IR 05000003/2020001
| ML20343A167 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/08/2020 |
| From: | Anthony Dimitriadis Decommissioning Branch I |
| To: | Vitale A Entergy Nuclear Operations |
| References | |
| IR 2020001, IR 2020013 | |
| Download: ML20343A167 (15) | |
Text
December 8, 2020
SUBJECT:
ENTERGY NUCLEAR OPERATIONS, INC., INDIAN POINT NUCLEAR GENERATING STATION UNITS 1 AND 2 - NRC INSPECTION REPORT NO.
05000003/2020001 AND 05000247/2020013
Dear Mr. Vitale:
On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the permanently shutdown Indian Point Nuclear Energy Center, Units 1 and 2. A combination of on-site and remote inspection activities were performed over this period. Some inspection activities (in-office reviews) were conducted remotely as a consequence of the COVID-19 public health emergency (PHE) during this inspection period. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and the conditions of your license. The inspection consisted of observations by the inspector, interviews with personnel, and a review of procedures and records. The results of the inspection were discussed with you and other members of your staff on October 29, 2020 and are described in the enclosed inspection report. No findings of safety significance were identified.
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's Website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). No reply to this letter is required. Please contact Katherine Warner (610) 337-5389 if you have any questions regarding this matter.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Nuclear Materials Safety
cc w/encl: Distribution via ListServ
Enclosure: Inspection Report Nos.
05000003/2020001 and 05000247/2020013
SUMMARY
Entergy Nuclear Operations, Inc.
Indian Point Energy Center, Units 1 and 2 NRC Inspection Report Nos. 05000003/2020001 and 05000247/2020013
An announced decommissioning inspection was completed at Indian Point Energy Center, Units 1 and 2 on September 30, 2020. A combination of on-site and remote inspection activities were performed over this period. Certain inspection activities (in-office reviews) were conducted remotely as a consequence of the COVID-19 public health emergency (PHE) during this inspection period.
The inspection included a review of organization and management at the site, design changes and modifications, maintenance and surveillance, self-assessments, audits, and corrective actions, spent fuel safety, effluent and environmental monitoring, radioactive waste management and transportation of radioactive materials, and decommissioning performance and status.
The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. The U.S. Nuclear Regulatory Commissions (NRC's) program for overseeing the safe operation of a shut-down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program."
Based on the results of this inspection, no findings of safety significance were identified.
REPORT DETAILS
1.0 Background
Indian Point Unit -1 (IP-1) is a pressurized water reactor that was granted a 40-year Operating License in 1962 and was permanently shut down in 1974. Pursuant to the June 19, 1980 Commission Order Revoking Authority to Operate Facility and the Decommissioning Plan for Indian Point Unit No. 1, approved by the NRC in an Order, dated January 31, 1996, the reactor remains in a defueled status.
Indian Point Unit 2 (IP-2) is a pressurized water reactor that commenced operations in 1974.
On February 8, 2017, Entergy Nuclear Operations, Inc. (Entergy) notified the NRC of its intent to permanently cease power operations at IP-2 by April 30, 2020 subject to operating extensions through, but not beyond 2024 (Agencywide Documents and Access Management System (ADAMS) Accession Number: ML17044A004). On May 12, 2020, Entergy certified cessation of power operations and the permanent removal of fuel from the IP-2 reactor vessel (ADAMS Accession Number: ML20133J902). On May 13, 2020, the NRC notified Indian Point that the Operating Reactor Assessment Program had ceased and that implementation of the Decommissioning Power Reactor Inspection Program at IP-2 would begin on May 13, 2020 (ADAMS Accession Number: ML20134H943).
IP-1 and IP-2 are physically contiguous and share certain systems, such as the integrated liquid waste system, the air handling system, and facilities, such as the chemistry and health physics laboratories. IP-1 also contains radioactive waste processing facilities that provide waste processing services for both units. Radiological effluent limits are met on an overall site basis and specific operating limits and surveillance requirements for effluent monitoring instrumentation, including stack noble gas monitoring, are discussed in the Offsite Dose Calculation Manual (ODCM).
IP-1 is currently in the SAFSTOR, Co-Located with Operational Unit, No Fuel in the Spent Fuel Pool Phase and IP-2 is currently in the Post Operation Transition Phase of decommissioning as described in IMC 2561. The NRC's program for overseeing the safe operation of a shut-down nuclear power reactor is described in IMC 2561. Completion of certain core inspection procedures listed in IMC 2561, Appendix A, were completed via use of samples associated with IP 71111.01, Adverse Weather Preparations that the resident inspectors performed as part of the Reactor Oversight Process. Additionally, certain inspection procedures associated with IP 71124.01, Radiological Hazard Assessment and Exposure Controls were completed in place of IP 83750, Occupational Radiation Exposure and contributed to the completion of IP 62801, Maintenance and Surveillance at Permanently Shutdown Reactors. No issues were identified during these inspection activities.
