IR 05000286/2011010

IR 05000286/2011010; 07/18/11-08/05/11; Indian Point Nuclear Generating (Indian Point) 3; Biennial Baseline Inspection of Problem Identification and Resolution

ML112570059
Person / Time
Site:	Indian Point
Issue date:	09/14/2011
From:	Mel Gray Reactor Projects Branch 2
To:	Joseph E Pollock Entergy Nuclear Operations
References
IR-11-010
Download: ML112570059 (29)

Text

{{#Wiki_filter:UNITED STATES N UCLEAR REGU LATORY COMMISSION

REGION I

475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406.1415 September 14, 2OII Mr. Joseph Site Vice President Entergy Nuclear Operations, lnc.

lndian Point Energy Center 450 Broadway, GSB Buchanan. NY 1051 1-0249 INDIAN POINT NUCLEAR GENERATING UNIT 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000286/2011010

Dear Mr. Pollock:

On August 5,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Uriit 3. The enclosed report documents the inspection results, which were discussed on August 5,2011, with you and other members of your staff.

This inspection examined activities conducted under your license as they relate to the identification and resolution of problems and compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the samples selected for review, the inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Entergy personnel identified problems and entered them into the Corrective Action Program (CAP) at a low threshold.

Station personnel generally screened issues appropriately for operability and reportability, and prioritized issues commensurate with the safety significance of the problems. Corrective actions addressed the identified problems and were typically implemented in a timely manner.

This report documents two NRC-identified findings of very low safety significance (Green). The inspectors determined that one of the findings also involved a violation of NRC requirements.

However, because of its very low safety significance and because it was entered into your CAP, the NRC is treating this as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy, lf you contest this NCV, 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 Senior Resident Inspector at Indian Point Nuclear Generating Unit 3. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region 1, and the NRC Senior Resident Inspector at Indian Point Nuclear Generating Unit 3. ln 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 or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://rnnrrrw.nrc.sov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, k/'-A -V^oy.- MelGray, Chief

     ,r Projects Branch 2 Division of Reactor Projects Docket No. 50-286 License No. DPR-26 Enclosure: Inspection ReportNo. 05000286/2011010 M Attachment: Supplemental lnformation

SUMMARY OF FINDINGS

lR 050002g612011a10;7118111 - 815t11; Indian Point Nuclear Generating (lndian Point) unit 3; Biennial Baseline lnspection of Problem ldentification and Resolution. The inspectors identified two findings in the area of effectiveness of identification and prioritization of issues.

This NRC team inspection was performed by two resident and two region-based inspectors.

also determined Two findings of very low significance (Green) were identified. One finding was to be a non-cited violation [Ncvy of trtilc requirements. The significance of most findings is Manual Chapter (lMC)indicated by their color (Grben, \rvhite, Yellow, Red) using Inspection

       ,,significance Determination Process." Findings for which the significance determination 0609, process tsopl does not apply may be Green, or be assigned a severity level after NRC using IMC management ieview. The cross-cutting aspects for the findings were determined fng    NRC's    program    for   overseeing      safe 0310, "Components within the Cross-Cutting Areas.'

in NUREG-1649, "Reactor operation of commercial nuclear power reactors is described Oversight Process," Revision 4, dated December 2006' ldentification and Resolution of Problems and The inspectors concluded that Entergy was generally effective in identifying, evaluating, resolving problems. Entergy personnet iOeniified problems, entered them into the corrective action piogram at a low thre*shold, and prioritized issues commensurate with their safety issues,for operability significancl. In most cases, Entergy personnel appropriately screened extent of arid reportability, and performed ca-usal analyses that appropriately considered that condition, generic issues and previous occuirences. The inspectors also determined actions to address the problems identified in the Entergy stJff typically implemented corrective the inspectors identified two findings, corrective action pro6t"r in a timely manner. However, one of which was als-o a violation of regulatory requirements, and several weaknesses of minor and prioritization of safety significance associated with pro-blem identification, evaluation, corrective actions.

and applied The inspectors concluded that, in general, Entergy adequately identified, reviewed, relevant industry operating experience to Indian Point Nuclear Generating Unit 3 operations' In inspectors determined that Entergy's addition. based on those ilems selected for review, the audits and self-assessments were thorough.

inspection, Based on the interviews the inspectors conducted over the course of the reviews of individual cAP and employee concerns program observations of plant activities, and unwilling to raise issues, the inspectors did not identify any indications that site personnel were have had a negative impact on the site's safety l.ru", nor oio they identify conditions that could safety conscious work environment.

Cornerstone: Mitigating SYstems

 .

Green.

The inspectors identified a finding of very low safety significance (Green) because of EN-DC-Entergy personnel did not adequately imptemeni the procedural requirements

           ,ngineering Change Process,'i during the installation of a modification to the 33 1 15, fuses in the instrument air deiiccantiryer. Specifically, Entergy staff incorrectly replaced fuses, rather than motor control center(MCC] which powers the dryer with smaller capacity replacing existing control power fuses in the dryer control panel with fuses of increased As  a  result, the  fuses    in  the   MCC      performed capacityl as inteided by the design change.

the dryer, and leading to excessive their intended function ind burned out, deenergizing Entergy staff unavailability of the dryer and high humidity air in the instrument air header.

                                                                                            (cR)-lP3-2011-entered this issue into their corrective action process as condition report 03798.

was similar The inspectors determined the finding was more than minor because the finding with example 5 b of Inspection Manual to the'more than minor if'statement associated the finding was Chapter (lMC) 0612 Appendix E, "Examples of Minor lssues." Additionally, attribute of the more than minor because it was associated with the Equipment Performance ensure the Mitigating Systems cornerstone and affected the cornerstone objective to prevent undesirable availability and capability of systems that respond to initiating events to the unavailability of the 33 instrument air con""qu"nces (i.e., core damage). Specifically, turn led to high humidity and low dryer caused moist air in the instrument air heider which in prersrre alarms on the 33 instrument air header. The inspectors_ evaluated the finding of using IMC 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization the Findlngs," and determined the finding was of very low safety significance because of system safety finding was not a Jesign or qualificaiion deficiency, did not represent a loss potentially risk significant due to external initiating events.

functi5n, and did not sireen as associated with This finding had a cross-cutting aspect in tne arel of Human Performance, personnel did not adequately coordinate the Work Controf attribute. Specifically, Entergy planning and implementaiion of tne engineering change process, which involved several the missed site departments, and resulted in incorrectly installed fuses and multiple opportunities to both prevent and identify the error. (H'3(b)) (Section aOA2'1'c(1)) .

Green.

The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix corrective actions B, Criterion XVl, "Corrective Action," for Entergy's failure to take adequate pipes to the emergency diesel for a condition adverse to quality involving service water (SW)generators (EDGs). Speciiically, Entergy personnel did not take timely and appropriate supply lines to the corrective actions ior carbon steel pipe wall thinning on the common SW corrective action process as condition EDGs. Entergy staff entered this issue into their a structural report (cR)-lCa-201 1-03g31 . Entergy's short-term corrective actions included the source of continual wetting, engineering inspection, an operabilit--y evaluation, redirecting to this inspection, anI reprior-itizinblnl sw piping refuibishment work order. subsequent of the pipes that Entergy personiel performed Jltrasonic testing of the affected area on one operable.

they fincluded was most affected and confirmed that the pipe remained performance deficiency had The finding was more than minor because if left uncorrected the i^.,!^^ .^,n{{inn Specifically,.the continuing wetting the potentLl to lead to a more significant safety concern. .' 'l.l raraahr monitoring. could adversely and associated external corrosion of the pipe without appropriate

                                                                                                                 ^ll.

