IR 05000255/2017002

NRC Integrated Inspection Report and Exercise of Enforcement Discretion 05000255/2017002

ML17220A349
Person / Time
Site:	Palisades
Issue date:	08/08/2017
From:	Eric Duncan Region 3 Branch 3
To:	Arnone C Entergy Nuclear Operations
References
EA-17-115 IR 2017002
Download: ML17220A349 (62)

Text

UNITED STATES ust 8, 2017

SUBJECT:

PALISADES NUCLEAR PLANTNRC INTEGRATED INSPECTION REPORT AND EXERCISE OF ENFORCEMENT DISCRETION 05000255/2017002

Dear Mr. Arnone:

On June 30, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. On July 27, 2017, the NRC inspectors discussed the results of this inspection with yourself and other members of your staff. The enclosed report represents the results of this inspection.

A finding and associated violation of the licensees current site-specific licensing basis for tornado-generated missile protection was identified. Because this violation was identified during the discretionary period discussed in Enforcement Guidance Memorandum 15-002, Enforcement Discretion for Tornado Missile Protection Noncompliance, Revision 1, and because the licensee implemented interim compensatory measures and has planned final corrective actions, the NRC is exercising enforcement discretion by not issuing an enforcement action for the underlying 10 CFR Part 50, Appendix B, Criterion III, Design Control, violation.

The NRC inspectors did not identify any additional findings or violations of more than minor significance. This letter, its enclosure, and your response, (if any), will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Eric Duncan, Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20 Enclosure:

Inspection Report 05000255/2017002 cc: Distribution via LISTSERV

SUMMARY

Inspection Report (IR) 05000255/2027002, 04/01/2017 - 06/30/2017; Palisades Nuclear Plant;

Routine Integrated Inspection Report This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The Nuclear Regulatory Commissions (NRC's)program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 201

NRC-Identified

and Self-Revealed Findings None.

Licensee-Identified Violations

A violation of the licensees current site-specific licensing basis for tornado-generated missile protection was identified. Because this violation was identified during the discretionary period discussed in Enforcement Guidance Memorandum 15-002,

Enforcement Discretion for Tornado Missile Protection Noncompliance, Revision 1, and because the licensee implemented interim compensatory measures and has planned final corrective actions, the NRC is exercising enforcement discretion by not issuing an enforcement action for the underlying 10 CFR Part 50, Appendix B, Criterion III, Design Control, violation. This violation is discussed in Section 4OA3.1.

REPORT DETAILS

Summary of Plant Status

The plant operated at or near approximately 70 percent power until April 10, 2017, when the unit was reduced to approximately 55 percent power to remove the B cooling tower from service in preparation for refueling outage (RFO) 1R25. On April 11, 2017, power was raised to at or near 65 percent power. On April 18, 2017, the operators entered a coast down period in preparation for RFO 1R25. On April 23, 2017, the unit was taken offline to start RFO 1R25.

On May 17, 2017, the reactor was taken critical. Due to a leaking seal identified on control rod drive (CRD) mechanism 40, the reactor was shut down on the same day. On May 20, 2017, the reactor was taken critical and the plant was synchronized to the grid. The reactor achieved full power on May 26, 2017, and remained at or near full power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection

.1 Readiness of Offsite and Alternate AC Power Systems

a. Inspection Scope

The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate alternating current (AC) power systems during adverse weather were appropriate. The inspectors reviewed the licensees procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify that the appropriate information was being exchanged when issues arose that could impact the offsite power system. Examples of aspects considered in the inspectors review included:

• coordination between the TSO and the plant during off-normal or emergency events;

• explanations for the events;

• estimates of when the offsite power system would be returned to a normal state; and

• notifications from the TSO to the plant when the offsite power system was returned to normal.

The inspectors also verified that plant procedures addressed measures to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system prior to or during adverse weather conditions. Specifically, the inspectors verified that the procedures addressed the following:

• actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the plant would not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply;

• compensatory actions identified to be performed if it would not be possible to predict the post-trip voltage at the plant for the current grid conditions;

• re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide offsite power; and

• communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power was challenged.

Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed corrective action program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures.

This inspection constituted one readiness of offsite and alternate AC power systems sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

.2 Summer Seasonal Readiness Preparations

a. Inspection Scope

The inspectors performed a review of the licensees preparations for summer weather for selected systems, including conditions that could lead to an extended drought.

During the inspection, the inspectors focused on plant specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions.

Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR)and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed CAP items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures. The inspectors reviews focused specifically on the following plant systems:

• AC power systems; and

• Ultimate heat sink.

This inspection constituted one seasonal adverse weather sample as defined in IP 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

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

• Shutdown Cooling System;

• Boric Acid Addition Pathway; and

• Electrical Distribution.

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, UFSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports (CRs), 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 CAP with the appropriate significance characterization.

Documents reviewed are listed in the Attachment to this report.

These activities constituted three partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings 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:

• Fire Area #16: Component Cooling Water (CCW) pump room;

• Walkdowns of risk significant areas during RFO 1R25 higher risk plant operating state (HRPOS) #1;

• Fire Area #14: Containment, 590' elevation; and

• Fire Area #14: Containment, 607', 611', 625', and 649' elevations.

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 implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants 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 plants ability to respond to a security event.

Using the documents listed in the Attachment to this report, 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 licensees CAP.

Documents reviewed are listed in the Attachment to this report.

These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R07 Annual Heat Sink Performance

.1 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the licensees testing of shutdown cooling heat exchangers to verify that potential deficiencies did not mask the licensees ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors compared the licensees observations with acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results.

