ML16053A472
| ML16053A472 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/22/2016 |
| From: | Louden P Division Reactor Projects III |
| To: | Vitale A Entergy Nuclear Operations |
| References | |
| EA-15-039, OI 3-2012-021 IR 2015013 | |
| Download: ML16053A472 (7) | |
See also: IR 05000255/2015013
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, IL 60532-4352
February 22, 2016
Mr. Anthony Vitale
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: PALISADES NUCLEAR PLANT, INSPECTION REPORT 05000255/2015013;
INVESTIGATION REPORT 3-2012-021; AND APPARENT VIOLATIONS
Dear Mr. Vitale:
This is in reference to an investigation completed on March 10, 2015, by the U.S. Nuclear
Regulatory Commission's (NRCs) Office of Investigations (OI) at your Palisades Nuclear Plant
(Palisades). The purpose of the investigation was to determine whether personnel at Palisades
deliberately failed to provide complete and accurate information to the NRC regarding a safety
injection and refueling water storage tank (SIRWT) leak. A Factual Summary, included as
Enclosure 1 to this letter, provides a summary of the factual basis for the apparent violations.
Based on the results of NRCs review of this investigation, three apparent violations were
identified and are being considered for escalated enforcement action in accordance with the
NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs website at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. It appears to the NRC
that parts of these violations were willful as described in the enclosed factual summary.
The first apparent violation involves the willful failure, on the part of four individuals, to enter
information concerning a leak in the SIRWT into the corrective action program as required by
Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V and
procedure EN-LI-102, Revision 16. The second apparent violation involves the failure to
perform adequate operability determinations of conditions associated with the SIRWT leak as
required by 10 CFR Part 50, Appendix B, Criterion V and procedure EN-OP-104, Revision 5.
The third apparent violation involves the apparent failure to comply with Technical Specification
(TS), surveillance requirement Section SR 3.0.3, when you failed to perform the test within 24
hours or perform a risk evaluation to complete the surveillance at a later date.
Before the NRC makes its enforcement decision, we are providing you with the opportunity to:
(1) request a predecisional enforcement conference (PEC); or (2) request alternative dispute
resolution (ADR). If a PEC is held, it will be closed to public observation because the NRCs
preliminary findings are based on an NRC OI report that has not been publicly disclosed. If
you decide to participate in a PEC or pursue ADR, please contact Mr. John Jandovitz at
A. Vitale
2
630-829-9763 within 10 days of the date of this letter. A PEC should be held within 30 days of
the receipt of this letter and an ADR session within 45 days of the date of this letter.
If you choose to request a PEC, the conference will afford you the opportunity to provide your
perspective on the apparent violations and any other information that you believe the NRC
should take into consideration before making an enforcement decision. The decision to hold a
PEC does not mean that the NRC has determined that a violation has occurred or that
enforcement action will be taken. This conference would be conducted to obtain information to
assist the NRC in making an enforcement decision. The topics discussed during the conference
may include: (1) information to determine whether the violations occurred; (2) information to
determine the significance of the violations; (3) information related to the identification of the
violations; and (4) information related to any corrective actions taken or planned to be taken. In
presenting your corrective actions, you should be aware that the promptness and
comprehensiveness of your actions will be considered in assessing any civil penalty for the
apparent violations. The guidance from NRC Information Notice 96-28, "Suggested Guidance
Relating to Development and Implementation of Corrective Action," may be helpful.
In lieu of a PEC, you may also request ADR with the NRC in an attempt to resolve this issue.
Alternative dispute resolution is a general term encompassing various techniques for resolving
conflicts using a neutral third party. The technique that the NRC has decided to employ is
mediation. Mediation is a voluntary, informal process in which a trained neutral (the mediator)
works with parties to help them reach resolution. If the parties agree to use ADR, they select a
mutually agreeable neutral mediator who has no stake in the outcome and no power to make
decisions. Mediation gives parties an opportunity to discuss issues, clear up
misunderstandings, be creative, find areas of agreement, and reach a final resolution of the
issues. Additional information concerning the NRC's program can be obtained at
http://www.nrc.gov/about-nrc/regulatory/enforcement/adr.html. The Institute on Conflict
Resolution (ICR) at Cornell University has agreed to facilitate the NRC's program as a neutral
third party. Please contact ICR at 877-733-9415 within 10 days of the date of this letter if you
are interested in pursuing resolution of this issue through ADR.
