IR 05000255/2016009

Evaluations of Changes, Tests and Experiments and Permanent Plant Modifications Baseline Inspection Report 05000255/2016009

ML16217A081
Person / Time
Site:	Palisades
Issue date:	08/02/2016
From:	Robert Daley Engineering Branch 3
To:	Vitale A Entergy Nuclear Operations
References
IR 2016009
Download: ML16217A081 (18)

Text

UNITED STATES ust 2, 2016

SUBJECT:

PALISADES NUCLEAR PLANT - EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000255/2016009

Dear Mr. Vitale:

On July 15, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments, and Permanent Plant Modifications inspection at your Palisades Nuclear Plant. The enclosed inspection report documents the inspection results, which were discussed on July 15, 2016, with members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

One NRC-identified finding of very-low safety significance (Green) was identified during this inspection. The finding was determined to involve a violation of NRC requirements. However, because of the very-low safety significance, and because the issue was entered into your Corrective Action Program, the NRC is treating the issue as Non-Cited Violation in accordance with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the subject or severity of the Non-Cited-Violation, 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 copies to the Regional Administrator, Region III; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Palisades Nuclear Plant.

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

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-255 License No. DPR-20

Enclosure:

IR 05000255/2016009

REGION III==

Docket No: 50-255 License No: DPR-20 Report No: 05000255/2016009 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Dates: June 27 - July 15, 2016 Inspectors: A. Shaikh, Senior Reactor Inspector (Lead)

I. Khan, Reactor Inspector L. Rodriguez, Reactor Inspector V. Petrella, Reactor Inspector L. Ward, Reactor Inspector Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report 05000255/2016009; 06/27/2016 - 07/15/2016; Palisades Nuclear Plant;

Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications.

This report covers a 2-week announced baseline inspection on evaluations of changes, tests, and experiments, and permanent plant modifications. The inspection was conducted by Region III based engineering inspectors. One finding of very-low safety significance was identified by the inspectors. The finding was considered a Non-Cited Violation of U.S. Nuclear Regulatory Commission (NRC) regulations. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Cross-cutting aspects were determined using IMC 0310, Aspects within the Cross-Cutting Areas. Findings and/or violations for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs 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: Barrier Integrity

Green: The inspectors identified a Severity Level IV, Non-Cited Violation of Title 10 of the Code of Federal Regulations (CFR), Part 50.59, Changes, Tests, and Experiments, and an associated finding of very low safety significance (Green) for the licensees failure to maintain records of a change in the facility which included a written evaluation that provided the bases for the determination that the change did not require a license amendment. Specifically, the licensee failed to have a written evaluation that provided the bases for why removal of the 8-hour operator rounds credited to detect a Spent Fuel Pool (SFP) dilution event from the Final Safety Analysis Report did not require a license amendment. The licensee entered this issue into their Corrective Action Program (CAP)as CR-PLP-2016-03055 and issued a standing order to log SFP level every eight hours as an immediate corrective action. The licensees planned corrective actions include preparation of a 10 CFR 50.59 evaluation for the change.

The inspectors determined that the failure to perform a 10 CFR 50.59 evaluation for the change to the Final Safety Analysis Report which removed the eight hour operator rounds credited to detect a SFP dilution event was contrary to 10 CFR 50.59(d)(1), and was a performance deficiency. The inspectors determined the performance deficiency was more than minor, and a finding, because it was associated with the barrier integrity cornerstone attribute of Configuration Control and adversely affected the associated Cornerstone Objective of ensuring that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the removal of the 8-hour operator rounds is associated with the boron concentration reactivity control in the SFP and could adversely affect the fuel claddings function to protect the public from radionuclide releases. In addition, the associated violation was determined to be more-than-minor because the inspectors could not reasonably determine that the changes would not have ultimately required NRC prior approval. The inspectors evaluated the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, Exhibit 3, for the Barrier Integrity cornerstone and were directed to further evaluate the significance of the finding using IMC 0609 Appendix M, Significance Determination Process Using Qualitative

