IR 05000247/2011005

IR 05000247-11-005, on 12/31/2011, Indian Point Unit 2, Equipment Alignment and Maintenance Effectiveness

ML12039A162
Person / Time
Site:	Indian Point
Issue date:	02/08/2012
From:	Mel Gray Reactor Projects Branch 2
To:	Ventosa J Entergy Nuclear Operations
Gray M
References
IR-11-005
Download: ML12039A162 (39)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 February 8,2012 Mr. John Ventosa Site Vice President Entergy Nuclear OPerations, lnc'

Indian Point EnergY Center 450 BroadwaY, GSB Buchanan, NY 1051 1-0249 2 NRC INTEGMTED SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT -

I NSPECTION REPORT 05000247 1201 1 005

Dear Mr. Ventosa:

(NRC) completed an on December 31 ,2011, the u.S. Nuclear Regulatory commission integrated inspection report inspection at Inoian Foint Nucrea, c"nliaiing-unit z. The encrosed on January 19'2012' with you and documents the inspection results, which *"tE Oit.ussed other members of Your staff'

your license as they relate to safety and The inspection examined activities conducted under with the conditions of your license'

compriance witn tne commission,s rutei ano regurations.and records, observed activities' and interviewed The inspectors reviewed selected pro""orr", a-nd personnel.

of very1ow safety significance (Green) and two This report documents one serf-revearing findin-g (Green;' Two of these findings were NRC-identitieO nnO-inls of u"ry tow satet-y significance a licensee-identified determined to invjvJviotations ot Hnc-ieqiirement-s.'Additionally, is listed in this report'

safety significance.,.

violation, which was determined to O" of uew fow very low safety significance,..ind-because they are entered into your However, because of the as non-cited violations corrective action ;;;;; tcApi, tn" r.rnc is treating these findings e6ticy' lf you contest any NCVs (NCVs), consisteni-viitn Section'Z.g.Z ot tne NRC Eiforcement inspection report'

in this report, you should provide t99Oont"

• itnin 30 days of the.dite *tlit

"

with the basis for your denial, to the N;J;;; Relulatory Commission, ATTN': Document Control 1; the Desk, washington, DC 20555-000r; *it .opies-to tne'negional Administrator', Region Washington'

Regulatory g"Tn:ti?n'

Director, Office of Lnforcement, UniteJ St"t". Nuclear Dc 20555-0001; and the NRC senior Resident rnspector it tnoiah point Nuclear Generating aspect as-sig1e.d to any finding in this unit 2. In addition, if you disagree with the cross-cutting with Oays oithe date of this inspection report'

report, you should provide a response *iinin iO Senior Region l, and the NRC the basis for your disagreement, to n" Clgi""alAiministrator, point Nuclear Generating Unit 2.

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

Sincerely, 4. t x2 7{-( A/6/

Mel Gray, Chief /

Reactor Projects Branch 2 Division of Reactor Projects Docket No. 50-247 License No. DPR-26

Enclosure:

lnspection Report 05000247 1201 1 005 w/Attachment: Supplementary Information

REGION I Docket No.: 50-247 License No.: DPR-26 Report No.: 050002471201 1005 Licensee: Entergy Nuclear Northeast ( Entergy)

Facility: Indian Point Nuclear Generating Unit 2 Location: 450 Broadway, GSB Buchanan, NY 1 051 1-0249 Dates: October 1,2011 through December 31,2011 lnspectors: M. Catts, Senior Resident Inspector - lndian Point 2 O. Ayegbusi, Resident Inspector - Indian Point 2 B. Bickett, Senior Project Engineer - Region I T. Fish, Senior Operations Engineer - Region I J. Furia, Senior Health Physicist - Region I S. McCarver, Project Engineer - Region I J. Noggle, Senior Health Physicist - Region I Approved By: Mel Gray, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

-

lR 0500024712011005; 10/1/1 1 12131111; Indian Point Nuclear Generating (lndian Point)

Unit 2; Equipment Alignment and Maintenance Effectiveness.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified three findings of very low safety significance (Green), two of which were NCVs. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (lMC)0609, "Significance Determination Process" (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. 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.

Cornerstone: Mitigating Systems

o

Green.

The inspectors identified a finding because Entergy procedure ENN-DC-150,

Condition Monitoring of Maintenance Rule Structures, did not have appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, since September 6, 2007, Entergy personnel did not have an adequate procedure with acceptance criteria to determine if wall penetrations were properly sealed, which resulted in water intrusion into the 480 volt room during Hurricane lrene due to degradation of two service water (SW) pipe penetrations. Entergy personnel immediately directed water to a floor drain, placed sandbags around the 480 volt switchgear, and initiated actions to develop a permanent repair to the penetration seals.

Entergy personnel entered this issue into the CAP as CR-lP2-2011-4324.

This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Also, in accordance with Inspection Manual Chapter (lMC) 0612, Power Reactor Inspection Reports, Appendix E, Minor Examples, this finding is similar to examples 3.i and 3.j. Specifically, water intrusion in the 480 volt room could impact all four trains of 480 volt switchgear. Using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," the inspectors determined this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not result in an actual loss of safety function, was not a loss of barrier function, and was not potentially risk significant for external events. The finding has a cross-cutting aspect in the area of human performance associated with the resources attribute because Entergy personnel did not have complete, accurate and up-to-date procedures and work packages, to ensure adequate inspection of flood penetration seals. H.2(c) per IMC 0310]

(Section 1R12)

.

Green.

The inspectors documented a self-revealing NCV of 10 CFR 50, Appendix B,

Criterion V, "lnstructions, Procedures, and Drawings," because Entergy personnel did not follow Entergy procedure 2-BRK-022-ELC, Westinghouse Model DB-50 Breaker Preventative Maintenance, to remove and clean the zinc dichromate plating on 480 volt DB-50 breaker inertia latches. Specifically, between July 24,2008 and October 3, 2011 ,

Entergy personnel did not follow procedure 2-BRK-022-ELC, steps 4.6.16.11 - 4.6,16.15 to remove zinc dichromate plating on the 21 service water pump (SWP) breaker inertia latch, resulting in the inoperability of the 21 SWP. Additionally, Technical Specification (TS)3.7.8.4, Service Water System, which requires that a SWP on the essential header be restored to operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, was not met. Specifically, between September 30, 2011 and October 3,2011, 21 SWP was inoperable for 76.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without the pump being returned to operable status. Entergy's corrective actions included replacing the 21 SWP breaker, performing an extent of condition inspection of the other safety-related 480 volt DB-50 breakers, human performance error reviews and re-enforcing expectations, and enhancing the procedure to provide additional guidance for breaker cleaning. Entergy personnel entered these issues into the CAP as CR-lP2-2011-4893.

