IR 05000247/2019004

Integrated Inspection Report 05000247/2019004 and 05000286/2019004

ML20042E476
Person / Time
Site:	Indian Point
Issue date:	02/10/2020
From:	Daniel Schroeder Reactor Projects Branch 2
To:	Vitale A Entergy Nuclear Operations
Schroeder D
References
IR 2019004
Download: ML20042E476 (23)

Text

ary 10, 2020

SUBJECT:

INDIAN POINT ENERGY CENTER, UNITS 2 AND 3 - INTEGRATED INSPECTION REPORT 05000247/2019004 AND 05000286/2019004

Dear Mr. Vitale:

On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Energy Center, Units 2 and 3. On January 27, 2020, the NRC inspectors 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.

No findings or violations of more than minor significance were identified during this inspection.

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 at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000247 and 05000286 License Nos. DPR-26 and DPR-64

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000247 and 05000286 License Numbers: DPR-26 and DPR-64 Report Numbers: 05000247/2019004 and 05000286/2019004 Enterprise Identifier: I-2019-004-0041 Licensee: Entergy Nuclear Operations, Inc.

Facility: Indian Point Energy Center, Units 2 and 3 Location: 450 Broadway, Generation Support Building Buchanan, NY 10511-0249 Inspection Dates: October 1, 2019, to December 31, 2019 Inspectors: B. Haagensen, Senior Resident Inspector A. Siwy, Resident Inspector J. Vazquez, Resident Inspector T. Hedigan, Operations Engineer M. Patel, Operations Engineer P. Ott, Operations Engineer S. Wilson, Health Physicist Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Indian Point Energy Center, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.

Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

PLANT STATUS

Unit 2 began the inspection period at rated thermal power. On December 14, 2019, Unit 2 reduced power to 95 percent in response to a loss of condenser vacuum due to removal of the 21 condenser bay from service. Unit 2 was returned to rated thermal power on December 17, 2019. On December 18, 2019, Unit 2 reduced power to 60 percent due to a feedwater leak.

The unit was returned to rated thermal power on December 20, 2019, and remained at or near rated thermal power for the remainder of the inspection period.

Unit 3 began the inspection period at rated thermal power. On October 1, 2019, Unit 3 reduced power to 95 percent for turbine valve testing and subsequent repairs. Unit 3 was returned to rated thermal power on October 3, 2019. Unit 3 remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection Seasonal Extreme Weather Sample (IP Section 03.02)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:

• Unit 2 auxiliary feedwater system

• Unit 3 primary auxiliary building heating and ventilation system

Impending Severe Weather Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated readiness for impending adverse weather conditions for a high wind warning at Units 2 and 3 on October 17, 2019.

External Flooding Sample (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated readiness to cope with external flooding using Operating Experience Smart Sample (OpESS) 2007-02, Revision 3, for the following areas:

• Unit 2 primary auxiliary building

• Unit 2 switchyard and 480 volt switchgear room

• Unit 2 turbine building

• Unit 3 primary auxiliary building

• Unit 3 switchyard and 480 volt switchgear room

• Unit 3 turbine building

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Service water pump piping and supports at Unit 3 on October 25, 2019

(2) 31 and 33 emergency diesel generators (EDGs) during maintenance on the 32 EDG at Unit 3 on October 28, 2019

(3) 32 auxiliary feedwater pump during maintenance on the 33 auxiliary feedwater pump at Unit 3 on October 30, 2019

(4) 33 charging pump during maintenance on the 31 and 32 charging pumps at Unit 3 on November 22, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Primary auxiliary building, general floor plan, 80-foot elevation (pre-fire plan (PFP)-211), at Unit 2 on October 21, 2019

(2) Primary auxiliary building, general floor plan, 98-foot elevation (PFP-212), at Unit 2 on October 21, 2019

(3) Diesel fire pump house (PFP-265) at Unit 2 on November 1, 2019

(4) Auxiliary feedwater building, all elevations (PFP-259, PFP-260, PFP-261, and PFP-262), at Unit 2 on November 1, 2019

(5) Control building, battery rooms (PFP-252A), at Unit 2 on November 25, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 2 480 volt vital switchgear room on December 4, 2019

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance Requalification Examination Results (IP Section 03.03)

(1) The inspectors reviewed and evaluated requalification examination results at Unit 2 (biennial written and annual operating exams), which were completed on December 9, 2019.

