IR 05000255/2014007

IR 05000255-14-007; 05/05/2014-06/11/2014; Palisades Nuclear Plant; Problem Identification and Resolution

ML14171A394
Person / Time
Site:	Palisades
Issue date:	06/20/2014
From:	Eric Duncan Region 3 Branch 3
To:	Vitale A Entergy Nuclear Operations
References
IR-14-007
Download: ML14171A394 (37)

Text

UNITED STATES une 20, 2014

SUBJECT:

PALISADES NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000255/2014007

Dear Mr. Vitale:

On June 11, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution Inspection at your Palisades Nuclear Plant. The enclosed inspection report documents the inspection results, which were discussed at an interim exit meeting on May 23, 2014, and a final exit meeting on June 11, 2014, with you and other members of your staff.

The inspection examined activities conducted under your license as they related to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

On the basis of the samples selected for review, the inspectors concluded that the Corrective Action Program at Palisades Nuclear Plant was adequate in the areas of identifying, evaluating and correcting issues with some identified opportunities for improvement. There was a low threshold for identifying issues and entering them into the Corrective Action Program. The significance of the issues was screened using risk insights and the significance drove the prioritization of issue evaluation and resolution. Evaluations were adequate, overall, in determining the underlying cause of the issues and corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was evaluated and entered into the Corrective Action Program, if applicable. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments, audits, and effectiveness reviews were found to be conducted at a sufficient depth for all departments. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. Based on the results of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment (SCWE) at Palisades Nuclear Plant with the exception of the Security Department.

Licensee staff was aware of and generally familiar with the Corrective Action Program and other station processes, including the Employee Concerns Program, through which concerns could be raised. The staff was also comfortable raising concerns without fear of retaliation. As discussed in NRC Inspection Report 05000255/2014009, dated March 6, 2014, the NRC performed a limited scope Problem Identification and Resolution inspection that identified a chilled work environment within the Security Department. In particular, the NRC concluded that staff within the Security Department perceived that: (1) recent actions to terminate the employment of two supervisors was in retaliation for their raised concerns; (2) the Corrective Action Program was ineffective at addressing equipment and other concerns raised by the Security staff; (3) Security management was unresponsive to employees concerns; and (4) the Employee Concerns Program could not be relied upon to maintain employee confidentiality.

In response to our identification of a chilled work environment within the Security Department, you developed the Palisades Security SCWE Action Plan and the NRC planned to review the effectiveness of actions taken to implement the Action Plan.

During this inspection, we reviewed your implementation of the Palisades Security SCWE Action Plan and verified that, to date, you have completed all of the actions as committed to in the Action Plan. However, we concluded that the quality of the actions implemented have been insufficient to assess and understand the cause of the chilled work environment within the Security Department and did not demonstrate a strong commitment to effectively improve the safety conscious work environment in the Security Department. Specifically, significant gaps were found to exist in the security officers knowledge of the actions being taken to address the chilled safety conscious work environment and managements commitment to improving the overall safety conscious work environment.

For example, security officers had a limited recollection of any discussion of the results of the NRCs limited scope Problem Identification and Resolution inspection, and security officers stated that they were not informed of the sites development and implementation of a Security SCWE Action Plan or the specific actions required by the Action Plan. Also, the security officers were unaware of the establishment of the sites Security Ombudsman Program as directed in the Action Plan; the intent of the program; or their shift representatives for the Program, despite the selection and assignment of personnel to these positions at the end of March 2014. Lastly, the security officers were unaware of a significant organizational change that added the Regulatory and Performance Improvement Director to the Security Department chain of command.

Therefore, we are requesting that you provide a response to us, within 30 days of your receipt of this letter, that outlines actions that you have taken or plan to take to further enhance your Palisades Security SCWE Action Plan to improve the safety conscious work environment in the Security Department at Palisades. The NRC will continue to closely monitor Security Department safety conscious work environment and any supplemental actions that you may choose to take with a follow-up inspection.

