IR 05000293/2017004: Difference between revisions
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Mr. Brian Sullivan Site Vice President Entergy Nuclear Operations, Inc. | Mr. Brian Sullivan Site Vice President Entergy Nuclear Operations, Inc. | ||
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 | Pilgrim Nuclear Power Station | ||
600 Rocky Hill Road Plymouth, MA 02360-5508 | |||
SUBJECT: PILGRIM NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000293/2017004 | SUBJECT: PILGRIM NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000293/2017004 | ||
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No NRC-identified or self-revealing findings were identified during this inspection. | No NRC-identified or self-revealing findings were identified during this inspection. | ||
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 Code of Federal Regulations (CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding." | This letter, its enclosure, and your response (if any) will be made available for public inspection | ||
and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 Code of Federal Regulations (CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding." | |||
Sincerely,/RA/ Anthony Dimitriadis, Chief Reactor Projects Branch 5 | |||
Division of Reactor Projects Docket No. 50-293 License No. DPR-35 | |||
===Enclosure:=== | ===Enclosure:=== | ||
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Supplementary Information cc w/encl: Distribution via ListServ | Supplementary Information cc w/encl: Distribution via ListServ | ||
ML18045A058 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME JKrafty LCline via email ADimitriadis DATE 2/14/18 2/13/18 2/14/18 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I | ML18045A058 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME JKrafty LCline via email ADimitriadis DATE 2/14/18 2/13/18 2/14/18 | ||
1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I | |||
Report No.: 05000293/2017004 Licensee: Entergy Nuclear Operations, Inc. (Entergy) | Docket No: 50-293 | ||
License No: DPR-35 | |||
Report No.: 05000293/2017004 | |||
Licensee: Entergy Nuclear Operations, Inc. (Entergy) | |||
Facility: Pilgrim Nuclear Power Station (PNPS) | Facility: Pilgrim Nuclear Power Station (PNPS) | ||
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Dates: October 1, 2017 through December 31, 2017 | Dates: October 1, 2017 through December 31, 2017 | ||
Inspectors: E. Carfang, Senior Resident Inspector P. Cataldo, Acting Senior Resident Inspector J. Krafty, Acting Senior Resident Inspector B. Pinson, Resident Inspector P. Boguszewski, Project Engineer J. Ambrosini, Senior Emergency Preparedness Inspector B. Dionne, Health Physicist D. Silk, Senior Operations Engineer J. DeBoer, Emergency Preparedness Inspector M. Orr, Reactor Inspector J. Vazquez, Project Engineer S. Elkhiamy, Reactor Inspector Approved By: Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects | Inspectors: E. Carfang, Senior Resident Inspector P. Cataldo, Acting Senior Resident Inspector J. Krafty, Acting Senior Resident Inspector B. Pinson, Resident Inspector P. Boguszewski, Project Engineer J. Ambrosini, Senior Emergency Preparedness Inspector B. Dionne, Health Physicist D. Silk, Senior Operations Engineer J. DeBoer, Emergency Preparedness Inspector M. Orr, Reactor Inspector J. Vazquez, Project Engineer S. Elkhiamy, Reactor Inspector | ||
Approved By: Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects | |||
2 | 2 | ||
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IR 05000293/2017004; 10/01/2017 to 12/31/2017; PNPS; Routine Integrated Inspection Report | IR 05000293/2017004; 10/01/2017 to 12/31/2017; PNPS; Routine Integrated Inspection Report | ||
This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6. Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity | This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6. | ||
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity No findings were identified. | |||
4 | 4 | ||
=REPORT DETAILS= | =REPORT DETAILS= | ||
Summary of Plant Status Pilgrim began the inspection period at 100 percent power. On October 24, 2017, operators reduced power to approximately 45 percent for a planned main condenser thermal backwash. | |||
===Summary of Plant Status=== | |||
Pilgrim began the inspection period at 100 percent power. On October 24, 2017, operators reduced power to approximately 45 percent for a planned main condenser thermal backwash. | |||
Operators returned the unit to 100 percent on October 25, 2017 and remained at or near 100 percent power for the remainder of the inspection period. Documents reviewed for each section of this inspection report are listed in the Attachment. | Operators returned the unit to 100 percent on October 25, 2017 and remained at or near 100 percent power for the remainder of the inspection period. Documents reviewed for each section of this inspection report are listed in the Attachment. | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1R04}} | {{a|1R04}} | ||
==1R04 Equipment Alignment | ==1R04 Equipment Alignment== | ||
Partial System Walkdowns (71111.04 - 3 samples) | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors performed partial walkdowns of the following systems: | The inspectors performed partial walkdowns of the following systems: | ||
High pressure coolant injection (HPCI) walk down during reactor core isolation cooling (RCIC) system outage on November 1, 2017 | |||
High pressure coolant injection (HPCI) walk down during reactor core isolation cooling (RCIC) system outage on November 1, 2017 | |||
'A' residual heat removal (RHR) during 'B' RHR maintenance on November 15, 2017 Instrument air with temporary air compressor in service on November 16, 2017 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the FSAR, TSs, work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the system's performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of t he 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. | ||
{{a|1R05}} | |||
==1R05 Fire Protection== | |||
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples) | |||
====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 station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures. | 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. | |||
Standby liquid control room on October 10, 2017 | Standby liquid control room on October 10, 2017 | ||
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==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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===.1 Quarterly Review of Licensed Operator Requalification Testing and Training=== | ===.1 Quarterly Review of Licensed Operator Requalification Testing and Training=== | ||
(71111.11Q - 1 sample) | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors observed licensed operator simulator training on October 23, 2017, which included a fire on the standby gas treatment (SBGT) system, a stuck open safety relief valve (SRV) and a failure to scram following hydraulic binding of control rods. The scenario required declaration of a general emergency. 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. | The inspectors observed licensed operator simulator training on October 23, 2017, which included a fire on the standby gas treatment (SBGT) system, a stuck open safety relief valve (SRV) and a failure to scram following hydraulic binding of control rods. The scenario required declaration of a general emergency. 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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The following inspection activities were performed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 11, and Inspection Procedure Attachment 71111.11, "Licensed Operator Requalification Program." | The following inspection activities were performed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 11, and Inspection Procedure Attachment 71111.11, "Licensed Operator Requalification Program." | ||
Examination Results | Examination Results On December 13, 2017, the results of the annual operating tests were reviewed to | ||
determine if pass/fail rates were consistent with the guidance of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 11, and NRC Inspection Manual Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process." The review verified that the failure rate (individual or crew) did not exceed 20 percent. | |||
One out of 54 operators failed at least one section of the Annual Exam. The overall individual failure rate was 1.8 percent. | |||
Zero out of eight crews failed the simulator test. The crew failure rate was 0.0 percent. | |||
Observations were made of the dynamic simulator exams and job performance measures (JPMs) administered during the week of September 25, 2017. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of JPMs. | |||
Written Examination Quality The inspectors reviewed two written examinations administered during the 2016 examination cycle for qualitative and quantitative attributes as specified in Appendix B of 71111.11, "Licensed Operator Requalification." There was no written examination administered in 2017. | |||
Operating Test Quality Ten JPMs and six scenarios for the operating tests for the weeks of September 18 and September 25, 2017, were reviewed for qualitative and quantitative attributes as specified in Appendix C of 71111.11, "Licensed Operator Requalification Program." | |||
Licensee Administration of Operating Tests | |||
Observations were made of the dynamic simulator exams and JPMs administered during the week of September 25, 2017. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of JPMs. | |||
Examination Security | |||
The inspectors assessed whether facility staff properly safeguarded exam material. | |||
JPMs, scenarios, and written examinations were checked for excessive overlap of test items. | JPMs, scenarios, and written examinations were checked for excessive overlap of test items. | ||
Remedial Training and Re-Examinations | Remedial Training and Re-Examinations | ||
Proficiency watch standing records were reviewed for the second quarter of 2017. All active licensed operators met the watch standing requirements to maintain an active license. | No remediation plans or examinations were reviewed because there were no recent | ||
failures. | |||
Conformance with Operator License Conditions | |||
Medical records for nine senior reactor operator licenses and six reactor operator licenses were reviewed to assess conformance with license conditions. All records reviewed were satisfactory. | |||
Proficiency watch standing records were reviewed for the second quarter of 2017. All active licensed operators met the watch standing requirements to maintain an active | |||
license. | |||
The reactivation plan for three licensed operators were reviewed to assess the effectiveness of the reactivation process. The reactivations were processed in accordance with site procedures. | The reactivation plan for three licensed operators were reviewed to assess the effectiveness of the reactivation process. The reactivations were processed in accordance with site procedures. | ||
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Records for the participation of licensed operators in the requalification program for 2017 were reviewed. Records for the performance of licensed operators on annual requalification operating test and biennial requalification written exams were reviewed. | Records for the participation of licensed operators in the requalification program for 2017 were reviewed. Records for the performance of licensed operators on annual requalification operating test and biennial requalification written exams were reviewed. | ||
Simulator Performance | Simulator Performance Simulator performance and fidelity were reviewed for conformance to the reference plant control room. A sample of simulator deficiency reports was also reviewed to ensure facility staff addressed identified modeling problems. Simulator test documentation was | ||
Problem Identification and Resolution A review was conducted of recent operating history documentation found in inspection reports, the licensee's CAP, and the most recent NRC plant issues matrix. The inspectors also reviewed specific events from the licensee's CAP which indicated possible training deficiencies to verify that they had been appropriately addressed. The senior resident inspector was also consulted for insights regarding licensed operators' performance. These reviews did not detect any operational events that were indicative of possible training deficiencies. | also reviewed. | ||
Problem Identification and Resolution | |||
A review was conducted of recent operating history documentation found in inspection | |||
reports, the licensee's CAP, and the most recent NRC plant issues matrix. The inspectors also reviewed specific events from the licensee's CAP which indicated possible training deficiencies to verify that they had been appropriately addressed. The senior resident inspector was also consulted for insights regarding licensed operators' performance. These reviews did not detect any operational events that were indicative of possible training deficiencies. | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on the risk significance of the associated components and systems: | The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on the risk significance of the associated components and systems: | ||
HPCI low oil level on September 28, 2017 Dual indication on 'A' RHR primary containment isolation valve on October 4, 2017 Damper position alarm on 'B' EDG on October 11, 2017 Recirculation pump speed limiter deviation from FSAR values on November 15, 2017 | |||
HPCI low oil level on September 28, 2017 Dual indication on 'A' RHR primary containment isolation valve on October 4, 2017 Damper position alarm on 'B' EDG on October 11, 2017 Recirculation pump speed limiter deviation from FSAR values on November 15, 2017 The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and FSAR to Entergy's evaluations to determine whether the | |||
components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Entergy. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1R18}} | {{a|1R18}} | ||
==1R18 Plant Modifications== | ==1R18 Plant Modifications== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the piping modifications to accommodate the temporary air compressor implemented by EC 74577. The inspectors evaluated 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 | The inspectors reviewed the piping modifications to accommodate the temporary air compressor implemented by EC 74577. | ||
The inspectors evaluated 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 modifi cations to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems. | |||
====b. Findings==== | ====b. Findings==== | ||
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====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 TSs, the FSAR, and Entergy procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests: | The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the FSAR, and Entergy procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests: | ||
8.5.5.8, RCIC overspeed trip test on September 27, 2017 8.M.2-1.5.3.4, Primary containment isolation logic channel test, channel B2, on October 19, 2017 8.7.4.4, Main steam isolation valve operability on October 24, 2017 (in-service test) 8.E.13, RCIC system instrument calibration on November 1, 2017 8.M.2-2.10.4.3, HPCI simulated automatic actuation on November 7, 2017 | 8.5.5.8, RCIC overspeed trip test on September 27, 2017 8.M.2-1.5.3.4, Primary containment isolation logic channel test, channel B2, on October 19, 2017 8.7.4.4, Main steam isolation valve operability on October 24, 2017 (in-service test) 8.E.13, RCIC system instrument calibration on November 1, 2017 8.M.2-2.10.4.3, HPCI simulated automatic actuation on November 7, 2017 | ||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. Cornerstone: Emergency Preparedness | No findings were identified. | ||
===Cornerstone:=== | |||
Emergency Preparedness | |||
{{a|1EP2}} | {{a|1EP2}} | ||
==1EP2 Alert and Notification System Evaluation== | ==1EP2 Alert and Notification System Evaluation== | ||
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====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|1EP4}} | {{a|1EP4}} | ||
==1EP4 Emergency Action Level and Emergency Plan Changes== | ==1EP4 Emergency Action Level and Emergency Plan Changes== | ||
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Entergy implemented various changes to the Pilgrim Emergency Action Levels (EALs), Emergency Plan, and Implementing Procedures. Entergy had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR Part 50, Appendix E. | Entergy implemented various changes to the Pilgrim Emergency Action Levels (EALs), Emergency Plan, and Implementing Procedures. Entergy had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR Part 50, Appendix E. | ||
The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by Entergy as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements listed in 10 CFR 50.54(q) were used as reference criteria. | The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by Entergy as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements listed in 10 CFR 50.54(q) were used as | ||
reference criteria. | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors evaluated the efficacy of efforts to maintain the Pilgrim emergency preparedness program. The inspectors reviewed: memoranda of agreement with offsite agencies; procedures for the 10 CFR 50.54(q) Emergency Plan change process; Pilgrim's maintenance of equipment important to emergency preparedness; records of evacuation time estimate population evaluation; and provisions for, and implementation of, primary, backup, and alternative emergency response facility maintenance. The inspectors also verified compliance with NRC regulations regarding: emergency action levels for hostile action events, protective actions for on-site personnel during events, emergency declaration timeliness, ERO augmentation and alternate facility capability, evacuation time estimate updates, on-shift ERO staffing analysis, and ANS back-up means. | The inspectors evaluated the efficacy of efforts to maintain the Pilgrim emergency preparedness program. The inspectors reviewed: memoranda of agreement with offsite agencies; procedures for the 10 CFR 50.54(q) Emergency Plan change process; Pilgrim's maintenance of equipment important to emergency preparedness; records of evacuation time estimate population evaluation; and provisions for, and implementation of, primary, backup, and alternative emergency response facility maintenance. The | ||
inspectors also verified compliance with NRC regulations regarding: emergency action levels for hostile action events, protective actions for on-site personnel during events, emergency declaration timeliness, ERO augmentation and alternate facility capability, evacuation time estimate updates, on-shift ERO staffing analysis, and ANS back-up means. | |||
The inspectors further evaluated the ability to maintain Pilgrim's emergency preparedness program through their identification and correction of weaknesses, by reviewing a sample of drill reports, self-assessments, condition reports, and 10 CFR 50.54(t) reviews since the last NRC emergency preparedness program inspection in March 2015. | The inspectors further evaluated the ability to maintain Pilgrim's emergency preparedness program through their identification and correction of weaknesses, by reviewing a sample of drill reports, self-assessments, condition reports, and 10 CFR 50.54(t) reviews since the last NRC emergency preparedness program inspection in March 2015. | ||