Ttte^inspectors impact the structural integrity of one or both EDG SW supply headers'

                                                                                       (lMC) 9609'

evaluated the findin! in aicordance with lnspection Manual Chapter "Phase 1 - initial Screening and Characterization of Attachment 0609, Attachment 4, very low safety significance (Green) because it Findings," and determined the finding was of represent a loss of system safety was not a design or lualification def[iency, did not This finding had a function, and was noi risk significant with iespect to external events' cross-cutting aspect in the irea of problem ldentification and Resolution, associated with did not take timely the corrective Action Program attribute. specifically, Entergy personnel corrective actions to address SW carbon steel pipe wall thinning due to external corrosion and periodically monitor the pipe for further degradation, commensurate with the safety significance of the pipe. (P.1(d)) (Section 4OA2'1 .c(2))

REPORT DETAILS

4OA2 Problem ldentification and Resolution (71152B- - 1 sample)

This inspection constitutes one biennial sample of problem identification and resolution this as defined by Inspection Procedure71152. All documents reviewed during inspection are listed in the Attachment to this report'

.1 a.

Inspection ScoPe The inspectors reviewed the procedures that described Entergy's corrective action program at Indian point Unit 3. To assess the effectiveness of the corrective action pro!r"t, the inspectors reviewed performance in three primary areas: problem iOeititication, prioritization and evaluation of issues, and corrective action implementat'on. The inspectors compared perfo_rmance in these areas to the (10 requirements and standards contained in Title 10, Code of Federal Regulations "Corrective Action," and Entergy's procedure Cfnl part 50, Appendix B, Criterion XVl, EN-LI-102, "Coriective Action Process," Revision 16.

For each of these areas, the inspectors'considered risk insights from the station's risk analysis and reviewed in the NRCs condition reports (CRs) selectid across the seven cornerstones of safety process.

Additionally, the inspectors attended multiple Operations Reactor Oversighi Action Review Board (CARB) Focus, Condition Review Group (CRG);and Corrective following functional areas for review: meetings. The inspectors selected items from the preparedness, radiation protection' engine6ring, operations, maintenance, emergency chemistry, physical security, and oversight programs'

(1) Effectiveness of Problem ldentification of completed ln addition to the items described above, the inspectors reviewed a sample surveillance test corrective and preventative maintenance work orders, completed procedures, operator logs, and periodic trend reports. The inspectors also completed (SW)' auxiliary field walkdowns of vario-us plani systems, such as the service water reviewed a feedwater (AFW), and instrument air systems. Additionally, the inspectors slmpte of condition reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience verify that Entergy staff entered frogr"r. The inspectors c5mpleted this review toaction program as appropriate' conditions adverse to quality into their corrective

(2) Effectiveness of Prioritization and Evaluation of lssues The inspectors reviewed the evaluation and prioritization of a sample of cRs issued problem ldentification and Resolution inspection completed since the last NRC biennial assigned lower levels of in June 2009. The inspectors also reviewed cRs that were that they were iign6i"un"e that did not include formal cause evaluations to ensure properly classified. The inspectors' review included the appropriateness of the assigned significince, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues'

(3) Effectiveness of Corrective Actions The inspectors reviewed Entergy's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Entergy's timeliness in implemeniing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CRs associated with non-cited violations (NCVs) and findings to verify that Entergy personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Entergy's actions related to conditions adverse to quality associated with SW system corrosion, instrument air system performance, and AFW system performance' b.

Assessment

(1) Effectiveness of Problem ldentification Based on the selected samples reviewed, plant walkdowns, and interviews of site personnel, the inspectors determined that Entergy personnel identified problems and entered them into the CAP at a low threshold. For the issues reviewed, the inspectors determined that problems or concerns were generally documented in sufficient detail to understand the issues. The inspectors observed managers and supervisors at CRG and CARB meetings appropriately questioning and challenging CRs to ensure clarification of the issues. The inspectors determined Entergy personnel trended equipment and programmatic issues at low levels and CR descriptions appropriately included reference io repeat occurrences of issues. ln general, the inspectors did not identify issues or concerns that had not been appropriately entered into the CAP for evaluation and resolution. However, the inspectors identified the following example of a minor issue that was not adequately identified by Entergy staff. Entergy staff promptly entered the issue into the CAP for resolution.

     .

The inspectors identified that Entergy personnel performed maintenance on three AFW 1ow control valves during tne 2Ot 1 refueling outage, but did not perform the required post maintenance tests (PMTs) on the valves prior to declaring the AFW system operable. The inspectors also identified the PMTs were not correctly scheduled to be completed after the maintenance that occurred during the outage' The inspectors noted that Entergy personnel subsequently satisfactorily stroked the valves during the next normally scheduled, quarterly AFW in-service testing approximately one week later.

The inspectors determined that the missed PMT for the valves was a performance deficiency. However, because the subsequent valve stroke times a week later indicated that the AFW valves were operable, the inspectors determined that the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. Entergy staff initiated CR-IP3-2011-03815 for this performance deficiency.

(2) Effectiveness of Prioritization and Evaluation of lssues The inspectors determined that, in general, Entergy personnel appropriately prioritized and evaluated issues commensurate with their safety significance. CRs were screened for operability and reportability, categorized by significance, and assigned to a department for evaluation and resolution. The CR screening process considered human performance issues, radiological safety concerns, repetitiveness, and adverse trends.

The inspectors observed managers and supervisors at CRG and CARB meetings appropriately questioning and challenging CRs to ensure appropriate prioritization.

The inspectors determined that CRs were generally categorized for evaluation and resolution commensurate with the significance of the issues. Based on the sample of CRs reviewed, the guidance provided by the Entergy implementing procedures appeared sufficient to ensure consistency in categorization of the issues. Operability and reportability determinations were generally performed when conditions warranted and the evaluations supported the conclusions. Causal analyses appropriately considered the extent of the condition or problem, generic issues, and previous occurrences of the issue.

Notwithstanding these conclusions, the inspectors identified the following example where the evaluation of a repeat issue was not commensurate with the potential significance of the issue.

e Based on a nuclear plant operator (NPO) log and CAP database review, the inspectors noted that on several occasions NPOs documented degraded conditions regarding roof leaks and housekeeping issues in the primary auxiliary building (PAB)during the week of July 3, 2011. Further, the inspectors noted that some of these conditions had existed for six months. The inspectors determined that Entergy staff missed an opportunity to trend these conditions and ensure conditions were appropriately addressed in a timely manner consistent with CAP expectations.

However, because none of the leaks or housekeeping conditions challenged or impacted equipment important to safety, the inspectors determined that the issues were of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. Entergy staff documented this issue in CR-lP3-2011-03295.

I

(3) Effqcjivene,ss oJ C-orrective Aptions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, corrective actions were identified to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective.

The inspectors noted, based on the samples inspected, that Entergy staff completed effectiveness reviews for significant issues to verify that implemented corrective actions were effective. However, the inspectors identified two issues (replacement of incorrect fuses associated with the 33 instrument air dryer, and ineffective actions taken to address leakage from a SW vacuum breaker that was causing corrosion issues) that had contributed to findings that were determined to be more than minor (Green). These findings are documented in the following Section (Section 4OA2.1.c).

c.

