J. Ventosa

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I 2100 RENAISSANCE BLVD., SUITE 100

KING OF PRUSSIA, PA 19406-2713

August 8, 2014

Mr. John Ventosa Site Vice President Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB Buchanan, NY 10511-0249 SUBJECT: INDIAN POINT POWER STATION – NRC INTEGRATED INSPECTION

REPORT 05000247/2014003 AND 05000286/2014003 Dear Mr. Ventosa: On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Indian Point Nuclear Generating Units 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on July 17, 2014, with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission’s rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no violations of NRC requirements were identified. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs “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’s Public Document Room or from the

J. Ventosa 2

Publicly Available Records component of the NRC’s Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA/ Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

Enclosure: Inspection Report 05000247/2014003 and 05000286/2014003 w/Attachment: Supplementary Information

cc w/encl: Distribution via ListServ

J. Ventosa 2 Publicly Available Records component of the NRC’s Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA/ Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

Enclosure: Inspection Report 05000247/2014003 and 05000286/2014003 w/Attachment: Supplementary Information

cc w/encl: Distribution via ListServ Distribution w/encl: (via E-mail) W. Dean, RA D. Lew, DRA H. Nieh, DRP M. Scott, DRP J. Trapp, DRS P. Krohn, DRS A. Burritt, DRP T. Setzer, DRP L. McKown, DRP

J. Petch, DRP S. Stewart, DRP, SRI B. Bollinger, DRP, RI (Actg) G. Newman, DRP, RI D. Hochmuth, DRP, AA A. Bowers, RI OEDO RidsNrrPMIndianPoint Resource RidsNrrDorlLpl1-1 Resource ROPReports Resources

DOCUMENT NAME: G:\DRP\BRANCH2\A - INDIAN POINT\IP2&3 INSPECTION REPORTS\2014\2014-003\IP2&3 2014.003.FINAL.DOCX ADAMS ACCESSION NUMBER: ML14223A045

SUNSI Review

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

OFFICE RI/DRP RI/DRP RI/DRP

NAME SStewart/TCS for TSetzer/TCS ABurritt/ALB

DATE 7/31/14 7/31/14 8/8/14

OFFICIAL RECORD COPY

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 Report Nos. 05000247/2014003 and 05000286/2014003 Licensee: Entergy Nuclear Northeast (Entergy) Facility: Indian Point Nuclear Generating Units 2 and 3 Location: 450 Broadway, GSB Buchanan, NY 10511-0249 Dates: April 1, 2014, through June 30, 2014 Inspectors: J. Stewart, Senior Resident Inspector A. Patel, Resident Inspector G. Newman, Resident Inspector J. Furia, Health Physicist S. Galbreath, Reactor Inspector

E. H. Gray, Senior Reactor Inspector R. Latta, Senior Reactor Inspector

L. McKown, Project Engineer T. Setzer, Senior Project Engineer

Approved By: Arthur L. Burritt, Chief Reactor Projects Branch 2 Division of Reactor Projects

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TABLE OF CONTENTS

SUMMARY .................................................................................................................................... 3 

REPORT DETAILS ....................................................................................................................... 4 

1.  REACTOR SAFETY .............................................................................................................. 4 

1R01  Adverse Weather Protection ....................................................................................... 4 1R04  Equipment Alignment .................................................................................................. 5 1R05  Fire Protection ............................................................................................................. 6 1R06  Flood Protection Measures ......................................................................................... 8 1R07  Heat Sink Performance ............................................................................................... 9 1R08  Inservice Inspection Activities ..................................................................................... 9 1R11  Licensed Operator Requalification Program ............................................................. 10 1R12  Maintenance Effectiveness ....................................................................................... 12 1R13  Maintenance Risk Assessments and Emergent Work Control .................................. 12 1R15  Operability Determinations and Functionality Assessments ..................................... 14 1R18  Plant Modifications .................................................................................................... 15 1R19  Post-Maintenance Testing ........................................................................................ 16 1R22  Surveillance Testing .................................................................................................. 17 1EP6  Drill Evaluation .......................................................................................................... 18 

2.  RADIATION SAFETY .......................................................................................................... 19 

2RS7  Radiological Environmental Monitoring Program ...................................................... 19 

4.  OTHER ACTIVITIES ............................................................................................................ 21 

4OA1  Performance Indicator Verification ............................................................................ 21 4OA2  Problem Identification and Resolution ....................................................................... 22 4OA3  Follow Up of Events and Notices of Enforcement Discretion .................................... 26 4OA5  Other Activities .......................................................................................................... 26 4OA6  Meetings, Including Exit ............................................................................................ 29 

ATTACHMENT: SUPPLEMENTARY INFORMATION............................................................... 29 

SUPPLEMENTARY INFORMATION ........................................................................................ A-1 

KEY POINTS OF CONTACT .................................................................................................... A-1 

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ..................................... A-1 

LIST OF DOCUMENTS REVIEWED ........................................................................................ A-1 

LIST OF ACRONYMS ............................................................................................................... A-6 

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SUMMARY IR 05000247/2014003, 05000286/2014003; 04/01/2014 – 06/30/2014; Indian Point Power Station, Units 2 and 3; Routine Integrated Inspection Report. This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. No findings were identified. The NRC’s program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, “Reactor Oversight Process,” Revision 5.

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REPORT DETAILS Summary of Plant Status Unit 2 began the inspection period at 100 percent power. Unit 2 remained at or near 100 percent power for the remainder of the inspection period. Unit 3 began the inspection period at 100 percent power. Unit 3 remained at or near 100 percent power for the remainder of the inspection period. 1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01 – 2 samples) .1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of Entergy’s readiness for the onset of seasonal high temperatures. The inspectors reviewed procedure OAP-048, “Seasonal Weather Preparation (Units 2 and 3).” The focused areas were auxiliary boiler feedwater pump (ABFP) building ventilation systems (2-SOP-11.1, 3-SOP-V-001), emergency diesel generator (EDG) buildings, and service water pump areas. The inspectors reviewed the updated final safety analysis report (UFSAR), technical specifications (TSs), control room logs, and the corrective action program (CAP) to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Entergy personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Entergy’s seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during hot weather conditions. Documents reviewed for each section of the inspection report are listed in the Attachment.

b. Findings

No findings were identified.

.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Entergy’s procedures affecting these areas and the communications protocols between the transmission system operator and Entergy. This review focused on changes to the established program and material condition of the offsite and alternate AC power

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equipment. The inspectors assessed whether Entergy established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing condition reports (CRs) and open work orders (WOs), and walking down portions of the offsite AC power systems including the 345 kilovolt (kV), 138kV, and 13.8kV switchyard.

b. Findings

No findings were identified.

