IR 05000286/2020004

Integrated Inspection Report 05000286/2020004

ML21028A633
Person / Time
Site:	Indian Point
Issue date:	01/28/2021
From:	Daniel Schroeder Reactor Projects Branch 2
To:	Vitale A Entergy Nuclear Operations
Schroeder D
References
IR 2020004
Download: ML21028A633 (19)

Text

January 28, 2021

SUBJECT:

INDIAN POINT ENERGY CENTER, UNIT 3 - INTEGRATED INSPECTION REPORT 05000286/2020004

Dear Mr. Vitale:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Energy Center, Unit 3. On January 19, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

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

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Indian Point Energy Center, Unit 3.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Indian Point Energy Center, Unit 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, X /RA/

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

Enclosure:

As stated

Inspection Report

Docket Number: 05000286 License Number: DPR-64 Report Number: 05000286/2020004 Enterprise Identifier: I-2020-004-0074 Licensee: Entergy Nuclear Operations, Inc.

Facility: Indian Point Energy Center, Unit 3 Location: 450 Broadway, Generation Support Building Buchanan, NY 10511-0249 Inspection Dates: October 1, 2020, to December 31, 2020 Inspectors: N. Floyd, Senior Resident Inspector Z. Coffman, Resident Inspector S. Obadina, Resident Inspector J. Ambrosini, Senior Emergency Preparedness Inspector K. Mangan, Senior Reactor Inspector P. Ott, Operations Engineer J. Rady, Emergency Preparedness Inspector K. Warner, Senior Health Physicist Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Indian Point Energy Center, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Establish Adequate Written Instructions for Emergency Diesel Generator Maintenance Resulted in a Significant Lube Oil Leak Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.5] - 71111.12 Systems NCV 05000286/2020004-01 Operating Open/Closed Experience A self-revealed Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings was identified when Entergy failed to establish adequate written instructions for the performance of maintenance for the 31 emergency diesel generator (EDG). Specifically,

Entergy maintenance procedure 0-GNR-406-ELC, for the 31 EDG lube oil filter, did not provide quantitative instructions to tighten/torque the bolts on the lube oil filter housing cover which resulted in a significant lube oil leak and the diesel generator being declared inoperable.

Additional Tracking Items

None.

PLANT STATUS

Unit 3 began the inspection period at rated thermal power. On November 12, 2020, Unit 3 reduced power to 95 percent for main turbine stop and control valve testing. Unit 3 was returned to rated thermal power on November 12, 2020. Unit 3 remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:

(1) EDGs, Appendix R diesel, and safety-related outdoor water storage tanks on December 16, 2020

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (1 Sample)

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

(1) 31/33 EDGs and safety trains on buses 2A/5A while the 32 EDG was out of service for maintenance on November 2, 2020

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

(1) The inspectors evaluated system configurations during a complete walkdown of the safety injection system on October 19, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)

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

(1) Circulating and service water pumps building (pre-fire plan PFP-385) on October 30, 2020

(2) Primary auxiliary building, general floor plan, 41-foot elevation, and component cooling water pumps (PFP-305A, PFP-306, and PFP-306A) on December 2, 2020

(3) Cable spreading room and battery rooms (PFP-352 and PFP-352A) on December 16, 2020

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the Unit 3 licensed operator requalification exam results for the annual operating exam and biennial written exam on November 24, 2020.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during a planned down power and main generator turbine control and valve testing on November 12, 2020.

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

(1) The inspectors observed and evaluated operator performance during a licensed operator requalification examination on November 18, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

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

(1) Revised maintenance procedure and bolt torque checks for EDGs on November 2, 2020

(2) Through-wall pipe leak and corrective actions for service water system line 1093 on December 10, 2020

(3) Review of licensee's maintenance rule (a)(3) periodic evaluation on December 28, 2020

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Diode and control card replacements on the station battery chargers as a corrective action in response to root cause CR-IP2-2019-01298 performed in accordance with NRC Operating Experience Smart Sample 2019/01 Commercial Grade Dedication, Procurement, and Design Control on December 3, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

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

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

(1) Elevated risk due to maintenance and testing on 34 steam generator atmospheric relief valve (MS-PCV-1137) and calibration of the 34 service water pump load sequencer on October 20, 2020

