Text

May 6, 2009

Mr. Kevin Bronson, Site Vice President Pilgrim Nuclear Power Station Entergy Nuclear Operations, Inc.

600 Rocky Hill Road Plymouth, MA 02360-5508

SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000293/2009002

Dear Mr. Bronson:

On March 31, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Pilgrim Nuclear Power Station (PNPS). The enclosed inspection report documents the results, which were discussed on April 8, 2009, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The report documents two NRC-identified findings of very low safety significance (Green). Both of these findings were determined to involve violations of NRC requirements. However, because the findings are of very low safety significance and the findings have been entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs)

consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator of Region I; the Director, Office of Enforcement; and the NRC Resident Inspectors at PNPS. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspectors at PNPS. The information you provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Mel Gray, Chief Projects Branch 2 Division of Reactor Projects

Docket No. 50-293 License No. DPR-35

Enclosure:

Inspection Report 05000293/2009002

w/Attachment:

Supplemental Information

cc w/encl: Vice President, Operations, Entergy Nuclear Operations Vice President, Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety & Licensing, Entergy Nuclear Operations Senior Vice President and COO, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations R. Walker, Director, Radiation Control Program, Commonwealth of Massachusetts The Honorable Therese Murray The Honorable Vincent deMacedo Chairman, Plymouth Board of Selectmen Chairman, Duxbury Board of Selectmen Chairman, Nuclear Matters Committee Plymouth Civil Defense Director D. O'Connor, Massachusetts Secretary of Energy Resources J. Miller, Senior Issues Manager Office of the Commissioner, Massachusetts Department of Environmental Protection Office of the Attorney General, Commonwealth of Massachusetts Electric Power Division, Commonwealth of Massachusetts R. Shadis, New England Coalition Staff D. Katz, Citizens Awareness Network W. Meinert, Nuclear Engineer J. Giarrusso, MEMA, SLO Commonwealth of Massachusetts, Secretary of Public Safety

SUMMARY OF FINDINGS

.............................................................................................................. 2

REPORT DETAILS

REACTOR SAFETY

........................................................................................................................ 4 1R01 Adverse Weather Protection ......................................................................................... 4 1R04 Equipment Alignment .................................................................................................... 5 1R05 Fire Protection ............................................................................................................... 6 1R07 Heat Sink Performance ................................................................................................. 6

1R11 Licensed Operator Requalification Program ................................................................ 7 1R12 Maintenance Effectiveness ........................................................................................... 7 1R13 Maintenance Risk Assessments and Emergent Work Control .................................. 10 1R15 Operability Evaluations ............................................................................................... 10 1R18 Plant Modifications ...................................................................................................... 13 1R19 Post-Maintenance Testing .......................................................................................... 13 1R22 Surveillance Testing .................................................................................................... 14 1EP6 Drill Evaluation

OTHER ACTIVITIES (OA)

............................................................................................................. 15

4OA1 Performance Indicator (PI) Verification ....................................................................... 15 4OA2 Identification and Resolution of Problems .................................................................. 15 4OA3 Event Follow-up .......................................................................................................... 16 4OA5 Other Activities ............................................................................................................ 18 4OA6 Meetings, Including Exit .............................................................................................. 18 ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

...................................................................................................... A-1

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED ........................................................... A-1

LIST OF DOCUMENTS REVIEWED

.......................................................................................... A-2

LIST OF ACRONYMS

...... ........................................................................................................... A-7

2SUMMAR Y

OF [[]]

FINDIN [[]]

GS

IR 05000293/2009-002; 01/01/2009 - 03/31/2009; Pilgrim Nuclear Power Station; Maintenance

Effectiveness and Operability Evaluations.

The report documents the results of a three-month period of inspection by the resident inspectors.

Two Green findings were identified, both of which were determined to be non-cited violations

(NCVs). The significance for most findings is indicated by their color (Green, White, Yellow, Red)

using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). The

cross-cutting aspect for each finding was determined using IMC 0305, "Operating Reactor

Assessment Program." Findings for which the SDP does not apply may be Green or be assigned

a severity level after

NRC management review. The

NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in

NUR [[]]

EG-1649, "Reactor Oversight

Process," Revision 4, dated December 2006.

A. [[]]

NRC -Identified and Self-Revealing Findings Cornerstone: Mitigating Systems * Green. The inspectors identified a non-cited violation (NCV) of very low safety significance of

10 CFR Part 50, Appendix B, Criterion

III [[, "Design Control," because Entergy personnel did not establish and maintain measures to monitor critical design parameters to assure that equipment and processes essential to the safety-related function of the emergency diesel generator (EDG) air start system were adequate. Specifically, Entergy did not establish adequate measures to assure that an adequate supply of air was available to the air receivers for a minimum of two cold engine starts without recharging. This resulted in the "A"]]

EDG being inoperable on March 8, 2009. Entergy entered this issue into their corrective action program (

CAP ) for resolution as

CR -

PNP-2009-00807. The immediate corrective actions included establishing compensatory requirements to increase the monitoring frequency for the air start system critical parameters. This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the finding affected the reliability of the EDG to ensure a minimum of two cold engine starts without recharging to help mitigate the consequences of design basis events. The inspectors determined that the finding is of very low safety significance (Green) because it is not a design or qualification deficiency, did not represent a loss of safety function, and did not screen as potentially risk significant due to external events. There is no cross-cutting aspect identified for this finding because the inspectors determined that the performance deficiency is not reflective of current plant

performance. The monitoring frequencies of the EDG air start system critical

parameters were established for an extended period and prior to this problem there

had not been recent issues with monitoring EDG air start capability. (Section 1R12)

3* Green. The inspectors identified an

NCV of very low safety significance of Technical Specification 5.4.1 "Procedures," because Entergy personnel did not adequately implement procedure requirements in accordance with

EN -MA-133, "Control of Scaffolding." Specifically, personnel did not erect scaffold in accordance with procedure

EN -

MA -133 and maintain the minimum distance erection requirements for safety-related equipment or alternatively perform engineering evaluations that concluded the equipment will not be impacted by the scaffolds. Entergy entered this issue into their

CAP for resolution as

CR-PNP-2009-00064, implemented prompt actions to correct the scaffolds, and performed engineering evaluations to assess the affect of the scaffolds on the safety-related equipment. The finding is more than minor because it is associated with the external factors attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to

ensure the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Additionally, the finding is similar to example 4.a in

Appendix E of IMC 0612 in that personnel did not routinely perform engineering

evaluations for scaffolds constructed less than the minimum allowed distance to safety-

related equipment. The inspectors determined that the finding is of very low safety

significance (Green) because the scaffold issues identified were not a design or

qualification deficiency, did not represent a loss of safety function, and did not screen

as potentially risk significant due to external events.

