ML102990265
| ML102990265 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/26/2010 |
| From: | Diane Jackson NRC/RGN-I/DRP/PB5 |
| To: | Bronson K Entergy Nuclear Operations |
| Jackson, D E RI/DRP/PB5/610-337-5306 | |
| References | |
| IR-10-004 | |
| Download: ML102990265 (35) | |
See also: IR 05000293/2010004
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PA 19406-1415
October 26, 2010
..
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 05000293/2010004
Dear Mr. Bronson:
On September 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report
documents the results, whit:h were discussed on October 13, 2010, yvith you and members of
your staff.
The inspection examined activities performed 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.
This report documents one NRC identified 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 this finding as a non-cited violation (NCV), consistent with Section 2.3.2.a of the
NRC's Enforcement Policy. If you contest any NCV, 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, A TIN.: 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 PNPS. In addition, if you disagree with the cross-cutting aspect assigned
to the finding in this report, you should provide a response within 30 days of the date of this
inspection report, with the basis for your disagreement, to the Regional Administrator, Region I,
and the NRC Senior Resident Inspector at PNPS.
K. Bronson
2
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of the
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
..
http://www.nrc.gov/reading-rm/adams.html(the Public Electr<1nic Reading Room).
Sincerely,
~t:""""'CAl--
Donald E. Jac on. Chief
Projects Branch 5
Division of Reactor Projects
Docket No.
50-293
License No.
Enclosure:
Inspection Report 05000293/2010004
w/Attachment: Supplemental Information
cc; w/encl:
Distribution via ListServ
\\
\\
K. Bronson
2
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available RElcords (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).
..
Sincere~y,
IRA!
Donald E. Jackson, Chief
Projects Branch 5
Division of Reactor Projects
Docket No.
50-293
License No.
Enclosure:
Inspection Report 05000293/2010004
w/Attachment: Supplemental Information
Distribution w/encl:
W. Dean, RA
(R10RAMAIL RESOURCE)
T. Setzer, DRP
M. Dapas, DRA (R10RAMAIL RESOURCE)
\\
D. Lew, DRP
(R10RAMAIL RESOURCE)
B, Smith, DRP, RI
J, Clifford, DRP (R1DRPMAIL RESOURCE)
S. Campbell, DRP, Resident OA
D. Collins, DRP (R1DRPMAIL RESOURCE)
A. Ford, DRP, Resident OA
D. Roberts, DRS(R1DRSMAIL RESOURCE)
D. Bearde, DRS
P. Wilson, DRS (R1DRSMAIL RESOURCE)
RidsNrrPMPilgrim Resource
L. Trocine, RI OEDO
RidsNrrDorlLPL1-1 Resource
D, Jackson, DRP
ROPreports Resource@nrc,gov
SUNSI Review Complete: _--!..TC::::,lS"--__ (Revlewer's Initials)
DOCUMENT NAME: G:\\DRP\\BRANCH5\\Reports\\Drafts\\pil2010004.docx
After declaring this document "An Official Agency Record" it will be released to the Public,
To receive a copy of this document, indicate in the box: "e" =Copy without attachment/enclosure "E" =Copy with
attachment/enclosure UN" = No copy
OFFICE
RIIDRP
Ilhp RIIDRP
l IRIIDRP
I
NAME
MSchneiderlTCS for
TSetzerlTS
- DJackson/DJ
DATE
10/19/10
10/19110
110/25/10
OFFICIAL RECORD COpy
U.S. NUCLEAR REGULATORY COMMISSION
"
REGION I
Docket No:
50-293
License No:
Report No:
Licensee:
Entergy Nuclear Operations. Inc.
Facility:
Pilgrim Nuclear Power Station (PNPS)
Location:
600 Reeky Hill Road
Plymouth. MA 02360
Inspection Period:
July 1. 2010 through September 30, 2010
Inspectors:
Approved By:
M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP)
B. Smith, Resident Inspector, DRP
R. Rolph, Health Physicist. Division of Reactor Safety (DRS)
J. Trapp, Plant Support Branch 1 , Branch Chief, DRS
B. Yip. Physical Security Inspector, DRS
Donald E. Jackson, Chief
Projects Branch 5
Division of Reactor Projects
Enclosure
2
TABLE OF CONTENTS
SUMMARY OF FINDINGS ...............................................................................................................3
REPORT DETAILS ..........................................................................................................................4
i.REACTOR SAFETy .....................................................................................................................4
1ROi
Adverse Weather Protection ................................................................................4
1R04
Equipment Alignment ...........................................................................................5
1R05
Fire Protection ......................................................................................................6
1R06
Flood Protection Measures ..................................................................................7
1R07
Heat Sink Performance ........................................................................................7
1R11
Licensed Operator Requalification Program .........................................................8
1R12
Maintenance Effectiveness ..................................................................................8
1R13
Maintenance Risk Assessments and Emergent Work Control} .............................8
1R 15
Operability Evaluations ...................................................................................... 1 0
1 R 18
Plant Modifications .............................................................................................11
1R 19
Post-Maintenance Testing .................................................................................12
1R22
Surveillance Testing ...........................................................................................12
1EP6
Drill Evaluation ...................................................................................................13
2.RADIATION SAFETY ...\\ ........................................................... \\' ............................................... 13
2RS06
Gaseous and Liquid Effluent Treatment.. ........................................................... 13
4.0THER ACTIViTIES ...................................................................................................................15
40A1
Performance Indicator (PI) Verification ................................................................15
40A2
Identification and Resolution of Problems ........................................................... 16
40A3
Event Follow-up .................................................................................................17
40A5
Other Activities ...................................................................................................18
40A6
Meetings, Including Exit ......................................................................................22
SUPPLEMENTAL INFORMATION ............................................................................................. A-1
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-9
Enclosure
3
SUMMARY OF FINDINGS
IR 05000293/2010004; 07101/2010-09/30/2010; Pilgrim Nuclear Power Station; Maintenance Risk
Assessments and Emergent Work Control.
The report covered a three-month period of inspection by the resident and region based inspectors ...
One Green non-cited violation (NCV) was identified. The significance of most findings is indicated
by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (lMC) 0609,
"Significance Determination Process." The cross-cutting aspect for the finding was determined
using IMC 0310, "Components Within The Cross-Cutting Areas." Findings for which the significance
determination process does not apply may be Green or be assigned a severity level after NRC
management review. The NRC's program for overseeing the safe operation of commercial nuclear
power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated
December 2006.
Cornerstone: Initiating Events
Green. The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65
paragraph (a)(4) for Entergy's failure to manage a Yellow risk condition for an unplanned
half-scram. Specifically, Entergy performed an incorrect risk assessment and thereby did not
recognize an increase in risk to a Yellow condition had occurred, and as a result Entergy did
not specify any risk management actions. Entergy entered this issue into their corrective
action program, specified corrective actions to upgradr this risk to Yellow, and implemented
appropriate risk management actions.
This finding was determined to be more than minor because Entergy did not consider the
increase in Initiating Event likelihood where the outcome of the overall elevated plant risk put
the plant into a higher risk management category, and thereby required additional risk
management actions. In addition, the finding affected the Human Performance attribute of
the Initiating Events cornerstone's objective to limit the likelihood of those events that upset
plant stability and challenge critical safety functions. The inspectors performed an evaluation
in accordance with IMC 0609, "Significance Determination Process," Appendix K,
"Maintenance Risk Assessment and Risk Management Significance Determination Process,"
because the finding related to Entergy's assessment anci management of risk. The finding
was determined to be of very low safety significance (Gmen) because the Incremental Core
Damage Probability Deficit for the medium trip risk for the durati.On of the activity was less
than 1.0 E-6 per year (approximately 1.0 E-9 per year). The inspectors determined that this
finding had a cross-cutting aspect in the Human Performance cross-cutting area, Decision
Making component, because when faced with an unexpected plant condition, Entergy did not
correctly implement its systematic process to make a risk-significant decision. [H.1 (a)]
(Section 1 R13)
Enclosure
i
.1
4
REPORT DETAILS
Summary of Plant Status
..
