IR 05000255/2021004
| ML22031A283 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/08/2022 |
| From: | Billy Dickson NRC/RGN-III/DRP/B2 |
| To: | Corbin D Entergy Nuclear Operations |
| References | |
| EA-21-159 IR 2021004 | |
| Download: ML22031A283 (27) | |
Text
SUBJECT:
PALISADES NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000255/2021004 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Corbin:
On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant. On January 19, 2022, 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 did not involve a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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.
February 7, 2022 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, 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:
Report Number:
Enterprise Identifier:
I-2021-004-0113
Licensee:
Entergy Nuclear Operations, Inc.
Facility:
Palisades Nuclear Plant
Location:
Covert, MI
Inspection Dates:
October 01, 2021 to December 31, 2021
Inspectors:
J. Cassidy, Senior Health Physicist
J. Corujo-Sandin, Senior Reactor Inspector
G. Hansen, Sr. Emergency Preparedness Inspector
J. Havertape, Reliability and Risk Analyst
P. Laflamme, Senior Resident Inspector
J. Mancuso, Resident Inspector, Donald C. Cook Nuclear Plant
C. St. Peters, Resident Inspector
R. Trelka, Reactor 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 Preventative Maintenance Change Request Process Results in a Failure of Condensate Pump (P-2B) Oil Cooler and Subsequent Rapid Downpower Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000255/2021004-01 Open/Closed
[P.5] -
Operating Experience 71152 A finding of green significance was self-revealed on July 28, 2021, for the licensee's failure to follow their preventative maintenance change request (PMCR) process. Specifically, a preventative maintenance activity scope was changed without processing a PMCR, resulting in a failure to perform the preventative maintenance on the condensate pump (P-2B) oil cooler. As a result, a pin hole leak developed in the P-2B oil cooler leading to an oil/water mixture discharging from the P-2B motor's upper bearing housing sight glass vent, and the subsequent need to perform a rapid downpower of the reactor to secure P-2B.
Additional Tracking Items
Type Issue Number Title Report Section Status EDG EA-21-159 Failure to Comply with 10 CFR Part 37 71124.08 Closed
PLANT STATUS
The plant began the inspection period at full power and remained at or near full power for the entire 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 activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems on November 4, 2020:
Service water system
Auxiliary feedwater (AFW) system
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk significant systems from impending severe weather during a Geomagnetic Storm Watch on October 30, 2021.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Left train low pressure safety injection on October 6, 2021
- (2) Right train high pressure safety injection on October 1, 2021
- (3) Left train AFW on October 26, 2021
- (4) Right train containment spray on December 4, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 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 1: Control Room/Elev. 625' and Fire Area 33: Technical Support Center/
Elev. 625' on October 1, 2021
- (2) Fire Area 22: Turbine Lube Oil Room/ Elev. 590' on October 7, 2021
- (3) Fire Area 29-31: Mechanical Equipment Room/ Elev. 629'-2" & 639' on October 13, 2021
- (4) Fire Area 13G: Spent Fuel Pool Heat Exchanger Room/ Elev. 590' on October 16, 2021
- (5) Fire Area 6 & 8: Diesel Generator 1-2 and Fuel Oil Day Tank Room/ Elev. 590' on November 13, 2021
- (6) Fire Area 59: Auxiliary Feedwater Pump P-8D Room/ Elev. 590' on November 17, 2021
- (7) Fire Area 15: Engineering Safeguards Panel and Stairway/ Elev. 570'-664' on December 2, 2021
- (8) Fire Area 21: Electrical Equipment Room/ Elev. 607'-6" on December 13, 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) Emergency Diesel Generator (EDG) rooms on October 18, 2021
71111.07T - Heat Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)
The inspectors evaluated heat exchanger/sink performance on the following:
- (1) Control Room Heating, Ventilation, and Air Conditioning (HVAC) Refrigerant Condensing Units (VC-10)
- (2) Control Room HVAC Refrigerant Condensing Units (VC-11)
Ultimate Heat Sink (IP Section 03.04) (1 Sample)
- (1) The Ultimate Heat Sink, Specifically Sections 03.04.d and 03.04.e were completed
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during a downpower to support QO-21C (P-8C AFW pump testing) on October 25, 2021.
