IR 05000247/2007004

Download: ML073170147

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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406 November 9, 2007

Mr. Fred Site Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000286/2007004

Dear Mr. Dacimo:

On September 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Indian Point Nuclear Generating Unit 3. The enclosed integrated inspection report documents the inspection results, which were discussed on October 3, 2007, with Mr. Anthony Vitale 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 NRC-identified inspection finding of very low safety significance (Green). The finding was also a violation of NRC requirements. However, because of the very low safety significance, and because it was entered into your corrective action program, the NRC is treating the finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest this 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, D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Senior Resident Inspector at Indian Point Nuclear Generating Unit 3.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of 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,/RA/ Eugene W. Cobey, Chief Projects Branch 2 Division of Reactor Projects Docket No. 50-286 License No. DPR-64

Enclosure:

Inspection Report No. 05000286/2007004

w/Attachment:

Supplemental Information

cc w/encl: J. Wayne Leonard, Chairman and CEO, Entergy Nuclear Operations, Inc.

G. J. Taylor, Chief Executive Officer, Entergy Operations M. Kansler, President, Entergy Nuclear Operations, Inc.

J. T. Herron, Senior Vice President for Operations M. Balduzzi, Senior Vice President and COO, Northeastern Regional Operations Senior Vice President of Engineering and Technical Services J. DeRoy, Vice President, Operations Support (ENO)

A. Vitale, General Manager, Plant Operations O. Limpias, Vice President, Engineering (ENO)

J. McCann, Director, Nuclear Safety and Licensing (ENO)

E. Harkness, Director of Oversight (ENO)

P. Conroy, Director, Nuclear Safety Assurance J. Lynch, Manager, Licensing (ENO)

P. Tanko, 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. Smith, President, NYS Energy, Research, and Development Authority 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 Executive R. Bondi, Putnam County Executive

SUMMARY OF FINDINGS

.........................................................................................................iii

REPORT DETAILS

.....................................................................................................................1

REACTOR SAFETY

...................................................................................................................1 1R01 Adverse Weather Protection...................................................................................1

1R04 Equipment Alignment.............................................................................................

.1

1R05 Fire Protection........................................................................................................

.2

1R07 Heat Sink Performance..........................................................................................

.3

1R11 Licensed Operator Requalification Inspection........................................................

.4

1R12 Maintenance Effectiveness.....................................................................................

.4 1R13 Maintenance Risk Assessment and Emergent Work Control..................................7 1R15 Operability Evaluations............................................................................................7 1R19 Post-Maintenance Testing.......................................................................................8 1R22 Surveillance Testing................................................................................................8

1R23 Temporary Plant Modifications...............................................................................

.9 1EP2 Alert and Notification System Evaluation.................................................................9 1EP6 Drill Evaluation......................................................................................................10

RADIATION SAFETY

...............................................................................................................11 2OS1 Access Control to Radiologically Significant Areas................................................11 2OS2 ALARA Planning and Controls..............................................................................12

OTHER ACTIVITIES (OA)

........................................................................................................13

4OA6 Meetings, including Exit.........................................................................................16

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

..................................................................................................A-1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

......................................................A-1

LIST OF DOCUMENTS REVIEWED

......................................................................................A-2

LIST OF ACRONYMS

............................................................................................................A-8

iiiSUMMARY

OF [[]]

FINDINGS IR 05000286/2007-004; 07/01/2007 - 09/30/2007, Indian Point Nuclear Generating Unit 3;

Maintenance Effectiveness.

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

One Green finding was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance

Determination Process." Findings for which the significance determination process (SDP) does

not apply may be Green or be assigned a severity level after NRC management review. The

NRC's program for overseeing the safe operation of commercial nuclear power reactors is

described in

NUR [[]]

EG -1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. [[]]

NRC Identified and Self-Revealing Findings Cornerstone: Mitigating Systems Green. The inspectors identified a non-cited violation (NCV) of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power

Plants," because Entergy did not monitor the performance or condition of the

emergency lighting system against licensee-established goals, in a manner sufficient to

provide reasonable assurance that the system was capable of fulfilling its intended

function. Specifically, in January 2007, Entergy returned the emergency lighting system

to a 10 CFR 50.65(a)(2) status without taking appropriate corrective action when

established goals were not met in accordance with its action plan. Entergy entered this

issue into their corrective action program, and is performing a 10 CFR 50.65(a)(1)

evaluation for the emergency lighting system. Entergy also plans to review system

performance over the last two years to ensure previous functionality determinations

have appropriate engineering bases.

The inspectors determined that this finding was more than minor because it was similar

to Example 7.a in Inspection Manual Chapter (IMC) 0612, Appendix E, "Examples of

Minor Issues." Specifically, Entergy failed to take appropriate corrective action when

established goals were not met in accordance with its Maintenance Rule (a)(1) action

plan for the emergency lighting system. The inspectors evaluated the significance of

this finding using Phase 1 of IMC 0609, Appendix F, "Fire Protection Significance

Determination Process." The inspectors determined that this finding was of very low

safety significance because the degradation of safe shutdown functions was low, since

the majority of emergency lights were available to support safe-shutdown operator

actions in the event of a fire and loss of normal lighting. In addition, backup portable

emergency lights and flashlights were available to operators. The inspectors

determined this finding had a cross-cutting aspect in the area of human performance

because Entergy did not use conservative assumptions when determining the

functionality of degraded emergency lights and whether identified emergency light

functional failures were maintenance preventable. (H.1(b)) (Section 1R12)

ivB. Licensee-Identified Violations None.

REPORT [[]]

DETAILS Summary of Plant Status Indian Point Nuclear Generating Unit 3 began the inspection period at full power and remained

at or near full power for the entire inspection period.

1.

REACTO R

SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01 - 1 sample) a. Inspection Scope The inspectors reviewed Entergy's adverse weather procedures, operating experience, corrective action program, Updated Final Safety Analysis Report (UFSAR), Technical Specifications, operating procedures, and applicable plant documents to determine the types of adverse weather challenges to which the site is susceptible. The inspectors performed plant walkdowns and reviews to verify that plant features and procedures for operation and continued availability of the ultimate heat sink during adverse weather were appropriate including equipment availability for performance of the reactor shutdown function under the weather conditions assumed prior to shutdown. The documents reviewed during this inspection are listed in the Attachment. The auxiliary feedwater system, offsite power system, and emergency diesel generators are risk-significant systems that are required to be protected from adverse weather conditions and were selected for inspection. Collectively, this inspection represented one inspection sample of risk-significant systems.

b. Findings No findings of significance were identified.

