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{{Adams
#REDIRECT [[IR 05000293/2015010]]
| number = ML15273A456
| issue date = 10/01/2015
| title = Problem Identification and Resolution Inspection Report and Notices of Violation 05000293/2015010
| author name = Mckinley R
| author affiliation = NRC/RGN-I/DRP
| addressee name = Dent J
| addressee affiliation = Entergy Nuclear Operations, Inc
| docket = 05000293
| license number = DPR-035
| contact person =
| document report number = IR 2015010
| document type = Inspection Report, Letter, Notice of Violation
| page count = 36
}}
See also: [[see also::IR 05000293/2015010]]
 
=Text=
{{#Wiki_filter:OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
                                          UNITED STATES
                            NUCLEAR REGULATORY COMMISSION
                                                REGION I
                                  2100 RENAISSANCE BLVD., SUITE 100
                                    KING OF PRUSSIA, PA 19406-2713
                                          October 1, 2015
Mr. John Dent
Site Vice President
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station
600 Rocky Hill Road
Plymouth, MA 02360-5508
SUBJECT:        PILGRIM NUCLEAR POWER STATION - PROBLEM IDENTIFICATION AND
                RESOLUTION INSPECTION REPORT AND NOTICES OF VIOLATION
                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)
                OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
 
 
 
                                                Non-Sensitive                          Publicly Available
    SUNSI Review
                                                Sensitive                              Non-Publicly Available
OFFICE              RI/DRP              RI/ORA                RI/DRS            RI/DRP                  RI/DRP
NAME                CBickett/cab        BBickett/mmm for      ADimitriadis/ad  RPowell/cab for        RMcKinley/rrm
DATE                09/15/15            09/16/15              09/21/15          09/28/15                10/01/15
                                                 
                OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
Letter to John Dent from Raymond R. McKinley dated October 1, 2015
SUBJECT:      PILGRIM NUCLEAR POWER STATION - PROBLEM IDENTIFICATION AND
              RESOLUTION INSPECTION REPORT AND NOTICES OF VIOLATION
              05000293/2015010
DISTRIBUTION w/encl 1, encl 2; w/o encl 3, encl 4; w/o OUO-SRI: (via email)
DDorman, RA
DLew, DRA
MScott, DRP
JColaccino, DRP
RLorson, DRS
GSuber, DRS
RMcKinley, DRP
SShaffer, DRP
EDiPaolo, DRP
JDeBoer, DRP
MHenrion, DRP
ECarfang, DRP, SRI
BScrabeck, DRP, RI
TGreer, DRP, AA
JJessie, RI OEDO
RidsNrrPMPilgrim Resource
RidsNrrDorlLPL1-1 Resource
ROPReports.Resource
DISTRIBUTION w/encl 1, encl 2, encl 3, encl 4; w/OUO-SRI: (via email)
CJohnson, NSIR
NSimonian, NSIR
EWharton, NSIR
BDesai, DRS, RII
SOrth, DRS, RIII
MHaire, DRS, RIV
RMcKinley, DRP
ECarfang, DRP, SRI
                OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
 
                  OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
                                      NOTICE OF VIOLATION
Entergy Nuclear Operations, Inc.                                        Docket No. 50-293
Pilgrim Nuclear Power Station                                          License No. DPR-35
During an NRC inspection conducted from August 3 through August 20, 2015, a violation of
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the
violation is listed below:
        10 CFR 50.54(q)(2) requires, in part, that a holder of a nuclear power reactor operating
        license shall follow and maintain the effectiveness of an emergency plan that meets the
        requirements in Appendix E to this part, and the planning standards of 10 CFR 50.47(b).
        10 CFR 50.47(b)(8) requires, in part, that adequate equipment to support the emergency
        response are provided and maintained.
        The Pilgrim Nuclear Power Station (Pilgrim) Emergency Plan states, in part, that Pilgrim
        has two meteorological towers, a 220 primary and a 160 back-up, equipped with
        instrumentation for continuous reading of the wind speed, wind direction, air
        temperature, and delta air temperature.
