Text

IR 05000293-10-005, on 10/01/2010 - 12/31/2010, Pilgrim Nuclear Power Station, Maintenance Risk Assessments and Emergent Work Control, Identification and Resolution of Problems
	ML110390343
Person / Time
Site:	Pilgrim
Issue date:	02/08/2011
From:	Jackson D E; NRC/RGN-I/DRP/PB5
To:	Rich Smith; Entergy Nuclear Operations
References
	IR-10-005
	Download: ML110390343 (39)
	v • d • e

February 8, 2011

Mr. Robert SmithSite Vice PresidentEntergy Nuclear Operations, lnc.Pilgrim Nuclear Power Station600 Rocky Hill RoadPlymouth, MA 02360-5508

SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC INTEGRATED INSPECTIONREPORT 05000293/201 0005

Dear Mr. Smith:

On December 31 ,2010, the U.S. Nuclear Regulatory Commission (NRC) completed aninspection at your Pilgrim Nuclear Power Station (PNPS). The enclosed inspection reportdocuments the results, which were discussed on January 5,2011, with you and other membersof your staff.The inspection examined activities performed under your license as they relate to safety andcompliance with the Commission's rules and regulations, and with the conditions of yourlicense. The inspectors reviewed selected procedures and records, observed activities, andinterviewed personnel.This report documents three NRC-identified findings of very low safety significance (Green). Allof these findings were determined to be violations of NRC requirements. Additionally, alicensee-identified violation which was determined to be of very low safety significance is listedin this report. However, because of the very low safety significance and because they areentered into your corrective action program, the NRC is treating these findings as non-citedviolations (NCU consistent with Section 2.3.2.a of the NRC's Enforcement Policy. lf youcontest any NCV, you should provide a response within 30 days of the date of this inspectionreport, with the baiis for your denial, to the Nuclear Regulatory Commission,.ATTN.: DocumentControl Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region l;the Director, Office of Enforcement, United States Nuclear Regulatory Commission,Washington, DC 20555-0001; and the NRC Senior Resident lnspector at PNPS. ln addition, ifyou disigree with the cross-cutting aspect assigned to any finding in this report, you shouldprovide J response within 30 days of the date of this inspection report, with the basis for yourdisagreemeni, to the RegionalAdministrator, Region l, and the NRC Senior Resident lnspectorat ptrlpS. The information you provide will be considered in accordance with lnspection ManualChapter 0305. ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any)will be available electronically for public inspection in theNRC Public Doiument Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC Web site athttp://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).WrkDocket No.License No.

Enclosure:

cc: dencl:Projects Branch 5Division of Reactor Projects50-293DPR-35lnspection Report 05000293/201 0005d

Attachment:

Supplemental InformationDistribution via ListServ

SUMMARY OF FINDINGS

lR 05000293/2010005t 1010112010-1213112010; Pilgrim Nuclear Power Station; Maintenance RiskAssessments and Emergent Work Control; ldentification and Resolution of Problems.The report covered a three-month period of inspection by the resident and regional-basedinspectors. Three Green NR0-identified non-cited violations (NCV) and one licensee-identifiedviolation of very low safety significance (Green) were identified. The significance of most findingsis indicated by their color (Green, White, Yellow, Red) using lnspection Manual Chapter (lMC)0609, "Significance Determination Process." Cross-cutting aspects associated with findings aredetermined using IMC 0310, "Components Within the Cross-Cutting Areas." The NRC's programfor overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65paragraph (aX4) for Entergy's failure to correctly assess and manage a Yellow riskcondition for planned testing of the High Pressure Coolant Injection (HPCI) system fromthe Alternate Shutdown Panel (ASP). Specifically, Entergy considered HPCI available bycrediting multiple manual actions to restore the automatic function. However, theseactions were not "feW' or "simple" and would not have restored the HPCI automaticfunction in a timeframe consistent with guidance discussed in NUMARC 93-01, "lndustryGuideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Inaddition, HPCI's automatic function would not have been restored in a timeframeconsistent with Pilgrim's Updated Final Safety Analysis Report (UFSAR), Section 6.4.1,which specifies 90 seconds for HPCI to reach its required design flow rate. Correctiveactions included issuing a standing order to alert Operators of the specific requirements tomaintain a system "available" during maintenance and testing. Corrective actions plannedinclude revising Entergy's Risk Assessment Procedure to verify systems credited as"available" have clear and simple direction to restore automatic functional status duringmaintenance and testing.This finding was determined to be more than minor because Entergy's elevated plant riskwould put the plant into a higher risk category and require additional risk managementactions, namely protecting the Reactor Core lsolation Cooling system. In addition, thefinding affected the Human Performance attribute of the Mitigating System's cornerstoneobjective to ensure the availability of systems to respond to initiating events and preventundesirable consequences. The inspectors performed an evaluation in accordance withIMC 0609, "Significance Determination Process," Appendix K, "Maintenance RiskAssessment and Risk Management Significance Determination Process," because thefinding related to Entergy's assessment and management of risk. The finding wasdetermined to be of very low safety significance (Green) because the lncremental CoreDamage Probability Deficit for the unavailability of HPCI for the duration of the activity wasless than 1.0E-6 per year (approximately 2.6E-9 per year). The inspectors determined thatthis finding had a cross-cutting aspect in the Human Performance cross-cutting area, WorkEnclosure 4Control component, because Entergy did not correctly plan and coordinate work activitiesby incorporating appropriate risk insights H.3(a). (Section 1R13)Green. The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion X,"lnspection," for the failure to ensure that Quality Control verification inspections wereconsistently included and correctly specified in quality-affecting procedures and workinstructions for construction-like work activities as required by the Quality AssuranceProgram. Entergy initiated prompt fleet-wide corrective actions to ensure proper workorder evaluation and proper inclusion of Quality Control verification inspections. Thisissue was entered into the corrective action program as condition reports (CR) CR-HON2009-01 1 84 and CR-HQN-2010-001 3.The failure to ensure that adequate Quality Control verification inspections were includedin quality-affecting procedures and work instructions as required by the Quality AssuranceProgram was a performance deficiency. This issue was more than minor because, if leftuncorrected, it could lead to a more significant safety concern; in that, the failure to checkquality attributes could involve an actual impact to plant equipment. This issue affectedthe Design Control attribute of the Mitigating Systems cornerstone because missed orimproper quality control inspections during plant modifications could impact the availability,reliability, and capability of systems needed to respond to initiating events. Thisperformance deficiency was determined to be of very low safety significance (Green),since it was confirmed to involve a qualification deficiency that did not result in a loss ofoperability or functionality. The inspectors determined that this issue had a cross-cuttingaspect in the Human Performance cross-cutting area, Decision-Making component,because the licensee did not have an effective systematic process for obtaininginterdisciplinary reviews of proposed work instructions to determine whether QualityControl verification inspections were appropriate H.1(a). (Section 4OA2)Green. The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion ll, "QualityAssurance Program," for the failure to implement the experience and qualificationrequirements of the Quality Assurance Program. As a result, the licensee failed to ensurethat an individual assigned to the position of Quality Assurance Manager met thequalification and experience requirements of ANSI/ANS 3.1-1 978 as required by theQuality Assurance Program. Specifically, the individual assigned to be the responsibleperson for the licensee's overall implementation of the Quality Assurance Program did nothave at least one year of nuclear plant experience in the overall implementation of theQuality Assurance Program within the quality assurance organization prior to assumingthose responsibilities. This issue was entered into the corrective action program as CR-HQN-2010-00386.The failure to ensure that an individual assigned to the position of Quality AssuranceManager met the qualification and experience requirements of ANSI/ANS 3.1-1978 asrequired by the Quality Assurance Program was a performance deficiency. This issue wasmore than minor because, if left uncorrected, it could create a more significant safetyconcern. The failure to have a fully qualified individual providing overall oversight to theQuality Assurance Program had the potential to affect all cornerstones, but the inspectorsdetermined that this finding will be tracked under the Mitigating Systems cornerstone asthe area most likely to be impacted. The issue was not suitable for quantitativeEnclosure 5assessment using existing NRC Significance Determination Process (SDP) guidance, so itwas determined to be of very low safety significance (Green) using NRC InspectionManual Chapter (lMC) 0609, Appendix M, "Significance Determination Process UsingQualitative Criteria." The inspectors determined that there was no cross-cutting aspectassociated with this finding because this issue was not indicative of current performanceas it occurred more than three years ago. (Section 4OA2)Other FindinqsA violation of very low safety significance, which was identified by the licensee, has beenreviewed by the inspectors. Corrective actions taken or planned by the licensee havebeen entered into the licensee's corrective action program. The violation and correctiveaction tracking numbers are listed in Section 4OA7.Enclosure 6

REPORT DETAILS

Summarv of Plant StatusPilgrim Nuclear Power Station (PNPS) began the inspection period operating at 100 percentpower. On October 13,2010, operators reduced power to 50 percent to perform a thermalbackwash on the main condenser. Pilgrim returned to 100 percent power on October 14, 2010.On November 11 ,2010, operators reduced power to 45 percent for a backwash of the maincondenser. Pilgrim returned to 100 percent power later the same day. On November 30, 2010,operators reduced power to 70 percent to perform control rod blade'channel interference testingand returned to 100 percent power later the same day. On December 22,2010, operatorsreduced power to 50 percent to perform a condenser backwash and returned to 100 percentpower on December 23,2010. On December 27,2010, operators reduced power to 50 percent inresponse to high screen wash differential pressure due to a significant coastal storm. Pilgrimreturned to 100 percent power later the same day. Operators maintained the reactor at or near100 percent power for the remainder of the inspection period.1. REACTORSAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R04 Eouipment Aliqnment (711 11.04)Partial Svstem Walkdowns (7 1 1 11

