IR 05000293/2013004
| ML13318A304 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/14/2013 |
| From: | Raymond Mckinley NRC/RGN-I/DRP/PB5 |
| To: | Dent J Entergy Nuclear Operations |
| McKinley R | |
| References | |
| IR 13-004 | |
| Download: ML13318A304 (45) | |
Text
UNITED STATES ber 14, 2013
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2013004
Dear Mr. Dent:
On September 30, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents the inspection results, which were discussed on October 23, 2013, 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 NRC-identified finding of very low safety significance (Green).
This finding was determined to involve a violation of NRC requirements. However, because of its very low safety significance, and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the NCV in this report, 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 Resident Inspector at PNPS. In addition, if you disagree with the cross-cutting aspect assignment 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 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 and 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/
Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No: 50-293 License No: DPR-35
Enclosure:
Inspection Report 05000293/2013004 w/Attachment: Supplementary Information
REGION I==
Docket No: 50-293 License No: DPR-35 Report No: 05000293/2013004 Licensee: Entergy Nuclear Operations, Inc.
Facility: Pilgrim Nuclear Power Station (PNPS)
Location: Plymouth, MA 02360 Dates: July 1, 2013 through September 30, 2013 Inspectors: M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP)
B. Smith, Resident Inspector, DRP B. Scrabeck, Resident Inspector, DRP T. Moslak, Health Physicist, Division of Reactor Safety (DRS)
H. Gray, Senior Reactor Inspector, DRS T. Burns, Reactor Inspector, DRS N. Floyd, Reactor Inspector, DRS J. Rady, Reactor Inspector, DRS C. Lally, Operations Engineer, DRS C. Newport, Operations Engineer, DRS Approved By: Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
IR 05000293/2013004; 07/01/2013 09/30/2013; Pilgrim Nuclear Power Station; Problem
Identification and Resolution.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one non-cited violation (NCV) of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI,
Corrective Action, because Entergy did not complete a design control review for the station blackout (SBO) fuel oil transfer system in a timely manner. Entergy extended the corrective action due date out to greater than a year from the discovery of the original condition. Entergy has increased the priority of this design review and captured this issue in condition report CR-PNP-2013-6906.
The performance deficiency was determined to be more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. The failure to complete a timely design review of a credited support system for the onsite power safety function further extends the vulnerability of the safety function if the design review determines the system is inadequate. The inspectors used IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening. The finding was determined to be of very low safety significance (Green)because the finding was a design deficiency that did not result in the loss of system safety function or a loss of safety function of a single train for greater than its Technical Specification allowed outage time. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Entergy did not take appropriate corrective actions to address a safety issue in a timely manner, commensurate with its safety significance. P.1(d). (Section 4OA2)
REPORT DETAILS
Summary of Plant Status
Pilgrim Nuclear Power Station began the inspection period operating at 100 percent reactor power. On July 17, Pilgrim reduced power to 85 percent due to the high temperature of the ultimate heat sink (UHS), and returned to 100 percent reactor power later the same day. On July 18, Pilgrim reduced power to 90 percent due to the high temperature of the UHS, and returned to 100 percent reactor power later the same day. On July 25, Pilgrim reduced power to 90 percent due to the high temperature of the UHS, and returned to 100 percent reactor power on July 26. On August 20, Pilgrim reduced power to 50 percent to perform a condenser thermal backwash, and returned to 98 percent reactor power on August 21. On August 22, Pilgrim initiated a manual scram due to a loss of feedwater and entered forced outage 20-1 to perform repairs to the feedwater system. On August 25, Pilgrim performed a startup and reached 23 percent power on August 26, where the unit remained due to a loss feedwater heating. On August 28, operators increased power to 75 percent power, where the unit remained for troubleshooting of the A reactor feed pump (RFP). On September 8, Pilgrim shut down and entered Forced Outage 20-2 to perform repairs to the A RFP, and to repair steam leaks in the feedwater heating system. On September 15, Pilgrim performed a startup and reached 75 percent reactor power on September 16, where power remained for completion of repairs to the A RFP. Pilgrim returned to 98 percent power on September 17. On September 18, Pilgrim reduced power to 77 percent to perform a control rod pattern adjustment, and returned to 98 percent reactor power later that same day, and power remained at 98 percent due to troubleshooting on the ultrasonic feedwater flow instrumentation. Pilgrim returned to 100 percent power on September 20 and continued to operate at 100 percent power for the remainder of the quarter.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 External Flooding