This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the 21 SWP was inoperable and accrued unavailability for a period of time which could impact the service water system function to provide a heat sink for the removal of process and operating heat from safety related components during a Design Basis Accident or transient, Using IMC 0609 Attachment 4 "Phase 1 - Initial Screening and Characterization of Findings," the inspectors determined that a Phase 2 evaluation was required because the finding screened as potentially risk significant since the 21 SWP inoperability was an actual loss of safety function of a single train for greater than the allowed outage time. A Region I Senior Risk Analyst (SRA) conducted a Phase 3 analysis because the complexities with the service water line-up during the performance deficiency exposure period are not well represented in the NRC Phase 2 notebook. Based upon the conclusions of the Phase 3 analysis, the Region I SRA determined this finding was of very low safety significance (Green). The finding has a cross-cutting aspect in the area of human performance associated with the work practices attribute because Entergy personnel did not define and effectively communicate expectations regarding procedural compliance and personnelfollowing procedures. H.4(b) per IMC 0310] (Section 1R12)

Cornerstone: Barrier Integrity

o

Green.

The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion XVl,

"Corrective Action," because Entergy personnel did not promptly correct an adverse condition related to the safety-related control room ventilation fan. Specifically, between September 1, 2010 and September 27,2011, inspectors identified that Entergy personnel did not promptly implement corrective actions to revise maintenance procedures to include post maintenance belt tensioning after a break-in period which resulted in additional failures of the 21 central control room fan (CCRF) while in service. Entergy staff revised scheduled work orders to perform post-maintenance break-in checks. Entergy personnel entered this issue into the CAP as CR-lP2-2012-0625.

This finding is more than minor because it is associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity cornerstone and affects the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the untimely corrective actions resulted in additional failures and subsequent inoperability of the 21 CCRF, Using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," the finding was determined to have very low safety significance (Green) because the finding did not represent a degradation of the radiological barrier function of the control room, a degradation of the barrier function of the control room against smoke or a toxic atmosphere, an actual open pathway in the physical integrity of reactor containment and heat removal components, and the finding did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the CAP attribute because Entergy personnel did not take appropriate corrective actions to address safety issues and adverse trends specific to the 21 CCRF in a timely manner, commensurate with its safety significance and complexity. tP.1(d) per IMC 03101 (Section 1R04)

Other Findings

A violation of very low safety significance that was identified by Entergy staff was reviewed by the inspectors. Corrective actions taken or planned by Entergy staff have been entered into Entergy's CAP. This violation and corrective action tracking number are tisted in Section 4OAT of this report.

REPORT DETAILS

Summarv of Plant Status Indian Point Unit 2 began the inspection period at 100 percent power. The unit remained at or near 100 percent power for the remainder of the inspection period.

1. REACTORSAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Aliqnment

Partial Svstem Walkdowns (71111.04Q - 2 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

.

21 SWP following breaker maintenance on November 16,2011

.

Control room ventilation system (CRVS)after maintenance on the 21 CCRF on December 19,2011 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Evaluation Report (UFSAR), Technical Specifications (TSs), work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.

The inspectors also reviewed whether Entergy staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b, Findinqs

Introduction:

The inspectors identified an NCV of very low safety significance (Green) of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," because Entergy personnel did not promptly correct a condition adverse to quality associated with the safety-related CCRF. Specifically, subsequent to a September 1, 2010 21 CCRF failure, inspectors identified that Entergy personnel did not promptly implement corrective actions to revise maintenance procedures to include post maintenance belt tensioning after a break-in period which resulted in additional failures of the 21 CCRF while in service.

Description:

On June 25,2010, Entergy personnel initiated CR-lP2-2010-04290 documenting an adverse trend of fan issues including two failures of the 21 CCRF on June 13 and 14,2010, while in service. The 21 CCRF again tripped on August 14,2014 and was documented to have loose belts and slow fan speed. Each failure required entry by operators into TS 3.7.10, "Control Room Ventilation System," which requires that two CRVS trains shall be operable. With one fan out of seryice, TS 3.7.10, requires that the fan be restored to operable status within seven days. In September 2010, Entergy personnelcompleted an apparent cause evaluation (ACE) of fan failures in CR-lP2-2010-4290 and determined the cause to be a result of inadequate belt tensioning and alignment. As a result, Entergy personnel initiated corrective actions to revise fan maintenance procedure 0-FAN-401-HVA, fnspection and Repair of Heating, Ventilation, and Air Conditioning (HVAC) /Plant Ventilation Fans, and work orders to include vendor recommendations to perform belt tensioning and alignment checks after a short break-in period.

On March 1, 2011, 21 CCRF was declared inoperable after operations personnel identified it tripped due to a broken belt. Work order 268052 was initiated and completed to replace the belts and return thefan to service. On June 10,2011, during a quarterly vibrations check on the 21 CCRF, fan vibrations were determined to be above the high limit value. In addition, the fan belt was identified as making noise attributable to a possible belt alignment issue. Entergy personnel corrected the condition by replacing the belts using a two-year preventive maintenance activity originally scheduled tor 2012.

The maintenance activities for the belt replacements for the March 1,2011 and June 10,2011 issues did not include the corrective actions from the ACE to re-tension the belts. On September 1, 2011, the fan was documented as making noise due to loose belts. Entergy personnel replaced the belts and, after inspector questions regarding the increased fan failures, implemented previously identified corrective actions to re-tension the belts after a short break-in period.

The inspectors reviewed the ACE and related work orders to determine if the corrective actions taken were adequate. The inspectors determined that corrective actions initiated to revise procedures and work orders had been extended on two occasions without providing interim guidance to operations and maintenance departments for re{ensioning the belts after a break-in period. The inspectors determined this was not consistent with procedure expectations outlined in Entergy procedure EN-LI-102, Corrective Action Process, in that actions and due dates should have been selected to minimize the next potential occurrence of the problem. The inspectors determined that Entergy staff did not promptly implement corrective actions, previously identified as a result of the September 2010 CCRF failure, to correct belt issues which subsequently contributed to the increase in short-term unavailability of the 21 CCRF in March, June, and September 2011.

