IR 05000255/2019002
| ML19210D321 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/26/2019 |
| From: | Chuck Norton NRC/RGN-III |
| To: | Arnone C Entergy Nuclear Operations |
| References | |
| IR 2019002 | |
| Download: ML19210D321 (33) | |
Text
July 26, 2019
SUBJECT:
PALISADES NUCLEAR PLANT, UNIT 1INTEGRATED INSPECTION REPORT 05000255/2019002
Dear Mr. Arnone:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant, Unit 1. On July 9, 2019, the NRC inspectors discussed the results of this inspection with Mr. D. Corbin, Acting Site Vice President and other members of your staff.
The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance or severity of the violation documented in this inspection report, 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; and the NRC Resident Inspector at Palisades.
If you disagree with a cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Palisades. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Charles H. Norton, Acting Chief Branch 2 Division of Reactor Projects
Docket No. 05000255 License No. DPR-20
Enclosure:
As stated
Inspection Report
Docket Number:
05000255
License Number:
Report Number:
Enterprise Identifier: I-2019-002-0061
Licensee:
Entergy Nuclear Operations, Inc.
Facility:
Palisades Nuclear Plant
Location:
Covert, MI
Inspection Dates:
April 1, 2019 to June 30, 2019
Inspectors:
B. Bartlett, Project Engineer
N. Feliz-Adorno, Senior Reactor Inspector
E. Fernandez, Reactor Inspector
M. Holmberg, Senior Reactor Inspector
M. Jones, Reactor Inspector
P. Laflamme, Senior Resident Inspector
J. Mancuso, Resident Inspector
V. Myers, Senior Health Physicist
J. Winslow, Resident Inspector
Approved By:
Charles H. Norton, Acting Chief
Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Palisades Nuclear Plant in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Inadequate Ultrasonic Examination of Reactor Head Nozzles Results in Operation with Pressure Boundary Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000255/2019002-01 Open/Closed
[H.2] - Field Presence 71111.08P The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of Technical Specification (TS) 3.4.13.a, Reactor Coolant System Operational Leakage, for the licensees failure to place the plant in Mode 3 (Hot Standby) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 (Cold Shutdown) within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> with the plant in Mode 1 (Power Operation) during a portion of operating Cycle 26 with pressure boundary LEAKAGE present at reactor vessel closure head (RVCH) penetration nozzle 25. In particular, the licensees UT contractor mischaracterized flaw indications, and thus had not identified them as flaws before they resulted in operation with the pressure boundary LEAKAGE. The inspectors determined the condition was reasonably foreseeable and preventable by the licensee as there were several weaknesses in the licensees oversight of its contractor that mischaracterized the nozzle flaw indications.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000255/2013005-06 Qualification Basis for Safety-Related Agastat Relays and Molded Case Circuit Breakers 71152 Closed LER 05000255/2018003-00 LER 2018-003-00 Indications Identified in Reactor Pressure Vessel Head Nozzle Penetrations 71111.08P Closed URI 05000255/2018004-01 Potential Failure to Identify/Correct Rejectable Flaws in Reactor Pressure Vessel Head Penetration 71111.08P Closed
PLANT STATUS
The plant began the inspection period at rated thermal power, and remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated readiness to cope with external flooding from May 23 to May 28, 2019
Summer Readiness Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated summer readiness of offsite and alternate alternating current (AC) power systems on May 28, 2019
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Right Train Control Room Heating, Ventilation, and Air Conditioning (CRHVAC)during Left Train CRHVAC maintenance on May 8 and 9, 2019
- (2) Safeguards Transformer 1-1 System on May 28, 2019
- (3) P-66A, Right Train High Pressure Safety Inspection System following check valve testing on June 27, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Fire Area 9: Screen House/Intake Structure during the week of April 1, 2019
- (2) Fire Area 24: Auxiliary Feed Water (AFW) Pump Room during the week of April 1, 2019
- (3) Fire Area 1: Control Room and Fire Area 33: Technical Support Center during the week of April 1, 2019
- (4) Fire Area 29-31: Mechanical Equipment Rooms, on May 24, 2019
- (5) Fire Area 4: 1C 2.4KV Switchgear Room on June 20, 2019
71111.07T - Heat Sink Performance Triennial Review (IP Section 02.02)
The inspectors evaluated heat exchanger/sink performance on the following:
- (1) Containment Air Coolers VHX-1, VHX-2, VHX-3, Cooled by Service Water
- (2) Diesel Generator 1-2 Jacket Water Heat Exchanger, Cooled by Service Water
- (3) Ultimate Heat Sink, IP 71111.07T Sections 02.02.d.5 and 02.02.d.6 were completed
===71111.08P - Inservice Inspection Activities (PWR)
PWR Inservice Inspection Activities Sample (IP Section 03.01) (1 Partial)
(1)
(Partial)
The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from June 17, 2019 to June 27, 2019:
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities
- Reactor head penetration nozzle nonvisual examinations completed during the 2018 refueling outage and during previous outages
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Training/Examinations (IP Section 03.02)===
- (1) The inspectors observed and evaluated a Licensed Operator Requalification As Found Exam on June 4, 2019
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Control Room Ventilation System during the week of April 1, 2019
- (2) Chemical and Volume Control System on June 24, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Elevated risk for breaker 52-1214, Motor Control Center 22 and 24 480 volt feeder breaker maintenance on May 1, 2019
- (2) Elevated risk due to geomagnetic storm, planned battery charger #1 maintenance and testing, and dry fuel cask inspections during the week of May 13, 2019
- (3) Elevated risk for planned P-7B, Service Water Pump maintenance and emergent maintenance on 1-1 Emergency Diesel Generator (EDG) during the week of May 6, 2019
- (4) Elevated Risk due to 1-1 EDG speed droop relay replacement on June 20, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (4 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Evaluation of 2.4 KV Safeguards Power Supply on April 25, 2019 (2)1-1 EDG operability determination after failure to start during surveillance testing on May 7, 2019
- (3) Evaluation of Right Channel Safety Injection Actuation System test circuitry on May 24, 2019
- (4) Evaluation of 1-1 EDG Indicating Lights for Parallel/Unit Selector Switch on June 4, 2019
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Engineering Change (EC) 81531, Main Transformer Cooler Bank 5 Pump from Temporary Power and EC 82148 Supplemental Cooling to EX-10 Main Transformer from May 31 through June 20, 2019
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) QO-5 after CV-3070, P-66B High Pressure Safety Injection Pump Subcooling Valve Actuator maintenance on April 8, 2019
- (2) MO-33B after Right Train CRHVAC maintenance on April 19, 2019 (3)1-1 EDG Engine A Start Relay replacement on May 8, 2019
- (4) Testing after Battery Charger #1 preventative maintenance on May 13, 2019 (5)1-1 EDG speed droop relay replacement on June 20, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
FLEX Testing (IP Section 03.02)
- (1) P-1003, FLEX Pump One Year Operational Test as documented in WO 52817904 on April 16, 2019
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) QO-20A, Low Pressure Safety Injection Pumps on June 18, 2019
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
- (1) QO-34, Control Rod Exercising on April 23, 2019
- (2) QI-39, Auxiliary Feedwater Actuation System Logic Test on May 15, 2019
- (3) RE-132, Diesel Generator 1-2 Load Reject Test on May 20, 2019
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated an Emergency Response Organization (ERO) Drill on April 10, 2019
- (2) The inspectors evaluated an ERO Drill on May 22,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Calibration and Testing Program (IP Section 02.02) (1 Partial)
The inspectors evaluated the calibration and testing program implementation.
