IR 05000247/2013012

IR 05000247-13-012 and 05000286-13-012; 10/21/2013 - 11/08/2013; Indian Point Power Station; Biennial Baseline Inspection of Problem Identification and Resolution (Pi&R). One Traditional Enforcement Severity Level IV NCV Was Identified in t

ML13353A175
Person / Time
Site:	Indian Point
Issue date:	12/19/2013
From:	Arthur Burritt Reactor Projects Branch 2
To:	Ventosa J Entergy Nuclear Indian Point 3
burritt, al
References
IR-13-012
Download: ML13353A175 (25)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 19, 2013

SUBJECT:

INDIAN POINT POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000247/2013012 AND 05000286/2013012

Dear Mr. Ventosa:

On November 8, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Indian Point Power Station Units 2 and 3. The enclosed report documents the inspection results, which were discussed on November 8, 2013, with Mr. J. Dinelli, General Manager Plant Operations, and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the samples selected for review, the inspectors concluded that Entergy Nuclear Northeast (Entergy) was generally effective in identifying, evaluating, and resolving problems.

Entergy personnel identified problems and entered them into the corrective action program at a low threshold. Entergy prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.

This report documents one NRC Identified, Traditional Enforcement Severity Level IV non-cited violation (NCV). This NCV was determined to be a violation of NRC requirements; however, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Indian Point. 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 available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 Enclosure: Inspection Report 05000247/2013012 and 05000286/2013012 w/Attachment: Supplementary Information cc w/encl: Distribution via ListServ

SUMMARY

IR 05000247/2013012 and 05000286/2013012; 10/21/2013 - 11/08/2013; Indian Point Power

Station; Biennial Baseline Inspection of Problem Identification and Resolution (PI&R). One traditional enforcement Severity Level IV NCV was identified in the area of Corrective Action Program - Problem Evaluation.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified one traditional enforcement Severity Level IV NCV. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Problem Identification and Resolution The inspectors concluded that Entergy Nuclear Northeast (Entergy) was generally effective in identifying, evaluating, and resolving problems. Entergy personnel identified problems, entered them into the corrective action program at a low threshold, and in general, prioritized issues commensurate with their safety significance. Entergy appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Entergy implemented corrective actions to address the problems identified in the corrective action program in a timely manner. However, the inspectors identified one violation of NRC requirements in the area of problem evaluation that was not reflective of current performance.

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

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

Cornerstone: Miscellaneous

(1) Severity Level IV. The inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR 50.73 (a)(2)(i)(B) for failure to make a required report to the NRC.

Specifically in 2008, a section of essential service water piping was identified to be below the American Society of Engineers (ASME) code case N 513 minimum pipe wall thickness to ensure structural integrity was maintained and therefore, the system was determined to have been inoperable. This condition existed longer than the technical specification allowed system outage time for essential service water.

Therefore, this should have been reported in 2008 as operations in a condition prohibited by technical specifications under 10 CFR 50.73 (a)(2)(i)(B) within 60 days of the date of discovery. Entergy entered the issue into their corrective action program as CR-IP2-2013-4346 and completed corrective actions to discuss the 2008 event as part of a licensee event report 247-2013004 submitted on November 12, 2013 for leaks in the same system discovered in September 2013.

The inspectors determined that the failure to submit a notification required by 10 CFR 50.73 (a)(2)(i)(B) is a performance deficiency which was reasonably within Entergys ability to foresee and correct and should have been prevented. Because the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy, the inspectors determined that the violation was a Severity Level IV (more than minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation. The information in the 10 CFR 50.73 report that was not submitted would not have adversely impacted any regulatory decisions by the NRC. Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B. (Section 4OA2.1.c)

.

REPORT DETAILS

4OA2 Problem Identification and Resolution

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

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described Entergys corrective action program at Indian Point. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, and Entergy procedure EN-LI-102, Corrective Action Program (CAP) Procedure, Revision 21. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Plan-of-the-Day, Operations Focus Meeting, Condition Review Group (CRG), Corrective Action Review Boards (CARB), and Self-Assessment Review Board (SARB) meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and radiation protection.

