ML12170B021
| ML12170B021 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/17/2012 |
| From: | Lampert M Pilgrim Watch |
| To: | Borchardt R NRC/EDO |
| References | |
| 2.206, G20120327 | |
| Download: ML12170B021 (12) | |
Text
UNITED STATES OF AMERICA
- k.
D DEDW NUCLEAR REGULATORY COMMISSION DWDMt BEFORE THE EDO, U.S. NUCLEAR REGULATORY COMMISSION June 17, 2012 Qcs.
R. William Borchardt eaLc NW Executive Director for Operations A
O U.S. Nuclear Regulatory Commission Q0 I
Washington, DC 20555-0001 s(J
, Q I Via Email hearingdocket@nrc.gov SUPPLEMENT TO 2.206 ENFORCEMENT PETITION REGARDING LABOR DISPUTE PILGRIM NPS (SUBMITTED MAY 16, 2012) - CONDITION REPORTS Pilgrim Watch ("PW") respectfully requests to supplement its 2.206 enforcement petition submitted originally on May 16, 2012 regarding the labor dispute at Pilgrim Station highlighting its public safety implications.
We submit the following pertinent new information that supports PW's request for NRC to order Pilgrim closed for operations until the labor dispute is resolved and all 369 union workers reinstated back onsite in their original jobs.
The attached Condition Reports ("CRs") have occurred since the labor dispute and lock-out. They indicate to us that operations are not being maintained as they should.
Further, the CRs add to the multiple safety issues previously brought forward by Pilgrim Watch ("PW") and Jones River Watershed Association ("JRWA") in prior supplements and in our initial 2.206.
These concerns further erode the public's confidence that there is reasonable assurance of public safety. For example, two CRs (02549 and 02560) raise security issues over and above the lack of security training brought forward by Petitioners in earlier supplements. One CR (02459)
-1 E-A)D-ON 6LtN&
WDJ- 0
describes workers entering the site without their ID's being verified at the entry point. The other CR (CR 02560) reports from security that grasses onsite at PNPS are getting very long. We logically infer from the CR, although the CR comes to a very different explanation, that the real concern of high grass is that any party ("bad guy") hiding on site in the high grass could not be easily identified. But, the CR focuses instead on the risk of terrorists, or anyone for that matter, getting Lyme disease from ticks and become ill.
Petitioners maintain that absent reasonable assurance, NRC is required to order the reactor to cease operations until such time as the regular worker force is back on site in full.
Respectfully submitted on behalf of Petitioners, (Electronically signed)
Mary lampert Pilgrim Watch, Director 148 Washington Street Duxbury, MA Tel. 781-934-0389 Email: rnary.lampert(ci)comcast.net June 17, 2012 2
ATTACHMENT Below is a list of 41 CR's created from (6/7/2012 6:07:40 AM to 6/11/2012 6:07:40 AM).
PW/JRWA highlighted those that appear most significant to us; however we appreciate that NRC technical staff may very well identify others.
Codition. Number.§
~
odto Descriptio0n' CR-PNP-201--- 2-*
2 02528 "Administrative issue - Due to circumstances related to the ongoing labor situation, there I
] was no attendance at the 50% review meeting for EC34744 - GSU test switches on 6/7/12.
Discovered: 6/7/2012 9:24:49 AM Originated: 6/7/2012 9:30:44 AM Originator: Sitkowski Jr,Dennis J Eng DE Elect Staff PNP Systems:
Equipment:
CR-PNP-2012- 02529 Discoverd:
6/7/2012 9:48:03 AM Originated: 6/7/2012 9:49:51 AM Originator: Hettwer,Michael H Operations Mgmt PNP Systems:
24 Equipment: VAC-104B CR-PNP-2012- 02530 Discoverd:
6/7/2012 9:49:24 AM Originated: 6/7/2012 10:06:12 AM Originator: Kelly,Gary R Maint Electrical Mgmt PNF Systems:
24 Equipment: VHU-103 CR-PNP-2012- 02531 Discoverd:
6/7/2012 11:48:40 AM Originated: 6/7/2012 11:59:59 AM Originator: Anonymous General Manager PNP Systems:
Equipment:
VAC-I 04B belts are broken and need to be replaced - NEED belts, none on-site, delivery scheduled for 06/11/2012 WO-5231 1608-01 to perform 3.m.3-68 cai't be completed. The dead date is 6/25/12. The 3.m.3-68 requires the breaker to be cycled 4 times and voltage readings to be taken. The inspection portion of the 3.m.3-68 is complete. Currently the breaker is tagged out IAW tagout IC19-1-24H-015-VHU-103. A work order WO 226149-01 is to repair the VHU-103. Currently the Work order is in plan status.
