IR 05000247/2008001
| ML080610015 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/03/2008 |
| From: | Collins S Region 1 Administrator |
| To: | Joseph E Pollock Entergy Nuclear Operations |
| Cobey, Eugene W. RI/DRP/PB2/610-337-5171 | |
| References | |
| FOIA/PA-2010-0209, IR-08-001 | |
| Download: ML080610015 (10) | |
Text
UNITED STATES rch 3, 2008
SUBJECT:
ANNUAL ASSESSMENT LETTER - INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 (REPORTS 05000247/2008001 & 05000286/2008001)
Dear Mr. Pollock:
On February 13, 2008, the NRC staff completed its performance reviews of Indian Point Nuclear Generating Units 2 and 3. Our technical staff reviewed performance indicators for the most recent quarter and inspection results from January 1 through December 31, 2007. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.
This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as Official Use Only - Security Information will include the security cornerstone review and resultant inspection plan.
Overall, Indian Point Nuclear Generating Units 2 and 3 operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance at Unit 2 for the most recent quarter, as well as for the first three quarters of the assessment cycle, was within the Licensee Response column of the NRCs Action Matrix based on all inspection findings being classified as having very low safety significance (Green) and all performance indicators indicating performance at a level requiring no additional NRC oversight (Green).
Plant performance for the most recent quarter at Unit 3 was within the Licensee Response column of the NRCs Action Matrix based on all inspection findings being classified as having very low safety significance (Green) and all performance indicators indicating performance at a level requiring no additional NRC oversight (Green). While plant performance for the most recent quarter was within the Licensee Response column of the Action Matrix, there was one performance indicator of low to moderate safety significance (White) in the Initiating Events cornerstone affecting the second quarter of the assessment cycle. Specifically, the Unit 3 Unplanned Scrams per 7000 Critical Hours performance indicator exceeded the Green/White threshold of greater than three scrams per 7000 critical hours.
On September 4, 2007, the NRC began supplemental inspection 95001 on Unit 3 for the White performance indicator. However, on September 7, 2007, you requested
[ADAMS Ref. ML072540159] that we cease the supplemental inspection because your staff needed additional time to complete and document causal evaluations and corrective actions.
On September 12, 2007, the NRC acknowledged the request [ADAMS Ref. ML072550571] and informed you that the inspection would be rescheduled when your actions were complete and suitable for NRC review. On February 25, 2008, you informed the NRC of your readiness for the supplemental inspection [ADAMS Ref. ML080570458]; therefore, in addition to the baseline inspection program, we plan to conduct supplemental inspection 95001 on Unit 3 beginning on April 14, 2008.
In our annual assessment letter dated March 2, 2007 [ADAMS Ref. ML070610603], we advised you of a substantive cross-cutting issue in the area of human performance related to procedure adequacy (H.2(c)) at Unit 2. In our mid-cycle performance review letter dated August 31, 2007
[ADAMS Ref. ML072430942], we informed you that we had concluded that you did not satisfy the criteria for clearing the cross-cutting issue, as delineated in the March 2, 2007, annual assessment letter. Specifically, you had not effectively implemented your corrective action plan for upgrading operating procedures; and, you had not achieved a notable reduction in the number of findings with cross-cutting aspects in procedural adequacy.
During this assessment period, there continued to be inspection findings attributable to procedure adequacy at Unit 2. In addition, there were four inspection findings on Unit 3 associated with multiple cornerstones that were attributable to procedure adequacy. These inspection findings involved inadequate operations, maintenance, plant modification, and surveillance test procedures. We understand that Entergy has recognized the site-wide cross-cutting theme in procedure adequacy and has developed action plans to upgrade operations, instrumentation and controls, and maintenance procedures. However, we are concerned that at the time of our inspection of this area in late 2007, you had not effectively implemented your action plan for operations procedures. We are also concerned that the screening process in your action plan for instrumentation and controls procedures is not robust and commensurate with the extended timeline for upgrading these procedures. As a result, we have concluded that you have not met the criteria for clearing the substantive cross-cutting issue. Additionally, we have determined that the substantive cross-cutting issue applies to both Units 2 and 3.