        Contrary to the above, since December 2011, Entergy Nuclear Operations, Inc.
        (Entergy) did not follow and maintain the effectiveness of the Pilgrim Emergency Plan to
        meet the requirement that adequate equipment to support the emergency response was
        provided and maintained. Specifically, in December 2011, Entergy cancelled
        preventative maintenance of the 160 back-up meteorological tower, and that tower
        became non-functional. As a result, on eight occasions between March 18, 2012, and
        August 15, 2015, when the 220 primary meteorological tower was also non-functional
        for various reasons, Pilgrim did not have instrumentation available on either tower for
        continuous reading of the wind speed, wind direction, air temperature, and delta air
        temperature.
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Entergy Nuclear Operations, Inc. (Entergy) is
hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the Pilgrim
Nuclear Power Station, within 30 days of the date of the letter transmitting this Notice of
Violation (Notice). This reply should be clearly marked as a Reply to a Notice of Violation and
should include: (1) the reason for the violation, or, if contested, the basis for disputing the
violation or severity level, (2) the corrective steps that have been taken and the results
achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will
be achieved. Your response may reference or include previous docketed correspondence, if
the correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
                                                                                          Enclosure 1
                  OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
 
                OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
                                                  2
If you contest this enforcement action, you should provide a copy of your response, with the
basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC website at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases of your claim of withholding (e.g., explain why the disclosure of information
required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or
financial information). If safeguards information is necessary to provide an acceptable
response, please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 1st day of October, 2015.
                OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
 
            OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
                                            1
                    U.S. NUCLEAR REGULATORY COMMISSION
                                      REGION I
Docket No.        50-293
License No.      DPR-35
Report No.        05000293/2015010
Licensee:        Entergy Nuclear Operations, Inc. (Entergy)
Facility:        Pilgrim Nuclear Power Station
Location:        600 Rocky Hill Road
                  Plymouth, MA 02360
Dates:            August 3 - 20, 2015
Team Leader:      C. Bickett, Senior Project Engineer, Region I
Inspectors:      D. Caron, Senior Security Inspector, Region I
                  E. Knutson, Senior Resident Inspector, FitzPatrick
                  B. Scrabeck, Resident Inspector, Pilgrim
                  R. Taylor, Senior Project Inspector, Region II
Approved By:      Raymond R. McKinley, Chief
                  Reactor Projects Branch 5
                  Division of Reactor Projects
                                                                    Enclosure 2
            OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
 
                  OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
                                                  2
                                            SUMMARY
IR 05000293/2015010; 08/03/2015 - 08/20/2015; Pilgrim Nuclear Power Station (Pilgrim);
Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified
one finding in the area of problem identification, one finding in the area of problem evaluation,
and two findings in the area of problem resolution.
This U.S. Nuclear Regulatory Commission (NRC) team inspection was performed by three
regional inspectors, including an inspector from Region II, one senior resident inspector, and
one resident inspector. During this inspection, the inspectors identified four findings of very low
safety significance (Green). Two of these findings were classified as cited violations because
Entergy did not restore compliance within a reasonable amount of time after the NRC initially
identified the violations. The other two findings were classified as non-cited violations. The
significance of inspection findings is indicated by their color (i.e., greater than Green, or Green,
White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance
Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC
0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of NRC
requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated
February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear
power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Problem Identification and Resolution
Based on the samples selected for review, the inspectors concluded that Entergy was generally
effective at identifying issues and entering them into the corrective action program at a low
threshold. However, the inspectors noted several examples where Entergy missed identification
of conditions adverse to quality throughout the two-year period since the last problem
identification and resolution inspection in October 2013. Additionally, the inspectors identified
one violation related to an inadequate compensatory measure that resulted from Entergy not
identifying an adverse condition in the corrective action program for resolution.
