IR 05000255/2009002

IR 05000255-09-002, on 01/01/2009 - 3/31/2009, Palisades Nuclear Plant; Integrated Inspection Report, Problem Identification and Resolution, Other Activities

ML091340480
Person / Time
Site:	Palisades
Issue date:	05/14/2009
From:	John Giessner Reactor Projects Region 3 Branch 4
To:	Schwarz C J Entergy Nuclear Operations
References
IR-09-002
Download: ML091340480 (33)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 May 14, 2009 Mr. Christopher Site Vice President Entergy Nuclear Operations, Inc. Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANT INTEGRATED INSPECTION REPORT 05000255/2009-002

Dear Mr. Schwarz:

On March 31, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection findings, which were discussed on April 7, 2009, with you and members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. This report documents two NRC-identified findings and one self-revealed finding of very low safety significance (Green). The findings were determined to involve violations of NRC requirements. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. However, because of their very low safety significance, and because the issues were enter ed into your corrective action program, the NRC is treating the issues as Non-Cited Violations (NCV) in accordance with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you shoul d 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Palisades Nuclear Plant. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Palisades Nuclear Plant. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

C. Schwartz -2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-erm/adams.html (the Public Electronic Reading Room).

Sincerely,\

/RA/ John B. Giessner, Chief Branch 4 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 05000255/2009-002

w/Attachment:

Supplemental Information

cc w/encl: Senior Vice President Vice President Oversight Senior Manager, Nuclear Safety & Licensing Senior Vice President and COO Assistant General Counsel Manager, Licensing W. DiProfio W. Russell G. Randolph Supervisor, Covert Township Office of the Governor T. Strong, State Liaison Officer Michigan Department of Environmental Quality Michigan Office of the Attorney General

C. Schwartz -2- In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-erm/adams.html (the Public Electronic Reading Room).

Sincerely,John B. Giessner, Chief Branch 4 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 05000255/2009-002

w/Attachment:

Supplemental Information

cc w/encl: Senior Vice President Vice President Oversight Senior Manager, Nuclear Safety & Licensing Senior Vice President and COO Assistant General Counsel Manager, Licensing W. DiProfio W. Russell G. Randolph Supervisor, Covert Township Office of the Governor T. Strong, State Liaison Officer Michigan Department of Environmental Quality Michigan Office of the Attorney General DOCUMENT NAME: G:\PALI\PALI 2009 002.doc Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII NAME FTran:dtp

• JBG for JGiessner DATE 05/14/09 05/14/09 OFFICIAL RECORD COPY

Letter to from J. Giessner dated May 14, 2009

SUBJECT: PALISADES NUCLEAR PLANT INTEGRATED INSPECTION REPORT 05000255/2009-002 DISTRIBUTION:

Tamara Bloomer RidsNrrPMPalisades

RidsNrrDorlLpl3-1 Resource

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DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource

U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-255 License No: DPR-20 Report No: 05000255/2009-002 Licensee: Entergy Nuclear Operations, Inc. Facility: Palisades Nuclear Plant Location: Covert, MI Dates: January 1, 2009, to March 31, 2009 Inspectors: J. Ellegood, Senior Resident Inspector T. Taylor, Resident Inspector N. Valos, Senior Operations Engineer

Approved by: John B. Giessner, Chief Branch 4 Division of Reactor Projects Enclosure Enclosure

SUMMARY OF FINDINGS

IR 05000255/2009-002; 01/01/2009 - 3/31/2009; Palisades Nuclear Plant; Integrated Inspection Report; Problem Identification and Resolution; Other Activities. This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. Three Green findings were identified by the inspectors. The findings were considered Non-Cited Violations of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP).

Cross-cutting aspects were determined using IMC 0305, Operating Reactor Assessment Program. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events

Green.

On February 20, 2009, the inspectors identified an NCV of Technical Specification (TS) 5.4, Procedures. Specifically, the licensee failed to revise procedures needed to implement TS amendment 236.

Amendment 236 revised license requirements for storage of fuel in the Spent Fuel Pool (SFP) and was prepared, in part, pursuant to Confirmatory Action Letter (CAL) RIII-08-003. The licensee notified the NRC via letter on February 11 that the amendment had been implemented. During review of licensee actions to lift the CAL, the inspectors identified that the licensee had not revised affected procedures. The licensee entered the issue into their corrective action program (CAP) and revised procedures prior to adding new fuel to the pool. The inspectors determined that the failure to revise affected procedures prior to implementation of the TS amendment was more than minor because it is associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of an initiating event. Specifically, the criticality analysis relies on geometric controls to maintain the effective neutron multiplication factor (K eff) below one and the procedures ensure the controls are in place. Because the licensee did not load any fuel to a location prohibited by the TS, the finding is not of more than very low safety significance. The inspectors determined the finding included a cross-cutting aspect in the area of human performance, work control, coordination of work activities (H.3.(b)). Specifically, during implementation of the amendment, the licensee failed to coordinate between licensing, operations and engineering to ensure all procedures affected by the change were reviewed and revised where needed.(4OA5)

Cornerstone: Mitigating Systems

Green.

A finding of very low safety significance and associated NCV of TS 5.4, "Procedures," was self-revealed on February 7, 2009, when High Pressure Safety Injection (HPSI) system loop injection valve MO-3064 failed to open during routine operations. Specifically, the licensee failed to have adequate procedures in place to 1

The inadequacy of maintenance procedures in addressing foreign material exclusion (FME) control was greater than minor because it affected the Equipment Performance attribute of the Mitigating Systems cornerstone, in that the foreign material adversely affected the availability, reliability, and capability of a system that responds to initiating events to prevent undesirable consequences. Because the safety function of one train of the HPSI system was not lost for greater than the TS allowed outage time, the finding screened as Green, or very low safety significance. The finding had an associated cross-cutting aspect in the area of human performance, work control, ability to appropriately plan work activities (H.3.(a)). (4OA2)

Green.