1R04 Equipment Alignment .1 Partial System Walkdowns (71111.04Q – 5 samples)

a. Inspection Scope The inspectors performed partial walkdowns of the following systems: Unit 2 EDGs using Entergy procedure 2-COL-27.3.1, “Diesel Generators,” when switchyard

breaker BT2-3 was being replaced concurrent with planned maintenance on the Appendix R EDG output breaker on April 24, 2014

22 and 23 Safety Injection Pumps (SIPs) using Entergy procedure 2-COL-10.1.1, “Safety Injection System,” when 21 SIP was out of service (OOS) for 4-year motor preventive maintenance (PM) on May 20, 2014

21 ABFP lineup using Entergy procedure 2-COL-21.3, “Steam Generator Water Level,” when 23 ABFP was removed from service for planned maintenance (18-month) on June 4, 2014

Unit 3 31 control room air conditioning system (CRACS) while 32 CRACS was OOS for

planned maintenance on April 23, 2014 31, 32, and 33 EDGs and Appendix R diesel generator with primary 138kV feeder

95331 removed from service due to work in Buchanan switchyard by Consolidated Edison on April 28, 2014

The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, WOs, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.

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The inspectors also reviewed whether Entergy staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings No findings were identified. .2 Full System Walkdown (71111.04S – 1 sample)

a. Inspection Scope

On May 28, 2014, the inspectors performed a complete system walkdown of accessible portions of the Unit 3 control room heating, ventilation, and air conditioning system including the CRACS and control room emergency ventilation system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs and WOs to ensure Entergy appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified. 1R05 Fire Protection .1 Resident Inspector Quarterly Walkdowns (71111.05Q – 5 samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Entergy staff controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for degraded or inoperable fire protection equipment, as applicable, in accordance with procedures. Unit 2 Auxiliary feedwater building (elevation 18'), pre-fire plan 259, was reviewed during

the walkdown

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Primary Auxiliary Building 68’ and 72’ when high energy line break and fire door 218 located at the 68' primary auxiliary building mezzanine failed to close and latch by itself from April 13–25, 2014 (CR-IP2-2014-2638). Inspectors reviewed hourly fire watch activities and reviewed Pre-Fire Plans PFP-215 and 216. The door was repaired and returned to service on April 25, 2014.

Primary auxiliary building (elevation 98'), Pre-Fire plan 217 was reviewed during the walkdown. In addition, compensatory actions for potential spurious operation of LCV-112C should a fire occur in the area were reviewed.

Unit 3 480V switchgear room, pre-fire plan 351, was used during unavailability of the

appendix R diesel generator for planned maintenance on May 27, 2014 Auxiliary feedwater building, 18'-6″ elevation, auxiliary feedwater pump room using

pre-fire plan 365, on June 17, 2014

b. Findings

No findings were identified. .2 Fire Protection – Drill Observation (71111.05A – 1 sample)

a. Inspection Scope

The inspectors observed a fire brigade drill conducted on April 17, 2014, that involved a simulated fire in the Unit 2 21 auxiliary feedwater pump. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Entergy personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows: Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met The inspectors also evaluated the fire brigade’s actions to determine whether these actions were in accordance with Entergy’s fire-fighting strategies. Entergy document EN-TQ-125, “Fire Brigade Drills,” Attachment Drill Report, was reviewed by the inspectors.

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b. Findings

No findings were identified. 1R06 Flood Protection Measures (71111.06 – 3 samples) .1 Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if Entergy staff identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors verified the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, and temporary or removable flood barriers. Unit 2 EDG building postulated flooding resulting from piping break of service water system,

fire protection system (IP-RPT-09-00026, Indian Point Unit 2, Internal Flooding Analysis)

Unit 3 Residual heat removal pump rooms in the primary auxiliary building (elevation 15')

postulated flooding resulting from piping break of safety injection (SI) system, CCW system, city water system, service water system, fire protection system (IP-RPT-10-00023, Indian Point Unit 3, Internal Flooding Analysis)

b. Findings

No findings were identified.

.2 Annual Review of Cables Located in Underground Bunkers/Manholes

a. Inspection Scope The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could disable risk-significant equipment on April 10, 2014. The inspectors performed walkdowns of risk-significant areas, including Unit 2 manhole 24 and Unit 3 manholes 31, 31A, and 31B, to verify that the cables were not continually submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed. For those cables found submerged in water, the inspectors verified that Entergy had conducted an operability evaluation for the cables and were implementing appropriate corrective actions.

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b. Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07A – 2 samples)

a. Inspection Scope

The inspectors reviewed the readiness and availability of the Unit 2 22 EDG jacket water and lube oil heat exchangers (during 0-HTS-405-EDG, EDG Lube Oil and Jacket Water Heat Exchanger Maintenance) and the Unit 3 31 CCW heat exchanger during Entergy inspections. The inspectors reviewed the design basis of the heat exchangers and verified Entergy’s commitments to NRC Generic Letter 89-13. The inspectors observed actual performance tests for the heat exchangers and/or reviewed the results of previous inspections of the 22 EDG jacket water and lube oil, 31 CCW heat exchanger, and similar heat exchangers. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left conditions. The inspectors verified that Entergy initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchangers did not exceed the maximum amount allowed.

b. Findings

No findings were identified. 1R08 Inservice Inspection Activities (71111.08P – 1 sample) Underground Piping and Tank Integrity (Temporary Instruction 2515/182, Phase 2)

a. Inspection Scope Entergy’s buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.a of Temporary Instruction (TI) 2515/182. It was confirmed that activities, which correspond to completion dates specified in the program that have passed since the Phase 1 inspection was conducted, have been completed. Additionally, Entergy’s buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of the TI, and responses to specific questions found in http://www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf were submitted to the NRC headquarters staff. Identification and Resolution of Problems (Inspection Manual Chapter Section 02.05) The inspectors verified that buried piping and underground piping and tanks program related problems and nonconforming conditions were properly identified, characterized, and evaluated for disposition within the CAP.

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b. Findings

No findings were identified. 1R11 Licensed Operator Requalification Program (71111.11Q – 4 samples)

Unit 2 .1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on May 1, 2014, which included steam generator tube leak leading to steam generator tube rupture without pressure control following feed regulating valve controller failure. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified. .2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed and reviewed 2-PT-Q058, “Steam Generator Level

Bistables,” and 2-PT-Q029B, “22 Safety Injection Pump,” conducted on June 17 and 18, 2014. The inspectors observed infrequently performed test or evolution briefings, pre-shift briefings, and reactivity control briefings to verify that the briefings met the criteria specified in Entergy’s Operations Section Expectations Handbook and Entergy Administrative Procedure, OP-AA-329, “Conduct of Infrequently Performed Tests and Evolutions.” Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards. On May 20, 2014, the inspectors observed operator response to a component cooling water (CCW) alarm - cable fire detection system, for the CCW supervisory circuit, zone 8 (CR-IP2-2014-3233). The inspectors verified the operators’ response in accordance with alarm response procedure 2-ARP-SDF.

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b. Findings No findings were identified.

Unit 3 .3 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on May 1, 2014, which included an instrument failure, a main steam line break, a steam generator tube rupture coincident with a loss of offsite power, and the failure of select components to automatically start as required. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings No findings were identified. .4 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed a five percent downpower in preparation for turbine valve testing on June 24, 2104. After the downpower, the inspectors observed operators use 3-AOP-FW-001, “Loss of Feedwater,” due to feedwater flow and level oscillations, placing the 31 feedwater regulating valve in manual to stabilize the plant. The inspectors observed infrequently performed test or evolution briefings, pre-shift briefings, and reactivity control briefings to verify that the briefings met the criteria specified in Entergy’s Operations Section Expectations Handbook and Entergy Administrative Procedure, OP-AA-329, “Conduct of Infrequently Performed Tests and Evolutions.” Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.

b. Findings

No findings were identified.