a. Inspection Scope
During the week of August 5, 2013, the inspectors performed an inspection of the external flood protection measures for Entergy. The inspectors reviewed technical specifications (TS), procedures, design documents, and the Updated Final Safety Analysis Report (UFSAR), Chapter 2.4.2.4, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of external areas of the plant to ensure that Entergy had maintained flood protection barriers in accordance with design specifications. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if Entergy planned or established adequate measures to protect against external flooding events. Documents reviewed for each section of this inspection report are listed in the
.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
A residual heat removal (RHR) system alignment during heavy load lift over B safety-related train components on July 26 Electric fire pump alignment during diesel fire pump maintenance on July 31 Reactor core isolation cooling (RCIC) system during a high pressure coolant injection (HPCI) system quarterly surveillance on August 14 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 UFSAR, TS, work orders (WO),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 their corrective action program (CAP) for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
During the week of August 5, the inspectors performed a complete system walkdown of accessible portions of the A train of the RHR system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, drawings, equipment line-up check-off lists, system health reports, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems 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 to ensure Entergy appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Resident Inspector Quarterly Walkdowns
a. Inspection Scope
The inspectors conducted 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.
B reactor building component cooling water system on August 7 A reactor building component cooling water system on August 7 HPCI pump/turbine room on August 15 RCIC pump quadrant on August 15 RCIC quadrant mezzanine level on August 15 A switchgear and load center room on September 4
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
The inspectors observed a fire brigade drill scenario conducted on August 5, which involved a fire in the Machine Shop adjacent to the 23 elevation of the access control area. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Entergy personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:
Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met The inspectors also evaluated the fire brigades response actions to determine whether their actions were in accordance with Entergys fire-fighting strategies.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
.1 Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors reviewed the CAP to determine if Entergy identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors also focused on the RCIC room to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, common drain lines and sumps.
b. Findings
No findings were identified.
.2 Annual Review of Cables Located in Underground Bunkers/Manholes
a. Inspection Scope
The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could affect risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including cable pits 1, 3, and 4 containing underground safety and non-safety related cables, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. For those cables found submerged in water, the inspectors verified that Entergy had conducted an operability evaluation for the cables and were implementing appropriate corrective actions.
b. Findings
No findings were identified.
1R07 Heat Sink Performance
Triennial Heat Sink Performance (71111.07T - 3 samples)
a. Inspection Scope
Triennial Heat Sink and Heat Exchanger Sample Selection Based on Entergys site risk ranking of safety-related heat exchangers (HXs), a review of past triennial heat sink inspections, recent operational experience, and resident inspectors input, the inspectors selected the salt service water (SSW) cooled reactor building closed cooling water (RBCCW) HXs, a RHR system HX cooled by the RBCCW system, and the air-cooled emergency diesel generators (EDGs) HXs. Additionally, because during the inspection the UHS temperature was nearing the plant TS limit, the inspectors reviewed the plant history, procedural controls and the plant staff activities in addressing an increase in UHS temperature.
For the samples selected, the inspectors reviewed program and system health reports, self-assessments, and Entergy's methods (inspection, cleaning, maintenance, and performance monitoring) used to ensure heat removal capabilities for the safety-related HXs and associated engineering calculations and evaluations. The site UHS system engineering evaluations, testing practices, and maintenance activities were compared to the commitments made in response to Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, the American Society of Mechanical Engineers Code on HX performance testing (OM-S/G-1994), and Electric Power Research Institute Guidance (NP-7552).
Heat Exchangers Directly Cooled by Salt Service Water Both loops of the SSW cooled RBCCW system, and the turbine building closed cooling water (TBCCW) system including the HXs, system pumps and valves were observed during plant walkdowns by the inspectors. These observations included SSW supply to the RBCCW and TBCCW HXs and the outlet from the HXs to the plant systems cooled by the closed loop cooling water.
