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| number = ML16337A098
| number = ML16337A098
| issue date = 12/02/2016
| issue date = 12/02/2016
| title = Palisades Nuclear Plant - NRC Temporary Instruction 2515/191, Mitigation Strategies, Spent Fuel Pool Instrumentation and Emergency Preparedness Inspection Report 05000255/2016008
| title = NRC Temporary Instruction 2515/191, Mitigation Strategies, Spent Fuel Pool Instrumentation and Emergency Preparedness Inspection Report 05000255/2016008
| author name = Stone A M
| author name = Stone A
| author affiliation = NRC/RGN-III/DRS/SS
| author affiliation = NRC/RGN-III/DRS/SS
| addressee name = Arnone C F
| addressee name = Arnone C
| addressee affiliation = Entergy Nuclear Operations, Inc
| addressee affiliation = Entergy Nuclear Operations, Inc
| docket = 05000255
| docket = 05000255
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 December 2, 2016  
{{#Wiki_filter:mber 2, 2016


Mr. Charles Arnone Vice President, Operations Entergy Nuclear Operations, Inc. Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
==SUBJECT:==
PALISADES NUCLEAR PLANTNRC TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES, SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS INSPECTION REPORT 05000255/2016008


SUBJECT: PALISADES NUCLEAR PLANT-NRC TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES, SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS INSPECTION REPORT 05000255/2016008
==Dear Mr. Arnone:==
On November 16, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans inspection at your Palisades Nuclear Plant. The NRC inspection team discussed the results of this inspection with Mr. M. Lee and other members of your staff. The enclosed report represents the results of this inspection.


==Dear Mr. Arnone:==
The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.
On November 16, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed Temporary Instruction (TI) 2515/191, "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans" inspection at your Palisades Nuclear Plant. The NRC inspection team discussed the results of this inspection with Mr. M. Lee and other members of your staff. The enclosed report represents the results of this inspection. The inspection examined activities conducted un der your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commission's rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel. The NRC inspectors did not identify any findings or violations of more than minor significance. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding,"
of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,/RA/
The NRC inspectors did not identify any findings or violations of more than minor significance. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Ann Marie Stone, Team Leader Technical Support Staff


Division of Reactor Projects Docket No. 50-255 License No. DPR-20  
Sincerely,
/RA/
Ann Marie Stone, Team Leader Technical Support Staff Division of Reactor Projects Docket No. 50-255 License No. DPR-20


===Enclosure:===
===Enclosure:===
Inspection Report 05000255/2016008 cc: Distribution via LISTSERV
Inspection Report 05000255/2016008


Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-255 License No: DPR-20 Report No: 05000255/2016008 Licensee: Entergy Nuclear Operations, Inc. Facility: Palisades Nuclear Plant Location: Covert, MI Dates: September 26 through November 16, 2016
REGION III==
Docket No: 50-255 License No: DPR-20 Report No: 05000255/2016008 Licensee: Entergy Nuclear Operations, Inc.


Inspectors: J. Boettcher, Resident Inspector (Team Lead) B. Bartlett, Project Engineer J. Benjamin, Senior Reactor Inspector S. Sheldon, Project Engineer  
Facility: Palisades Nuclear Plant Location: Covert, MI Dates: September 26 through November 16, 2016 Inspectors: J. Boettcher, Resident Inspector (Team Lead)
B. Bartlett, Project Engineer J. Benjamin, Senior Reactor Inspector S. Sheldon, Project Engineer Approved by: A. Stone, Team Leader Technical Support Staff Division of Reactor Projects Enclosure


Approved by: A. Stone, Team Leader Technical Support Staff Division of Reactor Projects 2
=SUMMARY=
Inspection Report 05000255/2016008, 09/26/2016 - 09/30/2016, Palisades Nuclear Plant;


=SUMMARY=
Temporary Instruction 2515/191 Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans.
Inspection Report 05000255/2016008, 09/26/2016 - 09/30/2016, Palisades Nuclear Plant; Temporary Instruction 2515/191 Implementation of Mitigation Strategies and Spent Fuel Pool  


Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans. This inspection was performed by a resident inspector and three U.S. Nuclear Regulatory Commission (NRC) regional inspectors. No findings of significance or violations of NRC requirements were identified during this inspection. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter (IMC) 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated July 2016.
This inspection was performed by a resident inspector and three U.S. Nuclear Regulatory Commission (NRC) regional inspectors. No findings of significance or violations of NRC requirements were identified during this inspection. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter (IMC) 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated July 201