The inspectors identified an NCV for failure to maintain fire doors consistent with license condition 2.C.3. Specifically, in report 05000255/2008003 the inspectors documented an Unresolved Item (URI) related to the adequacy of the licensee's maintenance of fire doors consistent with requirements of National Fire Protection Association (NFPA) 80. The licensee failed to maintain the fire doors compliant with NFPA-80 requirements or adequately evaluate fire doors in accordance with Generic Letter (GL) 86-10. Subsequent evaluation consistent with GL 86-10 provided an adequate basis for the condition of the doors based on the hazards present. The inspectors determined that the failure to maintain fire doors in compliance with the requirements by either meeting NFPA-80 or having an adequate evaluation based on the hazards present was a performance deficiency. The inspectors concluded that the finding was more than minor in accordance with IMC 0612, Appendix E, Example 3.j, in that the condition created reasonable doubt as to the operability of the fire doors and because the condition was programmatic in nature since the procedure allowed generic exceptions to NFPA-80 requirements. The inspectors further evaluated the issue in accordance with IMC 0609 and concluded the finding was not of more than very low safety significance because the fire doors would provide nearly the same level of protection based on the hazards present. Because of the age of the previous analysis, the inspectors concluded the finding does not represent current licensee performance; therefore, there is no cross-cutting aspect. (4OA5)

B. Licensee-Identified Violations

Violations of very low safety significance that were identified by the licensee have been reviewed by the inspectors. Corrective actions planned or taken by the licensee have been entered into the licensee's corrective action program. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report. 2

REPORT DETAILS

Summary of Plant Status

The plant began the inspection period at or near 100 percent reactor power. On February 17, the licensee shut down the plant to repair a leaking control rod drive mechanism. The licensee started up the plant on February 20 and returned to 100 percent power on February 22. The plant remained at or near 100 percent power until March 22 when the licensee shut down the plant for a planned refueling outage. The plant remained shutdown for the remainder of the inspection period.

REACTOR SAFETY

Initiating Events, Mitigating systems, Barrier Integrity, and Emergency Preparedness

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• Service water system with service water pump P-7B out of service;

• 1-1 Emergency diesel generator (EDG) during maintenance outage on 1-2 EDG; and

• Service water system with servic e water pump P-7C out of service. The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report (UFSAR), TS requirements, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization. Documents reviewed are listed in the Attachment. These activities constituted three partial system walkdown samples as defined in IP 71111.04-05. 3 Enclosure

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• Auxiliary feedwater (AFW) pump room;

• 1-1 EDG room;

• Turbine building; and

• 'C' switchgear room. The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's CAP. Documents reviewed are listed in the Attachment to this report. These activities constituted four inspection samples as defined in IP 71111.05-05.

b. Findings

No findings of significance were identified.

1R06 Flooding

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety related equipment from internal 4 Enclosure flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, and abnormal operating procedures to identify licensee commitments. The inspectors performed a walkdown of the following plant area to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

• Service water screenhouse. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensee's corrective action documents with respect to past flood-related items identified in the CAP to verify the adequacy of the corrective actions. The specific documents reviewed are listed in the Attachment to this report. This inspection constituted one internal flooding sample as defined in IP 71111.06-05.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On January 29, 2009, the inspectors observed a crew of licensed operators in the plant's simulator during licensed operator requalification examinations to verify that operator

performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crew's clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications. The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator requalification program sample as defined in IP 71111.11. 5 Enclosure

b. Findings

No findings of significance were identified.

.2 Annual Operating Test Results and Biennial Written Examination Results

a. Inspection Scope

The inspectors reviewed the overall pass/fail results of the individual Job Performance Measure operating tests, the simulator operating tests, and the biennial written examination (required to be given per 10 CFR 55.59(a)(2)) administered by the licensee from January 2009 through February 2009 as part of the licensee's operator licensing requalification cycle. These results were compared to the thresholds established in IMC 0609, Appendix I, "Licensed Operator Requalification Significance Determination Process (SDP)." The evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG 1021, "Operator Licensing Examination Standards for Power Reactors," and IP 71111.11, "Licensed Operator Requalification Program." The documents reviewed during this inspection are listed in the Attachment.

This inspection constituted one inspection sample as defined in IP 71111.11.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk significant systems:

• High pressure air; and

• Alternate shutdown panel. The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition

problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and 6 Enclosure

• verifying appropriate performance criteria for structures, systems, and components/functions classified as (a)(2) or appropriate and adequate goals and corrective actions for systems classified as (a)(1). The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• Maintenance risk with EDG 1-2 out of service for maintenance;

• Maintenance with HPSI out of service and winter storms;

• Maintenance risk for a forced outage;

• Component cooling water heat exchanger work during reduced inventory; and

• Operations with elevated primary coolant system leakage and troubleshooting. These activities were selected based on their potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. These maintenance risk assessments and emergent work control activities constituted five samples as defined in IP 71111.13-05.

b. Findings

No findings of significance were identified. 7 Enclosure

1R15 Operability Evaluations

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• Corrosion of AFW pump 'C' suction piping;

• Primary coolant system due to elevated leak rate ;

• 'D' Thermal margin monitor missed TS surveillance; and

• Steam generator blowdown valves due to environmental qualification. The inspectors selected these potential operability issues based on the risk-significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensee's evaluations, to determine

whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report. This operability inspection constituted four samples defined in IP 71111.15-05.

