IR 05000247/2018002
| ML19010A317 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/09/2019 |
| From: | Daniel Schroeder Reactor Projects Branch 2 |
| To: | Vitale A Entergy Nuclear Operations |
| Schroeder D | |
| References | |
| IR 2018002 | |
| Download: ML19010A317 (24) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ary 9, 2019
SUBJECT:
ERRATA FOR INDIAN POINT NUCLEAR GENERATING - INTEGRATED INSPECTION REPORT 05000247/2018002 AND 05000286/2018002
Dear Mr. Vitale:
The U.S. Nuclear Regulatory Commission (NRC) identified two administrative errors in the NRC Integrated Inspection Report 05000247/2018002 and 05000286/2018002, dated August 1, 2018 (ADAMS Accession No. ML18213A153). In the List of Findings and Violations, the docket number was listed incorrectly, and has been changed to 05000247. In Section 71153, Follow-up of Events and Notices of Enforcement Discretion, the docket number is again listed incorrectly, and has been changed to 05000247. As a result, the NRC has reissued the report in its entirety to correct these errors.
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
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 Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Entergys 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 NRCs 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 Not Applicable 71111.15 Non-Cited Violation (NCV)05000247/2018-002-01 Closed 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 Status Results Section LER 05000286/2017-004-00 Reactor Trip Due to Main 71153 Closed Generator Loss of Field LER 05000286/2018-001-00 Reactor Trip Due to Main 71153 Closed Generator Loss of Excitation
TABLE OF CONTENTS
INSPECTION SCOPES
REACTOR SAFETY
.....................................................................................................................
RADIATION SAFETY
...................................................................................................................
OTHER ACTIVITIES - BASELINE
..............................................................................................
INSPECTION RESULTS
............................................................................................................
EXIT MEETINGS AND DEBRIEFS
............................................................................................ 15
DOCUMENTS REVIEWED
......................................................................................................... 16
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 Entergys 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 generator on June 27, 2018.
71111.05AQ - Fire Protection Annual/Quarterly
Quarterly Inspection (6 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
(4) Alternate safe shutdown pressurizer level instrument PT-3101 on June 28, 2018
Unit 3
(5) Fuel storage building (PFP-315 and PFP-316) on June 6, 2018
(6) Diesel generator building (PFP-354) on June 29, 2018
71111.07A - Heat Sink Performance
Heat Sink (1 Sample)
The inspectors observed Entergys 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 Entergys 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 Entergys boric acid corrosion control program performance.
(3) The inspectors reviewed Entergys steam generator aging management program,
including eddy current 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 plants
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,
2018
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 Entergys 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 Entergys 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 Entergys 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 Entergys implementation of its corrective action program related to
the following issues:
(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 LE
- R.
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 LE
- R.
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 Not Applicable 71111.15
NCV 05000247/2018-002-01
Closed
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
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 plants TSs, respectively.
The inspectors reviewed the RCS leakage monitoring records, Entergys event report, the
causal analyses, and previous examination records. These reviews were conducted to
determine whether Entergys 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 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 the RPV head is not accessible when the plant is 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 Number 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 Entergys
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 NRCs 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 Processs 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 Entergys ability to
foresee and correct, Entergys actions did not contribute to the degraded condition, and the
actions taken were reasonable to identify and address the condition. Furthermore, because
Entergys actions did not contribute to this violation, it will not be considered in the
assessment process or the NRCs 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
hours 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
hours.
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 Entergys 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 Entergys
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 Entergys 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
Procedures
IP-SMM-OP-104, Offsite Power Continuous Monitoring and Notification, Revision 13
Condition Reports (CR-IP2-) (*initiated in response to inspection)
2018-03277*
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
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
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
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
Condition Reports (CR-IP2-) (*initiated in response to inspection)
2018-02246*
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
21-F-20343, Flow Diagram, City Water, Revision 43
21-F-27513, Flow Diagram, Auxiliary Coolant System in Primary Auxiliary Building and Fuel
Storage Building, Sheet No. 1, Revision 34
21-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
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*
Condition Reports (CR-IP2-)
2017-05238
Maintenance Orders/Work Orders
Drawings
21-2561, Containment Building Residual Heat Exchanger Piping Plans and Sections (A.C.S.),
Revision 23
21-2720, 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
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*
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
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
71152
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