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| number = ML15273A456 | | number = ML15273A456 | ||
| issue date = 10/01/2015 | | issue date = 10/01/2015 | ||
| title = | | title = Problem Identification and Resolution Inspection Report and Notices of Violation 05000293/2015010 | ||
| author name = | | author name = Mckinley R | ||
| author affiliation = NRC/RGN-I/DRP | | author affiliation = NRC/RGN-I/DRP | ||
| addressee name = Dent J | | addressee name = Dent J | ||
Line 14: | Line 14: | ||
| page count = 36 | | page count = 36 | ||
}} | }} | ||
See also: [[ | See also: [[see also::IR 05000293/2015010]] | ||
=Text= | =Text= | ||
{{#Wiki_filter:OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | {{#Wiki_filter:OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | ||
UNITED STATES | |||
Mr. John Dent Site Vice President Entergy Nuclear Operations, Inc. | NUCLEAR REGULATORY COMMISSION | ||
Pilgrim Nuclear Power Station | REGION I | ||
600 Rocky Hill Road | 2100 RENAISSANCE BLVD., SUITE 100 | ||
Plymouth, MA | KING OF PRUSSIA, PA 19406-2713 | ||
05000293/2015010 | October 1, 2015 | ||
On August 20, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection | Mr. John Dent | ||
at your Pilgrim Nuclear Power Station (Pilgrim). | Site Vice President | ||
Entergy Nuclear Operations, Inc. | |||
The inspectors reviewed selected procedures and records, observed activities, and interviewed | Pilgrim Nuclear Power Station | ||
personnel. | 600 Rocky Hill Road | ||
Plymouth, MA 02360-5508 | |||
threshold. | SUBJECT: PILGRIM NUCLEAR POWER STATION - PROBLEM IDENTIFICATION AND | ||
In addition to implementation of the corrective action program, the inspectors also reviewed | RESOLUTION INSPECTION REPORT AND NOTICES OF VIOLATION | ||
challenges to | 05000293/2015010 | ||
observations, Pilgrim staff are willing to raise nuclear safety concerns through at least one of the several means available. | Dear Mr. Dent: | ||
On August 20, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection | |||
at your Pilgrim Nuclear Power Station (Pilgrim). The enclosed report documents the inspection | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | results, which were discussed on August 20, 2015, with you and other members of your staff. | ||
second violation contains security-related information and is documented in Enclosures 3 and 4. | NRC inspectors examined activities conducted under your license as they relate to safety and | ||
The NRC evaluated both of these violations in accordance with the NRC Enforcement Policy, located on the | compliance with the Commissions rules and regulations and with the conditions of your license. | ||
Specifically, Entergy did not restore compliance within a reasonable amount of time after the | The inspectors reviewed selected procedures and records, observed activities, and interviewed | ||
NRC first issued these violations in Inspection Report 05000293/2013008, issued November 20, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13326A072). | personnel. | ||
Based on the samples selected for review, the inspectors concluded that Entergy Nuclear | |||
You are required to respond to this letter and should follow the instructions specified in the | Operations, Inc., (Entergys) implementation of the corrective action program and overall | ||
enclosed Notices when preparing your response. | performance related to evaluating and resolving problems was marginally effective. In most | ||
necessary to ensure compliance with regulatory requirements. | cases, Entergy identified issues and entered them into the corrective action program at a low | ||
threshold. However, Entergy did not consistently prioritize, evaluate, and implement corrective | |||
The inspectors determined that the security-related cited violation had a cross-cutting aspect in | actions to resolve problems in a timely manner, commensurate with the safety significance of | ||
the area of Problem Identification and Resolution, Evaluation, because Entergy did not thoroughly evaluate the issue to ensure that resolutions addressed causes and extent of condition, commensurate with the significance of the issue [P.2]. | the issues. | ||
in this cited violation was corrected or compensated for, and the plant was in compliance with | In addition to implementation of the corrective action program, the inspectors also reviewed | ||
applicable physical protection and security requirements within the scope of this inspection | Entergys use of operating experience, conduct of self-assessments, and safety conscious work | ||
before inspectors left the site. | environment at the station. Based on the samples selected for review, the inspectors did not | ||
Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, | identify any issues with Entergys use of industry operating experience at Pilgrim. The | ||
inspectors concluded that the self-assessments reviewed were generally effective in identifying | |||
issues and improvement opportunities. Finally, the inspectors found no evidence of significant | |||
challenges to Pilgrims safety conscious work environment. Based on the inspectors | |||
observations, Pilgrim staff are willing to raise nuclear safety concerns through at least one of the | |||
several means available. | |||
Enclosures 3 and 4 contain Sensitive Unclassified | |||
Non-Safeguards Information. When separated | |||
from Enclosures 3 and 4, the transmittal document | |||
is DECONTROLLED. | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
J. Dent -2- | |||
Two violations of very low safety significance (Green) are cited in the enclosed Notices of | |||
Violation (Notices). The details of the first violation are documented in Enclosures 1 and 2. The | |||
second violation contains security-related information and is documented in Enclosures 3 and 4. | |||
The NRC evaluated both of these violations in accordance with the NRC Enforcement Policy, | |||
located on the NRCs website at http://www.nrc.gov/about-nrc/regulatory/ enforcement/enforce- | |||
pol.html. The NRC is citing both of these violations because all of the criteria specified in | |||
Section 2.3.2.a of the NRC Enforcement Policy for a non-cited violation were not satisfied. | |||
Specifically, Entergy did not restore compliance within a reasonable amount of time after the | |||
NRC first issued these violations in Inspection Report 05000293/2013008, issued November 20, | |||
2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. | |||
ML13326A072). | |||
You are required to respond to this letter and should follow the instructions specified in the | |||
enclosed Notices when preparing your response. If you have additional information that you | |||
believe the NRC should consider, you may provide it in response to the Notices. The NRC | |||
review of your response to the Notices will also determine whether enforcement action is | |||
necessary to ensure compliance with regulatory requirements. | |||
The inspectors determined that the security-related cited violation had a cross-cutting aspect in | |||
the area of Problem Identification and Resolution, Evaluation, because Entergy did not | |||
thoroughly evaluate the issue to ensure that resolutions addressed causes and extent of | |||
condition, commensurate with the significance of the issue [P.2]. Also, the deficiency described | |||
in this cited violation was corrected or compensated for, and the plant was in compliance with | |||
applicable physical protection and security requirements within the scope of this inspection | |||
before inspectors left the site. | |||
This report also documents two findings of very low safety significance (Green). The inspectors | |||
determined that each of these findings also involved a violation of NRC requirements. However, | |||
because of the very low safety significance, and because they were 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 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- | Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555- | ||
0001; and the NRC Resident Inspector at Pilgrim. | 0001; and the NRC Resident Inspector at Pilgrim. In addition, if you disagree with the cross- | ||
Administrator, Region I, and the NRC Resident Inspector at Pilgrim. | cutting aspect assigned to any finding 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 | |||
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the | Administrator, Region I, and the NRC Resident Inspector at Pilgrim. | ||
However, the material enclosed herewith contains security-related information in accordance with 10 CFR 2.390(d)(1), and its disclosure to unauthorized individuals could present a security vulnerability. | In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be | ||
entire response | available electronically for public inspection in the NRCs Public Document Room or from the | ||
requirements for your response. | Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC | ||
website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | |||
Raymond R. McKinley, Chief Reactor Projects Branch 5 Division of Reactor Projects | However, the material enclosed herewith contains security-related information in accordance | ||
License No. DPR-35 | with 10 CFR 2.390(d)(1), and its disclosure to unauthorized individuals could present a security | ||
vulnerability. Therefore, the material in Enclosures 3 and 4 will not be made available | |||
2. (Public) Inspection Report 05000293/2015010 | OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
cc w/encl 1, encl 2, encl 3, encl 4; w/OUO-SRI: P. Beabout, Protective Services Department Section Manager J. Giarrusso, SLO, Massachusetts Emergency Management Agency (MEMA) | J. Dent -3- | ||
electronically for public inspection in the NRC Public Document Room or from the Publicly | |||
Available Records component of NRCs ADAMS. If you choose to provide a response, and | |||
security-related information is necessary to provide an acceptable response, please mark your | |||
entire response Security-Related Information - Withhold from Public Disclosure under 10 CFR | |||
2.390 in accordance with 10 CFR 2.390(d)(1), and follow instructions for withholding in 10 CFR | |||
2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit | |||
requirements for your response. | |||
Sincerely, | |||
/RA/ | |||
Raymond R. McKinley, Chief | |||
Reactor Projects Branch 5 | |||
Division of Reactor Projects | |||
Docket No. 50-293 | |||
License No. DPR-35 | |||
Enclosures: | |||
1. (Public) Notice of Violation | |||
2. (Public) Inspection Report 05000293/2015010 | |||
w/Attachment: Supplementary Information | |||
3. (Non-Public) Notice of Violation | |||
(CONTAINS OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION (OUO- | |||
SRI)) | |||
4. (Non-Public) Inspection Report 05000293/2015010 | |||
w/Attachment: Supplementary Information | |||
(CONTAINS OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION (OUO- | |||
SRI)) | |||
cc w/encl 1, encl 2; w/o encl 3, encl 4; w/o OUO-SRI: | |||
Distribution via ListServ | |||
cc w/encl 1, encl 2, encl 3, encl 4; w/OUO-SRI: | |||
P. Beabout, Protective Services Department Section Manager | |||
J. Giarrusso, SLO, Massachusetts Emergency Management Agency (MEMA) | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
Non-Sensitive Publicly Available | |||
SUNSI Review | |||
Sensitive Non-Publicly Available | |||
OFFICE RI/DRP RI/ORA RI/DRS RI/DRP RI/DRP | |||
NAME CBickett/cab BBickett/mmm for ADimitriadis/ad RPowell/cab for RMcKinley/rrm | |||
DATE 09/15/15 09/16/15 09/21/15 09/28/15 10/01/15 | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
Letter to John Dent from Raymond R. McKinley dated October 1, 2015 | |||
SUBJECT: PILGRIM NUCLEAR POWER STATION - PROBLEM IDENTIFICATION AND | |||
RESOLUTION INSPECTION REPORT AND NOTICES OF VIOLATION | |||
05000293/2015010 | |||
DISTRIBUTION w/encl 1, encl 2; w/o encl 3, encl 4; w/o OUO-SRI: (via email) | |||
DDorman, RA | |||
DLew, DRA | |||
MScott, DRP | |||
JColaccino, DRP | |||
RLorson, DRS | |||
GSuber, DRS | |||
RMcKinley, DRP | |||
SShaffer, DRP | |||
EDiPaolo, DRP | |||
JDeBoer, DRP | |||
MHenrion, DRP | |||
ECarfang, DRP, SRI | |||
BScrabeck, DRP, RI | |||
TGreer, DRP, AA | |||
JJessie, RI OEDO | |||
RidsNrrPMPilgrim Resource | |||
RidsNrrDorlLPL1-1 Resource | |||
ROPReports.Resource | |||
DISTRIBUTION w/encl 1, encl 2, encl 3, encl 4; w/OUO-SRI: (via email) | |||
CJohnson, NSIR | |||
NSimonian, NSIR | |||
EWharton, NSIR | |||
BDesai, DRS, RII | |||
SOrth, DRS, RIII | |||
MHaire, DRS, RIV | |||
RMcKinley, DRP | |||
ECarfang, DRP, SRI | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
NOTICE OF VIOLATION | |||
Entergy Nuclear Operations, Inc. Docket No. 50-293 | |||
Pilgrim Nuclear Power Station License No. DPR-35 | |||
During an NRC inspection conducted from August 3 through August 20, 2015, a violation of | |||
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the | |||
violation is listed below: | |||
10 CFR 50.54(q)(2) requires, in part, that a holder of a nuclear power reactor operating | |||
license shall follow and maintain the effectiveness of an emergency plan that meets the | |||
requirements in Appendix E to this part, and the planning standards of 10 CFR 50.47(b). | |||
10 CFR 50.47(b)(8) requires, in part, that adequate equipment to support the emergency | |||
response are provided and maintained. | |||
The Pilgrim Nuclear Power Station (Pilgrim) Emergency Plan states, in part, that Pilgrim | |||
has two meteorological towers, a 220 primary and a 160 back-up, equipped with | |||
instrumentation for continuous reading of the wind speed, wind direction, air | |||
temperature, and delta air temperature. | |||
Contrary to the above, since December 2011, Entergy Nuclear Operations, Inc. | |||
(Entergy) did not follow and maintain the effectiveness of the Pilgrim Emergency Plan to | |||
meet the requirement that adequate equipment to support the emergency response was | |||
provided and maintained. Specifically, in December 2011, Entergy cancelled | |||
preventative maintenance of the 160 back-up meteorological tower, and that tower | |||
became non-functional. As a result, on eight occasions between March 18, 2012, and | |||
August 15, 2015, when the 220 primary meteorological tower was also non-functional | |||
for various reasons, Pilgrim did not have instrumentation available on either tower for | |||
continuous reading of the wind speed, wind direction, air temperature, and delta air | |||
temperature. | |||
This violation is associated with a Green Significance Determination Process finding. | |||
Pursuant to the provisions of 10 CFR 2.201, Entergy Nuclear Operations, Inc. (Entergy) is | |||
hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory | |||
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the | |||
Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the Pilgrim | |||
Nuclear Power Station, within 30 days of the date of the letter transmitting this Notice of | |||
Violation (Notice). This reply should be clearly marked as a Reply to a Notice of Violation and | |||
should include: (1) the reason for the violation, or, if contested, the basis for disputing the | |||
violation or severity level, (2) the corrective steps that have been taken and the results | |||
achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will | |||
be achieved. Your response may reference or include previous docketed correspondence, if | |||
the correspondence adequately addresses the required response. If an adequate reply is not | |||
received within the time specified in this Notice, an order or a Demand for Information may be | |||
issued as to why the license should not be modified, suspended, or revoked, or why such other | |||
action as may be proper should not be taken. Where good cause is shown, consideration will | |||
be given to extending the response time. | |||
Enclosure 1 | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
2 | |||
If you contest this enforcement action, you should provide a copy of your response, with the | |||
basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory | |||
Commission, Washington, DC 20555-0001. | |||
Because your response will be made available electronically for public inspection in the NRC | |||
Public Document Room or from the NRCs document system (ADAMS), accessible from the | |||
NRC website at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not | |||
include any personal privacy, proprietary, or safeguards information so that it can be made | |||
available to the public without redaction. If personal privacy or proprietary information is | |||