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The inspectors evaluated the conduct of routine Entergy emergency drills on October 23, 2017 and November 7, 2017, to identify any potential weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. | The inspectors evaluated the conduct of routine Entergy emergency drills on October 23, 2017 and November 7, 2017, to identify any potential weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. | ||
The inspectors also attended the station drill critique to compare inspector observations with those identified by Entergy staff in order to evaluate Entergy's critique and to verify whether the Entergy staff was properly identifying weaknesses and entering them into the CAP. | The inspectors also attended the station drill critique to compare inspector observations with those identified by Entergy staff in order to evaluate Entergy's critique and to verify whether the Entergy staff was properly identifying weaknesses and entering them into | ||
the CAP. | |||
====b. Findings==== | ====b. Findings==== | ||
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===Cornerstone:=== | ===Cornerstone:=== | ||
Public Radiation Safety | Public Radiation Safety | ||
{{a|2RS2}} | {{a|2RS2}} | ||
==2RS2 Occupational As Low As Is Reasonably Achievable Planning and Controls== | ==2RS2 Occupational As Low As Is Reasonably Achievable Planning and Controls== | ||
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The inspectors assessed Entergy's performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). | The inspectors assessed Entergy's performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). | ||
The inspectors used the requirements contained in 10 CFR 20, applicable Regulatory Guides (RGs), TSs, and procedures required by TSs as criteria for determining compliance. Implementation of ALARA and Radiological Work Control The inspectors reviewed radiological work controls and ALARA practices during the observation of in-plant work activities. The inspectors reviewed the results achieved against the intended ALARA estimates to confirm adequate implementation and oversight of radiological work controls. The inspectors also verified that post job reviews were performed for the refueling outage jobs and the lessons learned were captured in the Entergy CAP. | The inspectors used the requirements contained in 10 CFR 20, applicable Regulatory Guides (RGs), TSs, and procedures required by TSs as criteria for determining compliance. | ||
Implementation of ALARA and Radiological Work Control | |||
The inspectors reviewed radiological work controls and ALARA practices during the observation of in-plant work activities. The inspectors reviewed the results achieved against the intended ALARA estimates to confirm adequate implementation and oversight of radiological work controls. The inspectors also verified that post job reviews were performed for the refueling outage jobs and the lessons learned were captured in the Entergy CAP. | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the control of in-plant airborne radioactivity and the use of respiratory protection devices in these areas. The inspectors used the requirements in 10 CFR 20, RG 8.15, RG 8.25, NUREG/CR-0041, TSs, and procedures required by TSs as criteria for determining compliance. Self-Contained Breathing Apparatus (SCBA) for Emergency Use The inspectors reviewed the following: the status and surveillance records for three SCBAs staged in-plant for use during emergencies; Entergy's SCBA procedures and maintenance and test records; the refilling and transporting of SCBA air bottles; SCBA mask size availability; and the qualifications of personnel performing service and repair of this equipment. | The inspectors reviewed the control of in-plant airborne radioactivity and the use of respiratory protection devices in these areas. The inspectors used the requirements in 10 CFR 20, RG 8.15, RG 8.25, NUREG/CR-0041, TSs, and procedures required by TSs as criteria for determining compliance. | ||
Self-Contained Breathing Apparatus (SCBA) for Emergency Use | |||
The inspectors reviewed the following: the status and surveillance records for three SCBAs staged in-plant for use during emergencies; Entergy's SCBA procedures and maintenance and test records; the refilling and transporting of SCBA air bottles; SCBA mask size availability; and the qualifications of personnel performing service and repair of this equipment. | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed Entergy's submittal of the Mitigating Systems Performance Index for the following systems for the period of October 1, 2016 through September 30, 2017: | The inspectors reviewed Entergy's submittal of the Mitigating Systems Performance Index for the following systems for the period of October 1, 2016 through September 30, | ||
Emergency alternating current power system Cooling water tower | |||
2017: | |||
Emergency alternating current power system Cooling water tower To determine the accuracy of the performance indicator (PI) data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7. The inspectors also reviewed Entergy's operator narrative logs, | |||
CRs, mitigating system performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals. | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed data for the Pilgrim emergency preparedness PIs: (1) Drill and Exercise Performance (EP01); (2) ERO Drill Participation (EP02); and (3) ANS Reliability (EP03). The inspectors conducted the last NRC emergency preparedness inspection at Pilgrim in the fourth calendar quarter of 2016, so the inspectors reviewed supporting documentation from emergency preparedness drills and tests from the fourth calendar quarter of 2016 through the third calendar quarter of 2017, to verify the accuracy of the reported PI data. The inspectors | The inspectors reviewed data for the Pilgrim emergency preparedness PIs: (1) Drill and Exercise Performance (EP01); (2) ERO Drill Participation (EP02); and (3) ANS Reliability (EP03). The inspectors conducted the last NRC emergency preparedness inspection at Pilgrim in the fourth calendar quarter of 2016, so the inspectors reviewed supporting documentation from emergency preparedness drills and tests from the fourth calendar quarter of 2016 through the third calendar quarter of 2017, to verify the accuracy of the reported PI data. The inspectors conduct ed this review in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI | ||
Document 99-02, "Regulatory Assessment Perf ormance Indicator Guidelines," Revision | |||
===7. === | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed licensee submittals for the occupational radiological occurrences PI for the fourth quarter of 2016 through the first, second and third quarters of 2017. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Revision 7, to determine the accuracy of the PI data reported. The inspectors reviewed electronic personal dosimetry accumulated dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized PI occurrences. | The inspectors reviewed licensee submittals for the occupational radiological occurrences PI for the fourth quarter of 2016 through the first, second and third quarters of 2017. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Revision 7, to determine the accuracy of the PI data reported. The | ||
inspectors reviewed electronic personal dosimetry accumulated dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized PI occurrences. | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
As required by Inspection Procedure 71152, "Problem Identification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify Entergy entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Entergy performed an evaluation in accordance with 10 CFR Part 21. | As required by Inspection Procedure 71152, "Problem Identification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify Entergy entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Entergy performed an | ||
evaluation in accordance with 10 CFR Part 21. | |||
====b. Findings==== | ====b. Findings==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors performed a semi-annual review of site issues to identify trends that might indicate the existence of more significant safety concerns. As part of this review, the inspectors included repetitive or closely-related issues documented by Entergy in department trend reports, system health reports and MR assessments. The inspectors evaluated a sample of condition reports generated over the course of the past two quarters by departments that provide input to the quarterly trend reports with a focus on operations, maintenance and engineering. The inspectors also reviewed Entergy's CAP database for the third and fourth quarters of 2017 to assess condition reports written in various subject areas, as well as individual issues identified during the NRC's daily condition repot review (Section 4OA2.1). The inspectors reviewed Entergy's quarterly Department Performance Review Meeting and Aggregate Performance Review Meeting reports completed during the third quarter of 2017, conducted under EN-LI-121, "Trending and Performance Review Process," to verify that Entergy personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures. | The inspectors performed a semi-annual review of site issues to identify trends that might indicate the existence of more significant safety concerns. As part of this review, the inspectors included repetitive or closely-related issues documented by Entergy in department trend reports, system health reports and MR assessments. The inspectors evaluated a sample of condition reports generated over the course of the past two quarters by departments that provide input to the quarterly trend reports with a focus on operations, maintenance and engineering. The inspectors also reviewed Entergy's CAP database for the third and fourth quarters of 2017 to assess condition reports written in | ||
various subject areas, as well as individual issues identified during the NRC's daily condition repot review (Section 4OA2.1). The inspectors reviewed Entergy's quarterly Department Performance Review Meeting and Aggregate Performance Review Meeting reports completed during the third quarter of 2017, conducted under EN-LI-121, "Trending and Performance Review Process," to verify that Entergy personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures. | |||
====b. Findings and Observations==== | ====b. Findings and Observations==== | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed Entergy's corrective actions taken to address non-cited violation 05000293/2017001-03, Untimely Corrective Actions associated with Boraflex degradation in the Spent Fuel Pool. Specifically, the NRC had previously determined that Entergy had not established corrective actions to ensure that the SFP configuration would meet analysis-established limitations beyond September 2017. Following up on this issue, the inspectors reviewed corrective actions, subsequently developed by Entergy, to ensure that that these actions were adequately developed and implemented to maintain the SFP was maintained in a safe configuration. Inspectors reviewed updated operability determinations, a root cause evaluation, updated fuel move sheets for fuel moves taking place in 2017, revised fuel handling procedures, and documentation of the current SFP configuration. The current SFP configuration was assessed to ensure conformance with Entergy's criticality evaluation of record and compliance with station procedures. Inspectors also verified fuel assembly positions via a sample-based review of video recordings. Inspectors discussed with Entergy staff the reasoning behind the current SFP configuration and the fuel moves performed to ensure that implemented corrective actions were based on conservative assumptions. The inspectors assessed the prioritization and timeliness of Entergy's corrective actions to determine whether Entergy's completed and planned corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Entergy's CAP and 10 CFR Part 50, Appendix B | The inspectors reviewed Entergy's corrective actions taken to address non-cited violation 05000293/2017001-03, Untimely Corrective Actions associated with Boraflex degradation in the Spent Fuel Pool. Specifically, the NRC had previously determined that Entergy had not established corrective actions to ensure that the SFP configuration would meet analysis-established limitations beyond September 2017. Following up on this issue, the inspectors reviewed corrective actions, subsequently developed by Entergy, to ensure that that these actions were adequately developed and implemented to maintain the SFP was maintained in a safe configuration. | ||
Inspectors reviewed updated operability determinations, a root cause evaluation, updated fuel move sheets for fuel moves taking place in 2017, revised fuel handling procedures, and documentation of the current SFP configuration. The current SFP configuration was assessed to ensure conformance with Entergy's criticality evaluation of record and compliance with station procedures. Inspectors also verified fuel assembly positions via a sample-based review of video recordings. Inspectors discussed with Entergy staff the reasoning behind the current SFP configuration and the fuel moves performed to ensure that implemented corrective actions were based on conservative assumptions. The inspectors assessed the prioritization and timeliness of Entergy's corrective actions to determine whether Entergy's completed and planned corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Entergy's CAP and 10 CFR Part 50, Appendix B | |||
====b. Findings and Observations==== | ====b. Findings and Observations==== | ||
No findings were identified. | No findings were identified. | ||
After the NRC's previous inspection of this issue documented in NRC IR 050002932017001 (ML17136A015), Entergy rearranged the fuel in the SFP to ensure subcriticality could be maintained within regulatory limits beyond September 2017. This rearrangement was intended to ensure the SFP would remain subcritical only as a result of the spatial separation of the fissile material in the fuel, and not rely on the neutron absorption provided by the Boraflex panels. The inspectors' reviewed the vendor's analysis of the new spent fuel configuration and independently verified the final locations of a risk-informed sample of spent fuel cells after Entergy completed the required fuel moves. Based on these reviews the inspectors concluded that that the new configuration provided reasonable assurance that the SFP would be maintained in a safe condition, without further reconfiguration, as long as additional fuel is not added to the pool. | After the NRC's previous inspection of this issue documented in NRC IR 050002932017001 (ML17136A015), Entergy rearranged the fuel in the SFP to ensure subcriticality could be maintained within regulatory limits beyond September 2017. This rearrangement was intended to ensure the SFP would remain subcritical only as a result of the spatial separation of the fissile material in the fuel, and not rely on the neutron absorption provided by the Boraflex panels. The inspectors' reviewed the vendor's analysis of the new spent fuel configuration and independently verified the final locations of a risk-informed sample of spent fuel cells after Entergy completed the required fuel moves. Based on these reviews the inspectors concluded that that the new configuration provided reasonable assurance that the SFP would be maintained in a safe condition, without further reconfiguration, as long as additional fuel is not added to the | ||
pool. | |||
Inspectors noted two examples of Entergy staff demonstrating effective and proactive conservative decision-making practices. In one instance, Entergy staff had a more detailed evaluation performed that determined that the SFP configuration would meet the analysis-established limitations until November 2017 - as opposed to the initially established September 2017 date - in case there were unexpected delays in completing the necessary fuel moves. Nevertheless, the fuel moves and associated configuration verification were completed on August 24, 2017. In another instance, cells adjacent to the initially-discovered degraded panel were maintained empty or blocked, despite the fact that fuel storage in these cells would have been permissible in accordance with the criticality analysis of record. | Inspectors noted two examples of Entergy staff demonstrating effective and proactive conservative decision-making practices. In one instance, Entergy staff had a more detailed evaluation performed that determined that the SFP configuration would meet the analysis-established limitations until November 2017 - as opposed to the initially established September 2017 date - in case there were unexpected delays in completing the necessary fuel moves. Nevertheless, the fuel moves and associated configuration verification were completed on August 24, 2017. In another instance, cells adjacent to the initially-discovered degraded panel were maintained empty or blocked, despite the fact that fuel storage in these cells would have been permissible in accordance with the criticality analysis of record. | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors performed an in-depth review of Entergy's improvement plans to the MR and preventive maintenance (PM) programs. Specifically, the review focused on corrective actions associated with CR 2016-05555, which included Entergy's apparent cause evaluation for MR program implementation discrepancies. The inspectors also reviewed Entergy's corrective actions associated with CR 2016-09147, stemming from Entergy's PM program self-assessment to improve its maintenance strategies and address SSC wear, performance, reliability, and the effects of equipment aging. The inspectors reviewed Entergy's apparent cause evaluation associated with MR program problems identified and its self-assessment to understand the scope of the issues. This inspection focused on the tracking, prioritization, completion, and timeliness of Entergy's corrective actions resulting from these reviews to determine whether Entergy was appropriately correcting problems consistent with its potential safety significance, Entergy's CAP procedures and the requirements in 10 CFR Part 50, Appendix B. In addition, the inspectors interviewed engineering personnel to assess the effectiveness of the implemented corrective actions. | The inspectors performed an in-depth review of Entergy's improvement plans to the MR and preventive maintenance (PM) programs. Specifically, the review focused on corrective actions associated with CR 2016-05555, which included Entergy's apparent cause evaluation for MR program implementation discrepancies. The inspectors also reviewed Entergy's corrective actions associated with CR 2016-09147, stemming from Entergy's PM program self-assessment to improve its maintenance strategies and address SSC wear, performance, reliability, and the effects of equipment aging. | ||
The inspectors reviewed Entergy's apparent cause evaluation associated with MR program problems identified and its self-assessment to understand the scope of the issues. This inspection focused on the tracking, prioritization, completion, and timeliness | |||
of Entergy's corrective actions resulting from these reviews to determine whether Entergy was appropriately correcting problems consistent with its potential safety significance, Entergy's CAP procedures and the requirements in 10 CFR Part 50, Appendix B. In addition, the inspectors interviewed engineering personnel to assess the | |||
effectiveness of the implemented corrective actions. | |||
====b. Findings and Observations==== | ====b. Findings and Observations==== | ||
