UNITED STATES

N UCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

KING OF PRUSSTA. PA 19406-1415

May 13, 2011

Mr. Robert G. Smith

Site Vice President

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station

600 Rocky Hill Road

Plymouth, MA 02360-5508

PILGRIM NUCLEAR POWER STATION - NRC TEMPORARY INSTRUCTION

2515t183 TNSPECT|ON REPORT 05000293/201 1009

Dear Mr.

On April 15,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

your Pilgrim Nuclear Power Station (PNPS), using Temporary Instruction 2515/183, "Followup

to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection report

documents the inspection results which were discussed on April 1 5,2011, with you and other

members of your staff.

The objective of this inspection was to promptly assess the capabilities of Pilgrim to respond to

extraordinary consequences similar to those that have recently occurred at the Japanese

Fukushima Daiichi Nuclear Station. The results from this inspection, along with the results from

this inspection performed at other operating commercial nuclear plants in the United States will

be used to evaluate the United States nuclear industry's readiness to safely respond to similar

events. These results will also help the NRC to determine if additional regulatory actions are

warranted.

All of the potential issues and observations identified by this inspection are contained in this

report. The NRC's Reactor Oversight Process willfurther evaluate any issues to determine if

they are regulatory findings or violations. Any resulting findings or violations will be documented

by the NRC in a separate report. You are not required to respond to this letter.
R. Smith

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be made available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRC's

Agencyruide Documents Access and Management System (ADAMS), accessible from the NRC

Web site at http://www.nrc.qovireadinq-rmiadams.html (the Public Electronic Reading Room).

Sincerely,

b[^"t -r^-

Lawrence T. Doerflein, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No.: 50-293

License No.: DPR-35

Enclosure: Inspection Report No. 05000293/201 1009

cc dencl: Distribution via ListServ
R. Smith 2

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be made available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRC's

Agency,vide Documents Access and Management System (ADAMS), accessible from the NRC

Web site at http:/iwww.nrc.qov/readinq-rm/adams.html(the Public Electronic Reading Room).

Sincerely,

/RN

Lawrence T. Doerflein, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No.: 50-293

License No.: DPR-35

Enclosure: Inspection Report No. 05000293/2011009

cc Mencl: Distribution via ListServ

ADAMS PACKAGE: ML11 1300168 ADAMS DOCUMENT ACGESSION: ML1 11310008

SUNSI Review Complete: LTD (Reviewer's Initials)

DOCUMENT NAME: G:\DRS\T|-183 Inspection Reports\PlL Tl-183 lR 2011009.docx

After declaring this document "An Official Agency Record" it will be released to the Public.

b receive a copy of this document, indicate in the box: 'C" = without attachmenVenclosure = CoDv with attachmenue 'tclosure "N'= No cop\

OFFICE RI/DRS RI/DRS RI/DRP RI/DRS

NAME J. Richmond/JR WCookWAC DJackson/DJ LDoerflein/LTD

DATE 5111111 5t11t11 5112111 5t13t11

OFFICIAL RECORD COPY
R. Smith

Distribution Mencl:

W. Dean, RA

D. Lew, DRA

D. Roberts, DRP

J. Clifford, DRP

C. Miller, DRS

P. Wilson, DRS

S. Bush-Goddard, Rl OEDO

T. Kobetz, NRR, DIRS

D. Jackson, DRP

T. Setzer, DRP

D. Dodson, DRP

M. Schneider, DRP, SRI

B. Smith, DRP, Rl

S. Campbell, Resident OA

D. Bearde, DRS

RidsNrrPMPilg rim Resource

RidsNrrDorlLPLl -1 Resource

ROPReports.Resource

3
Docket No.:

License No.:

Report No.:

Licensee:

Facility:

Location:

lnspection Period:

Inspectors:

Approved By:

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

50-293

DPR-35

05000293/201 1009

Entergy Nuclear Operations, lnc.

Pilgrim Nuclear Power Station (PNPS)

600 Rocky Hill Road

Plymouth, MA 02360

April 11 - 15,2011

J. Richmond, Senior Reactor Inspector, Division of Reactor Safety

Lawrence T. Doerflein, Chief

Engineering Branch 2

Division of Reactor Safety

Enclosure
SUMMARY OF FINDINGS

lR 0500029312011009; 0411112011 - 0411512011; Pilgrim Nuclear Power Station; Temporary

lnstruction 25151183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.