(1)
(Partial)
The inspectors completed all items in section 02.02 with the exception of 02.02(c):
Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors
- SAM 54, SN 285662
- GEM-5, SN 1712-186
- ARGOS-5AB, SN 1712-183
Failure to Meet Calibration or Source Check Acceptance Criteria
- Telepole 6605-093, 01/28/2019
- HD-09A Air Sampler 23697, 01/10/2019
- HD-09A Air Sampler 17380, 01/10/2019
Walk Downs and Observations (IP Section 02.01) (1 Sample)
The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.
- (1) The inspectors reviewed the following:
Portable Survey Instruments
- Ludlum 12-4, SN 326407
- Telepole, SN 6600-038
- RO-20, SN 11838
- Ludlum 117, SN 12045
- Ludlum 43-92, SN 273222
- AMP 100, SN 600798
Source Check Demonstration
- Telepole, SN 6600-038
- RO-20, SN 11838
- Ludlum 12-4, SN 326407
Area Radiation Monitors and Continuous Air Monitors
- Area monitor for radiologically controlled area hallway
- Area monitor for radioactive waste processing area East
- Area monitor for radioactive waste processing area West
- Air monitoring system for truckbay
- Air monitoring system for hot machine shop
- Air monitoring system for tool decon area Personnel Contamination Monitors, Portal Monitors and Small Article Monitors
- SAM 54, SN 285662
- ARGOS-5AB, SN 1712-185
- GEM-5, SN 091
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Instrumentation and Equipment (IP Section 02.04) (1 Sample)
The inspectors reviewed the following radioactive effluent discharge system surveillance test results:
- (1) The inspectors reviewed effluent flow measurements, air cleaning systems, and accident range effluent monitors
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) Unit 1 (10/01/2018-03/31/2019)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
- (1) Unit 1 (April 1, 2018 - March 31, 2019)
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)
- (1) Unit 1 (April 1, 2018 - March 31, 2019)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) Unit 1 (10/01/2018-03/31/2019)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample.
(IP Section 02.16) (1 Sample)
- (1) Unit 1 (10/01/2018-03/31/2019)
71152 - Problem Identification and Resolution
Annual Follow-Up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Licensee Cause Evaluation for Missed Flaw Indications Identified in Reactor Pressure Vessel Head Nozzle Penetrations as documented in CR-PLP-2018-05857 between June 17 and June 27, 2019
- (2) Adverse Cause Analysis for RPS Channel B Failure Resulting in an Automatic Reactor Trip on January 9, 2019, as documented in CR-PLP-2019-00117
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends with a focus on human performance issues that might be indicative of a more significant safety issue during the period from January 1, 2019 to June 30, 2019
71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000255/2018-003-00 Indications Identified in Reactor Pressure Vessel Head Nozzle Penetrations. ADAMS Accession: ML19003A239 The circumstances surrounding this LER are documented in the Results Section of this Report
INSPECTION RESULTS
Observation: Semi-Annual Trend Review 71152 The inspectors review was focused on human performance issues, but also considered the results of daily inspector CAP item screening and licensee trending efforts. The inspectors review nominally considered the 6 month period of January 2019 through June 2019, although some examples expanded beyond those dates when warranted by the scope of the trend.
The inspectors reviewed condition reports, trend reports, and human performance evaluations to address performance oversight at the site. During the inspection period, the NRC inspectors noted a few challenges where low level human performance errors occurred in multiple departments, including Operations, Maintenance, and Projects. Examples included an inadvertent fuse disconnect during maintenance activities which resulted in an unanticipated momentary loss of the 1D DC distribution system during live-dead-live checks, component cooling water system miss-alignment to two control rod drive mechanism housings resulting in a 40F increase in housing temperatures, bumping open a Main Steam Isolation Valve Bypass Valve motor power supply breaker with a fire hose during a planned fired drill, and hanging a danger tag on the wrong drain valve on the plant heating boiler system and then not identifying the error until after maintenance had been completed.
Although the above examples did not challenge safety function or equipment reliability, these issues illustrated a decline in the use of human performance tools to prevent errors while performing work in the field and signs of complacency; all of which could potentially impact nuclear safety.
The licensee appropriately entered these issues into the CAP and completed timely evaluations of these issues to determine the causes of the performance decline. Corrective actions included training, site-wide communications reinforcing standards and expectations, and a re-emphasis on the following human performance tools: pre-job briefs; procedure use and adherence; and verification and validation activities. The inspectors determined that the corrective actions taken to date appeared to be effective at addressing the identified gaps and plan to continue to evaluate these actions during routine observations and inspections.
Observation: RPS Channel B Failure Resulting in an Automatic Reactor Trip 71152 On January 9, 2019, the licensee experienced an automatic reactor trip and valid actuation of the auxiliary feedwater (AFW) system. The direct cause of the event was identified to be a loss of all power to the reactor protection system (RPS) BD matrix due to shorted capacitors associated with the RPS B channel and a blown fuse association with the RPS D channel BD matrix power supply. The inspectors reviewed the licensee's final adverse cause analysis after a failure evaluation of the RPS D channel BD matrix power supply and fuse was conducted.
The inspectors reviewed the results of the failure evaluation and discussed these results with the licensee. Using the results of the failure evaluation, the licensee identified that the RPS D channel BD matrix power supply module was no longer meeting its efficiency rating and was a causal factor. Additional corrective actions from the failure evaluation included creation of a periodic maintenance activity to perform periodic thermography on the power supplies to identify potential vulnerabilities to similar failure modes. The inspectors determined that the corrective actions were appropriate and timely based on the safety significance of the issue.
Observation: Licensee Cause Determination - Missed Flaw Indications Identified in Reactor Pressure Vessel Head Nozzle Penetrations 71152 On November 10, 2018, with the plant in Mode 6, during bare metal visual inspections of the reactor vessel closure head (RVCH), dried boric acid was identified in the area of reactor head nozzle 25, indicative of a through-wall flaw. The licensees contractor had recently completed ultrasonic (UT) examinations of this nozzle and the inspectors inquired if the licensees contractor had identified flaw indications or evidence of leakage during this examination. The inspectors questions prompted the licensees contractor to re-review nozzle 25 UT data and the contractor staff subsequently identified an inside diameter (ID)connected flaw indication and UT indications of leakage within the annulus behind nozzle 25 (e.g. UT leak path). Subsequently, the contractor performed a re-review of all nozzle UT data and subsequently applied an eddy current (ET) technique to the ID surface of nozzles 34 and 36 and identified an additional two nozzles with ID flaw indications (nozzles 33 and 36).
The results of the licensee's 2018 RVCH UT examination were documented in report 180-9291875-000 Palisades Unit 1, 1RO26 Reactor Head Inspection Report and included the following information: penetration nozzle 25 had an inside diameter connected axial 100 percent through-wall flaw indication with a 1.4 inch length; penetration nozzle 33 contained an inside diameter connected axial part through-wall flaw indication with a 0.890 inch length; and penetration nozzle 36 had two inside diameter connected part through-wall off-axis flaws that were recorded as 0.514 inch and 0.729 inch in length respectively. As a corrective action, the licensee performed just-in-time training on the flaw characteristics observed in nozzles 25 and 33 and this training was applied to re-inspection of the remainder of the reactor head nozzle population to ensure all flawed nozzles were identified. The licensee repaired the affected nozzles 25, 33 and 36 utilizing the contractor's (Framatome) half-nozzle replacement method prior to returning the RVCH to service. On January 3, 2019, the licensee issued LER 2018-003-00 Indications Identified in Reactor Pressure Vessel Head Nozzle Penetrations and reported this in accordance with 50.73(a)(2)(ii)(A) as a condition of the nuclear power plant, including its principal safety barriers, being seriously degraded. Additional information on the event can be found in Section 71153 of this report.
