IR 05000247/2018002
| ML18213A153 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/01/2018 |
| From: | Schroeder D L Reactor Projects Branch 2 |
| To: | Vitale A J Entergy Nuclear Operations |
| Schroeder D L | |
| References | |
| IR 2018002 | |
| Download: ML18213A153 (25) | |
Text
August 1, 2018
Mr. Anthony Site Vice President Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, General Services Building P.O. Box 249 Buchanan, NY 10511-0249
SUBJECT: INDIAN POINT NUCLEAR GENERATING - INTEGRATED INSPECTION REPORT 05000247/2018002 AND 05000286/2018002
Dear Mr. Vitale:
On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating (Indian Point), Units 2 and 3. On July 18, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection. The NRC inspectors documented one violation, which was determined to be Severity Level IV in this report. The NRC is treating this v iolation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, 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; and the NRC Resident Inspector at Indian Point. This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, "Public Inspections, Exemptions, Requests for Withholding."
Sincerely,/RA/ Daniel L. Schroeder, Chief Reactor Projects Branch 2
Division of Reactor Projects
Docket Numbers: 50-247 and 50-286 License Numbers: DPR-26 and DPR-64
Enclosure:
Inspection Report 05000247/2018002 and 05000286/2018002
cc w/encl: Distribution via ListServ
ML18213A153 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME BHaagensen via email TSetzer DSchroeder DATE 7/25/18 7/25/18 8/1/18
1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report
Docket Numbers: 50-247 and 50-286
License Numbers: DPR-26 and DPR-64
Report Numbers: 05000247/2018002 and 05000286/2018002
Licensee: Entergy Nuclear Northeast (Entergy)
Facility: Indian Point Nuclear Generating, Units 2 and 3
Location: 450 Broadway, General Services Building Buchanan, NY 10511-0249
Inspection Dates: April 1, 2018 to June 30, 2018
Inspectors: B. Haagensen, Senior Resident Inspector A. Siwy, Resident Inspector J. Vazquez, Resident Inspector J. Fuller, Acting Resident Inspector D. Kern, Senior Reactor Inspector M. Modes, Senior Reactor Inspector L. McKown, Acting Resident Inspector S. Wilson, Health Physicist
Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 2 Division of Reactor Projects
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Entergy's performance at Indian Point Nuclear Generating, Units 2 and 3, by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor
Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealing findings, violations, and additional items are summarized in the table below.
List of Findings and Violations Reactor Pressure Boundary Leakage Due to Weld Failure in Reactor Vessel Head Penetration #3 Cornerstone Severity Cross-Cutting Aspect Inspection Results Section Not Applicable Severity Level IV Non-Cited Violation (NCV)05000286/2018-002-01 Closed Not Applicable 71111.15 A self-revealing Severity Level IV NCV of Technical Specification (TS) 3.4.13.a, "Reactor Coolant System Operational Leakage," was identified when Entergy operated the reactor in Mode 1 with pressure boundary leakage for a period of time longer than the allowable limiting condition of operation. Specifically, a leak in the J-weld around reactor pressure vessel (RPV) head penetration #3 occurred during the last operating cycle and was not identified until after the reactor was shutdown for a refueling outage.
Additional Tracking Items Type Issue number Title Inspection Results Section Status LER 05000286/2017-004-00 Reactor Trip Due to Main Generator Loss of Field 71153 Closed LER 05000286/2018-001-00 Reactor Trip Due to Main Generator Loss of Excitation 71153 Closed 3 TABLE OF CONTENTS INSPECTION SCOPES .............................................................................................................
... 4REACTOR SAFETY ................................................................................................................
..... 4RADIATION SAFETY ..............................................................................................................
..... 8OTHER ACTIVITIES - BASELINE .............................................................................................. 9INSPECTION RESULTS ............................................................................................................ 10EXIT MEETINGS AND DEBRIEFS ............................................................................................ 15DOCUMENTS REVIEWED
......................................................................................................... 16 4
PLANT STATUS
Unit 2 began the inspection period during refueling outage 2RFO23 which lasted 33 days. Upon completion of the outage, the operators restarted Unit 2 on April 19, 2018, and increased power slowly to approximately eight percent power when the unit was tripped by the operators due to an issue with the main turbine control valves. The unit was returned to rated thermal power on April 25, 2018. On June 22, 2018, the operators reduced power to approximately 62 percent power to repair an oil leak on the 22 main boiler feed pump. The unit was returned to rated thermal power on June 23, 2018, and remained at or near rated thermal power for the remainder of the inspection period.
Unit 3 operated at or near rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, "Light-Water Reactor Inspection Program - Operations Phase." The inspectors performed plant status activities described in IMC 2515, Appendix D, "Plant Status" and conducted routine reviews using IP 71152, "Problem Identification and Resolution." The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess Entergy's performance and compliance with Commission rules and regulations, license conditions, site procedures, and
standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Summer Readiness (1 Sample)
The inspectors evaluated summer readiness of offsite and alternating current power systems at Units 2 and 3 on May 17, 2018.
71111.04 - Equipment Alignment Partial Walkdown (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
Unit 2 (1) Appendix R diesel generator on June 12, 2018 Unit 3 (2) 33 auxiliary boiler feedwater pump on June 5, 2018 (3) Service water Zurn strainers on June 18, 2018 (4) Refueling water storage tank on June 28, 2018
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the Unit 2 emergency diesel generators on June 27, 2018.
