IR 05000286/2020003

Integrated Inspection Report 05000286/2020003

ML20303A069
Person / Time
Site:	Indian Point
Issue date:	10/28/2020
From:	Daniel Schroeder Reactor Projects Branch 2
To:	Vitale A Entergy Nuclear Operations
Schroeder D
References
IR 2020003
Download: ML20303A069 (14)

Text

October 28, 2020

SUBJECT:

INDIAN POINT ENERGY CENTER, UNIT 3 - INTEGRATED INSPECTION REPORT 05000286/2020003

Dear Mr. Vitale:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Energy Center, Unit 3. On October 15, 2020, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Indian Point Energy Center, Unit 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, X /RA/

Signed by: Daniel L. Schroeder Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No. 05000286 License No. DPR-64

Enclosure:

As stated

Inspection Report

Docket Number: 05000286 License Number: DPR-64 Report Number: 05000286/2020003 Enterprise Identifier: I-2020-003-0073 Licensee: Entergy Nuclear Operations, Inc.

Facility: Indian Point Energy Center, Unit 3 Location: 450 Broadway, Generation Support Building Buchanan, NY 10511-0249 Inspection Dates: July 1, 2020, to September 30, 2020 Inspectors: N. Floyd, Senior Resident Inspector S. Obadina, Resident Inspector K. Warner, Senior Health Physicist Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Indian Point Energy Center, Unit 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. A licensee-identified non-cited violation is documented in report section 71111.1

List of Findings and Violations

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

Additional Tracking Items

None.

PLANT STATUS

Unit 3 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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. Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather associated with Tropical Storm Isaias on August 4, 2020.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) 32 safety injection pump after maintenance and testing on July 10, 2020

(2) 32 emergency diesel generator after maintenance and testing on August 11, 2020

(3) 32 component cooling water pump after maintenance and testing on September 28, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the auxiliary feedwater system on September 1, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fuel storage building (pre-fire plans PFP-315 and PFP-316) on July 15, 2020

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on July 20, 2020, and an unannounced drill on August 17, 2020.

71111.06 - Flood Protection Measures

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) 31, 31A, and 31B electrical manholes on September 15, 2020

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated operator performance during a licensed operator requalification examination on August 31, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Chemical volume and control system on August 5, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Elevated risk due to 32 safety injection pump maintenance and testing on July 8, 2020

(2) Yellow risk due to 32 auxiliary feedwater pump maintenance and testing on September 21, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) (CR-IP3-2020-01711) City water technical specification surveillance requirement SR 3.7.7.1 identified as potentially non-conservative on July 23, 2020 (2) (CR-IP3-2020-02053) CH-FCV-111B (blender outlet to volume control tank) leakby on August 27, 2020

71111.18 - Plant Modifications

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

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) EC-86073, installation of temporary air compressor in place of Unit 3 instrument air compressor due to air-to-water leak

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Diesel driven fire pump test after engine rebuilt on July 1, 2020

(2) 31 battery charger full load test after preventative replacement of control card and diodes on July 30, 2020

(3) 31 instrument air compressor after maintenance and testing to repair an air-to-water leak on August 10, 2020

(4) 32 emergency diesel generator after maintenance and testing to repair emergency output breaker on August 11, 2020

(5) Appendix R diesel generator functional test after preventative maintenance on August 24, 2020

(6) 31 emergency diesel generator functional test after repair of engine lube oil filter housing leak on September 1, 2020

(7) 32 auxiliary feedwater pump after planned maintenance and testing on September 21, 2020

(8) 32 component cooling water pump after seal replacement on September 24, 2020

(9) 33 emergency diesel generator fuel oil day tank level limit switches after replacement on September 28, 2020

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) The inspectors evaluated the conduct of a routine emergency preparedness drill on September 23, 2020.

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Conduct of an emergency preparedness tabletop drill on August 19,

71124.01 - Radiological Hazard Assessment and Exposure Controls

The inspectors previously performed portions of the inspection procedure and documented it in Indian Point Integrated Inspection Report 05000247/2020002 and 05000286/2020002 (Agencywide Documents Access and Management System (ADAMS) Accession No.

ML20223A284) dated August 10, 2020. During this inspection, the inspectors completed all required portions of the inspection procedure to credit sample completion.

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated radiological protection-related instructions to plant workers.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.

(1) The inspectors evaluated the licensee's physical and programmatic controls for highly activated or contaminated materials (non-fuel) stored within the spent fuel.

(2) The inspectors evaluated licensee controls when exiting contaminated areas and the radiological controlled area.

Radiological Hazards Control and Work Coverage (IP Section 03.04) (2 Samples)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) The inspectors evaluated in-plant radiological conditions and controls during facility walkdowns, including entry into an infrequently accessed area.

(2) The inspectors observed pre-job briefs and work inspecting fuel bundles in the fuel storage building. This involved work in the spent fuel pool.

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:

(1) 31 waste hold-up tank room

(2) Reviewed procedural changes since the last inspection to determine the adequacy of access controls for high radiation areas and very high radiation areas

(3) Evaluated the adequacy of a locked high radiation area brief and controls Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

OTHER ACTIVITIES - BASELINE

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

MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) July 1, 2019, through June 30, 2020

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) July 1, 2019, through June 30, 2020

MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1) July 1, 2019, through June 30, 2020

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) July 1, 2019, through June 30, 2020

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) July 1, 2019, through June 30,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

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

(1) Verify Grand Gulf Confirmatory Order EA-17-132/153 Commitments (ADAMS Accession No. ML18072A191):

• Element B: Verified Entergy conducted annual training for all Indian Point workers in 2020 emphasizing that willfulness will not be tolerated.