===NRC-Identified and Self-Revealing Findings===
===NRC-Identified and Self-Revealing Findings===


None 3
None


=REPORT DETAILS=
=REPORT DETAILS=
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==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
{{a|4OA5}}
{{a|4OA5}}
==4OA5 Other Activities (Temporary Instruction 2515/191) The objective of Temporary Instruction (TI) 2515/191, "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency==
==4OA5 Other Activities (Temporary Instruction 2515/191)==
 
The objective of Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify the licensee has adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (Agencywide Documents Access Management System (ADAMS) Accession No. ML15351A351), the licensees supplement to the notification of full compliance (ADAMS Accession No. ML16083A285), and the U.S. Nuclear Regulatory Commissions (NRCs) safety evaluation (ADAMS Accession No.
 
ML16014A318) and to verify the licensee installed reliable water-level measurement instrumentation in their spent fuel pool (SFP). The purpose of this TI was also to verify the licensee had implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure staffing is sufficient and communications can be maintained during such an event.


Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans," is to verify the licensee has adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (Agencywide Documents Access Management System (ADAMS) Accession No. ML15351A351), the licensee's supplement to the notification of full compliance (ADAMS Accession No. ML16083A285), and the U.S. Nuclear Regulatory Commission's (NRC's) safety evaluation (ADAMS Accession No. ML16014A318) and to verify the licensee installed reliable water-level measurement instrumentation in their spent fuel pool (SFP). The purpose of this TI was also to verify the licensee had implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure staffing is sufficient and communications can be maintained during such an event. The inspection also verifies plans for complying with NRC Orders EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML12054A736) and EA-12-051, "Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation" (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, "Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned," dated March 27, 2013, (ADAMS Accession No. ML12339A262). The inspectors discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify the strategies could be implemented as stated in the licensee's submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged.
The inspection also verifies plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (ADAMS Accession No. ML12054A736) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS Accession No. ML12339A262).


Specific details of the team's inspection activities are described in the following sections.
The inspectors discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify the strategies could be implemented as stated in the licensees submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged.
 
Specific details of the teams inspection activities are described in the following sections.


===.1 Mitigation Strategies for Beyond-Design Basis External Events===
===.1 Mitigation Strategies for Beyond-Design Basis External Events===


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors examined the licensee's established guidelines and implementing procedures for the beyond-design basis mitigation strategies. The inspectors assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The inspectors selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios. The inspectors verified a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and periodic equipment inventories were in place and being conducted. Additionally, the inspectors examined the introductory and planned periodic/refresher training provided to the Operations staff most likely to be tasked with implementation of the FLEX mitigation strategies. The inspectors also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel. Documents reviewed are listed in the attachment. b. Assessment Based on samples selected for review, the inspectors verified the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-049. The inspectors verified the licensee satisfactorily:
The inspectors examined the licensees established guidelines and implementing procedures for the beyond-design basis mitigation strategies. The inspectors assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The inspectors selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.
 
The inspectors verified a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and periodic equipment inventories were in place and being conducted. Additionally, the inspectors examined the introductory and planned periodic/refresher training provided to the Operations staff most likely to be tasked with implementation of the FLEX mitigation strategies. The inspectors also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel. Documents reviewed are listed in the attachment.
 
b. Assessment Based on samples selected for review, the inspectors verified the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-049. The inspectors verified the licensee satisfactorily:
* developed and issued FLEX Support Guidelines (FSG) to implement the FLEX strategies for postulated external events;
* developed and issued FLEX Support Guidelines (FSG) to implement the FLEX strategies for postulated external events;
* integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;
* integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;
* protected FLEX equipment from site-specific hazards;
* protected FLEX equipment from site-specific hazards;
* developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;
* developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;
* trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and
* trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and
* developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations. The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program as appropriate.
* developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.
 
The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program as appropriate.


====c. Findings====
====c. Findings====
Line 78: Line 93:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors examined the licensee's newly installed SFP instrumentation. Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel were physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.
The inspectors examined the licensees newly installed SFP instrumentation.
 
Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel were physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.


b. Assessment Based on samples selected for review, the inspectors determined the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-051. The inspectors verified the licensee satisfactorily:
b. Assessment Based on samples selected for review, the inspectors determined the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-051. The inspectors verified the licensee satisfactorily:
* installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal(s)and safety evaluation;
* installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal(s)and safety evaluation;
* installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittal(s); and
* installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittal(s); and
* trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation. The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
* trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.
 
