Text

IR 05000255/2014005; 07200007/2014001; on 10/01/2014 - 12/31/2014; Palisades Nuclear Plant; Problem Identification and Resolution
	ML15034A629
Person / Time
Site:	Palisades
Issue date:	02/03/2015
From:	John Ellegood; Region 3 Branch 3
To:	Vitale A; Entergy Nuclear Operations
References
	IR 2014001, IR 2014005
	Download: ML15034A629 (30)
	v • d • e

UNITED STATES ary 3, 2015

SUBJECT:

PALISADES NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000255/2014005; 07200007/2014001

Dear Mr. Vitale:

On December 31, 2014, 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 January 8, 2015, with you and other members of your staff.

Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified. The finding involved a violation of NRC requirements. However, because of its very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating the issue as a non-cited violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the subject or severity of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the 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 addition, if you disagree with the cross-cutting aspect assigned to the 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. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," 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 Documents Access and Management System (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John Ellegood, Acting Chief Branch 3 Division of Reactor Projects Docket Nos. 50-255;72-007 License No. DPR-20

Enclosure:

IR 05000255/2014005; 07200007/2014001 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 50-255;72-007 License No: DPR-20 Report No: 05000255/2014005; 07200007/2014001 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Dates: October 1 through December 31, 2014 Inspectors: A. Garmoe, Senior Resident Inspector A. Scarbeary, Resident Inspector R. Elliott, Acting Resident Inspector J. Cassidy, Senior Health Physicist J. Ellegood, Senior Resident Inspector, DC Cook J. Lennartz, Project Engineer S. Sheldon, Senior Reactor Engineer J. Beavers, Emergency Preparedness Inspector R. Edwards, Reactor Inspector Approved by: John Ellegood, Acting Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000255/2014005; 07200007/2014001; 10/01/2014 - 12/31/2014;

Palisades Nuclear Plant; Problem Identification and Resolution.

This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One Green finding was identified by the inspectors.

The finding was considered a non-cited violation (NCV) of NRC regulations. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow,

Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP) dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310,

Aspects Within the Cross-Cutting Areas dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.

Cornerstone: Mitigating Systems

Green: The inspectors identified a finding of very low safety significance (Green) with an associated non-citied violation of Technical Specification (TS) 5.4.1, Procedures and Programs, for the failure to follow site procedures covering the storage of material in the vicinity of safety-related equipment. Specifically, on three occasions the inspectors identified ladders at ladder station 42 in the 590 elevation of the component cooling water room that were either in contact with safety-related equipment or were capable of toppling into safety-related equipment. For immediate corrective actions, licensee personnel properly stored the ladder after each issue was identified by the inspectors.

This issue is documented in the licensees corrective action program (CAP) as Condition Report CR-PLP-2015-00126.

The performance deficiency was determined to be more than minor based on Inspection Manual Chapter (IMC) 0612, Appendix E, Example 4.a, which determined that low-level procedural errors without a safety consequence are more than minor when they become a repetitive/routine occurrence. Specifically, unrestrained ladders could impact safety-related equipment during a design basis seismic event. The inspectors evaluated the significance of the finding in accordance with IMC 0609, Attachment 4, Initial Characterization of Findings. In accordance with Table 2, the finding was determined to affect the Mitigating Systems Cornerstone. The inspectors answered No to the questions in Table 3 and continued the significance evaluation in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power.

The inspectors answered No to the Mitigating Systems Screening Questions contained in Exhibit 2 and determined the finding was of very low safety significance (Green). This finding was associated with a cross-cutting aspect of Identification in the Problem Identification and Resolution cross-cutting area (P1). (Section 4OA2.3)

REPORT DETAILS

Summary of Plant Status

The plant was operated at or near 100 percent power for the duration of the inspection period with the exception of December 11, 2014, when reactor power was reduced to approximately 90% as a result of a feedwater heater level transient. Following repair of the controller, the licensee returned the plant to full power.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Winter Seasonal Readiness Preparations

a. Inspection Scope

The inspectors conducted a review of the licensees preparations for winter conditions to verify that the plants design features and implementation of procedures were sufficient to protect mitigating systems from the effects of adverse weather. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. Cold weather protection, such as heat tracing and area heaters, was verified to be in operation where applicable. The inspectors also reviewed CAP items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment to this report. The inspectors reviews focused specifically on the following plant systems due to their risk significance or susceptibility to cold weather issues:

condensate storage tank and safety injection refueling water tank heat-tracing and insulation; and

warm water recirculation pump rebuild.