(2) The inspectors reviewed and evaluated requalification examination results at Unit 3 (biennial written and annual operating exams), which were completed on December 9, 2019.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance Unit 3 Licensed Operator Requalification Program (IP Section 03.04)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered December 9, 2019.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by Title 10 of the Code of Federal Regulations (10 CFR) 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1) The inspectors observed and evaluated licensed operator performance in the control room during main turbine generator stop and control valve testing at Unit 3 on October 1, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the simulator during control room evacuation and alternate safe shutdown (OpE Smart Sample 2012-02) at Unit 2 on November 21, 2019.

(2) The inspectors observed and evaluated licensed operator performance in the simulator during an emergency planning drill at Unit 3 on November 21, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Containment equipment hatch closure plug maintenance rule scoping assessment at Unit 3 on November 13, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Elevated risk during 31 EDG maintenance concurrent with 35 service water pump maintenance at Unit 3 on October 7, 2019

(2) Emergent yellow risk during 22 EDG testing with concurrent high-wind conditions at Unit 2 on October 17, 2019

(3) Emergent risk for 33 battery charger after removal from service due to erratic voltage output at Unit 3 on October 23, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) (CR-IP2-2019-04264) 22 EDG breaker initially failed to close during monthly test at Unit 2 on October 17, 2019 (2) (CR-IP3-2019-03698) 33 battery charger erratic voltage output at Unit 3 on October 23, 2019

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 2 EC-81092, permanent modification to multi-purpose canister 439 lid lift plug repairs

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) 2-PT-Q013-DS149, PCV-1190, PCV-1191, PCV1192, SOV-1279, and SOV-1280 inservice testing data sheet after replacement of actuator switch for PCV-1190 (containment pressure relief valve) at Unit 2 on November 20, 2019

(2) 3-PT-M097C, 33 EDG functional test after petcock and filter replacement at Unit 3 on December 5, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) 3-PT-R201C, 33 station battery charger functional test at Unit 3 on October 24, 2019

(2) 2-PT-M021C, EDG 23 load test at Unit 2 on November 20, 2019

(3) 2-PT-Q56A and 2-PT-Q56B, 6.9kV under-voltage and under-frequency relays trip actuating device tests at Unit 2 on December 4, 2019

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) 0-SOP-LEAKRATE-001, reactor coolant system leak rate evaluation at Unit 3 on December 15, 2019

71114.06 - Drill Evaluation Drill/Training Evolution Observation (IP Section 03.02)

The inspectors evaluated:

(1) Conduct of a routine emergency preparedness drill at Unit 2 on November 20,

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment Walk Downs and Observations (IP Section 02.01)

The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:

(1)

• Liquid radwaste treatment system at Units 1 and 2

• Liquid radwaste treatment system at Unit 3

• Fuel storage building ventilation system and exhaust fan

• Control room envelope ventilation and filtration Calibration and Testing Program (Process and Effluent Monitors) (IP Section 02.02) (1 Sample)

The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:

(1)

• Unit 3 wide range gas monitor R-27 channel calibration completed December 9, 2017

• Unit 3 wide range gas monitor R-27 channel functional test April 30, 2019

• Unit 3 waste gas effluent radiation monitor R-20 calibration completed March 1, 2018

• Unit 3 waste gas effluent radiation monitor R-20 channel functional test completed December 11, 2018

• Unit 2 liquid effluent radiation monitor R-49 channel functional test completed July 12, 2017

• Unit 2 liquid effluent radiation monitor R-54 calibration completed February 1, 2018

• Unit 3 steam generator blowdown radiation monitor R-19 calibration completed June 15, 2018

• Unit 2 liquid effluent radiation monitor R-54 channel functional test completed November 16, 2018

• Unit 2 liquid effluent radiation monitor R-54 channel functional test completed February 8, 2019

Sampling and Analysis (IP Section 02.03) (1 Sample)

The inspectors reviewed the following:

(1) Radioactive Effluent Sampling and Analysis Activities

• Demonstration of remote vapor containment gaseous sampling

• Demonstration of vapor containment gaseous sample analysis

Instrumentation and Equipment (IP Section 02.04) (1 Sample)