The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.


====c. Findings====
====c. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
Through discussions with plant staff, review of documentation and plant walk downs, the inspectors verified the licensee has implemented required changes to staffing, communications equipment and facilities to support a multi-unit extended loss of alternating current power (ELAP) scenario as described in the licensee's staffing
Through discussions with plant staff, review of documentation and plant walk downs, the inspectors verified the licensee has implemented required changes to staffing, communications equipment and facilities to support a multi-unit extended loss of alternating current power (ELAP) scenario as described in the licensees staffing assessment and the NRC safety assessment. The inspectors also verified the licensee has implemented multi-unit dose assessment (including releases from SFPs) capability using the licensees site-specific dose assessment software and approach as described in the licensees multi-unit dose assessment submittal. Documents reviewed are listed in the attachment.


assessment and the NRC safety assessment. The inspectors also verified the licensee has implemented multi-unit dose assessment (including releases from SFPs) capability using the licensee's site-specific dose assessment software and approach as described in the licensee's multi-unit dose assessment submittal. Documents reviewed are listed in the attachment. b. Assessment The inspectors reviewed information provided in the licensee's multi-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all alternating current power to all site units and impedes access to the site. The inspectors verified the following:
b. Assessment The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all alternating current power to all site units and impedes access to the site. The inspectors verified the following:
* the licensee satisfactorily implemented required staffing change(s) to support a multi-unit ELAP scenario;
* the licensee satisfactorily implemented required staffing change(s) to support a multi-unit ELAP scenario;
* EP communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and
* EP communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and
* the licensee implemented multi-unit dose assessment capabilities (including releases from SFPs) using the licensee's site-specific dose assessment software and approach. The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
* the licensee implemented multi-unit dose assessment capabilities (including releases from SFPs) using the licensees site-specific dose assessment software and approach.
 
The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.


====c. Findings====
====c. Findings====
No findings were identified.
No findings were identified.
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Management Meeting Exit Meeting Summary On November 16, 2016, the inspectors presented the inspection results to Mr. M. Lee and other members of the licensee's staff.==
==4OA6 Management Meeting==
The licensee acknowledged the issues presented. The inspectors confirmed none of the potential report input discussed was considered proprietary. ATTACHMENT:
 
===Exit Meeting Summary===
 
On November 16, 2016, the inspectors presented the inspection results to Mr. M. Lee and other members of the licensees staff. The licensee acknowledged the issues presented. The inspectors confirmed none of the potential report input discussed was considered proprietary.
 
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 108: Line 134:
==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==


Licensee  
Licensee
: [[contact::C. Arnone]], Site Vice President  
: [[contact::C. Arnone]], Site Vice President
: [[contact::A. Williams]], General Manager Plant Operations  
: [[contact::A. Williams]], General Manager Plant Operations
: [[contact::T. Mulford]], Operations Manager  
: [[contact::T. Mulford]], Operations Manager
: [[contact::B. Baker]], Operations Manager - Shift  
: [[contact::B. Baker]], Operations Manager - Shift
: [[contact::J. Borah]], Engineering Manager, Systems and Components  
: [[contact::J. Borah]], Engineering Manager, Systems and Components
: [[contact::T. Davis]], Regulatory Assurance  
: [[contact::T. Davis]], Regulatory Assurance
: [[contact::B. Dotson]], Regulatory Assurance  
: [[contact::B. Dotson]], Regulatory Assurance
: [[contact::J. Erickson]], Regulatory Assurance  
: [[contact::J. Erickson]], Regulatory Assurance
: [[contact::O. Gustafson]], Director of Regulatory and Performance Improvement  
: [[contact::O. Gustafson]], Director of Regulatory and Performance Improvement
: [[contact::J. Hardy]], Regulatory Assurance Manager  
: [[contact::J. Hardy]], Regulatory Assurance Manager
: [[contact::J. Haumersen]], Site Projects and Maintenance Services Manager  
: [[contact::J. Haumersen]], Site Projects and Maintenance Services Manager
: [[contact::G. Heisterman]], Maintenance Manager  
: [[contact::G. Heisterman]], Maintenance Manager
: [[contact::M. Lee]], Operations Manager - Support  
: [[contact::M. Lee]], Operations Manager - Support
: [[contact::D. Lucy]], Outage Manager  
: [[contact::D. Lucy]], Outage Manager
: [[contact::D. Malone]], Emergency Planning Manager  
: [[contact::D. Malone]], Emergency Planning Manager
: [[contact::W. Nelson]], Training Manager  
: [[contact::W. Nelson]], Training Manager
: [[contact::D. Nestle]], Radiation Protection Manager
: [[contact::D. Nestle]], Radiation Protection Manager
: [[contact::K. O'Connor]], Engineering Manager, Design and Programs  
: [[contact::K. OConnor]], Engineering Manager, Design and Programs
: [[contact::C. Plachta]], Nuclear Independent Oversight Manager  
: [[contact::C. Plachta]], Nuclear Independent Oversight Manager
: [[contact::P. Russell]], Site Engineering Director  
: [[contact::P. Russell]], Site Engineering Director
: [[contact::M. Schultheis]], Performance Improvement Manager  
: [[contact::M. Schultheis]], Performance Improvement Manager
: [[contact::M. Soja]], Chemistry Manager  
: [[contact::M. Soja]], Chemistry Manager
: [[contact::J. Tharp]], Security Manager  
: [[contact::J. Tharp]], Security Manager
: [[contact::U.S. Nuclear Regulatory Commission A. Stone]], Team Leader, Technical Support Staff
U.S. Nuclear Regulatory Commission
: [[contact::A. Stone]], Team Leader, Technical Support Staff


