IR 05000247/2014004

IR 05000247-14-004, 05000286-14-004; 07/01/2014 - 09/30/2014; Indian Point Nuclear Generating Units 2 and 3 (Indian Point); Occupational ALARA Planning and Controls and Problem Identification and Resolution

ML14314A052
Person / Time
Site:	Indian Point
Issue date:	11/07/2014
From:	Arthur Burritt Reactor Projects Branch 2
To:	Ventosa J Entergy Nuclear Operations
Burritt A
References
IR 2014004
Download: ML14314A052 (44)

Text

{{#Wiki_filter: UNITED STATES ber 7, 2014

SUBJECT:

INDIAN POINT NUCLEAR GENERATING - NRC INTEGRATED INSPECTION REPORT 05000247/2014004 AND 05000286/2014004

Dear Mr. Ventosa:

On September 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Indian Point Nuclear Generating, Units 2 and 3 (Indian Point). The enclosed inspection report documents the inspection results, which were discussed on October 24, 2014, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents two findings of very low safety significance (Green). One of these findings was determined to involve a violation of NRC requirements. However, because of the very low safety significance, and because it has been entered into your corrective action program, the NRC is treating this finding as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violation in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at Indian Point. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement, 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 I, and the NRC Senior Resident Inspector at Indian Point. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, /RA/ Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

Enclosure:

Inspection Report 05000247/2014004 and 05000286/2014004 w/Attachment: Supplementary Information

REGION I== Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 Report Nos. 05000247/2014004 and 05000286/2014004 Licensee: Entergy Nuclear Northeast (Entergy) Facility: Indian Point Nuclear Generating, Units 2 and 3 Location: 450 Broadway, GSB Buchanan, NY 10511-0249 Dates: July 1, 2014, through September 30, 2014 Inspectors: J. Stewart, Senior Resident Inspector A. Patel, Resident Inspector G. Newman, Resident Inspector B. Bollinger, Acting Resident Inspector J. Brand, Acting Resident Inspector C. Lally, Acting Resident Inspector J. Furia, Health Physicist S. Galbreath, Reactor Inspector S. Hammann, Senior Health Physicist S. McCarver, Physical Security Inspector Approved By: Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY

IR 05000247/2014004, 05000286/2014004; 07/01/2014 - 09/30/2014; Indian Point Nuclear

Generating Units 2 and 3 (Indian Point); Occupational ALARA Planning and Controls and Problem Identification and Resolution.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified one finding and one non-cited violation (NCV), both which were of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Entergy personnel did not adequately implement procedure EN-OP-104, Operability Determination Process, Step 5.5, to assess the operability and degraded condition of the 22 station battery capacity. Specifically, Entergy personnel did not identify the degraded/non-conforming condition or evaluate the condition relative to support functions for Technical Specification (TS) Surveillance Requirement (SR) 3.8.6.6.

The finding was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, after inspectors questioned the operability determination, the degraded condition was identified and resulted in the 22 station battery being declared OPERABLE but DEGRADED. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green), because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event. Entergy placed this issue into the corrective action program (CAP) as condition report (CR)-IP2-2014-04825 and performed an immediate operability determination followed by a request for an exigent change in TS requirements. The inspectors assigned a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because Entergy did not thoroughly evaluate the condition of the 22 station battery capacity. Specifically, Entergy did not identify the degraded/non-conforming condition or evaluate the condition relative to support functions for TS SR 3.8.6.6. [P.2].

   (Section 4OA2)

Cornerstone: Occupational/Public Radiation Safety

Green.

A self-revealing finding (FIN) of very low safety significance (Green) was identified due to Entergy having excessive unintended occupational collective exposure. This resulted from performance deficiencies in planning and work control while performing reactor coolant pump (RCP) work activities during the Unit 2 refueling outage. Inadequate work planning and control resulted in unplanned, unintended collective exposure due to conditions that were reasonably within Entergys ability to control and prevent. The work activity performance deficiencies resulted in the collective exposure for these activities increasing from the planned dose of 7.269 person-rem to an actual dose of 13.742 person-rem.

Entergy entered this issue into their CAP as CR-IP2-2014-02558.

The finding was more than minor because it was associated with the Program and Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation. Additionally, the performance deficiency was more than minor based on a similar example (6.i) in Appendix E of IMC 0612; in that, the actual collective dose exceeded 5 person-rem and exceeded the planned, intended dose by more than 50 percent. Entergy placed this issue into the CAP as CR-IP2-2014-02558 and completed a root cause evaluation. The finding had a cross-cutting aspect in the area of Human Performance, Teamwork, in that the work groups did not coordinate activities, which involved job site activities, that adversely impacted radiological safety. Specifically, higher source term due to not delaying the start of work to reduce reactor coolant system (RCS)activity levels following the crud burst and the inability to properly sequence the installation of shielding packages with the work activities resulted in collective exposures that exceeded estimates by greater than 50 percent. [H.4] (Section 2RS2)

REPORT DETAILS

Summary of Plant Status

Unit 2 operated at 100 percent power during the inspection period.

Unit 3 began the inspection period at 100 percent power. On August 13, 2014, Unit 3 tripped from full power due to a spurious signal during testing of the reactor protection system (RPS).

The unit was restarted on August 15 and returned to full power on August 17. Unit 3 remained at full power for the remainder of the period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Entergys preparations for the onset of hot weather on July 30, 2014. The inspectors reviewed the implementation of adverse weather preparation procedures including OAP-48, Seasonal Weather Preparation (Units 2 and 3), and 2-SOP-24.1.1, Service Water Hot Weather Operation (Units 2), before the onset of and during this adverse weather condition. The inspectors walked down the Unit 2 emergency diesel generator (EDG) building; the Unit 2 480 volt (V) switchgear room; the Unit 3 EDG rooms; and the Unit 3 service water room to ensure system availability and that there were no problems as a result of the severe weather. The inspectors verified that operator actions defined in Entergys adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations. The inspectors discussed hot weather preparedness with operators and maintained an awareness of hot weather issues throughout the hot weather periods. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified. ==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Unit 2 21 and 23 auxiliary boiler feedwater pumps (ABFPs) while 22 ABFP was out of service (OOS) for planned maintenance on August 28, 2014 21 and 22 EDGs while 23 EDG was OOS for a two-year mechanical overspeed test on September 12, 2014 Unit 3 31 and 33 EDG and 480V switchgear rooms while 32 EDG was OOS for a scheduled two-year preventive maintenance on August 4, 2014 31 and 33 ABFPs while 32 ABFP was OOS for planned maintenance on flow control valve (FCV)-405B on September 24 and 25, 2014 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TSs, work orders (WOs), CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Entergy staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On August 20, 2014, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 containment spray system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, support structure isometric drawings, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs and WOs to ensure Entergy appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified. ==1R05 Fire Protection