ML022410064
| ML022410064 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  (DPR-026) |
| Issue date: | 08/28/2002 |
| From: | Miller H Region 2 Administrator |
| To: | Kansler M Entergy Nuclear Operations |
| References | |
| FOIA/PA-2003-0379, FOIA/PA-2003-0388 | |
| Download: ML022410064 (8) | |
Text
August 28, 2002 Mr. Michael R. Kansler Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -
INDIAN POINT NUCLEAR GENERATING UNIT 2
Dear Mr. Kansler:
On August 7, 2002, the NRC staff completed its mid-cycle plant performance assessment of Indian Point 2. In accordance with NRC Inspection Manual Chapter 0305 Operating Reactor Assessment Program, the mid-cycle review involved the participation of all technical divisions in evaluating the performance of your Indian Point 2 facility for the first half of the current assessment cycle, January 1 - December 31, 2002. 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.
Plant performance for the most recent quarter was within the Multiple/Repetitive Degraded Cornerstone Column of the NRCs Action Matrix based on a Red finding in the Initiating Events Cornerstone. NRC has maintained heightened oversight of the Indian Point 2 facility for the past several years. In May 2000, under guidelines of the NRC oversight process in effect at the time, the facility was designated an Agency Focus plant in light of persistent performance problems which were illustrated by several significant plant events, including a plant trip with complications in August 1999 and a steam generator tube failure in February 2000.
Subsequently, in October 2000, with a Red finding associated with the steam generator tube failure, we informed the previous plant owner, Consolidated Edison, that the plant was in the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix of the newly initiated NRC Reactor Oversight Process (ROP). NRC oversight has included expanded inspection efforts, key among them being an extensive team inspection in February 2001 which examined root causes of plant performance problems. Through these inspections and regulatory performance meetings, many held at or near the site, we have closely monitored station improvement efforts. These efforts were begun by Consolidated Edison. Upon assuming ownership, Entergy put in place the Fundamentals Improvement Plan (FIP), a more comprehensive improvement program building on self-assessments it conducted, as well as on NRC inspection findings. NRC has held open the Red finding past the normal four quarters stipulated in the ROP given the extent of the performance problems and to provide NRC an extended period to monitor results.
Mr. Michael R. Kansler 2
Since the beginning of this assessment cycle, regulatory performance meetings have been conducted in February, March, and May 2002, focusing on progress being made under the FIP.
Progress has also been monitored through continued expanded inspection efforts. In addition to the baseline inspections, for example, in April 2002 we conducted a supplemental inspection to review the licensed operator high failure rates during the 2001 annual requalification examinations. We also conducted a supplemental Problem Identification and Resolution (PI&R) inspection in June-July 2002, to examine Entergys progress in addressing the underlying performance weaknesses which contributed to the Multiple/Repetitive degraded cornerstones.
Through these and other inspection efforts over the past year, we determined that Indian Point 2 has operated in a manner that preserved public health and safety and that substantial progress has been made at the station. Significant additional resources have been committed by Entergy to improvement initiatives. New plant management has brought higher performance standards and levels of accountability to the station. Performance indicators, established by the FIP, have shown overall positive results. For example, corrective maintenance backlogs, operator work-arounds and control room deficiencies have been reduced substantially. Human error rates have decreased. The multi-year efforts to improve engineering and configuration control documentation have resulted in needed improvements, and these efforts continue.
Accordingly, we have concluded that the weaknesses underlying the August 1999 plant trip and February 2000 steam generator tube failure, which led to a significant reduction in safety margin, have been substantially addressed. We are, thus, closing the Red finding, which will move Indian Point 2 from the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix after the end of the third quarter, 2002.