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

.1 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the following temporary modification:

• Temporary crane for stator replacement.

The inspectors compared the temporary configuration changes and associated 10 CFR 50.59 screening and evaluation information against the design basis, the UFSAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected system(s). The inspectors performed field verifications to ensure that the modifications were installed as directed; the modifications operated as expected; modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not 8 Enclosure impact the operability of any interfacing systems. Lastly, the inspectors discussed the temporary modification with operations, engineering, and maintenance personnel to ensure that the individuals were aware of how extended operation with the temporary modification in place could impact overall plant performance. This inspection constituted one temporary modification sample as defined in IP 71111.18-05.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

.1 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional

capability:

• 1-2 EDG air start system modifications;

• Surveillance testing following planned maintenance outage on 1-2 EDG;

• 1-2 EDG following replacement of a check valve;

• Component cooling water pump P-52C breaker maintenance;

• Service water pump P-7C shaft replacement; and

• Temporary crane for stator lift. These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as

written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion), and test

documentation was properly evaluated. The inspectors evaluated the activities against the TS, UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report. This inspection constituted six post-maintenance testing samples as defined in IP 71111.19-05. 9 Enclosure

b. Findings

No findings of significance were identified.

1R20 Outage Activities

.1 Forced Outage for Control Rod Drive Seal Replacement

a. Inspection Scope

The inspectors evaluated outage activities for a forced outage that began on February 17, 2009, and continued through the reactor startup on February 20, 2009.

The inspectors reviewed activities to ensure that the licensee considered risk in developing, planning, and implementing the outage schedule. The inspectors observed the reactor shutdown and cooldown, outage equipment configuration and risk management, electrical lineups, control and monitor of decay heat removal, control of containment activities, startup and heatup activities, and identification and resolution of problems associated with the outage. The licensee entered the forced outage due to rapidly increasing control rod drive leakage. The inspectors performed a walkdown of containment shortly after shutdown to identify boric acid leaks. In addition, the inspectors accompanied licensee personnel during the containment closeout tour. This inspection constituted one other outage sample as defined in IP 71111.20-05.

b. Findings

No findings of significance were identified.

.2 Refueling Outage Activities

a. Inspection Scope

The inspectors reviewed the outage risk profile and contingency plans for the refueling outage (RFO), conducted starting March 22, 2009, to confirm that the licensee had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense-in-depth. During the RFO, the inspectors observed portions of the shutdown and cooldown processes and monitored licensee controls over the outage activities listed below.

Documents reviewed during the inspection are listed in the Attachment to this report.

• Licensee configuration management, including maintenance of defense-in-depth commensurate with risk for key safety functions and compliance with the applicable TS when taking equipment out-of-service.

• Implementation of clearance activities and confirmation that tags did not adversely affect defense-in-depth.

• Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error.

• Controls over the status and configuration of electrical systems to ensure that TS and outage risk plan requirements were met, and controls over switchyard

activities. 10 Enclosure

• Monitoring of decay heat removal processes, systems, and components.

• Controls to ensure that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system.

• Reactor water inventory controls including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss.

• Controls over activities that could affect reactivity.

• Maintenance of secondary containment as required by TS.

• Refueling activities, including fuel handling and sipping to detect fuel assembly leakage.

• Licensee identification and resolution of problems related to RFO activities. This inspection does not constitute one RFO sample as defined in IP 71111.20-05 because the outage extends beyond the last day of the inspection period.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural

and TS requirements:

• 'B' Containment spray pump inservice testing;

• Safety injection system quarterly testing;

• Calibration of 1-2 EDG support system pressure switches;

• Nuclear instrument and thermal power calibrations;

• Loading of the SFP; and

• Primary coolant leakage determination. The inspectors observed in plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

• were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;

• plant equipment calibration was correct, accurate, and properly documented;

• as-left setpoints were within required ranges; and the calibration frequency were in accordance with TSs, the USFAR, procedures, and applicable commitments;

• measuring and test equipment calibration was current;

• test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied; 11 Enclosure

• test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored

where used;

• test data and results were accurate, complete, within limits, and valid;

• test equipment was removed after testing;

• where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the

system design basis;

• where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

• where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;

• where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

• prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

• equipment was returned to a position or status required to support the performance of its safety functions; and

• all problems identified during the testing were appropriately documented and dispositioned in the CAP. Documents reviewed are listed in the Attachment to this report. This inspection constituted 4 routine surveillance testing samples, one inservice testing sample, and one reactor coolant system leak detection inspection sample, as defined in IP 71111.22, Sections -02 and -05.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on February 12, 2009, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator control room, technical support center and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program.

As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report. This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index (M

SPI) - High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - High Pressure Injection Systems performance indicator for the period from the first quarter through the fourth quarter of 2008 to determine the accuracy of the Performance Indicator data reported during those periods. Performance Indicator definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline,"

Revision 5, were used to assist the inspectors' evaluation. The inspectors reviewed the licensee's operator narrative logs, condition reports, MSPI derivation reports, MSPI margin reports, and maintenance rule data for the period of first quarter through fourth quarter 2008 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. Documents reviewed are listed in the Attachment to this

report. This inspection constituted one MSPI high pressure injection system sample as defined in IP 71151-05.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

.1 Routine Review of items Entered Into the Corrective Action Program

a. Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities 13 Enclosure and plant status reviews to verify that they were being entered into the licensee's CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: the complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; that evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue. Minor issues entered into the licensee's CAP as a result of the inspectors' observations are included in the Attachment to this report. These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

Introduction:

A Green NCV of TS 5.4, "Procedures," was self-revealed when a failure of a HPSI isolation valve to open rendered the right train of the HPSI system inoperable. Subsequent investigation by the licensee determined that foreign material introduced by maintenance activities on an auxiliary contact had prevented the proper operation of the valve.

