IR 05000293/2012004
| ML12305A220 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/31/2012 |
| From: | Bellamy R NRC/RGN-I/DRP/PB5 |
| To: | Rich Smith Entergy Nuclear Operations |
| Bellamy R | |
| References | |
| IR-12-004 | |
| Download: ML12305A220 (36) | |
Text
UNITED STATES ber 31, 2012
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2012004
Dear Mr. Smith:
On September 30, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents the inspection results, which were discussed on October 9 with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one self-revealing finding of very low safety significance (Green). This self-revealing finding was determined to not involve a violation of NRC requirements. 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 NRCs Rules of Practice, 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 NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Ronald R. Bellamy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 50-293 License Nos.: DPR-35
Enclosure:
Inspection Report 05000293/2012004 w/Attachment: Supplementary Information
REGION I==
Docket Nos.: 50-293 License Nos.: DPR-35 Report No.: 05000293/2012004 Licensee: Entergy Nuclear Operations, Inc.
Facility: Pilgrim Nuclear Power Station (PNPS)
Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: July 1, 2012 through September 30, 2012 Inspectors: M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP)
B. Smith, Resident Inspector, DRP T. Moslak, Health Physicist, Division of Reactor Safety (DRS)
M. Patel, Reactor Engineer, DRS S. Rutenkroger, Senior Resident Inspector at Vermont Yankee, DRP G. Smith, Physical Security Inspector, DRS Approved By: Ronald R. Bellamy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000293/2012004; 07/01/201209/30/2012; Pilgrim Nuclear Power Station; Follow-Up of
Events and Notices of Enforcement Discretion.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. One finding of very low safety significance (Green) 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 (SDP). The cross-cutting aspect for this finding was determined using IMC 0310,
Components Within Cross-Cutting Areas. Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. The NRCs 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.
A finding of very low safety significance (Green) was identified for personnel not adequately classifying work in regards to processing an emergent work order. Specifically, personnel classified work on a reach rod position indication for valve 1-HO-163, Steam Jet Air Ejector (SJAE) steam supply valve, as minor maintenance, which resulted in the failure to identify and correct the reach rod indicator and position. This resulted in a degraded vacuum during a power maneuver and a subsequent reactor scram. Entergy entered this issue in the corrective action program (CR-PNP-2012-2304).
The finding was determined to be more than minor because it was associated with the Configuration Control (i.e., Operating Equipment Lineup) attribute of the Initiating Events cornerstone, and adversely affected the cornerstones objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations.
The inspectors screened the issue for significance using IMC 0609.04, Phase 1 - Initiating Screening and Characterization of Findings and IMC 0609 Appendix A, Exhibit 1, Initiating Events Screening. The finding was determined to be of very low safety significance (Green)because although the performance deficiency did result in a reactor scram, it did not cause a reactor scram combined with the loss of mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding has a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Entergy did not appropriately plan and coordinate the repair of the SJAE steam supply valve by incorporating the operational impact of the work activity consistent with nuclear safety. H.3(b)
(Section 4OA3)
REPORT DETAILS
Summary of Plant Status
Pilgrim Nuclear Power Station began the inspection period operating at 33 percent reactor power. On July 2, 2012, Pilgrim returned to 100 percent reactor power following repairs to the main generator rectifier bank cooling system. On July 3, operators reduced reactor power to 76 percent to support a control rod pattern adjustment and returned to 100 percent reactor power later that same day. On July 12, operators reduced reactor power to 99 percent to support a brush replacement on the Vital Motor-Generator Set and returned to 100 percent reactor power following the evolution. On July 19, operators reduced power to 60 percent to perform a deep/shallow control rod sequence exchange and returned to 100 percent reactor power.