This finding has a cross-cutting aspect in the area of Human Performance because

Entergy's supervisory and management staff did not provide adequate oversight of

workers or communicate expectations to workers to ensure scaffold erection

requirements were fully understood (H.4.c of IMC 305). (Section 1R15)

B. Licensee-Identified Violations None.

4REPORT [[]]

DETAILS

Summary of Plant Status

Pilgrim Nuclear Power Station (PNPS) operated at or near 100 percent reactor power during the

inspection period with the following exceptions: On February 4, 2009, Entergy operators reduced

reactor power to 75 percent as requested by the Independent System Operator- New England

(ISO-NE) due to work on the offsite grid and resumed full power the same day. On February 12,

2009, operators reduced reactor power to 54 percent as requested by

ISO -

NE due to work on the

offsite grid and resumed full power the following day. On February 22, 2009, operators reduced

reactor power to 75 percent to perform a rod pattern adjustment and resumed full power the same

day. On March 16, 2009, operators reduced reactor power to 72 percent to perform a rod pattern

adjustment and resumed full power the same day. Operators maintained the reactor at 100

percent power for the remainder of the inspection period. 1.

REACTO R

SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01 - 2 samples)

.1 Seasonal Susceptibility a. Inspection Scope

The inspectors reviewed actions taken by Entergy personnel in preparation for the onset of

cold weather during the week of January 19, 2009. The inspectors reviewed procedure

8.C.40, Seasonal Weather Surveillance, and verified selected steps were completed. The inspectors walked down selected areas addressed in the procedure to determine if heat

tracing as well as ventilation systems were properly working. The inspectors walked down

portions of the intake structure, salt service water pump area and the technical support

center emergency diesel generator room. The documents reviewed during the inspection

are listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 Impending Winter Storm

a. Inspection Scope On February 3, 2009, a winter storm warning was in affect for the surrounding areas of the

site. The inspectors reviewed Entergy's preparations for the impending winter storm as

well as for the high winds expected to accompany the storm. The inspectors reviewed

procedure 2.1.37, Coastal Storm Preparations and Actions. The inspectors conducted a

tour of the plant grounds and the switchyard to determine if loose debris or other material

could become airborne in the presence of high winds or if snow accumulation could impact

5safety-related equipment. The documents reviewed during the inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment (71111.04)

.1 Partial System Walkdowns (71111.04Q - 4 samples)

a. Inspection Scope

The inspectors performed four partial system walkdowns during this inspection period. The

inspectors reviewed the documents listed in the Attachment to determine the correct

system alignment. The inspectors conducted a partial walkdown of each system to

determine if the critical portions of the selected systems were correctly aligned in

accordance with procedures and to identify discrepancies that may adversely impact

operability. The walkdowns included selected switch and valve position checks, and verification of electrical power to critical components. In addition, the inspectors evaluated

other elements, such as material condition, housekeeping, and component labeling. The

documents reviewed during the inspection are listed in the Attachment.

The following systems were reviewed based on their risk significance for the given plant

configuration:

Core spray (CS) "A" while

CS "B" was out of service for maintenance; * Reactor core isolation cooling (

RCIC ) following maintenance on the

RCIC alternate shutdown panel; * Residual heat removal (

RHR ) "A" with

RHR "B" out of service; and * "B" emergency diesel generator (

EDG) with the "A" EDG out of service.

b. Findings No findings of significance were identified.

.2 Complete System Walkdown (71111.04S - 1 sample) a. Inspection Scope The inspectors completed a detailed review of the salt service water (SSW) system to

verify the functional capability of the system. The inspectors conducted a walkdown of the system to determine whether the critical components, such as valves, switches, and

breakers were aligned in accordance with procedures and to identify discrepancies that

could impact system operability. The inspectors discussed system health such as material condition and vibration trending data with the system engineer to determine whether known

deficiencies significantly affected the SSW system function. The inspectors also reviewed

condition reports (CRs) to determine whether SSW equipment problems were being

6identified and appropriately resolved. The documents reviewed during the inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05) Fire Protection - Tours (71111.05Q - 5 samples)

a. Inspection Scope

The inspectors performed walkdowns of five fire protection areas during the inspection

period. The inspectors reviewed Entergy's fire protection program to determine the

required fire protection design features, fire area boundaries, and combustible loading

requirements for the selected areas. The inspectors walked down areas to assess

Entergy's control of transient combustible material and ignition sources. The inspectors

also evaluated the material condition and operational status of fire detection and

suppression capabilities, fire barriers, and related compensatory measures. The inspectors then compared the existing condition of the areas to the fire protection program

requirements to determine whether program requirements were met. In addition, the

inspectors reviewed Entergy's response and contingency plan for backup fire fighting

capabilities from January 8 to January 9, 2009, following a fire system pipe rupture near the Health Physics check point. The fire system pipe rupture on January 8, 2009,

degraded portions of the station's fire water system. The documents reviewed during the

inspection are listed in the Attachment. The fire protection areas reviewed were the

following: * Multiple fire areas affected by the fire system pipe rupture on January 8, 2009; * Fire Area 1.9, Fire Zone 1.11 - east side on elevation 51' and reactor water cleanup equipment area; * Fire Area 1.10, Fire Zone 1.28 - recirculation pump motor generator set room; * Fire Area 1.21, Fire Zone 1.21- reactor building closed cooling water (RBCCW) pump room; and * Fire Area 1.10, Fire Zone 1.3 - high pressure coolant injection (HPCI) pump room. b. Findings No findings of significance were identified.