The inspectors also verified that test acceptance criteria considered differences between test conditions and design conditions. Documents reviewed for this inspection are listed in the Attachment to this report.

This annual heat sink performance inspection constituted one sample as defined in IP 71111.07-05.

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

From April 24, 2017, through May 6, 2017, the inspectors conducted a review of the implementation of the licensees Inservice Inspection (ISI) Program for monitoring degradation of the primary coolant system (PCS), steam generator (SG) tubes, emergency feedwater systems, risk-significant piping and components and containment systems.

The inspections described in Sections 1R08.1, 1R08.2, 1R08.3, 1R08.4 and 1R08.5 below constituted one ISI sample as defined in Inspection Procedure 71111.08-05.

.1 Piping Systems Inservice Inspection

a. Inspection Scope

The inspectors observed or reviewed records of the following non-destructive examinations (NDE) mandated by the American Society of Mechanical Engineers (ASME)

Section XI Code to evaluate compliance with the ASME Code Section XI and Section V requirements and if any indications and defects were detected, to determine if these were dispositioned in accordance with the ASME Code or an NRC approved alternative requirement:

• Encoded phased array ultrasonic testing (PAUT) of PCS weld: 1A cold leg branch connection weld PCS-30-RCL-1A-5/2 (WO 429824);

• Encoded PAUT of PCS weld: 1B cold leg branch connection weld PCS-30 RCL-1B-5/2 (WO 429825);

• Encoded PAUT of pressurizer weld: dissimilar metal weld PCS-6-PRS-1A1-1 (RV-1039) (WO 438006);

• Encoded PAUT of pressurizer weld: dissimilar metal weld PCS-4-PRS-1P1-1 (WO 437974);

• Ultrasonic testing (UT) for examination of the reactor vessel head penetrations; and

• Eddy current testing (ECT) of the reactor vessel head vent line and associated j-weld.

The inspectors reviewed the following examination records with recordable indications accepted for continued service to determine if acceptance was in accordance with the ASME Code Section XI or an NRC-approved alternative.

• UT of welds PCS-12-RCL-1A-11/2 in the PCS system; and

• UT of welds PCS-12-RCL-2A-11/3 in the PCS system.

The inspectors reviewed the following pressure boundary welds completed for risk-significant systems during the last refueling outage) to determine if the licensee applied the pre-service NDE and acceptance criteria required by ASME Code Section XI.

Additionally, the inspectors reviewed the welding procedure specification and supporting weld procedure qualification records to determine if the weld procedure was qualified in accordance with the requirements of the Construction Code and the ASME Code Section IX:

• ASME Code Category Class 2: Install new vent on high pressure safety injection Train 2 pump P-66A discharge vent root, MV-ES561 (WO 418130).

b. Findings

No findings were identified.

.2 Reactor Pressure Vessel Upper Head Penetration Inspection Activities

a. Inspection Scope

For the reactor vessel head, a non-visual examination of the head penetration nozzles was required pursuant to Title 10 of the Code of Federal Regulations (CFR),

Part 50.55a(g)(6)(ii)(D).

The inspectors observed the non-visual examinations conducted on a sample of the reactor vessel head penetration nozzles to determine if the activities were conducted in accordance with the requirements of ASME Code Case N-729 and 10 CFR 50.55a(g)(6)(ii)(D). In particular, the inspectors confirmed that:

• the required examination scope (volumetric and surface coverage) was achieved and limitations (if applicable were recorded) in accordance with the licensee procedures;

• the required examination for (wetted surface coverage) was achieved and limitations (if applicable were recorded) in accordance with the licensee procedures;

• the ultrasonic examination equipment and procedures used were demonstrated by blind demonstration testing;

• if indications or defects were identified, the licensee documented the conditions in examination reports and/or entered this condition into the corrective action system and implemented appropriate corrective actions;

• if indications were accepted for continued service the licensee evaluation and acceptance criteria were in accordance with the ASME Section XI Code; and

• 10 CFR 50.55a(g)(6)(ii)(D) or an NRC approved alternative.

The licensee did not perform any welded repairs to vessel head penetration nozzles since the beginning of the preceding outage. Therefore, no NRC review was completed for this inspection procedure attribute.

b. Findings

No findings were identified.

.3 Boric Acid Corrosion Control

a. Inspection Scope

On April 23, 2017, the inspectors observed the licensee staff performing visual examinations on portions of the of the PCS and connected systems within containment to determine if these visual examinations emphasized locations where boric acid leaks can cause degradation of safety significant components.

The inspectors reviewed the following licensee evaluations of PCS components with boric acid deposits to determine if degraded components were documented in the corrective action system and for degraded components that the planned or completed corrective actions met the Construction Code, ASME Section XI Code, and/or NRC-approved alternative.

• Boric acid evaluation for CR-PLP-2017-01001, Dry Boric Acid on SIT [Safety Injection Tank] T-82C Outlet Isolation Valve.

The inspectors reviewed the following corrective actions related to evidence of boric acid leakage to determine if the corrective actions completed were consistent with the requirements of the ASME Code Section XI and 10 CFR Part 50, Appendix B, Criterion XVI:

• CR-PLP-2017-00996, Control Rod Drive CRD-12 with Dry Boric Acid; and

• CR-PLP-2017-01695, Shutdown Cooling SDC Relief Valve RV-0401 with Dry Boric Acid.

b. Findings

No findings were identified.

