Text

IR 05000247-12-003; 04/01/12 - 06/30/12; Indian Point Nuclear Generating Unit 2 - NRC Integrated Inspection Report
	ML12222A131
Person / Time
Site:	Indian Point
Issue date:	08/09/2012
From:	Mel Gray; Reactor Projects Branch 2
To:	Ventosa J; Entergy Nuclear Operations
	GRAY, MEL
References
	IR-12-003
	Download: ML12222A131 (37)
	v • d • e

UNITED STATES August 9, 2012

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC INTEGRATED INSPECTION REPORT 05000247/2012003

Dear Mr. Ventosa:

On June 30, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Unit 2. The enclosed integrated inspection report documents the inspection results, which were discussed on August 2, 2012, 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.

This report documents one self-revealing finding of very low safety significance (Green) and one NRC-identified Severity Level IV violation. These findings were determined to involve violations of NRC requirements. Additionally, licensee-identified violations, which were determined to be of very low safety significance, are listed in this report. However, because of the very low safety significance, and because they are entered into your corrective action program (CAP), the NRC is treating these findings as non-cited violations (NCVs), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at Indian Point Nuclear Generating Unit 2. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at Indian Point Nuclear Generating Unit 2. 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 available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs 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,

/RA/

Mel Gray, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No. 50-247 License No. DPR-26

Enclosure:

Inspection Report 05000247/2012003 w/Attachment: Supplementary Information

REGION I==

Docket No.: 50-247 License No.: DPR-26 Report No.: 05000247/2012003 Licensee: Entergy Nuclear Northeast (Entergy)

Facility: Indian Point Nuclear Generating Unit 2 Location: 450 Broadway, GSB Buchanan, NY 10511-0249 Dates: April 1, 2012, through June 30, 2012 Inspectors: O. Ayegbusi, Acting Senior Resident Inspector - Indian Point 2 M. Catts, Senior Resident Inspector - Indian Point 2 R. Montgomery, Acting Resident Inspector - Indian Point 2 J. Furia, Senior Health Physicist - Region I S. McCarver, Project Engineer - Region I Approved By: Mel Gray, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000247/2012003; 4/01/12 - 6/30/12; Indian Point Nuclear Generating (Indian Point) Unit 2;

Maintenance Effectiveness and Surveillance Testing.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one finding of very low safety significance (Green) and one Severity Level IV violation, which were NCVs. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect for the finding was 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 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.

Cornerstone: Initiating Events

Green.

A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, was identified because Entergy personnel did not follow procedure 0-PMP-401-RCS, Reactor Coolant Pump Seal Package Inspection, to prevent foreign material from entering the 21 reactor coolant pump (RCP) seal package.

Specifically, during the March 2010 refueling outage, Entergy personnel did not follow procedure 0-PMP-401-RCS and implement the foreign material exclusion procedural controls which resulted in a degraded 21 RCP seal package. Entergy personnel subsequently replaced the 21 RCP seal package and entered this issue into the CAP as condition report (CR)-IP2-2011-5052.

The performance deficiency associated with this finding was that Entergy staff did not follow procedure 0-PMP-401-RCS to prevent foreign material from entering the 21 RCP seal assembly. This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the foreign material introduced into the 21 RCP seal package resulted in an increase in the likelihood of tripping the 21 RCP due to further potential for degradation of the 21 RCP seal package. Additionally, if left uncorrected, the foreign material had the potential to further damage the seal package and result in a more significant safety concern. 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 would not result in exceeding the technical specification limit for RCS leakage and would not have affected other mitigation systems resulting in a total loss of their safety function. 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. H.4(b) per IMC 0310]

Cornerstone: Mitigating Systems

SL-IV. The inspectors identified a Severity Level lV, NCV of 10 CFR 50.73(a)(2)(i)(B),

because Entergy personnel did not provide a written licensee event report (LER) to the NRC within 60 days of identifying during testing that MS-46D, main steam line safety valve, was inoperable and in a condition prohibited by the plants Technical Specification (TS). Entergy personnel adjusted the valves lift setpoint to within the TS operability limit, repaired and tested the valve before plant startup. Entergy staff entered this issue into the CAP as CR-IP2-2012-3320 and CR-IP2-2012-4153.