1R04 Equipment Alignment

.1 Partial Walkdown (71111.04Q - 5 samples)

a. Inspection Scope The inspectors performed five partial system walkdowns to verify the operability of

redundant or diverse trains and components during periods of system train unavailability

or following periods of maintenance. The inspectors referenced the system procedures,

the

UFS [[]]

AR, and system drawings to verify that the alignment of the available train

2supported its required safety functions. The inspectors also reviewed applicable condition reports and work orders to ensure that Entergy had identified and properly

addressed equipment discrepancies that could potentially impair the capability of the

available train, as required by Title 10 of the Code of Federal Regulations (CFR) Part 50,

Appendix B, Criterion XVI, "Corrective Action." The documents reviewed during these

inspections are listed in the Attachment. The inspectors performed the following partial

walkdowns: * 31 and 33 emergency diesel generators (EDGs) during 32 EDG maintenance activities; * 31 charging pump during 32 charging pump maintenance activities;

• 33 residual heat removal pump following testing activities;

• 33 EDG following testing activities; and

• Mini-containment system for residual heat removal valve 885A. b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05Q - 10 samples)

a. Inspection Scope The inspectors conducted a tour of several fire areas to assess the material condition

and operational status of fire protection features. The inspectors verified, consistent with

applicable administrative procedures, that: combustibles and ignition sources were

adequately controlled; passive fire barriers, manual fire-fighting equipment, and

suppression and detection equipment were appropriately maintained; and compensatory

measures for out-of-service, degraded, or inoperable fire protection equipment were

implemented in accordance with Entergy's fire protection program. The inspectors

evaluated the fire protection program against the requirements of Licensee Condition

2.H. The documents reviewed are listed in the Attachment. This inspection represented

inspection samples for fire protection tours and were conducted in the following areas: * Fire Zone 9;

• Fire Zones 5, 6, 7, 8;

• Fire Zones 10, 36A, 101A, 102A;

• Fire Zones 1, 1A;

• Fire Zones 2, 2A;

• Fire Zone 58A;

• Fire Zone 23;

• Fire Zone 52A;

• Fire Zone 57A; and

• Fire Zone 65A.

b. Findings No findings of significance were identified.

1R07 Heat Sink Performance (IP 71111.07B - 3 samples)

a. Inspection Scope Based on a plant specific risk assessment, past inspection results, recent operational

experience, and resident inspector input, the inspectors selected the following heat

exchangers (HXs) for review: "A" component cooling water heat exchanger; "B" emergency diesel generator jacket water and lube oil coolers; "B" high head safety injection pump coolers. The inspectors reviewed Entergy's inspection, maintenance, chemical control, and

performance monitoring methods and frequency for the selected components and

systems to determine whether potential deficiencies could mask degraded performance,

and to assess the capability of the HXs to perform their design functions. The inspectors

evaluated the associated Indian Point Unit 3 programs to assess whether they conformed

to Entergy's commitments to NRC Generic Letter 89-13, "Service Water System

Problems Affecting Safety-Related Equipment." In addition, the inspectors evaluated

whether any potential common cause heat sink performance problems could affect

multiple

HX s in mitigating systems or result in an initiating event. The inspectors reviewed system health reports,

HX and service water (SW) pipe

inspection records, eddy current test results, performance and surveillance test results,

as-left

HX tube plugging, and design specifications and calculations. The inspectors compared as-found

HX inspection results, and performance and surveillance test results

to established acceptance criteria to determine whether the as-found conditions were

acceptable and conformed to design basis assumptions for heat transfer capability. The

inspectors evaluated performance trends to assess whether the inspection and test

frequencies were adequate to identify degradation prior to loss of heat removal

capabilities below their design requirements. In addition, the inspectors assessed

Entergy's methods to monitor and control bio-fouling, corrosion, erosion, and silting to

verify whether Entergy's methodology and acceptance criteria, as-implemented, were

adequate.

The inspectors performed field walkdowns of the selected

HX s, portions of the

SW

system piping, selected SW valve pits, and the intake structure to independently assess

the material condition of these systems and components. In addition, the inspectors

viewed several SW buried piping inspection videos from refueling outage 3R13, reviewed

work order history, and discussed system health with the respective system engineers.

The documents reviewed during this inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

41R11 Licensed Operator Requalification Inspection (71111.11Q - 1 sample)

a. Inspection Scope On September 17, 2007, the inspectors observed a licensed-operator simulator

evaluation to verify that operator performance was adequate and that evaluators were

identifying and documenting crew performance problems. The inspectors evaluated the

performance of risk-significant operator actions, including the use of emergency

operating procedures. The inspectors assessed the clarity and effectiveness of

communications, the implementation of appropriate actions in response to alarms, the

performance of timely control board operation and manipulation, and the oversight and

direction provided by the shift manager. The inspectors also reviewed simulator fidelity

with respect to the actual plant. Licensed operator training was evaluated against the requirements of 10 CFR Part 55, "Operators' Licenses." The documents reviewed during

this inspection are listed in the Attachment.

b. Findings No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12Q - 3 samples)

a. Inspection Scope The inspectors reviewed performance-based problems associated with the structures,

systems, or components (SSCs) listed below, to assess the effectiveness of the

maintenance program:

• 34 fan cooler unit cable splice failure extent of condition;

• Emergency lighting system; and

• Service water system leaks.

The inspectors reviewed system health reports, maintenance backlogs, and Maintenance

Rule basis documents, and evaluated the maintenance program against the

requirements of 10 CFR 50.65. The documents reviewed are listed in the Attachment.

In addition, reviews focused on:

• Proper Maintenance Rule scoping in accordance with 10 CFR 50.65;

• Characterization of reliability issues;

• Changing system and component unavailability;

• 10 CFR 50.65(a)(1) and (a)(2) classifications;

• Identifying and addressing common cause failures;

• Trending of system flow and temperature values;

• Appropriateness of performance criteria for SSCs classified (a)(2); and

• Adequacy of goals and corrective actions for SSCs classified (a)(1).

b. Findings Introduction: The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power

Plants," because Entergy did not monitor the performance or condition of the emergency

lighting system against licensee-established goals in a manner sufficient to provide

reasonable assurance that the system was capable of fulfilling its intended function. Description: The emergency lighting system consists of 157 emergency lights and provides battery backup lighting during a 10 CFR 50, Appendix R fire event for access to

and egress from locations of alternate safe shutdown equipment and instruments. The

system was initially placed in 10 CFR 50.65 (a)(1) status in April 2004, when Entergy

determined that 59 maintenance preventable functional failures (MPFF) had occurred

over the previous three years, predominantly due to premature battery failures. Entergy

developed an action plan to improve performance of the system, which included

replacement of all batteries on a periodic basis not to exceed 5 years. Entergy continued

to experience premature battery failures in 2005 and attributed the majority of failures to

high temperature environments. Subsequently, Entergy developed two technical

evaluations to address premature battery failures for two models of emergency lights.

Technical evaluation TE-06-002150 addressed the use of high temperature sealed

batteries, and technical evaluation TE-06-001454 addressed the use of high temperature

charge cards. Entergy identified that the new high temperature batteries of TE-06-

2150 had a shorter life expectancy than the originally installed batteries and elected to

perform replacements of these new batteries every two years. Entergy updated the

emergency lighting action plan to switch the TE-06-002150 emergency lights to the high

temperature battery as each light reached its 5-year replacement schedule, followed by

new battery replacements every two years. No formal plan was created for installing high

temperature charge cards in the emergency lights affected by

TE -06-001454. The emergency lighting 10

CFR 50.65 (a)(1) action plan required that the emergency

lighting system be monitored for three consecutive one-month periods with no additional

MPFF s prior to returning the system to 10

CFR 50.65 (a)(2) status. In January 2007,

Entergy determined that this requirement had been met and returned the emergency

lighting system to 10 CFR 50.65 (a)(2) status.

The inspectors reviewed condition reports on the emergency lighting system that were

generated during the three-month monitoring period discussed above and determined

that the Maintenance Rule (a)(1) action plan performance goals were not met. The

inspectors identified that two

MP [[]]

FFs occurred during the months of October and

December 2006. These two functional failures involved premature failures of batteries,

because the corrective actions identified in the technical evaluations had not been

implemented. Additionally, the inspectors noted that Maintenance Rule applicability and

functionality determinations performed by licensee personnel for the condition reports did

not consistently provide complete engineering bases for functionality.

