IR 05000255/2020002

Integrated Inspection Report 05000255/2020002 and Exercise of Enforcement Discretion

ML20224A204
Person / Time
Site:	Palisades
Issue date:	08/11/2020
From:	April Nguyen NRC/RGN-III
To:	Corbin D Entergy Nuclear Operations
References
EA-17-115 IR 2020002
Download: ML20224A204 (19)

Text

August 11, 2020

SUBJECT:

PALISADES NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000255/2020002 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Corbin:

On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant. On July 23, 2020, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

April M. Nguyen, 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: DPR-20 Report Number: 05000255/2020002 Enterprise Identifier: I-2020-002-0033 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Inspection Dates: April 1, 2020 to June 30, 2020 Inspectors: J. Benjamin, Senior Reactor Inspector P. Laflamme, Senior Resident Inspector J. Mancuso, Resident Inspector V. Myers, Senior Health Physicist C. St. Peters, Resident Inspector Approved By: April M. Nguyen, Acting Chief Branch 2 Division of Reactor Projects Enclosure

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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status EDG EA-17-115 Enforcement Action 71111.15 Discussed EA-17-115: Enforcement Discretion for Tornado Missile Protection Non-Conforming Conditions

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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities, and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated summer readiness of offsite and alternating current (AC) power systems on June 3, 2020

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on June 9, 2020

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) Emergency diesel generator (EDG) 1-1 on April 23, 2020

(2) Right train high pressure safety injection (HPSI) system on June 3, 2020

(3) Left train low pressure safety injection (LPSI) system on June 15, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations while performing a complete walkdown of the right train auxiliary feedwater (AFW) system during the week of May 18, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Area 24: AFW pump room, elevation 571' on April 10, 2020

(2) Fire Areas 5 & 7: 1-1 diesel generator and fuel oil day tank rooms, elevation 590' on April 24, 2020

(3) Fire Area 33: Technical Support Center, elevation 625' on May 7, 2020

(4) Fire Area 1: Control Room, elevation 625' on June 29, 2020

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated PLSEG-LOR-20B-04 on June 19, 2020

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Thermal margin monitoring system on April 20, 2020

(2) Primary coolant system on May 29, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Risk management activities and emergent work for P1-A, main feedwater pump (MFP), recirculation valve steam leak on April 23, 2020

(2) Emergent troubleshooting and work management activities associated with letdown system pressure control on April 29, 2020

(3) Elevated risk for planned shutdown cooling system testing on June 10, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Review of identified tornado missile protection nonconformance during the week of April 6, 2020

(2) Thermal margin monitor channel A operability evaluation on May 5, 2020

(3) Quench tank pressure rise evaluation on June 25, 2020

(4) Pressurizer heater breaker friction block evaluation on June 26, 2020

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) Temporary modification to CV-944A manual side packing on April 17, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Control Room ventilation system testing following planned maintenance activities on April 27, 2020

(2) Letdown stop valve orifice testing following planned maintenance activities on May 7, 2020

(3) CV-0711, P-1A MFP recirculation valve testing following body to bonnet steam leak repairs on May 14, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) 1-2 EDG monthly surveillance test on April 21, 2020

(2) Reactor protection matrix logic quarterly surveillance test on June 3, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) QO-42, shutdown cooling valves test on June 10, 2020

FLEX Testing (IP Section 03.02) (1 Sample)

(1) FLEX Standby PM: P-1003, One Year Operational Test on April 14,

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Dose assessment for a declared pregnant worker in 2019

(2) Effective dose equivalent assessment for individual performing reactor head work in

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

=

(1) Unit 1 (April 1, 2019-March 31, 2020)

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1) Unit 1 (April 1, 2019-March 31, 2020)

71152 - Problem Identification and Resolution

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, 2020 to

June 30, 2020 Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Letdown relief valve lift and subsequent isolation adverse condition analysis, as documented in CR-PLP-2020-00611, during the week of May 18, 2020

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) Licensee Event Reports 05000255/2017-001-00/01, "Inadequate Protection from Tornado Missiles Identified Due to Nonconforming Conditions" retraction This LER was submitted and subsequently retracted LERs 05000255/2017-001-00(01) by licensee correspondence titled "Cancellation of Licensee Event Reports 2017-001-00 and 2017-001-01, "Inadequate Protection from Tornado Missiles Identified Due to Nonconforming Design Conditions", dated March 31, 2020, ADAMS Accession No. ML20091J599. The inspectors reviewed the LER and completed an inspection sample listed under 71111.15, Operability Determination, of this report.