Notwithstanding this action, our oversight of Indian Point 2 will remain above the NRC baseline program, in accordance with the Degraded Cornerstone Column of the Action Matrix. The mitigating systems cornerstone remains degraded due to the open Yellow finding related to operator requalification exam failures and associated training issues. Further, while less frequent and of less risk significance than before, events at the station and some inspection findings indicate continued efforts are needed to further strengthen plant performance. The preliminary White finding associated with the control room west wall fire barrier in the recent supplemental PI&R inspection illustrates this. Other findings and events indicate a need for continued efforts to improve the thoroughness of engineering reviews, to reduce instances of unplanned Technical Specification limiting conditions, to strengthen operator knowledge, and to improve control of contractors. As a result, within the parameters of the ROP, the cross-cutting issues in the area of human performance and corrective action, opened in the previous end-of-cycle assessment, will remain open. We plan to follow-up on Entergys progress in these areas through focused inspections by our resident inspection staff and region-based specialists. In addition to a supplemental inspection in December 2002, which will examine your response to the White finding, we plan inspections of your September 2002 licensed operator requalification examinations and Emergency Plan Exercise, and the Indian Point 2 fourth quarter 2002 refueling outage.
Mr. Michael R. Kansler 3
The enclosed inspection plan details the schedule for inspections through September 30, 2003.
The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature.
The last six months of the inspection plan is tentative and may be revised at the end-of-cycle review.
In addition, the NRC is in the process of finalizing a Temporary Instruction (TI) that will be used to review implementation of the Interim Compensatory Measures required by the Agencys Security Order to all commercial nuclear power plants dated February 25, 2002. Schedules have not yet been finalized, but it is anticipated that these inspections will begin within the next calendar quarter. Once finalized, the details will be communicated by separate correspondence.
In accordance with 10 CFR 2.790 of the NRCs Rules 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 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. We plan to further discuss this assessment of your performance at a regulatory performance meeting at the Cortlandt Town Hall, on September 4, 2002, at 7 p.m. Please contact Peter Eselgroth, Projects Branch Chief, at 610-337-5234 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
Hubert J. Miller Regional Administrator Docket No.50-247 License No. DPR-26
Enclosure:
Indian Point 2 Inspection/Activity Plan
Mr. Michael R. Kansler 4
cc w/encl:
F. Dacimo, Vice President - Operations J. Yelverton, Chief Executive Officer M. R. Kansler, Senior Vice President and Chief Operating Officer J. Herron, Senior Vice President R. J. Barrett, Vice President - Operations C. Schwartz, General Manager - Operations D. Pace, Vice President - Engineering J. Knubel, Vice President Operations Support J. McCann, Manager, Nuclear Safety and Licensing J. Kelly, Director of Licensing C. Faison, Manager - Licensing, Entergy Nuclear Operations, Inc.
H. Salmon, Jr., Director of Oversight, Entergy Nuclear Operations, Inc.
J. Fulton, Assistant General Counsel, Entergy Nuclear Operations, Inc.
W. Flynn, President, New York State Energy, Research and Development Authority J. Spath, Program Director, New York State Energy Research and Development Authority P. Eddy, Electric Division, New York State Department of Public Service C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law T. Walsh, Secretary, NFSC, Entergy Nuclear Operations, Inc.
Mayor, Village of Buchanan R. Albanese, Executive Chair, Four County Nuclear Safety Committee S. Lousteau, Treasury Department, Entergy Services, Inc.
M. Slobodien, Director Emergency Programs B. Brandenburg, Assistant General Counsel P. Rubin, Operations Manager Assemblywoman Sandra Galef, NYS Assembly County Clerk, Westchester County Legislature 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 Congresswoman Sue W. Kelly Congressman Ben Gilman Congresswoman Nita Lowey Senator Hilary Rodham Clinton Senator Charles Schumer J. Riccio, Greenpeace A. Matthiessen, Executive Director, Riverkeepers, Inc.
