IR 05000247/2010004

IR 05000247-10-004, on 07/01/2010 - 09/30/2010, Indian Point Nuclear Generating, Indian Point, Unit 2, Post-Maintenance Testing

ML103140355
Person / Time
Site:	Indian Point
Issue date:	11/10/2010
From:	David Lew Reactor Projects Branch 2
To:	Joseph E Pollock Entergy Nuclear Operations
Gray, Mel NRC/RGNI/DRP/PB2/610-337-5209
References
EA-10-212 IR-10-004
Download: ML103140355 (37)

Text

{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC INTEGRATED INSPECTION REPORT 05000247/2010004 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Pollock:

On September 30,2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Unit 2. The enclosed integrated inspection report documents the inspection results, which were discussed on October 28, 2010, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one self-revealing finding of very low safety significance (Green). This 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 2.3.2 of the NRC Enforcement Policy. If you contest 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 Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Indian Point Nuclear Generating Unit 2. Additionally, if you disagree with the cross-cutting aspect assigned to the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Indian Point Nuclear Generating Unit 2.

r I In addition, the inspectors reviewed Licensee Event Report 05000247/2010-004, which described the circumstances associated with reactor coolant system pressure boundary leakage from a five-sixteenth inch through-wall weld defect located at a socket weld associated with the 22 reactor coolant pump three-quarter inch seal bypass line. Although this issue constitutes a violation of NRC requirements, in that any reactor coolant system boundary leakage at power constitutes a violation, the NRC concluded that this issue was not within Entergy's ability to foresee and correct, that Entergy staff's actions did not contribute to the degraded condition, and that actions taken were reasonable to identify and address this matter. As a result, the NRC did not identify a performance deficiency. A risk evaluation was performed and the issue was determined to be of very low safety significance. Based on these facts, I have been authorized, after consultation with the Director, Office of Enforcement, and the Regional Administrator, to exercise enforcement discretion in accordance with Section 3.5 of the Enforcement Policy and refrain from issuing enforcement for the violation.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 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 of from the Publicly Available Records 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).

~C~ David C. Lew, Director DiviSion of Reactor Projects Docket No. 50*247 License No. DPR-26 Enclosure: Inspection Report No. 05000247/2010004 wI Attachment: Supplemental Information cc w/encl: Distribution via ListServ Enclosure In addition, the inspectors reviewed licensee Event Report 05000247/2010~004, which described the circumstances associated with reactor coolant system pressure boundary leakage from a five-sixteenth inch through~wall weld defect located at a socket weld associated with the 22 reactor coolant pump three~quarter inch seal bypass line. Although this issue constitutes a violation of NRC requirements, in that any reactor coolant system boundary leakage at power constitutes a violation, the NRC concluded that this issue was not within Entergy's ability to foresee and correct, that Entergy staffs actions did not contribute to the degraded condition, and that actions taken were reasonable to identify and address this matter. As a result, the NRC did not identify a performance deficiency. A risk evaluation was performed and the issue was determined to be of very low safety significance. Based on these facts, I have been authorized, after consultation with the Director, Office of Enforcement, and the Regional Administrator, to exercise enforcement discretion in accordance with Section 3.5 of the Enforcement Policy and refrain from issuing enforcement for the violation.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 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 of from the Publicly Available Records 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, IRA! David C. Lew, Director Division of Reactor Projects Docket No. 50~247 license No. DPR-26 Enclosure: Inspection Report No. 05000247/2010004 wI Attachment: Supplemental Information Distribution (via email) W.Dean, RA R. Conte, DRS M. Catts, SRI M. Dapas. ORA D. Holody, ORA ) A. Ayegbusi, RI D. Lew. DRP G. Miller, RI OEDO D. Hochmuth, DRP J. Clifford. DRP M. Gray. DRP D. Bearde, DRS D. Collins, DRP B. Bickett, DRP RidsNrrPMlndianPoint Resource D. Roberts. DRS S. McCarver. DRP RidsNrrDorlLpl1-1 Resource P. Wilson. DRS M. Jennerich, DRP ROPreport Resource@nrc.gov SUNSI Review Complete: bb (Reviewers Initials) ML103140355 DOCUMENT NAME: G:\DRP\BRANCH2\a - Indian Point 2\1nspection Reports\lP2 IR 201 0-004\IP2 201 0.004.final.docx After declaring this document "An OffICial Agency Record" it will be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIIDRP Ilhp RI/DRP I RIIORA I NAME MCatts/mc BBickettlbb DHolody/mmm for DATE 10125/10 10/25/10 10/27/10 OFFICE RIIDRS I RIIDRP I RIIDRP I NAME RConte/rc MGray/mQ DLew/dl DATE 10126/10 11/03/10 11/09/10 OFFICIAL RECORO COpy

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U.S. Nuclear Regulatory Commission Region I Docket No.: 50-247 License No.: DPR-26 Report No.: 05000247/2010004 Licensee: Entergy Nuclear Northeast (Entergy) Facility: Indian Point Nuclear Generating Unit 2 Location: Buchanan, NY 10511 Dates: July 1, 2010 through September 30,2010 Inspectors: M. Catts, Senior Resident Inspector - Unit 2 O. Ayegbusi, Resident Inspector - Unit 2 B. Bickett, Senior Project Engineer - Region I H. Gray, Senior Reactor Inspector - Region I J. Nicholson, Health Physicist - Region I Approved By: Mel Gray, Chief Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000247/2010004; 7/01/2010 - 9/30/2010; Indian Point Nuclear Generating (Indian Point)

Unit 2; Post-Maintenance Testing.

This report covered a three-month period of inspection by resident and region-based inspectors.

One non-cited violation (NCV) of very low significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process." The cross-cutting aspect for the finding was determined using IMC 0310, "Components within the Cross-Cutting Areas."

Findings for which the significance determination process does not apply may be Green, or be assigned a severity level after NRC management review. The NRC's program for overseeing safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings," was identified because Entergy personnel did not adequately implement the preventive maintenance (PM) procedure for the B reactor trip breaker (RTB}.Specifically, on March 10,2009, Entergy staff did not adequately implement PM Procedure 0-BRK-401-ELC, 'Westinghouse, Reactor Trip and Bypass Circuit Breaker (DB-50)," which resulted in the inoperability of the B RTB shunt trip device function on July 5, 2010. Entergy personnel took immediate corrective actions to replace the B RTB and its associated fuse block assembly. This issue was entered into Entergy's corrective action program as condition report (CR)-IP2-201 0-4451.

This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (Le. core damage). Specifically, inadequate preventive maintenance contributed to the failure of the shunt trip device function of the B RTB. Using IMC 0609.04, "Phase 1 -Initial Screening and Characterization of Findings," the finding was determined to have very low safety Significance (Green)because the finding did not result in a loss of system safety function because the undervoltage coil was operable; there was not an actual loss of safety function of a single train for greater than its technical speCification allowed outage time; and the issue was not potentially risk significant due to a seismic, flooding, or severe weather initiating event.

The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program attribute of complete and accurate identification of issues. Specifically, Entergy staff performing preventive maintenance did not identify and communicate RTB conditions completely and accurately such that the B RTB conditions were fully identified in the CAP. [P.1(a) per IMC 0310] (Section 1R19)

REPORT DETAILS

Summary of Plant Status

Indian Point Unit 2 began the inspection period operating at full reactor power (100%). The Unit 2 reactor automatically tripped during a planned shutdown on September 3,2010, due to high water level in the 23 steam generator. Unit 2 remained shutdown for a planned maintenance outage to repair the 21 reactor coolant pump (RCP) motor. Operators returned the plant to full power on September 15, 2010. Unit 2 remained at or near full power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Impending Adverse Weather

a. Inspection Scope

Because severe weather was forecast in the vicinity of the facility for July 14, 2010, the Inspectors reviewed Entergy's overall preparations/protection for the expected weather conditions. The inspectors walked down systems required for normal operation and shutdown conditions because their safety related functions could be affected, or required, as a result of high wind impacts or the loss of offsite power. The inspectors evaluated the plant staff's preparations in accordance with site procedures to determine if actions were adequate. During the inspection, the inspectors focused on plant specific design features and station procedures used to respond to adverse weather conditions.

The inspectors also toured the site to identify loose debris that could become projectiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for the systems selected for inspection, and reviewed whether operator actions were appropriate as specified by plant specific procedures.

The inspectors also reviewed a sample of corrective action program (CAP) items to verify that the licensee identified adverse weather impact issues at an appropriate threshold and dispositioned them through the CAP in accordance with station corrective action procedures.

Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one sample as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified. ==1R04 Equipment Alignment

.1 Partial System Walkdowns

a.== Inspection Scope The inspectors performed partial system walkdowns of the follOwing risk significant systems:

• July 27,2010,22 safety injection train after post maintenance testing (PMT);
• September 14, 2010, 22 residual heat removal train after a maintenance outage; and
• September 27,2010,22 auxiliary feedwater (AFW) pump after a maintenance outage.

The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors focused on those conditions that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, technical specification requirements, technical specifications (TSs),work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Entergy staff had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization.

Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of three partial system walkdown samples as defined in NRC Inspection Procedure 71111.04.

b. Findings

No findings were identified .

.2 Full System Walkdown

a. Inspection Scope

On September 21 and 22, 2010, the inspectors perfonmed a complete system alignment inspection of the safety injection system to verify the functional capability of the system.

The inspectors selected this system because it was considered both safety significant and risk significant in the licensee's probabilistic risk assessment. The inspectors inspected the system to review mechanical and electrical equipment line ups, electrical power availability, component lubrication and equipment cooling, hanger and support functionality, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. In addition, the inspectors reviewed the CAP database to ensure that system adverse conditions were being identified and appropriately resolved.

Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one complete system walkdown sample as defined in NRC Inspection Procedure 71111.04.

b. Findings

No findings were identified. ==1R05 Fire Protection