Though Entergys identification of issues was generally effective, the inspectors determined that
Entergys implementation of the corrective action program related to evaluating and resolving
problems was marginally effective. Entergy did not consistently prioritize, evaluate, and
implement corrective actions to resolve problems in a timely manner, commensurate with the
safety significance of the issues. The inspectors identified one violation related to inadequate
procedures, and two cited violations because Entergy did not restore compliance within a
reasonable amount of time after the NRC issued the original violations in November 2013.
Additionally, the inspectors noted multiple examples of deficiencies related to evaluation and
resolution of issues throughout the two-year inspection period. Also of note, Pilgrims self-
assessment of the corrective action program performed in preparation for this inspection
determined that the effectiveness of both causal analyses and resolution of issues in a thorough
and timely manner were unsatisfactory.
The inspectors determined that in general, Entergy appropriately considered industry operating
experience information for applicability, and used the information for corrective and preventive
actions to identify and prevent similar issues when appropriate. The inspectors concluded that
the self-assessments reviewed were generally thorough and effective in identifying issues and
improvement opportunities.
                  OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
 
                OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
                                                  3
Based on the interviews the inspectors conducted over the course of the inspection,
observations of plant activities, and reviews of individual corrective action program and
employee concerns program issues, the inspectors did not identify any indications that site
personnel were unwilling to raise safety issues nor did they identify any conditions that could
have had a negative impact on the sites safety conscious work environment.
Cornerstone: Initiating Events
*  Green. The inspectors identified a self-revealing Green non-cited violation of Technical
  Specification 5.4.1, Procedures, because Entergy did not provide adequate procedures in
  that appropriate operator actions to recover systems and components important to safety
  were not included within operating procedures 2.1.1, Startup from Shutdown, and 2.2.93,
  Main Condenser Vacuum System, as well as abnormal operating procedure 2.4.36,
  Decreasing Condenser Vacuum. Corrective actions include, in part, for Entergy engineers
  to establish operational limits for the offgas system, to include the factors of reactor power,
  air in-leakage, sea water system alignment, status of the augmented offgas system, status
  of the main turbine, and sea water inlet temperature, and to incorporate these limitations into
  site procedures. Entergy entered this issue into their corrective action program as condition
  report CR-PNP-2015-5197.
  This finding was more than minor because it was associated with the procedure quality
  attribute of the Initiating Events cornerstone and adversely affected the cornerstone
  objective to limit the likelihood of events that upset plant stability and challenge critical safety
  functions during shutdown as well as power operations. Additionally, this performance
  deficiency is similar to example 4.b in IMC 0612, Appendix E, Examples of Minor Issues, in
  that it contributed to a reactor trip. The inspectors evaluated the finding using IMC 0609,
  Appendix A, Exhibit 1, Initiating Events Screening Questions. The inspectors determined
  this finding was of very low safety significance (Green) because it did not cause a loss of
  mitigation equipment relied upon to transition the plant from the onset of the trip to a stable
  shutdown condition. This finding had a cross-cutting aspect in the area of Human
  Performance, Design Margins, because Entergy did not operate equipment within design
  margins. Specifically, Entergy staffs lack of awareness of the limitations of offgas system
  during startup and while placing the main turbine in service resulted in operators
  establishing conditions that were outside those limitations. [H.6] (Section 4OA2.c.(1))
Cornerstone: Emergency Preparedness
*  Green. The inspectors identified a Green cited violation of Title 10 of the Code of Federal
  Regulations (10 CFR) Part 50.54(q)(2) because Entergy did not ensure that the Pilgrim
  Emergency Plan met the planning standards in 10 CFR 50.47(b). Specifically, in December
  2011, Entergy cancelled preventative maintenance of the 160 back-up meteorological
  tower, and that tower became non-functional. As a result, on eight occasions between
  March 18, 2012, and August 15, 2015, when the 220 primary meteorological tower was also
  non-functional for various reasons, Pilgrim did not have instrumentation available on either
  tower for continuous reading of the wind speed, wind direction, air temperature, and delta air
  temperature. At the time of this inspection in August 2015, Entergy was in the process of
  obtaining necessary permits for construction of the new tower.
                OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
 
                OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
                                                  4
  This finding is more than minor because it is associated with the facilities and equipment
  attribute of the Emergency Preparedness cornerstone and adversely affected the
  cornerstone objective of ensuring the licensee is capable of implementing adequate
  measures to protect the health and safety of the public in the event of a radiological
  emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness
  Significance Determination Process, Table 5.8-1, the inspectors determined the finding to
  be of very low safety significance (Green) because the planning standard function was
  degraded. Specifically, a significant amount of equipment necessary to implement the
  emergency plan was not functional to the extent that an emergency response organization
  member could not perform assigned functions, in the absence of compensatory measures.
  However, Pilgrim was able to make adequate dose assessments at all times using the
  National Weather Service to obtain necessary data. This finding has a cross-cutting aspect
  in the area of Problem Identification and Resolution, Resolution, because Pilgrim did not
  take effective corrective actions to address issues in a timely manner commensurate with
  their safety significance. Specifically, numerous delays and extensions of corrective actions
  resulted in a period of approximately two years in which the adverse condition identified by
  the inspectors had not been corrected, during which additional outages of the primary
  meteorological tower have resulted in additional unnecessary degradation of the Pilgrim
  Emergency Plan. [P.3] (Section 4OA2.c.(2))
* Green. The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2) because
  Entergy did not follow and maintain an emergency plan that meets the requirements of
  planning standards 10 CFR 50.47(b) and Appendix E. Specifically, the Emergency Plan
  Implementing Procedure specified insufficient equipment as the primary method of
  emergency action level assessment, and directed invalid compensatory measures to be
  used when the primary method of emergency action level assessment for reactor coolant
  system leakage was unavailable. Entergy entered these issues into the corrective action
  program as condition reports CR-PNP-2015-7183 and CR-PNP-2015-7394. Additionally,
  since the time of this inspection, Entergy completed and issued the new procedure
  governing equipment important to emergency response.
  This finding was more than minor because it was associated with the emergency response
  organization performance (program elements not meeting 50.47(b) planning standards)
  attribute of the Emergency Preparedness cornerstone and affected the cornerstone
  objective of ensuring that the licensee is capable of implementing adequate measures to
  protect the health and safety of the public in the event of a radiological emergency.
  Specifically, the incomplete procedural guidance and the inadequate compensatory
  measure could have led to an 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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Description. The emergency action level declaration conditions for reactor coolant
system identified leakage is determined based on the volume of water pumped from the
drywell equipment sump. Similarly, the declaration conditions for reactor coolant system
unidentified or pressure boundary leakage are determined based on the volume of water
pumped from the drywell floor sump. The emergency action level threshold for an
Unusual Event (SU6.1) is 10 gallons per minute of unidentified or pressure boundary
leakage or 25 gallons per minute identified leakage. Entergy utilizes Emergency Plan
Implementing Procedures to provide guidance to operators and emergency response
organization members for following and maintaining the planning standard functions in
the approved Emergency Plan. Specifically, Entergy developed Emergency Plan
Implementing Procedure EP-IP-100.1, Emergency Action Levels, to provide guidance
to operators for classifying abnormal plant events as well as compensating actions for
out-of-service emergency action level equipment.
In the extent of condition review of an apparent cause evaluation for the inadequate
compensatory measures identified by the inspectors on January 27, 2015, for the
assessment of bay level, Entergy determined that the prescribed compensatory measure
for the assessment of reactor coolant system leakage was invalid. Specifically, EP-IP-
100.1, Attachment 9.2, Emergency Action Level Related Equipment, listed level
indicator LI-5008, the primary containment water level indicator, as the alternate source
of information. The purpose of LI-5008 is to provide indication of water level in the
primary containment in the event that an accident requires the deliberate flooding of the
containment. Entergy staff determined that this compensatory measure was inadequate
to provide timely assessment of reactor coolant system leak rates.
Although Entergy initially identified this invalid compensatory measure during the
apparent cause evaluation, the station did not write a condition report in accordance with
EN-LI-118, Cause Evaluation Process. Entergy staff chose to correct this issue as part
of a longer term procedure revision which called for the development of a larger and
more comprehensive procedure governing equipment important to emergency response,
which was a corrective action for the inadequate bay level compensatory measures.
