IR 05000255/2022010
| ML22090A254 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/01/2022 |
| From: | Richard Skokowski Engineering Branch 3 |
| To: | Corbin D Entergy Nuclear Operations |
| References | |
| Download: ML22090A254 (13) | |
Text
April 1, 2022
SUBJECT:
PALISADES NUCLEAR PLANT - TRIENNIAL INSPECTION OF EVALUATION OF CHANGES, TESTS AND EXPERIMENTS BASELINE INSPECTION REPORT 05000255/2022010
Dear Mr. Corbin:
On March 4, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant and 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.
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 04/01/22 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: 05000255/2022010 Enterprise Identifier: I-2022-010-0028 Licensee: Entergy Nuclear Operations, Inc.
Facility: Palisades Nuclear Plant Location: Covert, MI Inspection Dates: February 23, 2022 to March 04, 2022 Inspectors: M. Gangewere, Reactor Inspector M. Holmberg, Senior Reactor Inspector G. O'Dwyer, Reactor Engineer A. Shaikh, Senior Reactor Inspector R. Trelka, 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 inspection of evaluation of changes, tests and experiments baseline 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
Type Issue Number Title Report Section Status URI 05000255/2022010-01 Inadequate Evaluation for 71111.17T Open Revised Main Steam Line Break (MSLB) Analysis
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.
REACTOR SAFETY
71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)
The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from November 2019, through November 2021.
- (1) Evaluation 20-0059 R1, Engineering Change (EC) 76688 R1, V-27A/B/C/D Engineering Safeguards Room Ventilation Fans Modify Control Circuit to Resolve CR-PLP-2016-03456
- (2) Evaluation 19-0117, EC 83306, Issue Revised Main Steam Line Break (MSLB)
Analysis
- (3) Evaluation 20-0058 R1, EC 76687 R1, V-24A/B/C/D Emergency Diesel Generator Room Ventilation Fans Modify Control Circuit to resolve CR-PLP-2016-03456
- (4) Evaluation 20-0118 R1, EC 27518 R1, Motor Control Centers (MCCs) 1, 2, 7, & 8 Bucket Replacement
- (5) Evaluation 18-0051 R1, EC 55441, Install High Head Auxiliary Feedwater (AFW)
Pump P-8D & Shed and Cross-Connect Tank T-2 to T-939
- (6) Screening 20-0061, Procedure Change-SOP-28, Fuel Handling System
- (7) Screening 20-0076, EC 82400, Palisades Cycle 28 Reload Core Design Review
- (8) Screening 20-0114, EC 87802, Actual Lake Michigan Elevation Exceeds Design Basis Elevation
- (9) Screening 21-0050, Procedure Change-SOP-27, Spent Fuel Pool
- (10) Screening 21-0074, Procedure Change-EM-04-29, Guidelines for Preparing Fuel Movement Plans
- (11) Screening 21-0089, Procedure Change-SOP-27, Spent Fuel Pool
- (12) Applicability Determination 19-0155, Procedure Change - Offsite Dose Calculation Manual (ODCM)
- (13) Applicability Determination 19-0150, Procedure Change-SEP-ISI-PLP-003, Palisades Inservice Inspection Master Program Fifth Interval, American Society of Mechanical Engineers (ASME) Section XI, Division 1
- (14) Screening 19-0133, COP-22A, Diesel Fuel Oil Sampling Procedure
- (15) Screening 19-0135, SOP-3, Safety Injection and Shutdown Cooling System
- (16) Screening 20-0011, EN-CY-122, Diesel Fuel Oil Program
- (17) Screening 21-0090, EM-04-58, Spent Fuel Pool Metamic Coupon Surveillance Program
- (19) Screening 20-0006, EC-85325, Alternate Item for Cooling Tower Fan Starters
- (20) Applicability Determination 21-0106, EN-DC-330, Fire Protection Program
- (21) Applicability Determination 21-0101, FPSP-MO-1, Fire Suppression Water System Valve Alignment and FPSP-QO-2, Fire Protection Sprinkler System Water Flow Switch Alarm Surveillance Test
- (22) Screening 20-0065, EC 86779 Service Water Pumps P-7C Pump Column Bracket Replacement
- (23) Screening 20-0110, Procedure Change; Emergency Operating Procedure (EOP)
Supplement 12, A S/G SGTR Isolation Checklist EOP Supplement 13, B S/G Steam Generator Tube Rupture (SGTR) Isolation Checklist EOP Supplement 17, A S/G ESDE Isolation Checklist EOP Supplement 18, B S/G ESDE Isolation Checklist
- (25) Screening 21-0012, Procedure Change; Addition of the diesel driven AFW pump (P-8D) to EOP-7, EOP-9, and Abnormal Operating Procedure (AOP) Supplement 14 as an alternate source of steam generator inventory
- (26) Screening 21-0037, Procedure Change; EN-DC-343, Underground Piping and Tanks Inspection and Monitoring Program
- (27) Screening 21-0038, EC 89805, Establish Technical Basis for Entry Conditions to Abnormal Operating Procedure AOP-23, Primary Coolant Leak (and AOP-23 revision)