The inspectors reviewed the salt water side chlorination, cleaning, inspection, and maintenance practices for these HXs, with the responsible system engineer. A sample of video records of the, as-found, and, as-left conditions, of the SSW side of the RBCCW and TBCCW HX, tubesheets, and tubes were reviewed.
Additionally, the inspectors reviewed the controls on chlorination of the SSW system and the water quality of the fresh closed loop cooling water with the plant chemistry department as to the frequency and extent of chemistry analysis. For the "A" RBCCW HX, the inspectors reviewed the HX efficiency test process records and results for the test performed on April 2. The test method and the calculation basis were discussed with the responsible design engineer. During the inspection, the SSW intake temperature approached the UHS TS limit of 75 degrees Fahrenheit maximum. The inspectors reviewed the basis for this limit and the associated calculations with the responsible design engineer.
Heat Exchangers Cooled by Closed Loop Cooling Water.
The inspectors reviewed the programs and procedures for maintaining the safety functions of the "A RHR HX which is cooled by closed cooling water output from one of the RBCCW HXs. The inspectors reviewed the HX efficiency test, process records and results for the test performed on April 15. The test method and the calculation basis were discussed with the responsible design engineer.
The inspectors walked down and observed conditions of the RHR components, including piping, pumps, valves, and HXs with the system engineer.
The inspectors reviewed the most recently completed inspection/cleaning work orders to verify that the as-found and as-left condition of the RHR HXs was bounded by assumptions in the engineering analyses and provided reasonable assurance of continued operability. The inspectors compared RHR surveillance test data to the established acceptance criteria to verify that the results were acceptable and that operation was consistent with design. The inspectors reviewed the RHR flow balance calculation to verify that the minimum calculated flowrate, in conjunction with the heat transfer capability of the RHR HX, supported the minimum heat transfer rates assumed during accident and transient conditions described in the UFSAR.
Air-Cooled Emergency Diesel Generators (EDGs)
The inspectors walked down each of the air cooled EDGs, reviewed the EDG system health reports and discussed the EDG cooling adequacy with the responsible system engineer. The plans for an instrumented test of the EDG oil lubrication system and turbocharger oil cooling were reviewed by the inspectors.
Review of Corrective Action Reports The inspectors selected and reviewed a sample of CAP reports related to the UHS, RBCCW, RHR and EDG HXs. The review verified that Entergy is appropriately identifying, characterizing, and correcting problems related to these systems and components, and that the planned or completed corrective actions for the reported issues were appropriate.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training on July 25, which included a major loss of coolant accident and subsequent loss of primary containment. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. 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. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor.
Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
For the plant activities listed below, the inspectors observed and reviewed operator performance in the main control room. See section 4OA3 for specific discussion of these activities. The inspectors reviewed operational and alarm response, implementation of procedural guidance, and Emergency Action Level evaluations. The inspectors also observed control room conduct and control of evolutions and events.
Loss of main control room annunciators and declaration of unusual event on July 15 Exceedance of UHS temperature limits and reactor plant downpowers to address this condition from July 8 to July 10, and from July 15 to July 18 Primary containment isolation system logic testing on August 7 Reactor plant downpower to support a condenser thermal backwash on August 19 Reactor plant scram following a loss of all 3 RFPs on August 22 Reactor plant shutdown for repair of restricting orifice on feedwater heater bypass line on September 8
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP 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.
Review of Maintenance Rule (a)(1) Action Plan to return EDG system from MR (a)(1)status to MR (a)(2)
Review of Maintenance Rule (a)(1) Evaluation for control rod drive pump failures
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 from service. 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 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.
