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17 Palisades Nuclear Plant, Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team): Inspection Report 05000255/2017007
	ML17258A081
Person / Time
Site:	Palisades
Issue date:	09/13/2017
From:	Jamie Benjamin; NRC/RGN-III/DRS/EB2
To:	Arnone C; Entergy Nuclear Operations
References
	IR 2017007
	Download: ML17258A081 (7)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

September 13, 2017

Mr. Charles Arnone

Vice President, Operations

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANT, REQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM):

INSPECTION REPORT 05000255/2017007.

Dear Mr. Arnone:

On October 30, 2017, the U. S. Nuclear Regulatory Commission (NRC) will begin a Triennial

Baseline Design Basis Assurance Inspection at the Palisades Nuclear Plant. This inspection

will be performed in accordance with NRC Baseline Inspection Procedure 71111.21M and

adjusted for the stations current plan to transition to decommissioning as allowed by Inspection

Manual Chapter 2515. The inspection samples to be reviewed during this inspection are

skewed toward decommissioning activities.

The Design Bases Assurance Inspection focuses on the design, maintenance, and operation of

risk significant components with low margin, or associated with an accident scenario, or a

specific system. The inspection also monitors the implementation of modifications to structures,

systems, and components as modifications to one system may also affect the design bases and

functioning of interfacing systems as well as introduce the potential for common cause failures.

The specific components and modifications to be reviewed during this baseline inspection will

be identified as part of the preparation for the inspection and finalized during the in-office

preparation week that occurs prior to the first onsite inspection week. In addition, operating

experience issues, associated with the component samples, will also be selected for review.

The inspection team may request scenarios to be performed on the simulator. This request

would require support from your simulator staff to validate scenarios, simulator time, and a crew

to perform the actions which would most likely occur during the second onsite week. The team

will work closely with your staff early on during the inspection process to ensure this activity can

be accomplished with minimal impact.

The inspection will include two weeks onsite. The inspection team will consist of four NRC

inspectors and two contractors. The current inspection schedule is as follows:

Offsite preparation: October 23-27, 2017.

Onsite weeks: October 30-November 3, 2017; and

November 13-17, 2017.

C. Arnone -2-

Experience with previous baseline design/modification inspections of similar depth and length

has shown that this type of inspection is extremely resource intensive, both for the NRC

inspectors and the licensee staff. In order to minimize the inspection impact on the site and to

ensure a productive inspection for both parties, we have enclosed a request for information

needed for the inspection.

It is important that all of these documents are up-to-date and complete in order to minimize the

number of additional documents requested during the preparation and/or the onsite portions of

the inspection. Insofar as possible, this information should be provided electronically to the lead

inspector.

The lead inspector for this inspection is Jamie Benjamin. If there are any questions about the

inspection or the material requested in the enclosure, please contact the lead inspector at

630-829-9747 or via e-mail at 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.

This letter and its enclosure will be made available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in

accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Jamie Benjamin, Senior Reactor Engineer

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-255

License No. DPR-20

Enclosure:

Design Bases Assurance Inspection

Document Request

cc: Distribution via LISTSERV

C. Arnone -3-

Letter to Charles Arnone from Jamie Benjamin dated September 13, 2017

SUBJECT: PALISADES NUCLEAR PLANT, REQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM):

INSPECTION REPORT 05000255/2017007.

DISTRIBUTION:

Jeremy Bowen

RidsNrrPMPalisades Resource

RidsNrrDorlLpl3

RidsNrrDirsIrib Resource

Cynthia Pederson

DRPIII

DRSIII

ADAMS Accession Number ML17258A081

OFFICE RIII RIII RIII RIII

NAME JBenjamin:cl

DATE 09/13/17

OFFICIAL RECORD COPY

DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

Inspection Report: 05000255/2017007

Inspection Dates: October 30-November 3; and

November 13-17.

Inspection Procedure: IP 71111.21M, Design Bases Assurance Inspection (Team)

Lead Inspector: Jamie Benjamin, Senior Reactor Engineer, DRS

630-829-9747

Jamie.Benjamin@nrc.gov

Selected components:

Spent fuel pool

Spent fuel pool leakage detection

Spent fuel pool neutron absorber

Spent fuel pool cooling water pumps

Spent fuel pool cooling water heat exchanger

Spent fuel pool cooling water component electrical supply

Control room ventilation dampers

Control room ventilation fans

Control room ventilation electrical supply

Main steam isolation valves (LERF sample)

I. Information Requested (for the above selected components) to be available to the

team lead by October 16, 2017:

This information should be separated for each selected component or modification,

especially if provided electronically (e.g., folder with component or modification name

that includes calculations, condition reports, maintenance history, etc.).