The inspectors reviewed the following radioactive effluent discharge system surveillance test results:

(1)

• Unit 2 control room envelope inleakage testing report dated October 1, 2017

• Unit 3 control room envelope inleakage testing report dated December 14, 2018

Dose Calculations (IP Section 02.05) (1 Sample)

The inspectors reviewed the following to asses public dose:

(1) Liquid and Gaseous Discharge Permits

• Unit 2 vapor containment pressure relief release gaseous permit 190136 dated August 26, 2019

• Unit 3 vapor containment pressure relief release gaseous permit 190064 dated August 14, 2019

• Units 1 and 2 liquid radioactive waste release permit 190020 dated August 14, 2019

• Unit 3 liquid radioactive waste release permit 190090 dated August 29, 2019 Abnormal Gaseous or Liquid Tank Discharges

• The inspectors verified the licensee's method of evaluating abnormal releases. The inspectors determined that the licensee's evaluations satisfied the survey requirements of 10 CFR 20.1501.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Radioactive Material Storage (IP Section 02.01)

The inspectors evaluated radioactive material storage.

(1) The inspectors toured the radioactive material storage locations within the owner-controlled area and performed container integrity observations as well as dose-rate and inventory verification surveys.

Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)

The inspectors evaluated the following radioactive waste processing systems and processes during plant walkdowns:

(1) Liquid or Solid Radioactive Waste Processing Systems

• Units 1 and 2 liquid radioactive waste processing systems

• Unit 3 liquid radioactive waste processing system

• Solid waste and dry active waste storage areas for Units 1, 2, and 3. Solid waste and dry active waste was sent offsite to a vendor for processing.

Radioactive Waste Resin and/or Sludge Discharges Processes

• Units 1 and 2 radioactive waste processing

• Unit 3 radioactive waste processing system Waste Characterization and Classification (IP Section 02.03) (1 Sample)

The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:

(1)

• Radioactive waste shipment number 18-177, spent resin, waste class B, Type B container, dated October 22, 2018

• Radioactive waste shipment number 18-167, spent resin, waste class B, Type B container, dated October 22, 2018

• Radioactive waste shipment number 19-153, spent resin, waste class B, Type B container, dated September 30, 2019

Shipment Preparation (IP Section 02.04) (1 Sample)

The inspectors evaluated the following radioactive material shipment preparation processes:

(1) Two package receipt surveys were observed. One package contained calibrated tools and equipment and one contained contaminated underwater tooling.

Shipping Records (IP Section 02.05) (1 Sample)

The inspectors evaluated the following non-excepted package shipment records:

(1)

• Radioactive waste shipment number 18-177, spent resin, waste class B, Type B container, dated October 22, 2018

• Radioactive waste shipment number 18-167, spent resin, waste class B, Type B container, dated October 22, 2018

• Radioactive waste shipment number 19-153, spent resin, waste class B, Type B container, dated September 30,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

(1) Unit 2 (October 1, 2018, through September 30, 2019)

(2) Unit 3 (October 1, 2018, through September 30, 2019)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

The inspectors verified that the occupational exposure control effectiveness performance indicator was accurately reported.

(1) The inspectors reviewed the performance indicator reports for October 1, 2018, to September 30, 2019.

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

The inspectors verified the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences performance indicator was accurately reported.

(1) The inspectors reviewed the performance indicator reports for October 1, 2018, to September 30, 2019.

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

(1) The inspectors reviewed the corrective maintenance backlog, control room deficiency tags, open operability evaluations, and operator workarounds over the past six months at Units 2 and 3.

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Maintenance rule monitoring status for all maintenance rule systems including any rescheduled corrective actions and verification of systems for follow up actions at Units 2 and 3

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated a leak on the 21 component cooling water heat exchanger service water inlet line at Unit 2 and the licensees response on November 6, 2019.

(2) The inspectors evaluated a leak in the 22 main feedwater pump casing vent line, an unplanned power reduction to 60 percent, and licensees response at Unit 2 on December 18 and 19,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

92702 CONF - Enforcement Related Order Follow-Up-Only Enforcement Related Order Follow-Up-Only

(1) Verify Grand Gulf Confirmatory Order EA-17-132/153 Commitments (ML18072A191)

• Element B: Verified the Site Vice President and Plant General Manager communicated a balanced message to all workers at Indian Point regarding the circumstances leading to the confirmatory order, that willful actions will not be tolerated, and that Entergy will be undertaking efforts to confirm whether others are engaging in such conduct at Indian Point in April 2018.