The licensee documented an apparent cause evaluation (ACA) for boric acid found at control rod drive nozzle 25 in CR-PLP-2018-05857. In this ACA, the licensee identified two direct causes of the boric acid deposit found at control rod drive nozzle 25: Direct Cause 1 - the Palisades head nozzle material (Inconel Alloy 600) which is susceptible to primary water stress corrosion cracking (PWSCC), resulted in a through-wall flaw in nozzle 25, and Direct Cause 2 - the contractor examiners failure to resolve the ID surface initiated flaw in nozzle 25. Additionally, the licensee identified two causal factors: Causal Factor 1 - Flaws that initiate on the outside diameter are the primary area of focus during head penetration exams, resulting in the examiner failing to identify specific characteristics of ID initiated flaws. As a result, the ID initiated flaws were not identified and corrected prior to the through-wall flaw in
1R26 (a.k.a. - Palisades 2018 refueling outage); and Causal Factor 2 - ET was removed as
an examination technique and therefore, the ID initiated flaws were not resolved prior to developing a through-wall flaw in 1R26.
The inspectors reviewed the licensees cause investigation, extent of condition, and extent of cause for this event associated with the identification of degraded nozzles in the RVCH to ensure that the licensee identified the full extent of performance errors and had established actions to correct these errors. Additionally, the NRC Vendor Inspection Branch completed a review of the contractors root cause investigation and corrective actions for this event as this issue potentially impacted other licensees (reference NRC report 99901300/2019-201). The inspectors confirmed the licensee established an adequate basis for the Direct Causes 1 and 2 in the ACA completed under CR-PLP-2018-05857. However, Causal Factor 2 associated with the removal of the ET technique, did not have a sufficient basis for the inspectors to independently confirm this as a causal factor because both ET and UT are qualified to detect ID flaws. Specifically, the UT technique applied was demonstrated as qualified to detect ID flaws and ET was also qualified to detect ID flaws, so either method would be sufficient to detect PWSCC. Therefore, the inspectors could not substantiate Causal Factor 2 and considered this a weakness in the licensees ACA. Additionally, the scope of the licensees ACA was limited to planar flaws within the RVCH nozzles and did not include the contractors failure to identify evidence of a UT leak path signal at nozzle 25. The UT leak path method is relied on to identify flaws that may exist in the J-groove weld of a nozzle and which may not be detected by visual examinations looking for evidence of leakage on the RVCH. To address this issue, the licensees contractor assigned an action to correct this error during the 2018 outage (e.g. just in time training and procedure changes) and therefore the inspectors were not concerned that the narrow scope of the licensees ACA had adversely impacted the ability to detect the full extent of degraded RVCH nozzles and J-groove welds.
In response to the missed flaw indications, the licensee conducted a self-assessment of the programs for contractor oversight of the vessel head inspections. Specifically, in CR-HQN-2019-00577 Fleet NDE oversight of RVCH examinations the licensee identified causal factors and conclusions as they related to programs for oversight of the contractor head UT examinations. In this document, the licensee identified program weaknesses which included:
No governing standard existed for oversight of RVCH inspections; Fleet Inspection Services did not rigorously challenge the implementation of the contractor procedure requirements for two specific areas - pre-job briefings and UT data analyst independence, and no formal operating experience screening was performed for a similar missed flaw event that occurred in 2013 at the Shearon Harris Plant. The licensee concluded that had these insights been realized prior to the examinations, Entergy would have been less vulnerable to missed indications.
The inspectors reviewed the licensees self-assessment as documented in CR-HQN-2019-00577 and confirmed the licensee established an adequate basis for its program findings but noted that the licensee had not reviewed the Indian Point Unit 2 (IP2) nozzle leakage event which occurred within the prior 6 months of the Palisades head leak (reference IP2 licensee event report (LER) 05000-247-2018-001-00, Penetration Indications Discovered During Reactor Pressure Vessel Head Inspection). The lack of a review of the IP2 event to gain insights on program performance indicated a narrow scope of review for related operating experience, in particular since the IP2 site is owned and operated by the Palisades licensee.
Minor Violation 71153 Minor Violation: On January 21, 2019, the licensee was informed by the reactor vessel closure head (RVCH) examination contractor of a Part 21 deviation in contracted services based on a vendor reanalysis of ultrasonic (UT) exam data completed in November of 2018 (reference Framatome CR 2018-9955). The contractor identified a Part 21 deviation from contracted services in RVCH examinations associated with the results the contractors re-review of UT data, for past outages. Specifically, an axially oriented flaw indication was present in the nozzle 25 material that had not been reported as a flaw indication during previous RVCH examinations. As of June 27, 2019, the licensee had not applied site procedure EN-LI-1008-01 10 CFR 21 Evaluations And Reporting in response to the contractors identification of a Part 21 deviation. Specifically, the licensee did not follow Section 5.2 of procedure EN-LI-1008-01 which stated If it is determined that the deficiency/condition does constitute 10 CFR 21 discovery of a Technical Specification Safety Limit related issue, deviation or failure to comply, then the Responsible Department Manager documents the bases of the determination and proceeds to Section 5.3. and Assign a corrective action to the Responsible Department Manager to complete Attachment 9.3 as soon as practicable, and in all cases within 60 calendar days of determining that the deficiency/condition does constitute discovery of a deviation or failure to comply (i.e., the determination of answers to Attachment 9.2). The licensees failure to follow procedure EN-LI-1008-01 and complete an evaluation of the contractor identified Part 21 deviation, represented a violation of 10 CFR Appendix B, Criterion V Instructions, Procedures, and Drawings, which requires in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Screening: The inspectors determined the performance deficiency was minor. For this issue, the licensees contractor completed a Part 21 evaluation and concluded that although this issue met the definition of a Part 21 deviation, the missed UT indication in nozzle 25 did not pose a substantial safety hazard or a risk of violating a safety limit (as defined in 10 CFR Part 21) associated with the integrity of the reactor coolant pressure boundary and was therefore not a defect as defined in Part 21. Based on substantial margins that existed until reaching a critical (e.g. unstable) crack size for nozzle 25 and the absence of corrosion induced wastage of the RVCH, the inspectors agreed with the licensees contractor assessment that this issue did not pose a substantial safety hazard. With this result, the inspectors applied the IMC 0612, Appendix B Issue Screening process and answered no to the more than minor questions for this violation because no loss of safety function occurred. Additionally, the inspectors considered this to be this similar to minor Example F of Section 4 Insignificant Procedural Errors of IMC 0612, Appendix E Examples of Minor Issues.