This report covers an announced Temporary lnstruction (Tl) inspection. The inspection was

conducted by a senior region based inspector. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor

Oversight Process," Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the Tl is to provide a broad overview of the industry's preparedness for events that

may exceed the current design basis for a plant. The focus of the Tl was on (1) assessing the

licensee's capability to mitigate consequences from large fires or explosions on site,

(2) assessing the licensee's capability to mitigate station blackout (SBO) conditions,

(3) assessing the licensee's capability to mitigate internal and external flooding events

accounted for by the station's design, and (4) assessing the thoroughness of the licensee's

walkdowns and inspections of important equipment needed to mitigate fire and flood events to

identify the potential that the equipment's function could be lost during seismic events possible

for the site. lf necessary, a more specific followup inspection will be performed at a later date.

INSPECTION RESULTS

All of the potential issues and observations identified by this inspection are contained in this

report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if

they are regulatory findings or violations. Any resulting findings or violations will be documented

by the NRC in a separate report.

Enclosure
03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events, typically bounded by

security threats, committed to as part of NRC Security Order Section 8.5.b issued February 25, 2002, and severe accident

management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection

Procedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. lf lP 71111.05T was recently

performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of

inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but

not be limited to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect equipment.

Verify through test or

inspection that

equipment is available

and functional. Active

equipment shall be

tested and passive

equipment shall be

walked down and

inspected. lt is not

expected that

permanently installed

equipment that is tested

under an existing

regulatory testing

program be retested.

This review should be

done for a reasonable

sample of mitigating

strateg ies/eq uipment.

Entergy performed equipment inspections, inventory of necessary tools and materials, and an

operational test of a portable diesel powered pump to verify B.S.b equipment readiness and

ensure that the equipment was available and functional. Entergy walked down equipment storage

and staging locations to verify the adequacy of the required inventories. In addition, implementing

procedure walkdowns were performed to verify that necessary equipment, tools, and materials

specified for use within the procedures were available.

Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed

test results, discussed actions, reviewed records, etc.).

The inspector evaluated the adequacy of installed and portable equipment staged explicitly for

implementation of the mitigation strategies. The types of equipment examined included: interior

fire water supply piping and hose stations; portable pump and associated suction and discharge

hoses, adapters, and tools; portable DC power supplies; portable radios and communications

devices; and equipment lockers and associated tools. The inspector's review included field

verification and inventory checks of standby and staged equipment, and compatibility of the

portable equipment with installed systems. In addition, the inspector evaluated the staging and

storage locations of B.5.b related equipment to ensure the survivability and availability of

equipment. The inspector also reviewed test results of the portable diesel powered pump. The

inspector observed a walk-throuqh demonstration of selected mitioatino strateoies to

Enclosure
independently evaluate the adequacy and functionality of the available equipment, and

interviewed licensed and non-licensed operators to further assess equipment functionality.

Discuss general results including corrective actions by licensee.

Entergy did not identify any deficiencies of significance as part of their equipment checks. Entergy

identified several minor issues which they entered into their correction action program.

One minor deficiency was identified by the inspector. The portable DC power supplies consisted

of a 12 volt lead acid battery and a DC to DC converter. Based on a previous NRC observation,

CR-PNP-2O1 1-00341 documented a corrective action to create a preventive maintenance task for

the battery. During this inspection, Entergy added an additional action to evaluate the addition of

a functional test for the battery and DC to DC converter. The inspector determined this was a

minor issue because there was a reasonable expectation of functionality for the portable DC

power supplies based on battery voltage checks performed during the inspection period and preinstallation checks performed on the DC to DC converters. The inspector verified these checks by

direct observation and interview. Entergy entered this issue into their corrective action program as

CA-24 to CR-PN P -201 I -00341 .

Based on the results of the reviews, walkdowns, and interviews described above, the inspector

concluded that the required equipment was available and functional.

Licensee Action Describe the licensee's actions to verify that procedures are in place and can be executed (e.g.

walkdowns, demonstrations, tests, etc.)

Enclosure
b. Verify through

walkdowns or

demonstration that

procedures to implement

the strategies associated

with 8.5.b and 10 CFR

50.54(hh) are in place

and are executable.

Licensees may choose

not to connect or

operate permanently

installed equipment

during this verification.

This review should be

done for a reasonable

sample of mitigating

strateg ies/eq uipment.

Entergy validated procedure adequacy by using operators or engineers to perform 8.5.b

procedure reviews and walkdown demonstrations of selected 8.5.b procedures. In addition,

selected procedures were actually performed to verify both equipment readiness and procedure

adequacy, such as equipment inventory and inspection, emergency alarms and radios testing, and

portable pump functional testing. The B.5.b and severe accident management guideline (SAMG)

procedures were verified current and staged in the appropriate locations.

Describe inspector actions and the sample strategies reviewed. Assess whether procedures were

in place and could be used as intended.

