Text

IR 05000293-14-003 and ISFSI Report 07201044-14-002; 04/01/2014 - 06/30/2014; Pilgrim Nuclear Power Station (Pilgrim); Maintenance Risk Assessments and Emergent Work Control and Operability Determinations and Functionality Assessments
	ML14224A067
Person / Time
Site:	Pilgrim
Issue date:	08/11/2014
From:	Raymond Mckinley; NRC/RGN-I/DRP/PB5
To:	Dent J; Entergy Nuclear Operations
	McKinley R
References
	IR 14-003, IR-14-002, ISFSI Rpt 07201044/2014002
	Download: ML14224A067 (54)
	v • d • e

ust 11, 2014

SUBJECT:

PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2014003 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) REPORT 07201044/2014002

Dear Mr. Dent:

On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents the inspection results, which were discussed on July 22, 2014, 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 Commissions rules and regulations and with the conditions of your license.

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

This report documents two violations of NRC requirements, both of which were of very low safety significance (Green). However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violations in this report, you should provide a 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 Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at PNPS. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement, in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at PNPS. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 50-293 License No. DPR-35

Enclosure:

Inspection Report 05000293/2014003 w/Attachment: Supplementary Information

REGION I==

Docket No. 50-293 License No. DPR-35 Report No. 05000293/2014003 Licensee: Entergy Nuclear Operations, Inc. (Entergy)

Facility: Pilgrim Nuclear Power Station Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: April 1, 2014 through June 30, 2014 Inspectors: M. Schneider, Senior Resident Inspector, Division of Reactor Projects (DRP)

E. Carfang, Senior Resident Inspector, DRP B. Scrabeck, Resident Inspector, DRP K. Kolaczyk, Senior Resident Inspector, DRP J. Schoppy, Senior Reactor Inspector, Division of Reactor Safety (DRS)

B. Dionne, Health Physicist, DRS F. Arner, Senior Resident Inspector, DRS H. Gray, Senior Resident Inspector, DRS S. Chaudhary, Senior Reactor Inspector, DRS R. Latta, Senior Reactor Inspector, DRS, Region IV J. Nicholson, Health Physicist, Division of Nuclear Materials Safety Approved By: Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY

IR 05000293/2014003; 04/01/2014 - 06/30/2014; Pilgrim Nuclear Power Station (Pilgrim);

Maintenance Risk Assessments and Emergent Work Control and Operability Determinations and Functionality Assessments.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified two non-cited violations (NCVs) of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Barrier Integrity

Green.

The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.65 paragraph (a)(4) because Entergy did not identify and manage risk for emergent maintenance on primary containment isolation valves (PCIVs).

Specifically, an incorrect risk assessment resulted in Entergy not recognizing an increase in risk to a Yellow condition, and therefore no risk management actions were taken. Entergy has captured this issue in condition report (CR)-PNP-2014-2007, has corrected the inadequate risk assessment, and has initiated an apparent cause evaluation (ACE) to determine causes and appropriate corrective actions.

The performance deficiency was more than minor because if left uncorrected the failure to recognize risk and take appropriate risk management actions has the potential to lead to more significant safety concerns. Moreover, a review of IMC 0612, Appendix E, "Minor Examples," identified that Section 7, Maintenance Rule, Example e, reflected a similar more than minor example, in that the outcome of the overall elevated plant risk put the plant into a higher risk management category and thereby required additional risk management actions. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, issued May 19, 2005, the inspectors determined that this finding is of very low safety significance (Green) because the Incremental Core Damage Probability Deficit for the duration of the activity was less than 1.0 E-6 per year (approximately 1.29 E-7 per year). This finding has a cross-cutting aspect in the area of Human Performance,

Consistent Process, because when faced with the requirement to perform emergent, unscheduled maintenance, Entergy did not use a consistent, systematic approach to make decisions, and did not incorporate appropriate risk insights. Specifically, while Entergy had the tools and processes in place to assess risk for emergent conditions, individuals did not consistently use this process, and therefore did not recognize the elevated risk condition.

[H.13] (Section 1R13)

Green.

The inspectors identified a Green NCV of Technical Specification (TS) 3.7.A,

Primary Containment, because Entergy failed to comply with the TS-required actions for inoperable PCIVs. Specifically, while maintenance was being performed on an inoperable automatic PCIV, Entergy failed to either isolate and deactivate at least one containment isolation valve in the same line, or to complete an orderly shutdown to the Cold Shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Entergy has captured this issue in CR-PNP-2014-2008, and has assigned corrective actions to update the Pilgrim TS bases document to provide additional guidance on acceptable methods of PCIV isolation.

The performance deficiency is more than minor because it is associated with the configuration control attribute of the Barrier Integrity cornerstone, and adversely affected the associated cornerstone objective to provide reasonable assurance that physical design barriers (i.e. containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Entergys failure to close and deactivate a valve in the same line as the inoperable PCIV as required by TS did not ensure the operability of the primary containment. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, effective July 1, 2012, the inspectors determined that this finding is of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components. This finding has a cross-cutting aspect in the area of Human Performance,

Conservative Bias, because Entergy did not use decision-making practices that emphasize prudent choices over those that are simply allowable, or in this case, those that are perceived to be allowable. Specifically, Entergys reliance on the design characteristics of the PCIVs to meet the TS requirement, while refraining to take additional measures to ensure the valves remained closed in the case of personnel error or equipment malfunction, was not conservative. [H.14] (Section 1R15)

REPORT DETAILS

Summary of Plant Status

Pilgrim began the inspection period operating at 100 percent reactor power. On April 19, 2014, Pilgrim reduced power to 50 percent to perform testing on the 1B main steam isolation valve (MSIV) and returned to 100 percent power on the same day. On May 13, 2014, Pilgrim commenced a planned outage and returned to 100 percent power on May 19, 2014. On May 20, 2014, Pilgrim reduced power to 75 percent to perform a control rod pattern adjustment and returned to 100 percent power the same day. On June 17, 2014, Pilgrim reduced power to 50 percent to perform a planned thermal backwash of the main condenser and returned to 100 percent power the same day. On June 19, 2014, Pilgrim reduced power to 88 percent to perform a control rod pattern adjustment, returned to 100 percent power on the same day, and continued to operate at 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review of Entergys plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Entergys procedures affecting these areas and the communication protocols between the transmission system operator and Entergy. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Entergy established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing CRs and open work orders (WOs), and walking down portions of the offsite and AC power systems including the switchyard. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