Please be advised that the number and characterization of apparent violations may change as a
result of further NRC review. You will be advised by separate correspondence of the results of
our deliberations on this matter.
In accordance with 10 CFR Section 2.390 of the NRC's Rules of Practice, a copy of this letter,
its enclosure, and your response, if you choose to provide one, will be made available
electronically for public inspection in the NRCs Public Document Room or from the NRCs
Agencywide Documents Access and Management System (ADAMS), accessible from the
NRCs website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your
response should not include any personal privacy, proprietary, or safeguards information so that
it can be made available to the public without redaction.
A. Vitale
3
If you have any questions concerning this matter, please contact Mr. John Jandovitz of my staff
at 630-829-9763.
Sincerely,
/RA Julio Lara Acting for/
Patrick L. Louden, Director
Division of Reactor Projects
Docket No. 50-255
License No. DPR-20
Enclosure:
Factual Summary of NRC Investigation
cc: Distribution via LISTSERV
Factual Summary of NRC Investigation
On June 25, 2012, the U.S. Nuclear Regulatory Commissions Office of Investigations initiated
an investigation to determine whether personnel at the Palisades Nuclear Power Plant
(Palisades) deliberately failed to provide complete and accurate information to the NRC
regarding a safety injection and refueling water storage tank (SIRWT) leak. The investigation
was completed on March 10, 2015.
On May 18, 2011, Condition Report (CR) PLP-2011-02491 was initiated when leakage from
the ceiling in the Palisades main control room was identified following heavy rains in the area.
Chemistry analysis of this leakage revealed several radioactive isotopes including Cobalt-58, a
short-lived isotope found in the primary coolant. After repairs were made to the auxiliary
building roof, leakage into the control room stopped and did not recur. The Palisades auxiliary
building contains the main control room with the catacombs directly above it, and the SIRWT is
located on the auxiliary building roof directly above catacombs.
On May 27, 2011, a robotic visual inspection was performed in the catacombs above the control
room and below the SIRWT to look for the source of the leakage. This inspection identified
boric acid deposits on the catacombs ceiling and floor, and on piping components.
On June 2, 2011, a direct visual inspection (VT-2) was performed in the catacombs that
identified two active leaks: one from the catacombs ceiling and one from a 3-inch SIRWT piping
flange in the catacombs.
Condition Report PLP-2011-02738 was initiated for the active flange leak on the
3-inch SIRWT piping flange. The flange bolting material was carbon steel, which is
susceptible to boric acid corrosion. In accordance with procedure EM-09-20, Boric
Acid Corrosion Control Program, a boric acid evaluation was required to determine the
current and future integrity of the bolts. However, the VT-2 data sheet did not contain
information on the material condition of the flange bolting. The CR documented a minor
(less than one drop per minute) flange leak on the 3-inch piping flange, but did not
identify any through-wall leakage or component wastage. It stated that no degraded or
nonconforming condition existed per procedure EN-OP-104, Operability Determination
Process, and T-58 (SIRWT) remained operable.
Condition Report PLP-2011-02740 was written for the active leak from the
catacombs ceiling. The operability determination for this CR was copied directly from
CR PLP-2011-02738, which was written to document leakage from the 3-inch piping
flange, a separate and different condition. The operability determination did not address
the actual CR condition, which was a leak from the ceiling; and therefore, possibly the
On June 8, 2011, a Kepner-Tregoe (K-T) team was formed to investigate and identify potential
and most likely leakage source. Leakage collection and analysis of the catacombs ceiling leak
took place on almost a daily basis since the initial catacombs inspection. However, the analysis
results of the leakage varied throughout the collection timeframe. The team could not identify
the source of the leakage with 100% certainty.
On June 13, 2011, a contracted engineering firm, Structural Integrity Associates (SIA), was
requested to propose a contract to evaluate a potential SIRWT leak.