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1R12 Maintenance Effectiveness (71111.12Q – 3 samples)

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule basis documents to ensure that Entergy was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria established by Entergy staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries. Unit 2 CR-IP2-2013-2696; while attempting a course adjust of NI-41, channel 41 spiked low

causing the power range dropped rod stop alarm. The first quarter 2014 nuclear instrument system health report and the (a)(1) action plan were reviewed during the inspection

CR-IP2-2014-2273; functional failure of relay 27-1/6A during testing on February 26, 2014. The first quarter 2014 480V AC system health report was reviewed during the inspection

Unit 3 CR-IP3-2013-4235; 35 service water pump differential pressure slightly above

expected range during quarterly testing. The first quarter 2014 service water system health report was reviewed during the inspection

b. Findings

No findings were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 – 6 samples)

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Entergy personnel performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Entergy personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Entergy identified emergent

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work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station’s probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Unit 2 April 24, 2014: Elevated risk associated with planned maintenance on 138kV bus

section 3 de-energized, appendix R diesel generator removed from service for planned maintenance, and testing of 21 auxiliary boiler feedwater pump. The inspectors verified Entergy’s contingency postings in accordance with Entergy’s procedure EN-OP-119, “Protected Equipment Postings,” and procedure EN WM-104, “On Line Risk Assessment,” as part of the inspection

April 28, 2014: Elevated risk associated with planned maintenance on 138kV bus section 2, feeder 95331 (primary for Unit 3) removed from service, feeder 95332 (primary for Unit 2) powered from one out of three feeders (96952), and 26 service water pump removed from service. The inspectors verified Entergy’s contingency postings in accordance with Entergy’s procedure EN-OP-119, “Protected Equipment Postings,” and procedure EN WM-104, “On Line Risk Assessment,” as part of the inspection

June 4, 2014: Elevated risk associated with planned maintenance on 23 ABFP. The inspectors verified Entergy’s contingency postings in accordance with Entergy’s procedure EN-OP-119, “Protected Equipment Postings,” and procedure EN WM-104, “On Line Risk Assessment,” as part of the inspection

Unit 3

April 2, 2014: Elevated risk associated with planned testing and maintenance on

32 ABFP. The inspectors verified Entergy’s contingency postings in accordance with Entergy’s procedure EN-OP-119, “Protected Equipment Postings,” and procedure EN WM-104, “On Line Risk Assessment,” as part of the inspection

April 8, 2014: Elevated risk associated with planned maintenance on 31 EDG while the Unit 3 appendix R diesel generator was nonfunctional. The inspectors verified Entergy’s contingency postings in accordance with Entergy’s procedure EN-OP-119, “Protected Equipment Postings,” and procedure EN WM-104, “On Line Risk Assessment,” as part of the inspection

April 28, 2014: Elevated risk associated with planned maintenance of 138kV feeder 95331 removed from service while relying on Unit 2 feeder 95332 via the 33332 cross tie. The inspectors verified Entergy’s contingency postings in accordance with Entergy’s procedure EN-OP-119, “Protected Equipment Postings,” and procedure EN WM-104, “On Line Risk Assessment,” as part of the inspection.

b. Findings

No findings were identified.

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1R15 Operability Determinations and Functionality Assessments (71111.15 – 8 samples)

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions: Unit 2 Operational decision making activities using Entergy procedure 0-SOP-LEAKRATE-

001, RCS Leakrate Surveillance and Leak Identification; associated with high reactor coolant system (RCS) leakage on April 9, 2014. The inspectors verified containment parameters within normal ranges and no trend on volume control tank level. The leakage was later identified by Entergy as non-reactor coolant system leakage (21 charging pump drain).

(CR-IP2-2014-2792 and CR-IP2-201402793) Station battery 22, cell 1, contained a piece of material in the electrolyte resting on plates and cell 42 showed signs of copper intrusion on several of the negative plates. The inspectors reviewed the test results and performed visual observation to ensure operability

(CR-IP2-2014-3073) Operability of vapor containment on May 9, 2014, when it was determined that the airlock leakage was greater than the procedural criteria of 10,000 standard cubic feet per minute (SCFM). The airlock seal was replaced and the test was repeated using 2-PT-2Y016B, 95' Containment Air Lock Test. The inspectors reviewed the licensee’s operability determination and test results after the seal replacement to ensure the leakage was within the total containment acceptance criteria of less than 0.60 La (130,435 cc/min).

(CR-IP2-2014-03383) Cable spreading room halon fire protection system control panel backup battery had a reading of zero mv on the battery test meter. The inspectors determined that the system remained functional due to primary power supplied via an instrument bus that is backed up by an automatic emergency power source. The inspectors also verified mechanical actuation of the system remains available via a compressed nitrogen cylinder

Unit 3 On February 6, 2014, following the loaded run of 31 EDG per 3-PT-M79A, when

31 EDG output breaker was opened, 31 EDG non-SI blackout logic defeated reset itself without operator action and 32 ABFP started in auto (CR-IP3-2014-00368). This indicated that resetting SI after a loss of offsite power and SI actuation will cause 32 CCW pump and 32 ABFP to auto start. This condition was result of a sticking reset pushbutton. The inspectors reviewed the logic drawings and verified that the failure of this reset circuit does not adversely affect the safety of the plant, the EDGs, or the Engineering Safeguard Features

On March 25, 2014, the inspectors performed a walkdown of the Unit 3 intake structure to evaluate concrete spalling on the service water pit ceiling. The inspectors compared direct observations against Entergy’s structural analysis and operability evaluation (CR-IP3-2014-00405). Specifically, the inspectors verified that adequate concrete thickness remained and that exposed rebar was still bonded to concrete and could perform its function

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On May 5, 2014, the 32 EDG jacket water cooler was found to exceed administrative tube blockage limits as part of an annual preventative maintenance inspection and cleaning. The inspectors reviewed Entergy’s analyses and industry guidance and independently determined that heat exchanger remained operable

On May 18, 2014, water was discovered to be leaking from the transformer moats into the turbine building via a faulty conduit seal. The inspectors reviewed Entergy’s actions taken to verify that the source of water was not the degraded service water line which had been temporarily repaired with an engineered clamp

The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to Entergy’s evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Entergy. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18 – 2 samples) .1 Temporary Modification

a. Inspection Scope The inspectors reviewed the temporary modification listed below to determine whether the modification affected the safety functions of systems that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results and conducted field walkdowns of the modification to verify that the temporary modification did not degrade the design bases, licensing bases, and performance capability of the affected systems. Unit 2 Engineering Change 51043 – 24 RCP Zone 3 (smoke detector spurious fire alarm),

smoke detector circuit wires lifted to remove input to the containment building fire alarm on the Unit 2 central control room fire indicating unit panel, EFA6, in order to prevent the faulty detector from masking the other alarm inputs in the case of an actual fire situation (CR-IP2-2014-3084, 3150 and 3164).

b. Findings

No findings were identified.

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.2 Permanent Modification

a. Inspection Scope

The following inspection sample examined ongoing modifications fulfilling NRC’s EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigating Strategies for Beyond Design Basis External Events. Specifically, the inspectors reviewed Entergy’s activities on Unit 3 listed below to meet the order. The inspection did not address whether the modification satisfactorily addressed the objectives of Order EA-12-049. The inspection scope for the modification was restricted to those elements necessary to satisfy the stated objectives of Inspection Procedure 71111.18, specifically: To verify that modifications have not affected the safety functions of important safety

systems; To verify that the design bases, licensing bases, and performance capability of risk

significant SSCs have not been degraded through modifications; and Verify that modifications performed during increased risk-significant configurations

did not place the plant in an unsafe condition. Engineering Change 45666 – Install Spent Fuel Pool Level Instrumentation, and Planned FLEX Modifications The inspectors walked down the on-going modification installation activities and verified that the design bases, licensing bases, and performance capability of systems affected by the modifications were not degraded. In addition, the inspectors reviewed selected documents associated with the design changes.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19 – 8 samples)

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

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Enclosure

Unit 2 Review of bus 6A 480V undervoltage relay 27-1/6A calibration and replacement (2-

year preventive maintenance) on September 5, 2013, prior to its failure during surveillance testing on February 26, 2014

Motor operated valve diagnostic test (10-year PM) on SWN-41-5A-OPER, 25 Containment Recirculation Fan Cooler Unit Service Water Inboard Inlet Isolation Valve, per WO 52430244, in accordance with 2-PT-Q013-DS142, 25 Fan Cooler Unit Service Water Valves Inservice Testing (IST) Data Sheet (Containment Isolation Valve Stroke) on April 14, 2014

Review of 2PC-2Y1, Reactor Coolant System Alternate Safe Shutdown Temperature Monitor Calibration, for channel TI-5139 and TI-5141 restoration after impairment (IP2-2014-528, IP2-2014-554) per WOs 340641-65 and 379160 on April 15, 2014

Review of 2-PT-M021C, Emergency Diesel Generator 23 Load Test, after 23 EDG output breaker 52/EG3 replacement (2-year PM) per WO 52413852 on April 16, 2014

Review of 2-PT-M110, Appendix R Diesel Generator Functional Test, after the PM of output breaker 2-CB-52/SBO/ASS per WO 52342906 on April 24, 2014

Review of 2-PT-M021A, Emergency Diesel Generator 21 Load Test, after 8-year inspection of 21 EDG engine per WO 52294982 on May 17, 2014

Unit 3 3-PT-079B, 32 Emergency Diesel Generator Functional Test, following maintenance

on the lube oil and jacket water heat exchangers per WOs 52488223 and 52488224 on May 6, 2014

3-PT-V059C, 33 Service Water Pump Reference Test, following planned replacement of the pump and motor per WO 372137 on June 12, 2014

b. Findings

No findings were identified. 1R22 Surveillance Testing (71111.22 – 7 samples)

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and Entergy procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

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Enclosure

Unit 2 2-PT-Q028B, 22 Residual Heat Removal Pump Surveillance Test, on April 11, 2014 2-PT-2Y018G, Transfer Switch EDD-7 (23 EDG) Test, on April 18, 2014 2-PT-Q001C, 23 Station Battery Surveillance and Charging, on April 22, 2014

(WO 52539233) 2-PT-Q017A, Alternate Safe Shutdown Supply Verification to 21 Auxiliary Feedwater

Pump, on April 24, 2014 Unit 3 3-PT-Q120B, 32 Auxiliary Boiler Feedwater Pump Surveillance and Inservice Test,

on April 4, 2014 (IST) 3-PT-M079C, 33 EDG Functional Test, on April 10, 2014 0-SOP-LEAKRATE-001, RCS Leakrate Surveillance, Evaluation, and Identification,

on June 30, 2014 (RCS)

b. Findings

No findings were identified. Cornerstone: Emergency Preparedness 1EP6 Drill Evaluation (71114.06 – 2 samples) .1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine Entergy emergency drill on June 4, 2014, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Entergy staff in order to evaluate Entergy’s critique and to verify whether the Entergy staff was properly identifying weaknesses and entering them into the CAP.

b. Findings

No findings were identified.

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Enclosure

.2 Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for Unit 2 licensed operators on May 1, 2014, which required emergency plan implementation by an operations crew. Entergy planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors’ activities was to note any weaknesses and deficiencies in the crew’s performance and ensure that Entergy evaluators noted the same issues and entered them into the CAP.

b. Findings

No findings were identified. 2. RADIATION SAFETY Cornerstone: Public Radiation Safety and Occupational Radiation Safety 2RS7 Radiological Environmental Monitoring Program (71124.07 – 1 sample)

a. Inspection Scope

During the week of June 2 – 6, 2014, the inspectors verified that the radiological environmental monitoring program (REMP) quantifies the impact of radioactive effluent releases to the environment and validates the integrity of the radioactive gaseous and liquid effluent release program. The inspectors used the requirements in 10 CFR 20; 10 CFR 50, Appendix A, Criterion 60, “Control of Release of Radioactivity to the Environment;” 10 CFR 50, Appendix I,” Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion ‘As Low as is Reasonably Achievable’ for Radioactive Material in Light-Water – Cooled Nuclear Power Reactor Effluents;” 40 CFR 190, “Environmental Radiation Protection Standards for Nuclear Power Operations;” 40 CFR 141, “Maximum Contaminant Levels for Radionuclides;” Regulatory Guides 1.23, 4.1, and 4.15; NUREG 1301 or 1302; applicable industry standards; and Entergy procedures as criteria for determining compliance. Inspection Planning The inspectors reviewed the annual radiological environmental operating reports and the results of any Entergy assessments since the last inspection to verify that the REMP was implemented in accordance with the plant TS and the offsite dose calculation manual (ODCM). The inspectors reviewed the report for changes to the ODCM with respect to environmental monitoring, sampling locations, monitoring and measurement frequencies, land use census, interlaboratory comparison program, and analysis of data.

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Enclosure

The inspectors reviewed the UFSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation. The inspectors reviewed the annual effluent release report and the 10 CFR 61, “Licensing Requirements for Land Disposal of Radioactive Waste,” report, to determine if Entergy was sampling for the predominant radionuclides likely to be released in effluents.

Site Inspection

The inspectors walked down air sampling stations and thermoluminescent dosimeter (TLD) monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition. For the air samplers and TLDs selected, the inspectors reviewed the calibration and maintenance records to verify that they demonstrate adequate operability. Additionally, the inspectors reviewed the calibration and maintenance records of composite water samplers. The inspectors verified that Entergy had initiated sampling of other appropriate media upon loss of a required sampling station. The inspectors observed the collection and preparation of the following environmental samples: Hudson River bottom sediment, Hudson River shoreline soil, and Hudson River aquatic vegetation. The inspectors verified that environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with procedures.