The inspectors determined that returning the emergency lighting system to 10 CFR 50.65

(a)(2) status without meeting the Maintenance Rule (a)(1) action plan performance goals

was a performance deficiency. Entergy did not meet the requirements of 10 CFR

650.65(a)(1), which specifies, in part, that when the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective

action shall be taken. The inspectors concluded that the cause of this deficiency was

within Entergy's ability to foresee and correct and should have been prevented.

Traditional enforcement does not apply because there were no actual safety

consequences or potential for impacting the NRC's regulatory function, and the finding

was not the result of any willful violation of

NRC requirements or Entergy's procedures. Analysis: The inspectors determined that this finding was more than minor because it was similar to Example 7.a in Inspection Manual Chapter (

IMC) 0612, Appendix E,

"Examples of Minor Issues." Specifically, Entergy failed to take appropriate corrective

action when established goals were not met in accordance with its Maintenance Rule

(a)(1) action plan for the emergency lighting system. The inspectors evaluated the

significance of this finding using Phase 1 of IMC 0609, Appendix F, "Fire Protection

Significance Determination Process." The inspectors determined that this finding was of

very low safety significance because the degradation of safe shutdown functions was

low, since the majority of emergency lights were available to support safe-shutdown

operator actions in the event of a fire and loss of normal lighting. In addition, backup

portable emergency lights and flashlights were available to operators. The inspectors determined that this finding had a cross-cutting aspect in the area of

human performance because Entergy did not use conservative assumptions when

determining functionality of degraded emergency lights and whether the identified

functional failures were maintenance preventable. Specifically, Entergy assumed the

degraded emergency lights were functional without a complete engineering basis, and

incorrectly determined that functional failures were not maintenance preventable.

(H.1(b))

Enforcement:

10 CFR 50.65(a)(1) requires, in part, that licensees monitor the performance or condition of

SSCs within the scope of the rule as defined by 10 CFR

50.65(b) against licensee-established goals, in a manner sufficient to provide reasonable

assurance that such SSCs are capable of fulfilling their intended functions. When the

performance or condition of a structure, system, or component does not meet

established goals, appropriate corrective action shall be taken. Contrary to the above,

during the three months prior to January 2007, Entergy failed to take appropriate

corrective action when the established goals of the Maintenance Rule (a)(1) action plan

were not met. Specifically, inspectors identified

MP [[]]

FFs in condition reports in October

2006 and December 2006 where Entergy inappropriately determined that degraded

emergency lights were functional. As a result, these functional failures were not

identified or evaluated to determine if they were maintenance preventable, and Entergy

did not take appropriate corrective action. Entergy entered this issue into the corrective

action program (CR

IP 2-2007-03543) and is performing a 10

CFR 50.65 (a)(1) evaluation

for the emergency lighting system and developing a new (a)(1) action plan to address

system performance. In addition, Entergy plans to review condition reports over the last

two years to determine if additional functional failures should have been identified and

whether functional failures that were maintenance preventable were appropriately

classified. Because this issue is of very low safety significance and is entered into the

corrective action program, this violation is being treated as an NCV consistent with

7Section

VI.A. 1 of the

NRC Enforcement Policy: (NCV 05000286/2007004-01, Failure to Monitor Emergency Lighting System in accordance with 10 CFR 50.65 (a)(1) Action

Plan). 1R13 Maintenance Risk Assessment and Emergent Work Control (71111.13 - 6 samples)

a. Inspection Scope The inspectors reviewed maintenance activities to verify that the appropriate risk

assessments were performed prior to removing equipment for work. The inspectors

verified that risk assessments were performed as required by 10 CFR 50.65(a)(4), and

were accurate and complete. For emergent work, the inspectors verified that the plant

risk was promptly reassessed and managed. The documents reviewed during this

inspection are listed in the Attachment. The following activities were reviewed: * Work order (WO)

IP 3-05-22103, auxiliary feedwater room temperature sensor calibration; *

WO IP3-06-20475, safety injection logic testing;

WO 51478748, flow control valve

FCV-1113 leakby;

• WO 51475514, reactor protection logic testing;

• WO 00122244, 32 charging pump degraded suction check valve; and

• WO 00123786, 32 auxiliary boiler feedwater pump loss of speed control.

b. Findings No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - 6 samples)

a. Inspection Scope The inspectors reviewed the adequacy of operability evaluations, the use and control of

compensatory measures when applicable, and compliance with Technical Specifications.

The reviews included verification that the operability determinations were performed in

accordance with procedure

ENN -

OP-104, "Operability Determinations." The inspectors

also assessed the technical adequacy of the evaluations to ensure consistency with the

UFS [[]]

AR and associated design basis documents. The documents reviewed during this

inspection are listed in the Attachment. The inspectors reviewed the following operability

evaluations: *

CR [[]]

IP 3-07-02789, 32 auxiliary boiler feedwater pump steam supply leakby; *

CR [[]]

IP3-07-02724, residual heat removal system gas voids;

CR [[]]

IP 3-07-03275, residual heat removal system suction valve differential pressure; *

CR [[]]

IP 3-07-03130, 33 safety injection pump degraded agastat relay; *

CR [[]]

IP3-07-03318, auxiliary feedwater suction piping seismic interaction; and

CR [[]]

IP3-07-03515, control room ventilation during damper F-2 failure.

b. Findings No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19 - 6 samples)

a. Inspection Scope The inspectors reviewed post-maintenance test procedures and associated testing

activities for selected risk-significant mitigating systems and assessed whether the effect

of maintenance on plant systems was adequately addressed by Entergy. The inspectors

verified that: test acceptance criteria were clear; tests demonstrated operational

readiness and were consistent with design basis documentation; test instrumentation had

current calibrations and appropriate range and accuracy for the application; and tests

were performed as written, with applicable prerequisites satisfied. Upon completion, the

inspectors verified that equipment was returned to the proper alignment necessary to

perform its safety function. Post-maintenance testing was evaluated against the

requirements of

10 CFR Part 50, Appendix B, Criterion

XI, "Test Control." The

documents reviewed during this inspection are listed in the Attachment. The inspectors

reviewed the following post-maintenance activities:

• WO 51477467, 32 boric acid transfer pump following maintenance;

WO 51487533, pressure control valve

PCV-1139 following maintenance;

WO [[]]

IP3-06-19882, 32 emergency diesel generator following maintenance;

WO [[]]

IP3-05-22103, 32 auxiliary boiler feedwater pump following maintenance;

• WO 00120465, 'A' steam generator water level bistable following repairs; and

• WO 51467706, 32 charging pump following suction valve repairs.

b. Findings No findings of significance were identified.

