IR 05000255/2022002

Integrated Inspection Report 05000255/2022002

ML22214A071
Person / Time
Site:	Palisades
Issue date:	08/03/2022
From:	Eve E NRC/RGN-III/DRP/B2
To:	Mlynarek M Holtec Decommissioning International
References
IR 2022002
Download: ML22214A071 (11)

Text

August 3, 2022

SUBJECT:

PALISADES NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000255/2022002

Dear Mr. Mlynarek:

On June 13, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant. On June 21, 2022, the NRC inspectors discussed the results of this inspection with Mr. Darrell Corbin, Site Vice President, Entergy Nuclear Operations, Inc., 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 Burket, Elise on 08/03/22 Elise C. Eve, 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: 05000255/2022002 Enterprise Identifier: I-2022-002-0051 Licensee: Entergy Nuclear Operations, Inc.1 Facility: Palisades Nuclear Plant Location: Covert, MI Inspection Dates: April 1, 2022 to June 13, 2022 Inspectors: J. Dykert, Acting Senior Resident Inspector R. Edwards, Senior Reactor Inspector J. Mancuso, Acting Senior Resident Inspector C. St. Peters, Resident Inspector Approved By: Elise C. Eve, Acting Chief Branch 2 Division of Reactor Projects 1 License transferred to Holtec Decommissioning International, LLC on June 28, 2022 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

None.

PLANT STATUS

The plant began the inspection period at full power. On May 20, 2022, power operations ceased. All reactor fuel was removed from the reactor vessel and safely stored in the spent fuel pool by June 10, 2022. By letter dated June 13, 2022, Entergy Nuclear Operations, Inc.

submitted a Certification of Permanent Cessation of Power Operations to the NRC certifying that the plant had permanently ceased power operations and that all fuel had been permanently removed (ADAMS Accession No. ML22164A067). Effective June 13, 2022, the NRC notified Entergy Nuclear Operations, Inc. that oversight activities will no longer be conducted in accordance with the Operating Reactor Assessment Program and that oversight activities will be conducted in accordance with the Decommissioning Power Reactor Program (ADAMS Accession No. ML22164A432). On June 28, 2022, Entergy Nuclear Operations, Inc. informed the NRC of the successful purchase and sale transaction closing of the Palisades facilities to Holtec Decommissioning International, LLC (ADAMS Accession No. ML22179A075). On the same day, the NRC issued license amendments transferring the Palisades Nuclear Plant facility license from Entergy Nuclear Operations, Inc. to Holtec Palisades, LLC; and Holtec Decommissioning International, LLC (ADAMS Accession No. ML22173A179).

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, 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 1-2 emergency diesel generator, during routine 1-1 emergency diesel generator surveillance on May 2, 2022

(2) Left train containment spray following routine surveillance on containment spray pump P-54B on May 5, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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 16: component cooling water pump room; elevation 590', 607'-6", & 625' on April 6, 2022

(2) Fire Area 2: cable spreading room; elevation 607' on April 22, 2022

(3) Fire Area 13G: spent fuel pool heat exchanger room, elevation 590' on May 13, 2022

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) Component cooling water pump room on April 1, 2022

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 reactor shutdown on May 20, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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

(1) Emergency diesel generator system on May 4, 2022

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 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) Protected equipment walkdown during elevated shutdown risk on May 31, 2022

(2) Elevated risk due to reduced inventory on June 2, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)

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

(1) Immediate operability determination due to door-142 being declared non-functional on May 15, 2022

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

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

(1) Component cooling water periodic maintenance on April 14, 2022

(2) Ultrasonic flow monitor repair on May 6, 2022

(3) 1-3 emergency diesel generator planned work on May 10, 2022

(4) Diesel driven fire pump post-maintenance test following planned maintenance on May 17, 2022

(5) Bench test following replacement of nuclear instrument, NI-2/4A, NI-1/3A spare drawer on May 26, 2022

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated final shutdown activities from May 20 to June 10, 2022.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (2 Samples)

(1) RO-128, 1-1 emergency diesel generator 24-hour load run on April 4-5, 2022

(2) QO-14A, service water pump P-7A on May 18, 2022

Inservice Testing (IP Section 03.01) (1 Sample)

(1) QO-16B, containment spray inservice test on May 3, 2022

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

(1) Control rod drive mechanism 23 elevated leak rate from May 16 to May 20, 2022

FLEX Testing (IP Section 03.02) (1 Sample)

(1) Annual FLEX Testing on April 21,

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, 2021 through March 31, 2022)

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

(1) Unit 1 (April 1, 2021 through March 31, 2022)

71152A - Annual Follow-Up Problem Identification and Resolution Annual Follow-Up of Selected Issues (Section 03.03)

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

(1) Corrective actions and evaluation of the 1-1 emergency diesel generator 5R fuel line support stud failure as documented in CR-PLP-2022-00283

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

On June 21, 2022, the inspectors presented the integrated inspection results to Mr. Darrell Corbin, Site Vice President, Entergy Nuclear Operations, Inc., and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Procedures SOP-22 Emergency Diesel Generators 85

SOP-3 Safety Injection and Shutdown Cooling System 109

71111.05 Fire Plans Pre-Fire Plan Spent Fuel Pool Heat Exchanger Room; Elevation 590' 6

13G

Pre-Fire Plan 16 Component Cooling Pump Room, Elevation 590', 607'-6", 6

and 625'

