IR 05000293/2010003

IR 05000293-10-003, on 04/01/10 - 06/30/10; Pilgrim Nuclear Power Station; Flood Protection Measures

ML102100150
Person / Time
Site:	Pilgrim
Issue date:	07/29/2010
From:	Diane Jackson NRC/RGN-I/DRP/PB5
To:	Bronson K Entergy Nuclear Operations
Jackson, D E RI/DRP/PB5/610-337-5306
References
IR-10-003
Download: ML102100150 (50)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 July 29 t 2010 Mr. Kevin Bronson Site Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2010003 I

Dear Mr. Bronson:

On June 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents the results, which were discussed on July 1.3, 2010, with you and 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 Gonditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The report documents one NRC identified finding of very low safety significance (Green).

Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance and because it is entered into your corrective action program (CAP), the NRC is treating this as a non-cited violation (NCV), consistent with Section VLA 1 of the NRC's Enforcement Policy. If you contest any NCV, 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 Senior Resident Inspector at PNPS.

In addition, if you disagree with the cross-cutting aspect assigned to the 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 Senior Resident Inspector at PNPS. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice, II a copy of this letter, its enclosure, 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.govlreading-rm/adams.html(the Public Electronic Reading Room).

JI

iJr Donald E. Jack 0 Projects Branc Division of Reactor Projects Docket No. 50-293 License No. DPR-35

Enclosure:

Inspection Report 05000293/2010003 w/Attachment: Supplemental Information co w.encl:Distribution via ListServ In a

REGION I==

Docket No: 50-293 License No: DPR-35 Report No: 05000293/2010003 Licensee: Entergy Nuclear Operations, Inc.

Facility: Pilgrim Nuclear Power Station (PNPS)

Location: 600 Rocky Hill Road Plymouth, MA 02360 Inspection Period: April 1, 2010 through June 30, 2010 Inspectors: M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP)

B. Smith, Resident Inspector, DRP S. Rich, Reactor Inspector. DRP J. Schoppy. Senior Reactor Inspector, Division of Reactor Safety (DRS)

R. Rolph, Health PhYSicist, DRS J. Richmond, Senior Reactor Inspector, DRS D. Molteni, Operator Licensing Inspector, DRS S. Pindale, Senior Reactor Inspector, DRS M. Balazik, Reactor Inspector, DRS C. Williams. Reactor Inspector. DRS Approved By: Donald E. Jackson. Chief Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000293/2010003; 04/01/2010-06/30/2010; Pilgrim Nuclear Power Station; Flood Protection

Measures.

The report covered a three-month period of inspection by the resident inspector staff and region based inspectors. One Green finding was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC}

0609, "Significance Determination Process." The cross-cutting aspect for the finding was determined using IMC 0310, "Components Within The Cross-Cutting Areas." Findings for which the significance determination process does riot apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

The inspectors identified a Green finding (FIN) for improper maintenance of underground non-safety related medium voltage electric cables. The inspectors identified that Entergy allowed non-safety related medium voltage cables to remain submerged in water for extended periods of time. Entergyentered this issue into their Corrective Action Program (CAP), and specified corrective actions to identify all underground medium voltage cables included under the Cable Reliability Program, and to identify which manholes should have dewatering capability.

The inspectors determined that the finding was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, continued submergence of the non-safety related power cables (from the start-up transformer to electrical buses A2 and A4) could lead to cable failure and cause an event that would affect plant stability. The inspectors performed a Phase 1 Significance Determination Process screening of the finding in accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance because the condition did not contribute to both the likelihood of a reactor trip and the unavailability of mitigating systems equipment. The inspectors determined that this finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Entergy personnel did not thoroughly evaluate the problem when submerged cabling was initially identified

P.1(c}. (Section 1R06)

Other Findings

A violation of very low safety Significance that was identified by Entergy has been reviewed by the inspectors. Corrective actions taken or planned by Entergy have been entered into Entergy's corrective action program. This violation and corrective action tracking number is listed in Section 40A7 of this report.

REPORT DETAILS

Summary of Plant Status

Pilgrim Nuclear Power Station (PNPS) began the inspection period operating at 100 percent power. On May 1,2010, operators reduced power to 56 percent in response to the "8" Feedwater Regulating Valve (FRV) drifting closed. The valve was manually locked and Pilgrim returned to 100 percent power later the same day. On May 20,2010, operators reduced power to 50 percent power for a backwash of the main condenser and to support troubleshooting of the "8" FRV. Pi/grim returned to 100 percent power on May 21,2010. following successful repairs to the "8" FRV. On May 24, 2010, operators reduced power to 49 percent power for a second backwash of the main condenser. Pilgrim returned to 100 percent power later the same day. On May 27, 2010. operators reduced power to 80 percent for a control rod pattern adjustment and returned to 100 percent power !ater the same day. Operators maintained the reactor at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Seasonal Readiness

a.

Inspection Scope (1 sample)

The inspectors performed a review of severe weather preparations during the week of May 13, 2010, to evaluate the site's readiness for the onset of hurricane season, including the readiness of three risk-significant systems, which included the intake structure, the Emergency Diesel Generators (EDGs) and the Station Blackout (SBO)

Diesel Generator. 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 performed partial walkdowns of the intake structure, the EDG enclosures, and the SBO enclosure to determine the adequacy of equipment protection from the effects of hurricanes. The documents reviewed during the inspection are listed in the

.

b. Findings

No findings were identified.

.2 Grid Stability* Alternating Current (AC) Power System Readiness

a.

Inspection Scope (1 sample)

The inspectors performed a review of Entergy's offsite and onsite AC power system readiness for susceptibilities during adverse weather. The inspectors reviewed Entergy's plant features and procedures for operation and continued availability of offsite and onsite AC power systems to determine if they were appropriate. The inspection focused on procedures affecting these areas and communication protocols between the transmisSion system operator (TSO) and Entergy to verify that appropriate information would be exchanged when issues arise that could impact the offsite power system. The inspectors also reviewed Entergy's procedures to ensure that they addressed actions to be taken when notified by the TSO to transfer safety-related loads to the onsite power supply, compensatory actions to be performed if it were not possible to predict grid conditions, and reassessment of plant risk based on maintenance activities which could affect grid reliability. The documents reviewed during the inspection are listed in the

.

b. Findings

No findings were identi'fied.

1R04 Equipment Alignment

.1 Partial System Walkdowns (71111.040)

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 performed a partial walkdown of each system to determine if the critical portions of the selected systems were correctly aligned in accordance with procedures, and to identify any discrepancies that may have had an effect on operability. The walkdowns included selected control switch reviews, 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:

• Electric Fire Pump following testing on the Diesel Fire Pump;

• Reactor Core Isolation Cooling System with the High Pressure Coolant Injection System out of service for maintenance; and

• Station Blackout Diesel Generator with the fiN Emergency Diesel Generator out of service for maintenance.

b. Findings

No findings were identified.

.2 Complete System Walkdowns

a.