Enforcement:
This failure to comply with 10 CFR Appendix B, Criterion V constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Minor Violation 71153 Minor Violation: On November 10, 2018, with the plant in Mode 6, during bare metal visual inspections of the reactor vessel closure head, dried boric acid was identified in the area of reactor head nozzle 25, indicative of a through-wall flaw. On January 3, 2019, the licensee issued a licensee event report (LER) 2018-003-00 Indications Identified in Reactor Pressure Vessel Head Nozzle Penetrations and reported this in accordance with 10 CFR Part 50.73(a)(2)(ii)(A) as a condition of the nuclear power plant, including its principal safety barriers, being seriously degraded. However, the licensee did not perform an investigation to determine if the accumulation of a boric acid deposit at nozzle 25 was indicative of plant operation with through-wall pressure boundary leakage and as such was prohibited by Technical Specification (TS) LCO 3.4.13, which states that operational LEAKAGE shall be limited to: No pressure boundary LEAKAGE. The licensees failure to report plant operation prohibited by TS to the NRC in an LER represented a violation of 10 CFR Part 50.73(a)(2)(i)(B).
Screening: The inspectors determined the performance deficiency was minor. Consistent with the guidance in Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, the inspectors determined the performance deficiency was not a finding of more than minor significance based on No answers to the more-than-minor screening questions. The inspectors also reviewed the examples of minor issues in IMC 0612, Appendix E, Examples of Minor Issues and found no examples related to this issue. Additionally, based on review of Section 2.2.2 Traditional Enforcement of the NRCs Enforcement Policy, this issue represents a minor violation because failure to make this report resulted in no appreciable potential safety consequence and was less significant than a SL IV violation.
Enforcement:
This failure to comply with Part 50.73(a)(2)(i)(B) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Unresolved Item (Closed)
Qualification Basis for Safety-Related Agastat Relays and Molded Case Circuit Breakers05000255/2013005-06 71152
Description:
On February 12, 2014, the NRC issued Inspection Report 05000255/2013005 documenting Unresolved Item (URI)05000255/2013005-06. This URI was associated with safety-related molded case circuit breakers (MCCBs) and Agastat relays installed in mild environments which appeared to not have preventive maintenance (PM) schedules for inspection or replacement to address their specified lifetime. Since then, the NRC undertook efforts, such as training, to assist inspectors in dispositioning issues related to how long safety-related components remain in service and to clarify the applicability of various regulations and industry standards. As part of this effort, the NRC determined current agency regulations require the establishment of quality assurance programs and supporting procedures that, among other things, set PM schedules for the inspection or replacement of parts having a specific lifetime.
During the NRC's previous inspection, the inspectors determined the licensee had developed PM schedules and associated procedures for the inspection of the MCCBs. However, the appropriateness of the schedule and procedures to detect degradation prior to the MCCB experiencing a loss of safety function was not readily evident. While the NRC undertook the training efforts previously described, the licensee replaced the MCCBs installed beyond their specified life and created recurring work tasks to replace MCCBs prior to the breakers exceeding their specified life as documented in CR-PLP-2015-1914 and CR-PLP-2013-4010.
Because these actions reasonably ensured the continued quality of the MCCBs during their specified lifetime, the inspectors determined further efforts to evaluate the appropriateness of the procedures in effect at the time the URI was issued were no longer needed to provide reasonable assurance of adequate protection of public health and safety.
Regarding the Agastat relays, the inspectors determined the licensee had developed PM schedules and associated procedures to manage the service life of safety-related Agastat relays prior to the issuance of this URI. Specifically, on January 1, 2009, the licensee initiated corrective action document CR-PLP-2009-00346 to address a deficiency regarding their PM strategy for safety-related Agastat relays. The associated corrective actions included the development of EC20559, Validate Selective Agastat Relays Setpoint Data, Revision 0, which validated and/or established inspection acceptance criteria intended to detect degradation prior to loss of safety function. These acceptance criteria were included in calibration sheets which are implemented during periodic PM activities.
Based on the above, no performance deficiency or violation of regulatory requirements was identified. This review did not represent an inspection sample.
Corrective Action Reference(s): CR-PLP-2015-1914 and CR-PLP-2013-4010
Unresolved Item (Closed)
Potential Failure to Identify/Correct Rejectable Flaws in Reactor Pressure Vessel Head Penetration 05000255/2018004-01 71111.08P
Description:
This was closed to a Green NCV.
Inadequate Ultrasonic Examination of Reactor Head Nozzles Results in Operation with Pressure Boundary Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green NCV 05000255/2019002-01 Open/Closed
[H.2] - Field Presence 71111.08P The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of Technical Specification (TS) 3.4.13.a, Reactor Coolant System Operational Leakage, for the licensees failure to place the plant in Mode 3 (Hot Standby) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 (Cold Shutdown) within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> with the plant in Mode 1 (Power Operation) during a portion of operating Cycle 26 with pressure boundary LEAKAGE present at reactor vessel closure head (RVCH) penetration nozzle 25. In particular, the licensees UT contractor mischaracterized flaw indications, and thus had not identified them as flaws before they resulted in operation with the pressure boundary LEAKAGE. The inspectors determined the condition was reasonably foreseeable and preventable by the licensee as there were several weaknesses in the licensees oversight of its contractor that mischaracterized the nozzle flaw indications.
Description:
On November 10, 2018, with the plant in Mode 6, during bare metal visual inspections of the RVCH, dried boric acid was identified in the area of nozzle 25, indicative of a primary coolant system (PCS) leakage from a through-wall flaw. The licensees contractor (Framatome) had recently completed UT examinations of nozzle 25 and the NRC inspectors inquired if the contractor had identified flaw indications or evidence of leakage during this UT examination. The inspectors questions prompted the licensees contractor to re-review nozzle 25 UT data and the contractor staff subsequently identified an inside diameter (ID)connected axial thru-wall flaw indication and UT indications of leakage within the annulus behind nozzle 25 (e.g. UT leak path). Subsequently, the contractor performed a re-review of all nozzle UT data and then applied an eddy current examination technique to the ID surface of nozzles 34, and 36 and identified additional ID connected flaws in nozzles 33 and 36. In licensee event report (LER) 2018-003-00, the licensee determined the cause of these flaws to be primary water stress corrosion cracking (PWSCC) based on the nozzle material (Inconel Alloy 600) which is known to be susceptible to PWSCC. Additionally, the licensee reported that the reactor head UT contractor performed an in-depth summary of the prior data reviews on reactor head nozzles 25, 33, and 36 and that the result of this review shows that the ID-initiated axial flaws were present and detectible with the demonstrated inspection method in 2007, 2009, 2010, and 2012. The licensees contractor staff had not observed ID initiated flaws since the 2001-2002 timeframe, and thus the UT examinations of the RVCH were focused on identification of outside diameter (OD) initiated flaws.
Each of the RVCH nozzle UT examinations dating back to 2007 were completed by the same contractor (Framatome) in accordance with procedure 54-ISI-604 Automated Ultrasonic Examination of Open Tube Reactor Pressure Vessel Closure Head Penetrations (Revisions 3 through 13) and this procedure was required to be qualified for detection of flaws in vessel head penetration nozzles in accordance with applicable NRC requirements (e.g. NRC Order EA 03-009 Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors, 10 CFR 50.55a Codes and Standards, Code Cases 729-1 and Code Case N-729-4). Procedure 54-ISI-604 included instructions for identification of ID connected flaws and the contractor staff that applied this procedure had demonstrated the capability to detect ID flaws with this procedure. Specifically, certification records (Performance Demonstration Qualification Records issued by the Electric Power Research Institute (EPRI)) existed for each of the contractor staff that performed inspections of nozzles 25, 33 and 36 confirming that the contractor staff member had demonstrated the ability to detect and size flaws that originated at both the ID and OD surface of mockup RVCH nozzles.
