IR 05000293/2016008
| ML16060A018 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/29/2016 |
| From: | Dan Dorman Region 1 Administrator |
| To: | Dent J Entergy Nuclear Operations |
| Burritt A | |
| References | |
| IR 2016008 | |
| Download: ML16060A018 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 February 29, 2016 Mr. John Dent Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 SUBJECT: PILGRIM NUCLEAR POWER STATION - SUPPLEMENTAL INSPECTION REPORT (PHASE A) 05000293/2016008
Dear Mr. Dent:
On January 15, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed Phase A of Inspection Procedure (IP) 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input, at your Pilgrim Nuclear Power Station (Pilgrim). The enclosed inspection report documents the inspection results, which were discussed with you and members of your staff.
Consistent with the NRC Reactor Oversight Process Action Matrix in Inspection Manual Chapter 0305, Operating Reactor Assessment Program, the NRC is performing this supplemental inspection because Pilgrim transitioned into the Repetitive Degraded Cornerstone Column (Column 4), as discussed in the mid-cycle assessment letter, dated September 1, 2015 (ML15243A2591). This phase of the inspection reviewed Entergy Nuclear Operations, Inc. (Entergys) progress in addressing corrective action program weaknesses identified during previous inspections. Its objectives were to verify that Entergys evaluations of, and corrective actions for, significant performance deficiencies were sufficient to correct the deficiencies and prevent recurrence. Additionally, the inspection assessed whether Entergys evaluations into these significant deficiencies were of a depth commensurate with the significance of the issue, root and contributing causes of risk-significant deficiencies were identified, and corrective actions were taken to correct immediate problems and to prevent recurrence.
To accomplish these objectives, this inspection reviewed long-standing open corrective actions.
It also reviewed a sample of NRC violations that were not reviewed by other inspections to determine if Entergy had taken appropriate actions to address the issue. It reviewed Entergys program for classification of adverse versus non-adverse condition reports, a sample of non-adverse condition reports to ensure they were categorized correctly, and any condition reports documenting misclassification (i.e., adverse vs. non-adverse) of condition reports.
Designation in parentheses refers to an Agencywide Documents Access and Management System (ADAMS) accession number. Documents referenced in this report are publicly available using the accession number in ADAMS. Based on the samples selected for review, the inspectors determined that there were no long-standing risk-significant issues documented in the corrective action program that were not addressed, or assigned appropriate corrective actions and due dates. The inspectors concluded that, in general, Entergy classified, evaluated, and developed appropriate actions to correct past NRC violations. The inspectors also determined that Entergy appropriately classified condition reports as adverse or non-adverse. As such, based on the results of this inspection, as well as a review of performance indicators and inspection results from the fourth quarter of 2015, the NRC concluded that Pilgrim continues to operate safely, and additional regulatory actions beyond those prescribed for plants in Column 4 are not required at this time.
This inspection served as a partial completion of IP 95003, Section 02.02.a. Accordingly, Pilgrim will remain in the Repetitive Degraded Cornerstone Column of the Action Matrix until the NRC completes the required scope of IP 95003.
This report documents one finding of very low safety significance (Green), which was also determined to be a violation of NRC requirements. However, because of the very low safety significance and because it has been 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 Pilgrim. In addition, if you disagree with the cross-cutting aspect assignment discussed in the enclosure, 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 Pilgrim. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRC's ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA David C. Lew for/
Daniel H. Dorman Regional Administrator Docket No. 50-293 License No. DPR-35
Enclosure:
Inspection Report 05000293/2016008 w/Attachment: Supplementary Information
REGION I==
Docket No. 50-293 License No. DPR-35 Report No. 05000293/2016008 Licensee: Entergy Nuclear Operations, Inc. (Entergy)
Facility: Pilgrim Nuclear Power Station Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: January 11 - 15, 2016 Inspectors: R. Clagg, Senior Resident Inspector, Team Leader N. Embert, Operations Engineer N. Floyd, Reactor Inspector J. Pfingsten, Reactor Engineer (observing)
Approved by: Arthur L. Burritt, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000293/2016008; 01/11/2016 - 01/15/2016; Pilgrim Nuclear Power Station (Pilgrim); Supplemental Inspection - Inspection Procedure (IP) 95003.
The inspection was conducted by a senior resident inspector, an operations engineer, a reactor inspector, and a project engineer. The inspectors identified one non-cited violation (NCV),
which was 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, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of U.S. 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.