The inspector independently evaluated selected Entergy B.5.b mitigating strategy implementing

procedures to verify procedure adequacy. ln addition, the inspector reviewed the interface or

transition between the Emergency Operating Procedures (EOPs), off-normal procedures, and the

mitigating strategy procedures. The inspector performed walkdowns with licensed and nonlicensed operators and other Entergy staff to assess: the adequacy and completeness of the

procedures; familiarity of operators with the procedure objectives and specific guidance; staging

and compatibility of equipment; and the practicality of the operator actions prescribed by the

procedures, consistent with the postulated scenarios.

As a result of the NRC inspection, one finding of very low safety significance was identified,

involving procedural deficiencies that challenged a spent fuel pool cooling strategy. Entergy

entered this issue into their corrective action program as CR-PNP-2011-01505 and

CR-PNP 2011-01075 CA-24. Details on this finding will be documented in Pilgrim Inspection

Report 05000293/201 101 1 .

Discuss general results including corrective actions by licensee.

Entergy did not identify any deficiencies of significance as part of their check to verify that

procedures were in-place and executable. Entergy identified several minor issues which they

entered into their correction action proqram.

Enclosure
Entergy immediately evaluated the NRC identified finding, briefed operations personnel, and,

based on the updated briefing information, verified the strategies could be reasonably

implemented within the credited time limits. The inspector reviewed Entergy's immediate and

proposed actions, including their assessment and prioritization, and concluded they were

reasonable.

Based on the results of the reviews and walkdowns described above, with the exception of one

finding to be documented in a separate report, the inspector determined that the procedures to

implement the strategies associated with 8.5.b and 10 CFR 50.54(hh) were in place and were

executable.

Licensee Action Describe the licensee's actions and conclusions regarding training and qualifications of operators

and support staff.

Verify the training and

qualifications of

operators and the

support staff needed to

implement the

procedures and work

instructions are current

for activities related to

Security Order Section

B.5.b and severe

accident management

guidelines as required by

10 cFR 50.54 (hh).

Entergy audited training records for operations, security, fire fighters, engineering, and emergency

response organization (ERO) personnel to verify that all staff members within a designated group

were current with their initial and requalification training requirements. ln addition, Entergy also

verified that there was a sufficient number of trained personnel on-site and on each operating shift

to implement the severe accident management guidelines. Entergy also verified that off-site local

fire department members were current in their training.

Describe inspector actions and the sample strategies reviewed to assess training and

qualifications of operators and support staff.

The inspector interviewed selected licensed and non-licensed operators, and non-operations plant

staff to evaluate the adequacy of their training and the completeness of Entergy's training audit. In

addition, the inspector interviewed a licensed operator simulator instructor regarding simulator and

job performance measure training scope and schedules.

Enclosure
Discuss general results including corrective actions by licensee.

Entergy did not identify any training deficiencies of significance.

Based on the inspecto/s review of formal training, interviews, and observations of plant staff

during walkdowns of mitigating strategies in the field, the inspector concluded that the overall

B.5.b training was appropriate and consistent with industry guidelines.

Licensee Action Describe the licensee's actions and conclusions regarding applicable agreements and contracts

are in place.

d. Verify that any

applicable agreements

and contracts are in

place and are capable of

meeting the conditions

needed to mitigate the

consequences of these

events.

This review should be

done for a reasonable

sample of mitigating

strategies/eq uipment.

Entergy verified the agreements with off-site localfire departments were in place and active. In

addition, Entergy also verified that required off-site equipment was available.

For a sample of mitigating strategies involving contracts or agreements with offsite entities,

describe inspector actions to confirm agreements and contracts are in place and current (e.9.,

confirm that offsite fire assistance agreement is in place and current).

The inspector verified through interviews with plant staff that necessary agreements were in-place

and current with off-site flre departments, and that equipment which was expected to be available

to implement the mitigating strategies was, in fact, available.

Discuss general results including corrective actions by licensee.

Enclosure
Entergy did not identify any deficiencies of significance.

The inspector concluded that sufficient agreements and contracts were in place and capable of

meeting the conditions necessary to mitigate the consequences of 8.5.b events, as required by

Entergy's licensing and design basis.

Licensee Action Document the corrective action report number and briefly summarize problems noted by the

licensee that have significant potential to prevent the success of any existing mitigating strategy.

e. Review any open

corrective action

documents to assess

problems with mitigating

strategy implementation

identified by the

licensee. Assess the

impact of the problem on

the mitigating capability

and the remaining

capability that is not

impacted.