Based on direct observation and review of records, the inspectors verified that the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC Regulatory Guide 1.23, “Meteorological Monitoring Programs for Nuclear Power Plants,” and Entergy procedures. The inspectors verified that the meteorological data readout and recording instruments in the control room and at the tower were operable. The inspectors verified that missed and or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors reviewed Entergy’s assessment of any positive sample results. The inspectors reviewed the associated radioactive effluent release data that was the source of the released material.

The inspectors selected SSCs that could involve the release of licensed material to reach ground water and verified that Entergy had implemented a sampling and monitoring program sufficient to detect this leakage. The inspectors verified that records, as required by 10 CFR 50.75(g), of leaks, spills, and remediation since the previous inspection was documented as required.

The inspectors reviewed any significant changes made by Entergy to the ODCM as the result of changes to the land census, long-term meteorological conditions (three-year average), or modifications to the sampler stations since the last inspection. The inspectors reviewed technical justifications for any changed sampling locations. The inspectors verified that Entergy performed the reviews required to ensure that the

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Enclosure

changes did not affect the ability to monitor the impacts of radioactive effluent releases on the environment.

The inspectors verified that appropriate detection sensitivities were used for counting environmental samples. The inspectors reviewed quality control charts for maintaining radiation measurement instrument status and actions taken for degrading detector performance. The inspectors reviewed the results of Entergy’s inter-laboratory comparison program to verify the adequacy of environmental sample analyses performed by Entergy. The inspectors verified that the inter-laboratory comparison test included the media/nuclide mix appropriate for the facility.

Identification and Resolution of Problems

The inspectors verified that problems associated with the REMP are being identified by Entergy at an appropriate threshold and were properly addressed for resolution in the CAP. The inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented that involved the REMP.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES 4OA1 Performance Indicator Verification (71151 – 6 samples) Initiating Events Performance Indicators (6 samples)

a. Inspection Scope

The inspectors reviewed Entergy’s submittal of the following Initiating Events performance indicators for the period April 1, 2013, through March 31, 2014: Unit 2 Unplanned Scrams per 7000 Critical Hours (IE01) Unplanned Power Changes per 7000 Critical Hours (IE03) Unplanned Scrams with Complications (IE04) Unit 3 Unplanned Scrams (IE01) Unplanned Power Changes (IE03) Unplanned Scrams with Complications (IE04) To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, “Regulatory Assessment Performance Indicator Guideline,” Revision 7. The inspectors reviewed Entergy’s operator narrative logs, maintenance

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Enclosure

planning schedules, CRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals. There were no unplanned power changes or scrams with complications during the review period.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152 – 3 samples) .1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, “Problem Identification and Resolution,” the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Entergy entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.

b. Findings

No findings were identified. .2 Annual Sample: Unit 2 Monitoring of Spent Fuel Pool Neutron Absorbing Material

a. Inspection Scope

The inspectors performed an in-depth review of Entergy's evaluations and corrective actions associated with CR-IP2-2014-0776, which documented the results of the Fall 2013 BADGER (boron-10 areal density) testing of selected panels in the Unit 2 spent fuel pool. Evaluation of test results revealed that 19 of 48 panels had degradation which challenged the assumed boraflex degradation used in the NRC approved criticality analysis of record (CAOR).

The inspectors assessed Entergy's problem identification threshold, problem analysis, extent of condition reviews, compensatory actions, and the prioritization and timeliness of corrective actions to evaluate whether Entergy was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Entergy's CAP and 10 CFR 50, Appendix B. The inspectors observed portions of the BADGER testing, reviewed documents including vendor test reports, and interviewed engineering and licensing personnel to assess the adequacy of the planned and completed actions for boraflex degradation. Assessment of the as-found fuel storage configuration was beyond the scope of the inspection and was pending further evaluation by Entergy.

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Enclosure

b. Findings and Observations

No findings were identified.

Boraflex degradation in the Unit 2 spent fuel pool is a long standing problem which had been addressed by a license amendment in 2002. At the end of 2006, operability of the neutron absorbing capability of the spent fuel pool was maintained through compensatory measures that included maintaining an increased level of dissolved neutron poison in the pool, more frequent monitoring of the dissolved neutron poison level in the pool, periodic predictive evaluation using the computer program RACKLIFE which predicted dissolution of boraflex in each of the pool panels, and confirmatory measurement of selected panel neutron absorber efficacy using periodic BADGER tests. Throughout this period, spent fuel pool boron had been maintained at greater than TS limits assuring that fuel in the pool remained subcritical. Following BADGER testing in Fall 2013, Entergy was provided with results that revealed 19 panels of 48 tested with greater degradation than assumed in the CAOR. These panels exhibited total mass loss greater than assumed or gap lengths in excess of assumed worst case examples, and for two panels, both conditions were observed. Gaps that were observed occurred near the center of the panel and below adjacent fuel assembly midplane. Because the pool remained at greater than 2000 ppm dissolved boron, there was no period when the pool was not operable. To establish continued operability, Entergy augmented the predictive RACKLIFE by establishing compensatory measures for panels that had received a threshold dose prior to 2007 as described below. The inspectors verified that compensatory measures were established and in place: maintain boron concentration in the Unit 2 spent fuel pool greater than 2400 ppm; sample and analyze the spent fuel pool boron concentration once per day; and perform rounds in the spent fuel pool building twice per shift to verify no gross in-leakage of diluting water to the pool. Further, Entergy established three compensatory measures for suspected failed panels where the CAOR assumes no more than a fixed percent loss of neutron absorber capability. Identification of suspect panels was provided both by RACKLIFE prediction and evaluation of susceptibility using dose and temperature exposure. The compensatory measures verified in place by inspectors were: use Region 2-1 loading requirements on both sides of a failed panel; use an empty cell on one side of a failed panel; and use a control rod in an assembly on one side of a failed panel. Entergy completed an estimate of the as-found configuration of stored fuel considering the BADGER results and estimated that excess burnup of assemblies in the pool would compensate for the reactivity effects of the degraded panels. A detailed evaluation of the as-found configuration was in progress. As further corrective action, Entergy plans on submitting a revised criticality analysis to the NRC which would no longer credit boraflex panels in the pool for criticality control. Preparation of this submittal was in progress during the inspection and was discussed with engineering personnel.

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Enclosure

.3 Annual Sample: 32 Battery Charger Over-Voltage Shutdown

a. Inspection Scope The inspectors performed an in-depth review of Entergy's evaluations and corrective actions associated with CR-IP3-2012-03335 and apparent cause evaluation (ACE) for 32 battery charger over-voltage shutdown. The CR documented on October 17, 2012, that the 32 battery charger auto-tripped on high voltage while adjusting the equalizing charge voltage potentiometer. The voltage adjustment caused a spike in the charger output voltage causing the battery charger to automatically shutdown. Operations entered TS allowed outage time (AOT) 3.8.4, Condition B, at 12:02 p.m., for having the 32 battery charger inoperable. During the time the charger was shutdown, Equipment Out of Service quantitative risk assessment tool was orange in aggregate with other equipment OOS for approximately 12 minutes. The charger was restored at 12:14 p.m., per procedure 3-SOP-EL-033, at which time Operations exited the associated AOT.