The NRC performed this supplemental inspection in accordance with IP 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input, to review Energys progress in addressing corrective action program (CAP) weaknesses identified in previous inspections. This inspection served as partial completion of IP 95003, Section 02.02.a.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, because Entergy did not promptly correct a condition adverse to quality for the core spray system.
Specifically, though Entergy identified in March 2015 that core spray system leakage was the likely cause of voiding in the system, Entergy had not taken timely action to identify the source of the leakage and address the issue. Entergys immediate corrective actions included entering the issue into the CAP as a condition report (CR)-PNP-2016-00201 and generating a work order to repair seat leakage from the core spray test return line motor-operated valve, MO-1400-4A.
The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined this issue is more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, an unmonitored increase in core spray system leakage could result in an unanalyzed condition where the operability of the core spray system cannot be assured. In accordance with IMC 0609,
Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated July 1, 2012, the inspectors determined the finding was of very low safety significance (Green) because it did not represent an actual loss of function of one or more non-technical specification (TS) trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. This finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because Entergy did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, Entergy failed to fully evaluate the source of core spray system leakage identified in CR-PNP-2015-01406 because they closed out the CR to another CR with a different focus. [P.2] (Section 4OA4.2)
REPORT DETAILS
OTHER ACTIVITIES
4OA4 Supplemental Inspection
.1 Inspection Scope
The NRC performed this supplemental inspection in accordance with IP 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input, to review Entergys progress in addressing CAP weaknesses identified in previous inspections. This inspection served as partial completion of IP 95003, Section 02.02.a. The objectives of this inspection were to verify that Entergys evaluations of, and corrective actions for, significant performance deficiencies have been sufficient to correct the deficiencies and prevent recurrence. IP 95003 provides specific guidance for this objective and directs the inspectors to evaluate whether Entergys evaluations into significant deficiencies are of a depth commensurate with the significance of the issue; that root and contributing causes of risk-significant deficiencies are identified; and corrective actions are taken to correct immediate problems and to prevent recurrence. Specifically, inspectors:
- (1) sampled long-standing open corrective actions;
- (2) reviewed a sample of NRC violations that have not been reviewed by other inspections to determine if Entergy has taken appropriate actions to address the issues; and
- (3) reviewed Entergys program for classification of adverse versus non-adverse CRs, reviewed a sample of non-adverse CRs to ensure they are categorized correctly, and reviewed any CRs documenting misclassification (i.e., adverse vs. non-adverse) of CRs;
.2 Evaluation of the Inspection Requirements
2.01 Review of Licensee Control Systems for Identifying, Assessing, and Correcting Performance Deficiencies a. Determine whether licensee evaluations of, and corrective actions to, significant performance deficiencies have been sufficient to correct the deficiencies and prevent recurrence.
.1 Review of Long-Standing Open Corrective Actions
The inspectors reviewed Entergys CAP procedures which described the administrative process for initiating and resolving problems, primarily through the use of CRs. To verify that corrective actions were being properly evaluated, assigned a significance commensurate with their safety importance, and appropriately completed or extended, inspectors reviewed CRs initiated prior to October 1, 2013, with corrective actions that were still open at the time of the inspection. The inspectors determined that for the CRs reviewed, Entergy, in general, was effective in completing corrective actions or assigning appropriate due date extensions for these issues. The team identified one example, listed below, where the corrective actions for an issue were not taken in a timely manner.
In the documentation for CR-PNP-2008-02638, a heat load analysis determined that the control room temperature would reach 114°F with a loss of normal heating, ventilation, and air conditioning, and potentially cause an operator habitability issue.
As a corrective action, Entergy staff developed a modification to install an augmented cooling system in order to mitigate the high temperatures. The corrective actions for this condition were extended multiple times until final suspension of the modification project in 2015. The inspectors evaluated this issue using IMC 0612, Appendix B, Issue Screening, and determined that this issue was minor. The inspectors noted that there are no current licensing or design basis documents that establish control room temperature limitations for operator habitability; however, there would be increased staffing challenges due to heat stress management and the resultant short stay times. Entergy entered this observation into their CAP for further evaluation as CR-PNP-2016-00276.