necessary to provide an acceptable response, then please provide a bracketed copy of your | |||
response that identifies the information that should be protected and a redacted copy of your | |||
response that deletes such information. If you request withholding of such material, you must | |||
specifically identify the portions of your response that you seek to have withheld and provide in | |||
detail the bases of your claim of withholding (e.g., explain why the disclosure of information | |||
required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or | |||
financial information). If safeguards information is necessary to provide an acceptable | |||
response, please provide the level of protection described in 10 CFR 73.21. | |||
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working | |||
days of receipt. | |||
Dated this 1st day of October, 2015. | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
1 | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION I | |||
Docket No. 50-293 | |||
License No. DPR-35 | |||
Report No. 05000293/2015010 | |||
Licensee: Entergy Nuclear Operations, Inc. (Entergy) | |||
Facility: Pilgrim Nuclear Power Station | |||
Location: 600 Rocky Hill Road | |||
Plymouth, MA 02360 | |||
Dates: August 3 - 20, 2015 | |||
Team Leader: C. Bickett, Senior Project Engineer, Region I | |||
Inspectors: D. Caron, Senior Security Inspector, Region I | |||
E. Knutson, Senior Resident Inspector, FitzPatrick | |||
B. Scrabeck, Resident Inspector, Pilgrim | |||
R. Taylor, Senior Project Inspector, Region II | |||
Approved By: Raymond R. McKinley, Chief | |||
Reactor Projects Branch 5 | |||
Division of Reactor Projects | |||
Enclosure 2 | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
2 | |||
SUMMARY | |||
IR 05000293/2015010; 08/03/2015 - 08/20/2015; Pilgrim Nuclear Power Station (Pilgrim); | |||
Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified | |||
one finding in the area of problem identification, one finding in the area of problem evaluation, | |||
and two findings in the area of problem resolution. | |||
This U.S. Nuclear Regulatory Commission (NRC) team inspection was performed by three | |||
regional inspectors, including an inspector from Region II, one senior resident inspector, and | |||
one resident inspector. During this inspection, the inspectors identified four findings of very low | |||
safety significance (Green). Two of these findings were classified as cited violations because | |||
Entergy did not restore compliance within a reasonable amount of time after the NRC initially | |||
identified the violations. The other two findings were classified as non-cited violations. The | |||
significance of inspection 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, dated April 29, 2015. Cross-cutting aspects are determined using IMC | |||
0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of NRC | |||
requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated | |||
February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear | |||
power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5. | |||
Problem Identification and Resolution | |||
Based on the samples selected for review, the inspectors concluded that Entergy was generally | |||
effective at identifying issues and entering them into the corrective action program at a low | |||
threshold. However, the inspectors noted several examples where Entergy missed identification | |||
of conditions adverse to quality throughout the two-year period since the last problem | |||
identification and resolution inspection in October 2013. Additionally, the inspectors identified | |||
one violation related to an inadequate compensatory measure that resulted from Entergy not | |||
identifying an adverse condition in the corrective action program for resolution. | |||
Though Entergys identification of issues was generally effective, the inspectors determined that | |||
Entergys implementation of the corrective action program related to evaluating and resolving | |||
problems was marginally effective. Entergy did not consistently prioritize, evaluate, and | |||
implement corrective actions to resolve problems in a timely manner, commensurate with the | |||
safety significance of the issues. The inspectors identified one violation related to inadequate | |||
procedures, and two cited violations because Entergy did not restore compliance within a | |||
reasonable amount of time after the NRC issued the original violations in November 2013. | |||
Additionally, the inspectors noted multiple examples of deficiencies related to evaluation and | |||
resolution of issues throughout the two-year inspection period. Also of note, Pilgrims self- | |||
assessment of the corrective action program performed in preparation for this inspection | |||
determined that the effectiveness of both causal analyses and resolution of issues in a thorough | |||
and timely manner were unsatisfactory. | |||
The inspectors determined that in general, Entergy appropriately considered industry operating | |||
experience information for applicability, and used the information for corrective and preventive | |||
actions to identify and prevent similar issues when appropriate. The inspectors concluded that | |||
the self-assessments reviewed were generally thorough and effective in identifying issues and | |||
improvement opportunities. | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
3 | |||
Based on the interviews the inspectors conducted over the course of the inspection, | |||
observations of plant activities, and reviews of individual corrective action program and | |||
employee concerns program issues, the inspectors did not identify any indications that site | |||
personnel were unwilling to raise safety issues nor did they identify any conditions that could | |||
have had a negative impact on the sites safety conscious work environment. | |||
Cornerstone: Initiating Events | |||
* Green. The inspectors identified a self-revealing Green non-cited violation of Technical | |||
Specification 5.4.1, Procedures, because Entergy did not provide adequate procedures in | |||
that appropriate operator actions to recover systems and components important to safety | |||
were not included within operating procedures 2.1.1, Startup from Shutdown, and 2.2.93, | |||
Main Condenser Vacuum System, as well as abnormal operating procedure 2.4.36, | |||
Decreasing Condenser Vacuum. Corrective actions include, in part, for Entergy engineers | |||
to establish operational limits for the offgas system, to include the factors of reactor power, | |||
air in-leakage, sea water system alignment, status of the augmented offgas system, status | |||
of the main turbine, and sea water inlet temperature, and to incorporate these limitations into | |||
site procedures. Entergy entered this issue into their corrective action program as condition | |||
report CR-PNP-2015-5197. | |||
This finding was more than minor because it was associated with the procedure quality | |||
attribute of the Initiating Events cornerstone and adversely affected the cornerstone | |||
objective to limit the likelihood of events that upset plant stability and challenge critical safety | |||
functions during shutdown as well as power operations. Additionally, this performance | |||
deficiency is similar to example 4.b in IMC 0612, Appendix E, Examples of Minor Issues, in | |||
that it contributed to a reactor trip. The inspectors evaluated the finding using IMC 0609, | |||
Appendix A, Exhibit 1, Initiating Events Screening Questions. The inspectors determined | |||
this finding was of very low safety significance (Green) because it did not cause a loss of | |||
mitigation equipment relied upon to transition the plant from the onset of the trip to a stable | |||
shutdown condition. This finding had a cross-cutting aspect in the area of Human | |||
Performance, Design Margins, because Entergy did not operate equipment within design | |||
margins. Specifically, Entergy staffs lack of awareness of the limitations of offgas system | |||
during startup and while placing the main turbine in service resulted in operators | |||
establishing conditions that were outside those limitations. [H.6] (Section 4OA2.c.(1)) | |||
Cornerstone: Emergency Preparedness | |||
* Green. The inspectors identified a Green cited violation of Title 10 of the Code of Federal | |||
Regulations (10 CFR) Part 50.54(q)(2) because Entergy did not ensure that the Pilgrim | |||
Emergency Plan met the planning standards in 10 CFR 50.47(b). Specifically, in December | |||
2011, Entergy cancelled preventative maintenance of the 160 back-up meteorological | |||
tower, and that tower became non-functional. As a result, on eight occasions between | |||
March 18, 2012, and August 15, 2015, when the 220 primary meteorological tower was also | |||
non-functional for various reasons, Pilgrim did not have instrumentation available on either | |||
tower for continuous reading of the wind speed, wind direction, air temperature, and delta air | |||
temperature. At the time of this inspection in August 2015, Entergy was in the process of | |||
obtaining necessary permits for construction of the new tower. | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
4 | |||
This finding is more than minor because it is associated with the facilities and equipment | |||
attribute of the Emergency Preparedness cornerstone and adversely affected the | |||
cornerstone objective of ensuring the licensee is capable of implementing adequate | |||
measures to protect the health and safety of the public in the event of a radiological | |||
emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness | |||
Significance Determination Process, Table 5.8-1, the inspectors determined the finding to | |||
be of very low safety significance (Green) because the planning standard function was | |||
degraded. Specifically, a significant amount of equipment necessary to implement the | |||
emergency plan was not functional to the extent that an emergency response organization | |||
member could not perform assigned functions, in the absence of compensatory measures. | |||
However, Pilgrim was able to make adequate dose assessments at all times using the | |||
National Weather Service to obtain necessary data. This finding has a cross-cutting aspect | |||
in the area of Problem Identification and Resolution, Resolution, because Pilgrim did not | |||
take effective corrective actions to address issues in a timely manner commensurate with | |||
their safety significance. Specifically, numerous delays and extensions of corrective actions | |||
resulted in a period of approximately two years in which the adverse condition identified by | |||
the inspectors had not been corrected, during which additional outages of the primary | |||
meteorological tower have resulted in additional unnecessary degradation of the Pilgrim | |||
Emergency Plan. [P.3] (Section 4OA2.c.(2)) | |||
* Green. The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2) because | |||
Entergy did not follow and maintain an emergency plan that meets the requirements of | |||
planning standards 10 CFR 50.47(b) and Appendix E. Specifically, the Emergency Plan | |||
Implementing Procedure specified insufficient equipment as the primary method of | |||
emergency action level assessment, and directed invalid compensatory measures to be | |||
used when the primary method of emergency action level assessment for reactor coolant | |||
system leakage was unavailable. Entergy entered these issues into the corrective action | |||
program as condition reports CR-PNP-2015-7183 and CR-PNP-2015-7394. Additionally, | |||
since the time of this inspection, Entergy completed and issued the new procedure | |||
governing equipment important to emergency response. | |||
This finding was more than minor because it was associated with the emergency response | |||
organization performance (program elements not meeting 50.47(b) planning standards) | |||
attribute of the Emergency Preparedness cornerstone and affected the cornerstone | |||
objective of ensuring that the licensee is capable of implementing adequate measures to | |||
protect the health and safety of the public in the event of a radiological emergency. | |||
Specifically, the incomplete procedural guidance and the inadequate compensatory | |||
measure could have led to an | |||
the condition into the corrective action program under condition report CR-PNP-2013- | the condition into the corrective action program under condition report CR-PNP-2013- | ||
6829. However, the inspectors determined that Entergys actions to address the | |||
adverse condition have not been addressed in a timely manner. In March 2014, Entergy | |||
developed initial corrective actions to reinstitute preventive maintenance on the 160 | |||
meteorological tower and restore the tower to operation; however, these corrective | |||
actions were not implemented. In July 2014, Entergy decided to cease plans to restore | |||
the 160 meteorological tower and instead to design and construct a new tower. At the | |||
time of this inspection in August 2015, Entergy was in the process of obtaining | |||
necessary permits for construction of the new tower. | |||
Due to the delays in both the initiation and the implementation of corrective actions, the | |||
condition that was identified by the inspectors in 2013 continues to exist. Moreover, | |||
during that time period there have been numerous additional instances where the 220 | |||
meteorological tower was non-functional: from January 14, 2015, through January 19, | |||
2015, due to a malfunctioning wind sensor; January 27, 2015, due to effects from winter | |||
storm Juno; February 21, 2015, through April 12, 2015, due to a failed differential | |||
temperature instrument; May 4, 2015, and May 5, 2015, due to power being secured | |||
during an outage; and August 11, 2015, through August 15, 2015, due to malfunctioning | |||
wind sensors and the effects of nearby construction activities. During these periods, | |||
both the 160 and 220 meteorological towers were no longer capable of providing a | |||
continuous reading of the parameters mentioned above, and therefore did not have the | |||
capability to provide accurate data necessary to perform assessment of offsite dose | |||
consequences during a radiological emergency condition, as required by Pilgrims | |||
Emergency Plan. And again, as a result, Entergy was relying on the information from | |||
the National Weather Service as an alternate data source. | |||
Analysis. The inspectors determined that not maintaining the 160 and 220 | |||
meteorological towers in accordance with 10 CFR 50.47(b)(8), resulting in both towers | |||
being out of service concurrently for eight separate periods between 2012 and 2015, | |||
was a performance deficiency that was within Entergys ability to foresee and correct, | |||
and should have been prevented. This performance deficiency is more than minor | |||
because it is associated with the facilities and equipment attribute of the Emergency | |||
Preparedness cornerstone and adversely affected the cornerstone objective of ensuring | |||
the licensee is capable of implementing adequate measures to protect the health and | |||
safety of the public in the event of a radiological emergency. In accordance with IMC | |||
0609, Appendix B, Emergency Preparedness Significance Determination Process, | |||
Table 5.8-1, issued September 26, 2014, the inspectors determined the finding to be of | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
18 | |||
very low safety significance (Green) because the planning standard function | |||
}} | }} |
Latest revision as of 22:15, 4 December 2019
ML15273A456 | |
Person / Time | |
---|---|
Site: | Pilgrim |
Issue date: | 10/01/2015 |
From: | Raymond Mckinley Division Reactor Projects I |
To: | Dent J Entergy Nuclear Operations |
References | |
IR 2015010 | |
Download: ML15273A456 (36) | |
See also: IR 05000293/2015010
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100
KING OF PRUSSIA, PA 19406-2713
October 1, 2015
Mr. John Dent
Site Vice President
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station
600 Rocky Hill Road
Plymouth, MA 02360-5508
SUBJECT: PILGRIM NUCLEAR POWER STATION - PROBLEM IDENTIFICATION AND
RESOLUTION INSPECTION REPORT AND NOTICES OF VIOLATION
Dear Mr. Dent:
On August 20, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Pilgrim Nuclear Power Station (Pilgrim). The enclosed report documents the inspection
results, which were discussed on August 20, 2015, with you and other members of your staff.
