IR 05000293/2013005
| ML14041A203 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/10/2014 |
| From: | Raymond Mckinley NRC/RGN-I/DRP/PB5 |
| To: | Dent J Entergy Nuclear Operations |
| McKinley R | |
| References | |
| IR-13-001, IR-13-005 | |
| Download: ML14041A203 (50) | |
Text
February 10, 2014
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2013005 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT 07201044/2013001
Dear Mr. Dent:
On December 31, 2013, 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 January 23, 2014, with Mr. Steven Verrochi, General Manager Plant Operations, 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.
Two NRC-identified findings of very low safety significance (Green) were identified during this inspection. One finding did not involve a violation of NRC requirements and one finding is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any 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 assigned to any 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 Resident Inspector at PNPS.
As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised beginning in calendar year (CY) 2014. New cross-cutting aspects identified in CY 2014 will be coded under the latest revision to Inspection Manual Chapter (IMC) 0310. Cross-cutting aspects identified in the last six months of 2013 using the previous terminology will be converted to the latest revision in accordance with the cross-reference in IMC 0310. The revised cross-cutting aspects will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the CY 2014 mid-cycle assessment review.
In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, 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 NRCs Public Document Room or from the Publicly Available Records 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:
Enclosure:
Inspection Report 05000293/2013005
w/Attachment: Supplementary Information
REGION I==
Docket No:
50-293
License No:
Report No:
Licensee:
Entergy Nuclear Operations, Inc.
Facility:
Pilgrim Nuclear Power Station
Location:
600 Rocky Hill Road
Plymouth, MA 02360
Dates:
October 1, 2013 through December 31, 2013
Inspectors:
M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP)
B. Scrabeck, Resident Inspector, DRP
J. Rady, Reactor Inspector, DRP J. Laughlin, Emergency Preparedness Inspector, Office of Nuclear Security and Incident Response (NSIR)
T. Moslak, Health Physicist, Division of Reactor Safety (DRS)
E. Burkett, Emergency Preparedness Inspector, DRS
T. Fish, Senior Operations Engineer, DRS
T. Hedigan, Operations Engineer, DRS
J. Schoppy, Senior Reactor Inspector, DRS
J. Nicholson, Health Physicist, Division of Nuclear Materials Safety (DNMS)
J. Piotter, Senior Structural Engineer, Office of Nuclear Material Safety and Safeguards
Approved By:
Raymond R. McKinley, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Enclosure
SUMMARY
IR 05000293/2013005; 10/1/2013 - 12/31/2103; Pilgrim Nuclear Power Station (PNPS);
Maintenance Effectiveness and Maintaining Emergency Preparedness.
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) and one finding 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, 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: Initiating Events
- Green.
The inspectors identified a finding (FIN) associated with Entergy Nuclear Operations, Inc. (Entergy) procedure EN-DC-204, Maintenance Rule Scoping and Basis, because Entergy did not perform plant level monitoring in accordance with the criteria set forth therein. Specifically, the plant level performance criteria of Unplanned Scrams and Unplanned Power Changes were not monitored as Maintenance Rule performance criteria. Entergy entered this issue into its corrective action program (CAP) as condition report (CR)-PNP-2013-8114.
The performance deficiency was more than minor because if left uncorrected it would have the potential to lead to a more significant safety concern, and because it is associated with the equipment performance attribute of the Initiating Events cornerstone and the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, failure to monitor the plant against the required performance criteria and subsequent failure to evaluate for functional failures can result in the inability to identify systems that are not effectively being maintained and can contribute to events that upset plant stability and contribute to a significant event. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train or two separate safety systems for greater than the technical specification allowed outage time, and did not represent an actual loss of safety function of one or more non-technical specification trains of equipment designated as risk significant in accordance with Entergys maintenance rule program. The finding has a cross-cutting aspect in the area of Human Performance, Resources component, because Entergy did not ensure that procedures are available and adequate to assure nuclear safety.
Specifically, Entergy did not ensure that Maintenance Rule Bases Documents were updated to include all monitoring criteria requirements set forth in EN-DC-204. H.2(c). (Section 1R12)
Cornerstone: Emergency Preparedness
- Green.
The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.54(t)(1), Conditions of Licenses, for failure to provide adequate justification to extend the review of the emergency preparedness program elements.
Specifically, Entergy did not base its justification on an adequate assessment against a set of performance indicators.
The failure to provide justification based on an adequate assessment against performance indicators to exceed the 12-month interval to perform a review of its emergency preparedness program elements is a performance deficiency within Entergys ability to foresee and correct. The finding is more than minor because it affected the emergency response organization (ERO) readiness, facilities and equipment, procedure quality, and ERO performance attributes of the emergency preparedness cornerstone. This finding is of very low safety significance (Green) because it was a failure to comply with NRC requirements and was not associated with the planning standards of 10 CFR 50.47(b),
Emergency Plans. Entergy entered this issue into its CAP as CR-PNP-2013-07463. This finding was assigned a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program component, because Entergy did not thoroughly evaluate the issue identified in 2009 and did not implement corrective actions to address the issue P.1(c). (Section 1EP5)
REPORT DETAILS
Summary of Plant Status
Pilgrim Nuclear Power Station began the inspection period operating at 100 percent reactor power. On October 9, Pilgrim reduced power to 50 percent to perform a condenser thermal backwash, control rod settle testing, and a control rod pattern adjustment, and returned to 100 percent reactor power on October 10. On October 11, Pilgrim reduced power to 90 percent to perform a control rod pattern adjustment, and returned to 100 percent reactor power the same day. On October 14, Pilgrim scrammed from 100 percent power due to a loss of offsite power caused by the failure of a power pole at an offsite substation. Pilgrim entered Forced Outage 20-3 to replace safety relief valve (SRV) 3C, and to allow NSTAR to perform power pole repairs. On October 21, Pilgrim performed a startup, and reached 100 percent reactor power on October 22. On October 22, Pilgrim reduced power to 80 percent to perform a control rod pattern adjustment, and returned to 100 percent reactor power the same day. On October 23, Pilgrim reduced power to 74 percent to perform a control rod pattern adjustment, and returned to 100 percent reactor power the same day. On November 6, Pilgrim reduced power to 85 percent to perform a condenser thermal backwash and to perform repairs to feedwater check valve 6-CK-62A, and returned to 100 percent reactor power the same day. On November 8, Pilgrim reduced power to 85 percent to perform a control rod pattern adjustment, and returned to 100 percent reactor power the same day. On December 3, Pilgrim shut down and entered Forced Outage 20-4, for repair of a leaking steam seal regulator steam supply valve in the condenser bay. On December 7, Pilgrim performed a startup, and returned to 100 percent reactor power on December 8. On December 20, Pilgrim reduced power to 80 percent to perform a control rod pattern adjustment, returned to 100 percent reactor power the same day, and continued to operate at 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
During the week of November 3, 2013, the inspectors performed a review of Entergys readiness for the onset of seasonal cold weather. The review focused on the emergency diesel generators, the station blackout diesel generator, and the technical support center diesel generator. The inspectors reviewed station procedures, including Entergys seasonal weather preparation procedure and applicable operating procedures, to verify that selected steps had been completed. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the functionality of the systems during cold weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors performed a review of Pilgrims readiness for an impending high wind warning issued by the National Weather Service for November 27. The review focused on Entergys preparations for the storm. The inspectors reviewed station procedures, including Pilgrims coastal storm and severe weather procedures. The inspectors performed walkdowns of the stations outside areas to ensure that station personnel had identified issues that could challenge the operability of systems during high wind conditions.
