ML24228A195

Restart Inspection Plan

ML24228A195
Person / Time
Site:	Palisades
Issue date:	08/20/2024
From:	NRC/RGN-III/DORS
To:
References
Download: ML24228A195 (1)

Text

ML24228A195PALISADES NUCLEAR PLANT RESTART INSPECTION PLAN LIGHT-WATER REACTOR INSPECTION PROGRAM FOR RESTART OF REACTOR FACILITIES FOLLOWING PERMANENT CESSATION OF POWER OPERATIONS Inspection Manual Chapter 2562 Inspection Objectives This series of inspections will provide input for developing an objective and documented basis for a Nuclear Regulatory Commission (NRC) decision to transition the Palisades Nuclear Plant to the ROP and resume power operations following the certification of permanent cessation of plant operations and removal of fuel from the reactor. These inspections shall sample and assess key aspects of licensee operational readiness across the ROP cornerstones of safety to support reasonable assurance of adequate protection of public health and safety.

Applicable Inspection Procedures Existing inspection procedures for ROP baseline inspections, decommissioning inspections, and construction inspections should be used in full or in part to accomplish the inspection activities. If a new or temporary instruction needs to be created to accomplish the inspection activities, it will be created in accordance with IMC 0040, Preparation, Revision, Issuance, and Ongoing Oversight of NRC Inspection Manual Documents. If a discontinued inspection procedure or temporary instruction is needed, the regional Team Leader will coordinate with the applicable group in NRR to restore the procedure or instruction for use.

Prepared By:

A. Nguyen, Lead, Palisades Restart Team, RIII Approved By:

J. Kozal, Director, DORS, RIII J. Pelton, Deputy Director, DORL, NRR P. McKenna, Deputy Director, DRO, NRR Signed by Nguyen, April on 08/15/24 Signed by Kozal, Jason on 08/20/24 Signed by Pelton, Jamie on 08/16/24 Signed by McKenna, Philip on 08/19/24

INSPECTION PLAN DETAILS

I Inspectors: Qualified resident inspectors, reactor inspector specialists, and experts from the regional offices and headquarters will be utilized to accomplish the inspection goals.

II Detailed Inspection Schedule

Inspection Preparation: Each inspection team point of contact or inspector shall coordinate with the Palisades Restart Team to establish a point of contact (POC) with the licensee. The inspection POC/inspector will then communicate directly with the licensee POC to establish needed communications for the inspection activity, including coordinating updates for any schedule changes.

The inspector(s) will also request through the point(s) of contact, with a Request for Information or through discussion, any required documentation needed for the inspection. The inspector(s) will finally create a specific inspection plan for the activity being conducted, including the inspection procedure(s) used, either fully or in part, inspection objectives, and details on the activities being inspected. This inspection plan will be approved by the Palisades Restart Team Lead and/or the inspectors Branch Chief.

Onsite Inspection: Until readiness for Restart is confirmed and all inspection objectives have been accomplished. This is currently targeted in late 2025 but could move based on the licensees schedule.

Entrance Briefing/Meeting: Each inspection activity should conduct either an inspection entrance meeting or briefing with the licensee to describe the inspection activities and establish coordination and communication.

Debriefs/Exit Meetings: Each inspection activity or set of activities shall conduct either a technical debrief and/or exit meeting to conclude the inspection activity with the licensee. The inspector(s) shall also debrief regional management/the regional Team Lead of the results of the inspection activity and any noteworthy observations, findings, and/or violations identified.

Inspection Reports: Quarterly or standalone reports will be issued for each group or individual inspection activity (to be determined by regional management).

See Section V for more details on documentation.

III Inspection Activities

01.Decommissioning Activities

Decommissioning inspections will continue until the NRC determines that they are no longer needed, or the Commission directs the staff to no longer implement the program. The established decommissioning inspection plan shall

2 be reviewed to determine potential areas of overlap and adjusted as applicable to ensure all requirements are still met while most efficiently using inspection resources. Existing ROP baseline inspection procedures can be used in lieu of decommissioning procedures to inspect licensee activities that are being conducted in support of restarting the unit. Dual credit shall be used, where appropriate, for the inspections.

For example, the licensee might use the same radiation protection program procedures for ALARA planning in both decommissioning and restart activities.

The inspector(s) will determine the most appropriate inspection procedure(s) to use for reviewing and observing these activities and assessment of the activities will be used for credit to the decommissioning program and restart determination, as applicable.

02.Restart Activities

02.01 Baseline Inspections The inspector(s) shall select appropriate sections of IPs to perform a variety of inspection activities across all cornerstones of safety to verify operational readiness.

