IR 05000293/2009003

ISI activities. The inspector's observation and documentation review of non-destructive testing included the following: * Ultrasonic testing, manual

XI. [[The sample selection was based on the inspection procedure objectives, sample availability, and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage. The inspector verified by documentation review that test procedures and examiner qualifications were current and in accordance with the]]

ASME [[Code requirements. Also, the inspector reviewed examiner qualifications for use of the performance demonstration initiative (PDI) manual ultrasonic test (UT) procedures to examine welds. The inspector selected a sample of Condition Reports (CR), operability/functionality evaluations and corrective actions for review of Entergy's effectiveness in the identification and resolution of relevant indications discovered during the observed]]

PDI -UT of pipe to cap butt weld 1-SD-1,

RHR system, carbon steel, 3.5" diameter, 0.438" wall thickness; * Magnetic particle test (

MT ) of support lugs, integral attachment to carbon steel piping. High Pressure Coolant Injection (HPCI) system, welds

EB -23-13

HL1(4); * In Vessel Visual Inspection (IVVI) of steam dryer leveling screw tack welds, divider plate anchor, shroud head bolt #18 and various jet pump diffusers, swing gates, main wedges, auxiliary wedges, wedge restrainer bracket set screws and rods; and * Liquid Penetrant test (PT) of stainless steel field weld of pipe to valve, B-11-159, Standby Liquid Control (SBLC), at drawing location ISI-1-11-1. The inspector reviewed selected steam dryer and jet pump structural members and component base materials to evaluate examiner skill, test equipment performance, examination technique, and inspection environment (water clarity). The inspector

selected jet pump nonconforming conditions identified in Indication Notification Reports (INR) P1R17-IVVI-09-01, P1R17-IVVI-09-02 and P1R17-IVVI-09-03 for the review of

IVVI effectiveness of indication identification and characterization. The inspector reviewed

CR -PNP-2009-01531, which was initiated to report and characterize mechanical wear on jet pump components and shroud head bolt #18. Also, the indications reported during this examination were evaluated by comparison with previous examination results noted in 2005 and 2007. The comparison revealed no noticeable change in characterization of the indications. The inspector selected two

XI [[repair/replacement plans for review where welding on a pressure boundary was performed. The review was performed to evaluate specification of appropriate base and weld materials and control of the welding process as detailed in the work order. Also, the inspector reviewed the weld procedures and welder qualifications for compliance with the requirements of]]

XI. Also, the inspector reviewed documentation that the weld examinations were performed in accordance with the

ASME code requirements. The two

XI repair/replacement work orders reviewed were: *

WO 00133037, Fabrication and replacement of salt service water (SSW) system spool piece

JF 29-19-1 for application of rubber lining and installation in Loop "B" of system #29. Component parts consisting of carbon steel,

ASTM A234, six inch schedule 40 150#, elbow, weld neck pipe flange and seamless pipe, weld map #1, Rev 0, welds 1 and 2; and *

WO 00133039, Fabrication and replacement of

SSW spool piece

JF and additional structural members attached to the liner to assess the condition of the protective coating. The inspector performed this visual evaluation to determine the extent of any peeling, blistering, coating loss or other damage as a result of corrosion, foreign material impact or lack of maintenance. The inspector reviewed a sample of Condition Reports initiated during]]

ISI examinations this outage to evaluate Entergy effectiveness in the identification and resolution of problems within the corrective action process. The inspector selected for review

PNP -2009-01180 (RHR pipe support H-10-1-12),

PNP -2009-01514 (linear indication at head to flange weld) and

PNP-2009-01182 (error in specification M301, extent of condition). The inspector reviewed the problem identification, flaw characterization, engineering assessment (operability/functionality evaluation) and the disposition entered into the corrective action program. b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11)

Licensed Operator Training

a. Inspection Scope (1 sample) The inspectors reviewed licensed operator response to a simulated General Emergency

during an emergency planning drill on May 28, 2009. The inspectors reviewed operator response to the event in the simulator, emergency plan implementation by the Senior

Reactor Operator, and the completion of a post drill critique. In addition, the inspectors observed licensed operator training on April 14, 2009. Specifically, the inspectors

observed classroom Just In-Time training for senior reactor operators, reactor operators,

and non-licensed operators to prepare them for Pilgrim's Refueling Outage. The lectures

discussed upcoming outage work activities including reactor cavity water level, the

replacement of control rod drive mechanisms, the integrated leak rate testing, and

temporary power configurations. The inspectors assessed the training to determine if the

training adequately prepared the operators for the refueling outage. The inspectors

reviewed the lesson plans and training objectives to determine if they had been achieved.

The documents reviewed during this inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12Q) a. Inspection Scope (2 samples) The inspectors reviewed degraded conditions associated with the systems listed below for

items such as: (1) appropriate work practices; (2) identifying and addressing common

cause failures; (3) scoping in accordance with 10 CFR 50.65(b) of the Maintenance Rule;

(4) characterizing reliability issues for performance; (5) trending key parameters for condition monitoring; (6) charging unavailability for performance; (7) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and (8) appropriateness of

performance criteria for structures, systems, and components (SSC)s/functions classified

as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for

SSCs/functions classified as (a)(1). The documents reviewed during this inspection are

listed in the Attachment. Items reviewed included the following: * Functional Failure Determination of Startup Transformer; and * Switchyard Breakers 102, 103, 104, and 105. b. Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope (7 samples) The inspectors evaluated seven maintenance risk assessments for planned and emergent

maintenance activities. The inspectors reviewed maintenance risk evaluations, work

schedules, and control room logs to determine if concurrent maintenance or surveillance activities adversely affected the plant risk already incurred with out-of-service components.

The inspectors verified the appropriate use of Entergy's qualitative risk assessment

checklist for shutdown safety functions and entry into appropriate risk categories. The

inspectors evaluated whether Entergy took the necessary steps to control work activities,

minimized the probability of initiating events, and maintained the functional capability of mitigating systems. The inspectors assessed Entergy's risk management actions during

plant walkdowns. The documents reviewed during this inspection are listed in the

Attachment. The inspectors reviewed the conduct and adequacy of maintenance risk

assessments for the following maintenance and testing activities: * Orange Risk Condition due to the unavailability of the Shutdown Transformer and Station Blackout Emergency Diesel Generator; * Orange Risk Condition during Maintenance and Valve Logic Testing of Residual Heat Removal Valves which affected shutdown cooling; * Orange Risk Condition due to Closure of Shutdown Cooling Suction Valves to Support Residual Heat Removal Valve Hydrostatic and Local Leak Rate Testing; * Emergent Departure from Defense-In-Depth Orange Risk Condition to Support Repair of MO-1001-29A Strain Gage; * Yellow Risk for Shutdown Transformer Breaker 504 to A5 4160V Bus Timing; * Orange Risk during Loss of Offsite Power/Emergency Core Cooling Systems Loading Testing; and * Orange Risk during Primary Containment Isolation Valve Testing which removed Shutdown Cooling from Service.

b. Findings No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope (5 samples) The inspectors reviewed five operability determinations associated with degraded or non-conforming conditions to determine if the operability determination was justified and if the mitigating systems or barriers remained available such that no unrecognized increase

in risk had occurred. The inspectors also reviewed compensatory measures to determine

if the compensatory measures were in place and were appropriately controlled. The

inspectors reviewed licensee performance against related Technical Specifications and

UFS [[]]

AR requirements. The documents reviewed during this inspection are listed in the

Attachment. The inspectors reviewed the following degraded or non-conforming

conditions:

PNP -2009-01182, Main steam drain line valve weld not radiograph tested as specified by

ASME Code; *

CR -PNP-2009-01261, Diesel Damper Vanes did not close all the way; *

PNP -2009-02016, Shutdown Transformer Relay did not close within its Technical Specifications Timeband; *

PNP -2009-02502, "B" Feed Regulating Valve Digital Controller Faults; and *

MG Set Room Heatup During Station Blackout Conditions," to determine the post-accident

PNP-2009-02707, Security Emergency Diesel Generator does not meet Surveillance Acceptance Criteria.

b. Findings No findings of significance were identified.

1R18 Plant Modifications (71111.18)

.1 Permanent Modification for Booster Fan in Vital Motor Generator (MG) Set Room a. Inspection Scope (1 sample) The inspectors reviewed Permanent Modification Field Revision Notice (FRN) 87-73-29,

"Installation of a Permanent Booster Fan in the Vital MG Set Room," to determine whether

the licensing bases and performance capability inside the Vital MG Set Room had been degraded through the modification. A walkdown was performed to determine whether the

components inside the room would perform their function under certain conditions. The

inspectors reviewed applicable condition reports and drawings to determine whether they

properly reflected the permanent modification. The inspectors also reviewed design basis

calculations to determine if they were conservative in their heat loading assumptions. The

documents reviewed during this inspection are listed in the Attachment.

b. Findings Introduction: The inspectors identified an Unresolved Item (URI) regarding design basis calculations for the Vital MG Set Room. The inspectors questioned Entergy about the

most limiting initiating event for room heat-up and the subsequent impact on safety related

components. Entergy provided the inspectors a calculation which addressed the room

heatup following a Station Blackout event; however, they could not identify a design basis

calculation which assessed room heatup following a Loss of Coolant Accident (LOCA)

without a Loss of Offsite Power (LOOP). The performance deficiency is that Entergy did

not have a calculation to verify an adequate design for the Vital

MG Set Room during a

LOCA without a

LOOP event. As such, the inspectors could not verify which event was

more limiting, whether safety related components in the room would be affected, and

whether the performance deficiency was more than minor.

Description: The inspectors reviewed Calculation N124, "Vital

MG set room

temperature limit. Calculation N124 assumes a heat-up time for the Vital MG Set Room of

eight hours, the mission time for a Station Blackout (SBO) event. Under worst case initial

conditions, i.e. hottest summer day and maximum heat loading, the calculation predicts the

room will heat up to 116 degrees F in an eight-hour time frame. However, the inspectors noted that other accident scenarios have a longer mission time, specifically the

LO [[]]

CA without

LO [[]]

OP could result in a higher maximum temperature. Entergy concluded that the

LOCA without

LOOP could be more limiting than the SBO event and entered this issue into

their corrective action program as

URI 05000293/2009003-02, Design Calculation of the Vital

PNP-2009-0991. As part of their corrective actions,

Entergy is modeling calculations of the Vital MG Set Room to determine the peak

temperature in the room for a

LOCA without

LOOP event. The issue of concern is that if

the peak temperature in the room is determined to be higher than what was previously

evaluated, the safety-related circuit breakers in the room would need to be evaluated to

ensure they could perform their function at the higher peak temperature. The inspectors

require Entergy's final calculation to be completed to determine if the performance deficiency is more than minor.

