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05000293/FIN-2018002-0330 June 2018 23:59:59PilgrimNRC identified480V Bus B6 Auto Transfer Function Degraded Due to Time Delay Relay FailureThe 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.
05000293/FIN-2017002-0730 June 2017 23:59:59PilgrimNRC identifiedUntimely 10 CFR 50.72 Notification of a Secondary Containment System Functional FailureAn NRC-identified SL IV NCV of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, was identified because both trains of the SBGTS were made inoperable during surveillance testing, and the condition was not reported to the NRC within eight hours of the occurrence, as required by 10 CFR 50.72(b)(3)(v), Event or Condition that Could Have Prevented Fulfillment of a Safety Function. Specifically, on April 5, 2017, while performing TS SR 4.7.C, trains A and B of the SBGTS were made inoperable leading to the inoperability of the Secondary Containment System (SCS). As a corrective action, Entergy personnel performed a causal evaluation. This issue was entered into the CAP as CR 2017-7446. The inspectors evaluated this performance deficiency in accordance with the traditional enforcement process because the issue impacted the regulatory process, in that a condition that could have prevented a safety function was not reported to the NRC within the required timeframe, thereby delaying the NRCs opportunity to review the matter. Using Example 6.9.d.9 from the NRC Enforcement Policy (the failure of a licensee to make a report as required by 10 CFR 50.72 or 10 CFR 50.73), the inspectors determined that the violation was a SL IV violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation, inspectors did not assign a cross-cutting aspect, in accordance with IMC 0612, Appendix B.
05000293/FIN-2017406-0131 March 2017 23:59:59PilgrimNRC identifiedSecurity
05000293/FIN-2016011-0731 March 2017 23:59:59PilgrimNRC identifiedFailure to Report Condition Prohibited by Technical Specifications and a Safety System Functional FailureThe NRC team identified a Severity Level IV non-cited violation of 10 CFR 50.73, Licensee Event Report System, associated with Entergys failure to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria. Specifically, on September 28, 2016, Entergy identified the A emergency diesel generator was inoperable. The NRC team determined that the condition was prohibited by technical specifications and the inoperability of the A emergency diesel generator existed for a period of time longer than allowed by Technical Specification 3.5.F, Core and Containment Cooling Systems. This was also reportable as a safety system functional failure. Entergy entered this issue into the corrective action program as CR-PNP-2016-09552. Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, the NRC team evaluated the performance deficiency using traditional enforcement. The violation was evaluated using Section 2.3.11 of the NRC Enforcement Policy, because the failure to submit a required licensee event report may impact the ability of the NRC to perform its regulatory oversight function. In accordance with Section 6.9.d, Example 9, of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV non-cited violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation, the NRC team did not assign a cross-cutting aspect to this violation, in accordance with IMC 0612, Appendix B.
05000293/FIN-2017001-0431 March 2017 23:59:59PilgrimNRC identifiedFailure to Submit a Required 50.72 NotificationSeverity Level lV. The inspectors identified a Severity Level IV NCV of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, because a TS required shutdown was not reported to the NRC within four hours of the occurrence, as required by 10 CFR 50.72(b)(2)(i). Specifically, on December 16, 2016, PNPS initiated a shutdown, as required by TS, as a result of the discovery of leakage associated with main steam isolation valves (MSIVs) 2C and 2D, leadi ng to the required isolation of the C and D main steam lines. Entergy entered the issue into the CAP as CR 2017-3723. Inspectors determined the issue had the potential to affect the NRCs ability to perform its regulatory function, therefore, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy (the failure of a licensee to make a report as required by 10 CFR 50.72 or 10 CFR 50.73), the inspectors determined that the violation was a Severity Level IV violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B
05000293/FIN-2015002-0530 June 2015 23:59:59PilgrimNRC identifiedFailure to Submit an LERThe inspectors identified a Severity Level IV NCV because Entergy personnel did not provide a written report to the NRC within 60 days after discovery of the event as required by 10 CFR 50.73(a)(2)(i)(B) for a condition which was prohibited by TS 3.5.E, Automatic Depressurization System (ADS). Specifically, on January 27, 2015, Pilgrim experienced a loss of offsite power and reactor scram during a winter storm. While operators performed a reactor cooldown with manual operation of safety relief valves (SRVs), the 3C SRV twice failed to open upon demand by the operations crew. Entergy staff initiated CR-PNP-2015-0561 to document SRV 3Cs failure to open, and the valve was immediately declared inoperable. The inspectors determined that the improper operation of SRV 3C was reportable in accordance with 10 CFR 50.73(a)(2)(i)(B). Entergy has captured this issue in CR-2015-6191. The inspectors determined that Entergys failure to submit an event notification in accordance with 10 CFR 50.73 within the required time was a performance deficiency that was reasonably within Entergys ability to forsee and correct, and should have been prevented. Because the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the Enforcement Policy, the inspectors determined that the violation was a Severity Level IV (a failure of a licensee to make a report required by 10 CFR 50.72 or 10 CFR 50.73) violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.
