IR 05000293/2018005
| ML18240A030 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/28/2018 |
| From: | David Lew Region 1 Administrator |
| To: | Brian Sullivan Entergy Nuclear Operations |
| Dimitriadis A | |
| References | |
| IR 2018005 | |
| Download: ML18240A030 (7) | |
Text
August 28, 2018
SUBJECT:
PILGRIM NUCLEAR POWER STATION - ASSESSMENT FOLLOW-UP LETTER AND UPDATED INSPECTION PLAN (INSPECTION REPORT 05000293/2018005)
Dear Mr. Sullivan:
The NRC completed its quarterly performance assessment of Pilgrim Nuclear Power Station (PNPS) on August 1, 2018, reviewing performance indicators, inspection results, and enforcement actions from July 1, 2017 through June 30, 2018. This letter informs you of the NRCs assessment of your facility during this period and our plans for future inspections. This letter supplements, but does not supersede, the annual assessment letter issued on February 28, 2018.
The NRC determined the performance at PNPS remains in Column 4, or the Multiple/Repetitive Degraded Cornerstone Column, of the NRCs Reactor Oversight Process (ROP) Action Matrix in Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program. The NRC also determined that Entergy continued to operate PNPS safely and securely, and that additional regulatory action beyond Column 4 was not warranted. Notwithstanding placement remained within Column 4, our review of performance indicators and inspection results for PNPS indicated improved performance over the course of the past 12 months. The NRC observed progress by site leadership through their continued reinforcement of site standards and expectations and conservative decision making. We have also noted progress on the completion of actions stipulated in the recovery plan; however, a significant amount of work related to the performance recovery of PNPS remain for Entergy to be completed. The NRC will inspect and verify that these recovery actions are adequately implemented to support sustainable performance improvement.
In 2017, the NRC completed Inspection Procedure (IP) 95003 inspection, as required by IMC 0305 for all Column 4 plants. The inspection was conducted in three phases (A through C)
(ML16060A018, ML16144A027, and ML17129A2171). The results of these inspections were used to inform the performance improvements described in the Confirmatory Action Letter (CAL) issued on August 2, 2017 (ML17214A088), and updated on June 7, 2018 (ML18158A134), and August 23, 2018 (ML18235A028), which confirmed Entergys commitment
1 The designation in parentheses refers to an Agencywide Documents Access and Management System (ADAMS) Accession Number. Documents referenced in this letter are publicly available using the Accession Number in ADAMS to perform specific corrective actions to resolve the causes for the performance decline that led to PNPSs transition to the Multiple/Repetitive Degraded Cornerstone Column. The NRC is in the process of conducting quarterly CAL follow-up inspections, which started in the 4th quarter of 2017, to ensure adequate actions are taken to complete the CAL commitments. The results of these inspections will support the future performance assessments of PNPS that the NRC will use to determine whether the CAL can be closed, and whether, in accordance with IMC 0305, Pilgrim should transition out of Column 4 of the ROP Action Matrix, or the NRC should take additional regulatory action in accordance with IMC 0305. NRC staff is currently finalizing documentation of the results of the third quarterly CAL follow-up inspection. Two additional quarterly CAL follow-up inspections are scheduled between now and the end of 2019 with additional inspections to be scheduled as warranted.
After reviewing PNPSs performance in addressing the White finding related to the A safety relief valve failure during the second CAL follow-up inspection, the NRC concluded that your actions met the objectives of IP 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs (ML18164A224). In accordance with the guidance in IMC 0305, Operating Reactor Assessment Program, this White finding is closed and will no longer be considered in assessing plant performance. All Column 4 inputs are now closed; however, PNPS will remain within the Multiple/Repetitive Degraded Cornerstone column (Column 4) of the NRCs ROP Action Matrix pending completion of all actions needed to close the CAL.
NRC senior management will continue to conduct quarterly reviews of PNPS performance to assess the effectiveness of improvement efforts. The NRC added resources to support additional inspection at PNPS, and will continue to engage in, Entergy Nuclear Operations, Inc.
frequent site visits.
The enclosed inspection plan lists the inspections scheduled through 2019. In addition to the baseline inspections and the CAL inspections, the NRC will conduct IP 60855.1, Operation of an ISFSI Independent Spent Fuel Storage Installation at Operating Plants. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. Routine inspections performed by resident inspectors are not included in the inspection plan.