SAFETY CONCERN: Multiple vehicles on site are without required Lighting underneath them 3
CR-PNP-2012- 02532 While posted at the I&S parking lot, Security Officer Noticed Madi security personnel assembling a pop up tent on company property. Security Officer noticed that Contractors Discoverd:
6/7/2012 1:56:20 PM were not using proper PPE and attempted to correct them but was ignored. Nuclear Originated: 6/7/2012 2:01:08 PM Security Offlicers should NOT be ignored. Salfety is EVERYONES responsibility.
Originator: Brain SrJonathan E Security Plant Staff PNP Systems:
Equipment:
CR-PNP-2012- 02533 Based upon the focused Self Assessment of MFLS Training program, three negative observations and one Area for Improvement (AFI) have been identified. This CR is Discoverd:
6/7/2012 1:57:05 PM written to address these findings.
Originated: 6/7/2012 2:08:46 PM Originator: Corbo,William F Training Mgmt PNP Systems:
Equipment:
CR-PNP-2012- (12534 Door knob on DR-] 61 Fan room two. does not turn on the inside, door will not open from the inside if latch worked, door does not latch. CR-PNP-2012-1109 identified this Discoverd:
6/7/2012 2:23:46 PM condition. (TORNADO BARRIER DOOR DR-161 FOR FAN ROOM 2,(5 1 TB), IS Originated: 6/7/2012 2:29:47 PM FAILING TO LATCH AND REQUIRES MANUAL ACTION TO FULLY CLOSE.)
Door knob needs repair. WO 308134 was written to repair door Originator: Mone.Patrick Eng Sys BOP Staff PNP Systems:
56 Equipment: DR-161 CR-PNP-2012- 02535 During RHR Pump-B testing. FI-1040-2B., RHR TOTAL FLOW, was observed to indicate approximately 100-200 gpm lower that flow indication on FI-1040-12B, RHR Discoverd:
6/7/2012 3:15:23 PM Containment Cooling. These indicators should show the sante flow while in the test Originated: 6/7/2012 3:35:17 PM lineup See attached Pt trace.
Originator: Flynn,Grant Operations Staff PNP Systems:
10 Equipment: Ff-1040-12B CIR-PN P-2012- 02536 Discoverd:
Originated:
Originator:
6/7/2012 4:57:11 PM 6/7/2012 5:10:56 PM Flynn,Grant Operations Staff PNP Received EPIC alarm RCW008, RWCU non-regen heat exchanger outlet temp high while establishing flow through the RHIR heat exchanger. Throttled flow to the RHR Heat Exchanger to provide more flow to the RWCU NRHX, which cleared the alarm. Hlighest temperature observed was 123 deg-F. Normal temperature is approximately 110 deg-F.
RWCU high-temperature trip is 140 deg-F.
Systems:
Equipment:
4
CR-PNP-2012- 02537 After viewing video footage and exiting out of the work window on The SAS SOCA Work Station, the Work Station locked up and required a reboot.
Discoverd:
6/7/2012 8:35:05 PM Originated: 6/7/2012 8:43:22 PM Originator: MacNeilICraig Security Plant Mgmt PNP Systems:
Equipment:
CR-PNP-2012- 02538 D-15 250 VDC backup charger failed PMT WO# 315015-02 Discoverd: 6/8/2012 4:54:39 AM Originated: 6/8/2012 4:59:17 AM Originator: Dagnello,Michael A Maint FIN Team Staff PNP Systems:
46G Equipment: DI5 CR-PNP-2012- 02539 While conducting the daily surveillance of the EOF Mechanical Room it was noted that the hot water tank located in the EOF Mechanical Room had breached, which caused Discoverd:
6/8/2012 6:15:46 AM localized flooding in the room. Note: The hot water tank is NOT a piece of equipment that Originated: 6/8/2012 6:38:58 AM is important to EP, as delineated in EP-IP-100.1, Art. 9.3, and is only used for hot water supply to the EOF for the bathrooms and the kitchen area.
Originator: Anonymous General Manager PNP Comment Petitioners:
Systems:
CR-PNP-2012-02539 was written because the hot water tank in the EOF Mechanical Room had breached. PW/JRWA does not believe that the evaluation that concluded that the hot water tank is not important is sufficient. When investigating a drive-by shooting, it really doesn't matter if the vehicle was traveling below the posted speed limit. The concern is that the bullets coming from the vehicle might harm people. In this case, that the hot water tank is not important has to be complemented by an evaluation of potential harm from the.
water it leaked into the room. Could that water damage equipment that IS important? Entergy failed to ask and answer all the right questions. It's not sufficient to have the right answers until one has asked all the right questions.
CR-PNP-2012- 0254()
Operations did not attend the T-28 meeting on June 7, 2012 to meet requirements of EN-WM-101.
J)iscoverd: 6/8/2012 6:33:50 AM Originated: 6/8/2012 6:46:49 AM Originator: EllisonH-eather Elizabeth Eng P&C Plant Prog/Comp Systems:
Equipment:
5
CR-PNP-2012- 02541 K-1 17 diesel air compressor has exceeded its maintenance rule perlormance criteria of not more than 2 functional failures in the past 2 year period. Actual performance is 3 Discoverd:
6/8/2012 6:43:56 AM functional failures in the past 2 years. The most recent failure identified by CR-2012-2366 Originated: 6/8/20 12 6:47:07 AM is also a repeat functional failure. EN-DC-205 requires the initiation of a new CR when Originator: O'Donnelljonathan performance criteria are exceeded or a repeat functional failure is identified.
Eng Sys NSSS Staff PNP Systems:
31 Equipment: K-117, TT-1277, TT-21 CR-PN-P-2012- 02542 During performance of weekly battery surveillance under W/O 52421314-01 the 250V security battery bank voltage did not come inside the acceptance criteria range of 260-Discoverd:
6/8/2012 7:25:39 AM 270VDC. As-found voltage was 270.1 VDC Originated: 6/8/2012 7:29:02 AM Originator: Dwyer,Joseph P Maint Electrical Mgmt PNF Systems:
Equipment:
CR-PNP-2012- 02543 Received "CRD/ DRYWELL/MISC AREAS TEMP HI" C903R (A l). Alarm due to high temp alarm on CRD 26-27. Temp reading is currently 250F.
Discoverd:
6/8/2012 10:10:20 AM Originated: 6/8/2012 10:14:45 AM Originator: Connerton,Kelly L Operations Staff PNP Systems:
Equipment:
C(R-PNP-2012- 02544 Condensate pump area cooler VAC-101A red fan ON indicating light has a bulb broken off in the socket at Panel C60.
Diseoverd:
6/8/2012 1:46:23 PM Originated: 6/8/2012 1:47:51 PM Originator: Haskell,Kenneth D Operations Statf PNP Systems:
Equipment:
CR-PNP-2012- 02545 While performing the calibration ofRR-1705-1 I per 8.M. 1-13 ATT 5. step [LIj (e)4 the
?as-found? set point for the Blue pen was found at 4.00 E3. The desired trip setting is 3.00 Discoverd:
6/8/2012 228:18 PM E3. The alarm was adjusted to 3.00 E3. functionally tested and placed back into service.
Originated: 6/8/2012 2:30:35 PM Originator: CookDennis J Maint I&C Mgmt PNP Systems:
Equipment:
6
CR-PNP-2012- 02546 WWTF emergency diesel auto start. B41-2 transfer switch in tripped condition. Notified control room.
Diseoverd:
6/8/2012 2:29:36 PM Originated: 6/8/2012 2:34:34 PM Originator: Mantenf l,Martin B Eng P&C Code Program Sti Systems:
Equipment: B4102 CR-PNP-2012- 02547 While performing 2.1.25, Eyewash station checkoff list, one portable eyewash station was not fully charged. The Portable eyewash station in the EDG 'A' Compressor room had a Discoverd:
6/8/2012 2:23:00 PM charge indication of Yellow. Green is fully charged and Red indicates a need for recharge.
Yellow indicates a lowering pressure.
Originated: 6/8/2012 2:37:30 PM Originator: Johnson,Adam Operations Staff PNP Systems:
Equipment:
CR-PNP-2012- 02548 The control room received a spurious C19A/B Trouble Alarm, in and clear. CI9A is currently out of service. Chemistry investigated and found no abnormalities with Cl9B.
Distoverd:
6/8/2012 4:46:13 PM Originated: 6/8/2012 5:09:49 PM Originator: FlynnGrant Operations Staff PNP Systems:
66 Equipment: C-191 (R-PNP-2012- 02549 On Thursday 6/7/12 security officers were instructed not to board the bus loaded with contingency workers and let them pass without verifying their IDs. When security officer Discoverd:
6/7/2012 9:00:00 AM questioned management, officer was told lDs were verified at the pick up location by the Originated: 6/8/2012 5:15:50 PM senior security training supervisor. Security officer then questioned if the training supervisor was qualified to do the patrolnman's job. This issue is currently being addressed Originator: Brain SrJonathan E by the NRC.
Security Plant Staff PNP Systems:
Comment Petitioners: CR-PNP-2012-02549 was written because workers are Equipment:
entering the site without their ID's being verified at the entry point. Allegedly, their IDs are being verified at the pickup point. This is potentially dangerous.
This practice could allow bad guys to intercept the bus between the pickup point and the entry point, board the bus, and whip through the entry point without challenge.
CR-PNP-2012- 02550 H2 analyzer B N-009B low flow alarm intermittent. Alarm in and clear approximately I minute cycles.
Discoverd:
6/8/2012 6:58:50 PM Originated: 6/8/2012 7:04:25 PM 7
Originator: Smith,Wade M.
Tech Chemistry Mgmt PNP Systems:
Equipment:
CR-PNP-2012- 02551 WADI Security personnel did not not receive EN-MA-126 brief as required by procedure Discoverd:
6/8/2012 8:06:33 PM Originated: 6/8/2012 8:)6:40 PM Originator: HendersonIoseph C Human Performance PNP Systems:
Equipment:
CR-PNP-2012- 02552 During the perfolnance of 8.C.22, Startup Transformer and 345kV Switchyard Surveillance, found voltage differential between battery ground detectors on D658 Discoverd:
6/9/2012 10:25:54 AM
>30VDC. POS-to-GND reading was 68VDC. NEG-to-GND reading was 67VDC.
Originated: 6/9/2012 10:43:25 AM Originator: Burmham Jr,Danicl Thomas Operations Staff PNP Systems:
Equipment:
CR-PNP-2012- 02553 Doble Engineering has notified Entergy blanket PO 50014627 has expired. This means PNPS transformer oil analysis must be arrested until funding is renewed. Oil analysis is Discoverd:
6/9/2012 10:11:51 AM the primary performance monitoring tool for the large transfonncrs.
Originated: 6/9/2012 11:22:44 AM Originator: KeeneJeffrey W Eng Sys Elect/l&C Staff Pt' Systems:
Equipment:
CR-PNP-2012- 02554 Found "gap vax" vehicle parked in front of executive building without wheel chocks in place.
Discoverd:
6/9/2012 4:57:42 I'M Originated: 6/9/2012 5:02:23 PM Originator: Vazquez,Gcorge W QA Audit Staff PNP Systems:
Equipment:
(CR-PNlI-2012- (02555 The following descrepancies were noted during tie Weekly Control Rod Exercise lAW 8.3.2: Control Rod 38-3 1, Degraded Rod Motion 300# to Withdraw WR# 275252 Control Rod 50-23 Degraded Rod Motion 340 # to Insert. WR#275254 Control Rod 14-15, No rod 8
Discoverd: 6/9/2012 4:27:59 PM select light on Full Core Display WR#275255 Control Rod 10-07 No rod seledet light on Originated: 6/9/2012 5:23:21 PM Full Core Display. WR# 275256 Originator: Knell,Kenneth C Outage Staff PNP Systems:
Equipment:
CR-PNP-2012- 02556 Individual needed to cover the minimum manning requirements for Operations shift coverage during the strike contingency period. The individual was hired Discoverd: 6/9/2012 9:00:00 AM from 0700 to 1030 on 5/9/2012 after he worked the previous nightshift 1900 -
Originated: 6/9/2012 5:54:37 PM 0700. As a result, this individual exceeded 26 work hours in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.