The inspectors determined that the failure to provide a written LER within 60 days was a performance deficiency that was reasonably within Entergys ability to foresee and correct, and should have been prevented. This violation involved not making a required report to the NRC and is considered to impact the regulatory process. Such violations are dispositioned using the traditional enforcement process instead of the Significance Determination Process. Using the NRC Enforcement Policy Section 6.9, Inaccurate and Incomplete Information or Failure to Make a Required Report, example (d)(9), the NRC determined this violation is more than minor and is categorized as a Severity Level IV violation. Because this violation involves the traditional enforcement process with no underlying technical violation that would be considered more than minor in accordance with IMC 0612, a cross-cutting aspect is not assigned to this violation. (Section 1R22)

Other Findings

Violations of very low safety significance that were identified by Entergy were reviewed by the inspectors. Corrective actions taken or planned by Entergy staff have been entered into Entergys corrective action program. The violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Indian Point Unit 2 began the inspection period near the end of a planned refueling outage (2R20). On April 1, 2012, with the unit at or near 5 percent power, operators shut the plant down to hot standby conditions (Mode 3) to repair a main generator exciter system component.

Following repairs, on April 1, operators synchronized the generator to the grid completing the planned refueling outage (2R20) and continued reactor power ascension. On April 7, with the unit at or near 90 percent power, operators reduced power to approximately 51 percent to repair speed oscillations on the 22 main boiler feed pump. Following repairs, operators resumed power ascension and achieved full reactor power on April 8. On June 6, the reactor tripped from 100 percent power due to a turbine trip that resulted from a main generator exciter problem. Following repairs, operators returned the unit to 100 percent on June 8. The unit remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Entergys procedures affecting these areas and the communications protocols between the transmission system operator and Entergy. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Entergy personnel established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system engineer, reviewing condition reports and open work orders, and walking down portions of the offsite and alternate AC power systems including portions of the offsite Buchanan switchyard as well as onsite 138 kV switchyard areas and components.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04Q

Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

21 emergency diesel generator (EDG) while 23 EDG was out of service on April 10, 2012 Appendix R EDG after a cooling valve was left in closed position on April 12, 2012 22 auxiliary feed water pump while 23 auxiliary feed pump was out of service on June 5, 2012 21 containment spray pump (CSP) following quarterly testing on June 20, 2012 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 analysis report (UFSAR), technical specifications, 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 the 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 corrective action program for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05Q

Resident Inspector Quarterly Walkdowns

a. Inspection Scope

Main article: IP 71111.12Q

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, corrective action program 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 (a)(2) 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 (a)(2). Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

Weld channel and pressurization system zone 3 leaks resulting in control room alarms on December 23, 2011 21 reactor coolant pump (RCP) seal degradation resulting in a reactor shutdown on January 10, 2012 Service water relief valves 42-1, 42-2, and 42-5 failed the as-found set pressure tests on March 15 - 18, 2012 Pressurizer safety valve 468 leaking from its inlet flange resulting in mode change from Mode 3 to Mode 5 to replace the valve on March 24, 2012

b. Findings

Introduction:

A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified because Entergy personnel did not adequately implement procedure 0-PMP-401-RCS, Reactor Coolant Pump Seal Package Inspection, to prevent foreign material from entering the 21 RCP seal package.

Specifically, during the March 2010 refueling outage, Entergy personnel did not adequately implement foreign material exclusion procedural controls which resulted in a degraded 21 RCP seal package.

Description:

On October 11, 2011, the 21 RCP exhibited temporary increased seal return flow (No. 1 seal) from 2.3 gallons per minute (gpm) to 3.1 gpm. Seal return flow range is acceptable between 1 and 5 gpm, and is normally around 2 gpm. Entergy staff entered this condition into their operational decision making process (ODMI). The purpose of the ODMI was to provide operations with guidance to monitor and advise Entergys management team of any anomalies with respect to the seal return flow for RCP-21 while within normal operating parameters and outside the entry conditions of 2-AOP-RCP-1, Reactor Coolant Pump Malfunction. Over the next couple of months several increases in seal return flow followed by subsequent returns to expected nominal, stable conditions occurred until December 30, 2011. At that time, operators identified an increase in seal return flow which did not return to the lower stable value.

Seal return flow continued to increase until the alarm setpoint was received at 5 gpm.

On January 10, 2012, when seal flow exceeded 5 gpm, operations personnel implemented the alarm response procedure and procedure 2-AOP-RCP-1, Reactor Coolant Pump Malfunction, and implemented a controlled shutdown of the reactor.