- (2) The inspectors observed and evaluated licensed operator performance in the Control Room during QO-1 SI Actuation Test (elevated risk evolution) - right train on November 30, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated PLSEG-LOR-21E-04, EOP 5.0, and PLSEG-LOR-21E-02, EP Static, on November 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) Reactor protection system on October 27, 2021
- (2) Primary coolant system on December 1, 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) Emergent issues associated with EDG 1-2 monthly surveillance, on October 6, 2021
- (2) Yellow risk due to left train of service water out of service for planned maintenance and testing, on October 14, 2021
- (3) Emergent work activities associated with P-55A charging pump following speed oscillations, on November 12, 2021
- (4) Emergent work activities on 1-2 EDG jacket water temperature switch, on December 1, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Service water system evaluation on October 4, 2021
- (2) Station Battery No. 1 and 2 system evaluation on December 13, 2021
- (3) Pressurizer spray valve evaluation on December 15, 2021
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)-90291; T-2 Return Line Heat Exchanger Modification on December 6, 2021.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) EDG 1-2 timed start following check valve replacement, on October 28, 2021
- (2) CVCO-4 performed on the P-55A charging pump following flow drive replacement, on December 2, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) QO-15A, Inservice Test Procedure-Component Cooling Water Pump P-52A, on October 5, 2021
- (2) QO-16C, Inservice test procedure-Containment Spray Pump P-54C, on October 13, 2021
- (3) QO-1, SI Actuation Test (left train), on November 30, 2021
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.
The licensee did not make any changes to the site's Emergency Action Level procedures or Emergency Plan during the period of this inspection (July 1, 2020 through June 30, 2021). The NRC inspectors independently reviewed the revisions of the site's Emergency Action Level procedures and Emergency Plan that were current for the inspection period to verify no changes were made.
This evaluation does not constitute NRC approval.
RADIATION SAFETY
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Spent Fuel Pool Ventilation - Unit 1
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (9 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Portable Ion Chamber Dose Rate Instruments "Ready for Use" at the entrance to the radiologically controlled area
- (2) Extendable Geiger-Mueller Dose Rate Instruments "Ready for Use" at the entrance to the radiologically controlled area
- (3) Personnel Contamination Monitors used at the exit of the radiologically controlled area
- (4) Small Article Contamination Monitor used at the exit of the radiologically controlled area
- (5) Shepherd Model 89 Box Calibrator used to perform functional checks of portable dose rate instruments
- (6) Portable Geiger-Mueller Frisker "Ready for Use" at the Main Access Facility
- (7) Personnel Gamma Portal Monitor used to exit the Main Access Facility
- (8) Personnel Contamination Monitors used at the exit of East Radwaste radiologically controlled area
- (9) Personnel Gamma Portal Monitor used to exit East Radwaste radiologically controlled area
Calibration and Testing Program (IP Section 03.02) (13 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Model 3030 Scaler Serial Number 334592
- (2) DMC-3000 Electronic Dosimeter Serial Number A168801
- (3) Telepole Serial Number 6605-002
- (4) RO-20 Serial Number 1445
- (5) Shepherd Model 89 Box Calibrator Serial Number 91-1134
- (6) Model 3 Frisker Instrument # 238945
- (7) GEM-5 Monitor 1803-091
- (8) ARGOS Monitor ID 1712-184
- (9) PCM-2 ID 457
- (10) SAM12 Serial Number 202
- (11) RADECO Model HD-29A Air Sampler UTC No 17379
- (12) Protean Model WPC-1050 Serial Number 11171115
- (13) FASTSCAN Whole Body Counter Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Unit 1, Liquid Radwaste Discharge Monitor, RIA-1049
- (2) Unit 1, High Range Noble Gas Effluent Monitor, RIA-2327
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
- (1) Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials.
- (2) Inspectors evaluated the licensees performance in accounting and verification that sealed sources have been verified to be intact.
Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)
- (1) Inspectors walked down accessible portions of the solid radioactive waste systems on 590' auxiliary building and evaluated system configuration and functionality.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) October 1, 2020 - September 30, 2021
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) October 1, 2020 - September 30, 2021 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) October 2020 - September 2021
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) October 2020 - September 2021 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) October 2020 - September 2021
71152 - Problem Identification and Resolution (PI&R)
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in equipment reliability that might be indicative of a more significant safety issue during the period of July 1, 2021, to December 31, 2021.
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 2B condensate pump oil cooler water intrusion and subsequent reactor power reduction as documented in CR-PLP-2021-01984 on November 29, 2021.
(2)1-2 EDG cylinder 7L crack and subsequent online maintenance and liner replacement causal evaluation as documented in CR-PLP-2021-02180 on December 16,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===71003 - Post-Approval Site Inspection for License Renewal The team conducted a partial Phase IV license renewal inspection (Section 02.02.d).
Specifically, with a focus on verifying the management of aging effects in accordance with the aging management program(s).