The inspectors assessed Entergy’s problem identification threshold, problem analysis, extent of condition reviews, compensatory actions, and the prioritization and timeliness of Entergy's corrective actions to determine whether Entergy was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Entergy's CAP and 10 CFR 50, Appendix B, Criterion XVI, “Corrective Action.” In addition, the inspectors reviewed documentation associated with this issue, including ACE, operability determination, and revised surveillance procedures and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions to complete full resolution of the issue.

b. Findings and Observations No findings were identified. The inspectors found that Entergy took appropriate actions to identify the direct and apparent cause of the issue. The direct cause of the issue was a spike in the charger output voltage. The apparent cause was determined to be an unanticipated degradation of the float/equalize toggle switch due to normal environmental factors. Entergy replaced the toggle switch in a timely manner as well as replaced the equalize adjustment potentiometer as a precaution, although no defects were found. Entergy also performed an extent of condition review for this condition as it applies to Unit 3 Battery Chargers 31, 33, 34, and 35 as they have toggle switches which are likely original equipment. Entergy revised the battery charger PM procedures to include checks of the float/equalize toggle switch. Lastly, Entergy revised management expectations to require operator monitoring of battery charger voltage when on equalize charge.

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Enclosure

The inspector determined Entergy’s overall response to the issue was commensurate with the safety significance, was timely, and the actions taken and planned were reasonable to resolve the failure of the float/equalize toggle switch.

.4 Semi-Annual Trend Review

a. Inspection Scope The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, “Problem Identification and Resolution,” to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Entergy outside of the CAP, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed Entergy’s CAP database for the third and fourth quarters to assess trends in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed Entergy’s Operational Excellence, Management Review Meeting package dated June 5, 2014, to check issues that are the focus of Entergy management reviews.

b. Findings and Observations No findings were identified. The inspectors observed that Entergy documented adverse conditions in the CAP at a very low threshold and verified on a sampling basis that these issues were addressed within the scope of the CAP. For example, the inspectors noted that Entergy conducted weekly reviews of maintenance completion effectiveness. The inspectors also observed that operational issues were tracked and reviewed by management on a frequency commensurate with risk. The inspectors observed an apparent increase in the number of issues related to procedure clarity or adherence during the refueling outage. Examples include a fuel contacting fuel event (CR-IP2-2014-1462) caused in part, by weak procedure guidance for incorporating fuel handling deviation reports into fuel move sheets; incomplete documentation of a TS surveillance identified by the inspectors and documented by Entergy in CR-IP2-2014-2459; and inadequate procedure controls during outage maintenance which allowed plant operators to not be knowledgeable of RCS status, identified by the inspectors and documented in Inspection Report 50-247/2014-002 (CR-IP2-2014-1986). When identified to Entergy, short term actions were taken and long term resolution of these issues was being evaluated in Entergy’s CAP at the end of the inspection period.

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Enclosure

4OA3 Follow Up of Events and Notices of Enforcement Discretion (71153 – 2 samples)

(Closed) Licensee Event Reports (LERs) 05000247 and 05000286/2012-007-00: Technical Specification (TS) Prohibited Condition Due to Diesel Generator Reserve Fuel Oil Storage Tank Total Particulates Not Within Limits for Greater Than TS Allowed Outage Time

On August 20, 2012, Entergy Nuclear Operations identified an event regarding a TS prohibited condition due to the emergency diesel generator reserve fuel oil storage tank (RFOST) total particulates not within limits for greater than the TS allowed outage time. Indian Point Units 2 and 3 emergency diesel generator RFOST fuel oil sample particulate results taken on June 17, 2011 (13.4 mg/l), and December 1, 2011 (13.2 mg/l) exceeded the TS limit of 10 mg/l. This condition meets the reporting criteria because fuel oil samples showed total particulates that were not within the allowable value per TS 5.5.11 for Unit 2 and TS 5.5.12 for Unit 3. Additionally, the results of a November 18, 2011, sample from the 22 fuel oil storage tank (FOST) were provided to Indian Point on December 7, 2011, yet were apparently not reviewed by Chemistry staff and were not entered into the Chemistry Database. The out of spec fuel oil conditions for the sample results received in July and December 2011 were not adequately addressed in 30 days and the required TS actions not taken nor were actions taken for the vendor analysis on March 15, 2012 and April 18, 2012, which is a TS prohibited condition reportable under 10 CFR 50.73(a)(2)(i)(B). This represents a licensee-identified Green non-cited violation, and the enforcement aspects of this issue were communicated to Entergy in a letter dated April 29, 2014 (ADAMS Accession number ML14118A124). This LER is closed.

4OA5 Other Activities .1 Follow Up on Traditional Enforcement Actions Including Violations, Deviations,

Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders (Inspection Procedure 92702)

a. Inspection Scope

On August 24, 2011, the NRC issued a Confirmatory Order (EA-11-096) to Entergy Operations Inc., and Entergy Nuclear Operations, Inc. (collectively referred to as Entergy). The Confirmatory Order actions were agreed upon by Entergy and the NRC during an alternative dispute resolution session held on July 18, 2011, to resolve NRC concerns regarding an apparent violation of employee protection requirements at the River Bend Station. The actions focused on reorganizing the Quality Control reporting relationships, ensuring adequate training of 10 CFR 50.7, “Employee Protection,” and performing an effectiveness review of the Employee Concerns Program (ECP) procedures at all Entergy facilities.

By letter dated August 23, 2012, Entergy notified the NRC of the actions that had been taken in response to the requirements imposed by the Confirmatory Order. Accordingly, during the week of April 29, 2013, NRC staff from the Office of Enforcement and

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Enclosure

Region IV performed an inspection at the River Bend Station to assess the specific actions identified in Entergy’s response letter. NRC staff also verified implementation of the remaining actions required to satisfy the conditions set forth in the Confirmatory Order for all Entergy sites. Subsequent to this inspection, NRC staff continued to interact with Entergy regarding the adequacy of the corrective and preventive actions related to the underlying discriminatory issue.

b. Findings and Observations

No findings were identified. During the follow-up inspection, the NRC staff reviewed Entergy’s ECP supervisory training and general employee training documents, the relevant “lessons learned” from the facts of this matter, and the fleet-wide written communication reinforcing Entergy’s commitment to maintaining a safety conscious work environment.

The NRC staff also reviewed the General Employee Training and Supervisory Training modules. Based on these reviews, it was determined that these training modules adequately addressed employee protection and included insights from the underlying discriminatory matter. The NRC staff determined that the supervisory training module appeared complete and included case studies as well as the specific elements from the underlying §50.7 “Employee Protection,” violation. Additionally, NRC staff evaluated the results of Entergy’s effectiveness review of ECP enhancements and the associated training that arose from the corrective actions taken to address this matter. Based on the results of this evaluation it was determined that Entergy had performed the requisite reviews at each station including: examination of selected ECP Case Files, Records Retention, Concerned Individual Follow Up, and ECP Coordinator Training. Within the areas examined, no findings were identified and in general it was determined that Entergy had adequately performed the effectiveness review of ECP procedural enhancements and the ECP training related to this matter.

