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{{Adams
#REDIRECT [[IR 05000255/2015003]]
| number = ML15303A366
| issue date = 10/30/2015
| title = NRC Integrated Inspection Report 05000255/2015003
| author name = Duncan E
| author affiliation = NRC/RGN-III/DRP
| addressee name = Vitale A
| addressee affiliation = Entergy Nuclear Operations, Inc
| docket = 05000255
| license number = DPR-020
| contact person =
| document report number = IR 2015003
| document type = Inspection Report, Letter
| page count = 51
}}
See also: [[see also::IR 05000255/2015003]]
 
=Text=
{{#Wiki_filter:UNITED STATES
                            NUCLEAR REGULATORY COMMISSION
                                                REGION III
                                    2443 WARRENVILLE RD. SUITE 210
                                          LISLE, IL 60532-4352
                                          October 30, 2015
Mr. Anthony Vitale
Vice-President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: PALISADES NUCLEAR PLANT
              NRC INTEGRATED INSPECTION REPORT 05000255/2015003
Dear Mr. Vitale:
On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Palisades Nuclear Plant. The enclosed report documents the results of this
inspection, which were discussed on October 29, 2015, with you and other members of your
staff.
Based on the results of this inspection, two NRC-identified findings of very low safety
significance were identified. The findings involved violations of NRC requirements. However,
because of their very low safety significance, and because the issues were entered into your
corrective action program, the NRC is treating the violations as non-cited violations (NCVs) in
accordance with Section 2.3.2 of the NRC Enforcement Policy.
If you contest the subject or severity of any NCV, you should provide a response within 30 days
of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a
copy to the Regional Administrator, U.S. Nuclear Regulatory Commission-Region III,
2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident
Inspector Office at the Palisades Nuclear Plant. In addition, if you disagree with the
cross-cutting aspect assigned to any finding in this report, you should provide a response within
30 days of the date of this inspection report, with the basis for your disagreement, to the
Regional Administrator, Region III, and the NRC Resident Inspector at the Palisades Nuclear
Plant.
 
A. Vitale                                      -2-
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy
of this letter, its enclosure, and your response (if any) will be available electronically for public
inspection in the NRCs Public Document Room or from the Publicly Available Records System
(PARS) component of the NRC's Agencywide Documents Access and Management System
(ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
                                              Sincerely,
                                              /RA/
                                              Eric Duncan, Chief
                                              Branch 3
                                              Division of Reactor Projects
Docket No. 50-255
License No. DPR-20
Enclosure:
IR 05000255/2015003
  w/Attachment: Supplemental Information
cc w/encl: Distribution via LISTSERV
 
          U.S. NUCLEAR REGULATORY COMMISSION
                          REGION III
Docket No:          50-255
License No:        DPR-20
Report No:          05000255/2015003
Licensee:          Entergy Nuclear Operations, Inc.
Facility:          Palisades Nuclear Plant
Location:          Covert, MI
Dates:              July 1 through September 30, 2015
Inspectors:        A. Nguyen, Senior Resident Inspector
                    J. Boettcher, Resident Inspector
                    B. Boston, Acting Resident Inspector
                    J. Cassidy, Senior Health Physicist
                    R. Elliott, Reactor Engineer
                    M. Holmberg, Reactor Inspector
                    J. Lennartz, Project Engineer
                    V. Myers, Senior Health Physicist
                    T. Taylor, Resident Inspector, D.C. Cook
Approved by:        E. Duncan, Chief
                    Branch 3
                    Division of Reactor Projects
                                                            Enclosure
 
                                        TABLE OF CONTENTS
TABLE OF CONTENTS ................................................................................................................ 1
SUMMARY OF FINDINGS ........................................................................................................... 2
REPORT DETAILS ....................................................................................................................... 4
  Summary of Plant Status ........................................................................................................... 4
    1.    REACTOR SAFETY .................................................................................................... 4
      1R04  Equipment Alignment (71111.04) ....................................................................... 4
      1R05  Fire Protection (71111.05) .................................................................................. 5
      1R06  Flooding (71111.06) ........................................................................................... 6
      1R11  Licensed Operator Requalification Program (71111.11) .................................... 7
      1R12  Maintenance Effectiveness (71111.12) .............................................................. 8
      1R13  Maintenance Risk Assessments and Emergent Work Control (71111.13) ......... 9
      1R15  Operability Determinations and Functional Assessments (71111.15) .............. 10
      1R19  Post-Maintenance Testing (71111.19) ............................................................. 13
      1R20  Outage Activities (71111.20) ............................................................................ 14
      1R22  Surveillance Testing (71111.22) ....................................................................... 15
      1EP6  Drill Evaluation (71114.06) ............................................................................... 16
    2.    RADIATION SAFETY ................................................................................................ 17
      2RS6  Radioactive Gaseous and Liquid Effluent Treatment (71124.06) ..................... 17
    4.    OTHER ACTIVITIES ................................................................................................. 24
      4OA1  Performance Indicator Verification (71151) ...................................................... 24
      4OA2  Identification and Resolution of Problems (71152) ........................................... 27
      4OA3  Follow-Up of Events and Notices of Enforcement Discretion (71153) .............. 28
      4OA5  Other Activities ................................................................................................. 28
      4OA6  Management Meetings ..................................................................................... 28
SUPPLEMENTAL INFORMATION ............................................................................................... 1
  KEY POINTS OF CONTACT..................................................................................................... 1
  LIST OF ITEMS OPENED, CLOSED AND DISCUSSED ......................................................... 2
  LIST OF DOCUMENTS REVIEWED......................................................................................... 3
  LIST OF ACRONYMS USED .................................................................................................. 18
 
                                      SUMMARY OF FINDINGS
Inspection Report (IR) 05000255/2015003, 07/01/2015-09/30/2015; Palisades Nuclear Plant;
Operability Determinations and Functional Assessments; and Radioactive Gaseous and Liquid
Effluent Treatment.
This report covers a 3-month period of inspection by resident inspectors and announced
baseline inspections by regional inspectors. Two Green findings were identified by the
inspectors. These findings were considered non-cited violations (NCVs) of U.S. Nuclear
Regulatory Commission (NRC) regulations. The significance of inspection findings is indicated
by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using
Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated
April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the
Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are
dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRC's
program for overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.
        Cornerstone: Mitigating Systems
        Green. An NRC-identified finding of very low safety significance and an associated NCV
        of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B,
        Criterion III, Design Control, was identified for the failure to justify continued service of
        safety-related electrolytic capacitors that were installed beyond their recommended
        service life associated with the safety-related containment floor level indicating
        transmitters (LITs). Specifically, on June 21, 2015, containment floor LIT LIT-0446B
        and LIT-0446A did not satisfy the acceptance criteria of the technical specification
        surveillance monthly channel checks and LIT-0446B was declared inoperable. Further
        troubleshooting identified a failure of the electrolytic capacitor within the transmitters
        converter module and that this failure was most likely due to age since the transmitter
        had been in service for greater than its recommended service life. In addition to entering
        this issue into their Corrective Action Program (CAP) as CR-PLP-2015-04972, the
        licensee replaced the failed components and planned to develop a replacement
        schedule for non-critical, safety-related electrolytic capacitors.
        The performance deficiency was determined to be more than minor because it was
        associated with the Equipment Performance attribute of the Mitigating Systems
        cornerstone and adversely affected the cornerstone objective of ensuring the availability,
        reliability, and capability of systems that respond to initiating events to prevent
        undesirable consequences (i.e., core damage). The finding screened as having very low
        safety significance based on answering No to all of the screening questions in the
        Mitigating Structures, Systems, and Components (SSCs) and Functionality section of
        IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power,
        Exhibit 1, Mitigating Systems Screening Questions. The finding had a cross-cutting
        aspect of Operating Experience in the Problem Identification and Resolution
        cross-cutting area because the licensee did not effectively and thoroughly evaluate and
        implement relevant industry operating experience and guidance for age-related
        electrolytic capacitor degradation [P.5]. (Section 1R15)
                                                2
 
Cornerstones: Occupational Radiation Safety and Public Radiation Safety
Green. A finding of very low safety significance and an associated NCV of Technical
Specification (TS) 5.5.1, Offsite Dose Calculation Manual, was identified for the failure
to establish, implement, and maintain the Offsite Dose Calculation Manual (ODCM)
relative to dose calculation parameters. Specifically, the licensee failed to modify the
parameters used in public radiation calculations when changes in the use of unrestricted
areas were identified. As a result, the quarterly and annual doses that were calculated
every 31 days, as required by the ODCM, were incorrect and non-conservative. In
addition to entering this issue into their CAP as CR-PLP-2015-2972, the licensee
recalculated the dose using the correct calculation parameters.
The performance deficiency was determined to be more than minor because it was
associated with the Program and Process attribute of the Public Radiation Safety
cornerstone and adversely affected the cornerstone objective of ensuring the adequate
protection of public health and safety from exposure to radioactive materials released
into the public domain as a result of routine civilian nuclear reactor operation. The
finding was determined to be of very low safety significance in accordance with
IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process,
because the issue did not represent a significant deficiency in evaluating a planned or
unplanned effluent release since the resulting dose was not grossly underestimated.
The finding had a cross-cutting aspect of Training in the Human Performance
cross-cutting area because the licensee did not ensure adequate knowledge transfer to
maintain a knowledgeable, technically competent workforce. [H.9] (Section 2RS6)
                                        3
 
                                          REPORT DETAILS
Summary of Plant Status
The plant operated at or near full power during the inspection period until August 24, 2015,
when the operators entered a coastdown period in preparation for refueling outage (RFO) 1R24.
On September 16, 2015, the unit automatically tripped in response to an electrical failure in the
digital electrohydraulic control system. The unit remained shutdown and transitioned into the
RFO for the remainder of the inspection period.
1.      REACTOR SAFETY
        Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment (71111.04)
.1      Quarterly Partial System Walkdowns
  a.    Inspection Scope
        The inspectors performed partial system walkdowns of the following risk-significant
        systems:
        *        Left train auxiliary feedwater system during surveillance of right train auxiliary
                  feedwater system;
        *        1-2 diesel generator during surveillance of the 1-1 diesel generator;
        *        A' train shutdown cooling system during RFO 1R24; and
        *        Air system alignment to containment during RFO 1R24.
        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, the Updated Final Safety Analysis Report (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
        Corrective Action Program (CAP) with the appropriate significance characterization.
        Documents reviewed are listed in the Attachment to this report.
        These activities constituted four partial system walkdown samples as defined in
        Inspection Procedure (IP) 71111.04-05.
                                                  4
 
  b. Findings
      No findings were identified.
.2  Semiannual Complete System Walkdown
  a. Inspection Scope
      Between July 21 and August 12, 2015, the inspectors performed a complete system
      alignment inspection of the service water system to verify the functional capability of the
      system. This system was selected because it was considered both safety-significant
      and risk-significant in the licensees probabilistic risk assessment. The inspectors
      walked down the system to review mechanical and electrical equipment lineups;
      electrical power availability; system pressure and temperature indications; component
      labeling; component lubrication; component and equipment cooling; hangers and
      supports; operability of support systems; and to ensure that ancillary equipment or
      debris did not interfere with equipment operation. A review of a sample of past and
      outstanding WOs was performed to determine whether any deficiencies significantly
      affected the system function. In addition, the inspectors reviewed the CAP database to
      ensure that system equipment alignment problems were being identified and
      appropriately resolved. Documents reviewed are listed in the Attachment to this report.
      These activities constituted one complete system walkdown sample as defined in
      IP 71111.04-05.
  b. Findings
      No findings were identified.
1R05 Fire Protection (71111.05)
  a. Inspection Scope
      The inspectors conducted fire protection walkdowns which were focused on the
      availability, accessibility, and the condition of firefighting equipment in the following
      risk-significant plant areas:
      *      Fire Area 16: component cooling water (CCW) pump room;
      *      Fire Area 9: screenhouse;
      *      Fire Area 10: east engineered safeguards room;
      *      Risk-significant fire areas during the higher risk plant operating state #1 of
              RFO 1R24;
      *      Fire Areas 29, 30, and 31: electrical and mechanical equipment rooms; and
      *      Fire Area 6: diesel generator 1-2 and fuel oil day tank room.
      The inspectors reviewed areas to assess if the licensee had implemented a fire
      protection program that adequately controlled combustibles and ignition sources within
      the plant, effectively maintained fire detection and suppression capability, maintained
      passive fire protection features in good material condition, and implemented adequate
      compensatory measures for out-of-service, degraded, or inoperable fire protection
      equipment, systems, or features in accordance with the licensees fire plan.
                                              5
 
