IR 05000293/2008004
| ML083020357 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/28/2008 |
| From: | Diane Jackson NRC/RGN-I/DRP/PB5 |
| To: | Bronson K Entergy Nuclear Operations |
| jackson d 610-337-5306 | |
| References | |
| IR-08-004 | |
| Download: ML083020357 (31) | |
Text
October 28, 2008
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2008004
Dear Mr. Bronson:
On September 30, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed report documents the results, which were discussed on October 14, 2008, with Mr. Stephen Bethay, Director of Nuclear Safety Assurance, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/ Original Signed By:
Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Docket No.
50-293 License No. DPR-35
Enclosure:
Inspection Report 05000293/2008004 w/Attachment: Supplemental Information
SUMMARY OF FINDINGS
IR 05000293/2008004; 07/01/2008-09/30/2008; Pilgrim Nuclear Power Station; Routine Quarterly
Integrated Report.
The report covered a three month period of inspection by resident and region-based inspectors.
The NRC's program for overseeing the safe operation of nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Pilgrim Nuclear Power Station (PNPS) operated at or near 100 percent power during the inspection period with the following exceptions: On August 20, 2008, Entergy reduced power to approximately 40 percent to perform a thermal backwash on the main condenser; Entergy resumed 100 percent power operation on August 21, 2008. On August 22, 2008, Entergy reduced power to approximately 85 percent to perform a Rod Pattern Adjustment; Entergy resumed 100 percent power on August 22, 2008. The plant remained at or near 100 percent for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Seasonal Susceptibility
a.
Inspection Scope (1 sample)
The inspectors performed a review of severe weather preparations during the week of July 14, 2008, to evaluate the sites readiness for the hurricane season, including the readiness of three risk-significant systems. The inspection examined selected equipment and supporting structures to determine if they were configured in accordance with Entergy procedures and if adequate controls were in place to ensure functionality of the systems.
The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and compared the UFSAR with procedure requirements to ascertain if procedures were consistent with the UFSAR. The inspectors performed partial walkdowns of the salt service water system, fire water system, and switchyard to determine the adequacy of equipment protection from the effects of hurricanes. Documents reviewed during the inspection are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
.2 Impending Storm
a.
Inspection Scope (1 sample)
On September 6, 2008, Tropical Storm Hanna was tracking to impact the Pilgrim plant that evening and into the next morning. The inspectors responded to the site that day to review Entergys preparations for the tropical storm and the high winds expected to accompany the storm. The inspectors reviewed Entergys severe weather procedures including; operations during severe weather, coastal storm preparations, and high winds (hurricane)procedures. The inspectors also reviewed the stated plant risk given the external risk increase from the storm and compared this to equipment that was out of service to determine if there was an overall increase in risk. The inspectors toured the A and B Residual Heat Removal (RHR) Quadrants, the Reactor Core Isolation Cooling (RCIC)
Quadrant, the High Pressure Coolant Injection (HPCI) room, the Control Rod Drive (CRD)
Quadrant, as well as other areas of the Radiologically Controlled Area. The inspectors also conducted a tour of the plant grounds and the switchyard to determine if loose debris or other material could become airborne in the presence of high winds and thereby potentially impact safety related equipment. Documents reviewed during this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a.
Inspection Scope (3 samples)
The inspectors performed three partial system walkdowns during this inspection period.
The inspectors reviewed the documents listed in the Attachment to determine the correct system alignment. The inspectors conducted a partial walkdown of each system to determine if the critical portions of the selected systems were correctly aligned in accordance with these procedures and to identify any discrepancies that may have had an effect on operability. The walkdowns included selected switch and valve position checks, and verification of electrical power to critical components. Finally, the inspectors evaluated other elements, such as material condition, housekeeping, and component labeling. The following systems were reviewed based on their risk significance for the given plant configuration:
- B RHR following Logic Testing;
- Fire Water System Equipment during maintenance on the A Fire Water Tank; and
- B Emergency Diesel Generator (EDG) during Electrical Bus A5 Logic Testing.
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown
a.
Inspection Scope (1 sample)
The inspectors completed a detailed review of the HPCI System to verify the functional capability of the system. The inspectors conducted a walkdown of the system to determine whether the critical components, such as valves, switches, and breakers were aligned in accordance with procedures and to identify any discrepancies that could have an effect on operability. The inspectors discussed system health with the system engineer to determine whether the deficiencies significantly affected the HPCI system function. The inspectors also reviewed recent condition reports (CRs) to determine whether HPCI equipment problems were being identified and appropriately resolved. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
Fire Protection - Tours (71111.05Q)
a.