.2 Review of Corrective Actions for Past NRC Violations
The inspectors reviewed Entergys CAP procedures which described the administrative process for initiating the review of issues, specifically inspection report findings identified by the NRC, primarily through the use of CRs. The inspectors reviewed a sample of CRs initiated as a result of NRC violations issued since October 1, 2013. The inspectors determined that, in general, Entergy appropriately initiated CRs as a result of NRC violations. CRs were classified in accordance with procedure guidance, investigations were conducted at the level specified by the CAP, and suitable corrective actions were developed. The inspectors reviewed corrective actions and determined that, in general, they were completed or appropriately extended. The inspectors identified an issue where the corrective actions for NRC violations were not adequately completed.
NRC Inspection Report 05000293/2014002 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14129A282) documents an NCV (2014002-02) related to an inadequate procedure for determining operability of the shutdown transformer. Specifically, an NSTAR calculation concluded that certain alternative offsite power lines did not satisfy Pilgrims minimum voltage criteria for the shutdown transformer, but this information was never incorporated into the degraded 23kV line procedure for determining the operability of the shutdown transformer.
Entergy procedure EN-LI-102, Corrective Action Program, requires Entergy staff to document the receipt of NRC violations as a CR; however, this did not occur. The inspectors noted that EN-LI-102 would have likely directed performance of an apparent cause evaluation and could have prevented the receipt of a second NCV for a similar issue in 2015. NRC Inspection Report 05000293/2015003 (ADAMS Accession No.
ML15317A030) documents an NCV (2015003-03) issued for an inadequate operability assessment of the shutdown transformer because Entergy staff did not appropriately evaluate changes made to the shutdown transformer when an alternate offsite power configuration was used that resulted in the transformer being inoperable. The inspectors noted that the degraded 23kV procedure contained incorrect information at that time, which the operations staff used during the operability evaluation. The inspectors determined that Entergys failure to document NCV 2014002-02 as a CR and perform a cause evaluation in accordance with EN-LI-102 was a performance deficiency. Because this issue is an additional contributor to the inadequate operability assessment, and the enforcement aspects of the inadequate operability assessment are already addressed as NCV 2015003-03, this issue is not being documented as a separate finding. Entergy entered this issue into their CAP as CR-PNP-2016-00302 for further evaluation.
.3 Review of Classification of Adverse Versus Non-Adverse Condition Reports
The inspectors reviewed Entergys CAP procedures which described the administrative process for initiating the review of problems, primarily through the use of CRs. In Entergy procedure EN-LI-102, Corrective Action Program, adverse conditions are defined as those conditions which include conditions adverse to quality plus conditions related to areas such as design basis, licensing basis, NRC regulations and commitments, and equipment required to support safety-related equipment. Non-adverse conditions are those conditions that do not fall within the definition of adverse conditions and are not required to be tracked in the CAP.
The inspectors reviewed a sample of CRs generated since September 2014, when Entergy implemented the process for classifying CRs as adverse or non-adverse. The inspectors determined that Entergy appropriately classified CRs as adverse or non-adverse. The inspectors did identify a gap in the guidance contained in procedure EN-LI-102 for the classification of CRs as adverse or non-adverse. Specifically, the inspectors identified that guidance for classifying CRs as adverse tended to require an actual adverse impact. No clear guidance exists for those situations where an actual adverse impact does not occur (i.e., close calls or near misses). This has the effect of creating a gap in the guidance where the classification of CRs is at the discretion of the reviewing body. The inspectors identified that in these situations, the reviewing body tended to classify CRs as non-adverse. The inspectors did not identify any CRs where the classification as non-adverse was subjective and resulted in a negative consequence. Entergy documented this observation in their CAP as CR-HQN-2016-00039.
b. Findings
Introduction.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because Entergy did not promptly correct a condition adverse to quality for the core spray system. Specifically, though Entergy identified in March 2015 that core spray system leakage was the likely cause of voiding in the system, Entergy had not taken timely action to identify the source of the leakage and address the issue.
Description.
On January 27, 2015, during a loss of offsite power event, the A loop of core spray experienced indications of voiding in the discharge line. Following an inquiry by NRC inspectors, Entergy entered the issue into their CAP as CR-PNP-2015-01406.
Subsequent engineering analysis, completed in March 2015, confirmed the presence of voiding and assessed the impacts of the voiding on core spray system operability. The inspectors reviewed CR-PNP-2015-01406 and noted that Entergy determined the core spray system remained operable, and also identified core spray system leakage as a likely cause of the voiding. The enforcement aspects associated with the failure to identify partial voiding in the core spray system are documented in NRC Inspection Report 05000293/2015007 (ADAMS Accession No. ML15147A412) as NCV 2015007-
05.
