IR 05000293/2015004

Integrated Inspection Report 05000293/2015004, October 1, 2015 Through December 31, 2015

ML16042A327
Person / Time
Site:	Pilgrim
Issue date:	02/11/2016
From:	Arthur Burritt NRC/RGN-I/DRP/PB5
To:	Dent J Entergy Nuclear Operations
Burritt A
References
IR 2015004
Download: ML16042A327 (53)

Text

{{#Wiki_filter:ary 11, 2016

SUBJECT:

PILGRIM NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000293/2015004

Dear Mr. Dent:

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed report documents the inspection results, which were discussed on January 25, 2016, with you and other members of your staff.

NRC Inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The inspectors documented four findings of very low safety significance (Green) in this report.

All four of these findings involve violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at PNPS. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at PNPS. In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, /RA/ Arthur Burritt, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-293 License No. DPR-35

Enclosure:

Inspection Report 05000293/2015004 w/Attachment: Supplementary Information

REGION I== Docket No. 50-293 License No. DPR-35 Report No. 05000293/2015004 Licensee: Entergy Nuclear Operations, Inc (Entergy) Facility: Pilgrim Nuclear Power Station Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: October 1, 2015 through December 31, 2015 Inspectors: E. Carfang, Senior Resident Inspector B. Scrabeck, Resident Inspector J. Pfingstien, Reactor Engineer S. Elkhiamy, Project Engineer B. Dionne, Health Physicist J. DeBoer, Emergency Preparedness Inspector T. Dunn, Operations Engineer T. Hedigan, Operations Engineer P. Presby, Operations Engineer T. Fish, Senior Operations Engineer Approved By: Arthur Burritt, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY

Inspection Report 05000293/2015004; 10/01/2015 - 12/31/2015; Pilgrim Nuclear Power Station (PNPS); Problem Identification and Resolution and Follow-Up of Events and Notices of Enforcement Discretion.

This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. The inspectors identified four non-cited violations (NCVs), all of which were of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red)and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of U.S. Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Initiating Events

Green.

A self-revealing Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion III, Design Control, was identified because Entergy did not use the correct work planning and design controls to repair the support for the nitrogen supply line for the 1C inboard main steam isolation valve (MSIV). Specifically, inadequate design controls led to a failed horizontal unistrut support for the nitrogen supply line to the 1C MSIV, resulting in the header resting on the main steam line. This caused vibration-induced cyclic failure of the nitrogen supply line, closure of 1C MSIV, and a plant scram. The damaged line was modified and repaired using an additional unistrut for support as determined by the engineering change process. Entergy entered the issue into the corrective action program (CAP) under condition report (CR) 2015-07285.

This finding is more than minor because it is associated with the Initiating Events cornerstone attribute of equipment performance and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure of the pneumatic supply header support resulted in a plant scram due to the vibration induced cyclic failure of the nitrogen supply line and subsequent closure of 1C MSIV. In accordance with IMC 0609.04 and Exhibit 1 of IMC 0609, Appendix A, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affect mitigation equipment. The inspectors determined this finding does not have a cross-cutting aspect because the performance deficiency occurred in 2001 and is not indicative of current performance.

       (Section 4OA3)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, when Entergy did not determine the cause of a significant condition adverse to quality (SCAQ). Specifically, a causal evaluation was not performed for a failed safety-related relay that ensured the automatic operation of the low pressure coolant injection (LPCI) system injection valves in a degraded voltage condition.

Entergy replaced the failed relay and restored LPCI to an operable status on May 10, 2015. Entergy entered the issue into the CAP as CR 2015-9762.

This finding is more than minor because it is associated with the Mitigating System cornerstone attribute of equipment performance and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The failure to identify the cause and extent of condition of the relay failure as directed by site procedures could result in repeat events which adversely affect safety system availability. In accordance with IMC 0609.04 and Exhibit 2 of IMC 0609, Appendix A, the inspectors determined that this finding was of very low safety significance (Green)because the finding did not involve the design of a mitigating structure, system, or component (SSC) or a loss of function of a train or system for greater than the technical specification (TS) allowed outage time. The inspectors determined this finding has a cross-cutting aspect in Human Performance, Procedure Adherence, because individuals did not recatergorize the CR to a higher level requiring a causal evaluation, as required by EN-LI-102 when a licensee event report (LER) was issued. The site also did not retain the failed safety-related part, as required by EN-MA-101-02. [H.8] (Section 4OA3)

Green.

