ML052070351

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IR 05000293-05-003; on 04/01-06/30/2005; for Pilgrim Nuclear Power Station, Activities Related to Safety and Compliance with the NRCs Rules and Regulations and with the Conditions of the License
ML052070351
Person / Time
Site: Pilgrim
Issue date: 07/26/2005
From: Anderson C
NRC/RGN-I/DRP/PB5
To: Balduzzi M
Entergy Nuclear Operations
References
IR-05-003
Download: ML052070351 (51)


See also: IR 05000293/2005003

Text

July 26, 2005

EA-05-039

Mr. Michael A. Balduzzi

Site Vice President

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station

600 Rocky Hill Road

Plymouth, Massachusetts 02360-5508

SUBJECT:

PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION

REPORT 05000293/2005003

Dear Mr. Balduzzi:

On June 30, 2005, the US Nuclear Regulatory Commission (NRC) completed an inspection at

your Pilgrim reactor facility. The enclosed integrated inspection report documents the

inspection findings, which were discussed on July 7, 2005, with Mr T. Kirwin and members of

your staff.

The inspection examined activities conducted under your license as they relate to safety 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.

On the basis of the results of this inspection, no findings of significance were identified. After

this inspection period ended, the NRC issued a letter on July 14, 2005, issuing a Severity Level

III Notice of Violation and Proposed Imposition of Civil Penalty. This inspection report

acknowledges issuance of that letter and assigns a tracking number for the Severity Level III

Notice of Violation. Additionally, licensee-identified violations which were determined to be of

very low safety significance are listed in Section 4OA7 of this report. If you contest any NCV in

this report, you should provide a response with the basis for your denial, within 30 days of the

dated of this inspection report, to the U.S. Nuclear Regulatory Commission, ATTN: Document

Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region

I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555-0001; and the NRC Resident Inspector at Pilgrim.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of the NRCs document

Michael Balduzzi

2

system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Clifford Anderson, Chief

Projects Branch 5

Division of Reactor Projects

Docket No.

50-293

License No.

DPR-35

Enclosure:

Inspection Report 05000293/2005003

w/Attachment: Supplemental Information

cc w/encl:

G. J. Taylor, Chief Executive Officer, Entergy Operations

M. Kansler, President, Entergy Nuclear Operations, Inc.

J. T. Herron, Senior Vice President and Chief Operating Officer

C. Schwarz, Vice-President, Operations Support

S. J. Bethay, Director, Nuclear Safety Assurance

O. Limpias, Vice President, Engineering

J. F. McCann, Director, Licensing

C. D. Faison, Manager, Licensing

M. J. Colomb, Director of Oversight, Entergy Nuclear Operations, Inc.

B. S. Ford, Manager, Licensing, Entergy Nuclear Operations, Inc.

T. C. McCullough, Assistant General Counsel

S. Lousteau, Treasury Department, Entergy Services, Inc.

R. Walker, Department of Public Health, Commonwealth of Massachusetts

The Honorable Therese Murray

The Honorable Vincent deMacedo

Chairman, Plymouth Board of Selectmen

Chairman, Duxbury Board of Selectmen

Chairman, Nuclear Matters Committee

Plymouth Civil Defense Director

D. OConnor, Massachusetts Secretary of Energy Resources

J. Miller, Senior Issues Manager

Office of the Commissioner, Massachusetts Department of Environmental Protection

Office of the Attorney General, Commonwealth of Massachusetts

Electric Power Division, Commonwealth of Massachusetts

R. Shadis, New England Coalition Staff

D. Katz, Citizens Awareness Network

Chairman, Citizens Urging Responsible Energy

J. Sniezek, PWR SRC Consultant

Michael Balduzzi

3

M. Lyster, PWR SRC Consultant

C. McCombs, Acting Director, MEMA and Commonwealth of Massachusettts, SLO Designee

Commonwealth of Massachusetts, Secretary of Public Safety

Michael Balduzzi

4

Distribution w/encl:

S. Collins, RA

M. Dapas, DRA

S. Lee, RI EDO Coordinator

C. Anderson, DRP

D. Florek, DRP

P. Krohn, DRP

B. Norris, DRP

J. Shea, PM, NRR

R. Ennis, NRR

W. Raymond, DRP, Senior Resident Inspector

C. Welch, DRP, Resident Inspector

A. Ford, DRP, Resident OA

Region I Docket Room (with concurrences)

DOCUMENT NAME: E:\\Filenet\\ML052070351.wpd

SISP Review Complete: DJF1 (Reviewers Initials)

After declaring this document An Official Agency Record it will be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy

OFFICE

RI/DRP

RI/DRP

/

NAME

DFlorek

CAnderson

DATE

07/25/05

07/26/05

OFFICIAL RECORD COPY

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No:

50-293

License No:

DPR-35

Report No:

05000293/2005003

Licensee:

Entergy Nuclear Operations, Inc.

Facility:

Pilgrim Nuclear Power Station

Location:

600 Rocky Hill Road

Plymouth, MA 02360

Inspection Period:

April 1, 2005 - June 30, 2005

Inspectors:

W. Raymond, Senior Resident Inspector

C. Welch, Resident Inspector

T. Burns, Reactor Inspector

D. Silk, Senior Emergency Preparedness Inspector

A. Ziedonis, Reactor Engineer Intern

J. Schoppy, DRS, Senior Reactor Inspector

T. OHara, DRS, Reactor Inspector

D. Szwarc, Reactor Engineer Intern

J. McFadden, Health Physicist

Approved By:

Clifford Anderson, Chief

Projects Branch 5

Division of Reactor Projects

Enclosure

ii

TABLE OF CONTENTS

SUMMARY OF FINDINGS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

REACTOR SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1R02

Evaluations of Changes, Tests, or Experiments . . . . . . . . . . . . . . . . . . . . . . . . 1

1R04

Equipment Alignment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

1R05

Fire Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

1R08

Inservice Inspection (ISI), Inspection Procedure . . . . . . . . . . . . . . . . . . . . . . . . 3

1R11

Licensed Operator Requalification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

1R13

Maintenance Risk Assessments and Emergent Work Control . . . . . . . . . . . . . . 5

1R14

Personnel Performance During Non-routine Plant Evolutions . . . . . . . . . . . . . . 6

1R15

Operability Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

1R16

Operator Work-Arounds

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

1R17

Permanent Plant Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1R19

Post-Maintenance Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

1R20

Refueling and Other Outage Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

1R22

Surveillance Testing

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

1R23

Temporary Plant Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

1EP2 Alert and Notification System (ANS) Testing . . . . . . . . . . . . . . . . . . . . . . . . . 14

1EP3 Emergency Response Organization (ERO) Augmentation Testing

. . . . . . . . 14

1EP4 Emergency Action Level (EAL) Revision Review . . . . . . . . . . . . . . . . . . . . . . 14

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies . . . . 15

RADIATION SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

2OS1 Access Control to Radiologically Significant Areas . . . . . . . . . . . . . . . . . . . . . 15

2OS2 ALARA Planning and Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2OS3 Radiation Monitoring Instrumentation and Protective Equipment . . . . . . . . . . 21

OTHER ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

4OA1 Performance Indicator (PI) Verification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

4OA2 Identification and Resolution of Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

4OA3 Event Follow-up . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

4OA5 Other . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

4OA6 Meetings, Including Exit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

4OA7 Licensee-Identified Violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

SUPPLEMENTAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

KEY POINTS OF CONTACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . A-2

LIST OF DOCUMENTS REVIEWED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-2

LIST OF ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-14

Enclosure

iii

SUMMARY OF FINDINGS

IR 05000293/2005003; 04/01-06/30/2005; Pilgrim Nuclear Power Station, Other

The report covered a 13 week period of inspection by resident inspectors and announced

inspections by regional inspectors including a senior emergency preparedness Inspector, senior

reactor inspector, health physics inspector and reactor inspectors. One Severity Level III Notice

of Violation and Proposed Imposition of Civil Penalty issued in a letter dated July 14, 2005, is

documented in this report. The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter (IMC) 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 NRCs program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 3, July 2000.

A.

Inspector Identified and Self-Revealing Findings

Miscellaneous

SL-III In a letter dated July 14, 2005, the NRC issued a Severity Level III Notice of

Violation and Proposed Imposition of Civil Penalty to Entergy in the base amount of

$60,000 associated with a Severity Level III problem. The Severity Level III problem

involved four violations of NRC requirements related to Technical Specification 5.4.1, 10 CFR Part 50 Appendix B, and 10 CFR Part 26. The specific violations involved: (1) a

Pilgrim control room supervisor sleeping for approximately four minutes in the control

room; (2) a reactor operator observing the sleeping control room supervisor, but

deliberately not taking immediate actions to awaken the control room supervisor, inform

appropriate site personnel and initiate a condition report; (3) a Shift Manager, in

careless disregard of requirements, although taking some actions, not informing

appropriate site personnel and initiating a condition report; and (4) the sleeping control

room supervisor not being relieved of duty and for-cause Fitness-for-Duty tested. There

were no actual safety consequences resulting from this event because there were no

plant conditions that warranted immediate action.

B.

Licensee Identified Violations

Violations of very low safety significance, which were identified by Entergy, have been

reviewed by the inspector. Corrective actions taken or planned by Entergy have been

entered into Entergys corrective action program. The violations are listed in Section

4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Pilgrim Nuclear Power Station operated at reduced power in end-of-cycle coast down at the

beginning of the period. The plant shutdown to conduct refueling outage RFO#15 on

April 17, 2005. The outage was conducted with no major events. Entergy completed the

scheduled outage tests and maintenance, including the 10 year inservice inspection and reactor

vessel exams; repaired cracked welds on steam dryer tie-bars; and removed a leaky fuel

bundle. Following the outage, the reactor was made critical on May 11 and full power was

reached on May 15. The plant operated during the period at 100 percent (%) core thermal

power, except for short periods of planned operation at reduced power for routine testing and

condenser maintenance.

1.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R02

Evaluations of Changes, Tests, or Experiments (71111.02)

a.

Inspection Scope (19 samples)

The inspectors reviewed six safety evaluations (SEs) listed in the attachment, all of

which were either issued during the past two years or associated with plant

modifications that were completed during the past two years. The SEs reviewed were in

the Initiating Event, Mitigating Systems, and Barrier Integrity cornerstones. The

selected SEs were reviewed to verify that changes to the facility or procedures as

described in the Updated Final Safety Analysis Reports (UFSAR) were reviewed and

documented in accordance with 10 CFR 50.59, that safety issues pertinent to the

changes were properly resolved or adequately addressed, and that Entergy had

appropriately evaluated whether the changes and tests could be accomplished without

obtaining license amendments.

The inspectors also reviewed 13 screened-out evaluations for changes, tests and

experiments for which Entergy determined that SEs were not required. This review was

performed to verify that Entergys threshold for performing SEs was consistent with 10 CFR 50.59. The listing of the SEs and screened-out evaluations reviewed is provided in

the attachment.

In addition, the inspectors reviewed the administrative procedures that were used to

control the screening, preparation, and issuance of the SEs to ensure that the

procedure adequately covered the requirements of 10 CFR 50.59.

The inspectors reviewed condition reports (CRs) associated with 10 CFR 50.59 issues

to ensure that Entergy was identifying, evaluating, and correcting problems associated

with these areas and that the planned or completed corrective actions for the issues

were appropriate. The inspectors also reviewed self-assessments related to 10 CFR 50.59 SEs at Pilgrim. The listing of the condition reports and self assessments reviewed

is provided in the attachment.

2

Enclosure

b.

Findings

On March 10, 2005, Entergy approved a change to Procedure No. 8.M.3-1, Special Test

for Automatic ECCS Load Sequencing of Diesels and Shutdown Transformer with

Simulated Loss of Offsite Power and Special Shutdown Transformer Load Test, using

its 10 CFR 50.59 process. One aspect of the change involved removing the automatic

sequencing of the reactor building closed cooling water (RBCCW) and salt service water

(SSW) pumps (emergency loads) during the simulated loss of offsite power (LOP)/loss-

of-coolant accident (LOCA) testing to allow Entergy to perform the testing without

impacting the refueling outage critical path. The inspectors noted that Technical

Specifications (TSs) 4.9.A.1.b and 4.9.A.1.c require the energization of the auto-

connected emergency loads through the load sequencer to verify loading onto the

emergency diesel generators (EDGs) and shutdown transformer (SDT), respectively.

Entergy justified the change based, in part, on the TS 4.9.A.1 bases wording (the bases

did not specifically mention these emergency loads) and their existing load sequencing

overlap testing. The inspectors determined that the overlap testing does not actually

verify the load sequencing following an EDG start from ambient conditions as prescribed

by TS 4.9.A.1.b nor SDT loading following an EDG trip as prescribed by TS 4.9.A.1.c.

As a result, the inspectors questioned whether Entergy needed a TS Amendment to

make this change.

The NRC requires more information to determine whether this issue is an acceptable

item. Pending further review and discussion with the Office of Nuclear Reactor

Regulation (NRR), this is an unresolved item (URI). (URI 05000293/2005003-01,

2005012-02 Adequacy of Entergys Change to LOP/LOCA Testing Without Seeking

a TS Amendment)

1R04

Equipment Alignment (71111.04)

a.

