IR 05000293/2011005

IR 05000293-11-005, on 10/01/2011 - 12/31/2011, Pilgrim Nuclear Power Station, Licensed Operator Requalification Program

ML12033A229
Person / Time
Site:	Pilgrim
Issue date:	02/02/2012
From:	Ronald Bellamy NRC/RGN-I/DRP/PB5
To:	Rich Smith Entergy Nuclear Operations
Bellamy R
References
EA-11-260 IR-11-005
Download: ML12033A229 (53)

Text

SUBJECT:

PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/201 1 005

Dear Mr. Smith:

On December 31,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents tn-e inspection results, which were discussed on January 10,2012, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

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

Based on the results of this inspection, three apparent violations of NRC requirements were identified. The significance of these apparent violations has been designated as To Be Determined (TBD) untilthe final significance characterization has been completed. The apparent violations are associated with the medical examination and license conditions of licensed operators. The plant has taken appropriate immediate corrective actions such that the apparent violations do not represent an immediate safety concern. The final significance of ttidse apparent violations willbe communicated to you in separate, future correspondence.

One NRC identified finding of very low safety significance (Green) was identified during this inspection. This finding did not involve a violation of NRC requirements. Additionally, the NRC has determined that a Severity Level lV violation occurred. Further, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report.

However, because of the very low safety significance, and because they have been entered into your corrective action program, the NRC is treating these violations as non-cited violations (NCVs), consistent with the NRC's Enforcement Policy. lf you contest any NCV in this report, you should provide a written 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 RegionalAdministrator, Region l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at PNPS.

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 NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://r,r.rww.nrc.gov/readino-rm/adams.html (the Public Electronic Reading Room).

Sincerely, Tt*s&Q.,

Docket Nos.:

License Nos.:

Enclosure:

REGION I==

50-293 DPR-35 05000293/201 1005 Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station (PNPS)

600 Rocky Hill Road Plymouth, MA 02360 October 1, 2011 through December 31, 2011 M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP)

B. Smith, Resident Inspector, DRP M. Catts, Senior Resident Inspector, Indian Point Energy Center, Unit 2, (DRP)

K. Mangan, Senior Reactor Inspector, Division of Reactor Safety (DRS)

R. Rolph, Health Physicist, DRS J. Caruso, Senior Operations Engineer, DRS T. Fish, Senior Operations Engineer, DRS J. Tomlinson, Operations Engineer, DRS C. Newport, Operations Engineer, DRS Ronald R. Bellamy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

lR 0500029312011005; 1010112011-121311201 1; Pilgrim Nuclear Power Station; Licensed

Operator Requalification Program.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified three apparent violations (AVs), one Severity Level lV NCV, and one finding of very low safety significance (Green). The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP 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: Mitigating Systems

. TBD. The inspectors identified an apparent violation (AV) of Title 10 of the Code of Federal Regulations (10 CFR) 55.53 and 10 CFR 55.21 related to Entergy's medical examinations of licensed operators. Specifically, at various times over a period of almost four years, ten operators did not meet certain medical requirements (for stamina and/or blood pressure) for performing NRC-licensed operator activities, and the operators continued to perform NRC-licensed activities. Additionally, Entergy did not perform complete medical testing of its licensed operators, in that five of those licensed operators had not been administered stamina tests for more than two years and therefore did not complete their NRC-required biennial medical exam. lmmediately after the NRC identified the issue, Entergy restricted operators from watch until they could pass the requirements of their medical testing. Entergy entered this issue into their corrective action program (CR-PNP-201 1 -04554).

The inspectors determined that Entergy's failure to ensure that licensed operators met the license conditions associated with medical testing prior to performing license activities was a performance deficiency that was within Entergy's ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC's ability to perform its regulatory function because the NRC relies upon the accurate certification by the licensee's medical examiner to ensure all licensed operators meet the medical conditions of their license. Specifically, ten operators had not taken the stamina test during their annual physical, but were certified by the medical examiner and licensee as being fit to safely perform their watch-standing duties. Additionally, five of those operators had not taken the stamina test during their biennial physical, but were certified by the medical examiner and licensee as being fit to safely perform their watch-standing duties. Lastly, an individual who had not passed their blood pressure examination, and required a license condition to take medication, was placed back on watch-standing duty without such a license condition. The performance deficiency was screened against the Reactor Oversight Process (ROP) per the guidance of lnspection Manual Chapter (lMC)0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-cutting aspect was assigned. These issues are being characterized as an apparent violation in accordance with the NRC's Enforcement Policy, and its final significance will be dispositioned in separate future correspondence. (Section 1R1 1)

TBD. The inspectors identified an AV of 10 CFR 50.9, "Completeness and Accuracy of Information," related to Entergy's medical examinations of licensed operators.

Specifically, Entergy did not provide information to the NRC that was complete and accurate in all material respects, in that Entergy submitted two NRC licensed operator renewal applications which certified that the applicants met the medical requirements for license renewal when in fact they did not complete the required stamina tests. Entergy entered this issue into their corrective action program (CR-PNP-2011-04554).

The inspectors determined that Entergy's failure to provide complete and accurate information to the NRC was a performance deficiency that was within Entergy's ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC's ability to perform its regulatory function. Specifically, Entergy did not provide information to the NRC that was complete and accurate in all material respects, in that although Entergy had not administered complete medical examinations of licensed operators in accordance with American National Standards Institute/American Nuclear Society (ANSI/ANS)3.4-1983 (because it had not conducted stamina testing), it submitted two NRC Form-396s for renewal of operator licenses which certified that the applicants met the medical requirements of ANSI/ANS 3.4-1983, Subsequently, the NRC made a licensing decision based on this information that was not complete and accurate in all material respects. The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-cutting aspect was assigned. This issue constitutes an apparent violation in accordance with the NRC's Enforcement Policy, and its final significance will be dispositioned in separate future correspondence. (Section 1R1 1)

TBD. The inspectors identified an AV of 10 CFR 50.74, "Notification of Change in Operator or Senior Operator Status." Specifically, Entergy did not notify the NRC within 30 days of discovering a change in medical condition for two licensed operators.

Subsequently, Entergy submitted notifications for both operators on November 10, 2Q11, and entered the issue into their corrective action program (CR-PNP-2011-04554).

The inspectors determined that Entergy's failure to notify the NRC within 30 days of discovering the change in medical condition for two licensed operators was a performance deficiency that was within Entergy's ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC's ability to perform its regulatory function because if a licensed operator has a change in medical condition, the NRC may need to perform a review for consideration of a licensing action. Specifically,

Entergy had not notified the NRC within 30 days of learning of a change in medical condition for two licensed operators for which a license condition was required. The performance deficiency was screened against the ROP per the guidance of IMC 0612,

Appendix BProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0612,</br></br>Appendix B" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., "lssue Screening." No associated ROP finding was identified and no cross-cutting aspect was assigned, This issue constitutes an apparent violation in accordance with the NRC's Enforcement Policy, and its final significance will be dispositioned in separate future correspondence. (Section 1 R1 1 )

SL-IV. The inspectors identified a Severity Level lV NCV of 10 CFR 55.53 (e) and (f),

"Conditions of Licenses," because Entergy incorrectly credited two individuals for proficiency watch-standing experience and then these operators subsequently stood watch without meeting the minimum proficiency requirements necessary to maintain an active license. Entergy implemented immediate corrective action that included discontinuing the practice of crediting the emergency core cooling system (ECCS) and Extra Balance of Plant (BOP) positions for proficiency. Entergy entered this issue into their corrective action program (CR-PNP-201 1-04649).

The inspectors determined that Entergy incorrectly credited two individuals for proficiency watch-standing experience and then these operators subsequently stood watch in the control room. This error constitutes a performance deficiency that was within Entergy's ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC's ability to perform its regulatory function because if a licensed operator fails to meet the conditions of their license, the NRC may need to perform a review for consideration of a licensing action, and if the information regarding an individual's qualifications is not accurately presented, the NRC could potentially make an incorrect licensing decision based on the inaccurate information. Specifically,

Entergy did not ensure that two reactor operator (RO) licensed individuals maintained their RO licenses in an active status in the 2nd quarter 2011, prior to standing RO watches in the 3rd quarter 201 1 which violated a license condition as specified in 10 CFR 55.53 (e) and (f). The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-cutting aspect was assigned. This issue is similar to violation example 6.4.c.1(c) in the NRC Enforcement Policy for a Severity Level lll violation because it involves noncompliance with a condition stated on an individual's license. However, since there were no adverse impacts to nuclear safety, the NRC has determined that this issue constitutes a Severity Level lV NCV in accordance with the NRC's Enforcement Policy. (Section 1R1 1)

.

Green.

The inspectors identified a Green finding of 10 CFR 55.59, "Requalification," based on a determination that greater than 20 percent of the biennial requalification written exam questions administered to licensed operators during weeks three and four of the 2010 examination cycle were unacceptable. Entergy entered this issue into the corrective action program (CR-PNP-201 1 -04561 ).