Post-Approval Site Inspection for License Renewal===
- (1) The following aging management program was evaluated by the team:
Open Cycle Cooling Water Program
INSPECTION RESULTS
Enforcement Discretion Enforcement Action EA-21-159: Failure to Comply with 10 CFR Part 37 71124.08
Description:
On August 2, 2016, the licensee was issued NRC Inspection Report No. 05000255/2016407, which documented a licensee identified violation of 10 CFR Part 37, Physical Protection of Category 1 and Category 2, Quantities of Radioactive Material at Facilities with a 10 CFR Part 73, Physical Protection Program. The violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52."
Subsequently, the inspectors re-evaluated this activity and found that while a violation of regulatory requirements continues to exist, the conditions remain within the criteria for enforcement discretion established within EGM 14-001.
Corrective Actions: As specified in EGM 14-001, the application of discretion is authorized until the underlying technical issue is dispositioned through rulemaking or other regulatory action. Additional corrective actions are not required.
Corrective Action References: Not Applicable.
Enforcement:
Violation: On August 2, 2016, a violation of 10 CFR Part 37 was documented in Palisades Inspection Report No.05000255/2016407. The inspectors determined that the previously identified violation remains.
Basis for Discretion: This violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52."
Failure to Follow Preventative Maintenance Change Request Process Results in a Failure of Condensate Pump (P-2B) Oil Cooler and Subsequent Rapid Downpower Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000255/2021004-01 Open/Closed
[P.5] -
Operating Experience 71152 A finding of green significance was self-revealed on July 28, 2021, for the licensee's failure to follow their preventative maintenance change request (PMCR) process. Specifically, a preventative maintenance activity scope was changed without processing a PMCR, resulting in a failure to perform the preventative maintenance on the condensate pump (P-2B) oil cooler. As a result, a pin hole leak developed in the P-2B oil cooler leading to an oil/water mixture discharging from the P-2B motor's upper bearing housing sight glass vent, and the subsequent need to perform a rapid downpower of the reactor to secure P-2B.
Description:
On July 28, 2021, the control room received an unexpected alarm, EK-0162 (Condensate Pump P-2B High Temp or Overload), with the unit at full power. The licensee locally inspected condensate pump P-2B and found an oil/water mixture discharging from the motor's upper bearing housing sight glass vent. Shortly after discovering the oil/water mixture condition, the site entered Abnormal Operating Procedure (AOP) 7, "Rapid Downpower." The operators reduced power to approximately 25 percent and then secured pump P-2B. The licensee performed work order (WO) 565778. During the work, the licensee confirmed that the upper bearing oil cooler had developed a service water leak at one of the brass fittings used to connect to the service water inlet/outlet piping. The licensee cleaned and dried the upper bearing housing, then flushed the housing and bearing and installed a new bearing oil cooler. Pump P-2B was returned to service on July 29, 2021.
The licensee performed an apparent cause analysis (ACA). The ACA determined that sand entrained in the service water eroded the copper/brass cooler at a bend in the brass inlet/outlet connection, causing a pinhole leak at the brass fitting of the upper bearing oil cooler. The ACA identified that a preventative maintenance (PM) activity existed to replace the oil cooler periodically. In the ACA, the licensee noted their staff had deferred the PM activity several times, and the replacement did not occur as scheduled during the Fall 2018 refueling outage, 1R26. Instead, the PM activity was re-planned to use the 1R26 motor refurbishment work order to complete the oil cooler replacement. The licensee determined that their staff did not revise the 1R26 motor refurbishment work order to include oil cooler replacement. The ACA also noted incorrect interpretation of EN-WM-102, "Work Implementation and Closeout," and EN-DC-324, "Preventative Maintenance Program" by licensee staff. The wrong interpretation of EN-DC-324 resulted in the licensee staff changing the scope of the oil cooler replacement PM from replacement to cleaning and testing, which resulted in the oil cooler not being replaced. On the contrary, when the scope was changed, the licensee staff should have processed a PMCR per step 5.5.3 of EN-DC-324. The site also noted in the ACA that a previous leak in the P-2B motor upper oil cooler occurred on July 22, 2004, and also required a rapid downpower to remove the P-2B condensate pump.
The inspectors evaluated the licensee's emergent work, rapid downpower, post-maintenance testing, and ACA associated with this event. The inspectors determined the licensee failed to follow the PMCR process when changing the PMs scope, which resulted in the site failing to perform preventative maintenance.
Corrective Actions: The site wrote a condition report (CR) and performed an ACA. The licensee replaced the P-2B motor's upper bearing oil cooler. The site also added pre-outage refresher training to reinforce expectations. The site revised PMIDs and associated work orders to include a statement that the bearing oil cooler replacement is not to be delayed beyond the established PM due date. In addition, the licensee reinforced with staff that they cannot make changes to a work order without work order feedback or an approved PMCR.
