IR 05000247/2008005: Difference between revisions

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{{Adams|number = ML090370084}}
{{Adams
| number = ML090340463
| issue date = 02/03/2009
| title = IR 05000247-08-005; 10/01/2008 - 12/31/2008; Indian Point Nuclear Generating Unit 2; Resident Inspector Quarterly Integrated Inspection Report
| author name = Gray M K
| author affiliation = NRC/RGN-I/DRP/PB2
| addressee name = Pollock J E
| addressee affiliation = Entergy Nuclear Operations, Inc, Entergy Operations, Inc
| docket = 05000247
| license number = DPR-026
| contact person = Gray, Mel NRC/RGNI/DRP/PB2/610-337-5209
| case reference number = FOIA/PA-2009-0094, FOIA/PA-2010-0209
| document report number = IR-08-005
| document type = Inspection Report, Letter
| page count = 39
}}


{{IR-Nav| site = 05000247 | year = 2008 | report number = 005 }}
{{IR-Nav| site = 05000247 | year = 2008 | report number = 005 }}
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=Text=
=Text=
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[[Issue date::February 5, 2009]]
[[Issue date::February 3, 2009]]


EA-08-354 Mr. Joseph Site Vice President Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB Buchanan, NY 10511-0249
Mr. Joseph Site Vice President Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB Buchanan, NY 10511-0249


SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000286/2008005 AND EXERCISE OF ENFORCEMENT DISCRETION
SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC INTEGRATED INSPECTION REPORT 05000247/2008005


==Dear Mr. Pollock:==
==Dear Mr. Pollock:==
On December 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Unit 3. The enclosed integrated inspection report documents the inspection results, which were discussed on January 8, 2009, with you and other members of your staff.
On December 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Unit 2. The enclosed integrated inspection report documents the inspection results, which were discussed on January 9, 2009, with you and other members of your staff.


The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. This report documents one self-revealing finding of very low safety significance (Green). This finding was determined to be a violation of NRC requirements. Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in the report. However, because the findings are of the very low safety significance and are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any 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 DC 20555-0001; with copies to the Regional Administrator, Region 1; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Indian Point Unit 3.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.


In addition, the inspectors reviewed Licensee Event Report 50-286/2008-001, which described the circumstances associated with a 31 safety injection (SI) pump breaker that did not close on January 27, 2008, during routine operation of the pump. As a result of this breaker problem, the SI pump was inoperable and determined to have exceeded the allowed outage time of 72 hours detailed in technical specification (TS) 3.5.2, and therefore is a violation of TS. A risk evaluation was performed by the regional staff and the issue was determined to be of very low safety significance. Although this issue constitutes a violation of NRC requirements, the NRC determined that the breaker subcomponent problem that resulted in the inoperability of the SI pump was not within Entergy's ability to foresee and correct, and as a result, the NRC did not identify a performance deficiency associated with this condition. The NRC's assessment considered: (1) the scope of maintenance performed on the SI pump breaker by Entergy was appropriate and up to date, (2) the breaker failure mechanism would not be reasonably identified through routine Entergy processes or quality assurance measures, (3) operating experience information available to Entergy did not identify the potential for the subcomponent problem that was experienced, and (4) Entergy implemented timely and effective corrective actions to prevent recurrence of the issue. Based on the results of the NRC's inspection and assessment, I have been authorized, after consultation with the Director, Office of Enforcement, and the Regional Administrator, to exercise enforcement discretion in accordance with Section VII.B.6 of the Enforcement Policy and refrain from issuing enforcement for this violation (EA-08-354). In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room of the Publicly Available Records System (PARS) component of the NRC's 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).
Based on the results of this inspection, no findings of significance were identified.


Sincerely,/RA/ Original Signed By: David C. Lew, Director Division of Reactor Projects Docket No. 50-286 License No. DPR-64
However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Indian Point Nuclear Generating Station, Unit 2.
 
In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room of from the Publicly Available Records (PARS) component of the NRC's 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/
Mel Gray, Chief Projects Branch 2 Division of Reactor Projects
 
Docket No. 50-247 License No. DPR-26
 
===Enclosure:===
Inspection Report No. 05000247/2008005 w/
 
===Attachment:===
Supplemental Information cc w/encl:
Senior Vice President, Entergy Nuclear Operations Vice President, Operations, Entergy Nuclear Operations Vice President, Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety and Licensing, Entergy Nuclear Operations Senior Vice President and COO, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations Manager, Licensing, Entergy Nuclear Operations C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law A. Donahue, 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 P. Eddy, NYS Department of Public Service Assemblywoman Sandra Galef, NYS Assembly T. Seckerson, County Clerk, Westchester County Board of Legislators 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 Congressman John Hall Congresswoman Nita Lowey Senator Hillary Rodham Clinton Senator Charles Schumer G. Shapiro, Senator Clinton's Staff J. Riccio, Greenpeace P. Musegaas, Riverkeeper, Inc. M. Kaplowitz, Chairman of County Environment & Health Committee A. Reynolds, Environmental Advocates D. Katz, Executive Director, Citizens Awareness Network K. Coplan, Pace Environmental Litigation Clinic M. Jacobs, IPSEC W. Little, Associate Attorney, NYSDEC M. J. Greene, Clearwater, Inc. R. Christman, Manager Training and Development J. Spath, New York State Energy Research, SLO Designee F. Murray, President & CEO, New York State Energy Research A. J. Kremer, New York Affordable Reliable Electricity Alliance (NY AREA)
 
ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,/RA/  Mel Gray, Chief Projects Branch 2 Division of Reactor Projects  
 
Docket No. 50-247 License No. DPR-26


===Enclosure:===
===Enclosure:===
Inspection Report No. 05000286/2008005 w/  
Inspection Report No. 05000247/2008005 w/  


===Attachment:===
===Attachment:===
Supplemental Information cc w/encl: Senior Vice President, Entergy Nuclear Operations Vice President, Operations, Entergy Nuclear Operations Vice President, Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety and Licensing, Entergy Nuclear Operations Senior Vice President and COO, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations Manager, Licensing, Entergy Nuclear Operations P. Tonko, President and CEO, New York State Energy Research and Development Authority C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law A. Donahue, Mayor, Village of Buchanan J. G. Testa, Mayor, City of Peekskill R. Albanese, Four County Coordinator S. Lousteau, Treasury Department, Entergy Services, Inc.
Supplemental Information Distribution w/encl:
S. Collins, RA M. Dapas, DRA D. Lew, DRP J. Clifford, DRP Stephen Campbell, RI OEDO R. Nelson, NRR M. Kowal, NRR J. Boska, PM, NRR J. Hughey, NRR S. Hansell, DRS M. Gray, DRP B. Bickett, DRP A. Rosebrook, DRP S. McCarver, DRP G. Malone, DRP, SRI - Indian Point 2 C. Hott, DRP, RI - Indian Point 2 Region I Docket Room (w/concurrences) ROPreport Resources (All IRs)
SUNSI Review Complete: _BB__ (Reviewer's Initial)
ML090340463 DOCUMENT NAME: G:\DRP\BRANCH2\a - Indian Point 2\Inspection Reports\IP2 IR2008-005\IP2 2008005 r5.doc 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 GMalone/BB for BBickett/BB MGray/MG Date 02/02/09 01/27/09 02/02/09 OFFICAL AGENCY RECORD 1 Enclosure
 
U.S. Nuclear Regulatory Commission Region I Docket No.: 50-247 License No.: DPR-26
 
Report No.: 05000247/2008005 Licensee: Entergy Nuclear Northeast (Entergy)
 
Facility: Indian Point Nuclear Generating Unit 2 Location: 450 Broadway, GSB Buchanan, NY 10511-0249
 
Dates: October 1, 2008 through December 31, 2008
 
Inspectors: G. Malone, Senior Resident Inspector, Indian Point 2 C. Hott, Resident Inspector, Indian Point 2 P. Cataldo, Senior Resident Inspector, Indian Point 3 A. Koonce, Resident Inspector, Indian Point 3 J. Noggle, Reactor Inspector, Region I J. Commisky, Reactor Inspector, Region I A. Rosebrook, Senior Project Engineer, Region I R. Fuhrmeister, Senior Project Engineer, Region I D. Silk, Senior Operations Engineer, Region I B. Haagensen, Operations Engineer, Region I Approved By: Mel Gray, Chief Projects Branch 2 Division of Reactor Projects Enclosure


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
......................................................................................................... 3
IR 05000247/2008005; 10/01/2008 - 12/31/2008; Indian Point Nuclear Generating Unit 2; Resident Inspector Quarterly Integrated Inspection Report.
 
This report covered a three-month period of inspection by resident and region based inspectors.
 
The NRC's program for overseeing safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
 
===A. NRC-Identified and Self-Revealing Findings===
 
No findings of significance were identified.
 
===B. Licensee-Identified Violations===
 
A violation of very low safety significance that was identified by Entergy was reviewed by the inspectors. Corrective actions taken or planned by Entergy were entered into Entergy's corrective action program. The violation and its corrective action tracking numbers are listed in Section 4OA7.


=REPORT DETAILS=
=REPORT DETAILS=
===Summary of Plant Status===
Indian Point Nuclear Generating Unit 2 began the inspection period operating at 100 percent reactor power. Operators reduced plant power to 85 percent on October 22 to repair an expansion joint on the suction piping of the 22 condensate pump. The plant was returned to full power operation on October 23. Unit 2 operated at or near full power for the remainder of the inspection period.


==REACTOR SAFETY==
==REACTOR SAFETY==
................................................................................................................... 5 1R01 Adverse Weather Protection .................................................................................... 5 1R04 Equipment Alignment .............................................................................................. 5 1R05 Fire Protection ......................................................................................................... 6 1R06 Flood Protection Measures ...................................................................................... 7 1R07 Heat Sink Performance ........................................................................................... 8 1R11 Licensed Operator Requalification Program ............................................................ 8 1R12 Maintenance Effectiveness ...................................................................................... 9 1R13 Maintenance Risk Assessments/Emergent Work Control ...................................... 10 1R15 Operability Evaluations .......................................................................................... 10 1R18 Plant Modifications ................................................................................................ 11 1R19 Post-Maintenance Testing ..................................................................................... 11 1R22 Surveillance Testing .............................................................................................. 14 1EP2 Alert and Notification System Evaluation ............................................................... 15 1EP6 Drill Evaluation
Cornerstones:  Initiating Events, Mitigating Systems, and Barrier Integrity
 
{{a|1R01}}
==1R01 Adverse Weather Protection==
{{IP sample|IP=IP 71111.01|count=2}}
 
===.1 Cold Weather Preparations===
 
====a. Inspection Scope====
The inspectors reviewed the readiness of risk-significant systems for extreme cold-weather conditions. The inspectors reviewed Entergy's adverse weather procedures, operating experience, corrective action program, Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TS), operating procedures, staffing, and applicable plant documents to determine the types of adverse weather challenges to which the site is susceptible. The following risk-significant systems that were required to be protected from adverse weather conditions were selected and collectively represent one inspection sample:
* Primary, refueling, and primary water storage tanks;
* Service water intake structure and components; and
* Fire water storage tank.
 
====b. Findings====
No findings of significance were identified.
 
===.2 External Flooding===
 
====a. Inspection Scope====
The inspectors reviewed the readiness of barriers to external flooding for the service water intake structure and related equipment. The inspectors reviewed Entergy's adverse weather procedures, abnormal operating procedures, operating experience, Updated Final Safety Analysis Report (UFSAR), and Internal Plant Examination of External Events (IPEEE) to determine susceptibilities to external floods and review the site's methods to mitigate the effects of external flooding. The inspectors walked down the service water pump vault and the strainer vaults to verify the integrity of the structures and components contained within to the effects of flooding. The inspectors 3 Enclosure also verified that barriers and systems used to mitigate flooding were available and in adequate material condition.
 
====b. Findings====
No findings of significance were identified.
 
{{a|1R04}}
==1R04 Equipment Alignment==
{{IP sample|IP=IP 71111.04Q|count=4}}
 
Partial System Walkdowns
 
====a. Inspection Scope====
The inspectors performed partial system walkdowns to verify the operability of redundant or diverse trains and components during periods of system train unavailability, or following periods of maintenance. The inspectors referenced the system procedures, the UFSAR, and system drawings to verify that the alignment of the available train supported its required safety functions. The inspectors also reviewed applicable condition reports (CR) and work orders to ensure that Entergy had identified and properly addressed equipment discrepancies that could potentially impair the capability of the available train, as required by Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, "Corrective Action."  Documents reviewed during this inspection are listed in the Attachment.
 
The inspectors performed a partial walkdown on the following systems, which represented four inspection samples:
* 21 residual heat removal (RHR) pump train during 22 RHR pump maintenance;
* Appendix R diesel following restoration from planned maintenance;
* 23 safety injection (SI) pump train during 21 SI pump breaker maintenance; and
* 22 and 23 emergency diesel generators and 22 auxiliary feed pump during maintenance on 21 emergency diesel generator.
 
====b. Findings====
No findings of significance were identified.
 
{{a|1R05}}
==1R05 Fire Protection==
{{IP sample|IP=IP 71111.05Q|count=6}}
 
====a. Inspection Scope====
The inspectors conducted tours of fire areas to assess the material condition and operational status of fire protection features. The inspectors verified, consistent with the applicable administrative procedures, that: combustibles and ignition sources were adequately controlled; passive fire barriers, manual fire-fighting equipment, and suppression and detection equipment were appropriately maintained; and compensatory measures for out-of-service, degraded, or inoperable fire protection equipment were implemented in accordance with Entergy's fire protection program. The inspectors evaluated the fire protection program against the requirements of License Condition 2.K. The documents reviewed during this inspection are listed in the Attachment. This 4 Enclosure inspection represented six inspection samples for fire protection tours, and was conducted in the following areas:
* Zone 8, Boric acid transfer pump (BATP) and tank area;
* Zone 74A, Electrical penetration area;
* Zone 2, Containment spray pump room;
* Zone 1, Component cooling water pump room;
* Zones 12,13, and 14, 125-Vdc vital battery rooms (batteries 21, 22, and 24); and
* Zones 3 and 4, Residual heat removal pump rooms (pumps 21 and 22).
 
====b. Findings====
No findings of significance were identified.
{{a|1R11}}
==1R11 Licensed Operator Requalification Program==
 
===.1 Quarterly Review===
{{IP sample|IP=IP 71111.11Q|count=1}}
 
====a. Inspection Scope====
On August 18, 2008, the inspectors observed licensed operator simulator training to verify that operator performance was adequate, and that evaluators were identifying and documenting crew performance problems. The inspectors evaluated the performance of risk-significant operator actions, including the use of emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, the implementation of appropriate actions in response to alarms, the performance of timely control board operation and manipulation, and the oversight and direction provided by the control room supervisor. The inspectors also reviewed simulator fidelity with respect to the actual plant. The inspectors evaluated licensed operator training against the requirements of 10 CFR Part 55, "Operator Licenses."  The documents reviewed during this inspection are listed in the Attachment. This observation of operator simulator training represented one inspection sample.
 
====b. Findings====
No findings of significance were identified.
 
===.2 Biennial Review===
{{IP sample|IP=IP 71111.11B|count=1}}
 
====a. Inspection Scope====
The following inspection activities were performed using NUREG 1021, Rev. 9, AOperator Licensing Examination Standards for Power Reactors;
@ and NRC Inspection Procedure 71111.11, ALicensed Operator Requalification Program,@ Appendix A AChecklist for Evaluating Facility Testing Material
@ and Appendix B ASuggested Interview Topics.@  The inspectors reviewed recent operating history documentation found in inspection reports, licensee event reports, the licensee
=s corrective action program, and the most recent NRC plant issues matrix (PIM). The inspectors also reviewed specific events 5 Enclosure from Entergy
=s corrective action program which indicated possible training deficiencies, to verify they had been appropriately addressed. The senior resident inspector was also consulted for insights regarding licensed operators
= performance.
 
The remediation plans for a crew or individual
=s performance weaknesses or enhancements were reviewed by the inspectors to assess the effectiveness of the remedial training. The inspectors interviewed operators, instructors and training/operation
=s management for feedback on their training program and the quality of training received.
 
The inspectors reviewed simulator performance and fidelity for conformance to the reference plant control room.
 
A sample of records for requalification training attendance, program feedback, reporting, and medical examinations were reviewed by the inspectors for compliance with license conditions, including NRC regulations.
 
The inspectors reviewed the operating tests for the weeks of September 29 and October 6, 2008, for content, quality and overlap. Likewise, the 2007 written exam was reviewed for content, quality, and overlap.
 
The inspectors observed dynamic simulator exams and job performance measures administered during the week of October 6, 2008. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of five JPMs.
 
On October 20, 2008, the inspectors reviewed the results of the annual operating tests for year 2008 and the written exam for 2007 to determine if pass/fail rates were consistent with the guidance of NUREG-1021, Revision 9, AOperator Licensing Examination Standards for Power Reactors
@ and NRC Manual Chapter 0609, Appendix I, AOperator Requalification Human Performance Significance Determination Process (SDP).@  The review verified the following:
 
$ Crew failure rate on the dynamic simulator was less than 20%.
 
(Failure rate was 0.0%)
$ Individual failure rate on the dynamic simulator test was less than or equal to 20%. (Failure rate was 0.0%)
$ Individual failure rate on the walkthrough test (job performance measures) was less than or equal to 20%. (Failure rate was 0.0%)
$ Individual failure rate on the 2007 comprehensive written exam was less than or equal to 20%. (Failure rate was 0.0%)
$ More than 75% of the individuals passed all portions of the exam (100% of the individuals passed all portions of the exam).
 
====b. Findings and Observations====
No findings of significance were identified.
 
{{a|1R12}}
==1R12 Maintenance Effectiveness==
{{IP sample|IP=IP 71111.12Q|count=2}}
 
====a. Inspection Scope====
The inspectors reviewed performance-based problems that involved structures, systems, and components (SSCs) to assess the effectiveness of maintenance activities. When applicable, the reviews focused on:
* Proper Maintenance Rule scoping in accordance with 10 CFR 50.65;
* Characterization of reliability issues;
* Changing system and component unavailability;
* 10 CFR 50.65(a)(1) and (a)(2) classifications;
* Identifying and addressing common cause failures;
* Trending of system flow and temperature values;
* Appropriateness of performance criteria for SSCs classified (a)(2); and
* Adequacy of goals and corrective actions for SSCs classified (a)(1).
 
The inspectors also reviewed system health reports, maintenance backlogs, and Maintenance Rule basis documents. The inspectors evaluated maintenance effectiveness and monitoring activities against the requirements of 10 CFR 50.65.
 
The documents reviewed during this inspection are listed in the Attachment. The following Maintenance Rule samples were reviewed and represented two inspection samples:
* Service water pumps; and
* Buried piping inspections of the condensate storage tank supply piping to the auxiliary feedwater system.
 
====b. Findings====
No findings of significance were identified.
 
{{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13|count=4}}
 
====a. Inspection Scope====
The inspectors reviewed scheduled and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment from service for maintenance or repair. The inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4), and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. Documents reviewed during this inspection are listed in the Attachment. The following activities represented four inspection samples:
* Planned elevated-risk maintenance condition for 23 charging pump motor replacement;
* Planned elevated-risk maintenance condition for an endurance run on the 23 emergency diesel generator performed once every 18-months;
* Planned elevated-risk maintenance condition during 21 auxiliary boiler feedwater pump breaker outage; and
* Planned elevated-risk maintenance condition during 138kv [kilovolt] feeder outage and safety injection system testing.
 
====b. Findings====
No findings of significance were identified.
 
{{a|1R15}}
==1R15 Operability Evaluations==
{{IP sample|IP=IP 71111.15|count=2}}
 
====a. Inspection Scope====
The inspectors reviewed operability evaluations to assess the acceptability of the evaluations, the use and control of compensatory measures when applicable, and compliance with Technical Specifications. The inspectors' reviews included verification that operability determinations were performed in accordance with procedure ENN-OP-104, "Operability Determinations."  The inspectors assessed the technical adequacy of the evaluations to ensure consistency with the Technical Specifications, UFSAR, and associated design basis documents (DBDs). The documents reviewed are listed in the Attachment. The following operability evaluations were reviewed and represented two inspection samples:
* Impact of incorrect component materials on component cooling pump constant level oilers; and
* Accumulator leak on nitrogen system supply for power-operated relief valve PCV-455C.
 
====b. Findings====
No findings of significance were identified.
 
{{a|1R18}}
==1R18 Plant Modifications==
{{IP sample|IP=IP 71111.18|count=1}}
 
====a. Inspection Scope====
The inspectors reviewed a temporary plant modification package associated with an additional nitrogen supply connected to the air supply system for the 138kV 52/BT4-5 air-operated breaker. The breaker's function is to provide an alternate path for 138kV offsite power to be cross-connected between Indian Point Units 2 and 3. The temporary modification was installed to address a degrading air compressor on the breaker until corrective maintenance is performed. The inspectors verified that the design bases, licensing bases, and performance capability of the system was not negatively impacted by the temporary modification. In addition, the inspectors interviewed plant staff, and reviewed issues that were entered into the corrective action program to determine whether Entergy had been effective in identifying and resolving problems associated with the temporary modification. The documents reviewed are listed in the Attachment.
 
====b. Findings====
No findings of significance were identified.
 
{{a|1R19}}
==1R19 Post-Maintenance Testing==
{{IP sample|IP=IP 71111.19|count=7}}
 
====a. Inspection Scope====
The inspectors reviewed post-maintenance test procedures and associated testing activities for selected risk-significant mitigating systems, and assessed whether the effect of maintenance on plant systems was adequately addressed by control room and engineering personnel. The inspectors verified that: test acceptance criteria were clear, demonstrated operational readiness and were consistent with design basis documentation; test instrumentation had current calibrations, and appropriate range and accuracy for the application; and the tests were performed as written, with applicable prerequisites satisfied. Upon completion of the tests, the inspectors verified that equipment was returned to the proper alignment necessary to perform its safety function. Post-maintenance testing was evaluated against the requirements of 10 CFR 50, Appendix B, Criterion XI, "Test Control."  The documents reviewed are listed in the Attachment. The following post-maintenance activities were reviewed and represented seven inspection samples:
* 25 service water pump following bearing repair;
* 23 charging pump following motor replacement;
* 21 auxiliary boiler feed pump (ABFP) alternate safe shutdown breaker test;
* 21 service water pump 480V breaker replacement;
* 22 ABFP following maintenance on steam supply valve PCV-1139;
* 21 emergency diesel generator following semi-annual jacket water and lube oil heat exchanger inspections; and
* 22 containment fan cooler unit following bearing lubrication.
 
====b. Findings====
No findings of significance were identified.
 
{{a|1R22}}
==1R22 Surveillance Testing==
{{IP sample|IP=IP 71111.22|count=6}}
 
====a. Inspection Scope====
The inspectors observed performance of portions of surveillance tests and/or reviewed test data for selected risk-significant SSCs to assess whether they satisfied Technical Specifications, UFSAR, Technical Requirements Manual, and Entergy procedure requirements. The inspectors verified that: test acceptance criteria were clear, demonstrated operational readiness, and were consistent with design basis documentation; test instrumentation had accurate calibration, and appropriate range and accuracy for the application; and tests were performed as written, with applicable prerequisites satisfied. Following the tests, the inspectors verified that the equipment was capable of performing the required safety functions. The inspectors evaluated the surveillance tests against the requirements in Technical Specifications. The documents reviewed during this inspection are listed in the Attachment. The following surveillance tests were reviewed and represented six inspection samples:
* 2-PC-4Y74C, nuclear instruments power range N-43 channel calibration;
* 2-PT-V59, reactor trip breaker "A" changeout and functional test;
* 2-PT-Q035B,  22 containment spray in-service test;
* 2-PC-2Y55, channel calibration of containment sump level indicator LT-941;
* 2-NF-309, reactor coolant system loop delta-T, T-average, and flow measurement; and
* PT-Q13, valve stroke 869B (containment isolation valve).
 
====b. Findings====
No findings of significance were identified.
 
===Cornerstone:===
Emergency Preparedness (EP)1EP2 Alert and Notification System (ANS) Evaluation
 
====a. Inspection Scope====
The inspectors observed a full-volume siren test on October 22, 2008 to verify Entergy's newly installed siren system functioned properly. The inspectors verified that the minimum required number of sirens functioned when actuated. This inspection was conducted in accordance with the baseline inspection program deviation authorized by the NRC Executive Director of Operations (EDO) in a memorandum dated October 31, 2005, and renewed by the EDO in a memorandum dated December 19, 2007.
 
====b. Findings====
No findings of significance were identified.


==RADIATION SAFETY==
==RADIATION SAFETY==
............................................................................................................... 15 2OS3 Radiation Monitoring Instrumentation and Protective Equipment


==OTHER ACTIVITIES (OA)==
===Cornerstone:===
........................................................................................................ 17
Occupational Radiation Safety (OS)2OS3 Radiation Monitoring Instrumentation and Protective Equipment
 
====a. Inspection Scope====
(71121.03 - 9 samples)
During December 15-19, 2008, the inspectors conducted the following activities to evaluate the operability and accuracy of radiation monitoring instrumentation, and the adequacy of the respiratory protection program for issuing self-contained breathing apparatus (SCBA) to emergency response personnel. Implementation of these programs was reviewed by the inspectors against the criteria contained in 10 CFR 20, applicable industry standards, and Entergy's procedures.
 
1) The inspectors reviewed the UFSAR to identify area radiation monitors that are installed at Indian Point Units 2 and 3 for the protection of workers, and reviewed the calibration procedure and current calibration records for selected instrumentation, including Unit 2 plant radiation monitors; main steam line 10 Enclosure radiation monitors (R-28, R-29, R-30, R-31), refuel floor area radiation monitor (R-5), containment high-range radiation and noble gas monitors (R-25, R-26), gaseous and particulate containment radiation monitors (R-42, R-41), in-core area radiation monitor (R-7), steam generator blow down radiation monitor (R-49); Unit 3 plant radiation monitors; main steam line radiation monitors (R-62A, R-62B, R-62C, R-62D), refuel floor area radiation monitor (R-5), containment high-range radiation and noble gas monitors (R-25, R-26), gaseous and particulate containment radiation monitors (R-12, R-11), in-core area radiation monitor (R-7), and steam generator blow down radiation monitor (R-19). The inspectors discussed the monitoring system health reports and instrument reliability trends with the system engineer.
 
2) The inspectors identified various radiation detection instruments used at Indian Point used for job coverage for work in radiologically significant areas, including continuous air monitors and whole body counters. Instruments evaluated were 49 electronic dosimeters, 13 radiation survey instruments, 12 extendable probe survey instruments, 6 neutron radiation survey instrument, 6 continuous air monitors, 4 portal monitors, 7 beta/alpha counters and 2 whole body counters.
 
3) Current calibration records, applicable calibration procedures, operability, and alarm set points were reviewed by the inspectors for the instruments identified above. In addition, the inspectors reviewed the applicable calibrators utilized for appropriate instrument calibration geometries and National Institute for Science and Technology standard traceability. They included: Shepherd 81-12B beam source calibrators, Shepherd 142-10 panoramic calibrator, Shepherd 149 neutron source calibrator and Shepherd 1000B box source calibrator. The plant source term was reviewed by the inspectors to determine whether calibration sources being used were representative.
 
4) Radiological incidents involving internal exposures identified by condition reports for 2008 were reviewed by the inspectors. In addition, dosimetry electronic records were queried for any internal exposures >50 mrem committed effective dose equivalent (CEDE). None were identified for further review.
 
5) The inspectors reviewed condition reports with respect to radiation protection program deficiencies to determine if the deficiencies were appropriately characterized and corrected commensurate with their safety significance.
 
6) Based on the condition reports reviewed, no repetitive deficiencies were identified for further follow-up.
 
7) With respect to the RP portable instruments listed in 3) above, the instrument
=s calibration expiration and response check stickers were reviewed by the inspectors. The applicable response check beta-source and instrument sign-out procedures were also reviewed. The inspectors queried radiation protection technicians regarding appropriate instrument selection and observed self verification of instrument operability prior to use.
 
8) The inspectors sampled emergency plan-specified self contained breathing apparatus (SCBA) equipment and qualified users based on Indian Point Energy Center Emergency Plan documents and included inspection of selected SCBAs 11 Enclosure and air bottle cascade systems located inside or adjacent to both the Unit 2 and Unit 3 main control rooms. The inspectors verified SCBA qualification records for select on-shift reactor operators were current. The inspectors also verified that air used to fill the SCBAs met the Grade D quality criteria of the Compressed Gas Association. The inspectors queried on shift reactor operators to determine the storage location of required spectacles.
 
9) The inspectors examined selected SCBA units for periodic air cylinder hydrostatic testing and maintenance records. The inspectors also performed a review of approved replacement parts documentation and certification of the repair personnel.
 
====b. Findings====
No findings of significance were identified.
 
==OTHER ACTIVITIES==
[OA]
 
{{a|4OA1}}
{{a|4OA1}}
==4OA1 Performance Indicator Verification ......................................................................... 17 4OA2 Identification and Resolution of Problems .............................................................. 18 4OA3 Event Followup ...................................................................................................... 23 4OA5 Other Activities ...................................................................................................... 25 4OA6 Meetings, including Exit ......................................................................................... 28 4OA7 Licensee-Identified Violations ................................................................................ 28==
==4OA1 Performance Indicator Verification==
{{IP sample|IP=IP 71151|count=4}}
 
====a. Inspection Scope====
The inspectors reviewed performance indicator data for the cornerstones listed below and used Nuclear Energy Institute 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, to verify individual performance indicator accuracy and completeness. The documents reviewed during this inspection are listed in the Attachment.
 