.04 O)a. Inspection Scope (3 samples)The inspectors performed three partial system walkdowns during this inspection period.The inspectors performed a partial walkdown of each system to determine if the criticalportions of the selected systems were correctly aligned in accordance with procedures,and to identify any discrepancies that may have had an effect on operability. Thewalkdowns included selected control switch position verifications, valve position checks,and verification of electrical power to critical components. In addition, the inspectorsevaluated other elements, such as material condition, housekeeping, and componentlabeling. The documents reviewed are in the Attachment. The following systems werereviewed based on their risk significance for the given plant configuration:. 'B' Emergency Diesel Generator (EDG) with 'A' Residual Heat Removal out of service;. 'A' EDG with 'B' Core Spray and 345KV Line 342 out of service; ando 'B' Reactor Protection System Train while on backup power supply from B-10.b. FindinosNo findings were identified.Enclosure

71R05 Fire Protection (71 11 1.05)Fire Protection - Tours (71111.05O)a. lnspection Scope (5 samples)The inspectors performed walkdowns of five fire protection areas during the inspectionperiod. The inspectors reviewed Entergy's fire protection program to determine the fireprotection design features, fire area boundaries, and combustible loading requirements forthe selected areas. The inspectors walked down these areas to assess Entergy's controlof transient combustible material and ignition sources. ln addition, the inspectorsevaluated the material condition and operational status of fire detection and suppressioncapabilities and fire barriers. The inspectors then compared the existing condition of theareas to the fire protection program requirements to determine whether all programrequirements were met. The documents reviewed during this inspection are listed in theAttachment. The fire protection areas reviewed were:. Fire Area 1.10, Fire Zone 4.1,'B'Emergency Diesel Generator Room;o Fire Area 1.9, Fire Zone 1.9A, 'A' Residual Heat Removal Pipe Room;. Fire Area 1.9, Fire Zone 3.5, Vital Motor Generator Set Room;. Fire Area 1

===.10 , Fire Zone 2.1, 'B' Switchgear and Load Center Room; and. Fire Area 1.10, Fire Zone 2.11A, Turbine Deck-West End.b. FindinssNo findings were identified.

1R11 Licensed Operator Requalification Proqram (71 1 11

.1 1)Resident Insoector Quarterlv Review (71111.1 1Q)a. lnspection Scope (1 sample)The inspectors observed licensed operator performance during an annual licensedoperator requalification exam involving two evaluated scenarios on October 26,2010.fheinspectors observed crew response to a Station Blackout scenario complicated by a Lossof Coolant Accident. ln addition, the inspectors observed a fuel failure scenario with anunisolable leak from the Reactor Water Cleanup system. The inspectors assessed thelicensed operators' performance to determine if the training evaluators adequatelyaddressed observed deficiencies. The inspectors reviewed the applicable trainingobjectives from the scenarios to determine if they had been achieved. ln addition, theinspectors performed a simulator fidelity review to determine if the arrangement of thesimulator instrumentation, controls, and tagging closely paralleled that of the control room.The documents reviewed during this inspection are listed in the Attachment.Enclosure===

Ib. FindinosNo findings were identified.

1R12 Maintenance Effectiveness (71 1 1 1

.12 Q)Inspection Scope (2 samples)The inspectors reviewed the two samples listed below for items such as: (1) appropriatework practices; (2) identifying and addressing common cause failures; (3) scoping inaccordance with 10 CFR 50.65 paragraph (b) of the Maintenance Rule; (4) characterizingreliability issues for performance; (5) trending key parameters for condition monitoring; (6)charging unavailability for performance; (7) classification and reclassification inaccordance with 10 CFR 50.65 paragraph (aX1) or (aX2); and (8) appropriateness ofperformance criteria for structures, systems, and components (SSCs)/functions classifiedas paragraph (aX2) and/or appropriateness and adequacy of goals and corrective actionsfor SSCs/functions classified as paragraph (aX1). The documents reviewed during thisinspection are listed in the Attachment. ltems reviewed included the following:o Post Accident Sampling System Maintenance Rule (aX1) Action Plan; ando Condition Monitoring of Building and Structures.b. FindinosNo findings were identified.1 R13 Maintenance Risk Assessments and Emerqent Work Control (71 1 1 1 .13)a. Inspection Scope (3 samples)The inspectors evaluated three maintenance risk assessments for planned testing andmaintenance activities. The inspectors reviewed maintenance risk evaluations, workschedules, and control room logs to determine if concurrent maintenance or surveillanceactivities adversely affected the plant risk already incurred with out-of-service components.The inspectors evaluated whether Entergy took the necessary steps to control workactivities, minimized the probability of initiating events, and maintained the functionalcapability of mitigating systems. The inspectors assessed Entergy's risk managementactions during plant walkdowns. The documents reviewed during this inspection are listedin the Attachment. The inspectors reviewed the conduct and adequacy of maintenancerisk assessments for the following maintenance and testing activities:. Green Risk for Testing and Maintenance on the 'B' Core Spray System, Line 342, theDiesel Fire Pump, and the DieselAir Compressor;. Yellow Risk for'B' Residual Heat Removal Maintenance; and. Green Risk for High Pressure Coolant lnjection System Testing from the AlternateShutdown Panel.Enclosure

b.9Findinoslntroduction: The inspectors identified a Green NCV of 10 CFR 50.65 paragraph (a)( ) forEntergy's failure to correctly assess and manage a Yellow risk condition during testing ofthe HPCI system from the Alternate Shutdown Panel (ASP). Specifically, Entergyconsidered HPCI available by crediting multiple manual actions to restore the automaticfunction. However, these actions were not "few" or "simple" and would not have restoredthe HPCI automatic function in a timeframe consistent with guidance discussed inNUMARC 93-01, "lndustry Guideline for Monitoring the Effectiveness of Maintenance atNuclear Power Plants," nor with Pilgrim's UFSAR.Description: On November 15,2010, Entergy performed surveillance testing of HPCI fromthe ASP. During this test, operators place a control switch on the ASP from "remote" to"local" which removes the automatic function of HPCI to mitigate a Loss of CoolantAccident. Entergy's Equipment Out of Service (EOOS) risk assessment model calculatesthe risk with HPCI out of service to be "Yellow." However, Entergy credited a localoperator and manual actions to restore the HPCI automatic function during the test andthereby considered HPCI available and managed the plant risk as "Green."NUMARC 93-01, Section 11, Appendix B, Revision 2, dated 212212000, discusses manualrestoration actions to maintain a system available during the conduct of testing whichremoves the automatic function. NUMARC 93-01, discusses that, "Restoration actionsmust be contained in a written procedure, must be uncomplicated (a single action or a fewsimple actions), and must not require diagnosis or repair." ln order to restore HPCI,Operations briefed restoration steps in procedure 8.5.4.6, "HPCI Pump and ValveOperability from Alternate Shutdown Panel." The briefing sheet included, in part,"performing Section 8.2, starting at step-6, and then section 8.4for system restoration."Approximately 25 steps were required to be performed to restore HPCI's automaticfunction, Entergy did not recognize that the number of steps required to restore HPCI'sautomatic function would not meet a timeframe consistent with the guidelines in NUMARC93-01 to assure the automatic function was maintained. In addition, HPCI's automaticfunction would not have been restored in a timeframe consistent with Pilgrim's UFSARSection 6.4.1, which specifies a 90 second timeframe for HPCI to reach its required designflow rate. As a result, Entergy did not recognize that risk should have been Yellow andthat risk management actions, including protecting the Reactor Core lsolation CoolingSystem (RCIC) system, would be required.Analysis: The performance deficiency associated with this finding is that Entergyperformed an incorrect risk assessment for HPCI testing from the ASP and, as a result, didnot take all necessary risk management actions as specified by 10 CFR 50.65 paragraph(aX4). Traditional Enforcement did not apply as the issue did not have actual or potentialsafety consequence, had no willful aspects, nor did it impact the NRC's ability to performits regulatory function.A review of NRC Inspection Manual Chapter (lMC) 0612, Appendix E, "Minor Examples,"identified that Section 7, "Maintenance Rule," Example'e', reflected a similar more thanminor example. Specifically, this finding was determined to be more than minor becauseEntergy's elevated plant risk would put the plant into a higher risk category and requireEnclosure 10additional risk management actions, namely protecting the RCIC system. In addition, thefinding affected the Human Performance attribute of the Mitigating System's cornerstoneobjective to ensure the availability of systems to respond to initiating events and preventundesirable consequences. The inspectors performed an evaluation in accordance withIMC 0609, "Significance Determination Process," Appendix K, "Maintenance RiskAssessment and Risk Management Significance Determination Process," because thefinding related to Entergy's assessment and management of risk. The finding wasdetermined to be of very low safety significance (Green) because the Incremental CoreDamage Probability Deficit for the unavailability of HPCI for the duration of the activity wasless than 1.0 E-6 per year (approximately 2.6 E-9 per year).The inspectors determined that this finding had a cross-cutting aspect in the HumanPerformance cross-cutting area, Work Control component, because Entergy did not planand coordinate work activities by incorporating appropriate risk insights. H.3(a)]Enforcement: 10 CFR 50.65 paragraph (aX4), "Requirements for Monitoring theEffectiveness of Maintenance at Nuclear Power Plants," states, in part, "...the licenseeshall manage the increase in risk that may result from the proposed maintenanceactivities." Contrary to the above, on November 15, 2010, Energy incorrectly managed theincrease in risk from testing HPCI from the ASP. As a result, Entergy did not recognize aYellow risk condition and thus did not take all appropriate risk management actions.Corrective actions included issuing a standing order to alert Operators of the specificrequirements to maintain a system "available" during maintenance and testing. Correctiveactions planned include revising Entergy's Risk Assessment Procedure to verify systemscredited as "available" have clear and simple direction to restore automatic functionalstatus during maintenance and testing. Because of the very low safety significance andbecause it has been entered into the corrective action program (CR-PNP-2010-4267), theNRC is treating this as an NCV, consistent with Section 2.3.2 a of the NRC's EnforcementPolicy. (NCV 05000293/2010005-01, Failure to Manage a Yellow Risk ConditionDuring HPGlTesting from the Alternate Shutdown Panel.)1R15 Operabilitv Evaluations (71111.15)a. Inspection Scope (5 samples)The inspectors reviewed five operability determinations associated with degraded ornon-conforming conditions to determine if the operability determination was justified and ifthe mitigating systems or barriers remained available such that no unrecognized increasein risk had occurred. The inspectors also reviewed compensatory measures to determineif the compensatory measures were in place and were appropriately controlled. Theinspectors reviewed Entergy's performance against related Technical Specifications andUFSAR requirements. The documents reviewed during this inspection are listed in theAttachment. The inspectors reviewed the following degraded or non-conformingconditions;. Transfer Switch Y-10 acting sluggishly when transferring back to normal power supply;. 'A' Emergency Diesel Generator jacket water temperature switch found defective;o Degradation of Main Breakwater Structure;Enclosure 11. Residual Heat Removal/ Fuel Pool Cooling supports degraded; ando Drain Valve on the 'D' Moisture Separator Drain Tank not maintaining normal level.b. FindinqsNo findings were identified.1 R19 Post-Maintenance Testinq (71 1 1 1

