ML052100202

IR 05000247-050-03; 04/01/2005 - 06/30/2005, Indian Point Nuclear Generating Unit 2; Ti 2515/163, Operational Readiness of Offsite Power; Event Followup

ML052100202
Person / Time
Site:	Indian Point
Issue date:	07/29/2005
From:	Brian Mcdermott Reactor Projects Branch 2
To:	Dacimo F Entergy Nuclear Operations
References
TI 2515/163, FOIA/PA-2016-0148 IR-05-003
Download: ML052100202 (41)

Text

July 29, 2005 Mr. Fred R. Dacimo Site Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC INTEGRATED INSPECTION REPORT NO. 05000247/2005003

Dear Mr. Dacimo:

On June 30, 2005 the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Unit 2 (IP2). The enclosed integrated inspection report documents the inspection findings which were discussed with Mr. Paul Rubin, and other members of your staff, on July 20, 2005.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. Within these areas, the inspection consisted of a selected examination of procedures and representative records, observations of activities, and interviews with personnel.

Based on the results of the inspection, two findings of very low safety significance (Green) were identified. One of these findings was determined to involve a violation of NRC requirements.

However, because of its very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A. of the NRC Enforcement Policy. If you contest the NCV in this report, 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, D.C. 20555-001: with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Indian Point 2.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs 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).

Sincerely,

/RA/

Brian J. McDermott, Chief Projects Branch 2 Division of Reactor Projects

Mr. Fred R. Dacimo 2

Docket No. 50-247 License No. DPR-26

Enclosure:

Inspection Report No. 05000247/2005003 w/

Attachment:

Supplemental Information cc w/encl:

G. J. Taylor, Chief Executive Officer, Entergy Operations, Inc.

M. R. Kansler, President - Entergy Nuclear Operations, Inc.

J. T. Herron, Senior Vice President and Chief Operations Officer C. Schwarz, Vice President, Operations Support P. Rubin, General Manager - Plant Operations O. Limpias, Vice President, Engineering J. McCann, Director, Licensing C. D. Faison, Manager, Licensing, Entergy Nuclear Operations, Inc.

M. J. Colomb, Director of Oversight, Entergy Nuclear Operations, Inc J. Comiotes, Director, Nuclear Safety Assurance P. Conroy, Manager, Licensing, Entergy Nuclear Operations, Inc.

T. C. McCullough, Assistant General Counsel, Entergy Nuclear Operations, Inc.

P. R. Smith, President, 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 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 B. Brandenburg, Assistant General Counsel 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

Mr. Fred R. Dacimo 3

Congresswoman Nita Lowey Senator Hillary Rodham Clinton Senator Charles Schumer J. Riccio, Greenpeace A. Matthiessen, Executive Director, Riverkeeper, Inc.

M. Kapolwitz, Chairman of County Environment & Health Committee A. Reynolds, Environmental Advocates M. Jacobs, Director, Longview School D. Katz, Executive Director, Citizens Awareness Network P. Leventhal, The Nuclear Control Institute K. Coplan, Pace Environmental Litigation Clinic W. DiProfio, PWR SRC Consultant D. C. Poole, PWR SRC Consultant W. Russell, PWR SRC Consultant W. Little, Associate Attorney, NYSDEC R. Christman, Supt. Operations Training L. Cortopassi, Manager Training and Development

Mr. Fred R. Dacimo 4

Distribution w/encl:

S. Collins, RA M. Dapas, DRA S. Lee, RI OEDO R. Laufer, NRR J. Boska, PM, NRR B. McDermott, DRP D. Jackson, DRP P. Krohn, DRP C. Long, DRP S. Smith, DRP P. Habighorst, DRP, SRI - IP2 M. Cox, DRP, RI - IP2 R. Martin, DRP, OA Region I Docket Room (w/concurrences)

DOCUMENT NAME:E:\\Filenet\\ML052100202.wpd SISP REVIEW COMPLETE ____BJM______ (Reviewer's initials)

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 RI/DRP NAME PHabighorst /RA DJackson BMcDermott DATE 7/02/2005 07/29/2005 07/29 /05 OFFICIAL RECORD COPY

Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket No.

50-247 License No.

DPR-26 Report No.

05000247/2005003 Licensee:

Entergy Nuclear Northeast Facility:

Indian Point Nuclear Generating Unit 2 Location:

295 Broadway, Suite 3 Buchanan, NY 10511-0308 Dates:

April 1, 2005 - June 30, 2005 Inspectors:

P. Habighorst, Senior Resident Inspector, IP2 M. Cox, Resident Inspector, IP2 D. Jackson, Senior Project Engineer, Region I C. Long, Reactor Engineer, Region I T. Hipschman, Senior Resident Inspector, IP3 R. Berryman, Resident Inspector, IP3 R. Prince, Decommissioning Branch Inspector, DNMS, Region I S. Chaudry, Decommissioning Branch Inspector, DNMS, Region I M. Snell, Reactor Engineer, Region I L. Scholl, Senior Reactor Engineer, Region I J. Lilliendahl, Reactor Engineer, Region I K. Young, Reactor Inspector, Region I (In office review June 26 - 30)

Approved by: Brian J. McDermott, Chief Projects Branch 2 Division of Reactor Projects

Enclosure ii TABLE OF CONTENTS

SUMMARY

OF FINDINGS................................................... iii Summary of Plant Status..................................................... 1 REACTOR SAFETY......................................................... 1 1R01 Adverse Weather Protection....................................... 1 1R04 Equipment Alignment............................................ 1 1R05 Fire Protection.................................................. 2 1R06 Flood Measures................................................ 3 1R11 Licensed Operator Requalification Program........................... 4 1R12 Maintenance Effectiveness........................................ 4 1R13 Maintenance Risk Assessments and Emergent Work Control.............. 5 1R14 Personnel Performance During Non-routine Plant Evolutions and Events.... 6 1R15 Operability Evaluations........................................... 6 1R17 Permanent Modifications.......................................... 7 1R19 Post-Maintenance Testing........................................ 7 1R22 Surveillance Testing

............................................. 8 1R23 Temporary Plant Modifications

..................................... 9 1EP6 Drill Evaluation.................................................. 9 SAFEGUARDS............................................................ 10 3PP8 Fitness for Duty Program......................................... 10 OTHER ACTIVITIES........................................................ 10 4OA2 Problem Identification and Resolution............................... 10 4OA3 Event Followup................................................ 12 4OA5 Other Activities................................................ 16 4OA6 Meetings, including Exit.......................................... 19 4OA7 Licensee Identified Violations..................................... 19 SUPPLEMENTAL INFORMATION............................................ A-1 KEY POINTS OF CONTACT........................................... A-1 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED..................... A-2 LIST OF BASELINE INSPECTIONS PERFORMED......................... A-2 LIST OF DOCUMENTS REVIEWED..................................... A-3 LIST OF ACRONYMS............................................... A-13

Enclosure iii

SUMMARY

OF FINDINGS IR 05000247/2005003; 04/01/2005 - 06/30/2005, Indian Point Nuclear Generating Unit 2; TI 2515/163, Operational Readiness of Offsite Power; Event Followup The report covers a 3-month period of inspection by resident inspectors and eight regional inspectors. Two Green findings were identified, one of which was also determined to be a non-cited violaton (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," (SDP). The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.

A.

NRC Identified and Self-Revealing Findings Cornerstone: Mitigating Systems Green. The inspector identified a Green NCV of 10 CFR 50, App. B, Criterion XI "Test Control" involving an inadequate post work test following maintenance on auxiliary component cooling water discharge check valve 755A. This resulted in the failure to identify a condition which led to one train of the containment recirculation spray system being unavailable for greater than its technical specification (TS) allowed outage time. The finding is associated with the cross-cutting issue of problem identification and resolution in that the licensee's evaluation for CR IP2-2005-00252 failed to identify the deficiencies in the post maintenance test therefore no corrective actions were written to address this issue until prompted by the inspectors. (See Section 4OA2)

This issue is greater than minor because the performance deficiency adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective associated with ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. A Phase 3 SDP analysis was used to assess the deficiency due to modeling limitations of the Phase 2 SDP tools. The Phase 3 evaluation, performed by a Region I Senior Reactor Analyst, confirmed that this issue was of very low safety significance.

(Section 4OA3)

Green. The inspectors identified a Green finding involving inadequate corrective actions associated with the adequacy of plant procedures to be utilized during degraded grid voltage conditions and the operators knowledge of these procedures.