Analysis:

The performance deficiency associated with this finding was that Entergy personnel did not promptly correct a condition adverse to quality associated with the safety related 21 CCRF. This finding is more than minor because it is associated with the SSC and barrier performance attribute of the Barrier Integrity cornerstone and affects the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the untimely corrective actions resulted in subsequent fan failures and unavailability of the 21 CCRF, Using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," the finding was determined to have very low safety significance (Green) because the finding did not represent a degradation of the radiological barrier function of the control room, a degradation of the barrier function of the control room against smoke or a toxic atmosphere, an actual open pathway in the physical integrity of reactor containment and heat removal components, and the finding did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the CAP attribute because Entergy personnel did not take appropriate corrective actions to address safety issues and adverse trends specific to the 21 CCRF in a timely manner, commensurate with its safety significance and complexity. IP.1(d) per IMC 0310J

Enforcement:

10 CFR 50, Appendix B, Criterion XVl, "Corrective Action Program,"

requires, in part, that the licensee assure that conditions adverse to quality, such as deficiencies, deviations, defective material and equipment, and nonconformance's are promptly identified and corrected. Entergy procedure EN-LI-102, Corrective Action Process, step 5.9[2].b states in part that "corrective action due dates should be selected with consideration given toward: the next potential occurrence of the problem and should ensure the action is complete prior to the next potential occurrence of the problem, if possible; and the potential impact to plant operations while the action completion is pending," Contrary to the above, between September 1,2Q10 and September 27 ,2011, Entergy staff did not implement prompt corrective actions to address an adverse condition with the 21 CCRF, which resulted in subsequent fan failures and short-term unavailability in March 1, June 10 and September 1,2011. Entergy staff revised scheduled work orders to perform post-maintenance break-in checks. Because this finding was of very low safety significance and was entered into Entergy's CAP as CR-lP2-2012-0625, consistent with Section 2.3.2 of the Enforcement Policy, this violation is being treated as NCV 0500024712011005-01, Untimely Corrective Actions for Repeated Control Room Fan Failures.

1R05 Fire Protection

Resident Inspector Quarterlv Walkdowns (71111.05Q - 4 samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Entergy staff controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan (PFP), and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

o PFP-214 (fire zone (FZ)74A,748): Electrical Penetration Area - Fan House on November 6,2011 o PFP-215 (FZ 1A): General Floor Plan - Fan House on November 6, 2011 o PFP-218 (FZ 99A, 100A, 101A): General Floor Plan - Boric Acid Evaporator Building on November 6, 2011 r PFP-1 56 (FZ 140,240,241): General Floor Plan - Superheater Building on December 19.2Q11 b. Findinqs No findings were identified.

1R06 Flood Protection Measures- (71111.06 - 1 sample)

Annual Review of Cables Located in Underqround Bunkers/Manholes Inspection Scope The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could disable risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including manhole 24 containing safety related electrical cabling to the SWPs, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged.

The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed. Previously, manhole 21 was inspected and documented in lnspection Report 0500024712011002.

a. Findinqs No findings were identified.

1R11 Licensed Operator Requalification Proqram

.1 Quarterlv Review (71111.11Q

- 1 sample)

a. Inspection Scope

The inspectors observed licensed operator simulator training on October 20,2011, which included a simulated steam generator tube leak, a loss of offsite power leading to a station blackout, an offsite release, and the failure of select components to automatically start as required. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findinqs No findings were identified.

.2 Licensed Operator Requalification (71111.1 1B

- 1 sample)

a. Inspection Scope

On December 13, 2011, a region-based inspector conducted an in-office review of results of licensee-administered annual operating tests and comprehensive written exams for 2011. The inspection assessed whether pass rates were consistent with the guidance of IMC 0609, Appendix l, "Operator Requalification Human Performance Significance Determination Process." The inspector verified that:

o Crew pass rate was greater than 80 percent. (Pass rate was 100 percent.)

r Individual pass rate on the dynamic simulator test was greater than 80 percent.

(Pass rate was 100 percent.)

Individual pass rate on the written exam was greater than 80 percent. (Pass rate was 98 percent.)

r Individual pass rate on the job performance measures of the operating exam was greater than 80 percent, (Pass rate was 100 percent.)

.

Overall pass rate among individuals for all portions of the exam was greater than or equal to 75 percent. (Overall pass rate was 98 percent.)

b. Findinqs No findings were identified.

1 R12 Maintenance Ejectiveness (71111.12Q - 3 samples)

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on SSC performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders, and maintenance rule basis documents to ensure that Entergy staff were identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (aX2)performance criteria established by Entergy staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (aX2). Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occuned within and across maintenance rule system boundaries.

r Flood penetration seal degradation in the 480 volt switchgear room on August 28,2Q11

.

Low service water header pressure to allfive fan cooler units (FCUs) during testing on October 3,2011 o DB-50 breakers inertial latch degradation and extent of condition on October 3,2011 b. Findinqs

.1 Water Intrusion Due to Leakino Flood Penetration Seals in the 480 Volt Room Durinq

Hurricane lrene

Introduction:

The inspectors identified a finding of very low safety significance (Green)because Entergy procedure ENN-DC-150, Condition Monitoring of Maintenance Rule Structures, did not have appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, since September 6,2007, Entergy personnel did not have an adequate procedure with acceptance criteria to determine if wall penetrations were properly sealed, which resulted in water intrusion into the 480 volt room during Hurricane lrene due to degradation of two SW pipe penetrations.

Description:

On August 28, 2011, when Hurricane lrene was impacting the area around Indian Point, water intrusion was identified by Entergy staff in the 480 volt room. Water was identified coming in around two SW pipes that enter the wall of the 480 volt room from under the transformer yard. Operations personnel discovered the water intrusion and also identified that the drain nearest to the water intrusion was plugged. Operations personnel used a catch basin to direct the water to another drain and placed sandbags around the 480 volt switchgear. The inspectors walked down the area during the hurricane and determined no water impacted the operation of the 480 volt switchgear.

As a result of the event, the NRC opened an unresolved item (URl) in lR 0500024712011004 requiring further information from Entergy staff regarding the causes of the water intrusion.

The inspectors reviewed the condition report (CR) written by Entergy staff to address the water intrusion and determined the CR was classified as a Category D, where no cause determination or tracking of corrective actions is required by Entergy staff, and the CR can be closed to the work management system. The inspectors questioned this level of classification because Entergy procedure EN-Ll-102, Corrective Action Process, provides classification guidance that indicates a Category B designation when it is prudent to not only fix the identified problem, but also to determine/document cause(s) of the problem and determine/document an action plan to fix cause(s) for an adverse condition classified as non-significant. After the inspectors questioned the classification, Entergy staff initiated a Category B CR to determine the cause of the water intrusion into the 480 volt room since water intrusion in this room has the potential to impact allfour trains of 480 volt switchgear.

