ML16019A460

Information Request to Support Upcoming Problem Identification and Resolution Inspection at the Palisades Nuclear Plant

ML16019A460
Person / Time
Site:	Palisades
Issue date:	01/19/2016
From:	Jandovitz J Region 3 Branch 3
To:	Vitale A Entergy Nuclear Operations
References
Download: ML16019A460 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 January 19, 2016 Mr. Anthony Vitale Vice-President, Operations Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

INFORMATION REQUEST TO SUPPORT UPCOMING PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION AT THE PALISADES NUCLEAR PLANT

Dear Mr. Vitale:

This letter is to request information to support our scheduled Problem Identification and Resolution (PI&R) inspection beginning March 21, 2016, at your Palisades Nuclear Plant. This inspection will be performed in accordance with the NRC baseline Inspection Procedure 71152.

Experience has shown that these inspections are extremely resource intensive both for the NRC inspectors and the utility staff. In order to minimize the impact that the inspection has on the site and to ensure a productive inspection, we have enclosed a list of documents required for the inspection.

The documents requested are copies of condition reports and lists of information necessary to ensure the inspection team is adequately prepared for the inspection. The information requested prior to the inspection may be provided in either CD-ROM/DVD (preferred) or hard copy format and should be ready for NRC review by March 1, 2016. Mr. Jamie Benjamin, the Lead Inspector, will contact your staff to determine the best method of providing the requested information.

If there are any questions about the material requested, or the inspection in general, please contact Mr. Benjamin at 630-842-7109 or Jamie.Benjamin@nrc.gov.

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, Control Number 3150-0011.

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management 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 Jandovitz, Acting Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Requested Information to Support PI&R Inspection cc w/encl: Distribution via LISTSERV

Enclosure Requested Information to Support Problem Identification and Resolution (PI&R) Inspection Please provide the information on a compact disc or DVD, if possible. Unless otherwise specified, the time frame for requested information is for the period of March 1, 2016, through the time the data request is answered. Please label any electronic files with file content information.

In addition, inspectors will require computer access to the corrective action program (CAP) database while on site.

PROGRAM DOCUMENTS

1.

Copies of current administrative procedures associated with the corrective action program (CAP). This should include procedures related to: 1) corrective action process;

2) operating experience program; 3) self-assessment program; 4) maintenance rule program; 5) operability determination process; 6) degraded/non-conforming condition process (e.g., RIS 2005-20); 7) system health process or equivalent equipment reliability improvement programs; and 8) operational decision making (ODMI) process.

2.

A current copy of the Employee Concerns Program/Ombudsman administrative procedure.

3.

Description of any substantive changes made to the CAP since the last PI&R Inspection (June 2014). Please include the effective date with each listed change.

ASSESSMENTS

4.

A copy of Quality Assurance (QA) audits of the corrective action program.

5.

A list of all other QA audits completed with a brief description of areas where findings were identified.

6.

The schedule of future QA audits.

7.

A copy of completed CAP self-assessments and the plan/schedule for future CAP self-assessments.

8.

A chronological list of department and site self-assessments completed (include date completed).

9.

A list of condition reports (CRs) written for findings or concerns identified in self-assessments and audits. Include a short description/title of the finding, its status, and include a cross-reference to the audit or self-assessment number.

2 CORRECTIVE ACTION DOCUMENTS

10.

A list of completed root cause evaluations with a brief description of the issue. Provide status of any actions developed as part of the evaluations and their present status.

Include a reference, if not part of the root cause package, to the documents and/or CRs directing and tracking the actions.

11.

A list of completed apparent cause evaluations with a brief description of the issue.

Provide status of any actions developed as part of the evaluations and their present status. Include a reference, if not part of the apparent cause package, to the documents and/or CRs directing and tracking the actions.

12.

A list of all open condition reports sorted by significance level. Include CR number, the date initiated, a brief description/title, system affected if any, significance level, and anticipated completion date, if available. This list should be grouped by responsible department and listed in order of initiation date (oldest listed first).

13.

A list of closed CRs sorted by significance level and then initiation date. Include CR number, a brief description/title, the significance level, the date initiated and closed, assigned organization, system affected and whether there was an associated operability evaluation.

14.

A list of open corrective actions, sorted by significance/priority level, with a brief description/title, initiating date and due date. The list should be grouped by the responsible department.

15.

A list of CRs generated by the corporate office that involve or affect plant operation, sorted by significance level. Include the date initiated, a brief description/title, site(s) affected, system affected, significance/priority level, assigned organization, and status (if closed include date closed; if open, include scheduled date to be closed).

16.

A list of completed effectiveness reviews with a brief description of the results. Include a cross-reference to the CRs for which the effectiveness review was conducted and, if applicable, CR numbers documenting any additional follow-up actions.

17.

A list of CRs initiated for inadequate or ineffective corrective actions. Include the date initiated, a brief description/title, significance/priority level, system affected, assigned organization, and status (if closed include date closed; if open, include scheduled date to be closed). Include a cross-reference to the CR or evaluation that generated the original corrective action.

18.

A copy of any performance reports or indicators used to track CAP effectiveness for the past 18 months. The most recent data and end-of-quarter data will suffice; monthly reports are not required.

19.

A data table (or similar format) showing the total number of CRs generated in 2014 and 2015 sorted by department (i.e. operations, engineering, security etc.).

20.

A data table showing the number of issues identified externally (NRC, INPO, other etc.)

as compared to internally in 2014 and 2015.

3

21.

A list of rework items and repeat failures from the maintenance program. Include the applicable WO and associated CRs.

22.

A copy of any trend reports for Work Orders. Include a copy of WO work down curves.

23.

A list of open Work Orders associated with degraded equipment. Include a brief description, whether the item is outage related, age, and status code. Include a copy of the meaning of the status codes.

TRENDS

24.

A list of CRs initiated for trends of conditions adverse to quality. Include the date initiated, a brief description/title, significance/priority level, and status (if closed include date closed; if open, include scheduled date to be closed).

25.

Copies of any completed trend reports for CRs. Quarterly trend reports are acceptable; copies of all monthly reports are not required.

26.

Copies of all apparent, common and/or root cause evaluations regarding adverse human performance trends.

OPERATING EXPERIENCE

27.

A copy of the most recent operating experience program effectiveness review.

28.

A list of CRs initiated to evaluate industry and NRC operating experience, and NRC generic communications (e.g. bulletins, information notices, generic letters, etc.).

Include date the CR was initiated, a brief description/title, and the status (if closed include date closed; if open, include scheduled date to be closed).

SYSTEMS AND COMPONENTS

29.

A list of the top ten risk significant systems and top ten risk significant components.

30.

A list of operability determinations/evaluations. Include a brief description/title, date initiated, date closed or date scheduled to be closed. Also include any open operability evaluations that were initiated prior to January 1, 2014.

31.

Cause analysis, corrective actions documents, health reports, and trend analysis for systems and components considered Maintenance Rule (a)(1). Provide this information starting one year earlier from when the system or component entered (a)(1) status.

Include dates when system/components entered (a)(1) status and, if applicable, returned to (a)(2) status. For recurring reports, quarterly reports are sufficient; monthly reports are not required.

32.

A list of temporary modifications that were installed since January 1, 2014, with a brief description/title, installation date, and current status. Include any in-place temporary modifications that were installed prior to January 1, 2014

4 SCWE

33.

Results of completed safety culture/safety conscious work environment surveys or self-assessments. Include reference to associated CRs and status of the CRs actions.

Also include schedule/plans for future surveys.

REGULATORY ISSUES

34.

A list of CRs for issues (findings, violations, etc.) documented in NRC inspection reports.

Include the CR number, brief description/title, date initiated and the status (if closed include date closed; if open, include scheduled date to be closed).

35.

A list of CRs for licensee identified violations that have been documented in NRC inspection reports. Include the CR number, brief description/title, date initiated and the status (if closed include date closed; if open, include scheduled date to be closed).

36.

A list of CRs associated with NRC identified issues. Include the CR number, brief description/title, date initiated and the status (if closed include date closed; if open, include scheduled date to be closed).

37.

