IR 05000293/2016013

Temporary Instruction 2515/191 Inspection Report 05000293/2016013

ML16189A066
Person / Time
Site:	Pilgrim
Issue date:	07/07/2016
From:	Marc Ferdas Division Reactor Projects I
To:	Dent J Entergy Nuclear Operations
Ferdas M
References
IR 2016013
Download: ML16189A066 (13)

Text

UNITED STATES uly 7, 2016

SUBJECT:

PILGRIM NUCLEAR POWER STATION - TEMPORARY INSTRUCTION 2515/191 INSPECTION REPORT 05000293/2016013

Dear Mr. Dent:

On May 26, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Pilgrim Nuclear Power Station (PNPS). The enclosed report documents the inspection results, which were discussed on May 26, 2016, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with plant 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 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC 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 Web site at http://www.nrc.gov/readingrm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Marc S. Ferdas, Chief Technical Support and Assessment Branch Division of Reactor Projects Docket No. 50-293 License No. DPR-35

Enclosure:

Inspection Report 05000293/2016013 w/Attachment: Supplementary Information

REGION I==

Docket No. 50-293 License No. DPR-35 Report No. 05000293/2016013 Licensee: Entergy Nuclear Operations, Inc. (Entergy)

Facility: Pilgrim Nuclear Power Station Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: May 23 - May 26, 2016 Inspectors: W. Cook, Senior Reactor Analyst, Division of Reactor Safety (DRS)

E. Carfang, Senior Resident Inspector, Pilgrim T. Dunn, Operations Engineer, DRS B. Pinson, Resident Inspector, Pilgrim C. Cahill, Senior Reactor Analyst, DRS (Observer)

M. Brown, Chief, Orders Management Branch, Japan Lessons-Learned Division, Office of Nuclear Reactor Regulations, (Observer)

D. Jackson, Chief, Operations Branch, DRS (Observer)

Approved by: Marc S. Ferdas, Chief Technical Support and Assessment Branch Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000293/2016013; 05/23/2016 - 05/26/2016; Pilgrim Nuclear Power Station (PNPS); Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans.

The inspection covered a one week inspection by a senior reactor analyst, an operations engineer, a senior resident inspector, and a resident inspector. No findings were identified. The U.S. Nuclear Regulatory Commissions (NRCs) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 5.

REPORT DETAILS

4OA5 Other Activities

TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans The objective of TI 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify:

(1) that licensees have adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15202A415) and the NRCs plant safety evaluation (ADAMS Accession No. ML16008B077);

(2) that licensees have installed reliable water-level measurement instrumentation in their spent fuel pools (SFPs); and

(3) that licensees have implemented emergency preparedness enhancements as described in their site-specific submittals and NRC safety assessments, including dose assessment capability, enhancements to ensure that staffing is sufficient, and that communications can be maintained during beyond-design-basis external events.

The team verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events, (ADAMS Accession No. ML12054A735) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12056A044) were in place and were being implemented by Entergy. The team also verified that Entergy had implemented staffing and communication plans provided in response to the March 12, 2012, request for information letter and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).

The team discussed the plans and strategies with Entergy personnel, reviewed documentation, completed a tabletop exercise involving a beyond-design-basis event leading to an extended loss of offsite power and, where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in Entergys submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the teams inspection activities are described in the following sections. Documents reviewed for each section of this report are listed in the Attachment.

1. Mitigation Strategies for Beyond-Design-Basis External Events

a. Inspection Scope

The team examined Entergys established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the Entergy staff coordinated and documented the interface/transition between existing off-normal and emergency operating procedures at PNPS with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

The team verified that a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment, and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and PNPS staff most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.

b. Assessment Based on samples selected for review, the team verified that Entergy satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation. The team determined that Entergy was in compliance with NRC Order EA-12-049.

The team verified that Entergy satisfactorily:

• Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events;

• Integrated their FSGs into their existing emergency operating procedures and off-normal procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;

• Protected FLEX equipment from site-specific hazards;

• Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;

• Trained their staff to ensure personnel proficiency in the mitigation of beyond-design-basis events; and

• Developed procedures to ensure that the necessary off-site FLEX equipment would be available from off-site locations.

The team verified that observations made during the inspection were entered into Entergy's corrective action program.

c. Findings

No findings were identified.

2. Spent Fuel Pool Instrumentation

a. Inspection Scope

The team examined PNPSs newly installed SFP instrumentation. Specifically, the team verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation, and that the cabling for the power supplies and the indications for each channel were physically and electrically separated. In addition, the team verified that Entergy had evaluated the environmental conditions and accessibility of the instrumentation.

The team verified that Entergy had approved procedures for maintenance, testing, calibration, and use of the primary and backup SFP instrumentation channels. The team also verified that the procedures followed the industry guidance contained in Nuclear Energy Institute 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, and that these procedures were part of an existing Entergy process to be maintained.

b. Assessment Based on samples selected for review, the team determined that Entergy satisfactorily installed and established appropriate operating and maintenance controls for the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation. The team determined that Entergy was in compliance with NRC Order EA-12-051.

The team verified that Entergy satisfactorily:

• Installed the SFP instrumentation sensors, cabling, and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation;

• Installed the SFP instrumentation display in the accessible location, and environmental conditions as described in the plant specific submittals;

• Trained their staff to ensure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and

• Developed and issued procedures for maintenance, testing, and use of the reliable SFP instrumentation.

The team verified that observations made during the inspection were entered into Entergy's corrective action program.

c. Findings

No findings were identified.

3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation, and plant walk downs, the team verified that Entergy had implemented required changes to staffing, communications equipment, and facilities to support an extended loss of all AC power (ELAP) scenario as described in Entergys staffing assessment and the NRC safety evaluation. The team also verified that Entergy had implemented dose assessment (including releases from SFPs) capability using site-specific dose assessment software, as described in Entergys dose assessment submittal.

b. Assessment The team reviewed information provided in Entergys dose assessment submittal and in response to the NRCs March 12, 2012, request for information letter (ADAMS Accession No. ML12053A340), and verified that Entergy satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3, response to a large scale natural emergency event that results in an ELAP and impedes access to the site.

The team verified the following:

• Entergy satisfactorily implemented required staffing changes to support an ELAP scenario;

• Emergency preparedness communications equipment and facilities were sufficient for dealing with an ELAP scenario; and

• Entergy implemented dose assessment capabilities (including releases from SFPs)using PNPSs site-specific dose assessment software and approach.

The team verified that observations identified during the inspection were entered into Entergy's corrective action program.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On May 26, 2016, the team presented the inspection results to Mr. John Dent, Site Vice President, and other members of the PNPS staff. The team verified that no proprietary information was retained by team members or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

P. Benbort, Security Manager

J. Bonner, Fukushima Project Engineer

R. Byrne, Regulatory Assurance

D. Calabrese, Emergency Preparedness Manager

B. Chenard, Engineering

F. Clifford, Operations Assistant Manager

J. Dent, Site Vice President

J. Edelhauser, Fukushima Project

G. Flynn, Operations Manager

R. German, Nuclear Plant Operator

W. Hendy, Training Instructor

M. Jacobs, NIOS Manager

K. Jenks, Fukushima Project Manager

J. Macdonald, General Manager Plant Operations

D. Noyes, Recovery Director

J. Parmenter, Emergency Preparedness Senior Planner

E. Perkins, Regulatory Assurance Manager

B. Rancourt, Design Engineering

M. Romeo, RAPID

E. Skorupski, Maintenance Manager

W. Townes, FLEX Marshal, Palisades Operations Department

G. Vonderesch, Recovery Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

None

Discussed

None