ML12033A229
| ML12033A229 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/02/2012 |
| From: | Bellamy R NRC/RGN-I/DRP/PB5 |
| To: | Rich Smith Entergy Nuclear Operations |
| Bellamy R | |
| References | |
| EA-11-260 IR-11-005 | |
| Download: ML12033A229 (53) | |
See also: IR 05000293/2011005
Text
UNITED STATES
N UCLEAR REGU LATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PENNSYLVANIA 19406-1415
February 2,2012
Mr. Robert Smith
Site Vice President
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station
600 Rocky Hill Road
Plymouth, MA 02360-5508
SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION
REPORT 05000293/201 005 1
Dear Mr. Smith:
On December 31 ,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report
documents tn-e inspection results, which were discussed on January 10,2012, with you and
other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, three apparent violations of NRC requirements were
identified. The significance of these apparent violations has been designated as To Be
Determined (TBD) untilthe final significance characterization has been completed. The
apparent violations are associated with the medical examination and license conditions of
licensed operators. The plant has taken appropriate immediate corrective actions such that the
apparent violations do not represent an immediate safety concern. The final significance of
ttidse apparent violations willbe communicated to you in separate, future correspondence.
One NRC identified finding of very low safety significance (Green) was identified during this
inspection. This finding did not involve a violation of NRC requirements. Additionally, the NRC
has determined that a Severity Level lV violation occurred. Further, a licensee-identified
violation, which was determined to be of very low safety significance, is listed in this report.
However, because of the very low safety significance, and because they have been entered into
your corrective action program, the NRC is treating these violations as non-cited violations
(NCVs), consistent with the NRC's Enforcement Policy.
R. Smith
lf you contest any NCV in this report, you should provide a written response within 30 days of
the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the
RegionalAdministrator, Region l; the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector
at PNPS.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is
accessible from the NRC Web site at http://r,r.rww.nrc.gov/readino-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
Tt*s&Q.,
Ronald R. Bellamy, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Docket Nos.: 50-293
License Nos.: DPR.35
Enclosure: Inspection Report 05000293/201 1 005
w/Attachment: Supplemental I nformation
cc Mencl: Distribution via ListServ
R. Smith
lf you contest any NCV in this report, you should provide a written response within 30 days of
the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the
RegionalAdministrator, Region l; the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector
at PNPS.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) wilt be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is
accessibie from the NRC Web site at http:/iwww.nrc.gov/reading-rmiadams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Ronald R. Bellamy, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Docket Nos.: 50-293
License Nos.' DPR'35
Enclosure: Inspection Report05000293/2011005
w/Attachment: Supplemental Information
cc dencl: Distribution via ListServ
Distribution dencl:
W. Dean, RA B. Smith, Rl J. Teator, Ol
D. Lew, DRA S. Campbell, OA L. Chang,OEDO
J. Tappert, DRP T. SeEer, DRP R. Eul, HQ OE
J. Clifford. DRP J. DeBoer, DRP A. DeFrancisco, ORA
C. Miller, DRS D. Jackson, DRS RidsNrrPMPilgrim Resource
P. Wilson, DRP J. Caruso, DRS RidsNrrDorlLPLl -1 Resource
R. Bellamy, DRP D. Holody, ORA ROP reports. Resou rce@n rc. gov
M. Schneider, SRI K. Farrar. ORA
SUNSlReviewGomplete:-TGs-(Reviewer'slnitials) ML12033A229
DOCUM ENT NAM E: G:\DRP\B RANCH5\REPORTS\PI LG 201 1005 REV 1 . DOCX
After declaring this document "An Official Agency Record" it will be-1
released to the Public.
To receive aLopy of this document, indicate in the box: "C" = CoPY without attachmenVenclosure
with attach menVenclosure "N" = No
f,FFICE RI/DRP RI/DRP RI/DRS
NAME MSchneider/TCS for TSetzer/TS DJackson/DJ
DATE 01t31t12 01t03t12 01t31t't2
CFFICE Rl/ORA/ADeF RI/ORA/KF Rt/ot/JT
NAME ADeFrancisco KFarrar JTeator
DATE 01t31t12 01t31t12 02t01t12
OFFICE RI/DRP
NAME RBellamv
)ATE 02to1t12
OFFIC IAL COPY
1
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos.: 50-293
License Nos.: DPR-35
Report No.: 05000293/201 1005
Licensee: Entergy Nuclear Operations, Inc.
Facility: Pilgrim Nuclear Power Station (PNPS)
Location: 600 Rocky Hill Road
Plymouth, MA 02360
Dates: October 1, 2011 through December 31 , 2011
lnspectors: M. Schneider, Senior Resident Inspector, Division of Reactor Projects
(DRP)
B. Smith, Resident Inspector, DRP
M. Catts, Senior Resident Inspector, Indian Point Energy Center, Unit 2,
(DRP)
K. Mangan, Senior Reactor Inspector, Division of Reactor Safety (DRS)
R. Rolph, Health Physicist, DRS
J. Caruso, Senior Operations Engineer, DRS
T. Fish, Senior Operations Engineer, DRS
J. Tomlinson, Operations Engineer, DRS
C. Newport, Operations Engineer, DRS
Approved By: Ronald R. Bellamy, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Enclosure
2
TABLE OF CONTENTS
SUMMARY OF FlNDlNGS..........., .........3
1. REACTOR SAFETY .......................7
1R01 Adverse Weather Protection. .................7
1R04 Equipment Alignment ...........8
1R05 Fire Protection............ ..........8
1R11 Licensed Operator Requalification Program .............. ........,.....9
1R12 Maintenance Effectiveness.......... ........21
1R13 Maintenance Risk Assessments and Emergent Work Control............. ....................21
1 R15 Operability Determinations and Functionality Assessments.......... .,........22
1R19 Post-Maintenance Testing..... ..............23
1R20 Refueling and Other Outage Activities... ...............23
1R22 Surveillance Testing ...........24
2. RADTATTON SAFETY (RS)......... .......,...........25
2RS01 Radioactive Hazard Assessment and Exposure Controls....,....... ...........25
2RS02 Occupational As Low As ls Reasonably Achievable Planning and Controls ............27
2RS03 In-Plant Airborne Radioactivity Control and Mitigation,,.......... ..........,.....28
2RS04 Occupational Dose Assessment...,.,.......... ...........29
2RS05 Radiation Monitoring Instrumentation......... ..........31
4. OTHER ACT1VlTlES............... ......31
4OA1 Performance lndicator Verification .....,,31
4OA2 Problem ldentification and Resolution ..................32
4OA3 Follow-Up of Events and Notices of Enforcement Discretion ..................35
40A6 Meetings, Including Exit .......... ............35
4OA7 Licensee-ldentified Violations.. ....,.......36
ATTACHMENT: SUPPLEMENTARY INFORMATION ...........36
SUPPLEMENTARY INFORMATION.......... ........A-1
KEY POINTS OF CONTACT ............. A-1
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED .........,......... A-1
LIST OF DOCUMENTS REVIEWED ........... ....... A-3
LtsT oF ACRONYMS............... ....... A-14
Enclosure
3
SUMMARY OF FINDINGS
lR 0500029312011005; 1010112011-121311201 1; Pilgrim Nuclear Power Station; Licensed
Operator Requalification Program.
This report covered a three-month period of inspection by resident inspectors and announced
inspections performed by regional inspectors. The inspectors identified three apparent
violations (AVs), one Severity Level lV NCV, and one finding of very low safety significance
(Green). The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process"
(SDP). Findings for which the SDP does not apply may be Green, or be assigned a severity
level after NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"
Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
. TBD. The inspectors identified an apparent violation (AV) of Title 10 of the Code of
Federal Regulations (10 CFR) 55.53 and 10 CFR 55.21 related to Entergy's medical
examinations of licensed operators. Specifically, at various times over a period of
almost four years, ten operators did not meet certain medical requirements (for stamina
and/or blood pressure) for performing NRC-licensed operator activities, and the
operators continued to perform NRC-licensed activities. Additionally, Entergy did not
perform complete medical testing of its licensed operators, in that five of those licensed
operators had not been administered stamina tests for more than two years and
therefore did not complete their NRC-required biennial medical exam. lmmediately after
the NRC identified the issue, Entergy restricted operators from watch until they could
pass the requirements of their medical testing. Entergy entered this issue into their
corrective action program (CR-PNP-201 1 -04554).
The inspectors determined that Entergy's failure to ensure that licensed operators met
the license conditions associated with medical testing prior to performing license
activities was a performance deficiency that was within Entergy's ability to foresee and
correct and should have been prevented. The inspectors determined that Traditional
Enforcement applies, as the issue had the potential to impact the NRC's ability to
perform its regulatory function because the NRC relies upon the accurate certification by
the licensee's medical examiner to ensure all licensed operators meet the medical
conditions of their license. Specifically, ten operators had not taken the stamina test
during their annual physical, but were certified by the medical examiner and licensee as
being fit to safely perform their watch-standing duties. Additionally, five of those
operators had not taken the stamina test during their biennial physical, but were certified
by the medical examiner and licensee as being fit to safely perform their watch-standing
duties. Lastly, an individual who had not passed their blood pressure examination, and
required a license condition to take medication, was placed back on watch-standing duty
without such a license condition. The performance deficiency was screened against the
Reactor Oversight Process (ROP) per the guidance of lnspection Manual Chapter (lMC)
0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no
cross-cutting aspect was assigned. These issues are being characterized as an
apparent violation in accordance with the NRC's Enforcement Policy, and its final
significance will be dispositioned in separate future correspondence. (Section 1R1 1)
Enclosure
4
TBD. The inspectors identified an AV of 10 CFR 50.9, "Completeness and Accuracy of
Information," related to Entergy's medical examinations of licensed operators.
Specifically, Entergy did not provide information to the NRC that was complete and
accurate in all material respects, in that Entergy submitted two NRC licensed operator
renewal applications which certified that the applicants met the medical requirements for
license renewal when in fact they did not complete the required stamina tests. Entergy
entered this issue into their corrective action program (CR-PNP-2011-04554).
The inspectors determined that Entergy's failure to provide complete and accurate
information to the NRC was a performance deficiency that was within Entergy's ability to
foresee and correct and should have been prevented. The inspectors determined that
Traditional Enforcement applies, as the issue had the potential to impact the NRC's
ability to perform its regulatory function. Specifically, Entergy did not provide information
to the NRC that was complete and accurate in all material respects, in that although
Entergy had not administered complete medical examinations of licensed operators in
accordance with American National Standards Institute/American Nuclear Society
(ANSI/ANS)3.4-1983 (because it had not conducted stamina testing), it submitted two
NRC Form-396s for renewal of operator licenses which certified that the applicants met
the medical requirements of ANSI/ANS 3.4-1983, Subsequently, the NRC made a
licensing decision based on this information that was not complete and accurate in all
material respects. The performance deficiency was screened against the ROP per the
guidance of IMC 0612, Appendix B, "lssue Screening." No associated ROP finding was
identified and no cross-cutting aspect was assigned. This issue constitutes an apparent
violation in accordance with the NRC's Enforcement Policy, and its final significance will
be dispositioned in separate future correspondence. (Section 1R1 1)
TBD. The inspectors identified an AV of 10 CFR 50.74, "Notification of Change in
Operator or Senior Operator Status." Specifically, Entergy did not notify the NRC within
30 days of discovering a change in medical condition for two licensed operators.
Subsequently, Entergy submitted notifications for both operators on November 10, 2Q11 ,
and entered the issue into their corrective action program (CR-PNP-2011-04554).
The inspectors determined that Entergy's failure to notify the NRC within 30 days of
discovering the change in medical condition for two licensed operators was a
performance deficiency that was within Entergy's ability to foresee and correct and
should have been prevented. The inspectors determined that Traditional Enforcement
applies, as the issue had the potential to impact the NRC's ability to perform its
regulatory function because if a licensed operator has a change in medical condition, the
NRC may need to perform a review for consideration of a licensing action. Specifically,
Entergy had not notified the NRC within 30 days of learning of a change in medical
condition for two licensed operators for which a license condition was required. The
performance deficiency was screened against the ROP per the guidance of IMC 0612,
Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-
cutting aspect was assigned, This issue constitutes an apparent violation in accordance
with the NRC's Enforcement Policy, and its final significance will be dispositioned in
separate future correspondence. (Section 1 R1 1 )
SL-IV. The inspectors identified a Severity Level lV NCV of 10 CFR 55.53 (e) and (f),
"Conditions of Licenses," because Entergy incorrectly credited two individuals for
proficiency watch-standing experience and then these operators subsequently stood
watch without meeting the minimum proficiency requirements necessary to maintain an
Enclosure
5
active license. Entergy implemented immediate corrective action that included
discontinuing the practice of crediting the emergency core cooling system (ECCS) and
Extra Balance of Plant (BOP) positions for proficiency. Entergy entered this issue into
their corrective action program (CR-PNP-201 1-04649).
The inspectors determined that Entergy incorrectly credited two individuals for
proficiency watch-standing experience and then these operators subsequently stood
watch in the control room. This error constitutes a performance deficiency that was
within Entergy's ability to foresee and correct and should have been prevented. The
inspectors determined that Traditional Enforcement applies, as the issue had the
potential to impact the NRC's ability to perform its regulatory function because if a
licensed operator fails to meet the conditions of their license, the NRC may need to
perform a review for consideration of a licensing action, and if the information regarding
an individual's qualifications is not accurately presented, the NRC could potentially make
an incorrect licensing decision based on the inaccurate information. Specifically,
Entergy did not ensure that two reactor operator (RO) licensed individuals maintained
their RO licenses in an active status in the 2nd quarter 2011, prior to standing RO
watches in the 3rd quarter 201 1 which violated a license condition as specified in 10
CFR 55.53 (e) and (f). The performance deficiency was screened against the ROP per
the guidance of IMC 0612, Appendix B, "lssue Screening." No associated ROP finding
was identified and no cross-cutting aspect was assigned. This issue is similar to
violation example 6.4.c.1(c) in the NRC Enforcement Policy for a Severity Level lll
violation because it involves noncompliance with a condition stated on an individual's
license. However, since there were no adverse impacts to nuclear safety, the NRC has
determined that this issue constitutes a Severity Level lV NCV in accordance with the
NRC's Enforcement Policy. (Section 1R1 1)
. Green. The inspectors identified a Green finding of 10 CFR 55.59, "Requalification,"
based on a determination that greater than 20 percent of the biennial requalification
written exam questions administered to licensed operators during weeks three and four
of the 2010 examination cycle were unacceptable. Entergy entered this issue into the
corrective action program (CR-PNP-201 1 -04561 ).