A list of degraded/non-conforming conditions. Include the CR number, brief description/title, date initiated and date closed or projected closeout date. Include open issues that were identified prior to January 1, 2014.

38.

A list of current control room deficiencies and operator work-arounds, sorted by priority, with a brief description/title and corresponding CR and/or work order number.

5-YEAR REVIEW

39.

A list of CRs regarding the Equipment Reliability Program that have been generated since January 1, 2011. Include the CR number, brief description/title, level of evaluation (i.e. root cause, apparent cause, common cause etc.), date initiated, and the status (if closed include date closed; if open, include scheduled date to be closed).

ADMIN

40.

A copy of the latest plant organizational chart and phone listing

41.

Scheduled dates, times, and location for all meetings associated with implementing the CAP (e.g. CR screening meetings, corrective action review board meetings). Include work order screening/assessment meetings.

Documents requested to be available on-site during the inspection:

a.

Updated Final Safety Analysis Report.

b.

Technical Specifications.

c.

Procedures and procedure index.

5

d.

Copies of any self-assessments and associated condition reports generated in preparation for this PI&R inspection.

e.

A copy of the QA manual.

f.

A list of issues brought to the ECP/ombudsman and the actions taken for resolution.

g.

A list of the codes used in the CAP.

h.

A copy of the latest independent/offsite organization review of safety culture/safety conscious work environment and internal equivalent assessments if not provided as part of the requested data package.

Other:

On the first day of the inspection, or early on the second day, please provide the inspection team a briefing of your corrective action program. Include your expectations for personnel using the program and how the work order system fits into the overall scheme for addressing identified issues. Also please demonstrate how to use a computer to access CAP data.

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management 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 Jandovitz, Acting Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Requested Information to Support PI&R Inspection cc w/encl: Distribution via LISTSERV DISTRIBUTION w/encl:

Kimyata MorganButler RidsNrrPMPalisades Resource RidsNrrDorlLpl3-1 Resource RidsNrrDirsIrib Resource Cynthia Pederson Darrell Roberts Richard Skokowski Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Jim Clay Carmen Olteanu ADAMS Accession Number ML16019A460 Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII RIII NAME JJandovitz for BBartlett:bw JJandovitz DATE 01/19/2016 01/19/2016 OFFICIAL RECORD COPY

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 January 19, 2016 Mr. Anthony Vitale Vice-President, Operations Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

INFORMATION REQUEST TO SUPPORT UPCOMING PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION AT THE PALISADES NUCLEAR PLANT

Dear Mr. Vitale:

This letter is to request information to support our scheduled Problem Identification and Resolution (PI&R) inspection beginning March 21, 2016, at your Palisades Nuclear Plant. This inspection will be performed in accordance with the NRC baseline Inspection Procedure 71152.

Experience has shown that these inspections are extremely resource intensive both for the NRC inspectors and the utility staff. In order to minimize the impact that the inspection has on the site and to ensure a productive inspection, we have enclosed a list of documents required for the inspection.

The documents requested are copies of condition reports and lists of information necessary to ensure the inspection team is adequately prepared for the inspection. The information requested prior to the inspection may be provided in either CD-ROM/DVD (preferred) or hard copy format and should be ready for NRC review by March 1, 2016. Mr. Jamie Benjamin, the Lead Inspector, will contact your staff to determine the best method of providing the requested information.

If there are any questions about the material requested, or the inspection in general, please contact Mr. Benjamin at 630-842-7109 or Jamie.Benjamin@nrc.gov.

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, Control Number 3150-0011.

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management 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 Jandovitz, Acting Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Requested Information to Support PI&R Inspection cc w/encl: Distribution via LISTSERV

Enclosure Requested Information to Support Problem Identification and Resolution (PI&R) Inspection Please provide the information on a compact disc or DVD, if possible. Unless otherwise specified, the time frame for requested information is for the period of March 1, 2016, through the time the data request is answered. Please label any electronic files with file content information.

In addition, inspectors will require computer access to the corrective action program (CAP) database while on site.

PROGRAM DOCUMENTS

1.