Mitigating Systems Cornerstone
* Heat Removal Systems (MSPI)
* Cooling Water Systems (MSPI)
Occupational Radiation Safety Cornerstone
* Occupational Exposure Control Effectiveness Public Radiation Safety Cornerstone
* RETS/ODCM Radiological Effluent Occurrences
 
====b. Findings====
No findings of significance were identified.
 
12 Enclosure
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems==
{{IP sample|IP=IP 71152|count=4}}
 
===.1 Routine Problem Identification & Resolution Program Review===
 
====a. Inspection Scope====
As required by Inspection Procedure 71152, "Identification and Resolution of Problems," and to identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of all items entered into Entergy's corrective action program. The review was accomplished by accessing Entergy's computerized database for condition reports, and attending condition report screening meetings.
 
In accordance with the baseline inspection modules, the inspectors selected corrective action program items across the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for further follow-up and review. The inspectors assessed Entergy's threshold for problem identification, adequacy of the causal analysis, extent of condition reviews, and operability determinations, and timeliness of the associated corrective actions.
 
====b. Findings====
No findings of significance were identified.
 
===.2 Semi-Annual Trend Review===
{{IP sample|IP=IP 71152|count=1}}
 
====a. Inspection Scope====
The inspectors performed a semi-annual review to identify trends that might indicate the existence of a more significant safety issue. The inspectors included in this review, repetitive or closely-related issues that may have been documented by Entergy outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors reviewed Entergy's corrective action program database for the third and fourth quarters of 2008 to assess the total number and significance of condition reports (CRs) written in various subject areas. The inspectors also reviewed Entergy's corrective action, engineering, and maintenance quarterly trend reports for the second and third quarters of 2008 to ensure Entergy was appropriately evaluating and trending adverse conditions.
 
The inspectors focused on an adverse trend in through-wall leaks identified in service water piping. The inspectors reviewed CRs, causal evaluations, maintenance plans, business plans, and interviewed station personnel to assess whether Entergy identified the adverse trend and developed appropriate corrective actions to address the conditions.
 
b. Assessment and Observations No findings of significance were identified.
 
13 Enclosure Entergy identified three leaks in service water system blowdown piping on August 19, 2008 and determined the leaks were pinhole size that resulted in wetting of the pipe surface. Entergy entered the issue into the CAP and performed an immediate operability assessment that concluded the piping was operable and did not impact the pipe's structural integrity. Entergy performed extent-of-condition walkdowns in the service water intake area and discovered additional leaks on service water system blowdown piping welds. Entergy personnel performed volumetric non-destructive testing of the pipes in accordance with their procedures and determined that these additional leaks were minor localized defects that did not impact structural integrity and, therefore, the service water systems they supported remained operable. Entergy performed the actions described in ASME Code Case N-513-2 for the ASME Class III service water piping and established monitoring frequencies and flaw acceptance criteria. Entergy's short term corrective actions included: performing engineering walkdowns of all stainless steel piping in the service water system, establishing daily walkdowns of identified flaws, and performing volumetric inspection on the identified flaws as required by ASME Code. Entergy identified long term actions that include replacement of the stainless steel service water blowdown piping with a more corrosion-resistant material as Entergy personnel determined that the 304 stainless steel blowdown piping is susceptible to pitting corrosion due to the brackish water of the Hudson River. The replacement is planned to be completed prior to the next refueling outage in the spring of 2010.
 
Additionally, as part of Entergy's extent-of-condition walkdowns, Entergy identified several leaks on stainless steel service water piping servicing radiation monitors for the containment fan coil units. Similar to the service water blowdown piping, Entergy determined the pinhole leaks were on weld material. However, because the leaks appeared on socket welds and the flaws could not be accurately characterized, ASME Code Case N-513-2 was not applicable and Entergy declared the radiation monitors inoperable and repaired the flaws. Entergy determined that the leaks were caused by pitting corrosion in the 300 series stainless steel pipe welds and the brackish water of the Hudson River. Entergy implemented corrective actions that included immediate repair of all leaking welds and development of an Engineering Change Request package that will replace the radiation monitor piping with a highly corrosion resistant material (AL6XN).
 
On September 16, 2008, the inspectors identified a small through-wall leak on service water piping supplying cooling water to the containment fan-coil units (FCUs). Specifically, the inspectors identified a pinhole leak that resulted in a wetted pipe surface on a weld neck flange for a 2-inch carbon-steel drain line connected to a 10-inch supply header to the 22 FCU. Entergy performed an operability assessment for the containment penetration and supported the evaluation with confirmatory ultrasonic tests and structural calculations. Entergy determined the cause of this failure was the result of improperly coated weld surfaces internal to the pipe that occurred in 2002. Entergy determined the maintenance procedures, at that time, used to prepare the piping prior to welding did not contain adequate instructions for properly preparing a pipe or weld surface prior to the application of the corrosion resistant coating. Entergy developed procedure 0-SYS-409-GEN, "Belzona and Enecon Metal Repair Applications," in 2005 to improve surface preparation and application techniques. Entergy implemented short term actions to monitor the leakage daily, perform 90-day follow-up ultrasonic testing on the leak location, and perform extent-of-condition walkdowns and UT measurements on the corresponding welds of the 21, 23, 24, and 25 FCUs. Entergy's long term corrective actions includes procedure revisions, repair of the weld during the next refueling outage, 14 Enclosure and plans to visually inspect the welds on the other FCUs during the next refueling outage.
 
The inspectors determined that there was reasonable opportunity for Entergy to identify and correct the 22 FCU leak prior to NRC identification as required per 10 CFR 50, Appendix B, criterion XVI, "Corrective Action;" however, the inspectors determined, based on subsequent testing of the 22 FCU performed by Entergy, that the operability of the 22 FCU and the corresponding containment penetration was not impacted. Therefore, this violation of 10 CFR 50, Appendix B is considered to be of minor significance and not subject to NRC enforcement.
 
In general and notwithstanding the NRC inspector-identified minor leak, the inspectors determined that Entergy appropriately identified the adverse trend in service water piping corrosion issues in the corrective action program and documented operability assessments for the service water leaks that were supported by a sufficient technical basis. The inspectors determined that Entergy performed appropriate causal evaluations and implemented extent-of-condition reviews to understand the corrosion mechanisms that existed in service water piping and the extent of the issues. The inspectors also determined that Entergy identified and implemented or planned corrective actions commensurate with the requirements of their corrective action program and the ASME Code. Additionally, the inspectors observed that corrective actions included consideration for the safety significance of the issues.
 
===.3 Aggregate Impact of Operator Workarounds===
{{IP sample|IP=IP 71152|count=1}}
 
====a. Inspection Scope====
The inspectors conducted a review of the aggregate impact of operator burdens and workarounds. The inspectors reviewed Entergy's implementation of procedures OAP-45, "Operator Burden Program," Revision 1. The inspectors conducted control room walkdowns and interviewed plant operators to determine the impact of deficiencies on operator response to plant events.
 
====b. Findings and Observations====
No findings of significance were identified. The inspectors verified that operator workarounds and burdens were entered into the corrective action program at an appropriate threshold and that corrective actions were planned or taken commensurate with their safety significance.
 
===.4 Substantive Cross-Cutting Issue Review: Human Performance - Procedure===
 
Adequacy (71152 - 1 sample)
 
====a. Inspection Scope====
The inspectors reviewed Entergy's actions to address the Substantive Cross-Cutting Issue (SCCI) in Human Performance related to procedure adequacy. The inspectors' review focused on Entergy's progress in addressing the SCCI since their implementation of a revised action plan in May 2008. The inspectors evaluated Entergy's performance improvement plans and actions using inspection guidance in Inspection Procedure 71152, "Identification and Resolution of Problems."  Specifically, the inspectors 15 Enclosure assessed Entergy's progress in resolving the cross-cutting issue by evaluating whether Entergy's internal milestones were being monitored and consistently met and whether adjustments in approach were made when necessary. This inspection focused on the progress made since the PI&R sample inspection conducted in October 2008 (NRC Inspection Report 05000247/2008013 and 05000286/2008011).
 
The inspectors conducted a review of the applicable condition reports (CRs), corrective action assignments (CAs), focused self-assessments, Quality Assurance group assessments, and causal evaluations for the substantive cross-cutting issue. The inspectors also reviewed Entergy's performance indicators related to their performance improvement plan; reviewed a sample of revised procedures; conducted a series of interviews with station management, procedure writers and reviewers, maintenance technicians, and operators in order to assess the adequacy of the performance plan and effectiveness of corrective actions.
 
====b. Findings and Observations====
No findings of significance were identified.
 
The inspectors determined that Entergy continued to make progress in effectively implementing their corrective action plans that address the substantive cross-cutting issue in Human Performance related to procedure adequacy.
 
The inspectors concluded that Entergy's corrective action plans were reasonable in scope because they addressed procedures that contributed to the substantive cross-cutting issue. Entergy's corrective action plans included Operations, Electrical and Mechanical Maintenance, and I&C Maintenance procedures. The procedure upgrade project portion of Entergy's corrective action plans focused on risk significant components and actions in operating procedures. The inspectors determined the procedure upgrade project scope appropriately included operating procedures related to initiating events, single point vulnerabilities, and integrated plant operating procedures. The inspectors observed that station training was developed and provided for the individuals involved in the procedure upgrade project and their management. The inspectors also observed that procedure reviews were being conducted for Security, Chemistry, Radiation Protection, and Engineering procedures to improve the quality of procedures in those areas.
 
The inspectors confirmed previous NRC observations, through interviews with Entergy staff, that the station has shifted the ownership of this project from the support organizations to the line organization. Entergy personnel indicated this organizational alignment has been a significant factor in the increased acceptance and participation from plant workers, and produced a noticeable improvement in revised procedure quality. The inspectors observed that several personnel interviewed commented that the human performance training simulator is an effective tool, and assisted procedure writers with the identification of human performance error traps in existing procedures.
 
The inspectors concluded that the realignment of the procedure upgrade project resulted in enhanced project accountability and quality output.
 
With respect to the progress of the procedure upgrade project, Entergy completed Phase I of the project ahead of their internal schedule and started Phase II. Phase I consisted of operations procedures associated with the top three risk significant systems 16 Enclosure for Units 2 and 3. Phase II of the procedure upgrade project included the remaining top 10 plant risk significant systems, integrated plant operating procedures, procedures which involved single point vulnerabilities and initiating events. Current Entergy plans and progress indicate that the Phase II portion of the procedure upgrade project will be completed by June 2009, several months ahead of the corrective action plan schedule. The inspectors reviewed a sample of the revised Phase I and Phase II procedures and determined that significant revisions were made and the results met the quality and procedure standards described in Entergy's action plan.
 
The inspectors also observed that the Electrical and Mechanical Maintenance procedure upgrade project and the I&C Maintenance procedure development project made progress that was consistent with internal action plan schedules and milestones. The inspectors determined that the projects continue to receive the appropriate level of resources and management review and support to ensure completion of these projects.
 
The inspectors determined that human error awareness and prevention actions were being implemented by Entergy to address the human performance aspects that contributed to the substantive cross-cutting issue in procedure adequacy. The inspectors determined that implementation of training, specifically the human performance training simulator, was appropriate to reinforce human error prevention techniques being applied in the plant.
 
The inspectors concluded Entergy developed appropriate monitoring measures and performance indicators to assess corrective action effectiveness. The inspectors observed that Entergy utilized these tools to provide initial feedback on corrective action implementation. For example, the inspectors determined that the performance indicators, related to procedure completion status and procedure feedback process backlog, were an effective tool for monitoring station progress in these areas.
 
Additionally, the inspectors concluded that self-assessments were an effective tool for corrective action adjustments and for evaluation of internal and external stakeholder recommendations. Entergy has adjusted the corrective action plan and procedure upgrade project scope to adequately incorporate stakeholder recommendations.
 
5. Substantive Cross-Cutting Issue Review: Problem Identification and Resolution -
Implementation of Corrective Actions (71152 - 1 sample)
 
====a. Inspection Scope====
The inspectors reviewed Entergy's action plan to address the Substantive Cross Cutting Issue (SCCI) identified for Unit 2 in the area of Problem Identification and Resolution related to implementation of effective corrective actions. This SCCI was identified in the NRC's 2008 Annual Assessment letter [ADAMS Ref. No. ML080610015] and was continued in the NRC 2008 Mid Cycle Performance Review [ADAMS Ref. No. ML082470316].
 
The inspectors conducted a review of the applicable condition reports (CRs), corrective action assignments (CAs), focused self-assessments, Quality Assurance group assessments, root cause analyses, common cause analyses, and apparent cause determinations for the substantive cross-cutting issue. The inspectors also reviewed the CRs and corrective actions associated with the four NCVs which contributed to this cross-cutting issue and reviewed a sample of corrective actions for NRC findings in 2007 17 Enclosure and 2008 to determine if a trend existed. The inspectors reviewed Entergy's performance in order to assess the adequacy of the performance plan and effectiveness of corrective actions.
 
====b. Findings and Observations====
There were no findings of significance.
 
The inspectors determined that Entergy continued to make progress in effectively implementing their corrective action plans, specific to the substantive cross-cutting issue in Problem Identification and Resolution related to implementation of corrective actions at Unit 2.
 
The inspectors observed progress made in developing and implementing a site-wide action plan to address the issue. The inspectors concluded that the performance improvement plan developed by Entergy was appropriately focused and sufficiently broad to address the cross-cutting aspect of implementation of corrective actions. Additionally, Entergy is approaching their corrective actions from a site-wide perspective (Units 2 and 3) and implemented changes in the processes and level of management review to ensure the issue was appropriately addressed for both units. Specific corrective actions identified by Entergy included the following: administrative procedure revisions to change corrective action tracking; revised procedure requirements for corrective action review board (CARB) review of level 2 and higher tier causal evaluations; revised corrective action requirements for post-closure CARB review of cause evaluations completed over the past year to include verification that that effectiveness reviews were scheduled, completed, and reviewed by CARB for all significant conditions adverse to quality and violations of regulatory requirements. The inspectors observed that these changes were implemented and further observed management review and challenge of several causal evaluations and effectiveness reviews.
 
Entergy developed performance indicators to track and trend the implementation of the corrective actions. The inspectors reviewed the data from the performance indicators and concluded that the performance indicators were effective and an indication that corrective actions were identifying areas for improvement. The inspectors also determined that Entergy conducted focused self assessments and benchmarking surveys as additional measures to verify planned actions were sufficiently effective.
 
{{a|4OA3}}
==4OA3 Event Followup==
{{IP sample|IP=IP 71153|count=1}}
 
===.1 (Closed) Licensee Event Report (LER) 05000247/2008-002-00, Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for an Inoperable Engineered Safety Feature Actuation System Automatic Actuation Logic and Actuation Relay Caused by Improper Relay Wiring===
 
====a. Inspection Scope====
On March 28, 2008, Entergy identified an improperly wired safety injection (SI) logic relay during troubleshooting of a high resistance contact in the relay. Specifically, Entergy determined that 23 Containment Fan Cooler Unit (FCU) breaker was not wired to receive a closing signal from the SI relay associated with the electric bus that supplies 18 Enclosure its power. The 23 FCU is powered from bus 2A, and is designed to receive a sequenced start relay during an SI from the 2A bus SI relay. However, in this case, Entergy identified that 23 FCU would have received its start signal from the 5A bus SI relay. Therefore, if bus 5A was de-energized during an SI, 23 FCU would not receive an automatic sequenced start signal as designed. In this scenario, 23 FCU would still be available for manual start by the operators. Entergy determined the incorrect wiring configuration was a result of an improperly implemented design change by the original plant installer in 1973. The incorrect wiring was never detected during subsequent testing because all four safety bus SI relays are tested simultaneously during biannual SI blackout testing.
 
Entergy entered this issue into their corrective action program, corrected the relay wiring configuration, and performed an extent-of-condition review of other SI relays. No additional instances of incorrect wiring were identified. The inspectors reviewed the LER and verified the corrective actions were adequate. The enforcement aspects of this finding are discussed in section 4OA7. This LER is closed.
 
{{a|4OA5}}
==4OA5 Other Activities==
 
===.1 Implementation of Temporary Instruction (TI) 2515/176 - Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing===
 
====a. Inspection Scope====
The objective of TI 2515/176, "Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing," is to gather information to assess the adequacy of nuclear power plant emergency diesel generator endurance and margin testing as prescribed in plant-specific technical specifications (TS). The inspectors reviewed emergency diesel generator ratings, design basis event load calculations, surveillance testing requirements, and emergency diesel generator vendor's specifications and gathered information in accordance with TI 2515/176.
 
The inspector assessment and information gathered while completing this TI was discussed with licensee personnel. This information was forwarded on to the Office of Nuclear Reactor Regulation for further review and evaluation.
 
====b. Findings====
No findings of significance were identified.
 
===.2 TI 2515/173, Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative===
 
====a. Inspection Scope====
An NRC assessment was performed the week of August 11, 2008 of Entergy's implementation of the Nuclear Energy Institute - Voluntary Ground Water Protection Initiative (dated August 2007, ADAMS Ref. No. ML072610036). Entergy evaluated work practices that could lead to leaks and spills, and performed an evaluation of systems, 19 Enclosure structures, and components that contain licensed radioactive material to determine potential leak or spill mechanisms.
 
Entergy completed a site characterization of geology and hydrology to determine the predominant ground water gradients and potential pathways for ground water migration from on-site locations to off-site locations. An on-site ground water monitoring program was implemented to monitor for potential licensed radioactive leakage into groundwater. The ground water monitoring results are being reported in the annual effluent and/or environmental monitoring report.
 
(http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html)  Entergy prepared procedures for the decision making process for potential remediation of leaks and spills, including consideration of the long term decommissioning impacts. Records of leaks and spills are being recorded in Entergy's decommissioning files in accordance with 10 CFR 50.75(g).
 
Entergy identified appropriate local and state officials and conducted briefings on Entergy's ground water protection initiative. Protocols have been established for notification to these local and state officials regarding detection of leaks and spills.
 
====b. Findings and Observations====
No findings of significance were identified.
 
===.3 Ground-Water Contamination Review===
 
====a. Inspection Scope====
The inspectors reviewed plans, procedures, and remediation activities affecting the contaminated ground water condition at Indian Point, relative to NRC regulatory requirements, as authorized by the NRC Executive Director of Operations in a Reactor Oversight Process deviation memorandum dated December 19, 2007 (ADAMS Accession number ML073480290). The inspectors also reviewed Entergy's performance relative to remediation of the principal source of groundwater contamination including observation of the draining and sludge removal of the Unit 1 spent fuel pools, the radioactive waste processing of the fuel pool water and residual sludge materials, and reviewed the radioactive liquid effluent release accounting and dose calculations resulting from these activities. The inspection included onsite inspections on September 18, 2008; October 10, 2008; October 14-15, 2008; and November 17-18, 2008.
 
====b. Findings and Observations====
No findings of significance were identified.
 
Following the removal of Unit 1 spent fuel to dry cask storage, Entergy established special radioactive liquid processing and sampling equipment for conducting the drain down of the Unit 1 spent fuel pools. Between September 15, 2008 and November 7, 2008, approximately 500,000 gallons of water were drained and processed which included pool surface rinse water used during sludge removal activities. The liquid processing equipment was designed to clarify the pool water prior to discharge into the 20 Enclosure Hudson River. The liquid processing system consisted of a series of sequential processing modules which included a filter cartridge, a 25 ft³ mixed (cation and anion) demineralizer resin vessel followed by five 12.5 ft³ supplemental water polishing units consisting of an activated charcoal vessel, a cation demineralizer resin vessel, a mixed demineralizer resin vessel, a cesium-specific filter media vessel, and finally another activated charcoal vessel. The filtered and demineralized water was sampled by an automatic composite sampler for monitoring and analysis prior to the effluent stream release into the discharge canal. Residual sludge from the bottom of the spent fuel pools was mixed with water and sluiced into a 120 ft 3 polyethylene disposal container. Liquids were removed from this solid waste container by periodically pumping down the container through the self-contained dewatering system contained in the disposal container. These liquid wastes were subsequently processed through the same liquid processing system as described above, however, due to the potentially higher radioactive contaminants, the final processed water was redirected to a Unit 1 waste collection tank to allow for additional waste water treatment prior to discharge. The 120 ft 3 disposal container of solid waste was classified as Class B waste and will be stored onsite until an offsite disposal facility becomes available.
 
The inspectors determined that treated and discharged water was sampled and properly accounted by Entergy to result in less than 1 Curie of radioactivity discharged consisting mostly of tritium, and small amounts of Kr-85 and Cs-137. The resulting public dose associated from this liquid discharge activity was 0.00007 mrem to the whole body and 0.00012 mrem to the highest organ (teen/liver). The inspectors confirmed these values represented small fractions of the liquid discharge limits of 3 mrem/yr whole body and 10 mrem/yr maximum organ dose limits specified in 10 CFR 50, Appendix I.
 
{{a|4OA6}}
==4OA6 Meetings==
 
===Exit Meeting Summary===
 
On January 9, 2008, the inspectors presented the inspection results to Mr. Joseph Pollock and other Entergy staff members, who acknowledged the inspection results presented. Entergy did not identify any material as proprietary.
 
{{a|4OA7}}
==4OA7 Licensee-Identified Violations==
 
The following violation of very low safety significance (Green) was identified by Entergy 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.
 
Technical Specification (TS) 3.6.6 requires, in part, a minimum of three trains of containment fan cooler units (FCU) to be operable in mode 1. Contrary to this requirement, the required number of FCUs was not operable in mode 1, assuming a single failure of one emergency diesel generator (EDG) to supply power to the 5A bus during a design basis accident, coincident with a loss of offsite power. Specifically, on March 28, 2008, Entergy identified an incorrect wiring configuration that would have prevented the automatic start of the 23 FCU. This condition, coincident with a single failure of an EDG during a design basis accident, coincident with a loss of offsite power, would have prevented the automatic start of at least three FCUs.
 
This issue was corrected on March 28, 2008 and entered into Entergy's corrective action 21 Enclosure program as IP2-2008-01482. The finding was more than minor because it was associated with the mitigating systems cornerstone and impacted the objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that this finding was of very low safety significance (Green) based on IMC 0609, Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," because the finding did not represent an actual loss of safety function of the FCUs for greater than their allowed outage time.
 
ATTACHMENT:   
ATTACHMENT:   


Line 46: Line 520:


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
.............................................................................................. A-1
 
==LIST OF ITEMS==
Entergy Personnel
OPENED, CLOSED AND DISCUSSED .................................................... A-2
: [[contact::J. Pollock]], Site Vice President
: [[contact::A. Vitale]], General Manager, Plant Operations
: [[contact::P. Conroy]], Director, Nuclear Safety Assurance
: [[contact::A. Williams]], Manager, Operations
: [[contact::J.R. Beckman]], Manager, Maintenance
: [[contact::T. Orlando]], Manager, Engineering
: [[contact::B. Sullivan]], Manager, Emergency Planning
: [[contact::S. Verrochi]], Manager, System Engineering
: [[contact::R. Walpole]], Manager, Licensing
: [[contact::D. Loope]], Manager, Radiation Protection
: [[contact::F. Inzirillo]], Manager, Quality Assurance
: [[contact::C. English]], Superintendent, Unit 1
: [[contact::S. Sandike]], Chemistry and Environmental Specialist
: [[contact::T. Stephens]], Energy Solutions
: [[contact::R. Turner]], Energy Solutions
: [[contact::R. Christman]], Training Manager
: [[contact::J. Whitney]], Emergency Diesel Generator System Engineer
 
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
 
===Opened and Closed===
 
None.  
===Closed===
: [[Closes LER::05000247/LER-2008-002]]-00 LER Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for an Inoperable Engineered Safety Feature Actuation System Automatic
: Actuation Logic and Actuation Relay Caused by Improper Relay Wiring (Section 4OA3) 
: Attachment
 
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
................................................................................... A-3
Indian Point Unit 2 Common Documents
==LIST OF ACRONYMS==
: Indian Point Unit 2 Control Room Narrative Logs Control Room Standing Orders Indian Point Unit 2 Updated Final Safety Analysis Report (UFSAR)
  ....................................................................................................... A-10
 
Enclosure
==Section 1R01: Adverse Weather Protection==
: [[SUMMAR]] [[Y]]
 
: [[OF]] [[]]
===Procedures===
: [[FINDIN]] [[]]
: OAP-048, Seasonal Weather Preparation
GS IR 05000286/2008-005; 10/01/2008 - 12/31/2008; Indian Point Nuclear Generating Unit 3; Post-Maintenance Testing. This report covered a three-month period of inspection by resident and region based inspectors.
: OAP-008, Severe Weather Preparations 2-COL-11.5, Space Heating and Winterization 2-COL-30.1, Electric Heat Tracing 2-AOP-FLOOD-1, Flooding 
One finding of very low significance (Green) was identified. This finding was also determined to be a non-cited violation (NCV) of
===Condition Reports===
: [[NRC]] [[requirements. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (]]
: IP2-2007-05291
IMC) 0609, "Significance Determination Process." Findings for which the significance determination process (SDP) does not apply may be Green, or be assigned a severity level after
: IP2-2008-04096
: [[NRC]] [[management review. The]]
: IP2-2007-00884
: [[NRC]] [['s program for overseeing safe operation of commercial nuclear power reactors is described in]]
: IP2-2007-04853
: [[NUREG]] [[-1649, "Reactor Oversight Process," Revision 4, dated December 2006.]]
: IP2-2006-02133
: [[A.]] [[]]
: IP2-2006-03406
: [[NRC]] [[-Identified and Self-Revealing Findings Cornerstone:  Mitigating Systems  * (Green)  A self-revealing, non-cited violation of]]
: IP2-2006-06311
: [[10 CFR]] [[50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings" was identified, because Entergy did not establish the appropriate torque requirements and lubricant specifications in plant instructions and procedures during replacement and maintenance of bearings for the 34 control building (]]
: IP2-2007-04332  
CB) exhaust fan. Specifically, between January 2006 and September 2008, Entergy did not establish procedural guidance to ensure proper torque values
===Miscellaneous===
were used on the
: Individual Plant Examination of External Events for Indian Point Unit No. 2
: [[34 CB]] [[exhaust fan pillow block bolts to preclude movement of the fan bearings. Additionally, during this time period, Entergy used an incompatible grease to lubricate 34]]
 
CB exhaust fan bearings. The incompatible grease and improperly torqued bolts contributed to the 34 CB exhaust fan bearings being replaced in January 2006; June 2008; and in September 2008. Entergy corrected the incompatible grease issue
==Section 1R04: Equipment Alignment==
and included vendor-recommended torque values during the most-recent bearing replacement for the
 
: [[34 CB]] [[exhaust fan in September 2008. The inspectors determined the finding was more than minor because it was associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the cornerstone objective to ensure reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Entergy did not ensure the reliability of the 34]]
===Procedure===
CB exhaust fan with appropriate instructions that established bolt torques and type of grease. The significance of this finding was
: 2-COL-27.3.1, Diesel Generators
evaluated using a Phase 1 SDP screening and was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency; it did not represent a loss of system safety function; and it did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating events. The finding had a cross-cutting aspect in problem identification and resolution in that Entergy did not thoroughly evaluate problems such that the resolutions addressed the causes when equipment failed on an increased frequency. (P.1(c)) (Section 1R19)
: 2-PT-Q028A, "21 Residual Heat Removal Pump," Rev. 18 2-SOP-4.2.1, "Residual Heat Removal System," Rev. 61 2-COL-4.2.1, "Residual Heat Removal System," Rev. 26 2-COL-10.1.1, "Safety Injection System," Rev. 32 2-COL-27.6, "Unit 2 Appendix R Diesel Generator," Rev. 0 
Enclosure
===Drawings===
: [[B.]] [[Licensee-Identified Violations A violation of very low safety significance identified by Entergy was reviewed by the inspectors. Corrective actions taken or planned by Entergy have been entered into the corrective action program. This violation and corrective action tracking number are listed in Section 4]]
: 9321-2735
OA7 of this report.
: 235296
Enclosure
: 251783 
: [[REPORT]] [[]]
===Miscellaneous===
DETAILS  Summary of Plant Status  Indian Point Nuclear Generating (Indian Point) Unit 3 operated at or near full power throughout the inspection period.
: ARDG-003-APP-R, Restoration tagout dated 10/21/08
 
==Section 1R05: Fire Protection==
 
===Procedures===
: 2PT-2Y017, Penetration Fire Barrier Seal Inspections 2-PT-EM19, Cable Spreading Room Halon Testing
: PT-EM28, Fire Dampers Operability
: SAO-703, Fire Protection Impairment Criteria and Surveillance
: EN-DC-161, Control of Combustibles
: Attachment  
===Condition Reports===
: IP2-2008-04245
: IP2-2008-04657
: IP2-2008-04888
: IP2-2008-04962
: IP2-2008-05090
: IP2-2008-05551 
===Drawings===
: 400401-04, Fire Area/Zone Arrangement at
: EL 15'
: 400404-02, Fire Area/Zone Arrangement at
: EL 80' Orders
: IP2-03-31785
: IP2-05-21166
: 51645811 
===Miscellaneous===
: Indian Point Nuclear Generating Station, Unit 2, Fire Protection Program Plan, Rev. 9 Indian Point Pre-Fire Plans Unit 2 - Nuclear
: IP2-RPT-03-00015, "IP2 Fire Hazards Analysis," Rev. 3
 
==Section 1R11: Licensed Operator Requalification Program==
 
===Procedures===
: EN-TQ-201, Systematic Approach to Training Process, Rev 4
: IP-SMM
: TQ-114, Continuing Training & Requalification Examinations for Licensed Personnel, Rev 7
: OAP-032, Operations Training Program, Rev 9
: OAP-033, Conduct of Operations Simulator Training, Evaluations, and Debriefs, Rev 4 2-AOP-FW-1, "Loss of Main Feedwater," Rev. 11
: 2-AOP-SG-1, "Steam Generator Tube Leak," Rev. 10  
===Miscellaneous===
: LRQ Sample Plan for 2007 Comprehensive Written Exam 12SG-LOR-AOP014, Instrument/Controller Failures Lesson Plan, Rev 2 12LP-LOR-AOP009, Containment Integrity, RCS Activity, & Air System Malfunction Lesson Plan, Rev 0
 
==Section 1R12: Maintenance Effectiveness==
 
===Procedures===
: EN-DC-203, Maintenance Rule Program
: EN-DC-205, Maintenance Rule Monitoring
: EN-DC-324, Preventive Maintenance Process 0-SYS-401-Gen, "Application of Protective Coatings," Rev. 1 
===Condition Reports===
: IP2-2008-04472
: IP2-2008-04709
: IP2-2008-04342
: IP2-2008-04228
: IP2-2008-04112  
===Work Orders===
: 00164495
===Miscellaneous===
: NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants Service Water System Health Report, 3Q 2008  
: Attachment Maintenance Rule Basis Document - Service Water
: IP2-UT-08-085, UT erosion/corrosion examination line #1505
: IP2-UT-08-086, UT erosion/corrosion examination line #1505
: IP2-UT-08-087, UT erosion/corrosion examination line #1509
: IP2-UT-08-088, UT erosion/corrosion examination line #1509
: IP2-UT-08-089, UT erosion/corrosion examination line #1509
 
==Section 1R13: Maintenance Risk Assessments and Emergent Work Control==
 
===Procedures===
: 2-PT-R084C, 23 EDG 8 Hour Load Test
: IP-SMM-WM-101, On-Line Risk Assessment 
===Condition Reports===
: IP2-2008-04812
===Work Orders===
: 51570202
: 00156016
: 51570202
: 00156016 
===Miscellaneous===
: TS 3.8.1.10 Note 2 Assessment for U2 EDG 8 Hour Runs in Mode 1 Indian Point Daily Status Reports for October 1, 2, and 3, 2008 EOOS Risk Model Operator's Risk Report for Unit 2 on 10/2 and 10/3, 2008
: Week 0840 Unit 2 Operator's Risk Report.
 