2.0 Unit 1 Safe Storage (SAFSTOR) Performance and Status Review
a. Inspection Scope
[Inspection Procedures (IPs) [37801, 40801, 83750]
A routine announced on-site safety inspection was conducted on September 21 - 24, 2020 at IP-1. The inspection consisted of observations by the inspectors, interviews with Entergy personnel, a review of procedures and records, and plant walk-downs. The inspectors reviewed the safe storage (SAFSTOR) program as outlined in the Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TS), and ODCM. The inspectors reviewed SAFSTOR activities, including site operations, engineering, maintenance, plant support activities, management oversight, and the corrective action program (CAP). The inspectors also assessed the material condition of the IP-1 facilities during plant tours of the containment annulus, containment building, and fuel handling building, nuclear services building, and chemistry services building.
The inspectors reviewed quality assurance (QA) audit and CAP documents associated with IP-1 to determine if issues were being appropriately identified, assessed and reviewed; and that corrective actions were being appropriately implemented.
Inspection for Unit 1 under IPs 36801, 71801, 84750, and 86750 are described in their respective sections below.
b. Observations and Findings
The inspectors noted that while organizational responsibilities for IP-1 are shared across multiple groups within the Indian Point Energy Center (IPEC) organization, the ownership of Unit 1 has been centralized to the Director of Decommissioning. The inspectors discussed the IP-1 support functions performed by various organizational groups including operations, radiation protection, engineering, and work control with representatives from the respective groups and determined that activities were effectively coordinated between the various technical groups to maintain IP-1s SAFSTOR condition.
The inspectors confirmed that the staff effectively implemented the SAFSTOR program. The inspectors verified that the staff conducted the maintenance and surveillance program for systems and components in accordance with the TS requirements and established procedures. The inspectors evaluated the results of Entergys IP-1 2019 structural engineering inspection that included the Containment Building and determined that there were some areas that showed some signs of deterioration, but no areas required immediate action.
The inspectors determined that Entergy effectively entered concerns into the CAP for prioritization and evaluated them commensurate with their safety significance. Generally, Entergy effectively addressed identified issues, implemented corrective actions, and tracked them to closure.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
3.0 Unit 1 Safe Storage (SAFSTOR) and Unit 2 Post-Operation Transition Performance and Status Review
3.1 Organization, Management, and Cost Controls at Permanently Shutdown Reactors (IP 36801) and Decommissioning Performance and Status Reviews at Permanently Shutdown Plants (IP 71801)
a. Inspection Scope
The inspectors performed an on-site inspection on September 21 - 24, 2020. The inspectors reviewed procedures and processes to evaluate IPECs ability to resolve employee safety concerns, disseminate safety information and effectively resolve identified problems. The inspectors conducted document reviews, attended management and personnel meetings, and interviewed plant personnel to determine if regulatory requirements were properly implemented with respect to the site organization, staffing and staff qualifications. The inspectors also met with IPEC management and discussed staffing levels and the current maintenance workload. The inspectors also reviewed the backlog of maintenance work to assess the age and prioritization of the items.
The inspection consisted of observations by the inspectors, interviews with IPEC personnel, a review of procedures and records, and plant walk-downs.
a. Observations and Findings
The inspectors verified that management oversight was adequate for the Post-Operation Transition phase of decommissioning for Unit 2 and SAFSTOR phase for Unit 1 and that the decommissioning organization and changes to the operating unit organizations responsibilities was appropriately implemented upon Unit 2s cessation of operations. The inspectors discussed the planned Phase 1 organization to be implemented after the planned Unit 3 shutdown scheduled for April 2021. The inspectors noted that the Phase 1 organization contained all of the major groups necessary for Post-Operation Transition and that IPEC plans to implement a training plan to close any qualification gaps prior to the reorganization.
The inspectors observed a license transition meeting between Holtec, Comprehensive Decommissioning International, LLC (CDI), and Entergy personnel. The inspectors noted that transition planning is ongoing and includes lessons learned from transition implementation performed at Pilgrim and Oyster Creek.
