IR 05000293/2018002
| ML18226A023 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/14/2018 |
| From: | Anthony Dimitriadis NRC/RGN-I/DRP/PB5 |
| To: | Brian Sullivan Entergy Nuclear Operations |
| Dimitriadis A | |
| References | |
| IR 2018002 | |
| Download: ML18226A023 (26) | |
Text
UNITED STATES gust 14, 2018
SUBJECT:
PILGRIM NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000293/2018002
Dear Mr. Sullivan:
On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Pilgrim Nuclear Power Station (Pilgrim). On July 24, 2018, the NRC inspectors discussed the results of this inspection with Mr. Bruce Chenard, Acting General Manager of Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
One finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. Further, inspectors documented two licensee-identified violations, one of which was determined to be of very low safety significance, and one of which was determined to be Severity Level IV, in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Pilgrim. In addition, if you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at Pilgrim. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Number: 50-293 License Number: DPR-35
Enclosure:
Inspection Report 05000293/2018002
Inspection Report
Docket Number: 50-293 License Number: DPR-35 Report Number: 05000293/2018002 Enterprise Identifier: I-2018-002-0059 Licensee: Entergy Nuclear Operations, Inc. (Entergy)
Facility: Pilgrim Nuclear Power Station Location: Plymouth, Massachusetts Inspection Dates: April 1, 2018 to June 30, 2018 Inspectors: E. Carfang, Senior Resident Inspector B. Pinson, Resident Inspector P. Boguszewski, Acting Resident Inspector J. Ambrosini, Acting Senior Resident Inspector S. Wilson, Health Physicist D. Kern, Senior Reactor Inspector M. Rossi, Resident Inspector M. McLaughlin, Senior Enforcement Specialist Approved By: Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Entergys performance at Pilgrim by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealing findings, violations, and additional items are summarized in the table below.
Licensee-identified non-cited violations (NCVs) are documented in report Section 71153.
List of Findings and Violations Failure to Properly Implement the Fatigue Management Program - Work Hour Controls for Covered Workers Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green P.3 - Resolution 71152 NCV 05000293/2018002-01 Annual Opened/Closed Follow-up of Selected Issues The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR)26.205(d). During the period December 2017 to April 2018, Entergy did not properly control the work hours of several workers who performed work covered under 10 CFR 26.4(a).
Specifically, on eleven occasions, workers exceeded one of the following work hour limits: (1)16 work hours in any 24-hour period; (2) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period; or (3) 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> per week average over a 6-week rolling time period.
Loss of Secondary Containment Integrity due to Simultaneously Opened Airlock Doors Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green H.9 - Training 71153 FIN 05000293/2018002-02 Follow-up of Opened/Closed Events and Notices of Enforcement Discretion A self-revealed Green finding was identified when personnel did not implement a procedure requiring the closure and verification of doors credited with specific design functions.
Procedure 1.3.135, Control of Doors, requires station personnel to ensure closing and latching of doors. Failure to meet this requirement caused the loss of secondary containment integrity and unplanned entry into Technical Specification (TS) condition 3.7.C.1.
480V Bus B6 Auto Transfer Function Degraded Due to Time Delay Relay Failure Cornerstone Severity Cross-Cutting Inspection Aspect Results Section Not Applicable Severity Level IV Not Applicable 71153 NCV 05000293/2018002-03 Follow-up of Opened/Closed Events and Notices of Enforcement Discretion The inspectors identified a Severity Level IV NCV of TS 3.5.A.2 because a component of the low pressure coolant injection system was inoperable between May 12, 2015, and May 3, 2017, during which time, on occasions, core spray systems were also not operable.
Specifically, a relay, used to transfer the power feed for the low pressure coolant injection valves to the backup source in the event of a degraded voltage condition, failed during testing.
As a result, under certain conditions, the transfer would not have automatically occurred. This condition existed through the operating cycle, during which time the core spray pumps were also inoperable when removed from service for scheduled maintenance.
Additional Tracking Items Type Issue number Title Inspection Status Results Section LER 05000293/2015-004-01 480V Bus B6 Auto Transfer Function 71153 Closed Degraded, on March 8, 2016 LER 05000293/2016-008-00 Emergency Diesel Generator A Past 71153 Closed Inoperability LER 05000293/2017-008-00 480V Bus B6 Auto Transfer Function 71153 Closed Degraded, on March 8, 2016 LER 05000293/2017-008-01 Supplement 480V Bus B6 Auto 71153 Closed Transfer Function Degraded, on March 8, 2016 LER 05000293/2017-011-00 Simultaneously Opened Reactor 71153 Closed Building Airlock Doors Caused Loss of Secondary Containment LER 05000293/2017-013-00 Reportable Conditions Involving 71153 Closed Standby Gas Treatment System and Secondary Containment Inoperability Not Reported in the Previous Three Years LER 05000293/2017-013-01 Supplement to Reportable Conditions 71153 Closed Involving Standby Gas Treatment System and Secondary Containment Inoperability Not Reported in the Previous Three Years
TABLE OF CONTENTS
PLANT STATUS
INSPECTION SCOPES
................................................................................................................
REACTOR SAFETY
............................................................................................................
RADIATION SAFETY
..........................................................................................................
OTHER ACTIVITIES - BASELINE
....................................................................................
INSPECTION RESULTS
............................................................................................................