Factual Summary of NRC Investigation
2
On June 16, 2011, CR PLP-2011-03021 was written to document that (RT-71M) for SIRWT
and associated piping Code pressure surveillance test had not been conducted at the frequency
required by the Code. The operability statement stated that the RT-71M surveillance was
required by Technical Specifications (TSs), but incorrectly stated that the surveillance had been
completed on June 2, 2011, thereby meeting the surveillance requirements.
On June 30, 2011, the engineering Code program supervisor issued an e-mail stating that if
short-lived radioisotopes were identified in leakage samples, the probability of the SIRWT being
the leak source was "essentially 100%." Short-lived isotopes had been identified in samples
throughout the sampling timeframe; they were first identified in the May 20, 2011, sample.
On July 27, 2011, the K-T team was disbanded.
On August 2, 2011, an industry chemistry consultant was contacted to independently analyze
the leakage data. On September 16, the consultant sent an e-mail to the chemistry manager
stating that the SIRWT was the likely source of the leakage.
On September 19, 2011, in an e-mail response to questions regarding his conclusions, the
consultant replied that there is never 100% certainty in any evaluation of this type. However,
the SIRWT isotopic analysis matched up much better than any of the other possible sources.
On September 25, 2011, the chemistry manager e-mailed the former K-T team managers and
stated that, although 100% certainty could not be assured, the source of the leakage was the
On December 5, 2011, Structural Integrity Associates Calculation 1100772.301 requested on
June 13, 2011, was approved by Palisades.
On February 15, 2012, a draft operability determination using the SIA calculation was developed
by Engineering as a contingency.
On February 16, 2012, CR PLP-2012-01091 was generated by Operations to perform an
operability evaluation on the SIRWT, since it was the suspected source of the catacombs
leakage. When correlating the tritium levels in the SIRWT to the catacombs in-leakage tritium
levels, the correlation was sufficient to suspect SIRWT leakage. The CRs operability
determination concluded that the SIRWT was operable, using the engineering contingency
evaluation developed the previous day.
Repairs to the SIRWT were completed during the March 2012 refueling outage; however, after
the outage, additional leakage was identified from the SIRWT and monitored using the leakage
acceptance criteria developed in the previous SIA calculation. Leakage progressively worsened
until July 2012 when the plant was shut down to conduct additional repairs. The tank floor was
replaced during the 2013 fall Refueling Outage.
Based on the evidence gathered in the OI investigation, it appears that four individuals willfully
violated NRC requirements by failing to follow site corrective action procedures, when it became
known to the individuals that the leakage was most likely originating from the SIRWT.
Specifically, these inactions caused the licensee to be in apparent willful violation of Title 10 of
the Code of Federal Regulations, Part 50, Appendix B, Criterion V, for their failure to follow
procedure EN-LI-102, Corrective Action Process. Two other apparent violations were also
Factual Summary of NRC Investigation
3
identified. The first was the failure to follow procedure EN-OP-104, Operability Determination
Process. Specifically, the licensee failed to perform an adequate operability determination on
an active leak from the catacombs ceiling and again on an active leak from a SIRWT piping
flange. The second apparent violation was for the licensees failure to meet the requirement of
TS surveillance requirement Section SR 3.0.3. Specifically, when the licensee identified
surveillance procedure RT-71M, the surveillance to conduct ASME inservice pressure tests of
the SIRWT and associated piping, had not been performed within its required schedule, the
licensee failed to perform the test within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or perform a risk evaluation to complete the
surveillance at a later date.
A. Vitale
3
If you have any questions concerning this matter, please contact Mr. John Jandovitz of my staff
at 630-829-9763.
Sincerely,
/RA Julio Lara Acting for/
Patrick L. Louden, Director
Division of Reactor Projects
Docket No. 50-255
License No. DPR-20
Enclosure:
Factual Summary of NRC Investigation
cc: Distribution via LISTSERV
DISTRIBUTION:
Kimyata MorganButler
RidsNrrPMPalisades Resource
RidsNrrDorlLpl3-1 Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
DRPIII
DRSIII
Bill Dean
Trish Holahan
John Jandovitz
ROPassessment.resource@nrc.gov
ADAMS Accession Number ML16053A472
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
RIII
RIII
NAME
JJandovitz:tr/bw/
mz
RSkokowski
JLara for
PLouden
DATE
02/22/16
02/22/16
02/22/16
OFFICIAL RECORD COPY