Inspection Scope (1 sample)

The inspeCtors completed a detailed review of the "B" Reactor Building Closed Cooling Water (RBCCW) system to assess the functional capability of the system. The inspectors performed a walkdown of the system to determine whether the critical components, such as valves and circuit breakers, were aligned in accordance with operating procedures, and to assess the material condition of valves, piping, and seismic supports. The inspectors discussed system health with the system engineer, reviewed the system's Maintenance Rule status, and performed a review of outstanding maintenance work orders to determine whether the deficiencies significantly affected the "8" RBCCW system function. The inspectors also reviewed condition reports from the past year to determine whether "B" RBCCW equipment problems were being identified and appropriately resolved. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Fire Protection - Tours (71111.050)

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 specified 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 and fire barriers. The inspectors then compared the existing condition of the areas to the fire protection program requirements to determine whether all program requirements were met The documents reviewed during this inspection are listed in the Attachment. The fire protection areas reviewed were:

• Fire Area 1.10, Fire Zone 1.30A, Torus Compartment;

• Fire Area 1.9, Fire Zone 1.9, Control Rod Drive Hydraulic Control Units East Side;

• Fire Area 1.10, Fire Zone 1.26, Auxiliary Boiler Room;

• Fire Area 1.10, Fire Zone 1.28, Reactor Recirculation Pump Motor Generator Sets Room; and

• Fire Area 1.10, Fire Zone 1.3, High Pressure Coolant Injection Pump and Turbine Room.

.2 Annual Fire Drill Observation

a.

Inspection Scope (1 sample)

The inspectors observed an announced fire drill in the Operations and Maintenance Building Weld Shop Area. The fire drill was performed in accordance with procedure EN-TQ-125, Revision 0, "Fire Brigade Drills." The inspectors observed performance of the fire brigade personnel to determine whether Entergy's fire fighting pre-plan strategies were utilized, the pre-planned drill scenario was followed, and the drill objectives were met. The inspectors observed the drill to verify that protective clothing and breathing apparatus were donned: sufficient fire fighting equipment was brought to the scene; the fire brigade leader's fire fighting directions were clear: and communications with the plant operators and between fire brigade members were effective. The inspectors observed the drill critique to determine whether areas to improve fire brigade performance were identified. Additional documents reviewed during this inspection are listed in the

.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Underground Cable Inspection a.

Inspection Scope (1 sample)

The inspectors reviewed a sample of flood protection measures affecting cables located in underground manholes. The inspectors selected an inspection of cable pits 2A, 4, and 5 that contain underground non-safety related power cables (from the start-up transformer to electrical buses A2 and A4) near the main transformer and the south side of the switchyard near the start-up transformer. The inspectors monitored Entergy's maintenance inspection and dewatering activities associated with each manhole to evaluate the as-found condition and corrective actions. The inspectors assessed the condition of power cables, splices, and supports. The inspectors also reviewed Entergy's Cable Reliability Program and corrective actions taken for this issue and the Cable Reliability Program in general. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

Introduction:

The inspectors identified a finding (FIN) of very low safety Significance (Green) for improper maintenance of underground non-safety related medium voltage electric cables. The inspectors observed partially and fully submerged medium voltage cables during the regularly scheduled monthly dewatering and inspection of three cable vaults.

Description:

The electric power distribution system provides electric power to safety and non-safety related distribution buses in the plant. Off-site power is provided to the system by two independent circuits through non-safety related, medium voltage (typically those rated from 2 kilovolts to 35 kilovolts), Kente cables that are routed through .

underground vaults and ducts. These cables are not rated for continuous submergence in water.

On April 28, 2010, the inspectors observed water in each of the manholes and vaults listed above. The inspectors noted that no dewatering or drainage systems existed in the manholes. Entergy procedure EN-DC-346, Revision 0, "Cable Reliability Program," was issued and effective on December 31, 2009. This procedure discusses manhole inspections and dewatering, and requires, in part, "If manual inspections and pumping are used to maintain a cable system dry, the intervals must be sufficient to keep the cables dry. Adjust intervals as necessary, based on inspection results." Discussions with Entergy personnel involved with these inspections indicated that cables in Manhole 2A were periodically found submerged or partially submerged, and that cables in Manholes 4 and 5 were always found submerged. The cables that were submerged included cables that were installed from the 4160V, non-safety related startup

. transformer and connected to the A2 and A4 non-safety related busses. The inspectors identified that Entergy had previously identified submerged cables in August and September of 2009, however, corrective actions were not sufficient to preclude these cables from being submerged. The inspectors also determined that Entergy had not implemented the Cable Reliability Program guidance in a timely manner to ensure that the degrading effects of this environmental condition were minimized (Le., pumping intervals were not sufficient to maintain the cables dry).

Entergy generated Condition Report (CR) CR-PNp*2010*1529, and specified actions to identify a\l underground medium voltage cables included in the Cable Reliability Program, and to identify which manholes should have dewatering capability. Entergy also created a corrective action to increase the frequency of the dewatering activities for these areas.

In addition, the Electric Power Research Institute has generated a cable testing database that will be used to compare the test results of cables that have been removed from service to evaluate the potential for degradation of in-service cables.

Analysis:

The inspectors determined that allowing medium voltage cables to remain submerged for extended periods of time was a performance deficiency. The cause of the issue was within Entergy's ability to foresee and correct, and should have been prevented. Traditional Enforcement did not apply, as the issue did not have actual or potential safety consequence, had no willful aspects, nor did it impact the NRC's ability to perform its regulatory function.

A review of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, "Minor Examples,"

revealed that no minor examples were applicable to this finding. The finding was more than minor because it was associated with the design control attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically. continued submergence of the non safety related power cables (from the start-up transformer to electrical buses A2 and A4)could lead to cable failure and cause an event that would affect plant stability. The inspectors performed a Phase 1 Significance Determination Process screening of the finding in accordance with NRC Inspection Manual Chapter 0609, Attachmenl 4, "Phase 1 -Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance because the condition did not contribute to both the likelihood of a reactor trip and the unavailability of mitigating systems equipment.

The inspectors determined that this finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Entergy personnel did not thoroughly evaluate the problem when submerged cabling was initially identified IP.1(c)].

Enforcement:

This finding does not involve enforcement action because no regulatory requirement violation was identified. Because this finding does not involve a violation and has very low safety significance, it is identified as FIN 0500029312010003-01 t Submerged Medium Voltage Cables.

R07 Heat Sink Performance

a.

Inspection Scope (2 samples)

Based on a plant specific risk assessment, previous inspections, recent operational experience, and resident inspector input, the inspector selected the following heat sink samples:

• Operation and performance testing of the salt service water(SSW) system; and

• Performance of the ultimate heat sink (UHS), which included SSW piping integrity and SSW intake structure functionality.

The SSW system was designed to function as the UHS for all the systems cooled by the RBCCW and turbine building closed cooling water (TBCCW) systems during all operating modes by continuously providing adequate cooling water flow to the RBCCW and TBCCW heat exchangers. The inspectors reviewed the SSW system design to evaluate the adequacy of system monitoring and performance testing. The inspectors reviewed a sample of SSW pump and valve performance tests, system health and walkdown reports, and in*service test vibration monitoring results for adverse trends and to verify that the system functioned as designed. The inspectors verified that Entergy performed the pump and valve in-service tests in accordance with American Society of Mechanical Engineers (ASME) Code requirements. In addition, the inspectors reviewed Entergy's monitoring, maintenance, and testing of interface valves between safety related SSW and non-safety related or non-seismic piping systems to ensure that adequate SSW flow is available post-accident consistent with design basis assumptions.

The inspectors reviewed Entergy's buried pipe inspection and monitoring program to independently assess the condition and structural integrity of the SSW piping. The inspectors reviewed a sample of SSW pipe nondestructive examination records and videos of underwater inspections of the SSW intake bays to ensure that Entergy appropriately identified and dispositioned any SSW system degradation. The inspectors performed an above ground walkdown of accessible areas containing buried SSW piping to look for soil subsidence or other indications of piping leakage and/or degradation. The inspectors also directly observed the condition of SSW piping in the accessible portions of the SSW bays and valve pits.

