ML17214A088

From kanterella
Jump to navigation Jump to search
Confirmatory Action Letter - Pilgrim Nuclear Power Station
ML17214A088
Person / Time
Site: Pilgrim
Issue date: 08/02/2017
From: Dan Dorman
Region 1 Administrator
To: Brian Sullivan
Entergy Nuclear Operations
Burritt A
References
EA-17-086
Download: ML17214A088 (56)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD.

KING OF PRUSSIA, PA 19406-2713 August 2, 2017 EA-17-086 Mr. Brian Sullivan Site Vice President Entergy Nuclear Operations, Inc.

600 Rocky Hill Road Plymouth, MA 02360-5508

SUBJECT:

CONFIRMATORY ACTION LETTER - PILGRIM NUCLEAR POWER STATION

Dear Mr. Sullivan:

This Confirmatory Action Letter (CAL) confirms the commitments made by Entergy Nuclear Operations, Inc. (Entergy) to the U.S. Nuclear Regulatory Commission (NRC) concerning Pilgrim Nuclear Power Station (Pilgrim). In a letter dated July 28, 2017, Pilgrim Nuclear Power Station (PNPS) Recovery Plan (ML17212A5711) (Enclosure 1), Entergy notified the NRC staff of its revised plan to perform specific corrective actions to resolve the causes for the performance decline that led to Pilgrims transition to the Multiple/Repetitive Degraded Cornerstone Column (Column 4) of the NRCs Reactor Oversight Process (ROP) Action Matrix, as discussed in the 2015 mid-cycle assessment letter, dated September 1, 2015 (ML15243A259). The NRC understands that you will implement the action items described in .

In our 2015 mid-cycle assessment letter, we informed you that Pilgrim entered Column 4, or the Multiple/Repetitive Degraded Cornerstone Column, of the NRCs ROP Action Matrix as described in Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program.

The entry into Column 4 was caused by the issuance of an additional White finding in the Mitigating Systems cornerstone while Pilgrim was in the Degraded Cornerstone Column (Column 3) of the ROP Action Matrix for more than five consecutive quarters. Pilgrim had entered the Degraded Cornerstone Column for two White inputs under the Initiating Events cornerstone. Four scrams in 2013 caused two performance indicators in the Initiating Events cornerstone, Unplanned Scrams per 7000 Critical Hours and Unplanned Scrams with Complications, to cross the threshold from Green to White (ML15026A069). The additional White finding documented on September 1, 2015 (ML15230A217), in the Mitigating Systems cornerstone was associated with the failure to identify, evaluate, and correct a significant condition adverse to quality associated with the Pilgrim A safety relief valve (SRV) which resulted in the C SRV failing to open on January 27, 2015, during a loss of offsite power event.

NRC IMC 0305 specifies the actions that will be taken when plant performance is in Column 4 of the ROP Action Matrix. Specifically, you developed a recovery plan based on the results of your 1

Designation in parentheses refers to an Agencywide Documents Access and Management System (ADAMS) accession number. Documents referenced in this report are publicly available using the accession number in ADAMS.

B. Sullivan 2 evaluation of the issues that led to Pilgrims degraded performance, and as required by IMC 0305, the NRC staff reviewed your recovery plan in accordance with Inspection Procedure (IP) 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input. The results of this inspection are documented in NRC Inspection Report 05000293/2016011 (ML17129A217). Based on these inspection results, the NRC identified weaknesses in your recovery plan that needed to be addressed.

As discussed in your July 28 letter, you have evaluated the results of the IP 95003 supplemental inspection, revised your recovery plan to address the identified issues, and issued those revisions in the PNPS Recovery Plan that is included in Enclosure 1. The plan consists of 11 Area Action Plans that identify the key improvement actions and the effectiveness measures (e.g., metrics and assessments) that will be used to monitor future performance.