Entergy entered this NCV into the CAP as CR-PNP-2015-05537. Entergy procedure EN-LI-102, Corrective Action Program, Revision 25, requires a B level apparent cause evaluation be performed for NRC-documented NCVs. The inspectors reviewed CR-PNP-2015-05537 and noted it was closed to a root cause evaluation documented in CR-PNP-2015-05533, which was originally initiated to address programmatic issues regarding failures to identify conditions adverse to quality. The inspectors noted that CR-PNP-2015-05533 did not evaluate the technical issue of core spray system leakage and the potential for system voiding if the non-safety-related condensate transfer system was lost, as was identified in CR-PNP-2015-01406.
In November 2015, Entergy initiated CR-PNP-2015-09156 as a result of an identified increase of leakage into the torus and elevated temperatures in the test return line of the A loop of core spray header. The inspectors reviewed CR-PNP-2015-09156 and noted that Entergy documented the elevated temperatures could be an indication of condensate transfer leaking out of the core spray system through the test return line. In December 2015, Entergy identified the core spray test return line motor operated valve, MO-1400-4A, as the source of leakage from the core spray system into the torus.
Though the valve leakage was documented in a work order, the inspectors noted that this issue was not entered into the CAP until January 12, 2016. The inspectors also noted that Entergy did not have a process in place to monitor for increases in core spray system leakage which could result in an unanalyzed condition where the operability of the core spray system cannot be assured.
Entergy procedure EN-LI-102 defines a condition adverse to quality, in part, as a failure, malfunction, or deficiency that has the potential to affect safety-related functions of systems, structures, or components. The inspectors concluded core spray system leakage was a known condition adverse to quality since March 2015, based on the information documented in CR-PNP-2015-01406 and the subsequent engineering analysis. Because Entergy did not adequately evaluate the technical aspects of this issue in CR-PNP-2015-05533, identification of the source of the leakage was delayed until December 2015. Therefore, the inspectors also concluded that Entergy did not promptly correct this condition adverse to quality as required by 10 CFR 50, Appendix B, Criterion XVI. Entergy documented this issue in CR-PNP-2016-00201 and CR-PNP-2016-00311.
Analysis.
The inspectors determined that not promptly identifying and correcting a condition adverse to quality, as required by 10 CFR 50, Appendix B, Criterion XVI, was a performance deficiency. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined this issue is more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, an unmonitored increase in core spray system leakage could result in an unanalyzed condition where the operability of the core spray system cannot be assured. In accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated July 1, 2012, the inspectors determined the finding was of very low safety significance (Green) because it did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program.
The inspectors determined this issue had a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because Entergy did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, Entergy failed to fully evaluate the source of core spray system leakage identified in CR-PNP-2015-01406 because they closed out the CR to another CR with a different focus. [P.2]
Enforcement:
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality are promptly corrected. Contrary to the above, from March 2015 until January 2016, Entergy failed to promptly identify and correct a condition adverse to quality involving core spray system leakage. Entergys immediate corrective actions included entering the issue into the CAP as CR-PNP-2016-00201 and generating a work order to repair valve MO-1400-4A. Because the finding is of very low safety significance (Green) and was entered into Entergys CAP as CR-2015-00311, this violation is being treated as an NCV, in accordance with section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000293/2016008-01, Failure to Promptly Identify and Correct Core Spray System Leakage)
4OA6 Meetings, Including Exit
On January 15, 2016, the inspectors presented the inspection results to Mr. John Dent, Site Vice President, and other members of his staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- J. Dent, Site Vice President
- S. Asplin, Senior System and Components Engineer
- G. Blankenbiller, Manager, Chemistry
- J. Gerety, Manager, Systems and Components
- D. Miller, Maintenance Department Performance Improvement Coordinator
- P. Miner, Regulatory Assurance
- J. ODonnell, System Engineer
- J. Ohrenberger, Manager, Maintenance
- E. Perkins, Manager, Regulatory Assurance
- A. Zelie, Manager, Radiation Protection
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened and Closed
- 05000293/2016008-01 NCV Failure to Promptly Identify and Correct Core Spray System Leakage (Section 4OA4.2)