In accordance with the requirements for a Category B CR, Entergy staff performed an ACE and determined that the apparent cause was the lack of sensitivity of risk for water intrusion vulnerabilities for plant components, and that Entergy staff had not developed and implemented a proactive identification and resolution strategy to preclude or mitigate water intrusion. Entergy procedure ENN-DC-150, Condition Monitoring of Maintenance Rule Structures, Attachment 9.5, Masonry Wall Inspection Checklist, indicates an action to determine if all penetrations (within the scope of the procedure) are properly sealed.

The inspectors determined that this procedure does not provide acceptance criteria to determine when a penetration is properly sealed. These seals were last inspected by Entergy personnel on September 6, 2007. Entergy staff, at that time, concluded the penetrations were properly sealed although there was documented efflorescence (indication of concrete/water interaction) on the wall near the seals. The inspectors noted that no CR was written and no evaluation was performed on the efflorescence to determine the source of water through the concrete.

The inspectors reviewed Entergy staff's response to operating experience associated with water intrusion into safety-related rooms, including lnformation Notice (lN) 92-69, Water Leakage From Yard Area Through Conduits Into Buildings; lN 2005-11, Internal Flooding/Spray-Down of Safety-Related Equipment Due to Unsealed Equipment Hatch Floor Plugs and/or Blocked Floor Drains; and lN 201 1-12, Reactor Trips Resulting From Water Intrusion Into Electrical Equipment. The inspectors determined that Entergy staff did not perform thorough reviews of the operating experience, and did not institute corrective actions to address potentialwater intrusion issues into safety-related equipment rooms.

Entergy staff revised procedure ENN-DC-150, Condition Monitoring of Maintenance Rule Structures, for inspections of structural elastomers, including seals and gaskets, to inspect for signs of cracks, separation, deterioration, foreign material, air leakage, and missing penetration sealant. Entergy personnel also implemented a permanent repair for the penetration seals and entered this issue into the CAP as CR-lP2-2011-4324.

Analvsis: The performance deficiency associated with this finding was that Entergy procedure ENN-DC-150, Condition Monitoring of Maintenance Rule Structures, did not have appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Also, in accordance with IMC 0612, Power Reactor lnspection Reports, Appendix E, Minor Examples, this finding is similar to examples 3.i and 3.j. Specifically, water intrusion in the 480 volt room could lead to the inoperability of 480 volt switchgear.

However, the inspectors noted that operators were able to direct the water away from switchgear using an existing floor drain. Using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," the inspectors determined this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not result in an actual loss of safety function, was not a loss of barrier function, and was not potentially risk significant for external events.

The finding has a cross-cutting aspect in the area of human performance associated with the resources attribute because Entergy personnel did not have complete, accurate and up-to-date procedures and work packages, to ensure adequate inspection of flood penetration seals. H.2(c) per IMC 0310]

Enforcement:

The inspectors identified a Green finding because Entergy personnel did not ensure that activities affecting quality were prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and that the activities were accomplished in accordance with these instructions, procedures, or drawings. No violation of regulatory requirements occurred because procedure ENN-DC-150, Condition Monitoring of Maintenance Rule Structures, is not subject to the quality assurance requirements as directed in the administrative section of TS 5.4, Procedures.

Because this issue does not involve a violation of regulatory requirements and has very low safety significance, it is identified as a finding. Entergy personneltook corrective actions and directed water to an unclogged floor drain, placed sandbags around the 480 volt switchgear, and initiated actions to develop a permanent repair to the penetration seals. The issue was entered into Entergy's CAP as CR-lP2-2011-4324. FIN

===0500024712011005-02, Water Intrusion Due to Leaking Flood Penetration Seals In the 480 Volt Room During Hurricane lrene.

.2 Maintenance Procedure not Followed for Inertia Latch Cleanino on 21 Service Water

Pump lntroduction: The inspectors documented a self-revealing NCV of very low safety significance (Green) of 10 CFR 50, Appendix B, Criterion V, "lnstructions, Procedures, and Drawings," because Entergy personnel did not follow Entergy procedure 2-BRK-022-ELC, Westinghouse Model DB-50 Breaker Preventative Maintenance, to remove and clean the zinc dichromate plating on 480 volt DB-50 breaker inertia latches.

Specifically, between July 24,2008 and October 3, 2011, Entergy personnel did not follow procedure 2-BRK-022-ELC, steps 4.6.16.11 - 4.6.16.15 to remove zinc dichromate plating on the 21 SWP inertia latch, resulting in the inoperability of the 21 SWP.

Description:

On October 3,2011, the 21 SWP failed to start as required in response to low service water flow to the containment FCUs during testing. Operations personnel discovered the control power fuse had failed and the breaker inertia latch was stiff and binding throughout its movement. With the breaker inertia latch toggled and not reset, the breaker will be mechanically blocked from closing and will result in control fuse actuation.

Entergy personnelwere in the process of conducting an ACE for 21 SWP, when on October 20,2011, during a surveillance test of the 21 auxiliary boiler feed water pump (ABFP), the 21ABFP breaker failed to operate as required after being secured from a pump run. After securing the pump, Entergy personnel identified the supply breaker's inertia latch bound and unable to be reset. After this failure, Entergy staff performed a root cause evaluation (RCE). Entergy staff determined the direct cause to be the breaker inertia latch was not reset and prevented the breaker from closing on demand.

Entergy staff determined the root cause to be the failure of maintenance personnel to perform the required cleaning to remove the zinc dichromate plating as required by proced u re 2-BRK-022-ELC, Westi n g house Model DB-50 Breaker Preventative Maintenance.

After the failure of the 21 ABFP breaker, the inspectors questioned Entergy personnel on the potential for a trend associated with these 480 volt DB-50 breakers. The inspectors questioned the control room operators on the operability of other 480 volt breakers based on a loss of coolant accident (IOCA) scenario followed by a loss of offsite power (LOOP), and whether these 480 volt breakers would close and re-sequence on the EDGs as required. Entergy personnel initiated CR-lP2-2011-5277, performed an immediate operability determination, and inspected all other safety-related 480 volt DB-50 breakers. No other stuck inertia latches were identified by Entergy personnel.

Entergy's corrective actions included replacement of the breaker inertia latches on 21 SWP and 21ABFP, extent of condition inspections of other similar breakers, human performance error reviews and re-enforcing expectations, and enhancing the procedure to provide additional guidance for breaker cleaning.