.4 Steam Generator Tube Inspection Activities

a. Inspection Scope

The NRC inspectors observed acquisition of ET data observed ET data analysis, observed in-situ pressure test of SG B, tube 62-101, reviewed SG tube plugging and reviewed procedures implementing the SG ISI Program to determine if:

• in-situ SG tube pressure testing screening criteria used were consistent with those identified in the Electric Power Research Institute (EPRI) TR-107620, SG In-Situ Pressure Test Guidelines, and whether these criteria were properly applied to screen degraded SG tubes for in-situ pressure testing;

• in-situ pressure test records demonstrated the correct tube was selected and that pressure and hold times were consistent with EPRI TR-107620;

• in-situ pressure test results were properly applied to SG tube integrity performance criteria identified in TSs and EPRI 3002007571 - SG Integrity Assessment Guidelines;

• the numbers and sizes of SG tube flaws/degradation identified were bound by the licensees previous outage Operational Assessment predictions;

• the SG tube ET examination scope and expansion criteria were sufficient to meet the TSs, and EPRI 1003138, Pressurized Water Reactor SG Examination Guidelines;

• the SG tube ET examination scope included potential areas of tube degradation identified in prior outage SG tube inspections and/or as identified in NRC generic industry operating experience applicable to these SG tubes;

• the licensee identified new tube degradation mechanisms and implemented adequate extent of condition inspection scope and repairs for the new tube degradation mechanism;

• the licensee implemented repair methods which were consistent with the repair processes allowed in the plant TS requirements and implemented at appropriate tube locations;

• qualified depth sizing methods were applied to degraded tubes accepted for continued service;

• the licensee implemented an inappropriate plug on detection tube repair threshold (e.g., no attempt at sizing of flaws to confirm tube integrity);

• the primary-to-secondary leakage (e.g., SG tube leakage) was below three gallons-per-day or the detection threshold during the previous operating cycle;

• the ET probes and equipment configurations as documented on the Examination TS Sheets used to acquire/analyze data from the SG tubes were qualified to detect and/or size the known/expected types of SG tube degradation in accordance with Appendix H and I, Performance Demonstration for ET Examination, of EPRI 1003138;

• the licensee performed secondary side SG inspections for location and removal of foreign materials;

• the licensee implemented repairs or appropriately evaluated SG tubes damaged by foreign material; and

• inaccessible foreign objects were left within the secondary side of the SGs, and if so, whether the licensee implemented evaluations which included the effects of foreign object migration and/or tube fretting damage.

b. Findings

No findings were identified.

.5 Identification and Resolution of Problems

a. Inspection Scope

The inspectors performed a review of ISI/SG related problems entered into the licensees CAP and conducted interviews with licensee staff to determine if:

• the licensee had established an appropriate threshold for identifying ISI/SG-related problems;

• the licensee had identified issues related to excessive deposit buildup on the SG tube bundle and/or excessive SG tube wear indicative of fluid-elastic instability within the SG tube bundle;

• the licensee had performed a root cause (if applicable) and taken appropriate corrective actions; and

• the licensee had evaluated operating experience and industry generic issues related to ISI and pressure boundary integrity.

The inspectors performed these reviews to evaluate compliance with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements. The corrective action documents reviewed by the inspectors are listed in the Attachment to this report.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

On June 20, 2017, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crews 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 crews 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 simulator sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk

(71111.11Q)

a. Inspection Scope

On April 23, 2017, the inspectors observed reactor shutdown and cooldown activities in the main control room in preparation for the refueling outage. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms (if applicable);

• correct use and implementation of procedures;

• control board (or equipment) manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications (if applicable).

The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.3 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk

(71111.11Q)

a. Inspection Scope

On May 17, 2017 the inspectors observed reactor startup activities following the refueling outage in the main control room. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms (if applicable);

• correct use and implementation of procedures;

• control board (or equipment) manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications (if applicable).

The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

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

• Control room heating, ventilation and air conditioning.

The inspectors reviewed events including those 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

• verifying appropriate performance criteria for structures, systems, and components (SSCs)/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 one quarterly maintenance effectiveness sample as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 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:

• Emergent repairs to PCV-3027, pressure control valve for CV-3027, emergency core cooling system recirculation to safety injection/refueling water tank;

• risk evaluation for operating at reduced power in support of maintenance activities;

• higher risk plant operating state (HRPOS) associated with reduced inventory period #1;

• HRPOS associated with reduced inventory period #2;

• emergent work on LS-1453, 1-2 diesel generator (DG) control level switch, for failure to stop filling the diesel generator day tank; and

• movement and staging of FLEX equipment for RFO 1R25.

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.

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

These maintenance risk assessments and emergent work control activities constituted six samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functional Assessments

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• Immediate operability of containment spray pump P-54B after identification of overcurrent relay on breaker 152-112 outside of design basis;

• Operability evaluation of ED-01, left channel main station battery, after identification of base of a post on cell 46 was rising;

• Operability of 1-2 DG cabinet with improper latching bolts; and

• Initial operability evaluation of P-18A, fuel oil transfer pump failure to stop auto fill and LS-1453, 1-2 DG control level switch to initiate startup of P-18A at expected level.

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 Updated Final Safety Analysis Report (UFSAR) to the licensees 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 reviewed a sample 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 Attachment to this report.

This operability inspection constituted four samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

.2 Licensee Implementation of Enforcement Guidance Memorandum 15-002,

Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance On June 10, 2015, the NRC issued Regulatory Issue Summary 2015-06, Tornado Missile Protection, focusing on the requirements regarding tornado-generated missile protection and required compliance with the facility-specific licensing basis. The Regulatory Issue Summary also provided examples of noncompliance that had been identified through different mechanisms and referenced enforcement guidance memorandum (EGM)15-002, which was also issued on June 10, 2015. Revision 1 of EGM 15-002 was issued on February 7, 2017. The EGM provided guidance to allow the NRC staff to exercise enforcement discretion when an operating power plant licensee did not comply with the current licensing basis for tornado-generated missile protection. Specifically, the discretion applied to structures, systems, and components (SSCs) declared inoperable resulting in TS Limiting Condition for Operations (LCOs) that would require a reactor shutdown or mode change if the licensee could not meet the required actions within the TS completion time. The discretion allowed the licensee to re-establish operability through compensatory measures and established criteria for continued operation of the facility as longer term corrective actions were implemented.