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:
Station blackout diesel generator prior to long term removal of line 342 offsite power supply from service on October 4
Reactor core isolation cooling (RCIC) train components during a heavy lift in the reactor building on November 13
B control rod drive (CRD) prior to A CRD pump replacement on December 2
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, work orders (WO), CRs, 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 CAP for resolution with the appropriate significance characterization.
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.
A train salt service water pumps room on October 11
B train salt service water pumps room on October 11
A diesel generator day tank room and A diesel generator room on November 1
Diesel driven fire pump room on November 1
High pressure coolant injection (HPCI) control panel room on November 13
b. Findings
No findings were identified.
==1R07 Heat Sink Performance (711111.07A - 1 sample)
a. Inspection Scope
==
The inspectors reviewed the A and B residual heat removal (RHR) area coolers to determine their readiness and availability to perform safety functions. The inspectors reviewed the design basis for the components and verified Entergys commitments to NRC Generic Letter 89-13, Service Water Problems Affecting Safety-Related Equipment. The inspectors reviewed the results of cleaning and inspections of the RHR area coolers. The inspectors reviewed the system health reports and discussed the RHR area cooler cooling adequacy with the responsible system engineer. The inspectors verified that Entergy initiated appropriate corrective actions for identified deficiencies.
b. Findings
No findings were identified.
==1R11 Licensed Operator Requalification Program (71111.11 - 5 samples; 71111.11B - 1 sample)
==
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training on November 20, which included a turbine trip and reactor scram, failure of automatic bus transfer, and a small break loss of cooling accident requiring the use of containment spray. 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 technical specification 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 1R20 and 4OA3 for specific discussion of these activities. The inspectors reviewed operational and alarm response, implementation of procedural guidance, and Emergency Action Level determination.
The inspectors also observed control room conduct and control of evolutions and events.
Reactor Plant downpower to support condenser thermal backwash on October 9
Reactor Plant Scram following a loss of offsite power on October 14
Reactor Plant downpower to support condenser thermal backwash on November 6
Reactor Plant start-up following forced outages on October 20 and December 7
b. Findings
No findings were identified.
.3 Biennial Licensed Operator Requalification
a. Inspection Scope
The following inspection activities were performed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, and Inspection Procedure 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance.
Examination Results
Requalification examination results for year 2013 were reviewed to determine if pass/fail rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process.
The review verified the following:
Individual pass rate on the dynamic simulator scenarios was greater than 80 percent. (Pass rate was 100 percent.)
Individual pass rate on the job performance measure (JPM) part of the operating examination was greater than 80 percent. (Pass rate was 100 percent.)
Individual pass rate on the comprehensive written examination was greater than 80 percent. (N/A: Written examinations will be administered at the end of the two year requalification program cycle, November/December 2014.)
More than 80 percent of the individuals passed all portions of the requalification examination. (Pass rate was 100 percent.)
Crew pass rate was greater than 80 percent. (Pass rate was 100 percent.)
Written Examination Quality
The inspectors reviewed a sample of comprehensive written examinations that facility staff previously administered to the operators in November 2012 and December 2012.
Operating Test Quality
The inspectors reviewed the operating tests (scenarios and JPMs) associated with the onsite examination week, plus additional scenarios and JPMs previously administered to operators prior to the inspection week.
Licensee Administration of Operating Tests
The inspectors observed facility training staff administer dynamic simulator examinations and JPMs during the week of October 21. These observations included facility evaluations of crew and individual operator performance during the simulator examinations and individual performance of JPMs.
Examination Security
The inspectors assessed whether facility staff properly safeguarded examination material, and whether test item repetition guidelines were met.
Remedial Training and Re-examinations
The inspectors reviewed the remedial training package and associated re-examination for an operator who failed a comprehensive written examination previously administered in November 2012.
Conformance with License Conditions
License reactivation and license proficiency records were reviewed to ensure that 10 CFR 55.53 license conditions and applicable program requirements were met. The inspectors also reviewed a sample of records for requalification training attendance, and a sample of medical examinations for compliance with license conditions and NRC regulations.
Simulator Performance
Scenario-based tests and simulator performance tests were reviewed for conformance and fidelity to the plant control room. A sample of simulator deficiency reports was also reviewed to ensure facility staff addressed any identified modeling problems.
Problem Identification and Resolution
The inspectors reviewed recent operating history documentation found in inspection reports, licensee event reports (LERs), Entergys CAP, NRC End-of-Cycle and Mid-Cycle reports, and the most recent NRC plant issues matrix. The inspectors focused on events associated with operator errors that may have occurred due to possible training deficiencies.
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, or component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, 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.
Maintenance Rule 50.65 (a)(3) Periodic Assessment
Loss of all reactor feed pumps resulting in a complicated manual scram on August 22, 2013
b. Findings
Introduction.
The inspectors identified a Green finding of Entergy Procedure EN-DC-204, Maintenance Rule Scope and Basis, because Entergy did not perform plant level monitoring in accordance with the criteria set forth therein. Specifically, the plant level performance criteria of Unplanned Scrams and Unplanned Power Changes were not monitored as Maintenance Rule performance criteria.
Description.