This inspection constituted one winter seasonal readiness preparations sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

a. Inspection Scope

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

containment spray pumps P-54A and P-54C with P-54B out of service; and

emergency diesel generator (EDG) 1-1.

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, 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 to this report.

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

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

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:

Fire Area 24: auxiliary feedwater (AFW) pump room;

Fire Area 16: component cooling water (CCW) pump room;

Fire Area 15: engineering safeguards panel room; and

Fire Area 19: track alley.

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.

1R06 Flooding

Main article: IP 71111.06

.1 Underground Vaults

a. Inspection Scope

The inspectors selected underground bunkers/manholes subject to flooding that contained cables whose failure could disable risk-significant equipment. The inspectors determined that the cables were not submerged, that splices were intact, and that appropriate cable support structures were in place. In those areas where dewatering devices were used, such as a sump pump, the device was operable and level alarm circuits were set appropriately to ensure that the cables would not be submerged. In those areas without dewatering devices, the inspectors verified that drainage of the area was available, or that the cables were qualified for submergence conditions. The inspectors also reviewed the licensees corrective action documents with respect to past submerged cable issues identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following underground bunkers/manholes subject to flooding:

Manholes 4 and 8 Specific documents reviewed during this inspection are listed in the Attachment to this report. This inspection constituted one underground vaults sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

On October 21, 2014, 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 during Periods of Heightened Activity or Risk

a. Inspection Scope

On December 5, 2014, the inspectors observed operator performance of safety injection system testing, which involved coordination between many operators and many equipment manipulations. 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 (if applicable);

correct use and implementation of procedures;

control board (or equipment) manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications (if applicable).

The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion 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

Main article: IP 71111.12

a. Inspection Scope

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

pressurizer heater breaker buckets; and

B safety injection tank leakage.

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 (SSCs)/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

Main article: IP 71111.13

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:

B traveling water screen emergent maintenance;

ED-15 battery charger maintenance;

bus 1C supply breaker from safeguards transformer maintenance; and

B safety injection tank liquid and nitrogen leakage troubleshooting.

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. Documents reviewed during this inspection are listed in the Attachment to this report.

These maintenance risk assessments and emergent work control activities constituted four samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functional Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed the following issues:

nonsafety-related oilers installed on safety-related CCW pumps;

turbine-driven AFW pump overspeed trip; and

revised operability evaluation for non-conservative spent fuel pool region II criticality analysis.

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.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

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:

pressurizer pressure indicators PIA-0102ALL and PIA-0102CLL following maintenance;

bus 1C supply breaker from safeguards bus preventive maintenance;

NI-5 power range detector following erratic readings; and

containment air-lock leak test following inner door seal maintenance.

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 four post-maintenance testing samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

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-19B, 'B' high pressure safety injection quarterly inservice surveillance (IST);

DWO-1, operators daily/weekly items mode 1, 2, 3 and 4, primary coolant system leak rate calculation (Reactor Coolant System (RCS) Leak Detection);

MO-7A-2, EDG 1-2 monthly surveillance (Routine);

RO-145, B AFW pump surveillance (Routine); and

QO-1, safety injection actuation system surveillance (Routine).

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

did preconditioning occur;

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

acceptance criteria were clearly stated, demonstrated operational readiness, and were 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 UFSAR, 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, American 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 disposed in the CAP.

For the reactor coolant system leak detection inspection sample, the inspectors verified that the licensee had programs and processes in place to:

(1) monitor plant-specific instrumentation that could indicate potential reactor coolant system leakage;

(2) meet existing requirements related to degraded or inoperable leakage detection instruments;

(3) use an inventory balance check when there is unidentified leakage;

(4) take appropriate corrective action for adverse trends in unidentified leak rates; and

(5) pay particular attention to changes in unidentified leakage.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted three routine surveillance testing samples, one IST sample and one RCS leak detection inspection sample as defined in IP 71111.22, Sections-02 and -05.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

Main article: IP 71114.04

a. Inspection Scope

The regional inspectors performed an in-office review of the latest revisions to the Emergency Plan and Emergency Plan Implementing Procedures as listed in the to this report.