M. Kapolwitz, Chairman of County Environment & Health Committee A. Reynolds, Environmental Advocates
Mr. Michael R. Kansler 5
M. Jacobs, Executive Director, Westchester Peoples Action Coalition D. Katz, Executive Director, Citizens Awareness Network P. Gunter, Nuclear Information & Resource Service P. Leventhal, The Nuclear Control Institute K. Copeland, Pace Environmental Litigation Clinic R. Witherspoon, The Journal News
Mr. Michael R. Kansler 6
Distribution w/encl:
H. Miller, RA/J. Wiggins, DRA (1)
A. Blough, DRP W. Lanning, DRS J. Clifford, DRP B. Holian, DRP R. Crlenjak, DRS H. Nieh, RI EDO Coordinator P. Habighorst, SRI - Indian Point 2 S. Richards, NRR (ridsnrrdlpmlpdi)
D. Screnci, ORA N. Sheehan, ORA T. Walker, ORA P. Eselgroth, DRP DRS Branch Chief (5)
P. Milano, PM, NRR G. Vissing, PM, NRR (Backup)
S. Barber, DRP W. Cook, DRP J. McFadden, DRS P. Frechette, DRS D. Silk, DRS B. Platchek, DRP R. Junod, DRP R. Martin, DRP Ridsnrrdipmlipb Region I Docket Room (w/concurrences)
DOCUMENT NAME: G:\\BRANCH2\\ROP-3 FILES\\2002 Ip2 midcycleletter rev10.wpd After declaring this document An 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 E
NRR RI/DRP E
RI/ORA E
NAME WCook/WAC PEselgroth/PWE CCarpenter/PWE concurred by email BHolian/BEH HMiller/HM DATE 08/28/02 08/28/02 08/28/02 08/28/02 08/28/02 OFFICIAL RECORD COPY
Indian Point Inspection / Activity Plan 06/30/2002 - 09/30/2003 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 1 of 2 08/28/2002 12:54:08 Report 22 6
ASSESS
- AUGMENTED PI&R, ENGR, HUMAN PERFORMANCE Baseline Inspections 07/08/2002 07/12/2002 Identification and Resolution of Problems IP 71152B 2
Supplemental Program 07/08/2002 07/12/2002 Inspection For One Degraded Cornerstone Or Any Three White Inputs In A Strategic Performance Area IP 95002 2
1 7112203
- PUB RAD SAFETY - REMP Baseline Inspections 07/08/2002 07/12/2002 Radiological Environmental Monitoring Program IP 7112203 2
1 71121
- OCC RAD SAFETY Baseline Inspections 08/05/2002 08/09/2002 Access Control to Radiologically Significant Areas IP 7112101 2
Baseline Inspections 08/05/2002 08/09/2002 ALARA Planning and Controls IP 7112102 2
Baseline Inspections 08/05/2002 08/09/2002 Radiation Monitoring Instrumentation and Protective Equipment IP 7112103 2
Baseline Inspections 08/05/2002 08/09/2002 Performance Indicator Verification IP 71151 2
2 71130
- SECURITY-RESPONSE ATT3 Baseline Inspections 08/26/2002 08/30/2002 Response to Contingency Events (Protective Strategy and Implementation of Protective Strategy)
2 7111111B
- U2 L.O.REQUALIFICATION PROGRAM Baseline Inspections 09/16/2002 09/20/2002 Licensed Operator Requalification IP 7111111B 2
4 7111401
- EP EXERCISE & EP PI VERIFICATION Baseline Inspections 09/23/2002 09/27/2002 Exercise Evaluation IP 7111401 2
Baseline Inspections 09/23/2002 09/27/2002 Performance Indicator Verification IP 71151 2
2 7111108
- INSERVICE INSPECTION Safety Issues 11/04/2002 11/08/2002 Circumferential Cracking of Reactor Pressure Vessel Head Penetration Nozzles (NRC Bulletin 2001-01)
Baseline Inspections 11/04/2002 11/08/2002 Inservice Inspection Activities IP 7111108 2
2 71151
- PUB RAD SAFETY PI VERIFICATION Baseline Inspections 11/04/2002 11/08/2002 Performance Indicator Verification IP 71151 2
1 71121
- OCC RAD SAFETY Baseline Inspections 11/11/2002 11/15/2002 Access Control to Radiologically Significant Areas IP 7112101 2
Baseline Inspections 11/11/2002 11/15/2002 ALARA Planning and Controls IP 7112102 2