.2 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of Entergys readiness for the onset of the hurricane season. The review focused on the intake structure, the emergency diesel generators (EDGs), and the station blackout (SBO) diesel generator. The inspectors reviewed station procedures, including Entergys adverse weather procedures and applicable operating procedures to determine what could challenge these systems, and to ensure Entergy personnel had adequately prepared for these challenges. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during adverse weather.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

Main article: IP 71111.04

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

Partial equipment alignment check of the diesel driven fire protection pump and system on April 8, 2014 Control rod drive (CRD) A pump and hydraulic system with CRD B out of service on April 14, 2014 Salt Service Water (SSW) system following lining inspections and spool-piece repairs during a maintenance outage on May 21, 2014 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), TS, WOs, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify 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 staff had properly identified equipment issues and entered them into the corrective action program (CAP) for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

Main article: IP 71111.04S

a. Inspection Scope

During the week of June 16, 2014, the inspectors performed a complete system walkdown of accessible portions of the A train of the reactor building closed cooling water (RBCCW) system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, drawings, equipment line-up check-off lists, system health reports, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs to ensure Entergy appropriately evaluated and resolved any deficiencies.

No findings were identified.

1R07 Heat Sink Performance (711111.07A - 1 sample)

a. Inspection Scope

The inspectors reviewed the HPCI and RCIC area coolers to determine their readiness and availability to perform safety functions. The inspectors reviewed the design basis for the components and verified Entergys commitments to NRC Generic Letter 89-13. The inspectors reviewed the results of cleaning and inspections of the HPCI and RCIC area coolers. The inspectors reviewed the system health reports and discussed the HPCI and RCIC area cooler cooling adequacy with the responsible system engineer. The inspectors verified that Entergy initiated appropriate corrective actions for identified deficiencies.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on May 19, 2014, which included a loss of turbine building closed cooling water (TBCCW), a loss of feedwater heating, the loss of 4160 [volts alternating current] VAC bus A5, the loss of one reactor recirculation pump, the loss of a RHR pump while in torus cooling, and a fire in a RHR pump motor necessitating the declaration of an Alert. Following the trip of an additional TBCCW pump, a manual scram was required, with MSIV closure and maintenance of pressure and level with HPCI, RCIC, and safety relief valves (SRVs). A leak in the RHR piping resulted in an unisolable leak and lowering water level in the torus, requiring an emergency depressurization. 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 TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

For the plant activities listed below, the inspectors observed and reviewed operator performance in the main control room. See section 4OA3 for specific discussion of these activities. The inspectors reviewed operational and alarm response and implementation of procedural guidance. The inspectors also observed control room conduct and control of evolutions and events, in accordance with procedure EN-OP-115, Conduct of Operations, Revision 14.

Reactor Plant downpower to support MSIV timing on April 19, 2014 Reactor Plant shutdown to commence a maintenance outage on May 13, 2014 Reactor power maneuvers to support a rod pattern adjustment on May 20, 2014 B moisture separator drain tank level transient on June 5, 2014

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12Q

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that Entergy was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with 10 CFR 50.65 and verified that the (a)(2)performance criteria established by Entergy staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Entergy staff were identifying and addressing common cause failures that occurred within and across MR system boundaries.

Review of MR (a)(1) action plan to return SSW system from MR (a)(1) status to MR (a)(2) on May 20, 2014 MR function failure determinations, MR(a)(1) action plans, and corrective actions associated with the K110, K111, and K117 instrument air compressors on May 19-20, 2014

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

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 personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Entergy performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Planned elevated risk during RCIC testing with 345 kilovolt (kV) Line 355 out of service for maintenance on April 1, 2014 Planned maintenance on EDG B, 345kV Line 355, and CRD pump B on April 15, 2014 Planned elevated risk during scram discharge instrument volume circuit card replacement on April 18, 2014 Planned elevated risk due to B 125 volts direct current (VDC) Battery Charger and the B Core Spray system out of service for maintenance on April 21, 2014 Emergent work controls and risk assessment due to unscheduled maintenance on PCIVs on May 7, 2014 Shutdown risk assessment during a planned maintenance outage on May 14, 2014

b. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR 50.65 paragraph (a)(4)because Entergy did not identify and manage risk for emergent maintenance on PCIVs.

Specifically, an incorrect risk assessment resulted in Entergy not recognizing an increase in risk to a Yellow condition, and therefore no risk management actions were taken.

Description.

On May 3, 2014, Entergy staff began emergent maintenance on Torus Purge Exhaust Isolation Valve AO-5042A, which is a PCIV. As part of the protective tagging boundary for the maintenance, and in order to comply with Pilgrim TS requirements for PCIVs, Torus Purge Exhaust Isolation Valve AO-5042B, which is in the same line as the inoperable valve undergoing maintenance, was placed in the isolated condition and tagged. Entergy procedure 1.5.22, Risk Assessment Process, requires, in part, that during off-hours and backshifts, the Shift Manager shall be responsible for assessing the risk associated with emergent work, and that the assessment of risk will be performed using the risk assessment profile developed for the existing work week, by the Equipment Out Of Service (EOOS) risk assessment tool, and/or qualitative risk considerations. Entergy staff performed a qualitative risk assessment which considered the isolation function of AO-5042B, and as the valve was already in the isolated condition, Entergy staff concluded that the risk condition remained Green (minimal risk)and that no further risk management actions were required. A quantitative risk assessment using the EOOS risk assessment tool was not performed. However, in addition to the requirement to isolate the primary containment when necessary, AO-5042B also has the requirement to open on demand in the event that emergency conditions require direct venting of the torus, and it is therefore modeled in the Pilgrim EOOS risk model. On May 7, 2014, after the inspectors discussed the risk significance of AO-5042B with Pilgrim operations staff, including its significance in the EOOS risk model, a quantitative risk assessment was performed and it was determined that with AO-5042B removed from service the actual risk condition was Yellow (acceptable risk),requiring risk management actions. Entergy procedure 1.5.22, Risk Assessment Process, states, in part, that a component can be considered able to perform its intended function taking credit for reasonable operator manual actions provided these actions are contained in procedures, are uncomplicated, and do not require diagnosis or repair. Immediate corrective actions were to implement specific proceduralized compensatory measures that directed the removal of the protective tag from AO-5042B in the event that an emergency required the direct venting of the torus. With AO-5042B made available through this specific risk management action, the Yellow station risk level was then allowed to be categorized as Green. Subsequently on May 8, 2014, due to changes in the tagging isolation boundaries, Entergy staff appropriately recognized that the actions to restore AO-5042B to service would no longer meet the criteria to allow it to be considered available, and station risk was appropriately elevated to Yellow.

