IR 05000255/2024012
| ML24317A041 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/12/2024 |
| From: | April Nguyen NRC/RGN-III/DORS |
| To: | Mlynarek M Holtec Decommissioning International |
| References | |
| IR 2024012 | |
| Download: ML24317A041 (1) | |
Text
SUBJECT:
PALISADES NUCLEAR PLANT - RESTART INSPECTION REPORT 05000255/2024012
Dear Mike Mlynarek:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed inspections at the Palisades Nuclear Plant. The enclosed inspection report documents these inspection results, which the inspectors discussed on November 7, 2024, with you and other members of your staff.
One Severity Level IV violation is documented in this report. 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 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, HQ; the Director, Office of Enforcement; and the NRC Lead, Palisades Restart Team.
On June 13, 2022, Palisades ceased permanent power operations and subsequently removed all fuel from the reactor, as detailed in the letter from Entergy to the NRC, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, (ADAMS Accession No. ML22164A067). On September 28, 2023, Holtec Decommissioning International, LLC (Holtec) submitted a letter to the NRC requesting exemptions from certain portions of the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(2) to pursue the potential reauthorization of power operations at Palisades (ADAMS Accession No. ML23271A140). The NRCs initial acceptance to review Palisades request for exemptions was documented in ADAMS at Accession No. ML23291A440 on November 3, 2023.
November 12, 2024 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, April M. Nguyen, Lead Palisades Restart Team Division of Operating Reactor Safety Docket No. 05000255 License No. DPR-20
Enclosure:
As stated
Inspection Report
Docket Number:
05000255
License Number:
Report Number:
Licensee:
Holtec Decommissioning International, LLC
Facility:
Palisades Nuclear Plant
Location:
Covert, MI
Inspection Dates:
July 01, 2024 to September 30, 2024
Inspectors:
B. Bergeon, Senior Operations Engineer
E. Fernandez, Senior Reactor Inspector
A. Hobbs, Reactor Inspector (observer)
V. Myers, Senior Health Physicist
J. Park, Reactor Inspector
A. Shaikh, Senior Reactor Inspector
J. Winslow, Senior Project Engineer
Approved By:
April M. Nguyen, Lead
Palisades Restart Team
Division of Operating Reactor Safety
SUMMARY
This report covers announced inspections completed by regional inspectors.
The U.S. Nuclear Regulatory Commission (NRC) performed inspections of the licensees activities to ensure the adequate protection of workers and the public under the radiation safety cornerstone and to assess requalification training and evaluation of previously licensed operators under the reactor safety cornerstones.
List of Findings and Violations
Locked High Radiation Area Identified During Chemical Decontamination Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000255/2024012-01 Open/Closed Not Applicable 71124.01 A self-revealed Severity Level IV Non-Cited Violation (NCV) of Technical Specification (TS) 5.7.2 was identified when the licensee failed to post and control an area meeting Locked High Radiation Area (LHRA) conditions.
Additional Tracking Items
None.
PLANT STATUS
The Palisades Nuclear Plant ceased power operations and subsequently removed all fuel from the reactor, as certified in a letter to the NRC on June 13, 2022. On September 28, 2023, Holtec Decommissioning International, LLC (Holtec) submitted a letter to the NRC requesting exemptions from certain portions of the requirements of 10 CFR 50.82(a)(2) to pursue the potential reauthorization of power operations. The NRC is conducting inspections to evaluate and assess the licensees activities for potential restoration to an operational status.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the referenced 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.
REACTOR SAFETY
CORNERSTONES 71111.08P - Inservice Inspection Activities (PWR)
Reactor Pressure Vessel (03.01)
From July 24, 2024, to August 20, 2024, the inspectors observed and verified Holtec Palisades nondestructive examination (NDE) activities of the Reactor Pressure Vessel conducted in accordance with the requirements of the ASME Code Section XI and MRP-227, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, Revision 1-A. The purpose of these inspections was to verify that the reactor coolant system boundary, reactor vessel internals, and risk-significant piping system boundaries are appropriately monitored for degradation. The NRC inspectors also verified that the examination results were thoroughly reviewed and appropriately evaluated, and that required corrective actions to address identified indications and defects will be appropriately implemented. During this quarter, Holtec Palisades completed the NDE activities and evaluation of the data. Further NRC inspections will occur when corrective actions are implemented.