During the maintenance outage, the 21 RCP seal package was replaced and the operators returned the unit to service on January 19, 2012.

The inspectors reviewed Entergys apparent cause evaluation (ACE) that documented the direct cause of the degraded 21 RCP seal package condition as observed by seal return flow perturbations. The evaluation documented there was a degraded seal ring of the 21 RCP Double Delta Channel Seal (DDCS) and associated o-ring. The degradation allowed the seal ring to behave erratically due to frictional effects between the DDCS o-ring and the insert. The eventual failure of the o-ring allowed bypass leakage via the ring/insert interface which caused the increased seal return flow. Entergy personnel determined that the apparent cause of the degraded seal package was foreign material debris found downstream of the No. 1 seal assembly. This material intruded under the sealing surface of the DDCS causing degradation and eventual failure around the balance diameter of the insert. The inspectors noted that Entergy personnel determined the foreign material was likely introduced into the seal package when the seal package was open for maintenance during the March 2010 refueling outage. Entergy staff reviewed the seal maintenance instructions in 0-PMP-401-RCS and determined that the documentation for seal maintenance was incomplete with regard to procedural controls of foreign material. Entergy procedure 0-PMP-401-RCS, Reactor Coolant Pump Seal Package Inspection, step 4.6 requires foreign material exclusion control (Attachment 5)must be established prior to removal of seal assemblies. Attachment 5 requires an access list (Attachment 6) shall be maintained to restrict access to the exclusion area.

Access shall be controlled by a monitor stationed in a low radiation area. Only workers briefed on tool and material control for the seal package work and on the Authorized Access List will be permitted to enter the exclusion area. Procedure 0-PMP-401-RCS, step 4.12.2 documented that 10 individuals were involved in the work. However, Attachment 6, RCP Seal Package RCS Exclusion Area Access List, indicated that only one individual properly signed onto the access list.

The inspectors determined that Entergy personnel did not properly implement foreign material exclusions procedure controls which would have likely mitigated or prevented foreign material from entering the 21 RCP seal package. Entergy sent samples of the foreign material to Westinghouse for analysis, but the source of the material could not be identified. The inspectors noted that Entergy staff, based upon post-inspection results of the 21 RCP seal package, determined that the degraded condition that occurred had not impacted the 21 RCP sealing surfaces or pump seal function. Additional corrective actions by Entergy staff included revising procedure 0-PMP-401-RCS to include the 21 RCP issue for operating experience, and discussing the event and importance of foreign material control with plant personnel.

Analysis:

The performance deficiency associated with this finding was that Entergy staff did not follow procedure 0-PMP-401-RCS to prevent foreign material from entering the 21 RCP seal assembly. This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the foreign material introduced into the 21 RCP seal package resulted in an increase in the likelihood of tripping the 21 RCP due to further potential for degradation of the 21 RCP seal package. Additionally, if left uncorrected, the foreign material had the potential to further damage the seal package and result in a more significant safety concern. 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 would not result in exceeding the technical specification limit for RCS leakage and would not have affected other mitigation systems resulting in a total loss of their safety function.

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. H.4(b) per IMC 0310]

Enforcement:

10 CFR 50, Appendix B, Criterion V, "lnstructions, Procedures, and Drawings," states, in part, 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. Entergy procedure 0-PMP-401-RCS, Reactor Coolant Pump Seal Package Inspection, step 4.6 requires foreign material exclusion control (Attachment 5) must be established prior to removal of seal assemblies. Attachment 5 states an access list (Attachment 6) shall be maintained to restrict access to the exclusion area. Access shall be controlled by a monitor stationed in a low radiation area. Only workers who have been briefed regarding tool and material control and on the Authorized Access List will be permitted to enter the exclusion area. Procedure 0-PMP-401-RCS, step 4.12.2 indicated that 10 individuals were involved in the work.

However, Attachment 6, RCP Seal Package RCS Exclusion Area Access List, documented only one individual properly signed in the access list. Contrary to the above, during the March 2010 refueling outage, Entergy personnel did not follow procedure 0-PMP-401-RCS, including not completing and establishing adequate foreign material exclusion procedural controls, resulting in foreign material and subsequent degradation of the 21 RCP No. 1 seal. Entergys initial corrective actions included replacing the 21 RCP seal package. Because this finding is of very low safety significance and was entered into Entergy's CAP as CR- lP2-2011-5052, consistent with Section 2.3.2 of the NRC Enforcement Policy, this violation is being treated as a NCV.