No findings were identified. | No findings were identified. | ||
The inspectors determined that Entergy staff identified two apparent causes to the MR program implementation discrepancies involving inadequate management oversight and dedicated resources to ensure successful implementation of the MR program. Entergy staff further identified contributing causes in four areas: change management during previous program transitions, rigor applied and maintained regarding MR documentation, MR related qualification requirements, and MR program oversight by engineering management. The inspectors concluded the evaluation scope appeared sufficient to identify the problems and reasonably | The inspectors determined that Entergy staff identified two apparent causes to the MR program implementation discrepancies involving inadequate management oversight and dedicated resources to ensure successful implementation of the MR program. Entergy staff further identified contributing causes in four areas: change management during previous program transitions, rigor applied and maintained regarding MR documentation, MR related qualification requirements, and MR program oversight by engineering management. The inspectors concluded the evaluation scope appeared sufficient to | ||
identify the problems and reasonably s upport corrective action development. | |||
With respect to the PM program, the inspectors determined Entergy identified implementation problems related to PM processes and procedures that could impact reliable equipment performance and ensure compliance with regulatory requirements (10 CFR 50.65). Entergy entered these issues into its CAP on March 24, 2016 (CR 2016-02056 and CR 2016-02061). Entergy staff developed a project plan to improve its PM program implementation. The plan included addressing component PM strategy deficiencies, improving the quality and technical rigor of PM program engineering products, and ensuring adequate PM strategies existed for critical station equipment. For critical station equipment where PM deficiencies were identified during its focused self-assessment, Entergy staff evaluated whether the equipment was vulnerable to failure due to the deficient or missing PMs, and developed and tracked mitigation actions as required. For equipment that was not specifically evaluated during the self-assessment, Entergy staff performed a risk-based review of PM recommendations to identify whether program vulnerabilities existed. | |||
The inspectors reviewed the prioritization, tracking, and completion of corrective actions and confirmed that timeliness of the corrective actions were commensurate with the potential safety significance of the issues. In cases where due dates were extended, the inspectors verified that extensions received the appropriate review in accordance with Entergy's corrective action procedure and that appropriate interim and/or compensatory measures were implemented to minimize the problem or mitigate the effects until permanent actions could be completed. | |||
The corrective actions to address the MR program implementation were tracked under CR-2016-05555. The inspectors reviewed corrective action priority and compensatory actions and determined they were appropriate. In particular, one corrective action related to ensuring the quality of maintenance rule functional failure (MRFF)determinations included compensatory measures to require the management review committee to review all MRFF evaluations until the MRFF coordinator refresher training was completed. The inspectors reviewed additional specific corrective actions, including the development of a database for MR scoped systems and a program notebook for centralized program information, the development of an MR Coordinator qualification card, and the training and qualification of engineers from different departments to ensure qualified back-ups. Finally, the inspectors noted that Entergy was tracking and providing oversight for the overall completion of the MR program improvement plan. The inspectors concluded Entergy's planned actions in these areas were reasonable. | The corrective actions to address the MR program implementation were tracked under CR-2016-05555. The inspectors reviewed corrective action priority and compensatory actions and determined they were appropriate. In particular, one corrective action related to ensuring the quality of maintenance rule functional failure (MRFF)determinations included compensatory measures to require the management review committee to review all MRFF evaluations until the MRFF coordinator refresher training was completed. The inspectors reviewed additional specific corrective actions, including the development of a database for MR scoped systems and a program notebook for centralized program information, the development of an MR Coordinator qualification card, and the training and qualification of engineers from different departments to ensure qualified back-ups. Finally, the inspectors noted that Entergy was tracking and providing oversight for the overall completion of the MR program improvement plan. The inspectors concluded Entergy's planned actions in these areas were reasonable. | ||
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Specifically, inspectors reviewed CRs, causal evaluations, and other documents associated with two recent instances in which either TS requirements were not implemented as written, or the functions of safety related equipment were affected due to improper implementation of the requirements. | Specifically, inspectors reviewed CRs, causal evaluations, and other documents associated with two recent instances in which either TS requirements were not implemented as written, or the functions of safety related equipment were affected due to improper implementation of the requirements. | ||
The inspectors reviewed the details of Entergy's discovery that it was not complying with TS requirements for control room habitability testing. Specifically, from November 2008 until October 2016 the Pilgrim control room envelope was not pressure tested in accordance with the TS requirements. The inspectors also reviewed the fact that Entergy operators had performed a refueling outage surveillance test while at 97 percent power, which inappropriately removed the safety function of the SBGT system, and rendered the secondary containment system inoperable. This occurrence was | The inspectors reviewed the details of Entergy's discovery that it was not complying with TS requirements for control room habitability testing. Specifically, from November 2008 until October 2016 the Pilgrim control room envelope was not pressure tested in accordance with the TS requirements. | ||
The inspectors also reviewed the fact that Entergy operators had performed a refueling outage surveillance test while at 97 percent power, which inappropriately removed the safety function of the SBGT system, and rendered the secondary containment system inoperable. This occurrence was previous ly discussed in NRC Inspection Report 05000293/2017002 (ML17226A015). | |||
The inspectors performed in-depth reviews of Entergy's evaluations, extent of condition, and associated corrective actions to ensure that the causes were understood and appropriate corrective actions were established. Additionally, the inspectors interviewed Entergy personnel involved in the causal evaluations. | The inspectors performed in-depth reviews of Entergy's evaluations, extent of condition, and associated corrective actions to ensure that the causes were understood and appropriate corrective actions were established. Additionally, the inspectors interviewed Entergy personnel involved in the causal evaluations. | ||
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The inspectors determined that Entergy's evaluations and extent of condition reviews were thorough, and the causes were appropriately identified. The inspectors also determined that the corrective actions were reasonable, timely, and addressed the concerns with improper implementation of TS requirements. | The inspectors determined that Entergy's evaluations and extent of condition reviews were thorough, and the causes were appropriately identified. The inspectors also determined that the corrective actions were reasonable, timely, and addressed the concerns with improper implementation of TS requirements. | ||
Inspectors reviewed the adverse condition analysis (ACA) associated with CR 2016-7901, "Control Room Envelope Test," and determined that the identified causal factors, the planned and taken corrective actions, and the extent of condition were adequate. Inspectors also reviewed the root cause evaluation (RCE) associated with CR 2017-2900, which investigated the April 2017 occurrence of the SBGT system being made unavailable for surveillance testing. Inspectors determined that the root cause, causal factors, planned and taken corrective actions, extent of condition, and extent of cause were adequate. Corrective actions to address the identified causes in the RCE included providing additional training to staff related to the implementation of TS requirements, procedure changes, and implementation of a more thorough review of upcoming work activities to ensure tasks involving safety-related equipment are performed in accordance with all license requirements. | Inspectors reviewed the adverse condition analysis (ACA) associated with CR 2016-7901, "Control Room Envelope Test," and determined that the identified causal factors, the planned and taken corrective actions, and the extent of condition were adequate. | ||
Inspectors also reviewed the root cause evaluation (RCE) associated with CR 2017-2900, which investigated the April 2017 occurrence of the SBGT system being made unavailable for surveillance testing. Inspectors determined that the root cause, causal factors, planned and taken corrective actions, extent of condition, and extent of cause were adequate. Corrective actions to address the identified causes in the RCE included providing additional training to staff related to the implementation of TS requirements, procedure changes, and implementation of a more thorough review of upcoming work activities to ensure tasks involving safety-related equipment are performed in accordance with all license requirements. | |||
Specifically, guidance was developed to ensure that technical specification surveillance tests, in-service inspections and in-service tests are completed in the correct mode of operation, completed at the correct frequency interval, satisfies all licensing basis requirements, and are completed without electively defeating a safety function that is required at the time of the test. Inspectors did not identify any issues in subsequent tests following implementation of the associated corrective actions. However, inspectors did note that Entergy staff identified, as part of the more thorough reviews, that an upcoming SBGT system test would have made both trains of the SBGT system inoperable had the test been performed as written. CRs 2017-11714 and 2017-12306 were written to document the issue, and CR 2017-2900 was revised to implement additional corrective actions as a result. | |||
In conclusion, inspectors determined that Entergy's causal evaluations, assessments, corrective actions, extents of condition and extents of cause were effective in identifying and correcting the associated TS surveillance requirements implementation issues. | |||
{{a|4OA3}} | {{a|4OA3}} | ||
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===.1 (Closed) Licensee Event Report (LER) 05000293/2017-005-00:=== | ===.1 (Closed) Licensee Event Report (LER) 05000293/2017-005-00:=== | ||
10 CFR 50, Appendix J, Option B, Leak Rate Criteria Exceeded | 10 CFR 50, Appendix J, Option B, Leak Rate Criteria Exceeded On April 10, 2017, the personnel airlock, X-2, failed to meet local leak rate test (LLRT) acceptance criteria of 0.05 L a during the as-found LLRT, and on April 22, 2017, two HPCI turbine exhaust check valves failed to meet LLRT acceptance criteria. The HPCI | ||
turbine check valve test failure was dispositioned in NRC inspection report 05000293/2017003 (ML17319A158), this LER assessment addresses the X-2 airlock LLRT failure. The inspectors' review of the test results determined that although the leak rate of the inner personnel airlock door exceeded the overall surveillance test acceptance criteria of 10.525 standard liters per minute, the outer personnel airlock door remained operable, and containment integrity was maintained consistent with TSs. In addition, the licensee determined that the cause of the personnel airlock leak test failure was the air lock pressure equalizing device (PED) sealing O-rings. During testing, the pressure was applied from outside the drywell, which is opposite of expected design basis conditions. This test method caused the PED to open, which caused O-ring extrusion and leakage through the airlock. During an actual event, increased post-accident pressures inside the drywell would tend to seal the inner door and its associated PED. Acceptable leakage values during testing ensure consistency with applicable TS and design basis requirements. Because the testing verified the outer door had maintained containment integrity, which ensured TS requirements were met, no violations were identified. The inspectors did not identify any new issues during the | |||
review of this LER. This LER is closed. | |||
===.2 (Closed) LER 05000293/2017-007-00:=== | ===.2 (Closed) LER 05000293/2017-007-00:=== | ||
Potential Inoperability of Safety Relief Valve 3A | Potential Inoperability of Safety Relief Valve 3A On April 24, 2017, following replacement of a pilot valve for safety-relief valve SV203-3A, electrical resistance testing of the associated solenoid circuit identified high resistance values greater than the acceptance criteria. Pilgrim staff entered the issue into the CAP, replaced the solenoid, and the solenoid was sent to a vendor for failure analysis. The inspectors reviewed the RCE, the failure analysis from Altran, as well as the independent review conducted by Exponent, Inc. The inspectors determined that reasonable engineering testing methodologies were utilized for the failure analyses, and that the results support the identified cause of the high resistance to be corrosion internal to the crimped connections for the solenoid coils. The underlying performance issue associated with the internal corrosion build-up was previously dispositioned in NRC inspection report 05000293/2017003 (ML17319A158). The inspectors did not identify any new issues during the review of this LER. This LER is closed. | ||
===.3 (Discussed) LER 05000293/2016-003-00, 2016-003-01, 2016-003-02:=== | ===.3 (Discussed) LER 05000293/2016-003-00, 2016-003-01, 2016-003-02:=== | ||
Spent Fuel Storage Design Feature Exceeded | Spent Fuel Storage Design Feature Exceeded In May 2016, Entergy identified degraded conditions on a Boraflex panel in the Pilgrim spent fuel pool (SFP). Further assessment of the conditions also led Entergy to determine that the current Technical Specification 4.3.1.1.a, which allows loading a fuel assembly with k-infinity as high as 1.32, may be non-conservative for racks with Boraflex panels. If a fuel bundle with a k-infinity of 1.32 were to be introduced into one of the locations affected by Boraflex degradation in the SFP, this could potentially challenge the capability of maintaining the overall criticality of the pool (k-effective) below the limit of 0.95, established by Pilgrim Technical Specifications. | ||
NRC Administrative Letter 98-10 states that the discovery of an inadequate (e.g. non-conservative) Technical Specification value is to be considered a degraded or nonconforming condition, and that prompt corrective action to correct or resolve the condition must be taken in accordance with 10 CFR Part 50, Appendix B. The NRC expects that, following the imposition of administrative controls to address any associated safety concerns, an amendment to the Technical Specification will be submitted in a timely fashion. | NRC Administrative Letter 98-10 states that the discovery of an inadequate (e.g. non-conservative) Technical Specification value is to be considered a degraded or nonconforming condition, and that prompt corrective action to correct or resolve the condition must be taken in accordance with 10 CFR Part 50, Appendix B. The NRC expects that, following the imposition of administrative controls to address any associated safety concerns, an amendment to the Technical Specification will be submitted in a timely fashion. | ||
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The inspectors determined that these administrative controls were adequate to maintain the SFP in a safe condition. | The inspectors determined that these administrative controls were adequate to maintain the SFP in a safe condition. | ||
Furthermore, the inspectors reviewed Entergy's planned corrective actions to obtain a revised criticality safety analysis and submit an associated license amendment request. The revised criticality analysis is complex and unique for boiling water reactor SFPs, and will, therefore, require considerable time to complete. The criticality analysis is necessary to provide sufficient basis for the amendment request. The inspectors concluded that these actions, once completed, should be sufficient to resolve the non-conservatism in the technical specification, in accordance with Administrative Letter 98-10. | Furthermore, the inspectors reviewed Entergy's planned corrective actions to obtain a revised criticality safety analysis and submit an associated license amendment request. The revised criticality analysis is complex and unique for boiling water reactor SFPs, and will, therefore, require considerable time to complete. The criticality analysis is necessary to provide sufficient basis for the amendment request. The inspectors concluded that these actions, once completed, should be sufficient to resolve the non-conservatism in the technical specification, in accordance with Administrative Letter 98- | ||
10. | |||
The NRC will continue review of this issue to verify the adequate and timely development and submission of Entergy's planned amendment request and to ensure that Entergy continues to maintain the safe configuration of the SFP. Until the planned amendment request is submitted, the issue of a non-conservative technical specification cannot be considered fully resolved. Therefore, this LER remains open, pending further NRC review. | The NRC will continue review of this issue to verify the adequate and timely development and submission of Entergy's planned amendment request and to ensure that Entergy continues to maintain the safe configuration of the SFP. Until the planned amendment request is submitted, the issue of a non-conservative technical specification cannot be considered fully resolved. Therefore, this LER remains open, pending further NRC review. | ||
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Additional details regarding the NRC's evaluation of corrective actions taken by Entergy to address a previously identified safety concern associated with the SFP (NCV 05000293/2017001-03, Untimely Corrective Actions associated with Boraflex degradation in the Spent Fuel Pool) can be found in Section | Additional details regarding the NRC's evaluation of corrective actions taken by Entergy to address a previously identified safety concern associated with the SFP (NCV 05000293/2017001-03, Untimely Corrective Actions associated with Boraflex degradation in the Spent Fuel Pool) can be found in Section | ||
{{a|4OA2}} | {{a|4OA2}} | ||
==4OA2 of this inspection report. | ==4OA2 of this inspection== | ||
report. | |||
{{a|4OA6}} | {{a|4OA6}} | ||
==4OA6 Meetings, Including Exit== | ==4OA6 Meetings, Including Exit== | ||
