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IR 05000293/2015009; 05/04/2015 - 05/08/2015; Pilgrim Nuclear Power Station (Pilgrim); Follow-up Supplemental Inspection - Inspection Procedure (IP) 95002
	ML15169A946
Person / Time
Site:	Pilgrim
Issue date:	06/18/2015
From:	Ho Nieh; Division Reactor Projects I
To:	Dent J; Entergy Nuclear Operations
	McKinley R
References
	IR 2015009
	Download: ML15169A946 (19)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 June 18, 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 - NRC 95002 SUPPLEMENTAL FOLLOW-UP INSPECTION REPORT 05000293/2015009

Dear Mr. Dent:

On May 8, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a follow-up supplemental inspection in accordance with Inspection Procedure (IP) 95002, "Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area," at your Pilgrim Nuclear Power Station (Pilgrim). Specifically, Pilgrim experienced four reactor scrams in 2013 which resulted in two performance indicators (PIs) in the Initiating Events cornerstone, Unplanned Scrams per 7000 Critical Hours and Unplanned Scrams with Complications, crossing the threshold from Green to White. The enclosed inspection report documents the inspection results, which were discussed on May 8, 2015, with you and other members of your staff.

The NRC previously completed a supplemental inspecti on in December 2014 to review your actions to address the White PIs. Inspection results are documented in NRC Inspection Report 05000293/2014008, dated January 26, 2015 (Reference ML15026A069). At that time, the NRC staff determined Entergy's actions to address the two White PIs were not sufficient and that collectively, the issues represented a significant weakness as described in NRC IP 95002. Accordingly, the NRC assigned two parallel White PI inspection findings and identified the need to complete an additional inspection after Entergy staff had addressed the extent of condition concerns, made sufficient progress on the improvements to the corrective action program (CAP), and informed the NRC staff of their readiness for further inspection.

The objectives of this follow-up supplemental inspection were to verify that Entergy addressed the deficiencies which resulted in the assignment of two parallel White PI inspection findings in NRC Inspection Report 05000293/2014008. Specifically, this inspection was performed to verify that Entergy has: (1) assessed the independent failure analysis of the faulted 345kV electrical switchyard insulators for potential impact to the root cause evaluation (RCE) and revised as appropriate; (2) assessed the revised RCE for the February 8, 2013 winter storm station impact and associated reactor scram, to include additional actions for the incomplete initial effectiveness review; (3) evaluated the effectiveness of additional maintenance department human performance related corrective actions implemented during the inspection through in-progress and completed work; (4) completed the evaluation of the cause(s) for the failed electrical cable splice that resulted in a loss of all three reactor feedwater pumps and has revised the RCE to include additional corrective actions, if appropriate; and (5) evaluated the revisions to the RCEs for the overall common cause evaluation, which included taking action to understand why corrective actions intended to address the identified CAP implementation weakness were not effective at ensuring the inspection objectives were satisfied. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The inspectors completed their onsite reviews on May 8, 2015.

The NRC determined that Pilgrim's extent of condition reviews and corrective actions related to the original four root causes were sufficient and appropriate to address the identified significant weakness as documented in Supplemental Inspection Report 05000293/2014008. Additionally, no findings of significance were identified as a result of this inspection. Based upon the collective results of this inspection and Supplemental Inspection Report 05000293/2014008, the NRC determined the inspection objectives of IP 95002 have been satisfied.

Because the objectives of IP 95002 were satisfied, the two parallel White findings assigned in the December 2014 IP 95002 supplemental inspection will be considered closed at the end of the second quarter 2015. On May 27, 2015, the NRC issued Special Inspection Report 05000293/2015007, which was associated with the January 27, 2015 partial loss of offsite power event (ADAMS Accession Number ML15147A412). The special inspection report documented a preliminary White finding associated with Entergy's inadequate identification, evaluation, and correction of the 'A' safety/relief valve (SRV) failure to open upon manual actuation during a plant cooldown on February 9, 2013. After the significance determination for the 'A' SRV finding is finalized, the NRC will assess Pilgrim's overall performance in relation to the Reactor Oversight Process Action Matrix.

Accordingly, Pilgrim's performance will remain within the Degraded Cornerstone Column of the NRC's Reactor Oversight Process Action Matrix as discussed in the Pilgrim Annual Assessment Letter (Report 05000293/2014001), dated March 4, 2015. If Pilgrim transitions to a different Action Matrix Column following the final significance determination for the preliminary White finding, then the transition will be communicated in a future correspondence. Additionally, the NRC will continue to assess the effectiveness and sustainability of your efforts to address challenges in CAP implementation during the next biennial problem identification and resolution inspection, scheduled for August 2015.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of ADAMS. ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Ho K. Nieh, Director

Division of Reactor Projects Docket No. 50-293 License No. DPR-35

Enclosure:

Inspection Report 05000293/2015009 w/Attachment: Supplemental Information

REGION I==

Docket No. 50-293

License No. DPR-35

Report No. 05000293/2015009

Licensee: Entergy Nuclear Operations, Inc. (Entergy)

Facility: Pilgrim Nuclear Power Station

Location: Plymouth, Massachusetts

Dates: May 4, 2015 through May 8, 2015

Inspectors: S. Hansell, Senior Resident Inspector, Lead Inspector T. Setzer, Senior Project Engineer G. Newman, Resident Inspector Approved by: Raymond R. McKinley, Chief Reactor Projects Branch 5

Division of Reactor Projects

2

SUMMARY OF FINDINGS

Inspection Report (IR) 05000293/2015009; 05/04/2015 - 05/08/2015; Pilgrim Nuclear Power Station (Pilgrim); Follow-up Supplemental Inspection - Inspection Procedure (IP) 95002.

The report covered an on-site inspection by a Senior Resident Inspector, Senior Project Engineer, and one Resident Inspector. No findings were identified. The U.S. Nuclear

Regulatory Commission's (NRC's) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5, February 2014.

Cornerstone: Initiating Events

The NRC staff performed this supplemental inspection in accordance with IP 95002, "Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area," to assess Entergy's actions to evaluate and implement changes to address the initial IP 95002 supplemental inspection (IR 05000293/2014008) conducted, in part, to review the two White performance indicators (PIs) and the initial corrective actions that were not sufficient to address the White PIs at that time. Consistent with Inspection Manual Chapter (IMC) 0305, "Operating Reactor Assessment Program," Section 11.01(e), this follow-up supplemental inspection specifically focused on the areas of significant weaknesses as documented in NRC Supplemental Inspection Report 05000293/2014008.

The inspectors did not identify any new significant weaknesses in regard to Entergy's actions to address the White PIs. The inspectors concluded that Entergy implemented adequate corrective actions and made sufficient progress in applicable areas to address the significant weaknesses previously documented in IP 95002 Supplemental IR 05000293/2014008.

The inspection objectives of IP 95002 have been satisfied and the two parallel White findings issued as part of Supplemental IR 05000293/2014008 will be considered closed at the end of the second quarter 2015.

Other Findings

None 4

REPORT DETAILS

OTHER ACTIVITIES

4OA4 Follow-Up Supplemental Inspection

Main article: IP 95002

.01 Inspection Scope

The NRC staff performed this follow-up supplemental inspection in accordance with IP 95002, "Supplemental Inspection for One Degraded Cornerstone of Any Three White Inputs in a Strategic Performance Area." This inspection follows up on a supplemental inspection completed and documented in Supplemental IR 05000293/2014008 that issued two parallel White findings associated with Entergy's extent of condition reviews and corrective actions related to the four root causes performed for the events that resulted in two PIs in the Initiating Events cornerstone crossing the threshold from Green to White.

The NRC follow-up supplemental inspection team has concluded that Entergy has successfully addressed the five significant deficiencies documented in Supplemental IR 05000293/2014008.

The inspectors have verified that Entergy's completed and planned corrective actions have addressed the previously identified significant deficiencies by performing the following:

1) Assessed the independent failure analysis of the faulted 345 kilovolt (kV) electrical switchyard insulators for potential impact to the root cause evaluation (RCE) and revised as appropriate;

2) Assessed the revised RCE for the February 8, 2013 winter storm station impact and associated reactor scram, to include additional actions for the incomplete initial

effectiveness review; 3) Evaluated that Entergy has demonstrated the effectiveness of additional

maintenance department human performance related corrective actions implemented during the inspection through in-progress and completed work;

4) Verified that Entergy has completed the evaluation of the cause(s) for the failed electrical cable splice that resulted in a loss of all three reactor feedwater pumps; and has revised the RCE to include additional corrective actions; and

5) Evaluated the Entergy revisions to the RCEs for the overall common cause evaluation, which included taking action to understand why corrective actions intended to address the identified corrective action program (CAP) implementation weakness were not effective at ensuring the inspection objectives were satisfied.

.02 Evaluation of the Inspection Requirements

02.01 Root Cause, Extent of Condition, and Extent of Cause Evaluation Failed Electrical Cable Splice/Loss of all Reactor Feed Pumps Missed Opportunity/Missing Post-Maintenance Tests not Captured in Corrective Action Program During the initial supplemental inspection, the NRC reviewed RCE CR-PNP-2013-5949 and concluded that Entergy did not identify a root or contributing cause for the failed reactor feed pump (RFP) electrical cable splice. In March 2015, Entergy completed a revision to the RCE, in which the direct cause, root cause, and contributing causes were revised. The revised RCE identified a contributing cause for the failed splice. Specifically, station maintenance procedures and work processes were not followed by the maintenance personnel when performing a non-safety-related splice for solenoid valve (SV)-3067. Entergy determined that the splice had most likely been fabricated in 1999 during implementation of a plant design change (PDC) of multiple valves (PDC 98-38). In their investigation, Entergy found multiple deficient work practice issues with the splice, which included that it was fabricated with the wrong crimp tool, and that it was not staggered to ensure room and flexibility in the conduit. This resulted in an inadequate splice that ultimately failed and led to the loss of all three RFPs on August 22, 2013.

The inspectors determined that Entergy performed a thorough evaluation of the failed splice and revised the RCE to include extent of condition and extent of cause actions that were reasonable with supported conclusions. However, the inspectors identified the following observations regarding the extent of condition and extent of cause:

As part of the extent of condition, Entergy created work orders (WOs) to inspect the wiring associated with four additional SVs (SV-3001, SV-3004, SV-3066, and SV-3351) that were rewired in 1999 as part of PDC 98-38. The inspections were performed during a plant shutdown in February 2015. The WO instructions (375493, 375489, 375495, and 375497) did not contain adequate guidance on how to perform the inspections. Specifically, the instructions did not direct the technicians to completely remove the wires to determine if any splices were hidden in the conduit.

The technicians only removed condulet covers and inspected the ends of the wiring.

As a result, the inspections had to be performed again during the refueling outage of May 2015 (RFO20). The inspectors determined that the lack of work instructions and missed opportunity to perform the inspections properly was not captured in the CAP. Additionally, three WOs for the inspections in RFO20 did not include post-maintenance test activities. Entergy entered the missed inspection opportunity and post-maintenance tests as items in the CAP (CR-PNP-2015-04455 and CR-PNP-2015-04403, respectively).

Regarding the extent of cause, Entergy determined the inadequate work practices associated with the maintenance personnel that performed the splice in 1999 indicated that similar modified valves may have inadequate splices. In 1999 there was no specific training on crimping or electrical terminations using butt splices.

Training on these topics was not provided until 2006. Entergy performed a review of modifications from 1995-2000 that replaced, relocated, or reoriented non-safety-related components that could have splices. The inspectors determined the timeframe of 1995-2000 was of limited benefit to fully explore the work practice issues in plant modifications, since technicians were not trained until 2006. Entergy entered this observation into the CAP (CR-PNP-2015-04443).

The above observations were determined not to be violations of NRC regulatory requirements and as stated earlier have been entered into Entergy's CAP for further

evaluation.

b. Findings

No findings were identified.

02.03 Corrective Actions a. CAP Evaluation for CR-PNP-2014-05735 - Assess the Independent Failure Analysis of the Faulted 345kV Electrical Switchyard Insulators for Potential Impact to the RCE and Revise as Appropriate

During the initial supplemental inspection, the inspectors determined that Entergy had improperly closed a corrective action to conduct failure analysis on failed insulators from a previous loss of offsite power event. Entergy generated CR-PNP-2014-05735 and sent the insulator off site for failure analysis.

