Text

Biennial Problem Identification and Resolution Inspection Report 05000247/2019010 and 05000286/2019010
	ML19270D646
Person / Time
Site:	Indian Point
Issue date:	09/26/2019
From:	Daniel Schroeder; Reactor Projects Branch 2
To:	Vitale A; Entergy Nuclear Operations
	Schroeder D
References
	IR 2019010
	Download: ML19270D646 (16)
	v • d • e

September 26, 2019

SUBJECT:

INDIAN POINT NUCLEAR GENERATING, UNITS 2 AND 3 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000247/2019010 AND 05000286/2019010

Dear Mr. Vitale:

On August 15, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at Indian Point Nuclear Generating, Units 2 and 3 and 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.

The NRC inspectors did not identify any finding or violation 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 at the NRC Public Document Room in accordance with 10 CFR 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:

05000247/2019010 and 05000286/2019010

Enterprise Identifier: I-2019-010-0009

Licensee:

Entergy Nuclear Northeast

Facility:

Indian Point Nuclear Generating, Units 2 and 3

Location:

Buchanan, NY

Inspection Dates:

July 29, 2019 to August 15, 2019

Inspectors:

J. Schussler, Senior Resident Inspector (Team Lead)

P. Boguszewski, Resident Inspector

S. Horvitz, Resident Inspector

J. Vazquez, Resident Inspector

Approved By:

Daniel L. Schroeder, Chief

Reactor Projects Branch 2

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Indian Point Nuclear Generating, 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.

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 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.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

Main article: IP 71152

(1) The inspectors performed a biennial assessment of Entergy's corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of Unit 2 component cooling water and Unit 3 auxiliary feedwater.

Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program -

Identification: The inspectors determined that, in general, Entergy identified issues and entered them into the corrective action program at a low threshold. During plant walk downs, there is evidence of continued focus to improve the look and condition of the plant, although the inspectors identified a few deficiencies not previously identified and captured in Entergy's corrective action program. Entergy promptly entered each issue into their corrective action program and took actions to evaluate and address.

Prioritization and Evaluation: Based on the samples reviewed, the inspectors determined that, in general, Entergy appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Entergy appropriately screened condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution.

Correcting Problems: The inspectors determined that the overall corrective action program performance related to resolving problems was effective. In most cases, Entergy implemented corrective actions to resolve problems in a timely manner.

However, the inspectors identified a minor violation and a minor performance deficiency relating to the identification of problems.

Assessment 71152B Operating Experience -

The team determined that Entergy appropriately evaluated industry operating experience for its relevance to the facility. Entergy appropriately incorporated both internal and external operating experience into plant procedures and processes, as well as lessons learned for training and pre-job briefs.

Self-Assessments and Audits -

The team reviewed a sample of self-assessments and audits to assess whether Entergy was identifying and addressing performance trends. The team concluded that Entergy had an effective self-assessment and audit process.

However, the inspectors identified an observation relating to the evaluation and response to operational experience which is documented below.

Assessment 71152B Safety Conscious Work Environment -

The team interviewed individuals in eight different work groups through one-on-one and group interviews. The purpose of these interviews was

(1) to evaluate the willingness of Entergy staff to raise nuclear safety issues,

(2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and

(3) to evaluate Entergy's safety-conscience work environment. The personnel interviewed were randomly selected by the inspectors from the Operations, Engineering, Maintenance, Security, Chemistry, Emergency Preparedness, and Radiation Protection work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) Coordinator to assess her perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.

All individuals interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Most interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of Entergy's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, most individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. The team determined that the processes in place to mitigate potential safety culture issues were adequately implemented.

Minor Violation 71152B Minor Violation: The inspectors identified a minor violation of Indian Point Unit 2 Technical Specification 5.4.1.k and Indian Point Unit 3 Technical Specification 5.4.1.d that requires written procedures shall be established, implemented, and maintained covering Fire Protection Program implementation. Entergy procedure 0-PT-M004, Fire Extinguisher Inspection, Revision 13, implements monthly inspections of portable fire extinguishers to verify that all acceptance criteria is satisfied. The procedure states in part that the acceptance criteria includes all specified portable fire extinguishers are inspected and determined to have satisfactory weight or pressure, a functional portable fire extinguisher of the correct size and type is located at each specified location, and corrective actions are initiated for any specified portable fire extinguisher identified as past due for hydrostatic testing or required maintenance. The procedure also states that if a portable extinguisher fails inspection, then remove the extinguisher from service and replace it with a charged extinguisher of the same type and the same or larger size. Contrary to the above, on July 30, 2019, the inspectors identified a number of portable fire extinguishers in both Unit 2 and Unit 3 that failed inspection and had not been removed from service and replaced with properly charged extinguishers. This is a similar issue to a licensee identified violation documented in Triennial Fire Protection Inspection Report 05000247/2017007 and 05000286/2017007.

