IR 05000255/2024013
| ML25024A083 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/24/2025 |
| From: | April Nguyen NRC/RGN-III/DORS |
| To: | Mlynarek M Holtec Decommissioning International |
| References | |
| IR 2024013 | |
| Download: ML25024A083 (1) | |
Text
SUBJECT:
PALISADES NUCLEAR PLANT - RESTART INSPECTION REPORT 05000255/2024013
Dear Mike Mlynarek:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Palisades Nuclear Plant. The enclosed inspection report documents the inspection results, which the inspectors discussed on January 8, 2024, with and other members of your staff.
No violations of more than minor significance were identified during this inspection.
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.
January 24, 2025 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:
October 01, 2024 to December 31, 2024
Inspectors:
J. Austin, Senior Project Engineer, Region II
E. Fernandez, Senior Reactor Inspector, Region III
E. Magnuson, Reactor Inspector, Region III
J. Mancuso, Senior Resident Inspector
T. Okamoto, Resident Inspector
A. Sanchez, Senior Project Engineer, Region IV
S. Schwind, Senior Resident Inspector, Callaway
C. Speer, Reactor Systems Engineer, NRR
T. Steadham, Senior Resident Inspector, Browns Ferry
D. Werkheiser, Senior Reactor Analyst, Region I
J. Winslow, Senior Project Engineer, Restart Team
Approved By:
April M. Nguyen, Lead
Palisades Restart Team
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) performed inspections of the licensees activities to verify that the reactor coolant system boundary, reactor vessel head, and risk-significant piping system boundaries are appropriately monitored for degradation and that required repairs and replacements are appropriately examined and accepted; systems, structures, and components (SSCs) are appropriately inspected, maintained, and tested to ensure they can perform their required safety functions for potential restart; and human performance issues are being appropriately addressed at a low threshold to prevent more significant issues from occurring.
List of Findings and Violations
None.
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.
The Resident Inspector office was staffed in December 2024 to provide daily, on-site oversight and inspection of Holtecs potential restart activities.
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)
From November 14, 2024, to December 18, 2024, the inspectors observed and verified Holtec Palisades nondestructive examination (NDE) and repair/replacement activities of the reactor pressure vessel head and Alloy 600 welds, conducted in accordance with the requirements of the ASME Code Section XI. The purpose of these inspections was to verify that the reactor coolant system boundary, reactor pressure vessel head, and risk-significant piping system boundaries are appropriately monitored for degradation. The 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, the licensee completed NDE activities and evaluation of data for both the reactor pressure vessel head and Alloy 600 welds in the primary coolant system and began repair/replacement activities in both areas. Further NRC inspections will monitor repair/replacement activities as they are conducted.
The inspectors verified that the following nondestructive examination and repair/replacement 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:
Nondestructive Examination and Welding Activities (IP Section 03.01)
Alloy 600 Weld Inspection and Mitigation (November 14, 2024-December 18, 2024)
- Dye Penetrant (PT) Examination of weld overlay locations
- Phased Array Ultrasonic Testing (PAUT) of safety injection piping
- Fabrication of full structural weld overlay on hot leg 2 shutdown cooling line Vessel Upper Head Penetration Inspection Activities (IP Section 03.02)
Reactor Pressure Vessel Head (November 14, 2024-December 18, 2024)
- Preparatory machining activities for control rod drive mechanism (CRDM) nozzle repairs
- PT examination of reactor vessel head vent line
- Inner diameter (ID) profilometry of CRDM nozzle #5 OTHER BASELINE ACTIVITIES
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) PAL-02885, Adverse Trend in Human Performance Incidents, August 9, 2024 A summary of this review and the inspectors observations are documented in the Results Section below.
System Return to Service On December 2, 2024, the inspectors commenced reviews of Phases I and II of the licensees system return to service (SRTS) plans. The SRTS plans document licensee activities to verify that the configuration and condition of Systems, Structures, and Components (SSCs) are consistent with the design and licensing bases to support potential restart. The inspectors began initial reviews on Phases I and II of the SRTS plans, which include areas such as licensing and design-basis functions, system material conditions, reviewing open and deferred work prior to shutdown, and program applicability. The inspectors conducted these reviews using IP 71152, Problem Identification and Resolution, and IP 71111.21M, Comprehensive Engineering Team Inspection (CETI), as applicable.