Originator: Clifford,Francis C The oncoming Radwaste / Fire Brigade Operator was found to be not coming in Outage Mgnit PNP for his scheduled shift due to a planned vacation. Previous attempts on the nightshift to provide watch coverage this individual were unsuccessfil. In Systems:
addition, there is a limited amount of eligible candidates for coverage.
Equipment:
CR-PNP-2012- 02557 During an NRC inspector walk down of the intake structure toolbox that supports 2.1.37 COASTAL STORM - PREPARATIONS AND ACTIONS attachment I Discoverd: 6/10/2012 4:23:48 AM SCREENVIOUSE PARTS AND TOOLS INVENTORY LIST; 12 one eighth inch cotter Originated: 6/10/2012 4:25:31I AM pins were missing from the toolbox inventory.
Originator: Paul,Stanley W Comment Petitioners CR-PNP-2012-02557 was written because an NRC Operations Staff PN P inspector discovered 12 1/8 inch cotter pins missing from the toolbox staged in Systems:
support of coastal storm procedures. However we wonder if the replacement Equipment:
workers are likely to even find the toolbox, yet alone notice that it's missing some pieces.
CR-PNP-2012- 02558 The control room received a spurius C19A/13 Trouble Alarm twice, in and clear. CI9A is currently out ofIservice. Chemistry investigated and fotund no abnomialities with C I9B.
Discoverd:
6/10/2012 3:56:55 AM Originated: 6/10/2012 4:39:54 AM Originator: Webers,John W Operations Staff PNP Syste ms:
Equipment:
CR-PNP-2012- 02559 Received alarm C3R-C7, Line 342 Alternate Pilot twice. The first time, the alarm was spurious, the second alarm stayed in for several hours.
Diseoverd:
6/10/2012 4:46:01 AM Originated: 6/10/2012 4:56:20 AM Originator: Webers,John W Operations Staff PNP Systems:
Equipment:
9
CR-PNP-2012- 02560 The grass onsite at PNPS is getting very long and tick season is in full bloom. As you may know, ticks carry Lyme Disease, a debillitating and potentally lethal ailment. In the Discoverd:
6/10/2012 7:29:30 AM interest of saving human lives, please cut the grass. Please see to this ASAP as even one Originated: 6/10/2012 7:42:01 AM death is one too man.
Originator: Anonymous Securityr Alntmous SafPComment Petitioners : We suspect that the real, or certainly other, reason CR-PNP-2012-02560 was written by security is their concern for any terrorist's Systems:
health who may be hiding in the grass onsite and get bitten by ticks carrying Equipment:
Lyme disease and become gravely ill.
C(R-PNP-2012- 02561 NRC personnel noted that control room log for 6/9/12 nightshift and 6/9/12 dayshift did not fully identify all of the members assigned to the tire brigade for those two shifts.
Discoverd:
6/10/2012 10:04:19 AM Specifically, the deputy fire member for 6/9/12 nightshift and the 5th member for 6/9/12 Originated: 6/10/2012 12:02:52 PM dayshifi were not logged. The positions not fully identified were from both Operations and Security. Review of all fire brigade positions for the contingency time period determined that although the log did not fully reflect fire brigade assignments, all required fire Operations Mgmt PNP positions were properly staffed. See Immediate actions section below.
Systems:
Equipment:
Immediate Action
Description:
Reviewed fire brigade log entries from when contingency staffing began (6/5/12 @ 2300).
log was not fully updated. Those instances were 4th and 5th positions on 6/6/12 dayshift at personnel assignments and discussion with Security supervision for the shifts in question d required fire brigade positions were properly staffed. Those positions were covered by the Reid); 5th Position Security (Hart) 6/7/12 Nightshift: 5th Position Security (P. Nugent) 6/9 Confirmed via the Security Shift Commander that J. Couto was onsite for the full shift witl (N. Reid)
CR-PNP-2012- 02562 Trending Condition Report. CRD Suction Filter 'B' has shown a rising Differential pressure increasing by 0.3 psid per day. Current reading is 5.7 psid and tour reading max Discoverd: 6/10/2012 12:22:38 PM is 10 psid.