The inspectors determined that the finding was more than minor because it was
associated with the Human Performance attribute of the Mitigation Systems cornerstone
and affected the cornerstone objective of ensuring the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences (i.e., core damage). Specifically, the finding affected the quality and level
of difficulty of biennial written exams which potentially impacted Entergy's ability to
appropriately evaluate licensed operators. The risk importance of this issue was
evaluated using IMC 0609, Appendix l, "Licensed Operator Requalification Significance
Determination Process (SDP)." Appendix I was entered using the number of written
exam questions that did not meet the qualitative standard for the written exam questions.
The qualitative standard used by the inspectors is defined in NUREG-1021 , Rev. 9, ES-
602, Attachment 1, "Guidelines for Developing Open-Reference Examinations," and
Appendix B, "Written Examination Guidelines." Since 28.6 percent of the questions
reviewed did not meet the guidance, Block 16 of Appendix I applied, specifically, "Were
more than 20 percent of the written questions sampled by the inspectors unacceptable?"
Enclosure
6
Based on this screening criteria, the finding was characterized by the SDP as having
very low safety significance (greater than 20 percent unacceptable), or Green. A review
of the cross-cutting aspects was performed and no cross-cutting aspect was identified
that would be considered a contributor to the cause of the finding. (Section 1R1 1)
Other Findings
A violation of very low safety significance, which was identified by Entergy, has been reviewed
by the inspectors. Corrective actions taken or planned by Entergy have been entered into their
corrective action program. The violation and corrective actions are listed in Section 4OA7 of
this report.
Enclosure
7
REPORT DETAILS
Summarv of Plant Status
Pilgrim Nuclear Power Station began the inspection period operating at 100 percent reactor
power. On October 14,2Q11, operators reduced reactor power to 71 percent to perform scram
time testing on Control Rod 14-43. Pilgrim returned to 100 percent reactor power later that
same day. On November 17, operators reduced reactor power to 50 percent to perform a
thermal backwash on the main condenser. During the thermal backwash, a leak on the 'B'
feedwater discharge check valve was identified. Operators shut down the plant to conduct a
forced outage to repair this containment isolation valve. On November 26, operators returned to
100 percent reactor power. On November 27 , operators reduced reactor power to 65 percent
power to perform a control rod pattern adjustment and returned to 100 percent reactor power
later that same day. On December 26, operators shut down the plant to conduct a forced
outage and repair a leaking Safety Relief Valve. On December 31, reactor power returned to
100 percent, then was reduced to 65 percent to perform a control rod pattern adjustment, and
then returned to 100 percent reactor power on January 1,2012.
1. REACTORSAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - 1 sample)
Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of Pilgrim's readiness for the onset of seasonal cold
weather and temperatures during the week of October 31,2011. The review focused on
the station Blackout Diesel Generator, condensate storage tank, and Technical Support
Center Emergency Diesel Generator. The inspectors reviewed station procedures,
including Pilgrim's seasonalweather preparation procedure and applicable operating
procedures to verify that selected steps had been completed. The inspectors performed
walkdowns of the selected systems to ensure station personnel identified issues that
could challenge the operability of the systems during cold weather conditions.
Documents reviewed for each section of this inspection report are listed in the
Attachment.
b. Findinqs
No findings were identified.
Enclosure
1R04 EquipmentAliqnment
Partial Svstem Walkdowns (71111.04Q - 3 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
. 'B' Emergency Diesel Generator (EDG) following 2,4, and 8 year preventative
maintenance
. High Pressure Coolant Injection System during 'B' EDG Outage
. Salt Service Water System during Intake Canal Dredging
The inspectors selected these systems based on their risk-significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors reviewed
applicable operating procedures, system diagrams, the Updated Final Safety Analysis
Report (UFSAR), technical specifications, work orders, condition reports, and the impact
of ongoing work activities on redundant trains of equipment in order to identify conditions
that could have impacted system performance or their intended safety functions. The
inspectors also performed field walkdowns of accessible portions of the systems to verify
that system components and support equipment were aligned correctly and were
operable. The inspectors examined the material condition of the components and
observed operating parameters of equipment to verify that there were no deficiencies.
The inspectors also reviewed whether Entergy had properly identified equipment issues
and entered them into the corrective action program for resolution with the appropriate
sig n ificance characterization.
b. Findinqs
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterlv Walkdowns (71111.05Q - 5 samples)
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material
condition and operational status of fire protection features. The inspectors verified that
Entergy controlled combustible materials and ignition sources in accordance with
administrative procedures. The inspectors verified that fire protection identification and
suppression equipment was available for use as specified in the area pre-fire plan, and
that passive fire barriers were maintained in good material condition. The inspectors
also verified that station personnel implemented compensatory measures for out of
service, degraded, or inoperable fire protection equipment, as applicable, in accordance
with procedures.
r Fire Area 1 .21, Fire Zone 1.21,'A' Reactor Building Closed Cooling Water (RBCCW)
Pumps/Heat Exchanger Room
o Fire Area 1.10, Fire Zone 1.22,'B' RBCCW Pumps/Heat Exchanger Room
Enclosure
I
. Fire Area 1.10, Fire Zone 1.3, High Pressure Coolant Injection Pump/Turbine Room
. Fire Area 1.10, Fire Zone 1.7, Reactor Core lsolation Cooling Quadrant Mezzanine
. Fire Area 1.10, Fire Zone 1.304, Torus Compartment
b. Findinqs
No findings were identified.
1R1 1 Licensed Operator Requalification Prooram (71111.11)
.1 Requalification Review bv Resident Inspectors (71111.1 1Q - 1 sample)
a. lnspection Scope
The inspectors observed licensed operator simulator training on November 16, 2011 ,
which included a Recirculation Loop Seal Failure, Anticipated Transient Without Scram
combined with a Loss of Offsite Power scenario. The inspectors evaluated operator
performance during the simulated event and verified completion of risk significant
operator actions, including the use of abnormal and emergency operating procedures.
The inspectors assessed the clarity and effectiveness of communications,
implementation of actions in response to alarms and degrading plant conditions, and the
oversight and direction provided by the Control Room Supervisor. The inspectors
verified the accuracy and timeliness of the emergency classification made by the Shift
Manager and the technical specification action statements identified by the Shift Control
Room Engineer. Additionally, the inspectors assessed the ability of the crew and
training staff to identify and document crew performance problems. Finally, the
inspectors performed a simulator fidelity review to determine if the arrangement of the
simulator instrumentation, controls, and tagging closely paralleled that of the control
room.
b. Findinqs
No findings were identified.
.2 Biennial Review bv Reqignal Specialists (71111.1 1B - 1 sample)
a. Inspection Scope
The following inspection activities were performed using NUREG-1021, "Operator
Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, NRC
inspection procedure Attachment71111.1 1, "Licensed Operator Requalification
Program," Appendix A, "Checklist for Evaluating Facility Testing Material," and
Appendix B, "Suggested Interview Topics."
A review was conducted of recent operating history documentation found in inspection
reports, licensee event reports, the licensee's corrective action program, and the most
recent NRC plant issues matrix (PlM), The inspectors also reviewed specific events
from the licensee's corrective action program which indicated possible training
deficiencies, to verify that they had been appropriately addressed. The senior resident
inspector was also consulted for insights regarding licensed operators' performance.
Enclosure
10
The inspectors reviewed two comprehensive written exams administered during weeks
three and four of the 2010 exam cycle, six simulator scenarios, and ten job performance
measures, which comprised the test items administered or planned for administration the
weeks of September 26,2011, and October 3, 2011, to ensure the quality of these
exams met or exceeded the criteria established in the Examination Standards and
10 CFR 55.59. The inspectors observed the administration of the operating exams to
one crew during the onsite inspection week, which began October 4,2011.
On November 9, 2011, the results of the annual operating tests for year 2011 were
reviewed to determine if pass/fail rates were consistent with the guidance of
NUREG-1021, "Operator Licensing Examination Standards for Power Reactors,"
Revision 9, Supplement 1, and NRC IMC 0609, Appendix l, "Operator Requalification
Human Performance Significance Determination Process (SDP)." The review verified
the following:
o Crew pass rates were greater than 80 percent. (Pass rate was 100 percent)
r Individual pass rates on the dynamic simulator test were greater than 80 percent.
(Pass rate was 96.5 percent)
r lndividual pass rates on the job performance measures of the operating exam were
greater than 80 percent. (Pass rate was 100 percent)
o lndividual pass rates on the written exam were greater than 80 percent. (N/A for this
year)
. More than 75 percent of the individuals passed all portions of the exam.
(96.5 percent of the individuals passed all portions of the examination)
Observations were made of the dynamic simulator exams and job performance
measures (JPM) administered during the week of October 3,2011. These observations
included facility evaluations of crew and individual performance during the dynamic
simulator exams and individual performance of five JPMs.
The remediation plans for two individual simulator failures and two JPM exams that
needed improvement were reviewed to assess the effectiveness of the remedial training.
Operators, instructors and training/operation's management were interviewed for
feedback on their training program and the quality of training received. Simulator
performance and fidelity were reviewed for conformance to the reference plant control
room.
A sample of records for requalification training attendance, program feedback, reporting,
license reactivation, proficiency watch-standing experience, and medical examinations
were reviewed for compliance with license conditions, including NRC regulations. The
documents reviewed are listed in the Attachment.
Enclosure
11
b. Findinqs
.1 lntroduction: The inspectors identified an apparent violation (AV) of Title 10 of the Code
of Federal Regulations (10 CFR) 55.53 and 10 CFR 55.21 related to Entergy's medical
examinations of licensed operators. Specifically, at various times over a period of
almost four years, ten operators did not meet certain medical requirements (for stamina
and/or blood pressure) for performing NRC-licensed operator activities, and the
operators continued to perform NRC-licensed activities. Additionally, Entergy did not
perform complete medical testing of its licensed operators, in that five of those licensed
operators had not been administered stamina tests for more than two years and
therefore did not complete their NRC-required biennial medical exam. lmmediately after
the NRC identified the issue, Entergy restricted operators from watch until they could
pass the requirements of their medical testing.
Description: As part of the biennial Licensed Operator Requalification Training (LORT)
program inspection, the inspectors reviewed a sample of Pilgrim's licensed operator
medical records. The NRC's requirements related to the conduct and documentation of
medical examinations for operators are contained in Subpart C, Medical Requirements,
of 10 CFR Part 55, "Operators' Licenses." Specifically, 10 CFR 55.21 , "Medical
Examination," requires every operator be examined by a physician when he or she first
applies for a license and every two years, thereafter, once the license is received. The
physician is to verify that the operator's medical condition and general health will not
adversely affect the performance of assigned operator duties or cause operational errors
that endanger public health and safety, as stated in 10 CFR 55.33(a)(1). Additionally, 10
CFR 55.53, "Conditions of Licenses," states that each license contains and is subject to
certain conditions whether stated in the license or not, One of these conditions, 10 CFR
55.53 (i), requires the licensee to have a biennial medical examination.
The licensee must also certify which industry standard (i.e,, the 1983 or 1996 version of
ANSI/ANS 3.4, "Medical Certification and Monitoring of Personnel Requiring Operator
Licenses for Nuclear Power Plants," or other NRC-approved method) was used in
making the fitness determination. The inspectors determined that Entergy had stated on
NRC Form 396 that the 1983 industry standard was used for the completion of the
medical examination. The inspectors noted that the following ANSI/ANS sections apply:
Section 5.1, states in part, "...Consequently, any physical condition...that restricts
mobility of the individual or precludes wearing of protective clothing and equipment is
a liability to safe operation. . .;"
Section 5.2.1, "Capacity," states in part, "The examinee shall demonstrate stability
and capacityforall of thefollowing: (3)...,stamina, ...range of motion...;"
Section 5.3, "Disqualifying Conditions," states in part, "A history or other indication of
any disqualifying condition shall be considered disqualifying unless adequate
supplementalfindings demonstrate that no disqualifying condition exists...;"
Section 5.4.6, "Respiratory," states in part, "Capacity and reserve to perform
strenuous physical exertion in emergencies...;"
Section 5.4.7, "Cardiovascular," states in part, "... tolerance to postural changes and
capacity for exertion during emergencies...;"
Enclosure
12
Section 5.4.7 also establishes 160/100 mm Hg as the upper limit for blood pressure;
and Section 6, "Waiver or Specifically Limited Approval," states in part, "...the
designated medical examiner may recommend waiver of that portion of the
Standard. lt is the examinee's responsibility to supply additional information
necessary for consideration of the granting of such a waiver. Documentation
supporting the waiver shall include: (1) Medical history and results of physical exam
and other pertinent medical findings; (2) Specific statements by the medical
examiner as to the individual's capacity and the potential effects of any medical
impairment on the individual's ability to perform nuclear reactor operator duties; (3)
Description by the facility operator of specific practical tests and demonstrations of
ability to perform these duties..; (4) Certification from the designated medical
examiner and facility operator indicating that the individual can safely perform his
assigned duties,"
In addition, the inspectors noted that the following sections of Entergy procedure
EN-NS-1 12, "Medical Program," apply:
Section 4.5, "The Medical Examiner or designee is responsible for," states in part,
'...[4] Ensuring the appropriate personnel are notified if a worker fails to meet the
requirements of the medical examination;..."