1R07 Heat Sink Performance (71111.07 - 1 sample)

a. Inspection Scope The inspectors reviewed one sample of Entergy's program for maintenance, testing, and

monitoring of risk significant heat exchangers (HXs) to assess the capability of the

HX s to perform their design functions. The inspectors assessed whether the

HX program

7conformed to Entergy's commitments at Pilgrim related to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment." In addition, the

inspectors evaluated whether potential common cause heat sink performance problems

could affect multiple HXs in mitigating systems or result in an initiating event. Based on

risk significance and prior inspection history, the "A" turbine building closed cooling water

(TBCCW) heat exchanger was selected for detailed review by the inspectors. Documents

reviewed during the inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11)

Resident Inspector Quarterly Review (71111.11Q - 1 sample)

a. Inspection Scope The inspectors observed one sample of licensed operator requalification testing on

January 12, 2009. Specifically, the inspectors observed crew response to an accident

scenario involving the loss of the main transformer and "B" emergency diesel generator

followed by a loss of offsite power, and a subsequent loss of coolant accident. The

inspectors assessed the testing to determine if the training evaluators adequately

addressed observed deficiencies regarding crew response and the use of emergency

operating procedures and emergency action level classification and notification

procedures. In addition, the inspectors conducted a simulator fidelity review to determine if

the arrangement of the simulator instrumentation and controls closely paralleled that of the

control room. The documents reviewed during the inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12Q - 2 samples) a. Inspection Scope The inspectors reviewed performance-based problems that involved structures, systems,

and components (SSCs) to assess the effectiveness of maintenance activities. When

applicable, the reviews focused on:

Proper Maintenance Rule scoping in accordance with

10 CFR 50.65; * Characterization of reliability issues; * Changing system and component unavailability; * 10

CFR 50.65(a)(1) and (a)(2) classifications; * Identifying and addressing common cause failures; * Trending of system flow and temperature values; * Appropriateness of performance criteria for SSCs classified (a)(2); and

8* Adequacy of goals and corrective actions for SSCs classified (a)(1).

The inspectors also reviewed system health reports, maintenance history, and

Maintenance Rule basis documents. The inspectors evaluated maintenance effectiveness

and monitoring activities to the requirements of 10 CFR 50.65. The documents reviewed

during this inspection are listed in the Attachment. The following Maintenance Rule

samples were reviewed:

"A" emergency diesel generator starting air motors; and * Reactor building closed cooling water system. b. Findings Introduction: The inspectors identified a non-cited violation (NCV) of very low safety significance (Green) of

10 CFR Part 50, Appendix B, Criterion

III, "Design Control," because Entergy personnel did not establish and maintain measures to monitor critical

design parameters to assure that equipment and processes essential to the safety-related

function of the emergency diesel generator (EDG) air start system were adequate.

Specifically, personnel did not establish sufficient measures to monitor critical design

parameters for the EDG air start system to ensure that an adequate quantity of air would

be available in the air receivers to perform a minimum of two cold engine starts without

recharging the air receivers. Description: On March 8, 2009, Pilgrim operators declared the "A" EDG inoperable because the starting air pressures for both air receiver tanks decreased below the

minimum required pressure of 225 pounds per square inch (psi). An operator identified the

two air receiver tanks at 200 psi while performing a training exercise in the EDG room.

The pressure in the tanks decreased because the control power fuse blew on the air

compressor. Normally, the air compressor operates automatically to maintain the pressure

in the air receiver tanks between 235 and 250 psi to ensure that an adequate supply of air

is available to perform a minimum of two cold engine starts without recharging the

receivers. The two cold engine starts without air recharging is the design function of the air

start system to maintain the starting capability of the EDG. Generally, operators perform a surveillance to monitor the air compressor and air receiver tanks' parameters on a weekly

basis.

During inspection follow-up, the inspectors reviewed operator logs, EDG surveillance procedures, alarm response procedures, condition reports, and the daily round entries.

The inspectors determined that personnel did not provide sufficient monitoring for the EDG

air start system's critical parameters to ensure that an adequate quantity of air is available

in the air receivers to perform a minimum of two cold engine starts without recharging the

receivers. The inspectors observed that there is not an alarm to alert operators of a low

pressure condition in the air receiver tanks. The inspectors determined that the low

pressure alarm located downstream of the air receiver tanks and after a pressure reducing

valve monitors the delivery pressure to the air start motors, but does not ensure that the air

receiver tanks remain above their minimum required pressure of 225 psi.

Additionally, the inspectors determined that the frequency of procedurally required operator

9checks and surveillances do not assure the critical parameters of the

EDG air start system remain in specification to assure operability. Specifically, the inspectors determined that without an air receiver tank low pressure alarm, the

EDG air start system leak rate

acceptance criteria described in plant procedures allows the air receivers to leak at a rate

that can render the EDG air start system inoperable for a period of time when considering

the frequency of operator monitoring. For example, with the specified air start system leak

rate acceptance criterion of 18.8 psi in four hours and an initial air receiver pressure of 250

psi, if operator rounds are not performed within eight hours and there is a malfunction of

the air compressor, the air receiver tanks would drop below the minimum required pressure

of 225 psi. The inspectors determined that performing operator checks once a week does

not ensure that the design function of the air start system is met because there is an

opportunity for the pressure in the tanks to decrease below their minimum required

pressure without operators' knowledge as evidenced in the case with the blown fuse.

