IR 05000255/2012004

IR 05000255-12-004, 07/01/12 - 9/30/12, Palisades Nuclear Plant, Maintenance Risk Assessments and Emergent Work Control; Operability Determinations and Functional Assessments

ML12319A093
Person / Time
Site:	Palisades
Issue date:	11/13/2012
From:	Jack Giessner Reactor Projects Region 3 Branch 4
To:	Vitale A Entergy Nuclear Operations
References
IR-12-004
Download: ML12319A093 (40)

Text

ber 13, 2012

SUBJECT:

PALISADES NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000255/2012004

Dear Mr. Vitale:

On September 30, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. The enclosed report documents the results of this inspection, which were discussed on October 12, 2012, 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 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 this inspection, three self-revealed findings of very low safety significance (Green) were identified. The findings involved violations of NRC requirements.

However, because of their very low safety significance, and because the issues were entered into your corrective action program, the NRC is treating these issues as non-cited violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the subject or severity of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Palisades Nuclear Plant.

If you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Palisades Nuclear Plant.

A.Vitale -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Document Access and Management System (ADAMS).

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

Sincerely,

/RA/

John B. Giessner, Chief Branch 4 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 05000255/2012004 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-255 License No: DPR-20 Report No: 05000255/2012004 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Dates: July 1, 2012 through September 30, 2012 Inspectors: T. Taylor, Resident Inspector A. Scarbeary, Resident Inspector T. Bilik, Senior Reactor Engineer B. Cushman, Resident Inspector, Quad Cities J. Ellegood, Senior Resident Inspector, D.C. Cook M. Jones Jr., Reactor Inspector P. LaFlamme, Resident Inspector, D.C. Cook J. Lennartz, Project Engineer, Branch 4 Approved by: J. Giessner, Chief Branch 4 Division of Reactor Projects

SUMMARY OF FINDINGS

Inspection Report (IR) 05000255/2012004; 07/01/2012 - 09/30/2012; Palisades Nuclear Plant;

Maintenance Risk Assessments and Emergent Work Control; Operability Determinations and Functional Assessments This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. Three Green findings were identified by the inspectors. The findings were considered non-cited violations (NCVs) of NRC regulations.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects were determined using IMC 0310, Components Within the Cross-cutting Areas dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated June 7, 2012. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events

Green.

A self-revealed finding of very low safety significance and two associated NCVs were identified for the failure to conduct maintenance activities in accordance with work management procedures. Two NCVs are being documented in accordance with NRC Enforcement Manual Section 2.13.8 because of a cause-and-effect relationship under one performance deficiency. The first NCV was of Technical Specification (TS) 5.4.1 for failure to implement work management procedures. Specifically, Fix-It-Now (FIN)maintenance personnel working on a control room light indication issue for the safety-related Component Cooling Water Surge Tank Fill Valve, CV-0918, conducted troubleshooting outside of what was originally planned and briefed. Contrary to work management procedures, the required documentation, independent and/or supervisory reviews, nor risk assessment were completed. This deviation resulted in the installation of jumpers from an 115V alternating current (AC) circuit to the safety-related 125V direct current (DC) power system, which actuated various control room alarms, including a ground alarm on the DC system. The second associated NCV, revealed as a result of the first, was for a failure to implement risk management actions as required by 10 CFR 50.65(a)(4), Maintenance Rule. Contrary to this, the licensee failed to perform a quantitative or qualitative risk assessment for work (installation of jumpers) on circuitry associated with CV-0918. Corrective actions consisted of entering the issue into the corrective action program (CAP) and reassigning the FIN team personnel back to their respective maintenance shops and a suspension of all tool pouch maintenance activities pending further investigation. The licensee also held information sharing sessions with the maintenance and operations departments about this incident, the work management process, the standards for implementing this process, and new checklists for use during work planning and authorization.

The finding was more than minor utilizing IMC 0612, Appendix B, because it could reasonably be viewed as a precursor to a significant event and it affected the Initiating Events Cornerstone attribute of Human Performance, adversely impacting the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, planning and conducting work outside work management requirements resulted in a short circuit and various control room alarms. The finding screened as Green by answering no to the Transient Initiator question of contributing to both the likelihood of a reactor trip and the likelihood that mitigating equipment or functions would not be available in Exhibit 1 of IMC 0609, Appendix A. Additionally, the inspectors screened the finding as Green utilizing an Incremental Core Damage Probability Deficit (ICDPD) calculation performed by a regional Senior Risk Analyst in accordance with IMC 0609, Appendix K, due to the one NCV associated with the Maintenance Rule. The finding had a cross-cutting aspect in the area of Human Performance, related to the cross-cutting component of Decision Making, in that the licensee uses conservative assumptions in decision making, adopts a requirement to demonstrate that the proposed action is safe in order to proceed, and identifies possible unintended consequences of a decision. In this finding, there were personnel in various departments that could have questioned the continuation of the maintenance with respect to following the work management process (H.1(b)).

(Section 1R13)

Green.