Findinqs

(1) Ineffeqtive Us,e of the Enqineerinq Chanoe Plocess Durinq l/lodification of the 33 Inslrument Air Drver

Introduction:

The inspectors identified a finding of very low safety significance (Green)because Entergy personnel did not adequately implement the procedural requirements of EN-DC-115, "Engineering Change Process," during the installation of a modification to 33 instrument air desiccant dryer.

Description:

Entergy personnel developed Engineering Change (EC) 8501 to prevent intermittent failures of the 33 instrument air desiccant dryer blower motor due to high motor inrush currents during startup. Based on a vendor recommendation, the EC directed the replacement of existing four amp control power fuses with six amp fuses.

The fuses are located in the 33 instrument air dryer control panel.

During implementation of the EC on May 11 , 2011, Entergy personnel removed 15 amp fuseslrom the 33 motor control center (MCC), which powers the 33 instrument air dryer, rather than removing the four amp fuses from the dryer control panel. The electricians proceeded to replace the 15 amp fuses with the new six amp fuses. When the instrument air dryer was reenergized, the six amp fuses, which did not have sufficient amperage capacity for the MCC application, performed their intended function and burned out, deenergizing the dryer. The dryer remained deenergized and unavailable for a period of approximately two weeks until Entergy personnel found water in the air supply to BFD-PCV-3, the steam generator blowdown recovery outlet backpressure controller. Upon troubleshooting the water issue, Entergy personnelfound and corrected the undersized fuses in 33 MCC and placed the dryer back in service. On June 9, 2011, the four amp fuses in the dryer control panel were correctly replaced with six amp fuses, in accordance with the EC. This issue was previously entered into Entergy's CAP as CR-lP3-2011-02767, CR-lP3-2011-02918, and CR-lP3-2011-02920' At tne iime of the inspection, these CRs had been closed to corrective actions already taken, which included correcting the fuse error and coaching personnel to read the EC documentation more thoroughlY.

The inspectors questioned the causes of humidity and low pressure alarms on the 33 instrument air header, which had been documented in condition reports initiated in June and July 2011. Through interviews with the system engin-eer, the inspectors learned that after the fuse issue ha-d been resolved, troubleshooting of high humidity and low pressure alarms on the 33 instrument air header had revealed that the 33 instrument air dryer had been degraded by moisture passing into the air header while the dryer had been unavailable due to the blown fuses. Degradation of the dryer's tower swapping mechanism allowed air to partially

                            'The       bypass the dryer, thereby causing lhe high humidity and low pressure alarms.

inspectors noted that additional unavailability of the dryer the was acciued while Entergy personnel performed troubleshooting and repair of degraded dryer. Based on ine inspectors' questioning, lltergy personneldocumented thjissue as a maintenance rule functional failure of the 33 instrument air dryer and calculated the total cumulative unavailability of the dryer attributed to the modification error. The calculated unavailability was 580 hours, which exceeded the licensee's established Maintenance Rule (10 CFR 50.65) threshold of 525 hours for (a)(1 ) consideration.

The inspectors reviewed EN-DC-1 15, "Engineering Change Process," and identified the several examples where Entergy personnel did not implement the requirements of package incorrectly identified the location of the modification process. First, the EC fuses, and tfris error was translated into the work package which was used by maintenance personnelwho implemented the EC. Specifically, the Post Modification Test plan pait age stated that the four amp fuses were located in the 33 MCC' the fuse Additionally, the maintenance personnelwho implemented the EC did not follow the 15 amp fuses from the MCC and prior to verification procedure when removing was not performed in a timely manner in reinstalling ihe six amp fuses. Finally, the PMT that the 3i instrumentair train was piaced back in service without a PMT having been performed. The inspectors determined that each of these examples had been which opportunities, or "barriers", built into the Engineering change process, through the eniergy personnel could have either prevented or recognized the error and avoided in the air cumulative unavailability of the instrument air dryer and associated moist air header.

personnel' The inspectors determined these problems were not identified by Entergy Entergy staff entered this issue inio their CAP as CR-lP3-2011-03798' Planned correJtiue actions include performing an Apparent Cause Evaluation for the issue.

Analvsis: The inspectors determined that the issue was a performance deficiency o-e Entergy personnel did not follow proceduresTheto.effectively implement the inspectors determined that the engineering cnihge to the 33 instrument air dryer.

to the "more than minor if' finjing was-morelhan minor because the finding was similar statement associated with example 5.b of Inspection Manual chapter (lMc) 0612

               ,,Examples of Minor lssues." Additionally, the finding was more than minor Appendix E, Mitigating because it was associated with the Equipment Performance attribute of the cornerstone   objective   to ensure    the   availability Systems cornerstone and affected the ano capauility of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the unavailability of the 33 instrument air dryer resulted in moist air in the instrument air header which in turn led to high humidity and low pressure conditions on the 33 instrument air header. The inspectors evaluated the finding using IMC 0609, Attachment 4, "Phase 1 - lnitial Screening and Characterization of Findings," and determined the finding was of very low safety significance (Green) becaJse the finding was not a !9sio1 or qualification deficiency, did nJt ,"pr"r"ni a loss of system safety function, and did not screen as            potentially   risk significant due to external initiating events.

of The inspectors determined that the finding had a cross-cutting aspect in the area Human performance, associated with the Work Control attribute, because Entergy personnel did not appropriately coordinate work activities by incorporating actions to with address: 1) the n"eO tor workgroups to communicate, coordinate, and cooperate to each otherduring activities in wnicn interdepartmental coordination is necessary performance; and 2) the need to keep personnel apprised of assure plant and human activities. Specifically, Entergy personnel work status and the operational impact of work did not adequately coordinate the planning and implementation of the engineering clrange process, which involved several site departments, and resulted in incorrectly instalTed'fuses and multiple missed opportunities to both prevent and subsequently identify the error. (H.3(b)) not

Enforcement:

Enforcement does not apply because the performance deficiency did air system is not a safety involve a violation of regulatory requirements. The instrument r"l"t"O system and 10 Cfn pirt 50 Appendix B requirements are not applicable.

is of very Because this issue does not involve a violation of regulatory requiremenls 91{ tow safety significance, it is being treated as a finding (FlN). (FlN 0500028612011010'01' Frocedural Requ i rements of Engineeri ng Change Process Not I mplemented)lntroduction. The inspectors identified a Green non-cited violation of 10 CFR 50' App".d" q Criterion XVl, "Corrective Action," for Entergy's failure to take adequate EDGs' coirective actions for a condition adverse to quality involving SW pipes to the personnel did not take timely and appropriate corrective actions for Specifically, Entergy carbon steel pipe w-ati tninning on the common SW supply lines to the EDGs'

Description.

on July 19,2011, the inspectors observed that a leaking sw return line valve room, which ffi breaker (SWN-6g) ported water into the piping pit in the EDG The inJirectly sprayed'the bottom of both redundant EDG SW supply pipe headers' inspectors'not-eo that this portion of both 1o-inch diameter sw supply headers was approximately two fe_et. The inspectors noted that continuously wetted over a length of the vacuum breaker had been leaking since February 2009.

