ML18158A133
| ML18158A133 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/06/2018 |
| From: | Marc Ferdas Division Reactor Projects I |
| To: | David Pelton Division Reactor Projects I |
| Shared Package | |
| ML18158A104 | List: |
| References | |
| Download: ML18158A133 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406-2713 June 6, 2018 MEMORANDUM TO: David L. Pelton, Director Division of Reactor Projects FROM: Marc S. Ferdas, Chief /RA/
Technical Support & Assessment Branch
SUBJECT:
EXTENT-OF-CONDITION REVIEW IN RESPONSE TO FINDINGS ASSOCIATED WITH INSPECTION PROCEDURE 95003: EVALUATION OF NRC ASSESSMENT AND INSPECTION PROCESSES AT PILGRIM NUCLEAR POWER STATION In accordance with Inspection Procedure (IP) 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input, Region I conducted an evaluation to determine whether the NRCs assessment and inspection processes applied at Pilgrim Nuclear Power Station (Pilgrim), appropriately characterized licensee performance, based on previous inspection information and whether sufficient warning was provided to identify a significant reduction in safety. The review concluded the NRC responded appropriately to the decline in Pilgrims performance and the Reactor Oversight Process (ROP) and inspection processes were appropriate to provide sufficient warning of degraded and declining performance. However, the review also identified that Licensee Event Reports (LERs) in the 2011 - 2013 timeframe were not consistently evaluated and documented as findings or violations consistent with ROP and enforcement guidance. In response to this observation, an extent-of-condition review was conducted to determine if a similar issue existed across other Region I sites. The extent-of-condition review was conducted by a Region I team consisting of a senior resident inspector, senior risk analyst, and a branch chief.
Based on an independent review of over 90 LERs, the team determined that overall LERs were properly evaluated and documented in accordance with the applicable inspection and enforcement guidance available to inspectors at the time of their closeout. There were a few isolated examples spread across different sites in which this review came to a different conclusion than what was originally documented. Due to the regulatory judgement that can be applied when reviewing an issue, some variance in the final assessment is expected between different inspectors. None of the identified examples would have caused the agency to change its assessment or oversight activities for that site. The results of this review was shared with the responsible branches. Any additional and clarifying information received from the branches was factored into the teams final assessment. The enclosed report details the results of our review.
Enclosure:
As Stated CONTACT: Marc S. Ferdas, RI/DRP (610) 337-5022
ML18158A133 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DRP RI/DRP NAME MGray/mg MFerdas/mf DATE 5/31/18 6/6/18 Enclosure 1 Extent-of-Condition Review - Closeout of License Event Reports 2009 to 2017
Background
In accordance with Section 03.11 of Inspection Procedure 95003, Region I conducted a review of NRCs oversight of Pilgrim Nuclear Power Station (Pilgrim) for the period leading to the plants placement in Column 4 of NRCs Action Matrix. The review concluded the NRC responded appropriately to the decline in Pilgrims performance and the ROP and inspection processes were appropriate to provide sufficient warning of degraded and declining performance. However, the review also identified that Licensee Event Reports (LERs) in the 2011 - 2013 timeframe were not consistently evaluated and documented as findings or violations consistent with ROP and enforcement guidance.
Scope/Activities Conducted In response to the teams findings, an extent-of-condition review was conducted to determine if a similar issue existed across other Region I sites. The extent-of-condition review was conducted by a Region I team consisting of a senior resident inspector, senior risk analyst, and a branch chief. The team reviewed 641 LERs closed in calendar years 2009 - 2015.
Additionally, a review of 282 LERs closed in calendar years 2016 and 2017 was completed to further assess current performance. A list of the LERs reviewed are contained in .
Each LER and the inspection report in which it was closed out was reviewed. Based on the information contained in these documents, the team assessed the determination made concerning the existence of a performance deficiency and whether that conclusion was reasonably supported by the information. Additionally, a brief assessment of the assigned risk significance was performed to determine if it seemed appropriate.
