IR 05000247/2010008

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IR 05000247-10-008, on 05/03/2010 - 05/20/2010; Indian Point Nuclear Generating Unit 2; Biennial Baseline Inspection of the Identification and Resolution of Problems. One Finding Was Identified in the Area of Effectiveness of Corrective Act
ML101760345
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 06/25/2010
From: Mel Gray
Reactor Projects Branch 2
To: Joseph E Pollock
Entergy Nuclear Operations
Gray, Mel NRC/RGNI/DRP/PB2/610-337-5209
References
IR-10-008
Download: ML101760345 (22)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406*1415 June 25, 2010 Mr. Joseph Site Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB Buchanan, NY 10511-0249 SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT NO.2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000247/2010008

Dear Mr. Pollock:

On May 20,2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Indian Point Nuclear Generating (Indian Point) Unit 2. The enclosed report documents the inspection results, which were discussed on May 20, 2010, with you and other members of your staff.

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

Based on the samples selected for review, the inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. En1ergy personnel identified problems at a low threshold and entered them into the Corrective Action Program (CAP).

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

However, the inspectors identified one violation of NRC requirements in the area of corrective action effectiveness.

This report documents one NRC-identified finding of very low safety Significance (Severity Level IV). The finding was determined to involve a violation of NRC requirements. However, because of its very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section VI.A.1 of the NRC's Enforcement Policy. If you contest the NCV, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region I: the Director, Office of NRC Senior Resident Inspector at Indian Point Unit 2. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the Qasis for your disagreement. to the Regional Administrator. Region I, and the NRC Senior Resident Inspector at Indian Point Unit 2. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure. and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely

.

t:1.~;v-Projects Branch 2 Division of Reactor Projects Docket No. 50-247 License No. DPR-26 Enclosure: Inspection Report No. 05000247/2010008 wI Attachment: Supplemental Information cc: w/enc: Distribution via ListServ

SUMMARY OF FINDINGS

IR 05000247/2010008; 05/03/2010 - 05/20/2010; Indian Point Nuclear Generating (Indian Point)

Unit 2; Biennial Baseline Inspection of the Identification and Resolution of Problems. One finding was identified in the area of effectiveness of corrective actions.

This NRC team inspection was performed by four NRC regional inspectors and one resident inspector. One finding of very low safety significance (Severity Level IV) was identified during this inspection and was classified as a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC)0609, "Significance Determination Process" (SDP). The cross-cutting aspect was determined using IMC 0310, "Components Within The Cross-Cutting Areas." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, December 2006.

Identification and Resolution of Problems The inspectors concluded that Entergy was generally effective in identifying, evaluating, and resolving problems. Entergy personnel identified problems at a low threshold and entered them into the Corrective Action Program (CAP). For most condition reports (CRs) reviewed, the inspectors determined that site personnel screened issues appropriately for operability and reportability, and generally prioritized issues commensurate with the safety significance of the problems. The inspectors determined that causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that corrective actions addressed the identified causes and were implemented in a timely manner.

However, the inspectors identified one violation of NRC requirements in the area of effectiveness of corrective actions. The issue was entered into Entergy's CAP during the inspection.

Entergy's audits and self-assessments reviewed by the inspectors were thorough and probing.

Additionally, the inspectors concluded that Entergy adequately identified, reviewed. and applied relevant industry operating experience (DE) to Indian Point Unit 2. Based on interviews, observations of plant activities, and reviews of the CAP and the Employee Concerns Program (ECP), the inspectors concluded that there was not evidence of challenges to the free flow of information regarding safety concerns.

Cornerstone: Mitigating Systems

This issue is considered within the traditional enforcement process because it has the potential to impede or impact the NRC's ability to perform its regulatory functions. The inspectors used the Enforcement Policy, Supplement I - Reactor Operations, to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor because the longstanding and incorrect information in the UFSAR had a potential impact on safety and licensed activities. Similar to Enforcement Policy Supplement I, example D.6, the inspectors determined the violation was of SLiV (very low safety significance) since the erroneous information not updated in the UFSAR was not used to make an unacceptable change to the facility nor impacted a licensing or safety decision by the NRC.