A finding of very low safety significance with an associated NCV of TS 5.4.1 was self-revealed for the failure to implement work management procedures when operators noticed water leakage into the control room from the ceiling during maintenance activities. Water dripped onto the top of a panel near the middle of the control room and inside a nearby walk-in panel. Metal trays that had been previously established to measure and route known leakage from the Safety Injection and Refueling Water Tank (SIRWT) out of the roof area (catacombs) above the control room were moved during maintenance. The plant was shut down at the time to repair the SIRWT and the tank was drained. However, a water-cooled drilling device was being used in the roof at the time to core-bore out old nozzles. Contrary to Quality Procedure EN-WM-105,

Planning, no controls were established to keep the trays in place or otherwise prevent water from accumulating in the catacomb area. As a result, the water from the tool seeped through the catacomb floor while it was in use and wetted equipment in the walk-in panel. Operators immediately halted the work in the roof area and shielded equipment from further wetting. The licensee inspected the affected equipment and determined there were no adverse effects as a result of the wetted equipment. The issue was also entered into the CAP.

The failure to plan work activities in a manner to protect control room equipment from leakage was a performance deficiency warranting further evaluation in the SDP. The issue was determined to be more than minor using IMC 0612, Appendix B, because it impacted the Configuration Control attribute of the Initiating Events Cornerstone, and it adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions. Specifically, wetting of electrical components in the control room challenges the ability of those components to perform their function reliability. The inspectors utilized IMC 0609, Appendix G, Shutdown Significance Determination Process, to assess the significance of the finding because the plant was shut down at the time. The finding screened as Green, or very-low safety significance, using Checklist 2 of Attachment 1 because with the primary coolant system closed and steam generators available for heat removal, none of the conditions listed as requiring a Phase 2 or 3 analysis applied and all shutdown safety functions were maintained. The finding had an associated cross-cutting aspect in the Human Performance area, specifically in the Work Control component. The licensee did not coordinate work activities consistent with nuclear safety (H.3(a)). The core-bore work activity did not properly incorporate the job site conditions, risk insights, or the need for compensatory actions. Since there was a known deficiency in the control room boundary regarding the potential for water ingress, appropriate controls should have been outlined in work instructions or exercised over the catch devices themselves to help control the water that was being used in the tank/catacomb area. (Section 1R15)

Cornerstone: Mitigating Systems

Green.

A finding of very-low safety significance with an associated NCV of TS 5.4.1 was self revealed for failure to implement a maintenance procedure when it was discovered that foreign material had entered the SIRWT during a forced outage to repair the tank.

A few days after the tank was refilled, a non-safety-related recirculation pump for the tank failed. The licensee discovered a plastic bag in the pump suction. The licensee entered the issue in their CAP and performed a root cause evaluation. The licensee concluded that inadequate implementation of Quality Procedure EN-MA-118, Foreign Material Exclusion, allowed the bag to enter the SIRWT during the refilling of the tank from the upper manway access. Since all Emergency Core Cooling system (ECCS)pumps have their suctions aligned to the SIRWT, the operability of those pumps came into question upon discovery of the bag in the recirculation pump. As a result, the licensee tested all of the pumps to ensure they were operable. There were no abnormalities noted during the test-runs.

The failure to adequately implement EN-MA-118, Foreign Material Exclusion, was a performance deficiency warranting further assessment in the SDP. Specifically, a buffer zone was not established around the upper opening to the SIRWT and consideration was not given to the effects of ventilation in the area. Both contributed to the introduction of foreign material into the tank. Utilizing IMC 0612, Appendix B, the inspectors determined the issue was more than minor because it adversely impacted the Equipment Performance attribute of the Mitigating Systems Cornerstone, whose objective is to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, introduction of foreign material challenged the reliability of all ECCS pumps and necessitated emergent testing to ensure they remained operable. The finding screened as Green, or very-low safety significance, utilizing IMC 0609, Appendix A, based on answering no to all questions in Section A of Exhibit 2. The inspectors also determined that the finding had an associated cross-cutting aspect in the Human Performance area, specifically in the Work Practices component. Based on other examples of poor implementation of the Foreign Material Exclusion (FME) program identified by both the inspectors and licensee; combined with the failure to correct those issues, the inspectors determined that the licensee did not ensure there was adequate supervisory and management oversight of work activities such that nuclear safety was supported (H.4(c)).

(Section 1R15)

Licensee-Identified Violations

No findings were identified.

REPORT DETAILS

Summary of Plant Status

The plant began the inspection period in a forced outage to repair the SIRWT. The reactor was brought critical on July 10, 2012, and returned to 100 percent power on July 12, 2012. The plant remained at or near 100 percent power until August 11, 2012, when the plant shutdown due to elevated Primary Coolant System (PCS) unidentified leakage. Pressure boundary leakage was discovered from the Control Rod Drive (CRD) Mechanism 24 housing. The plant remained shutdown to repair the CRD 24 housing and inspect others. The reactor was brought critical on August 29, 2012, and power was returned to 100 percent on August 31, 2012. The plant remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

The inspectors performed a detailed review of the licensees procedures and preparations for operating the facility during an extended period of time when ambient outside temperatures were high. The inspectors focused on plant specific design features and implementation of the procedures for responding to or mitigating the effects of these conditions on the operation of the facilitys engineered safeguards systems, emergency diesel generators, auxiliary feedwater system, auxiliary shutdown panels, and charging pumps. Inspection activities included a review of the licensees adverse weather and normal operating procedures, daily monitoring of the off-normal environmental conditions, and that operator actions specified by plant specific procedures were appropriate to ensure operability of the facilitys normal and emergency cooling systems.