- (28) Applicability Determination 21-0042, EN-DC-308, Safety and Quality Classification of Replacement Parts
- (29) Applicability Determination 21-0103, RT-204 - Control Room Envelope Integrated Unfiltered In-Leakage Test
INSPECTION RESULTS
Unresolved Item Inadequate Evaluation for Revised Main Steam Line 71111.17T (Open) Break (MSLB) Analysis URI 05000255/2022010-01
Description:
On October 4, 2018, the licensee was notified of a vendor (Framatome) identified deficiency in the Modified Barnett Critical Heat Flux (CHF) Correlation used in the Palisades Main Steam Line Break (MSLB) analysis and documented this condition in CR-PLP-2018-04548.
Specifically, the licensee document that the CHF correlation used in the current Palisades MSLB analysis (Modified Barnett CHF Correlation) may be non-conservative for predicting departure from nucleate boiling (DNB). The Palisades MSLB analysis (Final Safety Analysis Report (FSAR) 14.14) is based on the NRC approved Framatome methodology in EMF-2310.
The NRC Safety Evaluation for EMF-2310 approved the use of several correlations for predicting CHF during MSLB events. Framatome has re-analyzed the MSLB event using approved CHF correlations with adjusted (when appropriate) correlation limits and has shown that DNB does not occur. The licensee corrective actions included an action for tracking the vendor (Framatome) revision of the topical report EMF-2310, and/or submittal to NRC and NRC approval. Additionally, once the vendor provided an updated Safety Analysis Report (UFSAR), the licensee proposed actions included revision to: the Core Operating Limits Report (COLR), FSAR Table 14.1-1 and Section 14.14 to be consistent with updated analysis of record.
On September 6, 2019, in Safety Evaluation (SE) No. 19-0117 the licensee evaluated and accepted a revised MSLB Analysis as implemented by EC-83306 Issue Revised Main Steam Line Break (MSLB) Departure from Nucleate Boiling (DNB)
Analysis.
To support this change, the licensee also implemented changes to Chapter 14 of the UFSAR including Chapter 14.10 Increase in Steam Flow (Excess Load). This UFSAR update (Revision 35)included incorporation by reference the supporting vendor report EMF-2310(P)(A)
Revision 1, SRP Chapter 15 Non-LOCA Methodology for Pressurized Water Reactors, Framatome ANP, May 2004. In SE No. 19-0117, the licensee identified that the MSLB event was analyzed to assess the potential for fuel failure due to a DNB and that a CHF correlation was used in the analysis to obtain the minimum DNB ratio (MDNBR) - the ratio of the heat flux at the predicted core conditions that would result in DNB to the actual heat flux at those conditions. This ratio was verified by the licensee to be above the CHF correlation limit, which includes appropriate uncertainties at an appropriate confidence interval (i.e., 95/95), to ensure the MSLB event does not result in fuel failures due to DNB. The current MSLB Analysis utilized the Modified Barnett CHF correlation to determine the MDNBR (FSAR Section 14.14.2.1) and the associated Modified Barnett DNB Correlation Limit (FSAR Table 14.1-1). The revised MSLB Analysis utilized three CHF correlations (Modified Barnett, Biasi, and HTP) and the associated correlation limits to cover the range of boundary conditions, with a corrected limit used for Modified Barnett that addresses the discovered deficiency (CR-PLP-2018- 04548). The licensee concluded this change did not require prior NRC approval based on evaluation of the eight criteria identified in 10 CFR 50.59. In particular, the licensee determined that this change did not represent a departure from a method of evaluation described in the UFSAR used in establishing the design bases or in the safety analyses. To support this conclusion the licensee stated Framatome developed a new applicable CHF correlation limit in accordance with methods used for other NRC-accepted correlation limits. A new applicable value was needed as a result of evaluating the new test data. The new value is appropriate for the intended application and within the limitations and conditions of use of the safety evaluation for the EMF-2310 methodology. In lieu of a fixed limit, the new Modified Barnett correlation limit varies with pressure to avoid an overly conservative limit but is at all pressures more conservative (higher) than the existing limit. Therefore, the change is a change to a different method of evaluation that is approved by the NRC for the intended application.