INSPECTION RESULTS

EDG Enforcement Action EA-17-115: Enforcement Discretion 71111.15 (Discussed) for Tornado Missile Protection Non-Conforming Conditions EDG

Description:

On June 10, 2015, the NRC issued Regulatory Issue Summary 2015-06, Tornado Missile Protection, focusing on the requirements regarding tornado-generated missile protection and required compliance with the facility-specific licensing basis. The Regulatory Issue Summary also provided examples of noncompliances that had been identified through different mechanisms and referenced Enforcement Guidance Memorandum (EGM) 15-002, which was also issued on June 10, 2015. Revision 1 of EGM 15-002 was issued on February 7, 2017. The EGM revision provided guidance to allow the NRC staff to exercise enforcement discretion when an operating power plant licensee did not comply with the current licensing basis for tornado-generated missile protection. Specifically, the discretion applied to structures, systems, and components (SSCs) declared inoperable resulting in TS Limiting Conditions for Operation (LCOs) that would require a reactor shutdown or mode change if the licensee could not meet the required actions within the TS completion time. The discretion allowed the licensee to re-establish operability through compensatory measures and established criteria for continued operation of the facility as longer-term corrective actions were implemented.

On March 29, 2017, the licensee initiated condition reports (CRs) CR-PLP-2017-01248, CR-PLP-2017-01249, CR-PLP-2017-01250, CR-PLP-2017-01251, CR-PLP-2017-01252, and CR-PLP-2017-01253, identifying multiple nonconforming conditions of their site-specific licensing basis. Specifically, the licensee identified multiple non-conforming conditions related to inadequate tornado-generated missile protection. The licensee declared multiple SSCs inoperable, promptly implemented interim compensatory measures, and subsequently exited the TS LCO action statements based upon NRC EGM 15-002 guidelines. The NRC documented additional information in Integrated Inspection Report 05000255/2018001.

On January 20, 2020, the licensee completed a tornado missile nonconformance review to document the licensing basis for Palisades tornado missile protection features, specifically regarding the non-conforming issues identified as a result of NRC Regulatory Issue Summary 2015-06. The licensees review concluded that the previously identified non-conforming issues were, in fact, conforming to the current licensing basis. As such, the licensee concluded that corrective actions were not required to restore compliance.

The inspectors reviewed the licensees nonconformance review documented in Engineering Change (EC) 85113, condition reports initiated by the licensee, historic NRC correspondence, aspects of the original conditional operating license and final operating license, the original FSAR, the UFSAR, related safety evaluation report correspondence, the incorporation of the Systematic Evaluation Program into the current licensing basis and other documents provided in the documents reviewed section of this report. Consistent with the licensees review documented in EC 85113, the inspectors did not identify any non-conforming conditions, findings or violations. As a result, no corrective actions are required and EA-17-115 is considered closed.

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 2020 through June 2020, 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, Security, and Training.

Examples included the operation of a breaker failure relay during maintenance activities which resulted in an unexpected trip of the switchyard 345 kV rear bus, not all required sections of Simulator Exercise Guide (SEG) being covered during the Licensed Operator initial simulator training, a level-3 tagging error, a missed window to block MSIV closure, and an unplanned water transfer to SIRWT. Although the above examples did not challenge safety function or equipment reliability, these issues illustrated a decline in the use of human performance tools, which could potentially impact nuclear safety.