Criteria, dated April 12, 2012. The inspectors performed the qualitative evaluation described in IMC 0609, Appendix M, and determined the significance of the finding to be of very low safety significance (Green) by considering the availability of other measures the licensee had in place to detect a SFP dilution event. In accordance with Section 6.1.d of the NRC Enforcement Policy this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very-low safety significance (i.e., Green finding). The inspectors determined the associated finding had a cross-cutting aspect in the area of Human Performance because the licensee did not ensure their staff were adequately trained in the implementation of the 10 CFR 50.59 rule. Specifically, the licensee staff did not realize that a change which fundamentally alters the existing means of performing or controlling design functions (removal of the 8-hour operator rounds for detecting a SFP dilution event in lieu of an automatic alarm) is adverse and requires an evaluation. (Section 1R17.1.b) [H.9]

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications

.1 Evaluation of Changes, Tests, and Experiments

a. Inspection Scope

The inspectors reviewed two safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR), Part 50.59 to determine if the evaluation was adequate and that prior U.S. Nuclear Regulatory Commission (NRC) approval was obtained as appropriate. The inspectors also reviewed 25 screenings and/or applicability determinations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59, and that sufficient documentation existed to confirm that a license amendment was not required; the safety issue requiring the change, tests or experiment was resolved; the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and the design and licensing basis documentation was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute (NEI) Document 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.

This inspection sample constituted 2 evaluations and 25 samples of screenings and/or applicability determinations as defined in Inspection Procedure 71111.17-04. The inspectors could not review the minimum sample size of 6 evaluations because the licensee only performed 2 evaluations during the triennial sample period.

b. Findings

Failure to Document 50.59 Evaluation for Removal of 8-Hour Operator Rounds from the Final Safety Analysis Report

Introduction:

The inspectors identified a Severity Level IV, Non-Cited Violation (NCV)of 10 CFR 50.59, Changes, Tests, and Experiments, and an associated finding of very-low safety significance (Green) for the licensees failure to maintain records of a change in the facility which included a written evaluation that provided the bases for the determination that the change did not require a license amendment. Specifically, the licensee failed to have a written evaluation that provided the bases for why removal of the 8-hour operator rounds credited to detect a Spent Fuel Pool (SFP) dilution event from the Final Safety Analysis Report (FSAR) did not require a license amendment.

Description:

In 2001, the licensee submitted a license amendment request to the NRC to change Technical Specification (TS) 3.7.15, Spent Fuel Pool (SFP) Boron Concentration, among other things. As part of the changes to the TS, the licensee completed a boron dilution analysis to support crediting soluble boron in the SFP in order to meet SFP subcriticality requirements. The licensee concluded, based on the analysis, that an unplanned or inadvertent event that would dilute the SFP to the point where it could challenge SFP subcriticality was not credible. The most limiting dilution scenario was determined to be a 1.5 inch fire protection hose flowing into the SFP. In this scenario, it would take over 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> to dilute the SFP boron concentration to the point where it could challenge SFP subcriticality. In 2002, the NRC issued Palisades License Amendment No. 207 which granted the licensees requested TS change. The NRC Safety Evaluation Report (SER) for the approved license amendment concluded that the operating practice of an operator round every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, in combination with other measures, was adequate to detect a dilution event prior to the event challenging SFP subcriticality. The other measures credited in the SER to detect a SFP dilution event were:

(1) the large volume of water required for a dilution event to challenge SFP subcriticality;

(2) the flow rates and dilution times that could challenge SFP subcriticality;

(3) the licensees administrative requirements for maintaining the SFP;

(4) the TS controlled SFP boron concentration; and

(5) the 7-day SFP boron concentration sampling required by TS.

As a result of the license amendment, Section 9.11.3.4, Prevention of Criticality During Transfer and Storage, and Section 14.19, Fuel Handling Incident, of the FSAR were revised to include the following statement, operating practice requires at least one operator round each 8-hour shift. In 2009, the licensee changed their operator shifts from 8-hour shifts to 12-hour shifts. The change adversely affected the credited operator rounds because they were no longer being performed at the frequency which had been credited to detect a SFP dilution event. In 2011, the licensee captured the discrepancy between the FSAR statement and the operating practice in CR-PLP-2011-06580.