      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.
      These activities constituted six quarterly fire protection inspection samples as defined in
      IP 71111.05-05.
  b. Findings
      No findings were identified.
1R06 Flooding (71111.06)
.1  Internal Flooding
  a. Inspection Scope
      The inspectors reviewed selected risk-important plant design features and licensee
      procedures intended to protect the plant and its safety-related equipment from internal
      flooding events. The inspectors reviewed flood analyses and design documents,
      including the UFSAR, engineering calculations, and abnormal operating procedures to
      identify licensee commitments. The inspectors also reviewed the licensees corrective
      action documents with respect to past flood-related items identified in the CAP to verify
      the adequacy of the corrective actions. The inspectors performed a walkdown of the
      following plant area to assess the adequacy of watertight doors and verify drains and
      sumps were clear of debris and were operable, and that the licensee complied with its
      commitments:
      *      cable spreading room.
      Documents reviewed during this inspection are listed in the Attachment to this report.
      This inspection constituted one internal flooding sample as defined in IP 71111.06-05.
  b. Findings
      No findings were identified.
.2  Underground Vaults
  a. Inspection Scope
      The inspectors selected underground bunkers/manholes subject to flooding that
      contained cables whose failure could disable risk-significant equipment. The inspectors
      determined whether the cables were submerged, whether splices were intact, and
      whether appropriate cable support structures were in place. In those areas where
                                              6
 
      dewatering devices were used, such as a sump pump, the inspectors determined
      whether the device was operable and level alarm circuits were set appropriately to
      ensure that the cables would not be submerged. In those areas without dewatering
      devices, the inspectors verified that drainage of the area was available, or that the
      cables were qualified for submerged conditions. The inspectors also reviewed the
      licensees corrective action documents with respect to past submerged cable issues
      identified in the CAP to verify the adequacy of the corrective actions. The inspectors
      performed a walkdown of the following underground bunkers/manholes subject to
      flooding:
      *        Manhole #4 and Manhole #8.
      Documents reviewed are listed in the Attachment to this report. This inspection
      constituted one underground vaults sample as defined in IP 71111.06-05.
  b. Findings
      No findings were identified.
1R11 Licensed Operator Requalification Program (71111.11)
.1  Resident Inspector Quarterly Review of Licensed Operator Requalification (71111.11Q)
  a. Inspection Scope
      On August 5, 2015, 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;
      *        the 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
      *        the ability to identify and implement appropriate TS actions and Emergency Plan
              actions and notifications.
      Crew 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.
                                                7
 
.2  Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk
      (71111.11Q)
  a. Inspection Scope
      On September 16, 2015, the inspectors observed a reactor cooldown to Mode 5
      following a reactor trip. This was an activity that required heightened awareness or was
      related to increased risk. The inspectors evaluated the following areas:
      *      licensed operator performance;
      *      the 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 procedures;
      *      control board manipulations;
      *      oversight and direction from supervisors; and
      *      the ability to identify and implement appropriate TS actions and Emergency Plan
              actions and notifications.
      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 (71111.12)
  a. Inspection Scope
      The inspectors evaluated degraded performance issues involving the following
      risk-significant system:
      *      containment personnel inner air lock door.
      The inspectors reviewed events including those in which ineffective equipment
      maintenance 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 Title 10 of the Code of Federal
              Regulations (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;
                                              8
 
    *        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 (71111.13)
  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 appropriate risk assessments were performed prior
    to removing equipment for work:
    *        breaker 72-13, A primary coolant pump (PCP) direct current oil lift pump,
              removal;
    *        purification demineralizer filter replacement;
    *        diving in the spent fuel pool tilt pit;
    *        reduced inventory period #1 during RFO; and
    *        emergent work to uncouple control rod drive 11.
    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 are listed in the Attachment to this report. These maintenance risk
    assessments and emergent work control activities constituted five samples as defined in
    IP 71111.13-05.
  b. Findings
    No findings were identified.
                                              9
 
1R15 Operability Determinations and Functional Assessments (71111.15)
  a. Inspection Scope
    The inspectors reviewed the following issues:
    *      primary cooling system (PCS) branch connection weld inspection calculation
            errors;
    *      fuel oil transfer system operability;
    *      A PCP decreasing lower bearing oil level trend; and
    *      containment level indicating transmitter (LIT) capacitor failure.
    The inspectors selected these potential operability issues based on the risk significance
    of the associated components and systems. The inspectors evaluated the technical
    adequacy of the evaluations to ensure that TS operability was properly justified and the
    subject component or system remained available such that no unrecognized increase in
    risk occurred. The inspectors compared the operability and design criteria in the
    appropriate sections of the TS and UFSAR to the 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 three samples as defined in IP 71111.15-05. The
    sample for the weld inspection calculation error was accounted for in Inspection Report
    (IR) 05000255/2015012.
  b. Findings
    Introduction. An NRC-identified finding of very low safety significance (Green) and an
    associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design
    Control, was identified for the failure to justify continued service of safety-related
    electrolytic capacitors installed beyond their recommended service life associated with
    containment floor LITs LIT-0446B
    and LIT-0446A.
    Description. During the performance of monthly operations TS surveillance test MO-45,
    Control Room Channel Checks, on June 21, 2015, LIT-0446B, the B containment LIT,
    was found to be indicating below the acceptance criteria minimum required value. The
    transmitter was declared inoperable in accordance with TS 3.3.7, Post Accident
    Monitoring, since the accuracy over the entire level span of the instrument was
    considered degraded such that it could no longer perform its function to accurately
    monitor containment water level as specified by Regulatory Guide 1.97. These
    containment LITs are relied upon in the plants emergency operating procedures to
    ensure adequate net positive suction head for emergency core cooling system (ECCS)
    pumps following receipt of a recirculation actuation signal (RAS).
                                            10
 
On July 16, 2015, further troubleshooting was conducted and determined that the
electrolytic capacitor within the transmitters converter module failed and the most likely
cause of the capacitor failure was operation beyond the components service life since
the LITs had been in service for greater than 10 years. Entergy subsequently submitted
letter PNP 2015-058 to the NRC on August 3, 2015, reporting this information as
required by TS 5.6.6. This specification states that if post-accident monitoring
instrumentation is inoperable, a preplanned alternate method of monitoring, the cause of
the inoperability, and the schedule for restoring the inoperable instrument to an operable
status shall be submitted in a report to the NRC.
The resident inspectors asked follow-up questions associated with industry operating
experience and the preventive maintenance program for these transmitters. These LITs
were replaced on an as-required basis (no preventive maintenance frequency) and
were classified as non-critical components in the licensees maintenance program.
However, industry operating experience and Electric Power Research Institute guidance
was found by the inspectors that indicated electrolytic capacitors have a specified
lifespan based on operating conditions and applications. The NRC issued Information
Notice (IN) 2012-11, Age-Related Capacitor Degradation, in July 2012, which also
informed licensees of problems that involved the age-related degradation of capacitors.
The licensee documented a review of this IN in CR-PLP-2012-5721. However, the
licensees preventive maintenance interval review of this operating experience only
considered electrolytic capacitors that were classified as critical components in their
maintenance rule program. The capacitors which were identified during this review were
scheduled for, at most, 10 year replacement intervals. The licensee potentially missed
the opportunity to establish a replacement program for these transmitters at that time. In
addition to entering this issue into their CAP as CR-PLP-2015-04972, the licensee
replaced the failed components and planned to develop a replacement schedule for
non-critical, safety-related electrolytic capacitors.
Analysis. The inspectors determined that the failure to review for suitability of
application of the safety-related electrolytic capacitors in the containment floor LITs,
which were installed beyond their recommended service life, was contrary to
10 CFR Part 50, Appendix B, Criterion III, Design Control, and was a performance
deficiency.
The inspectors determined that the performance deficiency was more than minor in
accordance with Inspection Manual Chapter (IMC) 0612 "Power Reactor Inspection
Reports," Appendix B, "Issue Screening," dated September 7, 2012, because the
performance deficiency was associated with the Equipment Performance attribute of the
Mitigating Systems cornerstone and adversely affected the cornerstone objective of
ensuring the availability, reliability, and capability of systems that respond to initiating
events to prevent undesirable consequences (i.e., core damage). The containment
water LITs are relied upon in the plants emergency operating procedures to ensure
adequate net positive suction head for ECCS pumps following a RAS. The finding was
screened in accordance with IMC 0609, Appendix A, The Significance Determination
Process for Findings At-Power, Exhibit 1, Mitigating Systems Screening Questions,
dated July 1, 2012. The finding screened as having very low safety significance
(i.e., Green) based on answering No to all the screening questions under the Mitigating
SSCs and Functionality section of IMC 0609, Appendix A, Exhibit 1.
                                          11
 
    The finding had a cross-cutting aspect of Operating Experience in the Problem
    Identification and Resolution cross-cutting area since the licensee did not effectively and
    thoroughly evaluate and implement relevant industry operating experience and guidance
    for age-related electrolytic capacitor degradation [P.5].
    Enforcement. 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part,
    that measures shall be established for the selection and review for suitability of
    application of materials, parts, equipment, and processes that are essential to the
    safety-related functions of SSCs.
    Contrary to the above, as of June 21, 2015, the licensee failed to review for suitability of
    application of parts essential to the safety-related functions of the containment floor level
    indicating system. Specifically, the licensee did not review for suitability of application of
    safety-related electrolytic capacitors in the containment floor LITs that were installed
    beyond their recommended service life to justify their continued service considering
    in-service deterioration. As part of their immediate corrective actions, the licensee
    replaced the failed components. Because this violation was of very low safety
    significance and it was entered into the licensees CAP as CR-PLP-2015-04972, it is
    being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.
    (NCV 05000255/2015003-01 Failure to Justify Continued Service of Safety-Related
    Electrolytic Capacitors Installed Beyond Their Service Life)
.2  Review of Operator Workarounds
  a. Inspection Scope
    Operator workarounds are operator actions taken to compensate for degraded or
    non-conforming conditions. Operator workarounds that cannot be implemented
    effectively can contribute to an increase in overall plant risk. The inspectors verified that
    the licensee was identifying operator workarounds at an appropriate threshold, entering
    them into their CAP, and had planned or taken appropriate corrective actions. As part of
    their review, the inspectors considered all existing plant conditions and the cumulative
    impact of all operator workarounds.
    The inspectors evaluated the licensee's operator workarounds to determine if any
    mitigating system functions were adversely impacted. Additionally, the inspectors
    assessed whether or not the operator workarounds had adversely impacted the
    operators ability to implement abnormal or emergency operating procedures. The
    inspectors placed particular emphasis on any operator workarounds that had not been
    effectively evaluated by the licensee; that had been formalized or proceduralized as the
    long-term corrective actions for a degraded or nonconforming condition; and that may
    have increased the potential for human error, such as operator workarounds that:
    *        Required operations that were not consistent with current training and system
              knowledge;
    *        Required a change from long-standing operational practices;
    *        Required operation of a system or component in a manner that was inconsistent
              with similar systems or components;
    *        Created the potential for the compensatory action to be performed on equipment
              or under conditions for which it was not appropriate;
                                            12
 