(NCV 05000247/2012003-01, Foreign Materials Control Procedure Not Followed Resulting in Degraded 21 Reactor Coolant Pump Seal Package)

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

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 operators 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 stations 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.

24 static inverter out of service for unplanned maintenance and planned calibration of nuclear instrumentation on April 3, 2012 23 EDG and 25 circulating water pump out of service for planned maintenance and 22 charging pump out of service for corrective maintenance on April 10, 2012 138 kV feeder 96951 out of service for planned maintenance and reactor protection logic channel B testing on April 23, 2012 22 heater drain tank pump discharge flow transmitter unplanned maintenance during 480V under-voltage testing on May 9, 2012 Emergent work to determine the cause of the turbine generator trip and subsequent reactor trip on June 6, 2012

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

24 static inverter transfer to alternate power source on April 3, 2012 23 static inverter transfer function failure on April 9, 2012 21 CSP discharge valve (MOV-866B) missing limiter plate on June 19, 2012 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 technical specification 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 technical specifications and UFSAR to Entergys 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 personnel. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

1R18 Plant Modifications

Main article: IP 71111.18

Temporary Modification

a. Inspection Scope

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 technical specifications, 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:

2-PT-R006, Main Steam Safety Valve Setpoint Determination on March 2, 2012 2-PT-V024Q, CD-109 Condensate Storage Tank Inlet Header Check Valve Inservice Closure Test, on March 6, 2012 2-PT-2Y008C, 23 Emergency Diesel Generator Mechanical Overspeed Trip, on April 11, 2012 2-PT-Q034, 22 Auxiliary Feed Water Pump, on May 3, 2012 2-PT-V-63A, Reactor Protection Logic Train A Partial Functional Test, on June 6, 2012 2-PT-V-63B, Reactor Protection Logic Train B Partial Functional Test, on June 6, 2012

a. Findings

Introduction:

The inspectors identified a Severity Level lV, NCV of 10 CFR 50.73(a)(2)(i)(B), because Entergy did not provide a written LER to the NRC within 60 days of identifying a condition prohibited by the plants TS. Specifically, Entergy personnel did not report the inoperability of a steam generator main steam safety valve for greater than its TS allowed outage time (AOT) to the NRC.

Description:

On March 2, 2012, during performance of procedure 2-PT-R006, Main Steam Safety Valve Setpoint Determination, MS-46D, one of five main steam safety valves on the 24 steam generator, lifted outside the TS required range. TS 3.7.1, Main Steam Safety Valves, requires that MSSVs be operable in accordance with TS Table 3.7.1-1 and Table 3.7.1-2. MS-46D lifted at 1136.9 psig, which is outside +/-3% from the TS setpoint of 1080 psig. Entergy operators declared the valve inoperable and entered the applicable action statement. The lift setpoint was subsequently adjusted to within +/-

3% of the desired setpoint and the action statement was exited. Entergy personnel entered the issue in its CAP as CR-IP2-2012-01311 to perform a reportability evaluation, an apparent cause evaluation and initiate corrective actions.

On March 11, 2012, MS-46D was disassembled and inspected as part of preventive maintenance, during which Entergy personnel identified the failure mechanism to be a valve spring skew. On March 15, 2012, Entergys reportability evaluation determined that the as-found condition was not reportable because the safety valve failure did not impact the accident analyses as described in the UFSAR. On March 25, 2012, Entergys ACE documented that the valve failure was due to internal spring skew determined to be as a result of line vibrations and steam flow in the main steam line over time. On March 28, 2012, Entergy personnel completed corrective actions and closed the condition report requiring no further evaluations.

The inspectors reviewed CR-IP2-2012-01311 and procedure 2-PT-R006, and noted that the spring skew failure mechanism occurred over time, which Entergy staff determined rendered the valve inoperable for greater than its AOT in TS 3.7.1 prior to the valve being tested. Considering NUREG-1022, section 3.2.2, the inspectors determined that MS-46D lifting outside the TS setpoint range was reportable because the failure mechanism was known and the valve was determined to be inoperable for greater than its TS AOT. Inspector questions caused Entergy staff to re-evaluate reportability.