Furthermore, the NRC has taken into consideration your intention to cease operations by June 1, 2019 as part of the inspection planning process. The ROP and Inspection Program provides inherent flexibility to permit inspection sampling adjustments to be made in order to better inform our assessment of performance during this unique period of transition from operating status to permanent shutdown. Any inspections scheduled after the final shutdown date will be reevaluated at that time for applicability. Once you formally notify the NRC that PNPS is permanently shut down and that all fuel has been removed from the reactor vessel, then PNPS will transition from IMC 0305, Operating Reactor Assessment Program, and IMC 2515, Light Water Reactor Inspection Program - Operations Phase, to IMC 2561, Decommissioning Power Reactor Inspection Program. As a result, inspections after June 2019 are tentative; and, the NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes.
From January 1, 2017 to December 31, 2017, the NRC issued three Severity Level IV Traditional Enforcement Violations for impeding the regulatory process. Therefore, the NRC plans to conduct IP 92723, Follow-Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, to follow-up on these violations. Following the completion of the 2017 end-of-cycle assessment, the NRC identified two cross-cutting themes at PNPS associated with the Problem Identification & Resolution Cross-Cutting Area: one theme due to exceeding the threshold of 12 inspection findings (13 total) assigned with cross-cutting aspects in this cross-cutting area for this 12-month assessment period, and the other due to having at least 6 inspection findings (8 total) assigned with the cross-cutting aspect Evaluation [P.2]. This was the only assessment period with which these themes were assigned. As of the completion of this second quarter performance assessment, due to the reduction in the number of associated findings over this 12-month assessment period, PNPS no longer has either of these cross-cutting themes in the Problem Identification & Resolution Cross-Cutting Area.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRCs Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR ), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.
Please contact Anthony Dimitriadis at (610)337-6953 with any questions you have regarding this letter.
Sincerely,
/RA/
David C. Lew Regional Administrator
Docket No. 50-293 License No. DPR-35
Enclosure:
Inspection Plan
cc: Distribution via ListServ
SUNSI Review
Non-Sensitive Sensitive
Publicly Available Non-Publicly Available
OFFICE RI/DRP RI/DRP RI/ORA
NAME LCline via email ADimitriadis DLew
DATE 8/24/18 8/24/18 8/27/18
Pilgrim 07/01/2018 - 06/30/2020 Unit Start End Activity CAC Title Staff Count ISFSI LOADING CAMPAIGN INSPECTION
1 07/09/2018 07/20/2018 IP 60855 001001 Operation Of An ISFSI
07/09/2018 07/20/2018 IP 60855.1 000590 Operation of an Independent Spent Fuel Storage Installation at Operating Plants RP ALARA, AIRBORNE, IP71124.02, IP71124.03
1 07/09/2018 07/13/2018 IP 71124.02 000726 Occupational ALARA Planning and Controls
07/09/2018 07/13/2018 IP 71124.03 000727 In-Plant Airborne Radioactivity Control and Mitigation Annual PIR Sample - HPCI Vibration
1 08/13/2018 08/17/2018 IP 71152 000748 Problem Identification and Resolution RAD INSTRUMENTATION IP71124.05
1 08/27/2018 08/31/2018 IP 71124.05 000729 Radiation Monitoring Instrumentation PROTECTIVE STRATEGY, TSR
1 08/27/2018 08/31/2018 IP 71130.05 000737 Protective Strategy Evaluation
08/27/2018 08/31/2018 IP 71130.14 000743 Review of Power Reactor Target Sets Confirmatory Action Letter 4
1 09/10/2018 09/14/2018 IP 92702 000238 Followup On Corrective Actions For Violations And Deviations TRIENNIAL FIRE PROTECTION
