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:	Gray M K Reactor Projects Branch 2
To:	Pollock J E Entergy Nuclear Operations
References
IR-11-010
Download: ML112570059 (29)

Text

{{#Wiki_filter: ; with copies to theRegional Administrator, Region 1; the Director, Office of Enforcement, United States NuclearRegulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspectorat Indian Point Nuclear Generating Unit 3. In addition, if you disagree with the cross-cuttingaspect assigned to any finding in this report, you should provide a response within 30 days ofthe date of this inspection report, with the basis for your disagreement, to the RegionalAdministrator, Region 1, and the NRC Senior Resident Inspector at Indian Point NuclearGenerating Unit 3. ln accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rulesof Practice," a copy of this letter, its enclosure, and your response (if any) will be availableelectronically for public inspection in the NRC Public Document Room or from the PubliclyAvailable Records (PARS) component of the NRC's document system (ADAMS). ADAMS isaccessible from the NRC Web Site at http://rnnrrrw.nrc.sov/reading-rm/adams.html (the PublicElectronic Reading Room).

Sincerely,k/'-A -V^oy.-,rMelGray, ChiefProjects Branch 2Division of Reactor ProjectsDocket No. 50-286License No. DPR-26

Enclosure:

Inspection ReportNo. 05000286/2011010M

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 identifiedtwo 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.Two findings of very low significance (Green) were identified. One finding was also determinedto be a non-cited violation [Ncvy of trtilc requirements. The significance of most findings isindicated by their color (Grben, \rvhite, Yellow, Red) using Inspection Manual Chapter (lMC)0609, ,,significance Determination Process." Findings for which the significance determinationprocess tsopl does not apply may be Green, or be assigned a severity level after NRCmanagement ieview. The cross-cutting aspects for the findings were determined using IMC0310, "Components within the Cross-Cutting Areas.' fng NRC's program for overseeing safeoperation of commercial nuclear power reactors is described in NUREG-1649, "ReactorOversight Process," Revision 4, dated December 2006'ldentification and Resolution of ProblemsThe inspectors concluded that Entergy was generally effective in identifying, evaluating, andresolving problems. Entergy personnet iOeniified problems, entered them into the correctiveaction piogram at a low thre*shold, and prioritized issues commensurate with their safetysignificancl. In most cases, Entergy personnel appropriately screened issues,for operabilityarid reportability, and performed ca-usal analyses that appropriately considered extent ofcondition, generic issues and previous occuirences. The inspectors also determined thatEntergy stJff typically implemented corrective actions to address the problems identified in thecorrective action pro6t"r in a timely manner. However, the inspectors identified two findings,one of which was als-o a violation of regulatory requirements, and several weaknesses of minorsafety significance associated with pro-blem identification, evaluation, and prioritization ofcorrective actions.The inspectors concluded that, in general, Entergy adequately identified, reviewed, and appliedrelevant industry operating experience to Indian Point Nuclear Generating Unit 3 operations' Inaddition. based on those ilems selected for review, the inspectors determined that Entergy'saudits and self-assessments were thorough.Based on the interviews the inspectors conducted over the course of the inspection,observations of plant activities, and reviews of individual cAP and employee concerns programissues, the inspectors did not identify any indications that site personnel were unwilling to raisesafety l.ru", nor oio they identify conditions that could have had a negative impact on the site'ssafety conscious work environment.

Cornerstone: Mitigating SYstems.

Green.

The inspectors identified a finding of very low safety significance (Green) becauseEntergy personnel did not adequately imptemeni the procedural requirements of EN-DC-1 15, ,*ngineering Change Process,'i during the installation of a modification to the 33instrument air deiiccantiryer. Specifically, Entergy staff incorrectly replaced fuses in themotor control center(MCC] which powers the dryer with smaller capacity fuses, rather thanEnclosure 3replacing existing control power fuses in the dryer control panel with fuses of increasedcapacityl as inteided by the design change. As a result, the fuses in the MCC performedtheir intended function ind burned out, deenergizing the dryer, and leading to excessiveunavailability of the dryer and high humidity air in the instrument air header. Entergy staffentered this issue into their corrective action process as condition report (cR)-lP3-2011-03798.The inspectors determined the finding was more than minor because the finding was similarto the'more than minor if'statement associated with example 5 b of Inspection ManualChapter (lMC) 0612 Appendix E, "Examples of Minor lssues." Additionally, the finding wasmore than minor because it was associated with the Equipment Performance attribute of theMitigating Systems cornerstone and affected the cornerstone objective to ensure theavailability and capability of systems that respond to initiating events to prevent undesirablecon""qu"nces (i.e., core damage). Specifically, the unavailability of the 33 instrument airdryer caused moist air in the instrument air heider which in turn led to high humidity and lowprersrre alarms on the 33 instrument air header. The inspectors_ evaluated the findingusing IMC 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization ofFindlngs," and determined the finding was of very low safety significance because thefinding was not a Jesign or qualificaiion deficiency, did not represent a loss of system safetyfuncti5n, and did not sireen as potentially risk significant due to external initiating events.This finding had a cross-cutting aspect in tne arel of Human Performance, associated withthe Work Controf attribute. Specifically, Entergy personnel did not adequately coordinatethe planning and implementaiion of tne engineering change process, which involved severalsite departments, and resulted in incorrectly installed fuses and multiple missedopportunities 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, AppendixB, Criterion XVl, "Corrective Action," for Entergy's failure to take adequate corrective actionsfor a condition adverse to quality involving service water (SW) pipes to the emergency dieselgenerators (EDGs). Speciiically, Entergy personnel did not take timely and appropriatecorrective actions ior carbon steel pipe wall thinning on the common SW supply lines to theEDGs. Entergy staff entered this issue into their corrective action process as conditionreport (cR)-lCa-201 1-03g31 . Entergy's short-term corrective actions included a structuralengineering inspection, an operabilit--y evaluation, redirecting the source of continual wetting,anI reprior-itizinblnl sw piping refuibishment work order. subsequent to this inspection,Entergy personiel performed Jltrasonic testing of the affected area on one of the pipes thatthey fincluded was most affected and confirmed that the pipe remained operable.The finding was more than minor because if left uncorrected the performance deficiency hadi^.,!^^ .^,n{{innthe potentLl to lead to a more significant safety concern. Specifically,.the continuing wetting.' 'l.l ^ll. raraahrand associated external corrosion of the pipe without appropriate monitoring. could adverselyimpact the structural integrity of one or both EDG SW supply headers' Ttte^inspectorsevaluated the findin! in aicordance with lnspection Manual Chapter (lMC) 9609'Attachment 0609, Attachment 4, "Phase 1 - initial Screening and Characterization ofFindings," and determined the finding was of very low safety significance (Green) because itwas not a design or lualification def[iency, did not represent a loss of system safetyfunction, and was noi risk significant with iespect to external events' This finding had across-cutting aspect in the irea of problem ldentification and Resolution, associated withthe corrective Action Program attribute. specifically, Entergy personnel did not take timelyEnclosure 4corrective actions to address SW carbon steel pipe wall thinning due to external corrosionand periodically monitor the pipe for further degradation, commensurate with the safetysignificance of the pipe. (P.1(d)) (Section 4OA2'1 .c(2))

5

REPORT DETAILS

4.