We plan to discuss with you the results of our safety conscious work environment inspections during the upcoming End-of-Cycle assessment public meeting. The NRC requests that you be prepared to discuss: (1) the root cause of the chilled work environment within the Security Department; (2) your progress in addressing the safety conscious work environment concerns within the Security Department; and (3) any additional actions planned and/or implemented to address the safety conscious work environment at Palisades, including actions as a result of our observations during this Problem Identification and Resolution inspection. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eric Duncan, Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report No. 05000255/2014007 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-255 License No: DPR-20 Report No: 05000255/2014007 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Dates: May 5, 2014, through June 11, 2014 Team Leader: R. Ng, Project Engineer Inspectors: A. Scarbeary, Resident Inspector C. Zoia, License Examiner E. Sanchez-Santiago, Reactor Inspector G. Hansen, Physical Security Inspector Approved by: E. Duncan, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000255/2014007; 05/05/2014 - 06/11/2014; Palisades Nuclear Plant;

Problem Identification and Resolution.

This inspection was performed by four region-based inspectors and the Palisades Resident Inspector. 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.

Problem Identification and Resolution On the basis of the samples selected for review, the inspectors concluded that the Corrective Action Program at Palisades Nuclear Plant was adequate in the areas of identifying, evaluating and correcting issues with some identified opportunities for improvement. The licensee had a low threshold for identifying issues and entering them into the Corrective Action Program. The significance of the issues was screened using risk insights and the significance drove the prioritization of issue evaluation and resolution. Evaluations were adequate, overall, in determining the underlying cause of the issues and corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was evaluated and entered into the Corrective Action Program, if applicable. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments, audits, and effectiveness reviews were found to be conducted at a sufficient depth for all departments. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. Based on the results of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment (SCWE) at Palisades Nuclear Plant with the exception of the Security Department.

Licensee staff was aware of and generally familiar with the Corrective Action Program and other station processes, including the Employee Concerns Program, through which concerns could be raised. The staff was also comfortable raising concerns without fear of retaliation.

Although implementation of the Corrective Action Program was determined to be adequate, the inspectors identified several issues that were either minor in nature and/or represented a potential weakness in the program.

The inspectors concluded that, to date, the site had completed all the actions as committed to in the Security SCWE Action Plan. However, the inspectors concluded that the quality of the actions implemented have been insufficient to assess and understand the cause of the chilled work environment within the Security Department and did not demonstrate a strong commitment to effectively improve the safety conscious work environment in the Security Department.

Specifically, significant gaps were found to exist in the security officers knowledge of the actions being taken to address the chilled safety conscious work environment and managements commitment to improving the overall safety conscious work environment.

Based on the information reviewed during this inspection, the inspectors concluded that the control room structure continues to perform its intended safety function, and the installed modifications, if maintained, are adequate to prevent water intrusion into the control room.

Therefore, the inspectors determined that the licensee had fulfilled the Confirmatory Action Letter commitments to address the Safety Injection Refueling Water Tank (SIRWT) and Control Room concrete support structure leakage.

NRC-Identified

and Self-Revealed Findings None.

Licensee-Identified Violations

None.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of Problem Identification and Resolution as defined by Inspection Procedure 71152, Problem Identification and Resolution.

Documents reviewed are listed in the Attachment to this report.

.1 Assessment of the Corrective Action Program Effectiveness

Inspection Scope The inspectors reviewed the procedures and processes that described the Corrective Action Program at Palisades Nuclear Plant to ensure, in part, that the requirements of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, were met. The inspectors observed and evaluated the effectiveness of meetings related to the Corrective Action Program, such as the Condition Report Prescreening meeting, the Condition Review Group meeting, and the Corrective Action Review Board meeting. Selected licensee personnel were interviewed to assess their understanding of and their involvement in the Corrective Action Program.

The inspectors reviewed selected condition reports across all seven Reactor Oversight Process cornerstones to determine if problems were being properly identified and entered into the licensees Corrective Action Program. The majority of the risk-informed samples of condition reports reviewed were issued since the last NRC biennial Problem Identification and Resolution inspection completed in February 2012. The inspectors also reviewed selected issues that were more than 5 years old.

The inspectors assessed the licensees characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significance and evaluation classes, including root cause evaluations, apparent cause evaluations, common cause evaluations, condition report responses, and human performance error reviews. The inspectors assessed the scope and depth of the licensees evaluations. For significant conditions adverse to quality, the inspectors evaluated the licensees corrective actions to prevent recurrence and for less significant issues, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significance.

The inspectors selected the Auxiliary Feedwater Actuation System and Reactor Protection System power supply components to review in detail over a 5 year period.