Analysis: The inspectors identified a performance deficiency related to Entergy personnel not establishing and maintaining adequate measures to monitor critical design parameters

for the EDG air start system such that an adequate supply of air is available for a minimum

of two cold engine starts without recharging. This finding is more than minor because it is

associated with the design control attribute of the Mitigating Systems cornerstone and

affects the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the

absence of an air receiver tank low pressure alarm combined with frequency of operator

monitoring of the air start system's critical parameters affected the reliability of the "A" EDG

starting air system. The inspectors evaluated this finding using IMC 0609 Attachment 4,

"Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined

that the finding is of very low safety significance (Green) because it is not a design or

qualification deficiency, did not represent a loss of safety function, and did not screen as

potentially risk significant due to external events.

There is no cross-cutting aspect identified for this finding because the inspectors

determined that the performance deficiency is not reflective of current plant performance.

The monitoring frequencies of the EDG air start system critical parameters were

established for an extended period and prior to this problem there had not been recent

issues with monitoring EDG air start capability.

Enforcement:

10 CFR 50, Appendix B, Criterion

III, "Design Control," requires, in part, that measures shall be established for the selection and review for the suitability of application of materials, parts, equipment, and process that are essential to the safety-related

functions of the structures, systems and components. Contrary to the above, prior to

March 08, 2009, Entergy personnel did not adequately consider the suitability of alarms and processes that monitor critical parameters for the EDG air start system to ensure an

adequate supply of air is available for a minimum of two cold engine starts without

recharging the air receivers. Entergy took corrective action to increase the monitoring

frequency for the air start system critical parameters suitable to their alarm design.

Because this issue is of very low safety significance (Green) and was entered into

Entergy's

CAP as

CR -PNP-2009-00807, this violation is being treated as an

NCV consistent with Section

VI.A. 1 of the

NRC Enforcement Policy. (

NCV 05000293/2009002-01, Failure to Establish and Maintain Adequate Measures to Monitor Critical

10Parameters of the EDG Air Start System) 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 6 samples)

a. Inspection Scope The inspectors evaluated six on-line 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 risk assessment

tool, Equipment Out of Service (EOOS), and entry into appropriate risk categories. The

inspectors evaluated whether Entergy personnel 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 the inspection are listed

in the Attachment. The inspectors reviewed the adequacy of maintenance risk

assessments for the following maintenance and testing activities: * Emergent maintenance when the 120V

AC safety bus (Y2) was powered by the backup B-15 power supply with reactor core isolation cooling (

RCIC ) out of service; * Planned maintenance with

RC [[]]

IC out of service due to alternate shutdown panel testing; * Planned maintenance on the high pressure coolant injection system and the "A" turbine building closed cooling water heat exchanger; * Planned maintenance on the "B" residual heat removal system motor operated valves; * Planned maintenance on the electric fire pump and station blackout diesel; and * Planned maintenance when A6 electrical bus was inoperable due to load shed testing. b. Findings No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - 5 samples) a. Inspection Scope The inspectors reviewed five operability determinations associated with degraded or non-conforming conditions to determine if the operability determinations were justified and if the mitigating systems or those affecting barrier integrity 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 Entergy's performance for conformance

to applicable Technical Specifications (TS) and

UFS [[]]

AR requirements. The documents

reviewed during the inspection are listed in the Attachment. The inspectors reviewed the

following degraded or non-conforming conditions:

CR -

PNP-2009-00064, Scaffolding erected in "B" residual heat removal/torus room in

11violation of clearance requirements; *

CR -

PNP -2009-00097, Bolts on torus access hatch found not fully tight; *

CR -

PNP -2009-00360, "A"

EDG abnormal damper position issue; *

CR -PNP-2009-00560, High pressure coolant injection steam admission valve (MO-2301-3) failed to fully close on demand; and *

CR -

PNP-2009-00234, EDG day tank enclosures colder than expected.

b. Findings Introduction: The inspectors identified a non-cited violation of very low safety significance (Green) of Technical Specification 5.4.1 "Procedures," because Entergy personnel did not

implement procedure requirements in accordance with

EN -

MA-133, "Control of

Scaffolding." Specifically, personnel did not erect scaffolds in accordance with procedure

EN -

MA-133 and maintain minimum distance erection requirements from safety-related

equipment or alternatively perform engineering evaluations that conclude the equipment

will not be impacted by the scaffolds. Description: On January 7, 2009, during a walkdown of equipment in safety-related areas, the inspectors identified several instances where erected scaffolding did not comply with

the requirements of Entergy's scaffolding procedure

EN -

MA-133. Specifically, Entergy's

scaffolding procedure requires all seismic scaffolding erected in safety-related areas to

maintain at least a 2-inch clearance from safety-related equipment and a 3-inch clearance

from expanding system components. In the event that scaffolding cannot be erected in

accordance with the requirement stated above, an engineering evaluation is required.

Contrary to the procedure, the inspectors identified the following scaffolds within the

minimum allowed distance with no engineering evaluation:

Less than 1" clearance between the scaffold and the "B" core spray pump body; * Approximately 1/8" clearance between the scaffold and

RBCCW pipe; * Approximately 1/4" clearance between the scaffold and hand wheel of the

RHR "B" pump discharge valve; * Approximately 1/2" clearance between scaffold bracing and the RHR "D" pump motor lifting lug; and * A ladder and scaffold knuckle were in direct contact with the torus shell at one location, the scaffold support was less than 1/2" to the torus saddle at another location, and at

two more locations scaffolds were less than 1" away from the torus shell. The inspectors communicated this concern to the on-duty shift manager. Entergy

dispatched personnel to correct the scaffolding pole arrangement for the torus, requested

engineering evaluations to assess the affect of the scaffolds on the plant equipment, and

performed an extent of condition (EOC) walk down of other safety-related equipment

areas. However, during a subsequent walkdown on March 26, 2009, the inspectors

identified an additional scaffold not in accordance with Entergy's scaffold procedure. An

erected scaffold in preparation for the refueling outage had been tied off to the "B" core

spray safety-related pipe with no engineering evaluation performed. The inspectors

determined that Entergy's procedural expectations were not well defined as operations,

engineering, and supplemental workers were not fully familiar with the requirements of

EN -

MA-133. The inspectors concluded that the training and qualifications were inadequate in

2familiarizing personnel with plant guidelines as it relates to preventing impact damage during a seismic event to safety related equipment. Furthermore, Entergy supervisory

personnel did not follow-up with pre-job briefings to reinforce seismic expectations and

identify shortcomings in the training. This finding is related to a weakness in Entergy's scaffold control program. The inspectors

also identified that the procedure directs operations to review the potential effects of

scaffold activities including review and inspection of long-term scaffolds in all risk

significant areas. The torus shell scaffold had been erected since February 26, 2001.