Description:

On February 7, 2009, while attempting to fill the T-82C safety injection tank during routine operations, control room operators attempted to throttle open MO-3064, one of two HPSI isolation valves to primary coolant loop 2A. The valve did not reposition. The licensee declared the right train of HPSI inoperable and began troubleshooting to determine the cause of the failure. The valve had successfully operated earlier in the evolution. Later in the day, during troubleshooting of the valve motor's circuit breaker, electricians discovered a small strand from a Scotch-Brite cleaning pad in one of the auxiliary contacts. The contacts are normally closed and act as a permissive for the valve motor to open the valve if the valve has a demand to open. The licensee determined that the foreign material became stuck between two contacts, thus preventing the contact from closing and the valve from operating. This condition also would have prevented the valve from opening as designed during a safety injection actuation signal. The licensee last performed maintenance in December 2008. During the maintenance, electricians cleaned and lightly buffed the contacts using a Scotch-Brite pad. The breaker passed post-maintenance testing. After evaluating the failure, the licensee concluded that the Scotch-Brite strand was introduced to the circuit breaker through the cleaning process. The licensee subsequently removed the strand and retested the valve satisfactorily. A review of the work instruction and maintenance procedure for FME controls revealed only a general reference to take precautions when moving or storing breakers and parts. The fleet FME procedure, EN-MA-118, did have several applicable examples of when certain FME controls should be employed and examples of how to incorporate them into maintenance procedures and work instructions. A licensee search for relevant operating experience yielded some examples applicable to this issue as well. 14 Enclosure

Analysis:

The failure of MO-3064 (a safety-related HPSI valve) to operate due to an inadequate procedure for FME control is a performance deficiency warranting further screening per IMC 0612. The issue is more than minor because it affected the Equipment Performance attribute of the Mitigating Systems cornerstone, in that the foreign material adversely affected the availability, reliability, and capability of a system that responds to initiating events to prevent undesirable consequences. Specifically, the HPSI isolation valve MO-3064 would neither operate automatically on a safety injection signal nor from its switch in the control room. Since the licensee successfully operated the valve earlier on February 7, 2009, the inspectors concluded that the valve was inoperable for less than the TS allowed outage time. To determine the significance of the finding, IMC 0609, Attachment 4, "Phase 1-Initial Screening and Characterization of Findings," was utilized based on the issue screening as greater than minor. For the Mitigating Systems cornerstone, the negative response to all questions in Table 4a yielded a significance of Green, or very low safety significance, for the finding. The finding has an associated cross-cutting aspect in the area of human performance, work control, ability to appropriately plan work activities (H.3.(a)), in that appropriate FME precautions were neither planned nor incorporated into procedures.

Enforcement:

TS 5.4, "Procedures," states, in part, that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33 states, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to this, the licensee failed to have adequate procedures established for work on the HPSI injection valve to preclude introduction of foreign material. As a result, on February 7, 2009, valve MO-3064 failed to operate. The licensee entered the issue into the CAP as Condition Report (CR) PLP-2009-00528, and removed the foreign material. Because this violation was of very low safety significance and it was entered into the licensee's CAP, this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 05000255/2009002-01, Inoperability of HPSI Valve due to Foreign Material)

.2 Daily Corrective Action Program Reviews

a. Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's CAP. This review was accomplished through inspection of the station's daily condition report packages. These daily reviews were performed by procedure as part of the inspectors' daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings of significance were identified. 15 Enclosure

4OA5 Other Activities

.1 Closure of Unresolved Item (URI) 2008004-03

a. Inspection Scope

In report 05000255/2008004 the inspectors documented a URI related to an unexplained release of waste gas to the turbine building during waste gas processing. While performing a routine evolution to send waste gas to the plant stack, a radiation monitor for the main condenser steam jet air ejectors alarmed. Although the licensee generated a CR, the licensee classified it at the lowest significance level without an evaluation of the cause. The inspectors questioned the appropriateness of this classification and the licensee subsequently generated additional CR's to investigate the cause and potential consequences of the gas flow. The licensee determined that the most probable pathway was reverse flow through the air ejector radiation monitor from the stack and then through a loop seal attached to the air ejector condenser drains. With no steam flow through the air ejectors (such as after plant shutdowns), it appeared that the loop seal could be lost, permitting a path from the plant stack to the turbine building to exist. The licensee instituted procedural changes to isolate this pathway during conditions where steam flow would be secured to the air ejectors. The licensee also evaluated potential dose consequences to workers and the public, and also evaluated the turbine building area for contamination. After reviewing the licensee's evaluations and discussing the issue with regional health physics staff, the inspectors determined the URI could be closed, since there was negligible impact on dose as the activity was accounted for in the batch waste gas release permit and therefore included in the annual effluent release report. Additionally, the radiological impact to any workers in the affected area of the turbine building was negligible.

b. Findings

No findings of significance were identified.

.2 Institute of Nuclear Power Operations Plant Assessment Report Review

a. Inspection Scope

The inspectors reviewed the final report for the Institute of Nuclear Power Operations plant assessment conducted in May 2008. The inspectors reviewed the report to ensure that issues identified were consistent with the NRC perspectives of licensee performance and to verify if any significant safety issues were identified that required further NRC follow-up.

b. Findings

No findings of significance were identified. 16 Enclosure

.3 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours. These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

.4 Closure of Confirmatory Action Letter (CAL) RIII-08-003

a. Inspection Scope

Using guidance contained in Inspection Procedure 92702, Follow-up on traditional Enforcement Actions including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders and Alternate Dispute Resolution Confirmatory Orders, the inspectors reviewed the licensee's actions to exit CAL RIII-08-003. The NRC issued the CAL to confirm commitments made by the licensee regarding degradation of neutron absorbing material credited in the SFP criticality analysis. Because of the degradation, the licensee no longer complied with TS 4.3.1.1b "Design Features-Fuel Storage-Criticality," and 10 CFR 50.68, "Criticality Accident Requirements." The licensee instituted measures to ensure fuel could be safely stored in the pool until compliance could be re-established with the facility license. On February 6, the NRC approved TS amendment 236 which revised the TS such that the licensee could comply with the license. On February 11, the licensee sent a letter to the NRC stating that "Entergy Nuclear Operations, Inc. has completed actions and commitments to reestablish compliance with site license requirements for the spent fuel pool; addressed

in the CAL dated September 18, 2008." In order to verify the licensee's statement that the licensee had completed actions necessary to exit the CAL, the inspectors reviewed the loading of the SFP, procedures used for SFP loading, and training of licensed operators. Based on this review, the inspectors concluded that the licensee had not implemented the TS with respect to procedural revisions and training of licensed operators; however, the SFP loading did meet the requirements of TS amendment 236.

b. Findings

Introduction:

On February 20, 2009 the inspectors identified a Green NCV of TS 5.4, "Procedures". Specifically, the licensee failed to revise procedures needed to implement TS amendment 236; although, the licensee notified the NRC via letter on February 11

that the amendment had been implemented.

Description:

In response to NRC concerns related to swelling of SFP storage racks, the licensee performed testing of the neutron absorption capability of the spent fuel pool storage racks. Based on this testing, the licensee determined that the neutron absorption capability no longer met assumptions in their criticality analysis. Therefore, the licensee determined that design features TS 4.3 no longer provided adequate assurance that the spent fuel pool would remain subcritical for all required conditions.

On August 27, 2008, the licensee sent a letter to the NRC identifying interim actions to ensure the SFP remained critically safe. On September 20, the NRC approved a CAL in response to that letter to confirm licensee actions. As part of the actions to restore compliance, the licensee developed TS amendment 236 to codify necessary controls to ensure the safety of the SFP. By letter dated February 11, the licensee informed the NRC that Amendment 236 had been implemented. The NRC inspected the actions taken by the licensee to implement the amendment and concluded that the licensee had failed to take actions required by licensee procedures to implement the amendment.

Since the CAL prohibited addition of new fuel to the SFP, the licensee needed the NRC to lift that CAL to support outage activities. In addition, loading of new fuel into the SFP required extensive use of two procedures directly affected by the amendment. Procedure EM-04-29 provides instruction on development of fuel loading sheets used to establish a safe and compliant SFP load pattern. The amendment added a new TS surveillance requirement, SR 3.7.16.1, which required verifying, by administrative means, that each fuel assembly meets the requirements given in TS 3.7.16. The licensee failed to revise this procedure to include the requirements of the amendment.

Procedure SOP-28 provides instructions on moving fuel in the SFP and procedure ADM-10.51, "Writer's Guideline for Site Procedures," governs the format and content of the procedure. Required content includes identification of affected TS precautions and limitations that could result in non-compliance with TS. The licensee failed to revise procedure SOP-28 to reflect those requirements.

Analysis:

The inspectors determined that the failure to revise affected procedures prior to implementation of the TS amendment was a performance deficiency that warranted a significance determination. The finding is more than minor because it is associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of an initiating event.

Specifically, the criticality analysis relies on geometric controls to maintain K eff below one. In order to ensure the geometric control is in place, the amendment established a surveillance requirement to verify each fuel assembly meets fuel pool storage requirements prior to storing the assembly into the SFP. The licensee failed to incorporate the requirements into the procedure used to develop SFP loading patterns. The inspectors determined that the finding was not suitable for further SDP analysis because it is related to an initiating event in the SFP. Using the guidance in IMC 0609, Appendix M, the inspectors performed a bounding analysis to determine the significance. The inspectors concluded the bounding condition would be placement of a single fuel bundle face adjacent to fuel bundles in the pool. The inspectors concluded that the licensee would identify the error prior to improperly placing more than one bundle. The inspectors arrived at this conclusion due to the heightened awareness of reactor engineers of loading constraints, the presence of a senior operator to validate placement consistent with the TS requirements and pre-job briefings that provided a detailed discussion of SFP loading requirements. On going analysis of the SFP shows additional margin to criticality beyond that credited in the license amendment. Therefore, the inspectors concluded that the pool would remain sub-critical for a single 18 Enclosure misplaced bundle. In addition, the licensee did not place fuel into the SFP in a location prohibited by TS 3.7.16. Therefore, the inspectors concluded, and NRC management concurred, that the finding was not of more than very low safety significance. The inspectors determined the finding included a cross-cutting aspect in the area of human performance, work control, coordination of work activities (H.3.(b)). Specifically, during implementation of the amendment, the licensee failed to coordinate between licensing, operations and engineering to ensure all procedures affected by the change were reviewed and revised where needed.