The licensee appropriately entered these issues into the CAP and completed timely evaluations addressing each challenge listed above. 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: Letdown Relief Valve Lift Adverse Condition Analysis Review 71152 The inspectors reviewed the events, circumstances, and causal evaluation associated with the letdown relief valve, RV-2006, lift that occurred on February 25, and again on March 4, 2020. Their efforts included assessing the licensee's Failure Mode Analysis (FMA),troubleshooting, trending, and aggregate review activities. Additionally, the inspectors reviewed primary coolant system leakage trends, equipment condition assessments for the letdown system, monthly containment tour results, and quench tank level monitoring. The inspectors also interviewed operators, maintenance workers, and engineering personnel to complete their assessment efforts. In their review, the inspectors noted that the direct cause of relief valve lift was attributed to a localized pressure transient in the letdown system resulting from the intermediate letdown pressure controller timing sensitivity coupled with gas void collapse at the relief valve seat. For corrective actions, the licensee replaced RV-2006 and re-tuned the intermediate letdown pressure controller, which resulted in stabilizing system pressure. Therefore, since the licensee sufficiently determined the direct cause of relief valve lift and successfully completed corrective actions, the inspectors concluded the licensee actions taken were timely and effective commensurate with safety significance.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 23, 2020, the inspectors presented the integrated inspection results to Mr. D. Corbin, Site Vice President, and other members of the licensee staff.

• On May 13, 2020, the inspectors presented the radiation protection inspection results to Mr. D. Corbin, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action CR-PLP-2020- Boot Seals on South Wall (Containment) of Room 121 A 05/01/2020

Documents 01398 (Dog House)

CR-PLP-2020- Lake Michigan Level has Potentially Exceeded the Design 06/10/2020

01864 Basis Elevation of 583.2 ft MSL

Engineering EC 0000029653 Revise Flooding Analysis to Reflect Changes in Plant Revision 0

Changes Configuration

Miscellaneous Engineering Palisades Nuclear Plant Flooding Hazard Re-Evaluation 05/09/2015

Information Report

Record 51-

26987-000

PNP 2015-018 Required - Response 2 for Near-Term Task Force 03/11/2015

Recommendation 2.1: Flooding - Hazard Re-Evaluation

Report

71111.04 Corrective Action CR-PLP-2020- During Walkdown of EDG 1-1 Noted that Flexible Piping for 04/23/2020

Documents 01295 Crankcase Exhaust Motors was Degrading

CR-PLP-2020- While Performing Maintenance in the Aux Feed Pump 04/30/2020

01381 Room, I&C Technicians Noticed Water Running Down the

Wall

CR-PLP-2020- 1-1 Diesel Generator Found that the Number 7L Petcock 05/04/2020

01418 was Spinning Freely When he Attempted to Open it

CR-PLP-2020- Received EK-1319, Safety Injection Tank T-82B Hi-Lo Level 06/05/2020

01806 Unexpectedly

CR-PLP-2020- MO-3045, Safety Injection Tank T-82B Outlet Isolation Valve 06/10/2020

01861

CR-PLP-2020- PT-0510, Turbine Bypass Valve Controller Pressure for 06/11/2020

01883 CV-0511 Turbine Bypass Valve

CR-PLP-2020- P-8D Diesel Driven Aux Feedwater Pump 06/11/2020

01884

CR-PLP-2020- Nitrogen Station 5 Bottle Station has a Leak Somewhere 06/15/2020

01911 Causing Lowering Station Pressure

CR-PLP-2020- PI-3027 HP Air to CV-3027 Actuator is Reading 192 psig, 06/15/2020

01915 eSOMS Limit is 190 psig

Inspection Type Designation Description or Title Revision or

Procedure Date

CR-PLP-2020- Observed Water Leaking from Overhead Drain Header Line 06/15/2020

01916

Corrective Action CR-PLP-2020- NRC Inspector Noted a Discrepancy Between In-Plant 06/22/2020

Documents 01969 Labeling and a Table in SOP-3 Attachment 18.

Resulting from

Inspection

Procedures SOP-3, Engineered Safeguard Administrative Control Verification Revision 106

