IR 05000293/2009003
Download: ML092020460
Text
July 20, 2009
Mr. Kevin Bronson Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2009003
Dear Mr. Bronson:
On June 30, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed report documents the results, which were discussed on July 7, 2009, with Mr. Stephen Bethay, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The report documents one self-revealing finding of very low safety significance (Green). The finding was determined to involve a violation of NRC requirements. However, because of its very low safety significance and because it was entered into your corrective action program, the NRC is treating the finding as a non-cited violation (NCV), in accordance with Section VI.A.1 of the NRC's Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-
0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at the PNPS. In addition, if you disagree with the characterization of 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 Senior Resident Inspector at PNPS. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
2 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Donald E. Jackson, Chief Projects Branch 5 Division of Reactor Projects Docket No. 50-293 License No. DPR-35
Enclosure:
Inspection Report 05000293/2009003
w/Attachment:
Supplemental Information cc w/encl: Vice President, Operations, Entergy Nuclear Operations Vice President, Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety & Licensing, Entergy Nuclear Operations Senior Vice President and COO, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations R. Walker, Director, Radiation Control Program, Commonwealth of Massachusetts The Honorable Therese Murray The Honorable Vincent DeMacedo Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Committee Plymouth Civil Defense Director D. O'Connor, Massachusetts Secretary of Energy Resources J. Miller, Senior Issues Manager Office of the Commissioner, Massachusetts Department of Environmental Protection Office of the Attorney General, Commonwealth of Massachusetts Electric Power Division, Commonwealth of Massachusetts R. Shadis, New England Coalition Staff D. Katz, Citizens Awareness Network W. Meinert, Nuclear Engineer J. Giarrusso, MEMA, SLO Commonwealth of Massachusetts, Secretary of Public Safety
SUMMARY OF FINDINGS
.................................................................................................................. 3
REPORT DETAILS
.............................................................................................................................. 4
REACTOR SAFETY
............................................................................................................................ 4 1R01 Adverse Weather Protection .................................................................................. 4 1R04 Equipment Alignment ............................................................................................. 5 1R05 Fire Protection ........................................................................................................ 6 1R06 Flood Protection Measures ..................................................................................... 6 1R08 In-service Inspection (ISI) ....................................................................................... 7 1R11 Licensed Operator Requalification Program .......................................................... 9 1R12 Maintenance Effectiveness .................................................................................... 9 1R13 Maintenance Risk Assessments and Emergent Work Control ............................ 10 1R15 Operability Evaluations ......................................................................................... 10 1R18 Plant Modifications ................................................................................................ 11 1R19 Post-Maintenance Testing .................................................................................... 13 1R20 Refueling and Other Outage Activities .................................................................. 14 1R22 Surveillance Testing ............................................................................................. 18 1EP6 Drill Evaluation ...................................................................................................... 18
RADIATION SAFETY
........................................................................................................................ 19 2OS1 Access Control To Radiologically-Significant Areas ............................................ 19 2OS2 As Low As Reasonably Achievable (ALARA) Planning and Controls ................. 22
OTHER ACTIVITIES
[OA] ................................................................................................................. 24
4OA1 Performance Indicator (PI) Verification
................................................................ 24
4OA2 Identification and Resolution of Problems
............................................................ 25
4OA3 Event Follow-up
.................................................................................................... 28
4OA5 Other Activities ....................................................................................................... 31 4OA6 Meetings, Including Exit ......................................................................................... 31
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
.......................................................................................................... A-1
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED ............................................................... A-1
LIST OF DOCUMENTS REVIEWED
.............................................................................................. A-2
LIST OF ACRONYMS
- ...... ............................................................................................................. A-13
- OF [[]]
- FINDIN [[]]
GS IR 05000293/2009003; 04/01/2009-06/30/2009; Pilgrim Nuclear Power Station; Refueling and
Other Outage Activities
The report documents the results of a three-month period of inspection by the resident and region
based inspectors. One Green finding was identified, which was determined to be a non-cited
violation (NCV). The significance for most findings is indicated by their color (Green, White,
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process"
(SDP). The cross-cutting aspect for each finding was determined using IMC 0305, "Operating
Reactor Assessment Program." Findings for which the SDP does not apply may be Green or be
assigned a severity level after
NRC's program for overseeing the
safe operation of commercial nuclear power reactors is described in
- NUR [[]]
EG-1649, "Reactor
Oversight Process," Revision 4, dated December 2006.
Cornerstone: Barrier Integrity * Green. A Green self-revealing non-cited violation (NCV) of Technical Specification 5.4.1 "Procedures," was identified, because Entergy's refueling bridge operators did
not continuously monitor a Double Blade Guide (DBG) that was moved into the
core to ensure the DBG did not encounter any obstructions, interferences, or other
abnormal indications specified by Pilgrim Procedure 4.3, Revision 113, "Fuel
Handling." Specifically, the failure to properly implement the procedure resulted in
damaging the refueling mast when the mast was moved and still latched to the
CR-PNP-
2009-2083. Corrective actions included replacing a section of the refueling mast,
replacing the grapple camera, conducting additional training with the refueling
crews including a table top dry run, performing a Human Performance Error
Review, and requiring Operations Senior Management to provide oversight during
one hour of each three hour shift when the refueling crew was on the bridge moving
fuel. The inspectors determined that the finding was more than minor because the
finding was associated with the human performance attribute of the Barrier Integrity
Cornerstone and adversely affected the cornerstone's objective to provide
reasonable assurance that physical design barriers (i.e. fuel cladding) protect the
public from radionuclide releases caused by accidents or events. The risk
significance of the performance deficiency was determined to be of very low safety
significance (Green) using IMC 0609, "Significance Determination Process,"
0609.04, "Phase 1 Initial Screening and Characterization of Findings."
Specifically, since the finding did not affect spent fuel pool cooling or inventory and
since no fuel or control rod was damaged when the mast was bent, the finding was
determined to be of very low safety significance. The finding has a cross cutting
aspect in Human Error Prevention Techniques in the Work Practices component of
the Human Performance area. Specifically, Entergy did not employ effective self
and peer checking techniques such that refueling activities were performed safely.
(H.4.a of
- REPORT [[]]
DETAILS
Summary of Plant Status
Pilgrim Nuclear Power Station (PNPS) began the inspection period operating at 100 percent
reactor power.
- PN [[]]
PS started end-of-cycle power reduction on April 1, 2009 and was shutdown on
April 17, 2009, to begin refueling outage (RFO) 17. Following completion of RFO 17 activities, a
reactor start up was conducted on May 18, 2009, and the plant returned to 100 percent reactor
power on May 22, 2009. On June 18, 2009, operators reduced power to 70 percent reactor power
to perform a control rod pattern adjustment and to troubleshoot the "B" feedwater regulating valve.
Operators restored the plant to 100 percent reactor power on June 19, 2009, and operated at or
near 100 percent reactor power for the remainder of the inspection period. 1.
SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01)
.1 Seasonal Susceptibility
a. Inspection Scope (1 sample)
The inspectors performed a review of severe weather preparations during the week of
June 15, 2009, to evaluate the site's readiness for the onset of hurricane season, including
the readiness of two risk-significant systems, the intake structure and the switchyard. The
inspection examined selected equipment and supporting structures to determine if they
were configured in accordance with Entergy procedures and if adequate controls were in
place to ensure functionality of the systems. The inspectors reviewed selected steps in
Entergy Procedure 2.1.37, Revision 25, "Coastal Storm Preparation and Actions," to
ascertain if the steps had been completed. The inspectors performed partial walkdowns of
the intake structure and switchyard to determine the adequacy of equipment protection
from the effects of hurricanes. The documents reviewed during this inspection are listed in
the Attachment.
b. Findings
No findings of significance were identified.
.2 Alternating Current (AC) Power System Readiness
a. Inspection Scope (1 sample) The inspectors performed a review of Entergy's offsite and alternate
- AC power system readiness for susceptibilities during adverse weather. The inspectors reviewed Entergy's plant features and procedures for operation and continued availability of offsite and alternate
AC power systems to determine if they were appropriate. The inspection focused
on procedures affecting these areas and communication protocols between the
transmission system operator (TSO) and Entergy to verify that appropriate information
would be exchanged when issues arise that could impact the offsite power system.
The inspectors also reviewed Entergy's procedures to ensure that they addressed actions
to be taken when notified by the TSO to transfer safety-related loads to the onsite power
supply, compensatory actions to be performed if it were not possible to predict grid
conditions, reassessment of plant risk based on maintenance activities which could affect
grid reliability, and required communications between Entergy and the TSO. The documents reviewed during this inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment (71111.04)
.1 Partial System Walkdowns (71111.04Q)
a. Inspection Scope (3 samples)
The inspectors performed three partial system walkdowns during this inspection period.
The inspectors reviewed the documents listed in the Attachment to determine the correct
system alignment. The inspectors performed a partial walkdown of each system to
determine if the critical portions of the selected systems were correctly aligned in
accordance with these procedures and to identify any discrepancies that may have had an
effect on operability. The walkdowns included selected control switch and valve position checks, and verification of electrical power to critical components. Finally, the inspectors
evaluated other elements, such as material condition, housekeeping, and component
labeling. The following systems were reviewed based on their risk significance for the
given plant configuration: * Reactor Building Closed Cooling Water System "A" in Cross-Tie; * Residual Heat Removal (RHR) "B" while RHR "A" was in Shutdown Cooling Mode; and * Emergency Diesel Generator "A" following Simulated Loss of Offsite Power Testing
b. Findings No findings of significance were identified.
.2 Complete System Walkdown (71111.04S)
a. Inspection Scope (1 sample) The inspectors completed a detailed review of the Reactor Core Isolation Cooling (RCIC)
system to assess the functional capability of the system. The inspectors performed a walkdown of the system to determine whether the critical components, such as valves,
circuit breakers, and control switches, were aligned in accordance with operating
procedures and to identify any discrepancies that could have an effect on operability. The inspectors discussed system health with the system engineer and conducted a review of
outstanding maintenance work orders to determine whether the deficiencies significantly
affected the
- RC [[]]
IC system function. The inspectors also reviewed recent condition reports
(CRs) to determine whether
- RC [[]]
IC equipment problems were being identified and
appropriately resolved. The documents reviewed during this inspection are listed in the
Attachment.
b. Findings No findings of significance were identified.