Pilgrim Nuclear Power Station (PNPS) began the inspection period operating at 100 percent power.
On July 15, 2010, operators reduced power to 50 percent to p13rform a thermal backwash of the
main condenser. Pilgrim returned to 100 percent power on July 16, 2010. On July 19, 2010,
operators reduced power to 88 percent for a control rod pattern adjustment and returned to 100
percent power later the same day. On August 1, 2010, operators reduced power to 48 percent for
an unplanned backwash of the main condenser due to a large deposition of mussels in the main
condenser. Pilgrim returned to 100 percent power on August 2, 2010. On August 3, 2010,
operators reduced power to 89 percent for a control rod pattern adjustment and returned to 100
percent power later the same day. On August 17, 2010, operators reduced power to 48 percent to
perform a thermal backwash. Pilgrim returned to 100 percent power on August 18, 2010. On
August 20, 2010, operators reduced power to 87 percent for a control rod pattern adjustment and
returned to 100 percent power later the same day. Operators maintained the reactor at or near 100
percent power for the remainder of the inspection period.
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01
Adverse Weather Protection (71111.01)
Seasonal Susceptibility
a.
Inspection Scope (1 sample)
The inspectors performed a review of seasonal weather preparations during the week of
July 4, 2010, to evaluate the site's readiness for the onset of hot weather. The inspectors
reviewed the readiness of three risk-significant plant areas, which included the Reactor
Building, the Turbine Building, and the Control Room. 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 performed partial walkdowns of the Reactor Building, Turbine
Building, associated fan rooms, and the Control Room to determine the adequacy of
equipment protection from the effects of hot outside temperatures. The documents reviewed
during the inspection are listed in the Attachment.
b.
Findings
No findings were identified.
Enclosure
5
.2
External Flooding
a.
Inspection Scope (1 sample)
The inspectors reviewed the Pilgrim plant design and procedures for coping with the design
basis probable maximum flood during the week of August 23, 2010. The inspectors
reviewed the "Storm Flooding Protection" section of the Updated Final Safety Analysis
Report (UFSAR) and operating procedures for mitigating external flooding conditions during
severe weather. The inspectors also performed a walkdown of the site to determine if all
susceptible flooding conditions had been considered in the plant design, and whether
operating procedures could be reasonably carried out to mitigate flooding concerns. The
documents reviewed during this inspection are listed in the Attachment.
b.
Findings
No findings were identified .
. 3
Imminent Adverse Weather
a.
Inspection Scope (1 sample)
During the week of August 30. 2010, Hurricane Earl was tracking to impact the Pilgrim plant
late in the week. {he inspectors reviewed Entergy's preparations for the hurricane and the
high winds expected to accompany the storm. The inspectors reviewed Entergy's severe
weather procedures including operations during SeVerE! weather, coastal storm preparation,
and high winds (hurricane) procedures. The inspectors also conducted a walkdown of the
outside areas including the switchyard to determine if loose debris or other material could
become airborne in the presence of high winds and thereby potentially impact safety related
equipment. The documents reviewed during this inspection are listed in the Attachment.
b.
Findings
No findings were identified.
1 R04 Equipment Alignment (71111.04)
.1
Partial System Walkdowns (71111.040)
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
procedures, and to identify any discrepancies that may have had an effect on operability.
The walkdowns included selected control switch position verifications, valve pOSition checks,
and verification of electrical power to critical components. In addition, the inspectors
evaluated other elements, such as material condition, housekeeping, and component
Enclosure
6
labeling. The following systems were reviewed based on their risk significance for the given
plant configuration:
High Pressure Coolant Injection (HPCI) System with Reactor Core Isolation Cooling
(RCIC) Systj?m Out of Service for Maintenance;
..
- "A" Core Spray System Following Maintenance and Testing.
b.
Findings
No findings were identified .
. 2
Complete System Walkdowns (71111.04S)
a.
Inspection Scope (1 sample)
The inspectors completed a detailed review of the Station Blackout (SBO) Emergency Diesel
Generator(EDG) 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 and breakers. were aligned in accordance with operating procedures, and to assess
the material condition of valves, piping, and other supporting equipment. The inspectors
discussed system health with the system engineer, reviewed the system's Maintenance Rule
status, and performed a review of outstanding mainten'lnce work orders to determine
whether the deficiencies significantly affected the SBO EDG system fUnction. The inspectors
also reviewed condition reports from the past year to determine whether SBO EDG
eqUipment problems were being identified and appropriately resolved. The documents
reviewed during this inspection are listed in the Attachment.
b.
Findings
No findings were identified.
1 R05 Fire Protection (71111.05)
Fire Protection - Tours (71111.050)
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 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 and
fire barriers. 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:
Enclosure
7
Fire Area 1.21, Fire Zone 1.21, "A" Reactor Building Closed Cooling Water (RBCCW)
Pumps/Heat Exchanger Room;
Fire Area 1.10, Fire Zone 1.22, "B" RBCCW Pumps/Heat Exchanger Room;
Fire Area 1.9, Fire Zone 1.1, "A" Residual Heat Removal and Core Spray Pumps
Quadrant;
..
Fire Area 1.10, Fire Zone 1.10A, Traversing In~Core Probe Room; and
Fire Area 1.10, Fire Zone 1.4, High Pressure Coolant I njection Control Panel Room.
b.
Findings
No findings were identified.
1 R06 Flood Protection Measures (71111.06)
Internal Flooding Inspection
Inspection Scope (1 sample)
The inspectors walked down the "A" R8CCW pump room and associated flood propagation
pathways to assess the effectiveness of Entergy's internal flood control measures. The
inspectors assessed the condition of the RBCCW floor drain to the torus room, curbing,
selected flood pathways, and the flood door separating the "A" and "8" RBCCW rooms. The
inspectors also evaluated whether potential source~ o'f internal flooding were analyzed. The \\
documents reviewed during this inspection are listea in the Attachment.
b.
Findings
No findings were identified.
1 R07 Heat Sink Performance (71111.07)
a.
Inspection Scope (1 sample)
The inspectors reviewed one sample of Entergy's program for maintenance, testing, and
monitoring of risk significant heat exchangers (HXs) to assess the capability of the HXs to
perform their design functions. The inspectors assessed whether the HX program
conformed to Entergy's commitments at Pilgrim related to NRC Generic Letter 89-13,
"Service Water System Problems Affecting Safety~Related Equipment." In addition, the
inspectors evaluated whether potential common cause heat sink performance problems
could affect multiple HXs in mitigating systems or result in an initiating event. Based on risk
significance and prior inspection history, the "A" RBCCW Heat Exchanger was selected for
detailed review by the inspectors.
b.
Findings
No findings were identified.
Enclosure
8
1R11
Licensed Operator Requalification Program (71111.11)
Resident Inspector Quarterly Review (71111.11 Q)
a.
Inspection Scope (1 sample)
..
The inspectors observed licensed operator performance during a simulator as-found
Licensed Operator Requalification training evaluated scenario on July 26. 2010. The
inspectors observed crew response to a scenario which included a steam release into the
secondary containment. The inspectors assessed the licensed operators' performance to
determine if the training evaluators adequately addressed observed deficiencies. The
inspectors reviewed the applicable training objectives from the scenario to determine if they
had been achieved. In addition. the inspectors performed a simulator fidelity review to
determine if the arrangement of the simulator instrumentation. controls. and tagging closely
paralleled that of the control room. The documents reviewed during this inspection are listed
in the Attachment.
b.