• Element C: Verified Entergy performed an evaluation at Indian Point that was used to inform the Entergy Headquarters causal evaluation for the performance deficiencies identified in the confirmatory order in August 2018.

• Elements H and I: Verified Entergy conducted an organizational health survey at Indian Point in 2018 and 2019.

• Element B: Verified Entergy conducted semi-annual training (in May and November) for all Indian Point workers in 2018 and 2019 emphasizing that willfulness will not be tolerated.

• Element D: Verified Entergy completed annual effectiveness reviews at Indian Point in 2018 and 2019.

92709 - Licensee Strike Contingency Plans Licensee Strike Contingency Plans

(1) On October 1, 2019, at midnight, the labor contract expired between Entergy and the Teamsters Union for the security guard force. In preparation for a potential strike or lockout during the extended period of negotiations, the NRC inspectors evaluated the adequacy of the licensees contingency plan. The inspectors assessed the adequacy of the plan's post strike staffing levels, staff qualifications, safety conscious working environment, and site access in meeting operational and security requirements. No strike occurred. Security contract negotiations were completed on October 6, 2019, and the Teamsters Union membership ratified the new contract on October 29,

INSPECTION RESULTS

Observation: Semiannual Trend Analysis of Corrective Maintenance Backlog, 71152 Control Room Deficiencies, Open Operability Evaluations, and Operator Workarounds The inspectors reviewed and assessed the corrective maintenance backlog, control room deficiency tags, open operability evaluations, and operator workarounds for trends from May 1 to November 15, 2019. No adverse trends were noted.

Corrective maintenance backlog: The current corrective maintenance backlog is relatively small, and out of service equipment is being promptly repaired. The total maintenance backlog has been reduced by 82 percent since the start of 2019 and is 20 percent down from the last quarter. Entergy continues to repair equipment and reduce the historic maintenance backlog from past periods. There are no corrective-critical maintenance items in the backlog.

Control room deficiencies: There are a total of five control room deficiencies, one in Unit 2 and four in Unit 3. This represents a very small net increase of one deficiency over a six-month period of performance. Indian Point is effectively managing the backlog of control room deficiencies. None of the control room deficiencies were safety-significant.

Open operability evaluations: As of November 15, 2019 (date of sample completion), there were eight operability evaluations for equipment that is considered operable but degraded or non-conforming (OP-DNC) in the Entergy condition reporting system. These included:

• CR-IP3-2019-01335 - Unit 3 baffle bolt structure is degraded.

• CR-IP2-2018-02127 - Unit 2 baffle bolt structure is degraded.

• CR-IP2-2018-01697 - Stud 20 stuck in reactor pressure vessel.

• CR-IP2-2016-04959 - Spent fuel pit Boraflex - RAKLIFE software under-predicts the degradation in the Boraflex panels.

• CR-IP2-2014-04414 - Spent fuel pit Boraflex panels have degraded and the technical specifications are non-conservative.

• CR-IP2-2012-06255 - Unit 2 turbine building high-energy line break effects 480 volt switchgear.

• CR-IP3-2012-03262 - Unit 3 turbine building high-energy line break affects 480 volt switchgear.

• CR-IP2-2009-05175 - 23 EDG flex coupling is degraded - NOTE: This condition was corrected in 2009 and should no longer be listed as OP-DNC.

The OP-DNC condition reports for spent fuel pool Boraflex RAKLIFE software (CR-IP2-2016-06255) and non-conservative technical specifications (CR-IP2-2014-04414)were subsequently corrected by the implementation of a licensing amendment that was implemented prior to the end of the quarter and this condition report was corrected and closed. None of the OP-DNC components are significant safety risks.

There are four additional operability evaluations that were statused as requiring compensatory measures to re-establish operability (OP-COMP MEAS).

• CR-IP3-2009-04819 - 33 EDG jacket water pressure switch failed to close. Implemented a standing order to verify jacket water pressure switch is closed following EDG monthly test. This verification was subsequently incorporated into a procedure.