The inspectors reviewed CR-PNP-2014-05735 to determine whether Entergy had completed or planned corrective actions to address the significant deficiencies. Entergy created new corrective actions in CR-PNP-2013-00798 to track the testing and review of test results. Entergy sent two insulators, one insulator that had experienced flashover and an insulator that was not installed in the electrical switchyard, to a third-party testing facility, Doble Engineering. Doble Engineering performed current leakage testing and partial discharge testing on the insulators. Doble Engineering determined that both insulators were still within the original equipment manufacturer's (OEMs) specifications. Doble Engineering recommended testing additional insulators to determine remaining service life. Entergy reviewed the results of the testing and provided the test report to the OEM, LAPP, for review. The OEM informed Entergy that the results were normal and that the insulators have a service life of 30 years. Entergy generated CR-2014-PNP-6799 to track the creation of preventive maintenance (PM) to replace insulators before the end of their service life.

The inspectors questioned how Entergy addressed Doble Engineering's recommendation to test other installed insulators. Entergy informed the inspectors that the recommendation would be considered as part of the PM corrective action due in 2016. Entergy created CR-2015-PNP-04473 to capture their planned actions in response to the vendor recommendation.

Entergy determined that the results of the testing did not impact the RCE performed for CR-PNP-2013-0798 since the testing results did not show substantial insulator degradation; therefore, a revision was not necessary. In general, the inspectors determined that the proposed corrective actions were appropriate and addressed each identified root and contributing cause. Entergy has taken actions to address the deficiencies identified in evaluation or correction of the individual performance issues discussed above. Specifically, the inspection verified that Entergy has taken action to:

(1) address the specific deficiencies in execution of corrective actions;

(2) address the deficient cause evaluation; and

(3) understand why corrective actions intended to address the identified CAP implementation weakness were not effective at ensuring the inspection objectives were satisfied.

b. 2013 Winter Storm Scram - Verify that Entergy has Revised the RCE for the Winter Storm Scram to Include Additional Action for the Incomplete Effectiveness Review During the initial supplemental inspection, the NRC reviewed RCE CR-PNP-2013-0798 and concluded that Entergy did not complete a second effectiveness review in accordance with CAP requirements.

Specifically, the initial effectiveness review for the de-icing PM was concluded to be indeterminate, but a follow-up (second) effectiveness review was never assigned to ensure the action would be completed properly. In January 2015, the second effectiveness review was completed following the January 27, 2015 winter storm known as Juno. This review determined that actions taken during winter storm Juno were ineffective, as both 345kV electrical lines were de-energized due to extensive icing of the switchyard insulators. Portable salamander heaters used during the storm were unable to prevent icing of the insulators as water would quickly refreeze once the heaters were removed. As a result, Entergy hired an outside contractor to perform pressure washing of the switchyard to remove ice from the insulators. This method was found to be effective and the plant was able to restart without any flashover events. In March 2015, a third effectiveness review was completed which concluded that the effectiveness of pressure washing the switchyard was validated, and that this method should be added to existing PM tasks to de-ice the switchyard in the future.

Entergy modified PM task 16789 to include salamander heaters, manual brushing, and the use of an offsite contractor for pressure washing.

Entergy determined that the RCE did not need revision as a result of the effectiveness reviews. Activities to perform the effectiveness reviews were already assigned in CR-PNP-2013-0798 but were not completed. The inspectors determined that the incomplete effectiveness review was completed with supportable conclusions. Additionally, the inspectors verified that the original RCE contained actions to complete the effectiveness review so a revision was not warranted.

c. Effectiveness of Maintenance Department Human Performance Related Corrective Actions During the initial supplemental inspection, the inspectors determined that observations of maintenance execution did not support closure or cancellation of corrective actions identified in the RCE. The inspectors identified the following deficiencies:

Entergy's actions in September 2014 directed interim actions for enhanced supervisor oversight and procedure review in preparation for maintenance. This was an interim action until a long-term procedure upgrade project for maintenance was complete. The inspectors identified that the maintenance standing order was not being implemented at the time of the on-site inspection. Several procedures did not have critical steps annotated properly. A technician identified a critical step during a pre-job brief, but did not generate a condition report or a procedure feedback form to ensure permanent correction of the deficiency.

One procedure contained steps that directed calibration of an instrument after fuses and alarms had been verified restored, an action that if performed without re-performing steps in the body of the procedure would result in an adverse

consequence. Technicians continued with testing activities after encountering challenges, contrary to the station expectation to stop and evaluate the unexpected conditions.

In response to the inspectors concerns, Entergy created multiple condition reports and revised the RCE to include additional corrective actions for procedural reviews prior to performance of work and enhanced oversight. At the time of the follow-up inspection, the previous maintenance standing order was augmented and formalized into a permanent procedure, 1.3.144, "Maintenance Performance of Trip Sensitive Activities." The procedure provides guidance to reinforce human performance attributes for maintenance work that could cause a plant automatic shutdown or inadvertent safeguard system actuation. The procedure is an interim measure until the procedure upgrade

program is complete.

The inspectors observed a pre-job briefing and performance of trip-sensitive activities.

Additionally, the inspectors reviewed a sample of completed WOs for trip sensitive activities and WO instructions for scheduled ac tivities to verify the interim measures were implemented. Specifically, the inspectors verified that work was classified

appropriately as a trip sensitive activity and that the additional requirements of procedure 1.3.144 were implemented, for example:

Discussion of the consequences of performance errors; Identification and validation of critical procedure steps; Discussion of work after logic restoration; Preparations to stop work if unexpected results are obtained; Discussion of procedure adherence requirements; and Review of procedure changes since last performed.

The inspectors observed technicians stop work when the procedure did not address restoration of robust barriers when leaving the area to perform another step in a separate area. The inspectors also observed successful performance of a critical step verifying that contacts associated with backup scram valves are open prior to initiating a half-scram signal.

With respect to the procedure upgrade project in the maintenance department, the current due date for this corrective action is March 3, 2016. Based on documentation review and interviews with station personnel, the inspectors noted that the procedure upgrade project is on schedule to be completed by the March 2016 date.

d. CAP Overall Common Cause Evaluation for CR-PNP-2015-00375

Entergy has taken actions to address the deficiencies identified in the evaluation or correction of the individual performance issues discussed above. Specifically, the follow-up inspection verified that Entergy has taken action to:

(1) address the specific deficiencies in execution of corrective actions;

(2) address the deficient cause evaluation; and

(3) understand why corrective actions intended to address the identified CAP implementation weakness were not effective at ensuring the inspection objectives were satisfied.

Entergy made changes to ensure station management and supervision were effective at driving accountability at all levels of the organization to improve performance in all areas of the CAP. Specific areas included: corrective action implementation, corrective action timeliness, corrective action closure documentation, CAP procedure compliance, and resolution of early indications of poor CAP implementation. In addition, Entergy identified that an inadequate procedure used to prepare for the initial supplemental inspection, EN-LI-123-01, "Preparation for 95001(2)," did not provide structured preparation guidance to perform and support a performance based inspection that assumed the CAP program was robust and effective.

The CAP routine initial data entry input and classification by the Department Performance Improvement Coordinators (DPICs) and subsequent review by the management Condition Review Group (CRG) to assign responsible actions have improved substantially in the past four months. The improvements were accomplished with the DPIC's review of every corrective action closure package. Prior to the change, numerous corrective actions were closed to unapproved processes, closure dates were extended or transferred to other condition reports, several significant CAP related condition reports were closed to a single condition report and some remained open through May 2015. The follow-up team reviewed the satisfactory closure of three RCE closure items related to CR-PNP-2015-00375. Fifteen corrective action closure items were partially complete and will be available for inspection during the August 2015 biennial problem identification and resolution inspection team.

Pilgrim implemented a station performance improvement process in June 2014 to improve the station's personnel accountability at all levels of the organization in an effort to improve performance in all areas of the CAP. The improvement process included the following three key processes: 1) 200 Percent Accountability model that emphasized individual accountability and holding others accountable to station core values and processes; 2) a Culpability model that ensures consistent coaching and discipline when human errors result in plant events, consequential errors, non-consequential errors, and issues that require management attention to resolve; and 3) Pilgrim Excellence in Behaviors model that includes seven fundamental behaviors that are exhibited by successful and high performing organizations. After an initial learning curve, the station implementation of the three models has contributed to improved CAP performance.

DPICs' routine weekly training was a very effective knowledge transfer method to improve individual and group experience and ensure consistent understanding and application of the CAP process. The inspectors noted that DPICs were not required to observe CRG or corrective action review board meetings as part of their qualification.

These meetings, in addition to their own pre-screening meeting, are integral parts of the CAP and would give the DPICs better perspective of their role in the CAP. Additionally, the inspectors noted that there was no formal continuing training for the DPICs. The inspectors note that DPICs meet weekly to perform training and periodically meet with the Site Vice President.

Additionally, the NRC will continue to assess the effectiveness and sustainability of the efforts to address challenges in CAP implementation during the next biennial problem identification and resolution inspection, scheduled for August 2015.

e. Findings

No findings were identified.

4OA6 Exit Meeting

On May 8, 2015, the inspectors presented the inspection results to Mr. J. Dent, Site Vice President, and other members of his staff. The inspectors verified that no proprietary information was retained by the inspection team.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT

Licensee Personnel

N. Berg Contractor T. Bordelon Performance Improvement Manager

A. Brouchard Engineering DPIC

S. Burke Senior Staff Engineer

B. Chenard Engineering Director K. Connerton Operations E. Cota Maintenance DPIC

P. Couture Licensing Engineer

S. Das Senior Lead Engineer

B. Deacon Senior Maintenance Specialist M. Farrell Nuclear Control Technician M. Fichera I&C Technician

J. Freeman Lead Nuclear Control Technician

J. Gerety System Engineering Manager

B. Hannigan Equipment Reliability Coordinator E. Herbert I&C Superintendent C. Holstrom I&C Working Foreman S. Hudson System Engineer K. Kee Engineering Design Programs Supervisor N. Levesque I&C Technician J. Macdonald Operations Department Manager

A. Madeiras Design Engineering, Mechanical and Civil

D. Mannai Senior Manager Fleet Regulatory Affairs

E. McCaffrey System Engineer M. McDonald Shift Supervisor F. McGinnis Licensing Engineer

D. Miller Maintenance Coordinator

D. Noyes Director, Regulatory and Performance Improvement

J. O'Donnell NSSS Supervisor

J. Ohrenberger Senior Maintenance Manager P. O'Neil Contractor C. Perkins Manager, Regulatory Assurance

B. Rancourt Senior Lead Engineer

F. Russell Preventive Maintenance Engineer

J. Shumate Senior Manager, Production R. Swanson Balance of Plant Systems Manager S. Verrochi General Manager Plant Operations

J. Vertossa Chief Operating Officer Entergy Northeast

T. Wheble I&C Supervisor

T. White Design and Program Engineering Manager

M. Williams Nuclear Safety Licensing Specialist K. Woods Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened/Closed

05000293/2014008-03 FIN Parallel White Unplanned Scrams per 7000 Critical Hours PI

05000293/2014008-04 FIN Parallel White Unplanned Scrams with Complications PI Finding

Procedures 1.3.142, PNPS Risk Review and Disposition, Revision 0 1.3.142, PNPS Risk Review and Disposition, Revision 1

1.3.143, PNPS Accountability Model, Revision 1

1.3.144, Maintenance Performance of Trip Sensitive Activities, Revision 0

1.3.144, Maintenance Performance of Trip Sensitive Activities, Revision 1

1.3.144, Maintenance Performance of Trip Sensitive Activities, Revision 2

1.4.4, New England Power Grid Operations/Interfaces, Revision 26 1.5.22, Risk Assessment Process, Revision 24

2.1.14, Station Power Changes, Revision 112

2.1.37, Coastal Storm - Preparation and Actions, Revision 35

2.1.42, Operations during Severe Weather, Revision 20

2.2.1, 345 kV System, Revision 41

2.2.7, 480V AC System, Revision 32 2.2.31.1, Att. 8, Temporary Modification to Disable RFP Flow Switches while Performing Maintenance on TBCCW Heat Exchangers, Revision 15

2.4.150, Loss of Feedwater Heating, Revision 22

3.M.3-17.1, Raychem or Taping of 1000 Volt and Under Cables and/or Wires, Revision 17

3.M.3-33, 345kV Startup Transformer Calibration and Functional Relay Testing, Revision 33 3.M.3-51, Electrical Termination Procedure, Revision 20EN-DC-336, Plant Health Committee, Revision 8 3.M.3-71, Inspection and Maintenance of 345 kV Disconnects, Insulators, and Miscellaneous Switchyard Components, Revision 7 5.2.2, High Winds (Hurricane), Revision 35