The inspectors determined there was a cross-cutting aspect in the area of problem identification and resolution associated with the component area of corrective action effectiveness. Specifically, Entergy personnel did not implement adequate actions in a timely manner to update the UFSAR to be consistent with plant conditions. (P.1.d per IMC 0310) (Section 40A2.1.c)

REPORT DETAILS

OTHER ACTIVITIES (OA)

40A2 Problem Identification and Resolution (PI&R) (711528 -1 sample)

.1 Assessment of the Corrective Action Program (CAP) Effectiveness

a. Inspection Scope

The inspectors reviewed Entergy's procedures that describe the CAP implementation at Indian Point Unit 2. Entergy personnel identified problems by initiating CRs for conditions adverse to quality, plant equipment deficiencies, industrial or radiological safety concems, or other significant issues .. Condition reports were subsequently screened for operability and reportability. categorized by significance level (A, most significant, through D, least significant), and assigned to personnel for evaluation and resolution or trending.

The inspectors evaluated the process for assigning and tracking issues to ensure that issues were scre.ened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the inspectors interviewed plant staff and management to determine their understanding of, and involvement with, the CAP.

The inspectors reviewed CRs selected across the seven comerstones of safety in the NRC's Reactor Oversight Process (ROP) to determine if site personnel properly identified, characterized, and entered problems into the CAP for evaluation and resolution. The inspectors selected items from functional areas that included chemistry, emergency preparedness, engineering, maintenance, operations, physical security, radiation safety, and oversight programs to ensure Entergy staff appropriately addressed problems identified in these functional areas. The inspectors selected a risk-informed sample of CRs issued since the last NRC Pl&R inspection conducted at Unit 2 in June 2008.

Insights from the site's risk analyses were considered by the inspectors to focus the sample selection and plant walkdowns on risk-significant systems and components. The corrective action review was expanded to five years for evaluation of identified concerns within eRs relative to charging pump reliability and safety injection (SI) accumulator and pressurized operated relief valve (PORV) nitrogen low pressure alarms.

The inspectors selected items from various processes implemented at Indian Point Unit 2 to verify issues were appropriately considered for entry into the CAP. Specifically, the inspectors reviewed a sample of engineering requests, operator workarounds, operability determinations, system health reports, equipment problem lists, work orders (WOs) and issues entered into the ECP.

The inspectors reviewed CRs to assess whether Entergy personnel adequately evaluated and prioritized identified issues. The CRs reviewed encompassed the full range of evaluations, including root cause analyses, apparent cause evaluations, and common cause analyses. A sample of CRs that were categorized at lower levels (level C and level D) which did not include formal cause evaluations were also reviewed by the inspectors to ensure appropriate classification consistent with EN~LI-102, Corrective Action Process, guidance. The inspectors' reviews included the appropriateness of the assigned Category, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. As part of this review, the inspectors interviewed various station personnel to fully understand details within the evaluations and the planned and completed corrective actions. The inspectors observed daily condition review group (CRG) meetings in which Entergy personnel reviewed new CRs for prioritization and assignment. The inspectors also observed Corrective Action Review Board (CARB) meetings in which station management assessed the adequacy of recent apparent and root cause analysis reports. Further, the inspectors reviewed equipment operability determinations, reportability assessments. and extent-of condition reviews for selected CRs to verify these specific reviews adequately addressed equipment operability, reporting of issues to the NRC, and the extent of problems.

The inspectors' reviews of CRs also focused on the associated corrective actions to determine whether the actions addressed the identified causes of the problems. The inspectors reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Entergy's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed CRs associated with NRC NCVs and findings since the last PI&R inspection to determine whether Entergy personnel properly evaluated and resolved the issues.

Specific documents reviewed during the inspection are listed in the Attachment to this report.

b.