Entergy Procedure EN-DC-204 requires, in part, that each plant establish plant level performance criteria of 2 Unplanned Scrams per 7000 Critical Hours over a rolling four quarter period, and 4 Unplanned Power Changes per 7000 Critical Hours over a rolling four quarter period. These performance criteria are set at two-thirds of the white performance indicator threshold in order to provide margin to that limit for evaluation of SSCs that contribute to adverse plant level performance. Contrary to the guidance contained in EN-DC-204, the above performance criteria were not included in the Pilgrim Maintenance Rule bases document for plant level monitoring. Plant level performance criteria that are included in Pilgrims Maintenance Rule Bases Document include: no more than 235,000 megawatt hours net unplanned generation loss annually, no more than 147,000 megawatt hours net unplanned generation loss annually for similar function components, no more than two unplanned automatic and manual scrams while critical per cycle, and no more than two unplanned safety system actuations per cycle. As the existing monitoring criteria were based on the operating cycle and not the rolling four quarter period specified by EN-DC-204, the existing unplanned scram criteria did not provide equivalent ability to monitor plant performance.
During the first quarter of 2013, Pilgrim reached a performance indicator level of 2.5 unplanned scrams per 7000 critical hours. An input to this performance indicator was the loss of condenser vacuum and manual scram on May 23, 2012. A functional failure determination was performed for this event; however, it narrowly focused on the criteria of net unplanned generation loss, and the existing performance criteria of unplanned scrams during a two year cycle was not addressed. During the third quarter of 2013, Pilgrim again crossed the performance criteria threshold, this time with a performance indicator value of 2.9 unplanned scrams per 7000 critical hours. An input to this performance indicator was the loss of all reactor feed pumps on August 22, 2013. No functional failure determination was performed for this event until inquiries were made by the inspectors on November 19. The subsequent evaluation determined that the event was a Maintenance Rule Functional Failure.
Analysis.
The inspectors determined that Entergys failure to monitor unplanned scrams and unplanned power changes in accordance with EN-DC-204 was a performance deficiency that was within Entergys ability to foresee and correct. The performance deficiency is more than minor because if left uncorrected it would have the potential to lead to a more significant safety concern, and because it is associated with the equipment performance attribute of the Initiating Events cornerstone and the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.
Specifically, failure to monitor the plant against the required performance criteria and subsequent failure to evaluate for functional failures can result in the inability to identify systems that are not effectively being maintained and can contribute to events that upset plant stability and contribute to a significant event. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train or two separate safety systems for greater than the technical specification allowed outage time, and did not represent an actual loss of safety function of one or more non-technical specification trains of equipment designated as risk significant in accordance with Entergys maintenance rule program.
The finding has a cross-cutting aspect in the area of Human Performance, Resources component, because Entergy did not ensure that procedures are available and adequate to assure nuclear safety. Specifically, Entergy did not ensure that Maintenance Rule Bases Documents were updated to include all monitoring criteria requirements set forth in EN-DC-204. H.2(c)
Enforcement.
The inspectors determined that the finding did not represent a violation of regulatory requirements because, although it was a failure to perform required monitoring, it was not associated with a specific SSC and its maintenance rule scope.
The issue has been entered into their CAP as CR-PNP-2013-8114. (FIN 0500293/2013-005-02, Failure to Perform Plant Level Maintenance Rule Monitoring)
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 to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Yellow risk condition during analog trip system trip unit calibration, with RCIC surveillance testing, and with standby liquid control testing on October 2
Shutdown risk assessment following a reactor scram and extended loss of offsite power on October 15
Yellow risk condition during emergency bus loss of voltage and degraded voltage testing, with a fire water storage tank out of service for inspection on October 28
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:
Leakage from feedwater A check valve 6-CK-62A on October 19
Assessment of secondary containment operability due to reactor building truck lock door gap on October 24
Elevated drywell temperatures on November 23
Inability to establish drywell to torus differential pressure on December 9
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 technical specification 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 technical specifications 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.
1R18 Plant Modifications
a. Inspection Scope
The inspectors evaluated a modification to the RCIC system implemented by engineering change package, Engineering Change (EC) 48052, RCIC Vent Valve 13-HO-2 and 13-HO-3 Pressure boundary and Repair. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the design change.
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.
Replacement of a SRV on October 21
Removal and replacement of hydraulic control unit 06-43 solenoid valves on November 6
Feedwater check valve 6-CK-62A leak repair on November 6
Intermediate range monitor C capacitor replacement on November 7
RCIC vent valve 13-HO-2 and 13-HO-3 pressure boundary and repair on December 10
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
.1 Forced Outage 20-3
a. Inspection Scope
The inspectors reviewed the outage schedule and shutdown risk assessments for a forced outage performed from October 14 through October 21. The outage was performed following a reactor scram in response to a loss of offsite power. Entergy utilized this forced outage to replace SRV 3B due to minor leakage. 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 technical specifications
Outage control center activities
Plant startup
Licensee identification and resolution of problems.
b. Findings
No findings were identified.
.2 Forced Outage 20-4
a. Inspection Scope
The inspectors reviewed the outage schedule and shutdown risk assessments for a forced outage performed from December 4 through December 7. The outage was performed following a normal plant shutdown for repair of a leaking steam seal regulator steam supply valve in the condenser bay. During this outage, the inspectors observed plant cooldown and startup, as well as the outage activities listed below:
Cold and hot shutdown temperature control
Shutdown risk assessment and risk management
Implementation of technical specifications
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 technical specifications, 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 liquid control pump quarterly and flow rate test (IST) on October 2
HPCI valve (quarterly) operability test (CIV) on November 13
Low pressure coolant injection loop B quarterly flow rate test and valve test (IST) on November 20
A Emergency diesel generator surveillance test on December 13
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation
a. Inspection Scope
An onsite review was conducted to assess the maintenance and testing of the alert and notification system (ANS). During this inspection, the inspectors conducted a review of the ANS testing and maintenance programs. The inspectors reviewed the associated ANS procedures and the Federal Emergency Management Agency approved ANS Design Report to ensure compliance with design report commitments for system maintenance and testing. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 2. 10 CFR 50.47(b)(5) and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03 -
1 sample)
a. Inspection Scope
The inspectors conducted a review of the PNPS ERO augmentation staffing requirements and the process for notifying and augmenting the ERO. The review was performed to verify the readiness of Entergys key staff to respond to an emergency event and to verify Entergys ability to activate their emergency response facilities (ERF)in a timely manner. The inspectors reviewed the PNPS Emergency Plan for ERF activation and ERO staffing requirements, the ERO duty roster, applicable station procedures, augmentation test reports, the two most recent drive-in drill reports, and corrective action reports related to this inspection area. The inspectors also reviewed a sample of ERO responder training records to verify training and qualifications were up to date. The inspection was conducted in accordance with NRC Inspection Procedure
===71114, Attachment 3. Title 10 CFR 50.47(b)(2) and related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The Office of Nuclear Security and Incident Response headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures and the Emergency Plan located under ADAMS accession number ML13277A364 as listed in the Attachment.