However, the procedure steps for classifying UT indications as ID flaws were not properly applied by the licensees contractor staff during each of the 7 times that the RVCH nozzles were examined from 2007 through 2018. As a result, the flaw indications present in nozzles 25, 33 and 36 were previously mischaracterized by the contractor staff and thus not identified as flaws.
Upon discovery of the through-wall leak on nozzle 25, the licensee determined that the leak was present for a maximum of the duration of operating cycle 26 and that refinement of that leakage duration was immaterial to cause investigation, corrective action determination, or repair plans. Therefore, the licensee did not conduct an evaluation to determine a more precise leakage duration. Based on the presence of a through-wall flaw in nozzle 25, in conjunction with a confirmed UT leak path signal, and dried boric acid deposit present at the outside vessel head surface at nozzle 25, the inspectors concluded leakage existed well in excess of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> during operating cycle 26.
In response to the missed flaw indications, the licensee conducted a self-assessment of the programs for contractor oversight of the vessel head inspections. Specifically, in CR-HQN-2019-00577 Fleet NDE oversight of RVCH examinations the licensee identified causal factors and conclusions as they related to programs for oversight of the contractor head UT examinations. In this document, the licensee identified a number of program weaknesses which included: No governing standard existed for oversight of RVCH inspections; Fleet Inspection Services did not rigorously challenge the implementation of the contractor procedure requirements for two specific areas - pre-job briefings and UT data analyst independence, and no formal operating experience screening occurred for a similar 2013 missed flaw event that occurred at the Shearon Harris Plant. The licensee concluded that had these insights been realized prior to the RVCH examinations, Entergy would have been less vulnerable to missed indications. Therefore, the licensee missed opportunities to strengthen oversight of the Palisades UT examination process that could have precluded extended operation with a through-wall flaw at nozzle 25 as revealed during the 2018 Palisades outage (e.g. the leakage event at Palisades was reasonably foreseeable and preventable).
Corrective Actions: The licensees contractor staff completed training on the flaw characteristics observed in nozzles 25 and 33 and applied lessons learned from this training to the remainder of the reactor head nozzle population during the 2018 refueling outage to ensure all flawed nozzles were identified and the licensee repaired each of the flawed nozzles (25, 33 and 36) prior to returning the RVCH to service. The inspectors identified that the licensee had operated during cycle 26 with pressure boundary LEAKAGE which is prohibited by TS LCO 3.4.13 and the licensee entered this TS violation into the corrective action program for further corrective action.
Corrective Action References: CR-PLP-2019-02516
Performance Assessment:
Performance Deficiency: The licensees failure to change plant operating conditions from Mode 1 (Power Operation) to Mode 3 (Hot Standby) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and Mode 5 (Cold Shutdown) within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, with pressure boundary LEAKAGE at RVCH nozzle 25 during operating cycle 26 was contrary to TS LCO 3.4.13 and a performance deficiency. In particular, the licensees UT contractor mischaracterized flaw indications, and thus had not identified them as flaws before they resulted in operation with the pressure boundary LEAKAGE. The inspectors determined the condition was reasonably foreseeable and preventable by the licensee as there were several weaknesses in the licensees oversight of its contractor that mischaracterized the nozzle flaw indications.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, continued operation with pressure boundary LEAKAGE at RVCH nozzle 25 if not corrected, would result in wastage of the RVCH which would increase the chance for a loss-of-coolant (LOCA) event and rod ejection.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the safety significance as Green using IMC 0609, Appendix A, Exhibit 1, LOCA Initiators, because, after a reasonable assessment of degradation, it was determined that the violation did not result in exceeding the PCS leak rate for a small-break LOCA and did not affect any other systems used to mitigate a LOCA that could result in a total loss of function. Although, the licensee's UT examination was not successful in identifying the flaw in nozzle 25 before minor leakage occurred, the licensees bare metal visual exam was successful in identifying the leakage condition, and the licensee's timely corrective actions prevented this condition from becoming a more safety significant concern. Therefore, the inspectors determined that the issue is of very low safety significance (Green).
Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. In this case, the licensee failed to establish adequate oversight of the contractor during UT examinations of RVCH nozzles which resulted in extended operation with an undetected flaw in nozzle 25 that progressed through-wall and caused pressure boundary LEAKAGE [Item H.2].
Enforcement:
Violation: TS LCO 3.4.13 requires in part, PCS operational LEAKAGE shall be limited to: a.
No pressure boundary LEAKAGE; with the reactor in Modes 1, 2 3 and 4.
TS LCO 3.4.13.b Action statements for Condition Pressure boundary LEAKAGE exists include: B.1 - Be in MODE 3 completion time - 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and B.2 - Be in MODE 5 completion time - 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Contrary to the above, since approximately May of 2017 thru October 13, 2018, with the plant in Mode 1 (Power Operation) and pressure boundary LEAKAGE present through a nonisolable fault in a PCS component (reactor vessel head penetration nozzle 25), the licensee failed to place the plant in Mode 3 (Hot Standby) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 (Cold Shutdown) within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
The disposition of this finding and associated violation closes URI: 05000255/2018004-01.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 11, 2019, the inspectors presented the Triennial Heat Sink to Mr. D. Lucy, Assistant General Manager of Plant Operations and other members of the licensee staff.
- On May 29, 2019, the inspectors presented the Debrief for Unresolved Item 05000255/2013005-06 to Mr. O. Gustafson, Director of Regulatory and Performance Improvement and other members of the licensee staff.
- On June 6, 2019, the inspectors presented the radiation protection baseline inspection results to Mr. D. Corbin, General Manager Plant Operations, and other members of the licensee staff.
- On June 27, 2019, the inspectors presented the Debrief for URI 05000255/2018004-01 Potential Failure to Identify/Correct Rejectable Flaws in Reactor Pressure Vessel Head Penetration and LER 05000255/2018-003-00 Indications Identified in Reactor Pressure Vessel Head Nozzle Penetrations to Mr. C. Arnone, Site Vice President and other members of the licensee staff.
- On July 9, 2019, the inspectors presented the Debrief for URI 05000255/2018004-01 Potential Failure to Identify/Correct Rejectable Flaws in Reactor Pressure Vessel Head Penetration to Mr. D. Corbin, Acting Vice President and other members of the licensee staff.