1R22 Surveillance Testing (71111.22 - 7 samples)

a. Inspection Scope The inspectors observed the performance of surveillance tests and/or reviewed test data

of selected risk-significant structures, systems and components to assess whether they

satisfied Technical Specifications,

UFS [[]]

AR, Technical Requirements Manual, and Entergy

procedure requirements. The inspectors verified that: test acceptance criteria were

clear, demonstrated operational readiness, and were consistent with design basis

documentation; test instrumentation had current calibrations and appropriate range and

accuracy for the application; and tests were performed as written, with applicable

prerequisites satisfied. Following the test, the inspectors verified that equipment was

capable of performing the required safety functions. The documents reviewed during this

inspection are listed in the Attachment. The inspectors reviewed the following

9surveillance tests (one RCS leakage rate sample, one inservice testing sample, and five other surveillance tests):

• 3-PT-M13B1, "Reactor Protection Logic Channel Functional Test," Revision 12;

• 3-PT-M14B, "Safety Injection System Logic Functional Train B," Revision 3;

• 3-PT-Q062C, "33 Charging Pump Operability Test," Revision 9;

• 0-SOP-Leakrate-001, "Reactor Coolant System (RCS) Leakrate Surveillance,

Evaluation, and Leak Identification," Revision 0;

• 3-PT-Q116C, "33 Safety Injection Pump Functional Test," Revision 12;

• 3-PT-Q97, "Steam Generator Level Analog Functional," Revision 11; and

• 3-PC-OLOIC1, Reactor Coolant Loop Narrow Range Temperature Instrument Calibration (Loop 1)," Revision 3. b. Findings No findings of significance were identified.

1R23 Temporary Plant Modifications (71111.23 - 1 sample)

a. Inspection Scope The inspectors evaluated activities associated with the leak repair conducted on the 34

main steam isolation valve in accordance with work order 00119847 on

September 13, 2007. The inspectors verified that the installation was consistent with the

modification documentation, the drawings and procedures were updated as applicable,

and the post-installation testing was adequate. The documents reviewed during this

inspection are listed in the Attachment.

b. Findings

No findings of significance were identified. Cornerstone: Emergency Preparedness (EP)

1EP 2 Alert and Notification System Evaluation (

IP 71114.02 - 1 sample)

a. Inspection Scope

A region-based specialist inspector reviewed Entergy's activities related to the existing

Indian Point alert and notification system (ANS), and reviewed the progress made in the

design and installation of a new siren system. This inspection was conducted in

accordance with the baseline inspection program deviation authorized by the NRC

Executive Director of Operations (EDO) in a memorandum dated October 31, 2005, and

renewed by the EDO in a memorandum dated December 11, 2006. The new siren system is being installed around the Indian Point Energy Center to satisfy

commitments documented in an NRC Confirmatory Order (dated January 31, 2006) that

implements the requirements outlined in the 2005 Energy Policy Act. In January 2007,

10Entergy requested an extension of the deadline for completing the ANS project as described in the Confirmatory Order. The Confirmatory Order set a January 30, 2007,

deadline for completing installation. Entergy's extension request cited several issues that

were beyond their control, as the basis for the delay. On January 23, 2007, the NRC

granted Entergy's extension request and established April 15, 2007, as the new

installation completion date. The licensee conducted a full-system demonstration test of

the new ANS on April 12, and the results of that test failed to meet the acceptance

criteria for the new system. On April 13, 2007, Entergy requested another extension

which was subsequently denied. On April 23, 2007, the NRC issued a Notice of Violation

(NOV) and civil penalty for Entergy's failure to comply with the siren operability date in

the Confirmatory Order. On May 23, 2007, Entergy responded to the NOV and

committed to August 24, 2007, as the latest date anticipated for declaring the new ANS

operable.

On August 30, the

NRC issued a

NOV to Entergy due to its failure to take timely and

necessary actions to ensure the Federal Emergency Management Agency's (FEMA)

approval for the use of the

ANS by August 24, 2007. On September 12, 2007,

FEMA

issued a letter indicating that the new ANS was not adequate in the areas of acoustics,

sound blockage from foliage, and control systems. In a letter dated September 21, 2007,

Entergy requested a meeting with

FE [[]]

MA to discuss the technical aspects of Entergy's

proposed plans and determine a mutually acceptable schedule for resolving the open

items.

The inspectors conducted the following onsite inspection activities during this quarter:

• Observed the full-volume sounding to obtain far-field acoustical data (August 9, 2007); and

• Met with Entergy representatives to discuss and obtain complete back-up battery testing results (August 13 - 14, 2007).

The inspectors also inspected the status of and corrective actions for the current ANS to

assure that Entergy was appropriately maintaining the system, including the quarterly

full-system growl test of the current ANS to demonstrate its functionality. Inspectors

were on site on September 12, 2007, to observe and verify the performance of the

current

ANS during the annually-conducted full-volume test of the current

ANS.

b. Findings No findings of significance were identified.

1EP6 Drill Evaluation (71114.06 - 1 sample)

a. Inspection Scope The inspectors observed an emergency preparedness drill conducted on

September 17, 2007. The inspectors used NRC Inspection Procedure 71114.06, "Drill

Evaluation," as guidance and criteria for evaluation of the drill. The inspectors observed

11the drill and critiques that were conducted from the participating facilities onsite, including the Indian Point Unit 2 plant simulator, and the emergency operations facility. The

inspectors focused the reviews on the identification of weaknesses and deficiencies in

classification and notification timeliness, quality, and accountability of essential personnel

during the drill. The inspectors observed Entergy's critique and compared Entergy's

self-identified issues with the observations from the inspectors' review to ensure that

performance issues were properly identified.

b. Findings No findings of significance were identified.

2.

RADIAT [[]]

ION [[]]

SAFETY Cornerstone: Occupational Radiation Safety (

OS) 2OS1 Access Control to Radiologically Significant Areas (71121.01 - 14 samples)

a. Inspection Scope During July 16 through 19, 2007, the inspectors conducted the following activities to

verify that the licensee was properly implementing physical, engineering, and

administrative controls for access to high radiation areas, and other radiologically

controlled areas, and that workers were adhering to these controls when working in these

areas. Implementation of the access control program was reviewed against the criteria

contained in 10 CFR 20, Technical Specifications, and the licensee's procedures. (1) There were no occupational exposure cornerstone performance indicator incidents during the current assessment period. (2) The inspectors walked down exposure significant work areas of the plant

(both Units 2 and 3) and reviewed licensee controls and surveys to determine if licensee surveys, postings, and barricades were acceptable and in accordance

with regulatory requirements. (3) The inspectors walked down exposure significant work areas of the plant

(both Units 2 and 3) and conducted independent surveys to determine whether prescribed radiation work permit and procedural controls were in place and

whether licensee surveys and postings were complete and accurate. (4) There were no internal dose assessments greater than 50 mrem during 2007. (5) The licensee's physical and programmatic controls for highly activated materials stored underwater in the Unit 2 and Unit 3 spent fuel pools were reviewed and

evaluated through observation and a review of the applicable access control

procedure.

2(6) A review of licensee radiation protection program self-assessments and audits during 2007 was conducted to determine if identified problems were entered into

the corrective action program for resolution. (7) Seven condition reports associated with the radiation protection access control and

ALA [[]]

RA areas between March 2007 and July 2007, were reviewed and

discussed with licensee staff to determine if the follow-up activities were being

conducted in an effective and timely manner commensurate with their safety

significance.