• CR-IP3-2009-04502 - 33 EDG auxiliaries - pre-lube pump was not running - special log implemented to monitor jacket water temperature every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

NOTE: EC-18677 was installed and no compensatory measures are currently required to establish operability. The operability evaluation status was not updated to show operable status.

• CR-IP2-2009-00027 - 22 EDG pre-lube pump failed - NOTE: This condition was corrected in 2009 but the operability evaluation status was not updated to show operable status.

• CR-IP3-2007-03630 - SWN-38 leak - NOTE: This condition was corrected in 2007 but the operability determination was not revised to show operable status.

The last three condition reports that had categorized the conditions as "OP-COMP MEAS" had been previously corrected. The operability evaluation status had not been updated to reflect the repairs.

Entergy's decision not to maintain up-to-date and accurate records regarding the present status of operability determinations within the corrective action process makes it difficult to determine the current status of safety-related equipment that is inoperable, operable but degraded, or operable with compensatory measures. However, there is no regulatory requirement to maintain an up-to-date status of operability evaluations in the corrective action process and Entergys procedure does not require the operability status to be updated after operability has been reestablished.

Operator workarounds: There are no operator workarounds or operator burdens on either unit.

Entergy is continuing to operate both units safely and correct any safety-significant problems as they occur. No adverse trends were identified for corrective maintenance backlog, control room deficiency tags, open operability evaluations, and operator workarounds.

Observation: Review of Maintenance Rule Systems 71152 The inspectors reviewed the licensees monitoring of maintenance rule systems in accordance with 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants maintenance rule systems. The inspectors reviewed systems in monitoring status or near monitoring status and reviewed the associated actions. The inspectors verified that the systems are being monitored appropriately.

Observation: Verification of Confirmatory Order EA-17-132/153 92702 CONF The inspectors verified the corrective actions committed to in Alternate Dispute Resolution (ADR) Confirmatory Order (CO) EA-17-132/153 for 2018 and 2019. These actions included:

• ADR CO Element B: Communications: Training was conducted as required by confirmatory order for 2018 and 2019:

o All supervisors and above completed integrity training at Indian Point, which addressed the requirements of 10 CFR 50.5, 10 CFR 50.7, and 10 CFR 50.9 in 2018.

o A computer-based-training course was created in plateau entitled "Entergy Nuclear Employee Integrity Expectations." This computer-based training was completed by all Indian Point personnel in 2019.

o Entergy provided tier-2 communication via the web training access program to all employees and long-term contractors. 100 percent of all personnel completed this training in April 2019.

o Indian Point conducted semi-annual refresher training for all Indian Point workers that emphasized willful misconduct will not be tolerated at Indian Point in 2019.

• ADR CO Element C: A causal evaluation was completed in July 2018 by Entergy Headquarters staff that determined the root and contributing causes to determine why prior fleet-wide corrective actions from previous confirmatory orders and willful violations issued after January 2009 were not successful in preventing or minimizing instances of willful misconduct across the fleet. The results and lessons learned from this analysis were shared at Indian Point.

• ADR CO Elements H and I: An organization health survey was conducted in March 2019 for all station personnel that provided insights into the organizational health at Indian Point. The survey results showed a generally improving trend overall.

• ADR CO Element D: Entergy completed all required effectiveness reviews for corrective actions in 2018 and 2019 at Indian Point.

o The 2018 interim effectiveness review concluded that two measures were assessed as effective and one measure was ineffective. Corrective actions were taken to address the ineffective measure.

o The 2019 effectiveness reviews reported (ML19364A214) that:

Entergy concluded the results of the fleet-wide effectiveness reviews of the corrective actions to prevent recurrence were not effective in preventing or minimizing instances of willful misconduct across the fleet. Entergy revised the corrective actions to address the cause(s) of ineffectiveness. This conclusion was not identified as being specific to Indian Point.

Entergy also concluded "An Effectiveness Review completed in October 2019, for the fleet root cause addressing why, from 2015-2017, there have been multiple instances in which site personnel violated integrity standards found training audits effective based on the revision and implementation of the procedure as intended. However, the effectiveness review was rated indeterminate based on a recurrence of proctor misconduct occurring after the effectiveness review period was identified. This was corrected by conducting a confidential investigation and internal cause evaluation associated with the proctor misconduct and revising the root cause to add a follow-on effectiveness review in 2020."

o The inspectors concluded that integrity concerns identified at Indian Point were not pervasive within the IPEC workforce and did not significantly impact plant safety.