Entergy personnel reviewed the history of the 21 SWP breaker and determined the breaker was last operated satisfactorily on September 30, 2011. Technical Specification 3.7.8.4, Service Water System, requires that with one SW pump on the essential header inoperable, that the pump must be restored to operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Entergy personnel determined 21 SWP was inoperable from September 30 to October 3, 2011,

'for 76.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, greater than the TS 3.7.8 AOT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Therefore, Entergy submitted Licensee Event Report (LER) 0500024712011-002-00, "Technical Specification (TS)

Prohibited Condition Caused by an Inoperable 21 Service Water Pump for Greater than TS AOT Due to a Faulty Inertia Latch in the Supply Breaker." This LER is closed in Section 4OA3 of this report.

Analvsis: The performance deficiency associated with this finding was that Entergy personnel did not follow Entergy procedure 2-BRK-022-ELC, Westinghouse Model DB-50 Breaker Preventative Maintenance, to remove and clean the zinc dichromate plating on 480 volt DB-50 breaker inertia latches. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the 21 SWP was inoperable and accrued unavailability for a period of time and could impact the service water system function to provide a heat sink for the removal of process and operating heat from safety related components during a Design Basis Accident or transient. Using IMC 06 "Phase 1 - Initial Screening and Characterization of Findings," the inspectors determined that a Phase 2 evaluation was required because the finding screened as potentially risk significant since the 21 SWP inoperability was an actual loss of safety function of a single train for greater than the allowed outage time.

A Region I SRA conducted a Phase 3 analysis because the complexities with the service water line-up during the performance deficiency exposure period are not well represented in the NRC Phase 2 notebook. The SRA used Indian Point's Standardized Plant Analysis Risk model, version 8.15, in conjunction with the System Analysis Programs for Hands-On Integrated Reliability Evaluations, version 8.0.7.17, dated May 18,2011, to estimate the internal risk contribution of the Phase 3 risk assessment.

To closely approximate the type of failure exhibited by the 21 SWP, the SRA used the failure-to-start event and changed its failure probability to True, representing a 100 percent failure-to-run condition. The exposure time for this condition was 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br />.

Based upon the nature of the failure, no adjustments were made to the nominal operator recovery credit. The dominant core damage sequence was a LOOP, with a failure of EDGs and a failure to recover either off-site power or the EDGs. Additionally, the sequence also includes a failure to manually control the turbine driven ABFP and depressurize the steam generators. Given the delta CDF, in the low E-7 range, the SRA determined that the increase in large early release frequency would be negligible, in accordance with IMC 0609 Appendix H, since the containment type is large dry. Further the SRA determined that external events were not of concern given the very short, 76 hour8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> exposure period. Based upon the conclusions of the Phase 3 analysis, the Region I SRA determined this flnding was of very low safety significance (Green).

The finding has a cross-cutting aspect in the area of human performance associated with the work practices attribute because Entergy personnel did not define and effectively communicate expectations regarding procedural compliance and personnel following procedures. tH.4(b) per IMC 03101

Enforcement:

10 CFR 50, Appendix B, Criterion V, "lnstructions, Procedures, and Drawings," states, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Entergy procedure 2-BRK-0 22-ELC, Westinghouse Model DB-50 Breaker Preventative Maintenance, steps 4.6.16.11 - 4.6.16.15 direct Entergy personnel to remove zinc dichromate plating on the 480 volt DB-50 breaker inertia latches.

Contrary to the above, between July 24,2008 and October 3,2011, Entergy personnel did not folfow procedure 2-BRK-022-ELC, steps 4.6.16.1 1 - 4.6.16.15 to remove zinc dichromate plating on the 21 SWP inertia latch, resulting in the inoperability of the 21 SWP. Additionally, TS 3.7.8.A, Service Water System, requires that with one SW pump on the essential header inoperable, the pump must be restored to operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Contrary to the above, between September 30, 2011 and October 3,2011, 21 SWP was inoperable for 76.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without the pump being returned to operable status. Entergy's corrective actions included replacing the 21 SWP and 21 ABFP breakers, performing an extent of condition inspection of the other safety related 480 volt DB-50 breakers, human performance error reviews and re-enforcing expectations, and enhancing the procedure to provide additional guidance for breaker cleaning. Because this finding is of very low safety significance and was entered into Entergy's CAP as CR-lP2-2011-4893, consistent with Section 2.3.2 of the NRC Enforcement Policy, this violation is being treated as a NCV. NCV 0500024712011005-03, Maintenance Procedure not Followed for Inertia Latch Cleaning on 21 Service Water Pump.

1R13 Maintenance Risk Assessnlents and Emerqent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Entergy personnel performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Entergy personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Entergy personnel performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

.

With 23 charging pump planned maintenance and PT-Q55 pressurizer pressure bistable test on October 5,2011

.

With PT-M48 480V undervoltage test, 21 component cooling water pump out of service (OOS) and 21,25, and 26 SWP OOS for planned maintenance on October 31, 2011 r With PT-2M4 safety injection logic testing and 138 kV feeder 95891 OOS for maintenance on November 2,2011 o With 22 SWP breaker, refueling water storage tank level instrument 5751, and 138 kV feeders 95891 , 95331 , and 96951 OOS for planned maintenance; and 21 fan cooler unit out of service for emergent maintenance on November 10, 2011 b, Findinqs No findings were identified.

1R15 OperabilitvDeterminationsand F_gnctionalitvAssessments

a. Inspection Scooe The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

.

22 EDG fuel linkage mis-position during planned maintenance on September 12,2011 o 21 reactor coolant pump elevated seal return flow on October 12,2011

.

22 ABFP steam admission valve PCV-1139 increased leak-by on October 14,2011

.

21 EDG jacket water leak on December 8,2011 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to Entergy's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Entergy. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findinqs No findings were identified.

1R18 Plant Modifications (71111

.18 - 1 sample)

Temporarv Modification a. lnspection Scope The inspectors reviewed the temporary modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety.

The inspectors reviewed 10 CFR 50,59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.

.

Installation of a temporary screen on 27 and 28 seryice water inlet bays while de-silting and while the associated traveling wash screen was non-operationalon October 24,2011 b. Findinqs No findings were identified.

1R19 Post-Maintenance Testing (71111

.19 - 6 samples)

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

.

21 SWP after breaker replacement on October 3,2011

.

22 safety injection pump after breaker replacement on October 22,2011

.

23 EDG after air start motor replacements on October 13,2011 o f38 kV bus tie circuit breaker BT4-5 after repairs on November 13,2011 c 22 component cooling water heat exchanger after cleaning and eddy current inspection on November 14,2011 o 6.9 kV breaker 52GT26 after cubicle inspection and installation of new breaker on December 13.2011 b.

Findinos No findings were identified.

