:
- (1) drill and exercise performance;
- (2) ERO drill participation; and,
- (3) ANS reliability. The last NRC emergency preparedness inspection at PNPS was conducted in the second calendar quarter of 2014. Therefore, the inspectors reviewed supporting documentation from emergency preparedness drills and equipment tests from the second calendar quarter of 2014 through the fourth calendar quarter of 2014 to verify the accuracy of the reported performance indicator data. The review of the performance indicators was conducted in accordance with NRC Inspection Procedure 71151. The acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 7, was used as reference criteria.
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 Entergy entered issues into the CAP 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 CAP and periodically attended CR screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample: Inservice Testing (IST) Trending
a. Inspection Scope
The inspectors performed an in-depth review of Entergys apparent cause evaluation and corrective actions associated with CR-PNP-2014-1851, A Negative Trend of Valves Trended to Satisfy IST Requirements Has Been Identified. Specifically, the monitoring of valve stroke times for multiple safety-related valves was not identifying adverse trends in an effective and timely manner, which resulted in equipment operability issues and emergent repairs.
The inspectors assessed Entergys problem identification threshold, cause analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of Entergys corrective actions to determine whether Entergys staff were 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 Entergys CAP and the requirements of 10 CFR 50, Appendix B. In addition, the inspectors independently reviewed a sample of IST trend data for several pumps and valves and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions.
b. Findings and Observations
No findings were identified.
Entergy staff determined there were two apparent causes: 1) component and system engineers and supervisors were generally unaware of their responsibilities to review and trend IST component data as required by Entergy fleet procedures, and 2) the IST engineer did not take timely action to initiate CRs in accordance with program requirements. Entergy staff also determined that system monitoring challenge board meetings were not conducted on a regular basis during this period as required by procedure EN-DC-159, System Monitoring Program.
The inspectors concluded that Entergy staff conducted an appropriate review to identify the likely causes of the IST trending issue. The inspectors also concluded that Entergy staff identified the extent of condition which was mostly the trending of IST program data for the in scope systems; however, the review included an evaluation of the other programs where trending is performed as part of condition monitoring. Corrective actions included a review of the procedure requirements conducted between the system engineers and their supervisors, establishment of a reoccurring schedule for system monitoring challenge board meetings, training for system engineers on monitoring and trending expectations, and revisions of system monitoring plans to include IST data parameters.
The inspectors observed a system monitoring challenge board meeting for the primary containment system and confirmed the critical parameters were being tracked and included appropriate alert and action levels. The inspectors also reviewed a selection of system monitoring plans and interviewed engineering staff to verify that monitoring and trending of IST data was being conducted accordingly. The inspectors noted that the roles and responsibilities of the IST program engineer and the system engineer were reviewed by the staff and trending expectations were being communicated by the supervisors. The inspectors reviewed a selection of IST data for various components and did not identify any additional issues. The inspectors determined Entergys overall response to the issue was commensurate with the safety significance, was timely, and included appropriate compensatory actions. The inspectors concluded that actions completed were reasonable to correct the problem and prevent reoccurrence.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
Plant Events
a. Inspection Scope
For the plant event listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Entergy made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Entergys follow-up actions related to the events to assure that Entergy implemented appropriate corrective actions commensurate with their safety significance.
Automatic reactor scram following a generator load reject and LOOP during plant power reduction on January 27, 2015
b. Findings
No findings were identified.
4OA5 Other Activities
Initial Loading of the ISFSI (60855, 60855.1)
a. Inspection Scope
The inspectors observed and evaluated Entergys loading of the first of three multipurpose canisters (MPCs) associated with their initial Independent Spent Fuel Storage Installation (ISFSI) dry cask campaign on January 5-15, 2015. The inspectors reviewed Entergys activities related to initial operation and monitoring of the ISFSI. The inspectors also performed in-office reviews of documentation associated with Entergys activities during loading of the second and third MPC. The inspectors verified compliance with the Certificate of Compliance (CoC), technical specifications, regulations, and station procedures.
The inspectors observed the heavy load movement of the transfer cask and loaded MPC from the spent fuel pool to the cask decontamination and processing area. The inspectors also observed MPC processing operations including: decontamination and surveying, welding, non-destructive weld examinations, MPC draining, vacuum drying, helium backfilling, HI-TRAC/HI-STORM stack-up, installation of rail system for moving the HI-STORM from the RB, and transport of the HI-STORM to the ISFSI pad. The inspectors performed an independent verification of Entergys time-to-boil calculation for the loaded MPC to ensure that Entergy adequately calculated and tracked the time-to-boil and properly planned for contingent alternate cooling. During performance of these activities, the inspectors verified that procedure use, communication, and coordination of ISFSI activities was performed in accordance with Entergys procedures.