4OA2 Problem ldentification and Resolution (71152B- - 1 sample)This inspection constitutes one biennial sample of problem identification and resolutionas defined by Inspection Procedure71152. All documents reviewed during thisinspection are listed in the Attachment to this report'.1a.Inspection ScoPeThe inspectors reviewed the procedures that described Entergy's corrective actionprogram at Indian point Unit 3. To assess the effectiveness of the corrective actionpro!r"t, the inspectors reviewed performance in three primary areas: problemiOeititication, prioritization and evaluation of issues, and corrective actionimplementat'on. The inspectors compared perfo_rmance in these areas to therequirements and standards contained in Title 10, Code of Federal Regulations (10Cfnl part 50, Appendix B, Criterion XVl, "Corrective Action," and Entergy's procedureEN-LI-102, "Coriective Action Process," Revision 16. For each of these areas, theinspectors'considered risk insights from the station's risk analysis and reviewedcondition reports (CRs) selectid across the seven cornerstones of safety in the NRCsReactor Oversighi process. Additionally, the inspectors attended multiple OperationsFocus, Condition Review Group (CRG);and Corrective Action Review Board (CARB)meetings. The inspectors selected items from the following functional areas for review:engine6ring, operations, maintenance, emergency preparedness, radiation protection'chemistry, physical security, and oversight programs'(1) Effectiveness of Problem ldentificationln addition to the items described above, the inspectors reviewed a sample of completedcorrective and preventative maintenance work orders, completed surveillance testprocedures, operator logs, and periodic trend reports. The inspectors also completedfield walkdowns of vario-us plani systems, such as the service water (SW)' auxiliaryfeedwater (AFW), and instrument air systems. Additionally, the inspectors reviewed aslmpte of condition reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experiencefrogr"r. The inspectors c5mpleted this review to verify that Entergy staff enteredconditions adverse to quality into their corrective action program as appropriate'(2) Effectiveness of Prioritization and Evaluation of lssuesThe inspectors reviewed the evaluation and prioritization of a sample of cRs issuedsince the last NRC biennial problem ldentification and Resolution inspection completedin June 2009. The inspectors also reviewed cRs that were assigned lower levels ofiign6i"un"e that did not include formal cause evaluations to ensure that they wereEnclosure

