ML19294A287
| ML19294A287 | |
| Person / Time | |
|---|---|
| Site: | Palisades  (DPR-020) |
| Issue date: | 10/21/2019 |
| From: | Karla Stoedter NRC/RGN-III/DRS/EB2 |
| To: | Arnone C Entergy Nuclear Operations |
| References | |
| IR 2019010 | |
| Download: ML19294A287 (11) | |
See also: IR 05000255/2019010
Text
October 21, 2019
Mr. Charles Arnone
Vice President, Operations
Entergy Nuclear Operations, Inc.
27780 Blue Star Memorial Highway
Covert, MI 49042-9530
SUBJECT:
PALISADES NUCLEAR PLANT: DESIGN BASIS ASSURANCE INSPECTION
(PROGRAMS) INSPECTION REPORT 05000255/2019010
Dear Mr. Arnone:
On September 12, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Palisades Nuclear Plant and discussed the results of this inspection with
Mr. Darrell Corbin and other members of your staff. The results of this inspection are
documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding
involved a violation of NRC requirements. We are treating this violation as a non-cited violation
(NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or significance or severity of the violation documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector
at Palisades.
This letter, its enclosure, and your response (if any) 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/
Karla K. Stoedter, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No. 05000255
License No. DPR-20
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE RIII/EB2
RIII/EB2
NAME
NFeliz-Adorno
KStoedter
DATE
10/21/19
10/21/19
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000255
License Number:
Report Number:
Enterprise Identifier: I-2019-010-0053
Licensee:
Entergy Nuclear Operations, Inc.
Facility:
Palisades Nuclear Plant
Location:
Covert, MI
Inspection Dates:
August 18, 2019 to September 12, 2019
Inspectors:
N. Feliz-Adorno, Senior Reactor Inspector
M. Greenleaf, Reactor Inspector
M. Jones, Reactor Inspector
Approved By:
Karla K. Stoedter, Chief
Engineering Branch 2
Division of Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting a design basis assurance inspection (programs) inspection at
Palisades Nuclear Plant in accordance with the Reactor Oversight Process. The Reactor
Oversight Process is the NRCs program for overseeing the safe operation of commercial
nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more
information.
List of Findings and Violations
Failure to Environmentally Qualify Electric Equipment Inside Containment for the Most Severe
Chemical Composition
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
The inspectors identified a Green finding and an associated Non-Cited Violation of Title 10 of
the Code of Federal Regulations, Part 50.49, "Environmental Qualification of Electric
Equipment Important to Safety for Nuclear Power Plants," Paragraph (e)(3), for the licensee's
failure to base the qualification of electric equipment inside containment on a chemical
composition that was at least as severe as that resulting from the most limiting mode of plant
operation. Specifically, the most severe chemical composition expected inside containment
would result from the containment spray injection mode. However, the qualification of electric
equipment inside containment was based on the less severe chemical composition of the
containment spray recirculation mode, which is borated water from the injection mode
neutralized by the sodium tetraborate located inside of containment.
Additional Tracking Items
None.
3
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21N - Design Bases Assurance Inspection (Programs)
The inspectors evaluated the environmental qualification program implementation through the
sampling of the following components:
Select Sample Components to Review - Risk Significant/Low Design (Inside/Outside
Containment) (IP Section 02.01) (6 Samples)
(1)
Shutdown Cooling Suction Valve MO-3015
(2)
Low Pressure Safety Injection Pump P-67A Motor
(3)
Cable 19-I29A
(4)
Narrow Range Pressure Transmitter PT-0104B
(5)
Component Cooling Water Heat Exchanger Control Valve Pilot Valve SV-0821
(6)
Shutdown Cooling Heat Exchanger Inlet Valve SV-0937
Select Sample Components to Review - Primary Containment (Inside Containment)
(IP Section 02.01) (1 Sample)
(1)
Power Operated Relief Valve PRV-1042B
INSPECTION RESULTS
Failure to Environmentally Qualify Electric Equipment Inside Containment for the Most
Severe Chemical Composition
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
None (NPP)
The inspectors identified a Green finding and an associated Non-Cited Violation of Title 10 of
the Code of Federal Regulations (10 CFR), Part 50.49, Environmental Qualification of
Electric Equipment Important to Safety for Nuclear Power Plants, Paragraph (e)(3), for the
licensee's failure to base the qualification of electric equipment inside containment on a
chemical composition that was at least as severe as that resulting from the most limiting
mode of plant operation. Specifically, the most severe chemical composition expected inside
containment would result from the containment spray injection mode. However, the
qualification of electric equipment inside containment was based on the less severe chemical
4
composition of the containment spray recirculation mode, which is borated water from the
injection mode neutralized by the sodium tetraborate located inside of containment.