The NRC has also identified a substantive cross-cutting issue in the area of problem identification and resolution at Unit 2. During this assessment period, there were four inspection findings associated with multiple reactor safety cornerstones that were attributable to implementation of corrective actions (P.1(d)). These inspection findings involved failure to effectively implement corrective actions for degraded containment fan cooler units, adverse station battery resistances, adverse reliability of an onsite gas turbine-generator, and inadequate monitoring of service water intake bay level. In addition, Entergy has not implemented effective corrective actions to ensure that the new siren system was installed in accordance with NRC orders and has not effectively implemented corrective actions for the long-standing substantive cross-cutting issue in procedure adequacy. Consequently, we are concerned with Entergys scope of efforts and progress in addressing the cross-cutting theme because Entergy has not demonstrated recognition that the cross-cutting theme affects other areas and has not initiated appropriate action to address it.
We will monitor your progress in the areas of corrective action implementation and procedure adequacy through the baseline inspection program, including a review of your actions during the biennial problem identification and resolution inspection scheduled for the second quarter of 2008. The NRC will clear these substantive cross-cutting issues when Entergy has demonstrated sustainable performance improvement as evidenced by effective implementation of an appropriate corrective action plan that results in no safety significant inspection findings and a notable reduction in the overall number of inspection findings with the same causal factor. Because this is the third consecutive assessment letter identifying a substantive cross-cutting issue associated with procedural adequacy, the NRC requests that you conduct an assessment of the safety culture at Indian Point Energy Center. This assessment should be conducted by individuals who are independent from the corporate and site organizations being assessed. We also request that you respond in writing, within 30 days of the issuance of this letter, to provide a detailed description of your plans for the conduct of this assessment including, as a minimum:
the assessment scope and methodology; the assessment team composition and qualifications; and a detailed schedule with milestone dates. Following our evaluation of your plan, we will inform you of the schedule for our inspection activities to evaluate your assessment and corrective actions.
In addition to the baseline inspection program, we plan to conduct license renewal and independent spent fuel storage installation inspections at both units. The NRC will also continue enhanced oversight of Entergy's actions to address issues associated with on-site groundwater contamination characterization and mitigation, and the performance of the alert and notification system (ANS), including implementation and initial testing of the replacement ANS that you are installing in response to the Energy Policy Act of 2005. We expect to continue enhanced oversight until you have completed actions associated with on-site groundwater contamination and installation of the replacement ANS as described in the renewed ROP Deviation Memorandum, approved on December 19, 2007 [ADAMS Ref. ML073480290].
The enclosed inspection plan details the baseline and deviation memorandum inspections, less those related to physical protection, scheduled through June 30, 2009. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last six months of the inspection plan are tentative and may be revised at the mid-cycle safety performance review.
In accordance with 10 CFR 2.390 of the NRC=s ARules of Practice,@ a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Eugene Cobey at 610-337-5171 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
Samuel J. Collins Regional Administrator Region I Docket Nos. 50-247 and 50-286 License No. DPR-26 and DPR-64 Enclosures: Indian Point Nuclear Generating Unit 2 and Unit 3 Inspection/Activity Plans cc w/encl:
Senior Vice President, Entergy Nuclear Operations Vice President, Operations, Entergy Nuclear Operations Vice President, Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety and Licensing, Entergy Nuclear Operations Senior Vice President and CCO, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations Manager, Licensing, Entergy Nuclear Operations P. Tonko, President and CEO, New York State Energy Research and Development Authority C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law D. ONeill, Mayor, Village of Buchanan J. G. Testa, Mayor, City of Peekskill R. Albanese, Four County Coordinator S. Lousteau, Treasury Department, Entergy Services, Inc.
Chairman, Standing Committee on Energy, NYS Assembly Chairman, Standing Committee on Environmental Conservation, NYS Assembly Chairman, Committee on Corporations, Authorities, and Commissions M. Slobodien, Director, Emergency Planning P. Eddy, NYS Department of Public Service Assemblywoman Sandra Galef, NYS Assembly T. Seckerson, County Clerk, Westchester County Board of Legislators A. Spano, Westchester County Executive R. Bondi, Putnam County Executive C. Vanderhoef, Rockland County Executive E. A. Diana, Orange County Executive T. Judson, Central NY Citizens Awareness Network M. Elie, Citizens Awareness Network D. Lochbaum, Nuclear Safety Engineer, Union of Concerned Scientists Public Citizen's Critical Mass Energy Project M. Mariotte, Nuclear Information & Resources Service F. Zalcman, Pace Law School, Energy Project L. Puglisi, Supervisor, Town of Cortlandt Congressman John Hall Congresswoman Nita Lowey Senator Hillary Rodham Clinton Senator Charles Schumer G. Shapiro, Senator Clinton's Staff J. Riccio, Greenpeace P. Musegaas, Riverkeeper, Inc.