Inspection Scope (5 samples)
The inspectors performed walkdowns of five fire protection areas during the inspection period. The inspectors reviewed Entergy's fire protection program to determine the required fire protection design features, fire area boundaries, and combustible loading requirements for the selected areas. The inspectors walked down these areas to assess Entergy's control of transient combustible material and ignition sources. In addition, the inspectors evaluated the material condition and operational status of fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors then compared the existing condition of the areas to the fire protection program requirements to determine whether all program requirements were met. In addition, the inspectors reviewed Entergys contingency plan for fire water makeup during maintenance on the A Fire Water Tank. Documents reviewed during the inspection are listed in the
. The fire protection areas reviewed were:
$
B RHR/Core Spray Quadrant - Fire Zone 1.2;
$
Control Rod Drive (CRD) Pump Quadrant Mezzanine Level - Fire Zone 1.8;
$
Fire Water Tank A Out of Service affecting multiple areas;
$
Control Building (Control Room Heating, Ventilation, and Air Conditioning El. 51) -
Fire Zone 3.1; and
$
Cable Spreading Room - Fire Zone 3.2.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
Internal Flooding Inspection
a.
Inspection Scope (1 sample)
The inspectors walked down the B RHR quadrant, Flood Zone RB-17D, and associated flood propagation pathways, to assess the effectiveness of Entergys internal flood control measures. The inspectors assessed the condition of curbing, floor drains, and water-tight doors. The inspectors also evaluated whether potential sources of internal flooding were analyzed. Documents reviewed during the inspection are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
a.
Inspection Scope (1 sample)
The inspectors reviewed one sample of Entergys program for maintenance, testing, and monitoring of risk significant heat exchangers (HXs) to assess the capability of the HXs to perform their design functions. The inspectors assessed whether the HX program conformed to Pilgrims commitments to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment. In addition, the inspectors evaluated whether any potential common cause heat sink performance problems could affect multiple HXs in mitigating systems or result in an initiating event. Based on risk significance and prior inspection history, the B RHR system HX was selected for review. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No Findings of significance were identified.
1R11 Licensed Operator Requalification Program
Resident Inspector Quarterly Review (71111.11Q)
a.
Inspection Scope (1 sample)
The inspectors observed one sample of licensed operator requalification testing on September 23, 2008. Specifically, the inspectors observed crew response to three accident scenarios including intake structure fouling in conjunction with a HPCI steam line break, a Safety Relief Valve (SRV) failing open resulting in high containment pressure, and a RCIC isolation in conjunction with the loss of hotwell level control. The inspectors assessed the testing to determine if the training evaluators adequately addressed observed deficiencies regarding the Emergency Operating Procedures (EOPs) and Emergency Action Level (EAL) classification and notification. In addition, the inspectors conducted a simulator fidelity review to determine if the arrangement of the simulator instrumentation and controls closely paralleled that of the control room. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a.
Inspection Scope (2 samples)
The inspectors reviewed the two samples listed below for items such as:
- (1) appropriate work practices;
- (2) identifying and addressing common cause failures;
- (3) scoping in accordance with 10 CFR 50.65(b) of the Maintenance Rule (MR);
- (4) characterizing reliability issues for performance;
- (5) trending key parameters for condition monitoring; (6)charging unavailability for performance;
- (7) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and
- (8) appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as (a)(1). In addition, the inspectors reviewed the appropriateness of excluding infrequently performed maintenance activities from SSC unavailability performance criteria.
Documents reviewed are listed in the Attachment. Items reviewed included the following:
$
Neutron Monitoring System Functional Failures; and
$
Evaluation of Maintenance Rule (a)(1) status for the A EDG.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a.
Inspection Scope (5 samples)
The inspectors evaluated five online maintenance risk assessments for planned maintenance activities. The inspectors reviewed maintenance risk evaluations, work schedules, and control room logs to determine if concurrent maintenance or surveillance activities adversely affected the plant risk already incurred with out-of-service components.