- On July 9, 2019, the inspectors presented the integrated inspection results to Mr. D. Corbin, Acting Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-PLP-2019-
2146
Unsecured Compressed Cylinder Protective Cap Sitting on
Post Near Safeguards Transformer 1-1
05/28/2019
CR-PLP-2019-
2150
Nitrogen Bottle Found Unsecured Outside the 590' Elevation
North Entrance to the Turbine Building
05/29/2019
Miscellaneous
PLP-RPT-12-
00142
Palisades Nuclear Plant Flooding Walkdown Submittal
Report for Resolution of Fukushima Near-Term Task Force
Recommendation 2.3: Flooding
Procedures
Admin 4.00
Operations Organization, Responsibilities, and Conduct
Admin 4.02
Control of Equipment
Acts of Nature
SOP-30
Station Power
Work Orders
Annual Inspection of Watertight Barriers
08/07/2018
Corrective Action
Documents
CR-PLP-2019-
2404
150/151-115 (Z-Phase) Component Cooling Pump P-52C
OC Relay Flag Actuated
06/17/2019
CR-PLP-2019-
2477
Level 2 Oil Leak from VC-10 Compressor Shaft Seal
06/20/2019
CR-PLP-2019-
2528
Safeguards Transformer Found Power Available Light was
not Illuminated Gas-in-Oil Monitor
06/25/2019
Drawings
M-218, Sheet 6
Piping & Instrument Diagram, Heating, Ventilation and Air-
Conditioning Control Room
M-218, Sheet 6A
Piping & Instrument Diagram Heating, Ventilation and Air-
Conditioning Control Room
M-218, Sheet 7
Piping & Instrument Diagram, Heating, Ventilation and Air-
Conditioning Control room
Procedures
SOP-24
Ventilation and Air Conditioning System
SPS-E-28
Safeguards Transformer 1-1 (EX-07) Load Tap Changer
Voltage Settings
Work Orders
Safeguards Transfer EX-07 Load Tap Changer Set
05/24/2019
EX-07: Load Tap Changer Controller, Replace 1K Rheostat
04/19/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.05Q Fire Plans
Pre Fire Plan 4,
34, 35, & 36 /
Rooms 116A,
190, 191, & 192
1-C Switchgear Room and Manhole 1, 2, & 3 / Elevation 590
Calculations
EA-C-PAL-99-
Generation of Flow Rate Acceptance Criteria for Technical
Specification Surveillance Test RO-216
2/06/2012
EA-EAR-2000-
0119-01
Instrument Uncertainty Calculation for TI-1319, Critical
Service Water Temperature Indication
08/21/2000
EA-EC28106-03
Diesel Generator Lube Oil Cooler Tube Plugging
2/27/2013
EA-GL-96-06-
SWS-02
Service Water GL 96-06 Waterhammer Assessment
08/12/2004
EA-GOTHIC-04-
Containment Response to a LOCA Using GOTHIC 7.2a
10/21/2010
EA-GOTHIC-04-
Containment Response to a MSLB Using GOTHIC 7.2a
10/21/2010
EAR-98-0512
Establish 85* as the Design Basis Service Water Inlet
Temperature Limit
07/24/2001
E031A/B Lube Oil and E-22A/B Jacket Water Coolers Tube
Plugging Allowance
2/14/2011
EDG Jacket Water Cooler Tube Plugging Revision
2/02/2016
Corrective Action
Documents
CR-PLP-2015-
05318
Pre-NRC UHS Assessment
10/26/2015
CR-PLP-2015-
4504
RO-216 Acceptance Criteria for EDG1-1 Not Met
09/30/2015
CR-PLP-2017-
226
RO-216, Service Water Flow Verification, Actual
Containment Air Cooler Service Water Flow Was
Outside of the Containment +/- 10 % Air Cooler Flow Band
05/05/2017
CR-PLP-2018-
00313
E-22B, 1-2 D/G Jacket Water Cooler 12 Partially Blocked
Tubes
01/16/2018
CR-PLP-2018-
00318
E-22B, D/G 1-2 Jacket Water Cooler, Eddy Current
Inspection Identified Tubes for Plugging
01/17/2018
CR-PLP-2018-
06058
VHX-3 Inspection Identified Tube Blockage
11/15/2018
Miscellaneous
RU14-021
Inspection of Raw Water Intake Pipe
10/30/2015
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
UCC Job # 02-07-
203.97
Spring 2018 Inspection and Cleaning
04/24/2018
UCC Job # 02-07-
203.99
Fall 2018 Inspection and Cleaning
09/30/2018
Procedures
EDG 1-2 Malfunctions
Revision 3
ARP-20B
Diesel Generator 1-2 Scheme EK-30
08/18/14
DWO-1
Operators Daily/Weekly Items MODEs 1, 2, 3, and 4
07/20/2017
Heat Exchanger Performance and Conditioning Monitoring
Revision 11
MO-29
Engineered Safety System Alignment
Revision 40
SEP-HX-PLP-001
Heat Exchanger Condition Assessment Program
Revision 3
SEP-SW-PLP-
2
Service Water and Fire Protection Inspection Program
Revision 6
SEP-UIP-005
Underground Component Inspection Plan
Revision 5
Work Orders
RO-144 - IST P-7A,B,C SWS PMP Comprehensive Test
05/08/2017
RO-216 Service Water Flow Verification
05/11/2017
VHX-2, Inspection for Tube Fouling
05/04/2017
E-11B; Replace Jacket Water Cooler HT Exchanger Tube
Bundle
07/17/2018
RO-216 Service Water Flow Verification
09/30/2015
VHX-1, Inspection for Tube Fouling and Eddy Current Test
10/16/2015
VHX-1, Containment Air Cooler Air Side Inspection
09/22/2015
VHX-2, Containment Air Cooler Air Side Inspection
09/22/2015
QO-6 1R25 Cold Shutdown Valve Test Procedure (18 month
Reg)
07/19/2018
VHX-3, Containment Air Cooler Inspection
04/25/2017
VHX-1, Containment Air Cooler Air Side Inspection
04/24/2017
VHX-2, Containment Air Cooler Air Side Inspection
05/10/2017
E-22B, Eddy Current Testing of EDG Jacket Water Cooler
05/03/2018
VHX-3, Inspection for Tube Fouling
11/16/2018
VHX-1, Containment Air Cooler Air Side Inspection
10/29/2018
RO-144 -IST P-7A,B,C SWS Pmp Comprehensive Test
11/12/2018
RO-216 Service Water Flow Verification
11/18/2018
VHX-2, Containment Air Cooler Air Side Inspection
11/13/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
QO-6 - Cold Shutdown Valve Test Procedure
2/20/2018
QO-14A - P-7A, IST Service Water Pump
06/01/2018
QO-14A - P-7A IST Service Water Pump
08/20/2018
QO-14C -P-7C, IST Service Water Pump
09/18/2018
QO-14A - P-7A IST Service Water Pump
11/27/2018
QO-14C -P-7C, IST Service Water Pump
2/29/2018
MO-29 Engineering Safety System Alignment
2/26/2019
MO-7A-2 Emergency Diesel Generator 1-2
2/19/2019
MO-29 Engineering Safety System Alignment
03/26/2019
Corrective Action
Documents
Resulting from
Inspection
CR-PLP-2019-
2516
The NRC is Proposing a Green Finding and Associated NCV
of TS 3.4.13.
