IR 05000293/2018010

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Confirmatory Action Letter (EA-17-086) Follow-Up Inspection Report 05000293/2018010
ML18164A224
Person / Time
Site: Pilgrim
Issue date: 06/13/2018
From: Anthony Dimitriadis
NRC/RGN-I/DRP/PB5
To: Brian Sullivan
Entergy Nuclear Operations
Dimitriadis A
References
EA-15-081, EA-17-086 IR 2018010
Download: ML18164A224 (22)


Text

June 13, 2018

SUBJECT:

PILGRIM NUCLEAR POWER STATION - CONFIRMATORY ACTION LETTER (EA-17-086) FOLLOW-UP INSPECTION REPORT 05000293/2018010

Dear Mr. Sullivan:

On March 23, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an on-site team inspection at Pilgrim Nuclear Power Station (PNPS). The NRC inspectors discussed the results of this inspection with you and other members of your staff via a teleconference exit on May 3, 2018. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed PNPSs progress in implementing the actions from the PNPS Recovery Plan that were committed to in the Confirmatory Action Letter (CAL) dated August 2, 2017 (NRCs Agencywide Documents Access and Management System (ADAMS)

Accession No. ML17214A088) (EA-17-086). Specifically, for this inspection, the team reviewed the adequacy of the corrective actions PNPS completed to address 24 individual CAL items in the Operability Determination and Functionality Assessments, and the Safety Relief Valve (SRV) White Finding Area Action Plans. The team also reviewed site performance to determine whether all the actions completed for these plans, in aggregate, achieved the safety performance improvement objectives stated in the PNPS Recovery Plan.

The team determined that all 24 of the individual CAL items reviewed and the two associated Area Action Plans were effective in achieving the associated PNPS Recovery Plan performance improvement objectives and adequately completed. As a result, the 24 CAL items and the Operability Determination and Functionality Assessments and the SRV White Finding Area Action Plans are closed.

No findings or violations of NRC requirements were identified during this inspection.

As part of this inspection, the team also completed a follow-up supplemental inspection for the White finding related to the A SRV failure. On September 1, 2015, the NRC issued the final significance determination for the White finding (ADAMS Accession No. ML15230A217). The White finding was associated with a violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, in that Entergy did not identify, evaluate, and correct a significant condition adverse to quality associated with the A SRV. Entergy did not identify, evaluate, and correct the A SRVs failure to open upon manual actuation during a plant cool-down on February 9, 2013, following a loss of offsite power event caused by a winter storm. The failure to take actions to preclude repetition resulted in the C SRV failing to open due to a similar cause following a January 27, 2015, loss of offsite power event also caused by a winter storm. The NRC determined that the A SRV had been inoperable for a period greater than the technical specification allowed outage time of 14 days.

The Inspection Procedure (IP) 95003 Phase C inspection report (ADAMS Accession No. ML17129A217) documented the completion of an initial review of Entergys response to this finding using IP 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs.

That review identified a significant weakness related to several concerns regarding methodologies used in the associated root cause evaluation (CR-PNP-2016-01621). Most notably, there were incorrect conclusions and assumptions related to the adequacy of information in the condition report originally written for the A SRV operation during a 2013 plant transient. The significant weakness caused Entergy to inappropriately assess the impact of lack of rigor in shift manager operability determination review and its associated causal factors.

Based on this significant weakness, the NRC determined that all objectives for the IP 95001 inspection could not be met.

The corrective actions required to address the impact of the SRV White finding significant weakness on the objectives of the IP 95001 inspection were included in the SRV White Finding Area Action Plan items in the CAL. These items were inspected during this inspection and the previous CAL follow-up inspection, the results of which were documented in NRC Inspection Report 05000293/2017010 (ADAMS Accession No. ML18032A463). During this most recent inspection, the team closed the remaining nine SRV White Finding Area Action Plan action items, and verified that all of the actions were complete and effective, and that they adequately addressed the identified significant weakness. The NRC concluded that PNPSs actions met the objectives of the IP 95001 inspection and, therefore, the White finding related to the A SRV failure (EA-15-081) is closed.

In accordance with the guidance in Inspection Manual Chapter 0305, Operating Reactor Assessment Program, this White finding will no longer be considered in assessing plant performance. However, PNPS will remain within the Multiple/Repetitive Degraded Cornerstone column of the NRCs Reactor Oversight Process Action Matrix pending completion of all actions needed to close the CAL. To review the remaining CAL actions and area action plans, the NRC currently plans and has scheduled at least three additional quarterly CAL follow-up inspections in addition to the two already completed. The NRC staff will assess the effectiveness of Entergys implementation of these corrective actions and evaluate whether the safety performance of PNPS has demonstrated sustained improvement warranting transition of PNPS out of Column 4 in accordance with Inspection Manual Chapter 0305, Section 10.02d, paragraph 7. The NRC plans to communicate the results of this determination at a public meeting following the successful completion of these CAL closure activities. The final CAL follow-up inspection is currently scheduled to be completed in December 2018, and the report documenting the results of that inspection to be issued shortly thereafter. The NRC may schedule additional CAL inspections, as warranted. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects

Docket No. 50-293 License No. DPR-35

Enclosure:

Inspection Report 05000293/2018010 w/Attachment: Confirmatory Action Letter Item Status

Inspection Report

Docket Number:

50-293

License Number:

DPR-35

Report Number:

05000293/2018010

Enterprise Identifier: I-2018-010-0044

Licensee:

Entergy Nuclear Operations, Inc. (Entergy)

Facility:

Pilgrim Nuclear Power Station (PNPS)

Location:

Plymouth, MA

Inspection Dates:

03/19/2018 - 03/23/2018

Team Lead:

Leonard M. Cline Jr., Senior Project Engineer

Inspectors:

Peter Boguszewski, Project Engineer

Matthew Fannon, Resident Inspector

Christopher Highley, Resident Inspector

Adam Ziedonis, Resident Inspector

Approved By:

Anthony Dimitriadis, Chief

Reactor Projects Branch 5

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Entergys performance at PNPS by conducting the confimatory action letter (CAL) follow-up inspection in accordance with the Reactor Oversight Process (ROP). The ROP is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

The team reviewed 24 of the 156 items that Entergy committed to complete in the PNPS CAL (EA-17-086). The team determined that all 24 of the items reviewed and the two associated area action plansOperability Determination and Functionality Assessments (ODFA) and Safety Relief Valve (SRV) White Findingwere adequately completed and effective in achieving the associated performance improvement objectives. As a result, the 24 CAL items and these two area action plans are closed. In addition, based on the closure of the SRV White Finding Area Action Plan, Notice of Violation (NOV)05000293/2015007-02, Failure to Identify,

Evaluate, and Correct A SRV Failure to Open Upon Manual Actuation, (EA-15-081), is also closed.

No findings or more-than-minor violations were identified.

Additional Tracking Items

Type Issue number Title Report Section Status NOV 05000293/

2015007-02 Failure to Identify, Evaluate, and Correct A SRV Failure to Open Upon Manual Actuation Inspection Results 92702 Closed CAL

EA-17-086 PNPS Confirmatory Action letter Inspection Results 92702 Discussed

INSPECTION SCOPES

This inspection was conducted using the appropriate portions of the applicable inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess Entergys performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT, AND ABNORMAL

95001 - Supplemental Inspection Response to Action Matrix Column 2 Inputs

Scope of Review

The NRC completed its assessment of Entergys corrective actions for a White finding associated with the A SRV failure to open, using IP 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs, dated August 24, 2016. The purpose of this inspection was to confirm that the corrective actions taken by Entergy to address the White finding met the following four objectives:

Objective 1 - To assure that the root and contributing causes of the significant performance issues are understood;

Objective 2 - To independently assess and assure that the extent of condition and extent of cause of significant performance issues are identified;

Objective 3 - To assure that corrective actions taken to address and preclude repetition of significant performance issues are prompt and effective; and

Objective 4 - To assure that corrective action plans direct prompt actions to effectively address and preclude repetition of significant performance issues.

Background

On January 27, 2015, PNPS was reducing power, in accordance with station procedures, due to loss of one of the two 345kV distribution lines during a winter storm. While at 52 percent power, operators observed a generator load reject and automatic reactor scram when the remaining 345kV offsite distribution line de-energized. Operator response to the scram was challenged by multiple equipment issues, including failure of the C SRV to operate at low pressure. On February 2, 2015, the NRC dispatched a Special Inspection Team to the station to review the event.

The Special Inspection Team identified a White finding with an associated violation of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, in that Entergy did not identify, evaluate, and correct a significant condition adverse to quality (SCAQ) associated with a failure of the A SRV to open upon manual actuation during a plant cooldown on February 9, 2013, following a loss of offsite power event caused by a winter storm. The failure to take actions to preclude repetition of the SCAQ resulted in the C SRV failing to open during the January 27, 2015, event described above. More information on this event and the White finding can be found in NRC Inspection Reports 05000293/2015007 and 05000293/2015011 (ADAMS Accession Nos. ML15147A412 and ML15230A217, respectively).

On September 1, 2015, the NRC determined that due to its performance, Pilgrim was moved to the Multiple/Repetitive Degraded Cornerstone Column (Column 4) of the ROP Action Matrix retroactive to the beginning of the first quarter 2015. The entry into Column 4 was caused by the issuance of this White finding in the Mitigating Systems cornerstone while Pilgrim was in the Degraded Cornerstone Column (Column 3) of the ROP Action Matrix for more than five consecutive quarters. Pilgrim had entered the Degraded Cornerstone Column for two White inputs under the Initiating Events cornerstone. Four scrams in 2013 caused two performance indicators in the Initiating Events cornerstone, Unplanned Scrams per 7000 Critical Hours and Unplanned Scrams with Complications, to cross the threshold from Green to White (ML15026A069).

As a result of PNPSs transition into the Multiple/Repetitive Degraded Cornerstone Column (Column 4) of the ROP Action Matrix, the NRC implemented IP 95003, in a phased approach, to ensure that continued operation of the facility was acceptable until the final phase of the inspection could be completed. The final phase of IP 95003 implementation, or Phase C, included a review of the White finding described above, using IP 95001. The results of the IP 95003 Phase C Inspection are documented in NRC Inspection Report 05000293/2016011 (ADAMS Accession No. ML17129A217). As described in Section 4.4b of that inspection report, the NRC determined that the collective issues associated with the methodologies in Entergys associated root cause evaluation (RCE) represented a significant weakness, such that the objectives of IP 95001 could not be satisfied. The scope of this CAL inspection included a review of Entergys actions to address the significant weakness associated with the White finding, and to determine if the objectives of IP 95001 could be met. Entergys response to the RCE concerns was included in the SRV White Finding Area Action Plan item SRV-4.1.