Inspection Scope (5 samples)

The inspector completed a partial system review of the below-listed risk significant

systems during periods when its redundant train or system was out-of-service for

maintenance and/or testing or on restoration of the train. The position of key valves,

breakers, and control switches, required for system operability, were determined by field

walkdown and/or review of the main control board indicators. To ascertain the required

system configuration, the inspectors reviewed plant procedures, system drawings, the

Updated Final Safety Analysis Report, and the Technical Specifications. The references

used for this review are described in the attachment to this report. This inspection

activity represented five samples.

A RHR train, during maintenance on the B train per MR 05102963.

Alternate Shutdown Cooling (Mode 1) on 4/25/05.

Alternate Shutdown Cooling (Mode 2) on 4/26/05 while shutdown cooling was

secured for maintenance.

B RBCCW train, post-refuel startup readiness.

3

Enclosure

B Core Spray Train, post-refuel startup readiness.

b.

Findings

No findings of significance were identified.

1R05

Fire Protection (71111.05)

a.

Inspection Scope (12 samples)

The inspector toured selective areas of the plant to observe conditions related to: (1)

transient combustibles and ignition sources; (2) fire detection systems; (3) manual

firefighting equipment and capability; and (4) passive fire protection features. The

inspector evaluated whether the material condition of active and passive fire protection

systems features and their operational lineup and readiness were adequate. The

inspector also reviewed the applicable fire hazard analysis fire zone data sheets and

selective surveillance procedures to ensure that the specified fire suppression systems

surveillance criteria were met. The references used for this review are described in the

attachment to this report. This inspection activity represented twelve samples.

Fire Zone 1.30, Drywell

Fire Zones 2.9A & 2.10A, Condenser Bay

Fire Zone 2.8, Condensate Pump Area

Fire Zones 1.21 & 1.22, RBCCW & TBCCW pumps/heat exchangers rooms

Fire Zones 2.11 & 2.12, Feedwater Pumps Area

Fire Zones 4.1 & 4.3, A and B Emergency Diesel Generator Rooms

Fire Zones 4.2 & 4.4, A and B Emergency Diesel Day Tank Rooms

b.

Findings

No findings of significance were identified.

1R08

Inservice Inspection (ISI), Inspection Procedure (71111.08)

a.

Inspection Scope (1 sample)

The inspector observed selected in-process nondestructive examination (NDE)

activities. Also, the inspector reviewed documentation of NDE and repair/replacement

activities. The activities reviewed were based on the inspection procedure objectives

and risk priority of those components and systems where degradation could result in a

significant increase in risk of core damage. The observations and documentation

reviews were performed to verify activities were accomplished in accordance with the

American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code

requirements. The inspector reviewed reports that documented the performance and

results of ISI examinations completed during this period. Also, the inspector evaluated

Entergys effectiveness in resolving relevant indications identified during ISI activities.

4

Enclosure

The inspector observed manual ultrasonic testing (UT) and reviewed documentation of

the magnetic particle (MT), penetrant (PT), and visual test (VT) activities to verify the

effectiveness of the examiner and process for identifying degradation of risk significant

systems, structures and components. The inspector reviewed documentation to

determine whether test examiners qualifications were current and in accordance with

the ASME Code requirements and, as applicable, performance demonstration initiative

(PDI) qualifications were current. The inspector reviewed the UT test of the reactor

pressure vessel (RPV) head to flange weld RPV-HF-240-360 and the UT test

examination results of RPV top head welds RPV-TH-M4 and M5. Condition reports

(CR) were initiated for indications identified in each of the two top head welds. The

indications identified in these welds were characterized, sized and entered into the

corrective action program for engineering evaluation and disposition.

The inspector examined Entergys evaluation and disposition for continued operation

without repair or rework of non-conforming conditions identified during ISI activities by

review of CR-2003-01095 (reduced wall thickness on torus shell) and CR 2005-01916

(indication in N2F nozzle to safe end weld). The inspector reviewed a portion of the

remote in-vessel visual inspection of the reactor steam dryer base metal, structural

welds, tie bar welds and the tack welds of the leveling screws. The review was

conducted to evaluate examiner skill, test equipment performance, examination

technique, and inspection environment (water clarity) to verify Entergys ability to identify

and characterize observed indications.

The inspector did not review outage welding activities on the pressure boundary of

ASME Code Class 1 or 2 systems since no ASME Section XI welding activities on these

systems had been performed prior to the period the inspector was on site or were

underway during the period the inspector was on site.

The inspector reviewed CR 2005-01914, CR 2005-02322, and Maintenance Request

05108176 associated with acceptance of a socket weld in the standby liquid control

system. The socket weld was UT and PT tested but an indication identified during the

UT test could not be characterized and sized because of procedure limitations. The

inspector conducted the review to verify the activities were in accordance with the

applicable ASME Code requirements.

The inspector reviewed Condition Report (CR) 2005-01608 and Indication Notification

Report (INR) RFO15-05-01, Rev. 1, which identified cracks discovered in the welds of

four tie bars of the steam dryer. The tie bars maintain spacing and provide lateral

support to the steam dryer banks. The inspector reviewed the CR to determine whether

the tie bar weld cracks identified during non-destructive testing were reported,

characterized, evaluated and appropriately dispositioned and entered into the corrective

action program. Also, the inspector reviewed CR 2005-01916 which had been initiated

to report the identification of a circumferential indication in the N2F (recirculation inlet)

nozzle to safe-end weld. The indication had not been identified during previous

ultrasonic tests. The indication was identified during this examination period using the

qualified Performance Demonstration Initiative (PDI) ultrasonic test and was evaluated,

5

Enclosure

characterized, sized and dispositioned as accept for continued use by fracture

mechanics evaluation in accordance with ASME Section XI.

b.

Findings

No findings of significance were identified.

1R11

Licensed Operator Requalification (71111.11)

1.

Licensed Operator Simulator Training

a.

Inspection Scope (1 sample)

The inspector observed the performance of an operator crew during a simulator training

session on June 8, 2005. The training was conducted per module O-RQ-06-02-102 as

part of licensed operator requalification program. The inspector also reviewed training

conducted on June 8 on the procedures related to offsite power and observed a joint

training session between the Pilgrim Station and the Transmission System operator

(TSO). The simulator scenarios involved operational transients and loss of power

events. The training with the TSO personnel reviewed procedures and protocols to

monitor grid reliability and to enhance communications in response to degraded grid

conditions. The inspector evaluated whether the crew met the training scenario

objectives and performed the critical tasks. The inspector evaluated whether the crew

was properly using system operating procedures and emergency operating procedures.

The inspector also evaluated whether the post-training review discussed any relevant

lessons learned and highlighted actions to improve crew performance. This inspection

activity represented one sample.

b.

Findings

No findings of significance were identified.

1R13

Maintenance Risk Assessments and Emergent Work Control (71111.13)

a.

Inspection Scope (6 samples)

The inspector evaluated on-line risk management for planned and emergent work. The

inspector reviewed maintenance risk evaluations, work schedules, recent corrective

actions, and control room logs to verify that other concurrent planned and emergent

maintenance or surveillance activities did not adversely affect the plant risk already

incurred with the out of service components. The inspector evaluated whether Entergy

took the necessary steps to control work activities, took actions to minimize the

probability of initiating events and maintained the functional capability of mitigating

systems. The inspector assessed Pilgrims risk management actions during plant

walkdowns. The inspector also discussed the risk management with maintenance,

engineering and operations personnel as applicable for the activities. Other references

6

Enclosure

used for the inspection are identified in the attachment to this report. The inspection

covered the following six samples:

MR 05102963, 05102965, 05102969, B RHR System Valve Maintenance

MR 0001297, Planned Startup Transformer maintenance on April 4-6

MR 01108097, B RBCCW Heat Exchanger Inspection and Repair

Local Leak rate testing of MO-1001-50 on April 26, 2005.

April 21, 2005 during bus outages on A6 and A8.

April 28, 2005, during special testing of the ECCS and EDG load sequencing.

b.

Findings

No Findings of significance were identified.

1R14

Personnel Performance During Non-routine Plant Evolutions (71111.14)

a.

Inspection Scope (2 samples)

The inspectors observed the following non-routine planned evolutions or portions thereof

to assess the performance of the control room operators. The inspections focused on

command and control, communications, procedure adherence, and response to

abnormal conditions and/or alarms.

Procedure 2.2.20, Core Spray; for reactor cavity fill with core spray from the

CST.

Procedure 8.M.3-1, Special Test for Automatic ECCS Load Sequencing of

Diesels and Shutdown Transformer with Simulated Loss of Off-Site Power and

Special Shutdown Transformer Load Test.

b.

Findings

No findings of significance were identified.

1R15

Operability Evaluations (71111.15)

a.

Inspection Scope (7 samples)

The inspector reviewed selected operability determinations to assess the adequacy of

the evaluations, the use and control of compensatory measures, compliance with the

technical specifications, and the risk significance of the issues. The inspector used the

technical specifications, Final Safety Analysis Report, associated Design Basis

Documents, Procedure ENN-OP-104 Operability Determinations, and the additional

references listed in the attachment to this report for Section 1R15. This review covered

seven inspection samples.

7

Enclosure

OE and REO CR 200501136, Potential Safety Limit Violation for Analyzed

Operational Occurrences, (CR 200501136, GE Part 21 Report SC05-03)

Condition Reports 200502037, 200501711, 200501851 and 200501748 identified

safety-related snubbers SS-23-20-36, SS-2-20-25, SS-2-20-02, and SS-10-20-

08 did not have a visible hydraulic fluid level. The inspector reviewed test results

acquired per 3.M.4-37, Hydraulic and Mechanical Snubbers Functional Test, to

verify Entergys determination that the snubbers were operable.

OE and REO CR200502618, 8.M.3-1 loss of off-site power test discrepancies

MO-1001-29A torque switch setting low out of specification past operability

determination (CR 200501820).

OE and REO CR 200501028, MO-1001-29A control power fuse installed in

neutral vs power feed.

CR 200503168, B EDG POT Fuse Failure During Test Run (MR 05109337)

CR 200503140 and 200503151, Both EDGs Inoperable due to High Ambient

Temperatures

b.

Findings

No findings of significance were identified.

1R16

Operator Work-Arounds (71111.16)

a.

Inspection Scope (2 samples)

The inspector reviewed the operator work around, burden, and tour lists to evaluate the

potential cumulative impact of the equipment deficiencies on the operators ability to

implement abnormal or emergency operating procedures. The inspector walked down

the control room panels and selected plant areas to review the impact of the deficiencies

and to ensure that applicable deficiencies were captured in Entergys deficiency list. The

inspector discussed the operator workarounds with station personnel to assess the

aggregate impact on plant operations. During the review, the inspector used the criteria

contained in Entergys procedure 1.3.34.4. This inspection covered one inspection

sample of the cumulative effects of operator workarounds.

This review covered one inspection sample of specific operator workarounds. The

inspector reviewed Entergys actions to address item #349, inoperable emergency

lights, in the list of operator compensatory measures. The inspector reviewed the

deficiencies to determine if the functional capability of the system or human reliability in

responding to an initiating event was affected. The inspector evaluated the effect of the

deficiency on the operators ability to implement abnormal and emergency operating

procedures.

The inspector determined whether Entergy evaluated deficiencies for potential impact as

operator workarounds, entered them into the corrective action process, and had planned

maintenance activities to correct the identified operational deficiencies. References

used during this inspection are identified in the attachment to this report.

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Enclosure

b.

Findings

No findings of significance were identified.

1R17

Permanent Plant Modifications (71111.17)

a.

Inspection Scope (6 samples)

The inspectors reviewed six risk-significant plant modification packages selected from

the design changes that were completed within the past two years. The review was

performed to verify that: (1) the design bases, licensing bases, and performance

capability of risk significant structures, systems, and components (SSCs) had not been

degraded through the modifications; and, (2) the modifications performed during

increased risk configurations did not place the plant in an unsafe condition. The listing

of the modifications reviewed is provided in The attachment.

The selected plant modifications were distributed among the Initiating Event, Mitigating

Systems, and Barrier Integrity cornerstones. For these selected modifications, the

inspectors reviewed the design inputs, assumptions, and design calculations to

determine the design adequacy. The inspectors also reviewed field change notices that

were issued during the installation to confirm that the problems associated with the

installation were adequately resolved. In addition, the inspectors reviewed the post-

modification testing, functional testing, and instrument and relay calibration records to

determine readiness for operations. Finally, the inspectors reviewed the affected

procedures, drawings, design basis documents, and UFSAR sections to verify that the

affected documents were appropriately updated.

For the accessible components associated with the modifications, the inspectors also

walked down the systems to detect possible abnormal installation conditions.

The inspectors reviewed condition reports (CRs) associated with plant modification

issues to ensure that Entergy was identifying, evaluating, and correcting problems

associated with these areas and that the planned or completed corrective actions for the

issues were appropriate. The inspectors also reviewed self-assessments related to

plant modification activities at Pilgrim. The listing of the condition reports and self

assessments reviewed is provided in The attachment.

b.