M. Kaplowitz, Chairman of County Environment & Health Committee A. Reynolds, Environmental Advocates D. Katz, Executive Director, Citizens Awareness Network S. Tanzer, The Nuclear Control Institute K. Coplan, Pace Environmental Litigation Clinic cc w/encl:
M. Jacobs, IPSEC W. Little, Associate Attorney, NYSDEC M. J. Greene, Clearwater, Inc.
R. Christman, Manager Training and Development J. Spath, New York State Energy Research, SLO Designee A. J. Kremer, New York Affordable Reliable Electricity Alliance (NY AREA)
Institute of Nuclear Power Operations (INPO) cc w/encl:
M. Jacobs, IPSEC W. Little, Associate Attorney, NYSDEC M. J. Greene, Clearwater, Inc.
R. Christman, Manager Training and Development J. Spath, New York State Energy Research, SLO Designee A. J. Kremer, New York Affordable Reliable Electricity Alliance (NY AREA)
Institute of Nuclear Power Operations (INPO)
Distribution w/encl: RidsNrrDirslpab@nrc.gov S. Collins, RA J. Trapp, DRS M. Dapas, DRA J. Rogge, DRS G. West, RI OEDO (Acting) S. Hansell, DRS J. Lubinski, NRR J. White, DRS M. Kowal, NRR L. Doerflein, DRS J. Boska, PM, NRR R. Conte, DRS J. Hughey, NRR L. Scholl, DRS E. Cobey, DRP P. Frechette, DRS D. Jackson, DRP D. Silk, DRS C. Hott, DRP, Senior Resident Inspector - D. Screnci, PAO Indian Point 2 (Acting) N. Sheehan, PAO A. Patel, Resident Inspector - Indian Point 2 R. Barkley, ORA (Acting) D. Holody, ORA Region I Docket Room (w/concurrences) J. Anderson, NRR ROPreports@nrc.gov J. Thompson, NRR (JWT1@nrc.gov)
SUNSI Review Complete: DEJ (Reviewer=s Initials)
DOCUMENT NAME: S:\ROP-8 EOC Review\Branch 2\Indian Point 2\IPEC Annual Assessment Letter rev2.doc After declaring this document AAn Official Agency Record@ it will be released to the Public.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure
"E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/DRP RI/DRP RI/DRP ORA NAME DJackson/DEJ ECobey/EWC DLew/DCL SCollins/SJC DATE 02/27/08 02/27/08 02/27/08 02/29/08 OFFICIAL RECORD COPY
Page 1 of 2 Indian Point 02/28/2008 15:46:22 Inspection / Activity Plan Report 22 01/01/2008 - 06/30/2009 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type 1/7 EXM - U2 INITIAL OPERATOR LICENSING EXAM 5 2 U01683 FY08 - INDIAN POINT 2 INITIAL EXAM 01/07/2008 01/11/2008 Not Applicable 71002 - LICENSE RENEWAL INSPECTION 8 2 IP 71002 License Renewal Inspection 01/28/2008 02/01/2008 License Renewal Inspec 2 IP 71002 License Renewal Inspection 02/11/2008 02/15/2008 License Renewal Inspec ISFSI - ISFSI INSPECTIONS 1 2 IP 60854.1 Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants 01/28/2008 10/31/2008 Other Routine 2 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants 01/28/2008 10/31/2008 Other Routine TI-172 - TI-172 RCS DISSIMILIAR METAL WELDS 1 2 IP 2515/172 Reactor Coolant System Dissimiliar Metal Butt Welds 03/31/2008 04/04/2008 Generic Safety Inspectio 7111108P - U2 INSERVICE INSPECTION 1 2 IP 7111108P Inservice Inspection Activities - PWR 03/31/2008 04/11/2008 Baseline Inspections 71121 - OCC RAD SAFETY 1 2 IP 7112101 Access Control to Radiologically Significant Areas 04/07/2008 04/11/2008 Baseline Inspections 2 IP 7112102 ALARA Planning and Controls 04/07/2008 04/11/2008 Baseline Inspections TI-166 - CONTAINMENT SUMP MODIFICATIONS 1 2 IP 2515/166 