92702 - Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders

The inspectors reviewed the status of the corrective actions that Entergy had reported completed for 24 of the 156 items listed on Enclosure 2 of the PNPS CAL (EA-17-086)

(ADAMS Accession No. ML17214A088). The inspectors also reviewed the status of the area action plans associated with these 24 items, which in accordance with Enclosure 2 of the PNPS CAL included the ODFA and SRV White Finding Area Action Plans. Entergy had reported these two area action plans were complete and effective.

The inspection team examined these areas to determine if:

(1) CAL item corrective actions were completed in a timely manner consistent with their safety significance;
(2) Area action plans were effective at addressing the performance issues identified in the CAL;
(3) CAL performance metrics were appropriate and accurate;
(4) Closure of each CAL item and area action plan was completed in accordance with established PNPS procedural guidance; and,
(5) The SRV White Finding Area Action Plan adequately addressed the weaknesses in Entergys cause evaluation and corrective actions for NOV 05000293/2015007-02, Failure to Identify, Evaluate, and Correct A SRV Failure to Open Upon Manual Actuation (ADAMS Accession Nos. ML15147A412 and ML15230A217) as documented in Sections 4.4 and 4.5 of the IP 95003 Phase C Inspection Report (ADAMS Accession No. ML17129A217).

During this review, the inspectors completed the following specific activities:

(1) Reviewed Entergys closure packages for each CAL action included in the scope of this inspection.
(2) Reviewed Entergys closure reports for the ODFA and SRV White Finding Area Action Plans.
(3) Reviewed Entergys effectiveness reviews and self-assessments completed for the ODFA and SRV White Finding Area Action Plans.
(4) Interviewed 20 senior reactor operators and 10 engineers.
(5) Observed one simulator evaluated scenario and one simulator training scenario.
(6) Reviewed simulator training results reported in the operator crew performance notebooks.
(7) Observed the conduct of daily Operability Determination Challenge Boards (ODCBs).
(8) Reviewed ODCB weekly feedback for each operating crew, and the monthly and quarterly roll-up reports of ODCB operability determination reviews.
(9) Reviewed approximately 100 operability determinations completed between October 2017 and March 2018.
(10) Confirmed the accuracy of the Recovery Plan performance metrics for both the SRV White Finding and the ODFA Area Action Plans.

INSPECTION RESULTS

Observation 95001 Objective 1 (IP 95001, Section 02.02b)

Entergy performed RCE CR-PNP-2016-01621 in response to the NRC White finding associated with a failure of the A SRV to open upon manual actuation during a plant cooldown on February 9, 2013. As discussed in Section 4.4b of the IP 95003 Phase C inspection report, the NRC determined that the collective issues associated with the methodologies in Entergys associated RCE represented a significant weakness. This ultimately resulted in Entergy inappropriately assessing the impact of shift manager review rigor, and any associated causal factors. In response to the significant weakness, Entergy completed Revision 3 to the RCE (CR-PNP-2016-1621). Revision 3 to the RCE addressed the problems identified during the IP 95003 Phase C inspection and identified a third root cause for the White finding: the shift manager approved the operability determination for SRV A without performing an adequate review that challenged and validated the results of the determination.

The CAL team reviewed the results of the IP 95003 Phase C inspection associated with the A SRV White finding and Entergys RCE, Revision 3. The team confirmed that Entergy had adequately addressed the collective issues identified by the IP 95003 Phase C inspection team regarding the RCE. The CAL team interviewed approximately 20 shift managers and senior reactor operators and 10 engineers to assess the organizations understanding of the operability determination process improvements and the reinforcement of the specified role of the shift manager in the process. Based on these interviews, its review of the revised RCE, and the IP 95003 inspection results, the CAL team concluded that Entergy understood the root and contributing causes associated with the SRV White finding. Therefore, the CAL team concluded that Objective 1 was now satisfied.

Objective 2 (IP 95001, Sections 02.02d, 02.02e, 02.03a, 02.04a, 02.03c, and 02.04b)

The IP 95003 Phase C inspection team conducted an independent extent of condition (EoC)and extent of cause (EoCa) review for the A SRV White finding. The team determined that the extent of condition for the failure to identify, evaluate, and correct a SCAQ was narrowly focused on PNPS personnel, and did not evaluate personnel performance at other stations or the corporate offices. Entergy documented this weakness in CR-PNP-2017-00828 and completed several corrective actions that included reviewing Entergy Corporate performance relative to identifying and correcting SCAQs, revising corporate procedures, and initiating fleet-wide actions for training and leadership development in this area.

The IP 95003 Phase C inspection team also determined that Entergys EoCa review required more evaluation to assess the extent of cause related to the impacts of inadequate shift manager operability review rigor. Entergy expanded the scope of the EoCa for this issue to include all areas that require shift manager quality reviews. Entergys corrective actions included procedure revisions that now require shift manager approval of limiting condition for operation entries and narrative logs, and also face-to-face sessions between operations management and all senior reactor operators to reinforce expectations associated with the procedure requirements governing review and approval of technical specification surveillance tests, narrative logs, and limiting condition for operation entries.

The IP 95003 Phase C inspection team identified weaknesses in Entergys consideration of the safety culture traits against the root cause, EoC, and EoCa evaluations. Specifically, the IP 95003 Phase C inspection team identified weaknesses in how some of the safety culture traits had been applied to the issues associated with the operability determination process.

As part of Revision 3 to RCE CR-PNP-2016-01621, Entergy re-performed the review of the safety culture traits and assigned traits to the newly identified third root cause, inadequate shift manager operability determination review rigor. Entergy determined that overall, there were 16 safety culture aspects associated with the root and contributing causes for the SRV White finding, and that all aspects would be addressed by the corrective actions already established by the PNPS Recovery Plan.

The CAL team determined that Entergy completed all of its corrective action program requirements for EoC and EoCa for the A SRV White finding and that Entergys review of the safety culture traits was adequate to satisfy the IP 95001 inspection requirement. Based on the results of the IP 95003 Phase C inspection, Entergys initial EoC and EoCa reviews, and the additional actions taken to address the IP 95003 Phase C inspection identified weaknesses in EoC and EoCa, the CAL team concluded that the EoC and EoCa for all of the significant performance issues associated with A SRV White finding were identified.

Therefore, the CAL team concluded that Objective 2 was now satisfied.

Objective 3 (IP 95001, Sections 02.03b, 02.04a, and 02.04c)

The IP 95003 Phase C inspection team determined that Entergy generally completed appropriate corrective actions to preclude repetition of the A SRV White finding. However, the IP 95003 Phase C inspection team identified a weakness in the lack of specific corrective actions to address shift manager operability determination rigor. As discussed under Objective 1, Entergy completed Revision 3 to the RCE (CR-PNP-2016-1621) to address the significant weakness that was identified by the IP 95003 Phase C inspection team. In this Revision 3 to the RCE, Entergy identified the lack of rigor in shift manager operability determination reviews as a root cause and has completed extensive corrective actions to address this problem. The actions included:

(1) revising station procedures to clearly outline the roles and responsibilities of the shift manager in the operability determination process;
(2) conducting shift manager and senior reactor operator training on the operability determination process;
(3) creating operator aids and templates for the conduct of operability determinations;
(4) creating an ODCB to independently assess all operability determinations using specific evaluation criteria; and
(5) tracking the quality of crew operability determinations using metrics based on the results of ODCB evaluations. Entergy also performed operations management face-to-face training sessions with all shift manager-qualified individuals. The face-to-face sessions reinforced management expectations regarding the conduct of timely and rigorous shift manager reviews for operability and functionality determinations commensurate with the significance of the issue. This action was scheduled to recur semi-annually, until the A SRV RCE effectiveness review determined the corrective action plan was effective and shift manager performance was acceptable. In March 2018, Entergy completed the effectiveness review and determined the corrective action was effective based on satisfactory operability determination metrics.

The CAL team interviewed approximately 20 shift managers and senior reactor operators and reviewed a sample of 100 completed operability determinations to independently assess the effectiveness of the operability determination process improvements and the reinforcement of the specified role of the shift manager in the process. Based on the results of these activities and the documentation of the additional corrective actions Entergy completed to address the lack of rigor in shift manager operability determination reviews, the CAL team concluded that the corrective actions Entergy had completed to address and preclude repetition of the A SRV White finding were effective. Therefore, the CAL team concluded that Objective 3 was now satisfied.

Objective 4 (IP 95001, Sections 02.03a, 02.04a, 02.03b, 02.04a, 02.03c, 02.04b, and 02.04c)

As described in the results of the IP 92702 inspection described below, the CAL team determined that all corrective actions for the SRV White finding were complete and effective.

The CAL team concluded that Objective 4 was now satisfied.

Observation 92702 CAL Item Closure

Based on the actions taken by the licensee, data evaluated by the team, and observations and interviews performed onsite, the team concluded the actions listed below were effective.

Therefore, the following actions are closed (a narrative description of each item is listed in 1 to the PNPS CAL (ADAMS Accession No. ML17214A088)):

Operability Determinations and Functionality Assessments (ODFA) - 1.2, 1.3, 1.4, 1.5, 1.6, 2.2, 3.1, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, 5.8

Safety Relief Valve (SRV) White Finding - 1.1, 1.2, 3.1, 3.2, 3.3, 3.4, 4.1, 5.1, 5.2 CAL Area Action Plan Summary Review

The inspectors concluded that the individual CAL items described above and the associated area action plans were adequately completed and were effective in achieving the associated performance improvement objectives described in the PNPS Recovery Plan.

Based on this conclusion, the ODFA and the SRV White Finding Area Action Plans listed in 2 to the PNPS CAL are closed.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On May 3, 2018, the inspectors telephonically presented the CAL follow-up inspection results to Mr. Brian Sullivan, Site Vice President, and other members of PNPS staff.

DOCUMENTS REVIEWED

CAL Item Closure Packages

ODFA-1.2

ODFA-1.3

ODFA-1.4

ODFA-1.5

ODFA-1.6

ODFA-2.2

ODFA-3.1

ODFA-5.1

ODFA-5.2

ODFA-5.3

ODFA-5.4

ODFA-5.5

ODFA-5.6

ODFA-5.7

ODFA-5.8

SRV-1.1

SRV-1.2

SRV-3.1

SRV-3.2

SRV-3.3

SRV-3.4

SRV-4.1

SRV-5.1

SRV-5.2

Procedures

1.3.34, Operations Administrative Policies and Processes, Responsibilities, Revision 157

1.3.34, Operations Administrative Policies and Processes, Responsibilities, Revision 139

EN-OP-104, Operability Determination Process, Revision 14

EN-OP-104, Operability Determination Process, Revision 13

EN-OP-104, Operability Determination Process, Revision 6

EN-LI-118, Cause Evaluation Process, Revision 26

EN-LI-102, Corrective Action Program, Revision 32

1.3.37, Post Trip Review, Revision 36

EN-LI-123-12-PNP-RC, Comprehensive Recovery Plan and Performance Metrics, Revision 2

EN-FAP-LI-005, Recovery Project Adminstration Controls, Revision 4

EN-FAP-LI-002, Project Review Board Guide, Revision 5

EN-LI-104, Self Assessment and Benchmark Process, Revision 13

EN-LI-121, Trending and Performance Review Process, Revision 24

JA-PI-01, Analysis Manual, Revision 6

EN-WM-100, Work Request Generation, Screening and Classification, Revision 13

EN-OP-115, Conduct of Operations, Revision 24

Operations Policy No. 5, Operability Determinations (Operability Template), Revision 0

EN-OP-115-09, Log Keeping, Revision 2

Audits/Self Assessments/Surveillances

LO-PNPLO-2016-00089, Operability Determination Performance Improvement Plan -

Corrective Action Effectiveness Review, 1/12/2017

LO-PNPLO-2018-00010, Self Assessment for NRC Inspection of Area Action Plan Operability

Determination and Functionality Assessment (Human Performance Focus Area, 2/5/2018

QS-2018-PNPS-02, NIOS Assessment of Operability Determination/Functionality Assessment

(ODFA) and SRV White Finding Recovery Problem Areas fro Readiness for NRC Inspection,

Revision 1

Condition Reports

CR-PNP-2013-00825

CR-PNP-2018-00112

CR-PNP-2018-02125

CR-PNP-2018-02126

CR-PNP-2018-02127

CR-PNP-2018-02128

CR-PNP-2018-02129

CR-PNP-2018-02130

CR-PNP-2018-02131

CR-PNP-2018-02132

CR-PNP-2018-02133

CR-PNP-2018-02134

CR-PNP-2018-02135

CR-PNP-2018-02136

CR-PNP-2018-02137

CR-PNP-2018-02138

CR-PNP-2018-02139

CR-PNP-2018-02140

CR-PNP-2018-02141

CR-PNP-2018-02142

CR-PNP-2018-02143

CR-PNP-2018-02144

CR-PNP-2018-02145

CR-PNP-2018-02146

CR-PNP-2018-02147

CR-PNP-2018-02148

CR-PNP-2018-02149

CR-PNP-2018-02150

CR-PNP-2018-02151

CR-PNP-2018-02152

CR-PNP-2018-02153

CR-PNP-2018-02154

CR-PNP-2018-02155

CR-PNP-2018-02156

CR-PNP-2018-02157

CR-PNP-2018-02158

CR-PNP-2018-02159

CR-PNP-2018-02160

CR-PNP-2018-02161

CR-PNP-2018-02162

CR-PNP-2018-02163

CR-PNP-2018-02164

CR-PNP-2018-02165

CR-PNP-2018-02166

CR-PNP-2018-02167

CR-PNP-2018-02168

CR-PNP-2018-02169

CR-PNP-2018-02170

CR-PNP-2018-02171

CR-PNP-2018-02172

CR-PNP-2018-02173

CR-PNP-2018-02174

CR-PNP-2018-02175

CR-PNP-2018-02176

CR-PNP-2018-02177

CR-PNP-2018-02178

CR-PNP-2018-02179

CR-PNP-2018-02180

CR-PNP-2018-02181

CR-PNP-2018-02182

CR-PNP-2018-02183

CR-PNP-2018-02184

CR-PNP-2018-02185

CR-PNP-2018-02186

CR-PNP-2018-02187

CR-PNP-2018-02188

CR-PNP-2018-02189

CR-PNP-2018-02190

CR-PNP-2018-02191

CR-PNP-2018-02192

CR-PNP-2018-02193

CR-PNP-2018-02194

CR-PNP-2018-02195

CR-PNP-2018-02196

CR-PNP-2018-02197

CR-PNP-2018-02198

CR-PNP-2018-02199

CR-PNP-2018-02200

CR-PNP-2018-02201

CR-PNP-2018-02202

CR-PNP-2018-02203

CR-PNP-2018-02204

CR-PNP-2018-02205

CR-PNP-2018-02206

CR-PNP-2018-02207

CR-PNP-2018-02208

CR-PNP-2018-02209

CR-PNP-2018-02210

CR-PNP-2018-02211

CR-PNP-2018-02212

CR-PNP-2018-02213

CR-PNP-2018-02214

CR-PNP-2018-02215

CR-PNP-2018-02216

CR-PNP-2018-02217

CR-PNP-2018-02218

CR-PNP-2018-02219

CR-PNP-2018-02220

CR-PNP-2018-02221

CR-PNP-2018-02222

CR-PNP-2018-02223

CR-PNP-2018-02224

CR-PNP-2018-02225

CR-PNP-2018-02226

CR-PNP-2018-02227

CR-PNP-2018-02228

CR-PNP-2018-02229

CR-PNP-2018-02230

CR-PNP-2018-02231

CR-PNP-2018-02232

CR-PNP-2018-02233

CR-PNP-2018-02234

CR-PNP-2018-02235

CR-PNP-2018-02236

CR-PNP-2018-02237

CR-PNP-2018-02238

CR-PNP-2018-02239

CR-PNP-2018-02240

CR-PNP-2018-02241

CR-PNP-2018-02242

CR-PNP-2018-02243

CR-PNP-2018-02244

CR-PNP-2018-02245

CR-PNP-2018-02246

CR-PNP-2018-02247

CR-PNP-2018-02248

CR-PNP-2018-02249

CR-PNP-2018-02250

CR-PNP-2018-02251

CR-PNP-2018-02252

CR-PNP-2018-02253

CR-PNP-2018-02254

CR-PNP-2018-02255

CR-PNP-2018-02256

CR-PNP-2018-02257

CR-PNP-2018-02258

CR-PNP-2018-02259

CR-PNP-2018-02260

Operability Determinations

CR-PNP-2017-00009

CR-PNP-2017-00033

CR-PNP-2017-00086

CR-PNP-2017-00204

CR-PNP-2017-00215

CR-PNP-2017-00239

CR-PNP-2017-00257

CR-PNP-2017-00494

CR-PNP-2017-00499

CR-PNP-2017-00714

CR-PNP-2017-00961

CR-PNP-2017-01101

CR-PNP-2017-01236

CR-PNP-2017-01363

CR-PNP-2017-01405

CR-PNP-2017-01531

CR-PNP-2017-01709

CR-PNP-2017-01747

CR-PNP-2017-01846

CR-PNP-2017-02194

CR-PNP-2017-02276

CR-PNP-2017-02381

CR-PNP-2017-02434

CR-PNP-2017-02622

CR-PNP-2017-02785

CR-PNP-2017-02900

CR-PNP-2017-02994

CR-PNP-2017-03541

CR-PNP-2017-03694

CR-PNP-2017-03952

CR-PNP-2017-04208

CR-PNP-2017-04563

CR-PNP-2017-04768

CR-PNP-2017-05067

CR-PNP-2017-05075

CR-PNP-2017-05137

CR-PNP-2017-05255

CR-PNP-2017-05390

CR-PNP-2017-05531

CR-PNP-2017-05586

CR-PNP-2017-05801

CR-PNP-2017-05903

CR-PNP-2017-06029

CR-PNP-2017-06197

CR-PNP-2017-06380

CR-PNP-2017-07320

CR-PNP-2017-07390

CR-PNP-2017-07658

CR-PNP-2017-07658

CR-PNP-2017-07745

CR-PNP-2017-08038

CR-PNP-2017-08724

CR-PNP-2017-08849

CR-PNP-2017-08971

CR-PNP-2017-09154

CR-PNP-2017-09211

CR-PNP-2017-09589

CR-PNP-2017-09683

CR-PNP-2017-09684

CR-PNP-2017-09690

CR-PNP-2017-09699

CR-PNP-2017-09838

CR-PNP-2017-09925

CR-PNP-2017-10010

CR-PNP-2017-10242

CR-PNP-2017-10374

CR-PNP-2017-10482

CR-PNP-2017-10647

CR-PNP-2017-10660

CR-PNP-2017-10833

CR-PNP-2017-11023

CR-PNP-2017-11430

CR-PNP-2017-11612

CR-PNP-2017-12093

CR-PNP-2017-12105

CR-PNP-2017-12214

CR-PNP-2017-12516

CR-PNP-2017-12571

CR-PNP-2017-12603

CR-PNP-2017-12603

CR-PNP-2017-12623

CR-PNP-2018-00045

CR-PNP-2018-00093

CR-PNP-2018-00112

CR-PNP-2018-00169

CR-PNP-2018-00257

CR-PNP-2018-00258

CR-PNP-2018-00306

CR-PNP-2018-00476

CR-PNP-2018-00489

CR-PNP-2018-00553

CR-PNP-2018-00666

CR-PNP-2018-00667

CR-PNP-2018-00923

CR-PNP-2018-00958

CR-PNP-2018-01034

CR-PNP-2018-01101

CR-PNP-2018-01417

CR-PNP-2018-01565

Work Orders

WO-PNP-00435308 WO-PNP-00435311 WO-PNP-00435314 WO-PNP-00435316

Training Material

AFG-2016-01, Simulator Based Exercise, 09/22/2016

SES-2018-01, LORT/NRC Simulator Exam Scenario, 03/06/2018

TQF-210-DD03-GRADE, LOR Simulator Crew Performance Evaluation Grading Criteria,

Revision 4

TQF-201-IM05, Remedial Training Plan, 01/09/2017

O-RQ-04-01-230, Training Material: Operability Determinations, Revision 1

O-RQ-04-01-238, Training Material: Operability Determination Functionality Assessment

Fundamentals, Revision 0

O-RQ-06-02-177, LOR Cycle 7 Scenario #1 Loss 355 line, SSW leak, Chloride Intrusion,

Revision 0

SES-2018-01, LORT/NRC Simulator Exam Scenario, 03/06/2018

TQF-201-IM05, Remedial Training Plan, 01/09/2017

AFG-2016-01, Simulator Based Exercise, 09/22/2016

O-RQ-04-01-257, LOR Cycle 3 2017, HIT Plant Status Update, Revison 1

Effectivenes Reviews

PNPLO-2016-0002 CA-53, Effectiveness Review CR-PNP-2016-01621 RC-3 CAPR-1, CA -79,

3/7/2018

PNPLO-2016-0002 CA-35, Effectiveness Review CR-PNP-2016-01621 RC-2 CAPR-1, CA-13,

3/6/2018

PNPLO-2016-0002 CA-34, Effectiveness Review CR-PNP-2016-01621 RC-1 CAPR-1 CA-11,

10/20/2017

PNPLO-2016-0002 CA-70, Effectiveness Review for the Operability Determination and

Functionality Assessment (ODFA) Area Action Plan, 3/6/2018

Miscellaneous

ODCB Daily Meeting Minutes March 19, 2018

ODCB Daily Meeting Minutes March 20, 2018

ODCB Daily Meeting Minutes March 21, 2018

ODCB Daily Meeting Minutes March 22, 2018

ODCB Daily Meeting Minutes January 9, 2018

ODCB Daily Meeting Minutes January 10, 2018

ODCB Daily Meeting Minutes January 11, 2018

Overnight CR Report 2018-03-16

Overnight CR Report 2018-03-17

Overnight CR Report 2018-03-18

Overnight CR Report 2018-03-19

CR-PNP-2016-01621, PNPS, Root Cause Evaluation, Failure to classify SRV A Inoperable,

Revision 3

CR-PNP-2018-0093, Pilgrim Station Scram Report - January 4, 2018,

CR-PNP-2016-1340, Comprehensive Recovery Plan Operability Determination and

Functionality Assessment Area Action Plan Closure Report, March 9, 2018

CR-PNP-2016-1621, Comprehensive Recovery Plan Area Action Plan Safety Relief Valve White

Finding Closure Report, March 9, 2018

Operator Aid #16-06, EN-OP-104 Entry Requirements, March 6, 2018

Operator Aid #16-07, Immediate Operability Determination, March 6, 2018

CR-PNP-2017-7015, Human Performance Evaluation, Missed Reportability Determination for

