Text

Integrated Inspection Report 05000255/2021001
	ML21132A222
Person / Time
Site:	Palisades
Issue date:	05/12/2021
From:	Billy Dickson; NRC/RGN-III/DRP/B2
To:	Corbin D; Entergy Nuclear Operations
References
	IR 2021001
	Download: ML21132A222 (19)
	v • d • e

May 12, 2021

SUBJECT:

PALISADES NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000255/2021001

Dear Mr. Corbin:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant. On April 22, 2021, 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.

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 of the Enforcement Policy.

If you contest the violation or the 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 Nuclear Plant.

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 Nuclear Plant. 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/

Billy C. Dickson, Jr., 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:

05000255/2021001

Enterprise Identifier: I-2021-001-0043

Licensee:

Entergy Nuclear Operations, Inc.

Facility:

Palisades Nuclear Plant

Location:

Covert, MI

Inspection Dates:

January 01, 2021 to March 31, 2021

Inspectors:

R. Baker, Senior Operations Engineer

J. Hanna, Senior Reactor Analyst

P. Laflamme, Senior Resident Inspector

V. Meghani, Reactor Inspector

C. St. Peters, Resident Inspector

Approved By:

Billy C. Dickson, Jr., 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

Failure to Follow Procedure Resulted in Cotter Pin Misalignment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000255/2021001-01 Open/Closed

[H.12] - Avoid Complacency 71152 A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1a was identified for failure to follow the procedure for coupling valve CV-0826, "Component Cooling Water (CCW) Heat Exchanger E-54B Service Water Outlet" to its Bettis actuator. Specifically, the licensee failed to insert the cotter pin through the coupling and connecting shaft in accordance with SOP-15 "Service Water System" step 5.2g.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000255/2020-001-00 LER 2020-001-00 for the Palisades Nuclear Plant Service Water System Inoperable for Longer than Allowed by Technical Specifications 71153 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 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 Disease 2019 (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; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; 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 portions 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.

REACTOR SAFETY

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)1-2 emergency diesel generator (EDG) starting air system on January 8, 2021.

(2)7 A service water system on January 28, 2021.

(3) Station battery number 2 system on February 3, 2021.

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 9; screen house/intake structure on January 28, 2021.

(2) Fire Area 13 A: auxiliary building corridor 590' elevation on February 1, 2021.

(3) Fire Area 11: battery room on March 26, 2021.

(4) Fire Area 26: southwest cable penetration room on March 29, 2021.

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the on-site fire brigade training and performance during an unannounced fire drill on January 21, 2021.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Auxiliary feedwater (AFW) room 570' elevation on February 11, 2021.

===71111.11 A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03)===

Main article: IP 71111.11

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating and biennial written examinations administered from January 6, 2021 through February 10, 2021.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during RO-145 A AFW testing on March 10, 2020.

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

(1) The inspectors observed and evaluated NRC simulator scenarios SES-245 and SES-250 on February 10, 2021.

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) CCW on January 26, 2021.

(2) Service water system on March 11, 2021.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 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) Elevated risk due to planned maintenance and testing on P-66B, high pressure safety injection (HPSI) pump, on January 13, 2021.

(2) Yellow risk due to planned maintenance and testing of P-52B CCW and AFW system on January 25, 2021.

(3) Elevated risk due to 1-2 EDG planned maintenance on February 18, 2021.

(4) Elevated risk due to planned Safety Injection actuation testing on February 24, 2021.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

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

(1) Primary coolant pump 50B lower seal on January 13, 2021.

(2) E-54 A CCW heat exchanger (HX) south end bell evaluation on January 15, 2021.

(3) Station battery number 2 cell cover evaluation on February 9, 2021.

(4) Station battery number 1 cracked jar evaluation on February 11, 2021.

(5) Bus 1C 2400 V Z-phase over current evaluation on March 17, 2021.

(6) Direct current (DC) bus 2 ground detection evaluation on March 30, 2021.

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change (EC) 86031; Primary Coolant System (PCS) Uncontrolled Bleed-off Lines Modification on January 27, 2021.

(2) EC 89080; Station Battery #2 Temporary Modification on February 23, 2021.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

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

(1) Left train HPSI valve testing following planned breaker maintenance on January 6, 2021.