(1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generators, service water, main steam, auxiliary feedwater, core spray, residual heat removal, 125 volts direct current batteries, and 4 kilovolt equipment rooms. Additionally, the inspectors reviewed a sample of condition reports written to document issues identified through internal self-assessments, audits, and the operating experience program. The inspectors completed this review to verify that Entergy entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of condition reports issued since the last NRC biennial Problem Identification and Resolution inspection reports issued in June 2010 for Unit 2 and September 2011 for Unit 3. The inspectors also reviewed condition reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed Entergys completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed condition reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Entergys timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of condition reports associated with selected non-cited violations and findings to verify that Entergy personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Entergy actions related to identified equipment problems and trends in the auxiliary feedwater system and the sites emergency diesel generators.

(4) Trending The inspectors reviewed Entergys processes for identifying and addressing emergent and existing adverse trends in equipment and human performance. The inspectors conducted interviews with plant staff who conducted the department trend reviews, reviewed department trend reports, site quarterly trend reports, maintenance rule performance monitoring reports, a(1) action plans and evaluations as required by 10 CFR 50.65, and attended the SARB where the most recent site quarterly trend report was reviewed.

b. Assessment

(1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Entergy identified problems and entered them into the corrective action program at a low threshold. Entergy staff at Indian Point initiated 12,392 condition reports in 2011, 11,654 condition reports in 2012, and 7,479 condition reports through September of 2013. The inspectors observed supervisors at the Plan-of-the-Day, Operations Focus, CRG, CARB, and SARB meetings appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Entergy trended equipment and programmatic issues, and appropriately identified problems in condition reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Entergy personnel promptly initiated condition reports and/or took immediate action to address the issues.

However, the team did identify one instance where a long standing condition adverse to quality had not been entered into the CAP. The team identified boric acid deposits on a section of Unit 2 component cooling water (CCW) piping. The boric acid was likely from an overflow of the 22 boric acid storage tank occurring in December 2012 and not an active leak. After questioning by the inspectors, Entergy entered the condition into their corrective action program, cleaned the boric acid from the carbon steel CCW piping, and evaluated the condition of the piping. Given that the issue was an isolated instance and the CCW piping integrity was not affected, the violation was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Entergy entered the issue into the corrective action program as condition report CR-IP2-2013-04464.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, Entergy appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.

Entergy screened condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of condition reports reviewed, the inspectors noted that the guidance provided by Entergy corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. However, the inspectors did note some observations in Entergys prioritization and evaluation of the following issues:

Evaluation of a Leaking Pressurizer Safety Valve on Unit 2 In 2012, during plant startup after the unit 2 refueling outage, a unit 2 pressurizer safety valve was observed to be leaking. After several attempts to reseat the valve, the valve continued to leak and a decision was made to return to Mode 5 and replace the valve.

The same valve had leaked in 2004 and 2008. Pressurizer relief valves are removed and sent for testing and refurbishment offsite and replaced with a spare refurbished valve each outage. Entergy personnel had not monitored relief valve performance by unit serial number, so they did not realize the same individual valve had leaked in 2004, 2008, and 2012. In 2012, it was determined the leaking valve was constructed differently making it more susceptible to leakage. Since this was not diagnosed prior to 2012, the corrective actions developed to address leakage were more general recommendations and did not address or correct the actual deficient condition of the valve. Therefore, the deficient condition was never corrected and repetitive leakage occurred. However, the valves safety function to lift and relieve pressure was unaffected by seat leakage and no technical specification violation for reactor coolant leak rate was determined to have occurred. Therefore, the safety valve remained operable. The inspectors independently evaluated the deficiency for significance in accordance with the guidance in Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined the deficiency was of minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy. This issue is captured in Entergys corrective action program as CR-IP2-2012-2417.

Evaluation of Repetitive Essential Service Water System Leaks In 2008, several pinhole leaks were discovered in the essential service water system line to the service water radiation monitors. Condition report CR-IP2-2008-4268 was written, the leaks were repaired, and a modification was developed and approved to replace the service water piping with a different material which was less susceptible to chloride pitting. However, the modification was deferred and de-scoped from the 2010 and 2012 refueling outages and is now scheduled to be implemented during the 2014 outage. In 2013, eight additional leaks were identified in the same piping. Condition report CR-IP2-2013-3759 was written and identified that no bridging or monitoring strategy had been put in place when the modification was deferred as required by station procedures. The inspectors also noted that the evaluation did not evaluate if the leaks were from the same locations/welds as the 2008 leaks and noted that a white paper in the work order package for the repairs stated the cause of the leaks was microbiologically induced corrosion vice chloride pitting as determined by the 2008 and 2013 evaluations. Entergy entered the inspectors observations into their corrective action program as CR-IP2-2013-4345. The 2013 leaks were determined to be from different welds than 2008 leaks and the white paper, which was not a formal evaluation, was removed from the work orders to avoid confusion.