The EGM stated that the bounding risk analysis performed for this issue concluded that this issue was of low risk significance and, in Palisades case, provided for enforcement discretion of up to three years from the date of issuance of the EGM.

Palisades was licensed prior to issuance of Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants (GDC). Specifically, GDC 2, Design Bases for Protection Against Natural Phenomena, and GDC 4, Environmental and Dynamic Effects Design Basis, discuss how licensees SSCs important to safety shall be designed to protect against natural phenomena such as tornadoes and shall be adequately protected against dynamic effects including missiles. The licensees site-specific licensing bases with regard to how they comply with the GDCs are described in the UFSAR. In particular, UFSAR Sections 5.1.2.2 and 5.1.2.4 describe how Palisades meets GDC 2 and GDC 4. Additional discussion on how Palisades protects SSCs against tornado-generated missiles can be found in UFSAR Section 5.5, Missile Protection.

On March 29, 2017, the licensee initiated condition reports (CRs)

CR-PLP-2017-01248, CR-PLP-2017-01249, CR-PLP-2017-01250, CR-PLP-2017-01251, CR-PLP-2017-01252, and CR-PLP-2017-01253, identifying a nonconforming condition of their site-specific licensing basis. Specifically, multiple vulnerabilities were identified where SSCs were not adequately protected from tornado-generated missiles. The licensee declared multiple SSCs inoperable and promptly implemented compensatory measures designed to reduce the likelihood of tornado-generated missile effects within the expiration time of the affected TS LCO required actions. The inspectors reviewed the licensees immediate and more comprehensive compensatory measures that included:

• review and revision of procedures for a tornado watch and a tornado warning to provide additional instructions for operators preparing for tornados and/or high winds, and a potential loss of SSCs vulnerable to the tornado missiles;

• confirmation of readiness of equipment and procedures dedicated to the Diverse and Flexible Coping Strategy (FLEX);

• verification that training was up to date for individuals responsible for implementing preparation and response procedures; and

• establishment of a heightened station awareness and preparedness relative to identified tornado missile vulnerabilities.

The condition was reported to the NRC as Event Notice 52647 as an unanalyzed condition and potential loss of safety function. The licensee documented the inoperability of the SSCs and the affected TS LCO conditions in the CAP and in the control room operating log. The licensee notified the NRC resident inspectors of implementation of EGM 15-002, and documented the implementation of the compensatory measures to establish the SSCs operable but nonconforming prior to expiration of the LCO required action. The enforcement discretion was applied to the required shutdown actions of the following TS LCOs:

• TS 3.0.3, General Shutdown LCO (cascading or by reference from other LCOs)

• TS 3.7.5, Auxiliary Feedwater System;

• TS 3.7.7, Component Cooling Water System;

• TS 3.7.8, Service Water System;

• TS 3.7.10, Control Room Ventilation Filtration;

• TS 3.7.11, Control Room Ventilation Cooling;

• TS 3.8.1, AC Sources - Operating; and

• TS 3.8.3, Diesel Fuel, Lube Oil, and Starting Air.

The comprehensive actions were to remain in place until permanent repairs are completed, or until the NRC dispositions the non-compliance in accordance with a method acceptable to the NRC such that discretion was no longer needed.

a. Inspection Scope

The inspectors reviewed the licensees immediate actions and compensatory measures to restore operability of the affected SSCs in accordance with Revision 1 of EGM 15-002. The inspectors review addressed the material issues in the plant, and whether the measures were implemented in accordance with the guidance documentation for the EGM. The inspectors also evaluated whether the measures as implemented would function as intended and were properly controlled. The inspectors did not review the underlying circumstances that resulted in the TS violations.

Additionally, the inspectors reviewed the licensees 60-day comprehensive compensatory measures. The inspectors concluded that those actions provided additional protection such that the likelihood of tornado missile effects were lessened.

This review constituted one operability sample as defined in IP 71111.15-02.

b. Findings

No findings were identified. Additional information regarding the non-conforming conditions and performance deficiencies associated with the tornado-generated missile vulnerability is discussed in Section 4OA3.1 of this report.

1R18 Plant Modifications

.1 Plant Modifications

a. Inspection Scope

The inspectors reviewed the following modifications:

• Air accumulator addition to CV-0910, containment cooling water (CCW) supply to containment (permanent); and

• overcurrent relay setting modification on breaker 152-112, P-54B containment spray pump (permanent).

The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening 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, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed are listed in the Attachment to this report.

This inspection constituted two permanent plant modification samples as defined in IP 71111.18-05.

b. Findings

No findings 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:

• QO-6 after CV-0780 atmospheric dump valve positioner replacement;

• VT-2 after E-54B, CCW heat exchanger inspection and tube plugging;

• tan-delta testing after C bus cable repairs;

• VT-2 after repairs to containment building fire water supply MV-SW264; and

• RO-22 and VT-2 after control rod drive CRD-40 seal repairs.