71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
Unit 2 (1) Primary auxiliary building and fan house pre-fire plan (PFP-215) on May 15, 2018 (2) Cable spreading room (PFP-252) on May 31, 2018 (3) Primary auxiliary building, 15-foot elevation (PFP-204), on June 7, 2018
Unit 3 (4) Fuel storage building (PFP-315 and PFP-316) on June 6, 2018 (5) Diesel generator building (PFP-354) on June 29, 2018
71111.07A - Heat Sink Performance
Heat Sink (1 Sample)
The inspectors observed Entergy's inspections and the state of cleanliness of the tubes of the 22 component cooling water heat exchanger at Unit 2 on May 22, 2018.
71111.08P - Inservice Inspection Activities (1 Sample)
The inspectors evaluated Entergy's non-destructive examination and welding activities at Unit 2 by reviewing the following examinations from April 24 to April 27, 2018:
(1) Volumetric Examinations The ultrasonic, eddy current, and liquid penetrant examination of the J-weld and associated interfaces of RPV head penetration #3, with subsequent repair by weld surface seal weld Ultrasonic examination of the dissimilar welds of reactor nozzles 24-1A and 22-1A (2) The inspectors reviewed Entergy's boric acid corrosion control program performance. (3) The inspectors reviewed Entergy's steam generator aging management program, including eddy current testing of steam generator tubes. 71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification (1 Sample)
Unit 3 (1) The inspectors observed and evaluated a crew of licensed operators in the plant's simulator during licensed operator requalification training on June 5, 2018.
Operator Performance (1 Sample)
Unit 2 (1) The inspectors observed and evaluated operator performance during 2RFO23 reactor startup on April 19, 2018.
71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
Unit 2 (1) CR-IP2-2018-2246, Containment structure on June 25, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (8 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
Unit 2 (1) Planned Yellow risk associated with freeze seal to affect repairs to MOV-769, component cooling water to reactor coolant pump seal cooling, isolation valve on April 7, 2018 (2) Planned Yellow risk for vacuum fill of the reactor coolant system (RCS) on April 14, 2018 (3) Risk for maintenance on containment recirculation sump level transmitter LT-939 on April 20, 2018 (4) Unplanned Yellow risk for loss of bus 2 on 13.8kV feeder 13W93 on June 1, 2018
Unit 3 (5) 13.8kV feeders out of service for planned gas turbine auto transformer maintenance on May 1, 2018 (6) Planned Yellow risk for 480 volt degraded voltage relay testing on May 17, 2018 (7) Planned Yellow risk for charging pump backflow preventer maintenance on June 6, 2018 (8) Planned Yellow risk for 32 component cooling water pump oil sampling on June 13, 2018 71111.15 - Operability Determinations and Functionality Assessments (5 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
Unit 2 (1) CR-IP2-2018-02127, Baffle bolt operability assessment during 2RFO23 on April 17, 2018 (2) CR-IP2-2018-1944, RPV head penetration #3 through-wall leak past operability on April 17, 2018 (3) CR-IP2-2018-2359, PCV-1191 containment pressure relief valve on April 19, 2018
Unit 3 (4) CR-IP3-2018-01448, 34 atmospheric dump valve past-operability associated with unsecured nearby equipment on May 23, 2018 (5) CR-IP3-2018-01552, 33 service water pump operability during 32 emergency diesel generator testing with 35 service water pump out of service on June 5, 2018
71111.18 - Plant Modifications (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1) Engineering Change (EC) Package 76614 - Evaluate using freeze seal isolation on 6-inch line 13 to perform maintenance on valve 769 (temporary modification) at Unit 2 on April 7, 2018 (2) EC Package 75312 - Engineering weld-repaired leaking RHR line A-98 per ASME Code Case N-666 (permanent modification) on at Unit 2 on April 24, 2018
71111.19 - Post-Maintenance Testing (13 Samples)
The inspectors evaluated post-maintenance testing for the following maintenance/repair activities:
Unit 2 (1) MOV-744, Anchor Darling double-disc gate valve inspection following repairs on April 2, 2018 (2) MOV-769, Anchor Darling double-disc gate valve inspection following repairs on April 2, 2018 (3) MOV-746, Anchor Darling double-disc gate valve inspection following repairs on April 2, 2018 (4) MOV-784, Anchor Darling double-disc gate valve inspection of condition and performance monitoring following minor valve maintenance on April 7, 2018 (5) MOV-885B, Anchor Darling double-disc gate valve inspection of condition and performance monitoring following minor valve maintenance on April 7, 2018 (6) Containment pressure relief valve PCV-1191 following repairs for local leak-rate test failure on April 12, 2018 (7) RPV head penetration #3 weld repairs on April 17, 2018 (8) 24 reactor coolant pump motor repair on April 18, 2018 (9) Control rod H6 following individual rod position indication repairs on April 18, 2018.
(10) 22 reactor coolant pump motor repair on April 18, 2018 (11) Control rod G3 drive coil stack replacement on April 18, 2018 Unit 3 (12) Control rod M4 individual rod position indication post-maintenance testing following calibration to resolve indication issues on May 8, 2018 (13) 33 atmospheric dump valve post-maintenance testing following instrument airline repairs on May 23, 2018
71111.20 - Refueling and Other Outage Activities (1 Sample)
The inspectors evaluated Unit 2 2RFO23 activities from March 18 to April 21, 2018.