The inspector reviewed numerous corrective action documents during this inspection, which are

listed in the Attachment to this report. In addition, NRC Resident Inspectors conduct daily reviews

of newly issued condition reports. The NRC Senior Resident Inspector and the NRC Tl-183

inspector discussed whether potential deficiencies, identified within Entergy's corrective action

program, could result in a significant adverse impact to mitigating strategy implementation. In

addition, the inspector reviewed all condition reports identified by Entergy during their recent self

assessments of B.5.b mitigating strategies. The inspector evaluated Entergy's immediate

corrective actions for the associated condition reports, and concluded that the actions appeared to

be reasonable.

As discussed above in section 03.01.b, the inspector identified one finding of very low safety

significance. No other significant impacts were identified.

Enclosure
03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All

Alternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of

Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline. lt is not intended that Tl 25151120 be completely reinspected.

The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO

event.

a. Verify through

walkdowns and

inspection that all

required materials are

adequate and properly

staged, tested, and

maintained.

Entergy conducted walkdowns of the SBO diesel generator (DG), SBO control stations,

associated switchgear, and related equipment to verify the equipment was adequate and properly

staged. Entergy also reviewed associated procedures to identify any necessary temporary

equipment, and verified that such items were available and pre-staged.

Describe inspector actions to verify equipment is available and useable.

The inspector independently walked down the SBO DG, control stations, associated switchgear,

and station batteries to independently verify material conditions and equipment readiness. The

walkdowns were conducted with licensed and non-licensed operators, an electrical design

engineer, and the responsible system engineer. The inspector also interviewed operations and

engineering personnel regarding typicalfunctional test results and reviewed selected test results

to further assess equipment availability and readiness. In addition, the inspector reviewed DC

system design calculations to verify that the station battery capacity discharge test acceptance

criteria included necessary SBO loads and load durations.

Discuss general results including corrective actions by licensee.

Enclosure
Entergy did not identify any deficiencies of significance as part of their equipment checks.

One minor deficiency was identified by the inspector. Entergy had not implemented industry

standard or vendor recommendations for battery performance discharge testing on the SBO

switchgear 125 volt battery since initial installation to 2005. The inspector determined this was a

minor issue because there was a reasonable expectation of functionality for the battery because a

factory acceptance test discharge had been performed on 11122105 prior to initial installation, float

current was checked weekly, and individual cell voltages and intercell terminations were checked

quarterly. IEEE 1106-2005, "Recommended Practice for Installation, Maintenance, Testing, and

Replacement of Vented Nickel-Cadmium Batteries for Stationary Applications," recommended a

performance test discharge within the first two years of service and every five years thereafter.

The vendor service life for this battery was 20 years, and the factory acceptance test satisfied the

IEEE recommendations. Since a performance test was only a few months overdue, and in this

instance, the battery was within the first six years of a 2O year service life, and did not have any

identified degraded trends, the inspector concluded that a performance test would be reasonably

expected to pass. The inspector walked down the battery to independently verify material

condition, reviewed the results from the last four quarterly battery checks and the factory

acceptance test results, and interviewed the system engineer to assess battery performance

trends. Entergy entered this issue into their corrective action program as CR-PNP-2011-01548

and CR-PNP-2011 -01 075 CA-17 .

The inspector identified a beyond design basis and beyond licensing basis vulnerability, in that the

SBO DG cooling radiator is potentially susceptible to damage from high wind generated flying

debris. Entergy entered this issue into their corrective action program as CR-PNP-201 1-01503

and CR-PNP-2011 -01 075 CA-1 1 .

The inspector identified a beyond design basis and beyond licensing basis vulnerability, in that the

SBO DG switchgear battery was not restrained within a battery rack and was potentially

susceptible to movement during a seismic event. Entergy entered this issue into their corrective

action program as CR-PNP-2011-01551 and CR-PNP-2011-01075 CA-18.

Enclosure
Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.

Demonstrate through

walkdowns that

procedures for response

to an SBO are

executable.

Entergy performed table top demonstration reviews and walkdowns of procedures required for

response to a SBO event to verify that the procedures were executable. ln addition, Entergy also

verified that licensed operator training included appropriate training tasks for SBO activities in

initial and requalification training.

Describe inspector actions to assess whether procedures were in place and could be used as

intended.

The inspector reviewed SBO related procedures, including DC load shedding procedures, and

observed a table top demonstration of plant response to an SBO (e.9., SBO DG starting and

loading) performed by licensed operators. The inspectofs review also included licensed operator

job performance measures for local and remote start and operation of the SBO DG. In addition,

the inspector interviewed a licensed operator simulator instructor and reviewed crew critical task

time results for simulator scenarios to independently verify that the SBO DG could be started and

loaded within the design basis time of 10 minutes.

Discuss general results including corrective actions by licensee.

Entergy did not identify any deficiencies of significance.

Based on the results of the reviews, walkdowns, and interviews described above, the inspector

found the procedures for an SBO were executable.

