IR 05000255/2011010
| ML111320363 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/13/2011 |
| From: | Jack Giessner Reactor Projects Region 3 Branch 4 |
| To: | Kirwin T Entergy Nuclear Operations |
| References | |
| TI 2515/183 IR-11-010 | |
| Download: ML111320363 (22) | |
Text
May 13, 2011
SUBJECT:
PALISADES NUCLEAR PLANT - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000255/2011010
Dear Mr. Kirwin:
On April 29, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant, using Temporary Instruction 2515/183, Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event. The enclosed inspection report documents the inspection results which were discussed on May 5, 2011, with yourself and members of your staff.
The objective of this inspection was to promptly assess the capabilities of Palisades Nuclear Plant to respond to extraordinary consequences similar to those that have recently occurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, along with the results from this inspection performed at other operating commercial nuclear plants in the United States will be used to evaluate the U. S. nuclear industrys readiness to safely respond to similar events. These results will also help the NRC to determine if additional regulatory actions are warranted.
All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
John B. Giessner, Chief Branch 4 Division of Reactor Projects Docket Nos. 50-255 License Nos. DPR-20
Enclosure:
Inspection Report 05000255/2011010
REGION III==
Docket No: 50-255 License No: DPR-20 Report No: 05000255/2011010 Licensee: Entergy Nuclear Operations, Inc.
Facility: Palisades Nuclear Plant Location: Covert, MI Dates: March 23, 2011, through April 29, 2011 Inspectors: J. Ellegood, Senior Resident Inspector T. Taylor, Resident Inspector Approved by: John B. Giessner, Chief Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000255/2011010, 03/23/2011 - 04/29/2011; Palisades Nuclear Plant Temporary
Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event This report covers an announced Temporary Instruction inspection. The inspection was conducted by Resident and Region III inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
INSPECTION SCOPE
The intent of the TI is to provide a broad overview of the industrys preparedness for events that may exceed the current design basis for a plant. The focus of the TI was on
- (1) assessing the licensees capability to mitigate consequences from large fires or explosions on site,
- (2) assessing the licensees capability to mitigate station blackout (SBO) conditions,
- (3) assessing the licensees capability to mitigate internal and external flooding events accounted for by the stations design, and
- (4) assessing the thoroughness of the licensees walk downs and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. If necessary, a more specific follow-up inspection will be performed at a later date.
INSPECTION RESULTS
All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report.
03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines (SAMGs) and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Use Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), Section 02.03 and 03.03 as a guideline. If IP 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool (SFP). The inspection should include, but not be limited to, an assessment of any licensee actions to:
Licensee Action Describe what the licensee did to test or inspect equipment.
a. Verify through test or inspection Licensee actions included the identification of equipment (active and passive) utilized for that equipment is available and implementation of B.5.b actions and any additional equipment used in Severe Accident functional. Active equipment Management Guidelines (SAMGs). The licensee credited ongoing programs where shall be tested and passive permanently installed equipment is part of the mitigating strategy. These programs include equipment shall be walked down the limiting condition for operation (LCO) board, for safety-related equipment, and the and inspected. It is not Operations aggregate list for nonsafety-related equipment. For equipment not permanently expected that permanently installed, the licensee performed walkdowns, tested or verified recent operation of the installed equipment that is equipment. Non-installed active equipment within the scope defined above that did not tested under an existing have recent test results was tested. Non-installed passive equipment within the scope was regulatory testing program be walked down and inspected.
retested.
Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, reviewed test results, discussed actions, reviewed records, etc.).
This review should be done for a The inspectors reviewed the licensees consolidated response. In addition, the inspectors reasonable sample of mitigating performed a walkdown/inventory of equipment stored in the licensees B.5.b building and an strategies/equipment.
in-plant location. The inspectors discussed the operation of the equipment with licensee personnel responsible for maintaining the equipment. The inspectors observed the start of a generator-operated light and a portable generator. The inspectors performed a walkdown and checked calibration of radiation meters available outside of the protected area.