A EDG and SBO diesel out of service for emergent maintenance on July 3 Elevated risk during low pressure coolant injection testing on July 11 Qualitative and quantitative risk assessment during maintenance and testing on standby gas treatment and control room high efficiency air filtration systems and half scram during scram discharge instrument volume maintenance and emergent orange/yellow risk due to reactor building component cooling water inoperability on July 29 Shutdown risk assessment following a complicated reactor scram and plant cooldown with a short time to boil on August 23
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:
Degraded condition resulting from the loss of all annunciators on July 15 Operational decision making issue to address operational philosophy for high UHS temperature conditions on July 24 Pipe support for RBCCW suction header A severely degraded on July 30 Safety relief valve (SRV) 3C failed to release after lift on the test stand on August 6 RCIC high suction pressure on August 27 SRV 3C leaking on September 15 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.
Standby gas treatment system relay maintenance on July 24 Standby gas treatment and control room high efficiency air filtration system breaker preventative maintenance on August 2 Replacement of standby liquid control pump discharge pressure transmitter on August 15 HPCI turbine steam admission valve maintenance on September 17 Remove and replace PSV-203-7, backup nitrogen supply safety relief valve on September 30
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
.1 Forced Outage 20-1
a. Inspection Scope
The inspectors reviewed the outage schedule and shutdown risk assessments for a forced outage performed from August 22 through August 28. The outage was performed following a complicated reactor scram due to the trip of all 3 RFPs. During this outage, the inspectors observed plant shutdown and startup, as well as the outage activities listed below:
Cold and hot shutdown temperature control Shutdown risk assessment and risk management Implementation of TS Outage control center activities Plant startup Licensee identification and resolution of problems
b. Findings
No findings were identified.
.2 Forced Outage 20-2
a. Inspection Scope
The inspectors reviewed the outage schedule and shutdown risk assessments for a forced outage performed from September 8 through September 16. The outage was performed following a normal shutdown for repair of a restricting orifice on the feedwater heater bypass line. During this outage, the inspectors observed plant shutdown and startup, as well as the outage activities listed below:
Cold and hot shutdown temperature control Shutdown risk assessment and risk management Implementation of TS Outage control center activities Plant startup Licensee identification and resolution of problems
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 Entergy 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:
Standby gas treatment system exhaust fan logic test and instrument calibration on July 29 High drywell pressure, low water level, and high radiation logic system A-inboard functional test on August 8 SSW flow rate operability test on August 8 HPCI quarterly in-service test on August 12 Functional test of initiation circuit associated with start-up transfer and bus A6 on September 11 B EDG monthly surveillance on September 16
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine Entergy emergency drill on July 25 to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspectors observations with those identified by Entergy staff in order to evaluate Entergys critique and to verify whether Entergy staff was properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Public and Occupational Safety
2RS5 Radiation Monitoring Instrumentation
a. Inspection Scope
From August 12 through 15, the inspectors assessed the accuracy and operability of radiation monitoring instruments used to monitor and quantify liquid and gaseous effluents. The inspectors used the requirements contained in the offsite dose calculation manual (ODCM), applicable industry standards, and Entergys procedures, as criteria for determining compliance.
Calibration and Testing Program for Effluent Monitors The inspectors reviewed the current calibration records and alarm set points for installed liquid and gaseous effluent monitors; i.e. liquid radwaste monitor (RM 1705-30) and the main stack monitors (RM 1705-18 A/B). This review included an assessment of the methodology Entergy uses to determine sampler and process flow rates for these effluent instruments.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
Groundwater Protection Initiative (GPI) Program From August 12 through 15, the inspectors reviewed groundwater monitoring results and changes to Entergys program for identifying, mitigating, and monitoring contaminated spills/leaks to on-site groundwater pathways. The inspectors used the guidance contained in Nuclear Energy Institute (NEI) 07-07, Industry Groundwater Protection Initiative (GPI), to evaluate the licensees implementation of the GPI.
Walkdowns and Observations The inspectors walked down the monitoring wells from which groundwater samples are taken and analyzed for tritium. The inspectors reviewed Entergys measures to monitor and analyze groundwater samples, and the plans for installing additional monitoring wells to measure the effectiveness of the contamination controls.
The inspectors assessed the current on-site ground water sample results to determine the trends in the concentrations of tritiated water in the monitoring wells.