===.19 )a. Inspection Scope (5 samples)The inspectors reviewed five samples of post-maintenance tests during this inspectionperiod. The inspectors reviewed these activities to determine whether the postmaintenance test adequately demonstrated that the safety-related function of theequipment was satisfied given the scope of the work performed, and that operability of thesystem was restored. In addition, the inspectors evaluated the applicable test acceptancecriteria to verify consistency with the associated design and licensing bases, as well asTechnical Specification requirements. The inspectors also evaluated whether conditionsadverse to quality were entered into the corrective action program for resolution. Thedocuments reviewed during this inspection are listed in the Attachment. The followingmaintenance activities and their post-maintenance tests were evaluated:. Reactor Core lsolation Cooling maintenance for valves MO-1301-26, MO-1301-22,and MO-1301-25;. Line 342 Maintenance;. Troubleshooting 'B' Reactor Protection System Spurious Half-Scrams;. 'A' Emergency Diesel Generator Start Push Button Replacement and OtherPreventative Maintenance; ando Replace Main Stack Dilution Fan'B'(VSF-2068).b. FindinosNo findings were identified.

1R22 Surveillance Testino (7 11 1 1.22)lnspection Scope (5 samples)The inspectors witnessed five surveillance activities andlor reviewed test data todetermine whether the testing adequately demonstrated equipment operational readinessand the ability to perform the intended safety-related functions. The inspectors reviewedselected prerequisites and precautions to determine if they were met, and if the tests wereperformed in accordance with the procedural steps. Additionatly, the inspectors evaluatedthe applicable test acceptance criteria for consistency with associated design bases,licensing bases, and Technical Specification requirements. The inspectors also evaluatedwhether conditions adverse to quality were entered into the corrective action program forEnclosure

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12resolution. The documents reviewed during this inspection are listed in the Attachment.The following surveillance tests were evaluated:. 'A' Emergency Diesel Generator Operability;. 'B'and 'D' Residual Heat Removal Pump Operability (lST);. High Pressure Coolant Injection (HPCI) Quarterly Operability Test (lST);o Control Blade Interference Testing; and. 'B' Core Spray Pump Operability and Flow Rate Test (lST).b. FindinqsNo findings were identified.2. RADTATTON SAFETY (RS)Cornerstone: Occupational/Public Radiation Safety2RS01 Radioloqical Hazard Assessment and Exposure Controls (71124.01)a. Inspection Scope (1 Sample)During the period October 18 through October 21, 2010, the inspectors conducted thefollowing activities to verify that Pilgrim properly assessed the radiological hazards in theworkplace and implemented appropriate radiation monitoring and exposure controls duringroutine operations. lmplementation of these controls was reviewed against the criteriacontained in 10 CFR 20, "Standards for Protection Against Radiation," relevant TechnicalSpecifications, and the licensee's procedures. This inspection activity represents thecompletion of one sample relative to this inspection area; completing the annual inspectionrequirement.Radiolooical Hazard Assessment. The inspectors verified air samples were collected and analyzed in accordance withPilgrim procedures.Instructions to Workers. The inspectors ver:ified that workers would be informed of changing conditions by theradiological controls technician providing continuous job coverage.Contamination and Radioactive Material Control. The inspectors observed the Radiological Control Area exit at the "green line" to verifythe surveying and release of material was in accordance with plant procedures. Theinspectors verified the procedures are sufficient to control the spread of contaminationand prevent unintended release of licensed materialfrom the site.Enclosure 13. The inspectors verified that Pilgrim has not established a de facto "release limit" byaltering the instrument's typical sensitivity through altering energy discrimination orplacing instruments in high background radiation areas.Radioloqical Hazards Control and Work Coveraqeo There were no opportunities to observe work in areas with significant dose gradientsduring this inspection period.o Pilgrim has no posted airborne radiation areas. Therefore, the inspectors had noopportunities to observe work in such areas and could not evaluate controls for thoseareas.. The inspectors verified the physical and programmatic controls for highly activatedmaterials stored in the spent fuel pool to ensure that appropriate controls are in placeto preclude the inadvertent removal of these materials from the pool.. The inspectors verified the posting and physical controls for the Traversing In-CoreProbe (TlP) room were appropriate when TIP movement was in progress. This areawas a very high radiation area (VHRA) at the time of the observation.Risk-Siqnificant Hiqh Radiation Area and Verv Hioh Radiation Area Controlso The inspectors discussed the VHRA controls and procedures with the RadiationProtection Manager (RPM).. The inspectors discussed the controls in place for entry into the TIP room with aRadiation Protection (RP) supervisor. The inspector verified that communication withthe RP group is required prior to moving probes. The RP supervisor is on a tag outthat must be cleared prior to probe movement.. The inspectors verified that an individual is not able to gain unauthorized access to theTIP room during probe movement.b. FindinosNo findings were identified.2RS02 Occupational ALARA Planninq and Controls (71124.02)a. lnspection Scope (4 samples)During the period October 18 through October 21, 2010, the inspectors performed thefollowing activities to verify that the licensee was properly implementing operational,engineering, and administrative controls to maintain personnel exposure As Low AsReasonably Achievable (ALARA) for activities performed during routine operations.lmplementation of these controls was reviewed against the criteria contained in10 CFR 20, applicable industry standards, and the licensee's procedure.Enclosure b.4.14Inspection Plannino. The inspectors reviewed pertinent information regarding cumulative exposure history,current exposure trends, and ongoing activities. The inspectors reviewed the site's 3-year rolling average dose and compared the site's average with the industry's average.. The inspectors reviewed Pilgrim's trend in collective exposure and the site's sourceterm measurements.Verification of Dose Estimates and Exposure Trackino Svstemsr The inspectors verified that Pilgrim has established measures to track, trend, and settrigger points to prompt additionalALARA planning and controls.. The inspectors performed an evaluation of Pilgrim's method of adjusting exposureestimates when unexpected changes occur.FindinosNo findings were identified.orHER ACTTVTTTES [OA]4OA1 Performance lndicator Verification (71 151).1 Cornerstone: Mitigating Systemsa. Inspection Scope (2 samples)The inspectors reviewed Performance lndicator (Pl) data to determine the accuracy andcompleteness of the reported data. The review was accomplished by comparing reportedPl data to confirmatory plant records and data available in plant logs, Condition Reports(CRs), Licensee Event Reports (LERs), and NRC inspection reports. The acceptancecriteria used for the review was Nuclear Energy lnstitute (NEl) 99-02, Revision 6,"Regulatory Assessment Performance Indicator Guidelines." The documents reviewedduring the inspection are listed in the Attachment. The following performance indicatorswere reviewed:o Emergency AC Power System from the fourth quarter 2009, through the third quarterof 2010 [MS06]; and. Cooling Water (Salt Service Water/Reactor Building Closed Cooling Water) from thefourth quarter 2009 through the third quarter of 2010 [MS10].b. FindinqsNo findings were identified.Enclosure

.215 Cornerstone: Occupational/Public Radiation SafetyOccupational Exposure Control EffectivenessInspection Scope (1 sample)The inspectors reviewed implementation of the licensee's Occupational Exposure ControlEffectiveness Performance Indicator (Pl) Program. Specifically, the inspector reviewedrecent condition reports and associated documents for occurrences involving locked highradiation areas, very high radiation areas, and unplanned exposures against the criteriaspecified in Nuclear Energy Institute (NEl) 99-02, "Regulatory Assessment Performancelndicator Guideline," to verify that all occurrences that met the NEI criteria were identifiedand reported as performance indicators. This inspection activity represents the completionof one sample relative to this inspection area; completing the annual inspectionrequirement.FindinqsNo findings were identified.ldentification and Resolution of Problems (71 '152)Review of ltems Entered into the Corrective Action Prooram (CAP)Inspection ScopeThe inspectors performed a screening of each item entered into Entergy's correctiveaction program. This review was accomplished by reviewing printouts of each CR,attending daily screening meetings and/or accessing Entergy's database. The purpose ofthis review was to identify conditions such as repetitive equipment failures or humanperformance issues that might warrant additional follow-up.FindinqsNo findings were identified.Semi-Annual Review to ldentifv TrendsInsoection Scope (1 sample)The inspectors performed a review of Entergy's CAP and associated documents to identifytrends that could indicate the existence of a more significant safety issue. The review wasfocused on repetitive equipment and corrective maintenance issues, but also consideredthe results of daily inspector CAP item screening. The review included issuesdocumented in CAP trend reports and the site CAP performance indicator data. Thereview focused on the six month period of July 2010, through December 2010, althoughthe inspectors also evaluated previous trend results for CRs and observations fromselected inspection samples from January 2010 through June 2010 which have beenEnclosureb.4c.42,1a.b..2a.