==Section 1R15: Operability Evaluations==
 
===Procedures===
: 3-PMP-003-CCW, Inspection/Repair of the Component Cooling Pump 
===Drawings===
: 242688
: 235306
: 21-2723 
===Condition Reports===
: IP2-2008-04921
: IP2-2008-03041
: IP2-2008-04495
: IP2-2008-04351
: IP2-2008-04951 
===Work Orders===
: 51668324
: 00149226
===Miscellaneous===
: Vendor manual - Ingersoll Rand "S" Line General Service Pumps
 
==Section 1R18: Plant Modifications==
 
===Procedures===
: EN-DC-136, Temporary Modifications
: Attachment 
===Condition Reports===
: IP2-2008-04898 
===Work Orders===
: 00174868
===Drawings===
: Sketch "A"
: TM-12305 
===Miscellaneous===
: Indian Point Unit 2 Maintenance Rule Document - 138 kVAC Electrical System Vendor manual - 1380-SF-10000 series electrical breaker TMOD No:
: EC 12305, Install Nitrogen connection at
: BT4-5 air compressor tank.
 
==Section 1R19: Post-Maintenance Testing==
 
===Procedures===
: 2-BRK-021-CUB, Westinghouse 480V DB Series Breaker Cubicle Inspection and Cleaning
: 0-HTX-405-EDG, EDG Lube Oil and Jacket Water Heat Exchanger Maintenance 2-IC-PC-I-P-1139, "Auxiliary Boiler Feed Pump No.22 Steam Supply Controller," Rev. 0
: OAP-24, "Operations Testing," Rev. 3
: PFM-44, "Generic Inservice Pressure Test Program," Rev. 3 2-BRK-001-ELC, "ITE Type KC, Model G-Air Circuit Breaker," Rev. 0 
===Condition Reports===
: IP2-2008-05089 
===Work Orders===
: 270253
: 51670696
: 51606970
: 00137722
: 00173188
: 51644972
: 51655457
: 51315478
: 51672218 
===Drawings===
: 226033
: 251231
: 251232 9321-2017 9321-2125
: 208088
: 244016
===Miscellaneous===
: Conoflow Regulators and Controls Instruction and Maintenance Manual, GP50 series
 
==Section 1R22: Surveillance Testing==
 
===Procedures===
: 2-PT-Q035B, 22 Containment Spray Pump Test 2-PC-2Y55, Containment Sump Discrete Level Instrumentation 2-ES-1.3, Transfer to Cold Leg Recirculation 2-E-1, Loss of Reactor or Secondary Coolant
: 2-NF-309, RCS Delta-T, T-Avg and Flow Measurement 2-PT-V59, "Reactor Trip Breaker "A" Changeout and Functional Test," Rev. 4 2-PC-4Y74C, "Nuclear Instruments Power Range N-43," Rev. 1
: PT-Q13, "Inservice Valve Tests", Data Sheet 38 - valve 869B, Rev. 21
: Attachment  
===Condition Reports===
: IP2-2008-04852
: IP2-2008-04380
: IP2-2008-04450
: Orders
: 51570801
: 00164350
: 51298850  
===Miscellaneous===
: EC 3714, Replacement of
: LT-3300 and
: LT-3301 and Addition of PICS input from
: LT-939 and
: LT-941
: IP2-RHR/SIS DBD, Residual Heat Removal and Safety Injection Design Basis Document
 
==Section 1EP2: Alert and Notification System (ANS) Evaluation==
 
===Procedures===
: Command and Control Alert Notification Testing, October 22, 2008
 
==Section 2OS3: Access Control to Radiologically Significant Areas==


1.
===Procedures===
: [[REACTO]] [[R]]
: EN-CY-108, Rev. 2, Monitoring of Non-Radioactive Systems
SAFETY  Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity  1R01 Adverse Weather Protection    a. Inspection Scope (71111.01 - 1 sample)  The inspectors performed a detailed review of Entergy's adverse weather procedure, operating procedures, Technical Specifications (TS), and Corrective Action Program (CAP) to verify applicable cold weather preparations were completed for anticipated
: EN-RP-113, Rev. 2, Response to Contaminated Spills / Leaks
adverse winter weather challenges. The inspectors evaluated Entergy's preparation and readiness for freezing weather conditions, evaluated applicable compensatory measures, and conducted plant and system walkdowns in the auxiliary feedwater building, service water intake structure, and
: EN-RP-303, Rev. 2, Source Check Radiation Protection Instrumentation
control building. In addition, the inspectors reviewed the status of deficiencies identified by Entergy during the current seasonal preparations, and verified that adverse conditions were adequately addressed to ensure that cold temperatures would not have significant impact on plant operation and safety. The documents reviewed during this inspection are listed in the Attachment. This represented one inspection sample of risk-
: EN-RP-306, Rev. 2, Calibration and Operation of the Eberline
significant systems. b. Findings  No findings of significance were identified. 1R04 Equipment Alignment  .1 Partial System Walkdown (71111.04Q - 3 samples)
: PM-7
a. Inspection Scope  The inspectors performed partial system walkdowns to verify the operability of redundant or diverse trains and components during periods of system train unavailability, and where applicable, following return to service after maintenance. The inspectors reviewed system procedures, the Updated Final Safety Analysis Report (UFSAR), and system drawings to verify that the alignment of the applicable system or component
: EN-RP-309, Rev. 1, Operation and Calibration of the Eberline
supported its required safety functions. The inspectors also reviewed applicable condition reports or work orders to ensure that Entergy had identified and properly addressed equipment deficiencies that could potentially impair the capability of the available train. The documents reviewed during this inspection are listed in the Attachment.
: AMS-3 / 3A Continuous Air
Enclosure The inspectors performed partial walkdowns of the following systems or components, which represented three inspection samples: * 31 emergency diesel generator (EDG) while the 32 EDG was out of service on November 4, 2008; * 31 service water pump following return to service on November 23, 2008; and * 32 charging pump following return to service on December 22, 2008. b. Findings  No findings of significance were identified. 
: Monitor
.2 Complete System Walkdown (71111.04S - 1 sample)    a. Inspection Scope  The inspectors performed a complete system walkdown of accessible portions of the
: EN-RP-501, Rev. 3, Respiratory Protection Program
containment spray (CS) system, to identify discrepancies between the existing equipment alignment and the required alignment for the current plant conditions. The inspectors reviewed operating procedures, surveillance tests, electrical drawings, equipment lineup check-off lists, and the
: EN-RP-502, Rev. 4, Inspection and Maintenance of Respiratory Protection Equipment
: [[UFSAR]] [[, to determine if the]]
: IP-EP-AD6-20, Rev. 2, Respiratory Protection Monthly Equipment Inventory
CS system was aligned to perform its required safety functions. The inspectors reviewed a sample of condition reports that were written to address deficiencies associated with the CS system, and verified that these deficiencies were appropriately evaluated and/or
: IP-EP-AD6-21, Rev. 3, Respiratory Protection Quarterly Equipment Inventory
resolved. The documents reviewed during this inspection are listed in the Attachment. The walkdown of the CS system represented one inspection sample. 1R05 Fire Protection 
: IP-RP-IC-301, Rev. 1, Calibration of the Eberline
.1 Fire Protection Tours (71111.05Q - 4 samples)    a. Inspection Scope  The inspectors conducted tours of fire areas to assess the material condition and
: AMS-4 Air Monitoring System Using Windows
operational status of fire protection features. The inspectors verified, consistent with the applicable administrative procedures, that: combustible material and ignition sources were adequately controlled; passive fire barriers, manual fire-fighting equipment, and suppression and detection equipment were appropriately maintained; and compensatory measures for out-of-service, degraded, or inoperable fire protection equipment were
: IP-SMM-CY-001, Rev. 6, Radioactive Effluents Control Program
implemented in accordance with Entergy's fire protection program. The inspectors also evaluated the fire protection program against the requirements of License Condition 2.K. The documents reviewed during this inspection are listed in the Attachment. This inspection represented four inspection samples and was conducted in the areas
: RE-ADM-1-22, Rev. 0, Site Soil Characterization
covered by the following Pre-Fire Plans:  * Pre-Fire Plan 354; * Pre-Fire Plan 354A; * Pre-Fire Plan 355, 356; and * Pre-Fire Plan 357, 358.
: RE-INS-7CC-1, Rev. 12, Calibration of the Eberline
Enclosure  b. Findings  No findings of significance were identified.  .2 Annual Fire Drill (71111.05A - 1 sample)
: AMS-2 Beta-Gamma Air Monitor
a. Inspection Scope  On December 9, 2008, the inspectors observed an unannounced fire brigade drill that utilized on-watch fire brigade members from the shift operations crew. The drill was conducted in accordance with Entergy's preplanned drill scenario that involved a
: RE-INS-7CC-7/8, Eberline
simulated electrical fire with associated hazards in the vicinity of the 31 vital battery room located in the control building. The inspectors evaluated the performance of the fire brigade during the drill, consistent with the pre-planned drill scenario, to verify the following attributes: * The fire brigade members properly donned protective clothing/turnout gear, which included simulated use of self-contained breather apparatus (SCBA) equipment; * Fire hose lines were capable of reaching the fire hazard locations, were laid out without flow restrictions, and were simulated being charged with water; * Brigade members entered the fire area in a controlled manner, and utilized appropriate equipment consistent with the type of fire simulated during the drill; * Sufficient fire-fighting equipment was brought to the scene by the fire brigade; * The fire brigade leader's directions during implementation of the pre-fire plans for the designated fire area were clear and effective; * Radio communications, as well as face-to-face communications with the plant operators and fire brigade members were clear and effective; * Control room personnel followed applicable procedures for response to a fire and declared appropriate Emergency Action Levels and associated notifications consistent with the appropriate procedures and the Emergency Plan; * The drill report contained appropriate post-drill critique comments and identified deficiencies consistent with the objectives and acceptance criteria of the drill; and * Deficiencies were entered into the corrective action program. Documents reviewed during this inspection are listed in the Attachment. b. Findings  No findings of significance were identified. 1R06 Flood Protection Measures  a. Inspection Scope (71111.06 - 1 sample)  The inspectors reviewed the Unit 3 Individual Plant Examination, the
: PING-1A Calibration Record
: [[UFS]] [[]]
: RE-INS-7CH-3, Rev. 10, Calibration of the Merlin-Gerin
: [[AR]] [[, and]]
: CDM-21 Electronic Dosimeter
: [[IP]] [[-]]
: Calibrator Using WCDM 2000
: [[RPT]] [[-06-00071, "Indian Point Unit 3 Probabilistic Safety Assessment (PSA)," Rev. 2, concerning internal flooding events. The inspectors assessed flood mitigation of the primary auxiliary building (PAB). Specifically, Engineering Change 5000041988, which implemented new flood protection measures by directing water out of the]]
: RE-INS-7CH-4, Rev. 5, Characterization of the J.L. Shepherd 81-12, 142-10 and 149 Sources
: [[PAB]] [[via a new drain pipe and check valve. The inspectors also reviewed applicable portions of 3-]]
: RE-INS-7UH-12, Rev. 10, Beam Source Check Sheet 0-RP-IC-101, Rev. 2, Calibration of Portable Ion Chamber Survey Meters 0-RP-IC-102, Rev. 0, Calibration of the Eberline
AOP-
: ASP-1 with Neutron Detector 0-RP-IC-301, Rev. 1, Calibration of the Eberline
Enclosure
: AMS-4 Air Monitoring System Using Windows 0-RP-IC-402, Rev. 1, Calibration and use of the MGP Telepole 0-RP-IC-601, Rev. 0, Calibration of the Tennelec
: [[FLOOD]] [[-1, "Flooding," Rev. 4, and verified assumptions included in the site's internal flooding analysis. This inspection represented one sample for internal flood protection measures. b. Findings  No findings of significance were identified. 1R07 Heat Sink Performance    a. Inspection Scope (71111.07 - 1 sample) The inspectors evaluated maintenance activities and reviewed performance data associated with the 32]]
: LB-5100 Alpha-Beta Counting System Using
EDG jacket water heat exchanger. The inspectors reviewed applicable design basis information and commitments associated with Entergy's Generic Letter 89-13 program to validate that maintenance activities were adequate to ensure the system could perform its safety function. The inspectors reviewed as-found and as-left results from previous heat exchanger cleanings to ensure the periodicity of
: Eclipse 0-RP-IC-603, Rev. 0, Interchangeable Counting Room Calibration with
maintenance activities were appropriate, and conditions adverse to quality were being identified and corrected. This inspection represented one sample for heat sink performance. b. Findings  No findings of significance were identified. 1R11 Licensed Operator Requalification Program 
: HP-300 0-RP-IC-604, Rev. 0, Calibration of the Eberline Model
.1 Quarterly Resident Inspector Evaluation (71111.11Q - 1 sample)   a. Inspection Scope  The inspectors observed licensed operator requalification training conducted on
: BC-4 Beta Counter
November 18, 2008, in the Unit 3 plant-reference simulator. The inspectors assessed the scope and breadth of the training, which included the following:  (1) discussions with Entergy staff regarding deficiencies in operator performance and/or training being addressed in the current requalification training cycle; (2) assessment of the implementation of abnormal and emergency procedures utilized by Unit 3 control room
: 0-CY-1420, Rev. 2, Radiological Quality Assurance Program 0-CY-1510, Rev. 4, IPEC Storm Drain Sampling 0-CY-1900, Rev. 0, Nuclear Environmental Monitoring Sampling and Analysis Schedule 0-CY-2740, Rev. 1, Liquid Radioactive Effluents Attachment  
operators to respond to, and mitigate the effects of, simulated loss of feedwater and uncontrolled cool-down events at the site; (3) technical specification implementation for the specific events simulated during the training; and (4) overall crew performance. The inspectors reviewed simulator fidelity to verify correlation with the actual plant control room, and to verify that differences in fidelity that could potentially impact training effectiveness were either identified or appropriately dispositioned. Licensed operator
: 2-PC-R25, Rev. 15, Main Steam Line Radiation Monitor Detector Calibration (R-28, 29, 30, 31) 2-PC-R38-1, Rev. 3, High Range Containment Area Radiation Monitor (R-25) 2-PC-R38-2, Rev. 2, High Range Containment Area Radiation Monitor (R-25) 2-PC-R38-3, Rev. 3, High Range Containment Area Radiation Monitor (R-26) 2-PC-R38-4, Rev. 2, High Range Containment Area Radiation Monitor (R-26) 2-PC-R15B, Rev. 17, VC Area Radiation Monitor Calibration (R-7)
training was evaluated against the requirements of 10 CFR 55, "Operator Licenses."  Documents reviewed during this inspection are listed in the Attachment. This review represented one inspection sample for licensed operator requalification training.
: 2-PC-EM4, Rev. 12, Non-VC Area Radiation Monitors Calibration 2-PC-EM30, Rev. 10, Process Radiation Monitor Calibration (R-41, 42) 2-PC-2Y23, Rev. 10, Liquid Radiation Monitor Calibration 3-CY-2325, Rev. 6, Radioactive Sampling Schedule 3-IC-RMP-R-7, Rev. 0, Calibration of Radiation Monitor R-7
Enclosure  b. Findings  No findings of significance were identified.  .2 Region-Based Requalification Program Inspection (71111.11B -1 sample)
: 3-PC-R40, Rev. 17, Main Steam Line Radiation Monitor Calibration (R-62) 3-PC-OL-48, Rev. 4, Fuel Storage Building Radiation Monitor Calibration (R-5) 3-PC-R46A, Rev. 15, Containment High Range Radiation Monitor Calibration (R-25) 3-PC-R46B, Rev. 14, Containment High Range Radiation Monitor Calibration (R-26) 3-PC-OL-58A, Rev. 2, Process Radiation monitors R11/12 Calibration 3-PC-OL-49A, Rev. 2, Steam Generator Blow down Radiation Monitor Calibration (R-19)   
a. Inspection Scope  On November 14, 2008, a region-based inspector conducted an in-office review of results of the licensee-administered annual operating tests and comprehensive written exams for 2008 on Unit 3. The inspection assessed whether pass rates were consistent
===Condition Reports===
with the guidance of
: IP2-2007-04816
: [[NRC]] [[Manual Chapter 0609, Appendix I,]]
: IP2-2007-04818
AOperator Requalification Human Performance Significance Determination Process (SDP).@  The inspector verified that:  * Crew failure rate was less than 20%.  (Crew failure rate was 0%);  * Individual failure rate on the dynamic simulator test was less than or equal to 20%. (Individual failure rate was 0%);  * Individual failure rate on the walk-through test was less than or equal to 20%. (Individual failure rate was 0%);  * Individual failure rate on the comprehensive written exam was less than or equal to 20%. (Individual failure rate was 0%); and * Overall pass rate among individuals for all portions of the exam was greater than or equal to 75%.  (Overall pass rate was 100%). b. Findings  No findings of significance were identified. 1R12 Maintenance Effectiveness    a. Inspection Scope (71111.12Q - 3 samples)  The inspectors reviewed performance based problems that involved selected structures, systems, or components (SSCs), to assess the effectiveness of maintenance activities
: IP2-2008-00055
and to verify activities were conducted in accordance with site procedures and
: IP2-2008-00405
: [[10 CFR]] [[50.65 (The Maintenance Rule). The reviews focused on: * Evaluation of Maintenance Rule scoping and performance criteria; * Verification that reliability issues were appropriately characterized; * Verification of proper system and/or component unavailability; * Verification that Maintenance Rule (a)(1) and (a)(2) classifications were appropriate; * Verification that system performance parameters are appropriately trended; and * For]]
: IP2-2008-00601
SSCs classified as Maintenance Rule (a)(1), that goals and associated corrective actions were adequate and appropriate for the circumstances.
: IP2-2008-00770
Enclosure The inspectors also reviewed system health reports, maintenance backlogs, and Maintenance Rule basis documents. The documents reviewed during this inspection are listed in the Attachment. The following systems and/or components were reviewed and represented three inspection samples: * 138kV electrical system, breaker
: IP2-2008-01236
: [[BT]] [[-5-6 deficiencies; * Low pressure steam dump system deficiencies; and * Safety injection system deficiencies. b. Findings  No findings of significance were identified. 1R13 Maintenance Risk Assessments/Emergent Work Control    a. Inspection Scope (71111.13 - 4 samples)  The inspectors reviewed maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work as required by 10]]
: IP2-2008-01262
CFR 50.65 (a)(4). When planned work scope or schedules were altered to address emergent or unplanned conditions, the inspectors verified that the plant risk was promptly reassessed and managed. The documents reviewed during this inspection are listed in the Attachment. The following activities represented four inspection samples: * Planned risk on October 2, 2008, while 138kV feeder 33332 L&M was removed from service; * Planned risk on October 30, 2008, while 34 containment fan cooler unit was removed from service; * Planned risk on November 10, 2008, during safety injection system logic testing; and * Planned risk on December 19, 2008, while the 32 instrument air compressor was out-of-service during severe weather warnings. b. Findings  No findings of significance were identified.
: IP2-2008-01391
1R15 Operability Evaluations    a. Inspection Scope (71111.15 - 4 samples)  The inspectors reviewed operability evaluations to assess the acceptability of the
: IP2-2008-01463
evaluations, the use and control of compensatory measures when applicable, and compliance with Technical Specifications. These reviews included verification that operability determinations were performed in accordance with procedure
: IP2-2008-01760
: [[ENN]] [[-]]
: IP2-2008-01823
: [[OP]] [[-104, "Operability Determinations."  The inspectors assessed the technical adequacy of the evaluations to ensure consistency with the]]
: IP2-2008-02000
: [[UFS]] [[]]
: IP2-2008-02504
AR and associated design and licensing
: IP2-2008-02621
basis documents. The documents reviewed are listed in the Attachment. The following operability evaluations were reviewed and represented four inspection samples: *
: IP2-2008-02739
: [[CR]] [[-]]
: IP2-2008-03659
IP3-2008-03085: Corrosion and battery post seal-bulging on Battery 31;
: IP2-2008-03661
Enclosure *
: IP2-2008-03798
: [[CR]] [[-]]
: IP2-2008-04192
: [[IP]] [[3-2003-01600:  Recurrent 31 service water system zurn strainer corrosion; *]]
: IP2-2008-04428
: [[CR]] [[-]]
: IP2-2008-05074
: [[IP]] [[3-2008-03046: Spurious containment fan cooler unit low flow alarms; and *]]
: IP2-2008-05410
: [[CR]] [[-]]
: IP2-2008-05411
IP3-2008-02822: PCV-1190 failure-to-close during testing. b. Findings  No findings of significance were identified. 1R18 Plant Modifications  .1 Temporary Setpoint Change for Main Unit Generator Exciter Cold Gas Temperatures
: IP2-2008-05412
a. Inspection Scope (71111.18 - 1 sample)  The inspectors reviewed the design documentation associated with the temporary setpoint change for the exciter cold gas temperature alarms. The inspectors verified the adequacy of the temporary modification and reviewed the associated operational
: IP2-2008-05483
decision-making instruction. This verification included review of the system impacts of raising the alarm setpoint, the impact on operator actions, and the modification installation testing requirements. The inspectors also reviewed the work package and planning that was scheduled in the next outage to clear this temporary modification. b. Findings  No findings of significance were identified.  .2 Installation of a Full Enclosure Clamp on Steam Valve
: IP2-2008-05516
: [[MS]] [[-202  a. Inspection Scope (71111.18 - 1 sample)  The inspectors reviewed the design documentation associated with the temporary repair of a steam leak on main steam valve (]]
: IP3LO-2008-00069
MS)-202, isolation valve for main turbine cylinder heating steam. The inspectors reviewed plant operating procedures to ensure the installation of the sealing clamp would not adversely impact normal and off-normal plant
: IP3-2008-00314
operations. The inspectors also verified that the sealing technique would not adversely impact plant equipment, which included chemistry impacts and steam generator parameters. Installation testing and restoration work was reviewed along with the timeline for restoration of the valve to its original configuration.
: IP3-2008-00484
b. Findings  No findings of significance were identified. 1R19 Post-Maintenance Testing    a. Inspection Scope (71111.19 - 8 samples)  The inspectors reviewed post-maintenance test procedures and associated testing activities for selected risk-significant mitigating systems, and assessed whether the effect of maintenance on plant systems was adequately addressed by control room and plant personnel. The inspectors verified that: test acceptance criteria were clear; tests
: IP3-2008-00516
Enclosure demonstrated operational readiness and were consistent with design basis documentation; test instrumentation had current calibrations and appropriate range and accuracy for the application; tests were performed as written; and applicable test prerequisites were satisfied. Upon completion of the tests, the inspectors verified that equipment was returned to the proper alignment necessary to perform its safety function. Post-maintenance testing was evaluated against the requirements of 10 CFR 50,
: IP3-2008-00705
Appendix B, Criterion
: IP3-2008-00729
: [[XI]] [[, "Test Control."  The following post-maintenance activities were reviewed and represented eight inspection samples:  * 34 control building exhaust fan bearing replacement on September 27, 2008; * 32 containment fan cooler unit (]]
: IP3-2008-01454
: [[FCU]] [[) maintenance on October 8, 2008; * 31 emergency diesel generator (EDG) outage on October 8 - 9, 2008; * 32 central control room air-conditioning unit maintenance on October 23, 2008; * 34 service water pump (SWP) breaker inspection on October 27, 2008; *]]
: IP3-2008-01464
: [[32 EDG]] [[maintenance activities on November 4 - 5, 2008; * 36]]
: IP3-2008-01815
SWP maintenance activities on November 5, 2008; and * 31 boric acid transfer pump maintenance activities on December 22, 2008. b. Findings  Introduction:  A Green, self-revealing, non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified, because
: IP3-2008-02117
Entergy did not establish appropriate torque values in maintenance procedures used for bearing replacements for the 34 Control Building (CB) exhaust fan. Additionally, Entergy did not specify the appropriate grease for lubrication of the
: IP3-2008-02566
: [[34 CB]] [[exhaust fan pillow block bearings during maintenance. Description:  The 34]]
: IP3-2008-02851
CB exhaust fan is required to remove heat from the 480 volt switchgear room to ensure Entergy can safely shutdown and maintain the Unit 3 reactor in a safe condition. The 34 CB exhaust fan experienced bearing failures more frequently than expected for the type of bearing being used in the fan, as evidenced by bearing replacements that occurred in January 2006, June 2008, and September 2008. In
: IP3-2007-04640 
January 2006, Entergy installed new, pillow block bearings on the
===Miscellaneous===
: [[34 CB]] [[exhaust fan, based on information contained in Technical Evaluation #98-001561. This Technical Evaluation, which was completed in June 1998, did not incorporate the manufacturer-recommended torque values for the pillow block bearings into the applicable maintenance procedures. In addition, Entergy's technical evaluation did not identify that the grease used on-site to lubricate these bearings was incompatible with the grease used by the manufacturer to pre-lubricate the bearings. In May 2007, Entergy identified elevated vibration readings on the 34]]
: LCOTR # 2-TS-08-0923 IPEC Radiation Monitoring System Top Ten Technical Issues Action Plan, updated 12/17/08
CB exhaust fan, as well as discolored grease and metal filings in the vicinity of the fan's bearings. Entergy generated a work order to replace the bearings and perform an alignment of the fan but the issue was not entered into Entergy's corrective action program (CAP) and the
: IPEC Radiation Monitoring System Long Range Plan Plan, updated 12/17/08 IPEC Radiation Monitoring System Condition Report Trend Review, updated 12/17/08 RMS Maintenance Improvement Plan, updated 12/17/08 Units 2 and 3 System Health Report for 2008 ER No. 04-2-042, R-41 / 42 Reliability Improvements Engineering Review package Radiation Monitor, Portable Radiation Monitoring Instrumentation, and Calibrator Calibration
maintenance was not scheduled or performed in the short term. Subsequently, the
: Sheets C.A.R.E Authorized Repair Center Certifications DUKE / NUPIS Member Audit Report of General Engineering Laboratories, LLC (GEL) IPEC: Nuclear Energy Institute Groundwater Protection Initiative Self Assessment Checklist, dated July 2008.
: [[34 CB]] [[exhaust fan experienced a step change in its vibration signature on December 10, 2007. This step change in fan vibration was documented by Entergy in condition report (]]
CR)-IP3-2007-04535, and vibration readings were trended thereafter by Entergy staff. In June 2008, the 34 CB exhaust fan bearings were replaced and a fan alignment was performed with the work order previously generated in 2007. Subsequently, on July 21,
Enclosure 2008, Entergy identified elevated vibrations on the
: [[34 CB]] [[exhaust fan, and replaced the 34]]
: [[CB]] [[exhaust fan belts and performed an alignment between the fan and motor. On August 20, 2008, Entergy identified that the]]
: [[34 CB]] [[exhaust fan shaft was rubbing the fan housing and entered the issue into the]]
: [[CAP]] [[as]]
: [[CR]] [[-]]
IP3-2008-2004. In addition, due to excessive noise and vibrations from the 34 CB exhaust fans, Entergy removed the fan
from service. Following replacement of the fan bearings, belts, shaft and pulleys, the fan was returned to service on September 30, 2008. During Entergy's investigations following the August 2008 bearing issues, Entergy personnel determined that the primary cause of the more frequent bearing failures in the
: [[CB]] [[exhaust fan was inadequate application of torque on the 34]]
: [[CB]] [[exhaust fan pillow block bolts, which resulted in fan shaft movement that affected the alignment and caused degradation of the fan bearings. Specifically, Entergy determined that their technical evaluation performed in 1998 and the]]
: [[CB]] [[exhaust fan bearing replacement procedure 3-]]
FAN-011-CBF, "Inspection, Cleaning, and Repair of Control Building Exhaust Fans and Louvers L-319 and L-320," did not reference the manufacturer recommended torque value or guidance for the pillow block bearing housing bolts.
Entergy also determined that incompatible grease was used to lubricate the bearings and contributed to more frequent bearing failures. Specifically, the pillow block bearings were supplied from the manufacturer pre-lubricated with Timken Ball Bearing grease (No. 2 polyurea-based grease). The grease used by Entergy during installation and periodic lubrication of these bearings was Mobilith AW-2 grease, which Entergy later
determined to be incompatible with the grease used by the manufacturer. Entergy determined the incompatible greases reduced their lubrication properties and likely degraded bearing performance and resulted in elevated equipment vibration. The inspectors determined that Entergy's failure to establish appropriate torque
requirements in the applicable maintenance procedures, including establishment of an appropriate bearing lubricant, was a performance deficiency. Additionally, Entergy had opportunities to evaluate and correct these performance issues in May 2007, December 2007, and July 2008, in response to elevated vibrations associated with the CB exhaust fan, as well as a bearing replacement that occurred in June 2008.
Analysis:  The inspectors determined the finding was more than minor because it was associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the cornerstone objective to ensure availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences. Specifically, Entergy did not ensure the reliability of the
: [[34 CB]] [[exhaust fan by applying improper torque to the pillow block bolts to preclude movement during equipment operation and usage of incompatible grease to lubricate the bearings. The significance of this finding was evaluated using a Phase 1]]
SDP screening and was determined to be
of very low safety significance (Green) because it was not a design or qualification deficiency; it did not represent a loss of system safety function; and it did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating events.
The finding had a cross-cutting aspect in problem identification and resolution in that Entergy did not thoroughly evaluate problems such that the resolutions addressed the causes when the 34 CB exhaust fan exhibited high vibrations on an increased frequency. (P.1(c))
Enclosure  Enforcement:
: [[10 CFR]] [[50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings" states, in part, that instructions, procedures, and drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to the above, Entergy did not specify the appropriate torque requirements and lubricant in maintenance procedure 3-]]
: [[FAN]] [[-011-]]
CBF, "Inspection, Cleaning, and Repair of Control Building Exhaust Fans and Louvers L-319 and L-320," for replacing and maintaining the bearings for the 34 control building (CB) exhaust fan. Specifically, after the August 2008, 34 CB exhaust fan bearing issues, Entergy determined that since January 2006 they had applied improper torque to the fan bearings and used incompatible grease to lubricate the fan bearings.
Entergy's apparent cause evaluation and corrective actions are documented in
: [[CR]] [[-]]
: [[IP]] [[3-2008-02224 and]]
: [[CR]] [[-]]
: [[IP]] [[3-2008-02345. Entergy implemented vendor recommended torque specifications for the pillow block bolts and used the proper lubricant during the September 2008 repair. Because this issue is of very low safety significance and is entered into Entergy's corrective action program, this violation is being treated as an]]
: [[NCV]] [[consistent with Section]]
: [[VI.A.]] [[1 of the]]
: [[NRC]] [[Enforcement Policy: (]]
: [[NCV]] [[05000286/2008005-01,]]
: [[34 CB]] [[Fan bearing failures caused by torque and lubrication deficiencies)  1R22 Surveillance Testing    a. Inspection Scope (71111.22 - 5 samples)  The inspectors witnessed performance of surveillance tests and/or reviewed test data of selected risk-significant structures, systems, and components, to assess whether test results satisfied Technical Specification,]]
UFSAR, Technical Requirements Manual, and Entergy procedure requirements. The inspectors verified that:  test acceptance criteria
were sufficiently clear; tests demonstrated operational readiness and were consistent with design basis documentation; test instrumentation had accurate calibrations and appropriate range and accuracy for the application; tests were performed as written; and applicable test prerequisites were satisfied. Following the tests, the inspectors verified that the equipment was capable of performing the required safety functions. The
documents reviewed during this inspection are listed in the Attachment. The following surveillance tests were reviewed and represented five inspection samples:  * 3-PT-Q092D, "34 Service Water Pump Train Operational Test," Rev. 11, on October 21, 2008; * 3-PT-Q120C, "33
: [[ABFP]] [[(Motor Driven) Surveillance and]]
: [[IST]] [[," Rev. 9, on October 31, 2008; * 3-PT-M062C, "480V Undervoltage /Degraded Grid Protection System Bus 6A Functional," Rev. 6, on October 9, 2008; * 3-PT-Q032, "RC-AOV-519, 552, 548, &]]
: [[549 IST]] [[," Rev. 20, on November 2, 2008; and * 3-]]
PT-M79C, "33 EDG Functional Test," Rev. 36, On November 3, 2008;    b. Findings  No findings of significance were identified. Cornerstone:  Emergency Preparedness
Enclosure  1EP2 Alert and Notification System Evaluation    a. Inspection Scope (71114.02)  The inspectors observed a full-volume siren test on October 22, 2008, to verify that
Entergy's newly-installed siren system functioned properly. The inspectors verified that the minimum required number of sirens functioned, when actuated. This inspection was conducted in accordance with the baseline inspection program deviation authorized by the
: [[NRC]] [[Executive Director of Operations (]]
EDO) in a memorandum dated October 31, 2005, and renewed by the EDO in a memorandum dated December 19, 2007. b. Findings  No findings of significance were identified.
1EP6 Drill Evaluation    a. Inspection Scope (71114.06 - 1 sample)  The inspectors observed an emergency preparedness drill conducted on October 29,
2008. The inspectors used NRC Inspection Procedure 71114.06, "Drill Evaluation," as guidance and criteria for evaluation of the drill. The inspectors observed the drill and various critiques that were conducted from participating facilities on-site, including the Indian Point Unit 3 plant-reference simulator and the technical support center. The inspectors focused the reviews on the identification of weaknesses and deficiencies in
various performance areas, which included on-site training objectives, such as:  command and control, communications and notifications, corrective actions, and accident assessment and protective actions. The inspectors observed Entergy's critique and compared the licensee's self-identified issues with the observations from the inspectors' review to ensure that performance issues were properly identified. The
observation of the drill represented one inspection program sample. b. Findings  No findings of significance were identified.
2. Radiation Safety  Cornerstone: Occupational Radiation Safety (OS)
2OS3 Radiation Monitoring Instrumentation and Protective Equipment
a. Inspection Scope (71121.03 - 9 samples)  During December 15 - 19, 2008, the inspectors conducted the following activities to evaluate the operability and accuracy of radiation monitoring instrumentation, and the adequacy of the respiratory protection program for issuing self-contained breathing
apparatus (SCBA) to emergency response personnel. Implementation of these programs was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and Entergy's procedures.
Enclosure 1) The inspectors reviewed the
: [[UFS]] [[]]
AR to identify area radiation monitors that are installed in Indian Point Units 2 and 3 for the protection of workers, reviewed calibration procedures and records for selected instrumentation, and discussed the system monitoring health reports and instrument reliability trends with the system engineer for the following instrumentation:  Unit 2 plant radiation monitors, main steam line radiation monitors (R-28, R-29, R-30, R-31), refuel
floor area radiation monitor (R-5), containment high-range radiation and noble gas monitors (R-25, R-26), gaseous and particulate containment radiation monitors (R-42, R-41), in-core area radiation monitor (R-7), steam generator blow down radiation monitor (R-49); Unit 3 plant radiation monitors, main steam line radiation monitors (R-62A, R-62B, R-62C, R-62D), refuel floor area radiation
monitor (R-5), containment high-range radiation and noble gas monitors (R-25, R-26), gaseous and particulate containment radiation monitors (R-12, R-11), in-core area radiation monitor (R-7), and steam generator blow down radiation monitor (R-19). 2) The inspectors evaluated radiation detection instruments used at Indian Point for job coverage and work in radiologically-significant areas, which included
continuous air monitors and whole body counters. The inspectors evaluated the following specific instruments: 49 electronic dosimeters, 13 radiation survey instruments, 12 extendable probe survey instruments, six neutron radiation survey instruments, six continuous air monitors, four portal monitors, seven beta and alpha counters, and two whole body counters. 3) The inspectors reviewed the current calibration records, applicable calibration procedures, as well as operability and alarm set-points for the instruments identified in Item 2) above. In addition, the inspectors verified that appropriate instrument calibration geometries and National Institute for Science and
Technology (NIST) standard traceability were utilized for the applicable calibrators. These calibrators included Shepherd 81-12B beam source calibrators, the Shepherd 142-10 panoramic calibrator, the Shepherd 149 neutron source calibrator, and the Shepherd 1000B box source calibrator. The inspectors verified that the calibration sources used by Entergy were
representative of the Unit 2 and Unit 3 source terms. 4) The inspectors reviewed radiological incidents that involved internal exposures identified by condition reports for 2008. In addition, electronic dosimetry records were queried to identify incidents for further review based on exposures that
exceeded 50 mRem committed effective dose equivalent (CEDE). None were identified for further review. 5) The inspectors reviewed condition reports (See Section
: [[4OA]] [[2), with respect to radiation protection program deficiencies to determine if the deficiencies were appropriately characterized and corrected commensurate with their safety significance. 6) Based on the condition reports reviewed (See Section 4]]
OA2), no repetitive deficiencies were identified by the inspectors for further follow-up. 7) With respect to the RP portable instruments listed in 3) above, the calibration expiration and response check stickers for the instruments were reviewed by the inspectors. The applicable response check beta-source and instrument sign-out
Enclosure procedures were also reviewed. The inspectors queried radiation protection technicians regarding appropriate instrument selection and performed field observations to ensure that self-verifications of instrument operability were being performed prior to use. 8) A sample of Emergency Plan-required self-contained breathing apparatus (SCBA) equipment and qualified users were reviewed by the inspectors based on Indian Point Energy Center Emergency Plan documents. This review included inspection of selected
: [[SCBA]] [[s and air bottle cascade systems located inside or adjacent to both the Unit 2 and Unit 3 central control rooms.]]
SCBA qualification records for select, on-shift reactor operators were verified for currency. The
inspectors also verified that air used to fill the
: [[SCBA]] [[s met the Grade D quality criteria of the Compressed Gas Association. The inspectors queried on-shift reactor operators to determine the storage location of required spectacles. 9) The inspectors reviewed periodic air cylinder hydrostatic testing and maintenance records for selected]]
SCBA units, which included a review of approved replacement parts documentation and certification of repair personnel. b. Findings  No findings of significance were identified. 4. Other Activities (OA)  4OA1 Performance Indicator Verification    a. Inspection Scope (71151 - 3 samples)  The inspectors reviewed performance indicator data for the cornerstones listed below and used Nuclear Energy Institute 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, to verify individual performance indicator accuracy and completeness. The documents reviewed during this inspection are listed in the
Attachment. Barrier Integrity  * Reactor Coolant System Leakage  Occupational radiation Safety Cornerstone  * Occupational Exposure Control Effectiveness  Public Radiation Safety Cornerstone  *
: [[RETS]] [[/]]
ODCM Radiological Effluent Occurrences  The inspectors also reviewed specific data and plant records for the unique inspections listed above, which included:  performance indicator data summary reports, operator narrative logs, the corrective action program, radiological-controlled area dosimeter exit
Enclosure logs, effluent release reports, monthly/quarterly projected dose assessment results for liquid and gaseous releases, and dose assessment procedures. b. Findings  No findings of significance were identified.
: [[4OA]] [[2 Identification and Resolution of Problems  .1 Routine Problem Identification and Resolution (]]
PI&R) Program Review
a. Inspection Scope  As required by Inspection Procedure 71152, "Identification and Resolution of Problems," and to identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of all items entered into Entergy's corrective action program. The review was accomplished by accessing Entergy's computerized database for condition reports, and attending condition report screening
meetings. In accordance with the baseline inspection procedures, the inspectors selected corrective action program items across the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for further follow-up and review. The inspectors assessed
Entergy's threshold for problem identification, the adequacy of the cause analysis, extent of condition reviews, operability determinations, and the timeliness of the associated corrective actions. The condition reports reviewed during this inspection are listed in the Attachment.
b. Findings  No findings of significance were identified.  .2 Substantive Cross-Cutting Issue Review:  Human Performance - Procedure Adequacy (71152 - 1 sample)    a. Inspection Scope  The inspectors reviewed Entergy's actions to address the Substantive Cross-Cutting
Issue (SCCI) in Human Performance related to procedure adequacy. The inspectors' review focused on Entergy's progress in addressing the
: [[SC]] [[]]
CI since their implementation of a revised action plan in May 2008. The inspectors evaluated Entergy's performance improvement plans and actions using inspection guidance in Inspection Procedure 71152, "Identification and Resolution of Problems."  Specifically, the inspectors assessed Entergy's progress in resolving the cross-cutting issue by evaluating whether Entergy's internal milestones were being monitored and consistently met and whether
adjustments in approach were made when necessary. This inspection focused on the progress made since the
: [[PI&R]] [[sample inspection conducted in October 2008 (]]
NRC Inspection Report 05000247/2008013 and 05000286/2008011). The inspectors conducted a review of the applicable condition reports (CRs), corrective
action assignments, focused self-assessments, Quality Assurance group assessments, and causal evaluations for the substantive cross-cutting issue. The inspectors also
Enclosure reviewed Entergy's performance indicators related to their performance improvement plan; reviewed a sample of revised procedures; conducted a series of interviews with station management, procedure writers and reviewers, maintenance technicians, and operators in order to assess the adequacy of the performance plan and effectiveness of corrective actions. b. Findings and Observations  No findings of significance were identified. The inspectors determined that Entergy continued to make progress in effectively
implementing their corrective action plans that address the substantive cross-cutting issue in Human Performance related to procedure adequacy.        The inspectors concluded that Entergy's corrective action plans were reasonable in scope because they addressed procedures that contributed to the substantive cross-cutting issue. Entergy's corrective action plans included Operations, Electrical and Mechanical Maintenance, and I&C Maintenance procedures. The procedure upgrade
project portion of Entergy's corrective action plans focused on risk significant components and actions in operating procedures. The inspectors determined the procedure upgrade project scope appropriately included operating procedures related to initiating events, single point vulnerabilities, and integrated plant operating procedures. The inspectors observed that station training was developed and provided for the
individuals involved in the procedure upgrade project and their management. The inspectors also observed that procedure reviews were being conducted for Security, Chemistry, Radiation Protection, and Engineering procedures to improve the quality of procedures in those areas.
The inspectors confirmed previous NRC observations, through interviews with Entergy staff, that the station has shifted the ownership of this project from the support organizations to the line organization. Entergy personnel indicated this organizational alignment has been a significant factor in the increased acceptance and participation from plant workers, and produced a noticeable improvement in revised procedure
quality. The inspectors observed that several personnel interviewed commented that the human performance training simulator is an effective tool, and assisted procedure writers with the identification of human performance error traps in existing procedures. The inspectors concluded that the realignment of the procedure upgrade project resulted in enhanced project accountability and quality output.      With respect to the progress of the procedure upgrade project, Entergy completed Phase I of the project ahead of their internal schedule and started Phase
: [[II.]] [[Phase I consisted of operations procedures associated with the top three risk significant systems for Units 2 and 3. Phase]]
II of the procedure upgrade project included the remaining top 10 plant risk significant systems, integrated plant operating procedures, procedures which involved single point vulnerabilities and initiating events. Current Entergy plans
and progress indicate that the Phase
: [[II]] [[portion of the procedure upgrade project will be completed by June 2009, several months ahead of the corrective action plan schedule. The inspectors reviewed a sample of the revised Phase I and Phase]]
II procedures and determined that significant revisions were made and the results met the quality and procedure standards described in Entergy's action plan. 