Entergy determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection.
b. Findings
No findings were identified.
1EP5 Maintaining Emergency Preparedness
a. Inspection Scope
The inspectors reviewed a number of activities to evaluate the efficacy of Entergys efforts to maintain the PNPS emergency preparedness program. The inspectors reviewed letters of agreement with offsite agencies; the 10 CFR 50.54(q) Emergency Plan change process and practice; Entergys maintenance of equipment important to emergency preparedness; records of evacuation time estimate population evaluation; and provisions for, and implementation of, primary, backup, and alternate ERF maintenance. The inspectors also verified Entergys compliance at Pilgrim with new NRC emergency preparedness regulations regarding: emergency action levels for hostile action events; protective actions for on-site personnel during events; emergency declaration timeliness; ERO augmentation and alternate facility capability; evacuation time estimate updates; on-shift ERO staffing analysis; and ANS back-up.
The inspectors further evaluated Entergys ability to maintain their emergency preparedness program through their identification and correction of emergency preparedness weaknesses, by reviewing a sample of drill reports, actual event reports, self-assessments, 10 CFR 50.54(t) reviews, and emergency preparedness-related CRs.
The inspectors reviewed a sample of emergency preparedness-related CRs initiated at PNPS from July 2011 through November 2013. The inspection was conducted in accordance with NRC Inspection Procedure 71114.05. 10 CFR 50.47(b), Emergency Plans, and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
Introduction.
The inspectors identified a Green NCV of 10 CFR 50.54(t)(1), Conditions of Licenses, for Entergys failure to provide an adequate justification based on an assessment against performance indicators for exceeding the 12-month interval to perform a review of its emergency preparedness program elements.
Description.
The inspectors identified that Entergy failed to provide an adequate justification to exceed the 12-month interval and not perform the 2012 review of the emergency preparedness program elements.
During the 2009 NRC emergency preparedness program inspection, the inspectors determined that the 2008 quality assurance (QA) surveillance performed to justify exceeding the 12-month review frequency did not include an assessment against adequate performance indicators. The inspectors discussed the issue with Entergy and provided a copy of the published final rule from the Federal Register (64 FR14814; March 29, 1999), which contains expanded guidance on the use of performance indicators related to this rulemaking. The guidance explained that performance indicators are generally intended to monitor success in performing an activity relative to a success level identified as acceptable. The performance indicators discussed above are separate from the three emergency preparedness cornerstone performance indicators submitted by Entergy to the NRC in accordance with Nuclear Energy Institute (NEI) 99-02 guidance. Entergy entered this issue into its CAP as CR-HQN-2009-01043.
Entergy closed the CR after a database of performance indicators had been developed and made available for the emergency preparedness staff. The corrective action also stated that the database would be updated monthly and that a review had been added to the agenda for a bi-weekly emergency preparedness peer group review of performance indicator information. During the 2013 emergency preparedness program inspection, the inspectors reviewed the performance indicators that were developed as a corrective action to the issue initially identified in 2009 and determined that, although various ranges of acceptability had been developed (indicated by green, white, yellow, and red),thresholds had not been established that would initiate or indicate the need for a 10 CFR 50.54(t) review. As explained in the Federal Register, performance that is indicated as being below the acceptable success level would indicate the need for a program review or audit of the affected area. The use of performance indicators provides a means to continually monitor the performance of the emergency preparedness program, in lieu of more frequent reviews as outlined in 10 CFR 50.54(t).
The procedure EN-QV-108, QA Surveillance Process, states that surveillances should address NRC and internal Entergy Emergency Preparedness Performance Indicator status and trends. However, the procedure only recommends that an audit or review be performed if one or more NEI 99-02 indicators have declined, or are likely to decline, from green to white.
While reviewing the documentation for Energys 10 CFR 50.54(t) reviews associated with 2012 and 2013, the inspectors identified that a QA surveillance had again been performed in 2012 to justify exceeding the 12-month review frequency. The 2012 QA surveillance reviewed whether any significant changes were made to personnel, procedures, equipment, or facilities and if those changes adversely affected the emergency preparedness program. Additionally, the QA surveillance reviewed the status of the three NEI 99-02 emergency preparedness cornerstone performance indicators, not the more comprehensive set of performance indicators developed by Entergy in 2009. The inspectors concluded the 2012 QA surveillance did not meet the requirements of 10 CFR 50.54(t)(1) because an adequate assessment against performance indicators was not performed to extend the 12-month review frequency.
Analysis.
The inspectors determined that failure to provide an adequate justification based on an assessment against performance indicators to exceed the 12-month interval to perform a review of its emergency preparedness program elements as required by 10 CFR 50.54(t)(1) is a performance deficiency within Entergys ability to foresee and correct. The finding is more than minor because it affected the ERO readiness, facilities and equipment, procedure quality, and ERO performance attributes of the emergency preparedness cornerstone. The finding was associated with a violation of NRC requirements. This finding was evaluated using Paragraph 5.0.3(a) of IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, and was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements. This finding was assigned a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program component, because Entergy did not thoroughly evaluate the issue identified in 2009 and did not implement corrective actions to address the issue P.1(c).
Enforcement.
10 CFR 50.54(t)(1) states, in part, the licensee shall ensure that all
[emergency preparedness] program elements are reviewedat intervals not to exceed 12-months or, as necessary, based on an assessment by the licensee against performance indicators. Contrary to the above, the 2012 QA surveillance did not provide adequate justification to extend review of the emergency preparedness program elements. Specifically, Entergy did not base their justification on an assessment against a set of performance indicators. Entergy has an open corrective action to perform an apparent cause evaluation of this issue. Because this failure is of very low safety significance and has been entered into Entergys CAP as CR-PNP-2013-07463, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000293/2013-005-01, Failure to Provide Adequate Justification to Extend the 12-Month Review Frequency of the Emergency Preparedness Program.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors conducted the following activities to verify that Entergy was properly implementing physical, administrative, and engineering controls for access to locked high radiation areas (LHRAs) and other radiological controlled areas (RCAs) during power operations and outages. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, relevant technical specifications, and Entergys procedures.