Enclosure
03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design. Refer to lP

71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline. The

inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections

that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include

verification that accessible doors, barriers, and penetration seals are functional.

Licensee Action Describe the licensee's actions to verify the capability to mitigate existing design basis flooding

events.

a. Verify through

walkdowns and

inspection that all

required materials are

adequate and properly

staged, tested, and

maintained.

Entergy walked down and inspected accessible flood protection barriers, penetration seals, and

room or sump high level alarm instruments that were credited or relied upon to mitigate internal

and external flooding events. The walkdowns and inspections included breakwaters, jetties, and

revetments. In addition, Entergy reviewed procedures used to prepare for severe weather or

inspect plant structures post severe weather.

Describe inspector actions to verify equipment is available and useable. Assess whether

procedures were in place and could be used as intended.

The inspector walked down selected plant areas to independently assess the adequacy of flood

protection barriers. The walkdown was conducted with a structural engineer and utilized a

structural monitoring surveillance procedure table which listed flood barriers routinely inspected.

Selected plant areas included reactor building emergency core cooling system (ECCS) pump

rooms, reactor core isolation cooling (RCIC) room, and control rod drive (CRD) room; turbine

building 4kV switchgear and battery rooms; EDG rooms; intake structure, including service water

pump rooms, and diesel driven fire water pump room; and the SBO DG enclosures.

Discuss general results including corrective actions by licensee.

Enclosure
Entergy did not identify any deficiencies of significance.

The inspector identified one minor deficiency, in that piping penetrations between the torus room

and ECCS rooms, which were credited flood barriers, had not been included in Entergy's flood

barrier structural monitoring surveillances. Entergy performed an initial review which determined

that all of the pipe penetrations were equipped with water tight seal assemblies and that previous

inspection of similar seals in other plant areas had not identified any significant degraded trends.

Entergy entered this issue into their corrective action program as CR-PNP-2011-01530 and CRPNP-2011-01075 CA-20. The inspector reviewed the condition reports, and determined that

Entergy's initial responses, including their assessment and prioritization, were appropriate.

Based on the results of the reviews and walkdowns described above, the inspector concluded that

Entergy's capabilities to mitigate internal and externalflood events adequately satisfied design

basis requirements. On a sampling basis, the inspector also verified that accessible doors,

barriers, and penetration seals were functional.

03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and

flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assess

the licensee's development of any new mitigating strategies for identified vulnerabilities (e.9., entered it in to the corrective action

program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of

important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response

equipment; and developed mitigating strategies to cope with the loss of that important function. Use lP 71111.21, "Component

Design Basis lnspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the

licensee's walkdowns and inspections.

Licensee Action Describe the licensee's actions to assess the potential impact of seismic events on the availability

of equipment used in fire and flooding mitigation strategies.

Enclosure
Verify through

walkdowns that all

required materials are

adequate and properly

staged, tested, and

maintained.

Entergy identified equipment utilized or required for mitigation of fire and flood events, including

both permanent and temporary equipment, conducted walkdowns, and documented the results.

Prior to the walkdowns, guidelines were established to govern the conduct of walkdowns and

inspections. Entergy determined whether the system, structure, and component (SSC) was

seismically qualified or seismically rugged. For non-seismically rugged SSCs, Entergy evaluated

whether a mitigating strategy was needed to perform the function after a safe shutdown

earthquake.

Describe inspector actions to verify equipment is available and useable. Assess whether

procedures were in place and could be used as intended.

The inspector reviewed the scope of Entergy's walkdowns, and the results of Entergy's

inspections and assessments to evaluate the thoroughness of Entergy's actions. The inspector

walked down selected risk significant plant areas to independently assess beyond design basis

seismic vulnerabilities to equipment needed to mitigate fire and flood events. This equipment

included, but was not limited to:

. 8.5.b contingency response equipment;

o portions of the installed fire protection and suppression equipment in various plant areas;

. diesel and electric fire pumps and their controls; and

e watertight doors, roof hatches and floor plugs at the plant's intake structure.

Based on the results of the reviews and walkdowns described above, the inspector concluded that

Entergy satisfied the current licensing and design bases for B.5.b, fire protection, and flooding.

Discuss general results including corrective actions by licensee. Briefly summarize any new

mitigating strategies identified by the licensee as a result of their reviews.

Enclosure
Entergy did not identify any deficiencies of significance.

The inspector concluded Entergy's reviews were comprehensive. The inspector noted that the

majority of the flood protection SSCs were either seismically rugged or seismically qualified. In

reviewing these beyond design basis seismic interactions with fire or flood mitigation SSCs,

Entergy identified several potential enhancements that could improve fire fighting capabilities

following an earthquake. The identified seismic vulnerabilities, including storage locations and fire

headers, were entered into the corrective action program. Resolution and/or mitigating strategies

for the identified vulnerabilities were under evaluation.