As part of the inspection, the inspectors noted that the licensee had obtained an air compressor for recharging air bottles. The inspectors noted that the compressor could be used as an air source for small pneumatic plant loads.
The inspectors identified a discrepancy with equipment needed for emergency cooling of the SFP. One required fitting was missing that was discovered while preparing for a walk thru of the procedure for the NRC. Other mitigating strategies exist for cooling the SFP in addition to the one strategy that requires the missing fitting. The licensee wrote a condition report (CR) to address the issue and obtained the missing coupling. The inspectors are determining the significance of this issue.
The inspectors reviewed the results of the triennial fire protection inspection documented in report 05000255/2010-008. No findings of significance were identified. The triennial team reviewed the following strategies:
NEI 06-12, Licensee Strategy (Table) Selected for Revision 2, Section Review 3.2.2 On-Site and Off-Site Communications Evaluated (Table A.3-1)3.2.3 Notifications/ERO Activation (Table A.3-1) Evaluated 3.2.4 Initial Operational Response Actions Evaluated (Table A.3-1)3.2.5 Initial Damage Assessment (Table A.3-1) Evaluated 3.3.7 PWR Enhancement Strategy No.7 - Portable Evaluated Sprays (Table A.4-7)
Discuss general results including corrective actions by licensee.
The licensee identified several enhancements which have been added to condition reports.
The licensee identified the following discrepancies:
- Some consumables useful to plugging a hole in the SPF were not in stock. The licensee determined that sufficient material was available to plug a breech.
- Caterpillar gensets, an offsite resource, were not available. This equipment is redundant to other B.5.b equipment and the licensee will delete the item.
- One section of hose for B.5.b response was missing. The staged B.5.b equipment trailer contained 29 hoses; 20 are needed with 10 additional lengths of hose as part of the normal inventory. The licensee initiated actions to obtain another length of hose.
- Two cell phones were missing from the Emergency Operations Facility (EOF). The licensee replaced the phones.
Describe the licensees actions to verify that procedures are in place and can be Licensee Action executed (e.g. walkdowns, demonstrations, tests, etc.)
b. Verify through walkdowns or The licensee developed a matrix that listed applicable procedures. For most procedures, demonstration that procedures to the licensee performed a review. In some cases, the licensee also performed a walkdown implement the strategies associate of the procedure. The walkdowns were performed primarily for procedures that are not with B.5.b and 10 CFR 50.54(hh) a specific to B.5.b/SAMGs.
in place and are executable.
Describe inspector actions and the sample strategies reviewed. Assess whether Licensees may choose not to procedures were in place and could be used as intended.
connect or operate permanently installed equipment during this The inspectors reviewed the licensees results. The inspectors observed some walkdowns verification.
to verify adequacy of the procedures and equipment. The inspectors reviewed portions of three procedures specific to B.5.b/SAMGs. These procedures were:
This review should be done for a - Emergency Management Guidelines reasonable sample of mitigating - Alternate resources document strategies/equipment.
- PCSO-5, Alternate Source for Charging to PCS The inspectors discussed the emergency management guidelines and alternate resources document with Operations.
The inspectors concluded that the procedures, with one exception, were in place and could be used as intended. The exception relates to PCSO-5, the procedure for emergency SFP cooling. As previously identified, an additional fitting was needed to hook the hoses to the water source. The licensee wrote a condition report (CR) to address the issue and obtained the missing coupling.
Discuss general results including corrective actions by licensee.
The licensee identified several enhancements to procedures. In some cases, the enhancements address conditions that have changed since the procedures were first developed. For example, one procedure directed responders to the Emergency Operations Facility (EOF) to muster in the manner (Sic) house. The manor house is associated with the old EOF. The licensee initiated procedure changes. The inspector concluded that the discrepancies did not impact the licensees ability to perform the mitigating strategies.