(2) Elevated risk due to 32 EDG and 34 battery charger maintenance on November 3, 2020

71111.15 - Operability Determinations and Functionality Assessments

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

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

(1) (CR-IP3-2020-02667) Unit auxiliary transformer oil analyses increased trend of dissolved gasses on November 16, 2020 (2) (CR-IP3-2020-03156) Service water pipe leak in the EDG valve room upstream of SWN-30 on December 10, 2020

71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)

The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from October 26 to October 30, 2020:

(1) Safety Evaluation - Operation of Auxiliary Feedwater System with CT-82-7 Throttled Open up to 10 gpm without a Dedicated Operator

(2) Safety Evaluation - Revision to Technical Requirements Manual (TRM) 3.8.A Allowing Greater Period of Continued Operation When One Turbine Stop or Control Valve Is Inoperable

(3) Safety Evaluation - Revise the IP3 TRM to Reduce the Test Frequency of the Low Pressure Steam Dump Valves from Monthly to Quarterly, TRM 3.8.A

(4) Safety Evaluation - Extension of 6-Month Interval for Turbine Stop and Control Valve Test 3-PT-SA-045, TRM 3.8.A

(5) Screen - Revise Unit 3 Instrument Bus Calculations IP3-CALC-EL-00113, 114, 115, 116, 188, 189, 190, and 191 by Incorporating All Plant Changes Installed to Date

(6) Screen - Estimating Environmental Qualification Life of Unit 3 Transfer Switches

(7) Screen - Specify Feeder Cable Size for Backup Spent Fuel Pool Cooling System Diesel Generator

(8) Screen - Modified Plant Information Computer System Computer Points for Computer Alarm Delta Flux or Rod Deviation on IP3 Central Control Room Panel SFF

(9) Screen - Analyzing the Operation of Station Batteries (31, 32, 33, and 34) When a Single Cell Is Electrically Isolated

(10) Screen - Use of Fire Protection Water as a Backup Source to the Screen Wash System

(11) Screen - Permanently Remove Pipe Support for the EDG Fuel Oil Line in Protected Trench (Retire in Place)

(12) Screen - Evaluation of Component Cooling Water Pumps without the Use of Flinger

(13) Screen - Installation of Deck Plates Over Unit 3 Fuel Storage Building Transfer Canal

(14) Screen - Revise IP-CALC-06-00017

(15) Screen - Reactor Vessel Closure Head O-Ring Groove and Vessel Flange Stainless Steel Cladding Defect Criteria

(16) Screen - Eliminate Single Point Vulnerability Associated with Turbine Thrust Bearing Failure Pressure Switches

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)

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

(1) 34 steam generator atmospheric dump valve, MS-PCV-1137, testing after replacement of the current-to-pressure module and valve positioner on October 20, 2020

(2) 32 EDG functional test after planned maintenance on November 2, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Inservice Testing (IP Section 03.01)

(1) 3-PT-Q92D, 34 service water pump operational test on October 21, 2020

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.10-02.11) (1 Partial)

(1) (Partial)

As a result of the COVID-19 public health emergency, Entergy submitted an exemption request to reschedule the onsite portion of the planned 2020 biennial emergency preparedness exercise as conducted in accordance with 10 CFR Part 50, Appendix E, Section IV.F.2.b (ADAMS Accession No. ML20282A612). This was approved on December 8, 2020 (ADAMS Accession No. ML20320A000). The inspectors observed Entergy's participation in the offsite biennial emergency plan exercise which still proceeded as required by 10 CFR Part 50, Appendix E, Section IV.F.2.c, on November 17, 2020.

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated Entergy's maintenance and testing of the Indian Point alert and notification system on November 16 to November 19, 2020, for the period of July 2019 through October 2020.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of Entergy's emergency preparedness organization on November 16 to November 19, 2020.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:

• IPEC-EP-19-02, Indian Point Energy Center Emergency Plan, Revision 19-02

• IPEC-EP-19-03, Indian Point Energy Center Emergency Plan, Revision 19-03

• IPEC-EP-20-02, Indian Point Energy Center Emergency Plan, Revision 20-02 This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program on November 16 to November 19, 2020, for the period of July 2019 through October 2020.