MG Set Room Peak Temperatures

.2 Permanent Modification for High Pressure Coolant Injection (HPCI) Turbine Controls Testing Device (TCTD) a. Inspection Scope (1 sample) The inspectors reviewed Permanent Modification

EC -4350, Revision 0, "Installation of a

HPCI [[]]

TCTD," and the associated 10 CFR 50.59 screening, to determine whether the

licensing bases and performance capability of the

HP [[]]

CI system had been degraded through the modification. A walkdown was performed to determine whether the

components inside the room were as described in the permanent modification

documentation. The inspectors reviewed applicable condition reports and drawings to

determine whether they properly reflected the permanent modification. The documents

reviewed during this inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

.3 Temporary Modification for Reactor Shutdown/Flood-up Level Indication a. Inspection Scope (1 sample) The inspectors reviewed Temporary Modification Procedure 3.M.2-40, Revision 6, "Refuel

Outage Temporary Modification Reactor Shutdown/Flood-up Level Indication," to

determine whether the performance capability of the Reactor Vessel Level Indication had been degraded through the modification. The inspectors reviewed Control Room

drawings, relevant condition reports, and procedures to ensure the temporary modification

did not adversely affect the Reactor Vessel Level Indication. The inspectors reviewed the

updated Control Room drawings to determine whether they properly reflected the

temporary modification. The inspectors also performed a walkdown of temporary

equipment installed in the plant to ensure the temporary equipment was installed in

accordance with the procedural requirements. The documents reviewed during this

inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

.4 Temporary Modification for 125V DC Power to Bus "B" a. Inspection Scope (1 sample) The inspectors reviewed Temporary Modification Procedure 3.M.3-36.7, Revision 0,

"Temporary Power for 125V

DC Bus "B"," to determine whether the performance capability of the 125V

DC safety related bus had been degraded through the modification. The

inspectors reviewed electrical schematics and procedures to ensure the temporary

modification did not adversely affect the reliability of 125V DC power. The inspectors reviewed Control Room drawings to determine whether they properly reflected the

temporary modification. The inspectors also performed a walkdown in the lower

switchgear room where temporary equipment was installed to ensure it was installed in

accordance with procedural requirements. The documents reviewed during this inspection

are listed in the Attachment.

b. Findings No findings of significance were identified.

.5 Temporary Modification for Residual Heat Removal (RHR) Valve Interlocks a. Inspection Scope (1 sample) The inspectors reviewed Temporary Modification Procedure 2.2.19.1, Attachment 19,

Revision 28, "Bypassing

MO -1001-47 and

MO-1001-50 Valve Interlocks," to determine

whether the performance capability of the RHR System had been degraded through the modification. The inspectors reviewed Control Room drawings, relevant condition reports,

and procedures to ensure the temporary modification did not adversely affect the RHR

System. The inspectors reviewed the updated Control Room drawings to determine

whether they properly reflected the temporary modification. The inspectors also

performed a walkdown of temporary equipment installed in the plant to ensure the

temporary equipment was installed in accordance with the procedural requirements. The

documents reviewed during this inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19) a. Inspection Scope (8 samples) The inspectors reviewed eight samples of post-maintenance tests (PMT) during this

inspection period. The inspectors reviewed these activities to determine whether the PMT

adequately demonstrated that the safety-related function of the equipment was satisfied,

given the scope of the work performed, and that operability of the system was restored. In addition, the inspectors evaluated the applicable test acceptance criteria to verify

consistency with the associated design and licensing bases, as well as TS requirements.

The inspectors also evaluated whether conditions adverse to quality were entered into the

corrective action program for resolution. Documents reviewed during this inspection are

listed in the Attachment. The following maintenance activities and their post-maintenance

tests were evaluated: * Replacement of the Station Blackout Diesel Governor; * Preventive Maintenance conducted on

MO -1001-50, Shutdown Cooling Suction Valve; * Motor Replacement for Motor Operated Valve

MO -1400-25A, Core Spray "A" Injection Valve; * Replacement of the "B"

125VDC Battery Bank; * Replacement of Drywell Fan Unit

VAC 205D1; * Hydraulic Control Unit Maintenance on

HCU 38-07 and

HCU 22-47; * Replacement of the "A" Recirculation Pump; and * Replace Reactor Head Vent Valves.

b. Findings No findings of significance were identified.

1R20 Refueling and Other Outage Activities (71111.20)

a. Inspection Scope (1 sample)

Periodic review of RFO 17 Work Plan and Outage Risk

The inspectors, on a routine basis, reviewed the refueling outage work plan and daily

shutdown risk assessments to verify Entergy addressed the outage impact on defense-in-

depth for critical safety functions. Periodic risk updates, accounting for schedule changes

and unplanned activities were also reviewed. The inspectors' review focused on verifying

Entergy had provided adequate defense-in-depth for each safety function, and/or

implemented planned contingencies to minimize the overall risk where redundancy was

limited or not available. Detailed risk reviews for specific high risk periods and activities

are documented in section 1R13 of this report.

Monitoring of Shutdown Activities

The inspectors observed operators performing portions of the reactor shutdown, and plant

cooldown to assess operator performance with respect to communications, command and

control, procedure adherence, and compliance with Technical Specification cooldown

limits. Upon shutdown, the inspectors also performed an inspection walkdown of the

drywell to verify the integrity of structures, piping and supports, and to confirm systems

appeared functional.

Clearance Activities

The inspectors reviewed a sample of risk significant clearance activities and verified tags

were properly hung and/or removed, equipment was appropriately configured per the

clearance requirement, and that the clearance did not impact equipment credited to meet

the shutdown critical safety functions.

Reactor Coolant System (RCS) Instrumentation

The inspectors periodically observed and verified by diverse means that associated

instruments for the reactor/refueling cavity/spent fuel pool (SFP) water level, the reactor

coolant and

SFP temperature, and the operating

RHR system were functioning properly

and accurately.

Electrical Power

The inspectors verified that the status of electrical systems met Entergy's outage risk

control plan. The inspectors verified that compensatory measures were implemented

when electrical power supplies were impacted by outage work activities. The inspectors

verified that credited backup power supplies were available.

Residual Heat Removal (RHR) and Spent Fuel Pool (SFP) System Monitoring

The inspectors observed the

RHR and

SFP system status and operating parameters to

verify that the cooling systems operated properly. Verification included periodic review of

the

SFP and reactor cavity level, temperature, and

RHR system flow. Partial system

walkdowns, to verify proper system configuration, were periodically performed for both

RHR and Reactor Building Closed Cooling Water alignment.

Inventory Control

The inspectors reviewed Entergy's actions to establish, monitor, and maintain the proper

water inventory in the reactor vessel and spent fuel pool. The inspectors reviewed the

plant system flow paths and configurations established for reactor makeup and verified the

configurations were consistent with the outage plan. In addition, the inspectors observed

Entergy's installation of a freeze seal on a 1" line of their Hydraulic Control Unit 50-39 to

support emergent maintenance on May 3, 2009. The inspectors reviewed Entergy's

contingencies for ensuring reactor vessel level control if the freeze seal were to fail.

Foreign Material Exclusion (FME)

The inspectors reviewed implementation of licensee procedures for FME control for the

open reactor vessel, reactor cavity, and SFP. The inspectors reviewed a sample of

Entergy's actions to identify, document, and resolve FME events/issues.

Control of Heavy Loads

The inspectors reviewed licensee actions to control the lift of heavy loads during the

outage. The review included activities related to the heavy loads associated with the

replacement of the "A" reactor recirculation pump and motor. The inspectors reviewed

licensee actions to manage the increased risk during these activities and to implement

compensatory measures to protect the integrity of systems important to safe shutdown.

This review included consideration of industry operating experience and licensee

commitments to NRC regulatory guidance.

Containment Control

The inspectors reviewed licensee activities during the outage to control primary and

secondary containment and to clean and prepare the containment for closure prior to plant

restart. The inspectors performed periodic tours of the drywell to review the control of work

activities and containment conditions. The inspectors performed a walkdown of the drywell

prior to reactor startup to review licensee cleanup and demobilization controls in areas where work was completed to assure that tools, materials and debris were removed. The

inspectors also reviewed data and acceptance criteria for the primary containment

Integrated Leak Rate Test (ILRT).

Fuel Shuffle Activities and Reactivity Control

The inspectors verified that refueling activities were performed in accordance with core

alterations Technical Specifications, including the requirements for core monitoring using

the source range monitors and the functional checks of the refueling interlocks. The

inspectors observed communications and the coordination of activities between the control

room, the General Electric physicist, and the refueling floor while fuel handling activities

were in progress. The inspectors reviewed Entergy's response to refueling floor

operational problems, including problems identified during movement of control rod blade

guides which resulted in damage to a blade guide.

Monitoring Heatup and Startup Activities

The inspectors observed and/or reviewed heatup and startup activities during the period of

May 18, 2009 through May 22, 2009. The inspection consisted of control room

observations, plant walkdowns, and a review of control board indicators, operator logs,

plant computer information, and station procedures. The inspectors observed operator

actions including the preparations for the approach to criticality, reactor critical operations,

low power operations, and the synchronization of the main turbine generator to the

electrical grid. The inspectors observed plant restart and power ascension to verify that

Technical Specifications, license conditions, and other requirements for mode changes

were met.

Problem Identification and Resolution

The inspectors verified that Entergy was identifying outage related issues and had entered

them into the corrective action program. The inspectors reviewed a sample of the

corrective actions to verify they were appropriate to resolve the issues. The references

used in this review are listed in the Attachment.

b. Findings Introduction: A Green self-revealing non-cited violation (NCV) of Technical Specification 5.4.1 "Procedures" was identified, because Entergy's refueling bridge operators did not

continuously monitor a Double Blade Guide (DBG) that was being moved into the core to

ensure the DBG did not encounter any obstructions, interferences, or other abnormal

indications as discussed in Pilgrim Procedure 4.3, Revision 113, "Fuel Handling."

Specifically, the failure to follow the procedure resulted in damaging the refueling mast

when the mast was moved and still latched to a

DBG. Description: On May 4, 2009, during Pilgrim's refueling outage, refueling personnel bent and damaged their refueling mast following the insertion of a

DBG into the core. The

DBG

is a tool used for control rod vertical support when adjacent fuel is removed from the core.