The inspectors verified the appropriate use of Entergys risk assessment tool, Equipment Out of Service (EOOS), and entry into appropriate risk categories. The inspectors evaluated whether Entergy took the necessary steps to control work activities, minimized the probability of initiating events, and maintained the functional capability of mitigating systems. The inspectors assessed Entergy's risk management actions during plant walkdowns. Documents reviewed during the inspection are listed in the Attachment. The inspectors reviewed the conduct and adequacy of maintenance risk assessments for the following maintenance and testing activities:
$
Fire Tank A Out of Service;
$
Yellow Risk Assessment During Station Blackout EDG Outage;
$
Risk Assessment of inoperability of Low Pressure Coolant Injection (LPCI) during HPCI run;
$
Yellow Risk Assessment of HPCI inoperability during Breaker and Valve Maintenance; and
$
Yellow Risk Assessment During EDG A Initiation by RHR Logic.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a.
Inspection Scope (4 samples)
The inspectors reviewed four operability determinations associated with degraded or non-conforming conditions to determine if the operability determination was justified and if the mitigating systems or those affecting barrier integrity remained available such that no unrecognized increase in risk had occurred. The inspectors also reviewed compensatory measures to determine if the compensatory measures were in place and were appropriately controlled. The inspectors reviewed licensee performance against related Technical Specifications (TS) and UFSAR requirements. Documents reviewed during the inspection are listed in the Attachment. The inspectors reviewed the following degraded or non-conforming conditions:
$
CR-PNP-2008-2095, HPCI/RCIC Cooling/Condensate Storage Tank Air Introduction During Pressure Control Mode;
$
CR-PNP-2008-1995, Air Cooled Breaker 104B Disconnect Not Seating Properly;
$
CR-PNP-2008-2147, Defects in KWN-R-15 Fuses for B RHR Pump Motors; and
$
CR-PNP-2003-3546, Lack of Ventilation in D8/D9 Motor Control Center Enclosure.
b. Findings
No findings of significance were identified.
1R18 Plant Modifications
.1 Permanent Modification
a.
Inspection Scope (1 sample)
The inspectors reviewed Permanent Modification ERO6112309, Replace Unit Auxiliary Transformer (UAT) circuit breaker 8-1 with a Magnetic Only Style, and the associated 10 CFR 50.59 screening, to determine whether the licensing bases and performance capability of the associated system had been degraded through the modification. A walkdown was performed to determine whether the modified circuit breaker would be subject to the same conditions that degraded the performance of the old circuit breaker.
The inspectors reviewed applicable condition reports, calculations, and electrical drawings to determine whether they properly reflected the permanent modification. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 Temporary Modification
a.
Inspection Scope (1 sample)
The inspectors reviewed Temporary Modification Engineering Change (EC) 5000071914, Install Four Clamps on P-208A Discharge Head to Base Plate to Reduce Vibration, to determine whether the performance capability of the A Salt Service Water Pump had been degraded through the modification. A walkdown was performed to determine whether the material condition and structural integrity of the pumps base plate had degraded. The inspectors reviewed applicable drawings to determine whether they properly reflected the temporary modification. In addition, the inspectors reviewed pump vibration data before and after the modification to determine whether the modification caused any negative trends. Documents reviewed during the inspection are listed in the
.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a.
Inspection Scope (8 samples)
The inspectors reviewed eight samples of post-maintenance tests (PMT) during this inspection period. The inspectors reviewed these activities to determine whether the PMT adequately demonstrated that the safety-related function of the equipment was satisfied, given the scope of the work performed, and that operability of the system was restored. In addition, the inspectors evaluated the applicable test acceptance criteria to verify consistency with the associated design and licensing bases, as well as TS requirements.
The inspectors also evaluated whether conditions adverse to quality were entered into the corrective action program for resolution. Documents reviewed during the inspection are listed in the Attachment. The following maintenance activities and their post-maintenance tests were evaluated:
$
Replacement of RCIC Steam High Flow Relay;
$
B EDG Motor Operated Controller Replacement;
$
A Control Room High Efficiency Air Filtration system maintenance;
$
HPCI Turbine Gland Seal Hotwell Pump P-220 Breaker Maintenance and HPCI Turbine Steam Supply Valve Maintenance;
$
Replacement of Charcoal Filter Cells in the Standby Gas Treatment System;
$
Station Blackout Diesel Generator Stator Winding, Exciter Field Winding, and Cable Insulation Maintenance and Testing;
$
Shutdown Transformer Inspection and Testing of F15 Spark Gap; and
$
Startup Transformer Maintenance and Testing.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a.