    *        Impaired access to required indications, increased dependence on oral
              communications, or impacted the timeliness of time-critical event mitigating
              actions under adverse environmental conditions;
    *        Required the use of equipment and interfaces that had not been designed with
              consideration of the task being performed;
    *        Required the licensee to assess and manage an increase in risk; or
    *        Required a license amendment in accordance with 10 CFR 50.59, but were
              implemented without an approved amendment.
    Documents reviewed are listed in the Attachment to this report. These activities by the
    inspectors constituted a single operator workarounds review inspection sample as
    required by IP 71111.15, Section 02.01(a).
  b. Findings
    No findings were identified.
1R19 Post-Maintenance Testing (71111.19)
  a. Inspection Scope
    The inspectors reviewed the following post-maintenance testing activities to verify that
    procedures and testing activities were adequate to ensure system operability and
    functional capability:
    *        CVCO-4, pump testing, following C charging pump bladder replacement;
    *        MI-43, instrument calibration, following replacement of the reactor vessel level
              indicating system power supply;
    *        valve testing following repairs to the charging system surge tank vent valve; and
    *        diagnostic and stroke testing of service water control valves replaced on the
              CCW heat exchanger during RFO 1R24.
    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 four post-maintenance testing samples as defined in
    IP 71111.19-05.
                                            13
 
  b. Findings
      No findings were identified.
1R20 Outage Activities (71111.20)
.1  Refueling Outage Activities
  a. Inspection Scope
      The inspectors evaluated outage activities for RFO 24 (RFO 1R24) that began on
      September 16, 2015, and continued through the end of the assessment period. The
      RFO began when the reactor tripped following a turbine trip due to a digital
      electrohydraulic control system failure on September 16, 2015. The licensee continued
      the plant shutdown to cold shutdown conditions to begin the RFO.
      The inspectors reviewed the Outage Risk Assessment (ORAT) and contingency plans
      for 1R24, prior to the shutdown, to confirm that the licensee had appropriately
      considered risk, industry operating experience, and previous site-specific problems in
      developing and implementing a plan that assured maintenance of defense-in-depth.
      During the RFO, the inspectors observed portions of the shutdown and cooldown
      processes and monitored licensee controls over the RFO activities listed below:
      *      licensee configuration management, including maintenance of defense-in-depth
            commensurate with the ORAT for key safety functions and compliance with the
            applicable TSs 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 primary 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 ORAT requirements were met, and controls over switchyard activities;
      *      monitoring of decay heat removal processes, systems, and components;
      *      controls to ensure that RFO 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; and
      *      licensee identification and resolution of problems related to RFO activities.
      Documents reviewed are listed in the Attachment to this report. Since the RFO
      extended into the fourth quarter of 2015, these activities do not count as an inspection
      sample this quarter, but will be counted next quarter.
  b. Findings
      No findings were identified.
                                            14
 
1R22 Surveillance Testing (71111.22)
  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:
    *      RI-99, left channel nuclear instrumentation calibration (routine);
    *      EA-12, protective relay functional testing (routine);
    *      local leak rate test of containment personnel air lock (routine);
    *      PCS leak rate calculation (PCS leak detection);
    *      QO-16C, containment spray pump inservice surveillance testing (inservice test);
    *      RT-202, control room heating, ventilation, and air conditioning heat removal
            capability testing (routine);
    *      RT-8D, right train engineered safeguards system integrated test (routine);
    *      RO-105, safety injection tank full flow inservice test (routine); and
    *      RO-141, containment sump check valve inservice test (containment isolation
            valve).
    The inspectors observed in-plant activities and reviewed procedures and associated
    records to determine the following:
    *      did preconditioning occur;
    *      were the effects of the testing adequately addressed by control room personnel
            or engineers prior to the commencement of the testing;
    *      were acceptance criteria clearly stated, sufficient to demonstrate operational
            readiness, and consistent with the system design basis;
    *      was plant equipment calibration correct, accurate, and properly documented;
    *      were as-left setpoints within required ranges; and was the calibration frequency
            in accordance with TSs, the UFSAR, plant procedures, and applicable
            commitments;
    *      was measuring and test equipment calibration current;
    *      was the test equipment used within the required range and accuracy and were
            applicable prerequisites described in the test procedures satisfied;
    *      did test frequencies meet TS requirements to demonstrate operability and
            reliability;
    *      were tests performed in accordance with the test procedures and other
            applicable procedures;
    *      were jumpers and lifted leads controlled and restored where used;
    *      were test data and results accurate, complete, within limits, and valid;
    *      was test equipment removed following testing;
    *      where applicable for inservice testing activities, was testing performed in
            accordance with the applicable version of Section XI of the American Society of
            Mechanical Engineers Code, and were reference values consistent with the
            system design basis;
    *      was the unavailability of the tested equipment appropriately considered in the
            performance indicator (PI) data;
                                            15
 
      *        where applicable, were test results not meeting acceptance criteria addressed
                with an adequate operability evaluation, or was the system or component
                declared inoperable;
      *        where applicable for safety-related instrument control surveillance tests, was the
                reference setting data accurately incorporated into the test procedure;
      *        was equipment returned to a position or status required to support the
                performance of its safety function following testing;
      *        were all problems identified during the testing appropriately documented and
                dispositioned in the licensees CAP;
      *        where applicable, were annunciators and other alarms demonstrated to be
                functional and were annunciator and alarm setpoints consistent with design
                documents; and
      *        where applicable, were alarm response procedure entry points and actions
                consistent with the plant design and licensing documents.
      Documents reviewed are listed in the Attachment to this report. This inspection
      constituted six routine surveillance testing samples, one in-service test sample, one
      reactor coolant system leak detection inspection sample, and one containment isolation
      valve sample as defined in IP 71111.22, Sections-02 and-05.
  b. Findings
      No findings were identified.
1EP6 Drill Evaluation (71114.06)
.1  Emergency Preparedness Drill Observation
  a. Inspection Scope
      The inspectors evaluated the conduct of a routine licensee emergency drill on
      August 26, 2015, to identify any weaknesses and deficiencies in classification,
      notification, and protective action recommendation development activities. The
      inspectors observed emergency response operations in the emergency operations
      facility, technical support center, and the control room simulator to determine whether
      the event classification, notifications, and protective action recommendations were
      performed in accordance with procedures. The inspectors also attended the licensee
      drill critique to compare any inspector-observed weakness with those identified by the
      licensee staff in order to evaluate the critique and to verify whether the licensee staff was
      properly identifying weaknesses and entering them into the CAP. As part of the
      inspection, the inspectors reviewed the drill package and other documents listed in the
      Attachment to this report.
      This emergency preparedness drill inspection constituted one sample as defined in
      IP 71114.06-06.
  b. Findings
      No findings were identified.
                                              16
 
2.    RADIATION SAFETY
2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
      This inspection constituted one complete sample as defined in IP 71124.06-05.
.1  Inspection Planning and Program Reviews (02.01)
      Event Report and Effluent Report Reviews
  a. Inspection Scope
      The inspectors reviewed the Radiological Effluent Release Reports issued since the last
      inspection to determine if the reports were submitted as required by the Offsite Dose
      Calculation Manual (ODCM)/TSs. The inspectors reviewed anomalous results,
      unexpected trends, or abnormal releases identified by the licensee for further inspection
      to determine if they were evaluated, were entered in the CAP, and were adequately
      resolved.
      The inspectors selected radioactive effluent monitor operability issues reported by the
      licensee as provided in effluent release reports, to review these issues during the onsite
      inspection, as warranted, given their relative significance, and determine if the issues
      were entered into the CAP and adequately resolved.
  b. Findings
      No findings were identified.
      Offsite Dose Calculation Manual and Final Safety Analysis Report Review
  a. Inspection Scope
      The inspectors reviewed UFSAR descriptions of the radioactive effluent monitoring
      systems, treatment systems, and effluent flow paths so they could be evaluated during
      inspection walkdowns.
      The inspectors reviewed changes to the ODCM made by the licensee since the last
      inspection against the guidance in NUREG-1301, 1302, and 0133, and Regulatory
      Guides 1.109, 1.21, and 4.1. When differences were identified, the inspectors reviewed
      the technical basis or evaluations of the change during the onsite inspection to
      determine whether they were technically justified and maintain effluent releases
      as-low-as-reasonably-achievable.
      The inspectors reviewed licensee documentation to determine if the licensee has
      identified any non-radioactive systems that have become contaminated as disclosed
      either through an event report or the ODCM since the last inspection. This review
      provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59
      evaluations, and allowed a determination if any newly contaminated systems have an
      unmonitored effluent discharge path to the environment, whether any required ODCM
      revisions were made to incorporate these new pathways, and whether the associated
      effluents were reported in accordance with Regulatory Guide 1.21.
                                              17
 
  b. Findings
    No findings were identified.
    Groundwater Protection Initiative Program
  a. Inspection Scope
    The inspectors reviewed reported groundwater monitoring results and changes to the
    licensees written program for identifying and controlling contaminated spills/leaks to
    groundwater.
  b. Findings
    No findings were identified.
    Procedures, Special Reports, and Other Documents
  a. Inspection Scope
    The inspectors reviewed Licensee Event Reports, event reports, and/or special reports
    related to the Effluent Program issued since the previous inspection to identify any
    additional focus areas for the inspection based on the scope/breadth of problems
    described in these reports.
    The inspectors reviewed the Effluent Program implementing procedures, particularly
    those associated with effluent sampling, effluent monitor set-point determinations, and
    dose calculations.
    The inspectors reviewed copies of licensee and third party (independent) evaluation
    reports of the Effluent Monitoring Program since the last inspection to gather insights
    into the licensees program, and aid in selecting areas for inspection review (smart
    sampling).
  b. Findings
    No findings were identified.
.2  Walkdowns and Observations (02.02)
  a. Inspection Scope
    The inspectors walked down selected components of the gaseous and liquid discharge
    systems to evaluate whether equipment configuration and flow paths align with the
    documents reviewed in 02.01 above, and to assess equipment material condition.
    Special attention was made to identify potential unmonitored release points (such as
    open roof vents in boiling water reactor turbine decks, temporary structures butted
    against turbine, auxiliary or containment buildings), building alterations which could
    impact airborne, or liquid effluent controls, and ventilation system leakage that
    communicates directly with the environment.
                                            18
 
    For equipment or areas associated with the systems selected for review that were not
    readily accessible due to radiological conditions, the inspectors reviewed the licensee's
    material condition surveillance records, as applicable.
    The inspectors walked down filtered ventilation systems to assess for conditions such as
    degraded high-efficiency particulate air/charcoal banks, improper alignment, or system
    installation issues that would impact the performance or the effluent monitoring capability
    of the effluent system.
    As available, the inspectors observed selected portions of the routine processing and
    discharge of radioactive gaseous effluent (including sample collection and analysis) to
    evaluate whether appropriate treatment equipment was used, and the processing
    activities align with discharge permits.
    The inspectors determined if the licensee had made significant changes to their effluent
    release points (e.g., changes subject to a 10 CFR 50.59 review, or require NRC
    approval of alternate discharge points).
    As available, the inspectors observed selected portions of the routine processing and
    discharging of liquid waste (including sample collection and analysis) to determine if
    appropriate effluent treatment equipment was being used, and that radioactive liquid
    waste was being processed and discharged in accordance with procedure requirements
    and aligned with discharge permits.
  b. Findings
    No findings were identified.
.3  Sampling and Analyses (02.03)
  a. Inspection Scope
    The inspectors selected effluent sampling activities, consistent with smart sampling, and
    assessed whether adequate controls have been implemented to ensure representative
    samples were obtained (e.g., provisions for sample line flushing, vessel recirculation,
    composite samplers, etc.).
    The inspectors selected effluent discharges made with inoperable (declared
    out-of-service) effluent radiation monitors to assess whether controls were in place to
    ensure compensatory sampling was performed consistent with the radiological effluent
    TSs/ODCM, and that those controls were adequate to prevent the release of
    unmonitored liquid and gaseous effluents.
    The inspectors determined whether the facility was routinely relying on the use of
    compensatory sampling in lieu of adequate system maintenance, based on the
    frequency of compensatory sampling since the last inspection.
    The inspectors reviewed the results of the Inter-Laboratory Comparison Program to
    evaluate the quality of the radioactive effluent sample analyses, and assessed whether
    the Inter-Laboratory Comparison Program included hard-to-detect isotopes as
    appropriate.
                                            19
 
  b. Findings
    No findings were identified.
.4  Instrumentation and Equipment (02.04)
    Effluent Flow Measuring Instruments
  a. Inspection Scope
    The inspectors reviewed the methodology the licensee used to determine the effluent
    stack and vent flow rates to determine if the flow rates were consistent with radiological
    effluent TSs/ODCM or UFSAR values, and that differences between assumed and
    actual stack, and vent flow rates did not affect the results of the projected public doses.
  b. Findings
    No findings were identified.
    Air Cleaning Systems
  a. Inspection Scope
    The inspectors assessed whether surveillance test results since the previous inspection
    for TS required ventilation effluent discharge systems (high-efficiency particulate air and
    charcoal filtration), such as the Standby Gas Treatment System, and the Containment/
    Auxiliary Building Ventilation System, met TS acceptance criteria.
  b. Findings
    No findings were identified.
.5  Dose Calculations (02.05)
  a. Inspection Scope
    The inspectors reviewed all significant changes in reported dose values compared to the
    previous Radiological Effluent Release Report (e.g., a factor of five, or increases that
    approach Appendix I criteria) to evaluate the factors, which may have resulted in the
    change.
    The inspectors reviewed radioactive liquid and gaseous waste discharge permits to
    assess whether the projected doses to members of the public were accurate and based
    on representative samples of the discharge path.
    The inspectors evaluated the methods used to determine the isotopes that are included
    in the source term to ensure all applicable radionuclides are included within detectability
    standards. The review included the current Part 61 analyses to ensure hard-to-detect
    radionuclides are included in the source term.
    The inspectors reviewed changes in the licensees offsite dose calculations since the
    last inspection to evaluate whether changes were consistent with the ODCM and,
    Regulatory Guide 1.109. Inspectors reviewed meteorological dispersion and deposition
                                            20
 