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==


===Opened===
===Opened===
None  
 
None
 
===Closed===
===Closed===
: None  
 
None


===Discussed===
===Discussed===


None
None


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
The following is a partial list of documents reviewed during the inspection.
: Inclusion on this list does not imply the NRC inspector reviewed the documents in their entirety, but rather that selected sections or portions of the documents were evaluated as part of the overall inspection effort.
: Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
===Condition Reports===
: Initiated as a Result of the Inspection -
: CR-HQN-2016-01215, It Was Discovered that Two Copies of the Palisades FLEX FIP Exist, September 27, 2016 -
: CR-PLP-2016-04603, It Was Discovered that the Labels on Both the FLEX Diesel Generators are Incorrect, September 28, 2016 -
: CR-PLP-2016-04610, Walkdown Discovered that the Labels on the FLEX Diesel Generators are Incorrect, September 28, 2016 -
: CR-PLP-2016-04638, Flooding Level in A Flex Building Question, September 29, 2016
-
: CR-PLP-2016-04641, A Later Version of Staffing Assessment, Revision 2, was Discovered, September 29, 2016 -
: CR-PLP-2016-04643, NRC Identified, Incorrect Value to Fill Tank T-81, September 29, 2016 -
: CR-PLP-2016-04650, No Specific Operator Guidance for Flex Hose Minimum Bend Radius, September 29, 2016 
===Condition Reports===
: Reviewed -
: CR-HQN-2015-00345, Potential Concern with the Instrumentation for Spent Fuel Pool Level Monitoring, April 9, 2015 -
: CR-HQN-2016-00164, Fukushima Project:
: Uninterruptable Power Supply Rated Battery Life, February 9, 2016 -
: CR-PLP-2015-02436, Cables do not Appear to Connect to the Generator, June 11, 2015
-
: CR-PLP-2015-02482, Tracking of NRC FLEX/SFPI Audit Follow-up Items, June 16, 2015 -
: CR-PLP-2015-05627, Broken Weld on "A" FLEX Generator, November 11, 2015 -
: CR-PLP-2015-05750, Breaker 11 was Found in Trip Free Condition, November 19, 2015
-
: CR-PLP-2016-00127,
: LI-2141 Spent Fuel Level Indicator Blank Screen, January 7, 2016
-
: CR-PLP-2016-01079, Uninterruptable Power Supply Battery Life Error, March 2, 2016
-
: CR-PLP-2016-01224, The Rating of the Generators in the FIP are Wrong, March 10, 2016 -
: CR-PLP-2016-01364, K-2 FLEX Diesel Generator Fuel Oil Level Low, March 19, 2016 -
: CR-PLP-2016-01655,
: LI-2141 Spent Fuel Level Indicator Blank Screen, April 5, 2016
-
: CR-PLP-2016-01740, Trend with
: LI-2141 Spent Fuel Level Indicator Blank Screen, April 12, 2016 -
: CR-PLP-2016-01902,
: LI-2141 Spent Fuel Level Indicator Time Incorrect, April 21, 2016
-
: CR-PLP-2016-02248, K-1 FLEX Diesel Generator Trailer Wiring Harness is Damaged, May 14, 2016 -
: CR-PLP-2016-02451, Satellite Phone Cords Failed, May 26, 2016
-
: CR-PLP-2016-02985,
: LI-2141 Spent Fuel Level Indicator Blank Screen, June 29, 2016
-
: CR-PLP-2016-03992,
: LI-2141 Spent Fuel Level Indicator Time Incorrect, August 25, 2016
-
: CR-PLP-2016-04564, NSRCs Declared Degraded but Operational due to the Inability of Two or More 4160VAC Portable Generators to Perform Load Sharing, September 26, 2016 
===Calculations===
-
: EA-GOTHIC-AFW-01, Auxiliary Feedwater Pump Room Heat Up Analysis, Revision 0 -
: EA-EC46465-08, Freezing of Coolant Sources for FLEX Event, Revision 0
-
: EA-EC46465-14, T-2 Inventory Makeup Capability of AFW with T-81 Gravity Feed, Revision 0 -
: EA-EC46467-04, Sliding and Rocking Evaluation of FLEX Storage Building-A Equipment, Revision 1 
===Drawings===
- B213781, 2500 kVA Transformer Outline Drawing for Graybar, Revision 0 - E-1 Sh. A, Single Line Meter and Relay Diagram, Revision 12 - E-44 Sh. 156, Lighting Panel Schedule Panel L-76, Revision 7 - E-44 Sh. 105, Lighting Panel Schedule Panel L-258, Revision 6 Miscellaneous Documents - Enercon Report, Flex Portable Hose Failure Extent of Condition Review - Letter of Agreement Between Entergy Nuclear Operations, Inc., as Agent for Entergy Nuclear Palisades, LLC, Owner of Palisades Nuclear Power Plant and Andrews University Airpark