05000293/FIN-2015007-0731 March 2015 23:59:59PilgrimNRC identifiedFailure to Report a Major Loss of Emergency Assessment CapabilityAn NRC-identified SL IV NCV of 10 CFR Part 50.72(b)(3)(xiii) was identified when Entergy failed to make a required event notification within eight hours for a major loss of assessment capability. Specifically, an unplanned loss occurred of all EAL instrumentation associated with Sea Water Bay level that resulted in an inability to evaluate all EALs for an abnormal water level condition. Entergy entered the issue into the CAP as CR-PNP-2015-00949. Compliance was restored on February 5, 2015, when Entergy reported the major loss of assessment capability under Event Notification (EN) 50790. The inspectors determined that Entergys failure to submit an event notification in accordance with 10 CFR 50.72 within the required time was a performance deficiency that was reasonably within Entergys ability to foresee and correct, and should have been prevented. Since the failure to submit a required event report impacts the regulatory process, the violation was evaluated using Section 2.2.4 of the NRCs Enforcement Policy, dated July 9, 2013, instead of the SDP. Using the example listed in Section 6.9.d.9, A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73, the issue was evaluated and determined to be a SL IV violation. The inspectors reviewed the condition for reactor oversight process significance. Because this NRC-identified violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, the inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612.
05000293/FIN-2014005-0131 December 2014 23:59:59PilgrimNRC identifiedModification to the Spent Fuel Pool Cask Area without Prior NRC ApprovalSeverity Level lV. The inspectors identified a Severity Level lV NCV of Title 10 of the Cod of Federal Regulations (10 CFR) 50.59 in that Entergy did not obtain a license amendment prior to implementing a change to the plant that required a change to technical specification (TS). Specifically, Entergy removed the energy absorbing pad described in TS 4.3.4.b, Design Features, and Updated Final Safety Analysis Report (UFSAR) section 10.3.6, Consequences of a Dropped Fuel Cask, without receiving prior NRC approval. Entergy submitted a License Amendment Request (LAR) supplement to the NRC on September 11, 2014, to remove the energy absorbing pad language from TS, and performed an extent of condition review on previous engineering changes and prohibited placing a cask in the spent fuel pool (SFP) until receiving NRC approval for a change to TS 4.3.4.b. The inspectors determined that Entergy did not perform an adequate 10 CFR 50.59 evaluation and obtain a license amendment prior to removing the SFP energy absorbing pad. The inspectors determined this was a performance deficiency that was within Entergys ability to foresee and correct and should have been prevented. Because the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using the Enforcement Manual, the inspectors determined that the violation was a Severity Level IV (a 10 CFR 50.59 violation that resulted in conditions that required NRC approval before implementation) violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.
