IR 05000247/2020014
| ML21032A118 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/01/2021 |
| From: | Anthony Dimitriadis Decommissioning Branch I |
| To: | Vitale A Entergy Nuclear Operations |
| References | |
| IR 2020014 | |
| Download: ML21032A118 (12) | |
Text
February 1, 2021
SUBJECT:
ENTERGY NUCLEAR OPERATIONS, INC., INDIAN POINT NUCLEAR GENERATING STATION UNIT 2 - NRC INSPECTION REPORT NO.
Dear Mr. Vitale:
On December 31, 2020 the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the permanently shutdown Indian Point Nuclear Generating Station Unit 2. A combination of on-site and remote inspection activities (in-office reviews) were performed as a consequence of the COVID-19 public health emergency (PHE) during this inspection period. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and the conditions of your license. The inspection consisted of observations by the inspectors, interviews with site personnel, and a review of procedures and records. The results of the inspection were discussed with you and other members of your staff on January 7, 2021 and are described in the enclosed inspection report. No findings of safety significance were identified.
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 made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's Website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). No reply to this letter is required. Please contact Katherine Warner (610) 337-5389 if you have any questions regarding this matter.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor HP Branch Division of Nuclear Materials Safety cc w/encl: Distribution via ListServ Enclosure: Inspection Report Nos. 05000247/2020014
EXECUTIVE SUMMARY
Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Station Unit 2 NRC Inspection Report No. 05000247/2020014 An announced routine decommissioning inspection at Indian Point Unit 2 was completed on December 31, 2020. A combination of on-site and remote inspection activities were performed over this period. Certain inspection activities (in-office reviews) were conducted remotely as a consequence of the COVID-19 public health emergency (PHE) during this inspection period. The inspection included a review of organization and management at the site, design changes and modifications, maintenance and surveillance, self-assessments, audits, corrective actions, spent fuel safety, and decommissioning performance and status. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. The U.S. Nuclear Regulatory Commissions (NRC's) program for overseeing the safe operation of a shut-down nuclear power reactor is described in Inspection Manual Chapter (IMC)2561, Decommissioning Power Reactor Inspection Program."
Based on the results of this inspection, no findings of safety significance were identified.
ii
REPORT DETAILS
1.0 Background Indian Point Unit 2 (IP-2) is a pressurized water reactor that commenced operations in 1974. On February 8, 2017, Entergy Nuclear Operations, Inc. (Entergy) notified the NRC of its intent to permanently cease power operations at IP-2 by April 30, 2020 subject to operating extensions through, but not beyond 2024 (Agencywide Documents and Access Management System (ADAMS) Accession Number: ML17044A004). On May 12, 2020, Entergy certified cessation of power operations and the permanent removal of fuel from the IP-2 reactor vessel (ADAMS Accession Number: ML20133J902). On May 13, 2020, the NRC notified Indian Point that the Operating Reactor Assessment Program had ceased and that implementation of the Decommissioning Power Reactor Inspection Program at IP-2 would begin on May 13, 2020 (ADAMS Accession Number: ML20134H943).
IP-2 is currently in the Post Operation Transition Phase of decommissioning as described in IMC 2561. The NRC's program for overseeing the safe operation of a shut-down nuclear power reactor is described in IMC 2561. Completion of certain core inspection procedures listed in IMC 2561, Appendix A, were completed via use of samples associated with IP 71111.01, Adverse Weather Preparations that the resident inspectors performed as part of the Reactor Oversight Process. Additionally, certain sections of inspection procedure IP 71124.01, Radiological Hazard Assessment and Exposure Controls were performed in place of IP 83750, Occupational Radiation Exposure and contributed to the completion of IP 62801, Maintenance and Surveillance at Permanently Shutdown Reactors.
2.0 Unit 2 Post-Operation Transition Performance and Status Review 2.1 Organization, Management, and Cost Controls at Permanently Shutdown Reactors (IP 36801) and Decommissioning Performance and Status Reviews at Permanently Shutdown Plants (IP 71801)
a. Inspection Scope
The inspectors performed an on-site inspection on October 26 - 29, 2020 supplemented by periodic phone calls. The inspectors also met with IPEC management and discussed staffing levels and the current maintenance workload. The inspectors reviewed the backlog of maintenance work to assess the age and prioritization of the items. The inspectors evaluated the storage of combustibles and flammables to determine if such storage was in accordance with plant procedures and fire plan for the subject location. The inspectors evaluated the installed fire detection and suppression systems to determine if they were effectively maintained, if surveillances were performed and they were capable of performing their intended function.
The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs.
b. Observations and Findings
The inspectors verified that management oversight was adequate for the Post-Operation Transition phase of decommissioning for Unit 2 and that the decommissioning organization and changes to the operating unit organizations responsibilities was appropriately implemented upon Unit 2s cessation of operations. The inspectors discussed the planned Phase 1 organization to be implemented after the planned shutdown of Unit 3 on April 30, 2021. The inspectors noted that the Phase 1 organization contained all of the major groups necessary for Post-Operation Transition and that IPEC plans to implement a training plan to close any qualification gaps prior to implementation of the reorganization.