This inspection constituted one readiness for impending adverse weather condition sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• A Control Room heating and ventilation system with the B train out-of-service for maintenance;

• high pressure safety injection with maintenance on opposite train; and

• B Component Cooling Water (Right train) with C and then A (both Left train)out-of-service for maintenance.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report (UFSAR), TS requirements, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down 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 obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization.

Documents reviewed are listed in the Attachment to this report.

These activities constituted three partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• condensate pump room and auxiliary feedwater pump room / TB Elev. 571 (Fire Areas 23 and 24);

• cooling tower pump house (Fire Area 38);

• auxiliary building general access and charging pump cubicles / AB Elev. 590 (Fire Areas 13A/B); and

• 1-1 EDG room.

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event.

Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP.

Documents reviewed are listed in the Attachment to this report.

These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On August 1, 2012, the inspectors observed a fire brigade activation in response to a B.5(b) loss of cooling in the Spent Fuel Pool scenario. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires as well as employ the sites alternate resources plan for establishing cooling to the spent fuel pool.

The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief; and took appropriate corrective actions.

Specific attributes evaluated were:

• proper use and layout of fire hoses;

• employment of appropriate fire fighting techniques;

• sufficient firefighting equipment brought to the scene;

• effectiveness of fire brigade leader communications, command, and control;

• utilization of pre-planned strategies;

• adherence to the pre-planned drill scenario; and

• drill objectives.

Documents reviewed are listed in the Attachment to this report.

These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R06 Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. The specific documents reviewed are listed in the to this report. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensees corrective action documents with respect to past flood-related items identified in the corrective action program (CAP) to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant area(s) to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

• east engineering safeguards room.

Specific documents reviewed during this inspection are listed in the Attachment to this report. This inspection constituted one internal flooding sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

On August 10, 2012, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk

a. Inspection Scope

On July 10, 2012 the inspectors observed the reactor startup at the conclusion of the forced outage to address leakage from the SIRWT. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions.

The performance in these areas was compared to pre-established operator action expectations and procedural compliance requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant systems:

• instrument air system; and

• high pressure safety injection.

The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for structures, systems, and components/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• Insertion of ground on DC system during troubleshooting of CV-0918, component cooling water surge tank fill valve;

• QO-1, Safety Injection System, preparations and execution; and

• repairs to service water piping downstream of A component cooling water heat exchanger.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Specific documents reviewed during this inspection are listed in the Attachment to this report. These maintenance risk assessments and emergent work control activities constituted three samples as defined in IP 71111.13-05.

b. Findings

Introduction:

A self-revealed finding of very low safety significance (Green) and an associated NCV of TS 5.4.1 was identified for the failure to conduct maintenance activities in accordance with work management procedures. Specifically, FIN maintenance personnel working on a control room light indication issue inadvertently connected an AC circuit to DC, causing control room alarms. As a result of this performance deficiency, and contrary to the requirements of 10 CFR 50.65(a)(4), a risk assessment was also not performed.

Description:

On May 14, 2012, FIN electrical workers were tasked with validating a work request for a control room red indicating light for CV-0918, Component Cooling Water Surge Tank Fill Valve, which did not come on when the valve was opened.

The validation of a work request does not authorize any intrusive troubleshooting; conversely, it is simply a way to determine if there is a valid problem with the component and determine the parts or tagging that would be required to fix the issue. The workers contacted the Work Control Center Senior Reactor Operator (WCC SRO) and Control Room operators via phone to discuss the task of manually operating the position switch for this valve.

Once this task was conducted and it was determined that the position switch was not the problem, workers discussed plans to work on the level switch that controls this valve.

A mental plan was constructed to insert jumpers into the level switch low level sensing probe to stroke the valve. This would also require another valve to be manipulated by an auxiliary operator to prevent level changes in the CCW surge tank. At this point, the workers incorrectly believed this plan still fell under the FIN toolpouch maintenance process, which did not require additional documentation or assessment. However, the planned activities would have categorized the work by a different set of procedures within the work management process. For example, Administrative Procedure 5.16, Control of Jumpers, Leads, and Links during Maintenance, Modifications, and Testing, would require this type of maintenance to have a work authorizing document, such as a work order, procedure, or clearance order. Additionally, EN-WM-100, Work Request Generation, Screening, and Classification would have directed the workers to the Online Work Management Process, EN-WM-101, which would require a work order and risk assessment of the activity. Procedure EN-WM-105, Planning, also has guidance that states that installation of jumpers will be clearly documented in an implementing procedure or work order to ensure than an adequate operations assessment can be performed. None of these were done.

Proceeding on, the FIN workers then copied a section of an electrical print, which included the CV-0918 position switches and indicating lights, but left out the section where the DC power supply and isolation fuses were within the circuit. They then proceeded to discuss their plan with the WCC SRO. The Control Room Supervisor was in the WCC at the time and listened to the conversation. Discussion included jumpering of the level probes for the level switch, which was believed would open the valve. The FIN personnel did not communicate to the WCC SRO that a risk assessment for this work had not been performed per their FIN Team Process procedure, EN-MA-130, nor did the WCC SRO or the Control Room Supervisor ask for such information.