The inspectors reviewed Entergy's procedures for SSW and intake structure operation, abnormal SSW operations, adverse weather conditions, and for a loss of the SSW system. The inspectors verified that Entergy maintained these procedures consistent with their design and licensing basis and that plant operators could reasonably implement the procedures as written. The inspectors independently verified that SSW and intake level instrumentation, which operators rely upon for decision making, was available and functional. The inspectors also reviewed recent SSW and intake area modifications to verify that the design bases, licensing bases, and performance capability of the SSW system had not been degraded by the design changes.

The inspectors walked down control room instrument panels, the RBCCW and TBCCW heat exchangers, accessible portions of SSW piping in the auxiliary building, and SSW intake area (including the SSW pumps, spray wash pumps, and traveling water screens)to assess the material condition and configuration control of these structures, systems and components (S5Cs). The inspectors also reviewed a sample of corrective action condition reports (CRs) related to the SSW isolation valves, SSW pumps, and SSW piping integrity to ensure that Entergy appropriately identified, characterized, and corrected problems related to these essential 5SCs. Documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings were identified.

1R11 Licensed Operator Regualification Program

Resident Inspector Quarterly Review (71111.11Q)a.

Inspection Scope (1 sample)

The inspectors observed licensed operator "as-found" simulator training on April 19, 2010. The inspectors observed crew response to an AntiCipated Transient Without Scram. The inspectors assessed the licensed operators' performance to determine if the training evaluators adequately addressed observed deficiencies. The inspectors reviewed the applicable training objectives from the scenario to determine if they had been achieved. In addition. the inspectors performed a simulator fidelity review 10 determine if the arrangement of the simulator instrumentation, controls. and tagging closely paralleled that of the control room. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

.

No findings were identified.

1R12 Maintenance Effectiveness

a.

Inspection Scope (3 samples)

The inspectors reviewed the three 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 paragraph

(b) of the Maintenance Rule; (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 paragraph (a)(1) or (a)(2); and (8)appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as paragraph (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as paragraph (aX1). The documents reviewed during this inspection are listed in the Attachment. Items reviewed included the following:

• Loop "B" Salt Service Water Flow Indicator, Indicating Flow with Flow Control Valve Closed;

• Air Introduction into Standby Liquid Control System; and

• Functional Failure Determinations of the Feedwater Regulating Valves (FRV).

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control {71111.13}

a.

Inspection Scope (5 samples)

The inspectors evaluated five 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 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. The documents reviewed during this inspection are listed in the

. The inspectors reviewed the conduct and adequacy of maintenance risk assessments for the following maintenance and testing activities:

• Yellow Risk for "8" Diesel Logic Test and Fire Protection Features Out-of-Service;

• Yellow Risk Due to Unavailability of One Offsite Power Line, Diesel Fire Pump, Increased Loss of Offsite Power and Increased Trip Risk;

• Yellow Risk with High Pressure Coolant Injection Out of Service for Maintenance;

• Yellow Risk During Unavailability of "8" Residual Heat Removal Motor Operated Valve; and

• Yellow Risk with Station Blackout Maintenance and Shutdown Transformer Out of Service.

b. Findings

No findings were identified.

1R15 Operability Evaluations

a.

Inspection Scope (5 samples)

The inspectors reviewed five operability determinations associated with degraded or non-conforming conditions to determine if the operability determination was justified and if the mitigating systems or barriers 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 Entergy's performance against related Technical Specifications and Updated Final Safety Analysis Report requirements. The documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following degraded or non-conforming conditions:

• CR-PNP-2010-1303, High Pressure Coolant Injection Steam Une Drain Root Valve Steam Leak;

• CR-PNP-2009-4944, Drywell Leakage Upward Trend over Three Pump-Downs;

• CR-PNP-2010-1289, Potential Air in Standby Liquid Control System;

• CR-PNP-2010-1481 , GNF2 Fuel Assembly Manufacturing Defects; and

• CR-PNP-2010-1609, Calculation for Operators' Dose during Main Steam Line 6reak outside containment cannot be retrieved.

b. Findings

No findings were identified.

1R 18 Plant Modifications (71111.18)

.1 Permanent Modification to "6" Salt Service Water (SSW} Pump Flange Connection

a.

Inspection Scope (1 sample)

The inspectors reviewed Permanent Modification EC21320, "Evaluate and Provide Altemate DeSign for P-208B Discharge Head to Top Column Flange Connection," to determine whether the performance capability of the "6" SSW pump had been degraded through the modification. The inspectors reviewed engineering drawings, relevant condition reports, and work packages to ensure the modification did not adversely affect the SSW system. The inspectors reviewed the drawings to determine whether they properly reflected the modification. The inspectors also walked down the SSW pump compartment room in the intake structure. The documents reviewed during this inspection are listed in the Attachment.

Ij' I

I

b. Findings

No findings were identified .

.2 Permanent Modification for Installing Turbine-Style Air Start Motors and Regulators on

Emergency Diesel Generator (EDG) X-107B

b. Inspection Scope

(1 sample)

The inspectors reviewed Permanent Modification EC 12969, Revision 0, "Install Turbine~

Style Air Start Motors and Regulators on EDG X-107B," and the aSSOCiated 10 CFR 50.59 screening, to determine whether the licensing bases and performance capability of the "B" EDG system had been degraded through the modification. A walkdown was performed to determine whether the components inside the room were as described in the permanent modification documentation. The inspectors reviewed applicable drawings to determine whether they properly reflected the permanent modification. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

1R19 PostwMaintenance Testing

a.

Inspection Scope (6 samples)

The inspectors reviewed s!xsamples of post-maintenance tests during this inspection period. The inspectors reviewed these activities to determine whether the post maintenance test 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 Technical SpeCification requirements. The inspectors also evaluated whether conditions adverse to quality were entered into the CAP for resolution. The documents reviewed during this inspection are listed in the Attachment. The following maintenance activities and their post-maintenance tests were evaluated:

• Overhaul Power Supply Circuit Breaker for Reactor Recirculation Pump Suction to Reactor Water Clean Up Pump Valve (MO-1201 ~5);

• Disconnect and Reconnect "S" Salt Service Water Pump Motor during P-208B Overhaul;

• "S" Salt Service Water Pump Check Valve 29-CK-3880B Rebuild; .

• High Pressure Coolant Injection Valve AO-2301-64, Replacement for Limit Switch;

• "A" Emergency Diesel Generator 2 year, 4 year, and 8 year Preventive Maintenance; and

• Replace Fuel Injector Snubber Valves on "At! Emergency Diesel Generator.

b. Findings

No findings were identified.

1

R22 Surveillance Testing

a.

Inspection Scope (6 samples)

The inspectors witnessed six surveillance activities and/or reviewed test data to determine whether the testing adequately demonstrated eqUipment operational readiness and the ability to perform the intended safety-related functions. The inspectors reviewed selected prerequiSites and precautions to determine jf 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 Technical Specification requirements.

The inspectors also evaluated whether conditions adverse to quality were entered into the Corrective Action Program for resolution. The documents reviewed during this inspection are listed in the Attachment. The following surveillance tests were evaluated:

• Reactor Core Isolation Cooling Operability and In-Service Test (1ST);

• Standby Liquid Control Operability and 1ST;

• Main Steam Line Containment Isolation Valve (CIV) Logic Test;

• High Pressure Coolant Injection System Operability and 1ST;

• "8" Residual Heat Removal Operability Test (Routine); and

• "An Core Spray Pump Operability and 1ST.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Cornerstone: Emergency Preparedness

a.