These activities were selected based upon the SSCs 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 TSs, the 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 five post-maintenance testing samples as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R20 Outage Activities

.1 Refueling Outage Activities

a. Inspection Scope

The inspectors reviewed the Outage Risk Assessment and contingency plans for RFO

1R25 , conducted April 23, 2017, to May 20, 2017, to confirm that the licensee had

appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenanceof 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:

• licensee configuration management, including maintenance of defense-in-depth commensurate with the outage safety plan for key safety functions and compliance with the applicable TS when taking equipment out of service;

• implementation of clearance activities and confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing;

• 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 safety plan requirements were met, and controls over switchyard activities;

• 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 TSs;

• licensee fatigue management, as required by 10 CFR 26, Subpart I;

• refueling activities, including fuel handling and sipping to detect fuel assembly leakage;

• startup and ascension to full power operation, tracking of startup prerequisites, walkdown of the primary containment to verify that debris had not been left which could block emergency core cooling system suction strainers, and reactor physics testing; and

• licensee identification and resolution of problems related to RFO activities.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one RFO sample as defined in IP 71111.20-05.

b. Findings

No findings 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:

• RO-105, safety injection tank valve full flow testing (routine);

• RO-11, containment high radiation surveillance test (routine);

• RT-8D, right train engineered safeguards systems test (routine);

• RO-32-14, CCW containment inlet local leak rate test (containment isolation valve);

• QO-16, C containment spray pump test (inservice test); and

• RO-22, control rod drop time testing (routine).

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

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

• acceptance criteria were clearly stated, demonstrated operational readiness, and were 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 was in accordance with TSs, the USAR, 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;

• 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 four routine surveillance testing samples, one in-service test sample, and one containment isolation valve sample as defined in IP 71111.22, Sections-02 and-05.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

.1 Radiological Hazard Assessment (02.02)

a. Inspection Scope

The inspectors assessed the licensees current and historic isotopic mix, including alpha emitters and other hard-to-detect radionuclides. The inspectors evaluated whether survey protocols were reasonable to identify the magnitude and extent of the radiological hazards.

The inspectors determined if there have been changes to plant operations since the last inspection that may have resulted in a significant new radiological hazard for onsite individuals. The inspectors evaluated whether the licensee assessed the potential impact of these changes and implemented periodic monitoring, as appropriate, to detect and quantify the radiological hazard. The inspectors reviewed the last two radiological surveys from selected plant areas and evaluated whether the thoroughness and frequency of the surveys were appropriate for the given radiological hazard.

The inspectors conducted walkdowns of the facility, including radioactive waste processing, storage, and handling areas to evaluate material conditions and performed independent radiation measurements as needed to verify conditions were consistent with documented radiation surveys.

The inspectors assessed the adequacy of pre-work surveys for select radiologically risk-significant work activities.

The inspectors evaluated the radiological survey program to determine if hazards were properly identified. The inspectors discussed procedures, equipment, and performance of surveys with radiation protection staff and assessed whether technicians were knowledgeable about when and how to survey areas for various types of radiological hazards.

The inspectors observed work in potential airborne areas to assess whether air samples were being taken appropriately for their intended purpose and reviewed various survey records to assess whether the samples were collected and analyzed appropriately. The inspectors also reviewed the licensees program for monitoring contamination, which has the potential to become airborne.

These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.2 Instructions to Workers (02.03)

a. Inspection Scope

The inspectors reviewed select radiation work permits used to access high radiation areas and evaluated the specified work control instructions or control barriers. The inspectors also assessed whether workers where made aware of the work instructions and area dose rates.

The inspectors reviewed electronic alarming dosimeter dose and dose rate alarm setpoint methodology. For selected electronic alarming dosimeter occurrences, the inspectors assessed the workers response to the alarm, the licensees evaluation of the alarm, and any follow-up investigations.

The inspectors reviewed the licensees methods for informing workers of changes in plant operations or radiological conditions that could significantly impact their occupational dose.

The inspectors reviewed the labeling of select containers of licensed radioactive material that could cause unplanned or inadvertent exposure to workers.

These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.3 Contamination and Radioactive Material Control (02.04)

a. Inspection Scope

The inspectors observed locations where the licensee monitors material leaving the radiologically controlled area and assessed the methods used for control, survey, and release of material from these areas. As available, the inspectors observed health physics personnel surveying and releasing material for unrestricted use.

The inspectors observed workers leaving the radiologically controlled area and assessed their use of tool and personal contamination monitors and reviewed the licensees criterial for use of the monitors.

The inspectors assessed whether instrumentation was used at its typical sensitivity levels based on appropriate counting parameters or whether the licensee had established a de facto release limit.

The inspectors selected several sealed sources from the licensees inventory records and assessed whether the sources were accounted for and verified to be intact. The inspectors also evaluated whether any transactions, since the last inspection, involving nationally tracked sources were reported in accordance with Title 10 of the Code of Federal Regulations, Part 20.2207.

These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.4 Radiological Hazards Control and Work Coverage (02.05)

a. Inspection Scope

The inspectors evaluated ambient radiological conditions during tours of the facility.

The inspectors assessed whether the conditions were consistent with applicable posted surveys, radiation work permits, and worker briefings.

The inspectors evaluated the adequacy of radiological controls, such as required surveys, radiation protection job coverage, and contamination controls. The inspectors evaluated the licensees use of electronic alarming dosimeters in high noise areas as high radiation area monitoring devices.

The inspectors assessed whether radiation monitoring devices were placed on the individuals body consistent with licensee procedures. The inspectors assessed whether the dosimeter was placed in the location of highest expected dose or that the licensee properly employed an NRC-approved method of determining effective dose equivalent.

The inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel in work areas with significant dose rate gradients.

For select airborne area radiation work permits, the inspectors reviewed airborne radioactivity controls and monitoring, the potential for significant airborne levels, containment barrier integrity, and temporary filtered ventilation system operation.

The inspectors examined the licensees physical and programmatic controls for highly activated or contaminated materials stored within pools and assessed whether appropriate controls were in place to preclude inadvertent removal of these materials from the pool.