Entergy staff initiated CR-IP2-2012-3320 to submit a 60-day LER and CR-IP2-2012-4153 to document the incorrect reportability determination on March 15, 2012. Entergy's corrective actions included the initiation of CR-IP2-2012-3320 and CR-IP2-2012-4153, and the submittal of LER 2012-005-00 to the NRC on May 24, 2012.

Analysis:

The inspectors determined that the failure to provide a written LER within 60 days was a performance deficiency that was reasonably within Entergys ability to foresee and correct, and should have been prevented. This violation involved not making a required report to the NRC and is considered to impact the regulatory process.

Such violations are dispositioned using the traditional enforcement process instead of the Significance Determination Process. Using the Enforcement Policy, Section 6.9, Inaccurate and Incomplete Information or Failure to Make a Required Report, example (d)(9), which states A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73, the NRC determined this violation is more than minor and is categorized as a Severity Level IV violation (very low safety significance).

Because this violation involves the traditional enforcement process with no underlying technical violation that would be considered more than minor in accordance with IMC 0612, a cross-cutting aspect is not assigned to this violation.

Enforcement:

10 CFR 50.73(a)(2)(i)(B) requires, in part, that licensees submit a LER for any operation or condition which was prohibited by the plants Technical Specifications, within 60 days of discovering the event. Contrary to the above, Entergy failed to submit a report within 60 days of March 2, 2012, when Entergy personnel identified during testing, an inoperable steam generator main steam safety valve; a condition which was determined to be prohibited by the plants Technical Specification. Because this violation was of very low safety significance and was entered into Entergys corrective action program, this violation is being treated as an NCV, consistent with section 2.3.2 of the NRC Enforcement Policy. (NCV 05000247/2012003-02, An LER for an Inoperable Main Steam Safety Valve Was Not Submitted When Required)

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

Main article: IP 71114.06

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine Entergy emergency drill on May 3, 2012, to identify any 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 Entergys critique and to verify whether the Entergy staff was properly identifying weaknesses and entering them into the corrective action program.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstone: Occupational/Public Radiation Safety

2RS7 Radiological Environmental Monitoring Program

Main article: IP 71124.07

a. Inspection Scope

The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendix A, Criterion 60 - Control of Release of Radioactivity to the Environment; 10 CFR Part 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion As Low As is Reasonably Achievable for Radioactive Material in Light-Water - Cooled Nuclear Power Reactor Effluents; 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations; 40 CFR Part 141, Maximum Contaminant Levels for Radionuclides; the guidance in Regulatory Guides 1.23, 4.1 and 4.15, NUREG 1301 and/or 1302, as well as, applicable industry standards and licensee procedures as criteria for determining compliance.

The inspectors reviewed the annual radiological environmental operating reports, and the results of any licensee assessments since the last inspection, to verify that the radiological environmental monitoring program (REMP) was implemented in accordance with the plant TS and the offsite dose calculation manual (ODCM). The inspectors reviewed the report for changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and analysis of data.

The inspectors reviewed the annual effluent release report and the 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, report, to determine if Entergy staff were sampling, as appropriate, for the predominant and dose-causing radionuclides likely to be released in effluents.

The inspectors walked down air sampling stations and thermo-luminescence dosimeter (TLD) monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition. For the air samplers and TLDs selected above, the inspectors reviewed the calibration and maintenance records to verify that they demonstrate adequate operability of these components. Additionally, the inspector reviewed the calibration and maintenance records of composite water samplers as available.

The inspectors verified that Entergy had initiated sampling of other appropriate media upon loss of a required sampling station.

The inspectors observed the collection and preparation of environmental samples from different environmental media as available. Sampling observed included river water, seaweed, and river sediment. The inspectors verified that environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with procedures.

Based on direct observation and review of records, the inspectors verified that the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, and Entergys procedures. The inspector verified that the meteorological data readout and recording instruments in the control room and at the tower were operable.

The inspectors verified that missed and or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors reviewed the licensees assessment of any positive sample results. The inspectors reviewed the associated radioactive effluent release data that was the source of the released material.

The inspectors selected SSCs that involved or could reasonably involve licensed material for which there is a credible mechanism for licensed material to reach groundwater, and verified that the Entergy had implemented a sampling and monitoring program sufficient to detect leakage of these SSCs to groundwater.

The inspectors verified that records, as required by 10 CFR 50.75(g), Reporting and Recordkeeping for Decommissioning Planning, of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner.