Plant Walkdown and Radiation Work Permit Reviews
The inspectors toured accessible RCAs in the reactor building, radwaste building, turbine building, and auxiliary building. Radiation surveys were reviewed of selected areas to confirm the accuracy of survey data, and the adequacy of postings.
LHRAs and Very High Radiation Areas (VHRAs) were verified to be properly secured, posted, and monitored during plant tours.
The inspectors evaluated the effectiveness of contamination controls that were implemented following the recent loss of off-site power and the subsequent overflowing of building sumps onto floor areas. The inspectors reviewed survey maps and related condition reports, and observed the postings and practices at various work locations in the RCA.
Contaminated Areas, High Radiation Areas, and Very High Radiation Area Controls
The inspectors reviewed procedures related to the control of contaminated areas, high radiation areas, LHRAs, and VHRAs. The inspectors discussed these procedures with Radiation Protection Supervision to determine that any changes made to these procedures did not reduce safety measures.
The inspectors reviewed the actions made in response to changing plant radiological conditions due to the recent crud burst. The crud burst resulted in elevated dose rates in various plant systems including the control rod drive hydraulic control units and the scram discharge instrument volume tank and headers. Additionally, since a scram resulted from a loss of offsite power, power was not available to sump pumps resulting in the sumps overflowing and contaminating floor surfaces.
Radiation Worker and Radiation Protection Technician Performance
During tours of RCAs, the inspectors questioned radiation protection technicians regarding the radiological conditions at the work site and the radiological controls that applied to the task. Additionally, radiological-related CRs, including dose/dose rate alarm reports, were reviewed to evaluate if the incidents were caused by repetitive radiation worker or technician errors and to determine if an observable pattern traceable to a similar cause was evident.
Problem Identification and Resolution
The inspectors evaluated Entergys program for assuring that access controls to radiological significant areas were effective and properly implemented by reviewing relevant CRs. The inspectors determined that problems were identified in a timely manner, an extent of condition and cause evaluation was performed when appropriate, and corrective actions were appropriate to preclude repetitive problems.
b. Findings
No findings were identified.
2RS2 Occupational As Low as Reasonable Achievable Planning and Controls (71124.02 - 1
sample)
a. Inspection Scope
The inspectors conducted the following activities to verify that Entergy was properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as reasonable achievable (ALARA) for activities performed during the spring refueling outage, forced outages, and power operations. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 and Entergys procedures.
Radiological Work Planning
The inspectors reviewed pertinent information regarding site cumulative exposure history, current exposure trends, refueling outage exposure, and the ongoing challenges resulting from forced outages.
The inspectors reviewed the ALARA Plans for all outage projects whose estimated potential exposure could exceed 5 person-rem. Included in this review were:
scaffolding installation/removal (radiation work permit(RWP) 2013-481), refueling insulation removal/reinstallation (RWP 2013-539), CRD exchange (RWP 2013-509),shielding installation (RWP 2013-501), SRV replacement (RWP2013-506), local leak rate testing (RWP 2013-493), and reactor disassembly/reassembly (RWP 2013-485).
In reviewing these RWPs and associated ALARA post-job reviews, the inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify any missing ALARA program elements and interface problems. The evaluation was accomplished by interviewing site staff, and reviewing outage ALARA Managers Committee and Sub-Committee meeting minutes.
Verification of Dose Estimates
The inspectors reviewed the assumptions and basis for the outage exposure plan. The inspectors also reviewed the revisions made to various outage project dose estimates that resulted from exposure challenges.
The inspectors reviewed Entergys procedures associated with monitoring and re-evaluating dose estimates when the forecasted cumulative exposure for tasks was approached and implementation of these procedures during the outage. The inspectors reviewed the exposures for the ten workers who received the highest doses for 2013 (through October 22, 2013) to confirm that no individual exceeded the regulatory annual limit or the performance indicator criteria.
Problem Identification and Resolution
The inspectors reviewed elements of Entergys CAP, related to implementing the ALARA program to determine if problems were being entered into the program for timely resolution. CRs related to programmatic dose challenges, personnel contaminations, dose/dose rate alarms, and the effectiveness in predicting and controlling worker exposure were reviewed.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors evaluated whether in-plant airborne concentrations are being controlled consistent with ALARA principles. The inspectors used the requirements in 10 CFR 20, Regulatory Guide 8.25, Air Sampling in the Workplace, and Entergys procedures as criteria for determining compliance.
Airborne Controls
There were no current RWPs for airborne radioactivity areas with the potential for individual worker internal exposures to exceed 10 mrem during the forced outages. The inspectors reviewed air sampling records to confirm that airborne radioactivity levels in the RCA were not significant.
During plant tours, the inspectors verified the operability and location of various continuous airborne monitors to assure that areas that were susceptible to airborne radioactivity were properly monitored. AMS-4 monitors examined included those located in the Station Service Red Line, Refuel Floor area, and reactor building truck lock.
Problem Identification and Resolution
The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by Entergy at an appropriate threshold and were properly addressed for resolution in Entergys CAP. The inspectors assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by Entergy.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors evaluated the processes and procedures implemented by Entergy to determine occupational dose. This was performed to determine if the total effective dose equivalent, resulting from external and internal exposure, was appropriately monitored and assessed. The inspectors used the requirements in 10 CFR 20 and Entergys procedures as criteria for determining compliance.
External Dose
During plant tours, the inspectors confirmed that detailed procedures were implemented associated with dosimeter use. The inspectors confirmed that dosimeters were appropriately worn by workers, on their body location receiving the highest dose rate.
The inspectors reviewed CRs related to electronic dose and dose rate alarms received on electronic dosimetry to determine if the cause of the alarm was properly determined and that no performance indicator criteria was exceeded.
The inspectors reviewed exposure records for the ten highest exposed workers occurring in 2013 (through October 21) and electronic dosimeter alarm reports to verify that no regulatory criteria were exceeded and no performance indicator threshold was met.