The inspectors verified that the following nondestructive examination activities were conducted appropriately per the ASME Code or required standard, and that any potential indications and defects were identified and evaluated at the proper thresholds:
MRP 227 Reactor Internals Exams (July 29, 2024, through August 12, 2024)
- Ultrasonic Testing (UT) of Core Shroud Bolts
- Visual Examination (VT) of Core Shroud Plates, Core Support Plate and Fuel Alignment Plate ASME Section XI 10 Year ISI (August 3, 2024, through August 19, 2024)
- Phased Array Ultrasonic Testing (PAUT) of Clevis Bolts
- Visual examination (VT) of the interior surface of the vessel and supports Steam Generator Activities (03.04)
From August 26, 2024, to September 6, 2024, the inspectors observed and verified Holtec Palisades Steam Generator (SG) inspection activities conducted as described in the operating plant Technical Specification Requirements and EPRI Steam Generator Management Program guidance. Of note, the operating plant Technical Specifications are currently under review by the NRC. If approved, these will be implemented with the operating plant licensing basis documents if the plant goes back to an operational status. Using this as guidance for inspections now will ensure that all Technical Specification requirements will be met prior to resumption of power operations. The purpose of these inspections is to verify that the SG tube integrity is appropriately monitored and any potential mechanisms that could lead to primary-to-secondary tube leakages are addressed. The NRC inspectors verified that the inspections were properly conducted per the regulatory requirements and guidance documents, that the inspection results were thoroughly reviewed and appropriately evaluated, and that required corrective actions to address identified indications were appropriately implemented.
The inspectors also reviewed Holtec Palisades loose parts inspections, foreign material controls, and chemistry controls for the SGs. During this quarter, Holtec Palisades completed the inspection activities and were in the process of evaluating the data. Further NRC inspections will review the data analysis and any corrective actions as they are implemented.
The inspectors verified that the following inspection and cleanliness activities were conducted appropriately, and that any potential indications were identified and evaluated at the proper thresholds:
- Eddy Current Testing (ET) of 100% of Steam Generator Tubes in SG A
- Eddy Current Testing (ET) of 100% of Steam Generator Tubes in SG B
- Foreign Objects Search and Retrieval (FOSAR) for SG A and SG B Preliminary results of the Steam Generator inspections identified a large number of SG tubes with indications that required further analysis and/or repair. This information is documented in Preliminary Notification, PNO-III-24-002, PRELIMINARY RESULTS OF STEAM GENERATOR INSPECTIONS AT PALISADES NUCLEAR PLANT, dated September 18, 2024, (ADAMS Accession No. ML24262A092). Also, preliminary results were discussed between Holtec and NRC staff in a conference call held on September 3, 2024. This call is documented in the letter, PALISADES NUCLEAR PLANT - SUMMARY OF CONFERENCE CALL REGARDING STEAM GENERATOR TUBE INSPECTIONS, dated October 1, 2024 (ADAMS Accession No. ML24267A296).
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Training/Examinations (03.02)
On September 17, 2024, an NRC inspector conducted an inspection of Holtec Palisades licensed operator requalification training program. This inspection reviewed the conduct of requalification training activities in the main control room simulator and assessed the Palisades training staffs ability to evaluate the performance of their licensed operators. The NRC inspector observed the licensed operator crews performance during a complex casualty graded scenario and the training staffs post-scenario assessment of the crew.