Inspection Scope (1 sample)

The inspectors observed licensed operator "as-found" simulator training on April 19, 2010. The inspectors evaluated the operating crew activities related to an accurate and timely classification and notification of a Site Area Emergency, Emergency Action Level Declaration 2.3.1.3. Additionally, the inspectors assessed the ability of training evaluators to adequately address operator performance deficiencies identified during the exercise. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

RADIATION SAFETY

(RS)

2RS0 1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

During the period May 17, 2010, through May 20,2010, the inspectors performed the following activities to verify that Entergy properly assessed the radiological hazards in the workplace and implemented appropriate radiation monitoring and exposure controls during routine operations. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, "Standards for Protection Against Radiation," relevant Technical Specifications, and Entergy's procedures.

This inspection effort represented partial completion of one sample. Further inspection is planned to fully complete this sample, and the results will be documented in a future report.

Inspection Planning

• The inspectors reviewed all of Pilgrim's Performance Indicators for the Occupational Exposure Cornerstone for follow up;

• The inspectors reviewed radiation protection program self assessments and audits; and

• The inspectors verified no operational events occurred relating to radiation safety.

Radiological Hazard Assessment

• The inspectors verified no changes to plant operations were implemented or planned that would result in a change to plant radiological conditions;

• The inspectors reviewed the last two

(2) surveys performed on each level of the Reactor Building to include the Refuel Floor and the Traversing In-core Probe Room;

• The inspectors walked down the faCility, including the Trash Compactor Facility, the radioactive waste processing area, storage, and handling areas to evaluate material and radiological conditions and the reactor building. With the assistance of a radiation protection technician, dose rates were verified at the boundary of several high radiation areas and at the doors to locked high radiation areas; and

• The inspectors observed work in progress in the condenser bay at 100% power. The inspectors reviewed pre-work surveys and documentation which identified appropriate hazards.

Instructions to Workers

• The inspectors verified the labeling of several drums containing licensed material staged in cubicles and entrances to cubicles in the radwaste hallway;

• The inspectors reviewed four radiation work permits (RWP) used to access High Radiation Areas and verified specified work control instructions; and

• The inspectors reviewed five

(5) condition reports where a worker's electronic personal dosimeter (EPD) alarmed.

Contamination and Radioactive Material Control

• The inspectors reviewed Pilgrim's criteria for the survey and release of material and the response required for an alarm indicating the presence of licensed material;

• The inspectors verified the presence of three

(3) sources on Pilgrim's inventory and verified that the sources were leak tested and were not leaking; and

• The inspectors verified that Pilgrim has three

(3) sources meeting the requirements to be reported on the nationally tracked sources system. The sources have not been moved and are still in use.

Radiological Hazards Control and Work Coverage

• The inspectors observed work in progress in the condenser bay at 100% power. The workers removed and re-instal.led a feedwater regulating valve controller. The inspectors attended the pre-job briefing and verified the eXisting conditions were conSistent with posted surveys, RWP, and worker briefing;

• The inspectors verified the adequacy of radiological controls such as radiation and contamination surveys, video surveillance, communication, and stay time tracking during personnel entry and egress from the condenser bay;

• The inspectors verified the placement of radiation monitOring devices on the individuals; and

• There was no opportunity to review an RWP for airborne radioactivity area entry. No airborne area entries were specified therefore, no RWPs were written.

Radiation Worker Performance

• The inspectors observed radiation worker performance and observed that they were aware of the radiological conditions and the RWP controls and that their performance reflected the level of radiological hazards present; and

• The inspectors reviewed six

(6) condition reports where hUman performance errors were the cause.

Radiation Protection Technician Proficiency

• The inspectors observed radiation protection technician performance to determine if technicians were aware of the radiological conditions in their workplace and the RWP controls; and

• The inspectors reviewed five

(5) condition reports where the cause was radiation protection technician error.

Problem Identification and Resolution

• The inspectors reviewed Pilgrim's self-assessments, audits, and Special Reports related to the radiation protection program to determine if identified problems were entered into the CAP. The inspectors verified that problems identified were entered into the CAP and appropriate corrective actions were identified.

b. Findings

No findings were identified.

OTHER ACTIVITIES

lOA]

I.

40A1 Performance Indicator (PI) Verification (71151)

Cornerstone: Initiating Events

===I a.

Inspection ScoRe (3 samples)===

II The Initiating Events cornerstone PI data for unplanned scrams per 7,000 critical hours (IE01); unplanned scrams with loss of normal heat removal (IE04); and unplanned power I t

changes per 7,000 critical hours (IE03) was reviewed to assess the completeness and 1 accuracy ofthe report information. Specifically, PI data from the second quarter of 2009 I-through the first quarter of 2010 was reviewed and compared to information contained in I NRC inspection reports, Licensee Event Reports (LERs), and operator logs. The I-documents reviewed during the inspection are listed in the Attachment.

I

b. Findings

l No findings were identified.

40A2 Identification and Resolution of Problems (71152)

.1 Review of Items Entered into the Corrective Action Program (CAP)

a. Inspection Scope

The inspectors performed a screening of each item entered into Entergy's Corrective Action Program. This review was accomplished by reviewing printouts of each Condition Report (CR). attending daily screening meetings and/or accessing Entergy'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 were identified .

.2 Semi-Annual Review to Identity Trends

a.

Inspection Scope (1 sample)

The inspectors performed a review of Entergy's CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The review was focused on repetitive equipment and corrective maintenance issues, but also considered the results of daily inspector. CAP item screening. The review included issues documented in CAP trend reports and the site CAP performance indicator data.

The review focused on the six month period of January 2010, through June 2010, although the inspectors also evaluated previous trend results for Condition Reports from July 2009, through December 2009, which were discussed in Pilgrim Integrated Inspection Report 2009005. The documents reviewed during the inspection are listed in the Attachment.

b. Findings

and ObselVations No findings were identified. One low level trend discussed in Pilgrim Integrated Inspection Report 2009005 was reviewed and is discussed below. In addition.

a new low level trend was identified in the area of the Maintenance Rule Program (MRP).

Post Maintenance and Modification Testing The inspectors reviewed CR-PNP-2009-2778, which was written to perform an assessment of post maintenance test activities documented at Pi/grim during and since Pilgrim's most recent refueling outage (RF017). The inspectors performed additional post-maintenance test samples during the first two quarters of 2010 and identified fewer deficiencies in post maintenance testing. Due to the identification of fewer deficiencies and because corrective actions to improve post maintenance testing at Pilgrim appear to have been effective, the inspectors consider this low level trend closed.

Maintenance Rule Program The inspectors have reviewed eleven MRP samples since the second quarter of 2009 in order to verify that Entergy appropriately addresses Maintenance Rule component performance and condition problems. In addition, the inspectors reviewed Entergy's implementation of the Maintenance Rule seoping requirements, functional failure evaluations and their baSis. and the conduct of oversight of the MRP by the onsite Maintenance Rule Committee. Examples of problems identified by the inspectors during this time period included:

• A non-cited violation of 10 CFR 50.65 was identified for the failure to include the security diesel generator into the Pilgrim Maintenance Rule scoping document (Pilgrim inspection report 05000293/2009004). The inspectors identified that the security diesel generator was credited in the fire hazards analysis for the backup battery power supply for safe shutdown emergency lighting but was not included in the Maintenance Rule scoping document. Entergy evaluated this condition and subsequently incorporated the security diesel generator into Maintenance Rule scoping documents. CR-PNP-2009-2852 was written to evaluate the seoping of the  !