Assessment

(1) Effectiveness of Problem Identification Based on the selected samples reviewed. plant walkdowns, and interviews of site personnel, the inspectors determined that Entergy personnel identified problems and entered them into the CAP at a low threshold. For the issues reviewed, the inspectors determined problems or concerns were documented in sufficient detail to understand the issues. The inspectors observed managers and supervisors at CRG and CARB meetings appropriately questioning and challenging CRs to ensure clarification of the issues. The inspectors determined Entergy personnel trended equipment and programmatic issues at levels consistent with the station's implementing procedures. In general, the inspectors did not identify issues or concerns that had not been appropriately entered into the CAP for evaluation and resolution. However, the inspectors identified and/or observed during plant tours a number of minor conditions with regards to general housekeeping and cleanliness standards that did not meet station expectations and/or were not previously entered into the CAP. Specifically:

a A fire extinguisher remained unsecured in the 51 pump area and had an expired inspection sticker; o Valve locks and chains lying on the floors in safety-related pump areas; o 22 auxiliary boiler feedwater pump oil leak beneath the pump's governor with no deficiency tag or associated CR; o Unrestrained equipment located near safety~related pumps; and o Loose debris in containment spray pump room behind flow meter panel.

In response to the equipment observations identified by the inspectors during plant walkdowns, Entergy personnel promptly initiated CRs and/or took immediate action to correct the conditions.

The inspectors determined that the issues identified did not impact equipment operability or availability. The inspectors independently evaluated the issues noted above for significance in accordance with the guidance in IMC 0612, Appendix B, "Issue Screening,"

and Appendix E, "Examples of Minor Issues." The inspectors determined that the issue was of minor significance and, therefore, is not subject to enforcement action in accordance with the NRC's Enforcement Policy.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, Entergy personnel appropriately prioritized and evaluated issues commensurate with their safety Significance. CRs were screened for operability and reportability, categorized by significance, and assigned to a department for evaluation and resolution. The CR screening process considered human performance issues, radiological safety concerns, repetitiveness and adverse trends. The inspectors observed managers and supervisors at CRG and CARB meetings appropriately questioning and challenging CRs to ensure appropriate prioritization.

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

The inspectors, however, identified one example where a lower tier apparent cause evaluation was not adequate consistent with expectations in EN-L1~119, Apparent Cause Evaluation Process, to enable effective resolution of the problem. Specifically:

  • CR-IP2:..2009-4419 documented a licensee-*identified condition regarding a communication pathway setting (microwave or Telco) discrepancy for the alert notification system (ANS) in the emergency operations facility. Entergy personnel conducted an apparent -cause evaluation and determined that the issue was likely related to a procedure adequacy issue. However, the inspectors noted that subsequent review by station personnel determined that the procedure was adequate and a procedure revision was not necessary. Further, the inspectors identified no corrective action was initiated by station personnel at that time to review the initial cause evaluation adequacy. Entergy personnel initiated CR-IP2-2010-3273 to address the issue.

The inspectors noted that this setting discrepancy with the ANS communication pathway preferred position did not have an impact on ANS functionality and was related to a conservative approach for backup power selection. The inspectors independently evaluated the issue noted above for significance in accordance with the guidance in IMC 0612, Appendix B, "Issue Screening," and Appendix E, "Examples of Minor Issues." The inspectors determined that the issue was of minor significance and, therefore, is not subject to enforcement action in accordance with the NRC's Enforcement Policy.

(3) Effectiveness of Corrective Actions The inspectors concluded tliat corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, corrective actions were identified to prevent recurrence. The inspectors concluded that corrective actions to address NRC NCVs and findings since the last PI&R inspection were timely and effective. There was, however, one performance issue of more than minor significance related to the effectiveness of corrective actions regarding actions taken to ensure the UFSAR was updated consistent with the current plant design. This finding is documented in Section 40A2.1.c.

Additionally, there were other examples where corrective actions were not fully effective or consistent with standards outlined in EN-U-102, Corrective Action Program. Specifically:

  • The inspectors identified that corrective actions have not been effective in addressing and reinforcing station standards/expectations regarding alternate safe shutdown (ASSO) cabinet and inventory control deficiencies identified over the last two years.

Specifically, the 2008 and 2010 NRC PI&R team identified similar cabinet control issues regarding outdated procedure revisions required for implementation of 2-AOP*

5S0-1, Control Room Inaccessibility - Safe ShuJdown Control. Entergy personnel also self-identified, in 2008 and 2009, missing equipment in ASSO cabinets required for implementation of alternate safe shutdown procedures. Additionally, based on limited discussions with operations staff and review of the April 2010 ASSD quarterly inventory and inspection record, the inspectors noted that there did not appear to be a consistent implementation of the station expectations regarding ASSD inventory and cabinet control specific to evaluation of tools/inventory issues for operator impact and CR initiation threshold for ASSO inventory control discrepancies.