Analysis.

The inspectors determined that Entergys failure to identify and manage the Yellow risk condition was a performance deficiency that was within Entergys ability to foresee and correct, and therefore should have been prevented. This finding was determined to be more than minor because if left uncorrected the failure to recognize risk and take appropriate risk management actions has the potential to lead to more significant safety concerns. Moreover, a review of IMC 0612, Appendix E, "Minor Examples," identified that Section 7, Maintenance Rule, Example e, reflected a similar more than minor example, in that the outcome of the overall elevated plant risk put the plant into a higher risk management category and thereby required additional risk management actions. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, issued May 19, 2005, the inspectors determined that this finding is of very low safety significance (Green) because the Incremental Core Damage Probability Deficit for the duration of the activity was less than 1.0 E-6 per year (approximately 1.29 E-7 per year).

This finding has a cross-cutting aspect in the area of Human Performance, Consistent Process, because when faced with the requirement to perform emergent, unscheduled maintenance, Entergy did not use a consistent, systematic approach to make decisions, and did not incorporate appropriate risk insights. Specifically, while Entergy had the tools and processes in place to assess risk for emergent conditions, individuals did not consistently use this process, and therefore did not recognize the elevated risk condition.

[H.13]

Enforcement.

10 CFR 50.65 paragraph (a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," states, in part, that "the licensee shall manage the increase in risk that may result from the proposed maintenance activities." Contrary to the above, on May 3, 2014, Entergy incorrectly assessed the increased risk that resulted from an emergent condition, and thus did not recognize a Yellow risk condition. Consequently, from May 3 through May 7, 2014, Entergy did not take any risk management actions for the associated Yellow risk condition. Corrective actions included Entergy upgrading to the appropriate risk condition and taking the appropriate risk management actions, which included rescheduling other maintenance activities that would have required further elevation of risk. Because of the very low safety significance and because it has been entered into the CAP (CR-PNP-2014-2007),the NRC is treating this as an NCV, consistent with Section 2.3.2.a of the NRC's Enforcement Policy. (NCV 05000293/2014003-01, Failure to Manage a Yellow Risk Condition for Unavailable Torus Vent Valve)

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

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

Failure of traversing incore probe C to withdraw and isolate on April 14, 2014 A recirculation pump second stage seal pressure step change on April 18, 2014 Adverse trend in MSIV AO-203-1B fast closure time on March 24, 2014 Reactor building inner trucklock door (DR-45) gaps on June 10-12, 2014 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 TS 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 from the TSs and UFSAR to Entergys 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. Findings

Introduction.

The inspectors identified a Green NCV of TS 3.7.A, Primary Containment, because Entergy failed to comply with the TS-required actions for inoperable PCIVs. Specifically, while maintenance was being performed on an inoperable automatic PCIV, Entergy failed to either isolate and/or deactivate at least one containment isolation valve in the same line, or to complete an orderly shutdown to the Cold Shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Description.

On May 3, 2014, Entergy staff began emergent maintenance on Torus Purge Exhaust Isolation Valve AO-5042A and Drywell Purge Exhaust Isolation Valve 5044A, which are PCIVs. In addition, Drywell Purge Supply Isolation Valve AO-5035B, also a PCIV, had been declared inoperable on June 4, 2013, and had since then been undergoing periodic maintenance. Pilgrim TS 3.7.A.2.b states, in part, that in the event that any automatic primary containment isolation valve becomes inoperable, at least one containment isolation valve in each line having an inoperable valve shall be deactivated in the isolated condition and that deactivation means to electrically or pneumatically disarm, or to otherwise secure the valve. Additionally, if the above action cannot be met, TS 3.7.A.5 requires, in part, that an orderly shutdown shall be initiated and the reactor shall be in a Cold Shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In order to comply with the above required actions, Entergy staff placed Torus Purge Exhaust Isolation Valve AO-5042B, Drywell Purge Supply Isolation Valve AO-5035A, and Drywell Purge Exhaust Isolation Valve 5044B in the closed position; however, these valves were not electrically or pneumatically disarmed. Discussions with Entergy staff revealed that the existing interpretation at Pilgrim, in the case of isolation valves which fail closed and have no automatic opening feature, was that placing a protective tag on the control switch was sufficient to meet the TS requirement to secure the valve. However, the protective tagging process is solely administrative in nature and does not meet the intent of the TS-required actions, because it does not prevent inadvertent valve operation due to personnel error, nor does it prevent unexpected operation due to equipment failure, as the source of motive energy has not been removed from the isolated and credited valve.

On May 8, the inspectors discussed this concern with Entergy staff and informed them that they were not in compliance with their TSs, at which point Entergy staff appropriately disarmed the PCIVs in accordance with the requirements of Pilgrim TSs.

Analysis.

The inspectors determined that Entergys failure to comply with the TS requirement to deactivate at least one isolation valve in the same line as the inoperable valve, or to otherwise place the reactor in a Cold Shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , was a performance deficiency that was within Entergys ability to foresee and correct, and therefore should have been prevented. The inspectors determined that the finding is more than minor because it is associated with the configuration control attribute of the Barrier Integrity cornerstone, and adversely affected the associated cornerstone objective to provide reasonable assurance that physical design barriers (i.e.

containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Entergys failure to close and deactivate a valve in the same line as the inoperable PCIV as required by TS did not ensure the operability of the primary containment. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, effective July 1, 2012, the inspectors determined that this finding is of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components.

This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because Entergy did not use decision making-practices that emphasize prudent choices over those that are simply allowable, or in this case, those that are perceived to be allowable. Specifically, Entergys reliance on certain design characteristics of the PCIVs to meet the TS requirement, while refraining to take additional measures to remove the source of energy from the valves in order to ensure the valves remained closed in the case of personnel error or equipment malfunction, was not conservative.

[H.14]

Enforcement.

Pilgrim TS 3.7.A, Primary Containment, requires, in part, in the event that any automatic primary containment isolation valve becomes inoperable, at least one containment isolation valve in each line having an inoperable valve shall be deactivated in the isolated condition and that if the above action cannot be met, an orderly shutdown shall be initiated and the reactor shall be in a Cold Shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Contrary to the above, from June 4, 2013 to May 8, 2014, Entergy performed maintenance on inoperable PCIVs without deactivating another valve in the isolated position, and without placing the reactor in a Cold Shutdown condition. Immediate corrective actions included pneumatically isolating the credited isolation valves.