(8) Based on the condition reports reviewed, repetitive deficiencies were screened to determine if the licensee's self-assessment activities were identifying and

addressing these deficiencies. (9) There were no Occupational Exposure Performance Indicator incidents reported during the current assessment period. (10) Changes to the high radiation area and very high radiation area procedures since the last inspection in this area were reviewed and management of these changes

were discussed with the Radiation Protection Manager. (11) Controls associated with potential changing plant conditions to anticipate timely posting and controls of radiation hazards was discussed with a radiation

protection supervisor. (12) All accessible locked high radiation area entrances in both Units 2 and 3 were verified to be locked through challenging the locks or doors. (13) Several radiological condition reports were reviewed to evaluate if the incidents were caused by radiation worker errors and determine if there were any trends or

patterns and if the licensee's corrective actions were adequately addressing these

trends. (14) Several radiological condition reports were reviewed to evaluate if the incidents were caused by radiation protection technician errors and determine if there were

any trends or patterns and if the licensee's corrective actions were adequately

addressing these trends.

b. Findings

No findings of significance were identified.

2OS 2

ALARA Planning and Controls (71121.02 - 2 samples)

a. Inspection Scope During July 16 through 19, 2007, the inspectors conducted the following activities to

verify that the licensee was properly maintaining individual and collective radiation

13exposures as low as is reasonably achievable (ALARA). Implementation of the

ALARA program was reviewed against the criteria contained in 10

CFR 20.1101(b) and the

licensee's procedures. (1) The procedure and methodology for adjusting work activity exposure estimates was evaluated to include revisions for emergent work and unexpected radiological

conditions. The methodology for the exposure estimate adjustments was

evaluated with respect to sound radiation protection and

ALA [[]]

RA principles and to

ensure the revised exposure estimates provided an effective

ALA [[]]

RA performance

measure. (2) Based on the condition reports reviewed, repetitive deficiencies in the

ALA [[]]

RA program were screened to determine if the licensee's self-assessment activities

were identifying and addressing these deficiencies.

b. Findings No findings of significance were identified. 4.

OTHER [[]]

ACTIVITIES (OA) 4OA1 Performance Indicator Verification (71151 - 5 samples)

a. Inspection Scope The inspectors reviewed performance indicator (PI) data for the cornerstones listed

below and used Nuclear Energy Institute 99-02, "Regulatory Assessment Performance

Indicator Guideline," Revision 5, to verify individual PI accuracy and completeness. The

documents reviewed during this inspection are listed in the Attachment.

Mitigating Systems Cornerstone

• Mitigating Systems Performance Index -

RHR (October 2006 - June 2007) * Mitigating Systems Performance Index -

HPI (October 2006 - June 2007)

• Mitigating Systems Performance Index - AFW (October 2006 - June 2007)

• Mitigating Systems Performance Index - EAC (October 2006 - June 2007)

• Mitigating Systems Performance Index - CW (October 2006 - June 2007) The inspectors reviewed data and plant records from the above-noted periods, which

included

PI data summary reports (

LERs), reports, operator narrative logs, the licensee

corrective action program, and Maintenance Rule records. The inspectors verified the

accuracy of the number of critical hours reported, and interviewed the system engineers

and operators responsible for data collection and evaluation.

b. Findings

No findings of significance were identified.

144OA2 Identification and Resolution of Problems

.1 Routine Problem Identification and Resolution (PI&R) Program Review As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"

and in order to help identify repetitive equipment failures or specific human performance

issues for follow-up, the inspectors performed a daily screening of all items entered into

Entergy's corrective action program (CAP). The review was accomplished by accessing

Entergy's computerized database for condition reports (CRs) and attending CR screening

meetings. Additionally, In accordance with the baseline inspection modules, the inspectors selected

CAP items across the Initiating Events, Mitigating Systems, and Barrier Integrity

cornerstones for additional follow-up and review. The inspectors assessed Entergy's

threshold for problem identification, the adequacy of the cause analyses, extent of

condition review, and operability determinations, and the timeliness of the specified

corrective actions. The CRs reviewed are listed in the Attachment.

4OA5 Other Activity

Groundwater Contamination Investigation

a. Inspection Scope

Continued inspection of Entergy's plans, procedures, and characterization activities affecting the contaminated groundwater condition at Indian Point, relative to NRC

regulatory requirements, was authorized by the NRC Executive Director of Operations in

a Reactor Oversight Process deviation memorandum dated October 31, 2005 (ADAMS

Accession Number

ML 053010404) and renewed on December 11, 2006 (

ADAMS

Accession Number ML063480016). Accordingly, continuing oversight of licensee

progress has been conducted throughout this quarterly inspection report period, which

included: onsite review of licensee performance, progress, and achievements;

independent split sample analyses of selected monitoring wells; expanded sampling of

the edible portions of various fish collected from multiple locations in the Hudson River;

review of an onsite underground auxiliary steam pipe leak; and frequent communication

of

NRC observations with interested Federal, State, and local government stakeholders. In July and August 2007,

NRC staff and

U.S. Geological Survey (

USGS) scientists, in

consultation with representatives of New York State Department of Environmental

Conservation (DEC), conducted an independent assessment of selected data and

information developed by Entergy and its geophysical contractor relative to fracture flow

modeling, and groundwater characterization relative to flow and transport. The methodology applied by

US [[]]

GS utilized data collected from downhole geophysical

and flow logs conducted by Geophysical Applications, Inc, under the direction of the

Entergy's principal contractor for the groundwater investigations, GeoEnvironmental, Inc.

(GZA). The geophysical data (i.e., caliper, optical and acoustic televiewer, fluid resistivity

and temperature logs), fracture mapping and flow logs were processed and visualized

15with a computer-based system,

WELLC [[]]

AD. The method permitted a systematic mapping of fracture orientations, density, associated flow conditions and properties using

composite portrayals of vertical plots of the geophysical logs and hydraulic test data and

analyses. These composite portrayals facilitated comparisons and analyses of selected

IP [[]]

EC monitoring wells for the determination of the location and direction of discrete high

flow zones, including associated flux and transmissivity. It is expected that the

information and analyses will aid the

NRC and

USGS staff in evaluations of GZA's

conceptual groundwater flow and transport model that was derived from previous

hydraulic pump and tracer tests conducted on selected monitoring wells.

b. Findings and Observations No findings of significance were identified.

The fracture flow assessment provided an effective means of visualizing fracture zones

and properties of certain

IP [[]]

EC monitoring wells; and provided an enhanced

conceptualization of groundwater flow and transport characteristics which is important to

the NRC's overall assessment of the licensee's groundwater modeling and

characterization. The

NRC and

USGS will apply the knowledge gained from this

assessment for independent review of Entergy's characterization of groundwater

behavior, its selection of monitoring locations and performance indicators for long-term

site groundwater monitoring, and its determination of remediation strategies, as

appropriate. This assessment provides another tool to be used to effectively verify and

validate that Entergy's groundwater modeling and dose assessment methods continue to

assure that public health and safety, and protection of the environment is maintained. During this period, the NRC continued split sampling of selected monitoring wells for

independent analysis by the Oak Ridge Institute for Science and Education,

Environmental Site Survey and Assessment Program (ORISE/ESSAP) radioanalytical

laboratory. The NRC's assessment of the licensee's sample analytical results data

indicated that the licensee's analytical contractor reported final sample results that were

comparable with the NRC's analytical results. Fish samples were also split and independently analyzed during this period. The

samples were collected from three separate locations on the Hudson River (i.e., an area

in the near vicinity of the plant, the Roseton control location (20-30 miles, up river), and

the Catskills region (about 80 to 90 miles, up river)). The NRC analyzed edible portions

of the fish samples, commensurate with the requirements of the environmental

monitoring program and the existing pathway for exposure from liquid radiological

releases to the Hudson River. None of the 18 samples indicated any detectable

radioactivity distinguishable from background (i.e., all samples were less than the

Minimum Detectable Activity established by

ORI [[]]

SE for gamma and strontium-90

radionuclides). The

NRC 's

ORISE /ESSAP sample results are available in

ADA [[]]

MS under the following

Accession Numbers:

ML 072840255,

ML 072840278,

ML 072840292,

ML 072840312,

ML 072840323,

ML072840334, ML072840357. To date, plant-related radioactivity has

not been detected in any of the site's southern boundary wells or offsite environmental

16groundwater monitoring locations. Information collected and assessed to-date, continues to support that the estimated radiological release fraction through groundwater is

negligible relative to NRC regulatory limits.