1R05 Fire Protection (71111.05) Fire Protection - Tours (71111.05Q)
a. Inspection Scope (5 samples)
The inspectors performed walkdowns of five fire protection areas during the inspection
period. The inspectors reviewed Entergy's fire protection program to determine the
required fire protection design features, fire area boundaries, and combustible loading
requirements for the selected areas. The inspectors walked down these areas to assess
Entergy's control of transient combustible material and ignition sources. In addition, the
inspectors evaluated the material condition and operational status of fire detection and
suppression capabilities, fire barriers, and any related compensatory measures. The inspectors then compared the existing condition of the areas to the fire protection program
requirements to determine whether all program requirements were met. The documents
reviewed during this inspection are listed in the Attachment. The fire protection areas
reviewed were: * Fire Area 1.30, Fire Zone 1.30, Drywell Areas; * Fire Area 3.2, Fire Zone 3.2, Cable Spreading Room; * Fire Area 1.10, Fire Zone 1.23, Standby Gas Treatment Systems Room; * Fire Areas 1.10 and 4.3, Fire Zones 4.2 and 4.4, Emergency Diesel Generator Day Tanks Rooms "A" and "B"; and * Fire Area 1.10, Fire Zone 1.10B, Traversing Incore Probe Room. b. Findings No findings of significance were identified.
1R06 Flood Protection Measures (71111.06) Internal Flooding Inspection
a. Inspection Scope (1 sample) The inspectors walked down the "A" Switchgear Room, Flood Zone TB37Y, and
associated flood propagation pathways, to assess the effectiveness of Entergy's internal
flood control measures. The inspectors assessed the condition of floor drains, walls, and
doors. The inspectors also evaluated whether potential sources of internal flooding were
analyzed and if operators could adequately respond to an internal flooding event. The
documents reviewed during this inspection are listed in the Attachment.
b. Findings No findings of significance were identified. 1R08 In-service Inspection (ISI) (71111.08) a. Inspection Scope (1 sample) The purpose of this inspection was to assess the effectiveness of Entergy's
- ISI [[program for monitoring degradation of reactor pressure vessel internals, reactor coolant system boundary, risk significant piping system boundaries, and the containment boundary. The inspector assessed the in-service inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (]]
- NRC Regulatory Requirements. The inspector selected a sample of nondestructive examination (NDE) activities for observation and also performed a documentation review of additional
- XI. [[The sample selection was based on the inspection procedure objectives, sample availability, and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage. The inspector verified by documentation review that test procedures and examiner qualifications were current and in accordance with the]]
- ASME [[Code requirements. Also, the inspector reviewed examiner qualifications for use of the performance demonstration initiative (PDI) manual ultrasonic test (UT) procedures to examine welds. The inspector selected a sample of Condition Reports (CR), operability/functionality evaluations and corrective actions for review of Entergy's effectiveness in the identification and resolution of relevant indications discovered during the observed]]
- ISI activities. The inspector's observation and documentation review of non-destructive testing included the following: * Ultrasonic testing, manual
- MT ) of support lugs, integral attachment to carbon steel piping. High Pressure Coolant Injection (HPCI) system, welds
HL1(4); * In Vessel Visual Inspection (IVVI) of steam dryer leveling screw tack welds, divider plate anchor, shroud head bolt #18 and various jet pump diffusers, swing gates, main wedges, auxiliary wedges, wedge restrainer bracket set screws and rods; and * Liquid Penetrant test (PT) of stainless steel field weld of pipe to valve, B-11-159, Standby Liquid Control (SBLC), at drawing location ISI-1-11-1. The inspector reviewed selected steam dryer and jet pump structural members and component base materials to evaluate examiner skill, test equipment performance, examination technique, and inspection environment (water clarity). The inspector
selected jet pump nonconforming conditions identified in Indication Notification Reports (INR) P1R17-IVVI-09-01, P1R17-IVVI-09-02 and P1R17-IVVI-09-03 for the review of
- CR -PNP-2009-01531, which was initiated to report and characterize mechanical wear on jet pump components and shroud head bolt #18. Also, the indications reported during this examination were evaluated by comparison with previous examination results noted in 2005 and 2007. The comparison revealed no noticeable change in characterization of the indications. The inspector selected two
- XI [[repair/replacement plans for review where welding on a pressure boundary was performed. The review was performed to evaluate specification of appropriate base and weld materials and control of the welding process as detailed in the work order. Also, the inspector reviewed the weld procedures and welder qualifications for compliance with the requirements of]]
- XI. Also, the inspector reviewed documentation that the weld examinations were performed in accordance with the
- JF 29-19-1 for application of rubber lining and installation in Loop "B" of system #29. Component parts consisting of carbon steel,
- ASTM A234, six inch schedule 40 150#, elbow, weld neck pipe flange and seamless pipe, weld map #1, Rev 0, welds 1 and 2; and *
- JF and additional structural members attached to the liner to assess the condition of the protective coating. The inspector performed this visual evaluation to determine the extent of any peeling, blistering, coating loss or other damage as a result of corrosion, foreign material impact or lack of maintenance. The inspector reviewed a sample of Condition Reports initiated during]]
- ISI examinations this outage to evaluate Entergy effectiveness in the identification and resolution of problems within the corrective action process. The inspector selected for review
PNP-2009-01182 (error in specification M301, extent of condition). The inspector reviewed the problem identification, flaw characterization, engineering assessment (operability/functionality evaluation) and the disposition entered into the corrective action program. b. Findings No findings of significance were identified.
1R11 Licensed Operator Requalification Program (71111.11)
Licensed Operator Training
a. Inspection Scope (1 sample) The inspectors reviewed licensed operator response to a simulated General Emergency
during an emergency planning drill on May 28, 2009. The inspectors reviewed operator response to the event in the simulator, emergency plan implementation by the Senior
Reactor Operator, and the completion of a post drill critique. In addition, the inspectors observed licensed operator training on April 14, 2009. Specifically, the inspectors
observed classroom Just In-Time training for senior reactor operators, reactor operators,
and non-licensed operators to prepare them for Pilgrim's Refueling Outage. The lectures
discussed upcoming outage work activities including reactor cavity water level, the
replacement of control rod drive mechanisms, the integrated leak rate testing, and
temporary power configurations. The inspectors assessed the training to determine if the
training adequately prepared the operators for the refueling outage. The inspectors
reviewed the lesson plans and training objectives to determine if they had been achieved.
The documents reviewed during this inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12Q) a. Inspection Scope (2 samples) The inspectors reviewed degraded conditions associated with the systems listed below for
items such as: (1) appropriate work practices; (2) identifying and addressing common
cause failures; (3) scoping in accordance with 10 CFR 50.65(b) of the Maintenance Rule;
(4) characterizing reliability issues for performance; (5) trending key parameters for condition monitoring; (6) charging unavailability for performance; (7) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and (8) appropriateness of
performance criteria for structures, systems, and components (SSC)s/functions classified
as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for
SSCs/functions classified as (a)(1). The documents reviewed during this inspection are
listed in the Attachment. Items reviewed included the following: * Functional Failure Determination of Startup Transformer; and * Switchyard Breakers 102, 103, 104, and 105. b. Findings No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. Inspection Scope (7 samples) The inspectors evaluated seven maintenance risk assessments for planned and emergent
maintenance activities. The inspectors reviewed maintenance risk evaluations, work
schedules, and control room logs to determine if concurrent maintenance or surveillance activities adversely affected the plant risk already incurred with out-of-service components.
The inspectors verified the appropriate use of Entergy's qualitative risk assessment
checklist for shutdown safety functions and entry into appropriate risk categories. The
inspectors evaluated whether Entergy took the necessary steps to control work activities,
minimized the probability of initiating events, and maintained the functional capability of mitigating systems. The inspectors assessed Entergy's risk management actions during
plant walkdowns. The documents reviewed during this inspection are listed in the
Attachment. The inspectors reviewed the conduct and adequacy of maintenance risk
assessments for the following maintenance and testing activities: * Orange Risk Condition due to the unavailability of the Shutdown Transformer and Station Blackout Emergency Diesel Generator; * Orange Risk Condition during Maintenance and Valve Logic Testing of Residual Heat Removal Valves which affected shutdown cooling; * Orange Risk Condition due to Closure of Shutdown Cooling Suction Valves to Support Residual Heat Removal Valve Hydrostatic and Local Leak Rate Testing; * Emergent Departure from Defense-In-Depth Orange Risk Condition to Support Repair of MO-1001-29A Strain Gage; * Yellow Risk for Shutdown Transformer Breaker 504 to A5 4160V Bus Timing; * Orange Risk during Loss of Offsite Power/Emergency Core Cooling Systems Loading Testing; and * Orange Risk during Primary Containment Isolation Valve Testing which removed Shutdown Cooling from Service.
b. Findings No findings of significance were identified.
1R15 Operability Evaluations (71111.15)
a. Inspection Scope (5 samples) The inspectors reviewed five operability determinations associated with degraded or non-conforming conditions to determine if the operability determination was justified and if the mitigating systems or barriers remained available such that no unrecognized increase
in risk had occurred. The inspectors also reviewed compensatory measures to determine
if the compensatory measures were in place and were appropriately controlled. The
inspectors reviewed licensee performance against related Technical Specifications and
- UFS [[]]
AR requirements. The documents reviewed during this inspection are listed in the
Attachment. The inspectors reviewed the following degraded or non-conforming
conditions:
- PNP -2009-02016, Shutdown Transformer Relay did not close within its Technical Specifications Timeband; *
PNP-2009-02707, Security Emergency Diesel Generator does not meet Surveillance Acceptance Criteria.
b. Findings No findings of significance were identified.
1R18 Plant Modifications (71111.18)
.1 Permanent Modification for Booster Fan in Vital Motor Generator (MG) Set Room a. Inspection Scope (1 sample) The inspectors reviewed Permanent Modification Field Revision Notice (FRN) 87-73-29,
"Installation of a Permanent Booster Fan in the Vital MG Set Room," to determine whether
the licensing bases and performance capability inside the Vital MG Set Room had been degraded through the modification. A walkdown was performed to determine whether the
components inside the room would perform their function under certain conditions. The
inspectors reviewed applicable condition reports and drawings to determine whether they
properly reflected the permanent modification. The inspectors also reviewed design basis
calculations to determine if they were conservative in their heat loading assumptions. The
documents reviewed during this inspection are listed in the Attachment.
b. Findings Introduction: The inspectors identified an Unresolved Item (URI) regarding design basis calculations for the Vital MG Set Room. The inspectors questioned Entergy about the
most limiting initiating event for room heat-up and the subsequent impact on safety related
components. Entergy provided the inspectors a calculation which addressed the room
heatup following a Station Blackout event; however, they could not identify a design basis
calculation which assessed room heatup following a Loss of Coolant Accident (LOCA)
without a Loss of Offsite Power (LOOP). The performance deficiency is that Entergy did
not have a calculation to verify an adequate design for the Vital
LOOP event. As such, the inspectors could not verify which event was
more limiting, whether safety related components in the room would be affected, and
whether the performance deficiency was more than minor.