I security diesel and to include the diesel in Maintenance Rule scoping documents.

Ii

• A Maintenance Rule functional failure evaluation for the "An Feedwater Regulating Valve (FRV) was not performed. CR-PNP-201 0-1299 was written to evaluate the FRV failure and concluded a functional failure had occurred. This functional failure exceeded the Feedwater Level Control System functional failure criteria and thereby required an evaluation for 10 CFR 50.65 (a)(1) classification.

I

• A Maintenance Rule functional failure evaluation of Process Radiation Monitoring (PRM) instruments for the Steam Jet Air Ejectors (SJAE) was not performed. The inspectors identified that a failure of SJAE PRMs was not evaluated under the Maintenance Rule procedure to determine if a functional failure had occurred. CR PNP-2009-4070 was written to evaluate the PRM failures and concluded a functional failure had occurred.

• The basis for a Standby Liquid Control (SLC) Maintenance Rule functional failure determination was incorrect. The inspectors identified that the basis for a SLC Maintenance Rule functional faiture concluded that both trains of SLC were needed to perform the SLC function and, therefore, the loss of one of the pumps was a functional failure. The inspectors reviewed Pilgrim design basis documents and determined that only one pump was required to meet the SLC function and that the loss of one pump would not constitute a Maintenance Rule functional failure. CR PNP-2009-4006 was written to document the incorrect basis and to re-perform the functional failure evaluation.

• A Maintenance Rule Functional Failure (MRFF) evaluation of secondary containment incorrectly concluded that secondary containment was not seeped within the Maintenance Rule. The inspectors then determined that the subsequent MRFF evaluation used incorrect piping sizes in evaluatin9 an allowable gap size for secondary containment. CR-PNP-2010-1181 was written to document the issue and the basis in the original CR was corrected.

In addition to the above examples, the inspectors attended Maintenance Rule Committee meetings and noted examples of inadequate preparation by presenters, a lack of .

understanding of the role of the Maintenance Rule Coordinator, and problem solving by the Maintenance Rule Committee members versus providing oversight of the products brought to the meeting. The inspectors discussed this trend with Entergy in the fall of 2009 and CR-PNP-2009-4197 was written to document examples. conduct an apparent cause evaluation, and to specify corrective actions. Corrective actions have included clarifying the roles and responsibilities of the Maintenance Rule Coordinator, conduct of training on the Maintenance Rule and the need for rigor and review of design basis documents in the conduct of functional failure evaluations, and formalizing Maintenance Rule Committee protocols and meeting conduct guidelines. The inspectors have noted improvement in the conduct of Maintenance Rule Committee meetings; however.

additional examples of MRP issues continued to occur over the last two quarters. The inspectors have therefore concluded that the number and extent of MRP issues during the past year constitutes a low level trend with the implementation of this program. The inspectors will follow Entergy's corrective actions to evaluate their response to this low level trend .

.3 Annual Sample: Maintenance Rule Program Issues

a. Inspection Scope

(1 sample)

The inspectors focused on Entergy's identification, evaluation, and resolution of MRP deficiencies and issues as documented in CR-PNP*2009-4197.

The inspectors reviewed Entergy's apparent cause analysis, extent of condition review, and their short-term and long-term corrective actions. The inspectors conducted interviews, reviewed corporate procedures and condition reports related to the implementation of the MRP at Pilgrim. The documents reviewed during the inspection are listed in the Attachment.

b. Findings and Observations

No findings were identified. See Section 40A2.2 for a discussion on the identification of a low level trend in the implementation of the MRP at Pilgrim.

The apparent cause identified that Engineering Management had provided a greater focus on the equipment reliability process and had not provided the same level of oversight to the MRP. In addition, the Condition Report (CR) discussed a lack of rigor by engineers in implementing the process. Corrective actions discussed in the apparent cause to correct the problem included; review of expectations with System Engineers for daily CR screening, assigning qualified engineers to review functional failures and (a)(1)action plans, briefing of the Condition Report Review Group on Maintenance Rule risk significant components, and a review of the Maintenance Rule basis documents to ensure accuracy and adequate scoping. In addition, the System Engineering Maintenance Rule Coordinator, SE Supervisor and SE Manager reviewed all corporate MRP documents to ensure they understood all requirements, roles, and responsibilities.

Also, additional formal training was provided to System Engineers on MRP responsibilities, proper documentation, and expectations for completing functional failure determinations and 10 CFR 50.65 (a)(1) action plans.

The inspectorp determined that MRP deficiencies continue to occur at Pilgrim. The inspectors also concluded that the number of issues identified during MRP inspections constitutes a low level trend which is documented in Section 40A2.2. The inspectors will conduct follow-up inspections of Entergy MRP performance as part of the periodic assessment of low level trends.

.4 Annual Sample: Feedwater Regulating Valve Lockup Concerns

a.

Inspection Scope (1 sample)

This inspection focused on Entergy's problem identification, evaluation, and resolution conceming feedwater regulating valve (FRV) lockup issues that provided a challenge to automatic reactor water level control. The inspectors selected Entergy's FRV corrective actions for review based on the potential impact on reactor vessel level control as undesired FRV lockups could complicate event response, result in a plant transient, andlor unnecessarily challenge control room operators. The inspectors reviewed Entergy's associated troubleshooting documentation, root cause evaluations, extent-of condition review, and short and long-term corrective actions. The inspectors performed a walkdown of the FRV electronic control modules and a remote camera inspection of the normally inaccessible FRVs to assess the FRV controller error code status, actuator pressures, material condition, and configuration control. The inspectors also interviewed plant personnel; inspected several replaced FRV actuator components and Entergy's FRV mock-up facility; and reviewed procedures, vendor manuals, related industry operating experience, and drawings. Documents reviewed are listed in the attachment.

b. Findings and Observations

No findings were identified. I&C technicians determined that the "8" FRV control system had not locked up electrically in the conventional way, but had locked up by a computer output failure as evidenced by the FRV actuator response and the recorded error codes.

Engineering concluded that the root cause of the abnormal and spurious operation that resulted in the "silent" lockups of the "8" FRV was high input process noise caused by the failure to adequately set up the FW level transmitters for maximum dampening following their replacement in RF017. In addition, engineering concluded that the failure to install new software in the "8" FRV control system was a contributing cause. The new software provided sensitivity changes to improve overall system response and operation. I&C adjusted the level transmitters for maximum dampening on May 27, 2009 and installed the new software in the 8 FRV controller on June 16, 2009. Entergy's corrective actions also included: increased system monitoring in accordance with their Operational Decision Making Issue (ODMI) process, implementation of permanent changes to the controlling documents associated with the replacement and calibration of FW level transmitters. and conducting an extent-of-condition review.

Regarding the above "8" FRV lockup issue, the inspectors concluded that Entergy had taken appropriate action in accordance with station procedures, NRC Maintenance Rule (MR)requirements, and their corrective action program (CAP). The inspectors determined that engineering's associated root cause evaluation was sufficiently thorough and based on the best available information, troubleshooting, sound engineering judgment. and relevant industry operating experience. In general, Entergy's assigned corrective actions were aligned with the identified causal factors, adequately tracked, appropriately documented, and completed as scheduled. The inspectors noted that Entergy created and effectively used a FRV actuator mock-up to facilitate their root cause evaluation, troubleshooting, and training i" efforts. In addition, Entergy management effectively implemented their ODMI process to provide additional monitoring and oversight of FRV performance in response to the identified

~silent" lockups.