On April 7, 2007, two separate underground steam leaks were detected emanating through the asphalt surfaces west and north of Unit 3. The affected 8" auxiliary steam

line was isolated on April 23, 2007, and subsequently excavated and replaced. As

expected, a very low tritium concentration was detected in the area, likely due to normal

tritium diffusion or deposition onsite, Condition Report No.

CR -

IP3-2007-1852 pertains.

Entergy performed a very conservative bounding evaluation of the resulting ground and

air releases that indicated approximately 1E-8 mrem/yr and 2E-6 mrem/yr due to the

liquid and air release pathways, respectively. Such releases are not considered

significant and are below reporting requirements.

4OA6 Meetings, including Exit Exit Meeting Summary On October 3, 2007, the inspectors presented the inspection results to Mr. Anthony Vitale

and other Entergy staff members, who acknowledged the inspection results presented.

Entergy did not identify any material as proprietary.

ATTACH [[]]

MENT [[:]]

SUPPLE [[]]

MENTAL [[]]

INFORM [[]]

ATION A-1ATTACHMENT

SUPPLE [[]]

MENTAL [[]]

INFORM [[]]

ATION [[]]

KEY [[]]

POINTS [[]]

OF [[]]

CONTACT Licensee Personnel

F. Dacimo, Site Vice President

A. Vitale, General Manager Plant Operations

P. Conroy, Director, Nuclear Safety Assurance

T. Orlando, Director, Engineering

J. Donnelly, Manager, Site Operations

D. Gagnon, Manager, Security

S. Verrochi, Manager, System Engineering

R. Walpole, Manager, Licensing

R. Burroni, Manager, Engineering Programs and Components

B. Sullivan, Manager, Emergency Planning

S. Davis, Superintendent, Operations Training

R. Christman, Manager, Training

R. Beckman, Manager, Maintenance

L. Lee, Supervisor, System Engineering

P. Cloughhessy, Maintenance Rule Program Coordinator

N. Azevedo, Supervisor, Code Programs

S. Joubert, Supervisor, Training

R. Drake, Supervisor, Design Engineering

LIST [[]]

OF [[]]

ITEMS [[]]

OPENED ,

CLOSED ,

AND [[]]

DISCUS [[]]

SED Opened and Closed

05000286/2007004-01

NCV Failure to Monitor Emergency Lighting System in accordance with 10

CFR 50.65(a)(1) Action Plan

A-2LIST

OF [[]]

DOCUME NTS

REVIEW [[]]

ED Section 1R01: Adverse Weather Protection Procedures

OAP-008, "Severe Weather Preparations," Revision 2

OAP-48, "Seasonal Weather Preparation," Revision 4

TSP-011, "Environmental Qualification Program Harsh Area and Service Condition," Revision 9

Calculations

IC [[]]

DE -89-6054-C-2, Revision 0

IP 3-

CALC -AFW-00418, Revision 1

IP 3-

CALC-HVAC-00408, Revision 0

Condition Reports

IP 3-2007-03080

IP 3-2007-03187 Section 1R04: Equipment Alignment Procedures 3-COL-RHR-1, "Residual Heat Removal System," Revision 25

COL -

CB-2, "Weld Channel and Containment Penetration Pressurization System," Revision 16

3-PT-R035G, "Leakage Test for

SI -

MOV-885A Valve Container (Mini-Containment)," Revision 3

3-SOP-EL-001, "Emergency Diesel Generator Electrical System," Revision 8

3-SOP-CVCS-002, "Charging Seal Water and Letdown Control," Revision 0

Drawings 9321-F-27513, Sheet Nos. 1 and 2

21-F-27353, Sheet No. 1

21-F-27503, Sheet No. 2

21-F-27363, Sheet No. 1

Section 1R05: Fire Protection Procedures

ENN -

DC -161, "Transient Combustible Program," Revision 1

SMM -

DC-901, "IPEC Fire Protection Program," Revision 2

Section 1R07: Heat Sink Performance Procedures 0-HTX-405-EDG, Revision 0, "EDG Lube Oil & Jacket Water HX Maintenance,"

3-COL-RW-2, "SW System Check-off List," Revision 42

3-PT-2Y013A, "SW Manual Isolation Valves Test," Revision 1

3-PT-Q058, "Back-Up Service Water Pump Test" Revision 15

3-SOP-CC-001B, "Component Cooling System Operation," Revision 33

A-33-SOP-RW-007, "Sodium Hypochlorite Injection System," Revision

32 HS -

HT -01, "Installation Procedure for Hydra-tight Seals," Revision 1

HTX -004-

CCW, "Component Cooling Water HX Maintenance," Revision 1

PFM -22E, "Inservice Testing Program Basis Document," Revision 1

SEP -

SW -001, "Generic Letter 89-13 Service Water Program," Revision 1

EN -

DC-147, "Indian Point Units 2 & 3 Eddy Current Program," Revision 2

0-HTX-400-GEN, "Eddy Current Inspection of Heat Exchanger Tubes," Revision 1

Design & Licensing Basis, Calculations, and Analyses 6604.003-8-SW-140, "EDG Jacket Water Tube Plugging Limit," Revision 0

6604.219-8-SW-024, "EDG Lobe Oil Cooler Tube Plugging Limit," Revision 2

DC -3-352-

SI , "Safety Injection Pump Mechanical Seal HX Replacement," Revision 0

ECN -3-352-005, "Safety Injection Pump Mechanical Seal

HX Replacement," Revision 0

EN -

NE Specification

TS -

MS -027, "SW Piping and Components," Revision 3

EN -S Standard on

IST , Attachment 2, "IST Position No. 1, Category A Valves," Revision 1

IP 3-

CALC -07-00150, "Evaluation of

SW Pipe Leak at

PCV -1179," Revision 0

IP 3-

CALC -CCW-02487, "CCW HX Tube Plugging Limit," Revision 0

IP 3-

CALC -MULT-00734, "Minimum Thread Engagement for Bolted Connections," Revision 0

IP 3-

RPT-UNSPEC-03499, "Eddy Current Program," Revision 1

Drawings 9321-F-27513, "Auxiliary Coolant System in Primary Auxiliary Building," Revision 29

ISI -20333, "

SW System Flow Diagram, " Revision 13

ISI -27223, "