: Airport Authority, September 15, 2014 - Letter to the NRC from Anthony J. Vitale, Response to NRC Request for Information Pursuant to 10
: CFR 50.54(f) Regarding Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment, May 19, 2015 - Letter to the NRC from Anthony J. Vitale, Notification of Full Compliance with NRC Order
: EA-12-049, "Order Modifying Licenses with Regar
d to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," December 16, 2015 - Letter to the NRC from Anthony J. Vitale, Notification of Full Compliance with NRC Order
: EA-12-049, "Order Modifying Licenses with Regar
d to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," December 16, 2015 - Letter to Vice President, Operations at Entergy Nuclear Operations, Inc. from Mandy Halter, NRC/NRR, Palisades Nuclear Plant - Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders
: EA-12-049
and
: EA-12-051 (CAC Nos. MF0768 and MF0769), August 22, 2016  -
: LO-HWNLO-2015-0001, Phase 2 Communicati ons Assessment Fukushima Project, April 19, 2016 - M0204-0161, MOHR Vendor Manual SFPI Level Indication, Revision 0
-
: Memorandum of Understanding Between West Michigan Airport Authority and Entergy Nuclear Operations, Inc., as Agent for Entergy Nuclear Palisades, LLC, Owner of Palisades Nuclear Power Plant, September 15, 2014 - MSP/EMHSD Response Procedure #22 b, Emer gency Operation Center Extended Loss AC Power Response Plan, August 2015 - Mutual Assistance Agreement Between DTE Energy Electric Company, Entergy Nuclear Palisades, LLC and Indiana Michigan Power -
: PLP-RPT-13-00050, Turbine Driven Auxiliary Feedwater (TDAFW) Upgrade Evaluation for FLEX, Revision 0 -
: PLP-RPT-14-00030, Report of Geotechnical Exploration FLEX Equipment Storage Building, Revision 0 -
: PLP-RPT-15-00049, Palisades Final Integrated Plan for FLEX Implementation, Revision 0
-
: PLP-RPT-15-00049, Palisades Final Integrated Plan for FLEX Implementation, Revision 1 - Palisades Nuclear Plant FLEX Validation, September 28, 2015 
- Palisades Nuclear Plant IPEEE, Revision 1 - Palisades Nuclear Plant
: NEI 12-01 / Phase 2 Staffing Assessment, Revision 1
- Palisades Nuclear Plant
: NEI 12-01 / Phase 2 Staffing Assessment, Revision 2 - SAFER Response Plan for Palisades Nuclear Plant, Revision 1 - Snapshot Assessment: Pre-NRC Fukushima Lessons Learned, Une 21, 2016
-
: WCAP-17601-P, Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering, and Babcock & Wilcox NSSS Designs, Revision 0 Modifications -
: EC 46465, FLEX Basis (Base/Parent EC), Revision 0 -
: EC 46466, Spent Fuel Pool Instrumentation, Revision 0
-
: EC 46467, Storage Buildings, Revision 0 -
: EC 47490, EP Communications, Revision 0 -
: EC 63992, Capacity of Turbine Building Uninterruptable Power Supply, Revision 0 -
: EC 66731, FLEX Hose Bend Radius Evaluation, Revision 0 
===Procedures===
-
: AOP-26, Loss of Spent Fuel Pool Cooling, Revision 3 -
: AOP-30,
: Loss of Shutdown Cooling, Revision 2
-
: AOP-38, Acts of Nature, Revision 6
-
: ARP-7, Auxiliary Systems Scheme
: EK-11 (C-13), Revision 96 -
: EI-6.0, Palisades Nuclear Plant Emergency Impl ementing Procedure Rapid Dose Calculation, Revision 16 -
: EI-6.9, Palisades Nuclear Plant Emergency Implementing Procedure Automated Dose Assessment Program, Revision 8 -
: EN-OP-201, Diverse and Flexible Coping Strategies (FLEX) Fleet Program Document, Revision 2 -
: EN-OP-201-05, Palisades FLEX Program Document, Revision 1 -
: EN-OP-202, Diverse and Flexible Coping Strategies (FLEX) Program Document Bases, Revision 0 -
: EN-OU-103, Long Range Outage Planning, Revision 3
-
: EN-WM-105, Planning, Revision 16
-
: EN-WM-109, Scheduling, Revision 10 -
: EOP-1.0, Standard Post-Trip Actions, Revision 18 -
: EOP-2.0, Reactor Trip Recovery, Revision 14
-
: EOP-3.0, Station Blackout Recovery, Revision 17
- EOP 8.0, Loss of Offsite PWR - Forced Circulation Recovery, Revision 19
- EOP 9.0,
: PC-2 PCS Press Control PORVS
: PC-2 Tree D, Revision 19
-