CR-PNP-2017-6380

Confirmatory Action Letter Item Status

Line

Item

Area Action Plan

CAL Item

Inspection Report Number

Closed

Nuclear Safety Culture

NSC-1.1

Nuclear Safety Culture

NSC-1.2

Nuclear Safety Culture

NSC-1.3

Nuclear Safety Culture

NSC-1.4

Nuclear Safety Culture

NSC-1.5

Nuclear Safety Culture

NSC-1.6

Nuclear Safety Culture

NSC-1.7

Nuclear Safety Culture

NSC-1.8

Nuclear Safety Culture

NSC-1.10

Nuclear Safety Culture

NSC-2.2

Nuclear Safety Culture

NSC-2.3

Nuclear Safety Culture

NSC-3.1

Nuclear Safety Culture

NSC-3.2

Nuclear Safety Culture

NSC-3.3

Nuclear Safety Culture

NSC-3.4

Nuclear Safety Culture

NSC-3.5

Nuclear Safety Culture

NSC-3.6

Nuclear Safety Culture

NSC-3.7

Nuclear Safety Culture

NSC-3.8

Nuclear Safety Culture

NSC-4.1

Nuclear Safety Culture

NSC-4.2

Nuclear Safety Culture

NSC-5.1

Nuclear Safety Culture

NSC-5.2

Nuclear Safety Culture

NSC-5.3

Nuclear Safety Culture

NSC-5.4

Nuclear Safety Culture

NSC-6.1

Nuclear Safety Culture

NSC-7.1

Nuclear Safety Culture

NSC-8.1

Nuclear Safety Culture

NSC-8.6

Nuclear Safety Culture

NSC-8.8

Nuclear Safety Culture

NSC-8.9

Nuclear Safety Culture

NSC-8.10

Nuclear Safety Culture

NSC-8.21

Nuclear Safety Culture

NSC-8.22

Nuclear Safety Culture

NSC-8.25

Nuclear Safety Culture

NSC-8.26

Nuclear Safety Culture

NSC-8.27

Nuclear Safety Culture

NSC-8.28

Nuclear Safety Culture

NSC-8.29

Corrective Action Program

CAP-1.1

05000293/2017010

Y

Line

Item

Area Action Plan

CAL Item

Inspection Report Number

Closed

Corrective Action Program

CAP-1.2

Corrective Action Program

CAP-1.3

Corrective Action Program

CAP-1.4

Corrective Action Program

CAP-1.5

Corrective Action Program

CAP-1.7

Corrective Action Program

CAP-1.8

Corrective Action Program

CAP-1.9

Corrective Action Program

CAP-1.10

Corrective Action Program

CAP-1.11

Corrective Action Program

CAP-2.1

Corrective Action Program

CAP-2.2

Corrective Action Program

CAP-2.3

Corrective Action Program

CAP-3.1

Corrective Action Program

CAP-3.2

Corrective Action Program

CAP-4.2

Corrective Action Program

CAP-4.3

Procedure Use and

Adherence

PUA-1.1

05000293/2017010

Y

Procedure Use and

Adherence

PUA-1.2

05000293/2017010

Y

Procedure Use and

Adherence

PUA-1.3

05000293/2017010

Y

Procedure Use and

Adherence

PUA-1.4

05000293/2017010

Y

Procedure Use and

Adherence

PUA-1.6

Procedure Use and

Adherence

PUA-2.2

Procedure Use and

Adherence

PUA-2.3

Procedure Use and

Adherence

PUA-2.4

Procedure Use and

Adherence

PUA-2.5

Procedure Use and

Adherence

PUA-3.1

Procedure Use and

Adherence

PUA-3.2

Procedure Use and

Adherence

PUA-3.3

Procedure Use and

Adherence

PUA-3.4

Line

Item

Area Action Plan

CAL Item

Inspection Report Number

Closed

Procedure Use and

Adherence

PUA-4.1

Procedure Use and

Adherence

PUA-4.2

Procedure Use and

Adherence

PUA-4.3

Procedure Use and

Adherence

PUA-5.1

Procedure Use and

Adherence

PUA-5.2

Procedure Use and

Adherence

PUA-5.7

Procedure Use and

Adherence

PUA-5.8

Procedure Use and

Adherence

PUA-5.9

Operability Determinations

and Functionality

Assessments

ODFA-

1.1

05000293/2017010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

1.2

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

1.3

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

1.4

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

1.5

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

1.6

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

2.2

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

3.1

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

5.1

05000293/2018010

Y

Line

Item

Area Action Plan

CAL Item

Inspection Report Number

Closed

Operability Determinations

and Functionality

Assessments

ODFA-

5.2

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

5.3

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

5.4

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

5.5

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

5.6

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

5.7

05000293/2018010

Y

Operability Determinations

and Functionality

Assessments

ODFA-

5.8

05000293/2018010

Y

Operations Department

Standards and Leadership

OPS-1.1

Operations Department

Standards and Leadership

OPS-1.2

Operations Department

Standards and Leadership

OPS-1.4

Operations Department

Standards and Leadership

OPS-1.6

Operations Department

Standards and Leadership

OPS-1.7

Operations Department

Standards and Leadership

OPS-2.2

100

Operations Department

Standards and Leadership

OPS-3.1

101

Operations Department

Standards and Leadership

OPS-3.2

2

Operations Department

Standards and Leadership

OPS-4.1

103

Operations Department

Standards and Leadership

OPS-4.2

104

Risk Recognition and

Decision Making

RRDM-

1.1

Line

Item

Area Action Plan

CAL Item

Inspection Report Number

Closed

105

Risk Recognition and

Decision Making

RRDM-

1.2

106

Risk Recognition and

Decision Making

RRDM-

1.3

107

Risk Recognition and

Decision Making

RRDM-

2.1

108

Risk Recognition and

Decision Making

RRDM-

3.1

109

Risk Recognition and

Decision Making

RRDM-

3.2

110

Risk Recognition and

Decision Making

RRDM-

3.3

111

Risk Recognition and

Decision Making

RRDM-

4.3

2

Risk Recognition and

Decision Making

RRDM-

4.8

113

Risk Recognition and

Decision Making

RRDM-

4.9

114

Procedure Quality

PQ-1.1

Reviewed - 05000293/2017010

N

115

Procedure Quality

PQ-2.1

05000293/2017010

Y

116

Procedure Quality

PQ-2.2

05000293/2017010

Y

117

Procedure Quality

PQ-3.1

05000293/2017010

Y

118

Procedure Quality

PQ-3.2

05000293/2017010

Y

119

Procedure Quality

PQ-3.3

05000293/2017010

Y

20

Procedure Quality

PQ-5.1

05000293/2017010

Y

21

Procedure Quality

PQ-5.2

Reviewed - 05000293/2017010

N

2

SRV White Finding

SRV-1.1

05000293/2018010

Y

23

SRV White Finding

SRV-1.2

05000293/2018010

Y

24

SRV White Finding

SRV-1.3

05000293/2017010

Y

25

SRV White Finding

SRV-2.1

05000293/2017010

Y

26

SRV White Finding

SRV-3.1

05000293/2018010

Y

27

SRV White Finding

SRV-3.2

05000293/2018010

Y

28

SRV White Finding

SRV-3.3

05000293/2018010

Y

29

SRV White Finding

SRV-3.4

05000293/2018010

Y

130

SRV White Finding

SRV-4.1

05000293/2018010

Y

131

SRV White Finding

SRV-5.1

05000293/2018010

Y

2

SRV White Finding

SRV-5.2

05000293/2018010

Y

133

Engineering Programs

EP-1.1

05000293/2017010

Y

134

Engineering Programs

EP-1.2

135

Engineering Programs

EP-2.1

136

Engineering Programs

EP-2.2

137

Engineering Programs

EP-2.3

138

Engineering Programs

EP-2.4

Line

Item

Area Action Plan

CAL Item

Inspection Report Number

Closed

139

Engineering Programs

EP-3.1

140

Engineering Programs

EP-4.1

141

Equipment Reliability

ER-1.1

05000293/2017010

Y

2

Equipment Reliability

ER-1.2

05000293/2017010

Y

143

Equipment Reliability

ER-1.3

144

Equipment Reliability

ER-2.1

145

Equipment Reliability

ER-2.2

146

Equipment Reliability

ER-3.1

147

Equipment Reliability

ER-3.2

148

Equipment Reliability

ER-3.3

149

Work Management

WM-1.1

150

Work Management

WM-1.2

151

Work Management

WM-1.3

2

Work Management

WM-2.1

153

Work Management

WM-2.2

154

Work Management

WM-3.1

155

Work Management

WM-3.3

156

Work Management

WM-4.2