05000293/FIN-2014003-0330 June 2014 23:59:59PilgrimNRC identifiedFailure to Follow Licensed Operator Medical Requirements(Open/Closed) NCV 05000293/2014003-003: NRC Letter, dated February 26, 2014 (ML1405A584), documented an NRC Office of Investigation review to determine whether a contract medical assistant deliberately failed to conduct required tactile and/or olfactory testing during annual physical examinations of three licensed operators on January 10, 2013 (NRC Investigation Report Number 1-2013-010). The NRC concluded that the medical assistants actions caused Entergy to violate NRC requirements in 10 CFR 55.27 and 10 CFR 55.9. This is being treated as a Severity Level IV NCV. In order to facilitate entering this issue into the NRCs Plant Issues Matrix and assessment process, this issue is identified as NCV 05000293/2014003-03, Failure to Follow Licensed Operator Medical Requirements
05000293/FIN-2011005-0331 December 2011 23:59:59PilgrimNRC identifiedEntergy did not Notify the NRC within 30 days of discovering changes in Medical ConditionsThe inspectors identified an AV of 10 CFR 50.74, Notification of Change in Operator or Senior Operator Status. Specifically, Entergy did not notify the NRC within 30 days of discovering a change in medical condition for two licensed operators. Subsequently, Entergy submitted notifications for both operators on November 10, 2011 and entered the issue into their corrective action program (CR-PNP-2011-04554). The inspectors determined that Entergy\\\'s failure to notify the NRC within 30 days of discovering the change in medical condition for two licensed operators was a performance deficiency that was within Entergy\\\'s ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC\\\'s ability to perform its regulatory function because if a licensed operator has a change in medical condition, the NRC may need to perform a review for consideration of a licensing action. Specifically, Entergy had not notified the NRC within 30 days of learning of a change in medical condition for two licensed operators for which a license condition was required. The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, lssue Screening. No associated ROP finding was identified and no crosscutting aspect was assigned. This issue constitutes an apparent violation in accordance with the NRC\\\'s Enforcement Policy, and its final significance will be dispositioned in separate future correspondence.
05000293/FIN-2011005-0431 December 2011 23:59:59PilgrimNRC identifiedEntergy Incorrectly Credited Operators Proficiency Watch-Standing Experience and the Operators subsequently stood watchThe inspectors identified a Severity Level lV NCV of 10 CFR 55.53 (e) and (f), Conditions of Licenses, because Entergy incorrectly credited two individuals for proficiency watch-standing experience and then these operators subsequently stood watch without meeting the minimum proficiency requirements necessary to maintain an active license. Entergy implemented immediate corrective action that included discontinuing the practice of crediting the emergency core cooling system (ECCS) and Extra Balance of Plant (BOP) positions for proficiency. Entergy entered this issue into their corrective action program (CR-PNP-201 1-04649). The inspectors determined that Entergy incorrectly credited two individuals for proficiency watch-standing experience and then these operators subsequently stood watch in the control room. This error constitutes a performance deficiency that was within Entergy\\\'s ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC\\\'s ability to perform its regulatory function because if a licensed operator fails to meet the conditions of their license, the NRC may need to perform a review for consideration of a licensing action, and if the information regarding an individual\\\'s qualifications is not accurately presented, the NRC could potentially make an incorrect licensing decision based on the inaccurate information. Specifically, Entergy did not ensure that two reactor operator (RO) licensed individuals maintained their RO licenses in an active status in the 2nd quarter 2011, prior to standing RO watches in the 3rd quarter 201 1 which violated a license condition as specified in 10 CFR 55.53 (e) and (f). The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, lssue Screening. No associated ROP finding was identified and no cross-cutting aspect was assigned. This issue is similar to violation example 6.4.c.1(c) in the NRC Enforcement Policy for a Severity Level lll violation because it involves noncompliance with a condition stated on an individual\\\'s license. However, since there were no adverse impacts to nuclear safety, the NRC has determined that this issue constitutes a Severity Level lV NCV in accordance with the NRC\\\'s Enforcement Policy.
05000293/FIN-2009005-0131 December 2009 23:59:59PilgrimNRC identifiedIncomplete licensed operator medical examinationsA Severity level lV violation (VIO) of 10 CFR 50.9, Completeness and Accuracy of Information, was identified due to the submittal of inaccurate medical information for licensed operators. The submittals to the NRC were inaccurate because they certified that the operators had been medically examined and had met all medical qualifications, when in fact, olfactory testing to detect odor of products of combustion had not been performed. The facility has completed corrective actions to develop and administer an appropriate test. All licensed operators passed this new test, and no new license conditions were required. The licensee\'s medical physician failed to adequately test all licensed operators (both initial and renewal licensees) in accordance with 10 CFR 55.21 and 55.33 with respect to ANSI/ANS-3.4 1983. The licensee submitted medical information for its licensed operators and applicants that was incomplete and incorrect in its assessment of the medical condition and general health of its licensed operators and initial applicants. The licensee\'s failure to provide complete and accurate information to the NRC, which could have resulted in an incorrect licensing action, is a performance deficiency because the licensee is expected to comply with 10 CFR 50.9, and because it was within the licensee\'s ability to foresee and prevent. Because violations of 10 CFR 50.9 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the Traditional Enforcement process. The applicability of crosscutting aspects related to the performance deficiency of this finding will be determined after NRC review of Entergy\'s response to the Notice of Violation.