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Category:Inspection Report
MONTHYEARIR 05000255/20230032023-10-0404 October 2023 NRC Inspection Report No. 05000255/2023003(DRSS)-Holtec Decommissioning International, LLC, Palisades Nuclear Plant IR 05000255/20230022023-07-19019 July 2023 NRC Inspection Report 05000255/2023002 DRSS-Holtec Decommissioning International, LLC, Palisades Nuclear Plant IR 05000255/20220032022-12-28028 December 2022 NRC Inspection Report No. 05000255/2022003(DRSS); 07200007/2022001 (Drss) Holtec Decommissioning International, LLC, Palisades Nuclear Plant IR 05000255/20224012022-11-0909 November 2022 Decommissioning Palisades Nuclear Plant - Decommissioning Security Inspection Report 05000255/2022401 IR 05000255/20220022022-08-0303 August 2022 Integrated Inspection Report 05000255/2022002 IR 05000255/20220012022-05-13013 May 2022 Integrated Inspection Report 05000255/2022001 IR 05000255/20220102022-04-0101 April 2022 Triennial Inspection of Evaluation of Changes, Tests and Experiments Baseline Inspection Report 05000255/2022010 IR 05000255/20210062022-03-0202 March 2022 Annual Assessment Letter for Palisades Nuclear Plant, Unit 1, (Report 05000255/2021006) IR 05000255/20210102022-02-24024 February 2022 Triennial Fire Protection Inspection Report 05000255/2021010 IR 05000255/20210042022-02-0808 February 2022 Integrated Inspection Report 05000255/2021004 and Exercise of Enforcement Discretion IR 05000255/20214042021-11-15015 November 2021 NRC Independent Spent Fuel Storage Installation Security Inspection Report 05000255/2021404 and 07200007/2021401 IR 05000255/20210032021-11-0303 November 2021 Integrated Inspection Report 05000255/2021003 IR 05000255/20214032021-10-21021 October 2021 Material Control and Accounting Program Inspection Report 05000255/2021403 IR 05000255/20214022021-10-0606 October 2021 Security Baseline Inspection Report 05000255/2021402 IR 05000255/20210052021-09-0101 September 2021 Updated Inspection Plan for Palisades Nuclear Plant (Report 05000255/2021005) IR 05000255/20210022021-08-10010 August 2021 Integrated Inspection Report 05000255/2021002 ML21197A0322021-07-21021 July 2021 Review of the Fall 2020 Steam Generator Tube Inspection Report IR 05000255/20210012021-05-12012 May 2021 Integrated Inspection Report 05000255/2021001 IR 05000255/20214012021-04-14014 April 2021 Security Baseline Inspection Report 05000255/2021401 IR 05000255/20200062021-03-0404 March 2021 Annual Assessment Letter for Palisades Nuclear Plant (Report 05000255/2020006) IR 05000255/20200042021-02-11011 February 2021 Integrated Inspection Report 05000255/2020004 IR 05000255/20204012021-01-0606 January 2021 Security Baseline Inspection Report 05000255/2020401 ML20342A1812020-12-10010 December 2020 Security Inspection Report Cover Letter 05000255/2020420 IR 05000255/20204202020-12-10010 December 2020 Security Inspection Report 05000255/2020420 IR 05000255/20204022020-11-30030 November 2020 Cyber Security Inspection Report 05000255/2020402 IR 05000255/20205012020-11-20020 November 2020 Emergency Preparedness Inspection Report 05000255/2020501 IR 05000255/20200032020-11-13013 November 2020 Integrated Inspection Report 05000255/2020003 IR 05000255/20200052020-09-0101 September 2020 Updated Inspection Plan for Palisades Nuclear Plant (Report 05000255/2020005) IR 05000255/20200102020-08-24024 August 2020 Biennial Problem Identification and Resolution Inspection Report 05000255/2020010 IR 05000255/20203012020-08-13013 August 2020 NRC Initial License Examination Report 05000255/2020301 IR 05000255/20200022020-08-11011 August 2020 Integrated Inspection Report 05000255/2020002 and Exercise of Enforcement Discretion IR 05000255/20010082020-05-12012 May 2020 Final ASP Analysis - Palisades (IR 050002552001008) IR 05000255/20200012020-05-12012 May 2020 Integrated Inspection Report 05000255/2020001 IR 05000255/20200112020-04-21021 April 2020 Design Basis Assurance Inspection (Teams) Inspection Report 05000255/2020011 IR 05000254/20204012020-03-23023 March 2020 Security Baseline Inspection Report 05000254/2020401 and 05000265/2020401 IR 05000255/20190062020-03-0303 