71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:
Routine (3 Samples)
(1) 3-PT-M13B1, Reactor Protection Train B Logic Test, at Unit 3 on May 7, 2018 (2) 3-PT-Q120A, 31 Motor Driven Auxiliary Boiler Feedwater Pump Functional Test, at Unit 3 on May 21, 2018 (3) 0-PT-6Y001, B.5.b Diesel Driven Pump Capacity Test, at Units 2 and 3 on June 13,
RADIATION SAFETY
71124.07 - Radiological Hazard Assessment and Exposure Controls Site Inspection (1 Sample)
The inspectors verified that the radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. The inspectors observed environmental sampling of groundwater, surface water, broad leaf vegetation, and air samples.
The inspectors verified that the radiological environmental monitoring program was consistently implemented with Entergy's TSs and/or offsite dose calculation manual and validated that the program meets the design objectives in Appendix I to Title 10 of the Code of Federal Regulations (10 CFR), Part 2.39010.
Groundwater Protection Initiative Implementation (1 Sample)
The inspectors verified that Entergy is continuing to implement the voluntary Nuclear Energy Institute/Industry Groundwater Protection Initiative.
OTHER ACTIVITIES
- BASELINE 71151 - Performance Indicator Verification The inspectors verified Entergy's performance indicators submittals listed below for the period from April 1, 2017, through March 31, 2018 (6 Samples).
Unit 2 (1) Unplanned Scrams Per 7000 Critical Hours (IE01) (2) Unplanned Power Changes Per 7000 Critical Hours (IE03)
(3) Unplanned Scrams with Complications (IE04)
Unit 3 (4) Unplanned Scrams Per 7000 Critical Hours (IE01)
(5) Unplanned Power Changes Per 7000 Critical Hours (IE03)
(6) Unplanned Scrams with Complications (IE04)
71152 - Problem Identification and Resolution
Semiannual Trend Review (1 Sample)
The inspectors reviewed Entergy's corrective action program for trends that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (1 Sample)
The inspectors reviewed Entergy's implementation of its corrective action program related to the following issue:
(1) Several fire protection deficiencies were identified for Units 2 and 3 during the last year, including portable fire extinguisher preventive maintenance not performed documented in the Indian Point Integrated Inspection Report 05000247/2017007 and 05000286/2017007 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML17341A080), fire hose hydrostatic testing and preventive maintenance not performed, and pre-fire plan inaccuracy. Condition reports associated with the above issues included CR-IP2-2017-02945, CR-IP2-2017-04090, CR-IP2-2018-02800, CR-IP3-2017-04084, CR-IP3-2017-05035, CR-IP3-2017-05040, CR-IP3-2018-00463, and CR-IP3-2018-00533.
71153 - Follow-up of Events and Notices of Enforcement Discretion Events (1 Sample)
The inspectors evaluated response to the following event:
(1) RPV head penetration #3 flaw, 50.72 report, at Unit 2 on April 2, 2018
Licensee Event Reports (LERs) (2 Samples)
The inspectors evaluated the following LERs:
(1) LER 05000286/2017-004-00, Unit 3 Reactor Trip Due to Main Generator Loss of Field (ADAMS Accession Number ML17363A212)
Entergy conducted a causal evaluation and determined that the Thyristor Firing Module B drawer had failed. Entergy made repairs to the failed components and
returned the system to service with additional monitoring equipment. The inspectors did not identify any new issues during the review of the LER. The inspectors determined that it was not reasonable to foresee and prevent the cause discussed in the LER. Therefore, no performance deficiency was identified. The inspectors also concluded that no violation of NRC requirements occurred.
(2) LER 05000286/2018-001-00, Unit 3 Reactor Trip Due to Main Generator Loss of Excitation (ADAMS Accession Number ML18110A088)
Entergy conducted a causal evaluation and determined that the Thyristor Firing
Module A drawer had failed. Entergy replaced both Thyristor Firing Module drawers and
returned the system to service with additional monitoring equipment. The inspectors did not identify any new issues during the review of the LER. The inspectors determined that it was not reasonable to foresee and prevent the cause discussed in the LER. Therefore, no performance deficiency was identified. The inspectors also concluded that no violation of NRC requirements occurred.
Personnel Performance (1 Sample)
The inspectors evaluated response during the following non-routine evolutions or transients.
(1) Unit 2 reactor trip at 7 percent power due to a loss of feedwater during main turbine startup from 2RFO23 on April 20, 2018.
INSPECTION RESULTS Reactor Pressure Boundary Leakage Due to Weld Failure in Reactor Vessel Head Penetration #3 Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000286/2018-002-01
Closed Not Applicable 71111.15
Introduction:
A self-revealing Severity Level IV NCV of TS 3.4.13.a, "Reactor Coolant System Operational Leakage," was identified when Entergy operated the reactor in Mode 1 with pressure boundary leakage for a period of time longer than the allowable limiting condition of operation. Specifically, a leak in the J-weld around RPV head penetration #3 occurred during the last operating cycle and was not identified until after the reactor was shutdown for a refueling outage.