Based on the corroded rust condition of the bottom portion of both headers and the quantity of accumulated questioned the condition of these flakes/pieces beneath both headers, the inspectors pipes.

external Entergy personnel informed the inspectors that they had originally identifled the location on Septembgr 30, 2008 (CR corrosion on the SW supply lines aithat specific Lp3-2008-02383). Tne inspectors reviewed CR-;P3-2008-02383 and Entergy's operations, associated corrective actions and noted the following:

(1) the CR initiator, and cRG screened the cR as not requiring an operability review (thus no operability review was performed for this safety-related SW piping degraded condition);

(2) CRG classified the CR as significance "D" and closed the CR to WO 166970;

(3) WO 166970 was created to clean, repaint and inspect the piping per the external corrosion monitoring program;

(4) planning took the WO to "plan" status on October 1, 2008; and

(5) as of August 2011, the WO was active and targeted to work in 2015. The inspectors requested operability evaluations of this degrading condition, other associated CRs, documented inspections (including ultrasonic tests) or trending reports, and any associated WOs since October 2008. Entergy personnel stated that no additional documented information was identified but indicated that the system engineers periodically inspected the piping during their walkdowns.

Based on the inspectors' questions, Entergy staff initiated CR-lP3-2011-03831. Entergy structural engineering personnel inspected the piping on July 21. Based on their input regarding iron oxide exfoliation, an estimate of SW piping wall loss and no leakage, engineering personnel determined that the structural integrity of the pipe was not affected and that the pipe remained operable. The inspectors reviewed Entergy's operability evaluation and determined that it was adequate based on the information available. Entergy's short-term corrective actions also included redirecting the vacuum breaker discharge to a local sump (completed on August 2) and reprioritizing the SW piping refurbishment work order (scheduled to work in 2011). Subsequent to this inspeition, Entergy personnel performed ultrasonic testing of the affected area on one of the pipes that they concluded was most affected and confirmed that the pipe remained operable.

Analvsis. The inspectors determined that Entergy's failure to take adequate corrective actions for an adverse condition associated with the EDG SW supply piping was a performance deficiency that was reasonably within Entergy's ability to foresee and prevent. Specifically, Entergy personnel did not take timely and appropriate corrective actions commensurate with the safety significance of a potential common mode failure of all three EDGs due to carbon steel pipe wall thinning on the common SW supply. The finding was determined to be more than minor because if left uncorrected the performance deficiency had the potential to lead to a more significant safety concern.

Specifically, the continuing wetting and associated external corrosion of the pipe without appropriate monitoring could adversely impact the structural integrity of one or both EDG SW supply headers. The inspectors evaluated the finding in accordance with IMC 0609, 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," Table 4afor the Mitigating Systems Cornerstone. The inspectors determined that the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and was not risk significant with respect to external events.

This finding had a cross-cutting aspect in the area of Problem ldentification and Resolution, associated with the Corrective Action Program attribute, because Entergy personnel did not take appropriate corrective actions to address an adverse trend in a timely manner, commensurate with the safety significance. Specifically, Entergy personnel did not take timely corrective actions to address SW carbon steel pipe wall ifrinning due to external corrosion, such as eliminating the source of the wetting by redireciing the flow of water, evaluating the as-found structural integrity of the pipe, and periodically monitoring the pipe for further degradation, commensurate with the safety significance of the pipe. (P.1(d))

Enforcement.

10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, in part, that, "Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected." Contrary to the above, Entergy staff did not promptly correct the degraded condition of the EDG SW piping from September 30, 2008, to August 2, 2011. Because this violation was of very low safety significance and it was entered into Entergy's CAP (CR-IP3-201 1-03831), it is being treated as an NCV consistent with the Enforcement Policy. (NGV 05000286/2011010-02, Inadequate Gorrective Action for Degraded EDG SW Piping)

.2 Assessment of the Use of Operatino Experience (OE)

a. Insoection Scope The inspectors selected a sample of CRs associated with the review of industry OE to determine whether Entergy personnel appropriately evaluated the OE information for applicability to Indian Point Unit 3 and had taken appropriate actions, when warranted.

The inspectors reviewed CR evaluations of OE documents associated with a sample of NRC generic letters and information notices to ensure that Entergy staff adequately considered the underlying problems associated with the issues for resolution through their CAP. The inspectors also observed CRG and CARB meetings to determine if industry OE was considered during the CR screening and resolution processes.

b. Assessment The inspectors determined that, in general, Entergy staff appropriately considered industry OE information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that OE was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable.

The inspectors observed that industry OE was discussed and considered during the conduct of CRG and CARB meetings. However, the inspectors noted in one CR that, Entergy staff had not appropriately considered internal and industry OE and/or effectively used the information to implement timely corrective and preventive actions. For example: r The inspectors noted that Entergy staff had received from industry sources operating experience related to the Calvert Cliffs plant, where water intrusion from a roof leak had caused a dual unit trip in 2010. The inspectors noted that, in May 2010, Entergy staff determined that the Indian Point Units were not susceptible to the same type of event due to the design of the electrical systems, in that the Units are electrically isolated from one another. Entergy staff determined that no additional actions were necessary to address this industry OE. The inspectors determined that, in this instance, Entergy's response was narrowly focused, given the presence of roof leaks in the Unit 3 PAB and the identified roof leak in the 31 EDG cell (WO 225582).

However, the inspectors noted that, as of July 2Q11, Entergy had an open action item in their CAP to perform an OE review of NRC Information Notice 2011-12, "Reactor Trips Resulting from Water Intrusion into Electrical Equipment," which the NRC issued in June 2Q11in response to the Calvert Cliffs event. Therefore, because none of the leaks challenged or impacted equipment important to safety, and Entergy has open actions to address potential site-specific applicability of the OE regarding roof leaks, the inspectors determined that the performance aspects regarding this issue were of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Findinqs No findings were identified.

.3 Assessment of Self-Asqegsmentg and Audits

a. Inspection Scope

The inspectors reviewed a sample of Quality Assurance (aA) audits, including a review of several of the findings from the most recent audit of the CAP, and self-assessments focused on various plant programs. These reviews were performed to determine if problems identified through these assessments were entered into the CAP, when appropriate, and whether corrective actions were initiated to address identified deficiencies. The effectiveness of the audits and assessments was evaluated by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment The inspectors concluded that QA audits and self-assessments were critical, thorough, and generally effective in identifying issues. The inspectors observed that these audits and self-assessments were completed by personnel knowledgeable in the subject areas and were completed to a sufficient depth to identify issues that were then entered into the CAP for evaluation. Corrective actions associated with the issues were implemented commensurate with their safety significance.

Findinqs No findings were identified.

.4 Assessment of Safetv Conscious Work Environment

a. lnspection Scope During interviews with station personnel, the inspectors assessed aspects of the safety conscious work environment at Indian Point Unit 3. Specifically, as part of personnel interviews during the inspection, the inspectors asked questions to identify whether station personnel were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program (ECP)coordinator to determine what actions were implemented to ensure employees were aware of the program and its availability with regard to raising concerns. The inspectors reviewed a numder of ECP files to ensure that issues were entered into the CAP when appropriate.

b. Assessment During interviews, plant staff expressed a willingness to use the CAP to identify plant issueJ and deficiencies and indicated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation where there were indications an individual had been hesitant to raise a safety issue. All persons interviewed demonstrated an adequate knowledge of the CAp unO gCp. Based on these limited interviews, the inspectors concluded that there was no evidence of significant challenges to the free flow of information regarding safety concerns.

c. Findinqs No findings were identified.