No issues of concern were identified during the inspectors observation of the requalification training activities. Overall, operations training effectively evaluated the operating crew and provided effective feedback to continue to improve the performance of the operating crew.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (03.01)
From June 17, 2024, to July 12, 2024, the inspectors evaluated temporary modifications to the primary coolant system (PCS) and the auxiliary building, 649' elevation, in support of the PCS decontamination project. The purpose of this inspection was to verify that the temporary modifications did not degrade or adversely affect the safety functions or structural integrity of the PCS and auxiliary building structure. The inspectors reviewed drawings, calculations, and evaluations of the temporary system used for the decontamination activity; performed walkdowns of the system once installed to verify appropriate installation; and observed system testing to verify no primary system leakage or adverse impacts to the normal operation of the PCS. The inspectors also verified the PCS was returned to its normal configuration after the temporary system was uninstalled.
No issues of concern were identified during the inspectors review of the temporary modifications for this project.
RADIATION SAFETY
CORNERSTONE
71124.01 - Radiological Hazard Assessment and Exposure Controls
From July 1, 2024, to July 11, 2024, the inspectors observed and evaluated Holtec Palisades radiological assessment and controls for the PCS decontamination project. The purpose of these inspections was to evaluate the stations radiological hazards assessments, instructions to radiological workers, radiation protection access and controls to the areas affected by the project, and coverage for workers performing in-field activities for the project. The inspectors verified that the radiation protection program was appropriately implemented for the project as required by Technical Specifications, regulations, and station procedures.
The PCS decontamination activity was a process that chemically shocked the primary system piping to release radiologically contaminated build-up on the inside of the piping. Once released from the piping, the contaminated water was then sent through a series of resin beds to remove the contamination. This process was being conducted to reduce the overall contamination and radiation hazards in the system and to reduce worker dose for future activities. This was a first-time evolution for this process at Palisades.
Prior to initiation of the chemical decontamination process, the inspectors reviewed documents related to planning and control of the evolution. This included items such as system schematics, system operating procedures, planned radiological survey points, shielding packages, radiological posting plans, and radiation work permits and As-Low-As-Reasonably-Achievable (ALARA) plans. In addition, the inspectors performed several walkdowns of the system, attended pre-job briefings, and observed radiation protection staff performing posting and control changes to potentially affected areas of the plant.
During the chemical injection and subsequent clean-up phases, the inspectors continued to provide oversight of the evolution. This included various walkdowns to validate radiological postings and controls, observations of dose rates being collected throughout the site via remote monitoring capabilities, and observations of radiation protection technician job coverage.
One SLIV NCV was identified during these inspection activities, which is described in detail in the inspection results section below. Additionally, the inspectors shared an observation of note with the Palisades team during the exit meeting. This is documented in more detail in the results section below.
INSPECTION RESULTS
Locked High Radiation Area Identified During Chemical Decontamination Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000255/2024012-01 Open/Closed Not Applicable 71124.01 A self-revealed Severity Level IV Non-Cited Violation (NCV) of Technical Specification (TS) 5.7.2 was identified when the licensee failed to post and control an area meeting Locked High Radiation Area (LHRA) conditions.
Description:
On July 6, 2024, Holtec Palisades initiated recirculation of clean water through the primary coolant system (PCS) chemical decontamination skid to test for leaks prior to commencing chemical injection. During this time, radiological surveys conducted by a radiation protection technician in the auxiliary building 649' elevation identified a hot spot on a piece of skid equipment that resulted in dose rates of 2 rem/hr at 30 cm from the source. At that time, the auxiliary building 649' elevation was controlled as a radiation area. Also, radiation protection (RP) staff had administratively required that radiation protection technicians monitor radiological conditions any time personnel were in this area. The licensee had a pre-established posting plan for the PCS chemical decontamination activity that included posting this location as a Locked High Radiation Area (LHRA). However, this posting plan was to be initiated prior to chemical injection, which had not occurred yet. Upon identification of the LHRA conditions, the licensee guarded the area and subsequently implemented the pre-established posting plan for all areas potentially affected by the PCS decontamination activities. This included posting and controlling this area as an LHRA.
Corrective Actions: The licensee immediately guarded the area and subsequently posted and controlled the area as an LHRA.
Corrective Action References: PAL-02617 and PAL-03310
Performance Assessment:
None
Enforcement:
Severity: The inspectors determined this was a SLIV NCV in accordance with the enforcement policy. Specifically, the failure to post and control the LHRA was of more than minor concern but resulted in relatively inappreciable potential safety consequences.