b.16discussed previously in Pilgrim lntegrated Inspection Report 2010003 (M1102100150).The documents reviewed during the inspection are listed in the Attachment.Findinqs and ObservationsNo findings were identified. One low level trend discussed in PilgrimIntegrated Inspection Report 2010003 was reviewed and is discussed below.Maintenance Rule ProoramThe inspectors reviewed CR-PNP-2009-4197 and CR-PNP-2010-2211, which were writtento perform assessments of the Maintenance Rule Program (MRP) and the MaintenanceRule Functional Failure evaluation process. The inspectors performed additionalMaintenance Rule inspection samples during the 3'd and 4th quarters of 2010, andidentified fewer deficiencies in the MRP, the scoping of systems into the MRP, and infunctionalfailure evaluation quality. In addition, the inspectors noted improvedMaintenance Rule Committee oversight and discipline and ownership by engineers fortheir MRP products. Due to the identification of fewer deficiencies and because correctiveactions to improve the MRP and Maintenance Rule Functional Failure evaluation quality atPilgrim appear to have been effective, the inspectors consider this low level trend closed.Selected lssue Follow-up InspectionInspection ScopeAn inspection was performed at the Entergy corporate office in Jackson, Mississippi onJune 14 through 17 , 2010, to review the circumstances surrounding missed quality control(QC) verification inspections documented in CR-HQN-2009-01184 and CR HQN 201000013. The issue involved QC verification inspections performed during construction-related activities which were required as part of the Entergy quality oversight andverification programs. The inspection was performed to determine if the licensee hadtaken corrective actions commensurate with the significance of the identified issues, andto assess the impact, if any, on the operability of plant equipment caused by the missedinspections. This inspection was conducted by inspectors from Regions l, ll, and lV, aswell as a Senior Program Engineer from the Quality and Vendor Branch of the Office ofNuclear Reactor Regulation (NRR). The inspection covered all NRO-licensed sites ownedby Entergy Operations, lnc., including Arkansas Nuclear One, James A. Fitzpatrick, GrandGulf Nuclear Station, lndian Point Units 2 and 3, Palisades Plant, Pilgrim Nuclear PowerStation, River Bend Station, Vermont Yankee, and Waterford 3.The inspectors reviewed root cause analyses documented in CR-HQN-2009-01184 andCR-HQN-2010-00013, and the results of the licensee's extent of condition reviews andplant impact assessments. The inspectors also independently assessed the potentialimpacts of the missed inspections on the operability of plant equipment by reviewing all ofthe examples identified by the licensee, and by independently reviewing completedmodifications and work orders to identify additional examples. The inspectors alsoreviewed the corrective action database to assess reported equipment failures in order toassess whether the failure might have involved missed QC verification inspections.Enclosure.3a.