These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.5 High Radiation Area and Very High Radiation Area Controls (02.06)

a. Inspection Scope

The inspectors observed posting and physical controls for high radiation areas and very high radiation areas to assess adequacy.

The inspectors conducted a selective inspection of posting and physical controls for high radiation areas and very high radiation areas to assess conformance with performance indicators.

The inspectors reviewed procedural changes to assess the adequacy of access controls for high and very high radiation areas to determine whether procedural changes substantially reduced the effectiveness and level of worker protection.

The inspectors assessed the controls for very high radiation areas and areas with the potential to become very high radiation areas. The inspectors also assessed whether individuals were unable to gain unauthorized access to these areas.

These inspection activities constituted a partial sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.6 Radiation Worker Performance and Radiation Protection Technician Proficiency (02.07)

a. Inspection Scope

The inspectors observed radiation worker performance and assessed their performance with respect to radiation protection work requirements, the level of radiological hazards present, and radiation work permit controls.

The inspectors assessed worker awareness of electronic alarming dosimeter set points, stay times, or permissible dose for radiologically significant work as well as expected response to alarms.

The inspectors observed radiation protection technician performance and assessed whether the technicians were aware of the radiological conditions and radiation work permit controls and whether their performance was consistent with training and qualifications for the given radiological hazards.

The inspectors observed radiation protection technician performance of radiation surveys and assessed the appropriateness of the instruments being used, including calibration and source checks.

These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.7 Problem Identification and Resolution (02.08)

a. Inspection Scope

The inspectors assessed whether problems associated with radiological hazard assessment and exposure controls were being identified at an appropriate threshold and were properly addressed for resolution. For select problems, the inspectors assessed the appropriateness of the corrective actions. The inspectors also assessed the licensees program for reviewing and incorporating operating experience.

The inspectors reviewed select problems related to human performance errors and assessed whether there was a similar cause and whether corrective actions taken resolve the problems.

The inspectors reviewed select problems related to radiation protection technician error and assessed whether there was a similar cause and whether corrective actions taken resolve the problems.

These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

.1 Implementation of ALARA and Radiological Work Controls (02.04)

a. Inspection Scope

The inspectors reviewed the radiological administrative, operational, and engineering controls planned for selected radiologically significant work activities and evaluated the integration of these controls and as-low-as-reasonably-achievable (ALARA)requirements into work packages, work procedures and/or radiation work permits.

The inspectors conducted observations of in-plant work activities and assessed whether the licensee had effectively integrated the planned administrative, operational, and engineering controls into the actual field work to maintain occupational exposure ALARA. The inspectors observed pre-job briefings, and determined if the planned controls were discussed with workers. The inspectors evaluated the placement and use of shielding, contamination controls, airborne controls, radiation work permit controls, and other engineering work controls against the ALARA plans.

The inspectors assessed licensee activities associated with work-in-progress to ensure the licensee was tracking doses, performed timely in-progress reviews, and, when jobs did not trend as expected, appropriately communicated additional methods to be used to reduce dose. The inspectors evaluated whether health physics and ALARA staff were involved with the management of radiological work control when in-field activities deviated from the planned controls. The inspectors assessed whether the Outage Control Center and station management provided sufficient support for ALARA re-planning.

The inspectors assessed the involvement of ALARA staff with emergent work activities during maintenance and when possible, attended in-progress review discussions, outage status meetings, and/or ALARA committee meetings.

The inspectors compared the radiological results achieved with the intended radiological outcomes and verified that the licensee captured lessons learned for use in the next outage.

These inspection activities constituted one complete sample as defined in IP 71124.02-05.

b. Findings

No findings were identified.

.2 Radiation Worker Performance (02.05)

a. Inspection Scope

The inspectors observed radiation worker and radiation protection technician performance during work activities being performed in radiation areas, airborne radioactivity areas, or high radiation areas to assess whether workers demonstrated the ALARA philosophy in practice and followed procedures. The inspectors observed radiation worker performance to evaluate whether the training and skill level was sufficient with respect to the radiological hazards and the work involved.

The inspectors interviewed individuals from selected work groups to assess their knowledge and awareness of planned and/or implemented radiological and ALARA work controls.

These inspection activities constituted one complete sample as defined in IP 71124.02-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Unplanned Power Changes per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Power Changes per 7000 Critical Hours performance indicator (PI) for the period from the second quarter 2016 through the first quarter 2017. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, condition reports, maintenance rule records, event reports and U.S. Nuclear Regulatory Commission (NRC) Integrated Inspection Reports for the period of April 2016 through March 2017 to validate the accuracy of the submittals.

The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one unplanned transients per 7000 critical hours sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Safety System Functional Failures

a. Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures PI for the period from the second quarter 2016 through the first quarter 2017. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73," definitions and guidance, were used. The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, condition reports, event reports and NRC Integrated Inspection Reports (IR)s for the period of April 2016 through March 2017 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one safety system functional failures sample as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees corrective action program at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed. Some minor issues were entered into the licensees corrective action program as a result of the inspectors observations; however, they are not discussed in 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.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector corrective action program item screening discussed in Section 4OA2.1 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of January 2017 through June 2017, although some examples expanded beyond those dates where the scope of the trend warranted.

The review also included issues documented outside the corrective action program in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees corrective action program trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

This review constituted one semi-annual trend review inspection sample as defined in IP 71152.

b. Observations The inspectors reviewed the licensees initiation of condition reports (CRs) to ensure that conditions adverse to quality were identified and receiving the appropriate level of oversight within the CAP. A decline in the implementation of some elements of the CAP, including initiation, was noted in CR-PLP-2016-02440 and CR-PLP-2016-02536.