Findings
No findings were identified.
1 R 12 Maintenance Effectiveness (71111.12Q)
Inspection Scope (2 samples)
The inspectors reviewed the two samples 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 paragraph (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 paragraph (a)(1) or (a)(2); and (8) appropriateness of performance criteria
for structures, systems. and components (SSCs)/functions classified as paragraph (a)(2)
and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions
classified as paragraph (a)( 1). The documents reviewed during this inspection are listed in
the Attachment. Items reviewed included the following:
"C" Salt Service Water Pump Experiencing High Vibrations; and
Station Blackout Emergency Diesel Generator System.
b.
Findings
No findings were identified.
1 R13 Maintenance Risk Assessments and_Emergent Work Control (71111.13)
a.
Inspection Scope (5 samples)
The inspectors evaluated five maintenance risk assessments for planned and emergent
maintenance activities. The inspectors reviewed maint,enance risk evaluations, work
Enclosure
1
9
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 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:
- Yellow Risk for Planned Testing for Reactor Core Isolation Cooling;
Green Risk for Emergent Half Scram and Diesel Fire Pump Out of Service;
- Yellow Risk during Calibration of the "A" Emergency Diesel Generator Temperature
Switch;
- Yellow Risk during Reactor Building Closed Cooling Water Support Bolt Replacement;
and
- Yellow Risk during the week of August 30, 2010, due to the Shutdown Transformer and
Station Blackout Emergency Diesel Generator Out of Service and the onset of Hurricane
Earl.
b.
Findings
Introduction: The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65
paragraph (a)(4lfor Entergy's failure to identify and manage a Yellow risk condition for an
unplanned half-scram. Specifically, an incorrect risk assessment resulted in Entergy not
recognizing an increase in risk to a Yellow condition, and therefore no risk management
actions were taken.
Description: On July 26, 2010, operators received an unplanned half-scram on the "8"
channel of their Reactor Protection System (RPS) and determined the cause was a failure of
the power supply to that channel. During the event, Entergy's Diesel Fire. Pump was out of
service for scheduled maintenance. In addition, Entergy had input into their Equipment Out
of Service (EOOS) risk assessment model an increase in Loss of Offsite Power risk (LOOP
risk low) for an ongoing upgrade project to their 345 kilovolt (kV) relay protection scheme.
Following the half-scram, Entergy performed a risk assessment and concluded that they
remained green for their equipment configuration and initiating event inputs.
The inspectors inquired with operations about the adequacy of the emergent risk
assessment. Specifically, the inspectors noted that the likelihood for a reactor scram had
increased due to one half ("B" channel) of the scram channels being placed in the trip
condition. Following the discussion, operations performed a second risk assessment and
input an increase in the trip likelihood (Trip risk medium in EOOS) into their model.
Operations concluded that their risk characterization was now Yellow for their equipment
configuration and the additional initiating event input. Entergy then implemented risk
management actions for the Yellow condition, which included protecting the Vital Motor
Generator Set Room.
Analysis: The performance deficiency associated with this finding is that Entergy performed
an incorrect risk assessment for an emergent half scram and, as a result. did not take risk
management actions as specified by 10 CFR 50.65(a)(4). Traditional Enforcement did not
Enclosure
10
apply as the issue did not have actual or potential safety consequence, had no willful
aspects, nor did it impact the NRC's ability to perform its regulatory function.
A review of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, "Minor Examples,"
identified that Section 7, Maintenance Rule, Example e, reflected a similar more than minor
example. This finding was determined to be more than minor because Entergy did not
consider the increase in Initiating Event likelihood, where the outcome of the overall elevated
plant risk put the plant into a higher risk management category and thereby required
additional risk management actions. In addition, the finding affected the Human
Performance attribute of the Initiating Events cornerstone's objective to limit the likelihood of
those events that upset plant stability and challenge critical safety functions. The inspectors
performed an evaluation in accordance with IMC 0609, "Significance Determination
Process," Appendix K, "Maintenance Risk Assessment and Risk Management Significance
Determination Process," because the finding related to Entergy's assessment and
management of risk. The finding was determined to be of very low safety significance
(Green) because the Incremental Core Damage Probability Deficit for the medium trip risk for
the duration of the activity was less than 1.0 E-6 per year (approximately 1.0 E-9 per year).
The inspectors determined that this finding had a cross-cutting aspect in the Human
Performance cross-cutting area, Decision Making component, because when faced with an
unexpected plant condition, Entergy did not correctly implement its systematic process to
make an appropriate risk-significant decision. [H .1 (a)]
Enforcement: 10 CFR 50.65 paragraph (a)(4), "ReqJirements for Monitoring the
Effectiveness of Maintenance at Nuclear Power Plants," states, in part, that " ... the licensee
shall manage the increase in risk that may result from the proposed maintenance activities."
Contrary to the above, on July, 26, 2010, Entergy incorrectly assessed the increased risk that
resulted from an emergent condition. As a result. Entergy did not recognize the Yellow risk
condition and thus did not take any risk management actions. Corrective actions included
Entergy upgrading their risk characterization to Yellow and taking risk management actions
which included protecting the Vital Motor-Generator Set Room. Because of the very low
safety-significance and because it has been entered into the corrective action program (CR
PNP-2010-3440), the NRC is treating this as a non-cited violation (NCV), consistent with
Section 2.3.2 a of the NRC's Enforcement Policy. (NCV 05000293/2010004-01, Failure to
Manage a Yellow Risk Condition for an Unplanned Half Scram)
1 R15 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 Entergy's performance against related Technical Specifications and Updated Final
Safety Analysis Report requirements. The documents reviewed during this inspection are
listed in the Attachment. The inspectors reviewed the following degraded or non-conforming
conditions:
Enclosure
.1
11
- CR-PNP-2010-2264, Scram Discharge Volume West Not Drained Alarm;
- CR-PNP-2010-2355, Lack of Board Certified Rated Capacities for Safety Relief Valves;
- CR-PNP-2010-2935, High Pressure Coolant Injection Steam Admission Valve Packing
Leak;
~
.
~
- CR-PNP-2010-2594, Reactor Building Closed Cooling Water Suction Header for Both
Loops Show Signs of Degradation; and
CR-PNP-2010-2645, Buried Condensate Storage Tank Transfer Piping Indications.
b.
Findings
No findings were identified.
1R18 Plant Modifications (71111,18)
Temporary Modification to Modify Drain Piping to Facilitate Validating the Integrity of the
Main Stack Drain Line
a.
Inspection Scope (1 sample)
The inspectors reviewed Temporary Modification EC 23807, "Modify Drain Piping to
Facilitate Validating the Integrity of the Main Stack Drain Line," to determine whether the
integrity of Secondary Containment had been de9[aded through the modification. The
\\
inspectors reviewed Control Room drawings, calculations. work orders, and limiting condition
of operation logs to ensure the temporary modification did not adversely affect the integrity of
secondary containment. The inspectors reviewed the annotated drawings to determine
whether they properly reflected the temporary modification. The inspectors also walked
down the High Pressure Coolant Injection Control Panel Room to review the installed
modification. The documents reviewed during this inspection are listed in the Attachment.
b.
Findings
No findings were identified .
. 2
Temporarv Modification to Gag AO-N-98 in the Open Position
a.
Inspection Scope (1 sample)
The inspectors reviewed Temporary Modification EC 23892, "Gag AO-N-98 in the Open
Position,>> to determine whether the performance capability of the Standby Gas Treatment
(SBGT) System had been degraded through the modification. The inspectors reviewed
Control Room and procedural drawings, relevant condition reports, and work orders to
ensure the temporary modification did not adversely affect the SBGT system. The inspectors
reviewed the annotated drawings to determine whether they properly reflected the temporary
modification. The inspectors also walked down the Traversing In-Core Probe room to review
the installed modification. The documents reviewed during this inspection are listed in the
Attachment.