The Team identified that the change evaluated in SE No. 19-0117 also represented a change associated with application of the elements (e.g., CHF correlations) within the existing vendor NRC approved topical report methodology (EMF-2310(P)(A) Revision 1) that had been incorporated into the license basis. In particular, based on NRC endorsed guidance in NEI 96-07 Guidelines for 10 CFR 50.59 Implementation, the three CHF correlations that are the subject of this change, are elements of the NRC approved methodology supporting the DNBR methodology (e.g., EMF-2310(P)(A) Revision 1). However, in SE No. 19-0117, the licensee had not identified these CHF correlations as elements of the methodology, nor provided a basis to support the change from applying one to three CHF correlations to confirm this did not represent a change to an element of the methodology, nor if the change to adopt three CHF correlations resulted in an increase in margins to the MDNBR safety limits. The licensee had applied the revised methodology in Table 2.3 Summary of MDNBR and FCM/LHR Results of revision 1 to ANP-3707 Palisades Cycle 27 Safety
Analysis.
Specifically, in Table 2.3, for the 15.1.5 Steam System Piping Failures Inside and Outside Containment, and HZP [Hot Zero Power] with LOOP [Loss of Offsite Power] event, the MDNBR result changed from 1.641 to 3.427 which appeared to represent a gain in margin to the DNBR safety limit. Gaining margin by revising an element of a method of evaluation is considered to be a non-conservative change and thus a departure from a method of evaluation for purposes of 10 CFR 50.59 as discussed in Sections 3.4 and 4.3.8.1 of NEI 96-07. Therefore, the Team determined that SE 19-0117 did not provide an adequate written basis to demonstrate that the change in application of the elements of the license basis DNBR methodology would not represent a departure from the NRC approved methodology (and thus require NRC approval). Failure to document a written evaluation which provides the bases for the determination that the change, from applying one to three CHF correlations did not require a license amendment pursuant to 10 CFR 50.59 (c)(2) is contrary to 10 CFR 50.59 and represented a licensee performance deficiency.
Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process instead of the significance determination process (SDP) because they are considered to be violations that potentially impede or impact the regulatory process. In this case, the Team was not able to evaluate/inform the underlying issue with the SDP process because of the subject matter of this change (e.g., vendor proprietary software and codes to assess changes to CHF correlations) which was not amenable to application of the NRC SDP process.
Therefore, the Team evaluated the significance of this issue in accordance with the NRC traditional enforcement process. Specifically, in accordance with Section 2.1.3 of the NRC Enforcement Manual, violations of 50.59 are minor if there is no reasonable likelihood that the change would ever require NRC approval. In this case, the Team could not make this determination and therefore this issue is an unresolved item until the licensee completes additional written analysis to demonstrate that the change as evaluated within SE 19-0117 did not require NRC prior approval.
Planned Closure Actions: The Team will review the updated SE 19-0117 after the licensee revises this document, to determine if the issue of concern is a more than minor violation of NRC requirements.
Licensee Actions: The licensee determined this issued did not impact operability and entered this concern into the corrective action program and intend to develop a revision to SE No. 19-0117.
Corrective Action References: CR-PLP-2022-00441, Deficiency Identified in 50.59 Evaluation 19-0117.
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public disclosure.