Copies of current administrative procedures associated with the corrective action program (CAP). This should include procedures related to: 1) corrective action process;

2) operating experience program; 3) self-assessment program; 4) maintenance rule program; 5) operability determination process; 6) degraded/non-conforming condition process (e.g., RIS 2005-20); 7) system health process or equivalent equipment reliability improvement programs; and 8) operational decision making (ODMI) process.

2.

A current copy of the Employee Concerns Program/Ombudsman administrative procedure.

3.

Description of any substantive changes made to the CAP since the last PI&R Inspection (June 2014). Please include the effective date with each listed change.

ASSESSMENTS

4.

A copy of Quality Assurance (QA) audits of the corrective action program.

5.

A list of all other QA audits completed with a brief description of areas where findings were identified.

6.

The schedule of future QA audits.

7.

A copy of completed CAP self-assessments and the plan/schedule for future CAP self-assessments.

8.

A chronological list of department and site self-assessments completed (include date completed).

9.

A list of condition reports (CRs) written for findings or concerns identified in self-assessments and audits. Include a short description/title of the finding, its status, and include a cross-reference to the audit or self-assessment number.

2 CORRECTIVE ACTION DOCUMENTS

10.

A list of completed root cause evaluations with a brief description of the issue. Provide status of any actions developed as part of the evaluations and their present status.

Include a reference, if not part of the root cause package, to the documents and/or CRs directing and tracking the actions.

11.

A list of completed apparent cause evaluations with a brief description of the issue.

Provide status of any actions developed as part of the evaluations and their present status. Include a reference, if not part of the apparent cause package, to the documents and/or CRs directing and tracking the actions.

12.

A list of all open condition reports sorted by significance level. Include CR number, the date initiated, a brief description/title, system affected if any, significance level, and anticipated completion date, if available. This list should be grouped by responsible department and listed in order of initiation date (oldest listed first).

13.

A list of closed CRs sorted by significance level and then initiation date. Include CR number, a brief description/title, the significance level, the date initiated and closed, assigned organization, system affected and whether there was an associated operability evaluation.

14.

A list of open corrective actions, sorted by significance/priority level, with a brief description/title, initiating date and due date. The list should be grouped by the responsible department.

15.

A list of CRs generated by the corporate office that involve or affect plant operation, sorted by significance level. Include the date initiated, a brief description/title, site(s) affected, system affected, significance/priority level, assigned organization, and status (if closed include date closed; if open, include scheduled date to be closed).

16.

A list of completed effectiveness reviews with a brief description of the results. Include a cross-reference to the CRs for which the effectiveness review was conducted and, if applicable, CR numbers documenting any additional follow-up actions.

17.

A list of CRs initiated for inadequate or ineffective corrective actions. Include the date initiated, a brief description/title, significance/priority level, system affected, assigned organization, and status (if closed include date closed; if open, include scheduled date to be closed). Include a cross-reference to the CR or evaluation that generated the original corrective action.

18.

A copy of any performance reports or indicators used to track CAP effectiveness for the past 18 months. The most recent data and end-of-quarter data will suffice; monthly reports are not required.

19.

A data table (or similar format) showing the total number of CRs generated in 2014 and 2015 sorted by department (i.e. operations, engineering, security etc.).

20.

A data table showing the number of issues identified externally (NRC, INPO, other etc.)

as compared to internally in 2014 and 2015.

3

21.

A list of rework items and repeat failures from the maintenance program. Include the applicable WO and associated CRs.

22.

A copy of any trend reports for Work Orders. Include a copy of WO work down curves.

23.

A list of open Work Orders associated with degraded equipment. Include a brief description, whether the item is outage related, age, and status code. Include a copy of the meaning of the status codes.

TRENDS

24.

A list of CRs initiated for trends of conditions adverse to quality. Include the date initiated, a brief description/title, significance/priority level, and status (if closed include date closed; if open, include scheduled date to be closed).

25.

Copies of any completed trend reports for CRs. Quarterly trend reports are acceptable; copies of all monthly reports are not required.

26.

Copies of all apparent, common and/or root cause evaluations regarding adverse human performance trends.

OPERATING EXPERIENCE

27.

A copy of the most recent operating experience program effectiveness review.

28.