I17The inspectors assessed causal factors that may have contributed to missing QCverification inspections. This assessment included reviewing the Entergy QualityAssurance Program Manual (OAPM) requirements, changes made to the QAPM, and thelevel of agreement between the QAPM and its implementing procedures. Documentsreviewed are listed in the attachment.b. FindinqsBackqround: The inspectors identified problems with the implementation of elements ofthe Quality Assurance (QA) Program that affected the fleet of Entergy Operations Inc.,(hereafter referred to as "Entergy") nuclear power plants that are licensed by the NRC.While the plant organizations are NRC licensees, Entergy also has corporate groupswhich are not NRC licensees that are actively involved in some activities affecting sites,including program and procedure changes. Entergy adopted a business strategy ofadopting standard programs and procedures at all fleet plants.On October 30, 2009, the NRC discussed with Entergy the initial concerns about whetherQC verification inspections were being performed consistently for the types of work thatrequire that level of inspection. Both the non-licensed and licensed Entergy organizationsresponded with an appropriate review of the issues. Entergy's review of work documentsthat were potentially affected was extensive at each site. Entergy's total review examinedover 320 Engineering Change documents and 2676 Work Orders. Of the 30 Work Ordersidentified to have QC verification inspection deficiencies affecting eight safety-relateddesign changes, all 30 were determined by Entergy to have sufficient documentation toprovide confidence that the equipment was installed correctly. Specific corrective actionswere identified and implemented to ensure that QC verification inspections would beincluded in current and future work documents, including procedure enhancements.The information provided to the NRC was used to perform a focused inspection in order toassess the impact of the missed verification inspections at each of the NRC-licensedfacilities. The inspection documented below independently assessed the potential impactof missed QC verification inspections on the operability of plant equipment, as well asassessing details of QA Program for the Entergy fleet.Two findings were identified during this inspection. These findings involved missed QCverification inspections at seven Entergy sites, and the assignment of individuals to the QAManager position that did not meet the experience and qualification requirements at eightsites. Only the findings impacting Pilgrim are described below.The inspectors concluded that the Entergy fleet organizational structure and Entergystrategy of adopting standardized procedures across the fleet were contributing factors tothefindings. Specifically:o Changes to adopt the standard fleet QA program created a partial conflict with existingrequirements for worker qualifications at some sites. The process for creating andrevising standardized fleet procedures and programs used to meet NRC requirementsEnclosure b.118must ensure that site-specific regulatory requirements and commitments are properlyaddressed for all sites.. Changes that removed details from existing site-specific QA and QC programimplementing procedures while shifting to standardized fleet procedures contributed tothe finding involving missed QC verification inspections. CRs at individual sitesregarding problems related to this issue were not recognized collectively as symptomsof a problem with these procedures because they were addressed at the site level.Failure to Perform Required Qualitv Control InspectionsIntroduction: The inspectors identified a Green, NCV of 10 CFR 50, Appendix B, CriterionX, "lnspection," for the failure to ensure that Quality Control verification inspections wereincluded in quality-affecting procedures and work instructions for construction-like workactivities as required by the Quality Assurance Program.Description: ln response to the inspectors' request for information concerningimplementation of the quality oversight and verification programs, the licensee performeda review of a representative sample of engineering changes and work order tasks issuedbetween 2006 and 2009. The licensee's review included performing equipmentwalkdowns, evaluating rework rates and human error rates, and causes for failures ofsignificant components. Based on the results of these reviews, Entergy initiated CRs atthe various sites to document problems with Quality Control (QC) verification activities andfailures to perform required QC reviews of safety-related engineering changes andconstruction related work activities. Entergy's investigation concluded that procedurescontained inadequate guidance, which resulted in inconsistent implementation of the QCProgram. Specifically, some safety-related design change work orders were not reviewedto determine whether QC verification inspections were required, and some safety-relateddesign change work orders did not include all required QC verification inspections. Theseexamples were documented in CR-HQN-2009-01083, -01084, -01085, -01093, -01096, -01 140, -01 169, -01170, -01184, and -01 188.Additional findings identified by Entergy's review included:o Managers in maintenance organizations did not have a detailed understanding of QCresponsibilities, required inspections, or what documents required review (CR HQN-2009-01 150).. A weakness was identified in the process for ensuring proper approval of contract QCinspection personnel at all Entergy sites. Procedure EN-QV-1 11, "Training andCertification of Inspection/verification and examination Personnel," Section 4.0 [1],required that the Manager responsible for Quality Assurance or designee at eachlocation is responsible for approving ANSI N45.2.6 certification of QC inspectionpersonnel. In practice, contract QC inspectors'qualifications were not approved by theQA Manager prior to November of 2009. This was determined to be a minor violationbecause the ANSI Level lll inspector at each site was documenting that the contractQC personnel had the necessary qualifications to perform the inspections for whichEnclosure 19they were contracted. This issue was entered into the licensee's corrective actionprogram as CR-HQN-2009-1 091 .o At individual Entergy plants, 27 condition reports were written in 2008 and 2009 todocument potentially missed QC verification inspections or missed reviews to considerQC verification inspections prior to the NRC engaging Entergy on this issue. Of those,seven were actual missed inspections (CR-RBS-2009-05041, CR-JAF-2008-03648,and CR-PNP-2008-0091 6 and CR-PNP-2008-03922, CR-PNP-2009-01 798, CR-PNP-2009-02059, and CR-PNP-2009-02255). Multiple condition reports documented workpackage quality issues that impacted the ability to identify appropriate QC verificationinspection req uirements.o Two examples of QC programmatic issues were identified, assigned by Entergyheadquarters, and not properly addressed (CR-ANO-C-2009-01884, andCR-HQN-2009-00178). These were considered examples of the violation discussedbelow.o River Bend Station was using notification points instead of designating specific QChold points (CR-RBS-2008-04685).o Insufficient resources were assigned or qualified to perform the required tasks atGrand Gulf Nuclear Station and River Bend Station. River Bend Station operated witha single QC Level ll inspector for more than 3 years, and Grand Gulf Nuclear Station'stwo QC inspectors did not have all of the discipline certifications for which they wereconducting inspections (CR-HON-2009-01 140 and CR GGN-2009-06575). Whilethese conditions were inappropriate, the inspectors did not identify a separate violationassociated with these issues. To the extent that the individuals at River Bend Stationwere evaluating work documents for QC verification inspections and not correctlyidentifying those verifications, those examples are part of the violation discussedbelow.e Although equipment-related QC condition reports were addressed appropriately, QCprogrammatic issues were not always effectively addressed.. QA audits and oversight activities for the QC Program missed opportunities to identifythe findings of their investigation (CR-HQN-2009-01169, CR-HQN-2009-0153, andCR-HQN-2O10-00013). In particular, the Entergy corporate ANSI Level lll inspectorwas required to perform periodic surveillances of QC inspection activities to ensure theprogram is being adequately implemented and maintained, but these requiredsurveillances were not performed in 2008 (CR-HQN-2009-001 11). This is furtherdiscussed in Section 4OA7.Subsequent to the identification of these deficiencies, Entergy initiated prompt correctiveactions to ensure that appropriate safety-related, engineering changes and non-routinemaintenance work orders were identified and routed to the Maintenance lnspectionCoordinator for evaluation and inclusion of QC verification inspections in accordance withthe revised requirements of procedure EN-WM-105, "Planning." These corrective actionsEnclosure 2Aand actions to preclude recurrence were collectively documented in the following Level Acondition reports: CR-HQN 2009-01 184, dated December 21, 2009, and CR-HQN-2010-0013, dated January 6, 2010.In-office NRC reviews identified the need to conduct further inspection activities. On June14 through 17,2010, the inspectors conducted a focused review of work performed ateach NRC-licensed Entergy site to assess whether examples of missed QC verificationinspections identified by Entergy during their review had the potential to have impacted theoperability of important plant equipment. The inspectors also reviewed the correctiveaction database and maintenance records to independently assess the rigor of the Entergyreview and to identify additional examples of missed QC verification inspections. Theinspectors identified no additional examples, and concluded that the Entergy reviews weresufficient to identify the scope of the problems and develop actions to address the causes.The inspectors reviewed specific work items whose scope met QAPM requirements tohave had QC verification inspections but did not have the appropriate inspections. Basedin part on interviews with Entergy personnel, the inspectors determined that proceduralguidance for work planning was not sufficiently detailed or clear to ensure that workpackages with construction-like activities would be reviewed by the specified QCpersonnel. These individuals were responsible for designating the QC inspections thatwere required by the QAPM.The inspectors also identified. numerous CRs written at Entergy sites that documentedimproper implementation of QC verification inspections. Specific CRs are listed in theattachment.Analvsis: The failure to ensure that adequate Quality Control verification inspections wereincluded in quality-affecting procedures and work instructions as required by the QualityAssurance Program was a performance deficiency. This programmatic deficiency, if leftuncorrected, could lead to a more significant safety concern; in that, the failure to checkquality attributes could involve an actual impact to plant equipment. This issue affectedthe Design Control attribute of the Mitigating Systems cornerstone because missed qualitycontrol inspections during plant modifications could impact the availability, reliability, andcapability of systems needed to respond to initiating events. This performance deficiencywas determined to have very low safety significance since it was confirmed to involve aqualification deficiency that did not result in a loss of operability or functionality.Specifically, inspectors verified by sampling that work documents provided objectivequality evidence that work activities that had missed quality control verifications wereproperly performed.The inspectors determined that this issue had a cross-cutting aspect in the HumanPerformance cross-cutting area, Decision-Making component, because the licensee didnot have an effective systematic process for obtaining interdisciplinary reviews ofproposed work instructions to determine whether Quality Control verification inspectionswere appropriate [H. 1 (a)].Enforcement: 10 CFR Part 50, Appendix B, Criterion X, "lnspection," requires, in part,that, "Examinations, measurements, or tests of material... shall be performed for eachEnclosure 21work operation where necessary to assure quality . lf mandatory inspection hold points,which require witnessing or inspecting by the licensee's designated representative andbeyond which work shall not proceed without the consent of the designated representativeare required, the specific hold points shall be indicated in appropriate documents."Entergy's QAPM, Revision 20, Section B.12, "lnspection," requires, in part, that,"Provisions to ensure inspection planning is properly accomplished are to be established.Planning activities are to identify the characteristics and activities to be inspected, theinspection techniques, the acceptance criteria, and the organization responsible forperforming the inspection. Provisions to identify inspection hold points, beyond whichwork is not to proceed without consent of the inspection organizatior; ?f* to be defined."Contrary to the above, from February 2006, to December 2009, the licensee failed toensure that examinations, measurements, or tests of material were performed for eachwork operation where necessary to assure quality, and failed to include mandatoryinspection hold points in appropriate documents. Specifically, multiple examples ofMaintenance Work Orders and Engineering Change documents for construction-relatedactivities involving safety-related systems structures and components were identifiedwhere witnessing or inspections were required to be performed to ensure quality, butthese steps were not identified, included in the work documents, or performed as requiredQC hold points in the work instructions. Condition reports documenting the specificproblems and examples of the violation included:cR-PNP-2009-05359;cR-HQN-2009-01083;cR-HQN-2009-01084;cR-HQN-2009-01085;cR-HQN-2009-01093;cR-HQN-2009-01096;CR-HQN-2009-01 140;cR-HQN-2009-01169;OR-HQN-2009-01170;CR-HQN-2009-01 1 84; andcR-HQN-2009-01 188.Because this issue was of very low safety significance and was entered into the CAP asCR-HQN 2009-01184 and CR-HQN-2010-0013, this violation is being treated as an NCV,consistent with Section 2.3.2.a of the NRC's Enforcement Policy (NCV05000293/2010005-02, Failure to Perform Required Quality Gontrol Inspections).b.2. Failure to lmplement the Experience and Qualification Reouirements Associated With theQualitv Assurance Prooramlntroduction: The inspectors identified a Green NCV violation of 10 CFR 50, Appendix B,Criterion ll, "Quality Assurance Program," for the failure to implement the experience andqualification requirements of the Quality Assurance Program. As a result, the licenseefailed to ensure that an individual assigned to the position of Quality Assurance ManagerEnclosure 22met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required bythe Quality Assurance Program.Description: During their review of the issues surrounding the improper implementation ofquality control (QC) verifications discussed above, the inspectors noted that the root causeanalysis documented in CR-HQN-2O10-0013 identified that lack of experience of theQuality Assurance (QA) Manager contributed to the failure to identify the trend in missedQC verification inspections. The inspectors reviewed the relevant experience andqualifications of the QA Manager at each Entergy site. The inspectors also reviewed theNRC's safety evaluation report that approved Entergy's original corporate QualityAssurance Program Manual (QAPM), which is the document that contains the QAProgram. Additionally, the inspectors reviewed the administrative section of the TechnicalSpecifications for all the Entergy sites and a sample of evaluations, performed inaccordance with 10 CFR 50.54(a), that supported Entergy QAPM changes and alignmentof plants that were subsequently purchased by Entergy.The Entergy corporate QAPM required each site to meet the experience and qualificationstandards in ANSI/ANS 3.1-1978, "American National Standard for Selection and Trainingof Nuclear Power Plant Personnel." Section 4.4 included qualification and experiencerequirements for the personnel described as "group leaders" of five professionaltechnicalgroups, including Quality Assurance. Section 4.4.5, "Quality Assurance," required that"...the responsible person shall have six years experience in the field of quality assurance,preferably at an operating nuclear plant, or operations supervisory experience. At leastone year of this six years experience shall be nuclear power plant experience in the overallimplementation of the quality assurance program. (This experience shall be obtainedwithin the quality assurance organization)."On December 15, 2008, procedure EN-QV-117, "Oversight Training Program," the Entergyprocedure used by all Entergy sites to implement the requirements of ANSI/ANS 3.1-1978,was revised by the Entergy corporate QA group. Section 5.7, "Manager/QA Senior AuditorTraining," was changed to state:Either the QA Manager or the Senior QA Auditor will meet the requirements of ANS3.1-1978 paragraph 4.4.5 for operating plants and it applicable ANS 3.1-1993paragraph 4.3.7 for new plants.The inspectors reviewed completed Personnel Change Planning ChecklisUForms for QAManagers at each site. Entergy used this form to evaluate QA Manager candidates priorto the implementation of an Entergy fleet-wide restructuring in July 2007. Attachment 8,"Change Management Guidelines for Alignment lmplementation," included the followingconclusion for the individual that subsequently was assigned to be the QA Manager:flndividual's name redactedl meets the minimum requirements for QA Managerwith the exception of at least one year of this six years experience shall be nuclearpower plant experience in the overall implementation of the quality assuranceprogram. This requirement must be met by the QA Senior Auditor.Enclosure 23Based on discussions with Entergy corporate QA personnel, the inspectors determinedthat Entergy personnel had interpreted ANSI/ANS 3.1-1978, Sections 4.4 and 4.4.5 toallow the Senior Auditor to be considered the QA group leader described in the standardfor purposes of meeting the experience requirements of Section 4.4.5 in cases where acandidate for the position of QA Manager did not satisfy the experience requirements.In reviewing this issue, the NRC staff has determined that the group leader in this case isthe individual filling the position assigned responsibility for overall implementation of theQA Program (Entergy used the title "QA Manage/'for this position). The individualmeeting the experience and qualification requirements must be the individual assigned theresponsibilities for overall implementation of the QA Program assigned within the QAProgram.The inspectors determined that this change to procedure EN-QV-117 did not ensure thatthe qualifications for the QA Manager would meet the requirements of standard. Theinspectors identified an example where the Senior Auditor was credited as being the groupleader for purposes of meeting ANSI/ANS 3.1-1978, and the individual who was assignedas the QA Manager did not meet the ANSI/ANS 3.1-1978 experience requirements. Theteam also determined that the responsibilities assigned to the QA Manager under theQAPM were not reassigned to the Senior Auditor, and the Senior Auditor did not reportdirectly to the designated senior executive. The Senior Auditor continued to report to theQA Manager, so the person with the greater experience did not have the positionalauthority to decide issues.Analvsis: The failure to ensure that an individual assigned to the position of QualityAssurance Manager met the qualification and experience requirements ofANSI/ANS 3.1-1978 as required by the Quality Assurance Program was a performancedeficiency. This performance deficiency was determined to be more than minor because,if left uncorrected, it could create a more significant safety concern. Failure to have a fullyqualified individual providing overall oversight to the QA Program had the potential toaffect all cornerstones, but this finding will be tracked under the Mitigating Systemscornerstone as the area most likely to be impacted. The issue was not suitable forquantitative significance determination, so it was assessed using IMC 0609, Appendix M,and was evaluated using the qualitative criteria listed in Table 4.1. This finding wasdetermined to be of very low safety significance because other quality assurance programfunctions remained unaffected by this performance deficiency, so defense-in-depthcontinued to exist. The inspectors determined that there was no cross-cutting aspectassociated with this finding because this issue was not indicative of current performanceas it occurred more than three years ago.Enforcement: Appendix B to 10 CFR 50, Criterion ll, "Quality Assurance Program,"requires, in part, that the licensee establish a quality assurance program which complieswith Appendix B. This program shall be documented by written policies, procedures, orinstructions and shall be carried out throughout plant life in accordance with those policies,procedures, or instructions. The program shall provide for indoctrination and training ofpersonnel performing activities affecting quality as necessary to assure that suitableproficiency is achieved and maintained.Enclosure 24The Entergy Quality Assurance Program Manual, Revision 13, is the document used ateach Entergy-owned site to describe the quality assurance program. Table 1, Section A ofthe Quality Assurance Program Manual states, in part, that qualifications and experiencefor station personnel shall meet ANSI/ANS 3.1-1978 except for positions where anexception to either ANSI/ANS 3.1-1978 or N18.1-1971 is stated in the applicable unit'sTechnical Specifications.ANSI/ANS 3.1-1978, Section 4.4.5, "Quality Assurance," states, in part, that theresponsible person (i.e. the Quality Assurance Manager) shall have six years experiencein the field of quality assurance. At least one year of this six years experience shall beobtained within the quality assurance organization.Contrary to the above, between February 22 and June 30, 2010, the licensee failed toimplement the quality assurance program requirements intended to provide indoctrinationand training of personnel performing activities affecting quality as necessary to assure thatsuitable proficiency was achieved and maintained. Specifically, the individual assigned tobe the responsible person for the licensee's overall implementation of the QualityAssurance Program did not have at least one year of nuclear plant experience in theoverall implementation of the Quality Assurance Program within the quality assuranceorganization prior to assuming those responsibilities. Because this issue was of very lowsafety significance and was entered into the CAP as CR-HQN-2O10-00386, this violation isbeing treated as an NCV consistent with Section 2.3.2.a of the NRC's Enforcement Policy.(NCV 05000293/2010005-03, Failure to lmplement the Experience and QualificationRequirements of the Quality Assurance Program).4OA5 Othef ActivitiesInstitute of Nuclear Power Operations (INPO) and World Association of Nuclear Operators(WANO) Plant Assessment Report Reviewa. Inspection ScopeThe inspectors reviewed the report for the INPOMANO plant assessment of the PilgrimNuclear Power Station conducted in December 2010. The inspectors reviewed the reportto ensure that issues identified were consistent with the NRC perspectives of licenseeperformance and to verify if any significant safety issues were identified that requiredfurther NRC follow-up.b. FindinqsNo findings were identified.4OAO Meetinqs. Includinq ExitOn October 21,2010, a Radiation Safety exit meeting was conducted with Mr. StephenBethay and other members of the Pilgrim staff. The inspectors confirmed that noproprietary information was provided during the inspection.Enclosure On January 5,2011, the resident inspectors conducted an exit meeting and presented thepreliminary inspection results to Mr. Robert Smith, and other members of the Pilgrim staff.The inspectors confirmed that proprietary information provided or examined during theinspection was controlled andior returned to Entergy, and the content of this reportincludes no proprietary information.On January 10,2011, the inspector presented the results of the Selected lssue Follow-uplnspection of quality assurance and quality control issues to Mr. T. White, Manager, QualityAssurance, and other members of the Pilgrim staff. The inspectors confirmed that noproprietary information was provided during the inspection.40 A7 Licensee-ldentified ViolationsThe following violation of very low safety significance (Green) was identified by thelicensee and is a violation of NRC requirements, which meets the criteria of Section Vl ofthe NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.Procedure, EN-QV-111, "Training and Certification of lnspectionA/erification andExamination Personnel," Section 4.0 [4](i), requires that the Entergy corporate ANSILevel lll inspector shall perform periodic (annual) surveillances of quality controlinspection activities to ensure that the program is being adequately implemented andmaintained. Contrary to the above, no surveillances of quality control inspectionactivities were performed for any Entergy site during calendar year 2008. The issuewas not suitable for quantitative significance determination, so it was assessed usingIMC 0609, Appendix M, and was evaluated using the qualitative criteria listed in Table4.1. This finding was determined to be of very low safety significance because otherquality assurance program functions remained unaffected by this performancedeficiency, so defense-in-depth continued to exist. This issue was entered into thelicensee's CAP as CR-HQN-2009-001 1 1.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Director, Nuclear Safety AssuranceSystem Engineering ManagerEngineering DirectorLicensing EngineerLicensing ManagerAssistant Operations Manager-ShiftChemistry ManagerOperations ManagerRadiation Protection ManagerChemistry SupervisorStaff ChemistSite Vice PresidentMaintenance Manager

