IR 05000247/2017008

Problem Identification and Resolution Inspection Report 05000247/2017008 and 05000286/2017008

ML17303A739
Person / Time
Site:	Indian Point
Issue date:	10/27/2017
From:	Jon Greives Reactor Projects Branch 2
To:	Vitale A Entergy Nuclear Operations
Setzer T
References
IR 2017008
Download: ML17303A739 (16)

Text

October 27, 2017

SUBJECT:

INDIAN POINT NUCLEAR GENERATING - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000247/2017008 AND 05000286/2017008

Dear Mr. Vitale:

On October 5, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at Indian Point Nuclear Generating (Indian Point), Units 2 and 3. The NRC inspection team discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

In all of the areas reviewed, the NRC inspectors did not identify any findings or violations of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Jonathan E. Greives, Acting Chief Reactor Projects Branch 2 Division of Reactor Projects

Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

Enclosure:

Inspection Report 05000247/2017008 and 05000286/2017008 w/Attachment:

Supplementary Information

REGION I==

Docket Nos.

50-247 and 50-286

License Nos.

DPR-26 and DPR-64

Report Nos.

05000247/2017008 and 05000286/2017008

Licensee:

Entergy Nuclear Northeast (Entergy)

Facility:

Indian Point Nuclear Generating, Units 2 and 3

Location:

450 Broadway, General Services Building

Buchanan, NY 10511-0249

Dates:

September 18 - 22, 2017

October 2 - 5, 2017

Team Leader:

Thomas Setzer, PE, Senior Project Engineer

Inspectors:

Mark Draxton, Project Engineer

Chris Safouri, Project Engineer

Andrew Siwy, Resident Inspector

Approved by:

Jonathan E. Greives, Acting Chief

Reactor Projects Branch 2

Division of Reactor Projects

SUMMARY

IR 05000247/2017008 and 05000286/2017008; 09/18/2017 - 10/05/2017; Indian Point Nuclear

Generating; Biennial Baseline Inspection of Problem Identification and Resolution.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.

Problem Identification and Resolution

The inspectors concluded that Entergy was effective in identifying, evaluating, and resolving problems. Entergy personnel identified problems, entered them into the corrective action program (CAP) at a low threshold, and in general, prioritized issues commensurate with their safety significance. Entergy appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Entergy implemented corrective actions to address the problems identified in the CAP in a timely manner.

The inspectors concluded that Entergy adequately identified, reviewed, and applied relevant industry operating experience to Indian Point operations. In addition, based on those items selected for review, the inspectors determined that Entergys self-assessments and audits were thorough.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual CAP and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.

No findings were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described Entergys CAP at Indian Point.

To assess the effectiveness of the CAP, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, and Entergy procedure EN-LI-102, Corrective Action Program. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed CAP condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, fire protection, chemistry, physical security, maintenance rule, and oversight programs.

(1) Effectiveness of Problem Identification

In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems in both Units 2 and 3, which included the auxiliary feedwater, service water, circulating water, emergency diesel generator, charging, and safety injection systems. Additionally, the inspectors reviewed a sample of CAP condition reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Entergy entered conditions adverse to quality into their CAP as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues

The inspectors reviewed the evaluation and prioritization of a sample of CAP condition reports issued since the last NRC biennial problem identification and resolution inspection completed in January 2016. The inspectors also reviewed CAP condition reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution.

The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, licensee event reports, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues. Finally, the inspectors attended multiple condition report pre-screening meetings and Plant Review Group (PRG) meetings.

(3) Effectiveness of Corrective Actions

The inspectors reviewed Entergys completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CAP condition reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Entergys timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CAP condition reports associated with selected non-cited violations and findings to verify that Entergy personnel properly evaluated and resolved these issues.

In addition, the inspectors expanded the corrective action review to five years to evaluate Entergys actions related to the boric acid corrosion control program.

b. Assessment

(1) Effectiveness of Problem Identification

Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Entergy identified problems and entered them into the CAP at a low threshold. Entergy staff at Indian Point initiated approximately 19,000 CAP condition reports between January 2016 and September 2017. The inspectors observed supervisors at the PRG meetings appropriately questioning and challenging CAP condition reports to ensure clarification of the issues.

Based on the samples reviewed, the inspectors determined that Entergy trended equipment and programmatic issues, and appropriately identified problems in CAP condition reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the CAP as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels.

(2) Effectiveness of Prioritization and Evaluation of Issues

Based on the samples selected, the inspectors determined that, in general, Entergy appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Entergy screened CAP condition reports for operability and reportability, categorized the CAP condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The issue report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety-conscious work environment.

Based on the sample of CAP condition reports reviewed, the inspectors noted that the guidance provided by Entergy CAP implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were performed when conditions warranted and the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.