Section 4.7, "Supervisors of Licensed Nuclear Operators or designee is responsible
for," states in part, "...[3] Notifying medicalservices personnelof any physicalor
mental condition that may limit the performance of Licensed Nuclear Operators;"
Section 5.6[5], 'NRC Licensed Nuclear Operator Physical," states in part, "
examination shall consist of: ...Stamina assessment:"
Section 5.6[5] "Minimum Qualifying Criteria," states in part, "...The examining
physician shall report...untreated hypertension (over 160/100 mm Hg)...;"
Section 5.6[5], "Disqualifying Conditions," states in part, "...Temporary disabilities
incurred during the term of an Operator's License do not require NRC notification as
long as the operator is not assigned licensed operator duties during the period of
disability;" and
Section 5.6151(k) states, "lndividuals qualified for licensed operator duties must notify
the plant Medical Examiner or nurse of any change in their physical or mental
condition. The Medical Examiner will evaluate the individual's condition to determine
if it adversely affects his/her ability to perform licensed duties. lf the individual fails
the plant nurse shall make verbal notification with written follow-up to the individual;"
The inspectors identified that at various times from March 2008 through October 1 1,
2011, ten operators did not complete a stamina assessment as part of their medical
exams. Both ANSI/ANS 3.4-1983 and Entergy procedure EN-NS-112 require a stamina
assessment be completed as part of the licensed operator medical examination which is
a condition of the license for performing NRC-licensed operator activities. The
inspectors reviewed the operators' medical Synopsis, and noted the facility medical
officer had decided not to administer and deferred the stamina test for varying reasons,
For example, ten operators had not taken the test due to pain associated with hip
replacement; pain associated with spinalfusion; pain associated with knee replacement;
Enclosure
13
knee pain; a torn meniscus; and high blood pressure. The stamina tests were deferred,
in some cases for multiple years, due to the various disabilities reported at the time of
their medical exams. Also, in December 2010, medical exam results for one of these ten
operators indicated blood pressure results which exceeded the limit established in
The inspectors noted from a review of the medical records that apparently these ten
operators were not reporting their disabilities at the time of injury or incapacitation as
required, but instead waited to disclose their conditions until the administration of their
medical exams. These disabilities restricted their mobility and/or stability to carry out
operator responsibilities in an emergency situation such as safe shutdown outside the
control room. ANSI/ANS 3.4-1983 states that any physical condition that restricts
mobility of the individual is a liability to safe operation. These operators should have
been restricted from license duty and in the case of a more permanent disability their
licenses should have included a permanent restriction such as a license condition which
would have prevented them from standing watch by themselves ("no-solo" condition).
The Pilgrim Medical Examiner did not document any basis for deferment of the required
stamina testing at the time of the medical examination as required by ANSI/ANS 3.4-
1 983.
The inspectors noted that following the NRC inspection, the Medical Examiner added a
"Memo to File" to each of the affected individual's medical records which documented
the bases for medically clearing these individuals which in some cases had been
deferred multiple times over a period of almost four years. The NRC's medical doctor
independently reviewed a sample of six of the ten medical records and the associated
memos to file and concluded that this approach with respect to stamina testing did not
satisfy the ANSI/ANS standard. Although some of these individuals may have
possessed aerobic stamina, it appears that the reported temporary disabilities and
associated pain (i.e., that precluded them from passing a stamina test at the time) would
have severely impaired their mobility, range of motion, and/or physical stability to carry
out operator responsibilities in an emergency situation such as safe shutdown outside
the control room as required by the ANSI/ANS standard. In all instances, these ten
operators continued to perform NRC-licensed activities even though they had not met
the minimum requirements for completing licensed operator medical examination which
was a condition of their license.
Additionally, the inspectors identified that Entergy did not perform complete biennial
medical testing of its licensed operators; in that, between March 2008 and October 2Q11,
five of those licensed operators had not been administered stamina tests for more than
two years and therefore did not complete their NRC-required biennial medical exam.
ANSI/ANS 3.4-1983, section 5.2.1 and Entergy procedure EN-NS-1 12, section 5.6t51
require the stamina test to be completed as part of satisfactorily completing the biennial
medical exam. The medical reasons given for not administering the test included pain
due to hip replacement; pain associated with spinal fusion; knee pain; and high blood
pressure.
Analvsis: The inspectors determined that Entergy's failure to ensure that licensed
operators met the license conditions associated with medical testing prior to performing
license activities was a performance deficiency that was within Entergy's ability to
foresee and correct and should have been prevented. The inspectors determined that
Traditional Enforcement applies, as the issue had the potential to impact the NRC's
Enclosure
14
ability to perform its regulatory function because the NRC relies upon the accurate
certification by the licensee's medical examiner to ensure all licensed operators meet the
medical conditions of their license. Specifically, ten operators had not taken the stamina
test during their annual physical, but were certified by the medical examiner and licensee
as being fit to safely perform their watch-standing duties. Additionally, five of those
operators had not taken the stamina test during their biennial physical, but were certified
by the medical examiner and licensee as being fit to safely perform their watch-standing
duties. Lastly, an individualwho had not passed the blood pressure examination, and
required a license condition to take medication, was placed back on watch-standing duty
without such a license condition. The performance deficiency was screened against the
Reactor Oversight Process (ROP) per the guidance of Inspection Manual Chapter (lMC)
0612, Appendix B, "lssue Screening." No associated ROP finding was identified and no
cross-cutting aspect was assigned.
Enforcement: 10 CFR 55.53, requires, in part, that each license contains and is subject
to the following conditions whether stated in the license or not...(i) the licensee shall
have a biennial medical examination....(l) the licensee shall comply with any other
conditions that the Commission may impose to protect health or to minimize danger to
health and property.
10 CFR 55.21 requires, in part, that a licensee shall have a medical examination by a
physician every two years. The physician shall determine that the licensee meets the
requirements of 55.33(aX1 ).
10 CFR 55.33(a)(1) states that the applicant's medical condition and general health will
not adversely affect the performance of operator job duties or cause operational errors
endangering public health and safety. The Commission will base its finding upon the
certification by the facility licensee as detailed in 10 CFR 55.23.
10 CFR 55.23 requires, in part, that to certify the medical fitness of the applicant, an
authorized representative of the facility licensee shall complete and sign NRC Form 396,
"Certification of Medical Examination by Facility Licensee."
The NRC Form 396, after being signed by an authorized representative of the facility
licensee, demonstrates the medical fitness of the licensee and that the guidance
contained in ANSI/ANS 3.4-1983, "Medical Certification and Monitoring of Personnel
Requiring Operator Licenses for Nuclear Power Plants," was followed in conducting the
examination and making the determination of medical qualification.
Contrary to the above, at various times from March 2008 through October 2011, Entergy
failed to ensure that licensed operators standing watch were medically qualified in
accordance with ANSI/ANS 3.4-1983. Specifically, the portion of the annual medical
examinations involving a stamina assessment was not administered to ten operators,
and five of those licensed operators had not been administered stamina tests for over
two years (one operator had not taken a stamina test for over three years). In addition,
one operator did not pass the required blood pressure test but was determined to be
medically qualified to stand watch, and did so, without any license condition.
lmmediately after the NRC identified the issues, Entergy restricted operators from watch
until they could pass the requirements of their medical testing. Regarding the individual
for whom a condition was required for blood pressure medication, Entergy requested the
Enclosure
15
license amendment and the license has been appropriately conditioned. Entergy
entered the issues into their corrective action program (CR-PNP-2O11-04554). These
issues are being characterized as an apparent violation in accordance with the NRC's
Enforcement Policy, and its final significance will be dispositioned in separate future
correspondence. (AV 0500029312011 005-01, Licensed Operators Stood Watch
Without Being Medically Qualified)
.2 lntroduction: The inspectors identified an AV of 10 CFR 50.9, "Completeness and
Accuracy of Information," related to Entergy's medical examinations of licensed
operators. Specifically, Entergy did not provide information to the NRC that was
complete and accurate in all material respects, in that Entergy submitted two NRC
licensed operator renewal applications which certified that the applicants met the
medical requirements for license renewal when in fact they did not complete the required
stamina tests.
Description: As part of the biennial LORT program inspection, the inspectors reviewed a
sample of licensed operator medical records. The inspectors identified that Entergy
provided information to the NRC that was not complete and accurate in all material
respects, in that Entergy submitted two NRC licensed operator renewal applications
which certified that the applicants met the medical requirements for license renewal
when in fact they did not.
The ANSI/ANS 3.4-1983, section 5.2.1, and Entergy procedure EN-NS-112, section
5.6[5] require a stamina test to be completed as part of satisfactorily completing the
biennial medical exam. Entergy submitted two NRC Form-396s for renewal of operator
licenses which certified that the applicants met the medical requirements of
ANSI/ANS 3.4-1983. This form, when signed by an authorized representative of the
facility licensee, certifies that a physician conducted a medical examination of the
applicant as required in 10 CFR 55.21, and that the guidance contained in
ANSI/ANS 3.4-1983 was followed in conducting the examination and making the
determination of medical qualification. The inspectors noted NRC Form 396 was signed
by a senior licensee representative, verifying the examination had been performed.
The NRC issued one individual a license renewal on June 23, 2011, but at the time of
renewal the individual had not completed the NRC-required biennial medical exam
because stamina testing had been deferred by the Pilgrim Medical Examiner for at least
two years (i.e., individual was deferred in January 2010 and again in January 201 1
which was the end of the two year period for the physical). Another individual was also
issued an NRC license renewal on June 23,2011, but at the time of renewal the
individual had not completed the NRC-required biennial medical exam because stamina
testing had again been deferred by the Pilgrim Medical Examiner for over two years (i.e.,
individual was deferred in March 2008, February 2009, February 2010, and in January
2011).
Analvsis: The inspectors determined that Entergy's failure to provide complete and
accurate information to the NRC was a performance deficiency that was within Entergy's
ability to foresee and correct and should have been prevented. The inspectors
determined that Traditional Enforcement applies, as the issue had the potential to impact
the NRC's ability to perform its regulatory function, Specifically, Entergy did not provide
information to the NRC that was complete and accurate in all material respects, in that
although Entergy had not administered complete medical examinations of licensed
Enclosure
16
operators in accordance with ANSI/ANS 3.4-1983 (because it had not conducted
stamina testing), it submitted two NRC Form-396s for renewal of operator licenses which
certified that the applicants met the medical requirements of ANSI/ANS 3.4-1983.
Subsequently, the NRC made a licensing decision based on this information that was
not complete and accurate in all material respects. The performance deficiency was
screened against the ROP per the guidance of IMC 0612, Appendix B, "lssue
Screening." No associated ROP finding was identified and no cross-cutting aspect was
assigned.
Enforcement: 10 CFR 50.9 requires, in part, that information provided to the
Commission by a licensee shall be complete and accurate in all material respects.
Contrary to the above, Entergy submitted two NRC licensed operator renewal
applications which certified that the applicants met the medical requirements for license
renewal when in fact they did not, in violation of 10 CFR 50.9. Entergy entered this
issue into their corrective action program (CR-PNP-2011-04554). This issue constitutes
an apparent violation in accordance with the NRC's Enforcement Policy, and its final
significance will be dispositioned in separate future correspondence,
(AV 0500029312011005-02, Entergy Did Not Provide Complete and Accurate
Medical Information for Licensed Operator Renewal Applications)
.3 fntroduction: The inspectors identified an AV of 10 CFR 50.74, "Notification of Change
in Operator or Senior Operator Status." Specifically, Entergy did not notify the NRC
within 30 days of discovering a change in medical condition for two licensed operators.
Description: As part of the biennial LORT program inspection, the inspectors reviewed a
sample of licensed operator medical records. The inspectors identified that Entergy had
not notified the NRC within 30 days of learning of a change in medical condition for two
licensed operators for which a license condition was required by 10 CFR 50.74. In
addition, the inspectors noted facility staff also failed to adhere to the requirements of
EN-NS-112, "Medical Program," Section 5.6, related to, "Changes in medical condition
or medication use." Paragraph(c), states in part, "lf the change in medical
condition/medication is determined to be chronic or maintenance then notification shall
be made to the NRC within 30 days of identification ..."
ln December 2Q10 and in August 2010 respectively, Pilgrim medical staff became aware
of medical conditions that caused two licensed operators to fail to meet the requirements
of 10 CFR 55.21 and for which license conditions were required. Specifically, for the first
example, the inspectors identified that a licensed operator informed the Pilgrim medical
officer during the physical examination in December 2010 that he/she had been put on
hypertension medication. For the second example, Entergy staff, during their October
2011 extent of condition review of medical records, identified that vision test results
documented on an operator's August 2010 medical exam warranted NRC notification
due to a change in the operator's vision (the operator needed corrective lenses). Pilgrim
staff did not notify the NRC of these medical changes until November 10, 2011, a period
greater than 30 days.
Analvsis: The inspectors determined that Entergy's failure to notify the NRC within
30 days of discovering the change in medical condition for two licensed operators was a
performance deficiency that was within Entergy's ability to foresee and correct and
should have been prevented. The inspectors determined that Traditional Enforcement
applies, as the issue had the potential to impact the NRC's ability to perform its
Enclosure
17
regulatory function because if a licensed operator has a change in medical condition, the
NRC may need to perform a review for consideration of a licensing action. Specifically,
Entergy had not notified the NRC within 30 days of learning of a change in medical
condition for two licensed operators for which a license condition was required. The
performance deficiency was screened against the ROP per the guidance of IMC 0612,
Appendix B, "lssue Screening." No associated ROP finding was identified and no cross-
cutting aspect was assigned.
Enforcement: 10 CFR 50.74 requires, in part, "Each licensee shall notify the
Commission in accordance with 50.4 within 30 days of the following in regard to licensed
operator or senior operator:,..(c) Permanent disability or illness.,." Contrary to the
above, in December 2010 and in August 2010, Entergy did not notify the NRC within
30 days of learning of a change in medical condition for two licensed operators for which
a license condition was required. Specifically, Pilgrim medical staff became aware of
medical conditions that caused two licensed operators to failto meet the requirements of
10 CFR 55.21 and for which license conditions were required, but the staff did not notify
the NRC of these medical changes until November 10, 2011, a period greater than
30 days. As a result of the inspection, Entergy entered this issue into their corrective
action program (CR-PNP-2011-04554), and submitted requests for license amendments.
This issue constitutes an apparent violation in accordance with the NRC's Enforcement
Policy, and its final significance will be dispositioned in separate future correspondence.
(AV 0500029312011005-03, Entergy Did Not Notify the NRC Within 30 Days of
Discovering Changes in Medical Gonditions)
.4 lntroduction: The inspectors identified a Severity Level lV NCV of 10 CFR 55,53 (e) and
(f), "Conditions of Licenses," because Entergy incorrectly credited two individuals for
proficiency watch-standing experience and then these operators subsequently stood
watch without meeting the minimum proficiency requirements necessary to maintain an
active license.