Enclosure
12
b.
Findings
No findings were identified.
1R19 Post-Maintenance Testing (71111.19)
..
a.
Inspection Scope (6 samples)
The inspectors reviewed six samples of post-maintenance tests during this inspection period.
The inspectors reviewed these activities to determine whether the post-maintenance test
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 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 maintenance activities and their
post-maintenance tests were evaluated:
- Voltage Balance Relay Replacement for Relay 160-609 on the "B" Emergency Diesel
Generator;
- "C" Salt Service Water Pump Rebuild;
\\
- Replace Reactor Building Closed Cooling Water Temperature Control Valve Linkage;
- Electric Fire Pump Replacement;
- Temporary Modification to Gag Open AO-N-98; ancl
- Station Blackout Emergency Diesel Generator, Shutdown Transformer and AS Bus Relay
Maintenance.
b.
Findings
No findings were identified.
1 R22 Surveillance Testing (71111.22)
a.
Inspection Scope (5 samples)
The inspectors witnessed five surveillance activities and/or reviewed test data 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:
Enclosure
13
Control Rod Weekly Exercise;
High Pressure Coolant Injection Quarterly In-Service Test (1ST);
Station Blackout Emergency Diesel Generator Test;
Core Spray Keepfill Check; and
Reactor Coolant System (RCS) Leakage Detection.
b.
Findings
No findings were identified.
1 EP6 Drill Evaluation (71114.06)
Cornerstone: Emergency Preparedness
a.
Inspection Scope (1 sample)
The inspectors observed licensed operator "as-found", simulator training on July 26,2010.
The inspectors evaluated the operating crew activities related to an accurate and timely
classification and notification of a site area emergency. Additionally, the inspectors assessed
the ability of training evaluators to adequately address operator performance deficiencies
identified during the exercise. The documents reviewed during this inspection are listed in
the Attachment.
1
b.
Findings
No findings were identified.
2.
RADIATION SAFETY (RS)
Cornerstone: Occupational/Public Radiation Safety
2RS06 Gaseous and liquid Effluent Treatment (71124.06)
a.
Inspection Scope
During the period July 12,2010 through July 15,2010, the inspectors performed the
following activities to verify the gaseous and liquid effluent systems are maintained, and
discharges and conditions are control/ed in accordance with applicable regulatory
requirements and Pilgrim procedures.
Inspection Planning
The inspectors reviewed the Effluent and Waste Disposal 2008 Annual Report. The
inspectors noted no anomalous results and reviewed the effluent monitor operability issues
reported. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and
descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent
flow paths. The inspectors reviewed the changes made to revision 10 of Pilgrim's Offsite
Dose Calculation Manual (ODeM). The inspectors verified there were no systems
Enclosure
14
contaminated with licensed material that were previously uncontaminated. The inspectors
reviewed reported groundwater monitoring results, and changes to the Pilgrim written
program for identifying and controlling contaminated spillslleaks to groundwater. The
inspectors reviewed reports and procedures for the effluent program .
Walk-downs and Observations
The inspectors walked down accessible components of the gaseous and liquid discharge
systems. The inspectors verified the equipment configuration and flow paths aligned with the
UFSAR. The inspectors observed the equipment physical condition. The inspectors
determined no condition surveillance records exist for areas that are not readily accessible.
The inspectors walked-down the filtered ventilation systems and verified there were no
degraded High Efficiency Particulate Assemblies or charcoal banks, improper alignment, or
system installation issues that would impact performance, or the effluent monitoring
capability, of the effluent system. The inspectors observed sampling and analysis of the
main stack ventilation. The inspectors verified that no changes have been made to effluent
release points. The inspectors observed the simulated sampling and analysis of a Treated
Water Tank (TWT) for release.
Sampling and Analysis
The inspectors verified liquid effluent sampling includes provisions for sample line flushing,
vessel recirc'!lation. and composite sampling durin~ a release. The inspectors reviewed two
release packages for releases made with monitoring equipment out of service. The
inspectors verified that compensatory sampling was performed consistent with the ODCM.
The inspectors verified Pilgrim is not routinely relying on the use of compensatory sampling
in lieu of adequate system maintenance. Liquid releases are performed on an infrequent
basis. The inspectors reviewed the inter-laboratory comparison program to verify the quality
of the radioactive effluent sample analyses. and that the program included hard-to-detect
isotopes.
Instrumentation and Eguipment
The inspectors reviewed the methodology Pilgrim uses to determine the main stack and
reactor building vent flow rates. The inspectors verified the flow rates used are consistent
with the ODCM values. The inspectors reviewed surveillance test results for the standby gas
treatment and the control room environmental filters system to verify they met Technical
Specification acceptance criteria.
Dose Calculations
The inspectors verified there were no Significant changes in the reported dose values
compared to the previous Radiological Effluent Release Report. The inspectors reviewed
two (2) liquid release permits to verify that projected doses to members of the public are
accurate and based on representative samples. There were no gaseous release packages
to review. The inspectors reviewed the analysis used to determine hard-to-detect
radionuclides. The inspectors verified these radioisotopes were included in the source term.
The inspectors reviewed the changes made for Revision 10 of the ODCM since the last
inspection. The inspectors reviewed the latest Land Use Census and verified that no
Enclosure
.1
15
changes were needed to the dose calculations. The inspectors verified for the release
packages review, the calculated doses were within the 10 CFR Part 50, Appendix I and
Technical Specification dose criteria. The inspectors verified there were no abnormal
releases during this inspection period.
- Groundwater Protection Implementation (GPI) *
The inspectors reviewed the monitoring results of the GPI Initiative to verify Pilgrim has
implemented their program as intended and to identify any anomalous results. The
inspectors verified that no entries were made into the 10 CFR 50.75 (g) file during this
inspection period. The inspectors verified there were no leaks or spills during this inspection
period. The inspectors could not evaluate discharges from onsite surface water bodies
because Pilgrim has no onsite surface water bodies. The inspectors verified that the results
of groundwater monitoring are included in the Annual Radiological Effluent Release Report.
The inspectors noted that Pilgrim has no new discharge paints.
Problem Identification and Resolution
The inspectors reviewed Pilgrim self-assessments, audits, and special reports related to the
radiological effluent treatment system to determine if identified problems were entered into
the corrective action program. The inspectors verified that problems identified were put into
the corrective action program and corrective actions were appropriate.
b.
~indings
\\
No findings were identified.
4.
OTHER ACTIVITIES [OA]
40A1 Performance Indicator (PI) Verification (71151)
Cornerstone: Mitigating Systems
a.
Inspection Scope (3 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, eRs, Licensee Event Reports (LERs), and
NRC inspection reports. The acceptance criteria used for the review was Nuclear Energy
Institute (NEI) 99-02, Revision 6, "Regulatory Assessment Performance Indicator
Guidelines." The documents reviewed during the inspection are listed in the Attachment.
The following performance indicators were reviewed:
High Pressure Injection System from the third quarter of 2009 through the second quarter
of 2010 [MS07];
Heat Removal System from the third quarter of 2009 through the second quarter of 2010
[MS08J; and
- Residual Heat Removal System from the third quarter of 2009 through the second
quarter of 2010 [MS09].
Enclosure
16
b.
Findings
No findings were identified.
..
.2
Cornerstone: Occupational/Public ~adiation Safety
Radiological Effluent Technical Specification (RETS) /Offsite Dose Calculation Manual
(aDeM) Radiological Effluent Occurrences [PR01]
a.