Internal Dose
The inspectors selected an internal dose assessment in which a worker received a recordable dose of 11 millirem, from inhaling radioactive contamination during the spring refueling outage, to evaluate the adequacy of the calculation and the processes implemented to determine the workers exposure. Included in this review were the initial and follow-up whole body counts for the worker, an evaluation of the radionuclide library used for the counting system including the gamma-emitting radionuclides that exist at the site, and a review of the calculations used to make the dose assessment. The inspectors confirmed that the workers committed effective dose equivalent has been appropriately recorded on the individuals Occupational Dose Record (NRC Form 5).
Problem Identification and Resolution
The inspectors assessed whether problems associated with occupational dose
assessment are being identified by Entergy at an appropriate threshold and are properly addressed for resolution in Entergys CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by Entergy involving occupational dose assessment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Emergency Preparedness (3 samples)
a. Inspection Scope
The inspectors reviewed data for the following three Emergency Preparedness Performance Indicators:
- (1) drill and exercise performance;
- (2) ERO drill participation; and,
- (3) ANS reliability. The last NRC emergency preparedness inspection at PNPS was conducted in the fourth calendar quarter of 2012. Therefore, the inspectors reviewed supporting documentation from emergency preparedness drills and equipment tests from the fourth calendar quarter of 2012 through the third calendar quarter of 2013 to verify the accuracy of the reported performance indicator data. The review of the performance indicators was conducted in accordance with Inspection Procedure 71151, Performance Indicator Verification. The acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 7, was used as reference criteria.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index (2 samples)
a. Inspection Scope
The inspectors reviewed Entergys submittals of the Mitigating Systems Performance Index for the following systems for the period of October 1, 2012, through September 30, 2013:
Emergency AC power system
Cooling water systems
To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed Entergys operator narrative logs, CRs, 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.
.3 Occupational Exposure Control Effectiveness (1 sample)
a. Inspection Scope
The inspectors reviewed implementation of Entergys Occupational Exposure Control Effectiveness Performance Indicator Program. Specifically, the inspectors reviewed CRs and associated documents for incidents involving LHRAs, VHRAs, and unplanned exposures, occurring over the past four calendar quarters, against the criteria specified in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to verify that all occurrences that met the NEI criteria were identified and reported as performance indicators.
b. Findings
No findings were identified.
.4 Radiological Efflluents Technical Specification/Offsite Dose Calculation Manual
Radiological Effluent Occurrences===
a. Inspection Scope
The inspectors reviewed relevant effluent release reports for the period October 1, 2012, through October 1, 2013, for issues related to the public radiation safety performance indicator, which measures radiological effluent release occurrences that exceed 1.5 mrem/quarter whole body, or 5.0 mrem/quarter organ dose for liquid effluents; 5 mrad/quarter gamma air dose, or 10 mrad/quarter beta air dose; and 7.5 mrad/quarter for organ dose for gaseous effluents.
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 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 CAP and periodically attended CR screening meetings.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Entergy outside of the CAP, such as trend reports, performance indicators, major equipment problem lists, system health reports, Quality Assurance Reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed Entergys CAP database to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed Entergys quarterly trend reports to verify that Entergys personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.
b. Findings and Observations
No findings were identified.
Equipment Reliability
Equipment reliability issues resulting in plant transients have been identified as a continuing trend by the inspectors and Entergy. The following observations have been noted by the inspectors: SRV performance was a driver for several down powers and forced outages in 2012 and into 2013; a number of unplanned down powers and shutdowns were the result of non-safety-related equipment failures; it appears that non-safety-related equipment that was characterized as a run-to-failure is starting to reach the end of their service life and can likely become contributors to such events. These issues have directly led to six forced outages in 2013, and have contributed to Pilgrim crossing multiple performance indicator thresholds. Additionally, although two of the events which resulted in complicated scrams at Pilgrim in 2013 were the result of offsite initiators, these also represent opportunities for Pilgrim to further evaluate options to limit their vulnerability to, or to mitigate the consequences of, such events.
.3 Annual Sample: Increased Radiation Levels on Plant Systems due to Crud Bursts
a. Inspection Scope
The inspectors evaluated the effectiveness of Entergys CAP in response to increases in the dose rates and contamination levels of various plant systems and areas due to reactor scrams and subsequent crud bursts. On a broader scope, the inspectors assessed Entergys response to controlling the spread and removal of contamination and implementing radiological controls to keep worker dose ALARA. Specifically, the inspectors reviewed survey maps, CRs, action plans, Entergy procedures, and toured various plant areas that have been affected by crud bursts.
Background
During the period January 1 through October 14, the plant has experienced several reactor scrams and forced outages. As a result of these scrams, crud bursts occurred that resulted in radioactive contamination being dislodged from reactor system piping and components and re-located elsewhere in these plant systems. This relocation has resulted in increased dose rates in the affected components and surrounding areas. The crud was transported to the CRD hydraulic control units, scram discharge instrument volume headers/ piping, reactor water cleanup system, reactor water sample sink, mitigation monitoring system, and the RHR system.
Additionally, some of the scrams resulted from the loss of off-site power. With the loss of off-site power, sump pumps for plant areas became inoperable, resulting in the sumps overflowing and spreading contamination to floor areas.
In response to the changing radiological conditions, a multi-department team was formed to identify corrective actions to minimize personnel exposure. Immediate actions were taken by the radiation protection department to systematically evaluate plant dose rates, update survey maps, repost the affected areas, and evaluate measures to remove contamination from the affected systems and plant areas.
b. Findings and Observations
Identification of Issues
The inspectors determined that procedural criteria (EN-LI-102, Corrective Action Process, Revision 22) have been implemented to assure that any significant changes in plant radiological conditions are captured in the CAP. Entergy has consistently generated CRs at a low threshold to assure that any off-normal condition is promptly addressed to assure that the cause is understood, that response actions are assigned to specific individuals, and that the progress in returning the area or component to its normal condition is monitored.
Additionally, specific procedures were implemented to characterize the extent and magnitude of elevated dose rates; i.e. EN-RP-108, Radiation Protection Posting, and EN-RP-109, Hot Spot Program. Accordingly, the affected components and areas were reposted to identify changes in the classification of the areas based on dose rates and contamination levels. To assure that personnel are aware of changed radiological conditions, prior to entry into the RCA, workers are briefed by radiation protection technicians and the most current survey map is reviewed by the workers.
Prioritization and Evaluation of Issues
The inspectors determined that a multi-disciplinary team was formed to systematically evaluate issues and identify possible actions to minimize personnel dose. By evaluating the extent of elevated dose rates, the team developed strategies and prioritization of tasks. Strategies included flushing hot spots, shielding of components, hydrolyzing piping, de-sludging crud buildup locations, and manually decontaminating plant areas.