On March 4, 2022, the inspectors presented the triennial inspection of evaluation of changes, tests and experiments baseline inspection results to Darrell Corbin, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.17T Corrective Action CA-33 of WT- Corrective Action Generated to Document LBDCR 20-019 04/20/2020
Documents WTPLP-2020-
00002
CR-PLP-2018- Coupon Removal Activity 03/13/2018
229
CR-PLP-2018- Framatome Identified Deficiency in the Modified Barnett 10/04/2018
04548 Critical Heat Flux Correlation Used in the Palisades Main
Steam Line Break Analysis
CR-PLP-2019- General PAD Quality Issues as Identified in the Past Three 10/01/2019
03933 PAD Self-Assessment that Have the Potential to Lead to
Violation of Licensing or Design Basis Requirements
CR-PLP-2019- Engineering Change 63472, "Revise NAI-1149-024, 10/01/2019
03935 Determination of Direct Shine Doses for Design Basis LOCA
for Palisades, to Accommodate Track Alley West Wall
Modification for DFS" 50.59 Evaluation Did Not Clearly
Document the Software Differences and/or Benchmark Runs
between MicroShield 8.03 and MicroShield 5 for the
Criterion #8 Response
CR-PLP-2019- SE 18-0051 Did Not Evaluate an Additional Manual Operator 12/12/2019
04880 Action
CR-PLP-2020- OSRC Annual Review of Completed PAD Forms for PAD 04/30/2020
01376 2019-0134, EC 83004 Air Operated Valve Calculations
Update
CR-PLP-2021- OSRC Annual Review of Completed PAD Forms for PAD 11/01/2021
2800 2020-0086, EN-OP-125, Fire Brigade Drills
CR-PLP-2021- Impact Reviews for Fire Protection Program 12/02/2021
03060
CR-PLP-2021- A Continuing Theme Was Noted with Overall PAD Quality 12/09/2021
03118 and the Most Common Issue Was PADs that Were Missing
Information
Corrective Action CR-PLP-2022- Deficiency Identified in 50.59 Evaluation 19-0117 03/03/2022
Documents 00441
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from
Inspection
Drawings C-103 SHT 6 Standard MIS
- C. Steel Details Sheet 6, EC-88033 Markup 2
Section K-K
M-11 Sh. 1 Equipment Location Turbine Building Plan of El. 590'-0" 55
M-215 Sh. 1 Piping & Instrument Diagram Plant Heading System 103
M-655 Sh. 1 Piping & Instrument Diagram Radwaste Auxiliary System 78
Engineering 76688 V-27A/B/C/D Engineered Safeguards Rooms Cooler Fans 1
Changes Modify Control Circuit to Resolve CR-PLP-2016-03456
79725 Engineering Input on Deficiency in Modified Barnett Critical 0
Heatflux Correlation Used in the Palisades MSLB Core
Response Analysis (FSAR 14.14)
83306 Issue Revised Main Steam Line Break (MSLB) Departure 0
from Nucleate Boiling (DNB) Analysis
Miscellaneous 18-0051 Safety Evaluation - Engineering Change (EC) 55441, Install 1
High Head AFW Pump P-8D & Shed and Cross-Connect
Tank T-2 to T-939
19-0117 Safety Evaluation - Engineering Change (EC) 83306, Issue 0
Revised MSLB Analysis
19-0133 Screening - COP-22A, Diesel Fuel Oil Sampling Procedure 0
19-0135 Screening - SOP-3, Safety Injection and Shutdown Cooling 0
System
19-0150 Applicability Determination - Procedure Change-SEP-ISI- 0
PLP-003, Palisades Inservice Inspection Master Program
Fifth Interval, ASME Section XI, Division 1
19-0155 Applicability Determination - Procedure Change - Offsite 0
Dose Calculation Manual (ODCM)
20-0006 Screening - EC-85325, Alternate Item for Cooling Tower Fan 0
Starters
20-0011 Screening - EN-CY-122, Diesel Fuel Oil Program 0
20-0058 Safety Evaluation, EC 76687 R1, V-24A/B/C/D Emergency 1
Diesel Generator Room Ventilation Fans Modify Control
Circuit to Resolve CR-PLP-2016-03456
20-0059 Safety Evaluation - Engineering Change (EC) 76688 R1, 1
Inspection Type Designation Description or Title Revision or