18

71111.05 Corrective Action CR-PLP-2020- Fire Protection Check Sheet Annual Inspection Sticker was 05/03/2020

Documents 01406 Past Due

CR-PLP-2020- P-8D, Diesel Driven Aux Feedwater Pump 06/10/2020

01869

Fire Plans Pre-Fire Plan 1 Control Room Elev 625' Revision 5

71111.11Q Procedures PSLEG-LOR- TG Synch Scenario Revision 2

20B-04

71111.12 Corrective Action CR-PLP-2019- Received Alarm EK-0748, Reactor Water Low Level 01/11/2019

Documents 0152 Indication LIA-0105 Alarm

CR-PLP-2020- CA-03 Maintenance Rule (a)(1) Evaluation Component 01/28/2020

00032 Failure Performance Criteria Exceeded on PCS/PZR

Instrumentation

CR-PLP-2020- Water and Oil Mixture on the Floor of SFP Heat Exchanger 04/11/2020

01148 Room

CR-PLP-2020- P-67A(LPSI Pump) has Boron Precipitate on Studs/Nuts at 04/13/2020

01155 Motor/Pump Interface

CR-PLP-2020- CV-2056 Failure to Align to Clean Waste Receiver Tank 04/15/2020

01176

CR-PLP-2020- 'A' Charging Pump Speed Elevated from Previous 04/18/2020

227 Indications During CVCS Double Charging and Letdown

CR-PLP-2020- Thermal Margin Monitor (TMM) PY-0102C Repeat 04/27/2020

01320 Functional Failure

CR-PLP-2020- Time Displayed on the Three Recently Replaced LCD 05/02/2020

01400 Thermal Margin Monitor Screens (B/C/D) is One Hour Later

than Actual Time

71111.12 Corrective Action CR-PLP-2020- Chemical & Volume Control System (CVC-CVC) has 06/17/2020

Documents 01937 Exceeded its Maintenance Rule Reliability Performance

Criteria

Miscellaneous PZR System Health Report 2Q2018 04/01/2018 -

06/30/2019

PZR System Health Report 4Q2018 10/01/2018 -

2/31/2018

PZR System Health Report 2Q2019 04/01/2019 -

06/30/2019

PZR System Health Report 4Q2019 10/01/2019 -

2/31/2019

PCS System Health Report 2Q2019 04/01/2019 -

06/30/2019

PCS System Health Report 2Q2018 04/01/2018 -

06/30/2018

PCS System Health Report 4Q2018 10/01/2018 -

2/31/2018

PCS System Health Report 4Q2019 04/01/2019 -

06/30/2019

WT-WTPLP- CA-81 Proposed New Maintenance Rule Functional Failure 08/11/2017

2017-00011 Performance Criteria for Primary Coolant System

Instruments

71111.13 Corrective Action CR-PLP-2020- Steam Leak Identified on CV-0711 Feed Pump P-1A 04/22/2020

Documents 01264 Recirculation

CR-PLP-2020- Integrated Risk for RI-95B, Aux Feedwater Flow FT-0749 05/12/2020

01522 Instrument Loop Calibration was Reclassified on the Day of

Execution

Drawings M-202 Chemical & Volume Control System Piping & Instrument Revision 62

Diagram

M-207 Feedwater & Condensate System Piping & Instrument Revision 53

Diagram

Miscellaneous Adverse CV-0711, Feed Pump P-1A Recirculation, Steam Leak 04/22/2020

Condition and

Monitoring Plan

for WO 543553

71111.15 Corrective Action CR-PLP-2017- Service Water System Tornado Missile Nonconformance 03/29/2017

Documents 01248 Issue

CR-PLP-2017- Fuel Oil System Tornado Missile Nonconformance Issue 03/29/2017

249

CR-PLP-2017- Emergency Diesel Generator Tornado Missile 03/29/2017

250 Nonconformance Issue

CR-PLP-2017- Control Room Ventilation System Tornado Missile 03/29/2017

251 Nonconformance Issue

CR-PLP-2017- Steam Driven Auxiliary Feedwater Pump Tornado Missile 03/29/2017

252 Nonconformance Issue

CR-PLP-2017- Component Cooling Water System Tornado Missile 03/29/2017

252 Nonconformance Issue

CR-PLP-2018- Additional Component Cooling Water System Tornado 01/31/2018

00556 Missile Vulnerability

CR-PLP-2020- Thermal Margin Monitor (TMM) Screen is Showing Double 03/04/2020

00740 Numbers on Top of Each Other

CR-PLP-2020- Operability of the Class EC-2 Piping 04/20/2020

242

CR-PLP-2020- Small Packing Leak from CV-1656 06/29/2020

2077

Engineering EC 0000085113 Tornado Missile Nonconformance Review 01/29/2020

Changes

Miscellaneous NUREG-0820 Integrated Plant Safety Assessment Systematic Evaluation 10/01/1982