However, no 50.59 evaluation was performed as required by

EN -

MA-133. Entergy

personnel entered these issues into their corrective action program for resolution, took

actions to correct the scaffolds, and performed engineering evaluations to assess the

affect of the scaffolds on the safety-related equipment. The evaluations determined that

the scaffolds did not adversely affect the plant equipment. Analysis. The inspectors identified a performance deficiency in that in some instances Entergy personnel did not implement station procedures when assembling scaffolding in

safety-related areas of the plant. The finding is more than minor because it is associated

with the external factors and equipment performance attributes of the Mitigating Systems

cornerstone and affects the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. The finding is also

similar to example 4.a in Appendix E of IMC 0612 in that Entergy personnel did not

routinely perform engineering evaluations for scaffolds constructed within the minimum

allowed distance of safety related equipment. The inspectors evaluated this finding using

IMC 0609 Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings."

The inspectors determined that the finding is of very low safety significance (Green)

because it is not a design or qualification deficiency, did not represent a loss of safety

function, and did not screen as potentially risk significant due to external events.

This finding has a cross-cutting aspect in the area of Human Performance because

Entergy supervisory and management personnel did not ensure oversight of work

activities, including contractors, such that nuclear safety is supported. Specifically, Entergy

personnel were not familiar with the requirements of

EN -

MA-133 due to Entergy's supervisory and management not effectively communicating and reinforcing expectations

related to erection of scaffolds (H.4.c of

IMC 0305). Enforcement. Technical Specification 5.4.1, "Procedures", requires, in part, 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 9 includes procedures for performing maintenance on safety-

related equipment. Contrary to the above, since January 7, 2009, there were multiple

examples where Entergy personnel and contractors did not implement procedure

EN -

MA-

133, "Control of Scaffolding," requirements in that all seismic scaffolding is required to

maintain at least a 2-inch clearance from safety related equipment or have an engineering

evaluation performed. Entergy's corrective actions included restoring identified scaffolds

into compliance with procedure

EN -

MA-133, performing engineering evaluations on all

scaffolds found to be within clearance requirements, re-inspecting all existing scaffolds,

and coaching operators to walk down existing scaffolds to identify any conditions adverse

13to quality. Because this finding is of very low significance and Entergy entered it into their corrective action program (CR-PNP-2009-00050,

CR -

PNP -2009-00051,

CR -

PNP-2009-

00064, and

CR -

PNP -2009-01086), this violation is being treated as an

NCV , consistent with Section

VI.A. 1 of the

NRC Enforcement Policy. (

NCV 05000293/2009002-02: Failure to Implement Scaffolding Procedure Requirements)

1R18 Plant Modifications (71111.18 - 1 sample) a. Inspection Scope The inspectors reviewed temporary modification engineering change (EC) 12705,

Reconfigure Alternate Power Feed Leads for

MO -1001-28A in

MCC Unit 52M-2031, to

determine whether the performance capability of the "A" residual heat removal Injection valve breaker had been degraded through the modification. The inspectors reviewed

electrical drawings, relevant condition reports, procedures, and the 10 CFR 50.59

screening to ensure the temporary modification did not adversely affect the breaker's

electrical capability to provide power to the motor operated valve. The inspectors reviewed the updated electrical drawings to determine whether they properly reflected the temporary

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

b. Findings No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19 - 7 samples)

a. Inspection Scope The inspectors reviewed seven samples of post maintenance tests (PMT) during this

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

adequately demonstrated the safety-related function of the equipment, 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. The documents reviewed during the inspection are listed in the

Attachment. The following maintenance activities and their post-maintenance tests were

evaluated:

Leak rate testing on the torus man way covers; * "A" residual heat removal injection throttle valve (MO-1001-28A) maintenance; * Replacement of the alternate shutdown panel reactor core isolation cooling flow controller; * Adjustment and lubrication of

EDG limit switches due to an abnormal damper position alarm; * Re-sleeve of the "A"

TBCCW heat exchanger * "B" residual heat removal motor operated valve maintenance; and * Reactor building closed cooling water seal replacement on the "C" pump.

14 b. Findings No findings of significance were identified.

1R22 Surveillance Testing (71111.22 - 7 samples)

a. Inspection Scope The inspectors reviewed seven 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 performance of surveillance activities to determine if the tests were performed in accordance with procedures. Additionally, the inspectors evaluated the

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

bases, and TS requirements. The inspectors also evaluated whether conditions adverse

to quality were entered into the corrective action program for resolution. The documents

reviewed during the inspection are listed in the Attachment. The following surveillance

tests were evaluated:

RCIC high water level turbine trip/auto-restart logic test; *

RCIC surveillance from alternate shutdown panel; *

RBCCW "C" in-service testing surveillance; * Reactor coolant system leakage detection surveillance; * "A"

EDG and associated emergency bus surveillance; * High pressure coolant injection simulated automatic actuation, flow rate and cold quick start test; and * "B" and "D" residual heat removal pump tests. b. Findings No findings of significance were identified. Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06 - 1 simulator training sample)

a. Inspection Scope The inspectors observed licensed operator requalification testing on January 12, 2009.

The inspectors evaluated the operating crew activities related to accurate and timely

classifications and notifications of emergency action level (EAL) declarations. Additionally,

the inspectors assessed the ability of training evaluators to adequately address operator performance deficiencies identified during the exercise. The documents reviewed during

the inspection are listed in the Attachment.

b. Findings

15 No findings of significance were identified.

4.