Pressurized Water Reactor Containment Sump Blockage [NRC GENERIC LETTER 2004-02] 04/21/2008 04/25/2008 Safety Issues 7111117B - SBO EDG MOD 2 2 IP 7111117B Evaluations of Changes, Tests, or Experiments & Permanent Plant Modifications 06/02/2008 06/06/2008 Baseline Inspections 71152B - PI&R 5 2 IP 71152B Identification and Resolution of Problems 05/19/2008 05/23/2008 Baseline Inspections 2 IP 71152B Identification and Resolution of Problems 06/02/2008 06/06/2008 Baseline Inspections 7112201 - PUB RAD SAFETY - RETS 1 2 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 07/07/2008 07/11/2008 Baseline Inspections 7111111B - REQUAL INSPECTION +P/F REVIEW 3 2 IP 7111111B Licensed Operator Requalification Program 09/22/2008 09/26/2008 Baseline Inspections MODS - PERMANENT PLANT MODIFICATIONS 4 2 IP 7111117B Evaluations of Changes, Tests, or Experiments & Permanent Plant Modifications 07/28/2008 08/01/2008 Baseline Inspections 2 IP 7111117B Evaluations of Changes, Tests, or Experiments & Permanent Plant Modifications 08/11/2008 08/15/2008 Baseline Inspections 7112203 - PUB RAD SAFETY - REMP 1 2 IP 7112203 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 08/04/2008 08/08/2008 Baseline Inspections 71121 - OCC RAD SAFETY 1 2 IP 7112101 Access Control to Radiologically Significant Areas 08/18/2008 08/22/2008 Baseline Inspections 2 IP 7112102 ALARA Planning and Controls 08/18/2008 08/22/2008 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Page 2 of 2 Indian Point 02/28/2008 15:46:22 Inspection / Activity Plan Report 22 01/01/2008 - 06/30/2009 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type TI 171 - TI 171 3 2 IP 2515/171 Verification of Site Specific Implementation Of B.5.b Phase 2 & 3 Mitigating Strategies 09/29/2008 10/03/2008 Generic Safety Inspectio 71122.02 - PUB RAD SAFETY - RADWASTE 1 2 IP 7112202 Radioactive Material Processing and Transportation 11/17/2008 11/21/2008 Baseline Inspections EP - EP EXERCISE EVALUATION 1 2 IP 7111401 Exercise Evaluation 12/01/2008 12/05/2008 EP Baseline Inspection 2 IP 7111404 Emergency Action Level and Emergency Plan Changes 12/01/2008 12/05/2008 EP Baseline Inspection 2 IP 71151-EP01 Drill/Exercise Performance 12/01/2008 12/05/2008 Baseline Inspections 2 IP 71151-EP02 ERO Drill Participation 12/01/2008 12/05/2008 Baseline Inspections 2 IP 71151-EP03 Alert & Notification System 12/01/2008 12/05/2008 Baseline Inspections 71121 - OCC RAD SAFETY 1 2 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 12/15/2008 12/19/2008 Baseline Inspections 2 IP 71151-OR01 Occupational Exposure Control Effectiveness 12/15/2008 12/19/2008 Baseline Inspections 2 IP 71151-PR01 RETS/ODCM Radiological Effluent 12/15/2008 12/19/2008 Baseline Inspections 71121 - OCC RAD SAFETY 1 2 IP 7112101 Access Control to Radiologically Significant Areas 03/23/2009 03/27/2009 Baseline Inspections 2 IP 7112102 ALARA Planning and Controls 03/23/2009 03/27/2009 Baseline Inspections 7111107B - HEAT SINK INSP 1 2 IP 7111107B Heat Sink Performance 05/11/2009 05/15/2009 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Page 1 of 2 Indian Point 3 02/28/2008 15:46:48 Inspection / Activity Plan Report 22 01/01/2008 - 06/30/2009 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type 71002 - LICENSE RENEWAL