The inspectors interviewed personnel from Entergy corporate responsible for financial assurance on the overall financial status of decommissioning. No issues were identified.
The inspectors noted that NRC headquarters staff has the lead for assessing the appropriateness of a licensees decommissioning fund allocation.
The inspectors determined through plant tours and interviews that Entergy had maintained appropriate fire detection and mitigation capabilities, and that the maintenance backlog had been reviewed by site management on a regular basis and the safety significance appropriately assessed.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
2.2 Self-Assessment, Auditing, and Corrective Actions at Permanently Shutdown Reactors (IP 40801)
a. Inspection Scope
The inspectors performed a continuous inspection of applicable activities during the inspection period. The inspectors reviewed documents and interviewed IPEC personnel to determine if IPEC management performed audits and self-assessments, and if issues were identified and corrected in accordance with the sites corrective action program (CAP). The inspectors reviewed a representative selection of CAP documents to determine if a sufficiently low threshold for problem identification existed, follow-up evaluations were of sufficient quality, and IPEC assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue.
b. Observations and Findings
The inspectors determined that issues had been identified and entered into the CAP and evaluated commensurate with their safety significance.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
2.3 Spent Fuel Pool Safety at Permanently Shutdown Reactors (IP 60801)
a. Inspection Scope
The inspectors performed an on-site inspection on October 26 - 29, 2020. The inspectors reviewed Entergys programs for the safe wet storage of spent fuel. The inspectors performed a walkdown of the SFP and associated support systems to assess material condition, configuration control, and system operation. The inspectors toured the control room and interviewed certified fuel handlers (CFHs) to verify SFP system instrumentation, alarms and leakage detection monitoring is adequate to assure the safe storage of spent fuel.
b. Observations and Findings
The inspectors determined that Entergy had safely stored spent fuel in wet storage and that SFP chemistry and cleanliness controls had been adequately implemented.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
2.4 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (IP 37801) and Maintenance and Surveillance at Permanently Shutdown Reactors (IP 62801)
a. Inspection Scope
The inspectors performed a continuous inspection of applicable activities during the inspection period. The inspectors conducted document reviews and interviews with plant personnel to determine whether licensee procedures and processes conform with the regulations and guidance associated with 10 CFR 50.59. The inspectors conducted plant tours, interviews, and directly observed maintenance and surveillance activities throughout the inspection period to evaluate the effectiveness of activities associated with maintaining structures, systems, and components important to the safe storage of spent fuel and proper operation of radiation monitoring and effluent control equipment. During walkdowns, the inspectors evaluated material condition and housekeeping, assessed area radiological conditions, radiological access control and associated posting/labeling, and reviewed the overall condition of systems, structures and components that support decommissioning.
b. Observations and Findings
The inspectors reviewed the change in safety classification documented under engineering change EC 83553 for those structures, systems and components (SSC) that no longer have a quality related function as described in the Defueled Safety Analysis Report (DSAR). Most of the previously classified safety related or quality SSCs were changed in classification to be non-safety related. The applicable Design Basis Accidents for IP-2 in the permanently defueled condition involve several hypothetical scenarios, including: a fuel handling accident (FHA) in the fuel handling building, an accidental release-recycle of waste liquid, and the accidental release of waste gas where the only SSC credited in the DSAR to prevent or mitigate the consequences of such an accident is the spent fuel pit.
Therefore, the spent fuel pit will remain as a safety-related structure and the spent fuel pit level indicators (required as part of the post-Fukushima FLEX order) will remain classified as augmented quality. The inspectors also reviewed the process for system abandonment and system boundary isolation for those SSCs that are no longer required. Specifically, inspectors observed a sample of tag outs applied and draining of the chemical volume control system. The inspectors determined that procedural requirements were met and that the changes did not require prior NRC approval.
The inspectors noted that throughout the inspection period, housekeeping in the reactor building and containment building remained satisfactory and changing radiological conditions were addressed in a prompt and timely manner by site personnel.
The inspectors noted that, in general, Entergy appropriately prioritized corrective maintenance on the remaining systems required for permanent cessation of operations.
The inspectors verified that when equipment issues occurred, Entergy staff implemented the appropriate troubleshooting procedures to identify and correct the relevant equipment deficiency identified. As part of an on-demand maintenance activity, the inspectors reviewed the opening, cleaning, and internal examination of the 22 closed cooling water heat exchanger. This system and associated heat exchanger provide the cooling necessary for the spent fuel pit heat exchanger. The inspectors determined that the licensee followed its procedures and conducted the maintenance in accordance with specified work order instructions.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
4.0
Exit Meeting Summary
On January 7, 2021, the inspectors presented the inspection results to Mr. Anthony Vitale, Site Vice President and other members of Entergys organization. No proprietary information was retained by the inspectors or documented in this report.