Findings

No findings of significance were identified.

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Enclosure

1R19

Post-Maintenance Testing (71111.19)

a.

Inspection Scope (6 samples)

The inspector reviewed post-maintenance test activities on risk significant systems to

verify that the effect of the test on the plant had been evaluated adequately, the test was

properly performed in accordance with procedures, the test data met the required

acceptance criteria, and the test activity was adequate to verify system operability and

functional capability following maintenance. The inspector assessed whether systems

were properly restored following testing and that discrepancies were appropriately

documented in the corrective action process. The inspection activity represented six

samples:

Post Work Test for MR05102967 and 05102970 for B RHR System, 4/1/05

PWT per 8.5.3.14 for MR 01108097 following B RBCCW HX Overhaul

PWT for MRs P0000060, 03111321, P0000052 MSIV AO-203-1D actuator,

springs, and packing replacement per 8.7.1.6 for local leak rate testing and

8.I.11.21 for valve stroke timing and fail safe operation.

PWT for MR 031119011 MSIV AO-203-2A packing replacement per 8.7.1.6 for

local leak rate testing and 8.I.11.21 for valve stroke timing and fail safe

operation.

PWT for MRs 03109316, 03109315, 03109315 Rev 1(CR 200502219),

03109314, 03109387, for local leak rate testing per 8.7.1.5 of the feedwater

check valves following soft seat replacement and refurbishment.

Procedure 3.M.3-24.16, Quick look Operations Procedure; for static and

dynamic testing of motor-operated valve (MO) MO-1001-29A (CR 200501820).

b.

Findings

No findings of significance were identified.

1R20

Refueling and Other Outage Activities (71111.20)

a.

Inspection Scope (1 sample)

1.

Review of Outage Plan

The inspector reviewed the RFO-15 outage Shutdown Risk Assessment and procedure

TP05-002, RFO15 Compensatory Measures, to verify that Entergy addressed the

outage impact on defense-in-depth for the five shutdown critical safety functions:

electrical power availability, inventory control, decay heat removal, reactivity control, and

containment. The inspector reviewed how Entergy provided adequate defense-in-depth

for each safety function, and the planned contingencies to minimize the overall risk

where redundancy was limited or not available. Consideration of operational experience

was also assessed. The inspector periodically reviewed the daily risk up-date,

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Enclosure

accounting for schedule changes and unplanned activities. The references used during

this review are listed in the attachment to this report.

2.

Monitoring of Plant Shutdown and Cooldown Activities

The inspector reviewed Entergys action to shut the plant down in accordance with

procedures 2.1.14, Station Power Changes, and 2.1.5, Controlled Shutdown from

Power, 2.2.19.1, Residual Heat Removal-Shutdown Cooling Mode of Operation, and

2.2.85, Augmented Fuel Pool Cooling. Portions of various activities to place the plant

in a cold shutdown condition and on shutdown cooling were observed by the inspector to

assess operator performance, communications, command and control and procedure

adherence. The inspector reviewed the reactor vessel cool down rate, recorded per

OPER-07 and 2.1.7, Vessel Heat up and cool down, to determine whether it was within

technical specification requirements. Other references used are listed in the attachment

to this report.

The inspector also conducted inspection walkdowns of plant areas not normally

accessible during plant power operations (drywell, condenser bay, and main steam

tunnel) to verify the integrity of structures, piping and supports, and to confirm systems

appeared functional.

3.

Fuel Shuffle Activities and Reactivity Control

The inspector reviewed refueling activities to determine whether they were conducted in

accordance with the technical specifications and procedure 4.3, Fuel Handling. The

inspector independently reviewed, on a sampling basis, core alteration activities. The

inspector observed core alterations to assess whether core reactivity was properly

controlled. The inspector observed activities from the control room and the refueling

floor at various times. The inspector determined whether the location of fuel and core

components was tracked in accordance with the fuel movement schedule. The inspector

reviewed Entergys actions to meet the requirements of Technical Specification 3.10 for

core alterations, including the requirements for core monitoring using the source range

monitors and the functional checks of the refueling interlocks. The inspector reviewed

Entergys use of and technical bases for alternate core quadrant definitions as described

in procedure 4.3. The inspector observed communications and the coordination of

activities between the control room and the refueling floor while fuel handling activities

were in progress. The inspector independently reviewed Entergys action to verify the

proper core loading per procedure 4.5. Other references used during this review are

described in the attachment to this report.

4.

Control of Outage Activities

Outage Risk

The inspectors performed routine daily checks of the outage risk profile and determined

whether Entergy maintained defense-in-depth for the key safety functions

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Enclosure

commensurate with the outage risk control plan and that control room operators were

kept cognizant of the plant configuration.

Clearance Activities

The inspectors reviewed a sample of risk significant clearance activities to verify

whether tags were properly hung and/or removed, equipment was appropriately

configured per the clearance requirement, and that the clearance did not impact

equipment credited to meet the shutdown critical safety functions.

RBCCW system clearances: 30-0002, 29-0001-G, 30-0009-C

Inventory Control

The inspector reviewed Entergys actions to establish, monitor and maintain the proper

water inventory in the reactor during the outage, and in the reactor and spent fuel pool

after flooding the reactor cavity for refueling activities. The inspector reviewed the plant

system flow paths and configurations established for reactor makeup and determined

whether the configurations were consistent with the outage plan. The inspector

reviewed Entergys evaluations and corrective actions related to Condition Report

200501535.

Foreign Material Exclusion

The inspector reviewed the implementation of Entergys procedures for foreign material

exclusion control (FME) for the open reactor vessel, reactor cavity and spent fuel pool.

The inspector reviewed Entergys actions to verify that FME issues were documented

and resolved. References used for this review are described in the attachment to this

report.

Electrical Power

The inspector evaluated the status of electrical systems to determine whether they met

the technical specifications requirements and Entergys outage risk control plan. The

inspector reviewed the work plans for the switchyard during the A6 bus outage while the

shutdown transformer and the station blackout diesel generator were unavailable.

Decay Heat Removal (DHR) System Monitoring

The inspector observed spent fuel pool (SFP) and reactor decay heat removal system

status and operating parameters to determine whether the cooling systems operated

properly. The review included periodic review of SFP & reactor cavity level,

temperature, and RHR flow . The inspector conducted partial system walkdowns to

determine whether the proper system configuration was established for alternate spent

fuel pool cooling following an RHR train swap. The inspector also determined whether

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Enclosure

procedures were in place to establish alternate decay heat removal systems (i.e.

augmented fuel pool cooling) to recover from a loss of SFP cooling.

Containment Control

The inspector reviewed Entergys activities during the outage to control primary and

secondary containment and to clean and prepare the containment for closure prior to

plant restart. The inspector performed a walkdown of the drywell prior to reactor startup

to review cleanup and demobilization controls in areas where work was completed to

assure that tools, materials and debris were removed. This review focused on the

removal of debris which might impact the performance of the safety systems.

5.

Monitoring Plant Startup, Heatup and Approach to Critical

The inspector observed operator performance during the plant startup activities during

the period of May 8 through May 12, 2005. The inspection consisted of control room

observations, plant walkdowns and a review of the operator logs, plant computer

information, station procedures 2.1.1, Startup from Shutdown, and 2.1.14, Station

Power Changes. The inspector observed the approach to critical on May 11, 2005.

The inspector assessed whether Entergy met the Technical Specification requirements

during heatup and startup activities. The inspector assessed whether Entergy met the

Technical Specification requirements for compliance with the banked position withdrawal

sequence (BPWS) and the rod worth minimizer.

The inspector reviewed plant restart activities in accordance with procedure 2.1.1 to

determine whether, on a sampling basis, technical specifications, license conditions, and

other requirements for mode changes were met. The inspector evaluated whether

reactor coolant system (RCS) integrity was maintained throughout the restart process by

periodically reviewing RCS leakage calculations and by review of systems that monitor

conditions inside the containment.

The inspector reviewed the test results for the in-sequence shutdown margin

determination to determine whether the calculated test results per 9.16.1, In-Sequence

Critical For Shutdown Margin Demonstration, met the technical specification

requirements.

6.

Problem Identification and Resolution

The inspectors reviewed condition reports to determined whether Entergy was

identifying outage related issues and had entered them into the corrective action

program. The inspectors reviewed a sample of the corrective actions to verify they were

appropriate to resolve the issues. The references used in this review are listed in the

attachment to this report.

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Enclosure

b.

Findings

No findings of significance were identified.

1R22

Surveillance Testing (71111.22)

a.

Inspection Scope (6 samples)

The inspector observed and/or reviewed surveillance testing results to determine

whether the test acceptance criteria was consistent with Technical Specifications and

related Performance Indicators, that the test was performed in accordance with the

written procedure, the test data was complete and met procedural requirements, and

the components were capable of performing their intended safety functions. The

inspection activity represented six samples:

Procedure 8.10.1, Refueling Interlocks Functional Test, 4/20/05

Procedure 3.M.3-24.16, Quick look Operations Procedure, for static and dynamic

testing of motor operated valve (MO) MO-1400-25A.

Procedure 8.7.1.6, Local Leak Rate Testing of the Main Steam Isolation Valves.

Procedure 8.7.1.5, Local Leak Rate Testing of Primary Containment Penetrations

and Isolation Valves, for MO-1001-28A.

Procedure 8.M.3-1, Special Test for Automatic ECCS Load Sequencing of Diesels

and Shutdown Transformer with Simulated Loss of Off-Site Power and Special

Shutdown Transformer Load Test.

2.1.8.5 & 2.1.8.3, Class 1 Reactor Pressure Test, 5/9/05.

b.

Findings

No findings of significance were identified.

1R23

Temporary Plant Modifications (71111.23)

a.

Inspection Scope (1 sample)

The inspector reviewed temporary alteration 05-1-026, installed per procedure 3.M.2-

40, Refuel Outage Temporary Alteration Reactor Shutdown/Floodup Level Indicator.

A walkdown was performed to determine whether temporary equipment was installed in

accordance with the work instructions. The inspector reviewed applicable category A

drawings to determine whether they were up-to-date with the temporary alteration.

Alignment data for the temporary indicator and detector was reviewed to determine

whether it was within the established acceptance criteria. The inspector observed the

detectors response to actual reactor level changes.

b.

Findings

No findings of significance were identified.

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Enclosure

Cornerstone: Emergency Preparedness (EP)

1EP2 Alert and Notification System (ANS) Testing (71114.02)

a.

Inspection Scope (1 sample)

An onsite review of Entergys ANS was conducted to ensure prompt notification of the

public for taking protective actions. During the inspection at Pilgrim, the inspector

reviewed the test and maintenance documentation for the siren system. Condition

reports (CRs) generated as a result of siren testing were reviewed for causes, trends

and corrective actions. The inspection was conducted in accordance with NRC

Inspection Procedure 71114, Attachment 02, and the applicable planning standard,

10 CFR 50.47(b)(5) and its related 10 CFR 50, Appendix E requirements were used as

reference criteria.

b.

Findings

No findings of significance were identified.

1EP3 Emergency Response Organization (ERO) Augmentation Testing (71114.03)

1.

Inspection Scope (1 sample)

A review of Pilgrims ERO augmentation staffing requirements and the process for

notifying the ERO was conducted to ensure the readiness of key staff for responding to

an event and timely facility activation. The inspector reviewed procedures and CRs

associated with the ERO notification system and process. The inspection was

conducted in accordance with NRC Inspection Procedure 71114, Attachment 03, and

the applicable planning standard, 10 CFR 50.47(b)(2) and its related 10 CFR 50,

Appendix E requirements were used as reference criteria.

2.

Findings

No findings of significance were identified.

1EP4 Emergency Action Level (EAL) Revision Review (71114.04)

a.

Inspection Scope (1 sample)

Prior to this inspection, the NRC had received and acknowledged the changes made to

the Pilgrim Emergency Plan and implementing procedures. These changes were made

by Entergy in accordance with 10 CFR 50.54(q), after Entergy had determined the

change did not result in a decrease in effectiveness of the Plan and concluded that the

changes continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50. The inspector conducted a sampling review of the changes which could

potentially result in a decrease in effectiveness. This review does not constitute an

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Enclosure

approval of the changes and, as such, the changes are subject to future NRC

inspection. The inspection was conducted in accordance with NRC Inspection

Procedure 71114, Attachment 4, and the applicable requirements in 10 CFR 50.54(q)

were used as reference criteria.

b.

Findings

No findings of significance were identified.

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies (71114.05)

a. Inspection Scope (1 sample)

The inspector reviewed CRs initiated by Pilgrim from drills, tests, and audits and the

associated corrective actions to determine the significance of the issues and to

determine if repeat problems were occurring. A list of the CRs reviewed are contained

in the attachment to this report. Also, the 2003 and 2004 audit reports were reviewed

to assess Pilgrims ability to identify issues, assess repetitive issues and the

effectiveness of corrective actions through their independent audit process. This

inspection was conducted according to NRC Inspection Procedure 71114, Attachment

05, and the applicable planning standard, 10 CFR 50.47(b)(14) and its related 10 CFR 50, Appendix E requirements were used as reference criteria.

b.

