IR 05000293/2016001
| ML16133A433 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/12/2016 |
| From: | Arthur Burritt NRC/RGN-I/DRP/PB5 |
| To: | Dent J Entergy Nuclear Operations |
| Burritt A | |
| References | |
| IR 2016001 | |
| Download: ML16133A433 (31) | |
Text
May 12, 2016
SUBJECT:
PILGRIM NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000293/2016001
Dear Mr. Dent:
On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents the inspection results, which were discussed on April 28, 2016, 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.
Based on the results of this inspection, no violations of NRC requirements were identified.
In accordance with Title 10 of the Code of Federal Regulations (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 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/
Arthur L. Burritt, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-293 License No. DPR-35
Enclosure:
Inspection Report 05000293/2016001 w/Attachment: Supplementary Information
REGION I==
Docket No. 50-293 License No. DPR-35 Report No. 05000293/2016001 Licensee: Entergy Nuclear Operations, Inc. (Entergy)
Facility: Pilgrim Nuclear Power Station (PNPS)
Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: January 1, 2016 through March 31, 2016 Inspectors: E. Carfang, Senior Resident Inspector S. Elkhiamy, Resident Inspector (Acting)
S. Horvitz, Resident Inspector (Acting)
B. Sienel, Resident Inspector B. Dionne, Health Physicist Approved By: Arthur L. Burritt, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000293/2016001; 01/01/2016 - 03/31/2016; Pilgrim Nuclear Power Station (Pilgrim); Routine Integrated Inspection Report.
This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
REPORT DETAILS
Summary of Plant Status
The unit began the inspection period at 100 percent power. On February 7, 2016, operators commenced a controlled shutdown due to predicted weather conditions. After the winter storm concluded, the unit returned to 100 percent power on February 12, 2016. On February 15, 2016, the unit down powered to 50 percent power due to a main condenser tube leak. The unit returned to 100 percent power on February 16, 2016. The unit down powered to 48 percent power for a planned thermal backwash on March 29, 2016, and returned to 100 percent power on March 30, 2016. The unit remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed Entergys preparations for the onset of severe winter weather conditions listed below. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition.
The inspectors walked down the emergency diesel generators (EDGs) and switchyard to ensure system availability. The inspectors verified that operator actions defined in Entergys adverse weather procedure maintained the readiness of essential systems.
The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.
Noreaster winter storm on January 22, 2016 Blizzard on February 7-8, 2016
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:
Salt service water (SSW) swing pump C during maintenance on SSW pump B on February 17, 2016 Core spray (CS) B system during maintenance on the A CS loop on February 24, 2016 345 kilovolt (kV) line 355 during maintenance on 345 kV line 342 on March 23, 2016 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 Final Safety Analysis Report (FSAR), technical specifications (TSs), work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.
The inspectors also reviewed whether Entergy staff had properly identified equipment issues and entered them into the corrective action program (CAP) for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On February 28, 2016, the inspectors performed a complete walkdown of accessible portions of the SSW system, to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the FSAR 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 as-built system configuration matched plant documentation, and that system components and support equipment remained operable. The inspectors confirmed that systems and components were aligned correctly, free from interference from temporary services or isolation boundaries, environmentally qualified, and protected from external threats. The inspectors also examined the material condition of the components for degradation and observed operating parameters of equipment to verify that there were no deficiencies. For identified degradation, the inspectors confirmed the degradation was appropriately managed by the applicable aging management program. Additionally, the inspectors reviewed a sample of related CRs and WOs 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.