EXIT MEETINGS AND DEBRIEFS
............................................................................................ 21
DOCUMENTS REVIEWED
......................................................................................................... 22
PLANT STATUS
The unit began the inspection period in cold shutdown. On April 17, 2018, operations personnel
commenced a reactor startup and returned the unit to rated thermal power. On April 27, 2018,
operators commenced a shutdown to correct an issue with the feedwater regulating valves. On
May 2, 2018, operators commenced a startup and returned the unit to rated thermal power. On
May 15, 2018 and May 17, 2018, operators lowered power to approximately 60 percent power
to perform backwashes of the main condenser then returned the unit to rater thermal power. On
June 27, 2018, operators performed a down power to approximately 35 percent power to
perform thermal and mechanical backwashes of the main condenser. In addition, Entergy
cleaned and inspected a main condenser water box. The unit was returned to rated thermal
power on June 30, 2018.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures in effect
at the beginning of the inspection unless otherwise noted. Currently approved inspection
procedures with their attached revision histories are located on the public website at
http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the inspection procedure requirements most
appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2515,
Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant
status activities described in Inspection Manual Chapter 2515, Appendix D, Plant Status, and
conducted routine reviews using Inspection Procedure 71152, Problem Identification and
Resolution. The inspectors reviewed selected procedures and records, observed activities,
and interviewed personnel to assess Entergys performance and compliance with Commission
rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Summer Readiness (1 Sample)
The inspectors evaluated summer readiness of offsite and alternate alternating current
power systems the week of May 28, 2018.
Seasonal Extreme Weather (1 Sample)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the
seasonal warm temperatures and heavy rains on May 29, 2018.
71111.04 - Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) B train of shutdown cooling after swapping from A train shutdown cooling on
April 5, 2018
(2) Reactor core isolation cooling system during high pressure coolant injection system
isolation testing on May 9, 2018
(3) B emergency diesel generator following maintenance on June 21, 2018
71111.05A/Q - Fire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Salt service water bay on April 11, 2018
(2) Cable spreading room on May 9, 2018
(3) Upper 4160 volt switchgear room on May 9, 2018
(4) A and B emergency diesel generator rooms on May 10, 2018
(5) A residual heat removal valve room on June 30, 2018
71111.06 - Flood Protection Measures
Internal Flooding (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the intake structure on
May 25, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated licensed operator requalification training, in
accordance with 10 CFR 55.59, on May 8, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated activities associated with the following licensed
operator performance in the control room:
(1) Shutdown cooling train swap from A to B on April 11, 2018
(2) Reactor startup on April 17, 2018
(3) A feedwater regulating valve failure on April 26, 2018
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated with
the following equipment and/or safety significant functions:
(1) Area and process radiation monitors the week of April 23, 2018
Quality Control (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the
following equipment performance issues:
(1) B emergency diesel generator damper modifications the week of May 7, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work
activities:
(1) Elevated outage risk for B emergency diesel generator out of service due to a fuel oil
transfer pump planned surveillance on April 2, 2018
(2) Elevated risk while shutdown cooling was secured for planned alternate trip system
testing on April 16, 2018
(3) Elevated risk for planned maintenance on the shutdown transformer and station blackout
diesel generator on May 21, 2018
(4) Elevated risk following emergent outage of shutdown transformer and station blackout
diesel generator on May 24, 2018
(5) Elevated risk during planned two year overhaul of B emergency diesel generator on
June 11, 2018
71111.15 - Operability Determinations and Functionality Assessments (6 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Missing/out of place piping supports in the control rod drive rod insertion and withdrawal
system on April 3, 2018
(2) A emergency diesel generator sparking on April 3, 2018
(3) Reactor building component cooling water motor operated inlet valve for A residual heat
removal heat exchanger (MO-4060A) failure on April 16, 2018
(4) Startup transformer nitrogen blanket leak during the week of April 23, 2018
(5) B residual heat removal pump lower than expected differential pressure on
May 18, 2018
(6) Shutdown transformer lockout of 4160 volt bus A8 on May 23, 2018
71111.18 - Plant Modifications (3 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1) B emergency diesel generator room damper position modification on April 4, 2018
(2) Startup transformer cooling system on April 12, 2018
(3) Startup transformer replacement on April 13, 2018
71111.19 - Post Maintenance Testing (9 Samples)
The inspectors evaluated post maintenance testing for the following maintenance/repair
activities:
(1) Standby gas treatment fan relay (OC-37-1416A1, A2, A3 and TD-62-1416A)
replacements on March 29, 2018
(2) Post work test on technical support center diesel run after sparking was observed on the
technical support center transformer on April 2, 2018
(3) Control rod drive piping supports the week of April 2, 2018
(4) Startup transformer replacement on April 13, 2018
(5) Post work test on high pressure coolant injection steam line inboard isolation valve after
packing adjustment on April 18, 2018
(6) Repair to junction box J2523 for temperature element repair on safety valve RV-203-4B
on April 20, 2018
(7) Post work test on combined intermediate valve (CIV-3) on May 2, 2018
(8) Feedwater three element level control system repairs on May 2, 2018
(9) B feedwater regulating valve repairs on May 2, 2018
71111.20 - Refueling and Other Outage Activities (2 Samples)
The inspectors evaluated forced outage activities for the following:
(1) Feedwater heater repairs and startup transformer replacement from March 6 to
April 17, 2018
(2) A and B feedwater regulating valve repairs from April 26 to May 2, 2018
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (4 Samples)
(1) 8.M.2-2.10.1, Degraded Voltage Relay testing on April 20, 2018
(2) 2.1.31, Rod Worth Minimizer Operability on April 30, 2018
(3) 8.5.4.1, High Pressure Coolant Injection System Pump and Valve Quarterly and Biennial
Comprehensive Operability on May 10, 2018
(4) 3.M.3-61.5, Overspeed Surveillance Testing of B Emergency Diesel Generator on
June 15, 2018
In-service (1 Sample)
(1) 8.I.11.21, Main Steam Isolation Valve Cold Shutdown Operability on April 29, 2018 and
May 1, 2018
71114.06 - Drill Evaluation
Emergency Planning Drill (1 Sample)
The inspectors evaluated the conduct of a routine Entergy emergency planning drill on
June 20, 2018.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (1 Sample)
The inspectors conducted independent radiation measurements during walkdowns of the
facility and reviewed:
the radiological survey program;
any changes to plant operations since the last inspection;
recent plant radiation surveys for radiological work activities;
air sampling and analysis; and
continuous air monitor use.