March 2020 Annual Assessment Letter Palisades Nuclear Plant (Report 05000255/2019006) IR 05000255/20190042020-01-28028 January 2020 Integrated Inspection Report 05000255/2019004 and 07200007/2019001 ML19357A2752019-12-23023 December 2019 Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000255/2020011 IR 05000255/20190112019-11-27027 November 2019 Triennial Inspection of Evaluation of Changes, Tests and Experiments Baseline Inspection Report 05000255/2019011 IR 05000255/20194112019-11-25025 November 2019 Security Baseline Inspection Report 05000255/2019411 and Independent Spent Fuel Storage Security Inspection Report 07200007/2019401 (Cover Letter Only) (DRS-M.Ziolkowski) IR 05000255/20190032019-11-14014 November 2019 Integrated Inspection Report 05000255/2019003 IR 05000255/20190102019-10-29029 October 2019 Reissue - Palisades Nuclear Plant - Design Basis Assurance Inspection (Programs) Inspection Report 05000255/2019010 ML19294A2872019-10-21021 October 2019 Design Basis Assurance Inspection (Programs) Inspection Report 05000255/2019010 IR 05000255/20190052019-08-28028 August 2019 Updated Inspection Plan for Palisades Nuclear Plant, Unit 1 (Report 05000255/2019005) ML19210D4022019-07-29029 July 2019 Ltr. 07/29/19 Palisades Nuclear Plant - Information Request for NRC Triennial Evaluations of Changes, Tests, and Experiments (50.59) Baseline Inspection; Inspection Report 05000255/2019011 (DRS-D.Szwarc) IR 05000255/20190022019-07-26026 July 2019 Integrated Inspection Report 05000255/2019002 IR 05000255/20194102019-06-0404 June 2019 NRC Security Baseline Inspection Report 05000255/2019410 (Cover Letter Only) (DRS-N.Egan) IR 05000255/20190012019-05-10010 May 2019 Errata - Palisades Nuclear Plant, Unit 1 - NRC Integrated Inspection Report 05000255/2019001 ML19123A1742019-05-0303 May 2019 NRC Integrated Inspection Report 05000255/2019001 IR 05000255/20150032019-04-11011 April 2019 Errata - Palisades Nuclear Plant, NRC Integrated Inspection Report 05000255/2015003 (DRS-K.Stoedter) 2023-07-19
[Table view] Category:Inspection Report Correspondence
MONTHYEARIR 05000255/20224012022-11-0909 November 2022 Decommissioning Palisades Nuclear Plant - Decommissioning Security Inspection Report 05000255/2022401 ML18221A4862018-08-0909 August 2018 Ltr. 08/09/18 Quad Cities Nuclear Power Station, Units 1 and 2 - Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information; Inspection Report 05000254/2018004; 05000265/2018004 (DRS-A.Dunlop) ML17075A0372017-03-15015 March 2017 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000255/2017002 PNP 2016-020, ADR Meeting (EA-15-039) to Discuss Apparent Violations in IR 3-2012-0212016-03-22022 March 2016 ADR Meeting (EA-15-039) to Discuss Apparent Violations in IR 3-2012-021 PNP 2016-018, Extension Request for Determination of Denial of Non-Cited Violation2016-03-11011 March 2016 Extension Request for Determination of Denial of Non-Cited Violation PNP 2015-056, Readiness for 95001 Inspection2015-07-20020 July 2015 Readiness for 95001 Inspection IR 05000255/20114032011-04-0404 April 2011 IR 05000255-11-403(DRS); 02/28/2011 - 03/04/2011; Palisades Nuclear Plant; Routine Security Baseline Inspection - Cover Letter ML1008805162010-03-26026 March 2010 Ltr. 03/26/10 Palisades Heat Sink Performance Inspection Request for Information IR 05000255/20094062010-01-11011 January 2010 IR 05000255-09-406, (Drs), on 05/27/2009 - 12/15/2009, Palisades Nuclear Plant, Temporary Instruction 2201/002 Inspection - Cover Letter IR 05000255/20082012009-11-17017 November 2009 IR 05000255-08-201, on 07/31/2009, Palisades Nuclear Plant - NRC Security Baseline Inspection Report ML0928002302009-10-0202 October 2009 Information Request IR 05000255/20070082008-01-24024 January 2008 IR 05000255-07-008, on 11/26/2007 - 12/12/2007, Palisades, Evaluation of Changes, Tests, or Experiments (10 CFR 50.59) and Permanent Plant Modifications ML0731205002007-11-0606 November 2007 IR 05000255-07-404, (Rs), 08/27/2007 - 08/31/2007, 10/23/2007, Palisades Nuclear Plant, Routine Secutiry Baseline Inspection - Cover Letter Only IR 05000255/20052022007-10-0303 