: FIG-1, FLEX Generator Staging and Operation, Revision 1 -
: FIG-2, FLEX Pump Staging and Operations, Revision 0 -
: FIG-3, Alternate SFP Makeup and Cooling, Revision 0
-
: FIG-4, Low Pressure Feedwater, Revision 0
-
: FIG-5, FLEX T-77 Boration Blending, Revision 0
-
: FIG-7, FLEX PCS Injection, Revision 0 -
: FIG-8, Alternate Ventilation, Revision 0 -
: FIG-9, Backup ADV Nitrogen Station 9 Operation, Revision 0
-
: FIG-10, Fuel Oil Transfer, Revision 0
-
: FIG-11, Service Water - NSRC (Phase 3), Revision 0 
-
: FIG-12, 4160 VAC Generator - NSRC (Phase 3), Revision 2 -
: FSG-1, Long Term Inventory Control, Revision 0
-
: FSG-4, ELAP DC Bus Load Shed and Management, Revision 0 -
: FSG-5, Initial Assessment and FLEX Equipment Staging, Revision 0 -
: FSG-5, Initial Assessment and FLEX Equipment Staging - Attachment 4, Ops Flowchart, Revision 0 -
: FSG-7, Loss of Vital Instrument or Control Power, Revision 1
-
: FSG-8, Alternate PCS Boration, Revision 0
-
: FSG-11, Alternate SFP Makeup and Cooling, Revision 0 -
: FSG-13, Transition from Flex Equipment, Revision 0 -
: FSG-14, Shutdown PCS Makeup, Revision 0
-
: FSG-15, Shutdown ELAP, Revision 0
-
: FSG-100, Beyond Design Bases External Event (BDBEE) with an Extended Loss of Offsite and Onsite Power (ELAP) Emergency Response, Revision 0 -
: FSG-101, BDBEE / EP Communications, Revision 1 -
: SOP-2A, Chemical and Volume Control System, Revision 86
-
: SOP-14, Service Water System, Revision 65
- Spent Fuel Pool Level Instrumentation (SFPI) Boric Acid Mitigation, January 14, 2014 - Spent Fuel Pool Level Instrumentation (SFPI) Channel Functional Check, January 14, 2014
: Training Documents -
: PLLP-NLO Training, FLEX Loader, Revision 0 -
: PLLP-OPS-FLEXOVER, FLEX Process & Equipment, Training Cycle 15B -
: PLLP-OPS-15D-01, Palisades Operations Cycle 15D Kickoff
-
: PLLP-OPS-FLEXGAP, FLEX Process & Equipment, Cycle 15E GAP Training 
===Work Orders===
-
: 00374145 04, FUK,
: EC-47345,
: BUS 19 Voltage & Phase Rotation Checks, October 4, 2015 -
: 00374147 04, FUK,
: EC-47345,
: BUS 20 Voltage & Phase Rotation Checks, September 29, 2015 -
: 00378594 16, FUK, (FLEX
: EC-46465) Verification of FLEX Pumps/Equip, August 26, 2015
-
: 00378594 17, FUK, (FLEX
: EC-46465) Verification of PH 2 Generator/Equip, August 27, 2015
-
: 00424932 01, FLEX Standby Periodic Maintenance (PM) - 6 Month Inspection -
: FEL-FLEX1B, April 19, 2016 -
: 00424934 01, FLEX Standby PM - 6 Month Functional - K-4-FLEX Generator, March 19, 2016 -
: 00424939 01, FLEX Standby PM - 6 Month Inspection - Tow Vehicle A, April 19, 2016
-
: 00424941 01, FLEX Standby PM - 6 Month Functional - C-910 Air Comp, April 19, 2016
-
: 52676484 01, FLEX Standby PM - 1 Yr Operational Test - P-1002 Pump (FSB B), April 19, 2016 -
: 52676487 01, FLEX Standby PM - 1 Yr Operational Test - K-1-FLEX Generator, April 19, 2016 -
: 52676489 01, FLEX Standby PM - 1 Yr Operational Test - K-2-FLEX Generator, April 19, 2016 -
: 52709100 01, Emergency Communications Test, Monthly, August 31, 2016
==LIST OF ACRONYMS==
: [[USED]] [[]]
: [[ADAMS]] [[Agencywide Documents Access Management System]]
: [[CFR]] [[Code of Federal Regulations]]
: [[ELAP]] [[Extended Loss of]]
: [[AC]] [[Power]]
: [[EP]] [[Emergency Preparedness]]
: [[FLEX]] [[Diverse and Flexible Coping Strategies]]
: [[FSG]] [[]]
: [[FLEX]] [[Support Guidelines]]
: [[IMC]] [[Inspection Manual Chapter]]
: [[NRC]] [[U.S. Nuclear Regulatory Commission]]
: [[PARS]] [[Publicly Available Records System]]
: [[PM]] [[Periodic Maintenance]]
SFP Spent Fuel Pool TI Temporary Instruction
C. Arnone    -2- In accordance with Title 10 of the Code of Federal Regulations
(10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding,"
of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public
inspection in the
: [[NRC]] [['s Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS).]]
: [[ADAMS]] [[is accessible from the]]
NRC Web site at  http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Ann Marie Stone, Team Leader
Technical Support Staff


