IR 05000293/2013003: Difference between revisions
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| issue date = 08/08/2013 | | issue date = 08/08/2013 | ||
| title = IR 05000293-13-003; 04/01/2013 - 06/30/2013; Pilgrim Nuclear Power Station; Refueling and Other Outage Activities | | title = IR 05000293-13-003; 04/01/2013 - 06/30/2013; Pilgrim Nuclear Power Station; Refueling and Other Outage Activities | ||
| author name = Bower F | | author name = Bower F | ||
| author affiliation = NRC/RGN-I/DRP/PB5 | | author affiliation = NRC/RGN-I/DRP/PB5 | ||
| addressee name = Dent J | | addressee name = Dent J | ||
Line 9: | Line 9: | ||
| docket = 05000293 | | docket = 05000293 | ||
| license number = DPR-035 | | license number = DPR-035 | ||
| contact person = Bower F | | contact person = Bower F | ||
| document report number = IR-13-003 | | document report number = IR-13-003 | ||
| document type = Inspection Report, Letter | | document type = Inspection Report, Letter | ||
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=Text= | =Text= | ||
{{#Wiki_filter:UNITED STATES | {{#Wiki_filter:UNITED STATES ugust 8, 2013 | ||
==SUBJECT:== | |||
PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2013003 | |||
SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2013003 | |||
==Dear Mr. Dent:== | ==Dear Mr. Dent:== | ||
On June 30, 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 July 18, 2013, with Steve Verrochi, General Manager Plant Operations, and other members of your staff. | On June 30, 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 July 18, 2013, with Steve 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 | 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. | The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. | ||
This report documents one self-revealing finding of very low safety significance (Green). | This report documents one self-revealing finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance, and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the 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 the 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. In accordance with 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 NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | ||
This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance, and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the 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 the 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. In accordance with 10 CFR 2.390 of the NRCs | |||
Docket No: 50-293 License No: DPR-35 | Sincerely, | ||
/RA/ | |||
Fred L. Bower III, Acting Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No: 50-293 License No: DPR-35 | |||
===Enclosure:=== | ===Enclosure:=== | ||
Inspection Report 05000293/2013003 | Inspection Report 05000293/2013003 w/Attachment: Supplementary Information | ||
Supplementary Information | |||
REGION I== | |||
Docket No: 50-293 License No: DPR-35 Report No.: 05000293/2013003 Licensee: Entergy Nuclear Operations, Inc. | |||
Inspectors: M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP) | Facility: Pilgrim Nuclear Power Station (PNPS) | ||
B. Smith, Resident Inspector, DRP J. Krafty, Resident Inspector, Millstone Nuclear Power Station, DRP T. Moslak, Health Physicist, Division of Reactor Safety (DRS) T. Burns, Reactor Inspector, DRS J. Laughlin, Emergency Preparedness Inspector, Office of Nuclear Security and Incident Response (NSIR) | Location: Plymouth, MA 02360 Dates: April 1, 2013 through June 30, 2013 Inspectors: M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP) | ||
Approved By: Fred L. Bower III, Acting Chief Reactor Projects Branch 5 Division of Reactor Projects | B. Smith, Resident Inspector, DRP J. Krafty, Resident Inspector, Millstone Nuclear Power Station, DRP T. Moslak, Health Physicist, Division of Reactor Safety (DRS) | ||
T. Burns, Reactor Inspector, DRS J. Laughlin, Emergency Preparedness Inspector, Office of Nuclear Security and Incident Response (NSIR) | |||
Approved By: Fred L. Bower III, Acting Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure | |||
TABLE OF CONTENTS 1. REACTOR SAFETY .............................................................................................................. 4 1R01 Adverse Weather Protection ....................................................................................... 4 1R04 Equipment Alignment .................................................................................................. 5 1R05 Fire Protection ............................................................................................................. 6 1R06 Flood Protection Measures ......................................................................................... 7 1R07 Heat Sink Performance ............................................................................................... 7 1R08 In-Service Inspection .................................................................................................. 7 1R11 Licensed Operator Requalification Program ............................................................... 9 1R12 Maintenance Effectiveness ....................................................................................... 10 1R13 Maintenance Risk Assessments and Emergent Work Control ................................. 11 1R15 Operability Determinations and Functionality Assessments ..................................... 11 1R18 Plant Modifications .................................................................................................... 12 1R19 Post-Maintenance Testing ........................................................................................ 13 1R20 Refueling and Other Outage Activities ...................................................................... 13 1R22 Surveillance Testing.................................................................................................. 16 1EP4 Emergency Action Level and Emergency Plan Changes ......................................... 16 1EP6 Drill Evaluation .......................................................................................................... 17 2. RADIATION SAFETY ........................................................................................................ 17 2RS1 Radiological Hazard Assessment and Exposure Controls ........................................ 17 2RS2 Occupational ALARA Planning and Controls ............................................................ 19 2RS3 In-Plant Airborne Radioactivity Control and Mitigation .............................................. 20 2RS4 Occupational Dose Assessment ............................................................................... 21 4. OTHER ACTIVITIES ............................................................................................................ 22 4OA1 Performance Indicator Verification ............................................................................ 22 4OA2 Problem Identification and Resolution ...................................................................... 23 4OA3 Follow-Up of Events and Notices of Enforcement Discretion.................................... 24 4OA6 Meetings, Including Exit ............................................................................................ 25 ATTACHMENT: SUPPLEMENTARY INFORMATION................................................................ 25 SUPPLEMENTARY INFORMATION ........................................................................................ A-1 KEY POINTS OF CONTACT .................................................................................................... A-1 LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ..................................... A-1 LIST OF DOCUMENTS REVIEWED ........................................................................................ A-2 LIST OF ACRONYMS ............................................................................................................. A-14 Enclosure | |||
A-14 | |||
=SUMMARY= | =SUMMARY= | ||
IR 05000293/2013003; 04/01/2013 - 06/30/2013; | IR 05000293/2013003; 04/01/2013 - 06/30/2013; Pilgrim Nuclear Power Station; Refueling and | ||
Pilgrim Nuclear Power Station; Refueling and | |||
Other Outage Activities. | |||
The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, | This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. One finding of very low safety significance (Green) was identified, which was a non-cited violation (NCV). The significance of inspection findings are 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 the Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. | ||
The | 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=== | ===Cornerstone: Initiating Events=== | ||
: '''Green.''' | : '''Green.''' | ||
A self-revealing NCV of Technical Specification (TS) 5.4.1, | A self-revealing NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for operators not implementing procedures to supply safety-related alternate electrical power to shutdown cooling valves during shutdown cooling operation. Specifically, because operators did not perform all applicable steps in a procedure, a loss of shutdown cooling resulted when operators were shifting power supplies for the B train shutdown cooling suction and discharge valves on May 2, 2013. Corrective actions included restoring shutdown cooling following a prompt investigation of the event. Entergy has captured this event in their corrective action program (CAP) as CR-PNP-2013-3457. | ||
The performance deficiency is more than minor because it affects the objective of the Initiating Events cornerstone to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The unavailability of shutdown cooling for five hours challenged the safety function of decay heat removal (DHR) supplied by the residual heat removal (RHR) system. A review of IMC 0612, Appendix E, | The performance deficiency is more than minor because it affects the objective of the Initiating Events cornerstone to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The unavailability of shutdown cooling for five hours challenged the safety function of decay heat removal (DHR) supplied by the residual heat removal (RHR) system. A review of IMC 0612, | ||
Appendix E, Examples of Minor Issues, found no more than minor examples that applied. | |||
The inspectors evaluated the finding using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined that the finding required further review using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, because the issue affected the safety of the reactor during a refueling outage. The inspectors determined that this finding was of very low safety significance (Green), using IMC 0609, Appendix G, Checklist 7, BWR Refueling Operation with Reactor Coolant System (RCS) Level >23. This determination did not require a further phase 2 or phase 3 analysis in that it did not increase the likelihood of a loss of RCS inventory; did not result in the loss of RCS level instrumentation; did not degrade Entergys ability to terminate a leak path or add RCS inventory; and did not degrade Entergys ability to recover DHR once it was lost. In addition, a loss of thermal margin did not occur since the change in RCS temperature resulted in less than 20 percent of the temperature margin to boil. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance area, Work Practices component, because personnel did not follow procedures [H.4(b)]. (Section 1R20) | |||
=REPORT DETAILS= | =REPORT DETAILS= | ||
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==REACTOR SAFETY== | ==REACTOR SAFETY== | ||
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity | Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity | ||
{{a|1R01}} | |||
{{a|1R01}} | |||
==1R01 Adverse Weather Protection== | ==1R01 Adverse Weather Protection== | ||
{{IP sample|IP=IP 71111.01|count=2}} | {{IP sample|IP=IP 71111.01|count=2}} | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors performed a review of | The inspectors performed a review of Entergys plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Entergys procedures affecting these areas and the communication protocols between the transmission system operator and Entergy. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Entergy established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing condition reports and open work orders, and walking down portions of the offsite and AC power systems including the switchyard. Documents reviewed for each section of this inspection report are listed in the Attachment. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
===.2 Readiness for Seasonal Extreme Weather Conditions=== | ===.2 Readiness for Seasonal Extreme Weather Conditions=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors performed a review of | The inspectors performed a review of Entergys readiness for the onset of the hurricane season. The review focused on the intake structure, the emergency diesel generators (EDGs), and the station blackout diesel generator. The inspectors reviewed station procedures, including Entergys adverse weather procedures and applicable operating procedures to determine what could challenge these systems, and to ensure Entergy personnel had adequately prepared for these challenges. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during adverse weather. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R04}} | ||
{{a|1R04}} | |||
==1R04 Equipment Alignment== | ==1R04 Equipment Alignment== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors performed partial walkdowns of the following systems: | The inspectors performed partial walkdowns of the following systems: | ||