The licensee transmitted the Emergency Plan and Emergency Action Level revisions to the NRC pursuant to the requirements of 10 CFR Part 50, Appendix E, Section V, Implementing Procedures. The NRC review was not documented in a Safety Evaluation Report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment to this report.

This Emergency Action Level and Emergency Plan Change inspection constituted one sample as defined in IP 71114.04-06.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

Main article: IP 71151

.1 Mitigating Systems Performance IndexEmergency AC Power System

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 follow-up, 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.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of July 1 through December 31, 2014, although some examples expanded beyond those dates where the scope of the trend warranted.

The review also included issues documented outside the normal CAP in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

This review constituted one semi-annual trend inspection sample as defined in IP 71152-05.

b. Findings

Failure to Follow Procedure for Storage of Equipment in the Vicinity of Safety-Related Equipment

Introduction:

The inspectors identified a finding of very low safety significance (Green)with an associated NCV of TS 5.4.1, Procedures and Programs, for the failure to follow site procedures covering the storage of material in the vicinity of safety-related equipment. Specifically, on three occasions the inspectors identified ladders at ladder station 42 in the 590 elevation of the component cooling water room that were either in contact with safety-related equipment or were capable of toppling into safety-related equipment.

Description:

On July 10, 2014, the inspectors identified ladders that were in contact with safety-related supply lines from nitrogen station 1. Nitrogen station 1 provides nitrogen backup to valves CV-0727, A and B AFW pumps supply to the B steam generator, and CV-0749, A and B AFW pumps supply to the A steam generator. The inspectors reviewed licensee procedure 1.01, Attachment 2, Guidelines for the Placement of Items in Areas Containing Operable Safety-Related Equipment. Procedure 1.01, 2, defined restrained and unrestrained items as follows:

Restrained Items: items in use for purposes of transport or storage or materials, tools, or equipment, that have been evaluated and appropriately restrained with bracing, fasteners, wire, rope, or other approved means Unrestrained Items: items in use for purposes of transport or storage of materials, tools, or equipment that can topple, roll, fall, shift, or slide during a seismic or similar event and threaten the operation of safety-related equipment. This includes tools/parts that are left unattended and unrestrained on scaffold platforms.

The normal air supply to valves CV-0727 and CV-0749 is instrument air, which is not safety-related. Section 2.3.4 of Design Basis Document DBD-1.05, Compressed Air Systems, discussed that the nitrogen backup stations are treated as safety-related systems except for resistance to certain external events including earthquakes. In most cases, the nitrogen back up stations reside in a non-seismic structure thus precluding seismic qualification. However, the auxiliary building location where nitrogen station 1 is installed is a seismic structure. Additionally, valves CV-0727 and CV-0749 are classified as safety-related equipment in the licensees equipment database. Step 1.5 of Procedure 1.01, Attachment 2, discussed safety-related equipment and sub-step 1.5.1 stated, All support systems such as instruments, tubing, pipe supports, wiring, cable trays, etc. that support the functionality of any specific piece of equipment shall also be considered safety-related. As a result, it was clear to the inspectors that the nitrogen lines should be treated as safety-related.

Step 3.2 of Procedure 1.01, Attachment 2, stated, Unrestrained, potentially damaging items which cannot topple shall be separated from operable safety-related equipment by curbs or other barriers, or shall be no closer to operable safety-related equipment than four feet in any horizontal direction. Step 3.3 stated, Unrestrained, potentially damaging items which can topple shall be separated from operable safety-related equipment by a minimum horizontal distance equal to the height of the item plus five feet. Step 3.5 stated, Ladders and equipment covers should not be placed in such a manner that creates a potential hazard to safety-related equipment. The ladders identified by the inspectors on July 10 were in contact with, or within a fraction of an inch of, safety-related nitrogen lines and did not meet the Procedure 1.01, Attachment 2, steps listed above. The licensee documented this example in their CAP as CR-PLP-2014-03686, NRC Identified Plant Housekeeping Issues, dated July 13, 2014.

During the week of August 18th, the inspectors identified ladders at ladder station 42 that were in contact with safety-related supply lines from nitrogen station 1. For the same reasons as in the July 10 instance, storage of the ladders did not meet the requirements of procedure 1.01, Attachment 2. The licensee did not enter this example into their CAP.

On December 24, 2014, the inspectors identified a 12-foot ladder that was not adequately restrained and the top of the ladder was within approximately one foot of the air operator for valve CV-0910, component cooling water supply to containment, which is classified as a safety-related valve in the licensees equipment database. The ladder was stored upright against an I-beam with a chain around one of the legs approximately three feet from the ground. This represented another example where ladder storage at ladder station 42 did not meet the storage requirements of Procedure 1.01,

2. The licensee entered this example into their CAP as CR-PLP-2014-

05939, Seismic Concerns with Ladder Storage, dated December 24, 2014.

For immediate corrective actions, licensee personnel properly stored the ladder after each issue was identified by the inspectors. When the inspectors discussed the repeated identification of inadequate ladder storage at ladder station 42 the licensee entered the issue into their CAP as CR-PLP-2015-00126, Repetitive Failure to Adequately Store Ladders in a Seismic Area, dated January 8, 2015. The licensee also implemented an Operations Standing Order to communicate proper storage of ladders and was in the process of evaluating physical changes to the ladder station.

Analysis:

The inspectors determined that the repetitive failure to follow Procedure 1.01, 2, requirements for the storage of ladders in the vicinity of safety-related equipment was an issue of concern. The issue was a performance deficiency since it represented the failure to meet a standard (compliance with procedures in accordance with TS 5.4.1.a) and was reasonably within the licensees ability to foresee and correct.

The performance deficiency was more than minor based on IMC 0612, Appendix E, Example 4.a, which determined that low-level procedural errors without a safety consequence are more than minor when they become a repetitive/routine occurrence.

Specifically, unrestrained ladders could impact safety-related equipment during a design basis seismic event.

The inspectors evaluated the significance of the finding in accordance with Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, issued June 19, 2012. In accordance with Table 2, Cornerstones Affected by Degraded Condition or Programmatic Weaknesses, the finding was determined to affect the Mitigating Systems Cornerstone. The inspectors answered No to the questions in Table 3, SDP Appendix Router, and continued the significance evaluation in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012. The inspectors answered No to the Mitigating Systems Screening Questions contained in Exhibit 2 and determined the finding was of very low safety significance (Green).

This finding was associated with a cross-cutting aspect of Identification in the Problem Identification and Resolution cross-cutting area. Specifically, equipment not in compliance with Procedure 1.01 requirements was not identified by licensee personnel who frequently traverse the area to ensure ladders were properly restrained to prevent interaction with safety-related systems during a design basis seismic event (P1).

Enforcement:

Technical Specification 5.4.1(a), states, in part, that written procedures shall be established, implemented, and maintained as recommended in Regulatory Guide 1.33, Revision 2, dated February 1978, that include safety-related activities carried out during operation of the reactor plants. Section 9.a, Procedures for Performing Maintenance, states in part, Maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Procedure 1.01, Attachment 2, Guidelines for the Placement of Items in Areas Containing Operable Safety-Related Equipment, Step 3.3 stated, Unrestrained, potentially damaging items which can topple shall be separated from operable safety-related equipment by a minimum horizontal distance equal to the height of the item plus five feet. Step 4.4 stated, in part, An appropriately restrained item shall be installed with a minimum horizontal or vertical separation of six inches in all directions from operable safety-related equipment, unless otherwise justified.

Contrary to the above, on July 10, the week of August 18, and December 24, the licensee stored unrestrained ladders in contact with or very near operable safety-related equipment. For immediate corrective actions, licensee personnel properly stored the ladder after each issue was identified by the inspectors. Because the licensee entered the issue into the corrective action program as CR-PLP-2015-00126 and because the finding is of very low safety significance (Green), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRCs Enforcement Policy.

(NCV 05000255/2014005-01, Failure to Follow Procedure for Storage of Equipment in the Vicinity of Safety-Related Equipment)

4OA5 Other Activities

.1 Operation of an ISFSI at Operating Plants

a. Inspection Scope

The inspectors conducted document reviews; held discussions with licensee staff; and performed a walk-down of the Independent Spent Fuel Storage Installation (ISFSI) to verify compliance with the applicable Certificate of Compliance, TS, Safety Analysis Report, and approved ISFSI procedures. During the walk-down, the material condition of the ISFSI pads and storage casks was evaluated and the inspectors observed the licensee perform routine surveillance activities.

Site procedures were reviewed to verify that adequate controls were in place to monitor the dose resulting from the operation of the ISFSI. The inspectors reviewed several routine surveys performed by the licensee around the pad and conducted independent surveys to verify dose rates.

Condition reports and the associated follow up actions were reviewed to determine whether corrective actions were adequate and conducted in a timely manner to correct the issues. In addition, no changes to the ISFSI were identified that were performed pursuant to Title 10 CFR 72.48, Changes, Tests, and Experiments, or 10 CFR 50.59, Changes, Tests, and Experiments.

b. Findings

No findings were identified.

.2 Post-Approval Site Inspection for License Renewal -Inspection Procedure 71003

a. Inspection Scope

Review of Commitments NRC Inspection Report 05000255/2011008 (ML11126A328) documented Phase II of a Post-Approval Site Inspection for License Renewal in which inspectors verified that the licensee implemented the Aging Management Programs included in NUREG-1871, Safety Evaluation Report Related to the License Renewal of the Palisades Nuclear Plant, in accordance with Title 10 CFR Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants. In this report all but one commitment was documented as complete. The open commitment was related to the Reactor Vessel Integrity Surveillance Program.

The Reactor Vessel Integrity Surveillance Program manages the reduction of fracture toughness of the reactor vessel due to neutron embrittlement using monitoring methods in accordance with 10 CFR Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements. This program ensures the reactor vessel materials meet Title 10 CFR Part 50, Appendix G, Fracture Toughness Requirements, and have adequate margin against brittle fracture caused by pressurized thermal shock.

Commitment Item 2 in the safety evaluation report stated that an equivalent margins analysis, completed in accordance with Title 10 CFR Part 50, Appendix G, Section IV.A.1, would be submitted for NRC-approval at least three years before beltline material upper shelf energy decreased to less than 50 ft-lb. According to the evaluation contained in WCAP-17341, the upper shelf energy was estimated to decrease below 50 ft-lb in 2016; and therefore, this effort was not required to be completed at the time of the previous inspection. The inspectors verified that the licensee submitted an equivalent margin analysis in a letter dated October 21, 2013 (ML13295A448). This was subsequently followed by a license amendment request for approval of Palisades Nuclear Plant 10 CFR Part 50, Appendix G, Equivalent Margins Analysis in a letter dated November 21, 2014 (ML14316A190).

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 2.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On January 8, 2015, 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 confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meetings

Interim exits were conducted for:

The results of the ISFSI operational inspection were presented on October 2, 2014, to Mr. A. Vitale, Site Vice President, and other members of the licensees staff; and

The annual review of Emergency Action Level and Emergency Plan changes with the licensee's Emergency Preparedness Manager, Mr. D. Malone, via telephone on December 19, 2014.

The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

A. Vitale, Site Vice President

B. Dotson, Regulatory Assurance

D. Malone, Emergency Preparedness Manager

B. VanWagner, Dry Fuel Storage Manager

Nuclear Regulatory Commission

John Ellegood, Acting Chief, Reactor Projects Branch 3

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

05000255/2014005-01 NCV Failure to Follow Procedure for Storage of Equipment in the Vicinity of Safety-Related Equipment (Section 4OA2.3)

Closed

05000255/2014005-01 NCV Failure to Follow Procedure for Storage of Equipment in the Vicinity of Safety-Related Equipment (Section 4OA2.3)

Discussed

None Attachment

LIST OF DOCUMENTS REVIEWED