Results/Assessment The extent-of-condition review verified that a systemic issue did not exist within Region I associated with the review and closeout of LERs. Overall, LERs have been properly evaluated and documented in accordance with the applicable inspection and enforcement guidance available to inspectors at the time of their closeout. The review did identify a few isolated examples (3) spread across several different sites where a performance deficiency was not identified even though information within the LER likely justified that a finding or violation of very low safety significance (Green) should have been documented. Additionally, the team identified a couple of instances (2) where a performance deficiency was not identified even though information within the LER likely justified that a minor finding or violation likely existed and should have been documented as part of the LER closeout. The table below provides a complete summary of the extent-of-condition review.
1 694 LERs closed (20092015). Does not include Pilgrim.
2 188 LERs closed (2016 - 2017).
E-2 As Documented in NRC Inspection Report Extent-of-Condition Review 2009-2015 2016-2017 LIV-Green No PD 2* 0 LIV-Green SR-Minor 1 0 No PD SR-Green 3 0 No PD SR-Minor 0 1 No PD LIV-Minor 1 0 Number of LERs Reviewed3 64 28 Key LIV = Licensee Identified Violation PD = Performance Deficiency SR=Self Revealing Finding/Violation Note
- Involved specific issue associated with safety relief valve (SRV) set-point drift, which is currently under review by the program office to ensure greater consistency across the regional offices in how these type of issues are assessed and the associated LER is closed. Thus the difference between as documented and the teams assessment was expected.
Due to the regulatory judgement that can be applied when reviewing an issue, some variance in the final assessment was expected between different inspectors. None of the identified examples would have caused the agency to change its assessment or oversight activities for that site.
Conclusion/Summary Based on an independent review of over 90 LERs, the team determined that overall LERs were properly evaluated and documented in accordance with the applicable inspection and enforcement guidance available to inspectors at the time of their closeout.
3 Survey Monkey Sample Size Calculator (https://www.surveymonkey.com/mp/samplesizecalculator/) used to determine number of LERs to review. [Population = Number of LERs Closed/Confidence Level = 90%/Margin of Error = 1015%].
Attachment 1 Site LER Number LER Title LER Closeout 2009-2015 BV 05000334/2009-004-00 Two Ultrasonic Indications Found In Reactor Coolant System Drain Pipe BV 05000334/2014-002-00 Beaver Valley Unit 1 Turbine Driven Auxiliary Feedwater Pump Governor Oscillations Result In Pump Trip BV 05000334,05000412/2014-004- Unanalyzed Condition Resulting From Unfused Direct 00 Current Control Circuits BV 05000412/2011-003-00 Automatic Actuation of Standby Service Water Pumps Following Unexpected Service Water Pump Trip CC 05000317/2010-001-00 Reactor Trip Due to Water Intrusion into Switchgear Protective Circuitry CC 05000317,05000318/2012-001- Valve Surveillance Requirement Not Met Due to Legacy 00 Issues CC 05000318/2013-001-00 Reactor Coolant System Pressure Boundary Leakage in Valve Leakoff Line Weld CC 05000317,05000318/2014-004- Unfused 250 VDC Circuits Result in 10 CFR 50 01 Appendix R Unanalyzed Condition Due to Original Design did not Adequately Address Fire Protection Requirements CC 05000317/05000318/2011-002- Technical Specification 3.0.3 Entry for Inoperable 125V 02 Direct Current Channels FP 05000333/2012-002-01 High Pressure Coolant Injection Pressure Control Valve Failure.
FP 05000333/2014-002-01 Secondary Containment Vacuum Below Technical Specification Limit FZ 05000333/2011-001-00 RCIC Inoperable Longer than Allowed by TS GN 05000244/2009-002-00 Plant Trip Due to Loss of Electrohydraulic Control System Pressure GN 05000244/2011-001-00 Unanalyzed Condition due to Postulated Fire Causing a Station Blackout GN 05000244/2012-001-00 Automatic Start of 'B' Emergency Diesel Generator Caused by Loss of Offsite Circuit 767 Due to Wildlife GN 05000244/2014-002-00 Unanalyzed Condition Due to Postulated Hot Short Fire Event Involving DC Control Circuits Affecting Multiple Fire Areas GN 05000244/2011-002-00 Train 'B' Actuation Logic Circuit to Operate the 'B' Main Steam Isolation Valve was not Operable HC 05000354/2009-004-00 Multiple Control Rod Drifts Resulting In A Reactor Scram HC 05000354/2009-006-00 Post-Fire Safe Shutdown Analysis Error HC 05000354/2010-003-00 RHR Shutdown Cooling Suction Relief Valve Missed Surveillance HC 05000354/2013-007-00 As-Found Values for Safety Relief Valve Lift Set Points Exceed Technical Specification Allowable Limit HC 05000354/2013-010-01 Loss of Both Control Room Chillers.