A reactor building closed cooling water (RBCCW) system during B RBCCW heat-exchanger re-sleeving on April 23 Standby liquid control system following maintenance and system realignment on May 14 High pressure coolant injection system following overhaul on May 19 Control rod drive system following the refueling outage on May 22 The inspectors selected 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), TS, work orders, condition reports, 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 the CAP for resolution with the appropriate significance characterization. | |||
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 the CAP for resolution with the appropriate significance characterization. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
===.2 Full System Walkdown=== | |||
{{IP sample|IP=IP 71111.04S|count=1}} | |||
===.2 Full System Walkdown | |||
sample | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R05}} | ||
{{a|1R05}} | |||
==1R05 Fire Protection== | ==1R05 Fire Protection== | ||
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====a. Inspection Scope==== | ====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 | 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. | ||
Fire Area 1.9, Fire Zone 1.15, standby liquid control pumps and equipment on April Fire Area 1.30, Fire Zone 1.30, drywell on May 10 Fire Area 1.20, Fire Zone 3.6, radwaste truck lock on May 20 Fire Area 1.9, Fire Zone 1.8, control rod drive pump quadrant-mezzanine level on May 22 Fire Area 1.10, Fire Zones 4.1 and 4.2, B EDG building and day tank room on June | |||
Fire Area 1.9, Fire Zone 1.15, standby liquid control pumps and equipment on April Fire Area 1.30, Fire Zone 1.30, drywell on May 10 | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1R06}} | |||
{{a|1R06}} | |||
==1R06 Flood Protection Measures== | ==1R06 Flood Protection Measures== | ||
{{IP sample|IP=IP 71111.06|count=1}} | {{IP sample|IP=IP 71111.06|count=1}} | ||
Internal Flooding Review | Internal Flooding Review | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|1R07}} | ||
{{a|1R07}} | ==1R07 Heat Sink Performance (711111.07A - 1 sample)== | ||
==1R07 Heat Sink Performance (711111.07A - 1== | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the B RBCCW heat exchanger to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified Entergys commitments to NRC Generic Letter 89-13. The inspectors reviewed the results of inspections of the RBCCW heat exchanger. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of as-found and as-left conditions. The inspectors verified that Entergy initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed. | ||
Findings | Findings No findings were identified. | ||
{{a|1R08}} | {{a|1R08}} | ||
==1R08 In-Service Inspection (711111.08 - 1== | ==1R08 In-Service Inspection (711111.08 - 1 sample)== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
From April 22 through 26, the inspectors conducted an inspection and review of | From April 22 through 26, the inspectors conducted an inspection and review of Entergys implementation of in-service inspection (ISI) program activities for monitoring degradation of the reactor coolant system (RCS) boundary, risk significant piping and components, and containment systems during the Pilgrim refuel outage (RFO-19). The sample selection was based on the inspection procedure objectives and risk priority of those pressure retaining components in systems where degradation would result in a significant increase in risk. The inspectors observed in-process non-destructive examinations (NDE), reviewed documentation, and interviewed Entergy personnel to verify that the NDE activities performed as part of the fourth interval, third period, of the Pilgrim ISI program were conducted in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, 2001 Edition with Addenda thru 2003. | ||
Nondestructive Examination and Welding Activities (IMC Section 02.01) | |||
The inspectors performed direct observation of NDE activities in process and reviewed documentation of nondestructive examinations listed below. Activities included observation of ultrasonic testing (UT) in the field and review of documentation of liquid penetrant testing (PT), magnetic particle testing (MT) and visual testing (VT-1 and VT-3). | The inspectors performed direct observation of NDE activities in process and reviewed documentation of nondestructive examinations listed below. Activities included observation of ultrasonic testing (UT) in the field and review of documentation of liquid penetrant testing (PT), magnetic particle testing (MT) and visual testing (VT-1 and VT-3). | ||
ASME Code Required Examinations The inspectors observed the manual ultrasonic examination of one 20-inch diameter pipe to pipe butt weld in the RHR system. This observation was performed in the field to verify process compliance with ASME Section XI. The UT procedure used for this examination and acceptance was GEH-PDI-UT-1, Revision 8. No recordable indications were identified as a result of the examination, and 100 percent Code coverage of the inspectable area was achieved. The inspectors verified the UT procedure and the examiner were appropriately qualified in accordance with the requirements of ASME Section XI. | ASME Code Required Examinations The inspectors observed the manual ultrasonic examination of one 20-inch diameter pipe to pipe butt weld in the RHR system. This observation was performed in the field to verify process compliance with ASME Section XI. The UT procedure used for this examination and acceptance was GEH-PDI-UT-1, Revision 8. No recordable indications were identified as a result of the examination, and 100 percent Code coverage of the inspectable area was achieved. The inspectors verified the UT procedure and the examiner were appropriately qualified in accordance with the requirements of ASME Section XI. | ||
A documentation review was performed of the volumetric examination of the safe end to nozzle weld 2R-N2E-1, using Performance Demonstration Initiative (PDI) qualified manual phased array UT procedure EPRI-DMW-PA-1, Revision 4. The weld was a dissimilar metal butt weld of the recirculation system safe end to nozzle, 16-inch diameter and 1.32-inch wall thickness. The inspectors reviewed the test procedure, calibration reports, weld volume coverage, analysis of test results and noted that 100 percent Code coverage was achieved and no relevant indications were identified. The qualifications of the test examiner were verified for compliance with ASME Section XI and PDI requirements. | A documentation review was performed of the volumetric examination of the safe end to nozzle weld 2R-N2E-1, using Performance Demonstration Initiative (PDI)qualified manual phased array UT procedure EPRI-DMW-PA-1, Revision 4. The weld was a dissimilar metal butt weld of the recirculation system safe end to nozzle, 16-inch diameter and 1.32-inch wall thickness. The inspectors reviewed the test procedure, calibration reports, weld volume coverage, analysis of test results and noted that 100 percent Code coverage was achieved and no relevant indications were identified. The qualifications of the test examiner were verified for compliance with ASME Section XI and PDI requirements. | ||
The inspectors performed a documentation review of the magnetic particle examination of the weld of the bottom mounted skirt (integral attachment) to the reactor pressure vessel (RPV). The inspectors reviewed the documentation to verify the MT procedure CEP-NDE-0731, Revision 3 and the examiner were appropriately qualified to the requirements of ASME Section XI. The inspectors also reviewed the contents of the MT examination report to determine the test variables were applied in accordance with the procedure and the results were recorded and evaluated for acceptance as specified by the procedure. The inspectors noted that no recordable indications were identified. | The inspectors performed a documentation review of the magnetic particle examination of the weld of the bottom mounted skirt (integral attachment) to the reactor pressure vessel (RPV). The inspectors reviewed the documentation to verify the MT procedure CEP-NDE-0731, Revision 3 and the examiner were appropriately qualified to the requirements of ASME Section XI. The inspectors also reviewed the contents of the MT examination report to determine the test variables were applied in accordance with the procedure and the results were recorded and evaluated for acceptance as specified by the procedure. The inspectors noted that no recordable indications were identified. | ||
The reactor pressure vessel UT documentation review included the upper head meridional (closure) head weld, RPV-TH-M8, being examined from the outside surface in accordance with ASME Section XI. The inspectors reviewed the examination report produced by Entergy of the UT inspection. The examination achieved 100 percent of the Code required volume and, no recordable indications were detected | The reactor pressure vessel UT documentation review included the upper head meridional (closure) head weld, RPV-TH-M8, being examined from the outside surface in accordance with ASME Section XI. The inspectors reviewed the examination report produced by Entergy of the UT inspection. The examination achieved 100 percent of the Code required volume and, no recordable indications were detected. | ||
. | |||
Repair/Replacement with Welding Activities The inspectors performed a record review of the restoration of the degraded wall thickness of the turbine building closed cooling water B heat exchanger to verify that welding and applicable NDE activities were performed in accordance with the ASME Code requirements. The inspectors reviewed weld procedure and welder qualifications to verify those qualifications were in accordance with the requirements of the Code of construction and the repair was performed in accordance with the Entergy ASME Section XI repair program. This repair was governed by Work Order WO-00293345-A and acceptance criteria was specified as visual examination of the welding supplemented by a PT with a pressure test of the completed repair in accordance with ASME Section XI. | |||
The inspector also reviewed a sample of digital video records of prior component examinations that were used for comparison to the current inspection observations. The inspectors observed that there was no change in the characteristics, orientation and size of previous identified indications. | Industry Initiative Examination The inspectors selected a sample of RPV internals for observation and evaluation of the in-vessel visual inspection activity. The activity inspected was the remote under water examination of reactor vessel internals using procedure TP12-014 and TP12-015 for in-vessel visual inspection of internals. The inspection scope included portions of the core shroud, steam dryer, core spray piping inside the vessel, top guide bars and other structural members. The inspectors observed the examination of portions of the core spray piping, spargers, both access hole cover plate welds, and various structural components within the vessel. The inspector also reviewed a sample of digital video records of prior component examinations that were used for comparison to the current inspection observations. The inspectors observed that there was no change in the characteristics, orientation and size of previous identified indications. | ||
Containment Visual Examination The inspectors visually examined the condition of the primary containment liner surfaces on the nine and 19-foot elevations and limited portions of the 41-foot elevation. The inspector was able to access the liner surfaces at the lower elevations. Containment surfaces above and below the listed elevations were accessible for visual examination. | Containment Visual Examination The inspectors visually examined the condition of the primary containment liner surfaces on the nine and 19-foot elevations and limited portions of the 41-foot elevation. The inspector was able to access the liner surfaces at the lower elevations. Containment surfaces above and below the listed elevations were accessible for visual examination. | ||
liner was being maintained in serviceable condition with some areas having been locally re-coated to provide the base metal with protection from degradation. | The inspectors noted that the condition of the liner coating reflected evidence that the liner was being maintained in serviceable condition with some areas having been locally re-coated to provide the base metal with protection from degradation. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1R11}} | |||
==1R11 Licensed Operator Requalification Program== | |||
{{IP sample|IP=IP 71111.11Q|count=2}} | |||
===.1 Quarterly Review of Licensed Operator Requalification Testing and Training=== | ===.1 Quarterly Review of Licensed Operator Requalification Testing and Training=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors observed licensed operator simulator training on June 13, which included an electric pressure regulator malfunction, a seismic event, a loss of coolant accident, and a station blackout. 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 | The inspectors observed licensed operator simulator training on June 13, which included an electric pressure regulator malfunction, a seismic event, a loss of coolant accident, and a station blackout. 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 technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems. | ||
====b. Findings==== | ====b. Findings==== | ||
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No findings were identified. | No findings were identified. | ||
{{a|1R12}} | {{a|1R12}} | ||
==1R12 Maintenance Effectiveness== | ==1R12 Maintenance Effectiveness== | ||
{{IP sample|IP=IP 71111.12Q|count=2}} | {{IP sample|IP=IP 71111.12Q|count=2}} | ||
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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 was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries. | 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 was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries. | ||