6properly classified. The inspectors' review included the appropriateness of the assignedsignificince, the scope and depth of the causal analysis, and the timeliness ofresolution. The inspectors assessed whether the evaluations identified likely causes forthe issues and developed appropriate corrective actions to address the identifiedcauses. Further, the inspectors reviewed equipment operability determinations,reportability assessments, and extent-of-condition reviews for selected problems toverify these processes adequately addressed equipment operability, reporting of issuesto the NRC, and the extent of the issues'(3) Effectiveness of Corrective ActionsThe inspectors reviewed Entergy's completed corrective actions through documentationreview and, in some cases, field walkdowns to determine whether the actions addressedthe identified causes of the problems. The inspectors also reviewed CRs for adversetrends and repetitive problems to determine whether corrective actions were effective inaddressing the broader issues. The inspectors reviewed Entergy's timeliness inimplemeniing corrective actions and effectiveness in precluding recurrence for significantconditions adverse to quality. The inspectors also reviewed a sample of CRs associatedwith non-cited violations (NCVs) and findings to verify that Entergy personnel properlyevaluated and resolved these issues. In addition, the inspectors expanded thecorrective action review to five years to evaluate Entergy's actions related to conditionsadverse to quality associated with SW system corrosion, instrument air systemperformance, and AFW system performance'b. Assessment(1) Effectiveness of Problem ldentificationBased on the selected samples reviewed, plant walkdowns, and interviews of sitepersonnel, the inspectors determined that Entergy personnel identified problems andentered them into the CAP at a low threshold. For the issues reviewed, the inspectorsdetermined that problems or concerns were generally documented in sufficient detail tounderstand the issues. The inspectors observed managers and supervisors at CRG andCARB meetings appropriately questioning and challenging CRs to ensure clarification ofthe issues. The inspectors determined Entergy personnel trended equipment andprogrammatic issues at low levels and CR descriptions appropriately included referenceio repeat occurrences of issues. ln general, the inspectors did not identify issues orconcerns that had not been appropriately entered into the CAP for evaluation andresolution. However, the inspectors identified the following example of a minor issuethat was not adequately identified by Entergy staff. Entergy staff promptly entered theissue into the CAP for resolution.. The inspectors identified that Entergy personnel performed maintenance on threeAFW 1ow control valves during tne 2Ot 1 refueling outage, but did not perform therequired post maintenance tests (PMTs) on the valves prior to declaring the AFWsystem operable. The inspectors also identified the PMTs were not correctlyscheduled to be completed after the maintenance that occurred during the outage'The inspectors noted that Entergy personnel subsequently satisfactorily stroked theEnclosure 7valves during the next normally scheduled, quarterly AFW in-service testingapproximately one week later.The inspectors determined that the missed PMT for the valves was a performancedeficiency. However, because the subsequent valve stroke times a week laterindicated that the AFW valves were operable, the inspectors determined that theissue was of minor significance and not subject to enforcement action in accordancewith the NRCs Enforcement Policy. Entergy staff initiated CR-IP3-2011-03815 forthis performance deficiency.(2) Effectiveness of Prioritization and Evaluation of lssuesThe inspectors determined that, in general, Entergy personnel appropriately prioritizedand evaluated issues commensurate with their safety significance. CRs were screenedfor operability and reportability, categorized by significance, and assigned to adepartment for evaluation and resolution. The CR screening process considered humanperformance issues, radiological safety concerns, repetitiveness, and adverse trends.The inspectors observed managers and supervisors at CRG and CARB meetingsappropriately questioning and challenging CRs to ensure appropriate prioritization.The inspectors determined that CRs were generally categorized for evaluation andresolution commensurate with the significance of the issues. Based on the sample ofCRs reviewed, the guidance provided by the Entergy implementing proceduresappeared sufficient to ensure consistency in categorization of the issues. Operabilityand reportability determinations were generally performed when conditions warrantedand the evaluations supported the conclusions. Causal analyses appropriatelyconsidered the extent of the condition or problem, generic issues, and previousoccurrences of the issue.Notwithstanding these conclusions, the inspectors identified the following examplewhere the evaluation of a repeat issue was not commensurate with the potentialsignificance of the issue.e Based on a nuclear plant operator (NPO) log and CAP database review, theinspectors noted that on several occasions NPOs documented degraded conditionsregarding 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 theseconditions had existed for six months. The inspectors determined that Entergy staffmissed an opportunity to trend these conditions and ensure conditions wereappropriately addressed in a timely manner consistent with CAP expectations.However, because none of the leaks or housekeeping conditions challenged orimpacted equipment important to safety, the inspectors determined that the issueswere of minor significance and not subject to enforcement action in accordance withthe NRCs Enforcement Policy. Entergy staff documented this issue in CR-lP3-2011-03295.Enclosure I(3) Effqcjivene,ss oJ C-orrective AptionsThe inspectors concluded that corrective actions for identified deficiencies weregenerally timely and adequately implemented. For significant conditions adverse toquality, corrective actions were identified to prevent recurrence. The inspectorsconcluded that corrective actions to address the sample of NRC NCVs and findingssince the last problem identification and resolution inspection were timely and effective.The inspectors noted, based on the samples inspected, that Entergy staff completedeffectiveness reviews for significant issues to verify that implemented corrective actionswere effective. However, the inspectors identified two issues (replacement of incorrectfuses associated with the 33 instrument air dryer, and ineffective actions taken toaddress leakage from a SW vacuum breaker that was causing corrosion issues) that hadcontributed to findings that were determined to be more than minor (Green). Thesefindings 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 33Inslrument Air DrverIntroduction: The inspectors identified a finding of very low safety significance (Green)because Entergy personnel did not adequately implement the procedural requirementsof EN-DC-115, "Engineering Change Process," during the installation of a modification to33 instrument air desiccant dryer.Description: Entergy personnel developed Engineering Change (EC) 8501 to preventintermittent failures of the 33 instrument air desiccant dryer blower motor due to highmotor inrush currents during startup. Based on a vendor recommendation, the ECdirected 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 ampfuseslrom 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 electriciansproceeded to replace the 15 amp fuses with the new six amp fuses. When theinstrument air dryer was reenergized, the six amp fuses, which did not have sufficientamperage capacity for the MCC application, performed their intended function andburned out, deenergizing the dryer. The dryer remained deenergized and unavailablefor a period of approximately two weeks until Entergy personnel found water in the airsupply to BFD-PCV-3, the steam generator blowdown recovery outlet backpressurecontroller. Upon troubleshooting the water issue, Entergy personnelfound andcorrected the undersized fuses in 33 MCC and placed the dryer back in service. OnJune 9, 2011, the four amp fuses in the dryer control panel were correctly replaced withsix amp fuses, in accordance with the EC. This issue was previously entered intoEntergy'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 alreadytaken, which included correcting the fuse error and coaching personnel to read the ECdocumentation more thoroughlY.Enclosure 9The inspectors questioned the causes of humidity and low pressure alarms on the 33instrument air header, which had been documented in condition reports initiated in Juneand July 2011. Through interviews with the system engin-eer, the inspectors learned thatafter the fuse issue ha-d been resolved, troubleshooting of high humidity and lowpressure alarms on the 33 instrument air header had revealed that the 33 instrument airdryer had been degraded by moisture passing into the air header while the dryer hadbeen unavailable due to the blown fuses. Degradation of the dryer's tower swappingmechanism allowed air to partially bypass the dryer, thereby causing lhe high humidityand low pressure alarms. 'The inspectors noted that additional unavailability of the dryerwas acciued while Entergy personnel performed troubleshooting and repair of thedegraded dryer. Based on ine inspectors' questioning, lltergy personneldocumentedthjissue as a maintenance rule functional failure of the 33 instrument air dryer andcalculated the total cumulative unavailability of the dryer attributed to the modificationerror. The calculated unavailability was 580 hours, which exceeded the licensee'sestablished 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 identifiedseveral examples where Entergy personnel did not implement the requirements of themodification process. First, the EC package incorrectly identified the location of thefuses, and tfris error was translated into the work package which was used bymaintenance personnelwho implemented the EC. Specifically, the Post ModificationTest plan pait age stated that the four amp fuses were located in the 33 MCC'Additionally, the maintenance personnelwho implemented the EC did not follow the fuseverification procedure when removing the 15 amp fuses from the MCC and prior toreinstalling ihe six amp fuses. Finally, the PMT was not performed in a timely manner inthat the 3i instrumentair train was piaced back in service without a PMT having beenperformed. The inspectors determined that each of these examples had beenopportunities, or "barriers", built into the Engineering change process, through whicheniergy personnel could have either prevented or recognized the error and avoided thecumulative unavailability of the instrument air dryer and associated moist air in the airheader.The inspectors determined these problems were not identified by Entergy personnel'Entergy staff entered this issue inio their CAP as CR-lP3-2011-03798' PlannedcorreJtiue actions include performing an Apparent Cause Evaluation for the issue.Analvsis: The inspectors determined that the issue was a performance deficiencyo-e Entergy personnel did not follow procedures to.effectively implement theengineering cnihge to the 33 instrument air dryer. The inspectors determined that thefinjing was-morelhan minor because the finding was similar to the "more than minor if'statement associated with example 5.b of Inspection Manual chapter (lMc) 0612Appendix E, ,,Examples of Minor lssues." Additionally, the finding was more than minorbecause it was associated with the Equipment Performance attribute of the MitigatingSystems cornerstone and affected the cornerstone objective to ensure the availabilityano capauility of systems that respond to initiating events to prevent undesirableconsequences (i.e., core damage). Specifically, the unavailability of the 33 instrumentair dryer resulted in moist air in the instrument air header which in turn led to highEnclosure 10humidity and low pressure conditions on the 33 instrument air header. The inspectorsevaluated the finding using IMC 0609, Attachment 4, "Phase 1 - lnitial Screening andCharacterization of Findings," and determined the finding was of very low safetysignificance (Green) becaJse the finding was not a !9sio1 or qualification deficiency, didnJt ,"pr"r"ni a loss of system safety function, and did not screen as potentially risksignificant due to external initiating events.The inspectors determined that the finding had a cross-cutting aspect in the area ofHuman performance, associated with the Work Control attribute, because Entergypersonnel did not appropriately coordinate work activities by incorporating actions toaddress: 1) the n"eO tor workgroups to communicate, coordinate, and cooperate witheach otherduring activities in wnicn interdepartmental coordination is necessary toassure plant and human performance; and 2) the need to keep personnel apprised ofwork status and the operational impact of work activities. Specifically, Entergy personneldid not adequately coordinate the planning and implementation of the engineeringclrange process, which involved several site departments, and resulted in incorrectlyinstalTed'fuses and multiple missed opportunities to both prevent and subsequentlyidentify the error. (H.3(b))Enforcement: Enforcement does not apply because the performance deficiency did notinvolve a violation of regulatory requirements. The instrument air system is not a safetyr"l"t"O system and 10 Cfn pirt 50 Appendix B requirements are not applicable.Because this issue does not involve a violation of regulatory requiremenls 91{ is of verytow 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 adequatecoirective actions for a condition adverse to quality involving SW pipes to the EDGs'Specifically, Entergy personnel did not take timely and appropriate corrective actions forcarbon 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 lineffi breaker (SWN-6g) ported water into the piping pit in the EDG valve room, whichinJirectly sprayed'the bottom of both redundant EDG SW supply pipe headers' Theinspectors'not-eo that this portion of both 1o-inch diameter sw supply headers wascontinuously wetted over a length of approximately two fe_et. The inspectors noted thatthe vacuum breaker had been leaking since February 2009. Based on the corrodedcondition of the bottom portion of both headers and the quantity of accumulated rustflakes/pieces beneath both headers, the inspectors questioned the condition of thesepipes.Entergy personnel informed the inspectors that they had originally identifled the externalcorrosion on the SW supply lines aithat specific location on Septembgr 30, 2008 (CRLp3-2008-02383). Tne inspectors reviewed CR-;P3-2008-02383 and Entergy'sassociated corrective actions and noted the following: (1) the CR initiator, operations,and cRG screened the cR as not requiring an operability review (thus no operabilityEnclosure 11review was performed for this safety-related SW piping degraded condition); (2) CRGclassified the CR as significance "D" and closed the CR to WO 166970; (3) WO 166970was created to clean, repaint and inspect the piping per the external corrosionmonitoring 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 inspectorsrequested operability evaluations of this degrading condition, other associated CRs,documented inspections (including ultrasonic tests) or trending reports, and anyassociated WOs since October 2008. Entergy personnel stated that no additionaldocumented information was identified but indicated that the system engineersperiodically inspected the piping during their walkdowns.Based on the inspectors' questions, Entergy staff initiated CR-lP3-2011-03831. Entergystructural engineering personnel inspected the piping on July 21. Based on their inputregarding iron oxide exfoliation, an estimate of SW piping wall loss and no leakage,engineering personnel determined that the structural integrity of the pipe was notaffected and that the pipe remained operable. The inspectors reviewed Entergy'soperability evaluation and determined that it was adequate based on the informationavailable. Entergy's short-term corrective actions also included redirecting the vacuumbreaker discharge to a local sump (completed on August 2) and reprioritizing the SWpiping refurbishment work order (scheduled to work in 2011). Subsequent to thisinspeition, Entergy personnel performed ultrasonic testing of the affected area on one ofthe pipes that they concluded was most affected and confirmed that the pipe remainedoperable.Analvsis. The inspectors determined that Entergy's failure to take adequate correctiveactions for an adverse condition associated with the EDG SW supply piping was aperformance deficiency that was reasonably within Entergy's ability to foresee andprevent. Specifically, Entergy personnel did not take timely and appropriate correctiveactions commensurate with the safety significance of a potential common mode failure ofall three EDGs due to carbon steel pipe wall thinning on the common SW supply. Thefinding was determined to be more than minor because if left uncorrected theperformance deficiency had the potential to lead to a more significant safety concern.Specifically, the continuing wetting and associated external corrosion of the pipe withoutappropriate monitoring could adversely impact the structural integrity of one or both EDGSW supply headers. The inspectors evaluated the finding in accordance with IMC 0609,Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings,"Table 4afor the Mitigating Systems Cornerstone. The inspectors determined that thefinding was of very low safety significance (Green) because it was not a design orqualification deficiency, did not represent a loss of system safety function, and was notrisk significant with respect to external events.This finding had a cross-cutting aspect in the area of Problem ldentification andResolution, associated with the Corrective Action Program attribute, because Entergypersonnel did not take appropriate corrective actions to address an adverse trend in atimely manner, commensurate with the safety significance. Specifically, Entergypersonnel did not take timely corrective actions to address SW carbon steel pipe wallifrinning due to external corrosion, such as eliminating the source of the wetting byredireciing the flow of water, evaluating the as-found structural integrity of the pipe, andEnclosure

.3 a.13However, the inspectors noted that, as of July 2Q11, Entergy had an open actionitem in their CAP to perform an OE review of NRC Information Notice 2011-12,"Reactor Trips Resulting from Water Intrusion into Electrical Equipment," which theNRC 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 theOE regarding roof leaks, the inspectors determined that the performance aspectsregarding this issue were of minor significance and not subject to enforcement actionin accordance with the NRCs Enforcement Policy.FindinqsNo findings were identified.Assessment of Self-Asqegsmentg and AuditsInspection ScopeThe inspectors reviewed a sample of Quality Assurance (aA) audits, including a reviewof several of the findings from the most recent audit of the CAP, and self-assessmentsfocused on various plant programs. These reviews were performed to determine ifproblems identified through these assessments were entered into the CAP, whenappropriate, and whether corrective actions were initiated to address identifieddeficiencies. The effectiveness of the audits and assessments was evaluated bycomparing audit and assessment results against self-revealing and NRC-identifiedobservations made during the inspection.AssessmentThe inspectors concluded that QA audits and self-assessments were critical, thorough,and generally effective in identifying issues. The inspectors observed that these auditsand self-assessments were completed by personnel knowledgeable in the subject areasand were completed to a sufficient depth to identify issues that were then entered intothe CAP for evaluation. Corrective actions associated with the issues were implementedcommensurate with their safety significance.FindinqsNo findings were identified.Assessment of Safetv Conscious Work Environmentlnspection ScopeDuring interviews with station personnel, the inspectors assessed aspects of the safetyconscious work environment at Indian Point Unit 3. Specifically, as part of personnelinterviews during the inspection, the inspectors asked questions to identify whetherstation personnel were hesitant to raise safety concerns to their management and/or theNRC. The inspectors also interviewed the station Employee Concerns Program (ECP)b..4a.Enclosure

14coordinator to determine what actions were implemented to ensure employees wereaware of the program and its availability with regard to raising concerns. The inspectorsreviewed a numder of ECP files to ensure that issues were entered into the CAP whenappropriate.b. AssessmentDuring interviews, plant staff expressed a willingness to use the CAP to identify plantissueJ and deficiencies and indicated that they were willing to raise safety issues. Theinspectors noted that no one interviewed stated that they personally experienced or wereaware of a situation where there were indications an individual had been hesitant toraise a safety issue. All persons interviewed demonstrated an adequate knowledge ofthe CAp unO gCp. Based on these limited interviews, the inspectors concluded thatthere was no evidence of significant challenges to the free flow of information regardingsafety concerns.c. FindinqsNo findings were identified.4046 Meetinqs. lncludinq ExitExit Meetinq SummarvOn August 5,2011, the inspectors presented the inspection results-to Mr' Josephpollocli, Site Vice President, and other members of the Entergy staff' The inspectorsreviewed proprietary information, which was returned to Entergy staff at the end of theinspection. The inspectors verified that no proprietary information was retained by theinspectors or documented in this report.ATTACHMENT:

SUPPLEMENTAL INFORMATION

Enclosure Enterqv Personnel

J. PollockR. AguiarB. AltadonnaJ. BencivengaM. BurneyP. ConroyK. CurleyG. DahlM. FerrettiE. FirthD. GagnonM. HaggstromC. HasenbeinT. lavicoliR. JohnsonJ. LaffertyR. MartinF. PhilipsJ. ReynoldsB. SchmidtB. TaggartM. TumickiJ. VentosaA-1SUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTSite Vice PresidentSecurity SupervisorPrograms and Components EngineerDesign EngineeringLicensing SpecialistDirectorProperty "Contact" (as page type) with input value "J. PollockR. AguiarB. AltadonnaJ. BencivengaM. BurneyP. ConroyK. CurleyG. DahlM. FerrettiE. FirthD. GagnonM. HaggstromC. HasenbeinT. lavicoliR. JohnsonJ. LaffertyR. MartinF. PhilipsJ. ReynoldsB. SchmidtB. TaggartM. TumickiJ. VentosaA-1SUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTSite Vice PresidentSecurity SupervisorPrograms and Components EngineerDesign EngineeringLicensing SpecialistDirector" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Nuclear Safety AssuranceSystem EngineerLicensing SpecialistMaintenance SupervisorManager, Corrective Action & AssessmentSite Security ManagerSystem EngineerSystem EngineerRadiation Protection SpecialistMaintenance SupervisorSystem Engineering SupervisorSenior Planner, Emergency PlanningSenior Planner, Emergency PlanningCorrective Action & Assessment SpecialistOperationsEmployee Concerns Program CoordinatorCorrective Action & Assessment SpecialistGeneral Manager, Plant Operations

A-2LIST OF ITEMS OPENED, CLOSED AND DISCUSSEDOpened and Closed05000286/201 1 01 0-0105000286/2011010-02FINNCVProcedural Requirements of Engineering ChangeProcess Not lmplementedInadequate Corrective Action for Degraded EDGSW PipingAttachment A-3LIST OF DOGUMENTS REVIEWEDSection 4OA2: ldentification and Resolution of ProblemsAudits and Self-AssessmentsLO-lP3LO-2009-00067, "Plant Status and Configuration Control - IPEC Snapshot Self-Assessment Report," dated December 12,2009LO-lP3LO-2009-00071, "QA NIEP Audit Criteria - IPEC Focused Self-Assessment Report,"dated July 13,2009LO-lP3LO-2010-00008, "Quality of CR Closures Performed by Department lmprovementCoordinators (DPlCs) - IPEC Snapshot Self-Assessment Report," dated December 31,2010LO-lP3LO-2010-00074, "Conduct of Operations - IPEC Snapshot Self-Assessment Report,"dated November 13,2010LO-lP3LO-2010-00157, "Tone Alert Radio Program Administration and Recordkeeping - IPECSnapshot Self-Assessment Report," dated May 10,2010LO-lP3LO-2011-00023, "Operations Facilities and Equipment - IPEC Snapshot Setf-Adsessment Report," dated June 1 ,2011LO-lP3LO-2010-00035, "Snapshot Self-Assessment on Access Controls," dated May 26,2Q10LO-lP3_LO-2010-00078, "Focused Self-Assessment on Closed Cooling Water Chemistry," datedTtAay 14,2010LO-lP3LO-201 0-00045, "Fatigue Rule Compliance", dated February 23, 2010LO-lP3LO-2010-00196, "Preventive Maintenance (PM) Feedback," dated September 28,2010QA-07-2011-lP-1, "Emergency Preparedness (EP) Quality Assurance Audit Report," dated June13,2011QA-12-2009-lP-1, "Operations/Technical Specifications Quality Assurance Audit Report," datedAugust 3, 2009QA-04-2010-lP-1, "Engineering Design Control Quality Assurance Audit Report," dated May 27,2010QA-10-2010-1P-1 , "Maintenance Quality Assurance Audit Report," dated October 13, 2010QA-01-2009-lP-1, "Fitness for Duty Quality Assurance Audit Report," dated August 20,20QgQA-1 6-2009-l P-1, "Security Quality Assurance Audit Report," dated December 17, zQQgQA-16-2010-lP-1, "security Quality Assurance Audit Report," dated February 9,2011CalculationslP3-CALC-SWS-02022, "Operability Determination and Supports Repair in the Zurn Pit,"Revision 0lP-CALC-08-00118, "Evaluation of Through Wall Leak for Tee Downstream of SWN-38 for Line408," Revision 0Completed Surveillances3-PT-M079A, "31 EDG Functional Test," performed May 15,2011 and June 16, 20113-PT-M0798, "32 EDG Functional Test," performed May 17, 2011 and June 13, 20113-PT-M079C, "33 EDG Functional Test," performed June 14,20113-PT-Q120F, "32 ABFP (Turbine Driven) Surveillance and lST," performed April 15, 20113-PT-Q134A, "31 RHR Pump FunctionalTest (RHR Cooling Not in Service)," performed June 3,2011Attachment A-43-PT-Q1348,"32 RHR Pump Functional Test (RHR Cooling Not in Service)," performed June29,20113-PT-R0078, "32 ABFP Full Flow Test," performed April 6, 201 13-PT-R090E, "Local Operation of 32 ABFP," performed July 5,20113-PT-R1604, "31 EDG Capacity Test," performed March 29,20113-PT-R1608,"32 EDG Capacity Test," performed March 29,20113-PT-R160C, "33 EDG Capacity Test," performed March 20,20113-PT-R189A, "Functional Test of 31 Automatic Trips," performed March 24,20113-PT-R189B, "Functional Test of 32 Automatic Trips," performed March 28,20113-PT-R189C, "Functional Test of 33 Automatic Trips," performed March 17 , 2Q113-PT-R198,"32 ABFP Turbine Overspeed Test," performed April 1 ,20113-PT-Q1168,"32 Safety Injection Pump," dated July 11,20113-PT-Q1 168, "32 Safety Injection Pump," dated July 12, 2011Condition Reports (CR-lP2-)201 1-03604-2010-007462010-056392010-064972010-06527201 1-00654201 1-0'16082011-016102011-02392201 1-03603.* CR written as a result of this inspectionCondition Reports (CR-lP3-)2003-016002003-0361 32003-042982006-0001 32006-002902006-01 5962006-020712006-040632007-002752007-01 01 02007-015122007-033932007-042122008-003342008-003692008-004092008-004892008-006982008-007172008-01 5892008-020262008-021372008-021 662008-023832008-027872008-030092009-003812009-0051 22009-005722009-023682009-024432009-024622009-025392009-025732009-025872009-026262009-027162AA9-027202009-027912009-028312009-030402009-030892009-031 502009-031772009-0331 12009-033212009-033362009-033412009-033432009-033752009-033862009-034812009-035382009-035462009-035622009-035782009-035902009-037862009-038082009-0381 I2009-038672009-039042009-039082009-039432009-039562009-040062009-040352009-040772009-041232009-042192009-042622009-042812009-042822009-042882009-043592009-044012009-044202009-044502009-044522009-044622009-044822009-044982009-044992009-045022009-045232009-045852009-046072009-046382009-046552009-046932009-046942009-047692009-0481 92009-048672009-048762009-04901201 0-000072010-00045201 0-000602010-00202201 0-002692010-003472010-004102010-00419Attachment 2010-004202010-00421201 0-005492010-00631201 0-00735201 0-00853201 0-008632010-00917201 0-009982010-01028201 0-01 0342010-012172010-012272010-012382010-01433201 0-01 533201 0-01 5432010-016922010-01730201Q-Q1825201 0-01 883201 0-01 8902010-019242010-019642010-020052010-022042010-022312010-022882010-022942010-023312A10-023482010-023762010-023772010-023792010-023842010-02395201 0-023962010-024442010-025012010-025042010-025882010-026142010-Q2617201 0-026902010-027232010-027312010-027552010-02854201 0-029002010-03061201 0-03099201 0-031 092010-031 192010-031412010-032162010-03229201 0-03299201 0-034692010-03478201 0-03554201 0-03686201 0-03687201 0-03696201 0-03859201 1-000182011-00021201 1 -000392011-002052011-002322011-00259201 1-00318201 1-003692011-00394201 1 -003962011-004332011-005742011-00575201 1-005762011-00577201 1-00580201 1 -00858201 1 -008602011-00926201 1-009552011-010282011-01052201 1-010562011-010782011-011072011-011152011-011202011-011362011-011562011-011862011-012462011-012522011-012542011-012602011-01327201 1-01 3302011-013452011-013712011-01377201 1-013982011-014032011-014342011-014472011-014652011-014922011-014962011-015172011-015252011-015882011-016152011-016192011-01745201 1-018692011-019152011-019172011-019292011-019442011-019972011-021312011-021392011-021422011-021462011-022042011-Q22272011-022402011-023052011-023092011-023522011-023582011-023912011-023972011-024032011-024132011-024172011-024742011-024962011-025042011-025202011-025212011-025242011-025942011-026092011-027492011-027672011-027852011-028342011-028352011-028442011-028672011-029182011-02920201 1-030802011-031272011-031482011-031702011-032432011-032802011-03295201 1-033602011-034812011-03522201 1-035612011-03574201 1-035832011-035842Q11-03592201 1-03594201 1-03596201 1-03599201 1 -03609201 1-036132011-03614201 1-036162011-03617201 1-03619201 1-036312011-03632*2011-03648*2011-03654*201 1 -03656.201 1-03663.2011-036642011-03672*2011-036762011-Q3682*201 1-03685.2011-Q37042011-03705.201 1-03709"2011-037132011-037272011-03729*2011-03734.2011-037352011-037592011-03779Attachment 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 inspectionDrawinqs9321-F-20333 Sheets. 1 &2, "Flow Diagram Service Water System," Revisions 50 and 289321-F-20343 Sheets. 1 &2, "Flow Diagram City Water," Revisions 36 and 209321-F-21223, "Flow Diagram Appendix'R'6.9 KV Emergency Diesel Generator Jacket WaterSystem," Revision 39321-F-27533, "Flow Diagram Hydrogen Recombiner System," Revision 129321-F-33733, "Logic Tripping Diagram for RCS Overpressurization Protection System,"Revision 39321-H-20283, "Flow Diagram Jacket Water to Diesel Generators," Revision 22INSUL-50453, "Containment Building Restraint & Support Design Line 62 Insulation Details,"Revision 0Emerqencv Preparedness RelatedBinder #EOF-1, "Emergency Director Emergency Response Organization Position Binder,"updated July 8, 2011Binder #EOF-4, "RadiologicalAssessment Coordinator Emergency Response OrganizationPosition Binder," updated July 8, 2011Binder #EOF-5, "Dose Assessor Emergency Response Organization Position Binder," updatedJuly 8,2011Binder #lCP-1, "Security Coordinator lCP," updated July 8,2011Binder #TSC-1, "Emergency Plant Manager Emergency Response Organization PositionBinder," updated July 8, 2011Binder #TSC-4, "Reactor Engineer Emergency Response Organization Position Binder,"updated July 8, 2011Binder #TSC-8, "TSC Communicator Emergency Response Organization Position Binder,"updated July 8, 2011Drill Number 2008-7 , "Emergency Preparedness Unit 3 Exercise December 3, 2008Performance Report," Revision 0Drill Number 2Q1O-5, "Emergency Preparedness Unit 2 FEMA/NRC Exercise September 14,2010 Performance Report," dated October 12,2010Drill Number 2010-6, "Emergency Preparedness Unit 2 Training Drill December 7, 2010Performance Report," dated December 15,2010Drill Number 2011-1, "Emergency Preparedness Unit 2 Training Drill February 3,2Q11Performance Report," dated February 10,2011Drill Number 2011-2, "Emergency Preparedness Unit 3 SAMG Training Drill June 9,2011Performance Report," dated June 30,2011EN-PL-155 Attachment 9.1, "Notification Forms Revision Change Management Checklist,"dated January 25,2011Form EP-3, "Control Room NOE Notification Checklist," Revision 14Form EP-4, .CCR Initial Notification Checklist - AlerUSAElGE," Revision 13Attachment A-7Form EP-5, "Upgrade/Update Notification - AIeTUSAE/GE Checklist," Revision 11lP-EP-AD33, "IPEC ATI Siren System Quarterly Preventative Maintenance," Revision 6lP-EP-AD34, "IPEC ATI Control Station Semi-Annual Preventative Maintenance," Revision 4lP-EP-AD35, "IPEC ATI Siren Site Annual Preventative Maintenance," Revision 4Siren-01, "Siren Main and Auxiliary Amplifier Board Replacement," Revision 4TSC-1, "lndian Point Energy Center Emergency Telephone Directory," July 2011EvaluationsCR lP2-2009-03701, "Alert Notification System Test Failure Root Cause Analysis Report,"Revision 1CR lP3-2009-02640, "32 Main Boiler Feed Pump Rework Root Cause Analysis Report,"Revision 1CR lP3-2009-02831, "Lifting of Sl-855 Relief Valve During 3PT-Q1168 Functional Test for 32 SlPump Apparent Cause Evaluation," dated July 15,2009CR lP3-2009-02968, "Emergency Plan Contingency Actions with the Seismic MonitoringInstrumentation Out-of-Service Apparent Cause Evaluation," dated August 4,2009CR lP3-2009-04454, "Main Line "A" Phase Fuse Blown to the 33 EDG Auxiliaries in MCC 39Cubicle SBL Apparent Cause Evaluation," dated December 9, 2009CR lP3-2010-01542, "Two Performance Indicator Opportunities Were Missed DuringEmergency Planning Drill Apparent Cause Evaluation," dated June 29, 2010CR lP3-2010-02082, "MIDAS (Meteorological Information and Data Acquisition System)Program Displayed an Incorrect Emergency Classification Apparent Cause Evaluation,"dated August 9, 2010CR lP3-2011-00680, "U3 Service Water Leak Downstream of SWN-6 Root Cause AnalysisReport," Revision 1PMRQ 50068322-02,"1Y INSP HX (Tube-Side) IAW HTX-}Z2-EDG PM Deferral Request,"dated May 19, 2011SW Line 1222Equipment Failure Evaluation, Revision 0Learninq Orqanization Trackino Reports (LO-lP3LO-)201 0-001 64201 0-001 89Licensee Event ReportsLER 0500028612009-009-01, "Loss of a Single Train Neutron Flux Detector N-38 Required forPlant Shutdown Remote from the Control Room due to a Power Supply Failure," datedOctober 29,2010Maintenance Rule. Svstem Health. and Trendinq32 ABFP Oil Analysis Report Summary, dated August 3,2Q10 - July 5,2011lP3-WebCDMS Sample Analysis Results Summary (EDG Fuel Oil), dated July 2,2011 - August1, 2011IPEC Top Ten Equipment Reliability lssues, dated July 14,2011lP-RPT-1 1-00020, 'tMaintenance Rule Structural Monitoring lnspection Report (4th Cycle) forIntake Structure," dated April 15,2011LO-lP3LO2011-00003, "Operations Department Quarterly Trend Report, 4tn Quarter 201Q"Attachment A-8LO-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 14,2011SOP-WDS-O10 Attachment 1, "Containment Sump Flow Daily Average," dated April 1 0, 2011 -July 29,2011Unit #3 Boric Acid Walkdown, performed July 13,2011lP3-RPT-IA-O1891, "Maintenance Rule Basis Document for Instrument Air and Instrument AirClosed Cooling Systems," Revision 0System Health Report Unit 3 AFW, 1" Quarter 2011System Health Report Unit 3 DC, 1't Quarter 2011Miscellaneous3-PT-D001, "CCR TS Rounds," dated July 3-9, 20113-PT-D001C, "Field TS Rounds," dated July 3-9, 20113-RND-CV, "Conventional Rounds," dated July 3-9, 2011, and July 19,20113-RND-NUC, "Nuclear Rounds," dated July 3-9, 2011EN-MA-1 18 Attachment 9.6, "lntake Structure Access Port Line 409 Foreign Material ExclusionComponent Close-Out," dated March 25,2011IPEC Operations Shift Order, dated June 24, 2011, June 27-30 , 2011, July 5-8, 2011, and July11, 2011Log Entries Report, dated June 19-24,2011 and July 3-9, 2011SIPD 1248, "lnstall Status Light on EDG JWPS 1 and 2 Air Start Pressure Switches," datedJune 1,2410TS-MS-003, "Technical Specification for Piping and Equipment Insulation," Revision 8Unit 3 Control Room Deficiency Log, dated June 15,2011Unit 3 Operations Feedback Report for Group 3-AOP, dated July 13,2011Unit 3 Operations Feedback Report for Group 3-ARP, dated July 13,2011Unit 3 Operations Feedback Report for Group 3-ECA, dated July 13,2011EC 8501, "Replace existing Gould Shawmut model number TRS4R fuses for 33 Instrument AirDesiccant Dryer Blower Motor with Ferraz Shawmut model number TRSOR fuses,"Revision 0Maintenance Aggregate Index, as of May 2011Non-Outage Fluid Leaks, as of May 2011On-Line Corrective Maintenance Backlog, as of May 2011On-Line Deficient Maintenance, as of May 2011Outage Corrective Maintenance Backlog, as of May 2011Outage Deficient Maintenance, as of May 2011Outage Fluid Leaks, as of May 2011PIR Rework Analysis, as of May 2011Non-Cited Violations and FindinqsFIN 0500028612010003-02, "Failure to Perform an Adequate Operability Evaluation for NeutronDetector N-38 Anomalous Behavior"NCV 0500028612009005-02, "Untimely Compensatory Measures for Degraded EDG PressureSwitches"NCV 05000 286 l 2009005-03, "S i ren Test Fa i I u re"NCV 0500028612009005-04, "Failure to Promptly ldentify and Correct a Molded Case CircuitBreaker Service Life Nonconformance"Attachment A-9NCV 0500028612010004-01, "Untimely Corrective Actions for Degraded Capacitors for the 31Static lnverted'NCV 0500028612010005-03, "Failure of the Offsite Notification Procedure to Meet theRequirements of the Site Emergency Plan"NCV 0500028612010009-01, "lnadequate Design Control of Service Water Strainer Room FloodBarrier"NCV 0500028612010005-01, "Repeated Control Room Air Conditioner Gasket Failures"Non-Destructive Examination ReportslP3-UT-08-034,"18-inch Line-408 U/S Valve SWN-40-2 UT Erosion/Corrosion Examination,"performed August 24, 2008lP3-UT-08-055, "18-inch Line-408 U/S Valve SWN-40-2 UT Erosion/Corrosion Examination,"performed November 10, 2008lP3-UT-09-083, "Gas Intrusion - 4" Line #16 @ Penetration Q - PAB Side of Containment UT"Calibration/Examination," performed July 16, 2009IP3-UT-10-008, "31 SW Pump Discharge 14" Line #1081UT Erosion/Corrosion Examination,"performed February 5, 2Q10lP3-UT-10-009, "32 SW Pump Discharge 14" Line #1082 UT Erosion/Corrosion Examination,"performed February 5, 2010lP3-UT-10-010, "33 SW Pump Discharge 14" Line #1083 UT Erosion/Corrosion Examination,"performed February 5, 2010lP3-UT-10-01 1 , "34 SW Pump Discharge 14" Line #1084 UT Erosion/Corrosion Examination,"performed February 5, 2010IP3-UT-10-012, "35 SW Pump Discharge 14" Line #1085 UT Erosion/Corrosion Examination,"performed February 5, 2010lP3-UT-10-013, "36 SW Pump Discharge 14" Line #1086 UT Erosion/Corrosion Examination,"performed February 5, 2010W-07-033, SW "34 Support-ATT Visual Examination of Component Supports and Snubbers(Vr-1)", performed January 22, 2QQTW-07-034, "AFW 32 Support Visual Examination of Component Supports and Snubbers (W-3)," performed January 22,2007W-07-067, "SW-H&R-12C-17 Visual Examination of Pipe Hanger, Support or Restraint (VT-3),"performed March 8,2007W-07-069, "SW-H&R-128-12-ATl Visual Examination of Pipe Hanger, Support or Restraint(VI-1)," performed March 9,2007Operatinq ExperienceCR-fP2-2010-7322, "NRC-IN-2010-23, Malfunctions of Emergency Diesel Generator SpeedSwitch Circuits," dated February 9,2011CR-lP2-2011-00832, CA-2, "Containment Insulation Walkdowns at domestic PWRs in Supportof NRC Generic Safety lssue 191," dated April 8, 201 1CR-lP2-2011-00834, CA-2, "Containment Insulation Drawing Review in Support of NRCGeneric Safety lssue 191," dated June 21, 2011CR-lP2-2011-00835, CA-2, "lnsulation Specification Update for Unit 3 (TS-MS-003) to identifyGSI-191 related information," dated May 25,2011CR-lP2-201 1-00836, CA-1, "Control of Containment Insulation in Support of NRC GenericSafety lssue 191," dated March 10,2011Attachment A-10CR-lP3-201 1-0381 1 , "10CFR21-0102 Concerning the Potential for Failures of SS810 Air StartMotors," dated August 2,2011LO-WTIPC-2011-OOO29, CA-49, "NRC-IN-2011-02 Operator Performance lssues InvolvingReactivity Management at Nuclear Power Plants," Revision 0LO-WTIPC-2011-00029, CA-60, "NRC-Event-4607-A2-lPC-001, Potential Voiding in AuxiliaryFeedwater Alternate Suction Line," Revision 0NRC Information Notice 2007-06, "Potential Common Cause Vulnerabilities in Essential ServiceWater Systems," dated February 9,2007NRC Information Notice 2008-11, "Service Water System Degradation at Brunswick SteamElectric Plant Unit 1," dated June 18, 2008NRC lnformation Notice2011-l2, "ReactorTrips Resulting from Water Intrusion into ElectricalEquipment," dated June 16,2011ProceduresO-AOP-SEC-3, "Event Contingency Actions," Revision 30-GNR-403-ELC, "Emergency Diesel Generator Quarterly Inspection," Revision 23-AOP-Flood-1, "Flooding," Revision 43-AOP-Leak-1, "Sudden Increase in Reactor Coolant System Leakage," Revision 53-ARP-009, "VC Sump Pump Running," Revision 413-ARP-011, "Panel SHF Electrical," Revision 333-ARP-019, "Panel Local- Diesel Generators," Revision 263-ECA-0.0, "Loss of All AC Power," Revision 63-ECA-1.2, "LOCA Outside Containment," Revision 03-PT-W001, "Emergency Diesel Support Systems Inspection," Revision 403-SAG-2, "Depressurize the RCS," Revision 13-SOP-AFW-001, "Auxiliary Feedwater System Operation," Revision 33-SOP-CB-002, "Containment Entry and Egress," Revision 333-SOP-EL-001, "Diesel Generator Operation," Revision 453-SOP-EL-005A, "480 Volt Electrical System Operation," Revision 12EN-LI-102, "Corrective Action Process," Revision 16EN-Ll-104, "Self-Assessment and Benchmark Process," Revision 7EN-Ll-1 18, "Root Cause Evaluation Process," Revision 14EN-LI-118-06, "Common Cause Analysis (CCA)," Revision 1EN-Ll-119, "Apparent Cause Evaluation (ACE) Process," Revision 12EN-Ll-121, "Entergy Trending Process," Revision 10EN-OE-100, "Operating Experience Program," Revision 12EN-OP-1 15, "Conduct of Operations," Revision 1 1EN-WM-107, "Post Maintenance Testing," Revision 3IPEC Emergency Action Levels," Revision 10-2SEP-SW-OO1, "NRC Generic Letter 89-13 Service Water Program," Revision 4EN-Ll-1 02, "Corrective Action Process," Revision 16EN-WM-107, "Post Maintenance Testing," Revision 33-REF-002-GEN, "lndian Point Unit 3 Refueling Procedure," Revision 43-PT-M108, "RHRySI/CS System Venting," Revision 140-CY-2510, "Closed Cooling Water Chemistry Specifications and Frequency," Revision 12EN-RP-101, "Access Controlfor Radiologically Controlled Areas," Revision 60-RP-RWP-407, "Refueling Support," Revision 23-PT-R032A, "Fuel Storage Building Filtration System," Revision 200-NF-311, "NlS Power Range Gain Adjustment," Revision 2Attachment A-11EN-DC-117, "Post Modification Testing and Special Instructions," Revision 43-SOP-lA-001, "lnstrument Air System Operation," Revision 25EN-DC-1 15, "Engineering Change Process," Revision 1 13-ARP-012,"Panel SJF - Cooling Water and Air," Revision 483-AOP-AlR-1, "Air Systems Malfunction," Revision 3EN-DC-205, "Maintenance Rule Monitoring," Revision 3EN-DC-204, "Maintenance Rule Scope and Basis," Revision 2EN-DC-206, "Maintenance Rule (aX1) Process," Revision 1Safetv Culture / Emplovee Concerns ProqramLO-HQNLO-2010-00002, "Entergy Nuclear Fleet 2009 Nuclear Safety Culture Survey ActionPlan," dated January 28,2010LO-lP3LO-2009-00164, "lndian Point Energy Center 2009 Nuclear Safety Culture Survey ActionPlan," dated January 28,2010LO-lP3LO-2010-00138, "Security Department Nuclear Safety Culture Survey Action Plan,"dated January 28,2010LO-lP3LO-2009-00164, "lndian Point Employee Concerns lmprovement Plan," dated November30, 2009Meeting Minutes, Indian Point Energy Center Executive Protocol Group Meeting 09-016, datedDecember 7,2009Meeting Minutes, Indian Point Energy Center Special Executive Protocol Group Meeting10-001, dated January 8,2010Summary List of ECP Cases for 2009, 2010, and 2Q11IPEC ECP Monthly Report for June, 2011lndian Point Employee Concerns Data Analysis Reports for 2009 and 2010Self-Assessment of IPEC Nuclear Plant Employee Concerns Program, dated October, 2010Work Orders52036144001 85072001 957960023334452214280001 6365700278896Attachment ADAMSAFWCACAPCARBCFRCRCRGCWDRSECECPEDGEntergyFINGLgpmHXtMcISTKVLOMCCNCVNPONRCOEPABPMTQASCWESDPSSCSTSWTSunsatUTWOA-12LIST OF ACRONYMSAgencywide Document Management Systemauxiliary feedwatercorrective actioncorrective action programCorrective Action Review BoardCode of Federal Regulationscondition reportCondition Review Groupcity waterDivision of Reactor Safetyengineering changeEmployee Concerns Programemergency diesel generatorEntergy Nuclear NortheastfindingGeneric Lettergallons per minuteheat exchangerinspection manual chapterin-service testkilovoltlubricating oilmotor control centernon-cited violationnuclear plant operatorNuclear Regulatory Commissionoperating experienceprimary auxiliary buildingpost-maintenance testquality assurancesafety conscious work environmentsignificance determination processstructures, systems, and componentssurveillance testservice waterTech nical Specificationsunsatisfactoryultrasonic testingwork orderAttachment }}