NRC inspectors 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.
Based on the samples selected for review, the inspectors concluded that Entergy Nuclear
Operations, Inc., (Entergys) implementation of the corrective action program and overall
performance related to evaluating and resolving problems was marginally effective. In most
cases, Entergy identified issues and entered them into the corrective action program at a low
threshold. However, Entergy did not consistently prioritize, evaluate, and implement corrective
actions to resolve problems in a timely manner, commensurate with the safety significance of
the issues.
In addition to implementation of the corrective action program, the inspectors also reviewed
Entergys use of operating experience, conduct of self-assessments, and safety conscious work
environment at the station. Based on the samples selected for review, the inspectors did not
identify any issues with Entergys use of industry operating experience at Pilgrim. The
inspectors concluded that the self-assessments reviewed were generally effective in identifying
issues and improvement opportunities. Finally, the inspectors found no evidence of significant
challenges to Pilgrims safety conscious work environment. Based on the inspectors
observations, Pilgrim staff are willing to raise nuclear safety concerns through at least one of the
several means available.
Enclosures 3 and 4 contain Sensitive Unclassified
Non-Safeguards Information. When separated
from Enclosures 3 and 4, the transmittal document
is DECONTROLLED.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
J. Dent -2-
Two violations of very low safety significance (Green) are cited in the enclosed Notices of
Violation (Notices). The details of the first violation are documented in Enclosures 1 and 2. The
second violation contains security-related information and is documented in Enclosures 3 and 4.
The NRC evaluated both of these violations in accordance with the NRC Enforcement Policy,
located on the NRCs website at http://www.nrc.gov/about-nrc/regulatory/ enforcement/enforce-
pol.html. The NRC is citing both of these violations because all of the criteria specified in
Section 2.3.2.a of the NRC Enforcement Policy for a non-cited violation were not satisfied.
Specifically, Entergy did not restore compliance within a reasonable amount of time after the
NRC first issued these violations in Inspection Report 05000293/2013008, issued November 20,
2013 (Agencywide Documents Access and Management System (ADAMS) Accession No.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notices when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in response to the Notices. The NRC
review of your response to the Notices will also determine whether enforcement action is
necessary to ensure compliance with regulatory requirements.
The inspectors determined that the security-related cited violation had a cross-cutting aspect in
the area of Problem Identification and Resolution, Evaluation, because Entergy did not
thoroughly evaluate the issue to ensure that resolutions addressed causes and extent of
condition, commensurate with the significance of the issue [P.2]. Also, the deficiency described
in this cited violation was corrected or compensated for, and the plant was in compliance with
applicable physical protection and security requirements within the scope of this inspection
before inspectors left the site.
This report also documents two findings of very low safety significance (Green). The inspectors
determined that each of these findings also involved a violation of NRC requirements. However,
because of the very low safety significance, and because they were 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 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 Pilgrim. In addition, if you disagree with the cross-
cutting aspect assigned to any finding 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 Pilgrim.
In accordance with Title 10 of the Code of Federal Regulations (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 NRCs ADAMS. ADAMS is accessible from the NRC
website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
However, the material enclosed herewith contains security-related information in accordance
with 10 CFR 2.390(d)(1), and its disclosure to unauthorized individuals could present a security
vulnerability. Therefore, the material in Enclosures 3 and 4 will not be made available
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
J. Dent -3-
electronically for public inspection in the NRC Public Document Room or from the Publicly
Available Records component of NRCs ADAMS. If you choose to provide a response, and
security-related information is necessary to provide an acceptable response, please mark your
entire response Security-Related Information - Withhold from Public Disclosure under 10 CFR 2.390 in accordance with 10 CFR 2.390(d)(1), and follow instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit
requirements for your response.
Sincerely,
/RA/
Raymond R. McKinley, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Docket No. 50-293
License No. DPR-35
Enclosures:
1. (Public) Notice of Violation
2. (Public) Inspection Report 05000293/2015010
w/Attachment: Supplementary Information
3. (Non-Public) Notice of Violation
(CONTAINS OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION (OUO-
SRI))
4. (Non-Public) Inspection Report 05000293/2015010
w/Attachment: Supplementary Information
(CONTAINS OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION (OUO-
SRI))
cc w/encl 1, encl 2; w/o encl 3, encl 4; w/o OUO-SRI:
Distribution via ListServ
cc w/encl 1, encl 2, encl 3, encl 4; w/OUO-SRI:
P. Beabout, Protective Services Department Section Manager
J. Giarrusso, SLO, Massachusetts Emergency Management Agency (MEMA)
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE RI/DRP RI/ORA RI/DRS RI/DRP RI/DRP
NAME CBickett/cab BBickett/mmm for ADimitriadis/ad RPowell/cab for RMcKinley/rrm
DATE 09/15/15 09/16/15 09/21/15 09/28/15 10/01/15
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
Letter to John Dent from Raymond R. McKinley dated October 1, 2015
SUBJECT: PILGRIM NUCLEAR POWER STATION - PROBLEM IDENTIFICATION AND
RESOLUTION INSPECTION REPORT AND NOTICES OF VIOLATION
DISTRIBUTION w/encl 1, encl 2; w/o encl 3, encl 4; w/o OUO-SRI: (via email)
DDorman, RA
DLew, DRA
MScott, DRP
JColaccino, DRP
RLorson, DRS
GSuber, DRS
RMcKinley, DRP
SShaffer, DRP
EDiPaolo, DRP
JDeBoer, DRP
MHenrion, DRP
BScrabeck, DRP, RI
JJessie, RI OEDO
RidsNrrPMPilgrim Resource
RidsNrrDorlLPL1-1 Resource
ROPReports.Resource
DISTRIBUTION w/encl 1, encl 2, encl 3, encl 4; w/OUO-SRI: (via email)
CJohnson, NSIR
NSimonian, NSIR
EWharton, NSIR
BDesai, DRS, RII
SOrth, DRS, RIII
MHaire, DRS, RIV
RMcKinley, DRP
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
NOTICE OF VIOLATION
Entergy Nuclear Operations, Inc. Docket No. 50-293
Pilgrim Nuclear Power Station License No. DPR-35
During an NRC inspection conducted from August 3 through August 20, 2015, a violation of
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the
violation is listed below:
10 CFR 50.54(q)(2) requires, in part, that a holder of a nuclear power reactor operating
license shall follow and maintain the effectiveness of an emergency plan that meets the
requirements in Appendix E to this part, and the planning standards of 10 CFR 50.47(b).
10 CFR 50.47(b)(8) requires, in part, that adequate equipment to support the emergency
response are provided and maintained.
The Pilgrim Nuclear Power Station (Pilgrim) Emergency Plan states, in part, that Pilgrim
has two meteorological towers, a 220 primary and a 160 back-up, equipped with
instrumentation for continuous reading of the wind speed, wind direction, air
temperature, and delta air temperature.
Contrary to the above, since December 2011, Entergy Nuclear Operations, Inc.
(Entergy) did not follow and maintain the effectiveness of the Pilgrim Emergency Plan to
meet the requirement that adequate equipment to support the emergency response was
provided and maintained. Specifically, in December 2011, Entergy cancelled
preventative maintenance of the 160 back-up meteorological tower, and that tower
became non-functional. As a result, on eight occasions between March 18, 2012, and
August 15, 2015, when the 220 primary meteorological tower was also non-functional
for various reasons, Pilgrim did not have instrumentation available on either tower for
continuous reading of the wind speed, wind direction, air temperature, and delta air
temperature.
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Entergy Nuclear Operations, Inc. (Entergy) is
hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the Pilgrim
Nuclear Power Station, within 30 days of the date of the letter transmitting this Notice of
Violation (Notice). This reply should be clearly marked as a Reply to a Notice of Violation and
should include: (1) the reason for the violation, or, if contested, the basis for disputing the
violation or severity level, (2) the corrective steps that have been taken and the results
achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will
be achieved. Your response may reference or include previous docketed correspondence, if
the correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
Enclosure 1
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
2
If you contest this enforcement action, you should provide a copy of your response, with the
basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC website at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases of your claim of withholding (e.g., explain why the disclosure of information
required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or
financial information). If safeguards information is necessary to provide an acceptable
response, please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 1st day of October, 2015.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
1
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No. 50-293
License No. DPR-35
Report No. 05000293/2015010
Licensee: Entergy Nuclear Operations, Inc. (Entergy)
Facility: Pilgrim Nuclear Power Station
Location: 600 Rocky Hill Road
Plymouth, MA 02360
Dates: August 3 - 20, 2015
Team Leader: C. Bickett, Senior Project Engineer, Region I
Inspectors: D. Caron, Senior Security Inspector, Region I
E. Knutson, Senior Resident Inspector, FitzPatrick
B. Scrabeck, Resident Inspector, Pilgrim
R. Taylor, Senior Project Inspector, Region II
Approved By: Raymond R. McKinley, Chief
Reactor Projects Branch 5
Division of Reactor Projects
Enclosure 2
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
2
SUMMARY
IR 05000293/2015010; 08/03/2015 - 08/20/2015; Pilgrim Nuclear Power Station (Pilgrim);
Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified
one finding in the area of problem identification, one finding in the area of problem evaluation,
and two findings in the area of problem resolution.
This U.S. Nuclear Regulatory Commission (NRC) team inspection was performed by three
regional inspectors, including an inspector from Region II, one senior resident inspector, and
one resident inspector. During this inspection, the inspectors identified four findings of very low
safety significance (Green). Two of these findings were classified as cited violations because
Entergy did not restore compliance within a reasonable amount of time after the NRC initially
identified the violations. The other two findings were classified as non-cited violations. The
significance of inspection 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, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of NRC
requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated
February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear
power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Problem Identification and Resolution
Based on the samples selected for review, the inspectors concluded that Entergy was generally
effective at identifying issues and entering them into the corrective action program at a low
threshold. However, the inspectors noted several examples where Entergy missed identification
of conditions adverse to quality throughout the two-year period since the last problem
identification and resolution inspection in October 2013. Additionally, the inspectors identified
one violation related to an inadequate compensatory measure that resulted from Entergy not
identifying an adverse condition in the corrective action program for resolution.
Though Entergys identification of issues was generally effective, the inspectors determined that
Entergys implementation of the corrective action program related to evaluating and resolving
problems was marginally effective. Entergy did not consistently prioritize, evaluate, and
implement corrective actions to resolve problems in a timely manner, commensurate with the
safety significance of the issues. The inspectors identified one violation related to inadequate
procedures, and two cited violations because Entergy did not restore compliance within a
reasonable amount of time after the NRC issued the original violations in November 2013.
Additionally, the inspectors noted multiple examples of deficiencies related to evaluation and
resolution of issues throughout the two-year inspection period. Also of note, Pilgrims self-
assessment of the corrective action program performed in preparation for this inspection
determined that the effectiveness of both causal analyses and resolution of issues in a thorough
and timely manner were unsatisfactory.
The inspectors determined that in general, Entergy appropriately considered industry operating
experience information for applicability, and used the information for corrective and preventive
actions to identify and prevent similar issues when appropriate. The inspectors concluded that
the self-assessments reviewed were generally thorough and effective in identifying issues and
improvement opportunities.
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3
Based on the interviews the inspectors conducted over the course of the inspection,
observations of plant activities, and reviews of individual corrective action program and
employee concerns program issues, the inspectors did not identify any indications that site
personnel were unwilling to raise safety issues nor did they identify any conditions that could
have had a negative impact on the sites safety conscious work environment.