10 tubes of the | 10 tubes of the B RBCCW system failed 50 percent of their wall loss acceptance criterion functional failure evaluation review on June 14 Secondary containment functional failure evaluation review for a damaged reactor building inner truck lock door on June 19 | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1R13}} | |||
{{a|1R13}} | |||
==1R13 Maintenance Risk Assessments and Emergent Work Control== | ==1R13 Maintenance Risk Assessments and Emergent Work Control== | ||
{{IP sample|IP=IP 71111.13|count=6}} | {{IP sample|IP=IP 71111.13|count=6}} | ||
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The inspectors reviewed station evaluation and management of plant risk for the maintenance 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. | The inspectors reviewed station evaluation and management of plant risk for the maintenance 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 | 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. | ||
Planned Orange risk due to maintenance on the A8 vital bus resulting in unavailability of the station blackout diesel generator and the shutdown transformer on April 16 | Planned Orange risk due to maintenance on the A8 vital bus resulting in unavailability of the station blackout diesel generator and the shutdown transformer on April 16 Planned and emergent risk assessments during operations with the potential to drain the reactor vessel (control rod blade moves and hydraulic control unit freeze seal) on April 26 Emergent Yellow risk due to the loss of B-17, 480 volt safety-related bus on May 23 Planned Yellow risk due to the LOOP test on May 8 Emergent Yellow risk due to containment declared out of service on May 23 Planned Yellow risk due to high pressure coolant injection system testing on June 19 | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1R15}} | |||
==1R15 Operability Determinations and Functionality Assessments== | |||
{{IP sample|IP=IP 71111.15|count=5}} | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions: | The inspectors reviewed operability determinations for the following degraded or non-conforming conditions: | ||
23 kV system cannot support operability of the shutdown transformer when the Manoment substation exceeds 22.2 megawatts on April 1 | 23 kV system cannot support operability of the shutdown transformer when the Manoment substation exceeds 22.2 megawatts on April 1 B 125 Vdc back-up battery for use in RFO-19 stored in a trailer with no ventilation on April 9 Oil leak on lube oil cooler of A EDG on May 18 Reactor water clean-up valve exceeds local leak rate test limit on May 20 Containment leakage due to leak on high pressure coolant injection valve 23-HO-321 on May 23 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 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 TS 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. | ||
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==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1R18}} | |||
==1R18 Plant Modifications== | |||
{{IP sample|IP=IP 71111.18|count=3}} | |||
===.1 Temporary Modifications=== | ===.1 Temporary Modifications=== | ||
====a. Inspection Scope==== | ====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. | 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. | |||
Installation of instrumentation on, and adjacent to, safety relief valves | Installation of instrumentation on, and adjacent to, safety relief valves Removal of the high crank case vacuum shutdown on the A EDG during surveillance testing | ||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors evaluated a modification to the standby liquid control system implemented by engineering change package, Engineering Change (EC) 34037, | The inspectors evaluated a modification to the standby liquid control system implemented by engineering change package, Engineering Change (EC) 34037, Replace HO-1101-22 Test Valve with Globe Valve. 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 upgrade and design change. The inspectors also reviewed revisions to the system test procedure and interviewed operations personnel to ensure the procedure could be reasonably performed. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1R19}} | |||
==1R19 Post-Maintenance Testing== | |||
{{IP sample|IP=IP 71111.19|count=9}} | |||
====a. Inspection Scope==== | ====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. | 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. | ||
A 125 Vdc battery replacement on May 3 Main steam isolation valve 2C outboard replacement of valve internals on May 18 Replacement of standby liquid control valve 1101-22 on May 22 High pressure coolant injection flow controller repair on May 24 Repair of lube oil leak on A EDG lube oil piping on May 30 Replacement of the B recirculation pump seal cartridge on May 30 Troubleshooting of the C9 annunciator system on May 31 250 VDC D3 battery replacement on June 11 X-56 transformer replacement on June 20 | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1R20}} | {{a|1R20}} | ||
==1R20 Refueling and Other Outage Activities== | ==1R20 Refueling and Other Outage Activities== | ||
{{IP sample|IP=IP 71111.20|count=1}} | {{IP sample|IP=IP 71111.20|count=1}} | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the stations work schedule and outage risk plan for the maintenance and refueling outage (RFO-19), which was conducted April 14 through May 30. 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 technical specifications when taking equipment out of service | Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable technical specifications 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 Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting Status and configuration of electrical systems and switchyard activities to ensure that TS were met Monitoring of DHR operations Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, operations with the potential to drain the reactor vessel, and controls to prevent inventory loss Activities that could affect reactivity Maintenance of secondary containment as required by TS Refueling activities Fatigue management Tracking of startup prerequisites, walkdown of the drywell to verify that debris had not been left which could block the emergency core cooling system suction strainers, and startup and ascension to full power operation Identification and resolution of problems related to refueling outage activities. | ||
====b. Findings==== | ====b. Findings==== | ||
=====Introduction.===== | =====Introduction.===== | ||
A self-revealing NCV of very low safety significance (Green) of TS 5.4.1, | A self-revealing NCV of very low safety significance (Green) of TS 5.4.1, Procedures, was identified for operators not implementing procedures to supply safety-related alternate electrical power to shutdown cooling valves during shutdown cooling operation. Specifically, because operators did not perform all applicable steps in a procedure, a loss of shutdown cooling resulted when operators were shifting power supplies for the B train shutdown cooling suction and discharge valves on May 2, 2013. | ||
=====Description.===== | =====Description.===== | ||
On May 2, RFO-19 was in progress, the | On May 2, RFO-19 was in progress, the B train of shutdown cooling was in-service supplying DHR, and the A train of shutdown cooling was removed from service for planned maintenance. At 12:20 p.m., operators were swapping electrical loads from safety-related 480 Vac bus B-20 to its alternate safety-related 480 Vac bus B-17 in preparation for maintenance activities on bus B-20. While transitioning loads to bus B-17, specifically power to the B train shutdown cooling suction and discharge valves, supply breaker B17116 tripped, closing both the suction and discharge valves resulting in a loss of shutdown cooling. Operators restored shutdown cooling to service approximately five hours later at which point reactor coolant system temperature had increased approximately 8 degrees as a result of the loss of shutdown cooling. | ||
Entergy initiated a prompt investigation and error review and identified that the breaker trip functioned as designed but that a human error had established the conditions that resulted in the breaker trip. Specifically operators had inappropriately marked procedural steps of Procedure 2.4.143, Appendix F, Section 3.5, Revision 50, | Entergy initiated a prompt investigation and error review and identified that the breaker trip functioned as designed but that a human error had established the conditions that resulted in the breaker trip. Specifically operators had inappropriately marked procedural steps of Procedure 2.4.143, Appendix F, Section 3.5, Revision 50, Alternate Power to RHR Valves, as not to be performed, when in accordance with the procedure applicability statements and the prerequisites based on plant conditions the steps should have been performed. The steps that were not performed would have de-energized B-20 first in order to automatically shift the affected loads over to B-17. This would have maintained power to the B RHR train suction and discharge valves and prevented the loss of shutdown cooling. By not de-energizing B-20 first, the B-17 supply breaker automatically opened resulting in the trip of the RHR valves supply breaker and the resultant loss of shutdown cooling. | ||
=====Analysis.===== | =====Analysis.===== | ||
The inspectors determined that operators not following procedures as written resulted in the loss of shutdown cooling and was a performance deficiency that was reasonably within | The inspectors determined that operators not following procedures as written resulted in the loss of shutdown cooling and was a performance deficiency that was reasonably within Entergys ability to foresee and correct. Traditional enforcement does not apply because there were no actual safety consequences, no impacts on the NRCs ability to perform its regulatory function, and no willful aspects associated with the issue. | ||
The finding is more than minor because it affects the objective of the Initiating Events cornerstone to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The unavailability | The finding is more than minor because it affects the objective of the Initiating Events cornerstone to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The unavailability of shutdown cooling for five hours challenged the safety function of DHR. A review of IMC 0612, Appendix E, Examples of Minor Issues, found no more than minor examples that applied. | ||
The inspectors evaluated the finding using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined that the finding required further review using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, because the issue affected the safety of the reactor during a refueling outage. The inspectors determined that this finding was of very low safety significance (Green) using IMC 0609, Appendix G, Checklist 7, BWR Refueling Operation with Reactor Coolant System Level >23. This determination did not require a further phase 2 or phase 3 analysis in that it did not increase the likelihood of a loss of RCS inventory; did not result in the loss of RCS level instrumentation; did not degrade Entergys ability to terminate a leak path or add RCS inventory; and did not degrade Entergys ability to recover DHR once it was lost. In addition, a loss of thermal margin did not occur because the change in RCS temperature resulted in less than 20 percent of the temperature margin to boil. | |||
The inspectors evaluated the finding using IMC 0609, Attachment 4, | |||
The inspectors determined that this finding had a cross-cutting aspect in the Human Performance area, Work Practices component, because personnel did not follow procedures [H.4(b)]. | The inspectors determined that this finding had a cross-cutting aspect in the Human Performance area, Work Practices component, because personnel did not follow procedures [H.4(b)]. | ||
=====Enforcement.===== | =====Enforcement.===== | ||
TS 5.4.1.a, | TS 5.4.1.a, Procedures, requires that written procedures be implemented as recommended in NRC Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978. RG 1.33, Appendix A, Section 4.e includes procedures for shutdown cooling. Contrary to the above, on May 2, 2013, Pilgrim operators did not implement required procedures for shutdown cooling. Specifically, on May 2, 2013, while shifting power supplies for the suction and discharge valves for the B train of shutdown cooling in preparation for maintenance, Procedure 2.4.143, Appendix F, Section 3.5, Revision 50, Alternate Power to RHR Valves, was not implemented in that certain steps were inappropriately marked as not applicable and therefore were not performed. This led to the tripping of RHR valve breakers and the loss of shutdown cooling for five hours. Corrective actions included restoring shutdown cooling following a prompt investigation of the event. Proposed corrective actions include developing a standard checklist that will ensure future bus de-energize plans to include all procedural direction and impacts. Because this finding is of very low safety significance and Entergy has entered it into their CAP (CR-PNP-2013-3457), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV | ||
{{a|1R22}} | |||
===05000293/2013003-01, Failure to Follow Procedures Results in Loss of Shutdown Cooling) | |||
{{a|1R22}} | |||
==1R22 Surveillance Testing== | ==1R22 Surveillance Testing== | ||
{{IP sample|IP=IP 71111.22|count=7}} | {{IP sample|IP=IP 71111.22|count=7}} | ||
====a. Inspection Scope==== | ====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 TS, 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: | The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, 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: | ||