5.2.3, Tornado, Revision 21 8.M.1-20, High Water Level Scram Discharge Tank Instrumentation Calibration/Functional Test Without Half Scrams - Critical Maintenance, Revision 73 8.M.2-1.5.3.1, Primary Containment Isolation Logic Channel Test - Channel A1 - Critical

Maintenance, Revision 23 EN-FAP-EP-010, Severe Weather Response, Revision 1 EN-FAP-EP-012, Severe Weather Recovery, Revision 0 EN-FAP-OM-020, Comprehensive Recovery Plans, Revision 0

EN-FAP-OU-104, Refueling Outage Scope Identification and Control, Revision 3

EN-FAP-OU-105, Refueling Outage Execution, Revision 3

EN-FAP-WM-002, Critical Evolutions, Revision 1

EN-HU-102, Human Performance Traps and Tools, Revision 13 EN-HU-104, Engineering Task Risk and Rigor, Revision 5 EN-HU-106, Procedure and Work Instruction Use and Adherence, Revision 3

EN-LI-102, Corrective Action Program, Revision 24 EN-LI-118, Cause Evaluation Process, Revision 20 and 21

EN-LI-118-01, Event and Causal Factor Charting, Revision 2 EN-LI-118-03, Barrier Analysis, Revision 1 EN-LI-118-06, Common Cause Analysis (CCA), Revision 4

EN-LI-118-08, Failure Modes Analysis, Revision 2

EN-LI-118-11, Why Staircase, Revision 0

EN-LI-121-, Trending and Performance Review Process, Revision 17

EN-MA-118, Foreign Material Exclusion, Revision 10 EN-NS-221, Security Organization, Standards, and Expectations, Revision 6

EN-OE-100, Operating Experience Program, Revision 21

EN-OE-100-02, Operating Experience Evaluations, Revision 1

EN-OP-111, Operational Decision-Making Issue (ODMI) Process, Revision 11 EN-OP-116, Infrequently Performed Tests or Evolutions, Revision 12 EN-OP-122, Operational Decision-Making Issue Precursor Process, Revision 0 EN-OU-103, Long Range Outage Planning, Revision 3

EN-PL-187, Safety Conscious Work Environment (SCWE) Policy, Revision 1

EN-PL-190, Maintaining a Strong Safety Culture, Revision 2

EN-TQ-104, Engineering Support Personnel Training Program, Revision 18 EN-TQ-127, Supervisor Training Program, Revision 14 EN-TQ-212, Conduct of Training and Qualification, Revision 13

EN-WM-101, On-Line Work Management Process, Revision 11

EN-WM-104, On-Line Risk Assessment, Revision 9

EN-WM-105, Planning, Revision 13

EN-WM-109, Scheduling, Revision 7 NOP98A1, Procedure Process, Revision 36 FFAM-CAA-DPIC, Job Familiarization Guide, Department Performance Improvement Coordinator (DPIC), Revision 4 W10112, Pilgrim Line Outage Risk Mitigation Procedure, Revision 0

Condition Reports (*denotes NRC identified during this inspection) CR-HQN-2014-0291 CR-PNP-2013-0798 CR-PNP-2013-5949 CR-PNP-2013-6298 CR-PNP-2014-6799 CR-PNP-2014-7830

CR-PNP-2015-0070 CR-PNP-2015-0558 CR-PNP-2015-0896

CR-PNP-2015-0897 CR-PNP-2015-1059 CR-PNP-2015-1148

CR-PNP-2015-0375 CR-PNP-2015-0715 CR-PNP-2015-3823 CR-PNP-2015-3613 CR-PNP-2015-4313* CR-PNP-2015-4319* CR-PNP-2015-4370* CR-PNP-2015-4461* CR-PNP-2015-4468*

CR-PNP-2015-4403* CR-PNP-2015-4405* CR-PNP-2015-4406*

CR-PNP-2015-4407* CR-PNP-2015-4409* CR-PNP-2015-4443*

CR-PNP-2015-4453* CR-PNP-2015-4455* CR-PNP-2015-4461* CR-PNP-2015-4473*

Work Orders 367142 381541 375495 375489

375497 375493 52499608

Learning Organization Documents

Miscellaneous FQC-EMT1-EMMTE, Maintenance and Test Equipment, training material

FLP-EMT1-EMMTE, Maintenance and Test Equipment, training lesson plan DPIC Meeting Agenda, dated February 24, 2015 PM Request PMRQ 16789 (AR187396187396

Condition Review Group Meeting Agenda, dated 05/06-7/2015

Corrective Action Program Recovery Performance Indicators

Entergy Operating Experience Point of Contact List - Pilgrim Performance Overview, Pilgrim Nuclear Power Station Pilgrim CAP Recovery Plan

Schedule for Plant Health Committee Review of Single Point Vulnerability Mitigating Strategies, as of 11/18/2014 Schedule for presentation of mitigating strategies related to single point vulnerabilities to Plant

Health Committee Maintenance Excellence Plan Procedure Review Checklist

Maintenance Procedure Review Requirements

PMQR 50076985-01 / 00029164-01

PNPS-FSAR, Section 8, Electrical Power System

PNPS Technical Specification 3.9, Auxiliary System

Drawings M1H20-4, Elementary Diagram Residual Heat Removal (RHR) System, Revision 9, Sheet 16

M1H10-10, Elementary Diagram RHR System, Revision 16, Sheet 6

M1H8-10, Elementary Diagram RHR System, Revision 20, Sheet 4 E415, Schematic Diagram Recirculation System, Revision 16 M1H9-12, Elementary Diagram RHR System, Revision 21, Sheet 5

M1H7-12, Elementary Diagram RHR System, Revision 21, Sheet 3

M1H5-1-15, Elementary Diagram RHR System, Revision 18, Sheet 1

M1H6-9, Elementary Diagram RHR System, Revision 19, Sheet 2

E112, Schematic Diagram RFP System, Revision 14

E115, Schematic Diagram RFP System, Revision 12, Sheet 1

E115, Schematic Diagram RFP System, Revision 4, Sheet 2

E1, Single Line Diagram Station, Revision 24, Sheet 1

SE155, Station Electrical Single Line Composite Diagram 4.16 kV & 480V AC, Revision 73, Sheet 2 SE155, Station Electrical Single Line Composite Diagram 4.16 kV & 480V AC, Revision 33, Sheet 3 SE155, Station Electrical Single Line Composite Diagram 4.16 kV & 480V AC, Revision 26, Sheet 4

LIST OF ACRONYMS

CAP corrective action program CRG condition review group DPIC Departmental Performance Improvement Coordinator

IMC Inspection Manual Chapter

IP Inspection Procedure

IR Inspection Report

kV kilovolt NRC U.S. Nuclear Regulatory Commission OEM original equipment manufacturer

PDC plant design change

PI performance indicator

PM preventive maintenance RCE root cause evaluation RFP reactor feed pump

SV solenoid valve

WO work order

IR 05000293/2015009: Difference between revisions

Revision as of 15:35, 18 August 2019

Text

Dear Mr. Dent:

Enclosure:

SUMMARY OF FINDINGS

Cornerstone: Initiating Events

Other Findings

REPORT DETAILS

OTHER ACTIVITIES

4OA4 Follow-Up Supplemental Inspection

.01 Inspection Scope

.02 Evaluation of the Inspection Requirements

b. Findings

e. Findings

4OA6 Exit Meeting

SUPPLEMENTAL INFORMATION

Licensee Personnel

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 {{Adams
-| number = ML15176A317
+| number = ML15169A946
-| issue date = 06/24/2015
+| issue date = 06/18/2015
-| title = LTR-15-0344 - Mary Lampert, Director, Pilgrim Watch, E-mail Request to Withdraw Nrc'S 95002 Supplemental Follow-Up Inspection Report 05000293/2015009 Issued June 18, 2015, and Issue a New Report
+| title = IR 05000293/2015009; 05/04/2015 - 05/08/2015; Pilgrim Nuclear Power Station (Pilgrim); Follow-up Supplemental Inspection - Inspection Procedure (IP) 95002
-| author name = Lampert M
+| author name = Nieh H
-| author affiliation = Pilgrim Watch
+| author affiliation = NRC/RGN-I/DRP
-| addressee name = Dean B
+| addressee name = Dent J
-| addressee affiliation = NRC/NRR
+| addressee affiliation = Entergy Nuclear Operations, Inc
 | docket = 05000293
 | license number = DPR-035
-| contact person = Guzman R
+| contact person = McKinley R
-| case reference number = 2.206, LTR-15-0344
+| document report number = IR 2015009
-| package number = ML15176A318
+| document type = Inspection Report, Letter
-| document type = E-Mail
+| page count = 19
-| page count = 24
 }}
@@ Line 19: / Line 18: @@
 =Text=
-{{#Wiki_filter:NRCExecSec Resource From: Sent: To: Cc: Subject: Attachments:
+{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 June 18, 2015 Mr. John Dent Site Vice President Entergy Nuclear Operations, Inc.
-Hello: Mary Lampert <mary.lampert@comcast.net>
-Wednesday , June 24, 2015 10:44 AM Dean , Bill Nieh, Ho; McKinley, Raymond; NRCE x ecSec Resource Pilgrim Watch and organizations listed request that NRC's 95002 Supplemental FollowUp Inspection report 05000293/2015009 issued June 18 , 2015 withdrawn and new report issued COMMENT NRC 06.18.15 PNPS SUP INSP REPORT 06.24.15.pdf; 2 206 PETITION EMERGENCY PLANNING PW CAPE DOWNWINDERS 06 .03.15.pdf Please find attached Pilgrim Watch and organizations listed request that NRC's 95002 Supplemental Follow-Up Inspection report 05000293/2015009 issued June 18, 2015 is withdrawn and a new report issued. If you have trouble downloading the attachments, please call Mary Lampert at 781-934-0389. Courtesy of receipt by return email appreciated.
-Thank you and enjoy the day. Mary 1 William Dean Ho Nieh Raymond McKinley US NRC Via Email June 24, 2015 RE: PILGRIM NUCLEAR POWER STATION - NRC 95002 SUPPLEMENTAL FOLLOW-UP INSPECTION REPORT 05000293/2015009 (June 18, 2015) Pilgrim Watch and organizations listed below request -Up Inspection report 05000293/2015009 issued June 18, 2015 is withdrawn and a new report issued. Our reasons are as follows: Report Is Self-Contradictory and Makes No Sense For example towards the bottom of page (7) there are two sentences back to back that say: 1. Activities to perform the effectiveness reviews were already assigned in CR-PNP-2013-0798 but were not completed. 2. The inspectors determined that the incomplete effectiveness review was completed with supportable conclusions. The first sentence says that the effectiveness reviews were not completed; the second sentence says that the incomplete effective review was completed. Therefore it is unclear if whether the effectiveness review is complete or incomplete. In the second sentence, the NRC wrote The CAP Situation Described on Page 5-6 is Inconsistent The NRC said that RCE CR-PNP-2013-5939 did not identify a root or contributing cause. The bottom of page 5 records two additional NRC concerns with the condition report (CR) and its root cause evaluation (RCE).
+Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
-The top of page 6 indicates that Entergy responded to the NRC's many problems with its corrective action process (CAP) by entering CR-PNP-2015-04443 into the CAP. The NRC conducts a supplemental follow-up inspection into previous findings of a deficient Corrective Action Process, identifies even more deficiencies, and dismisses them because Entergy entered them into the known-to-be-broken-and-now-verified-not-to-be-fixed Corrective Action Process. This does not look like regulatory oversight. NRC provides No Information to Assure are either real or timely Icing in Switchyard: The report says that Entergy plans to address the icing in the switchyard with portable heaters, pressure washing and /or manual brushing. Regarding the heaters: The report fails to say whether Entergy is buying more heaters; and if so will there be a sufficient number and whether the plan to store them are in locations that they can be brought to the yard in a time effective manner in a severe winter storm; or, are they dragging the heater(s) around and refreezing behind it? How many heaters does the NRC feel are sufficient to avoid re-freezing? Has NRC analyzed the storage location of the heaters and time required under harsh conditions to transport the heaters to location? Regarding Power Washing: There is no explanation how power washing avoids re-freezing. If heaters are the answer; again, how many are required? Where is the water to power wash coming from? What assurance does NRC have that the power washing equipment and personnel can get to location in a severe winter storm, like Juno? Brushing: How can the NRC assure energized lines will not be mistakenly brushed by Entergy workers manually brushing lines in the switchyard? What assurance does NRC have that the personnel can get to location in a severe winter storm, like Juno?
+SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC 95002 SUPPLEMENTAL FOLLOW-UP INSPECTION REPORT 05000293/2015009
-Commenters conclude that the real solution is to enclose the switchyard. The switchyard faces northeast, into the eye of the storm, and the surrounding hills channel the wind and spray into it. Insulator Service Life Issue Although the report says that the Doble Engineering, the testing company, said that the insulator expected service life was (30) years and therefore all insulators should be tested, Entergy decided not to follow its advice and got into trouble. The Supplemental Report says that Entergy will test them all by 2016. We see this as a lack of commitment for not doing testing in the first place (money); a relaxed schedule to finally get it done; and invitation by the NRC to the industry to run equipment to failure. The NRC and its Office of Inspector General (OIG) both chronicled this problem. David Lochbaum, Union of Concerned Scientists, blogged about it ( http://allthingsnuclear.org/nuclear-plants-and-nuclear-excuses-this-is-getting-old/) and outlined how the NRC and its OIG found that some owners replace components before the service lifetimes while other owners run equipment to failure. While NRC prefers the former, they don't sanction the latter. Bottom line - NRC inaction is driving more and more owners toward bad behavior.. Lochbaum concludes that the NRC seems pleased to allow the practice to continue until it kills someone, and then use those deaths to ask the industry to change its ways. Report Again Ignores Emergency Planning during JUNO - No Reasonable Assurance The January 27, 2015 Winter Storm Juno resulted in significant problems at Pilgrim Nuclear Power Station. The storm itself caused a Loss of the Offsite Power (LOOP) that is required to lowed by numerous equipment and operator failures at the reactor.1 The Scram occurred on January 27 at 04:02 and the HPSI was declared inoperable at 09:48. But on January 26 at 12:55, Governor Baker announced a state of emergency and travel ban. (See Attachment A to the attached 2.206 Petition) The NRC did not require Pilgrim to shut down, as it should have. It was apparent that there was no reasonable    1 Subject: Pilgrim Nuclear Power Station NRC Special Inspection Report 05000293/2015007; and Preliminary White Finding, May 27,2015 4 assurance regarding emergency planning. The attached 2.206 Enforcement Petition shows that the NRC shifted responsibility to FEMA and MEMA saying that they informed the NRC that there was reasonable assurance that the state was capable of implementing its emergency plan, including evacuation. Who is not telling the truth NRC, FEMA and/or MEMA? There is no shifting responsibility. The buck stops with the NRC and no one would believe that NRC R Therefore, the NRC should amend its May 27, 2015 Inspection Report and the June 18, 2015 Supplemental Report to explicitly state that during Juno there was no reasonable assurance that the State was capable of implementing their emergency plan, including evacuation. Pilgrim was out-of-compliance by continuing to operate after the Governorpractical purposes should have voluntarily shut down as a precautionary measure before. We ROP. Thank you for your consideration; we respectfully request a response to issues raised. Mary Lampert Pilgrim Watch, Director 148 Washington Street - Duxbury, MA 02332 Tel 781-934-0389/ Email: mary.lampert@comcast.net Karen Vale Jones River Watershed Association 55 Landing Road, Kingston, MA 02364, Tel 781-585-2322/ Email: karen@capecodbaywatch.org Diane Turco, Cape Downwinders/MA Downwinders 157 Long Road, Harwich, MA 02645 Tel 508-776-3132/tturco@comcast.net Rebecca Chin Co-Chair Town of Duxbury Nuclear Advisory Committee 31 Deerpath Trail, North-Duxbury, MA 02332 Tel. 781-837-0009 /Email: rebeccajchin@hotmail.com Heather Lightner & Norm Pierce Concerned Neighbors of Pilgrim 54 Settlers Road, Plymouth, MA 02360 Tel. 401-578-4189/Email: heather@concernedneighborsofpilgrim.org June 11, 2015 Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 By Mail & Email: NrcExecSec@nrc.gov PILGRIM WATCH, CAPE DOWNWINDERS AND THE TOWN OF DUXBURY NUCLEAR MATTERS COMMITTEE 2.206 PETITION TO MODIFY, SUSPEND, OR TAKE ANY OTHER ACTION TO THE OPERATING LICENSE OF PILGRIM STATION UNTIL THE NRC CAN PROVIDE REASONABLE ASSURANCE THAT ADEQUATE PROTECTIVE MEASURES BASED ON ACCURATE INFORMATION CAN AND WILL BE TAKEN TO SATISFY OBLIGATION TO PROTECT PUBLIC HEALTH & SAFETY I. INTRODUCTION Pursuant to &sect;2.206 of Title 10 the Code of Federal Regulations, Pilgrim Watch (Hereafter and Cape ), on behalf of their members, and the Town of request that the Nuclear Regulatory Commission (NRC) institute a proceeding to modify, suspend or take any other action1 as may be proper and necessary relative to the operating license of Pilgrim Station and -party information in order that the NRC can provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Pilgrim Station. During the January 27, 2015 winter storm Juno that resulted in a LOOP followed by equipment and operator failures at Pilgrim, 2 FEMA and MEMA falsely informed the NRC that there was reasonable assurance that the state was capable of implementing its emergency plan, including    1 NRC Enforcement actions include: notices of violation, civil penalties, orders, notice of nonconformance, confirmatory action letters, letters of reprimand, and demand for action. 2 Subject: Pilgrim Nuclear Power Station NRC Special Inspection Report 05000293/2015007; and Preliminary White Finding, May 27,2015 2 evacuation. The NRC relied on this false information. Because it did so, the NRC, on which ultimate responsibility rests, was not able to perform its mission to ensure adequate protective actions are in place to protect the health and safety of the public in the event of a radiological emergency. g the storm event. The NRC has already determined that Pilgrim is a troubled plant that requires far more Emergency Plan and Procedures provide reasonable assurance, particularly in severe weather or in the event of yet another Pilgrim personnel or equipment failure, NRC needs to send its own with the local emergency management directors, department heads, and public not simply with Entergy, FEMA and MEMA. II. Petitioners Pilgrim Watch and Cape Downwinders are environmental, public health and safety organizations with members who are concerned that current NRC emergency planning requirements are not adequate to protect their health and safety in the event of an accident at the plant. 02332. Duxbury is within the Pilgrim 10-mile EPZ. Its membership extends throughout the Commonwealth. Cape Downwinders membership extends throughout the Commonwealth with the majority of its members on Cape Cod. Cape Cod is connected to the mainland by two bridges, closed to outgoing traffic in a radiological emergency. Often it is downwind from 3 Pilgrim Station. The Town of Duxbury Nuclear Advisory Committee is appointed by the Duxbury Board of Selectmen to review radiological emergency plans and procedures and other issues at Pilgrim that impact the town. Duxbury is in the Pilgrim EPZ. III. FACTS IN SUPPORT OF THE PETITION A. Agency Roles and Responsibilities in Emergency Planning:3 A key component of the mission is to ensure that adequate protective actions are in place to protect the health and safety of the public. Protective actions are taken to avoid or reduce radiation dose and are sometimes referred to as protective measures. responsibility is to evaluate if nuclear plant offsite emergency plans are adequate to protect public health and safety actions are in place. State and local governments implement appropriate protective actions for the public during a nuclear power plant radiological emergency. The NRC relies on the Federal Emergency Management Agency (FEMA or DHS) and the Massachusetts Emergency Management Agency (MEMA) routes, is adequate for eryl Khan to Diane Turco, Attachment 1) B. NRC , FEMA and MEMA Failures of Responsibility In a February 2, 2015 letter to the NRC, Cape Downwinders, Pilgrim Coalition, Cape Cod Bay Watch and Concerned Neighbors of Pilgrim requested that Pilgrim be kept shut down during a    3 See http://www.nrc.gov/about-nrc/emerg-preparedness/protect-public.html 4 severe winter storm due to an inability to implement emergency response plans, if needed, during events such as the January, 2015 winter storm. Carol Khan, an NRC Senior Project Engineer, responded to that letter on March 30, 2015 (Attachment 1). Ms. Kshows that FEMA and Massachusetts Emergency Management Agency (MEMA) provided the NRC with false statements assuring NRC that there was reasonable assurance that the state was capable of implementing its emergency plan, including evacuation, based upon their consultation with emergency management agencies within the 10 mile EPZ. Specifically Ms. Khan said at 2 (email attached) that: During the recent Massachusetts snow storms, the NRC was in continuous contact with FEMA and the Massachusetts Emergency Management Agency (MEMA). In consultation with town emergency management agencies within the 10 mile EPZ, the State and FEMA provided the NRC a reasonable assurance finding that the State was capable of implementing their emergency plan, including evacuation. The indisputable fact is that there was no such direct readiness, and that MEMA knew the state was not plan, including evacuation. A state-wide travel ban was in effect. As shown by Attachment B, Massachusetts Gov. Charlie Baker had declared a state of emergency, including a travel ban, in the Commonwealth of Massachusetts due to Winter Storm Juno. In his televised announcement, The Governor said: White-out conditions and treacherous roads will make driving anywhere extremely dangerous I repeat, driving will be virtually impossible in many areas for extended periods starting late tonight and through much of tomorrow. I can't stress this part enough. Please stay off the roads. Everyone should expect impassable roads across the state. We are also preparing for major coastal flooding along our entire coastline. High tide is conveniently coming at about 4 a.m. in most places, which will be right at the peak of the 5 storm and the threat of coastal flooding is very real. We can see damage to coastal roads as well. It's extremely important that everyone stay off the roads. We have declared a state of emergency effective immediately. We will implement a state wide travel ban. He announced the state of emergency at a press conference held at Massachusetts Emergency Management Agency (MEMA) headquarters in Framingham. Does anyone really believe that MEMA, FEMA and NRC did not know this? MEMA Spokesperson discusses travel ban during storm Which agency(s) is not telling the truth - NRC, FEMA, or MEMA? During the storm event, neither FEMA nor MEMA directly contacted Emergency Management Director (EMD) Had they done so, the Duxbury EMD would have told them that during the particularly severe weather event there was no reasonable assurance that Duxbury could implement its emergency evacuation plan.