On June 5, 2013, the licensee completed Licensing Basis Document Change Request 13-015 which removed from FSAR Section 9.11.3.4 and Section 14.19 the reference to the credited operator rounds each eight hour shift for detecting a SFP dilution event. This FSAR change was reviewed under Process Applicability Determination 13-0132 which incorrectly determined that a 10 CFR 50.59 evaluation was not required. Specifically, as discussed in Section 4.2.1.2 of NRC endorsed guidance document NEI 96-07, Guidelines for 10 CFR 50.59 Implementation, a change which fundamentally alters the existing means of performing or controlling design functions (removal of the eight hour operator rounds for detecting a SFP dilution event) should be conservatively treated as adverse and screened in.

Process Applicability Determination 13-0132 attempted to justify the change was not adverse by crediting a SFP level alarm that would annunciate in the main control room to detect the SFP dilution event. The alarm is non-safety related and not seismically qualified. As discussed in section 4.2.1.2 of NEI 96-07, changes that include replacement of automatic action by manual action (or vice versa) should be conservatively treated as adverse and screened in. Therefore, the inspectors determined the licensee was required to perform a 10 CFR 50.59 evaluation to remove from the FSAR the 8-hour operator rounds credited to detect a SFP dilution event.

The removal of the 8-hour operator rounds from the FSAR adversely affects the licensing basis assumption that an unplanned or inadvertent event that would dilute the SFP to the point where it could challenge SFP subcriticality is not credible. Therefore, due to the incorrect change, the SFP criticality event might be a more credible event that could adversely impact the fuel claddings ability to perform its barrier function.

The licensee captured the inspectors concern in their Corrective Action Program as CR-PLP-2016-03055. The licensees immediate corrective actions to address the safety concern included issuance of a standing order to log SFP level every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The licensees planned corrective actions include preparation of a 10 CFR 50.59 evaluation for the change. Although the issue involves an adverse change to how a SFP dilution event is detected, it is important to note that the licensee has the following additional measures that were not credited in the licensing basis to detect the event:

(1) SFP high-level alarm;

(2) additional SFP level instrumentation and annunciation installed in response to NRC Order EA-12-049 (FLEX);

(3) fire protection pump start alarm on a loss of fire protection water inventory;

(4) waste drain tank high-level alarm from spilled SFP inventory;

(5) SFP level video monitor in the control room; and

(6) operator rounds being performed each 12-hour shift.

Analysis:

The inspectors determined that the failure to perform a 10 CFR 50.59 evaluation for the change to the FSAR which removed the 8-hour operator rounds credited to detect a SFP dilution event was contrary to 10 CFR 50.59(d)(1) and was a performance deficiency. Specifically, the licensee failed to provide the basis for why a license amendment was not required to remove the 8-hour operator rounds from the FSAR. The inspectors determined the performance deficiency was more-than-minor, and a finding, because it was associated with the barrier integrity cornerstone attribute of Configuration Control and adversely affected the associated Cornerstone Objective of ensuring that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the removal of the 8-hour operator rounds is associated with the boron concentration reactivity control in the SFP and could adversely affect the fuel claddings function to protect the public from radionuclide releases.

In addition, the associated violation was determined to be more-than-minor because the inspectors could not reasonably determine that the changes would not have ultimately required NRC prior approval.

Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process instead of the significance determination process (SDP) because they are considered to be violations that potentially impede or impact the regulatory process. This violation is associated with a finding that has been evaluated by the SDP and communicated with an SDP color reflective of the safety impact of the deficient licensee performance. The SDP, however, does not specifically consider the regulatory process impact. Thus, although related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding.

The inspectors determined the finding could be evaluated using the SDP in accordance with Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Using Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012, Table 2, the inspectors determined that the finding affected the Barrier Integrity cornerstone. As a result, the inspectors evaluated the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, Exhibit 3, for the Barrier Integrity cornerstone. The inspectors answered Yes to Question D.4 in Exhibit 3, Barrier Integrity Screening Questions, because the finding does affect the SFP soluble boron concentration during a spent fuel pool dilution event. As a result of answering Yes to Question D.4, the inspectors were required to evaluate the significance of the finding using IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria, dated April 12, 2012.