The inspectors reviewed relevant condition reports and subsequent actions related to the identification of a separation in the discharge line from the Waste Neutralizing Sump that resulted in contaminating the surrounding soil on site. The inspectors reviewed the data from soil samples and discussed with the project manager the scope of the investigation, mitigating actions, and repair strategies. The inspectors confirmed that the soil condition and related condition reports were contained in the 50.75 (g)decommissioning files.
Problem Identification and Resolution The inspectors assessed whether problems associated with the GPI program are being identified by the licensee at an appropriate threshold and are properly addressed for resolution in Entergys CAP.
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program
From August 12 through 15, the inspectors verified that the radiological environmental monitoring program (REMP) quantifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program.
The inspectors used the requirements contained in 10 CFR 50, Appendix I, the Pilgrim ODCM, applicable industry standards, and Entergys procedures as criteria for determining compliance to the REMP.
a. Inspection Scope
Inspection Planning
The inspectors reviewed the Pilgrim Annual Radiological Environmental Operating Reports for 2011 and 2012, and the results of Entergy assessments since the last inspection to verify that the REMP was implemented and reported in accordance with the TSs and ODCM. This review assessed whether environmental monitoring had been appropriately performed at the required sampling locations and at the proper frequencies, that a land use census had been performed, and that the inter-laboratory comparison program was implemented, and that data was analyzed.
The inspectors reviewed the Pilgrim ODCM, and related procedures, to identify locations of environmental monitoring stations and the sample collection frequency.
The inspectors reviewed the Pilgrim FSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation.
The inspectors reviewed the Pilgrim Annual Radioactive Effluent Release Reports and the most recent results from waste stream analysis, to determine if Entergy is sampling and analyzing for the predominant radionuclides likely to be released in effluents.
Environmental Sampling Inspection The inspectors walked down 11 air sampling stations and 12 thermoluminescent dosimeter (TLD) monitoring stations to determine whether they are located as described in the ODCM and to determine the equipment material condition.
For the selected air samplers, the inspectors reviewed the calibration and maintenance records to verify the operability of the samplers pump and dry gas meter.
The inspectors observed the collection and preparation of environmental samples from different environmental media, including surface water (discharge canal, Bartlett Pond, Powder Point), to verify that environmental sampling is representative of the release pathways as specified in the ODCM and that sampling techniques are in accordance with procedures.
Based on direct observation and review of records, the inspectors assessed whether the meteorological instruments were operable, calibrated, and maintained in accordance with procedures. The inspectors assessed whether the meteorological data readout and recording instruments in the control room and the meteorological tower instruments were operable and reading similar values.
The inspectors evaluated whether missed and/or anomalous environmental samples were identified and reported in the Annual Radiological Environmental Operating Reports. The inspectors selected events that involved a missed sample, inoperable air sampler, lost TLDs, or anomalous measurement to verify that Entergy has identified the cause and has implemented corrective actions.
The inspectosr reviewed any potential changes made to the ODCM as the result of changes in the land census, changes in long-term meteorological conditions, or modifications to the sampler stations, since the last inspection.
The inspectors assessed whether the detection sensitivities for environmental samples were below the lower limits of detection specified in the ODCM. The inspectors reviewed the results of the Entergy inter-laboratory comparison programs to verify the adequacy of environmental sample analyses performed by the licensee. The inspectors assessed whether the results included the radionuclide mix appropriate for the facility.
Identification and Resolution of Problems The inspectors assessed whether problems associated with the REMP were being identified by Entergy at an appropriate threshold and appropriate corrective actions are assigned for resolution in their CAP.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
Mitigating Systems Performance Index (3 samples)
a. Inspection Scope
The inspectors reviewed Entergys submittal of the mitigating systems performance index for the following systems for the period of July 1, 2012 through June 30, 2013:
High pressure injection system (HPCI)
Heat removal system (RCIC)
RHR system To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors also reviewed Entergys operator narrative logs, condition reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
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 their CAP 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 CAP and periodically attended condition report screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample: Station Blackout (SBO) Diesel Fuel Oil Transfer System Design Control
a. Inspection Scope
The inspectors performed an in-depth review of Entergys apparent cause analysis associated with condition report CR-PNP-2012-3428, incorrect hose staged to support the SBO fuel oil transfer system. This condition report was also referenced in NCV 05000293/2012005-01, Failure to Verify the Adequacy of the Design of the SBO Fuel Oil Transfer System, and was selected for review as a follow-up to this NCV.
