IR 05000293/2016005

Mid-Cycle Assessment Letter for Pilgrim Nuclear Power Station (Report 05000293/2016005)

ML16239A119
Person / Time
Site:	Pilgrim
Issue date:	08/31/2016
From:	Dan Dorman Region 1 Administrator
To:	Dent J Entergy Nuclear Operations
Burritt A
References
IR 2016005
Download: ML16239A119 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 August 31, 2016 Mr. John Dent Site Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 SUBJECT: MID-CYCLE ASSESSMENT LETTER FOR PILGRIM NUCLEAR POWER STATION (REPORT 05000293/2016005)

Dear Mr. Dent:

On August 9, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed its mid-cycle performance review of Pilgrim Nuclear Power Station (Pilgrim). The NRC reviewed the most recent quarterly performance indicators in addition to inspection results and enforcement actions from July 1, 2015, through June 30, 2016. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility.

The NRC determined the performance at Pilgrim during the most recent quarter was within the Repetitive Degraded Cornerstone Column (Column 4) of the NRCs Reactor Oversight Process (ROP) Action Matrix as defined in Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program. This resulted from issuance of an additional White finding in the Mitigating Systems cornerstone while Pilgrim was in the Degraded Cornerstone Column (Column 3) of the ROP Action Matrix for more than five consecutive quarters, as described in the mid-cycle assessment letter dated September 1, 2015 (ML15243A2591). The NRC also determined that Pilgrim continues to operate safely, and additional regulatory actions beyond those prescribed for plants in Column 4 are not required at this time. There have been no risk-significant events, equipment failures, or inspection findings since Pilgrims entry into Column 4.

During the last assessment period, the NRC had identified a cross-cutting theme in Problem Identification and Resolution in accordance with IMC 0305 because the inspectors had identified 13 findings with a cross-cutting aspect in this area. In the current assessment cycle this cross-cutting theme no longer exists.

As a result of Pilgrims entry into Column 4, in addition to ROP baseline inspections, the NRC must complete a supplemental inspection in accordance with Inspection Procedure (IP) 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input. Based on the corrective action program weaknesses that resulted in Pilgrims entry into Column 4, the scope of this

The designation in parentheses refers to an Agencywide Documents Access and Management System (ADAMS) Accession Number. Documents referenced in this letter are publicly available using the Accession Number in ADAMS. supplemental inspection at Pilgrim is focused on the corrective action program and safety culture assessment (reference sections 02.02 and 02.07 through 02.09 of IP 95003). The scope also includes the Reactor Safety Strategic Performance Area, with focus on the key attributes of human performance, procedure quality, and equipment performance (reference sections 02.03c, 02.03d and 02.03e of IP 95003).

In a letter dated December 18, 2015 (ML15352A128), the NRC informed you of its intent to conduct the IP 95003 inspection in three phases (A through C). The Phase A and B portions of this inspection are complete (ML16060A018 and ML16144A027). These inspections reviewed aspects of the Pilgrim corrective action program to determine whether continued operation of Pilgrim was acceptable or additional regulatory action was needed to arrest declining performance. Based on the overall results of these inspections, the NRC concluded that Pilgrim continued to operate safely. We plan to conduct Phase C of the inspection, which will complete our review of the IP 95003 inspection scope described above, once you have informed us of your readiness.

In the interim, in addition to the aforementioned phased approach of IP 95003, IMC 0305 provides a number of regulatory tools to ensure increased oversight to monitor for any additional performance decline. For instance, NRC senior management has been conducting quarterly reviews of Pilgrim performance, with a particular focus on monitoring for additional performance decline. The NRC has added additional inspection resources and has engaged Entergy Nuclear Operations, Inc. (Entergy) with more frequent site visits. The Commission met with Entergy to discuss Entergys performance improvement plan at the Commission public meeting held on June 2, 2016. As our assessment of the plants performance in Column 4 continues, the NRC may take additional regulatory actions as warranted, including additional supplemental inspections, a demand for information, or issuance of an order, up to and including a plant shutdown.

The enclosed inspection plan lists the inspections scheduled through June 30, 2018. Routine inspections performed by resident inspectors are not included in the inspection plan. In addition, the NRC plans to conduct IP 60855.1, Operation of an Independent Spent Fuel Storage Installation at Operating Plants, at your facility. The inspections listed during the last half of the inspection period in the inspection plan are tentative and may be revised at the end-of-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security-related inspections, which will be sent via separate, non-publicly available correspondence.

From July 1, 2015, to June 30, 2016, the NRC issued a Severity Level III traditional enforcement violation to Pilgrim for falsified fire watches. In accordance with IMC 0305, Operating Reactor Assessment Program, Section 13.02.b, the NRC will follow up on the Severity Level III violation through IP 92702, Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders.

In Staff Requirements Memorandum - SECY 16-0009, Recommendations Resulting from the Integrated Prioritization and Re-Baselining of Agency Activities, (ML16104A158) the Commission approved the NRC staff recommendation to discontinue the formal mid-cycle assessment process beginning in calendar year 2017. This will be the final mid-cycle assessment letter. The staff will continue to conduct assessment reviews and communicate changes in the assessment of licensee performance quarterly, and will also issue end-of-cycle assessment letters.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Please contact Arthur Burritt at (610)337-5069 with any questions you have regarding this letter.