06/25/2019
NDE Reports
1075
Performance Demonstration Program Qualification for
Jeffery Grigsby
08/20/2014
180-9247379-000
Palisades Unit 1, 1 R024 Reactor Head Inspection Report
180-9271125-000
Palisades Unit 1, 1RO25 Reactor Head Inspection Report
180-9291875-000
Palisades Unit 1, 1RO26 Reactor Head Inspection Report
180-9291875-000
Palisades Unit 1, 1RO26 Reactor Head Inspection Report
2/04/2018
384
Performance Demonstration Program Qualification for Scott
R. Breiholz
08/20/2014
407
Performance Demonstration Program Qualification for
Vladimir Zado
08/28/2014
498
Performance Demonstration Program Qualification for
Michael W. Key
08/25/2014
- 9062418 -
000
Palisades Unit 1, RO19 Reactor Head Inspection Report
- 9110490 -
000
Palisades Unit 1, RO20 Reactor Head Inspection Report
- 9181224 -
000
Palisades Unit 1, 1RO22 Reactor Head Inspection Report
- 9218473 -
000
Palisades Unit 1, RO23 Reactor Head Inspection Report
51-9147146-000
Palisades Unit 1, 1RO21 Reactor Head Inspection Report
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
671
Performance Demonstration Program Qualification for
Hrvoje Bezlaj
08/19/2014
939
Performance Demonstration Program for Rickie L. Rose
08/26/2014
Procedures
54-ISI-604-013
Automated Ultrasonic Examination of Open Tube RPV
Closure Head Penetrations
08/31/2006
PLSEG-LOR-
Licensed Operator Re-qualification Cycle 19B as Found
Scenario
Corrective Action
Documents
CR-PLP-2017-
257
Maintenance Rule Evaluation
2/23/2017
CR-PLP-2017-
00634
VC-11 Control Room HVAC Refrigeration Condensing Unit
did not Automatically Start in Auto as Expected Following
the Swap
2/22/2017
CR-PLP-2017-
04335
P-55B Low Oil Pressure During CVCO-4
09/21/2017
CR-PLP-2017-
05085
P-55C Unusual Noises in P-55A Cube with P-55C Running
11/03/2017
CR-PLP-2017-
05188
VC-11 Failed to Start After Being Returned to Auto
11/09/2017
CR-PLP-2017-
299
VC-11 Control Room HVAC Refrigeration Condensing Unit
Failed to Start
11/17/2017
CR-PLP-2017-
05599
P-55C Input Shaft Oil Leaks
2/08/2017
CR-PLP-2017-
05668
P-55A Exhibited Loud Banging Noises
2/12/2017
CR-PLP-2018-
221
Returning the Charging Pumps to Active (a)(1) Status with
Corrective Actions
01/11/2018
CR-PLP-2018-
00932
While Swapping CRHVAC Trains for MO-33B, VC-11 did not
Pump Down as Expected
2/22/2018
CR-PLP-2018-
00939
Air Handling Unit V-96 Outside Air Damper was Slow to
Open
2/23/2018
CR-PLP-2018-
00940
CR HVAC Testing, FIS-1681, Air Handling Unit V-95
Discharge Flow Indicator was Reading 5000 CFM
2/23/2018
CR-PLP-2018-
01050
Visual Inspection of RT-85D-B Control Room Emergency
Ventilation Filtration Testing - B Train
2/28/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-PLP-2018-
03154
VC-11, Control Room HVAC Refrigeration Condensing Unit
not Running
07/03/2018
CR-PLP-2019-
00327
Multiple Equipment Failures Associated with the Control
Room Ventilation System Over the Past Several Years
01/23/2019
CR-PLP-2019-
00383
V-95 Control Room Ventilation Main Supply Fan Tripped
Unexpectedly
CR-PLP-2019-
00785
Control Room HVAC System (VAS-CRV) is Maintenance
Rule "Near (a)(1)" Due to Experiencing Two (2) Functional
Failures
2/22/2019
CR-PLP-2019-
2512
Tracking CR for Maintenance Rule Evaluations (Failure
Determinations) of Low Safety Significant Equipment
Performance Issues
06/25/2019
Engineering
Evaluations
9.9
Equipment Failure Evaluation
01/25/2019
Miscellaneous
Q1-2019 System
Health Report
Chemical Volume Control - Charging/Letdown
06/28/2019
Q3-2018
Control Room HVAC System Health Report
03/26/2019
Q4-2018
Chemical Volume Control - Charging/Letdown System
Health Report
06/28/2019
Q4-2018
Control Room HVAC System Health Report
03/26/2019
Procedures
Control Room Ventilation System Reliability
Drawings
E-5, Sheet 5B
Relay Diagram 480 Volt Motor Control Centers
Miscellaneous
Operators Risk Report
05/01/2019
Procedures
Admin 4.02
Control of Equipment
Acts of Nature
Corrective Action
Documents
CR-PLP-2019-
01671
High Pressure Safety Injection (HPSI) Pumps Operability
Evaluation
04/24/2019
CR-PLP-2019-
01863
1-1 EDG Failed to Start
05/06/2019
CR-PLP-2019-
01871
G1-1/ESR1 Relay Coil was Found with a Cracked Housing
with a White Substance Emanating From It
05/07/2019
CR-PLP-2019-
2108
Preconditioning Evaluation for MO-7A-1 Emergency Diesel
Generator
05/23/2019
CR-PLP-2019-
The TS/PB-R, SIS Test Button CKT No 2, was Momentarily
05/23/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2114
Released during Step 5.4.13 of QO-1 Safety Injection
System Testing
CR-PLP-2019-
238
"Parallel" Light did not Light when G1-1/DSR Parallel/Unit
Selector was Placed in Parallel
06/04/2019
Drawings
E 17, Sheet 13
Diesel Generator Breakers
E-17, Sheet 12
Diesel Engine Control Trips and Alarms
VEN-M12, Sheet
Control Equipment Schematic, Excitation Relaying &
Metering
VEN-M12, Sheet
98(1)
Engine Control Diesel Generator 1-1
VEN-M12; Sheet
Wiring Diagram Engine Exciter Panel C22 DG 1-1
VEN-M12; Sheet
98(1)
Schematic Diagram Engine Control DG 1-1
Miscellaneous
DBD-5.01
Diesel Engine and Auxiliary Systems
Procedures
MO-7A-1
Emergency Diesel Generator 1-1
Engineering
Changes
81531
EX-10 Oil Cooler; Feed Cooler Bank 5 Pump from
Temporary Power / and Connect Wavebook to Monitor
Current
2148
Supplemental Cooling to EX-10 Main Transformer
Miscellaneous
PLP-RPT-19-
00025
EX-10 Main Transformer - GSU Transformer Thermal
Evaluation
PLP-RPT-19-
00028
Zones of Influence for Temporary Cooling Equipment in the
Palisades Plant Yard Area
Procedures
SOP-8
Main Turbine and Generating Systems
110
Work Orders
Breaker 8-5 (EX-10), Oil Pump Tripped for Bank #5
01/25/2019
Corrective Action
Documents
CR-PLP-2019-
2458
An N/O Set of Contacts on the Droop Relay G1-1/DR was
Hanging up and not fully Changing States
06/20/2019
CR-PLP-2019-
2474
Unloaded Field Voltage Lower than Normal During MO-7A-1
for EDG 1-1
06/20/2019
Miscellaneous
Work Instruction
WI-EPS-E-01
Battery Charger Maintenance
Work Instruction,
WI-EPS-E-04
Calibration Testing of Electrical Meters
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
SOP-22
Work Orders
G1-1/DR; Parallel Light did not Light
06/20/2019
ML-3070, Post-Maintenance Test: Inspect/Repair Oiler, Adj
W/QO-5
05/09/2019
Battery Charger Maintenance
05/13/2019
VC-10, Condenser Overhaul Post-Maintenance
04/16/2019
Check Calibration of EAI-48
5/13/2019
MO-33B - Perform MO-33B for 'B' CRHVAC
04/19/2019
Corrective Action
Documents
CR-PLP-2019-
00145
CRD-24 did not Move with the Group
01/10/2019
CR-PLP-2019-
01645
Control Rod #23 Temperature was Observed Rising