71114.08 - Exercise Evaluation Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Partial)

(1) (Partial)

The inspectors reviewed and evaluated the proposed scenario for the offsite portion of the biennial emergency plan exercise on October 15,

OTHER ACTIVITIES - BASELINE

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

EP01: Drill/Exercise Performance (IP Section 02.12) ===

(1) April 1, 2019, through September 30, 2020

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) April 1, 2019, through September 30, 2020

EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) April 1, 2019, through September 30, 2020

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1) October 1, 2019, through September 30, 2020

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1, 2019, through September 30, 2020 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) October 1, 2019, through September 30, 2020

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensee's corrective maintenance backlog, control room deficiency tags, open operability evaluations, and operator workarounds over the past 6 months for potential adverse trends that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Failure to Establish Adequate Written Instructions for Emergency Diesel Generator Maintenance Resulted in a Significant Lube Oil Leak Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.5] - 71111.12 Systems NCV 05000286/2020004-01 Operating Open/Closed Experience A self-revealed Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings was identified when Entergy failed to establish adequate written instructions for the performance of maintenance for the 31 emergency diesel generator (EDG). Specifically, Entergy maintenance procedure 0-GNR-406-ELC, for the 31 EDG lube oil filter, did not provide quantitative instructions to tighten/torque the bolts on the lube oil filter housing cover which resulted in a significant lube oil leak and the diesel generator being declared inoperable.

Description:

On September 1, 2020, while performing the required monthly surveillance of the 31 EDG, operators identified a significant amount of oil leaking from the top of the lube oil filter housing. The 31 EDG had been running at full rated load for 15 minutes when this leak was discovered. The EDG was immediately unloaded and shutdown. Approximately 5 gallons of oil leaked from the filter housing and collected on the floor below. Entergy determined that the amount of oil leakage was large enough to prohibit the 31 EDG from satisfying its mission time without frequent makeup from an operator and, as a result, the 31 EDG was declared inoperable. Technical Specification 3.8.1.B was entered and required Entergy to return the diesel to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Indian Point has three 480 volt EDGs that have a safety function to provide onsite standby power.

Entergy assembled an emergent issues team with the specific task of identifying the cause of the leaking filter housing, implementing repair, and running the diesel without any additional leakage in order to return it to operable status. Engineering and maintenance staff inspected the sealing surfaces of the top of the filter housing as well as the O-ring groove. Both the cover surface and O-ring seating surface were in a satisfactory condition. The installed O-ring was also removed and inspected with no evidence of material degradation. The inspectors identified that preventive maintenance had been last performed on the 31 EDG lube oil filter in October 2019 using maintenance procedure 0-GNR-406-ELC, Emergency Diesel Generator 6-Year Inspection, Revision 10. The inspectors reviewed the procedure and noted that it provided instructions to tighten the cover nuts in a normal crisscross pattern wrench tight, but did not provide a specific torque value for the cover bolts.

As part of the licensees corrective action process, Entergy performed an equipment failure evaluation and past operability determination. Entergy determined that the most probable cause for the lube oil leak was inadequate torque on the filter housing cover bolts.

Specifically, inadequate bolting load allowed lube oil to pass by the O-ring seal resulting in leakage while the diesel engine was operating at full load and pressure. In addition, Entergy identified two previous instances of leakage associated with the lube oil filter housing cover: the 31 EDG in July of 2017 and the 33 EDG in November of 2017. A work order was initiated to tighten the housing cover bolts in both instances. The inspectors noted that this operating experience provided further evidence that a torque specification was needed for the filter housing cover bolts. Entergy also performed a past operability determination and credited operator action to maintain the operability of the diesel for its mission time of 7 days. Specifically, Entergy determined that if a lube oil leak occurred, operators could respond to the diesel within 10 minutes, and upon identification of the leak, the operators would attempt to tighten the lube oil filter housing cover bolts. If that was unsuccessful, operators would provide frequent makeup of lube oil to maintain the diesel operable. Entergy estimated that lube oil consumption was approximately 10 gallons per hour (gph), which included a 9 gph leak from the lube oil filter housing and

.83 gph of normal consumption.