Description: The containment spray system has two modes of operation. During the initial
injection mode, the containment spray system draws borated water from the safety injection
and refueling water tank and sprays it inside containment to alleviate pressure during large
break loss of coolant accidents and to scrub radioactive particles. The sprayed borated water
collects at the containment sump where it is neutralized by mixing with sodium tetraborate,
which is pre-staged in baskets inside of containment. The containment spray system
transitions to its recirculation mode of operation after depleting the tank, drawing suction from
the containment sump and spraying the recirculated solution inside containment to continue
scrubbing radionuclides.
The most severe chemical composition expected inside containment would result from the
containment spray initial injection mode. However, in 2004, the licensee discovered the
environmental qualification of electric equipment inside of containment was based on the
chemical effects of the containment spray recirculation mode. This condition was captured in
the Corrective Action Program as CR-PLP-2004-1616. As a result, the licensee evaluated
the effects of the initial spray pH. However, the inspectors noted the licensee did not
evaluate the chemical compatibility of the initial spray with each exposed material composing
the electric equipment required to be environmentally qualified. During this inspection period,
the licensee determined this concern affected 17 systems such as low pressure injection,
high pressure injection, and shutdown cooling.
Corrective Actions: The licensee was still evaluating its planned corrective actions at the time
of the inspection. However, the continued non-compliance does not present an immediate
safety concern because the licensee reasonably determined the affected equipment
remained capable of performing their safety functions. Specifically, the licensee identified all
material in environmentally qualified components inside containment and located an
evaluation from a similar nuclear power plant addressing boric acid interaction with all but one
of the materials located inside of Palisades containment. The licensee determined this
evaluation reasonably demonstrated the evaluated materials were compatible with the initial
borated water spray. Similarly, the licensee located industry information for the material that
was not addressed by the evaluation (i.e., chlorinated polyethylene) and reasonably
determined it was compatible with the initial borated water spray.
Corrective Action References: CR-PLP-2019-3692, CR-PLP-2019-
3693, CR-PLP-2019-3694, CR-PLP-2019-3695, CR-PLP-2019-3697, CR-PLP-2019-3698,
CR-PLP-2019-3699, CR-PLP-2019-3700, CR-PLP-2019-3702, CR-PLP-2019-3703,
CR-PLP-2019-3704, CR-PLP-2019-3705, CR-PLP-2019-3706, CR-PLP-2019-3707,
CR-PLP-2019-3708, CR-PLP-2019-3709, and CR-PLP-2019-3710.
Performance Assessment:
Performance Deficiency: The failure to base the qualification of electric equipment inside
containment on a chemical composition that was at least as severe as that resulting from the
most limiting mode of plant operation was contrary to 10 CFR 50.49(e)(3) and was
performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Equipment Performance attribute of the Mitigating
Systems cornerstone and adversely affected the cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to prevent
5
undesirable consequences. Specifically, the failure to demonstrate qualification of electric
equipment inside containment for the most severe chemical effects does not ensure the
equipment would be capable of providing its accident mitigating functions.