The inspectors assessed Entergys problem identification threshold, cause analysis, extent of condition review, compensatory actions, and the prioritization and timelines of Entergys 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 Entergys CAP 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.
b. Findings and Observations
Introduction.
The inspectors identified a finding of very low safety significance (Green)involving an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because Entergy did not complete a design control review for the SBO fuel oil transfer system in a timely manner. Specifically, the failure to implement design control measures when this system was first proposed in 1999 was initially identified in August 2012 and has not been completed as of the conduct of this inspection in September 2013.
Description.
In August 2012, the inspectors identified that Entergy did not have a documented design basis for crediting the SBO fuel oil transfer system to meet the seven day underground fuel oil storage tank requirement to support the EDG onsite power safety function. In the apparent cause analysis of this issue, Entergy determined that the SBO fuel oil transfer system had not been subjected to a design change or modification process and, as a result, the necessary design inputs, evaluations, and reviews were not performed. Entergy concluded that a design modification process was not implemented at the time the SBO fuel oil transfer system was established in 1999 to support the safety function of onsite standby power provided by the EDGs.
In September of 2012, Entergy established a corrective action in the subject condition report to develop, implement, and close an engineering change for the equipment and process used to execute the EDG fuel oil transfer process. The original due date for the completion of this action was March 29, 2013.
On March 25, 2013, Entergy extended the due date to July 31, citing the unavailability of personnel to perform design change reviews due to refueling outage preparations. On July 24, an additional extension was requested and approved to move the corrective action completion date out to January 31, 2014, citing additional rigor being applied to the design as part of the nuclear change process and the refueling outage mentioned previously. This additional extension would allow approximately 16 months to pass between problem identification and corrective action completion.
The inspectors review of the status of Entergys corrective actions associated with this original condition report and the subsequent NCV concluded that Entergys corrective actions were not timely nor commensurate with the importance of this system and its support of the EDG onsite power safety function. In addition, the lack of timely corrective action has and will extend the vulnerability of this safety function should the design review determine there is an inadequacy in the design of the system.
Analysis.
The inspectors determined that Entergys failure to take timely corrective action to complete the design change process for crediting the SBO fuel oil transfer system in support of the EDG emergency AC power safety system, as required by 10 CFR 50, Appendix B, Criterion XVI was a performance deficiency that was within Entergys ability to foresee and correct and should have been prevented. This finding is more than minor because it is associated with the design control attribute of the Mitigating System cornerstone, and adversely affected the cornerstones objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to complete a timely design review of a credited support system for the onsite power safety function further extends the vulnerability to the safety function if the design review determines the system is inadequate.
In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because it was a design or qualification deficiency that did not result in the loss of system safety function or a loss of safety function of a single train for greater than its Technical Specification allowed outage time.
The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Correction Action Program, because Entergy did not take appropriate corrective actions to address a safety issue in a timely manner, commensurate with its safety significance [P.1.(d)].
Enforcement.
10 CFR 50, Appendix B, Criterion XVI, requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, from August 2012 through September 2013, Entergy did not complete a design control process to ensure that the SBO fuel oil transfer system would support the EDG onsite power safety function. A corrective action specified to complete this activity was extended twice in 2013 with a current due date of January 2014. The extension of the completion of the design modification process is not commensurate with the potential impact of the issue to the safety function of onsite power. Corrective actions included Design Engineering establishing a higher priority for the completion of this design review in 2013. Entergy has captured this issue in condition report CR-PNP-2013-6906. (NCV 05000293/2013004-01, Failure to Complete a Design Control Review for the SBO Fuel Oil Transfer System in a Timely Manner)
.3 Annual Sample: Review of the Operator Workaround Program
a. Inspection Scope
The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in Entergys procedures (EN-OP-117, Operations Assessments and EN-FAP-OP-006, Operator Impact Index Performance Indicator).