Inspection Scope (1 sample)
The inspectors reviewed relevant effluent release reports for the period January 1, 2009
through December 31, 2009, for issues related to the pubHc radiation safety performance
indicator, which measures radiological effluent release occurrences that exceed 1.5 milli
rem/quarter whole body or 5.0 milli-rem/quarter organ dose for liquid effluents; 5 milli
rads/quarter gamma air dose; 10 milli-rads/quarter beta air dose; and 7.5 milli-rads/quarter
for organ dose for gaseous effluents. This inspection activity represents the completion of
one sample relative to this inspection area; completing the annual inspection requirement.
b.
Findings
No findings were identified.
\\
\\
40A2 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 corrective action
program. This review was accomplished by reviewing printouts of each Condition Report
(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 were identified .
. 2
Annual Sample: Operator Workarounds
a.
Inspection Scope (1 sample)
The inspectors performed the annual review of operator workarounds to verify Entergy was
identifying operator workaround problems at an appropriate threshold and entering them into
the corrective action program. The inspectors reviewed identified workarounds to determine
whether the mitigating system function was affected, whether the operator's ability to
implement abnormal and emergency operating procedures was affected, and whether
Enclosure
.1
17
appropriate procedures had been updated to reflect actual plant conditions. The inspection
was accomplished through personnel interviews, plant tours, and review of station
documents. The documents reviewed during the inspection are listed in the Attachment.
b.
Findings and Observations
No findings were identified. Operator workarounds have been identified and entered into the
corrective action program for resolution. No unrecognized impacts to operator or system
performance were identified, and corrective actions have been implemented to restore the
affected systems.
40A3 Event Foliow-uR (71153)
Release of Hydrogen Gas to the Environment
a.
Inspection Scope (1 sample)
On August 25,2010, Entergy identified an increase in generator hydrogen gas usage
following the return to service of a hydrogen seal oil system vacuum pump. Operators
isolated the vacuum pump and generator hydrogen makeup returned to normal. Operations
reviewed reporting requirements and notified the State of Massachusetts due to the release
of hydrogen gas greater than the reportable quantity of 10 Ibs. (approximately 20 Ibs. was
released). Operations also notified the Nuclear Regulatory Commission Headquarters
Operations Officer. The inspectors reviewed Entergy's actions, procedures, notification
requirements, and applicability of emergency action level guidance.
b.
Findings
No findings were identified .
. 2
o.perator Performance During Main Condenser Backwash
a.
Inspection Scope (1 sample)
The inspectors observed operators perform a backwash on August 1, 2010. Specifically, the
inspectors observed an unplanned plant downpower to 48 percent reactor power to support
the backwash of the main condenser due to fouling. The inspectors reviewed procedural
guidance for station power changes and the power maneuver plan, and observed control
room conduct and control of the evolution. The documents reviewed during this inspection
are listed in the Attachment.
b.
Findings
No findings were identified.
Enclosure
.1
18
40A5 Other Activities
(Closed) Temporary Instruction 2515/173, Review of the Implementation of the Voluntary
Industry Groundwater Protection Initiative (GPI}
..
.
a.
Inspection Scope
During the period July 12,2010, through July 15, 2010, an NRC assessment was performed
of Pilgrim's GPI program to determine whether Pilgrim implemented the voluntary Industry
Groundwater Protection Initiative, dated August 2007 (Nuclear Energy Institute (NEI) 07-07,
ADAMS Accession Numbers ML07261 0036 and ML072600292). The inspectors interviewed
personnel, performed walkdowns of selected areas as needed and reviewed documentation.
GPI Objective 1.1 - Site Hydrology and Geology
The inspectors verified that a hydrology and geologic study was performed by an outside
contractor to determine the predominant groundwater flow characteristics and gradients.
The inspectors verified the study was reviewed by a knowledgeable utility employee. The
inspectors verified that potential pathways have been identified for groundwater migration
from on-site locations to off-site locations through groundwater. The inspectors verified that
a five (5) year frequency has been established in Pilgrim procedures for periodic review of
the hydrogeologie studies. The inspectors verified that no changes were required to the
Updated Firal Safety Analysis ~eport.
GPI Objective 1.2 - Site Risk Assessment
The inspectors verified that Pilgrim has identified structures, systems, and components
(SSCs) that involve or could reasonably be expected to involve licensed material and for
which there is a credible mechanism for licensed material to reach groundwater. The
inspectors verified that the Pilgrim corrective action program will be used to identify and track
corrective actions.
GPI Objective 1.3 - On-Site Groundwater Monitoring
The inspectors verified Pilgrim has considered the placement of monitoring wells down
gradient from the plant but within the site boundary. The inspectors verified that Pilgrim
considered placing sentinel wells closer to structures, systems or components (SSCs) that
have the highest potential for inadvertent releases that could reach groundwater. The
inspectors verified that Pilgrim has established sampling and analysiS protocols, including
analytical sensitivity in site procedures. The inspectors verified that a formal written program
has been established for long term groundwater monitoring. The inspectors verified that the
Offsite Dose Calculation Manual has not been revised to include groundwater monitoring as
the monitoring locations are not included in the Radiological Environmental Monitoring
Program (REMP). The inspectors verified that the analytical capabilities are periodically
reviewed as part of the analytical cross check program. The inspectors verified that a long
term program has been established in Pilgrim procedures for the groundwater monitoring
wells. The inspectors verified a frequency has been established in Pilgrim procedures for the
periodiC review of the groundwater monitoring program.
Enclosure
..
\\
19
GPI Objective 1.4 - Remediation Process
The inspectors verified that written procedures have been established outlining the decision
making process for the remediation of leaks and spills or other instances of inadvertent
releases. The inspectors verified that an evaluation was performed of the potential for
detectible levels of licensed material from plarlhed releases of liquids and/or airborne
materials.
GPI Objective 1.5 - Record Keeping
The inspectors verified that a record keeping program has been established to meet the
requirements of 10 CFR 50.75 (g).
GPI Objective 2.1 - Stakeholder Briefings
The inspectors verified by discussion with Pi/grim staff and review of documentation that
initial briefings have been conducted with designated State and Local officials of the site
specific GPI program. The inspectors verified Pilgrim has considered including additional
information or updates on groundwater protection in the annual reports for the State and
Local officials.
9PI Objective 2.2 - Voluntary Communications
The inspectors verified that Pilgrim procedures ~stablish communication protocols for
communicating leaks and spills to State and Local officials. The inspectors verified that the
ODCM establishes communication protocols for groundwater samples exceeding REMP
reporting criteria.
GPI Objective 2.3 - Thirty Day Reports
The inspectors verified that groundwater samples are analyzed and compared to the
standards and limits contained in the ODeM. The inspectors verified that no thirty day
special reports for groundwater monitoring have been submitted to the Nuclear Regulatory
Commission (NRC).
GPI Objective 2.4 - Annual Reporting
The inspectors verified that appropriate changes have beEm made to appropriate Pilgrim
procedures to support the 2006 performance. The inspectors verified that aI/ groundwater
sample results are included in the Annual Radiological Effluent Release Report (ARERR).
The inspectors verified that no groundwater samples taken as part of the GPI are part of the
REMP program. The inspectors verified that, at the time of this inspection, no water sample
results exceeded REMP reporting thresholds since the implementation of the GPI.
Enclosure
20
GPI Objective 3.1 - Perform a Seff Assessment of the GPI Program
The inspectors verified that an independent individual performed the initial self assessment
of the groundwater program prior to the implementation of the GPI and another self
assessment performed in 2009. The inspectors verified that self assessments are s;>ecified
every five years per Pilgrim procedures. The inspectors verified that the self assessment
included an evaluation of all of the GPI objectives. The inspectors verified the self
assessments are documented in accordance with Pilgrim procedures.