Description:
On March 28, 2018, during the Unit 2 bare metal exam, Entergy observed white deposits on the top of the RPV head next to (spare) penetration #3. Entergy concluded the deposits were dried boric acid. Subsequently, Entergy evaluated indications using ultrasonic test, eddy current test, and dye penetrant test examination techniques. Entergy concluded that one indication had propagated into a through-wall pressure boundary leak in RPV head penetration #3 caused by primary water stress cracking corrosion. Entergy determined that this leakage was prohibited by TS 3.4.13, "Reactor Coolant System Operational Leakage," which requires that there be no pressure boundary leakage during operating Modes 1 through
4. The condition was reported to the NRC in
Event Notification EN-53305 on March 31, 2018, as required by 10 CFR 50.72(b)(3)(ii)(A), because it constituted a degradation of a principal safety barrier. Entergy also reported this event in LER 05000247/2018-001-00 (ADAMS Accession Number ML18149A126) on May 21, 2018, under 10 CFR 50.73(a)(2)(ii)(A) and 10 CFR 50.73(a)(2)(i)(B). These subparts describe an event or condition that resulted in the nuclear power plant including its principal safety barriers being seriously degraded, and an operation or a condition which was prohibited by the plant's TSs, respectively.
The inspectors reviewed the RCS leakage monitoring records, Entergy's event report, the causal analyses, and previous examination records. These reviews were conducted to determine whether Entergy's monitoring of operational leakage during the previous operating cycle and prior non-destructive examination activities met regulatory requirements and applicable standards.
The inspectors independently reviewed the unidentified leak rate data over the previous operating cycle and the trace boric acid deposits observed during the refueling outage. The inspectors noted that Entergy completed a bare metal examination of the RPV the previous refueling outage and determined there were no boric acid deposits in this location. Entergy conducted isotopic analysis of the boric acid deposits and estimated the leak occurred within the previous 90 to 180 days. The boron deposits were pure white in appearance indicating that there were no corrosion products present. Entergy completed leakage monitoring during the operating cycle in accordance with standards and TS requirements. The inspectors determined that the applicable limits were met and that the leak was not readily detectable by these methods because the change in leak rate was too small to be identified. The inspectors ultimately concluded there was no opportunity for Entergy to observe this condition visually during the operating cycle because existing boron deposits were not visible when the plant was operating.
The inspectors observed activities during the refueling outage to determine whether Entergy completed examinations of the RPV and head penetration #3 in accordance with regulatory requirements in 10 CFR Part 50, paragraph (g)(6)(ii)(D)), which conditionally endorses American Society of Mechanical Engineers (ASME), Code Case N-729-4. Specifically, the inspectors reviewed the results of the nondestructive examinations: time-of-flight ultrasonic testing, liquid penetrant testing, and eddy current testing. The inspectors also conducted discussions with the personnel who performed these tests. The inspectors determined Entergy staff and their contractors implemented these non-destructive examination activities in accordance with regulatory requirements and their implementing procedures.
Corrective Actions: Entergy implemented corrective actions to repair head penetration #3 by applying a weld onlay prior to returning the RPV to service. This alternative repair method was the subject of relief request IP2-ISI-RR-06 which was submitted to the NRC and
subsequently approved (ADAMS Accession Nu mber ML18101A032). This weld onlay reestablished the RCS pressure boundary and addressed the primary water stress cracking corrosion degradation mechanism. Entergy verified that the pressure boundary had been restored using both non-destructive testing methods (dye penetration testing and ultrasonic testing) and an operational pressure test.
Corrective Action References: CR-IP2-2018-01944 and CR-IP2-2018-02122
Performance Assessment: The inspectors determined that the pressure boundary leakage was not within Entergy's ability to foresee and prevent. Entergy had complied with all ASME code requirements for inspection of the RPV and there were no indications of RCS pressure boundary leakage during the operating cycle. As a result, no performance deficiency was identified. Therefore, this violation will not be considered in the assessment process or the NRC's action matrix.
Enforcement:
Severity: This issue is considered within the Traditional Enforcement process because there was no performance deficiency associated with the violation of NRC requirements, and the Reactor Oversight Process's significant determination process does not specifically consider violations without performance deficiencies in its assessment of licensee performance. In reaching this decision, the NRC determined that the issue was not within Entergy's ability to foresee and correct, Entergy's actions did not contribute to the degraded condition, and the actions taken were reasonable to identify and address the condition. Furthermore, because Entergy's actions did not contribute to this violation, it will not be considered in the assessment process or the NRC's action matrix.
Using IMC 0612, Appendix B, "Issue Screening," the inspectors determined that the violation is associated with the Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The Barrier Integrity cornerstone was not applicable for this violation because the violation did not involve pressurized thermal shock.
The inspectors evaluated the issue using IMC 0609.04, "Initial Characterization of Finding," and determined the violation was a LOCA initiator. The inspectors screened the safety significance to Green using IMC 0609, Appendix A, Exhibit 1, "LOCA Initiators," because, after a reasonable assessment of degradation, it was determined that the violation did not result in exceeding the RCS leak rate for a small-break LOCA and did not affect any other systems used to mitigate a LOCA that could result in a total loss of function. Therefore, the inspectors determined that the issue is of very low safety significance and concluded that the violation would be best characterized as Severity Level IV under the Traditional Enforcement
process.