During the extent-of-condition review for the "8" FRV "silent" lockup issue, the inspectors noted that Entergy had also identified degraded conditions associated with the "An FRV's actuator assembly. On April 17, 2009 (prior to RF017), the FW system engineer identified an adverse trend in the actuator pressures and initiated CR-PNP-2009-1372 to assess and trend the condition. The condition had no noticeable impact on FRV performance and engineering continued to monitor the FRV performance. A focused engineering walkdown immediately following the plant shutdown for RF017 identified that the "A" FRV was closed, as expected, but locked up {a "silent" lockup caused by a friction failure error code}. An Engineering inspection of the "A" FRV stepper motor found excessive friction in the stepper motor worm gear due to hardened grease, and some indications of scoring inside the spool and sleeve assembly (CR-PNP-2009-1983). Engineering determined that the apparent cause was the vendor supplied lubricant found in the spool/sleeve assembly and a mismatched spool/sleeve assembly that may have contributed to the friction. (The vendor applied lubricant to the stepper motor shaft and gear; however, the spool/sleeve assembly is a matched set with tight tolerances that should not be lubricated.) Entergy replaced the "An FRV actuator internals (with a matched spoollsleeve set) and performed an extent-of condition inspection on the "6" FRV.

The inspectors noted that the causal factors for the two FRV performance issues noted above were different. even though they both resulted in "silent" FRV lockups. The inspectors noted that Entergy took prompt and appropriate corrective actions to address the short-term concerns associated with the A FRV high friction failure (and accompanying "silent" lockup);however, did not effectively track long-term actions within their CAP and did not adequately evaluate potential MR aspects of the issue. Specifically,

(1) the equipment failure evaluation for CR-PNP-2009-1983 noted that "the condition resulted in the loss of a critical function of the SSC" and "the failed SSC resulted in an unexpected operational effect," however, engineering did not perform a MR functional failure evaluation of the condition;

(2) the discovery of the "eilenr lockup (an unexpected failure) did not trigger a higher Significance CR review;

(3) long-term corrective actions to ensure appropriate changes were made to preventive maintenance procedures to verify actuator assembly lubrication and spool/sleeve condition were labeled as enhancements and remained open; and

(4) there were no apparent corrective actions to address the excessive wear identified within the spool assembly. Engineering initiated CR-PNP-20 10-1299 to address these issues.

Based upon direct observation of the FRV module error codes and operational history review, the inspectors noted that Pilgrim had not experienced any "silent" lockups Since implementing corrective actions in June 2009. The inspectors noted that engineering initiated actions to work with the FRV controller vendor to eliminate any potential "silent" lockups (all error codes that disable the FRV but do not trip the fault relay to provide control room alarm). Entergy proceeded cautiously and appropriately to ensure that they did not introduce any additional electronic lockups below the threshold of those previously analyzed and expected. Although engineering believed that they had addressed the causal factors associated with the unexpected FRV "silent" lockups in May and June 2009, the inspectors noted that operations had not incorporated periodic FRV control module monitoring to check the error code status to verify no "silent" lockups present (until such time that they were no longer vulnerable to "silent" lockups). Engineering captured this inspector observation within CR 2010*1299 .

.5 Annual Sample: Motor Control Center Relay Failure

a. Inspection Scope

(1 sample)

The inspectors performed an in-depth review of Entergy's root cause analysis and corrective actions associated with condition report (CR) CR~2008-3338. High Pressure Coolant Injection (HPCI) System Injection Valve Motor Control Center (MeC) D954 Under-Voltage Relay Failure. Specifically, a normally energized under-voltage relay failed, which resulted in de-energizing the motor actuator for the normally closed HPCI injection valve, MO~2301-08.

The inspectors assessed Entergy's problem identification threshold, cause analyses.

extent of condition reviews, compensatory actions, and the prioritization and timeliness of Entergy's corrective actions to determine whether Entergy was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Entergy's corrective action program and 10 CFR 50, Appendix B. In addition, the inspectors performed field walkdowns and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions.

Specific documents reviewed are listed in the Attachment to this report.

b. Findings and Observations

No findings were identified. Entergy determined the most probable cause was an isolated relay failure early in its service life due to a manufacturing defect. Entergyalso determined that the relay had operated at a higher voltage than assumed in the environmental qualification (EO) report, because the 250 VDC battery bus typically operated at about 266 VDC while the battery was on float charge. Entergy determined that operating the relay at a slightly higher voltage would result in a higher component intemal temperature, which may have led to a shortened life expectancy and may have been a contributing cause to the premature relay failure.

Entergy conducted a thorough technical review of the relay failure, including a comprehensive failure analysis performed by an independent third party laboratory.

Entergy's extent of condition review identified additional normally energized DC relays which were also operating on a battery float voltage greater than assumed in their EO reports. Corrective actions included replacing the failed relay and revising the EO service life and preventative maintenance (PM) replacement tasks for the affected relays.

The inspectors reviewed selected relay maintenance records and did not identify any additional issues. The inspectors determined Entergy's overall response to the issue was commensurate with the safety significance, timely, and included appropriate compensatory actions. The inspectors determined that the actions taken were reasonable to resolve both the initial relay failure and the impact from elevated operating temperatures to relay service life.

However, the inspector's review of selected design records identified insufficient design control measures had been used during the revision of the relays EO service life.

Specifically, the inspectors identified that a field measurement of relay temperature had been used as a key design input parameter to re-calculate the EO service life. However, Entergy did not use calibrated measurement and test equipment (M&TE) for the field measurement, and did not evaluate the measurement or test uncertainty in the field measurement. In addition, Entergy used a vendor to re-calculate the relay EO service life.

However, the vendors new EQ service life values were documented in a memorandum from the vendor to Entergy, without any supporting details or analysis, and the memorandum was not controlled under a quality assurance (OA) program.

This performance deficiency was determined to be a minor because it was related to equipment qualification and no equipment operability or functionality was Significantly affected. In accordance with NRC Inspection Manual Chapter 0612, "Power Reactor Inspection Reports," the above 'issue constituted a violation of minor significance that is not subject to enforcement action in accordance with the NRC's Enforcement Policy.

Entergy entered the inspector's observations into their CAP (CR-PNP-201 0-2073).

40A3 Event Follow-up (71153)

.1 Operator Performance During Thermal Backwash

a.

Inspection Scope (1 sample)

The inspectors observed an infrequently performed evolution on May 20,2010.

Specifically, the inspectors observed a plant downpower to support thermal backwash of r

the condenser and "B" feedwater regulating valve post maintenance testing. The I inspectors reviewed procedural guidance for station power changes and the power maneuver plan, and observed control room conduct and control of the evolution. The documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified .

.2 (Closed) Licensee Event Report (LER 05000293/2010-001-00) Single Train of Reactor

Building Closed Cooling Water (RBCCW) System Inoperable for Time Period Exceeding Technical Specification Limits The inspectors reviewed Entergy's actions and reportability criteria associated with LER 05000293/2010-001-00, which are addressed in CR-PNP-2010-0130. On January 10, 2010, plant operators discovered a broken bolt on the clamp of the seismic support for the instrument line of the local pump suction pressure gauge on the "A" train of R8CCW. Upon discovery, Entergy entered and then exited their Technical Specifications (TS) once the bolt was replaced. However, subsequent engineering reviews could not determine the exact time the bolt broke. 8ased on the condition of the bolt it was assumed that the bolt was broken for a time period that exceeded the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowable TS Limiting Condition for Operation (LCO) action statement for one RBCCW subsystem being inoperable. Entergy took corrective actions which included installation of the new bolt on the instrument line and performing an extent of condition review on the "8" train of R8CCW from which they identified no other broken bolts or seismic support damage. The documents reviewed during the inspection are listed in the Attachment. The enforcement aspects of this finding are discussed in Section 40A7. This LER is closed .