OTHER [[]]

ACTIVI TIES (OA)

4OA 1 Performance Indicator (

PI) Verification (71151)

Barrier Integrity Cornerstone (71151 - 1 sample) a. Inspection Scope 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, CRs, system health reports,

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

The following performance indicator was reviewed:

Reactor Coolant System Unidentified Leakage from the first quarter of 2008 through the fourth quarter of 2008.

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 As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"

and to identify repetitive equipment failures or specific human performance issues for

follow-up, the inspectors performed a daily screening of all items entered into Entergy's

corrective action program. The review was accomplished by accessing Entergy's

computerized database for condition reports, and attending condition report screening

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

.2 Annual Sample: Review of Security Department Procedure Implementation (1 sample)

a. Inspection Scope

16 The inspectors focused on Entergy's problem identification, evaluation, and resolution of a

potential adverse trend identified in security-related work practices and procedure compliance

in the area of human performance. On September 12, 2008, inspectors completed a security

baseline inspection at the

PNPS (

ADAMS Accession No. ML082940103. Three of the findings

identified during the inspection had a cross-cutting aspect in the area of human performance.

Entergy initiated condition reports (CR-PNP-2008-03584,

CR -

PNP -2008-03586, and

CR -

PNP-

2008-03587) to resolve the issues. Entergy promptly corrected or compensated for these

deficiencies, and before the inspectors left the site, Entergy complied with the applicable

physical protection and security requirements within the scope of the inspection. In addition,

Entergy initiated a condition report (CR-PNP-2008-03588) for the Security Department to

evaluate if a potential trend existed in human performance.

The inspectors reviewed Entergy's associated apparent cause evaluation, extent of condition

review, and proposed short-term and long-term corrective actions. The inspectors conducted

interviews with site personnel and reviewed site-specific procedures, memos, standing orders,

and shift turnover notes. In addition, the inspectors reviewed the

PN [[]]

PS security plan and

security post orders to ensure that applicable physical protection and security requirements

identified in these documents complied with regulatory requirements.

b. Findings and Observations No findings of significance were identified. Entergy used a "why staircase" methodology in the

apparent cause evaluation to determine if a trend or additional corrective actions were

needed. The apparent cause evaluation determined that the issues involved individual

accountability. The inspectors determined that Entergy performed an adequate review of the issues and implemented the appropriate corrective actions. The corrective actions were

aligned with the apparent cause evaluation and included a review of additional work

departments. The inspectors concluded that Entergy had taken appropriate action in

accordance with station procedures and the corrective action program. The inspectors also

determined that the apparent cause evaluation and subsequent corrective action follow-up

were appropriate. 4OA3 Event Follow-up (71153 - 2 samples)

.1 Operator Response to Unplanned Inoperability of the Torus

a. Inspection Scope On January 12, 2009, 2:01 p.m., operators declared the torus inoperable due to the

discovery of loose bolts on one of the two torus manway covers. Specifically, fourteen of

forty-four bolts were found to be "hand-tight", or less than the specified 45 foot-pounds of

torque required, on the east manway cover. After discovery of the degraded manway

cover, Entergy staff declared the torus inoperable and entered TS 3.7.A.2.a.3, "Primary

Containment Integrity - Blind Flanges and Manways," which requires the plant to be in cold

shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Entergy staff performed an extent of condition review

subsequent to the discovery which included verifying the other manway cover, the north

manway. Three of the forty-four bolts on the north manway cover were found to be less

17than the specified 45 foot-pounds of torque required. Entergy proceeded to torque each bolt on both local manway covers to the required 45 foot-pounds of torque, and then

conducted an individual leak rate test on both manways to determine the torus leakage.

Entergy determined there was no leakage and exited TS 3.7.A.2.a.3 at 10:57pm. In

addition, Entergy personnel conducted a past operability evaluation and determined that the torus would have met its design function with the as-found condition of "hand-tight"

bolts.

The inspectors reviewed the technical specifications, control room logs, risk profile, and

interviewed operations, engineering, and maintenance personnel. The inspectors

reviewed the basis for declaring the torus operable by reviewing the subsequent leak rate

testing performed after the bolts were tightened. The inspectors also reviewed Entergy's

past operability evaluation to determine whether the torus safety function was maintained considering the bolts in an as-found condition of "hand-tight." The documents reviewed

during the inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

.2 (Closed)

LER 05000293/2008-004-00, High Pressure Coolant Injection System (

HPCI) Inoperable Due to Undervoltage Relay Failure in Valve Power Supply Circuit (1 sample)

a. Inspection Scope On October 21, 2008, the control room received a motor control center (MCC) D9 trouble

alarm. Operators noted that the

HP [[]]

CI injection valve indicator light was extinguished.

After further investigation, operators discovered that the 125V DC valve control power

circuit for the normally closed

HP [[]]

CI injection valve was deenergized due to an

undervoltage relay failure in the 250V

DC power feed to the valve motor operator.

HPCI

was declared inoperable and Technical Specification (TS) 3.5.C was entered at 7:44pm.

The TS allowed outage time is 14 days provided that the reactor core isolation cooling

system and the low pressure injection system are both operable or be in cold shutdown

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Entergy personnel took corrective actions to replace the undervoltage

relay and

HP [[]]

CI was returned to service at 4:04am on October 22, 2008. Additional

corrective actions by Entergy included performing an undervoltage relay destructive failure

analysis and an engineering evaluation on installed DC power motor operated valve

undervoltage relays. Entergy's root cause and failure analysis identified that the relay was

the correct relay verified by the receipt inspection, the temperature was within its operating

parameters, and the relay did not display any unusual external indications. The relay was

not discolored and there were no maintenance activities in October that would have had a

direct impact on this failure. The analysis further stated the cause to be an isolated

premature component failure due to a manufacturing defect, specifically damage to a

single coil wire. This was identified in Entergy's corrective action program as

CR -

PNP-

2008-03338. This LER is closed.

b. Findings

18 No findings of significance were identified.

4OA5 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 8, 2009, the resident inspectors conducted an exit meeting and presented the

preliminary inspection results to Mr. Kevin Bronson, Site Vice President, and other

members of the Pilgrim staff. The inspectors confirmed that no proprietary information was

retained from this inspection period.

