IR 05000247/2009001
| ML090620503 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/04/2009 |
| From: | Collins S Region 1 Administrator |
| To: | Joseph E Pollock Entergy Nuclear Operations |
| collins s | |
| Shared Package | |
| ML090620501 | List: |
| References | |
| IR-09-001 | |
| Download: ML090620503 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PA 19406-1415 March 4, 2009 Mr. Joseph Site Vice President Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB Buchanan, NY 10511-0249 SUBJECT: ANNUAL ASSESSMENT LETTER
- INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 (R EPORTS 05000247/2009001 & 05000286/2009 001)
Dear Mr. Pollock:
On February 1 0 , 2009 , the NRC staff completed its performance reviews of Indian Point Nuclear Generating Units 2 and 3. Our technical staff revie wed p erformance indicators for the most recent quarter and inspection results from Jan uary 1 through December 31, 2008. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspect ions at your facility.
This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "
Official Use Only
- Security Information
" will include the security cornerston e review and result ant inspection plan.
Overall, Indian Point Nuclear Generating Unit s 2 and 3 operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance at Unit 2 and 3 for the most recent quarter, as well as f or the first three quarters of the assessment cycle, was within the Licensee Response column of the NRC's Action Matrix based on all inspection findings being classified as having very low safety significance (Green) and all performance indicator s indicati ng performance at a level requiring no additional NRC oversight (Green).
Therefore, we plan to conduct Reactor Oversight Process (ROP) baseline inspections at your facility. In our mid-cycle performance review letter dated September 2 , 2008 [ML082470316]1 , we advised you of continuing a substantive cross-cutting issue in the area of human performance related to procedure adequacy (H.2(c))2 at Unit s 2 and 3. At that time, we concluded that the criteria for clearing the cross-cutting issue, as initially established in the March 2, 2007
, annual assessment letter
[ML070610603
] were not satisfied. Specifically, during the 2008 mid-cycle performance review, we concluded that the scope and definition of some actions were still being formulated by Entergy and other actions were in the initial stages of implementation.
1 Designation in parentheses refers to an ADAMS ascension number. Documents referenced in this letter are publicly available using the ascension number in ADAMS
. 2 This is a descriptor which correlates to the cross cutting as pect in Inspection Manual Chapter 0305, "Operating Reactor Assessment Program"
. Additionally, you were evaluating and developing insights and actions from a recently completed safety culture a ssessment conducte d at Indian Point in August 2008 that would help confirm your co rrective actions. During the last six months of the performance assessment cycle, t he NRC staff reviewed your corrective action plans and p rogress in implement ing your actions as part of Problem Identification and Resolution focused inspection samples c onducted in October 2008
[ML083300034
] and December 2008 [Ref. ML090370084]. During the October 2008 inspection, t he staff also reviewed the results of your safety culture assessment and your consideration of the results in developing and affirming your c orrective actions.
Based on the results of the se inspections and a decreasing trend in the number of findings at your Indian Point Units 2 and 3 related to procedure adequacy, the NRC has concluded that you have satisf ied the criteria for clearing this su bstantive cross-cutting issue.
Specifically, Entergy has demonstrated sustainable performance improvement as evidenced by effective implementation of your corrective action plans that result ed in no safety significant inspection findings and a notable red uction in the overall number of inspection findings with the causal factor of procedure adequacy. In accordance with NRC inspection manual chapter 0305 "Operating Reactor Assessment Program,"
we will continue to monitor your performance in this area throu gh the ROP baseline inspection program.
In our 2008 mid-cycle performance review, we also advised you of continuing the substantive cross-cutting issue in the area of problem identification and resolution related to implementation of corrective actions (P.1(d)) at Unit 2. At that time, we concluded the exit criteria for clearing the cross-cutting issue, as initially established in the March 3 , 200 8, annual assessment letter
[ML080610015]
were not satisfied. Specifically, during the 2008 mid-cycle perfor mance review, we concluded that key corrective actions were either in the early stages of implementation or remained to be completed , and as a result , the exit criteria related to the effectiveness of your actions had yet to be demonstrated.