Control rod drive hydraulic control units east side on January 21, 2016 Refueling floor on January 21, 2016 Reactor core isolation cooling (RCIC) pump quadrant on January 21, 2016 Reactor building truck lock on January 21, 2016 Plant computer room on January 26, 2016
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
The inspectors observed a fire brigade drill scenario conducted on January 15, 2016, that involved announced fire drill prep activities in the B battery room and switchgear room. 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 the following specific attributes of the drill:
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 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 actions to determine whether these actions were in accordance with Entergys fire-fighting strategies.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the FSAR, the site flooding analysis, and plant procedures to identify internal flooding susceptibilities for the site. The inspectors review focused on the SSW intake structure. The inspectors verified the adequacy of equipment seals located below the flood line, floor and water penetration seals, common drain lines, level alarms, control circuits, and temporary or removable flood barriers. The inspectors assessed the adequacy of operator actions that Entergy had identified as necessary to cope with flooding in this area and also reviewed the CAP to determine if Entergy was identifying and correcting problems associated with both flood mitigation features and site procedures for responding to flooding.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed two scenarios as part of licensed operator simulator training on March 17, 2016. The first training scenario involved an offshore oil spill, which led to the loss of all SSW, requiring the declaration of an Unusual Event when flooding had the potential to affect safety-related equipment in the SSW bay. The second scenario involved a loss of hotwell level control and the failure of select components to respond or start as required. 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 control room engineer. 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
The inspectors observed the controlled shutdown and subsequent startup associated with predicted blizzard conditions on February 7-11, 2016. The inspectors observed and reviewed rod scram time testing on February 11, 2016. The inspectors observed pre-shift briefings and reactivity control briefings to verify that the briefings met the criteria specified in Entergys procedure EN-OP-115, Conduct of Operations, Revision 16.
Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
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 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 structure, system, or component was properly scoped into the maintenance rule in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria established by Entergy staff was reasonable. As applicable, for structures, systems, and components classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these structures, systems, and components 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.
B SSW pump on January 6, 2016 Fire protection system on March 23, 2016
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Entergy performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Entergy personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Entergy performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Elevated risk with A shutdown cooling train providing decay heat removal during Mars blizzard outage on February 8-10, 2016 Planned maintenance on A EDG with B EDG out of service on February 29, 2016 Planned maintenance on RCIC pump out of service in conjunction with emergent maintenance on B SSW pump on March 4, 2016 Planned heavy lift of a resin cask to the refuel floor area on March 16, 2016
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 based on the risk significance of the associated components and systems:
A EDG room temperature on January 23, 2016 Shutdown transformer disconnect switch hot spot on February 3, 2016 Main turbine electronic pressure regulator power failure alarm on February 11, 2016 Seismic evaluation of SSW pumps restraints on February 25, 2016 A CS system on February 29, 2016 (operator workaround (OWA))
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 TSs and FSAR to Entergys evaluations to determine whether the components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, such as in the case of OWAs, the inspectors determined whether the measures in place would function as intended and were properly controlled by Entergy. Based on the review of the selected OWA listed above, the inspectors verified that Entergy identified OWAs at an appropriate threshold and addressed them in a manner that effectively managed OWA-related adverse effects on operators, and structures, systems, and components.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety.
The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
Switchyard bushing heat lamps on January 11, 2016 Temporary supplemental heating to the EDG building on January 23, 2016
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
The inspectors reviewed the permanent modifications listed below. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modifications. The inspectors observed the installation of the modifications in the field. In addition, the inspectors reviewed modification documents associated with the upgrades and design changes. Inspectors reviewed testing requirements to ensure code standards, when appropriate, were met.
Movement of temperature element 8125-102 in the A EDG room on February 1, 2016 Replacement of B SSW pump baseplate February 15-23, 2016
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 adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, confirmed work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold point were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.
A fuel pool cooling pump motor replacement on January 1-2, 2016 B SSW pump adjustment to correct high vibrations on January 12 and 19, 2016 Control room high efficiency air filtration system A relative humidity switch replacement and instrumentation calibration on February 3, 2016 Replacement of hydraulic control unit 14-03 riser outlet valve 305-112-14-03 and directional control valve SV-305-121 on February 9, 2015 B SSW pump rebuild after baseplate replacement on February 23, 2016 A CS full flow test valve MOV-1400-4A torque switch setting adjustment on February 24, 2016
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors reviewed the stations work schedule and outage risk plan for the forced outage during the period February 7-11, 2016 due to the Mars blizzard. The inspectors reviewed Entergys development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:
Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment out of service Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing Monitoring of decay heat removal operations Activities that could affect reactivity Monitoring of cooldown and heat up rates Fatigue management Identification and resolution of problems related to forced outage activities
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 structures, systems, and components to assess whether test results satisfied TSs, the FSAR, 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:
B EDG quarterly surveillance test on January 13, 2016 Post-accident sampling system and H2O2 analyzer valve quarterly surveillance test on January 20, 2016 Residual heat removal pump B and loop B valves quarterly surveillance tests on February 18, 2016 (in-service test)
Station blackout diesel monthly surveillance test on February 23, 2016 Thermal limits manual calculations surveillance test on March 1, 2016 Logic system functional test of B standby gas treatment system on March 15, 2016
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Occupational and Public Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors reviewed Entergys performance in assessing and controlling radiological hazards in the workplace. The inspectors used the requirements contained in 10 CFR 20, TSs, applicable regulatory guides, and the procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the performance indicators for the occupational exposure cornerstone, radiation protection program audits, and reports of operational occurrences in occupational radiation safety since the last inspection.
