IR 05000293/2013403

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IR 05000293-13-403; 12/2/2013 to 12/6/2013; Pilgrim Nuclear Power Station; Access Control, Protective Strategy Evaluation, and Problem Identification and Resolution, Letter Only
ML14017A405
Person / Time
Site: Pilgrim
Issue date: 01/17/2014
From: Anthony Dimitriadis
Plant Support Branch 1
To: Dent J
Entergy Nuclear Operations
References
IR-13-403
Download: ML14017A405 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ary 17, 2014

SUBJECT:

PILGRIM NUCLEAR POWER STATION - NRC BASELINE SECURITY INSPECTION REPORT 05000293/2013403 AND NOTICES OF VIOLATION

Dear Mr. Dent:

On December 6, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS). The inspection covered one or more of the key attributes of the security cornerstone of the NRCs Reactor Oversight Process. The enclosed inspection report documents the inspection results which were discussed on December 6, 2013, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to security and compliance with the Commissions rules and regulations and with the conditions of your license.

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

Two violations of very low security significance (Green) are cited in the enclosed Notices of Violation (Notices) and the circumstances surrounding them are described in the enclosed inspection report. These violations were evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs website at http://www.nrc.gov/aboutnrc/regulatory/enforcement/enforcement-pol.html. These violations are being cited in the Notices because not all of the criteria specified in Section 2.3.2.a of the NRC Enforcement Policy for a non-cited violation (NCV) were satisfied. Specifically, Entergy Nuclear Operations, Inc., failed to correct long-standing equipment deficiencies important to station security defense in depth strategy to restore compliance within a reasonable amount of time after violations were issued in November 2012 (05000293/2012403, ML12307A288).

Enclosures contain Sensitive Unclassified Non-Safeguards Information. When separated from enclosures, the transmittal document is decontrolled. You are required to respond to this letter and should follow the instructions specified in the enclosed Notices when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notices. The NRC review of your response to the Notices will also determine whether enforcement action is necessary to ensure compliance with regulatory requirements.

Two identical cross-cutting aspects were assigned to the NOVs in the area of Problem Identification and Resolution, Corrective Action Program, because Pilgrim did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity P.1(d).

Three NRC identified findings of very low security significance (i.e., Green as determined by the Baseline Security Significance Determination Process) were identified during this inspection.

The deficiencies were promptly corrected or compensated for, and the plant was in compliance with applicable physical protection and security requirements within the scope of this inspection before the inspectors left site.

Two of these findings were determined to involve violations of NRC requirements. The NRC is treating these violations as NCVs consistent with Section 2.3.2 of the Enforcement Policy.

If you contest these violations or the significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-001; and the NRC Resident Inspectors at the Pilgrim Nuclear Power Station.

Two cross-cutting aspects were assigned to the findings in the areas of Human Performance.

One cross-cutting aspect was assigned in the area of Human Performance, Decision Making, because Pilgrim failed to use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action was safe in order to proceed rather than a requirement to demonstrate that it was unsafe in order to disapprove the action H.1(b). The second cross-cutting aspect was assigned in the area of Human Performance, Work Practices, because Pilgrim did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported H.4(c). If you disagree with a cross-cutting aspect assignments in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I; and the NRC Resident Inspectors at the Pilgrim Nuclear Power Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 2.390, Public Inspections, Exemptions, requests for Withholding, of the NRC's Rules of Practice, a copy of this letter 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://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). However, the material enclosed herewith contains Security-Related Information in accordance with 10 CFR §2.390(d)(1) and its disclosure to unauthorized individuals could present a security vulnerability. Therefore, the material in the enclosures will not be made available electronically for public inspection in the NRC Public Document Room or from ADAMS.

If you choose to provide a response and Security-Related Information is necessary to provide an acceptable response, please mark your entire response Security-Related Information -

Withhold From Public Disclosure Under 10 CFR §2.390 in accordance with 10 CFR §2.390(d)(1) and follow the instructions for withholding in 10 CFR §2.390(b)(1).

In accordance with 10 CFR §2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.

Sincerely,

/RA/

Anthony Dimitriadis, Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-293 License No. DPR-35 Enclosures:

1. Inspection Report 05000293/2013403 w/Attachment: Supplemental Information 2. Notices of Violation cc w/o encl; w/o OUO-SRI: Distribution via ListServ cc w/encl; w/OUO-SRI:

D. Burke, Protective Services Department Section Manager J. Giarrusso, SLO, Massachusetts Emergency Management Agency (MEMA) However, the material enclosed herewith contains Security-Related Information in accordance with 10 CFR §2.390(d)(1) and its disclosure to unauthorized individuals could present a security vulnerability. Therefore, the material in the enclosures will not be made available electronically for public inspection in the NRC Public Document Room or from ADAMS.

If you choose to provide a response and Security-Related Information is necessary to provide an acceptable response, please mark your entire response Security-Related Information -

Withhold From Public Disclosure Under 10 CFR §2.390 in accordance with 10 CFR §2.390(d)(1) and follow the instructions for withholding in 10 CFR §2.390(b)(1).

In accordance with 10 CFR §2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.

Sincerely,

/RA/

Anthony Dimitriadis, Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-293 License No. DPR-35 Enclosures:

1. Inspection Report 05000293/2013403 w/Attachment: Supplemental Information 2. Notices of Violation cc w/o encl; w/o OUO-SRI: Distribution via ListServ cc w/encl; w/OUO-SRI:

D. Burke, Protective Services Department Section Manager J. Giarrusso, SLO, Massachusetts Emergency Management Agency (MEMA)

Distribution: See Next Page Non-Public Designation Category: MD 3.4 Non-Public A.3 DOCUMENT NAME: G:\DRS\Plant Support Branch 1\Security\2013 IR Draft\Pilgrim\Pilgrim 2013403 Rev 13.docx ADAMS ACCESSION NO.: ML14017A405(Cover ltr) ADAMS ACCESSION NO.: ML14017A401(Cvr ltr w/encl)

Cover Letter X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available Cover Letter w/Enclosure Non-Sensitive Publicly Available X SUNSI Review X Sensitive X Non-Publicly Available OFFICE RI/DRS RI/DRS RI/DRS RI/OE RI/DRP RI/DRS RI/DRS NAME DCaron/KH DEverhart KHussar CCrisden/BB RMcKinley CCahill ADimitriadis DATE 01/16/14 01/14/14 01/16/14 01/14/14 01/15/14 01/16/14 01/17/14 OFFICIAL RECORD COPY Distribution w/o encl; w/o OUO-SRI: (via E-mail)

W. Dean, RA (R1ORAMAIL Resource)

D. Lew, DRA (R1ORAMAIL Resource)

D. Roberts, DRP (R1DRPMAIL Resource)

M. Scott, DRP (R1DRPMail Resource)

R. Lorson, DRS (R1DRSMail Resource)

J. Trapp, DRS (R1DRSMail Resource)

R. McKinley, DRP S. Shaffer, DRP J. DeBoer, DRP E. Keighley, DRP S. Schneider, DRP, SRI B. Scrabeck, DRP, RI S. Campbell, DRP, Resident AA B. Rini, RI OEDO RidsNrrPMPilgrim Resource RidsNrrDorlLPL1-1 Resource ROPReports.Resource Distribution w/encl; w/OUO-SRI:

A. Dimitriadis, DRS R. Albert, NSIR S. Coker, NSIR S. Schneider, DRP, SRI C. Johnson, NSIR B. Desai, DRS, RII R. Skokowski, DRS, RIII M. Haire, DRS, RIV