During the follow-up review of the Quality Control/Quality Assurance reporting relationship, it was determined that Entergy’s response did not ensure that persons performing the quality assurance function of receipt inspection reported to a management level sufficient to maintain organizational freedom and independence from cost and schedule were maintained. Subsequent to the identification of this performance issue, which affected the implementation of the quality assurance program at all nine Entergy sites, the condition was entered into Entergy’s CAP as CR-HQN-2013-00466. Following the identification of this issue, additional discussions were held between NRC and Entergy to clarify the intent of the settlement agreement and subsequent Confirmatory Order stemming from the earlier alternate dispute resolution mediation. As a result of these discussions, Entergy’s Corporate Licensing organization developed a fleet reconciliation plan to modify Entergy’s Quality Assurance Program Manual to require that individuals performing inspections in accordance with Quality Assurance Program Manual, Section B.12, “Inspection,” functionally report to the associated manager responsible for Quality Assurance. As described in the corrective actions

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Enclosure

associated with CR-HQN-2013-00466, the affected individuals were those requiring certification in accordance with Quality Assurance Program Manual, Table 1, Regulatory Commitments, Section G, Regulatory Guide 1.58, Revision 1, “Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel,” dated September 1980. In addition to revising the applicable provisions in the Quality Assurance Program Manual, corrective actions were initiated to revise implementing procedures to reflect the change in reporting relationship during the performance of required inspections as well as providing training to the affected individuals. The NRC staff confirmed that the remaining conditions of the Confirmatory Order were adequately addressed. Based on the above reviews, the NRC determined that Entergy properly implemented the conditions specified in the Confirmatory Order and the associated actions were adequately implemented.

.2 On-Site Elevated Tritium in Groundwater (April 2014)

a. Inspection Scope

The inspectors conducted on-site reviews (April 29 – 30, 2014, and June 2 – 6, 2014) of CR-IP2-2014-02564 dated April 9, 2014, which documented elevated tritium concentrations and trace indications of Co-58 and Cr-51 in groundwater samples taken from monitoring wells (MW)-31 and MW-32 in late March 2014. Later Entergy data also indicated elevated tritium levels in MW-30. These three wells are located near the Unit 2 spent fuel pool.

b. Findings and Observations

No findings were identified. In early April 2014, Entergy identified unexpected increased tritium concentrations in the ground water monitoring wells located near the Unit 2 spent fuel pool (maximum of 687,000 pCi/L). Based on the confirmed measurement results, a multi-discipline investigation team was organized to identify the cause. Initial Entergy reviews indicated that the increased ground water radioactivity was recent reactor water, and ground water concentration appeared to quickly decrease based on weekly ground water sampling data. Entergy is currently working with contract hydrogeologists and plant staff to further characterize the source of the subsurface contamination and conduct systematic reviews of potential refueling outage related work activities and reactor water flooded components to determine the cause of the ground water contamination. By June 9, 2014, levels in all three wells had decreased (maximum of 250,000 pCi/L). The current on-site ground water contamination condition is expected to slowly migrate to the Hudson River and represents a negligible dose impact to the public. The NRC is closely following Entergy’s investigation and plans additional future inspection activities of this concern.

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Enclosure

.3 Institute of Nuclear Power Operations (INPO) Report Review

a. Inspection Scope

The inspectors reviewed the final report for the INPO plant assessment of Indian Point Units 2 and 3, conducted in December 2013. The inspectors reviewed the report to ensure that any issues identified were consistent with NRC perspectives of Entergy performance and to determine if INPO identified any significant safety issues that required further NRC follow up.

b. Findings

No findings were identified. 4OA6 Meetings, Including Exit

On July 17, 2014, the inspectors presented the inspection results to Mr. John Ventosa, Site Vice President, and other members of the Entergy staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT: SUPPLEMENTARY INFORMATION

A-1

Attachment

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT Entergy Personnel N. Azevedo, Code Programs Supervisor S. Bianco, Operations Fire Marshall R. Burroni, Engineering Director T. Chan, Mechanical Systems Supervisor D. Dewey, Assistant Operations Manager J. Dinelli, General Manager Plant Operations R. Dolanksy, ISI Program Manager R. Drake, Civil Design Engineering Supervisor J. Ferrick, Production Manager D. Gagnon, Security Manager D. Gray, Chemistry Supervisor F. Inzirillo, Training Manager F. Kich, Performance Improvement Manager J. Kirkpatrick, Director, Regulatory and Performance Improvement D. Mayer, Unit 1 Director B. McCarthy, Operations Manager M. Miele, Emergency Planning Manager F. Mitchell, Radiation Protection Manager J. Spagnulo, Maintenance Manager M. Tesoriero, System Engineering Manager M. Troy, Quality Assurance Manager J. Ventosa, Site Vice President R. Walpole, Regulatory Assurance Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED Closed 05000247 and 05000286/ LER Technical Specification (TS) Prohibited Condition 2012-007-00 Due to Diesel Generator Reserve Fuel Oil (FO) Storage Tank Total Particulates Not Within Limits for Greater Than TS Allowed Outage Time

(Section 4OA3)

LIST OF DOCUMENTS REVIEWED Common Documents Used Indian Point Unit 2, Updated Final Safety Analysis Report Indian Point Unit 2, Individual Plant Examination Indian Point Unit 2, Individual Plant Examination of External Events Indian Point Unit 2, Technical Specifications and Bases Indian Point Unit 2, Technical Requirements Manual

A-2

Attachment

Indian Point Unit 2, Control Room Narrative Logs Indian Point Unit 2, Plan of the Day Section 1R01: Adverse Weather Protection Procedures IP-SMM-OP-104, Offsite Power Continuous Monitoring and Notification, Revision 13 Maintenance Orders/Work Orders 344056 344057 344058 344059 344060 Section 1R04: Equipment Alignment Procedures 2-PC-EM11-2, No. 23 AFP Run-Out Protection Instruments, Revision 9 3-SOP-V-004, Control Room Heating, Ventilation, and Air Conditioning System, Revision 20 Condition Reports (CR-IP2-) 2014-3398 Condition Reports (CR-IP3-) 2014-1176 Maintenance Orders/Work Orders 52393635-01 Miscellaneous Central Control Room HVAC System Health Report Q4-2013 Section 1R05: Fire Protection Procedures EN-DC-161, Control of Combustibles, Revision 10 0-PT-M004, Fire Extinguisher Inspection, Revision 8 SEP-FPP-IP-001, IPEC Fire Protection Program Plan, Revision 3 Condition Reports (CR-IP3-) 2014-01366 2014-01371 Maintenance Orders/Work Orders 52557706 379978 Drawings 9321-F-24403 Miscellaneous IP3-CALC-FP-02795, Combustible Loading Calculation for IP3 Fire Hazards Analysis,

Revision 0 IP3-ANAL-FP-02143, Fire Hazards Analysis Report, Revision 5

A-3

Attachment

IP3-ANAL-FP-01503, Appendix R, Sections III.G and III.L, Safe-Shutdown Analysis Report, Revision 3