During the la st six months of the performance assessment cycle, t he NRC staff reviewed your corrective action plans and progress in implement ing your actions as part of a Problem Identification and Resolution focused inspection sample conducted in December 2008
[ML090340463]. Based on the results of this inspection and the results of other baseline inspections, and no findings identified during the assessment period related to corrective action effectiveness, we have concluded that you s atisfi ed the criteria for cleari ng this substantive cross-cutting issue.
Specifically, Entergy has demonstrated sustainable performance improvement as evidenced by effective implementation of an appropriate corrective action plan that has resulted in no safety significant inspection fin dings and no inspection findings during the assessment period with the causal factor of implementation of corrective actions. In accordance with NRC inspection manual chapter 0305 "Operating Reactor Assessment Program," we will continue to monitor your pe rformance in this area through the ROP baseline inspection program.
During this 2008 annual review period , the NRC staff identified there were four green inspection findings at Indian Point Unit 3 for the current 12-month assessment period with documente d cross-cutting aspects in the area of human performance, and there is a cross-cutting theme in the aspect of human error prevention techniques (H.4(a)) associated with these findings. In evaluating Entergy's scope of efforts and progress in addressing th e cross-cut ting theme, the NRC determined that Entergy appropriately identified the cross-cutting them e and the scope of the issues at your Indian Point Unit 3. Additionally, Entergy scheduled and initiated a ctions t hat appear appropriate to address the c ross-cutting theme. Therefore, the NRC does not have concerns with the scope of your efforts or progress, and has concluded that a substantive cross-cutting issue in human performance related to human error prevention techniques does not exist at this tim e. W e will continue to monitor your performance in this area through the ROP baseline inspection program.
During this 2008 annual review period, the NRC staff performed augmented inspections of your
activities related to the replacement Alert and Notific ation System (ANS) in accordance with the Deviation Memorandum in effect for calendar year 2008 [ADAMS Ref. ML073480290]. The Federal Emergency Management Agency (FEMA) provided provisional approval of the
replacement ANS on August 22, 2008, and Entergy p laced the system in service on August 27, 2008. The NRC staff completed an inspection of your activities related to the replacement ANS in December 2008, and issued the results in an inspection report dated January 27, 2009
[ML090280267]. Based on the st atus of your actions regarding the replacement ANS, the NRC staff concluded that enhanced inspections and oversight of your activities related to the replacement ANS is no longer warranted. We will continue to monitor your activities required in
order to receive final approval of the replacement ANS from FEMA in 2009. Additionally, we plan to monitor implementation of your corrective actions to address the causes of your untimely replacement of the ANS through a focused problem identification and resoluti on baseline inspection.
In addition to the baseline inspection program, we plan to conduct independent spent fuel storage installation inspections at Unit 2. The NRC will also continue enhanced oversight of En tergy's actions to address issues associated with on-site groundwater contamination characterization and mitigation. We expect to continue enhanced oversight until you have completed actions associated with on-site groundwater contamination as described i n the renewed ROP Deviation Memorandum, approved on December 1 8 , 200 8 [ML083590057
]. The enclosed inspection plan details the baseline and deviation memorandum inspections, less those related to physical protection, scheduled through June 30, 2010. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine inspections by resident inspectors are not
listed due to their ongoing and continuous nature. The inspections in the last nine months of the inspection plan are tentative and may be revised at the mid-cycle safety performance review.
In accordance with 10 CFR 2.390 of the NRC
=s A Rules of Practice,@ a copy of this l etter and its enclosure will be made 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/reading-rm/adams.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 Mel Gray at 610-337-5209 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/ Original Signed By:
Samuel J. Collins Regional Administrator Region I Docket Nos. 50-247 and 50-286 License No. DPR-26 and DPR-64 Enclosures:
Indian Point Nuclear Generating Unit 2 and Unit 3 Inspection/Activity Plans cc w/encl: Senior Vice President, Entergy Nuclear Operations Vice President, Operations, Entergy Nuclear Operations Vice President , Oversight, Entergy Nuclear Operations Senior Manager, Nuclear Safety and Licensing, Entergy Nuclear Operations Senior Vice President and CCO, Entergy Nuclear Operations Assistant General Counsel, Entergy Nuclear Operations Manager, Licensing, Entergy Nuc lear Operations P. Tonko, President and CEO, New York State Energy Research and Development Authority C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law D. O'Neill, Mayor, Village of Buchanan J. G. Testa, Mayor, City of Peekskill R. Albanese, Four County Coordinator S. Lousteau, Treasury Department, Entergy Services, Inc.