The inspectors determined that the finding was more than minor because it was associated with the Human Performance attribute of the Mitigation Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the finding affected the quality and level of difficulty of biennial written exams which potentially impacted Entergy's ability to appropriately evaluate licensed operators. The risk importance of this issue was evaluated using IMC 0609, Appendix l, "Licensed Operator Requalification Significance Determination Process (SDP)." Appendix I was entered using the number of written exam questions that did not meet the qualitative standard for the written exam questions.

The qualitative standard used by the inspectors is defined in NUREG-1021, Rev. 9, ES-602, Attachment 1, "Guidelines for Developing Open-Reference Examinations," and Appendix B, "Written Examination Guidelines." Since 28.6 percent of the questions reviewed did not meet the guidance, Block 16 of Appendix I applied, specifically, "Were more than 20 percent of the written questions sampled by the inspectors unacceptable?"

Based on this screening criteria, the finding was characterized by the SDP as having very low safety significance (greater than 20 percent unacceptable), or

Green.

A review of the cross-cutting aspects was performed and no cross-cutting aspect was identified that would be considered a contributor to the cause of the finding. (Section 1R1 1)

Other Findings

A violation of very low safety significance, which was identified by Entergy, has been reviewed by the inspectors. Corrective actions taken or planned by Entergy have been entered into their corrective action program. The violation and corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

Summarv of Plant Status Pilgrim Nuclear Power Station began the inspection period operating at 100 percent reactor power. On October 14,2Q11, operators reduced reactor power to 71 percent to perform scram time testing on Control Rod 14-43. Pilgrim returned to 100 percent reactor power later that same day. On November 17, operators reduced reactor power to 50 percent to perform a thermal backwash on the main condenser. During the thermal backwash, a leak on the 'B' feedwater discharge check valve was identified. Operators shut down the plant to conduct a forced outage to repair this containment isolation valve. On November 26, operators returned to 100 percent reactor power. On November 27, operators reduced reactor power to 65 percent power to perform a control rod pattern adjustment and returned to 100 percent reactor power later that same day. On December 26, operators shut down the plant to conduct a forced outage and repair a leaking Safety Relief Valve. On December 31, reactor power returned to 100 percent, then was reduced to 65 percent to perform a control rod pattern adjustment, and then returned to 100 percent reactor power on January 1,2012.

1. REACTORSAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Seasonal Extreme Weather Conditions Inspection Scope The inspectors performed a review of Pilgrim's readiness for the onset of seasonal cold weather and temperatures during the week of October 31,2011. The review focused on the station Blackout Diesel Generator, condensate storage tank, and Technical Support Center Emergency Diesel Generator. The inspectors reviewed station procedures, including Pilgrim's seasonalweather preparation procedure and applicable operating procedures to verify that selected steps had been completed. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions.

Documents reviewed for each section of this inspection report are listed in the

.

Findinqs No findings were identified.

a.

b.

==1R04 EquipmentAliqnment Partial Svstem Walkdowns (71111.04Q - 3 samples)

a. Inspection Scope

==

The inspectors performed partial walkdowns of the following systems:

. 'B' Emergency Diesel Generator (EDG) following 2,4, and 8 year preventative maintenance

. High Pressure Coolant Injection System during 'B' EDG Outage

. Salt Service Water System during Intake Canal Dredging The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance or their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify that system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.

The inspectors also reviewed whether Entergy had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate sig n ificance characterization.

b. Findinqs No findings were identified.

==1R05 Fire Protection Resident Inspector Quarterlv Walkdowns (71111.05Q - 5 samples)

a. Inspection Scope

==

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Entergy controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection identification and suppression equipment was available for use as specified in the area pre-fire plan, and that passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

r Fire Area 1

.21, Fire Zone 1.21,'A' Reactor Building Closed Cooling Water (RBCCW)

Pumps/Heat Exchanger Room o Fire Area 1.10, Fire Zone 1.22,'B' RBCCW Pumps/Heat Exchanger Room I

. Fire Area 1.10, Fire Zone 1.3, High Pressure Coolant Injection Pump/Turbine Room

.

Fire Area 1.10, Fire Zone 1.7, Reactor Core lsolation Cooling Quadrant Mezzanine

.

Fire Area 1.10, Fire Zone 1.304, Torus Compartment b. Findinqs No findings were identified.

1R1 1 Licensed Operator Requalification Prooram (71111.11)

.1 Requalification Review bv Resident Inspectors (71111.1 1Q - 1 sample)

a. lnspection Scope The inspectors observed licensed operator simulator training on November 16, 2011,

which included a Recirculation Loop Seal Failure, Anticipated Transient Without Scram combined with a Loss of Offsite Power scenario. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures.

The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the Control Room Supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the Shift Manager and the technical specification action statements identified by the Shift Control Room Engineer. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems. Finally, 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.

b. Findinqs No findings were identified.

.2 Biennial Review bv Reqignal Specialists (71111.1 1B - 1 sample)

a. Inspection Scope

The following inspection activities were performed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, NRC inspection procedure Attachment71111.1 1, "Licensed Operator Requalification Program," Appendix A, "Checklist for Evaluating Facility Testing Material," and Appendix B, "Suggested Interview Topics."

A review was conducted of recent operating history documentation found in inspection reports, licensee event reports, the licensee's corrective action program, and the most recent NRC plant issues matrix (PlM), The inspectors also reviewed specific events from the licensee's corrective action program which indicated possible training deficiencies, to verify that they had been appropriately addressed. The senior resident inspector was also consulted for insights regarding licensed operators' performance.

The inspectors reviewed two comprehensive written exams administered during weeks three and four of the 2010 exam cycle, six simulator scenarios, and ten job performance measures, which comprised the test items administered or planned for administration the weeks of September 26,2011, and October 3, 2011, to ensure the quality of these exams met or exceeded the criteria established in the Examination Standards and 10 CFR 55.59. The inspectors observed the administration of the operating exams to one crew during the onsite inspection week, which began October 4,2011.

On November 9, 2011, the results of the annual operating tests for year 2011 were reviewed to determine if pass/fail rates were consistent with the guidance of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors,"

Revision 9, Supplement 1, and NRC IMC 0609, Appendix l, "Operator Requalification Human Performance Significance Determination Process (SDP)." The review verified the following:

o Crew pass rates were greater than 80 percent. (Pass rate was 100 percent)r Individual pass rates on the dynamic simulator test were greater than 80 percent.

(Pass rate was 96.5 percent)r lndividual pass rates on the job performance measures of the operating exam were greater than 80 percent. (Pass rate was 100 percent)o lndividual pass rates on the written exam were greater than 80 percent. (N/A for this year)

. More than 75 percent of the individuals passed all portions of the exam.

(96.5 percent of the individuals passed all portions of the examination)

Observations were made of the dynamic simulator exams and job performance measures (JPM) administered during the week of October 3,2011. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of five JPMs.

The remediation plans for two individual simulator failures and two JPM exams that needed improvement were reviewed to assess the effectiveness of the remedial training.

Operators, instructors and training/operation's management were interviewed for feedback on their training program and the quality of training received. Simulator performance and fidelity were reviewed for conformance to the reference plant control room.

A sample of records for requalification training attendance, program feedback, reporting, license reactivation, proficiency watch-standing experience, and medical examinations were reviewed for compliance with license conditions, including NRC regulations. The documents reviewed are listed in the Attachment.

b.

.1 Findinqs

lntroduction: The inspectors identified an apparent violation (AV) of Title 10 of the Code of Federal Regulations (10 CFR) 55.53 and 10 CFR 55.21 related to Entergy's medical examinations of licensed operators. Specifically, at various times over a period of almost four years, ten operators did not meet certain medical requirements (for stamina and/or blood pressure) for performing NRC-licensed operator activities, and the operators continued to perform NRC-licensed activities. Additionally, Entergy did not perform complete medical testing of its licensed operators, in that five of those licensed operators had not been administered stamina tests for more than two years and therefore did not complete their NRC-required biennial medical exam. lmmediately after the NRC identified the issue, Entergy restricted operators from watch until they could pass the requirements of their medical testing.

Description:

As part of the biennial Licensed Operator Requalification Training (LORT)program inspection, the inspectors reviewed a sample of Pilgrim's licensed operator medical records. The NRC's requirements related to the conduct and documentation of medical examinations for operators are contained in Subpart C, Medical Requirements, of 10 CFR Part 55, "Operators' Licenses." Specifically, 10 CFR 55.21, "Medical Examination," requires every operator be examined by a physician when he or she first applies for a license and every two years, thereafter, once the license is received. The physician is to verify that the operator's medical condition and general health will not adversely affect the performance of assigned operator duties or cause operational errors that endanger public health and safety, as stated in 10 CFR 55.33(a)(1). Additionally, 10 CFR 55.53, "Conditions of Licenses," states that each license contains and is subject to certain conditions whether stated in the license or not, One of these conditions, 10 CFR 55.53 (i), requires the licensee to have a biennial medical examination.