Corrective Action References: CR-PLP-2021-1984
Performance Assessment:
Performance Deficiency: The licensee failed to follow fleet procedure EN-DC-324, "Preventative Maintenance Program," step 5.5.3. Specifically, the licensee changed the scope of the associated P-2B condensate pump oil cooler PM and failed to process a PMCR.
This led to the licensee crediting cleaning and testing by the motor vendor versus periodic replacement of the oil cooler, resulting in the P-2B oil cooler failing and the site performing a rapid downpower.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee changed the scope of the planned PM on the condensate pump P-2B oil cooler without processing a PMCR due to incorrect interpretation of EN-DC-324. The oil cooler eventually failed due to a pinhole leak from entrained sand, and the licensee had to perform a rapid downpower in order to take the P-2B condensate pump out of service.
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 Initiating Events screening questions in Exhibit 1 and answered "No" to the Transient Initiators question. This resulted in the finding screening to green.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. Specifically, the licensee had previous operating experience with the same event happening in 2004. This operating experience, at the site, was not captured in the preventative maintenance activity to provide background as to why the PM activity existed.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Observation: 1-2 EDG Cylinder 7L Crack Evaluation 71152 The inspectors reviewed the associated causal evaluation, "Why Staircase" analysis, equipment failure evaluation, the extent of condition, subsequent vendor analysis, and corrective actions taken for a crack in the liner of cylinder 7L on EDG 1-2 that the licensee discovered during a monthly surveillance test. Specifically, licensee personnel identified exhaust coming out of the associated crack on August 16, 2021, rendering the 1-2 EDG inoperable. After declaring the diesel generator inoperable, the licensee proceeded with a visual inspection of all cylinders on both diesel generators and subsequent liner replacement and verified that no additional cracks or exhaust leaks were present. In parallel, the inspectors performed an extent of condition walkdown of both EDGs, discussed the condition with operations, monitored liner replacement activities, and reviewed subsequent post-maintenance testing. The inspectors noted that the direct cause of the cylinder 7L liner crack was due to low-cycle fatigue. Specifically, the low-cycle fatigue resulted from preloading stress, thermal cycling, and non-uniform seating surface conditions going back to the original liner installation in 1996. The inspectors noted that both licensee and vendor review concluded the standards for seating surface conditions had been met at the time of original liner installation. Therefore, the inspectors determined that the identified crack was not within the licensees ability to foresee or prevent before identification during planned monthly testing on August 16, 2021. For corrective actions, the licensee successfully replaced the 7L liner and initiated measures to develop and implement a preventative maintenance strategy to ensure adequate seating surface conditions to lower fatigue stresses. The inspectors identified no issues of significance.
Observation: Semiannual Trend Review 71152 The inspectors' review focused on equipment reliability and considered the results of daily inspector Corrective Action Program (CAP) item screening and licensee trending efforts. The inspectors' review nominally considered the six months of July 2021 through December 2021, although some examples expanded beyond those dates when warranted by the trend's scope.
The inspectors reviewed condition reports, trend reports, and engineering calculations addressing human performance and equipment reliability at the site. During the inspection period, the NRC inspectors noted a few challenges to equipment reliability. Specifically, the inspectors observed and reviewed the steam dump control relay exceeding the vendor recommended service life, overheating, and rendering the atmospheric dump valves inoperable. The inspectors also observed and reviewed activities associated with other potential challenges to equipment reliability such as the station batteries having multiple cells with cracks, elevated control rod drive (CRD) temperatures, continued "B" primary coolant pump (PCP) seal degradation, and oil cooler replacement for the 2B condensate pump.
The inspectors noted that the licensee identified and monitored the station batteries cell cracks, including developing an adverse condition monitoring plan (ACMP) and performing more frequent inspections of the battery rooms. Also, the inspectors noted that the licensee monitored the increase in CRD 23 elevated temperatures, performed a weekly trend analysis of the seal pressures, and implemented ACMPs for the CRD temperature and for the PCP seal degradation. Regarding the oil cooler replacement, the licensee identified an unexpected alarm, recognized the potential cause, performed a rapid downpower to replace the oil cooler and reduce the potential for a transient to the plant, and completed an ACA to determine the cause of the oil cooler failure. Although these issues illustrated a challenge to equipment reliability, the inspectors reviewed the identified causes and did not identify an adverse trend during this assessment period.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 19, 2022, the inspectors presented the integrated inspection results to Mr. D. Corbin, Vice President, Operations, and other members of the licensee staff.
On December 8, 2021, the inspectors presented the radiation protection inspection results to Mr. D. Nestle, Radiation Protection Manager, and other members of the licensee staff.