• Element D: Verified Entergy planned to complete annual effectiveness reviews at Indian Point in 2020.

• Element H: Verified Entergy conducted an organizational health survey at Indian Point in

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, states in part that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, from November 7, 2000, to present, the licensee did not promptly identify and correct a non-conservative technical specification associated with the city water surveillance requirement SR 3.7.7.1, which was a condition adverse to quality that impacted the safety function of the city water system. Specifically, the surveillance requirement to verify city water header pressure was insufficient to assure that an adequate volume of city water remained available as a back-up source for the auxiliary feedwater system under certain accident conditions.

Significance/Severity: Green. The inspectors evaluated this finding in accordance with NRCs IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and determined the finding to be of very low safety significance (Green) because the city water tank had maintained its functionality based on a review of past tank level measurements.

Corrective Action References: CR-IP3-2020-01711 and CR-IP3-2020-01949 Observation: Verification of Confirmatory Order EA-17-132/153 92702 CONF Confirmatory Order EA-17-132 and EA-17-153, ADAMS Accession No. ML18072A191, was issued on March 12, 2018, which contained actions to be implemented fleet-wide by Entergy Operations, Inc. as agreed upon during an alternate dispute resolution process. These actions included commitments to conduct fleet-wide communications to employees at all Entergy sites, training, causal evaluations, and organizational health surveys.

The inspectors verified the corrective actions committed to in alternate dispute resolution Confirmatory Order EA-17-132/153 for Indian Point as of September 30, 2020. These actions included:

• Element B: Entergy conducted annual training on the intolerance of willful misconduct for 2020. A computer-based-training course (FCBT-ADM-INTGRT) was previously developed and assigned to all Indian Point personnel. Entergy deployed an annual refresher training for all Indian Point workers in 2020. The completion status was at 88 percent in August, which exceeded the 80 percent effectiveness review criteria for the end of year. Indian Point wrote two condition reports (CR-IP3-2020-02221 and -02030) to address multiple discrepancies associated with an error in how the training was being assigned to staff using the fleet procedure EN-TQ-107, General Employee Training. These discrepancies were captured as part of a self-assessment completed in September 2020 and corrective actions were initiated to clarify the procedure.

• Element D: Entergy planned to complete the required annual effectiveness reviews for corrective actions in 2020 at Indian Point. Indian Point performed a follow-up assessment of its corrective action program in June 2020 and concluded that it was effective. The annual effectiveness review is due in December 2020. The inspectors verified that Entergy had actions in place to complete this review at Indian Point and will include those results in an annual letter to the Region I Administrator.

• Element H: An organizational health survey was conducted in September 2020 for all station personnel that provided insights into the organizational health at Indian Point. The survey results showed a generally improving trend overall; however, there were a few departments with declines in response to specific questions. Entergy is giving these departments priority for follow-up to better understand the survey results.

Indian Point confirmed readiness to close the Confirmatory Order except for the remaining open actions for the effectiveness review and notifications to the NRC. The inspectors determined that integrity concerns were not pervasive within the Indian Point workforce and did not significantly impact plant safety.

The inspectors concluded that Indian Point was complying with the requirements of confirmatory order EA-17-132/153 in

EXIT MEETINGS AND DEBRIEFS

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

• On July 23, 2020, the inspectors presented the radiological hazard assessment and exposure controls inspection results to Robert Walpole, Regulatory and Performance Improvement Director, and other members of the licensee staff.

• On October 15, 2020, the inspectors presented the integrated inspection results to Anthony J. Vitale, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures 0-SOP-WEATHER- Severe Weather Preparations Revision 2

2

71111.05 Calculations IP3-CALC-FP-02795 Combustible Loading Calculation for IP3 Fire Hazards Revision 2

Analysis

Miscellaneous SEP-FPP-IP-001 IPEC Fire Protection Program Plan Revision 6

Procedures EN-DC-161 Control of Combustibles Revision 21

EN-TQ-125 Fire Brigade Drills Revision 10

71111.06 Corrective Action CR-IP3-2015-515

Documents

Engineering EC 15481 Remove Corroded Cable Supports in Manhole 31A 06/11/2009

Changes

Procedures 0-ELC-418-GEN Manhole Inspections Revision 8

Work Orders 52944107

71111.12 Corrective Action CR-IP3-2020-0741

Documents

Miscellaneous EN-DC-153 Preventive Maintenance Component Classification Revision 21

Work Orders 541612

71111.15 Procedures 2-Graph-TC-29 City Water Storage Tank Level Revision 3

71111.19 Corrective Action CR-IP3-2020-2120

Documents CR-IP3-2020-2268

71111.19 Procedures 0-PMP-427-CCW Inspection/Repair of the Component Cooling Water Pump Revision 3

3-IC-PM-I-E-31BC 31 Battery Charger Preventative Maintenance Revision 8

3-PT-M042B Diesel Fire Pump Test Revision 13

3-PT-Q139 Appendix R Diesel Generator Functional Test Revision 3

Work Orders 00550388

2822910

2912935

2921944

00550986

71124.01 Procedures EN-RP-100 Radiation Worker Expectations Revision 12

EN-RP-108 Radiation Protection Posting Revision 22

Inspection Type Designation Description or Title Revision or

Procedure Date

2702 Corrective Action CR-HQN-2017-01968

CONF Documents CR-HQN-2018-00578

Miscellaneous LO-HQNLO-2020- Pre-NRC Inspection Assessment for Confirmatory Order September 17,

00007 EA-17-132/EA-17-153 2020

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