Describe the licensees actions and conclusions regarding training and qualifications Licensee Action of operators and support staff.
c. Verify the training and The licensee verified that all emergency response organization (ERO) and fire brigade qualifications of operators and personnel were in the Learning Management System (LMS) and current on training.
the support staff needed to Describe inspector actions and the sample strategies reviewed to assess training and implement the procedures and qualifications of operators and support staff.
work instructions are current for The inspectors reviewed print outs of LMS qualifications to verify that training was current activities related to Security for personnel. The inspectors also reviewed initial and requalification lesson plans for ERO Order Section B.5.b and severe members. ERO members are tested each year on Emergency Management Guidelines.
accident management Prior to the test, members have the option to complete computer based training on the guidelines as required by Emergency Management Guidelines.
10 CFR 50.54 (hh).
For fire brigade members, the inspectors discussed training content and frequency with personnel responsible for fire brigade training. The trainers stated that use of the B.5.b pump is demonstrated on a routine basis as part of fire brigade training. The inspectors reviewed the training reports for the third quarters of 2009 and 2010 that identified B.5.b related training. The inspectors observed a fire brigade member walkthrough a procedure for emergency cooling to the SFP.
The inspectors identified through discussion that the electricians had not received training on the use of a small portable generator. However, the procedures and job aides showed the installation. Based on the general skill set of the electricians, the inspectors concluded that the generator could be used.
The inspectors did not identify any training issues that would prevent implementation of procedures Discuss general results including corrective actions by licensee.
The licensee did not identify any training issues.
Describe the licensees actions and conclusions regarding applicable agreements Licensee Action and contracts are in place.
d. Verify that any applicable The licensee contacted local fire departments and verified current contact information.
agreements and contracts are in For a sample of mitigating strategies involving contracts or agreements with offsite place and are capable of entities, describe inspector actions to confirm agreements and contracts are in place meeting the conditions needed and current (e.g., confirm that offsite fire assistance agreement is in place and current).
to mitigate the consequences of The inspectors reviewed memoranda of understanding with local fire departments. In these events.
addition the inspectors reviewed existing contracts for private organizations identified as sources for equipment and supplies. The inspectors noted that the contracts may need This review should be done for a modification during an event to obtain desired equipment and supplies. In addition, the reasonable sample of mitigating licensee included several suppliers that do not have contracts in place. The inspectors strategies/equipment.
reviewed the memorandum of understanding between Palisades and D.C. Cook.
Discuss general results including corrective actions by licensee.
No issues were identified. The inspectors concluded that the licensee had adequate contracts in place.
Document the corrective action report number and briefly summarize problems noted Licensee Action by the licensee that have significant potential to prevent the success of any existing mitigating strategy.
e. Review any open corrective The licensee did not identify any issues that could have a significant impact on the success action documents to assess on the mitigating strategy. The inspectors reviewed open CRs for potential impacts that problems with mitigating were not already discussed in Sections 03.01a through d above. No additional major strategy implementation impacts were noted.
identified by the licensee.
Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.
03.02 Assess the licensees capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, Loss of All Alternating Current Power, and station design, is functional and valid. Refer to TI 2515/120, Inspection of Implementation of Station Blackout Rule Multi-Plant Action Item A-22 as a guideline. It is not intended that TI 2515/120 be completely reinspected. The inspection should include, but not be limited to, an assessment of any licensee actions to:
Describe the licensees actions to verify the adequacy of equipment needed to Licensee Action mitigate an SBO event.
a. Verify through walkdowns and The licensee verified that equipment relied upon for mitigating an SBO was available and inspection that all required appropriately staged. The licensee reviewed procedures that would be utilized in an SBO materials are adequate and and did field walkdowns of equipment utilized in the procedures to validate it was available.
properly staged, tested, and Additionally, the licensee did a walkdown of spare safety-related motors in the warehouse.
maintained.
Describe inspector actions to verify equipment is available and useable.
The inspectors walked down temporary equipment staged to provide fuel to a backup generator on-site to ensure the procedure could be performed and that necessary parts were available. The inspectors also reviewed surveillance and corrective action records to validate that there were no issues impacting the functionality of a backup emergency generator. Additionally, manual actions for control of auxiliary feedwater during SBO were reviewed and the parts necessary for that evolution were verified in-place and ready to use.