Both systems were safety-related and risk-significant Maintenance Rule (a)(1) systems with previously identified power supply component problems. At the time of the inspection, the Reactor Protection System was in a Maintenance Rule (a)(1) status, and the Auxiliary Feedwater Actuation System had recently returned from a Maintenance Rule (a)(1) status to a Maintenance Rule (a)(2) status. The primary purpose of this review was to determine whether the licensee was properly monitoring and evaluating the performance of risk-significant systems. The inspectors also assessed the licensees implementation of various system monitoring programs and performed walkdowns, as needed, to verify the resolution of issues. As part of this review, the inspectors interviewed the current and previous system engineers, reviewed a sample of system health reports, condition reports, operating experience, apparent cause evaluations, and root cause evaluations. The inspectors also attended the Plant Health Committee Meeting to observe the process the licensee used for identifying, prioritizing, and resolving issues that challenged unit reliability. The inspectors reviewed Corrective Action Program and work management system procedures that provided guidance for trending. In addition, the inspectors walked down the Auxiliary Feedwater Actuation System panel area to visually inspect recent power supply-related maintenance and to verify that identified concerns were entered into the Corrective Action Program.

The inspectors examined the results of self-assessments of the Corrective Action Program completed during the review period. The results of the self-assessments were compared to self-revealed and NRC-identified findings. The inspectors also reviewed the corrective actions associated with previously identified non-cited violations and findings to determine whether the station properly evaluated and resolved those issues.

The inspectors performed walkdowns, as necessary, to verify the resolution of the issues.

Assessment

(1) Identification of Issues Based on the results of the inspection, the inspectors concluded that, overall, the station was effective in identifying issues at a low threshold and properly entering them into the Corrective Action Program. The inspectors determined that problems were usually identified and captured in a complete and accurate manner in the Corrective Action Program. The station was appropriately screening issues from both NRC and industry operating experience at an appropriate level and entering them into the Corrective Action Program when the issues were applicable to the station. The inspectors also noted that deficiencies were identified by external organizations, including the NRC, that had not been previously identified by licensee personnel. These deficiencies were subsequently entered into the Corrective Action Program for resolution.

The inspectors determined that the station was generally effective at trending low level issues to prevent more significant issues from developing. The licensee also used the Corrective Action Program to document instances where previous corrective actions were ineffective or were inappropriately closed.

The inspectors concluded that power supply-related concerns were identified and entered into the Corrective Action Program at a low threshold, and concerns were resolved in a timely manner commensurate with their safety significance.

(2) Prioritization and Evaluation of Issues Based on the results of the inspection, the inspectors concluded that the station was adequately prioritizing and evaluating issues commensurate with the safety significance of the identified issue, which included a consideration of risk.

The inspectors determined that the Condition Report Prescreening meeting, the Condition Review Group meeting, and the Corrective Action Review Board meeting were all generally thorough and maintained a high standard for evaluation quality. Members of the Condition Review Group discussed selected issues in sufficient detail and challenged the responsible department representatives regarding their conclusions and recommendations.

The inspectors performed a detailed review of issues related to the Reactor Protection System and Auxiliary Feedwater Actuation System power supplies over roughly the past 5 years. The inspectors concluded that the evaluation of design issues, along with failure analyses, provided for a thorough review of potential causes of issues. The corrective actions already implemented to evaluate the extent of condition of an issue and those being completed to revise the design of the power supplies were being implemented in a timely manner commensurate with the safety significance of the issues. The inspectors noted that the licensee generally exhibited no reluctance in placing structures, systems, and components into a Maintenance Rule (a)(1) status.

Appropriate corrective actions to address identified maintenance deficiencies were prescribed and completed. A detailed review of the structures, systems, and components performance generally occurred before returning such structures, systems, and components to a Maintenance Rule (a)(2) status.

The inspectors determined that the licensee typically evaluated equipment functionality requirements adequately after a degraded or non-conforming condition was identified.

Overall, appropriate actions were assigned to correct the degraded or non-conforming condition.