The inspectors commenced reviews of the SRTS plans for the following systems:
- AC Power Systems
- DC Power Systems
- Low Pressure Safety Injection and Shutdown Cooling These systems were selected based on the importance of the SSCs during normal and emergency plant operating conditions, risk significance and defense-in-depth of the SSCs specific functions and required work/modifications of the SSCs scheduled prior to potential restart.
INSPECTION RESULTS
Assessment: Adverse Trend in Human Performance Incidents 71152 On August 9, 2024, the licensee wrote issue report (IR) PAL-02885 identifying an adverse trend in human performance incidents at the site. Five incidents in July and August 2024 were noted as part of the trend. An apparent cause evaluation (ACE) was performed to understand the incidents and implement actions to arrest the trend. As part of the ACE analysis, the licensee reviewed additional IRs that identified similar human performance incidents. Additionally, a previous safety and human performance trend identified in IR PAL-01857 on February 21, 2024, and associated corrective actions were reviewed.
The licensee identified five causal factors documented in the ACE associated with reinforcement of standards, guidance for procedures on hold, standards and expectations for new personnel, ineffective communications on safety and human performance issues, and less than adequate evaluation and corrective actions from previously identified issue reports.
Corrective actions completed or planned include, but are not limited to, development of a safety and human performance monitoring and communications plan, reinforcement of expectations for site employees, and performance of an effectiveness review.
The inspectors reviewed the licensees ACE, including IRs for the human performance incidents reviewed as part of the ACE. They also reviewed the identified causal factors and completed and planned corrective actions discussed in the ACE. The inspectors determined that the corrective actions were appropriate to the circumstances.
The licensee has planned to perform an effectiveness review of the corrective actions after all actions have been implemented. The inspectors noted that the methods of verification, process attributes, and success criteria for the effectiveness review are still being identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 8, 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
PAL-04217
PT Indications for Alloy 600 Weld Overlay
11/18/2024
PAL-04220
PT Indications on the Stainless on 1A Safety Injection
11/18/2024
PAL-04282
PT Indications on 2B Safety Injection Stainless Steel Valve
11/22/2024
PAL-04303
As-measured Palisades RVCH Thickness
11/25/2024
PAL-04316
PT Indication on 2A Cold Leg SI Nozzle
11/25/2024
Corrective Action
Documents
PAL-04614
PT Indications Following Vent Line Machining
2/18/2024
CR-2024-3181-
10-UT-001
UT Thickness Measurements of RVCH
11/15/2024
CR-2024-3181-
10-UT-002
UT Thickness Measurements of RVCH
11/22/2024
CR-2024-3406-
07-UT-001
UT Thickness Measurements of RVCH
11/26/2024
CR-2024-3406-
08-UT-001
UT Thickness Measurements of RVCH
2/02/2024
SI-1A-80-00-PT-
001
Liquid Penetrant Examination of 1A SI Nozzle
11/16/2024
SI-1B-80-00-PT-
001
Liquid Penetrant Examination of 1B SI Nozzle
11/26/2024
SI-2A-80-00-PT-
001
Liquid Penetrant Examination of 2A SI Nozzle
11/25/2024
NDE Reports
SI-2B-80-00-PT-
001
Liquid Penetrant Examination of 2B SI Nozzle
11/22/2024
54-PT-200-026
Color Contrast Solvent Removable Liquid Penetrant
Examination of Components
LMT-10-PAUT-
007
Fully Encoded Phased Array Ultrasonic Examination of
Dissimilar Metal Piping Welds
Procedures
LMT-10-PAUT-
019
Manual Phased Array Ultrasonic Examination of Dissimilar
Metal Piping Welds
Corrective Action
Documents
PAL-02643
Westinghouse PCS Decon Skid Operator Entered Incorrect
Value
07/10/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PAL-02768
Wire Rope Contacting Electrical Cable
07/30/2024
PAL-02770
Extraction of Personnel from Spider Man Basket
07/30/2024
PAL-02885
Adverse Trend in Human Performance Incidents
08/09/2024
PAL-02911
Personal Vehicle/Forklift Incident
08/12/2024
PAL-03651
NSRB Issue - Human Performance
10/17/2024
ENG-105
System Return to Service Plans
OM-126
Management and Oversight of Supplemental Personnel
Procedures
Corrective Action Program
0