Using the engine lube oil capacity, the minimum required lube oil level, and the consumption rate, Entergy determined that operators would have 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> to stage lube oil for make up to the diesel before reaching the minimum lube oil level. With a 7-day mission time and a consumption rate of 10 gph, Entergy ascertained that a total of 1,680 gallons of oil would be required and most of the lube oil was available onsite. As such, Entergy stated that the 31 EDG would have maintained operability if called upon to perform its safety-related function. The inspectors reviewed the evaluation and determined that past operability would be maintained through the use of operator actions.

Corrective Actions: Entergys immediate corrective actions included replacement of the O-ring, post-maintenance testing of the diesel to ensure that no leakage was observed, and periodic walkdowns by operations staff and the system engineer to identify any potential signs of leakage post-testing. In addition, Entergy established a torque value for the bolting based on operating experience, and revised maintenance procedure 0-GNR-406-ELC to include a torque value for the cover bolts. Entergy performed an extent of condition to torque the cover bolting for the three EDGs using the recommended torque value and established preventive maintenance to verify the torque on a periodic basis.

Corrective Action References: CR-IP3-2020-2120

Performance Assessment:

Performance Deficiency: Entergys failure to establish quantitative written instructions for the performance of maintenance, in accordance with 10 CFR Part 50, Appendix B, Criterion V, to ensure the 31 EDG remained capable of performing its safety function was a performance deficiency that was reasonably within Entergys ability to foresee and correct, and should have been prevented. Specifically, Entergy maintenance procedure 0-GNR-406-ELC did not provide adequate instruction for torquing the bolts on the lube oil filter housing cover and resulted in a significant lube oil leak that rendered the 31 EDG inoperable on September 1, 2020.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inadequate bolt torque on the 31 EDG resulted in a significant lube oil leak and inoperability of the diesel.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because the degraded condition did not actually impact the ability of the component to maintain its operability. Specifically, Entergy demonstrated that manual operator action could be used to make up lube oil to the engine for continued operability.

Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. The inspectors determined that Entergy did not use internal operating experience to evaluate the cause of previous lube oil filter housing leaks.

Specifically, Entergy found leaks coming from the lube oil filter housing cover on two different diesels in 2017 and did not implement the operating experience to develop a torque specification to prevent further leaks.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, on October 8, 2019, Entergys EDG maintenance procedure did not provide appropriate quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, procedure 0-GNR-406-ELC, Emergency Diesel Generator 6-Year Inspection, did not provide specific torque specifications for the reinstallation of the lube oil filter housing cover bolts, which led to a significant oil leak and inoperability of the diesel on September 1, 2020.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Semiannual Trend Analysis of Corrective Maintenance Backlog, 71152 Control Room Deficiencies, Open Operability Evaluations, and Operator Workarounds The inspectors reviewed and assessed the corrective maintenance backlog, control room deficiency tags, open operability evaluations, and operator workarounds for trends from July 1 to December 31, 2020. The inspectors did not identify any potential adverse trends. Entergy continues to correct problems in a timely manner commensurate with the safety significance of the issue.

Corrective maintenance backlog: The current corrective maintenance backlog is relatively small, and out of service equipment is being promptly repaired. The total maintenance backlog remains consistent compared to the past two quarters. Entergy continues to repair equipment and manage the maintenance backlog from past periods. There were no corrective-critical maintenance items in the backlog.

Control room deficiencies: There is a total of one control room deficiency. This represents a decrease of two deficiencies over a 6-month period of performance. Indian Point is effectively managing the backlog of control room deficiencies. None of the control room deficiencies were safety-significant.

Open operability evaluations: As of December 30, 2020 (date of sample completion), there were three operability evaluations for equipment that is considered operable but degraded or non-conforming (OP-DNC) in the Entergy corrective action program. These included:

• CR-IP3-2012-03262 - Turbine building high-energy line break effects on the 480 volt switchgear

• CR-IP3-2019-01335 - Baffle bolt structure is degraded

• CR-IP3-2020-03156 - Service water leak on line 1093 in the diesel generator valve room between the east wall and SWN-30 None of the OP-DNC components were significant safety risks. The inspectors noted that Entergys dedicated report titled Open ODM-ODNC-OCMC Report did not include CR-IP3-2012-03262 even though the item has an open operability determination. This was a result of the way the data was categorized and only represented one example. While not included in this report, the inspectors were able to readily retrieve the items status in the corrective action program database and verified that the licensee used the database as opposed to this report for tracking purposes.