Vulnerabilities in Condition Evaluations The inspectors identified several instances in which the licensees evaluation lacked sufficient quality to address the condition such that a technically competent reviewer could understand how the corrective actions would correct the identified condition. This lack of quality could potentially impact the licensees ability to identify adequate corrective actions. The inspectors identified the following condition reports as examples where the licensees evaluation lacked sufficient quality:

• Foreign Material Intrusion Effectiveness Review Condition Report CR-PLP-2012-05054, Root Cause Evaluation Report for Foreign Material Intrusion P-74, SIRWT Recirculation Pump, evaluated a foreign material intrusion event in July 2012 that affected the Safety Injection Refueling Water Tank recirculation pump. The effectiveness reviews performed by the licensee did not establish the proper threshold to identify issues at a level that could be addressed prior to the issue becoming a more significant concern. In the root cause evaluation report, the licensee documented that the foreign material intrusion event was caused by a failure to follow the foreign material excursion procedure. However, the failure threshold for the effectiveness review performed was a failure to follow procedures that resulted in foreign material intrusion. During the effectiveness review, the licensee identified failures to follow the foreign material excursion procedure.

However, the licensee concluded in the effectiveness review that the corrective actions were effective because no foreign material intrusion event actually occurred.

The inspectors reasoned that the absence of a foreign material intrusion given a failure to follow the foreign material excursion procedure may have been fortuitous, rather than deliberate. Subsequently, an actual foreign material intrusion event occurred, which further demonstrated that the corrective actions might not have been effective. Specifically, when installing an inflatable bladder inside the Service Water system, on two occasions these bladders were inadvertently entrained into the return header of the Service Water system by the relative vacuum created by the system flow. It was determined that this was a result of the failure to establish adequate controls as required by the foreign material excursion procedure. This issue was documented as a non-cited violation in NRC Inspection Report 05000255/2014002.

• Vital Area Doors Alarm Evaluation While reviewing the common cause analysis for Condition Report CR-PLP-2013-4391, Trend in Vital Area Doors Found Unsecured, the inspectors identified issues with the thoroughness of the initial evaluation for the identified trend and the methodology used for the effectiveness review of the corrective actions implemented. The common cause analysis reviewed 40 instances of unsecured vital area doors that occurred between January and October 2013. The analysis identified the departments that were responsible for the doors being found unsecured and the month the issue occurred. The evaluation identified a lack of use of appropriate human performance tools associated with verifying that security doors were properly latched and closed after use. The corrective actions resulting from this trend analysis were to reinforce with site personnel and supplemental employees the proper human performance tools to use when traversing through security doors and actions to take if a door did not properly close. This common cause analysis did not evaluate potential mechanical issues with the doors that would not allow them to close properly.

The effectiveness review for this trend reviewed 20 instances of unsecured vital area doors that occurred between January 15 and March 16, 2014. This review compared the number of times the door was used to how many times the door was found unsecured. The effectiveness review determined that a low percentage of errors occurred during this timeframe, and therefore the issue was resolved with no additional actions needed. This was a different methodology with a different acceptance standard than the initial common cause analysis used since in the identification of security door violations originally identified, the number of violations was focused on, and in the follow-up review, the failure rate was focused on. These observations were discussed with the licensee. Subsequent to the effectiveness review, the licensee identified an adverse trend station-wide for the number of security door violations that occurred and planned to re-evaluate both the human performance and the mechanical door operation components of this issue and initiate follow-on corrective actions to address them.

The inspectors concluded that a lack of quality in some evaluations existed and that this was similar to what was documented in the previous biennial Problem Identification and Resolution inspection.

During this inspection, although the inspectors did not identify any findings related to the lack of quality in evaluations, a minor violation related to a Part 21 evaluation is documented in Section 4OA2.2.b of this report. Therefore, based on the samples reviewed during this inspection, the quality of evaluations, overall, appeared to be improving.

(3) Effectiveness of Corrective Actions Based on the results of the inspection, the inspectors concluded that the licensee was generally effective in addressing identified issues and that the assigned corrective actions were generally appropriate. The licensee implemented corrective actions in a timely manner, commensurate with their safety significance, including an appropriate consideration of risk. Problems identified using root or apparent cause methodologies were resolved in accordance with the Corrective Action Program procedural and regulatory requirements. Corrective actions designed to prevent recurrence were generally comprehensive, thorough, and timely. The inspectors sampled corrective action assignments for selected NRC documented violations and determined that actions assigned were generally effective and timely.

For example, the licensee received a non-cited violation in 2002 for the failure to operate the primary coolant pumps in accordance with their design operating criteria. The inspectors verified that the licensees evaluations for the issue were comprehensive and the corrective actions completed and planned were appropriate and timely, commensurate with their safety significance.