02.01.a) Reactor Safety Cornerstones

i. Initiating Events - Design, Protection Against External Factors, Configuration Control, Equipment Performance, Procedure Quality, Human Performance ii. Mitigating Systems - Design, Protection Against External Factors, Configuration Control, Equipment Performance, Procedure Quality, Human Performance iii. Barrier Integrity (RCS, Containment, Cladding) - Design Control, Configuration Control, Equipment Performance, Procedure Quality, Human Performance 02.01.b) Emergency Preparedness Cornerstone 02.01.c) Radiation Safety Cornerstones - Occupational

& Public - Facilities, Equipment, and Instrumentation; Programs/Process; Human Performance 02.01.d) Security Cornerstone - Physical Protection, Access Authorization, Access Control, Response to Contingency Events, Material Control and Accountability

02.02 Safety Culture Safety Culture is the core values and behaviors resulting from a collective commitment by leaders and individuals to emphasize safety over competing goals. Inspectors observe a licensees Safety Culture as it is demonstrated in meetings, pre-job briefings, during work activities, and in interactions amongst leaders and individual contributors. A Safety Conscious Work Environment (SCWE) is a work environment where employees are encouraged to raise safety concerns and where concerns are promptly

3 reviewed, given the proper priority based on their potential safety significance, and appropriately resolved with timely feedback to the originator of the concerns and to other employees as appropriate. Inspectors can observe SCWE through the corrective action program, during meetings and interactions, and by reviewing allegations data.

The Palisades Restart Panel, based on inspection assessments and inputs from inspectors, will determine if NRC management discussion with Palisades management on any safety culture aspect is required. This would encourage licensee action to address safety culture aspects before significant performance degradation occurs.

02.03 Corrective Action Program 02.03.a) The Palisades Restart Panel, based on a recommendation from the regional Team Leader, will determine the size, scope, and timing of a corrective action program team inspection prior to authorization of restart.

02.03.b) This inspection shall be conducted in accordance with the applicable portions of IP 71152 and will be documented in a standalone inspection report.

02.03.c) This inspection should be scheduled at an appropriate time to ensure the licensee has sufficient run-time to verify appropriate implementation of the program.

02.03.d) This program shall be reviewed against the Quality Assurance criteria to ensure that all changes made from decommissioning to operating status have been appropriately incorporated.

02.04 Other Items 02.04.a) Open Items

i. Review open items from prior to shutdown and ensure licensee has a plan for resolution if issue is determined to be necessary for restart.

ii. Review deferred licensing actions and corrective actions to determine appropriate implementation plans and actions to resolve.

iii. Review historic site-specific issues for timely and effective resolution.

a. For example, review list of open adverse condition monitoring plans that were in place prior to shut down. Ensure the licensee has evaluated the condition and determined appropriate corrective actions to resolve prior to restart, as necessary.

4 IV HRMS and Time Charge Information

Attachment A describes projected amounts of inspection time for these activities. The activities are split by inspection area and resources needed for the specific task(s). The projections were made using the applicable Inspection Procedure guidance to estimate the amount of time needed for each activity (either in full or in part). Some activities will take more or less time depending on the level of review needed and any unforeseen issues that arise. As inspection activities are scheduled, coordinate with the regional Team Lead/Senior Project Engineer to enter the activities into RPS to generate the required time codes.

Travel: AT Preparation: BIP Communications: COM Inspection: per IP Documentation: BID

• Observers charge to Training (unless conducting a specific IP).

V Documentation

Unless otherwise specified, all inspections will be documented in RPS.

The inspection reports/inputs shall document the applicable IPs (or sections within) completed, which SSCs or programs were reviewed, findings/violations, open or unresolved items, specific notable items related to the samples (as Observations), documents reviewed, and any debrief/exit meetings. Any noteworthy observations, open or unresolved items, and identified findings and violations shall be dispositioned per the applicable guidance documents and tracked in RPS as inputs into the final operational readiness assessment.

Note: Follow-up inspection of open or unresolved items will be tracked and completed per existing NRC guidance. Follow-up inspection of identified findings and violations will be completed through individual issue review or as part of the Problem Identification and Resolution inspection, depending on the significance of the issue and within an appropriate timeframe to ensure effective resolution.

Any items required to be resolved prior to restart will be identified as such in the writeup.