Significance: The inspectors assessed the significance of the finding using Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. The finding screened as of
very low safety significance (Green) because it did not result in the loss of operability or
functionality of mitigating systems. Specifically, the licensee reasonably determined the
affected equipment remained capable of performing their safety functions based on an
evaluation from a similar nuclear power plant and industry information addressing boric acid
interaction with the affected materials.
Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance.
Enforcement:
Violation: Title 10 CFR 50.49(e)(3) requires The electric equipment qualification program
must include and be based on, in part, Chemical Effects, and that The composition of
chemicals used must be at least as severe as that resulting from the most limiting mode of
plant operation (e.g., containment spray, emergency core cooling, or recirculation from
containment sump).
Contrary to the above, as of September 16, 2019, the licensees electric equipment
qualification program failed to include and be based on the chemical effects of the most
severe composition of chemicals resulting from the most limiting mode of plant
operation. Specifically, the most severe chemical composition expected inside containment
would result from the containment spray injection mode. However, the qualification of electric
equipment inside containment was based on the chemical composition of the containment
spray recirculation mode, which was less severe due to the borated water from the injection
mode being neutralized by the sodium tetraborate located inside of containment.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On September 12, 2019, the inspectors presented the design basis assurance
inspection (programs) inspection results to Mr. Darrell Corbin and other members of the
licensee staff.
6
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21N Corrective Action
Documents
CR-PLP-2004-
01616
PRE-NRC SSDI, RB Spray pH Considerations Title: FSA
Pre-NRC SSDI, RB Spray pH Considerations
03/02/2004
CR-PLP-2015-
00583
EQ replacement dates occur before 1R24 begins
02/19/2015
CR-PLP-2017-
01007
VOP-3015 Gear Box Grease Degraded
03/18/2017
CR-PLP-2018-
00238
EMA-1206 oil was identified with higher than expected
viscosity
01/12/2018
Corrective Action
Documents
Resulting from
Inspection
CR-HQN-2019-
01982
The NRC identified that EN-MA-141, Attachment 1 does not
contain any reference to potential EQ implications during
grease evaluation
09/06/2019
CR-PLP-2019-
03371
Boric acid leak on P-67A
08/27/2019
CR-PLP-2019-
03409
Corrective action document written for unsat oil viscosity for
EMA-1206 did not address EQ or past-operability
08/29/2019
CR-PLP-2019-
03463
Unable to locate auxiliary feedwater pump P-8C motor oil
analysis for 2013
09/04/2019
CR-PLP-2019-
03464
Auxiliary feedwater pump P-8C had unsat oil viscosity
09/04/2019
CR-PLP-2019-
03559
DBD-7.01 contain misleading information regarding what
containment spray density is required for EQ Qualification of
equipment inside containment
09/10/2019
CR-PLP-2019-
03692
Qualification of CIS did not consider chemical effects
09/16/2019
CR-PLP-2019-
03693
Qualification of CLP did not consider chemical effects
09/16/2019
CR-PLP-2019-
03694
Qualification of CRS did not consider chemical effects
09/16/2019
CR-PLP-2019-
03695
Qualification of CSW did not consider chemical effects
09/16/2019
CR-PLP-2019-
03697
Qualification of CVC did not consider chemical effects
09/16/2019
7
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-PLP-2019-