On December 8, 2021, the inspectors presented the emergency plan and emergency action level changes review inspection results to Mr. D. Malone, Emergency Planning Manager, and other members of the licensee staff.
On December 14, 2021, the inspectors presented the triennial heat sink and license renewal phase 4 inspection results to Mr. D. Corbin, Vice President, Operations, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-PLP-2020-
03380
Framatone Indication Notification, Change in Material
Condition Reactor Head - Aging Example
09/11/2020
CR-PLP-2020-
04799
QI-5 Found Terminal Block Link #2 in Poor Condition - Aging
Example
2/03/2020
Corrective Action
Documents
CR-PLP-2021-
00733
PIC-1656 Failure - Aging Example
03/17/2021
Corrective Action
Documents
Resulting from
Inspection
CR-PLP-2021-
03130
SEP-RLP-PLP-001 Requirements are Difficult to Implement
2/10/2021
LR-AM R-OCC
Open Cycle Cooling Water System
Miscellaneous
LR-AMPBD-19-
OCCW
Open Cycle Cooling Water Program
NDE Reports
WDLC200316029
Coupon Analysis Report
03/25/2020
71003
Procedures
SEP-AMP-PLP-
2
Palisades Aging Management Program Assessment for
Failed or Degraded Equipment Program Section
Corrective Action
Documents
Resulting from
Inspection
CR-PLP-2021-
03171
NRC Identified: V-21F (Intake Structure Fresh Air Fan) is
Missing a Fastener on the Bottom Right Corner of the
Ventilator as Viewed from the Outside
2/15/2021
Acts of Nature
Diesel Fuel Oil Program
004
SOP-23,
Cold Weather Checklist
Procedures
SOP-23,
Cold Weather Checklist - Electrical
Miscellaneous
DBD-2.03
Design Basis Document for Containment Spray System
SOP-12,
14
Auxiliary Feedwater System Checklist (Except K-8 Steam
Supply)
Procedures
SOP-3,
18
Engineered Safeguards Administrative Control Verification
Fire Plans
Pre-Fire Plan 1
Control Room, Elevation 625', Room 325 and Various
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Rooms
Pre-Fire Plan 13G
Spent Fuel Pool Heat Exchanger Room, Elevation 590',
Rooms 113, 113A, 114, & 115
Pre-Fire Plan 15
Auxiliary Building, Rooms 2, 16, and 121, Elevation 570' to
664'
Pre-Fire Plan 21
Electrical Equipment Room, Elevation 607'-6"; Room 725
Pre-Fire Plan 22
Turbine Lube Oil Room, Elevation 590', Room 132
Pre-Fire Plan 29,
30, & 31
Mechanical Equipment Rooms, Elevation 629'-2" & 639',
Various Rooms
Pre-Fire Plan 33
Technical Support Center, Elevation 625', Room 320A
Pre-Fire Plan 59
Auxiliary Feedwater Pump P-8D Room, Elevation 590'
Pre-Fire Plans 6
& 8
Diesel Generator 1-2 and Fuel Oil Day Tank Room,
Elevation 590', Rooms 116B & 147
Corrective Action
Documents
Resulting from
Inspection
CR-PLP-2021-
2879
Steam Leak in the 1-2 Diesel Generator Room on
Condensate Return Line in the Overhead
11/09/2021
13055
EA-C-PAL-95-1526-01: Internal Flooding Evaluation for
Plant Areas Outside Containment
29653
EA-C-PAL-95-1526-01: Internal Flooding Evaluation for
Plant Areas Outside Containment
43483
EA-C-PAL-95-1526-01: Internal Flooding Evaluation for
Plant Areas Outside Containment
43604
EA-C-PAL-95-1526-01: Internal Flooding Evaluation for
Plant Areas Outside Containment
43605
EA-C-PAL-95-1526-01: Internal Flooding Evaluation for
Plant Areas Outside Containment
Engineering
Changes
64658
EA-C-PAL-95-1526-01: Internal Flooding Evaluation for
Plant Areas Outside Containment
Miscellaneous
DBD-7.08
Design Basis Document for Plant Protection Against
Flooding
Procedures
Internal Plant Flooding
2-M-001
Control Room Required Cooling Load
Calculations
RT-202 Basis
Palisades Nuclear Plant Technical Specification Surveillance 4/30/2009
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedure Basis Document for RT-202: Control Room
HVAC Heat Removal Capability
Corrective Action
Documents
CR-PLP-2015-
05765
UHS Triennial Inspection (2015) Minor Violation