Following the deep/shallow sequence exchange, on July 20, operators reduced power to 91 percent to support a subsequent control rod pattern adjustment and then returned to 100 percent reactor power. On August 22, operators reduced reactor power to 50 percent to perform a thermal backwash of the main condenser. On August 23, Pilgrim returned to 100 percent reactor power. On August 24, operators reduced reactor power to 88 percent to perform a control rod pattern adjustment and returned to 100 percent reactor power later that same day. On September 22, operators reduced reactor power to 68 percent in response to a fast transfer of the 120VAC non-safety related bus and loss of a feedwater heater. Pilgrim returned to 100 percent reactor power and remained at or near 100 percent through the end of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
B emergency diesel generator (EDG) during maintenance on the A core spray (CS) system A CS system during testing on the B CS system Station blackout diesel generator manual fuel oil transfer system The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications (TS), work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.
The inspectors also reviewed whether Entergy staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
During the week of September 24, the inspectors performed a complete system walkdown of accessible portions of the salt service water system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, hangar and support functionality, applicable temporary modifications, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Entergy appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)
a. Inspection Scope
The inspectors performed tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Entergy controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out-of-service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
Fire Area 1.9, Fire Zone 1.6, control rod drive (CRD) pump quadrant Fire Area 1.9, Fire Zone 1.9, CRD hydraulic control units, east side Fire Area 1.10, Fire Zone 2.11, feedwater pump A area Fire Area 3.3, Fire Zone 3.3, plant computer room Fire Area 5.3, Fire Zone 5.3, C salt service water pump room
b. Findings
No findings were identified.
1R07 Heat Sink Performance (711111.07A - 1 sample)
a. Inspection Scope
The inspectors reviewed one sample of Entergys program for maintenance, testing, and monitoring of risk significant heat exchangers (HXs) to assess the capability of the HXs to perform their design functions. The inspectors also evaluated whether potential common cause problems could affect multiple HXs. Based on its risk significance and performance history, the B residual heat removal heat exchanger was selected for detailed review by the inspectors.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Requalification Review by Resident Inspectors
a. Inspection Scope
The inspectors observed licensed operator simulator as found training on August 20, which included a loss of offsite power event complicated by the loss of an emergency diesel generator and a small break loss of coolant accident. The inspectors evaluated operator performance during the simulated events and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors verified that emergency classifications within the scenario were declared accurately and timely. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the Control Room Supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems. Finally, the inspectors performed a simulator fidelity review to determine if the arrangement of the simulator instrumentation, controls, and tagging closely paralleled that of the control room.
b. Findings
No findings were identified.
.2 Main Control Room Review by Resident Inspectors
a. Inspection Scope
The inspectors observed main control room activities during replacement of a vital motor generator set DC brush, a control rod pattern adjustment, repair of main generator rectifier bank #4, and the restoration from the loss of a feedwater heater during a 120VAC power supply fast transfer. See section 4OA3 for specific discussion of these activities. The inspectors reviewed procedural guidance for station power changes and the power maneuver plan, and observed control room conduct and control of these evolutions.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the two samples listed below to assess the effectiveness of maintenance activities on structures, systems, and components (SSC) performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Entergy was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Entergy staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
(a)(1) evaluation of emergency lighting exceeding functional failure performance criteria (a)(1) evaluation for repeat failures of the K-117 diesel driven air compressor
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Entergy performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Entergy personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Entergy performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Green risk during Y1 on its alternate power supply and the second point feedwater heater B out of service Yellow risk for maintenance and testing on the B residual heat removal system Yellow risk for maintenance and testing on the shutdown transformer and station blackout diesel generator Yellow risk for the high pressure coolant injection system out of service and in the presence of main generator rectifier bank leakage.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Drywell floor sump monitoring equipment not functioning properly First point feedwater heater leak and Operational Decision-Making Issue (ODMI)
Increased hotwell conductivity ODMI Standby liquid control tank level increased approximately 300 gallons Three local power range monitors failed calibration The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to Entergys evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Entergy. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
A control room high efficiency air filtration system temperature switch replacement Reactor water clean-up motor operated valve maintenance Rebuild B standby gas treatment system damper actuators Replacement of vital motor generator set brushes Residual heat removal torus cooling isolation valve MO-1001-34B maintenance Removal of temporary modification and installation of thermal overloads for the A salt service water pump
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and Entergys procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
Vital bus protective relay functional test A salt service water flow rate monthly surveillance B core spray pump quarterly inservice test (IST)
A low pressure coolant injection system pump and valve quarterly IST Main steam isolation valve operability (CIV)
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
During the period August 13 through 16, the inspector performed activities to verify that Entergy was evaluating, monitoring, and controlling radiological hazards for work performed, in locked high radiation areas (LHRA) and other radiological controlled areas.
Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, TS, and Entergy=s procedures.
Radiological Hazards Control and Work Coverage The inspector identified work performed in radiological controlled areas and evaluated Entergys assessment of the radiological hazards. Specific work activities evaluated included calibrating a high activity source; i.e., forty-five
- (45) curies of Iridium-192 (Ir-192), and using this source to calibrate high range instruments, such as the turbine building vent monitors and the steam jet air ejector (SJAE) monitors. These activities were classified by Entergy as an Infrequently Performed Test/Evolution (IPTE) and additional administrative controls were implemented.
The inspector attended the pre-job briefings for these tasks and evaluated the survey maps, postings, barrier controls, electronic dosimeter dose/dose rate alarm setpoints, and associated radiation work permits (RWP), to determine if the exposure controls were acceptable. The inspector assessed the adequacy of instructions given to workers regarding the radiological conditions near the source location and the contingency plans.
Additionally, the inspector walked down the job sites and observed the work-in-progress for calibrating the radioactive source in the trash compactor building, and the calibration of the SJAE high range monitors in the turbine building.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation
This area was inspected August 13 through 16, to verify that Entergy is assuring the accuracy and operability of radiation monitoring instruments used to protect occupational workers and to protect the public from nuclear power plant operations. The inspector used the requirements in 10 CFR Part 20, 10 CFR Part 50, Appendix A , Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64 Monitoring Radioactive Releases; 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents; 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations; NUREG-0737, Clarification of Three Mile Island Corrective Action Requirements; TS/Offsite Dose Calculation Manual; applicable industry standards; and Entergys procedures required by TS, as criteria for determining compliance.
.1 Inspection Planning
a. Inspection Scope
The inspector reviewed the UFSAR to identify radiation instruments associated with monitoring area radiation, airborne radioactivity, process streams, effluents, materials/articles, and workers. Additionally, the inspector reviewed the associated TS requirements for post-accident monitoring instrumentation. The inspector reviewed a list of in-service survey instrumentation including air samplers and small article monitors (SAM), along with radiation monitoring instruments used to detect and analyze workers external contamination as well as external dose. Additionally, the inspector reviewed personnel contamination monitors and portal monitors including whole-body counters used to detect workers surface and internal contamination. The inspector assessed whether an adequate number and type of instruments were available to support operations.
The inspector reviewed Entergy and third-party evaluation reports of the radiation monitoring program since the last inspection.
The inspector reviewed procedures that govern instrument source checks and calibrations, focusing on instruments used for monitoring transient radiological conditions. The inspector reviewed the calibration and source check procedures for adequacy. The inspector reviewed the area radiation monitor alarm setpoint values and bases as provided in the TS and the UFSAR.
The inspector reviewed effluent monitor alarm setpoint bases and the calculation methods provided in the Offsite Dose Calculation Manual.
b. Findings
No findings were identified.
.2 Walkdowns and Observations
a. Inspection Scope
The inspector walked down the SJAE gaseous effluent radiation monitoring system (1705-3A/B) and the liquid radwaste monitor (1705-30). The inspector determined that the effluent/process monitor configurations aligned with descriptions contained in the UFSAR and Offsite Dose Calculation Manual.
The inspector selected seven portable survey instruments in use or available for issuance and assessed calibration and source check stickers for currency, instrument material condition and operability.
The inspector observed Entergy staff performance for source checks for three different types of portable survey instruments. These instruments included Ludlum 3/12, RO-20, and telepoles. The inspector assessed whether high-range instruments were source checked on all appropriate scales.
The inspector walked down three area radiation monitors and three continuous air monitors to determine whether they were appropriately positioned relative to the radiation sources or areas they were intended to monitor.