Cornerstone: Initiating Events
- Green. The inspectors identified a self-revealing Green non-cited violation of Technical
Specification 5.4.1, Procedures, because Entergy did not provide adequate procedures in
that appropriate operator actions to recover systems and components important to safety
were not included within operating procedures 2.1.1, Startup from Shutdown, and 2.2.93,
Main Condenser Vacuum System, as well as abnormal operating procedure 2.4.36,
Decreasing Condenser Vacuum. Corrective actions include, in part, for Entergy engineers
to establish operational limits for the offgas system, to include the factors of reactor power,
air in-leakage, sea water system alignment, status of the augmented offgas system, status
of the main turbine, and sea water inlet temperature, and to incorporate these limitations into
site procedures. Entergy entered this issue into their corrective action program as condition
report CR-PNP-2015-5197.
This finding was more than minor because it was associated with the procedure quality
attribute of the Initiating Events cornerstone and adversely affected the cornerstone
objective to limit the likelihood of events that upset plant stability and challenge critical safety
functions during shutdown as well as power operations. Additionally, this performance
deficiency is similar to example 4.b in IMC 0612, Appendix E, Examples of Minor Issues, in
that it contributed to a reactor trip. The inspectors evaluated the finding using IMC 0609,
Appendix A, Exhibit 1, Initiating Events Screening Questions. The inspectors determined
this finding was of very low safety significance (Green) because it did not cause a loss of
mitigation equipment relied upon to transition the plant from the onset of the trip to a stable
shutdown condition. This finding had a cross-cutting aspect in the area of Human
Performance, Design Margins, because Entergy did not operate equipment within design
margins. Specifically, Entergy staffs lack of awareness of the limitations of offgas system
during startup and while placing the main turbine in service resulted in operators
establishing conditions that were outside those limitations. [H.6] (Section 4OA2.c.(1))
Cornerstone: Emergency Preparedness
- Green. The inspectors identified a Green cited violation of Title 10 of the Code of Federal
Regulations (10 CFR) Part 50.54(q)(2) because Entergy did not ensure that the Pilgrim
Emergency Plan met the planning standards in 10 CFR 50.47(b). Specifically, in December
2011, Entergy cancelled preventative maintenance of the 160 back-up meteorological
tower, and that tower became non-functional. As a result, on eight occasions between
March 18, 2012, and August 15, 2015, when the 220 primary meteorological tower was also
non-functional for various reasons, Pilgrim did not have instrumentation available on either
tower for continuous reading of the wind speed, wind direction, air temperature, and delta air
temperature. At the time of this inspection in August 2015, Entergy was in the process of
obtaining necessary permits for construction of the new tower.
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4
This finding is more than minor because it is associated with the facilities and equipment
attribute of the Emergency Preparedness cornerstone and adversely affected the
cornerstone objective of ensuring the licensee is capable of implementing adequate
measures to protect the health and safety of the public in the event of a radiological
emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness
Significance Determination Process, Table 5.8-1, the inspectors determined the finding to
be of very low safety significance (Green) because the planning standard function was
degraded. Specifically, a significant amount of equipment necessary to implement the
emergency plan was not functional to the extent that an emergency response organization
member could not perform assigned functions, in the absence of compensatory measures.
However, Pilgrim was able to make adequate dose assessments at all times using the
National Weather Service to obtain necessary data. This finding has a cross-cutting aspect
in the area of Problem Identification and Resolution, Resolution, because Pilgrim did not
take effective corrective actions to address issues in a timely manner commensurate with
their safety significance. Specifically, numerous delays and extensions of corrective actions
resulted in a period of approximately two years in which the adverse condition identified by
the inspectors had not been corrected, during which additional outages of the primary
meteorological tower have resulted in additional unnecessary degradation of the Pilgrim
Emergency Plan. [P.3] (Section 4OA2.c.(2))
- Green. The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2) because
Entergy did not follow and maintain an emergency plan that meets the requirements of
planning standards 10 CFR 50.47(b) and Appendix E. Specifically, the Emergency Plan
Implementing Procedure specified insufficient equipment as the primary method of
emergency action level assessment, and directed invalid compensatory measures to be
used when the primary method of emergency action level assessment for reactor coolant
system leakage was unavailable. Entergy entered these issues into the corrective action
program as condition reports CR-PNP-2015-7183 and CR-PNP-2015-7394. Additionally,
since the time of this inspection, Entergy completed and issued the new procedure
governing equipment important to emergency response.
This finding was more than minor because it was associated with the emergency response
organization performance (program elements not meeting 50.47(b) planning standards)
attribute of the Emergency Preparedness cornerstone and affected the cornerstone
objective of ensuring that the licensee is capable of implementing adequate measures to
protect the health and safety of the public in the event of a radiological emergency.
Specifically, the incomplete procedural guidance and the inadequate compensatory
measure could have led to an emergency not being declared in a timely manner. The
inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of
Findings, and IMC 0609, Appendix B, Emergency Preparedness Significance
Determination Process. Using Figure 5.4-1, Significance Determination for Ineffective
EALs and Overclassification, and the example in Table 5.4-1, the inspectors determined the
finding was of very low safety significance (Green). The finding had a cross-cutting aspect
in the area of Problem Identification and Resolution, Identification, because Entergy did not
ensure that the issues were promptly reported and documented in the corrective action
program at a low threshold. Specifically, while performing the extent of condition review of
emergency plan implementing procedure EP-IP-100.1, Emergency Action Levels, Entergy
did not effectively utilize the corrective action program to identify and correct newly identified
deficiencies with the guidance for emergency action level assessment and the invalid
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5
compensatory measures. This resulted in the associated degradation of the emergency
plan assessment capability remaining in effect. [P.1] (Section 4OA2.c.(3))
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6
REPORT DETAILS
4. OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (71152B)
This inspection constitutes one biennial sample of problem identification and resolution
as defined by Inspection Procedure 71152. All documents reviewed during this
inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described Entergys corrective action
program at Pilgrim. To assess the effectiveness of the corrective action program, the
inspectors reviewed performance in three primary areas: problem identification,
prioritization and evaluation of issues, and corrective action implementation. The
inspectors compared performance in these areas to the requirements and standards
contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, 10 CFR
73.55(b)(10), and Entergy procedure EN-LI-102, Corrective Action Program, Revision
24. For each of these areas, the inspectors considered risk insights from the stations
risk analysis and reviewed condition reports selected across the seven cornerstones of
safety in the NRCs Reactor Oversight Process. Included in this sample were condition
reports that documented Entergys evaluation and corrective actions for a selective
sample of non-cited violations and findings that had been identified since the last
biennial problem identification and resolution inspection completed in October 2013.
Additionally, the inspectors observed Operational Focus, Condition Report Screening
Committee, Condition Review Group, and Corrective Action Review Board meetings.
Finally, the inspectors reviewed corrective action program insights from NRC inspection
reports issued since the last biennial problem identification and resolution inspection
(period of review: October 2013 through August 2015). The inspectors selected items
from the following functional areas for review: engineering, operations, maintenance,
emergency preparedness, radiation protection, chemistry, physical security, and
oversight programs.
(1) Effectiveness of Problem Identification
In addition to the items described above, the inspectors reviewed system health reports,
a sample of completed corrective and preventative maintenance work orders, completed
surveillance test procedures, operator logs, and department performance review
meeting reports. The inspectors also completed field walkdowns of various areas and
systems on site, including the salt service water system, main control room, and central
alarm station. Additionally, the inspectors reviewed a sample of condition reports written
to document issues identified through internal self-assessments, audits, emergency
preparedness drills, and the operating experience program. The inspectors completed
this review to verify that Entergy entered conditions adverse to quality into their
corrective action program as appropriate.
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(2) Effectiveness of Prioritization and Evaluation of Issues
The inspectors reviewed the evaluation and prioritization of a sample of condition reports
issued since the last NRC biennial problem identification and resolution inspection,
completed in October 2013. The inspectors also reviewed condition reports that were
assigned lower levels of significance that did not include formal cause evaluations to
ensure that they were properly classified. The inspectors review included the
appropriateness of the assigned significance, the scope and depth of the causal
analysis, and the timeliness of resolution. The inspectors assessed whether the
evaluations identified likely causes for the issues and developed appropriate corrective
actions to address the identified causes. Further, the inspectors reviewed equipment
operability determinations, reportability assessments, and extent-of-condition reviews for
selected problems to verify these processes adequately addressed equipment
operability, reporting of issues to the NRC, and the extent of the issues.
(3) Effectiveness of Corrective Actions
The inspectors reviewed Entergys completed corrective actions through documentation
review and, in some cases, field walkdowns to determine whether the actions addressed
the identified causes of the problems. The inspectors also reviewed condition reports for
adverse trends and repetitive problems to determine whether corrective actions were
effective in addressing the broader issues. The inspectors reviewed Entergys
timeliness in implementing corrective actions and effectiveness in precluding recurrence
for significant conditions adverse to quality. The inspectors also reviewed a sample of
condition reports associated with selected non-cited violations and findings to verify that
Entergy personnel properly evaluated and resolved these issues. In addition, the
inspectors expanded the corrective action review to five years to evaluate Entergys
corrective actions related to salt service water system deficiencies.
b. Assessment
(1) Effectiveness of Problem Identification
Based on the selected samples, plant walkdowns, and interviews of site personnel in
multiple functional areas, the inspectors concluded that Entergy generally identified
issues and entered them into the corrective action program at a low threshold. However,
the inspectors identified one violation, discussed in Section 4OA2.1.c.(3), in this area.
Additionally, the inspectors noted several examples where Entergy missed identification
of conditions adverse to quality throughout the period of review for this inspection
(October 2013 through August 2015).
(a) Inspection Observations
Weaknesses in Corrective Action Program Oversight
Entergy procedure EN-LI-102, Corrective Action Program, Revision 24, allows the
station to close condition reports and corrective actions to work orders, provided
certain criteria are met, as described in Attachment 9.6 to this procedure. EN-LI-102,
Section 5.9, Program Oversight, states that the production department will
periodically, typically at least monthly, report to the Condition Review Group the
status of work orders with condition reports and corrective actions closed to them.
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The focus of this report should be the monitoring for timely resolution for those work
orders per Entergy procedure EN-WM-100, Work Request Generation, Screening,
and Classification. The inspectors identified that the Condition Review Group has
not reviewed this information since prior to February 2015.
The inspectors independently screened this issue in accordance with IMC 0612,
Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor
Issues, and determined that this issue was minor. Specifically, inspectors reviewed
a sample of work orders that had condition reports or corrective actions closed to
them and did not identify any that were categorized improperly or affected the
operability of a safety-related system. Entergy documented this issue in their
corrective action program as condition reports CR-PNP-2015-06926 and CR-PNP-
2015-06939. The Condition Review Group meeting agenda has been updated to
ensure that this information is reviewed on a monthly basis.
(b) Inspection Period Observations
The NRC has previously documented specific examples of weaknesses in
identification of conditions adverse to quality over the period of review for this
inspection. This includes:
- In NRC Inspection Report 2015001, the inspectors identified a Green non-cited
violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, because Entergy
did not establish requirements in accordance with their test program for safety-
related 4160V degraded voltage relays. Entergy had multiple opportunities to
identify that undervoltage dropout settings for relays 127-509/1 and 2 were not
being tested during establishment of the test setup or through periodic trending
against similar relays in other systems. (NCV 2015001-01)
- In NRC Inspection Report 2015007, the inspectors identified a Green non-cited
violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because
Entergy did not identify and correct a condition adverse to quality associated with
the partial voiding of the A core spray discharge header on January 27, 2015,
following the loss of the keepfill system due to a loss of offsite power. (NCV
2015007-05)
- In NRC Inspection Report 2015002, the inspectors identified a Green non-cited
violation of 10 CFR 71.5, Transportation of Licensed Material, and 49 CFR 172,
Subpart I, Safety and Security Plans. Specifically, Entergy shipped a Category
2 radioactive material in quantities of concern to a waste processor without
adhering to a transportation security plan. The security transportation plan
requirements became effective in March 2003, but had not been effectively
identified by Entergy. (NCV 2015002-04)
(2) Effectiveness of Prioritization and Evaluation of Issues
The inspectors determined that Entergys implementation of the corrective action
program related to prioritization and evaluation of issues was marginally effective. The
inspectors identified one self-revealing finding in this area related to inadequate
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procedures for operation of the condensate system and plant start-up that resulted in a
reactor scram (Section 4OA2.c.(1)). The inspectors also determined that there were
weaknesses in functionality determinations performed by operations, and noted that
inadequate evaluation of an issue contributed to the violation discussed in Enclosure 4.
Additionally, over the two-year period of inspection, the inspectors noted several
examples in multiple Reactor Oversight Process cornerstones where Entergy did not
properly prioritize and evaluate issues commensurate with the safety significance of the
identified problem. Also of note, Pilgrims self-assessment of the corrective action
program performed in preparation for this inspection identified that the effectiveness of
causal analyses was unsatisfactory.
(a) Inspection Observations
Weaknesses in Functionality Determinations
Inspectors reviewed various condition reports documenting occasions when the 220
meteorological tower was out of service. Each time the 220 meteorological tower
was out of service, the station performed functionality determinations of the
emergency plan in accordance with Entergy procedure EN-OP-104, Operability
Determination Process. In multiple cases, the inspectors noted that the functionality
determinations for the emergency plan credited the 160 meteorological tower and
the National Weather Service as a back-up source of information. Though the
National Weather Service was available, the 160 meteorological tower has been out
of service since 2011. Pilgrim entered this issue into their corrective action program
as condition report CR-PNP-2015-07207. See Section 4OA2.c.(2) for more detail.