1 10/15/2018 10/19/2018 IP 71111.05T 000696 Fire Protection (Triennial)
10/29/2018 11/02/2018 IP 71111.05T 000696 Fire Protection (Triennial)
ALARA, AIR ACT, RAD INSTRUM, PI's 71124.02, 03, 05, PR01, OR01
1 10/15/2018 10/19/2018 IP 71124.02 000726 Occupational ALARA Planning and Controls
10/15/2018 10/19/2018 IP 71124.03 000727 In-Plant Airborne Radioactivity Control and Mitigation
10/15/2018 10/19/2018 IP 71124.05 000729 Radiation Monitoring Instrumentation
10/15/2018 10/19/2018 IP 71151 000746 Performance Indicator Verification IP 92723
1 10/29/2018 11/02/2018 IP 92723 000914 Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the S EP EXERCISE INSPECTION
1 11/05/2018 11/09/2018 IP 71114.01 000716 Exercise Evaluation 7/27/2018 11:34:43 AM Page 1 of 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
IP 22 Inspection Activity Plan Report Enclosure
Pilgrim 07/01/2018 - 06/30/2020 Unit Start End Activity CAC Title Staff Count EP EXERCISE INSPECTION
1 11/05/2018 11/09/2018 IP 71151 001397 Performance Indicator Verification Confirmatory Action Letter 5
1 12/10/2018 12/14/2018 IP 92702 000238 Followup On Corrective Actions For Violations And Deviations RAD HAZARD IP 71124.01
1 02/11/2019 02/15/2019 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls PI&R BIENNIAL
1 02/25/2019 03/01/2019 IP 71152B 000747 Problem Identification and Resolution
03/11/2019 03/15/2019 IP 71152B 000747 Problem Identification and Resolution ACCESS CONTROL, EQUIP PERF, TRAINING
1 04/08/2019 04/12/2019 IP 71130.02 000734 Access Control
04/08/2019 04/12/2019 IP 71130.04 000736 Equipment Performance, Testing, and Maintenance
04/08/2019 04/12/2019 IP 71130.07 000739 Security Training
04/08/2019 04/12/2019 IP 71151 001338 Performance Indicator Verification Evaluations of Changes, Tests and Experiments (50.59)
1 04/15/2019 04/19/2019 IP 71111.17T 000709 Evaluations of Changes, Tests, and Experiments RP DOSE ASSESS IP 71124.04
1 04/15/2019 04/19/2019 IP 71124.04 000729 Occupational Dose Assessment RAD GAS AND LIQUID EFFLUENT TREATMENT, DOSE ASSESS, 71124.06, 04
1 05/13/2019 05/17/2019 IP 71124.04 000729 Occupational Dose Assessment
05/13/2019 05/17/2019 IP 71124.06 000730 Radioactive Gaseous and Liquid Effluent Treatment Triennial Heat Sink
1 07/15/2019 07/19/2019 IP 71111.07T 000700 Heat Sink Performance -Triennial PILGR REQUAL INSP WITH P/F RESULTS
1 09/09/2019 09/13/2019 IP 71111.11A 000703 Licensed Operator Requalification Program and Licensed Operator Performance (Annual)
09/09/2019 09/13/2019 IP 71111.11B 000704 Licensed Operator Requalification Program and Licensed Operator Performance (Biennial)
7/27/2018 11:34:43 AM Page 2 of 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
IP 22 Inspection Activity Plan Report
Pilgrim 07/01/2018 - 06/30/2020 Unit Start End Activity CAC Title Staff Count EQ PROGRAM
1 11/04/2019 11/08/2019 IP 71111.21N 000714 Design Bases Assurance Inspection (Programs)
11/18/2019 11/22/2019 IP 71111.21N 000714 Design Bases Assurance Inspection (Programs)
EP PROGRAM INSPECTION
1 12/02/2019 12/06/2019 IP 71114.02 000717 Alert and Notification System Testing
12/02/2019 12/06/2019 IP 71114.03 000718 Emergency Response Organization Staffing and Augmentation System
12/02/2019 12/06/2019 IP 71114.05 000720 Correction of Emergency Preparedness Weaknesses and Deficiencies
12/02/2019 12/06/2019 IP 71151 001397 Performance Indicator Verification PILGRIM EP EXERCISE INSPECTION
1 04/06/2020 04/10/2020 IP 71114.01 000716 Exercise Evaluation
04/06/2020 04/10/2020 IP 71151 001397 Performance Indicator Verification 7/27/2018 11:34:43 AM Page 3 of 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
IP 22 Inspection Activity Plan Report