The inspector selected four personnel contamination monitors and two small article monitors and evaluated whether the periodic source checks were performed in accordance with Entergy procedures and the manufacturers recommendations.
b. Findings
No findings were identified.
.3 Calibration and Testing Program
Process and Effluent Monitors
a. Inspection Scope
The inspector selected three effluent monitor instruments and evaluated whether channel calibration and functional tests were performed consistent with TS and the Offsite Dose Calculation Manual. The inspector assessed whether
- (a) Entergy calibrated its monitors with National Institute of Standards and Technology traceable sources;
- (b) the primary calibrations adequately represented the plant nuclide mix; (c)when secondary calibration sources were used, the sources were verified by comparison with the primary calibration source; and
- (d) Entergys channel calibrations encompassed the instruments alarm set-points.
The inspector assessed whether the effluent monitor alarm setpoints were established as provided in the Offsite Dose Calculation Manual and station procedures. For changes to effluent monitor setpoints, the inspector evaluated the basis for changes to ensure that an adequate justification exists.
b. Findings
No findings were identified.
.4 Laboratory Instrumentation
a. Inspection Scope
The inspector assessed laboratory instruments used for radiological analyses to determine whether daily performance checks and calibration data indicated that the frequency of the calibrations was adequate and there were no indications of degraded performance. The instrumentation inspected included three gamma spectroscopy systems and a scintillation counter.
The inspector assessed whether appropriate corrective actions were implemented in response to indications of degraded performance.
b. Findings
No findings were identified.
.5 Whole Body Counter
a. Inspection Scope
The inspector reviewed the methods and sources used to perform functional checks on the whole body counter (FastScan) before use and assessed whether check sources were appropriate and align with the plants isotopic mix.
The inspector reviewed calibration records for the whole body counter since the last inspection and evaluated whether calibration sources were representative of the plant radionuclide mix and that an appropriate calibration phantom was used. The inspector looked for anomalous results or other indications of instrument performance problems.
b. Findings
No findings were identified.
.6 Post-Accident Monitoring Instrumentation
a. Inspection Scope
The inspector reviewed the calibration documentation for the reactor building vent (RT-1001-609) high-range monitor. The inspector assessed whether an electronic calibration was completed for all range decades and was calibrated using an appropriate radiation source. The inspector assessed whether calibration acceptance criteria were reasonable, considering the large measuring range and the intended use of the instrument.
The inspector selected two high range effluent monitors, the reactor building vent and SJAE monitors, and evaluated the calibration and availability of these instruments, and observed the radiation source calibration of the SJAE detectors. The inspector reviewed Entergys capability to collect high-range, post-accident effluent samples.
b. Findings
No findings were identified.
.7 Portal Monitors, Personnel Contamination Monitors, and Small Article Monitors
a. Inspection Scope
The inspector selected two PM-7 and two ARGOS 4B portal monitors, two small article monitors (SAM), and observed the daily source checks and verified that the alarm setpoint values were reasonable under the circumstances to ensure that licensed material is not released from the site.
The inspector reviewed the calibration documentation for each selected instrument and reviewed the calibration methods to determine consistency with the manufacturers recommendations.
b. Findings
No findings were identified.
.8 Portable Survey Instruments, Area Radiation Monitors, Electronic Dosimetry, and Air
Samplers/Continuous Air Monitors
a. Inspection Scope
The inspector reviewed calibration documentation for a variety of portable instruments having ion chamber, Geiger tube, and sodium iodide detectors. For these portable survey instruments, the inspector reviewed detector measurement geometry and calibration methods and reviewed the source characterization data for the calibrator.
The inspector reviewed the calibration records for selected electronic dosimeters, continuous air samplers, and area monitors to determine that the instruments were calibrated within the required frequency and met the calibration acceptance criteria.
Area monitors reviewed included the spent fuel pool area, new fuel storage area, standby gas treatment system area, control room area, and condensate pump room.
b. Findings
No findings were identified.