Description: The inspectors reviewed Calculation N124, "Vital
MG set room
temperature limit. Calculation N124 assumes a heat-up time for the Vital MG Set Room of
eight hours, the mission time for a Station Blackout (SBO) event. Under worst case initial
conditions, i.e. hottest summer day and maximum heat loading, the calculation predicts the
room will heat up to 116 degrees F in an eight-hour time frame. However, the inspectors noted that other accident scenarios have a longer mission time, specifically the
- LO [[]]
- LO [[]]
LOOP could be more limiting than the SBO event and entered this issue into
their corrective action program as
PNP-2009-0991. As part of their corrective actions,
Entergy is modeling calculations of the Vital MG Set Room to determine the peak
temperature in the room for a
LOOP event. The issue of concern is that if
the peak temperature in the room is determined to be higher than what was previously
evaluated, the safety-related circuit breakers in the room would need to be evaluated to
ensure they could perform their function at the higher peak temperature. The inspectors
require Entergy's final calculation to be completed to determine if the performance deficiency is more than minor.
MG Set Room Peak Temperatures
.2 Permanent Modification for High Pressure Coolant Injection (HPCI) Turbine Controls Testing Device (TCTD) a. Inspection Scope (1 sample) The inspectors reviewed Permanent Modification
- HPCI [[]]
TCTD," and the associated 10 CFR 50.59 screening, to determine whether the
licensing bases and performance capability of the
- HP [[]]
CI system had been degraded through the modification. A walkdown was performed to determine whether the
components inside the room were as described in the permanent modification
documentation. The inspectors reviewed applicable condition reports and drawings to
determine whether they properly reflected the permanent modification. The documents
reviewed during this inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
.3 Temporary Modification for Reactor Shutdown/Flood-up Level Indication a. Inspection Scope (1 sample) The inspectors reviewed Temporary Modification Procedure 3.M.2-40, Revision 6, "Refuel
Outage Temporary Modification Reactor Shutdown/Flood-up Level Indication," to
determine whether the performance capability of the Reactor Vessel Level Indication had been degraded through the modification. The inspectors reviewed Control Room
drawings, relevant condition reports, and procedures to ensure the temporary modification
did not adversely affect the Reactor Vessel Level Indication. The inspectors reviewed the
updated Control Room drawings to determine whether they properly reflected the
temporary modification. The inspectors also performed a walkdown of temporary
equipment installed in the plant to ensure the temporary equipment was installed in
accordance with the procedural requirements. The documents reviewed during this
inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
.4 Temporary Modification for 125V DC Power to Bus "B" a. Inspection Scope (1 sample) The inspectors reviewed Temporary Modification Procedure 3.M.3-36.7, Revision 0,
"Temporary Power for 125V
DC safety related bus had been degraded through the modification. The
inspectors reviewed electrical schematics and procedures to ensure the temporary
modification did not adversely affect the reliability of 125V DC power. The inspectors reviewed Control Room drawings to determine whether they properly reflected the
temporary modification. The inspectors also performed a walkdown in the lower
switchgear room where temporary equipment was installed to ensure it was installed in
accordance with procedural requirements. The documents reviewed during this inspection
are listed in the Attachment.
b. Findings No findings of significance were identified.
.5 Temporary Modification for Residual Heat Removal (RHR) Valve Interlocks a. Inspection Scope (1 sample) The inspectors reviewed Temporary Modification Procedure 2.2.19.1, Attachment 19,
Revision 28, "Bypassing
MO-1001-50 Valve Interlocks," to determine
whether the performance capability of the RHR System had been degraded through the modification. The inspectors reviewed Control Room drawings, relevant condition reports,
and procedures to ensure the temporary modification did not adversely affect the RHR
System. The inspectors reviewed the updated Control Room drawings to determine
whether they properly reflected the temporary modification. The inspectors also
performed a walkdown of temporary equipment installed in the plant to ensure the
temporary equipment was installed in accordance with the procedural requirements. The
documents reviewed during this inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
1R19 Post-Maintenance Testing (71111.19) a. Inspection Scope (8 samples) The inspectors reviewed eight samples of post-maintenance tests (PMT) during this
inspection period. The inspectors reviewed these activities to determine whether the PMT
adequately demonstrated that the safety-related function of the equipment was satisfied,
given the scope of the work performed, and that operability of the system was restored. In addition, the inspectors evaluated the applicable test acceptance criteria to verify
consistency with the associated design and licensing bases, as well as TS requirements.
The inspectors also evaluated whether conditions adverse to quality were entered into the
corrective action program for resolution. Documents reviewed during this inspection are
listed in the Attachment. The following maintenance activities and their post-maintenance
tests were evaluated: * Replacement of the Station Blackout Diesel Governor; * Preventive Maintenance conducted on
HCU 22-47; * Replacement of the "A" Recirculation Pump; and * Replace Reactor Head Vent Valves.
b. Findings No findings of significance were identified.
1R20 Refueling and Other Outage Activities (71111.20)
a. Inspection Scope (1 sample)
Periodic review of RFO 17 Work Plan and Outage Risk
The inspectors, on a routine basis, reviewed the refueling outage work plan and daily
shutdown risk assessments to verify Entergy addressed the outage impact on defense-in-
depth for critical safety functions. Periodic risk updates, accounting for schedule changes
and unplanned activities were also reviewed. The inspectors' review focused on verifying
Entergy had provided adequate defense-in-depth for each safety function, and/or
implemented planned contingencies to minimize the overall risk where redundancy was
limited or not available. Detailed risk reviews for specific high risk periods and activities
are documented in section 1R13 of this report.
Monitoring of Shutdown Activities
The inspectors observed operators performing portions of the reactor shutdown, and plant
cooldown to assess operator performance with respect to communications, command and
control, procedure adherence, and compliance with Technical Specification cooldown
limits. Upon shutdown, the inspectors also performed an inspection walkdown of the
drywell to verify the integrity of structures, piping and supports, and to confirm systems
appeared functional.
Clearance Activities
The inspectors reviewed a sample of risk significant clearance activities and verified tags
were properly hung and/or removed, equipment was appropriately configured per the
clearance requirement, and that the clearance did not impact equipment credited to meet
the shutdown critical safety functions.
Reactor Coolant System (RCS) Instrumentation
The inspectors periodically observed and verified by diverse means that associated
instruments for the reactor/refueling cavity/spent fuel pool (SFP) water level, the reactor
coolant and
RHR system were functioning properly
and accurately.
Electrical Power
The inspectors verified that the status of electrical systems met Entergy's outage risk
control plan. The inspectors verified that compensatory measures were implemented
when electrical power supplies were impacted by outage work activities. The inspectors
verified that credited backup power supplies were available.
Residual Heat Removal (RHR) and Spent Fuel Pool (SFP) System Monitoring
The inspectors observed the
SFP system status and operating parameters to
verify that the cooling systems operated properly. Verification included periodic review of
the
RHR system flow. Partial system
walkdowns, to verify proper system configuration, were periodically performed for both
RHR and Reactor Building Closed Cooling Water alignment.
Inventory Control
The inspectors reviewed Entergy's actions to establish, monitor, and maintain the proper
water inventory in the reactor vessel and spent fuel pool. The inspectors reviewed the
plant system flow paths and configurations established for reactor makeup and verified the
configurations were consistent with the outage plan. In addition, the inspectors observed
Entergy's installation of a freeze seal on a 1" line of their Hydraulic Control Unit 50-39 to
support emergent maintenance on May 3, 2009. The inspectors reviewed Entergy's
contingencies for ensuring reactor vessel level control if the freeze seal were to fail.
Foreign Material Exclusion (FME)
The inspectors reviewed implementation of licensee procedures for FME control for the
open reactor vessel, reactor cavity, and SFP. The inspectors reviewed a sample of
Entergy's actions to identify, document, and resolve FME events/issues.
The inspectors reviewed licensee actions to control the lift of heavy loads during the
outage. The review included activities related to the heavy loads associated with the
replacement of the "A" reactor recirculation pump and motor. The inspectors reviewed
licensee actions to manage the increased risk during these activities and to implement
compensatory measures to protect the integrity of systems important to safe shutdown.
This review included consideration of industry operating experience and licensee
commitments to NRC regulatory guidance.
Containment Control
The inspectors reviewed licensee activities during the outage to control primary and
secondary containment and to clean and prepare the containment for closure prior to plant
restart. The inspectors performed periodic tours of the drywell to review the control of work
activities and containment conditions. The inspectors performed a walkdown of the drywell
prior to reactor startup to review licensee cleanup and demobilization controls in areas where work was completed to assure that tools, materials and debris were removed. The
inspectors also reviewed data and acceptance criteria for the primary containment
Integrated Leak Rate Test (ILRT).
Fuel Shuffle Activities and Reactivity Control
The inspectors verified that refueling activities were performed in accordance with core
alterations Technical Specifications, including the requirements for core monitoring using
the source range monitors and the functional checks of the refueling interlocks. The
inspectors observed communications and the coordination of activities between the control
room, the General Electric physicist, and the refueling floor while fuel handling activities
were in progress. The inspectors reviewed Entergy's response to refueling floor
operational problems, including problems identified during movement of control rod blade
guides which resulted in damage to a blade guide.
Monitoring Heatup and Startup Activities
The inspectors observed and/or reviewed heatup and startup activities during the period of
May 18, 2009 through May 22, 2009. The inspection consisted of control room
observations, plant walkdowns, and a review of control board indicators, operator logs,
plant computer information, and station procedures. The inspectors observed operator
actions including the preparations for the approach to criticality, reactor critical operations,
low power operations, and the synchronization of the main turbine generator to the
electrical grid. The inspectors observed plant restart and power ascension to verify that
Technical Specifications, license conditions, and other requirements for mode changes
were met.
Problem Identification and Resolution
The inspectors verified that Entergy was identifying outage related issues and had entered
them into the corrective action program. The inspectors reviewed a sample of the
corrective actions to verify they were appropriate to resolve the issues. The references
used in this review are listed in the Attachment.
b. Findings Introduction: A Green self-revealing non-cited violation (NCV) of Technical Specification 5.4.1 "Procedures" was identified, because Entergy's refueling bridge operators did not
continuously monitor a Double Blade Guide (DBG) that was being moved into the core to
ensure the DBG did not encounter any obstructions, interferences, or other abnormal
indications as discussed in Pilgrim Procedure 4.3, Revision 113, "Fuel Handling."
Specifically, the failure to follow the procedure resulted in damaging the refueling mast
when the mast was moved and still latched to a
- DBG. Description: On May 4, 2009, during Pilgrim's refueling outage, refueling personnel bent and damaged their refueling mast following the insertion of a
is a tool used for control rod vertical support when adjacent fuel is removed from the core.