INSPECTION 8 3 IP 71002 License Renewal Inspection 01/28/2008 02/01/2008 License Renewal Inspec 3 IP 71002 License Renewal Inspection 02/11/2008 02/15/2008 License Renewal Inspec TRI FIRE - TRIENNIAL FIRE PROTECTION INSPECTION 4 3 IP 7111105T Fire Protection [Triennial] 01/21/2008 01/25/2008 Baseline Inspections 3 IP 7111105T Fire Protection [Triennial] 02/04/2008 02/08/2008 Baseline Inspections 71121 - OCC RAD SAFETY 1 3 IP 7112101 Access Control to Radiologically Significant Areas 04/07/2008 04/11/2008 Baseline Inspections 3 IP 7112102 ALARA Planning and Controls 04/07/2008 04/11/2008 Baseline Inspections 7112201 - PUB RAD SAFETY - RETS 1 3 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 07/07/2008 07/11/2008 Baseline Inspections 7112203 - PUB RAD SAFETY - REMP 1 3 IP 7112203 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 08/04/2008 08/08/2008 Baseline Inspections 71121 - OCC RAD SAFETY 1 3 IP 7112101 Access Control to Radiologically Significant Areas 08/18/2008 08/22/2008 Baseline Inspections 3 IP 7112102 ALARA Planning and Controls 08/18/2008 08/22/2008 Baseline Inspections TI 171 - TI 171 3 3 IP 2515/171 Verification of Site Specific Implementation Of B.5.b Phase 2 & 3 Mitigating Strategies 09/29/2008 10/03/2008 Generic Safety Inspectio 71122.02 - PUB RAD SAFETY - RADWASTE 1 3 IP 7112202 Radioactive Material Processing and Transportation 11/17/2008 11/21/2008 Baseline Inspections EP - EP EXERCISE EVALUATION 1 3 IP 7111401 Exercise Evaluation 12/01/2008 12/05/2008 EP Baseline Inspection 3 IP 7111404 Emergency Action Level and Emergency Plan Changes 12/01/2008 12/05/2008 EP Baseline Inspection 3 IP 71151-EP01 Drill/Exercise Performance 12/01/2008 12/05/2008 Baseline Inspections 3 IP 71151-EP02 ERO Drill Participation 12/01/2008 12/05/2008 Baseline Inspections 3 IP 71151-EP03 Alert & Notification System 12/01/2008 12/05/2008 Baseline Inspections 71121 - OCC RAD SAFETY 1 3 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 12/15/2008 12/19/2008 Baseline Inspections 3 IP 71151-OR01 Occupational Exposure Control Effectiveness 12/15/2008 12/19/2008 Baseline Inspections 3 IP 71151-PR01 RETS/ODCM Radiological Effluent 12/15/2008 12/19/2008 Baseline Inspections TI-172 - TI-172 RCS DISSIMILIAR METAL WELDS 1 3 IP 2515/172 Reactor Coolant System Dissimiliar Metal Butt Welds 03/16/2009 03/20/2009 Generic Safety Inspectio 7111108P - U3 INSERVICE INSPECTION 1 3 IP 7111108P Inservice Inspection Activities - PWR 03/16/2009 03/27/2009 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Page 2 of 2 Indian Point 3 02/28/2008 15:46:48 Inspection / Activity Plan Report 22 01/01/2008 - 06/30/2009 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type 71121 - OCC RAD SAFETY 1 3 IP 7112101 Access Control to Radiologically Significant Areas 03/23/2009 03/27/2009 Baseline Inspections 3 IP 7112102 ALARA Planning and Controls 03/23/2009 03/27/2009 Baseline Inspections 7111107B - HEAT SINK INSP 1 3 IP 7111107B Heat Sink Performance 05/11/2009 05/15/2009 Baseline Inspections 71152B - PI&R BIENNIAL TEAM 4 3 IP 71152B Identification and Resolution of Problems 05/18/2009 05/22/2009 Baseline Inspections 3 IP 71152B Identification and Resolution of Problems 06/01/2009 06/05/2009 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.