.9 Instrument Calibrator
a. Inspection Scope
The inspector reviewed the current radiation output values for Entergys portable survey and area radiation monitor instrument calibrator units, a bench calibrator (N-273) and a box calibrator (N-360). The inspector assessed whether Entergy periodically verified calibrator output over the range of the exposure rates/dose rates using an ion chamber or an electrometer. The inspector assessed whether the measuring devices had been calibrated by a facility using National Institute of Standards and Technology (NIST)traceable sources and whether decay correction factors for these measuring devices were properly applied by Entergy in its output verification.
b. Findings
No findings were identified.
.10 Calibration and Check Sources
a. Inspection Scope
The inspector reviewed Entergys source term or waste stream characterization per 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.
b. Findings
No findings were identified.
.11 Problem Identification and Resolution
a. Inspection Scope
The inspector evaluated whether problems associated with radiation monitoring instrumentation were being identified by Entergy at an appropriate threshold and were properly addressed for resolution in Entergys corrective action program (CAP). The inspector assessed the appropriateness of the corrective actions for a selected sample of problems documented by Entergy that involve radiation monitoring instrumentation.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
Cornerstone: Mitigating Systems
a. Inspection Scope
The inspectors reviewed Performance Indicator (PI) data to determine the accuracy and completeness of the reported data. The review was accomplished by comparing reported PI data to confirmatory plant records and data available in plant logs, CRs, Licensee Event Reports (LERs), and NRC inspection reports. The acceptance criteria used for the review included Nuclear Energy Institute (NEI) 99-02, Revision 6, Regulatory Assessment Performance Indicator Guidelines, and NUREG-1022, Revision 2, Event Report Guidelines 10 CFR 50.73. The following performance indicators were reviewed:
High pressure coolant injection system from the third quarter of 2011 through the second quarter of 2012 [MS07]
Heat removal system from the third quarter of 2011 through the second quarter of 2012 [MS08]
Residual heat removal system from the third quarter of 2011 through the second quarter of 2012 [MS09]
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergy entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report group (CRG) screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample: Fitness For Duty
a. Inspection Scope
The inspector examined activities performed under Fitness-For-Duty (FFD) hours as an inspection sample for in-depth review to assess the corrective actions taken by Entergy when granting security officers FFD waivers under 10 CFR 26.207. The sample of FFD waivers reviewed was documented in Entergys corrective action program for evaluation and appropriate corrective actions were taken.
The inspector reviewed CRs, FFD waivers, fatigue assessments, work schedules, and interviewed security officers. The inspector assessed Entergys problem identification, evaluation, and corrective action effectiveness to ensure security force personnel were not assigned to duty while in a fatigued condition that could have reduced their alertness or ability to perform functions necessary to identify and promptly respond to plant security threats.
b. Findings and Observations
Entergy granted FFD waivers in accordance with 10 CFR 26 207(a) (1)(i). However, Entergy did not document the specific circumstances on the FFD waiver requiring waivers to be granted. CR-PNP-2012-3906 was issued to document this observation.
The inspectors determined that this did not represent a violation of NRC requirements.
.3 Annual Sample: Operator Workarounds
a. Inspection Scope
The inspectors performed the annual review of operator workarounds to verify Entergy was identifying operator workaround problems at an appropriate threshold and entering them into the corrective action program. The inspectors reviewed identified workarounds to determine whether the mitigating system function was affected, whether the operators ability to implement abnormal and emergency operating procedures was affected, and whether appropriate procedures had been updated to reflect actual plant conditions. The inspection was accomplished through personnel interviews, plant tours, and review of station documents.
b. Findings and Observations
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 Operator and Maintenance Performance during a Downpower to Support Vital Motor
Generator (MG) Set DC Brush Replacement
a. Inspection Scope
The inspectors observed an infrequently performed evolution on July 12. Specifically, the inspectors observed an approximate one percent downpower to support locking up the recirculation pumps scoop tube positioner in order to preclude an increase in recirculation pump speed and resultant power increase should the alternating current (AC) power supply to the vital MG set be lost. In addition, the inspectors observed the brief, reviewed electrician qualifications, and observed the work in the field.
b. Findings
No findings were identified.