Procedure Date
V-27A/B/C/D Engineering Safeguards Room Ventilation
Fans Modify Control Circuit to Resolve CR-PLP-2016-03456
20-0061 Screening - Procedure Change - SOP-28, Fuel Handling 0
System
20-0065 Screening - Engineering Change (EC) 86779 Service Water 0
Pumps P-7C Pump Column Bracket Replacement
20-0076 Screening - Engineering Change (EC) 82400, Palisades 0
Cycle 28 Reload Core Design Review
20-0110 Screening - Procedure Change; EOP Supplement 12, A 0
S/G SGTR Isolation Checklist EOP Supplement 13, B S/G
SGTR Isolation Checklist EOP Supplement 17, A S/G
ESDE Isolation Checklist EOP Supplement 18, B S/G
ESDE Isolation Checklist
20-0114 Screening - Engineering Change (EC) 87802, Actual Lake 0
Michigan Elevation Exceeds Design Basis Elevation
20-0118 Safety Evaluation - Engineering Change (EC) 27518 R1, 1
MCCs 1, 2, 7, & 8 Bucket Replacement
20-0119 Screening - LBD Change; LBDCR 20-019 0
21-0012 Screening - Procedure Change; Addition of the diesel driven 0
AFW Pump (P-8D) to EOP-7, EOP-9, and AOP Supplement
as an Alternate Source of Steam Generator Inventory
21-0037 Screening - Procedure Change; EN-DC-343, Underground 0
Piping and Tanks Inspection and Monitoring Program
21-0038 Screening - Engineering Change (EC) 89805, Establish 0
Technical Basis for Entry Conditions to Abnormal Operating
Procedure AOP-23, Primary Coolant Leak (and AOP-23
Revision)
21-0042 Applicability Determination - EN-DC-308, Safety and Quality 0
Classification of Replacement Parts
21-0050 Screening - Procedure Change - SOP-27, Spent Fuel Pool 0
21-0068 Screening - EC-88033, Alternate Shim Configuration for 0
Regulator Mounting Clamps
21-0074 Screening - Procedure Change - EM-04-29, Guidelines for 0
Preparing Fuel Movement Plans
Inspection Type Designation Description or Title Revision or
Procedure Date
21-0089 Screening - Procedure Change - SOP-27, Spent Fuel Pool 0
21-0090 Screening - EM-04-58, Spent Fuel Pool Metamic Coupon 0
Surveillance Program
21-0093 Applicability Determination - CEP-UPT-0100 Underground 09/21/2021
Piping and Tanks Inspection and Monitoring
21-0101 Applicability Determination - FPSP-MO-1, Fire Suppression 0
Water System Valve Alignment and FPSP-QO-2, Fire
Protection Sprinkler System Water Flow Switch Alarm
Surveillance Test
21-0103 Applicability Determination - RT-204 - Control Room 0
Envelope Integrated Unfiltered In-Leakage Test
21-0106 Applicability Determination - EN-DC-330, Fire Protection 0
Program
ANP-3707 Palisades Cycle 27 Safety Analysis Report 0 and 1
EMF-2310(NP)(A) SRP Chapter 15 Non-LOCA Methodology for Pressurized 1
Water Reactors
LBDCR 19-009 EC-83306 - Issue Revised MSLB Analysis 09/05/2019
PLP-RPT-17- Palisades Cycle 27 Principal Plant Parameters 0
00028
SEP-ISI-PLP-003 Palisades Inservice Inspection Master Program Fifth Interval, 9
ASME Section XI, Division 1
Topic Notes for Topic Notes for EC-88411 Rev 0 Associated with 0
Procedures COP-22A Diesel Fuel Oil Sampling Procedure 38
EM-04-29 Guidelines for Preparing Fuel Movement Plans 22
EM-04-58 Spent Fuel Pool Metamic Coupon Surveillance Program 2
EN-AD-101 NMM Procedure Process 35
EN-DC-308 Safety and Quality Classification of Replacement Parts 5
EN-DC-330 Fire Protection Program 9
EN-DC-343 Underground Piping and Tanks Inspection and Monitoring 13
Program
EN-LI-100 Process Applicability Determination 31
EN-LI-101 10 CFR 50.59 Evaluations 20
RT-204 Control Room Envelope Integrated Unfiltered In-Leakage 4
Inspection Type Designation Description or Title Revision or
Procedure Date
Test
SOP-27 Fuel Pool System 73 and 74
SOP-28 Fuel Handling System 55
11