Refueling personnel had placed the DBG into its core location and the refueling Senior

Reactor Operator (SRO) authorized grapple release and the raising of the refuel mast.

Refueling personnel thought the mast had delatched from the DBG. However, the refuel

bridge operator did not perform a mast rotation verification check to ensure the DBG was

delatched. In addition, neither the

SRO nor the spotter visually verified the

DBG was

delatched. The refuel bridge operator proceeded to raise the mast above the core and

traverse to the next location which bent the mast and the handle to the DBG. Entergy

conducted inspections of the adjacent fuel assembly and control rod to ensure that no fuel

or control rod had been damaged. The performance deficiency is that Entergy did not

properly implement their Procedure 4.3 "Fuel Handling," which requires them to

continuously monitor

DBG movement to ensure the

DBG does not encounter any

obstructions, interferences, or abnormal indications. By not following their procedure,

Entergy's refueling personnel damaged the refueling mast.

Analysis: The performance deficiency was the failure of Entergy's refueling bridge operators to continuously monitor a DBG during movement within the core to ensure the

DBG did not encounter any obstructions, interferences or other abnormal indications as

required by the fuel handling procedure. The inspectors determined that the finding was

more than minor because the finding was associated with the human performance attribute

of the Barrier Integrity Cornerstone and adversely affected the cornerstone's objective to

provide reasonable assurance that physical design barriers (i.e. fuel cladding) protect the

public from radionuclide releases caused by accidents or events. Although no fuel

damage occurred during this event, the failure to follow the fuel handling procedure

affected the cornerstone's objective to provide reasonable assurance that physical design

barriers protect the public from radionuclide releases caused by accidents or events.

The failure to properly implement the fuel handling procedure affected the Barrier Integrity

Cornerstone. IMC 0609, "Significance Determination Process," Attachment 0609.04,

"Phase 1-Initial Screening and Characterization of Findings," was used to evaluate the

significance of the finding. Attachment 0609.04, Table 4a, was used to evaluate the

impact of the finding on fuel clad integrity. Following this event, Entergy inspected fuel

assemblies and the control rod in proximity to the DBG and concluded that no damage had

occurred to the fuel or control rod. Since the finding did not affect spent fuel pool cooling

or inventory and since no fuel or control rod was damaged when the mast was bent, the

finding was determined to be of very low safety significance (Green).

The finding has a cross cutting aspect in Human Error Prevention Techniques in the Work

Practices component of the Human Performance area. Specifically, Entergy did not

employ effective self and peer checking techniques such that refueling activities were

performed safely. (H.4.a of

IMC 305). Enforcement: Technical Specification 5.4.1, "Procedures", requires that written procedures be implemented as recommended in

NRC Regulatory Guide (RG) 1.33, "Quality

Assurance Program Requirements," Revision 2, Appendix A, February 1978. RG 1.33,

Appendix A, Section 2 includes procedures for Refueling Equipment Operation. Contrary

to this, on May 4, 2009, Entergy did not properly implement Procedure 4.3, "Fuel

Handling," which required them to continuously monitor DBG movement to ensure the

DBG does not encounter any obstructions, interferences, or other abnormal indications.

Corrective actions included replacing a section of the refueling mast, replacing the grapple

camera, conducting additional training with the refueling crews including a table top dry

run; performing a Human Performance Error Review and requiring Operations Senior

Management to provide oversight during one hour of each three hour shift when the

refueling crew was on the bridge moving fuel. Because this violation was of very low safety

significance and Entergy has entered it into their corrective action program (CR-PNP-2009-

02083), this violation is being treated as an

NCV , consistent with Section

VI.A. 1 of the

NRC Enforcement Policy.

NCV 05000293/2009003-01, Failure to Follow Procedure Resulting in Damage to Refueling Mast 1R22 Surveillance Testing (71111.22)

a. Inspection Scope (6 samples) The inspectors reviewed six samples of surveillance activities to determine whether the

testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety-related functions. The inspectors reviewed selected

prerequisites and precautions to determine if they were met and if the tests were

performed in accordance with the procedural steps. Additionally, the inspectors evaluated

the applicable test acceptance criteria for consistency with associated design bases,

licensing bases, and Technical Specification requirements. The inspectors also evaluated

whether conditions adverse to quality were entered into the corrective action program for

resolution. The documents reviewed during this inspection are listed in the Attachment.

The following surveillance tests were evaluated:

Local Leak Rate Testing of the "C" Main Steam Isolation Valve, Containment Isolation Valve (CIV); * Loss of Offsite Power/Emergency Core Cooling Systems Loading Testing; * Control Rod Scram Timing; * Reactor Vessel Pressurization and Leakage Test; * Primary Containment Integrated Leak Rate Test; and *

HPCI Operability Run at 150 psig (

IST). b. Findings No findings of significance were identified. Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

a. Inspection Scope (1 drill observation sample) The inspectors observed an emergency planning drill on May 28, 2009. The inspectors evaluated the emergency response organization performance in the simulator, and in the

Emergency Operations Facility, for a scenario which escalated to a General Emergency and involved a simulated offsite release. The inspectors assessed the implementation of

Emergency Action Level (EAL) classification and notification decisions as well as

Protective Action Recommendation development and notifications. The inspectors also

assessed whether Pilgrim's critique of the exercise assessed all of the drill's observations and findings. The documents reviewed during this inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

2.

RADIAT [[]]

ION [[]]

SAFE [[]]

TY Cornerstone: Occupational Radiation Safety

2OS1 Access Control To Radiologically-Significant Areas (71121.01)

.1 Access Control to Radiologically-Significant Areas (Pre-Outage)

.a Inspection Scope (12 samples) During the period March 30, 2009 through April 2, 2009, the inspectors performed the

following activities to verify that Entergy was properly implementing operational,

administrative, and engineering controls for access to locked high-radiation areas, and

other radiologically significant areas. Implementation of these controls was reviewed

against the criteria contained in 10 CFR 20, Standards for Protection Against Radiation,

relevant Technical Specifications, and Entergy=s procedures. This inspection activity represented the completion of twelve (12) samples relative to this inspection area. * The inspectors identified the refuel floor activities and the incore tip room survey activities as significant work areas and reviewed the associated controls and surveys of

these areas to determine if controls were acceptable. * The inspectors walked down the perimeter of these areas to determine whether prescribed radiation work permits (RWP)s, procedure, and engineering controls were in

place, whether licensee surveys and postings were acceptable, and whether air

samplers were properly located. * The inspectors reviewed RWPs for the upcoming refueling outage used to access high radiation areas and identify what work control instructions or control barriers had been

specified. These RWPs included scaffold work, refueling activities, reactor

recirculation pump 'A' replacement, inservice inspection activities, and minor

maintenance. The inspectors reviewed electronic personal dosimeter (EPD) alarm set

points (both integrated dose and dose rate) for conformity with survey indications and

plant policy. The inspectors verified that workers knew what actions they were to take

if their EPD malfunctioned or alarmed. * During job performance observations for refueling preparation activities, the inspectors verified the adequacy of radiological controls, such as; required surveys, including

airborne surveys, radiation protection job coverage, and contamination controls. * The inspectors reviewed seventeen (17) condition reports related to access controls. The inspectors also reviewed the 2007 radiation protection annual audit and the

station's five year As Low As Reasonably Achievable (ALARA) plan. * The inspectors questioned workers to verify that radiation workers were aware of the significant radiological conditions in their workplace, their

RWP precautions, their

EPD

set-points, and that their performance took into consideration the level of radiological

hazards present. The inspectors also observed radiation worker performance with

respect to stated radiation protection work requirements.

Of the 17 condition reports reviewed by the inspectors, 11 were due to radiation worker error. The inspectors reviewed the reports for observable patterns and discussed

corrective actions planned and taken with the Radiation Protection Manager (RPM). * The inspectors observed radiation protection technician performance with respect to radiation protection work requirements. * Of the 17 condition reports reviewed by the inspectors, 3 were due to radiation protection technician error. The inspectors discussed with the RPM the status of

changes in licensee procedural controls of high dose rate - high radiation areas and

very high radiation areas (VHRA). * The inspectors discussed with a radiation protection supervisor the controls in place for special areas that have the potential to become

VH [[]]

RA during certain plant operations.

Either because the conditions did not exist or an event had not occurred, no

opportunities were available to review the following items: * Review of

RWP [[s for airborne radioactivity areas with the potential for individual worker internal exposures of >50 millirem Committed Effective Dose Equivalent (]]

CEDE ) (20

DAC -hrs); and * Adequacy of Entergy's internal dose assessment for any actual internal exposure greater than 50 millirem

CEDE. b. Findings No findings of significance were identified.

.2 Access Control To Radiologically-Significant Areas (Outage)

a. Inspection Scope (12 samples)

During the period April 29, 2009 through May 5, 2009, the inspectors performed the following activities to verify that Entergy was properly implementing operational,

administrative, and engineering controls for access to locked high radiation areas, and

other radiologically significant areas. Implementation of these controls was reviewed

against the criteria contained in 10 CFR 20, relevant Technical Specifications, and

Entergy=s procedures. This inspection activity represents the completion of twelve (12) samples relative to this inspection area. * The inspectors reviewed all licensee Performance Indicators (PIs) for the Occupational Exposure Cornerstone for follow-up. * The inspectors walked down the perimeter of the drywell, work areas inside the drywell such as the 'A' recirculation pump replacement, and under the vessel work. The

inspectors also walked down the refueling floor and the condenser bay. The inspectors

verified whether prescribed RWP, procedure, and engineering controls were in place,

whether licensee surveys and postings were acceptable, and whether air samplers

were properly located.

The inspectors reviewed seventeen (17) condition reports from the start of the refueling outage through May 1, 2009. Follow-up actions for these condition reports were

performed in an efficient and timely manner commensurate with their importance to

safety and risk. * During job performance observations for N9A weld overlay activities and refueling activities, the inspectors verified the adequacy of radiological control preparation

activities. The inspectors verified the adequacy of radiological controls, such as:

required surveys, radiation protection job coverage and contamination control. * The inspectors observed radiation worker performance to determine if they were aware of significant radiological conditions in their workplace, the RWP controls/limits, and

that their performance took into consideration the level of the radiological hazards

present. * The inspectors reviewed two (2) condition reports since the beginning of the refueling outage that found the cause to be due to radiation worker error. The inspectors

verified there were no observable patterns traceable to a similar cause. * The inspectors observed radiation protection technician performance with respect to all radiation protection work requirements. The inspectors verified that worker

performance was consistent with their training and qualifications with respect to the

radiological hazards and work activities. * The inspectors reviewed one (1) condition report that found the cause of the event was radiation protection technician error. The inspectors verified this was an isolated case

and no pattern traceable to a similar cause. Either because the conditions did not exist or an event had not occurred, no opportunities

were available to review the following items: * Review

RWP [[s for airborne radioactivity areas with the potential for individual worker internal exposures of >50 millirem]]

CEDE (20

DAC -hrs); * Adequacy of Entergy's internal dose assessment for any actual internal exposure greater than 50 millirem

CEDE packages; * Review of licensee documentation for PI events; and * Review the application of dosimetry to effectively monitor exposure when significant dose rate gradients exist. b. Findings No findings of significance were identified.