.3 (Closed) Licensee Event Report (LER 05000293/2010-002-00), Standby Gas Treatment

Declared Inoperable After Discovery of Open Demister Door The inspectors reviewed Entergy's actions associated with LER 05000293/2010-002-00, which are addressed in the CAP as CR-PNP-201 0-1 079. The event and enforcement aspects of a licensee-identified violation were discussed in NRC Inspection Report (IR)05000293(2010002 in Section 40A7 of that report. The documents reviewed during the inspection are listed in the Attachment. This LER is closed.

40A5 Other Activities 1. (CLOSED) EA-10-003, NOV 050000293/2009005-01, Incomplete Licensed Operator Medical Examinations

a. Inspection Scope

In accordance with Inspection Procedure 92702, "Followup on Corrective Actions for Violations and Deviations," the inspectors conducted a follow-up inspection of enforcement action EA-10-003, which was identified due to the submittal of inaccurate medical information for licensed operators. The submittals to the NRC were inaccurate due to incomplete olfactory testing "to detect odor of products of combustion" from required licensed operator and initial applicant medical examinations. This issue was documented as a cited violation in inspection report 05000293/2009005. The inspectors reviewed the condition reports and analyses developed by Entergy to ensure the adequacy of

(1) the evaluation of the issue;

(2) the eValuation and impact of generic implications; and

(3) that corrective actions have been fully implemented.

The inspectors reviewed the scope and depth of the analysis in addressing the identified deficiency. The inspectors also reviewed the licensee's assessment of generic implications of the identified violation on other Entergy facilities and other aspects of licensed operator medical examinations. The inspectors evaluated the corrective actions implemented by Entergy to determine whether they were adequate to address the identified deficiency and prevent recurrence. Additionally, the inspectors evaluated the licensee's determination of why appropriate action was not taken in response to Information Notice (IN) 2004-20, "Recent Issues Associated with NRC Medical Requirements for Licensed Operators," to identify that appropriate olfactory testing was not being conducted. The inspectors reviewed the licensee's identified causes and the actions taken by the licensee to prevent recurrence of those causes.

b. Findings

No findings were identified.

The inspectors determined that the scope and depth of the analysis to address the identified deficiency was adequate and appropriate. The inspectors also determined that the generic implications identified by the corrective action process were adequate and appropriate. The inspectors concluded that Entergy's corrective actions were both timely and appropriate to address the identified deficiency and generic implications.

The inspectors determined that weaknesses in the Operating Experience Program that were identified as contributing causes in the failure to take appropriate action when IN 2004-20 was issued, were adequately corrected by changes made to the program.

The changes were determined to correct the identified cause and prevent recurrence.

The inspectors determined that no cross*cutting aspect would be assigned to the NOV, because the failure to use operating experience effectively was not indicative of current performance.

2. (CLOSED) URI 050000293/2009005-01. Procedure Change to Allow Disabling HPCI

DUring Transients.

a. Inspection Scope

During the previous reporting period, the NRC issued an Unresolved Item (URI) to document an issue involving 10 CFR 50.59, "Changes, Test and Experiments," due to the improper implementation of a procedure change which may have resulted in a "more than minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component (SSC) important to safety...." The issue was opened as an Unresolved Item (URI) in NRC Inspection Report 050000293/2009005. The inspectors concluded that the 10 CFR 50.59 preliminary evaluation checklist developed to support the current and previous revisions to procedure 2.2.21.5, "HPCllnjection and Pressure Contro'" was incorrect and did not support the procedure actions.

The inspectors reviewed the licensee actions to develop a 10 CFR 50.59 evaluation that addressed the conditions described in procedure 2.2.21.5. The inspectors also evaluated the completed 10 CFR 50.59 evaluation to ensure that the changes made to procedure 2.2.21.5 did not require prior NRC approval.

b. Findings

No findings were identified.

The inspectors determined that the actions taken to address the issue were appropriate and adequate. Additionally, the inspectors reviewed the 10 CFR 50.59 evaluation developed by the licensee and determined that procedure 2.2.21.5 did not require a license amendment or NRC approval prior to use. Per the guidance provided in the NRC Enforcement Manual, this issue meets the definition of a minor violation per Section 2.10.6. The inspectors concluded that URI 050000293/2009005-01 can be closed and the corrective actions taken to address this issue were adequate to correct the identified cause.

3. TI2515/179 Verification of Licensee Responses to NRC Requirement for Inventories of

Mat~rials Tracked in the National Source Tracking System Pursuant to Title 10, Code of I*

Eederal Regulations. Part 20.2207 (10 CFR 20.2207)a. InsQection Scope I During the period May 17, 2010 through May 20,2010, the inspectors performed the I

following activities to confirm the inventories of materials possessed by Pilgrim were II appropriately reported and documented in the National Source Tracking System (NSTS)in accordance with 10 CFR 20.2207

Inspection Planning

• The inspectors retrieved a copy of Pilgrim's NSTS inventory from Pilgrim's NSTS I

account via Regional staff with NSTS access.

/

I I

Inventory Verification

• The inspectors performed a physical inventory of the sources listed on the Pilgrim's inventory and visually identified each source listed on the inventory;

• The inspectors verified the presence of the nationally tracked sources by having a radiation protection supervisor perform a survey with a radiation survey instrument;

• The inspectors examined the physical condition of the source containers, evaluated the effectiveness of the procedures for secure storage and handling. discussed Pilgrim's maintenance of the devices including source leak tests, and verified the posting and labeling of the sources was appropriate; and

• The inspectors reviewed Pilgrim's records for these sources and compared the records with the data from the NSTS inventory. The inspectors evaluated the effectiveness of Pilgrim's procedures for updating the inventory records.

Determine the Location of Unaccounted-for Nationally tracked source(s}

• The inspectors verified Pilgrim has no unaccounted-for source(s).

Review of Other Administrative Information

• The inspectors reviewed the administrative information contained in the NSTS inventory printout with Pilgrim personnel. All administrative information, mailing address, docket number, and license number, was verified to be correct.

b. Findings

No findings were identified .

.4 (Closed) NRC Temporary Instruction 2515/177 - Managing Gas Accumulation in

Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems

a. Inspection Scope

The inspectors performed the inspection in accordance with Temporary Instruction (TI} 2515/177, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems". The NRC staff developed TI25151177 to support the NRC's confirmatory review of licensees' response to NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems." The Office of Nuclear Reactor Regulation (NRR) documented completion of their review of Entergy's GL 2008-01 response in a closure letter dated April 6, 2010 (ADAMS Accession No. ML100950092). Based on the review of Entergy's GL 2008-01 response letters, the NRR staff provided guidance on TI inspection scope to the regional inspectors. The inspectors used this inspection guidance along with the TI to verify that Entergy implemented or was in the process of acceptably implementing the commitments, modifications, and programmatically controlled actions described in their GL 2008-01 response. The inspectors verified that the plant-specific information (including licensing bases documents and design information) was consistent with the information used by NRR in their assessment and that it supported a conclusion that the subject systems' operability was reasonably assured.