Entergy personnel issued CR-IP2-2010-3535/3548 to address the performance issues. The inspectors determined that the issues identified were of minor significance and did not impact the ability of operations personnel to implement safe shutdown procedures nor adversely impact critical operator actions within assumed safe shutdown time lines.

  • The inspectors identified that corrective actions to reduce the likelihood of repeat failures of charging pump internal check valves experienced in June 2009 and January 2010 (CR-IP2-2009-2376 and 2010-0448) have not been implemented conSistently with CAP expectations. Specifically:

o The inspectors identified the above eRs and related cause evaluations contained limited, documented technical rationale and engineering basiS to support the failure determinations and effectiveness of previous corrective actions. The inspectors identified that Entergy personnel did not evaluate, in January 2010, whether corrective actions implemented by station personnel to reduce the likelihood of these failures since June 2009 were appropriate or adequate to minimize the repeat issues.

o The inspectors identified that Entergy personnel's monitoring actions to reduce charging pump failures regarding intemal check valves were not described in the CAP or other formal station process. Specifically, system engineering staff was tracking various monitoring aspects regarding pump run-time to ensure appropriate valve inspections/valve replacement activities were accomplished in a manner to minimize repeat failures. However, the inspectors identified these monitoring actions were conducted informally by station personnel.

Additionally, the inspectors identified that one of the informal thresholds for initiating charging pump package replacement work orders was not accomplished as expected in April 2010.

Entergy personnel issued CR-IP2-2010-4031 to address the performance issues.

The inspectors, through document review supported by interviews with the system manager, determined that the corrective action related observations identified did not impact the current functionality and availability of the charging pumps.

  • The inspectors identified corrective actions associated with emergency operating facility (EOF) battery replacements as documented in CR-IP2-2008-03062 did not correct the underlying condition. Specifically, Entergy personnel identified that EOF batteries had not been replaced in accordance with procedures within the station specified 2 year frequency (-5 years). Station personnel took corrective actions to replace the batteries at that time. However, personnel did not take action to develop a recurring replacement task or formalize the expected replacement frequency in a station process (work control) to provide for future battery replacements. Entergy personnel issued CR-IP2-2010-3554 to address the issue. The inspectors noted that the corrective action observations did not impact EOF equipment functionality or availability.

regarding investigation of unexpected contamination levels in Unit 2 storm drains, were not specific to address contributing causal factors identified by Entergy staff.

Specifically, Entergy's apparent cause appropriately identified contributing causes related to the evaluation of radiation protection controls for job coverage and radiation protection staff threshold for CR initiation. The actions assigned to address those causes were not specific, nor could it be assumed by the corrective action description that actions would address the contributing causes. Entergy personnel issued revised corrective actions to CR-IP2-201 0-00331.

The inspectors independently evaluated the performance issues and corrective action observations documented above for significance in accordance with the guidance in IMC 0612, Appendix B, "Issue Screening," and Appendix E, "Examples of Minor Issues," The inspectors determined that the issues were of minor significance and, therefore, are not subject to enforcement action in accordance with the NRC's Enforcement Policy.

c. Findings

UFSAR Section 5.1.3.12. Cathodic Protection, Not Updated Consistent with Current Plant Conditions

Introduction:

The inspectors identified a Severity Level IV (SUV) NCV of 10 CFR 50.71 (e)because Entergy personnel did not update the UFSAR with information consistent with plant conditions. Specifically, Entergy personnel did not remove reference to or correct information to reflect current plant conditions with regard to systems described as having cathodic protection consistent with UFSAR Section 5.1.3.12, Cathodic Protection.

DescriRtion: In late 2005, Entergy personnel identified that UFSAR Section 5.1.3.12, regarding cathodic protection of certain systems, was not consistent with current plant conditions. Specifically, Section 5.1.3.12 described circulating water lines, service water lines, and metallic structures inside the intake structure as,having cathodic protection.