The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined these condition reports were deficiencies of minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

10 CFR 50.73 Reportability Issue The inspectors identified a legacy 10 CFR 50.73 reportability issue.

In 2008, several pinhole leaks in essential service water piping were identified. During the evaluation of these leaks, American Society of Engineers (ASME) code case N 513 had to be applied to evaluate structural integrity. During this evaluation, an area on the mixing tee was discovered to be below minimum wall thickness to ensure structural integrity was maintained and therefore, the system was inoperable and an ASME code repair was required. This condition existed longer than the technical specification allowed system outage time for essential service water of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Therefore, this should have been reported in 2008 as operations in a condition prohibited by technical specifications under 10 CFR 50.73 (a)(2)(i)(B) within 60 days of the date of discovery.

Entergy entered the issue into their corrective action program as CR-IP2-2013-4346 and developed corrective actions to discuss the 2008 event as part of a licensee event report to be submitted for the 2013 leaks. The enforcement aspects of this issue are discussed in Section 4OA2.1c.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Entergy identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective. The inspectors did observe some weaknesses in Entergys resolution of degraded conditions. For example:

Work Order System and Condition Report System do not communicate:

The inspectors identified a vulnerability in that Entergys corrective action program procedures allow condition reports with open corrective actions to be closed to the Work Order System. However, since the Condition Report System and the Work Order System are independent of one another and do not communicate, work orders relied upon to complete corrective actions can be deferred or not completed, but the corrective action program shows the actions to be completed. The inspectors identified two instances where condition reports with corrective actions were closed several years earlier and the associated work orders were still open or in planning. Specifically:

1. CR-IP2-2008-4268 for essential service water piping leaks developed corrective actions to ensure ASME code repair were conducted and all ASME Code required retests were completed. The condition report and corrective actions were closed to work order 165373 in 2008. These corrective actions were necessary to restore the system to an operable status. During the inspection, the inspectors discovered that several tasks for work order 165373 were still open.

One of these tasks included the completion of post repair function leakage checks, a required retest in accordance with the code traveler. There was no documentation this ASME code required retest was completed and the system had been returned to service. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. Since periodic system walkdowns were performed with the system at rated pressure between 2008 and 2013, system operability was established. The inspectors determined this deficiency was administrative in nature and of minor significance and, therefore, is not subject to enforcement action in accordance with the NRCs Enforcement Policy. Condition report CR-IP2-2013-04345 was written to document this issue.

2. CR-IP2-2011-03837 captured a repeat issue involving 16 monitors out of service for the Offsite Radiation Monitoring System. Entergy brought in the vendor, who provided an analysis and recommended ten corrective actions in IP-RPT-11-00041 to fix this issue. Seven of these corrective actions were closed to work order 305539 on March 4, 2012. During the inspection inspectors identified that work order 305539 was still in planning. Entergy reviewed the inspectors observation and determined the corrective actions were considered enhancements since dose assessment capability is still maintained by the site thus corrective actions were not untimely in accordance with Entergys corrective action program procedure. The inspectors reviewed Entergys response, concurred that the open corrective actions were enhancements and that the dose assessment capability was maintained. Therefore, the team determined no violation had occurred. Entergy entered this observation into their corrective action program as condition report CR-IP2-2013-4742.

Main Steam Safety Valve Modification Implementation:

Indian Point Units 2 and 3 have had repetitive failures of MSSV lift tests. Since 2009, at least one valve failed technical specification as-found lift setpoint test. Working with the safety valve vendor, Entergy developed a modification package to address one of the causes for these failures. An Engineering Change Package was developed and approved from 2011-2012 and the implementation of the modification began during the Unit 3 2013 refueling outage. The implementation schedule was developed to install the modification on each valve during its six year refurbishment preventive maintenance.

The inspectors noted that three of the MSSVs had failed multiple times. Of these valves, one was scheduled for the modification in 2017 and one in 2018. The remaining valve had received the modification during the 2013 outage. Considering two of the valves had failed their last two consecutive tests (each valve is tested every 4 years), it would appear more risk informed to ensure these valves were modified in a more timely manner. Although this does not represent a performance deficiency, Entergy captured the inspectors observation in their corrective action program as condition report CR-IP2-2013-4741 and are evaluating their implementation schedule for this modification.