ATTACH [[]]

MENT [[:]]

SUPPLE [[]]

MENTAL [[]]

INFORM [[]]

ATION A-1

SUPPLE [[]]

MENTAL [[]]

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

B. Sullivan Director, Engineering D. Noyes Operations Manager

J. MacDonald Assistant Operations Manager

J. Lynch Licensing Manager

S. Wollman Engineering Supervisor

B. Chenard Shift Manager

LIST [[]]

OF [[]]

ITEMS [[]]

OPENED ,

CLOSED [[]]

AND [[]]

DISCUS [[]]

SED

Opened and Closed

05000293/2009002-01

NCV Failure to Establish and Maintain Adequate Design Measures to Monitor Critical Parameters of the

EDG Air Start

System (Section 1R12)05000293/2009002-02 NCV Failure to Implement Scaffolding Procedure Requirement (Section 1R15)

Closed

05000293/2008004-00

LER High Pressure Coolant Injection (

HPCI) Inoperable Due to Undervoltage Relay Failure in Valve Power Supply Circuit

(Section 4OA3.2)

A-2LIST

OF [[]]

DOCUME NTS

REVIEW [[]]

ED Section 1R01 Procedure 8.C.40, Revision 22, Seasonal Weather Surveillance Procedure 2.1.37, Revision 25, Coastal Storm Preparations and Actions

Section 1R04 Control Room Logs

Procedure 2.2.20, Revision 70, Core Spray

Procedure 2.2.32, Revision 79, Salt Service Water System

Pilgrim Training Manual, "Sea and Salt Service Water Systems"

PI&D M212 Sh. 1, Service Water System

Procedure 5.3.3, Revision 26, Loss of All Service Water

Procedure 5.3.26, Revision 24, RPV Injection During Emergencies

Procedure 3.M.1-15, Revision 43, Vibration Monitoring for Preventive Maintenance and Balancing

CR 2007-04783

CR 2008-02341

Procedure 8.5.5.6, Revision 26,

RC [[]]

IC Pump and Valve Operability from Alternate Shutdown Panel System Manual Drawings

Piping and Instrumentation Diagrams M245 & M246,

RC [[]]

IC System

Procedure 2.2.19, Revision 99, Residual Heat Removal

Drawing M241, Revision 07, Residual Heat Removal System

P& [[]]

ID [[]]

SDBD -10, Revision 2,

PNPS Design Basis Document for the Residual Heat Removal (RHR) System Procedure 2.2.8, Revision 94, Standby AC Power System (Diesel Generator)

Procedure 2.1.12.1, Revision 67, Emergency Diesel Generator Surveillance Drawing M219, Revision 22, Diesel Generator Air Start System

P& [[]]

ID Drawing M259, Revision 10, Diesel Generator Turbo Air Assist System

P& [[]]

ID [[]]

SDBD -61, Revision 1, Emergency Diesel Generator and Auxiliary Systems Section 1R05

UFSAR 10.8.4.2, Firewater Supply System

Procedure 2.4.54, Revision 22, Loss of All Fire Suppression Pumps or Loss of Redundancy in the Fire Water Supply System Procedure 8.B.14, Revision 41, Fire Protection Technical Requirements

Procedure 8.B.12, Revision 32, Fire Protection System Flow Tests

Exemption Request #8, No Intervening Combustibles Between Trains

Exemption Request #9, Fixed Suppression Exemption Where Alternate Shutdown Capability Exists Procedure 5.5.2, Revision 40, Special Fire Procedure

Drawing A-319, Reactor & Turbine Building Floor Plan 51'0" & 74'3" Fire Barrier System

Engineering Evaluation #24, Floor Barrier has Inoperable Dampers

Procedure 8.B.29, Revision 10, Inspection of Fire Barriers

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

Procedure 2.2.29, Revision 26, Smoke and Heat Detection Systems

A-389XM-1-ER-Q, Revision 7, Updated Fire Hazards Analysis

CR -

PNP-2009-00399

Procedure

EN -

DC-161, Revision 3, Control of Combustibles

Section 1R07

Procedure

3.M. 4-99, Revision 15,

TBCCW [[]]

HX Tube, Channel Cover, Channel Shell, and Partition Plate Repair Procedure 2.2.31, Revision 48,

TBCCW System

Tube sheet mapping M11-16-2, sheet 2

CR -

PNP -2009-00468

CR -

PNP-2009-00475

Section 1R11

LORT /

NRC Simulator Exam Scenario

SES -177, Loss of Transformer Cooling,

LOOP , Small

LO [[]]

CA and Loss of "B" Emergency Diesel Generator Section 1R12

Procedure

EN -

DC-203, Revision 1, Maintenance Rule Program

Procedure

EN -

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

Procedure

EN -

DC-205, Revision 1, Maintenance Rule Monitoring

Procedure

EN -

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

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

Procedure 2.1.12.1, Revision 67, Emergency Diesel Generator Surveillance Drawing M219, Revision 22, Diesel Generator Air Start System

P& [[]]

ID Drawing M259, Revision 10, Diesel Generator Turbo Air Assist System

P& [[]]

ID [[]]

SDBD -61, Revision 1, Emergency Diesel Generator and Auxiliary Systems Procedure 2.2.30, Revision 67, Reactor Building Closed Cooling Water (

RBCCW) System

Vendor Manual V-0309, Ingersol Rand Pumps

Maintenance Rule Basis Document for

RBC [[]]

CW System Health Report for

RBC [[]]

CW [[]]

PN [[]]