October 2007 Letter to Mr. Schwarz Palisades Nuclear Plant - NRC Material Control and Accounting Program Inspection Report No. 05000255/2005202 IR 05000255/20064012006-10-26026 October 2006 IR 05000255-06-401(DRS) on 09/11/2006 - 09/15/2006 for Palisades Nuclear Plant; Routine Security Baseline Inspection IR 05000255/20060102006-08-21021 August 2006 IR 05000255-06-010(DRS); 07/10/2006 - 07/14/2006; Palisades Nuclear Plant; Routine Security Baseline Inspection - Cover Letter IR 05000255/20060042006-07-28028 July 2006 IR 05000255-06-004, on 04/01/2006 - 06/30/2006, Palisades IR 05000255/20010172002-02-22022 February 2002 IR 05000255/2001-017 on 12/30/2001 - 02/09/2002, Nuclear Management Company, LLC, Palisades Nuclear Generating Plant. Non-routine Evolutions, Post Maintenance Testing, Human Performance, and Corrective Actions. Non-cited Violations Noted IR 05000255/20010162002-01-11011 January 2002 IR 05000255/2001-016, Palisades Nuclear Generating Plant, Inspection on 11/20/2001 - 12/29/2001 Related to Adverse Weather Protection and Heat Sink Performance. Three Issues of Very Low Safety Significance Identified 2022-11-09
[Table view] Category:Letter
MONTHYEARML24022A1172024-01-23023 January 2024 Acceptance of Requested Licensing Action Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations ML24012A2422024-01-16016 January 2024 Acceptance of Requested Licensing Action License Transfer Request ML23236A0042023-12-27027 December 2023 Issuance of Amendment 274 Re Changes to Perm Defueled Emergency Plan and Perm Defueled Emergency Action Level Scheme ML23355A1242023-12-26026 December 2023 Withdrawal of an Amendment Request Re License Amendment Request to Revise License Condition to Eliminate Cyber Security Plan Requirements ML23192A0772023-12-26026 December 2023 Letter Exemption from the Requirements of 10 CFR 140.11(a)(4) Concerning Offsite Primary and Secondary Liability Insurance ML23191A5222023-12-22022 December 2023 Exemption Letter from the Requirements of 10 CFR 50.54(W)(1) Concerning Onsite Property Damage Insurance (EPID - L-2022-LLE-0032) ML23263A9772023-12-22022 December 2023 Exemption from Certain Emergency Planning Requirements and Related Safety Evaluation ML23354A2602023-12-21021 December 2023 Reference Simulator Inspection Request for Information L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 PNP 2023-030, License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations2023-12-14014 December 2023 License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations PNP 2023-035, Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements2023-12-12012 December 2023 Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements PNP 2023-028, Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments2023-12-0606 December 2023 Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23291A4402023-11-0303 November 2023 Acceptance of Requested Licensing Action Request for Exemption from 10 CFR 50.82(a)(2) to Support Reauthorization of Power Operations IR 05000255/20230032023-10-0404 October 2023 NRC Inspection Report No. 05000255/2023003(DRSS)-Holtec Decommissioning International, LLC, Palisades Nuclear Plant ML23275A0012023-10-0202 October 2023 Request for Withholding Information from Public Disclosure for Palisades Nuclear Plant PNP 2023-025, Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.822023-09-28028 September 2023 Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82 PNP 2023-026, Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations2023-09-28028 September 2023 Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations PNP 2023-023, Special Report High Range Noble Gas Monitor Inoperable2023-08-0909 August 2023 Special Report High Range Noble Gas Monitor Inoperable ML23215A2302023-08-0303 August 2023 Notice of Organization Change - Chief Nuclear Officer IR 05000255/20230022023-07-19019 July 2023 NRC Inspection Report 05000255/2023002 DRSS-Holtec Decommissioning International, LLC, Palisades Nuclear Plant ML23087A0362023-05-0202 May 2023 PSDAR Review Letter ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment PNP 2023-018, 2022 