-evacuation component of the plan due to the snow amounts. After Cape Downwinders received Ms. KMr. William Mauer, a member of Cape Downwinders and Pilgrim CoalitionDirector, Chief Kevin Nord, if FEMA or MEMA had contacted him for consultation during Juno informing him of events unfolding at Pilgrim and asking him of his assessment/assurance of evacuation. response flatly contradicted Ms. Khan. He said in conference calls with Entergy, It was stated clearly that the days following the storm that Duxbury could not implement its evacuation component of the He also said that if he had been capability in the days leading up to the storm, plan From: "Chief Kevin M. Nord" <nord@town.duxbury.ma.us> To: "William Maurer" <wmmaurer@comcast.net> Cc: "Aaron Wallace" <awallace@townhall.plymouth.ma.us> Sent: Thursday, May 28, 2015 7:57:54 AM Subject: RE: Pilgrim: Storm Juno
+==Dear Mr. Dent:==
+On May 8, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a follow-up supplemental inspection in accordance with Inspection Procedure (IP) 95002, "Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area," at your Pilgrim Nuclear Power Station (Pilgrim). Specifically, Pilgrim experienced four reactor scrams in 2013 which resulted in two performance indicators (PIs) in the Initiating Events cornerstone, Unplanned Scrams per 7000 Critical Hours and Unplanned Scrams with Complications, crossing the threshold from Green to White. The enclosed inspection report documents the inspection results, which were discussed on May 8, 2015, with you and other members of your staff.
-==Dear Mr. Maurer,==
+The NRC previously completed a supplemental inspecti on in December 2014 to review your actions to address the White PIs. Inspection results are documented in NRC Inspection Report 05000293/2014008, dated January 26, 2015 (Reference ML15026A069). At that time, the NRC staff determined Entergy's actions to address the two White PIs were not sufficient and that collectively, the issues represented a significant weakness as described in NRC IP 95002. Accordingly, the NRC assigned two parallel White PI inspection findings and identified the need to complete an additional inspection after Entergy staff had addressed the extent of condition concerns, made sufficient progress on the improvements to the corrective action program (CAP), and informed the NRC staff of their readiness for further inspection.
-In response to your two questions as listed below I have the following information. Did MEMA and/or FEMA or anyone for that matter contact you for consultation during Juno informing you of the events unfolding at Pilgrim (precautionary powering down, then LOOP then emergency shutdown); and for an assessment/assurance of your ability to implement Pilgrim emergency plans, including evacuation? Entergy did inform Duxbury of the LOOP and Emergency shutdown and following calls varied between one and two times a day with the culmination of preparing to 7 repower and reviewing their assessment benchmarks for the ability of communities to meet their obligation regarding the RERP. It was stated clearly that the days following the storm that Duxbury could not implement its evacuation component of the plan due to the snow amounts. Additionally, I have no recall or evidence that Entergy reached out to Duxbury in the days leading up to the storm or leading up to the emergency, as if they had I would have reported that during that particular weather event I as not have reasonable assurance I could implement the plan during that snow event. I hope this helps. (Emphasis added) The statements in Ms. Khare flatly contradicted by Chief Nord. Reporting what the NRC had been told by FEMA and MEMA, Ms. Khan In consultation with town emergency management agencies within the 10 mile EPZ, the State and FEMA provided the NRC a reasonable assurance finding that the State was capable of implementing their emergency plan, including evacuation Chief Nord, EMD Duxbury, said that Duxbury could not implement its evacuation component of the plan due to the snow amounts (and) during that particular weather reasonable assurance I could implement the plan during that snow event In short, FEMA and MEMA failed to do what they were supposed to do. They compounded their failure by falsely telling (or at best inexcusably misleading) the NRC that despite Juno, State was capable of implementing their emergency plan, including evacuation The NRC then relied on false information given it by FEMA and MEMA, and without making any independent inquiry (or apparently even listening to the weather news or reading Boston-areas newspapers), blithely concluded that Duxbury could be evacuated according to plan despite the storm.
-The inescapable conclusion from the actual facts is that the public did not have reasonable assurance during the January 27 storm. This fact is underscored by State Senator Daniel Wolf and State Representative Sarah Peake in a June 1, 2015 letter to Undersecretary and Homeland Security and Emergency Management Director Kurt Swartz that said: There is consensus that such evacuation plans could not be implemented during serious storm events, including even moderate snowfalls. Therefore, MEMA should direct the nuclear power station to power down and go offline during any meteorological event that makes evacuation infeasible or impossible. Obviously, any time state government institutes travel bans or travel restrictions for Southeastern Massachusetts, this should apply. In addition, should travel conditions significantly reduce speed, visibility, and road quality, this directive should be implemented. MEMA should create a clear policy as to when and how this order would be issued. Implementing this policy is not suggesting that every significant storm would create a public safety issue at Pilgrim. It is acknowledging that if any public safety issue did arise during such an event, either related to weather or coincidental, MEMA would not be able to implement the evacuation and emergency response procedures it is required to have in place. (Attachment C) Petitioners appreciate that MEMA does not have the authority to order Pilgrim shut during any meteorological event that makes evacuation infeasible or impossibleNRC does have the authority and should do so. In addition, the Pilgrim Nuclear Power Station NRC Special Inspection Report 05000293/2015007; and Preliminary White Finding, May 27, 2015 Inspection Report requires an amendment to state the fact that there was no reasonable assurance. Neither the public nor the NRC can assume that this is the only time that FEMA and MEMA have provided false or intentionally misleading information to NRC regarding the adequacy of Radiological Emergency Plan and Procedures. Misinformation is likely to result in NRC incorrectly determining that the radiological emergency plan and procedures provide reasonable assurance when in fact they do not. Neither the public nor NRC now has any reason to trust the assessments of either FEMA or 9 MEMA, or NRC decisions that rely on any information from either. These facts lead to three conclusions: 1. Emergency plans in winter storms conditions cannot ensure adequate protective actions are in place to protect the health and safety of the public. To believe otherwise would be basing that assessment on patently false information from FEMA and MEMA. In order to provide reasonable assurance in winter storm conditions Pilgrim Station must be required via a license amendment to shutdown, as a precautionary measure. The Juno event proved conclusively that evacuation is not possible in a severe winter storm. Severe storms are not a one-time event. Winter storms are increasing in frequency and severity due to climate change; history has shown that Pilgrimfailures during storms and successful corrective actions are yet to be devised. 2. The NRC must add the fact that there was no reaso2015 Inspection Report for the record. 3. plan, including the availability of evacuation routes, protects public health and safety. The information FEMA and MEMA provide to the NRC must accurately reflect reality. When, as during Juno, the NRC is given and relies on false information, the NRC cannot perform its mission and take necessary protective actions. The NRC bears the ultimate responsibility to protect the health and safety of the public. 4. There is no basis for the NRC or the public adequate 10 protective actions to protect the health and safety of the public. IV. WHAT SHOULD BE DONE 1. The NRC should send a team to Pilgrim and itself reevaluate the adequacy of the plan and procedures, in consultation with the local emergency management directors, department untrustworthy. to Pilgrim and itself revieto ensure adequate protective actions are in place to protect the health and safety of the public. 2. The NRC should investigate the failure of FEMA and MEMA to provide correct information relative to evacuation during Juno; and take all steps necessary to insure that FEMA, MEMA and Entergy recognize the importance of providing complete and accurate information, and will do so in the future. 3. The NRC should require, by agreement or amendment of its operating license, that Pilgrim make a precautionary shut down when severe weather conditions are forecast or present. 4. The NRC should amend its May 27, 2015 Inspection Report to explicitly state that during Juno there was no reasonable assurance that the State was capable of implementing their emergency plan, including evacuation. V. CONCLUSION mission of the NRC is to ensure adequate protective actions are in place to protect the health and 11 safety of the public. Protective actions are taken to avoid or reduce radiation dose and are The petitioners have shown that adequate protective measures were not in place during winter storm Juno, the May 27, 2015 NRC Inspection Report needs to be corrected to reflect that fact; FEMA and MEMA provided false information to NRC saying that adequate plans were in place; and because FEMA and MEMA showed that their assessments cannot be trusted, NRC must Radiological Emergency Plan and Procedures to ensure adequate protective measures are in place. With one possible exception, the NRC had not granted a section 2.206 petitioner the substantive relief it sought for at least 37 years. Judge Rosenthal of the ASLB accurately said that, truly substantive relief is being sought (i.e., some affirmative administrative action taken with respect to the licensee or license), there should be no room for a belief on the r that the pursuit of such a course is either being encouraged by Commission officialdom or has a fair chance of success."4 We truly hope that Judge Rosenthal will be proven wrong and this petition will be granted. Respectfully submitted on June 11, 2015, Mary Lampert Pilgrim Watch, Director 148 Washington Street - Duxbury, MA 02332 Tel 781-934-0389/ Email: mary.lampert@comcast.net William Maurer Cape Downwinders 140 Gifford Street -Falmouth, MA 02540 Tel. 508-548-6221/Email: wmmaurer@comcast.net    4 Memorandum And Order (Denying Petitions For Hearing), LBP-12-14, July 10, 2012, Additional Comments of -12-05-/12-51)
+The objectives of this follow-up supplemental inspection were to verify that Entergy addressed the deficiencies which resulted in the assignment of two parallel White PI inspection findings in NRC Inspection Report 05000293/2014008. Specifically, this inspection was performed to verify that Entergy has: (1) assessed the independent failure analysis of the faulted 345kV electrical switchyard insulators for potential impact to the root cause evaluation (RCE) and revised as appropriate; (2) assessed the revised RCE for the February 8, 2013 winter storm station impact and associated reactor scram, to include additional actions for the incomplete initial effectiveness review; (3) evaluated the effectiveness of additional maintenance department human performance related corrective actions implemented during the inspection through in-progress and completed work; (4) completed the evaluation of the cause(s) for the failed electrical cable splice that resulted in a loss of all three reactor feedwater pumps and has revised the RCE to include additional corrective actions, if appropriate; and (5) evaluated the revisions to the RCEs for the overall common cause evaluation, which included taking action to understand why corrective actions intended to address the identified CAP implementation weakness were not effective at ensuring the inspection objectives were satisfied. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The inspectors completed their onsite reviews on May 8, 2015.