The inspectors concluded that Indian Point was complying with the requirements of Confirmatory Order EA-17-132/153 in 2018 and

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 27, 2020, the inspectors presented the integrated inspection results to Anthony J. Vitale, Site Vice President, and other members of the licensee staff.

• On December 12, 2019, the inspectors presented the radioactive gas and liquid treatment inspection results to Robert Walpole, Regulatory Assurance and Performance Improvement Director, and other members of the licensee staff.

THIRD PARTY REVIEWS The inspectors reviewed Institute on Nuclear Power Operations reports that were issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Date

Procedure

71111.01 Corrective Action CR-IP2-2019-04267, CR-IP2-2019-04308, CR-IP2-2019-

Documents 04595, CR-IP2-2019-04863, CR-IP3-2019-03922

71111.01 Corrective Action CR-IP2-2019-04281

Documents

Resulting from

Inspection

71111.01 Miscellaneous IP-RPT-12-00036 IP2 Flooding Walkdown Submittal Report for Resolution of November 27,

Fukushima Near-Term Task Force Recommendation 2.3: 2012

Flooding License Amendment Request LAR-2017-000095,

CA4

71111.01 Miscellaneous ML14119A973 Flooding Walkdown Report - Entergy's Response to NRC June 18, 2014

Request for Information Pursuant to 10 CFR 50.54(f)

Regarding the Flooding Aspects of Recommendation 2.3 of

the Near-Term Task Force Review of Insights from the

Fukushima Dai-Ichi Accident Indian Point Unit No. 2, Docket

No. 50-247, License No. DPR-26

71111.01 Miscellaneous NUREG 1437, Generic Environmental Impact Statement for License Revision 5

Supplement 38 Renewal of Nuclear Power Plants, Regarding Indian Point

Nuclear Generating Station

71111.01 Procedures 0-MET-402-GEN Location of Sandbags in Flood Warning Conditions Revision 5

71111.01 Procedures 0-SOP-WEATHER-001 Seasonal Weather Preparation Revision 7

71111.01 Procedures 0-SOP-WEATHER-002 Severe Weather Preparations Revision 1

71111.01 Procedures 2-AOP-FLOOD-1 Flooding Revision 12

71111.01 Procedures 2-COL-30.1 Electric Heat Tracing Revision 34

71111.01 Procedures 2-SOP-11.5 Space Heating and Winterization Revision 39

71111.01 Procedures 3-AOP-FLOOD-1 Flooding Revision 11

71111.01 Procedures EN-WM-100 Work Request, Generation, Screening, and Classification Revision 15

71111.04Q Calculations IP-CALC-12-00045 Stress Analysis of Service Water Line 1081 Due to Removal Revision 0

of Pipe Support SWN-H&R-1081-6-R

71111.04Q Calculations IP-CALC-19-00013 Stress Analysis of Service Water Line 1082 Due to Removal Revision 0

of Pipe Support SWN-H&R-1082-6-R

71111.04Q Corrective Action CR-IP3-2019-03533

Documents

71111.04Q Corrective Action CR-IP3-2019-03719, CR-IP3-2019-03729, CR-IP3-2019-

Documents 03732, CR-IP3-2019-03756, CR-IP3-2019-03930, CR-IP3-

Resulting from 2019-03932

Inspection

71111.04Q Drawings 9321-F-27223 Flow Diagram - Service Water System, Nuclear Steam Revision 55

Supply Plant

71111.04Q Drawings 9321-F-27363 (FSAR) Flow Diagram Chemical and Volume Control Revision 55

System SH 1

71111.04Q Procedures 3-COL-CVCS-001 Chemical and Volume Control System Revision 34

71111.04Q Procedures 3-COL-EL-005 Diesel Generators Revision 40

71111.04Q Procedures 3-COL-RW-002 Service Water System Revision 52

71111.05Q Corrective Action CR-IP2-2019-04337

Documents

Resulting from

Inspection

71111.06 Miscellaneous Generic Letter 89-18 Resolution of Unresolved Safety Issue A-17, "Systems September 6,

Interactions in Nuclear Power Plants" 1989

71111.06 Miscellaneous IP-RPT-04-00230 Indian Point Unit 2 Probabilistic Safety Assessment (PSA) Revision 1

71111.06 Miscellaneous NEA 06-028 Interoffice IP2 Closeout of EDG Flooding CR-IP2-2005-04868-CA-8 March 29, 2006

Memo

71111.11Q Procedures 0-OSP-TG-001 Main Turbine Stop and Control Valve Contingency Actions Revision 1