The NRC reviewed the revised PNPS Recovery Plan and determined that effective implementation of the plan would satisfactorily address the fundamental problem areas that led to the transition of Pilgrim to Column 4 in a manner that should lead to sustained performance improvement. Included with this CAL as Enclosure 2 is a subset of the corrective actions described in the PNPS Recovery Plan that the NRC staff determined are necessary to address the key performance issues identified by our assessment activities including the IP 95003 inspection. The NRC staff will assess the effectiveness of Entergys implementation of these identified corrective actions and evaluate whether the safety performance of Pilgrim has demonstrated sustained improvement warranting transition of Pilgrim out of Column 4 in accordance with IMC 0305, Section 10.02d, paragraph 7. To support the NRC staffs inspection and assessment, the actions listed in Enclosure 2 have been categorized into seven inspection focus areas based on the results of the NRCs IP 95003 supplemental inspection.

Accordingly, based on our review of your July 28 letter, and the telephone discussion between Daniel Dorman, Regional Administrator, NRC Region I, and Brian Sullivan, Pilgrim Site Vice President on August 2, 2017, it is our understanding that Entergy commits to take the actions identified in Enclosure 2 by the dates specified. The expected completion dates listed in indicate the dates that the items listed under each focus area should be ready for inspection.

Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232(a), you are required to:

1. Notify me immediately, in writing, if your understanding differs from that set forth above;
2. Notify me, in writing, if for any reason you cannot complete the corrective actions identified in Enclosure 2 within the specified schedule and advise me, in writing, of your modified schedule in advance of the change;
3. Notify me, in writing, if for any reason you intend to change, deviate from or not complete any of the documented actions listed in Enclosure 2, and advise me, in writing, of the changes or deviations; and
4. Notify me, in writing, when you have completed all of the actions addressed in this CAL.

These written notifications must be provided to the Regional Administrator, Region I, at 2100 Renaissance Blvd., King of Prussia, PA 19406-2713. The NRC plans to conduct follow-up inspections to review the implementation of the corrective actions listed in Enclosure 2 and

B. Sullivan 3 associated effectiveness reviews to verify the actions have been completed and are adequate to support sustainable performance improvement. Inspectors may also review additional corrective actions listed in the PNPS Recovery Plan on a sampling basis.

To facilitate the NRC follow-up inspections, we request that you inform us in a timely manner of changes to any of the individual corrective actions listed under each of the seven inspection focus areas, when each individual corrective action has been completed and is ready for inspection, and when the Area Action Plans listed in Enclosure 2 are complete and confirmed to be effective. Following these notifications, the NRC will independently verify via inspection the completion of the Enclosure 2 actions and effectiveness reviews. The results of these inspections will provide information for future performance assessments of Pilgrim, and will serve as the basis for the NRC to determine if the CAL can be closed and whether Pilgrim should transition out of Column 4 of the ROP Action Matrix or if the NRC should take additional regulatory action, in accordance with IMC 0305.

Issuance of this CAL does not modify or amend Pilgrims license and does not preclude issuance of an Order making the above commitments legally binding requirements or requiring other actions on the part of Pilgrim. In addition, the NRC is not precluded from taking enforcement action for violations of NRC requirements that may have prompted the issuance of the CAL. Failure to meet the commitments in this CAL may result in an Order if Pilgrims performance, as demonstrated by the failure to meet CAL commitments, does not provide reasonable assurance that the NRC can rely on Pilgrim to meet the NRCs requirements and protect public health and safety or the common defense and security.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice and Procedure," a copy of this letter and your response will be made available electronically for public inspection in the NRC Public Document Room or in the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, security-related, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information).

B. Sullivan 4 If you have any questions concerning this matter, please contact Arthur Burritt of my staff.

Mr. Burritt can be reached at (610) 337-5069.

Sincerely,

/RA/

Daniel H. Dorman Regional Administrator Docket No. 50-293 License No. DPR-35

Enclosures:

1. Pilgrim Nuclear Power Station Recovery Plan
2. List of Inspection Focus Areas to Assess Sustained Performance Improvement at Pilgrim

ML17214A088 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DRP RI/DRS RI/DRP RI/DRS RI/ORA NAME ABurritt DJackson via email RLorson JYerokun BKlukan DATE 7/24/17 7/24/17 7/25/17 7/25/17 7/27/17 OFFICE RI/ORA HQ/NRR RI/ORA NAME BBickett BHolian via email DDorman DATE 7/28/17 8/1/17 8/2/17 ML17212A571 Enclosure 1

List of Inspection Focus Areas to Assess Sustained Performance Improvement at Pilgrim1

1) Nuclear Safety Culture. To address issues associated with the nuclear safety culture fundamental problem, Pilgrim will implement the following actions by May 31, 2018:

Area Action Plan Corrective Action No.