(b) Inspection Period Observations
The NRC has previously documented specific examples of ineffective prioritization or
evaluation of issues over the period of review for this inspection. This includes:
- In NRC Inspection Report 2013005, the inspectors identified a Green non-cited
violation of 10 CFR 50.54(t)(1), Conditions of Licenses, because Entergy did
not provide an adequate justification for exceeding the 12-month interval to
perform a review of its emergency preparedness program elements. Entergy did
not thoroughly evaluate a similar issue identified in 2009 and did not implement
corrective actions to address the issue. (NCV 2013005-01)
- In NRC Inspection Report 2014002, inspectors identified a Green non-cited
violation of 10 CFR 50, Appendix B, Criterion III, Design Control, because
Entergy did not correctly translate their design basis related to the shutdown
transformer into station procedures. This resulted from Entergy not thoroughly
evaluating and understanding the results of a calculation that was performed to
support the operability of the shutdown transformer. (NCV 2014002-02)
- In NRC Inspection Report 2014008, inspectors identified a Green finding
because Entergy did not fully derive the causes of the manual scram on August
22, 2013, following a loss of all feedwater. Entergy focused on the causes
related to the modification of the feed pump trips and did not investigate the
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causes of a failed cable splice which directly caused an electrical transient that
resulted in the automatic tripping of all three reactor feed pumps. (FIN 2014008-
01)
- In NRC Inspection Report 2014005, inspectors identified a severity level IV non-
cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, when
Entergy did not perform an adequate 50.59 evaluation and obtain a license
amendment prior to implementing a change to the plant that required a change to
technical specifications. (NCV 2014005-01)
- In NRC Inspection Report 2015007, the inspectors identified a White violation of
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because Entergy did
not identify, evaluate, and correct the A safety relief valves failure to open upon
manual actuation. Entergy staff did not thoroughly evaluate the operation of the
A safety relief valve during the February 9, 2015, plant cooldown, and should
have reasonably identified that the valve did not open upon three manual
actuation demands. (VIO 2015007-02)
- In NRC Inspection Report 2015007, the inspectors identified a Green non-cited
violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, when Entergy staff performed an inadequate past operability
evaluation that assessed performance of the C safety relief valve. Specifically,
following the January 27, 2015, reactor scram, operators placed an open
demand on the C safety relief valve twice during post-scram recovery
operations, but the valve did not respond as expected and did not perform its
pressure reduction function on both occasions. Entergys subsequent past
operability evaluation for the valves operation incorrectly concluded that the
valve was fully capable of performing its required functions during its installed
service. (NCV 2015007-01)
- In NRC Inspection Report 2015002, inspectors documented a self-revealing
Green finding when residual heat removal pump B experienced cavitation during
refueling outage 20 that was a result of inadequate corrective actions associated
with equipment used to determine flow rate. Entergy did not thoroughly evaluate
and develop appropriate corrective actions for issues associated with the
ultrasonic flow meter in 2011 and 2013 to ensure that the causes were
addressed to prevent challenges using this equipment during alternate fuel pool
cooling. (FIN 2015002-01)
- In NRC Inspection Report 2015002, inspectors identified a Green non-cited
violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, when Entergy staff performed an inadequate operability determination
that assessed the X-107B emergency diesel generator following cylinder head
leakage indications during pre-start checks for a planned monthly operability run.
Operators did not consider that potential sources of leakage, such as a crack in
the cylinder or cylinder head, could reasonably worsen during operation, such
that the engine would not be able to complete its 30-day mission time, and
therefore should be declared inoperable. (NCV 2015002-02)
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(3) Effectiveness of Corrective Actions
The inspectors determined that Entergys implementation of the corrective action
program related to resolution of issues was marginally effective. The inspectors
identified two cited violations in this area. Specifically, the inspectors noted that Entergy
did not implement timely corrective actions associated with a violation documented in
2013 related to the stations meteorological towers (Section 4OA2.1.c.(2)). The second
violation is discussed in Enclosure 4. The inspectors also noted weaknesses in closure
of condition reports and corrective actions, as discussed below. Additionally, over the
two-year period of inspection, the inspectors noted several examples in multiple Reactor
Oversight Process cornerstones where Entergy did not implement corrective actions to
resolve adverse conditions in a timely manner, commensurate with the safety
significance of the issues. Two of these examples are documented in Enclosure 4. Also
of note, Pilgrims self-assessment of the corrective action program performed in
preparation for this inspection determined that the effectiveness of the corrective action
program in resolving issues in a timely manner was unsatisfactory.
(a) Inspection Observations
Weaknesses in Corrective Action Closure
The inspectors noted some examples where closure of a condition report or
corrective action did not meet the standards described in Entergy procedure EN-LI-
102, Corrective Action Program.
- Inspectors reviewed condition report CR-PNP-2014-02007, which Entergy wrote
to address a previous NRC non-cited violation related to an inadequate risk
assessment. The inspectors noted that one of the actions, related to conduct of
a performance analysis, referenced other corrective actions that were never
generated in the condition report. Additionally, the condition report did not
contain sufficient documentation to support closure of this action. EN-LI-102,
Section 5.6[4] states that with respect to corrective action response,
documentation should be attached to provide objective evidence that the action
was completed. Though not attached to or documented in the condition report,
Entergy performed a training evaluation action request that resulted in
completion of a performance analysis and risk assessment training for
operations. Entergy documented this issue in condition report CR-PNP-2015-
07224.
- Inspectors reviewed corrective actions generated from the problem identification
and resolution focused area self-assessment that Entergy performed in
preparation for this inspection. Corrective action 13 to the self-assessment (LO-
PNPLO-2015-00121), documented a negative observation associated with
classification of condition reports as adverse versus non-adverse. The corrective
action also stated that this negative observation included a need for a better
understanding of corrective action program requirements related to NRC
commitments and design and licensing basis commitments. EN-LI-102, Section
5.6[4] states that the corrective action response must address the intent of the
action. Inspectors noted that the response to the corrective action only
addressed the concern related to understanding of commitments, and did not
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address the issues related to classification of condition reports as adverse versus
non-adverse. Entergy documented this issue in condition report CR-PNP-2015-
07193.
- Inspectors reviewed condition report CR-PNP-2013-06829, corrective action
nine, that was written to ensure trees and other vegetation around the 220
meteorological tower were maintained so that instrumentation on the tower was
not adversely affected. Through a series of due date extensions and
inappropriate closure of this corrective action to other corrective actions, Entergy
extended the due date of this action almost a year without following the required
process defined in EN-LI-102, Section 5.6[3]. Inspectors also noted a second
example similar to this issue where the station closed a condition report to
subsequent condition reports without completing the specified action. This
example is discussed as part of the cited violation in Enclosure 4.
The inspectors evaluated each of these examples independently in accordance with
IMC 0612, Appendix B, Issue Screening, and determined that these issues were
minor. With the exception of the example documented in Enclosure 4, the respective
corrective actions are either completed or in progress and being tracked by another
condition report.
Corrective Action Implementation Weaknesses in Common Cause Evaluation CR-
Entergy performed a common cause evaluation under condition report CR-PNP-
2015-00375 to address the deficiencies that led to failure of the NRC 95002
supplemental inspection and subsequent issuance of two parallel White findings in
November 2014. In May 2015, the NRC conducted a 95002 supplemental follow-up
inspection which, in part, reviewed this cause evaluation and the status of the
associated corrective actions.
During this biennial problem identification and resolution inspection, the inspectors
reviewed the status of the corrective actions that were not complete at the time of the
NRC 95002 supplemental follow-up inspection. The inspectors noted that Entergy
continues to implement the corrective action plan developed as part of CR-PNP-
2015-00375. However, the inspectors did note some weaknesses related to certain
time-based corrective actions. Entergy procedure EN-LI-102, Corrective Action
Program, Section 5.6[4] states that a corrective action response must not indicate
correction or implementation based on future action (a promise). The inspectors
identified multiple examples of actions in the corrective action plan that were written
such that the action needed to continue under a certain frequency for a certain
period of time, but could be closed after completing a fewer number of cycles, with a
promise to continue the action through the specified time period. For example, one
action stated, Director Regulatory and Performance Improvement to validate
performance shortfallsare captured during quarterly accountability meetings
through June 2015. This action can be signed off once the review has been
completed for three quarters, with the understanding that it will continue for one
year. The inspectors also noted an example where the plan was worded such that
the station would have to establish and maintain an action, and the station closed
the action even though the maintain portion was not complete. In both cases, once
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the initial corrective action was closed, there was no follow-up assignment created to
ensure that the action would continue for the specified time period. The inspectors
evaluated this issue in accordance with IMC 0612, Appendix B, Issue Screening,
and determined that this issue was minor. Though there was no documented
corrective action tracking completion through the specified time period, Entergy had
not missed completion of any of the actions at the time of this inspection. Entergy
entered this issue into their corrective action program as condition report CR-PNP-
2015-06937.
(b) Inspection Period Observations
The NRC has previously documented specific examples of ineffective or untimely
implementation of corrective actions over the period of review for this inspection.
This includes:
- In NRC Inspection Report 2013004, inspectors identified a Green non-cited
violation of 10 CFR 50, Criterion XVI, Corrective Action, because Entergy did
not complete a design control review for the station blackout fuel oil transfer
system in a timely manner. Specifically, the lack of design control measures
when this system was first proposed in 1999 was initially identified in August
2012 and was not corrected as of September 2013. (NCV 2013004-01)
- In NRC Inspection Report 2014008, inspectors identified a Green finding
because Entergy did not implement corrective actions in accordance with
program requirements which resulted in not identifying and correcting several
conditions adverse to quality. This includes examples where Entergy
inappropriately cancelled or closed corrective actions, implemented actions that
did not meet the intent of the original corrective action written to address the
adverse condition, and did not complete effectiveness reviews in accordance
with program requirements. (FIN 2014008-02)
- In NRC Inspection Report 2015002, inspectors identified a Green non-cited
violation of 10 CFR 20.1406(c) in that Entergy did not conduct operations to
minimize the introduction of residual radioactivity on site. Effective corrective
actions were not taken to address issues in a timely manner commensurate with
their safety significance. (NCV 2015002-03)
- In NRC Inspection Report 2015002, the inspectors documented the results of the
semi-annual trend review conducted in accordance with Inspection Procedure
71152, Problem Identification and Resolution. The review noted that Entergy
determined that the largest weaknesses in executing the corrective action
program were associated with performing the evaluation and resolution of a
condition report, along with the closure process. The inspectors also noted
challenges with the corrective action programs ability to address deficiencies in
the Beta annunciator system that date back to July 2013.
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c. Findings
(1) Inadequate Procedures for Placing the Main Turbine in Service
Introduction. The inspectors identified a self-revealing Green non-cited violation of
Technical Specification 5.4.1, Procedures, because Entergy did not provide adequate
procedures in that appropriate operator actions to recover systems and components
important to safety were not included within operating procedures 2.1.1, Startup from
Shutdown, and 2.2.93, Main Condenser Vacuum System, as well as abnormal
operating procedure 2.4.36, Decreasing Condenser Vacuum.
Description. On May 21, 2015, Pilgrim was starting up following the completion of a
refueling outage. During this startup, there were several parameters or system lineups
that were out of normal, but permissible by plant operating procedures. First, the
observed condenser air in-leakage was higher than normal. Entergy first observed an
increase of air in-leakage by approximately 40 - 50 standard cubic feet per minute
(scfm), to a new baseline level of approximately 70 scfm on February 8, 2015, during the
startup following a forced outage. Entergy observed a corresponding rise in offgas
system flowrate, to a value of 200 scfm. At the time of the shutdown for the refueling
outage, the source of this air in-leakage had not been located, and therefore, had not
been corrected. Subsequently, during the post refueling outage startup on May 22,
2015, Entergy observed offgas system flowrate at a level greater than 200 scfm, which is
off of the indicated scale.
Secondly, due to indications of seawater leakage during the startup, only two of the four
condenser waterboxes were in service. On May 21, 2015, hotwell conductivity
exceeded the action level for increased sampling. When Entergy initially placed the
main turbine in service, the condensate pump suction conductivity levels degraded, and
operators isolated the affected waterbox and secured the B sea water pump for
inspection and repair of any leaks. Upon securing the sea water pump, there was a
degradation and subsequent stabilization of condenser hotwell temperature, offgas
system flowrate, offgas system temperatures, and condenser vacuum. Operators
recognized the degraded conditions and set benchmarks for additional action, but
concluded that there was no immediate operational threat.
Additional factors included the lineup of the augmented offgas system and delays in
placing the main turbine online. Operators experienced challenges placing the
augmented offgas system in service due to high moisture levels in the system. Although
the augmented offgas system is not required to be in service during a startup, it does
provide certain benefits. With the augmented offgas system in service, operators have
the benefit of direct measurements of condenser air-in-leakage, as well as increased air
removal capability of the offgas system. The delays in placing the main turbine in
service were due to abnormal noise at the generator that was noted on the initial turbine
roll at 20:32 on May 21, 2015. The startup was suspended with reactor power
maintained at approximately 18 - 20 percent, while the generator noise was investigated
and corrected. This caused a delay of approximately nine hours until the main turbine
was placed in service at 05:27 on May 22, 2015, during which time the condenser was in
a two waterbox lineup, the offgas system was operating at reduced capacity and with
high air in-leakage, and steam was entering the condenser directly via the turbine
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bypass valves, resulting in a buildup of non-condensable gasses in the upper portions of
the condenser air space.