The licensees pre-inspection review identified several instances where corrective actions were closed inappropriately and that additional actions were needed to complete the closeout of the corrective actions. The inspectors determined these discrepancies were minor compliance issues with the licensees Corrective Action Program procedures and the licensee had taken appropriate actions to address these issues.

The inspectors also identified that there were approximately 260 open corrective action items at the time of the inspection. However, only 20 of these open corrective action items were more than 2 years old. The inspectors reviewed a sample of these corrective action items and verified that the sampled condition reports were evaluated and actions assigned appropriately. The inspectors determined that most of the remaining actions were related to a fire protection license amendment request, which was in the NRC review process. Other corrective actions were related to minor non-conformances or enhancements with low safety significance. For those corrective actions that were safety significant, the inspectors verified that the due dates were reasonable and the licensee had appropriate compensatory actions in place.

Through interviews with the licensee staff and a review of the trend of the total outstanding corrective actions over the last 5 years, the inspectors determined that the licensee had been reducing the corrective action backlog.

c. Findings

No findings were identified.

.2 Implementation of Corrective Actions Generated Following NRC Inspection Procedure

(IP) 95002 Supplemental Inspection

a. Inspection Scope

The inspectors reviewed the IP 95002 supplemental inspection action items that were implemented since the completion of an IP 95002 supplemental inspection on November 9, 2012. This supplemental inspection was related to a Yellow finding documented in NRC Inspection Report 05000255/2011019 and 0500025/2011020.

The Yellow finding was associated with the loss of the Left train of direct current (DC)power due to the failure to ensure that the work instructions on a safety-related 125-Volt DC distribution panel were adequate for the scheduled work. The results of this supplemental inspection were documented in NRC Inspection Report 05000255/2012011.

b. Assessment The inspectors reviewed Condition Report CR-PLP-2011-04822, which was the overarching condition report for the issue that resulted in the Yellow finding, and found that the associated corrective actions had been planned and implemented. There were various tasks associated with this condition report that were completed subsequent to the supplemental inspection. These actions included development and implementation of training to address the deficiencies identified as part of the root cause analysis, as well as actions to review the root cause report and completed corrective actions to ensure any additional issues and/or concerns identified had already been addressed and did not invalidate the actions taken. The inspectors reviewed the completed corrective actions and found them to be adequate.

c. Findings

No findings were identified.

.3 Implementation of Corrective Actions Generated Following NRC IP 95001 Supplemental

Inspection

a. Inspection Scope

The inspectors reviewed the corrective actions that were implemented and the effectiveness reviews of those corrective actions that had been conducted since the completion of an IP 95001 supplemental inspection on June 29, 2012. This supplemental inspection was related to a White finding associated with the Turbine-Driven Auxiliary Feedwater pump that was documented in NRC Inspection Report 05000255/2011013 and 05000255/2011017. The results of this supplemental inspection were documented in NRC Inspection Report 05000255/2012010.

b. Assessment The inspectors reviewed Condition Report CR-PLP-2011-5723 and the associated root cause evaluation report, Auxiliary Feedwater Pump P-8B Overspeed Trip Actuation, and found that all of the associated corrective actions had been implemented. Two effectiveness reviews had also been completed to evaluate the adequacy of the corrective actions implemented. The first effectiveness review conducted in April 2012 examined the revisions to the maintenance procedure for the Auxiliary Feedwater Pump, and identified some enhancements to be included in the procedure based on information in the root cause evaluation. The inspectors reviewed the most current revision of this maintenance procedure and found that all of those enhancements had been included in the document. The second effectiveness review examined maintenance records, condition reports generated, and operations logs to determine if any unexpected Limiting Condition for Operation entries were made, or Limiting Condition for Operation time was extended, due to maintenance issues related to the Turbine-Driven Auxiliary Feedwater Pump. This review was conducted in April 2014 after the most recent refueling outage (refueling outage maintenance caused the issues the led to the White finding initially), and concluded that there were no maintenance-induced problems related to this pump. All corrective actions associated with the aforementioned condition report and root cause evaluation, and all effectiveness reviews had been completed for this White finding. The inspectors reviewed all of this information and determined that the actions implemented were adequate.

c. Findings

No findings were identified.