Corrective Actions Not Captured Under Formal Process The NRC inspectors identified an instance of Entergy failing to use its corrective action program to capture corrective actions taken to address an adverse trend discussed in the lower tier Apparent Cause Evaluation (ACE) Report CR-IP3-2013-00292, Revision 1, dated July 11, 2013. The documentation of the corrective actions that were completed and proposed in the ACE did not effectively describe what Entergy actually did to address the issues identified in the adverse trend (the details of which are being withheld given their security-related nature). These actions were taken in an informal manner outside of the corrective action process and have not been captured in documentation related to the corrective action process documents, trend report documents, or incorporated in station procedures. Although the corrective actions were not formally captured, the corrective actions have been effective, and the team was concerned these corrective actions could be discontinued at any time. The issue is of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Entergy entered the issue into their corrective action program as condition report CR-IP2-2013-4743.

(4) Trending The inspectors reviewed Entergys processes for identifying and addressing emergent and existing adverse trends in equipment and human performance. Entergy was generally able to identify trends a low level using their monthly department trending process. These trends were rolled up to station level on a quarterly basis and action and monitoring plans were developed as appropriate. Additionally, the stations maintenance rule performance monitoring program also appears to be effective in evaluating system performance and identifying trends.

The inspectors had one observation in this area. Both the station trending program and the maintenance rule consider relatively short time periods by design when monitoring performance. This creates a vulnerability in ensuring longer term trends are identified and addressed appropriately. For equipment which is tested on a once an outage or longer basis, there are insufficient data points to determine if a trend in developing. A specific example of this vulnerability is demonstrated by the MSSV failures on unit 1 and 2. Testing is done on an outage basis and each valve is tested once every four years.

Thus a rolling 24 month average will not effectively predict an emerging trend for this equipment. MSSV failures, resulting in system inoperability and 10 CFR 50.73 reports, occurred in each refueling outage since 2009; however, this is not identified as a trend.

Entergy entered the inspectors observation into their corrective action program as condition report CR-IP2-2013-4747

c. Findings

(1) Failure to Submit a Required 10 CFR 50.73 Report.

(1)

Introduction.

The inspectors identified a Severity Level IV NCV of 10 CFR 50.73 (a)(2)(i)(B) for failure to make a required report to the NRC. Specifically in 2008, a section of essential service water piping was identified to be below the American Society of Engineers (ASME) code case N 513 minimum pipe wall thickness to ensure structural integrity was maintained and therefore, the system was determined to have been inoperable. This condition existed longer than the technical specification allowed system outage time for essential service water. Therefore, this should have been reported in 2008 as operations in a condition prohibited by technical specifications under 10 CFR 50.73 (a)(2)(i)(B) within 60 days of the date of discovery.

Description.

In September 2008, several pinhole leaks in essential service water piping were identified. During the evaluation of these leaks, American Society of Engineers (ASME) code case N 513 had to be applied to evaluate structural integrity.

During this evaluation, an area on the mixing tee was discovered to be below minimum wall thickness to ensure structural integrity was maintained and therefore, the system was inoperable and an ASME code repair was required. This condition existed longer than the technical specification allowed system outage time for essential service water of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Therefore, this should have been reported in 2008 as operations in a condition prohibited by technical specifications under 10 CFR 50.73 (a)(2)(i)(B) within 60 days of the date of discovery.

Entergy entered the issue into their corrective action program as CR-IP2-2013-4346 and completed corrective actions to discuss the 2008 event as part of a licensee event report 247-2013004 submitted on November 12, 2013 for leaks in the same system discovered in September 2013.

Analysis.

The inspectors determined that the failure to submit a notification required by 10 CFR 50.73 (a)(2)(i)(B) is a performance deficiency which was reasonably within Entergys ability to foresee and correct and should have been prevented.

Because the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy, the inspectors determined that the violation was a Severity Level IV (more than minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation. The information in the 10 CFR 50.73 report that was not submitted would not have adversely impacted any regulatory decisions by the NRC. The inspectors also evaluated the performance deficiency for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues, and determined it was minor since the performance deficiency was limited to a reporting issue.

Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.

Enforcement.