Chairman, Standing Committee on Energy, NYS Assembly Chairman, Standing Committee on Environmental Conservation, NYS Assembly Chairman, Committee on Corporations , Authorities, and Commissions M. Slobodien, Director, Emergency Planning P. Eddy, NYS Department of Public Service Assemblywoman Sandra Galef, NYS Assembly T. Seckerson, County Clerk, Westchester County Board of Legislators A. Spano, Westchester County E xecutive R. Bondi, Putnam County Executive C. Vanderhoef, Rockland County Executive E. A. Diana, Orange County Executive T. Judson, Central NY Citizens Awareness Network M. Elie, Citizens Awareness Network D. Lochbaum, Nuclear Safety Engineer, Union of Con cerned Scientists Public Citizen's Critical Mass Energy Project M. Mariotte, Nuclear Information & Resources Service F. Zalcman, Pace Law School, Energy Project L. Puglisi, Supervisor, Town of Cortlandt Congressman John Hall Congresswoman Nita Lowey Senat or Hillary Rodham Clinton Senator Charles Schumer G. Shapiro, Senator Clinton's Staff J. Riccio, Greenpeace P. Musegaas, Riverkeeper, Inc.
M. Kaplowitz, Chairman of County Environment & Health Committee A. Reynolds, Environmental Advocates D. Katz, Executi ve Director, Citizens Awareness Network S. Tanzer, The Nuclear Control Institute K. Coplan, Pace Environmental Litigation Clinic M. Jacobs, IPSEC W. Little, Associate Attorney, NYSDEC M. J. Greene, Clearwater, Inc.
R. Christman, Manager Training and Develo pment J. Spath, New York State Energy Research, SLO Designee A. J. Kremer, New York Affordable Reliable Electricity Alliance (NY AREA)
Institute of Nuclear Power Operations (INPO) concerns with the scope of your efforts or progress, and has concluded tha t a substantive cross-cutting issue in human performance related to human error prevention techniques does not exist at this time. W e will continue to monitor your performance in this area through the baseline inspection program.
During this 2008 annual review period, the NRC staff performed augmented inspections of your activities related to the replacement Alert and Notification System (ANS) in accordance with the Deviation Memorandum in effect for calendar year 2008 [ML073480290]. The Federal
Emergenc y Management Agency (FEMA) provided provisional approval of the replacement ANS on August 22, 2008, and Entergy placed the system in service on August 27, 2008. The NRC staff completed an inspection of your activities related to the replacement ANS in
Dec ember 2008, and issued the results in an inspection report dated January 27, 2009
[ML090280267]. Based on the status of your actions regarding the replacement ANS, the NRC staff concluded that enhanced inspections and oversight of your activities related to the replacement ANS is no longer warranted. We will continue to monitor your activities required in order to receive final approval of the replacement ANS from FEMA in 2009. Additionally, we
plan to monitor implementation of your corrective actions to address the causes of your untimely replacement of the ANS through a focused problem identification and resolution baseline inspection.
In addition to the baseline inspection program, we plan to conduct indepe ndent spent fuel storage installation inspections at Unit 2. The NRC will also continue enhanced oversight of Entergy's actions to address issues associated with on-site groundwater contamination characterization and mitigation. We expect to continue enh anced oversight until you have completed actions associated with on-site groundwater contamination as described in the renewed ROP Deviation Memorandum, approved on December 1 8 , 200 8 [ML083590057
]. The enclosed inspection plan detail s the baseline and deviation memorandum inspections, less those related to physical protection, scheduled through June 30, 2010. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues
well in advance of inspector arrival onsite. Routine inspections by resident inspectors are not listed due to their ongoing and continuous nature. The inspections in the last nine months of the inspection plan are tentative and may be revised at the mid-cycl e safety performance review.