Once in the field, the technician realized that the level switch for this valve was not the same as others he had previously worked with. Without stopping for additional clarification, the technician jumpered two connections in the level switch. Since this attempt was unsuccessful in actuating the valve, jumpering was attempted a second time between the two different connections with the same result. Instead of stopping and discussing the issues with a supervisor, the workers continued their plan. The worker retrieved a second set of jumpers and proceeded to jumper what was believed to be the two AC inputs to the two AC output connections in the circuit. This assumption was never validated (and could not have been with only the partial electrical schematic the workers had in the field). When installing the jumper, a spark was observed and the jumper was immediately removed. At this time, the control room received several alarms, including a 125V DC Bus Ground, and contacted the FIN team to stop work.

Analysis:

The inspectors determined that the failure to conduct maintenance activities in accordance with work management procedures was a performance deficiency that warranted a significance determination. The inspectors determined that the finding was more than minor in accordance with Inspection Manual Chapter (IMC) 0612 "Power Reactor Inspection Reports," Appendix B, "Issue Screening," dated June 10, 2012, because it could reasonably be viewed as a precursor to a significant event and it affected the Initiating Events Cornerstone attribute of Human Performance, adversely impacting the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, maintenance occurred without the required documentation, independent and/or supervisory reviews, nor risk assessment being completed as prescribed by work management procedures. This resulted in the installation of jumpers from an 115V AC circuit to the safety-related 125V DC power source, creating a short, and subsequently actuating various control room alarms. Utilizing IMC 0609, Appendix A, Exhibit 1, dated June 19, 2012, the finding screened as Green by answering no to the Transient Initiator question of contributing to both the likelihood of a reactor trip and the likelihood that mitigating equipment or functions would not be available.

The inspectors also applied IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, dated May 19, 2005, to address the significance of the failure to perform a risk assessment as a result of not following work management procedures. In accordance with Appendix K, a Region III Senior Reactor Analyst performed an analysis of the risk deficit for the unevaluated condition associated with the work on valve CV-0918.

The Palisades Standardized Plant Analysis Risk model version 8.20 and SAPHIRE version 8.0.8.0 was used to calculate an Incremental ICDPD for the unevaluated condition associated with work on the valve CV-0918 circuit. The Root Cause Evaluation Report associated with the issue identified that the same circuitry affected by the troubleshooting contained power for CV-1359, Service Water Non-Critical Isolation Valve. Although protective devices existed between the short-to-ground and CV-1359, an assumption that the valve could fail closed was used as a bounding case for the significance determination. The closure of CV-1359 at-power would have required manually tripping the reactor and the turbine generator due to a loss of service water cooling to the main generator. A reactor trip would have resulted in an ICDPD of 4.17E-7. The dominant core damage sequences involved "anticipated transient without scram" (i.e., ATWS) sequences; more specifically, a reactor trip with failure of control rods to insert and failure of charging pumps to supply borated water to the reactor core.

In accordance with IMC 0609, Appendix K, because the calculated ICDPD was not greater than 1E-6, the finding was determined to be of very low safety significance or Green.

The finding had a cross-cutting aspect in the area of Human Performance related to the cross-cutting component of Decision Making, in that the licensee uses conservative assumptions in decision making, adopts a requirement to demonstrate that the proposed action is safe in order to proceed, and identifies possible unintended consequences of a decision. In this finding, there were multiple personnel in various departments that could have questioned the continuation of the maintenance with respect to following the work management process. The FIN workers did not understand the safety-significance of the component they were working on nor the impact of installing jumpers into this circuit; the senior reactor operators did not question the workers mental plan before allowing work to proceed in the field; and the nuclear risk significance of this activity was not clearly understood when an intrusive maintenance plan was formulated (H.1(b)).

Enforcement:

Two NCVs associated with this performance deficiency are being documented in accordance with the guidance in NRC Enforcement Manual Section 2.13.8, Documenting Related Violations. In particular, these NCVs are being grouped under one performance deficiency (failure to follow work management procedures) to more appropriately characterize the incident and because they have a cause and effect relationship. The first associated NCV is of TS 5.4.1, which requires that written procedures shall be established, implemented, and maintained covering the activities in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978.

Section 9 of the Regulatory Guide states, in part, that procedures for performing maintenance that can affect the performance of safety-related equipment should be properly pre-planned and completed in accordance with written procedures and documented instructions appropriate to the circumstances. Contrary to this, on May 14, 2012, Quality Procedures in the work management process (EN-MA-130, EN-WM-105, EN-WM-101, EN-WM-100, EN-MA-125, and Admin 5.16) that would have directed further documentation and assessment for work on CV-0918, a safety-related component, were not followed. As a result, a ground on a safety-related DC bus occurred. Work was stopped and FIN team personnel were reassigned back to their respective shops pending further investigation. Because this violation was of very low safety significance and it was entered into the licensees CAP as CR-PLP-2012-03873, it is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.

The second NCV is of 10 CFR 50.65(a)(4), the Maintenance Rule. Title 10 CFR 50.65(a)(4) states that before performing maintenance activitiesthe licensee shall assess and manage the increase in risk that may result. Contrary to this, on May 14, 2012, the licensee failed to perform a quantitative or qualitative risk-assessment for the work (installation of jumpers) that was conducted on CV-0918. Because this violation was of very low safety significance and it was entered into the licensees CAP as CR-PLP-2012-03873, it is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. NCV 05000255/2012004-01, Failure to Follow Work Management Processes.