This finding is greater than minor because the performance deficiency adversely impacted the Mitigating Systems Cornerstone objective associated with procedure quality. The inspectors conducted a Phase 1 SDP screening and

Enclosure iv determined that the finding was of very low safety significance. The 138KV system voltage had been maintained greater than the minimum operating voltage throughout the year and implementation of the procedure was not required, therefore an actual loss of safety function did not exist during the period in question. (Section 4OA5)

B.

Licensee-Identified Violations.

A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and corrective actions are listed in Section 4A07 of this report.

Enclosure Report Details Summary of Plant Status Indian Point Unit 2 (IP2) began the inspection period at full power. On May 14, May 24, June 3, and June 20, Entergy initiated planned power reductions to between 95 - 97% of rated power to accomplish turbine stop/control valve testing and troubleshooting (Sections 1R15 and 1R22). The unit was at 100% power at the end of the inspection period.

1.

REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness 1R01 Adverse Weather Protection c.

Inspection Scope (71111.01 -

sample of actual adverse weather)

The inspectors reviewed Entergys administrative controls and implementation of a periodic maintenance program to ensure adequate protection to the ultimate heat sink in the event of severe debris on the Hudson River. On April 22, 2004, the inspectors walked down of the circulating water traveling screens, service water discharge strainers, screenwash system, and availability of alarm functions for degraded conditions. The inspectors verified the availability of mitigating systems in response to a loss of service water event, applicable system operating procedures, alarm response procedures, calibration records for associated instrumentation, outstanding maintenance deficiencies, temporary modifications, operator workarounds, and control room deficiencies that impact availability of the ultimate heat sink. The specific information reviewed is referenced in the Supplemental Information attachment at the end of this report.

b.

Findings No findings of significance were identified.

1R04 Equipment Alignment a.

Inspection Scope (71111.04Q - 3 samples, 71111.04S-1 Sample)

Partial System Walkdowns: The inspectors performed three partial system walkdowns during periods of system train unavailability in order to verify that the alignment of the available train was proper to support its required safety functions, and to assure that Entergy had identified and properly addressed equipment discrepancies that could potentially impair the capability of the available train. Referenced documents are listed in the Supplemental Information attachment at the end of this report. The following system walkdowns were performed:

On April 28, 2005, the inspector performed a partial system walkdown of 22 containment spray train while 21 containment spray pump was out of service for

2 Enclosure maintenance. The inspector reviewed system drawings and applicable checkoff lists (COL) to verify proper alignment of valves, and control switches. The inspector also observed the physical condition of the equipment during the verification.

On June 14, 2005, the inspector performed a partial system walkdown of gas turbine 1 fuel oil system while gas turbine 3 and the 23 emergency diesel generator were out of service for planned maintenance and testing. The inspector reviewed system drawings and the applicable checkoff list to verify proper alignment of valves. The inspector also observed the physical condition of the equipment during the verification.

On June 22, 2005, the inspector performed a partial system walkdown of 23 Auxiliary feedwater system while 21 auxiliary feedwater pump was out of service for planned maintenance and testing. The inspector reviewed system drawings and the applicable checkoff list to verify proper alignment of valves. The inspector also observed the physical condition of the equipment during the verification.

Full Equipment Alignment: The inspectors performed an extensive walkdown of the auxiliary feedwater system. The inspectors walked down the systems using COL 21.3, "Steam Generator Water Level and Auxiliary Boiler Feedwater," Rev 27 and the system flow diagram, drawing 9321-F-2019-112. The inspectors verified that all accessible components were in the proper position per the COL and verified that any position discrepancies were properly documented. The inspectors also verified that the field configuration was consistent with the current revision of the COL. Additionally, the inspectors evaluated the physical condition of the equipment during the walk down and reviewed open condition reports and work orders to evaluate if any would potentially impact system performance.

b.

Findings No findings of significance were identified.

1R05 Fire Protection a.

Inspection Scope (71111.05Q - 6 samples)

The inspector toured areas that were identified as important to plant safety and risk significance. The inspector consulted the Indian Point 2 Individual Plant Examination for External Events (IPEEE), Section 4.0, "Internal Fires Analysis," and the top risk significant fire zones in Table 4.6-2, "Summary of Core Damage Frequency Contributions from Fire Zones." The objective of this inspection was to determine if Entergy had adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, and had adequately established compensatory measures for degraded fire protection equipment. The inspector evaluated conditions related to: 1) control of transient combustibles and

3 Enclosure ignition sources; 2) the material condition, operational status, and operational lineup of fire protection systems, equipment and features; and 3) the fire barriers used to prevent fire damage or fire propagation. Reference material used by the inspector to determine the acceptability of the observed conditions in the fire zones are referenced in the Supplemental Information attachment at the end of this report. The areas reviewed were:

Zone 9 Zone 12 Zone 13A Zone 650 Zone 6A Zone 7A b.

Findings No findings of significance were identified.

1R06 Flood Measures e.

Inspection Scope (71111.06 - 1 external sample)

The inspector reviewed Entergys external flood analysis, flood mitigation procedures and design features to verify whether they were consistent with IP2's design requirements. The inspector walked down several internal and external plant areas that contained equipment important to safety. The inspector evaluated the condition and adequacy of mitigation equipment to assess whether flood protection design features were adequate. The specific information reviewed is referenced in the Supplemental Information attachment at the end of this report. The specific areas walked down by the inspector included:

Service Water pump area 15-ft elevation of the control building Circulating water pump area Intake Structure The inspector reviewed Entergys flood mitigation procedures, selected preventative maintenance and surveillance procedures on flood mitigation equipment. In addition, the inspector reviewed the corrective action program (CAP) to verify whether previous flood related issues had been appropriately evaluated and resolved. The specific information reviewed is referenced in the Supplemental Information attachment at the end of this report.

b. Findings No findings of significance were identified.

4 Enclosure 1R11 Licensed Operator Requalification Program a.

Inspection Scope (71111.11Q - 2 samples)

During the simulator exercise, the inspectors evaluated the teams performance for:

1) clarity and formality of communications; 2) correct use and implementation of emergency operating procedures (EOPs) and abnormal operating procedures (AOPs);

3) operators ability to properly interpret and verify alarms; 4) operators ability to classify events in a timely fashion, and 4) operators ability to take timely actions in a safe direction based on transient conditions. In addition, the inspectors evaluated the control room supervisors ability to exercise effective oversight and control of the crews actions during the exercise. The inspectors verified that the feedback from the instructors was thorough, that they identified specific areas for improvement, and that they reinforced management expectations regarding crew competencies in the areas of procedure use, communications, and peer checking. The inspectors also evaluated Entergys post-scenario critique.

On May 2, 2005, the inspectors observed simulator training for licensed operators on Operations Team 2A. The inspectors reviewed an "as found" simulator scenario, performed under lesson plan 2-INPO-AOP-2" to determine if the scenario contained: 1) clear event descriptions with realistic initial conditions; 2) clear start and end points; 3) clear descriptions of visible plant symptoms for the crew to recognize; and 4) clear expectations of operator actions in response to abnormal conditions.

On June 13, 2005, the inspectors observed simulator training for licensed operators on Operations Team 2B. The inspectors reviewed two annual simulator evaluations, performed under lesson plans SES-FR-S.1-E2 and SES-ECA-00.a to determine if the scenario contained: 1) clear event descriptions with realistic initial conditions; 2) clear start and end points; 3) clear descriptions of visible plant symptoms for the crew to recognize; and 4) clear expectations of operator actions in response to abnormal conditions.

b.

Findings No findings of significance were identified.

1R12 Maintenance Effectiveness a.

Inspection Scope (71111.12Q - 2 samples)

The inspectors reviewed the maintenance activities listed below, and recent performance issues with systems and components to assess the effectiveness of Entergys Maintenance Rule (MR) program. Using 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

the inspectors verified that Entergy was implementing their MR program in accordance

5 Enclosure with NRC regulations and guidelines, properly classifying equipment failures, and using the appropriate performance criteria for MR systems in 10 CFR 50.65 (a)(2) status.

The inspectors also reviewed work orders (WOs), and associated post-maintenance test activities to assess whether: 1) the effect of maintenance work in the plant had been adequately addressed by control room personnel; 2) work planning was adequate for the maintenance performed; 3) the acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing documents; and, 4) the equipment was effectively returned to service. Referenced documents are listed in the Supplemental Information attachment at the end of this report. The below-listed maintenance activities were observed and evaluated.

Safety Injection System The inspector performed a review of maintenance issues associated with the safety injection (SI) system since June 2004. The inspector evaluated the MR basis document to determine system boundaries and verified that the system was being properly tracked in accordance with the requirements of 10 CFR 50.65, "Requirements of Monitoring the Effectiveness of Maintenance." The inspector reviewed the quarterly system health report for the first quarter of 2005 and evaluated the system performance monitoring criteria for scope and accuracy. The inspector reviewed CRs for the system and evaluated their proper classification for the MR and compliance with ENN-DC-171, Rev.

2, "Maintenance Rule Monitoring."

22 Auxiliary Feedwater Train The inspector performed a review of maintenance issues associated with the 22 auxiliary feedwater train since April 2004. The inspector evaluated the MR basis document to determine system boundaries and verified that the system was being properly tracked in accordance with the requirements of 10 CFR 50.65, "Requirements of Monitoring the Effectiveness of Maintenance." The inspector reviewed the quarterly system health report for the fourth quarter of 2004 and evaluated the system performance monitoring criteria for scope and accuracy. The inspector reviewed CRs for the system and evaluated their proper classification for the MR and compliance with ENN-DC-171, Rev. 0, "Maintenance Rule Monitoring."

b.

Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control a.

Inspection Scope (71111.13 - 4 samples)

The inspectors observed selected portions of emergent maintenance work activities to assess Entergys risk management in accordance with 10 CFR 50.65(a)(4). The inspectors verified that Entergy took the necessary steps to plan and control emergent

6 Enclosure work activities, to minimize the probability of initiating events, and to maintain the functional capability of mitigating systems. The inspectors observed and/or discussed risk management actions with maintenance and operations personnel. The following planned activity was observed:

WO IP2-05-11908, 839H Modification The following three emergent activities were observed:

WO-IP2-05-14629, Containment Spray Discharge Valve 866 C WO IP2-05-00220, 22 Service Water Outlet Valve from CCW Heat Exchanger WO IP2-05-15246, GT-1 Repairs following Surveillance Failure b.

Findings No findings of significance were identified.

1R14 Personnel Performance During Non-routine Plant Evolutions and Events a.

Inspection Scope (71111.14 - 1 sample)

For the non-routine event described below, the inspectors reviewed operator logs, plant computer data, and strip charts to determine what occurred and how the operators responded, and to determine if the response was in accordance with plant procedures.

Main Generator Hydrogen Stator Coolant System Trouble and Inlet Low Pressure Alarms due to flow controller failure.

b.

Findings No findings of significance were identified.

1R15 Operability Evaluations a.

Inspection Scope (71111.15 - 5 samples)

The inspectors selected operability evaluations for review on the basis of their potential risk significance. The selected operability evaluations were developed by Entergy to address degraded or non-conforming conditions identified in the CRs listed below. The inspectors assessed the accuracy of the evaluations, the use and control of compensatory measures, if needed, and compliance with the TSs. The inspectors review included a verification that the operability evaluations were made as specified by procedure ENN-OP-104, "Operability Determinations." The technical adequacy of the evaluations were reviewed and compared to the TSs, Technical Requirements Manual (TRM), FSAR, and associated design basis documents.

7 Enclosure CR IP2-2004-06768, Operability Determination of 26 SWPs With 26 Zurn Strainer Low Blowdown Flow CR IP2-2005-01546, Assessment of Part 21 issue associated with Emergency Diesel Generator (EDG) governors due to potential for null voltage shift CR IP2-2005-02197, Operability Determination for 23 Safety Injection (SI) pump following indications of gas in the pump casing CR IP2-2005-02307, Operability Determination of recirculation pumps to assess difference in pump rotational speed than that used in system calculations.

CR IP2-2005-02051, Failure of No. 1 Turbine Stop Valve to Close during PT-SA067

b.

Findings No findings of significance were identified.

1R17 Permanent Modifications a.

Inspection Scope (71111.17A - 1 sample)

The inspectors reviewed a plant design change to install an isolation valve in a 3/4" test line associated with the safety injection system in accordance with design change package (DCP) ER-05-2-030, "Install Isolation Valve in 3/4" SI-1501R Line #31". The plant design change was reviewed to verify that: (1) the design bases, licensing bases and performance capability of the system had not been degraded by the modification and, (2) the modification performed did not place the plant in an unsafe condition.

During this evaluation the inspectors reviewed the design inputs, assumptions and associated calculations to determine design adequacy.

The inspectors reviewed the freeze seal method used for system isolation during the modification installation to ensure it conformed to industry standards. The inspectors also observed full scale mock-up testing performed prior to the installation and observed portions of the valve installation in the field. After the valve installation, the inspectors reviewed and observed the post modification testing performed to ensure system integrity.

b.

Findings No findings of significance were identified.

1R19 Post-Maintenance Testing a.

Inspection Scope (71111.19 - 5 samples)

The inspector reviewed post-work test (PWT) procedures and associated testing activities to assess whether: 1) the effect of testing in the plant had been adequately addressed by control room personnel; 2) testing was adequate for the maintenance WO performed; 3) acceptance criteria were clear and adequately demonstrated operational

8 Enclosure readiness consistent with design and licensing documents; 4) test instrumentation had current calibrations, range, and accuracy for the application; and 5) test equipment was removed following testing.

The selected testing activities involved components that were risk significant as identified in the IP2 Individual Plant Examination (IPE). The regulatory references for the inspection included TSs and 10 CFR 50, Appendix B, Criterion XIV, "Inspection, Test, and Operating Status." The following testing activities were evaluated:

WO IP2-05-16151, 866C Bucket Replacement WO IP2-04-13051, CCW Heat Exchanger Tube Plugging Activity WO IP2-05-11908, SI-839H Valve Replacement WO IP2-05-13576, 90 Day Follow-up NDE UT Inspection of 23 EDG 5th weld SW Pipe WO IP2-04-23593, PWT following 21 AFW Pump Shaft Alignment

b. Findings No findings of significance were identified.

1R22 Surveillance Testing a.

Inspection Scope (71111.22 - 7 samples)

The inspectors reviewed surveillance test procedures and observed testing activities to assess whether: 1) the test preconditioned the component tested; 2) the effect of the testing was adequately addressed in the control room; 3) the acceptance criteria demonstrated operational readiness consistent with design calculations and licensing documents; 4) the test equipment range and accuracy were adequate and the equipment was properly calibrated; 5) the test was performed per the procedure; 6) test equipment was removed following testing; and 7) test discrepancies were appropriately evaluated. The surveillance tests observed were based upon risk significant components as identified in the IP2 IPE. The regulatory requirements that provided the acceptance criteria for this review were 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," Criterion XIV, "Inspection, Test, and Operating Status," Criterion XI, "Test Control," and TS 6.8.1.a. The following test activities were reviewed:

PT-Q026F, "26 Service Water Pump", Rev. 8 - performed on April 5, 2005 PT-M21B, "22 Emergency Diesel Generator," Rev. 12 - performed on April 22, 2005 WO IP2-05-18082, No 1 Stop and Control Valve Testing - performed on June 3, 2005 WO IP2-05-22331, Electrical Tunnel Exhaust Fan Air Flow Test - performed on June 7, 2005 PT-Q55, "Pressurizer Pressure [Channel Operational Test and Channel Calibration]", Rev. 8-performed on June 8, 2005

9 Enclosure 2-SOP-10.1.1, Safety Injection Accumulators and Refueling Water Storage Tank Operations, Rev. 48 - performed on June 14, 2005 WO IP2-05-19227, Temporary TSC Diesel Annual Load Test - performed on June 22, 2005 b.

Findings No findings of significance were identified.

1R23 Temporary Plant Modifications a.

Inspection Scope (71111.23 - 1 sample)

The inspectors reviewed a temporary alteration, TA-05-2-017, to install a Foreign Material Exclusion (FME) cover over the spent fuel pool. This cover is required to support construction activities associated with the removal of existing fuel storage building ventilation duct work and supports. The inspectors reviewed the modification to ensure that there would be no adverse consequences.

b.

Findings No findings of significance were identified.

1EP6 Drill Evaluation a.

Inspection Scope The inspectors observed an emergency preparedness (EP) drill conducted on May 19, 2005. The inspectors used NRC Inspection Procedure (IP) 71114.06, "Drill Evaluation" as guidance and criteria for evaluation of the drill. The drill consisted of a loss of component cooling water, reactor coolant pump thermal barrier leak, steam generator tube leak followed by a loss of all on-site and off-site power. The inspectors observed the drill and conducted reviews from the participating facilities on-site, including the IP2 Plant Simulator, the Technical Support Center (TSC), and the Emergency Operations Facility (EOF). The inspectors focused the reviews on the identification of weaknesses and deficiencies in the classification and notification timeliness and quality and accountability of essential personnel during the drill. The inspectors were briefed on Entergys critique results and compared the licensees self-identified issues with the observations from the inspectors review to ensure that performance issues were properly identified.

b.

Findings No findings of significance were identified.

10 Enclosure 3.

SAFEGUARDS Physical Protection (PP) 3PP8 Fitness for Duty Program a.

Inspection Scope (71130l.08)

The inspector evaluated selected portions of this program relative to fatigue and work hour controls by: reviewing program procedures, implementing procedures, and records; conducting interviews with responsible personnel and plant employees; and reviewing payroll records, work hour tracking records, and overtime hour records for compliance with the Indian Point Energy Center Physical Security Plan.

b.

Findings No findings of significance were identified.

4.

OTHER ACTIVITIES 4OA2 Problem Identification and Resolution 1.

Daily Review

a.

Inspection Scope (71152)

The inspectors screened all items entered into Entergys corrective action program (CAP), as required by IP 71152, "Identification and Resolution of Problems," in order to identify repetitive failures or specific human performance issues for follow-up. This review was accomplished by reviewing paper copies of each condition report (CR).

b.

Findings No findings of significance were identified.

2.

PI&R Annual Sample - Reactor Protection System Calculational Error in Core Operating Limits Report (COLR) a.

Inspection Scope (71152 - 1 sample)

The inspectors selected CR-IP2-2004-6713, which identified that the overpower delta T setpoint calculation was inconsistent between the engineering calculation, technical specifications, and the core operating limit report. The inspectors reviewed CR-IP2-2004-06713, interviewed personnel, and reviewed associated documents to ensure that the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified, prioritized, and implemented. The

11 Enclosure inspectors evaluated these items against the requirements of Entergys corrective action program (CAP) as delineated in EN-LI-102, "Corrective Action Process."

b.

Findings No findings of significance were identified.

3.

PI&R Annual Sample - Cable Separation a.

Inspection Scope (71152 - 1 sample)

The inspectors performed a detailed review of the implementation of the Design Basis Improvement Project (PI-10) Electrical Separation Program including: post-1995 modification reviews, cable tray walkdowns inside and outside of containment, documentation reconstitution from the 1995 Cable Separation Program, and improvements to the cable separation controls in the design process. The inspectors noted that although significant work remains to complete the project (scheduled for completion in December 2005), substantial progress has been made. The inspectors reviewed documentation, interviewed staff, and walked down congested areas in the plant to assess the adequacy of the licensees modification reviews and cable tray walkdowns. The inspectors reviewed upgrades made to the Electrical Cable and Raceway Information System (ECRIS), and interviewed staff and contractors to verify that significant progress has been made toward resolving the data discrepancies identified in the Data Transfer Verification Reports (DTVRs). The inspectors verified that issues identified by the PI-10 program were properly characterized in the corrective action program, that operability evaluations were accurate and complete, and that appropriate corrective actions were implemented. The documents reviewed are listed in the supplemental information in the attachment to this report.

b.

Findings and Observations No findings of significance were identified, however inspectors identified a minor violation of 10CFR50 Appendix B, Criterion XVI in that a level "B" CR (CR-IP2-2004-01914) and several of its corrective actions were inappropriately closed. The licensee generated a new corrective action document (CR-IP2-2005-02602) to address the inappropriate corrective action closure. The violation is considered minor because it is not considered a precursor to a more significant event, and if left uncorrected would not lead to a more significant safety concern. In addition, this violation is not related to Reactor Oversight Program performance indicators or cornerstones. Although this issue should be corrected, it constitutes a violation of minor significance that is not subject to enforcement action in accordance with Section IV of the NRC Enforcement Policy.

Entergy management was informed of the minor violation of 10CFR50 Appendix B, Criterion XVI.

12 Enclosure

4.

PI&R Semi-annual Trend Review a.

Inspection Scope (71152 - 1 sample)

The inspectors reviewed Entergys CAP database over the last quarter of 2004 and first quarter of 2005 in order to assess the total number and significance of CRs written in various subject areas such as equipment and processes. The results were evaluated on a per quarter basis to identify any notable trends. The assessment specifically consisted of CR reviews in the following areas:

C Level "A" CRs: which required a full root cause analysis and review by the Corrective Actions Review Board (CARB) prior to closeout; and Level "B" CRs:

which required an apparent cause evaluation and an optional CARB review.

The number and significance of CRs associated with plant equipment previously identified as having reliability issues.

A review of the corrective action database to assess trends in the number of CRs written in the previous two quarters that were related to subject areas that reflect the quality of maintenance, work controls, operations, procedures, etc.

A review of the Indian Point Energy Center Quarterly Integrated Self-Assessment/Trend Reports for 4Q04 and 1Q05 written by the IPEC Quality Assurance Department, which contained Entergys assessments of CR trends during those quarters.

b.

Findings No findings of significance were identified.

5.

Cross-References to PI&R Findings Documented Elsewhere Inspection findings in other sections of this report also had implications regarding Entergys identification, evaluation and resolution of problems as follows:

Section 4AO3.1 - The licensees evaluation following the identification of a failed check valve did not identify deficiencies in the post work test therefore no corrective actions were written to address this issue.

Section 4A05.1 - Inadequate corrective actions resulted in inadequate training and operator knowledge of procedure for degraded grid voltage conditions.

4OA3 Event Followup 1.

(Closed) LER 05000247/2005001-00, Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for One Inoperable Train of ECCS Caused by an Inoperable Auxiliary Component Cooling Water Check Valve

13 Enclosure a.

Inspection Scope The inspectors reviewed the LER 05000247/2005001-00 and CR IP2-2005-00252, and evaluated the conditions that led to the loss of one train of the containment recirculation spray system (RSS) for greater than its technical specification (TS) allowed outage time.

On January 19, 2005, a quarterly surveillance was performed on 21 Auxiliary Component Cooling Water (ACCW) pump. The test failed due to the pump not achieving the required head. Subsequent troubleshooting identified the failure was due to the parallel pump's discharge check valve, valve 755A, being hung open thus short circuiting flow back to the suction of 21 ACCW pump. Entergy evaluated the condition and determined that the discharge check valve and its associated ACCW pump were inoperable since the maintenance performed in November 2004. One inoperable ACCW pump renders the associated containment RSS pump inoperable. The licensee identified that inadequate maintenance on a discharge check valve was the root cause of the event. The inspectors determined that this issue constituted a non-cited violation of Technical Specification Requirement 3.5.2.A which limits the allowed outage time for one ECCS train to less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This licensee identified finding involved a violation of TS 3.5.2., "ECCS - Operating". The enforcement aspects of the violation are discussed in Section 4OA7. This LER is closed.

In addition the inspectors reviewed the post maintenance testing (PMT) performed on the check valve to evaluate it for proper scope and depth based on the maintenance performed. The PMT was conducted in accordance with work order #IP2-03-29254.

b.

Findings Introduction. The inspectors identified a Green non-cited violation of 10 CFR 50 Appendix B Criterion XI, "Test Control" for a post maintenance test on ACCW discharge check valve 755A that was not sufficient to ensure the valve could perform its safety function. Entergy's evaluation of the check valve failure in CR IP-2005-00252 did not assess why the post maintenance test failed to detect the problem.

Description. On November 4, 2004, Entergy personnel performed a maintenance inspection of valve 755A, the discharge check valve for 22 ACCW pump. The technicians discovered that the valve disk was bound, and work was performed to establish freedom of movement for the disk. Following completion of the work, a post maintenance test was performed to verify operability. The post work test consisted of two steps: 1) running 22 ACCW pump and verifying that proper flow was achieved to ensure that the check valve would open and 2) running the parallel pump, 21 ACCW pump, and observing that 22 ACCW pump did not reverse rotate to verify the check valve operated in the closed direction. This PWT was completed satisfactorily and the system was returned to service. However, on January 19, 2005, during the investigation of an inservice test failure of the 21 ACCW pump, technicians found that the 755A check valve's disc was stuck partially open.

Analysis. The inspectors determined that the post-work testing on valve 755A involved a performance deficiency because the test was insufficient to ensure the valve could

14 Enclosure perform its design function to close and prevent reverse flow through the 22 ACCW pump. The examples in IMC 0612 Appendix E were not applicable to this specific finding. This issue was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone objective. One aspect of the objective is to ensure the availability of systems that respond to initiating events to prevent undesirable consequences.

The inspectors performed a Phase 1 screening in accordance with IMC 0612 and determined that the failure of the 755A check valve to close, by itself, would not have resulted in an actual loss of the safety function of an RSS train. Additional failures of the 22 CCW pump or loss of power to the 22 ACCW pump would have been required to cause the loss of cooling to the RSS pumps. While these additional failures are part of the licensing basis for the plant, they are not assumed when using the risk based significance determination process. As such the finding was determined to be of very low safety significance because, by itself, it did not result in the loss of a safety function and was not potentially significant due to a seismic, flooding or severe weather initiating event.

An SRA Phase 3 assessment, conducted because of the complexities and interactions involved, confirmed that this issue was of very low safety significance. This assessment used the Indian Point Unit 2 Standardized Plant Analysis Risk Model, Rev. 3.12., with modifications for both ACCW pumps to included the check valve failures to close and the associated conditions where this failure would result in a failure of the other ACCW pump. The assumed exposure time was the 77 days, between November 4, 2004 and January 19, 2005. The increase in internal core damage frequency was on the order of 1 core damage accident in 1,250,000 years of reactor operation (in the range of 8E-7 per year). The dominate core damage sequence was a loss of offsite power with: the failure of the 23 EDG, a stuck open PORV, and failure of HPR and LPR due to the inability to cool the RSS pump motors and failures of RHR recirculation valves due to the loss of power and EDG 23 failure. The SRA determined that external initiating events were not a significant contributor to the overall core damage frequence increase.

Specifically, the initiating event frequency for seismically inducted LOOP was significantly below the internal events LOOP frequency assumption and the ACCW pumps were not credited in fire safety shutdown path nor were they credited in the 480 volt switchgear room internal flooding event.

The finding is associated with the cross-cutting issue of problem identification and resolution in that the licensee's evaluation for CR IP2-2005-00252 failed to identify the deficiencies in the post maintenance test therefore no corrective actions were written to address this issue until prompted by the inspectors. (See Section 4OA2)

Enforcement. 10 CFR 50 Appendix B Criterion XI, "Test Control", state in part that a test program shall assure that all testing required to demonstrate that structures, system and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Contrary to this the licensee failed to provide a post work test of sufficient scope to ensure that ACCW

15 Enclosure check valve 755A could perform its intended safety function in the closed direction.

Because this violation is of very low safety significance and has been entered in the licensee's corrective actions program (CR IP2-2005-00252) this violation is being treated as a non-cited violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy: (NCV 50-247/05-03-01; Inadequate post work test resulting in a safety related system exceeding its AOT) 2.

(Closed) Unresolved Item (URI)05000247/2004005-01, RCP Seal Cooling for Alternate Safe Shutdown Procedure Strategies.

During a triennial fire protection inspection (NRC IR 05000247/2004005, August 20, 2004) the team identified an unresolved item concerning the ability of the alternate safe shutdown system (ASSS) procedure 2-AOP-SSD-1, "Control Room Inaccessibility Safe Shutdown Control," Revision 1, to ensure Indian Point Unit 2, could achieve and maintain post-fire safe shutdown of the plant for a severe fire in the 480 volt switchgear room. Specifically, the procedure may not have precluded an extended loss of reactor coolant pump (RCP) seal injection flow which could have led to RCP leakage above the Westinghouse Owners Group (WOG) guidance of 21 gallons per minute (gpm) after 13 minutes.

On June 1, 2005, the NRC issued Information Notice (IN) 2005-14, "Fire Protection Findings on Loss of Seal Cooling to Westinghouse Reactor Coolant Pumps." The inspectors reviewed the Information Notice and the following Entergy documents:

ASSS procedure AOP-SSD-1, "Control Room Inaccessibility Safe Shutdown Control," Revision 1 Calculation CN-PO-04-02, "Indian Point Unit 2 Appendix R Loss of All AC Power Recovery Analysis Operator timeline validation information provided by Entergy Nuclear Northeast The inspectors determined that Indian Point Unit 2 utilizes high temperature O-rings in their RCPs, the ASSS procedure provided instructions to secure the RCPs prior to the operators leaving the control room, and the operators had sufficient time to initiate charging. When the operators initiate charging prior to the required time, pressurizer level would be maintained in the indicating range with an assumed RCP seal leakage of 21 gpm per pump and a RCP purge volume of 50 gallons. Sufficient charging pump capability (98 gpm) existed for make-up to the RCP seals. During the inspection (NRC IR 05000247/2004005), operators demonstrated that they could perform the time critical steps of revision 1 of the ASSS procedure within the required times. Additionally, discussions with Entergy personnel indicated that revision 1 of the ASSS procedure, operated their RCPs consistent with the manufacturers guidance at the time the procedure was active. Revision 4 of the procedure operates the RCPs within the requirements of the current manufacturers guidance.

Based on the information provided in the IN 2005-14 and by Entergy, the inspectors determined that the ASSS procedure, AOP-SSD-1, Revision 1, would allow pressurizer

16 Enclosure level to be maintained in the indicating range with the assumed RCP seal leakage of 21 gpm and a RCP purge volume of 50 gallons. Therefore, the inspectors did not identify a violation of NRC requirements. Additionally, Entergy has initiated a CR IP2-2004-01445 that will review any additional WOG RCP operational guidance that may result from the WOGs review of NRC IN 2005-14. This unresolved item is closed.

4OA5 Other Activities

1.

TI 2515/163, Operational Readiness of Offsite Power

a.

Inspection Scope The inspector performed Temporary Instruction 2515/163, "Operational Readiness of Offsite Power." The inspector reviewed licensee procedures and supporting information pertaining to the offsite power system. The inspector reviewed this data against the requirements of 10 CFR 50.63; 10 CFR 50.65; 10 CFR 50 Appendix A General Design Criterion 17, "Electric Power Systems," and Plant Technical Specifications. This information was forwarded to NRC headquarters for further review.

b. Findings Introduction. The inspectors identified a green finding involving inadequate corrective actions associated with the adequacy of plant procedures to be utilized during degraded grid voltage conditions and the operators knowledge of these procedures.

Description. In June 2004, the inspectors performed Temporary Instruction (TI) 2515/156, "Operational Readiness of Offsite Power." As part of the inspection effort the inspectors reviewed plant procedures dealing with degraded voltage on the offsite power grid. The required plant actions for responding to degraded grid conditions are contained in procedure IP-SMM-OP-104 "Offsite Power Continuous Monitoring and Notification." The inspectors noted that the Site Management Manual (SMM) does not contain procedures that operators would normally reference for routine or abnormal plant operations. A review of the standard and abnormal operating procedures (SOPs and AOPs) associated with the system showed that no reference was provided in these procedures to the appropriate SMM procedure. Based on discussions with licensed plant operators the inspectors determined there was a general lack of knowledge that this specific procedure existed and that the minimum voltage for operability of the138KV system was not known by the operators and not readily available to them in any documents or procedures except for IP-SMM-OP-104. The inspectors discussed these deficiencies with site operations management in June 2004. Entergy documented these items in CR-IP2-2004-6535 and CR-IP2-2004-2447.

During the performance of TI 2515/163 in June 2005, the inspectors again evaluated procedures associated with degraded grid conditions and operator knowledge of IP-SMM-OP-104 to ensure the corrective actions from observations the preceding year had been adequately addressed. The inspectors found that a majority of the operators interviewed would not have referenced the appropriate procedure and did not know the

17 Enclosure minimum voltage requirements for system operability. The inspectors reviewed condition reports relating to offsite power and found that no CRs were written to specifically address the operators lack of knowledge identified the previous year. A review of corrective actions for condition reports associated with procedure quality showed that the licensee evaluated the procedure to determine if the SMM was the appropriate place for its inclusion and additional corrective actions were written to provide the operating limits in the technical specification basis and in SOP 27.1.1 "Operation of 345 KV and 138 KV Components." Entergy determined that the SMM was the appropriate manual for the procedure and the technical specification basis change had not yet been submitted.

Analysis. The inspectors determined that this was a performance deficiency since the corrective actions associated with existing CRs (CR-IP2-2004-6535 and CR-IP2-2004-2447) did not correct the operator lack of knowledge on how to mitigate grid problems resulting in low voltage on the 138 KV system. In addition, procedural inconsistencies that were previously identified were not adequately addressed. Entergy procedure EN-LI-102 Rev.1 "Corrective Action Process" requires that appropriate corrective actions be developed and implemented to correct adverse conditions. It is reasonable that Entergy was cognizant that this requirement existed and the deficiencies should have been prevented. Traditional enforcement does not apply since there were no actual safety consequences or potential for impacting the NRCs regulatory function, and the finding was not the result of any willful violation of NRC requirements or Entergys procedures.