Effectiveness of Corrective Actions
In response to elevated dose rates and loose surface contamination, the inspectors determined that timely actions have been taken to mitigate their effect on routine plant operations. Immediate measures included: reducing dose rates and contamination levels in certain areas, informing workers of enhanced radiological controls, and monitoring the progress in completing the actions. Entergy has developed long term actions to mitigate contamination control problems.
Summary
Entergy has appropriately responded to the challenges caused by increased dose rates and contamination levels in systems and areas that have been affected by crud bursts.
Appropriate actions have been taken by Entergy, to promptly identify changes in plant radiological conditions, and evaluate courses of actions including: ensuring that workers are informed of radiological controls; affected areas are properly posted and access is restricted; contamination is removed; components are shielded; and that radiological conditions are properly monitored and regulatory requirements are met.
.4 Annual Sample: Y11 Automatic Transfer Switch Relay Failure
a. Inspection Scope
The inspectors performed an in-depth review of Entergys failure analysis and corrective actions associated with CR-PNP-2012-04146 that documented an occurrence where the Y1 120VAC instrument bus automatically transferred from its normal power source to its energized backup power source because a circuit selector relay in the Y11 automatic transfer switch (ATS) failed. The plant was operating at 100 percent steady state power when the circuit selector relay failed. During the automatic transfer to the backup power source, there was a momentary loss of the Y1 120VAC instrument bus that caused a temporary loss of the feedwater heaters. The plant subsequently down powered to approximately 70 percent until the feedwater heaters were restored.
The inspectors assessed Entergys problem identification threshold, causal analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of corrective actions to determine whether Entergy was appropriately identifying, characterizing, and correcting problems associated with this issue. 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 direct and apparent causes of the issue. The direct cause of the issue was a failed circuit selector relay within the Y11 ATS. The apparent cause was determined to be that Entergy failed to identify this circuit selector relay during initial preventive maintenance classification which resulted in a lack of establishing a preventive maintenance procedure for replacing this energized relay prior to its failure. Entergy replaced the damaged circuit selector relay coil with a new relay coil in a timely manner. The Y11 automatic transfer switch was then functionally tested and declared fully operational.
Entergy also performed an extent of condition review for this circuit selector relay.
Based on this review, Entergy also replaced the relay coil within the Y12 ATS. Entergy also established a preventive maintenance procedure to periodically perform thermography and testing of the relays in the Y11 and Y12 ATSs in order to verify that the ATSs operate as expected. Lastly, Entergy established a replacement preventive maintenance procedure for the circuit selector relays in both ATSs to prevent age-related degradation of these relays.
The inspectors determined Entergys overall response to the issue was commensurate with the safety significance, was timely, and the actions taken and planned were reasonable to resolve the age-related failure of the Y11 automatic transfer switch circuit selector relay.
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 conduct of a plant downpower to approximately 50 percent power to support a condenser thermal backwash and subsequent return to 100 percent power on October 9
Operator response to a complicated reactor scram following the loss of 345KV Line 355 with 345KV Line 342 out of service for maintenance on October 14
Operator response to the isolation of Main Steam Isolation Valves during reactor startup on October 19
Operator conduct of a plant downpower to approximately 50 percent power to support a condenser thermal backwash and subsequent return to 100 percent power on November 6
b. Findings
No findings were identified.
.2 (Closed) LER 05000293/2013-005-00: Primary Containment Declared Inoperable During
HPCI Testing
The inspectors reviewed Entergy's actions and reportability criteria associated with LER 05000293/2013-005-00, which is addressed in CR-PNP-2013-4262. On May 23, with the plant in the Startup/Hot Standby Mode and reactor pressure approximately 550 psig following a refueling outage, primary containment was declared inoperable due to a leak in the HPCI turbine exhaust line observed while performing the HPCI system flow test. The cause of the leak was the failure to adequately tighten all of the flange bolting due to unique bolting and flange configuration associated with the new check valve and butterfly valve installation during the refueling outage. The flange bolting was subsequently re-tightened, leak rate testing performed, and the primary containment was declared operable. Additional corrective actions were to revise drawings and vendor manuals to provide detail for valve flanged joint assemblies. The inspectors did not identify any new issues during the review of the LER. This LER is closed.
.3 (Closed) LER 05000293/2013-006-00: HPCI Controller Failure to Achieve Rated Flow
while in Auto Mode
The inspectors reviewed Entergy's actions and reportability criteria associated with LER 05000293/2013-006-00, which is addressed in CR-PNP-2013-4286. On May 23, with the plant in the Startup/Hot Standby Mode and reactor pressure approximately 525 psig during plant startup following a refueling outage, Pilgrim declared the HPCI system inoperable due to failure of the HPCI flow indicating controller (FIC-2340-1) to maintain system discharge flow rate above the desired level while in automatic mode during planned post maintenance testing. The cause of this event was determined to be the flow indicating controller out of calibration due to degradation of the automatic (null)control/output circuit. Corrective actions taken included troubleshooting, bench testing, and recalibration of the HPCI flow controller. Additional planned corrective actions included replacement of the controller and evaluation by the vendor/manufacturer. The inspectors did not identify any new issues during the review of the LER. This LER is closed.
.4 (Closed) LER 05000293/2013-007-00: Ultimate Heat Sink and Salt Service Water
System Declared Inoperable
The inspectors reviewed Entergy's actions and reportability criteria associated with LER 05000293/2013-007-00, which is addressed in CR-PNP-2013-5246. On July 16, and again on July 17, during a period of hot summer weather conditions, Pilgrim declared the ultimate heat sink and salt service water systems inoperable due to exceeding the high sea water inlet temperature limit of 75 degrees Fahrenheit. This was due to a combination of increased sea water surface temperature in Cape Cod bay and the contribution of recirculation water from the plants outfall due to wind and tidal conditions. Operational decision making issue (ODMI) actions were put in place to reduce station power levels prior to reaching the technical specification ultimate heat sink temperatures. Additionally, corrective actions have been implemented to incorporate the ODMI actions into station operating procedures. The inspectors did not identify any new issues during the review of the LER. This LER is closed.