The inspectors also walked down a small gasoline generator that would connect to a safety-related panel to provide minimum safe shutdown capability in an SBO, watched it operate, and validated the necessary electrical connections were available and that the associated procedure could be implemented. Overall, based on their review, the inspectors determined there were no significant issues with the licensees mitigating strategy for SBO.
Discuss general results including corrective actions by licensee.
The licensees review of this attribute revealed no significant issues and concluded the capability to mitigate SBO and station design were functional and valid. The licensee did identify potential enhancements to a procedure that installs spare safety-related motors from the warehouse. As a result of additional walk-downs with the NRC, the licensee identified a potential enhancement with regard to a tagout needed in an off-normal procedure during an SBO. Specifically, while the tagout referenced in the procedure is pre-generated in the electronic tagging system, during a SBO or other possible events that system may not be available. Additionally, there may be other procedures where this is the case. The licensee initiated a document revision notice to consider creating a non-electronic backup for tagouts referenced in emergency and off-normal procedures.
Licensee Action Describe the licensees actions to verify the capability to mitigate an SBO event.
b. Demonstrate through The licensee reviewed procedures that would be utilized in an SBO event and verified that walkdowns that procedures for they were executable. This review included a walkdown of equipment required in the response to an SBO are procedures, as described above.
executable.
Describe inspector actions to assess whether procedures were in place and could be used as intended.
The inspectors reviewed commitments in SBO-related Safety Evaluation Reports and reviewed a sample of tests and procedures to verify the commitments were properly accounted for. An off-normal procedure for an electrical lineup to provide power to pressurizer heaters was also reviewed. The inspectors also reviewed the procedure to connect a small gasoline generator to a safety-related panel in the plant. Additionally, the inspectors reviewed the procedure for obtaining spare safety-related motors from the warehouse and the general emergency operating procedure for SBO events. Overall, based on their review, the inspectors determined there were no significant issues with the licensees mitigating strategy for SBO.
Discuss general results including corrective actions by licensee.
The licensees review of this attribute revealed no significant issues and concluded the capability to mitigate an SBO was functional and valid. The licensee identified possible enhancements to the gasoline generator connection procedure which would provide more clarity. During a walk down of the gasoline generator with the NRC, an additional enhancement was identified to include pictures of the connections for further clarity. The inspectors reviewed preventative maintenance procedures for the spare motors in storage as well. As a result of the inspectors observations, the licensee is considering an enhancement to a work order which would further clarify acceptable oil levels in the spare motors.
03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design. Refer to IP 71111.01, Adverse Weather Protection, Section 02.04, Evaluate Readiness to Cope with External Flooding as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.
Describe the licensees actions to verify the capability to mitigate existing design Licensee Action basis flooding events.
a. Verify through walkdowns and The licensee reviewed existing design and licensing basis documentation regarding inspection that all required protection against flooding events to include Individual Plant Examination of External Events materials are adequate and (IPEEE) reviews, the Final Safety Analysis Report (FSAR), off-normal and emergency properly staged, tested, and procedures, and design basis documents. As a result, the licensee identified both maintained.
permanent and non-permanent plant features, materials, and equipment used to respond to flooding. Walk downs were performed and preventative maintenance records were reviewed to validate the functionality of the equipment. Additionally, the licensee reviewed a number of condition reports previously written against flood mitigation features or equipment for functionality concerns.
Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.
The inspectors walked-down various safety-related areas to inspect flood mitigation features such as level switches, sump pumps, drain paths, and watertight barriers. Additionally, the inspectors reviewed flooding analyses that had been performed for safety-related plant areas and checked to see if assumptions were still valid during plant walk-downs. The inspectors also reviewed condition reports and preventative maintenance activities dealing with flood mitigation features to ensure there were no functionality issues and that the maintenance was being performed at the designated intervals. Overall, based on their review, the inspectors determined there were no significant issues with the licensees mitigating strategy for flooding.
Discuss general results including corrective actions by licensee.