Description: As part of the biennial LORT program inspection, the inspectors evaluated
Pilgrim watch standing records for time on shift. The NRC's regulations related to the
proficiency requirements for NRC licensed personnel are contained in 10 CFR 55.53,
"Conditions of Licenses." Specifically, Section 55.53(e) requires, in part, that to maintain
an active status, the licensee shall actively perform the functions of an operator or senior
operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter. For
licensed operators that do not fulfill these requirements, Paragraph (f) of 10 CFR 55.53
states, in part, that prior to resumption of functions authorized by a license, the facility
licensee shall certify that the individual license holder has completed a minimum of
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as
appropriate and in the position to which the individualwill be assigned.
Procedure No. 1.3.34, "Operations Administrative Policies and Processes," Revision
121 , Section 6.4, states that in order for a licensed RO to receive credit for a shift, the
license holder must stand seven "complete" 8-hour shifts or five "complete" 12-hour
shifts per quarter and shall be logged as filling one (or more) of the following RO
positions for the shift claimed: (a) Operator-at-the Controls, (b) Balance of Plant (BOP),
or (c) Emergency Core Cooling System (ECCS), Contrary to this guidance, during the
2no quarter of 2011, the inspectors identified that one licensed RO stood one of five
required proficiency watches and a second licensed RO stood two of five required
proficiency watches as the "Extra BOP" which is not one of the three credited shift crew
Enclosure
18
positions. These watches were incorrectly credited towards meeting their minimum
required quarterly proficiency requirements. The inspectors also determined that one of
the licensed operators incorrectly took credit for two complete 12-hour watches when the
watch-stander did not stand a complete watch in the control room. Specifically, over the
course of two credited 12-hour watches, the individual was present in the control room
for approximately 8 and 8.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> on April 27,2011, and on May 1,2011, respectively,
These watches did not represent l'complete" watches as defined in Pilgrim procedure
1.3.34.
NUREG 1021, Revision 9, Supplement 1, Section ES-605, states that watch standing
proficiency credit may also be appropriate for certain licensed RO or Senior Reactor
Operator (SRO) shift crew positions that are in excess of those required by a facility's
Technical Specifications (TS) if the licensee has in place administrative controls that (1)
list the title, description of duties, and indication of which positions are required by TSs
and (2) for shift crew positions in excess of TS, a description of how the position is
meaningfully and fully engaged in the functions and duties of the analogous minimum
licensed position(s) required by TS (Note: this same guidance was sent out to the
industry in NRC Regulatory lssue Summary 2007-29, "Clarified Guidance for Licensed
Operator Watch-Standing Proficiency," December 27,20Q7). In addition, TS
Amendment223, Section 5.2.2 states, in part, that at least one licensed RO shall be
present in the control room when fuel is in the reactor, and at least two licensed ROs
shall be present in the control room during reactor startups, scheduled reactor shutdown,
and during recovery from reactor trips. During the period of time in question, Pilgrim was
in a refueling outage requiring only one licensed RO to be present in the control room.
The inspectors determined that the activities assigned to these two operators as the
third (Extra BOP) operator during the periods in question (i.e., April 27-May 19, 2011) did
not meet the guidance established in ES-605, "meaningfully and fully engaged in the
function and duties of the analogous minimum licensed position required by technical
specifications" for the following reasons: 1) The operators were not fully engaged in the
function and duties of the analogous minimum licensed position required by TS, in fact
they were assigned as a third (Extra BOP) on shift during a period when TS required
only one RO to be present at the controls; 2) the operators were not assigned to duties
analogous to minimum TS positions but were instead assigned to perform various
surveillance testing (e.9., valve operability testing) and verifying completion of a startup
checklist as the third ROs assigned on shift; and 3) being assigned as the third RO
(Extra BOP) to the shift, they were essentially assisting the other watch standers and did
not have the primary responsibility to monitor and safely operate the reactor plant, In
this case the inspectors determined that the operators were not actively performing the
duties analogous to minimum TS positions. 10 CFR 55.4 states that "actively performing
the functions of an operator [ROJ or senior operator ISRO] means that an individual has
a position on a shift crew that requires an individual to be licensed as defined in the
facility's technical specifications, and that the individual carries out and is responsible for
the duties covered by that position."
Therefore, by not maintaining their RO license in an active status in the 2no quarter 2011,
the license holders violated 10 CFR 55.53 (f) when they subsequently stood RO watches
in the 3'd quarter 2011 without first reactivating their licenses.
In addition, the inspectors identified that Entergy procedure 1.3.34, section 5.8[3]
describes several specific duties that an additional licensed operator assigned to the
control room could perform that would meet the guidance prescribed in ES-605,
Enclosure
19
"meaningfully and fully engaged in the function and duties of the analogous minimum
licensed position required by technical specifications." For example, verifying control rod
manipulations as a second operator would be an example of a watch-stander that is
meeting this criteria. However, the inspectors determined that the procedure does not
establish adequate controls and guidance for ensuring credit is given only for proficiency
watches where the operator is meaningfully and fully engaged in the function and duties
of the analogous minimum licensed position required by TS.
Analvsis: The inspectors determined that Entergy incorrectly credited two individuals for
proficiency watch-standing experience and then these operators subsequently stood
watch in the control room. This error constitutes a performance deficiency that was
within Entergy's ability to foresee and correct and should have been prevented. The
inspectors determined that Traditional Enforcement applies, as the issue had the
potential to impact the NRC's ability to perform its regulatory function because if a
licensed operator fails to meet the conditions of their license, the NRC may need to
perform a review for consideration of a licensing action, and if the information regarding
an individual's qualifications is not accurately presented, the NRC could potentially make
an incorrect licensing decision based on the inaccurate information. Specifically,
Entergy did not ensure that two reactor operator (RO) licensed individuals maintained
their RO licenses in an active status in the 2no quarter 2011, prior to standing RO
watches in the 3'o quarter 201 1 which violated a license condition as specified in 10 CFR 55.53 (e) and (f). The performance deficiency was screened against the ROP per the
guidance of IMC 0612, Appendix B, "lssue Screening." No associated ROP finding was
identified and no cross-cutting aspect was assigned. This issue is similar to violation
example 6.4.c.1(c) in the NRC Enforcement Policy for a Severity Level lllviolation
because it involves noncompliance with a condition stated on an individual's license.
However, since there were no adverse impacts to nuclear safety, the NRC has
determined that this issue constitutes a Severity Level lV NCV in accordance with the
NRC's Enforcement Policy.
Enforcement: 10 CFR 55.53 (e)states, in part, "...To maintain an active status, a
license holder shall actively perform the functions of an operator or senior operator on a
minimum of seven 8-hour or five 12-hour shifts per calendar quarter. (f) lf paragraph (e)
is not met, before resumption of function...an authorized representative of the facility
licensee shall certify...(2) That the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of
shift function under the direction of an operator or senior operator..." Contrary to the
above, prior to allowing two RO licensed individuals from resuming licensed activities in
the 3rd quarter of 2011, the Entergy did not certify that the qualifications and status of
the operator licensees were current and valid, regarding each individual meeting the
minimum of seven 8-hour or five 12-hour shifts per calendar quarter. In fact, the RO
licensed individuals had not completed the minimum of seven 8-hour or five 12-hour
shifts per calendar quarter, yet were maintained in an active status by Entergy. Entergy
implemented immediate corrective action that included discontinuing the practice of
crediting ECCS and Extra BOP positions for proficiency. ln addition, Entergy plans to
revise procedure 1.3.34 to reflect which RO watch standing positions shall receive
proficiency credit, and to revise the Narrative Log module to eliminate redundant roster
positions and to identify positions that qualify for proficiency. Because this issue had no
adverse impacts to nuclear safety, and has been entered into the corrective action
program (CR-PNP-201 1-04649), this violation is being treated as a Severity Level lV
NCV, consistent with the NRC Enforcement Policy. (NCV 05000293/2011005-04,
Enclosure
20
Entergy Incorrectly Credited Operators Proficiency Watch-Standing Experience
and the Operators Subsequently Stood Watch)
.5 Introduction: The inspectors identified a Green finding of 10 CFR 55.59,
"Requalification," based on a determination that greater than 20 percent of the biennial
requalification written exam questions administered to licensed operators during weeks
three and four of the 2010 examination cycle were unacceptable.
Description: The NRC-required biennialwritten exams are designed to ensure that
licensed operators maintain safe standards of knowledge and ability in order to take
appropriate safety-related actions in response to actual abnormal or emergency
conditions. As part of the biennial LORT Program inspection, the inspectors evaluated
the content of two NRC required biennial written exams that the licensee developed and
administered to licensed operators during weeks three and four of the 2010 examination
cycle. Twenty of the 70 questions reviewed (i.e., approximately 28.6 percent) were
found to be unacceptable containing psychometric flaws such as, more than one
implausible distracter, direct lookup and double jeopardy questions. These
unacceptable written exam flaws collectively affected the level of exam difficulty making
the exams too easy. Entergy procedure EN-TQ-114, "Licensed Operator Training
Program Description," section 5.7[3](h) states in part, "All items should adhere to the
appropriate psychometric attributes and the psychometric error rate should be as low as
possible." and section 5.7[3](d) further states in part, "No test item in the comprehensive
written examination should be a direct lookup question," NUREG-1021, "Operator
Licensing Examination Standards for Power Reactors," Appendix B, "Written
Examination Guidelines," lists implausible distracters as a psychometric deficiency to be
avoided and section C.2.m, states in part, "Avoid "specific determiners" that give clues to
the correct answer. Specific determiners include the following:..(5) implausible
distracters." Adhering to the established qualitative guidelines for developing written
exams is important because it establishes an objective standard used throughout the
nuclear industry to ensure that the NRC-required biennial written exams are written at an
appropriate level of difficulty. The licensee entered this finding into their corrective
action process, an apparent cause evaluation was conducted and corrective actions
were assigned to remove closed reference questions from the biennial exam and to
evaluate revising EN-TQ-1 14 to add the use of a plausibility statement for each
distracter used (CR-PNP-201 1-04561 ).
Analvsis: A performance deficiency was identified in that Entergy did not ensure that
NRC-required biennial comprehensive written examinations met the qualitative
standards established for NRC written examinations. The inspectors determined that
the finding was more than minor because it was associated with the Human
Performance attribute of the Mitigation Systems cornerstone and affected the
cornerstone objective of ensuring the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences (i.e., core
damage). Specifically, the finding affected the quality and level of difficulty of biennial
written exams which potentially impacted Entergy's ability to appropriately evaluate
licensed operators.
The risk importance of this issue was evaluated using IMC 0609, Appendix l, "Licensed
Operator Requalification Significance Determination Process (SDP)." Appendix I was
entered using the number of written exam questions that did not meet the qualitative
standard for the written exam questions, The qualitative standard used by the
Enclosure
21
inspectors is defined in NUREG-1021, Rev. 9, ES-602, Attachment l, "Guidelines for
Developing Open-Reference Examinations," and Appendix B, "Written Examination
Guidelines." Since 28.6 percent of the questions reviewed did not meet the guidance,
Block 16 of Appendix I applied, specifically, "Were more than 20 percent of the written
questions sampled by the inspectors unacceptable?" Based on this screening criteria,
the finding was characterized by the SDP as having very low safety significance (greater
than 20 percent unacceptable), or Green. A review of the possible cross-cutting aspects
was performed and no cross-cutting aspect was identified that would be considered a
contributor to the cause of the finding.
Enforcement: 10 CFR 55.59, "Requalification," Section 4,"Evaluation," requires in part,
that the requalification program must include written examinations which determine
licensed operators'and senior operators' knowledge of subjects covered in the
requalification program and provide a basis for evaluating their knowledge of abnormal
and emergency procedures. However, the regulation does not specify a requirement for
the quality of exam material. Therefore, no violation of regulatory requirements
occurred. Enforcement action does not apply because the performance deficiency did
not involve a violation of a regulatory requirement. Entergy entered this issue into the
corrective action program (CR-PNP-201 1-04561). Because this finding does not involve
a violation of regulatory requirements and has very low safety significance, it is identified
as a FlN. (FlN 0500029312011005-05, Written NRC BiennialWritten Examinations
Did Not Meet Qualitative Standards)
1R12 Maintenance Effectivenesg (71111.12 - 1 sample)
a. lnspection Scope
The inspectors reviewed the 10 CFR 50.65(b) Scoping Evaluation of Alternate Shutdown
Panels (ASP) in order to assess the effectiveness of maintenance activities on ASP
performance and reliability. The inspectors verified that ASPs were evaluated for
scoping under the maintenance rule in accordance with 10 CFR 50.65, Requirements for
Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The inspectors
reviewed system health reports, corrective action program documents, maintenance
work orders, and maintenance rule basis documents to ensure that Entergy was
identifying and properly evaluating performance problems within the scope of the
maintenance rule.
b. Findinqs
No findings were identified.
1R13 Maintenance RiskAssessments and EmergentWork Control (71111.13- 3 samples)
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the
maintenance and emergent work activities listed below to verify that Entergy performed
the appropriate risk assessments prior to removing equipment for work. The inspectors
selected these activities based on potential risk significance relative to the reactor safety
cornerstones. As applicable for each activity, the inspectors verified that Entergy
performed risk assessments as required by 10 CFR 50.65(aX4) and that the
Enclosure
22
assessments were accurate and complete. When Entergy performed emergent work,
the inspectors verified that Operations personnel promptly assessed and managed plant
risk. The inspectors reviewed the scope of maintenance work and discussed the results
of the assessment with the station's probabilistic risk analyst and Operations personnel
to verify plant conditions were consistent with the risk assessment. The inspectors also
reviewed the technical specification requirements and inspected portions of redundant
safety systems, when applicable, to verify risk analysis assumptions were valid and
applicable requirements were met.
. Yellow Risk during Reactor Core lsolation Cooling system maintenance
. Green Risk with Low Pressure Coolant Injection system unavailable, 'A' pressure
sensor for the Automatic Depressurization System Maintenance, and Recirculation
Flow Converter Calibration
o Yellow Risk with High Pressure Coolant Injection system unavailable and
maintenance being performed on the'B'Turbine Building Closed Cooling Water heat
exchanger
b. Findinqs
No findings were identified.