.4 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience Program. Specifically, the inspectors reviewed the Operating Experience Program implementing procedures and licensee evaluations of operating experience issues and events. The inspectors also observed meetings and daily activities for the use of operating experience information to determine whether the licensee was effectively integrating operating experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees Operating Experience Program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used operating experience information in the planning and performance of departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of operating experience, were identified and implemented effectively and in a timely manner. In addition, the inspectors interviewed the Operating Experience Program owner to obtain insights on its use.

b. Assessment Based on the results of the inspection, the inspectors concluded that, overall, operating experience was effectively utilized at the station. The inspectors observed that representatives from different sites held periodic meetings to discuss recently published operating experience. Issues that were applicable to the Palisades Nuclear Plant were entered into the Corrective Action Program for resolution. Industry operating experience was effectively disseminated across plant departments through daily and pre-job briefings.

Nonetheless, the inspectors noted the following licensee identified minor violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, related to a 10 CFR Part 21 evaluation.

Deficiencies in Part 21 Evaluation On November 8, 2012, Fisher Control International submitted a Part 21 report that described certain butterfly valve parts that did not receive proper commercial grade dedication. These parts were considered essential-to-function and were required for the butterfly valve assembly to perform its safety-related function. Fisher Control International requested the recipients of the Part 21 report to review this information for applicability to their equipment and facilities and take appropriate actions, if required.

The licensee entered this issue in the Corrective Action Program on November 20, 2012.

The licensee contacted Fisher Control International and identified that two installed safety-related Component Cooling Heat Exchanger temperature control valves were affected. The licensee concluded that the valves would perform their design function, but did not clearly document the basis of that conclusion. In addition, Fisher Control International also communicated to the licensee that they had identified and notified the licensee of other components that might not have been commercially dedicated properly due to an ambiguity in the purchase orders. However, the licensee did not research this matter any further.

In May 2013 during an audit, Nuclear Oversight identified that the Part 21 evaluation was inadequate to support the conclusion that it was acceptable to use the butterfly valve as-is and did not address all the issues communicated by Fisher Control International.

Subsequently, an operability evaluation was performed, which concluded that all of the equipment impacted remained operable, but were non-conforming.

The inspectors determined that this was a licensee-identified minor violation of 10 CFR 50, Appendix B, Criteria XVI, Corrective Action. This failure to comply with the Appendix B requirement constituted a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. A replacement of the affected equipment was scheduled for the next refueling outage.

c. Findings

No findings were identified.

.5 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected self-assessments, bench markings, Snap-shot self-assessments, and Nuclear Oversight audits, as well as the schedule of past and future assessments. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the Corrective Action Program. In addition, the inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

b. Assessment Based on the results of the inspection, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. In many cases, these self-assessments and audits had identified numerous issues that were not previously recognized by the station. These issues were entered into condition reports as required by Corrective Action Program procedures.

c. Findings

No findings were identified.

.6 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors interviewed 19 Palisades Nuclear Plant personnel to determine if there were any indications that licensee personnel were reluctant to raise safety concerns to either their management or the NRC due to fear of retaliation. These individuals represented various departments onsite including Engineering, Maintenance, Operations, Radiation Protection, and Security. The inspectors also assessed the licensees safety conscious work environment through a review of Employee Concerns Program implementing procedures, discussions with the Employee Concerns Program Manager, and reviews of condition reports. The inspectors reviewed selected Employee Concerns Program activities to identify any emergent issues or potential trends. The licensees actions to publicize the Corrective Action Program and Employee Concerns Program were also reviewed. The review was performed to ensure there was a free flow of information and to determine if individuals were willing to raise nuclear safety concerns without fear of retaliation.

b. Assessment As discussed in NRC Inspection Report 05000255/2014009, dated March 6, 2014, the NRC performed a limited scope Problem Identification and Resolution inspection that focused on an assessment of the safety conscious work environment in the Chemistry Department, Security Department, and Mechanical Maintenance working group. This inspection was performed as a result of the NRCs receipt of several safety conscious work environment or safety culture-related concerns that prompted questions into the progress made in implementing the licensees Recovery Plan regarding safety culture deficiencies that, in part, contributed to two Greater-than-Green findings identified in 2011.

The NRC identified a chilled work environment in the Security Department as documented in NRC Inspection Report 05000255/2014009. The licensee implemented a number of corrective actions to address the chilled environment in the Security Department.