.2 Operator Performance during a Downpower to Support a Control Rod Pattern
Adjustment
a. Inspection Scope
The inspectors observed a planned downpower on July 19 to approximately 60 percent reactor power to support a control rod pattern adjustment. The inspectors reviewed procedural guidance for station power changes and the power maneuver plan, and observed control room operator conduct and control of the evolution.
b. Findings
No findings were identified.
.3 Operator and Maintenance Performance during a Repair of Main Generator Rectifier
Bank #4
a. Inspection Scope
The inspectors observed an infrequently performed evolution on August 19. Specifically, the inspectors observed maintenance perform a repair on main generator rectifier bank
- 4, which included installing a patch to secure a stator cooling water leak. In addition, the inspectors observed the brief, reviewed the contingency plan and operations procedures, and observed the work in the field.
b. Findings
No findings were identified.
.4 Operator Performance during the loss of the B 2nd point Feedwater Heater during Y1
fast transfer
a. Inspection Scope
The inspectors observed operator performance following the loss of the B 2nd point feedwater heater. On September 22, Pilgrims Y1 120 VAC electrical bus automatically transferred from its normal to its alternate power supply. During the transfer, the B 2nd point feedwater heater isolated and operators responded by lowering reactor power to 70 percent. The inspectors observed portions of the power maneuver back to 100 percent reactor power, reviewed operations procedures, and observed the evolutions in the control room.
b. Findings
No findings were identified.
.5 (Closed) Licensee Event Report (LER) 05000293/2012-001-00: Safety Relief Valves
Test Pressure Exceeded Setpoint Limits The inspectors reviewed Entergys actions and reportability criteria associated with LER
===05000293/2012-001-00, which is addressed in CR-PNP-2011-5228. On March 28, Pilgrim was notified that three of four two-stage Target Rock Safety Relief Valve (SRV)pilot assemblies had exceeded the TS tolerance limit. These two stage SRVs were replaced with three-stage SRVs during Refueling Outage 18 (April 2011) to address sticking SRVs due to setpoint variance and corrosion bonding. In addition, the tolerance limit for the new SRVs was increased to 3 percent. This LER is closed.
.6 (Closed) Licensee Event Report (LER) 05000293/2012-002-00: Manual Reactor Scram
Due to Degraded Condenser Vacuum
a. Inspection Scope
=
The inspectors reviewed Entergys actions associated with LER 05000293/2012-002-00, which are addressed in the corrective action program as CR-PNP-2012-2304. The event was discussed in NRC Inspection Report 05000293/2012003. The documents reviewed during the inspection are listed in the Attachment. This LER is closed with the following finding.
b. Findings
Introduction.
A finding of very low safety significance (Green) was identified for personnel not adequately classifying work in regards to processing an emergent work order. Specifically, personnel classified work on a reach rod position indication for valve 1-HO-163, SJAE steam supply valve, as minor maintenance which resulted in the failure to identify and correct the reach rod indicator and position. This resulted in a degraded vacuum during a power maneuver and a subsequent reactor scram.
Description.
On May 22, 2012, Entergy initiated a manual reactor scram while performing a thermal backwash on the main condenser when degrading condenser vacuum conditions became apparent (See NRC inspection report 05000293/2012003, Section 4OA3). Following the reactor scram, a root cause was performed and identified the cause of the scram to be a partially open SJAE steam supply valve, 1-HO-163. The partially open valve contributed to the loss of the SJAE inter-condenser loop seal and subsequent degrading main condenser vacuum. For the May 22 thermal backwash configuration, 1-HO-163s correct position would have been closed.
A discrepancy between 1-HO-163s reach rod position and actual position had been identified during the December 2011 forced outage. A work package was processed to correct this discrepancy; however, the classification of the package was inappropriately processed as minor maintenance. The work package did not contain sufficient work plan steps or post work test criteria to adequately address and correct the deficiency.