Inspection Scope (7 samples)
The inspectors reviewed seven samples of surveillance activities to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions. The inspectors reviewed selected prerequisites and precautions to determine if they were met and if the tests were performed in accordance with the procedural steps. Additionally, the inspectors evaluated the applicable test acceptance criteria for consistency with associated design bases, licensing bases, and TS requirements. The inspectors also evaluated whether conditions adverse to quality were entered into the corrective action program for resolution. Documents reviewed during the inspection are listed in the Attachment. The following surveillance tests were evaluated:
$
D Salt Service Water Pump In-Service Test (IST) Surveillance;
$
A EDG Monthly Surveillance;
$
4160 Volt Emergency Bus A5 and A6 Load Shed Surveillance;
$
A EDG Initiation by Residual Heat Removal logic;
$
Primary System Boundary Leak Rate Calculation;
$
A Reactor Building Closed Cooling Water Biennial Comprehensive IST Surveillance; and
$
Load Shed Relay Operation/Functional Test.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a. Inspection Scope
(1 simulator training sample)
The inspectors observed licensed operator requalification testing on September 23, 2008.
The inspectors evaluated the operating crew activities relating to accurate and timely classifications and notifications of EAL declarations. Additionally, the inspectors assessed the ability of training evaluators to adequately address operator performance deficiencies identified during the examination. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access Control to Radiologically Significant Areas (71121.01)a.
Inspection Scope (11 samples)
During the period July 7 through 10, 2008, the inspector conducted the following activities to verify that the licensee was properly implementing physical, administrative, and engineering controls for access to locked high radiation areas, and other radiologically controlled areas during power operations. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, relevant Technical Specifications, and the Entergys procedures. This inspection activity represents the completion of 11 samples relative to this inspection area.
Plant Walkdown and Radiation Work Permits (RWP) Reviews
The inspectors observed two work areas and reviewed associated Entergy controls for acceptability. The inspectors reviewed the electronic personal dosimeter alarm set points (both integrated dose and dose rate) for conformity with survey indications and plant policy.
There were no RWPs for airborne radioactivity areas with the potential for individual worker internal exposures of greater than 50 mrem Committed Effective Dose Equivalent (CEDE) and there were no actual internal exposures greater than 50 mrem CEDE. The inspectors examined Entergys physical and programmatic controls for highly activated or contaminated materials (non-fuel) stored within the spent fuel pool.
Problem Identification and Resolution
The inspectors reviewed Entergys condition reports related to the access control program since the last inspection to determine if repetitive deficiencies or significant individual deficiencies are identified. There were no Performance Indicator (PI) events since the previous inspection January 7 through 10, 2008.
Job-In-Progress Reviews
The inspectors reviewed all radiological job requirements, attended pre-job briefings and observed job performance for two work activities. The inspectors verified the adequacy of radiological controls during the work evolutions including, radiation protection job coverage and surveys.
Radiation Worker and Radiation Protection Technician Performance
The inspectors verified that the radiation workers performance was in conformance with the radiation protection work requirements. The inspectors reviewed condition reports since the last inspection that identified the cause as radiation protection technician error.
The inspectors looked for observable patterns traceable to a similar cause and if corrective actions were effective.
b. Findings
No findings of significance were identified.
2OS2 As Low As Reasonably Achieveable (ALARA) Planning and Controls (71121.02)
a.
Inspection Scope (3 samples)
During the period July 7 through 10, 2008, the inspector conducted the following activities to verify that Entergy was properly implementing operational, engineering, and administrative controls to maintain personnel exposure ALARA during routine plant operation. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and Entergys procedures. This inspection activity represents the completion of three samples relative to this inspection area.
Verification of Dose Estimates and Exposure Tracking Systems
The inspectors reviewed the assumptions and basis for the current annual collective exposure estimate and the methodology used. The inspectors reviewed the methods used to make adjustments to the exposure estimate when unexpected changes occurred.
Problem Identification and Resolution
The inspectors reviewed condition reports related to the ALARA program since the last inspection to determine if repetitive deficiencies or significant individual deficiencies are identified. There were no PI events since the previous inspection January 7 through 10, 2008.
b. Findings
No findings of significance were identified.
2OS3 Radiation Monitoring Instrumentation (71121.03)
a.
Inspection Scope (8 samples)
During the period August 11 through 14, 2008, the inspector conducted the following activities to verify the accuracy, operability, and proper use of Entergys radiation monitoring instruments and to evaluate the adequacy of the Entergys program to maintain Self Contained Breathing Apparatus (SCBA). Implementation of the controls was reviewed against the criteria contained in 10 CFR 20, Standards For Protection Against Radiation, relevant Technical Specifications, and Entergys procedures. This inspection activity represents the completion of eight samples relative to this inspection area.