Enforcement:

Technical Specification 5.4 requires the licensee to establish and implement procedures required by Regulatory Guide 1.33. Regulatory Guide 1.33 requires, in part, specific procedures for surveillance tests. Amendment 236 added a new TS surveillance requirement, SR 3.7.16.1, which required verifying, by administrative means, that each fuel assembly meets the requirements given in TS 3.7.16. Contrary to this requirement, the licensee failed to establish the procedure used for surveillance of SFP loading, EM-04-29, to reflect the requirements of TS Amendment 236. Because the finding is of very low safety significance and has been entered into the licensee's CAP as CR-2009-0630, this violation of TS 5.4 is being treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy.

(NCV 05000255/2009002-02, Failure to Implement Technical Specification)

.5 Closure of Unresolved Item (URI) 2008003-03

a. Inspection Scope

In report 05000255/2008003 the inspectors documented a URI related to adequacy of the licensee's maintenance of fire doors consistent with requirements of NFPA-80.

Specifically, the licensee improperly applied guidance in GL 86-10 that resulted in acceptance of degradations without sufficient basis. Subsequently, the licensee re-evaluated the degraded condition in EA-APR-98-004, "Analysis of Problems Concerning Fire Doors". The NRC reviewed the licensee's analysis and determined the revised analysis provided an adequate basis for deviations addressed in the analysis.

b. Findings

Introduction:

The inspectors identified a finding of very low safety significance (Green) and an associated NCV of License Condition 2.C.(3), "Fire Protection," during performance of a surveillance procedure inspection in accordance with IP 71111.22.

Specifically, the inspectors noted numerous fire doors that did not conform to the

requirements of NFPA-80.

Description:

As part of the licensee's fire protection strategy, the licensee credits numerous fire doors to limit the spread of fire between adjacent fire zones. NFPA-80, which the licensee's fire hazards analysis invokes for acceptability of fire doors, provides criteria for the acceptability of fire doors. Generic Letter 86-10 permits evaluation of deviations from NFPA requirements by a fire protection engineer to determine if the condition provides adequate protection based on the hazards present. The licensee's analysis failed to demonstrate the barriers would be effective based on the hazards present and, in some cases, provided generic deviations from NFPA-80 requirements. After discussions with the inspectors, the licensee impaired numerous fire doors and re-evaluated the condition of the discrepant doors. The inspectors reviewed the licensee's 19 Enclosure evaluation and concluded that none of the degradation was of more than very low safety significance.

Analysis:

The inspectors determined that the failure to maintain fire doors compliant with the requirements of NFPA-80 or have an adequate evaluation based on the hazards present represents a performance deficiency that warranted a significance determination. The inspectors concluded that the finding was more than minor in accordance with IMC 0612, Appendix E, Example 3.j, in that the condition created reasonable doubt as to the operability of the fire doors and because the condition was programmatic in nature since the procedure allowed generic exceptions to NFPA-80 requirements. The inspectors further evaluated the finding in accordance with IMC 0609. Because the finding affects the Mitigating System cornerstone and it is associated with the attribute of protection from the external factor of fire, the inspectors discussed the finding with region based fire protection specialists. The inspectors determined the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix F, because the degraded doors, based on the hazards present, would provide nearly the same protection as non-degraded doors. Because of the age of the previous analysis, the inspectors concluded the finding does not represent current licensee performance; therefore, there is no cross-cutting aspect.

Enforcement:

Renewed license DPR-20, License condition 2.C.(3), Fire Protection requires the licensee to implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in Safety Evaluation Reports dated September 01, 1978. The fire protection program as described in the licensee's fire hazards analysis credits fire doors

that meet the requirements of NFPA-80 with provisions for specific exceptions pursuant to GL 86-10. Contrary to this requirement, the licensee failed to maintain numerous fire doors compliant with NFPA-80 requirements and failed to demonstrate adequacy of the discrepant doors pursuant to GL 86-10. Because this finding was entered into the licensee's CAP as CR-PLP-2008-02696, the violation is being treated as an NCV consistent with Section VI.A of the NRC Enforcement Policy.

(NCV 05000255/2009002-03, Degradation of Fire Doors)

4OA6 Management Meetings

.1 Exit Meeting Summary

On April 7, 2009, the inspectors presented the inspection results to Chris Schwarz and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was

considered proprietary.

.2 Interim Exit Meetings

Interim exits were conducted for:

• The licensed operator requalification training program annual inspection results with Mr. T. Horan, Operations Training Requalification Supervisor, on March 16, 2009, via telephone. 20 Enclosure 21 Enclosure The inspectors confirmed that none of the potential report input discussed was considered proprietary.

4OA7 Licensee-Identified Violations

The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.

• Title 10 CFR 20.1602 requires in part, that in addition to the requirements for 10 CFR 20.1601 (control of access to high radiation areas), the licensee shall institute additional measures to ensure that an individual is not able to gain unauthorized or inadvertent access to very high radiation areas. Contrary to this, on September 24, 2007, the licensee provided the interlock keys to reactor engineering while irradiated fuel was loaded in the new fuel elevator. The keys allow raising fuel to the surface of the spent fuel pool creating a configuration that could result in radiation levels commensurate with a very high radiation area. The

inspectors interviewed personnel direct ly involved with the evolution and each person stated that they knew of no instance when the key was inserted with irradiated fuel in the elevator. The inspectors concluded that the licensee had not implemented additional controls required by 10 CFR 20.1602. The licensee entered the issue into the corrective action program as CR-PLP-2007-04378. The inspectors concluded the finding was of very low safety significance because it was not an As Low As Reasonably Achievable planning issue, there was no overexposure nor potential for overexposure, and the licensee's ability to assess dose was not compromised.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT

Licensee

C. Schwarz, Site Vice President

V. Beilfuss, Project Manager

A. Blind, Engineering Director

N. Brott, Emergency Preparedness Coordinator

T. Davis, Regulatory Compliance

B. Dotson, Regulatory Compliance

J. Fontaine, Senior Emergency Planning Coordinator

J. Ford, Corrective Action Manager

T. Horan, Operations Requalification Training Superintendent

T. Kirwin, Plant General Manager

L. Lahti, Licensing Manager

T. Shewmaker, Chemistry Manager

C. Sherman, Radiation Protection Manager

M. Sicard, Operations Manager

G. Sleeper, Assistant Operations Manager

Nuclear Regulatory Commission

D. Szwarz, Engineering Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened 05000255/2009002-01 NCV Inoperability if HPSI Valve due to Foreign Material (4OA2)05000255/2009002-02

NCV Failure to Implement Technical Specification (4OA5)05000255/2009002-03

NCV Degradation of Fire Doors (4OA5)

Closed 05000255/2009002-01 NCV Inoperability if HPSI Valve due to Foreign Material (4OA2)05000255/2009002-02

NCV Failure to Implement Technical Specification (4OA5)05000255/2009002-03

NCV Degradation of Fire Doors (4OA5)

CAL RIII-08-003

CAL Confirmatory Action Letter RIII-08-003 (4OA5)05000255/2008003-03

URI Fire Door Nonconformance (4OA5)05000255/2008004-03

URI Unexpected Activity Through Turbine Building Monitor During

Gas Release (4OA5)

Attachment

DOCUMENTS REVIEW

ED 1R04 Equipment Alignment

- SOP-15, Service Water System, revision 47

- SOP-22, Emergency Diesel Generators, Revision 45 1R05 Fire Protection

- CR-PLP-2009-00049, During MSM-M-16, Inspection of Watertight Barriers, Noted Caulking Missing From Two Locations on FZ-0480, January 8, 2009

- EA-RJC-92-0480, Analysis of the Affect of a Fire on the Fire Barrier Penetration Seal

1. FZ-0480, Revision 0

- Palisades Fire Hazards Analysis, Revision 7 1R06 Flood Protection Measures

- CR-PLP-2007-01782, Service Water Motor Spray Shields Do Not Match Design, May 1, 2007

- CR-PLP-2009-00140, Service Water Spray Shield Material Condition, January 14, 2009

- DBD-7.08, Plant Protection Against Flooding, Revision 5

- UFSAR Chapter 2.2, Hydrology, Revision 24

- UFSAR Chapter 5.4, Water Level Design, revision 24 1R11 Licensed Operator Requalification Program

- Requalification Examination Results/Calendar Year 2009

- SEG PL-OPS-SPE-80, Simulator Exercise Guide, Rev-0 1R12 Maintenance Effectiveness

- CR-PLP-2007-5118, Received alarm EK-1118, HP Control Air Compressors Hi-Lo unexpectedly, October 11, 2007

- CR-PLP-2007-5191, During T-205B, west engineered safeguards HP air system performance verification, test failed to meet acceptance criteria, November 23, 2007

- CR-PLP-2007-5951, C-6A did not start when air receiver was blown down, October 13, 2007

- EGAD-EP-10, Maintenance Rule Scoping Document, Revision 5

- Maintenance Action Plan for Alternate Shutdown Panel, rev. 0

- System Health Report, Fire Protection Alternate Shutdown, 4

th Quarter 2008

- System Health Report, High Pressure Air System, 4

th Quarter 2008 R13 Maintenance Risk Assessments and Emergent Work Control

- ADM 4.02, Control of Equipment, Rev. 49

- GOP-14 Shutdown Rick Assessment Checklist, February 18, 2009

- GOP-14, Reduced Inventory Checklist, March 26, 2009

- ONP-12, Acts of Nature, Revision 25

- QO-16, Inservice Test Procedure-HPSI Pumps and ESS Check Valve Operability Test, Revision 29

- Tagout CCS-012-A-E-54B, CCW Heat Exchanger Work

- Work Instructions generated for verifying source of elevated primary system leakage

Attachment

1R15 Operability Determinations

- CR-PLP-2009-00116, External Corrosion on AFW Pipe, January 13, 2009

- CR-PLP-2009-00866, Technical Specification Surveillance Requirement 3.3.1.1 Not Met, March 1, 2009

- CR-PLP-2009-00944, High Temperatures in the Auxiliary Building, March 6, 2009

- CR-PLP-2009-81, P-8C, 'C' Aux Feed Pump suction Line has Area of Surface Corrosion, January 9, 2009

- ENN-CS-S-008, Pipe Wall Thinning Structural Evaluation, Revision 1

- UFSAR Chapter 11, Radioactive Waste Management and Radiation Protection, Revision 21

- UFSAR Chapter 9, Chemical and Volume Control System, Revision 27

- ODMI for Rise in Primary System Drain Tank Inleakage, Revision 0

- ODMI for Rising Control Rod Drive Seal Leakage, Revision 0

- SHO-1, Operator's Shift Items Modes 1, 2, 3, and 4, Revision 68 1R18 Plant Modifications

- EA-EC9520-01, replace Generator Stator, March 23, 2009

- EN-OP-116 Attachment 9.3, IPTE supplemental control checklist for main Generator Stator Move, March 30, 2009 1R19 Post Maintenance Testing

- CR-PLP-2009-00293, CK-DE404 Check Valve Failed to Function, January 23, 2009

- DBD 5.01, Diesel Engine and Auxiliary Systems, Revision 5

- EC-5885, Emergency Diesel Generator 1-1 and 1-2 Starting Air System Reliability Upgrades

- UFSAR Section 8.4, Emergency Power Sources, Revision 27

- MO-7A-1 and 2, Technical Specification Surveillance Procedure Basis Document, Emergency Diesel Generators 1-1 and 1-2, Revision 12