Because of the very low safety significance and because it has been entered into the CAP (CR-PNP-2014-2008), the NRC is treating this as an NCV, consistent with Section 2.3.2.a of the NRC's Enforcement Policy. (NCV 05000293/2014003-02, Failure to Comply with TS Required Actions for Inoperable PCIV)

1R18 Plant Modifications

Main article: IP 71111.18

.1 Temporary Modification

Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on May 19, which required emergency plan implementation by an operations crew. Entergy planned for this evolution to be evaluated and included in performance indicator (PI) data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weakness and deficiencies in the crews performance and ensure that Entergy evaluators noted the same issues and entered them into their CAP.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstone: Occupational/Public Radiation Safety

2RS5 Radiation Monitoring Instrumentation

Main article: IP 71124.05

During June 9 - 13, 2014, the inspectors verified that Entergy is assuring the accuracy and operability of radiation monitoring instruments that are used to protect occupational workers and to protect the public from nuclear power plant operations. The inspectors used the requirements in 10 CFR 20; 10 CFR 50, Appendix A, Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64, Monitoring Radioactive Releases; 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents; 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations; NUREG-0737, Clarification of Three Mile Island Corrective Action Requirements; TSs/Offsite Dose Calculation Manual (ODCM); applicable industry standards; and Entergys procedures required by TSs as criteria for determining compliance.

a. Inspection Scope

Inspection Planning

The inspectors reviewed Pilgrims UFSAR to identify radiation instruments associated with monitoring area radiation, airborne radioactivity, process streams, effluents, materials/articles, and workers. Additionally, the inspectors reviewed the associated TS requirements for post-accident monitoring instrumentation. The inspectors reviewed a list of in-service survey instrumentation including: air samplers, small article monitors (SAMs), radiation monitoring instruments, personnel contamination monitors, portal monitors, and whole-body counters. The inspectors reviewed procedures that govern instrument source checks and calibrations.

The inspectors reviewed Entergy and third-party evaluation reports of the radiation monitoring program since the last inspection including evaluations of offsite calibration facilities and services.

Walkdowns and Observations The inspectors walked down six effluent radiation monitoring systems, including: Post Treatment Off-gas Air Ejector, Reactor Building Vent, RBCCW, Liquid Radwaste Effluent, Turbine Building, and Reactor Feed Pump. The inspectors selected eleven portable survey instruments in use or available for issuance and assessed the calibration and source check currency and the instrument operability.

The inspectors observed Entergy staff perform source checks for ion chambers, beta counters, and alpha counter survey instruments.

The inspectors walked down five area radiation monitors (ARMs) and five continuous air monitors (CAMs) to determine whether they are appropriately positioned relative to the radiation sources or areas they were intended to monitor. The inspectors compared monitor response (via local readout or remote control room indications) with actual area radiological conditions for consistency.

The inspectors selected four personnel contamination monitors, three portal monitors, and one SAM; and evaluated whether the periodic source checks were performed in accordance with the manufacturers recommendations and Entergys procedures.

Calibration and Testing Program

Laboratory Instrumentation

The inspectors assessed the performance results of laboratory analytical instruments used for radiological analyses based on daily performance checks and calibration data.

Whole Body Counter (WBC)

The inspectors reviewed daily performance checks and calibration data for the WBC and assessed whether WBC use incorporates methods to account for the plants radionuclide mix and that appropriate calibration phantom(s) were used.

Post-Accident Monitoring Instrumentation

Inspectors reviewed calibration documentation for the drywell and torus high-range radiation monitors. The inspectors assessed whether the electronic calibrations were completed for all range decades and the detector calibrations were conducted using an appropriate high level radiation source.

The inspectors selected two effluent/process monitors that are included in Entergys emergency preparedness program. The inspectors evaluated the calibration, measurement range, and availability of these instruments including the Radiation Monitor C3004 Reactor Feed Pump Gaseous Effluent Monitoring System.

Portal Monitors, Personnel Contamination Monitors, and SAMs The inspectors selected one of each type of these instruments and verified that the alarm set-point values are reasonable to ensure that licensed material is not released from the site. The inspectors reviewed calibration documentation and calibration methods for each instrument selected.

Portable Survey Instruments, ARMs, Electronic Dosimetry, and Air Samplers/CAMs The inspectors reviewed calibration documentation for at least one of each type of portable instrument in use including the Far West Technologys REM-500 Neutron Meter. For portable survey instruments and ARMs, the inspectors reviewed detector measurement geometry and calibration methods and reviewed the use of the instrument calibrator as applicable.

Instrument Calibrator

The inspectors reviewed the current radiation output values for Entergys portable survey and ARM instrument calibrator unit(s). The inspectors assessed whether Entergy periodically verifies calibrator output over the range of the exposure rates/dose rates using an ion chamber/electrometer.

The inspectors assessed whether the measuring devices had been calibrated by a facility using the National Institute of Science and Technology traceable sources and whether decay corrective factors for these measuring devices were properly applied by Entergy in its output verification.

Calibration and Check Sources The inspectors reviewed Entergys source term and waste stream characterization to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.

b. Findings

No findings were identified

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

Main article: IP 71124.06

The inspectors verified that gaseous and liquid effluent processing systems are maintained so radiological discharges are properly reduced, monitored, and released.

The inspectors verified that accuracy of the calculations for effluent releases and public doses.

The inspectors used the requirements in 10 CFR 20; 10 CFR 50.35(a) TSs; 10 CFR 50, Appendix A, Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64, Monitoring Radioactive Releases; 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents; 10 CFR 50.75(g), Reporting and Recordkeeping for Decommissioning Planning; 40 CFR 141, Maximum Contaminant Levels for Radionuclides; 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations; Regulatory Guide (RG) 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents; RG 1.21, Measuring, Evaluating, Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste; NUREG-1302, Offsite Dose Calculation Manual (ODCM) Guidance: Standard Radiological Effluent Controls; applicable Industry standards; and Entergy procedures required by TSs/ODCM as criteria for determining compliance.

a. Inspection Scope

Groundwater Protection Initiative Program The inspectors reviewed reported groundwater monitoring results and changes to Entergys program for identifying and controlling contaminated spills/leaks to groundwater. As previously reported in Inspection Report 05000293/2014002 (ADAMS Accession No. ML14129A282), on April 10, 2013, while investigating a water leak from an electrical penetration inside the Reactor Building, a tritium leak was discovered. This leak was reported to the NRC in Event Notification 48909 on April 10, 2013.