Inspection Planning
The inspectors reviewed the UFSAR to identify area, process, and emergency monitors.
The inspectors did not include monitors covered by the Maintenance Rule.
Instrument Reviews
The inspectors observed calibration of several types of radiation monitoring instruments and reviewed calibration records. During the calibration observations the inspectors reviewed detector measurement geometry, calibration method, and selection of calibration sources. The inspectors observed daily source checks of in use radiation monitoring instruments. The inspectors reviewed the actions taken when an instrument was found out of tolerance.
The inspectors reviewed source calibration certificates and Pilgrims 10 CFR 61, Licensing Requirements For Land Disposal of Radioactive Waste, analysis for several pathways to ensure the calibration sources used were representative of the plant source term.
Problem Identification and Resolution
The inspectors reviewed Pilgrims annual radiation protection program audit. There were no internal exposures greater than 50 milli-rem CEDE. The inspectors reviewed ten condition reports related to the radiation monitoring instruments and the SCBA program to determine if repetitive deficiencies or significant individual deficiencies were identified.
Radiation Protection Technician Performance
The inspectors observed a radiation protection technicians use of a radiation detection instrument. The inspectors verified the appropriate instrument was selected and the appropriate checks were performed prior to use.
Respiratory Protection - SCBA
The inspectors observed the operation of the SCBA bottle fill compressor and the pathways to transport SCBA bottles to and from the control room and the operations support center. The inspectors did not review qualifications of personnel maintaining SCBAs as Pilgrim does not perform any maintenance of the SCBAs. All required maintenance is performed by an outside vendor.
b. Findings
No findings of significance were identified.
Cornerstone: Public Radiation Safety
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)a.
Inspection Scope (2 samples)
During the period July 7 through 10, 2008, the inspector conducted the following activities to verify that radioactive gaseous and liquid effluents are properly mitigated, monitored, and evaluated with respect to public exposure. This inspection activity represents the completion of two samples relative to this inspection area.
The inspectors assessed Pilgrims understanding of the location and construction of underground pipes and tanks that contain radioactively contaminated liquids and Pilgrims onsite groundwater monitoring program. The inspectors reviewed Pilgrims verification and validation records for the dose calculation program. The inspectors reviewed Pilgrims interlaboratory comparison program to verify the quality of radioactive effluent sample analyses performed.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
[OA]
Cornerstone: Mitigating Systems
4OA1 Performance Indicator (PI) Verification
a.
Inspection Scope (3 samples)
The inspectors reviewed PI data to determine the accuracy and completeness of the reported data. The review was accomplished by comparing reported PI data to confirmatory plant records and data available in plant logs, CRs, Licensee Event Report (LERs), and NRC inspection reports. The acceptance criteria used for the review was Nuclear Energy Institute (NEI) 99-02, Revision 5, Regulatory Assessment Performance Indicator Guidelines. Documents reviewed during the inspection are listed in the
. The following performance indicators were reviewed:
- HPCI System from the third quarter of 2007 through the first quarter of 2008;
- Heat Removal RCIC System from the third quarter of 2007 through the first quarter of 2008;
- RHR System from the third quarter of 2007 through the first quarter of 2008;
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Review of Items Entered into the Corrective Action Program (CAP)
a. Inspection Scope
The inspectors performed a screening of each item entered into the licensee's CAP. This review was accomplished by reviewing printouts of each CR, attending daily screening meetings and/or accessing the licensee's database. The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow-up.
b. Findings
No findings of significance were identified.
.2 Annual Sample: Foreign Material Exclusion (FME) Control
a.
Inspection Scope (1 sample)
The inspectors focused on Entergy=s problem identification, evaluation, and resolution concerning potential FME control issues associated with a reactor pressure vessel (RPV)bottom head drain backflush evolution. Specifically, on April 17, 2007 a planned RPV bottom head drain backflush activity resulted in the inadvertent introduction of an underwater plume of debris back up into the RPV. The reactor was partially defueled with the reactor cavity flooded during a refueling outage when the event occurred. Entergy initiated several correction action condition reports (CRs) to address RPV clean-up, to assess FME controls, and to evaluate unrecoverable foreign material (lost parts and/or debris).