VI Inspection Activity Examples

The inspectors shall select appropriate sections of IPs to perform a variety of inspection activities across all cornerstones of safety to verify operational readiness. The following are examples of activities already screened to be scheduled for review and inspection:

5 Initiating Events Cornerstone o NFPA-805 Program Implementation Review program, procedure, and PRA updates to verify the licensee meets all regulatory requirements and guidance (IP 71111.05 and 71111.21)

Evaluate and inspect implementation and testing of system modifications (IP 71111.21, 71111.18)

Mitigating Systems Cornerstone o System Restoration of ECCS Review System Return-to-Service Plan Verify system maintenance and surveillance testing meet the QA program requirements and test all required design and licensing basis functions (IPs 71111.12, 71111.15, and 71111.24)

Observe system maintenance and testing activities (IP 71111.24)

Verify open work orders and corrective actions have been addressed prior to system startup Review any modifications to the system during decommissioning to ensure all components and functions are restored to an operational state (IP 71111.04 and 71111.18) o Licensed Operator Requalification Training Inspect readiness of Main Control Room Simulator for acceptable use in training activities (IP 41502)

Observe INPO re-accreditation activities for Licensed Operator Training program (as part of MOU)

Verify licensed operator requalification training program re-establishment meets all requirements and guidance (IP 71111.11)

Observe licensed operator requalification training activities, specifically testing of individuals seeking re-activation of licenses (IP 71111.11)

Verify all individuals seeking license re-activation meet all training and regulatory requirements (IP 71111.11)

Barrier Integrity Cornerstone o Reactor Vessel Inspections and Maintenance Observe and review data from In-service Inspections to verify integrity of the primary coolant system (including previously not-performed inspections such as Baffle Bolt UTs) (IP 71111.08)

Ensure NDE program and procedures are up to date Verify appropriate qualification of examiners and reviewers for NDE Verify proper calibration and testing of equipment Observe Rotary Peening of Reactor Vessel Head Nozzle Welds (deferred work prior to shutdown)

Observe in-field mitigation activities for Alloy-600 materials (Hot Leg, Cold Leg, Pressurizer, etc)

Review Alloy-600 Mitigation Repair Plans to ensure they meet the requirements of the ASME Code and work orders are appropriate for the activities

6 Emergency Preparedness Cornerstone o Observe and evaluate licensee emergency preparedness exercise(s) and drill(s) for implementation of the operating emergency plan (IP 71114.01 and 71114.06) o Review any proposed changes to the operating emergency plan and verify site procedures are updated appropriately Radiation Safety Cornerstones o Occupational Radiation Safety Primary Coolant System Decontamination Process (IP 71124.01)

• Verify the work is planned per ALARA standards

• Observe pre-job briefs and workers in the field to verify practices are implemented as required

• Verify licensee programs and procedures meet all regulatory requirements (TS, administrative controls, etc) o Public Radiation Safety Security Cornerstone o Verify transition from decommissioning plan to operational plan o Review modifications to plan to ensure no degradation in safety margin o Observe implementation testing of modifications o Observe and evaluate licensee training and force-on-force drills to verify operational readiness of new security plan o Inspect any changes to Target Sets

7 Attachment A

As highlighted in Section IV, this attachment describes projected amounts of inspection time for anticipated activities throughout the restart phase. The activities are split by inspection area and resources needed for the specific task(s). The projections were made using the applicable Inspection Procedure guidance to estimate the amount of time needed for each activity (either in full or in part).

Activities covered by Individuals conducting Baseline Inspections 2000-3000 hours

Resident Inspectors, Reactor Inspectors, Emergency Preparedness Inspectors and Security Inspectors in applicable areas

Includes activities to assess cornerstones of safety. For example, resident inspector baseline inspections, radiation protection baseline, operating security plan re-implementation, and emergency preparedness operating plan reviews and exercises.

Covers items not included in team reviews, such as modifications to SSCs, return-to-service system reviews, surveillance testing for operability/functionality, etc

Also, can include assistance from subject matter experts for review of specific issues (such as reactor vessel embrittlement evaluation, GSI-191 closure, etc)

Activities covered by Team Inspections 4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br />

Teams will consist of qualified Reactor Inspectors in the specific areas plus any required subject matter experts for those areas

Initial Licensed Operator Examination (1 class)

Emergency Preparedness (observe and evaluate operating emergency plan exercise)

Fire Protection (modified team to review NFPA-805 implementation actions)

Cyber Security (modified team to review re-implementation of operating requirements)

License Renewal Phase IV (team to review Aging Management Programs required for system operability, functionality, and reliability for the duration of the extended period of operation)

Open Phase Temporary Instruction inspection (to close out actions)

FLEX (modified team to review re-implementation of FLEX program)

Attachment A Problem Identification and Resolution (modified team to review implementation of corrective action program for an operating unit, may include safety culture focused review)

Inservice Inspection (multiple inspectors covering many ISI-related inspections - for example, reactor vessel and steam generator inspections, reactor vessel head repairs, alloy 600 mitigation activities, etc)

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