11/19/2015
Appendix C,
Specification
2447/054-M-
91(Q)
Heat Exchanger Data Sheet
06/01/1983
B, MR
2447/054-M-
91(Q)
Design Specification for Water-Cooled Condensers
DBD-1.06
Design Basis Document for Control Room HVAC System
Fall 2020
Fall Cleaning Intake Structure Inspection:
11/12/2020
Spec M-91
Technical Specification for Condensing Units
Spring 2021
Spring Cleaning Intake Structure Inspection 2021
04/28/2021
SW Bay Fall 2015
Palisades Inspection Report for all Activities August 2015
through November 2015 UCC Project Number -
2-07-203.81
11/30/2015
SW Bay Fall 2018
2018 Mixing Basin 2018 Service Water Bay UCC Project
Number 02-07-203.101
11/17/2018
Miscellaneous
Vendor Manual
M0091-SH-0093
Operation, Maintenance, and Service Manual for
Condensing Units VC-10 & VC-11
DWO-1
Operator's Daily/Weekly Items Modes 1, 2, 3, and 4
2
NRC Generic Letter 89-13 Service Water Program
RO-216
Service Water Flow Verification
SEP-SW-PLP-
001
Raw Water Corrosion Program
SOP 15
Service Water System
Procedures
SOP-24
Ventilation and Air Conditioning System
00393862
P-7A Preservice Test (Vibration Data)
09/12/2020
00397938 01
BS-1319; Bolt That Holds Swing Washer is Broken Off -
MDM
04/14/2016
00443415 01
F-2A; Remove Cover & Inspect Basket Strainer
10/23/2019
Work Orders
51629058
Diver Inspection/Cleaning of Intake Bay (Fall)
2/10/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2774007
Divers to Clean/Inspect Service Water Pump Bay
11/15/2018
2788631
VC-10 Condenser Overhaul PM
04/17/2019
2803545
VC-11, Condenser Overhaul PM
05/09/2019
2834811
RT-202B, VC-10 CR HVAC "B" Train Heat Removal
Capability
08/28/2019
2836067
RT-202A, VC-11 CR HVAC "A" Train Heat Removal
Capability
01/30/2020
2871596
P-7B & P-7C Vibration Data RO-144
09/14/2020
2876336
Diver Inspection/Cleaning of Intake Bay (Spring)
05/04/2020
2896339
RT-202A, VC-11 CR HVAC "A" Train Heat Removal
Capability
08/06/2020
2898372
RT-202B, VC-10 CR HVAC "B" Train Heat Removal
Capability
07/29/2020
PLSEG-LOR-
Emergency Planning Static
Miscellaneous
PLSEG-LOR-
Emergency Operating Procedure 5.0
Procedures
QO-21
Inservice Test Procedure Auxiliary Feedwater Pumps
CR-PLP-2018-
01523
PCP P-50A DC Oil Lift Pump did not Satisfy the Oil Pressure
Interlock
03/27/2018
CR-PLP-2019-
00130
PCS Leak Rates Since Start Up from the Refuel Outage
Have Been Elevated
01/09/2019
CR-PLP-2020-
04494
The Lower Stage of the Seal has a Lowering Trend
11/03/2020
CR-PLP-2021-
00080
Change to the P-50B, Primary Coolant Pump, Middle and
Upper Seal Pressures
01/13/2021
CR-PLP-2021-
2596
NI-6-RM10, Remote Power and VHPT Setpoint Meters, has
Lower than Expected Indication
10/09/2021
CR-PLP-2021-
2605
Primary Coolant Pumps
10/11/2021
CR-PLP-2021-
2642
Received EK-0926 Primary Coolant Pump P-50B Oil Level
Hi-Lo Unexpectedly
10/14/2021
Corrective Action
Documents
CR-PLP-2021-
2644
PY-0102B, B Channel Thermal Margin Monitor
10/14/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-PLP-2021-
2662
The Display Screen for the 'B' Thermal Margin Monitor Went
Black for About 4 Seconds
10/17/2021
CR-PLP-2021-
2671
"B" TMM Screen Briefly Goes Blank and then Displays
Normal
10/18/2021
System Health Report PCS - Primary Coolant System
04/01/2019 -
06/30/2019
System Health Report PCS - Primary Coolant System
04/01/2020 -
06/30/2020
System Health Report PCS - Primary Coolant System
04/01/2021 -
06/30/2021
System Health Report PCS - Primary Coolant System
10/01/2019 -
2/31/2019
System Health Report PCS - Primary Coolant System
10/01/2020 -
2/31/2020
System Health Report RPS - Reactor Protection System
04/01/2019 -
06/30/2019
System Health Report RPS - Reactor Protection System
10/01/2019 -
2/31/2019
System Health Report RPS - Reactor Protection System
04/01/2020 -
06/30/2020
