IR 05000255/2018416

NRC Inspection Report 05000255/2018416 and Investigation Report (3-2016-010) - Cover Letter Only (DRS-N.Egan)

ML19074A313
Person / Time
Site:	Palisades
Issue date:	03/15/2019
From:	O'Brien K NRC/RGN-III
To:	Arnone C Entergy Nuclear Operations
References
3-2016-010, EA-18-027 IR 2018416
Download: ML19074A313 (8)

Text

rch 15, 2019

SUBJECT:

PALISADES NUCLEAR PLANTNRC INSPECTION REPORT 05000255/2018416 AND INVESTIGATION REPORT (3-2016-010)

Dear Mr. Arnone:

This letter refers to the Nuclear Regulatory Commission (NRC) inspection and investigation conducted from July 28, 2016, to March 20, 2018, at the Palisades Nuclear Plant. The results of this inspection were discussed with you on March 15, 2019. The enclosed report presents the results of this inspection and investigation.

The NRCs investigation and inspection of activities at the Palisades Nuclear Plant were initiated to determine if your staffs failures to complete and to accurately document security patrols and fire tour activities constituted willful violations of NRC requirements. The NRCs conclusions in this matter were complicated by the overall programmatic weaknesses in your performance in this area, including apparent underlying deficiencies in training, procedures, and supervisory/

management oversight. Notwithstanding, the NRC did not determine that willful violations occurred.

Based on the results of this inspection and investigation, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The NRC is treating this violation as a Non-Cited Violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

Additionally, NRC inspectors documented a finding of very low security significance (Green) in this report. The finding involved a violation of NRC requirements. The NRC is treating this violation as a NCV consistent with Section 2.3.2.a of the Enforcement Policy.

Enclosures I contains Sensitive Unclassified Non-Safeguards Information. When separated from enclosure, this transmittal document is decontrolled. For the Green NCV, a cross-cutting aspect was assigned in the area of Human Performance-Field Presence. Specifically, the licensee failed to ensure leaders are commonly in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations were not corrected promptly.

Senior managers failed to ensure supervisory and management oversight of work activities, including contractors and supplemental personnel [H.2].

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; the Director, Office of Nuclear Security and Incident Response; and the NRC resident inspector at the Palisades Nuclear Plant.

If you disagree with the cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III, and the NRC Resident Inspector at Palisades Nuclear Plant.

This letter will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.

However, Enclosure I of this report contains Security-Related Information, so Enclosure I will not be made publically available in accordance with 10 CFR 2.390(d)(1). If you choose to provide a response that contains Security-Related Information, please mark your entire response Security-Related Information-Withhold from public disclosure under 10 CFR 2.390 in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). The NRC is waiving the affidavit requirements for your response in accordance with 10 CFR 2.390(b)(1)(ii).

You should note that final NRC documents, including the final Office of Investigations report, may be made available to the public under the Freedom of Information Act (FOIA) subject to redaction of information pursuant to the FOIA. Requests under the FOIA should be made in accordance with 10 CFR 9.23, Request for Records. The instructions for making a request for information under the FOIA are accessible at http://www.nrc.gov/reading-rm/foia/foia-request.html. Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

/RA Nathan Sanfilippo Acting for/

Kenneth G. OBrien, Director Division of Reactor Safety Docket No. 50-255 License No. DPR-20 Nonpublic Enclosure:

1. DRS IR 05000255/2018416 Public Enclosure:

2. DRP IR 05000255/2018416 cc w/o encl 1: Distribution via LISTSERV cc w/encl 1 and 2: D. Asselin, State Liaison Officer, State of Michigan

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting an inspection at the Palisades Nuclear Plant in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/

operating/oversight.html for more information. The NRC and self-revealed findings, violations, and additional items are summarized in the table below. There were no Licensee-identified violations.