Instructions to Workers (1 Sample)
The inspectors reviewed high radiation area work permit controls and use, reviewed
electronic alarming dosimeter alarms and set points, observed worker briefings on
radiological conditions, and observed containers of radioactive materials and assessed
whether the containers were labeled and controlled in accordance with requirements.
Contamination and Radioactive Material Control (1 Sample)
The inspectors observed the monitoring of potentially contaminated material leaving the
radiological controlled area and inspected the methods and radiation monitoring
instrumentation used for control, survey, and release of that material. The inspectors
selected several sealed sources from inventory records and assessed whether the sources
were accounted for and were tested for loose surface contamination. The inspectors
evaluated whether any recent transactions involving nationally tracked sources were
reported in accordance with requirements.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated in-plant radiological conditions and performed independent
radiation measurements during facility walkdowns and observation of radiological work
activities. The inspectors assessed whether posted surveys; radiation work permits; worker
radiological briefings and radiation protection job coverage of the Thermex System filters
filter replacement; the use of continuous air monitoring, air sampling and engineering
controls; and dosimetry monitoring were consistent with the present conditions. The
inspectors examined the control of highly activated or contaminated materials stored within
the spent fuel pool and the posting and physical controls for selected high radiation areas,
locked high radiation areas, and very high radiation areas.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors reviewed the procedures and controls for high radiation areas, very high
radiation areas, and radiological transient areas in the plant.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
The inspectors evaluated radiation worker performance with respect to radiation protection
work permit requirements. The inspectors evaluated radiation protection technicians in
performance of radiation surveys and in providing radiological job coverage.
71124.02 - Occupational As Low As Reasonably Achievable Planning and Controls
Radiological Work Planning (1 Sample)
The inspectors evaluated radiological work planning by reviewing significant work activities
to verify that as low as reasonably achievable planning was integrated into work procedures
and radiation work permit documents.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified Entergys performance indicators submittals listed below for the
period from April 1, 2017 through March 31, 2018. (3 Samples)
(1) Unplanned scrams per 7000 critical hours
(2) Unplanned power changes per 7000 critical hours
(3) Unplanned scrams with complications
71152 - Problem Identification and Resolution
Semiannual Trend Review (1 Sample)
The inspectors reviewed Entergys corrective action program for trends that might be
indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (2 Samples)
The inspectors reviewed Entergys implementation of its corrective action program related to
the following issues:
(1) Condition Report 2017-6029, Voiding in core spray A pump discharge line identified
through ultrasonic testing exam
(2) Condition Reports 2016-8289, 2017-1082, and 2017-7946, Deficient implementation of
EN-OM-123, Fatigue Management Program, to meet the requirements of 10 CFR Part 26, Subpart I, Managing Fatigue
71153 - Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (7 Samples)
The inspectors evaluated the following licensee event reports:
(1) Licensee Event Report 05000293/2015-004-01, 480V Bus B6 Auto Transfer Function
Degraded (ADAMS Accession No. ML16075A255). The circumstances surrounding
this licensee event report are documented in report section Inspection Results.
(2) Licensee Event Report 05000293/2016-008-00, Emergency Diesel Generator A
Past Inoperability (ADAMS Accession No. ML17010A035). The circumstances
surrounding this licensee event report are documented in Inspection Reports
05000293/2016011, Section 6.7.4.1 and 05000293/2017008, Enclosure 2.
(3) Licensee Event Report 05000293/2017-008-00, 480V Bus B6 Auto Transfer Function
Degraded Due to Time Delay Relay Failure (ADAMS Accession No. ML17212A615).
The circumstances surrounding this licensee event report are documented in report
section Inspection Results.
(4) Licensee Event Report 05000293/2017-008-01, Supplement to 480V Bus B6 Auto
Transfer Function Degraded Due to Time Delay Relay Failure (ADAMS Accession
No. ML17312A277). The circumstances surrounding this licensee event report are
documented in report section Inspection Results.
(5) Licensee Event Report 05000293/2017-011-00, Simultaneously Opened Reactor
Building Airlock Doors Caused Loss of Secondary Containment (ADAMS Accession
No. ML17234A318). The circumstances surrounding this licensee event report are
documented in report section Inspection Results.
(6) Licensee Event Report 05000293/2017-013-00, Reportable Conditions Involving
Standby Gas Treatment System and Secondary Containment Inoperability Not
Reported in the Previous Three Years (ADAMS Accession No. ML18033A326). The
circumstances surrounding this licensee event report are documented in report
section Inspection Results.
(7) Licensee Event Report 05000293/2017-013-01, Supplement to Reportable
Conditions Involving Standby Gas Treatment System and Secondary Containment
Inoperability Not Reported in the Previous Three Years (ADAMS Accession No.
ML18128A189). The circumstances surrounding this licensee event report are
documented in report section Inspection Results.