Ultimately, when steam was admitted to the condenser via the main turbines, this large
volume of gas was displaced and exhausted to the offgas system, which exceeded that
systems capabilities. Upon observing the degrading vacuum, operators entered
procedure 2.4.36, Degrading Condenser Vacuum, and at 07:26, due to continued
lowering condenser vacuum, operators tripped the main turbine. Vacuum continued to
degrade, and operators reduced power. At 08:21, Entergy determined that a shutdown
was required and continued lowering power. Operators realigned the seawater system
for three waterbox operation, however this action further overloaded the offgas system,
and at 10:02, upon reaching the assigned benchmark of 12 in-Hg condenser vacuum,
operators inserted a manual scram and proceeded to place the reactor in a hot
shutdown condition. After the scram, and due to the reduced steam input to the main
condenser, vacuum stabilized and the main condenser remained available for removal of
decay heat.
Entergy performed an evaluation and determined that plant staff did not adequately
understand the design limitations of the offgas system, which resulted in allowing a
combination of plant conditions to exist that overloaded the system, and resulted in
degradation of condenser vacuum, requiring a manual reactor scram. Entergy has
entered this issue into the corrective action program as condition report CR-PNP-2015-
5197. Corrective actions include, in part, for Entergy engineers to establish operational
limits for the offgas system, to include the factors of reactor power, air in-leakage, sea
water system alignment, status of the augmented offgas system, status of the main
turbine, and sea water inlet temperature, and to incorporate these limitations into site
procedures.
Analysis. The inspectors determined that not adequately maintaining Procedures 2.1.1,
Startup from Shutdown, 2.2.93, Main Condenser Vacuum System, and 2.4.36,
Decreasing Condenser Vacuum, as required by Technical Specification 5.4.1.a, was a
performance deficiency that was reasonably within Entergys ability to foresee and
correct, and should have been prevented. Specifically, Entergy did not provide sufficient
detail in these procedures resulting in operators not having appropriate guidance to
identify and mitigate the key events of May 22, 2015. The finding was more than minor
because it was associated with the procedure quality attribute of the Initiating Events
cornerstone and adversely affected the cornerstone objective to limit the likelihood of
events that upset plant stability and challenge critical safety functions during shutdown
as well as power operations. Additionally, this performance deficiency is similar to
example 4.b in IMC 0612, Appendix E, Examples of Minor Issues, in that it contributed
to a reactor trip. The inspectors evaluated the finding using IMC 0609, Appendix A,
Exhibit 1, Initiating Events Screening Questions, issued June 19, 2012. The inspectors
determined this finding was of very low safety significance (Green) because it did not
cause a loss of mitigation equipment relied upon to transition the plant from the onset of
the trip to a stable shutdown condition.
This finding had a cross-cutting aspect in the area of Human Performance, Design
Margins, because Entergy did not operate equipment within design margins.
Specifically, Entergy staffs lack of awareness of the limitations of offgas system during
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startup and while placing the main turbine in service resulted in operators establishing
conditions that were outside those limitations. [H.6]
Enforcement. Technical Specification 5.4.1.a requires, in part, that written procedures
shall be maintained covering the listed in Appendix A of Regulatory Guide 1.33, Revision
2, dated February 1978, which includes general plant operating procedures for hot
standby to minimum load (nuclear startup); turbine startup and synchronization of the
generator; startup and changing modes of operation of the turbine generator system;
and procedures for combating a loss of condenser vacuum. Contrary to the above, prior
to May 22, 2015, Entergy did not adequately maintain these written procedures required
by Appendix A of Regulatory Guide 1.33, Revision 2. Specifically, Entergy did not
ensure that adequate operational limits were known and understood for the offgas
system while placing the main turbine in service during a reactor startup, and did not
ensure that such operational limits were incorporated into plant operating procedures
2.1.1, Startup from Shutdown, 2.2.93, Main Condenser Vacuum System, and 2.4.36,
Decreasing Condenser Vacuum. Because this issue was of very low safety
significance (Green) and has been entered into Entergys corrective action program as
CR-PNP-2015-5197, this violation is being treated as a non-cited violation, consistent
with Section 2.3.2.a of the NRC's Enforcement Policy. (NCV 05000293/2015010-01,
Inadequate Procedures for Placing Main Turbine in Service)
(2) Untimely Actions to Restore Station Meteorological Towers
Introduction. The inspectors identified a Green cited violation of 10 CFR Part
50.54(q)(2) because Entergy did not ensure that the Pilgrim Emergency Plan met the
planning standards in 10 CFR 50.47(b). Specifically, on various occasions in 2012
through 2015, Pilgrim did not maintain both meteorological towers as necessary to
support emergency response.
Description. Per 10 CFR 50.54(q)(2), licensees are required to follow and maintain the
effectiveness of an emergency plan that meets the planning standards of 10 CFR
50.47(b). One of these standards, 10 CFR 50.47(b)(8), requires licensees to provide
and maintain adequate equipment to support emergency response. Pilgrim has two
meteorological towers onsite, both of which are credited in the Pilgrims Emergency
Plan. The meteorological towers are used to provide data on the wind speed, wind
direction, air temperature, and delta air temperature to perform offsite dose assessments
during a radiological emergency condition. The 220 meteorological tower provides data
remotely, and is the primary source used to gather this data. The 160 meteorological
tower is the back-up local data source. The local National Weather Service station is
available as an alternate source of data in the event that the meteorological towers are
unavailable. However, unlike the meteorological towers, the data provided by the
National Weather Service is not specific to Pilgrim, but is derived based on
measurements from instruments located in neighboring communities.
In December 2011, Entergy stopped performing preventative maintenance on the 160
meteorological tower. Subsequent to the 160 meteorological tower becoming non-
functional, the 220 meteorological tower was out of service from March 18, 2012,
through July 19, 2012, due to a broken aspirator fan; February 8, 2013, through March
13, 2013, due to effects from winter storm Nemo, and April 26, 2013, through April 30,
2013, due to power being secured for an outage. During these periods, the 160 and
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220 meteorological towers were no longer capable of providing a continuous reading of
the parameters mentioned above, and therefore did not have the capability to provide
accurate data necessary to perform assessment of offsite dose consequences during a
radiological emergency condition, as required by Pilgrims Emergency Plan. As a result,
Entergy was relying on the information from the National Weather Service as an
alternate data source.
In November 2013, the inspectors had identified that Entergy did not maintain in effect a
provision of its emergency plan. Specifically, emergency equipment needed to support
emergency response was not provided when the station cancelled preventative
maintenance for the 160 meteorological tower and the 220 meteorological tower was
non-functional for extended periods of time. The NRC dispositioned this performance
deficiency as a non-cited violation in NRC Inspection Report 2013008. Entergy entered
the condition into the corrective action program under condition report CR-PNP-2013-
6829. However, the inspectors determined that Entergys actions to address the
adverse condition have not been addressed in a timely manner. In March 2014, Entergy
developed initial corrective actions to reinstitute preventive maintenance on the 160
meteorological tower and restore the tower to operation; however, these corrective
actions were not implemented. In July 2014, Entergy decided to cease plans to restore
the 160 meteorological tower and instead to design and construct a new tower. At the
time of this inspection in August 2015, Entergy was in the process of obtaining
necessary permits for construction of the new tower.
Due to the delays in both the initiation and the implementation of corrective actions, the
condition that was identified by the inspectors in 2013 continues to exist. Moreover,
during that time period there have been numerous additional instances where the 220
meteorological tower was non-functional: from January 14, 2015, through January 19,
2015, due to a malfunctioning wind sensor; January 27, 2015, due to effects from winter
storm Juno; February 21, 2015, through April 12, 2015, due to a failed differential
temperature instrument; May 4, 2015, and May 5, 2015, due to power being secured
during an outage; and August 11, 2015, through August 15, 2015, due to malfunctioning
wind sensors and the effects of nearby construction activities. During these periods,
both the 160 and 220 meteorological towers were no longer capable of providing a
continuous reading of the parameters mentioned above, and therefore did not have the
capability to provide accurate data necessary to perform assessment of offsite dose
consequences during a radiological emergency condition, as required by Pilgrims
Emergency Plan. And again, as a result, Entergy was relying on the information from
the National Weather Service as an alternate data source.
Analysis. The inspectors determined that not maintaining the 160 and 220
meteorological towers in accordance with 10 CFR 50.47(b)(8), resulting in both towers
being out of service concurrently for eight separate periods between 2012 and 2015,
was a performance deficiency that was within Entergys ability to foresee and correct,
and should have been prevented. This performance deficiency is more than minor
because it is associated with the facilities and equipment attribute of the Emergency
Preparedness cornerstone and adversely affected the cornerstone objective of ensuring
the licensee is capable of implementing adequate measures to protect the health and
safety of the public in the event of a radiological emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process,
Table 5.8-1, issued September 26, 2014, the inspectors determined the finding to be of
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18
very low safety significance (Green) because the planning standard function was
degraded. Specifically, a significant amount of equipment necessary to implement the
emergency plan was not functional to the extent that an emergency response
organization member could not perform assigned functions, in the absence of
compensatory measures. However, Pilgrim was able to make adequate dose
assessments at all times using the National Weather Service to obtain necessary data.
This finding has a cross-cutting aspect in the area of Problem Identification and
Resolution, Resolution, because Pilgrim did not take effective corrective actions to
address issues in a timely manner commensurate with their safety significance.
Specifically, numerous delays and extensions of corrective actions resulted in a period of
approximately two years in which the adverse condition identified by the inspectors has
not been corrected, during which additional outages of the primary meteorological tower
have resulted in additional unnecessary degradation of the Pilgrim Emergency Plan.
[P.3]
Enforcement. 10 CFR 50.54(q)(2) requires, in part, that a holder of a nuclear power
reactor operating license shall follow and maintain the effectiveness of an emergency
plan that meets the requirements in Appendix E to this part, and the planning standards
of 10 CFR 50.47(b). 10 CFR 50.47(b)(8) requires, in part, that adequate equipment to
support the emergency response are provided and maintained. The Pilgrim Emergency
Plan states, in part, that Pilgrim has two meteorological towers, a 220 primary and a
160 back-up, equipped with instrumentation for continuous reading of the wind speed,
wind direction, air temperature, and delta air temperature. Contrary to the above, since
December 2011, Entergy did not follow and maintain the effectiveness of the Pilgrim
Emergency Plan to meet the requirement that adequate equipment to support the
emergency response was provided and maintained. Specifically, in December 2011,
Entergy cancelled preventative maintenance of the 160 back-up meteorological tower,
and that tower became non-functional. As a result, on eight occasions between March
18, 2012, and August 15, 2015, when the 220 primary meteorological tower was also
non-functional for various reasons, Pilgrim did not have instrumentation available on
either tower for continuous reading of the wind speed, wind direction, air temperature,
and delta air temperature. The NRC documented a Green non-cited violation related to
this issue on November 20, 2013, in NRC Inspection Report 2013008. Because Entergy
did not restore compliance at the first opportunity within a reasonable period of time
following the issuance of the non-cited violation, this violation is being cited, consistent
with NRC Enforcement Policy, Section 2.3.2. A Notice of Violation is attached
(Enclosure 1). (VIO 05000293/2015010-02, Untimely Actions to Restore Station
Meteorological Towers)
(3) Inadequate Guidance and Invalid Compensatory Measures for Out-of-Service
Emergency Action Level Instrumentation
Introduction. The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2)
because Entergy did not follow and maintain an emergency plan that meets the
requirements of planning standards 10 CFR 50.47(b) and Appendix E. Specifically, the
Emergency Plan Implementing Procedure specified insufficient equipment as the
primary method of emergency action level assessment, and directed invalid
compensatory measures to be used when the primary method of emergency action level
assessment for reactor coolant system leakage was unavailable.
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Description. The emergency action level declaration conditions for reactor coolant
system identified leakage is determined based on the volume of water pumped from the
drywell equipment sump. Similarly, the declaration conditions for reactor coolant system
unidentified or pressure boundary leakage are determined based on the volume of water
pumped from the drywell floor sump. The emergency action level threshold for an
Unusual Event (SU6.1) is 10 gallons per minute of unidentified or pressure boundary
leakage or 25 gallons per minute identified leakage. Entergy utilizes Emergency Plan
Implementing Procedures to provide guidance to operators and emergency response
organization members for following and maintaining the planning standard functions in
the approved Emergency Plan. Specifically, Entergy developed Emergency Plan
Implementing Procedure EP-IP-100.1, Emergency Action Levels, to provide guidance
to operators for classifying abnormal plant events as well as compensating actions for
out-of-service emergency action level equipment.
In the extent of condition review of an apparent cause evaluation for the inadequate
compensatory measures identified by the inspectors on January 27, 2015, for the
assessment of bay level, Entergy determined that the prescribed compensatory measure
for the assessment of reactor coolant system leakage was invalid. Specifically, EP-IP-
100.1, Attachment 9.2, Emergency Action Level Related Equipment, listed level
indicator LI-5008, the primary containment water level indicator, as the alternate source
of information. The purpose of LI-5008 is to provide indication of water level in the
primary containment in the event that an accident requires the deliberate flooding of the
containment. Entergy staff determined that this compensatory measure was inadequate
to provide timely assessment of reactor coolant system leak rates.
Although Entergy initially identified this invalid compensatory measure during the
apparent cause evaluation, the station did not write a condition report in accordance with
EN-LI-118, Cause Evaluation Process. Entergy staff chose to correct this issue as part
of a longer term procedure revision which called for the development of a larger and
more comprehensive procedure governing equipment important to emergency response,
which was a corrective action for the inadequate bay level compensatory measures.
Since Entergy did not enter the issue regarding the primary containment water level
invalid compensatory measure into the corrective action program, the measure remained
in place, and no interim guidance was provided to staff in order to assist in more
accurate and timely emergency action level assessment until the new procedure
governing equipment important to emergency response was issued.
Additionally, during review of procedure EP-IP-100.1, inspectors determined that the
specified emergency action level equipment for the assessment of reactor coolant
system leakage was incomplete and inaccurate. Specifically, the drywell floor sump
pumps are appropriately specified for the assessment of unidentified or pressure
boundary leakage, however they were given the incorrect designation of P-306A/B, while
the correct designation for this equipment is P-305A/B. Since the procedure listed the
correct name of the drywell floor sump pumps, equipment that is routinely used by
operators, the inspectors determined that the incorrect component number was a minor
editorial error that would not have reasonably interfered with emergency action level
assessment. However, in addition, the appropriate equipment for the assessment of
identified leakage, drywell equipment sump pumps P-301A/B, was absent from the
listing of emergency action level related equipment. Consequently, plant operators were
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provided with incomplete guidance in EP-IP-100.1 to aid in the assessment of
emergency action level thresholds for reactor coolant system leakage. Moreover, in the
event of equipment malfunction or normal maintenance that renders the drywell
equipment sump pumps P-301A/B unavailable, Entergy staff did not have clear guidance
to inform a determination of a major loss of assessment capability.
The inspectors performed a review of the revision history of EP-IP-100.1, and
determined that the invalid compensatory measure has been in place since January
2008, when the procedure was revised to incorporate Attachment 9.2 for the purpose of
listing necessary equipment for emergency action level declaration and to provide
associated compensatory measures when the equipment is out of service. The
inspectors also determined that the incomplete listing of equipment in the same
attachment for the assessment of reactor coolant system leakage had been in place
since September 2013, when the attachment was revised to replace the generic listing of
monitored parameters with more specific references to equipment used in assessment
of emergency action level entry conditions. The inspectors reviewed the information
being used to develop the proposed equipment important to emergency response
procedure, and verified that Entergy identified the incomplete information in the
development of the proposed procedure. However, as in the case of the invalid
compensatory measure, this newly identified deficiency with the current procedure was
not entered into the corrective action program, and therefore, the inadequate guidance
for emergency action level assessment was allowed to remain in place with no interim
guidance provided to Entergy staff. Entergy has entered these issues into the corrective
action program as condition reports CR-PNP-2015-7183 and CR-PNP-2015-7394.
Additionally, since the time of this inspection, Entergy has completed and issued the new
procedure governing equipment important to emergency response.
Analysis. The inspectors determined that not maintaining complete procedural guidance
or valid compensatory measures for out-of-service emergency action level equipment in
accordance with 10 CFR 50.47(b) was a performance deficiency that was within
Entergys ability to foresee and correct and should have been prevented. Specifically,
Entergy did not ensure that equipment and the compensatory measure listed in
Attachment 9.2 of EP-IP-100.1, Emergency Action Levels, Revision 11, was adequate
to support timely assessment of emergency action level entries. This NRC-identified
performance deficiency was more than minor because it was associated with the
emergency response organization performance (program elements not meeting 50.47(b)
planning standards) attribute of the Emergency Preparedness cornerstone and affected
the cornerstone objective of ensuring that the licensee is capable of implementing
adequate measures to protect the health and safety of the public in the event of a
radiological emergency. Specifically, the incomplete procedural guidance and the
inadequate compensatory measure could have led to an emergency not being declared
in a timely manner. The inspectors evaluated the finding using IMC 0609, Attachment 4,
Initial Characterization of Findings, issued June 19, 2012, and IMC 0609, Appendix B,
Emergency Preparedness Significance Determination Process, issued September 26,
2014. The inspectors determined the finding was associated with risk significant
planning standard 10 CFR 50.47(b)(4), Emergency Classification System, and
corresponded to the following Green Finding example in Table 5.4-1: an EAL has been
rendered ineffective such that any Alert or Unusual Event would not be declared, or
declared in a degraded manner for a particular off-normal event. Therefore, using
Figure 5.4-1, Significance Determination for Ineffective EALs and Overclassification,
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21
and the example in Table 5.4-1, the inspectors determined the finding was of very low
safety significance (Green).
The finding had a cross-cutting aspect in the area of Problem Identification and
Resolution, Identification, because Entergy did not ensure that the issues were promptly
reported and documented in the corrective action program at a low threshold.
Specifically, while performing the extent of condition review of EP-IP-100.1, Entergy did
not effectively utilize the corrective action program to identify and correct newly identified
deficiencies with the guidance for emergency action level assessment and the invalid
compensatory measures. This resulted in the associated degradation of the emergency
plan assessment capability remaining in effect. [P.1]
Enforcement. 10 CFR 50.54(q)(2) requires, in part, that a licensee shall follow and
maintain an emergency plan that meets the planning standards of 10 CFR 50.47(b) and
Appendix E. 10 CFR 50.47(b) requires, in part, that emergency response plans must
include a standard emergency classification and action level scheme, the bases of which
include facility system and effluent parameters. Contrary to the above, from January
2008 through August 2015, Entergy did not maintain an emergency plan that met the
planning standards of 10 CFR 50.47(b) and Appendix E that require emergency
response plans to include a standard emergency classification and action level scheme
based on accurate facility and system and effluent parameters. Specifically, Emergency
Plan Implementing Procedure EP-IP-100.1 directed a compensatory measure of
alternative indication with the use of LI-5008, Primary Containment Water Level
Indicator, which was an invalid compensatory measure and would have resulted in
untimely assessment of emergency action level thresholds. Additionally, from
September 2013 through August 2015, the equipment listed in EP-IP-100.1 as the
primary method of assessment of reactor coolant system leakage was inadequate, as it
did not specify all equipment needed to monitor the associated emergency action level
for the entire range of possible entry conditions. Because this violation is of very low
safety significance and has been entered into Entergys corrective action program, this
finding is being treated as a non-cited violation, consistent with Section 2.3.2.a of the
NRC Enforcement Policy. (NCV 05000293/2015010-03, Inadequate Guidance and
Invalid Compensatory Measures for Out-of-Service EAL Instrumentation)
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of condition reports associated with review of industry
operating experience to determine whether Entergy appropriately evaluated the
operating experience information for applicability to Pilgrim and had taken appropriate
actions, when warranted. The inspectors also reviewed evaluations of operating
experience documents associated with a sample of NRC generic communications to
ensure that Entergy adequately considered the underlying problems associated with the
issues for resolution via their corrective action program. In addition, the inspectors
observed various plant activities to determine if the station considered industry operating
experience during the performance of routine and infrequently performed activities.
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22
b. Assessment
The inspectors determined that Entergy appropriately considered industry operating
experience information for applicability, and used the information for corrective and
preventive actions to identify and prevent similar issues when appropriate. The
inspectors determined that operating experience was appropriately applied and lessons
learned were communicated and incorporated into plant operations and procedures
when applicable. The inspectors also observed that industry operating experience was
routinely discussed and considered during the conduct of pre-job briefs and various
other meetings at the site.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the
corrective action program, departmental self-assessments, and assessments performed
by independent organizations. Inspectors performed these reviews to determine if
Entergy entered problems identified through these assessments into the corrective
action program, when appropriate, and whether Entergy initiated corrective actions to
address identified deficiencies. The inspectors evaluated the effectiveness of the audits
and assessments by comparing audit and assessment results against self-revealing and
NRC-identified observations made during the inspection.
b. Assessment
The inspectors concluded that self-assessments, audits, and other internal Entergy
assessments were generally effective in identifying issues. The inspectors observed
that Entergy personnel knowledgeable in the subject completed these audits and self-
assessments in a methodical manner. Entergy completed these audits and self-
assessments to a sufficient depth to identify issues which were then entered into the
corrective action program for evaluation. In general, the station implemented corrective
actions associated with the identified issues commensurate with their safety significance.
c. Findings
No findings were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with station personnel, the inspectors assessed the safety conscious
work environment at Pilgrim. Specifically, the inspectors interviewed personnel to
determine whether they were hesitant to raise safety concerns to their management
and/or the NRC. The inspectors also reviewed a sample of anonymous condition
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23
reports, and the results of the last safety culture survey, conducted in 2012. The
inspectors interviewed the station Employee Concerns Program coordinator to
determine what actions are implemented to ensure employees were aware of the
program and its availability with regards to raising safety concerns, and reviewed a
sample of Employee Concerns Program files to ensure that Entergy entered issues into
the corrective action program when appropriate.
b. Assessment
During interviews, Pilgrim staff stated that they were willing to raise safety issues. The
inspectors noted that none of the staff interviewed stated that they personally
experienced or were aware of a situation in which an individual had been retaliated
against for raising a safety issue. All persons interviewed demonstrated an adequate
knowledge of the corrective action program and the Employee Concerns Program.