Program Palisades Plant

NUREG-0820 Integrated Plant Safety Assessment Systematic Evaluation 11/01/1983

Supplement 1 Program Palisades Plant

NUREG-1424 Safety Evaluation Report Related to the full-term Operating 11/01/1990

License for Palisades Nuclear Plant

Operability CR-PLP-2020- Pressurizer Heater Friction Block Operability Evaluation 06/23/2020

Evaluations 01988

Procedures QI-25 Thermal Margin Monitor Constant Checks 03/05/2020

Work Orders 00531075 PY-0102D; Replace Components and Reset Error Code 75, 10/10/2019

QI-25

00540421-01 PY-0102A; Replace Video Card and Other Components as 03/16/2020

Needed

71111.18 Corrective Action CR-PLP-2020- Received Alarm EK-0545 Preferred AC Bus No. 2 04/08/2020

Documents 01118 Unexpectedly

Operability EN-LI-113 Licensing Basis Document Change Process Revision 19

Evaluations

Procedures EN-LI-100 Process Applicability Determination Revision 29

Work Orders 00541712 CV-0944A Install Packing Follower Temp Block 04/06/2020

71111.19 Corrective Action CR-PLP-2020- Y-Phase Pole on Breaker 52-2624 (Condensing Unit VC-10 04/21/2020

Documents 01248 for Air Handling Unit V-96) Failed Instantaneous Overcurrent

Testing

CR-PLP-2020- During Inspection of PO-1712 (Modulating Damper D-21 04/22/2020

275 Positioner), Electricians Observed that the Locking Nuts and

Feedback Arm were Loose on the Shaft

Engineering EC 86710 Temporary Leak Repair of the Pressure-Seal Body-to- 04/28/2020

Changes Bonnet Joint on Main Feedwater Pump (P-1A) Recirculation

Valve CV-0711

Miscellaneous Field Change Installation Adjustments for EC-86710 Temporary Leak Revision 0

Request 86817 Repair of the Pressure-Seal Body-to-Bonnet Joint on Main

Feedwater Pump (P-1A) Recirculation Valve CV-0711

Procedures MO-33 Control Room Ventilation Emergency Operation 04/22/2020

Work Orders 0052856686 52-2624 (VC-10) OPS PMT 04/21/2020

00534222-03 3Y-8; New HGA Relay for VC-10 PMT 04/21/2020

00543553-01 CV-0711 - P-1A Recirc Valve 04/28/2020

00543843-02 CV-2004, OPS PMT 05/06/2020

71111.22 Corrective Action CR-PLP-2020- Cylinder Exhaust Temperature for 9R Cylinder was Found 04/21/2020

Documents 01247 Low Out of Specification

CR-PLP-2020- Relay for High Pressure Safety Injection (HPSI) P-66A 04/22/2020

280 Protection was Found to Have its High Dropout, Dropout

Low

CR-PLP-2020- SPI Control Rod Position Indication 06/22/2020

01970

Procedures MO-7A-2 Emergency Diesel Generator 1-2 04/21/2020

QI-3 Reactor Protection Matrix Logic Tests Revision 7

QO-42 Inservice Testing of Shutdown Cooling Control Valves Revision 24

QO-42 Mode 1, 2, or 3 (Greater than 325°F) Valve Exercising 06/10/2020

11 Stroke Time Data Sheet

Work Orders 0052910968-01 MO-7A-2 Emergency Diesel Generator 1-2 (K6B) 04/06/2020

0052925885-01 QO-42 IST Shutdown Cooling Valves 06/10/2020

71124.03 Corrective Action CR-PLP-2019- PortaCount Suspicious Fit Factor Warning Received 03/19/2019

Documents 01160

Miscellaneous FPF-GET-RPT MSA Powered Air Purifying Respirator Practical Revision 29