System Health Report RPS - Reactor Protection System
10/01/2020 -
2/31/2020
System Health Report RPS - Reactor Protection System
04/01/2021 -
06/30/2021
Maintenance Rule Performance Indicators Reactor
Protection System
2/08/2021
PLP-RPT-12-
00025,
Maintenance Rule Scoping Document Primary Coolant
System
Miscellaneous
PLP-RPT-12-
00026
Maintenance Rule Scoping Document Reactor Protection
System
Compression Fitting Installation, Disassembly, Inspection
and Reassembly
Procedures
Maintenance Configuration Control
03/26/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MI-43
Reactor Vessel Level Monitoring System Channel Check
03/26/2020
277252-01
P-50D Oil Level Transmitters
11/16/2018
28935-04
LT-0146B P/S Replacement
09/12/2020
Work Orders
541946-02
CV-1911; Ops PMT
2/24/2021
Procedures
On-Line Risk Assessment
565744-06
P-55A; Repair Sticking Poppet Valves (Contingency)
11/03/2021
568221-01
ASM-2B (K-6B); Replace CK-DE401, CK-DE423, RV-1485,
RV-1486
10/04/2021
568221-06
CK-DE401, Test Removed Check Valve
10/04/2021
568221-07
CK-DE421/CK-DE423 Test Removed Valve
10/04/2021
568221-08
RV-1485 Test Removed Valve
10/04/2021
568221-09
RV-1486 Test Removed Valve
10/04/2021
568221-13
RV-1486, Adjust Fuel Oil Relief Valve
10/04/2021
570079-01
P-55A; Adjust Crosshead Bearings
11/03/2021
571166-01
TS-1471 Replacement
11/30/2021
571166-02
TS-1471 Replacement (Prep Work)
11/29/2021
Work Orders
571166-03
TS-1471 Replacement
2/01/2021
CR-PLP-2021-
2433
Service Water Leak Between Mechanical NPT Fitting and
Outlet of MV-SW602
09/21/2021
Corrective Action
Documents
CR-PLP-2021-
03174
CV-1059, Pressurizer Spray Valve from Loop 2A
2/15/2021
M-201
Piping & Instrument Diagram Primary Coolant System
Drawings
VEN-M-107
Stress Isometric Pressurizer Spray
91126
Operability Input for Service Water Leak Near Threaded
Fitting Downstream of MV-SW602
Engineering
Changes
Pressurizer Spray Valve CV-1057 and CV-1059 Revised
Packing Arrangement with Live Load Set
DBD-2.04
Primary Coolant System
DBD-2.11
Pressurizer Pressure Control
Miscellaneous
Implementation
Plan Template
Packing Leakage on Pressurizer Spray Valve, CV-1059
2/02/2021
Corrective Action
CR-PLP-2021-
Inboard Pump Bearing Oil Bubbler for P-52B Component
2/06/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
03087
Cooling Water Pump Nearly Empty
CR-PLP-2021-
2879
Steam Leak in the 1-2 Diesel Generator Room on
Condensate Return Line in the Overhead
11/09/2021
Corrective Action
Documents
Resulting from
Inspection
CR-PLP-2021-
03082
NRC Resident Found a Puddle of Water Surrounding E-924
2/06/2021
Drawings
M-208
Piping & Instrument Diagram Non-Critical Service Water
System
108
Emergent Issue
Update Template
Service Water Supply Line to T-2 Return Line Heat
Exchanger
11/11/2021
Miscellaneous
Failure Modes
and Effects
Worksheet
T-2 Return Line Heat Exchanger / EC-90291
09/20/2021
563541-26
E-924, Condensate Return Heat Exchanger Bypass Hex
10/15/2021
Work Orders
563541-43
E-924; Install New SWS Tie-In D/S of MV-SW939
11/18/2021
Procedures
CVCO-4
Periodic Test Procedure - Charging Pumps
Work Orders
568221-10
ASM-2B (K-6B); Started Outside of Acceptable Start Time of
9.5
10/06/2021
2977575-01
QO-15A-P52A ISI Test Procedure, Component Cooling
Pump
09/16/2021
2978204-01
QO-16C-P54C, ISI Test Containment Spray Pump
09/27/2021
Work Orders
2983287-01
QO-1 Safety Injection Actuation System Test
11/30/2021
EAL Basis
Emergency Action Level Technical Bases
Emergency Planning 10CFR50.54(q) Review Program
Procedures
Palisades Nuclear Plant Site Emergency Plan
Work Orders
2810325 01
RT-85C SFP Ventilation HEPA & Charcoal Testing
08/21/2019
21 Recalibration of The Mirion ABACOS -2000 Fastscan
Counting System at the Entergy - Palisades Power Plant
06/16/2021
21-B2.28-
CALDAT-00645