The inspectors reviewed Entergys process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent Entergy self-assessments of the program. The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.
The inspectors also verified that Entergy entered operator workarounds and burdens into the CAP at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.
b. Findings and Observations
No findings were identified.
The inspectors identified that there are a significant number of operator work arounds, operator burdens, control room deficiencies and alarms, and other main control room deficiencies that are not receiving the appropriate attention and priority for resolution.
Entergy has recognized the impact of these issues and have identified and re-prioritized a number of main control room deficiencies to reduce the burden on control room operations personnel.
.4 Annual Sample: 250VDC Back-up Battery Charger Erratic Output Voltage
a. Inspection Scope
The inspectors performed an in-depth review of Entergys failure analysis and corrective actions associated with condition report CR-PNP-2012-02174 that documented an occurrence on May 10, 2012, where the 250VDC (voltage direct current) back-up battery charger output voltage was erratic and unable to maintain the normal bus voltage without constant monitoring and adjustments. Based on the 250VDC back-up battery chargers failure, the back-up battery charger was taken out of service and the 250VDC normal battery charger was placed in service to restore proper voltage to the 250VDC safety-related bus.
The inspectors assessed Entergys problem identification threshold, causal analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of Entergys corrective actions to determine whether Entergy was appropriately identifying, characterizing, and correcting problems associated with this issue. The inspectors compared the actions taken to the requirements of Entergys CAP and 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action. In addition, the inspectors reviewed documentation associated with this issue, including condition and failure analysis reports, and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions to complete full resolution of the issue.
b. Findings and Observations
No findings were identified.
The inspectors found that Entergy took appropriate actions to identify the apparent cause of the issue. The apparent cause was determined to be a potentiometer on the 250VDC battery chargers voltage control module board. The potentiometer was inspected and cleaned which subsequently eliminated the erratic behavior of the battery chargers output voltage.
Entergy promptly investigated the issue and completed a detailed troubleshooting plan to identify the faulty component. In addition to correcting the back-up battery chargers erratic voltage issue, Entergy procured the services of an outside vendor to re-engineer equivalent control module boards to be used for future replacement within the back-up battery charger. Entergy updated their battery charger maintenance procedure to inspect and clean battery charger potentiometers that are susceptible to dust and debris build-up.
The inspectors determined Entergys overall response to this issue was timely, commensurate with the safety significance, and that actions taken and planned were reasonable to resolve the erratic output voltage of the 250VDC back-up battery charger.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 Plant Events
a. Inspection Scope
For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to the appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Entergy made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Entergys follow-up actions related to the events to assure that Entergy implemented appropriate corrective actions commensurate with their safety significance.
Operator response to loss of all annunciator capability and declaration of an Unusual Event on July 15 Operator response to increasing UHS temperatures from July 8 through July 10 and from July 15 through July 18, including two downpowers Operator response to reactor feedwater bypass line leak in the condenser bay on August 1 through 13 Operator response to a complicated reactor scram following the loss of all 3 RFPs on August 22
b. Findings
No findings were identified.
.2 (Closed) LER 05000293/2013-003-00: Loss of Off-Site Power Events due to Winter
Storm Nemo The inspectors reviewed Entergy's actions and reportability criteria associated with LER 05000293/2013-003-00, which is addressed in CR-PNP-2013-00798. On February 8, during Winter Storm Nemo, Pilgrim experienced a loss of off-site power resulting in a load reject and reactor scram. The cause of the loss of off-site power was due to faults external to the Pilgrim switchyard. Upon re-energizing offsite power, subsequent loss of off-site power events occurred due to flashovers in the switchyard from snow and ice buildup on insulators and electrical components. During and following the storm, all plant safety systems responded as designed and operators were able to maintain safe shutdown conditions. Procedure changes and a feasibility study to upgrade switchyard components have been implemented to prevent this event from recurring. The inspectors did not identify any new issues during the review of the LER. This LER is closed.