Refueling personnel had placed the DBG into its core location and the refueling Senior
Reactor Operator (SRO) authorized grapple release and the raising of the refuel mast.
Refueling personnel thought the mast had delatched from the DBG. However, the refuel
bridge operator did not perform a mast rotation verification check to ensure the DBG was
delatched. In addition, neither the
DBG was
delatched. The refuel bridge operator proceeded to raise the mast above the core and
traverse to the next location which bent the mast and the handle to the DBG. Entergy
conducted inspections of the adjacent fuel assembly and control rod to ensure that no fuel
or control rod had been damaged. The performance deficiency is that Entergy did not
properly implement their Procedure 4.3 "Fuel Handling," which requires them to
continuously monitor
DBG does not encounter any
obstructions, interferences, or abnormal indications. By not following their procedure,
Entergy's refueling personnel damaged the refueling mast.
Analysis: The performance deficiency was the failure of Entergy's refueling bridge operators to continuously monitor a DBG during movement within the core to ensure the
DBG did not encounter any obstructions, interferences or other abnormal indications as
required by the fuel handling procedure. The inspectors determined that the finding was
more than minor because the finding was associated with the human performance attribute
of the Barrier Integrity Cornerstone and adversely affected the cornerstone's objective to
provide reasonable assurance that physical design barriers (i.e. fuel cladding) protect the
public from radionuclide releases caused by accidents or events. Although no fuel
damage occurred during this event, the failure to follow the fuel handling procedure
affected the cornerstone's objective to provide reasonable assurance that physical design
barriers protect the public from radionuclide releases caused by accidents or events.
The failure to properly implement the fuel handling procedure affected the Barrier Integrity
Cornerstone. IMC 0609, "Significance Determination Process," Attachment 0609.04,
"Phase 1-Initial Screening and Characterization of Findings," was used to evaluate the
significance of the finding. Attachment 0609.04, Table 4a, was used to evaluate the
impact of the finding on fuel clad integrity. Following this event, Entergy inspected fuel
assemblies and the control rod in proximity to the DBG and concluded that no damage had
occurred to the fuel or control rod. Since the finding did not affect spent fuel pool cooling
or inventory and since no fuel or control rod was damaged when the mast was bent, the
finding was determined to be of very low safety significance (Green).
The finding has a cross cutting aspect in Human Error Prevention Techniques in the Work
Practices component of the Human Performance area. Specifically, Entergy did not
employ effective self and peer checking techniques such that refueling activities were
performed safely. (H.4.a of
- IMC 305). Enforcement: Technical Specification 5.4.1, "Procedures", requires that written procedures be implemented as recommended in
NRC Regulatory Guide (RG) 1.33, "Quality
Assurance Program Requirements," Revision 2, Appendix A, February 1978. RG 1.33,
Appendix A, Section 2 includes procedures for Refueling Equipment Operation. Contrary
to this, on May 4, 2009, Entergy did not properly implement Procedure 4.3, "Fuel
Handling," which required them to continuously monitor DBG movement to ensure the
DBG does not encounter any obstructions, interferences, or other abnormal indications.
Corrective actions included replacing a section of the refueling mast, replacing the grapple
camera, conducting additional training with the refueling crews including a table top dry
run; performing a Human Performance Error Review and requiring Operations Senior
Management to provide oversight during one hour of each three hour shift when the
refueling crew was on the bridge moving fuel. Because this violation was of very low safety
significance and Entergy has entered it into their corrective action program (CR-PNP-2009-
02083), this violation is being treated as an
NCV 05000293/2009003-01, Failure to Follow Procedure Resulting in Damage to Refueling Mast 1R22 Surveillance Testing (71111.22)
a. Inspection Scope (6 samples) The inspectors reviewed six samples of surveillance activities to determine whether the
testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety-related functions. The inspectors reviewed selected
prerequisites and precautions to determine if they were met and if the tests were
performed in accordance with the procedural steps. Additionally, the inspectors evaluated
the applicable test acceptance criteria for consistency with associated design bases,
licensing bases, and Technical Specification requirements. The inspectors also evaluated
whether conditions adverse to quality were entered into the corrective action program for
resolution. The documents reviewed during this inspection are listed in the Attachment.
The following surveillance tests were evaluated:
- Local Leak Rate Testing of the "C" Main Steam Isolation Valve, Containment Isolation Valve (CIV); * Loss of Offsite Power/Emergency Core Cooling Systems Loading Testing; * Control Rod Scram Timing; * Reactor Vessel Pressurization and Leakage Test; * Primary Containment Integrated Leak Rate Test; and *
IST). b. Findings No findings of significance were identified. Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06)
a. Inspection Scope (1 drill observation sample) The inspectors observed an emergency planning drill on May 28, 2009. The inspectors evaluated the emergency response organization performance in the simulator, and in the
Emergency Operations Facility, for a scenario which escalated to a General Emergency and involved a simulated offsite release. The inspectors assessed the implementation of
Emergency Action Level (EAL) classification and notification decisions as well as
Protective Action Recommendation development and notifications. The inspectors also
assessed whether Pilgrim's critique of the exercise assessed all of the drill's observations and findings. The documents reviewed during this inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
2.
- RADIAT [[]]
- ION [[]]
- SAFE [[]]
TY Cornerstone: Occupational Radiation Safety
2OS1 Access Control To Radiologically-Significant Areas (71121.01)
.1 Access Control to Radiologically-Significant Areas (Pre-Outage)
.a Inspection Scope (12 samples) During the period March 30, 2009 through April 2, 2009, the inspectors performed the
following activities to verify that Entergy was properly implementing operational,
administrative, and engineering controls for access to locked high-radiation areas, and
other radiologically significant areas. Implementation of these controls was reviewed
against the criteria contained in 10 CFR 20, Standards for Protection Against Radiation,
relevant Technical Specifications, and Entergy=s procedures. This inspection activity represented the completion of twelve (12) samples relative to this inspection area. * The inspectors identified the refuel floor activities and the incore tip room survey activities as significant work areas and reviewed the associated controls and surveys of
these areas to determine if controls were acceptable. * The inspectors walked down the perimeter of these areas to determine whether prescribed radiation work permits (RWP)s, procedure, and engineering controls were in
place, whether licensee surveys and postings were acceptable, and whether air
samplers were properly located. * The inspectors reviewed RWPs for the upcoming refueling outage used to access high radiation areas and identify what work control instructions or control barriers had been
specified. These RWPs included scaffold work, refueling activities, reactor
recirculation pump 'A' replacement, inservice inspection activities, and minor
maintenance. The inspectors reviewed electronic personal dosimeter (EPD) alarm set
points (both integrated dose and dose rate) for conformity with survey indications and
plant policy. The inspectors verified that workers knew what actions they were to take
if their EPD malfunctioned or alarmed. * During job performance observations for refueling preparation activities, the inspectors verified the adequacy of radiological controls, such as; required surveys, including
airborne surveys, radiation protection job coverage, and contamination controls. * The inspectors reviewed seventeen (17) condition reports related to access controls. The inspectors also reviewed the 2007 radiation protection annual audit and the
station's five year As Low As Reasonably Achievable (ALARA) plan. * The inspectors questioned workers to verify that radiation workers were aware of the significant radiological conditions in their workplace, their
set-points, and that their performance took into consideration the level of radiological
hazards present. The inspectors also observed radiation worker performance with
respect to stated radiation protection work requirements.
- Of the 17 condition reports reviewed by the inspectors, 11 were due to radiation worker error. The inspectors reviewed the reports for observable patterns and discussed
corrective actions planned and taken with the Radiation Protection Manager (RPM). * The inspectors observed radiation protection technician performance with respect to radiation protection work requirements. * Of the 17 condition reports reviewed by the inspectors, 3 were due to radiation protection technician error. The inspectors discussed with the RPM the status of
changes in licensee procedural controls of high dose rate - high radiation areas and
very high radiation areas (VHRA). * The inspectors discussed with a radiation protection supervisor the controls in place for special areas that have the potential to become
- VH [[]]
RA during certain plant operations.
Either because the conditions did not exist or an event had not occurred, no
opportunities were available to review the following items: * Review of
- RWP [[s for airborne radioactivity areas with the potential for individual worker internal exposures of >50 millirem Committed Effective Dose Equivalent (]]
- DAC -hrs); and * Adequacy of Entergy's internal dose assessment for any actual internal exposure greater than 50 millirem
CEDE. b. Findings No findings of significance were identified.
.2 Access Control To Radiologically-Significant Areas (Outage)
a. Inspection Scope (12 samples)
During the period April 29, 2009 through May 5, 2009, the inspectors performed the following activities to verify that Entergy was properly implementing operational,
administrative, and engineering controls for access to locked high radiation areas, and
other radiologically significant areas. Implementation of these controls was reviewed
against the criteria contained in 10 CFR 20, relevant Technical Specifications, and
Entergy=s procedures. This inspection activity represents the completion of twelve (12) samples relative to this inspection area. * The inspectors reviewed all licensee Performance Indicators (PIs) for the Occupational Exposure Cornerstone for follow-up. * The inspectors walked down the perimeter of the drywell, work areas inside the drywell such as the 'A' recirculation pump replacement, and under the vessel work. The
inspectors also walked down the refueling floor and the condenser bay. The inspectors
verified whether prescribed RWP, procedure, and engineering controls were in place,
whether licensee surveys and postings were acceptable, and whether air samplers
were properly located.
- The inspectors reviewed seventeen (17) condition reports from the start of the refueling outage through May 1, 2009. Follow-up actions for these condition reports were
performed in an efficient and timely manner commensurate with their importance to
safety and risk. * During job performance observations for N9A weld overlay activities and refueling activities, the inspectors verified the adequacy of radiological control preparation
activities. The inspectors verified the adequacy of radiological controls, such as:
required surveys, radiation protection job coverage and contamination control. * The inspectors observed radiation worker performance to determine if they were aware of significant radiological conditions in their workplace, the RWP controls/limits, and
that their performance took into consideration the level of the radiological hazards
present. * The inspectors reviewed two (2) condition reports since the beginning of the refueling outage that found the cause to be due to radiation worker error. The inspectors
verified there were no observable patterns traceable to a similar cause. * The inspectors observed radiation protection technician performance with respect to all radiation protection work requirements. The inspectors verified that worker
performance was consistent with their training and qualifications with respect to the
radiological hazards and work activities. * The inspectors reviewed one (1) condition report that found the cause of the event was radiation protection technician error. The inspectors verified this was an isolated case
and no pattern traceable to a similar cause. Either because the conditions did not exist or an event had not occurred, no opportunities
were available to review the following items: * Review
- RWP [[s for airborne radioactivity areas with the potential for individual worker internal exposures of >50 millirem]]
- DAC -hrs); * Adequacy of Entergy's internal dose assessment for any actual internal exposure greater than 50 millirem
- CEDE packages; * Review of licensee documentation for PI events; and * Review the application of dosimetry to effectively monitor exposure when significant dose rate gradients exist. b. Findings No findings of significance were identified.