Core spray flow differential pressure in-service test (IST) on April 15 Station blackout diesel generator load test onto the A6 safety-related bus on April 17 A 125 Vdc battery discharge test on May 3 Main steam isolation valve 2C containment isolation valve (CIV) outboard stroke time on May 18 Special test for automatic emergency core cooling system load sequencing and shutdown transformer with simulated LOOP and special shutdown transformer load test on May 23 A EDG and associated emergency bus surveillance on May 29 Turbine generator overspeed testing on May 30 | |||
Core spray flow differential pressure in-service test (IST) on April 15 | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
===Cornerstone:=== | ===Cornerstone: Emergency Preparedness=== | ||
{{a|1EP4}} | {{a|1EP4}} | ||
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No findings were identified. | No findings were identified. | ||
{{a|1EP6}} | |||
{{a|1EP6}} | |||
==1EP6 Drill Evaluation== | ==1EP6 Drill Evaluation== | ||
{{IP sample|IP=IP 71114.06|count=1}} | {{IP sample|IP=IP 71114.06|count=1}} | ||
Simulator Training Evaluation | Simulator Training Evaluation | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors observed a simulator training evolution for licensed operators on June 13, 2013 which required emergency plan implementation by an operations crew. Entergy planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors | The inspectors observed a simulator training evolution for licensed operators on June 13, 2013 which required emergency plan implementation by an operations crew. Entergy planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weakness and deficiencies in the crews performance and ensure that Entergy evaluators noted the same issues and entered them into their CAP. | ||
====b. Findings==== | ====b. Findings==== | ||
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==RADIATION SAFETY== | ==RADIATION SAFETY== | ||
===Cornerstone:=== | ===Cornerstone: Occupational Radiation Safety=== | ||
{{a|2RS1}} | {{a|2RS1}} | ||
==2RS1 Radiological Hazard Assessment and Exposure Controls== | ==2RS1 Radiological Hazard Assessment and Exposure Controls== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
During the period of May 6 - 9, 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 the RFO-19 refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, relevant TS, and | During the period of May 6 - 9, 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 the RFO-19 refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, relevant TS, and Entergys procedures. | ||
Plant Walkdown and Radiation Work Permits (RWP) Reviews The inspectors toured accessible RCAs in the reactor building, turbine deck, condenser bay, radwaste building, re-tube building, and advance off-gas treatment building. | |||
Radiation survey maps were reviewed and independent measurements were made to confirm the accuracy of survey data and the adequacy of postings. | |||
The inspector identified radiological significant jobs scheduled to be performed in the drywell and other RCAs. The inspectors reviewed the applicable RWPs, as low as is reasonably achievable (ALARA) Plans, | The inspector identified radiological significant jobs scheduled to be performed in the drywell and other RCAs. The inspectors reviewed the applicable RWPs, as low as is reasonably achievable (ALARA) Plans, survey maps, and the electronic dosimeter dose/dose rate alarm set points, for the associated tasks, to determine if the radiological controls were acceptable and if the set points were consistent with plant policy. Drywell jobs reviewed included removal of shield blocks from the N1B nozzle (RWP 2013-536),mounting accelerometers on a safety relief valve (RWP 2013-506), and removing shielding from under the reactor vessel (RWP 2013-501). Jobs reviewed in other RCAs included reactor cavity decontamination (RWP 2013-490) in the refueling area and condenser bay scaffolding demobilization (RWP 2013-481). | ||
For the drywell jobs reviewed, the inspectors observed use of the remote monitoring room to provide radiological safety oversight of work in progress. The inspectors observed job site dose rates, worker doses, and air monitoring readings to evaluate actual site radiological conditions, and the coordination of workers by the senior radiation protection technician in charge. | For the drywell jobs reviewed, the inspectors observed use of the remote monitoring room to provide radiological safety oversight of work in progress. The inspectors observed job site dose rates, worker doses, and air monitoring readings to evaluate actual site radiological conditions, and the coordination of workers by the senior radiation protection technician in charge. | ||
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The inspectors reviewed the preparations made for various potentially high dose rate jobs including reactor cavity decontamination and under vessel shielding removal. This review included evaluating the effectiveness of contamination control measures, source term controls, the use of temporary shielding, and use of the remote monitoring system. | The inspectors reviewed the preparations made for various potentially high dose rate jobs including reactor cavity decontamination and under vessel shielding removal. This review included evaluating the effectiveness of contamination control measures, source term controls, the use of temporary shielding, and use of the remote monitoring system. | ||
Radiation Worker and Radiation Protection Technician Performance | Radiation Worker and Radiation Protection Technician Performance During tours of RCAs, the inspectors questioned radiation workers and radiation protection technicians regarding the radiological conditions at the work site and the radiological controls that applied to their task. Additionally, radiological-related condition reports, 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. | ||
During tours of RCAs, the inspectors questioned radiation workers and radiation protection technicians regarding the radiological conditions at the work site and the radiological controls that applied to their task. Additionally, radiological-related condition reports, 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 | 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 various Nuclear Oversight audits and field observation reports, and relevant condition reports. The inspector evaluated whether problems were identified in a timely manner, that an extent of condition and cause evaluation were performed when appropriate, and corrective actions were appropriate to preclude repetitive problems | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|2RS2}} | ||
{{a|2RS2}} | |||
==2RS2 Occupational ALARA Planning and Controls== | ==2RS2 Occupational ALARA Planning and Controls== | ||
{{IP sample|IP=IP 71124.02}} | {{IP sample|IP=IP 71124.02}} | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
During the period of May 6 - 9, the inspectors conducted the following activities to verify that Entergy was properly implementing operational, engineering, and administrative controls to maintain personnel exposure ALARA for activities performed during the refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 and | During the period of May 6 - 9, the inspectors conducted the following activities to verify that Entergy was properly implementing operational, engineering, and administrative controls to maintain personnel exposure ALARA for activities performed during the refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 and Entergys procedures. | ||
Radiological Work Planning | Radiological Work Planning The inspectors reviewed pertinent information regarding site cumulative exposure history, current exposure trends, and the ongoing exposure challenges for the outage. | ||
The inspectors reviewed | The inspectors reviewed the ALARA plans for various outage projects. | ||
The inspectors reviewed the specific ALARA Plans and associated RWPs for all outage projects that exceeded 5 person-rem estimated exposure. This review included: | |||
scaffolding installation/removal (RWP 2013-481), reactor disassembly/reassembly (RWP 2013-485), shielding installation/removal (RWP 2013-501), valve maintenance and modifications in the drywell (RWP 2013-506), insulation removal/installation (RWP2013-539) and control rod drive exchange (RWP 2013-509). In reviewing these projects, the inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems. The evaluation was accomplished by interviewing site staff, and reviewing outage Station ALARA Managers Committee (AMC) meeting | scaffolding installation/removal (RWP 2013-481), reactor disassembly/reassembly (RWP 2013-485), shielding installation/removal (RWP 2013-501), valve maintenance and modifications in the drywell (RWP 2013-506), insulation removal/installation (RWP2013-539) and control rod drive exchange (RWP 2013-509). In reviewing these projects, the inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems. The evaluation was accomplished by interviewing site staff, and reviewing outage Station ALARA Managers Committee (AMC) meeting minutes. | ||
Verification of Dose Estimates The inspectors reviewed the assumptions and basis for the RFO-19 outage ALARA dose estimates. The inspectors also reviewed the revisions made to various outage project dose estimates that resulted from exposure challenges presented to the AMC. | |||
The inspectors reviewed Entergys procedures associated with monitoring and re-evaluating dose estimates when the forecasted cumulative exposure for tasks was approached, and the implementation of these procedures during the outage. In particular, the inspectors evaluated the in-progress reviews for tasks that exceeded 40 percent and 80 percent of their estimated doses including scaffolding installation, control rod drive exchange, valve work in the drywell, reactor vessel disassembly, and shielding installation. | |||
The inspectors reviewed the | The inspectors reviewed the exposures for the ten | ||
: (10) workers who received the highest doses for the refueling outage to confirm that no individual exceeded the regulatory annual limit or the performance indicator criteria. Included in this review were the dose extension authorizations for workers who would exceed Entergys administrative dose limit. | |||
The inspectors reviewed | Job Site Inspections The inspectors reviewed the exposure controls specified in ALARA Plans and RWPs for reactor cavity decontamination and shield block removal from the N1B reactor nozzle. | ||
The inspectors attended pre-job ALARA briefings for these activities and observed aspects of these jobs using the remote monitoring system. | |||
During plant tours, the inspectors observed workers remove scaffolding and demobilize equipment from various RCAs. Workers were questioned regarding their knowledge of job site radiological conditions, the ALARA measures applied to their tasks, and contamination control. | During plant tours, the inspectors observed workers remove scaffolding and demobilize equipment from various RCAs. Workers were questioned regarding their knowledge of job site radiological conditions, the ALARA measures applied to their tasks, and contamination control. | ||
Source Term Reduction and Control The inspectors reviewed the status and historical trends for the plant source term. | Source Term Reduction and Control The inspectors reviewed the status and historical trends for the plant source term. | ||
underwater demineralizers during cavity flood up, system flushes, and use of temporary shielding. | Through a review of survey maps and interviews with the ALARA Supervisor, the inspectors evaluated recent source term measurements and control strategies. Specific strategies being employed included increasing reactor water cleanup flow, utilizing underwater demineralizers during cavity flood up, system flushes, and use of temporary shielding. | ||
The inspectors assessed the effectiveness of temporary shielding by reviewing pre- and post-installation radiation survey data for shielding the under vessel drain line, the A and B feedwater check valves, the N1A reactor nozzle, and the recirculation system ring | The inspectors assessed the effectiveness of temporary shielding by reviewing pre- and post-installation radiation survey data for shielding the under vessel drain line, the A and B feedwater check valves, the N1A reactor nozzle, and the recirculation system ring header. | ||
Problem Identification and Resolution The inspectors reviewed elements of Entergys CAP, including field observations by the Nuclear Oversight Department, related to implementing the ALARA program to determine if problems were being entered into the program for timely resolution. | |||
Condition reports related to programmatic dose challenges, personnel contaminations, dose/dose rate alarms, and the effectiveness in predicting and controlling worker exposure were reviewed. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|2RS3}} | ||
{{a|2RS3}} | |||
==2RS3 In-Plant Airborne Radioactivity Control and Mitigation== | ==2RS3 In-Plant Airborne Radioactivity Control and Mitigation== | ||
{{IP sample|IP=IP 71124.03}} | {{IP sample|IP=IP 71124.03}} | ||
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During the period of May 6 - 9, the inspectors conducted the following activities to verify that in-plant radioactivity airborne concentrations were being controlled and monitored and that the use of respiratory protection devices was appropriately specified and used. | During the period of May 6 - 9, the inspectors conducted the following activities to verify that in-plant radioactivity airborne concentrations were being controlled and monitored and that the use of respiratory protection devices was appropriately specified and used. | ||
Implementation of these controls was reviewed against the criteria contained in | Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 and Entergys procedures. | ||