.3 (Closed) LER 05000293/2013-004-00: Manual Scram Inserted during Reactor Shutdown
The inspectors reviewed Entergys actions and reportability criteria associated with LER 05000293/2013-004-00, which is addressed in CR-PNP-2013-2275. On April 14, during a normal reactor shutdown, a manual reactor scram was inserted due to reactor pressure decreasing faster than normal. It was determined that the root cause of the pressure reduction was due to the operation of a steam seal bypass valve above its steam line pressure operating limit. Entergy revised the applicable procedure to preclude recurrence. The inspectors did not identify any new issues during the review of the LER. This LER is closed.
4OA5 Other Activities
.1 Strike Contingency Plan
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 Local 25 United Government Security Officers of America (UGSOA) personnel engaged in a job action upon the expiration of their contract on October 1. Using the guidance contained in NRC Inspection Procedure 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 security operations would be maintained, as required; and a review to determine if the plan complied with NRC requirements. On September 17, Entergy and UGSOA, Local 25, tentatively agreed to a new contract and union members approved the contract on September 19. No job action was taken.
b. Findings
No findings were identified.
.2 Buried Piping, Temporary Instruction (TI)-2515/182, Phase 2
a. Inspection Scope
The licensees buried piping and underground piping and tanks program were inspected in accordance with paragraphs 03.02.a of the Temporary Instruction (TI) 2515/182, and it was confirmed that activities which correspond to the completion dates, specified in the program, which have passed since the Phase 1 inspection was conducted, have been completed. The licensees buried piping and underground piping and tanks program were inspected in accordance with paragraph 03.02.b of the TI and responses to specific questions found in www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf were submitted to NRC headquarters staff.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On October 23, 2013, the inspectors presented the quarterly inspection results to Mr. John Dent, Site Vice President, and other members of the PNPS staff. The inspectors verified that no proprietary information was retained or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Dent Site Vice President
B. Ahern Electrical System Engineer
G. Blankenbiller Chemistry Manager
G. Bradley Component Engineer
S. Brewer Radiation Protection Manager
D. Brugman Supervisor ALARA/Technical Support
D. Burke Security Manager
R. Byrne Licensing Engineer
B. Chenard Engineering Director
D. Cook I&C Supervisor
S. Cook Chemistry Supervisor
J. Couto Senior Reactor Operator
J. Cox Radiation Protection Operations Supervisor
M. Dagnello Superintendent FIN Team
B. Diorgi I&C Supervisor
K. Drown Nuclear Oversight and Recovery Manager
J. Falconieri Senior Lead Engineer
J. Fitzsimmons Radiation Protection Supervisor
K. Garrell Chemistry Technician
M. Gatslick Security Compliance Supervisor
R. Hargat Radiation Protection Technician
P. Harizi Design Engineer
C. Lewis Instrumentation and Control Technician
W. Lobo Compliance Engineer
J. Lynch Licensing Manager
J. Macdonald Operations Manager
D. Mannai Senior Manager Nuclear Safety and Licensing
W. Mauro Supervisor Radiation Protection Support
T. McElhinney Training Manager
F. McGinnis Licensing Engineer
R. Metthe Senior Engineer
A. Muse Superintendent Operations Training
J. Norris Radiological Engineer
D. Noyes Nuclear Safety Assurance Director
K. OBrien Electrical Maintenance
J. ODonnell System Engineer
J. Ohrenberger Maintenance Manager
R. Pace Design Engineer Supervisor
J. Priest Emergency Preparedness Manager
K. Sejkora Senior Health Physicist/Chemistry Specialist
W. Smith Chemistry Supervisor
M. Thornhill Radiation Protection Supervisor
S. Verrochi General Manager Plant Operations
T. F. White Design Engineering Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Open/Closed
- 05000293/2103004-01 NCV Failure to Complete a Design Control Review for the SBO Fuel Oil Transfer System in a Timely Manner (section 4OA2)
Closed
- 05000293/2013003-00 LER Loss of Off-Site Power Events due to Winter Storm Nemo (section 4OA3)
- 05000293/2013004-00 LER Manual Scram Inserted during Reactor Shutdown (section 4OA3)