The inspectors identified an NCV of TS 5.4.1, Procedures, because Entergy was not adequately maintaining procedures listed in Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978. Specifically, the inspectors identified several examples where Entergy staff inappropriately used Entergy procedure EN-OP-112, Night and Standing Orders, to implement procedure changes instead of PNPS quality assurance procedure NOP98A1, Procedure Process. Entergy entered the issue into the CAP as CR 2015-09233.

The performance deficiency was determined to be more than minor because if left uncorrected it has the potential to lead to a more significant safety concern. Specifically, the inspectors determined the issue was similar to Example 4.a of IMC 0612, Appendix E, which states that an insignificant procedure error would be more than minor if the licensee routinely failed to adhere to the applicable procedure. The inspectors evaluated the finding using IMC 0609, Attachment 4 and Appendix A. Using Exhibit 2 of Appendix A, the inspectors determined this finding was of very low safety significance (Green) because it did not involve a design or qualification deficiency, it would not lead to a potential or actual loss of system or safety functions, it did not involve the loss or degradation of equipment or a function specifically designed to mitigate a seismic, flooding, or severe weather initiating event, and it did not involve the total loss of any safety function as identified in Exhibit 4. The inspectors determined that the finding had a cross-cutting aspect in Problem Identification and Resolution, Resolution, because, Pilgrim did not adhere to the CAP evaluation and corrective action program timeliness requirements that would have likely led them to use the appropriate procedure change process. [P.3] (Section 4OA2)

Cornerstone: Barrier Integrity

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, because Entergy did not adequately implement corrective actions for an identified condition adverse to quality. Specifically, Entergy did not implement all of the procedure changes needed to ensure shutdown cooling was placed in service in a timely manner after plant shutdown in preparation for or during a severe winter storm.

Entergy entered this issue into the CAP as CR 2016-0120 and updated procedure 2.1.42 to meet the requirements of the corrective actions in CR 2015-0558. Inspectors verified that the new procedure revision included the required actions.

The inspectors determined this performance deficiency is more than minor because it is associated with the procedure quality attribute of the Barrier Integrity cornerstone, and adversely affected its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.

The inspectors determined that this finding is of very low safety significance (Green) in accordance with IMC 0609, Attachment 4 and Exhibit 3 of Appendix A, because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, and heat removal components. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Entergy staff did not ensure procedure revisions were made in accordance with the requirements of EN-LI-102, Corrective Action Program. [H.8] (Section 4OA2)

REPORT DETAILS

Summary of Plant Status

The unit began the inspection period at 100 percent power. On October 20, 2015, operators reduced power to approximately 50 percent to perform a main condenser thermal backwash.

The unit returned to 100 percent power on October 21, 2015 and remained at or near 100 percent power for the remainder of the inspection period.

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 Entergys readiness for the onset of seasonal low temperatures. The December 15, 2015, review focused on the cold weather preparations and actions from the January 12, 2015, storm. Walkdowns of the auxiliary boiler and emergency diesel generators (EDGs) were included in the inspection. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), TSs, control room logs, and the 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 Entergys 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. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Entergys preparations prior to the potential landfall of Hurricane Joaquin on October 1-2, 2015. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The review focused on Entergys preparations for the storm. The inspectors reviewed station procedures including Entergys coastal storm, high wind, and severe weather procedures. The inspectors performed walkdowns of the site to ensure that station personnel had identified issues that could challenge the operability of systems during high wind and winter storm conditions. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.

b. Findings

No findings were identified. ==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Station blackout diesel generator with the B EDG out of service (OOS) for planned maintenance on October 15, 2015 A standby gas treatment system while B standby gas treatment was OOS for planned maintenance on November 10, 2015 Station blackout diesel generator following emergent maintenance on December 18, 2015 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 UFSAR, TSs, work orders, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Entergy staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

The week of December 21, 2015, inspectors performed a complete system walkdown of accessible portions of the B EDG to verify the existing equipment lineup was correct.

The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify as-built system configuration matched plant documentation, and that system components and support equipment remained operable. The inspectors confirmed that systems and components were aligned correctly, free from interference from temporary services or isolation boundaries, environmentally qualified, and protected from external threats. The inspectors also examined the material condition of the components for degradation and observed operating parameters of equipment to verify that there were no deficiencies. For identified degradation, the inspectors confirmed the degradation was appropriately managed by the applicable aging management program. Additionally, the inspectors reviewed a sample of related CRs and work orders to ensure Entergy appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified. ==1R05 Fire Protection