A-2 Site LER Number LER Title HC 05000354/2015-004-00 As-Found Values for Safety Relief Valve Lift Set Points Exceed Technical Specifications Allowable Limit HC 05000354/2015-005-00 Reactor Scram Due to Invalid RRCS Actuation HC 05000354/2012-001-00 APRM Flow Unit Summers Out of Tech Spec Tolerance IP 05000247/2009-005-00 Automatic Reactor Trip Due to a Turbine-Generator Exciter Protective Trip Caused by a Loss of the Generrex Power Supply Monitored Voltage Due to a High Resistance Ground Connection IP 05000286/2011-003-00 Technical Specification Required Shutdown and a Safety System Functional Failure for a Leaking Service Water Pipe Causing Flooding in the SW Valve Pit Preventing Access for Accident Mitigation IP 05000286/2011-006-00 Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for an Inoperable Isolation Valve Seal Water System Due to an Out of Position Valve IP 05000286/2013-002-00 Safety System Functional Failure and Common Cause Inoperability of the Emergency Core Cooling System Due to Violation of Containment Sump Debris Barrier Integrity IP 05000286/2012-001-00 Common Cause Inoperability of Both Trains of MDAFW Pumps due to Inability to Control AFW Regulating Valves After Isolation of Nitrogen Backup LM 05000352,05000353/2012-007- Condition Prohibited by Technical Specifications due to 00 Primary Containment Isolation Valves Design LM 05000352/2012-003-01-00 Valid Manual Actuation of the Primary Containment Isolation System Due to Ventilation System Trip LM 05000353/2013-001-00 Valid Manual Actuation of the Reactor Protection System During Refuel Outage Testing LM 05000352/2014-004-00 Valid Manual Actuation of the Reactor Protection System With the Reactor Critical Due to Closure of Turbine Valves LM 05000353/2015-001-00 Condition That Could Have Prevented Fulfillment of the High Pressure Coolant Injection (HPCI) System Safety Function LM 05000352/2013-001-00 HPCI System Pressure Switch Lubricating Oil Leak MS 05000336/2009-005-00 Both Containment Air Lock Doors Open in Mode 1 MS 05000423/2013-007-00 Reactor Trip on Low-Low Steam Generator Level MS 05000423/2014-001-00 Limiting Condition for Operations Exceeded upon Approval of Enforcement Discretion MS 05000336/2014-005-00 Train A Containment Spray Inoperable Due To Gas Voids MS 05000423/2014-004-00 Unlatched Dual Train HELB Door Results in Potential Loss of Safety Function MS 05000336/2014-004-00 FM Found in a Motor Lead Rendered a MDAFW Pump Inoperable NMP 05000410/2011003-00 Reactor Shutdown due to an Unisolable Leak on a FW Pump Minimum Flow Line OC 05000219/2012-002-01 Loss of Offsite Power During Hurricane Sandy
A-3 Site LER Number LER Title OC 05000219/2014-006-00 Reactor SCRAM due to Decreasing Reactor Water Level OC 05000219/2013-001-00 Automatic Reactor SCRAM due to an Invalid Intermediate Range Monitor SCRAM Signal PB 05000277/2-10-04 -00 Improper Credit for Function of Off-site Power Source Transformer Load Tap Changer PB 05000278/3-13-001-00 Laboratory Analysis Identifies Safety Relief Valves and Safety Valve Set Point Deficiencies PB 05000277/2014-003-00 Containment Leakage Limit Exceeded Due to Through-Seat Leakage of Feedwater Check Valves PB 05000278/2013-001 SRV Set Point Deficiencies SB 05000443/2011-001-00 Noncompliance with Technical Specification for Leakage Detection Instruments SB 05000443/2012-004-00 Manual Actuation of the Service Water Cooling Tower SB 05000443/2009001-00 RPS Actuation on SG Low Water Level SL 05000272/2010-002-00 Automatic Reactor Trip Due to Main Power Transformer Bushing Failure SL 05000272/2011-005-00 Incorrect NIS Trip Setpoints Results in TS 3.0.3 Entry SL 05000272/2014-002-00 Manual Reactor Trip Due to Loss of the 11 Steam Generator Feedwater Pump SL 05000272/2015-007-00 Inoperable Control Room Emergency Air Conditioning System Due to Failed Charcoal Filter Surveillance Test.