GPI Objective 3.2 - Review the Program Under the Auspices of NEI
The inspectors verified an independent individual performed an initial review after the initial
assessment. The inspector verified that Pilgrim procedures require a periodic review of the
GPI program every five years.
b.
Findings and Assessments
No findings were identified. Implementation of the Industry GPI is VOluntary. Under the final
Initiative, each site was to have developed an effective, technically sound groundwater
protection program by August 2008. The inspectors identified that, at the time of this
inspection, Pilgrim had not taken action on all groundwater initiative objectives (as outlined in
the Temporary Instruction) as follows:
\\
1
GPI Objective 1.2
Pilgrim has identified SSGs that involve or could reasonably be expected to involve licensed
material and for which there is a credible mechanism for licensed material to reach
groundwater. However, Pilgrim has not identified work practices that involve or could
reasonably be expected to involve licensed material and for which there is a credible
mechanism for licensed material to reach groundwater. Pilgrim has not established a relative
risk for the SSGs identified. Pilgrim has not identified existing leak detection methods for
each sse and work practice that involve or could reasonably be expected to involve licensed
material and for which there is a credible mechanism for licensed material to reach
groundwater.
Pilgrim has not identified potential enhancements to leak detection systems or programs.
Pilgrim has not identified potential enhancements to prevent spills or leaks from reaching
groundwater. Pilgrim has a written long term program; however, it has not been formalized.
GPI Objective 1.4
Pilgrim has not documented an evaluation of the decommissioning impacts resulting from
remediation activities or the absence of remediation activities. However, a draft procedure
has been written about the subject.
In the 2007/2008 period, in accordance with the voluntary Groundwater Protection Initiative
(NEI-07-07), Pilgrim installed four monitoring wells (MW-201, 201,203, and 204) that were
located to detect potential radioactive material leakage from underground structures,
systems, and components (SSGs). These wells, and two other existing monitoring wells
(MW-3 and MW-4), were incorporated into Pilgrim's groundwater protection program, and
Enclosure
21
have been sampled on a quarterly basis, The samples are split with the Massachusetts
Department of Public Health (MDPH). These wells have not indicated any condition
perceived as an indicator of leakage from any SSC.
In May 2010, Pilgrim installed six additional groundwater monitoring wells in response to an
independent self-assessment that Entergy conducted relative to Pilgrim's implementation of
the NEI-07-07 objectives. These wells were identified as MW-202(1), 205, 206, 207, 208(S),
and 208(1}. [Note: S and I refer to Shallow and Intermediate depth). On May 16, 2010, the
first sample results for these six wells were reported. All indicated typically expected results,
with the exception of MW-205, which indicated 5,300 picocuries per liter (pCi/l), tritium (H-3).
Subsequent sampling on June 11 indicated 8,600 pCi!l; on June 21 indicated 11,000 pCi/l;
and on June 30 indicated 8,400 pCill. Since that time, sample results from MW-205 have
continued to vary; and the highest concentration measured to-date has been approximately
25,000 pCi/L
Entergy has been keeping the Massachusetts Emergency Management Agency (MEMA) and
the MDPH informed of these conditions, and has issued notifications to the NRC in
accordance with 10 CFR 50.72. The licensee has frequently met with representatives of
MEMA, MDPH, and NRC to discuss its plans and investigation process for determining the
source of the tritium contamination. Additionally, NRC resident inspectors and region-based
inspectors have been closely monitoring the licensee's plans, process, and progress in .
determining the cause and source of the contamination.
The NRC confirmed that Entergy established a technical team dedicated to the resolution of
this matter, and has implemented appropriate and reasonable actions to determine the
source and to resolve the condition. Frequent sampling of existing wells, development of
additional monitoring wells, application of ground penetrating radar surveillance.
implementation of leak detection techniques on suspected underground SSCs that are in the
vicinity of MW-205, and development of additional hydrological data are continuing. NRC
resident inspectors are closely following the licensee's onsite activities, and the licensee is
frequently communicating its plans and progress to NRC and to appropriate representatives
of the State of Massachusetts.
The NRC will continue to follow the licensee's performance closely to assure conformance
with regulatory requirements, and to assure that public health and safety is maintained.
Based on information reviewed to-date, the groundwater condition at Pilgrim has not, nor is
expect to, result in any public health and safety consequence .
. 2
Strike Contingency Plan (92709)
a.
Inspection Scope
Entergy developed a Security Staffing Contingency Plan to ensure a sufficient number of
qualified security officers were available to maintain Pilgrim's security plan in the event that
the United Government Security Officers of America, Local 25 security officers engaged in a
job action upon the expiration of their contract on October 1,2010. Using the guidance
contained in NRC Inspection Procedure 92709, "Licensee Strike Contingency Plans," the
inspectors reviewed Entergy's plans to address a potential job action at the site. The
inspection included an evaluation of the Security Staffing Contingency Plan content and the
Enclosure
22
actions needed to implement the plan, and a review to determine whether the number of
qualified security officers needed for the proper implementation of Pilgrim's Security Plan
would be available.
b.
Findings ..
..
No findings were identified.
40A6 Meetings, Including Exit
On July 15. 2010, the regional inspector conducted a Radiation Safety and closure of TI
2515/173 exit meeting. Bob Smith. Plant General Manager, attended the meeting. At the
exit meeting, the inspectors confirmed that no proprietary information was provided to the
inspectors for the inspection.
On October, 13,2010, the resident inspectors conducted an exit meeting and presented the
preliminary inspection results to Mr. Kevin Bronson, and other members of the Pilgrim staff.
The inspectors confirmed that proprietary information provided or eXamined during the
inspection was controlled and/or returned to Entergy, and the content of this report includes
no proprietary information.
\\
1
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Entergy personnel:
S. Bethay
Director, Nuclear Safety Assurance
R. Bowen
Chemistry Technician
K. Bronson
Site Vice President
G. Dechen
Engineer, Underground Pipes and Tanks
V. Fallacara
Engineering Director
W. Lobo
licensing Engineer
J. Lynch
Licensing Manager
J. Macdonald
Assistant Operations Manager-Shift
T. McElhinney
Chemistry Manager
D. Noyes
Operations Manager
B. Panzarella
Chemistry Technician
J. Priest
Radiation Protection Manager
J. Scheffer
Chemistry Supervisor
K. Sejkora
Staff Chemist
R. Smith
General Manager, Pilgrim Operations
\\
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened and Closed
Failure to Manage a Yellow Risk Condition for an Unplanned
Half Scram (Section 1R13)
Attachment
A-2
LIST OF DOCUMENTS REVIEWED
Section 1 R01
Procedure 2.2.40, Revision 31, Reactor Building Heating, Cooling, and Ventilation System
Procedure 2.1.42, Revision 10, Operation During Severe Weather
..