4046 Meetinqs. lncludinq Exit Exit Meetinq Summarv On August 5,2011, the inspectors presented the inspection results-to Mr' Joseph pollocli, Site Vice President, and other members of the Entergy staff' The inspectors reviewed proprietary information, which was returned to Entergy staff at the end of the inspection. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Enterqv Personnel J. Pollock Site Vice President R. Aguiar Security Supervisor B. Altadonna Programs and Components Engineer J. Bencivenga Design Engineering M. Burney Licensing Specialist

P. Conroy Director, Nuclear Safety Assurance

K. Curley System Engineer G. Dahl Licensing Specialist M. Ferretti Maintenance Supervisor

E. Firth Manager, Corrective Action & Assessment

D. Gagnon Site Security Manager M. Haggstrom System Engineer C. Hasenbein System Engineer T. lavicoli Radiation Protection Specialist R. Johnson Maintenance Supervisor J. Lafferty System Engineering Supervisor

R. Martin Senior Planner, Emergency Planning

F. Philips Senior Planner, Emergency Planning

J. Reynolds Corrective Action & Assessment Specialist B. Schmidt Operations B. Taggart Employee Concerns Program Coordinator M. Tumicki Corrective Action & Assessment Specialist

J. Ventosa General Manager, Plant Operations

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Opened and Closed 05000286/201 1 01 0-01 FIN Procedural Requirements of Engineering Change Process Not lmplemented 05000286/2011010-02 NCV Inadequate Corrective Action for Degraded EDG SW Piping

LIST OF DOGUMENTS REVIEWED Section 4OA2: ldentification and Resolution of Problems Audits and Self-Assessments LO-lP3LO-2009-00067, "Plant Status and Configuration Control - IPEC Snapshot Self- Assessment Report," dated December 12,2009 LO-lP3LO-2009-00071, "QA NIEP Audit Criteria - IPEC Focused Self-Assessment Report," dated July 13,2009 LO-lP3LO-2010-00008, "Quality of CR Closures Performed by Department lmprovement Coordinators (DPlCs) - IPEC Snapshot Self-Assessment Report," dated December 31, 2010 LO-lP3LO-2010-00074, "Conduct of Operations - IPEC Snapshot Self-Assessment Report," dated November 13,2010 LO-lP3LO-2010-00157, "Tone Alert Radio Program Administration and Recordkeeping - IPEC Snapshot Self-Assessment Report," dated May 10,2010 LO-lP3LO-2011-00023, "Operations Facilities and Equipment - IPEC Snapshot Setf- Adsessment Report," dated June 1 ,2011 LO-lP3LO-2010-00035, "Snapshot Self-Assessment on Access Controls," dated May 26,2Q10 LO-lP3_LO-2010-00078, "Focused Self-Assessment on Closed Cooling Water Chemistry," dated TtAay 14,2010 LO-lP3LO-201 0-00045, "Fatigue Rule Compliance", dated February 23, 2010 LO-lP3LO-2010-00196, "Preventive Maintenance (PM) Feedback," dated September 28,2010 QA-07-2011-lP-1, "Emergency Preparedness (EP) Quality Assurance Audit Report," dated June 13,2011 QA-12-2009-lP-1, "Operations/Technical Specifications Quality Assurance Audit Report," dated August 3, 2009 QA-04-2010-lP-1, "Engineering Design Control Quality Assurance Audit Report," dated May 27, 2010 QA-10-2010-1P-1 , "Maintenance Quality Assurance Audit Report," dated October 13, 2010 QA-01-2009-lP-1, "Fitness for Duty Quality Assurance Audit Report," dated August 20,20Qg QA-1 6-2009-l P-1, "Security Quality Assurance Audit Report," dated December 17, zQQg QA-16-2010-lP-1, "security Quality Assurance Audit Report," dated February 9,2011 Calculations lP3-CALC-SWS-02022, "Operability Determination and Supports Repair in the Zurn Pit," Revision 0 lP-CALC-08-00118, "Evaluation of Through Wall Leak for Tee Downstream of SWN-38 for Line 408," Revision 0 Completed Surveillances 3-PT-M079A, "31 EDG Functional Test," performed May 15,2011 and June 16, 2011 3-PT-M0798, "32 EDG Functional Test," performed May 17, 2011 and June 13, 2011 3-PT-M079C, "33 EDG Functional Test," performed June 14,2011 3-PT-Q120F, "32 ABFP (Turbine Driven) Surveillance and lST," performed April 15, 2011 3-PT-Q134A, "31 RHR Pump FunctionalTest (RHR Cooling Not in Service)," performed June 3, 2011

3-PT-Q1348,"32 RHR Pump Functional Test (RHR Cooling Not in Service)," performed June 29,2011 3-PT-R0078, "32 ABFP Full Flow Test," performed April 6, 201 1 3-PT-R090E, "Local Operation of 32 ABFP," performed July 5,2011 3-PT-R1604, "31 EDG Capacity Test," performed March 29,2011 3-PT-R1608,"32 EDG Capacity Test," performed March 29,2011 3-PT-R160C, "33 EDG Capacity Test," performed March 20,2011 3-PT-R189A, "Functional Test of 31 Automatic Trips," performed March 24,2011 3-PT-R189B, "Functional Test of 32 Automatic Trips," performed March 28,2011 3-PT-R189C, "Functional Test of 33 Automatic Trips," performed March 17 , 2Q11 3-PT-R198,"32 ABFP Turbine Overspeed Test," performed April 1 ,2011 3-PT-Q1168,"32 Safety Injection Pump," dated July 11,2011 3-PT-Q1 168, "32 Safety Injection Pump," dated July 12, 2011 Condition Reports (CR-lP2-) 2010-00746 2010-06527 2011-01610 201 1-03604- 2010-05639 201 1-00654 2011-02392 2010-06497 201 1-0'1608 201 1-03603.

• CR written as a result of this inspection

Condition Reports (CR-lP3-) 2003-01600 2009-00381 2009-03538 2009-04452 2003-0361 3 2009-0051 2 2009-03546 2009-04462 2003-04298 2009-00572 2009-03562 2009-04482 2006-0001 3 2009-02368 2009-03578 2009-04498 2006-00290 2009-02443 2009-03590 2009-04499 2006-01 596 2009-02462 2009-03786 2009-04502 2006-02071 2009-02539 2009-03808 2009-04523 2006-04063 2009-02573 2009-0381 I 2009-04585 2007-00275 2009-02587 2009-03867 2009-04607 2007-01 01 0 2009-02626 2009-03904 2009-04638 2007-01512 2009-02716 2009-03908 2009-04655 2007-03393 2AA9-02720 2009-03943 2009-04693 2007-04212 2009-02791 2009-03956 2009-04694 2008-00334 2009-02831 2009-04006 2009-04769 2008-00369 2009-03040 2009-04035 2009-0481 9 2008-00409 2009-03089 2009-04077 2009-04867 2008-00489 2009-031 50 2009-04123 2009-04876 2008-00698 2009-03177 2009-04219 2009-04901 2008-00717 2009-0331 1 2009-04262 201 0-00007 2008-01 589 2009-03321 2009-04281 2010-00045 2008-02026 2009-03336 2009-04282 201 0-00060 2008-02137 2009-03341 2009-04288 2010-00202 2008-021 66 2009-03343 2009-04359 201 0-00269 2008-02383 2009-03375 2009-04401 2010-00347 2008-02787 2009-03386 2009-04420 2010-00410 2008-03009 2009-03481 2009-04450 2010-00419