On January 25, 2018, the inspectors presented the inspection results to Mr. Brian Sullivan, Site Vice President, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report. | |||
On January 25, 2018, the inspectors presented the inspection results to Mr. Brian Sullivan, Site Vice President, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in | |||
this report. | |||
ATTACHMENT: | ATTACHMENT: | ||
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: [[contact::K. Woods]], Engineering Supervisor | : [[contact::K. Woods]], Engineering Supervisor | ||
: [[contact::G. Zavard]], Radiation Protection Supervisor | : [[contact::G. Zavard]], Radiation Protection Supervisor | ||
: [[contact::A. Zelie]], Radiation Protection Manager | : [[contact::A. Zelie]], Radiation Protection Manager | ||
==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED== | ==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED== | ||
===Closed=== | ===Closed=== | ||
: [[Closes LER::05000293/LER-2017-005]]-00 LER 10 CFR 50, Appendix J, Option B, Leak Rate Criteria Exceeded (Section 4OA3.1) | : [[Closes LER::05000293/LER-2017-005]]-00 LER 10 CFR 50, Appendix J, Option B, Leak Rate | ||
: [[Closes LER::05000293/LER-2017-007]]-00 LER Potential Inoperability of Safety Relief Valve 3A (Section 4OA3.2) | : Criteria Exceeded (Section 4OA3.1) | ||
: [[Closes LER::05000293/LER-2017-007]]-00 LER Potential Inoperability of Safety Relief Valve 3A | |||
(Section 4OA3.2) | |||
===Discussed=== | ===Discussed=== | ||
: 05000293/2016-003-00, | : 05000293/2016-003-00, | ||
2016-003-01, 2016-003-02 LER Spent Fuel Storage Design Feature Exceeded | |||
(Section 4OA3.3) | |||
==LIST OF DOCUMENTS REVIEWED== | ==LIST OF DOCUMENTS REVIEWED== | ||
==Section 1R01: Adverse Weather Protection== | ==Section 1R01: Adverse Weather Protection== | ||
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: 8.C.42, Subcompartment Barrier Control Surveillance, Revision 30 | : 8.C.42, Subcompartment Barrier Control Surveillance, Revision 30 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2017-9784 2017-10810 2017-12450 | : 2017-9784 2017-10810 2017-12450 | ||
: Maintenance Orders/Work Orders | : Maintenance Orders/Work Orders | ||
: 488368 | : 488368 | ||
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: 1.17.1, Potential Seismic Interaction Hazards, Revision 14 | : 1.17.1, Potential Seismic Interaction Hazards, Revision 14 | ||
: 2.2.19, Residual Heat Removal, Revision 113 | : 2.2.19, Residual Heat Removal, Revision 113 | ||
: 2.2.21, High Pressure Injection System (HPCI), Revision 85 8.C.24, Operations Equipment Lube Surveillance, Revision 96 | : 2.2.21, High Pressure Injection System (HPCI), Revision 85 8.C.24, Operations Equipment Lube Surveillance, Revision 96 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2016-3780 2017-9683 2017-11587 | : 2016-3780 2017-9683 2017-11587 | ||
Line 575: | Line 714: | ||
: 5.5.2, Attachment 17, Radwaste Truck Lock El. 23, Revision 57 | : 5.5.2, Attachment 17, Radwaste Truck Lock El. 23, Revision 57 | ||
: 5.5.2, Attachment 21, Diesel Generator Building El. 23, Revision 57 | : 5.5.2, Attachment 21, Diesel Generator Building El. 23, Revision 57 | ||
: EN-DC-161, Control of Combustibles, Revision 17 | : EN-DC-161, Control of Combustibles, Revision 17 | ||
===Miscellaneous=== | ===Miscellaneous=== | ||
: Fire Hazards Analysis - Fire Area 1.9, Fire Zone 1.1, 'A' RHR and CS Pumps Quadrant Fire Hazards Analysis - Fire Area 1.9, Fire Zone 1.15, Standby Liquid Control Pumps & Equipment | : Fire Hazards Analysis - Fire Area 1.9, Fire Zone 1.1, 'A' RHR and CS Pumps Quadrant Fire Hazards Analysis - Fire Area 1.9, Fire Zone 1.15, Standby Liquid Control Pumps & | ||
: Equipment | |||
: Fire Protection Evaluation 37, Electrical Boxes Generic, Revision 4 | : Fire Protection Evaluation 37, Electrical Boxes Generic, Revision 4 | ||
: PNPS | : PNPS | ||
Line 605: | Line 745: | ||
: EN-TQ-210, Conduct of Simulator Training, Revision 10 | : EN-TQ-210, Conduct of Simulator Training, Revision 10 | ||
: OT-8, Operating Training Department Work Instruction, "Simulator Evaluation Guidelines", Revision 21 | : OT-8, Operating Training Department Work Instruction, "Simulator Evaluation Guidelines", Revision 21 | ||
: TQF-201-IM05, Remedial Training Plan, Revision 9 | : TQF-201-IM05, Remedial Training Plan, Revision 9 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2015-07787 2015-08073 2016-03226 2016-06447 2016-06635 2016-07224 | : 2015-07787 2015-08073 2016-03226 2016-06447 2016-06635 2016-07224 | ||
: 2016-07955 2017-00626 2017-01203 2017-02175 2017-02785 2017-03724 | : 2016-07955 2017-00626 2017-01203 2017-02175 2017-02785 2017-03724 | ||
: 2017-05692 2017-05746 | : 2017-05692 2017-05746 | ||
: Simulator-Related Test Documents 16-002, Manual Scram on High Reactor Level, Event Date 09/06/2016 | : Simulator-Related Test Documents 16-002, Manual Scram on High Reactor Level, Event Date 09/06/2016 | ||
: 17-001, Rapid Power Reduction due to Chloride Intrusion, Event Date 2/6/17 | : 17-001, Rapid Power Reduction due to Chloride Intrusion, Event Date 2/6/17 | ||
Line 618: | Line 758: | ||
: 5/23/2017 T.8 - CERT 1-2. TST - Simultaneous Trip of All Reactor Feed Pumps, Date Tested 5/25/2017 | : 5/23/2017 T.8 - CERT 1-2. TST - Simultaneous Trip of All Reactor Feed Pumps, Date Tested 5/25/2017 | ||
: T.8 - CERT 3-3. TST - MSIV Closure with SORV and No HP ECCS Injection, Date Tested | : T.8 - CERT 3-3. TST - MSIV Closure with SORV and No HP ECCS Injection, Date Tested | ||
: 5/18/2017 | : 5/18/2017 | ||
===Miscellaneous=== | ===Miscellaneous=== | ||
: 2016 LORT Biennial Exam Test #3 RO | : 2016 LORT Biennial Exam Test #3 RO | ||
Line 639: | Line 779: | ||
: 10 CFR50.65 Maintenance Rule Scoping Basis Document for Neutron Monitoring Instrumentation, Revision 4 | : 10 CFR50.65 Maintenance Rule Scoping Basis Document for Neutron Monitoring Instrumentation, Revision 4 | ||
: Maintenance Rule (a)(1) Action Plan- Pilgrim Station, Revision 0 MRBD30A, RBCCW System 30A, Revision 4 Pilgrim Periodic Maintenance Effectiveness Assessment A Requirement of 10CFR50.65 (a)(3) | : Maintenance Rule (a)(1) Action Plan- Pilgrim Station, Revision 0 MRBD30A, RBCCW System 30A, Revision 4 Pilgrim Periodic Maintenance Effectiveness Assessment A Requirement of 10CFR50.65 (a)(3) | ||
: Operating Cycle 21 | : Operating Cycle 21 | ||
: System Health Report Power Range Neutron Monitoring, dated November 2017 | : System Health Report Power Range Neutron Monitoring, dated November 2017 | ||
Line 655: | Line 795: | ||
: 2.2.19.1, Residual Hear Removal System - Shutdown Cooling Mode of Operation, Revision 43 8.5.2.6, RHR Motor-Operated Valve Operability from Alternate Shutdown Panel, Revision 29 8.C.24, Operations Equipment Lube Surveillance, Revision 96 | : 2.2.19.1, Residual Hear Removal System - Shutdown Cooling Mode of Operation, Revision 43 8.5.2.6, RHR Motor-Operated Valve Operability from Alternate Shutdown Panel, Revision 29 8.C.24, Operations Equipment Lube Surveillance, Revision 96 | ||
: 8.M.2-1.5.6, RWCU Valves Inboard and Outboard Relay Logic Test - Critical Maintenance, Revision 31 | : 8.M.2-1.5.6, RWCU Valves Inboard and Outboard Relay Logic Test - Critical Maintenance, Revision 31 | ||
: EN-OP-104, Operability Determination Process, Revision 14 | : EN-OP-104, Operability Determination Process, Revision 14 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2017-3044 2017-6197 2017-9152 2017-9652 2017-9683 2017-9748 | : 2017-3044 2017-6197 2017-9152 2017-9652 2017-9683 2017-9748 | ||
Line 671: | Line 811: | ||
: V2098, Terry Turbine Maintenance Guide, HPCI Application, Revision 4 | : V2098, Terry Turbine Maintenance Guide, HPCI Application, Revision 4 | ||
===Drawings=== | ===Drawings=== | ||
: E5004, Electrical Schematic Diagram, Containment Spray Motor Operated Valves, Revision 13 E5021, Electrical Schematic Diagram Reactor Water Cleanup System Isolation Valve, | : E5004, Electrical Schematic Diagram, Containment Spray Motor Operated Valves, Revision 13 E5021, Electrical Schematic Diagram Reactor Water Cleanup System Isolation Valve, Revision E10 M1N39-13 Sheet 1, Elementary Diagram Primary Containment Isolation System, Revision E20 M241 SH 1, Residual Heat Removal System, Revision 88 M244 SH 2, HPCI System Turbine Lube and Control Oil Subsystem, Revision 2 | ||
==Section 1R18: Plant Modifications== | ==Section 1R18: Plant Modifications== | ||
Line 680: | Line 819: | ||
: EN-DC-115, Engineering Change Process, Revision 9 | : EN-DC-115, Engineering Change Process, Revision 9 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2017-10877 2017-11073 | : 2017-10877 2017-11073 | ||
: Maintenance Orders/Work Orders | : Maintenance Orders/Work Orders | ||
: 415142 | : 415142 | ||
: 434551 | : 434551 | ||
: 487100 | : 487100 | ||
===Miscellaneous=== | ===Miscellaneous=== | ||
: 0099-0051-CGAP-001, MPR Commercial Grade Item/Service Acceptance Plan, Revision 0 | : 0099-0051-CGAP-001, MPR Commercial Grade Item/Service Acceptance Plan, Revision 0 | ||
: 0099-0051-EE-001, Pilgrim Space Motor Operated Controllers, Revision 1 Instruction Manual | : 0099-0051-EE-001, Pilgrim Space Motor Operated Controllers, Revision 1 Instruction Manual | ||
: For Motor Operated Control, Revision A | : For Motor Operated Control, Revision A | ||
: CGI-EVAL-005, Basler Electric Motor | : CGI-EVAL-005, Basler Electric Motor Oper ated Controls Commercial Grade Evaluation, | ||
: Revision 10 | : Revision 10 | ||
: ECs 62735, 74577, 74246, 74553 | : ECs 62735, 74577, 74246, 74553 | ||
Line 709: | Line 848: | ||
: 8.5.3.2.1, Salt Service Water Pump Quarterly And Biennial (Comprehensive) Operability And | : 8.5.3.2.1, Salt Service Water Pump Quarterly And Biennial (Comprehensive) Operability And | ||
: 8.5.3.2.1, Salt Service Water Pump Quarterly And Biennial (Comprehensive) Operability And Valve Operability Tests, Revision 35 | : 8.5.3.2.1, Salt Service Water Pump Quarterly And Biennial (Comprehensive) Operability And Valve Operability Tests, Revision 35 | ||
: 8.9.16.1, Manually Start and Load Blackout | : 8.9.16.1, Manually Start and Load Blackout Dies el Via the Shutdown Transformer, Revision 54 8.M.2-2.10.2-3, RHR System High Drywell Pressure Auto-Initiation Trip System 'A', Revision 26 9.6, TIP System Operational Checkout, Revision 28 | ||
: 8.9.1, Emergency Diesel Generator and Associated Emergency Bus Surveillance, Revision 144 | : 8.9.1, Emergency Diesel Generator and Associated Emergency Bus Surveillance, Revision 144 | ||
: EN-DC-115, Engineering Change Process, Revision 9 | : EN-DC-115, Engineering Change Process, Revision 9 | ||
: EN-MA-125, Troubleshooting Control of Maintenance Activities, Revision 21 | : EN-MA-125, Troubleshooting Control of Maintenance Activities, Revision 21 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2017-8612 2017-9838 2017-9870 2017-9875 2017-10080 2017-10142 | : 2017-8612 2017-9838 2017-9870 2017-9875 2017-10080 2017-10142 | ||
Line 724: | Line 863: | ||
: 52783582 | : 52783582 | ||
===Miscellaneous=== | ===Miscellaneous=== | ||
: EC 62735 Revision 0 V1247, Recirculation System Pump Speed Controls, Revision 5 | : EC 62735 Revision 0 V1247, Recirculation System Pump Speed Controls, Revision 5 | ||
===Drawings=== | ===Drawings=== | ||
: E5004, Containment Spray Motor Operated Valves, Revision 14 | : E5004, Containment Spray Motor Operated Valves, Revision 14 | ||
Line 731: | Line 870: | ||
===Procedures=== | ===Procedures=== | ||
: 8.5.5.8, RCIC Overspeed Trip Test, Revision 33 8.7.4.4, Main Steam Isolation Valve Operability, 60% power, Revision 31 | : 8.5.5.8, RCIC Overspeed Trip Test, Revision 33 | ||
: 8.7.4.4, Main Steam Isolation Valve Operability, 60% power, Revision 31 | |||
: 8.E.13, RCIC System Instrument Calibration - Critical Maintenance, Revision 60 | : 8.E.13, RCIC System Instrument Calibration - Critical Maintenance, Revision 60 | ||
: 8.M.2-1.5.3.4, Primary Containment Isolation Logic Channel Test, Channel B2, Revision 25 8.M.2-2.10.4.3, HPCI Simulated Automatic Actuation (outboard) Revision 24 | : 8.M.2-1.5.3.4, Primary Containment Isolation Logic Channel Test, Channel B2, Revision 25 8.M.2-2.10.4.3, HPCI Simulated Automatic Actuation (outboard) Revision 24 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2017-10346 2017-10654 2017-11145 | : 2017-10346 2017-10654 2017-11145 | ||
: Maintenance Orders/Work Orders | : Maintenance Orders/Work Orders | ||
: | : 2658690 | ||
: 52719545 | : 52719545 | ||
===Miscellaneous=== | ===Miscellaneous=== | ||
: EC 71989, SRV/SSV Setpoint and Tolerance Increase and Replacement, Revision 0 | : EC 71989, SRV/SSV Setpoint and Tolerance Increase and Replacement, Revision 0 | ||
Line 745: | Line 885: | ||
===Procedures=== | ===Procedures=== | ||
: EP-108, Alert Notification System-American Signal Corporation Sirens, Revision 2 | : EP-108, Alert Notification System-American Signal Corporation Sirens, Revision 2 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2016-25200 2017-10496 | : 2016-25200 2017-10496 | ||
===Miscellaneous=== | ===Miscellaneous=== | ||
: ANS Testing and Maintenance Records, Spring 2016 - Spring 2017 | : ANS Testing and Maintenance Records, Spring 2016 - Spring 2017 | ||
: Letter from FEMA Region III to Pilgrim Steam Electric Station, dated November 7, 2008 Pilgrim Steam Electric Station Emergency Plan, Revision 61 Pilgrim Nuclear Power Station, Siren Alert Notification System Design Evaluation, Final Report, dated September 2008 | : Letter from FEMA Region III to Pilgrim Steam Electric Station, dated November 7, 2008 | ||
: Pilgrim Steam Electric Station Emergency Plan, Revision 61 Pilgrim Nuclear Power Station, Siren Alert Notification System Design Evaluation, Final Report, dated September 2008 | |||
: TEMPEST T-112/ T-121 Omni-directional Siren Installation, Operation, Maintenance and Parts Manual, Revision E | : TEMPEST T-112/ T-121 Omni-directional Siren Installation, Operation, Maintenance and Parts Manual, Revision E | ||
Line 757: | Line 898: | ||
===Procedures=== | ===Procedures=== | ||
: EP-113, Emergency Preparedness Staff Training, Revision 0 | : EP-113, Emergency Preparedness Staff Training, Revision 0 | ||
: TQ-113, Emergency Plan Training, Revision 4 | : TQ-113, Emergency Plan Training, Revision 4 | ||
===Miscellaneous=== | ===Miscellaneous=== | ||
: 50.54(q) Screens and Evaluations: S2016-06-06-01, Revision 2; S2017-02-16-01; | : 50.54(q) Screens and Evaluations: S2016-06-06-01, Revision 2; S2017-02-16-01; | ||
: S2017-07-03-01; E2017-09-08-01; E2017-09-07-01 | : S2017-07-03-01; E2017-09-08-01; E2017-09-07-01 | ||
: EP-102, Review, Revision, and Distribution of the SSES Emergency Plan and 50.54(Q) | : EP-102, Review, Revision, and Distribution of the SSES Emergency Plan and 50.54(Q) | ||
Line 779: | Line 920: | ||
: EP-115, Equipment Important to Emergency Response (EITER), Revision 8 | : EP-115, Equipment Important to Emergency Response (EITER), Revision 8 | ||
: SC-233-115, Calibration of the Unit 2 Turbine Building Vent Radiation Monitor System (VERMS) Low Range Noble Gas Channel, Revision 1 | : SC-233-115, Calibration of the Unit 2 Turbine Building Vent Radiation Monitor System (VERMS) Low Range Noble Gas Channel, Revision 1 | ||
: SC-233-116, Calibration of the Unit 2 Turbine Building Vent Radiation Monitor System (VERMS) Accident Channels, Revision 1 | : SC-233-116, Calibration of the Unit 2 Turbine Building Vent Radiation Monitor System (VERMS) Accident Channels, Revision 1 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2016-02543 2017-02868 2017-18657 2017-18694 | : 2016-02543 2017-02868 2017-18657 2017-18694 | ||
Line 796: | Line 937: | ||
: NASP-QA-406, Control of Audit Commitments, Revision 13 | : NASP-QA-406, Control of Audit Commitments, Revision 13 | ||
: Pilgrim Steam Electric Station Emergency Plan, Revision 61 | : Pilgrim Steam Electric Station Emergency Plan, Revision 61 | ||
: Pilgrim Steam Electric Station Evacuation | : Pilgrim Steam Electric Station Evacuation Ti me Estimate Sensitivity Study Construction of the South Valley Parkway in Nanticoke, Pennsylvania, dated November 2016 | ||
: SI-179-319B, 24 Month Calibration of Containment Area High Radiation Monitoring System | : SI-179-319B, 24 Month Calibration of Containment Area High Radiation Monitoring System | ||
Line 819: | Line 960: | ||
: EN-RP-203, Dose Assessment, Revision 10 | : EN-RP-203, Dose Assessment, Revision 10 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2017-02897 2017-03802 2017-03826 2017-04042 2017-04673 2017-04743 2017-05791 2017-11587 | : 2017-02897 2017-03802 2017-03826 2017-04042 2017-04673 2017-04743 | ||
: 2017-05791 2017-11587 | |||
: Self-Assessments and Audit Reports Entergy CFAM RP Observations at Pilgrim Station August 15 - 17, 2017 | : Self-Assessments and Audit Reports Entergy CFAM RP Observations at Pilgrim Station August 15 - 17, 2017 | ||
: PNPS Radiological Support Group 3rd Quarter 2017 Self-Assessment Report, October 1, 2017 | : PNPS Radiological Support Group 3rd Quarter 2017 Self-Assessment Report, October 1, 2017 | ||
Line 844: | Line 986: | ||
: EN-RP-505, PortaCount Respirator Fit Testing, Revision 7 | : EN-RP-505, PortaCount Respirator Fit Testing, Revision 7 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2017-01849 2017-05037 2017-06121 2017-06344 2017-06956 2017-08269 2017-08348 2017-08843 2017-09272 2017-10349 2017-11764 | : 2017-01849 2017-05037 2017-06121 2017-06344 2017-06956 2017-08269 | ||
: 2017-08348 2017-08843 2017-09272 2017-10349 2017-11764 | |||
: Self-Assessments and Audit Reports PNPS Radiological Support Group 3rd Quarter 2017 Self-Assessment Report, October 1, 2017 | : Self-Assessments and Audit Reports PNPS Radiological Support Group 3rd Quarter 2017 Self-Assessment Report, October 1, 2017 | ||
: Entergy CFAM RP Observations at Pilgrim Station August 15-17, 2017 | : Entergy CFAM RP Observations at Pilgrim Station August 15-17, 2017 | ||
Line 886: | Line 1,029: | ||
: 7.3.25, Particulate and Iodine Monitoring at the Main Stack and the Reactor Building Vent, Revision 42 | : 7.3.25, Particulate and Iodine Monitoring at the Main Stack and the Reactor Building Vent, Revision 42 | ||
: 7.3.31, Tritium Sampling, Revision 25 | : 7.3.31, Tritium Sampling, Revision 25 | ||
: 7.3.37, Noble Gas Effluent Sampling, Revision 39 7.3.48, Airborne Effluent Monitoring of the Turbine Deck and Reactor Feed Pump Bay, | : 7.3.37, Noble Gas Effluent Sampling, Revision 39 7.3.48, Airborne Effluent Monitoring of the Turbine Deck and Reactor Feed Pump Bay, Revision 26 7.9.12, Liquid Effluent Releases with RETDAS, Revision 10 | ||
: EP-114, Emergency Preparedness Performance Indicators, Revision 1 | : EP-114, Emergency Preparedness Performance Indicators, Revision 1 | ||
: EN-LI-114, Regulatory Performance Indicator Process, Revision 8 | : EN-LI-114, Regulatory Performance Indicator Process, Revision 8 | ||
: EN-FAP-RP-002, Radiation Protection Performance Indicator Program, Revision 3 | : EN-FAP-RP-002, Radiation Protection Performance Indicator Program, Revision 3 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2017-03156 2017-03826 2017-03833 2017-03965 | : 2017-03156 2017-03826 2017-03833 2017-03965 | ||
Line 921: | Line 1,063: | ||
: ANS Reliability PI data, October 2016- September 2017 DEP PI data, October 2016- September 2017 | : ANS Reliability PI data, October 2016- September 2017 DEP PI data, October 2016- September 2017 | ||
: Electronic Dosimeter Alarm History Report, January 1, 2016 through June 7, 2017 | : Electronic Dosimeter Alarm History Report, January 1, 2016 through June 7, 2017 | ||
: EN-LI-114, Regulatory Performance Indicator Process Data Sheet for | : EN-LI-114, Regulatory Performance Indicator Process Data Sheet for 4 | ||
th Quarter 2016, January | |||
: 4, 2017 | : 4, 2017 | ||
: EN-LI-114, Regulatory Performance Indicator Process Data Sheet for | : EN-LI-114, Regulatory Performance Indicator Process Data Sheet for 1 | ||