Enclosure The inspectors also observed that the Electrical and Mechanical Maintenance procedure upgrade project and the I&C Maintenance procedure development project made progress that was consistent with internal action plan schedules and milestones. The inspectors determined that the projects continue to receive the appropriate level of resources and management review and support to ensure completion of these projects.
==Section 4OA1: Performance Indicator Verification==
The inspectors determined that human error awareness and prevention actions were being implemented by Entergy to address the human performance aspects that contributed to the substantive cross-cutting issue in procedure adequacy. The inspectors determined that implementation of training, specifically the human performance training simulator, was appropriate to reinforce human error prevention
techniques being applied in the plant. The inspectors concluded Entergy developed appropriate monitoring measures and performance indicators to assess corrective action effectiveness. The inspectors observed that Entergy utilized these tools to provide initial feedback on corrective action implementation. For example, the inspectors determined that the performance indicators, related to procedure completion status and procedure feedback process
backlog, were an effective tool for monitoring station progress in these areas. Additionally, the inspectors concluded that self-assessments were an effective tool for corrective action adjustments and for evaluation of internal and external stakeholder recommendations. Entergy has adjusted the corrective action plan and procedure upgrade project scope to adequately incorporate stakeholder recommendations.  .3 Occupational Radiation Safety Cornerstone    a. Inspection Scope  The inspector reviewed condition reports initiated between November 2007 and December 2008, relative to the radiation protection program. The inspectors verified that problems identified by these condition reports were properly characterized by Entergy, and that applicable causes and corrective actions were identified commensurate with the safety significance of the occurrences. b. Findings and Observations  No findings of significance were identified. 
.4 Operator Workarounds Review (71152 - 1 sample)    a. Inspection Scope  The inspectors conducted a review of the aggregate impact of operator workarounds on the ability of operators to implement abnormal and emergency operating procedures (AOPs/EOPs), and to ensure that mitigating systems that are impacted remain capable
of performing the associated safety functions. This review included operator burdens, as well as control room alarms and deficiencies. The inspectors reviewed the prioritization, assessment, and ownership of the aggregate impact that is accomplished through the site's Unit Reliability Team, and the implementation and assessment of the Operations Aggregate Indicator, which is described in
: [[EN]] [[-]]
OP-115, "Conduct of Operations," Rev. 6.
The inspectors conducted control board walk downs, and discussed various deficiencies with operators to determine the overall impact the deficiencies would have on operator
Enclosure response to plant events, which included compensatory actions that resulted from the applicable deficiency. Additionally, the inspectors reviewed site performance indicators and associated inputs to determined if deficiencies were appropriately classified in accordance with site guidelines. b. Findings and Observations  No findings of significance were identified. The inspectors reviewed various deficiencies that input into Entergy's Operations Aggregate Index, and verified that these deficiencies were appropriately classified as
operator work-arounds, control room deficiencies and alarms. In addition, the inspectors verified that that the aggregate impact of the deficiencies did not significantly impact the ability of operators to respond appropriately during plant events while implementing applicable
: [[EOP]] [[s and]]
AOPs. The inspectors also verified that the Unit Reliability Team was appropriately addressing the prioritization of deficiencies to ensure timely corrective actions were being implemented commensurate with applicable safety significance. 
.5 Semi-Annual Trend Review (71152 - 1 sample)    a. Inspection Scope  The inspectors performed a semi-annual review to identify trends that might indicate the
existence of a more significant safety issue. The inspectors included in this review, repetitive or closely-related issues that may have been documented by Entergy outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed Entergy's corrective action
program database for the third and fourth quarters of 2008 to assess condition reports (CRs) written in various subject areas. The inspectors reviewed Entergy's quarterly trend reports from the corrective action, engineering, and maintenance departments for the second and third quarters of 2008 to ensure Entergy was appropriately evaluating and trending adverse conditions.
The inspectors focused on an emerging trend identified by Entergy from recent events in that human performance was determined to be either a direct or contributing cause. This trend was selected, in part, to evaluate Entergy's actions in response to the increased number of NRC inspection findings with associated human performance
cross-cutting aspects in 2008. The
: [[CR]] [[s listed below identified plant events that had related human performance aspects. The inspectors reviewed the]]
: [[CR]] [[s, causal evaluations, Entergy's Human Performance Program, business plans, and interviewed cognizant station personnel to assess whether Entergy identified the adverse trend and developed appropriate measures to address the conditions.  *]]
: [[IP]] [[3-2008-00818: Loss of bus 5A while performing monthly surveillance test; *]]
: [[IP]] [[3-2008-01589: Elevated cylinder exhaust temperatures identified on]]
: [[32 EDG]] [[while performing monthly surveillance; *]]
: [[IP]] [[3-2008-01863: Inadvertent initiation of auxiliary feedwater pumps during monthly surveillance on]]
: [[RPS]] [[; and *]]
IP3-2008-02518: Loss of bus 6A while performing monthly surveillance test.
Enclosure  b. Assessment and Observations  No findings of significance were identified. Several events that occurred at Indian Point in 2008, which resulted in both personal injury and equipment failures, were identified by Entergy to be attributable to human
performance errors. Entergy recognized the adverse trend in human performance, and developed a Human Performance Program to address the causes of the events, and to assist in the prevention or mitigation of future occurrences. The inspectors observed that the Human Performance Program includes actions to address the causes of human performance errors, reduce human performance errors, and monitor performance to
verify their actions are effective. Entergy reviewed the identified human performance errors to determine if a common cause existed, which was documented in
: [[CR]] [[-]]
IP2-2008-03671. Entergy determined that the human performance errors shared various contributing causes including application of human performance tools, identification of error-likely situations, work planning and execution, and application of resources. Entergy developed communication tools, training plans, and adjusted the site business plan to address the causal factors associated with human performance errors. Entergy implemented new communication tools including Safety and Human Performance Stand Downs and periodic human performance bulletins. The Safety and Human Performance
Stand Downs were used to develop a forum to reinforce site human performance expectations and discuss current human performance error events. Entergy also scheduled future stand downs to coincide with major evolutions on site in 2009, such as the Unit 3 refueling outage. Entergy developed a Human Performance Simulator and Work Management Academy to provide training on human performance traps, human performance tools, and to improve work planning and execution. The Human Performance Simulator focuses on reinforcing the proper threshold for error trap identification and the effective use of human performance tools to accomplish tasks. Operations and maintenance
departments completed this training, and it is included as annual refresher training for their department personnel. The Work Management Academy was required for all supervisory personnel and reinforced Entergy's work management model and procedures. Entergy also developed its Thought Improvement Process (TIP) Initiative to encourage employees to provide constructive feedback to improve the site's human
performance. The inspectors noted that Entergy has established measures to monitor human performance at Indian Point. In particular, human performance indicators and self-assessment results are used to monitor the effectiveness of the current programs and for evaluation of future trends in human performance. The next focused human performance self-assessment report is due July 10, 2009. The inspectors concluded that Entergy took timely and appropriately comprehensive action to address the site's emerging adverse human performance trend. The inspectors determined the programs established within Entergy's Human Performance program were reasonable to address the recent human performance errors and
emerging adverse trend in human performance.
Enclosure
: [[4OA]] [[3 Event Followup  .1 (Closed)]]
: [[LER]] [[05000286/2008-001-00, Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for an Inoperable Safety Injection Pump Caused by a Failed Motor Supply Breaker. On January 27, 2008, during an attempt to start the 31 Safety Injection Pump (SIP), the]]
: [[31 SIP]] [[failed to start. Entergy staff investigated the failure to start and determined that the power supply breaker for the pump motor failed to close. Technical Specification (]]
TS) 3.5.2, Emergency Core Cooling Systems (ECCS), Condition A was entered for one or more trains inoperable. Entergy's review of past operation of the 31 SIP determined
that the pump was last operable on January 11, 2008.
: [[TS]] [[3.5.2 requires three trains of]]
: [[ECCS]] [[to be operable. The required action]]
: [[A.]] [[1 for]]
TS 3.5.2, Condition A, is to restore the train(s) to operable within a completion time of 72 hours. The inoperable condition based on past operation exceeded the 72 hour allowed completion time for TS 3.5.2 with the required action not completed. Entergy determined the cause of the breaker problem was due to the breaker closing springs not charging. The closing springs did not charge properly due to a dislodged charging motor brush assembly because a
retaining screw became loose. Entergy's corrective actions included replacement of the breaker spring charging motor and subsequent breaker testing, and the breaker was returned to service on January 27, 2008. Entergy also revised the breaker maintenance procedure to require inspection of the breaker motor retaining screw.
The inspectors reviewed the
: [[LER]] [[and Entergy's evaluation of the event and associated corrective actions contained in]]
CR-IP-2008-00252. The inspectors determined that the problem with the 31 SIP breaker, specific to the closing springs, was not within Entergy's ability to foresee and correct based on review of the breaker's maintenance and operational history, equipment configuration, and available operating experience information. Specifically, the inspectors determined that Entergy's maintenance performed on this breaker was appropriate and up to date consistent with station and vendor instructions. The inspectors determined that, based on review on the operational history of the breaker, there was not information that indicated a potential reliability challenge related to the closing spring. The inspectors also determined that operating
experience information available to Entergy did not identify the potential for the closing spring problem that was evidenced for this type of breaker. Further, the inspectors concluded that, due to the installed location of the charging motor brush assembly, Entergy's routine processes and procedures would not have identified or reasonably detected the failure. Therefore, the inspectors determined this equipment failure could
not have been avoided or detected by Entergy's quality assurance program or other related control measures and did not constitute a performance deficiency. Additionally, based on the assumption that the
: [[31 SIP]] [[was inoperable for 16 days, the inspectors performed a Phase 2]]
SDP analysis that resulted in the risk significance of this issue as being of very low safety significance (Green). The inspectors determined that the 31 SIP being inoperable for greater than 72 hours
was a violation of Entergy's Technical Specification 3.5.2, Emergency Core Cooling System (ECCS), Condition A, which requires an inoperable train of safety injection to be restored to operable status within 72 hours. However, because there was no performance deficiency identified and the risk significance is of very low safety significance, the NRC has chosen to exercise enforcement discretion and refrain from
issuing enforcement action for this violation of
: [[NRC]] [[requirements in accordance with Section]]
VII.B.6 of the NRC's Enforcement Policy. Further, because Entergy's actions
Enclosure did not contribute to this violation, it will not be considered in the assessment process or
: [[NRC]] [['s action matrix. This]]
: [[LER]] [[is closed.  .2 (Closed)]]
: [[LER]] [[05000286/2008-004-00, Automatic Actuation of the Motor Driven Auxiliary Pumps During Surveillance Testing Caused by Incorrect Test Jumper Connection Due to Personnel Error. On August 4, 2008, during performance of the monthly Reactor Protection Logic Channel Functional Test 3-]]
: [[PT]] [[-M13B1, Instrumentation & Control (I&C) technicians were testing the Low-Low Steam Generator Water Level circuit, a required, wire "jumper" installed between terminal points became dislodged. During subsequent testing activities, which included re-installation of the dislodged jumper, control room operators notified the technicians of an automatic start of the motor-driven auxiliary feedwater pumps. The technicians stopped, removed the jumpers, and troubleshooting was performed. The auxiliary feedwater pumps were subsequently restored to their original configuration, and the test was subsequently performed satisfactorily. The inspectors reviewed the]]
: [[LER]] [[to verify its accuracy based on the]]
NRC's assessment
of the event, and reviewed Entergy's evaluation of the event contained in the causal report and associated corrective actions contained in
: [[CR]] [[-]]
: [[IP]] [[3-2008-01863. Because the personnel performance aspects that contributed to this event were previously evaluated and dispositioned as a Green, non-cited violation in]]
: [[NRC]] [[inspection report 50-286/2008-004, no further findings of significance or violation of]]
NRC requirements were identified.
This
: [[LER]] [[is closed.  .3 (Closed)]]
LER 05000286/2008-005-00, Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for an Inoperable Isolation Valve Seal Water System Due to an Out of Position Valve Caused by Personnel Error  On September 1, 2008, during implementation of various valve lineups at Unit 3, Entergy personnel identified an isolation valve seal water (IVSW) system valve, IV-1692, out of its required open position, e.g., it was found in the closed position. Entergy determined that the valve was out of its normally-open position since May 2007, for approximately
months, due to personnel error in the removal of a temporary modification and failure to ensure full restoration of valve
: [[IV]] [[-1692. As a result, one header of the]]
IVSW system was inoperable greater than the seven days allowed by technical specification (TS) 3.6.9.
Entergy restored IV-1692 to its normally-open position, performed an apparent cause evaluation, briefed maintenance personnel, which included supervisors, regarding human performance tools to minimize personnel error, and instituted a dynamic human performance simulator to reinforce aspects of performance such as, proper use of error reduction tools and procedure compliance. The inspectors determined this issue was more than minor because it impacted the Barrier Integrity cornerstone, and impacted its ability to limit fission product releases from containment during a design basis loss of
coolant accident. The issue was determined to be of very low safety significance (Green) in accordance with the
: [[SDP]] [[Phase 1 worksheet because it did not represent an actual open pathway in the physical integrity of the reactor containment. In addition, although Entergy credits the operable]]
IVSW system to calculate and ensure compliance with NRC containment leakage requirements, the system is not credited in the
calculation of offsite doses following the design basis loss of coolant accident. The
Enclosure enforcement aspects of this licensee-identified finding are discussed in Section
: [[4OA]] [[7. This]]
LER is closed.  .4 Loss of 480 Volt Emergency Safety Bus 6A During Surveillance Testing on October 9, 2008
a. Inspection Scope  The inspectors evaluated the response of control room personnel following the unexpected loss of 480 Volt safeguards bus 6A that occurred during the performance of a degraded grid/undervoltage relay surveillance test on October 9, 2008. The inspectors
reviewed plant computer data, evaluated plant parameter traces, and discussed the event with plant personnel, to verify that plant equipment responded as expected, and to ensure that operating procedures were appropriately implemented. The inspectors verified that Entergy's short term corrective actions were appropriate in response to the event. This event was entered into Entergy's corrective action program as
: [[CR]] [[]]
IP3-2008-02519. Corrective actions included the initiation of a root cause evaluation, and the determination that the test meter utilized during the surveillance would need to be
evaluated for potential deficiencies that may have contributed to the event. b. Findings  No findings of significance were identified.
: [[4OA]] [[5 Other Activities  .1]]
TI 2515/173, Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative    a. Inspection Scope  During the week of August 11, 2008, the NRC assessed Entergy's implementation of the Nuclear Energy Institute - Voluntary Ground Water Protection Initiative (dated August
2007, ML072610036). Entergy evaluated work practices that could lead to leaks and spills, and performed an evaluation of systems, structures, and components that contain licensed radioactive material to determine potential leak or spill mechanisms. Entergy completed a site characterization of geology and hydrology to determine the
predominant ground water gradients and potential pathways for ground water migration from on-site locations to off-site locations. An on-site ground water monitoring program has been implemented to monitor for potential licensed radioactive leakage into groundwater. The ground water monitoring results are reported in the annual effluent and/or environmental monitoring report. (See link below)  (http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html)  Entergy prepared procedures for the decision making process for potential remediation of leaks and spills, including consideration of the long term decommissioning impacts. Records of leaks and spills are recorded in Entergy's decommissioning files in accordance with 10 CFR 50.75(g).