List of Findings and Violations Security-Related Information Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable Severity Level IV Not Applicable

NCV 05000255/2018416-01 Open/Closed EA 18-027 Security-Related Information Security-Related Information Cornerstone Significance Cross-Cutting Aspect Report Section Security Green H.2 - Human

NCV 05000255/2018416-02 Performance, Field Opened/Closed Presence EA 18-027 Security-Related Information Additional Tracking Items Type Issue Number Title Report Section Status URI 05000255/2016404-02 Security-Related Information 1 Closed Type Issue Number Title Report Section Status URI 05000255/2016003-02 Hourly Fire Tour Discrepancies 71152 Closed 2

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Currently, approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2515, Light-Water Reactor Inspection Program-Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71152Problem Identification and Resolution

Annual Follow-Up of Selected Issues The inspectors reviewed the licensees implementation of its Corrective Action Program and the licensees actions related to the following issues:

(1) CR-PLP-2016-02650, A Review of Fire Tours Reported As Completed by Security Personnel Found Discrepancies in What was Reported; and

(2) Unresolved Item (URI)05000255/2016003-02, Hourly Fire Tour Discrepancies.

No inspection samples were completed

INSPECTION RESULTS

71152Problem Identification and Resolution URI Hourly Fire Tour Discrepancies IP 71152 (Closed) 0500255 /2016003-02

Description:

The inspectors documented an URI in IR 2016003 when they identified discrepancies in the licensees fire tour log sheets. The inspectors identified numerous areas on the fire tour log sheets that were annotated as complete, yet there were no corresponding badge records for these areas.

On April 6, 2016, the NRC issued a Confirmatory Order EA-15-100 to the Waterford Steam Electric Station, Unit 3 (ML16096A474) associated with deliberate violations related to fire watches that occurred between July 2013 and April 2014. The Confirmatory Order discussed actions required for Waterford and all other Entergy Nuclear Fleet sites, including Palisades.

Palisades was working to complete these actions at the time this issue was identified.

However, the licensees root cause evaluation identified programmatic, training, and organizational gaps with this issue that were specific to Palisades. These gaps resulted in site-specific corrective actions to prevent recurrence in addition to the actions required for the Confirmatory Order. The licensees root cause evaluation also identified that a contributing cause of this event was that Palisades Security managements response to operating experience from Waterford in 2014 did not validate that the vulnerability from the operating experience existed at Palisades, which allowed the aforementioned performance gaps to go unrecognized.

Corrective Action Reference: CR-PLP-2016-02650 Closure Basis: The concerns identified by the inspectors were consistent with the issues identified in Confirmatory Order EA-15-100. The order was open at the time that the issues at Palisades were identified. Therefore, the inspectors issues of concern are being closed to Confirmatory Order EA-15-100.

Observation 71152 As discussed in NRC Inspection Report (IR) 05000255/2017001 and IR 05000255/2017004, the licensee completed a root cause evaluation for this issue and identified corrective actions to prevent recurrence. Additionally, the licensee determined contributing causes and associated corrective actions.

The licensee also conducted effectiveness reviews to ensure that the corrective actions for the root causes and contributing causes adequately addressed the gaps identified in the root cause evaluation. These effectiveness reviews included:

(1) a review of changes to the fleet and station procedures associated with the conduct of fire tours to ensure that all elements of the corrective actions to prevent recurrence were included and interviews of responsible individuals to affirm their knowledge of their responsibilities within the procedures; and

(2) conduct of fire tour observations to assess performance of fire tours. The inspectors reviewed the results of these effectiveness review and did not identify any gaps associated with the implementation of corrective actions.

EXIT MEETING AND DEBRIEFS The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

• On March 15, 2019, the inspectors presented the inspection and investigation results to Mr. Charles Arnone and other members of the licensee staff.

DOCUMENTS REVIEWED

71152Problem Identification and Resolution

- CR-PLP-2016-02650; Discrepancies Found During Review of Completed Fire Tours;

06/08/2016

- EN-OP-139; Fire Watch Program; Revision 1

- FPIP-4; Fire Protection Systems and Fire Protection Equipment; Revision 36

- LO-PLPLO-2016-00037; Effectiveness Reviews for Root Cause Evaluation,

CR-PLP-2016-02650; 06/16/2016

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