2OS 2 As Low As Reasonably Achievable (

ALARA) Planning and Controls (71121.02)

.1 As Low As Reasonably Achievable (ALARA) Planning and Controls (Pre-Outage)

a. Inspection Scope (7 samples) During the period March 30, 2009 through April 2, 2009, the inspectors performed the

following activities to verify that Entergy properly implemented operational, engineering,

and administrative controls to maintain personnel exposure

ALA [[]]

RA during routine plant

operation. Implementation of these controls was reviewed against the criteria contained in

CFR 20, applicable industry standards, and Entergy=s procedures. This inspection activity represents the completion of seven (7) samples relative to this inspection area.

Current Cumulative Exposure and Trend

The inspectors reviewed pertinent information regarding plant collective exposure history,

current exposure trends, and ongoing or planned activities to assess current performance

and exposure challenges.

The inspectors reviewed the upcoming outage work schedule and the associated work

activity exposure estimates. The five work activities that are likely to result in the highest

personnel collective exposures are scaffolding, refueling activities on the refuel floor, in

service inspection, replacement of the 'A' recirculation pump, and routine maintenance.

Radiological Work Planning

The inspectors obtained from Entergy, a list of the outage work activities with estimated

exposures. The inspectors reviewed the

ALA [[]]

RA reviews for the five highest dose work

activities to determine if appropriate procedures, engineering, and work controls had been

designated.

Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the assumptions and basis for the current annual collective

exposure estimate and the methodology used. The inspectors reviewed the methods used

to make adjustments to the exposure estimate when unexpected changes occur.

Source Term Reduction and Control

The inspectors reviewed Pilgrim documentation to determine the historical trends and

current status of tracked plant source terms.

Problem Identification and Resolution The inspectors reviewed condition reports related to the

ALA [[]]

RA program since the last

inspection to determine if repetitive deficiencies or significant individual deficiencies are

identified.

Either because the conditions did not exist or an event had not occurred, no opportunities

were available to review the following item:

Pilgrim had no declared pregnant workers during this assessment period. b. Findings No findings of significance were identified.

.2 As Low As Reasonably Achievable (ALARA) Planning and Controls (Outage)

a. Inspection Scope (7 samples) During the period April 29, 2009 through May 5, 2009, the inspectors performed the

following activities to verify that Entergy was properly implementing operational,

engineering, and administrative controls to maintain personnel exposure

ALA [[]]

RA during

refueling outage operation. Implementation of these controls was reviewed against the

criteria contained in 10 CFR 20, applicable industry standards, and Pilgrim's procedures.

This inspection activity represents the completion of seven (7) samples relative to this

inspection area.

Inspection Planning

The inspectors reviewed the work schedule for the refueling outage during the inspection

period. The inspectors also reviewed the site specific procedures associated with

maintaining occupational exposures

ALA [[]]

RA.

Radiological Work Planning

The inspectors reviewed the exposure estimates for six (6) work activities that were likely

to result in the highest personnel collective exposures. The inspectors compared the

results achieved with the intended dose established in Pilgrim's

ALA [[]]

RA planning for these

work activities. The inspectors reviewed Pilgrim's response to increased dose rates and

higher than estimated work hours.

Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the method for adjusting exposure estimates and attended a

manager's

ALA [[]]

RA committee meeting for the purpose of making adjustments. The

inspectors verified that estimated exposure is based on sound radiation protection and

ALA [[]]

RA principles.

Source Term Reduction and Control

The inspectors reviewed the source term from shut down to May 1, 2009. The plant

implemented effective contingency plans when the refuel pool activity was higher than

expected.

Either because the conditions did not exist or an event had not occurred, no opportunities

were available to review the following item:

Pilgrim had no declared pregnant workers during this assessment period. b. Findings No findings of significance were identified. 4.

OTHER [[]]

ACTIVI [[TIES [OA]]]

4OA 1 Performance Indicator (

PI) Verification (71151)

a. Inspection Scope Cornerstone: Initiating Events (3 samples) The Initiating Events cornerstone PI data for unplanned scrams per 7,000 critical hours;

unplanned scrams with loss of normal heat removal; and unplanned power changes per

7,000 critical hours was reviewed to assess the completeness and accuracy of the

reported information. Specifically, PI data from the second quarter of 2008 through the first

quarter of 2009 was reviewed and compared to information contained in NRC inspection

reports, Licensee Event Reports (LERs), and operator logs.

Cornerstone: Barrier Integrity and Mitigating Systems (2 samples) The inspectors reviewed PI data to determine the accuracy and completeness of the

reported data. The review was accomplished by comparing reported PI data to

confirmatory plant records and data available in plant logs, the chemistry data base,

Licensee Event Reports (LER),

CR s, and

NRC inspection reports. The acceptance criteria

used for the review was Nuclear Energy Institute (NEI) 99-02, Revision 5, "Regulatory

Assessment Performance Indicator Guidelines," and Pilgrim TS 3.6, "Primary System

Boundary." The documents reviewed during this inspection are listed in the Attachment.

The following performance indicators were reviewed:

Mitigating System Cornerstone, Safety System Functional Failures from the first quarter of 2008 through the first quarter of 2009; and * Barrier Integrity Cornerstone, RCS Activity from the second quarter of 2008 through the first quarter of 2009

Cornerstone: Occupational Exposure Control Effectiveness (1 sample) The inspectors reviewed implementation of Entergy=s Occupational Exposure Control Effectiveness Performance Indicator (PI) Program. Specifically, the inspector reviewed recent condition reports, and associated documents, for occurrences involving locked high

radiation areas, very high radiation areas, and unplanned exposures against the criteria

specified in NEI 99-02, "Regulatory Assessment Performance Indicator Guidelines,"

Revision 5, to verify that all occurrences that met the NEI criteria were identified and

reported as performance indicators. This inspection activity represents the completion of

one (1) sample relative to this inspection area; completing the annual inspection

requirement.

b. Findings No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152)

.1 Review of Items Entered into the Corrective Action Program (CAP)

a. Inspection Scope The inspectors performed a screening of each item entered into Entergy's CAP. This

review was accomplished by reviewing printouts of each CR, attending daily screening

meetings and/or accessing Entergy's database. The purpose of this review was to identify

conditions such as repetitive equipment failures or human performance issues that might

warrant additional follow-up.

b. Findings No findings of significance were identified. .2 Semi-Annual Review to Identify Trends a. Inspection Scope The inspectors performed a review of Entergy's CAP and associated documents to identify

trends that could indicate the existence of a more significant safety issue. The review was

focused on repetitive equipment and corrective maintenance issues, but also considered

the results of daily inspector CAP item screening. The review included issues documented

in

CAP trend reports and the site

CAP performance indicator data. The review focused on

the six-month period of December 2008 through June 2009. The documents reviewed

during this inspection are listed in the Attachment.

b. Findings and Observations

No findings of significance were identified. Two low level trends were identified in the

areas of post maintenance/modification testing and temporary modification controls.

Post Maintenance/Modification Testing

The inspectors reviewed eight maintenance work order packages and one permanent

modification package during this quarter in order to verify that the testing adequately

demonstrates the safety function that may have been affected by the maintenance or

modification activity. In the majority of the packages reviewed, the inspectors identified

discrepancies with the specification, completion, and documentation of post maintenance

or modification test activities. Examples the inspectors identified included: * The Engineering Change (EC)

PMT requirements for drywell cooler work were not all specified in the work order (

WO) PMT section, including; verification of proper reassembly

for all structural elements, bolting and anchorages, proper alignment of the fan housing,

proper fit-up of flange joints with no visible gaps, and no loose or missing fasteners.

Substitute work and testing activities were identified which reasonably demonstrated the

expected

PMT attributes were met.

CR-PNP-2009-02618 was written to document the

missing

PMT. * The completion of the

EC [[]]

PMT requirements for reactor head vent valve work could not be located for inspector review. The

PMT requirements included; inspection for visible

leakage and/or the completion of non-destructive testing of all welded joints, soap bubble

tests of all air joints breached by the modification, continuity and meggar checks of all

cables, In-Service Test (IST) valve position verification, full exercise, stroke test and fail

safe tests, visual examination of all welds during the reactor vessel pressure test, and

establishing a new IST baseline. Substitute work and testing was identified which

reasonably demonstrated the expected

PMT attributes were met.

CR-PNP-2009-02648

and -02676 were written to document the missing

PMT. * The completion of

EC [[]]

PMT for the

HPCI [[]]

TCTD could not be located for inspector review. The functional test of the

HPCI pump (1 attribute of a total of 8 PMT attributes specified in

the EC post modification test plan) was located and satisfactorily completed. With the

exception of a new

TC [[]]

TD power supply circuit breaker thermography test, the remaining

TCTD equipment which does not directly

interface with the

HPCI system except during testing which is conducted when the

HPCI

system is not required to be operable. Operations assessed the condition of the lack of

thermography to be acceptable in consideration that no deficiencies were identified at the

circuit breaker panel or the

TC [[]]

TD during testing and that the circuit breaker is normally

open. In addition, discussion with Electrical Maintenance personnel identified that the

thermography had been performed successfully but that the documentation for the test

could not be located.

PNP -2009-02861 was written to document the missing

PMT. * The inspectors identified several documentation and administrative errors associated with

WO PMT requirements including; missing documentation for the verification of the

completion of PMT, lack of documentation of the basis for the satisfactory completion when

acceptance criteria had not been met and/or no CR documenting this basis, and the lack of

documentation of the completion of a soap bubble test. Each of these issues was

subsequently documented in a CR, the condition evaluated or corrected, and determined

not to affect the functionality or operability of safety-related equipment. Entergy corporate procedure

MA-101, Revision 6, "Conduct of Maintenance," identifies, in

part, that PMT consists of testing that is performed following any maintenance activity to

ensure that the original deficiency was corrected, no new deficiency was created as a result of

the maintenance activities, and equipment will perform its intended function when returned to service.