Engineering Controls The inspectors reviewed air sampling records and readings from portable air monitoring systems (AMS-4) for on-going jobs to confirm that airborne contamination was properly monitored and controlled. During plant walk downs, the inspectors evaluated the operability of air monitoring equipment and verified that air samples were representative of the work environment. Additionally, the inspectors evaluated the use of engineering controls, such as portable high efficiency particulate air filtration/ventilation systems, to assure the systems were tested, operable and properly located for tasks involving contaminated systems, such as reactor head staging and for dry well work activities. | |||
Use of Respiratory Protection Devices | Use of Respiratory Protection Devices The inspectors evaluated the use of powered air purifying respirators as a contingency for specific tasks involving potential airborne contamination, including reactor cavity decontamination and that full body (delta) suits were appropriately used for high contamination work; e.g. control rod drive replacements. The inspectors evaluated ALARA analyses that were performed to justify that the respirators would not be beneficial in minimizing worker dose. | ||
The inspectors evaluated the use of powered air purifying respirators as a contingency for specific tasks involving potential airborne contamination, including reactor cavity decontamination and that full body (delta) suits were appropriately used for high contamination work; e.g. control rod drive replacements. The inspectors evaluated ALARA analyses that were performed to justify that the respirators would not be beneficial in minimizing worker dose. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. {{a|2RS4}} | ||
{{a|2RS4}} | |||
==2RS4 Occupational Dose Assessment== | ==2RS4 Occupational Dose Assessment== | ||
{{IP sample|IP=IP 71124.04}} | {{IP sample|IP=IP 71124.04}} | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
During the period of May 6 - 9, the inspectors conducted the following activities to verify that the occupational dose was appropriately monitored and that the processes were effectively carried out in determining internal dose to assure that the total effective dose equivalent was accurately measured. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 and | During the period of May 6 - 9, the inspectors conducted the following activities to verify that the occupational dose was appropriately monitored and that the processes were effectively carried out in determining internal dose to assure that the total effective dose equivalent was accurately measured. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 and Entergys procedures. | ||
External Dosimetry The inspectors assessed the implementation of dosimetry procedures including: | External Dosimetry The inspectors assessed the implementation of dosimetry procedures including: routine thermoluminescent dosimeter issuance, multi-badging, and extremity dosimeter use. | ||
The inspectors verified that procedural controls were in place for external effective dose equivalent determinations, that would be used for high dose gradient tasks; e.g. control rod drive mechanism replacement and reactor nozzle ISIs. | The inspectors verified that procedural controls were in place for external effective dose equivalent determinations, that would be used for high dose gradient tasks; e.g. control rod drive mechanism replacement and reactor nozzle ISIs. | ||
The inspectors reviewed authorizations for extending the dose limits for specific workers to verify that the | The inspectors reviewed authorizations for extending the dose limits for specific workers to verify that the workers past dose history was evaluated and that the appropriate level of management approved the new limit. The inspectors reviewed dose records for the 10 highest exposures occurring during 2013 to determine if the dose was appropriately authorized and that regulatory limits were not exceeded. | ||
The inspectors reviewed condition reports related to electronic dose and dose rate alarms received on electronic dosimetry to determine if the cause of the alarm was properly determined. Additionally, the inspectors evaluated the resulting dose to determine if performance indicator criteria were met for unplanned exposures. | |||
The inspectors evaluated the dose assessments for contaminated individuals who had the potential for inhaling radioactive material. The inspectors reviewed the whole body counting data, dose calculations, and independently estimated the resultant dose. | Internal Dosimetry The inspectors evaluated the dose assessments for contaminated individuals who had the potential for inhaling radioactive material. The inspectors reviewed the whole body counting data, dose calculations, and independently estimated the resultant dose. | ||
Declared Pregnant Workers | Declared Pregnant Workers The inspectors assessed the program for controlling and restricting the dose to declared pregnant workers, who had access to performing outage related activities. | ||
The inspectors assessed the program for controlling and restricting the dose to declared pregnant workers, who had access to performing outage related activities. | |||
====b. Findings==== | ====b. Findings==== | ||
Line 514: | Line 444: | ||
==4OA1 Performance Indicator Verification== | ==4OA1 Performance Indicator Verification== | ||
{{IP sample|IP=IP 71151}} | {{IP sample|IP=IP 71151}} | ||
=== | |||
{{IP sample|IP=IP 05000|count=3}} | |||
===.1 Safety System Functional Failures=== | ===.1 Safety System Functional Failures=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors sampled | The inspectors sampled Entergys submittals for the Safety System Functional Failures performance indicators for the period of January 1, 2012, through December 31, 2012. | ||
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, | 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 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73. The inspectors reviewed Entergys plant logs, condition reports, licensee event reports (LERs), and NRC integrated inspection reports to validate the accuracy of the submittals. | ||
====b. Findings==== | ====b. Findings==== | ||
Line 529: | Line 459: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed | The inspectors reviewed Entergys submittal for the RCS specific activity and RCS leak rate performance indicators for the period of April 1, 2012, through March 31, 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. 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. | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|4OA2}} | {{a|4OA2}} | ||
==4OA2 Problem Identification and Resolution== | ==4OA2 Problem Identification and Resolution== | ||
{{IP sample|IP=IP 71152|count=2}} | {{IP sample|IP=IP 71152|count=2}} | ||
Line 541: | Line 471: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
As required by Inspection Procedure 71152, | 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 their 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 their CAP and periodically attended condition report screening meetings. | ||
====b. Findings==== | ====b. Findings==== | ||
Line 549: | Line 479: | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, | 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 condition reports written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily condition report 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==== | ====b. Findings and Observations==== | ||
Line 558: | Line 486: | ||
One new trend is discussed below. | One new trend is discussed below. | ||
Equipment Reliability | Equipment Reliability Equipment reliability issues resulting in plant transients have been identified as a trend by the inspectors and Entergy. Specifically, the Engineering Director initiated CR-PNP-2012-0239 to conduct a cause evaluation of equipment reliability issues from 2011 and into 2012. | ||
Equipment reliability issues resulting in plant transients have been identified as a trend by the inspectors and Entergy. Specifically, the Engineering Director initiated CR-PNP-2012-0239 to conduct a cause evaluation of equipment reliability issues from 2011 and into 2012. | |||
===.3 Annual Sample: Review of a Tagout Error Documented in CR-PNP-2012-1930=== | ===.3 Annual Sample: Review of a Tagout Error Documented in CR-PNP-2012-1930=== | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors selected condition report CR-PNP-2012-1930, which documented high pressure coolant injection system work that was performed without anyone signing on to the tagout. The inspectors assessed | The inspectors selected condition report CR-PNP-2012-1930, which documented high pressure coolant injection system work that was performed without anyone signing on to the tagout. The inspectors assessed Entergys extent of condition review and whether the planned or completed actions were appropriate. Additionally, the inspectors reviewed subsequent condition reports addressing tagout errors generated over the past year to determine if corrective actions were effective and whether an appropriate extent of condition of tagging errors was conducted. | ||
====b. Findings and Observations==== | ====b. Findings and Observations==== | ||
Line 579: | Line 505: | ||
====a. Inspection Scope==== | ====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, | 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 performance during a loss of all annunciator capability on May 3, 2013 Operator response to a report of a fire on the 51 elevation of the turbine building on May 7, 2013 Operator response to a fire in the turbine auxiliary lube oil pump room on May 20, 2013 Operator performance during power movement to support a main condenser thermal backwash on June 27, 2013 | |||
===.2 (Closed) LER 05000293/2013-001-00: Inadvertent Trip of Both Recirculation Pumps and=== | |||
Subsequent Manual Scram On January 10, 2013, both reactor recirculation pumps tripped and a manual scram was inserted. Operators responded to the event and all plant systems responded as designed. A follow-up investigation determined that a plant relay was inadvertently energized during restoration from surveillance testing. Procedure changes and training have been implemented to prevent this event from recurring. The LER was reviewed. | |||
No findings or violations of NRC requirements were identified. This LER is closed. | |||
{{a|4OA6}} | {{a|4OA6}} | ||
Line 601: | Line 527: | ||
===Licensee Personnel=== | ===Licensee Personnel=== | ||
J. Dent | J. Dent Site Vice President | ||
B. Ahern | B. Ahern Electrical System Engineer | ||
G. Blankenbiller | G. Blankenbiller Chemistry Manager | ||
D. Brugman | G. Bradley Component Engineer | ||
D. Burke | S. Brewer Radiation Protection Manager | ||
B. Chenard | D. Brugman Supervisor ALARA/Technical Support | ||
M. Dagnello | D. Burke Security Manager | ||
K. Drown | B. Chenard Engineering Director | ||
J. Falconieri | J. Couto Senior Reactor Operator | ||
R. Hargat | J. Cox Radiation Protection Operations Supervisor | ||
W. Lobo | M. Dagnello Superintendent FIN Team | ||
J. Lynch | K. Drown Nuclear Oversight and Recovery Manager | ||
J. Macdonald | J. Falconieri Senior Lead Engineer | ||
T. McElhinney | J. Fitzsimmons Radiation Protection Supervisor | ||
A. Muse | M. Gatslick Security Compliance Supervisor | ||
J. Norris | R. Hargat Radiation Protection Technician | ||
J. Priest | W. Lobo Compliance Engineer | ||
: [[contact::J. Scheffer | J. Lynch Licensing Manager | ||
W. Smith | J. Macdonald Operations Manager | ||
M. Thornhill | D. Mannai Senior Manager Nuclear Safety and Licensing | ||
T. F. White | W. Mauro Supervisor Radiation Protection Support | ||
T. McElhinney Training Manager | |||
A. Muse Superintendent Operations Training | |||
J. Norris Radiological Engineer | |||
D. Noyes Nuclear Safety Assurance Director | |||
J. Ohrenberger Maintenance Manager | |||
J. Priest Emergency Preparedness Manager | |||
: [[contact::J. Scheffer Specialist]], Effluent & Environmental Monitoring | |||
W. Smith Chemistry Supervisor | |||
M. Thornhill Radiation Protection Supervisor | |||
S. Verrochi General Manager Plant Operations | |||
T. F. White Design Engineering Manager | |||
==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED== | ==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED== | ||
===Opened/Closed=== | ===Opened/Closed=== | ||
: 05000293/2013005-01 | : 05000293/2013005-01 NCV Failure to Follow Procedures Results in Loss of Shutdown Cooling (Section 1R20) | ||
1R20) | |||
===Closed=== | |||
005000293/2013-001-00 LER Inadvertent Trip of Both Recirculation Pumps and Subsequent Manual Scram (section 4OA3) | |||
==LIST OF DOCUMENTS REVIEWED== | ==LIST OF DOCUMENTS REVIEWED== | ||
}} | }} |
Latest revision as of 14:41, 20 December 2019
ML13221A006 | |
Person / Time | |
---|---|
Site: | Pilgrim |
Issue date: | 08/08/2013 |
From: | Fred Bower NRC/RGN-I/DRP/PB5 |
To: | Dent J Entergy Nuclear Operations |
Bower F | |
References | |
IR-13-003 | |
Download: ML13221A006 (42) | |
Text
UNITED STATES ugust 8, 2013
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2013003
Dear Mr. Dent:
On June 30, 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 July 18, 2013, with Steve 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.
This report documents one self-revealing finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance, and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the 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 the 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. In accordance with 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 NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access 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/
Fred L. Bower III, Acting Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No: 50-293 License No: DPR-35
Enclosure:
Inspection Report 05000293/2013003 w/Attachment: Supplementary Information
REGION I==
Docket No: 50-293 License No: DPR-35 Report No.: 05000293/2013003 Licensee: Entergy Nuclear Operations, Inc.