The inspector selected Entergys post-event actions for review based on the potential impact on fuel cladding integrity, reactivity controls, and/or critical reactor coolant system (RCS)components. Specifically, unrecovered debris could cause fuel rod fretting, adversely impact control rod scram times or drive performance, or lodge in unwanted places in RCS components.
The inspector reviewed Entergy=s associated clean-up activities, FME-related apparent cause evaluations and self-assessments, extent of condition review, and short and long-term corrective actions. The inspector also interviewed plant personnel; viewed underwater in-vessel video footage of the event (including before and after pictures of the RPV bottom head cleanliness); and reviewed procedures, related industry operating experience (OE), and system health reports. In addition, the inspector reviewed Pilgrims Technical Specifications and UFSAR to assess potential adverse impact on RCS components and the thoroughness of Entergys evaluations. Documents reviewed are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified.
Entergy completed a thorough clean-up of the RPV bottom head debris, including expanding the scope of the initial clean-up effort to recover a high percentage of the debris. Engineering adequately evaluated the potential impact of several identified small items deemed unrecoverable. Entergy effectively used their corrective action process to identify and evaluate in-vessel foreign material (including items not attributed to the backflush activity) and adequately tracked associated corrective actions to completion.
The inspector noted that engineering did not thoroughly document their engineering judgment and basis for concluding that the potential debris dispersal pathway was limited to the RPV bottom head area. Given the number of FME issues identified in the two most recent Pilgrim refueling outages (RFO15 & RFO16), the inspector noted that Entergys FME-related self-assessments were not self-critical or probing and FME-related corrective actions did not include an effectiveness review to ensure adequate performance improvement. Based on documents reviewed and interviews conducted, the inspector concluded that the issue was of minor safety significance, in that, the backflush-induced debris did not adversely impact scram times, fuel clad integrity, control rod drive performance, or RCS components.
4OA6 Meetings, Including Exit
On July 10, 2008, an Occupational Radiation Safety exit meeting was conducted. The preliminary inspection results were presented to Mr. Robert Smith, General Manager, Plant Operations, and other members of the Pilgrim staff. The inspector confirmed that no proprietary information was provided or examined during the inspection.
On August 14, 2008, an Occupational Radiation Safety exit meeting was conducted. The preliminary inspection results were presented to Mr. Tom McElhinney, General Manager, Plant Operations (Acting), and other members of the Pilgrim staff. The inspector confirmed that no proprietary information was provided or examined during the inspection.
On August 21, 2008, a Problem Identification and Resolution exit meeting was conducted.
The preliminary inspection results were presented to Mr. Robert Smith, General Manager, Plant Operations and other members of the Pilgrim staff. The inspector confirmed that no proprietary information was provided or examined during the inspection.
On September 11, 2008, a Problem Identification and Resolution exit meeting was conducted. The preliminary inspection results were presented to Mr. Brian Sullivan, Engineering Director, and other members of the Pilgrim staff. The inspector confirmed that no proprietary information was provided or examined during the inspection.
On October 14, 2008, the resident inspectors conducted an exit meeting and presented the preliminary inspection results to Mr. Stephen Bethay, (Acting) Site Vice President, and other members of the Pilgrim staff. The inspectors confirmed that no proprietary information was provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
K. Bronson
Site Vice President
R. Smith
General Manager Pilgrim Operations
S. Bethay
Director, Nuclear Safety Assurance
J. Burns
Instrumentation & Controls Technician
D. Eldredge
Radiation Protection Technician
M. Farrell
Instrumentation & Controls Technician
J. Fitzsimmons
Radiation Protection Supervisor
M. Gatslick
Licensing Engineer
K. Gracia
Shift Manager (NUC)
P. Harizi
Design Engineer
G. Jennings
Radiation Protection Technician
C. Julius
Supervisor, Control Room
T. Kelly
Radiation Protection Technician
P. Kristian
Maintenance Supervisor
W. Lobo
Licensing Engineer
J. Lynch
Licensing Manager
J. Macdonald
Assistant Operations Manager
W. Mauro
Supervisor, Radiological Engineering (ALARA)
S. McAllister
System Engineering Manager
M. McDonnell
Assistant Manager, Operations (Support)
J. McDonough
Operations, PNP Lbr
T. McElhinney
Supt., Chemistry
J. Miketa
Radiation Protection Technician
D. Noyes
Manager Plant Operations
I. Onorato
Radiation Protection Technician
J. Priest
Radiation Protection Manager
J. West
Radiation Protection Technician
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened and Closed
None