SW System Flow Diagram," Revision 18

Condition Reports

IP 3-2002-03936

IP 3-2002-04094

IP 3-2005-01102

IP 3-2005-03566

IP 3-2005-05294

IP 3-2007-00309

IP 3-2007-00453

IP 3-2007-02298

IP 3-2007-02683

IP3-2007-02956 IP3-2007-02984

Work Orders

IP 3-95-01593

IP 3-02-20499

IP 3-02-23129

IP 3-02-23130

IP 3-02-23131

IP 3-04-12766

IP 3-04-18211

IP 3-05-20192

IP 3-06-13026

IP3-07-12092

Completed Surveillances 3-PT-Q116B, "32 Safety Injection Pump Functional Test," on 04-11-2007

3-PT-CS-032A, "SW Header Check Valves & Underground Line 409 Flow Test," on 04-01-2005

3-PT-CS-032B, "SW Header Check Valves & Underground Line 408 Flow Test," on 04-02-2005

IC -

PC -I-F-1142, "SW Pump 33 Flow Test," on 01-23-2006

PCA Job No. 26076, "

IP3 Intake Bay Silt Survey," dated 03-22-2006

Heat Exchanger & Service Water Inspection Reports

PD 04739, "Eddy Current Inspection of

EDG 32 Jacket Water & Lube Oil Cooler," Revision 0

PD 04796, "Eddy Current Inspection of

CCW HX 31," Revision 0

A-4Self Assessments

IP 3-

LO -2005-00143, "IP3 Ultimate Heat Sink Focused Self-Assessment," dated 07-13-05

IP 3-

LO-2007-00153, "IP3 Ultimate Heat Sink Snapshot Self-Assessment," dated 06-18-07

System Health Reports (SHRs) SHR for Heat Exchangers, 2nd Quarter 2007

SHR for Safety Injection, 1st Quarter 2007

SHR for Service Water, 1st Quarter 2007

Miscellaneous Letter

IPN -92-040, "

IP3 Response to NRC Generic Letter 89-13," dated 09-09-1992

Letter No. 20407.002, from Normandeau Associates, to

IP 3, "Zebra Mussel Monitoring Program June Results," dated 06-22-2007 Letter from Hunting Pipeline Services, to

IP 3, "Evaluation of As-found Condition of

SW Mechanical Seals," dated 03-17-2005 Video Inspection of buried

SW Line 456 during 3R13, dated 03-2005

Video Inspection of buried SW Line 408 during 3R13, dated 03-18-2005

Video Inspection of buried SW Line 408 during 3R13, dated 03-19-2005

Section 1R11: Licensed Operator Requalification Program

IP -

SMM -TQ-114, Attachment 10.9, "Simulator Examination Summary Sheet," Revision 6

LRQ -

SES-20, "Simulator Evaluated Scenario Lesson Plan," Revision 8

E-0, "Reactor Trip or Safety Injection, "Revision 0

E-2, "Faulted Steam Generator Isolation," Revision 0 E-3, "Steam Generator Tube Rupture," Revision

0 FR -S.1, "Response to Nuclear Power Generation/

ATWS ," Revision

0 EN -

EP -201, "Performance Indicators," Revision

6 EN -

LI-114, "Performance Indicator Process," Revision 2

Section 1R12: Maintenance Effectiveness Procedures

EN -

DC -203, "Maintenance Rule Program," Revision 0

EN -

DC -204, "Maintenance Scope and Basis," Revision 0

ENN -

DC-205, "Maintenance Rule Monitoring," Revision 0

AP -55, "Preventive Maintenance Program," Revision 5

EN -

DC -324, "Preventive Maintenance Process," Revision 3

EN -

LI -102, "Corrective Action Process," Revision 10

EN -

LI-119, "Apparent Cause Evaluation (ACE) Process," Revision 7

0-ELC-406-FIR, "Appendix R Emergency Light Units Test, Inspect, Repair, and Replace," Revision 1 0-ELC-420-FIR, "Appendix R Emergency Light Unit Inspection, Battery Replacement, and Test," Revision

0 ELC -018-

GEN, "Inspection, Repair, Replacement, and Semi-Annual Operability Testing of Appendix R Lighting Units," Revision 18 3PT-R148, "Eight Hour Discharge Test for Appendix R Emergency Battery Lights," Revision 8

A-53PT-M80, "Monthly Emergency Battery Light Unit Functional Test," Revision

16 SEP -

SW-001, "Generic Letter 89-13 Service Water Program," Rev 1

Condition Reports

IP 3-2007-02826

IP 3-1997-02025

IP 3-2005-04271

IP 3-2005-14493

IP 3-2006-03070

IP 3-2006-03109

IP 3-2006-03115

IP 3-2006-03180

IP 3-2006-03340

IP 3-2006-03425

IP 3-2006-03547

IP 3-2006-03761

IP 3-2006-03799

IP 3-2006-03885

IP 3-2006-03933

IP 3-2006-04069

IP 3-2006-04073

IP 3-2007-00013

IP 3-2007-00082

IP 3-2007-00336

IP 3-2007-00547

IP 3-2007-00709

IP 3-2007-00744

IP 3-2007-01645

IP 3-2007-01705

IP 3-2007-01711

IP 3-2005-04711

IP 3-2004-00378

IP 3-2005-00987

IP 3-2006-01250

IP 3-2007-00898

IP 3-2007-01630

IP 3-2007-01704

IP3-2007-02683 IP3-2007-03630

Work Orders

IP 3-05-20557

IP 3-05-25318

IP 3-03-22781

IP 3-06-20475

IP 3-06-25865

IP 3-06-25864

IP 3-06-25960

IP 3-06-02122

IP 3-04-15778

IP [[3-05-00279 IP3-04-15762 I3-990260036]]

IP 3-06-22951 I3-990260022

IP 3-06-25860 IP3-05-10292

IP 3-06-00216

IP 3-06-12186

IP 3-07-00007

IP 3-07-14598

IP 3-07-18399

IP 3-07-00076

IP 3-07-18188

IP3-07-17850

00107965

Miscellaneous Emergency Lighting Action Plan dated February 26, 2007, Revision 0

Maintenance rule expert panel meeting minutes dated February 13, 2007

Maintenance rule expert panel meeting minutes dated January 19, 2005

Maintenance rule expert panel meeting minutes dated April 20, 2004

Maintenance rule basis document, "120 VAC Emergency Lighting System," Revision 0

Maintenance rule program report, first quarter 2007

Technical Evaluation 06-001454, Revision 0

Technical Evaluation 06-002150, Revision 0

Technical Evaluation 97-000014, Revision 4

IP3 Service Water System Health Report, 2nd Quarter 2007

Remote Visual Inspection of #1099 Service Water Pipe at

IP 3, Everest

VIT , May 2, 2001

IP 3

SW Pipe Inspection NDE Checklist, 3R13 (3/05)

IP 3

SW Pipe Inspection NDE Checklist, 3R14 (3/07)

IPEC Maintenance Rule Basis Document, Service Water (

SW) - Revision 0

Section 1R13: Maintenance Risk Assessment and Emergent Work Control Procedures

IP -

SMM -WM-101, "On-Line Risk Assessment," Revision 1

IP -

SMM -WM-100, "Work Control Process," Revision 5

EN -

MA-125, "Troubleshooting Control," Revision 2

0-PMP-4-CVCS, "Replacement of Fluid Cylinder Valves, Union Charging Pump," Revision 0

A-6Section 1R15: Operability Evaluations Procedures

IP -

SMM -AD-102, "IPEC Implementing Procedure Preparation, Review and Approval," Revision 4