Violation: TS 5.7.2 requires, in part, that entryways into High Radiation Areas (HRAs) with dose rates greater than 1.0 rem/hr at 30 centimeters from the radiation source be conspicuously posted as an HRA and be provided with a locked or continuously guarded door or gate that prevents unauthorized entry. Contrary to the above, on July 6, 2024, the licensee failed to conspicuously post the entryway to an area with dose rates greater than 1.0 rem/hr at 30 centimeters from the radiation source as an HRA and failed to lock or continuously guard the entryway to prevent unauthorized entry.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Chemical Decontamination Process of the Primary Coolant System (Occupational Radiation Safety Cornerstone)71124.01 On July 7-10, 2024, Palisades performed a chemical decontamination process of the primary coolant system (PCS). The process involved the injection of mixed chemicals into the PCS to remove radiological contamination from piping to reduce worker dose for future activities. The inspectors observed the system setup and connections, initial radiation protection postings, initial chemical injection, and system cleanup. During the process, three of the units four primary coolant pumps were operated.
Overall, the inspectors observed that the activity was done safely. They noted there were several personnel new to the station or new to their roles and saw some instances where communications regarding the activities could have been clearer. An example of this was associated with the initial radiation protection postings prior to the start of the chemical injection process. The RP field supervisor identified several postings that needed to be corrected after individuals initially hung the postings in the field. Although these postings were corrected prior to the start of the activity, it demonstrated unclear directions for the individuals tasked with hanging the initial radiation protection postings. It is important to ensure that work activities are appropriately understood, roles and responsibilities are clear, and, in this specific example, in-field radiation protection postings provide the correct instructions and barriers for workers to prevent occupational radiation safety issues.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On November 7, 2024, the inspectors presented the inspection results to M. Mlynarek, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
PAL-02741
M&TE ID#016044 Used While Out of Calibration
07/25/2024
51-9379921-000
Palisades Unit 1 MRP Bolting Ultrasonic Examination Plan
INR-Palisades
Restart-24-001
Remote Visual Examination Indication Notification Report
07/30/2024
Miscellaneous
Visual Exam Plan
Palisades Reactor Vessel and Internals Remote Visual
Examinations
07/23/2024
L-1 Crane Hooks
Magnetic Particle Examination Report
04/22/2024
LD-1
Magnetic Particle Examination Report
04/22/2024
LD-1
Ultrasonic Calibration and Exam Report
06/18/2024
NDE Reports
LD-1
Visual Examination Report
04/22/2024
Procedures
CLP-M-6
Inspection of Heavy Load Lift Devices
08/22/2018
Work Orders
50083288-01-001
L-1 Polar Crane PMs
2/06/2024
Shift 3 Crew Notebook
09/17/2024
Miscellaneous
PLSEG-LOR-
Palisades 2024 Cycle 24C Simulator Scenario
PNT-114
Licensed Operator Requalification Training Program
Description
PNT-210
Conduct of Simulator Training
Procedures
PNT-217
Examination Security
Reactor Auxiliary Building Floor Plan EL.639'-0", 649'-0"
Drawings
WDD-DW-01160-
CPAL1
Chemical Decontamination Equipment Layout Plan
Radiological Survey Sheet for Auxiliary Building 649'
07/06/2024
Primary Coolant System Decontamination Posting Plan
07/06/2024
240274
Radiation Work Permit and ALARA Plan for Primary Coolant
System Full System Chemical Decontamination
TSR-2024-155
Temporary Shielding Request for Water Shield Tanks
Around Cask Washdown Pit
06/07/2024
Miscellaneous
TSR-2024-157
Temporary Shielding Request for 590' Shield Around Floor
06/20/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Plug
WI-RSD-R-008
Spent Resin Transfers to Resin Liners in Track Alley
Access Control for Radiological Controlled Areas
WDD-IP-01076-
CAPL
Palisades 2024 FSD Installation Procedure
Procedures
WDD-OP-00085-
CPAL1
Palisades 2024 FSD Operating Procedure
0