Enclosure
Meetinqs

4OAO Exit Meetinq

The inspector presented the inspection results to Mr. R. Smith and other members of

Entergy management at the conclusion of the inspection on April 15,2011. The

inspectors asked Entergy whether any materials examined during the inspection should

be considered proprietary. The inspectors confirmed that any proprietary information

was returned to the licensee.

14 Enclosure
A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Enterqv Personnel

Pace, Supervisor Mechanical Design

Doody, Mechanical Design Engineer

McDonnell, Assistant Operations Manager

Macdonald, Assistant Operations Manager-Shift

Lynch, Site Licensing Manager

Noyes, Operations Manager

Bracken, Senior Reactor Operator

Fratassio, Senior Reactor Operator

Berkland, Electrical Design Engineer

Ahern, System Engineer

Burke, Fire Protection Engineer

Berne, Licensing Engineer

NRC Personnel

C. Cahill, Senior Reactor Analyst, Division of Reactor Safety

W. Cook, Senior Reactor Analyst, Division of Reactor Safety

Commonwealth of Massachusetts (Observers)

John Giarrusso, Jr., Planning and Preparedness Division Manager, Massachusetts

Suzanne Condon, Associate Commissioner, Department of Public Health, Massachusetts

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety but rather that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

03.01 Assess the licensee's capability to mitigate conditions that result from beyond

design basis events

Procedures:

2.1.26,lnventory of Alternate Shutdown and EOP Support Tools and Materials, Rev. 36

2.4.31, Reactor Basin and/or Spent Fuel Pool Draindown, Rev. 19

Attachment
A-2

2.4.52, Loss of all Fire Suppression Pumps or Loss of Redundancy in the Fire Water Supply

System, Rev.25

5.3.3, Loss of All Service Water, Rev. 26

5.3.14, Security lncidents, Rev. 39

5.3.21, Bypassing Selected Interlocks, Rev. 29

5.3.25, Primary Containment Fill, Rev. 16

5.3.26, Reactor Pressure Vessel Injection During Emergencies, Rev. 25

5.3.36, Extensive Damage Mitigation Guidelines (EDMG), Rev. 3

5.4.6, Primary Containment Venting and Purging under Emergency Conditions, Rev. 44

8.A.13, Plant Emergency Alarms and Radio Test, Rev. 20

8.8.1, Fire Pump Test, Rev. 87

EMG-100, Emergency Management Guideline, Rev. 2

Drawinqs:

M-212, Service Water System, Sh. 1, Rev. 93

M-218, Fire Protection System, Sh. 1, Rev.59

M-227, Containment Atmospheric Gontrol, Sh. 1, Rev. 59

M-241, Residual Heat Removal System, Sh. 1, Rev. 86

M-245, RCIC, Rev. E35

M-246, RCIC Turbine, Sh. 1, Rev. 32

M-293, Standby Gas Treatment System , Rev. 27

Calculations and Evaluations:

FP-53, Calculation of Mitigation Strategy, Rev. 1

M-588, Fuel Pool Decay and Heat-up Times, Rev. 1

M-907, Refueling Outage Decay Heat Evaluation, Rev. 0

Condition Reports: (. NRC identified during this inspection)

CR-PNP-2008-00361, Found Battery on Portable Battery Cart Deteriorated, 1/30/08

CR-PNP-2008-00675, Time Line for Response Needs to be Validated Formally,2127l08

CR-PNP-2O11-00869, Review Previous NRC Inspection Findings and Observations to Ensure

all lssues are Complete,2l28l11

CR-PNP-201 1-01075, Self Assessment for Japanese Reactor Damage Event, 3115111

CR-PNP-2011-01179, Correct EOP, SAG, and EMG Procedures, and EP Surveillances

Administrative Discrepancies, 3121 I 1 1

CR-PNP-2011-01199, Evaluate P-159 Pump and Diesel Driven Air Compressor Fuel

Management Strategy, 31221 1 1

CR-PNP-2011-01206, Track Various Administrative Actions to Completion,3l23ll1

CR-PNP-2011-01491, During Manual Operation of Primary Containment Venting, SGTS was

Assumed to be lsolated,4112ll1

CR-PNP-2011-01492, PM for P-159 Called out Incorrect Fuel Oil and Lube Oil Filters, 4112111

.CR-PNP-201 1-01505, NRC Inspection ldentified Enhancement Opportunities, 4113111

.CR-PNP-201 

1 -01 684, Tl P Room Mitigating Strategies Observations, 41201 1 1

CR-PNP-2008-00661, Revise Procedure 5.3.36 to lnclude lssues ldentified by NRC, 2126108