1. List of condition reports (corrective action documents) associated with each of

the selected components for the last 6 years.

2. The maintenance history (corrective, preventive, and elective) associated with

each of the selected components for the last 10 years. Identify frequency of

preventive maintenance activities.

Enclosure

DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

3. Copies of calculations associated with each of the selected components (if not

previously provided), excluding data files. Please review the calculations and

also provide copies of important referenced material (such as drawings,

engineering requests, and vendor letters).

4. System Health Reports, System Descriptions, Design Basis Documents, and/or

Training Lesson Plans associated with each of the selected components.

5. A list of modifications, including equivalency evaluations and setpoint changes,

associated with each of the selected components. This list should include a

descriptive paragraph on the purpose of the modification. Please ensure this list

only includes design completed (not canceled) modifications.

6. Copies of operability evaluations (open/closed for last 3 years) associated with

each of the selected components and plans for restoring operability, if applicable.

7. Copies of selected operator work-around evaluations associated with each of the

selected components and plans for resolution, if applicable.

8. Copies of any open temporary modifications associated with each of the selected

components, if applicable.

9. Trend data on the selected electrical/mechanical components performance for

last 3 years (For example, pumps performance including in-service testing, other

vibration monitoring, oil sample results, etc., for valves: stroke time and leak rate

results, diagnostic trend data, etc.).

10. Provide copies of the normal and abnormal operating procedures associated with

the selected components and selected scenarios.

11. List of time critical or risk significant operator actions associated with

components. Identify those actions that do not have job performance measures.

12. Copy of latest completed tests and surveillances for each component, for

example:

a. Pumps: comprehensive test, quarterly test, flow balance, etc.

b. Valves: stroke time testing, diagnostic testing, leak testing, interlocks, etc.

c. Heat Exchangers/Room Coolers: thermal performance, clean/inspect, fan

flows, etc.

d. Components: Technical Specification surveillances.

e. Acceptance criteria basis calculations should also be included.

13. A copy of any internal/external self-assessments and associated corrective

action documents generated in preparation for the inspection.

14. A copy of engineering/operations related audits completed in the last 2 years.

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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

15. List of permanent plant modifications to structures, systems, and components

that are field work complete in the last 3 years. (For the purpose of this

inspection, permanent plant modifications include permanent: plant changes,

design changes, set point changes, equivalency evaluations, suitability analyses,

and commercial grade dedications.) The list should contain the number of each

document, the title, the revision (or date), and the affected system.

16. A list of calculation changes that have been issued for use in the last 3 years.

17. Copies of procedures addressing the following: modifications, design changes,

set point changes, equivalency evaluations or suitability analyses, commercial

grade dedications, and post-modification testing.

18. A list of corrective action documents (open and closed) in the last 3 years that

address permanent plant modifications issues, concerns, or processes. These

documents should also include the corrective action documents associated with

the modification implementation.

19. Electronic copies of Updated Final Safety Analysis Report, Technical

Specifications, Technical Specifications Bases, and Technical Requirements

Manual.

20. Electronic copies of Updated Final Safety Analysis Report, Technical

Specifications, Technical Specifications Bases, and Technical Requirements

Manual.

21. Major one line electrical drawings (ac and dc) and key diagrams (paper copies).

22. Electronic copy of Piping and Instrumentation Drawings (if available).

23. Site top ten issues list.

24. Electronic copy of the site Individual Plant Examination of External Events, if

available.

25. Current management and engineering organizational chart.

II. Additional Information to be Provided on October 30, 2017, Onsite (for final

selected components and modifications):

1. During the in-office preparation activities, the team will be making final selections

and may identify additional information needed to support the inspection. The

lead inspector will provide a list of the additional information needed during the

week of October 23, 2017.

2. Schedule of any testing/maintenance activities to be conducted on the selected

components during the two onsite inspection weeks.

III. Information Requested to be Provided Throughout the Inspection

1. Copies of any corrective action documents generated as a result of the teams

questions or queries during this inspection.

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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

2. Copies of the list of questions submitted by the team members and the

status/resolution of the information requested (provide daily by 2:00 p.m.

during the inspection to each team member).

3. One complete set of Piping and Instrumentation Drawings (paper copies).

4. Reference materials. (make available if needed during all onsite weeks):

a. Individual Plant Examination/Probabilistic Risk Assessment report;

b. Procurement documents for components and modifications selected

(verify retrievable);

c. Plant procedures (normal, abnormal, emergency, surveillance, etc.); and

d. Vendor manuals.

If you have questions regarding the information requested, please contact the lead inspector.

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ML17258A081

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