Division of Reactor Projects
Docket No. 50-255 License No. DPR-20
Enclosure: Inspection Report 05000255/2016008 cc:  Distribution via
: [[LISTSE]] [[RV]]
}}
}}

Latest revision as of 17:57, 19 December 2019

NRC Temporary Instruction 2515/191, Mitigation Strategies, Spent Fuel Pool Instrumentation and Emergency Preparedness Inspection Report 05000255/2016008
ML16337A098
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/02/2016
From: Ann Marie Stone
NRC/RGN-III/DRS/SS
To: Arnone C
Entergy Nuclear Operations
References
IR 2016008
Download: ML16337A098 (16)
v • d • e


Text

mber 2, 2016

SUBJECT:

PALISADES NUCLEAR PLANTNRC TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES, SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS INSPECTION REPORT 05000255/2016008

Dear Mr. Arnone:

On November 16, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans inspection at your Palisades Nuclear Plant. The NRC inspection team discussed the results of this inspection with Mr. M. Lee and other members of your staff. The enclosed report represents the results of this inspection.

The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

The NRC inspectors did not identify any findings or violations of more than minor significance. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Team Leader Technical Support Staff Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 05000255/2016008

REGION III==

Docket No: 50-255 License No: DPR-20 Report No: 05000255/2016008 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Dates: September 26 through November 16, 2016 Inspectors: J. Boettcher, Resident Inspector (Team Lead)

B. Bartlett, Project Engineer J. Benjamin, Senior Reactor Inspector S. Sheldon, Project Engineer Approved by: A. Stone, Team Leader Technical Support Staff Division of Reactor Projects Enclosure

SUMMARY

Inspection Report 05000255/2016008, 09/26/2016 - 09/30/2016, Palisades Nuclear Plant;

Temporary Instruction 2515/191 Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans.