2010-00420 201 0-03099 2011-01345 2011-02835 2010-00421 201 0-031 09 2011-01371 2011-02844 201 0-00549 2010-031 19 2011-01377 2011-02867 2010-00631 2010-03141 201 1-01398 2011-02918 201 0-00735 2010-03216 2011-01403 2011-02920 201 0-00853 2010-03229 2011-01434 201 1-03080 201 0-00863 201 0-03299 2011-01447 2011-03127 2010-00917 201 0-03469 2011-01465 2011-03148 201 0-00998 2010-03478 2011-01492 2011-03170 2010-01028 201 0-03554 2011-01496 2011-03243 201 0-01 034 201 0-03686 2011-01517 2011-03280 2010-01217 201 0-03687 2011-01525 2011-03295 2010-01227 201 0-03696 2011-01588 201 1-03360 2010-01238 201 0-03859 2011-01615 2011-03481 2010-01433 201 1-00018 2011-01619 2011-03522 201 0-01 533 2011-00021 2011-01745 201 1-03561 201 0-01 543 201 1 -00039 201 1-01869 2011-03574 2010-01692 2011-00205 2011-01915 201 1-03583 2010-01730 2011-00232 2011-01917 2011-03584 201Q-Q1825 2011-00259 2011-01929 2Q11-03592 201 0-01 883 201 1-00318 2011-01944 201 1-03594 201 0-01 890 201 1-00369 2011-01997 201 1-03596 2010-01924 2011-00394 2011-02131 201 1-03599 2010-01964 201 1 -00396 2011-02139 201 1 -03609 2010-02005 2011-00433 2011-02142 201 1-03613 2010-02204 2011-00574 2011-02146 2011-03614 2010-02231 2011-00575 2011-02204 201 1-03616 2010-02288 201 1-00576 2011-Q2227 2011-03617 2010-02294 2011-00577 2011-02240 201 1-03619 2010-02331 201 1-00580 2011-02305 201 1-03631 2A10-02348 201 1 -00858 2011-02309 2011-03632* 2010-02376 201 1 -00860 2011-02352 2011-03648* 2010-02377 2011-00926 2011-02358 2011-03654* 2010-02379 201 1-00955 2011-02391 201 1 -03656. 2010-02384 2011-01028 2011-02397 201 1-03663. 2010-02395 2011-01052 2011-02403 2011-03664 201 0-02396 201 1-01056 2011-02413 2011-03672* 2010-02444 2011-01078 2011-02417 2011-03676 2010-02501 2011-01107 2011-02474 2011-Q3682* 2010-02504 2011-01115 2011-02496 201 1-03685. 2010-02588 2011-01120 2011-02504 2011-Q3704 2010-02614 2011-01136 2011-02520 2011-03705. 2010-Q2617 2011-01156 2011-02521 201 1-03709" 201 0-02690 2011-01186 2011-02524 2011-03713 2010-02723 2011-01246 2011-02594 2011-03727 2010-02731 2011-01252 2011-02609 2011-03729* 2010-02755 2011-01254 2011-02749 2011-03734. 2010-02854 2011-01260 2011-02767 2011-03735 201 0-02900 2011-01327 2011-02785 2011-03759 2010-03061 201 1-01 330 2011-02834 2011-03779

2011-03789 2011-03806" 2011-03831* 2011-03845. 2011-03798. 2011-03810. 2011-03832* 2011-04040* 2011-03804. 2011-03815* 2011-03833* 2011-03805. 2011-03827. 2011-03840.

• CR written as a result of this inspection

Drawinqs 21-F-20333 Sheets. 1 &2, "Flow Diagram Service Water System," Revisions 50 and 28 21-F-20343 Sheets. 1 &2, "Flow Diagram City Water," Revisions 36 and 20 21-F-21223, "Flow Diagram Appendix'R'6.9 KV Emergency Diesel Generator Jacket Water System," Revision 3 21-F-27533, "Flow Diagram Hydrogen Recombiner System," Revision 12 21-F-33733, "Logic Tripping Diagram for RCS Overpressurization Protection System," Revision 3 21-H-20283, "Flow Diagram Jacket Water to Diesel Generators," Revision 22 INSUL-50453, "Containment Building Restraint & Support Design Line 62 Insulation Details," Revision 0 Emerqencv Preparedness Related Binder #EOF-1, "Emergency Director Emergency Response Organization Position Binder," updated July 8, 2011 Binder #EOF-4, "RadiologicalAssessment Coordinator Emergency Response Organization Position Binder," updated July 8, 2011 Binder #EOF-5, "Dose Assessor Emergency Response Organization Position Binder," updated July 8,2011 Binder #lCP-1, "Security Coordinator lCP," updated July 8,2011 Binder #TSC-1, "Emergency Plant Manager Emergency Response Organization Position Binder," updated July 8, 2011 Binder #TSC-4, "Reactor Engineer Emergency Response Organization Position Binder," updated July 8, 2011 Binder #TSC-8, "TSC Communicator Emergency Response Organization Position Binder," updated July 8, 2011 Drill Number 2008-7 , "Emergency Preparedness Unit 3 Exercise December 3, 2008 Performance Report," Revision 0 Drill Number 2Q1O-5, "Emergency Preparedness Unit 2 FEMA/NRC Exercise September 14, 2010 Performance Report," dated October 12,2010 Drill Number 2010-6, "Emergency Preparedness Unit 2 Training Drill December 7, 2010 Performance Report," dated December 15,2010 Drill Number 2011-1, "Emergency Preparedness Unit 2 Training Drill February 3,2Q11 Performance Report," dated February 10,2011 Drill Number 2011-2, "Emergency Preparedness Unit 3 SAMG Training Drill June 9,2011 Performance Report," dated June 30,2011 EN-PL-155 Attachment 9.1, "Notification Forms Revision Change Management Checklist," dated January 25,2011 Form EP-3, "Control Room NOE Notification Checklist," Revision 14