10 CFR 50.73 (a)(2)(i)(B) requires that a license submit a Licensee Event Report within 60 days of the date of discovery of any operation or condition which was prohibited by requirement in the plant's Technical Specifications. Indian Point Unit 2 Technical Specification 3.7.8, Service Water, requires the Essential Service Water Header to be operable or enter Technical Specification 3.0.3.

Technical Specification 3.0.3 requires the operators to place the plant in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Contrary to the above, from November 16, 2008 until November 12, 2013, Entergy failed to submit a licensee event report for a condition prohibited by Indian Point Unit 2 Technical Specifications 3.7.8 and 3.0.3 which was discovered on September 17, 2008 and clearly had existed for longer than the Technical Specification allowed outage time prior to discovery. However, because the violation was of very low safety significance and was entered into Entergys corrective action program (CR-IP2-2013-04346), this violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy, (NCV 05000247/2013012-01, Failure to Submit a Required 10 CFR 50.73 Report)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of condition reports associated with review of industry operating experience to determine whether Entergy appropriately evaluated the operating experience information for applicability to Indian Point and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Entergy adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that Entergy appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Plan-of-the-Day meetings, CRG meetings, and pre-job briefs.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. The inspectors performed these reviews to determine if Entergy entered problems identified through these assessments into the corrective action program, when appropriate, and whether Entergy initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

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

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

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

The inspectors reviewed the Employee Concerns Program files to ensure that Entergy entered issues into the corrective action program when appropriate. The inspectors also reviewed the results of and corrective actions from Indian Points most recent Independent Nuclear Safety Culture Review conducted in 2012.

b. Assessment During interviews, Indian Point staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On November 8, 2013, the inspectors presented the inspection results to Mr. J. Dinelli, General Manager Plant Operations, and other members the Indian Point staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

On December 17, 2013, the inspectors presented the results of NRC managements review of the inspection results, to Mr. R. Walpole, Licensing Manager and other members of the Indian Point staff.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

A. Ambrose - Emergency Preparedness

A. Iavicoli - Radiation Protection

B. McCarthy, Operations Manager

B. Taggart, Employee Concerns

C. Bristol, Maintenance

C. Hron, Reactor Operator Unit 3

D. Cagnon, Security Department Manager

D. Costabile, Security

D. Dewey, Assistant Operations Manager

D. Gagnon, Security Manager

D. Main, Operations

D. Mayer, Unit 1 Director

D. Smith - Radiation Protection

E. Firth, Corrective Action Program Manager

G. Dahl- Licensing

H. Robinson, Engineering

I. Sinert, Engineering

J. Kurt, Plant Operator, Unit 3

J. Baker, Shift Manager, Unit 2

J. Bazdaric, Interim Materials Supervisor, Materials, Purchasing and Contracts

J. Dinelli, General Manager Plant Operations

J. Kirkpatrick, Assistant General Manager Plant Operations

J. Miu, Engineering

J. Raffaele, Engineering Supervisor

J. Schaefer, Materials, Purchasing and Contracts Manager

L. Lubrano, Engineering

M. Kempski, Engineering Supervisor

M. Tesoriero, System Engineering Manager

M. Troy, Nuclear Oversight Manager

M. Tumicki, Corrective Action Program

M. Woodby, Engineering Director

N. Azevedo, Code Programs Supervisor

P. Bode, Operational Experience Coordinator

P. Conroy, Nuclear Safety Assurance Director

P. Stephen, Plant Operator, Unit 2

R. Aguiar, Senior Security Supervisor

R. Daley, Engineering

R. Dolanksy, ISI Program Manager

R. Grant III, Engineering

R. Martin - Emergency Preparedness

R. Pelke, Reactor Operator, Unit 2

R. Robenstein, Training

R. Tagliamonte, Radiation Protection Manager

R. Walpole, Licensing Manager

S. Manzione, Components Engineering Supervisor

T. Chan, Mechanical Systems Supervisor

T. Kelly. Engineering

T. McCaffrey, Design Engineering Manager

T. Thivierge, Senior Security Supervisor

V. Myers, Design Engineering

W. Wittich, Configuration Management Supervisor

NRC Personnel

J. Stewart, Senior Resident Inspector

J. Furia, Senior Health Physicist

J. Cherubini, Security Inspector

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

05000247/2013012-01 NCV Failure to Submit a Required 10 CFR 50.73 Report