The inspectors reviewed any significant changes made by Entergy to the ODCM as the result of changes to the land census, long-term meteorological conditions (3-year average), or modifications to the sampler stations since the last inspection. The inspectors reviewed technical justifications for any changed sampling locations. The inspectors verified that the licensee performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.

The inspectors verified that the appropriate detection sensitivities with respect to TS/ODCM were used for counting samples. The inspectors reviewed quality control charts for maintaining radiation measurement instrument status and actions taken for degrading detector performance.

The inspectors reviewed the results of Entergys inter-laboratory comparison program to verify the adequacy of environmental sample analyses performed by Entergy. The inspectors verified that the inter-laboratory comparison test included the media/nuclide mix appropriate for the facility.

The inspectors verified that problems associated with the REMP are being identified by Entergy staff at an appropriate threshold and were properly addressed for resolution in Entergys corrective action program. The inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by Entergy staff that involved the REMP.

The inspectors reviewed CR-IP3-2012-01507, which identified elevated concentrations of radioisotopes in monitoring wells at Indian Point during quarterly sampling. The sampling took place in February 2012. Results for tritium ranged between 2000 pCi/liter to 7000 pCi/liter, which is below the EPA drinking water standard (NOTE: water from these wells is not drinking water). One well showed between 12.6 and 16.8 pCi/liter for cesium-137, slightly above the minimum detectable concentration of 9.17 pCi/liter. This spike in results appears to be the result of normal groundwater flow from areas of higher concentration upstream, and not due to any new source of groundwater contamination.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

Main article: IP 71151

a. Inspection Scope

The inspectors sampled Entergys submittals for the below listed performance indicators (PIs) for Unit 2 for the period of April 1, 2011, through March 31, 2012. To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." As applicable, the inspectors reviewed Entergys operator narrative logs, condition reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

Safety System Functional Failures (MS05)

Mitigating Systems Performance Indicator (MSPI) - Emergency AC Power System (MS06)

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergy entered issues into the corrective action program 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 corrective action program and periodically attended condition report screening meetings.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification 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 Entergy outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed Entergys corrective action program database for the third and fourth 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 4OA2.1). The inspectors reviewed the Entergy quarterly trend report for the fourth quarter of 2011, conducted under LO-IP3LO-2011-00173 to verify that Entergy personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings 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 maintenance and instrumentation and controls departments. This review included a sample of issues and events that occurred over the course of the past two quarters to 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 verified that these issues were addressed within the scope of the corrective action program, or through department review and documentation in the quarterly trend report for overall assessment. For example, the inspectors noted that consistent with the onset of additional safety-related control room ventilation fan failures that have occurred over the past several months, Entergy personnel had appropriately identified fan failure due to belts as a monitored trend with ongoing corrective actions to address this issue. In other cases, the inspectors verified for resolved trends, such as vendor oversight, that applicable success criteria was identified to ensure successful resolution of adverse trends had been appropriately dispositioned.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Main article: IP 71153

.1 Plant Events

a. Inspection Scope

For the plant event listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Entergy made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Entergys follow-up actions related to the event to assure that Entergy implemented appropriate corrective actions commensurate with their safety significance.

Main generator trip and subsequent reactor trip on June 6, 2012

b. Findings

No findings were identified.

.2 (Closed) LER 05000247/2011-003-00: Technical Specification (TS) Violation for Entry

into TS 3.0.3 for 3 Inoperable Fan Cooler Unit Trains and Failure to Correct Condition Within 1 Hour and Actions Taken for Plant Shutdown On October 3, 2011, at 3:45 am, during a quarterly surveillance test, all five fan cooler units (FCUs) failed to meet minimum flow requirements with the essential service water (SW) header supplied by the 22 and 23 SWPs. Operations personnel declared all three trains of FCUs inoperable in accordance with TS 3.6.6.F and entered TS 3.0.3. In accordance with TS 3.0.3, Entergy operators initiated actions at 4:38 am to place the plant in Mode 3 within seven hours. Operations personnel, at 04:43 am initiated a turbine load reduction by approximately 5 MWs and swapped the essential SW header to the other header, the 4/5/6 header. TS 3.0.3 action statement was exited at 5:32 am after recovery of SW flow to required values, and power ascension to full power was commenced at 5:54 am. Entergy staff determined that the direct cause of the event was excessive accumulation of silt or debris in the SW bay which resulted in a change to the SWP inlet conditions. Entergy determined the root cause of the event was ineffective barriers established to monitor and remove silt accumulations that would affect SWP net positive suction head margin. Specifically, Entergy staff determined that the monitoring plans could have been enhanced to include predictive elements that account for changing environmental conditions. Entergys corrective actions include: performing sonar mapping and de-silting of the SW bay to identify and remove silt accumulation impeding SWP performance, the sonar mapping frequency will be increased from a 2-year to a 3-month frequency, the SW system monitoring plan will be revised to include alert and action levels for silt buildup, a comprehensive silt monitoring and mitigation plan will be developed to include predictive trending and monitoring methods, to provide early indication of influences from natural events. Entergy staff entered this issue into the CAP as CR-IP2-2011-4894.