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSEDFailure to Manage a Yellow Risk Condition During HPCITesting from the Alternate Shutdown Panel (Section 1R13)Failure to Perform Required Quality Control Inspections(Sections 4OA2)Failure to lmplement the Experience and QualificationRequirements of the Quality Assurance Program(Section 4OA2)Opened and ClosedN CV 05000 293 l 201 0005-0 1N CV 05000 2931 201 0005-02N CV 05000 2g3l 201 0005-03Attachment

A-2

LIST OF DOCUMENTS REVIEWED

Section 1R04Procedure 2.2.8, Revision 96, Standby AC Power System (Diesel Generators)CR-PNP-2010-3735, 'A' EDG Jacket Water Temperature Switch DefectiveCR-PNP-2010-3744, 'A' EDG Ventilation Damper

VD-2-8 failed in open position procedureProcedure 2.1.12.1, Attachment 1, Revision 72, Emergency Diesel Generator SurveillanceProcedure 2.2.79, Revision 39, Reactor Protection SystemTraining Manual Diagrams of RPSSection 1R05Procedure 5.5.2, Revision 46, Special Fire ProcedureFire Hazards Analysis , Fire Zone Data Sheet for the 'A' Residual Heat Removal Pipe RoomFire Hazards Analysis, Fire Area 1.10, Fire Zone 4.1, 'B' Train Emergency DieselGenerator RoomCR-PNP-2010-03987, Senior NRC Resident found a hose station typographical error in theFire Hazards AnalysisFire Hazards Analysis, Fire Area 1.9, Fire Zone 3.5, Vital Motor Generator Set RoomCR-PNP-2010-3948, Rolling Fire Door in lower switchgear room did not close completelyCR-PNP-2010, 4001, hourly fire watch sheet date was wrong in lower switchgear roomProcedure 8. B. 1 4, Revision 44, Fire Protection Technical RequirementsProcedure 8.8.17.1, Revision 20, Inspection of Fire Door AssembliesFire Hazards Analysis, Fire Area 1 .10, Fire Zone 2.1 , 'B' Switchgear and Load Center RoomFire Hazards Analysis, Fire Area 1.10, Fire Zone2.11A, Turbine Deck-West EndSection 1Rl1LORTiNRC Simulator Exam Scenario,

SES-2010-06, Revision 0, Loss of Feedwater Heatingwith Fuel Damage accompanied by RWCU leakLORT/NRC Simulator Exam Scenario,

SES-2010-04, Revision 0, small LOCA duringstation blackoutSection 1R12NUMARC 93-01, Revision 2, industry guideline for monitoring the effectiveness of maintenanceat nuclear power plantsProcedure

EN-DC-150, Revision O, Condition Monitoring of Maintenance Rule StructuresCR-PNP-2010-3696, main breakwater stones are missingMaintenance Rule SSC Basis Document, Buildings and StructuresCR-PNP-2010-4167, unclarity in maintenance rule decisions regarding structures categoryPost Accident Sampling System Maintenance Rule (aX1) Action PlanPost Accident Sampling System Maintenance Rule SSC Basis DocumentUFSAR Chapter 10.19, Post Accident Sampling SystemEC23680, Evaluation of PASS Heat Trace Circuits Required for System OperationCR-PNP-2008-2120, PASS has been declared potentially maintenance rule (aX1)due to recurring heat trace problemsAttachment

A-3EC12377, Replace H202 and PASS Health Trace System Temperature ControllersPost Accident Sampling System DrawingsPost Accident Sampling System Heat ReportSection 1R13Operator's Risk Report for 1Q127110-10129110Equipment Out-of-Service (EOOS) ToolProcedure

EN-DC-151, Revision 1, PSA Update and MaintenanceCR-PNP-2010-3860, Uncertainty with the Diesel Fire Pump being out-of-service with theVEX-101