Since Entergy did not enter the issue regarding the primary containment water level
invalid compensatory measure into the corrective action program, the measure remained
in place, and no interim guidance was provided to staff in order to assist in more
accurate and timely emergency action level assessment until the new procedure
governing equipment important to emergency response was issued.
Additionally, during review of procedure EP-IP-100.1, inspectors determined that the
specified emergency action level equipment for the assessment of reactor coolant
system leakage was incomplete and inaccurate. Specifically, the drywell floor sump
pumps are appropriately specified for the assessment of unidentified or pressure
boundary leakage, however they were given the incorrect designation of P-306A/B, while
the correct designation for this equipment is P-305A/B. Since the procedure listed the
correct name of the drywell floor sump pumps, equipment that is routinely used by
operators, the inspectors determined that the incorrect component number was a minor
editorial error that would not have reasonably interfered with emergency action level
assessment. However, in addition, the appropriate equipment for the assessment of
identified leakage, drywell equipment sump pumps P-301A/B, was absent from the
listing of emergency action level related equipment. Consequently, plant operators were
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provided with incomplete guidance in EP-IP-100.1 to aid in the assessment of
emergency action level thresholds for reactor coolant system leakage. Moreover, in the
event of equipment malfunction or normal maintenance that renders the drywell
equipment sump pumps P-301A/B unavailable, Entergy staff did not have clear guidance
to inform a determination of a major loss of assessment capability.
The inspectors performed a review of the revision history of EP-IP-100.1, and
determined that the invalid compensatory measure has been in place since January
2008, when the procedure was revised to incorporate Attachment 9.2 for the purpose of
listing necessary equipment for emergency action level declaration and to provide
associated compensatory measures when the equipment is out of service. The
inspectors also determined that the incomplete listing of equipment in the same
attachment for the assessment of reactor coolant system leakage had been in place
since September 2013, when the attachment was revised to replace the generic listing of
monitored parameters with more specific references to equipment used in assessment
of emergency action level entry conditions. The inspectors reviewed the information
being used to develop the proposed equipment important to emergency response
procedure, and verified that Entergy identified the incomplete information in the
development of the proposed procedure. However, as in the case of the invalid
compensatory measure, this newly identified deficiency with the current procedure was
not entered into the corrective action program, and therefore, the inadequate guidance
for emergency action level assessment was allowed to remain in place with no interim
guidance provided to Entergy staff. Entergy has entered these issues into the corrective
action program as condition reports CR-PNP-2015-7183 and CR-PNP-2015-7394.
Additionally, since the time of this inspection, Entergy has completed and issued the new
procedure governing equipment important to emergency response.
Analysis. The inspectors determined that not maintaining complete procedural guidance
or valid compensatory measures for out-of-service emergency action level equipment in
accordance with 10 CFR 50.47(b) was a performance deficiency that was within
Entergys ability to foresee and correct and should have been prevented. Specifically,
Entergy did not ensure that equipment and the compensatory measure listed in
Attachment 9.2 of EP-IP-100.1, Emergency Action Levels, Revision 11, was adequate
to support timely assessment of emergency action level entries. This NRC-identified
performance deficiency was more than minor because it was associated with the
emergency response organization performance (program elements not meeting 50.47(b)
planning standards) attribute of the Emergency Preparedness cornerstone and affected
the cornerstone objective of ensuring that the licensee is capable of implementing
adequate measures to protect the health and safety of the public in the event of a
radiological emergency. Specifically, the incomplete procedural guidance and the
inadequate compensatory measure could have led to an emergency not being declared
in a timely manner. The inspectors evaluated the finding using IMC 0609, Attachment 4,
Initial Characterization of Findings, issued June 19, 2012, and IMC 0609, Appendix B,
Emergency Preparedness Significance Determination Process, issued September 26,
2014. The inspectors determined the finding was associated with risk significant
planning standard 10 CFR 50.47(b)(4), Emergency Classification System, and
corresponded to the following Green Finding example in Table 5.4-1: an EAL has been
rendered ineffective such that any Alert or Unusual Event would not be declared, or
declared in a degraded manner for a particular off-normal event. Therefore, using
Figure 5.4-1, Significance Determination for Ineffective EALs and Overclassification,
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    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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  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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    reports, and the results of the last safety culture survey, conducted in 2012. The
    inspectors interviewed the station Employee Concerns Program coordinator to
    determine what actions are implemented to ensure employees were aware of the
    program and its availability with regards to raising safety concerns, and reviewed a
    sample of Employee Concerns Program files to ensure that Entergy entered issues into
    the corrective action program when appropriate.