1R15 Operabilitv Determinations and Functionalitv Assessments (71111.15 - 3 samples)
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-
conforming conditions:
. CR-PNP-2011-4342, Seismic Monitoring Equipment Trouble Alarm
. CR-PNP-2011-5388, Safety Relief Valve 203-3C Leaking
. CR-PNP-2O11-5355, Main Steam lsolation Valve 28 Position Indication Limit Switch
Failed Post Maintenance Test
The inspectors selected these issues based on the risk significance of the associated
components and systems. The inspectors evaluated the technical adequacy of the
operability determinations to assess whether technical specification operability was
properly justified and the subject component or system remained available such that no
unrecognized increase in risk occurred. The inspectors compared the operability and
design criteria in the appropriate sections of the technical specifications and UFSAR to
Entergy evaluations to determine whether the components or systems were operable.
Where compensatory measures were required to maintain operability, the inspectors
determined whether the measures in place would function as intended and were
properly controlled by Entergy. The inspectors determined, where appropriate,
compliance with bounding limitations associated with the evaluations.
b. Findinqs
No findings were identified.
Enclosure
23
1R19 Post-Maintenance Testinq (71111.19 - 5 samples)
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed
below to verify that procedures and test activities ensured system operability and
functional capability. The inspectors reviewed the test procedures to verify that the
procedures adequately tested the safety functions that may have been affected by the
maintenance activity, that the acceptance criteria in the procedure was consistent with
the information in the applicable licensing basis and/or design basis documents, and that
the procedure had been properly reviewed and approved. The inspectors also reviewed
test data to verify that the test results adequately demonstrated restoration of the
affected safety functions.
r Reactor Core lsolation Cooling Trip & Throttle Valve Maintenance
. Eight Year Preventive Maintenance Work and testing on electrical components for
the'B' Emergency Diesel Generator (EDG)
. 'B' EDG Replacement of Air Start Motors, Fuel Tank Level Calibration, and
Turbocharger Maintena nce
. 'B'EDG Emergency Diesel Generator Lockout During Testing
. Main Steam lsolation Valve AO-203-2B Cable Replacement
b. Findinss
No findings were identified.
1R20 Refuelinq and Other Outaoe Activities (71111.2A - 1 sample)
.1 Forced Outaqe 19-2
a. Inspection Scope
The inspectors reviewed the outage plan and shutdown risk assessments for a forced
outage performed from November 17,2011, through November 25,2011. The outage
was performed following a plant shutdown due to a 'B'feedwater check valve (a
containment isolation valve) steam leak. The documents reviewed during the inspection
are listed in the Attachment. During this outage, the inspectors observed plant shutdown
and start-up activities including the outage activities listed below:
r Hot and Cold Shutdown Cooling Control;
. Shutdown Risk Assessment and Risk Management;
r lmplementation of Technical Specifications;
o Outage Control Center Activities;
r Plant Startup; and
. Licensee identification and resolution of problems.
b. Findinqs
No findings were identified.
Enclosure
24
.2 Forced Outaqe 19-3
a. lnspection Scope
The inspectors reviewed the outage plan and shutdown risk assessments for a forced
outage performed from December 27 , 2011 , through January 1 , 2012. The outage was
performed following a plant shutdown due to Safety Relief Valve leakage. The
documents reviewed during the inspection are listed in the Attachment. During this
outage, the inspectors observed plant shutdown and start-up activities including the
outage activities listed below:
o Hot and Cold Shutdown Cooling Control;
. Shutdown Risk Assessment and Risk Management;
r lmplementation ofTechnical Specifications;
. Outage Control Center Activities;
. Plant Startup; and
. Licensee identification and resolution of problems.
b. Findinqs
No findings were identified.
1R22 Surveillance Testins (71111.22 - 4 samples)
a. lnspection Scope
The inspectors observed performance of surveillance tests andlor reviewed test data of
selected risk-significant structures, systems, and components (SSCs) to assess whether
test results satisfied technical specifications, the UFSAR, and Entergy's procedure
requirements. The inspectors verified that test acceptance criteria were clear, tests
demonstrated operational readiness and were consistent with design documentation,
test instrumentation had current calibrations and the range and accuracy for the
application, tests were performed as written, and applicable test prerequisites were
satisfied. Upon test completion, the inspectors considered whether the test results
supported that equipment was capable of performing the required safety functions. The
inspectors reviewed the following surveillance tests:
a 'A' Residual Heat Removal Pump Quarterly surveillance test
a 'D'Salt Service Water Pump In-Service Test (lST)
o High Pressure Coolant Injection (HPCI) Quarterly IST and HPCI Quarterly Valve
Operability Test
Local Leak Rate Test of Feedwater Discharge Check Valve and Containment
lsolation Valve (ClV) 6-CK-628
b. Findinos
No findings were identified.
Enclosure
25
2. RADTATTON SAFETY (RS)
Cornerstone: Occupational / Public Radiation Safety
2RS01 Radioactive Hazard Assessment and Exposure Controls (71124.01)
a. Inspection Scope
During the period from October 17,2011, through October 21,2011, the inspector
conducted the following activities to verify that Pilgrim properly assessed the radiological
hazards in the workplace and implemented appropriate radiation monitoring and
exposure controls during refueling outage operations. lmplementation of these controls
was reviewed against the criteria contained in 10 CFR Part 20, Standards for Protection
Against Radiation, relevant Technical Specifications, and the licensee's procedures.
Inspection Planning
o The inspector reviewed radiation protection program self-assessments and audits.
Radioloqical Hazard Assessment
o The inspector verified that Pilgrim assessed the potential impact of higher dose rates
in steam-affected areas during unit down-powers.
o The inspector reviewed the two most recent surveys for each elevation of the
Reactor Building and other selected spaces.
. The inspector walked down the facility, including the Reactor Building, to evaluate
material and radiological conditions. The inspector verified the integrity and postings
of the Locked High Radiation Areas (LHRA) in the Reactor Building and the
Radwaste Processing area.
. The inspector verified the surveys included identification of hot particles, alpha
emitters, potential airborne radioactive material, hazards associated with work
activities, and severe radiation fields, as appropriate.
lnstructions to Workers
. The inspector toured radioactive material storage areas and verified containers were
labeled and controlled in accordance with 10 CFR 20.1904, "Labeling Containers."
. The inspector reviewed radiation work permits (RWPs)for entrance into the drywell
to perform in-service inspection (lSl), scaffold work, and insulation work.
. The inspector verified that electronic personal dosimeter (EPD) set-points were
appropriate.
o The inspector reviewed all dosimeter alarms for 2011 and verified that workers
responded appropriately to the alarms and each event was reviewed by Radiation
Protection staff. In most cases. the event was entered into the corrective action
program.
Contamination and Radioactive Material Control
o The inspector reviewed Pilgrim's procedure for the survey and release of material.
Enclosure
26
The inspector verified that instrumentation is used at its typical sensitivity and is
sufficient to control the spread of contamination and prevent the unintended release
of radioactive materials from the site.
o The inspector verified two sealed sources from Entergy's inventory were accounted
for and intact.
. The inspector verified no transactions occurred that involved nationally tracked
sources.
Radioloqical Hazards Control and Work Coveraqe
. The inspector verified conditions were consistent with surveys, RWPs, and worker
briefings.
. The inspector verified the adequacy of radiation protection job coverage,
contamination control, and job area surveys.
. The inspector verified licensee controls for work areas with significant dose gradients
were adequate.
r The inspector reviewed the controls in place at the spent fuel pool for highly
activated material stored in the pool. The inspector verified appropriate controls
were in place.
. The inspector verified posting and physical controls for high radiation areas were
appropriate at the Reactor Water Clean Up Heat Exchanger room and the Backwash
Receiver Tank room.
Risk-Siqnificant Hiqh Radiation Area and Very Hiqh Radiation Area Controls
. The inspector discussed the controls and procedures in place for high radiation
areas (HRA) and very high radiation areas (VHRA) with the Radiation Protection
Manager (RPM).
o The inspector discussed the controls in place for special areas that have the
potential to become VHRAs during certain plant operations with a first line health
physics supervisor,
. The inspector verified that Pilgrim's controls for all VHRAs ensure that individuals will
not be able to gain unauthorized access.
Radiation Worker Performance
. During observations of workers, the inspector verified workers were aware of the
work area radiological conditions and the RWP requirements. The inspector
observed that workers performed activities in accordance with the RWP
requirements.
. The inspector reviewed condition reports (CRs) for human performance errors and
observable trends.
Radiation Protection Technician Proficiencv
. During observations of radiation protection technicians, the inspector verified the
technicians were aware of the area radiological conditions and the RWP
requirements. The inspector observed that technicians performed activities in
accordance with their training and qualifications.
Enclosure
27
. The inspector reviewed CRs for radiation protection technician errors and observable
trends,
Problem fdentification and Resolution
. The inspector verified problems associated with radiation monitoring and exposure
control are being identified at an appropriate threshold.
b. Findinqs
No findings were identified.
2RS02 Occupational As Low As ls Reasonablv Achievable Planninq and Controls (71124.02)
a. Inspection Scope
During the period from October 17,2011, through October 21,2011, the inspector
conducted the following activities to verify that the licensee was properly implementing
operational, engineering, and administrative controls to maintain personnel exposure As
Low As is Reasonably Achievable (ALARA). lmplementation of these controls was
reviewed against the criteria contained in 10 CFR Part2Q, applicable industry standards,
and the licensee's procedures.
lnspection Planninq
r The inspector reviewed Pilgrim's collective exposure history including the three year
rolling average.
r The inspector reviewed the specific trends in collective exposures and source term
measurements.
. The inspector reviewed the site specific procedures associated with maintaining
occupational exposures ALARA.
Radioloqical Work Planning
r The inspector obtained a list of the work activities ranked by estimated exposure for
the Spring 2011 refueling outage.
r The inspector reviewed the ALAM work activity evaluations, exposure estimates,
and exposure control requirements.
. The inspector verified Pilgrim identified appropriate dose mitigation techniques,
defined reasonable dose goals, included decreased worker efficiency from use of
respirators and heat stress, and included remote technologies.
. The inspector compared the actual exposure received with the dose estimates and
the actual hours with the estimated hours.
. The inspector reviewed post job reviews and verified that Pilgrim performs in-
progress reviews at two set-points, 40 pgrcent of estimate and 80 percent of
estimate, prior to actual exposure reaching the estimates. The inspector verified
problems identified in the post job reviews were entered into the corrective action
program.
Verification of Dose Estimates and Exposure Trackino Svstems
Enclosure
28
. The inspector reviewed the assumptions and basis described in the RWP and
ALARA packages for in-service inspection activities, reactor disassembly and
assembly activities, and scaffold activities. The inspector reviewed the "ALAM
Program" and "Radiation Work Permits" procedures to determine Pilgrim's
methodology for estimating exposures for specific work activities.
Source Term Reduction and Control
. The inspector reviewed Pilgrim's source term reduction program and the effects on
dose rates.
Radiation Worker Performance
. See section 2RS01, (Radiation Worker Performance and Radiation Protection
Technician Proficiency)
Problem ldentification an4 Resolution
. The inspector verified that problems associated with ALARA planning and controls
are identified in Pilgrim's corrective action program and properly addressed.
b. Findinqs
No findings were identified.
2RS03 ln-Plant Ai[Forne Radioactivitv Control and Mitiqation (71124.03)
a. Inspection Scope
During the period from October 17 , 2011, through October 21, 2011, the inspector
conducted the following activities to verify that the licensee was controlling in-plant
airborne concentrations consistent with ALARA. lmplementation of these controls was
reviewed against the criteria contained in '10 CFR Part20, applicable industry standards,
and the licensee's procedures.
Inspection Planninq
r The inspector reviewed Pilgrim's UFSAR to identify potential airborne area and the
associated ventilation systems or airborne monitoring instrumentation.
o The inspector reviewed Pilgrim's procedures for maintenance, inspection, and use of
respiratory protection equipment.
Enqineerinq Controls
o The inspector verified Pilgrim used ventilation systems as part of its engineering
controls to control airborne radioactivity. The inspector verified that the reactor
building and the spent fuel pool ventilation systems have adequate ventilation airflow
capacity and particulate filter/charcoal unit efficiencies are adequate.
Enclosure
29
Use of Respiratorv Protection Devices
. The inspector verified the air used in Self-Contained Breathing Apparatus (SCBA) is
tested and meets Grade D quality.
. The inspector verified training records for several individuals deemed fit to use
respiratory devices.
o The inspector observed respiratory equipment storage areas and verified the
physical condition of the device components. The inspector verified onsite personnel
assigned to repair vital components have received vendor-provided training.
Self-Contained Breathinq Apparatus for Emerqencv Use
. The inspector observed the monthly inspection of four SCBAs staged in various
locations including the Control Room. The inspector verified Pilgrim's capability to
refill and transport bottles to and from the control room and the Operations Support
Center during emergency conditions.
o The inspector verified control room operators and shift radiation protection
technicians are trained and qualified in the use of SCBAS. The inspector also
verified personnel assigned to fill bottles are trained and qualified to that task.
o The inspector verified appropriate mask sizes are available and that the control room
operators on duty had no facial hair that would interfere with the sealing surface of
the face seal and those that required corrective lenses had respiratory corrective
lenses readily available in the control room.
. The inspector reviewed maintenance records for the four SCBAs inspected and
verified any work performed is done by a contractor with certified training.
Problem ldentification and Resolution
o The inspector verified that problems associated with control and mitigation of in-plant
airborne radioactivity are put in the corrective action program and properly
addressed for resolution.
b. Findinss
No findings were identified.
2RS04 Occupational Dose Assessment (7 1 124.04)
a. Inspection Scope
During the period from October 17,2011, through October 21,2011, the inspector
conducted the following activities to verify that Pilgrim appropriately monitors
occupational dose. lmplementation of these controls was reviewed against the criteria
contained in 10 CFR Part20, applicable industry standards, and the licensee's
procedures.
Inspection Planninq
o The inspector reviewed audits and self assessments of the radiation protection
program.
Enclosure
30
o The inspector reviewed the most recent National Voluntary Laboratory Accreditation
Program (NVLAP) accreditation report for Pilgrim's vendor.
r The inspector review Pilgrim's dosimetry procedures.
o The inspector verified that Pilgrim has established procedural requirements for
determining when external and internaldosimetry is required.
External Dosimetrv
r The inspector verified that Pilgrim's personnel dosimeters are NVLAP accredited.