Personnel Performance (1 Sample)
The inspectors evaluated response during the following non-routine evolutions or transients:
(1) A feedwater regulating valve failure while at rated thermal power on April 26, 2018
INSPECTION RESULTS
Observations 71152
Semi-Annual Trend Review
The inspectors evaluated a sample of condition reports generated over the course of the past
two quarters by departments that provide input into the trimester trend reports. The
inspectors also evaluated maintenance backlogs, operator workarounds, operator burdens,
control room deficiencies, and site staffing in response to the planned decommissioning of the
unit in 2019. The inspectors determined that while Entergy, in general, identified issues at a
low threshold and entered them into the corrective action program, there continued to be self-
revealing and inspector identified procedure use and adherence (PU&A) issues that indicate a
continuing trend in the area of configuration control when operators inadvertently lowered
reactor water level by 10 inches (CR-PNP-2018-3531), and maintenance technicians
inadvertently raised hotwell level while working on an incorrect component (CR-PNP-2018-
4593). Additionally, inspectors identified low level PU&A related issues in the Radiation
Protection department and Maintenance departments over the previous two quarters.
Individually, Entergy identified PU&A as a contributor to these issues and developed
corrective actions to address the human performance aspects, including additional oversight
by department supervision, and continued focus on the appropriate use of human
performance tools (self-check, peer check, job site review). While PU&A errors did occur, as
described above, the previously identified negative trend has shown some
improvement. Specifically, errors in the past 6 months were less significant in
nature. Entergy has a human performance improvement plan developed under CR-PNP-
2017-5782 and identified the recent trend in CR-PNP-2018-5167.
Equipment reliability continued to challenge full power operation over the previous two
quarters, including a feedwater heater condenser tube failure on March 6, 2018 (CR-PNP-
2018-1943), the failure of the A feedwater regulating valve on April 26, 2018 (CR-PNP-2018-
3773), and the ongoing main condenser issues (CR-PNP-2018-4364, 4927, 5036, and 5255).
These issues required timely response by control room operators, and inspectors noted
improved operator performance relative to past events.
The issues identified above were determined to be minor because the transients were not
significant in nature per Inspection Manual Chapter 0612 and did not constitute a transient
(scram) per Inspection Manual Chapter 0609. The examples were non-compliances with site
procedures, but were not violations of a regulatory requirement.
Observations 71152
Annual Follow-up of Selected
Issues
Condition Report 2017-6029, Voiding in core spray A pump discharge line identified through
ultrasonic testing exam
The inspectors reviewed the apparent cause analysis and the corrective actions taken. The
inspectors concluded that the cause analysis was thorough, the extent of condition was
reasonable, and the corrective actions were timely. The original issue was identified in
Integrated Inspection Report 05000293/2017003 as NCV 05000293/2017003-07, Core Spray
Voiding Due to Inadequate Instructions (ADAMS Accession No. ML17319A158).
Observations 71152
Annual Follow-up of Selected
Issues
Condition Reports 2016-8289, 2017-1082 and 2017-7946, Deficient implementation of EN-
OM-123, Fatigue Management Program, to meet the requirements of 10 CFR Part 26,
Subpart I, Managing Fatigue
The inspectors determined several aspects of Fatigue Management Program implementation
has improved, including the following:
- The number of Work Hour Waivers was reduced [2015 (16), 2016 (31), 2017 (11)],
despite a continued large emergent maintenance workload and preventive
maintenance workload.
- Maintenance supervisors demonstrated greater awareness of their responsibility to
verify worker availability through the Personnel Qualification and Scheduling tracking
system prior to assigning overtime work.
- The 10 CFR 26.205(e) annual program self-assessment was thorough, with
meaningful findings and appropriate use of the corrective action program to address
identified deficiencies.
Notwithstanding, the inspectors identified several continued performance deficiencies which
are documented below as NCV 05000293/2018002-01.
Failure to Properly Implement the Fatigue Management Program - Work Hour Controls for
Covered Workers
Cornerstone Significance Cross-Cutting Report
Aspect Section
Initiating Events Green NCV P.3 - 71152
05000293/2018002-01 Resolution Annual
Open/Closed Follow-up of
Selected
Issues
The inspectors identified a Green NCV of 10 CFR 26.205(d). During the period December
2017 to April 2018, Entergy did not properly control the work hours of several workers who
performed work covered under 10 CFR 26.4(a). Specifically, on eleven occasions, workers
exceeded one of the following work hour limits: (1) 16 work hours in any 24-hour period; (2)
hours in any 7-day period; or (3) 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> per week average over a 6-week rolling time
period.
Description: Entergy previously implemented corrective actions to address deficient
implementation of EN-OM-123, Fatigue Management Program, Revision 13, to meet the
requirements of 10 CFR Part 26, Subpart I, Managing Fatigue. Annual self-assessments
(2015-2018) noted improvement, but also identified continued inconsistent verification of
worker hours in the Personnel Qualification and Scheduling tracking system prior to assigning
emergent work schedule changes. Corrective actions included training additional supervisors
on how to enter work-hours into the Personnel Qualification and Scheduling tracking system
and on methods of verifying work hour limits to ensure that limits are not exceeded prior to
assigning overtime. These corrective actions were completed on November 30, 2017.
The inspectors reviewed selected worker time records and the Personnel Qualification and
Scheduling database for the period December 24, 2017, to April 14, 2018, and identified three
instances where workers exceeded work hour limits without processing a work hour waiver
request or performing a fatigue assessment as required by EN-OM-123. Additionally, the
inspectors identified the following deficiencies and discussed them with licensee staff:
(1) Workers inconsistently charged time to shift turnovers (0, 0.5, 1.0, or 2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />), which
is excluded from work hour calculations. The inspectors reviewed NRC responses to
Fitness For Duty frequently asked questions and noted 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> is typically sufficient
for shift turnover. In many cases, workers charged excessive time to shift turnover
which should have been charged to covered work and counted against the work hour
limits. This practice artificially undercounted work hours and masked workers who
exceeded work hour limits.