1R22 Surveillance Testino (71111.22 - 4 samples)

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and Entergy procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

o 2-PT-Q026C, 23 SWP test on October 3,2011 o 2-PT-Q0274,21 ABFP test on October 20,2011 o 2-PT-W020, Electrical Verification - Inverters and DC Distribution in Modes 1to 4 test on November 1, 2Q11

.

0-SOP-LEAKRATE-001, Reactor Coolant System leakrate surveillance, evaluation and leak identification on November 12.2011 b. Findinqs No findings were identified.

lEPO Drill Evaluation (71114.06 - 1 sample)

.1 Emerqencv Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine Entergy emergency drill on October 20, 2011, to identify weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Entergy staff in order to evaluate Entergy's critique and to verify whether the Entergy staff was properly identifying weaknesses and entering them into the CAP.

b. FindinqS No findings were identified.

2RS2 QccupationalAs LowAs is ReasonablylAchievable Planninq and Controls (71124.02-

1 sample)

a. Inspection Scope

Radioloqical Work Planninq Based on radiation work permit outage work activity collective exposure results from the Unit 3 Spring 2011 refueling outage, the inspectors selected for review those work activities that resulted in a dose of five person-rem or greater. This review included the basis of the exposure estimates with reference to historical performance metrics, and exposure mitigation requirements planned for these outage tasks.

With respect to the outage work activity samples, the inspectors compared the actual exposure results with the estimated exposure established in Entergy's As Low As is Reasonably Achievable (ALARA) plans for these work activities. The inspectors also compared the person-hour estimates provided by maintenance planning and other groups to the radiation protection group with the work activity person-hour actual results, to evaluate the performance results. The inspectors determined the reasons (e.9.,

failure to adequately plan the activity, failure to provide sufficient work controls) for any inconsistencies between intended and actualwork activity doses. The inspectors also determined if any identified exposure overrun causes were identified and entered into Entergy's corrective action program.

Verification of Dose Estimates and Exposure Trackinq Svstems The Unit 3 Spring refueling outage ALARA work packages that resulted in greater than five person-rem were reviewed to include the assumptions and basis (including dose rate and man-hour estimates) for their collective exposure estimates. Applicable procedures were reviewed to determine the methodology for estimating exposures for specific work activities and determining the intended dose outcome.

The inspectors verified for the selected work activities that Entergy personnel established measures to track, trend, and if necessary reduce, occupational doses for ongoing work activities and that criteria were established to prompt additional reviews andlor additional ALARA planning and controls.

The inspectors evaluated Entergy's method of adjusting exposure estimates when unexpected changes in scope or emergent work were encountered, The inspectors determined if adjustments to exposure estimates (intended dose) were based on sound radiation protection and ALARA principles or if they were only adjusted to account for inadequate work control.

b.

Findinqs No findings were identified.

2RS8 Radioactive Solid Waste Processinq and Radioactive Material Handlinq, Storaoe. and

Transportation V1124.08- 1 sample)

a. Inspection Scope

The inspectors reviewed the solid radioactive waste system description in the updated final safety analysis report (UFSAR), the Process Control Program (PCP), and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed.

The inspectors reviewed the scope of any quality assurance (QA) audits in this area since the last inspection to gain insights into Entergy's performance and inform the "smart sampling" inspection planning.

The inspectors selected areas where containers of radioactive waste were stored, and verified that the containers were labeled in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 20.1904, "Labeling Containers," or controlled in accordance with 10 CFR 20.1905, "Exemptions to Labeling Requirements," as appropriate.

The inspectors verified that radioactive materials storage areas were controlled and posted in accordance with the requirements of 10 CFR Part20, "Standards for Protection against Radiation." For materials stored or used in the controlled or unrestricted areas, the inspectors verified that they were secured against unauthorized removal and controlled in accordance with 10 CFR 20.1801, "Security of Stored Material," and 10 CFR 20.1802, "Control of Material not in Storage," as appropriate.

The inspectors verified that Entergy staff established a process for monitoring the impact of long-term storage (e.9., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements. The inspectors selected containers of stored radioactive materials, and verified that there were no signs of swelling, leakage, and deformation.

The inspectors selected liquid and solid radioactive waste processing systems, and walked down accessible portions of systems to verify and assess that the current system configuration and operation agreed with the descriptions in the UFSAR, offsite dose calculation manual and PCP.

The inspectors selected radioactive waste processing equipment that was not operational andior was abandoned in place, and verified that Entergy staff had established administrative and/or physical controls to ensure that the equipment would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure. The inspectors verified that Entergy staff reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59, "Changes, Tests, and Experiments."

The inspectors reviewed the adequacy of any changes made to the radioactive waste processing systems since the last inspection. The inspectors verified that changes from what is described in the UFSAR were reviewed and documented in accordance with 10 CFR 50.59, as appropriate.

The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers. The inspectors verified that the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP, and provided representative samples of the waste product for the purposes of waste classification as described in 10 CFR 61

.55 ,

"Waste Classification. "

For those systems that provide tank recirculation, the inspectors verified that the tank recirculation procedure provided for sufficient mixing.

The inspectors verified that Entergy's PCP correctly described the current methods and procedures for dewatering and waste.

The inspectors selected radioactive waste streams, and verified that Entergy's radiochemical sample analysis results were sufficient to support radioactive waste characterization as required by 10 CFR Part 61 , "Licensing Requirements for Land Disposal of Radioactive Waste." The inspectors verified that Entergy's use of scaling factors and calculations, to account for difficult-to-measure radionuclides, was technically sound and based on current 10 CFR Part 61 analysis, For the waste streams selected above, the inspectors verified that changes to plant operational parameters were taken into account to

(1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update, and

(2) verify that waste shipments continued to meet the requirements of 10 CFR Part 61 .

The inspectors verified that Entergy personnel established and maintained an adequate QA program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, "Waste Characteristics."

The inspectors observed radiation workers during the conduct of radioactive waste processing and radioactive material shipment preparation and receipt activities. The inspectors determined that the shippers were knowledgeable of the shipping regulations and that shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport with respect to Entergy's response to NRC Bulletin 79-19, "Packaging of Low-Level Radioactive Waste for Transport and Burial,"

dated August 10, 1979, and 49 CFR Part 172,"Hazardous Materials Table, Special Provisions, Hazardous Materials Communication, Emergency Response Information, Training Requirements, and Security Plans," Subpart H, "Training." The inspectors verified that Entergy's training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.

The inspectors selected non-excepted package shipment records and verified that the shipping documents indicated the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and UN number. The inspectors verified that the shipment placarding was consistent with the information in the shipping documentation.