(2) P-55 A charging pump test following suction and discharge accumulator checks, on January 7, 2021.

(3) P-8B turbine driven AFW pump steam supply valve maintenance and testing on February 9, 2021.

(4) EDG 1-2 testing following relay maintenance on February 18, 2021.

(5) EDG 1-1 turbocharger support weld repair on March 9, 2021.

(6) Control Room heating, ventilation, and air conditioning B Train following maintenance on March 24, 2021.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22

(1) QO-14B: Service Water Pump P-7B Surveillance, on January 15, 2021.

(2) RO-145B: P-8B AFW Comprehensive Pump Test on February 9, 2021.

(3) QO-16 A P-54 A Containment Spray Pump Test, on February 22, 2021.

Inservice Testing (IP Section 03.01) (1 Sample)

(1) QO-19B: P-66B HPSI Inservice Test Surveillance, on January 27, 2021.

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Daily PCS Leak Rate Surveillance on February 2, 2021.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated an Emergency Preparedness (EP) drill on March 2,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01)===

Main article: IP 71151

(1) Unit 1 (January 1, 2020 - December 31, 2020)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (1 Sample)

(1) Unit 1 (January 1, 2020 - December 31, 2020)

MS08: Heat Removal Systems (IP Section 03.07) (1 Sample)

(1) Unit 1 (January 1, 2020 - December 31, 2020)

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) Causal evaluation for service water to CCW heat exchanger cotter pin misalignment as documented in CR-PLP-2020-02365 on January 12, 2021.

(2) Causal evaluation for P-50B primary coolant pump seal pressure changes as documented in CR-PLP-2021-00080 on March 25, 2021.

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

Main article: IP 71153

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 0000255/2020-01-00, Service Water System Inoperable for Longer than Allowed by Technical Specifications (ADAMS Accession No. ML20269A166). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.

INSPECTION RESULTS

Failure to Follow Procedure Resulted in Cotter Pin Misalignment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000255/2021001-01 Open/Closed

[H.12] - Avoid Complacency 71152 A self-revealed Green finding and associated NCV of TS 5.4.1 a was identified for failure to follow the procedure for coupling valve CV-0826, "Component Cooling Water (CCW) Heat Exchanger E-54B Service Water Outlet" to its Bettis actuator. Specifically, the licensee failed to insert the cotter pin through the coupling and connecting shaft in accordance with SOP-15 "Service Water System" step 5.2g.

Description:

On July 27, 2020, while the unit was in Mode 1, the licensee received Alarm EK-1170, "Component CLG EX-54 A HI-LO TEMP," due to higher service water temperatures as a result of elevated Lake Michigan bulk temperature. In response, control room operators adjusted HIC-0826, "Instrument Air Regulator for CV-0826." The operators then attempted to cycle CV-0826 to the open position from the control room. However, the operators observed while attempting to open the valve remotely that the corresponding expected pressure changes to the service water system had not occurred but noted the light indication for valve CV-0826 had changed from green to red, indicating the valve had opened. Upon investigating locally, the licensee observed the Bettis actuator was rotating, but the valve was not moving. The non-movement of the valve occurred because the cotter pin was not inserted in the Bettis operator alignment position. Instead, the cotter pin had been installed through the shaft gap that provided adequate collar engagement during previous strokes until July 27, 2020. In response, operators realigned the collar and cotter pin for CV-0826 to the Bettis operator. Following the realignment, the operators successfully opened the valve from the control room.

As a result of the misalignment issue, the licensee performed a causal evaluation which the inspectors reviewed in-depth. In their review, the inspectors noted that operators placed CV-0826 on its manual handwheel operator supporting maintenance on the CCW system during the 1R26 refueling outage in the fall of 2018. Later, following completion of CCW system maintenance, on November 9, 2018, licensee staff attempted to place CV-0826 on its Bettis actuator following step 5.2g of SOP-15, which stated in part, insert the cotter pin through the coupling and connecting shaft in order to retain coupling in place. However, instead of inserting the cotter pin in the shaft alignment hole that would securely align the Bettis operator to CV-0826, the licensee inserted the cotter pin through the shaft gap. This configuration allowed for sufficient Bettis operator engagement via shaft and collar alignment during quarterly inservice test (IST) stroke tests from November 9, 2018, until May 27, 2020, allowing successful surveillance test completion each quarter. Specifically, the licensee stated the coupling was mated to both the Bettis and valve shafts enough that the valve stem was sufficiently engaged to allow remote operation. The licensee noted that over time, the Bettis actuator became disengaged from the valve shaft. As a result, the licensee determined that the CV-0826 misalignment issue had rendered the A train of service water inoperable from May 27, 2020, until July 28, 2020, when the operators successfully realigned the valve and the Bettis operator.