The licensee must also certify which industry standard (i.e,, the 1983 or 1996 version of ANSI/ANS 3.4, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants," or other NRC-approved method) was used in making the fitness determination. The inspectors determined that Entergy had stated on NRC Form 396 that the 1983 industry standard was used for the completion of the medical examination. The inspectors noted that the following ANSI/ANS sections apply:

Section 5.1, states in part, "...Consequently, any physical condition...that restricts mobility of the individual or precludes wearing of protective clothing and equipment is a liability to safe operation...;"

Section 5.2.1, "Capacity," states in part, "The examinee shall demonstrate stability and capacityforall of thefollowing: (3)...,stamina,...range of motion...;"

Section 5.3, "Disqualifying Conditions," states in part, "A history or other indication of any disqualifying condition shall be considered disqualifying unless adequate supplementalfindings demonstrate that no disqualifying condition exists...;"

Section 5.4.6, "Respiratory," states in part, "Capacity and reserve to perform strenuous physical exertion in emergencies...;"

Section 5.4.7, "Cardiovascular," states in part, "... tolerance to postural changes and capacity for exertion during emergencies...;"

Section 5.4.7 also establishes 160/100 mm Hg as the upper limit for blood pressure; and Section 6, "Waiver or Specifically Limited Approval," states in part, "...the designated medical examiner may recommend waiver of that portion of the Standard. lt is the examinee's responsibility to supply additional information necessary for consideration of the granting of such a waiver. Documentation supporting the waiver shall include:

(1) Medical history and results of physical exam and other pertinent medical findings;

(2) Specific statements by the medical examiner as to the individual's capacity and the potential effects of any medical impairment on the individual's ability to perform nuclear reactor operator duties;

(3) Description by the facility operator of specific practical tests and demonstrations of ability to perform these duties..;

(4) Certification from the designated medical examiner and facility operator indicating that the individual can safely perform his assigned duties,"

In addition, the inspectors noted that the following sections of Entergy procedure EN-NS-1 12, "Medical Program," apply:

Section 4.5, "The Medical Examiner or designee is responsible for," states in part,

'...[4] Ensuring the appropriate personnel are notified if a worker fails to meet the requirements of the medical examination;..."

Section 4.7, "Supervisors of Licensed Nuclear Operators or designee is responsible for," states in part, "...[3] Notifying medicalservices personnelof any physicalor mental condition that may limit the performance of Licensed Nuclear Operators;"

Section 5.6[5], 'NRC Licensed Nuclear Operator Physical," states in part, "

examination shall consist of:...Stamina assessment:"

Section 5.6[5] "Minimum Qualifying Criteria," states in part, "...The examining physician shall report...untreated hypertension (over 160/100 mm Hg)...;"

Section 5.6[5], "Disqualifying Conditions," states in part, "...Temporary disabilities incurred during the term of an Operator's License do not require NRC notification as long as the operator is not assigned licensed operator duties during the period of disability;" and Section 5.6151(k) states, "lndividuals qualified for licensed operator duties must notify the plant Medical Examiner or nurse of any change in their physical or mental condition. The Medical Examiner will evaluate the individual's condition to determine if it adversely affects his/her ability to perform licensed duties. lf the individual fails the plant nurse shall make verbal notification with written follow-up to the individual;"

The inspectors identified that at various times from March 2008 through October 1 1, 2011, ten operators did not complete a stamina assessment as part of their medical exams. Both ANSI/ANS 3.4-1983 and Entergy procedure EN-NS-112 require a stamina assessment be completed as part of the licensed operator medical examination which is a condition of the license for performing NRC-licensed operator activities. The inspectors reviewed the operators' medical Synopsis, and noted the facility medical officer had decided not to administer and deferred the stamina test for varying reasons, For example, ten operators had not taken the test due to pain associated with hip replacement; pain associated with spinalfusion; pain associated with knee replacement; knee pain; a torn meniscus; and high blood pressure. The stamina tests were deferred, in some cases for multiple years, due to the various disabilities reported at the time of their medical exams. Also, in December 2010, medical exam results for one of these ten operators indicated blood pressure results which exceeded the limit established in ANSl/ANS 3.4-1983.

The inspectors noted from a review of the medical records that apparently these ten operators were not reporting their disabilities at the time of injury or incapacitation as required, but instead waited to disclose their conditions until the administration of their medical exams. These disabilities restricted their mobility and/or stability to carry out operator responsibilities in an emergency situation such as safe shutdown outside the control room. ANSI/ANS 3.4-1983 states that any physical condition that restricts mobility of the individual is a liability to safe operation. These operators should have been restricted from license duty and in the case of a more permanent disability their licenses should have included a permanent restriction such as a license condition which would have prevented them from standing watch by themselves ("no-solo" condition).

The Pilgrim Medical Examiner did not document any basis for deferment of the required stamina testing at the time of the medical examination as required by ANSI/ANS 3.4-1 983.

The inspectors noted that following the NRC inspection, the Medical Examiner added a "Memo to File" to each of the affected individual's medical records which documented the bases for medically clearing these individuals which in some cases had been deferred multiple times over a period of almost four years. The NRC's medical doctor independently reviewed a sample of six of the ten medical records and the associated memos to file and concluded that this approach with respect to stamina testing did not satisfy the ANSI/ANS standard. Although some of these individuals may have possessed aerobic stamina, it appears that the reported temporary disabilities and associated pain (i.e., that precluded them from passing a stamina test at the time) would have severely impaired their mobility, range of motion, and/or physical stability to carry out operator responsibilities in an emergency situation such as safe shutdown outside the control room as required by the ANSI/ANS standard. In all instances, these ten operators continued to perform NRC-licensed activities even though they had not met the minimum requirements for completing licensed operator medical examination which was a condition of their license.

Additionally, the inspectors identified that Entergy did not perform complete biennial medical testing of its licensed operators; in that, between March 2008 and October 2Q11, five of those licensed operators had not been administered stamina tests for more than two years and therefore did not complete their NRC-required biennial medical exam.

ANSI/ANS 3.4-1983, section 5.2.1 and Entergy procedure EN-NS-1 12, section 5.6t51 require the stamina test to be completed as part of satisfactorily completing the biennial medical exam. The medical reasons given for not administering the test included pain due to hip replacement; pain associated with spinal fusion; knee pain; and high blood pressure.

Analvsis: The inspectors determined that Entergy's failure to ensure that licensed operators met the license conditions associated with medical testing prior to performing license activities was a performance deficiency that was within Entergy's ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC's ability to perform its regulatory function because the NRC relies upon the accurate certification by the licensee's medical examiner to ensure all licensed operators meet the medical conditions of their license. Specifically, ten operators had not taken the stamina test during their annual physical, but were certified by the medical examiner and licensee as being fit to safely perform their watch-standing duties. Additionally, five of those operators had not taken the stamina test during their biennial physical, but were certified by the medical examiner and licensee as being fit to safely perform their watch-standing duties. Lastly, an individualwho had not passed the blood pressure examination, and required a license condition to take medication, was placed back on watch-standing duty without such a license condition. The performance deficiency was screened against the Reactor Oversight Process (ROP) per the guidance of Inspection Manual Chapter (lMC)0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-cutting aspect was assigned.

Enforcement:

10 CFR 55.53, requires, in part, that each license contains and is subject to the following conditions whether stated in the license or not...(i) the licensee shall have a biennial medical examination....(l) the licensee shall comply with any other conditions that the Commission may impose to protect health or to minimize danger to health and property.

10 CFR 55.21 requires, in part, that a licensee shall have a medical examination by a physician every two years. The physician shall determine that the licensee meets the requirements of 55.33(aX1 ).

10 CFR 55.33(a)(1) states that the applicant's medical condition and general health will not adversely affect the performance of operator job duties or cause operational errors endangering public health and safety. The Commission will base its finding upon the certification by the facility licensee as detailed in 10 CFR 55.23.

10 CFR 55.23 requires, in part, that to certify the medical fitness of the applicant, an authorized representative of the facility licensee shall complete and sign NRC Form 396, "Certification of Medical Examination by Facility Licensee."

The NRC Form 396, after being signed by an authorized representative of the facility licensee, demonstrates the medical fitness of the licensee and that the guidance contained in ANSI/ANS 3.4-1983, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants," was followed in conducting the examination and making the determination of medical qualification.

Contrary to the above, at various times from March 2008 through October 2011, Entergy failed to ensure that licensed operators standing watch were medically qualified in accordance with ANSI/ANS 3.4-1983. Specifically, the portion of the annual medical examinations involving a stamina assessment was not administered to ten operators, and five of those licensed operators had not been administered stamina tests for over two years (one operator had not taken a stamina test for over three years). In addition, one operator did not pass the required blood pressure test but was determined to be medically qualified to stand watch, and did so, without any license condition.

lmmediately after the NRC identified the issues, Entergy restricted operators from watch until they could pass the requirements of their medical testing. Regarding the individual for whom a condition was required for blood pressure medication, Entergy requested the license amendment and the license has been appropriately conditioned. Entergy entered the issues into their corrective action program (CR-PNP-2O11-04554). These issues are being characterized as an apparent violation in accordance with the NRC's Enforcement Policy, and its final significance will be dispositioned in separate future correspondence. (AV 0500029312011 005-01, Licensed Operators Stood Watch Without Being Medically Qualified)

.2 lntroduction: The inspectors identified an AV of 10 CFR 50.9, "Completeness and

Accuracy of Information," related to Entergy's medical examinations of licensed operators. Specifically, Entergy did not provide information to the NRC that was complete and accurate in all material respects, in that Entergy submitted two NRC licensed operator renewal applications which certified that the applicants met the medical requirements for license renewal when in fact they did not complete the required stamina tests.