Attachment
A-3

.CR-PNP-2011-01414, Review 5.3.36 and Evaluate Permanent and Temporary Component

Labeling, 4106111

CR-PNP-2008-00654, Revise Calculation FP-53, 2126108

CR-PNP-2010-02639, Review PM Needs for Battery Carts, 7129110

CR-PNP-2008-00663, Verify Strategy Meets Intent of NEI 06-12,2126108

CR-PNP-201 1-01313, Procedure 2.1 .26 Performed on 2-28-11 did not Document Control Room

Log Entry for Missing Gloves, 3131111

CR-PNP-2011-01415, Evaluate P-159 Fuel Makeup Strategy, 4106111

CR-PNP-201 1-01416, Evaluate P-159 Suction ltems, 4106111

.CR-PNP-201 1-01646, Review Inventory Procedure 2.1.26 of Alternate Shutdown and EOP

Support Tools and Materials, 41 191 1 1

Other:

Fuel Pool Cooling System Health Report, 4th Quarter 2010

NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, Rev. 2

NRC Tl 2515117l,Yerification of Site Specific lmplementation of B.S.b Phase 2 and 3 Mitigating

Strategies, Rev. 1

Pilgrim Facility Operating License No. DPR-35, Rev. 224

RCIC System Health Report, 1st Quarter 2011

UFSAR 10.4, Fuel Pool Cooling and Cleanup System, Rev.23

03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions

Procedures:

2.2.146, Station Blackout Diesel Generator, Rev. 41

5.3.31, Station Blackout, Rev. 14

5.3.11, Loss of Essential DC Bus D16 or D4 and D36, Rev. 43

3.M.3-25.8, A-8 Control Power Battery Quarterly Inspection, Rev. 4

3.M.3-25.10, Weekly Battery Pilot Cell and Charger Inspection, Rev. 13

5.3.12, Loss of Essential DC Bus D17 or D5 and D37, Rev. 39

2.4.16, Distribution Alignment Electrical System Malfunctions, Rev. 37

Completed Tests:

WO 05108463, 8.9.8.1 Battery Service Test Results,4l14l07

WO 05108435, 8.9.8.3 Battery Service Test Results, SlllOT

WO 52243036, 3.M.3-25.8 A-8 Control Power Battery Quarterly Inspection, 517110

WO 52258377, 3.M.3-25.8 A-8 Control Power Battery Quarterly Inspection, 814110

WO 52275979, 3.M.3-25.8 A-8 Control Power Battery Quarterly Inspection, 11l4l1O

WO 52294169, 3.M.3-25.8 A-8 Control Power Battery Quarterly Inspection, 212111

WO 52330544, 3.M.3-25.10, Weekly Battery Pilot Cell and Charger Inspection,3117l11

MR 01 124050, A-8 Battery Factory Acceptance Discharge Test, 1211105

Attachment
A-4

Drawinqs:

17322-M-SAM-13-0059-003, SBO A-8 Switchgear Wiring Diagram, Rev. E2

E-1, Electrical Distribution Single Line Diagram, Sh. 1, Rev.21

E-13,125 and 250 Vdc Relay & Meter Diagram, Rev. E80

E-17,4160 Meter and Relay Diagram, Rev. 5

Calculations and Evaluations:

00025-0042-001, Battery Load Profile, Rev. 1

TDBD-115, Station Blackout Design Basis Document, Rev. 1

Condition Reports:

CR-PNP-2Q10-04443, Review Leakage Modeling During an SBO Event, 12l2Ol1O

*CR-PNP-2011-00341 

, CA24, Evaluate PM Needs for DC-DC Converter, and Check Wire

Terminations, 4115111

CR-PNP-2011-01075, Self Assessment for Japanese Reactor Damage Event, 3115111

CR-PNP-2Q11-01326, Evaluate Susceptibility to Adverse Weather Effects on Venting Function

of EDG Fuel Storage Tanks, 3131111

*CR-PNP-2011-01503, Walkdown of SBO EDG ldentified Potential Vulnerability to High Wind

External Event, 411311 1

*CR-PNP-2011-01506, Battery Walkdown ldentified Several Terminal Connects with Signs of

Corrosion on the 250Vdc Battery D3,4113111

*CR-PNP-2011-01548, A-8 125Ydc Battery does not have Periodic Load Testing, 4115111

.CR-PNP-2Q11-01550, Civil Design Engineering Should Consider the Robustness of the SBO

Diesel Battery Stand, 4115111

*CR-PNP-201 1-01551 , Robustness of SBO Diesel Battery Stand should be Reviewed, 4115111