Findings

No findings of significance were identified.

2.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety (OS)

2OS1 Access Control to Radiologically Significant Areas (71121.01)

3.

On-site Inspection dates April 25 - 29, 2005

a.

Inspection Scope (7 samples)

The inspector reviewed radiological work activities and practices and procedural

implementation during observations and tours of the facilities and inspected

procedures, records, and other program documents to evaluate the effectiveness of

Pilgrims access controls to radiologically significant areas. This inspection activity

represents the completion of seven samples relative to this inspection area (i.e.,

inspection procedure sections 02.02.a thru d and 02.04.a thru c) in partial fulfillment of

the annual inspection requirements.

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Enclosure

Plant Walkdowns and RWP Reviews (02.02.a thru d)

During the inspection week of April 25, 2005, the Pilgrim plant was in the middle of a

scheduled refueling outage. The inspector reviewed the work activities taking place in

the radiologically controlled area to identify any exposure significant work areas within

radiation areas, high radiation areas (<1 Roentgen/hour), or airborne radioactivity

areas in the plant. For selected exposure significant work areas, the inspector

reviewed associated controls and surveys of those areas to determine if controls (e.g.,

surveys, postings, barricades) were acceptable. When possible, the inspector, with a

survey instrument, walked down those areas or their perimeters to determine whether

prescribed radiation work permits (RWPs), procedures, and engineering controls were

in place, whether surveys and postings were complete and accurate, and whether air

samplers were properly located. The inspector reviewed the radiation work permits

(RWPs)(as listed in the List of Documents Reviewed section) used to access these

and other high radiation areas and identified what work control instructions or control

barriers had been specified. The inspector reviewed electronic-personal-dosimeter

(EPD) alarm set points (both for the integrated dose and for the dose rate) for

conformity with survey indications and plant policy. The inspector contacted workers

to determine whether they knew what actions were required when their EPD

noticeably malfunctions or alarms. Also, the inspector reviewed radiation work permits

(RWPs) to identify any airborne radioactivity areas with the potential for individual

worker internal exposures of greater than 50 millirems (committed effective dose

equivalent). The inspector focused on work areas with a history of, or the potential for,

airborne transuranic radioactivity.

Job-In-Progress Reviews (02.04.a thru c)

During the inspection week of April 25, 2005, the inspector reviewed and observed

work activities on several radiation work permits (RWPs) including Numbers 05-0054,

05-0071, 05-0080, 05-0082, and 05-0101 (as listed in the List of Documents Reviewed

section). The inspector reviewed all radiological job requirements (RWP requirements

and work procedure requirements) and attended the RWP pre-job briefing on April 26,

2005 for the dryer weld repair work. During these reviews, the inspector determined

whether the radiological conditions in the work area were being adequately

communicated to workers through briefings and postings. The inspector reviewed

radiological controls including surveys, radiation protection job coverage,

contamination controls, and consideration of dosimetry in high radiation work areas

with significant dose rate gradients to determine whether they were adequate.

Related Activities

During the inspection week of April 25, 2005, the inspector observed Radiologically-

Controlled Area (RCA) entries and exits being made by radiation workers at the

primary RCA access control point to determine whether they complied with

requirements for RCA entry and exit, wearing of record dosimetry, and issuance and

use of alarming electronic radiation dosimeters. The inspector toured various

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Enclosure

elevations in the drywell and reactor building during this refueling outage to determine

whether the radiological controls being implemented were adequate. The inspector

reviewed observed work activities for compliance with the radiation work permit (RWP)

requirements. During these observations and tours the inspector reviewed, for

regulatory compliance, the posting, labeling, barricading, and level of radiological

access control for locked high radiation areas (LHRAs), high radiation areas (HRAs),

radiation and contamination areas, and radioactive material areas.

The inspector performed a selective examination of documents (as listed in the List of

Documents Reviewed section) to evaluate the adequacy of radiological controls. The

review in this area was against criteria contained in 10 CFR 19.12, 10 CFR 20

(Subparts D, F, G, H, I, and J), Technical Specifications, and procedures.

Identification and Resolution of Problems

During the inspection week of April 25, 2005, the inspector selected fourteen

issues/condition reports (CRs) identified in the Corrective Action Program (CAP) for

detailed review (i.e., CR-PNP-2004-02331, -03585, and -03625 and CR-PNP-2005-

00086, -00810, -00853, -00857, -00930, -01318, -01351, -01367, -01370, -01627, and

-01778). The documented reports for the issues were reviewed to determine whether

the full extent of the issues were identified, appropriate evaluations were performed,

and appropriate corrective actions were specified and prioritized.

b.

Findings

No findings of significance were identified.

4.

On-site Inspection dates June 13 - 16, 2005

a.

Inspection Scope (7 samples)

The inspector reviewed radiological work activities and practices and procedural

implementation during observations and tours of the facilities and inspected

procedures, records, and other program documents to evaluate the effectiveness of

Pilgrims access controls to radiologically significant areas. This inspection activity

represents the completion of seven samples relative to this inspection area (i.e.,

inspection procedure sections 02.02.f, 02.03.a thru d, and 02.05.a and b) in partial

fulfillment of the annual inspection requirements.

Plant Walk Downs and RWP Reviews (02.02.f)

During the inspection week of June 13, 2005, the inspector examined Entergys

physical and programmatic controls for highly activated or contaminated materials

(non-fuel) stored within spent fuel and other storage pools.

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Enclosure

Problem Identification and Resolution (02.03.a, b, c, and d)

During the inspection week of June 13, 2005, the inspector reviewed Entergys self-

assessment activities for any results related to the access control program since the

last inspection. The intent of this review was to determine if identified problems are

entered into the corrective action program for resolution. The inspector also reviewed

corrective action reports related to access controls and included in this review any

high radiation area radiological events that have occurred since the last inspection in

this area. The inspector selected eight CRs identified in the CAP for detailed review

(i.e., CR-PNP-2005-02021, -02151, -02175, -02205, -02221, -02793, -02796, -

02903). The inspector discussed the corrective action reports with several members

of the radiological protection staff to determine whether the follow-up activities were

being conducted in an effective and timely manner commensurate with their

importance to safety and risk. There were no self-assessments, conducted since the

last inspection, which covered health physics access controls directly. Also, there

were no Entergy Performance Indicator events or documentation packages for the

Occupational Exposure Cornerstone which required review.

High Risk Significant, High Dose Rate HRA and VHRA Controls (02.05.a and b)

During the inspection on the week of June 13, 2005, the inspector met at various

times with several radiation protection supervisors and discussed the controls and

procedures for high-dose-rate high radiation areas (HRAs) and for very high radiation

areas (VHRAs). The inspector reviewed the subject procedures (as listed in the List of

Documents Reviewed section) to determine whether the level of worker protection was

adequate.

Related Activities

The inspector performed a selective examination of documents (as listed in the List of

Documents Reviewed section) to evaluate the adequacy of radiological controls. The

review in this area was against criteria contained in 10 CFR 19.12, 10 CFR 20

(Subparts D, F, G, H, I, and J), Technical Specifications, and Entergys procedures.

b.

Findings

No findings of significance were identified.

2OS2 ALARA Planning and Controls (71121.02)

5.

On-site Inspection dates April 25 - 29, 2005

a.

Inspection Scope (3 samples)

The inspector reviewed the effectiveness of Entergys program to maintain

occupational radiation exposure as low as is reasonably achievable (ALARA). This

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Enclosure

inspection activity represents the completion of three samples relative to this

inspection area (i.e., inspection procedure sections 02.01.b, 02.03.b, and 02.04.a.1) in

partial fulfillment of the biennial inspection requirements.

Inspection Planning (02.01.b)

During the inspection week of April 25, 2005, the inspector reviewed the work being

conducted during the current refueling outage (RFO 15). The inspector examined the

outage work scheduled during this inspection period and the associated work activity

exposure estimates and the historical work activity data. The inspector selected work

activities which were likely to result in the highest personnel collective exposures. The

selected work activities/RWPs are described in the List of Documents Reviewed

section.

Verification of Dose Estimates and Exposure Tracking Systems (02.03.b)

The inspector reviewed, during the inspection week of April 25, 2005, Entergys

method for adjusting exposure estimates, or replanning work, when unexpected

changes in scope or emergent work were encountered. The dryer repair evolution

involving diving in the separator/dryer pool was an example of significant emergent

work during this outage. The inspector reviewed in-progress ALARA reviews for

RWPs 05-0054, -0080, -0082, -0099, and -0101 (as listed in the List of Documents

Reviewed section) to determine whether adjustments to estimated exposure (intended

dose) were based on sound radiation protection and ALARA principles and not just

adjusted to account for failures to control the work.

Job Site Inspections and ALARA Control (02.04.a.1)

Based on scheduled work activities during the inspection week of April 25, 2005 and

the associated exposure estimates, the inspector selected work activities in radiation

areas, airborne radioactivity areas, or high radiation areas for observation. The

inspector concentrated on work activities that presented the greatest radiological risk

to workers, for example, the work that was estimated to result in the highest collective

doses, the diving activities to repair the dryer tie-rods, and the under vessel work. The

inspector evaluated Entergys use of ALARA controls for these work activities. The

inspector accomplished this by evaluating Entergys use of engineering controls to

achieve dose reductions and whether the procedures and controls were consistent

with Entergys ALARA reviews.

Related Activities

On April 26, 2005, the inspector observed a pre-job radiological briefing for the diving

evolution to repair the dryer in the separator/dryer pool on the refueling floor of the

reactor building. This briefing included a detailed discussion of the ALARA

recommendations. On April 27, the inspector attended a site ALARA committee

meeting which addressed the dryer repair work activity for which the dose estimate

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Enclosure

was greater than one person-rem. The inspector also noted that the actual outage

dose to date was tracking slightly below the estimated outage dose to date.

The inspector performed a selective examination of documents (as listed in the List of

Documents Reviewed section) for regulatory compliance and for adequacy of control

of radiation exposure. The review was against criteria contained in 10 CFR 20.1101

(Radiation protection programs), 10 CFR 20.1701 (Use of process or other

engineering controls), and procedures.

b.

Findings

No findings of significance were identified.

6.

On-site Inspection dated June 16 - 19, 2005

a.

Inspection Scope (3 samples)

The inspector reviewed the effectiveness of Entergys program to maintain

occupational radiation exposure as low as is reasonably achievable (ALARA). This

inspection activity represents the completion of three samples relative to this

inspection area (i.e., inspection procedure sections 02.02.a, b, and c) in partial

fulfillment of the biennial inspection requirements.

Radiological Work Planning (02.02.a, b, and c)

During the inspection on the week of June 13, 2005, the inspector obtained from

Entergy a list of work activities ranked by actual/estimated exposure that had been

completed during the outage of earlier this year (refueling outage 15) and selected the

three work activities/radiation work permits (RWPs) of highest exposure significance.

These RWPs involved work activities connected with in-service inspection of reactor

vessel nozzles in the drywell, with electrical work on motor-operated valves in the

drywell, and with work activities on the refuel floor connected with reactor disassembly

and reassembly. The inspector reviewed the ALARA work activity evaluations,

exposure estimates, and exposure mitigation requirements to determine whether

Entergy had established procedures, engineering and work controls, based on sound

radiation protection principles, to achieve occupational exposures that were ALARA.

The inspector also reviewed to determine whether Entergy had reasonably grouped

the radiological work into work activities, based on historical precedence, industry

norms, and/or special circumstances. The inspector compared the results achieved

(dose rate reductions, person-rem used) with the intended dose established in

Entergs ALARA planning for these work activities. The inspector reviewed the

reasons for any inconsistencies between intended and actual work activity doses.

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Enclosure

Related Activities

The inspector performed a selective examination of documents (as listed in the List of

Documents Reviewed section) for regulatory compliance and for adequacy of control

of radiation exposure. The review was against criteria contained in 10 CFR 20.1101

(Radiation protection programs), 10 CFR 20.1701 (Use of process or other

engineering controls), and Entergys procedures.

b.

Findings

No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

1.

On-site Inspection dates April 25 - 29, 2005

a.

Inspection Scope (2 samples)

The inspector reviewed the program for health physics instrumentation to determine

the accuracy and operability of the instrumentation. This inspection activity represents

the completion of two samples relative to this inspection area (i.e., inspection

procedure sections 02.04.b and c) in partial fulfillment of the biennial inspection

requirements.

Problem Identification and Resolution (02.04.b and c)

During the inspection week of April 25, 2005, the inspector reviewed corrective action

program reports related to exposure significant radiological incidents that involved

radiation monitoring instrument deficiencies since the last inspection in this area.

During this review, the inspector looked at activities such as problem identification,

characterization, tracking, and the identification and implementation of corrective

actions which would achieve lasting results. The inspector performed this examination

to determine if those activities were being conducted in an effective and timely manner

commensurate with their importance to safety and risk. There were no recent self-

assessment activities which addressed radiation monitoring instrument deficiencies.