ALARA) Planning and Controls (71121.02)
.1 As Low As Reasonably Achievable (ALARA) Planning and Controls (Pre-Outage)
a. Inspection Scope (7 samples) During the period March 30, 2009 through April 2, 2009, the inspectors performed the
following activities to verify that Entergy properly implemented operational, engineering,
and administrative controls to maintain personnel exposure
- ALA [[]]
RA during routine plant
operation. Implementation of these controls was reviewed against the criteria contained in
CFR 20, applicable industry standards, and Entergy=s procedures. This inspection activity represents the completion of seven (7) samples relative to this inspection area.
Current Cumulative Exposure and Trend
The inspectors reviewed pertinent information regarding plant collective exposure history,
current exposure trends, and ongoing or planned activities to assess current performance
and exposure challenges.
The inspectors reviewed the upcoming outage work schedule and the associated work
activity exposure estimates. The five work activities that are likely to result in the highest
personnel collective exposures are scaffolding, refueling activities on the refuel floor, in
service inspection, replacement of the 'A' recirculation pump, and routine maintenance.
Radiological Work Planning
The inspectors obtained from Entergy, a list of the outage work activities with estimated
exposures. The inspectors reviewed the
- ALA [[]]
RA reviews for the five highest dose work
activities to determine if appropriate procedures, engineering, and work controls had been
designated.
Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the assumptions and basis for the current annual collective
exposure estimate and the methodology used. The inspectors reviewed the methods used
to make adjustments to the exposure estimate when unexpected changes occur.
Source Term Reduction and Control
The inspectors reviewed Pilgrim documentation to determine the historical trends and
current status of tracked plant source terms.
Problem Identification and Resolution The inspectors reviewed condition reports related to the
- ALA [[]]
RA program since the last
inspection to determine if repetitive deficiencies or significant individual deficiencies are
identified.
Either because the conditions did not exist or an event had not occurred, no opportunities
were available to review the following item:
- Pilgrim had no declared pregnant workers during this assessment period. b. Findings No findings of significance were identified.
.2 As Low As Reasonably Achievable (ALARA) Planning and Controls (Outage)
a. Inspection Scope (7 samples) During the period April 29, 2009 through May 5, 2009, the inspectors performed the
following activities to verify that Entergy was properly implementing operational,
engineering, and administrative controls to maintain personnel exposure
- ALA [[]]
RA during
refueling outage operation. Implementation of these controls was reviewed against the
criteria contained in 10 CFR 20, applicable industry standards, and Pilgrim's procedures.
This inspection activity represents the completion of seven (7) samples relative to this
inspection area.
Inspection Planning
The inspectors reviewed the work schedule for the refueling outage during the inspection
period. The inspectors also reviewed the site specific procedures associated with
maintaining occupational exposures
- ALA [[]]
RA.
Radiological Work Planning
The inspectors reviewed the exposure estimates for six (6) work activities that were likely
to result in the highest personnel collective exposures. The inspectors compared the
results achieved with the intended dose established in Pilgrim's
- ALA [[]]
RA planning for these
work activities. The inspectors reviewed Pilgrim's response to increased dose rates and
higher than estimated work hours.
Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the method for adjusting exposure estimates and attended a
manager's
- ALA [[]]
RA committee meeting for the purpose of making adjustments. The
inspectors verified that estimated exposure is based on sound radiation protection and
- ALA [[]]
RA principles.
Source Term Reduction and Control
The inspectors reviewed the source term from shut down to May 1, 2009. The plant
implemented effective contingency plans when the refuel pool activity was higher than
expected.
Either because the conditions did not exist or an event had not occurred, no opportunities
were available to review the following item:
- Pilgrim had no declared pregnant workers during this assessment period. b. Findings No findings of significance were identified. 4.
- OTHER [[]]
- ACTIVI [[TIES [OA]]]
PI) Verification (71151)
a. Inspection Scope Cornerstone: Initiating Events (3 samples) The Initiating Events cornerstone PI data for unplanned scrams per 7,000 critical hours;
unplanned scrams with loss of normal heat removal; and unplanned power changes per
7,000 critical hours was reviewed to assess the completeness and accuracy of the
reported information. Specifically, PI data from the second quarter of 2008 through the first
quarter of 2009 was reviewed and compared to information contained in NRC inspection
reports, Licensee Event Reports (LERs), and operator logs.
Cornerstone: Barrier Integrity and Mitigating Systems (2 samples) The inspectors reviewed PI data to determine the accuracy and completeness of the
reported data. The review was accomplished by comparing reported PI data to
confirmatory plant records and data available in plant logs, the chemistry data base,
Licensee Event Reports (LER),
NRC inspection reports. The acceptance criteria
used for the review was Nuclear Energy Institute (NEI) 99-02, Revision 5, "Regulatory
Assessment Performance Indicator Guidelines," and Pilgrim TS 3.6, "Primary System
Boundary." The documents reviewed during this inspection are listed in the Attachment.
The following performance indicators were reviewed:
- Mitigating System Cornerstone, Safety System Functional Failures from the first quarter of 2008 through the first quarter of 2009; and * Barrier Integrity Cornerstone, RCS Activity from the second quarter of 2008 through the first quarter of 2009
Cornerstone: Occupational Exposure Control Effectiveness (1 sample) The inspectors reviewed implementation of Entergy=s Occupational Exposure Control Effectiveness Performance Indicator (PI) Program. Specifically, the inspector reviewed recent condition reports, and associated documents, for occurrences involving locked high
radiation areas, very high radiation areas, and unplanned exposures against the criteria
specified in NEI 99-02, "Regulatory Assessment Performance Indicator Guidelines,"
Revision 5, to verify that all occurrences that met the NEI criteria were identified and
reported as performance indicators. This inspection activity represents the completion of
one (1) sample relative to this inspection area; completing the annual inspection
requirement.
b. Findings No findings of significance were identified.
4OA2 Identification and Resolution of Problems (71152)
.1 Review of Items Entered into the Corrective Action Program (CAP)
a. Inspection Scope The inspectors performed a screening of each item entered into Entergy's CAP. This
review was accomplished by reviewing printouts of each CR, attending daily screening
meetings and/or accessing Entergy's database. The purpose of this review was to identify
conditions such as repetitive equipment failures or human performance issues that might
warrant additional follow-up.
b. Findings No findings of significance were identified. .2 Semi-Annual Review to Identify Trends a. Inspection Scope The inspectors performed a review of Entergy's CAP and associated documents to identify
trends that could indicate the existence of a more significant safety issue. The review was
focused on repetitive equipment and corrective maintenance issues, but also considered
the results of daily inspector CAP item screening. The review included issues documented
in
CAP performance indicator data. The review focused on
the six-month period of December 2008 through June 2009. The documents reviewed
during this inspection are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified. Two low level trends were identified in the
areas of post maintenance/modification testing and temporary modification controls.
Post Maintenance/Modification Testing
The inspectors reviewed eight maintenance work order packages and one permanent
modification package during this quarter in order to verify that the testing adequately
demonstrates the safety function that may have been affected by the maintenance or
modification activity. In the majority of the packages reviewed, the inspectors identified
discrepancies with the specification, completion, and documentation of post maintenance
or modification test activities. Examples the inspectors identified included: * The Engineering Change (EC)
WO) PMT section, including; verification of proper reassembly
for all structural elements, bolting and anchorages, proper alignment of the fan housing,
proper fit-up of flange joints with no visible gaps, and no loose or missing fasteners.
Substitute work and testing activities were identified which reasonably demonstrated the
expected
CR-PNP-2009-02618 was written to document the
missing
- EC [[]]
PMT requirements included; inspection for visible
leakage and/or the completion of non-destructive testing of all welded joints, soap bubble
tests of all air joints breached by the modification, continuity and meggar checks of all
cables, In-Service Test (IST) valve position verification, full exercise, stroke test and fail
safe tests, visual examination of all welds during the reactor vessel pressure test, and
establishing a new IST baseline. Substitute work and testing was identified which
reasonably demonstrated the expected
and -02676 were written to document the missing
- EC [[]]
- HPCI [[]]
HPCI pump (1 attribute of a total of 8 PMT attributes specified in
the EC post modification test plan) was located and satisfactorily completed. With the
exception of a new
- TC [[]]
TCTD equipment which does not directly
interface with the
system is not required to be operable. Operations assessed the condition of the lack of
thermography to be acceptable in consideration that no deficiencies were identified at the
circuit breaker panel or the
- TC [[]]
TD during testing and that the circuit breaker is normally
open. In addition, discussion with Electrical Maintenance personnel identified that the
thermography had been performed successfully but that the documentation for the test
could not be located.
WO PMT requirements including; missing documentation for the verification of the
completion of PMT, lack of documentation of the basis for the satisfactory completion when
acceptance criteria had not been met and/or no CR documenting this basis, and the lack of
documentation of the completion of a soap bubble test. Each of these issues was
subsequently documented in a CR, the condition evaluated or corrected, and determined
not to affect the functionality or operability of safety-related equipment. Entergy corporate procedure
MA-101, Revision 6, "Conduct of Maintenance," identifies, in
part, that PMT consists of testing that is performed following any maintenance activity to
ensure that the original deficiency was corrected, no new deficiency was created as a result of
the maintenance activities, and equipment will perform its intended function when returned to service.
MA-101 also identifies that the PMT documentation fully describes the test
performed and results such that an independent third party will be able to review and understand what was done, what the results were and conclusions drawn. The inspectors
have concluded that the number and extent of PMT issues identified during this quarter
constitutes a low level trend with the specification, performance, and documentation of
PNP-2009-2778 was
written to document the examples, to conduct an apparent cause evaluation, and to specify
corrective actions. The inspectors will follow Entergy's investigation and corrective actions to evaluate their response to this low level trend.
Temporary Modification Controls The inspectors reviewed temporary modification packages during Pilgrim's refueling
outage in order to verify that modifications had not affected the safety functions of
important safety systems. During the review the inspectors identified discrepancies with
temporary modification controls including procedural adherence, appropriate tagouts, and
drawings not being up to date. The following examples illustrate these discrepancies: * During a review of the procedural temporary modification for cross-tying both trains of Reactor Building Closed Cooling Water, the inspectors identified that administrative
controls were not used as specified by the procedure. Specifically, tags were not
placed as specified on the control panel and on the piping and instrumentation drawing
(PI&D).