1R15 Operability Determinations and Functional Assessments

a. Inspection Scope

The inspectors reviewed the following issues:

• foreign material in SIRWT;

• water leakage into control room from maintenance activities;

• erratic indications on a nuclear instrument, and;

• pinhole leak on a manual service water valve.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that 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 TS and UFSAR to the licensees 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. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.

This operability inspection constituted three samples as defined in IP 71111.15-05.

Evaluation of the pinhole leak continued into the fourth quarter; therefore, that item does not constitute a completed sample in the third quarter.

b. Findings

(1) Water Leakage into Control Room during Maintenance

Introduction:

A finding of very-low safety significance (Green) and an associated NCV of TS 5.4.1, Procedures, was self-revealed when water was discovered dripping inside a control room panel during maintenance activities on the SIRWT. Contrary to work planning requirements, proper controls were not implemented in that devices used to capture known leakage in the roof above were not in place during use of water-cooled cement boring equipment in the roof area.

Description:

The plant shutdown in June of 2012 due to rising levels of leakage from the SIRWT. The leakage was being monitored since the plant startup from the refueling outage in May of 2012 in accordance with an NRC-approved American Society of Mechanical Engineers (ASME) Code Case. To address the leakage during the June forced outage, the tank was drained for inspection and repair activities. Part of the licensee repair efforts included removal and replacement of several nozzles at the bottom of the tank. To facilitate replacement, the old nozzles had to be core-bored out using a water-cooled drilling device that drilled through the concrete around the nozzles.

Prior to this, catch devices (metal trays) had been placed in the catacomb area below the roof in May when it was evident that the tank was still leaking after repair attempts.

Further, it was confirmed that water accumulation in the catacomb area could lead to dripping in the control room when water was spilled while priming one of the trays. The trays allowed the measurement of leakage for the ASME Code Case and served to prevent water ingress into the control room. On June 29, 2012, during core-bore activities in the tank, operators in the control room noticed water dripping in the middle of the control room and inside a walk-in panel in the front of the control room. The panel houses numerous pieces of safety-related electrical equipment. Several cables were wetted, along with some electrical connections and a pressure switch. Core-bore activities were suspended upon discovery of the leakage and operators acted to shield equipment from further wetting. No anomalous behavior was observed on any of the equipment and later walkdowns by electrical maintenance personnel confirmed there was no adverse impact to any equipment. The NRC inspectors also walked-down the panel that day to validate the status of equipment. The leakage stopped almost immediately after the core-boring stopped. The licensee determined that catch devices placed to address previous leakage in the catacombs had been moved, which allowed water from the maintenance activity to flow onto on the catacomb floor and make its way to the control room.

Procedure EN-WM-105, Planning, is the procedure used by the licensee to prepare for work. Contrary to the procedure requirements, the inspectors determined that there was neither an Operations Assessment form nor Operational Impact form included in the work order. These forms are used to describe potential impacts to the plant resulting from work. Additionally, the procedure contains requirements to review physical considerations pertaining to planned work, such as risk-to-generation equipment that may be impacted and barriers that may need to be controlled. At the time of the core-bore activities, the control room boundary had a known deficiency in that water accumulation in the catacombs could lead to dripping in the control room. Therefore, the inspectors concluded that the potential for leakage into the control room as a result of SIRWT maintenance activities should have been assessed and the work controlled in a manner to prevent such leakage. In addition to the replacement of the metal trays, the licensee subsequently installed a liner in the affected roof area pending further potential repair efforts.

Analysis:

The failure to plan work activities in a manner to protect control room equipment from leakage was a performance deficiency warranting further evaluation in the SDP. The issue was determined to be more than minor using IMC 0612, Appendix B, dated June 10, 2012, because it impacted the Configuration Control attribute of the Initiating Events Cornerstone, and it adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions. Specifically, wetting of components in control room panels challenges the ability of those components to reliably perform their function. The inspectors utilized IMC 0609, Appendix G, Shutdown Significance Determination Process, dated February 28, 2005, to assess the significance of the finding because the plant was shutdown at the time. The finding screened as Green, or very-low safety significance, using Checklist 2 of Attachment 1 (dated May 25, 2004) because with the primary coolant system closed and steam generators available for heat removal, none of the conditions listed as requiring a Phase 2 or 3 analysis applied and all shutdown safety functions were maintained. The finding had an associated cross-cutting aspect in the Human Performance area, specifically in the Work Control component. The licensee did not plan and coordinate work activities consistent with nuclear safety (H.3.a). The core-boring work activity did not properly incorporate the job site conditions, risk insights, or the need for compensatory actions. Since there was a recently known deficiency in the control room boundary regarding the potential for water ingress, appropriate controls should have been outlined in work instructions or exercised over the catch devices themselves to help control the water that was being used in the tank/catacomb area.

Enforcement:

TS 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained covering the activities in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Section 9 of the Regulatory Guide states, in part, that procedures for performing maintenance that can affect the performance of safety-related equipment should be properly pre-planned and completed in accordance with written procedures and documented instructions appropriate to the circumstances.

Quality Procedure EN-WM-105, Planning, contains requirements for preparing work.

Contrary to EN-WM-105, on June 29, 2012, appropriate controls were not incorporated into the core-boring work above the control room. As a result, water leaked into a control room panel, housing safety-related equipment. Operators noticed the leakage and immediately took action to protect equipment and terminate work in the SIRWT.

The leakage stopped relatively quickly. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very-low safety significance and was entered into the licensees CAP as CR-PLP-2012-04885.

NCV 05000255/2012004-02, Water Leakage into Control Room during Maintenance.

(2) Foreign Material in SIRWT

Introduction:

A finding of very-low safety significance (Green) with an associated NCV of TS 5.4.1, Procedures, was self-revealed when foreign material was found in the SIRWT recirculation pump. Inadequate implementation of the foreign material control procedure led to the introduction of a plastic bag into the SIRWT, which caused the pump to fail and challenged the operability of all ECCS pumps.

Description:

On July 5, 2012, the licensee commenced filling the SIRWT after inspections and repairs had been completed as part of forced outage to address leakage from the tank. On July 9, 2012, the licensee attempted to start P-74, SIRWT Recirculation Pump. Two attempts were made but the pump did not start due to an apparent thermal overload condition. P-74 is a non-safety-related pump used to recirculate water in the tank and had successfully run between July 6 and July 8, 2012.

On July 12, 2012, the licensee disassembled and inspected P-74. When the pump was opened, clear plastic material was found wrapped around the impeller and lodged in the suction area of the pump. Because the plastic likely originated from the SIRWT itself, the operability of all safety-related ECCS pumps (which draw suction from the tank) was in question. Most ECCS pumps had recently been run at the conclusion of the outage for normal operations without any issues being noted. However, the licensee elected to run quarterly surveillance tests on each ECCS pump to ensure they were operable.

No abnormalities were noted during the tests.

During the forced outage, water from the SIRWT was transferred to various in-plant and external tanks. Based on the in-plant system configurations used (all had some form of filtering/straining), the licensee determined it was not likely that the foreign material originated from an in-plant system. Further, the licensee concluded that the external tank utilized a strainer on the return line to the SIRWT, negating that as a potential source. That left the upper and lower manways into the tank as remaining pathways for the foreign material to enter the tank. Prior to filling, a closeout inspection was performed by the licensee and the lower manway was closed. During the fill, the upper manway remained open for filling and manipulation of equipment in the tank. The licensee determined that the plastic found in P-74 closely resembled plastic covers used on some of the hose fittings used to transfer water to/from the tank, and that several were staged near the open upper manway during the fill. The licensee concluded that poor implementation of procedure EN-MA-118, Foreign Material Exclusion, allowed plastic in the vicinity of the upper manway to enter the tank. Specific shortfalls were lack of a buffer zone around the opening to keep potential foreign material away and ignoring the effects of ventilation that had been routed to the tent around the opening. The SIRWT was classified as a FME Zone 1, which demanded the highest level of sensitivity and precautions. The root cause performed by the licensee identified other weaknesses in implementation of the FME program during both the forced outage and in other recent work performed onsite. Further, it was identified that previous efforts to correct problems with implementation of the FME program were unsuccessful.

Analysis:

The failure to adequately implement EN-MA-118, Foreign Material Exclusion, was a performance deficiency warranting further assessment in the SDP. Specifically, a buffer zone was not established around the upper opening to the SIRWT and consideration was not given to the effects of ventilation in the area. Both contributed to the introduction of foreign material into the tank. Utilizing IMC 0612, Appendix B, dated June 10, 2012, the inspectors determined the issue was more than minor because it adversely impacted the Equipment Performance attribute of the Mitigating Systems Cornerstone, whose objective is to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, introduction of foreign material challenged the reliability of all ECCS pumps and necessitated emergent testing to ensure they remained operable.

The finding affected the Mitigating Systems Cornerstone. Utilizing Inspection Manual Chapter 0609, Appendix A, Exhibit 1, dated June 19, 2012, the inspectors determined the finding screened as Green, or very-low safety significance, based on answering no to all questions in Section A, Exhibit 2. The inspectors also determined that the finding had an associated cross-cutting aspect in the Human Performance area, specifically in the Work Practices component. Based on other examples of poor implementation of the FME program identified by both the inspectors and licensee; combined with the failure to correct those issues, the inspectors determined that the licensee was not ensuring there was adequate supervisory and management oversight of work activities such that nuclear safety was supported H.4(c).

Enforcement:

TS 5.4.1 requires, in part, that the applicable procedures of Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978, be established, implemented, and maintained. Section 9 of Regulatory Guide 1.33 states, in part, that maintenance that can affect the performance of safety related equipment should be properly pre-planned and performed in accordance with written procedures appropriate to the circumstances. Quality Procedure EN-MA-118, Foreign Material Exclusion, establishes requirements for work in and near designated FME zones. Contrary to EN-MA-118, during refill of the SIRWT which commenced on July 5, 2012, appropriate controls in the form of a buffer zone and consideration of the effects of ventilation were not employed while there were openings in the tank. As a result, foreign material entered the tank.

The material resulted in the failure of P-74, SIRWT Recirculation Pump, and brought into question the operability of all ECCS pumps. Immediate corrective actions by the licensee included a test of all ECCS pumps to ensure their operability. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy because it was of very-low safety significance and was entered into the licensees CAP as a root cause under CR-PLP-2012-05054. NCV 05000255/2012004-03, Foreign Material in SIRWT.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed the following modification:

• modifications to SIRWT.

The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the UFSAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected system(s). The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed in the course of this inspection are listed in the Attachment to this report.

This inspection constituted one permanent plant modification sample as defined in IP 71111.18-05. This sample was started in the second quarter and inspection activities were completed in the third quarter.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• fuel oil transfer pump, P-18A, and associated electrical supply breaker preventive maintenance;

• C auxiliary feedwater pump EEQ preventive maintenance;

• electrical cable swap for CRD indication;

• repairs to SIRWT during forced outage, and;

• replacement of internal motor-operated valve parts in low pressure injection system valve.

These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.

This inspection constituted five post-maintenance testing samples as defined in IP 71111.19-05. Review of repair work on the SIRWT was started in the second quarter and concluded in the third quarter.

b. Findings

No findings were identified.

1R20 Outage Activities

.1 Forced Outage due to Safety Injection and Refueling Water Tank Leakage

a. Inspection Scope

The inspectors evaluated outage activities for a forced outage that began in the second quarter on June 12, 2012, and continued into the third quarter, concluding on July 10, 2012. The outage was a result of leakage from the SIRWT exceeding an administrative limit of 31 gallons per day (gpd). The licensee shut the plant down and drained the SIRWT for inspection and repair. The inspectors reviewed activities to ensure that the licensee considered risk in developing, planning, and implementing the outage schedule.

The inspectors observed or reviewed the reactor shutdown and cooldown, outage equipment configuration and risk management, electrical lineups, control and monitoring of decay heat removal, control of containment activities, personnel fatigue management, startup and heatup activities, and identification and resolution of problems associated with the outage. When the tank was refilled following repairs, leakage of approximately 20 gpd was identified from the tank area. This leakage subsequently tapered off and remained relatively low for the balance of the inspection period (approximately 0.05 gpd). NRC inspectors from the site, regional office, and headquarters reviewed the licensees evaluation of the tank prior to startup and concluded the plant and tank were safe to allow startup. An NRC-approved ASME Code Case was utilized by the licensee to evaluate the condition of the tank. It is unclear whether the small amounts of water currently collected daily from the vicinity of the tank is rainwater, residual water from maintenance activities, or a small tank leak. At the close of the inspection period, the licensee was preparing to modify and repair the roof around the tank. A goal of the modification is to allow a better determination of whether or not repairs have been completely effective. The NRC issued a Confirmatory Action Letter (CAL), dated July 17, 2012, to confirm commitments by Entergy to address the leakage and the condition of the roof area. The CAL is a publicly available document and can be found on the NRC Public Web site by utilizing the ADAMS database. The Accession Number is ML12199A409. Further, a summary of meetings held between NRC and Entergy in regard to the SIRWT can be found under Accession Number ML12193A631.

This inspection constituted one other outage sample as defined in IP 71111.20-05.

The sample was started in the second quarter and concluded in the third quarter.

b. Findings

No findings were identified.

.2 Forced Outage Due to CRD leakage

a. Inspection Scope

The inspectors evaluated outage activities for a forced outage that began on August 11, 2012, due to elevated PCS unidentified leakage. The licensee shut the plant down prior to reaching technical specification limits for unidentified leakage. The inspectors observed or reviewed the reactor shutdown and cooldown, outage equipment configuration and risk management, electrical lineups, control and monitoring of decay heat removal, control of containment activities, personnel fatigue management, startup and heatup activities, and identification and resolution of problems associated with the outage. The source of the leakage was determined to be from the pressure housing of CRD-24. The CRD housing was replaced and inspections were performed on other housings. An NRC Special Inspection Team was dispatched to the site to evaluate the CRD leakage. The inspection report from the Special Inspection Team is a publicly available document and can be found on the NRC Public Web site by utilizing the ADAMS database. The Accession Number is ML12291A806. The Special Inspection Team and other NRC inspectors from the site, regional office, and headquarters reviewed the licensees evaluations and determined the plant was safe to startup. The outage concluded on August 31, 2012. Summaries of discussions between NRC and the licensees staff can also be found on the NRCs Public Web site under Accession Numbers ML12243A519, ML12300A410, and ML12305A255. The NRC continues to assess the status of the CRDs as any new information becomes available and will evaluate inspection plans developed by the licensee for the CRDs going forward.

This inspection constituted one other outage sample as defined in IP 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• QO-42: inservice testing of shutdown cooling valves; and

• elevated PCS unidentified leakage after forced outage to repair SIRWT.

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

• were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;

• plant equipment calibration was correct, accurate, and properly documented;

• as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments;

• measuring and test equipment calibration was current;

• test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

• test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;

• test data and results were accurate, complete, within limits, and valid;

• test equipment was removed after testing;

• where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, ASME merican Society of Mechanical Engineers code, and reference values were consistent with the system design basis;

• where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

• where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;

• where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

• prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

• equipment was returned to a position or status required to support the performance of its safety functions; and

• all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one inservice testing sample and one reactor coolant system leak detection inspection sample as defined in IP 71111.22, Sections -02 and -05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee tabletop emergency drill on September 5, 2012 to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the 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 licensee drill critique to compare any inspector observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report.

This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

4OA1 Performance Indicator Verification

.1 Unplanned Transients per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Transients per 7000 Critical Hours performance indicator (PI) for the period from the fourth quarter 2011 through the second quarter 2012. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, was used. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports and NRC Integrated Inspection Reports for the period of the fourth quarter 2011 through the second quarter 2012 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one unplanned transients per 7000 critical hours sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Safety System Functional Failures

a. Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures PI for the period from the fourth quarter 2011 through the second quarter 2012.

To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73," definitions and guidance, were used. The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports and NRC Integrated Inspection Reports for the period of the fourth quarter 2011 through the second quarter 2012 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one safety system functional failures sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index - High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - High Pressure Injection Systems PI for the period from the third quarter 2011 through the second quarter 2012. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, was used. The inspectors reviewed the licensees operator narrative logs, issue reports, Mitigating Systems Performance Index (MSPI) derivation reports, event reports and NRC Integrated Inspection Reports for the period from the third quarter 2011 through the second quarter 2012, to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one MSPI high pressure injection system sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.4 Mitigating Systems Performance Index - Residual Heat Removal System

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - Residual Heat Removal System PI for the period from the third quarter 2011 through the second quarter 2012. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, was used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection Reports for the period from the third quarter 2011 through the second quarter 2012 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the to this report.

This inspection constituted one MSPI residual heat removal system sample as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for followup, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.

These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report 05000255/2011-002-00: Automatic Reactor Trip and

Auxiliary Feedwater System Actuation

a. Inspection Scope

On January 22, 2011, with the plant at 100 percent power, the operation of relay 251-2/SPG3, station power transformer 1-3 neutral to ground, actuated a generator direct trip lockout relay (backup), opening the main generator output breakers to the transmission system causing a turbine trip. The turbine trip actuated the reactor protective system to trip the reactor due to a loss of load. The cause for operation of the neutral to ground relay, and subsequent automatic plant trip, was a ground fault on the Y-phase of a medium voltage cable that provided electrical power to bus 1G, via breaker 252-401, from station power transformer 1-3. The licensee determined the probable cause of the ground fault on the cable was insulation flaws, with the effects of moisture acting on these flaws over time, causing the insulation to degrade. The licensee removed the affected cable and had a laboratory analysis performed to identify the cause of the failure. The conclusion of the analysis supported the initial probable cause developed by the licensee. The cables between bus 1G and station power transformer 1-3 were replaced. The inspectors also reviewed the status of other cables in the licensees cable reliability program. The inspectors noted most had been tested recently or were scheduled to be tested in upcoming outages. The inspectors also reviewed the results of cables tested during the most recent refueling outage. Several cables with questionable results were replaced by the licensee. The Licensee Event Report (LER)was reviewed. No findings or violations of NRC requirements were identified. The LER is closed.

This event followup review constituted one sample as defined in IP 71153-05.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 (Discussed) NRC Temporary Instruction (TI) 2515/187, Inspection of Near-Term Task

Force Recommendation 2.3 Flooding Walkdowns, and NRC TI 2515/188, Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns

a. Inspection Scope

Inspectors accompanied the licensee on a sampling basis during their flooding and seismic walkdowns to verify that the licensees walkdown activities were conducted using the methodology endorsed by the NRC. These walkdowns are being performed at all sites in response to a letter from the NRC to licensees, entitled, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated March 12, 2012, (ADAMS Accession Number ML12053A340).

3 of the March 12, 2012, letter requested licensees to perform seismic walkdowns using an NRC-endorsed walkdown methodology. Electric Power Research Institute document 1025286 titled, Seismic Walkdown Guidance, (ADAMS Accession Number ML12188A031) provided the NRC-endorsed methodology for performing seismic walkdowns to verify that plant features, credited in the current licensing basis for seismic events, are available, functional, and properly maintained.

4 of the letter requested licensees to perform external flooding walkdowns using an NRC-endorsed walkdown methodology (ADAMS Accession Number ML12056A050). NEI document 12-07 titled, Guidelines for Performing Verification Walkdowns of Plant Protection Features, (ADAMS Accession Number ML12173A215)provided the NRC-endorsed methodology for assessing external flood protection and mitigation capabilities to verify that plant features, credited in the current licensing basis for protection and mitigation from external flood events, are available, functional, and properly maintained.

b. Findings

Inspection activities commenced in the third quarter and are continuing into the fourth quarter. Findings or violations associated with the flooding and seismic walkdowns, if any, will be documented in the fourth quarter integrated inspection report.

4OA6 Management Meetings

.1 Exit Meeting Summary

On October 12, 2012, the inspectors presented the inspection results to Mr. A. Vitale and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violations

There were no licensee-identified violations.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

A. Vitale, Entergy, Site Vice-President

Nuclear Regulatory Commission

J. Giessner, Chief, Reactor Projects Branch 4

LIST OF ITEMS

Opened

05000255/2012004-01 NCV Failure to Follow Work Management Processes (Section 1R13)

05000255/2012004-02 NCV Water Leakage into Control Room during Maintenance (Section 1R15)

05000255/2012004-03 NCV Foreign Material in SIRWT (Section 1R15)

Closed

05000255/2012004-01 NCV Failure to Follow Work Management Processes (Section 1R13)

05000255/2012004-02 NCV Water Leakage into Control Room during Maintenance (Section 1R15)

05000255/2012004-03 NCV Foreign Material in SIRWT (Section 1R15)

05000255/2011-002-00 LER Automatic Reactor Trip and Auxiliary Feedwater System Actuation (Section 4OA3)

Discussed

2515/187 TI Inspection of Near Term Task Force Recommendation 2.3 Flooding Walkdowns (Section 4OA5)

2515/188 TI Inspection of Near Term Task Force Recommendation 2.3 Seismic Walkdowns (Section 4OA5)

Attachment