Radiological Hazard Assessment The inspectors conducted independent radiation measurements during walkdowns of the facility and reviewed the air sampling and analysis, continuous air monitor use, and any changes to plant operations since the last inspection to verify survey adequacy any new radiological hazards for onsite workers or members of the public.
Instructions to Workers (1 sample)
The inspectors reviewed high radiation area work permit controls and use, observed containers of radioactive materials, and assessed whether the containers were labeled and controlled in accordance with requirements.
The inspectors reviewed several occurrences where a workers electronic personal dosimeter alarmed. The inspectors reviewed Entergys evaluation of the incidents, documentation in the CAP, and whether compensatory dose evaluations were conducted when appropriate. The inspectors verified follow-up investigations of actual radiological conditions for unexpected radiological hazards were performed.
Contamination and Radioactive Material Control The inspectors observed the monitoring of potentially contaminated material leaving the radiological controlled area and inspected the methods and radiation monitoring instrumentation used for control, survey, and release of that material. The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with requirements.
Radiological Hazards Control and Work Coverage (1 sample)
The inspectors evaluated in-plant radiological conditions and performed independent radiation measurements during facility walk-downs and observation of radiological work activities. The inspectors assessed whether posted surveys; radiation work permits; worker radiological briefings and radiation protection job coverage; the use of continuous air monitoring, air sampling and engineering controls; and dosimetry monitoring were consistent with the present conditions. The inspectors examined the control of highly activated or contaminated materials stored within the spent fuel pools and the posting and physical controls for selected high radiation areas (HRAs), locked high radiation areas, and very high radiation areas (VHRA) to verify conformance with the occupational performance indicator.
Risk-Significant HRA and VHRA Controls (1 sample)
The inspectors reviewed the procedures and controls for HRAs, VHRAs, and radiological transient areas in the plant.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with radiation monitoring and exposure control were identified at an appropriate threshold and properly addressed in the CAP.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Reactor Coolant System Specific Activity and Reactor Coolant System Leak Rate (2
samples)
a. Inspection Scope
The inspectors reviewed Entergys submittal for the reactor coolant system (RCS)specific activity and RCS leak rate performance indicators for the period of January 1, 2015, through December 31, 2015. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the performance indicator. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing a RCS sample.
b. Findings
No findings were identified.
.2 Safety System Functional Failures (1 sample)
a. Inspection Scope
The inspectors sampled Entergys submittals for the Safety System Functional Failures performance indicator for the period of January 1, 2015, through December 31, 2015.
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 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed Entergys operator narrative logs, operability assessments, maintenance rule records, maintenance WOs, CRs, 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 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 the CAP and periodically attended CR screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Entergy performed an evaluation in accordance with 10 CFR Part 21.
b. Findings
No findings were identified.
.2 Annual Sample: Corrective Actions from Security Related Findings
On March 3, 2016, inspectors completed a problem identification and resolution sample to review corrective actions taken in response to previous security-related NRC findings.
The results of this inspection sample are documented in NRC Inspection Report 05000293/2016404 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16098A086), issued on April 7, 2016.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
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 appropriate regional personnel, and compared the event details with criteria contained in Inspection Manual Chapter 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.
Down power to 48 percent power due to condenser tube leak on February 15, 2016
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Inspection Procedure 92723, Follow-up Inspection for Three or More Severity Level IV
Traditional Enforcement Violations in the Same Area in a 12-Month Period
a. Inspection Scope
The inspectors performed a follow-up inspection in accordance with Inspection Procedure (IP) 92723 for four Severity Level (SL) IV traditional enforcement violations in the area of potential for impacting the Regulatory Process that occurred between the fourth quarter of 2014 and the third quarter of 2015. Consistent with guidance in IP 92723, multiple traditional enforcement violations in the same area should result in the licensee examining the group of violations to identify any commonalities. This inspection reviewed Entergys evaluation of the group of violations.