The inspectors reviewed a sample of isometric drawings and piping and instrument diagrams (P&IDs). and conducted selected system piping walkdowns to verify that Entergy's drawings reflected the subject system configurations and Updated Final Safety Analysis Report (UFSAR) descriptions. Specifically, the inspectors verified the following related to a sample of isometric drawings for the high pressure injection (HPCI), core spray, and residual heat removal (RHR) systems:

• High point vents were identified;

• High points that did not have vents were recognized and evaluated with respect to their potential for gas buildup;

• Other areas where gas could accumulate and potentially impact subject system operability, such as at orifices in horizontal pipes, isolated branch lines, heat exchangers, improperly sloped piping, and under closed valves, were acceptably evaluated in engineering reviews or had ultrasonic testing (UT) points which would reasonably detect void formation; and,

• For piping segments reviewed, branch lines and fittings were clearly shown.

The inspectors conducted walkdowns of portions of the above systems to reasonably assure the acceptability of Entergy's drawings utilized during their review of the GL 2008 01. The inspectors verified that Entergy conducted walkdowns of the applicable systems to confirm that system orientations, vents and alarms, in combination with instructions, procedures, tests, and training, would ensure that each system was sufficiently full of water to assure operability. The inspectors reviewed Entergy's methodology used to determine system piping high points, identification of negative sloped piping, and calculations of void sizes based on UT equipment readings, to ensure the methods were reasonable. The inspectors reviewed engineering analyses associated with the development of acceptance criteria for as-found voids. The review included engineering assumptions for void transport and acceptability of void fractions at the suction and discharge piping of the applicable system pumps. In addition, the inspectors reviewed the pressure transient analysis downstream of the low pressure core injection (LPCI)isolation valve (MO 1001-29NB) associated with steam voiding conditions within the piping to ensure LPCI operability following reactor depressurization. The inspectors also observed a field UT measurement in the HPCI suction piping from the torus to assess the adequacy of the monitoring techniques used to ensure system operability.

The inspectors reviewed a sample of Entergy's procedures used for filling and venting the associated GL 2008-1 systems to verify that the procedures were effective in venting or reducing voiding to acceptable levels. The inspectors verified that Entergy had plans in place to install two hardware vents, one vent located in the HPCI pump suction torus piping and the other located at a highpoint within the core spray discharge piping, as committed to in their GL response. The inspectors verified that Entergy's surveillance frequencies were consistent with Pilgrim's technical specifications and associated bases, and the UFSAR. The inspectors reviewed a sample of system venting surveillance results to ensure proper implementation of the surveillance program and that the existence of unacceptable gas accumulation was evaluated within the CAP, as necessary. The inspectors reviewed CAP documents to verify that selected actions described in Entergy's submittals were acceptably documented including completed actions, implementation schedule for incomplete actions, and verification that NRC commitments were included the CAP. Additionally, the inspectors reviewed evaluations and corrective actions for various issues Entergy identified during their GL 2008-01 review. The inspectors performed this review to ensure Entergy appropriately evaluated and adequately addressed any gas voiding concerns including the evaluation of operability for gas voids discovered in the field. Finally, the inspectors reviewed Entergy's training program and documentation to assess if appropriate training had been provided to the operations and engineering support staff to ensure appropriate awareness of the effects of gas voiding. Documents reviewed are listed in the

.

b.

Finding!?

No findings were identified.

40A6 Meetings, Including Exit On March 30, 2010, Donald Jackson, NRC Regional Branch Chief for Pilgrim, presented and discussed the End-of-Cycle performance assessment of the Pilgrim Nuclear Power Station with Mr. Stephen Bethay. The licensee acknowledged the assessment and planned regulatory oversight. This discussion was completed prior to a public performance assessment open-house meeting on March 30, 2010. (ADAMS Accession ML100621417).

On April 22, 2010, the inspectors presented the inspection results from a heat sink inspection and feedwater valve lockup issues to Mr. Robert Smith, General Manager Pilgrim Operations, and other members of the Entergy staff. The inspectors confirmed that no proprietary information was provided to the inspectors for the inspection.

On May 20, 2010, an occupational radiation inspection exit meeting was held with the plant.

Kevin Bronson, Site Vice President, attended the meeting. At the exit meeting, the inspectors confirmed that no proprietary information was provided to the inspectors for the inspection.

On June 11, 2010, the inspectors presented the inspection results from the failure ofthe High Pressure Coolant Injection system Condition Report review to Mr. Vincent Fallacara, Director of Engineering, and other members of Entergy's staff. The inspectors confirmed that no proprietary information was provided to the inspectors for the inspection.

On June 24,2010, the inspectors presented the inspection results from a gas accumulation inspection to Mr. Robert Smith, General Manager of Plant Operations, and other members of the Entergy staff. The team reviewed proprietary information, which was returned to Entergy at the end of the inspection. The inspectors verified that no proprietary information is documented in this report.

On July 13, 2010, the resident inspectors conducted an exit meeting and presented the preliminary inspection results to Mr. Kevin Bronson, and other members of the Pilgrim staff.

At the exit meeting, the inspectors confirmed that no proprietary information was provided to the inspectors for the inspection.

40A7 licensee-Identified Violations The following violation of very low safety significance (Green) was identified by Entergy and is a violation of NRC requirements, which meets the criteria of the NRC Enforcement Policy, for being dispositioned as an NeV.

• Technical Specification (TS) 3.5.B.3, Reactor Building Closed Cooling Water (RBCCW) System, requires that two RBCCW subsystems shall be operable whenever irradiated fuel is in the reactor vessel, reactor coolant temperature is >212° F, and prior to startup from a cold shutdown. With one RBCCW subsystem inoperable, the required action is to restore the subsystem to operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Cold Shutdown within an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Contrary to the above, the "N' train of RBCCW was inoperable for an indeterminate amount of time that likely exceeded the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of TS allowed outage time. Upon discovery of the broken bolt on the seismic support, the "A" train of RBCCW was declared inoperable.

An immediate corrective action was completed to install a new bolt on the seismic support and TS 3.5.8.3 was exited. The event is documented in Entergy's Corrective Action Program as CR-PNP-201 0-0130. The finding was evaluated using IMC 0609, Significance Determination Process, and was determined to be of very low safety significance (Green) because the finding would not have resulted in the total 1055 of a safety function during a seismic event ATIACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy personnel:

S. Bethay Nuclear Safety Assessment Director

K. Bronson Site Vice President

R. Byrne Licensing Engineer

B. Chenard System Engineering Manager

V. Fallacara Engineering Director

J. Gaedtke System Engineer

K. Kampschneider System Engineer

W. Lobo Licensing Engineer

J. Lynch Licensing Manager

B. Mello Program Engineer

F. Mulcahy System Engineer

D. Noyes Operations Manager

J. Priest Radiation Protection Manager

R. Smith General Manager Pilgrim Operations

M. Thornhill Radiation Protection Supervisor

E. Varmette Radiation Protection Technician

S. Wollman Engineering Supervisor

LIST OF ITEMS

Opened and Closed

FIN

05000293/2010003-01 Submerged Medium Voltage Cables

Closed

NOV

050000293/2009005-01 Incomplete Licensed Operator Medical Examinations URI

050000293/2009005*01 Procedure Change to Allow Disabling HPCI During Transients LER

0500029312010-001-00 Single Train of Reactor Building Closed Cooling Water (RBCCW) System. Inoperable for Time Period Exceeding Technical Specification Limits LER

05000293/2010-002-00 Standby Gas Treatment Declared Inoperable After Discovery of Open Demister Door