Annual Non-Radiological Environmental Operating Report2023-04-25025 April 2023 2022 Annual Non-Radiological Environmental Operating Report L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 PNP 2023-007, and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports2023-04-19019 April 2023 and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports PNP 2023-008, 2022 Radiological Environmental Operating Report2023-04-18018 April 2023 2022 Radiological Environmental Operating Report L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations PNP 2023-002, 6 to Updated Final Safety Analysis Report2023-03-31031 March 2023 6 to Updated Final Safety Analysis Report ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance PNP 2023-006, Report of Changes to Security Plan, Revision 202023-03-29029 March 2023 Report of Changes to Security Plan, Revision 20 PNP 2023-012, Presentation on Regulatory Path to Reauthorize Power Operations2023-03-16016 March 2023 Presentation on Regulatory Path to Reauthorize Power Operations ML23038A0982023-03-15015 March 2023 Request for Withholding Information from Public Disclosure ML23095A0642023-03-14014 March 2023 American Nuclear Insurers, Notice of Cancellation Rescinded PNP 2023-001, Regulatory Path to Reauthorize Power Operations2023-03-13013 March 2023 Regulatory Path to Reauthorize Power Operations PNP 2023-004, Report of Changes to Palisades Nuclear Plant Technical Specification Bases2023-03-0808 March 2023 Report of Changes to Palisades Nuclear Plant Technical Specification Bases PNP 2023-005, Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report2023-03-0101 March 2023 Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML23052A1092023-02-17017 February 2023 FEMA Letter to NRC, Proposed Commission Paper Language for Palisades Nuclear Plant Emergency Plan Decommissioning Exemption Request ML23032A3992023-02-0101 February 2023 Regulatory Path to Reauthorize Power Operations IR 05000255/20220032022-12-28028 December 2022 NRC Inspection Report No. 05000255/2022003(DRSS); 07200007/2022001 (Drss) Holtec Decommissioning International, LLC, Palisades Nuclear Plant L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 PNP 2022-037, Report of Changes to Security Plan, Revision 192022-12-14014 December 2022 Report of Changes to Security Plan, Revision 19 ML22321A2852022-11-17017 November 2022 LLC Master Decommissioning Trust Agreement for Palisades Nuclear Plant IR 05000255/20224012022-11-0909 November 2022 Decommissioning Palisades Nuclear Plant - Decommissioning Security Inspection Report 05000255/2022401 PNP 2022-036, Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2022-11-0808 November 2022 Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme PNP 2022-035, International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations2022-11-0202 November 2022 International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations PNP 2022-024, Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance PNP 2022-026, Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance ML22292A2572022-10-25025 October 2022 Permanently Defueled Emergency Plan License Amendment RAI Letter 2024-01-23
[Table view] |
Text
ary 24, 2008
SUBJECT:
PALISADES NUCLEAR PLANT NRC EVALUATION OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000255/2007008(DRS)
Dear Mr. Schwarz:
On December 12, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection findings which were discussed on December 12, 2007, with you and members of your staff.
Additional discussions were held with Mr. John Broschak and others via telephone conference on January 24, 2008.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions 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 the inspection, one NRC identified finding of very low safety significance was identified, which involved a violation of NRC requirements. However, because the violation was of very low safety significance and because it was entered into your corrective action program, the NRC is treating the issue as a Non-Cited Violation (NCV) in accordance with Section VI.A.1 of the NRCs Enforcement Policy.