(2) The Personnel Qualification and Scheduling tracking system database was not
updated with the most up-to-date hours worked thereby preventing the proper
verification of proposed assignment of overtime, resulting in workers to exceed work
hour limits.
- Sometimes, when assigning work, supervisors and watchbill coordinators did not
use the Personnel Qualification and Scheduling tracking system
- Some used it after work began vice prior to issuing watch bill change.
- The Personnel Qualification and Scheduling tracking system database had a high
error rate (29 of 330 entries were incorrect). In three instances, entire work days
had not been entered into the Personnel Qualification and Scheduling tracking
system.
Corrective Actions: In response to the inspectors concerns, Entergy performed an additional
review of work hours and identified eight additional instances where workers exceeded work
hour limits. Interim corrective actions included: Entergy requiring certain supervisors to verify
workers hours daily in the Personnel Qualification and Scheduling tracking system,
supervisors briefed on acceptable practices for charging time to shift turnover, and lessons-
learned communicated with the affected departments.
Corrective Action References: CR-PNP-2018-03632, CR-PNP-2018-03647, CR-PNP-2018-
03746, CR-PNP-2018-03755, and CR-PNP-2018-04145
Performance Assessment
Performance Deficiency: The inspectors determined the failure to control work hours as
required by EN-OM-123, Fatigue Management Program, and 10 CFR Part 26, Subpart I,
Managing Fatigue, was a performance deficiency. This performance deficiency was
reasonably within the Entergys ability to foresee and correct and should have been
prevented.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the human performance attribute of the Initiating Events
cornerstone and adversely affected the cornerstone objective to limit the likelihood of those
events that upset plant stability and challenge critical safety functions during shutdown as well
as power operations. Specifically, the resulting increased likelihood of human error and
associated potential to adversely impact equipment maintenance, availability, and reliability
increased the likelihood of an initiating event.
Significance: The inspectors assessed the significance of the finding using the Significance
Determination Process, Attachment 0609.04, Initial Characterization of Findings. Because
the finding impacted the Initiating Events cornerstone, the inspectors screened the finding
through Inspection Manual Chapter 0609, Appendix A, The Significance Determination
Process for Findings At-Power, using Exhibit 1, Initiating Event Screening Questions.
Although the increased likelihood of human error increased the likelihood of an initiating event
or adverse impact on mitigation equipment, the violation was determined to be of very low
significance because no significant event, reactor trip, or loss of mitigation equipment
occurred as a result of personnel fatigue linked to the hours worked.
Cross-Cutting Aspect: The cause of this finding, in accordance with Inspection Manual
Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014, has a
cross-cutting aspect in the area of Problem Identification and Resolution - Resolution
because corrective actions to ensure supervisors entered work hours into the Personnel
Qualification and Scheduling tracking system prior to assigning overtime were neither timely
nor effective. (P.3)
Enforcement
Violation: 10 CFR 26.205(d) states in part: Licensees shall control the work hours of
individuals who are subject to this section. (i) Except as permitted in 26.207, licensees shall
ensure any individuals work hours do not exceed the following limits: (ii) 16 work hours in any
24-hour period; (iii) 72 work hours in any 7-day period; and 26.205 (d)(7)(i) Individuals may
not work more than a weekly average of 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />, calculated using an averaging period of up
to 6 weeks. Procedure EN-OM-123 establishes the Entergy Fatigue Management Program
controls which implement the requirements of 10 CFR Part 26.
Contrary to the above, from December 24, 2017, until April 14, 2018, on eleven instances
Entergy did not control work hours to ensure individuals work hours did not exceed the work
hour limits specified in 10 CFR 26.205(d) and EN-OM-123.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2
of the Enforcement Policy.
Loss of Secondary Containment Integrity due to Simultaneously Opened Airlock Doors
Cornerstone Significance Cross-Cutting Report
Aspect Section
Reactor Safety - Green FIN H.9 -Training 71153(5)
Barrier Integrity 05000293/2018002-02 Follow-up of
Closed Events and
Notices of
Enforcement
Discretion
A self-revealed Green finding was identified when Entergy did not ensure implementation of
Procedure 1.3.135, Control of Doors, which requires station personnel to ensure closing and
latching of doors. This resulted in the loss of secondary containment integrity and unplanned
entry into TS 3.7.C.1, Secondary Containment.
Description: On June 20, 2017, Door 58, credited as one of two doors required to maintain
secondary containment integrity, failed to automatically latch closed and remained partially
open for at least one minute. After the door latch failed, Door 85, the other credited door for
maintaining containment integrity, was opened upon egress of a security officer. The security
officer reported that both doors were open at the same time. One minute prior, station
personnel exited both Door 85 and Door 58 without identifying this condition and did not
ensure Door 58 latched closed as required. This resulted in a loss of secondary containment
integrity and an unplanned entry into TS 3.7.C.1, Secondary Containment.
The inspectors reviewed Entergy Procedure 1.3.135, Section 5.0.3, which states, Station
personnel shall ensure doors are closed and properly latched after each entrance/egress.
This is accomplished by physically challenging the door to check that it is properly closed and
latched.
As part of the corrective action process, Entergy identified a training gap existed regarding
Procedure 1.3.135, Control of Doors, in that the requirement to verify that doors are properly
closed and latched was not understood by all site personnel. There was also a longstanding
work order to repair the latch on Door 58; however, the monthly check of the doors in the
plant was completed on June 15, 2018, and did not identify any discrepancies with Door 58
performance at that time. The inspectors reviewed the causal evaluation and agreed with the
cause determination.
Corrective Actions: The latch for Door 58 was repaired and associated training documents
were updated to include the requirements for confirming that doors are closed per Procedure
1.3.135.