Enclosure Entergy identified the appropriate local and state officials and has conducted briefings on the licensee's ground water protection initiative. Entergy established protocols for notification to local and state officials regarding detection of leaks and spills. b. Findings  No findings of significance were identified.  .2 Ground-Water Contamination Review    a. Inspection Scope  The inspectors reviewed plans, procedures, and remediation activities affecting the contaminated ground water condition at Indian Point, relative to
===Procedures===
: [[NRC]] [[regulatory requirements, as authorized by the]]
: EN-EP-201, "Performance Indicators," Rev. 6
NRC Executive Director of Operations in a Reactor Oversight Process deviation memorandum dated December 19, 2007 [ADAMS Ref. No. ML073480290]. Entergy's performance was assessed, relative to remediation of the principal source of groundwater contamination including observation of the draining and
: EN-LI-114, "Performance Indicator Process," Rev. 3
sludge removal of the Unit 1 spent fuel pools; the radioactive waste processing of the fuel pool water and residual sludge materials; and review of the radioactive liquid effluent release accounting and dose calculations resulting from these activities. The inspection included onsite inspections on September 18, 2008; October 10, 2008; October 14-15, 2008; and November 17-18, 2008.
: NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Rev. 5 
b. Findings and Observations  No findings of significance were identified. Following the removal of Unit 1 spent fuel to dry cask storage, Entergy established special radioactive liquid processing and sampling equipment for conducting the drain down of the Unit 1 spent fuel pools. Between September 15, 2008 and November 7, 2008, approximately 500,000 gallons of water were drained and processed which included pool surface rinse water used during sludge removal activities. The liquid
: Attachment
processing equipment was designed to clarify the pool water prior to discharge into the Hudson River. The liquid processing system consisted of a series of sequential processing modules which included a filter cartridge, a 25 ft³ mixed (cation and anion) demineralizer resin vessel followed by five 12.5 ft³ supplemental water polishing units consisting of an activated charcoal vessel, a cation demineralizer resin vessel, a mixed
demineralizer resin vessel, a cesium-specific filter media vessel, and finally another activated charcoal vessel. The filtered and demineralized water was sampled by an automatic composite sampler for monitoring and analysis prior to the effluent stream release into the discharge canal. Residual sludge from the bottom of the spent fuel pools was mixed with water and sluiced into a 120 ft3 polyethylene disposal container. Liquids were removed from this solid waste container by periodically pumping down the container through the self-contained PVC dewatering system contained in the disposal
container. These liquid wastes were subsequently processed through the same liquid processing system as described above, however, due to the potentially higher radioactive contaminants, the final processed water was redirected to a Unit 1 waste collection tank to allow for additional waste water treatment prior to discharge. The 120 ft3 disposal container of solid waste was classified as Class B waste and will be stored onsite until an offsite disposal facility becomes available.
Enclosure The inspectors determined the treated and discharged water was sampled and properly accounted by Entergy to result in less than 1 Curie of radioactivity discharged consisting mostly of tritium, and small amounts of Kr-85 and Cs-137. The resulting public dose associated from this liquid discharge activity was 0.00007 mRem to the whole body and 0.00012 mRem to the highest organ (teen/liver). The inspectors verified these values represent small fractions of the liquid discharge limits of 3 mRem/yr whole body and 10
mRem/yr maximum organ dose limits specified in 10 CFR 50, Appendix I.  .3 Quarterly Resident Inspector Observations of Security Personnel and Activities    a. Inspection Scope  During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that these activities were consistent with Entergy security procedures and applicable regulatory requirements. Although these observations did not constitute additional inspection samples, they were considered an integral part of the normal, resident inspector plant status reviews during implementation of the baseline inspection program. b. Findings  No findings of significance were identified. 
.4 Implementation of Temporary Instruction (TI) 2515/176 - Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing    a. Inspection Scope  The objective of
: [[TI]] [[2515/176, "Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing," was to gather information and assess the adequacy of nuclear power plant emergency diesel generator (]]
EDG) endurance and margin testing as prescribed in plant-specific technical
specifications (TS). The inspectors reviewed the Unit 3 emergency diesel generator ratings, design basis event load calculations, surveillance testing requirements, emergency diesel generator vendor's specifications, and other information in accordance with TI 2515/176.
The inspectors' assessment, and other pertinent information gathered during the implementation of this TI was discussed with Entergy personnel. In addition, this information was forwarded to the Office of Nuclear Reactor Regulation for further review and evaluation.      b. Findings  No findings of significance were identified.   


Enclosure 4OA6 Meetings, including Exit  Exit Meeting Summary  On January 8, 2009, the inspectors presented the inspection results to Joe Pollock and other Energy staff members, who acknowledged the inspection results. Entergy did not
==Section 4OA2: Identification and Resolution of Problems==
identify any material as proprietary.
: [[4OA]] [[7 Licensee-Identified Violations  The following violation of very low safety significance (Green) was identified by Entergy 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 an]]
: [[NCV.]] [[*]]
: [[TS]] [[3.6.9 requires that an inoperable isolation valve seal water (]]
: [[IVSW]] [[) system header be restored to operable status within seven days. Contrary to this requirement, Entergy did not identify that an]]
: [[IV]] [[]]
SW system valve, which provides seal water to maintain the leak-tight integrity of containment isolation valves, was out of its normally-open position for approximately 17 months beginning May
2007. The out-of-position
: [[IVSW]] [[valve was identified and corrected by Entergy on September 1, 2008. The issue was entered into Entergy's corrective action program as condition report]]
: [[CR]] [[]]
: [[IP]] [[3-2008-02095. The issue was determined to be of very low safety significance (Green) in accordance with the]]
SDP Phase 1 worksheet because it did not represent an actual open pathway in the physical
integrity of the reactor containment, and the system is not credited in the determination of post-accident radiation dose to the general public.
: [[ATTACH]] [[]]
: [[MENT]] [[:]]
: [[SUPPLE]] [[]]
: [[MENTAL]] [[]]
: [[INFORM]] [[]]
: [[ATION]] [[Attachment]]
: [[SUPPLE]] [[]]
: [[MENTAL]] [[]]
: [[INFORM]] [[]]
: [[ATION]] [[]]
: [[KEY]] [[]]
: [[POINTS]] [[]]
: [[OF]] [[]]
CONTACT  Entergy Personnel
J. Pollock, Site Vice President A. Vitale, General Manager, Plant Operations P. Conroy, Director, Nuclear Safety Assurance D. Gagnon, Manager, Security R. Walpole, Manager, Licensing
B. Beckman, Manager, Maintenance R. Christman, Manager, Training J. Dinelli, Assistant Operations Manager, Unit 3 V. Myers, Supervisor, Mechanical Design Engineering  A. Singer, Superintendent, Operations Training T. Orlando, Engineering Director C. English, Superintendent, Unit 1
B. Sullivan, Manager - Emergency Preparedness, Indian Point R. Burroni, Manager Programs, Components and Engineering D. Loope, Manager, Radiation Protection S. Verrochi, Manager System Engineering F. Inzirillo, Manager, Quality Assurance
: [[N.]] [[Azevedo, Supervisor, Code Programs T. Morzello, Maintenance Supervisor S. Prussman, Licensing Engineer G. Dahl, Licensing Engineer H. Anderson, Licensing Engineer]]
: [[S.]] [[Bianco, Fire Instructor S. Sandike, Effluent & Environmental Monitoring Specialist G. Hocking, Radiation Protection Support Supervisor B. Taggart,]]
ECP Coordinator T. Stephens, Energy Solutions
R. Turner, Energy Solutions
Attachment
: [[LIST]] [[]]
: [[OF]] [[]]
: [[ITEMS]] [[]]
: [[OPENED]] [[,]]
: [[CLOSED]] [[]]
: [[AND]] [[]]
: [[DISCUS]] [[]]
: [[SED]] [[Opened and Closed  05000286/2008005-01]]
: [[NCV]] [[34]]
CB Fan bearing failures caused by torque and
lubrication deficiencies. Closed  05000286/2008001-00
: [[LER]] [[Technical Specification Prohibited Condition Due to      Exceeding the Allowed Completion Time for an        Inoperable Safety Injection Pump Caused by a        Failed Motor Supply Breaker. 05000286/2008004-00]]
LER  Automatic Actuation of the Motor Driven Auxiliary        Pumps During Surveillance Testing Caused by        Incorrect Test Jumper Connection Due to
Personnel Error. 05000286/2008005-00 LER  Technical Specification Prohibited Condition Due to      Exceeding the Allowed Completion Time for an        Inoperable Isolation Valve Seal Water System Due
to an Out of Position Valve Caused by Personnel        Error.
Attachment
: [[LIST]] [[]]
: [[OF]] [[]]
: [[DOCUME]] [[]]
: [[NTS]] [[]]
: [[REVIEW]] [[]]
: [[ED]] [[Section 1R01:  Adverse Weather Protection  Procedures]]
: [[OAP]] [[-008, "Severe Weather," Rev. 5]]
OAP-048, "Seasonal Weather Preparation," Rev. 4
Section 1R04:  Equipment Alignment  Procedures 3-COL-CS-001, " Containment Spray System," Rev.14 3-PT-M096, "Containment Spray System Monthly Alignment Verification," Rev. 5 3-COL-CSV-001, "Containment Spray Verification," Rev. 6 3-COL-EL-005, "Diesel Generators," Revision 32 3-COL-CVCS-1, "Chemical and Volume Control System," Rev. 26 3-COL-RW-3, "Intake Structure," Rev. 12
3-COL-RW-2, "Service Water System," Rev. 42  Work Order 51677514 51420795 51349291
Other Flow Diagram 9321-F-27503, "Safety Injection System, Sheet 2," Rev. 48 Condition Report
: [[CR]] [[-]]
: [[IP]] [[3-2008-02944]]
: [[PID]] [[61513]]
PID 09177


Section 1R05: Fire Protection
===Procedures===
Procedures
: EN-LI-102, Corrective Action Process
: [[ENN]] [[-]]
: EN-LI-119, Apparent Cause Evaluation (ACE) Process
: [[DC]] [[-161, "Transient Combustible Program," Rev. 11]]
: SOP-27.3.1.1, 21 Emergency Diesel Generator Manual Operation
: [[EN]] [[-]]
: ICPM-0708-1, 13.8 KV L&P bus section 3 partial differential relays (87B2-A/B/C)
: [[DC]] [[-189, "Fire Drills," Rev. 1, and Fire Brigade Drill Report dated December 9,]]
: 3-REF-003-Gen, Reactor Core Refueling
: [[2008 SMM]] [[-]]
: SOV-003-ELC, Inspection and Testing of Target Rock Solenoid Operated Valves
: [[DC]] [[-901, "IPEC Fire Protection Program," Rev. 2 Pre-Fire Plan]]
: EN-LI-122, Common Cause Evaluation
: [[352AB]] [[, 354, 354A, 355, 356, 357, and 358 Condition Reports (]]
: EN-LI-119, Apparent Cause Evaluation (ACE) Process
: [[CR]] [[-IP3-) 2008-03060  Section 1R06: Flood Protection Measures]]
: EN-LI-102, Corrective Action Process
: [[IP]] [[-]]
: EN-OP-117, Operations Assessments
: [[CALC]] [[-08-00031, "Misc. Structural Evaluation for]]
: 3-SOP-NI-001, Excore Nuclear Instrumentation System Operation 2-SOP-ESP-001, Local Equipment Operation and Contingency Actions 3-PT-M079C, 33 EDG Functional Test 2-E-0, "Reactor Trip or Safety Injection," Rev. 0
: [[IP]] [[2 &]]
: EN-DC-185, Through-Wall Leaks in ASME Section XI Class 3 Moderate Energy Piping  
: [[IP]] [[3]]
===Condition Reports===
: [[RHR]] [[Pump Motor Flood Protection," Rev. 0]]
: IP2-2008-03144
: [[IP]] [[-CALC-08-00061, "Sizing Calculation for RHR Pump Flooding Line," Rev. 0]]
: IP2-2008-03869
: [[EC]] [[-5000041988, "Mod to Protect]]
: IP2-2008-03901
: [[RHR]] [[Pump Motors From Internal Flooding."]]
: IP2-2008-04246
: [[EC]] [[-5000034211, "Design Permanent Solution to Protect]]
: IP2-2008-03869
RHR Pump Motors From Internal Flooding." 3-AOP-FLOOD-1, "Flooding," Rev. 4  Section 1R07: Heat Sink Performance
: IP2-2008-04425
Attachment 0-GNR-406-ELC, "Emergency Diesel Generator 6-Year Inspection," Rev.1 0-HTX-405-EDG, "EDG Lube Oil and Jacket Water Heat Exchanger Maintenance," Rev.
: IP2-2008-04576
: [[0 CR]] [[-]]
: IP2-2008-04893
IP3-2008-01870 WO 00144830  Section 1R11: Licensed Operator Requalification
: IP3-2008-02026
Procedures    I3SG-LOR-AOP006, "IPEC Simulator Guide - Loss of Feedwater
: IP3-2008-02758
: [[3AOP]] [[-]]
: IP2-2006-06939
FW-1," Rev. 3 I3SG-LOR-AOP003, "IPEC Simulator Guide - 3-AOP-UC-1 Uncontrolled Cooldown," Rev. 1 3-AOP-FW-1, "Loss of Feedwater," Rev. 6
: IP2-2007-00259
3-AOP-UC-1, "Uncontrolled Cooldown," Rev. 2
: IP2-2007-01599
: IP2-2007-03706
: IP3-2007-03619
: IP3-2007-00453
: IP2-2008-01056
: IP2-2008-03671
: IP2-2008-02907
: IP2-2008-02624
: IP2-2008-02725
: IP2-2008-03511
: IP2-2008-03956
: IP2-2008-04020
: IP2-2008-01057
: IP2-2008-03330
: IP2-2008-03309
: IP2-2008-03310
: IP2-2008-00389
: IP2-2008-00464
: IP3-2008-00640 IP3 2008-01285
: IP3-2008-01745
: IP3-2008-02137
: IP3-2008-03013 IP3LO-2008-00004 IP3LO-2008-00111 IP3LO-2008-00143 IP3LO-2008-00172 IP3LO-2008-00178 IP3LO-2008-00179 IP3LO-2008-00180
: HQN-2008-00339
: LO-WTIPC-2008-00043 
===Work Orders===
: 00145055
: 51320416
: 00174762
: 51247771
: 00170717 
===Miscellaneous===
: IPEC Engineering Department Quarterly Trend Report 2Q 2008
: IPEC Engineering Department Quarterly Trend Report 3Q 2008 IPEC Maintenance Department Quarterly Trend Report 2Q 2008 IPEC Maintenance Department Quarterly Trend Report 3Q 2008 IPEC Corrective Action and Assessment Department Quarterly Trend Report 3Q 2008 NRC
: IR 05000247/2008001 & 05000286/2008001 "Annual Assessment Letter - Indian Point Nuclear Generating Units 2 and 3" Dated March 3, 2008 NRC "Mid Cycle Performance Review and Inspection Plan - Indian Point Nuclear Generating Station Units 2 and 3" dated September 2, 2008. NRC Inspection Report 05000247/2008010 "Indian Point Nuclear Generating Station Unit 2- NRC Problem Identification and Resolution Inspection Report" dated July 24, 2008 10
: CFR 50.72 ,"Immediate Notification requirements for Operating Nuclear Power Reactors"
: Indian Point Energy Center Procedure Adequacy Cross-Cutting Issue Resolution Plan Rev 4 Dated September 9, 2008 
: Attachment Indian Point Energy Center Procedure Adequacy Cross-Cutting Issue Resolution Plan Revs 0-3 Maintenance Department Procedure Improvement Plan (No date) Human Performance Training Plan and slides "Doer, Reader, Peer Checker, and Pilot" exercise. Human Performance Training Plan and slides "Human Performance for IPEC Personnel" Operations Procedure Upgrade Project Communications plan for Operations personnel. Procedure Adequacy Cross-Cutting Resolution Plan Slideshow dated 10/20/08 
===Procedure===
: Adequacy Cross-Cutting Resolution Plan Slideshow update dated 12/5/08 Plant Operating Procedures (POP) Procedure Upgrade Project Plan dated 9/9/08 Plant Operating Procedures (POP) Procedure Upgrade Project Plan Rev 2 dated 10/26/08 Performance Indicators and worksheets for Procedure Workdown Curves, Procedure Feedback Forms, NRC Findings, Equipment Reliability, and Preventive Maintenance Completion.
: Indian Point Units 2 and 3 Summary of Findings/ Violations Report dated 12/1/08 Equipment Reliablility Index Performance Indicator Guidance Book Revision 4 and Data CAP Improvement Plan-IPEC Unit 2 Cross Cutting Issue PI&R slide show dated 12/1/08 Human Performance Cross Cutting Resolution Plan Presentation dated 12/2/08 IPEC Open CR Inventory Report run 12/1/08 IPEC CRG Summary Agenda Report for 12/2/08 IPEC CARB Meeting Agenda Report for 12/2/08
: ASME Code Case N-513-2, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1


Section 1R12: Maintenance Effectiveness  Condition Reports (CR-IP3-) 2008-02609  2008-02611  2007-03045  2008-00493 2008-02459  2008-00752  2008-01323  2008-01587
==Section 4OA3: Event Followup==
2008-01616  2008-02234  Maintenance Rule Monitoring Documents
: [[EN]] [[-]]
: [[DC]] [[-143, "System Health Reports," Rev.]]
: [[8 EN]] [[-]]
: [[DC]] [[-159, "System Monitoring Program," Rev. 2]]
: [[EN]] [[-]]
: [[DC]] [[-167, "Classification of Structures, Systems, and Components," Rev.]]
: [[2 EN]] [[-]]
: [[DC]] [[-203, "Maintenance Rule Program," Rev.]]
: [[1 EN]] [[-]]
: [[DC]] [[-204, "Maintenance Scope and Basis," Rev.]]
: [[1 EN]] [[-]]
: [[DC]] [[-205,]]
: [[AM]] [[aintenance Rule Monitoring," Rev. 2]]
: [[EN]] [[-DC-206,]]
: [[AM]] [[aintenance Rule (a)(1) Process,@ Rev. 1 Unit 3 Safety Injection System health report for 3rd Qtr 2008, Rev. 0 Unit 3 Main Steam System Basis Document and System Health Report]]
IPEC 138 kV System Monitoring Plan
Section 1R13:  Maintenance Risk Assessment and Emergent Work Control  Procedures
: [[IP]] [[-]]
SMM-WM-101, "On-Line Risk Assessment," Rev. 3 Work Week Managers Operator's Risk Report, Work Weeks 0840, 0844, 0846, and 0851  Section 1R15:  Operability Evaluations
Procedures
: [[EN]] [[-]]
: [[OP]] [[-104, "Operability Determinations," Rev. 3 Indian Point Unit 3 Updated Final Safety Analysis Report, Rev.]]
: [[2 PFM]] [[-97, "Station Battery Inter-Cell Resistance Check," Rev. 3 and 4 3-]]
: [[PT]] [[-Q028, "Containment Isolation Valves]]
: [[PCV]] [[-1190,]]
: [[PCV]] [[-1191, and]]
: [[PCV]] [[-1192 Pressure Relief System," Rev. 17 3-]]
PT-126, "Fan Cooler Unit Operational Test," Rev. 0  Condition Reports (CR-IP3-) 2008-02822  2008-03046  2008-03070  2008-03074
Attachment Other Documents
: [[WO]] [[51565142]]
: [[WO]] [[51462980]]
: [[WO]] [[]]
: [[IP]] [[3-05-20386 Calculation]]
: [[IP]] [[3-]]
CALC-SWS-02022, "Operability Determination and Supports Repairs in the Zurn Pit," Rev. 4  Section 1R18: Plant Modifications
Engineering Changes
: [[EC]] [[-0000012263, "Install a Full Enclosure Clamp Around]]
: [[MS]] [[-202 Valve."]]
: [[EC]] [[-0000011472, "Temporary Setpoint Change for Exciter Cold Gas Temperature."  Section 1R19:  Post-Maintenance Testing  Procedures]]
: [[EN]] [[-MA-101, "Conduct of Maintenance," Rev.]]
: [[6 EN]] [[-]]
: [[WM]] [[-102, "Work Implementation and Closeout," Rev.]]
: [[2 EN]] [[-]]
WM-105, "Planning," Rev. 4
0-LUB-401-GEN, "Lubrication of Plant Equipment," Rev. 6\ 3-PT-M079A, "31
: [[EDG]] [[Functional Test," Rev. 36 3-]]
FAN-003-VSS, "Fan Cooler Unit Fan Assembly Preventive Maintenance Inspection," Rev. 9 3-FAN-007-VSS, "Fan Cooler Unit Dampers Inspection/Maintenance," Rev. 9 0-GNR-408-ELC, "Emergency Diesel Generator 12-Year Inspection," Rev.2
Condition Reports (CR-IP3-) 2008-00748 2008-01701 2008-01716 2008-02004 2008-02224 2008-02226 2008-02227 2008-02345 2008-02704 2008-02787 2008-04535 2008-02509 2008-02899 2008-02508
Work Orders 00145321 51672225 00162780 51549514 00159387 51485400 51443345 51571719 51669491 51570943 51570944 51674410 00142088 51485482 145333-02 165446-02 51510555 51653265
51428106 145334-02 51669508 148244-11 51478467 51467052 145330-02 152561-04 51565847 145335-01 145336-01 169221-01/02 167680-01  Misc. Standing Order 05-01, "Lubrication Information and Equivalents"
: [[IPEC]] [[Maintenance Feedback Forms for 3-]]
BKR-004-ELC and 3-BKR-018-ELC
Section 1R22:  Surveillance Activities
Miscellaneous Documents Indian Point Unit 3 Updated Final Safety Analysis Report, Rev. 2
Technical Report
: [[IP]] [[3-]]
: [[RPT]] [[-RCS-01799, "Containment Isolation Valve Closure Time Including Phase "A" Valves," Rev.]]
: [[0 IP]] [[3 Design Basis Document]]
: [[DBD]] [[-316, "Containment Isolation System," Rev.]]
: [[3 IP]] [[3 Schematic Diagram 9321-]]
: [[LL]] [[-31183, "480V Switchgear 32, Sheet 18," Rev.]]
: [[10 IP]] [[3 Schematic Diagram 9321-]]
LL-31183, "480V Switchgear 32, Sheet 4," Rev. 21
IP3 Flow Diagram 9321-H-20293, "Starting Air to Diesel Generators," Rev. 27
Attachment  Condition Reports (CR-IP3-) 2003-06439 2008-02520 2008-02759 2008-03061  Work Orders 51672225 51673284