            .CCR Initial Notification Checklist - AlerUSAElGE," Revision 13

Form EP-4,

Form EP-5, "Upgrade/Update Notification - AIeTUSAE/GE Checklist," Revision 11 lP-EP-AD33, "IPEC ATI Siren System Quarterly Preventative Maintenance," Revision 6 lP-EP-AD34, "IPEC ATI Control Station Semi-Annual Preventative Maintenance," Revision 4 lP-EP-AD35, "IPEC ATI Siren Site Annual Preventative Maintenance," Revision 4 Siren-01, "Siren Main and Auxiliary Amplifier Board Replacement," Revision 4 TSC-1, "lndian Point Energy Center Emergency Telephone Directory," July 2011 Evaluations CR lP2-2009-03701, "Alert Notification System Test Failure Root Cause Analysis Report," Revision 1 CR lP3-2009-02640, "32 Main Boiler Feed Pump Rework Root Cause Analysis Report," Revision 1 CR lP3-2009-02831, "Lifting of Sl-855 Relief Valve During 3PT-Q1168 Functional Test for 32 Sl Pump Apparent Cause Evaluation," dated July 15,2009 CR lP3-2009-02968, "Emergency Plan Contingency Actions with the Seismic Monitoring Instrumentation Out-of-Service Apparent Cause Evaluation," dated August 4,2009 CR lP3-2009-04454, "Main Line "A" Phase Fuse Blown to the 33 EDG Auxiliaries in MCC 39 Cubicle SBL Apparent Cause Evaluation," dated December 9, 2009 CR lP3-2010-01542, "Two Performance Indicator Opportunities Were Missed During Emergency Planning Drill Apparent Cause Evaluation," dated June 29, 2010 CR lP3-2010-02082, "MIDAS (Meteorological Information and Data Acquisition System) Program Displayed an Incorrect Emergency Classification Apparent Cause Evaluation," dated August 9, 2010 CR lP3-2011-00680, "U3 Service Water Leak Downstream of SWN-6 Root Cause Analysis Report," Revision 1 PMRQ 50068322-02,"1Y INSP HX (Tube-Side) IAW HTX-}Z2-EDG PM Deferral Request," dated May 19, 2011 SW Line 1222Equipment Failure Evaluation, Revision 0 Learninq Orqanization Trackino Reports (LO-lP3LO-) 201 0-001 64 201 0-001 89 Licensee Event Reports LER 0500028612009-009-01, "Loss of a Single Train Neutron Flux Detector N-38 Required for Plant Shutdown Remote from the Control Room due to a Power Supply Failure," dated October 29,2010 Maintenance Rule. Svstem Health. and Trendinq ABFP Oil Analysis Report Summary, dated August 3,2Q10 - July 5,2011 lP3-WebCDMS Sample Analysis Results Summary (EDG Fuel Oil), dated July 2,2011 - August 1, 2011 IPEC Top Ten Equipment Reliability lssues, dated July 14,2011 lP-RPT-1 1-00020, 'tMaintenance Rule Structural Monitoring lnspection Report (4th Cycle) for Intake Structure," dated April 15,2011 LO-lP3LO2011-00003, "Operations Department Quarterly Trend Report, 4tn Quarter 201Q"

LO-IP3LO2011-00125, "Operations Department Quarterly Trend Report, 1" Quarter 2011" SEP-SW-001 Attachment G, "31 EDG JW & LO Coolers Inspection Report," dated August 1 1, 2010 and July 14,2011 SOP-WDS-O10 Attachment 1, "Containment Sump Flow Daily Average," dated April 1 0, 2011 - July 29,2011 Unit #3 Boric Acid Walkdown, performed July 13,2011 lP3-RPT-IA-O1891, "Maintenance Rule Basis Document for Instrument Air and Instrument Air Closed Cooling Systems," Revision 0 System Health Report Unit 3 AFW, 1" Quarter 2011 System Health Report Unit 3 DC, 1't Quarter 2011 Miscellaneous 3-PT-D001, "CCR TS Rounds," dated July 3-9, 2011 3-PT-D001C, "Field TS Rounds," dated July 3-9, 2011 3-RND-CV, "Conventional Rounds," dated July 3-9, 2011, and July 19,2011 3-RND-NUC, "Nuclear Rounds," dated July 3-9, 2011 EN-MA-1 18 Attachment 9.6, "lntake Structure Access Port Line 409 Foreign Material Exclusion Component Close-Out," dated March 25,2011 IPEC Operations Shift Order, dated June 24, 2011, June 27-30 , 2011, July 5-8, 2011, and July 11, 2011 Log Entries Report, dated June 19-24,2011 and July 3-9, 2011 SIPD 1248, "lnstall Status Light on EDG JWPS 1 and 2 Air Start Pressure Switches," dated June 1,2410 TS-MS-003, "Technical Specification for Piping and Equipment Insulation," Revision 8 Unit 3 Control Room Deficiency Log, dated June 15,2011 Unit 3 Operations Feedback Report for Group 3-AOP, dated July 13,2011 Unit 3 Operations Feedback Report for Group 3-ARP, dated July 13,2011 Unit 3 Operations Feedback Report for Group 3-ECA, dated July 13,2011 EC 8501, "Replace existing Gould Shawmut model number TRS4R fuses for 33 Instrument Air Desiccant Dryer Blower Motor with Ferraz Shawmut model number TRSOR fuses," Revision 0 Maintenance Aggregate Index, as of May 2011 Non-Outage Fluid Leaks, as of May 2011 On-Line Corrective Maintenance Backlog, as of May 2011 On-Line Deficient Maintenance, as of May 2011 Outage Corrective Maintenance Backlog, as of May 2011 Outage Deficient Maintenance, as of May 2011 Outage Fluid Leaks, as of May 2011 PIR Rework Analysis, as of May 2011 Non-Cited Violations and Findinqs FIN 0500028612010003-02, "Failure to Perform an Adequate Operability Evaluation for Neutron Detector N-38 Anomalous Behavior" NCV 0500028612009005-02, "Untimely Compensatory Measures for Degraded EDG Pressure Switches" NCV 05000 286 l 2009005-03, "S ren Test Fa i u re" i I NCV 0500028612009005-04, "Failure to Promptly ldentify and Correct a Molded Case Circuit Breaker Service Life Nonconformance"

NCV 0500028612010004-01, "Untimely Corrective Actions for Degraded Capacitors for the 31 Static lnverted' NCV 0500028612010005-03, "Failure of the Offsite Notification Procedure to Meet the Requirements of the Site Emergency Plan" NCV 0500028612010009-01, "lnadequate Design Control of Service Water Strainer Room Flood Barrier" NCV 0500028612010005-01, "Repeated Control Room Air Conditioner Gasket Failures" Non-Destructive Examination Reports lP3-UT-08-034,"18-inch Line-408 U/S Valve SWN-40-2 UT Erosion/Corrosion Examination," performed August 24, 2008 lP3-UT-08-055, "18-inch Line-408 U/S Valve SWN-40-2 UT Erosion/Corrosion Examination," performed November 10, 2008 lP3-UT-09-083, "Gas Intrusion - 4" Line #16 @ Penetration Q - PAB Side of Containment UT" Calibration/Examination," performed July 16, 2009 IP3-UT-10-008, "31 SW Pump Discharge 14" Line #1081UT Erosion/Corrosion Examination," performed February 5, 2Q10 lP3-UT-10-009, "32 SW Pump Discharge 14" Line #1082 UT Erosion/Corrosion Examination," performed February 5, 2010 lP3-UT-10-010, "33 SW Pump Discharge 14" Line #1083 UT Erosion/Corrosion Examination," performed February 5, 2010 lP3-UT-10-01 1 , "34 SW Pump Discharge 14" Line #1084 UT Erosion/Corrosion Examination," performed February 5, 2010 IP3-UT-10-012, "35 SW Pump Discharge 14" Line #1085 UT Erosion/Corrosion Examination," performed February 5, 2010 lP3-UT-10-013, "36 SW Pump Discharge 14" Line #1086 UT Erosion/Corrosion Examination," performed February 5, 2010 W-07-033, SW "34 Support-ATT Visual Examination of Component Supports and Snubbers

      (Vr-1)", performed January 22, 2QQT

W-07-034, "AFW 32 Support Visual Examination of Component Supports and Snubbers (W- 3)," performed January 22,2007 W-07-067, "SW-H&R-12C-17 Visual Examination of Pipe Hanger, Support or Restraint (VT-3)," performed March 8,2007 W-07-069, "SW-H&R-128-12-ATl Visual Examination of Pipe Hanger, Support or Restraint

      (VI-1)," performed March 9,2007

Operatinq Experience CR-fP2-2010-7322, "NRC-IN-2010-23, Malfunctions of Emergency Diesel Generator Speed Switch Circuits," dated February 9,2011 CR-lP2-2011-00832, CA-2, "Containment Insulation Walkdowns at domestic PWRs in Support of NRC Generic Safety lssue 191," dated April 8, 201 1 CR-lP2-2011-00834, CA-2, "Containment Insulation Drawing Review in Support of NRC Generic Safety lssue 191," dated June 21, 2011 CR-lP2-2011-00835, CA-2, "lnsulation Specification Update for Unit 3 (TS-MS-003) to identify GSI-191 related information," dated May 25,2011 CR-lP2-201 1-00836, CA-1, "Control of Containment Insulation in Support of NRC Generic Safety lssue 191," dated March 10,2011

CR-lP3-201 1-0381 1 , "10CFR21-0102 Concerning the Potential for Failures of SS810 Air Start Motors," dated August 2,2011 LO-WTIPC-2011-OOO29, CA-49, "NRC-IN-2011-02 Operator Performance lssues Involving Reactivity Management at Nuclear Power Plants," Revision 0 LO-WTIPC-2011-00029, CA-60, "NRC-Event-4607-A2-lPC-001, Potential Voiding in Auxiliary Feedwater Alternate Suction Line," Revision 0 NRC Information Notice 2007-06, "Potential Common Cause Vulnerabilities in Essential Service Water Systems," dated February 9,2007 NRC Information Notice 2008-11, "Service Water System Degradation at Brunswick Steam Electric Plant Unit 1," dated June 18, 2008 NRC lnformation Notice2011-l2, "ReactorTrips Resulting from Water Intrusion into Electrical Equipment," dated June 16,2011 Procedures O-AOP-SEC-3, "Event Contingency Actions," Revision 3 0-GNR-403-ELC, "Emergency Diesel Generator Quarterly Inspection," Revision 2 3-AOP-Flood-1, "Flooding," Revision 4 3-AOP-Leak-1, "Sudden Increase in Reactor Coolant System Leakage," Revision 5 3-ARP-009, "VC Sump Pump Running," Revision 41 3-ARP-011, "Panel SHF Electrical," Revision 33 3-ARP-019, "Panel Local- Diesel Generators," Revision 26 3-ECA-0.0, "Loss of All AC Power," Revision 6 3-ECA-1.2, "LOCA Outside Containment," Revision 0 3-PT-W001, "Emergency Diesel Support Systems Inspection," Revision 40 3-SAG-2, "Depressurize the RCS," Revision 1 3-SOP-AFW-001, "Auxiliary Feedwater System Operation," Revision 3 3-SOP-CB-002, "Containment Entry and Egress," Revision 33 3-SOP-EL-001, "Diesel Generator Operation," Revision 45 3-SOP-EL-005A, "480 Volt Electrical System Operation," Revision 12 EN-LI-102, "Corrective Action Process," Revision 16 EN-Ll-104, "Self-Assessment and Benchmark Process," Revision 7 EN-Ll-1 18, "Root Cause Evaluation Process," Revision 14 EN-LI-118-06, "Common Cause Analysis (CCA)," Revision 1 EN-Ll-119, "Apparent Cause Evaluation (ACE) Process," Revision 12 EN-Ll-121, "Entergy Trending Process," Revision 10 EN-OE-100, "Operating Experience Program," Revision 12 EN-OP-1 15, "Conduct of Operations," Revision 1 1 EN-WM-107, "Post Maintenance Testing," Revision 3 IPEC Emergency Action Levels," Revision 10-2 SEP-SW-OO1, "NRC Generic Letter 89-13 Service Water Program," Revision 4 EN-Ll-1 02, "Corrective Action Process," Revision 16 EN-WM-107, "Post Maintenance Testing," Revision 3 3-REF-002-GEN, "lndian Point Unit 3 Refueling Procedure," Revision 4 3-PT-M108, "RHRySI/CS System Venting," Revision 14 0-CY-2510, "Closed Cooling Water Chemistry Specifications and Frequency," Revision 12 EN-RP-101, "Access Controlfor Radiologically Controlled Areas," Revision 6 0-RP-RWP-407, "Refueling Support," Revision 2 3-PT-R032A, "Fuel Storage Building Filtration System," Revision 20 0-NF-311, "NlS Power Range Gain Adjustment," Revision 2

EN-DC-117, "Post Modification Testing and Special Instructions," Revision 4 3-SOP-lA-001, "lnstrument Air System Operation," Revision 25 EN-DC-1 15, "Engineering Change Process," Revision 1 1 3-ARP-012,"Panel SJF - Cooling Water and Air," Revision 48 3-AOP-AlR-1, "Air Systems Malfunction," Revision 3 EN-DC-205, "Maintenance Rule Monitoring," Revision 3 EN-DC-204, "Maintenance Rule Scope and Basis," Revision 2 EN-DC-206, "Maintenance Rule (aX1) Process," Revision 1 Safetv Culture / Emplovee Concerns Proqram LO-HQNLO-2010-00002, "Entergy Nuclear Fleet 2009 Nuclear Safety Culture Survey Action Plan," dated January 28,2010 LO-lP3LO-2009-00164, "lndian Point Energy Center 2009 Nuclear Safety Culture Survey Action Plan," dated January 28,2010 LO-lP3LO-2010-00138, "Security Department Nuclear Safety Culture Survey Action Plan," dated January 28,2010 LO-lP3LO-2009-00164, "lndian Point Employee Concerns lmprovement Plan," dated November 30, 2009 Meeting Minutes, Indian Point Energy Center Executive Protocol Group Meeting 09-016, dated December 7,2009 Meeting Minutes, Indian Point Energy Center Special Executive Protocol Group Meeting 10-001, dated January 8,2010 Summary List of ECP Cases for 2009, 2010, and 2Q11 IPEC ECP Monthly Report for June, 2011 lndian Point Employee Concerns Data Analysis Reports for 2009 and 2010 Self-Assessment of IPEC Nuclear Plant Employee Concerns Program, dated October, 2010 Work Orders 001 85072 00233344 001 63657 52036144 001 95796 52214280 00278896

LIST OF ACRONYMS ADAMS Agencywide Document Management System AFW auxiliary feedwater CA corrective action CAP corrective action program CARB Corrective Action Review Board CFR Code of Federal Regulations CR condition report CRG Condition Review Group CW city water DRS Division of Reactor Safety EC engineering change ECP Employee Concerns Program EDG emergency diesel generator Entergy Entergy Nuclear Northeast FIN finding GL Generic Letter gpm gallons per minute HX heat exchanger tMc inspection manual chapter IST in-service test KV kilovolt LO lubricating oil MCC motor control center NCV non-cited violation NPO nuclear plant operator NRC Nuclear Regulatory Commission OE operating experience PAB primary auxiliary building PMT post-maintenance test QA quality assurance SCWE safety conscious work environment SDP significance determination process SSC structures, systems, and components ST surveillance test SW service water TS Tech nical Specifications unsat unsatisfactory UT ultrasonic testing WO work order Attachment }}