PNP-2009-1468 was written. * During a review of the reactor shutdown/flood-up level indication procedural temporary modification, the inspectors noted that a valve was not tagged as specified by the
procedure.
PNP-2009-2085 was written. * During a review of the MO-1001-50 shutdown cooling suction valve and pump interlock procedural temporary modification, the inspectors identified that Entergy did not update
the applicable control room drawing nor did they maintain a copy of the procedural
temporary modification in the control room as specified by the procedure.
PNP-
2009-2187 was written. The inspectors also identified that Entergy's temporary modification audit program requires
a quarterly review; however, there are no specific requirements to conduct audits during an
outage, a timeframe where a significant number of temporary modifications are
installed/implemented. The inspectors have concluded that the discrepancies identified
this quarter constitute a low level trend in the area of temporary modification controls. The
inspectors discussed this low level trend with Entergy and
PNP-2009-3064 was written
to document the examples and to specify corrective actions. The inspectors will follow Entergy's investigation and corrective actions to evaluate their response to this low level
trend.
.3 Annual Sample: Review of Risk Assessment Process Improvements and Management a. Inspection Scope (1 sample) The inspectors conducted a review of
PNP-2008-00946 to assess the effectiveness of
Entergy's corrective actions to improve the risk assessment process. The inspectors also
reviewed
NCV 05000293/2008005-
related to previous risk assessment issues, the RFO17 shutdown risk report, and attended
shutdown risk assessment meetings during the outage. b. Findings and Observations No findings of significance were identified. The inspectors concluded that Entergy's efforts to improve the assessment of the risk of
maintenance and testing activities, particularly emergent risk activities, have been
effective. The inspectors noted that the accuracy and communication of on-line and
shutdown risk assessment have improved and that Operations has taken a greater
leadership role in this process. The inspectors also noted that Entergy's shutdown risk
assessments during RFO17 more accurately reflected shutdown plant risk than they have
in the past and that Entergy took reasonable risk management actions during heightened
periods of risk. The inspectors did note that Entergy entered Orange risk conditions
several times during the outage and that Entergy may be able to avoid these heightened
risk activities by reviewing the activities and evaluating whether a different approach could
be used (e.g., evaluate whether the Loss of Offsite Power test can be conducted one train
at a time). The inspectors also noted that Entergy's risk assessment process should be
reviewed for improvements and updates (e.g., current risk communication methods, such
as risk information signs and color coded Outage Turnover reports, are not discussed in
this procedure) to more accurately reflect current risk assessment management
approaches.
4OA3 Event Follow-up (71153)
.1 Operator Response to Unplanned Loss of the 23KV Offsite Power Line
a. Inspection Scope (1 sample) On April 29, 2009, NStar de-energized a supply line which provides power to the shutdown
transformer. The loss of this power supply affected offsite power supplies for the
Technical Support Center, security loads, and auxiliary loads for the Station Blackout Emergency Diesel Generator. Operators entered Procedure 2.4.A.23, Loss/Degradation of
23KV Line, and verified that all onsite power supplies to the above loads had energized.
Power to the 23KV line was subsequently restored less than 10 minutes later. The
inspectors responded to the Control Room, reviewed applicable procedures and Technical
Specifications, and reviewed operator response. The documents reviewed during this
inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
.2 Refueling Personnel Response to Shroud Tie Rod Gap and Inability to Install the Separator
a. Inspection Scope (1 sample) On May 3, 2009, Refueling personnel identified a 1/2 inch gap between the core shroud
outside diameter and the tie rod upper support at the 135 degree location. The existence
of this gap was subsequently evaluated and the decision was made to leave the tie rod as-
is. On May 11, 2009, Refueling personnel identified a problem with the re-installation of
the separator. Visual inspections revealed that the separator was sitting on the 135
degree tie rod upper support. On May 12, 2009, the separator was removed from the
vessel and returned to the dryer/separator pool. Entergy and General Electric Hitachi
personnel generated a procedure to push the tie rod upper support closer to the shroud to
allow separator installation. The tie rod upper support was successfully pushed 1/2 inch
toward the core shroud and the separator was successfully seated, latched, and verified on
May 13, 2009.
The inspectors reviewed selected technical documents, the temporary procedure used to
re-position the tie rod upper support, and the Updated Facility Safety Analysis Report. The inspectors also attended the Onsite Safety Review Committee meeting which evaluated
this activity. The documents reviewed during this inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
.3 Operator Response to "B" Condensate Pump Leak
a. Inspection Scope (1 sample) On May 10, 2009, at approximately 10:00am, operators identified a leak coming from the
packing gland of the "B" condensate pump during fill of the condenser hotwell. The leakage was collecting in the condensate pump pit and draining to the radiological waste
system via the turbine building floor sumps. Operations stopped the fill of the hotwell and notified Mechanical Maintenance personnel. At that time, Mechanical Maintenance
personnel determined that the packing for the "B" condensate pump had not yet been
installed. Mechanical Maintenance personnel determined that a Mechanical Maintenance
supervisor had signed off of a work boundary tagout and had incorrectly reported that the
system was "pipe tight" to the Shift Outage Coordinator. Operations drained the condenser
hotwell to below the level of the "B" condensate pump packing, re-established the work
boundary tagout, and Mechanical Maintenance installed the "B" condensate pump packing
on May 11, 2009.
The inspectors interviewed Mechanical Maintenance personnel, Operations personnel and
Outage Control Center personnel and reviewed statements from Mechanical Maintenance
personnel. The inspectors reviewed control room logs, radiological waste logs, and
Outage Control Center logs. The inspectors reviewed the work order, tagouts associated
with the work order, and the timeline of the work, tagout removal, hotwell filling, problem discovery and resolution activities. The inspectors also reviewed the subsequent Apparent
Cause Evaluation conducted by the Maintenance Department. The documents reviewed
during the inspection are listed in the Attachment.
b. Findings and Observations No findings of significance were identified. The inspectors determined that Entergy did not
follow tagout procedure requirements and did not identify that work had not been
completed on the "B" condensate pump prior to signing off the work boundary tagout. This
failure to comply with tagout requirements constitutes a violation of minor significance that
is not subject to enforcement action in accordance with the NRC's Enforcement Policy. In
addition, the inspectors identified that no condition report was written by Entergy to
document the tagout problem and the resultant interruption to the hotwell fill activity at the time of the occurrence. An apparent cause evaluation was subsequently conducted and
corrective actions identified under
PNP-2009-02265 and was reviewed by the
inspectors.
.4 Operator Response to the Loss of Steam Jet Air Ejector Radiation Monitors
a. Inspection Scope (1 sample) On May 19, 2009, Operations determined that both pre-treatment (Steam Jet Air Ejector
(SJAE)) process radiation monitors were inoperable. As a result, Operators implemented
the Offsite Dose Calculation Manual (ODCM), Table 3.1-2, Radioactive Gaseous Effluent
Monitoring Instrumentation, requirements which allowed gases to continue to be released
from the
- SJ [[]]
AE to the offgas system for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provided the augmented offgas
system was not bypassed and that downstream post-treatment radiation monitors were
operable. Otherwise, the
- OD [[]]
CM would require the plant to be in hot standby within 12
hours. Operations also reviewed TS 3.8.1, Main Condenser Offgas, which requires that
the gross gamma activity rate of noble gases measured at a main condenser pre-treatment
monitor station shall be limited to 500,000 µCi/second whenever steam is available to the
air injectors. TS 3.8.1 requires the plant to be shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if this limit cannot
be met. However, Operations determined that TS 3.8.1 was met by a satisfactory "grab"
sample that is obtained once every 31 days as described in
ODCM to remove the 72-hour shutdown
requirement and to instead allow gases to continue to be released from the
- SJ [[]]
AE to the
augmented offgas (AOG) system as long as the AOG system is not bypassed, the post-
treatment radiation monitors were operable or tripped and capable of alarm and auto-
isolation of the main stack, the AOG charcoal area radiation monitor and control room
alarm are functional, and the TS 4.8.1.1 grab sample was performed once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
An additional option in the
TS 4.8.1.1 grab samples every 4
hours.
The inspectors reviewed the condition of the
- SJ [[]]
AE radiation monitors and concluded that
the inoperability of both
- OD [[]]
CM requirements and the
existence of additional equipment (e.g., AOG charcoal radiation monitors) and increased
sampling activities, and concluded that the requirements of TS 3.8.1 could reasonably be
shown to be met with these actions in place. The documents reviewed during this
inspection are listed in the Attachment.
b. Findings No findings of significance were identified.
.5 (Closed)
- LER 05000293/2008-006-00, Automatic Scram Resulting from Switchyard Breaker Fault during Winter Storm The inspectors reviewed Entergy's actions associated with the
LER, which are addressed
in the corrective action program as
PNP-2008-03962 and -03963. The event was
discussed in
OA3.5. No findings of
significance were identified and no violation of
LER
provided an accurate description of the event and follow-up actions, taken or planned,
were appropriate to address the event. This LER is closed.
.6 (Closed)
KV Off-Site Power to The Startup Transformer from Switchyard Breaker Fault The inspectors reviewed Entergy's actions associated with the LER, which are addressed
in the corrective action program as
PNP-2008-3980. The event was discussed in NRC
Inspection Report 05000293/2008005, Section 4OA3.6. No findings of significance were
identified and no violation of
LER provided an accurate
description of the event and follow-up actions, taken or planned, were appropriate to
address the event. This
OA5 Other Activities
Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope During the inspection period, the inspectors conducted observations of security force
personnel and activities to ensure that the activities were consistent with Entergy security
procedures and regulatory requirements relating to nuclear plant security. These
observations took place during both normal and off-normal plant working hours. These
quarterly resident inspector observations of security force personnel and activities did not
constitute any additional inspection samples and were considered an integral part of the
inspectors' normal plant status reviews and inspection activities.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
On April 2, 2009, an Occupational Radiation Safety exit meeting was held with Mr. Kevin
Bronson, Site Vice President. The inspectors verified prior to the exit meeting that the
inspector was not provided any proprietary information. On May 4, 2009, an In Service Inspection exit meeting was held with Mr. Kevin Bronson,
Site Vice President. The inspectors verified at the exit meeting that the inspector was not
provided any proprietary information. On May 5, 2009, an Occupational Radiation Safety exit meeting was held with Mr. Kevin
Bronson, Site Vice President. The inspectors verified at the exit meeting that the inspector
was not provided any proprietary information.
On July 7, 2009, the resident inspectors conducted an exit meeting and presented the
preliminary inspection results to Mr. Stephen Bethay, and other members of the Pilgrim
staff. The inspectors confirmed that proprietary information provided or examined during
the inspection was controlled or returned to Entergy and the content of this report includes
no proprietary information.