The inspectors attended Entergy briefings to assess their ability to identify critical steps of the evolution, potential failure scenarios, and human performance tools to prevent errors. The inspectors also reviewed training records of personnel assigned to ISFSI activities and verified all required training was completed prior to performing ISFSI operations.
The inspectors reviewed Entergys program associated with fuel characterization and selection for storage. The inspectors reviewed the first cask fuel selection package to verify that Entergy was loading fuel in accordance with the CoC, technical specifications, and procedures. The inspectors confirmed that Entergy did not plan to load any damaged fuel assemblies during this campaign. The inspectors reviewed radiation protection procedures and radiation work permits (RWPs) associated with the ISFSI loading campaign. The inspectors also reviewed the ALARA goal for the cask loading to determine the adequacy of Entergys radiological controls and to ensure that radiation worker doses were ALARA, and that project dose goals could be achieved. The inspectors reviewed radiological survey records from the current loading campaign to confirm that contact dose rates on the HI-TRAC surface were as expected. The inspectors assessed whether workers were aware of the radiological conditions in their work area and the RWP controls/limits.
The inspectors performed a walk-down of the heavy haul path to verify that no hazardous condition exists that could impact the HI-STORM. The inspectors also verified that transient combustibles greater than allowed were not being stored on the ISFSI pad. The inspectors also confirmed that vehicle entry onto the ISFSI pad was controlled in accordance with procedures.
The inspectors reviewed the actions taken by Entergy during severe winter storms on January 28 and February 14, 2015, to ensure technical specification requirements were being maintained. The inspectors also reviewed changes Entergy made to Procedure 2.1.42, Operation During Severe Weather, associated with ensuring clearing vents around the HI-STORM during winter storms was a priority of station personnel during their response, as well as the addition of sandbags around the ISFSI in cases where severe weather could lead to possible flooding conditions. The inspectors verified that the changes to the procedure were properly evaluated and made in accordance with Entergys process.
The inspectors reviewed corrective action reports and the associated follow-up actions that were generated since Entergy started planning for their initial ISFSI campaign to ensure that issues were entered into the CAP, prioritized, and evaluated commensurate with their safety significance.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On April 16, 2015, the inspectors presented the inspection results to Mr. John Dent, Site Vice President, and other members of the PNPS staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Dent Site Vice President
D. Berkland Senior Design Engineer
G. Blankenbiller Chemistry Manager
T. Bordelon Performance & Improvement Manager
D. Brugman Supervisor ALARA/Technical Support
P. Beabout Security Manager
R. Byrne Senior Licensing Engineer
D. Calabrese Emergency Preparedness Manager
B. Chenard Engineering Director
F. Clifford Operations Support Manager
S. Brewer Radiation Protection Supervisor
S. Burke Senior Design Engineer
S. Cook Chemistry Supervisor
J. Cotter Operations Training Supervisor
J. Cox Radiation Protection Operations Supervisor
B. Deevy Senior Engineering Training Instructor
- T. Glenn KoneCranes, Senior Service Technician
W. Grieves Quality Assurance
P. Harizi Senior Design Engineer
J. House Operations Training Supervisor
M. Jacobs Manager of Nuclear Oversight
G. James Reactor Engineering Supervisor
- L. Johnson Supervisor, Holtec
K. Kampschneider Senior System and Components Engineer
J. Keene System Engineer
- L. Kinney Holtec, Project Manager
- P. Kristian Project Manager, Dry Fuel Storage
J. Macdonald Senior Operations Manager
V. Magnetta Senior Operations Instructor
W. Mauro Supervisor Radiation Protection Support
E. McCaffrey System and Components Engineering Supervisor
C. McDonald Training Manager
F. McGinnis Licensing Specialist
C. McMorrow Fire Marshall
P. Miner Licensing Specialist
C. Minott Project Manager
R. Morris Senior System and Components Engineer
- J. Moylan Manager, Project & Maintenance Services
J. Norris Radiation Protection Supervisor
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. Prowse Nuclear Oversight, Supervisor
- B. Rancourt Senior Lead Engineer, Design Engineering
N. Reece System and Components Engineer
J. Sabina IST Program Engineer
K. Sejkora Senior Chemist
- R. Sheridan Operations, Control Room Supervisor
D. Sitkowski Senior Design Engineer
M. Thornhill Radiation Protection Supervisor
G. Vazquez Quality Assurance Supervisor
S. Velez Senior Lead Reactor Engineer
S. Verrochi General Manager Plant Operations
T. F. 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
- 05000293/2015001-01 NCV Failure to Perform Testing of Safety Related Undervoltage Alarm Relays (Section 1R15)