  factors used in the ODCM and effluent dose calculations to evaluate whether
  appropriate factors were being used for public dose calculations.
  The inspectors reviewed the latest Land Use Census to assess whether changes
  (e.g., significant increases or decreases to population in the plant environs, changes
  in critical exposure pathways, the location of nearest member of the public, or critical
  receptor, etc.) have been factored into the dose calculations.
  For the releases reviewed above, the inspectors evaluated whether the calculated doses
  (monthly, quarterly, and annual dose) were within the 10 CFR Part 50, Appendix I, and
  TS dose criteria.
  The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank
  discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc.) to
  ensure the abnormal discharge was monitored by the discharge point effluent monitor.
  Discharges made with inoperable effluent radiation monitors, or unmonitored leakages
  were reviewed to ensure that an evaluation was made of the discharge to satisfy
  10 CFR 20.1501 so as to account for the source term and projected doses to the public.
b. Findings
  Introduction: The inspectors identified a finding of very low safety significance (Green)
  and an associated NCV of TS 5.5.1, Offsite Dose Calculation Manual, for the failure to
  establish, implement, and maintain the ODCM relative to dose calculation parameters.
  Specifically, the licensee failed to modify the parameters used in public radiation
  calculations when changes in the use of unrestricted areas were identified.
  Description: The NRC requires that the licensee identify changes in the use of
  unrestricted areas to permit modifications in monitoring programs for evaluating doses to
  individuals from principal pathways of exposure. This was described as the Land Use
  Census, in the ODCM.
  The licensee completed the land use census in September/October 2014 using licensee
  procedure CH 6.41 Land Use Census. The procedure also directed that any changes
  to critical receptors or X/Q values that modify offsite dose calculations due to the land
  use census be effective January 1 of the year following the land use census. Although
  this was normal and expected, the new and sometimes more restrictive values were not
  transferred to the offsite dose calculation software, GASPAR. As a result, the quarterly
  and annual doses that were calculated every 31 days, as required by the ODCM, were
  incorrect and non-conservative.
  Discussions with the licensee revealed that the Radiological Effluent Technical
  Specification (RETS) Radiological Environmental Monitoring Program (REMP) Specialist
  assumed the duties and responsibilities of this position in November 2014; months after
  the previous RETS-REMP Specialist had left the organization. The new individual was
  aware that the land use census had been completed, but did not realize the results were
  not incorporated into the program for evaluating doses to individuals from principal
  pathways of exposure. As part of their immediate corrective actions, the licensee
  entered this issue into their CAP as CR-2015-2972 and recalculated the dose using the
  correct calculation parameters.
                                          21
 
Analysis: The inspectors determined that the failure to establish, implement, and
maintain the dose calculation parameters of the ODCM was not in accordance with
TS 5.5.1, and was a performance deficiency.
The inspectors determined that the performance deficiency was more than minor
because it was associated with the Program and Process attribute of the Public
Radiation Safety cornerstone and adversely affected the cornerstone objective of
ensuring the adequate protection of public health and safety from exposure to
radioactive materials released into the public domain as a result of routine civilian
nuclear reactor operation. Specifically, the non-conservative calculation of dose to
members of the public impeded the ability to provide adequate protection of public health
and safety from exposure to radioactive materials released into the public domain as a
result of routine civilian nuclear reactor operations. The finding was assessed using
IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process,
and was determined to be of very low safety significance (Green) because the issue did
not represent a significant deficiency in evaluating a planned or unplanned effluent
release since the resulting dose was not grossly underestimated.
As described above, the cause for this failure was attributed to the lack of turnover to the
new program owner from the previous program owner. As a result, the finding had a
cross-cutting aspect of Training in the Human Performance cross-cutting area because
the licensee did not ensure adequate knowledge transfer to maintain a knowledgeable,
technically competent workforce. (H.9).
Enforcement: TS 5.5.1, Offsite Dose Calculation Manual, requires the licensee to
establish, implement, and maintain the ODCM. ODCM, Section I.B, required dose rates
to be calculated for: (1) noble gases and (2) iodines and particulates. Dose rates as
defined in this section are based on 10 CFR 50, Appendix I, limits of millirem per quarter
and millirem per year. All dose pathways of major importance in the Palisades Nuclear
Plant environs are considered, and are to be evaluated at the offsite exposure points
where maximum concentrations are expected to exist (overland sector site boundaries)
and nearest residents.
Contrary to the above, between January 1 and July 16, 2015, the licensee failed to
calculate the dose rates from noble gases, iodines, and particulates to the nearest
resident. As part of their immediate corrective actions, the licensee recalculated the
dose using the correct calculation parameters. Because this violation was of very low
safety significance and was entered into the licensees CAP as CR-2015-2972, this
violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC
Enforcement Policy. (NCV 05000255/2015003-02, Failure to Establish, Implement,
and Maintain the ODCM Relative to Dose Calculation Parameters)
                                        22
 
.6  Groundwater Protection Initiative Implementation (02.06)
  a. Inspection Scope
    The inspectors reviewed monitoring results of the Groundwater Protection Initiative to
    determine if the licensee had implemented its program as intended, and to identify any
    anomalous results. For anomalous results or missed samples, the inspectors assessed
    whether the licensee had identified and addressed deficiencies through its CAP.
    The inspectors reviewed identified leakage or spill events and entries made into
    10 CFR 50.75(g) records. The inspectors reviewed evaluations of leaks or spills and
    reviewed any remediation actions taken for effectiveness. The inspectors reviewed
    onsite contamination events involving contamination of ground water and assessed
    whether the source of the leak or spill was identified and mitigated.
    For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the
    inspectors assessed whether an evaluation was performed to determine the type and
    amount of radioactive material that was discharged by:
    *        assessing whether sufficient radiological surveys were performed to evaluate the
              extent of the contamination and the radiological source term and assessing
              whether a survey/evaluation had been performed to include consideration of
              hard-to-detect radionuclides; and
    *        determining whether the licensee completed offsite notifications, as provided in
              its Groundwater Protection Initiative implementing procedures.
    The inspectors reviewed the evaluation of discharges from onsite surface water bodies
    that contained or potentially contained radioactivity, and the potential for groundwater
    leakage from these onsite surface water bodies. The inspectors assessed whether the
    licensee was properly accounting for discharges from these surface water bodies as part
    of their Effluent Release Reports.
    The inspectors assessed whether onsite groundwater sample results and a description
    of any significant onsite leaks/spills into groundwater for each calendar year were
    documented in the Annual Radiological Environmental Operating Report for the REMP,
    or the Annual Radiological Effluent Release Report for the RETS.
    For significant, new effluent discharge points (such as significant or continuing leakage
    to groundwater that continues to impact the environment if not remediated), the
    inspectors evaluated whether the ODCM was updated to include the new release point.
  b. Findings
    No findings were identified.
.7  Problem Identification and Resolution (02.07)
  a. Inspection Scope
    The inspectors assessed whether problems associated with the Effluent Monitoring and
    Control Program were being identified by the licensee at an appropriate threshold, and
                                              23
 
      were properly addressed for resolution in the licensee CAP. In addition, the inspectors
      evaluated the appropriateness of the corrective actions for a selected sample of
      problems documented by the licensee involving radiation monitoring and exposure
      controls.
  b. Findings
      No findings were identified.
4.    OTHER ACTIVITIES
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
      Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
      Security
4OA1 Performance Indicator Verification (71151)
.1  Mitigating Systems Performance IndexHigh Pressure Injection Systems
  a. Inspection Scope
      The inspectors sampled licensee submittals for the Mitigating Systems Performance
      Index (MSPI) - High Pressure Injection Systems (MS07) PI for the period from the third
      quarter 2014 through the second quarter 2015. To determine the accuracy of the PI
      data reported during those periods, PI definitions and guidance contained in Nuclear
      Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator
      Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the
      licensees operator narrative logs, CRs, MSPI derivation reports, event reports and NRC
      Integrated IRs for the period of July 1, 2014, through June 30, 2015, to validate the
      accuracy of the submittals. The inspectors reviewed the MSPI component risk
      coefficient to determine if it had changed by more than 25 percent in value since the
      previous inspection, and if so, that the change was in accordance with applicable
      NEI guidance. The inspectors also reviewed the licensees CR 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 MSPI - High Pressure Injection System sample as
      defined in IP 71151-05.
  b. Findings
      No findings were identified.
.2  Mitigating Systems Performance IndexResidual Heat Removal System
  a. Inspection Scope
      The inspectors sampled licensee submittals for the MSPI - Residual Heat Removal
      System (MS09) PI for the period from the third quarter 2014 through the second
      quarter 2015. To determine the accuracy of the PI data reported during those periods,
      PI definitions and guidance contained in NEI 99-02, Regulatory Assessment
      Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The
      inspectors reviewed the licensees operator narrative logs, CRs, MSPI derivation reports,
                                            24
 
    event reports and NRC Integrated IRs for the period of July 1, 2014, to June 30, 2015, to
    validate the accuracy of the submittals. The inspectors reviewed the MSPI component
    risk coefficient to determine if it had changed by more than 25 percent in value since the
    previous inspection, and if so, that the change was in accordance with applicable NEI
    guidance. The inspectors also reviewed the licensees CR 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 MSPI - Residual Heat Removal System sample as
    defined in IP 71151-05.
  b. Findings
    No findings were identified.
.3  Reactor Coolant System Specific Activity
  a. Inspection Scope
    The inspectors sampled licensee submittals for the reactor coolant system specific
    activity PI for Palisades Nuclear Plant for the period from the fourth quarter 2014 through
    the second quarter 2015. The inspectors used Performance Indicator definitions and
    guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator
    Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data
    reported during those periods. The inspectors reviewed the licensees reactor coolant
    system chemistry samples, TS requirements, CRs, event reports, and NRC Integrated
    IRs to validate the accuracy of the submittals. The inspectors also reviewed the
    licensees CR 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 reactor coolant system specific activity sample as
    defined in IP 71151-05.
  b. Findings
    No findings were identified.
.4  Reactor Coolant System Leakage
  a. Inspection Scope
    The inspectors sampled licensee submittals for the Reactor Coolant System Leakage PI
    for the period from the fourth quarter 2014 through the second quarter 2015. To
    determine the accuracy of the PI data reported during those periods, PI definitions and
    guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator
    Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the
    licensees operator logs, Reactor Coolant System leakage tracking data, CRs, event
    reports, and NRC Integrated IRs for the period of the fourth quarter 2014 through the
    second quarter 2015 to validate the accuracy of the submittals. The inspectors also
    reviewed the licensees CR database to determine if any problems had been identified
                                              25
 
    with the PI data collected or transmitted for this indicator. Documents reviewed are
    listed in the Attachment to this report.
    This inspection constituted one reactor coolant system leakage sample as defined in
    IP 71151-05.
  b. Findings
    No findings were identified.
.5  Occupational Exposure Control Effectiveness
  a. Inspection Scope
    The inspectors sampled licensee submittals for the Occupational Exposure Control
    Effectiveness PI for the period from the second quarter 2014 through the second
    quarter 2015. The inspectors used PI definitions and guidance contained in NEI 99-02,
    Regulatory Assessment Performance Indicator Guideline, Revision 7, dated
    August 2013, to determine the accuracy of the PI data reported during those periods.
    The inspectors reviewed the licensees assessment of the PI for occupational radiation
    safety to determine if indicator related data was adequately assessed and reported. To
    assess the adequacy of the licensees PI data collection and analyses, the inspectors
    discussed with radiation protection staff, the scope and breadth of its data review and
    the results of those reviews. The inspectors independently reviewed electronic personal
    dosimetry dose rate and accumulated dose alarms and dose reports, and the dose
    assignments for any intakes that occurred during the time period reviewed to determine
    if there were potentially unrecognized occurrences. The inspectors also conducted
    walkdowns of numerous locked high and very high radiation area entrances to determine
    the adequacy of the controls in place for these areas. Documents reviewed are listed in
    the Attachment to this report.
    This inspection constituted one occupational exposure control effectiveness sample as
    defined in IP 71151-05.
  b. Findings
    No findings were identified.
.6  Radiological Effluent Technical Specification/Offsite Dose Calculation Manual
    Radiological Effluent Occurrences
  a. Inspection Scope
    The inspectors sampled licensee submittals for the RETS/ODCM radiological effluent
    occurrences PI for the period from the third quarter 2014 through the second
    quarter 2015. The inspectors used PI definitions and guidance contained in NEI 99-02,
    Regulatory Assessment Performance Indicator Guideline, Revision 7, dated
    August 2013, to determine the accuracy of the PI data reported during those periods.
    The inspectors reviewed the licensees CR database and selected individual reports
    generated since this indicator was last reviewed to identify any potential occurrences
    such as unmonitored, uncontrolled, or improperly calculated effluent releases that may
    have impacted offsite dose. The inspectors reviewed gaseous effluent summary data
                                            26
 