Additionally, the station was in the process of conducting a site-wide safety culture
survey during this inspection. Based on these limited interviews, and review of the
various documentation discussed above, the inspectors concluded that there was no
evidence of an unacceptable safety conscious work environment and no significant
challenges to the free flow of information.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On August 20, 2015, the inspectors presented the 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
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A-1
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Dent, Site Vice President
P. Beabout, Security Manager
G. Blankenbiller, Chemistry Manager
R. Brooks, Radiation Protection Technician
D. Calabrese, Emergency Preparedness Manager
M. Cardinal, Electrician
B. Chenard, Engineering Director
S. Cook, Chemistry Technician
J. Cox, Radiation Protection Supervisor
R. Daly, Security Superintendent
K. Drown, Performance and Improvement Manager
M. Gastlick, Senior Supervisor, Security
M. Jacobs, Manager of Nuclear Oversight
G. Kelly, Electrical Maintenance Supervisor
C. Lewis, Instrument and Control Technician
K. Lowther, Employee Concerns Program Coordinator
J. MacDonald, Senior Operations Manager
D. Noyes, Director of Regulatory and Performance Improvement
J. Ohrenberger, Senior Maintenance Manager
E. Perkins, Regulatory Assurance Manager
R. Pierson, Senior Supervisor, Security
J. Sabina, Inservice Testing Program Engineer
J. Shumate, PS&O Manager
D. Smith, Mechanical Maintenance Supervisor
L. Timus, Mechanic
T. Wheble, Instrument and Control Maintenance Supervisor
M. Williams, Nuclear Safety Licensing Specialist
A. Zielie, Radiation Protection Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
05000293/2015010-01 NCV Inadequate Procedures for Placing Main Turbine
in Service (Section 4OA2.c(1))05000293/2015010-03 NCV Inadequate Guidance and Invalid Compensatory
Measures for Out-of-Service EAL
Instrumentation (Section 4OA2.c(3))
Attachment
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A-2
Opened
05000293/2015010-02 VIO Untimely Actions to Restore Station
Meteorological Towers (Section 4OA2.c(2))05000293/2015010-04 VIO Security Finding (Enclosure 4)
LIST OF DOCUMENTS REVIEWED
Condition Reports (* indicates that condition report was generated as a result of this inspection)
CR-HQN-2015-00291 CR-PNP-2013-05246 CR-PNP-2014-01321
CR-PNP-2008-02038 CR-PNP-2013-05256 CR-PNP-2014-01775
CR-PNP-2009-04552 CR-PNP-2013-05385 CR-PNP-2014-01994
CR-PNP-2009-04696 CR-PNP-2013-06186 CR-PNP-2014-02007
CR-PNP-2010-01557 CR-PNP-2013-06386 CR-PNP-2014-02008
CR-PNP-2010-02420 CR-PNP-2013-06684 CR-PNP-2014-02043
CR-PNP-2010-02846 CR-PNP-2013-06697 CR-PNP-2014-02112
CR-PNP-2010-03555 CR-PNP-2013-06721 CR-PNP-2014-02319
CR-PNP-2010-04531 CR-PNP-2013-06736 CR-PNP-2014-02379
CR-PNP-2011-00242 CR-PNP-2013-06741 CR-PNP-2014-02514
CR-PNP-2011-01180 CR-PNP-2013-06818 CR-PNP-2014-02739
CR-PNP-2011-01538 CR-PNP-2013-06829 CR-PNP-2014-02743
CR-PNP-2011-02696 CR-PNP-2013-06830 CR-PNP-2014-02749
CR-PNP-2011-03068 CR-PNP-2013-06831 CR-PNP-2014-02967
CR-PNP-2011-03636 CR-PNP-2013-06906 CR-PNP-2014-03381
CR-PNP-2011-04301 CR-PNP-2013-06961 CR-PNP-2014-03763
CR-PNP-2011-04503 CR-PNP-2013-07023 CR-PNP-2014-03973
CR-PNP-2011-05591 CR-PNP-2013-07025 CR-PNP-2014-03999
CR-PNP-2012-00669 CR-PNP-2013-07231 CR-PNP-2014-04009
CR-PNP-2012-00907 CR-PNP-2013-07313 CR-PNP-2014-04546
CR-PNP-2012-01359 CR-PNP-2013-07336 CR-PNP-2014-04676
CR-PNP-2012-01520 CR-PNP-2013-07445 CR-PNP-2014-04733
CR-PNP-2012-02304 CR-PNP-2013-07540 CR-PNP-2014-04951
CR-PNP-2012-02644 CR-PNP-2013-07547 CR-PNP-2014-05017
CR-PNP-2012-04248 CR-PNP-2013-07679 CR-PNP-2014-05065
CR-PNP-2012-04291 CR-PNP-2013-07824 CR-PNP-2014-05125
CR-PNP-2012-04621 CR-PNP-2013-07888 CR-PNP-2014-05561
CR-PNP-2012-04816 CR-PNP-2013-07907 CR-PNP-2014-05746
CR-PNP-2012-05202 CR-PNP-2013-07984 CR-PNP-2014-05825
CR-PNP-2012-05244 CR-PNP-2013-08042 CR-PNP-2014-05877
CR-PNP-2013-00213 CR-PNP-2014-00136 CR-PNP-2014-06294
CR-PNP-2013-00428 CR-PNP-2014-00149 CR-PNP-2014-06746
CR-PNP-2013-00610 CR-PNP-2014-00249 CR-PNP-2015-00062
CR-PNP-2013-00853 CR-PNP-2014-00251 CR-PNP-2015-00243
CR-PNP-2013-01158 CR-PNP-2014-00270 CR-PNP-2015-00277
CR-PNP-2013-01538 CR-PNP-2014-00815 CR-PNP-2015-00324
CR-PNP-2013-01570 CR-PNP-2014-00985 CR-PNP-2015-00499
CR-PNP-2013-01784 CR-PNP-2014-01207 CR-PNP-2015-00558
CR-PNP-2013-01819 CR-PNP-2014-01229 CR-PNP-2015-00559
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
A-3
CR-PNP-2015-00730 CR-PNP-2015-04216 CR-PNP-2015-06837*
CR-PNP-2015-00806 CR-PNP-2015-04313 CR-PNP-2015-06851*
CR-PNP-2015-00888 CR-PNP-2015-04370 CR-PNP-2015-06883*
CR-PNP-2015-00948 CR-PNP-2015-04411 CR-PNP-2015-06926*
CR-PNP-2015-00949 CR-PNP-2015-04530 CR-PNP-2015-06937*
CR-PNP-2015-01164 CR-PNP-2015-04531 CR-PNP-2015-06939*
CR-PNP-2015-01233 CR-PNP-2015-04729 CR-PNP-2015-06945*
CR-PNP-2015-01308 CR-PNP-2015-04731 CR-PNP-2015-06946*
CR-PNP-2015-01402 CR-PNP-2015-04865 CR-PNP-2015-06947*
CR-PNP-2015-01535 CR-PNP-2015-04998 CR-PNP-2015-06948*
CR-PNP-2015-01614 CR-PNP-2015-05197 CR-PNP-2015-06963*
CR-PNP-2015-01623 CR-PNP-2015-05337 CR-PNP-2015-06968*
CR-PNP-2015-01679 CR-PNP-2015-05425 CR-PNP-2015-06969*
CR-PNP-2015-01752 CR-PNP-2015-05534 CR-PNP-2015-06991*
CR-PNP-2015-01764 CR-PNP-2015-05745 CR-PNP-2015-06997*
CR-PNP-2015-01808 CR-PNP-2015-05746 CR-PNP-2015-07183*
CR-PNP-2015-01908 CR-PNP-2015-05825 CR-PNP-2015-07190*
CR-PNP-2015-02343 CR-PNP-2015-05826 CR-PNP-2015-07193*
CR-PNP-2015-02555 CR-PNP-2015-05827 CR-PNP-2015-07207*
CR-PNP-2015-02559 CR-PNP-2015-05829 CR-PNP-2015-07222*
CR-PNP-2015-02716 CR-PNP-2015-05833 CR-PNP-2015-07224*
CR-PNP-2015-02800 CR-PNP-2015-05834 CR-PNP-2015-07228*
CR-PNP-2015-03366 CR-PNP-2015-05836 CR-PNP-2015-07239*
CR-PNP-2015-03906 CR-PNP-2015-05837 CR-PNP-2015-07247*
CR-PNP-2015-04025 CR-PNP-2015-05839 CR-PNP-2015-07394
CR-PNP-2015-04105 CR-PNP-2015-06314
CR-PNP-2015-04115 CR-PNP-2015-06338
Learning Organization Documents
LO-HQNLO-2007-00211 LO-PNPLO-2014-00069 LO-PNPLO-2014-00105
LO-PNPLO-2014-00014 LO-PNPLO-2014-00072 LO-PNPLO-2014-00139
LO-PNPLO-2014-00033 LO-PNPLO-2014-00093 LO-PNPLO-2015-00101
LO-PNPLO-2014-00058 LO-PNPLO-2014-00096 LO-PNPLO-2015-00121
NRC Violations and Findings05000293/2011007-03, Inadequate Evaluation of the Effect of Non-Class I Equipment Internal
Flooding on Redundant Safety Related Equipment
05000293/2013005-01, Failure to Provide Adequate Justification to Extend the 12-Month
Review Frequency of the Emergency Preparedness Program
05000293/2013008-02, Failure to Maintain Station Meteorological Towers05000293/2014003-01, Failure to Manage a Yellow Risk Condition for Unavailable Torus Vent
Valve
05000293/2014003-02, Failure to Comply with Technical Specification Required Actions for
Inoperable Primary Containment Isolation Valve
05000293/2015001-01, Failure to Perform Testing of Safety Related Undervoltage Alarm
Relays05000293/2015002-03, Failure to Conduct Operations to Minimize the Introduction of Residual
Radioactivity to the Site
05000293/2015002-04, Failure to Properly Ship Category 2 Radioactive Material - Quantity of
Concern
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
A-4
05000293/2015007-03, Inadequate Loss of Instrument Air Abnormal Procedure
05000293/2015007-06, Failure to Implement Compensatory Measures for Out-of-Service
Emergency Action Level Instrumentation
05000293/2015007-07, Failure to Report a Major Loss of Emergency Assessment Capability
05000293/2015007-08, Inadequate Testing of the Diesel-Driven Air Compressor
Operating Experience
NRC Information Notice 2014-08: Need for Continuous Monitoring of Active Systems in Loaded
Spent Fuel Storage Canisters (Including Vacuum Drying Process)
Pilgrim Nuclear Power Station operating experience evaluation for GE SIL 667, supplement 2,
and EPRI OE concerning ECP measurements from the mitigation monitoring system that
were not representative of reactor vessel and piping conditions
Pilgrim Nuclear Power Station response to 2009 operating experience regarding failure of
control rod drive system hydraulic control unit directional control valve cap screws that
resulted in the associated control rod drifting into the core
Pilgrim Nuclear Power Station response to NRC-IN-2014-03, Turbine Driven Auxiliary
Feedwater Pump Overspeed Trip Mechanism Issues
Pilgrim Nuclear Power Station response to NRC-IN-2014-04, Potential for Teflon Material
Degradation in Containment Penetrations, Mechanical Seals, and Other Components
Pilgrim Nuclear Power Station response to NRC-IN-2014-05, Verifying appropriate dosimetry
evaluation
Pilgrim Nuclear Power Station response to NRC-RIS-2014-004, National Source Tracking
System long term storage indicator
Fleet Security Operating Experience, January 2015 to August 2015
NEI 12-03, Att. A, Industry Security Operating Experience, January 2015 to August 2015
JAF 2014-08-01, Operating Experience, 8/26/14
Procedures
2.1.1, Startup from Shutdown, Revision 192
2.2.93, Main Condenser Vacuum System, Revision 74
2.2.99, Main Turbine Generator, Revision 52
2.4.36, Decreasing Condenser Vacuum, Revision 33
EN-EC-100, Guidelines for Implementation of the Employee Concerns Program, Revision 8
EN-EC-100-01, Employee Concern Coordinator Training Program, Revision 1
EN-EP-202, Equipment Important to Emergency Preparedness, Revision 1
EN-FAP-LI-001, Condition Review Group (CRG), Revision 5
EN-LI-102, Corrective Action Program, Revision 24
EN-LI-102, Corrective Action Program, Revision 24
EN-LI-102-02, Condition Report Closeout Review, Revision 9
EN-LI-104, Self-Assessment and Benchmark Process, Revision 11
EN-LI-118, Cause Evaluation Process, Revision 21
EN-LI-121, Trending and Performance Review Process, Revision 17
EN-LI-121-01, Trend Codes, Revision 6
EN-NS-221, Security Organization, Standards and Expectations, Revision 7
EN-OE-100, Operating Experience Program, Revision 23
EN-OE-100, Operating Experience Program, Revision 24
EN-OP-104, Operability Determination Process, Revision 9
EN-PL-190, Maintaining a Strong Safety Culture, Revision 3
EN-QV-100, Conduct of Nuclear Oversight, Revision 11
EN-QV-136, Nuclear Safety Culture Monitoring, Revision 5
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
A-5
EN-WM-100, Work Request (WR) Generation, Screening, and Classification, Revision 10
EP-AD-270, Equipment Important to Emergency Response (EITER), Revision 0
EP-AD-601, Emergency Action Level Technical Bases Document, Revision 5
EP-IP-100.1, Emergency Action Levels (EALs), Revisions 4, 9, and 11
IN1-247, Calibration and Loop Accuracy of LT-5008, Revision 0
SEP-PNPS-IST-001, PNPS Inservice Pump and Valve Testing Program, Revision 4
Self-Assessments and Audits
QA-03-2015-PNP-1 QA-12/18-2013-PNP-1 QS-2015-PNP-019
QA-07-2014-PNPS-1 QA-12/18-2015-PNP-1 QS-2015-PNPS-023
QA-07-2015-PNP-1 QA-14/15-2013-PNP-1 QA-16-2014-HQN-1
QA-10-2014-PNP-1 QA-2-6-2013-PNP-1 QA-16-2013-HQN-1
Miscellaneous
116-C28, Blockwall Re-evaluation Wall No. 65.17, Revision 1
2013-55, Focused Benchmark Plan and Report Template, 9/12/13
3Q14 Pilgrim APRM Report
4Q13 Pilgrim APRM Report
4Q14 Pilgrim APRM Report
Calculation No. PS88, Voltage Profile and Loading Study for New Security Power System,
8/28/90
Condition Review Group Pre-Screening Meeting Report, dated August 4, 2015
Condition Review Group Summary Agenda Report, dated August 3, 2015
LER 05000293/1999-009-00, Manual Scram at 27 Percent Power Due to Degrading Main
Condenser Vacuum
LER 05000293/2012-002-00, Manual Reactor Scram Due to Degraded Condenser Vacuum
LER 05000293/2014-001-00, Condition Prohibited By Technical Specifications
LER 05000293/2015-005-00, Degrading Condenser Vacuum Resulting in Manual Reactor Scram
Meteorological tower project schedule
Nuclear Safety Culture Monitoring Panel Meeting Minutes, April 15, 2015
Operational Focus Meeting Agenda, dated August 6, 2015
O-RQ-04-01-187
Pilgrim Condition Review Group Summary Agenda Report, dated August 6, 2015
Pilgrim Condition Review Group Summary Agenda Report, dated August 10, 2015
Pilgrim Condition Review Group Summary Agenda Report, dated August 11, 2015
Pilgrim Condition Review Group Summary Agenda Report, dated August 18, 2015
Pilgrim Corrective Action Excellence Plan, Revision August 2, 2015
Pilgrim Memo from J. Priest, Emergency Preparedness Manager, detailing National Weather
Service Capability, dated January 16, 2013
Pilgrim NIOS Site Status Report
Pilgrim Nuclear Safety Culture Chronology (First Quarter 2013 through Second Quarter 2015)
Pilgrim Nuclear Station 2012 Entergy Employee Engagement Survey
Pilgrim Safety Review Committee Meeting Minutes, dated March 19, 2015
Pilgrim Safety Review Committee Meeting Minutes, dated September 10, 2014
Pilgrim SRC 2013-002 Summary
Pilgrim Station Operations Subcommittee Meeting Summary, January 2014
PMRQ 27726-01: Inspect external water box inlet expansion joints
PMRQ 27727-01: Inspect external water box outlet expansion joints
PNPS-2014-188
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
A-6
Quality Assurance Program Manual, Revision 29
Salt Service Water System 29 Maintenance Rule (a)(1) Action Plan, Revision 3, dated June 24,
2014
SDBD-29, System Design Basis Document for the Salt Service Water System, Revision E1
System Health Report for Salt Service Water System, third quarter 2014 through second quarter
2015
Tailgate Package, dated August 4, 2015
Tailgate Package, dated July 28, 2015
LIST OF ACRONYMS
CFR Code of Federal Regulations
IMC Inspection Manual Chapter
NRC Nuclear Regulatory Commission
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION