IR 05000255/2016002
| ML16207A382 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/25/2016 |
| From: | Eric Duncan Region 3 Branch 3 |
| To: | Vitale A Entergy Nuclear Operations |
| References | |
| EA-15-171 IR 2016002 | |
| Download: ML16207A382 (45) | |
Text
July 25, 2016
SUBJECT:
PALISADES NUCLEAR PLANTNRC INTEGRATED INSPECTION REPORT 05000255/2016002
Dear Mr. Vitale:
On June 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. On July 7, 2016, the NRC inspectors discussed the results of this inspection with yourself and other members of your staff. The enclosed report documents the results of this inspection.
Based on the results of this inspection, no findings of significance were identified.
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 NRCs Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's Agencywide Documents 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 Jamnes Cameron Acting for/
Eric Duncan, Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20
Enclosure:
REGION III==
Docket No:
50-255 License No:
DPR-20 Report No:
05000255/2016002 Licensee:
Entergy Nuclear Operations, Inc.
Facility:
Palisades Nuclear Plant Location:
Covert, MI Dates:
April 1 through June 30, 2016 Inspectors:
A. Nguyen, Senior Resident Inspector
J. Boettcher, Resident Inspector
J. Cassidy, Senior Health Physicist
M. Holmberg, Reactor Inspector
J. Jandovitz, Project Engineer
V. Myers, Senior Health Physicist
T. Taylor, Resident Inspector, D. C. Cook
Approved by:
E. Duncan, Chief Branch 3 Division of Reactor Projects
SUMMARY
Inspection Report (IR) 05000255/2016002, 04/01/2016 - 06/30/2016; Palisades Nuclear Plant;
Routine Integrated Inspection Report This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The Nuclear Regulatory Commission's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated February 2014.
No violations of significance were identified.
REPORT DETAILS
Summary of Plant Status
The plant began the assessment period operating at full power. The unit was down-powered to approximately 95 percent on April 6, 2016, to perform emergent maintenance on the Moisture Separator and Drain Tank level control valve, CV-0608. The unit was returned to 100 percent power on April 7, 2016, and operated at or near full power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness of Offsite and Alternate AC Power Systems
a. Inspection Scope
The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate alternating current (AC) power systems during adverse weather were appropriate. The inspectors reviewed the licensees procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify that the appropriate information was being exchanged when issues arose that could impact the offsite power system. Examples of aspects considered in the inspectors review included:
- coordination between the TSO and the plant during off-normal or emergency events;
- explanations for the events;
- estimates of when the offsite power system would be returned to a normal state; and
- notifications from the TSO to the plant when the offsite power system was returned to normal.
The inspectors also verified that plant procedures addressed measures to monitor and maintain the availability and reliability of both the offsite AC power system and the onsite alternate AC power system prior to or during adverse weather conditions. Specifically, the inspectors verified that the procedures addressed the following:
- actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the plant would not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply;
- compensatory actions identified to be performed if it would not be possible to predict the post-trip voltage at the plant for the current grid conditions;
- re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide offsite power; and
- communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power was challenged.
Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed corrective action program (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.
This inspection constituted one readiness of offsite and alternate AC power systems sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
.2 Summer Seasonal Readiness Preparations
a. Inspection Scope
The inspectors performed a review of the licensees preparations for summer weather for selected systems, including conditions that could lead to an extended drought.
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. Documents reviewed are listed in the Attachment to this report. 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. The inspectors reviews focused specifically on the following plant systems:
- service water system;
- auxiliary feedwater (AFW) system; and
- the ultimate heat sink.
This inspection constituted one seasonal adverse weather sample as defined in 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 and B containment spray trains;
- A and C service water trains; and
- A high pressure safety injection train.
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, the UFSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), 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
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on the availability, accessibility, and condition of firefighting equipment in the following risk-significant plant areas:
- Fire Area 23: turbine building, elevations 607', 612', and 625';
- Fire Area 28: west engineered safeguards room, elevation 570';
- Fire Area 16: component cooling water pump room, elevation 590';
- Fire Area 10: east engineered safeguards room, elevation 570'; and
- Fire Area 9: screen house/intake structure, elevation 590.
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 five quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
a. Inspection Scope
On May 17, 2016, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that 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 71111.11-05.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- diesel generator rooms heating, ventilation and air conditioning systems;
- primary coolant system; and
- a review of the licensees maintenance rule (a)(3) periodic evaluations.
The inspectors reviewed events 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 Title 10 of the Code of Federal Regulations (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 three 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:
- emergent downpower and repair of moisture separator and drain tank level control valve, CV-0608;
- elevated plant risk for P-7A, A service water pump, maintenance window concurrent with B channel RPS power supply board replacements;
- elevated plant risk for work activities on May 18-20, 2016;
- troubleshooting activities associated with P-50A, A primary coolant pump, seal low flow alarms; and
- elevated plant risk due to emergent work to replace all DG air start motors.
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 five samples as defined in IP 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functional Assessments
a. Inspection Scope
The inspectors reviewed the following issues:
- evaluation of the environmental conditions of the atmospheric dump valve cabinet tornado enclosure after a postulated high energy line break in the component cooling water room impacting an unsealed penetration;
- evaluation of CV-3042, safety injection tank T-82A pressure control valve, stroke test time degradation;
- evaluation of non-compliance with American Society of Mechanical Engineers (ASME) code required testing of safety-related valves;
- evaluation of the solenoid air valves associated with the safety injection tank pressure control valves after discovery of not performing all environmental qualification required maintenance;
- evaluation of DG air start motors (ASMs) due to identification of unhardened stop nut pin material on ASM-1A; and
- evaluation of the DG jacket water coolers remaining service life due to identified tube degradation.
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 TSs 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 sample 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 six samples as defined in IP 71111.15-05.
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following modification:
- Temporary modification for monitoring the operation of breaker 52-2535 for V-24A, 1-1 DG ventilation fan.
The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the UFSAR, and the TSs, as applicable, to verify that the modification did not affect the operability or availability of the affected systems. The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modification was installed as directed and consistent with the design control documents; the modification operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modification 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 are listed in the Attachment to this report.
This inspection constituted one temporary modification sample as defined in IP 71111.18-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance testing activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- A component cooling water pump surveillance test following maintenance;
- escape air lock local leak rate test following repair of the equalizing valve;
- right train control room Heating, Ventilation and Air Conditioning (HVAC)surveillance test following condenser overhaul and RV-1686 replacement;
- B channel reactor protection system surveillance and voltage checks following plug-in power supply boards replacements;
'A' service water pump surveillance test following coupling and shaft sleeve replacements;
- 1-1 and 1-2 DG test starts and surveillance tests following replacement of all air start motors; and
- C containment spray pump surveillance test following 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 seven post-maintenance testing samples as defined in IP 71111.19-05.
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:
- RO-147B, B high pressure safety injection pump surveillance (in-service test);
- QO-20B, B low pressure safety injection pump surveillance (routine);
- QO-21C, 'C' AFW pump surveillance (routine); and
- QI-39, AFW actuation system logic test (routine).
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, demonstrate operational readiness, and consistent with the system design basis;
- was plant equipment calibration correct, accurate, and properly documented;
- were as-left setpoints within required ranges; and was the calibration frequency in accordance with TSs, the USAR, procedures, and applicable commitments;
- was measuring and test equipment calibration current;
- was test equipment within the required range and accuracy; and were applicable prerequisites described in the test procedures satisfied;
- were test frequencies met for TS requirements to demonstrate operability and reliability; were tests performed in accordance with the test procedures and other applicable procedures; and were jumpers and lifted leads controlled and restored where used;
- were test data and results accurate, complete, within limits, and valid;
- was test equipment removed after testing;
- where applicable for inservice testing activities, was testing performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and were reference values consistent with the system design basis;
- where applicable, were test results not meeting acceptance criteria addressed with an adequate operability evaluation or was the system or component declared inoperable;
- where applicable for safety-related instrument control surveillance tests, were reference setting data accurately incorporated in the test procedure;
- where applicable, were actual conditions encountering high resistance electrical contacts such that the intended safety function could still be accomplished;
- had prior procedure changes provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- was equipment returned to a position or status required to support the performance of its safety functions; and
- were all problems identified during the testing appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted three routine surveillance testing samples and one in-service test 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 routine licensee emergency drills on April 13, 2016, and May 17, 2016, to identify any weaknesses or deficiencies in classification, notification, and protective action recommendation development activities.
The inspectors observed emergency response operations in the control room simulator, technical support center, operations support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the 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 two samples as defined in IP 71114.06-06.
b. Findings
No findings were identified.
RADIATION SAFETY
2RS7 Radiological Environmental Monitoring Program
.1 Site Inspection (02.02)
a. Inspection Scope
The inspectors walked down select air sampling stations and dosimeter monitoring stations to determine whether they were located as described in the Offsite Dose Calculation Manual (ODCM) and to determine the equipment material condition.
The inspectors reviewed calibration and maintenance records for select air samplers, dosimeters, and composite water samplers to evaluate whether they demonstrated adequate operability of these components.
The inspectors assessed whether the licensee had initiated sampling of other appropriate media upon loss of a required sampling station.
The inspectors observed the collection and preparation of environmental samples from select environmental media to determine if environmental sampling was representative of the release pathways specified in the ODCM and if sampling techniques were in accordance with procedures.
The inspectors assessed whether the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, and licensee procedures. The inspectors assessed whether the meteorological data readout and recording instruments were operable.
The inspectors evaluated whether missed and/or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors selected events that involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement to determine if the licensee had identified the cause and had implemented corrective actions. The inspectors reviewed the licensees assessment of any positive sample results and reviewed any associated radioactive effluent release data that was the source of the released material.
The inspectors selected structures, systems, or components that involve or could reasonably involve a credible mechanism for licensed material to reach ground water, and assessed whether the licensee had implemented a sampling and monitoring program sufficient to detect leakage to ground water.
The inspectors evaluated whether records important to decommissioning, as required by 10 CFR, Part 50.75(g), were retained in a retrievable manner.
The inspectors reviewed any significant changes made by the licensee to the ODCM as the result of changes to the land census, long-term meteorological conditions, or modifications to the sampler stations since the last inspection. The inspectors reviewed technical justifications for any changed sampling locations to evaluate whether the licensee performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.
The inspectors assessed whether the appropriate detection sensitivities with respect to the ODCM where used for counting samples. The inspectors reviewed the quality control program for analytical analysis.
The inspectors reviewed the results of the licensees Interlaboratory Comparison Program to evaluate the adequacy of environmental sample analyses performed by the licensee. The inspectors assessed whether the interlaboratory comparison test included the media/nuclide mix appropriate for the facility. The inspectors reviewed the licensees determination of any bias to the data and the overall effect on the Radiological Environmental Monitoring Program.
These inspection activities constituted one sample as defined in IP 71124.07-05
b. Findings
No findings were identified.
.2 Groundwater Protection Initiative Implementation (02.03)
a. Inspection Scope
The inspectors reviewed monitoring results of the Groundwater Protection Initiative to evaluate whether the licensee had implemented the program as intended and to assess whether the licensee had identified and addressed anomalous results and missed samples.
The inspectors evaluated the licensees implementation of the minimization of contamination and survey aspects of the Groundwater Protection Initiative and the Decommissioning Planning Rule requirements in 10 CFR 20.1406 and 10 CFR 20.1501.
The inspectors reviewed leak and spill events and 10 CFR 50.75
- (g) records and assessed whether the source of the leak or spill was identified and appropriately mitigated.
The inspectors assessed whether unmonitored leaks and spills where evaluated to determine the type and amount of radioactive material that was discharged. The inspectors assessed whether the licensee completed offsite notifications in accordance with procedure.
The inspectors reviewed evaluations of discharges from onsite contaminated surface water bodies and the potential for ground water leakage from them. The inspectors assessed whether the licensee properly accounted for these discharges as part of the Effluent Release Reports.
The inspectors assessed whether onsite ground water sample results and descriptions of any significant on-site leaks or spills into ground water were documented in the Annual Radiological Environmental Operating Report or the Annual Radiological Effluent Release Report.
The inspectors determined if significant new effluent discharge points where updated in the ODCM and the assumptions for dose calculations were updated as needed.
These inspection activities constituted one sample as defined in IP 71124.07-05
b. Findings
No findings were identified.
.3 Problem Identification and Resolution (02.04)
a. Inspection Scope
The inspectors assessed whether problems associated with the Radiological Environmental Monitoring Program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved the Radiological Environmental Monitoring Program.
These inspection activities constituted one sample as defined in IP 71124.07-05
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Unplanned Power Changes per 7000 Critical Hours
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Power Changes per 7000 Critical Hours Performance Indicator (1E03) for the period from the second quarter 2015 through the first quarter 2016. To determine the accuracy of the Performance Indicator (PI) data reported during those periods, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, condition reports, maintenance rule records, event reports and NRC Integrated Inspection Reports for the period of April 1, 2015, through March 31, 2016, 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. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one unplanned power changes 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 (MS05) for the period from the second quarter 2015 through the first quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, 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, condition reports, event reports and NRC Integrated Inspection Reports for the period of April 1, 2015, through March 31, 2016, 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. 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.
4OA2 Identification and Resolution of Problems
.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 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 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 January 2016 through June 2016, 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.
Observations: The inspectors noted during this time period a potential trend in repetitive equipment issues, specifically issues being resolved through the licensees troubleshooting process. The inspectors reviewed the troubleshooting process documents, associated work orders, corrective actions, and causal evaluations (if completed) for the following issues:
- C containment spray pump failure to run due to a breaker issue;
- containment instrument air system low pressure alarms repeatedly received in the control room;
- intermittent 2400 volt (V) ground on the safety-related electrical system;
- DG ventilation fan, V-24A, found tripped (twice);
- moisture separator and heater drain tank, T-5, level control issues; and
- the inability to clear the A isophase bus cooler low cooling air flow alarm when placed in service.
The inspectors also reviewed the licensees troubleshooting benchmark snapshot assessment. This assessment was performed based on the licensees identification of a potential trend.
Through the review, it appeared that identified equipment problems were being entered into the CAP in a timely manner. There were some examples identified where more complete and accurate documentation of the identified problem was needed. Since troubleshooting is an integral part of cause determination, it is essential that a thorough and documented initial investigation of the as-found condition be made prior to disturbing installed equipment or components to ensure that evidence leading to the cause(s) of a failure is not destroyed or lost. One example was when the C containment spray pump would not run. A complete and accurate set of data was not gathered or documented prior to personnel removing the breaker from the cubicle before starting intrusive work.
An apparent cause was not identified during the causal evaluation process for this issue due to a lack of initial information gathered. Also, in this instance, the timeliness of resolution of the issue was affected by the need to perform additional troubleshooting activities which required the plant to be in a certain configuration. The pump was determined to have been operable prior to and leading up to this event and passed its surveillance test run after intrusive work on the breaker.
In general, it appeared that the licensee completed corrective actions that were appropriately focused to correct the problem and to address root or apparent and contributing causes. It also appeared that the licensee generally appropriately considered the extent of condition and causes when evaluating problems and appropriately reviewed previous occurrences/operating experience to aid in the development of corrective actions.
Some weaknesses in the classification and prioritization of a problems resolution, commensurate with safety significance, were identified during this review. An example was when the moisture separator and heater drain tank level control valve, CV-0608, was not operating as designed. Condition reports written for identified deficiencies with this valve were not correctly classified as adverse conditions within the licensees CAP.
The appropriate level of corrective actions to either evaluate the condition or correct the condition were not completed and the issues identified contributed to additional problems with the level control system later. These issues have been corrected and did not have an adverse impact on plant operations.
Also during this review, it was identified that not all actions taken resulted in correcting the identified problem. One example was when the 1-1 DG ventilation fan, V-24A, was found with no light indication for the control switch and the fan breaker was found tripped on two different occasions approximately one month apart. Initially, the licensee replaced the breaker without entering the troubleshooting process. After the second trip, the licensee entered the troubleshooting process and identified excessive heating and signs of arcing on the temperature switch, which was determined to have caused the trip previously, as well. The licensee completed an apparent cause evaluation to review organizational and programmatic components of why there was a repeat failure. It was identified that personnel did not exhibit teamwork and advocacy necessary to resolve an equipment issue and were not in the mindset to prevent repeat equipment issues.
These two instances of the ventilation fan tripping did not cause the 1-1 DG to be declared inoperable since it was during colder months and the redundant train of ventilation was functional. However, this was identified as an example of underlying organizational and programmatic weaknesses which prevented the issue from being thoroughly evaluated after the first event.
This review constituted one semi-annual trend inspection sample as defined in IP 71152-05.Findings
b. Findings
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 (Closed) Licensee Event Report 05000255/2016-002-00:
Both Control Room Ventilation Filtration Trains Declared Inoperable On March 24, 2016, at approximately 2:11 a.m., both trains of the control room ventilation filtration system were declared inoperable due to the inability to close the control room envelope boundary door. This event was caused by personnel inadvertently operating the hand wheel for the door to the closed position with the door still open. This caused the doors locking bolts to extend, engage an interlock in the door, and prevent full closure. Additionally, the personnel operating the door were unaware of the interlock and continued turning the hand wheel, which was identified as a potential cause of the failure of a bushing inside the doors operating mechanism. The bushing failure prevented both normal and emergency operation of the doors locking bolts and prevented full closure of the door. Corrective actions included replacing the failed bushing and adding detail to the operating instructions for the door to ensure personnel were aware of the interlock. These actions are reasonable to prevent recurrence. Documents reviewed are listed in the Attachment to this report. This Licensee Event Report (LER) is closed.
This event follow-up review constituted one sample as defined in IP 71153-05.
4OA5 Other Activities
.1 (Closed) Notice of Violation and Apparent Violation 05000255/2015012-01;
Inaccurate/Incomplete Information Provided For Relief Request 4-18 In March of 2015, the licensee notified the NRC that the information provided to the NRC in letter PNP 2014-015 Relief Request Number RR 4-18 - Proposed Alternative, Use of Alternate ASME Code Case N-770-1 Baseline Examination, dated February 25, 2014, was not complete and accurate in all material respects. Specifically, in letter PNP 2014-015, the licensee stated, In the unlikely case that crack initiation were to occur, crack growth calculations considering primary water stress corrosion cracking as the failure mechanism demonstrate that the hot leg drain nozzle weldment satisfies ASME Code acceptance criteria for 60 effective full power years (EFPY) for a circumferential flaw, and more than 34 years for an axial flaw. However, this statement was not correct/accurate because of an error in a supporting vendor calculation related to misapplication of the normal operating pressure loads into the piping segment stress model which introduced a bending moment into the hot leg pipe wall rather than an expected radial and axial expansion loads typical of internally applied pressure in the piping. In particular, the induced bending moment created a compressive (i.e., less tensile) stress behavior in and around the inside of the nozzle-to-pipe weld. As a result of the erroneously applied pressure load, the radial and hoop tensile stresses at the weld inside diameter were reduced rather than increased. The net effect of this error on the analysis results was that the ASME Code acceptance criteria were met for only 20 EFPY for a postulated circumferential flaw and 11.3 EFPY for a postulated axial flaw.
Palisades EFPY of operation had exceeded both of these values at the point that the calculation error was discovered. This condition was not an immediate safety concern because the licensee demonstrated an adequate basis for continued operability of the affected welds. The licensee subsequently submitted corrected calculations to the NRC, completed an Apparent Cause Evaluation, and implemented corrective actions.
On September 17, 2015, the NRC identified an Apparent Violation (AV) 05000255/
2015012-01 of 10 CFR Part 50.9, related to a failure to provide information that was complete and accurate in all material respects to the NRC in letter PNP 2014-015.
By letter dated November 24, 2015, the NRC determined that a Violation of 10 CFR 50.9 occurred and issued a Notice of Violation (NOV) as the failure to provide complete and accurate information was of significant safety concern to the NRC because the inaccurate information impacted the NRCs ability to perform its regulatory function.
Specifically, the NRC had relied on the inaccurate information to make a licensing decision for approval of Relief Request 4-18. If the information had been correct, the NRC would have undertaken substantial further inquiry and/or reconsidered its regulatory position. Therefore, this violation was categorized in accordance with the NRC Enforcement Policy at Severity Level III. The NRC also concluded that information regarding:
- (1) the reason for the violation;
- (2) the corrective actions that had been taken and the results achieved; and
- (3) the date when full compliance will be achieved was adequately addressed in licensee letters, dated October 17, 2015 and October 28, 2015.
The inspectors conducted additional reviews as discussed in Section 4OA5.2 (below) to confirm that the licensee had implemented adequate corrective actions for this issue and this NOV and AV are closed.
.2 Follow-Up on Traditional Enforcement Actions Including Violations, Deviations
Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders Inspection Activities (92702)
a. Inspection Scope
From June 6, 2016, through June 8, 2016, the inspectors conducted a review of the licensees Apparent Cause Evaluation, 50.9 Violation of Relief Request 4-18 and associated corrective actions, attended biennial engineering training, reviewed Quality Assurance Audits of Engineering, and conducted interviews with the licensees Engineering Director and vendor staff to determine whether:
- the corrective actions for NOV and AV 05000255/2015012-01; Inaccurate/Incomplete Information Provided For Relief Request 4-18 had been fully implemented and that licensee management assigned responsibility for implementing corrective actions, including any necessary changes in procedures and practices;
- an adequate cause analysis and generic implication evaluation had been completed; and
- follow-up actions were initiated for deviations noted in any recent Quality Assurance audits conducted by the licensee of the inspection area in which traditional enforcement actions were identified.
The inspectors performed these reviews to evaluate compliance with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements. The corrective action documents reviewed by the inspectors are listed in the Attachment to this report.
b. Findings
No findings were identified.
4OA6 Management Meetings
.1
Exit Meeting Summary
On July 7, 2016, the inspectors presented the inspection results to Mr. A. Vitale, Site Vice President, 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 follow-up inspection for Apparent Violation 05000255/2015012-01 with Mr. A. Vitale, Site Vice President, and other members of the licensee staff, on June 8, 2016; and
- The results for the Radiological Environmental Monitoring Program inspection with Mr. A. Vitale, Site Vice President, and other members of the licensee staff, on June 27, 2016.
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
- A. Williams, General Manager Plant Operations
- T. Mulford, Operations Manager
- B. Baker, Operations Manager - Shift
- J. Borah, Engineering Manager, Systems and Components
- R. Craven, Production Manager
- T. Davis, Licensing Specialist
- B. Dotson, Acting Regulatory Assurance Manager
- D. Nestle, Radiation Protection Manager
- J. Hardy, Acting Director of Regulatory and Performance Improvement
- J. Haumersen, Site Projects and Maintenance Services Manager
- G. Heisterman, Maintenance Manager
- M. Lee, Operations Manager - Support
- D. Lucy, Outage Manager
- D. Malone, Emergency Planning Manager
- W. Nelson, Training Manager
- K. OConnor, Engineering Manager, Design and Programs
- C. Plachta, Nuclear Independent Oversight Manager
- P. Russell, Site Engineering Director
- M. Schultheis, Performance Improvement Manager
- M. Soja, Chemistry Manager
- J. Tharp, Security Manager
U.S. Nuclear Regulatory Commission
- E. Duncan, Chief, Reactor Projects Branch 3
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
- 05000255/2015012-01 AV Inaccurate/Incomplete Information Provided For Relief Request 4-18 (Section 4OA5)
- 05000255/2015012-01 NOV Inaccurate/Incomplete Information Provided For Relief Request 4-18 (Section 4OA5)
- 05000255/2016-002-00 LER Both Control Room Ventilation Filtration Trains Declared Inoperable (Section 4OA3)
Discussed
None