      and the results of associated offsite dose calculations for selected dates to determine if
      indicator results were accurately reported. The inspectors also reviewed the licensees
      methods for quantifying gaseous and liquid effluents and determining effluent dose.
      Documents reviewed are listed in the Attachment to this report.
      This inspection constituted one RETS/ODCM radiological effluent occurrences sample
      as defined in IP 71151-05.
  b. Findings
      No findings were identified.
4OA2 Identification and Resolution of Problems (71152)
.1  Routine Review of Items Entered into the Corrective Action Program
  a. Inspection Scope
      As part of the various baseline IPs 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 CAP at an
      appropriate threshold, that adequate attention was being given to timely corrective
      actions, and that adverse trends were identified and addressed. Attributes reviewed
      included: identification of the problem was complete and accurate; timeliness was
      commensurate with the safety significance; evaluation and disposition of performance
      issues, generic implications, common causes, contributing factors, root causes,
      extent-of-condition reviews, and previous occurrences reviews were proper and
      adequate; and that the classification, prioritization, focus, and timeliness of corrective
      actions were commensurate with safety and sufficient to prevent recurrence of the issue.
      Minor issues entered into the licensees CAP as a result of the inspectors observations
      are included in the Attachment to this report.
      These routine reviews for the identification and resolution of problems did not constitute
      any additional inspection samples. Instead, by procedure they were considered an
      integral part of the inspections performed during the quarter and documented in
      Section 1 of this report.
  b. Findings
      No findings were identified.
.2  Daily Corrective Action Program Reviews
  a. Inspection Scope
      In order to assist with the identification of repetitive equipment failures and specific
      human performance issues for follow-up, the inspectors performed a daily screening of
      items entered into the licensees CAP. This review was accomplished through
      inspection of the stations daily CR packages.
      These daily reviews were performed by procedure as part of the inspectors daily plant
      status monitoring activities and, as such, did not constitute any separate inspection
      samples.
                                              27
 
  b. Findings
      No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)
.1  Event Notification for Spill of Sewage from Chemical Toilet
  a. Inspection Scope
      The inspectors reviewed the plants response to an Event Notification for a Spill of
      Sewage from a Chemical Toilet on July 13, 2015. The inspectors reviewed the
      licensees actions to assess and report the spill. The spill occurred during a rainstorm
      with high winds which caused the chemical toilet to tip over and spill. The spill had no
      impact on plant operations. The inspectors also reviewed the Material Safety Data
      Sheet for the chemicals involved and the licensees notifications of government agencies
      to validate appropriate actions were taken and notifications were made. Documents
      reviewed are listed in the Attachment to this report.
      This event follow-up review constituted one sample as defined in IP 71153-05.
  b. Findings
      No findings were identified.
4OA5 Other Activities
.1  Contingency Plans for Licensee Strikes or Lockouts (IP 92709)
  a. Inspection Scope
      The United Government Security Officers of America Local 29 contract ended on
      July 1, 2015. The contract was extended multiple times past this date to continue
      negotiations between the licensee and union officials. Prior to the extended contract end
      date of August 21, 2015, the resident inspectors and Region III security specialists
      developed a strike/lockout contingency plan. The inspectors reviewed the licensees
      strike/lockout preparations, including staffing and training. A verbal agreement was
      reached between the union and Entergy on August 21, 2015, and was ratified on
      August 24, 2015, without a strike/lockout. These activities constituted one sample as
      defined in IP 92709.
  b. Findings
      No findings were identified.
4OA6 Management Meetings
.1  Exit Meeting Summary
      On October 29, 2015, the inspectors presented the inspection results to Mr. A. Vitale,
      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.
                                            28
 
.2  Interim Exit Meetings
    Interim exits were conducted for:
    *        The inspection results for the areas of radioactive gaseous and liquid effluent
              treatment; and reactor coolant system specific activity, occupational exposure
              control effectiveness, and RETS/ODCM radiological effluent occurrences PI
              verification with Mr. A. Vitale, Site Vice President, on July 17, 2015.
    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.
ATTACHMENT: SUPPLEMENTAL INFORMATION
                                              29
 
                              SUPPLEMENTAL INFORMATION
                                KEY POINTS OF CONTACT
Licensee
A. Vitale, Site Vice President
A. Williams, General Manager Plant Operations
B. Baker, Operations Manager Support
T. Mulford, Operations Manager
R. Craven, Senior Manager Production
B. Dotson, Licensing Specialist
T. Davis, Licensing Specialist
O. Gustafson, Regulatory and Performance Improvement Director
J. Hardy, Regulatory Assurance Manager
J. Haumersen, Senior Manager Projects
D. Malone, Emergency Preparedness Manager
W. Nelson, Training Manager
K. OConnor, Engineering Design Manager
J. Borah, Engineering Systems and Components Manager
G. Heisterman, Senior Maintenance Manager
M. Schultheis, Performance Improvement Manager
C. Plachta, Nuclear Independent Oversight Manager
P. Russell, Engineering Director
J. Tharp, Security Manager
D. Nestle, Radiation Protection Manager
M. Soja, Interim Chemistry Manager
K. Strickland, Environmental Specialist
Nuclear Regulatory Commission
E. Duncan, Chief, Branch 3
                                                              Attachment
 
                LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
                              Failure to Justify Continued Service of Safety-Related
                              Electrolytic Capacitors Installed Beyond Their Service Life
05000255/2015003-01    NCV
                              (Section 1R15)
                              Failure to Establish, Implement, and Maintain the Offsite
  05000255/2015003-02  NCV
                              Dose Calculation Manual (Section 2RS6.5.b)
Closed
                              Failure to Justify Continued Service of Safety-Related
                              Electrolytic Capacitors Installed Beyond Their Service Life
  05000255/2015003-01  NCV
                              (Section 1R15)
                              Failure to Establish, Implement, and Maintain the Offsite
  05000255/2015003-02  NCV
                              Dose Calculation Manual (Section 2RS6.5.b)
Discussed
None
                                          2
 
                                  LIST OF DOCUMENTS REVIEWED
The following is a partial list of documents reviewed during the inspection. Inclusion on this list
does not imply that the NRC inspector reviewed the documents in their entirety, but rather that
selected sections or portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
1R04 Equipment Alignment
- CR0PLP-2014-04910, Perform A Radiographic Examination of the CV-1655, Condensing Unit
  VC-11 Service Water Control, Valve Body, October 6, 2014
- CR-PLP-2014-02801, Tube Leak Discovered in E-901, Raw Water Heat Exchanger,
  April 26, 2014
- CR-PLP-2014-03090, CV-0821, CCW Heat Exchanger E-54A Temp Control Positioner Has a
  Small Air Leak, May 19, 2014
- CR-PLP-2014-03563, Main Lube Oil Bearing Supply Temperature is High, June 30, 2014
- CR-PLP-2014-03602, P-7A Basket Strainer High D/P Alarm, July 3, 2014
- CR-PLP-2014-03607, P-7C Pump Shaft in the Area of the Packing was Worn in an Hour Glass
  Shape, July 3, 2014
- CR-PLP-2014-04427, UT Measured Pipe Thickness Fell Below the Screening Criteria,
  September 10, 2014
- CR-PLP-2014-04502, While Performing Work on Service Water Pump P-7A Under
  WO #52474416-03, Some Problems Were Encountered, September 15, 2014
- CR-PLP-2014-04959, Maintenance Performed on the Pump P-7A Affected the Current
  Vibration Reference Values for the Test, October 12, 2014
- CR-PLP-2014-4401, Corrective Actions Associated with CR-PLP-2012-05813 Were Ineffective
  in the Prevention of Service Water Leaks Due to Cavitation, September 10, 2014
- CR-PLP-2015-00348, Service Water Side of the Lube Oil Cooler (E-31B) on Emergency
  Diesel Generator 1-2 East Side End Bell Cover Had Experienced Some Deep Corrosion in
  Some Areas of the Sealing Gasket, January 21, 2015
- CR-PLP-2015-00355, Copper Tubing Exiting Critical Service Water Piping Immediately
  Upstream of Control Valve CV-0885 (D/G 102 Service Water Inlet) Has a Pin Hole Leak,
  January 21, 2015
- CR-PLP-2015-00967, Engineering Review Has Determined that Credible New Information
  Exists that Potentially Challenges the Conservatism of Current Flooding Design Assumptions
  or Requirements, March 3, 2015
- CR-PLP-2015-01229, MV-SW176, K-7B Lube Oil Cooler E-24D Service Water Inlet Has an
  Active Packing Leak of 6 Drops Per Minute, March 23, 2015
- CR-PLP-2015-01573, Ultrasonic Thickness Measurements Less Than Tmin for Piping
  JB-1-10 Between E-15B and MV-SW201, April 15, 2015
- CR-PLP-2015-02177, P-7C Packing Shaft Was Excessively Worn in the Area Where the
  Packing Seals Against the Packing Shaft, May 27, 2015
- CR-PLP-2015-02578, E-15A Turbine Generator K-1 Main Lube Oil Cooler, West End Bell Has
  Approximately a 2.5-3 Gallon Per Hour Service Water Leak, June 23, 2015
- CR-PLP-2015-03178, DPS-1319 SWS PP P-7A Basket Strainer Hi Differential Pressure
  Switch is Alarming, July 31, 2015
- CR-PLP-2015-03404, P-7A Service Water Pump Packing Leakage Has Been Elevated and
  Has Required Daily Packing Adjustments, August 15, 2015
- CR-PLP-2015-03953, C-903A, Feedwater Purity Building Air Compressor Oil Pressure at
  18 psi with ESOMS Minimum of 20 psi, September 18, 2015
                                                    3
 
- CR-PLP-2015-04012, Alarm EK-1105 (Air Compressor Standby Comp Running)
  Unexpectedly, September 19, 2015
- CR-PLP-2015-04037, Standby Compressor Started Despite Normal Operating Pressure in
  System, September 20, 2015
- CR-PLP-2015-04122, C-903B Feedwater Purity Building Air Compressor Has Oil Leaking
  From Copper Tube Fitting, September 22, 2015
- Drawing M-214, Sheet 1, Lube Oil, Fuel Oil, and Diesel Generating Systems, Revision 69
- EC 5000121478, Replace Service Water Supply and Discharge Piping & Components for CR
  HVAC Condenser VC-10, Revision 2WT-PLP-2013-0324, Track Completion of Actions in
  Service Water Top Ten Action Plan, December 17, 2013
- EN-DC-136, EC-36294, Augmentation of Existing Proceduralized TM (SOP-19, Instrument Air
  System, Att. 6, Supply Service Air Header with Temporary Compressor) to Allow Rapid
  Realignment of IA Compressor C-2C, Revision 6
- M-203, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,
  Sheet A, Revision 7
- M-203, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,
  Sheet 2, Revision 27
- M-204, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,
  Sheet A, Revision 8
- M-204, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,
  Sheet 1A, Revision 43
- M-204, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,
  Sheet 1, Revision 84
- M-204, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,
  Sheet 1B, Revision 41
- M-208, Piping & Instrument Diagram, Non-Critical Service Water System, Sheet 1,
  Revision 105
- M-208, Piping & Instrument Diagram, Service Water System, Sheet 1A, Revision 65
- M-208, Piping & Instrument Diagram, Service Water system, Sheet 1B, Revision 38
- M-212, Piping & Instrument Diagram; Service & Instrument Air System, Sheet 1, Revision 83
- M-213, Piping & Instrument Diagram, Service Water, Screen Structure and Chlorinator,
  Revision 95
- SEP-SW-PLP-002, Service Water & Fire Protection Inspection Program, Revision 3
- SOP-12, Auxiliary Feedwater System Checklist, Revision 73
- SOP-15, Service Water System, Revision 60
- SOP-19, Instrument Air System, Revision 64
- SOP-3, Safety Injection and Shutdown Cooling System, Revision 100
- WO 384456, Replace MV-SW136; E-54B SW Outlet CV-028 Bypass
- WO 384458, Replace MV-SW-282; Control Room HVAC Condenser VC-10 SW Outlet
- WO 384459, Replace MV-SW283; Control Room HVAC Condenser VC-10 SW Inlet
- WO 52325906, CV-0826; Replace Valve Assembly
1R05 Fire Protection
- Admin 4.49, Non-Power Operation Fire Risk Management, Revision 0
- EN-DC-127, Control of Hot work & Ignition Sources, Revision 15
- EN-DC-161, Control of Combustibles, Revision 13
- EN-DC-359, Fire Risk Management During Non-Power Operations for NFPA 805 Plants,
  Revision 1
- Palisades Nuclear Plant Fire Hazards Analysis, Revision 7
                                                4
 