If you contest the subject or severity of an NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Palisades Nuclear Plant.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
David E. Hills, Chief Engineering Branch 1 Division of Reactor Safety Docket No. 50-255 License No. DPR-20 Enclosure: Inspection Report 05000255/2007006 w/Attachment: Supplemental Information cc w/encl: M. Kansler, President and Chief Executive Officer/
Chief Nuclear Officer J. Herron, Senior Vice President Senior Vice President, Engineering and Technical Services M. Balduzzi, Senior Vice President and Chief Operating Officer, Regional Operations, NE O. Limpias, Vice President, Engineering J. Ventosa, General Manager, Engineering J. DeRoy, Vice President, Operations Support Director, NSA J. McCann, Director, Nuclear Safety & Licensing E. Harkness, Director of Oversight General Manager, Plant Operations C. Faison, Manager, Licensing L. Lahti, Manager, Licensing W. Dennis, Assistant General Counsel W. DiProfio W. Russell G. Randolph Supervisor, Covert Township Office of the Governor State Liaison Officer, State of Michigan Michigan Department of Environmental Quality -
Waste and Hazardous Materials Division Michigan Office of the Attorney General
SUMMARY OF FINDINGS
IR 05000255/2007008; 11/26/2007 - 12/12/2007; Palisades Nuclear Plant; Evaluation of
Changes, Tests, or Experiments (10 CFR 50.59) and Permanent Plant Modifications.
The inspection covered a two week announced baseline inspection on evaluations of changes, tests, or experiments and permanent plant modifications. The inspection was conducted by three regional based engineering inspectors.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector-Identified and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Non-Cited Violation (NCV) of 10 CFR Part 50,
Appendix B, Criterion III, Design Control requirements. Specifically, the licensee failed to incorporate a number of uncertainties when calculating the technical specification (TS) limits for the emergency diesel generator (EDG) fuel oil volume. This resulted in a non-conservative TS value. Once identified by the inspectors, the licensee issued a standing order in the SRO Shift Turnover Items Shift Checklist to ensure that adequate margin existed for the EDG seven-day fuel oil requirement to account for the uncertainties and planned to address the issue further through their corrective action process.
The finding was more than minor because the uncertainties were significant enough to necessitate additional calculations to ensure adequate fuel would be maintained in the diesel fuel tank. The issue was of very low safety significance based on Phase 1 screening in accordance with IMC 609.04, Phase 1 - Initial Screening and Characterization of Findings. Specifically, it was determined that at the time of the inspection, adequate fuel existed in the diesel fuel tank (T-10A)to meet the required mission time and the inspectors did not identify any previous instances in which the tank level had dropped too low. The inspectors determined that there were no cross-cutting aspects associated with this finding because the performance deficiency occurred greater than two years ago.
Licensee-Identified Violations
None
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R02 Evaluations of Changes, Tests, or Experiments
Main article: IP 71111.02
.1 Review of 10 CFR 50.59 Evaluations and Screenings
a. Inspection Scope
From November 26 through December 12, 2007, the inspectors reviewed seven evaluations performed pursuant to 10 CFR 50.59 to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 13 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. In regard to the changes reviewed where no 10 CFR 50.59 evaluation was performed, the inspectors verified that the changes did not meet the threshold to require a 10 CFR 50.59 evaluation. The evaluations and screenings were chosen based on risk significance, safety significance, and complexity. The list of documents reviewed by the inspectors is included as an attachment to this report.
The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.
b. Findings
None
1R17 Permanent Plant Modifications
Main article: IP 71111.17B
.1 Review of Permanent Plant Modifications
a. Inspection Scope
From November 26 through December 12, 2007, the inspectors reviewed eight permanent plant modifications that had been installed in the plant during the last two years. The modifications were chosen based upon risk significance, safety significance, and complexity. As per inspection procedure (IP) 71111.17B, one modification was chosen that affected the barrier integrity cornerstone. The inspectors reviewed the modifications to verify that the completed design changes were in accordance with the specified design requirements, and the licensing bases, and to confirm that the changes did not adversely affect any systems' safety function. Design and post-modification testing aspects were reviewed to ensure the functionality of the modification, its associated system, and any support systems. The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an attachment to this report.
b. Findings
Failure to Establish Correct Tech Spec Limits.
Introduction:
Green. The inspectors identified an NCV of 10 CFR 50 Part 50, Appendix B, Criterion III, Design Control, requirements in that the licensee failed to incorporate a number of uncertainties when establishing the technical specification (TS) limits for the diesel generator seven-day fuel oil volume requirements.