The inspectors performed the qualitative evaluation described in IMC 0609, Appendix M, and determined the significance of the finding to be of very-low safety significance (Green). The inspectors arrived at this conclusion by considering the availability of other credited measures to detect a SFP dilution event such as:

(1) the large volume of water required for a dilution event to challenge SFP subcriticality;

(2) the flow rates and dilution times that could challenge SFP subcriticality;

(3) the licensees administrative requirements for maintaining the SFP;

(4) the TS controlled SFP boron concentration; and

(5) the 7-day SFP boron concentration sampling required by TS. In addition, the inspectors also considered the following measures available to the licensee that were not credited in the licensing basis to detect a SFP dilution event:

(1) SFP high-level alarm;

(2) additional SFP level instrumentation and annunciation installed in response to NRC Order EA-12-049 (FLEX);

(3) fire protection pump start alarm on a loss of fire protection water inventory;

(4) waste drain tank high level alarm from spilled SFP inventory;

(5) SFP level video monitor in the control room; and

(6) operator rounds being performed each 12-hour shift.

In accordance with Section 6.1.d of the NRC Enforcement Policy this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very-low safety significance (i.e., Green finding).

The inspectors determined the associated finding had a cross-cutting aspect in the area of Human Performance because the licensee did not ensure their staff were adequately trained in the implementation of the 10 CFR 50.59 rule. Specifically, the licensee staff did not realize that a change which fundamentally alters the existing means of performing or controlling design functions (removal of the 8-hour operator rounds for detecting a SFP dilution event in lieu of an automatic alarm) is adverse and requires an evaluation. (Section 1R17.1.b) [H.9]

Enforcement:

Title 10 CFR Part 50.59, Changes, Tests, and Experiments, Section (d)(1) requires the licensee to maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant 10 CFR 50.59(c).

These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment.

Contrary to the above, since June 5, 2013, the licensee failed to maintain records of a change in the facility which included a written evaluation that provided the bases for the determination that the change did not require a license amendment. Specifically, the licensee failed to have a written evaluation that provided the bases for why removal of the 8-hour operator rounds credited to detect a SFP dilution event from the FSAR did not require a license amendment.

This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy because it was a Severity Level IV violation and was entered into the licensees CAP as CR-PLP-2016-03055. The licensees immediate corrective actions to address the safety concern included issuance of a standing order to log SFP level every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The licensees planned corrective actions include preparation of a 10 CFR 50.59 evaluation for the change. (NCV 05000255/2016009-01; Failure to Document 50.59 Evaluation for Removal of 8-Hour Operator Rounds from the Final Safety Analysis Report)

.2 Permanent Plant Modifications

a. Inspection Scope

The inspectors reviewed 15 permanent plant modifications that had been installed in the plant during the last 3 years. This review included in-plant walk-downs for the SFP.

The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:

the supporting design and licensing basis documentation was updated; the changes were in accordance with the specified design requirements; the procedures and training plans affected by the modification have been adequately updated; the test documentation as required by the applicable test programs has been updated; and post-modification testing adequately verified system operability and/or functionality.

The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report.

This inspection constituted fifteen permanent plant modification samples as defined in Inspection Procedure 71111.17-04.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Condition Reports

a. Inspection Scope

The inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent plant modifications and evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification, and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the Attachment to this report.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

The inspectors presented the inspection results to Mr. P. Russell and other members of the licensee staff on July 15, 2016. The licensee personnel acknowledged the inspection results presented, and did not identify any proprietary content.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

A. Vitale, Site Vice President

P. Russell, Director, Site Engineering

D. Mannai, Fleet Senior Manager, Regulatory Assurance

B. White, Engineering Supervisor

J. Erickson, Senior Engineer, Regulatory Assurance

D. DePuydt, Senior Staff Engineer

A. Duluc, Engineer

S. Bunting, Engineer

B. Dotson, Regulatory Assurance Specialist

U.S. Nuclear Regulatory Commission

A. Nguyen, Senior Resident Inspector

J. Boettcher, Resident Inspector

LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System

CAP Corrective Action Program

CFR Code of Federal Regulations

IMC Inspection Manual Chapter

NCV Non-Cited Violation

NEI Nuclear Energy Institute

NRC U.S. Nuclear Regulatory Commission

PARS Publicly Available Records

SDP Significance Determination Process

SER Safety Evaluation Report

SFP Spent Fuel Pool

TS Technical Specification

LIST OF ITEMS

Opened and Closed

05000255/2016009-01 NCV Failure to Document 50.59 Evaluation for Removal of Eight Hour Operator Rounds from the FSAR (Section 1R17.1.b)

Discussed

None