Model 3030 Scaler Calibration Serial Number 334592
01/27/2021
21-B2.28-
CALDAT-00747
DMC-3000 Calibration Sheet S/N A168801
01/28/2021
21-B2.28-
CALDAT-00920
WR Telepole S/N 6605-002 Calibration Data Sheet
2/05/2021
Calibration
Records
21-B2.28-
RO-20 S/N 1445 Calibration Data Sheet
2/10/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CALDAT-00965
Inst Serial #91-
1134
130 Milli Curie Source Data Sheet
10/08/2020
Inst Serial# 91-
1134
400 Curie Source Data Sheet
10/08/2020
Instrument #
238945
Ludlum Model 3
07/28/2021
Monitor 1803-091
GEM-5 Calibration Data Sheet
06/08/2021
Monitor ID 1712-
184
ARGOS Calibration Data Sheet
07/19/2021
PCM-2 ID#457
PCM-2 Calibration Data Sheet
01/08/2021
SAM12 Serial
Number 202
SAM12 Calibration Data Sheet
2/25/2020
UTC No 17379
RADECO Model HD-29A Certificate of Calibration
2/11/2021
WPC-1050 Serial
Number
11171115
Protean Model WPC-1050 Calibration Coversheet
05/10/2021
Procedures
Operation and Calibration of the ARGOS-5AB Personnel
Contamination Monitor
Self-Assessments LO-PLPLO-2021-
00054
RP Radiation Monitoring Instrumentation Pre-NRC
Self-Assessment
08/12/2021
2907495 01
RR-9B Radwaste Discharge Monitor RIA-1049 Calibration
05/10/2021
Work Orders
2925326 01
RR-84C - Hi Range Noble Gas Effluent Mon RIA-2327 Cal
09/15/2021
Part 37 Security Plan for the Protection of Category 1 and
Category 2 Quantities of Radioactive Material
Training - 10 CFR Part 37 The Physical Protection of
Category 1 and Category 2 Quantities of Radioactive
Material
Miscellaneous
PLLP-RPCT-152-
Procedures
SIP 39
Protection of Category 1 and Category 2 Quantities of
Radioactive Material
Self-Assessments LO-PLPLO-2021-
00031
10CFR Part 37 Transportation, Security Review, and
Self-Assessment
06/02/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2867088 01
Perform Annual Rad Source Inventory
01/15/2020
2916544 01
Perform Annual Rad Source Inventory
01/14/2021
Work Orders
2958379 01
Semiannual Sealed Source Leak Test
07/19/2021
Occupational Exposure Control Effectiveness Performance
Indicator Validation Package
Various
Reactor Coolant System Specific Activity Performance
Indicator Validation Package
Various
RETS/ODCM Radiological Effluent Occurrence Performance
Indicator Validation Package
Various
NRC Performance Indicators Mitigating Systems
Performance Indicator Cooling Water Support
(MS10 CWS-2)
10/01/2020 -
09/30/2021
71151
Miscellaneous
NRC Performance Indicators Mitigating Systems
Performance Indicator Emergency AC Power (EDG)
(MS06)
10/01/2020 -
09/30/2021
CR-PLP-2021-
01984
Received EK-0162, Condensate Pump P-2B High Temp or
Overload, Unexpectedly
07/28/2021
Corrective Action
Documents
CR-PLP-2021-
2180
Emergency Diesel Generator 1-2 Cylinder Liner 7L Cracked
10/15/2021
Apparent Cause Analysis Equipment Issues Over the
Cycle
Miscellaneous
Nuclear Independent Oversight Functional Area
Performance Report June 2021 - September 2021
Preventative Maintenance Program
Preventative Maintenance Program
EN-DC-324-DP
Decommissioning Plant Preventive Maintenance Program
008
Procedures
Work Implementation and Closeout
2436159-06
P-2B; Pump Motor (EMA-2205) Removal
10/10/2018
565778-01
EMA-2205/P-2B; Replace Upper Oil Cooler - E-908B
07/28/2021
565778-02
EMA-2205/P-2B; Stancion Installation/Grating Removal
07/28/2021
565778-04
Bench Test New Bearing Oil Cooler Coil
07/28/2021
565778-05
EMA-2205/P-2B; Instrument Interference Removal
07/28/2021
565778-06
EMA-2205/P2B; Drain Cooler Reservoir
07/28/2021
Work Orders
565778-07
EMA-2205/P2B; Ops PMT
08/11/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
565778-08
EMA-2205/P-2B; Instrument Interference Reinstall
07/29/2021
565778-10
EMA-2205/P-2B; Vibration Measurement
07/29/2021
565778-11
EMA-2205 (P-2B) Perform Megger Testing
07/29/2021