71111.11Q Procedures 2-AOP-SSD-1 Control Room Inaccessibility Safe Shutdown Control Revision 29

71111.11Q Procedures 2-SOP-27.6 Unit 2 Appendix R Diesel Generator Operations Revision 18

71111.11Q Procedures 3-POP-2.1 Operation at Greater than 45% Power Revision 69

71111.11Q Procedures 3-PT-SA045 Main Turbine Stop and Control Valves Exercise Test Revision 7

71111.11Q Procedures I0LP-LOR-AOP010 Unit 2 / Unit 3 Field Activities Revision 3

71111.12 Calculations IP3-CALC-RCS-000917 General Model for Loss of RHR with the Reactor Shut Down Revision 2

71111.12 Engineering EC-17512 Installation of IP2 Equipment Hatch Closure Plug Revision 0

Changes

71111.12 Miscellaneous NSE 96-3-463 VC Installation of an Outage Equipment Hatch in Containment Revision 2

71111.12 Procedures 3-AOP-RHR-1 Loss of RHR Revision 12

71111.12 Procedures EN-DC-204 Maintenance Rule Scope and Basis Revision 4

71111.13 Corrective Action CR-IP2-2019-03521, CR-IP2-2019-04298

Documents

Resulting from

Inspection

71111.13 Miscellaneous Unit 3 Operators Risk Report for October 18, 2019

71111.13 Miscellaneous Unit 2 EOOS On-line Risk Report October 23,

2019

71111.13 Procedures EN-OP-119 Protected Equipment Postings Revision 11

71111.13 Procedures EN-WM-104 On Line Risk Assessment Revision 21

71111.15 Corrective Action CR-IP2-2019-04264, CR-IP2-2019-04298

Documents

71111.15 Operability CR-IP3-2019-03698 Operability Determination, 33 Battery Charger October 24,

Evaluations 2019

71111.15 Procedures 2-PT-M21B Emergency Diesel Generator 22 Load Test Revision 34

71111.15 Procedures 3-PT-R201-C 33 Station Battery Charger Functional Test Revision 0

71111.15 Work Orders WO 00532946

71111.18 Engineering EC-81092 MPC Lid Plug Repair, (MPC-32 S/N 439) Revision 0

Changes

71111.18 Procedures EN-OP-116 Attachment 3, IPTE Supplemental Controls, MPC #439 Lid September 26,

Plug Removal 2019

71111.18 Procedures HPP-2848-100R1 Holtec Procedure HPP-2848-100R1 Revision 1

71111.19 Corrective Action CR-IP2-2019-04766, CR-IP3-2019-04071, CR-IP3-2019-

Documents 04084, CR-IP3-2019-04085, CR-IP3-2019-04099

71111.19 Corrective Action CR-IP3-2019-04068, CR-IP3-2019-04086

Documents

Resulting from

Inspection

71111.19 Drawings 9321-F-27223 Flow Diagram, Service Water System, Nuclear Steam Revision 54

Supply Plant

71111.19 Procedures 2-PT-Q013-DS149 PCV-1190, PCV-1191, PCV1192, SOV-1279, and SOV- Revision 30

280 IST Data Sheet

71111.19 Work Orders WO 00503471

71111.19 Work Orders WO 00530870

71111.19 Work Orders WO 52789881

71111.19 Work Orders WO 52797129

71111.19 Work Orders WO 52798880

71111.19 Work Orders WO 52905688

71111.22 Miscellaneous RCS Leak Rate Evaluation December 15,

2019

71111.22 Procedures 0-SOP-LEAKRATE-001 RCS Leakrate Surveillance, Evaluation, and Leak Revision 6

Identification

71111.22 Procedures 2-PT-M-021C Emergency Diesel Generator 23 Load Test Revision 30

71111.22 Procedures 3-IC-PM-I-E-33BC No. 33 Battery Charger Preventive Maintenance Revision 6

71111.22 Procedures 3-PT-R201C 33 Station Battery Charger Functional Test Revision 0

71111.22 Work Orders WO 00053310

71111.22 Work Orders WO 52903861-01

