IR 05000293/2015003
| ML15317A030 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/12/2015 |
| From: | Raymond Mckinley NRC/RGN-I/DRP/PB5 |
| To: | Dent J Entergy Nuclear Operations |
| McKinley R | |
| References | |
| IR 2015003 | |
| Download: ML15317A030 (45) | |
Text
{{#Wiki_filter:ber 12, 2015
SUBJECT:
PILGRIM NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000293/2015003
Dear Mr. Dent:
On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (Pilgrim). The enclosed inspection report documents the inspection results, which were discussed on October 22, 2015, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one Severity Level IV non-cited violation (NCV), three NRC-identified NCVs of very low safety significance (Green) and one self-revealing NCV of very low safety significance (Green). These findings were determined to involve violations of NRC requirements. However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as NCVs, consistent with Section 2.3.2. of the NRC Enforcement Policy. If you contest any 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 Pilgrim. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Pilgrim. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the 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/ Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-293 License No. DPR-35
Enclosure:
Inspection Report 05000293/2015003 w/Attachment: Supplementary Information
REGION I== Docket No. 50-293 License No. DPR-35 Report No. 05000293/2015003 Licensee: Entergy Nuclear Operations, Inc. (Entergy) Facility: Pilgrim Nuclear Power Station Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: July 1, 2015 through September 30, 2015 Inspectors: E. Carfang, Senior Resident Inspector B. Scrabeck, Resident Inspector B. Dionne, Health Physicist K. Mangan, Senior Reactor Inspector T. Dunn, Operator Licensing Examiner J. Pfingsten, Project Engineer Approved By: Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000293/2015003; 07/01/2015 - 09/30/2015; Pilgrim Nuclear Power Station (Pilgrim); Maintenance Effectiveness, Operability Determinations and Functionality Assessments, Plant Modifications, and Radiological Hazard Assessment and Exposure Controls.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one Severity Level IV non-cited violation (NCV) and three findings of very low safety significance (Green), which were NCVs. A self-revealing finding of very low safety significance (Green) was also identified. 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 (SDP), dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of 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: Mitigating Systems
- Green.
The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (a)(2), because Entergy did not adequately demonstrate that the performance of the main control room (MCR) annunciators was effectively controlled through performance of appropriate preventive maintenance. Specifically, Entergy did not identify and properly account for functional failures of the MCR annunciators in February 2015 and May 2015, and did not recognize that the train exceeded its performance criteria and required a Maintenance Rule (a)(1) evaluation. Entergy entered the issue into the corrective action program under condition report (CR) 2015-7986 and CR 2015-7988 and is performing the Maintenance Rule (a)(1) evaluation.
The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects 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). Specifically, following the three failures of the main control annunciator panel in February 2015 and May 2015, Entergy did not identify the failures as functional failures, and consequently, did not establish goals and monitoring criteria in accordance with 10 CFR 50.65(a)(1). The inspectors evaluated the significance of this finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power. The finding is of very low safety significance (Green)because the finding was not a design or qualification deficiency, did not represent a loss of safety function, and did not represent an actual loss of function of a single train for greater than its technical specification (TS) allowed outage time. The inspectors determined that the finding has a cross cutting aspect in the area of Problem Identification and Resolution, Evaluation, in that the organization thoroughly evaluates issues to ensure that resolution addresses causes and extent of conditions commensurate with their safety significance.
Specifically, Entergy identified all of the failures of the MCR annunciator system, however, Entergy did not include maintenance rule monitoring functions in the evaluation of the MCR annunciator system failures. [P.2] (Section 1R12)
- Green.
The inspectors identified a Green NCV of TS 3.5.F, Minimum Low Pressure Cooling and Diesel Generator Availability, for failure to adequately perform TS surveillance requirement (SR) 4.5.F.1 to determine that the B emergency diesel generator (EDG) was not inoperable due to a common cause failure, or to perform the TS-specified EDG monthly surveillance test, within 24 hours of the time that operators determined that the A EDG was inoperable. Specifically, on July 1, 2015, after the A EDG was declared inoperable due to unexpected annunciator response during engine pre-start checks, and again on July 28, 2015, when the A EDG was declared inoperable due to reactive load oscillations during a routine surveillance, Entergy performed an inadequate common cause failure determination that did not address the failure mechanism of the inoperable EDG, which had not yet been determined. This issue has been entered into the corrective action program as CR 2015-8073, and additional guidance has been provided to the operations crew in the form of an operations section standing order, pending permanent corrective actions.
The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the operability of the B EDG was not verified as required, either through determination that it was not inoperable due to a common cause failure or through performance of the monthly TS-required surveillance. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, and did not represent an actual loss of function of a single train for greater than its TS allowed outage time. This finding had a cross-cutting aspect in the area of Human Performance, Conservative Bias, because Entergy did not use decision making practices that emphasized prudent choices over those that are simply allowed, or in this case those choices that were perceived to be allowed.
Specifically, Entergys credited SR 4.5.F.1 based on an administrative review instead of more deliberate actions or evaluations that would be necessary to confirm that a common cause condition did not exist. [H.14] (Section 1R15)
- Green.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Instructions, Procedures, and Drawings, when Entergy failed to adequately assess the operability of the shutdown transformer as required by EN-OP-104, Operability Evaluation Process.
Specifically, Entergy failed to evaluate changes to the 23 kilovolt (kV) line supplying the shutdown transformer that resulted in the shutdown transformer incorrectly being called operable. This issue has been entered into the corrective action program under CR 2015-7787. Entergy is conducting a causal analysis and operators have been given interim guidance to declare the shutdown transformer inoperable under similar conditions.
This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, a modification was made to the site, as described in the Updated Final Safety Analysis Report (UFSAR) that was unrecognized by Entergy during the operability determination process and resulted in the incorrect operability determination for the shutdown transformer. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, and did not represent an actual loss of function of a single train for greater than its TS allowed outage time. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, in that individuals did not recognize and plan for the possibility of mistakes, latent problems, or inherent risk, even while expecting successful outcomes. Specifically, personnel did not fully evaluate the change to the 23 kV line, and instead relied on a previous incorrect operability determination to justify declaring the shutdown transformer operable. [H.12] (Section 1R15) Severity Level IV. Inspectors identified a Severity Level IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments, in that Entergy implemented a change to its facility that required a TS change without seeking a license amendment as required by 10 CFR 50.90.
Specifically, the inspectors identified that Entergy altered the configuration of the 23 kV line to the shutdown transformer contrary to the UFSAR and that configuration required a TS change through a license amendment. Entergy is performing a causal analysis, updating required procedures, and issued a standing order to ensure the site remains in TS compliance with only the 23 kV line 108 able to supply power to maintain the shutdown transformer operable.
The performance deficiency was dispositioned using the traditional enforcement process because it could potentially impede or impact the regulatory process. In accordance with the NRC Enforcement Manual, Revision 9, Part II, Enforcement of 10 CFR 50.59 and Related FSAR, Sections 2.1.3.E.1 and 2.1.3.E.6, this violation was determined to be more than minor because Entergy failed to request a license amendment prior to implementation. In accordance with the NRC Enforcement Policy Section 6.1, the inspectors used the SDP to inform the severity of the 10 CFR 50.59 violation, based upon the impact on the offsite alternating current (AC) power sources. As referenced in Section 1R15, the technical aspects of this issue screen to
- Green.
Accordingly, per Section 6.1.d of the NRC Enforcement Policy, the severity of the violation of 10 CFR 50.59 was determined to be Severity Level IV, as it resulted in conditions evaluated as having very low safety significance (Green) by the SDP. There is no cross-cutting aspect associated with this violation because cross-cutting aspects are not assigned to tradition enforcement violations.
(Section 1R18)
Cornerstone: Occupational Radiation Safety
- Green.
The inspectors identified a self-revealing Green NCV of TS 5.4.1 procedure compliance associated with Regulatory Guide (RG) 1.33, Appendix A. Specifically, during Pilgrim refueling outage (RFO) 20, radiation workers did not comply with radiation work permit (RWP) instructions to Contact Radiation Protection prior to each entry to discuss work scope and to allow for [radiation protection] RP survey when accessible surfaces are exposed. When identified, Entergy immediately stopped work on this project, conducted a safety meeting between RP and the Entergy contractors, performed the RP surveys on the accessible surfaces, and enforced the RWP respiratory protection requirements for the remaining work. This issue was entered into the Entergy corrective action program (CR 2015-07577).
The inspectors determined that the performance deficiency was more than minor because it affected the Radiation Safety - Occupational Radiation Safety Cornerstone attribute of program and process associated with exposure/contamination controls and because it resulted in the unintended internal exposure of five workers. It was determined to be of very low safety significance (Green) because it was not related to as low as is reasonably achievable (ALARA), it did not involve an overexposure or a potential for an overexposure, and because the licensees ability to assess dose was not compromised. A cross-cutting aspect in Human Performance, Procedure Adherence, was assigned for individuals failing to follow processes, procedures, and work instructions, in that workers did not follow the verbal and written instructions on the RWP to discuss the scope of work with RP prior to beginning the work. Radiation workers did not follow the verbal and written instructions provided on the RWP to discuss the work scope work and for RP to survey newly accessible areas during the work. [H.8] (Section 2RS1)
REPORT DETAILS
Summary of Plant Status
The unit began the inspection period at 100 percent power. On August 9, 2015, operators reduced power to 90 percent based on salt service water intake temperatures, then returned to 100 percent power the same day. On August 19, 2015, operators reduced power to approximately 50 percent to perform a thermal backwash of the main condenser and returned to 100 percent power on August 20, 2015. On August 22, 2015, the unit scrammed when the 1C inboard main steam isolation valve closed due to a nitrogen line leak. The unit returned to 100 percent power on August 27, 2015. The unit 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
External Flooding
a. Inspection Scope
During the week of September 7, 2015, the inspectors performed an inspection of the external flood protection measures for Entergy. The inspectors reviewed TS, procedures, design documents, and the UFSAR, 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 general site walkdown of all external areas of the plant to ensure that Entergy had maintained flood protection barriers in accordance with design specifications. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if Entergy planned or established adequate measures to protect against external flooding events. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified. ==1R04 Equipment Alignment Partial System Walkdowns (71111.04 - 4 samples)
a. Inspection Scope
== The inspectors performed partial walkdowns of the following systems: B Standby gas treatment system (SGTS) while the A SGTS was out of service on July 28, 2015 - July 29, 2015 B Reactor building closed cooling water (RBCCW) loop while the A RBCCW loop was out of service on August 5, 2015 A and B EDGs while the station blackout diesel generator and the shutdown transformer were out of service for maintenance and testing on August 26, 2015 - August 27, 2015 High pressure coolant injection (HPCI) system while the reactor core isolation cooling system was out of service for planned maintenance on September 29, 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, TS, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.
The inspectors also reviewed whether Entergy staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b. Findings
No findings were identified. ==1R05 Fire Protection