This finding was determined to be greater than minor because it impacted the Mitigating Systems Cornerstone Objective, and was associated with the cornerstones procedure quality attribute. The inspectors determined that without adequate operator training to ensure the operators would follow the steps specified in IP-SMM-OP-104, the standard and abnormal operating procedures would be inadequate to ensure appropriate compensatory measures would be established during a degraded grid condition. In addition, the SOPs and AOPs associated with the 138kV system would not guide the operators to IP-SMM-OP-104 or list it as an interfacing document. A review of training records identified that while the SMM procedure had been placed in the training document database, there was no formal training associated with the procedure. Based on these factors the inspectors determined that the SOPs and AOPs associated with the 138KV system were inadequate to address a degraded voltage condition. This issue has been placed in Entergys corrective actions program as CR-IP2-2005-1814. The inspectors conducted a Phase 1 SDP screening and determined that the finding is of a very low safety significance since the performance deficiency does not represent an actual loss of safety function. The 138KV system voltage had been maintained greater than the minimum operating voltage throughout the year, and procedure entry would not have been required.

This finding is associated with the cross-cutting issue of problem identification and resolution in that it resulted from inadequate corrective actions associated with a previously identified issue. (See Section 4OA2)

Enforcement. No violation of regulatory requirements occurred since corrective action issues related to the non safety-related 138KV system are outside of the scope of

18 Enclosure 10 CFR 50 Appendix B. (FIN 50-247/05-03-02; Inadequate corrective actions associated with training, procedural adequacy and operator knowledge on methods to address degraded grid)

2.

On-site Fabrication of Components and Construction of an ISFSI

a.

Inspection Scope (IP 60853 1 - sample)

The inspector evaluated the design, supporting documentation, and construction activities associated with the ISFSI pad. The inspection consisted of interviews with cognizant personnel, observation of field work activities and review of documentation.

Entergy procured a batching plant to allow for the onsite preparation and mixing of the concrete to be used in the pouring of the Indian Point Independent Spent Fuel Installation Facility (ISFSI) pad. The inspector discussed the mechanisms established to ensure that a proper mix would be achieved, necessary test samples would be collected and lab test results communicated in a timely manner. The inspector noted that Entergy had made arrangements with a qualified contractor to provide oversight of batch plant operations during the pouring of the ISFSI pad. The inspector noted that the availability of a batch plant within the Protected Area would allow for timely transport of the prepared concrete mix, minimizing transit time after mixing and the initiation of a pour.

The inspector observed ongoing construction work in the field. ISFSI pad subsoil preparation work was complete with the engineered backfill in-place. The installation of the rebar was in progress. The inspector inspected the rebar that was already installed and observed work activities that were in progress. The inspector discussed work activities with the construction manager and other cognizant personnel and verified that personnel were knowledgeable of the design requirements. The inspector reviewed design documents and associated calculations to confirm that ISFSI pad parameters were bounded by the Safety Analysis requirements for the Holtec dry cask storage system to be utilized at Indian Point.

The inspector observed activities associated with the pouring of the ISFSI pad on May 16, 2005. Entergy had made arrangements for a fleet of concrete trucks to be available to transport concrete directly from the onsite batching plant to the ISFSI pad. The inspector observed activities in the batching plant control room and noted that appropriate controls were established to ensure that the mix of feed material was properly monitored to provide the desired batch composition in accordance with design specifications.

The inspector observed the collection of test samples and witnessed slump and air entrainment tests in the field. Entergy personnel stated that at least one truck was rejected based on failure to meet the air entrainment values (i.e., test sample was less than 4% for oxygen). Discussions with cognizant personnel indicated that personnel were knowledgeable of the test requirements and the procedure to be followed in the

19 Enclosure event that a sample failed to meet design specifications. The inspector noted that a vehicle was staged in the field for storage of test samples that were to be cured and tested for compressive strength.

The inspector observed the performance of vibration activities associated with the pour of the concrete pad. The inspector observed that the vibration of the concrete was being limited to the outer regions of the poured areas. The inspector discussed this with the licensee and as a result the vibration activities were expanded to other areas of the concrete pad. All other activities associated with the pouring of the ISFSI concrete pad were adequately controlled to meet design specifications.

b.

Findings No findings of significance were identified.

4OA6 Meetings, including Exit Exit Meeting Summary On July 20, 2005, the inspectors presented the inspection results to Mr. P. Rubin and other Entergy staff members, who acknowledged the inspection results presented. The inspectors asked the licensee what materials examined during the inspection should be considered proprietary. No proprietary information is presented in this report.

4OA7 Licensee Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements, which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a NCV.

TS 3.5.2 requires that the allowed outage time for one train of ECCS equipment be limited to less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Contrary to this the licensee determined that one ACCW pump and thus its associated recirculation pump were inoperable between November 4, 2004 and January 19, 2005. This was identified in the licensees corrective actions process under CR-IP2-2005-00252. This finding was considered to have very low safety significance since no actual loss of safety function occurred and did not screen as risk significant due to seismic, flooding or severe weather initiating events.

ATTACHMENT: SUPPLEMENTAL INFORMATION

A-1 Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel E. Anderson Lead Engineer, Cable Separation Program Improvements T. Barry Security Manager T. Beasley System Engineer L. Bello Records Management Clerk T. Foley System Engineer C. Wend Radiation Protection Manager C. Bergeren In-Service Testing Engineer J. Boccio I&C Superintendent J. Comiotes Director, Nuclear Safety Assurance P. Conroy Manager, Licensing F. Dacimo Site Vice President G. Dahl Technical Specialist, Licensing G. Dean Assistant Operations Manager - Training R. DeCensi Technical Support Manager R. Drake Supervisor, Mechanical Design Engineering D. Gately Assistant Radiation Protection Superintendent G. Hinrichs Project manager F. Inzirillo Emergency Planning Manager T. Jones Nuclear Safety/Licensing Specialist, Licensing R. Kalantari Contractor, EPM (Engineering Services Division Manager W. Mahlmeister Technical Lead, Cable Separation Program Improvements D. Mayer Unit 1 Project Manager B. Meek System Engineer V. Myers Systems Engineering Primary Systems Supervisor P. Peloquin Project Engineer S. Petrosi Manager, Design Engineering J. Raffaele Supervisor, Electrical Design Engineering V. Renzi Contractor, EPM (Software Support and Operations Manager)

B. Rokes Licensing Engineer H. Santis Project Construction Manager C. Schwarz Vice President, Operations Support G. Schwartz ISFSI Project Manager J. Skonieczny Project Engineer A. Stewart Licensing D. Smith Scheduling and Work Order Coordinator R. Sutton Systems Engineer J. Tuohy Manager, Cable Separation Program Improvements J. Ventosa Site Operations Manager

A-2 Attachment C. Wend Radiation Protection Manager S. Wilke Fire Protection Engineer NRC Personnel D. Caron Physical Security Manager LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 05000247/2004005-01 URI RCP Cooling for Alternate Safe Shutdown Procedure Strategies (Section 4OA3.1)05000247/2005001-00 LER Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for One Inoperable Train of ECCS Caused by an Inoperable Auxiliary Component Cooling Water Check Valve Opened and Closed 05000247/2005003-01 NCV Inadequate post work test resulting in a safety related system exceeding its AOT 50000247/2005003-02 FIN Inadequate corrective actions associated with training, procedural adequacy and operator knowledge on methods to address degraded grid LIST OF BASELINE INSPECTIONS PERFORMED 71111.01 Adverse Weather Protection 1R01 71111.04 Equipment Alignment 1R04 71111.05 Fire Protection 1R05 71111.06 Flood Protection Measures 1R06 71111.11 Operator Requalification Inspection 1R11 71111.12 Maintenance Effectiveness 1R12 71111.13 Maintenance Risk Assessment and Emergent Work Control 1R13 71111.14 Personnel Performance During Non-routine Plant Events 1R14 71111.15 Operability Evaluations 1R15

A-3 Attachment 71111.17 Permanent Modifications 1R17 71111.19 Post-Maintenance Testing 1R19 71111.22 Surveillance Testing 1R22 71111.23 Temporary Plant Modifications 1R23 71114.06 EP Drill 1EP6 71130.08 Fitness for Duty Program 3PP8 71152 Problem Identification and Resolution 4OA2 71153 Event Followup 4OA3 60853 On-Site Fabrication of Components and Contruction of an ISFSI 4OA5 TI 2515/163 Operational Readiness of Offsite Power 4OA5 LIST OF DOCUMENTS REVIEWED Section 1R01: Adverse Weather Protection Procedures SOP 22.1, Wash Water System and Traveling Screen Operation, Revision 22 2-ARP-SJF, Cooling Water and Air, Revision 34 LARP 28, Unit 2 Service Water Screen Trouble, revision 4 2-ARP-018, Traveling Water Screen Trouble, Revision 0 2-AOP-SW-1, Service Water Malfunction, Revision 2 IP2-ICPM-0407-D09 IP2-ICPM-0408-D09 Work Orders IP2-04-14549 IP2-04-8962 IP2-04-8962 IP2-04-9393 IP2-04-8756 IP2-04-34615 IP2-02-1130 IP2-05-00700 IP2-03-5853 IP2-05-00801 Condition Reports CR-IP2-2005-1471 CR-IP2-2005-1595 CR-IP2-2005-1598 CR-IP2-2005-1602 CR-IP2-2005-1643 CR-IP2-2005-1646