During routine reviews of the CAP, the inspectors noted some examples where issues were either not entered into the CAP or there was a delay in the entry of issues into the CAP. Additionally, the site Nuclear Independent Oversight organization also identified an instance where identified issues were not entered into the CAP.

The inspectors discussed CAP trending, performance monitoring, and self-assessments with the licensees performance improvement personnel. The licensee discussed the decline in the implementation of some elements of the CAP and provided examples of initiation elements that had declined, such as housekeeping items. In response to the CRs noted above, the licensee discussed CAP requirements with personnel during site tailgate discussion. The inspectors also performed an independent review of operating logs to determine any instances where issues were not entered into the CAP. In general, issues were entered into the CAP in accordance with the procedural guidance in EN-LI-102, Corrective Action Program. Issues identified during the inspectors independent review of logs and CRs were discussed with the licensee.

c. Findings

No findings were identified.

.3 Annual Follow-Up of Selected Issues: Degraded Steam Generator B Tube

a. Inspection Scope

The inspectors selected the following condition report for an in-depth review:

• CR-PLP-2017-02177, Axial Crack Identified in SG-E-50 B Tube As appropriate, the inspectors verified the inspection procedure attributes as discussed below during their review of the licensee's corrective actions for the above condition report. The inspectors discussed the corrective actions and associated evaluations with licensee personnel.

This review constituted one in-depth problem identification and resolution inspection sample as defined in IP 71152.

b. Observations It is an infrequent occurrence that steam generator (SG) tube degradation meets criteria for conducting an in-situ pressure test. The in-situ pressure test provides a means to determine whether a flawed tube meets the structural integrity and accident leakage performance criteria required by the licensees SG Program as implemented by TS 3.4.17 and 5.5.8. Therefore, the inspectors elected to review the licensees corrective actions associated with CR-PLP-2017-02177, which documented an axial crack identified in a SG B tube that met criteria for an in-situ pressure test. The inspectors noted that CR-PLP-2017-02177 did not reference vendor documents that assessed the cause and significance of this degraded SG B tube. To improve the auditability of the CR, the licensee subsequently incorporated reference to LR-LAR-2016-00155 in the closure notes which included actions to complete the 1R25 SG Tube Inspection Report as required by TS 5.6.8 and this report will incorporate or reference the vendor documents that contain detailed evaluations of the cause and significance as discussed below.

The inspectors reviewed the licensees vendor (AREVA) document 51-9270659, Palisades Steam Generator Condition Monitoring for 1R25 and Preliminary Operational Assessment for Cycle 26, which recorded the detailed crack profiling for the degraded tube R62, C101 identified in the B SG located in the hot leg side free-span region between support plates 03 and 04. Specifically, based on eddy current testing (ECT)data recorded using the +PointTM probe, the licensees vendor determined the crack depth and length of eight distinct flaws aligned axially within the degraded section of SG B tube R62, C101 and attributed the cause of this cracking to be outside diameter stress corrosion cracking (ODSCC). The deepest of these flaws was measured at 64 percent through-wall and could not be demonstrated analytically to meet the structural performance criteria identified in the licensees SG Program. Therefore, the licensee completed an in-situ pressure test during the outage, which demonstrated that this degraded tube had retained adequate structural and leakage integrity during the previous operating cycle and subsequently installed mechanical tube plugs to remove tube R62, C101 from service. Document 51-9270659 also included a historical record of tubes removed from service with ODSCC identified in the free-span area and based upon this review, the inspectors confirmed that no adverse increasing trend for ODSCC existed. Specifically, ODSCC in the free-span was identified in three SG tubes in 2004, two SG tubes in 2006 and one SG tube in 2009. The inspectors also interviewed the licensees ECT vendor personnel who conducted reviews of prior ECT data to confirm that no evidence of a defective tube existed during the RFO 24 SG ECT. Specifically, the vendor provided records of the SG ECT bobbin probe data to demonstrate that tube R62, C101 had not contained ECT signals indicative of flaws as defined by the site approved ECT Data Analyst Guidelines during RFO 1R24.

Based on the reviews discussed above, the inspectors confirmed that the licensee determined the cause, extent of cause and extent of condition for the degraded SG B tube. Additionally, the inspectors verified the completed corrective actions were appropriately focused to correct the problem.

c. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report 05000255/2017001-00: Inadequate Protection from

Tornado Missiles Identified Due to Non-Conforming Design Conditions

a. Inspection Scope

The inspectors reviewed Licensee Event Report (LER) 05000255/2017001-00, which was submitted to the NRC on May 24, 2017. On March 29, 2017, the licensee identified non-conforming conditions in the plant as-built configuration and conditions such that specific TS equipment was considered to not be adequately protected from tornado missiles as required by the current licensing and design basis. The licensee entered various TS action statements for the equipment listed below. Operability was restored promptly using the guidance in Interim DSS-ISG-2016-01, Clarification of Licensee Actions in Receipt of Enforcement Discretion, dated February 2016 per Enforcement Guidance Memorandum EGM 15-002, Revision 1, Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance, dated February 17, 2017.

A list of specific equipment adversely effected and discussed in the LER included:

• Ventilator openings that provide a straight-line path to parts of the service water system;

• Ventilator openings that provide a straight-line path to parts of the diesel generator fuel oil system;

• Vent lines for the fuel oil day tanks associated with the 1-1 diesel generator (DG)and 1-2 DG;

• Steam supply relief valves for the steam-driven auxiliary feedwater pump;

• CCW surge tank; and

• Air intake piping for the control room ventilation filtration system.

The licensee performed a root cause evaluation for these tornado missile vulnerabilities.