Related Activities

During the tours of the drywell and reactor conducted during this inspection week of

April 25, 2005, the inspector examined the calibration status and operability of

selected radiation protection equipment in use in the plant. Also, the inspector

performed a selective examination of documents (as listed in the List of Documents

Reviewed section) for regulatory compliance and adequacy in this area. The review

was against criteria contained in 10 CFR 20.1501, 10 CFR 20 Subpart H, Technical

Specifications, and procedures.

22

Enclosure

b.

Findings

No findings of significance were identified.

2.

On-site Inspection June 13 - 16, 2005

a.

Inspection Scope (2 samples)

The inspector reviewed the program for health physics instrumentation and protective

equipment to determine the accuracy and operability of the instrumentation and of the

equipment. This inspection activity represents the completion of two samples relative

to this inspection area (i.e., inspection procedure sections 02.06.a and b) in complete

fulfillment of the biennial inspection requirements.

Self-Contained Breathing Apparatus (SCBA) Maintenance and User Training (02.06.a

and b)

During the inspection on the week of June 13, 2005, the inspector reviewed the status

and surveillance records of SCBA staged and ready for use in the plant against

procedural requirements. The inspector also examined Entergys capability for refilling

and transporting SCBA air bottles to and from the control room and operations support

center during emergency conditions. Additionally, the inspector evaluated whether

control room operators and other emergency response and radiation protection

personnel were trained and qualified in the use of SCBA (including personal bottle

change-out). Additionally, the inspector reviewed whether only personnel who

possess manufacturer-certified training/qualifications were allowed to perform

maintenance and repairs on SCBA components vital to the units function. Entergy

stated that all maintenance and repairs on SCBA components vital to the units

function were performed by a vendor. Entergy provided documentation from the

SCBA manufacturer stating that the subject vendor was an authorized distributor and

service center for their SCBAs. The inspector reviewed available vital component

maintenance records for three SCBA units currently designated as ready for service.

Also, the inspector reviewed the records used to ensure that the required, periodic air

cylinder hydrostatic testing was documented and up to date and that the DOT-

required-retest air cylinder markings were in place.

Related Activities

During the tours of the reactor and radioactive waste buildings conducted during the

inspection week of June 13, 2005, the inspector examined the calibration status and

operability of selected radiation protection equipment in use in the plant. Also, the

inspector performed a selective examination of documents (as listed in the List of

Documents Reviewed section) for regulatory compliance and adequacy in this area.

The review was against criteria contained in 10 CFR 20.1501, 10 CFR 20 Subpart H,

Technical Specifications, and Entergys procedures.

23

Enclosure

b.

Findings

No findings of significance were identified.

4.

OTHER ACTIVITIES [OA]

4OA1 Performance Indicator (PI) Verification (71151)

a.

Inspection Scope (3 samples)

The inspector reviewed Entergys procedure for developing the data for the EP PIs

which are: (1) Drill and Exercise Performance (DEP); (2) ERO Drill Participation; and

(3) ANS Reliability. The inspector also reviewed Entergys drill/exercise reports,

training records and ANS testing data to verify the accuracy of the reported data.

Data generated since the April 2004 EP PI verification was reviewed during this

inspection. Therefore, data from the second, third and fourth quarters of 2004 and the

first quarter of 2005 were reviewed. The review was conducted in accordance with

NRC Inspection Procedure 71151. The acceptance criteria used for the review were

10 CFR 50.9 and NEI 99-02, Revision 1, Regulation Assessment Performance

Indicator Guideline.

b.

Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152)

1.

Routine Review of Corrective Action Program Issues

a.

Inspection Scope

As required by Inspection Procedure 71152, Identification and Resolution of

Problems, the inspector performed a screening of each item entered into Entergys

corrective action program. This review was accomplished by reviewing printouts of

each condition report, attending daily screening meetings and/or accessing Entergys

database. The purpose of this review was to identify conditions such as repetitive

equipment failures or human performance issues that might warrant additional follow-

up.

b.

Findings

No findings of significance were identified.

24

Enclosure

2.

Corrective Action Program Semi-annual Trend Review

a.

Inspection Scope

As required by Inspection Procedure 71152, Identification and Resolution of

Problems, the inspector performed the semi-annual trend review to identify trends,

either Entergy or NRC identified, that might indicate the existence of a more significant

safety issue. Included within the scope of this review were condition reports from June

2004 - June 2005, the 3rd and 4th quarter 2004 corrective action trend reports, and the

daily plant status report listings of operations equipment problems, operability

evaluations, and temporary alterations.

b.

Findings

No findings of significance were identified. No trends were noted which suggests the

presence of a more significant safety issue. The majority of the repetitive issues /

trends identified by the inspector had also been recognized by Entergy and were

captured in adverse trend CRs, including an emerging adverse trend in emergency

diesel generator performance (CR 2005-1058) that is currently being evaluated by

Entergy. Two trends noted by the inspector not captured in an adverse trend CR were

related to tracking and maintaining current required personnel qualifications and

observing scaffolding requirements.

4OA3 Event Follow-up (71153)

1.

Licensee Event Report Review and Closeout (2 samples)

a.

(Closed) LER 05000293/2005-01, High Pressure Coolant Injection System Inoperable

due to Fuse Failure in Valve Control Circuit. The inspector reviewed Entergys actions

associated with Licensee Event Report (LER) 50-293/2005-01. Entergys actions were

addressed in the corrective action program as Condition Report 20050517. This event

was similar to the events reported in LERs 2004-02 and 2002-01. The event was also

described in NRC Report 2005-006 for which a Green NCV was identified. The

inspector reviewed Entergys actions to inspect and replace potentially susceptible

fuses of the type caused the event. The LER provided an accurate description of the

event and followup actions, taken or planned, were appropriate to address the event

cause. This LER is closed.

b.

(Closed) LER 05000293/2005-02, One Less Than the Technical Specification

Required Minimum Number of Operable Drywell Pressure Channels due to Licensed

Operator Error. The inspector reviewed Entergys actions associated with Licensee

Event Report (LER) 50-293/2005-02. Entergys actions were addressed in the

corrective action program as Condition Reports 2005-1439 and 200502800. The

inspector reviewed actions to restore the channel to an operable status, assure other

channels remained operable, and to address human performance errors. The LER

provided an accurate description of the event and followup actions, taken or planned,

25

Enclosure

were appropriate to address the event cause. This licensee identified finding involved

a violation of TS 3.2.B Instrumentation that Initiates or Control the Core and

Containment Cooling Systems. The enforcement aspects of the violation are

discussed in Section 4OA7. This LER is closed.

4OA5 Other

1.

TI 2515/163, Operational Readiness of Offsite Power

The inspector performed Temporary Instruction 2515/163, Operational Readiness of

Offsite Power. The inspector collected and reviewed Entergys procedures and

supporting information pertaining to the offsite power system specifically relating to the

areas of offsite power operability, the maintenance rule (10 CFR 50.65), and the

station blackout rule (10 CFR 50.63). The inspector reviewed Entergys training in the

procedures related to offsite power and observed a joint training session between the

Pilgrim Station and the Transmission System operators on June 8, 2005. The

inspector reviewed this data against the requirements of 10 CFR 50.63; 10 CFR 50.65; 10 CFR 50 Appendix A General Design Criterion 17, Electric Power Systems;

and Plant Technical Specifications. This information was forwarded to NRR for further

review.

2.

TI 2515/161 - Transportation of reactor control rod drives in Type A packages

During the inspection week of June 13, 2005, this area was inspected to verify that

Entergys radioactive material transportation program complied with specific

requirements of 10 CFR Parts 20 and 71, and Department of Transportation (DOT)

regulations contained in 49 CFR Part 173. The inspector interviewed Entergy

personnel and determined that entergy had undergone refueling/defueling activities

twice since January 1, 2002. Entergy made five shipments of reactor control rod

drives in Department of Transportation Specification 7A Type A packages during this

time period. The inspector reviewed the documentation for each of these shipments.

No findings of significance were identified.

3.

Closed URI 05000293/2004005-02: Operator Inattentiveness in the Control Room

In a letter (ADAMS accession number: ml051960068) dated July 14, 2005, the NRC

issued a Severity Level III Notice of Violation and Proposed Imposition of Civil Penalty

to Entergy in the base amount of $60,000 associated with a Severity Level III problem.

The Severity Level III problem involved four violations of NRC requirements related to

Technical Specification 5.4.1, 10 CFR Part 50 Appendix B, and 10 CFR Part 26. The

specific violations involved: (1) a Pilgrim control room supervisor sleeping for

approximately four minutes in the control room and therefore being neither alert or

attentive to his duties; (2) a reactor operator observing the sleeping control room

supervisor, but deliberately not taking immediate actions to awaken the control room

supervisor, inform appropriate site personnel and initiate a condition report; (3) a Shift

Manager, in careless disregard of requirements, although taking some actions, not

26

Enclosure

informing appropriate site personnel and initiating a condition report; and (4) the

sleeping control room supervisor not being relieved of duty and for-cause Fitness-for-

Duty tested. VIO 05000293/2005003-002, Inattentive Control Room Supervisor

with Wilfull Inappropriate Response by Other Control Room Licensed Staff .

There were no actual safety consequences resulting from this event because there

were no plant conditions that warranted immediate action.

This Severity Level III Notice of violation closes out the unresolved item (URI

05000293/2004005-02) associated with operator Inattentiveness in the control room.

4.

Review of Third Party Assessment Reports

The inspector reviewed the results of the Pilgrim Plant Evaluation conducted by the

World Association of Nuclear Operators (WANO) in February 2005. The inspector

noted that the WANO assessment results were consistent with the NRC's assessment

of Pilgrim activities.

4OA6 Meetings, Including Exit

On April 29, 2005, the inspector presented the inspection results to Mr. P. Dietrich,

General Manager-Plant Operations, and other members of his staff who

acknowledged the inspection results.

On June 13, 2005, the inspector presented the inspection results to Mr. S. Bethay,

Safety Assessment Director, and other members of the site staff who acknowledged

the inspection results.

On June 23, 2005, the inspectors presented the inspection results to Mr. Robert

Smith, Engineering Director, and other members of Entergy management who

acknowledged the inspection results and confirmed the information reviewed by the

inspectors was not considered proprietary.

On June 24, 2005, the inspector presented the inspection results to Mr. Brian Ford,

Licensing Manager, and other members of his staff. Entergy had no objections to the

NRCs observations. The inspector confirmed that proprietary information was not

provided or examined during the inspection.

On July 7, 2005, the inspector presented the inspection results to Mr. T. Kirwin, Plant

Production Manager, and other members of the site staff who acknowledged the

inspection results. The inspector confirmed that proprietary information was not

provided or examined during the inspection.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by

Entergy and are a violation of NRC requirements which met the criteria of Section VI

27

Enclosure

of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a Non-Cited

Violation.

1.

Technical Specification (TS) 3.2.B requires two operable instrument channels per trip

system of drywell pressure instrumentation that initiate the core and containment

cooling system. If one channel of a trip system is inoperable, then the TS requires

Entergy to repair the trip system or place the reactor in a Cold Shutdown Condition

within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after this trip system is made or found to be inoperable. Contrary to

the above during plant operations at 87% full power on April 14, 2005, a licensed

operator made drywell pressure transmitter PT-1001-89B inoperable when he

inadvertently closed its isolation valve during a valving operation on the CRD backfill

system. This caused one of the two division B drywell pressure instrument channels

to be inoperable. On April 16, Entergy restored PT-1001-89B to an operable

condition. PT-1001-89B was out of service for a total of 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br /> and the reactor was

not placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the pressure instrument

channel was made inoperable. This finding is of very low safety significance because

during the time PT-1001-89B was isolated, the other drywell pressure instruments

were operable and would have actuated the emergency core cooling, containment

isolation and diesel generator initiation circuits in response to a high drywell pressure

condition. Entergy documented this issue in the corrective action program in CRs

200501439 and 200502800.

2.

Technical Specification 5.4.1 requires written procedures be established and

implemented. Contrary to the above on June 1, 2005, Entergys procedure for

calibrating emergency diesel generator (EDG) B control relays were not adequately

established and implemented and resulted in a wiring error on a capacitor in the

monitoring circuit for Breaker 52-609, that impacted the availability of the EDG. The

calibration procedure, 3.M.3-1, did not refer to the capacitor even though it had to be

removed to bench calibrate the relay. Work practices were inadequate because

procedure 3.M.3-51 was not used to document lifting the capacitor leads. The faulty

wiring was not identified due to an inadequate post-maintenance testing. Entergy

discovered the error during EDG surveillance testing on June 27, 2005, and required

additional EDG unavailability time to repair the wiring error. This finding is of very low

safety significance because the error affected the alarm circuit only and there was no

impact on EDG function. Entergy documented this issue in the corrective action

program in CR 200503183.

3.

Technical Specification 5.4.1 requires in part that written procedures be established

and implemented covering the activities recommended in Regulatory Guide 1.33,

Revision 2. Contrary to the above, on October 22, 2004, Entergy found valve 30-HO-

43 one-quarter turn open vs closed, as required by procedure 2.2.30, Reactor Building

Closed Cooling Water (RBCCW) System. The incorrect RBCCW valve position

resulted in a 3 gallon per minute leak thru vent valve 30-HO-43 and the A train of

RBCCW to be inoperable for approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> until the vent valve was closed.