EN -

OP-104, "Operability Determinations," Revision 4

OAP -026, "Determination of Operability," Revision 0

EN -

LI -102, "Corrective Action Process," Revision 8 3-PT-M108, "RHR/SI System Venting," Revision

3 SI -

SOP-SI-001, "Safety Injection System Operation," Revision 38

3-PT-OL3B19, "Safety Injection Pump #33 Load Sequencer Calibration," Revision 1

3-PT-R003B, "Safety Injection System Test Breaker Sequencing/Bus Stripping," Revision 25

EN -

OP-111, "Operational Decision-Making Issue (ODMI) Process," Revision 2

0-VLV-404-AOV, "Use of Air-Operated Valve Diagnostics," Revision 3

Condition Reports

IP 3-2007-03014

IP 3-2005-01971

IP 3-2007-02854

IP3-2007-03515

IP3-2007-02789

Drawings 9321-F-41813 9321-F-41943 9321-F-22433

Calculations

IP -

CALC-07-00180, Revision 0

CD -R-1080-5/6/7-R

IP 3-

CALC -ED-01131, Revision 1

IP 3-

CALC-SI-01374

Miscellaneous

WO 00118307

WO 51487533

Section 1R19: Post-Maintenance Testing Procedures

OAP -024, "Operations Testing," Revision 2 3-

SOP-FW-004, "Auxiliary Feedwater System Operation," Revision 26 0-VLV-412-MOV, "Use of Motor Operated Valve Diagnostics," Revision 2

3-PT-Q062B, "32 Charging Pump Operability Test," Revision 8

EN -

WM-100, "Work Request (WR) Generation, Screening and Classification," Revision 2

0-TUR-403-AFP, "Worthington Auxiliary Boiler Feed Pump Turbine Preventive Maintenance," Revision 2 0-LUB-401-GEN, "Lubrication of Plant Equipment," Revision 6

3-PT-R20B, "Auxiliary Boiler feed Pump Room Temperature Sensors (TC-1113A,

TC 1113S)," Revision 7

ENN-DC-117, "Post Modification Testing and Special Testing Instructions," Revision 4

3-PT-Q038B, "Boric Acid Transfer Pump Functional Test," Revision 0

3-PT-M079B, "32 EDG [emergency diesel generator] Functional Test," Revision 36

A-7Work Orders

IP 3-04-20639

WO 51477467

WO 51474671

WO 51474608

WO 51462867

WO 51487533 WO 51467706

Minor Maintenance Work Orders for

WRT -

IP3-07-22862 and 22863

Condition Reports

IP 3-2007-03001

IP 3-2007-03560

IP 3-2007-03639

IP 3-2006-03307

IP 3-2007-03019

IP3-2006-03310 IP2-2004-00085

Misc. Trico© Opto-Matic Oilers Instructions, Type

LS or

SS, Glass

VTM #451-100000596, "Instructions For Installation, Operation, Maintenance and List Of Parts

For WT Pumps," Revision 2

Section 1R22: Surveillance Testing Condition Reports

IP 3-2007-03019

IP3-2006-02321

Section 1R23: Temporary Modifications Procedures 0-LKR-401-GEN, "Temporary On-Line Leak Repairs," Revision 1

EN -

ME -S-001, Attachment 7.3, "Engineering Leak Repair Evaluation Form," Revision 1

EN -

DC-126, "Engineering Calculation Process," Revision 0

Calculations

IP -

CALC-07-00182

Section

1EP 6: Drill Evaluation Procedures

IP -EP-120, "Emergency Classification," Revision 2

IP -

EP -410, "Protective Action Recommendations," Revision 3

IP -

EP-AD1, "Maintaining Emergency Preparedness," Revision 1

Section 2S01: Access Control to Radiologically Significant Areas Quality Assurance Surveillance Report

QS -2007-

IP -07, Radiation Protection and Radiation Worker Practices during Refueling Outage 3R14 Quality Assurance Surveillance Report

QS -2007-

IP -05, Readiness of the Radiation Protection Organization for Refueling Outage 3R14

LO -

IP 3LO-2007-00014, Snapshot Self Assessment, Core Barrel Event

LO -

IP 3LO-2007-00249, Snapshot Self Assessment, Outage Work Control Planning for RP

LO -

IP 3LO-2007-00015, Snapshot Self Assessment, Surveys, Postings, and Labels

LO -

IP 3LO-2007-00132, Snapshot Self Assessment, Five Year

ALA [[]]

RA /Source Reduction Plan

LO -

IP 3LO-2007-00147, Snapshot Self Assessment,

ALA [[]]

RA Program

A-8Procedures

EN -

RP -101, "Access Control for Radiologically Controlled Areas," Revision 2

EN -

RP -105, "Radiation Work Permits," Revision 2

EN -

RP -141, "Job Coverage," Revision 2

EN -

RP-310, Operation and Initial Set-up of the Eberline AMS-4 Continuous Air Monitor

O-RP-IC-310, Calibration of the Eberline AMS-4 Air Monitoring System using Windows

Eberline AMS-4 Technical Manual, March 1994

Condition Reports:

IP 2-2007-02313

IP 3-2007-00866

IP 3-2007-00876

IP 3-2007-01553

IP 3-2007-01813

IP 3-2007-02151

IP 3-2007-02593 Section 4

OA 1: Performance Indicator Verification Procedures

EN -

LI -114, "Performance Indicator Process," Revision 2

NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 4

EN-LI-114, Attachment 9.2, "NRC Performance Indicator Technique Sheet," Revision 2

Condition Reports: IP3-2006-03361

Miscellaneous:

MSPI Emergency

AC Power System Derivation Report June 2007

MS [[]]

PI High Pressure Injection System Derivation Report June 2007

MS [[]]

PI Residual Heat Removal System Derivation Report June 2007

MS [[]]

PI Auxiliary Feedwater System Derivation Report June 2007

MS [[]]

PI Cooling Water System Derivation Report August 2007

LIST [[]]

OF [[]]

ACRONY [[]]

MS [[]]

ADA [[]]

MS agency-wide documents and management system

ALA [[]]

RA as low as is reasonably achievable

ANS alert notification system

AFW auxiliary feed water

CAP corrective action program

CCW component cooling water

CFR Code of Federal Regulations

CR condition report

DEC Department of Environmental Conservation

EDG emergency diesel generator

EDO Executive Director of Operations

EP Emergency Preparedness

ESS [[]]

AP Education, Environmental Site Survey and Assessment Program

GL generic letter

GZA GeoEnvironmental, Inc.

A-9HX heat exchanger IMC inspection manual chapter

IP2 Indian Point Nuclear Generating Unit 2

IP 3 Indian Point Nuclear Generating Unit 3

IP [[]]

EC Indian Point Energy Center

IST inservice test

LER licensee event report

MP [[]]

FF maintenance preventable functional failures

mrem millirem

MS [[]]

PI mitigating system performance index

NCV non-cited violation

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

NYSD [[]]

EC New York State Department of Environmental Conservation

OA other activities

ORI [[]]

SE Oak Ridge Institute for Science and Education

OS Occupational Radiation Safety

PA [[]]

RS publicly available records

PI performance indicator

PI&R Problem Identification and Resolution

RHR residual heat removal

RP radiation protection

RW recovery well

SDP significance determination process

SI safety injection

SHR system health report

SSC systems, structures, components

SW service water

TS technical specifications

UFS [[]]

AR updated final safety analysis report

WO work order