Pre-Fire Plan 2 Cable Spreading Room, Elevation 607' -6", Room 224 6

71111.06 Calculations EA-C-PAL-95- Internal Flooding Evaluation for Plant Areas Outside of 4

26-01 Containment

Miscellaneous DBD-7.08 Design Basis Document for Plant Protection Against 6

Flooding

Procedures AOP-39 Internal Plant Flooding 2

MSM-M-16 Inspection of Watertight Barriers 19

71111.11Q Procedures GOP-8 Power Reduction and Plant Shutdown to Mode 2 or 40

Mode 3 = 525°

GOP-9 Mode 3 = 525° to Mode 4 or Mode 5 37

71111.12 Miscellaneous Engineering Maintenance Rule Scoping Document 4

Report PLP-RPT-

2-00026,

System Health Q4-2021, Unit 1, Emergency Diesel Generators 10/01/2020 -

Report 06/30/2021

System Health Q4-2020Unit 1, Emergency Diesel Generators 10/01/2020 -

Report 12/31/2020

System Health Q2-2020, Unit 1, Emergency Diesel Generators 04/01/2020-

Report 06/30/2020

System Health Q2-2021, Unit 1, Emergency Diesel Generators 04/01/2021 -

Report 06/30/2021

71111.13 Procedures GOP-14 Shutdown Cooling Operations 54

71111.15 Corrective Action CR-PLP-2022- Door-142, Entrance to "C" Bus Area, Watertight Door has 05/06/2022

Documents 00838 Small Gap on Lower Right Portion as You Enter "C" Bus

Resulting from Area with the Normal Single Dog Closed

Inspection Type Designation Description or Title Revision or

Procedure Date

Inspection

Procedures 4.02 Control of Equipment 92

FPIP-4 Fire Protection Systems and Fire Protection Equipment 42

71111.19 Procedures QO-15 Inservice Test Procedure - Component Cooling Water 42

Pumps

Work Orders 00572797-01 EC-999; UFM is No Longer Able to Communicate - T/S & 01/25/2022

Repair

00572797-04 EC-999; UFM is No Longer Able to Communicate - T/S & 12/28/2021

Repair

00572797-06 EC-999; UFM is No Longer Able to Communicate - T/S & 04/28/2022

Repair

00573309-02 M-1000; (K-5) OPS-PMT 05/17/2022

00573479 NI-2/4A; Spare Drawer Checkout Cont. Replacement 03/21/2022

00574082-02 K-5; Fuel Leak Beneath Fuel Pump - Severity 2 - PMT 05/17/2022

00576343-01 M-1005; Failed to Run During PMT & CNTRL Shows Volt 03/17/2022

Reg Fault

00576343-02 M-1005; Failed to Run During PMT & CNTRL Shows Volt 03/17/2022

Reg Fault

00576343-03 M-1005; Failed to Run During PMT & CNTRL Shows Volt 03/17/2022

Reg Fault

00576343-04 M-1005; Failed to Run During PMT & CNTRL Shows Volt 03/18/2022

Reg Fault

00576343-07 M-1005; Failed to Run During PMT & CNTRL Shows Volt 03/17/2022

Reg Fault

2975478-02 FPSP-RM-3 for K-5 (P-9B); OPS-PMT 05/17/2022

2986171-01 P-52A Pump Bearing Oil Change 04/06/2022

2986171-02 P-52A, Pump Bearing Oil Change (OP5553) 04/06/2022

2994396-02 QO-15A -P-52A ISI Test Procedure - Component Cooling 03/31/2022

Pump

71111.20 ALARA Plans Work Order 52957914; Disassembly of the Reactor Head / 03/03/2022

(Reset RX Head in Cavity) and Associated Work Activities

(1DF1)

Procedures DWC-2 PCS Radiochemistry Analysis 43

GOP-9 Mode 3 = 525°F tot Mode 4 or Mode 5 37

Inspection Type Designation Description or Title Revision or

Procedure Date

PO-2 PCS Pressure and Temperature Data 7

Work Orders 52957464 RIA-2316/17 Fuel Handling Monitor Adjustments 03/24/2022

568781-01 PCS Hot Leg Level LT-0106 Calibration 03/24/2022

71111.22 Engineering 92896 Document Acceptability of Leaving Pipe Cooling Tool for

Changes CRDM Leak-Off Line in Containment While at Power

Procedures RO-128-1 Diesel Generator 1-1 24 Hour Load Run 28

Work Orders 5296254-01 FLEX Standby PM: P-990 One Year Operational Test (FSB 04/19/2022

B)

296362-01 FLEX Standby PM: K-1-FLEX One Year Operational Test 04/19/2022

(FSB A)

296368-01 FLEX Standby PM: K-2-FLEX One Year Operational Test 04/19/2022

(FSB B)

2968248-01 FLEX Standby PM: P-1003 One Year Operational Test (FSB 04/19/2022

A)

578663-01 MV-CC195, CRDM Leak-Off Isolation Valve Set-Up and 04/03/2022

Operate Pipe Qwik-Freeze Tool

71151 Miscellaneous NRC Performance Indicators - Safety System Functional 04/01/2021 -

Failures 03/31/2022

NRC Performance Indicators - Unplanned Power Changes 04/01/2021 -

per 7000 Critical Hours 03/31/2022

71152A Corrective Action CR-PLP-2022- After K-6A, Emergency Diesel Generator 1-1 was Secured 02/07/2022

Documents 00283 Following a MO-7A-1 Diesel Run, NPOs Found Sheared

Stud on the Ground

Miscellaneous Apparent Cause EDG 1-1 High Pressure Fuel Tube Stud Failure 03/10/2022

Analysis for CR-

PLP-2022-00283

Vendor Manual Alco Instruction Manual 97

9