-Diane Turco Cape Downwinders 157 Long Road -Harwich, MA 02645 Tel 508-776-3132/Email: tturco@comcast.net Rebecca Chin Co-Chair Town of Duxbury Nuclear Advisory Committee 31 Deerpath Trail, North-Duxbury, MA 02332 Tel. 781-837-0009/Email: rebeccajchin@hotmail.com 13 ATTACHMENT A From: "Khan, Cheryl" <Cheryl.Khan@nrc.gov> Date: March 30, 2015 10:36:31 AM EDT To: "Diane Turco (tturco@comcast.net)" <tturco@comcast.net> Cc: "McKinley, Raymond" <Raymond.McKinley@nrc.gov> Subject: FW: Pilgrim Response Ms. Turco, Email. So, I am resending it to ensure you receive our response to your original Email. Regards, Cheryl Khan From: Khan, Cheryl Sent: Thursday, March 19, 2015 4:03 PM To: 'Diane Turco' Cc: McKinley, Raymond Subject: Pilgrim Response Cape Downwinders Pilgrim Coalition Cape Code Bay Watch Concerned Neighbors of Plymouth
-==Dear Ms. Turco:==
+The NRC determined that Pilgrim's extent of condition reviews and corrective actions related to the original four root causes were sufficient and appropriate to address the identified significant weakness as documented in Supplemental Inspection Report 05000293/2014008. Additionally, no findings of significance were identified as a result of this inspection. Based upon the collective results of this inspection and Supplemental Inspection Report 05000293/2014008, the NRC determined the inspection objectives of IP 95002 have been satisfied.
-I am responding to your February 2, 2015, emailed letter to Mr. Stephen Burns, NRC Chairman, Mr. Raymond McKinley, Branch Chief in the Region I Division of Reactor Projects and Mr. Neil Sheehan, Public Affairs Officer in Region I, requesting that Pilgrim be kept shut down based on issues discussed in your letter. This letter was sent on behalf of the four named groups above. Your letter discussed, in part, a January 26, 2015, NRC inspection report as well as the events surrounding the January 27, 2015, Pilgrim shutdown during a severe winter storm. decision making process for our oversight of licensee performance is in accordance with the Reactor Oversight Process (ROP) as described in NRC Inspection http://pbadupws.nrc.gov/docs/ML1419/ML14198A117.pdf Prior to issuance of the January 26, 2015, inspection report, Pilgrim was in the Degraded Cornerstone of the IMC 0305 Action Matrix due to two White performance indicators (PIs) in the Initiating Events cornerstone. As a result, a supplemental inspection was performed in late 2014 and the results of this inspection were documented in the January 26 inspection report. The and corrective action plans for the White PIs were adequate. However, they identified understanding of some of the causes of the issues. As a result, the inspectors determined el required to meet all the inspection objectives and the NRC assigned two parallel White PI inspection findings. In addition, two 14 findings of very low safety significance (Green) were identified during this inspection. The two parallel White PI inspection findings led to Pilgrim remaining in the Degraded Cornerstone of the Action Matrix as documented in the January 26 inspection report. This condition (i.e., two White inspection findings in the same cornerstone) warrants continued increased NRC oversight since licensee performance is outside the normal performance range, but still represents an acceptable level of performance. Cornerstone objectives are still met with minimal reduction in safety margin. This condition does not lead to an indicated need for the plant to remain shut down. The NRC will resume the supplemental inspection at Pilgrim when the licensee notifies the NRC of their readiness. In addition, the NRC will address challenges in corrective action program (CAP) implementation during the next NRC biennial problem identification and resolution inspection, scheduled for August 2015. Your February 2, 2015, letter also discussed the January 27, 2015, plant shutdown and equipment issues experienced during the shutdown, including the partial loss of offsite power. As a result of this shutdown and related equipment issues, the NRC launched a special inspection on February 2. The event and related issues are being evaluated and the results of the NRC inspection will be made publicly available within 45 days of the i factored Appropriate followup actions will be determined at that time. Please keep in mind that although equipment issues were experienced during the shutdown, the reactor was safely shut down. severe winter storm. All nuclear power plants have procedures that dictate how they have to respond to a significant storm. For example, limits on wind Technical Specifications do not contain explicit limits with respect to wind speed, but the operability of the associated systems can be impacted by external events which may require a plant shutdown. Prior to the winter storm, the licensee evaluated a number of options including a preemptive shutdown. There was potential for reduced grid reliability associated with shutting down preemptively, and there was a plant trip risk associated with operating during the storm. The licensee evaluated their options and made an informed decision. The decision to continue to operate was within the conditions of their license. We were aware of their considerations. During a subsequent storm, in February 2015, the licensee factored in additional considerations based on lessons learned from the earlier winter storm. In this case, they voluntarily decided to shut down before the storm. It was not an action sought or required by the NRC. With that said, given the forecast intensity of this particular storm, and in light of other challenges Pilgrim has experienced during the prior severe winter storm, this planned and orderly shutdown in advance of the approaching blizzard was a prudent precautionary action. You identified a concern with the ability to implement the emergency response plans, if needed, during the January winter storm. The NRC works in partnership with the Federal Emergency Management Agency (FEMA) for ensuring the onsite and offsite emergency plans are adequate. The regulation of onsite emergency response falls 15 FEMA. The Commonwealth of Massachusetts has the overall authority for making protective action decisions (sheltering, evacuation, etc.) for ensuring the safety of their public during a radiological event. Should at any time there be a potential challenge to the offsite infrastructure within the 10 mile emergency planning zone (EPZ), whether in a radiological or natural disaster (e.g. severe weather event), the NRC relies on FEMA in agreement with the plan, including the availability of evacuation routes, is adequate for protecting the public health and safety. During the recent Massachusetts snow storms, the NRC was in continuous contact with FEMA and the Massachusetts Emergency Management Agency (MEMA). In consultation with town emergency management agencies within the 10 mile EPZ, the State and FEMA provided the NRC a reasonable assurance finding that the State was capable of implementing their emergency plan, including evacuation. For additional ning the adequacy of the EPZ, you may contact the Massachusetts Emergency Management Agency at (508) 8202000. (Emphasis added) was recently submitted to the NRC, the NRC intends to continue with the established process and not delay the Pilgrim. The information available to the NRC indicates Entergy has been responding 2012, Request for Information and associated guidance regarding its flooding reanalysis. The JWRA information that was submitted to the NRC was forwarded to the technical and project management staff who will be reviewing RC staff identifies any technical inadequacies or regulatory concerns in its will address them through appropriate regulatory processes. Also, in response to one of your questions, during the winter storm in January, there was no impact to the site from storm surge and wave action. Lastly, with respect to your questions associated with the FLEX plan, the NRC review and evaluation of ou raised in your letter will be forwarded to the technical submittal. Thank you for making us aware of your concerns. If you have any additional questions, please contact Ray McKinley (Raymond.McKinley@nrc.gov Cheryl Khan ***************** Cheryl Khan Senior Project Engineer US Nuclear Regulatory Commission RI/DRP/TSAB Cheryl.khan@nrc.gov 6103375244 16 ATTACHMENT B HTTP://WWW.WCVB.COM/WEATHER/STATE-OF-EMERGENCY-IN-EFFECT-TRAVEL-BAN-IMPOSED/30924606 VIDEO TRANSCRIPT NOW THE GOVERNOR IS ADDRESSING THE STATE FROM FRAMINGHAM AND LET'S LISTEN IN. YESTERDAY MORNING OUR ADMINISTRATION HAS BEEN IN TOUCH WITH THE NATIONAL WEATHER SERVICE, AND THE MASS EMERGENCY AGENCY AND LOCAL OFFICIALS, THE SOMEPLACE AND WITH MEMBERS OF OUR CABINET TO PREPARE FOR THIS STORM. BASED ON DEPENDABLE FORECASTING MODELS, THE COMMONWEALTH WILL EXPERIENCE EXTREME SNOWFALL, HURRICANE FORCE WINDS, AND BLIZZARD CONDITIONS FOR A N EXTENDED PERIOD OF TIME. WE ARE ANTICIPATING A HISTORIC TOP FIVE STORM BASED ON PROJECTED SNOWFALL. THE STORM WILL RESULT IN WIDESPREAD POWER OUTAGES THAT MAY EXIST FOR MULTIPLE DAYS DUE TO THE HARD WIND, WHICH IN MANY CASES WILL PREVENT UTILITY CREWS FROM OPERATING. AND THE OUTAGES ARE LIKELY T O BE WORSE IN PLYMOUTH, BRISTOL, AND BARNSTABLE COUNTIES DUE TO WETTER SNOW AND THE HIGH WINDS THAT THEY EXPECT TO HAVE THERE. WITH RESPECT TO THE SNOW ITSELF, WHITE-OUT CONDITIONS AND TREACHEROUS ROADS WILL MAKE DRIVING ANYWHERE EXTREMELY DANGEROUS STARTING AROUND MIDNIGHT TONIGHT AND EXTENDING THROUGH MOST OF TUESDAY. I REPEAT, DRIVING WILL BE VIRTUALLY IMPOSSIBLE IN MANY AREAS FOR EXTENDED PERIODS STARTING LATE TONIGHT AND THROUGH MUCH OF TOMORROW. I URGE EVERYONE EXCEPT ESSENTIAL MEDICAL EMERGENCY AND TRANSPORTATION WORKERS TO STAY OFF THE ROADS 17 UNTIL THE SNOW HAS PASSED. I CAN'T [ST]RESS THIS PART ENOUGH. PLEASE STAY OFF THE ROADS. EVERYONE SHOULD EXPECT IMPASSABLE ROA DS ACROSS THE STATE STARTING AT AROUND MIDNIGHT TONIGHT AND THROUGH MUCH OF TUESDAY. WE ARE ALSO PREPARING FOR MAJOR COASTAL FLOODING ALONG OUR ENTIRE COASTLINE. HIGH TIDE IS CONVENIENTLY COMING AT ABOUT 4 A.M. IN MOST PLACES, WHICH WILL BE RIGHT AT THE PEAK OF THE STORM AND THE THREAT OF COASTAL FLOODING IS VERY REAL. WE CAN SEE DAMAGE TO COASTAL ROADS AS WELL AND STRUCTURES ALONG THE COAST AND I URGE EVERYONE TO TAKE THE NECES SARY PRECAUTIONS IN LOW LYING COASTAL AREAS. SOME PLACES COULD EXPER IENCE 75 MILE AN HOUR GUSTS, OTHER PLACES 50 TO 60 MILE PER HOUR WINDS ON A SUSTAINED BASIS. THIS WILL TAKE DOWN TREES, AFFECT POWER LINES, AND MAKE DRIVING TREACHEROUS. IT'S EXTRE MELY IMPORTANT THAT EVERYONE STAY OFF THE ROADS. TODAY I AM AN NOUNCING THE FOLLOWING ACTIONS AND WILL GO INTO FURTHER DETAIL ABOUT EACH INITIATIVE. WE HAVE DECLARED A STATE OF EMERGENCY EFFECTIVE IMMEDIATELY. WE WILL IMPLEMENT A STATE WIDE TRAVEL BAN EFFECTIVE TONIGHT AT MIDNIGHT. ON TUESDAY, ALLSTATE OFFICES, BUT NOT ALLSTATE FACILITIES WILL BE CLOSED. THE MBTA WILL OPERATE ON A NORMAL SCHEDULE FOR THE REST OF THE DAY TODAY AND ON TUESDAY WE WILL ALSO BE CLOSED. ADDITIONALLY,LL ALSO BE CLOSED. ADDITIONALLY, I'LL ADDRESS THE FOLLOWING. DEPLOYING THE NATIONAL GUARD, THE MEMA SETUP. (Emphasis added) MEMA spokesperson discusses travel ban during storm ... www.myfoxboston.com/.../MEMA%20spokesperson%20discusses%... WFXT MEMA spokesperson discusses travel ban during storm. http://www.myfoxboston.com/clip/8342098/MEMA%20spokesperson%20discusses%20travel%20ban%20during%20storm 18 ATTACHMENT C 19
+Because the objectives of IP 95002 were satisfied, the two parallel White findings assigned in the December 2014 IP 95002 supplemental inspection will be considered closed at the end of the second quarter 2015. On May 27, 2015, the NRC issued Special Inspection Report 05000293/2015007, which was associated with the January 27, 2015 partial loss of offsite power event (ADAMS Accession Number ML15147A412). The special inspection report documented a preliminary White finding associated with Entergy's inadequate identification, evaluation, and correction of the 'A' safety/relief valve (SRV) failure to open upon manual actuation during a plant cooldown on February 9, 2013. After the significance determination for the 'A' SRV finding is finalized, the NRC will assess Pilgrim's overall performance in relation to the Reactor Oversight Process Action Matrix.
+Accordingly, Pilgrim's performance will remain within the Degraded Cornerstone Column of the NRC's Reactor Oversight Process Action Matrix as discussed in the Pilgrim Annual Assessment Letter (Report 05000293/2014001), dated March 4, 2015. If Pilgrim transitions to a different Action Matrix Column following the final significance determination for the preliminary White finding, then the transition will be communicated in a future correspondence. Additionally, the NRC will continue to assess the effectiveness and sustainability of your efforts to address challenges in CAP implementation during the next biennial problem identification and resolution inspection, scheduled for August 2015.
+In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of ADAMS. ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
+Sincerely,
+/RA/ Ho K. Nieh, Director
+Division of Reactor Projects Docket No. 50-293 License No. DPR-35
+===Enclosure:===
+Inspection Report 05000293/2015009 w/Attachment: Supplemental Information
+REGION I==
+Docket No. 50-293
+License No. DPR-35
+Report No. 05000293/2015009
+Licensee: Entergy Nuclear Operations, Inc. (Entergy)
+Facility: Pilgrim Nuclear Power Station
+Location: Plymouth, Massachusetts
+Dates: May 4, 2015 through May 8, 2015
+Inspectors: S. Hansell, Senior Resident Inspector, Lead Inspector T. Setzer, Senior Project Engineer G. Newman, Resident Inspector Approved by: Raymond R. McKinley, Chief Reactor Projects Branch 5
+Division of Reactor Projects
+=SUMMARY OF FINDINGS=
+Inspection Report (IR) 05000293/2015009; 05/04/2015 - 05/08/2015; Pilgrim Nuclear Power Station (Pilgrim); Follow-up Supplemental Inspection - Inspection Procedure (IP) 95002.
+The report covered an on-site inspection by a Senior Resident Inspector, Senior Project Engineer, and one Resident Inspector. No findings were identified. The U.S. Nuclear
+Regulatory Commission's (NRC's) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5, February 2014.
+===Cornerstone: Initiating Events===
+The NRC staff performed this supplemental inspection in accordance with IP 95002, "Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area," to assess Entergy's actions to evaluate and implement changes to address the initial IP 95002 supplemental inspection (IR 05000293/2014008) conducted, in part, to review the two White performance indicators (PIs) and the initial corrective actions that were not sufficient to address the White PIs at that time. Consistent with Inspection Manual Chapter (IMC) 0305, "Operating Reactor Assessment Program," Section 11.01(e), this follow-up supplemental inspection specifically focused on the areas of significant weaknesses as documented in NRC Supplemental Inspection Report 05000293/2014008.