04/23/2019
CR-PLP-2019-
01788
Question was Raised as to Whether the 1 Year Flex Pump
Standby PMs Required a 2 Hour Run or a 30 Minute Run
05/01/2019
CR-PLP-2019-
2061
Hi NO Alarm on the Portable NO Detector During MO-7A-2
05/20/2019
Procedures
EN-OP-201-05
Palisades FLEX Program Document
QI-39
Auxiliary Feedwater Actuation System Logic Test
QO-20
Inservice Test Procedure - Low Pressure Safety Injection
Pumps
QO-34
Control Rod Exercising
RE-132
Diesel Generator 1-2 Load Reject
SOP-22
K-16 Security Diesel Generator Checklist
Work Orders
FLEX Standby PM: P-1003 One Year Operational Test (FSB
A)
04/10/2019
QO-34 - Control Rod Exercising
04/23/2019
QO-20A P-67A Inservice Test Low Pressure Safety Injection
Pump
06/18/2019
K-16, Security Diesel Generator Monthly Start Test
06/10/2019
Corrective Action
Documents
CR-PLP-2018-
2083
Plant Public Address Announcements are not Being Heard
at Warehouse 2
05/22/2019
CR-PLP-2019-
2084
Central Alarm Station (CAS) Secondary Work Station Would
not Communicate with the CAS Printer
05/22/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-PLP-2019-
2110
General Performance of the Provided EP Radios was Poor
During Drill
05/23/2019
Miscellaneous
May 22, 2019, Emergency Planning Drill Scenario Narrative
Calibration
Records
Calibration Record For GEM-5 Serial Number 1712-186
08/24/2018
Calibration Record For ARGOS Serial Number 1712-183
08/30/2018
M-54 Calibration Data Sheet For Serial Number 285662
03/31/2019
Calibration Record For AMP-200 Serial Number 7704.032
06/01/2018
Calibration Record For RAS-1 Serial Number 19529
05/02/2018
Calibration Record For iSolo Serial Number 1047346
06/10/2018
2018-B2.28-
CALDAT-06948
Calibration Record for RO-20 Serial Number 1492
10/10/2018
2018-B2.28-
CALDAT-07015
Calibration Record For LM-177 Serial Number 273222
10/11/2018
2019-B2.28-
CALDAT-02731
Calibration Record For AMS-4 Serial Number 121
03/27/2019
2019-B2.28-
CALDAT-02950
Calibration Record For Telepole Serial Number 6600-019
04/03/2019
Miscellaneous
Gamma Spectroscopy Detector's 2018 Annual
Efficiency/Lower Limit of Detection Verifications
01/03/2019
DABD-03
Palisades - Stack Release Rate Calculations
06/24/2002
Procedures
Fuel Handling Area Ventilation System Filter Testing
03/01/2018
Self-Assessments LO-PLPLO-2018-
00014
Radiation Monitor Functionality Assessment
Work Orders
2641428
Hi Range Noble Gas Effluent Monitor RIA-2327 Calibration
04/03/2017
71151
Miscellaneous
NRC Performance Indicator Data Sheet, Initiating Events -
Unplanned Power Changes per 7,000 Critical Hours (IE03);
Second Quarter 2018 through Second Quarter 2019
04/01/2018
to
06/30/2019
NRC Indicator Safety System Functional Failures (MS05)
Technique/Data Sheet; 2nd Quarter 2018 to 1st Quarter
2019
04/01/2019
to
03/31/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-PLP-2009-
00346
Agastat Time Delay Relays Not Included in Site Calibration
Sheet Database
01/28/2009
CR-PLP-2018-
05857
Bare Metal Visual Examination of the Reactor Pressure
Vessel Head per Work Order 52779311 Identified
Recordable Boron Indications at Head Penetration Number
25. Samples of the Leakage Confirmed a High Boron
Concentration.
2/17/2018
CR-PLP-2019-
00063
As Found Condition Verified that CRDM Housing #37 & #28
Component Cooling Water Cooling Lines are Installed
Incorrectly.
01/04/2019
CR-PLP-2019-
00117
Plant Trip due to RPS BD Matrix Loss of Power
2/26/2019
CR-PLP-2019-
01676
The Process to Review changes in Plant Design,
Procedures/Processes and New Equipment has not been
Consistently Implemented
04/04/2019
CR-PLP-2019-
01678
Objectives from Department Rollups are not Creating Clear
Specific Gap Identification for Focused Coaching by
Supervisors
04/18/2019
CR-PLP-2019-
01832
Identified Trend of Failure to Coach When an Issue was
Identified by Non-consequential Procedure Compliance
Issues
05/03/2019
CR-PLP-2019-
241
Station Identified Leadership did not Act Promptly to More
Broadly Address Subtle Signs of Performance Decline
06/04/2019
CR-PLP-2019-
2175
During Fire Drill Operator Inadvertently Made Contact with
and Opened a Breaker
05/29/2019
CR-PLP-32019-
2520
Control Rod Drive Seal Leakage Measurement
06/25/2019
Corrective Action
Documents
Resulting from
Inspection
CR-PLP-2013-
04010
2013 NRC Aging Management Inspection - Three MCCBs
Are Exceeding Their Service Life
09/11/2013
CR-PLP-2013-
04344
Agastat Timing Relay Service Life Not Defined
10/03/2013
CR-PLP-2015-
01914
Resolution of Service Life TIA
05/08/2015
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering
Changes
Validate Selective Agastat Relays Setpoint Data
Miscellaneous
Performance Improvement Integrated Matrix (PIM) May
2019
DPRM/APRM
Report
Palisades Performance Improvement May 2019
Human
Performance
Evaluation for
CR-PLP-2019-
01120
Received Alarm EK-0524, Load Shedding/Safeguards Bus
Control CKT Undervoltage, Unexpectedly
03/18/2019
Procedures
1707-01
Framatome Procedure Implementation of 10 CFR 21
2/06/2019
EN-LI-108-01
CFR 21 Evaluations And Reporting
Revision 10
Performance Analysis Template
Self-Assessments EN-LI-121,
9.1
Palisades Performance Improvement
May 2019
9.3
Aggregate Performance Issue Worksheet for Failure to
Provide Reinforcement of Some Expectations from
Supervisors
Corrective Action
Documents
CR-HQN-2019-
00577
Fleet NDE Oversight of RXVCH Examinations
04/24/2019
CR-PLP-2018-
05857
Bare Metal Visual Examination of the Reactor Pressure
Vessel Head per Work Order 52779311 Identified
Recordable Boron Indications at Head Penetration
Number 25.
11/10/2018
CR-PLP-2018-
05895
Framatome Indication Notification Report RVCH-ISI-INR-
1R026-2018-002 Provides Notification of a Change in
Material Condition of Reactor Head Penetration Number 33.
11/21/2018
CR-PLP-2018-
225
Framatome Indication Notification Report RVCH-ISI-INR-
1R026-2018-003 Rev O Provides Notification of a Change in
Material Condition of Reactor Head Penetration Number 36.
11/21/2018
Corrective Action
Documents
Resulting from
CR-PLP-2019-
2460
The LER Should have also Included Reporting Criteria for 10 CFR 73(a)(2)(B) for Operation in a Condition that was
Prohibited by Tech Specs.
06/20/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
CR-PLP-2019-
2468
The inspector Identified that a Review Under 10 CFR 21,
Required by EN-LI-108-01, 10 CFR 21 Evaluations and
Reporting, was not Properly Conducted by the Site.
06/20/2019
Miscellaneous
05000255/2018-
003-00
Licensee Event Report-Indications Identified in Reactor
Pressure Vessel Head Nozzle Penetrations
01/30/2019