A-4 Attachment Temporary Alterations TA-03-2-11, Strainer Blowdown Line TA-04-2-052, 21 Traveling Water Screen High Differential Level TA-04-2-170, Install temporary trash rack for Unit 1 Dock Drawings 9321-F01-238-4 9321-F-2011 9321-F-2012 Miscellaneous FSAR Section 9.6.1 Section 1R04: Equipment Alignment Procedures 2-COL 31.1, Gas Turbine 1, Revision 7 2-COL-10.2.1, Containment Spray, Revision 18 2-COL-21.3, Steam Generator Water Level and Auxiliary Boiler Feedwater, Revision 17 Drawings A260586-10, Gas Turbine #1 Flow Diagram Fuel Forwarding System A260587-06, Gas Turbine #1 Fuel Oil System 312901-10, One Line Diagram Gas Turbine Generator #1 27 9321-2018 9321-F-2019-112 A240128-05 Section 1R05: Fire Protection Procedures SMM-DC-901, "IPEC Fire Protection Program Plan," Rev. 1 ENN-DC-161, "Transient Combustible Program," Rev. 1 ENN-DC-127, "Control of Hot Work and Ignition Sources," Rev.1 Fire Protection Implementation Plan, Pre-Fire Plans Pre-Fire Plans, PFP-167, Rev. 0 May 2004, "Unit 1 Gas Turbine (GT-1), Elev. 15'-0"

A-5 Attachment FP-16, "Handling and Storage of Flammable and Combustible Liquids and Compressed Gas Cylinders", Rev. 8 PFP-211, General Floor Plan - Primary Auxiliary Building Condition Reports CR-IP3-2005-02002 CR-IP2-2005-01383 for Compressed Gas CR-IP2-2004-00609 CR-IP2-2003-00765 CR-IP2-2005-01338 Miscellaneous NRC Information Notice 99-17, Problems Associated with Post-Fire Safe-Shutdown Circuit Analyses NRC Information Notice 2005-007, Results of Heymc Electrical Raceway Fire Barriers System Full Scale Fire Testing IPEC Security Fire Watch Sheet Dates of May 23 through May 30, 2005 IP2 Appendix R Issues and Impairment Description as of April 19, 2005 Section 1R06: Flood Protection Measures Condition Reports CR IP3-2005-02250 CR IP3-2005-02349 Drawings IP3V-503-0010 Intake Structure Plan 12'X 16' Traveling Screens 31-38, Rev. 1 9321-LL-12003 Intake Structure EL 15'0" Floor Access Hatch Key Plan, Section and Details, Rev. 0 Procedures IP-EP-AD13 IPEC Emergency Action Level Technical Bases, Rev. 1 OAP-008 Severe Weather Preparations, Rev. 0 IP-SMM-MA-118 Foreign Material Exclusion, Rev. 0 Section 1R11: Operator Requalification Miscellaneous SES-ECA-00.a, PT-412A Fails Low, Station Auxiliary Transformer Fails, Main Generator Trip, Loss of all AC SES-FR-S.1-E2, Loss of CCW, Steam Break in Turbine Building, ATWS, Failure of All MSIVs to Close, Loss of Offsite Power

A-6 Attachment 2-INPO-AOP-2, CCW Pump Trips with Failure of Standby Pump to Auto Start, RCP Thermal Barrier HX Leak, RCP High Vibration IP-EP-120 Revision 1, Emergency Classification MC 0609 Appendix I Section 1R12: Maintenance Effectiveness Condition Reports IP2-2004-03152 IP2-2005-00935 IP2-2005-00370 IP2-2005-05532 IP2-2004-06364 IP2-2004-06531 IP2-2005-00398 IP2-2004-03516 IP2-2004-03518 IP2-2004-02262 IP2-2004-02246 IP2-2004-02248 IP2-2004-04847 IP2-2005-00264 IP2-2005-01437 Procedures ENN-DC-121, "Maintenance Rule", Rev. 2 ENN-DC-143, "System Health Reports", Rev. 5 ENN-DC-172, "Maintenance Rule (a)(3) Periodic Assessment", Rev. 0 ENN-DC-171, Attachment 9.1, "Screening & Functional Failure (FF) Determination Form",

Rev. 1 Miscellaneous Indian Point Energy Center Maintenance Rule Basis Document, Safety Injection System, Rev. 0 IP-2 Safety Injection System Unavailability, June 8, 2005 Indian Point Energy Center Maintenance Rule Program Quarterly Report, First Quarter 2005 Unit 2 Safety Injection System Second Quarter 2004 System Health Report Unit 2 Auxiliary Feedwater Fourth Quarter 2004 System Health Report Indian Point 2 Maintenance Rule Basis Document Auxiliary Feedwater, revision 4 Indian Point 2 Auxiliary Feedwater Unavailability 2 year rolling average Section 1R13: Maintenance Risk Assessment and Emergent Work Control Procedures EOP ES 1.3, Transfer to Recirculation PT-2Y11A, Gas Turbine 1 Blackstart Timing Work Orders WO-IP2-05-00220 WO-IP2-05-15246

A-7 Attachment Section 1R15: Operability Evaluations Calculations FMX-00227-00, Pipe Flow Calculation of Service Water System WCAP-12655, Emergency Diesel Generator Loading Study Condition Reports CR-IP2-2004-06768 CR-IP2-2005-02501 CR-IP2-2005-06407 CR-IP2-2005-01546 CR-IP2-2005-02197 CR-IP2-2005-02307 Procedures ENN-OP-104, Reasonable Expectation of Operability, revision 2 2-PT-SA067, Main Turbine Stop and Control Valves, Revision 1 Miscellaneous UFSAR Section 9.6.1, Service Water System 2-ARP-SJF, Rev 34 Window 4-4, Service Water Strainers Trouble 2-SOP-24.1, Rev 55, Service Water System ENN-OP-104, Rev 2, Operability Determinations IP2 LL Stop Valve Troubleshooting Plan IP2 Lower Left Stop Valve Options Westinghouse Vendor Manual IL 1250-3702 UFSAR Seciton 10.2.3 10CFR21-0089, Report on Defects and Non-Compliance concerning Woodward Governors IPEC Gas Intrusion Monitoring Plan Section 1R17, Permanent Plant Modifications Drawings UFSAR Figure 6.2-1 Sheet 2 Revision 178 Miscellaneous ER-05-2-030, Install Isolation Valve In 3/4" SI-1501R Line #31 PPG-C-001-A Revision 8, Freeze Sealing of Stainless Steel Piping TRP-5106 Revision 0, Freeze Stop - Liquid Nitrogen NRC Inspection Manual Part 9900 Technical Guidance, Mechanical - Freeze Plugs

A-8 Attachment Section 1R19, Post Maintenance Testing Condition Reports IP2-2005-02340 Work Orders WO-05-13576 WO-03-18955 WO-04-23593 WO-05-14629 WO-05-16151 Drawings 9321-F-2019-112, Flow Diagram Boiler Feed Water S-000214-01, Containment Spray Valve Discharge Stop Valve MOV 866C 9321-F-3006-92, Single Line Diagram 480V MCC 26A and 26B Miscellaneous Operability Evaluation IP2-2005-02340 Ultrasonic Examination Report 05UT163 Ultrasonic Examination Report 05UT162 Ultrasonic Examination Report 05UT161 Ultrasonic Examination Report 05UT160 MOV 866C Troubleshooting Plan Section 1R22: Surveillance Testing Procedures PT-Q55, "Pressurizer Pressure", Rev. 8 PT-M16, "Electrical Tunnel Exhaust Fan Air Flow Test", Rev. 15 2-PT-Q026F, "26 Service Water Pump", Rev 8 FMX-00227, "Flow Calculation of Service Water System", Rev 1 2-SOP-10.1.1, Safety Injection Accumulator and Refueling Water Storage Tank Operations, rev. 48 2-SOP-10.6.4, Operation and Control of Non-Automatic Containment Isolation Valves, rev. 6 TOI-281 Revision 1, Temporary TSC Diesel Operation PT-M21B, 22 EDG Load Test Rev. 18