Entergy's review determined that as early as the 19805 either these systems' associated cathodic protection systems were no longer functional or were potentially not installed. As part of a number of actions to address overall cathodic protection at Units 2 and 3, Entergy personnel issued a corrective action to revise the UFSAR [CR-IP2-2005-03902: corrective action (CA) #14]. However, the inspectors noted this corrective action was dependent upon the completion of further engineering assessments/surveys regarding existing site corrosion conditions and subsequent engineering determinations of the need for cathodic protection to be installed at the station.

In 2008, Entergy personnel, in part to ensure actions and resources applied would support the resolution of the degraded cathodic protection system, designated the cathodic protection system as a top ten equipment reliability station focus item and developed a revised action plan that included verification of existing cathodic protection systems, performance of site corrosion surveys, and final detemlination on systems requiring cathodic protection. At that time, Entergy personnel continued to identify that the UFSAR remained inconsistent with current plant conditions and continued to extend the due date for CR~IP2-2005~03902 (CA #14) since the corrosion surveys and engineering assessments had not been completed.

The inspectors identified that the discrepancy in UFSAR Section 5.1.3.12 should have been updated in a timeframe consistent with the standards and expectations delineated in IP-SMM-Ll~ 113, IPEC Technical Specification Bases, Technical Requirements Manual and Updated Final Safety Analysis Report Amendment Preparation, Control and Change Process. Station procedures require Entergy personnel to periodically update/correct information in the UFSAR within an operating cycle to ensure the UFSAR accurately reflects the plant configuration and operation. The inspectors determined there were multiple opportunities and various levels of recognition by Entergy staff and management since 2005 in which the UFSAR should have been updated to reflect the status of cathodic protection at the station. The inspectors noted that Entergy personnel tracked the corrective action in accordance with CAP procedures. However, the inspectors determined those corrective action reviews were not sufficient to determine whether the corrective action remained adequate when 10ng~lead items like engineering assessments were not completed in the timeframe assumed in 2005.

Entergy issued CR-IP2-2010-03512 to address the UFSAR discrepancy. The inspectors also noted that Entergy staff has made progress consistent with its current action plan including completion of a site cathodic protection and corrosion survey that included service water and metallic structures of the intake structure.

Analysis:

This issue was a performance deficiency because Entergy personnel had reasonable opportunity to correct and update the UFSAR to be consistent with current plant conditions. This issue is considered within the traditional enforcement process because it has the potential to impede or impact the NRC's ability to perform its regulatory functions. The inspectors used the Enforcement Policy, Supplement I - Reactor Operations, to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor because the longstanding and incorrect information in the UFSAR had a potential impact on safety and licensed activities. Cathodic protection is important to ensure the long-term reliability of piping systems that are located at the site in environmental conditions susceptible to corrosion induced failures. Similar to Enforcement Policy Supplement 1, example 0.6, the inspectors determined the violation was of SLiV (very low safety significance) because the erroneous information not updated in the UFSAR was not used to make an unacceptable change to the faCility nor did it impact a licensing or safety decision by the NRC.

The inspectors determined there was a cross-cutting aspect in the area of problem identification and resolution associated with the component area of corrective action effectiveness. Specifically, Entergy personnel did not implement adequate actions in a timely manner to update the UFSAR to be consistent with current plant conditions. (P.1.d per IMC 0310)

Enforcement:

10 CFR 50.71(e} requires that licensees shall periodically update the Final Safety Analysis Report (FSAR), originally submitted as part of the application for the operating license, to assure that the information included in the report contains the latest information developed. In part, the submittal shall include the effects of all changes made in the facility or procedures as described in the FSAR such that FSAR as updated remains complete and accurate'. Contrary to the above, since 2005 Entergy became aware of and failed to update the UFSAR to accurately reflect the status of cathodic protection systems as described in UFSAR Section 5.1.3.12. The failure to adequately update the UFSAR as required by 10 CFR 50.71(e) is characterized as a Severity Level IV violation. However, because the violation was of very low safety significance and was entered in the Entergy's corrective action program (CR-IP2-2010-03512), this violation is being treated as an NCV consistent with NRC Enforcement Policy and is identified as NCV 05000247/2010008:

UFSAR Section 5.1.3.12, Cathodic Protection, not updated consistent with current plant conditions .