- Procedure No. 5.19, Post Maintenance Testing, Revision 13

- QO-14, Inservice Test, Service Water Pumps, Revision 29

- WO 51632673, Replace P-7C Pump Shaft Thru-Packing Area-Normal Wear

- WO 51675106, Preventative Maintenance for 152-116 Breaker

- WO 51793891, MO-7A-2, Emergency Diesel Generator 1R20 Outage Activities

- EM-04-24, Palisades Critical Prediction and Critical Approach, Revision 8

- EM-09-20, Boric Acid Corrosion Control Program, Revision 2

- EN-IS-108, Working in Hot Environments, Revision 7

- GOP-14, Shutdown Cooling Operations, rev. 35 thru 38

- GOP-3, Mode 3 525° to Mode 2, Revision 26

- GOP-8, Power Reduction and Plant Shutdown to Mode 2 or Mode 3, Revision 24

- Procedure No. 1.04, Containment Entry and Egress, Revision 0

- Unit Restart Checklist for outage 1F2004CS 1R22 Surveillance Testing

- CR-PLP-2009-0236, As-Found Setpoint for PS-1495 was out of As-Found Tolerance, January 20, 2009

Attachment

- CR-PLP-2009-0254, Pressure Switch 1493 Inoperable when Adjusting Setpoint for EC-5885, January 21, 2009

- CR-PLP-2009-0330, NI and Delta-T Power Seemed Low Compared to Heat Balance Power, January 27, 2009

- Drawing M-214, Lube Oil, Fuel Oil, and Diesel Generator Systems, Revision 68

- DWO-1 att. 8, PCS inventory form, February 25, 2009

- DWO-1, Operators Daily/Weekly Items Modes 1,2,3, and 4, Revision 85

- UFSAR Section 6.1, Safety Injection System, Revision 27

- UFSAR Section 7.3, Engineered Safeguards Controls, Revision 27

- GOP-5, Power Escalation in Mode 1, Revision 34

- GOP-8, Power Reduction and Plant Shutdown to Mode 2 or Mode 3 >/= 525 degrees-F, Revision 24

- QO-1, Safety Injection System Basis Document, Revision 4

- QO-1, Technical Specification Surveillance Procedure, Safety Injection System, Revision 57

- QO-16, Inservice Test Procedure-Containment Spray Pumps, Revision 29

- SOP-28, Fuel Handling System, Revision 40

- Technical Specification Surveillance Procedure Basis Document for QO-16, Revision 16

- WO 51689147, QO-1 Safety Injection Actuation System Test 1EP06 Drill Evaluation

- First Quarter Emergency Planning Drill, February 11, 2009

- NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5 4OA1 Performance Indicator Verification

- CR-PLP-2008-01392, Found P-66A Supply Breaker Rear MOC Switch Bayonet Operator with

Broken Welds, March 26, 2008

- ESOMS HPSI log entry search, 2008

- NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5

- Palisades HPI MSPI Reports, first through fourth quarter 2008

- Palisades Maintenance Rule Performance Indicator Data for HPSI, 2008

- Palisades MSPI Basis Document, June 26, 2008 4OA2 Problem Identification and Resolution

- CR-PLP-2009-00528, MO-3064 Would Not Open from the Control Room, February 7, 2009

- EN-MA-118, Foreign Material Exclusion, Revision 4

- WO 00182099, MO-3064 Will Not Operate

- WO 51624934,52-237 Test Breaker/Starter 4OA5 Other Activities

- CR-PLP-2008-04104, Control Room Habitability Concerns with flow from the Stack to the

Turbine Building, October 3, 2008

- CR-PLP-2008-03626, Follow-up to Unexpected Gaseous Waste Monitoring High Radiation Alarm, August 25, 2008

- UFSAR Chapter 11, Radioactive Waste Management and Radiation Protection, Revision 25

- Ltr Palisades Nuclear Plant to NRC, Completion of Actions in Confirmatory Action Letter- Palisades Nuclear Plant Commitments to Address degraded Spent Fuel Pool Storage rack

Neutron Absorber, February 11, 2009

Attachment

- EA-APR-98-004, Analysis of Problems Concerning Fire Doors, rev. 2

- Ltr Palisades Nuclear Plant to NRC, Additional Actions taken to Address Confirmatory Action letter- Palisades Nuclear Plant Commitments to Address degraded Spent Fuel Pool Storage

rack Neutron Absorber, February 20, 2009

- SOP-28, Fuel Handling System, Revisions 38 and 39

- Palisades Nuclear Plan evaluation, May 2008

- Fuel Move Sheet for Spent Fuel Pool, February 23, 2009

- EM-04-29, Guidelines for Preparing Fuel Movement Plans, rev 6 and 7

Attachment

Attachment

LIST OF ACRONYMS USED AFW Auxiliary Feed Water CAL Confirmatory Action Letter CAP Corrective Action Program CFR Code of Federal Regulations

CR Condition Report

EDG Emergency Diesel Generator

FME Foreign Material Exclusion

GL Generic Letter HPSI High Pressure Safety Injection IMC Inspection Manual Chapter

K eff Effective Neutron Multiplication Factor MSPI Mitigating Systems Performance Index

NCV Non-Cited Violation NEI Nuclear Energy Institute NFPA National Fire Protection Association

NRC U.S. Nuclear Regulatory Commission

RFO Refueling Outage

SDP Significance Determination Process SFP Spent Fuel Pool TS Technical Specification

UFSAR Updated Final Safety Analysis Report

URI Unresolved Item