Facility: Pilgrim Nuclear Power Station (PNPS)
Location: Plymouth, MA 02360 Dates: April 1, 2013 through June 30, 2013 Inspectors: M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP)
B. Smith, Resident Inspector, DRP J. Krafty, Resident Inspector, Millstone Nuclear Power Station, DRP T. Moslak, Health Physicist, Division of Reactor Safety (DRS)
T. Burns, Reactor Inspector, DRS J. Laughlin, Emergency Preparedness Inspector, Office of Nuclear Security and Incident Response (NSIR)
Approved By: Fred L. Bower III, Acting Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
TABLE OF CONTENTS 1. REACTOR SAFETY .............................................................................................................. 4 1R01 Adverse Weather Protection ....................................................................................... 4 1R04 Equipment Alignment .................................................................................................. 5 1R05 Fire Protection ............................................................................................................. 6 1R06 Flood Protection Measures ......................................................................................... 7 1R07 Heat Sink Performance ............................................................................................... 7 1R08 In-Service Inspection .................................................................................................. 7 1R11 Licensed Operator Requalification Program ............................................................... 9 1R12 Maintenance Effectiveness ....................................................................................... 10 1R13 Maintenance Risk Assessments and Emergent Work Control ................................. 11 1R15 Operability Determinations and Functionality Assessments ..................................... 11 1R18 Plant Modifications .................................................................................................... 12 1R19 Post-Maintenance Testing ........................................................................................ 13 1R20 Refueling and Other Outage Activities ...................................................................... 13 1R22 Surveillance Testing.................................................................................................. 16 1EP4 Emergency Action Level and Emergency Plan Changes ......................................... 16 1EP6 Drill Evaluation .......................................................................................................... 17 2. RADIATION SAFETY ........................................................................................................ 17 2RS1 Radiological Hazard Assessment and Exposure Controls ........................................ 17 2RS2 Occupational ALARA Planning and Controls ............................................................ 19 2RS3 In-Plant Airborne Radioactivity Control and Mitigation .............................................. 20 2RS4 Occupational Dose Assessment ............................................................................... 21 4. OTHER ACTIVITIES ............................................................................................................ 22 4OA1 Performance Indicator Verification ............................................................................ 22 4OA2 Problem Identification and Resolution ...................................................................... 23 4OA3 Follow-Up of Events and Notices of Enforcement Discretion.................................... 24 4OA6 Meetings, Including Exit ............................................................................................ 25 ATTACHMENT: SUPPLEMENTARY INFORMATION................................................................ 25 SUPPLEMENTARY INFORMATION ........................................................................................ A-1 KEY POINTS OF CONTACT .................................................................................................... A-1 LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ..................................... A-1 LIST OF DOCUMENTS REVIEWED ........................................................................................ A-2 LIST OF ACRONYMS ............................................................................................................. A-14 Enclosure
SUMMARY
IR 05000293/2013003; 04/01/2013 - 06/30/2013; Pilgrim Nuclear Power Station; Refueling and
Other Outage Activities.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. One finding of very low safety significance (Green) was identified, which was a non-cited violation (NCV). The significance of inspection findings are 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 the Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 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.
A self-revealing NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for operators not implementing procedures to supply safety-related alternate electrical power to shutdown cooling valves during shutdown cooling operation. Specifically, because operators did not perform all applicable steps in a procedure, a loss of shutdown cooling resulted when operators were shifting power supplies for the B train shutdown cooling suction and discharge valves on May 2, 2013. Corrective actions included restoring shutdown cooling following a prompt investigation of the event. Entergy has captured this event in their corrective action program (CAP) as CR-PNP-2013-3457.
The performance deficiency is more than minor because it affects the objective of the Initiating Events cornerstone to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The unavailability of shutdown cooling for five hours challenged the safety function of decay heat removal (DHR) supplied by the residual heat removal (RHR) system. A review of IMC 0612,
Appendix E, Examples of Minor Issues, found no more than minor examples that applied.
The inspectors evaluated the finding using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined that the finding required further review using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, because the issue affected the safety of the reactor during a refueling outage. The inspectors determined that this finding was of very low safety significance (Green), using IMC 0609, Appendix G, Checklist 7, BWR Refueling Operation with Reactor Coolant System (RCS) Level >23. This determination did not require a further phase 2 or phase 3 analysis in that it did not increase the likelihood of a loss of RCS inventory; did not result in the loss of RCS level instrumentation; did not degrade Entergys ability to terminate a leak path or add RCS inventory; and did not degrade Entergys ability to recover DHR once it was lost. In addition, a loss of thermal margin did not occur since the change in RCS temperature resulted in less than 20 percent of the temperature margin to boil. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance area, Work Practices component, because personnel did not follow procedures H.4(b). (Section 1R20)
REPORT DETAILS
Summary of Plant Status
Pilgrim Nuclear Power Station began the inspection period operating at 86 percent reactor power due to safety relief valve pilot leakage. On April 14, operators reduced reactor power in preparation for Refueling Outage 19 and subsequently initiated a manual reactor scram from less than 1 percent power due to an uncontrolled lowering of reactor pressure. On May 23, a reactor startup was performed and the plant reached 5 percent reactor power before main condenser parameters were observed to be degrading. The plant was returned to a shutdown condition on May 24 and repairs were made to the main condenser. On May 27, a reactor startup was performed and the plant reached 100 percent reactor power on May 30. On June 27, operators reduced reactor power to 50 percent to perform a thermal backwash of the main condenser. On June 28, operators returned the plant to 100 percent reactor power. Pilgrim remained at or near 100 percent reactor power through the end of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems
a. Inspection Scope
The inspectors performed a review of Entergys plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Entergys procedures affecting these areas and the communication protocols between the transmission system operator and Entergy. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Entergy established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing condition reports and open work orders, and walking down portions of the offsite and AC power systems including the switchyard. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of Entergys readiness for the onset of the hurricane season. The review focused on the intake structure, the emergency diesel generators (EDGs), and the station blackout diesel generator. The inspectors reviewed station procedures, including Entergys adverse weather procedures and applicable operating procedures to determine what could challenge these systems, and to ensure Entergy personnel had adequately prepared for these challenges. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during adverse weather.
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:
A reactor building closed cooling water (RBCCW) system during B RBCCW heat-exchanger re-sleeving on April 23 Standby liquid control system following maintenance and system realignment on May 14 High pressure coolant injection system following overhaul on May 19 Control rod drive system following the refueling outage on May 22 The inspectors selected 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), TS, work orders, condition reports, 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 the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
During the week of May 6, the inspectors performed a complete system walkdown of accessible portions of the core spray 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 UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Entergy appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)
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.
Fire Area 1.9, Fire Zone 1.15, standby liquid control pumps and equipment on April Fire Area 1.30, Fire Zone 1.30, drywell on May 10 Fire Area 1.20, Fire Zone 3.6, radwaste truck lock on May 20 Fire Area 1.9, Fire Zone 1.8, control rod drive pump quadrant-mezzanine level on May 22 Fire Area 1.10, Fire Zones 4.1 and 4.2, B EDG building and day tank room on June
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if Entergy identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors also focused on the EDG enclosures to verify the adequacy of scuppers, curbing, and check valves for common drain lines.
b. Findings
No findings were identified.
1R07 Heat Sink Performance (711111.07A - 1 sample)
a. Inspection Scope
The inspectors reviewed the B RBCCW heat exchanger to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified Entergys commitments to NRC Generic Letter 89-13. The inspectors reviewed the results of inspections of the RBCCW heat exchanger. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of as-found and as-left conditions. The inspectors verified that Entergy initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.
Findings No findings were identified.
1R08 In-Service Inspection (711111.08 - 1 sample)
a. Inspection Scope
From April 22 through 26, the inspectors conducted an inspection and review of Entergys implementation of in-service inspection (ISI) program activities for monitoring degradation of the reactor coolant system (RCS) boundary, risk significant piping and components, and containment systems during the Pilgrim refuel outage (RFO-19). The sample selection was based on the inspection procedure objectives and risk priority of those pressure retaining components in systems where degradation would result in a significant increase in risk. The inspectors observed in-process non-destructive examinations (NDE), reviewed documentation, and interviewed Entergy personnel to verify that the NDE activities performed as part of the fourth interval, third period, of the Pilgrim ISI program were conducted in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 2001 Edition with Addenda thru 2003.
Nondestructive Examination and Welding Activities (IMC Section 02.01)
The inspectors performed direct observation of NDE activities in process and reviewed documentation of nondestructive examinations listed below. Activities included observation of ultrasonic testing (UT) in the field and review of documentation of liquid penetrant testing (PT), magnetic particle testing (MT) and visual testing (VT-1 and VT-3).
ASME Code Required Examinations The inspectors observed the manual ultrasonic examination of one 20-inch diameter pipe to pipe butt weld in the RHR system. This observation was performed in the field to verify process compliance with ASME Section XI. The UT procedure used for this examination and acceptance was GEH-PDI-UT-1, Revision 8. No recordable indications were identified as a result of the examination, and 100 percent Code coverage of the inspectable area was achieved. The inspectors verified the UT procedure and the examiner were appropriately qualified in accordance with the requirements of ASME Section XI.
A documentation review was performed of the volumetric examination of the safe end to nozzle weld 2R-N2E-1, using Performance Demonstration Initiative (PDI)qualified manual phased array UT procedure EPRI-DMW-PA-1, Revision 4. The weld was a dissimilar metal butt weld of the recirculation system safe end to nozzle, 16-inch diameter and 1.32-inch wall thickness. The inspectors reviewed the test procedure, calibration reports, weld volume coverage, analysis of test results and noted that 100 percent Code coverage was achieved and no relevant indications were identified. The qualifications of the test examiner were verified for compliance with ASME Section XI and PDI requirements.
The inspectors performed a documentation review of the magnetic particle examination of the weld of the bottom mounted skirt (integral attachment) to the reactor pressure vessel (RPV). The inspectors reviewed the documentation to verify the MT procedure CEP-NDE-0731, Revision 3 and the examiner were appropriately qualified to the requirements of ASME Section XI. The inspectors also reviewed the contents of the MT examination report to determine the test variables were applied in accordance with the procedure and the results were recorded and evaluated for acceptance as specified by the procedure. The inspectors noted that no recordable indications were identified.
The reactor pressure vessel UT documentation review included the upper head meridional (closure) head weld, RPV-TH-M8, being examined from the outside surface in accordance with ASME Section XI. The inspectors reviewed the examination report produced by Entergy of the UT inspection. The examination achieved 100 percent of the Code required volume and, no recordable indications were detected.
Repair/Replacement with Welding Activities The inspectors performed a record review of the restoration of the degraded wall thickness of the turbine building closed cooling water B heat exchanger to verify that welding and applicable NDE activities were performed in accordance with the ASME Code requirements. The inspectors reviewed weld procedure and welder qualifications to verify those qualifications were in accordance with the requirements of the Code of construction and the repair was performed in accordance with the Entergy ASME Section XI repair program. This repair was governed by Work Order WO-00293345-A and acceptance criteria was specified as visual examination of the welding supplemented by a PT with a pressure test of the completed repair in accordance with ASME Section XI.
Industry Initiative Examination The inspectors selected a sample of RPV internals for observation and evaluation of the in-vessel visual inspection activity. The activity inspected was the remote under water examination of reactor vessel internals using procedure TP12-014 and TP12-015 for in-vessel visual inspection of internals. The inspection scope included portions of the core shroud, steam dryer, core spray piping inside the vessel, top guide bars and other structural members. The inspectors observed the examination of portions of the core spray piping, spargers, both access hole cover plate welds, and various structural components within the vessel. The inspector also reviewed a sample of digital video records of prior component examinations that were used for comparison to the current inspection observations. The inspectors observed that there was no change in the characteristics, orientation and size of previous identified indications.