03698
Qualification of ESS did not consider chemical effects
09/16/2019
CR-PLP-2019-
03699
Qualification of FWS did not consider chemical effects
09/16/2019
CR-PLP-2019-
03700
Qualification of HPI did not consider chemical effects
09/16/2019
CR-PLP-2019-
03702
Qualification of LPI did not consider chemical effects
09/16/2019
CR-PLP-2019-
03703
Qualification of MFW did not consider chemical effects
09/16/2019
CR-PLP-2019-
03704
Qualification of NMS did not consider chemical effects
09/16/2019
CR-PLP-2019-
03705
Qualification of PCS did not consider chemical effects
09/16/2019
CR-PLP-2019-
03706
Qualification of PZR did not consider chemical effects
09/16/2019
CR-PLP-2019-
03707
Qualification of RIA did not consider chemical effects
09/16/2019
CR-PLP-2019-
03708
Qualification of SDC did not consider chemical effects
09/16/2019
CR-PLP-2019-
03709
Qualification of SIT did not consider chemical effects
09/16/2019
CR-PLP-2019-
03710
Qualification of VAS did not consider chemical effects
09/16/2019
Drawings
VEN-E48
Install Conduit/Component Seals
4
Engineering
Changes
Equivalent Replacement and/or Substitution of Nebula EP0
Grease with MOV Long Life Grade 0 Grease
0
Engineering
Evaluations
E48-EMA-01
EQ File - Louis-Allis Model COGX Motors
12
E48-EMA-07
EQ File - Reliance Electric 2300 Vac motor
10
E48-SV-01
EQ file: Automatic Switch Company (ASCO) Model 206-381
and
NP 8320 solenoid valves
18
E48-VOP-03
EQ File - Limitorque Valve Operators with RH Motor
Insulation Systems Located in Containment
18
8
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
E48-XMTR-01
EQ File: Rosemount Series 1153B and 1153D Transmitters
8
E48-XMTR-02
EQ File: Rosemount Series 1154 Transmitters
8
Miscellaneous
DBD-7.01
Electrical Equipment Qualification Program
10
DBD-7.02
EQ Master Equipment List
14
E48-CABLE-19
Samuel Moore EPDM Insulated and Hypalon Jacketed
Instrumentation Cable
13
E48-SV-08
ASCO Model NP 8316 and NP 8321 Solenoid Valves
18
E48-SV-24
Target Rock Power Operated Relief Valves for Pressurizer
Pressure
7
Aging, Loss-of-Coolant Accident (LOCA), and High Potential
Testing of Damaged Cables
04/01/1994
Procedures
Lubrication Program
1
Predictive Maintenance Program
8
Limitorque Valve Operator Model SMB/SB/SBD-000
Through 5 MOV and HBC Periodic Inspection
13
Loss of Coolant Accident Recovery
24
MSE-E-41
Refurbishment of Limitorque Type SMB-0 Though SMB-3
Actuators
10
SEP-EQ-PLP-001 Environmental Qualification of Electrical Equipment
2
SEP-LUB-PLP-
001
Lubrication Analysis and Monitoring
2
WI-SPS-E-02
Insulation Resistance Testing of Electrical Equipment
9
Self-Assessments LO-PLPLO-2019-
00013
Environmental Qualification (EQ) Program Assessment
05/28/2019
Work Orders
PRV-1042B; VT-2 NOP/NOT (CR-PLP-2011-00191)
01/31/2011
MO-3015 Burnish Torque Switch Contacts
02/09/2014
PRV-1042B; Replace PRV-1042B EC-20196
08/19/2011
PRV-1043B; Replace PRV-1043B EC-20196
11/08/2010
- EEQ* REPLACE SV-0821
01/27/2014
EEQ Maint. - PM VOP-3015
02/09/2014
RI-59C - LTOP Pessure Transmitter Cals
10/19/2015
PT-0104B, EEQ Replace Transmitter
09/28/2015
P-67A MTR/PMP Oil Change
04/08/2016
9
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
EEQ Maint.-PM VOP-3009
06/28/2016
EEQ - EMA-1206 LPSI Pump P-67A Motor
03/27/2017
EEQ Maint. - PM VOP-3015
03/18/2017
EEQ Maint.-PM VOP-3012
07/25/2017
EEQ - EMA-1206 LPSI Pump P-67A Motor
09/18/2018
Thermalscan Equip.- P-67A Motor/Breaker
06/20/2018
RI-59C - LTOP Pressure Transmitter Cals
11/08/2018
QO-2X - Recirculation Actuation System
12/19/2014
P-67A MTR/PMP Oil Change
03/25/2019
Thermalscan Equip.- P-67A Motor/Breaker
06/18/2019