Section
===Condition Report===
: [[2OS]] [[3:  Access Control and]]
: IP2-2008-01482
: [[ALARA]] [[Procedures:]]
: IP2-2008-01537  
: [[EN]] [[-]]
===Work Orders===
: [[CY]] [[-108, Rev. 2, Monitoring of Non-Radioactive Systems]]
: 00145619
: [[EN]] [[-]]
: [[RP]] [[-113, Rev. 2, Response to Contaminated Spills / Leaks]]
: [[EN]] [[-]]
: [[RP]] [[-303, Rev. 2, Source Check Radiation Protection Instrumentation]]
: [[EN]] [[-]]
: [[RP]] [[-306, Rev. 2, Calibration and Operation of the Eberline]]
: [[PM]] [[-7]]
: [[EN]] [[-RP-309, Rev. 1, Operation and Calibration of the Eberline]]
: [[AMS]] [[-3 / 3A Continuous Air  Monitor]]
: [[EN]] [[-RP-501, Rev. 3, Respiratory Protection Program]]
: [[EN]] [[-]]
: [[RP]] [[-502, Rev. 4, Inspection and Maintenance of Respiratory Protection Equipment]]
: [[IP]] [[-]]
: [[EP]] [[-AD6-20, Rev. 2, Respiratory Protection Monthly Equipment Inventory]]
: [[IP]] [[-]]
: [[EP]] [[-AD6-21, Rev. 3, Respiratory Protection Quarterly Equipment Inventory]]
: [[IP]] [[-]]
: [[RP]] [[-IC-301, Rev. 1, Calibration of the Eberline]]
: [[AMS]] [[-4 Air Monitoring System Using Windows]]
: [[IP]] [[-SMM-CY-001, Rev. 6, Radioactive Effluents Control Program]]
: [[RE]] [[-]]
: [[ADM]] [[-1-22, Rev. 0, Site Soil Characterization]]
: [[RE]] [[-]]
: [[INS]] [[-7CC-1, Rev. 12, Calibration of the Eberline]]
: [[AMS]] [[-2 Beta-Gamma Air Monitor]]
: [[RE]] [[-INS-7CC-7/8, Eberline]]
: [[PING]] [[-1A Calibration Record]]
: [[RE]] [[-INS-7CH-3, Rev. 10, Calibration of the Merlin-Gerin]]
: [[CDM]] [[-21 Electronic Dosimeter  Calibrator Using]]
: [[WCDM]] [[]]
: [[2000 RE]] [[-]]
: [[INS]] [[-7CH-4, Rev. 5, Characterization of the J.L. Shepherd 81-12, 142-10 and 149 Sources]]
: [[RE]] [[-]]
: [[INS]] [[-7UH-12, Rev. 10, Beam Source Check Sheet 0-RP-IC-101, Rev. 2, Calibration of Portable Ion Chamber Survey Meters 0-RP-IC-102, Rev. 0, Calibration of the Eberline]]
: [[ASP]] [[-1 with Neutron Detector 0-]]
: [[RP]] [[-IC-301, Rev. 1, Calibration of the Eberline]]
: [[AMS]] [[-4 Air Monitoring System Using Windows 0-]]
RP-IC-402, Rev. 1, Calibration and use of the MGP Telepole
0-RP-IC-601, Rev. 0, Calibration of the Tennelec
: [[LB]] [[-5100 Alpha-Beta Counting System Using  Eclipse 0-]]
: [[RP]] [[-IC-603, Rev. 0, Interchangeable Counting Room Calibration with]]
: [[HP]] [[-300 0-]]
: [[RP]] [[-IC-604, Rev. 0, Calibration of the Eberline Model]]
: [[BC]] [[-4 Beta Counter  0-]]
CY-1420, Rev. 2, Radiological Quality Assurance Program
0-CY-1510, Rev. 4,
: [[IPEC]] [[Storm Drain Sampling 0-]]
: [[CY]] [[-1900, Rev. 0, Nuclear Environmental Monitoring Sampling and Analysis Schedule 0-CY-2740, Rev. 1, Liquid Radioactive Effluents 2-PC-R25, Rev. 15, Main Steam Line Radiation Monitor Detector Calibration (R-28, 29, 30, 31) 2-PC-R38-1, Rev. 3, High Range Containment Area Radiation Monitor (R-25) 2-PC-R38-2, Rev. 2, High Range Containment Area Radiation Monitor (R-25) 2-PC-R38-3, Rev. 3, High Range Containment Area Radiation Monitor (R-26) 2-PC-R38-4, Rev. 2, High Range Containment Area Radiation Monitor (R-26) 2-PC-R15B, Rev. 17,]]
: [[VC]] [[Area Radiation Monitor Calibration (R-7) 2-]]
PC-EM4, Rev. 12, Non-VC Area Radiation Monitors Calibration 2-PC-EM30, Rev. 10, Process Radiation Monitor Calibration (R-41, 42) 2-PC-2Y23, Rev. 10, Liquid Radiation Monitor Calibration 3-CY-2325, Rev. 6, Radioactive Sampling Schedule
Attachment 3-IC-RMP-R-7, Rev. 0, Calibration of Radiation Monitor R-7 3-PC-R40, Rev. 17, Main Steam Line Radiation Monitor Calibration (R-62) 3-PC-OL-48, Rev. 4, Fuel Storage Building Radiation Monitor Calibration (R-5) 3-PC-R46A, Rev. 15, Containment High Range Radiation Monitor Calibration (R-25) 3-PC-R46B, Rev. 14, Containment High Range Radiation Monitor Calibration (R-26) 3-PC-OL-58A, Rev. 2, Process Radiation monitors R11/12 Calibration
3-PC-OL-49A, Rev. 2, Steam Generator Blow down Radiation Monitor Calibration (R-19)  Condition Reports (CR):
: [[IP]] [[2-2007-04816]]
: [[IP]] [[2-2007-04818]]
: [[IP]] [[2-2008-00055]]
: [[IP]] [[2-2008-00405]]
: [[IP]] [[2-2008-00601]]
: [[IP]] [[2-2008-00770]]
: [[IP]] [[2-2008-01236]]
: [[IP]] [[2-2008-01262]]
: [[IP]] [[2-2008-01391]]
: [[IP]] [[2-2008-01463]]
: [[IP]] [[2-2008-01760]]
: [[IP]] [[2-2008-01823]]
: [[IP]] [[2-2008-02000]]
: [[IP]] [[2-2008-02504]]
: [[IP]] [[2-2008-02621]]
: [[IP]] [[2-2008-02739]]
: [[IP]] [[2-2008-03659]]
: [[IP]] [[2-2008-03661]]
: [[IP]] [[2-2008-03798]]
: [[IP]] [[2-2008-04192]]
: [[IP]] [[2-2008-04428]]
: [[IP]] [[2-2008-05074]]
: [[IP]] [[2-2008-05410]]
: [[IP]] [[2-2008-05411]]
: [[IP]] [[2-2008-05412]]
: [[IP]] [[2-2008-05483]]
: [[IP]] [[2-2008-05516]]
: [[IP]] [[3LO-2008-00069]]
: [[IP]] [[3-2008-00314]]
: [[IP]] [[3-2008-00484]]
: [[IP]] [[3-2008-00516]]
: [[IP]] [[3-2008-00705]]
: [[IP]] [[3-2008-00729]]
: [[IP]] [[3-2008-01454]]
: [[IP]] [[3-2008-01464]]
: [[IP]] [[3-2008-01815]]
: [[IP]] [[3-2008-02117]]
: [[IP]] [[3-2008-02566]]
: [[IP]] [[3-2008-02851]]
: [[IP]] [[3-2007-04640 Other Documents:]]
: [[LCOTR]] [[# 2-]]
: [[TS]] [[-08-0923]]
: [[IP]] [[]]
: [[EC]] [[Radiation Monitoring System Top Ten Technical Issues Action Plan, updated 12/17/08]]
: [[IPEC]] [[Radiation Monitoring System Long Range Plan Plan, updated 12/17/08]]
: [[IPEC]] [[Radiation Monitoring System Condition Report Trend Review, updated 12/17/08]]
: [[RMS]] [[Maintenance Improvement Plan, updated 12/17/08 Units 2 and 3 System Health Report for 2008]]
ER No. 04-2-042, R-41 / 42 Reliability Improvements Engineering Review package
Radiation Monitor, Portable Radiation Monitoring Instrumentation, and Calibrator Calibration  Sheets
: [[C.A.R.]] [[E Authorized Repair Center Certifications]]
: [[DUKE]] [[/]]
: [[NUPIS]] [[Member Audit Report of General Engineering Laboratories,]]
: [[LLC]] [[(GEL)]]
: [[IP]] [[]]
EC: Nuclear Energy Institute Groundwater Protection Initiative Self Assessment
Checklist, dated July 2008. Section
: [[4OA]] [[1:  Performance Indicator Verification  Procedures]]
: [[EN]] [[-LI-114, "Performance Indicator Process," Rev.]]
: [[2 EN]] [[-]]
LI-114, Attachment 9.2, "NRC Performance Indicator Technique/Data Sheet," Rev. 2, Second Quarter 2007 thru First Quarter 2008 NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Rev. 5  Other Documents Indian Point Unit 3 Operating Logs


Section 4OA2: Problem Identification and Resolution
==Section 4OA5: Other Activities==
Condition Reports
: Completed Surveillance Procedures
: [[IP]] [[2-2006-06939]]
: 2-PT-M021A, Rev. 17, Emergency Diesel Generator 21 Load Test, completed July 14, August 14, and September 8, 2008 2-PT-M021B, Rev. 17, Emergency Diesel Generator 22 Load Test, completed July 17, August 12, and September 10, 2008 2-PT-M021C, Rev. 15, Emergency Diesel Generator 23 Load Test, Completed July 16, August 12, and September 11, 2008 3-PT-M079A, Rev. 36, 31 EDG Functional Test, completed July 8, August 6, and September 4, 2008 3-PT-M079B, Rev. 37, 32 EDG Functional Test, completed July 9, August 6, and September2, 2008 3-PT-M079C, Rev. 36, 33 EDG Functional Test, completed July 11, August 8, and September 3, 2008  
: [[IP]] [[2-2007-00259]]
===Procedures===
: [[IP]] [[2-2007-01599]]
: 2-PT-R084A, Rev. 13, 21 EDG 8 Hour Load Test 3-PT-R160A, Rev. 11, 31 EDG Capacity Test 
: [[IP]] [[2-2007-03706]]
===Miscellaneous===
: [[IP]] [[3-2007-03619]]
: EnergySolutions Procedure
: [[IP]] [[3-2007-00453]]
: FP-FO-WI-001, Rev. 0, Spent Fuel Pool Cleaning at Indian Point Attachment Unit 1 Entergy Procedure 1-RP-RWM-913, Rev. 1, Unit 1 Fuel Handling Building West Pool 24/7 Demineralizer System Entergy Work Order
: [[IP]] [[2-2008-01056]]
: 00123484 10, Modifications to the FHB West Pool Demineralization System
IP2-2008-03671
: FEX-00039-02, Emergency Diesel Generator Loading Study
Attachment
: IP3-CALC-ED-00207, Rev. 7, 480 V Bus 2A, 3A, 5A, & 6A and EDGs 31, 32 & 33 Accident Loading Indian Point Nuclear Generating Unit No. 2 Updated Final Safety Analysis Report, Chapter 8, Rev. 20 Indian Point Nuclear Generating Unit No. 3, Updated Final Safety Analysis report, Chapter 8, Rev. 02, 2007 Emergency Diesel Generator Design Basis Document for Indian Point Unit 2, Rev. 1 Entergy Letter
: [[IP]] [[2-2008-02907]]
: NL-07-038, dated March 22, 2007, Proposed changes to Indian Point 2 Technical Specifications Regarding Diesel Generator Endurance Test Surveillance
: [[IP]] [[2-2008-02624]]
: Entergy Letter
: [[IP]] [[2-2008-02725]]
: NL-08-139, dated September 29, 2008, Reply to Request for Additional Information Regarding Indian Point Unit 2 Proposed Changes to Technical Specifications Regarding Diesel Generator Endurance Test Surveillance (TAC No.
: [[IP]] [[2-2008-03511]]
: MD9214) Entergy Letter
: [[IP]] [[2-2008-03956]]
: NL-08-157, dated October 8, 2008, Supplement to Reply to Request for Additional Information Regarding Indian Point Unit 2 Proposed Changes to Technical Specifications Regarding Diesel Generator Endurance Test Surveillance (TAC No. 9214) Entergy Letter
: [[IP]] [[2-2008-04020]]
: NL-08-160, dated October 13, 2008, Proposed Exigent License Amendment to Revise Technical Specification Surveillance Requirement 3.8.1.10 Frequency Regarding Diesel Generator Endurance Test NRC Letter dated October 20, 2008, Indian Point Nuclear Generating Unit No. 2 - Issuance of Exigent Amendment Re: Surveillance Interval for Diesel Generator Endurance Test (TAC No. MD9845)
: [[IP]] [[2-2008-01057]]
: MI-11272C, Engine Maintenance Schedule, Nuclear Standby Engines developed by ALCO Owner's Group and FM/ALCO Indian Point Nuclear Generating Unit No. 2 Technical Specifications, Section 3.8, Electrical Power Systems, through Amendment 255 Indian Point Nuclear Generating Unit No. 2 Technical Specifications Bases, Section 3.8, Electrical Power Systems, Rev. 2 Indian Point Nuclear Generating Unit No. 3 Technical Specifications, Section 3.8, Electrical Power Systems, through Amendment 226 Indian Point Nuclear Generating Unit No. 3 Technical Specifications Bases, Section 3.8, Electrical Power Systems, Rev. 3  
: [[IP]] [[2-2008-03330]]
: Attachment
: [[IP]] [[2-2008-03309]]
==LIST OF ACRONYMS==
: [[IP]] [[2-2008-03310]]
: [[ABFP]] [[auxiliary boiler feed pump]]
: [[IP]] [[2-2008-00389]]
: [[ADAMS]] [[Agency-wide Document and Management System]]
: [[IP]] [[2-2008-00464]]
: [[ANS]] [[alert and notification system]]
: [[IP]] [[3-2008-00640]]
: [[ASME]] [[American Society of Mechanical Engineers]]
: [[IP]] [[3 2008-01285]]
: [[CA]] [[corrective actions]]
: [[IP]] [[3-2008-01745]]
: [[CARB]] [[corrective action review board]]
: [[IP]] [[3-2008-02137]]
: [[CEDE]] [[committed effective does equivalent]]
: [[IP]] [[3-2008-03013]]
: [[CFR]] [[Code of Federal Regulations]]
: [[IP]] [[3LO-2008-00004]]
: [[CR]] [[condition report]]
: [[IP]] [[3]]
: [[EDO]] [[Executive Director of Operations ENTERGY  Entergy Nuclear Northeast]]
: [[LO]] [[-2008-00111]]
: [[EP]] [[Emergency Preparedness]]
: [[IP]] [[3]]
: [[FCU]] [[containment fan cooler unit]]
: [[LO]] [[-2008-00143]]
: [[IMC]] [[Inspection Manual Chapter]]
: [[IP]] [[3]]
: [[IPEC]] [[Indian Point Energy Center]]
: [[LO]] [[-2008-00172]]
: [[IPEEE]] [[Internal Plant Examination of External Events]]
: [[IP]] [[3]]
: [[JPM]] [[job performance measures]]
: [[LO]] [[-2008-00178]]
: [[LER]] [[licensee event report]]
: [[IP]] [[3]]
: [[MSPI]] [[Mitigating System Performance Indicator]]
: [[LO]] [[-2008-00179]]
: [[IP]] [[3]]
: [[LO]] [[-2008-00180]]
: [[HQN]] [[-2008-00339]]
: [[LO]] [[-WTIPC-2008-00043  Procedures]]
: [[SOP]] [[-27.3.1.1, "21 Emergency Diesel Generator Manual Operation," Rev. 16 and 17]]
ICPM-0708-1, "13.8 KV L&P bus section 3 partial differential relays (87B2-A/B/C)," Rev. 0
3-REF-003-Gen, "Reactor Core Refueling"
: [[SOV]] [[-003-]]
: [[ELC]] [[, "Inspection and Testing of Target Rock Solenoid Operated Valves"]]
: [[EN]] [[-]]
: [[LI]] [[-122, "Common Cause Evaluation," Rev.]]
: [[1 EN]] [[-]]
: [[LI]] [[-119, "Apparent Cause Evaluation (ACE) Process," Rev.]]
: [[7 EN]] [[-]]
: [[LI]] [[-102, "Corrective Action Process," Rev.]]
: [[13 EN]] [[-]]
OP-117, "Operations Assessments," Rev. 50 3-SOP-NI-001, "Excore Nuclear Instrumentation System Operation," Rev. 22
2-SOP-ESP-001, "Local Equipment Operation and Contingency Actions," Rev. 3 3-PT-M079C, "33
: [[EDG]] [[Functional Test," Rev. 36  Miscellaneous Documents]]
: [[NRC]] [[]]
: [[IR]] [[05000247/2008001 & 05000286/2008001 "Annual Assessment Letter - Indian Point Nuclear Generating Units 2 and 3" Dated March 3, 2008]]
: [[NRC]] [["Mid Cycle Performance Review and Inspection Plan - Indian Point Nuclear Generating Station Units 2 and 3" dated September 2, 2008.]]
: [[NRC]] [[Inspection Report 05000247/2008010 "Indian Point Nuclear Generating Station Unit 2-]]
NRC Problem Identification and Resolution Inspection Report" dated July 24, 2008
Indian Point Energy Center Procedure Adequacy Cross-Cutting Issue Resolution Plan Rev 4 Dated September 9, 2008 Indian Point Energy Center Procedure Adequacy Cross-Cutting Issue Resolution Plan Revs 0-3 Maintenance Department Procedure Improvement Plan (No date) Human Performance Training Plan and slides "Doer, Reader, Peer Checker, and Pilot" exercise.
Human Performance Training Plan and slides "Human Performance for
: [[IPEC]] [[Personnel" Operations Procedure Upgrade Project Communications plan for Operations personnel. Procedure Adequacy Cross-Cutting Resolution Plan Slideshow dated 10/20/08 Procedure Adequacy Cross-Cutting Resolution Plan Slideshow update dated 12/5/08 Plant Operating Procedures (]]
POP) Procedure Upgrade Project Plan dated 9/9/08
Plant Operating Procedures (POP) Procedure Upgrade Project Plan Rev 2 dated 10/26/08 Performance Indicators and worksheets for Procedure Workdown Curves, Procedure Feedback Forms,
: [[NRC]] [[Findings, Equipment Reliability, and Preventive Maintenance Completion. Indian Point Units 2 and 3 Summary of Findings/ Violations Report dated 12/1/08 Equipment Reliability Index Performance Indicator Guidance Book Revision 4 and Data Human Performance Cross Cutting Resolution Plan Presentation dated 12/2/08]]
: [[IPEC]] [[Open CR Inventory Report run 12/1/08]]
: [[IPEC]] [[]]
: [[CRG]] [[Summary Agenda Report for 12/2/08]]
: [[IPEC]] [[]]
CARB Meeting Agenda Report for 12/2/08
Section
: [[4OA]] [[5:  Other Activities  EnergySolutions Procedure]]
FP-FO-WI-001, Rev. 0, Spent Fuel Pool Cleaning at Indian Point
Attachment Unit 1 Entergy Procedure 1-RP-RWM-913, Rev. 1, Unit 1 Fuel Handling Building West Pool 24/7 Demineralizer System Entergy Work Order 00123484 10, Modifications to the
: [[FHB]] [[West Pool Demineralization System Completed Surveillance Procedures 3-]]
: [[PT]] [[-M079A, Rev. 36,]]
: [[31 EDG]] [[Functional Test, completed July 8, August 6, and Sept. 4, 2008 3-]]
: [[PT]] [[-M079B, Rev. 37,]]
: [[32 EDG]] [[Functional Test, completed July 9, August 6, and Sept. 2, 2008 3-]]
: [[PT]] [[-M079C, Rev. 36,]]
: [[33 EDG]] [[Functional Test, completed July 11, August 8, and Sept. 3, 2008  Procedures 3-]]
: [[PT]] [[-R160A, Rev. 11,]]
: [[31 EDG]] [[Capacity Test  Calculations]]
: [[IP]] [[3-CALC-ED-00207, Rev. 7, 480 V Bus 2A, 3A, 5A, & 6A and]]
: [[EDG]] [[s 31, 32 & 33 Accident Loading Other Documents Indian Point Nuclear Generating Unit No. 3, Updated Final Safety Analysis report, Chapter 8, Rev. 02, 2007]]
: [[MI]] [[-11272C, Engine Maintenance Schedule, Nuclear Standby Engines developed by]]
: [[ALCO]] [[Owner's Group and]]
FM/ALCO Indian Point Nuclear Generating Unit No. 3 Technical Specifications, Section 3.8, Electrical Power Systems, through Amendment 226 Indian Point Nuclear Generating Unit No. 3 Technical Specifications Bases, Section 3.8, Electrical Power Systems, Rev. 3
Attachment
: [[LIST]] [[]]
: [[OF]] [[]]
: [[ACRONY]] [[]]
: [[MS]] [[]]
: [[ADAMS]] [[Agency Wide Document Management System]]
: [[ALARA]] [[As Low As is Reasonably Achievable]]
: [[ANS]] [[Alert and Notification System]]
: [[AOP]] [[s  Abnormal Operating Procedure]]
: [[CAP]] [[Corrective Action Program]]
: [[CB]] [[Control Building]]
: [[CCW]] [[Component Cooling Water]]
: [[CEDE]] [[Cumulative Effective Dose Equivalent CFR  Code of Federal Regulations]]
: [[CR]] [[Condition Report]]
: [[CS]] [[Containment Spray]]
: [[DEC]] [[Department of Environmental Conservation]]
: [[ECCS]] [[Emergency Core Cooling System]]
: [[EDG]] [[Emergency Diesel Generator]]
: [[EDO]] [[Executive Director of Operations EOPs  Emergency Operating Procedures]]
: [[FCU]] [[Containment Fan Cooler Unit]]
: [[GL]] [[]]
: [[NRC]] [[Generic Letter]]
: [[GSI]] [[Generic Safety Inspection]]
: [[I&C]] [[Instrumentation and Controls]]
: [[IN]] [[Information Notice]]
: [[INPO]] [[Institute of Nuclear Power Operations]]
: [[IP]] [[Inspection Procedure]]
: [[IVSW]] [[Isolation Valve Seal Water]]
LCO  Limiting Condition for Operation LER Licensee Event Report
mRem  Millirem
: [[MS]] [[Main Steam]]
: [[MW]] [[Monitoring Well]]
: [[NCV]] [[non-cited violation]]
: [[NCV]] [[non-cited violation]]
: [[NEI]] [[Nuclear Energy Institute]]
: [[NDE]] [[non-destructive examination]]
: [[NIST]] [[National Institute of Science and Technology]]
: [[NRC]] [[Nuclear Regulatory Commission]]
: [[NRC]] [[Nuclear Regulatory Commission]]
: [[ODCM]] [[Offsite Dose Calculation Manual]]
: [[NRR]] [[Nuclear Reactor Regulation]]
: [[PAB]] [[Primary Auxiliary Building]]
: [[PARS]] [[Publicly Available Records System]]
: [[PA]] [[]]
: [[PI]] [[performance indicator]]
: [[RS]] [[Publicly Available Records]]
: [[PIM]] [[plant issues matrix]]
: [[PI]] [[Performance Indicator]]
: [[RHR]] [[residual heat removal]]
: [[PI&R]] [[Problem Identification and Resolution]]
: [[SCBA]] [[self-contained breathing apparatus]]
: [[POP]] [[Plant Operating Procedures]]
: [[SCCI]] [[substantive cross-cutting issue]]
: [[PRA]] [[Probabilistic Risk Assessments]]
: [[SDP]] [[significance determination process]]
: [[PWR]] [[Pressurized-Water Reactors]]
: [[SG]] [[steam generator]]
: [[QA]] [[Quality Assurance RCA Radiological Controlled Area]]
: [[SI]] [[safety injection]]
: [[RMS]] [[Radiation Monitoring Systems]]
: [[SSC]] [[structures, systems, and components]]
: [[RP]] [[Radiation Protection]]
: [[TI]] [[temporary instruction]]
: [[RWP]] [[Radiation Work Permit]]
: [[TS]] [[Technical Specification]]
SCBA  Self-Contained Breathing Apparatus SDP  Significance Determination Process
: [[UFSAR]] [[Updated Final Safety Evaluation Report]]
SFP  Spent Fuel Pool
: [[URI]] [[unresolved item WO  work order]]
Attachment
: [[SI]] [[Safety Injection]]
: [[SSC]] [[Structures, Systems, and Components]]
: [[SW]] [[Service Water]]
: [[SWP]] [[Service Water Pump]]
: [[TI]] [[Temporary Instruction]]
: [[TLD]] [[Thermoluminescent Dosimeter]]
: [[TS]] [[Technical Specifications]]
: [[UFSAR]] [[Updated Final Safety Analysis Report]]
}}
}}

Revision as of 15:52, 27 August 2018

IR 05000247-08-005; 10/01/2008 - 12/31/2008; Indian Point Nuclear Generating Unit 2; Resident Inspector Quarterly Integrated Inspection Report
ML090340463
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 02/03/2009
From: Gray M K
Reactor Projects Branch 2
To: Pollock J E
Entergy Nuclear Operations, Entergy Operations
Gray, Mel NRC/RGNI/DRP/PB2/610-337-5209
References
FOIA/PA-2009-0094, FOIA/PA-2010-0209 IR-08-005
Download: ML090340463 (39)
v • d • e


Text

February 3, 2009

Mr. Joseph Site Vice President Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB Buchanan, NY 10511-0249

SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC INTEGRATED INSPECTION REPORT 05000247/2008005

Dear Mr. Pollock:

On December 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Unit 2. The enclosed integrated inspection report documents the inspection results, which were discussed on January 9, 2009, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Indian Point Nuclear Generating Station, Unit 2.

In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room of from the Publicly Available Records (PARS) component of the NRC's 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/

Mel Gray, Chief Projects Branch 2 Division of Reactor Projects

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

Enclosure:

Inspection Report No. 05000247/2008005 w/

Attachment:

Supplemental Information cc w/encl:

Senior Vice President, Entergy Nuclear Operations Vice President, Operations, Entergy Nuclear Operations Vice President, Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety and Licensing, Entergy Nuclear Operations Senior Vice President and COO, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations Manager, Licensing, Entergy Nuclear Operations C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law A. Donahue, 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 P. Eddy, NYS Department of Public Service Assemblywoman Sandra Galef, NYS Assembly T. Seckerson, County Clerk, Westchester County Board of Legislators 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 Congressman John Hall Congresswoman Nita Lowey Senator Hillary Rodham Clinton Senator Charles Schumer G. Shapiro, Senator Clinton's Staff J. Riccio, Greenpeace P. Musegaas, Riverkeeper, Inc. M. Kaplowitz, Chairman of County Environment & Health Committee A. Reynolds, Environmental Advocates D. Katz, Executive Director, Citizens Awareness Network K. Coplan, Pace Environmental Litigation Clinic M. Jacobs, IPSEC W. Little, Associate Attorney, NYSDEC M. J. Greene, Clearwater, Inc. R. Christman, Manager Training and Development J. Spath, New York State Energy Research, SLO Designee F. Murray, President & CEO, New York State Energy Research A. J. Kremer, New York Affordable Reliable Electricity Alliance (NY AREA)

ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Mel Gray, Chief Projects Branch 2 Division of Reactor Projects

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

Enclosure:

Inspection Report No. 05000247/2008005 w/

Attachment:

Supplemental Information Distribution w/encl:

S. Collins, RA M. Dapas, DRA D. Lew, DRP J. Clifford, DRP Stephen Campbell, RI OEDO R. Nelson, NRR M. Kowal, NRR J. Boska, PM, NRR J. Hughey, NRR S. Hansell, DRS M. Gray, DRP B. Bickett, DRP A. Rosebrook, DRP S. McCarver, DRP G. Malone, DRP, SRI - Indian Point 2 C. Hott, DRP, RI - Indian Point 2 Region I Docket Room (w/concurrences) ROPreport Resources (All IRs)

SUNSI Review Complete: _BB__ (Reviewer's Initial)

ML090340463 DOCUMENT NAME: G:\DRP\BRANCH2\a - Indian Point 2\Inspection Reports\IP2 IR2008-005\IP2 2008005 r5.doc 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 GMalone/BB for BBickett/BB MGray/MG Date 02/02/09 01/27/09 02/02/09 OFFICAL AGENCY RECORD 1 Enclosure

U.S. Nuclear Regulatory Commission Region I Docket No.: 50-247 License No.: DPR-26

Report No.: 05000247/2008005 Licensee: Entergy Nuclear Northeast (Entergy)

Facility: Indian Point Nuclear Generating Unit 2 Location: 450 Broadway, GSB Buchanan, NY 10511-0249

Dates: October 1, 2008 through December 31, 2008

Inspectors: G. Malone, Senior Resident Inspector, Indian Point 2 C. Hott, Resident Inspector, Indian Point 2 P. Cataldo, Senior Resident Inspector, Indian Point 3 A. Koonce, Resident Inspector, Indian Point 3 J. Noggle, Reactor Inspector, Region I J. Commisky, Reactor Inspector, Region I A. Rosebrook, Senior Project Engineer, Region I R. Fuhrmeister, Senior Project Engineer, Region I D. Silk, Senior Operations Engineer, Region I B. Haagensen, Operations Engineer, Region I Approved By: Mel Gray, Chief Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000247/2008005; 10/01/2008 - 12/31/2008; Indian Point Nuclear Generating Unit 2; Resident Inspector Quarterly Integrated Inspection Report.

This report covered a three-month period of inspection by resident and region based inspectors.

The NRC's program for overseeing safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Violations

A violation of very low safety significance that was identified by Entergy was reviewed by the inspectors. Corrective actions taken or planned by Entergy were entered into Entergy's corrective action program. The violation and its corrective action tracking numbers are listed in Section 4OA7.

REPORT DETAILS

Summary of Plant Status

Indian Point Nuclear Generating Unit 2 began the inspection period operating at 100 percent reactor power. Operators reduced plant power to 85 percent on October 22 to repair an expansion joint on the suction piping of the 22 condensate pump. The plant was returned to full power operation on October 23. Unit 2 operated at or near full power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Cold Weather Preparations

a. Inspection Scope

The inspectors reviewed the readiness of risk-significant systems for extreme cold-weather conditions. The inspectors reviewed Entergy's adverse weather procedures, operating experience, corrective action program, Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TS), operating procedures, staffing, and applicable plant documents to determine the types of adverse weather challenges to which the site is susceptible. The following risk-significant systems that were required to be protected from adverse weather conditions were selected and collectively represent one inspection sample:

  • Primary, refueling, and primary water storage tanks;
  • Fire water storage tank.

b. Findings

No findings of significance were identified.

.2 External Flooding

a. Inspection Scope

The inspectors reviewed the readiness of barriers to external flooding for the service water intake structure and related equipment. The inspectors reviewed Entergy's adverse weather procedures, abnormal operating procedures, operating experience, Updated Final Safety Analysis Report (UFSAR), and Internal Plant Examination of External Events (IPEEE) to determine susceptibilities to external floods and review the site's methods to mitigate the effects of external flooding. The inspectors walked down the service water pump vault and the strainer vaults to verify the integrity of the structures and components contained within to the effects of flooding. The inspectors 3 Enclosure also verified that barriers and systems used to mitigate flooding were available and in adequate material condition.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

Main article: IP 71111.04Q

Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns to verify the operability of redundant or diverse trains and components during periods of system train unavailability, or following periods of maintenance. The inspectors referenced the system procedures, the UFSAR, and system drawings to verify that the alignment of the available train supported its required safety functions. The inspectors also reviewed applicable condition reports (CR) and work orders to ensure that Entergy had identified and properly addressed equipment discrepancies that could potentially impair the capability of the available train, as required by Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, "Corrective Action." Documents reviewed during this inspection are listed in the Attachment.

The inspectors performed a partial walkdown on the following systems, which represented four inspection samples:

  • Appendix R diesel following restoration from planned maintenance;
  • 23 safety injection (SI) pump train during 21 SI pump breaker maintenance; and

b. Findings

No findings of significance were identified.

1R05 Fire Protection

Main article: IP 71111.05Q

a. Inspection Scope

The inspectors conducted tours of fire areas to assess the material condition and operational status of fire protection features. The inspectors verified, consistent with the applicable administrative procedures, that: combustibles and ignition sources were adequately controlled; passive fire barriers, manual fire-fighting equipment, and suppression and detection equipment were appropriately maintained; and compensatory measures for out-of-service, degraded, or inoperable fire protection equipment were implemented in accordance with Entergy's fire protection program. The inspectors evaluated the fire protection program against the requirements of License Condition 2.K. The documents reviewed during this inspection are listed in the Attachment. This 4 Enclosure inspection represented six inspection samples for fire protection tours, and was conducted in the following areas:

  • Zone 8, Boric acid transfer pump (BATP) and tank area;
  • Zone 1, Component cooling water pump room;
  • Zones 12,13, and 14, 125-Vdc vital battery rooms (batteries 21, 22, and 24); and

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review

Main article: IP 71111.11Q

a. Inspection Scope

On August 18, 2008, the inspectors observed licensed operator simulator training to verify that operator performance was adequate, and that evaluators were identifying and documenting crew performance problems. The inspectors evaluated the performance of risk-significant operator actions, including the use of emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, the implementation of appropriate actions in response to alarms, the performance of timely control board operation and manipulation, and the oversight and direction provided by the control room supervisor. The inspectors also reviewed simulator fidelity with respect to the actual plant. The inspectors evaluated licensed operator training against the requirements of 10 CFR Part 55, "Operator Licenses." The documents reviewed during this inspection are listed in the Attachment. This observation of operator simulator training represented one inspection sample.

b. Findings

No findings of significance were identified.

