IR 05000247/2008502

IR 05000247-08-502 and 05000286-08-502; on 12/01/2008 - 12/04/2008; Indian Point Units 2 and 3; Exercise Evaluation; Emergency Action Level and Emergency Plan Changes; Emergency Preparedness Performance Indicators

ML090140087
Person / Time
Site:	Indian Point
Issue date:	01/14/2009
From:	James Trapp Plant Support Branch 1
To:	Joseph E Pollock Entergy Nuclear Operations
References
IR-08-502
Download: ML090140087 (12)

Text

ary 14, 2009

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NOS.

05000247/2008502 AND 05000286/2008502

Dear Mr. Pollock:

On December 4, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the December 3, 2008, evaluated emergency preparedness exercise at your Indian Point Energy Center. The enclosed inspection report documents the inspection results, which were discussed on December 4, 2008, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

James A. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos. 50-247, 50-286 License No. DPR-26, DPR-64 Enclosure: NRC Inspection Reports 05000247/2008502 and 05000286/208502

Mr. Joseph

SUMMARY OF FINDINGS

IR 05000247/2008502 and 05000286/2008502; 12/01/2008-12/04/2008; Indian Point Units 2 and 3; Exercise Evaluation; Emergency Action Level and Emergency Plan Changes;

Emergency Preparedness Performance Indicators.

This was an announced inspection conducted by four region-based inspectors and two headquarters-based inspectors. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Findings None.

ii

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Emergency Preparedness (EP)

1EP1 Exercise Evaluation (71114.01 - 1 Sample)

a. Inspection Scope

Prior to the December 3, 2008, emergency preparedness exercise, the NRC inspectors conducted an in-office review of the exercise objectives and scenario, which Entergy had submitted to the NRC, to determine if the exercise would test major elements of the Indian Point Energy Center Emergency Plan as required by 10 CFR 50.47(b)(14). This overall exercise inspection activity represented the completion of one sample on a biennial cycle.

The exercise evaluation consisted of the following review and assessment:

• The adequacy of Entergys performance in the biennial full-participation exercise regarding the implementation of the risk-significant planning standards (RSPS)described in 10 CFR 50.47(b)(4), (5), (9), and (10), which are: emergency classification; offsite notification; radiological assessment; and protective action recommendations, respectively.

• The overall adequacy of Entergys emergency response facilities with regard to NUREG-0696, Functional Criteria for Emergency Response Facilities, and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Technical Support Center (TSC), Emergency Operations Facility (EOF),and Joint Information Center (JIC).

• A review of other performance areas, such as: the Indian Point emergency response organizations (EROs) recognition of abnormal plant conditions; command and control; intra- and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies; staffing and procedure adequacy; and the overall implementation of the emergency plan and its implementing procedures.

• A review of past performance issues from the last NRC Indian Point exercise inspection report and Entergys EP drill reports, to determine the effectiveness of licensee corrective actions as demonstrated during the December 3, 2008, exercise and to ensure compliance with 10 CFR 50.47(b)(14).

• The licensees post-exercise critiques, to evaluate Entergys self-assessment of its ERO performance during the December 3, 2008, exercise and to ensure compliance with 10 CFR 50, Appendix E, Section IV.F.2.g.

The inspectors reviewed the documents listed in the attachment to this report.

b. Findings

No findings of significance were identified.

1EP4 Emergency Action Level (EAL) and Emergency Plan Changes (71114.04 - 1 Sample)

a. Inspection Scope

Since the last NRC inspection of this program area, Revision 08-01 of the Indian Point Energy Center Emergency Plan was implemented by Entergy. Entergy had determined that in accordance with 10 CFR 50.54(q), any change made to the Plan had not resulted in any decrease in effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50. The inspectors reviewed all EAL changes made since September 2007, and conducted a sampling review of other Emergency Plan changes, including changes to lower-tier emergency plan implementing procedures, to evaluate for any potential decreases in effectiveness of the Emergency Plan. However, this review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes.

Therefore, these changes remain subject to future NRC inspection in their entirety.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification (71151 - 3 Samples)

a. Inspection Scope

The inspectors reviewed data for the Indian Point EP PIs, which are:

(1) Drill and Exercise Performance (DEP);

(2) Emergency Response Organization (ERO) Drill Participation; and,

(3) Alert and Notification System (ANS) Reliability. The last EP inspection at Indian Point was conducted in the third quarter of 2007, so the inspectors reviewed supporting documentation from EP drills and tests from the third calendar quarter of 2007 through the third quarter of 2008, to verify the accuracy of the reported PI data. The review of these PIs was conducted in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 5.

Additionally, the inspector performed NRC Temporary Instruction (TI) 2515/175, Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review, ensured the completeness of the licensees completed Attachment 1 from the TI, and forwarded that data to NRC Headquarters.

This inspection activity represented the completion of three samples on an annual cycle.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

On December 4, 2008, the inspectors presented the results of this inspection to Mr. J.

Pollock, the Site Vice President, and other members of the Entergy staff. No proprietary information was provided to the inspectors during this inspection.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Pollock, Site Vice President

B. Sullivan, Indian Point Emergency Planning Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None