A boroscopic investigation into the related neutralizer sump discharge line identified a pipe joint separation about 6 - 8 below ground.

In addition, a sample collected from a newly installed Monitoring Well (MW-219) located in the vicinity of the neutralizer sump discharge line on December 30, 2013, resulted in a tritium concentration of 69,000 picoCuries/Liter (pCi/L). No other plant-related radionuclides were detected.

On May 27, 2014, an incident investigation report was issued by Entergy entitled Neutralizer Sump Discharge Pipe Investigation Report. This report documented that elevated concentrations of tritium and gamma emitting radionuclides were detected in soil samples collected in July 2013 in close proximity to the line break. The report indicated that additional leakage occurred through leaks in CB-10, which will require additional characterization sampling and surveys.

The NRC will continue to follow Entergy's performance closely to assure: 1) conformance with applicable regulatory requirements, 2) the new piping system integrity is evaluated, and 3) remediation of soil and groundwater is performed, if necessary, to ensure that public health and safety is maintained. Based on information reviewed to-date, the radionuclide concentrations in soil and groundwater at Pilgrim have not, nor are they expected to, have any adverse public health and safety impacts.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

Main article: IP 71151

a. Inspection Scope

The inspectors reviewed PI data to determine the accuracy and completeness of the reported data. The review was accomplished by comparing reported PI data to confirmatory plant records and data available in plant logs, CRs, licensee event reports (LERs), and NRC Inspection Reports. The acceptance criteria used for the review was Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 7. The following PIs were reviewed.

Unplanned SCRAMs per 7000 Critical Hours Unplanned SCRAMs with Complications Unplanned Power Changes per 7000 Critical Hours

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergy entered issues into their CAP 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 CAP and periodically attended CR review group meetings.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Entergy outside of the CAP, such as trend reports, PIs, major equipment problem lists, system health reports, MR assessments, and maintenance or CAP backlogs. The inspectors also reviewed Entergys CAP database for the first and second quarters of 2014 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed the Entergy quarterly trend reports to ensure that Entergys personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings and Observations

No findings were identified.

Equipment Reliability Equipment reliability issues resulting in plant transients have previously been identified as a continuing trend by the inspectors and Entergy. Trends that have been observed by the inspectors include the SRV performance contributing to several down powers and forced outages, the failures of non-safety-related equipment failures leading to unplanned down powers and plant shutdowns, and non-safety-related equipment categorized as run-to-failure reaching the end of service life and contributing to events.

As previously identified by the inspectors, these issues have directly led to six forced outages in the previous year, and have contributed in Pilgrim entering the degraded cornerstone column of the Reactor Oversight Process action matrix due to crossing multiple PI thresholds.

The planned mid-cycle maintenance outage performed at Pilgrim during the second quarter of 2014 has aided in efforts to increase equipment reliability and to reduce the aggregate burden of compensatory measures due to degraded conditions. Although in the first two quarters of 2014 there have existed fewer opportunities to demonstrate improvements in risk informed decision making in forced outages, the decision to perform a planned maintenance outage did allow the inspectors to observe some improvements in this area. Moreover, in addition to onsite equipment failures, two plant trips in 2013 were the result of offsite initiators. Although these initiators are outside the direct purview of Entergy, the staff is implementing corrective actions to coordinate maintenance and operations with the grid operator in a more risk informed manner.

.3 Annual Sample: Problem Identification and Resolution Cross-Cutting Aspect Common

Cause Analysis for P.1(d) - Untimely Corrective Actions

a. Inspection Scope

The inspectors performed an in-depth review of Entergys ACE and corrective actions associated with an apparent common theme regarding Entergys failure to take appropriate corrective actions to address safety issues and trends in a timely manner.

Specifically, based on NRC-identified findings in the 3rd and 4th quarters of 2013, four findings had the same cross-cutting aspects in the area of Problem Identification and Resolution, Corrective Action Program P.1(d)]1. On January 23, 2014, Entergy initiated a corrective action CR (CR-PNP-2014-0380) to perform a common cause analysis and to develop an action plan to address any common issues.

The inspectors assessed Entergys problem identification threshold, cause analysis, extent-of-condition reviews, corrective actions, and the prioritization and timeliness of corrective actions to evaluate whether Entergy was appropriately identifying, characterizing, and correcting problems associated with this adverse trend and whether the planned and/or completed corrective actions were appropriate. In particular, the inspectors reviewed a risk-informed sample of CRs open for greater than two years to ensure Entergy adequately tracked corrective actions, performed required periodic reviews, and implemented corrective actions in a timely manner commensurate with the safety significance. The inspectors compared the actions taken to the requirements of Entergys CAP, 10 CFR 50, Appendix B, and Entergys procedures. In addition, the inspectors interviewed Entergy personnel to understand Entergys causal analysis approach and to assess the effectiveness of the implemented corrective actions.

b. Findings

No findings were identified.

P.1(d) was the cross-cutting aspect designator in place at the time of the 3rd and 4th quarter 2013 NCVs.

The new cross-cutting aspect designator using IMC 0310 (dated 1/1/14) is P.3.

Entergy Common Cause Analysis The four recent NRC-identified findings with the P.1.d cross-cutting aspect were:

(1) failure to complete a design control review for the SBO fuel oil transfer system in a timely manner (NCV 2013-004-01);

(2) failure to maintain station meteorological towers (NCV 2013-008-02);

(3) repetitive failure to correct an inoperable security-related system in a timely manner (NOV 2013-403-04); and

(4) repetitive failure to correct an inoperable security-related system in a timely manner (NOV 2013-403-05).

The common cause analysis team determined that four CRs did not provide a large enough sample for analysis, so they expanded the sample size to include currently open Pilgrim CRs for the initial review. Upon further review, Entergy determined that 36 CRs in this expanded population should be evaluated. On March 10, 2014, Entergy completed their common cause analysis and concluded that a common cause did exist in that management did not properly prioritize work which resulted in some items being extended in order to meet other management PIs such as refueling outage milestones.

In addition, Entergys ACE identified lack of program monitoring as a contributing cause.

Specifically, Entergys ongoing monitoring of program implementation did not detect and respond to implementation gaps resulting in longstanding program deficiencies and/or continued degradation over time.