- Pre Fire Plan 10/Rooms 001, 001A, 001B, & 004, East Engineered Safeguards Room,
  Elevation 570 & 579
- Pre Fire Plan 16 / Room 123, Component Cooling Pump Room, Elevation 590
- Pre Fire Plan 16 / Room 238, Component Cooling Pump Room, Elevation 607 6
- Pre Fire Plan 16 / Room 338, Component Cooling Pump Room, Elevation 625
- Pre Fire Plan 29, 30, & 31 / Mechanical Equipment Rooms, Elevation 629-2 & 639
- Pre Fire Plan 6 / Rooms 116B & 147, Diesel Generator 1-2 and Fuel Oil Day Tank Room,
  Elevation 590, 607, & 625
- Pre Fire Plan 9 / Room 13, Screen House/Intake Structure, Elevation 590
- Refueling Outage 1R24 Fire Protection Log 2014
1R06 Flood Protection
- CR-PLP-2015-00585, Improperly Sized Sprinkler Heads Replaced in Cable Spreading Room,
  February 4, 2015
- CR-PLP-2015-03229, Eleven Inches of Water and Submerged Cables Discovered During
  MH-8 Cable and Manhole Inspection, August 3, 2015
- DBD-2.05, Reactor Protective System Safety Injection Signal Anticipated Transient Without
  Scram, Revision 7
- DBD-7.08, Plant Protection Against Flooding, Revision 6
- EN-WM-105, MH-4 Inspection Electrical, Revision February 3, 3007
- EN-WM-105, MH-8 Cable & Manhole Inspection, Revision February 3, 2007
- WO 52575326, D/GS and D Bus Floor Drain Flow Verification
1R11 Licensed Operator Requalification Program
- CR-PLP-2015-03464, Documentation of Coastdown Commencing on August 25, 2015,
  August 20, 2015
- EOP Supplement 1, Pressure Temperature Limit Curves, Revision 5
- EOP Supplement 2, PCS Cooldown Strategy, Revision 2
- EOP-1.0, Standard Post-Trip Actions, Revision 16
- EOP-2.0, Reactor Trip Recovery, Revision 13
- GOP-8, Power Reduction and Plant Shutdown to Mode 2 or Mode 3  525°F, Revision 36
- GOP-9, Mode 3525°F to Mode 4 or Mode 5, Revision 36
- PNT 17.0 Attachment 2, Form PNF-17-SES, Simulator Exam Scenario SES-115 Revision 4,
  Revision 5
- PO-2, PCS Heatup/Cooldown Operations, Revision 7
- SOP-1B, Primary Coolant System - Cooldown, Revision 19
- SOP-2A, Chemical and Volume Control System
1R12 Maintenance Effectiveness
- AOP-32, Loss Of Containment Integrity, Revision 0
- CIS-M-6, Personnel Air Lock Seal Contact Adjustment, Revision 0
- CR-PLP-2010-05643, Excessive Leakage on Inner Door Seal During DWO-13 LLRT-Local
  Leak Rate Tests for Inner and Outer Personnel Air Lock Door Seals, October 26, 2010
- CR-PLP-2011-01048, Inner Door Leakage Was High During Performance of Personnel Air
  Lock Test, DWO-13, March 3, 2011
- CR-PLP-2011-03574, Inner Door Leakage Was 3650 sccm During Performance of DWO-13
  LLRT-Local Leak Rate Tests for Inner and Outer Personnel Air Lock Door Seals, July 20, 2011
                                              5
 
- CR-PLP-2011-07003, Determine if There is a Method to Compensate for the Non-Uniform
  Seal Grooves and Compression Set of Seal Material or Document Acceptability of Continuing
  Under Current Conditions, December 22, 2011
- CR-PLP-2013-01894, Inner Door Leak Rate was 9011 sccm Per Step During DWO-13
  LLRT-Local Leak Rate Tests for Inner and Outer Personnel Air Lock Door Seals,
  April 26, 2013
- CR-PLP-2013-01965, During Performance of DWO-13, LLRT for Inner and Outer Personnel
  Air Lock Doors, Inner Door Test Pressure Would Not Return to 10.5-11.5 psig, May 1, 2013
- CR-PLP-2014-00254, AOP-32, Loss of Containment Integrity Was Not Entered When Entry
  Conditions Were Met, January 15, 2014
- CR-PLP-2014-05929, Assignment of Responsible Manager for Category C, Non-Significant
  CR, December 29, 2014
- CR-PLP-2014-05929, During Local Leak Rate Test Inner Door Leakage Determined to be
  5438 scfm With An Acceptance Criteria of Less Than or Equal to 3474 scfm,
  December 23, 2014
- CR-PLP-2014-05929, Ensure That Condition Documented in CR-PLP-2014-05930 is
  Appropriately Addressed Within the Scope of Corrective Action Plan, December 29, 2014
- CR-PLP-2015-00911, Evaluate Design of Inner and Outer Personnel Airlock (MZ-19) Seals,
  May 7, 2015
- CR-PLP-2015-03181, Entered AOP-32 for Inoperable Containment Inner Airlock Door,
  July 31, 2015
- CR-PLP-2015-03279, MZ-19 Inner Airlock Door Declared Inoperable Due to Excessive
  Leakage, August 6, 2015
- DBD-2.09, Containment Building, Revision 4
- DR-PLP-2015-00911, Excessive Leakage Excessive During Local Leak Rate Test of Inner
  Personnel Air Lock Door, February 27, 2015
- DWO-13, LLRT - Local Leak Rate Tests for Inner and Outer Personnel Air Lock Door Seals,
  Revision 26
- EN-DC-205, Functional Failure Determination Form for CR-PLP-2013-01965, Revision 4
- EN-DC-205, Functional Failure Determination Form, Revision 5
- EN-LI-118, Equipment Failure Evaluation, Revision 21
- EN-LI-119, Apparent Cause Evaluation Report for Failure of Personnel Air Lock Leak Rate
  Testing, Revision 1
- EN-MA-123, Rework Investigation Template for CR-PLP-2013-01965, Revision 5
- WO 407323 01, MZ-19, Inner Door Leakage Was Excessive Repair Seal
- WO 418803 01, MZ-19, Adjust Inner Door Seal (Contingency)
1R13 Maintenance Risk Assessments and Emergent Work Control
- AOP-30, Loss of Shutdown Cooling, Revision 1
- CR-PLP-2015-03144, NRC Inspector Identified Concern With the Number of Tie-Downs
  Securing Shielded Cast to Trailer During Purification Demineralizer Filter Change Out,
  July 28, 2015
- CR-PLP-2015-03682, Diver in Tilt Pit Received Alarm on an Extremity, Informational,
  Non-Whole Body Electronic Dosimeter, September 3, 2015
- CR-PLP-2015-03683, Discovered Galled Locking Cylinder Bracket Bolt During Removal of
  Locking Cylinder from the Spent fuel Side Upender, September 4, 2015
- CR-PLP-2015-03690, East Side Top Bolt Galled During Installation During Reassembly of
  Spent Fuel Side Upender Locking Cylinder, September 4, 2015
- CR-PLP-2015-04133, Implementation of EN-DC-161 During HRPOS, September 22, 2015
- CR-PLP-2015-04156, CRDM Located at Position A11 Was Found Stuck, September 22, 2015
                                                6
 
- EN-DC-161, Control of Combustibles, Revision 13
- EN-DC-359, Fire Risk Management During Non-Power Operations for NFPA 805 Plants,
  Revision 1
- EN-IS-123, Electrical Safety, Revision 14
- EN-MA-118, Foreign Material Exclusion, Revision 10
- EN-MA-119, Material Handling Program, Revision 23
- EN-MA-127, Conduct of Diving Operations, Revision 9
- EN-OP-116, Infrequently Performed Tests For Evolutions, Revision 12
- EN-RP-151, Radiological Diving, Revision 3
- FPIP-4, Fire Protection Systems and fire Protection Equipment, Revision 34
- OL-PLP-2014-0026, ORAT RO-24, Revision 1
- Procedure 4.49, Non-Power Operation Fire Risk Management, Revision 0
- Refueling Outage 1R24 Fire Protection Log
- RFL-D-11, Uncouple CRDMs and Raise Rack Extensions, Revision 8
- WI-RSD-R-016, Replacement of Purification Demineralizer Filter, Revision 11
- WO 2424601, H-13, Rebuild and Reinstall SFP Side Upender Locking Cylinder
- WO 381087, N-50, Uncouple CRDMs and Raise Rack Extensions
- WO 386059, 72-13, Replace DC Contactor and Install Current Limiting Fuses
- WO 409729, H-5, Inspect Wheels and Structure of Fuel Transfer Cart
- WO 52549986, F-54A, Replacement of Filter Prior to 1R24
1R15 Operability Determinations and Functionality Assessments
- AOP-29, PCP Abnormal Conditions, Revision 4
- ARP-5, PCP Steam Generator and Rod Drives Scheme EK-09 (C-12), Revision 102
- Calculation # E48-LE-01, Transamerica Delavel Containment Level Element, Revision 12
- CR-PLP-2011-01341, NRC Identified Concern With Regards to Part 21 Document During the
  Deferral of Governor Replacement, March 18, 2011
- CR-PLP-2012-05721, NRC Issued IN 2012-11: Age-Related Capacitor Degradation on
  July 23, 2012, August 16, 2012
- CR-PLP-2014-05918, MO-45 Control Room Channel Checks are Close to Being Outside
  Acceptance Criteria, December 21, 2014
- CR-PLP-2015,03064, Clarification Required in Maintenance Rule Scoping Document for
  Containment Level Instrumentation, July 22, 2015
- CR-PLP-2015-00596, Trend in P-50A Oil Level, February 5, 2015
- CR-PLP-2015-00757, Safety Injection Tank T-82C Pressure Transmitter Spiking,
  February 17, 2015
- CR-PLP-2015-00998, Open Indicating Light for CV-0944A Failed to Light, March 6, 2015
- CR-PLP-2015-01007, Unexpected Primary Makeup Tank T-81 Hi-Lo Alarm, March 8, 2015
- CR-PLP-2015-01133, Containment Radiation Monitor RIA-1817 Warning Light is Illuminated,
  March 16, 2015
- CR-PLP-2015-01236, Unexpected Charging Low Flow Alarm EK-0735, March 25, 2015
- CR-PLP-2015-01943, Safety Injection Tank T-82B Vent Valve CV-3065, May 12, 2015
- CR-PLP-2015-01994, Fire Protection Review of Oil Leak on PCP 50A, May 14, 2015
- CR-PLP-2015-02559, Containment Level Indicating Transmitter Found to be Indicating Below
  the Minimum Required, June 21, 2015
- CR-PLP-2015-02828, Received EK-0949, P-50A Seal Pressure Off-Normal, July 6, 2015
- CR-PLP-2015-02946, Oily Smell and Film Detected During Dewatering Setup, July 13, 2015
- CR-PLP-2015-03285, Based on Repair of LIT-0446B, Initiate A WO to Perform Same Repairs
  to LIT-0446A, August 6, 2015
                                                7
 