Violation: TS 3.4.13(A) requires, in part, that RCS operational leakage shall be limited to "no pressure boundary leakage." If pressure boundary leakage exists, then TS 3.4.13(A) limiting condition for operation action statement requires leakage to be reduced to within limits or TS 3.4.13(B) requires Unit 2 to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and TS 3.4.13(C) requires Unit 2 to be in Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above, for a period that began on an unknown date that was likely more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before reactor shutdown on March 19, 2018, RCS pressure boundary leakage existed, and Entergy did not place Unit 2 in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy, because Entergy restored compliance, placed the issue in the corrective action program, was non-repetitive, was not NRC-identified, was not willful, and did not meet any minor examples in the Enforcement Manual,Section III, Appendix E.
Observation 71152 Annual Follow-up of Selected Issues The inspectors determined several aspects of the fire protection program implementation had improved, including the following:
(1) Entergy implemented reasonable actions to address each of the fire protection deficiencies listed in Other Activities - Baseline, Inspection Procedure 71152, Annual Follow-up of Selected Issues. The most important positive action implemented was the hiring and training of three new people to perform the fire extinguisher and fire hose preventive maintenances. These personnel now report directly to the respective responsible supervisors for portable fire extinguishers and fire hoses.
(2) Entergy initiated an accelerated schedule for replacing 100 percent of the onsite fire hoses with new hoses or hoses that have been hydrostatically tested this year. The project is scheduled to be completed by December 2018.
Notwithstanding the significant progress, the inspectors determined several procedure gaps/deficiencies exist, which could permit more fire hoses to exceed their hydrostatic test due date prior to their next inspection/replacement. Entergy identified some of these through the corrective action program but had not resolved them. The inspectors identified additional deficiencies in eight fire protection hose implementing procedures and discussed the deficiencies with fire protection engineers. CR-IP3-2018-01465 was initiated to fix the procedure deficiencies. The inspectors independently inspected fire hoses at 40 onsite locations (including Units 1, 2, and 3, inside and outside of the radiological controlled areas, and the intake structure) and found each hose was properly hydrostatically tested within the required periodicity. Minor hose station deficiencies identified were promptly corrected (CR-IP3-2018-01388, CR-IP2-2018-03309, CR-IP2-2018-03310, and CR-IP2-2018-03318).
The inspectors determined the procedure deficiencies were minor, based on the fire hose inspection results and the progress Entergy had made on the project to replace all fire hoses in 2018.
Observation 71152 Semiannual Trend Review The inspectors performed a review of Entergy's evaluation and corrective actions associated with the mitigating system performance index (MSPI) for the period from July 2016 through June 2018. Specifically, the inspectors reviewed the corrective actions to verify they were addressing the identified conditions adverse to quality. The inspectors assessed Entergy's problem identification threshold, extent of condition reviews, and the prioritization and timeliness of corrective actions to determine whether Entergy was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Entergy's corrective action program and 10 CFR Part 50, Appendix B. In addition, the inspectors interviewed engineering personnel to assess the effectiveness of the implemented corrective actions.
There were licensee-identified and NRC-identified performance indicator reporting discrepancies documented during the reviewed timeframe. Of note, there were two NRC-identified instances in which multiple discrepancies were reported which led to Entergy reviewing the prior three years of reported data and identifying additional discrepancies. Also, there was a licensee-identified issue with the consolidated data entry (CDE) system where the system was reporting estimated values instead of actual values even though Entergy had reported the actual values appropriately.
Instances of discrepancies were identified by the NRC in November 2016 (CR-IP2-2016-07044) and September 2017 (CR-IP2-2017-03169, CR-IP2-2017-03196, CR-IP2-2017-03203, CR-IP3-2017-04222, and CR-IP3-2017-04268). The instance in 2016 involved all five MSPI systems. This resulted in the MSPI resultant values getting farther from the Green/White threshold. Entergy reviewed the prior three years, found discrepancies in every quarter, and submitted corrected data. The instance in 2017 involved all five MSPI systems. This resulted in a combination of the MSPI resultant values getting closer to and farther from the Green/White threshold. Entergy reviewed the prior three years, found discrepancies in every quarter, and submitted corrected data. The scope of the completed corrective actions for the 2016 instance was narrowly focused on post-maintenance testing. The scope of the 2017 review was broader and found errors in the overlapping 2015 and 2016 not related to post-maintenance testing.
Instances of discrepancies were identified by Entergy in October 2017 (CR-IP2-2017-03819)and January 2018 (CR-IP2-2018-00144). The instance in 2017 involved the way the CDE system was reporting data after they had already been submitted. A small portion of the high-pressure safety injection system was showing as estimated values instead of actual values. This resulted in a combination of the MSPI resultant values getting closer to and farther from the green/white threshold. Entergy checked all other parameters and corrected the condition so that the actual values are being reported. It is worth noting that the CDE
system is maintained by a third party. The instance in 2018 involved the number of hours of critical operation for both units which is used in the unavailability and unreliability indexes of MSPI. This resulted in the MSPI resultant values getting closer to the green/white threshold; however, Entergy corrected the data prior to it being reported.
Entergy did not identify specific trends or causes for the reasons of the discrepancies.
However, Entergy took action in each case to correct the discrepancies after discovery. Entergy provided coaching to the individuals who compiled and reported the data. Entergy also provided training in June 2018 by a third party expert to all individuals involved in the MSPI reporting process as a corrective action after the NRC-identified instance in 2017.
It is apparent that there have been programmatic reporting issues with MSPI at the site. None of the issues listed above led to a change in the performance indicators crossing a threshold.