The inspectors verified that problems associated with radioactive waste processing, handling, storage, and transportation were being identified by Entergy staff at an appropriate threshold, were properly characterized, and were properly addressed for resolution in the Entergy corrective action program. The inspectors verified the appropriateness of the conective actions for a selected sample of problems documented by Entergy staff that involved radioactive waste processing, handling, storage, and transportation.

The inspectors reviewed the results of selected audits performed since the last inspection of this program and evaluated the adequacy of Entergy's corrective actions for issues identified during those audits, b. Findinos No findings were identified.

4OA1 Performance Indicator Verification

.1 Mitiqatinq Svstems Performance lndex (2 samples)

a. Inppection Scope The inspectors reviewed Entergy's submittal of the Mitigating Systems Performance Index for the following systems for the period of October 1,2010, through September 30, 201 1:

r Unit 2 Residual Heat Removal System

.

Unit 2 Cooling Water System To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy lnstitute (NEl) Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors also reviewed Entergy's operator narrative logs, CRs, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findinqs No findings were identified.

,2 Reactor Coolant Svstem Specific Activjlr and RCS Leak Rate ===

a. lnsoection Scope The inspectors reviewed Entergy's submittal for the RCS specific activity and RCS leak rate performance indicators for both Unit 1 and Unit 2 for the period of October 1,2010 through September 30, 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements for RCS leakage, and compared that information to the data reported by the performance indicator. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personneltaking and analyzing an RCS sample.

b. Inspection Findinqs No findings were identified.

.3 Occupational Exposure Control Effectiveneqg (1 sample)

a. Inspection Scooe The inspectors reviewed implementation of the licensee's Occupational Exposure Control Effectiveness Performance Indicator (Pl) Program. Specifically, the inspectors reviewed CRs, and radiological controlled area dosimeter exit logs for the past four calendar quarters (through 3rd quarter 2011). These records were reviewed for occurrences involving locked high radiation areas, very high radiation areas, and unplanned exposures against the criteria specified in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, to verify that all occurrences that met the NEI criteria were identified and reported as performance indicators.

b. lnspection Findinqs No findings were identified.

Radiolooical Effluent Occurrences (1 sample)

lnsoection Scope The inspectors reviewed a listing of relevant effluent release reports for the past four calendar quarters (through 3rd quarter 2011), for issues related to the public radiation safety Pl, which measures radiological effluent release occurrences per site that exceed 1.5 mrem/quarter whole body or 5.0 mrem/quarter organ dose for liquid effluents; 5.0 mrads/quarter gamma air dose, 10 mrad/quarter beta air dose, and 7.5 mrads/quarter for organ dose for gaseous effluents. The review was against applicable criteria specified in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The purpose of the review was to verify that occurrences that met the NEI criteria were recognized and identified as Pl occurrences.

The inspectors reviewed the following documents to ensure the licensee met all requirements of the performance indicator:

.

Monthly projected dose assessment results due to radioactive liquid and gaseous effluent releases

.

Quarterly projected dose assessment results due to radioactive liquid and gaseous effluent releases o Dose assessment procedures b.

Inspection Findinos No findings were identified.

4OA2 Problem ldentification and Resolution (71152

- 3 samples)

.1 Routine Review of Problem ldentification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure71152,"Problem ldentification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergy personnel entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings.

b. Findinos No findings were identified.

.2 Semi-AnnualTrend Review

a. Insoection Scope The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, "Problem ldentification and Resolution," to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by personnel outside of the CAP, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed Entergy's CAP database for the first and second quarters of 2011 to assess condition reports written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily condition report review (Section 4042.1). The inspectors reviewed the Entergy quarterly trend report for the third quarter of 2011, conducted under LO-IP3LO-2011-0154 to verify that Entergy personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures b, Findinqs and Observations No findings were identified. The inspectors evaluated a sample of departments that are required to provide input into the quarterly trend reports, which included a focus on maintenance and planning departments. This review included a sample of issues and events that occurred over the course of the past two quarters with a focus on level 'D' significance condition reports to objectively determine whether issues were appropriately considered or ruled as emerging or adverse trends, and in some cases, verified the appropriate disposition of resolved trends.

The inspectors observed an apparent increase in the number of condition reports associated with 21 EDG jacket water leakage. The inspectors noted that a potential trend associated with jacket water leakage had not been recognized by Entergy personnel as a specific emerging or adverse trend. Entergy personnel entered this issue into the CAP as a corrective action to CR-lP2-2011-6257 to evaluate the issue including whether a revision to the preventative maintenance procedure to physically verify that the hose clamps on the cylinder head jacket water are tight was warranted.

.3 Annual Samole: Review of the Operator Workaround Proqram

Inspection Scope The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in Entergy procedure OAP-45, "Operator Burden Program."

The inspectors reviewed Entergy's process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent Entergy self assessments of the program. The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.

b. Findinqs and Observations No findings were identified.

The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures.

The inspectors also verified that Entergy personnel entered operator workarounds and burdens into the CAP at an appropriate threshold and planned or implemented CAs commensurate with their safety significance.

40A3 Follow-Up of Events and Notices of Enforcement Discretion (71153 - 3 samples)

.1 (Closed) Licensee Event Report 05000247/2010-009-00: Automatic Reactor Trip Due to

a Turbine Generator Trip Caused by a Fault of the 21 Main Transformer Phase B High Voltage Bushing On November 7, 2010, an automatic reactor trip occurred at full power as a result of a turbine generator trip due to a fault from the failure of the 21 main transformer. The failure was as a result of a low impedance fault of the 345 kV phase B busing. The inspectors evaluated the response of control room personnel and plant equipment following the automatic reactor trip as described in NRC Inspection Report 0500024712010005. Entergy personnel determined that the root cause of the event was inadequate vendor design and/or manufacturing deficiency of the trench electric type bushings. The immediate corrective actions included replacement of the 21 main transformer. Entergy personnel later replaced the 22 transformer bushings since the bushings were of a similar design as the 21 main transformer bushings. Entergy personnel documented the root cause evaluation in CR lP2-2010-06801. The inspectors reviewed the LER, CRs and corrective actions to determine whether the station adequately evaluated the condition. No findings were identified. This LER is closed.

.2 (Closed) Licensee Event Report 05000247/201 1-001-00: Automatic Actuation of

Emergency Diesel Generators Due to Undervoltage on 480 VAC Vital Buses 5A and 64 Caused by a Loss of Offsite Power During Switchyard Troubleshooting On March 1,2011, troubleshooting on a metering circuit in the Buchanan switchyard by Consolidated Edison resulted in a loss of 138 kV offsite power. The EDGs automatically actuated as a result of under-voltage on 480 volt buses 5A and 6A; buses 2A and 3A remained energized from the unit auxiliary transformer connected to the main generator.