Corrective Action Reference: CR-PNP-2017-6380
Performance Assessment:
Performance Deficiency: Pilgrim Procedure 1.3.135, Section 5.0.3 states, in part, Station
personnel shall ensure doors are closed and properly latched after each entrance/egress.
However, station personnel exited Doors 58 and 85 without ensuring the doors were properly
latched, which resulted in the loss of secondary containment integrity. The inspectors
determined that Entergys failure to implement and execute Procedure 1.3.135 for securing
doors was a performance deficiency. This performance deficiency was reasonably within the
licensees ability to foresee and correct and should have been prevented.
Screening: This finding was more than minor in accordance with Inspection Manual Chapter 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated January 1,
2018, because the performance deficiency is associated with the configuration control
attribute of the Barrier Integrity cornerstone and adversely affects the cornerstone objective to
provide reasonable assurance that the physical design barrier, containment, could protect the
public from radionuclide releases caused by accidents or events. Specifically, the loss of
secondary containment existed for at least one minute due to both doors being open. This is
also similar to Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues,
Example 2.e. Specifically, Procedure 1.3.135 was not implemented, and it was later
determined that secondary containment Door 58 had not met its design function.
Significance: The inspectors assessed significance of this condition using Inspection Manual
Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings,
and Inspection Manual Chapter 0609, Appendix A, Exhibit 3, Barrier Integrity Screening
Questions, Part C. Inspectors determined the finding to be Green because the finding only
represents a degradation of the radiological barrier function provided for the auxiliary building.
Cross-Cutting Aspect: This finding, in accordance with Inspection Manual Chapter 0310,
Aspects within the Cross-Cutting Areas, dated December 4, 2014, has a cross-cutting
aspect in the area of Human Performance - Training, in that Entergy failed to provide
adequate training to staff to ensure knowledge of site-wide expectations, policies, and
procedures. Specifically, Entergy determined that staff were unaware of the requirement to
ensure closure and latching of doors as specified in Procedure 1.3.135. (H.9)
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
The disposition of this finding closes Licensee Event Report 2017-011-00.
480V Bus B6 Auto Transfer Function Degraded Due to Time Delay Relay Failure
Cornerstone Severity Cross-Cutting Aspect Report
Section
Not Applicable Severity Level IV Not Applicable 71153(3)
NCV 05000293/2018002-03 Follow-up of
Closed Events and
Notices of
Enforcement
Discretion
The inspectors identified a Severity Level IV NCV of TS 3.5.A.2 because a component of the
low pressure coolant injection system was inoperable between May 12, 2015, and
May 3, 2017, during which time, on numerous occasions, core spray systems were also not
operable. Specifically, a relay used to transfer the power feed for the low pressure coolant
injection valves to the backup source in the event of a degraded voltage condition failed
during testing. As a result, under certain conditions, the transfer would not have automatically
occurred. This condition existed through the operating cycle, during which time the core
spray pumps were also inoperable when removed from service for scheduled maintenance.
Description: Power to the low pressure coolant injection valves is supplied by the 480V Bus
B6, which is, in turn, normally powered by Bus B1. The 27A-B1X/TDDO relay is used as part
of the transfer of Bus B6 to the backup power source (Bus B2) in the event of loss of power or
degraded voltage on Bus B1. Specifically, the relay (an Agastat Model E7022/PB004)
energizes on detection of a degraded voltage condition and introduces a delay in the transfer
to the backup bus in case the degraded condition clears before the transfer occurs. The relay
uses a pneumatic time delay mechanism that has an adjustable range of 0.5 to 5 seconds,
and was set for a 1.25 second delay.
On May 3, 2017, during Pilgrim Refueling Outage 21, Entergy performed Pilgrim Procedure,
480V Bus B6 Automatic Transfer Test, IV, Degraded Voltage and Timing Relays Calibration
and Annunciator Verification. Entergy identified that the 27A-B1X/TDDO relay energized
upon the degraded signal, but de-energized again after 0.03 seconds rather than after the
1.25 second time delay. With the relay dropping out almost instantaneously, if a degraded
voltage condition occurred and recovered, the Bus transfer could have not been completed,
resulting in the inoperability of low pressure coolant injection.
Entergy concluded that this condition existed during the operating cycle that began after the
relay was installed in May 2015, until the discovery on May 3, 2017. This issue constituted a
violation of TS Limiting Condition for Operation 3.5.A.2, Core Spray and Low Pressure
Coolant Injection Systems, because core spray systems were, at times, inoperable for
preventive maintenance but all components of the low pressure coolant injection system were
not operable. This issue was reported to the NRC in Licensee Event Report 05000293/2017-
008-00, dated June 30, 2017, and supplemented by Licensee Event Report 05000293/2017-
008-01, dated November 2, 2017.
Entergy sent the relay to a vendor laboratory (Altran Technologies) for failure analysis that
included examinations, testing, and disassembly. The vendor observed the same time-delay
failure in the relay, and concluded that it was due to an unspecified defect that caused the
spring in the time delay mechanism to latch in an intermediate position between normal and
energized. This prevented the pneumatic plunger from fully engaging, reducing the amount
of air retained in the delay chamber. The reduced amount of air would quickly bleed out,
resulting in the shortened time delay. The vendor did not identify a specific defect or its
cause. The vendor did not identify evidence of damage to the relay from handling or over-
heating, or any signs of degradation or foreign material. Therefore, the cause was
inconclusive.