Furthermore, for a work package to be classified as minor maintenance per Entergys work process, the work requires that no complex work be performed and no plant configuration changes take place. This was not the case. The discrepancy was not resolved and the SJAE steam supply valve was left partially open during the planned thermal backwash.
Analysis.
The inspectors determined that not adequately classifying work for reach rod 1-HO-163 to the SJAE steam supply valve was a performance deficiency within Entergys ability to foresee and correct, and should have been prevented. This condition did not impact the regulatory process and did not contribute to any actual consequences; therefore, Traditional Enforcement did not apply. The finding was determined to be more than minor because it was associated with the Configuration Control (i.e.,
Operating Equipment Lineup) attribute of the Initiating Events cornerstone, and adversely affected the cornerstones objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The inspectors screened the issue for significance using IMC 0609.04, Phase 1 - Initiating Screening and Characterization of Findings, and IMC 0609 Appendix A, Exhibit 1, Initiating Events Screening. The finding was determined to be of very low safety significance (Green) because although the finding did cause a reactor scram, it did not cause a reactor scram combined with the loss of mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding has a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Entergy did not appropriately plan and coordinate the repair of the SJAE steam supply valve by incorporating the operational impact of the work activity consistent with nuclear safety. H.3(b)
Enforcement.
This finding does not involve enforcement action because no violation of a regulatory requirement was identified. Corrective actions (CR-PNP-2012-2304) included applying a caution tag to the steam supply valve reach rod stating to verify position locally when position is changed, and incorporating into pre-outage training a case study that will enforce the expectation for effective work order screening in accordance with the requirements of Entergys work process. Because this finding does not involve a violation and has very low safety significance, it is identified as a finding (FIN). FIN 05000293/2012004-01, Inadequate Processing of Work Package Results in Reactor Scram
.7 (Closed) Licensee Event Report (LER) 05000293/2009-002-01: Failure to Meet
Technical Specification Requirements for Secondary Containment The inspectors reviewed Entergys actions and reportability criteria associated with LER revision 05000293/2009-002-01, which is also addressed in CR-PNP-2009-5295, CR-PNP-2009-5309 and in NRC Inspection Report 05000293/2010002. The revision updated the 10 CFR 50.73 reportability criteria section of the LER to reflect the appropriate reportability coding. This LER is closed.
4OA5 Other Activities
IP 92709 Licensee Strike Contingency Plans, IP 92711 Continued Implementation of Strike Plans During an Extended Strike, and IP 92712 Resumption of Normal Operations after a Strike
a. Inspection Scope
Entergy developed a Staffing Contingency Plan to ensure a sufficient number of qualified personnel were available to continue operations in the event that the Utility Workers Union of America (UWUA), Local 369 personnel engaged in a job action upon the expiration of their contract on May 15, 2012. Using the guidance contained in NRC Inspection Procedure (IP) 92709, Licensee Strike Contingency Plans, the inspectors reviewed Entergys plans to address a potential job action at the site. The inspection included an evaluation of the Staffing Contingency Plan content and the actions needed to implement the plan; a review to determine whether the number of qualified personnel needed for the proper operation of the facility would be available; a review to determine if reactor operations would be maintained, as required, and; a review to determine if the plan complied with TS requirements and other NRC requirements. On May 15, Entergy and UWUA, Local 369 had not come to an agreement on a new contract. The existing contract was subsequently extended until a May 25 deadline. On May 25, Entergy and UWUA, Local 369 had not come to an agreement on a new contract and further extended the existing contract until June 5.
On June 5, Entergy and UWUA, Local 369 engaged in a job action. Using the guidance contained in IP 92711, Continued Implementation of Strike Plans during an Extended Strike, the resident inspectors, with supplemental inspectors from the Region 1 office, reviewed Entergys long term implementation of the strike contingency plans and verified that operations were proceeding in a safe manner during the strike. The inspectors implemented continuous coverage as specified in IP 92711 and observed contingency crews for operations, maintenance, health physics, and chemistry. By June 30, an agreement on a new contract between Entergy and UWUA, Local 369 had not been reached and the job action was still in place. The inspectors continued to implement IP 92711.