OOSCR-PNP-2010-0388,

VEX-101 OOS raises the question of Diesel Fire Pump AvailabilityOperator's Risk Report for 1111110-1112110NUMARC 93-01, Revision 2, Industry Guideline for Monitoring the Effectiveness ofMaintenance at Nuclear Power PlantsProcedure 1.5.22, Revision 12, Risk Assessment ProcessProcedure 2.4.143, Revision 45, Shutdown from outside control roomProcedure 8.5.4.6, Revision 38, HPCI Pump and Valve Operability from alternate shutdown panelSection 1R15CR-PNP-2010-3551 , Transfer Switch Y-10 acting sluggishly when transferring back to normalpower supplyCR-PNP-2O10-3735, 'A' EDG Jacket Water Temperature Switch found defective andassociated operability evaluationCR-PNP-2010-3561, 'A' EDG Jacket Water Temperature found out-of-specificationProcedure 2.1.35, Revision 51, daily rounds (EDG Room Temperature Portion) andcontrol room readingsEN-OP-104, Revision 4, Operability Determination ProcessCR-PNP-2010-3696, Main Breakwater Stones are missing in previously identified areaand associated operability evaluationCR-PNP-2007-2691, Main Breakwater Stones are missingBoston Edison Letter #79-199, to NRC, dated September 28,1979CR-PNP-2O10-383, RHR / FPC Supports Degraded and Non-FunctionCR-PNP-2O10-3621, RHR Drawing indicates FPC pipe as non-Q versus safety-relatedCR-PNP-2010-3939, Drain Valve of Moisture Separator Drain Tank not maintaining normal levelOperational Decision Making lssue (ODMI) lmplementation Action Plan dated 111512010Section 1Rl9Work Order (WO) #00245032, Tasks 1&2, 8.Q.3.8.1, MOV Maintenance and Inspection(MO-1301-26)CR-PNP-2O10-3479, Discovered Strain Gauge off of

MO-1301-26WO#52246521, Tasks 1&2, Stem Lube for Reactor Core lsolation Cooling (RCIC) Valvesand Post Maintenance TestProcedure 8.Q.3-8.1, Revision 15, Limitorque Type HBC, SB/SMB-OO, and type

SMB-000Valve Operator MaintenanceWO#52186868, Tasks 1-4, Line 342 CCVT Inspection and TestingAttachment

A-4WO#52186868, Task 6, Line 342 CCt.fI Post Maintenance TestWO#52186868, Tasks 7-10, Installation of New CCVT for Line 342 and Post Maintenance TestWO#255378, Tasks 13 and 4 received spurious half scrams from RPS Channel 'B'WO#255378, Task 5, Post Maintenance Test of 'B' RPSWO#0024610601, X-107A, Replace Start Button in Panel

C-1038,'A'EDG iaw 3.M.3-51W0#5229362501, Train'A' Emergency Diesel Generator SurveillanceWO#00247107, Procedure 8.F.38.1, Diesel Generator Instrumental Calibration and Function TestCR-PNP-2010-4293, Time delays found outside procedure limitsCR-PNP-2010-4313, Air Start Motor Position M2 used during testingWO#001 81 369, Replace

VSF-2068EC-20051, Revision 0, Replace Main Stack Dilution FansCR-PNP-2010-4072, VSF206A tripped during VSF206B replacementECT-20051-01, Revision 0, functional test for

VSF-2068Procedure 3.M.3-51, Revision 27, Electrical Termination ProcedureProcedure 3.M.3-4, Revision 55, Insulation TestProcedure 3.M.4-14, Revision 39, Rotation Equipment Inspection Assembly and DisassemblySection 1R22WO#52287476, Task 1,8.9.1 (TS Surveillance) EDG Train A SurveillanceProcedure 8.9.1, Revision 1 16, Emergency Diesel Generator and Associated EmergencyBus SurveillanceTech nical SpecificationsCR-PNP-2010-3896, Timer

TMR1-45009, did not stop to indicate EDG start timeControl Room Logs for 11l2l1oProcedure 1.3.34, Revision 117, Operations Administrative Policies and Processes,Section 6.1 0, Pre-Evolution BriefingsProcedure 8.5.2.2.2, Revision 43, LPCI System LOOP B Operability-Pump Quarterly andBiennial Flow Rate Tests and Valve TestsWO#52278449, Task 1, Perform HPCI Operability Test at 1000psigProcedure 8.5.4.1, Revision 106, High Pressure Coolant lnjection (HPCI) System Pumpand Valve Quarterly OperabilityProcedure 9.39, Revision 0, Channel Control Blade lnterference TestingECH-NE-09-0056, Revision 1, PNPS Cycle 18 Channel-Control Blade InterferenceMonitoring PlanCR-PNP-2010-3635, Control Rod 46-39 did not meet acceptance criteria for settle timeCR-PNP-2010-4229, Control Rod 06-39 shows indication of channel control blade interferenceCR-PNP-2010-4230, unable to perform full stroke insertion testing on control rods 06-39 and46-39Procedure 8.5.1.1, Revision 55, Core Spray System Operability-Pump Quarterly andBiennial Comprehensive Flow Rate Tests and Valve TestsCR-PNP-2O10-3815, Suction Pressures were inconsistent during'B'Core Spray PumpOperability TestControl Room Logs dated 1012812010CR-PNP-2O10-4479, Resident lnspector concerns regarding the conduct of the 'B' CoreSpray Pump Surveillance on 1012812010Attachment

A-5Section 2RS01EN-RP-101, Revision 5, Access Control for Radiological Controlled AreasEN-RP-108, Revision 9, Radiation Protection PostingEN-RP-121, Revision 6, Radioactive Material ControlEN-RP-131, Revision 8, Air SamplingcR-2009-04266cR-2010-01474cR-2009-04427cR-2010-01541cR-2009-04480cR-2010-01775cR-2010-01810cR-2010-01761cR-2009-04655cR-2009-04809cR-2009-04925cR-2009-05298cR-2010-00358cR-2010-00666cR-2010-00819cR-2010-00923cR-2010-00940cR-2010-00974cR-2010-00979Section 2RS02EN-RP-110, ALARA Program, Revision 7Section 4OA1NEI 99-02, Revision 6, Regulatory Assessment Performance Indicator GuidelinesEmergency Diesel Generator System Health Report, 2O1O 3'd quarterCR-PNP-2O10-3357, 'B' EDG Cooling Air Damper Pressure Regulator FailedNRC Performance Indicator Technique I Data Sheets generated 4tn quarter 2009 through3'd quarter 2010Licensee Event Reports issued 4th quarter 2009 through 3'o quarter 2010CR-PNP-2010-3682, during a review of MSPI data, the NRC Sr. Resident Inspector questionedthe validity of the method used to account for EDG short term unavailabilityMSPI Data Sheets for Cooling Water for both Reactor Building Closed CoolingWater (RBCCW) and Salt Service Water (SSW)Section 4OMMiscellaneousCR-PNP-2009-4197, Gaps to Excellence in the lmplementation of the Maintenance RuleCR-PNP-2010-2211, Inconsistent lmplementation of the Maintenance Rule FunctionFailure Determination ProcessAttachment

A-6Pilgrim Station Quarterly Trend ReportsCR-PNP-2010-4479, Resident lnspector concerns regarding the conduct of the 'B' CoreSpray Pump Surveillance on 1012812010EN-OP-1 04, Revision 4, Operability Determination ProcessCR-PNP-2010-3815, Suction Pressures were inconsistent during'B'Core Spray PumpOperability TestEOI LetterResponse to Request for lnformation, Revision 1ENOC-10-00002EOI Letter Response to Request for InformationENOC-09-000371t8t1011t30t100 through 2011978QAPMRegulatoryGuide 1.8ANSI/ANS 3.1-1978ANSI N18.1-1971NRC SEREOI LetterBVY 03-12Entergy Quality Assurance Program ManualPersonnel Selection and TrainingAmerican National Standard for Selection and Training ofNuclear Power Plant PersonnelQuality Assurance Program Consolidation"Technical Unit Staff QualificationsSpecification5.3.1 Personnel Change Planning ChecklisVForms for QAManager CandidatesCEO2009-00195 Corporate ANSI Level lll Surveillance of W MaintenanceAmerican National Standard for Selection and Training of 1971Nuclear Power Plant PersonnelNRC Safety Evaluation Report, "Entergy Operations, Inc.11t6t98variousJuly 2QO712t15t2009Inspection Program (VfY)Vermont Yankee Nuclear Power Station, Docket No. 50-271 0210512003Annual Submittal of QAP Changes (WY)CfN-2003/00059 Vermont Yankee, 10 CFR Part 50.54(aX3) Change Review 0412412002EOI Letter No. Forms for QAPM Rev 8 (VfY)cNRO-2003-013EOI Letter No. Entergy Quality Assurance Program Manual, Rev. 8 (VfY) 0412412003cEXO-2003t164EOf Letter NO. lssuance of Entergy Quality Assurance Program Manual 0412412003CNRO-20021027 (OAPM) Revision 8 (WY)Attachment

cFR 50.59Review FormENO Letter No.1.2.02-067EN-QV-104Attachment 9.1ENOC LetterNO.07-0020AP-20.06,Attachment 1MCM-4.1Attachment 4.1AP-20.09Attachment 1Entergy LetterJLtC-02-017ENO Letter1.2.02-060Entergy LettercNRO-2002-02710

CFR 50.5a(a)EvaluationENO Letter1.2.02-060ENO MeetingSummaryA-7Entergy Quality Assurance Program Manual, Revision 7(PNPS)Entergy QA Program Manual, Revision 7 (PNPS)Entergy QA Program Manual, Revision 7 (PNPS)Independent Spent Fuel Storage lnstallationEntergy QA Program Manual Change Review Form50.5a(a) Parts 1,2 and 3 (PLP)Entergy QA Program Manual, Revision 16, Annual Report10

CFR 50.54(a)(3) and10 CFR72.140(d) (PLP)FSAR Change Request Form, Relocate QA Program fromChapter 17 to Entergy QAPM (JAF)Nuclear Engineering 10

CFR 50.59 Screening Form (JAF)Process Applicability Screening - Relocate QA ProgramFrom FSAR Ch. 17 to Entergy QAPM (JAF)Cross Reference of QAPM commitments to lmplementingprocedures at JAFAdaptation of Entergy Common QAPM, Revision 7 (JAF)Entergy QA Program Manual, Revision 7 (JAF)QA Program Change/Prior Approval Determination - Part A(rP3)Adaptation of Entergy Common QAPM, Revision 7,(lP2 and lP3)Development of Common QA Manual for northern EntergySites and Entergy Nuclear Generating Company Plants04t25t2002051021200207t30t200204.05t20070411512007051061200204t03t200204t01t200204t02t2002061211200204t25t2002051061200206t21t200211t3012001Enqineerinq ChanqeslMaintenance Work OrdersANO-EC-0703205885ANO-EC-0288609121RBS-EC-00893