During this inspection, the inspectors determined that the safety conscious work environment and overall performance related to identifying, evaluating, and resolving problems was acceptable for the site in general. However, the assessment below was not characteristic of the safety conscious work environment in the Security Department.

A detailed review of the licensees Security SCWE Action Plan is discussed in Section 4OA5.2 of this report.

With the exception of the Security Department, the inspectors did not identify any issues that suggested conditions were not conducive to the establishment and existence of a safety conscious work environment at Palisades Nuclear Plant. Licensee staff was aware of and familiar with the Corrective Action Program and other station processes, including the Employee Concerns Program, through which concerns could be raised.

The inspectors did not review the site Safety Culture and SCWE surveys and assessments during this inspection because these documents were recently reviewed as part of the limited scope Problem Identification and Resolution inspection and the conclusions from that inspection remained valid. The results indicated that there were no impediments to the identification of nuclear safety issues.

The staff also indicated that management had been focused on promoting an environment that encourages raising issues and concerns without fear of retaliation.

The formal policy was communicated at all hands meetings, shift turnover meetings, and through other communication venues, such as newsletters and emails. Department managers and supervisors promoted a safety conscious work environment and reinforced senior managements policy.

Individuals were comfortable raising issues and concerns without fear of retaliation.

Overall, they felt that condition reports were given the appropriate priority and actions taken to close condition reports were effective in addressing the identified issues.

c. Findings

No findings were identified.

4OA5 Other Activities

.1 Confirmatory Action Letter (CAL) - Palisades Nuclear Plant Commitments to Address

SIRWT and Control Room Concrete Support Structure Leakage As documented in NRC Letter EA-12-155, Confirmatory Action Letter (CAL) Revision 1

- Palisades Nuclear Plant Commitments to Address Safety Injection Refueling Water Tank (SIRWT) and Control Room Concrete Support Structure Leakage, (ADAMS ML13177A280) the NRC concluded that the structural integrity of the Safety Injection Refueling Water Tank was sufficient to meet its intended safety function, which addressed three of the five CAL items. The remaining two CAL items associated with the control room support structure were as follows:

1. Entergy Nuclear Operations, Inc., (ENO) will continue inspections of the concrete support structure above the control room, control room hallway, and the concrete support structure ceiling as prescribed in the approved Operations Standing Order. These inspections are to ensure that the temporary modifications installed to prevent impact to safety-related structures, systems and components are performing their intended functions.

2. ENO will correct the adverse condition related to cracking of the concrete support structure around the ceiling of the control room, which could lead to water intrusion, prior to restart from the next refueling outage.

To address these items, the licensee performed a modification in the catacombs area above the control room. This modification included the installation of a waterproof membrane and a design feature to divert water away from the control room, in the event of a leak into the catacombs area. The licensee also performed inspections of the areas where SIRWT leakage could occur, including the catacombs area, until all modification activities were complete.

The inspectors performed a review of the engineering change package that documented the details of the modification and the analyses performed to determine acceptability.

The inspectors ensured that the licensee addressed the capability of this system as well as other impacts that the addition of the waterproof membrane could have on other equipment. The inspectors also performed a walkdown of the areas below the catacombs to ensure a water intrusion scenario would not impact other safety-related equipment. The inspectors reviewed the logs that described the licensees inspections that were performed to ensure these inspections were adequate to identify any water intrusion and were performed in accordance with the CAL commitment.

Based on the information reviewed during this inspection, the inspectors concluded that the control room structure continues to perform its intended safety function, and the installed modifications, if maintained, are adequate to prevent water intrusion into the control room. Therefore, the inspectors determined that the licensee had fulfilled its commitments to address the Safety Injection Refueling Water Tank and control room concrete support structure leakage.

Separate correspondence will be issued to formally close Confirmatory Action Letter EA-12-155.

.2 Security Safety Conscious Work Environment Action Plan

The inspectors performed an independent evaluation of the sites implementation of the Security Safety Conscious Work Environment (SCWE) Action Plan. The plan was developed by the site and was being implemented in response to the NRCs identification of a chilled work environment within the Security Department during the December 2013 limited scope Problem Identification and Resolution inspection, which was documented in NRC Inspection Report 05000255/2014009 (ADAMS ML14064A569). The inspectors performed an independent review of the licensees implementation of the Security SCWE Action Plan. The inspection included a review of the licensees implementation and completion of SCWE Action Plan actions; two focus group meetings with 19 non-supervisory level security officers; and interviews with the Regulatory and Performance Improvement Director, Security Manager, and the Employee Concerns Program Manager.