The relay had been installed in May 2015 after the previously-installed component failed. The
relay that failed in 2015 had been installed for 14 years, and the cause of that failure was not
determined because Entergy did not retain the part for analysis. The NRC identified
Entergys failure to perform a causal analysis for the failed relay in 2015 to be a violation of
CFR Part 50, Appendix B, Criterion XVI, Corrective Actions. The Green finding and NCV
was documented in NRC Inspection Report 05000293/2015004, dated February 11, 2016.
For this 2017 failure, the inspectors reviewed the maintenance work order documentation
from installation of the relay in 2015. The inspectors noted that the relay was bench tested
and calibrated with a noted time delay of 1.25 seconds prior to installation. The relay was
also tested using the 3.M.3-27 procedure after it was installed, and was noted to have tested
sat. The inspectors also noted that, when purchasing the relay in 2000, the licensee
required that the vendor subject it to a 5000 cycle burn in. The inspectors also considered
that the relay had been in storage for 15 years, and had been installed in a mild environment,
in a normally de-energized state. Apart from the 2015 failure (which involved the relay failing
to energize at all), the inspectors did not identify previous similar failures at Pilgrim. Also, a
review of industry and vendor operating experience did not reveal any similar failures of the
pneumatic timing mechanism for this model relay.
Corrective Actions: Immediate corrective action was taken to replace the relay and verify its
calibration through functional testing. As a result of its root cause analysis, Entergy
developed a long-term corrective action to replace this relay with one that is not subject to
failures of the pneumatic timing mechanism. Entergys extent-of-condition review identified
additional relays of similar design installed in the plant. Entergy developed a long-term
corrective action to similarly replace a subset of these relays (the failure of which could result
in a loss of safety function) with the new style.
Corrective Action Reference: CR-PNP-2017-4768
Performance Assessment:
The inspectors determined that the failure of the 27A-B1X/TDDO relay was not within
Entergys ability to foresee and prevent. As a result, no performance deficiency was
identified. Therefore, this violation will not be considered in the assessment process or the
NRCs Action Matrix.
Enforcement:
Violation: TS 3.5.A.2, Core Spray and Low Pressure Coolant Injection Systems, requires
that during runs, startup, and hot shutdown modes, with one of the core spray systems
inoperable, restoration of the inoperable core spray system to operable status within 7 days
and maintain all active components of the low pressure coolant injection system and the
diesel generators operable. Otherwise, be in at least cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, on occasions between May 12, 2015, and May 3, 2017, one core
spray system was inoperable while an active component of the low pressure coolant injection
system was not maintained operable and Entergy did not place Pilgrim in at least cold
shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Specifically, an unspecified defect existed in the relay used to
transfer power feed for the low pressure coolant injection valves to the backup source in the
event of a degraded voltage condition. As a result, under certain conditions, the transfer
would not have automatically occurred. This condition existed through the operating cycle,
during which time the core spray systems were also individually declared inoperable when
removed from service for scheduled maintenance.
Severity/Significance: This issue is considered within the traditional enforcement process
because there was no performance deficiency associated with the violation of NRC
requirements and the Reactor Oversight Programs significant determination process does
not specifically consider violations without performance deficiencies in its assessment of
licensee performance. Therefore, it is necessary to address this violation using traditional
enforcement to adequately deter non-compliance. The NRC Enforcement Policy, Section
2.2.1 states, in part, that, whenever possible, the NRC uses risk information in assessing the
safety significance of violations. The inspectors evaluated the issue using Inspection Manual
Chapter 0609.04, Initial Characterization of Finding, and Inspection Manual Chapter 0609,
Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined
that the issue required a detailed risk evaluation because the defect in the 27A-B1X/TDDO
relay resulted in a potential loss of the residual heat removal low pressure injection function.
A Region I senior reactor analyst completed the detailed risk evaluation and estimated the
increase in core damage frequency associated with this issue to be 2.27 E-9 per year. The
dominant core damage sequence was a large break loss of coolant accident with a failure of
residual heat removal low pressure injection valves to open and failure of core spray. This
corresponds to very low risk significance (Green). To perform the detailed risk evaluation, an
NRC senior reactor analyst used the Systems Analysis Programs for Hands-On Evaluation,
Revision 8.1.6, Standardized Plant Analysis Risk Model, Version 8.50 for Pilgrim. Based on
the safety significance insights, the inspectors determined that the issue is of very low safety
significance and concluded that the violation would be best characterized as Severity Level
IV.
Disposition: The violation is being treated as a NCV consistent with Section 2.3.2 of the
The disposition of this violation closes Licensee Event Reports 05000293/2017-008-00 and
2017-008-01.
Minor Violation 71153
This violation of minor significance was identified by the licensee and has been entered into
the licensees corrective action program and is being treated as a minor violation, consistent
with the NRC Enforcement Policy.
Minor Violation: On June 22, 2015, Entergy submitted a licensee event report in accordance
with 10 CFR 50.73 that contained information that was not complete or accurate in all material
respects, contrary to the requirements in 10 CFR 50.9. Specifically, the licensee submitted
Licensee Event Report 2015-004-00 to communicate the failure during testing of time delay
Agastat relay 27A-B1X/TDDO intended to provide under-voltage protection for 480V
emergency bus B6 by transferring power from bus B1 to bus B2. In the licensee event report,
Entergy incorrectly documented that due to the failure, bus B6 would have continued to
receive power from bus B1 with degraded voltage. Upon identifying the issue, on March 8,
2016, Entergy submitted a revised licensee event report with the correct information.
Screening: Violations involving the submittal of inaccurate or incomplete information are
evaluated under Traditional Enforcement because they impact the NRCs regulatory process.
Accordingly, the inspectors evaluated this issue against the example violations in Section 6.9
of the NRC Enforcement Policy. The inspectors concluded that the violation is of minor safety
significance because the inaccurate information did not change the NRCs review of the
licensee event report and would not have altered the significance of the resulting violation.