.5 (Closed) LER 05000293/2013-008-00: Manual Scram - Reactor Feed Pump Trip
The inspectors reviewed Entergys actions and reportability criteria associated with LER 05000293/2013-008-00, which is addressed in CR-PNP-2013-5949. On August 22, with the reactor at 98 percent power, Pilgrim operators inserted a manual scram due to lowering reactor water level resulting from a trip of the reactor feed pumps. The loss of reactor feed pumps was caused by a loss of power to the pump seal cooling water flow switches and subsequent automatic actuation of the feed pump trip circuit. Operators entered the applicable operating procedures and restored water level using HPCI and RCIC. Pilgrim performed repairs and implemented modifications to ensure that loss of power to the pumps seal flow switches would no longer result in the trip of reactor feed pumps. The inspectors did not identify any new issues during the review of the LER. This LER is closed.
.6 (Closed) LER 05000293/2013-009-00: Loss of Offsite Power and Reactor Scram
The inspectors reviewed Entergy's actions and reportability criteria associated with LER 05000293/2013-009-00, which is addressed in CR-PNP-2013-6944. On October 14, with the plant operating at 100 percent reactor power and the offsite power 345KV Line 342 out of service for upgrades, Pilgrim experienced a loss of the second 345KV Line 355, resulting in a generator full load reject and reactor scram. The cause of the loss of offsite power was the failure of a tower support on the B phase of 345KV Line 355 at the Carver Substation. Repairs were performed and Line 355 was re-energized on October 15. Corrective actions performed were the replacement of the defective pole and inspection of the poles for remaining phases A and C, an aerial inspection of Line 355, and the delay of the scheduled December Line 355 outage to allow for additional run time on Line 342 and to reduce risk associated with winter storms. Additional corrective actions planned include revisions to station procedures to assess single point vulnerability and to consider margin for risk mitigation, formalizing risk mitigation actions for 345KV line removal, and to develop additional requirements to control work during single line configuration. The inspectors did not identify any new issues during the review of the LER. This LER is closed.
4OA5 Other Activities
Construction of an Independent Spent Fuel Storage Installation at Operating Plants (60853 - 1 sample; 60856 - 1 sample)
a. Inspection Scope
On November 20 - 21, 2013, the inspectors conducted a review of Entergy and contractor fabrication activities associated with the construction of the Independent Spent Fuel Storage Installation (ISFSI) pad at PNPS. The inspectors walked down the construction area; examined the rebar installation; and verified that the rebar size, spacing, splice length, and concrete coverage on the top, side, and bottom complied with licensee-approved drawings and specifications. The inspectors also evaluated the concrete formwork installation for depth, straightness, and horizontal bracing and verified the overall dimensions and orientation for compliance to the licensee-approved drawings. The inspectors interviewed Entergy and contract personnel to verify knowledge of the planned work and appropriate oversight of the construction activities.
The inspectors reviewed a sample of concrete truck batch tickets to verify that the concrete delivered to the site met code and specification requirements. The inspectors observed concrete placement, vibration, and finishing for the pad section, and observed tests for concrete slump and air content, temperature measurements, and the collection and preparation of cylinder samples for compression strength tests to verify that the work was implemented according to licensee-approved specifications and referenced industry codes and standards
The inspectors performed an in-office review of ISFSI pad design documentation to determine if the storage pad would adequately support both static and dynamic loads, as required by 10 CFR 72.212(b)(5)(ii), Conditions of General License Issued Under CFR 72.210. The inspectors verified that Entergy used appropriate assumptions in the seismic and liquefaction analyses for the storage pad. The inspectors reviewed Entergys conclusions about the acceptability of the storage pads design with respect to the sites hydrology, geology, and seismology.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On October 24, the inspectors presented the Occupational Radiation Safety inspection results to Mr. S. Brewer, Radiation Protection Manager, and other members of facility radiation protection management. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On October 24, the inspectors presented the Licensed Operator Requalification inspection results to Mr. M. Desilets, Training Manager, and other members of facility training management. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On November 7, the inspectors presented the Emergency Preparedness Program inspection results to Mr. J. Dent, Site Vice President, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On November 21, the inspectors presented ISFSI inspection results to Mr. Charlie Minott, Project Manager for Dry Cask Storage, and other Pilgrim personnel. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
On January 23, the inspectors presented the quarterly baseline inspection results to Mr. Steven Verrochi, General Manager Plant Operations, 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
Licensee Personnel
J. Dent
Site Vice President
J. Bracken
Assistant Operations Manager
S. Brewer
Radiation Protection Manager
D. Brugman
Supervisor ALARA/Technical Support
D. Burke
Security Manager
R. Byrne
Licensing Engineer
B. Chenard
Engineering Director
J. Cotter
LOT Superintendent
J. Cox
Radiation Protection Operations Supervisor
M. Desilets
Training Manager
B. Deevy
System Engineer
M. Gatslick
Security Compliance Supervisor
W. Grieves
Quality Assurance
J. House
Operations Training Manager
W. Lobo
Compliance Engineer
J. Lynch
Licensing Manager
J. Macdonald
Senior Operations Manager
V. Magnetta
Senior Operating Instructor
D. Mannai
Senior Manager Nuclear Safety and Licensing
W. Mauro
Supervisor Radiation Protection Support
T. McElhinney
Training Manager
F. McGinnis
Licensing Engineer
C. Minott
Project Manager
D. Noyes
Director of Regulatory & Performance Improvement
J. Ohrenberger
Senior Maintenance Manager
- J. Priest, Senior
Emergency Preparedness Manager
M. Thornhill
Radiation Protection Supervisor
G. Vazaquez
Quality Assurance Supervisor
S. Verrochi
General Manager Plant Operations
T. F. White
Design Engineering Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000293/2013-005-01 NCV Failure to Provide Adequate Justification to Extend the 12-Month Review Frequency of the Emergency Preparedness Program (Section 1EP5)
- 05000293/2013-005-02
Failure to Perform Plant Level Maintenance Rule Monitoring (Section 1R12)
Closed
- 05000293/2013-005-00 LER Primary Containment Declared Inoperable During
HPCI Testing (Section 4OA3)
- 05000293/2013-006-00 LER HPCI Controller Failure to Achieve Rated Flow while in Auto Mode (Section 4OA3)
- 05000293/2013-007-00 LER Ultimate Heat Sink and Salt Service Water System
Declared Inoperable (Section 4OA3)
- 05000293/2013-008-00
LER
Manual Scram - Reactor Feed Pump Trip (Section 4OA3)
- 05000293/2013-009-00 LER Loss of Offsite Power and Reactor Scram (Section 4OA3)