The inspectors did not identify a violation of TS 3.0.3 or related performance deficiencies. Specifically, the inspectors determined that Entergy operators implemented appropriate actions as prescribed by TS 3.6.6.F which directed entry into TS 3.0.3. The inspectors affirmed that Entergy personnel reported the condition consistent with guidance in NUREG-1022, Event Reporting Guidelines. This guidance indicates that if the condition that directed entry into TS 3.0.3 is not corrected in the first hour, the condition should be reported. This LER is closed.

.3 (Closed) LER 05000247/2012-001-00: Technical Specification (TS) Prohibited Condition

Caused by an Inoperable 23 Emergency Diesel Generator Fuel Oil Storage Tank Due to Fuel Oil Below TS Limit On February 8, 2012, during performance of a special log set up to verify 23 Fuel Oil Storage Tank (FOST) level during routine rounds and following completion of a diesel run, an operator discovered that the useable fuel oil in the tank was below the TS 3.8.3 required level. The special log was initiated after the tanks level indicator LI-1135 was declared inoperable on July 22, 2011. At the time the 23 FOST condition was identified, the tank had been inoperable for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , which is longer than the allowed outage time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Entergy staff entered this issue into the CAP as CR-IP2-2012-0821. Entergy staff determined the apparent cause was due to a lack of questioning attitude and understanding by operations watch personnel of out of service equipment (LI-1135) and the requirements of the special log in effect for LI-1135. Entergys corrective actions included coaching on managements expectations on the use of human performance tools, initiation of a shift order on requirements for hanging deficiency tags in the field, and update of the pre-job brief database.

The inspectors reviewed the LER and the associated apparent cause evaluation to verify Entergy staff adequately evaluated the TS violation and developed appropriate corrective actions. The enforcement aspects of this licensee-identified violation are discussed and documented in Section 4OA7. The inspectors did not identify any additional findings during the review of the LER. This LER is closed.

.4 (Closed) LER 05000247/2012-005-00: Technical Specification Prohibited Condition

Caused by a Main Steam Safety Valve Outside its As-Found Lift Setpoint Test Acceptance Criteria Due to Spring Skew/Spindle Wear On March 2, 2012, during the performance of surveillance procedure 2-PT-R006, main steam safety valve MS-46D failed its as-found lift setpoint pressure test. Valve MS-46D lifted at 1136.9 psig, 24.9 psig outside its acceptance range of 1048 to 1112 psig. TS 3.7.1, Main Steam Safety Valves, requires that MSSVs be operable in accordance with TS Table 3.7.1-1 and Table 3.7.1-2. MS-46D was declared inoperable since it lifted outside its acceptance range which resulted in the valve failing the as-found test.

Entergy staff entered this issue into the CAP as CR-IP2-2012-1311. Entergy staff determined the apparent cause was internal friction caused by spring skew and spindle wear. Entergys corrective actions included immediately adjusting the valve to within its operable limits and repairing the valve to within the TS operability setpoint band. In addition, Entergy plans to install a bronze wear sleeve along the inner diameter of the spindle contact points.

The inspectors identified a SL-IV NCV, as documented in Section 1R22 of this report.

The inspectors did not identify any additional findings during the review of the LER. This LER is closed.

4OA6 Meetings, Including Exit

On August 2, 2012, 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.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by Entergy and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as NCVs.