The inspectors noted that major IP-2 activities include tagging out unnecessary systems using abandonment tags to transition the site to a SAFSTOR status. This will continue to be an inspection focus during the next inspection period.
The inspectors determined that the maintenance backlog had been reviewed by site management on a regular basis and the safety significance appropriately assessed.
b. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
3.3 Self-Assessment, Auditing, and Corrective Actions at Permanently Shutdown Reactors (IP 40801)
a. Inspection Scope
The inspectors performed a continuous inspection of applicable activities during the inspection period. The inspectors reviewed documents and interviewed IPEC personnel to verify IPEC management performed audits and self-assessments, and ensured issues were identified and corrected in accordance with the sites corrective action program (CAP).
The inspectors reviewed a representative selection of CAP documents to determine if a sufficiently low threshold for problem identification existed, follow-up evaluations were of sufficient quality, and IPEC assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue.
b. Observations and Findings
The inspector determined that issues were being identified and entered into the CAP and evaluated commensurate with their safety significance.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
3.6 Spent Fuel Pool Safety at Permanently Shutdown Reactors (IP 60801)
a. Inspection Scope
The inspector reviewed Entergys programs for the safe wet storage of spent fuel.
The inspector interviewed certified fuel handlers (CFHs) to verify SFP system instrumentation, alarms and leakage detection monitoring is adequate to assure the safe storage of spent fuel. The inspector interviewed employees and reviewed SFP chemistry sample analysis that Entergy had performed between June 1, 2020 and August 20, 2020 in order to verify chemistry parameters were within the limits of Entergys license commitments. Further walk downs and activities to result in completion of this inspection procedure will be done in the next inspection period.
b. Observations and Findings
The inspectors determined that Entergy was safely storing spent fuel in wet storage. The inspectors verified that the neutron-absorbing materials present in the SFP are being adequately managed and maintained, and SFP chemistry and cleanliness controls had been adequately implemented. The inspectors verified surveillance requirements for water level, area radiation and temperature of the SFP were adequate as well as alarm/detection capability and that procedures provided guidance to restore SFP water level if required.
The inspectors also verified training programs were adequate the CFH rounds were adequate to satisfy the associated technical specification requirements for the SFP.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
3.8 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750)
a. Inspection Scope
The inspectors performed an on-site inspection on July 20 - 23, 2020 with follow-up on-site activities conducted September 21 - 25, 2020. The inspection consisted of observations by the inspectors, interviews with Entergy personnel, a review of reports and records, and site walk-downs.
The inspectors reviewed activities and documentation associated with radioactive effluent control and site radiological environmental monitoring program (REMP) to determine the effectiveness of site radiological programs. The inspectors reviewed radioactive gaseous and liquid effluent release permits, licensee audits, the fourth quarter 2019 long-term groundwater monitoring report, the annual radioactive effluent release report, and the annual radiological environmental operating report. The inspectors toured radwaste facilities to determine if gaseous, liquid, and solid radwaste were adequately stored in the engineered storage tanks or areas, as appropriate. The inspectors toured selected environmental monitoring stations to determine the adequacy of location.
b. Observations and Findings
The inspectors verified that effluent releases to the environment were being properly controlled, monitored, and quantified as required by NRC regulations. The inspectors verified that the long-term groundwater monitoring report, the annual radioactive effluent release report, and the annual radiological environmental operating report demonstrated that calculated doses were below regulatory dose criteria listed in 10 CFR 50, Appendix I.
The inspectors did not identify any major issues during a tour of selected environmental monitoring stations. However the inspectors questioned the placement of one of the environmental monitoring stations that may not to be in conformance with site procedures due to overgrown vegetation. The condition was entered into the site corrective action program under CR-IP2-2020-01622.
The inspectors reviewed records associated with 10 CFR 50.75(g) and assessed its adequacy. The inspectors noted apparent gaps of time where spills or leaks were not entered into the file. This condition was entered into the site corrective action program under CR-IP2-2020-01843 and CR-HQN-2020-01862. The inspectors will follow up in future inspections to verify that Entergy appropriately entered items into their 50.75(g) file and that Entergy performed extent of condition reviews per their corrective action process.
c. Conclusions
Based on the results of this inspection, no violations of safety significance were identified.
3.9 Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)
a. Inspection Scope
The inspectors performed an on-site inspection on July 20 - 23, 2020 with follow up on-site activities conducted September 21 - 25, 2020. The inspection consisted of observations by the inspectors, interviews with Entergy personnel, a review of reports and records, and site walk-downs.