EXIT MEETINGS AND DEBRIEFS The inspectors confirmed that proprietary information was controlled to protect from public disclosure.
On July 18, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. Anthony Vitale, Site Vice President, and other members of the Entergy staff.
DOCUMENTS REVIEWED
Common Documents Used Indian Point Units 2 and 3, Updated Final Safety Analysis Report Indian Point Units 2 and 3, Individual Plant Examination
Indian Point Units 2 and 3, Individual Plant Examination of External Events
Indian Point Units 2 and 3, Technical Specifications and Bases
Indian Point Units 2 and 3, Technical Requirements Manual
Indian Point Units 2 and 3, Control Room Narrative Logs Indian Point Units 2 and 3, Plan of the Day
71111.01 Procedures IP-SMM-OP-104, Offsite Power Continuous Monitoring and Notification, Revision 13
Condition Reports (CR-IP2-) (*initiated in response to inspection)
2018-03277*
71111.04 Procedures 3-COL-RW-002, Service Water System, Revision 51 3-COL-SI-001, Safety Injection System, Revision 44
3-SOP-SI-002, Filling the Refueling Water Storage Tank, Revision 12 3-SOP-SI-003, Recirculation and/or Purification of the Refueling Water Storage Tank, Revision 26
Condition Reports (CR-IP2-) (*initiated in response to inspection) 2018-02345* 2018-03138* 2018-03700* 2018-04013* 2018-04014*
Condition Reports (CR-IP3-) (*initiated in response to inspection) 2018-01180* 2018-01768* 2018-01864*
Miscellaneous CES-2A, Engineering Standards Manual, Seismic Design of Electrical Conduit Supports for Indian Point Units 2 and 3, Revision 3
71111.05AQ
Procedures 0-PT-M004, Fire Extinguisher Inspection, Revision 9 PFP-215, Unit 2 Primary Auxiliary Building and Fan House, 51-Foot and 68-Foot Elevations, Revision 8 PFP-252, Unit 2 Cable Spreading Room, Control Building, 33-Foot Elevation, Revision 11
Condition Reports (CR-IP2-) (*initiated in response to inspection) 2018-03029* 2018-03261*
Condition Reports (CR-IP3-) (*initiated in response to inspection)
2018-01717*
Calculations IP3-CALC-FP-02795, Combustible Loading Calculation for Indian Point 3 Hazards Analysis, Revision 2
Engineering Evaluations DC-88-207, Indian Point 2 Fire Barrier Engineering Evaluation, Evaluation No. 1, dated
March 24, 1989
Miscellaneous PFP-204, General Floor Plan - Primary Auxiliary Building, 15-Foot Elevation, Revision 0
PFP-315, Fuel Storage Bay Area - Fuel Storage Building, Revision 0
PFP-316, General Floor Plan - Fuel Storage Building, Revision 12
PFP-354, Diesel Generator Building - Diesel Generators 31, 32, and 33, 15-Foot Elevation, Revision 0
71111.07 Procedures EN-DC-316, Heat Exchanger Performance and Condition Monitoring, Revision 10
EN-MA-118, Foreign Material Exclusion, Revision 12
Condition Reports (CR-IP2-)
2018-03349 2018-03350
Miscellaneous EC-77962, Evaluate Acceptability of Allowing Temporary Tube Plugs in 22 Component Cooling Water Heat Exchanger to Next PM Activity, Revision 0
71111.08 Procedures WDI-STD-1013 (PDI-ISI-254-SE-NB), Remote Inservice Inspection of Rector Vessel Nozzle to Safe End, Nozzle to Pipe and Safe End to Pipe Welds Using the Nozzle Scanner,
Revision 3
Maintenance Orders/Work Orders WO 52568740 01 WO 52709908 01 WO 52708009 01 WO 0049815801
Calculation IP-CALC-04-01420, FCX-0538, Calculation of Effective Degradation Years for the IP2 Reactor Vessel Head by 2R18
Miscellaneous ACTS; IP-001-18 Bobbin Coil: 0.720 - Standard Pull Speed
ACTS; IPP 003-18 Bobbin Coil: 0.700
ACTS; IPP-005-18 3-Coil RPC: Mag. Biased 0.720 +PT
ACTS; IPP-006-18 Single Coil RPC: 0.680 U-bend +PT ACTS; PP-002-18 Bobbin Coil: 0.720 - Reduced Pull Speed ACTS; PP-004-18 3-Coil RPC: Standard 0.720 +PT
ACTS; PP-007-18 Bobbin Coil: 0.720-80 IPS Pull Speed
ANTS; IPP-B-18 3-Coil RPC - Standard and Mag. Biased (+PT/1 15/S080)
ANTS; IPP-C-18 Single Coil +PT U-bend RPC
ANTS; PP-A-18 All Bobbin Coil Probes
ANTS; PP-D-18 Data Quality and General Instructions - All Probe Types Inspection Data Outlet Nozzle to DM Weld at 158 Degradation Weld No. RPVS-22-1A Inspection Data Outlet Nozzle to DM Weld at 22 Degradation Weld No. RPVS-24-1A
IPP-R23-OH01-03-01, Ultrasonic Report Data Sheet
IPP-R23-PEN3ET-SCAN2-12940, Eddy Current Report Data Sheet
Linearity Record Pulser Receiver 30028599