Entergy Common Cause Corrective Actions On April 1, 2014, Entergy revised the weekly Regulatory Assurance Status Report to include a CR closure due date for each corrective action related to an NRC finding or violation and planned to continue to provide updates via future weekly reports until the actions were completed (CR-PNP-2014-0380 CA 6). The Regulatory Assurance Manager shares the status report weekly with Pilgrims senior leadership team and discusses the report in detail with Pilgrim management monthly at the Operations Focus Meeting. On May 23, 2014, Entergy documented completion of an action to add the following language to the appropriate existing open corrective actions for the NRC findings or violations listed on the most recent Regulatory Assurance Status Report:

"Regulatory Assurance Manager approval required for any due date extension" (CR-PNP-2014-0380 CA 12). On May 30, 2014, Entergy documented completion of an action to review the work orders currently associated with their expanded CR sample list and determined that the current work order priorities were appropriate (CR-PNP-2014-0380 CA 11). On June 6, 2014, Entergy added five CRs (longstanding issues that were not previous NRC findings) from their expanded CR sample list to the weekly Regulatory Assurance Status Report for additional management monitoring (CR-PNP-2014-0380 CA 13).

NRC Assessment of Common Cause Analysis and Corrective Actions The inspectors determined that Entergys associated common cause analysis could have been more detailed given the CAP implications and that Entergys analysis resulted in few substantive corrective actions to effectively drive Pilgrim CAP performance improvement. Specifically, the inspectors noted that Entergys common cause analysis approach was not well documented, did not appear well defined beyond the initial problem statement, and did not methodically dissect the four recent NRC-identified findings with the P.1.d cross-cutting aspects.

The inspectors noted that Entergys ACE concluded that a common cause did exist in that management did not properly prioritize work; however, the analysis did not appear to probe the initial WO priorities assigned to each of the original deficient conditions associated with the four NRC-identified findings to assess potential work control process shortcomings.

The inspectors noted that Entergy had previously performed an ACE on each of the above findings (Entergy evaluated the two security-related issues under the same ACE);however, none of the ACEs resulted in specific corrective actions targeted at addressing potential common cause process and/or organizational shortcomings that may cut across more than one safety cornerstone. In reviewing the ACEs associated with the four NRC-identified findings, the inspectors identified numerous commonalties that Entergys common cause analysis did not appear to completely assess all the commonalities. In particular, the inspectors noted that:

1. All four issues were NRC-identified; 2. The four findings were associated with three different cornerstones of safety (emergency preparedness, mitigating systems, and physical protection) and validated the cross-cutting nature of the CAP issues; 3. Three out of four involved non-safety-related equipment; 4. Three out of four involved associated compensatory measures that may have masked the longstanding nature of the underlying deficiency; 5. All four involved planned modifications with multiple extensions and/or changes in direction during the process; 6. All four were branded as long-term corrective actions which may have screened them from managements daily focus and attention; 7. Three out of four appeared to lack clear ownership within the organization; 8. Entergy reviewed three out of four issues as part of their pre-NRC problem identification and resolution inspection focused self-assessment in August 2013 but failed to question and take actions to correct the resolution timeliness issues; and 9. All four may have been exempt from interim and periodic reviews as the deficient equipment was not safety-related and thus bypassed a CAP barrier for screening longstanding corrective actions.

Overall, Entergys common cause analysis did not evaluate these potential common causes to identify and correct underlying causal factors evident in the cross-cutting aspects of the findings to effect organizational learning and sustained CAP performance improvement.

In addition, the inspectors identified several minor shortcomings associated with Entergys corrective actions linked to the weekly Regulatory Assurance Status Report.

Specifically:

1. Several of the CR closure dates for the monitored longstanding issues were not aligned with CR due dates in CAP; 2. Entergy did not consistently and completely add the "Regulatory Assurance Manager approval language to the appropriate existing open corrective actions for the NRC findings or violations;

3. Entergy did not add the "Regulatory Assurance Manager approval language to

any of the five CRs (longstanding issues that were not previous NRC findings)added from their expanded CR sample list; 4. Between April 1 and June 6, 2014, there were several due date extensions on CR closures, calling into question the effectiveness of the corrective actions; 5. There were several extensions after Entergy added the "Regulatory Assurance Manager approval language to the open corrective actions for the NRC findings or violations, however, the Regulatory Assurance Managers approval was not requested, calling into question the effectiveness of the corrective action; 6. There was no clearly defined and consistent process for the selection of the longstanding issues added to the weekly status report from the expanded CR sample list; and 7. There was no consistent, repeatable process established for the future addition of longstanding issues to the weekly status report (except for future NRC findings).

Entergys common cause CR directed a training performance analysis of the issues (CR-PNP-2014-0380 CA 4, completed February 28, 2014). Entergys training performance analysis identified seven potential areas for improvement associated with expectations, reinforcement of standards, process and procedure adequacy, obstacles, work instruction quality, and process efficiency. Entergys training performance analysis noted that each of these areas would be addressed by the CR-PNP-2014-00380 ACEs corrective actions. However, the inspectors observed that there were not any ACE corrective actions linked to and/or addressing the training performance analysis areas of concern.

Regarding Pilgrims CAP procedure, the inspectors noted that the procedure only required interim and periodic reviews (IPRs) for safety-related equipment. As part of the SBO fuel oil hose ACE corrective actions, Entergy revised the boilerplate of the CR IPR template to ensure that the reviewer considers the risk of delaying action on TS-related equipment (CR-PNP-2013-6906 CA 6, completed January 7, 2014). The inspectors observed that a potential IPR gap remained in that the review of important-to-safety components and equipment with specific regulatory significant functions (e.g., security and emergency preparedness equipment) may not receive an appropriate periodic review as they may not directly impact TS equipment. Thus, Entergys associated corrective action appeared narrowly focused as it was adequate for addressing the SBO fuel oil hose issue but did not necessarily fit across all the cornerstones of safety. In addition, the inspectors noted Entergys use of the new wording in several recent IPR corrective actions associated with non-safety-related equipment, however, Entergy had not initiated a change to the CAP procedure itself as it still stated that an IPR was not required if the equipment was not safety-related.

Despite these weaknesses, Entergys CAP process systematically and automatically generated IPR CAs to drive the respective CA owner to perform the periodic review at the required time and the Entergy staff demonstrated consistent performance in completing these auto-initiated tasks on time. However, Entergys demonstrated proficiency at performing these tasks was marked by varying levels of implementation.