The licensees review of this attribute concluded that all necessary equipment and features per the design and licensing bases were functional and appropriately staged. The licensee identified that a non-credited, gasoline-powered sump pump that could be used to mitigate flooding was located below the design flood level. As an enhancement, the licensee initiated a condition report to evaluate relocating the pump. NRC review revealed that in 2008, a condition report was written documenting an NRC-identified issue regarding the capacity of the floor drains in the safety-related 1-D switchgear and adjoining cable spreading room. Operators had been noting that they had to reduce flow to less-than approximately 20 gpm when performing a maintenance activity to flush fire piping and test the floor drains. Resolution of the issue at the time included generation of a work order to clean the drain piping. As of this review in 2011, the work order had not been completed.
After discussion with the licensee, the work order has been returned to planning and is being scheduled for completion. For some time, the licensee has maintained a door from the 1-D room to another room open for other concerns. With this larger effective floor area, the licensee determined that for the design flooding scenario, the analyses are not challenged. However, the licensee is evaluating if further control is needed over the door given the potential impact on flooding in the 1-D room.
03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use IP 71111.21, Component Design Basis Inspection, Appendix 3, Component Walkdown Considerations, as a guideline to assess the thoroughness of the licensees walkdowns and inspections.
Describe the licensees actions to assess the potential impact of seismic events on Licensee Action the availability of equipment used in fire and flooding mitigation strategies.
a. Verify through walkdowns that The licensee identified equipment utilized/required for mitigation of fire and flood events.
all required materials are The licensee also reviewed the results of the walk-downs conducted in the 1990s to adequate and properly staged, address Unresolved Safety Issue (USI) A-46, Seismic Qualification Utility Group (SQUG), in tested, and maintained.
which the plant sought to validate the adequacy of mechanical and electrical equipment against seismic criteria not in use when the plant was originally licensed. This included non-safety-related equipment such as fire and flood mitigation features. Additionally, walk-downs were performed of major equipment used to mitigate fires and flooding.
Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.
The inspectors conducted walk-downs of important structures, systems and components (SSCs) needed to mitigate fire and flood events to identify the potential that the SSCs function could be lost during a seismic event. This included installed fire protection equipment, flood barriers, and major B.5.b equipment. Additionally, the inspectors reviewed the context of USI A-46 (SQUG) and the conclusions drawn by the licensee from the review of that issue. Overall, based on their review, the inspectors determined there were no significant issues with the licensees mitigating strategies.
Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.
Seismically qualified SSCs normally consist of safety-related equipment that has been formally qualified to function during and after a design basis earthquake. The licensees reviews for this issue determined that nonsafety-related SSCs, in general, were not considered to be formally qualified to safety-related seismic standards. However, in resolving USI A-46 (SQUG) in the 1990s, experts reviewed the seismic ruggedness of nonsafety-related piping, cable trays, and other equipment throughout the plant as part of that effort. This included fire and flood mitigation piping and other features. The conclusion of analysis was that there were no seismic vulnerabilities and that piping systems were well supported. Additionally, for flood mitigation barriers, flooding loads were determined to bound seismic loads, maintaining the functionality of those barriers during seismic events.
Sump pumps and level switches not seismically rugged were determined to not be needed for flood mitigation. The licensee did identify a potential enhancement to provide more detailed direction in fire procedures for the use of alternate water sources given the primary source for a fire zone was disabled. Additionally, equipment staged to respond to B.5.b events was not stowed in seismically qualified buildings and locations, as a seismic event and B.5.b event have never been assumed to occur concurrently. Finally, the licensee is considering removing some heaters in the turbine building that might fall during a seismic event and impact hose stations below. In sum, the licensee determined present measures and design are sufficient with no need for new mitigating strategies.
Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. T. Kirwin and other members of licensee management at the conclusion of the inspection on May 5, 2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. White, Operations
D. Campbell
K. Simpson
M Sicard
G. Sleeper
T. Horan
L. Gilbert
Nuclear Regulatory Commission
R. Langstaff
Enclosure