- CR-PLP-2015-03536, LIT-0446A Containment Level Transmitter Indicator, A Level Indication
  Appears Erratic On the PPC, August 26, 2015
- CR-PLP-2015-03547, LIT-0446A, LIT-0446B Containment Floor Level Transmitters Do Not
  Meet the Acceptance Criteria of MO-45, August 27, 2015
- CR-PLP-2015-04972, Failure to Justify Continued Service of Safety-Related Electrolytic
  Capacitors Installed Beyond Their Service Life, October 13, 2015
- DBD-2.04, Primary Coolant System, Revision 8
- DBD-7.02, Appendix A, Table A-1, EQ Master Equipment List, Revision 13
- EN-DC-153, Preventive Maintenance Component Classification, Revision 12
- EN-DC-205, Functional Failure Determination Form for CR-PLP-2015-02559, Revision 5
- EN-WM-105, Remove LIT-0446A to Bench to Replace Convertor Capacitor, June 21, 2011
- EOP-4.0, Loss-of-Coolant Accident Recovery Basis, Revision 14
- EOP-4.0, Loss-of-Coolant Accident Recovery, Revision 23
- EOP-9.0, Functional Recovery Procedure, Revision 22
- FSAR Chapter 7, Instrumentation and Controls, Revision 31
- MO-45, Control Room Channel Checks, Revision 10
- Oil Level Trends, P-50A, 2006-2015
- Operations Aggregate List, August 24, 2015
- Operator Burden, Primary Makeup Tank T-81 Auto Makeup Capability Does Not Work,
  June 26, 2015
- Operator Burden, Safety Injection Tank T-82B Vent Valve CV-3065Not Working Properly,
  June 10, 2015
- PLO-RPT-12-00026, EGAD-EP-10, Palisades Maintenance Rule Scoping Document,
  Revision 0
- PNP 2015-058, Technical Specification Required Report, August 3, 2015
- RI-68, Containment Water Level and Sump Level Monitor Calibration, Revision 12
- Vendor Document M0001EB-0856, Allis Chalmers PCP Motor
- WO 380046, LIT-0446B; Replace LIT Water Level Transmitter Drifting
1R19 Post-Maintenance Testing
- CR-PLP-2015-03092, Amber Light for LTRI-0101A Heater Power Supply Failed During
  Performance of MI-43, July 23, 2015
- CR-PLP-2015-04299, New Valve Procured to be Installed as CV-0826 CCW HX E-54B SW
  Outlet Does Not Match the Configuration of the Valve Removed, September 25, 2015
- CR-PLP-2015-04380, CV-0826 CCW HX E-54B SW Outlet Failed Leakage Test,
  September 27, 2015
- CR-PLP-2015-04562, Unable to Fully Evaluate Post-Maintenances Diagnostic Testing on
  CV-0826 Due to Failure to Collect Torque Data, October 1, 2015
- CVCO-4, Periodic Test Procedure - Charging Pumps, Revision 7
- EC-60236, Evaluation of Alternate Valve Disc Hard Stop Configuration for CCW Heat
  Exchanger (E-54B) Service Water Outlet Valve CV-0826, Revision 0
- EN-MA-143, Use of VIPER or VOTES Infinity Air Operator Valve Diagnostics, Revision 4
- M-208, Piping & Instrument Diagram Service Water System, Sheet 1A, Revision 65
- MI-43, Reactor Vessel Level Monitoring System Channel Check, Revision 18
- QO-5, Valve Stroke Testing Data Sheet, CV-0821, CV-0822, CV-0826, Attachment 17,
  Revision 94
- WO 00384456 04, Replace MV-SW136, SW Outlet CV-0826 Bypass
- WO 52325906 01, CV-0826, CCW HX E-54B SW Outlet Valve Replace Vale
- WO 52436026 02, CV-0821, Inspect Valve and Repair or Replace as Necessary
- WO 52436027 04, CV-0822, Inspect Valve and Repair or Replace as Necessary
                                                8
 
- WO 52541561 02, CV/VOP-0915; Diagnostic Testing (Return To Service)
- WO 52617441 01, MI-43 Reactor Vessel Level Monitoring System Channel Check
1R20 Outage Activities
- Admin 4.49, Non-Power Operation Fire Risk Management, Revision 0
- AOP-25, Loss of Refueling Water Accident, Revision 0
- AOP-26, Loss of Spent Fuel Pool Cooling, Revision 2
- AOP-30, Loss of Shutdown Cooling, Revision 1
- AOP-34, Fuel Handling Accident, Revision 0
- CR-2015-04249, Penetration MZ-30, Containment Spray Pump Discharge was Not Listed on
  GOP-14, Attachment 12, September 25, 2015
- CR-PLP-2014-04909, Create a WO to Internally Inspect the Entire Length of the Intake Pipe
  and the Lakebed Immediately Above the Intake Pipe, October 10, 2014
- CR-PLP-2014-04924, Replace Power Cables Between EX-04 and 2400 V Busses 1C and 1D
  With Larger Higher Amp Rated Cables, October 10, 2014
- CR-PLP-2015-03039, Fire Risk Management During Non-Power Operations for NFPA 805
  Plants Have Not Been Fully Implemented in the Outage Schedule, July 20, 2015
- CR-PLP-2015-03469, Leakage Identified on MV-SW137, East ESS Room Cooler VHX-27A
  Outlet, August 20, 2015
- CR-PLP-2015-03840, Oil Build Up Observed Under Fill Port that Leads to Site Glass and
  Sample Tube on Primary Cooling Pump 50A, September 16, 2015
- CR-PLP-2015-03842, Oil Sample Obtained from the Upper Reservoir of PCP Motor 50B Was
  Found to be Darker in Color Than the Rest of the Samples Taken, September 16, 2015
- CR-PLP-2015-03848, Oil Samples for the P-50A PCP Motor and P-50C PCP Motor Were
  Taken With the Motors Running, September 16, 2015
- CR-PLP-2015-03864, Mode 3 Walkdown - CRD-36, September 17, 2015
- CR-PLP-2015-03876, SPI Reading for Rod 27 Was Found to be Reading 30 Prior to Rod
  Movements, September 17, 2015
- CR-PLP-2015-03882, Problem Identified on Spent Fuel Handling Machine During Dummy
  Fuel Bundle Moves, September 17, 2015
- CR-PLP-2015-03884, Mode 3 Walkdown - MV-CVC2296, September 16, 2015
- CR-PLP-2015-03885, Mode 3 Walkdown - MV-CVC2299, September 17, 2015
- CR-PLP-2015-03886, Mode 3 Walkdown - MV-ES3009, September 17, 2015
- CR-PLP-2015-03887, Mode 3 Walkdown - MV-ES3010A, September 17, 2015
- CR-PLP-2015-03889, Mode 3 Walkdown - MV-ES3109A, September 17, 2015
- CR-PLP-2015-03890, Mode 3 Walkdown - MV-ES3125A, September 17, 2015
- CR-PLP-2015-03895, Mode 3 Walkdown - CV-1015, September 16, 2015
- CR-PLP-2015-03896, Mode 3 Walkdown - MO-3011, September 17, 2015
- CR-PLP-2015-03897, Mode 3 Walkdown - CV-1013, September 16, 2015
- CR-PLP-2015-03899, Mode 3 Walkdown - MV-SFP505, September 16, 2015
- CR-PLP-2015-03902, Mode 3 Walkdown - MV-CRW113, September 16, 2015
- CR-PLP-2015-03903, Mode 3 Walkdown - MO-3068, September 17, 2015
- CR-PLP-2015-03904, Mode 3 Walkdown - MV-CRW112, September 16, 2015
- CR-PLP-2015-03906, Repair Workers Calculated Corrected Load Value for Input to the
  Battery Capacity Computer Test System Multiplied Correction to the Uncorrected Load vs the
  Procedural Step, September 27, 2015
- CR-PLP-2015-03915, Mode 3 Walkdown - CRD-40, September 18, 2015
- CR-PLP-2015-03916, Mode 3 Walkdown - CRD-17, September 18, 2015
- CR-PLP-2015-03920, Mode 3 Walkdown - T-72, September 18, 2015
- CR-PLP-2015-03921, Mode 3 Walkdown - MV-PC1068, September 18, 2015
                                              9
 
- CR-PLP-2015-03922, Mode 3 Walkdown - P-50B, September 18, 2015
- CR-PLP-2015-03923, mode 3 Walkdown - P-50A, September 18, 2015
- CR-PLP-2015-03926, Mode 3 Walkdown - CV-2202, September 18, 2015
- CR-PLP-2015-03927, Mode 3 Walkdown - CV-3038, September 18, 2015
- CR-PLP-2015-03931, Control Valve CV-0608 for the Moisture Separator Drain Tank Level
  Controls Did Not Stroke as Expected, September 18, 2015
- CR-PLP-2015-03933, Red Indication Lamp on Escape Airlock Door is Malfunctioning,
  September 18, 2015
- CR-PLP-2015-03945, Issues Identified During E-30B System Engineer Cooling Tower
  Walkdown, September 18, 2015
- CR-PLP-2015-03956, Mode 3 Walkdown of the PCS 590 Elevation, September 16, 2015
- CR-PLP-2015-03958, Operations Noted on Cameras That a Cable Was Routed Through the
  Recently Opened Equipment Hatch, September 18, 2015
- CR-PLP-2015-03960, Mode 3 Walkdown - MV-CC110, PCP P-50A, September 16, 2015
- CR-PLP-2015-03961, Mode 3 Walkdown - MV-CC112, PCP P50B, September 16, 2015
- CR-PLP-2015-03962, Mode 3 Walkdown - MV-CC196, September 16, 2015
- CR-PLP-2015-03964, Mode 3 Walkdown - P-50C, September 16, 2015
- CR-PLP-2015-03965, Mode 3 Walkdown - PCP P-50C, September 16, 2015
- CR-PLP-2015-03966, Mode 3 Walkdown - T-64C, September 16, 2015
- CR-PLP-2015-03967, Mode 3 Walkdown - RV-1041, PZR T-72, September 16, 2015
- CR-PLP-2015-03968, Mode 3 Walkdown - Pressurizer Shed on the 649 Elevation,
  September 16, 2015
- CR-PLP-2015-03969, Mode 3 Walkdown - P-50A, September 16, 2015
- CR-PLP-2015-03970, Alignments Between Work Group and Operations Were Not Precise,
  September 18, 2015
- CR-PLP-2015-03970, During Performance of RFL-D-3 Open Equipment Hatch, Alignments
  Between the Work Group and Operations Were Not Concise, September 18, 2015
- CR-PLP-2015-03971, Mode 3 Walkdown - P-50B, PCP, September 16, 2015
- CR-PLP-2015-03972, Mode 3 Walkdown - MV-PC1137, P-50C FE-0143A,
  September 16, 2015
- CR-PLP-2015-03973, Mode 3 Walkdown - T-64B, September 16, 2015
- CR-PLP-2015-03975, Mode 3 Walkdown - VHX-4, September 16, 2015
- CR-PLP-2015-03976, Mode 3 Walkdown - CRD-37, September 16, 2015
- CR-PLP-2015-03977, Mode 3 Walkdown - CRD-41, September 16, 2015
- CR-PLP-2015-03990, NDE Activities on L-1/:D-1, September 19, 2015
- CR-PLP-2015-04022, CV-3057 Solenoid Valve is Not Functioning Properly,
  September 20, 2015
- CR-PLP-2015-04023, Category 5 Air Leak on the Diaphragm of CV02111,
  September 20, 2015
- CR-PLP-2015-04050, Concentrate Boric Acid Storage Tank, T-53A is Above the Refueling
  Mode Admin Limit of 15,000-ppm, September 20, 2015
- CR-PLP-2015-04052, Mode 3 Walkdown - MO-3012, September 20, 2015
- CR-PLP-2015-04053, Mode 3 Walkdown - MO-3008, September 20, 2015
- CR-PLP-2015-04059, Mode 3 Walkdown - CRD-45, September 21, 2015
- CR-PLP-2015-04061, During Performance of RFL-D-8, CRDM Tool Access Flange Removal,
  Control Room SRO Approval Was Not Obtained, September 21, 2015
- CR-PLP-2015-04066, Drain Line for RV-0707 Was Found Broken During Valve Removal,
  September 21, 2015
- CR-PLP-2015-04070, Gaps Identified During Performance of the Turbine Stop Valve Cover
  Lift, September 21, 2015
                                            10
 
