IR 05000255/2021010

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Triennial Fire Protection Inspection Report 05000255/2021010
ML22041B099
Person / Time
Site: Palisades Entergy icon.png
Issue date: 02/24/2022
From: Richard Skokowski
Engineering Branch 3
To: Corbin D
Entergy Nuclear Operations
References
IR 2021010
Download: ML22041B099 (7)


Text

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, 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

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

Procedure

Type

Designation

Description or Title

Revision or

Date

CR-PLP-2004-

0464

EA-FPS-2001-01 Objectives Not Met w/ Hose Reels 19 &

with Track Alley Sprinkler

08/04/2004

CR-PLP-2004-

0486

EA-FPS-2001-01 Objectives Not Meet with Hose Reels 19

and 20 with Track Alley Sprinklers

08/04/2004

CR-PLP-2019-

230

Create a WR to Perform a Visual Inspection and

Functional Test of Door-1001

10/22/2019

Corrective Action

Documents

LR-LAR-2009-

244 CA 25

Replace or Test Sprinkler Heads

09/15/2009

CR-PLP-2021-

03060

Changes Did Not Have FP Impact Review

2/02/2021

CR-PLP-2021-

03126

PLP-RPT-12-00053 and DBD-7.10 Have Incorrect Nozzle

Manufacturer and Model

2/10/2021

Corrective Action

Documents

Resulting from

Inspection

CR-PLP-2022-

00075

Revise EA-FPS-2001-01 to Reflect the Installed 75 psi

Automatic Nozzles at Hose Reel 19 and 20

01/12/2022

NET-28086-000-

Criticality Safety Analysis for the Palisades Spent Fuel

Pool with Region 2 Empty Cells Credit

Engineering

Evaluations

PAD 20-0047

FPSP-SO-2 Inspection and Testing of Palisades Plant Fire

Doors

Fire Plans

FPF

Pre Fire Plans Manual

DBD 7.10

Design Basis Document for NFPA 805 Fire Protection

Program," Section 3.6.2 "Standpipe and Hose Station

Miscellaneous

FAQ 07-0040

Non-Power Operations Clarifications

EN-DC-127

Control of Hot Work and Ignition Sources

EN-DC-127

Control of Hot Work and Ignition Sources

EN-DC-161

Control of Combustibles

FPIP-4

Fire Protection Systems and Fire Protection Equipment

FPSP-AO-3

Fire Hose Reel/Rack Station Valve Check

Procedures

SOP-27

Fuel Pool System

71111.21N.05

Self-

Assessments

LO-PLPLO-2020-

00073

Pre-NRC Triennial Fire Protection Inspection Focused

Self-Assessment

06/08/2021