Enforcement: 10 CFR 50.9 requires that information provided to the Commission by a
licensee shall be complete and accurate in all material respects. Contrary to the above, on
June 22, 2015, Entergy provided information to the Commission that was not complete and
accurate in all material respects. In the licensee event report, the licensee documented that
due to the failure, bus B6 would have continued to receive power from bus B1 with degraded
voltage. However, bus B6 would actually have tripped from bus B1 and lost power
completely. This information was material to the NRC because the NRC requires timely and
accurate reporting of information related to events in order to evaluate the potential safety
significance and required NRC response.
Entergy identified the inaccuracy and entered the issue into its corrective action program [CR-
PNP-2015-9762]. On March 8, 2016, Entergy submitted a revision to the licensee event
report (2015-004-01) that corrected the report. This failure to comply with 10 CFR 50.9
constitutes a minor violation that is not subject to enforcement action in accordance with the
NRCs Enforcement Policy.
The disposition of this violation closes Licensee Event Report 05000293/2015-004-01.
Licensee Identified Non-Cited Violation 71153
This violation of very low safety significance was identified by the licensee and has been
entered into the licensees corrective action program and is being treated as a NCV,
consistent with Section 2.3.2 of the Enforcement Policy.
Violation: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings,
requires, in part, that activities affecting quality shall be prescribed by documented
instructions appropriate to the circumstances and shall be accomplished in accordance with
the instructions.
Contrary to the above, from January 1994 to June 2017, Entergy modified site surveillance
procedure 8.M.3-18, Standby Gas Treatment System Exhaust Fan Logic Test and
Instrument Calibration, without prescribing adequate documented instructions for the
condition caused by the testing. Specifically, Entergy failed to identify that the procedurally
prescribed lineup of the standby gas treatment system resulted in secondary containment
being inoperable due to the large opening introduced into the system.
Significance/Severity: The inspectors evaluated this finding using Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and Inspection Manual Chapter 0609,
Appendix A, Exhibit 3, Barrier Integrity Screening Questions. The inspectors determined
that the finding was of very low safety significance.
Corrective Action Reference: CR-PNP-2017-11714
The disposition of this violation closes Licensee Event Reports 05000293/2017-013-00 and
05000293/2017-013-01.
Licensee Identified Non-Cited Violation 71153
This violation of very low safety significance was identified by the licensee and has been
entered into the licensees corrective action program and is being treated as a NCV,
consistent with Section 2.3.2 of the Enforcement Policy.
Violation: 10 CFR 50.72(b)(3)(v)(C) requires licensees to a notify the NRC within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
any event or condition that at the time of discovery could have prevented the fulfillment of the
safety function of structures or systems that are needed to control the release of radioactive
material. Contrary to the above, Entergy did not make a required notification pursuant to
CFR 50.72(b)(3)(v)(C). Specifically, on June 20, 2017, secondary containment was
declared inoperable due to simultaneous opening of both airlock doors, and Entergy did not
make the required notification until June 22, 2017.
Significance/Severity: This violation is being treated under the NRCs traditional enforcement
process, for impeding the regulatory process, specifically Entergy did not make a required
notification, as outlined in Inspection Manual Chapter 0612, Appendix B. The Reactor
Oversight Processs significance determination process does not specifically consider the
regulatory process impact in its assessment of licensee performance. Therefore, it is
necessary to address this violation which impedes the NRCs ability to regulate using
traditional enforcement to adequately deter non-compliance. The severity of this violation
was determined to be Severity Level IV, as outlined in Example 9 from Section 6.9.d. of the
Corrective Action References: CR-PNP-2017-06380 and CR-PNP-2017-07015
The disposition of this finding closes Licensee Event Report 2017-011-00.
EXIT MEETINGS AND DEBRIEFS
Inspectors verified no proprietary information was retained or documented in this report.
On July 24, 2018, the inspectors presented the quarterly resident inspector inspection
results to Mr. Bruce Chenard, Acting General Manager of Plant Operations, and other
members of the Entergy staff.
DOCUMENTS REVIEWED
Procedures
EN-OP-115, Conduct of Operations
Procedures
EN-DC-205, Maintenance Rule Monitoring, Revision 5
Procedures
EN-WM-104, On-line Risk Assessment, Revision 16
Procedures
EN-OP-104, Operability Determination Process, Revision 16
Procedures
EN- DC-115, Engineering Change Process, Revision 25
EN- DC-136, Temporary Modifications, Revision 17
Procedures
EN-RP-101, Access Control for Radiologically Controlled Areas, Revision 14
EN-RP-204, Special Monitoring Requirements, Revision 11
Condition Reports (*initiated in response to inspection)
2017-09417 2018-01292 2018-03680 2018-03681 2018-03727 2018-03752
2018-03969
Radiation Work Permits
2018060 2018064 2018082
71152
Procedures
EN-OM-123, Fatigue Management Program, Revision 13
Condition Reports (*initiated in response to inspection)
2016-08289 2017-01082 2017-07946 2018-03313 2018-03632* 2018-03647*
2018-03746* 2018-03755* 2018-04145*
Miscellaneous
LO-PNPLO-2017-003, Fatigue Management Program Self-Assessment dated 1/30/17
LO-PNPLO-2018-008, Fatigue Management Program Self-Assessment dated 1/30/18
NEI 06-11, Managing Personnel Fatigue at Nuclear Power Reactor Sites, Revision 1
NRC Regulatory Guide 5.73, Fatigue Management For Nuclear Power Plant Personnel dated
March 2
Worker Time Records and PQ&S Records for Selected Maintenance Staff for the Period
2/24/17 to 4/14/18