Containment Visual Examination The inspectors visually examined the condition of the primary containment liner surfaces on the nine and 19-foot elevations and limited portions of the 41-foot elevation. The inspector was able to access the liner surfaces at the lower elevations. Containment surfaces above and below the listed elevations were accessible for visual examination.
The inspectors noted that the condition of the liner coating reflected evidence that the liner was being maintained in serviceable condition with some areas having been locally re-coated to provide the base metal with protection from degradation.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training on June 13, which included an electric pressure regulator malfunction, a seismic event, a loss of coolant accident, and a station blackout. 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 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
The inspectors observed and reviewed main control room activities during loss of offsite power (LOOP) testing on May 8. The inspectors reviewed procedural guidance for the LOOP test, attended the Infrequently Performed Test or Evolution brief, and observed control room and test personnel performance during the test. Additionally, the inspectors observed main control room activities during a reactor start-up to criticality and to the point of adding heat on May 22. The inspectors also observed main control room activities during power maneuvers to support a condenser thermal backwash on June 27. The inspectors reviewed procedural guidance for station power changes, power maneuver plans, and observed control room conduct and control of these evolutions.
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 (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders, 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 was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
10 tubes of the B RBCCW system failed 50 percent of their wall loss acceptance criterion functional failure evaluation review on June 14 Secondary containment functional failure evaluation review for a damaged reactor building inner truck lock door on June 19
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 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.
Planned Orange risk due to maintenance on the A8 vital bus resulting in unavailability of the station blackout diesel generator and the shutdown transformer on April 16 Planned and emergent risk assessments during operations with the potential to drain the reactor vessel (control rod blade moves and hydraulic control unit freeze seal) on April 26 Emergent Yellow risk due to the loss of B-17, 480 volt safety-related bus on May 23 Planned Yellow risk due to the LOOP test on May 8 Emergent Yellow risk due to containment declared out of service on May 23 Planned Yellow risk due to high pressure coolant injection system testing on June 19
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:
23 kV system cannot support operability of the shutdown transformer when the Manoment substation exceeds 22.2 megawatts on April 1 B 125 Vdc back-up battery for use in RFO-19 stored in a trailer with no ventilation on April 9 Oil leak on lube oil cooler of A EDG on May 18 Reactor water clean-up valve exceeds local leak rate test limit on May 20 Containment leakage due to leak on high pressure coolant injection valve 23-HO-321 on May 23 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 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 TS 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
.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.
Installation of instrumentation on, and adjacent to, safety relief valves Removal of the high crank case vacuum shutdown on the A EDG during surveillance testing
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
The inspectors evaluated a modification to the standby liquid control system implemented by engineering change package, Engineering Change (EC) 34037, Replace HO-1101-22 Test Valve with Globe Valve. 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 upgrade and design change. The inspectors also reviewed revisions to the system test procedure and interviewed operations personnel to ensure the procedure could be reasonably performed.
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.
A 125 Vdc battery replacement on May 3 Main steam isolation valve 2C outboard replacement of valve internals on May 18 Replacement of standby liquid control valve 1101-22 on May 22 High pressure coolant injection flow controller repair on May 24 Repair of lube oil leak on A EDG lube oil piping on May 30 Replacement of the B recirculation pump seal cartridge on May 30 Troubleshooting of the C9 annunciator system on May 31 250 VDC D3 battery replacement on June 11 X-56 transformer replacement on June 20
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 maintenance and refueling outage (RFO-19), which was conducted April 14 through May 30. 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 technical specifications 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 Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting Status and configuration of electrical systems and switchyard activities to ensure that TS were met Monitoring of DHR operations Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, operations with the potential to drain the reactor vessel, and controls to prevent inventory loss Activities that could affect reactivity Maintenance of secondary containment as required by TS Refueling activities Fatigue management Tracking of startup prerequisites, walkdown of the drywell to verify that debris had not been left which could block the emergency core cooling system suction strainers, and startup and ascension to full power operation Identification and resolution of problems related to refueling outage activities.
b. Findings
Introduction.
A self-revealing NCV of very low safety significance (Green) of TS 5.4.1, Procedures, was identified for operators not implementing procedures to supply safety-related alternate electrical power to shutdown cooling valves during shutdown cooling operation. Specifically, because operators did not perform all applicable steps in a procedure, a loss of shutdown cooling resulted when operators were shifting power supplies for the B train shutdown cooling suction and discharge valves on May 2, 2013.
Description.
On May 2, RFO-19 was in progress, the B train of shutdown cooling was in-service supplying DHR, and the A train of shutdown cooling was removed from service for planned maintenance. At 12:20 p.m., operators were swapping electrical loads from safety-related 480 Vac bus B-20 to its alternate safety-related 480 Vac bus B-17 in preparation for maintenance activities on bus B-20. While transitioning loads to bus B-17, specifically power to the B train shutdown cooling suction and discharge valves, supply breaker B17116 tripped, closing both the suction and discharge valves resulting in a loss of shutdown cooling. Operators restored shutdown cooling to service approximately five hours later at which point reactor coolant system temperature had increased approximately 8 degrees as a result of the loss of shutdown cooling.
Entergy initiated a prompt investigation and error review and identified that the breaker trip functioned as designed but that a human error had established the conditions that resulted in the breaker trip. Specifically operators had inappropriately marked procedural steps of Procedure 2.4.143, Appendix F, Section 3.5, Revision 50, Alternate Power to RHR Valves, as not to be performed, when in accordance with the procedure applicability statements and the prerequisites based on plant conditions the steps should have been performed. The steps that were not performed would have de-energized B-20 first in order to automatically shift the affected loads over to B-17. This would have maintained power to the B RHR train suction and discharge valves and prevented the loss of shutdown cooling. By not de-energizing B-20 first, the B-17 supply breaker automatically opened resulting in the trip of the RHR valves supply breaker and the resultant loss of shutdown cooling.
Analysis.
The inspectors determined that operators not following procedures as written resulted in the loss of shutdown cooling and was a performance deficiency that was reasonably within Entergys ability to foresee and correct. Traditional enforcement does not apply because there were no actual safety consequences, no impacts on the NRCs ability to perform its regulatory function, and no willful aspects associated with the issue.
The finding is more than minor because it affects the objective of the Initiating Events cornerstone to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The unavailability of shutdown cooling for five hours challenged the safety function of DHR. A review of IMC 0612, Appendix E, Examples of Minor Issues, found no more than minor examples that applied.
The inspectors evaluated the finding using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined that the finding required further review using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, because the issue affected the safety of the reactor during a refueling outage. The inspectors determined that this finding was of very low safety significance (Green) using IMC 0609, Appendix G, Checklist 7, BWR Refueling Operation with Reactor Coolant System Level >23. This determination did not require a further phase 2 or phase 3 analysis in that it did not increase the likelihood of a loss of RCS inventory; did not result in the loss of RCS level instrumentation; did not degrade Entergys ability to terminate a leak path or add RCS inventory; and did not degrade Entergys ability to recover DHR once it was lost. In addition, a loss of thermal margin did not occur because the change in RCS temperature resulted in less than 20 percent of the temperature margin to boil.
The inspectors determined that this finding had a cross-cutting aspect in the Human Performance area, Work Practices component, because personnel did not follow procedures H.4(b).
Enforcement.
TS 5.4.1.a, Procedures, requires that written procedures be implemented as recommended in NRC Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978. RG 1.33, Appendix A, Section 4.e includes procedures for shutdown cooling. Contrary to the above, on May 2, 2013, Pilgrim operators did not implement required procedures for shutdown cooling. Specifically, on May 2, 2013, while shifting power supplies for the suction and discharge valves for the B train of shutdown cooling in preparation for maintenance, Procedure 2.4.143, Appendix F, Section 3.5, Revision 50, Alternate Power to RHR Valves, was not implemented in that certain steps were inappropriately marked as not applicable and therefore were not performed. This led to the tripping of RHR valve breakers and the loss of shutdown cooling for five hours. Corrective actions included restoring shutdown cooling following a prompt investigation of the event. Proposed corrective actions include developing a standard checklist that will ensure future bus de-energize plans to include all procedural direction and impacts. Because this finding is of very low safety significance and Entergy has entered it into their CAP (CR-PNP-2013-3457), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV
===05000293/2013003-01, Failure to Follow Procedures Results in Loss of Shutdown Cooling)
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 TS, 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:
Core spray flow differential pressure in-service test (IST) on April 15 Station blackout diesel generator load test onto the A6 safety-related bus on April 17 A 125 Vdc battery discharge test on May 3 Main steam isolation valve 2C containment isolation valve (CIV) outboard stroke time on May 18 Special test for automatic emergency core cooling system load sequencing and shutdown transformer with simulated LOOP and special shutdown transformer load test on May 23 A EDG and associated emergency bus surveillance on May 29 Turbine generator overspeed testing on May 30
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The NSIR 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 ML13098A104 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 Entergy-generated changes; therefore, this revision is subject to future inspection.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
Simulator Training Evaluation
a. Inspection Scope
The inspectors observed a simulator training evolution for licensed operators on June 13, 2013 which required emergency plan implementation by an operations crew. Entergy planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weakness and deficiencies in the crews performance and ensure that Entergy evaluators noted the same issues and entered them into their CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
During the period of May 6 - 9, 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 the RFO-19 refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, relevant TS, and Entergys procedures.
Plant Walkdown and Radiation Work Permits (RWP) Reviews The inspectors toured accessible RCAs in the reactor building, turbine deck, condenser bay, radwaste building, re-tube building, and advance off-gas treatment building.
Radiation survey maps were reviewed and independent measurements were made to confirm the accuracy of survey data and the adequacy of postings.
The inspector identified radiological significant jobs scheduled to be performed in the drywell and other RCAs. The inspectors reviewed the applicable RWPs, as low as is reasonably achievable (ALARA) Plans, survey maps, and the electronic dosimeter dose/dose rate alarm set points, for the associated tasks, to determine if the radiological controls were acceptable and if the set points were consistent with plant policy. Drywell jobs reviewed included removal of shield blocks from the N1B nozzle (RWP 2013-536),mounting accelerometers on a safety relief valve (RWP 2013-506), and removing shielding from under the reactor vessel (RWP 2013-501). Jobs reviewed in other RCAs included reactor cavity decontamination (RWP 2013-490) in the refueling area and condenser bay scaffolding demobilization (RWP 2013-481).
For the drywell jobs reviewed, the inspectors observed use of the remote monitoring room to provide radiological safety oversight of work in progress. The inspectors observed job site dose rates, worker doses, and air monitoring readings to evaluate actual site radiological conditions, and the coordination of workers by the senior radiation protection technician in charge.
The inspectors attended the pre-job RWP briefings for removing shield blocks from the N1B nozzle and for decontaminating the reactor cavity, to determine if workers were properly informed, including discussions of past operating experiences, identification of the radiological conditions associated with their tasks, location of low dose waiting areas, industrial safety considerations, electronic dosimetry dose/dose rate set points, and dose mitigation measures.