This inspection was performed by a resident inspector and three U.S. Nuclear Regulatory Commission (NRC) regional inspectors. No findings of significance or violations of NRC requirements were identified during this inspection. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter (IMC) 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated July 201

NRC-Identified and Self-Revealing Findings

None

REPORT DETAILS

OTHER ACTIVITIES

4OA5 Other Activities (Temporary Instruction 2515/191)

The objective of Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify the licensee has adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (Agencywide Documents Access Management System (ADAMS) Accession No. ML15351A351), the licensees supplement to the notification of full compliance (ADAMS Accession No. ML16083A285), and the U.S. Nuclear Regulatory Commissions (NRCs) safety evaluation (ADAMS Accession No.

ML16014A318) and to verify the licensee installed reliable water-level measurement instrumentation in their spent fuel pool (SFP). The purpose of this TI was also to verify the licensee had implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure staffing is sufficient and communications can be maintained during such an event.

The inspection also verifies plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (ADAMS Accession No. ML12054A736) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS Accession No. ML12339A262).

The inspectors discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify the strategies could be implemented as stated in the licensees submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged.

Specific details of the teams inspection activities are described in the following sections.

.1 Mitigation Strategies for Beyond-Design Basis External Events

a. Inspection Scope

The inspectors examined the licensees established guidelines and implementing procedures for the beyond-design basis mitigation strategies. The inspectors assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The inspectors selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

The inspectors verified a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and periodic equipment inventories were in place and being conducted. Additionally, the inspectors examined the introductory and planned periodic/refresher training provided to the Operations staff most likely to be tasked with implementation of the FLEX mitigation strategies. The inspectors also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel. Documents reviewed are listed in the attachment.

b. Assessment Based on samples selected for review, the inspectors verified the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-049. The inspectors verified the licensee satisfactorily:

  • developed and issued FLEX Support Guidelines (FSG) to implement the FLEX strategies for postulated external events;
  • integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;
  • protected FLEX equipment from site-specific hazards;
  • developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;
  • trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and
  • developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.

The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program as appropriate.

c. Findings

No findings were identified.

.2 Spent Fuel Pool Instrumentation

a. Inspection Scope

The inspectors examined the licensees newly installed SFP instrumentation.

Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel were physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.

b. Assessment Based on samples selected for review, the inspectors determined the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-051. The inspectors verified the licensee satisfactorily:

  • installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal(s)and safety evaluation;
  • installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittal(s); and
  • trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.

The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings were identified.

.3 Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walk downs, the inspectors verified the licensee has implemented required changes to staffing, communications equipment and facilities to support a multi-unit extended loss of alternating current power (ELAP) scenario as described in the licensees staffing assessment and the NRC safety assessment. The inspectors also verified the licensee has implemented multi-unit dose assessment (including releases from SFPs) capability using the licensees site-specific dose assessment software and approach as described in the licensees multi-unit dose assessment submittal. Documents reviewed are listed in the attachment.

b. Assessment The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all alternating current power to all site units and impedes access to the site. The inspectors verified the following:

  • the licensee satisfactorily implemented required staffing change(s) to support a multi-unit ELAP scenario;
  • EP communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and
  • the licensee implemented multi-unit dose assessment capabilities (including releases from SFPs) using the licensees site-specific dose assessment software and approach.

The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings were identified.

4OA6 Management Meeting

Exit Meeting Summary

On November 16, 2016, the inspectors presented the inspection results to Mr. M. Lee and other members of the licensees staff. The licensee acknowledged the issues presented. The inspectors confirmed none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

C. Arnone, Site Vice President
A. Williams, General Manager Plant Operations
T. Mulford, Operations Manager
B. Baker, Operations Manager - Shift
J. Borah, Engineering Manager, Systems and Components
T. Davis, Regulatory Assurance
B. Dotson, Regulatory Assurance
J. Erickson, Regulatory Assurance
O. Gustafson, Director of Regulatory and Performance Improvement
J. Hardy, Regulatory Assurance Manager
J. Haumersen, Site Projects and Maintenance Services Manager
G. Heisterman, Maintenance Manager
M. Lee, Operations Manager - Support
D. Lucy, Outage Manager
D. Malone, Emergency Planning Manager
W. Nelson, Training Manager
D. Nestle, Radiation Protection Manager
K. OConnor, Engineering Manager, Design and Programs
C. Plachta, Nuclear Independent Oversight Manager
P. Russell, Site Engineering Director
M. Schultheis, Performance Improvement Manager
M. Soja, Chemistry Manager
J. Tharp, Security Manager

U.S. Nuclear Regulatory Commission

A. Stone, Team Leader, Technical Support Staff

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED

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