. The inspector evaluated the storage of dosimeters on-site. Pilgrim requires
dosimeters be stored on-site. The inspector verified that Pilgrim does not use non-
NVLAP dosimeters.
. The inspector verified the correction factor used for electronic dosimeters is based
on sound technical principles. The inspector reviewed condition reports for the trend
analysis of electronic dosimeters and the implemented actions.
lnternal Dosimetrv
o The inspector verified the procedures used to assess dose from internally deposited
nuclides address methods for determining if an individual is internally or externally
contaminated, the release of contaminated individuals, the determination of entry
route, and assignment of dose. The inspector verified that the frequency of whole
body count measurements is consistent with the biological half-life of the potential
nuclides available for intake. The inspector verified that whole body counting is the
method for screening intakes. The inspector reviewed whole body counts performed
for contaminated individuals and verified that each had sufficient counting time/low
background, used an appropriate nuclide library, and anomalous peaks/nuclides
received appropriate disposition. The inspector verified that hard-to-detect nuclides
are accounted for in the dose assessments.
o The inspector reviewed in-vitro monitoring for divers to determine tritium intake. The
inspector reviewed the adequacy of collection and storage of samples,
r The inspector reviewed the adequacy of dose assessments based on
airborne/Derived Airborne Concentration (DAC) monitoring. The inspector verified
that Pilgrim has not had to perform DAC calculations during the assessment cycle.
r The inspector reviewed internal dose assessments for which an actual internal
exposure greater than 10 millirem was assigned.
Special Dosimetric Situations
. The inspector reviewed several skin dose assessments. Pilgrim uses VARSKIN to
perform the calculations.
o The inspector reviewed Pilgrim's neutron dosimetry program. The inspector verified
Pilgrim uses the vendor's TracEtch chip and that calculations account for the gamma
radiation.
o The inspector verified that Pilgrim appropriately assigns total effective dose
equivalent (TEDE), shallow dose equivalent (SDE) and lens dose equivalent (LDE)
to individuals from both internal and external monitoring results, supplementary
information, and surveys including air monitoring results as required.
Problem ldentification and Resolution
Enclosure
31
' The inspector verified that problems associated with occupational dose assessment
have been identified at the appropriate threshold and properly addressed in Pilgrim's
corrective action program.
b. Findinqs
No findings were identified.
2RS05 Radiation Monitorinq Instrumentatign (7 1 124.05)
a. lnspection Scope
During the period from October 17 , 2011, through October 21, 2011, the inspector
conducted the following activities to verify that the licensee was ensuring the accuracy
and operability of radiation monitoring instruments.
Calibration and Testinq Proqram
Laboratory l nstrumentation
o The inspector verified that appropriate corrective actions were implemented for
instrument response to indications of degraded instrument performance.
Portable Survey Instruments, Area Radiation Monitors, Electronic Dosimetry, and Air
Samplers/Continuous Air Monitors
. The inspector verified that Pilgrim evaluated the possible consequences of
instrument use since the last successful calibration or source check for two
instruments that either failed source check or calibration.
4. OTHER ACTIVITIES
4AA1 Performance lndicator Verification (7 1151)
.1 Mitiqatinq Svstems (2 samples)
a. Inspection Scope
The inspectors reviewed Performance lndicator (Pl) data to determine the accuracy and
completeness of the reported data.
o Emergency AC Power from the fourth quarter 2010 through the third quarter 2011
lMS06l
. Cooling Water (Salt Service Water/Reactor Building Closed Cooling Water) from the
fourth quarter 2010 through the third quarter 2011 [MS10]
The review was accomplished by comparing reported Pl data to confirmatory plant
records and data available in plant logs, Condition Reports (CRs), Licensee Event
Reports (LERs), and NRC inspection reports. To determine the accuracy of the
Enclosure
32
performance indicator data, inspectors used definitions and guidance contained in the
Nuclear Energy Institute (NEl) Document 99-02, "Regulatory Assessment Performance
lndicator Guideline," Revision 6, and NUREG-1022,"Event Reporting Guidelines 10
CFR 50.72 and 10 CFR 50.73." The documents reviewed during the inspection are listed
in the Attachment.
b. Findinss
No findings were identified.
.2 Occupational Exposure Control Effectiveness (1 sample)
a. Inspection Scope
The inspector reviewed implementation of Entergy's Occupational Exposure Control
Effectiveness Pl Program. Specifically, the inspector reviewed recent CRs, and
associated documents, for occurrences involving locked HRAs, VHRAS, and unplanned
exposures against the criteria specified in Nuclear Energy Institute (NEl) 99-02, to verify
that all occurrences that met the NEI criteria were identified and reported as Pls. This
inspection activity represents the completion of one sample relative to this inspection
area; completing the annual inspection requirement.
b. Findinqs
No findings were identified.
4c42 Problem ldentification and Resolution (71152)
.1 Routine Review of Problem ldentification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure71152, "Problem ldentification and Resolution," the
inspectors routinely reviewed issues during baseline inspection activities and plant
status reviews to verify that Entergy entered issues into the corrective action program at
an appropriate threshold, gave adequate attention to timely corrective actions, and
identified and addressed adverse trends. In order to assist with the identification of
repetitive equipment failures and specific human performance issues for follow-up, the
inspectors performed a daily screening of items entered into the corrective action
program and routinely attended condition report screening meetings.
b. Findinqs
No findings were identified.
,2 Semi-Annual Trend Review (1 sample)
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection
Procedure 71152, "Problem ldentification and Resolution," to identify trends that might
Enclosure
33
indicate the existence of more significant safety issues. ln this review, the inspectors
included repetitive or closely-related issues that may have been documented by Entergy
outside of the corrective action program, such as trend reports, Pls, major equipment
problem lists, system health reports, maintenance rule assessments, and maintenance
or corrective action program backlogs. The inspectors also reviewed Entergy's
corrective action program database to assess condition reports written in various subject
areas (equipment problems, human performance issues, as well as individual issues
identified during the NRCs daily condition report review (Section 4OA2.1). The
inspectors reviewed Entergy's quarterly trend reports to verify that Entergy personnel
were appropriately evaluating and trending adverse conditions in accordance with
applicable procedures.
b. Findinqs and Observations
lmplementation of the Operabilitv Determination Process
The inspectors have continued to observe deficiencies in the areas of Operability
Determinations, including quality, timeliness, conservative decision making, and entry
into Technical Specifications. The inspectors have discussed these observations at the
time of their occurrence, during quarterly exit meetings, and during semi-annual trend
review discussions. Training was conducted by the Operations and Engineering
departments and improvements were subsequently noted in the quality and level of
detail in some operability samples in 2011. In addition, CR-PNP-2011-0137 and CR-
PNP-2011-1140 were written by the Operations Department in January and March of
2011 respectively, to assess operability shortfalls and to address programmatic areas for
improvement. As a corrective action to CR-PNP-2O11-0137, further operability training
was conducted by the Operations Department. However, additional recent examples
have been identified by the inspectors during the past six months, including:
The operability of a CR documenting that the ripple voltage for a power supply for the "A"
RHR containment spray flow header was out of specification. The immediate
assessment of operability was conducted approximately 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after identification and
no assessment of a limit for allowed ripple voltage was discussed. No extent of
condition assessment was performed and the "8" loop was subsequently found
significantly out of specification and declared inoperable as a result. Compensatory
measures to periodically measure "A" loop ripple voltage were not considered in the
original operability assessment when the nature of the degradation was unknown.
These were subsequently put in place when the "B" loop was also found out of
specification.
The operability assessment for a CR documenting control rod scram times which may be
affected by seismic concerns was not originally identified as "Operable-Compensatory
Measure," even though the operability evaluation required actions to be taken under
certain plant conditions to maintain control rods operable. The recognition and
designation of compensatory measures to maintain operability continues to be an area
that requires improvement.
A CR documenting misalignment and a bent pin on a connector for MSIV 28 was not
submitted to the control room. The inspectors brought this to the attention of Operations
and scheduling personnel who had initiated the CR. The subsequent operability
assessment indicated that the assessment of the condition was covered under another
Enclosure
34
CR that documented the replacement of MSIV cables, However, the other CR did not
address the as-left condition of the misaligned connector and the bent pin and the basis
for acceptability of this condition and system operability.
The inspectors concluded that the operability determination process improvements
remain a work in progress and corrective actions and progress in response to this trend
will continue to be evaluated.
.3 Annual Sample: Safetv Relief Valve Operability (1 sample)
a. Insoection Scope
The inspectors selected the issues of safety relief valve (SRV) and automatic
depressurization system (ADS) valve leakage and setpoint test failures as an inspection
sample for in-depth review to assess the corrective actions taken by Entergy to address
these long-standing issues. Entergy's corrective actions included replacing the four ADS
valves and the two safety relief valves with a Target Rock three-stage relief valve
design, increasing the capacity of the two safety relief valves, and amending the license
to allow for a set-point pressure band of +l- 3o/o. Additionally, the new valves were
equipped with multiple leak detection temperature indicators.
The inspectors reviewed procedures, condition reports, engineering evaluations,
modification packages, post maintenance testing, and license amendment
correspondence, and interviewed plant personnel to assess Entergy's problem
identification, evaluation, and corrective action effectiveness with respect to SRV and
ADS valve leakage and set-point drift. Additionally, the inspectors reviewed the
technical specifications and UFSAR to assess the change to the relief valves with
respect to design and licensing bases requirements. Documents reviewed are listed in
the attachment.
b. Findinqs and Observations
No findings were identified.
The ADS valves and SRVs were originally a two-stage Target Rock-type design,
consisting of a pilot-stage assembly and a main-stage assembly. Industry Operating
Experience had shown that two-stage Target Rock relief valves exhibited some amount
of pilot-stage leakage during plant operation. Additionally, the technical specification
allowed valve setpoint pressure band was +/- 1%, which left little margin to maintain the
valves operable in the event of valve leakage. As a result, SRV and ADS valve pilot-
stage leakage were challenges throughout the plant's operating history and caused
several forced shutdowns.
The inspectors noted, based on nuclear industry operating experience, that the
replacement of all the ADS and SRVs with the three-stage Target Rock design was a
significant positive step in reducing the likelihood of relief valve seat leakage.
Additionally, the inspectors noted Entergy's evaluation of an expanded relief valve set-
point pressure band and subsequent license amendment have resulted in significantly
more operating margin for the plant in the event that a valve does exhibit signs of
leakage. Finally, the inspectors determined the addition of several temperature
Enclosure
35
monitoring points on the valve would allow Entergy to more effectively evaluate the
operability of the valve should any leakage occur.
40A3 Follow-Up of Events and Notices of Enforcement Discretion (71 153)
.1 Operator Performance Durinq Thermal Backwash (1 sample)
a. Inspection Scope
The inspectors observed an infrequently performed evolution on November 17,2011.
Specifically, the inspectors observed a plant downpower to support thermal backwash of
the condenser, and control rod scram time testing. The inspectors reviewed procedural
guidance for station power changes and the power maneuver plan, and observed control
room conduct and control of the evolution. During the downpower, significant leakage
was identified from the'B' Feedwater Check Valve (a Containment lsolation Valve
(ClV)). Pilgrim determined that the CIV could not meet its safety function, shut down the
plant, and commenced Forced Outage 19-2 (see section 1R20). The documents
reviewed during this inspection are listed in the Attachment.
b. Findinqs
No findings were identified.
.2 Safetv Relief Valve (SRV-3D) Leakaqe
Inspection Scope
The inspectors observed a plant shutdown on December 27 , 2011 after operators
identified significant first-stage leakage on SRV-3D, Pilgrim determined that the leakage
exceeded limits in their station procedure, entered technical specifications, and shut
down the plant to commence Forced Outage 19-3 and repair the SRV (see section
1R20). The inspectors reviewed procedural guidance for station power changes and the
power maneuver plan, and observed control room conduct and control of the evolution,
The documents reviewed during this inspection are listed in the Attachment.
b. Findinqs
No findings were identified.
40A6 Meetinqs. Includinq Exit
A radiation protection exit meeting was held on October 2Q, 2011. Tom White, Acting
Engineering Director, attended the meeting. At the exit meeting, the inspector confirmed
that no proprietary information was provided to the inspector for the inspection.
On December 20, 2011 , the operator licensing inspectors presented the biennial
licensed operator requalification inspection results to Mr. R. Smith, Site Vice President,
and other members of the Entergy staff.
On January 10, 2Q12, the resident inspectors conducted an exit meeting and presented
the preliminary inspection results to Mr. Robert Smith, and other members of the Pilgrim
Enclosure
36
staff. The inspectors confirmed that proprietary information provided or examined during
the inspection was controlled and/or returned to Entergy, and the content of this report
includes no proprietary information.
4CA7 Licensee-ldentified Violations
The following violation of very low safety significance (Green) was identified by Entergy
and is a violation of NRC requirements which meets the criteria of the NRC Enforcement
Policy for being dispositioned as a non-cited violation (NCV),
Technical specification 5.4,1, "Procedures," requires that written procedures shall be
established, implemented, and maintained including the emergency operating
procedures (EOP) required to implement the requirements of NUREG-0737,
"Clarification of TMI Action Plan Requirements," and NUREG-0737, Supplement 1, as
stated in Generic Letter 82-33, "Order Confirming Licensee Commitments on Emergency
Response Capability Schedules." Contrary to technical specification 5,4.1, portions of
EOP-2, "RPV Control, Failure to Scram," could not have been implemented from
October 8, 2011 through November 6,2011. Specifically, injection of sodium
pentaborate would not have been able to be performed because Pilgrim's warehouse did
not resupply its inventory of the required 12 barrels of sodium pentaborate necessary to
implement EOP-2. Pilgrim entered this issue into the corrective action program as CR-
PNP-201 1-4887 , and obtained the required inventory on November 6, 201 1 . The
inspectors determined that the finding was of very low safety significance (Green) in
accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Phase 1 - Initial
Screening and Characterization of Findings," Mitigating Systems Cornerstone, because
the finding was not a design or qualification deficiency, did not represent a loss of
system safety function, did not represent an actual loss of a single train for greater than
its technical specification allowed outage time, and did not screen as potentially risk
significant due to a seismic, flooding, or severe weather initiating event.