SL 05000272/2011-002-00 Bypass of Steam Generator Blowdown Valve Isolation during Testing SQ 05000388/2011-002-00 Condition Prohibited by Technical Specification Due to Unknown RCIC Inoperability SQ 05000387/2013-003-00 Unauthorized Access Due to Not Completing Required Training SQ 05000387/2009001-00 HPCI System Inoperable due to Turbine Stop Valve Failure TMI 05000289/2011-001-00 Unanalyzed Condition Affecting Probable Maximum Flood (PMF) Level TMI 05000289/2012-002-01 Missing Seals in Air Intake Tunnel Conduits TMI 05000289/2008-001-00 Decay Heat River Water System Pump Failed to Start LER Closeout 2016 - 2017 05000334,05000412/2017001- Inadequate Tornado Missile Protection Identified Due to BV 00 Non-Conforming Design Conditions 05000318/2015-001-00 Manual Reactor Trip Due to Steam Generator Feed CC Pump 22 Trip 05000333/2015-007-00 Slow Exhaust Fan Start Leads to Secondary Containment Vacuum Below Technical Specification FP Limit 05000333/2016-002-00 Sticking DC Pilot in Solenoid Valve Cluster Assembly FP Results in Slow MSIV Closures 05000244/2016-001-00 Loss of Station Transformer 12A Resulting in Automatic Start of Emergency Diesel Generator 'A' due to GN Undervoltage Signals to Safeguard Buses 14 and 18 HC 05000354/2016-002-00 High Pressure Coolant Injection System Inoperable
A-4 Site LER Number LER Title 05000247/2015-003-00 Manual Reactor Trip Due to Indications of Multiple Dropped Control Rods Caused by Loss of Control Rod IP Power Due to a Power Supply Failure 05000247/2017-002-00 Auxiliary Feedwater Flow Indication Inoperable for Longer Than the Allowed Technical Specification Completion Time Due to Failure to Complete IP Restoration Following Calibration 05000353/2015-007-00 Condition Prohibited by Technical Specifications Due to an Inoperable Reactor Coolant Leakage Detection LM System MS 05000336/2015-003-00 Valid Actuation of the Reactor Protection System NMP 05000220/2017-002-00 Manual Reactor Scram Due to Pressure Oscillations 05000219/2016-002-01 Control Rod Drive Cooling Water System Isolation OC Scram Time Testing Was Not Performed 05000219/2016001-00 Failure of the No. 1 Emergency Diesel Generator during Surveillance Testing due to a Cooling Water System OC Leak 05000277/2016-001-00 Leak in High Pressure Service Water Pipe Results in PB Condition Prohibited by Technical Specifications 05000293/2017-003-00 Pressure Suppression Pool Declared Inoperable Due to PG High Water Level 05000293/2017-004-00 Secondary Containment Testing Led to Loss of Safety Function to Both Trains of Standby Gas Treatment PG System 05000293/2017-010-00 Air Accumulation Creates Small Void in Core Spray PG Discharge Piping 05000443/2017-001-00 Manual Reactor Trip in Response to a Feedwater SB Isolation due to High Level in Steam Generator 'B' 05000311/2015-003-00 Both Trains of High Head Safety Injection Inoperable SL Due to a Relief Valve Failure SL 05000311/2016-002-01 Automatic Reactor Trip due to Main Turbine Trip 05000272/2015-002-02 Condition Prohibited by Technical Specification for One SL Channel of Steam Generator Level Indication Inoperable 05000387/2015-007-00 Unit 1 'B' Inboard Main Steam Isolation Valve, HV141F022B closed during surveillance test which SQ caused a SCRAM on Unit 1 05000387,05000388/2016-008- Inoperability of Diesel Generator Due to Misalignment of 00 MOC Switch Contacts Due to Inadequate Post SQ Maintenance Testing SQ 05000387/2016-018-00 Inoperability of RCIC Due to an Oil Leak 05000388/2016-005-00 Unit 2 HPCI Manually Overridden Prior to a Manual SQ Scram During a Plant Transient 05000387/2016-019-00 Pressure Boundary Leakage from an Inadequate Weld SQ Repair in Small Bore Pump Seal Vent Piping 05000387/2016-011-01 Valve Inoperability for a period of longer than allowed by SQ Technical Specifications