The inspectors evaluated the effectiveness of contamination controls for various outage projects by reviewing personnel contamination event reports, condition reports, and observing monitoring practices at various work locations at the main control point.
High Radiation Area and Very High Radiation Area Controls The inspectors reviewed procedures related to the control of high radiation areas and very high radiation areas. The inspectors discussed these procedures with Radiation Protection Supervision to determine that any changes made to these procedures.
During plant tours, LHRAs located in various plant areas were verified to be properly secured and posted and the keys accounted for.
The inspectors reviewed the preparations made for various potentially high dose rate jobs including reactor cavity decontamination and under vessel shielding removal. This review included evaluating the effectiveness of contamination control measures, source term controls, the use of temporary shielding, and use of the remote monitoring system.
Radiation Worker and Radiation Protection Technician Performance During tours of RCAs, the inspectors questioned radiation workers and radiation protection technicians regarding the radiological conditions at the work site and the radiological controls that applied to their task. Additionally, radiological-related condition reports, 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 various Nuclear Oversight audits and field observation reports, and relevant condition reports. The inspector evaluated whether problems were identified in a timely manner, that an extent of condition and cause evaluation were performed when appropriate, and corrective actions were appropriate to preclude repetitive problems
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
During the period of May 6 - 9, the inspectors conducted the following activities to verify that Entergy was properly implementing operational, engineering, and administrative controls to maintain personnel exposure ALARA for activities performed during the refueling outage. 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, and the ongoing exposure challenges for the outage.
The inspectors reviewed the ALARA plans for various outage projects.
The inspectors reviewed the specific ALARA Plans and associated RWPs for all outage projects that exceeded 5 person-rem estimated exposure. This review included:
scaffolding installation/removal (RWP 2013-481), reactor disassembly/reassembly (RWP 2013-485), shielding installation/removal (RWP 2013-501), valve maintenance and modifications in the drywell (RWP 2013-506), insulation removal/installation (RWP2013-539) and control rod drive exchange (RWP 2013-509). In reviewing these projects, the inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems. The evaluation was accomplished by interviewing site staff, and reviewing outage Station ALARA Managers Committee (AMC) meeting minutes.
Verification of Dose Estimates The inspectors reviewed the assumptions and basis for the RFO-19 outage ALARA dose estimates. The inspectors also reviewed the revisions made to various outage project dose estimates that resulted from exposure challenges presented to the AMC.
The inspectors reviewed Entergys procedures associated with monitoring and re-evaluating dose estimates when the forecasted cumulative exposure for tasks was approached, and the implementation of these procedures during the outage. In particular, the inspectors evaluated the in-progress reviews for tasks that exceeded 40 percent and 80 percent of their estimated doses including scaffolding installation, control rod drive exchange, valve work in the drywell, reactor vessel disassembly, and shielding installation.
The inspectors reviewed the exposures for the ten
- (10) workers who received the highest doses for the refueling outage to confirm that no individual exceeded the regulatory annual limit or the performance indicator criteria. Included in this review were the dose extension authorizations for workers who would exceed Entergys administrative dose limit.
Job Site Inspections The inspectors reviewed the exposure controls specified in ALARA Plans and RWPs for reactor cavity decontamination and shield block removal from the N1B reactor nozzle.
The inspectors attended pre-job ALARA briefings for these activities and observed aspects of these jobs using the remote monitoring system.
During plant tours, the inspectors observed workers remove scaffolding and demobilize equipment from various RCAs. Workers were questioned regarding their knowledge of job site radiological conditions, the ALARA measures applied to their tasks, and contamination control.
Source Term Reduction and Control The inspectors reviewed the status and historical trends for the plant source term.
Through a review of survey maps and interviews with the ALARA Supervisor, the inspectors evaluated recent source term measurements and control strategies. Specific strategies being employed included increasing reactor water cleanup flow, utilizing underwater demineralizers during cavity flood up, system flushes, and use of temporary shielding.
The inspectors assessed the effectiveness of temporary shielding by reviewing pre- and post-installation radiation survey data for shielding the under vessel drain line, the A and B feedwater check valves, the N1A reactor nozzle, and the recirculation system ring header.
Problem Identification and Resolution The inspectors reviewed elements of Entergys CAP, including field observations by the Nuclear Oversight Department, related to implementing the ALARA program to determine if problems were being entered into the program for timely resolution.
Condition reports 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
During the period of May 6 - 9, the inspectors conducted the following activities to verify that in-plant radioactivity airborne concentrations were being controlled and monitored and that the use of respiratory protection devices was appropriately specified and used.
Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 and Entergys procedures.
Engineering Controls The inspectors reviewed air sampling records and readings from portable air monitoring systems (AMS-4) for on-going jobs to confirm that airborne contamination was properly monitored and controlled. During plant walk downs, the inspectors evaluated the operability of air monitoring equipment and verified that air samples were representative of the work environment. Additionally, the inspectors evaluated the use of engineering controls, such as portable high efficiency particulate air filtration/ventilation systems, to assure the systems were tested, operable and properly located for tasks involving contaminated systems, such as reactor head staging and for dry well work activities.
Use of Respiratory Protection Devices The inspectors evaluated the use of powered air purifying respirators as a contingency for specific tasks involving potential airborne contamination, including reactor cavity decontamination and that full body (delta) suits were appropriately used for high contamination work; e.g. control rod drive replacements. The inspectors evaluated ALARA analyses that were performed to justify that the respirators would not be beneficial in minimizing worker dose.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
During the period of May 6 - 9, the inspectors conducted the following activities to verify that the occupational dose was appropriately monitored and that the processes were effectively carried out in determining internal dose to assure that the total effective dose equivalent was accurately measured. Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 and Entergys procedures.
External Dosimetry The inspectors assessed the implementation of dosimetry procedures including: routine thermoluminescent dosimeter issuance, multi-badging, and extremity dosimeter use.
The inspectors verified that procedural controls were in place for external effective dose equivalent determinations, that would be used for high dose gradient tasks; e.g. control rod drive mechanism replacement and reactor nozzle ISIs.
The inspectors reviewed authorizations for extending the dose limits for specific workers to verify that the workers past dose history was evaluated and that the appropriate level of management approved the new limit. The inspectors reviewed dose records for the 10 highest exposures occurring during 2013 to determine if the dose was appropriately authorized and that regulatory limits were not exceeded.
The inspectors reviewed condition reports related to electronic dose and dose rate alarms received on electronic dosimetry to determine if the cause of the alarm was properly determined. Additionally, the inspectors evaluated the resulting dose to determine if performance indicator criteria were met for unplanned exposures.
Internal Dosimetry The inspectors evaluated the dose assessments for contaminated individuals who had the potential for inhaling radioactive material. The inspectors reviewed the whole body counting data, dose calculations, and independently estimated the resultant dose.
Declared Pregnant Workers The inspectors assessed the program for controlling and restricting the dose to declared pregnant workers, who had access to performing outage related activities.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
=
.1 Safety System Functional Failures
a. Inspection Scope
The inspectors sampled Entergys submittals for the Safety System Functional Failures performance indicators for the period of January 1, 2012, through December 31, 2012.
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 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73. The inspectors reviewed Entergys plant logs, condition reports, licensee event reports (LERs), and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 RCS Specific Activity and RCS Leak Rate
a. Inspection Scope
The inspectors reviewed Entergys submittal for the RCS specific activity and RCS leak rate performance indicators for the period of April 1, 2012, through March 31, 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. 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.
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 their 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 their CAP and periodically attended condition report 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 condition reports written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily condition report 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.
One new trend is discussed below.
Equipment Reliability Equipment reliability issues resulting in plant transients have been identified as a trend by the inspectors and Entergy. Specifically, the Engineering Director initiated CR-PNP-2012-0239 to conduct a cause evaluation of equipment reliability issues from 2011 and into 2012.
.3 Annual Sample: Review of a Tagout Error Documented in CR-PNP-2012-1930
a. Inspection Scope
The inspectors selected condition report CR-PNP-2012-1930, which documented high pressure coolant injection system work that was performed without anyone signing on to the tagout. The inspectors assessed Entergys extent of condition review and whether the planned or completed actions were appropriate. Additionally, the inspectors reviewed subsequent condition reports addressing tagout errors generated over the past year to determine if corrective actions were effective and whether an appropriate extent of condition of tagging errors was conducted.
b. Findings and Observations
No findings were identified.
The inspectors determined that the immediate actions taken in response to this error were appropriate.
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 performance during a loss of all annunciator capability on May 3, 2013 Operator response to a report of a fire on the 51 elevation of the turbine building on May 7, 2013 Operator response to a fire in the turbine auxiliary lube oil pump room on May 20, 2013 Operator performance during power movement to support a main condenser thermal backwash on June 27, 2013
.2 (Closed) LER 05000293/2013-001-00: Inadvertent Trip of Both Recirculation Pumps and
Subsequent Manual Scram On January 10, 2013, both reactor recirculation pumps tripped and a manual scram was inserted. Operators responded to the event and all plant systems responded as designed. A follow-up investigation determined that a plant relay was inadvertently energized during restoration from surveillance testing. Procedure changes and training have been implemented to prevent this event from recurring. The LER was reviewed.
No findings or violations of NRC requirements were identified. This LER is closed.
4OA6 Meetings, Including Exit
On July 18, 2013, the inspectors presented the inspection results to Steve Verrochi, General Manager Plant Operations, and other members of 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
B. Ahern Electrical System Engineer
G. Blankenbiller Chemistry Manager
G. Bradley Component Engineer
S. Brewer Radiation Protection Manager
D. Brugman Supervisor ALARA/Technical Support
D. Burke Security Manager
B. Chenard Engineering Director
J. Couto Senior Reactor Operator
J. Cox Radiation Protection Operations Supervisor
M. Dagnello Superintendent FIN Team
K. Drown Nuclear Oversight and Recovery Manager
J. Falconieri Senior Lead Engineer
J. Fitzsimmons Radiation Protection Supervisor
M. Gatslick Security Compliance Supervisor
R. Hargat Radiation Protection Technician
W. Lobo Compliance Engineer
J. Lynch Licensing Manager
J. Macdonald Operations Manager
D. Mannai Senior Manager Nuclear Safety and Licensing
W. Mauro Supervisor Radiation Protection Support
T. McElhinney Training Manager
A. Muse Superintendent Operations Training
J. Norris Radiological Engineer
D. Noyes Nuclear Safety Assurance Director
J. Ohrenberger Maintenance Manager
J. Priest Emergency Preparedness Manager
- J. Scheffer Specialist, Effluent & Environmental Monitoring
W. Smith Chemistry Supervisor
M. Thornhill Radiation Protection Supervisor
S. Verrochi General Manager Plant Operations
T. F. White Design Engineering Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000293/2013005-01 NCV Failure to Follow Procedures Results in Loss of Shutdown Cooling (Section 1R20)
Closed
005000293/2013-001-00 LER Inadvertent Trip of Both Recirculation Pumps and Subsequent Manual Scram (section 4OA3)