71124.06 Miscellaneous NL-19-039 Indian Point Nuclear Generating Units 1, 2, and 3 2018 April 23, 2019

Annual Radiological Effluent Release Report

71124.08 Corrective Action CR-IP2-2018-00334, CR-IP2-2018-00882, CR-IP2-2019-

Documents 4923

71124.08 Miscellaneous IP2 UFSAR UPDATE Unit 2 Updated Final Safety Analysis Report, Chapter 11 Revision 20

71124.08 Procedures 2-SOP-5.1.8 Unit 2 Liquid Waste Process System Operation October 31,

2019

71124.08 Procedures EN-RP-121 Radioactive Material Control Revision 16

71124.08 Procedures EN-RW-102 Radioactive Shipping Procedure Revision 17

71124.08 Radiation Unit 2 DAW 2018 L76234 10 CFR Part 61 Waste Stream Sample Screening and March 18, 2018

Surveys Evaluation

71124.08 Radiation Unit 2 SRST Resin 208 10 CFR Part 61 Waste Stream Sample Screening and March 18, 2018

Surveys L76234 Evaluation

71124.08 Radiation Unit 3 SRST Resin 10 CFR Part 61 Waste Stream Sample Screening and March 12, 2019

Surveys Evaluation

71151 Miscellaneous NRC Performance Indicator Technique/Data Sheets for the

Period of October 1, 2018, through September 30, 2019

71151 Procedures EN-LI-114 Regulatory Performance Indicator Process Revision 17

71152 Corrective Action CR-IP3-2007-03630, CR-IP2-2009-00027, CR-IP2-2009-

Documents 05175, CR-IP3-2009-04502, CR-IP3-2009-04819, CR-IP2-

2012-06255, CR-IP3-2012-03262, CR-IP2-2014-04414, CR-

IP2-2016-04959, CR-IP2-2018-01697, CR-IP2-2018-02127,

CR-IP3-2019-01335

71152 Procedures Standardized Operations Metrics Revision 5

71152 Procedures EN-LI-102 Corrective Action Program Revision 38

71152 Procedures EN-OP-104 Operability Determination Process Revision 16

71153 Corrective Action CR-IP2-2019-04593, CR-IP2-2019-05110

Documents

71153 Miscellaneous ASME Code Case N-666 On-Line Repair of Socket Weld Leakage Technical Update Revision 2

71153 Miscellaneous EPRI TR-108132 On-Line Welding Repair for Leaking Pipe Components January 1998

71153 NDE Reports Weld Map 00536618-08- 22 Main Boiler Feed Pump Casing Vent Line 559 Revision 0

71153 Procedures 2-POP-2.1 Plant Operation at Greater Than 45% Power Revision 66

71153 Procedures 2-SOP-21.1 Main Feedwater System Revision 67

71153 Procedures EN-OP-103 Operability Determination Process Revision 16

71153 Work Orders WO 00536618

2702 Corrective Action CR-HQN-2017-1968, CR-HQN-2018-0578

CONF Documents

2702 Corrective Action CR-HQN-2018-1210 Ineffective Actions on Willful Misconduct March 12, 2018

CONF Documents Root Cause Evaluation

2702 Miscellaneous 2019 OHI Indian Point Organizational Health Survey, 2019 July, 2019

CONF

2702 Miscellaneous CNRO-2019-00030 Entergy Response to Confirmatory Order EA-17-132/EA-17- December 30,

CONF (ML19364A214) 153, Element K 2019 Summary 2019

2702 Miscellaneous EA 17-132/153 Grand Gulf Confirmatory Order March 12, 2018

CONF (ML18072A191)

2702 Miscellaneous Letter CNRO-2018- Entergy Response to Confirmatory Order EA-17-132/EA-17- September 27,

CONF 00039 153 Element J 2018

2702 Miscellaneous Letter CNRO-2018- Entergy Response to Confirmatory Order EA-17-132/EA-17- December 28,

CONF 00051 153 Element K 2018

2709 Miscellaneous Indian Point Strike Contingency Plan Revision 0

21