st Quarter 2017, April 3, | |||
: 2017 | : 2017 | ||
: EN-LI-114, Regulatory Performance Indicator Process Data Sheet for | : EN-LI-114, Regulatory Performance Indicator Process Data Sheet for 2 | ||
: EN-LI-114, Regulatory Performance Indicator Process Data Sheet for | nd Quarter, July 6, 2017 | ||
: EN-LI-114, Regulatory Performance Indicator Process Data Sheet for 3 | |||
rd Quarter, October 4, | |||
: 2017 | : 2017 | ||
: ERO Drill Participation PI data, October 2016- September 2017 | : ERO Drill Participation PI data, October 2016- September 2017 | ||
: NDAP-QA-0737, Reactor Oversight Process ( | : NDAP-QA-0737, Reactor Oversight Process (R | ||
: OP) Performance Indicators, Revision 18 Pilgrim Nuclear Power Station Liquid Effluent Release Permit Log, November 18, 2017 | |||
: Pilgrim Nuclear Power Station Liquid Effluent Release Permit Report | : Pilgrim Nuclear Power Station Liquid Effluent Release Permit Report | ||
: 2017001, July 13, 2017 | : 2017001, July 13, 2017 | ||
Line 956: | Line 1,103: | ||
: Maintenance Rule (a)(1) Evaluation, System 24, Reactor Building Isolation System, 3/7/17 | : Maintenance Rule (a)(1) Evaluation, System 24, Reactor Building Isolation System, 3/7/17 | ||
: Maintenance Rule (a)(1) Evaluation, System 29, Service Water System, 8/16/17 | : Maintenance Rule (a)(1) Evaluation, System 29, Service Water System, 8/16/17 | ||
: Maintenance Rule (a)(1) Evaluation, System 31, Instrument Air, 7/26/17 Maintenance Rule (a)(1) Evaluation, System 31, Instrument Air, 3/6/17 Operability Evaluation | : Maintenance Rule (a)(1) Evaluation, System 31, Instrument Air, 7/26/17 Maintenance Rule (a)(1) Evaluation, System 31, Instrument Air, 3/6/17 | ||
: Operability Evaluation | |||
: OE-CR-PNP-2016-02205, Revision 3 | : OE-CR-PNP-2016-02205, Revision 3 | ||
: Operability Evaluation | : Operability Evaluation | ||
Line 966: | Line 1,114: | ||
: Project Plan for Preventive Maintenance Program Improvements, June 2017 | : Project Plan for Preventive Maintenance Program Improvements, June 2017 | ||
: Root Cause Evaluation | : Root Cause Evaluation | ||
: CR-PNP-2016-02205, Boraflex Panel RR35 South has 36.4 inches of Cumulative Gap, Revision 0 Spent Fuel Pool Configuration Diagram, SFP ICA Account Area Update 277 | : CR-PNP-2016-02205, Boraflex Panel RR35 South has 36.4 inches of Cumulative Gap, Revision 0 | ||
: Spent Fuel Pool Configuration Diagram, SFP ICA Account Area Update 277 | |||
==Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion== | ==Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion== | ||
Line 974: | Line 1,123: | ||
: EN-LI-102, Corrective Action Program, Revision 30 | : EN-LI-102, Corrective Action Program, Revision 30 | ||
===Condition Reports=== | ===Condition Reports=== | ||
: 2016-02205 2017-02125 2017-10190 2017-11887 | : 2016-02205 2017-02125 2017-10190 2017-11887 | ||
===Miscellaneous=== | ===Miscellaneous=== | ||
: Altran Report 17-0192-TR-003, Electrical Testing and Analysis of | : Altran Report 17-0192-TR-003, Electrical Testing and Analysis of | ||
Line 982: | Line 1,131: | ||
: LER 2016-003-00, Spent Fuel Storage Design Feature Exceeded | : LER 2016-003-00, Spent Fuel Storage Design Feature Exceeded | ||
: LER 2016-003-01, Spent Fuel Storage Design Feature Exceeded | : LER 2016-003-01, Spent Fuel Storage Design Feature Exceeded | ||
: LER 2016-003-02, Spent Fuel Storage Design Feature Exceeded Pilgrim Technical Specifications | : LER 2016-003-02, Spent Fuel Storage Design Feature Exceeded | ||
: Pilgrim Technical Specifications | |||
: PNPS DC Solenoid Failure Analysis, Exponent, Inc., October 16, 2017 | : PNPS DC Solenoid Failure Analysis, Exponent, Inc., October 16, 2017 | ||
: Root Cause Evaluation, SRV Operability, CR-PNP-2017-05067 | : Root Cause Evaluation, SRV Operability, CR-PNP-2017-05067 |
Revision as of 02:58, 29 June 2018
ML18045A058 | |
Person / Time | |
---|---|
Site: | Pilgrim |
Issue date: | 02/14/2018 |
From: | Anthony Dimitriadis NRC/RGN-I/DRP/PB5 |
To: | Brian Sullivan Entergy Nuclear Operations |
Dimitriadis A | |
References | |
IR 2017004 | |
Download: ML18045A058 (39) | |
Text
February 14, 2018
Mr. Brian Sullivan Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station
600 Rocky Hill Road Plymouth, MA 02360-5508
SUBJECT: PILGRIM NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000293/2017004
Dear Mr. Sullivan:
On December 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Pilgrim Nuclear Power Station (PNPS). On January 25, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 Code of Federal Regulations (CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding."
Sincerely,/RA/ Anthony Dimitriadis, Chief Reactor Projects Branch 5
Division of Reactor Projects Docket No. 50-293 License No. DPR-35
Enclosure:
Inspection Report 05000293/2017004
w/Attachment:
Supplementary Information cc w/encl: Distribution via ListServ
ML18045A058 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME JKrafty LCline via email ADimitriadis DATE 2/14/18 2/13/18 2/14/18
1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I
Docket No: 50-293
License No: DPR-35
Report No.: 05000293/2017004
Licensee: Entergy Nuclear Operations, Inc. (Entergy)
Facility: Pilgrim Nuclear Power Station (PNPS)
Location: Plymouth, MA
Dates: October 1, 2017 through December 31, 2017
Inspectors: E. Carfang, Senior Resident Inspector P. Cataldo, Acting Senior Resident Inspector J. Krafty, Acting Senior Resident Inspector B. Pinson, Resident Inspector P. Boguszewski, Project Engineer J. Ambrosini, Senior Emergency Preparedness Inspector B. Dionne, Health Physicist D. Silk, Senior Operations Engineer J. DeBoer, Emergency Preparedness Inspector M. Orr, Reactor Inspector J. Vazquez, Project Engineer S. Elkhiamy, Reactor Inspector
Approved By: Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects
2
SUMMARY
IR 05000293/2017004; 10/01/2017 to 12/31/2017; PNPS; Routine Integrated Inspection Report
This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6.
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity No findings were identified.
4
REPORT DETAILS
Summary of Plant Status
Pilgrim began the inspection period at 100 percent power. On October 24, 2017, operators reduced power to approximately 45 percent for a planned main condenser thermal backwash.
Operators returned the unit to 100 percent on October 25, 2017 and remained at or near 100 percent power for the remainder of the inspection period. Documents reviewed for each section of this inspection report are listed in the Attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors reviewed Entergy's readiness for the onset of seasonal cold temperatures. The review focused on the standby AC power system and diesel generator cooling and ventilation system. The inspectors reviewed the Final Safety Analysis Report (FSAR), technical specifications (TSs), control room logs, and the corrective action program (CAP) to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Entergy personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Entergy's seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions.
b. Findings
No findings were identified.
.2 External Flooding
a. Inspection Scope
During the week of December 18, 2017, the inspectors performed an inspection of the external flood protection measures for PNPS. The inspectors reviewed procedures, design documents, and FSAR, Chapter 2.4.4, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a walkdown of the retube room and turbine building truck bay and a general site walkdown of external areas of the plant to ensure that Entergy's flood protection measures were in accordance with design specifications. The inspectors inspected the watertight doors to confirm that they were being properly maintained. The inspectors also reviewed the results of the inspection of the seals on external penetrations below flood levels to determine if there was significant degradation. In addition, the inspectors reviewed operating procedures for mitigating external flooding during severe weather to confirm that, overall, Entergy had established adequate measures to protect against external flooding events and, more specifically, that credited operator actions were adequate.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial System Walkdowns (71111.04 - 3 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
High pressure coolant injection (HPCI) walk down during reactor core isolation cooling (RCIC) system outage on November 1, 2017
'A' residual heat removal (RHR) during 'B' RHR maintenance on November 15, 2017 Instrument air with temporary air compressor in service on November 16, 2017 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the FSAR, TSs, work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the system's performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of t he 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.
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.
Standby liquid control room on October 10, 2017
'A' RHR and core spray quadrant on October 30, 2017 'A' emergency diesel generator (EDG) room on October 30, 2017 'B' EDG room on October 30, 2017 Radiation waste truck lock on October 30, 2017
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the site flooding analysis, and plant procedures to identify internal flooding susceptibilities for the site. The inspectors' review focused on the cable spreading room. The inspectors verified the adequacy of doors and the curbs around doors used to limit and control flooding. The inspectors reviewed the assumptions used in the flooding analysis to determine if they were reasonable, and assessed the adequacy of operator actions which Entergy identified as necessary to cope with flooding in this area.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
(71111.11Q - 1 sample)
a. Inspection Scope
The inspectors observed licensed operator simulator training on October 23, 2017, which included a fire on the standby gas treatment (SBGT) system, a stuck open safety relief valve (SRV) and a failure to scram following hydraulic binding of control rods. The scenario required declaration of a general emergency. 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
On October 2, 2017, the inspectors observed the lowering of power to 98 percent to unlock the 'A' reactor recirculation pump after a scoop tube lock out occurred. After the scoop tube was unlocked, power was returned to 100 percent. Inspectors observed the reactivity and pre-job brief to verify that the briefings met the criteria specified in Entergy's Procedure EN-OP-115, "Conduct of Operations," Revision 21. Additionally, the inspectors observed operator performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
b. Findings
No findings were identified.
.3 Review of Licensed Operator Requalification Program (71111.11A, 71111.11B -
1 sample each)
a. Inspection Scope
The following inspection activities were performed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 11, and Inspection Procedure Attachment 71111.11, "Licensed Operator Requalification Program."
Examination Results On December 13, 2017, the results of the annual operating tests were reviewed to
determine if pass/fail rates were consistent with the guidance of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 11, and NRC Inspection Manual Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process." The review verified that the failure rate (individual or crew) did not exceed 20 percent.
One out of 54 operators failed at least one section of the Annual Exam. The overall individual failure rate was 1.8 percent.
Zero out of eight crews failed the simulator test. The crew failure rate was 0.0 percent.
Observations were made of the dynamic simulator exams and job performance measures (JPMs) administered during the week of September 25, 2017. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of JPMs.
Written Examination Quality The inspectors reviewed two written examinations administered during the 2016 examination cycle for qualitative and quantitative attributes as specified in Appendix B of 71111.11, "Licensed Operator Requalification." There was no written examination administered in 2017.
Operating Test Quality Ten JPMs and six scenarios for the operating tests for the weeks of September 18 and September 25, 2017, were reviewed for qualitative and quantitative attributes as specified in Appendix C of 71111.11, "Licensed Operator Requalification Program."
Licensee Administration of Operating Tests
Observations were made of the dynamic simulator exams and JPMs administered during the week of September 25, 2017. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of JPMs.
Examination Security
The inspectors assessed whether facility staff properly safeguarded exam material.
JPMs, scenarios, and written examinations were checked for excessive overlap of test items.
Remedial Training and Re-Examinations
No remediation plans or examinations were reviewed because there were no recent
failures.
Conformance with Operator License Conditions
Medical records for nine senior reactor operator licenses and six reactor operator licenses were reviewed to assess conformance with license conditions. All records reviewed were satisfactory.
Proficiency watch standing records were reviewed for the second quarter of 2017. All active licensed operators met the watch standing requirements to maintain an active
license.
The reactivation plan for three licensed operators were reviewed to assess the effectiveness of the reactivation process. The reactivations were processed in accordance with site procedures.
Records for the participation of licensed operators in the requalification program for 2017 were reviewed. Records for the performance of licensed operators on annual requalification operating test and biennial requalification written exams were reviewed.
Simulator Performance Simulator performance and fidelity were reviewed for conformance to the reference plant control room. A sample of simulator deficiency reports was also reviewed to ensure facility staff addressed identified modeling problems. Simulator test documentation was
also reviewed.
Problem Identification and Resolution
A review was conducted of recent operating history documentation found in inspection
reports, the licensee's CAP, and the most recent NRC plant issues matrix. The inspectors also reviewed specific events from the licensee's CAP which indicated possible training deficiencies to verify that they had been appropriately addressed. The senior resident inspector was also consulted for insights regarding licensed operators' performance. These reviews did not detect any operational events that were indicative of possible training deficiencies.
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 WOs, and maintenance rule (MR) basis documents to ensure that Entergy was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with 10 CFR 50.65 and verified that the (a)(2)performance criteria established by Entergy staff was reasonable. As applicable, for structures, systems, and components classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these structures, systems, and components to (a)(2). Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.
Neutron monitoring system the week of November 13, 2017 Review of periodic maintenance effectiveness assessment for operating cycle 21 the week of December 18, 2017 Reactor building closed loop cooling water system the week of December 18, 2017
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Entergy performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Entergy personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Entergy performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Elevated risk during 'B' EDG planned maintenance the week of October 9, 2017 Elevated risk with RCIC planned maintenance on November 1, 2017 Elevated risk during RCIC planned maintenance on November 15, 2017 Elevated risk during a planned A8 bus outage on November 30, 2017
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on the risk significance of the associated components and systems:
HPCI low oil level on September 28, 2017 Dual indication on 'A' RHR primary containment isolation valve on October 4, 2017 Damper position alarm on 'B' EDG on October 11, 2017 Recirculation pump speed limiter deviation from FSAR values on November 15, 2017 The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and FSAR to Entergy's evaluations to determine whether the
components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Entergy.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed the piping modifications to accommodate the temporary air compressor implemented by EC 74577.
The inspectors evaluated 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 modifi cations to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
The inspectors evaluated the following modifications implemented by engineering changes. 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 design change, including the implementation work activities, design drawing revisions, and the post-modification test plan. Additionally, the inspectors reviewed applicable failure modes analyses and associated corrective action documents to verify other similarly-affected valves were appropriately identified.
EC 74553, Control Circuit Changes to MO-1001-36A EC 62735, Motor Operated Controller (MOC) Design Upgrade with Sealed Potentiometer for EDG
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, observed the pre-job brief and post-job critique where possible, confirmed work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold point were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.
Station blackout diesel generator oil transfer pump level switch replacement on October 3, 2017 'A' RHR thermocouple replacement and diagnostic testing on October 6, 2017 'B' EDG MOC replacement on October 11, 2017 Recirculation pump power supply replacement on October 15, 2017 Traversing incore probe repairs on October 20, 2017 'A' salt service water pump balancing as a result of high vibration on November 2, 2017
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the FSAR, and Entergy procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
8.5.5.8, RCIC overspeed trip test on September 27, 2017 8.M.2-1.5.3.4, Primary containment isolation logic channel test, channel B2, on October 19, 2017 8.7.4.4, Main steam isolation valve operability on October 24, 2017 (in-service test) 8.E.13, RCIC system instrument calibration on November 1, 2017 8.M.2-2.10.4.3, HPCI simulated automatic actuation on November 7, 2017
b. Findings
No findings were identified.
Cornerstone:
1EP2 Alert and Notification System Evaluation
a. Inspection Scope
The inspectors conducted an onsite review to assess the maintenance and testing of the Pilgrim alert and notification system (ANS). During this inspection, the inspectors reviewed the Pilgrim siren system and backup route alerting, and the associated ANS procedures and the Federal Emergency Management Agency ANS Design Report to ensure compliance with design report commitments for system maintenance and testing.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System
a. Inspection Scope
The inspectors conducted a review of the Pilgrim Emergency Response Organization (ERO) augmentation staffing requirements and the process for notifying and augmenting the ERO to verify the readiness of key staff to respond to an emergency event and to verify their ability to activate their emergency response facilities in a timely manner. The inspectors reviewed: the Pilgrim Emergency Plan for facility activation and ERO staffing requirements, the ERO duty roster, applicable station procedures, augmentation test reports, call-in drill reports, and corrective action reports related to this inspection area.