PMT. The inspectors discussed this low level trend with Entergy and

MA-101 also identifies that the PMT documentation fully describes the test

performed and results such that an independent third party will be able to review and understand what was done, what the results were and conclusions drawn. The inspectors

have concluded that the number and extent of PMT issues identified during this quarter

constitutes a low level trend with the specification, performance, and documentation of

PNP-2009-2778 was

written to document the examples, to conduct an apparent cause evaluation, and to specify

corrective actions. The inspectors will follow Entergy's investigation and corrective actions to evaluate their response to this low level trend.

Temporary Modification Controls The inspectors reviewed temporary modification packages during Pilgrim's refueling

outage in order to verify that modifications had not affected the safety functions of

important safety systems. During the review the inspectors identified discrepancies with

temporary modification controls including procedural adherence, appropriate tagouts, and

drawings not being up to date. The following examples illustrate these discrepancies: * During a review of the procedural temporary modification for cross-tying both trains of Reactor Building Closed Cooling Water, the inspectors identified that administrative

controls were not used as specified by the procedure. Specifically, tags were not

placed as specified on the control panel and on the piping and instrumentation drawing

(PI&D).

PNP-2009-1468 was written. * During a review of the reactor shutdown/flood-up level indication procedural temporary modification, the inspectors noted that a valve was not tagged as specified by the

procedure.

PNP-2009-2085 was written. * During a review of the MO-1001-50 shutdown cooling suction valve and pump interlock procedural temporary modification, the inspectors identified that Entergy did not update

the applicable control room drawing nor did they maintain a copy of the procedural

temporary modification in the control room as specified by the procedure.

PNP-

2009-2187 was written. The inspectors also identified that Entergy's temporary modification audit program requires

a quarterly review; however, there are no specific requirements to conduct audits during an

outage, a timeframe where a significant number of temporary modifications are

installed/implemented. The inspectors have concluded that the discrepancies identified

this quarter constitute a low level trend in the area of temporary modification controls. The

inspectors discussed this low level trend with Entergy and

PNP-2009-3064 was written

to document the examples and to specify corrective actions. The inspectors will follow Entergy's investigation and corrective actions to evaluate their response to this low level

trend.

.3 Annual Sample: Review of Risk Assessment Process Improvements and Management a. Inspection Scope (1 sample) The inspectors conducted a review of

PNP-2008-00946 to assess the effectiveness of

Entergy's corrective actions to improve the risk assessment process. The inspectors also

reviewed

NCV 05000293/2008002-01, and

PNP -2009-03792,

NCV 05000293/2008005-

related to previous risk assessment issues, the RFO17 shutdown risk report, and attended

shutdown risk assessment meetings during the outage. b. Findings and Observations No findings of significance were identified. The inspectors concluded that Entergy's efforts to improve the assessment of the risk of

maintenance and testing activities, particularly emergent risk activities, have been

effective. The inspectors noted that the accuracy and communication of on-line and

shutdown risk assessment have improved and that Operations has taken a greater

leadership role in this process. The inspectors also noted that Entergy's shutdown risk

assessments during RFO17 more accurately reflected shutdown plant risk than they have

in the past and that Entergy took reasonable risk management actions during heightened

periods of risk. The inspectors did note that Entergy entered Orange risk conditions

several times during the outage and that Entergy may be able to avoid these heightened

risk activities by reviewing the activities and evaluating whether a different approach could

be used (e.g., evaluate whether the Loss of Offsite Power test can be conducted one train

at a time). The inspectors also noted that Entergy's risk assessment process should be

reviewed for improvements and updates (e.g., current risk communication methods, such

as risk information signs and color coded Outage Turnover reports, are not discussed in

this procedure) to more accurately reflect current risk assessment management

approaches.

4OA3 Event Follow-up (71153)

.1 Operator Response to Unplanned Loss of the 23KV Offsite Power Line

a. Inspection Scope (1 sample) On April 29, 2009, NStar de-energized a supply line which provides power to the shutdown

transformer. The loss of this power supply affected offsite power supplies for the

Technical Support Center, security loads, and auxiliary loads for the Station Blackout Emergency Diesel Generator. Operators entered Procedure 2.4.A.23, Loss/Degradation of

23KV Line, and verified that all onsite power supplies to the above loads had energized.

Power to the 23KV line was subsequently restored less than 10 minutes later. The

inspectors responded to the Control Room, reviewed applicable procedures and Technical

Specifications, and reviewed operator response. The documents reviewed during this

inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

.2 Refueling Personnel Response to Shroud Tie Rod Gap and Inability to Install the Separator

a. Inspection Scope (1 sample) On May 3, 2009, Refueling personnel identified a 1/2 inch gap between the core shroud

outside diameter and the tie rod upper support at the 135 degree location. The existence

of this gap was subsequently evaluated and the decision was made to leave the tie rod as-

is. On May 11, 2009, Refueling personnel identified a problem with the re-installation of

the separator. Visual inspections revealed that the separator was sitting on the 135

degree tie rod upper support. On May 12, 2009, the separator was removed from the

vessel and returned to the dryer/separator pool. Entergy and General Electric Hitachi

personnel generated a procedure to push the tie rod upper support closer to the shroud to

allow separator installation. The tie rod upper support was successfully pushed 1/2 inch

toward the core shroud and the separator was successfully seated, latched, and verified on

May 13, 2009.

The inspectors reviewed selected technical documents, the temporary procedure used to

re-position the tie rod upper support, and the Updated Facility Safety Analysis Report. The inspectors also attended the Onsite Safety Review Committee meeting which evaluated

this activity. The documents reviewed during this inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

.3 Operator Response to "B" Condensate Pump Leak

a. Inspection Scope (1 sample) On May 10, 2009, at approximately 10:00am, operators identified a leak coming from the

packing gland of the "B" condensate pump during fill of the condenser hotwell. The leakage was collecting in the condensate pump pit and draining to the radiological waste

system via the turbine building floor sumps. Operations stopped the fill of the hotwell and notified Mechanical Maintenance personnel. At that time, Mechanical Maintenance

personnel determined that the packing for the "B" condensate pump had not yet been

installed. Mechanical Maintenance personnel determined that a Mechanical Maintenance

supervisor had signed off of a work boundary tagout and had incorrectly reported that the

system was "pipe tight" to the Shift Outage Coordinator. Operations drained the condenser

hotwell to below the level of the "B" condensate pump packing, re-established the work

boundary tagout, and Mechanical Maintenance installed the "B" condensate pump packing

on May 11, 2009.

The inspectors interviewed Mechanical Maintenance personnel, Operations personnel and

Outage Control Center personnel and reviewed statements from Mechanical Maintenance

personnel. The inspectors reviewed control room logs, radiological waste logs, and

Outage Control Center logs. The inspectors reviewed the work order, tagouts associated

with the work order, and the timeline of the work, tagout removal, hotwell filling, problem discovery and resolution activities. The inspectors also reviewed the subsequent Apparent

Cause Evaluation conducted by the Maintenance Department. The documents reviewed

during the inspection are listed in the Attachment.

b. Findings and Observations No findings of significance were identified. The inspectors determined that Entergy did not

follow tagout procedure requirements and did not identify that work had not been

completed on the "B" condensate pump prior to signing off the work boundary tagout. This

failure to comply with tagout requirements constitutes a violation of minor significance that

is not subject to enforcement action in accordance with the NRC's Enforcement Policy. In

addition, the inspectors identified that no condition report was written by Entergy to

document the tagout problem and the resultant interruption to the hotwell fill activity at the time of the occurrence. An apparent cause evaluation was subsequently conducted and

corrective actions identified under

TS surveillance requirement 4.8.1.1. On May 20, 2009, Entergy revised the

PNP-2009-02265 and was reviewed by the

inspectors.

.4 Operator Response to the Loss of Steam Jet Air Ejector Radiation Monitors

a. Inspection Scope (1 sample) On May 19, 2009, Operations determined that both pre-treatment (Steam Jet Air Ejector

(SJAE)) process radiation monitors were inoperable. As a result, Operators implemented

the Offsite Dose Calculation Manual (ODCM), Table 3.1-2, Radioactive Gaseous Effluent

Monitoring Instrumentation, requirements which allowed gases to continue to be released

from the

SJ [[]]

AE to the offgas system for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided the augmented offgas

system was not bypassed and that downstream post-treatment radiation monitors were

operable. Otherwise, the

OD [[]]

CM would require the plant to be in hot standby within 12

hours. Operations also reviewed TS 3.8.1, Main Condenser Offgas, which requires that

the gross gamma activity rate of noble gases measured at a main condenser pre-treatment

monitor station shall be limited to 500,000 µCi/second whenever steam is available to the

air injectors. TS 3.8.1 requires the plant to be shutdown within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if this limit cannot

be met. However, Operations determined that TS 3.8.1 was met by a satisfactory "grab"

sample that is obtained once every 31 days as described in

ODCM to remove the 72-hour shutdown

requirement and to instead allow gases to continue to be released from the

SJ [[]]

AE to the

augmented offgas (AOG) system as long as the AOG system is not bypassed, the post-

treatment radiation monitors were operable or tripped and capable of alarm and auto-

isolation of the main stack, the AOG charcoal area radiation monitor and control room

alarm are functional, and the TS 4.8.1.1 grab sample was performed once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

An additional option in the

ODCM revision is to perform

TS 4.8.1.1 grab samples every 4

hours.

The inspectors reviewed the condition of the

SJ [[]]

AE radiation monitors and concluded that

the inoperability of both

SJAE radiation monitors would affect the ability to show compliance with

TS 3.8.1. The inspectors reviewed the

ODCM and the subsequent

ODCM revision. The inspectors performed a review of the new

OD [[]]

CM requirements and the

existence of additional equipment (e.g., AOG charcoal radiation monitors) and increased

sampling activities, and concluded that the requirements of TS 3.8.1 could reasonably be

shown to be met with these actions in place. The documents reviewed during this

inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

.5 (Closed)

LER 05000293/2008-006-00, Automatic Scram Resulting from Switchyard Breaker Fault during Winter Storm The inspectors reviewed Entergy's actions associated with the

LER, which are addressed

in the corrective action program as

NRC Inspection Report 05000293/2008005, Section 4

PNP-2008-03962 and -03963. The event was

discussed in

OA3.5. No findings of

significance were identified and no violation of

NRC requirements occurred. The

LER

provided an accurate description of the event and follow-up actions, taken or planned,

were appropriate to address the event. This LER is closed.