ATTACHMENT: SUPPLEM ENTARY I N FORMATION
Enclosure
A-1
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Enterqv Personnel
G. Bradley Component Engineering
B. Chenard System Engineering Manager
B. Clow Radiation Protection Technician
S. Colburn Supervisor Access Authorization and Fitness for Duty
J. Dreyfuss Plant General Manager
V. Fallacara Engineering Director
A. Felix Auxiliary Operator
J. Fitzsimmons Radiation Protection Supervisor
J. House Superintendent, Initial Operations Training
W. Lobo Licensing Engineer
J. Lynch Director, Nuclear Safety Assurance and Licensing Manager
J. Macdonald Assistant Operations Manager-Shift
T. McElhinney Training Manager
W. Morrow Radiation Protection Supervisor
A. Muse Superintendent, Operations Training
D. Noyes Operations Manager
J. Priest Radiation Protection Manager
R. Smith Site Vice President
J. Taormina Maintenance Manager
M. Thornhill Radiation Protection Supervisor
J. Whalley Operations Shift Manager
T. White Emergency Planning Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened
AV 05000293t201 1 005-01 Licensed Operators Stood Watch Without Being Medically
Qualified (Section 1R1 1)
AV 05000293t201 1 005-02 Entergy did not Provide Complete and Accurate Medicat
Information for Licensed Operator Renewal Applications
(Section 1R1 1)
AV 050002 93 l 201 1 005-03 Entergy did not Notify the NRC Within 30 Days of
Discovering Changes in Medical Conditions
(Section 1R1 1)
Enclosure
A-2
Opened and Closed
NCV 05000293t201 1 005-04 Entergy lncorrectly Credited Operators Proficiency Watch-
Standing Experience and the Operators Subsequently
Stood Watch (Section 1R1 1)
FtN 050002931201 1 005-05 Written NRC BiennialWritten Examinations did not meet
Qualitative Standards (Section 1R1 1)
Enclosure
A-3
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
8.C.40, Seasonal Weather Surveillance, Revision 25
2.2.38, Plant Heating System, Revision 48
2.2.35, Section 7.2, Condensate Storage Tank Temperature Control, Revision 44
Section 1R04: Equipment Aliqnment
Procedures
2.2.8, Standby AC Power System (Diesel Generators), Revision 98
2.2.21, High Pressure Coolant Injection System, Revision 79
8.C.13, Locked Component Lineup Surveillance, Revision 80
8.C.43, Monthly System Valve Lineup Surveillance, Revision 11
Condition Reports
CR-PNP-2011-2498, Valve 23-HO-320, Handwheel to Valve Stem Key Found Missing
CR-PNP-2011-3424, High Pressure Coolant Injection Turbine Exhaust Line Drain Pot Valves
lndicating Open when Normally Closed
CR-PNP-2011-4818, lSl Drawing Not Updated
CR-PNP-2011-5217, HPCI Oil Relay Pilot Supply Block Valve is not listed in the valve checklist
(Attachment 2) in the HPCI system procedure 2.2.21
Technical Specifications:
3.2.8, Protective Instrumentation
3.5.C, High Pressure Coolant Injection System
3.13, Inservice Code Testing
Miscellaneous
Updated Final Safety Analysis Report, Section 8.5, Standby AC Powersource
FSAR, Section 6.4.1, High Pressure Coolant Injection System
P&lD M243, High Pressure Coolant Injection System, Revision 53
P&lD M244, Sheet 1, High Pressure Coolant Injection System, Revision 31
P&lD M244. Sheet 2, High Pressure Coolant Injection System, Revision 9
Section 1R05: Fire Protection
Procedures
5.5.2, Special Fire Procedure, Revision 48
Condition Reports
CR-PNP-2011-4960, Blue matting is in contact with LS-9028; the level switch provides RBCCW
Pump Area Leakage alarm to main control room
CR-PNP-2011-4961, Tools such as tape, channel locks, screwdriver, and wire cutters were
adrift in the I Beam next to 815; this was reported by the NRC
CR-PNP-2011-4962, Sheet metal is leaning upright against the west wall of the 'A'Aux Bay;
one of the sheets has slid down such that it is behind, and in contact with the tubing for
FT-6240 "A SSW Loop Flow Transmitter." This was identified by the NRC resident.
Enclosure
A-4
CR-PNP-201 1-51 1 1 , During an NRC walkdown of fire area 1.21 fue zone 1 .21 'A' RBCCW
room the inspector questioned why hose reel RA-43-06 in fire area 1.22'B' RBCCW
room was noted in section F (Fire Protection Equipment) of the FHA
CR-PNP-2011-2239, Dry Chem Cart Outside of High Pressure Coolant Injection Room Found
Blocked
CR-PNP-2011-3338, Housekeeping lssues ldentified During High Pressure Coolant Injection
Room Walkdown
CR-PNP-201 1-3963, High Pressure Coolant Injection Exhaust Line Vacuum Breaker Check
Valve Insulation Not Replaced
CR-PNP-2011-5116, Found Combustible Material in a Level 1 Combustible Free Zone
CR-PNP-2011-4795,ldentified Wooden Stairs Down on Torus Room Floor
Maintenance OrdersMork Orders
WO 52251827, Task 01
WO 52294163, Task 01
WO 52302684, Task 01
Technical Specifications:
3.5.C, High Pressure Coolant Injection System
Miscellaneous
Fire Hazards Analysis
Compensatory Actions and Disabled Annunciator Log
Fire Door Inspections
Fire Damper Inspections
FSAR, Section 6.4.1, High Pressure Coolant Injection System
P&lD M243, High Pressure Coolant lnjection System, Revision 53
P&lD M244, Sheet 1, High Pressure Coolant Injection System, Revision 31
P&lD M244, Sheet 2, High Pressure Coolant lnjection System, Revision 9
'A' RBCCW Room Function Test Zone 2A
Section 1R11: Licensed Operator Requalification Proqram
Miscellaneous
LORT/NRC Simulator Exam Scenario, SES-2011-05, EPR Failure, Reactor
Recirculation Seal Failure, Loss of Normal Feed, Anticipated Transient Without Scram,
Loss of Offsite Power. and Torus Leak
Procedures
EN-TQ-114, Licensed Operator Requalification Training Program Description, Revision 6
EN-NS-112, Nuclear Management Manual, Medical Program, Revision 8
PNPS 1.3.34, Operations Administrative Policies and Procedures, Revision 121
TQF-201-1M05, Remedial Training Plan, Revision 8
RTYPE H6.09, Procedure 9.1, APRM Calibration, Revision 24
O-RO-03-03, NRC License Training Program Reactor Startup Competency Evaluation,
Revision 10
O-RQ-04-01-138, May 2011 IRM SCRAM Event Review Instructor Guide, Revision 0
O-RQ-04-04-68, Reactor Startup and Criticality Template Instructor Guide, Revision 0
License Medical Restrictions List
Licensee Watch-Standing Proficiency List
Enclosure
A-5
Condition Reports:
cR-PNP-2011-Q2475
CR-PNP-201 1-04554
CR-PNP-201 1-04355
CR-PNP-201 1-04561
CR-PNP-201 1-04649
Simulator Work Orders (closed):
A900009
A900345
8000041
8000046
80001 1 2
80001 1 6
8000126
80001 31
80001 32
80001 36
8000145
8000146
8000147
80001 60
Simulator Work Orders (open):
DR-Ag-100
DR-80-070
DR-81-034
DR-B1-044
Simulator Performance Tests:
T.1 9.3 w/T.S, Core Thermal Power Evaluation @ 50 percent
T.1 9.3 w/T.5, Core Thermal Power Evaluation @75 percent
T.10 AT02 3.27.2, ATWS with Failure to Initiate ARI
T.10 ED24 3.20.2, Total Loss of All AC Power
Section 1 Rl2: Maintenance Effectiveness
Procedures
EN-DC-204, Maintenance Rule Scope and Basis, Revision 2
EN-DC-205, Maintenance Rule Monitoring, Revision 3
Condition Reports
CR-PNP-201 1-4803, Need to Review the Maintenance Rules Scoping of Alternate
Shutdown Panels
List of Condition Reports Addressing Alternate Shutdown Panel Degraded Conditions over
the last several years
Enclosure
A-6
Miscellaneous
Maintenance Rule Basis Documents for Residual Heat Removal, Reactor Core
lsolation Cooling, High Pressure Coolant Injection, and Automatic Depressurization Systems
Section 1R13: Maintenance Risk Assessments and Emerqent Work Control
Procedures
1.5.22, Risk Assessment Process, Revision 14
8.M.2-2.3.1, ADS-Pump Discharge AC Interlock, Revision 31
LM.2-3.6.5, Neutron Monitoring System Flow converter Functional and
Calibration Test, Revision 37
8.5.2.2.1, LPCI System Loop A Operability-Pump Quarterly and Biennial
(Comprehensive) Flow Rate Tests and Valve Tests, Revision 53
Miscellaneous
Equipment Out-of-Service Quantitative Risk Assessment Tool
RCIC Super Window 2011 Maintenance Activity List
Control Room Logs
Weekly Risk Assessment for 11114111
Section I R1 5: Operabilitv D.eterminations and Fu nctionalitv Assessments
Procedures
5.2.1, Earthquake, Revision 34
EN-OP-111, Operational Decision-Making lssue (ODMI) Process, Revision 6
1.3.109, lssue Management, Revision 8
2.4.29, Stuck Open Safety Relief Valve, Revision 25
EN-OP-104, Operability Determination Process, Revision 5
Condition Reports
CR-PNP-2011-4342, Seismic System Trouble, Red error light lit and associated functionality
evaluation
CR-PNP-2011-4446, Seismic instrument on 91' elevation has degraded power supply
CR-PNP-201 1-5388, SRV-203-3C Leaking
CR-PNP-2011-2635, SRV-3C Leaking coming out of refueling outage
CR-PNP-2011-5411, SRV-203-3C, Epic Point RXXO12 indicating 200 degrees F
CR-PNP-2011-5421, Temperature Indication for Safety Valve 203-4A is fluctuating
CR-PNP-2011-5410, SRV tailpipe alarm set incorrectly at 200 degrees F
CR-PNP-2O11-5355, Main Steam lsolation Valve 28 Position Indication Limit Switch Failed
Post Maintenance Test
Section 1 R19: Post-Maintenance Testinq
Procedures
EN-WM-107, Post Maintenance Testing, Revision 3
EN-MA-125, Troubleshooting Control of Maintenance Activities, Revision 8
3.M.4-78, RCIC Turbine Major Preventive Maintenance lnspection, Revision 10
3.M.4-107, RCIC Turbine Overspeed Trip Preventive Maintenance, Revision 6
8.5.5.8, RCIC Overspeed Trip Test, Revision 31
Enclosure
A-7
3.M.3-51, Electrical Termination Procedure, Revision 28
3.M.3-1, A5/AO Busses Protective Relay Calibration/Functional Test and Annunciator
Verification, Revision 1 30
8.9.1, Emergency Diesel Generator and Associated Emergency Bus Surveillance, Revision 122
3.M.3-61.5, Emergency Diesel Generator Two-Year Overhaul Preventive Maintenance,
Revision 43
3.M.3-61.9, Emergency Diesel Generator Four-Year Preventive Maintenance, Revision 8
3.M.3-1, A5/AO Buses 4KV Protective Relay Calibration/Functional Test and Annunciator
Verification, Revision 130
3.M.3-5, Electrical Termination Procedure, Revision 28
8.1.11.21, Mainsteam lsolation Valve Cold Shutdown Operability, Revision 2
8.7 .4.4, Main Steam lsolation Valve Operability, 600/o Power, Revision 24
Condition Reports
CR-PNP-2011-4476, RCIC Trip & Throttle Valve Work identified discrepancies
CR-PNP-201 1-5496, Inspector was concerned that the procedure step to replace the magneto
shorting wire had been signed as not performed
Maintenance OrdersMork Orders
WO 00262619, Replace Hanger for PT-1360-24 Sensing Line
WO 51533719, Tasks 1 & 2, Replacement of screw spindle ring & thrust washer and
post maintenance test for major inspection of the RCIC trip & throttle valve
WO 52314345, Tasks 1-4, Overspeed Trip MaintenanceX-202
WO 52229557, Task 5, Motor Operated Controller (MOC) Potentiometer Checks
WO 52313841, Tasks 4, Exercise Potentiometer on MOC, X-107B
WO 52229557, Task 1, Replace 'B' EDG MOC Potentiometer
WO 52229557, Task 2, Post Installation Test of 'B' EDG MOC Potentiometer
WO 52314423,Task 1 EDG'B'to Bus 46 Relay Calibration and FunctionalTest
WO 52349213, Tasks 1 & 2, Diesel Generator Preventive Maintenance X-1078 Mechanical
WO 52285928, Tasks 1-6, Cat. 24, AOV Overhaul Actuator AO-4522
WO 51532089, Tasks 1-3, EDG 'B' Fuel Oil Level is rising about 4 gallons
WO 00294230, Tasks 1 & 2, 47-CK-301C 'B' EDG Turbo Assist Air Receiver Leaking By
WO 00296754 01, Troubleshoot 'B' EDG Lockout During Testing
WO 00296754 02, Perform Electrical Meggar Testing of generator and cables to breaker
in accordance with 3.M.3-61.5, Attachment 2C
WO 52376404 01, Conduct Procedure 8.9.1, Emergency Diesel Generator and
Associated Emergency Bus Surveillance, Revision 122
WO 00297770, Tasks 3, J58, Embrittled Conductors in Cables SBNSl5BCA & BCC
WO 00290898, Task 2, Stroke Time and Adjust Valve Fast Closure
Miscellaneous
Procurement Engineering Evaluation 49494, Potentiometer, Motor Operated, Standard
Single Turn
Section 1R20: Refuelins and Other Outase Activities
Procedures
3.M.1-45, Outage Shutdown Risk Assessment, Revision 13
2.1.5, Controlled Shutdown from Power, Revision 111
2.1.7, Vessel Heatup and Cooldown, Revision 54
Enclosure
A-8
2.2.23, Automatic Depressurization System, Revision 33
2.4.29, Stuck Open Safety Relief Valve, Revision 25
2.1.5, Controlled Shutdown From Power, Revision 114
Condition Reports
CR-PNP-201 1-5285, Two project managers exceed the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> rule by approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />
CR-PNP-2O1 'l-5286, Maintenance Fin Team Supervisor will violate the fatigue rule to