The inspectors reviewed activities and documentation associated with the possession, processing, storage, and shipment of licensed radioactive material. The inspectors reviewed documentation and observed surveys of a shipment of waste associated with IP-
1. The inspectors toured the 70 and 108 of Unit 1 containment where legacy waste
containers were being stored.
b. Observations and Findings
The inspectors noted that during this inspection period, Entergy conducted a shipping campaign for legacy Unit 1 mixed waste that had been stored in containment. This included 7 shipments to Energy Solutions in Bear Creek, Tennessee and ultimately to Clive, Utah. The inspectors walked down the storage areas and observed surveys of a shipment being prepared for transportation. The inspectors noted that the storage areas were appropriately posted and controlled. During the inspection conducted in September 2020, the inspectors reviewed shipping paperwork and discussed the project with the appropriate site personnel. The inspectors verified that the processing, packaging, storage, and shipment of license radioactive material was performed as required by NRC regulations. No potential public health and safety concerns were identified as a result of transportation activities.
The inspectors conducted walkdowns and tours of various facilities and storage areas, including the Unit 1 containment during this inspection period. The inspectors did not note any leakage or major degradation of containers.
The inspectors noted that no major modifications of the radwaste processing systems were planned at the time of this inspection.
c. Conclusions
Based on the results of this inspection, no violations of safety significance were identified.
4.0
Exit Meeting Summary
On October 29, 2020, the inspectors presented the inspection results to Mr. Richard Burroni, Director, Decommissioning, and other members of Entergys organization. No proprietary information was retained by inspectors or documented in this report.
SUPPLEMENTARY INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
- R. Burroni, Director, Special Projects
- R. Walpole, Director - Regulatory Assurance and Performance Improvement
- S. Stevens, Radiation Protection Manager
- M. Mirzai, Regulatory Assurance Manager
- N. Azevedo, Supervisor Code Programs
- C. Belcher, I&C Technician
- T. Buchal, Senior Reactor Operator
- C. Burpoe, Senior Emergency Planning Technician
- T. Carbonara, I&C Technician
- G. Dahl, Regulatory Assurance
- G. Delfini, Reactor Engineering Supervisor
- J. Doroski, Senior Health Physics/Chemistry Specialist
- K. Elliott, Fire Protection Engineer
- A. Eng, Regulatory Assurance
- C. English, Project Manager (Contractor)
- L. Fitzsimmons, Radiation Protection Technician (BHI Contractor)
- L. Frink, Radiation Protection Supervisor
- W. OBrien, Radiation Protection Supervisor
- S. Malinski, Civil/Structural Engineer
- G. Martin, Reactor Operator
- T. McKee, Operations Training
- R. Passalugo, Radiation Protection Supervisor
- G. Primrose, Senior Reactor Operator
- J. Ruch, Civil Engineer
- F. Spagnuolo, Manager-Outage
- M. Trott, Reactor Engineer
- K. Woznick, Manager of Finance Business Partners
ITEMS OPEN, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
Procedures
EN-DC-324-DP, Decommissioning Plant Preventive Maintenance Program, Revision 6
EN-CY-102, Laboratory Analytical Quality Control, Revision 14
EN-CY-111 Attachment 7, Spill/Leak Groundwater Sample Results Reporting Flowchart, Revision
010
EN-CY-113, Response to Contaminated Spills/Leaks, Revision 9
EN-LI-113-01, Updated Final Safety Analysis Report Change Process, Revision 5
EN-OP-102, Protective and Caution Tagging, Revision 024
EN-RW-105, Process Control Program, Revision 5
0-RP-ADM-109, Radiation Protection Periodic Task Scheduling, Revision 9
0-NF-203, Internal Transfer of Fuel Assemblies and Inserts, Revision 25
2-CY-2625, General Plant System Specifications and Frequencies, Revision 30