.6 (Closed)

LER 05000293/2008-007-00, Momentary Loss of all 345

KV Off-Site Power to The Startup Transformer from Switchyard Breaker Fault The inspectors reviewed Entergy's actions associated with the LER, which are addressed

in the corrective action program as

NRC requirements occurred. The

PNP-2008-3980. The event was discussed in NRC

Inspection Report 05000293/2008005, Section 4OA3.6. No findings of significance were

identified and no violation of

LER provided an accurate

description of the event and follow-up actions, taken or planned, were appropriate to

address the event. This

LER is closed. 4

OA5 Other Activities

Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope During the inspection period, the inspectors conducted observations of security force

personnel and activities to ensure that the activities were consistent with Entergy security

procedures and regulatory requirements relating to nuclear plant security. These

observations took place during both normal and off-normal plant working hours. These

quarterly resident inspector observations of security force personnel and activities did not

constitute any additional inspection samples and were considered an integral part of the

inspectors' normal plant status reviews and inspection activities.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

On April 2, 2009, an Occupational Radiation Safety exit meeting was held with Mr. Kevin

Bronson, Site Vice President. The inspectors verified prior to the exit meeting that the

inspector was not provided any proprietary information. On May 4, 2009, an In Service Inspection exit meeting was held with Mr. Kevin Bronson,

Site Vice President. The inspectors verified at the exit meeting that the inspector was not

provided any proprietary information. On May 5, 2009, an Occupational Radiation Safety exit meeting was held with Mr. Kevin

Bronson, Site Vice President. The inspectors verified at the exit meeting that the inspector

was not provided any proprietary information.

On July 7, 2009, the resident inspectors conducted an exit meeting and presented the

preliminary inspection results to Mr. Stephen Bethay, and other members of the Pilgrim

staff. The inspectors confirmed that proprietary information provided or examined during

the inspection was controlled or returned to Entergy and the content of this report includes

no proprietary information.

ATTACH [[]]

MENT [[:]]

SUPPLE [[]]

MENTAL [[]]

INFORM [[]]

ATION A-1SUPPLEMENTAL

INFORM [[]]

ATION [[]]

KEY [[]]

POINTS [[]]

OF [[]]

CONTACT

Licensee personnel:

K. Bronson Site Vice President

R. Smith General Manager Pilgrim Operations

S. Bethay Director, Nuclear Safety Assurance

T. Kelly Radiation Protection Technician

C. Littleton Probabilistic Risk Assessment Engineer J. Lynch Licensing Manager

W. Lobo Licensing Engineer

W. Mauro Supervisor, Radiological Engineering

D. Noyes Operations Manager

I. Onorato Radiation Protection Technician

J. Onorato Radiation Protection Technician

J. Priest Radiation Protection Manager

M. Thornhill Radiation Protection Supervisor T. Trainor Outage Manager

J. West Radiation Protection Technician

LIST [[]]

OF [[]]

ITEMS [[]]

OPENED ,

CLOSED [[]]

AND [[]]

DISCUS [[]]

SED

Opened and Closed

NCV 05000293/2009003-01 Failure to Follow Procedure Resulting in Damage to Refueling

Mast

Opened

URI 05000293/2009003-02 Design Calculation of the Vital

MG Set Room Peak Temperatures

Closed

LER 05000293/2008006-00 Automatic Scram Resulting from Switchyard Breaker Fault During Winter Storm

LER 05000293/2008007-00 Momentary Loss of all 345

KV Off-Site Power to The Startup Transformer from Switchyard Breaker Fault

A-2LIST

OF [[]]

DOCUME NTS

REVIEW [[]]

ED Section 1R01

Procedure 8.C.40, Revision 24, Seasonal Weather Surveillance Procedure 2.1.37, Revision 25, Coastal Storm - Preparations and Actions

Procedure 2.1.42, Revision 8, Operation During Severe Weather

Procedure 5.2.2, Revision 31, High Winds (Hurricane)

PNP -2007-03609, Copies of Procedure 2.2.94 had the Wrong Revision Out in the Field

PNP -2009-02853, Wrong Revision of Procedure 2.2.94 in Intake Structure Toolbox

NRC Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power

PNP-2009-02835, Tornado Door 247 Found Open

Procedure 1.4.4, Revision 20, New England Power Grid Operations/Interfaces

Procedure 2.1.14, Revision 98, Station Power Changes

TS 3.5.B.3, Reactor Building Closed Cooling Water System

PNP-2008-1582, Discrepancies within Pilgrim Response to Generic Letter 2006-02

Procedure 1.5.22, Revision 11, Risk Assessment Process

ISO New England Procedure, Master/Local Control Center Procedure #1, Revision 7, Nuclear

Plant Transmission Operations

Master/LCC Procedure #1, Revision 7, Attachment A, Pilgrim Nuclear Station

Pilgrim Response to GL 2006-02, dated 4/03/2006

Section 1R04

Procedure 2.2.30, Revision 67, Reactor Building Closed Cooling Water System

DC -136, Revision 3, Temporary Modifications

PNP-2009-01468, Clarification of Temporary Modification Tag Requirements

Training Manual on RHR Shutdown Cooling

Procedure 2.2.19, Revision 99, RHR

Procedure 2.2.19.1, Revision 28, RHR System - Shutdown Cooling Mode of Operation

Procedure 8.9.1, Revision 112, Emergency Diesel Generator and Associated Emergency Bus

Surveillance

Procedure 2.2.8, Revision 94, Standby AC Power System (Diesel Generators)

Procedure 2.1.12.1, Revision 67, Emergency Diesel Generator Surveillance Training Manual, Reactor Core Isolation Cooling System

Procedure

3.M. 4-78, Revision 9,

RCIC Turbine Major Preventive Maintenance Inspection

Final Safety Analysis Report Chapter 4.7, Reactor Core Isolation Cooling System

Procedure 2.2.22, Revision 69, Reactor Core Isolation Cooling System

System Health Report

PNP -2009-02593, Rescheduling

RC [[]]

IC Inverter Replacement

PNP -2009-01976, Anomaly in the Seating of

RC [[]]

IC Steam Line Inboard Isolation Valve

IC Turbine Exhaust Line Check Valve Not Seating

PNP -2009-01887,

RC [[]]

8.B. 3.1, Revision 16, Fire Hose Station Equipment Inspection

PNP -2008-03356,

RC [[]]

IC Turbine Flow and Pressure Outside of Specified Parameters

A-3Section 1R05

UFS [[]]

AR Chapter 10.8, Fire Protection System

Fire Hazards Analysis Fire Area 1.30-Drywell

Procedure 5.5.2, Revision 42, Special Fire Procedure

Procedure 8.B.13, Revision 4, Hydrostatic Testing of Fire Hose

Procedure

PS Probabilistic Safety Assessment, Appendix E, Internal Flooding Analysis Equipment Out-of-Service Risk Assessment Tool

PNP-2009-01894, Self-Adhesive Knee Pads on Drywell Equipment

Fire Hazards Analysis

Fire Damper Test Results

UFS [[]]

AR Chapter 10.8.4.6, Fire Barrier System

Procedure 8.B.17.2, Revision 9, Inspection of Fire Damper Assemblies

Procedure 8.B.17.1, Revision 19, Inspection of Fire Door Assemblies

Procedure 8.B.14, Revision 41, Fire Protection Technical Requirements

Exemption Request #7, Fixed Suppression and Twenty-Foot Separation with no Intervening Combustibles Exemption Request #9, Fixed Suppression Where Alternate Shutdown Capabilities Exist Section 1R06

PN [[]]

PN [[]]

PS Flooding Calculations

Timeline of Fire Response to Fire in the HP Cal Lab

Section 1R08 Non Destructive Test (NDT) Examination Reports

PT -09-002, Liquid Penetrant Examination Summary Sheet

ISI -I-11-1, weld B-11-159,

SBLC system, pipe to valve butt weld

MT -09-008, Magnetic Particle Examination Summary Sheet

ISI -I-23-2-

EB -23-13HL1(4), Support Lugs, High Pressure Coolant Injection system, integral attachment

UT -09-023, Ultrasonic Calibration/Examination, Summary Sheet

ISI -I-1-1SH2-1-SD-1, Main Steam system, weld

1SD -1, pipe to cap weld

RT -09-003, Radiographic Examination Summary

ISI -I-1-1

SH 2-1-SD-10R

NDT Examination Procedures

ENN -NDE-10.01, Revision 3,

VT -1 Examination

ENN -NDE-10.02, Revision 3,

VT -2 Examination

ENN -NDE-10.03, Revision 2,

VT -3 Examination

ENN -NDE-9.40, Revision 1, Liquid Penetrant Examination

NDE -9.41, Revision 1, Liquid

PT for

ENN -NDE-9.31, Revision 1, Magnetic Particle Examination (MT) for

XI [[]]

XI [[]]

NDE -9.04, Revision 2, Ultrasonic Examination of Ferritic Piping Welds (ASME Section

XI )

TP08-034 R0, Temporary Procedure for Phased Array Ultrasonic Examination of Core Shroud Assembly Welds Using Sector-Line Scanning

A-4 In Vessel Remote Visual Examination

INR -P1R17-

IVVI -09-01, Steam Dryer Leveling Screw Tack Weld

INR -P1R17-

IVVI -09-02, Steam Dryer Divider Plate Anchor

INR -P1R17-

IVVI -09-03, Steam Dryer Separator Shroud Head Bolt #18 Condition Reports

PNP -2009-01173, Mechanical Design specification M301 has error on Table

1 CR -

PNP -2009-01531,

IVVI inspection noted slight wear latched pin location shroud head bolt #18

CR -PNP-2009-01767,

IVVI inspection noted

FME at various locations

PNP -2009-01514, Identified linear indication at

RPV head to flange weld

CR -PNP-2009-01673, Unable to inspect nozzle

RPV -N9A-1

CR -PNP-2009-01688, Evaluate area of corrosion identified on core spray piping

PNP -2007-02093, Various areas identified as needing coating repairs in drywell

PNP -2009-01180, "B" loop

RHR piping support has cracking in saddle to pipe stitch weld

CR -PNP-2009-01182, Error in piping specification M301, Extent of Condition

PNP -2009-01285, Design drawing does not show installed tack welds,

RHR containment spray pipe support

CR -PNP-2009-02084, One dimension on the N9A overlay did not achieve minimum

PNP -2009-01977, Tack weld should have been mechanically removed Work Orders

WO 00133037, Fabrication of

SSW , system 29, spool piece

JF 29-19-1 for application in Loop B

WO 00133039 , Shop fabrication of spool piece

JF 29-15-7 for

SSW system

WO 00193071 , Removal of cracked tack weld on support H-10-1-12 Miscellaneous

NOP 83M1 R9,

ASME Code Repairs and Replacements

TP 08-028, Procedure for

IVVI of

BWR [[]]

2 RPV Internals

EN -LI-102 R13, Corrective Action Process

NDE -9.23, Revision 1, Indication Evaluation Flow Chart (Attachment 9.7)

CS -1/1-

RMD R0, Weld Procedure Specification for Gas Metal Arc Welding (GMAW) of carbon steel

LO -

PNPLO -2008-00135, Self-Assessment of the

PNPS [[]]

ISI Program Procedure Qualification Record

PQR 3355, Welding Procedure Qualification Record for

GMAW , semi-automatic, carbon steel to carbon steel

EN -0275, Welder Qualification, History and Continuity Log

PRR -19, Pilgrim Relief Request for weld overlay repair of

RPV Jet Pump Instrumentation Nozzle Weld,

RPV-N9A-1 Certificate of Examiner performance qualifications for penetrant, magnetic particle, ultrasonic (manual, performance demonstration initiative) and visual (VT1, 2 and 3). Documentation includes training and vision test results for selected examiners.