+The inspectors did not identify any new significant weaknesses in regard to Entergy's actions to address the White PIs. The inspectors concluded that Entergy implemented adequate corrective actions and made sufficient progress in applicable areas to address the significant weaknesses previously documented in IP 95002 Supplemental IR 05000293/2014008.
+The inspection objectives of IP 95002 have been satisfied and the two parallel White findings issued as part of Supplemental IR 05000293/2014008 will be considered closed at the end of the second quarter 2015.
+===Other Findings===
+None 4
+=REPORT DETAILS=
+==OTHER ACTIVITIES==
+{{a|4OA4}}
+==4OA4 Follow-Up Supplemental Inspection==
+{{IP sample|IP=IP 95002}}
+===.01 Inspection Scope===
+The NRC staff performed this follow-up supplemental inspection in accordance with IP 95002, "Supplemental Inspection for One Degraded Cornerstone of Any Three White Inputs in a Strategic Performance Area."  This inspection follows up on a supplemental inspection completed and documented in Supplemental IR 05000293/2014008 that issued two parallel White findings associated with Entergy's extent of condition reviews and corrective actions related to the four root causes performed for the events that resulted in two PIs in the Initiating Events cornerstone crossing the threshold from Green to White.
+The NRC follow-up supplemental inspection team has concluded that Entergy has successfully addressed the five significant deficiencies documented in Supplemental IR
+05000293/2014008.
+The inspectors have verified that Entergy's completed and planned corrective actions have addressed the previously identified significant deficiencies by performing the following:
+)  Assessed the independent failure analysis of the faulted 345 kilovolt (kV) electrical switchyard insulators for potential impact to the root cause evaluation (RCE) and revised as appropriate;
+)  Assessed the revised RCE for the February 8, 2013 winter storm station impact and associated reactor scram, to include additional actions for the incomplete initial
+effectiveness review; 3)  Evaluated that Entergy has demonstrated the effectiveness of additional
+maintenance department human performance related corrective actions implemented during the inspection through in-progress and completed work;
+)  Verified that Entergy has completed the evaluation of the cause(s) for the failed electrical cable splice that resulted in a loss of all three reactor feedwater pumps; and has revised the RCE to include additional corrective actions; and
+)  Evaluated the Entergy revisions to the RCEs for the overall common cause evaluation, which included taking action to understand why corrective actions intended to address the identified corrective action program (CAP) implementation weakness were not effective at ensuring the inspection objectives were satisfied.
+===.02 Evaluation of the Inspection Requirements===
+.01 Root Cause, Extent of Condition, and Extent of Cause Evaluation Failed Electrical Cable Splice/Loss of all Reactor Feed Pumps Missed Opportunity/Missing Post-Maintenance Tests not Captured in Corrective Action Program During the initial supplemental inspection, the NRC reviewed RCE CR-PNP-2013-5949 and concluded that Entergy did not identify a root or contributing cause for the failed reactor feed pump (RFP) electrical cable splice. In March 2015, Entergy completed a revision to the RCE, in which the direct cause, root cause, and contributing causes were revised. The revised RCE identified a contributing cause for the failed splice. Specifically, station maintenance procedures and work processes were not followed by the maintenance personnel when performing a non-safety-related splice for solenoid valve (SV)-3067. Entergy determined that the splice had most likely been fabricated in 1999 during implementation of a plant design change (PDC) of multiple valves (PDC 98-38). In their investigation, Entergy found multiple deficient work practice issues with the splice, which included that it was fabricated with the wrong crimp tool, and that it was not staggered to ensure room and flexibility in the conduit. This resulted in an inadequate splice that ultimately failed and led to the loss of all three RFPs on August 22, 2013.
+The inspectors determined that Entergy performed a thorough evaluation of the failed splice and revised the RCE to include extent of condition and extent of cause actions that were reasonable with supported conclusions. However, the inspectors identified the following observations regarding the extent of condition and extent of cause:
+As part of the extent of condition, Entergy created work orders (WOs) to inspect the wiring associated with four additional SVs (SV-3001, SV-3004, SV-3066, and SV-3351) that were rewired in 1999 as part of PDC 98-38. The inspections were performed during a plant shutdown in February 2015. The WO instructions (375493, 375489, 375495, and 375497) did not contain adequate guidance on how to perform the inspections. Specifically, the instructions did not direct the technicians to completely remove the wires to determine if any splices were hidden in the conduit.
+The technicians only removed condulet covers and inspected the ends of the wiring.
+As a result, the inspections had to be performed again during the refueling outage of May 2015 (RFO20). The inspectors determined that the lack of work instructions and missed opportunity to perform the inspections properly was not captured in the CAP. Additionally, three WOs for the inspections in RFO20 did not include post-maintenance test activities. Entergy entered the missed inspection opportunity and post-maintenance tests as items in the CAP (CR-PNP-2015-04455 and CR-PNP-2015-04403, respectively).
+Regarding the extent of cause, Entergy determined the inadequate work practices associated with the maintenance personnel that performed the splice in 1999 indicated that similar modified valves may have inadequate splices. In 1999 there was no specific training on crimping or electrical terminations using butt splices.
+Training on these topics was not provided until 2006. Entergy performed a review of modifications from 1995-2000 that replaced, relocated, or reoriented non-safety-related components that could have splices. The inspectors determined the timeframe of 1995-2000 was of limited benefit to fully explore the work practice issues in plant modifications, since technicians were not trained until 2006. Entergy entered this observation into the CAP (CR-PNP-2015-04443).
+The above observations were determined not to be violations of NRC regulatory requirements and as stated earlier have been entered into Entergy's CAP for further
+evaluation.
+====b. Findings====
+No findings were identified.
+.03 Corrective Actions a. CAP Evaluation for CR-PNP-2014-05735 - Assess the Independent Failure Analysis of the Faulted 345kV Electrical Switchyard Insulators for Potential Impact to the RCE and Revise as Appropriate
+During the initial supplemental inspection, the inspectors determined that Entergy had improperly closed a corrective action to conduct failure analysis on failed insulators from a previous loss of offsite power event. Entergy generated CR-PNP-2014-05735 and sent the insulator off site for failure analysis.
+The inspectors reviewed CR-PNP-2014-05735 to determine whether Entergy had completed or planned corrective actions to address the significant deficiencies. Entergy created new corrective actions in CR-PNP-2013-00798 to track the testing and review of test results. Entergy sent two insulators, one insulator that had experienced flashover and an insulator that was not installed in the electrical switchyard, to a third-party testing facility, Doble Engineering. Doble Engineering performed current leakage testing and partial discharge testing on the insulators. Doble Engineering determined that both insulators were still within the original equipment manufacturer's (OEMs) specifications. Doble Engineering recommended testing additional insulators to determine remaining service life. Entergy reviewed the results of the testing and provided the test report to the OEM, LAPP, for review. The OEM informed Entergy that the results were normal and that the insulators have a service life of 30 years. Entergy generated CR-2014-PNP-6799 to track the creation of preventive maintenance (PM) to replace insulators before the end of their service life.
+The inspectors questioned how Entergy addressed Doble Engineering's recommendation to test other installed insulators. Entergy informed the inspectors that the recommendation would be considered as part of the PM corrective action due in 2016. Entergy created CR-2015-PNP-04473 to capture their planned actions in response to the vendor recommendation.
+Entergy determined that the results of the testing did not impact the RCE performed for CR-PNP-2013-0798 since the testing results did not show substantial insulator degradation; therefore, a revision was not necessary. In general, the inspectors determined that the proposed corrective actions were appropriate and addressed each identified root and contributing cause. Entergy has taken actions to address the deficiencies identified in evaluation or correction of the individual performance issues discussed above. Specifically, the inspection verified that Entergy has taken action to:
+: (1) address the specific deficiencies in execution of corrective actions;
+: (2) address the deficient cause evaluation; and
+: (3) understand why corrective actions intended to address the identified CAP implementation weakness were not effective at ensuring the inspection objectives were satisfied.
+b. 2013 Winter Storm Scram - Verify that Entergy has Revised the RCE for the Winter Storm Scram to Include Additional Action for the Incomplete Effectiveness Review During the initial supplemental inspection, the NRC reviewed RCE CR-PNP-2013-0798 and concluded that Entergy did not complete a second effectiveness review in accordance with CAP requirements.
+Specifically, the initial effectiveness review for the de-icing PM was concluded to be indeterminate, but a follow-up (second) effectiveness review was never assigned to ensure the action would be completed properly. In January 2015, the second effectiveness review was completed following the January 27, 2015 winter storm known as Juno. This review determined that actions taken during winter storm Juno were ineffective, as both 345kV electrical lines were de-energized due to extensive icing of the switchyard insulators. Portable salamander heaters used during the storm were unable to prevent icing of the insulators as water would quickly refreeze once the heaters were removed. As a result, Entergy hired an outside contractor to perform pressure washing of the switchyard to remove ice from the insulators. This method was found to be effective and the plant was able to restart without any flashover events. In March 2015, a third effectiveness review was completed which concluded that the effectiveness of pressure washing the switchyard was validated, and that this method should be added to existing PM tasks to de-ice the switchyard in the future.
+Entergy modified PM task 16789 to include salamander heaters, manual brushing, and the use of an offsite contractor for pressure washing.
+Entergy determined that the RCE did not need revision as a result of the effectiveness reviews. Activities to perform the effectiveness reviews were already assigned in CR-PNP-2013-0798 but were not completed. The inspectors determined that the incomplete effectiveness review was completed with supportable conclusions. Additionally, the inspectors verified that the original RCE contained actions to complete the effectiveness review so a revision was not warranted.
+c. Effectiveness of Maintenance Department Human Performance Related Corrective Actions   During the initial supplemental inspection, the inspectors determined that observations of maintenance execution did not support closure or cancellation of corrective actions identified in the RCE. The inspectors identified the following deficiencies:
+Entergy's actions in September 2014 directed interim actions for enhanced supervisor oversight and procedure review in preparation for maintenance. This was an interim action until a long-term procedure upgrade project for maintenance was complete. The inspectors identified that the maintenance standing order was not being implemented at the time of the on-site inspection. Several procedures did not have critical steps annotated properly. A technician identified a critical step during a pre-job brief, but did not generate a condition report or a procedure feedback form to ensure permanent correction of the deficiency.
+One procedure contained steps that directed calibration of an instrument after fuses and alarms had been verified restored, an action that if performed without re-performing steps in the body of the procedure would result in an adverse
+consequence. Technicians continued with testing activities after encountering challenges, contrary to the station expectation to stop and evaluate the unexpected conditions.
+In response to the inspectors concerns, Entergy created multiple condition reports and revised the RCE to include additional corrective actions for procedural reviews prior to performance of work and enhanced oversight. At the time of the follow-up inspection, the previous maintenance standing order was augmented and formalized into a permanent procedure, 1.3.144, "Maintenance Performance of Trip Sensitive Activities."  The procedure provides guidance to reinforce human performance attributes for maintenance work that could cause a plant automatic shutdown or inadvertent safeguard system actuation. The procedure is an interim measure until the procedure upgrade
+program is complete.
+The inspectors observed a pre-job briefing and performance of trip-sensitive activities.
+Additionally, the inspectors reviewed a sample of completed WOs for trip sensitive activities and WO instructions for scheduled ac tivities to verify the interim measures were implemented. Specifically, the inspectors verified that work was classified
+appropriately as a trip sensitive activity and that the additional requirements of procedure 1.3.144 were implemented, for example:
+Discussion of the consequences of performance errors;  Identification and validation of critical procedure steps;  Discussion of work after logic restoration;  Preparations to stop work if unexpected results are obtained;  Discussion of procedure adherence requirements; and  Review of procedure changes since last performed.