- ATTACH [[]]
- MENT [[:]]
- SUPPLE [[]]
- MENTAL [[]]
- INFORM [[]]
- INFORM [[]]
- ATION [[]]
- KEY [[]]
- POINTS [[]]
- OF [[]]
CONTACT
Licensee personnel:
K. Bronson Site Vice President
R. Smith General Manager Pilgrim Operations
S. Bethay Director, Nuclear Safety Assurance
T. Kelly Radiation Protection Technician
C. Littleton Probabilistic Risk Assessment Engineer J. Lynch Licensing Manager
W. Lobo Licensing Engineer
W. Mauro Supervisor, Radiological Engineering
D. Noyes Operations Manager
I. Onorato Radiation Protection Technician
J. Onorato Radiation Protection Technician
J. Priest Radiation Protection Manager
M. Thornhill Radiation Protection Supervisor T. Trainor Outage Manager
- LIST [[]]
- OF [[]]
- ITEMS [[]]
- CLOSED [[]]
- AND [[]]
- DISCUS [[]]
SED
Opened and Closed
NCV 05000293/2009003-01 Failure to Follow Procedure Resulting in Damage to Refueling
Mast
Opened
MG Set Room Peak Temperatures
Closed
KV Off-Site Power to The Startup Transformer from Switchyard Breaker Fault
A-2LIST
- OF [[]]
- REVIEW [[]]
ED Section 1R01
Procedure 8.C.40, Revision 24, Seasonal Weather Surveillance Procedure 2.1.37, Revision 25, Coastal Storm - Preparations and Actions
Procedure 2.1.42, Revision 8, Operation During Severe Weather
Procedure 5.2.2, Revision 31, High Winds (Hurricane)
PNP-2009-02835, Tornado Door 247 Found Open
Procedure 1.4.4, Revision 20, New England Power Grid Operations/Interfaces
Procedure 2.1.14, Revision 98, Station Power Changes
- NRC Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power
PNP-2008-1582, Discrepancies within Pilgrim Response to Generic Letter 2006-02
Procedure 1.5.22, Revision 11, Risk Assessment Process
ISO New England Procedure, Master/Local Control Center Procedure #1, Revision 7, Nuclear
Plant Transmission Operations
Master/LCC Procedure #1, Revision 7, Attachment A, Pilgrim Nuclear Station
Pilgrim Response to GL 2006-02, dated 4/03/2006
Section 1R04
Procedure 2.2.30, Revision 67, Reactor Building Closed Cooling Water System
PNP-2009-01468, Clarification of Temporary Modification Tag Requirements
Training Manual on RHR Shutdown Cooling
Procedure 2.2.19, Revision 99, RHR
Procedure 2.2.19.1, Revision 28, RHR System - Shutdown Cooling Mode of Operation
Procedure 8.9.1, Revision 112, Emergency Diesel Generator and Associated Emergency Bus
Surveillance
Procedure 2.2.8, Revision 94, Standby AC Power System (Diesel Generators)
Procedure 2.1.12.1, Revision 67, Emergency Diesel Generator Surveillance Training Manual, Reactor Core Isolation Cooling System
Procedure
RCIC Turbine Major Preventive Maintenance Inspection
Final Safety Analysis Report Chapter 4.7, Reactor Core Isolation Cooling System
Procedure 2.2.22, Revision 69, Reactor Core Isolation Cooling System
System Health Report
- RC [[]]
- RC [[]]
- RC [[]]
- RC [[]]
IC Turbine Flow and Pressure Outside of Specified Parameters
A-3Section 1R05
- UFS [[]]
AR Chapter 10.8, Fire Protection System
Fire Hazards Analysis Fire Area 1.30-Drywell
Procedure 5.5.2, Revision 42, Special Fire Procedure
Procedure 8.B.13, Revision 4, Hydrostatic Testing of Fire Hose
Procedure
PNP-2009-01894, Self-Adhesive Knee Pads on Drywell Equipment
Fire Hazards Analysis
Fire Damper Test Results
- UFS [[]]
AR Chapter 10.8.4.6, Fire Barrier System
Procedure 8.B.17.2, Revision 9, Inspection of Fire Damper Assemblies
Procedure 8.B.17.1, Revision 19, Inspection of Fire Door Assemblies
Procedure 8.B.14, Revision 41, Fire Protection Technical Requirements
Exemption Request #7, Fixed Suppression and Twenty-Foot Separation with no Intervening Combustibles Exemption Request #9, Fixed Suppression Where Alternate Shutdown Capabilities Exist Section 1R06
- PN [[]]
- PS Probabilistic Safety Assessment, Appendix E, Internal Flooding Analysis Equipment Out-of-Service Risk Assessment Tool
- PN [[]]
PS Flooding Calculations
Timeline of Fire Response to Fire in the HP Cal Lab
Section 1R08 Non Destructive Test (NDT) Examination Reports
- XI [[]]
- XI [[]]
TP08-034 R0, Temporary Procedure for Phased Array Ultrasonic Examination of Core Shroud Assembly Welds Using Sector-Line Scanning
A-4 In Vessel Remote Visual Examination
- BWR [[]]
- PNPS [[]]
RPV-N9A-1 Certificate of Examiner performance qualifications for penetrant, magnetic particle, ultrasonic (manual, performance demonstration initiative) and visual (VT1, 2 and 3). Documentation includes training and vision test results for selected examiners.
A-5 Section 1R11
Lesson Plan O-RQ-04-04-58, RFO 17 Just-In Time Training
Control Rod Drive Matrix Schematic
Significant Event Report 2-08, Reduced Shutdown Safety Margins
Section 1R12
Procedure
DC-203, Revision 1, Maintenance Rule Program
Procedure
DC-207, Revision 1, Maintenance Rule Periodic Assessment
Procedure
- NUMARC 93-01, Revision 2, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants Procedure
EN-DC-206, Revision 1, Maintenance Rule (a)(1) Process
Regulatory Guide 1.160, Revision 2, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants Procedure
DC-204, Revision 1, Maintenance Rule Scope and Basis
Scram Data Sheets
Technical Basis for Revising Maintenance Rule Unavailability Performance Criteria for Lines 342 and 355 Maintenance Rule
PNP-2008-3962, Reactor Scram Due to Switchyard Fault Section 1R13
Refueling Outage 17 Risk Review Report
Departure from Defense In-Depth Form for Power Availability Risk Assessment Review Checklists
Procedure 3.M.1-45, Revision 7, Outage Shutdown Risk Assessment
Departure from Defense In-Depth Forms dated 3/11/09, 4/8/09, 4/22/09 and 4/26/09
Temporary Procedure No.
RFO-17 Compensatory Measures
RFO 17 Outage Shift Turnover Sheets dated 4/23/09, 4/24/09 and 4/27/09
Procedure
ECCS Load Sequencing of Diesels and Shutdown Transformer with Simulated Loss of Off-site Power and Special Shutdown Transformer
Load Tests Outage Risk Notebook
Procedure 8.M.2-1.5.9, Revision 26, Primary Containment Isolation Valve Testing
Section 1R15
- PWT [[]]
OP-104, Operability Determinations Inspection Manual Part 9900, Technical Guidance
A-6Specification M301, Field Fabrication and Installation of Piping and Instrumentation
- UFS [[]]
- PNP -2009-01315, Operability Evaluation without Discussion of Visual Exam Operability Evaluation on CR-2009-01261 Procedure 2.2.108, Revision 42, Diesel Generator Cooling and Ventilation System
- PNP -2009-02016, Shutdown Transformer Relay did not close within its Technical Specifications Timeband
PNP-2009-02502, "B" Feed Regulating Valve Digital Controller Faults
Operational Decision-Making Issue (ODMI) for
PNP-2009-02502, Revision 0, dated May 22, 2009 Procedure 2.4.49, Revision 40, Feedwater Malfunctions
Procedure 2.2.82, Revision 41, Reactor Vessel Water Level Control System
Final Safety Analysis Report, Chapter 11.8. Condensate and Feedwater System
- UFS [[]]
PNP-2009-02707, Security Emergency Diesel Generator Does Not Meet Acceptance Criteria
Fire Hazards Analysis
Procedure 8.9.14, Revision 31, Security Diesel Generator Surveillance
UFSAR Chapter 10.8, Fire Protection System
Procedure 2.2.153, Revision 10, Security Diesel Generator and Backup Power System
PNP-2009-02707 Does Not Address Appendix R 8 Hour Lighting Requirement Section 1R18
Procedure
- 3.M. 2-40, Revision 6, Refuel Outage Temporary Modification Reactor Shutdown/Flood-up Level Indication Control Room Logs
PNP-2009-02085, NRC Resident Identified a tag missing from a level transmitter bypass valve
Procedure
DC Bus "A" or "B"
Procedure 2.2.19.1, Revision 28, Residual Heat Removal System - Shutdown Cooling Mode of Operation Control Room Logs for Temporary Modification Installation/Removal and Limiting Condition for Operation Entry
PNP-2009-02187, Control Room Drawing not annotated as specified by the Procedural Temporary Modification and paperwork not retained in the Control Room as specified by
Procedure
PNP-2009-00991, Modification in Vital MG Set Room Basis Not Retrievable
Standard Review Plan 9.4.5, Revision 2, Engineered Safety Feature Ventilation System
Turbine Building Design Calculation
- SD [[]]
BD-24, Revision O
ER 06118315, Update Structural Drawing C194 with Fan Detail
Procedure 2.4.153, Revision 18, Loss of Turbine Building Ventilation
Procedure
MS-S-009-PNPS, Revision 0, System Safety Function Sheets
Memorandum dated May 15, 1992, Assessment of Heatup of Vital
- UFS [[]]
AR 10.9-2, Design Temperatures
A-7Calculation N124, Revision 0, Vital
FRN-87-73-29, Seismic Restraints for Permanently Installed Booster Fan
Procedure 5.3.18, Revision 27, Loss of 120V AC Safeguard Buses Y3 and Y31
Cutler Hammer Circuit Breakers Data Sheets
- HPCI [[]]
- TC [[]]
- TD [[]]
Engineering Calculation C15.0.3434, Motor Stand for the
- HPCI [[]]
HPCI System Pump and Valve Quarterly and Biennial
Comprehensive Operability
- HPCI [[]]
TCTD Post Modification Tests
Cannot be Found
DC-117, Revision 2, Post Modification Testing and Special Instructions
Section 1R19
AC Power Source
- PN [[]]
PS Inspection
Temporary Procedure