.2 Biennial Review

Main article: IP 71111.11B

a. Inspection Scope

The following inspection activities were performed using NUREG 1021, Rev. 9, AOperator Licensing Examination Standards for Power Reactors;

@ and NRC Inspection Procedure 71111.11, ALicensed Operator Requalification Program,@ Appendix A AChecklist for Evaluating Facility Testing Material

@ and Appendix B ASuggested Interview Topics.@ The inspectors reviewed recent operating history documentation found in inspection reports, licensee event reports, the licensee

=s corrective action program, and the most recent NRC plant issues matrix (PIM). The inspectors also reviewed specific events 5 Enclosure from Entergy

=s corrective action program which indicated possible training deficiencies, to verify they had been appropriately addressed. The senior resident inspector was also consulted for insights regarding licensed operators

= performance.

The remediation plans for a crew or individual

=s performance weaknesses or enhancements were reviewed by the inspectors to assess the effectiveness of the remedial training. The inspectors interviewed operators, instructors and training/operation

=s management for feedback on their training program and the quality of training received.

The inspectors reviewed simulator performance and fidelity for conformance to the reference plant control room.

A sample of records for requalification training attendance, program feedback, reporting, and medical examinations were reviewed by the inspectors for compliance with license conditions, including NRC regulations.

The inspectors reviewed the operating tests for the weeks of September 29 and October 6, 2008, for content, quality and overlap. Likewise, the 2007 written exam was reviewed for content, quality, and overlap.

The inspectors observed dynamic simulator exams and job performance measures administered during the week of October 6, 2008. These observations included facility evaluations of crew and individual performance during the dynamic simulator exams and individual performance of five JPMs.

On October 20, 2008, the inspectors reviewed the results of the annual operating tests for year 2008 and the written exam for 2007 to determine if pass/fail rates were consistent with the guidance of NUREG-1021, Revision 9, AOperator Licensing Examination Standards for Power Reactors

@ and NRC Manual Chapter 0609, Appendix I, AOperator Requalification Human Performance Significance Determination Process (SDP).@ The review verified the following:

$ Crew failure rate on the dynamic simulator was less than 20%.

(Failure rate was 0.0%)

$ Individual failure rate on the dynamic simulator test was less than or equal to 20%. (Failure rate was 0.0%)

$ Individual failure rate on the walkthrough test (job performance measures) was less than or equal to 20%. (Failure rate was 0.0%)

$ Individual failure rate on the 2007 comprehensive written exam was less than or equal to 20%. (Failure rate was 0.0%)

$ More than 75% of the individuals passed all portions of the exam (100% of the individuals passed all portions of the exam).

b. Findings and Observations

No findings of significance were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12Q

a. Inspection Scope

The inspectors reviewed performance-based problems that involved structures, systems, and components (SSCs) to assess the effectiveness of maintenance activities. When applicable, the reviews focused on:

  • Proper Maintenance Rule scoping in accordance with 10 CFR 50.65;
  • Characterization of reliability issues;
  • Changing system and component unavailability;
  • Identifying and addressing common cause failures;
  • Trending of system flow and temperature values;
  • Appropriateness of performance criteria for SSCs classified (a)(2); and
  • Adequacy of goals and corrective actions for SSCs classified (a)(1).

The inspectors also reviewed system health reports, maintenance backlogs, and Maintenance Rule basis documents. The inspectors evaluated maintenance effectiveness and monitoring activities against the requirements of 10 CFR 50.65.

The documents reviewed during this inspection are listed in the Attachment. The following Maintenance Rule samples were reviewed and represented two inspection samples:

  • Buried piping inspections of the condensate storage tank supply piping to the auxiliary feedwater system.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed scheduled and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment from service for maintenance or repair. The inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4), and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. Documents reviewed during this inspection are listed in the Attachment. The following activities represented four inspection samples:

  • Planned elevated-risk maintenance condition for 23 charging pump motor replacement;
  • Planned elevated-risk maintenance condition for an endurance run on the 23 emergency diesel generator performed once every 18-months;
  • Planned elevated-risk maintenance condition during 21 auxiliary boiler feedwater pump breaker outage; and
  • Planned elevated-risk maintenance condition during 138kv [kilovolt] feeder outage and safety injection system testing.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed operability evaluations to assess the acceptability of the evaluations, the use and control of compensatory measures when applicable, and compliance with Technical Specifications. The inspectors' reviews included verification that operability determinations were performed in accordance with procedure ENN-OP-104, "Operability Determinations." The inspectors assessed the technical adequacy of the evaluations to ensure consistency with the Technical Specifications, UFSAR, and associated design basis documents (DBDs). The documents reviewed are listed in the Attachment. The following operability evaluations were reviewed and represented two inspection samples:

  • Impact of incorrect component materials on component cooling pump constant level oilers; and

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

Main article: IP 71111.18

a. Inspection Scope

The inspectors reviewed a temporary plant modification package associated with an additional nitrogen supply connected to the air supply system for the 138kV 52/BT4-5 air-operated breaker. The breaker's function is to provide an alternate path for 138kV offsite power to be cross-connected between Indian Point Units 2 and 3. The temporary modification was installed to address a degrading air compressor on the breaker until corrective maintenance is performed. The inspectors verified that the design bases, licensing bases, and performance capability of the system was not negatively impacted by the temporary modification. In addition, the inspectors interviewed plant staff, and reviewed issues that were entered into the corrective action program to determine whether Entergy had been effective in identifying and resolving problems associated with the temporary modification. The documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed post-maintenance test procedures and associated testing activities for selected risk-significant mitigating systems, and assessed whether the effect of maintenance on plant systems was adequately addressed by control room and engineering personnel. The inspectors verified that: test acceptance criteria were clear, demonstrated operational readiness and were consistent with design basis documentation; test instrumentation had current calibrations, and appropriate range and accuracy for the application; and the tests were performed as written, with applicable prerequisites satisfied. Upon completion of the tests, the inspectors verified that equipment was returned to the proper alignment necessary to perform its safety function. Post-maintenance testing was evaluated against the requirements of 10 CFR 50, Appendix B, Criterion XI, "Test Control." The documents reviewed are listed in the Attachment. The following post-maintenance activities were reviewed and represented seven inspection samples:

  • 23 charging pump following motor replacement;
  • 21 auxiliary boiler feed pump (ABFP) alternate safe shutdown breaker test;
  • 22 ABFP following maintenance on steam supply valve PCV-1139;
  • 22 containment fan cooler unit following bearing lubrication.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed performance of portions of surveillance tests and/or reviewed test data for selected risk-significant SSCs to assess whether they satisfied Technical Specifications, UFSAR, Technical Requirements Manual, and Entergy procedure requirements. The inspectors verified that: test acceptance criteria were clear, demonstrated operational readiness, and were consistent with design basis documentation; test instrumentation had accurate calibration, and appropriate range and accuracy for the application; and tests were performed as written, with applicable prerequisites satisfied. Following the tests, the inspectors verified that the equipment was capable of performing the required safety functions. The inspectors evaluated the surveillance tests against the requirements in Technical Specifications. The documents reviewed during this inspection are listed in the Attachment. The following surveillance tests were reviewed and represented six inspection samples:

  • 2-PC-4Y74C, nuclear instruments power range N-43 channel calibration;
  • 2-PT-V59, reactor trip breaker "A" changeout and functional test;
  • 2-PC-2Y55, channel calibration of containment sump level indicator LT-941;
  • PT-Q13, valve stroke 869B (containment isolation valve).

b. Findings

No findings of significance were identified.

Cornerstone:

Emergency Preparedness (EP)1EP2 Alert and Notification System (ANS) Evaluation

a. Inspection Scope

The inspectors observed a full-volume siren test on October 22, 2008 to verify Entergy's newly installed siren system functioned properly. The inspectors verified that the minimum required number of sirens functioned when actuated. This inspection was conducted in accordance with the baseline inspection program deviation authorized by the NRC Executive Director of Operations (EDO) in a memorandum dated October 31, 2005, and renewed by the EDO in a memorandum dated December 19, 2007.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone:

Occupational Radiation Safety (OS)2OS3 Radiation Monitoring Instrumentation and Protective Equipment

a. Inspection Scope

(71121.03 - 9 samples)

During December 15-19, 2008, the inspectors conducted the following activities to evaluate the operability and accuracy of radiation monitoring instrumentation, and the adequacy of the respiratory protection program for issuing self-contained breathing apparatus (SCBA) to emergency response personnel. Implementation of these programs was reviewed by the inspectors against the criteria contained in 10 CFR 20, applicable industry standards, and Entergy's procedures.

1) The inspectors reviewed the UFSAR to identify area radiation monitors that are installed at Indian Point Units 2 and 3 for the protection of workers, and reviewed the calibration procedure and current calibration records for selected instrumentation, including Unit 2 plant radiation monitors; main steam line 10 Enclosure radiation monitors (R-28, R-29, R-30, R-31), refuel floor area radiation monitor (R-5), containment high-range radiation and noble gas monitors (R-25, R-26), gaseous and particulate containment radiation monitors (R-42, R-41), in-core area radiation monitor (R-7), steam generator blow down radiation monitor (R-49); Unit 3 plant radiation monitors; main steam line radiation monitors (R-62A, R-62B, R-62C, R-62D), refuel floor area radiation monitor (R-5), containment high-range radiation and noble gas monitors (R-25, R-26), gaseous and particulate containment radiation monitors (R-12, R-11), in-core area radiation monitor (R-7), and steam generator blow down radiation monitor (R-19). The inspectors discussed the monitoring system health reports and instrument reliability trends with the system engineer.

2) The inspectors identified various radiation detection instruments used at Indian Point used for job coverage for work in radiologically significant areas, including continuous air monitors and whole body counters. Instruments evaluated were 49 electronic dosimeters, 13 radiation survey instruments, 12 extendable probe survey instruments, 6 neutron radiation survey instrument, 6 continuous air monitors, 4 portal monitors, 7 beta/alpha counters and 2 whole body counters.

3) Current calibration records, applicable calibration procedures, operability, and alarm set points were reviewed by the inspectors for the instruments identified above. In addition, the inspectors reviewed the applicable calibrators utilized for appropriate instrument calibration geometries and National Institute for Science and Technology standard traceability. They included: Shepherd 81-12B beam source calibrators, Shepherd 142-10 panoramic calibrator, Shepherd 149 neutron source calibrator and Shepherd 1000B box source calibrator. The plant source term was reviewed by the inspectors to determine whether calibration sources being used were representative.

4) Radiological incidents involving internal exposures identified by condition reports for 2008 were reviewed by the inspectors. In addition, dosimetry electronic records were queried for any internal exposures >50 mrem committed effective dose equivalent (CEDE). None were identified for further review.

5) The inspectors reviewed condition reports with respect to radiation protection program deficiencies to determine if the deficiencies were appropriately characterized and corrected commensurate with their safety significance.

6) Based on the condition reports reviewed, no repetitive deficiencies were identified for further follow-up.

7) With respect to the RP portable instruments listed in 3) above, the instrument

=s calibration expiration and response check stickers were reviewed by the inspectors. The applicable response check beta-source and instrument sign-out procedures were also reviewed. The inspectors queried radiation protection technicians regarding appropriate instrument selection and observed self verification of instrument operability prior to use.

8) The inspectors sampled emergency plan-specified self contained breathing apparatus (SCBA) equipment and qualified users based on Indian Point Energy Center Emergency Plan documents and included inspection of selected SCBAs 11 Enclosure and air bottle cascade systems located inside or adjacent to both the Unit 2 and Unit 3 main control rooms. The inspectors verified SCBA qualification records for select on-shift reactor operators were current. The inspectors also verified that air used to fill the SCBAs met the Grade D quality criteria of the Compressed Gas Association. The inspectors queried on shift reactor operators to determine the storage location of required spectacles.

9) The inspectors examined selected SCBA units for periodic air cylinder hydrostatic testing and maintenance records. The inspectors also performed a review of approved replacement parts documentation and certification of the repair personnel.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

[OA]

4OA1 Performance Indicator Verification

Main article: IP 71151

a. Inspection Scope

The inspectors reviewed performance indicator data for the cornerstones listed below and used Nuclear Energy Institute 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, to verify individual performance indicator accuracy and completeness. The documents reviewed during this inspection are listed in the Attachment.

Mitigating Systems Cornerstone

  • Heat Removal Systems (MSPI)
  • Cooling Water Systems (MSPI)

Occupational Radiation Safety Cornerstone

  • RETS/ODCM Radiological Effluent Occurrences

b. Findings

No findings of significance were identified.

12 Enclosure

4OA2 Identification and Resolution of Problems

Main article: IP 71152

.1 Routine Problem Identification & Resolution Program Review

a. Inspection Scope

As required by Inspection Procedure 71152, "Identification and Resolution of Problems," and to identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of all items entered into Entergy's corrective action program. The review was accomplished by accessing Entergy's computerized database for condition reports, and attending condition report screening meetings.

In accordance with the baseline inspection modules, the inspectors selected corrective action program items across the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for further follow-up and review. The inspectors assessed Entergy's threshold for problem identification, adequacy of the causal analysis, extent of condition reviews, and operability determinations, and timeliness of the associated corrective actions.

b. Findings

No findings of significance were identified.

.2 Semi-Annual Trend Review

Main article: IP 71152

a. Inspection Scope

The inspectors performed a semi-annual review to identify trends that might indicate the existence of a more significant safety issue. The inspectors included in this review, repetitive or closely-related issues that may have been documented by Entergy outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors reviewed Entergy's corrective action program database for the third and fourth quarters of 2008 to assess the total number and significance of condition reports (CRs) written in various subject areas. The inspectors also reviewed Entergy's corrective action, engineering, and maintenance quarterly trend reports for the second and third quarters of 2008 to ensure Entergy was appropriately evaluating and trending adverse conditions.

The inspectors focused on an adverse trend in through-wall leaks identified in service water piping. The inspectors reviewed CRs, causal evaluations, maintenance plans, business plans, and interviewed station personnel to assess whether Entergy identified the adverse trend and developed appropriate corrective actions to address the conditions.

b. Assessment and Observations No findings of significance were identified.

13 Enclosure Entergy identified three leaks in service water system blowdown piping on August 19, 2008 and determined the leaks were pinhole size that resulted in wetting of the pipe surface. Entergy entered the issue into the CAP and performed an immediate operability assessment that concluded the piping was operable and did not impact the pipe's structural integrity. Entergy performed extent-of-condition walkdowns in the service water intake area and discovered additional leaks on service water system blowdown piping welds. Entergy personnel performed volumetric non-destructive testing of the pipes in accordance with their procedures and determined that these additional leaks were minor localized defects that did not impact structural integrity and, therefore, the service water systems they supported remained operable. Entergy performed the actions described in ASME Code Case N-513-2 for the ASME Class III service water piping and established monitoring frequencies and flaw acceptance criteria. Entergy's short term corrective actions included: performing engineering walkdowns of all stainless steel piping in the service water system, establishing daily walkdowns of identified flaws, and performing volumetric inspection on the identified flaws as required by ASME Code. Entergy identified long term actions that include replacement of the stainless steel service water blowdown piping with a more corrosion-resistant material as Entergy personnel determined that the 304 stainless steel blowdown piping is susceptible to pitting corrosion due to the brackish water of the Hudson River. The replacement is planned to be completed prior to the next refueling outage in the spring of 2010.

Additionally, as part of Entergy's extent-of-condition walkdowns, Entergy identified several leaks on stainless steel service water piping servicing radiation monitors for the containment fan coil units. Similar to the service water blowdown piping, Entergy determined the pinhole leaks were on weld material. However, because the leaks appeared on socket welds and the flaws could not be accurately characterized, ASME Code Case N-513-2 was not applicable and Entergy declared the radiation monitors inoperable and repaired the flaws. Entergy determined that the leaks were caused by pitting corrosion in the 300 series stainless steel pipe welds and the brackish water of the Hudson River. Entergy implemented corrective actions that included immediate repair of all leaking welds and development of an Engineering Change Request package that will replace the radiation monitor piping with a highly corrosion resistant material (AL6XN).

On September 16, 2008, the inspectors identified a small through-wall leak on service water piping supplying cooling water to the containment fan-coil units (FCUs). Specifically, the inspectors identified a pinhole leak that resulted in a wetted pipe surface on a weld neck flange for a 2-inch carbon-steel drain line connected to a 10-inch supply header to the 22 FCU. Entergy performed an operability assessment for the containment penetration and supported the evaluation with confirmatory ultrasonic tests and structural calculations. Entergy determined the cause of this failure was the result of improperly coated weld surfaces internal to the pipe that occurred in 2002. Entergy determined the maintenance procedures, at that time, used to prepare the piping prior to welding did not contain adequate instructions for properly preparing a pipe or weld surface prior to the application of the corrosion resistant coating. Entergy developed procedure 0-SYS-409-GEN, "Belzona and Enecon Metal Repair Applications," in 2005 to improve surface preparation and application techniques. Entergy implemented short term actions to monitor the leakage daily, perform 90-day follow-up ultrasonic testing on the leak location, and perform extent-of-condition walkdowns and UT measurements on the corresponding welds of the 21, 23, 24, and 25 FCUs. Entergy's long term corrective actions includes procedure revisions, repair of the weld during the next refueling outage, 14 Enclosure and plans to visually inspect the welds on the other FCUs during the next refueling outage.

The inspectors determined that there was reasonable opportunity for Entergy to identify and correct the 22 FCU leak prior to NRC identification as required per 10 CFR 50, Appendix B, criterion XVI, "Corrective Action;" however, the inspectors determined, based on subsequent testing of the 22 FCU performed by Entergy, that the operability of the 22 FCU and the corresponding containment penetration was not impacted. Therefore, this violation of 10 CFR 50, Appendix B is considered to be of minor significance and not subject to NRC enforcement.

In general and notwithstanding the NRC inspector-identified minor leak, the inspectors determined that Entergy appropriately identified the adverse trend in service water piping corrosion issues in the corrective action program and documented operability assessments for the service water leaks that were supported by a sufficient technical basis. The inspectors determined that Entergy performed appropriate causal evaluations and implemented extent-of-condition reviews to understand the corrosion mechanisms that existed in service water piping and the extent of the issues. The inspectors also determined that Entergy identified and implemented or planned corrective actions commensurate with the requirements of their corrective action program and the ASME Code. Additionally, the inspectors observed that corrective actions included consideration for the safety significance of the issues.

.3 Aggregate Impact of Operator Workarounds

Main article: IP 71152

a. Inspection Scope

The inspectors conducted a review of the aggregate impact of operator burdens and workarounds. The inspectors reviewed Entergy's implementation of procedures OAP-45, "Operator Burden Program," Revision 1. The inspectors conducted control room walkdowns and interviewed plant operators to determine the impact of deficiencies on operator response to plant events.

b. Findings and Observations

No findings of significance were identified. The inspectors verified that operator workarounds and burdens were entered into the corrective action program at an appropriate threshold and that corrective actions were planned or taken commensurate with their safety significance.

.4 Substantive Cross-Cutting Issue Review: Human Performance - Procedure

Adequacy (71152 - 1 sample)

a. Inspection Scope

The inspectors reviewed Entergy's actions to address the Substantive Cross-Cutting Issue (SCCI) in Human Performance related to procedure adequacy. The inspectors' review focused on Entergy's progress in addressing the SCCI since their implementation of a revised action plan in May 2008. The inspectors evaluated Entergy's performance improvement plans and actions using inspection guidance in Inspection Procedure 71152, "Identification and Resolution of Problems." Specifically, the inspectors 15 Enclosure assessed Entergy's progress in resolving the cross-cutting issue by evaluating whether Entergy's internal milestones were being monitored and consistently met and whether adjustments in approach were made when necessary. This inspection focused on the progress made since the PI&R sample inspection conducted in October 2008 (NRC Inspection Report 05000247/2008013 and 05000286/2008011).

The inspectors conducted a review of the applicable condition reports (CRs), corrective action assignments (CAs), focused self-assessments, Quality Assurance group assessments, and causal evaluations for the substantive cross-cutting issue. The inspectors also reviewed Entergy's performance indicators related to their performance improvement plan; reviewed a sample of revised procedures; conducted a series of interviews with station management, procedure writers and reviewers, maintenance technicians, and operators in order to assess the adequacy of the performance plan and effectiveness of corrective actions.

b. Findings and Observations

No findings of significance were identified.

The inspectors determined that Entergy continued to make progress in effectively implementing their corrective action plans that address the substantive cross-cutting issue in Human Performance related to procedure adequacy.

The inspectors concluded that Entergy's corrective action plans were reasonable in scope because they addressed procedures that contributed to the substantive cross-cutting issue. Entergy's corrective action plans included Operations, Electrical and Mechanical Maintenance, and I&C Maintenance procedures. The procedure upgrade project portion of Entergy's corrective action plans focused on risk significant components and actions in operating procedures. The inspectors determined the procedure upgrade project scope appropriately included operating procedures related to initiating events, single point vulnerabilities, and integrated plant operating procedures. The inspectors observed that station training was developed and provided for the individuals involved in the procedure upgrade project and their management. The inspectors also observed that procedure reviews were being conducted for Security, Chemistry, Radiation Protection, and Engineering procedures to improve the quality of procedures in those areas.

The inspectors confirmed previous NRC observations, through interviews with Entergy staff, that the station has shifted the ownership of this project from the support organizations to the line organization. Entergy personnel indicated this organizational alignment has been a significant factor in the increased acceptance and participation from plant workers, and produced a noticeable improvement in revised procedure quality. The inspectors observed that several personnel interviewed commented that the human performance training simulator is an effective tool, and assisted procedure writers with the identification of human performance error traps in existing procedures.

The inspectors concluded that the realignment of the procedure upgrade project resulted in enhanced project accountability and quality output.

With respect to the progress of the procedure upgrade project, Entergy completed Phase I of the project ahead of their internal schedule and started Phase II. Phase I consisted of operations procedures associated with the top three risk significant systems 16 Enclosure for Units 2 and 3. Phase II of the procedure upgrade project included the remaining top 10 plant risk significant systems, integrated plant operating procedures, procedures which involved single point vulnerabilities and initiating events. Current Entergy plans and progress indicate that the Phase II portion of the procedure upgrade project will be completed by June 2009, several months ahead of the corrective action plan schedule. The inspectors reviewed a sample of the revised Phase I and Phase II procedures and determined that significant revisions were made and the results met the quality and procedure standards described in Entergy's action plan.

The inspectors also observed that the Electrical and Mechanical Maintenance procedure upgrade project and the I&C Maintenance procedure development project made progress that was consistent with internal action plan schedules and milestones. The inspectors determined that the projects continue to receive the appropriate level of resources and management review and support to ensure completion of these projects.

The inspectors determined that human error awareness and prevention actions were being implemented by Entergy to address the human performance aspects that contributed to the substantive cross-cutting issue in procedure adequacy. The inspectors determined that implementation of training, specifically the human performance training simulator, was appropriate to reinforce human error prevention techniques being applied in the plant.

The inspectors concluded Entergy developed appropriate monitoring measures and performance indicators to assess corrective action effectiveness. The inspectors observed that Entergy utilized these tools to provide initial feedback on corrective action implementation. For example, the inspectors determined that the performance indicators, related to procedure completion status and procedure feedback process backlog, were an effective tool for monitoring station progress in these areas.

Additionally, the inspectors concluded that self-assessments were an effective tool for corrective action adjustments and for evaluation of internal and external stakeholder recommendations. Entergy has adjusted the corrective action plan and procedure upgrade project scope to adequately incorporate stakeholder recommendations.

5. Substantive Cross-Cutting Issue Review: Problem Identification and Resolution -

Implementation of Corrective Actions (71152 - 1 sample)

a. Inspection Scope

The inspectors reviewed Entergy's action plan to address the Substantive Cross Cutting Issue (SCCI) identified for Unit 2 in the area of Problem Identification and Resolution related to implementation of effective corrective actions. This SCCI was identified in the NRC's 2008 Annual Assessment letter [ADAMS Ref. No. ML080610015] and was continued in the NRC 2008 Mid Cycle Performance Review [ADAMS Ref. No. ML082470316].

The inspectors conducted a review of the applicable condition reports (CRs), corrective action assignments (CAs), focused self-assessments, Quality Assurance group assessments, root cause analyses, common cause analyses, and apparent cause determinations for the substantive cross-cutting issue. The inspectors also reviewed the CRs and corrective actions associated with the four NCVs which contributed to this cross-cutting issue and reviewed a sample of corrective actions for NRC findings in 2007 17 Enclosure and 2008 to determine if a trend existed. The inspectors reviewed Entergy's performance in order to assess the adequacy of the performance plan and effectiveness of corrective actions.

b. Findings and Observations

There were no findings of significance.

The inspectors determined that Entergy continued to make progress in effectively implementing their corrective action plans, specific to the substantive cross-cutting issue in Problem Identification and Resolution related to implementation of corrective actions at Unit 2.

The inspectors observed progress made in developing and implementing a site-wide action plan to address the issue. The inspectors concluded that the performance improvement plan developed by Entergy was appropriately focused and sufficiently broad to address the cross-cutting aspect of implementation of corrective actions. Additionally, Entergy is approaching their corrective actions from a site-wide perspective (Units 2 and 3) and implemented changes in the processes and level of management review to ensure the issue was appropriately addressed for both units. Specific corrective actions identified by Entergy included the following: administrative procedure revisions to change corrective action tracking; revised procedure requirements for corrective action review board (CARB) review of level 2 and higher tier causal evaluations; revised corrective action requirements for post-closure CARB review of cause evaluations completed over the past year to include verification that that effectiveness reviews were scheduled, completed, and reviewed by CARB for all significant conditions adverse to quality and violations of regulatory requirements. The inspectors observed that these changes were implemented and further observed management review and challenge of several causal evaluations and effectiveness reviews.

Entergy developed performance indicators to track and trend the implementation of the corrective actions. The inspectors reviewed the data from the performance indicators and concluded that the performance indicators were effective and an indication that corrective actions were identifying areas for improvement. The inspectors also determined that Entergy conducted focused self assessments and benchmarking surveys as additional measures to verify planned actions were sufficiently effective.

4OA3 Event Followup

Main article: IP 71153

.1 (Closed) Licensee Event Report (LER) 05000247/2008-002-00, Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for an Inoperable Engineered Safety Feature Actuation System Automatic Actuation Logic and Actuation Relay Caused by Improper Relay Wiring

a. Inspection Scope

On March 28, 2008, Entergy identified an improperly wired safety injection (SI) logic relay during troubleshooting of a high resistance contact in the relay. Specifically, Entergy determined that 23 Containment Fan Cooler Unit (FCU) breaker was not wired to receive a closing signal from the SI relay associated with the electric bus that supplies 18 Enclosure its power. The 23 FCU is powered from bus 2A, and is designed to receive a sequenced start relay during an SI from the 2A bus SI relay. However, in this case, Entergy identified that 23 FCU would have received its start signal from the 5A bus SI relay. Therefore, if bus 5A was de-energized during an SI, 23 FCU would not receive an automatic sequenced start signal as designed. In this scenario, 23 FCU would still be available for manual start by the operators. Entergy determined the incorrect wiring configuration was a result of an improperly implemented design change by the original plant installer in 1973. The incorrect wiring was never detected during subsequent testing because all four safety bus SI relays are tested simultaneously during biannual SI blackout testing.

Entergy entered this issue into their corrective action program, corrected the relay wiring configuration, and performed an extent-of-condition review of other SI relays. No additional instances of incorrect wiring were identified. The inspectors reviewed the LER and verified the corrective actions were adequate. The enforcement aspects of this finding are discussed in section 4OA7. This LER is closed.

4OA5 Other Activities

.1 Implementation of Temporary Instruction (TI) 2515/176 - Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing

a. Inspection Scope

The objective of TI 2515/176, "Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing," is to gather information to assess the adequacy of nuclear power plant emergency diesel generator endurance and margin testing as prescribed in plant-specific technical specifications (TS). The inspectors reviewed emergency diesel generator ratings, design basis event load calculations, surveillance testing requirements, and emergency diesel generator vendor's specifications and gathered information in accordance with TI 2515/176.

The inspector assessment and information gathered while completing this TI was discussed with licensee personnel. This information was forwarded on to the Office of Nuclear Reactor Regulation for further review and evaluation.

b. Findings

No findings of significance were identified.

.2 TI 2515/173, Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative

a. Inspection Scope

An NRC assessment was performed the week of August 11, 2008 of Entergy's implementation of the Nuclear Energy Institute - Voluntary Ground Water Protection Initiative (dated August 2007, ADAMS Ref. No. ML072610036). Entergy evaluated work practices that could lead to leaks and spills, and performed an evaluation of systems, 19 Enclosure structures, and components that contain licensed radioactive material to determine potential leak or spill mechanisms.

Entergy completed a site characterization of geology and hydrology to determine the predominant ground water gradients and potential pathways for ground water migration from on-site locations to off-site locations. An on-site ground water monitoring program was implemented to monitor for potential licensed radioactive leakage into groundwater. The ground water monitoring results are being reported in the annual effluent and/or environmental monitoring report.

(http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html) Entergy prepared procedures for the decision making process for potential remediation of leaks and spills, including consideration of the long term decommissioning impacts. Records of leaks and spills are being recorded in Entergy's decommissioning files in accordance with 10 CFR 50.75(g).