Operator workarounds: There were no operator workarounds or operator burdens.

EXIT MEETINGS AND DEBRIEFS

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

• On October 29, 2020, the inspectors presented the changes, tests, and experiments inspection results to Anthony J. Vitale, Site Vice President, and other members of the licensee staff.

• On November 19, 2020, the inspectors presented the emergency preparedness program inspection results to Anthony J. Vitale, Site Vice President, and other members of the licensee staff.

• On January 19, 2021, the inspectors presented the integrated inspection results to Anthony J. Vitale, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Miscellaneous Site Certification Letter for Winter Readiness Revision 2

Procedures 0-SOP-WEATHER- Seasonal Weather Preparation 12/04/2019

001

EN-FAP-WM-016 Seasonal Reliability Revision 3

Work Orders 50074244 04

71111.04 Drawings 9321-F-27353 Flow Diagram Safety Injection System, Sheet No. 1 Revision 44

21-F-27503 Flow Diagram Safety Injection System, Sheet No. 2 Revision 59

Procedures 3-COL-EL-005 Diesel Generators Revision 40

3-COL-SI-001 Safety Injection System Revision 44

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

Analysis

Engineering IP3-ANAL-FP-02143 Fire Hazards Analysis (FHA) Report Revision 5

Evaluations

Procedures 0-PT-M004 Fire Extinguisher Inspection Revision 15

EN-DC-161 Control of Combustibles Revision 23

71111.11Q Procedures 3-POP-2.1 Operation at Greater Than 45% Power Revision 70

3-PT-SA045 Main Turbine Stop and Control Valves Exercise Test Revision 7

EN-TQ-114 Licensed Operator Requalification Training Program Revision 13

Description

EN-TQ-210 Conduct of Simulator Training Revision 15

71111.12 Corrective Action CR-IP3-2011-03831

Documents CR-IP3-2020-01493

CR-IP3-2020-03156

CR-IP3-2020-03173

Corrective Action CR-IP3-2020-03233

Documents

Resulting from

Inspection

Miscellaneous Service Water System Health Report for 2Q2020 Revision 0

SPEC-16-0001- Electronic Assembly Refurbishment/Repair Revision 0

MULTI

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures EN-DC-106 Maintenance Rule (a)(1) Process Revision 3

EN-DC-207 Maintenance Rule Periodic Assessment Revision 3

EN-MP-120 Material Receipt Revision 16

Self-Assessments LO-IP3LO-2020- Maintenance Rule Self-Assessment 05/13/2020

0059

Work Orders 166970

2822910

28245

28248

71111.13 Procedures EN-OP-119 Protected Equipment Postings Revision 13

EN-WM-104 Online Risk Assessment Revision 22

Work Orders 478372

71111.15 Calculations IP-CALC-20-00031 Code Case N-513-4 Evaluation of Line 1093 in EDG Valve Revision 0

Room Upstream of SWN-30

Corrective Action CR-IP3-2020-02616

Documents

Miscellaneous Adverse Condition Monitoring Plan for Unit Aux 10/26/2020

Transformer Dissolved Gasses

NDE Reports IP-UT-20-038 Ultrasonic Test Report for 10" SW Line 1093 12/10/2020

71111.17T Engineering EC-66137 Revise Unit 3 Instrument Bus Calculations IP3-CALC-EL- 11/08/2017

Changes 00113, 114, 115, 116, 188, 189, 190, and 191 by

Incorporating All Plant Changes Installed to Date

EC-73106 Installation of Deck Plates Over U3 FSB Transfer Canal Revision 0

EC-73321 Revise IP-CALC-06-00017 Revision 0

EC-74797 Estimating EQ Life of IP3 Transfer Switches (Starwheel 01/16/2018

Only)