A list of CRs initiated to evaluate industry and NRC operating experience, and NRC generic communications (e.g. bulletins, information notices, generic letters, etc.).

Include date the CR was initiated, a brief description/title, and the status (if closed include date closed; if open, include scheduled date to be closed).

SYSTEMS AND COMPONENTS

29.

A list of the top ten risk significant systems and top ten risk significant components.

30.

A list of operability determinations/evaluations. Include a brief description/title, date initiated, date closed or date scheduled to be closed. Also include any open operability evaluations that were initiated prior to January 1, 2014.

31.

Cause analysis, corrective actions documents, health reports, and trend analysis for systems and components considered Maintenance Rule (a)(1). Provide this information starting one year earlier from when the system or component entered (a)(1) status.

Include dates when system/components entered (a)(1) status and, if applicable, returned to (a)(2) status. For recurring reports, quarterly reports are sufficient; monthly reports are not required.

32.

A list of temporary modifications that were installed since January 1, 2014, with a brief description/title, installation date, and current status. Include any in-place temporary modifications that were installed prior to January 1, 2014

4 SCWE

33.

Results of completed safety culture/safety conscious work environment surveys or self-assessments. Include reference to associated CRs and status of the CRs actions.

Also include schedule/plans for future surveys.

REGULATORY ISSUES

34.

A list of CRs for issues (findings, violations, etc.) documented in NRC inspection reports.

Include the CR number, brief description/title, date initiated and the status (if closed include date closed; if open, include scheduled date to be closed).

35.

A list of CRs for licensee identified violations that have been documented in NRC inspection reports. Include the CR number, brief description/title, date initiated and the status (if closed include date closed; if open, include scheduled date to be closed).

36.

A list of CRs associated with NRC identified issues. Include the CR number, brief description/title, date initiated and the status (if closed include date closed; if open, include scheduled date to be closed).

37.

A list of degraded/non-conforming conditions. Include the CR number, brief description/title, date initiated and date closed or projected closeout date. Include open issues that were identified prior to January 1, 2014.

38.

A list of current control room deficiencies and operator work-arounds, sorted by priority, with a brief description/title and corresponding CR and/or work order number.

5-YEAR REVIEW

39.

A list of CRs regarding the Equipment Reliability Program that have been generated since January 1, 2011. Include the CR number, brief description/title, level of evaluation (i.e. root cause, apparent cause, common cause etc.), date initiated, and the status (if closed include date closed; if open, include scheduled date to be closed).

ADMIN

40.

A copy of the latest plant organizational chart and phone listing

41.

Scheduled dates, times, and location for all meetings associated with implementing the CAP (e.g. CR screening meetings, corrective action review board meetings). Include work order screening/assessment meetings.

Documents requested to be available on-site during the inspection:

a.

Updated Final Safety Analysis Report.

b.

Technical Specifications.

c.

Procedures and procedure index.

5

d.

Copies of any self-assessments and associated condition reports generated in preparation for this PI&R inspection.

e.

A copy of the QA manual.

f.

A list of issues brought to the ECP/ombudsman and the actions taken for resolution.

g.

A list of the codes used in the CAP.

h.

A copy of the latest independent/offsite organization review of safety culture/safety conscious work environment and internal equivalent assessments if not provided as part of the requested data package.

Other:

On the first day of the inspection, or early on the second day, please provide the inspection team a briefing of your corrective action program. Include your expectations for personnel using the program and how the work order system fits into the overall scheme for addressing identified issues. Also please demonstrate how to use a computer to access CAP data.

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management 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 Jandovitz, Acting Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Requested Information to Support PI&R Inspection cc w/encl: Distribution via LISTSERV DISTRIBUTION w/encl:

Kimyata MorganButler RidsNrrPMPalisades Resource RidsNrrDorlLpl3-1 Resource RidsNrrDirsIrib Resource Cynthia Pederson Darrell Roberts Richard Skokowski Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Jim Clay Carmen Olteanu ADAMS Accession Number ML16019A460 Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII RIII NAME JJandovitz for BBartlett:bw JJandovitz DATE 01/19/2016 01/19/2016 OFFICIAL RECORD COPY