b.  Assessment
    During interviews, Pilgrim staff stated that they were willing to raise safety issues. The
    inspectors noted that none of the staff interviewed stated that they personally
    experienced or were aware of a situation in which an individual had been retaliated
    against for raising a safety issue. All persons interviewed demonstrated an adequate
    knowledge of the corrective action program and the Employee Concerns Program.
    Additionally, the station was in the process of conducting a site-wide safety culture
    survey during this inspection. Based on these limited interviews, and review of the
    various documentation discussed above, the inspectors concluded that there was no
    evidence of an unacceptable safety conscious work environment and no significant
    challenges to the free flow of information.
c.  Findings
    No findings were identified.
4OA6 Meetings, Including Exit
    On August 20, 2015, the inspectors presented the inspection results to Mr. John Dent,
    Site Vice President, and other members of the Pilgrim staff. The inspectors verified that
    no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT: SUPPLEMENTARY INFORMATION
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                                              A-1
                              SUPPLEMENTARY INFORMATION
                                  KEY POINTS OF CONTACT
Licensee Personnel
J. Dent, Site Vice President
P. Beabout, Security Manager
G. Blankenbiller, Chemistry Manager
R. Brooks, Radiation Protection Technician
D. Calabrese, Emergency Preparedness Manager
M. Cardinal, Electrician
B. Chenard, Engineering Director
S. Cook, Chemistry Technician
J. Cox, Radiation Protection Supervisor
R. Daly, Security Superintendent
K. Drown, Performance and Improvement Manager
M. Gastlick, Senior Supervisor, Security
M. Jacobs, Manager of Nuclear Oversight
G. Kelly, Electrical Maintenance Supervisor
C. Lewis, Instrument and Control Technician
K. Lowther, Employee Concerns Program Coordinator
J. MacDonald, Senior Operations Manager
D. Noyes, Director of Regulatory and Performance Improvement
J. Ohrenberger, Senior Maintenance Manager
E. Perkins, Regulatory Assurance Manager
R. Pierson, Senior Supervisor, Security
J. Sabina, Inservice Testing Program Engineer
J. Shumate, PS&O Manager
D. Smith, Mechanical Maintenance Supervisor
L. Timus, Mechanic
T. Wheble, Instrument and Control Maintenance Supervisor
M. Williams, Nuclear Safety Licensing Specialist
A. Zielie, Radiation Protection Manager
              LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
05000293/2015010-01              NCV      Inadequate Procedures for Placing Main Turbine
                                            in Service (Section 4OA2.c(1))
05000293/2015010-03              NCV      Inadequate Guidance and Invalid Compensatory
                                            Measures for Out-of-Service EAL
                                            Instrumentation (Section 4OA2.c(3))
                                                                                  Attachment
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                                                A-2
Opened
05000293/2015010-02                VIO        Untimely Actions to Restore Station
                                              Meteorological Towers (Section 4OA2.c(2))
05000293/2015010-04                VIO        Security Finding (Enclosure 4)
                              LIST OF DOCUMENTS REVIEWED
Condition Reports (* indicates that condition report was generated as a result of this inspection)
CR-HQN-2015-00291                  CR-PNP-2013-05246                  CR-PNP-2014-01321