support outage
CR-PNP'2011-5304, Performed 6 fatigue assessment waivers for the l&C department
CR-PNP-2O11-5300, Four l&C individuals exceeded Fatigue Rule limits during support
of forced outage
CR-PNP-2011-5296, ln the Upper SWGR room, observed Bus A5, Degraded Voltage
relays 127-504-3 and 127-504-4 and Undervoltage Relay 127-504-2 in the
tripped condition
CR-PNP-2011-5259, SRM'C', the as-found high voltage reading
CR-PNP-2QI1-5284,6 PS&O planners exceeded the administrative limit of greater than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period
CR-PNP-2011-5265, There are areas of pipe insulation that are loose and/or missing
CR-PNP-2011-276Q, Drywelltemperature point DRY004 is exceeding its trigger point of 169"F
CR-PNP-2011-5266, Per EN-FAP-OM-006 the Pilgrim GMPO has approved 35
engineering personnel to exceed overtime guidelines
CR-PNP-2011-5278, Checked out of warehouse three new bonnets (PlL-21113) for
6-CK-62B valve, cleaned and inspected, found indications on allthree bonnets in
sealing area
CR-PNP-2011-5281, The following maintenance l&C employees require fatigue
assessment waivers per EN-OM-123
CR-PNP-2011-5282, A Fatigue rule waiver was completed and approved for RPT who
will exceed the 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> break rule and the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 day period rule as per
CR-PNP-2011-5283, Due to the forced outage Mechanical Maintenance violated the
CR-PNP-2O1 1-5315, During inspection of Junction box J207 , a small cut was observed on
the white conductor of cable A2NS3Xa near the cable jacket
CR-PNP-2011-5298, During walkdown of nozzles in the drywell it was discovered that
strong backs for the Drywell biological shield plugs above the N2B (A-20A) and N2J
(A-20C) Nozzles are missing
CR-PNP-2011-5442, CR-PNP-201 1-5355 both check list boxes on the CR were marked
"NO." The CR was not processed through operations, and CRG review then missed
the potential reportability/operability req uirement
CR-PNP-2011-5870, Received Alarm - Relief/Safety Valve Leaking (C9031-42)
CR-PNP-2011-5886, 'B' Feed Pump Minimum Flow Piping Damaged Insulation
CR-PNP-2011-5879, Need a detailed evaluation for utilizing SRV3C Pilot Valve for SRV3D
CR-PNP-2011-5881, Kaye Temperature Readings could not be Validated at C85
CR-PNP-2O11-5891, 'B' Reactor Feed Pump Minimum Flow Valve Cycling at Higher
Power than Expected
CR-PNP-2O11-5923, After substituting rod positions for control rod 18-23 in accordance
with PNPS 2.2.90, # Substituted Rods ln Core on SUBCR display remained at 0
CR-PNP-2011-5922, Control rod 18-23 had no position indication at position 06
Enclosure
A-9
CR-PNP-2011-5921, When entering substitute values for failed rod positions, the RWM
still displayed the number of substitute values as zero
CR'PNP-2011-5920, Unexpected result of Rod Worth Minimizer in response to lost
position indication
CR-PNP-2011-5918, Rod Drift alarm (C905L-A3) on rod 18-23. Rod 18-23 has no
position indication at position 02
Technical Specifications
Technical Specifications 3.3.F, Rod Worth Minimizer (RWM)
50.72, Notification for a Technical Specification Required Shutdown Dated 1212612011
3.6.D, Safety and Relief Valves
Miscellaneous
FSAR 7.16.4.3, Rod Worth Minimizer Function, The RWM sequences stored in the
computer memory are based on control rod withdrawal procedures designed to limit
and, thereby, minimize individual control rod worth to acceptable levels as
determined by the design basis rod drop accident
FSAR 14.5.1, Control Rod Drop Accident
FSAR Chapter 4.4 Nuclear System Pressure Relief System
NRC Information Notice 93-39, Radiation Beams from Power Reactor Biological Shields
Shutdown Schedule
Shutdown Risk Profile
50.72 Notification of Plant Shutdown on 11117111
RPV Cooldown Data
Pilgrim Nuclear Power Station Startup from Forced Outage Power Man. Plan 19-10
OSRC Readiness for Restart Review 11121111
Power Maneuver Plan Dated 1212612011
Power Ascension Profiles
EN-OM-123, Fatigue Management Program, Revision 4
Section 1R22: Surveillance Testing
Procedures
8.5.2.2.1, LPCI System Loop 'A' Operability-Pump Quarterly and Biennial Flow Rate Tests and
Valve Tests 8.5.3.2.1, Salt Service Water Pump Quarterly and Biennial (Comprehensive) Operability and
Valve Operability Tests, Revision 24
8.5.4.1, High Pressure Coolant Injection (HPCI) System Pump and Valve Quarterly and Biennial
Comprehensive Operability, Revision 1 07
8.5.4.4, HPCI Valve (Quarterly) Operability Test, Revision 49
8.7.1.5, Local Leak Rate Testing of Primary Containment Penetrations, lsolation Valves, and
Inspection of Containment Structure, Revision 58
2.1.11.1, System Fill, Vent and Drain Instructions, Revision 21
Condition Reports
CR-PNP-2011-4612, M&TE failure during the RHR 'A'operability required the operability to
be performed twice
CR-PNP-2011-1390, East Salt Service Water Bay Level Reading Downscale
CR-PNP-2011-5451, During LLRT, Valves 6-H0-428 and 6-H0-429 did not provide a vent path
Enclosure
A-10
Maintenance OrdersMork Orders
WO 52354592, Task 01, Perform P-2O3A-LPCI LOOP 'A' Quarterly Operability Test
WO 52375127-01, Perform Salt Service Water Pump 'D' Quarterly Operability Test
Technical Specifications
3,5.B.4, Salt Service Water System
Miscellaneous
FSAR, Section 10.7, Salt Service Water System
Drawing M252, Sheet 2, P&lD Nuclear Boiler, Revision 67
Drawing M243, P&lD HPCI System, Revision 53
Drawing M208, Sheet 1, P&lD Condensate and Feedwater, Revision 68
Local Leak Rate Testing Data Sheets
Section 2RS01: Radiological Hazard Assessment and Exposure Gontrols
Procedures
EN-RP-100, Radiation Worker Expectations, Revision 7
EN-RP 101, Access Control for Radiologically Controlled Areas, Revision 6
EN-RP-102, Radiological Control, Revision 2
EN-RP-105, Radiation Work Permits, Revision 9
EN-RP-108, Radiation Protection Posting, Revision 10
EN-RP-110, ALARA Program, Revision 7
EN-RP-115-01, BRAC Survey Instructions, Revision 0
EN-RP-121, Radioactive Material Control, Revision 6
EN-RP-131, Air Sampling, Revision 8
EN-RP-302, Operation of Radiation Protection lnstrumentation, Revision 1
Audits and Self Assessments
LO11.0140, Inadequate Collective Radiation Exposure Performance lmprovements 912111
RP11-28, Pilgrim Nuclear Power Station 2010 Radiation Protection Program Annual Report
10124111
Survevs
Survey No. Date Time
PNP-1110-0042 10t6t11 031 5
PNP-1110-0039 10t5111 1120
PNP-1110-0033 10t5t11 0840
PNP-1110-0025 10t4t11 0930
PNP-1106-0117 6t14t11 1400
PNP-1109,0073 9t9t11 21oO
PNP-1108-0106 8t12111 0800
PNP-1110-0111 10t14t11 1 500
PNP-1110-0056 10t8t11 1 535
PNP-1110-0001 1ol1l11 1510
PNP-1110-0005 1012111 1510
PNP-1109-0024 914t11 1 500
PNP-1109-0180 9t22t11 1615
PNP-1108-0238 8t30t11 0300
PNP-1110-0104 10t13t11 1 600
Enclosure
A-11
PNP-1109-0050 9t7 t11 2100
PNP-1110-0119 10t16111 1 600
PNP-1110-0063 10tgt11 1725
Condition Reports
CR-PNP-201 0-0069. 1 875
CR-PNP-2011-0621, 3031 , 3544, 3192, 3721, 3757 , 3981
Section 2RS02: Ocgupational ALARA Planninq and Controls
Procedures
EN-RP-100, Radiation Worker Expectations, Revision 7
EN-RP-101, Access Control for Radiologically Controlled Areas, Revision 6
EN-RP-102, Radiological Control, Revision 2
EN-RP-105, Radiation Work Permits, Revision 9
EN-RP-110, ALARA Program, Revision 7
Condition Reports
cR- PNP-2011-1743, 1670, 1619, 1904, 2070, 2335
Post Job Review
2011498, ALARA Post Job Review for IN-SERVICE INSPECTION
2011481, ALARA Post Job Review for Install & Remove Scaffolding
2011539, ALARA Post Job Review for Insulation All Areas
2011506, ALARA Post Job Review to Replace 4 SRV's and 2 Safety Valves, PM Acoustic
Monitors, and ADS Equipment
Section 2RS03: In-Plant Airborne Radioactivitv Control and Mitiqation
Procedures
5.8.2, Emergency Facilities and Equipment Audits, Revision 37
6.7-123, Use of Breathing Air Monitoring and Supply System, Revision 5
6.7.1-201, Operation of the SCBA Air Compressor, Revision 11
6.7.1-202, PNPS Emergency Use Respiratory Protection Equipment Inspection, Revision 0
EN-RP-S01, Respiratory Protection Program, Revision 4
EN-RP-502, lnspection and Maintenance of Respiratory Protection Equipment, Revision 7
EN-RP-503, Selection, lssue, and Use of Respiratory Protection Equipment, Revision 5
SCBA Packs
Pack No. Hiqh Pressure Reducer Serial No.
1 38112-17
13 1 1 5S07200061 06
16 2870105
29 040901 6999
Condition Reports
CR-PNP-201 0-091 5, 3769
oR-PNP-201 1-0441, 0453
Enclosure
A-12
Other
Grade D Air Analysis Results Reports
Air Bank 611110
Compressor 11110110
Compressor 8/30/11
Service Air RM-1 213111
Service Air RM-1 515111
Service Air RAIV-1 8125111
Section 2RS04: Occupational Dose Assessment
Procedures
EN-RP-201, Dosimetry Administration, Revision 3
EN-RP-202, Personnel Monitoring, Revision 8
EN-RP-203, Dose Assessment, Revision 4
EN-RP-204, Special Monitoring Requirements, Revision 4
EN-RP-208, Whole Body Counting / In-Vitro Bioassay, Revision 4
Condition Reports
cR-201 1 -01 35, 1494, 02014, 2029, 3402
Section 4OA1 : Performance lndicator Verification
Condition Reports
CR-2011-0721, Failure of 'B' RBCCW HX
CR-2011-4285, Salt Service Water Pump Motors operating above their full load capacity
Miscellaneous
Mitigating System Performance lndicator (MSPI) Data Sheets for Salt Service Water and
Reactor Building Component Cooling Water Cooling Systems
MSPI Emergency AC Power System October 2010
September 201 1 Datasheets
Control Room Narrative and Tech Spec Logs
NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6
NRC Performance Indicators for Pilgrim Nuclear Power Station
Section 4OA2: Problem ldentification and Resolution
Procedures
EN-FAP-LI-006, Senior Assessment Review Board (SARB) Process, Revision 0
Condition Reports
cR-PNP-2011-2222
cR-PNP-2011-2614
cR-PNP-2011-2635
Enclosure
A-13
Maintenance OrdersMork Orders
WO 0022911214,lmplement EC 5000071989 for RV-203-3A for RFO 18
WO 00229113 10, lmplement EC 5000071989 for RV-203-38 for RFO 18
WO 0022911411, lmplement EC 5000071989 for RV-203-3C for RFO 18
WO 002291 15 1 1, lmplement EC 5000071989 for RV-203-3D for RFO 18
WO 00277163, TE 6284A for SRV D Rose 40 degrees, performed 5114111
WO 52261107 01, 8.5.6.2 ADS Subsystem Manual Opening of Relief Valves (Alt Method)
Miscellaneous
3379-270-7, 6x10 Pilot Operated Main Steam Relief Valve with 3-Way Solenoid Air Operator,
Rev.0
EC 5000071989, SRV/SSV Setpoint and Tolerance lncrease, and Replacement, Rev. 8
ECN29021, FSAR Changes for SRV/SSV Replacement, Rev. 2
PO 10250443, Curtis Wright Test Report for valve 09J-001-2, performed 315111
PO 10250443, Curtis Wright Test Report for valve 09J-001-3, performed 318111
PO 10250443, Curtis Wright Test Report for valve 09J-001-4, performed 3110111
PO 10250443, Curtis Wright Test Report for valve 09J-001-5, performed 3111111
Pilgrim Station 2011 Second Quarter, Quarterly Trend Report
Pilgrim Station 2011 Third Quarter, Quarterly Trend Report
3046, ADS Accumulator Post Operability Time, Rev. 1
Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 235
To Facility Operating License No. DPR-35, dated March 28,2011
SRV/SSV License Amendment 235
Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion
Procedures
2.1.14, Station Power Changes, Revision 106
2.2.94.5, Main Condenser Backwash, Revision 6
Miscellaneous
Power Maneuver Plan dated 11116111
Enclosure
A-14
LIST OF ACRONYMS
ADAMS Agencywide Documents Access and Management System
ALARA As Low As is Reasonably Achievable
CA corrective action
CFR code of federal regulations
crv containment isolation valve
CR condition report
DRP Division of Reactor Projects
DRS Division of Reactor Safety
EDG emergency diesel generator
FSAR Final Safety Analysis Report
HPCI high pressure coolant injection
rMc Inspection Manual Chapter
tsl in-service inspection
LER licensee event report
NCV non-cited violation
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
NVLAP National Voluntary Laboratory Accreditation Program
PI performance indicator
PNPS Pilgrim Nuclear Power Station
RBCCW reactor building closed cooling water
RCtC Reactor Core lsolation Cooling
RFO refueling outage
RPM Radiation Protection Manager
RWP's radiation work permit(s)
SCBA self-contained breathing apparatus
SSC structure, system, or component
UFSAR Updated Final Safety Analysis Report
VHRA very high radiation areas
WO work order
Enclosure