Sincerely,

/RA/

Daniel H. Dorman Regional Administrator Docket No. 50-293 License No. DPR-35 Enclosure:

Pilgrim Inspection/Activity Plan cc w/encl: Distribution via ListServ

ML16239A119 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP RI/ORA NAME JVazquez ABurritt MScott w/edits DDorman DATE 8/17/16 8/15/16 8/15/16 8/22/16

Page 1 of 2 Pilgrim 08/01/2016 10:26:33 Inspection / Activity Plan Report 22 07/01/2016 - 06/30/2018 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site 7111107T - TRIENNIAL HEAT SINK 1 1 07/18/2016 07/22/2016 IP 7111107T Heat Sink Performance 2/27EXM - PILGRIM INITIAL OL EXAM 4 1 01/30/2017 02/05/2017 U01945 FY17-PILGRIM INITIAL OPERATOR LICENSING EXAM 1 02/27/2017 03/03/2017 U01945 FY17-PILGRIM INITIAL OPERATOR LICENSING EXAM ISFSI - ISFSI LOADING CAMPAIGN INSPECTION 2 1 09/26/2016 09/30/2016 IP 60855 Operation Of An ISFSI 1 09/26/2016 09/30/2016 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants EP - EP EXERCISE EVALUATION 4 1 11/14/2016 11/18/2016 IP 7111401 Exercise Evaluation 71124 - 71151 PI VERIFY 71124.01EXPCONT05RAD MON 1 1 11/28/2016 11/30/2016 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 1 11/28/2016 11/30/2016 IP 71124.05 Radiation Monitoring Instrumentation 1 11/28/2016 11/30/2016 IP 71151-OR01 Occupational Exposure Control Effectiveness 1 11/28/2016 11/30/2016 IP 71151-PR01 RETS/ODCM Radiological Effluent Occurrences 7111108G - INSERVICE INSPECTION 1 1 04/17/2017 04/21/2017 IP 7111108G Inservice Inspection Activities - BWR 71124 - 71124.01 RAD HAZARD AND 71124.02 ALARA 1 1 04/24/2017 04/27/2017 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 1 04/24/2017 04/27/2017 IP 71124.02 Occupational ALARA Planning and Controls 71124.08 - RADWASTE 1 1 06/05/2017 06/09/2017 IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 71124 - RAD HAZ- ALARA- AIRBORNE-DOSIMETRY 1 1 06/05/2017 06/09/2017 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 1 06/05/2017 06/09/2017 IP 71124.02 Occupational ALARA Planning and Controls 1 06/05/2017 06/09/2017 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 1 06/05/2017 06/09/2017 IP 71124.04 Occupational Dose Assessment 7111111B - PILGRIM REQUAL INSP W/ P/F RESULTS 2 1 09/04/2017 09/08/2017 IP 7111111B Licensed Operator Requalification Program 7111121 - CDBI 6 1 07/31/2017 08/04/2017 IP 7111121 Component Design Bases Inspection 1 08/14/2017 08/18/2017 IP 7111121 Component Design Bases Inspection 1 08/28/2017 09/01/2017 IP 7111121 Component Design Bases Inspection This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures. Enclosure

Page 2 of 2 Pilgrim 08/01/2016 10:26:33 Inspection / Activity Plan Report 22 07/01/2016 - 06/30/2018 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site 71124 - 71124.06 RETS 1 1 08/07/2017 08/11/2017 IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment 71152B - PI&R BIENNIAL TEAM INSPECTION 5 1 09/11/2017 09/15/2017 IP 71152B Problem Identification and Resolution 1 09/25/2017 09/29/2017 IP 71152B Problem Identification and Resolution 71124 - 71124.07 REMP 1 1 09/18/2017 09/21/2017 IP 71124.07 Radiological Environmental Monitoring Program 71124 - 71151 PI VERIFY71124.02ALARA06RETS07REMP 1 1 11/20/2017 11/23/2017 IP 71124.02 Occupational ALARA Planning and Controls 1 11/20/2017 11/23/2017 IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment 1 11/20/2017 11/23/2017 IP 71124.07 Radiological Environmental Monitoring Program 1 11/20/2017 11/23/2017 IP 71151-OR01 Occupational Exposure Control Effectiveness 1 11/20/2017 11/23/2017 IP 71151-PR01 RETS/ODCM Radiological Effluent Occurrences EP - EP PROGRAM INSPECTION 1 1 11/27/2017 12/01/2017 IP 7111402 Alert and Notification System Testing 1 11/27/2017 12/01/2017 IP 7111403 Emergency Preparedness Organization Staffing and Augmentation System 1 11/27/2017 12/01/2017 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 1 11/27/2017 12/01/2017 IP 71151 Performance Indicator Verification 71124.01 - 01 EXPOSURE CONTROL 1 1 04/09/2018 04/12/2018 IP 71124.01 Radiological Hazard Assessment and Exposure Controls This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.