The inspectors also reviewed a sample of ERO responder training records to verify training and qualifications were up to date.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Entergy implemented various changes to the Pilgrim Emergency Action Levels (EALs), Emergency Plan, and Implementing Procedures. Entergy had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR Part 50, Appendix E.
The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by Entergy as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements listed in 10 CFR 50.54(q) were used as
reference criteria.
b. Findings
No findings were identified.
1EP5 Maintaining Emergency Preparedness
a. Inspection Scope
The inspectors evaluated the efficacy of efforts to maintain the Pilgrim emergency preparedness program. The inspectors reviewed: memoranda of agreement with offsite agencies; procedures for the 10 CFR 50.54(q) Emergency Plan change process; Pilgrim's maintenance of equipment important to emergency preparedness; records of evacuation time estimate population evaluation; and provisions for, and implementation of, primary, backup, and alternative emergency response facility maintenance. The
inspectors also verified compliance with NRC regulations regarding: emergency action levels for hostile action events, protective actions for on-site personnel during events, emergency declaration timeliness, ERO augmentation and alternate facility capability, evacuation time estimate updates, on-shift ERO staffing analysis, and ANS back-up means.
The inspectors further evaluated the ability to maintain Pilgrim's emergency preparedness program through their identification and correction of weaknesses, by reviewing a sample of drill reports, self-assessments, condition reports, and 10 CFR 50.54(t) reviews since the last NRC emergency preparedness program inspection in March 2015.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of routine Entergy emergency drills on October 23, 2017 and November 7, 2017, to identify any potential weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.
The inspectors also attended the station drill critique to compare inspector observations with those identified by Entergy staff in order to evaluate Entergy's critique and to verify whether the Entergy staff was properly identifying weaknesses and entering them into
the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone:
2RS2 Occupational As Low As Is Reasonably Achievable Planning and Controls
a. Inspection Scope
The inspectors assessed Entergy's performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA).
The inspectors used the requirements contained in 10 CFR 20, applicable Regulatory Guides (RGs), TSs, and procedures required by TSs as criteria for determining compliance.
Implementation of ALARA and Radiological Work Control
The inspectors reviewed radiological work controls and ALARA practices during the observation of in-plant work activities. The inspectors reviewed the results achieved against the intended ALARA estimates to confirm adequate implementation and oversight of radiological work controls. The inspectors also verified that post job reviews were performed for the refueling outage jobs and the lessons learned were captured in the Entergy CAP.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors reviewed the control of in-plant airborne radioactivity and the use of respiratory protection devices in these areas. The inspectors used the requirements in 10 CFR 20, RG 8.15, RG 8.25, NUREG/CR-0041, TSs, and procedures required by TSs as criteria for determining compliance.
Self-Contained Breathing Apparatus (SCBA) for Emergency Use
The inspectors reviewed the following: the status and surveillance records for three SCBAs staged in-plant for use during emergencies; Entergy's SCBA procedures and maintenance and test records; the refilling and transporting of SCBA air bottles; SCBA mask size availability; and the qualifications of personnel performing service and repair of this equipment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance Index (2 samples)
a. Inspection Scope
The inspectors reviewed Entergy's submittal of the Mitigating Systems Performance Index for the following systems for the period of October 1, 2016 through September 30,
2017:
Emergency alternating current power system Cooling water tower To determine the accuracy of the performance indicator (PI) data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7. The inspectors also reviewed Entergy's operator narrative logs,
CRs, mitigating system performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Emergency Preparedness Performance Indicator (3 samples)
a. Inspection Scope
The inspectors reviewed data for the Pilgrim emergency preparedness PIs: (1) Drill and Exercise Performance (EP01); (2) ERO Drill Participation (EP02); and (3) ANS Reliability (EP03). The inspectors conducted the last NRC emergency preparedness inspection at Pilgrim in the fourth calendar quarter of 2016, so the inspectors reviewed supporting documentation from emergency preparedness drills and tests from the fourth calendar quarter of 2016 through the third calendar quarter of 2017, to verify the accuracy of the reported PI data. The inspectors conduct ed this review in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI
Document 99-02, "Regulatory Assessment Perf ormance Indicator Guidelines," Revision
7.
b. Findings
No findings were identified.
.3 Occupational Exposure Control Effectiveness (1 sample)
a. Inspection Scope
The inspectors reviewed licensee submittals for the occupational radiological occurrences PI for the fourth quarter of 2016 through the first, second and third quarters of 2017. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Revision 7, to determine the accuracy of the PI data reported. The
inspectors reviewed electronic personal dosimetry accumulated dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized PI occurrences.
b. Findings
No findings were identified.
.4 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
(TS/ODCM) Radiological Effluent Occurrences (1 sample)
a. Inspection Scope
The inspectors reviewed licensee submittals for the radiological effluent TS/ODCM radiological effluent occurrences PI for the fourth quarter of 2016 through the first, second and third quarters of 2017. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Revision 7, to determine if the PI data was reported properly. The inspectors reviewed the public dose assessments for the PI for public radiation safety to determine if related data was accurately calculated and reported.
The inspectors reviewed the CAP database to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous and liquid effluent summary data and the results of associated offsite dose calculations to determine if indicator results were accurately reported.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, "Problem Identification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify Entergy entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Entergy performed an
evaluation in accordance with 10 CFR Part 21.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues to identify trends that might indicate the existence of more significant safety concerns. As part of this review, the inspectors included repetitive or closely-related issues documented by Entergy in department trend reports, system health reports and MR assessments. The inspectors evaluated a sample of condition reports generated over the course of the past two quarters by departments that provide input to the quarterly trend reports with a focus on operations, maintenance and engineering. The inspectors also reviewed Entergy's CAP database for the third and fourth quarters of 2017 to assess condition reports written in
various subject areas, as well as individual issues identified during the NRC's daily condition repot review (Section 4OA2.1). The inspectors reviewed Entergy's quarterly Department Performance Review Meeting and Aggregate Performance Review Meeting reports completed during the third quarter of 2017, conducted under EN-LI-121, "Trending and Performance Review Process," to verify that Entergy personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.
b. Findings and Observations
No findings were identified.
The inspectors determined that the issues were appropriately evaluated by Entergy staff for trends and that identified trends were input into the CAP and appropriately evaluated.
The inspectors also noted that Entergy's interim effectiveness reviews, which were intended to review progress of corrective actions taken to address the human performance issues that led to the March 31, 2017, torus fill event, determined that the actions taken to date were not fully effective. This was based on four additional low consequence events that involved inadequate operator fundamentals and poor procedure use and adherence in the third and fourth quarters of 2107. In response, Entergy has initiated benchmarking targeting specific crew inadequacies and additional focused operating crew assessments that use a senior reactor operator to perform focused observations of the operating crews.
.3 Annual Sample:
Spent Fuel Pool Boraflex Degradation
a. Inspection Scope
The inspectors reviewed Entergy's corrective actions taken to address non-cited violation 05000293/2017001-03, Untimely Corrective Actions associated with Boraflex degradation in the Spent Fuel Pool. Specifically, the NRC had previously determined that Entergy had not established corrective actions to ensure that the SFP configuration would meet analysis-established limitations beyond September 2017. Following up on this issue, the inspectors reviewed corrective actions, subsequently developed by Entergy, to ensure that that these actions were adequately developed and implemented to maintain the SFP was maintained in a safe configuration.
Inspectors reviewed updated operability determinations, a root cause evaluation, updated fuel move sheets for fuel moves taking place in 2017, revised fuel handling procedures, and documentation of the current SFP configuration. The current SFP configuration was assessed to ensure conformance with Entergy's criticality evaluation of record and compliance with station procedures. Inspectors also verified fuel assembly positions via a sample-based review of video recordings. Inspectors discussed with Entergy staff the reasoning behind the current SFP configuration and the fuel moves performed to ensure that implemented corrective actions were based on conservative assumptions. The inspectors assessed the prioritization and timeliness of Entergy's corrective actions to determine whether Entergy's completed and planned corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Entergy's CAP and 10 CFR Part 50, Appendix B
b. Findings and Observations
No findings were identified.
After the NRC's previous inspection of this issue documented in NRC IR 050002932017001 (ML17136A015), Entergy rearranged the fuel in the SFP to ensure subcriticality could be maintained within regulatory limits beyond September 2017. This rearrangement was intended to ensure the SFP would remain subcritical only as a result of the spatial separation of the fissile material in the fuel, and not rely on the neutron absorption provided by the Boraflex panels. The inspectors' reviewed the vendor's analysis of the new spent fuel configuration and independently verified the final locations of a risk-informed sample of spent fuel cells after Entergy completed the required fuel moves. Based on these reviews the inspectors concluded that that the new configuration provided reasonable assurance that the SFP would be maintained in a safe condition, without further reconfiguration, as long as additional fuel is not added to the
pool.
Inspectors noted two examples of Entergy staff demonstrating effective and proactive conservative decision-making practices. In one instance, Entergy staff had a more detailed evaluation performed that determined that the SFP configuration would meet the analysis-established limitations until November 2017 - as opposed to the initially established September 2017 date - in case there were unexpected delays in completing the necessary fuel moves. Nevertheless, the fuel moves and associated configuration verification were completed on August 24, 2017. In another instance, cells adjacent to the initially-discovered degraded panel were maintained empty or blocked, despite the fact that fuel storage in these cells would have been permissible in accordance with the criticality analysis of record.
Additional details regarding the NRC's ongoing review of the licensee event report associated with this issue (LER 05000293/2016-003-02, Spent Fuel Storage Design Feature Exceeded) can be found in Section
4OA3 of this inspection report.
.4 Annual Sample:
Maintenance Rule and Preventive Maintenance Program Improvement Plan Development and Implementation
a. Inspection Scope
The inspectors performed an in-depth review of Entergy's improvement plans to the MR and preventive maintenance (PM) programs. Specifically, the review focused on corrective actions associated with CR 2016-05555, which included Entergy's apparent cause evaluation for MR program implementation discrepancies. The inspectors also reviewed Entergy's corrective actions associated with CR 2016-09147, stemming from Entergy's PM program self-assessment to improve its maintenance strategies and address SSC wear, performance, reliability, and the effects of equipment aging.
The inspectors reviewed Entergy's apparent cause evaluation associated with MR program problems identified and its self-assessment to understand the scope of the issues. This inspection focused on the tracking, prioritization, completion, and timeliness
of Entergy's corrective actions resulting from these reviews to determine whether Entergy was appropriately correcting problems consistent with its potential safety significance, Entergy's CAP procedures and the requirements in 10 CFR Part 50, Appendix B. In addition, the inspectors interviewed engineering personnel to assess the
effectiveness of the implemented corrective actions.
b. Findings and Observations
No findings were identified.
The inspectors determined that Entergy staff identified two apparent causes to the MR program implementation discrepancies involving inadequate management oversight and dedicated resources to ensure successful implementation of the MR program. Entergy staff further identified contributing causes in four areas: change management during previous program transitions, rigor applied and maintained regarding MR documentation, MR related qualification requirements, and MR program oversight by engineering management. The inspectors concluded the evaluation scope appeared sufficient to
identify the problems and reasonably s upport corrective action development.
With respect to the PM program, the inspectors determined Entergy identified implementation problems related to PM processes and procedures that could impact reliable equipment performance and ensure compliance with regulatory requirements (10 CFR 50.65). Entergy entered these issues into its CAP on March 24, 2016 (CR 2016-02056 and CR 2016-02061). Entergy staff developed a project plan to improve its PM program implementation. The plan included addressing component PM strategy deficiencies, improving the quality and technical rigor of PM program engineering products, and ensuring adequate PM strategies existed for critical station equipment. For critical station equipment where PM deficiencies were identified during its focused self-assessment, Entergy staff evaluated whether the equipment was vulnerable to failure due to the deficient or missing PMs, and developed and tracked mitigation actions as required. For equipment that was not specifically evaluated during the self-assessment, Entergy staff performed a risk-based review of PM recommendations to identify whether program vulnerabilities existed.
The inspectors reviewed the prioritization, tracking, and completion of corrective actions and confirmed that timeliness of the corrective actions were commensurate with the potential safety significance of the issues. In cases where due dates were extended, the inspectors verified that extensions received the appropriate review in accordance with Entergy's corrective action procedure and that appropriate interim and/or compensatory measures were implemented to minimize the problem or mitigate the effects until permanent actions could be completed.
The corrective actions to address the MR program implementation were tracked under CR-2016-05555. The inspectors reviewed corrective action priority and compensatory actions and determined they were appropriate. In particular, one corrective action related to ensuring the quality of maintenance rule functional failure (MRFF)determinations included compensatory measures to require the management review committee to review all MRFF evaluations until the MRFF coordinator refresher training was completed. The inspectors reviewed additional specific corrective actions, including the development of a database for MR scoped systems and a program notebook for centralized program information, the development of an MR Coordinator qualification card, and the training and qualification of engineers from different departments to ensure qualified back-ups. Finally, the inspectors noted that Entergy was tracking and providing oversight for the overall completion of the MR program improvement plan. The inspectors concluded Entergy's planned actions in these areas were reasonable.
.5 Annual Sample:
Technical Specifications Surveillance Requirements Implementation
a. Inspection Scope
The inspectors reviewed recent instances where technical specification surveillance tests were performed outside of the license requirements included in the TSs.
Specifically, inspectors reviewed CRs, causal evaluations, and other documents associated with two recent instances in which either TS requirements were not implemented as written, or the functions of safety related equipment were affected due to improper implementation of the requirements.
The inspectors reviewed the details of Entergy's discovery that it was not complying with TS requirements for control room habitability testing. Specifically, from November 2008 until October 2016 the Pilgrim control room envelope was not pressure tested in accordance with the TS requirements.
The inspectors also reviewed the fact that Entergy operators had performed a refueling outage surveillance test while at 97 percent power, which inappropriately removed the safety function of the SBGT system, and rendered the secondary containment system inoperable. This occurrence was previous ly discussed in NRC Inspection Report 05000293/2017002 (ML17226A015).
The inspectors performed in-depth reviews of Entergy's evaluations, extent of condition, and associated corrective actions to ensure that the causes were understood and appropriate corrective actions were established. Additionally, the inspectors interviewed Entergy personnel involved in the causal evaluations.
b. Findings and Observations
No findings were identified.
The inspectors determined that Entergy's evaluations and extent of condition reviews were thorough, and the causes were appropriately identified. The inspectors also determined that the corrective actions were reasonable, timely, and addressed the concerns with improper implementation of TS requirements.
Inspectors reviewed the adverse condition analysis (ACA) associated with CR 2016-7901, "Control Room Envelope Test," and determined that the identified causal factors, the planned and taken corrective actions, and the extent of condition were adequate.
Inspectors also reviewed the root cause evaluation (RCE) associated with CR 2017-2900, which investigated the April 2017 occurrence of the SBGT system being made unavailable for surveillance testing. Inspectors determined that the root cause, causal factors, planned and taken corrective actions, extent of condition, and extent of cause were adequate. Corrective actions to address the identified causes in the RCE included providing additional training to staff related to the implementation of TS requirements, procedure changes, and implementation of a more thorough review of upcoming work activities to ensure tasks involving safety-related equipment are performed in accordance with all license requirements.
Specifically, guidance was developed to ensure that technical specification surveillance tests, in-service inspections and in-service tests are completed in the correct mode of operation, completed at the correct frequency interval, satisfies all licensing basis requirements, and are completed without electively defeating a safety function that is required at the time of the test. Inspectors did not identify any issues in subsequent tests following implementation of the associated corrective actions. However, inspectors did note that Entergy staff identified, as part of the more thorough reviews, that an upcoming SBGT system test would have made both trains of the SBGT system inoperable had the test been performed as written. CRs 2017-11714 and 2017-12306 were written to document the issue, and CR 2017-2900 was revised to implement additional corrective actions as a result.
In conclusion, inspectors determined that Entergy's causal evaluations, assessments, corrective actions, extents of condition and extents of cause were effective in identifying and correcting the associated TS surveillance requirements implementation issues.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 (Closed) Licensee Event Report (LER) 05000293/2017-005-00:
10 CFR 50, Appendix J, Option B, Leak Rate Criteria Exceeded On April 10, 2017, the personnel airlock, X-2, failed to meet local leak rate test (LLRT) acceptance criteria of 0.05 L a during the as-found LLRT, and on April 22, 2017, two HPCI turbine exhaust check valves failed to meet LLRT acceptance criteria. The HPCI
turbine check valve test failure was dispositioned in NRC inspection report 05000293/2017003 (ML17319A158), this LER assessment addresses the X-2 airlock LLRT failure. The inspectors' review of the test results determined that although the leak rate of the inner personnel airlock door exceeded the overall surveillance test acceptance criteria of 10.525 standard liters per minute, the outer personnel airlock door remained operable, and containment integrity was maintained consistent with TSs. In addition, the licensee determined that the cause of the personnel airlock leak test failure was the air lock pressure equalizing device (PED) sealing O-rings. During testing, the pressure was applied from outside the drywell, which is opposite of expected design basis conditions. This test method caused the PED to open, which caused O-ring extrusion and leakage through the airlock. During an actual event, increased post-accident pressures inside the drywell would tend to seal the inner door and its associated PED. Acceptable leakage values during testing ensure consistency with applicable TS and design basis requirements. Because the testing verified the outer door had maintained containment integrity, which ensured TS requirements were met, no violations were identified. The inspectors did not identify any new issues during the
review of this LER. This LER is closed.