2-NF-220, Fuel Assembly Categorization, Revision 2
2-AOP-FH-1, Fuel Damage or Loss of SFP Level, Revision 9
2-AOP-SF-1, Loss of Sent Fuel Pit Cooling, Revision 7
2-SOP-4.3.1, Spent Fuel Pit Colling, Revision 33
2-ARP-SGF, Auxiliary Coolant System, Revision 38
2-ARP-SBF-2, CCR Safeguards, Revision 33
Audits and Reports
2019 Annual Radioactive Effluent Release Report Indian Point Nuclear Generating Unit Nos 1, 2,
and 3, dated April 28, 2020
2019 Annual Radiological Environmental Operating Report Indian Point Unit Nos. 1, 2, and 3,
dated April 28, 2020
CNRO2020-00002, Decommissioning Funding Status Report per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) - Entergy Nuclear Operations, Inc, March 26, 2020
IP-RPT-17-00066, Criticality Safety Analysis for the Indian Point Unit 2 Spent Fuel Pool with No
Absorber Panel Credit, Revision 0
Unit 2 Liquid Release Permit Report, dated June 30, 2020
Unit 2 Liquid Release Permit Report, dated September 3, 2020
Unit 2 Radioactive Gaseous Release Permit Report, dated June 26, 2020
IP-CS-19-00060, Indian Point Unit 1 SAFSTOR 2019 Structural Inspection, May, 26, 2020
IP3LO-2018-00078, Pre-NRC Inspection Assessment 2019-02 and Periodic RP Assessment
Requirements, dated February 12, 2019
IP3LO-2019-00117, RP Program Annual Review for 2019 per 10 CFR 20.1101(c) and EN-RP-102;
and Pre-NRC Inspection Assessment for NRC IP 71151 (Sections 02.15 and 03.09), dated
March 11, 2020
LO-IP3LO-2019-0130, Pre-NRC Self-Assessment: Radioactive Environmental Monitoring Program
- 71124.07, dated April 10, 2020
Quarter Four 2018 IPEC Quarterly Long-Term Groundwater Monitoring Report, dated June 19,
20
Condition Reports
CR-IP2-2019-04377
CR-IP2-2019-04376
CR-IP2-2019-04169
CR-IP2-2019-04125
CR-IP3-2019-03546
CR-IP2-2019-05099
CR-IP2-2019-05119
CR-IP2-2019-05122
CR-IP2-2020-00258
CR-IP2-2020-00721
CR-IP2-2020-01415
CR-IP2-2020-01387
CR-IP2-2020-01328
CR-IP3-2020-01200
CR-IP2-2020-01163
CR-IP2-2020-01183
CR-IP2-2020-01745
CR-HQN-2020-01862
Miscellaneous
IPEC 10 CFR 50.75(g) file
EN-RP-113 Attachment 9.1, 10 CFR 50.75(g) Leak/Spill Record, dated February 26, 2020
EN-RP-113 Attachment 9.1, 10 CFR 50.75(g) Leak/Spill Record, dated March 30, 2019
IP1 IP2 OX Backlog, September 24, 2020
IP-1 TS (Appendix A to Provisional Operating License No. DPR-5)
Indian Point Energy Center Phase 1 Organization Chart, September, 2020
Indian Point Energy Center Units 1, 2, and 3 Offsite Dose Calculation Manual, Revision 4
Indian Point Nuclear Generating Unit No. 2 - Permanently Defueled Technical Specifications
Indian Point Unit 1 Safety Analysis Report
Indian Point Unit 2 Defueled Safety Analysis Report
Radiological Surveys for IP-1 Various Areas, January 2020, February 2020, May 2020
EN-RW-102, Radioactive Shipment Documentation Checklist, Shipment 20-073, Dated January
16, 2020
EN-RW-102, Radioactive Shipment Documentation Checklist, Shipment 20-073, Dated June 16,
20
EN-RW-102, Radioactive Shipment Documentation Checklist, Shipment 20-088, Dated August 11,
20
EN-RW-102, Radioactive Shipment Documentation Checklist, Shipment 20-093, Dated August 12,
20
Mixed Waste Annual Inspection, dated October 15, 2019
Radioactive Material Shipment Truck Survey Form, Tractor 4007; Trailer Number CKB 16024,
dated July 21, 2020
U1 Radiological Restricted Area Seal Verification, November 11, 2019
Unit 1 HRA/LHRA/VHRA Boundary Verifications, Revision 14
Work Orders
2549475
2657814
2761727
2388378
2540531
2692551
2753776
2808997
2867701
Work Orders (Contd)
59906103
2918779
2928659
2928740
2932653
2936519
Drawings
206912
2781
21-2720
21-F-2577
A206074
LIST OF ACRONYMS USED
Corrective Action Program
Entergy
Entergy Nuclear Operations, Inc.
IMC
Inspection Manual Chapter
IP
Inspection Procedure
Indian Point Energy Center
IP-1
Indian Point Unit 1
IP-2
Indian Point Unit 2
NRC
U.S. Nuclear Regulatory Commission
Offsite Dose Calculation Manual
Quality Assurance
Radiological Environmental Monitoring Program
SAFSTOR
Safe Storage
TS
Technical Specification