2

MED FPEX-MED- Respirator Medical Evaluation Records for Various Various

PHYRSP Individuals Dates

N/A Posi3 USB Test Results for Scott Air-Paks 0867 and 1681 09/04/2019

N/A Posi3 USB Test Results for Scott Air-Pak 1685 09/05/2019

PL-TRN19-2924 SCBA Practical and Fit Test 12/13/2019

PL-TRN20-0563 SCBA Practical and Fit Test 04/07/2020

PL-TRN20-0570 SCBA Practical and Fit Test 04/07/2020

PLLP-FBT- Training for Scott Air-Pak Self Contained Breathing Revision 06

SCOTTSCBA75 Apparatus

WI-RSD-T-008 SCBA Inspection Log 03/13/2020

Procedures EN-RP-502 Inspection and Maintenance of Respiratory Protection Revision 10

Equipment

EN-RP-505 PortaCount Respirator Fit Testing Revision 07

Radiation Work 20190310 Forced Outage Containment Decontamination Activities Revision 00

Permits (RWPs) 20190318 Pressurizer Spray Valve CV-1057 Maintenance Revision 02

Work Orders 52906597 B5B SCBA Breathing Air Systems 02/20/2020

2907638 Respiratory Protection Equipment Inspection 04/09/2020

71124.04 Corrective Action CR-PLP-2019- Dose Rate Alarm During Charging Pump Work 02/27/2019

Documents 00857

Corrective Action CR-HQN-2020- EN-RP-206 Potential Causes for Dosimetry Discrepancies 05/11/2020

Documents 01009 High-E Code Value Low

Resulting from CR-PLP-2020- Dosimetry Discrepancies and Ag-110m 05/12/2020

Inspection 01517

Miscellaneous EN-RP-203, Dosimetry Investigation Report for Various Individuals 02/27/2020

9.3

PLP-RPT-19-009 Update to TID 2015-008 rev 5, Palisades Dosimetry Revision 0

Background Performance

Procedures EN-RP-210 Area Monitoring Program Revision 1

Work Orders 52814864 TLD Monitoring Program 04/01/2019

71151 Corrective Action CR-PLP-2020- The Monthly Performance Indicator (PI) for Critical Scope 04/01/2020

Documents 01041 Survival and Schedule Completion Changed from Green to

Red for the Month of March 2020

Miscellaneous 4Q2019 NRC Performance Indicators 10/01/2019 -

2/31/2019

3Q2019 NRC Performance Indicators 07/01/2019 -

09/30/2019

2Q2019 NRC Performance Indicators 04/01/2019 -

06/30/2019

1Q2020 NRC Indicator Safety System Functional Failures 01/01/2020 -

03/31/2020

4Q2019 NRC Indicator Safety System Functional Failures 10/01/2019 -

2/31/2019

3Q2019 NRC Indicator Safety System Functional Failures 07/01/2019 -

09/31/2019

2Q2019 NRC Indicator Safety System Functional Failures 04/01/2019 -

06/30/2019

1Q2020 NRC Performance Indicators 01/01/2020 -

03/31/2020

71152 Corrective Action CR-PLP-2019- Inadvertent Water Transfer from SFP to SIRWT 09/05/2019

Documents 03474

CR-PLP-2020- RV-2006 Lifted Unexpectedly During Plant Evolution 04/14/2020

00611

CR-PLP-2020- Palisades Oversight of Switchyard Activities 03/02/2020

00696

CR-PLP-2020- Received Alarm EK-0704, Letdown Heat Exch Tube Inlet Hi- 04/22/2020

284 Lo Press Unexpectedly

CR-PLP-2020- Received EK-0704, Letdown Heat Exch Tube Hi-Lo Press 04/26/2020

01314 Momentarily While Lowering Charging Letdown per SOP-2A

CR-PLP-2020- The PPC Shows a Declining Tave Trend on the "8 Hour" 06/06/2020

01818 and "Day" Trend Time Frames

CR-PLP-2020- Quench Tk Level and Pressure Along with a Rise in 06/17/2020

01938 Temperature on RV-2006 Intermediate Letdown Relief Valve

CR-PLP-2020- On 06/04/2020 Quench Tank Pressure Started Rising at a 06/17/2020

01950 Rate of Approximately 1.2 psig/day

Miscellaneous DPRM/APRM Report 02/2020

DPRM/APRM Report 11/2019

71152 Procedures EN-LI-102 Corrective Action Program Revision 40

EN-LI-118 Casual Analysis Process Revision 31

Work Orders 0052910968-01 MO-7A-2 Emergency Diesel Generator 1-2 (K-6B) 04/06/2020

17