On July 7, Entergy and UWUA, Local 369 tentatively agreed to a new contract and union members approved the contract on July 8. During the reintegration of Entergy employees, the inspectors implemented IP 92712, Resumption of Normal Operations after a Strike, and verified that operations were proceeding in a safe manner.
b. Findings
No findings were identified.
.2 Temporary Instruction 2515/187 - Inspection of Near-Term Task Force
Recommendation 2.3 - Flooding Walkdowns On September 24, inspectors commenced activities to independently verify that Entergy conducted external flood protection walkdown activities using an NRC-endorsed walkdown methodology. These flooding walkdowns are being performed at all sites in response to Enclosure 4 of a letter from the NRC to licensees entitled, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ADAMS Accession No.
ML12053A340). The results of this temporary instruction will be documented in a future inspection report.
.3 Temporary Instruction 2515/188 - Inspection of Near-Term Task Force
Recommendation 2.3 - Seismic Walkdowns On September 24, inspectors commenced activities to independently verify that Entergy conducted seismic walkdown activities using an NRC-endorsed seismic walkdown methodology. These seismic walkdowns are being performed at all sites in response to 3 of a letter from the NRC to licensees entitled, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ADAMS Accession No.
ML12053A340). When complete, the results of this temporary instruction will be documented in a future inspection report.
4OA6 Meetings, Including Exit
On August 16, the inspector performed a radiation protection exit meeting and presented the results to Mr. Al Dodds, Nuclear Safety Assurance Director. At the exit meeting, the inspector confirmed that no proprietary information was provided to the inspector.
On October 9, the inspectors presented the inspection results to Mr. Robert Smith, Site Vice President, and other members of the PNPS staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Entergy Personnel
G. Blankenbiller Chemistry Manager
G. Bradley Component Engineering
- D. Brugman Supervisor, ALARA/Technical Support
D. Burke Protective Service Department Section Manager
B. Chenard System Engineering Manager
B. Clow Radiation Protection Technician
S. Colburn Supervisor Access Authorization and Fitness for Duty
J. Cox Supervisor Radiation Protection Operations
J. Dent General Manager Plant Operations
A. Dodds Director Nuclear Safety Assurance
K. Drown Nuclear Oversight Manager
V. Fallacara Engineering Director
A. Felix Auxiliary Operator
J. Fitzsimmons Radiation Protection Supervisor
M. Gatslick Sr. Security Compliance Supervisor
R. German Reactor Operator
R. Hargat Senior Radiation Protection Technician
T. Hatch I&C Superintendent
R. Heckman Senior Radiation Protection Technician
J. House Superintendent Initial Operations Training
W. Lobo Licensing Engineer
J. Lynch Licensing Manager
J. Macdonald Assistant Operations Manager-Shift
J. McClellan Quality Assurance Assessor
T. McElhinney Training Manager
- D. Mannai Senior Manager, Nuclear Safety and Licensing
W. Mauro Supervisor Radiation Protection Support
J. Miketa Senior Radiation Protection Technician
- A. Muse Superintendent, Operations Training
D. Noyes Operations Manager
J. Priest Radiation Protection Manager
- S. Purdy Superintendent, Plant Security
R. Smith Site Vice President
W. Smith Chemistry Supervisor
J. Taormina Maintenance Manager
M. Thornhill Radiation Protection Supervisor
D. Twomey Senior Radiation Protection Technician
J. Whalley Operations Shift Manager
T. White Emergency Planning Manager
- J. Yingling Senior Engineer, Systems Engineering
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000293/2012004-01 FIN Inadequate Processing of Work Package Results in Reactor Scram (Section 4OA3)
Closed
- 05000293/2012001-00 LER Safety Relief Valves Test Pressure Exceeded Setpoint Limits (Section 4OA3)
- 05000293/2012002-00 LER Manual Reactor Scram Due to Degraded Condenser Vacuum (Section 4OA3)
- 05000293/2009002-01 LER Failure to Meet Technical Specification Requirements for Secondary Containment (Section 4OA3)