Originated: 6/10/2012 12:42:57 PM Originator: McGilvray,Kyle R Operations Staff P'NP Systems:
Equipment:
CR-PNP-2012- 012563 Received accumulator alarm on HCU 14-15, reviewed ARP and dispactched Rtx. Bldg.
operator to investigate and restore.
Discoverd: 6/10/2012 4:40:31 PM Originated: 6/10/2012 4:47:03 PM Originator: Knell,Kenneth C Operations Staff PNP Systems:
Equipment:
10
CR-PNP-2012- 02564 THE FIRST HALF OF THE BREAKERS IN P-6 DO NOT HAVE THE BREAKER INDEX SUPPLIED. THIS IS REQUIRED FOR THE TOUR OPERATOR TO Discoverd:
6/10/2012 9:36:08 PM DETERMINE IF BREAKERS ARE CLOSED AS APPROPRIATE.
Originated: 6/10/2012 9:38:28 PM Originator: Coolidge.Robert W Comment Petitioners CR-PNP-2012-02564 was written because half the Operations Staff PNPI breakers in breaker panel P-6 are not labeled. The replacement workers need the labels to be able to check that the appropriate breakers are closed.
Systems:
Equipment:
CR-PNP-2012- 02565 Discoverd:
Originated:
Originator:
6/11/2012 4:42:49 AM 6/11/2012 4:48:02 AM Smryth,Donald P Focused Self Assessment of the Maintenance First Line Supervisor (MFLS) identified the following Negative Observation: A comparison of focus areas to long range training plan for MFLS indicated there is not a strong correlation between site business plan goals or flocus areas and the long range plan. The team recommends that the long range plan be enhanced by correlating site business plan goals and focus areas into the schedule. Also, we recommend including the reason for training in the schedule emphasizing training for performance improvement.
Training Support Staff PNP.
Systems:
Equipment:
CR-PNP-2012- 02566 Discoverd:
Originated:
Originator:
6/11/2012 4:48:23 AM 6/11/2012 4:51:02 AM Smyth.l)onald P Focused Self Assessment of the Maintenance First Line Supervisor (MFLS) identified the following Negative Observation: The quality of the management observations was found to be very light on comments for ME and EE. There was no indication of coaching being perlbrmed by the observer to the instructor and no indication of follow up actions or that comments for Needs Improvement (NI) was evaluated for action. Evaluate how to improve management observations at PNPS.
Training Support Staff PNP Systems:
Equipment:
CR-PNP-2012- 02567 Focused Self Assessment of the Maintenance First Line Supervisor (.MFLS) identified the following Negative Observation: A negative finding was identilied in the focused self assessment of MFLS training; Instructor evaluations contain little detail and there is a lack of SME evaluations. Evaluate how to improve instructor evaluations.
Discoverd:
Originated:
Originator:
Systems:
Equipment:
6/11/2012 4:52:56 AM 6/11/2012 4:54:32 AM Smyth.Donald P Training Support Staff PNIP CR-PNP-2012- 02568 Focused Self Assessment of the Maintenance First Line Supervisor (MFLS) identified the lollowing Area for Improvement: An AFI was identified in the focused self assessment of Discoverd:
6/11/2012 4:59:08 AM MFLS training; There are two items in section 4 of ACAD 90-010 which are required to Originated: 6/11/2012 5:01:53 AM be completed prior to independent supervision (Phase I). These two topics are identified as phase two topics in EN-TQ-127 Att. 9. 1. The topics are ?maintenance trending and Originator: Smnyth,Donald P analysis oar root cause detennination? (FLP-SUPV-RCAO) and ?provisions fbr the Training Support Staff PNP review, control, update, and use of vendor bulletins, reports. notices, and maintenance Systems:
related regulatory requirements? (EN-TQ-127 STP-10), also FQC-MFLS-00001 does not contain the required interviews listed in ACAD 90-010 Appendix B (required for Equipment:
independent supervision).
11
I Comment Petitioners CR-PNP-2012-02564 was written because half the breakers in breaker panel P-6 are not labeled. The replacement workers need the labels to be able to check that the appropriate breakers are closed. The ususal workers when which breaker was which.
12