The following traditional enforcement violations were the subject of this inspection:
A SL IV non-cited violation (NCV) of 10 CFR 50.59, Changes, Tests, and Experiments, because Entergy made a modification to the spent fuel pool cask area without prior NRC approval. (NCV 2014003-01; December 31, 2014)
A SL IV NCV of 10 CFR 50.72(b)(3)(xiii), Eight Hour Reports, because Entergy did not notify the NRC within eight hours of a major loss of emergency assessment capability (sea water bay level instrumentation). (NCV 2015007-07; March 20, 2015)
A SL IV NCV of 10 CFR 50.73, Licensee Event Report [LER] System, because Entergy did not provide a written report of a violation of TS 3.5.E for the inoperability of the automatic depressurization system to the NRC within 60 days of discovery.
(NCV 2015002-05; June 30, 2015)
A SL IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments, because Entergy made a modification to the 23 kV line to the shutdown transformer without prior NRC approval. (NCV 2015003-04; September 30, 2015)
The objectives of the inspection were:
To provide assurance that the cause(s) of multiple SL IV traditional enforcement violations are understood by Entergy To provide assurance that the extent of condition and extent of cause of multiple SL IV traditional enforcement violations are identified To provide assurance that Entergy corrective actions to traditional enforcement violations are sufficient to address the cause The inspectors reviewed the cause evaluation associated with each of the four issues as well as the common cause analysis, CRs, procedures, and relevant references to the violations. The inspectors also discussed the evaluations with management and staff personnel who were familiar with the violations and participated in the evaluation or corrective actions.
b. Findings
and Assessments No findings were identified.
The inspectors determined that Entergys apparent cause evaluation (CR 2015-07154),which collectively assessed the four violations to identify any common causes, met the inspection objectives of NRC IP 92723. Each of the CRs for the individual violations determined specific causes and corrective actions. Entergy decided to perform the common cause evaluation by determining the nuclear safety culture aspects associated with each of the issues to identify a collective common cause. Although no specific aspect was present in all four issues, Entergy determined the collective apparent cause to be Regulatory Assurance personnel failed to ensure accuracy in 10 CFR 50.59 screening and reportability reviews and failed to provide adequate oversight of operability determinations due to the lack of a right picture and ineffective challenges to the organization. Contributing causes were lack of a questioning attitude by Regulatory Assurance personnel and processes and procedures contained incorrect or lacked detailed guidance to perform some technical related activities. Corrective actions included training of affected personnel on the topics of 50.59 screening, reportability, and regulatory risk recognition, as well as specific procedure revisions. The inspectors determined that the corrective actions contained in CR 2015-07154 were reasonable.
The inspectors identified two observations during this inspection:
Failure to Document an Extent of Cause for the Common Cause Evaluation Entergy procedure EN-LI-123-03, Pre-Inspection Assessments for IP 92723, Revision 1, Attachment 9.1, requires that the extent of causes for the performance issues are identified, but does not specify the type of cause evaluation to be performed. Per Entergy procedure EN-LI-118, Cause Evaluation Process, Revision 22, only root cause evaluations require performance of extent of cause evaluations.
Because Entergy performed an apparent cause evaluation to assess the four violations, an extent of cause was not required. The inspectors determined that this represented a gap in evaluation of the violations. Entergy entered this issue into the CAP as CR 2016-2236. This issue screened to minor in accordance with IMC 0612, Appendix B, because the corrective actions performed would have addressed the extent of cause, in that the actions covered all groups that perform regulatory reviews (Operations, Licensing, Engineering and Medical).
Failure to Identify Internal Operating Experience for the Common Cause Evaluation Entergy did not identify internal operating experience relevant to traditional enforcement violations, as required by Entergy procedure EN-LI-118. Section 5.6 of EN-LI-118 states the purpose of the operating experience section of an evaluation is to determine if same or similar conditions have previously occurred and use the information to 1) assist in identifying the cause, 2) assist in identifying corrective actions and 3) identify potential barriers for use in causal analysis. Entergy performed an internal and external operating experience review as part of their collective cause determination. The inspectors identified that this review did not identify violations issued to Pilgrim in 2011 in the area of potential for impacting the regulatory process regarding licensed operator medical information. Entergy entered this observation into their CAP as CR 2016-2235. The issue screened to minor in accordance with IMC 0612, Appendix B, because the discrepant condition did not impact the scope of the corrective actions.
.2 Follow up Inspection for VIO 05000293/2015010-02 - Untimely Actions to Restore
Station Meteorological Towers
a. Inspection Scope
During the week of March 28, 2016, the inspectors performed an onsite review of Entergys records related to corrective actions taken in response to a Green Notice of Violation (NOV) issued to Pilgrim on October 1, 2015. The NOV involved Entergys untimely action to restore the functionality of the Pilgrim meteorological (met) towers to meet the requirements of 10 CFR 50.54(q)(2) and 10 CFR 50.47(b)(8) and is described in NRC Inspection Report 05000293/2015010. The objectives of the inspection were to determine whether adequate corrective actions have been implemented for the Green NOV, root causes have been identified, generic implications have been addressed, and that Entergys programs and practices have been appropriately enhanced to prevent recurrence. The inspectors reviewed CRs, procedures, and relevant references. The inspectors also walked down the newly installed 160 met tower, verified valid 160 met tower instrument indications were available on station computers and in the control room, and discussed the issue with responsible management and staff personnel.
b. Findings and Observations
No findings were identified.
Entergys apparent cause (CR 2013-6829) and root cause (CR 2015-0375) evaluations appropriately identified the apparent and contributing causes that resulted in the untimely restoration of the Pilgrim 160 met tower to service. Entergys corrective actions included the installation of a new 160 met tower which was placed in service on December 8, 2015, assigning overall met tower responsibility to the emergency preparedness department, and procedure changes to ensure appropriate met tower testing and preventive maintenance is performed. While 220 met tower equipment challenges continue, corrective actions to develop and implement a comprehensive instrument upgrade and maintenance plan are in progress. The inspectors determined that adequate corrective actions had been taken to restore 160 met tower functionality and preclude recurrence. VIO 05000293/2015010-02, Untimely Actions to Restore Station Meteorological Towers, is closed.
.3 Repetitive Degraded Cornerstone Column (Column 4) Follow-Up Activities
Background As described in the annual assessment letter, dated March 2, 2016 (ADAMS Accession No. ML16061A419), PNPS remains in the Repetitive Degraded Cornerstone Column (Column 4).
Completed Activities Regional NRC management conducted weekly teleconferences with PNPSs Recovery Manager to discuss the stations progress related to Column 4 recovery efforts. Regional management conducted multiple site visits to Pilgrim to meet with senior PNPS management, as well as provided oversight for various inspections conducted during the first quarter, including the IP 95003 Phase B inspection.
Inspectors conducted the IP 95003 Phase B inspection from April 4-8, 2016. The purpose of the inspection was to review overall CAP performance since the last problem identification and resolution inspection completed in August 2015, focusing on improvements made to the program as a result of Entergys recovery efforts. The results of the inspection will be documented in a stand-alone report, which will be issued on or about May 23, 2016.
.4 Institute of Nuclear Power Operations/World Association of Nuclear Operators
(INPO/WANO) Report Review
a. Inspection Scope
The inspectors reviewed the final report for the INPO/WANO plant assessment of PNPS conducted in late July 2015. The inspectors evaluated this report to ensure that NRC perspectives of Entergy performance were consistent with any issues identified during the assessments. The inspectors also reviewed this report to determine whether INPO/WANO identified any significant safety issues that required further NRC follow-up.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On April 28, 2016, the inspectors presented the 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 by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Dent, Site Vice President
- S. Asplin, Senior Engineer
- P. Bracken, Operations Manager
- D. Calabrese, Emergency Protection Manager
- W. Carroll, Senior Engineer
- P. Doody, Senior Engineer
- J. Falconieri, Senior Engineer
- G. Flynn, Operations Manager
- K. Gracia, Shift Manager
- M. Green, Motor Operated Valve Engineer
- D. Grimes, Senrior Engineer
- E. Hatzinikolaou, System Engineer
- G. James, Reactor Engineering Supervisor
- M. Landry, Senior Engineer
- M. Lynch, Engineering Supervisor
- J. MacDonald, General Manager, Plant Operations
- M. Mantenfel, Engineering Supervisor
- P. Miner, Regulatory Assurance
- J. Sabina, Senior Engineer
- B. Swanson, Mechanical Engineer
- J. Whalley, Shift Manager
- T. White, Engineering Supervisor
- K. Woods, Engineering Supervisor
- W. Wouti, Project Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Closed
- 05000293/2015010-02 VIO Untimely Actions to Restore Station Meteorological Towers (Section 4OA5)