Safety Evaluation Report, 1/7/1987, Indian Point, Unit 3, Exemption from the Technical Requirements of Sections III.G. and III.J. of Appendix R to 10 CFR 50 based on a reanalysis of fire protection program (ML003779008)

Section 1R06: Flood Protection Measures Procedures 0-ELC-418-GEN, Manhole Inspections, Revision 4 Condition Reports (CR-IP2-) 2014-2574 Condition Reports (CR-IP3-) 2014-0732 2014-0259 2013-4237 Maintenance Orders/Work Orders 52039796-01 52542959-01 52551509-01 Drawings 9321-F3090-7 Section 1R07: Heat Sink Performance Maintenance Orders/Work Orders 52420230-01 Section 1R12: Maintenance Effectiveness Condition Reports (CR-IP2-) 2013-4634 2013-2696 Condition Reports (CR-IP3-) 2011-4746 Section 1R15: Operability Determinations and Functionality Assessments Condition Reports (CR-IP3-) 2014-0957 Section 1R19: Post-Maintenance Testing Procedures 0-HTX-405-EDG, EDG Lube Oil and Jacket Water Heat Exchanger Maintenance, Revision 4 EN-WM-107, Post Maintenance Testing, Revision 4 Condition Reports (CR-IP2-) 2010-5446 2013-1656 2013-2630 2014-1144 2014-2045 2014-2278

A-4

Attachment

Condition Reports (CR-IP3-) 2014-0957 2014-1341 2014-2273 Maintenance Orders/Work Orders 255053 305669-03 347520-02 350509 351625-02 357068-03 372137-04 52202986-02 52294982-05 52330324-06 52330324-11 52330324-13 52330324-16 52369817-01 52516084-01 52527202-04 52527204-03 52527583-03 Drawings 9321-LL-3118 Shts 2, 3, 3B, 7 Section 1R22: Surveillance Testing Procedures 3-PT-Q120B, 32 ABFP (Turbine Driven) Surveillance and IST, Revision 23 Condition Reports (CR-IP3-) 2014-0720 2014-0727 2014-00786 Maintenance Orders/Work Orders 52550775-01 Miscellaneous IP3-DBD-303, AFW Design Basis Document, Revision 4 SEP-IP3-IST-1, IP3 Inservice Testing Program Plan, Revision 2 SEP-IP3-IST-2, IP3 Inservice Testing Program Plan, Revision 1 Section 1EP6: Drill Evaluation Condition Reports (CR-IP3-) 2014-01267 Miscellaneous IPEC Emergency Planning Drill/Exercise Controller/Evaluator/Observer Binder for June 3, 2014 Section 2RS7: Radiological Environmental Monitoring Program Procedures 0-CY-1900, REMP Sampling and Analysis Program, Revision 0 0-CY-1980, Preparation, Placement, and Collection of Site Environmental TLDs, Revision 0 0-CY-1920, REMP Land Use Census, Revision 0 Condition Reports (CR-IP3-) 2014-01257 Miscellaneous 2013 Annual Radiological Operating Report Exelon PowerLabs Gas Meter Certificates of Calibration

A-5

Attachment

Indian Point Energy Center, Units 1, 2 and 3, Offsite Dose Calculation Manual, Revision 4 Memorandum: Results of 2013 Annual Land Use Census, April 28, 2014 Meteorological Tower Semi-Annual Sensor Calibration, April 23, 2014 Teledyne Brown Engineering Environmental Services Annual 2013 Quality Assurance Report Section 4OA2: Problem Identification and Resolution Procedures 3-IC-PM-I-E-32BC, 32 Battery Charger Preventative Maintenance, Revision 3 3-IC-PM-I-E-35BC, 35 Battery Charger Preventative Maintenance, Revision 3 3-PC-OL27H, Bus 6A 480 Volt Undervoltage Relays Inspection and Calibration, Revision 2 EN-LI-102, Corrective Action Process, Revision 23 PFM-82, BCT-2000 Battery Test Computer Calibration, September 10, 1999, Revision 5 PFM-82, BCT-2000 Battery Test Computer Calibration, January 29, 2013, Revision 5 Condition Reports (CR-IP2-) 2009-3820 2014-0720 Condition Reports (CR-IP3-) 2008-0293 2011-00433 2012-03242 2012-03335 Maintenance Orders/Work Orders 00329979 52308424 052308446 Miscellaneous Indian Point 2 – Amendment: Credit for Soluble Boron and Burnup in Spent Fuel Pit,

May 29, 2002 NET-173-01, Criticality Analysis Soluble Boron and Burnup Credit in the Indian Point Unit 2

Spent Fuel Storage Racks, Attachment to LAR 01-010, September 20, 2001 Entergy document: Fuel Assembly Info In Affected Cell Locations.pdf (May 20, 2014) Letter to James Willoughby, Entergy Northeast; Indian Point Unit 2 Cycle 21 Core

Component/Fuel Assembly Storage Compatibility Analysis (PDM-11-105); dated December 13, 2011 (Westinghouse Proprietary)

Curtis Wright/NETCO letter to Giancarlo Delfini, Entergy Nuclear Northeast dated February 14, 2014; Extent of condition of IP2 Boraflex Degradation and Guidance for Future Moves

Section 4OA3: Follow Up of Events and Notices of Enforcement Discretion Condition Reports CR-IP2-2012-04132 CR-IP2-2012-04164 CR-IP3-2012-01914 CR-IP3-2012-01939 Section 4OA5: Other Activities Procedures EN-MP-120, Material Receipt, Revision 7 EN-MP-121, Materials, Purchasing and Contracts Indoctrination and Training, Revision 5

A-6

Attachment

EN-MP-138, Commercial Grade Dedication Lab Conduct of Operation, Revision 1 EN-QV-100, Conduct of Nuclear Oversight, Revision 9 EN-QV-111, Training and Certification of Inspection/Verification and Examination Personnel,

Revision 13 Condition Reports CR-HQN-2013-00466 CR-HQN-2011-00979 Miscellaneous Entergy Quality Assurance Program Manual, Revision 25 Entergy Nuclear Lesson Plan FCBT-GET-PATSS, Revision 16 Entergy Nuclear Safety Culture Assessment 2012 Survey, April 30, 2013 Evaluation of Indian Point Energy Center, Final Report, December 2013

LIST OF ACRONYMS

10 CFR Title 10 of the Code of Federal Regulations ABFP auxiliary boiler feedwater pump AC alternating current ACE apparent cause evaluation ADAMS Agencywide Document Access and Management System AOT allowed outage time CAP corrective action program CCW component cooling water CAOR criticality analysis of record CR condition report CRACS control room air conditioning system ECP Employee Concerns Program EDG emergency diesel generator Entergy Entergy Nuclear Northeast INPO Institute of Nuclear Power Operations IST inservice testing kV kilovolt MW monitoring well NRC Nuclear Regulatory Commission ODCM offsite dose calculation manual OOS out of service PM preventive maintenance RCP reactor coolant pump RCS reactor coolant system REMP radiological environmental monitoring program SCFM standard cubic feet per minute SI safety injection SIP safety injection pump SSC structure, system, and component TI temporary instruction TLD thermoluminescent dosimeter TS technical specification UFSAR updated final safety evaluation report WO work order