For example, the inspectors noted that the 4th periodic review evaluation associated with a longstanding fire protection issue for which Entergy compensates with hourly fire watches (CR-PNP-2010-01557 CA-104, CR IPR dated January 29, 2014) was approved by an engineering director but was not completely filled out. The inspectors also noted that that the latest revision of the CR IPR form (EN-LI-102, Attachment 9.8, Revision 23)states, Are all LI-102 requirements for action administration and control being met? If yes explain. This appeared to be an editorial error that was not identified and corrected by Entergy staff completing and reviewing the form, and which contributed to a wide range of explanations for their yes responses (including no response).

Related Entergy CAP Initiatives and Corrective Actions Even though Entergys common cause analysis did not identify or document links to other associated corrective actions, the inspectors noted several closely related CAP initiatives and corrective actions that Entergy had recently initiated to address corrective action and work management deficiencies. The related Entergy CAP initiatives and corrective actions included:

Based on a review of safety culture aspects of event investigations in 2013 and the results of safety culture feedback sessions, Entergy initiated actions to address aggregate safety culture issues. Entergy initiated an action to develop and implement a mechanism which prioritizes critical actions over less important ones and which allows safety culture aspects to be an element for consideration regarding extension requests and closure quality reviews (CR-PNP-2014-1669 CA 16, due June 16, 2014).

Entergy developed and established a mechanism to assure safety and regulatory issues are visible to all site groups such that progress can be evaluated regarding timely resolution of issues (CR-PNP-2013-6906 CA 10, completed March 20, 2014). Regulatory Assurance also developed a number of tracking/reporting tools to give visibility to the organization on issues related to NRC findings that are open and require focus to preclude recurrence (CR-PNP-2013-6906 CA 16, completed February 28, 2014).

Engineering management communicated to system, component, and design engineers the expectation to include high priority safety and regulatory items in the action plan section of their respective system and program health reports (CR-PNP-2013-6906 CA 11 & 12, completed January 29 and February 28, 2014).

Entergy developed and established a mechanism to prioritize the regulatory risk related to timely repairs of security equipment and/or implementation of security modifications (CR-PNP-2013-0700 CA 36, completed May 13, 2014).

Entergy revised the language of the CR IPR template to ensure that the reviewer considers the risk of delaying action on TS-related equipment (CR-PNP-2013-6906 CA 6, completed January 7, 2014). Entergys associated extent-of-condition review of numerous longstanding CRs identified that the previous IPRs did not address the implications of timeliness on safety or regulatory risk (CR-PNP-2013-6906 CA 7, completed January 31, 2014). Entergy assigned IPRs for each of the longstanding CRs that had previously been screened out as non-safety-related or because an operability basis had existed (CR-PNP-2013-6906 CA 14, completed February 5, 2014).

.4 Analysis and Actions for the Summer 2013 Plant Inlet Bay High Water Temperature

a. Inspection Scope

Several times during July and August 2013, the plant intake cooling water temperature approached or slightly exceeded the TS limit of 75°F. The intake water temperature reduced to below the 75°F limit each time within a few hours, vs the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TS limit.

Plant operators appropriately entered the SSW temperature issue into its problem identification program and evaluated the corrective action options.

The scope of the June 2014 inspection was to review the CRs for problem identification, including the evaluations and actions planned or taken to address SSW intake elevated temperature conditions subsequent to the Summer of 2013. The inspectors reviewed the corrective actions with the SSW System engineer and confirmed that operational temperature measurements and written procedures were in place for actions to be completed when the intake water temperature approached TS limits. Additionally, the inspectors reviewed the plant history, procedural controls and the plant staff activities in addressing an increase in ultimate heat sink temperature. Preparatory steps for the increased ambient temperatures of July and August including the cleaning by divers of the screen house trash rakes were observed.

Review of Corrective Action Reports The inspectors review of CAP reports and action taken or planned for the elevated intake SSW temperatures of 2013 verified that Entergy staff were appropriately identifying, characterizing, and correcting problems related to this system and components, and that the planned or completed corrective actions for the reported issues were appropriate.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Main article: IP 71153

Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Entergy made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Entergys follow-up actions related to the events to assure that Entergy implemented appropriate corrective actions commensurate with their safety significance.

Operator conduct of a plant downpower to approximately 55 percent power to support stroke time testing of MSIV AO-203-1B on April 19 B moisture separator drain tank level transient on June 5

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Follow-up on Traditional Enforcement Actions Including Violations, Deviations,

Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders (92702)

a. Inspection Scope

On August 24, 2011, the NRC issued a Confirmatory Order (EA-11-096) to Entergy Operations Inc., and Entergy Nuclear Operations, Inc. (collectively referred to as Entergy). The Confirmatory Order actions were agreed upon by Entergy and the NRC during an alternative dispute resolution session held on July 18, 2011, to resolve NRC concerns regarding an apparent violation of employee protection requirements at the River Bend Station. The actions focused on reorganizing the Quality Control reporting relationships, ensuring adequate training of 10 CFR 50.7, Employee Protection, and performing an effectiveness review of the Employee Concerns Program (ECP)procedures at all Entergy facilities.

By letter dated August 23, 2012, Entergy notified the NRC of the actions that had been taken in response to the requirements imposed by the Confirmatory Order. Accordingly, during the week of April 29, 2013, NRC staff from the Office of Enforcement and Region IV performed an inspection at the River Bend Station to assess the specific actions identified in Entergys response letter. NRC staff also verified implementation of the remaining actions required to satisfy the conditions set forth in the Confirmatory Order, for all Entergy sites. Subsequent to this inspection, NRC staff continued to interact with Entergy regarding the adequacy of the corrective and preventive actions related to the underlying discriminatory issue.

b. Findings and Observations

No findings were identified.

During the follow-up inspection, the NRC staff reviewed Entergys ECP supervisory training and general employee training documents, the relevant lessons learned from the facts of this matter, and the fleet-wide written communication reinforcing Entergys commitment to maintaining a safety conscious work environment.

The NRC staff also reviewed the General Employee Training and Supervisory Training modules. Based on these reviews, it was determined that these training modules adequately addressed employee protection and included insights from the underlying discriminatory matter. The NRC staff determined that the supervisory training module appeared complete and included case studies as well as the specific elements from the underlying §50.7 Employee Protection, violation. However, it was noted that although employees receive General Employee Training on an annual basis, Entergy does not require supervisors to take employee protection refresher training on a recurring basis, as a means to reinforce these standards.

