IR 05000255/2021010

Triennial Fire Protection Inspection Report 05000255/2021010

ML22041B099
Person / Time
Site:	Palisades
Issue date:	02/24/2022
From:	Richard Skokowski Engineering Branch 3
To:	Corbin D Entergy Nuclear Operations
References
IR 2021010
Download: ML22041B099 (7)

Text

February 24, 2022

SUBJECT:

PALISADES NUCLEAR PLANT - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000255/2021010

Dear Mr. Corbin:

On January 18, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant and discussed the results of this inspection with Mr. D. Lucy, General Manager, Plant Operations 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, Signed by Skokowski, Richard on 02/24/22 Richard A. Skokowski, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 05000255 License No. DPR-20

Enclosure:

As stated

Inspection Report

Docket Number: 05000255 License Number: DPR-20 Report Number: 05000255/2021010 Enterprise Identifier: I-2021-010-0058 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Inspection Dates: November 29, 2021 to December 10, 2021 Inspectors: J. Benjamin, Senior Reactor Inspector A. Dahbur, Senior Reactor Inspector J. Gilliam, Senior Reactor Inspector Approved By: Richard A. Skokowski, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection 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

None.

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 completed a reduced inspection at Palisades Nuclear Plant which focused on a sample of programs, systems, and components the site will rely on after their decommissioning. 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), inspectors were directed to begin telework. In addition, 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.

REACTOR SAFETY

71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)

The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).

(1) Spent Fuel Pool Makeup and Cooling Capabilities

(2) Aging Management Commitment for Fire Protection Sprinklers

Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)

The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.

(1) Combustible Control Program

Fire Protection Program Changes/Modifications (IP Section 03.03) (1 Sample)

The inspectors verified the following:

a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.

b. The adequacy of the design modification, if applicable.

c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.

d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.

e. Post-fire SSD operating procedures, such as abnormal operating procedures, affected by the modification were updated.

(1) Fire Protection Program Change to DBD 7.10 "Design Basis Document for NFPA 805 Fire Protection Program," Section 3.6.2 "Standpipe and Hose Station"

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

On January 18, 2022, the inspectors presented the triennial fire protection inspection results to Mr. D. Lucy, General Manager, Plant Operations and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.05 Corrective Action CR-PLP-2004- EA-FPS-2001-01 Objectives Not Met w/ Hose Reels 19 & 08/04/2004

Documents 0464 20 with Track Alley Sprinkler

CR-PLP-2004- EA-FPS-2001-01 Objectives Not Meet with Hose Reels 19 08/04/2004

0486 and 20 with Track Alley Sprinklers

CR-PLP-2019- Create a WR to Perform a Visual Inspection and 10/22/2019

230 Functional Test of Door-1001

LR-LAR-2009- Replace or Test Sprinkler Heads 09/15/2009

244 CA 25

Corrective Action CR-PLP-2021- Changes Did Not Have FP Impact Review 12/02/2021

Documents 03060

Resulting from CR-PLP-2021- PLP-RPT-12-00053 and DBD-7.10 Have Incorrect Nozzle 12/10/2021

Inspection 03126 Manufacturer and Model

CR-PLP-2022- Revise EA-FPS-2001-01 to Reflect the Installed 75 psi 01/12/2022

00075 Automatic Nozzles at Hose Reel 19 and 20

Engineering NET-28086-000- Criticality Safety Analysis for the Palisades Spent Fuel 0

Evaluations 01 Pool with Region 2 Empty Cells Credit

PAD 20-0047 FPSP-SO-2 Inspection and Testing of Palisades Plant Fire 0

Doors

Fire Plans FPF Pre Fire Plans Manual 6

Miscellaneous DBD 7.10 Design Basis Document for NFPA 805 Fire Protection 4

Program," Section 3.6.2 "Standpipe and Hose Station

FAQ 07-0040 Non-Power Operations Clarifications 5

Procedures EN-DC-127 Control of Hot Work and Ignition Sources 21

EN-DC-127 Control of Hot Work and Ignition Sources 21

EN-DC-161 Control of Combustibles 24

FPIP-4 Fire Protection Systems and Fire Protection Equipment 41

FPSP-AO-3 Fire Hose Reel/Rack Station Valve Check 8

SOP-27 Fuel Pool System 75

Self- LO-PLPLO-2020- Pre- NRC Triennial Fire Protection Inspection Focused 06/08/2021

Assessments 00073 Self-Assessment

5