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

a. Inspection Scope

The inspectors selected a sample of CRs associated with the review of industry OE to determine whether Entergy personnel appropriately eValuated the OE information for applicability to Indian Point Unit 2 and had taken appropriate aotions, when warranted.

The inspectors reviewed CR evaluations of OE documents associated with a sample of NRC generic letters and information notices to ensure that Entergy staff adequately

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considered the underlying problems associated with the issues for resolution via their CAP. The inspectors also observed eRG and CARS meetings to determine if industry OE was considered during the CR screening and resolution process. A list of the documents reviewed is included in the Attachme,nt to this report.

b.

Assessment I The inspectors determined that Entergy staff appropriately considered industry OE information for applicability, and used the information for corrective and preventive actions I

to identify and prevent similar issues when appropriate. The inspectors determined that DE was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors observed that industry DE was routinely discussed and considered during the conduct of CRG and CARS meetings.

c. Findings

No findings of significance were identified .

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of Quality Assurance (QA) audits, including a review of several of the findings from the most recent audit of the CAP, and a variety of self~

assessments focused on various plant programs. These reviews were performed to determine if problems identified through these assessments were entered into the CAP when appropriate, and whether corrective actions were initiated to address identified deficiencies. The effectiveness of the audits and assessments was evaluated by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

Additionally, the inspectors reviewed a 2009 station self-assessment regarding the safety culture and work environment at the station. This review was conducted to evaluate whether Entergy self-identified areas for improvement and current challenges regarding the safety culture. The inspectors verified Entergy initiated actions to address areas for improvement. A list of documents reviewed is included in the Attachment to this report.

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

c. Findings

No findings of significance were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

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

b. Assessment During interviews, plant staff expressed a willingness to use the CAP to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation where there were indications an individual had been hesitant to raise a safety issue. All persons interviewed demonstrated an adequate knowledge of the CAP and ECP. Based on these limited interviews, the inspectors concluded that there was not evidence of challenges to the free flow of information regarding safety concerns .

.c. Findings No findings of Significance were identified.

40A6 Meetings. Including Exit On May 20,2010, the inspectors presented the inspection results to Mr. Joseph Pollock, Site Vice President, and to other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in the report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

Joe Pollock, Site Vice President

Ann Stewart, Licensing Engineer

Anthony Ambrose, Senior Emergency Planner

Barbara Taggart, Employee Concerns Coordinator

Bob Walpole, Licensing Manager

Brian Sullivan, Emergency Planning Manager

Brian Zanstra, System Engineer

Charles Johnson, Security Supervisor

Christopher Ingrassia, System Engineer

Dan Morales, System Engineer

Dan Wilson, Chemistry Manager

Frank Inzirillo, Quality Assurance Manager

George Dahl, Licensing Engineer

Ivan Sinert. System Engineer

Jeff Cottam, Fire Protection Engineer

Joe Reynolds, Specialist - Corrective Actions & Assessment

John Balletta, Control Room Supervisor

John Dinelli, Operations Manager

Kevin Davidson, Assistance Plant Manager

Mark Cox, Manager, Corrective Action & Assessment Manager

Michael Dries,. System Engineer

Mike Ferreti, Maintenance Supervisor/Coordinator

Mike Tumicki, Specialist - Corrective Actions & Assessment

Nelson Azevedo, Engineering Supervisor

Ovidio Ramirez, Jr., System Engineer

Patrie Conroy, Nuclear Safety Assurance Director

Paul Bode, OE Coordinator

Robin Daley, System Engineer

Tat Chan, Engineering Supervisor

Thomas Gander *. Operations Procedure Group

Tim Garvey, Supervisor of Emergency Planning Infrastructure

Timothy Garvey, Emergency Planning Supervisor

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000247/2010008-01 NCV UFSAR Section 5.1.3.12, Cathodic Protection, not updated consistent with current plant conditions (Section 40A2.1.c)

LIST OF DOCUMENTS REVIEWED

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