The inspectors evaluated the response of control room personnel and plant equipment following the loss of 138 kV offsite power as described in NRC Inspection Report 0500024712011002. Entergy personnel determined the apparent cause to be a failure of Consolidated Edison's current transformer test switch associated with the metering circuit on the 138 kV offsite power line to make-before-break. The failed test switch was determined to have corrosion on the contact surfaces. Entergy staffs corrective actions included ensuring Consolidated Edison personnel replaced the test switch and improved its planned work notification procedure. The inspectors reviewed the LER, CRs and corrective actions to determine whether the station adequately evaluated the condition.

Entergy staff entered this issue into the CAP as CR-IP2-2011-0108. No findings were identified. This LER is closed.

.3 (Closed) Licensee Event Report 05000247/201 1-002-00: Technical Specification (TS)

Prohibited Condition Caused by an Inoperable 21 Service Water Pump for Greater than TS Allowed Outage Time (AOT) Due to a Faulty Inertia Latch in the Supply Breaker on October 3, 2011, 21 SWP did not start as required in response to low flow on the containment FCUs during testing. Operations personnel discovered the control power fuse had failed and the breaker inertia latch was stiff and binding throughout its movement. With the breaker inertia latch toggled and not reset, the breaker was mechanically blocked from closing and this resulted in controlfuse actuation. The root cause was that Entergy personnel did not perform the required cleaning to remove the zinc dichromate plating as required by the preventative maintenance procedure.

Entergy's corrective actions included replacement of the breaker inertia latch, extent of condition inspections of other similar breakers, human performance error reviews and re-enforcing expectations, and enhancing the procedure to provide additional guidance for breaker cleaning. Entergy staff entered this issue into the CAP as CR-lP2-2011-4893. The enforcement aspects of this issue are discussed and documented in Section 1R12. The inspectors did not identify any new findings during the review of the LER. This LER is closed.

4OA5 Other Activities

Operation of an ISFSI at Operatinq Plants (60855)

a. Inspection Scope

The inspectors verified by direct observation and independent evaluation that Entergy personnel had performed loading activities at the Independent Spent Fuel Storage Installation (lSFSl) in a safe manner and in compliance with applicable procedures. The inspectors toured the ISFSI and reviewed radiological surveys performed during the past 12 months.

b.

Findinqs No findings were identified.

40A6 Meetinqs, Includinq Exit On January 19,2011, the inspectors presented the inspection results to Mr. John Ventosa, Site Vice President and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

4C.A7 Licensee-ldentified Violations The following violation of very low safety significance (Green) was identified by Entergy and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

o 10 CFR 50, Appendix B, Criterion V, "lnstructions, Procedures, and Drawings,"

requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, on September 12, 2011, a non-intrusive inspection on the 22EDG was not accomplished in accordance with the maintenance proced ure. Specifically, maintenance personnel rotated the 22EDG governor linkage to set the fuel racks to the zero position instead of inspecting the fuel racks individually. This resulted in the 22 EDG being declared inoperable for 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> and an unplanned yellow risk condition. Entergy personnel entered the issue in the CAP as CR-lP2-201 1-04556 and 04579 and performed an ACE. The maintenance procedure was revised to include a caution note to prevent personnelfrom manipulating the governor during non-intrusive inspections. Using IMC 0609 Attachment 4, "Phase 1 - lnitial Screening and Characterization of Findings," the inspectors determined that this finding is of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not result in an actual loss of safety function, and was not potentially risk significant for external events.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Ventosa, Site Vice President

N. Azevedo, Manager, Engineering

J. Baker, Shift Manager

T. Beasely, Engineering

M. Burney, Nuclear Safety/License lV Specialist

R. Burroni, Manager, System Engineering

T. Cole, Project Manager, NUC

G. Dahl, Nuclear Safety/License lV Specialist

R. Daley, Engineer lll, Nuclear

M. Dechristopher, Engineering

G. Dean, Shift Manager

D. Dewey, Shift Manager

J. Dinelli, Manager, Operations

R. Dolanksy, Manager, lSl Program

R. Drake, Engineering

T. Flynn, Maintenance Inspection Coordinator

E. Goethicus, Operations Instructor

D. Gagnon, Manager, Security

F. Inzirillo, Manager, IPEC Quality Assurance

R. Lee, Lead Engineer, Buried Pipe and Tank Program

J. Lijoi, Superintendent, l&C

L. Lubrano, Senior Lead Engineer

R. Mages, Senior HP/Chemical Specialist

D. Mayer, Director, Unit 1

T. McCaffrey, Manager, Design Engineering

B. McCarthy, Manager, Assistant Operations

T. Motko, System Engineer

T. Orlando, Director, Engineering

E. Primrose, Shift Manager

S. Prussman, Nuclear Safety/License lV Specialist

J. Reynolds, Corrective Action Specialist

R. Robenstein, Superintendent, Simulator

T. Salentino, Superintendent, Dry Fuel Storage

S. Sandike, Senior HPiChemical Specialist

P. Santini, Senior Reactor Operator

A. Singer, Superintendent, Licensed Operator Requalification Training

D. Smith, TechnicalSpecialist lV

B. Sullivan, Manager, Emergency Preparedness

R. Tagliamonte, Manager, Radiation Protection

M. Tesoriero, Manager, Programs and Components

J. Thaliath, Engineer li, Nuclear

M. Troy, Manager, Engineering

R. Walpole, Manager, Licensing

A. Williams, Assistant General Manager, Plant Operations

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000247t2011-005-01 NCV Untimely Corrective Actions for Repeated Control Room Fan Failures (Section 1R04)

050a024712011-005-02 FIN Water lntrusion Due to Leaking Flood Penetration Seals in the 480 Volt Room During Hurricane lrene (Section 1R12)

0500024712011-005-03 NCV Maintenance Procedure Not Followed for Inertia Latch Cleaning on 21 Service Water Pump (Section 1R12)

Closed

0500024712010-009-00 LER Automatic Reactor Trip Due to a Turbine Generator Trip Caused by a Fault of the 21 Main Transformer Phase B High Voltage Bushing (Section 4OA3)

05000247/2011-001-00 LER Automatic Actuation of Emergency Diesel Generators Due to Undervoltage on 480 VAC Vital Buses 5A and 64 Caused by a Loss of Offsite Power During Switchyard Troubleshooting (Section 4OA3)

05000247t2011-002-00 LER Technical Specification Prohibited Condition Caused by an lnoperable 21 Service Water Pump for Greater than TS AOT Due to a Faulty Inertia Latch in the Supply Breaker (Section 4OA3)