In accordance with 10 CFR 2.390 of the NRC
=s A Rules of Practice,@ a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Availa ble Records (PARS) component of 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).
If circ umstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mel Gray at 610-337-5209 with any questions you may have regarding this letter or the inspection plan.
Sincerely
, /RA/ Original Signed By:
Samuel J. Collins Regional Administrator Region I Distribution
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Package No. ML090620501 Document No. ML090620503 SUNSI Review Complete:
AAR (Re viewer=s Initials
) DOCUMENT NAME:
S:\ROP-9 EOC Review
\Branch 2\IPEC 2009 Annual Assessment Letter Final R1.doc After declaring this document A 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 RI/DRP RI/DRP RI/DRP ORA NAME BBickett/ BB MGray/MG DLew/DL SCollins/SJC DATE 02/24/09 02/24/09 02/ 26/09 02/27/09 O FFICIAL RECORD COPY Distribution w/encl: S. Collins, RA M. Dapas, DRA S. Campbell , RI OEDO J. Lubinski, NRR M. Kowal, NRR J. Boska, PM, NRR M. Gray , DRP B. Bickett, DRP G. Malone, DRP, IP2 C. Hott, DRP, IP2 P. Cataldo, IP3 A. Koonce, IP3 Region I Docket Room (w/concurrences)
ROPreports@nrc.gov RidsNrrDirslpab@nrc.gov Director, DRS DRS Branch Chiefs D. Screnci, PAO N. Sheehan, PAO R. Barkley, ORA D. Holod y, ORA R. Franovich , NRR Inspection / Activity Plan Page 1 of 2 03/03/2009 09:35:25 Report 22 01/01/2009-06/30/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Indian Point 71121-OCC RAD SAFETY 1 2 IP Access Control to Radiologically Significant Areas 7112101 03/23/2009 03/27/2009 2 IP ALARA Planning and Controls 7112102 03/23/2009 03/27/2009 7111107T-HEAT SINK INSP 1 2 IP Heat Sink Performance 7111107T 05/11/2009 05/15/2009 71122.02-PUB RAD SAFETY - RADWASTE 1 2 IP Radioactive Material Processing and Transportation 7112202 06/22/2009 06/26/2009 7111121-CDBI 8 2 IP Component Design Bases Inspection 7111121 07/20/2009 07/24/2009 2 IP Component Design Bases Inspection 7111121 08/03/2009 08/07/2009 2 IP Component Design Bases Inspection 7111121 08/10/2009 08/14/2009 DEV MEMO-GROUND WATER DEVIATION MEMO 3 2 IP Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 7112203 08/17/2009 08/21/2009 7112201-PUB RAD SAFETY - RETS 1 2 IP Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 7112201 08/31/2009 09/04/2009 ISFSI-ISFSI LOADING CAMPAIGN INSPECTION 2 2 IP Operation Of An ISFSI 60855 09/01/2009 12/31/2009 71121-OCC RAD SAFETY 1 2 IP Access Control to Radiologically Significant Areas 7112101 09/28/2009 10/02/2009 2 IP ALARA - Required 7112102-7112102R 09/28/2009 10/02/2009 2 IP Performance Indicator Verification 71151 09/28/2009 10/02/2009 EP PROGR-EP PROGRAM INSPECTION 2 2 IP Alert and Notification System Testing 7111402 11/02/2009 11/06/2009 2 IP Emergency Response Organization Augmentation Testing 7111403 11/02/2009 11/06/2009 2 IP Emergency Action Level and Emergency Plan Changes 7111404 11/02/2009 11/06/2009 2 IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 11/02/2009 11/06/2009 2 IP Drill/Exercise Performance 71151-EP01 11/02/2009 11/06/2009 2 IP ERO Drill Participation 71151-EP02 11/02/2009 11/06/2009 2 IP Alert & Notification System 71151-EP03 11/02/2009 11/06/2009 TRI FIRE-TRIENNIAL FIRE PROTECTION INSPECTION 3 2 IP Fire Protection [Triennial]
7111105T 01/25/2010 01/29/2010 2 IP Fire Protection [Triennial]