The site submitted LER 0000255/2020-01-00, Service Water System Inoperable for Longer than Allowed by TSs, for this event. The inspectors review of LER 0000255/2020-01-00 is documented in report section 71153 of this inspection report.

Corrective Actions: The licensee coupled valve CV-0826 to its Bettis actuator. The licensee performed an apparent cause analysis and generated corrective actions from the results.

These corrective actions included revising procedure SOP-15 and reviewing the condition with all site nuclear plant operators.

Corrective Action References: CR-PLP-2020-02365

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee's failure to insert the cotter pin through the coupling in accordance with SOP-15 step 5.2g was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to follow procedure resulted in the cotter pin not being properly inserted.

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 finding against the Mitigating Systems screening questions in Exhibit 2 and answered "YES" to Question 3. Based on this screening, a detailed risk evaluation was required. A regional Senior Reactor Analyst used the Palisades Simplified Plant Analysis Risk model and calculated the impact of the performance deficiency by setting the basic event for the valve equal to True. An exposure time of 62 days was used, which was the duration since the prior successful surveillance test. The dominant sequence was a Loss of DC Bus-20 leading to a primary coolant pump seal loss-of-coolant accident. The analyst added the fire results the licensee provided from their fire probabilistic risk assessment model and the resultant increase in Core Damage Frequency ( CDF) for this condition was 7.1x10-7, therefore, this condition should be treated as a green finding. External Events and Large Early Release Frequency were considered qualitatively and determined to have negligible impact on the result.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee failed to recognize the cotter pin could be inserted in the space between the CV-0826 valve shaft and the Bettis actuator valve shaft.

Enforcement:

Violation: TS Section 5.4.1a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February,1978.

NRC Regulatory Guide 1.33, Revision 2, Appendix A, Section 3 addresses Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems and subparagraph m, addresses Service Water System. The licensee established Procedure SOP 15, Revision 70 to address operating the service water system. Procedure SOP-15, Revision 70, Step 5.2 g requires the licensee to insert cotter pin through coupling and connecting shaft in order to retain coupling in place.

TS Limiting Condition for Operability 3.7.8 requires that two service water system (SWS)trains shall be operable in Modes 1, 2, 3, and 4. Condition A. requires that with one or more SWS trains inoperable, restores train(s) to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If the required action in Condition A is not met, required action in B.1 states be in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the required action in B.2 states be in Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Contrary to the above, from November 9, 2018, to July 28, 2020, the licensee failed to implement Step 5.2g of procedure SOP-15. Specifically, the licensee did not insert the cotter pin through the coupling and connecting shaft on the Bettis actuator shaft for valve CV-0826.

Consequently, from May 27, 2020, to July 28, 2020, when the SWS left train was last surveilled and the cotter pin inserted correctly, the SWS train was inoperable for a period greater than the TS allowed outage time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and the required actions in TS 3.7.8.B.1 and TS 3.7.8.B.2 were not followed. The reactor was in Mode 1 during the time the SWS left train was inoperable.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Causal Evaluation Review: Seal Pressure Changes on Primary Coolant Pump P-50B 71152 The inspectors reviewed the associated causal evaluation, failure mode analysis, the extent of condition, and corrective actions taken for the sudden differential pressure reduction across the lower seal stage on Primary Coolant Pump (PCP) P-50B that occurred on January 13, 2021. The inspectors noted that the licensee attributed the direct cause to seat leakage across CK-CRW402, Primary Coolant Pump Seal Leakage Check Valve. This seat leakage that allowed backpressure from the Primary System Drain Tank (PSDT) to reach and affect the lower stage of P-50B and consequential reduction in differential pressure.