Planned corrective actions include submission of a license amendment request to use a tornado risk evaluation model and implement the model as part of the current licensing basis.

The inspectors reviewed the LER to ensure it was reported accurately in accordance with 10 CFR, Part 50.73 reporting requirements. Therefore, this LER is closed.

b. Findings

A finding and an associated violation of 10 CFR, Part 50, Appendix B, Criterion III, Design Control, was identified based upon the lack of adequate tornado missile protection to the safety-related equipment listed above. The finding was determined to be less than red (i.e., high safety significance) based on a generic and bounding risk evaluation performed by the NRC in support of the resolution of tornado-generated missile non-compliances. The bounding risk evaluation is discussed in Enforcement Guidance Memorandum 15-002, Revision 1, Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance, and can be found in ADAMS Accession No. ML16355A286.

Because this finding and violation was identified during the discretionary period covered by Enforcement Guidance Memorandum 15-002, Revision 1, Enforcement Discretion for Tornado Missile Protection Non-Compliance and because the licensee, prior to the expiration of the associated LCO, took initial compensatory measures that provided additional protection such that the likelihood of tonado missile effects were lessoned, followed by more comprehensive compensatory measures that were completed within approximately 60 days of issue discovery, and has final corrective actions planned, the NRC is exercising enforcement discretion by not issuing an enforcement action, as discussed in Section 1R15.2 of this report.

This event follow-up review constituted one sample as defined in IP 71153-05.

4OA5 Other Activities

.1 (Closed) Unresolved Item 05000255/2014008-10: Lack of Analysis for Electrical

Containment Penetration Protection The inspectors completed a review of Unresolved Item (URI)05000255/2014008-10, Lack of Analysis for Electrical Containment Penetration Protection. The inspectors reviewed the Current Licensing Basis for Palisades, specifically NUREG-1424, Safety Evaluation Report related to the full-term operating license for Palisades Nuclear Plant; NUREG-0820, Palisades Systematic Evaluation Program (SEP); and associated regulatory correspondence. The inspectors determined that secondary containment penetration protection was not an original design requirement nor was it ever formally imposed on Palisades; therefore, the inspectors found no violation of regulatory requirements.

The inspectors also reviewed the underlying technical basis for the conclusion in SEP Topic VIII-4 and were concerned that the conclusion of the SEP, i.e., no further action was required, was no longer appropriate given current standards for containment penetration protection. Specifically, the SEP stated, The staff concluded that the design of the Palisades Plant electrical penetrations is similar to those in other SEP plants, the probability of electrical failure of the penetrations is low, and any resultant leakage path would be small. The inspectors were specifically concerned with the assertion that the probability of electrical penetration failure is low and any resultant leakage path would be small was no longer appropriate given current standards (specifically Regulatory Guide 1.63, Electric Penetration Assemblies in Containment Structures for Nuclear Power Plants) for containment penetration protection. The inspectors reviewed industry data on the failure probability of electrical cables and circuit breakers along with the Core Damage Frequency for Palisades. These data were compared to established risk thresholds for Large Early Release Frequency. The inspectors concluded that although the licensee did not necessarily meet current day standards, the contribution to the Large Early Release Frequency due to a lack of secondary containment penetration protection was sufficiently low that a Safety Backfit in accordance with 10 CFR 50.109 would not be warranted. Because of this, the inspectors determined that no further action was warranted for this URI. This URI is closed.

4OA6 Management Meetings

.1 Exit Meeting Summary

On July 27, 2017, the inspectors presented the inspection results to Mr. C. Arnone, Site Vice President, 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 inspection results for the Radiation Safety Program review with Mr. C. Arnone, Site Vice President, and other members of the licensee staff on May 5, 2017; and

• The inspection results for the Inservice Inspection (ISI) with Mr. C. Arnone, Site Vice President, and other members of the licensee staff on May 5, 2017.

The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) or Severity Level IV was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation (NCV).

• A finding and an associated violation of the licensees current site-specific licensing basis for tornado-generated missile protection was identified.

Because this violation was identified during the discretionary period discussed in Enforcement Guidance Memorandum 15-002, Enforcement Discretion for Tornado Missile Protection Noncompliance, Revision 1, and because the licensee implemented interim compensatory measures and has planned final corrective actions, the NRC is exercising enforcement discretion by not issuing an enforcement action for the underlying 10 CFR Part 50, Appendix B, Criterion III, Design Control, violation. This violation is discussed in Section 4OA3.1.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

C. Arnone, Site Vice President

D. Corbin, General Manager Plant Operations

B. Baker, Operations Manager - Shift

J. Borah, Engineering Manager, Systems and Components

M. Briley, Corporate Level III, NDE

D. Dagget, SG Program Engineer

T. Davis, Regulatory Assurance

N. DeMaster, Outage Manager

B. Dotson, Regulatory Assurance

J. Erickson, Regulatory Assurance

D. Gerber, NDE Lead

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

J. Jerz, Engineering Supervisor

G. Katt, ISI Engineer

M. Lee, Operations Manager - Support

D. Lucy, Production Manager

D. Malone, Emergency Planning Manager

T. Mulford, Operations 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

N. Wortman, Boric Acid Program Owner

U.S. Nuclear Regulatory Commission

E. Duncan, Chief, Reactor Projects Branch 3

R. Daley, Chief, Reactor Safety Engineering Branch 3

A. Shaikh, Senior Reactor Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

05000255/2017001-00 LER Inadequate Protection from Tornado Missiles Identified Due to Non-Conforming Design Conditions (4OA3)

05000255/2014008-10 URI Lack of Analysis for Electrical Containment Penetration Protection (4OA5)

Discussed

None