.2 (Closed) LER 05000293/2017-007-00:
Potential Inoperability of Safety Relief Valve 3A On April 24, 2017, following replacement of a pilot valve for safety-relief valve SV203-3A, electrical resistance testing of the associated solenoid circuit identified high resistance values greater than the acceptance criteria. Pilgrim staff entered the issue into the CAP, replaced the solenoid, and the solenoid was sent to a vendor for failure analysis. The inspectors reviewed the RCE, the failure analysis from Altran, as well as the independent review conducted by Exponent, Inc. The inspectors determined that reasonable engineering testing methodologies were utilized for the failure analyses, and that the results support the identified cause of the high resistance to be corrosion internal to the crimped connections for the solenoid coils. The underlying performance issue associated with the internal corrosion build-up was previously dispositioned in NRC inspection report 05000293/2017003 (ML17319A158). The inspectors did not identify any new issues during the review of this LER. This LER is closed.
.3 (Discussed) LER 05000293/2016-003-00, 2016-003-01, 2016-003-02:
Spent Fuel Storage Design Feature Exceeded In May 2016, Entergy identified degraded conditions on a Boraflex panel in the Pilgrim spent fuel pool (SFP). Further assessment of the conditions also led Entergy to determine that the current Technical Specification 4.3.1.1.a, which allows loading a fuel assembly with k-infinity as high as 1.32, may be non-conservative for racks with Boraflex panels. If a fuel bundle with a k-infinity of 1.32 were to be introduced into one of the locations affected by Boraflex degradation in the SFP, this could potentially challenge the capability of maintaining the overall criticality of the pool (k-effective) below the limit of 0.95, established by Pilgrim Technical Specifications.
NRC Administrative Letter 98-10 states that the discovery of an inadequate (e.g. non-conservative) Technical Specification value is to be considered a degraded or nonconforming condition, and that prompt corrective action to correct or resolve the condition must be taken in accordance with 10 CFR Part 50, Appendix B. The NRC expects that, following the imposition of administrative controls to address any associated safety concerns, an amendment to the Technical Specification will be submitted in a timely fashion.
Inspectors reviewed Entergy's completed corrective actions to address the non-conservative k-infinity value currently listed in the technical specifications through the implementation of administrative controls. Entergy implemented administrative controls by revising the Pilgrim fuel handling procedure. The procedure established limits on the fuel assemblies that could be placed into the region of the spent fuel pool affected by Boraflex degradation based on the fuel burnup characteristics of each fuel assembly.
Fuel assemblies with higher criticality levels (i.e. higher k-infinity fuel) are to be placed in regions of the pool that rely on material other than Boraflex (i.e. boral or metamic) for neutron absorption. The revised procedure also requires additional verification by a qualified reviewer to ensure that the fuel is positioned with adequate spacing between bundles to maintain the overall criticality (k-effective) of the SFP below the 0.95 limit.
The inspectors determined that these administrative controls were adequate to maintain the SFP in a safe condition.
Furthermore, the inspectors reviewed Entergy's planned corrective actions to obtain a revised criticality safety analysis and submit an associated license amendment request. The revised criticality analysis is complex and unique for boiling water reactor SFPs, and will, therefore, require considerable time to complete. The criticality analysis is necessary to provide sufficient basis for the amendment request. The inspectors concluded that these actions, once completed, should be sufficient to resolve the non-conservatism in the technical specification, in accordance with Administrative Letter 98-
10.
The NRC will continue review of this issue to verify the adequate and timely development and submission of Entergy's planned amendment request and to ensure that Entergy continues to maintain the safe configuration of the SFP. Until the planned amendment request is submitted, the issue of a non-conservative technical specification cannot be considered fully resolved. Therefore, this LER remains open, pending further NRC review.
Additional details regarding the NRC's evaluation of corrective actions taken by Entergy to address a previously identified safety concern associated with the SFP (NCV 05000293/2017001-03, Untimely Corrective Actions associated with Boraflex degradation in the Spent Fuel Pool) can be found in Section
4OA2 of this inspection
report.
4OA6 Meetings, Including Exit
On January 25, 2018, the inspectors presented the inspection results to Mr. Brian Sullivan, Site Vice President, and other members of the Entergy 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
- B. Sullivan, Site Vice President
- R. Pitts, General Plant Manager
- G. Blankenbiller, Chemistry Manager
- L. Brown, Site Medical Staff
- D. Calabrese, Emergency Preparedness Manager
- S. Callis, Regulatory Assurance
- K. Connerton, Senior Reactor Operator
- J. Falconieri, EFIN Engineer
- D. Grimes, Design Engineer
- H. Grimes, Engineering Supervisor
- E. Herbert, I&C Superintendent
- G. James, Senior Reactor Engineer
- K. Kampschneider, Electrical Engineer
- D. Lecuye, Operations Training Instructor
- A. Madeiras, NSSS Engineering Supervisor
- R. Miller, Performance Improvement
- P. Miner, Licensing Engineer
- R. Morris, Mechanical Engineering
- L. Pepple, Radiation Protection Supervisor
- E. Perkins, Manager, Regulatory Assurance
- M. Powers, Licensing Specialist
- M. Riffle, Chemistry Supervisor
- F. Russell, PM Engineer
- P. Smith, Operations Support
- R. Swanson, Maintenance Rule Coordinator
- J. Taylor, Superintendent Operations Training
- M. Williams, Licensing Specialist
- J. Whalley, Shift Manager
- S. Wogos, Assistant Engineering Director
- K. Woods, Engineering Supervisor
- G. Zavard, Radiation Protection Supervisor
- A. Zelie, Radiation Protection Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Closed
- 05000293/LER-2017-005-00 LER 10 CFR 50, Appendix J, Option B, Leak Rate
- Criteria Exceeded (Section 4OA3.1)
- 05000293/LER-2017-007-00 LER Potential Inoperability of Safety Relief Valve 3A
(Section 4OA3.2)
Discussed
- 05000293/2016-003-00,
2016-003-01, 2016-003-02 LER Spent Fuel Storage Design Feature Exceeded
(Section 4OA3.3)
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
- 2.2.8, Standby AC Power System (Diesel Generators), Revision 119
- 2.2.108, Diesel Generator Cooling and Ventilation System, Revision 48
- 2.4.167, Flooding, Revision 2 5.2.2, High Winds (Hurricane), Revision 40
- 8.C.40, Seasonal Weather Surveillance, Revision 43
- 8.C.42, Subcompartment Barrier Control Surveillance, Revision 30
Condition Reports
- 2017-9784 2017-10810 2017-12450
- Maintenance Orders/Work Orders
- 488368
Miscellaneous
- C232, Turbine Building Shield Wall Plug Details, Revision 0 ENTCORP19-RPT-001, Pilgrim Nuclear Power Station Flooding Walkdown Summary in Response to 50.54(F) Information Request Regarding NTTF Recommendation 2.3, Revision 0
- PNPS-CS-12-00002, Pilgrim Nuclear Power Station Flooding Walkdown Submittal Report for
- Resolution of Fukushima Near-Term Task Force Recommendation 2.3:
- Flooding, Revision 0
- TDBD-109, Topical Design Basis Document for Internal and External Flooding, Revision 0
Section 1R04: Equipment Alignment
Procedures
- 1.17.1, Potential Seismic Interaction Hazards, Revision 14
- 2.2.19, Residual Heat Removal, Revision 113
- 2.2.21, High Pressure Injection System (HPCI), Revision 85 8.C.24, Operations Equipment Lube Surveillance, Revision 96
Condition Reports
- 2016-3780 2017-9683 2017-11587
Miscellaneous
- Calculation C15.0.3391, Seismic Interaction Calculation for Lead Shielding, Revision 0
Drawings
- M220 SH 1, P&ID Compressed Air System, Revision 78 M220 SH 2, P&ID Compressed Air System, Revision 37 M243, PI&D HPCI System, Revision 55 M244, SH1, HPCI System Piping and Instrumentation Diagram, Revision 31
- M244, SH2, HPCI Turbine Lube and Control Oil Subsystems, Revision 10
- Pilgrim House Drawing, High Pressure Coolant Injection System
Section 1R05: Fire Protection
Procedures
- 5.5.2, Special Fire Procedure, Revision 56
- 5.5.2, Attachment 17, Radwaste Truck Lock El. 23, Revision 57
- 5.5.2, Attachment 21, Diesel Generator Building El. 23, Revision 57
- EN-DC-161, Control of Combustibles, Revision 17
Miscellaneous
- Fire Hazards Analysis - Fire Area 1.9, Fire Zone 1.1, 'A' RHR and CS Pumps Quadrant Fire Hazards Analysis - Fire Area 1.9, Fire Zone 1.15, Standby Liquid Control Pumps &
- Equipment
- Fire Protection Evaluation 37, Electrical Boxes Generic, Revision 4
- SI-FP.1002B-19, Barrier No. 198.506 Radwaste Corridor, Revision 0
Drawings
- A317 SH1, Reactor and Turbine Building Floor Plan At Elevation 23' Fire Barrier System,
- Revision 59 M249, Standby Liquid Control, Revision 29
Section 1R06: Flood Protection Measures
Procedures
- 2.4.167, Flooding, Revision 2
- ARP-C7R, Alarm Response Procedure, Revision 22
Miscellaneous
- M-736, Evaluation of the Fire Protection Piping for Seismic Class II/I Concerns, Revision 0 M1374, Internal Flooding Calculation with Safe Shutdown Evaluation for the PNPS Turbine, RX
- Aux, EDG, Radwaste, Intake, Offgas & Main Stack Buildings, Revision 0
- TDBD-109, Topical Design Basis Document for Internal and External Flooding, Revision 0
Section 1R11: Licensed Operator Requalification Program
Procedures
- 1.3.34, Operations Administrative Policies and Process, Revision 152
- 2.1.14, Station Power Changes, Revision 115
- 2.2.84, Reactor Recirculation System, Revision 112
- 2.4.17, Recirculation Pump(s) Trip, Revision 47 2.4.19, Recirculation Pump MG Set Scoop Tube Lockup, Revision 29 8.9.1, EDG and Associated Emergency Bus Surveillance, Revision 144
- EN-TQ-114, Licensed Operator Requalification Training Program Description, Revision 10
- EN-TQ-210, Conduct of Simulator Training, Revision 10
- OT-8, Operating Training Department Work Instruction, "Simulator Evaluation Guidelines", Revision 21
- TQF-201-IM05, Remedial Training Plan, Revision 9
Condition Reports
- 2015-07787 2015-08073 2016-03226 2016-06447 2016-06635 2016-07224
- 2016-07955 2017-00626 2017-01203 2017-02175 2017-02785 2017-03724
- 2017-05692 2017-05746
- Simulator-Related Test Documents16-002, Manual Scram on High Reactor Level, Event Date 09/06/2016
- 17-001, Rapid Power Reduction due to Chloride Intrusion, Event Date 2/6/17
- EN-OP-200, Plant Transient Response Rules, Revision 3 T.5 - Steady State Verification Testing at 50%, Date Tested 9/28/17 T.5 - Steady State Verification Testing at 80%, Date Tested 7/3/17
- T.5 - Steady State Verification Testing at 100%, Date Tested 6/30/17
- T.8 - CERT 1-1.TST - Manual Scram (Via pushbutton), Date Tested 5/23/2017
- 5/23/2017 T.8 - CERT 1-2. TST - Simultaneous Trip of All Reactor Feed Pumps, Date Tested 5/25/2017
- 5/18/2017
Miscellaneous
Section 1R12: Maintenance Effectiveness
Procedures
- EN-DC-204, Maintenance Rule Scope and Basis, Revision 4
- EN-DC-205, Maintenance Rule Monitoring, Revision 6
- EN-DC-206, Maintenance Effectiveness of Neutron Monitoring Instrumentation, Revision 3
- EN-DC-207, Maintenance Rule Periodic Assessment, Revision 3
Condition Reports
- 2016-0018 2016-0976 2016-1036
- 2016-1812 2016-5289 2017-1010 2017-10164 2017-10204 2017-10797 2017-4555 2017-7400 2017-8352
- Maintenance Orders/Work Orders
- 437846
- 438802
Miscellaneous
- 10 CFR50.65 Maintenance Rule Scoping Basis Document for Neutron Monitoring Instrumentation, Revision 4
- Maintenance Rule (a)(1) Action Plan- Pilgrim Station, Revision 0 MRBD30A, RBCCW System 30A, Revision 4 Pilgrim Periodic Maintenance Effectiveness Assessment A Requirement of 10CFR50.65 (a)(3)
- Operating Cycle 21
- System Health Report Power Range Neutron Monitoring, dated November 2017
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Procedures
- EN-OM-132, Nuclear Risk Management Process, Revision 0
- EN-OP-102, Protective and Caution Tagging, Revision 20
- EN-OP-119, Protected Equipment Postings, Revision 8
- EN-WM-104, Online Risk Assessment, Revisions 15 and 16
Section 1R15: Operability Determinations and Functionality Assessments
Procedures
- 2.2.19.1, Residual Hear Removal System - Shutdown Cooling Mode of Operation, Revision 43 8.5.2.6, RHR Motor-Operated Valve Operability from Alternate Shutdown Panel, Revision 29 8.C.24, Operations Equipment Lube Surveillance, Revision 96
- 8.M.2-1.5.6, RWCU Valves Inboard and Outboard Relay Logic Test - Critical Maintenance, Revision 31
- EN-OP-104, Operability Determination Process, Revision 14
Condition Reports
- 2017-3044 2017-6197 2017-9152 2017-9652 2017-9683 2017-9748
- 2017-9925 2017-10143 2017-12050 2017-12051 2017-12152 2017-12366
- Maintenance Orders/Work Orders
- 486089
- 486601
Miscellaneous
- 257HA465AB, Revision 3
- 257HA465AB, Revision 4
- ELNRC1.2.90.049, Updated Summary of Compliance with Regulatory Guide 1.97, Revision 3
- PDC 94-35
- Updated Final Safety Analysis Report, Revision 30
- V2098, Terry Turbine Maintenance Guide, HPCI Application, Revision 4
Drawings
- E5004, Electrical Schematic Diagram, Containment Spray Motor Operated Valves, Revision 13 E5021, Electrical Schematic Diagram Reactor Water Cleanup System Isolation Valve, Revision E10 M1N39-13 Sheet 1, Elementary Diagram Primary Containment Isolation System, Revision E20 M241 SH 1, Residual Heat Removal System, Revision 88 M244 SH 2, HPCI System Turbine Lube and Control Oil Subsystem, Revision 2
Section 1R18: Plant Modifications
Procedures
- 3.M.3-51, Electrical Termination Procedure, Revision 31
- EN-DC-115, Engineering Change Process, Revision 9
Condition Reports
- 2017-10877 2017-11073
- Maintenance Orders/Work Orders
- 415142
- 434551
- 487100
Miscellaneous
- 0099-0051-CGAP-001, MPR Commercial Grade Item/Service Acceptance Plan, Revision 0
- 0099-0051-EE-001, Pilgrim Space Motor Operated Controllers, Revision 1 Instruction Manual
- For Motor Operated Control, Revision A
- CGI-EVAL-005, Basler Electric Motor Oper ated Controls Commercial Grade Evaluation,
- Revision 10
- ECs 62735, 74577, 74246, 74553
Drawings
- E8-31-4,
- SH 15, Wiring Diagram & Schematic Comb FVR Sizes 1, 2, 3, and 4, Revision 3 E5004, Electrical Schematic Diagram Containment Spray Motor Operated Valves, Revision 14
- E217,
- SH 77, Connection Diagram 480V MCC B17-7 Bkrs B1771, B1773, B1774, B1766, Revision 10 M1H39,
- SH 17, Elementary Diagram Residual Heat Removal System, Revision 16 M6-45-6, Wiring Diagram Diesel Generator 'B' C102 Automatic Voltage Control, Revision 7
- M220, SH 1, P&ID Compressed Air System, Revision 78
- M220, SH 2, P&ID Compressed Air System, Revision 37