Screening: The inspectors determined the performance deficiency was minor. The inspectors independently evaluated the deficiency for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, issued December 31, 2017, and Appendix E, Examples of Minor Issues, issued October 1, 2018. The inspectors determined that not promptly identifying a condition adverse to quality was a deficiency of minor significance because the condition did not challenge the capability of the fire protection system to fulfill its function. This issue was captured in Entergys corrective action program as CR-IP3-2019-02894.

Enforcement:

This failure to comply with Indian Point Unit 2 Technical Specification 5.4.1.k and Indian Point Unit 3 Technical Specification 5.4.1.d constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Minor Performance Deficiency 71152B Minor Performance Deficiency: The inspectors identified a minor performance deficiency associated with Entergy procedure EN-OP-115-05, Operation of Components, Revision 2 which is used in part to control locked valves. The procedure states that valves are not permitted to be chained to a structure that might move in a different direction during a seismic or water hammer event unless the configuration has been approved by Design Engineering.

Contrary to the above, the inspectors identified four auxiliary feedwater flow control valves, in Indian Point Unit 2, which were locked to stanchions or conduit without approval from Design Engineering.

Entergy promptly documented the issue in the corrective action program as CR IP-2-2019-03222 and CR-HQN-2019-01744. Corrective actions will include a review of the procedure for revision change, prompt operability decision, and an extent of condition review.

Screening: The inspectors determined the performance deficiency was minor. The inspectors independently evaluated the deficiency for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, issued December 31, 2017, and Appendix E, Examples of Minor Issues, issued October 1, 2018. The inspectors determined that not having an Engineering evaluation was a deficiency of minor significance, because it did not lead to a reasonable doubt of operability for the auxiliary feedwater system.

Observation: Operating Experience Review 71152B The inspectors observed two instances where documented responses to incoming industry operating experience were not appropriately self-critical in accordance with Entergy's procedure. Specifically, Entergy Procedure EN-OE-100, Operating Experience Program, states that incoming operating experience should be reviewed with the perspective that this event can happen here." However, in the case of two operating experience responses developed within the Radiation Protection work group, the inspectors identified that Entergy's responses communicated a reliance on previously-demonstrated successes within the working group, rather than focusing on the potential for unanticipated issues to arise at the station.

For example, the inspectors observed one operating experience response which stated that Indian Point is not vulnerable to similar events because of demonstrated good performance. Also, the inspectors identified another operating experience response associated with a human performance error that had happened at Indian Point. Entergy communicated that the event had been an isolated incident. The response stated that it was not something that occurs regularly or even occasionally. Additionally, the response went on to cite high ratings on recent third-party evaluations of the stations radiation protection program as justification for the conclusion that the event would not occur again. This response, however, did not discuss the actions that had been taken at the station to reinforce the associated radiation protection standards within the work group responsible for the human performance error.

The inspectors reviewed operating experience responses in different work groups and various date ranges and concluded the observed operating experience response issue was isolated to the Radiation Protection work group. Additionally, in both of these cases, the inspectors discussed the observation with Entergy's supervision and management, who indicated that the associated issues had been discussed with staff during crew briefs.

Observation: Extent of Condition Review 71152B The inspectors observed that an extent of condition review was not completed in a timely manner. Entergy created corrective action assignments resulting from a discrepancy identified in the chemical and volume control systems on Indian Point Unit 3, which generated work orders to conduct an extent of condition review. Specifically, CR-IP3-2017-03208 was written as a result of a leak that developed on chemical and volume control system valve CH-352 when Entergy switched between reactor coolant system demineralizers. One of the corrective action assignments associated with that condition report was to identify similar valves on Unit 2 and Unit 3 and issue a condition report, specifically generate work orders to verify valve body to bonnet joint integrity.

Entergy procedure EN-LI-118, Casual Evaluation Process, states in part, extent of condition should be explored as early as possible. Contrary to this, the inspectors identified that the work order to complete the extent of condition review for Indian Point Unit 2 had not been completed and is currently scheduled for January 2020. Additionally, the inspectors noted the adverse condition analysis completed as a result of the 2017 issue stated a contributing cause was due to inadequately tracking and implementing corrective actions from a similar 2012 event. Furthermore, the inspectors identified that valves Entergy included in the extent of condition review exhibited bonnet to body leaks within the last two years. The inspectors determined although some of the valves identified as part of the Unit 2 extent of condition were degraded, they did not represent a significant safety concern. Entergy promptly entered this issue into their correction action program as CR-IP2-2019-03221.

EXIT MEETINGS AND DEBRIEFS

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

On August 15, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Anthony J. Vitale, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

v t e Inspection Report - Indian Point - 2019010
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \| 26 \|
2019 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 10(0) 11(0) 12(0) Security 403(0) 410(0) 411(0) Operator Exams 301(0) Emergency Planning Other

IR 05000247/2019010