Technical Specification 3.8.3, Diesel Fuel Oil and Starting Air, requires, in part, that one diesel generator with usable fuel oil in its associated diesel generator fuel oil storage tank less than 6334 gallons, declare the associated diesel generator inoperable within two hours. Contrary to the above, on February 8, 2012, the 23 EDG fuel oil storage tank was inoperable for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months before the 23 EDG was declared inoperable by operators. Specifically, an operator did not use compensatory measure for a failed level indicator, to determine the 23 FOST level after a monthly test of the 23 EDG. Entergy staff entered this issue into the CAP as CR-IP2-2012-0821. Entergys corrective actions included coaching on managements expectations on use of human performance tools, initiation of a shift order on requirements for hanging deficiency tags in the field, and update of the pre-job brief database. This licensee-identified violation is associated with the Mitigating Systems Cornerstone. Using IMC 0609 Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined that this finding is of very low safety significance (Green) because the finding did not represent a loss of the emergency AC power system safety function and there was not an actual loss of the 23 EDG safety function.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Entergy Personnel

J. Ventosa, Site Vice President

R. Allen, Technical Specialist IV, Code Programs

N. Azevedo, Supervisor, Engineering

J. Baker, Shift Manager

T. Beasely, Engineering

M. Burney, Nuclear Safety/License IV Specialist

R. Burroni, Manager, System Engineering

T. Cole, Project Manager, NUC

P. Conroy, Director, Nuclear Safety Assurance

L. Cossio-Gonzalez, Engineer, Code Programs

L. Coyle, General Manager, Plant Operations

G. Dahl, Nuclear Safety/License IV Specialist

R. Daley, Engineer III, Nuclear

G. Dean, Shift Manager

D. Dewey, Assistant Operations Manager

J. Dinelli, Manager, Operations

R. Dolansky, Senior Lead Engineer

J. Doroski, Plant Chemistry

R. Drake, Supervisor, Engineering

E. Firth, Manager, Corrective Action

T. Flynn, Maintenance Inspection Coordinator

E. Goethicus, Operations Instructor

D. Gagnon, Manager, Security

F. Inzirillo, Manager, IPEC Quality Assurance

D. King, URS, NDE Project Manager

J. Kirkpatrick, Assistant Plant Manager

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

J. Lijoi, Superintendent, I&C

L. Lubrano, Senior Lead Engineer

R. Mages, Senior HP/Chemical Specialist

D. Mayer, Director, Unit 1

T. McCaffrey, Manager, Design Engineering

B. McCarthy, Assistant Operations Manager

J. Miu, Engineer, Programs and Components

N. Papaiya, Auditor, Quality Assurance

E. Primrose, Shift Manager

S. Prussman, Nuclear Safety/License IV Specialist

J. Reynolds, Work Week Manager

R. Robenstein, Superintendent, Simulator

T. Salentino, Superintendent, Dry Fuel Storage

S. Sandike, Senior HP/Chemical Specialist

A. Singer, Superintendent, Licensed Operator Requalification Training

D. Smith, Technical Specialist IV

B. Sullivan, Superintendent, Training-Nuc Ops

R. Tagliamonte, Manager, Radiation Protection

M. Tesoriero, Manager, Programs and Components

J. Thaliath, Engineer Ii, Nuclear

M. Troy, Manager, Engineering

R. Vogle, Senior Emergency Planner

R. Walpole, Manager, Licensing

D. Williams, Manager, Maintenance

M. Wilson, Manager, Emergency Planning

W. Wittich, Supervisor, Design Engineering

M. Woodby, Director, Engineering

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000247/2012-003-01 NCV Foreign Materials Control Procedure Not Followed Resulting in Degraded 21 Reactor Coolant Pump Seal Package (Section 1R12)

05000247/2012-003-02 NCV An LER for an Inoperable Main Steam Safety Valve Was Not Submitted When Required (Section 1R22)

Closed

05000247/2011-003-00 LER Technical Specification (TS) Violation for Entry into TS 3.0.3 for 3 Inoperable Fan Cooler Unit Trains and Failure to Correct Condition Within 1 Hour and Actions Taken for Plant Shutdown (4OA3)

05000247/2012-001-00 LER Technical Specification (TS) Prohibited Condition Caused by an Inoperable 23 Emergency Diesel Generator Fuel Oil Storage Tank Due to Fuel Oil Below TS Limit

05000247/2012-005-00 LER Technical Specification Prohibited Condition Caused by a Main Steam Safety Valve Outside its As-Found Lift Setpoint Test Acceptance Criteria Due to Spring Skew/Spindle Wear

LIST OF DOCUMENTS REVIEWED