Section 1R19: Post-Maintenance Testing
Procedures
- 3.M.1-15, Vibration Monitoring For Preventive Maintenance And Balancing, Revision 56
- 3.M.2-5.6.4, TIP Guide Tube Friction Test, Revision 22
- 3.M.3-51, Electrical Termination Procedure, Revision 31 8.5.2.2.1, LPCI LOOP 'A' Operability, Revision 62 8.5.2.6, RHR Motor Operated Valve Operability from Alternate Shutdown Panel, Revision 29
- 8.5.3.2.1, Salt Service Water Pump Quarterly And Biennial (Comprehensive) Operability And
- 8.5.3.2.1, Salt Service Water Pump Quarterly And Biennial (Comprehensive) Operability And Valve Operability Tests, Revision 35
- 8.9.16.1, Manually Start and Load Blackout Dies el Via the Shutdown Transformer, Revision 54 8.M.2-2.10.2-3, RHR System High Drywell Pressure Auto-Initiation Trip System 'A', Revision 26 9.6, TIP System Operational Checkout, Revision 28
- 8.9.1, Emergency Diesel Generator and Associated Emergency Bus Surveillance, Revision 144
- EN-DC-115, Engineering Change Process, Revision 9
- EN-MA-125, Troubleshooting Control of Maintenance Activities, Revision 21
Condition Reports
- 2017-8612 2017-9838 2017-9870 2017-9875 2017-10080 2017-10142
- 2017-10793
- Maintenance Orders/Work Orders
- 483452
- 485672
- 485798
- 488081
- 52592184
- 52783582
Miscellaneous
- EC 62735 Revision 0 V1247, Recirculation System Pump Speed Controls, Revision 5
Drawings
- E5004, Containment Spray Motor Operated Valves, Revision 14
Section 1R22: Surveillance Testing
Procedures
- 8.5.5.8, RCIC Overspeed Trip Test, Revision 33
- 8.7.4.4, Main Steam Isolation Valve Operability, 60% power, Revision 31
- 8.E.13, RCIC System Instrument Calibration - Critical Maintenance, Revision 60
- 8.M.2-1.5.3.4, Primary Containment Isolation Logic Channel Test, Channel B2, Revision 25 8.M.2-2.10.4.3, HPCI Simulated Automatic Actuation (outboard) Revision 24
Condition Reports
- 2017-10346 2017-10654 2017-11145
- Maintenance Orders/Work Orders
- 2658690
- 52719545
Miscellaneous
- EC 71989, SRV/SSV Setpoint and Tolerance Increase and Replacement, Revision 0
Section 1EP2: Alert and Notification System Evaluation
Procedures
Condition Reports
- 2016-25200 2017-10496
Miscellaneous
- ANS Testing and Maintenance Records, Spring 2016 - Spring 2017
- Letter from FEMA Region III to Pilgrim Steam Electric Station, dated November 7, 2008
- Pilgrim Steam Electric Station Emergency Plan, Revision 61 Pilgrim Nuclear Power Station, Siren Alert Notification System Design Evaluation, Final Report, dated September 2008
- TEMPEST T-112/ T-121 Omni-directional Siren Installation, Operation, Maintenance and Parts Manual, Revision E
Section 1EP3: Emergency Response Organization Staffing and Augmentation System
Procedures
- EP-113, Emergency Preparedness Staff Training, Revision 0
- TQ-113, Emergency Plan Training, Revision 4
Miscellaneous
- 50.54(q) Screens and Evaluations: S2016-06-06-01, Revision 2; S2017-02-16-01;
- S2017-07-03-01; E2017-09-08-01; E2017-09-07-01
- EP-102, Review, Revision, and Distribution of the SSES Emergency Plan and 50.54(Q)
- Evaluations, Revision 7
- On-call pager test results 2016-2017
- Pilgrim Steam Electric Station Emergency Plan, Revision 61
Section 1EP4: Emergency Action Level and Emergency Plan Changes
Procedures
- EP-AD-601, Emergency Action Level Technical Basis Document, Revision 8
Miscellaneous
- Pilgrim Nuclear Power Station Emergency Plan Revision 47
- Pilgrim Nuclear Power Station Emergency Plan Revision 48
Section 1EP5: Maintenance of Emergency Preparedness
Procedures
- SC-233-115, Calibration of the Unit 2 Turbine Building Vent Radiation Monitor System (VERMS) Low Range Noble Gas Channel, Revision 1
- SC-233-116, Calibration of the Unit 2 Turbine Building Vent Radiation Monitor System (VERMS) Accident Channels, Revision 1
Condition Reports
- 2016-02543 2017-02868 2017-18657 2017-18694
Miscellaneous
- Channel
- RITS-15720B, Revision 0
- EP Excellence Plan, Revision 7
- ETE Annual Assessment, 2015 and 2016Focused Area Self-Assessment
- DI-2015-29217
- Focused Area Self-Assessment
- DI-2016-00962
- Focused Area Self-Assessment
- DI-2015-29216
- Letters of Agreement/Memoranda of Understanding 2016, 2017
- NOSP-QA-401, Internal Audits, Revision 1
- NASP-QA-406, Control of Audit Commitments, Revision 13
- Pilgrim Steam Electric Station Emergency Plan, Revision 61
- Pilgrim Steam Electric Station Evacuation Ti me Estimate Sensitivity Study Construction of the South Valley Parkway in Nanticoke, Pennsylvania, dated November 2016
- SI-179-319B, 24 Month Calibration of Containment Area High Radiation Monitoring System
Section 1EP6: Drill Evaluation
Procedures
- EN-EP-306, Drills and Exercises, Revision 8
Miscellaneous
- Pilgrim Nuclear Plant Drill Guide, Drill No. 17-04 Pilgrim Station ERO Green Team Site Drill Report, dated November 17, 2017
Section 2RS2: Occupational
- ALARA Planning and Controls
Procedures
- EN-RP-105, Radiological Work Permits, Revision 18
- EN-RP-106-01, Radiological Survey Guidelines, Revision 4
- EN-RP-108, Radiation Protection Posting, Revision 19
- EN-RP-121-01, Receipt of Radioactive Material, Revision 3
- EN-RP-141, Job Coverage, Revision 8
- EN-RP-141-01, Job Coverage Using Remote Monitoring Technology, Revision 7
- EN-RP-143, Source Control, Revision 13
- EN-RP-152, Conduct of Radiation Protection, Revision 2
- EN-RP-203, Dose Assessment, Revision 10
Condition Reports
- 2017-02897 2017-03802 2017-03826 2017-04042 2017-04673 2017-04743
- 2017-05791 2017-11587
- Self-Assessments and Audit Reports Entergy CFAM RP Observations at Pilgrim Station August 15 - 17, 2017
- PNPS Radiological Support Group 3rd Quarter 2017 Self-Assessment Report, October 1, 2017
Miscellaneous
- 2.5 Year Exposure Reduction Plan 2017 - 2019, Revision 1 ALARA Management Committee Agenda, November 29, 2017
- ALARA Managers Committee Meeting Minutes, July 27, 2017
- RFO-21 Radiation Protection Outage Report, July 25, 2017 RWP Termination and Post Job ALARA Review, RWP NO.
- 2017482 - RFO21 Insulation Support, June 2, 2017
- 2017481 - RFO21 Scaffolding Support, May 23, 2017
- 2017511 - RFO21 MSIVs and
- 2017507 - RFO21 Drywell SRVs, May 21, 2017
- WBC Results for Determination of External or Internal Contamination, April 30, 2017
Section 2RS3: In-Plant Airborne Radioactivity Controls and Mitigation
Procedures
- EN-RP-502, Inspection and Maintenance of Respiratory Protection Equipment, Revision 10
- EN-RP-504, Breathing Air, Revision 4
- EN-RP-505, PortaCount Respirator Fit Testing, Revision 7
Condition Reports
- 2017-01849 2017-05037 2017-06121 2017-06344 2017-06956 2017-08269
- 2017-08348 2017-08843 2017-09272 2017-10349 2017-11764
- Self-Assessments and Audit Reports PNPS Radiological Support Group 3rd Quarter 2017 Self-Assessment Report, October 1, 2017
Miscellaneous
- Air Quality Analysis Form - Service Air 32-HO-4340B, December 18, 2016
- Air Quality Analysis Form - Service Air 32-HO-4340-B, September 25, 2017
- Air Quality Analysis Form - Service Air
- RW-1, June 27, 2017
- Air Quality Analysis Form - SCBA Air Butler Building, March 10, 2017
- Air Quality Analysis Form - SCBA Air, December 18, 2016 Air Quality Analysis Form - Service Air RW Corridor, March 10, 2017 Air Quality Analysis Form - SCBA Air Butler Building, August 8, 2017 Draeger Full Face Air Purifying Respirator Training and Fit Test Record, November 28, 2017
- Emergency SCBA Monthly Routine Matrix, November 27, 2017
- 28, 2017
- EN-RP-505 Attachment 9.4 Quantifit/Portacount Respirator Fit Testing, November 28, 2017
- FPF-GET-RPT, Respiratory Protection Practical Factor Guide, Revision 22
- Fire Tech & Safety of New England, Inc., Ltr. from Bill Dion dated July 21, 2016 RE: Training for Bauer Air Compressor Honeywell Certificate of Calibration No. 20121416L00563, Respirator Test Device Model 35-20- 01, Serial No. L00563, December 14, 2016 Honeywell Certificate of Calibration No. 56112916L01613, Respirator Test Device Model 35-56-
- 30, Serial No. L01613, November 29, 2016
- Honeywell Certificate of Calibration No. 56010616L04330, Respirator Test Device Model 35-56-
- 30, Serial No. L04330, January 6, 2016 Honeywell Certificate of Calibration No, 56061716L01944, Respirator Test Device Model 35-56- 30, Serial No. L01944, June 17, 2016
- Pilgrim Nuclear Power Station - SCBA Flow Check, November 2017
- Posi3 USB Test Results Scott Air Pak 4.5 ID No. 4216 - Functional Test, September 21, 2017
- Posi3 USB Test Results Scott Air Pak 4.5 ID No. 4046 - Functional Test, September 21, 2017
- SCBA Inspection Testing Report, March 17, 2017 SCBA Inspection Testing Report, March 27, 2017 SCBA Inspection Testing Report, March 28, 2017
- SCBA Inspection Testing Report, March 31, 2017
- SCBA Inspection Testing Report, April 3, 2017
- SCBA Inspection Testing Report, April 4, 2017 SCBA Inspection Testing Report, April 5, 2017 SCBA Inspection Testing Report, April 19, 2017
- SCBA Spare Bottle Inventory, October 27, 2017
- SCBA Spare Bottle Inventory, November 28, 2017
- SCBA Regulator Clean and Inspected Matrix, April 5, 2017
- Scott Self-Contained Breathing Apparatus Training and Fit Test Record, November 28, 2017 Scott Air Pack Certificate of Attendance Specialist Level Maintenance for Scott Air-Pak
- 2.2/3.0/4.5 and Fifty SCBA, March 4, 2010
- Scott Air Supplied Products Technician Maintenance and Overhaul Training Certificate, June 8, 2017 Scott Air Supplied Products Technician Maintenance and Overhaul Training Certificate,
- August 1, 2017 TSI Certificate of Testing, PortaCount Pro Model 8038,
- SN 8038152505, August 9, 2017 TSI Certificate of Testing, PortaCount Pro Model 8038,
- SN 8038161904, May 23, 2017
Section 4OA1: Performance Indicator Verification
Procedures
- 7.3.15, Dose Assessment, Revision 1
- 7.3.25, Particulate and Iodine Monitoring at the Main Stack and the Reactor Building Vent, Revision 42
- 7.3.31, Tritium Sampling, Revision 25
- 7.3.37, Noble Gas Effluent Sampling, Revision 39 7.3.48, Airborne Effluent Monitoring of the Turbine Deck and Reactor Feed Pump Bay, Revision 26 7.9.12, Liquid Effluent Releases with RETDAS, Revision 10
- EP-114, Emergency Preparedness Performance Indicators, Revision 1
- EN-LI-114, Regulatory Performance Indicator Process, Revision 8
- EN-FAP-RP-002, Radiation Protection Performance Indicator Program, Revision 3
Condition Reports
- 2017-03156 2017-03826 2017-03833 2017-03965
- 2017-04222
- 2017-04572
- 2017-07040
- 2017-09048 2017-09638
- Self-Assessments and Audit Reports
- NIOS-Cross Functional Area Performance Summaries, July - October 2016, October 25, 2016
- NIOS-Fleet Reports, October 2017
- NIOS-Site Status Report, February 2016
- NIOS-Functional Area Rating, May 2016
- NIOS-Functional Area Rating, June 2016
- NIOS-Functional Area Performance Report-RP, March 29, 2016
- NIOS-Functional Area Performance Report, January 2016
- NIOS-Functional Area Performance Report, February 2017
- NIOS-Functional Area Performance Report, February 2016
- NIOS-Functional Area Performance Report, May2016
- NIOS-Functional Area Performance Report, April 2016
- NIOS-Functional Area Performance Report, March 2016
- NIOS-Status Reports, March 2016
- NIOS-Status Reports, April 2016
- NIOS Status Reports, May 2016
- NIOS Status Reports, January 2017
- NIOS Status Reports, February 2017
- NIOS-Status Reports, March 2017
- NIOS-Status Reports, April 2017
- Performance Review Meeting Report, PNP Radiation Protection, September/October 2016 Performance Review Meeting Report, PNP / Radiation Protection, July/August 2016
Miscellaneous
- Electronic Dosimeter Alarm History Report, January 1, 2016 through June 7, 2017
- EN-LI-114, Regulatory Performance Indicator Process Data Sheet for 4
th Quarter 2016, January
- 4, 2017
- EN-LI-114, Regulatory Performance Indicator Process Data Sheet for 1
st Quarter 2017, April 3,
- 2017
- EN-LI-114, Regulatory Performance Indicator Process Data Sheet for 2
nd Quarter, July 6, 2017
- EN-LI-114, Regulatory Performance Indicator Process Data Sheet for 3
rd Quarter, October 4,
- 2017
- NDAP-QA-0737, Reactor Oversight Process (R
- OP) Performance Indicators, Revision 18 Pilgrim Nuclear Power Station Liquid Effluent Release Permit Log, November 18, 2017
- Pilgrim Nuclear Power Station Liquid Effluent Release Permit Report
- 2017001, July 13, 2017
- Pilgrim Nuclear Power Station Liquid Effluent Release Permit Report
- 2017002, November 18,
- 2017 Pilgrim Monthly Dose Summary Report: Percent of ODCM Effluent Control Limits for Gaseous and Liquid Effluent Releases, November 3, 2017
Section 4OA2: Problem Identification and Resolution
Procedures
- 4.3, Fuel Handling, Revisions 136 and 140
- EN-DC-205, Maintenance Rule Monitoring, Revision 6
- EN-DC-206, Maintenance Rule (a)(1) Process, Revision 3
- EN-DC-153, Preventive Maintenance Component Classification, Revision 14
- EN-DC-324, Preventive Maintenance Program, Revision 18
- EN-LI-102, Corrective Action Process, Revision 29
- EN-LI-104, Self-Assessment and Benchmark Process, Revision 13
Condition Reports
- 2016-02056 2016-02061 2016-02205 2016-05555 2016-05871 2016-07115
- 2016-07243 2016-07486 2016-07554 2016-07555 2016-07720 2016-08708
- 2016-09147 2017-01650 2017-02125
Miscellaneous
- Item Control Area Transfer Forms 2017-32 through 2017-39
- LO-PNPLO-2016-00039, Preventive Maintenance Focused Assessment Plan, 8/17/16 Maintenance Rule (a)(1) Evaluation, System 30A, RBCCW, 8/30/17
- Maintenance Rule (a)(1) Evaluation, System 24, Reactor Building Isolation System, 3/7/17
- Maintenance Rule (a)(1) Evaluation, System 29, Service Water System, 8/16/17
- Maintenance Rule (a)(1) Evaluation, System 31, Instrument Air, 7/26/17 Maintenance Rule (a)(1) Evaluation, System 31, Instrument Air, 3/6/17
- Operability Evaluation
- OE-CR-PNP-2016-02205, Revision 3
- Operability Evaluation
- OE-CR-PNP-2016-02205, Revision 4
- Operability Evaluation
- OE-CR-PNP-2016-02205, Revision 5
- Pilgrim Technical Specifications
- PNPS Maintenance Rule Systems Status, 8/29/2017 Project Plan for Maintenance Rule Program Improvements, August 2016 Project Plan for Preventive Maintenance Program Improvements, January 2017
- Project Plan for Preventive Maintenance Program Improvements, June 2017
- Root Cause Evaluation
- CR-PNP-2016-02205, Boraflex Panel RR35 South has 36.4 inches of Cumulative Gap, Revision 0
Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion
Procedures
- 4.3, Fuel Handling, Revision 140
- EN-LI-102, Corrective Action Program, Revision 30
Condition Reports
- 2016-02205 2017-02125 2017-10190 2017-11887
Miscellaneous
- Altran Report 17-0192-TR-003, Electrical Testing and Analysis of
- SV-203-3A (S/N 107) and Valve S/N 106, Revision 1, August 2017
- Critical Decision Document, dated 09/29/2017 Equipment failure evaluation,
- LER 2016-003-00, Spent Fuel Storage Design Feature Exceeded
- LER 2016-003-01, Spent Fuel Storage Design Feature Exceeded
- LER 2016-003-02, Spent Fuel Storage Design Feature Exceeded
- Pilgrim Technical Specifications
- Root Cause Evaluation, SRV Operability, CR-PNP-2017-05067