EC-75545 Specify Feeder Cable Size for Backup Spent Fuel Pool 05/03/2018

Cooling System Diesel Generator

EC-75690 Eliminate SPVs Associated w/Turbine Thrust Bearing Revision 0

Failure Pressure Switches

EC-77991 Reactor Vessel Closure Head O-Ring Groove and Vessel Revision 0

Flange Stainless Steel Cladding Defect Criteria

EC-82312 Permanently Remove Pipe Support for the EDG Fuel Oil Revision 0

(FO) Line in Protected Trench (Retire in Place)

Inspection Type Designation Description or Title Revision or

Procedure Date

EC-82318 Modified PICS Computer Points for Computer Alarm Delta 04/01/2019

Flux or Rod Deviation on IP3 CCR Panel SFF

EC-83292 Analyzing the Operation of Station Batteries (31, 32, 33, 06/19/2019

34) When a Single Cell Is Electrically Isolated

EC-83784 Evaluation of CCW Pumps without the Use of Flinger Revision 0

EC-86534 Use of Fire Protection Water as a Backup Source to the 05/06/2020

Screen Wash System

19-3001-00-EVAL Operation of Auxiliary Feedwater (AFW) System with Revision 0

CT-82-7 Throttled Open up to 10 gpm without a Dedicated

Operator

19-3002-00-EVAL Revision to TRM 3.8.A Allowing Greater Period of Revision 0

Continued Operation When One Turbine Stop or Control

Valve Is Inoperable

20-3001-00-EVAL Revise the IP3 Technical Requirements Manual to Reduce Revision 0

the Test Frequency of the Low Pressure Steam Dump

Valves from Monthly to Quarterly, TRM 3.8.A

20-3002-00-EVAL Extension of 6-Month Interval for Turbine Stop and Control Revision 0

Valve Test 3-PT-SA-045, Technical Requirements Manual

(TRM) 3.8.A.2

71111.19 Engineering 88333 EDG Lube Oil Cover Bolt Torque Evaluation Revision 0

Changes

Procedures 3-PT-CS030 Atmospheric Steam Dump Valves Stroke Test Revision 17

3-PT-M097B 32 EDG Functional Test Revision 60

Work Orders 478372

2947502

2016

71111.22 Procedures 3-PT-Q92D 34 Service Water Pump Operational Test Revision 24

Work Orders 52805172

71114.01 Miscellaneous 2020 Emergency Planning Exercise Drill Scenario, Indian

Point Nuclear Generating Unit Nos. 2 and 3

ML20282A612 One-Time Schedular Exemption Request from 10 CFR 50, Appendix E, Biennial Emergency Preparedness

Exercise Requirements Due to COVID-19 Public Health

Emergency

Inspection Type Designation Description or Title Revision or

Procedure Date

ML20320A000 Indian Point Nuclear Generating Station, Unit Nos. 1, 2,

and 3 - Temporary Exemption from Biennial Onsite

Emergency Preparedness Exercise Frequency

Requirements of 10 CFR Part 50, Appendix E,

Section IV.F.2.B (EPID-L-2020-LLE-0160 [COVID-19])

ML20320A000 Indian Point Nuclear Generating Station, Unit Nos. 1, 2,

and 3 - Temporary Exemption from Biennial Onsite

Emergency Preparedness Exercise Frequency

Requirements of 10 CFR Part 50, Appendix E,

Section IV.F.2.B (EPID-L-2020-LLE-0160 [COVID-19])

71114.02 Corrective Action CR-IP3-2020-02957

Documents

Resulting from

Inspection

Miscellaneous Design Report Indian Point Energy Center Alert and Notification System Revision 5

Design Report

71114.03 Miscellaneous Indian Point Energy Center On-Shift Staffing Analysis 02/07/2019

IPEC-EP-20-02 Indian Point Energy Center Emergency Plan Revision 20-02

71114.04 Procedures EN-EP-305 Emergency Planning 10CFR50.54(q) Review Program Revision 8

71114.05 Corrective Action CR-IP3-2020-02950

Documents

Resulting from

Inspection

Procedures IP-EP-AD40 Equipment Important to Emergency Response Revision 13

71151 Procedures EN-LI-114 Regulatory Performance Indicator Process Revision 17

71152 Corrective Action CR-IP3-2020-3300

Documents

Resulting from

Inspection

16