Sensitivity Calibration Data Sheet No. SE-AX-DET-01 Sensitivity Calibration Data Sheet No. SE-AX-DET-03 Sensitivity Calibration Data Sheet No. SE-AX-DET-04
Sensitivity Calibration Data Sheet No. SE-CIRC-DET-01
Sensitivity Calibration Data Sheet No. SE-CIRC-DET-02
SG-SGMP-18-2, Indian Point Unit 2 2RFO23 (Spring 2018) Steam Generator Degradation Assessment, Revision 0 WDI-CAL-002, Pulser/Receiver Linearity Procedure
71111.11 Procedures O-NF-206, Initial Criticality, Revision 8 O-NF-208, Zero Power Physics Testing, Revision 5
2-POP-1.1, Plant Heatup from Cold Shutdown, Revision 92
2-POP-1.2, Reactor Startup, Revision 61
2-POP-1.3, Plant Startup from Zero to 45 Percent Power, Revision 96
71111.12 Condition Reports (CR-IP2-) (*initiated in response to inspection)
2018-02246*
71111.13 Procedures 0-VLV-435-CWS, Annual Preventative Maintenance Testing and Replacement of Backflow
Preventers, Revision 2 2-PT-R002B, Recirculation Sump Level, Revision 20 2-SOP-1.1.1, Vacuum Filling and Degassing the Reactor Coolant System, Revision 31
3-PT-M62B, 480 Volt Undervoltage/Degraded Grid Protection System Bus 5A Functional, Revision 12 3-PT-M62C, 480 Volt Undervoltage/Degraded Grid Protection System Bus 2A and 3A Functional, Revision 13 3-PT-M62C, 480 Volt Undervoltage/Degraded Grid Protection System Bus 6A Functional, Revision 13 EN-OP-119, Protected Equipment Postings, Revision 9
EN-WM-104, On Line Risk Assessment, Revision 16
IP-SMM-DC-910, Temporary Equipment, Revision 3 IP-SMM-DC-910, Temporary Equipment, Revision 9
Condition Reports (CR-IP2-) (*initiated in response to inspection)
2018-02240*
Condition Reports (CR-IP3-) (*initiated in response to inspection)
2018-01717*
Drawings 310438, Safety Switch Level Indication and Pump Control Levels Reactor Cavity and Location Containment Sumps, Revision 10 9321-F-20343, Flow Diagram, City Water, Revision 43 9321-F-27513, Flow Diagram, Auxiliary Coolant System in Primary Auxiliary Building and Fuel Storage Building, Sheet No. 1, Revision 34 9321-F-33853, Electrical Distribution and Transmission System, Revision 21
Miscellaneous Unit 3 Equipment Out of Service on Line Risk Assessment for May 1, 2018 Unit 3 Equipment Out of Service on Line Risk Assessment for May 17, 2018
Unit 3 Equipment Out of Service on Line Risk Assessment for June 6, 2018
Unit 3 Equipment Out of Service on Line Risk Assessment for June 17, 2018
71111.15 Procedures IP-SMM-DC-910, Temporary Equipment, Revision 3
OAP-035, Technical Specifications and Technical Requirements Manual - License Adherence
and Use, Revision 15
Condition Reports (CR-IP2-) (*initiated in response to inspection) 2018-02541* 2018-02548* 2018-02581* 2018-02588*
Condition Reports (CR-IP3-) 2018-01448* 2018-01530 2018-01552 2018-01570 2018-01878*
71111.18 Condition Reports (CR-IP2-)
2017-05238
Maintenance Orders/Work Orders
Drawings 9321-2561, Containment Building Residual Heat Exchanger Piping Plans and Sections (A.C.S.), Revision 23 9321-2720, Flow Diagram Auxiliary Coolant System Updated Final Safety Analysis Report, Figure No. 9.3-1 (Sheet 2), Revision 93
Miscellaneous EC-75309, Install Temporary Clamp to Facilitate Weld Repair at Valve A-98, Revision 2 EC-75312, Engineering to Evaluate the Repair of Weld Per Code Case N-666 on a Leaky Socket Weld at Vent Valve A98 on Residual Heat Removal Line 361, Revision 0
EC-76614, Evaluate Using Freeze Seal Isolation on 6-Inch Line 13 to Perform Maintenance on
Valve 769, Revision 0
Procedures
2-AOP-RCP-1, Reactor Coolant Pump Malfunction, Revision 16
2-PT-Q013, Inservice Valve Tests, Revision 52
2-PT-R027C, WCPPS Local Leak Rate, Revision 11 3-PC-R06C, Rod Position Indication System "Hot Span" Confirmation, Revision 12 3-PT-CS030, Atmospheric Steam Dump Valves Stroke Test, Revision 17
3-SOP-RC-001, Full Length Rod Control and Rod Position Indication System Operation, Revision 29 EN-OP-104, Operability Determination Process, Revision 14 SEP-APJ-006, Indian Point Energy Center Primary Containment Leakage Rate Testing (Appendix J) Program Plan, Revision 4 SOP-1.3, Reactor Coolant Pump Startup and Shutdown, Revision 47
Condition Reports (CR-IP2-)
2016-01973 2016-02383 2018-02008 2018-02359
Condition Reports (CR-IP3-) (*initiated in response to inspection)
2017-05301 2018-01261 2018-01438 2018-01463*
Maintenance Orders/Work Orders WO 00441335 WO 00501265 WO 52697548 WO 00363219-01
WO 003623215-01
Miscellaneous 2-PT-Q013, Inservice Valve Tests, Revision 52, dated Mach 19, 2018 2-PT-R027C-DS001, Containment Pressure Relief Valves PCV-1190 and PCV-1191, dated
March 29, 2018 2-PT-R027C-DS001, Containment Pressure Relief Valves PCV-1190 and PCV-1191, dated
March 31, 2016 2-PT-R027C-DS002, Containment Pressure Relief Valves PCV-1191 and PCV-1192, dated
March 29, 2018
71111.20 Procedures
0-NF-206, Initial Criticality, Revision 8
0-NF-208, Zero Power Physics Testing, Revision 5
0-SOP-CB-001, Containment Entry and Egress, Revision 1
2-POP-1.1, Plant Heatup from Cold Shutdown, Revision 92
2-POP-1.2, Reactor Startup, Revision 61
2-POP-1.3, Plant Startup from Zero to 45 Percent Power, Revision 96
2-POP-3.1, Plant Shutdown from 45 Percent Power, Revision 60 2-POP-3.3, Plant Cooldown, Hot to Cold Shutdown, Revision 83 2-POP-3.4, Secondary Plant Shutdown, Revision 10
2-POP-4.1, Operation at Cold Shutdown, Revision 8
2-POP-4.2, Operation Below 20 Percent Pressurizer Level with Fuel in the Reactor, Revision 12 2-POP-4.3, Operation without Fuel in the Reactor, Revision 3
Condition Reports (CR-IP2-) (*initiated in response to inspection) 2018-02205* 2018-02671*
71111.22 Procedures 0-PT-6Y001, B.5.b Diesel Driven Pump Capacity Test, Revision 2
3-PT-M13B1, Reactor Protection Logic Channel Functional Test (Reactor Power Greater Than
Percent - P8), Revision 24 3-PT-Q120A, 31 Auxiliary Feedwater Pump, Revision 17
EN-HU-106, Procedure and Work Instruction Use and Adherence, Revision 6
Condition Reports (CR-IP2-)
2018-03672 2018-03675
Condition Reports (CR-IP3-)
2018-00214
Maintenance Orders/Work Orders WO 52810279 WO 52811023
71124.07 Procedures 0-CY-1930, REMP Air Samples, Revision 2
0-CY-1940, REMP Broad Leaf Vegetation Samples, Revision 0
0-CY-1950, REMP Collection, Preparation, and Analysis of Water Samples, Revision 0 0-EV-DD-101, Meteorological Systems Manual, Revision 1 EN-CY-111, Radiological Groundwater Protection Program, Revision 8
IP-SMM-CY-110, Radiological Groundwater Monitoring Program, Revision 9
Condition Reports (CR-IP2-)
2017-00635 2018-02134 2018-02272 2018-03578 2018-03624
Condition Reports (CR-IP3-)
2017-03403
Miscellaneous Environmental Dosimetry Company Annual Quality Assurance Status Report, dated March 7, 2018 Indian Point Energy Center Offsite Dose Calculation Manual, Revision 4
NAQA-17-0038, Audit Report 17-007 for the Audit of Environmental Dosimetry Company, dated September 1, 2017
71151
Procedures NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 7
Condition Reports (CR-IP2-) (*initiated in response to inspection) 2018-01129 2018-02739* 2018-03931
Procedures 0-OSP-FP-001, Hydrostatic Testing of Firehose, Revision 0
0-PT-M001, Fire Brigade Equipment Inventory and Inspection, Revision 18
0-PT-M004, Fire Extinguisher Inspection, Revision 9 2-PT-M112, Fire Protection Flow Path and Hose Station Equipment Verification, Revision 6 AP-64.1, Fire Protection/Appendix R Systems and Components Governed by Technical Requirements Manual and Technical Specifications, Revision 5 SAO-703, Fire Protection Impairment Criteria and Surveillance, Revision 35
Condition Reports (CR-IP2-) (*initiated in response to inspection) 2016-00509 2017-04090 2018-03262* 2018-03306* 2018-03309* 2018-03310*
2018-03318*
Condition Reports (CR-IP3-) (*initiated in response to inspection) 2018-01112 2018-01388* 2018-01465*
Maintenance Orders/Work Orders WO 00379953 WO 00383371 WO 00417368 WO 52620568
WO 52686482 WO 52692709 WO 52709916 WO 52723346
WO 52810046
Miscellaneous EC-76593, Indian Point Energy Center Pre-Fire Plan Updates, Revision 0
Indian Point Unit 3 Technical Requirements Manual, Section 3.7.A.5, Fire Hose Stations, Revision 3 Indian Point Unit 3 Technical Requirements Manual, Section 3.7.A.6, Yard Fire Hydrants and Hydrant Hose Houses, Revision 2 NFPA-1962, Standard for the Care, Use, Inspection, Service Testing, and Replacement of Fire Hose, Couplings, Nozzles, and Fire Hose Appliances, 2018 Edition
71153 Procedures EN-FAP-MP-009, Enhanced Procurement Process for Non-Safety Related Critical Spares, Revision 3 EN-MP-100, Critical Procurements, Revision 13
Condition Reports (CR-IP3-)
2017-05133 2018-00539