CR-PNP-201 1-01305, Procedure Enhancements for 5.3.31 , 5.3.36, 2.2.146, & 5.3.35.1 , 3130111

CR-PNP-2010-02268, C190 Panel Power Light Broke Socket, 6128110

CR-PNP-2011-00217, SBO DG Manual Load Test Discrepancy, 1117111

CR-PNP-2 010-02924, Protective Relay Found Out of Calibration, 81231 1 0

Other:

DC System Health Report, 4th Quarter 2O1O

IEEE 1106, Maintenance of Nickel Cadmium Batteries, 2005

JPM-290-01, Start the SBO Diesel Generator, Rev. 6

JPM-290-02, Local Operation of SBO DG during Station Blackout, Rev. 4

PDC 86-568, SBO DG lnstallation Modification, Rev. 0

SBO Diesel Generator System Health Report, 4th Quarter 2010

UFSAR 8.10, Blackout AC Power Source, Rev. 23

V-0541. SBO Diesel Generator Vendor Manual, Rev. 12

Attachment
A-5

03.03 Assess the licensee's capability to mitigate internal and external flooding events

required by station design

Procedures:

2,1.37, Coastal Storm Preparations and Actions, Rev. 28

2.1.42, Operation during Severe Weather, Rev. 10

3.M.5-3, Water Control Structures Monitoring Procedure, Rev. 2

5.2.2, High Winds (Hurricane), Rev. 31

8.C.42,Sub-compartment Barrier Control Surveillance, Rev. 22

EN-DC-150, Condition Monitoring of Maintenance Rule Structures, Rev. 1

Calculations and Evaluations:

IPEEE 5.2, Floods, Rev. 0

Condition Reports:

CR-PNP-2011-01075, Self Assessment for Japanese Reactor Damage Event, 3115111

CR-PNP-2011-01163, Revise EP-AD-601 to Reflect Current Document and Remove Reference

to Superseded Docum ents, 3121 | I 1

CR-PNP-2011-01255, Walkdown Results for Breakwaters, Jetties, and Revetments ldentified

Rock Displacements on the Jetty Tops, 3128111

CR-PNP-2011-01392, Debris Found in EDG Building Sump Floor Drain System, 415111

CR-PNP-2011-01394, Main Equipment Hatchway at RB El. 117 not Normally Closed,4l5l11

CR-PNP-2011-01530", Flood Seals (Elastomers) should be Inspected Periodically,4ll4lll

Other:

PMf D 50077725,3.M.5-3 Main Breakwater 5-Year Survey, Active

PMID 50079208, 3.M.5-3 Wind Speed Review for Breakwater Monitoring, Active

UFSAR 2.4.4, Storm Flooding Protection, Rev.25

03.04 Assess the thoroughness of the licensee's walkdowns and inspections of

important equipment needed to mitigate fire and flood events to identify the

potentiat that the equipment's function could be lost during seismic events

Procedures:

5.2.1, Earthquake, Rev. 43

Attachment
A-6

Condition Reports:

CR-PNP-201 1-01075, Self Assessment for Japanese Reactor Damage Event, 3115111

LO-WTPNP-2O11-00082 CA 55, Develop a Flooding Design Basis Document, 416111

LO-WTPNP-2O11-00082 CA 56, Analyze Equipment Drain Piping in CRD Quad to Determine it

will Remain Intact During an Earthquake,416lll

LO-WTPNP-201 1-00082 CA 54, Evaluate Procedure 2.4.54 - Not Intended to Address Loss of

Fire Protection or City Water Piping due to a Seismic Event, Evaluate, 416111

Other:

Fire Protection System Health Report, 1st Quarter 2011

ADAMS

CFR

CR

CRD

DG

ECCS

EDG

EDMG

EOP

ERO

IP

KV

NEI

P&ID

PARS

PM

PNPS

NRC

RCtC

SAMG

SBO

SBO DG

SGTS

SSC

TI

TIP

LIST OF ACRONYMS USED

[NRC]Agencywide Documents Access and Management System

Code of Federal Regulations

Condition Report

Control Rod Drive

Diesel Generator

Emergency Core Cooling System

Emergency Diesel Generator

Extensive Damage Mitigation Guidelines

Emergency Operating Procedure

Emergency Response Organization

lnspection Procedure

Kilovolt

Nuclear Energy Institute

Piping and Instrument Diagram

INRCI Publicly Available Records

Preventive Maintenance

Pilgrim Nuclear Power Station

Nuclear Regulatory Commission

Reactor Core lsolation Cooling

Severe Accident Management Guideline

Station Blackout

Station Blackout Diesel Generator

Standby Gas Treatment System

System, Structure, and Component

[NRC] Temporary lnstruction

Transverse Instrument Probe

Attachment