PS Maintenance Rule (a)(1) System Status Report

CR -

CR -

CR -

CR -

Procedure

EN -

LI-102, Revision 13, Corrective Action Process

Procedure

EN -

DC-203, Revision 1, Maintenance Rule Program

Section 1R13 Equipment Out Of Service (EOOS) Quantitative Risk Tool

20 VAC Y1 & Y2 Training Manual Drawings

Control Room Logs

CR -

PNP -2009-00015

CR -

PNP-2008-03792

A-4Procedure

8.C. 34, Revision 49, Operations Technical Specifications Requirements for Inoperable Systems/Components Procedure 8.5.5.6, Revision 26,

RCIC Pump and Valve Operability from Alternate Shutdown Panel Procedure 1.5.22, Revision 11, Risk Assessment Process

Procedure

EN -

DC -151, Revision 1, PSA Maintenance and Update

PNPS -

NE -07-00006, Revision 0, Pilgrim Probabilistic Safety Assessment (PSA) Rev2 Procedure

3.M. 3-47.2, Revision 18, "B" Train Functional Test of Individual Load Shed Components

NRC Reg. Guide 1.182, Assessing and Managing Risk before Maintenance Activities at Nuclear Power Plants Section 1R15

Procedure

EN -

MA -133, Revision 3, Control of Scaffolding

CR -

PNP-2009-00050

Pilgrim Station Long Term Scaffold Log

Control Room Logs

CR -

CR -

CR -

CR -

CR -

CR -

Procedure 1.5.15, Attachment 2, Revision 18, Scaffold Review and Approval Process

WO 0017859403, Torus Hatch X200B Inspection

WO 0017859401, Torus

NEI 94-01, Type B, Leak Rate Testing

MR 05109160, Remove and Install Torus Manways

PI&D [[]]

CIA-58-4, Suppression Chamber Penetration Details

PI&D M15, Reactor Building Basement El.-17"

Procedure

EN -

OP -104, Revision 3, Operability Determinations Section 1R18 Tagout Cover Sheet of MO-1001-28A

WO 51670713,

MO -1001-28A Breaker Testing

CR -

PNP-2009-00103

Procedure

8.Q. 3-3, Revision 54, 480V

AC Motor Control Center Testing and Maintenance

Electrical Drawing E8-31-4, Sheet 2, Revision E4, Wiring Diagram & Schematic Combination Full Voltage Reversing Starter

PI&D E5010, Revision E/2, Schematic Diagram Residual Heat Removal System Motor Operated Valves Electrical Drawing E8-19-9, Revision 32, Arrangement Diagram Motor Control Center B20

EC 0000012705, Reconfigure Alternate Power Feed Leads for

MO -1001-28A in

MCC Unit 52M-2031 Procedure

EN-DC-115, Revision 5, Engineering Change Development

A-5Section 1R19 WO 0017859403, Torus Hatch X200B Inspection

WO 0017859401, Torus Hatch X200A Inspection

CR -

PNP-2009-00097

NEI 94-01, Type B, Leak Rate Testing

MR 05109160, Remove and Install Torus Manways

PI&D C1A-58-4, Suppression Chamber Penetration Details

PI&D M15, Reactor Building Basement El.-17"

Tagout Cover Sheet of

MO -1001-28A

WO 51670713,

MO -1001-28A Breaker Testing

CR -

PNP-2009-00103

Procedure

8.Q. 3-3, Revision 54, 480V

AC Motor Control Center Testing and Maintenance

Electrical Drawing E8-31-4, Sheet 2, Revision E4, Wiring Diagram & Schematic Combination Full Voltage Reversing Starter PI&D E5010, Revision E/2, Schematic Diagram Residual Heat Removal System Motor Operated Valves Electrical Drawing E8-19-9, Revision 32, Arrangement Diagram Motor Control Center B20

Procedure 8.5.5.6, Revision 26,

RC [[]]

IC Pump and Valve Operability from Alternate Shutdown Panel Procedure 2.1.19, Revision 17, Suppression Chamber Temperatures

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

WO 00181333,

EDG 'A' Damper Abnormal Position Alarm (VD-206A)

Procedure

3.M. 4-99, Revision 15,

TBCCW [[]]

HX Tube, Channel Cover, Channel Shell, and Partition Plate Repair

CR -PNP-2009-00492

WO 51568423, Inspection and Tube and Plate Repair for the "A"

TBCCW

HX Procedure 8.5.2.3, Revision 47,

LPCI and Containment Cooling Motor-Operated Valves (

MOV s) Operability Test

WO 51694642, Lubrication and Maintenance on the

LPCI and Containment Cooling MOVs

CR -

PNP-2009-00705

Procedure 8.5.3.1, Revision 57, Reactor Building Closed Cooling Water System Quarterly and Biennial Comprehensive Operability Section 1R22 Procedure 8.M.2-2.10.11.1, Revision 15, Reactor Core Isolation Cooling High Water Level Turbine Trip/Auto-Restart Logic Test Procedure 2.1.19, Revision 17, Suppression Chamber Temperatures

Procedure 8.5.5.6, Revision 26,

RCIC Pump and Valve Operability from Alternate Shutdown Panel

CR-PNP-2009-00705

Daily Risk Notebooks

Procedure 8.5.3.1, Revision 57, Reactor Building Closed Cooling Water System Quarterly and Biennial Comprehensive Operability Procedure 2.5.2.71, Revision 31, Radwaste Collection System

Procedure 2.1.15, Revision 194, Daily Surveillance Log (Leak Rate Data Tables) Control Room Logs

A-6Procedure 1.3.34.7, Revision 18, Operations Performance Indicators - Data Sheets for

RCS Leakage Data Procedure 8.9.1, Revision 112, Emergency Diesel Generator and Associated Emergency Bus Surveillance Procedure 8.5.4.1-1, Revision 22,

HPCI Simulated Automatic Actuation, Flow Rate and Cold Quickstart Test Procedure 8.5.2.2.2, Revision 41,

LPCI System Loop B Operability - Pump Quarterly and Biennial (Comprehensive) Flow Rate Tests (

IST ) Section

1EP 6

LORT /NRC Simulator Exam Scenario,

SES -177, Revision 0, Loss of Transformer Cooling,

LOOP,

Small

LOCA and Loss of "B"