Specific observations included the following:

• Security officers had a limited recollection of discussing the results of the NRCs limited scope Problem Identification and Resolution inspection that was completed in February 2014. Security officers recalled being told that the NRC stated there appears to be a potential chilled work environment in Security.

The security officers stated that they believed the site did not feel there was a chilled work environment, but was only taking actions in response to the NRCs conclusions.

During an interview with the Security Manager, additional details on the dissemination of the inspection results were obtained. Specifically, security officers were provided the inspection report as an email attachment in advance of the Security Manager meeting with each of the security shifts. At the meetings, hard copies of the report were available for the security officers to reference and retain, as desired. The Security Manager acknowledged discussing the NRCs conclusions, but validated the fact that security officers were told the NRC stated there appears to be a potential chilled work environment in Security.

• Security officers stated they were never informed of the sites development and implementation of a Security SCWE Action Plan and were unaware of the specific actions required by the existing plan.

• Security officers perceived site management to be simply putting checks in the block to credit completion of action items and were not committed to changing the existing safety conscious work environment issues in the Security Department.

• Security officers identified a lack of interaction with supervisory and management personnel above the Security Shift Supervisor level within the Security Department and site senior management personnel external to the Security Department. Security officers did acknowledge an increase in the attendance of Security Operations Superintendents at shift turnover meetings.

• Security officers were unaware of the establishment of the sites Security Ombudsman Program and the intent of the program. Additionally, the security officers were unaware of who the security ombudsman was for their respective shift despite the selection and assignment of staff to these positions at the end of March 2014.

• Security officers were not aware of a change in the site security chain of command. Specifically, the fact that the Palisades Security Manager no longer reported to the Entergy Corporate Security Director, but reported to the Site Vice President through the Regulatory and Performance Improvement Director was not communicated. In addition, security officers were not introduced to the Regulatory and Performance Improvement Director.

• Since November 2013, the sites Aggregate Performance Review rated the Security Department as Green in the area of Nuclear Safety. At an Aggregate Performance Review Meeting conducted on May 19, 2014, this rating was challenged by a manager outside the Security Department and, as a result of this challenge, the participants agreed the Security Department should be rated Red in this area due to the chilled work environment identified in the department.

Since November 2013, the Security Department had been rating this area as Green in the Department Performance Review and this rating was unchallenged by senior management until the May 2014 Aggregate Performance Review Meeting.

The inspectors concluded that, to date, the site had completed all the actions as committed to in the Security SCWE Action Plan. However, the inspectors concluded that the quality of the actions implemented have been insufficient to assess and understand the cause of the chilled work environment within the Security Department and did not demonstrate a strong commitment to effectively improve the safety conscious work environment in the Security Department. Specifically, significant gaps were found to exist in the security officers knowledge of the actions being taken to address the chilled safety conscious work environment and managements commitment to improving the overall safety conscious work environment.

4OA6 Management Meetings

a. Interim Exit Meeting On May 23, 2014, the inspectors presented the preliminary inspection results to Mr. A. Vitale, Site Vice President, and other members of the licensee staff.

b. Exit Meeting On June 11, 2014, the inspectors presented the final inspection results to Mr. A. Vitale, Site Vice President and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

A. Vitale, Site Vice President

W. Nelson, Training Manager

G. Heisterman, Maintenance Manager

A. Notbohm, CA&A Manager

O. Gustafson, Regulatory and Performance Improvement Director

D. Corbin, Operations Manager

M. Seleski, Chemistry Supervisor

C. Plachta, Nuclear Oversight Manager

B. Davis, Engineering Director

E. Chetfield, Employee Concern Program Manager

D. Lucy, Planning, Scheduling and Outage Manager

J. Wright, Radwaste Supervisor

J. Ridley, Emergency Preparedness Coordinator

J. Haverly, Security Supervisor

NRC

A. Boland, Director, Division of Reactor Projects

E. Duncan, Branch Chief, Division of Reactor Projects

A. Garmoe, Senior Resident Inspector

A. Scarbeary, Resident inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None Attached