+The inspectors observed technicians stop work when the procedure did not address restoration of robust barriers when leaving the area to perform another step in a separate area. The inspectors also observed successful performance of a critical step verifying that contacts associated with backup scram valves  are open prior to initiating a half-scram signal.
+With respect to the procedure upgrade project in the maintenance department, the current due date for this corrective action is March 3, 2016. Based on documentation review and interviews with station personnel, the inspectors noted that the procedure upgrade project is on schedule to be completed by the March 2016 date.
+d. CAP Overall Common Cause Evaluation for CR-PNP-2015-00375
+Entergy has taken actions to address the deficiencies identified in the evaluation or correction of the individual performance issues discussed above. Specifically, the follow-up inspection verified that Entergy has taken action to:
+: (1) address the specific deficiencies in execution of corrective actions;
+: (2) address the deficient cause evaluation; and
+: (3) understand why corrective actions intended to address the identified CAP implementation weakness were not effective at ensuring the inspection objectives were satisfied.
+Entergy made changes to ensure station management and supervision were effective at driving accountability at all levels of the organization to improve performance in all areas of the CAP. Specific areas included: corrective action implementation, corrective action timeliness, corrective action closure documentation, CAP procedure compliance, and resolution of early indications of poor CAP implementation. In addition, Entergy identified that an inadequate procedure used to prepare for the initial supplemental inspection, EN-LI-123-01, "Preparation for 95001(2)," did not provide structured preparation guidance to perform and support a performance based inspection that assumed the CAP program was robust and effective.
+The CAP routine initial data entry input and classification by the Department Performance Improvement Coordinators (DPICs) and subsequent review by the management Condition Review Group (CRG) to assign responsible actions have improved substantially in the past four months. The improvements were accomplished with the DPIC's review of every corrective action closure package. Prior to the change, numerous corrective actions were closed to unapproved processes, closure dates were extended or transferred to other condition reports, several significant CAP related condition reports were closed to a single condition report and some remained open through May 2015. The follow-up team reviewed the satisfactory closure of three RCE closure items related to CR-PNP-2015-00375. Fifteen corrective action closure items were partially complete and will be available for inspection during the August 2015 biennial problem identification and resolution inspection team.
+Pilgrim implemented a station performance improvement process in June 2014 to   improve the station's personnel accountability at all levels of the organization in an effort to improve performance in all areas of the CAP. The improvement process included the following three key processes: 1) 200 Percent Accountability model that emphasized individual accountability and holding others accountable to station core values and processes; 2) a Culpability model that ensures consistent coaching and discipline when human errors result in plant events, consequential errors, non-consequential errors, and issues that require management attention to resolve; and 3) Pilgrim Excellence in Behaviors model that includes seven fundamental behaviors that are exhibited by successful and high performing organizations. After an initial learning curve, the station implementation of the three models has contributed to improved CAP performance.
+DPICs' routine weekly training was a very effective knowledge transfer method to improve individual and group experience and ensure consistent understanding and application of the CAP process. The inspectors noted that DPICs were not required to observe CRG or corrective action review board meetings as part of their qualification.
+These meetings, in addition to their own pre-screening meeting, are integral parts of the CAP and would give the DPICs better perspective of their role in the CAP. Additionally, the inspectors noted that there was no formal continuing training for the DPICs. The inspectors note that DPICs meet weekly to perform training and periodically meet with the Site Vice President.
+Additionally, the NRC will continue to assess the effectiveness and sustainability of the efforts to address challenges in CAP implementation during the next biennial problem identification and resolution inspection, scheduled for August 2015.
+====e. Findings====
+No findings were identified.
+{{a|4OA6}}
+==4OA6 Exit Meeting==
+On May 8, 2015, the inspectors presented the inspection results to Mr. J. Dent, Site Vice President, and other members of his staff. The inspectors verified that no proprietary information was retained by the inspection team.
+ATTACHMENT:
+=SUPPLEMENTAL INFORMATION=
+Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT
+===Licensee Personnel===
+N. Berg  Contractor T. Bordelon  Performance Improvement Manager
+A. Brouchard  Engineering DPIC
+S. Burke  Senior Staff Engineer
+B. Chenard  Engineering Director K. Connerton  Operations E. Cota  Maintenance DPIC
+P. Couture  Licensing Engineer
+S. Das   Senior Lead Engineer
+B. Deacon  Senior Maintenance Specialist M. Farrell  Nuclear Control Technician M. Fichera  I&C Technician
+J. Freeman  Lead Nuclear Control Technician
+J. Gerety  System Engineering Manager
+B. Hannigan  Equipment Reliability Coordinator E. Herbert  I&C Superintendent C. Holstrom  I&C Working Foreman S. Hudson  System Engineer K. Kee   Engineering Design Programs Supervisor N. Levesque  I&C Technician J. Macdonald  Operations Department Manager
+: [[contact::A. Madeiras  Design Engineering]], Mechanical and Civil
+D. Mannai  Senior Manager Fleet Regulatory Affairs
+E. McCaffrey  System Engineer M. McDonald  Shift Supervisor F. McGinnis  Licensing Engineer
+D. Miller  Maintenance Coordinator
+: [[contact::D. Noyes  Director]], Regulatory and Performance Improvement
+J. O'Donnell  NSSS Supervisor
+: [[contact::J. Ohrenberger Senior Maintenance Manager P. O'Neil  Contractor C. Perkins  Manager]], Regulatory Assurance
+B. Rancourt  Senior Lead Engineer
+F. Russell  Preventive Maintenance Engineer
+: [[contact::J. Shumate  Senior Manager]], Production R. Swanson  Balance of Plant Systems Manager S. Verrochi  General Manager Plant Operations
+J. Vertossa  Chief Operating Officer Entergy Northeast
+T. Wheble  I&C Supervisor
+T. White  Design and Program Engineering Manager
+M. Williams  Nuclear Safety Licensing Specialist K. Woods  Engineer
+LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
+Opened/Closed
+05000293/2014008-03                       FIN Parallel White Unplanned Scrams per 7000 Critical Hours PI
+05000293/2014008-04                       FIN Parallel White Unplanned Scrams with Complications PI Finding
+Procedures 1.3.142, PNPS Risk Review and Disposition, Revision 0 1.3.142, PNPS Risk Review and Disposition, Revision 1
+.3.143, PNPS Accountability Model, Revision 1
+.3.144, Maintenance Performance of Trip Sensitive Activities, Revision 0
+.3.144, Maintenance Performance of Trip Sensitive Activities, Revision 1
+.3.144, Maintenance Performance of Trip Sensitive Activities, Revision 2
+.4.4, New England Power Grid Operations/Interfaces, Revision 26 1.5.22, Risk Assessment Process, Revision 24
+.1.14, Station Power Changes, Revision 112
+.1.37, Coastal Storm - Preparation and Actions, Revision 35
+.1.42, Operations during Severe Weather, Revision 20
+.2.1, 345 kV System, Revision 41
+.2.7, 480V AC System, Revision 32 2.2.31.1, Att. 8, Temporary Modification to Disable RFP Flow Switches while Performing Maintenance on TBCCW Heat Exchangers, Revision 15
+.4.150, Loss of Feedwater Heating, Revision 22
+.M.3-17.1, Raychem or Taping of 1000 Volt and Under Cables and/or Wires, Revision 17
+.M.3-33, 345kV Startup Transformer Calibration and Functional Relay Testing, Revision 33 3.M.3-51, Electrical Termination Procedure, Revision 20EN-DC-336, Plant Health Committee, Revision 8 3.M.3-71, Inspection and Maintenance of 345 kV Disconnects, Insulators, and Miscellaneous Switchyard Components, Revision 7 5.2.2, High Winds (Hurricane), Revision 35
+.2.3, Tornado, Revision 21 8.M.1-20, High Water Level Scram Discharge Tank Instrumentation Calibration/Functional Test Without Half Scrams - Critical Maintenance, Revision 73 8.M.2-1.5.3.1, Primary Containment Isolation Logic Channel Test - Channel A1 - Critical
+Maintenance, Revision 23 EN-FAP-EP-010, Severe Weather Response, Revision 1 EN-FAP-EP-012, Severe Weather Recovery, Revision 0 EN-FAP-OM-020, Comprehensive Recovery Plans, Revision 0
+EN-FAP-OU-104, Refueling Outage Scope Identification and Control, Revision 3
+EN-FAP-OU-105, Refueling Outage Execution, Revision 3
+EN-FAP-WM-002, Critical Evolutions, Revision 1
+EN-HU-102, Human Performance Traps and Tools, Revision 13 EN-HU-104, Engineering Task Risk and Rigor, Revision 5 EN-HU-106, Procedure and Work Instruction Use and Adherence, Revision 3
+EN-LI-102, Corrective Action Program, Revision 24 EN-LI-118, Cause Evaluation Process, Revision 20 and 21
+EN-LI-118-01, Event and Causal Factor Charting, Revision 2 EN-LI-118-03, Barrier Analysis, Revision 1 EN-LI-118-06, Common Cause Analysis (CCA), Revision 4
+EN-LI-118-08, Failure Modes Analysis, Revision 2
+EN-LI-118-11, Why Staircase, Revision 0
+EN-LI-121-, Trending and Performance Review Process, Revision 17
+EN-MA-118, Foreign Material Exclusion, Revision 10 EN-NS-221, Security Organization, Standards, and Expectations, Revision 6
+EN-OE-100, Operating Experience Program, Revision 21
+EN-OE-100-02, Operating Experience Evaluations, Revision 1
+EN-OP-111, Operational Decision-Making Issue (ODMI) Process, Revision 11 EN-OP-116, Infrequently Performed Tests or Evolutions, Revision 12 EN-OP-122, Operational Decision-Making Issue Precursor Process, Revision 0 EN-OU-103, Long Range Outage Planning, Revision 3
+EN-PL-187, Safety Conscious Work Environment (SCWE) Policy, Revision 1
+EN-PL-190, Maintaining a Strong Safety Culture, Revision 2
+EN-TQ-104, Engineering Support Personnel Training Program, Revision 18 EN-TQ-127, Supervisor Training Program, Revision 14 EN-TQ-212, Conduct of Training and Qualification, Revision 13
+EN-WM-101, On-Line Work Management Process, Revision 11
+EN-WM-104, On-Line Risk Assessment, Revision 9
+EN-WM-105, Planning, Revision 13
+EN-WM-109, Scheduling, Revision 7 NOP98A1, Procedure Process, Revision 36 FFAM-CAA-DPIC, Job Familiarization Guide, Department Performance Improvement Coordinator (DPIC), Revision 4 W10112, Pilgrim Line Outage Risk Mitigation Procedure, Revision 0
+Condition Reports (*denotes NRC identified during this inspection) CR-HQN-2014-0291  CR-PNP-2013-0798  CR-PNP-2013-5949 CR-PNP-2013-6298  CR-PNP-2014-6799  CR-PNP-2014-7830
+CR-PNP-2015-0070  CR-PNP-2015-0558  CR-PNP-2015-0896
+CR-PNP-2015-0897  CR-PNP-2015-1059  CR-PNP-2015-1148
+CR-PNP-2015-0375  CR-PNP-2015-0715  CR-PNP-2015-3823 CR-PNP-2015-3613  CR-PNP-2015-4313*  CR-PNP-2015-4319* CR-PNP-2015-4370*  CR-PNP-2015-4461*  CR-PNP-2015-4468*
+CR-PNP-2015-4403*  CR-PNP-2015-4405*  CR-PNP-2015-4406*
+CR-PNP-2015-4407*  CR-PNP-2015-4409*  CR-PNP-2015-4443*
+CR-PNP-2015-4453*  CR-PNP-2015-4455*  CR-PNP-2015-4461* CR-PNP-2015-4473*
+Work Orders 367142  381541  375495  375489
+  375493  52499608
+Learning Organization Documents
+LO-PNPLO-2014-0122
+LO-PNPLO-2014-0135
+LO-PNPLO-2015-0100
+LO-PNPLO-2013-0026
+Miscellaneous FQC-EMT1-EMMTE, Maintenance and Test Equipment, training material
+FLP-EMT1-EMMTE, Maintenance and Test Equipment, training lesson plan DPIC Meeting Agenda, dated February 24, 2015 PM Request PMRQ 16789 (AR187396)
+Condition Review Group Meeting Agenda, dated 05/06-7/2015
+Corrective Action Program Recovery Performance Indicators
+Entergy Operating Experience Point of Contact List - Pilgrim Performance Overview, Pilgrim Nuclear Power Station Pilgrim CAP Recovery Plan
+Schedule for Plant Health Committee Review of Single Point Vulnerability Mitigating Strategies, as of 11/18/2014 Schedule for presentation of mitigating strategies related to single point vulnerabilities to Plant
+Health Committee Maintenance Excellence Plan Procedure Review Checklist
+Maintenance Procedure Review Requirements
+PMQR 50076985-01 / 00029164-01
+PNPS-FSAR, Section 8, Electrical Power System
+PNPS Technical Specification 3.9, Auxiliary System
+Drawings M1H20-4, Elementary Diagram Residual Heat Removal (RHR) System, Revision 9, Sheet 16
+M1H10-10, Elementary Diagram RHR System, Revision 16, Sheet 6
+M1H8-10, Elementary Diagram RHR System, Revision 20, Sheet 4 E415, Schematic Diagram Recirculation System, Revision 16 M1H9-12, Elementary Diagram RHR System, Revision 21, Sheet 5
+M1H7-12, Elementary Diagram RHR System, Revision 21, Sheet 3
+M1H5-1-15, Elementary Diagram RHR System, Revision 18, Sheet 1
+M1H6-9, Elementary Diagram RHR System, Revision 19, Sheet 2
+E112, Schematic Diagram RFP System, Revision 14
+E115, Schematic Diagram RFP System, Revision 12, Sheet 1
+E115, Schematic Diagram RFP System, Revision 4, Sheet 2
+E1, Single Line Diagram Station, Revision 24, Sheet 1
+SE155, Station Electrical Single Line Composite Diagram 4.16 kV & 480V AC, Revision 73, Sheet 2 SE155, Station Electrical Single Line Composite Diagram 4.16 kV & 480V AC, Revision 33, Sheet 3 SE155, Station Electrical Single Line Composite Diagram 4.16 kV & 480V AC, Revision 26, Sheet 4
+LIST OF ACRONYMS
+CAP   corrective action program CRG   condition review group DPIC   Departmental Performance Improvement Coordinator
+IMC   Inspection Manual Chapter
+IP   Inspection Procedure
+IR   Inspection Report
+kV   kilovolt NRC   U.S. Nuclear Regulatory Commission OEM   original equipment manufacturer
+PDC   plant design change
+PI   performance indicator
+PM   preventive maintenance RCE   root cause evaluation RFP   reactor feed pump
+SV   solenoid valve
+WO   work order
 }}

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2015 Quarterly Integrated 1Q (1) 2Q (5) 3Q (5) 4Q (4) Assessments Mid Cycle End of Cycle 7(8) 8(2) 9(0) 10(4) 11(0) Security 403(5) 404(5) Operator Exams Emergency Planning Other

IR 05000293/2015009: Difference between revisions

Revision as of 15:35, 18 August 2019

Text

Dear Mr. Dent:

Enclosure:

SUMMARY OF FINDINGS

Cornerstone: Initiating Events

Other Findings

REPORT DETAILS

OTHER ACTIVITIES

4OA4 Follow-Up Supplemental Inspection

.01 Inspection Scope

.02 Evaluation of the Inspection Requirements

b. Findings

e. Findings

4OA6 Exit Meeting

SUPPLEMENTAL INFORMATION

Licensee Personnel

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