ML15273A456

Problem Identification and Resolution Inspection Report and Notices of Violation 05000293/2015010

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

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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

05000293/2015010

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.

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-

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)

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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

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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

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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.

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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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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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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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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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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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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-

PNP-2015-00375

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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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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19

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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20

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

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

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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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

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

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

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

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

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

Work Order 52504622

LIST OF ACRONYMS

CFR Code of Federal Regulations

IMC Inspection Manual Chapter

NRC Nuclear Regulatory Commission

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION