IR 05000247/2002001

2002 Annual Assessment Letter - Indian Point 2 (Report 50-247/02-01)

ML020630475
Person / Time
Site:	Indian Point
Issue date:	03/04/2002
From:	Miller H Region 1 Administrator
To:	Dacimo F Entergy Nuclear Operations
References
IR-02-001
Download: ML020630475 (11)

Text

March 4, 2002

SUBJECT:

ANNUAL ASSESSMENT LETTER - INDIAN POINT 2 (REPORT 50-247/02-01)

Dear Mr. Dacimo:

On January 31, 2002, the NRC staff completed its end-of-cycle plant performance assessment of Indian Point 2 (IP2). The end-of-cycle review for IP2 involved the participation of all technical divisions in evaluating performance indicators for the most recent quarter and inspection results for the period from April 1, 2001 through December 31, 2001. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

Overall, IP2 operated in a manner that preserved public health and safety. Although overall performance was acceptable, it remained within the multiple degraded cornerstone column of the Action Matrix. The degraded cornerstones were based on several inspection findings in the initiating events and mitigating systems cornerstones. These degraded cornerstones are associated principally with the performance problems revealed during an August 1999 reactor trip with electrical distribution system complications and a February 2000 steam generator tube failure.

NRC oversight of IP2 activities remained at heightened levels throughout this assessment period.

Regulatory performance meetings were conducted in April, June, and December 2001, in which we reviewed status of your performance improvement efforts. On September 6, 2001, Entergy Nuclear Operations became the new owner of IP2. Subsequently, you requested we reschedule team inspections which we had planned to evaluate status of several degraded cornerstone issues. You indicated rescheduling these inspections would permit you to immediately undertake a number of improvement initiatives, including a mid-cycle outage to address some longstanding equipment problems and a comprehensive self-assessment. The self-assessment was performed over a three-week period in October of 2001 by a large team of industry professionals. As discussed, at the December 2001 regulatory performance meeting, this team confirmed many of the weaknesses identified in previous NRC inspections and assessments. In January 2002, you submitted your Fundamentals of Improvement Plan (FIP) which is intended to guide further improvement efforts at the station.

During the assessment period, we identified ongoing substantive cross-cutting issues in human performance and problem identification and resolution (PI&R). While some progress has been

Fred Dacimo

noted, these cross-cutting issues also indicate the need for continuing management attention to improvement efforts. The findings in the PI&R area involved a number of untimely or ineffective corrective actions. In the human performance area, knowledge and skill weaknesses were noted during operator response to certain plant problems and events. These weaknesses were indicative of operator training weaknesses and inconsistent enforcement of high performance standards for operating crews while on-shift. One inspection finding of substantial significance in the mitigating systems cornerstone involved weak operator performance during requalification exams last Fall, as described in our December 5, 2001 and February 28, 2002 letters.

Emergency preparedness inspection findings, noted in last years assessment, were closed during this assessment period based on improved performance. Enclosures 1 and 2 provide additional details regarding performance indicators and significant inspection findings for IP2.

As stated in prior correspondence, the NRC will continue heightened oversight of Indian Point 2 until we gain confidence that your performance improvement program has substantially addressed performance issues that underlie the degraded cornerstones. In this regard, we plan a variety of activities including inspections, site visits, quarterly assessments and meetings during which we will review performance metrics, and independently verify corrective actions. For example, on February 27, the NRC conducted a meeting to review the status of your FIP efforts. We plan to hold a follow-up to this meeting with you in May 2002. The June 2002 NRC supplemental team inspection will be key in evaluating your progress. You will note that our inspection plan includes a supplemental inspection in December 2002 that could be conducted, if needed as a follow up.

Enclosure 3 details inspections that are planned through March 31, 2003. The inspection plan is provided to facilitate resource planning and to allow for scheduling conflicts and personnel availability issues to be resolved in advance of inspector onsite arrival. Routine resident inspections are not listed due to their ongoing and continuous nature.

Consistent with the Reactor Oversight Process, we are finalizing plans to meet with you to discuss NRCs assessment of your performance during the recently completed assessment period, and your continuing actions to affect performance improvements at IP2. This meeting, which will be open for public observation, is scheduled for 7:00 p.m., March 14, 2002. The meeting location will be announced in our Meeting Notice. Also, in accordance with IMC 0305, Operating Reactor Assessment Program, the recent performance of your plant will be discussed at the upcoming Agency Action Review meeting. We will notify you via separate correspondence if any agency actions change as an outcome of the March meeting.

Immediately following the terrorist attacks on the World Trade Center and the Pentagon, the NRC issued safeguards advisories recommending that nuclear power plant licensees go to the highest level of security, and all promptly did so. With continued uncertainty about the possibility of additional terrorist activities, the Nation's nuclear power plants, including IP2 remain at a high level of security. On February 25, 2002, the NRC issued an Order to all nuclear power plant licensees, requiring them to take certain additional interim compensatory measures to address the generalized high-level threat environment. These additional compensatory requirements will provide the NRC with reasonable assurance that public health and safety and the common defense and security continue to be adequately protected in the current generalized high-level

Fred Dacimo

threat environment. These requirements will remain in effect pending notification from the Commission that a significant change in the threat environment occurs, or until the Commission determines that other changes are needed following a more comprehensive re-evaluation of current safeguards and security programs. To date, we have monitored IP2 actions in response to the terrorist attacks through a series of audits. With the issuance of the Order, we will evaluate IP2 compliance with these interim requirements.

In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Peter Eselgroth at 610-337-5234 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA by James T. Wiggins Acting For/

Hubert J. Miller Regional Administrator Docket No. 50-247 License No. DPR-26 Enclosures:

1. IP2 Performance History Chart 2. IP2 Performance History Details 3. IP2 Inspection Schedule

Fred Dacimo

cc w/encl:

J. Yelverton, Chief Executive Officer M. Kansler, Senior Vice President and CEO R. J. Barrett, Vice President - Operations L. Temple, General Manager - Operations D Pace, Vice President - Engineering J. Knubel, Vice President Operations Support J. McCann, Manager, Nuclear Safety and Licensing J. Kelly, Director of Licensing C. Faison, Manager - Licensing, Entergy Nuclear Operations, Inc.

H. Salmon, Jr., Director of Oversight, Entergy Nuclear Operations, Inc.

J. Fulton, Assistant General Counsel, Entergy Nuclear Operations, Inc.

W. Flynn, President, New York State Energy, Research and Development Authority J. Spath, Program Director, New York State Energy Research and Development Authority P. Eddy, Electric Division, New York State Department of Public Service C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law T. Walsh, Secretary, NFSC, Entergy Nuclear Operations, Inc.

Mayor, Village of Buchanan R. Albanese, Executive Chair, Four County Nuclear Safety Committee S. Lousteau, Treasury Department, Entergy Services, Inc.

M. Slobodien, Director Emergency Programs B. Brandenburg, Assistant General Counsel P. Rubin, Operations Manager T. Walsh, Secretary - NFSC W. Flynn, President, New York State Energy Research and Development Authority Assemblywoman Sandra Galef, NYS Assembly County Clerk, Westchester County Legislature A. Spano, Westchester County Executive R. Bondi, Putnam County Executive C. Vanderhoef, Rockland County Executive J. Rampe, Orange County Executive T. Judson, Central NY Citizens Awareness Network M. Elie, Citizens Awareness Network D. Lochbaum, Nuclear Safety Engineer, Union of Concerned Scientists Public Citizen's Critical Mass Energy Project M. Mariotte, Nuclear Information & Resources Service E. Smeloff, Pace University School of Law L. Puglisi, Supervisor, Town of Cortlandt Congresswoman Sue W. Kelly Congressman Ben Gilman Congresswoman Nita Lowey Senator Hilary Rodham Clinton Senator Charles Schumer J. Riccio, Greenpeace

Fred Dacimo

Distribution w/encl:

H. Miller, RA/J. Wiggins, DRA (1)

F. Congel, OE (2)

T. Bergman, RI EDO Coordinator W. Raymond, SRI - Indian Point 2 E. Adensam, NRR (ridsnrrdlpmlpdi)

RidsNrrDipmIipb P. Eselgroth, DRP P. Milano, PM, NRR G. Vissing, PM, NRR (Backup)

D. Screnci, PAO N. Sheehan, PAO S. Barber, DRP R. Martin, DRP W. Lanning, DRS R. Crlenjak, DRS DRS Branch Chiefs (5)

L. Scholl, DRS T. Walker, DRS J. McFadden, DRS P. Frechette, DRS D. Silk, DRS B. Platchek, DRP Region I Docket Room (w/concurrences)

DOCUMENT NAME: G:\\BRANCH2\\IP2\\EOC ltr ip2 2002_final.wpd After declaring this document An Official Agency Record it will/will not 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 RI/DRP

E RI/DRP E NRR NRR RI/DRP ORA NAME SBarber/S B

PEselgroth/P WE Jmunday/b y e-mail and telecon Mjohnson/

by e-mail and telecon BHolian/B EH HMiller/by telecon W/PWE/JTW DATE 03/4/02 03/4/02 03/4/02 03/4/02 03/04/02 03/4/02 OFFICIAL RECORD COPY

1 Inspections previously scheduled for this quarter were delayed at licensee request.

2 These issues are scheduled to be inspected for potential closure in June 2002.

3 Inspections previously scheduled for this quarter were delayed at licensee request.

4These issues are scheduled to be inspected for potential closure in June 2002.

5This is a YELLOW finding for annual operator requalification examination failures. A supplemental inspection to review this matter is planned for April 2002.

6 Because of sufficient performance improvement observed during a June 2001 EP exercise, the NRC closed out the degraded cornerstone in this area.

ENCLOSURE 1 IP2 PERFORMANCE HISTORY CHART-INPUTS TO NRC ACTION MATRIX (EXPLANATORY NOTES FOLLOW)

CY 2000 CY 2001 CY 2002 Cornerstone Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 IE PI1 White IF1 Red IF1 Red IF1 Red IF1 Red

2 MS IF2 Yellow PI2 White IF2 Yellow PI2 White

PI2 White

PI2 White

IF3 Yellow

IF3 Yellow5 BI PI3 Yellow EP IF4 White IF4 White IF5 White IF6 White IF7 White IF5 White IF6 White IF7 White IF5 White IF6 White IF7 White IF5 White IF6 White IF7 White

Matrix Column N/A Multiple Degraded Multiple Degraded Multiple Degraded Multiple Degraded Multiple Degraded Multiple Degraded Multiple Degraded Multiple Degraded () indicates a continuing finding

ENCLOSURE 2 IP2 Performance History Details (Inputs to NRC Action Matrix)

CURRENT PERFORMANCE INDICATORS AND INSPECTION FINDINGS:

!

All PIs for ROP-2 were green.

!

There were 17 GREEN findings and one YELLOW finding during ROP-2. The YELLOW finding was based on inspection follow-up of the September and October 2001 annual operator requalification examinations, and was based on the high number of failures of operators during simulator examinations. This inspection finding affected Mitigating System Cornerstone. (IF3)

!

In addition to these current PIs and findings, the RED and YELLOW findings (described below) continued to affect the assessment of IP2 performance. The NRC has conducted supplemental inspections to review licensee progress in addressing the underlying causes for these findings. Currently, a supplemental inspection is planned for June 2002 to review these issues with a follow up inspection planned for December 2002, if needed.

HISTORICAL PERFORMANCE INDICATORS:

A description of historical performance indicators is discussed below:

!

An Initiating Events PI was determined to be WHITE based on excessive reactor trip frequency. This was primarily due to the August 1999 automatic and the February 2000 manual reactor trips. (PI1)

!

A Mitigating Systems PI was determined to be WHITE based on excessive emergency diesel generator unavailability. This was due to an improper setpoint for an Emergency Diesel Generator breaker as revealed by investigation of the August 1999 event. (PI2)

!

During the February 2000 steam generator tube failure, the actual leak rate caused the Barrier Integrity PI was determined to be YELLOW based on exceeding the Technical Specification Leak Rate (ConEd Reported 109 gpm) for Steam Generator Tube Integrity based on the first quarter 2000 PI data. (PI3)

HISTORICAL INSPECTION FINDINGS:

A description of historical inspection findings is discussed below:

NRC inspections identified and/or confirmed risk significant findings in three cornerstones:

Initiating Events, Mitigating Systems, and Emergency Preparedness. These were based on applying the ROP Significance Determination Process (SDP) to findings that were the result of licensee performance problems or issues.

!

An inspection finding for the Initiating Event Cornerstone was determined to be RED based on a significant increase in the likelihood of a steam generator tube rupture with a corresponding increase in Core Damage Frequency (CDF) and large early release frequency (LERF). The licensee performance issue that led to this finding was a steam

Enclosure 2 (contd)

generator tube inspection program that was deficient in many respects, specifically in that timely corrective actions were not taken for conditions adverse to quality. The NRCs assessment was that the final determination was RED, which, by itself, places the plant in the multiple degraded cornerstone category. (IF1)

!

Based on inspection follow-up of the August 1999 event, an inspection finding for the Mitigating System Cornerstone was determined to be YELLOW based on the unavailability of certain auxiliary feedwater components and a degradation in feed and bleed capability. Some of the important licensee performance issues that led to these findings were the improper configuration of a Station Auxiliary Transformer Tap Changer and an improper setpoint for an Emergency Diesel Generator breaker. An NRC benchmarking study was performed of relevant findings during the ROP pilot phase (published in the ROP Feasibility Review, Attachment 7 to SECY 00-0049) and the study categorized this finding as YELLOW, which is a degraded cornerstone. Although this finding pre-dated initial ROP implementation, it provided important performance insights.

(IF2)

!

Based on NRC observations of a September 1999 exercise, an inspection finding for the Emergency Preparedness Cornerstone was determined to be WHITE based on a failure to identify an improper classification during self-critique of a September exercise.

(IF4)

!

Three Inspection findings for the Emergency Preparedness Cornerstone was determined to be WHITE based on problems associated with ERO augmentation, accountability of onsite personnel, and joint news center effectiveness during the February 2000 steam generator tube failure, and during previous drills and exercises.

This resulted in a degraded cornerstone. (IF5, IF6, IF7). This degraded cornerstone was cleared following a remedial emergency preparedness exercise and 95002 supplemental inspection conducted in June 2001.

Indian Point Inspection / Activity Plan 12/30/2001 - 03/31/2003 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 1 of 3 02/28/2002 12:07:54 Report 22

ASSESS

- REVIEW ENTERGY SELF ASSESSMENTS Other Routine 01/28/2002 02/01/2002 Identification and Resolution of Problems IP 71152

3 7111117B

- MODS Baseline Inspections 02/11/2002 02/15/2002 Evaluation of Changes, Tests, or Experiments IP 7111102

Baseline Inspections 02/11/2002 02/15/2002 Permanent Plant Modifications IP 7111117B

1 71121

- OCC RAD SAFETY Baseline Inspections 02/25/2002 03/01/2002 Access Control to Radiologically Significant Areas IP 7112101

Baseline Inspections 02/25/2002 03/01/2002 ALARA Planning and Controls IP 7112102

Baseline Inspections 02/25/2002 03/01/2002 Radiation Monitoring Instrumentation IP 7112103

Baseline Inspections 02/25/2002 03/01/2002 Performance Indicator Verification IP 71151

1 7111111B

- REQUESTED PLNT. OPERATIONAL EVAL.

Baseline Inspections 02/21/2002 02/21/2002 Licensed Operator Requalification IP 7111111B

4 95002

- REVIEW CA FOR RO/SRO REQUAL FAILURES Supplemental Program 03/21/2002 03/22/2002 Inspection For One Degraded Cornerstone Or Any Three White Inputs In A Strategic Performance Area IP 95002

Supplemental Program 04/08/2002 04/12/2002 Inspection For One Degraded Cornerstone Or Any Three White Inputs In A Strategic Performance Area IP 95002

Other Routine 04/08/2002 04/18/2002 Training And Qualification Effectiveness IP 41500

Supplemental Program 04/15/2002 04/18/2002 Inspection For One Degraded Cornerstone Or Any Three White Inputs In A Strategic Performance Area IP 95002

Supplemental Program 04/25/2002 04/26/2002 Inspection For One Degraded Cornerstone Or Any Three White Inputs In A Strategic Performance Area IP 95002

1 7111107B

- HEAT SINK Baseline Inspections 04/15/2002 04/19/2002 Heat Sink Performance IP 7111107B

1 71121

- OCC RAD SAFETY Baseline Inspections 04/29/2002 05/03/2002 Access Control to Radiologically Significant Areas IP 7112101

Baseline Inspections 04/29/2002 05/03/2002 ALARA Planning and Controls IP 7112102

Baseline Inspections 04/29/2002 05/03/2002 Radiation Monitoring Instrumentation IP 7112103

Baseline Inspections 04/29/2002 05/03/2002 Performance Indicator Verification IP 71151

1 71130

- SECURITY Baseline Inspections 05/20/2002 05/24/2002 Access Authorization Program (Behavior Observation Only)

IP 7113001

Baseline Inspections 05/20/2002 05/24/2002 Access Control (Search of Personnel, Packages, and Vehicles: Identification and Authorization)

IP 7113002

5 71152B

- AUGMENTED PI&R, ENGR, HUMAN PERFORMANCE Other Routine 06/24/2002 06/28/2002 Identification and Resolution of Problems IP 71152

Supplemental Program 06/24/2002 06/28/2002 Inspection For One Degraded Cornerstone Or Any Three White Inputs In A Strategic Performance Area IP 95002