Entergy identified appropriate local and state officials and conducted briefings on Entergy's ground water protection initiative. Protocols have been established for notification to these local and state officials regarding detection of leaks and spills.

b. Findings and Observations

No findings of significance were identified.

.3 Ground-Water Contamination Review

a. Inspection Scope

The inspectors reviewed plans, procedures, and remediation activities affecting the contaminated ground water condition at Indian Point, relative to NRC regulatory requirements, as authorized by the NRC Executive Director of Operations in a Reactor Oversight Process deviation memorandum dated December 19, 2007 (ADAMS Accession number ML073480290). The inspectors also reviewed Entergy's performance relative to remediation of the principal source of groundwater contamination including observation of the draining and sludge removal of the Unit 1 spent fuel pools, the radioactive waste processing of the fuel pool water and residual sludge materials, and reviewed the radioactive liquid effluent release accounting and dose calculations resulting from these activities. The inspection included onsite inspections on September 18, 2008; October 10, 2008; October 14-15, 2008; and November 17-18, 2008.

b. Findings and Observations

No findings of significance were identified.

Following the removal of Unit 1 spent fuel to dry cask storage, Entergy established special radioactive liquid processing and sampling equipment for conducting the drain down of the Unit 1 spent fuel pools. Between September 15, 2008 and November 7, 2008, approximately 500,000 gallons of water were drained and processed which included pool surface rinse water used during sludge removal activities. The liquid processing equipment was designed to clarify the pool water prior to discharge into the 20 Enclosure Hudson River. The liquid processing system consisted of a series of sequential processing modules which included a filter cartridge, a 25 ft³ mixed (cation and anion) demineralizer resin vessel followed by five 12.5 ft³ supplemental water polishing units consisting of an activated charcoal vessel, a cation demineralizer resin vessel, a mixed demineralizer resin vessel, a cesium-specific filter media vessel, and finally another activated charcoal vessel. The filtered and demineralized water was sampled by an automatic composite sampler for monitoring and analysis prior to the effluent stream release into the discharge canal. Residual sludge from the bottom of the spent fuel pools was mixed with water and sluiced into a 120 ft 3 polyethylene disposal container. Liquids were removed from this solid waste container by periodically pumping down the container through the self-contained dewatering system contained in the disposal container. These liquid wastes were subsequently processed through the same liquid processing system as described above, however, due to the potentially higher radioactive contaminants, the final processed water was redirected to a Unit 1 waste collection tank to allow for additional waste water treatment prior to discharge. The 120 ft 3 disposal container of solid waste was classified as Class B waste and will be stored onsite until an offsite disposal facility becomes available.

The inspectors determined that treated and discharged water was sampled and properly accounted by Entergy to result in less than 1 Curie of radioactivity discharged consisting mostly of tritium, and small amounts of Kr-85 and Cs-137. The resulting public dose associated from this liquid discharge activity was 0.00007 mrem to the whole body and 0.00012 mrem to the highest organ (teen/liver). The inspectors confirmed these values represented small fractions of the liquid discharge limits of 3 mrem/yr whole body and 10 mrem/yr maximum organ dose limits specified in 10 CFR 50, Appendix I.

4OA6 Meetings

Exit Meeting Summary

On January 9, 2008, the inspectors presented the inspection results to Mr. Joseph Pollock and other Entergy staff members, who acknowledged the inspection results presented. Entergy did not identify any material as proprietary.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by Entergy 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.

Technical Specification (TS) 3.6.6 requires, in part, a minimum of three trains of containment fan cooler units (FCU) to be operable in mode 1. Contrary to this requirement, the required number of FCUs was not operable in mode 1, assuming a single failure of one emergency diesel generator (EDG) to supply power to the 5A bus during a design basis accident, coincident with a loss of offsite power. Specifically, on March 28, 2008, Entergy identified an incorrect wiring configuration that would have prevented the automatic start of the 23 FCU. This condition, coincident with a single failure of an EDG during a design basis accident, coincident with a loss of offsite power, would have prevented the automatic start of at least three FCUs.

This issue was corrected on March 28, 2008 and entered into Entergy's corrective action 21 Enclosure program as IP2-2008-01482. The finding was more than minor because it was associated with the mitigating systems cornerstone and impacted the objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that this finding was of very low safety significance (Green) based on IMC 0609, Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," because the finding did not represent an actual loss of safety function of the FCUs for greater than their allowed outage time.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy Personnel

J. Pollock, Site Vice President
A. Vitale, General Manager, Plant Operations
P. Conroy, Director, Nuclear Safety Assurance
A. Williams, Manager, Operations
J.R. Beckman, Manager, Maintenance
T. Orlando, Manager, Engineering
B. Sullivan, Manager, Emergency Planning
S. Verrochi, Manager, System Engineering
R. Walpole, Manager, Licensing
D. Loope, Manager, Radiation Protection
F. Inzirillo, Manager, Quality Assurance
C. English, Superintendent, Unit 1
S. Sandike, Chemistry and Environmental Specialist
T. Stephens, Energy Solutions
R. Turner, Energy Solutions
R. Christman, Training Manager
J. Whitney, Emergency Diesel Generator System Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None.

Closed

05000247/LER-2008-002-00 LER Technical Specification Prohibited Condition Due to Exceeding the Allowed Completion Time for an Inoperable Engineered Safety Feature Actuation System Automatic
Actuation Logic and Actuation Relay Caused by Improper Relay Wiring (Section 4OA3)
Attachment

LIST OF DOCUMENTS REVIEWED

Indian Point Unit 2 Common Documents

Indian Point Unit 2 Control Room Narrative Logs Control Room Standing Orders Indian Point Unit 2 Updated Final Safety Analysis Report (UFSAR)

Section 1R01: Adverse Weather Protection

Procedures

OAP-048, Seasonal Weather Preparation
OAP-008, Severe Weather Preparations 2-COL-11.5, Space Heating and Winterization 2-COL-30.1, Electric Heat Tracing 2-AOP-FLOOD-1, Flooding

Condition Reports

IP2-2007-05291
IP2-2008-04096
IP2-2007-00884
IP2-2007-04853
IP2-2006-02133
IP2-2006-03406
IP2-2006-06311
IP2-2007-04332

Miscellaneous

Individual Plant Examination of External Events for Indian Point Unit No. 2

Section 1R04: Equipment Alignment

Procedure

2-COL-27.3.1, Diesel Generators
2-PT-Q028A, "21 Residual Heat Removal Pump," Rev. 18 2-SOP-4.2.1, "Residual Heat Removal System," Rev. 61 2-COL-4.2.1, "Residual Heat Removal System," Rev. 26 2-COL-10.1.1, "Safety Injection System," Rev. 32 2-COL-27.6, "Unit 2 Appendix R Diesel Generator," Rev. 0

Drawings

9321-2735
235296
251783

Miscellaneous

ARDG-003-APP-R, Restoration tagout dated 10/21/08

Section 1R05: Fire Protection

Procedures

2PT-2Y017, Penetration Fire Barrier Seal Inspections 2-PT-EM19, Cable Spreading Room Halon Testing
PT-EM28, Fire Dampers Operability
SAO-703, Fire Protection Impairment Criteria and Surveillance
EN-DC-161, Control of Combustibles
Attachment

Condition Reports

IP2-2008-04245
IP2-2008-04657
IP2-2008-04888
IP2-2008-04962
IP2-2008-05090
IP2-2008-05551

Drawings

400401-04, Fire Area/Zone Arrangement at
EL 15'
400404-02, Fire Area/Zone Arrangement at
EL 80' Orders
IP2-03-31785
IP2-05-21166
51645811

Miscellaneous

Indian Point Nuclear Generating Station, Unit 2, Fire Protection Program Plan, Rev. 9 Indian Point Pre-Fire Plans Unit 2 - Nuclear
IP2-RPT-03-00015, "IP2 Fire Hazards Analysis," Rev. 3

Section 1R11: Licensed Operator Requalification Program

Procedures

EN-TQ-201, Systematic Approach to Training Process, Rev 4
IP-SMM
TQ-114, Continuing Training & Requalification Examinations for Licensed Personnel, Rev 7
OAP-032, Operations Training Program, Rev 9
OAP-033, Conduct of Operations Simulator Training, Evaluations, and Debriefs, Rev 4 2-AOP-FW-1, "Loss of Main Feedwater," Rev. 11
2-AOP-SG-1, "Steam Generator Tube Leak," Rev. 10

Miscellaneous

LRQ Sample Plan for 2007 Comprehensive Written Exam 12SG-LOR-AOP014, Instrument/Controller Failures Lesson Plan, Rev 2 12LP-LOR-AOP009, Containment Integrity, RCS Activity, & Air System Malfunction Lesson Plan, Rev 0

Section 1R12: Maintenance Effectiveness

Procedures

EN-DC-203, Maintenance Rule Program
EN-DC-205, Maintenance Rule Monitoring
EN-DC-324, Preventive Maintenance Process 0-SYS-401-Gen, "Application of Protective Coatings," Rev. 1

Condition Reports

IP2-2008-04472
IP2-2008-04709
IP2-2008-04342
IP2-2008-04228
IP2-2008-04112

Work Orders

00164495

Miscellaneous

NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants Service Water System Health Report, 3Q 2008
Attachment Maintenance Rule Basis Document - Service Water
IP2-UT-08-085, UT erosion/corrosion examination line #1505
IP2-UT-08-086, UT erosion/corrosion examination line #1505
IP2-UT-08-087, UT erosion/corrosion examination line #1509
IP2-UT-08-088, UT erosion/corrosion examination line #1509
IP2-UT-08-089, UT erosion/corrosion examination line #1509

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

2-PT-R084C, 23 EDG 8 Hour Load Test
IP-SMM-WM-101, On-Line Risk Assessment

Condition Reports

IP2-2008-04812

Work Orders

51570202
00156016
51570202
00156016

Miscellaneous

TS 3.8.1.10 Note 2 Assessment for U2 EDG 8 Hour Runs in Mode 1 Indian Point Daily Status Reports for October 1, 2, and 3, 2008 EOOS Risk Model Operator's Risk Report for Unit 2 on 10/2 and 10/3, 2008
Week 0840 Unit 2 Operator's Risk Report.

Section 1R15: Operability Evaluations

Procedures

3-PMP-003-CCW, Inspection/Repair of the Component Cooling Pump

Drawings

242688
235306
21-2723

Condition Reports

IP2-2008-04921
IP2-2008-03041
IP2-2008-04495
IP2-2008-04351
IP2-2008-04951

Work Orders

51668324
00149226

Miscellaneous

Vendor manual - Ingersoll Rand "S" Line General Service Pumps

Section 1R18: Plant Modifications

Procedures

EN-DC-136, Temporary Modifications
Attachment

Condition Reports

IP2-2008-04898

Work Orders

00174868

Drawings

Sketch "A"
TM-12305

Miscellaneous

Indian Point Unit 2 Maintenance Rule Document - 138 kVAC Electrical System Vendor manual - 1380-SF-10000 series electrical breaker TMOD No:
EC 12305, Install Nitrogen connection at
BT4-5 air compressor tank.

Section 1R19: Post-Maintenance Testing

Procedures

2-BRK-021-CUB, Westinghouse 480V DB Series Breaker Cubicle Inspection and Cleaning
0-HTX-405-EDG, EDG Lube Oil and Jacket Water Heat Exchanger Maintenance 2-IC-PC-I-P-1139, "Auxiliary Boiler Feed Pump No.22 Steam Supply Controller," Rev. 0
OAP-24, "Operations Testing," Rev. 3
PFM-44, "Generic Inservice Pressure Test Program," Rev. 3 2-BRK-001-ELC, "ITE Type KC, Model G-Air Circuit Breaker," Rev. 0

Condition Reports

IP2-2008-05089

Work Orders

270253
51670696
51606970
00137722
00173188
51644972
51655457
51315478
51672218

Drawings

226033
251231
251232 9321-2017 9321-2125
208088
244016

Miscellaneous

Conoflow Regulators and Controls Instruction and Maintenance Manual, GP50 series

Section 1R22: Surveillance Testing

Procedures

2-PT-Q035B, 22 Containment Spray Pump Test 2-PC-2Y55, Containment Sump Discrete Level Instrumentation 2-ES-1.3, Transfer to Cold Leg Recirculation 2-E-1, Loss of Reactor or Secondary Coolant
2-NF-309, RCS Delta-T, T-Avg and Flow Measurement 2-PT-V59, "Reactor Trip Breaker "A" Changeout and Functional Test," Rev. 4 2-PC-4Y74C, "Nuclear Instruments Power Range N-43," Rev. 1
PT-Q13, "Inservice Valve Tests", Data Sheet 38 - valve 869B, Rev. 21
Attachment

Condition Reports

IP2-2008-04852
IP2-2008-04380
IP2-2008-04450
Orders
51570801
00164350
51298850

Miscellaneous

EC 3714, Replacement of
LT-3300 and
LT-3301 and Addition of PICS input from
LT-939 and
LT-941
IP2-RHR/SIS DBD, Residual Heat Removal and Safety Injection Design Basis Document

Section 1EP2: Alert and Notification System (ANS) Evaluation

Procedures

Command and Control Alert Notification Testing, October 22, 2008

Section 2OS3: Access Control to Radiologically Significant Areas

Procedures

EN-CY-108, Rev. 2, Monitoring of Non-Radioactive Systems
EN-RP-113, Rev. 2, Response to Contaminated Spills / Leaks
EN-RP-303, Rev. 2, Source Check Radiation Protection Instrumentation
EN-RP-306, Rev. 2, Calibration and Operation of the Eberline
PM-7
EN-RP-309, Rev. 1, Operation and Calibration of the Eberline
AMS-3 / 3A Continuous Air
Monitor
EN-RP-501, Rev. 3, Respiratory Protection Program
EN-RP-502, Rev. 4, Inspection and Maintenance of Respiratory Protection Equipment
IP-EP-AD6-20, Rev. 2, Respiratory Protection Monthly Equipment Inventory
IP-EP-AD6-21, Rev. 3, Respiratory Protection Quarterly Equipment Inventory
IP-RP-IC-301, Rev. 1, Calibration of the Eberline
AMS-4 Air Monitoring System Using Windows
IP-SMM-CY-001, Rev. 6, Radioactive Effluents Control Program
RE-ADM-1-22, Rev. 0, Site Soil Characterization
RE-INS-7CC-1, Rev. 12, Calibration of the Eberline
AMS-2 Beta-Gamma Air Monitor
RE-INS-7CC-7/8, Eberline
PING-1A Calibration Record
RE-INS-7CH-3, Rev. 10, Calibration of the Merlin-Gerin
CDM-21 Electronic Dosimeter
Calibrator Using WCDM 2000
RE-INS-7CH-4, Rev. 5, Characterization of the J.L. Shepherd 81-12, 142-10 and 149 Sources
RE-INS-7UH-12, Rev. 10, Beam Source Check Sheet 0-RP-IC-101, Rev. 2, Calibration of Portable Ion Chamber Survey Meters 0-RP-IC-102, Rev. 0, Calibration of the Eberline
ASP-1 with Neutron Detector 0-RP-IC-301, Rev. 1, Calibration of the Eberline
AMS-4 Air Monitoring System Using Windows 0-RP-IC-402, Rev. 1, Calibration and use of the MGP Telepole 0-RP-IC-601, Rev. 0, Calibration of the Tennelec
LB-5100 Alpha-Beta Counting System Using
Eclipse 0-RP-IC-603, Rev. 0, Interchangeable Counting Room Calibration with
HP-300 0-RP-IC-604, Rev. 0, Calibration of the Eberline Model
BC-4 Beta Counter
0-CY-1420, Rev. 2, Radiological Quality Assurance Program 0-CY-1510, Rev. 4, IPEC Storm Drain Sampling 0-CY-1900, Rev. 0, Nuclear Environmental Monitoring Sampling and Analysis Schedule 0-CY-2740, Rev. 1, Liquid Radioactive Effluents Attachment
2-PC-R25, Rev. 15, Main Steam Line Radiation Monitor Detector Calibration (R-28, 29, 30, 31) 2-PC-R38-1, Rev. 3, High Range Containment Area Radiation Monitor (R-25) 2-PC-R38-2, Rev. 2, High Range Containment Area Radiation Monitor (R-25) 2-PC-R38-3, Rev. 3, High Range Containment Area Radiation Monitor (R-26) 2-PC-R38-4, Rev. 2, High Range Containment Area Radiation Monitor (R-26) 2-PC-R15B, Rev. 17, VC Area Radiation Monitor Calibration (R-7)
2-PC-EM4, Rev. 12, Non-VC Area Radiation Monitors Calibration 2-PC-EM30, Rev. 10, Process Radiation Monitor Calibration (R-41, 42) 2-PC-2Y23, Rev. 10, Liquid Radiation Monitor Calibration 3-CY-2325, Rev. 6, Radioactive Sampling Schedule 3-IC-RMP-R-7, Rev. 0, Calibration of Radiation Monitor R-7
3-PC-R40, Rev. 17, Main Steam Line Radiation Monitor Calibration (R-62) 3-PC-OL-48, Rev. 4, Fuel Storage Building Radiation Monitor Calibration (R-5) 3-PC-R46A, Rev. 15, Containment High Range Radiation Monitor Calibration (R-25) 3-PC-R46B, Rev. 14, Containment High Range Radiation Monitor Calibration (R-26) 3-PC-OL-58A, Rev. 2, Process Radiation monitors R11/12 Calibration 3-PC-OL-49A, Rev. 2, Steam Generator Blow down Radiation Monitor Calibration (R-19)

Condition Reports

IP2-2007-04816
IP2-2007-04818
IP2-2008-00055
IP2-2008-00405
IP2-2008-00601
IP2-2008-00770
IP2-2008-01236
IP2-2008-01262
IP2-2008-01391
IP2-2008-01463
IP2-2008-01760
IP2-2008-01823
IP2-2008-02000
IP2-2008-02504
IP2-2008-02621
IP2-2008-02739
IP2-2008-03659
IP2-2008-03661
IP2-2008-03798
IP2-2008-04192
IP2-2008-04428
IP2-2008-05074
IP2-2008-05410
IP2-2008-05411
IP2-2008-05412
IP2-2008-05483
IP2-2008-05516
IP3LO-2008-00069
IP3-2008-00314
IP3-2008-00484
IP3-2008-00516
IP3-2008-00705
IP3-2008-00729
IP3-2008-01454
IP3-2008-01464
IP3-2008-01815
IP3-2008-02117
IP3-2008-02566
IP3-2008-02851
IP3-2007-04640

Miscellaneous

LCOTR # 2-TS-08-0923 IPEC Radiation Monitoring System Top Ten Technical Issues Action Plan, updated 12/17/08
IPEC Radiation Monitoring System Long Range Plan Plan, updated 12/17/08 IPEC Radiation Monitoring System Condition Report Trend Review, updated 12/17/08 RMS Maintenance Improvement Plan, updated 12/17/08 Units 2 and 3 System Health Report for 2008 ER No. 04-2-042, R-41 / 42 Reliability Improvements Engineering Review package Radiation Monitor, Portable Radiation Monitoring Instrumentation, and Calibrator Calibration
Sheets C.A.R.E Authorized Repair Center Certifications DUKE / NUPIS Member Audit Report of General Engineering Laboratories, LLC (GEL) IPEC: Nuclear Energy Institute Groundwater Protection Initiative Self Assessment Checklist, dated July 2008.

Section 4OA1: Performance Indicator Verification

Procedures

EN-EP-201, "Performance Indicators," Rev. 6
EN-LI-114, "Performance Indicator Process," Rev. 3
NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Rev. 5
Attachment

Section 4OA2: Identification and Resolution of Problems

Procedures

EN-LI-102, Corrective Action Process
EN-LI-119, Apparent Cause Evaluation (ACE) Process
SOP-27.3.1.1, 21 Emergency Diesel Generator Manual Operation
ICPM-0708-1, 13.8 KV L&P bus section 3 partial differential relays (87B2-A/B/C)
3-REF-003-Gen, Reactor Core Refueling
SOV-003-ELC, Inspection and Testing of Target Rock Solenoid Operated Valves
EN-LI-122, Common Cause Evaluation
EN-LI-119, Apparent Cause Evaluation (ACE) Process
EN-LI-102, Corrective Action Process
EN-OP-117, Operations Assessments
3-SOP-NI-001, Excore Nuclear Instrumentation System Operation 2-SOP-ESP-001, Local Equipment Operation and Contingency Actions 3-PT-M079C, 33 EDG Functional Test 2-E-0, "Reactor Trip or Safety Injection," Rev. 0
EN-DC-185, Through-Wall Leaks in ASME Section XI Class 3 Moderate Energy Piping

Condition Reports

IP2-2008-03144
IP2-2008-03869
IP2-2008-03901
IP2-2008-04246
IP2-2008-03869
IP2-2008-04425
IP2-2008-04576
IP2-2008-04893
IP3-2008-02026
IP3-2008-02758
IP2-2006-06939
IP2-2007-00259
IP2-2007-01599
IP2-2007-03706
IP3-2007-03619
IP3-2007-00453
IP2-2008-01056
IP2-2008-03671
IP2-2008-02907
IP2-2008-02624
IP2-2008-02725
IP2-2008-03511
IP2-2008-03956
IP2-2008-04020
IP2-2008-01057
IP2-2008-03330
IP2-2008-03309
IP2-2008-03310
IP2-2008-00389
IP2-2008-00464
IP3-2008-00640 IP3 2008-01285
IP3-2008-01745
IP3-2008-02137
IP3-2008-03013 IP3LO-2008-00004 IP3LO-2008-00111 IP3LO-2008-00143 IP3LO-2008-00172 IP3LO-2008-00178 IP3LO-2008-00179 IP3LO-2008-00180
HQN-2008-00339
LO-WTIPC-2008-00043

Work Orders

00145055
51320416
00174762
51247771
00170717

Miscellaneous

IPEC Engineering Department Quarterly Trend Report 2Q 2008
IPEC Engineering Department Quarterly Trend Report 3Q 2008 IPEC Maintenance Department Quarterly Trend Report 2Q 2008 IPEC Maintenance Department Quarterly Trend Report 3Q 2008 IPEC Corrective Action and Assessment Department Quarterly Trend Report 3Q 2008 NRC
IR 05000247/2008001 & 05000286/2008001 "Annual Assessment Letter - Indian Point Nuclear Generating Units 2 and 3" Dated March 3, 2008 NRC "Mid Cycle Performance Review and Inspection Plan - Indian Point Nuclear Generating Station Units 2 and 3" dated September 2, 2008. NRC Inspection Report 05000247/2008010 "Indian Point Nuclear Generating Station Unit 2- NRC Problem Identification and Resolution Inspection Report" dated July 24, 2008 10
CFR 50.72 ,"Immediate Notification requirements for Operating Nuclear Power Reactors"
Indian Point Energy Center Procedure Adequacy Cross-Cutting Issue Resolution Plan Rev 4 Dated September 9, 2008
Attachment Indian Point Energy Center Procedure Adequacy Cross-Cutting Issue Resolution Plan Revs 0-3 Maintenance Department Procedure Improvement Plan (No date) Human Performance Training Plan and slides "Doer, Reader, Peer Checker, and Pilot" exercise. Human Performance Training Plan and slides "Human Performance for IPEC Personnel" Operations Procedure Upgrade Project Communications plan for Operations personnel. Procedure Adequacy Cross-Cutting Resolution Plan Slideshow dated 10/20/08

Procedure

Adequacy Cross-Cutting Resolution Plan Slideshow update dated 12/5/08 Plant Operating Procedures (POP) Procedure Upgrade Project Plan dated 9/9/08 Plant Operating Procedures (POP) Procedure Upgrade Project Plan Rev 2 dated 10/26/08 Performance Indicators and worksheets for Procedure Workdown Curves, Procedure Feedback Forms, NRC Findings, Equipment Reliability, and Preventive Maintenance Completion.
Indian Point Units 2 and 3 Summary of Findings/ Violations Report dated 12/1/08 Equipment Reliablility Index Performance Indicator Guidance Book Revision 4 and Data CAP Improvement Plan-IPEC Unit 2 Cross Cutting Issue PI&R slide show dated 12/1/08 Human Performance Cross Cutting Resolution Plan Presentation dated 12/2/08 IPEC Open CR Inventory Report run 12/1/08 IPEC CRG Summary Agenda Report for 12/2/08 IPEC CARB Meeting Agenda Report for 12/2/08
ASME Code Case N-513-2, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1

Section 4OA3: Event Followup

Condition Report

IP2-2008-01482
IP2-2008-01537

Work Orders

00145619

Section 4OA5: Other Activities

Completed Surveillance Procedures
2-PT-M021A, Rev. 17, Emergency Diesel Generator 21 Load Test, completed July 14, August 14, and September 8, 2008 2-PT-M021B, Rev. 17, Emergency Diesel Generator 22 Load Test, completed July 17, August 12, and September 10, 2008 2-PT-M021C, Rev. 15, Emergency Diesel Generator 23 Load Test, Completed July 16, August 12, and September 11, 2008 3-PT-M079A, Rev. 36, 31 EDG Functional Test, completed July 8, August 6, and September 4, 2008 3-PT-M079B, Rev. 37, 32 EDG Functional Test, completed July 9, August 6, and September2, 2008 3-PT-M079C, Rev. 36, 33 EDG Functional Test, completed July 11, August 8, and September 3, 2008

Procedures

2-PT-R084A, Rev. 13, 21 EDG 8 Hour Load Test 3-PT-R160A, Rev. 11, 31 EDG Capacity Test

Miscellaneous

EnergySolutions Procedure
FP-FO-WI-001, Rev. 0, Spent Fuel Pool Cleaning at Indian Point Attachment Unit 1 Entergy Procedure 1-RP-RWM-913, Rev. 1, Unit 1 Fuel Handling Building West Pool 24/7 Demineralizer System Entergy Work Order
00123484 10, Modifications to the FHB West Pool Demineralization System
FEX-00039-02, Emergency Diesel Generator Loading Study
IP3-CALC-ED-00207, Rev. 7, 480 V Bus 2A, 3A, 5A, & 6A and EDGs 31, 32 & 33 Accident Loading Indian Point Nuclear Generating Unit No. 2 Updated Final Safety Analysis Report, Chapter 8, Rev. 20 Indian Point Nuclear Generating Unit No. 3, Updated Final Safety Analysis report, Chapter 8, Rev. 02, 2007 Emergency Diesel Generator Design Basis Document for Indian Point Unit 2, Rev. 1 Entergy Letter
NL-07-038, dated March 22, 2007, Proposed changes to Indian Point 2 Technical Specifications Regarding Diesel Generator Endurance Test Surveillance
Entergy Letter
NL-08-139, dated September 29, 2008, Reply to Request for Additional Information Regarding Indian Point Unit 2 Proposed Changes to Technical Specifications Regarding Diesel Generator Endurance Test Surveillance (TAC No.
MD9214) Entergy Letter
NL-08-157, dated October 8, 2008, Supplement to Reply to Request for Additional Information Regarding Indian Point Unit 2 Proposed Changes to Technical Specifications Regarding Diesel Generator Endurance Test Surveillance (TAC No. 9214) Entergy Letter
NL-08-160, dated October 13, 2008, Proposed Exigent License Amendment to Revise Technical Specification Surveillance Requirement 3.8.1.10 Frequency Regarding Diesel Generator Endurance Test NRC Letter dated October 20, 2008, Indian Point Nuclear Generating Unit No. 2 - Issuance of Exigent Amendment Re: Surveillance Interval for Diesel Generator Endurance Test (TAC No. MD9845)
MI-11272C, Engine Maintenance Schedule, Nuclear Standby Engines developed by ALCO Owner's Group and FM/ALCO Indian Point Nuclear Generating Unit No. 2 Technical Specifications, Section 3.8, Electrical Power Systems, through Amendment 255 Indian Point Nuclear Generating Unit No. 2 Technical Specifications Bases, Section 3.8, Electrical Power Systems, Rev. 2 Indian Point Nuclear Generating Unit No. 3 Technical Specifications, Section 3.8, Electrical Power Systems, through Amendment 226 Indian Point Nuclear Generating Unit No. 3 Technical Specifications Bases, Section 3.8, Electrical Power Systems, Rev. 3
Attachment

LIST OF ACRONYMS

ABFP auxiliary boiler feed pump
ADAMS Agency-wide Document and Management System
ANS alert and notification system
ASME American Society of Mechanical Engineers
CA corrective actions
CARB corrective action review board
CEDE committed effective does equivalent
CFR Code of Federal Regulations
CR condition report
EDO Executive Director of Operations ENTERGY Entergy Nuclear Northeast
EP Emergency Preparedness
FCU containment fan cooler unit
IMC Inspection Manual Chapter
IPEC Indian Point Energy Center
IPEEE Internal Plant Examination of External Events
JPM job performance measures
LER licensee event report
MSPI Mitigating System Performance Indicator
NCV non-cited violation
NDE non-destructive examination
NRC Nuclear Regulatory Commission
NRR Nuclear Reactor Regulation
PARS Publicly Available Records System
PI performance indicator
PIM plant issues matrix
RHR residual heat removal
SCBA self-contained breathing apparatus
SCCI substantive cross-cutting issue
SDP significance determination process
SG steam generator
SI safety injection
SSC structures, systems, and components
TI temporary instruction
TS Technical Specification
UFSAR Updated Final Safety Evaluation Report
URI unresolved item WO work order
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