SBODG via Safety
Bus A5 or A6 and Governor Response Check
V-0540, Blackout Diesel Generator Vendor Manual
Procedure 8.9.16.1, Manually Start and Load Blackout Diesel via the Shutdown Transformer
Station Blackout Governor Tuning Data
MO-1001-50
Procedure 3.M.3-51, Revision 26, Electrical Termination Procedure
Procedure
SMB-3 Valve
Operator Maintenance
MO-1400-25A
Procedure
MO-1400-25A
VDC Battery Bank
Procedure 8.9.8.2, Revision 20, "B"
PNP-2009-1705, The End of First Step Voltage Value was not met during the Service
Discharge Test 8.9.8.2
Procedure 3.M.3-25.3, Revision 13, Resistance Testing and Torquing of Station Batteries
Procedure 3.M.3-51, Revision 26, Electrical Termination Procedure
WO 00169979 01, 8.9.8.2B 125V D1 Battery Acceptance or Performance Test
TS 4.9.A.2, Station and Switchyard Batteries
A-8CR-PNP-2009-2538, Incorrect length of time chosen for battery equalizing time
RFO 17
Procedure 3.M.3-17.1, Revision 23, Raychem or Taping of 1000 Volt and Under Cables and/or
Wires
Procedure 3.M.3-4, Revision 53, Insulation Test
EC12133, Evaluate and Incorporate Replacement Fan Housing and Fan
Wheel Changes for
PNP-2009-2618, Post Maintenance Tests missing from Work Order
Technical Specifications
HCU-22-47)
WO 51527475, Remove and Replace Pump Internals, P201, Dust Maintenance
Power Maneuver Load Profile 5/12/09 Startup
Temporary Procedure TP08-017, Revision 1, Functional Test Following P-201A Rotating Element,
Cover and Motor Replacement
Procedure 2.2.84, Revision 100, Reactor Recirculation System
Procedure
MA-102, Attachment 9.2, Inspection Report of Electrical Portion of EC8218
Technical Manual for Target Rock Solenoid Operated Valve, Model 082511-001
Procedure 1.13.1, Revision 6, Postwork Test Matrices and Guidelines
Procedure 3.M.1-30, Revision 10, Postwork Testing Guidance
Section 1R20
- NUR [[]]
EG-0612, Control of Heavy Loads at Nuclear Power Plants
Procedure
- NUR [[]]
EG-1449, Shutdown and Low Power Operation at Commercial Nuclear Power Plants in the
United States
RFO-17, Just-In-Time Training
NRC Information Notice 93-72, Observations from Recent Shutdown Risk and Outage
Management Pilot Team Inspections
NRC Generic Letter 98-02, Loss of Reactor Coolant Inventory and Associated Potential for Loss
Of Emergency Mitigation Functions while in a Shutdown Condition
NRC Information Notice 2005-16, Outage Planning and Scheduling Impacts on Risk
Temporary Procedure TP08-027, Revision 0, Administrative Controls for Recirculation Pump
Motor Project P-201A Heavy Load Handling Activities in the Drywell
PNP-2009-02015, Station Risk Review Refers to TS 3.10D, which no longer exists
Pilgrim Relief Request 19, Jet Pump Instrumentation Nozzle Weld, RPV-N9A-1 Repair Plan
Procedure 2.2.19.1, Revision 28, Residual Heat Removal System - Shutdown Cooling Mode of
Operation
LI-102, Revision 13, Corrective Action Process
Procedure 3.M.4-9, Revision 14, Inspection of the Drywell and Suppression Chamber
Procedure 3.M.1-51, Revision 5, Readiness for Restart Reviews
A-9 Entergy Memorandum dated May 15, 2009, Results of UT Examination of Jet Pump
Instrumentation Nozzle
PNP-2009-2386, PV-9239 300# Regulator Connecting Link Assembly Nut Tightened by
Engineer
PNP-2009-2408, Results of Drywell Inspection
RFO-17 Daily Outage Shift Turnover Sheets
Procedure 2.1.1, Revision 167, Startup from Shutdown
Procedure 2.1.14, Revision 98, Station Power Changes
Procedure 2.1.5, Revision 109, Controlled Shutdown from Power
Procedure 2.1.7, Revision 52, Vessel Heatup and Cooldown
Contingency Plan for Freeze Seal on HCU50-39
Part 9900: Technical Guidance, Mechanical Freeze Plugs
PNP-2009-1828, Control Rod Blade Moved to the Wrong Location
Critical Step Review for Bridge Operation
Section 1R22
Procedure 8.7.1.6, Revision 25, Local Leak Rate Testing of the Main Steam Isolation Valves
- MS [[]]
IV As-Found Leak Rate @ 23 psig
PNP-2009-02016, Loss of Offsite Power Test Acceptance Criteria Not Met
Procedure 1.3.34, Revision 116, Operations Administrative Policies and Processes
Procedure
ECCS Load Sequencing of Diesels and Shutdown
Transformer with Simulated Loss of Offsite Power and Special Shutdown Transformer
Load Test
Procedure 9.9, Revision 64, Control Rod Scram Insertion Time Evaluation
Control Rod Scram Testing Data Forms
Technical Specifications Amendment 279, Revise Requirements for Control Rod Scram Insertion
Times
PNP-2008-00748, Control Rod 22-07 Identified as a Slow Rod
Procedure 2.1.8.5, Revision 21, Reactor Vessel Pressurization and Temperature Control for
Class 1 System Leakage Test
Procedure 8.7.1.4.1, Revision 19, Primary Containment Integrated Leak Rate Test Preparations
Procedure 8.7.1.4.2, Revision 17, Primary Containment Integrated Leak Rate Test
- IL [[]]
- HP [[]]
CI run allowed reactor pressure to drop significantly
Procedure 8.5.4.3, Revision 48, High Pressure Coolant Injection Operability Demonstration And Flow Rate Test at 150 psig
PNP-2009-02856, Leakage Rate Test Results Discrepancies observed
A-10 Section 1EP6
Procedure
Controller Manual Combined Functional Drill (09-02), May 28, 2009 EP Performance Indicator Reporting Form
Section 2OS1
Procedures:
- ALA [[]]
RP-150 Radiography and X-Ray Testing, Revision 5
6.1-220 Radiological Controls for High Risk Evolutions, Revision 5 Condition Reports:
2008-03470, 03481, 03498, 03575, 03576, 03604, 03632, 03639, 03733, 03759, 03845, 04077
2009-00665, 01057, 01115, 01138, 01139, 01379, 01458, 01459, 01462, 01474, 01483, 01487,
01603, 01626, 01666, 01682, 01693, 01698, 01723, 01725, 01821, 01885 Radiation Work Permits:
2009-0016, 0039, 0050, 0051, 0052, 0053, 0054, 0055, 0056, 0064, 0065, 0066, 0067, 0068,
0073, 0090, 0093, 5016, 0035, 0040, 0042, 0043, 0049, 0063, 0069, 0070, 0074, 0079, 0083,
0085, 0086, 0100, 0101, 0105, 0107, 0501
Other
2007 Radiation Protection Program Annual Report
Section 2OS2
Procedures:
- ALA [[]]
RA Program, Revision 5
6.1-220 Radiological Controls for High Risk Evolutions, Revision 5
Condition Reports:
2008-03562, 03631, 03758, 03675
2009-00045
A-11
- ALA [[]]
- ALA [[]]
PM09-08
Miscellaneous Records & Reports:
Hot Spot Master Tracking list as of 3/31/2009
Pilgrim Station 5 Year
- ALA [[]]
- PNPS [[]]
RFO 17 Chemistry Start Up / Shutdown and Outage Control Plan
Section 4OA1
NRC Performance Indicator Report for Pilgrim
NEI 99-02, Revision 5, Regulatory Assessment Performance Indicator Guidelines
Licensee Event Reports Issued from the 1st quarter 2008 through the 1st quarter 2009 TS 3.6.B, Coolant Chemistry
Pilgrim Chemistry Records for Reactor Coolant System Radioactivity (Total Iodine per ml of Water) Control Room Logs
PI Data Sheets
Procedure
LI-114, Revision 4, Performance Indicator Process
Section
- HPCI [[]]
- TM [[]]
- TM [[]]
- TM [[]]
- TM [[]]
PNP-2008-03792, Failure to Conduct at Risk Review for Out-of-Service Equipment
RFO-17 Outage Risk Assessment Report
RFO-17 Daily Shutdown Risk Assessments
Non-Cited Violation (NCV)05000293/2008002-01, Inadequate Risk Assessment for Emergent Maintenance on A5 Emergency Bus Undervoltage Relays NCV 05000293/2008005-01, Failure to Conduct a Risk Assessment for Emergent Maintenance
On the High Pressure Coolant Injection System
A-12 Section 40A3
Technical Specification 3.9, Auxiliary Electrical System
Control Room Logs
Procedure 2.4.A.23, Revision 12, Loss/Degradation of
PNP-2009-1951, Loss of 23KV Power Supply to the Shutdown Transformer
Operations and Maintenance Event Timelines
PNP-2009-02265, Installation Sequence for Condensate Pump Lantern Ring Necessitated Additional Engineering and Maintenance Resources WO 00135745, Task 1, Condensate Pump "B"
Personnel Statements
PNP-2009-1581, Inadequate Tagout for "B" Condensate Pump
Condensate and Feed Maintenance Rule Basis Document
PNP-2009-2300, Nuclear Safety Concern with "B" Condensate Pump Work
"B" Condensate Pump Tagout
Control Room Narrative Logs
Outage Control Center Log
Tagout Log
- DC -149, Revision 2, For Document 0000-0101-7465 Confirmation of the Acceptability of the Pilgrim Shroud Repair Assemblies for Future Operation Following 2009 Refueling Outage
- PNPS [[]]
- UFS [[]]
- WM -104, Revision 0, On-Line Risk Assessment of Loss of both Steam Jet Air Ejector Radiation Monitors Procedure
- 8.C. 34, Revision 49, Operations Technical Specifications Requirements for Inoperable Systems/Components
CR-PNP-2009-2515, Pre-Treatment Radiation Monitors Declared Inoperable Due to Low Flow
Radiation Monitoring Maintenance Rule Basis Document
PNP-2009-02508, Night Shift Chemistry Technicians Forced to Perform an Offgas Sample
Pilgrim Active LCO Log
Chemistry Logs for
- SJ [[]]
- PN [[]]
PS Offsite Dose Calculation Manual
Licensee Amendment 177, dated July 31, 1998
PNP-2008-3980, Loss of 345KV off-site power on 12/20/2008
A-13
- LIST [[]]
- OF [[]]
- ACRONY [[]]
- ALA [[]]
CEDE Committed Effective Dose Equivalent
CR Condition Reports
DRP Division of Reactor Projects
- OD [[]]
CM Offsite Dose Calculation Manual
PI Performance Indicator