Master/Local Control Center Procedure No.2 (M/L CC2) Abnormal Conditions Alert, Revision 14
Procedure 2.2.94, Revision 106, Seawater System
Procedure 2.4.149, Revision 10, Loss of Control Room Air Conditioning
Procedure 2.4.153, Revision 19, Loss of Turbine Building/Auxiliary Bay Area Ventilation
Procedure 8.C.40, Section 3, Revision 24, Warm Weather Surveillance
Procedure 2.1.37, Revision 26, Coastal Storm - Preparations and Actions
UFSAR, Section 2.4.4, Storm Flooding Protection
CR-PNP-2010-03006, NRC review of station response to the August 22-24 coast storm identified
that Procedure 2.1.37, Coastal Storm Preparations and Actions, does not direct a
preemptive walkdown of the site
NUREG-0654, Appendix 1, Basis for Emergency Action Levels for Nuclear Power Facilities
Procedure 5.2.2, Revision 31, High Winds (Hurricane)
Pilgrim Station Prep Checklist for Hurricane Earl
Section 1 R04
Procedure 2.2.21, Revision 77, High Pressure Coolant Injection System
Procedure 2.2.22, R}3vision 71, Reactor Core Isolation Cooling System
\\
Procedure .2.2.20, Revision 73, Core Spray
UFSAR Chapter 8.10, Blackout AC power Source
Procedure 2.2.146, Revision 40, Station Blackout Diesel Generator
Drawing M264, P&ID Station Blackout Diesel Generator Set
CR-PNP-2010-3320, SBO Valve has a position of "Factory Set" with no method to verify this
Position in Procedure 2.2.146
Section 1 R05
Procedure 8.B.17.1, Revision 18, Inspection of Fire Door Assemblies
Fire Hazards Analysis Section Fire Area 1.21, Fire Zone 1.21, "AU RBCCW Pumps/Heat
Exchanger Room
Engineering Evaluation No.3, Unprotected Structural Steel in part of wall barriers
Fire Hazards Analysis Section Fire Area 1.10, Fire Zone 1.22, "B" RBCCW Pumps/Heat
Exchanger Room
Exemption Request No. 12, Exemption for Redundant Trains of Equipment Separated by a Three-
Hour Barrier
Fire Hazards Analysis, Fire Zone Data Sheet for Fire Zone 1.1 OA
Procedure 8.B.17.2, Revision 12, Inspection of Fire Damper Assemblies
"Exemptions to Section III.G of Appendix R" Approval Letter dated December 18, 1984
"Correction to Exemption and Safety Evaluation Related to Section III.G of Appendix R" Approval
Letter dated June 1 0, 1985
Procedure 5.5.2, Revision 46, Special Fire Procedure
CR-2010-2945, TIP Room Discrepancies
Attachment
A-3
Fire Hazards Analysis Data Sheets for Fire Area 1.10, Fire Zone 1.4
EN-DC-161, Revision 4, Control of Combustibles
EC 23807, Modify Drain Piping to Facilitate Validating the Integrity of the Main Stack Drain Line
Section 1 R06
CR-PNP-2010-2594, Reactor Building Closed Cooling Water Suction header for both loops show
signs of degradation and associated operability evaluation
Calculation S&SA 60, Revision 0, Flooding due to Emergency Core Cooling System Leakage
Outside Containment
Calculation S&SA 61, Revision 1. Flood Level Calculations
Flood Propagation Pathway Charts
PNPS Probabilistic Safety Assessment IPE, Revision 1, Appendix E, Internal Flooding Analysis
Section 1R07
Generic Letter 89-13, Service Water System Problems Affecting Safety Related Equipment
Work Order (WO) 51674422, Tasks 1-3, "A" RBCCW HX Thermal Performance Test
Procedure 8.5.3.14.1, Revision 4, RBCCW Heat Exchanger Thermal Performance Test
Calculation M-710, Heat Exchanger Thermal Performance Testing
Section 1 R 11
As-Found Testing Scenario SES-171, Revision 1
Emergency Action Levels
Section 1R12
CR-PNP-2008-3736, P208C experienced high vibration and associated functional failure
determination
CR-PNP-2010-2291 , P208C experienced high vibration and was pulled to lock and associated
functional failure determination
Maintenance Rule Basis Document for Salt Service Water System
Procedure EN-DC-205, Revision 2, Maintenance Rule Monitoring
UFSAR Chapter 8.10, Blackout AC Power Source
Procedure 2.2.146, Revision 40, Station Blackout Diesel Generator
Drawing M264. P&ID Station Blackout Diesel Generator Set
Condition Report List for Station Blackout Diesel Generator Issues Documented September 2009
through September 2010
Maintenance Rule Basis Document for Station Blackout Diesel Generator
SBO Diesel Generator System Health Report
SBO CR listing from September 2009 through September 2010
Section 1 R 13
Equipment Out of Service (EOOS) Tool
Risk Profile for week of July 4 - July 11, 2010
Risk Sheet for Medium Trip Risk for July 26.2010
Attachment
A-4
Risk Sheet for High Trip Risk for July 26,2010
CR~PNP~2010-2584, Power Supply EIS 2229~BIL Blown Fuse 5-AF-30B
Work Week Schedules
Scheduler's Evaluation for Pilgrim the week of August 30, 2010
Compensatory"M.easures and Protected Area Sheet
Hurricane Earl Checklist
CR-PNP-2010-3440, Yellow Risk Condition Not Recognized
Section iRiS
CR-PNP-2010~2264. Scram Discharge Volume West Not Drained Alarm coming in the Control
Room and associated Operability Evaluation
CR-PNP-2009-3385, Scram Discharge Volume Level Instrumentation Drifting High
ODMllmplementation Action Plan for LT-302-83D, Drifting Causing False High Level Indication,
Revision 0
Alarm Response Procedure ARP-C905R-61, Revision 24
Procedure 8.M.1-32A.1, Revision 0, Analog Trip System':"" Trip Calibration with Gross Fail Check
Cabinet C2229-B2
CR-PNP-2010-2355, Lack of Board Certified Rated Capacities for Safety Relief Valves
CR-PNP~201 O~2935, HPCI Steam Admission Valve Packing Leak
EN-OP-104, Revision 4, Operability Determination Process
Technical Specification 3.5.C, HPCI System
CR-PNP-201 0-45~4, Reactor Building Closed Cooling Water Suction header for both loops show
Signs of degradation and associated operability evaluation
CR-PNP-2009~3338, RBCCW suction header piping show corrosion is in need of mitigation
CR-PNP-2001-9145, Degraded piping on RBCCW Loop A suction piping
Mechanical Calculations, Evaluation of RBCCW suction header piping calculation M*1036,
Revision 0
CR-PNP-2010-2645, Indications identified on Condensate Transfer Buried Piping
P&ID M209, Revision 67, Condensate and Demineralized Water Storage and Transfer Systems
CST System Safety Function Sheets
Section 1R18
EC 23892, Gag AO-N-98 in the Open Position
CR*PNP-2010-2716, Damper AO-N-98 found with blade not functioning properly
Procedure a.CA, Revision 22, Routine Running of SBGT System
Drawing M294, SBGT System
Technical SpeCification 3.7.B, SBGT System and Control Room High Efficiency Air Filtration
System
Drawing M294, Heating, Venting and Air Conditioning SBGT System Control Diagram
UFSAR, Section 5.3, Secondary Containment System
EN-DC-134, Attachment 9.1, DeSign Verification Checklist
EN*1I*100, Process Applicability Determination for Temporary Modification to Gag AO~N-98 in the
Open Position
UFSAR 5.3, Secondary Containment System
UFSAR 7.18. Reactor Building Isolation and Control System
Control Room Technical Specification Logs
Attachment
A-5
Temporary Modification EC 23807, Modify Drain Piping to Facilitate Validating the Integrity of the
Main Stack Drain Line
10 CFR Part 50.59, Screen for EC 23807
WO 244934, Installation of TMOD EC 23807
P&ID M210. Augmented Off Gas
Calculation C15.0.3381. Revision 3, Leakage Permitted for Secondary Containment
CR-PNP-2010-3285, Total known leakage for secondary containment was miscalculated
Section 1R19
WO 002122652, Task 4, Relay 160-609 Relay Replacement
Procedure 3.M.3-51, Revision 26, Electrical Termination Procedure
WO 00222652, Tasks Postwork Test for 160-609 Replacement
Procedure EN-WM-107, Revision 2, Post Maintenance Testing
Procedure 3.M.3-1, Revision 127, A5/A6 Buses 4kV Protective Relay Calibration/Functional Test
And Annunciator Verification
UFSAR, Section 8.5, Standby AC Power Source
Procedure 3.MA-14.2, Revision 56, Salt Service Water Pumps Routine Maintenance
WO 00242322-01, Rebuild "C" SSW Pump
Equivalent Change EC 0000012107, SSW Pump "C" Bolted Connections
Design Engineering Evaluation Form for WO 242322
WO 002422322-14, Compliance Package
EC 23446, Revision 0, Attachment 1, Recommended Epoxy Injection Procedure
WO 00242332-03, SSW Pump "C" Post Work Testi~g
Procedure 8.5.3.2.1, Revision 22, Salt Service Water Pump Quarterly and Biennial
(Comprehensive) Operability and Valve Operability Tests
WO 00245886-01, TV-3835 Failed Open
EN-MA-125, Revision 6, Troubleshooting Control of Maintenance Activities
CR-2010-2812, EN-MA-125 does not discuss Post Maintenance testing requirements
WO 00235076, Tasks 1 and 3, Replace Electric Fire Pump
Procedure 8.B.15, Revision 44, Functional Tests of Fire Pumps P-135, P-140, and P-181
Procedure 3.MA-14, Revision 37, Rotating Equipment Inspection Assembly and Disassembly
Procedure EN-WM-107, Revision 2, Post Maintenance Testing
Vendor Manual V-0251, Revision 95, Lubrication Manual
EC 23892, Gag AO-N-98 in the Open Position
Procedure 8.C.4, Revision 22, Routine Running of Standby Gas Treatment System
CR-PNP-2010-2716, Damper AO-N-98 found with blade not functioning properly
Technical Specification 3.7.B, Standby Gas Treatment System and Control Room High Efficiency
Air Filtration System
Final Safety Analysis Report, Section 5.3, Secondary Containment System
Final Safety Analysis Report, 7.18, Reactor Building Isolation and Control System
Procedure 8.7.6.2, 34, SGTS Single Train Operability Test
CR-PNP-2010-2789, Post Maintenance not in accordance with Temporary Modification
Requirements
CR-PNP-2010-3073, Coil Mechanism for lockout relay 186 failed to unlatch with a trip Signal
Present
LCO Maintenance Planning Checklist
WO 52219838, Task 1, F15 Switchyard Ground Grid Visual Inspection
Attachment
A-6
WO 52202875, Tasks 1 & 2, Cal & Functional of Breaker 152-801
Procedure 3.M.3-29.1, Revision 7, A8 Bus 4kV Protective Relay Calibration and Functional
Testing
WO 52202876, Task 1, Cal & Functional Test of Breaker 152-802
WO 52220914, Task 1, Shutdown Transformer to A5 & A6 Tie Relays
WO 00~09609, Task 1, Repair Pull Box 1A
..
WO 00164156. Task 1, Replace the SOT Hot Spot Indicator Heater
Section 1 R22
Procedure 8.3.2, Revision 54, Control Rod Exercise
CR-PNP-2010-2389, Procedure is unclear in indication for verifying a coupling check
Procedure 8.5.4.1, Revision 105, HPCI System Pump and
Biennial Comprehensive Operability
WO 52261114, Task 1, Perform 8.5.4.1, P-205 HPCI Operability and Flow Rate Test at 100 psig
WO 52263889 01, Manually start and load Blackout Diesel Generator
Procedures 8.9.16.1, Revision 41, Manually start and load Blackout Diesel via the Shutdown
transformer
CR-PNP-2010-3073, Station Blackout Lockout Relay did not unlatch with a trip signal present
CR-PNP-2010-2253, Hot Water that flashed to a steamy-water mix present when keepfill check
was performed
Procedure 8.5.2.15, Attachment 3, Revision 17, LPCI System and Core Spray System keepfill
c'1ecks
Operabi/it~ Evaluations for CR-PNP-2009-3312 and CR-PNP-2009-3348
\\
Drywell Leakage 7-day Rolling Average Chart
Drywell Leakage Data Sheets
Procedure 2.1.5, Revision 204, Daily Surveillance Log
Daily Log Test #48, Log the Drywell Leakage (flow integrators) on Panel C20
Section 1EP6
NEI 99-02, Revision 6, Regulatory Assessment Performance Indicator Guideline
EN-EP-201, Revision 10, Performance Indicators
EP Performance Indicator Reporting and Information Form dated July 26,2010
Section 2RS06
Procedures:
7.1.132
Obtaining Liquid Samples, Revision 13
7.3.25
Particulate and Iodine Monitoring at the Main Stack and Reactor Building,
Revision 42
7.3.31
Tritium Sampling, Revision 22
7.3.37
Noble Gas Effluent Sampling, Revision 35
7.3.48
Airborne Effluent Monitoring of the Turbine Deck and Reactor Feed Pump Bay,
Revision 17
7.9.12
Liquid Effluent Releases with RETDAS, Revision 5
Attachment
A-7
Condition Reports:
Audits and Assessments:
QA-02/06-2009-PNP-01,
Combined Chemistry, Effluents, and Environmental Monitoring,
September 16, 2009
Ventilation Surveillances
WO 51656607'A' CREFS
August 6, 2008
WO 51677838'8' CREFS
September 24, 2008
WO 51677839'8' S8GT
September 23, 2008
Release Permits
Liquid
2010001
'A'TWT
April 2. 2010
2010005
'8'TWT
April 6, 2010
Section 40A1
MSPI Data Sheets from 3mQuarter 2009 to 2nd Quarter 2010 for HPCIIRCIC
Control Room Logs
HPCIIRCIC Unavailability Data Spread Sheets
NEI 99-02. Revision 6. Regulatory Assessment Performance Indicator Guideline
Licensee Event Reports
NRC Inspection Reports
RHR System Health Report
NRC Performance Indicator Technique/Data Sheets for 3rd Quarter 2009 through 2nd quarter 2010
Section 40A2
Compensatory Actions and Disabled Annunciator Logs
Pilgrim Operator Workarounds Aggregate Impact Report
Pilgrim Operator Compensatory Measures Report
Section 40A3
Reactor Plant Event Notification 46206, Release of Hydrogen Gas to Environment and
Notification to the State of Massachusetts
Procedure 1.3.22, Revision 19, Oil Spill Prevention, Control and CounterMeasure Plan
EP-AD-600, Revision 15, Emergency Action Level Basis Document
NUREG 0654, Appendix 1, Emergency Action Level Guidelines for Nuclear Power Plants
Generator Auxiliaries Reference Text
Power Maneuver Plan
Attachment
A-8
Procedure 2.1.14, Revision 102, Station Power Changes
Procedure 2.2.94,5, Revision 5, Main Condenser Backwash
Section 40A5
Procedures
.
..
Sampling and Analysis of Groundwater Monitoring Wells, Revision 2
Radiological Groundwater Monitoring Program, Revision 0
Condition Reports
CR-PNP-2007 -04048
CR-PNP-20 10-00825
\\
\\
Attachment
A-9
LIST OF ACRONYMS
Annual Radiological Effluent Release Report
As Low As Reasonably Achievable
Agencywide Documents Access and Management System
CFR
CR
Code of Federal Regulations
Condition Report
..
..
Division of Reactor Projects
Division of Reactor Safety
Groundwater Protection Initiative
High Pressure Coolant Injection
Heat Exchanger
IMC
Inspection Manual Chapter
Non-Cited Violation
NEI
Nuclear Energy Institute
NRC
Nuclear Regulatory Commission
Offsite Dose Calculation Manual
Publicly Available Records
Performance Indicator
Pilgrim Nuclear Power Station
Reactor Building Closed Cooling Water
Reactor Core Isolation Cooling
Radiological Environmental Monitoring Program
t
Standby Gas Treatment
Station Blackout
Structure, System or Component
Salt Service Water
TWT
Treated Water Tank
Updated Final Safety Analysis Report
Work Order
Attachment