A-3
SUPPLEMENTARY INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
- R. Burroni, Director, Special Projects
- R. Walpole, Director - Regulatory Assurance and Performance Improvement
- S. Stevens, Radiation Protection Manager
- M. Mirzai, Regulatory Assurance Manager
- N. Azevedo, Supervisor Code Programs
- G. Dahl, Regulatory Assurance
- G. Delfini, Reactor Engineering Supervisor
- J. Doroski, Senior Health Physics/Chemistry Specialist
- K. Elliott, Fire Protection Engineer
- A. Eng, Regulatory Assurance
- L. Fitzsimmons, Radiation Protection Technician (BHI Contractor)
- R. Ford, Boric Acid Corrosion Control Engineer
- L. Frink, Radiation Protection Supervisor
- W. OBrien, Radiation Protection Supervisor
- S. Malinski, Civil/Structural Engineer
- R. Passalugo, Radiation Protection Supervisor
- C. Patterson, Dry Fuel Storage
- E. Rosario, System Engineer
- F. Spagnuolo, Manager- Outage
- M. Trott, Reactor Engineer
ITEMS OPEN, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
Procedures
2-ONOP-FP-001, Plant Fires Revisions 22 and 23
EN-DC-324-DP, Decommissioning Plant Preventive Maintenance Program, Revision 6
EN-CY-111 Attachment 7, Spill/Leak Groundwater Sample Results Reporting Flowchart, Revision
010
EN-CY-113, Response to Contaminated Spills/Leaks, Revision 9
EN-DC-161, Control of Combustibles, Revision 21
EN-LI-113-01, Updated Final Safety Analysis Report Change Process, Revision 5
EN-OP-102, Protective and Caution Tagging, Revision 024
EN-OP-125, Fire Brigade Drills, Revision 000
IP-SMM-AD-102, IPEC Implementing Procedure Preparation, Review, and Approval, Revision 17
IP-SMM-TQ-122, IPEC Fire Protection Program Training, Revision 8
SEP-FPP-IP-001, IPEC Fire Protection Program Plan, Revision 6
Enclosure
Audits and Reports
Decommissioning Funding Status Report per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) -
Entergy Nuclear Operations, Inc., dated March 26, 2020
IP2-RPT-03-00015, Indian Point 2 Fire Hazards Analysis, Revision 7
QA-9-2020-IP-1, Fire Protection Program, January 6, 2020 - February 10, 2020
Condition Reports
CR-IP2-2020-00581 CR-IP2-2020-01493 CR-IP2-2020-01712
CR-IP2-2020-00615 CR-IP2-2020-01499 CR-IP2-2020-01745
CR-IP2-2020-00994 CR-IP2-2020-01549 CR-IP2-2020-01917
CR-IP2-2020-01064 CR-IP2-2020-01586 CR-IP2-2020-01998
CR-IP2-2020-01155 CR-IP2-2020-01639 CR-IP2-2020-01999
CR-IP2-2020-01215 CR-IP2-2020-01645 CR-IP2-2020-02000
CR-IP2-2020-01345 CR-IP2-2020-01664
CR-IP2-2020-01346 CR-IP2-2020-01671
Miscellaneous
IPEC 10 CFR 50.75(g) file
EN-RP-113 Attachment 9.1, 10 CFR 50.75(g) Leak/Spill Record, dated February 26, 2020
EN-RP-113 Attachment 9.1, 10 CFR 50.75(g) Leak/Spill Record, dated March 30, 2019
IP1 IP2 OX Backlog, September 24, 2020
IP-1 TS (Appendix A to Provisional Operating License No. DPR-5)
Indian Point Energy Center Phase 1 Organization Chart, September, 2020
Indian Point Energy Center Units 1, 2, and 3 Offsite Dose Calculation Manual, Revision 4
Indian Point Nuclear Generating Unit No. 2 - Permanently Defueled Technical Specifications
Indian Point Unit 1 Safety Analysis Report
Indian Point Unit 2 Defueled Safety Analysis Report
Tag List for Tagout CVCS-002-CVCS Drain, dated October 1, 2020
Work Orders
Drawings
21-F-2720-94
A227781-82
SD 4.3 SFPC Figure 1
LIST OF ACRONYMS USED
CAP Corrective Action Program
DSAR Defueled Safety Analysis Report
Entergy Entergy Nuclear Operations, Inc.
IMC Inspection Manual Chapter
IP Inspection Procedure
IPEC Indian Point Energy Center
IP-2 Indian Point Unit 2
Enclosure
LIST OF ACRONYMS USED (Contd)
NRC Nuclear Regulatory Commission
ODCM Offsite Dose Calculation Manual
QA Quality Assurance
REMP Radiological Environmental Monitoring Program
SAFSTOR Safe Storage
TS Technical Specification
UFSAR Updated Final Safety Analysis Report
Enclosure