Description:
On December 10, 2007, the inspectors identified through the review of a modification package (EC9610) regarding operation of the EDGs with low sulfur content fuel, that the licensee had failed to incorporate various values of uncertainty into the calculations that determined the TS seven-day diesel fuel storage volume requirements.
The uncertainties included values associated with fuel variability (such as heat content),level instrumentation, transfer pump vortexing, unusable volume within the storage tank, and others. The failure to include uncertainty resulted in a TS value for the volume of diesel fuel which was less than that required to operate the EDG for the required mission based upon the licensees fuel consumption data.
The licensee was aware that they did not include some of these uncertainties in the calculation of the EDG fuel oil TS limit, but believed that surveillance procedure Proc No DWO-1 required EDG fuel oil tank T-10A level to be maintained at a level that provided adequate margin to address those uncertainties, including unusable volume. The inspectors reviewed Proc No DWO-1, revision 80, TS Surveillance Procedure and noted that the controls the licensee was relying on did not ensure that a level was maintained in tank T-10A to provide the uncertainty related margin, and did not take into consideration the 725 gallons of unusable volume in the tank.
After further review, the licensee concurred that insufficient controls were in place to preclude reducing tank level below that required to account for the uncertainties or unusable volume. As a result, the licensee added a standing order in the SRO Shift Turnover Items Shift Checklist to account for the uncertainties. The licensee opted to address this issue through an existing condition report (CR-PLP-2007-04259). Although, the existing condition report had already captured some limited aspects of the calculation uncertainty, it did not address much of the inspectors concern noted above.
As a result, implementation of additional controls was necessary after the inspectors identified the issue.
Analysis:
The inspectors determined that the failure to establish adequate TS limits for emergency diesel fuel oil volume was a performance deficiency warranting a significance determination. The inspectors concluded that the finding was greater than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Disposition Screening, because the finding met the criteria in IMC 0612, Appendix E, Examples of Minor Issues, Example 3j. Specifically, there was reasonable doubt on the operability of a system or component in that the uncertainties were significant enough to necessitate additional calculations to ensure adequate fuel would be maintained in the diesel fuel tank. The finding was determined to be of very low safety significance (Green) based on a Significance Determination Process (SDP)
Phase 1 determination that the finding was a design deficiency issue that did not result in a loss of operability of the EDGs because it was determined that at the time of the inspection, adequate fuel existed in the diesel fuel tank (T-10A) to meet the required mission time and the inspectors did not identify any previous instances in which tank level had dropped too low. The inspectors determined that there were no cross-cutting aspects associated with this finding because the performance deficiency occurred greater than two years ago.
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion III, Design Control requirements states, in part, that The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculation methods, or by the performance of a suitable testing program.
Contrary to the above, the licensees design control measures (calculations) failed to consider uncertainties associated with fuel variability, level instrumentation, transfer pump vortexing, and unusable volume within the storage tank. This resulted in the potential to have an insufficient fuel volume to support the seven-day mission Because of the very low safety significance of this finding and because the issue was entered into the licensee's corrective action program (CR-PLP-2007-04259), it is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000255/200700x-XX).
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
.1 Routine Review of Condition Reports
a. Inspection Scope
From November 26 through December 12, 2007, the inspectors reviewed eleven Corrective Action Program (CAP) documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions (CA) related to permanent plant modifications and evaluations for changes, tests, or experiments issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the team are listed in the attachment to this report.
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. C. Schwarz and others of the licensees staff, on December 12, 2007. Licensee personnel were asked to identify any documents, materials, or information provided during the inspection that were considered proprietary. No proprietary information was identified. In addition, a telephone re-exit was conducted on January 24, 2008 with Mr. John Broschak to discuss the NCV.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- C. Schwarz, Site Vice President
- A. Blind, Design Engineering Manager
- L. Lahti, Licensing Manager
- B. Kemp, Design Supervisor
- J. Erickson, Design Engineer
- B. Dotson, Technical Specialist
Nuclear Regulatory Commission
- J. Ellegood, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000255/2007008-01 NCV EDG Fuel Adequacy Calculation
Closed
- 05000255/2007008-01 NCV EDG Fuel Adequacy Calculation
Discussed
None Attachment
LIST OF DOCUMENTS REVIEWED