A-9 Attachment Condition Reports CR-IP2-2001-00170 Miscellaneous WO IP2-05-18082, No. 1 Stop and Control Valve Testing WO IP2-05-22331, Electrical Tunnel Exhaust Fan Air Flow Test WO IP2-05-09277, Loaded Surveillance Test Run for Temporary TSC Diesel Drawings 9321-F-2735-136, Flow Diagram Safety Injection System A235296-65, Flow Diagram Safety Injection System (UFSAR Figure 6.2-1) sheet 2 A226804-13, Technical Support Center One Line Diagram - Power Section 1R23, Temporary Alterations Miscellaneous UFSAR Section 14.2.1, Fuel Handling Accident UFSAR Section 9.3.1.1.3, 9.3.1.2.3, 9.3.2.3, Spent Fuel Pool Cooling Loop UFSAR Section 9.10, Fuel Storage Building Ventilation System ENN-DC-136, Rev 8, Temporary Modifications Section 1EP6: Emergency Plan Drill Procedures IP-EP-120, "Emergency Classifications," Rev. 0 IP-EP-130, "Emergency Notification and Mobilization," Rev. 2 IP-EP-430, "Site Assembly, Accountability and Relocation of Personnel Offsite," Rev. 1 IP-EP-220, "Technical Support Center," Rev. 0 IP-EP-250, "Emergency Operations Facility," Rev. 3 Condition Reports CR-IP2-2005-01968, CR-IP2-2005 -01969 CR-IP2-2005-02035 CR-IP2-2005-02060 CR-IP2-2005-02035 CR-IP2-2005-01971

A-10 Attachment Miscellaneous Entergy Nuclear Northeast Indian Point Energy Center, Unit 2, May 19, 2005 Drill Scenario Indian Point Energy Center Emergency Preparedness Summary of Performance for Training Drill on May 19, 2005 Section 3PP8: Fitness for Duty Program Security Training records for Range Qualifications, Annual T&Q, and Inclusion Training Sample of Security Payroll records for November 28, 2004 - February 19, 2005 Sample of Security Fatigue Hour tracking records for November 28, 2004 - February 19, 2005 Security Shift rosters for November 28, 2004 - February 19, 2005.

Section 40A2: Problem Identification and Resolution Condition Reports CR-IP2-2004-06713 CR-IP2-2003-07438 CR-IP2-2004-01059 CR-IP2-2004-01241 CR-IP2-2004-01452 CR-IP2-2004-01454 CR-IP2-2004-01914 CR-IP2-2004-01922 CR-IP2-2004-01932 CR-IP2-2004-02572 CR-IP2-2004-02693 CR-IP2-2004-03209 CR-IP2-2004-03211 CR-IP2-2004-03275 CR-IP2-2004-03487 CR-IP2-2004-05497 CR-IP2-2004-05501 CR-IP2-2004-05502 CR-IP2-2004-05505 CR-IP2-2004-05559 CR-IP2-2004-05565 CR-IP2-2004-05677 CR-IP2-2004-05678 CR-IP2-2004-05679 CR-IP2-2004-05750 CR-IP2-2004-05752 CR-IP2-2004-05754 CR-IP2-2004-05755 CR-IP2-2004-05844 CR-IP2-2004-05912 CR-IP2-2004-05913 CR-IP2-2004-05914 CR-IP2-2004-05916

A-11 Attachment CR-IP2-2004-05930 CR-IP2-2004-05931 CR-IP2-2004-05954 CR-IP2-2004-05955 CR-IP2-2004-05956 CR-IP2-2004-05957 CR-IP2-2004-05977 CR-IP2-2004-05979 CR-IP2-2004-06048 CR-IP2-2004-06818 CR-IP2-2004-06837 CR-IP2-2005-00011 CR-IP2-2005-00011 CR-IP2-2005-00128 CR-IP2-2005-00728 CR-IP2-2005-00729 CR-IP2-2005-00731 CR-IP2-2005-00793 CR-IP2-2005-00794 CR-IP2-2005-00949 CR-IP2-2005-01065 CR-IP2-2005-01229 CR-IP2-2005-01230 CR-IP2-2005-01231 CR-IP2-2005-01234 CR-IP2-2005-01235 CR-IP2-2005-01236 CR-IP2-2005-01237 CR-IP2-2005-01238 CR-IP2-2005-01239 CR-IP2-2005-01240 CR-IP2-2005-01241 CR-IP2-2005-01242 CR-IP2-2005-01243 CR-IP2-2005-01244 CR-IP2-2005-01651 CR-IP2-2005-02602*

CR-IP2-2005-02708*

• Generated as a result of this inspection Work Orders WO-IP2-04-24647 WO-IP2-04-24648 WO-IP2-04-24652 WO-IP2-04-30793 WO-IP2-04-30796 WO-IP2-04-30797 WO-IP2-04-32106

A-12 Attachment WO-IP2-04-32783 WO-IP2-04-32820 WO-IP2-05-11412 WO-IP2-05-13609 WO-IP2-05-13615 WO-IP2-05-13695 WO-IP2-05-14725 WO-IP2-05-15288 WO-IP2-05-16948 WO-IP2-05-19415 WO-IP2-05-19417 Engineering Requests ER-IP2-05-19341 ER-IP2-05-19342 ER-IP2-05-19343 ER-IP2-05-19344 Cable Separation Program Documentation OIRR-P1733-001, Cable Separation Program Open Item Resolution Report, Rev 0, 4/20/05 Design Basis Improvement Project PI-10, Electrical Separation Program Improvements, Rev 2, 8/19/04 ENN-EE-S-011-IP2, Electrical Separation Design Review Standard, Rev 0 AR-P1733-001, Cable Separation Anomaly Report, Rev 0, 5/20/05 ENN-DC-187, ECRIS Users Guide, Rev 0, 11/22/04 ENN-DC-169, Electrical Cable and Raceway Information System (ECRIS), Rev 0, 7/8/04 ENN-EE-S-010-IP2, Electrical Separation Design Criteria, Rev 0, 6/1/05 IP2-RPT-05-00017 2R16 VC Electrical Separation Tray Walkdowns, Rev 0, 2/17/05 DTVR-P1760-001, ECRIS Update for Channel Separation, Rev 0, 5/13/05 LSSVR-P1733-001, Cable Separation Upgrades, Rev 0, 5/10/05 ADR-P1686-001, Non-Cable Separation Anomaly Disposition Report, Rev 0, 8/26/04 IP2-RPT-05-13695, Phase II Summary Review of Cables Installed Post 1995, Rev 0, 3/25/05 Calculation EGP-S80-010-1, Cable Segregation by Service Class, Rev 1, 11/8/89 Procedures PT-Q52, Overtemperature Differential Temperature and Overpower Differential Temperature Bistables, rev. 25 Miscellaneous Indian Point Unit 2 Core Operating Limits Report Control Room Graph RPC-6 Westinghouse Issue Report 04-349-M004

A-13 Attachment Section 40A3 Calculations CN-PO-04-02,Indian Point Unit 2 Appendix R Loss of All AC Power Recovery Analysis Using Treat 2.02, Rev. 1 Condition Reports CR-2004-01445 Information Notice Information Notice 2005-14, Fire Protection Findings on Loss of Seal Cooling to Westinghouse Reactor Coolant Pumps NRC Inspection Reports 05000247/2004005, August 2004 Procedures AOP-SSD-1, "Control Room Inaccessibility Safe Shutdown Control," Revision 1 AOP-SSD-1, "Control Room Inaccessibility Safe Shutdown Control," Revision 4 Miscellaneous Documents Alternate Safe Shutdown System Operator Time Lines Fire Protection Program Plan, Revision 9 Fire Protection Program Plan, Revision 10 WOG-05-36, Westinghouse Owners Group, Reactor Coolant Pump Seal Performance for Appendix R Assessments, WCAP-16396-NP, January 28, 2005 LIST OF ACRONYMS ACCW auxiliary component cooling water AFW auxiliary feedwater ASSS Alternate Safe Shutdown System AOP abnormal operating procedure CARB corrective actions review board CFR Code of Federal Regulations COL check off list DCP design change package DTVR Data Transfer Verification Report ECRIS Electrical Cable and Raceway Information System EDG emergency diesel generator EOF Emergency Operations Facility EOP emergency operating procedure EP emergency preparedness FME foreign material exclusion IMC inspection manual chapter

A-14 Attachment INPO Institute of Nuclear Power Operations IN Information Notice IP Inspection Procedure IP2 Indian Point 2 IPE individual plant examination IPEC Indian Point Energy Center IPEEE individual plant examination of external events IR Inspection Report ISFSI Indian Point independent spent fuel installation facility MR maintenance rule NCV non cited violation NRC Nuclear Regulatory Commission PWT post work test RCP Reactor Coolant Pump RSS Recirculation Spray System SDP significance determination process SOP standard operating procedure TI temporary instruction TS technical specification TSC Technical Support Center WOG Westinghouse Owners Group