A-5 Site LER Number LER Title 05000289/2017-001-00 Low Temperature Over-Pressurization (LTOP)
TMI Technical Specification Requirements Were Not Met 05000334,05000412/2017001- Inadequate Tornado Missile Protection Identified Due to BV 00 Non-Conforming Design Conditions 05000318/2015-001-00 Manual Reactor Trip Due to Steam Generator Feed CC Pump 22 Trip 05000333/2015-007-00 Slow Exhaust Fan Start Leads to Secondary Containment Vacuum Below Technical Specification FP Limit 05000333/2016-002-00 Sticking DC Pilot in Solenoid Valve Cluster Assembly FP Results in Slow MSIV Closures 05000244/2016-001-00 Loss of Station Transformer 12A Resulting in Automatic Start of Emergency Diesel Generator 'A' due to GN Undervoltage Signals to Safeguard Buses 14 and 18 HC 05000354/2016-002-00 High Pressure Coolant Injection System Inoperable 05000247/2015-003-00 Manual Reactor Trip Due to Indications of Multiple Dropped Control Rods Caused by Loss of Control Rod IP Power Due to a Power Supply Failure 05000247/2017-002-00 Auxiliary Feedwater Flow Indication Inoperable for Longer Than the Allowed Technical Specification Completion Time Due to Failure to Complete IP Restoration Following Calibration 05000353/2015-007-00 Condition Prohibited by Technical Specifications Due to an Inoperable Reactor Coolant Leakage Detection LM System MS 05000336/2015-003-00 Valid Actuation of the Reactor Protection System NMP 05000220/2017-002-00 Manual Reactor Scram Due to Pressure Oscillations 05000219/2016-002-01 Control Rod Drive Cooling Water System Isolation OC Scram Time Testing Was Not Performed 05000219/2016001-00 Failure of the No. 1 Emergency Diesel Generator during Surveillance Testing due to a Cooling Water System OC Leak 05000277/2016-001-00 Leak in High Pressure Service Water Pipe Results in PB Condition Prohibited by Technical Specifications 05000293/2017-003-00 Pressure Suppression Pool Declared Inoperable Due to PG High Water Level 05000293/2017-004-00 Secondary Containment Testing Led to Loss of Safety Function to Both Trains of Standby Gas Treatment PG System 05000293/2017-010-00 Air Accumulation Creates Small Void in Core Spray PG Discharge Piping 05000443/2017-001-00 Manual Reactor Trip in Response to a Feedwater SB Isolation due to High Level in Steam Generator 'B' 05000311/2015-003-00 Both Trains of High Head Safety Injection Inoperable SL Due to a Relief Valve Failure SL 05000311/2016-002-01 Automatic Reactor Trip due to Main Turbine Trip
A-6 Site LER Number LER Title 05000272/2015-002-02 Condition Prohibited by Technical Specification for One SL Channel of Steam Generator Level Indication Inoperable 05000387/2015-007-00 Unit 1 'B' Inboard Main Steam Isolation Valve, HV141F022B closed during surveillance test which SQ caused a SCRAM on Unit 1 05000387,05000388/2016-008- Inoperability of Diesel Generator Due to Misalignment of 00 MOC Switch Contacts Due to Inadequate Post SQ Maintenance Testing SQ 05000387/2016-018-00 Inoperability of RCIC Due to an Oil Leak 05000388/2016-005-00 Unit 2 HPCI Manually Overridden Prior to a Manual SQ Scram During a Plant Transient