A-5 Section 1R11

Lesson Plan O-RQ-04-04-58, RFO 17 Just-In Time Training

Control Rod Drive Matrix Schematic

Significant Event Report 2-08, Reduced Shutdown Safety Margins

Section 1R12

Procedure

DC-203, Revision 1, Maintenance Rule Program

Procedure

DC-207, Revision 1, Maintenance Rule Periodic Assessment

Procedure

DC -205, Revision 1, Maintenance Rule Monitoring

NUMARC 93-01, Revision 2, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants Procedure

EN-DC-206, Revision 1, Maintenance Rule (a)(1) Process

Regulatory Guide 1.160, Revision 2, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants Procedure

DC-204, Revision 1, Maintenance Rule Scope and Basis

Scram Data Sheets

Technical Basis for Revising Maintenance Rule Unavailability Performance Criteria for Lines 342 and 355 Maintenance Rule

SSC Basis Document

8.M. 3-1, Special Test for Automatic

PNP-2008-3962, Reactor Scram Due to Switchyard Fault Section 1R13

Refueling Outage 17 Risk Review Report

Departure from Defense In-Depth Form for Power Availability Risk Assessment Review Checklists

Procedure 3.M.1-45, Revision 7, Outage Shutdown Risk Assessment

Departure from Defense In-Depth Forms dated 3/11/09, 4/8/09, 4/22/09 and 4/26/09

Temporary Procedure No.

TP 09-012, Revision 0,

RFO-17 Compensatory Measures

RFO 17 Outage Shift Turnover Sheets dated 4/23/09, 4/24/09 and 4/27/09

Procedure

ECCS Load Sequencing of Diesels and Shutdown Transformer with Simulated Loss of Off-site Power and Special Shutdown Transformer

Load Tests Outage Risk Notebook

Procedure 8.M.2-1.5.9, Revision 26, Primary Containment Isolation Valve Testing

Section 1R15

PNP -2009-01182, Main Steam Drain Line Valve Weld not radiograph tested as specified by

PWT [[]]

MR for Main Steam Outside Containment for

RFO #13

WO 01103702,

PWT for Vessel Hydro for RFO #13

AR Chapter 4.11, Main Steam Lines and Feedwater Piping

OP-104, Operability Determinations Inspection Manual Part 9900, Technical Guidance

A-6Specification M301, Field Fabrication and Installation of Piping and Instrumentation

UFS [[]]

PNP -2009-01315, Operability Evaluation without Discussion of Visual Exam Operability Evaluation on CR-2009-01261 Procedure 2.2.108, Revision 42, Diesel Generator Cooling and Ventilation System

PNP -2009-01261, Diesel Damper Vanes did not close all the way

PNP -2009-02016, Shutdown Transformer Relay did not close within its Technical Specifications Timeband

PNP-2009-02502, "B" Feed Regulating Valve Digital Controller Faults

Operational Decision-Making Issue (ODMI) for

AR , Chapter 7.10, Feedwater Control System

PNP-2009-02502, Revision 0, dated May 22, 2009 Procedure 2.4.49, Revision 40, Feedwater Malfunctions

Procedure 2.2.82, Revision 41, Reactor Vessel Water Level Control System

Final Safety Analysis Report, Chapter 11.8. Condensate and Feedwater System

UFS [[]]

PNPS Appendix R Exemption Summary, Exemption Summary #17, Emergency Lighting in the Yard Area

PNP-2009-02707, Security Emergency Diesel Generator Does Not Meet Acceptance Criteria

Fire Hazards Analysis

Procedure 8.9.14, Revision 31, Security Diesel Generator Surveillance

UFSAR Chapter 10.8, Fire Protection System

Procedure 2.2.153, Revision 10, Security Diesel Generator and Backup Power System

PNP -2009-02755, Functionality of

3.M. 2-40, Revision 6, Refuel Outage Temporary Modification Reactor Shutdown/Flood-up Level Indication Control Room Logs

PNP-2009-02707 Does Not Address Appendix R 8 Hour Lighting Requirement Section 1R18

Procedure

DC -136, Revision 3, Temporary Modifications

3.M. 3-36.7, Revision 0, Temporary Power for 125V

PNP-2009-02085, NRC Resident Identified a tag missing from a level transmitter bypass valve

Procedure

DC Bus "A" or "B"

Procedure 2.2.19.1, Revision 28, Residual Heat Removal System - Shutdown Cooling Mode of Operation Control Room Logs for Temporary Modification Installation/Removal and Limiting Condition for Operation Entry

PNP-2009-02187, Control Room Drawing not annotated as specified by the Procedural Temporary Modification and paperwork not retained in the Control Room as specified by

Procedure

PNP-2009-00991, Modification in Vital MG Set Room Basis Not Retrievable

Standard Review Plan 9.4.5, Revision 2, Engineered Safety Feature Ventilation System

Turbine Building Design Calculation

SD [[]]

BD-24, Revision O

ER 06118315, Update Structural Drawing C194 with Fan Detail

Procedure 2.4.153, Revision 18, Loss of Turbine Building Ventilation

Procedure

MS-S-009-PNPS, Revision 0, System Safety Function Sheets

Memorandum dated May 15, 1992, Assessment of Heatup of Vital

MG -Set Room

UFS [[]]

AR 10.9-2, Design Temperatures

A-7Calculation N124, Revision 0, Vital

MG -Set Room Heatup

FRN-87-73-29, Seismic Restraints for Permanently Installed Booster Fan

Procedure 5.3.18, Revision 27, Loss of 120V AC Safeguard Buses Y3 and Y31

Cutler Hammer Circuit Breakers Data Sheets

EC -4350, Revision 0,

HPCI [[]]

TC [[]]

TD [[]]

LI -100, Attachment 9.1, Revision 6, Process Applicability Determination Form for

EC -4350

EN -DC-117, Revision 1, Post Modification Test Plan Form for

EC -4350

ECN #14227

ECN #14227, Engineering Change Notice Summary Form for

EC-4350

Engineering Calculation C15.0.3434, Motor Stand for the

HPCI [[]]

TCTD Procedure

8.I. 1.1, Revision 22, Inservice Pump and Valve Testing Program Procedure 8.5.4.1, Revision 104,

HPCI System Pump and Valve Quarterly and Biennial

Comprehensive Operability

PNP -2009-02861, Completed Work Order Tasks for the

HPCI [[]]

TCTD Post Modification Tests

Cannot be Found

UFSAR Section 8.10, Blackout

DC-117, Revision 2, Post Modification Testing and Special Instructions

Section 1R19

AC Power Source

WO 51546813, Bench Test of New Governor

TP 09-001, Revision 0, Manual Start and Loading of

MA -102, Revision 2,

PN [[]]

PS Inspection

Temporary Procedure

SBODG via Safety

Bus A5 or A6 and Governor Response Check

V-0540, Blackout Diesel Generator Vendor Manual

Procedure 8.9.16.1, Manually Start and Load Blackout Diesel via the Shutdown Transformer

Station Blackout Governor Tuning Data

WO 51685930 01,

MO -1001-50 MOV Maintenance and Inspection

WO 51685930 02,

MO -1001-50 Post Maintenance Test

WO 00164837 01, Replace Motor on

MO-1001-50

Procedure 3.M.3-51, Revision 26, Electrical Termination Procedure

Procedure

8.Q. 3-8.2, Revision 15, Limitorque Type

HBC ,

SB /

SMB -0 through

SB -

SMB-3 Valve

Operator Maintenance

WO 00164837 02, Post Work Test

MO -1001-50

PNP -2009-02210, Post work Test Procedure for MO-1001-50 work cannot be located

PNP -2009-02273, Discrepancies Identified in Work Package 51685930

EC 12474 for Motor Replacement for

MO -1400-25A

WO 516865 01, Stem Lube for

MO-1400-25A

Procedure

3.M. 3-24.15, Revision 7, Valve Stem Lubrication

WO 00164834, Replace Motor on

MO-1400-25A

CR -2007-0844, Motors with Magnesium Rotors Should be replaced

WO 5153464 202, Replacement of the "B" 125

VDC Battery Bank

Procedure 8.9.8.2, Revision 20, "B"

125VDC Battery Acceptance, Performance or Service Test

EC 12778, Replace Fan Unit

PNP-2009-1705, The End of First Step Voltage Value was not met during the Service

Discharge Test 8.9.8.2

Procedure 3.M.3-25.3, Revision 13, Resistance Testing and Torquing of Station Batteries

Procedure 3.M.3-51, Revision 26, Electrical Termination Procedure

WO 00169979 01, 8.9.8.2B 125V D1 Battery Acceptance or Performance Test

TS 4.9.A.2, Station and Switchyard Batteries

A-8CR-PNP-2009-2538, Incorrect length of time chosen for battery equalizing time

WO 001485909 01,

VAC 205D1 in

RFO 17

Procedure 3.M.3-17.1, Revision 23, Raychem or Taping of 1000 Volt and Under Cables and/or