Nuclear Safety Culture NSC-1.12, -1.2, -1.3, -1.4, -1.52, -1.6, -1.7, -1.8, -

1.10, -2.2, -2.3, -3.1, -3.2, -3.3, -3.4, -3.5, -3.6, -3.7,

-3.8, -4.1, -4.2, -5.1, -5.2, -5.3, -5.4, -6.1, -7.1, -8.1,

-8.6, -8.8, -8.9, -8.10, -8.21, -8.22, -8.25, -8.26,

-8.27, -8.28, -8.29

2) Corrective Action Program. To address issues associated with the corrective action program fundamental problem, Pilgrim will implement the following by March 30, 2018:

Area Action Plan Corrective Action No.

Corrective Action Program CAP-1.1, -1.2, -1.3, -1.4, -1.5, -1.7, -1.8, -1.9, -1.10,

-1.11, -2.1, -2.2, -2.3, -3.1, -3.2, -4.2, -4.3

3) Human Performance. To address issues associated with the human performance key attribute of the reactor safety strategic performance area, Pilgrim will implement the following actions by February 28, 2018:

Area Action Plan Corrective Action No.

Procedure Use and Adherence PUA-1.1, -1.23, -1.33, -1.4, -1.6, -2.2, -2.3, -2.4, -2.5, -3.1,

-3.2, -3.3, -3.4, -4.1, -4.2, -4.3, -5.1, -5.2, -5.7, -5.8, -5.9 Operability Determinations and ODFA-1.1, -1.2, -1.3, -1.4, -1.5, -1.6, - 2.2, -3.1, -5.1, -5.2, Functionality Assessments -5.3, -5.4, -5.5, -5.6, -5.7, -5.8

4) Operational Standards and Leadership. To address issues associated with Operations Department standards and leadership, Pilgrim will implement the following actions by May 31, 2018:

Area Action Plan Corrective Action No.

Operations Department OPS-1.1, -1.2, -1.4, -1.6, -1.7, -2.2, -3.1, -3.2, -4.1, Standards and Leadership -4.2 Risk Recognition and Decision RRDM-1.1, -1.2, -1.3, -2.1, -3.1, -3.2, -3.3, -4.3, -4.8, Making -4.9 1

The Area Action Plans and Corrective Action Nos. provided in this enclosure are defined in Enclosure 1, Pilgrim Nuclear Power Station Recovery Plan.

2 NSC-1.1 and NSC-1.5 as described in the Recovery Plan are the same action directed at different levels of the organization 3

PUA-1.2 and PUA-1.3 as described in the Recovery Plan are the same action repeated for reinforcement Enclosure 2

2

5) Procedure Quality. To address issues associated with the procedure quality key attribute of the reactor safety strategic performance area, Pilgrim will implement the following actions by November 30, 2017:

Area Action Plan Corrective Action No.

Procedure Quality PQ-1.1, -2.1, -2.2, -3.1, -3.2, -3.3, -5.1, -5.2

6) Safety Relief Valve (SRV) White Finding. To fully address root and contributing causes in response to the White finding associated with the failure to identify, evaluate, and correct a significant condition adverse to quality associated with the A SRV failure to open (ML15147A412), including corrective actions to preclude repetition, Pilgrim will implement the following actions by March 30, 2018:

Area Action Plan Corrective Action No.

SRV White Finding SRV-1.1, -1.2, -1.3, -2.1, -3.1, -3.2, -3.3, -3.4, -4.1,

-5.1, -5.2

7) Engineering Programs and Equipment Performance. To address issues associated with the engineering programs, equipment performance, and work management problem areas, Pilgrim will implement the following actions by June 28, 2018:

Area Action Plan Corrective Action No.

Engineering Programs EP-1.1, -1.2, -2.1, -2.2, -2.3, -2.4, -3.1, -4.1 Equipment Reliability ER-1.1, -1.2, -1.3, -2.1, -2.2, -3.1, -3.2, -3.3 Work Management WM-1.1, -1.2, -1.3, -2.1, -2.2, -3.1, -3.3, -4.2