Specifically, normal and expected bleed-off (referred to as uncontrolled bleed-off by design)of primary system coolant travels from the PCP seal stages to the PSDT, which flows through CK-CRW402, a non-safety related component. Due to identified valve seat leakage across CK-CRW402, backpressure from the PSDT communicated with P-50B, which resulted in a sudden differential pressure reduction across the lower seal stage during a planned evolution that momentarily raised PSDT pressure slightly as expected per design. Since the resultant pressure drop was not significant enough to impact seal performance, the associated PCP was not adversely impacted. For corrective actions, the licensee rerouted the normal uncontrolled bleed-off piping directly to the containment sump, bypassing communication with the PSDT and removing CK-CRW402 from the flow path entirely. The inspectors concluded that the licensee completed the causal evaluation, the extent of condition, and subsequent modification bypassing original PSDT communication timely and effectively, commensurate with safety significance. No issues of significance were identified.

EXIT MEETINGS AND DEBRIEFS

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

On April 22, 2021, the inspectors presented the integrated inspection results to Mr. D. Corbin, Site Vice President Operations, and other members of the licensee staff.

On February 18, 2021, the inspectors presented the licensed operator requalification program annual operating and biennial written test results inspection results to Mr. F. Korfias, Simulator and Training Support Superintendent, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Corrective Action

Documents

CR-PLP-2021-

00845

DC Bus #2 Ground Volt Indicator Reading out of

Specification

03/26/2021

Corrective Action

Documents

Resulting from

Inspection

CR-PLP-2021-

282

NRC Senior Resident Inspector Identified Debris in the #19,

22, #31, and #39 Battery Cells

2/03/2021

Engineering

Changes

89170

NRC Identified Condition - EC Reply for ED-02 Cell 19, 22 l

31, and 39 Plastic Shavings

Procedures

SOP-15

Service Water System

SOP-22

Emergency Diesel Generators

71111.05

Corrective Action

Documents

CR-PLP-2021-

00529

Small Puddle of Coolant on the Floor that had Leaked from

P-41 D Diesel Driven Cooling Tower Fire Water PP

2/27/2021

CR-PLP-2021-

00534

P-41 Diesel Driven Cooling Tower Fire Water PP Seemingly

to be Excessively Warm

2/28/2021

CR-PLP-2021-

00846

Puddle of Diesel Fuel Oil on Floor Near P-9B, Diesel Driven

Fire Pump

03/28/2021

Fire Plans

Pre-Fire Plan 13A Main Corridor - North & South/Elevation 590

Pre-Fire Plan 9

Screen House/Intake Structure/Elevation 590

71111.06

Corrective Action

Documents

Resulting from

Inspection

CR-PLP-2021-

00079

NRC Resident Identified Ladder Station #7 Sign Needed to

be Re-Attached and Water on the Floor Along the West Wall

Under MV-FW765A (AFW Pump P-8C to E-50B Line Drain)

01/13/2021

Procedures

DBD 1.03

Auxiliary Feedwater System

71111.11 A Miscellaneous

Palisades Licensed Operator Requalification Annual

Examination Summary Results for 2021

2/18/2021

71111.11Q

Corrective Action

Documents

CR-PLP-2021-

00367

A Senior Reactor Operator Failed the LOR NRC Biennial

Written Exam

2/10/2021

Miscellaneous

SES-245

NRC Simulator Scenarios

SES-250

NRC Simulator Scenarios

Procedures

RO-145 A

Comprehensive Pump Test Procedure Auxiliary Feedwater

Pumps P-8 A, P-8B, and P-8C

71111.12

Corrective Action

CR-PLP-2021-

NRC Identified: Critical Service Water (CSW) System

03/25/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

Resulting from

Inspection

00833

Maintenance Rule Functional Failures (MRFFs) not Listed in

CSW System Health Report for 4Q 2020

Miscellaneous

System Health Report - CCS (Component Cooling)

10/01/2018 -

2/31/2018

System Health Report - CCS (Component Cooling)

04/01/2019 -

06/30/2019

System Health Report - CCS (Component Cooling)

10/01/2019 -

2/31/2019

System Health Report - CCS (Component Cooling)

04/01/2020 -

06/30/2020

System Health Report - CCS (Component Cooling)

10/01/2020 -

2/31/2020