ML063550311

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Problem Identification and Resolution Inspection Reports Nos. 05000247/2006006 and 05000286/2006006 and NRC Request for Response
ML063550311
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 12/21/2006
From: David Lew
Division Reactor Projects I
To: Dacimo F
Entergy Nuclear Operations
References
EA-06-311, IR-06-006
Download: ML063550311 (6)


See also: IR 05000247/2006006

Text

December 21, 2006EA-06-311Mr. Fred R. DacimoSite Vice President

Entergy Nuclear Operations, Inc.

Indian Point Energy Center

295 Broadway, Suite 1

P.O. Box 249

Buchanan, NY 10511-0249SUBJECT:INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 PROBLEMIDENTIFICATION AND RESOLUTION INSPECTION REPORT NOS.

05000247/2006006 AND 05000286/2006006 AND NRC REQUEST FOR

RESPONSEDear Mr. Dacimo:

On October 6, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed concurrentbiennial problem identification and resolution team inspections at the Indian Point Nuclear

Generating Units 2 and 3. The enclosed inspection reports document the inspection

observations and findings which were discussed with Entergy management during an exit

meeting onsite on December 5, 2006, and during a teleconference meeting on

December 14, 2006.The inspections were examinations of activities conducted under your licenses as they relate tothe identification and resolution of problems, and compliance with the Commission's rules and

regulations and the conditions of your licenses. Within these areas, the inspections involvedexamination of selected procedures and representative records, observations of activities, and

interviews with personnel.The inspection teams concluded that Entergy's implementation of the corrective action programat the Indian Point Nuclear Generating Units 2 and 3 was consistent across both units and

generally effective. The teams determined that Entergy staff had a low threshold for identifying

problems, and issues were prioritized and evaluated commensurate with their safety

significance. Corrective actions were typically implemented in a timely manner and addressed

the identified causes of the problems. Lessons learned from industry operating experience

were reviewed and applied when appropriate, and audits and assessments were critical with

appropriate actions taken to address identified issues in most cases. During the inspection, the team conducted interviews and reviewed specific concerns tounderstand the application and effectiveness of the corrective action program in support of

ensuring an environment where employees feel free to raise concerns. In the context of the

2F. Dacimosafety conscious work environment onsite, the inspection teams observed that most workersindicated that they would raise issues that they recognized as nuclear safety issues. The NRC

has become aware of incidents through insights gained during these inspections and from the

allegation program where workers perceived that individuals were treated negatively by

management for raising issues. As a result of these incidents, some workers expressed

reluctance to raise issues under certain circumstances. While most workers made a distinction

between nuclear safety issues and other concerns, the teams noted that some of the illustrative

examples provided by plant workers could have nuclear safety implications. However, the

teams did not identify any more than minor issues, which had not been raised.Additionally, in June 2006, the NRC referred concerns to you for your information and actioninvolving an alleged potential chilling effect in the Maintenance department. This referral

specifically referenced issues identified in a teamwork assessment of the Instrumentation and

Controls department, conducted in 2005, as well as the preliminary results of an independent

safety culture assessment sponsored by Entergy in early 2006. Our followup during these

inspections found that you had deferred action on the referred concerns pending evaluation of

the Entergy contracted safety culture assessment, and as a result, you had not taken

substantive action at the time of the inspection. Therefore, the team was unable to review or

evaluate your actions to address the potential adverse impact on the safety conscious work

environment within the Maintenance department. We recognize that the information that we received and developed during the inspectionsregarding the willingness of workers to raise issues is generally consistent with the results of

the independent safety culture assessment conducted for Entergy at Indian Point in 2006. We

understand you have taken actions to improve the general plant culture at Indian Point and

there are ongoing initiatives at the site dealing with expectations for workforce performance.

However, we are concerned that at the conclusion of the inspection you had not fully evaluated

the results of the Entergy contracted safety culture assessment to understand the causes of the

negative responses and declining trends related to the safety conscious work environment

onsite. As a result, the NRC requests that Entergy provide its plan for evaluating the potential

chilling effect onsite and its plan of action for addressing this matter to the NRC. Based on our

discussions of December 14, 2006, it is our understanding that Entergy agrees to provide this

information within 30 days of the date of this letter. Following receipt and review of the Entergy

response, we will determine if a meeting is needed to discuss your approach, schedule, and

NRC oversight. This issue will be included as an input to our assessment of plant performance

as described in Inspection Manual Chapter 0305, "Operating Reactor Assessment Program."In addition to the above observations, there were three Green findings identified by theinspectors during these inspections: two findings at Unit 2 and one finding common to both

units. Two of the findings were determined to be violations of NRC requirements. However,

because of their very low safety significance and because they were entered into your

corrective action program, the NRC is treating these findings as Non-Cited Violations (NCVs), in

accordance with Section VI.A.1 of the NRC's Enforcement Policy. If you deny any of these

NCVs, you should provide a response with the basis for your denial, within 30 days of the date

of this inspection report, to the U.S. Nuclear Regulatory Commission, ATTN.: Document

Control Desk, Washington DC, 20555-0001, with copies to the Regional Administrator,

Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission,

Washington, DC, 20555-0001; and the NRC Resident Inspector at the Indian Point facility.

3F. DacimoIn accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter andyour response will be made available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC's

document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).Because your response will be made available electronically for public inspection in the NRCPublic Document Room or from the PARS component of ADAMS, to the extent possible it

should not include any personal privacy, proprietary, or safeguards information so that it can be

made available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your withholding claim (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.If you have any questions regarding these matters, please contact Eugene Cobey at(610) 337-5171.Sincerely,/RA/David C. Lew, DirectorDivision of Reactor Projects

Region IDocket Nos. 50-247 and 50-286License Nos. DPR-26 and DPR-64Enclosures: Inspection Report Nos. 05000247/2006006 and 05000286/2006006w/Attachments: Supplemental Informationcc w/encl:G. J. Taylor, Chief Executive Officer, Entergy Operations

M. R. Kansler, President, Entergy Nuclear Operations Inc. (ENO)

J. T. Herron, Senior Vice President and Chief Operations Officer (ENO)

C. Schwarz, Vice President, Operations Support (ENO)

P. Rubin, General Manager Operations (ENO)

O. Limpias, Vice President, Engineering (ENO)

J. McCann, Director, Licensing (ENO)

4F. DacimoC. D. Faison, Manager, Licensing (ENO)M. J. Colomb, Director of Oversight (ENO)

J. Comiotes, Director, Nuclear Safety Assurance (ENO)

P. Conroy, Manager, Licensing (ENO)

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

P. R. Smith, President, New York State Energy, Research and Development Authority

P. Eddy, Electric Division, New York State Department of Public Service

C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law

D. O'Neill, Mayor, Village of Buchanan

J. G. Testa, Mayor, City of Peekskill

R. Albanese, Four County Coordinator

S. Lousteau, Treasury Department, Entergy Services, Inc.

Chairman, Standing Committee on Energy, NYS Assembly

Chairman, Standing Committee on Environmental Conservation, NYS Assembly

Chairman, Committee on Corporations, Authorities, and Commissions

M. Slobodien, Director, Emergency Planning

B. Brandenburg, Assistant General Counsel

Assemblywoman Sandra Galef, NYS Assembly

County Clerk, Westchester County Legislature

A. Spano, Westchester County Executive

R. Bondi, Putnam County Executive

C. Vanderhoef, Rockland County Executive

E. A. Diana, Orange County Executive

T. Judson, Central NY Citizens Awareness Network

M. Elie, Citizens Awareness Network

D. Lochbaum, Nuclear Safety Engineer, Union of Concerned Scientists

Public Citizen's Critical Mass Energy Project

M. Mariotte, Nuclear Information & Resources Service

F. Zalcman, Pace Law School, Energy Project

L. Puglisi, Supervisor, Town of Cortlandt

Congresswoman Sue W. Kelly

Congresswoman Nita Lowey

Senator Hillary Rodham Clinton

Senator Charles Schumer

J. Riccio, Greenpeace

A. Matthiessen, Executive Director, Riverkeeper, Inc.

M. Kaplowitz, Chairman of County Environment & Health Committee

A. Reynolds, Environmental Advocates

M. Jacobs, Director, Longview School

D. Katz, Executive Director, Citizens Awareness Network

P. Leventhal, The Nuclear Control Institute

K. Coplan, Pace Environmental Litigation Clinic

W. DiProfio, PWR SRC Consultant

D. C. Poole, PWR SRC Consultant

W. Russell, PWR SRC Consultant

W. Little, Associate Attorney, NYSDEC

R. Christman, Manager Training and Development

3F. DacimoBecause your response will be made available electronically for public inspection in the NRC Public Document Room or from the PARS component of ADAMS, to the extentpossible it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacyor proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be

protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your

response that you seek to have withheld and provide in detail the bases for your withholding claim (e.g., explain why the disclosure of information will create an unwarrantedinvasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). Ifsafeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.If you have any questions regarding these matters, please contact Eugene Cobey at (610) 337-5171.Sincerely,/ra/David C. Lew, DirectorDivision of Reactor Projects

Region IDocket Nos. 50-247 and 50-286License Nos. DPR-26 and DPR-64Enclosures: Inspection Report Nos. 05000247/2006006 and 05000286/2006006w/Attachments: Supplemental Informationcc w/encl:G. J. Taylor, Chief Executive Officer, Entergy Operations

M. R. Kansler, President, Entergy Nuclear Operations Inc. (ENO)

J. T. Herron, Senior Vice President and Chief Operations Officer (ENO)

C. Schwarz, Vice President, Operations Support (ENO)

P. Rubin, General Manager Operations (ENO)

O. Limpias, Vice President, Engineering (ENO)

J. McCann, Director, Licensing (ENO)

C. D. Faison, Manager, Licensing (ENO)

M. J. Colomb, Director of Oversight (ENO)

J. Comiotes, Director, Nuclear Safety Assurance (ENO)

P. Conroy, Manager, Licensing (ENO)

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

P. R. Smith, President, New York State Energy, Research and Development

Authority

P. Eddy, Electric Division, New York State Department of Public Service

C. Donaldson, Esquire, Assistant Attorney General, New York Department of

Law

D. O'Neill, Mayor, Village of BuchananJ. G. Testa, Mayor, City of Peekskill

R. Albanese, Four County Coordinator

S. Lousteau, Treasury Department, Entergy Services, Inc.

Chairman, Standing Committee on Energy, NYS Assembly

Chairman, Standing Committee on Environmental Conservation, NYS Assembly

Chairman, Committee on Corporations, Authorities, and Commissions

M. Slobodien, Director, Emergency Planning

B. Brandenburg, Assistant General Counsel

Assemblywoman Sandra Galef, NYS Assembly

County Clerk, Westchester County Legislature

A. Spano, Westchester County ExecutiveR. Bondi, Putnam County ExecutiveC. Vanderhoef, Rockland County Executive

E. A. Diana, Orange County Executive

T. Judson, Central NY Citizens Awareness Network

M. Elie, Citizens Awareness Network

D. Lochbaum, Nuclear Safety Engineer, Union of Concerned Scientists

Public Citizen's Critical Mass Energy Project

M. Mariotte, Nuclear Information & Resources Service

F. Zalcman, Pace Law School, Energy Project

L. Puglisi, Supervisor, Town of Cortlandt

Congresswoman Sue W. Kelly

Congresswoman Nita Lowey

Senator Hillary Rodham ClintonSenator Charles Schumer

J. Riccio, Greenpeace

A. Matthiessen, Executive Director, Riverkeeper, Inc.

M. Kaplowitz, Chairman of County Environment & Health Committee

A. Reynolds, Environmental Advocates

M. Jacobs, Director, Longview School

D. Katz, Executive Director, Citizens Awareness Network

P. Leventhal, The Nuclear Control Institute

K. Coplan, Pace Environmental Litigation Clinic

W. DiProfio, PWR SRC Consultant

D. C. Poole, PWR SRC Consultant

W. Russell, PWR SRC Consultant

W. Little, Associate Attorney, NYSDEC

R. Christman, Manager Training and DevelopmentDistribution w/encl:

(VIA E-MAIL)

S. Collins, RAM. Dapas, DRA

J. Clifford, DRP

D. Lew, DRP

B. Sosa, RI OEDO

E. Cobey, DRP

D. Jackson, DRP

B. Sienel, DRP

T. Walker, DRP

M. Cox, DRP, IP2 Senior ResidentG. Bowman , DRP, Acting IP3 Senior ResidentC. Hott, DRP, Acting IP2 Resident InspectorB. Wittick, DRP, IP3 Resident Inspector

R. Martin, DRP, Resident OA

P. Krohn, DRP

B. Norris, DRP

J. Boska, PM, NRR

R. Laufer, NRR

J. Anderson, NRR

D. Holody, ORA

Region I Docket Room (with concurrences)

ROPreports@nrc.govSUNSI Review Complete: EWC (Reviewer's Initials

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