The train was inoperable because of the inability to fulfill its thirty-day mission time

without the need to refill the expansion tank. The finding is of very low safety

significance because the condition did not exceed half of the allowable Limiting

28

Enclosure

Condition for Operation (LCO) time. Entergy documented this issue in the corrective

action program in CR 200503265.

4.

Technical Specification 5.4.1 requires in part that written procedures be established

and implemented covering the activities recommended in Regulatory Guide 1.33,

Revision 2. Contrary to the above, on March 28, 2005, Entergy personnel did not

follow procedure 8.7.1.19, Pressure Drop Test of Air Supply for Standby Gas

Treatment (SBGT) System Dampers. Specifically, Entergy personnel did not make

periodic projections to predict whether the final leak rate results would be acceptable

nor did they calculate the final results and compare them to the acceptance criteria

prior to securing from Attachment 1 of the test. As a result, Entergy did not recognize

on March 28 that the B train of SBGT was inoperable due to air system leakage.

Entergy recognized on March 29 that the B train was inoperable. Entry into a Limiting

Condition for Operation (LCO) and mitigative actions to place the system in a fail-safe

configuration were therefore unnecessarily delayed. The finding is of very low safety

significance because the condition did not exceed half of the allowable LCO time.

Entergy documented this issue in the corrective action program in CR 200501130.

ATTACHMENT: SUPPLEMENTAL INFORMATION

A-1

Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy personnel:

M. Balduzzi

Site Vice President

S. Bethay

Nuclear Assessment Director

P. Dietrich

Plant Manager

J. Detwiler

Radiation Protection Technician

R. Emmitt

Radiation Protection Specialist (Support)

B. Ford

Licensing Manager

L. Foreaker

Radiological Instruments Supervisor

W. Grieves

Quality Assurance Superintendent

T. Kirwin

Plant Production Manager

K. Larson-Sullivan

Sr. Emergency Planner

B. McDonald

Radiation Protection Specialist (Support)

P. McNulty

Radiation Protection Manager

B. Reynolds

Administrative Specialist

E. Salomon

Sr. Emergency Planner

L. Seehaus

Radiation Protection Technician

T. Sowdon

Emergency Planning Manager

B. Sullivan

Operations Superintendent

P. Sullivan

Sr. Emergency Planner

T. Tetzlaff

Radiation Protection Supervisor

J. Veglia

Programs & Components Manager

T. White

Design Control Manager

S. Wilson

Facilities and Equipment Specialist

G. Zavaski

Radiation Protection Specialist (Projects)

R. Blagborough

Senior Engineer

T. Collis

System Engineer

S. Das

Senior Lead Engineer

J. Falconieri

Senior Engineer

H. Goettsch

Senior Component Engineer

J. Keen

System Engineer

D. Mahesh

Senior Component Engineer

D. Sitkowski

Senior Engineer

R. Smith

Engineering Director

D. Titus

Senior Engineer

J. Yingling

Senior Engineer

D. Young

Senior Engineer

S. Woods

Structural Engineer

A-2

Attachment

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened

05000293/2005003-01

URI

Adequacy of Entergys Change to LOP/LOCA Testing

Without Seeking a TS Amendment. (Section 1R02)05000293/2005003-002

VIO

Inattentive Control Room Supervisor with Willful

Inappropriate Response by Other Control Room Licensed

Staff .

Closed

05000293/2004005-02

URI

Operator Inattentiveness in the Control Room

05000293/2005-01 LER High Pressure Coolant Injection System Inoperable due

to Fuse Failure in Valve Control Circuit.

05000293/2005-02 LER

One Less Than the Technical Specification Required

Minimum Number of Operable Drywell Pressure

Channels due to Licensed Operator Error

LIST OF DOCUMENTS REVIEWED

`

References for Sections 1R02 and 1R17

10 CFR 50.59 Applicability Determinations

SEE 1083, Safety Relief Valve O-Ring Seat Equivalency Evaluation, dated 7/17/03

PDC 03-51, 480 VAC Power from B35 Made Permanent, dated 7/23/03

10 CFR 50.59 Screened-out Evaluations

PDC 03-101, Replacement motor for Control Room Recirc Fan, VRF-101B

PDC 03-58, Replace Unit Auxiliary Transformer

PDC 03-090, ATWS Power Supply PS1A Replacement

ER 03105182, EDG, Install Load Shed Switches C6, B17, B18

PDC 03-76, Reactor Recirc Pump Leak Sealant Injection

SEE 1130, Equivalency Evaluation for UPS B44 AC Voltmeter (UPS Output) Selector Switch

Electro Switch Model PR10-910C8-6, Rev. 0

SEE 1030, Equivalency Evaluation for ASCO Solenoid Valve NP 831664E, Rev. 0

TA 04-1-032, Mechanical Gag to Open Reactor Building Exhaust Backdraft Dampers

SEE 1124, Lower Diaphragm Plate (Button), HCU Scram Actuators, P/N 213A8821P35 or

80025A (Scram Isolation Valves), Rev. 0

8.M.3-1, Special Test for Automatic ECCS Load Sequencing of Diesels and Shutdown

Transformer with Simulated Loss of Offsite Power and Special Shutdown Transformer

Load Test, dated 3/10/05

ER 03114086, MOV Modifications, Rev. 0

A-3

Attachment

PDC 03-059, Modification of Supports on the A EDG Air Start 2" Piping at Valves SV-4586

A/B, dated 7/18/03

New Procedure 7.4.64, Process Radiation Monitor Alarm Response, Rev. 0

Audits and Self-Assessments

Assessment Report, Assess the Quality of the Plant Design Changes, Temporary Modification

and Alteration Process at Pilgrim Station, dated 8/15/03

Calculations

PS79, Emergency Diesel Generator Loading, Rev. 5

PS234, Calculations - Scenarios & Load Categories, dated 8/25/99

PS95, Change No. 5, Rev. 2, dated 8/7/03

PS65, Change No. PS65-1-14, Rev. 1, dated 8/25/03

PS65A, Change No. PS65A-0-19, Rev. 0, dated 8/25/03

Calculation No. M1265, Effect of the Removal of the Biological Shield Blocks on the

Containment Temperatures, Rev. 0

PNPS-1-ERHS-XXII.A-2, Radiological of a Design Basis Fuel Handling Accident Using the

Alternate Source Term, Rev. 1

Completed Surveillances

Procedure No. 8.E.29.1, Salt Service Water (SSW) Instrumentation Calibration and Functional

Test, Attachment 2 & 4, dated 9/10/03

Procedure No. 8.E.29.1, Salt Service Water (SSW) Instrumentation Calibration and Functional

Test, Attachment 4, dated 10/12/04

Procedure No. 8.E.30.1, Closed Cooling Water System (CCWS) Instrumentation Calibration

and Functional Test, Attachment 1, dated 7/16/03

Procedure No. 3.M.3-47, Load Shed Relay Operational/Functional Test, Attachment 2, dated

10/18/03

Procedure No. 8.M.3-1, Special Test for Automatic ECCS Load Sequencing of Diesels and

Shutdown Transformer with Simulated Loss of Offsite Power and Special Shutdown

Transformer Load Test, dated 5/9/03 & 4/28/05

Procedure No. 3.M.3-47.2, B Train Functional Test of Individual Load Shed Components,

Attachment 8-9-10, dated 6/11/03

Procedure No. 3.M.3-47.2, B Train Functional Test of Individual Load Shed Components,

Attachment 11, dated 10/7/03

Procedure No. 7.1.30, HEPA Filter and Charcoal Cell Performance Test Program, dated

8/11/04 & 9/24/04

Procedure No. 7.1.44, Sampling of Charcoal Cells in Standby Gas Treatment and Control

Room Environmental Filters Systems for Methyl Iodide Testing, dated 8/10/04 &

9/29/04

Procedure No. 8.7.2.7, Measure Flow and Pressure Drop Across Control Room High Efficiency

Air Filtration System (CRHEAFS), dated 8/11/04 & 9/29/04

Procedure No. 8.5.3.2.1, Salt Service Water Pump Quarterly and Biennial (Comprehensive)

Operability and Valve Operability Tests, dated 9/24/04

A-4

Attachment

Corrective Action Reports

2003-00045

2003-02617

2003-02679

2003-03402

2003-03403

2003-03825

2004-00269

2004-00329

2004-00352

2004-00390

2004-00552

2004-00639

2004-00834

2004-00971

2004-01107

2004-01849

2004-02455

2004-02484

2004-02753

2004-02754

2004-02889

2004-03657

2004-03664

2004-03822

2005-00232

2005-03093

2005-03130

2005-03112

2005-03114

2005-03115

2005-03116

2005-03117

2005-03118

Drawings

E-18, Schematic Diagram Diesel Generator Load Shedding, Rev. E-18

E-173, Schematic Diagram Cooling Water System Turbine Building, Rev. E-4

E52A1, Outline and Dimension Salt Service Pump Motor, Rev. E2

41100-0428, Schematic Drawing Diesel Generator Load Shedding, Rev. E18

E176, Schematic Diagram - Reactor BLDG Closed Cooling Water System, Sh. 1, Rev. E8,

A-14, Turbine Auxiliary & Control BLDG Service Area EL +37'-0", Rev. E7

M8-4, Assembly Drawing Service Water Pump P208A, B, C, D, E; Rev. E19

M8-27, Service Water Pump (P-208A-E) Motor Base, Rev. A

Evaluations

SEE 1089, Controlled Document Change Notice 03-1583

SEE 718, Air Operated Manifold On Main Steam Isolation Valves, AO-203-1A, B, C & D

SEE 1087, Rosemount Master Trip Units

SEE-1092, Robertshaw Pressure Indicators PI-5001 A, B

ER 03120866, Permanent Removal of Drywell Shield Blocks, Rev. 0

SE 2619, Perform Patching and Painting on Panels and Consoles in Main Control

Room During Power Operations, dated 7/26/91

Miscellaneous

Risk-Informed Inspection Notebook For Pilgrim Nuclear Power Station Unit 1, Rev. 1

Regulatory Guide 1.186, Guidance and Examples for Identifying 10 CFR 50.2 Design Bases

NEI 96-07, Guidelines For 10 CFR 50.59 Implementation, Rev. 1

NEI 97-04, Design Basis Program Guidelines, Rev. 1

SDBD-61, System Design Basis Document for the Emergency Diesel Generator (EDG) and

Auxiliary Systems, Rev. E0, dated 10/18/00

SBDB-30B, Design Basis Document for the Turbine Building Closed Cooling Water System,

Rev. E0

ER 03105182; Addition of Test Switches to Load Shed Relays 105XA1, 105XA2 & 105XB2

ER 04114484; Reverse PDC 03-70 and Provide New Cable Types for Signal and HV Cables of

RM-1705-3A

A500024, Simulator Change Evaluation for ER 02116887, dated 5/9/05

LCS Test Report 0100417; Automatic Valve, Vibration Test, Model B5140-202, dated 9/17/01

Transformer Test Report No. R-3185, Replacement Unit Auxiliary Transformer, dated 8/11/03

TR62729-05N, Dedication/Qualification Test Report Meter Device TS P/N 233-3265, Rev. 0

A-5

Attachment

Supplier Design Document Review Form 9324-02, SUDDSRF #03-81 - Test of ATWS Power

Supply, Rev. 1, dated 10/2/03

Modification Closeout Report, PDC 03-76, Reactor Recirc Pump Leak Sealant Injection

Modification Closeout Report, PDC 03-021, Weld Repair and/or Epoxy Repair to TBCCW Heat

Exchanger E-122A

Control Room Logs, dated 6/16/03 - 8/13/03

LI-101 50.59 Program Information update and Lessons Learned, dated 7/7/04

Entergy Letter No. 2.04.115, Proposed License Amendment for a Limited Scope Application of

the Alternate Source Term (NUREG-1465) for Re-evaluation of the Fuel Handling

Accident Dose Consequences, Rev.1, dated 12/15/04

RTYPE E2.15, Maintenance Rule SSC Basis Document Manual, Rev. 5

Modifications

PDC 03-058, Replace Unit Auxiliary Transformer

ER 02116887, Reduce EDG Loading During Load Shed

PDC 03-021,Weld Repair and/or Epoxy Repair to TBCCW Heat Exchanger E-122A

FRN 03-13-01, Allow Threaded Connections Associated with X-141 Seal Oil Unit (PDC 03-13,

Replacement of Level Switch 63-L10)

PDC 02-44, Improving Performance of Control Room Envelope

FRN No. 99-01-10, Salt Service Water Pump/Motor Bases

Operating Experience

NRC Information Notice 98-22: Deficiencies Identified During NRC Design Inspections

GE Operating Experience Report (OER Ref. No. 1032), Biological Shield Plugs, dated 5/31/73

Entergy Response to NRC Information Notice 98-22, dated 6/25/98

Procedures

ENN-LI-100, Process Applicability Determination, Rev. 5

ENN-LI-101,10CFR50.59 Review Process, Rev. 7

ENN-DC-102, Operating Plant Changes and Modification, Rev. 1

ENN-DC-103, Design Process, Rev. 1

ENN-DC-105, Configuration Management, Rev. 1

ENN-DC-115, ER Response Development, Rev. 4

ENN-DC-116, ER Response Installation, Rev. 4

ENN-DC-117, Post Modification Testing and Special Testing Instructions, Rev. 4

ENN-DC-118, ER Response Closure, Rev. 4

ENN-DC-121, Maintenance Rule, Rev. 2

ENN-DC-171, Maintenance Rule Monitoring, Rev. 2

Procedure No. 1.4.75, Infrequently Performed Tests and Evolutions, Rev. 0

Temporary Test Procedure No. TP04-011, Functional Test of Load Shed Modifications to

TBCCW Pumps P-110A and B, completed 10/26/04.

Procedure No. 8.M.3-1, Special Test For Automatic Load Sequencing of Diesels And

Shutdown Transformer With Simulated Loss of Off Site Power and Shutdown

Transformer Load Test, completed 5/8/05

Procedure No. 8.E.30.1, Closed Cooling Water System (CCWS) Instrumentation Calibration

And Functional Test, completed 7/22/03

A-6

Attachment

Procedure No. 3.M.4-14.2, Salt Service Water Pumps Routine Maintenance, completed

9/22/04

Procedure No. 3.M.1-15, Vibration Monitoring for Preventive Maintenance and Balancing,

completed 9/22/04

Procedure No. NE6.02; Control of Drawings, Sketches, and Data Sheets, Rev. 35

Procedure No. 7.4.64, Process Radiation Monitor Alarm Response, Rev. 0

Safety Evaluations

SE 3400, New APRM FCTR Setpoints For Stability Option 1-D

SE 3398, Incorporate the term Operation with the Potential To Drain the Reactor Vessel

(OPDRV) in the UFSAR Section 1.2.

SE 3397, Cycle 15 Reload Core Design, Rev. 0

SE 3401, Evaluation to Identify The Design Basis for Salt Service Water

Pump Intake Water Level Requirements to Ensure Adequate Protection of System

Design Basis Requirements is Provided, Rev. 0

SE 3399, Permanent Removal of Drywell Shield Blocks, Rev. 0

SE 3397, Cycle 15 Reload Core Design with Revised Reference Loading Pattern, Rev. 1

Safety Review Committee (SRC) and On Site Review Committee (OSRC)

SRC OSRC Subcommittee Meeting Minutes dated 11/21/03, 2/12/04, 10/28/04, 4/12/05

OSRC Meeting Minutes dated 2/11/05, 4/4/05, 5/7/05

System Health Reports and Trending Data

Pilgrim Nuclear Power Station System Health Report, 4th Quarter 2004

EDG & Fuel Storage System Health Report, 4th Quarter 2004

Work Orders (MRs)

P9900631

02118469

03102361

03110734

03111257

References for Section 1R04

M241, Residual Heat Removal System, Sheet 1&2

2.2.19.1, Residual Heat Removal System - Shutdown Cooling Mode of Operation

M231, Fuel Pool Cooling & Demineralizer system,

2.2.85.1, Augmented Fuel Pool Cooling (With Shutdown Cooling) Mode 1

2.2.85.2, Augmented Fuel Pool Cooling (Without Shutdown Cooling) Mode 2

2.1.1, Startup From Shutdown

M242, Core Spray System

2.2.20, Core Spray System

M215, Reactor Building Closed Loop Cooling Water System, Sheets 1,2&3

2.2.30, Reactor Building Closed Loop Cooling Water System

References for Section 1R05

5.5.2, Special Fire Procedure

A-7

Attachment

Pilgrim Nuclear Power Station Fire Hazards Analysis

A319, Reactor & Turbine Building Floor Plan El. 51' - 0" & 74' - 3" Fire Barrier System

References for Section 1R08

PIL-R15-05-032, Examination summary sheet for UT of Merid Head Weld RPV-TH-M4

including sizing data and indication evaluation

PIL-R15-05-033, Examination summary sheet fo UT of RPV-TH-M5 weld including sizing data

and indication evaluation

PIL-R15-05-001 UT Examination summary sheets (UT-011, 012, 023 and 024) for Vessel

head to flange weld RPV-HF-240-360

PIL-R15-05-001 Magnetic Particle examination report (MT-001) for RPV-HF-240-360

IR 03-0145, Ultrasonic Examinations of the torus shell

NDE-10.02 R0, VT-2 Examination of annulus drains (IWE exam)

IR 03-0283, VT-3 Examination - IWE general visual walkdown

VT-50-05001 thru VT-3, Examination of containment and support surfaces 50-05009

05-M-307-ISI, MT examination of weld GB-14-VBWJ36A-1

05-M-308-ISI, MT examination of weld GB-14-VBW36A-2

05-M-323-ISI, MT examination of weld HL-23-4-1B

UT-038, UT calibration and examination record for procedure TP04-032

UT-039, UT calibration and examination record for procedure TP04-032

UT-001, 002, UT calibration and examination record for procedure ENN-NDE-9.11

015 & 016

UT-011, 012,UT calibration and examination record for procedure TP04-019

023 & 024

2.1.8.7, ASME Visual Examination of Primary Containment

ENN-NDE-9.31, Magnetic Particle Testing

ENN-NDE-10.02 R0, VT-2 ASME Section XI VT-2 examination of components

ENN-NDE-9.10 R0, UT of dissimilar metal piping welds (ASME XI)

ENN-NDE-9.11 R0, Manual UT of RPV welds (ASME XI)

TP04-014, Invessel Visual Inspection of BWR 3 RPV Internals

MR 05108176, Replace socket weld B-11-79 in SBLC system

ENN-DC-126, Evaluation of embedded flaw in N2F nozzle

PNPS-21Q-310, Wall thickness evaluation for Recirc inlet nozzle N2

1272 Calculation for Recirc inlet nozzle N2

CR-2005-01914, UT of socket weld revealed lack of fusion at weld root location

CR-2005-01888, Jet Pump Wedges #16 and 17 are in the full down position

CR-2005-01890, Metallic debris found in RPV annulus on shroud support ledge

CR-2005-01608, Four tie bars at top of steam dryer noted to be cracked (3, 4, 5 and 9)

CR-2005-01895, Nozzle N2G and N2J weld surface profile conditions

CR-2005-01827, Nozzle N2G weld crown surface conditions

CR-2005-01830, Nozzle N2J wall thickness and weld surface condition

CR-2005-01837, Loose insulation during nozzle work inside the drywell

CR-2005-01860, Unsecured insulation during drywell work

CR-2005-01870, Indication in top head meridional weld RPV-TH-M4

CR-2005-01871, Indication in top head meridional weld RPV-TH-M5

CR-2003-01095, Reduced wall thickness identified at some locations of torus shell

CR-2005-01368, Correction to frequency for refuel floor liner drains

A-8

Attachment

CR-2005-01657, Reduced wall thickness measured on nozzle N2E

CR-2003-01618, IWE containment examination identified some coating failure

CR-2005-01980, Loose nuts/studs on pressure relief valves of personnel air lock

CR-2005-01916, Indication identified in N2F nozzle to safe end weld

CR-2005-02322, Socket weld B-11-79 requires additional evaluation

CR-2005-01770, UT thickness readings on 2R-N2G-1 noted two areas below min wall

INR 015-05-01 R1, Steam dryer tie bars 3, 4, 5 and 9

INR 015-05-02, Steam dryer leveling screws, comparison with exam in 2003

JXEF4-04 RA, Steam dryer repair instructions (tie bar replacement)

JXEF4-07 RB, Revised steam dryer repair instructions (tie bar replacement)

ENN-DC-115 R4, Process for development of engineering requests response

OEN-2005-00110, Tee quencher bolting, moisture separator and decon line leakage

NE15.14, IWE Containment Inspection Program

References for Section 1R11

LORT Training Module #O-RQ-06-02-102, Loss of Feed Water Heating Heater Tube Leak

Procedure 2.1.144, Degraded Voltage

Procedure 2.1.6, Reactor Trip

EOP-1, RPV Control

Procedure 2.4.150, Loss of Feedwater Heating

Procedure 2.2.152, Feedwater Heater, Extraction Steam, and Heater Drains

Procedure 2.1.14, Station Power Changes

Procedure 2.4.49, Feedwater Malfunction

2.4.16, Distribution Alignment Electrical system Malfunction

References for Section 1R15

OE and REO CR 200501136, Potential Safety Limit Violation for Analyzed Operational

Occurrences (GE Part 21 Report SC05-03)

GE Part 21 Report SC05-03 dated March 29, 2005

Condition Report CR-WPO-2005-0071

Condition Reports 200503168, 200503140, 200503151

MR 05109337, Potential Fuse Failure Alarm During B EDG Test Run

Drawings 41100-0443, 41200-3127 and 41100-0427

Procedure 2.2.8, Standby AC Power Systems (Diesel Generators)

2.2.108, Diesel Generator Cooling and Ventilation System

Calculations M991, X-107A/B High Temperature Design Limit

Technical Specifications 3.5.F.1 and 3.9.B.3

UFSAR Sections 8.3 and 8.5

EN#41799, Both Emergency Diesel Generators Inoperable

10 CFR 50.72 (b)(3)

References for Section 1R16

Procedure 1.3.34.4, Compensatory Measures (CM)

Operator Compensatory Measure Log

CM Evaluation #314, 341, 342, 345, 349, 350, 351, 352, 354, 356, 357, 358, 359, 360, 361

Maintenance Request 04105084, Clean & Inspect ACB 102 Insulator Bushings

Condition Reports 200500826, 200501192, 200501482, 200502888, 200503034, 200503142

A-9

Attachment

ENN-LI-100, Att 9.1, SE Screen for CM #349, 4/14/05

ENN-LI-101, Att 9.1, 5059 Screen for CM #349, 4/20/05

References for Section 1R20

3.M.1-45, Outage Shutdown Risk Assessment

RFO 15 Shutdown Risk Review Report

TP05-002, RFO15 Compensatory Measures

Power Maneuvering Plan PMP-MAN.C15-39

2.1.5, Controlled Shutdown from Power, Rev 89

2.2.19.1, Residual Heat Removal System - Shutdown Cooling Mode of Operation (Rev.13)

2.1.7, Vessel Heatup and Cooldown (Rev 46)

2.4.25, Loss of Shutdown Cooling (Rev 27)

2.2.93, Main Condenser Vacuum System, Rev 50

4.3, Fuel Handling, Rev 99

4.5, Reactor Core Fuel Verification, Rev 19

LCO-1-05-0044, Inoperable Rod Worth Minimizer

LCO-OUT-1-05-0014 and LCO-ACT-1-05-084 for Standby Liquid Control

LCO-OUT-1-05-0075 for Structural Integrity of Primary System Boundary

OPER-07, RPV metal Temperatures and Pressures, 4/18/05

OPER-13, Daily Refueling Checklist

OPER-14, Shift Refueling Checklist

OPER-25, Fuel Movement Within the Spent Fuel Pool Checklist

2.4.31, Reactor Basin an/or Spent Fuel Pool Draindown

2.2.85.1, Augmented Fuel Pool Cooling (With Shutdown Cooling) Mode 1 (Rev 6)

Technical Specification 3.10.A and 4.10 A, Refueling Interlocks

Technical Specification 3.10.B, Core Monitoring

UFSAR Section 7.5.4, Source Range Monitoring

UFSAR Section 7.6, Refuelng Interlocks

INR RFO15-05-04 Foreign Material Indication Notification Report

Procedure 2.1.36, Object Retrieval from Reactor Cavity and Spent Fuel Pool

License Amendment No. 215, Alternate Source Term for Fuel Handling Accident, 4/28/05

NEA-03-052, Revised SRM Quadrant Definitions including Rotation of Quadrants, 4/21/03

GE-NE-0000-0014-5292, Pilgrim SRM Quadrant Definition Analysis, 4/18/03

MR 03108794, Secondary Containment Leak Rate Test

SRM Neutron Flux Response (MR03117386, 03117387, 03117388, 03117389), 4/17/05

MR 03108819, FCU and FME Cover Installation and Removal

Condition Reports 200501482, 200501498, 200501503, 200501666, 200501673, 200501676,

200501688, 200501702, 200501857, 200501890, 200501965, 200501979, 200501981,

200502024, 200502056, 200502139, 200502322, 200502302, 200502356, 200502357,

200502466, 200502468, 200502470, 200502471, 200502472

MR 05107627, Reactor Vessel Debris Removal

OSRC Meeting Minutes 05-06,07, 08, 09, 10 and 11

MAN.C16-01, Power Maneuvering Plan Cycle 16 Startup

References for Section 1R22

Procedure 4.3, Fuel Handling dated 4/20/05

8.10.1, Attachment 1, refueling Interlock Functional Test, 4/19/05 and 4/20/05

A-10

Attachment

8.10.1, Attachment 7, Refueling Interlocks Logic Functional Test, 4/20/05

1.3.34, Attachment 9, Surveillance Test Review, 4/20/05

Technical Specification 3/4.10 and Bases, Core Alterations

UFSAR 7.6, Refueling Interlocks

References for Section 1EP2

EP-AD-417, Annual Siren Test Program, Rev 3

EP-AD-418, Monthly Testing of the Prompt Alert and Notification System, Rev 5

EP-AD-419, Annual Maintenance of the PANS Two-Way System, Rev 2

References for Section 1EP3

PNPS Emergency Plan Section O, Emergency Response Training

Nuclear Training Manual Section 5.5, Emergency Plan Training, Rev 28

PNPS ERO Training Matrix

NOP88A4, Assignment of Responsibilities in Support of the PNPS EP Program, Rev 8

SCBA EP Qualifications Notification Forms (5/31/05 & 6/23/05)

RP-STD-28, Maintenance of SCBA Qualifications for the EP Program, Rev 1

Procedure No. 6.7-002, Respiratory Protection Program, Rev 9

Procedure No. 6.7.1-104, Issue Use and Return of Respiratory Protection Equipment, Rev 12

EP-IP-100, Emergency Classification and Notification, Rev 23

EP-IP-220, TSC Activation and Response, Rev 13

EP-IP-230, OSC Activation and Response, Rev 4

EP-IP-231, Onsite Radiation Protection, Rev 6

EP-IP-240, Emergency Security Organization Activation and Response, Rev 10

EP-AD-110, Emergency Preparedness Organization and Responsibilities, Rev 3A

EP-AD-122, Maintenance of the Emergency Telephone Directory, Rev 7

EP-AD-125, Maintenance of the ERO, Rev 3

EP-AD-410, Maintenance of the Computerized Automated Notification System, Rev 3

EP-AD-411, Testing of the CANS, Rev 6

Emergency Telephone Directory, Rev 70

NRC Inspection Reports 05000293/2003-007 & 010

CR-PNP-2005-03002

References for Section 1EP4

EP-IP-501, Transport of Contaminated Injured Personnel, RETIRED

10CFR50.54(q) Effectiveness Review for EP-IP-501

10CFR50.54(q) Effectiveness Review for EAL 5.3.1.1

10CFR50.54(q) Effectiveness Review for Revision 28 of the PNPS Emergency Plan

Revised Distribution List of EPPI Public Information Emergency Response Procedure Manual

CR-PNP-2004-03759

CR-PNP-2005-03109

References for Section 1EP5

Audit Report 03-10, Emergency Preparedness Program

Audit Report QA-07-2004-01, Emergency Preparedness Program

CR-PNP-2003-04581

CR-PNP-2003-04584

A-11

Attachment

CR-PNP-2004-00273

CR-PNP-2004-01136

CR-PNP-2004-01141

CR-PNP-2004-01142

CR-PNP-2004-01143

CR-PNP-2004-01144

CR-PNP-2004-01145

CR-PNP-2004-01146

CR-PNP-2004-01147

CR-PNP-2004-01148

CR-PNP-2004-01149

CR-PNP-2004-01150

CR-PNP-2004-01152

CR-PNP-2004-01153

CR-PNP-2004-01154

CR-PNP-2004-03882

CR-PNP-2005-00158

CR-PNP-2005-00581

CR-PNP-2005-00722

CR-PNP-2005-01298

CR-PNP-2005-01903

CR-PNP-2005-02741

CR-PNP-2005-02813

CR-PNP-2005-02815

WRT-053506

References for Section 2OS1

RWP No. 05-0054, Rev. 00, Electrical motor-operated valve work (drywell

elevations 23 and 41)

RWP No. 05-0071, Rev. 00, Dryer upgrade (underwater welding in the

separator/dryer pool)

RWP No. 05-0080, Rev. 00, ISI exams and support for N6A & B core spray

nozzle areas (drywell elevations 74 and 83)

RWP No. 05-0082, Rev. 00, ISI exams and support for N1 & N2 nozzle areas

(drywell elevations 23, 41, and 51)

RWP No. 05-0101, Rev.00, Control rod drive exchange and support (under

vessel)

Procedure EN-RP-104, Rev. 0, Personnel contamination events

RFO-15 drywell field guide by Radiation Protection Department, April 2005

Radiological surveys for elevation 74 of the drywell, 04/18 -27/2005

Skin dose assessment for a personnel contamination on 04/25/2005

Procedure No. 1.3.114, Rev. 19, Conduct of radiological operations

Procedure No. 1.16.1, Rev. 7, Spent fuel pool non-SNM inventory control

Procedure No. 6.1-009, Rev. 9, Radiological controls for handling highly radioactive objects

and refuel floor activities

Procedure No. 6.1-014, Rev. 16, High radiation area control

Procedure No. 6.1-031, Rev. 18, Radiation work permits

A-12

Attachment

Procedure No. 6.3-061, Rev. 17, Radiological survey techniques

Pilgrim Station daily dose report for June 13, 14, 15, and 16, 2005

RWP No. 05-0054, Rev. 00, Electrical motor-operated valve work (drywell elevations 23 and

41)

RWP No. 05-0065, Rev. 04, Reactor disassembly/reassembly and associated support

RWP No. 05-0071, Rev. 00, Dryer upgrade (underwater welding in the separator/dryer pool)

RWP No. 05-0080, Rev. 00, ISI exams and support for N6A & B core spray nozzle areas

(drywell elevations 74 and 83)

RWP No. 05-0082, Rev. 00, ISI exams and support for N1 & N2 nozzle areas (drywell

elevations 23, 41, and 51)

References for Section 2OS2

RWP No. 05-0054, Rev. 00, Electrical motor-operated valve work (drywell

elevations 23 and 41)

RWP No. 05-0071, Rev. 00, Dryer upgrade (underwater welding in the

separator/dryer pool)

RWP No. 05-0080, Rev. 00, ISI exams and support for N6A & B core spray

nozzle areas (drywell elevations 74 and 83)

RWP No. 05-0082, Rev. 00, ISI exams and support for N1 & N2 nozzle areas

(drywell elevations 23, 41, and 51)

RWP No. 05-0101, Rev.00, Control rod drive exchange and support (under

vessel)

Specific RWP dose by date report for 04/18 to 04/25/2005 (listing RWP/task-

description, actual hours to date by RWP, and actual dose to date by RWP)

Radiological engineering spreadsheet for RFO 15 as of 04/25/2005 (listing

component, description, RWP, maintenance request, location, zone, total estimated hours for

completion by RWP, total estimated rem for completion by RWP, and engineering controls)

Daily dose report for RFO-15 for 04/29/2005 (listing work activity description,

actual dose to date by work activity, total estimated dose for completion by work activity, and

percent of estimate)

Pre-job ALARA reviews for RWPs 05-0054, -0071, -0080, -0082, and -0101

RFO-15 steam dryer tie rod repair dose estimate as of 04/26/2005

In-progress ALARA reviews for RWPs 05

-0054 (Electrical motor-operated valve work (drywell elevations 23 and41)),

-0080 (ISI exams and support for N6A & B core spray nozzle areas

(drywell elevations 74 and 83)),

-0082 (ISI exams and support for N1 & N2 nozzle areas (drywell

elevations 23, 41, and 51)),

-0099 (VAC 206B-2 motor/fan replacement (drywell elevation 9)),

-0101 (Control rod drive exchange and support (under vessel))

- ALARA review checklist for jobs greater than one rem

Procedure No. 6.10-020, Rev. 9, ALARA work reviews

Procedure No. 6.10-021, Rev. 6, Station ALARA performance

Procedure No. 6.10-022, Rev. 8, ALARA engineering controls

Procedure No. 6.10-023, Rev. 3, ALARA planning assessments

RWP No. 05-0054, Rev. 00, Electrical motor-operated valve work (drywell elevations 23 and

41)

A-13

Attachment

RWP No. 05-0065, Rev. 04, Reactor disassembly/reassembly and associated support

RWP No. 05-0071, Rev. 00, Dryer upgrade (underwater welding in the separator/dryer pool)

RWP No. 05-0080, Rev. 00, ISI exams and support for N6A & B core spray nozzle areas

(drywell elevations 74 and 83)

RWP No. 05-0082, Rev. 00, ISI exams and support for N1 & N2 nozzle areas (drywell

elevations 23, 41, and 51)

ALARA review packages for RWP Nos. 05-0054, 05-0065, 05-0071, 05-0080, and 05-0082

Refueling outage - 15 dose report for June 14, 2005 by project

Refueling outage -15 dose report by RWP

References for Section 2OS3

Procedure No. 6.4-331, Rev. 16, Operation of common radiation detectors and air samplers

Procedure No. 6.7.1-106, Rev. 11, Inspection and testing of respiratory protection equipment

Procedure No. 6.7.1-201, Rev. 8, Operation of the SCBA air compressor

Monthly SCBA pressure check surveillance status as of June 16, 2005

Weekly emergency respirator inspection report as of June 16, 2005

SCBA EP qualification status notification form

CR-PNP-2005-02990, no supervisory review of SCBA surveillance records per 6.7.1-106, step

8.6.3(3)

CR-PNP-2005-02991, SCBA bottles staged and ready for use with expired hydrostatic testing

dates

CR-PNP-2005-03002, possible shortfall of electrical pool ERO responders with SCBA

qualifications

References Section 4OA1

EP-AD-150, Emergency Preparedness Indicator Tracking Guideline, Rev 2

PNPS Emergency Telephone Directory Rev 70

CR-PNP-2005-03108

CR-PNP-2005-03127

References for Section 4OA5

Temporary Instruction 2515/163, Operational Readiness of Offsite Power

Procedure 2.1.144, Degraded Voltage

Procedure 2.1.15, Daily Surveillance Log

Procedure EN-WM-101, On-Line Work Management Process

Procedure EN-WM-100, Work Request (WR) Generation, Screening, and Classification

Procedure 5.3.31, Station Blackout

Procedure 2.2.146, Station Blackout Diesel Generator

Procedure 1.5.22, Risk Assessment Process

NUREG 1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73

ISONE Procedure Master/Local control Center Procedure #1, Nuclear Plant Transmission

Operations

SPEC-01-1524, Revision 3, Packaging certification documentation, 7A Type A, Container

Products Corporation, December 21, 2004

USA DOT-7A Type A Container Certification Nos. 1340, 1341, 1342, 1343, 1344, 1347, 1348,

1349, 1350, 1351, and 1352

A-14

Attachment

Radioactive shipment records for reactor control rod drives: RSR Nos.03-321 (two boxes), 03-

323 (four boxes),03-325 (two boxes),05-325 (four boxes), and 05-326 (four boxes)

C-FB-02-02-01, Rev. 5, Self-contained breathing apparatus instructor guide

LIST OF ACRONYMS

ALARA

As Low As Reasonable Achievable

ANS

Alert and Notification System

ASME

American Society of Mechanical Engineers

CAP

Corrective Action Program

CCWS

Closed Cooling Water System

CFR

Code of Federal Regulations

CR

Condition Report

CST

Condensate Storage Tank

DEP

Drill and Exercise Performance

DHR

Decay Heat Removal

DOT

Department Of Transportation

EAL

Emergency Action Level

ECCS

Emergency Core Cooling System

EDG

Emergency Diesel Generator

EP

Emergency Preparedness

EPD

Electronic Personnel Dosimeter

ER

Engineering Request

ERO

Emergency Response Organization

FME

Foreign Material Exclusion

HRA

High Radiation Area

HX

Heat Exchange

INR

Indication Notification Report

IR

Inspection Report

ISI

Inservice Inspection

LER

Licensee Event Report

LHRA

Locked High Radiation Area

LOCA

Loss of Coolant Accident

LOP

Loss of Offsite Power

MO

Motor Operated

MOV

Motor-Operated Valve

MR

Maintenance Request

MSIV

Main Stream Isolation Valve

MT

Magnetic Particle

NDE

Non-Destructive Examination

NRC

Nuclear Regulatory Commission

OA

Other Activities

OE

Operating Experience

OS

Occupational Radiation Safety

OSRC

On Site Review Committee

PDI

Performance Demonstration Initiative

PI

Performance Indicator

A-15

Attachment

PI&R

Problem Identification and Resolution

PNPS

Pilgrim Nuclear Power Station

PT

Penetrant

PWT

Post Work Test

QASR

Quality Assurance Surveillance Report

RBCCW

Reactor Building Closed Cooling Water

RCA

Radiologically-Controlled Area

RCS

Reactor Coolant System

RFO

ReFueling Outage

RHR

Residual Heat Removal

RPV

Reactor Pressure Vessel

RSPS

Risk Significant Planning Standard

RWP

Radiation Work Permit

SCBA

Self-Contained-Breathing Apparatus

SDP

Significant Determination Process

SDT

Shutdown Transformer

SE

Safety Evaluation

SEE

Substitution Equivalency Evaluation

SFP

Spent Fuel Pool

SRC

Safety Review Committee

SSC

Structure, System, and Component

SSW

Salt Service Water

TBCCW

Turbine Building Closed Cooling Water

TI

Temporary Instruction

TS

Technical Specification

TSO

Transmission System Operators

UFSAR

Updated Final Safety Analysis Report

UT

Ultrasonic Testing

VHRA

Very High Radiation Area

VT

Visual Test