7111105T 02/08/2010 02/12/2010 7/12EXAM-U2 INITIAL OPERATOR LICENSING EXAM 5 2 FY10 - INDIAN POINT U2 INITIAL OPERATOR LICENSING EXAM U01787 06/14/2010 06/18/2010 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Inspection / Activity Plan Page 2 of 2 03/03/2009 09:35:25 Report 22 01/01/2009-06/30/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Indian Point 7111108P-IP2 INSERVICE INSPECTION 1 2 IP Inservice Inspection Activities - PWR 7111108P 03/15/2010 03/26/2010 71121.01-UNIT 2 OUTAGE HP INSPECTION 1 2 IP Access Control to Radiologically Significant Areas 7112101 03/22/2010 03/26/2010 2 IP ALARA - Required 7112102-7112102R 03/22/2010 03/26/2010 71152B-PI&R 4 2 IP Identification and Resolution of Problems 71152B 05/03/2010 05/07/2010 2 IP Identification and Resolution of Problems 71152B 05/17/2010 05/21/2010 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Inspection / Activity Plan Page 1 of 2 03/03/2009 09:36:32 Report 22 01/01/2009-06/30/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Indian Point 3 TI-172-U3 TI-172 RCS DISSIMILAR METAL WELDS 1 3 IP Reactor Coolant System Dissimiliar Metal Butt Welds 2515/172 03/16/2009 03/20/2009 7111108P-U3 INSERVICE INSPECTION 1 3 IP Inservice Inspection Activities - PWR 7111108P 03/16/2009 03/27/2009 71121-OCC RAD SAFETY 1 3 IP Access Control to Radiologically Significant Areas 7112101 03/23/2009 03/27/2009 3 IP ALARA Planning and Controls 7112102 03/23/2009 03/27/2009 7111107T-HEAT SINK INSP 2 3 IP Heat Sink Performance 7111107T 05/11/2009 05/15/2009 71152B-PI&R BIENNIAL TEAM 4 3 IP Identification and Resolution of Problems 71152B 05/18/2009 05/22/2009 3 IP Identification and Resolution of Problems 71152B 06/08/2009 06/12/2009 71122.02-PUB RAD SAFETY - RADWASTE 1 3 IP Radioactive Material Processing and Transportation 7112202 06/22/2009 06/26/2009 7111111B-BIENNIAL REQUAL INSP - U3 3 3 IP Licensed Operator Requalification Program 7111111B 09/21/2009 09/25/2009 DEV MEMO-GROUND WATER DEVIATION MEMO 3 3 IP Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 7112203 08/17/2009 08/21/2009 7112201-PUB RAD SAFETY - RETS 1 3 IP Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 7112201 08/31/2009 09/04/2009 71121-OCC RAD SAFETY 1 3 IP Access Control to Radiologically Significant Areas 7112101 09/28/2009 10/02/2009 3 IP ALARA - Required 7112102-7112102R 09/28/2009 10/02/2009 3 IP Performance Indicator Verification 71151 09/28/2009 10/02/2009 MODS-PERMANENT PLANT MODIFICATIONS 3 3 IP Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications 7111117T 10/19/2009 10/23/2009 3 IP Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications 7111117T 11/02/2009 11/06/2009 EP PROGR-EP PROGRAM INSPECTION 2 3 IP Alert and Notification System Testing 7111402 11/02/2009 11/06/2009 3 IP Emergency Response Organization Augmentation Testing 7111403 11/02/2009 11/06/2009 3 IP Emergency Action Level and Emergency Plan Changes 7111404 11/02/2009 11/06/2009 3 IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 11/02/2009 11/06/2009 3 IP Drill/Exercise Performance 71151-EP01 11/02/2009 11/06/2009 3 IP ERO Drill Participation 71151-EP02 11/02/2009 11/06/2009 3 IP Alert & Notification System 71151-EP03 11/02/2009 11/06/2009 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Inspection / Activity Plan Page 2 of 2 03/03/2009 09:36:32 Report 22 01/01/2009-06/30/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Indian Point 3 71121.01-HP OUTAGE INSPECTION 1 3 IP Access Control to Radiologically Significant Areas 7112101 03/22/2010 03/26/2010 3 IP ALARA - Required 7112102-7112102R 03/22/2010 03/26/2010 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.