CR-PNP-2008-02038                  CR-PNP-2013-05256                  CR-PNP-2014-01775
CR-PNP-2009-04552                  CR-PNP-2013-05385                  CR-PNP-2014-01994
CR-PNP-2009-04696                  CR-PNP-2013-06186                  CR-PNP-2014-02007
CR-PNP-2010-01557                  CR-PNP-2013-06386                  CR-PNP-2014-02008
CR-PNP-2010-02420                  CR-PNP-2013-06684                  CR-PNP-2014-02043
CR-PNP-2010-02846                  CR-PNP-2013-06697                  CR-PNP-2014-02112
CR-PNP-2010-03555                  CR-PNP-2013-06721                  CR-PNP-2014-02319
CR-PNP-2010-04531                  CR-PNP-2013-06736                  CR-PNP-2014-02379
CR-PNP-2011-00242                  CR-PNP-2013-06741                  CR-PNP-2014-02514
CR-PNP-2011-01180                  CR-PNP-2013-06818                  CR-PNP-2014-02739
CR-PNP-2011-01538                  CR-PNP-2013-06829                  CR-PNP-2014-02743
CR-PNP-2011-02696                  CR-PNP-2013-06830                  CR-PNP-2014-02749
CR-PNP-2011-03068                  CR-PNP-2013-06831                  CR-PNP-2014-02967
CR-PNP-2011-03636                  CR-PNP-2013-06906                  CR-PNP-2014-03381
CR-PNP-2011-04301                  CR-PNP-2013-06961                  CR-PNP-2014-03763
CR-PNP-2011-04503                  CR-PNP-2013-07023                  CR-PNP-2014-03973
CR-PNP-2011-05591                  CR-PNP-2013-07025                  CR-PNP-2014-03999
CR-PNP-2012-00669                  CR-PNP-2013-07231                  CR-PNP-2014-04009
CR-PNP-2012-00907                  CR-PNP-2013-07313                  CR-PNP-2014-04546
CR-PNP-2012-01359                  CR-PNP-2013-07336                  CR-PNP-2014-04676
CR-PNP-2012-01520                  CR-PNP-2013-07445                  CR-PNP-2014-04733
CR-PNP-2012-02304                  CR-PNP-2013-07540                  CR-PNP-2014-04951
CR-PNP-2012-02644                  CR-PNP-2013-07547                  CR-PNP-2014-05017
CR-PNP-2012-04248                  CR-PNP-2013-07679                  CR-PNP-2014-05065
CR-PNP-2012-04291                  CR-PNP-2013-07824                  CR-PNP-2014-05125
CR-PNP-2012-04621                  CR-PNP-2013-07888                  CR-PNP-2014-05561
CR-PNP-2012-04816                  CR-PNP-2013-07907                  CR-PNP-2014-05746
CR-PNP-2012-05202                  CR-PNP-2013-07984                  CR-PNP-2014-05825
CR-PNP-2012-05244                  CR-PNP-2013-08042                  CR-PNP-2014-05877
CR-PNP-2013-00213                  CR-PNP-2014-00136                  CR-PNP-2014-06294
CR-PNP-2013-00428                  CR-PNP-2014-00149                  CR-PNP-2014-06746
CR-PNP-2013-00610                  CR-PNP-2014-00249                  CR-PNP-2015-00062
CR-PNP-2013-00853                  CR-PNP-2014-00251                  CR-PNP-2015-00243
CR-PNP-2013-01158                  CR-PNP-2014-00270                  CR-PNP-2015-00277
CR-PNP-2013-01538                  CR-PNP-2014-00815                  CR-PNP-2015-00324
CR-PNP-2013-01570                  CR-PNP-2014-00985                  CR-PNP-2015-00499
CR-PNP-2013-01784                  CR-PNP-2014-01207                  CR-PNP-2015-00558
CR-PNP-2013-01819                  CR-PNP-2014-01229                  CR-PNP-2015-00559
              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 Findings
05000293/2011007-03, 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 Towers
05000293/2014003-01, 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
      Relays
05000293/2015002-03, 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
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