Description:

As part of the biennial LORT program inspection, the inspectors reviewed a sample of licensed operator medical records. The inspectors identified that Entergy provided information to the NRC that was not complete and accurate in all material respects, in that Entergy submitted two NRC licensed operator renewal applications which certified that the applicants met the medical requirements for license renewal when in fact they did not.

The ANSI/ANS 3.4-1983, section 5.2.1, and Entergy procedure EN-NS-112, section 5.6[5] require a stamina test to be completed as part of satisfactorily completing the biennial medical exam. Entergy submitted two NRC Form-396s for renewal of operator licenses which certified that the applicants met the medical requirements of ANSI/ANS 3.4-1983. This form, when signed by an authorized representative of the facility licensee, certifies that a physician conducted a medical examination of the applicant as required in 10 CFR 55.21, and that the guidance contained in ANSI/ANS 3.4-1983 was followed in conducting the examination and making the determination of medical qualification. The inspectors noted NRC Form 396 was signed by a senior licensee representative, verifying the examination had been performed.

The NRC issued one individual a license renewal on June 23, 2011, but at the time of renewal the individual had not completed the NRC-required biennial medical exam because stamina testing had been deferred by the Pilgrim Medical Examiner for at least two years (i.e., individual was deferred in January 2010 and again in January 201 1 which was the end of the two year period for the physical). Another individual was also issued an NRC license renewal on June 23,2011, but at the time of renewal the individual had not completed the NRC-required biennial medical exam because stamina testing had again been deferred by the Pilgrim Medical Examiner for over two years (i.e.,

individual was deferred in March 2008, February 2009, February 2010, and in January 2011).

Analvsis: The inspectors determined that Entergy's failure to provide complete and accurate information to the NRC was a performance deficiency that was within Entergy's ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC's ability to perform its regulatory function, Specifically, Entergy did not provide information to the NRC that was complete and accurate in all material respects, in that although Entergy had not administered complete medical examinations of licensed operators in accordance with ANSI/ANS 3.4-1983 (because it had not conducted stamina testing), it submitted two NRC Form-396s for renewal of operator licenses which certified that the applicants met the medical requirements of ANSI/ANS 3.4-1983.

Subsequently, the NRC made a licensing decision based on this information that was not complete and accurate in all material respects. The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-cutting aspect was assigned.

Enforcement:

10 CFR 50.9 requires, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects.

Contrary to the above, Entergy submitted two NRC licensed operator renewal applications which certified that the applicants met the medical requirements for license renewal when in fact they did not, in violation of 10 CFR 50.9. Entergy entered this issue into their corrective action program (CR-PNP-2011-04554). This issue constitutes an apparent violation in accordance with the NRC's Enforcement Policy, and its final significance will be dispositioned in separate future correspondence, (AV 0500029312011005-02, Entergy Did Not Provide Complete and Accurate Medical Information for Licensed Operator Renewal Applications)

.3 fntroduction: The inspectors identified an AV of 10 CFR 50.74, "Notification of Change

in Operator or Senior Operator Status." Specifically, Entergy did not notify the NRC within 30 days of discovering a change in medical condition for two licensed operators.

Description:

As part of the biennial LORT program inspection, the inspectors reviewed a sample of licensed operator medical records. The inspectors identified that Entergy had not notified the NRC within 30 days of learning of a change in medical condition for two licensed operators for which a license condition was required by 10 CFR 50.74. In addition, the inspectors noted facility staff also failed to adhere to the requirements of EN-NS-112, "Medical Program," Section 5.6, related to, "Changes in medical condition or medication use." Paragraph(c), states in part, "lf the change in medical condition/medication is determined to be chronic or maintenance then notification shall be made to the NRC within 30 days of identification..."

ln December 2Q10 and in August 2010 respectively, Pilgrim medical staff became aware of medical conditions that caused two licensed operators to fail to meet the requirements of 10 CFR 55.21 and for which license conditions were required. Specifically, for the first example, the inspectors identified that a licensed operator informed the Pilgrim medical officer during the physical examination in December 2010 that he/she had been put on hypertension medication. For the second example, Entergy staff, during their October 2011 extent of condition review of medical records, identified that vision test results documented on an operator's August 2010 medical exam warranted NRC notification due to a change in the operator's vision (the operator needed corrective lenses). Pilgrim staff did not notify the NRC of these medical changes until November 10, 2011, a period greater than 30 days.

Analvsis: The inspectors determined that Entergy's failure to notify the NRC within 30 days of discovering the change in medical condition for two licensed operators was a performance deficiency that was within Entergy's ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC's ability to perform its regulatory function because if a licensed operator has a change in medical condition, the NRC may need to perform a review for consideration of a licensing action. Specifically, Entergy had not notified the NRC within 30 days of learning of a change in medical condition for two licensed operators for which a license condition was required. The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-cutting aspect was assigned.

Enforcement:

10 CFR 50.74 requires, in part, "Each licensee shall notify the Commission in accordance with 50.4 within 30 days of the following in regard to licensed operator or senior operator:,..(c) Permanent disability or illness.,." Contrary to the above, in December 2010 and in August 2010, Entergy did not notify the NRC within 30 days of learning of a change in medical condition for two licensed operators for which a license condition was required. Specifically, Pilgrim medical staff became aware of medical conditions that caused two licensed operators to failto meet the requirements of 10 CFR 55.21 and for which license conditions were required, but the staff did not notify the NRC of these medical changes until November 10, 2011, a period greater than 30 days. As a result of the inspection, Entergy entered this issue into their corrective action program (CR-PNP-2011-04554), and submitted requests for license amendments.

This issue constitutes an apparent violation in accordance with the NRC's Enforcement Policy, and its final significance will be dispositioned in separate future correspondence.

(AV 0500029312011005-03, Entergy Did Not Notify the NRC Within 30 Days of Discovering Changes in Medical Gonditions)

===.4 lntroduction: The inspectors identified a Severity Level lV NCV of 10 CFR 55,53

(e) and===

(f), "Conditions of Licenses," because Entergy incorrectly credited two individuals for proficiency watch-standing experience and then these operators subsequently stood watch without meeting the minimum proficiency requirements necessary to maintain an active license.

Description:

As part of the biennial LORT program inspection, the inspectors evaluated Pilgrim watch standing records for time on shift. The NRC's regulations related to the proficiency requirements for NRC licensed personnel are contained in 10 CFR 55.53, "Conditions of Licenses." Specifically, Section 55.53(e) requires, in part, that to maintain an active status, the licensee shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter. For licensed operators that do not fulfill these requirements, Paragraph

(f) of 10 CFR 55.53 states, in part, that prior to resumption of functions authorized by a license, the facility licensee shall certify that the individual license holder has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individualwill be assigned.

Procedure No. 1.3.34, "Operations Administrative Policies and Processes," Revision 121, Section 6.4, states that in order for a licensed RO to receive credit for a shift, the license holder must stand seven "complete" 8-hour shifts or five "complete" 12-hour shifts per quarter and shall be logged as filling one (or more) of the following RO positions for the shift claimed:

(a) Operator-at-the Controls,

(b) Balance of Plant (BOP),or

(c) Emergency Core Cooling System (ECCS), Contrary to this guidance, during the 2no quarter of 2011, the inspectors identified that one licensed RO stood one of five required proficiency watches and a second licensed RO stood two of five required proficiency watches as the "Extra BOP" which is not one of the three credited shift crew positions. These watches were incorrectly credited towards meeting their minimum required quarterly proficiency requirements. The inspectors also determined that one of the licensed operators incorrectly took credit for two complete 12-hour watches when the watch-stander did not stand a complete watch in the control room. Specifically, over the course of two credited 12-hour watches, the individual was present in the control room for approximately 8 and 8.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> on April 27,2011, and on May 1,2011, respectively, These watches did not represent l'complete" watches as defined in Pilgrim procedure 1.3.34.

NUREG 1021, Revision 9, Supplement 1, Section ES-605, states that watch standing proficiency credit may also be appropriate for certain licensed RO or Senior Reactor Operator (SRO) shift crew positions that are in excess of those required by a facility's Technical Specifications (TS) if the licensee has in place administrative controls that (1)list the title, description of duties, and indication of which positions are required by TSs and

(2) for shift crew positions in excess of TS, a description of how the position is meaningfully and fully engaged in the functions and duties of the analogous minimum licensed position(s) required by TS (Note: this same guidance was sent out to the industry in NRC Regulatory lssue Summary 2007-29, "Clarified Guidance for Licensed Operator Watch-Standing Proficiency," December 27,20Q7). In addition, TS Amendment223, Section 5.2.2 states, in part, that at least one licensed RO shall be present in the control room when fuel is in the reactor, and at least two licensed ROs shall be present in the control room during reactor startups, scheduled reactor shutdown, and during recovery from reactor trips. During the period of time in question, Pilgrim was in a refueling outage requiring only one licensed RO to be present in the control room.

The inspectors determined that the activities assigned to these two operators as the third (Extra BOP) operator during the periods in question (i.e., April 27-May 19, 2011) did not meet the guidance established in ES-605, "meaningfully and fully engaged in the function and duties of the analogous minimum licensed position required by technical specifications" for the following reasons: 1) The operators were not fully engaged in the function and duties of the analogous minimum licensed position required by TS, in fact they were assigned as a third (Extra BOP) on shift during a period when TS required only one RO to be present at the controls; 2) the operators were not assigned to duties analogous to minimum TS positions but were instead assigned to perform various surveillance testing (e.9., valve operability testing) and verifying completion of a startup checklist as the third ROs assigned on shift; and 3) being assigned as the third RO (Extra BOP) to the shift, they were essentially assisting the other watch standers and did not have the primary responsibility to monitor and safely operate the reactor plant, In this case the inspectors determined that the operators were not actively performing the duties analogous to minimum TS positions. 10 CFR 55.4 states that "actively performing the functions of an operator [ROJ or senior operator ISRO] means that an individual has a position on a shift crew that requires an individual to be licensed as defined in the facility's technical specifications, and that the individual carries out and is responsible for the duties covered by that position."

Therefore, by not maintaining their RO license in an active status in the 2no quarter 2011, the license holders violated 10 CFR 55.53

(f) when they subsequently stood RO watches in the 3'd quarter 2011 without first reactivating their licenses.

In addition, the inspectors identified that Entergy procedure 1.3.34, section 5.8[3]

describes several specific duties that an additional licensed operator assigned to the control room could perform that would meet the guidance prescribed in ES-605, "meaningfully and fully engaged in the function and duties of the analogous minimum licensed position required by technical specifications." For example, verifying control rod manipulations as a second operator would be an example of a watch-stander that is meeting this criteria. However, the inspectors determined that the procedure does not establish adequate controls and guidance for ensuring credit is given only for proficiency watches where the operator is meaningfully and fully engaged in the function and duties of the analogous minimum licensed position required by TS.

Analvsis: The inspectors determined that Entergy incorrectly credited two individuals for proficiency watch-standing experience and then these operators subsequently stood watch in the control room. This error constitutes a performance deficiency that was within Entergy's ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC's ability to perform its regulatory function because if a licensed operator fails to meet the conditions of their license, the NRC may need to perform a review for consideration of a licensing action, and if the information regarding an individual's qualifications is not accurately presented, the NRC could potentially make an incorrect licensing decision based on the inaccurate information. Specifically, Entergy did not ensure that two reactor operator (RO) licensed individuals maintained their RO licenses in an active status in the 2no quarter 2011, prior to standing RO watches in the 3'o quarter 201 1 which violated a license condition as specified in 10 CFR 55.53

(e) and (f). The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-cutting aspect was assigned. This issue is similar to violation example 6.4.c.1(c) in the NRC Enforcement Policy for a Severity Level lllviolation because it involves noncompliance with a condition stated on an individual's license.

However, since there were no adverse impacts to nuclear safety, the NRC has determined that this issue constitutes a Severity Level lV NCV in accordance with the NRC's Enforcement Policy.

Enforcement:

10 CFR 55.53 (e)states, in part, "...To maintain an active status, a license holder shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter.

(f) lf paragraph (e)is not met, before resumption of function...an authorized representative of the facility licensee shall certify...(2) That the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift function under the direction of an operator or senior operator..." Contrary to the above, prior to allowing two RO licensed individuals from resuming licensed activities in the 3rd quarter of 2011, the Entergy did not certify that the qualifications and status of the operator licensees were current and valid, regarding each individual meeting the minimum of seven 8-hour or five 12-hour shifts per calendar quarter. In fact, the RO licensed individuals had not completed the minimum of seven 8-hour or five 12-hour shifts per calendar quarter, yet were maintained in an active status by Entergy. Entergy implemented immediate corrective action that included discontinuing the practice of crediting ECCS and Extra BOP positions for proficiency. ln addition, Entergy plans to revise procedure 1.3.34 to reflect which RO watch standing positions shall receive proficiency credit, and to revise the Narrative Log module to eliminate redundant roster positions and to identify positions that qualify for proficiency. Because this issue had no adverse impacts to nuclear safety, and has been entered into the corrective action program (CR-PNP-201 1-04649), this violation is being treated as a Severity Level lV NCV, consistent with the NRC Enforcement Policy. (NCV 05000293/2011005-04, Entergy Incorrectly Credited Operators Proficiency Watch-Standing Experience and the Operators Subsequently Stood Watch)

===.5

Introduction:

The inspectors identified a Green finding of 10 CFR 55.59,===

"Requalification," based on a determination that greater than 20 percent of the biennial requalification written exam questions administered to licensed operators during weeks three and four of the 2010 examination cycle were unacceptable.

Description:

The NRC-required biennialwritten exams are designed to ensure that licensed operators maintain safe standards of knowledge and ability in order to take appropriate safety-related actions in response to actual abnormal or emergency conditions. As part of the biennial LORT Program inspection, the inspectors evaluated the content of two NRC required biennial written exams that the licensee developed and administered to licensed operators during weeks three and four of the 2010 examination cycle. Twenty of the 70 questions reviewed (i.e., approximately 28.6 percent) were found to be unacceptable containing psychometric flaws such as, more than one implausible distracter, direct lookup and double jeopardy questions. These unacceptable written exam flaws collectively affected the level of exam difficulty making the exams too easy. Entergy procedure EN-TQ-114, "Licensed Operator Training Program Description," section 5.7[3](h) states in part, "All items should adhere to the appropriate psychometric attributes and the psychometric error rate should be as low as possible." and section 5.7[3](d) further states in part, "No test item in the comprehensive written examination should be a direct lookup question," NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Appendix B, "Written Examination Guidelines," lists implausible distracters as a psychometric deficiency to be avoided and section C.2.m, states in part, "Avoid "specific determiners" that give clues to the correct answer. Specific determiners include the following:..(5) implausible distracters." Adhering to the established qualitative guidelines for developing written exams is important because it establishes an objective standard used throughout the nuclear industry to ensure that the NRC-required biennial written exams are written at an appropriate level of difficulty. The licensee entered this finding into their corrective action process, an apparent cause evaluation was conducted and corrective actions were assigned to remove closed reference questions from the biennial exam and to evaluate revising EN-TQ-1 14 to add the use of a plausibility statement for each distracter used (CR-PNP-201 1-04561 ).

Analvsis: A performance deficiency was identified in that Entergy did not ensure that NRC-required biennial comprehensive written examinations met the qualitative standards established for NRC written examinations. The inspectors determined that the finding was more than minor because it was associated with the Human Performance attribute of the Mitigation Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the finding affected the quality and level of difficulty of biennial written exams which potentially impacted Entergy's ability to appropriately evaluate licensed operators.

The risk importance of this issue was evaluated using IMC 0609, Appendix l, "Licensed Operator Requalification Significance Determination Process (SDP)." Appendix I was entered using the number of written exam questions that did not meet the qualitative standard for the written exam questions, The qualitative standard used by the inspectors is defined in NUREG-1021, Rev. 9, ES-602, Attachment l, "Guidelines for Developing Open-Reference Examinations," and Appendix B, "Written Examination Guidelines." Since 28.6 percent of the questions reviewed did not meet the guidance, Block 16 of Appendix I applied, specifically, "Were more than 20 percent of the written questions sampled by the inspectors unacceptable?" Based on this screening criteria, the finding was characterized by the SDP as having very low safety significance (greater than 20 percent unacceptable), or Green. A review of the possible cross-cutting aspects was performed and no cross-cutting aspect was identified that would be considered a contributor to the cause of the finding.

Enforcement:

10 CFR 55.59, "Requalification," Section 4,"Evaluation," requires in part, that the requalification program must include written examinations which determine licensed operators'and senior operators' knowledge of subjects covered in the requalification program and provide a basis for evaluating their knowledge of abnormal and emergency procedures. However, the regulation does not specify a requirement for the quality of exam material. Therefore, no violation of regulatory requirements occurred. Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement. Entergy entered this issue into the corrective action program (CR-PNP-201 1-04561). Because this finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as a FlN. (FlN 0500029312011005-05, Written NRC BiennialWritten Examinations Did Not Meet Qualitative Standards)

1R12 Maintenance Effectivenesg

a. lnspection Scope The inspectors reviewed the 10 CFR 50.65(b) Scoping Evaluation of Alternate Shutdown Panels (ASP) in order to assess the effectiveness of maintenance activities on ASP performance and reliability. The inspectors verified that ASPs were evaluated for scoping under the maintenance rule in accordance with 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Entergy was identifying and properly evaluating performance problems within the scope of the maintenance rule.

b. Findinqs No findings were identified.

1R13 Maintenance RiskAssessments and EmergentWork Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Entergy performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Entergy performed risk assessments as required by 10 CFR 50.65(aX4) and that the assessments were accurate and complete. When Entergy performed emergent work, the inspectors verified that Operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst and Operations personnel to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

. Yellow Risk during Reactor Core lsolation Cooling system maintenance

. Green Risk with Low Pressure Coolant Injection system unavailable, 'A' pressure sensor for the Automatic Depressurization System Maintenance, and Recirculation Flow Converter Calibration o Yellow Risk with High Pressure Coolant Injection system unavailable and maintenance being performed on the'B'Turbine Building Closed Cooling Water heat exchanger b. Findinqs No findings were identified.

1R15 Operabilitv Determinations and Functionalitv Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

. CR-PNP-2011-4342, Seismic Monitoring Equipment Trouble Alarm

. CR-PNP-2011-5388, Safety Relief Valve 203-3C Leaking

. CR-PNP-2O11-5355, Main Steam lsolation Valve 28 Position Indication Limit Switch Failed Post Maintenance Test The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to Entergy evaluations to determine whether the components or systems were operable.

Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Entergy. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findinqs No findings were identified.

1R19 Post-Maintenance Testinq

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedures to verify that the procedures adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

r Reactor Core lsolation Cooling Trip & Throttle Valve Maintenance

. Eight Year Preventive Maintenance Work and testing on electrical components for the'B' Emergency Diesel Generator (EDG)

. 'B' EDG Replacement of Air Start Motors, Fuel Tank Level Calibration, and Turbocharger Maintena nce

. 'B'EDG Emergency Diesel Generator Lockout During Testing

. Main Steam lsolation Valve AO-203-2B Cable Replacement b. Findinss No findings were identified.

==1R20 Refuelinq and Other Outaoe Activities (71111.2A - 1 sample)

==

.1 Forced Outaqe 19-2

a. Inspection Scope

The inspectors reviewed the outage plan and shutdown risk assessments for a forced outage performed from November 17,2011, through November 25,2011. The outage was performed following a plant shutdown due to a 'B'feedwater check valve (a containment isolation valve) steam leak. The documents reviewed during the inspection are listed in the Attachment. During this outage, the inspectors observed plant shutdown and start-up activities including the outage activities listed below:

r Hot and Cold Shutdown Cooling Control;

. Shutdown Risk Assessment and Risk Management; r lmplementation of Technical Specifications; o Outage Control Center Activities; r Plant Startup; and

. Licensee identification and resolution of problems.

b. Findinqs No findings were identified.

.2 Forced Outaqe 19-3

a. lnspection Scope The inspectors reviewed the outage plan and shutdown risk assessments for a forced outage performed from December 27, 2011, through January 1, 2012. The outage was performed following a plant shutdown due to Safety Relief Valve leakage. The documents reviewed during the inspection are listed in the Attachment. During this outage, the inspectors observed plant shutdown and start-up activities including the outage activities listed below:

o Hot and Cold Shutdown Cooling Control;

. Shutdown Risk Assessment and Risk Management; r lmplementation ofTechnical Specifications;

. Outage Control Center Activities;

. Plant Startup; and

. Licensee identification and resolution of problems.

b. Findinqs No findings were identified.

1R22 Surveillance Testins

a. lnspection Scope The inspectors observed performance of surveillance tests andlor reviewed test data of selected risk-significant structures, systems, and components (SSCs) to assess whether test results satisfied technical specifications, the UFSAR, and Entergy's procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

'A' Residual Heat Removal Pump Quarterly surveillance test

'D'Salt Service Water Pump In-Service Test (lST)

High Pressure Coolant Injection (HPCI) Quarterly IST and HPCI Quarterly Valve Operability Test Local Leak Rate Test of Feedwater Discharge Check Valve and Containment lsolation Valve (ClV) 6-CK-628 Findinos No findings were identified.

a a

o b.

2RS0 1 Radioactive Hazard Assessment and Exposure Controls

a. Inspection Scope

During the period from October 17,2011, through October 21,2011, the inspector conducted the following activities to verify that Pilgrim properly assessed the radiological hazards in the workplace and implemented appropriate radiation monitoring and exposure controls during refueling outage operations. lmplementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, Standards for Protection Against Radiation, relevant Technical Specifications, and the licensee's procedures.

Inspection Planning o The inspector reviewed radiation protection program self-assessments and audits.

Radioloqical Hazard Assessment o The inspector verified that Pilgrim assessed the potential impact of higher dose rates in steam-affected areas during unit down-powers.

o The inspector reviewed the two most recent surveys for each elevation of the Reactor Building and other selected spaces.

. The inspector walked down the facility, including the Reactor Building, to evaluate material and radiological conditions. The inspector verified the integrity and postings of the Locked High Radiation Areas (LHRA) in the Reactor Building and the Radwaste Processing area.

. The inspector verified the surveys included identification of hot particles, alpha emitters, potential airborne radioactive material, hazards associated with work activities, and severe radiation fields, as appropriate.

lnstructions to Workers

. The inspector toured radioactive material storage areas and verified containers were labeled and controlled in accordance with 10 CFR 20.1904, "Labeling Containers."

. The inspector reviewed radiation work permits (RWPs)for entrance into the drywell to perform in-service inspection (lSl), scaffold work, and insulation work.

. The inspector verified that electronic personal dosimeter (EPD) set-points were appropriate.

o The inspector reviewed all dosimeter alarms for 2011 and verified that workers responded appropriately to the alarms and each event was reviewed by Radiation Protection staff. In most cases. the event was entered into the corrective action program.

Contamination and Radioactive Material Control o The inspector reviewed Pilgrim's procedure for the survey and release of material.

The inspector verified that instrumentation is used at its typical sensitivity and is sufficient to control the spread of contamination and prevent the unintended release of radioactive materials from the site.

o The inspector verified two sealed sources from Entergy's inventory were accounted for and intact.

. The inspector verified no transactions occurred that involved nationally tracked sources.

Radioloqical Hazards Control and Work Coveraqe

. The inspector verified conditions were consistent with surveys, RWPs, and worker briefings.

. The inspector verified the adequacy of radiation protection job coverage, contamination control, and job area surveys.

. The inspector verified licensee controls for work areas with significant dose gradients were adequate.

r The inspector reviewed the controls in place at the spent fuel pool for highly activated material stored in the pool. The inspector verified appropriate controls were in place.

. The inspector verified posting and physical controls for high radiation areas were appropriate at the Reactor Water Clean Up Heat Exchanger room and the Backwash Receiver Tank room.

Risk-Siqnificant Hiqh Radiation Area and Very Hiqh Radiation Area Controls

. The inspector discussed the controls and procedures in place for high radiation areas (HRA) and very high radiation areas (VHRA) with the Radiation Protection Manager (RPM).

o The inspector discussed the controls in place for special areas that have the potential to become VHRAs during certain plant operations with a first line health physics supervisor,

. The inspector verified that Pilgrim's controls for all VHRAs ensure that individuals will not be able to gain unauthorized access.

Radiation Worker Performance

. During observations of workers, the inspector verified workers were aware of the work area radiological conditions and the RWP requirements. The inspector observed that workers performed activities in accordance with the RWP requirements.

. The inspector reviewed condition reports (CRs) for human performance errors and observable trends.

Radiation Protection Technician Proficiencv

. During observations of radiation protection technicians, the inspector verified the technicians were aware of the area radiological conditions and the RWP requirements. The inspector observed that technicians performed activities in accordance with their training and qualifications.

. The inspector reviewed CRs for radiation protection technician errors and observable trends, Problem fdentification and Resolution

. The inspector verified problems associated with radiation monitoring and exposure control are being identified at an appropriate threshold.

b. Findinqs No findings were identified.

2RS0 2 Occupational As Low As ls Reasonablv Achievable Planninq and Controls

a. Inspection Scope

During the period from October 17,2011, through October 21,2011, the inspector conducted the following activities to verify that the licensee was properly implementing operational, engineering, and administrative controls to maintain personnel exposure As Low As is Reasonably Achievable (ALARA). lmplementation of these controls was reviewed against the criteria contained in 10 CFR Part2Q, applicable industry standards, and the licensee's procedures.

lnspection Planninq r The inspector reviewed Pilgrim's collective exposure history including the three year rolling average.

r The inspector reviewed the specific trends in collective exposures and source term measurements.

. The inspector reviewed the site specific procedures associated with maintaining occupational exposures ALARA.

Radioloqical Work Planning r The inspector obtained a list of the work activities ranked by estimated exposure for the Spring 2011 refueling outage.

r The inspector reviewed the ALAM work activity evaluations, exposure estimates, and exposure control requirements.

. The inspector verified Pilgrim identified appropriate dose mitigation techniques, defined reasonable dose goals, included decreased worker efficiency from use of respirators and heat stress, and included remote technologies.

. The inspector compared the actual exposure received with the dose estimates and the actual hours with the estimated hours.

. The inspector reviewed post job reviews and verified that Pilgrim performs in-progress reviews at two set-points, 40 pgrcent of estimate and 80 percent of estimate, prior to actual exposure reaching the estimates. The inspector verified problems identified in the post job reviews were entered into the corrective action program.

Verification of Dose Estimates and Exposure Trackino Svstems

. The inspector reviewed the assumptions and basis described in the RWP and ALARA packages for in-service inspection activities, reactor disassembly and assembly activities, and scaffold activities. The inspector reviewed the "ALAM Program" and "Radiation Work Permits" procedures to determine Pilgrim's methodology for estimating exposures for specific work activities.

Source Term Reduction and Control

. The inspector reviewed Pilgrim's source term reduction program and the effects on dose rates.

Radiation Worker Performance

. See section 2RS01, (Radiation Worker Performance and Radiation Protection Technician Proficiency)

Problem ldentification an4 Resolution

. The inspector verified that problems associated with ALARA planning and controls are identified in Pilgrim's corrective action program and properly addressed.

b. Findinqs No findings were identified.

2RS0 3 ln-Plant Ai[Forne Radioactivitv Control and Mitiqation

a. Inspection Scope

During the period from October 17, 2011, through October 21, 2011, the inspector conducted the following activities to verify that the licensee was controlling in-plant airborne concentrations consistent with ALARA. lmplementation of these controls was reviewed against the criteria contained in '10 CFR Part20, applicable industry standards, and the licensee's procedures.

Inspection Planninq r The inspector reviewed Pilgrim's UFSAR to identify potential airborne area and the associated ventilation systems or airborne monitoring instrumentation.

o The inspector reviewed Pilgrim's procedures for maintenance, inspection, and use of respiratory protection equipment.

Enqineerinq Controls o The inspector verified Pilgrim used ventilation systems as part of its engineering controls to control airborne radioactivity. The inspector verified that the reactor building and the spent fuel pool ventilation systems have adequate ventilation airflow capacity and particulate filter/charcoal unit efficiencies are adequate.

Use of Respiratorv Protection Devices

. The inspector verified the air used in Self-Contained Breathing Apparatus (SCBA) is tested and meets Grade D quality.

. The inspector verified training records for several individuals deemed fit to use respiratory devices.

o The inspector observed respiratory equipment storage areas and verified the physical condition of the device components. The inspector verified onsite personnel assigned to repair vital components have received vendor-provided training.

Self-Contained Breathinq Apparatus for Emerqencv Use

. The inspector observed the monthly inspection of four SCBAs staged in various locations including the Control Room. The inspector verified Pilgrim's capability to refill and transport bottles to and from the control room and the Operations Support Center during emergency conditions.

o The inspector verified control room operators and shift radiation protection technicians are trained and qualified in the use of SCBAS. The inspector also verified personnel assigned to fill bottles are trained and qualified to that task.

o The inspector verified appropriate mask sizes are available and that the control room operators on duty had no facial hair that would interfere with the sealing surface of the face seal and those that required corrective lenses had respiratory corrective lenses readily available in the control room.

. The inspector reviewed maintenance records for the four SCBAs inspected and verified any work performed is done by a contractor with certified training.

Problem ldentification and Resolution o The inspector verified that problems associated with control and mitigation of in-plant airborne radioactivity are put in the corrective action program and properly addressed for resolution.

b. Findinss No findings were identified.

2RS04 Occupational Dose Assessment (7 1 124.04)

a. Inspection Scope

During the period from October 17,2011, through October 21,2011, the inspector conducted the following activities to verify that Pilgrim appropriately monitors occupational dose. lmplementation of these controls was reviewed against the criteria contained in 10 CFR Part20, applicable industry standards, and the licensee's procedures.

Inspection Planninq o The inspector reviewed audits and self assessments of the radiation protection program.

o The inspector reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report for Pilgrim's vendor.

r The inspector review Pilgrim's dosimetry procedures.

o The inspector verified that Pilgrim has established procedural requirements for determining when external and internaldosimetry is required.

External Dosimetrv r The inspector verified that Pilgrim's personnel dosimeters are NVLAP accredited.

. The inspector evaluated the storage of dosimeters on-site. Pilgrim requires dosimeters be stored on-site. The inspector verified that Pilgrim does not use non-NVLAP dosimeters.

. The inspector verified the correction factor used for electronic dosimeters is based on sound technical principles. The inspector reviewed condition reports for the trend analysis of electronic dosimeters and the implemented actions.

lnternal Dosimetrv o The inspector verified the procedures used to assess dose from internally deposited nuclides address methods for determining if an individual is internally or externally contaminated, the release of contaminated individuals, the determination of entry route, and assignment of dose. The inspector verified that the frequency of whole body count measurements is consistent with the biological half-life of the potential nuclides available for intake. The inspector verified that whole body counting is the method for screening intakes. The inspector reviewed whole body counts performed for contaminated individuals and verified that each had sufficient counting time/low background, used an appropriate nuclide library, and anomalous peaks/nuclides received appropriate disposition. The inspector verified that hard-to-detect nuclides are accounted for in the dose assessments.

o The inspector reviewed in-vitro monitoring for divers to determine tritium intake. The inspector reviewed the adequacy of collection and storage of samples, r The inspector reviewed the adequacy of dose assessments based on airborne/Derived Airborne Concentration (DAC) monitoring. The inspector verified that Pilgrim has not had to perform DAC calculations during the assessment cycle.

r The inspector reviewed internal dose assessments for which an actual internal exposure greater than 10 millirem was assigned.

Special Dosimetric Situations

. The inspector reviewed several skin dose assessments. Pilgrim uses VARSKIN to perform the calculations.

o The inspector reviewed Pilgrim's neutron dosimetry program. The inspector verified Pilgrim uses the vendor's TracEtch chip and that calculations account for the gamma radiation.

o The inspector verified that Pilgrim appropriately assigns total effective dose equivalent (TEDE), shallow dose equivalent (SDE) and lens dose equivalent (LDE)to individuals from both internal and external monitoring results, supplementary information, and surveys including air monitoring results as required.

Problem ldentification and Resolution

'

The inspector verified that problems associated with occupational dose assessment have been identified at the appropriate threshold and properly addressed in Pilgrim's corrective action program.

b. Findinqs No findings were identified.

2RS05 Radiation Monitorinq Instrumentatign (7 1 124.05)a. lnspection Scope During the period from October 17, 2011, through October 21, 2011, the inspector conducted the following activities to verify that the licensee was ensuring the accuracy and operability of radiation monitoring instruments.

Calibration and Testinq Proqram Laboratory l nstrumentation o The inspector verified that appropriate corrective actions were implemented for instrument response to indications of degraded instrument performance.

Portable Survey Instruments, Area Radiation Monitors, Electronic Dosimetry, and Air Samplers/Continuous Air Monitors

. The inspector verified that Pilgrim evaluated the possible consequences of instrument use since the last successful calibration or source check for two instruments that either failed source check or calibration.

OTHER ACTIVITIES

4AA1 Performance lndicator Verification (7 1151)

.1 Mitiqatinq Svstems (2 samples)

a. Inspection Scope

The inspectors reviewed Performance lndicator (Pl) data to determine the accuracy and completeness of the reported data.

o Emergency AC Power from the fourth quarter 2010 through the third quarter 2011 lMS06l

. Cooling Water (Salt Service Water/Reactor Building Closed Cooling Water) from the fourth quarter 2010 through the third quarter 2011 [MS10]

The review was accomplished by comparing reported Pl data to confirmatory plant records and data available in plant logs, Condition Reports (CRs), Licensee Event Reports (LERs), and NRC inspection reports. To determine the accuracy of the

.2 b.

a.

b.

performance indicator data, inspectors used definitions and guidance contained in the Nuclear Energy Institute (NEl) Document 99-02, "Regulatory Assessment Performance lndicator Guideline," Revision 6, and NUREG-1022,"Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The documents reviewed during the inspection are listed in the Attachment.

Findinss No findings were identified.

Occupational Exposure Control Effectiveness (1 sample)

Inspection Scope The inspector reviewed implementation of Entergy's Occupational Exposure Control Effectiveness Pl Program. Specifically, the inspector reviewed recent CRs, and associated documents, for occurrences involving locked HRAs, VHRAS, and unplanned exposures against the criteria specified in Nuclear Energy Institute (NEl) 99-02, to verify that all occurrences that met the NEI criteria were identified and reported as Pls. This inspection activity represents the completion of one sample relative to this inspection area; completing the annual inspection requirement.

Findinqs No findings were identified.

Problem ldentification and Resolution (71152)

Routine Review of Problem ldentification and Resolution Activities Inspection Scope As required by Inspection Procedure71152, "Problem ldentification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergy entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and routinely attended condition report screening meetings.

Findinqs No findings were identified.

Semi-Annual Trend Review (1 sample)

Inspection Scope The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, "Problem ldentification and Resolution," to identify trends that might b.

4c42

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b.

indicate the existence of more significant safety issues. ln this review, the inspectors included repetitive or closely-related issues that may have been documented by Entergy outside of the corrective action program, such as trend reports, Pls, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed Entergy's corrective action program database to assess condition reports written in various subject areas (equipment problems, human performance issues, as well as individual issues identified during the NRCs daily condition report review (Section 4OA2.1). The inspectors reviewed Entergy's quarterly trend reports to verify that Entergy personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

Findinqs and Observations lmplementation of the Operabilitv Determination Process The inspectors have continued to observe deficiencies in the areas of Operability Determinations, including quality, timeliness, conservative decision making, and entry into Technical Specifications. The inspectors have discussed these observations at the time of their occurrence, during quarterly exit meetings, and during semi-annual trend review discussions. Training was conducted by the Operations and Engineering departments and improvements were subsequently noted in the quality and level of detail in some operability samples in 2011. In addition, CR-PNP-2011-0137 and CR-PNP-2011-1140 were written by the Operations Department in January and March of 2011 respectively, to assess operability shortfalls and to address programmatic areas for improvement. As a corrective action to CR-PNP-2O11-0137, further operability training was conducted by the Operations Department. However, additional recent examples have been identified by the inspectors during the past six months, including:

The operability of a CR documenting that the ripple voltage for a power supply for the "A" RHR containment spray flow header was out of specification. The immediate assessment of operability was conducted approximately 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after identification and no assessment of a limit for allowed ripple voltage was discussed. No extent of condition assessment was performed and the "8" loop was subsequently found significantly out of specification and declared inoperable as a result. Compensatory measures to periodically measure "A" loop ripple voltage were not considered in the original operability assessment when the nature of the degradation was unknown.

These were subsequently put in place when the "B" loop was also found out of specification.

The operability assessment for a CR documenting control rod scram times which may be affected by seismic concerns was not originally identified as "Operable-Compensatory Measure," even though the operability evaluation required actions to be taken under certain plant conditions to maintain control rods operable. The recognition and designation of compensatory measures to maintain operability continues to be an area that requires improvement.

A CR documenting misalignment and a bent pin on a connector for MSIV 28 was not submitted to the control room. The inspectors brought this to the attention of Operations and scheduling personnel who had initiated the CR. The subsequent operability assessment indicated that the assessment of the condition was covered under another

.3 CR that documented the replacement of MSIV cables, However, the other CR did not

address the as-left condition of the misaligned connector and the bent pin and the basis for acceptability of this condition and system operability.

The inspectors concluded that the operability determination process improvements remain a work in progress and corrective actions and progress in response to this trend will continue to be evaluated.

Annual Sample: Safetv Relief Valve Operability (1 sample)

Insoection Scope The inspectors selected the issues of safety relief valve (SRV) and automatic depressurization system (ADS) valve leakage and setpoint test failures as an inspection sample for in-depth review to assess the corrective actions taken by Entergy to address these long-standing issues. Entergy's corrective actions included replacing the four ADS valves and the two safety relief valves with a Target Rock three-stage relief valve design, increasing the capacity of the two safety relief valves, and amending the license to allow for a set-point pressure band of +l-3o/o. Additionally, the new valves were equipped with multiple leak detection temperature indicators.

The inspectors reviewed procedures, condition reports, engineering evaluations, modification packages, post maintenance testing, and license amendment correspondence, and interviewed plant personnel to assess Entergy's problem identification, evaluation, and corrective action effectiveness with respect to SRV and ADS valve leakage and set-point drift. Additionally, the inspectors reviewed the technical specifications and UFSAR to assess the change to the relief valves with respect to design and licensing bases requirements. Documents reviewed are listed in the attachment.

Findinqs and Observations No findings were identified.

The ADS valves and SRVs were originally a two-stage Target Rock-type design, consisting of a pilot-stage assembly and a main-stage assembly. Industry Operating Experience had shown that two-stage Target Rock relief valves exhibited some amount of pilot-stage leakage during plant operation. Additionally, the technical specification allowed valve setpoint pressure band was +/- 1%, which left little margin to maintain the valves operable in the event of valve leakage. As a result, SRV and ADS valve pilot-stage leakage were challenges throughout the plant's operating history and caused several forced shutdowns.

The inspectors noted, based on nuclear industry operating experience, that the replacement of all the ADS and SRVs with the three-stage Target Rock design was a significant positive step in reducing the likelihood of relief valve seat leakage.

Additionally, the inspectors noted Entergy's evaluation of an expanded relief valve set-point pressure band and subsequent license amendment have resulted in significantly more operating margin for the plant in the event that a valve does exhibit signs of leakage. Finally, the inspectors determined the addition of several temperature a.

b.

.1 40A3

40A6 monitoring points on the valve would allow Entergy to more effectively evaluate the operability of the valve should any leakage occur.

Follow-Up of Events and Notices of Enforcement Discretion (71 153)

Operator Performance Durinq Thermal Backwash (1 sample)

Inspection Scope The inspectors observed an infrequently performed evolution on November 17,2011.

Specifically, the inspectors observed a plant downpower to support thermal backwash of the condenser, and control rod scram time testing. The inspectors reviewed procedural guidance for station power changes and the power maneuver plan, and observed control room conduct and control of the evolution. During the downpower, significant leakage was identified from the'B' Feedwater Check Valve (a Containment lsolation Valve (ClV)). Pilgrim determined that the CIV could not meet its safety function, shut down the plant, and commenced Forced Outage 19-2 (see section 1R20). The documents reviewed during this inspection are listed in the Attachment.

Findinqs No findings were identified.

Safetv Relief Valve (SRV-3D) Leakaqe Inspection Scope The inspectors observed a plant shutdown on December 27, 2011 after operators identified significant first-stage leakage on SRV-3D, Pilgrim determined that the leakage exceeded limits in their station procedure, entered technical specifications, and shut down the plant to commence Forced Outage 19-3 and repair the SRV (see section

1R20 ). 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.

Findinqs No findings were identified.

Meetinqs. Includinq Exit A radiation protection exit meeting was held on October 2Q, 2011. Tom White, Acting Engineering Director, attended the meeting. At the exit meeting, the inspector confirmed that no proprietary information was provided to the inspector for the inspection.

On December 20, 2011, the operator licensing inspectors presented the biennial licensed operator requalification inspection results to Mr. R. Smith, Site Vice President, and other members of the Entergy staff.

On January 10, 2Q12, the resident inspectors conducted an exit meeting and presented the preliminary inspection results to Mr. Robert Smith, and other members of the Pilgrim a.

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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.

4CA7 Licensee-ldentified Violations The following violation of very low safety significance (Green) was identified by Entergy and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation (NCV),

Technical specification 5.4,1, "Procedures," requires that written procedures shall be established, implemented, and maintained including the emergency operating procedures (EOP) required to implement the requirements of NUREG-0737, "Clarification of TMI Action Plan Requirements," and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33, "Order Confirming Licensee Commitments on Emergency Response Capability Schedules." Contrary to technical specification 5,4.1, portions of EOP-2, "RPV Control, Failure to Scram," could not have been implemented from October 8, 2011 through November 6,2011. Specifically, injection of sodium pentaborate would not have been able to be performed because Pilgrim's warehouse did not resupply its inventory of the required 12 barrels of sodium pentaborate necessary to implement EOP-2. Pilgrim entered this issue into the corrective action program as CR-PNP-201 1-4887, and obtained the required inventory on November 6, 201 1. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," Mitigating Systems Cornerstone, because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent an actual loss of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.

ATTACHMENT: SUPPLEM ENTARY I N FORMATION

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Enterqv Personnel

G. Bradley

Component Engineering

B. Chenard

System Engineering Manager

B. Clow

Radiation Protection Technician

S. Colburn

Supervisor Access Authorization and Fitness for Duty

J. Dreyfuss

Plant General Manager

V. Fallacara

Engineering Director

A. Felix

Auxiliary Operator

J. Fitzsimmons Radiation Protection Supervisor

J. House

Superintendent, Initial Operations Training

W. Lobo

Licensing Engineer

J. Lynch

Director, Nuclear Safety Assurance and Licensing Manager

J. Macdonald Assistant Operations Manager-Shift

T. McElhinney Training Manager

W. Morrow

Radiation Protection Supervisor

A. Muse

Superintendent, Operations Training

D. Noyes

Operations Manager

J. Priest

Radiation Protection Manager

R. Smith

Site Vice President

J. Taormina

Maintenance Manager

M. Thornhill

Radiation Protection Supervisor

J. Whalley

Operations Shift Manager

T. White

Emergency Planning Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened

AV

05000293t201 1 005-01 AV

05000293t201 1 005-02 Licensed Operators Stood Watch Without Being Medically Qualified (Section 1R1 1)

Entergy did not Provide Complete and Accurate Medicat Information for Licensed Operator Renewal Applications (Section 1R1 1)

Entergy did not Notify the NRC Within 30 Days of Discovering Changes in Medical Conditions (Section 1R1 1)

AV 050002 93 l 201 1 005-03

Opened and Closed

NCV

05000293t201 1 005-04 FtN

050002931201 1 005-05

Entergy lncorrectly Credited Operators Proficiency Watch-

Standing Experience and the Operators Subsequently Stood Watch (Section 1R1 1)

Written NRC BiennialWritten Examinations did not meet Qualitative Standards (Section 1R1 1)