Baseline Inspections 11/11/2002 11/15/2002 Radiation Monitoring Instrumentation and Protective Equipment IP 7112103 2
Baseline Inspections 11/11/2002 11/15/2002 Performance Indicator Verification IP 71151 2
4 71152B
- PROBLEM IDENTIFICATION AND RESOLUTION Baseline Inspections 12/09/2002 12/20/2002 Identification and Resolution of Problems IP 71152B 2
1 SUPPLEME - SUPPLEMENTAL INSPECTION Supplemental Program 12/09/2002 12/20/2002 Supplemental Inspection For One Or Two White Inputs In A Strategic Performance Area IP 95001 2
1 7112201
- PUB RAD SAFETY - RETS Baseline Inspections 01/13/2003 01/17/2003 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems IP 7112201 2
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Indian Point Inspection / Activity Plan 06/30/2002 - 09/30/2003 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 2 of 2 08/28/2002 12:54:08 Report 22 7
7111121
- SSDI Baseline Inspections 01/20/2003 01/24/2003 Safety System Design and Performance Capability IP 7111121 2
Baseline Inspections 02/03/2003 02/07/2003 Safety System Design and Performance Capability IP 7111121 2
3 3/10+EXM
- U2 OPERATOR LICENSING INITIAL EXAMS Not Applicable 02/09/2003 02/13/2003 INDIAN POINT 2 INITIAL EXAM ( 3/10/03)
U01495 2
Not Applicable 03/10/2003 03/21/2003 INDIAN POINT 2 INITIAL EXAM ( 3/10/03)
U01495 2
1 71121
- OCC RAD SAFETY Baseline Inspections 02/24/2003 02/28/2003 Access Control to Radiologically Significant Areas IP 7112101 2
Baseline Inspections 02/24/2003 02/28/2003 ALARA Planning and Controls IP 7112102 2
Baseline Inspections 02/24/2003 02/28/2003 Radiation Monitoring Instrumentation and Protective Equipment IP 7112103 2
Baseline Inspections 02/24/2003 02/28/2003 Performance Indicator Verification IP 71151 2
1 71121
- OCC RAD SAFETY Baseline Inspections 05/19/2003 05/23/2003 Access Control to Radiologically Significant Areas IP 7112101 2
Baseline Inspections 05/19/2003 05/23/2003 ALARA Planning and Controls IP 7112102 2
Baseline Inspections 05/19/2003 05/23/2003 Radiation Monitoring Instrumentation and Protective Equipment IP 7112103 2
Baseline Inspections 05/19/2003 05/23/2003 Performance Indicator Verification IP 71151 2
1 71114
- EP PRGM REVIEW AND EP PI VERF Baseline Inspections 06/23/2003 06/27/2003 Alert and Notification System Testing IP 7111402 2
Baseline Inspections 06/23/2003 06/27/2003 Emergency Response Organization Augmentation Testing IP 7111403 2
Baseline Inspections 06/23/2003 06/27/2003 Emergency Action Level and Emergency Plan Changes IP 7111404 2
Baseline Inspections 06/23/2003 06/27/2003 Correction of Emergency Preparedness Weaknesses and Deficiencies IP 7111405 2
Baseline Inspections 06/23/2003 06/27/2003 Performance Indicator Verification IP 71151 2
1 71130
- SECURITY Baseline Inspections 07/14/2003 07/18/2003 Access Authorization Program (Behavior Observation Only)
Baseline Inspections 07/14/2003 07/18/2003 Access Control (Search of Personnel, Packages, and Vehicles: Identification and Authorization)
1 71122.02
- RADWASTE Baseline Inspections 08/18/2003 08/22/2003 Radioactive Material Processing and Transportation IP 7112202 2
5 7111117B
- PERMANENT PLANT MODS Baseline Inspections 09/22/2003 09/26/2003 Evaluation of Changes, Tests, or Experiments IP 7111102 2
Baseline Inspections 09/22/2003 09/26/2003 Permanent Plant Modifications IP 7111117B 2
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.