Wires

Procedure 3.M.3-4, Revision 53, Insulation Test

EC12133, Evaluate and Incorporate Replacement Fan Housing and Fan

Wheel Changes for

VAC -205's Howden Buffalo Quote

ENT -DF-BH-060908

CRD /HCU Post Maintenance Test

PNP-2009-2618, Post Maintenance Tests missing from Work Order

Technical Specifications

WO 163704, Perform

WO 51678259, 3.M.4-76 Scram Inlet & Outlet Valves

CV 126 &

CV 127 (

HCU -38-07)

WO 51686316, 3.M-4-76 Scram Inlet & Outlet Valves

CV 126 &

CV 127 (

HCU-22-47)

WO 51527475, Remove and Replace Pump Internals, P201, Dust Maintenance

Power Maneuver Load Profile 5/12/09 Startup

Temporary Procedure TP08-017, Revision 1, Functional Test Following P-201A Rotating Element,

Cover and Motor Replacement

Procedure 2.2.84, Revision 100, Reactor Recirculation System

Procedure

8.F. 42, Revision 14, Recirculation System Instrumentation Calibration

WO 51531741 02, Replace Reactor Head Vent Valves,

EC8218

EC 8218, Replace Reactor Head Vent Valves

3.M. 1-45, Revision 7, Outage Shutdown Risk Assessment

MA-102, Attachment 9.2, Inspection Report of Electrical Portion of EC8218

Technical Manual for Target Rock Solenoid Operated Valve, Model 082511-001

Procedure 1.13.1, Revision 6, Postwork Test Matrices and Guidelines

Procedure 3.M.1-30, Revision 10, Postwork Testing Guidance

Section 1R20

NUR [[]]

EG-0612, Control of Heavy Loads at Nuclear Power Plants

Procedure

NUR [[]]

EG-1449, Shutdown and Low Power Operation at Commercial Nuclear Power Plants in the

United States

RFO-17, Just-In-Time Training

NRC Information Notice 93-72, Observations from Recent Shutdown Risk and Outage

Management Pilot Team Inspections

NRC Generic Letter 98-02, Loss of Reactor Coolant Inventory and Associated Potential for Loss

Of Emergency Mitigation Functions while in a Shutdown Condition

NRC Information Notice 2005-16, Outage Planning and Scheduling Impacts on Risk

Temporary Procedure TP08-027, Revision 0, Administrative Controls for Recirculation Pump

Motor Project P-201A Heavy Load Handling Activities in the Drywell

PNP-2009-02015, Station Risk Review Refers to TS 3.10D, which no longer exists

Pilgrim Relief Request 19, Jet Pump Instrumentation Nozzle Weld, RPV-N9A-1 Repair Plan

Procedure 2.2.19.1, Revision 28, Residual Heat Removal System - Shutdown Cooling Mode of

Operation

OP -104, Revision 3, Operability Determination

RPV -N9A-1 Weld Overlay (

LI-102, Revision 13, Corrective Action Process

Procedure 3.M.4-9, Revision 14, Inspection of the Drywell and Suppression Chamber

Procedure 3.M.1-51, Revision 5, Readiness for Restart Reviews

A-9 Entergy Memorandum dated May 15, 2009, Results of UT Examination of Jet Pump

Instrumentation Nozzle

TAC No. ME1151)

PNP -2009-2414, Drywell Cleanup Should Have Occurred Days Earlier

PNP -2009-2424, Locking Nut Adjusted By Engineer without a Work Order

PNP -2009-2413, C-19B Failed Particulate functional check with C-19A Out-of-Service

PNP -2009-2421, C-19B Relay Chattering

PNP-2009-2386, PV-9239 300# Regulator Connecting Link Assembly Nut Tightened by

Engineer

IU -103, Revision 0, Human Performance Error Reviews

PNP-2009-2408, Results of Drywell Inspection

RFO-17 Daily Outage Shift Turnover Sheets

Procedure 2.1.1, Revision 167, Startup from Shutdown

Procedure 2.1.14, Revision 98, Station Power Changes

Procedure 2.1.5, Revision 109, Controlled Shutdown from Power

Procedure 2.1.7, Revision 52, Vessel Heatup and Cooldown

Contingency Plan for Freeze Seal on HCU50-39

Part 9900: Technical Guidance, Mechanical Freeze Plugs

EN -I-

PNP-2009-1828, Control Rod Blade Moved to the Wrong Location

Critical Step Review for Bridge Operation

Section 1R22

Procedure 8.7.1.6, Revision 25, Local Leak Rate Testing of the Main Steam Isolation Valves

PNP -2009-01598, Outboard Main Steam Isolation Valve "D" Failed Local Leak Rate Testing

MS [[]]

IV As-Found Leak Rate @ 23 psig

TS 4.7.A.4, Primary Containment Integrity Surveillances

8.M. 3-1, Special Test for Automatic

PNP-2009-02016, Loss of Offsite Power Test Acceptance Criteria Not Met

Procedure 1.3.34, Revision 116, Operations Administrative Policies and Processes

Procedure

ECCS Load Sequencing of Diesels and Shutdown

Transformer with Simulated Loss of Offsite Power and Special Shutdown Transformer

Load Test

Procedure 9.9, Revision 64, Control Rod Scram Insertion Time Evaluation

Control Rod Scram Testing Data Forms

Technical Specifications Amendment 279, Revise Requirements for Control Rod Scram Insertion

Times

PNP-2008-00748, Control Rod 22-07 Identified as a Slow Rod

Procedure 2.1.8.5, Revision 21, Reactor Vessel Pressurization and Temperature Control for

Class 1 System Leakage Test

Procedure 8.7.1.4.1, Revision 19, Primary Containment Integrated Leak Rate Test Preparations

Procedure 8.7.1.4.2, Revision 17, Primary Containment Integrated Leak Rate Test

PNP -2009-02614, Documentation of Lifted Leads and Jumpers could not be found

RT Test Procedure Discrepancies

PNP -2009-02677,

IL [[]]

PNP -2009-02452,

HP [[]]

CI run allowed reactor pressure to drop significantly

Procedure 8.5.4.3, Revision 48, High Pressure Coolant Injection Operability Demonstration And Flow Rate Test at 150 psig

PNP-2009-02856, Leakage Rate Test Results Discrepancies observed

A-10 Section 1EP6

Procedure

EP -

IP-100.1, Revision 5, EALs

Controller Manual Combined Functional Drill (09-02), May 28, 2009 EP Performance Indicator Reporting Form

Section 2OS1

Procedures:

RP -100 Rad Worker Expectations, Revision 3

RP -104 Radiation Work Permits, Revision 4

RP -106 Radiological Survey Documentation, Revision 2

RP -108 Radiation Protection Postings, Revision 7

RP -110

ALA [[]]

RA Program, Revision 5

RP -131 Air Sampling, Revision 6

RP-150 Radiography and X-Ray Testing, Revision 5

6.1-220 Radiological Controls for High Risk Evolutions, Revision 5 Condition Reports:

2008-03470, 03481, 03498, 03575, 03576, 03604, 03632, 03639, 03733, 03759, 03845, 04077

2009-00665, 01057, 01115, 01138, 01139, 01379, 01458, 01459, 01462, 01474, 01483, 01487,

01603, 01626, 01666, 01682, 01693, 01698, 01723, 01725, 01821, 01885 Radiation Work Permits:

2009-0016, 0039, 0050, 0051, 0052, 0053, 0054, 0055, 0056, 0064, 0065, 0066, 0067, 0068,

0073, 0090, 0093, 5016, 0035, 0040, 0042, 0043, 0049, 0063, 0069, 0070, 0074, 0079, 0083,

0085, 0086, 0100, 0101, 0105, 0107, 0501

Other

2007 Radiation Protection Program Annual Report

Section 2OS2

Procedures:

RA Managers Committee Meeting Minutes

RP -110

ALA [[]]

RA Program, Revision 5

6.1-220 Radiological Controls for High Risk Evolutions, Revision 5

Condition Reports:

2008-03562, 03631, 03758, 03675

2009-00045

A-11

ALA [[]]

ALA [[]]

RA Subcommittee Meeting Minutes

PM09-08

Miscellaneous Records & Reports:

Hot Spot Master Tracking list as of 3/31/2009

Pilgrim Station 5 Year

ALA [[]]

RA Plan

PNPS [[]]

RFO 17 Chemistry Start Up / Shutdown and Outage Control Plan

Section 4OA1

NRC Performance Indicator Report for Pilgrim

NEI 99-02, Revision 5, Regulatory Assessment Performance Indicator Guidelines

Licensee Event Reports Issued from the 1st quarter 2008 through the 1st quarter 2009 TS 3.6.B, Coolant Chemistry

Pilgrim Chemistry Records for Reactor Coolant System Radioactivity (Total Iodine per ml of Water) Control Room Logs

PI Data Sheets

Procedure

LI-114, Revision 4, Performance Indicator Process

Section

4OA 2

PNP -2009-02618, Drywell Cooler Missing PMT

PNP -2009-02648 and -02676, Head Vent Valve Missing PMT

PNP -2009-02861,

HPCI [[]]

TCTD Missing PMT

PNP -2009-2778, PMT Low Level Trend

TM [[]]

TM [[]]

OD Control Room Drawing Not Updated

TM [[]]

PNP -2009-3064,

TM [[]]

OD Low Level Trend

PNP -2008-00946, Inaccurate Assessment of Station Risk

PNP-2008-03792, Failure to Conduct at Risk Review for Out-of-Service Equipment

RFO-17 Outage Risk Assessment Report

RFO-17 Daily Shutdown Risk Assessments

Non-Cited Violation (NCV)05000293/2008002-01, Inadequate Risk Assessment for Emergent Maintenance on A5 Emergency Bus Undervoltage Relays NCV 05000293/2008005-01, Failure to Conduct a Risk Assessment for Emergent Maintenance

On the High Pressure Coolant Injection System

A-12 Section 40A3

Technical Specification 3.9, Auxiliary Electrical System

Control Room Logs

Procedure 2.4.A.23, Revision 12, Loss/Degradation of

23KV Line

PNP-2009-1951, Loss of 23KV Power Supply to the Shutdown Transformer

Operations and Maintenance Event Timelines

PNP-2009-02265, Installation Sequence for Condensate Pump Lantern Ring Necessitated Additional Engineering and Maintenance Resources WO 00135745, Task 1, Condensate Pump "B"

Personnel Statements

PNP-2009-1581, Inadequate Tagout for "B" Condensate Pump

Condensate and Feed Maintenance Rule Basis Document

PNP-2009-2300, Nuclear Safety Concern with "B" Condensate Pump Work

"B" Condensate Pump Tagout

Control Room Narrative Logs

Outage Control Center Log

Tagout Log