Other Routine 07/08/2002 07/12/2002 Identification and Resolution of Problems IP 71152

Supplemental Program 07/08/2002 07/12/2002 Inspection For One Degraded Cornerstone Or Any Three White Inputs In A Strategic Performance Area IP 95002

This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Indian Point Inspection / Activity Plan 12/30/2001 - 03/31/2003 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 2 of 3 02/28/2002 12:07:54 Report 22

7112203

- PUB RAD SAFETY - REMP Baseline Inspections 07/08/2002 07/12/2002 Radiological Environmental Monitoring Program IP 7112203

1 71121

- OCC RAD SAFETY Baseline Inspections 07/29/2002 08/02/2002 Access Control to Radiologically Significant Areas IP 7112101

Baseline Inspections 07/29/2002 08/02/2002 ALARA Planning and Controls IP 7112102

Baseline Inspections 07/29/2002 08/02/2002 Radiation Monitoring Instrumentation IP 7112103

Baseline Inspections 07/29/2002 08/02/2002 Performance Indicator Verification IP 71151

2 71130

- SECURITY-RESPONSE ATT3 Baseline Inspections 08/19/2002 08/23/2002 Response to Contingency Events (Protective Strategy and Implementation of Protective Strategy)

IP 7113003

2 7111111B

- U2 L.O.REQUALIFICATION PROGRAM Baseline Inspections 09/16/2002 09/20/2002 Licensed Operator Requalification IP 7111111B

4 7111401

- EP EXERCISE & EP PI VERIFICATION Baseline Inspections 09/23/2002 09/27/2002 Exercise Evaluation IP 7111401

Baseline Inspections 09/23/2002 09/27/2002 Performance Indicator Verification IP 71151

2 7111108

- INSERVICE INSPECTION Safety Issues 11/04/2002 11/08/2002 Circumferential Cracking of Reactor Pressure Vessel Head Penetration Nozzles (NRC Bulletin 2001-01)

IP 2515/145

Baseline Inspections 11/04/2002 11/08/2002 Inservice Inspection Activities IP 7111108

1 71151

- PUB RAD SAFETY PI VERIFICATION Baseline Inspections 11/04/2002 11/08/2002 Performance Indicator Verification IP 71151

1 71121

- OCC RAD SAFETY Baseline Inspections 11/11/2002 11/15/2002 Access Control to Radiologically Significant Areas IP 7112101

Baseline Inspections 11/11/2002 11/15/2002 ALARA Planning and Controls IP 7112102

Baseline Inspections 11/11/2002 11/15/2002 Radiation Monitoring Instrumentation IP 7112103

Baseline Inspections 11/11/2002 11/15/2002 Performance Indicator Verification IP 71151

4 71152B

- PROBLEM IDENTIFICATION AND RESOLUTION Baseline Inspections 12/09/2002 12/20/2002 Identification and Resolution of Problems IP 71152B

1 SUPPLEME - SUPPLEMENTAL INSPECTION (IF NECESSARY)

Supplemental Program 12/09/2002 12/20/2002 Inspection For One Degraded Cornerstone Or Any Three White Inputs In A Strategic Performance Area IP 95002

1 7112201

- PUB RAD SAFETY - RETS Baseline Inspections 01/13/2003 01/17/2003 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems IP 7112201

1 71121

- OCC RAD SAFETY Baseline Inspections 02/03/2003 02/07/2003 Access Control to Radiologically Significant Areas IP 7112101

Baseline Inspections 02/03/2003 02/07/2003 ALARA Planning and Controls IP 7112102

Baseline Inspections 02/03/2003 02/07/2003 Radiation Monitoring Instrumentation IP 7112103

This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Indian Point Inspection / Activity Plan 12/30/2001 - 03/31/2003 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 3 of 3 02/28/2002 12:07:54 Report 22 Baseline Inspections 02/03/2003 02/07/2003 Performance Indicator Verification IP 71151

5 7111121

- SSDI Baseline Inspections 02/10/2003 02/14/2003 Safety System Design and Performance Capability IP 7111121

Baseline Inspections 02/24/2003 02/28/2003 Safety System Design and Performance Capability IP 7111121

4 3/10+EXM

- U2 OPERATOR LICENSING INITIAL EXAMS Not Applicable 02/09/2003 02/13/2003 INDIAN POINT 2 INITIAL EXAM ( 3/10/03)

U01495

Not Applicable 03/10/2003 03/21/2003 INDIAN POINT 2 INITIAL EXAM ( 3/10/03)

U01495

This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.