RBS-EC-70734

GGN-EC-o1450RBS-EC-02692

GGN-EC-00085

GGN-EC-01452PLP-EC-PLP-EC-Attachment

ANO-EC-0306912392ANO-EC-0446114181ANO-EC-0804318042ANO-EC-0060806553WF3-EC-1545112731wF3-EC-10706wF3-EC-o1830wF3-EC-07960WF3-EC-O1166wF3-EC-09046wF3-EC-00935WF3-EC-01166WF3-EC-01396wF3-EC-01782wF30EC-03013wF3-EC-11284WF3-EC-13981ProceduresEN-Lt-121EN-MA-102EN-QV-1OOEN-QV-109EN-QV-109-02EN-QV-111EN-QV-117EN-QV-119EN-QV-123EN-QV-128EN-QV-129RBS-EC-03275RBS-EC-03643RBS-EC-03850RBS-EC-03275RBS-EC-05932RBS-EC-06947RBS-EC-07239RBS-EC-08504RBS-EC-12204RBS-EC-13128RBS-EC-16451RBS-EC-70752RBS-EC-07368RBS-EC-03852RBS-EC-03853RBS-EC-03975RBS-EC-70733A-8GGN-EC-00224GGN-EC-02048GGN-EC-02058GGN-EC-02065GGN-EC-02107GGN-EC-02110GGN-EC-02201GGN-EC-02784GGN-EC-04538GGN-EC-06299GGN-EC-06301GGN-EC-07471GGN-EC-07716GGN-EC-06875GGN-EC-06039GGN-EC-06086GGN-EC-00494GGN-EC-02048GGN-EC-02065GGN-EC-13326GGN-EC-13354GGN-EC-13355ANO U-1

EC 01039ANO U-1

EC 05808ANO U-1

EC 13153ANO U-1

EC 00380ANO U-1

EC 05054ANO U-1

EC 05388ANO U-1

EC 06241ANO U-1

EC 07032ANO U-1

EC 13224WF3-EC-844881wF3-EC-05854VYT-EC-O3138PLP-EC-PLP-EC-PLP-EC-PLP-EC-PLP-EC-Entergy Trending ProcessInspection ProgramConduct of Nuclear OversightAudit ProcessAudit Process GuidanceTraining and Certification of InspectionA/erification andExamination PersonnelOversight Training ProgramCorrective Action Requests, Supplier Stop Work Orders, andRecommendationsSupplier Audits/SurveysAssessments of Nuclear Oversight?Vulnerability Review ProcessRev 8Rev 3 and 4Rev 4Rev 16Rev 0Rev IRev 9Rev 6Rev 3Rev 2Rev 1CONDITION REPORTScR-ANO-1-2009-02330CR-ANO-1 -2010-00743CR-ANO-2010-01503Attachment

CR-ANO-C-2009-01884cR-ANO-C-2009-02608CR-AN0-2-2010-00028cR-JAF-2008-03648CR-HQN-2010-001 1 1cR-HQN-2009-00178cR-HQN-2009-01083cR-HQN-2009-01084cR-HQN-2009-01085cR-HQN-2009-01091cR-HQN-2009-01093cR-HQN-2009-01096CR-HON-2009-01 140cR-HQN-2009-01 150CR-HQN-2009-01 169CR-HQN-2009-01 170CR-HQN-2009-01 184cR-tP2-2010-04085cR-tP3-2010-01740cR-tP2-2010-03985cR-tP2-2010-03986cR-lP2-2010-03988cR-tP2-2010-03984cR-rP3-2009-04903cR-tP3-2009-04905cR-PLP-2009-04108cR-PLP-2009-05613cR-PLP-2009-05918cR-PLP-2009-05908cR-PNP-2009-01798cR-PNP-2009-02059cR-PNP-2009-02255cR-PNP-2008-00916cR-RBS-2008-04685CR-RB3-2009-05041CR-RBS-2009-06123A_9CR-ANO-1 -2010-01724CR-ANO-1 -2010-01182cR-JAF-2009-04592cR-HQN-2009-01 188cR-HQN-2009-01 197CR-HQN-2010-00013cR-HQN-2010-00386cR-HQN-2010-00571CR-HQN-2010-00593cR-HQN-2010-00515cR-HQN-2010-00550CR-HQN-2010-0051 1cR-HQN-2010-00510cR-HQN-2010-00475cR-HQN-2010-00499cR-HQN-2010-00338cR-tP3-2009-04917cR-lP3-2009-04920cR-tP3-2009-04897cR-tP2-2009-05404cR-tP2-2009-05409cR-tP3-2009-04868cR-rP3-2009-04883cR-rP3-2009-04884cR-PLP-2010-02288cR-PLP-2010-02290cR-PLP-2009-05942cR-PNP-2008-03922cR-PNP-2009-05359CR-PNP-2010-00015cR-RBS-2010-01472CR-RBS-2010-02033CR-RBS-2010-00200CR-ANO-1-2010-01080CR-ANO-1 -2010-00719CR-JAF-2010-03280CR-HON-2010-00415cR-HQN-2010-00333cR-HQN-2010-00123cR-HON-2010-00109cR-HQN-2010-00068cR-HQN-2010-00063cR-HQN-2010-00045cR-HQN-2010-00060CR-HQN-2009-01 198CR-HQN-2009-01 194cR-HQN-2010-00594oR-HQN-2009-01 171CR-HQN-2009-01 153cR-tP2-2009-05393cR-rP2-2009-05399cR-tP2-2009-05400cR-tP2-2009-05389cR-tP2-2009-05349cR-rP2-2009-05348cR-lP2-2009-05321cR-PLP-2009-05909cR-PLP-2010-02012cR-PLP-2009-05897cR-PNP-2009-05303cR-PNP-2009-05297cR-PNP-2010-02124cR-RBS-2010-00006cR-RBS-2009-06472cR-RBS-2009-06495Attachment

cR-RBS-2009-06446cR-RBS-2009-06451cR-RBS-2009-06471cR-RBS-2009-06473cR-RBS-2009-06490CR-RBS-2O10-00044cR-wF3-2010-01 198cR-wF3-2010-01356cR-wF3-2010-00746cR-wY-2009-04496cR-wY-2O10-01479cR-wY-2O10-02759CR-GGN-2010-04140cR-GGN-2010-02730CR-GGN-2010-04178CR-GGN-2010-04101cR-GGN-2010-04092cR-GGN-2010-03674cR-GGN-2010-03721CR-GGN-2010-03900cR-cGN-2010-03451CR-GGN-2010-03492CR-ANO-1-2009-02330A-10cR-RBS-2010-00221CR-RBS-2o10-00278cR-RBS-2010-00088CR-RBS-2010-0001 1cR-RBS-2009-06520cR-RBS-2009-06539cR-wF3-2010-00284cR-wF3-2009-07713cR-wY-2o10-04432cR-wY-2010-04434cR-GGN-2010-02135cR-GGN-2010-02382cR-GGN-2010-02902cR-GGN-2010-00590cR-GGN-2010-01247cR-GGN-2010-01252cR-GGN-2009-06575cR-GGS-2009-06907cR-GGS-2009-06920CR-ANO-2o10-01503cR-RBS-2009-06456cR-RBS-2009-06450cR-RBS-2009-06452cR-RBS-2009-061s8cR-RBS-2009-06209cR-RBS-2009-06449cR-wF3-2009-07711cR-wF3-2010-02629cR-wY-2o10-04496cR-wY-2o10-00070cR-GGS-2009-06921cR-GGS-2009-06922cR-GGS-2009-06923cR-GGS-2009-06927cR-GGS-2009-06806cR-GGN-2010-00164cR-GGN-2009-06904cR-GGN-2009-06910cR-GGN-2009-06505CR-ANO-1 -2010-00743Attachment

ADAMSALARAASPCFRCRDRPDRSEDGHPCItMcMRPNCVNEINRCPIPNPSRPRPMRPSRWP'sSSCTIPVHRAWOA-11

LIST OF ACRONYMS

Agencywide Documents Access and Management SystemAs Low As Reasonably AchievableAlternate Shutdown PanelCode of Federal RegulationsCondition ReportDivision of Reactor ProjectsDivision of Reactor SafetyEmergency Diesel GeneratorHigh Pressure Coolant InjectionInspection Manual ChapterMaintenance Rule ProgramNon-Cited ViolationNuclear Energy lnstituteNuclear Regulatory CommissionPerformance IndicatorPilgrim Nuclear Power StationRadiation ProtectionRadiation Protection ManagerReactor Protection SystemRadiation Work Permit(s)Structure, System or ComponentTraversing ln-Core ProbeVery High Radiation AreaWork OrderAttachment

IR 05000293/2010005

Text

Dear Mr. Smith:

Enclosure:

Attachment:

SUMMARY OF FINDINGS

Cornerstone: Mitigating Systems

REPORT DETAILS

1R11 Licensed Operator Requalification Proqram (71 1 11

1R12 Maintenance Effectiveness (71 1 1 1

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KEY POINTS OF CONTACT

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IR 05000293/2010005

Text

Dear Mr. Smith:

Enclosure:

Attachment:

SUMMARY OF FINDINGS

Cornerstone: Mitigating Systems

REPORT DETAILS

1R11 Licensed Operator Requalification Proqram (71 1 11

1R12 Maintenance Effectiveness (71 1 1 1

=

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

LIST OF ITEMS

LIST OF DOCUMENTS REVIEWED

LIST OF ACRONYMS

Navigation menu

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