The inspectors identified two instances in which a condition report was not prioritized in accordance with the guidance in Entergy procedure EN-LI-102. Specifically, one condition report (IP3-2016-01694) associated with the 32 residual heat removal pump pressure indicator (PI-635) was improperly coded as a non-CAQ instead of an adverse quality CR. Additionally, another condition report (IP3-2017-02417)associated with a Unit 3 nitrogen supply regulator valve was closed by PRG as a CAT D to work order when it was required to be processed as a CAT C - evaluate. The inspectors determined that the prioritization of these two condition reports did not meet the guidance described in procedure EN-LI-102 and therefore was a performance deficiency. However, because these issues were ultimately corrected, were isolated cases, and did not indicate a programmatic weakness to properly prioritize condition reports, the inspectors determined that the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. Entergy documented the issues in condition reports IP3-2017-04613 and IP3-2017-04622.

The inspectors identified one instance in which Entergy did not evaluate foreign material that was left in a plant system. The inspectors reviewed condition report IP3-2017-01791, which described an engineering review of the preliminary report of eddy current testing for the 32 containment recirculation fan cooling coil. This report determined that one tube recorded in 2011 as having been plugged no longer had a plug installed.

Additionally, four tubes that in 2011 were recorded as having a damaged tube plug collar did not have any collar installed. Entergy concluded these parts were missing and must have been lost in the system. The inspectors noted that Entergy procedure EN-MA-118, Foreign Material Exclusion, Section 5.8 and Attachment 9.10, Dropped and Unrecovered Process Flow Chart, requires an evaluation be done for potential impacts to the system when foreign material is determined to be irretrievable. In this case, the condition report was closed with no documented evaluation of the missing parts.

The inspectors determined that the failure to perform an evaluation on the missing tube plug and collars did not meet the guidance in Entergy procedure EN-MA-118, and therefore was a performance deficiency. However, because the loose parts were later determined by Entergy to not have any adverse impacts upon the cooling coil or any downstream components, the inspectors determined that the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. Entergy documented the issue in condition report IP3-2017-04497.

The tubes were eddy current tested and were found with no tube damage and were not required to be re-plugged. Additionally, all the cooling coil tubes were flushed clean with water to verify the missing parts had not caused any blockage.

(3) Effectiveness of Corrective Actions

Based on the selected samples, the inspectors concluded that corrective actions for identified deficiencies were timely and adequately implemented. For significant conditions adverse to quality, Entergy identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective.

c. Findings

No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of CAP condition reports associated with review of industry operating experience to determine whether Entergy appropriately evaluated the operating experience information for applicability to Indian Point and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Entergy adequately considered the underlying problems associated with the issues for resolution via their CAP.

Assessment

The inspectors determined that Entergy appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable.

b. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the CAP, departmental self-assessments, and assessments performed by independent organizations. The inspectors performed these reviews to determine if Entergy entered problems identified through these assessments into the CAP, when appropriate, and whether Entergy initiated corrective actions to address identified deficiencies.

Assessment

The inspectors concluded that self-assessments, audits, and other internal Entergy assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Entergy personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Entergy completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the CAP for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.

b. Findings

No findings were identified.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety-conscious work environment at Indian Point. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.

The inspectors reviewed the Employee Concerns Program files to ensure that Entergy entered issues into the CAP when appropriate.

Assessment

During interviews, Indian Point staff expressed a willingness to use the CAP to identify plant issues and deficiencies and stated that they were willing to raise safety issues.

The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the CAP and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety-conscious work environment and no significant challenges to the free flow of information.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On October 5, 2017, the inspectors presented the inspection results to Mr. A. Vitale, Site Vice President, and other members of the Indian Point staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

A. Vitale, Site Vice President

V. Andreozzi, Manager, Systems and Components

J. Breban, Security Supervisor

C. Bristol, Maintenance

J. Bubniak, Senior Engineer

M. Burney, Engineering

D. Candela, Engineer

G. Carbone, Radiation Protection Specialist

N. Chase, Unit Two Control Room Operator

J. DAntono, Engineer

L. Eagens, Chemistry Departmental Performance Improvement Coordinator

J. Ferrick, Director of Engineering

J. Fogarty, Performance Improvement Specialist

E. Graven, Engineer 1, Boric Acid Corrosion Control Program Lead

T. Iavicoli, Sr Radiation Protection Specialist and Departmental Performance Improvement

Coordinator

T.R. Jones, Licensing

J. Kirkpatrick, General Manager of Plant Operations

M. Lewis, Senior Manager, Operations

L. Lubrano, Senior Lead Engineer

D. Main, Operations Departmental Performance Improvement Coordinator

N. Malazzo, Engineer 2, Boric Acid Corrosion Control Program Lead

B. McCarthy, Director, Regulatory Assurance and Performance Improvement Director

T. OConnor, Senior Engineer

E. Portanova, Engineer

T. Thivierge, Security Supervisor

S. Torres, Sr Operational Specialist

M. Troy, Engineering Programs Supervisor

M. Tumicki, Performance Improvement

R. Walpole, Manager, Regulatory Assurance

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

None