Additionally, NRC staff evaluated the results of Entergys effectiveness review of ECP enhancements and the associated training that arose from the corrective actions taken to address this matter. Based on the results of this evaluation it was determined that Entergy had performed the requisite reviews at each station including; examination of selected ECP Case Files, Records Retention, Concerned Individual follow-up, and ECP Coordinator training. Within the areas examined, no findings were identified and in general it was determined that Entergy had adequately performed the effectiveness review of ECP procedural enhancements and the ECP training related to this matter.

During the follow-up review of the Quality Control/Quality Assurance reporting relationship, it was determined that Entergys response did not ensure that persons performing the quality assurance function of receipt inspection reported to a management level sufficient to maintain organizational freedom and independence from cost and schedule were maintained. Subsequent to the identification of this performance issue, which affected the implementation of the Quality Assurance program at all nine Entergy sites, the condition was entered into Entergys CAP as CR-HQN-2013-00466.

Following the identification of this issue, additional discussions were held between NRC and Entergy to clarify the intent of the settlement agreement and subsequent Confirmatory Order stemming from the earlier alternate dispute resolution mediation. As a result of these discussions, Entergys Corporate Licensing organization developed a fleet reconciliation plan to modify Entergys Quality Assurance Program Manual to require that individuals performing inspections in accordance with Quality Assurance Program Manual, Section B.12, Inspection, functionally report to the associated manager responsible for Quality Assurance. As described in the corrective actions associated with CR-HQN-2013-00466, the affected individuals were those requiring certification in accordance with Quality Assurance Program Manual, Table 1, Regulatory Commitments, Section G, Regulatory Guide 1.58 Revision 1, Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel, dated September 1980.

In addition to revising the applicable provisions in the Quality Assurance Program Manual, corrective actions were initiated to revise implementing procedures to reflect the change in reporting relationship during the performance of required inspections as well as providing training to the affected individuals. The NRC staff confirmed that the remaining conditions of the Confirmatory Order were adequately addressed.

Based on the above reviews, the NRC determined that Entergy properly implemented the conditions specified in the Confirmatory Order and the associated actions were adequately implemented.

.2 Preoperational Testing of Independent Spent Fuel Storage Installations at Operating

Plants (60854.1)

a. Inspection Scope

In 2013, the Pilgrim refuel floor overhead crane was upgraded to single failure proof in accordance with criteria in NUREG-0554 and NUREG-0612. The Pilgrim refuel floor overhead crane will be used as part of the process to transfer spent fuel from the spent fuel pool into dry storage containers.

The inspectors reviewed the readiness of the Pilgrim refuel floor overhead crane on April 21 - 24, 2014. This included a review of the lifting sequence, operator qualification records, and CRs. The crane factory test procedure, crane electrical calculation, overhead crane evaluation under revised loads, the crane seismic analysis, and other crane related calculations were also reviewed. The inspectors reviewed the inspection of the crane critical welds performed to date. The inspectors observed the movement of the crane bridge, trolley, and hooks.

The inspectors also reviewed Entergys Compliance Matrix for NUREG-0554/NUREG-0612 and NOG-1 that have comparisons of requirements for a single failure proof crane to the crane characteristics.

b. Findings

No findings were identified.

.3 (Open/Closed) NCV 05000293/2014003-003: NRC Letter, dated February 26, 2014

(ML1405A584), documented an NRC Office of Investigation review to determine whether a contract medical assistant deliberately failed to conduct required tactile and/or olfactory testing during annual physical examinations of three licensed operators on January 10, 2013 (NRC Investigation Report Number 1-2013-010). The NRC concluded that the medical assistants actions caused Entergy to violate NRC requirements in 10 CFR 55.27 and 10 CFR 55.9. This is being treated as a Severity Level IV NCV. In order to facilitate entering this issue into the NRCs Plant Issues Matrix and assessment process, this issue is identified as NCV 05000293/2014003-03, Failure to Follow Licensed Operator Medical Requirements.

4OA6 Meetings, Including Exit

On July 22, 2014, the inspectors presented the quarterly baseline inspection results to Mr. John Dent, Site Vice President, and other members of the Pilgrim staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Dent Site Vice President

G. Blankenbiller Chemistry Manager

T. Bordelon Performance & Improvement Manager

J. Bracken Assistant Operations Manager

D. Brugman Supervisor ALARA/Technical Support

D. Burke Security Manager

R. Byrne Licensing Engineer

B. Chenard Engineering Director

F. Clifford Operations Support Manager

J. Cotter Operations Training Supervisor

J. Cox Radiation Protection Operations Supervisor

B. Deevy System Engineer

P. Doody Senior Lead Enginner

G. Dyckman Senior Consultant

B. Ford Senior manager Nuclear Safety and Licensing

M. Gatslick Security Compliance Supervisor

P. Glover SSW System Engineer

W. Grieves Quality Assurance

P. Harizi Design Engineer

J. House Operations Training Supervisor

J. Keene System Engineer

P. Kristian Senior Project Manager Dry Cask

W. Lobo Licensing Engineer

J. Lynch Regulatory Assurance Manager

J. Macdonald Senior Operations Manager

V. Magnetta Senior Operations Instructor

W. Mauro Supervisor Radiation Protection Support

C. McDonald Training Manager

F. McGinnis Licensing Engineer

R. Metthe Senior Engineer

C. Minott Project Manager

J. Moylan Project & Maintenance Services Manager

P. Nigro Mechanical Maintenance Supervisor

D. Noyes Director of Regulatory & Performance Improvement

J. ODonnell Systems Engineer

J. Ohrenberger Senior Maintenance Manager

J. Priest Emergency Preparedness Manager

B. Rancourt Senior Lead Engineer, Design Engineering

K. Sejkora Senior Chemist

D. Sitkowski Design Engineer

D. Small Design Engineer

M. Thornhill Radiation Protection Supervisor

G. Vazquez Quality Assurance Supervisor

S. Verrochi General Manager Plant Operations

T. F. White Design & Program Engineering Manager

M. Williams Nuclear Safety Licensing Specialist

D. Wuoti Site Project Superintendent, Project Management

J. Yiingling System Engineer

A. Zolie Radiation Protection Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000293/2014003-01 NCV Failure to Manage a Yellow Risk Condition for Unavailable Torus Vent Valve (Section 1R13)

05000293/2014003-02 NCV Failure to Comply with TS Required Actions for Inoperable PCIV (Section 1R15)

05000293/2014003-03 NCV Failure to Follow Licensed Operator Medical Requirements (Section 4OA5)

LIST OF DOCUMENTS REVIEWED