- CR-PLP-2015-04076, Signal Person and Crane Operator Were Not in Constant
  Communication During One Portion of the Turbine Stop Valve Cover Removal,
  September 21, 2015
- CR-PLP-2015-04079,CV-1059 Failed Drop Test, September 21, 2015
- CR-PLP-2015-04085, CV-2099, PCP Controlled Bleed Off Containment Isolation, Diagnostic
  Testing Performed With Out Communications to Operations Personnel, September 21, 2015
- CR-PLP-2015-04090, CV-0701 and CV-0703 Actuator Stems and Bushings are Worn and
  Require Replacement, No Parts Available, September 22, 2015
- CR-PLP-2015-04092, Drop Test Failed During As-Left Testing to Check CV-2099 PCP
  Controlled Bleed Off Containment Isolation, September 22, 2015
- CR-PLP-2015-04096, BTV-0610 Internal Inspection Reveals Damage to Disc Causing it to Lay
  Sideways, September 22, 2015
- CR-PLP-2015-04109, As Found Testing Results at the Upper End of its Acceptance Criteria,
  September 22, 2015
- CR-PLP-2015-04116, RV-0775 Failed to Lift With an Acceptance Range of 1265 to 1465 psi,
  September 22, 2015
- CR-PLP-2015-04123, One Worker on Scaffold Building Crew Was Not FME qualified,
  September 22, 2015
- CR-PLP-2015-04130, B Channel AFAS Power Supply Appears to be Bad,
  September 22, 2015
- CR-PLP-2015-04153, Loose Spindle Cap Identified During Offsite Testing and Repair of
  RV-0703, September 23, 2015
- CR-PLP-2015-04155, ICI Flange 2 Cannot be Removed Due to What Appears to be a Bent
  Connector, September 23, 2015
- CR-PLP-2015-04159, An FME Bladder Was Installed Into the Valve Body of Main Steam
  Governor Valve #1 CV-0570 Without Logging it Into the FEM Log Book, September 23, 2015
- CR-PLP-2015-04163, RO-32-11 Exceeds Administrative Limit for Second Outage In A Row,
  September 23, 2015
- CR-PLP-2015-04169, PCV-1492 Failed As-Left Testing and Cannot Be Repaired,
  September 23, 2015
- CR-PLP-2015-04172, RO-32-42 Exceeds Administrative Limit for Second Outage in a Row,
  September 23, 2015
- CR-PLP-2015-04178, There are No Lanyards Available to Workers In Containment,
  September 23, 2015
- CR-PLP-2015-04180, Maintenance Activities on RV-0721, September 23, 2015
- CR-PLP-2015-04187, A High Pressure Turbine Rigging Hardware Interference Was Identified
  While Rigging the HP Turbine K-1-HP Outer Cylinder for Removal, September 23, 2015
- CR-PLP-2015-04192, Magnetic Particle NDE Examinations on the L-1/LD-4 and Alloy 600
  Projects, September 23, 2015
- CR-PLP-2015-04203, CV-0780 Failed a Drop Test by Dropping 7.5 Percent of Pressure,
  September 24, 2015
- CR-PLP-2015-04204, CV-0781 Failed a Drop Test by Dropping Approximately 10.1 Percent of
  Pressure Over 5 Minutes, September 24, 2015
- CR-PLP-2015-04218, Unable to Establish Required Flow Rate for Final Bundle Flush During
  Draining and Filling the B Steam Generator, September 25, 2015
- CR-PLP-2015-04222, Foreign Material Exclusion is Not Meeting Requirements of EN-MA-118
  for the Main Turbine Project, September 24, 2015
- CR-PLP-2015-04240, CV-1057 Pressurizer Spray Valve From Loop 1B Failed its Drop Test,
  September 24, 2015
- CR-PLP-2015-04243, RP Technician Preparing to Enter Containment Was Not Signed in on
  Tagging, September 23, 2015
                                                11
 
- CR-PLP-2015-04246, P50A PCP Motor Lower Oil Reservoir Has Active Leak From Lower
  Bearing Reservoir Gasket, September 25, 2015
- CR-PLP-2015-04248, During Venting, CV-3065, Safety Injection Tank T-82B Vent Valve,
  Would Not Close, September 25, 2015
- CR-PLP-2015-04265, Errors Were Discovered Within EN-MA-119, Material Handling
  Program Attachment 9.10, September 25, 2016
- CR-PLP-2015-04277, Packing End Rings Ordered for the AOV Stem Were Not the Proper
  Size, September 25, 2015
- CR-PLP-2015-04278, Slowly Lowering Trend on T-3, CCW Surge Tank, September 25, 2015
- CR-PLP-2015-04281, Procedure HED-M-2 Requires Revision, September 25, 2015
- CR-PLP-2015-04282, Robot Disconnected From Tubesheet and Fell Into Bowl with No
  Damage and All Loose Parts Accounted for, September 25, 2015
- CR-PLP-2015-04283, Feedwater Pump P-1A to SG E-50B Has Pipe Wall Thickness Readings
  Below the Calculated Minimum, September 25, 2015
- CR-PLP-2015-04290, A Protected Equipment Boundary Was Found Not to be in Place in the
  Cable Spreading Room, September 25, 2015
- CR-PLP-2015-04292, ED-16, Charger #2 for Station Battery #2 Would Not Transfer to
  Equalize Charge Mode, September 25, 2015
- CR-PLP-2015-04293, Supplemental Workers Performing Main Feedwater Pump P-1A
  Maintenance and Inspection Activities Were Observed Using Less Than Adequate Human
  Performance Tools, September 25, 2015
- CR-PLP-2015-04295, Replacement Flange Found Not to be the Same as Old Flange During
  Attempted Replacement on MV-FW166 Valve, September 25, 2015
- CR-PLP-2015-04302, Steam Erosion Found at the North East Corner of the K-1-HP Horizontal
  Joint, September 25, 2015
- CR-PLP-2015-04319, As-Built Rigging Assembly Too Long for the HP Turbine Rotor,
  September 26, 2015
- CR-PLP-2015-04339, GCA Oversight Seeing Minor Administrative Issues With FME Log
  Keeping, September 26, 2015
- CR-PLP-2015-04343, Incorrect Size Sealtight Ordered For TE-0131A, September 26, 2015
- CR-PLP-2015-04357, Steam Leak Path Bypasses the Finger Seal, September 27, 2015
- CR-PLP-2015-04361, Permissive in Pelco Camera System Needs to be Removed Prior to
  Start of Refueling Outage, September 27, 2015
- CR-PLP-2015-04368, New Piston Seals Were Not Like for Like in Repair of CV-3057,
  September, 27, 2015
- CR-PLP-2015-04388, Wrong Packing Was Procured for CV-3001, September 27, 2015
- CR-PLP-2015-04391, As Found Condition of Valve Internals on CV-0780, S/G E-50B ASDV
  Are Poor, September 27, 2015
- CR-PLP-2015-04392, Small Leak From Conduit Box on P-50D, September 27, 2015
- CR-PLP-2015-04396, Replacement Actuator Base Plate Does Not Match the Piece Removed
  From VOP-3057, September 27, 2015
- CR-PLP-2015-04398, CV-2191 PCP Controlled Bleedoff Stop, Air Supply Regulator Failed,
  September 28, 2015
- CR-PLP-2015-04400, Installed Flanges Were 300# and Replacement Flanges of 150# During
  Performance of WO-00378591, September 28, 2015
- CR-PLP-2015-04404, Need to Determine Correct Replacement Part for Steam Element Due
  to Mis-Marking, September 28, 2015
- CR-PLP-2015-04410, Packing Adjustment on MV-CC713 Was Unsuccessful,
  September 28, 2015
- CR-PLP-2015-04421, Work Group Did Not Fully Barricade or Adequately Verify the Work Area
  for the Main Condensate Pump (P-2A) Lift, September 28, 2015
                                            12
 
- CR-PLP-2015-04434, Performed PCP P-50D Inspection of Lube Oil System and Oil Collection
  System, September 28, 2015
- CR-PLP-2015-04435, Performed PCP P-50A Inspection of Lube Oil System and Oil Collection
  System, September 28, 2015
- CR-PLP-2015-04436, Performed PCP P-50B Inspection of Lube Oil System and Oil Collection
  System, September 28, 2015
- CR-PLP-2015-04438, Flange Leakage Drain, Leaked by at 3 GPM to the Primary System
  Drain Tank with the Reactor Head Removed and the Cavity Flooded, September 29, 2015
- CR-PLP-2015-04462, PCV-3057B, T-58 Outlet CV-3057 Needs to Be Adjusted A/S REG
  Setpoint, September 29, 2015
- CR-PLP-2015-04473, Containment Sump Check Valve Inservice Testing, Step 5.2.13.3 Was
  Not Consistent With CK-ES3166 Data Review, September 29, 2015
- CR-PLP-2015-04481, New Style Kits for Replacement of Buses 1C, 1D, and 1B Feeder Cable
  Replacement Projects, September 29, 2015
- CR-PLP-2015-04488, MV-ES3184, JPSI P-66A Suction Manual Valve Was Difficult to Operate
  During a Tagout, September 29, 2015
- CR-PLP-2015-04505, ICI Locking Device Quick Disconnect on Flange Number 7
  Disconnected, September 28, 2015
- CR-PLP-2015-04507, Valve Bellow at Maximum Procedural Tolerance, Valve Shows Erratic
  Set Pressure Testing/Adjustment, and Valve Disc is Within Tolerance During as Left Testing
  on RV-1041, September 30, 2015
- CR-PLP-2015-04511, Atmospheric Steam Dump Solenoid SV-0779A & SV-0782A did Not
  Isolate When Expected During Functional Test, September 30, 2015
- CR-PLP-2015-04514, Two Air Compressors Providing Breathing Air to Steam Generator
  Project are Within 10 Feet of Two Diesel Powered Water Pumps, September 30, 2015
- CR-PLP-2015-04521, Pen Cap Observed Floating in Reactor Cavity, September 29, 2015
- CR-PLP-2015-04533, Threads on the Valve Actuator Stem Were Sheared During Seat Load
  Adjustment on CV-3038, September 30, 2015
- CR-PLP-2015-04534, CV-3065 Safety Injection Tank T-82B Vent Valve Internal Valve Stem
  Guide Bushing Had Significant Corrosion Build Up, September 29, 2015
- CR-PLP-2015-04544, Minor Defects Identified on the Disk for CV-0781 That Will be Removed
  Prior to Installation, October 1, 2015
- CR-PLP-2015-04547, Red and Green Lenses Mistakenly Swapped During Repair,
  October 1, 2015
- CR-PLP-2105-03919, Battery Charger #1 (ED-15) Would Not Go Into Equalize,
  September 18, 2015
- CR-PLP-2105-04297, Loads Being Flown Over Top of People, September 25, 2015
- DR-PLP-2015-04043, Air Leak Was Heard Around CV-3057, SIRW Tank Outlet Isolation
  Valve During Containment Sump Check Valve Inservice Test, September 20, 2015
- EN-DC-127, Control of Hot Work & Ignition Sources, Revision 15
- EN-DC-161, Control of Combustibles, Revision 13
- EN-DC-319, Boric Acid Corrosion Control Program, Revision 11
- EN-DC-359, Fire Risk Management During Non-Power Operations for NFPA 805 Plants,
  Revision 1
- EN-MA-118, Foreign Material Exclusion, Revision 10
- EN-MA-119, Material Handling Program, Revision 11
- EN-OM-123, Fatigue Management Program, Revision 11
- EN-OP-102, Protective and Caution Tagging, Revision 18
- EN-OP-116, Infrequently Performed Tests or Evolutions, Revision 12
- EN-OU-108, Shutdown Safety Management Program (SSMP), Revision 8
- EOP Supplement 1, Pressure Temperature Limit Curves, Revision 5
                                              13
 
- FHS-M-23, Movement of Heavy Loads in the Spent Fuel Pool Area, Revision 36
- FHS-M-24, Movement of Heavy Loads in the Containment Building Area, Revision 38
- FPIP-1, Fire Protection Plan, Organization and Responsibilities, Revision 24
- GOP-11, Refueling Operations and Fuel Handling, Revision 48
- GOP-14, Shutdown Cooling Operations, Revision 49
- MSM-M-72, Movement of Heavy Loads in Turbine Building, Revision 1
- OL-OLPIP-2014-0026, ORAT, Revision 1
- PO-2, PCS Heatup/Cooldown Operations, Revision 7
- Report P2298-14-001, 1R24 Non-Power Operations Outage Assessment, Revision 0
- RFL-D-13, Reactor Pressure Vessel Head Detensioning, Revision 6
- RFL-D-16, Reactor Vessel Closure Head Removal, Revision 17
- RFL-D-19, Removal of UGS From Reactor Vessel, Revision 6
- RFL-D-3, Open Equipment Hatch, Revision 8
- RFL-SG-2, S/G Primary Nozzle Dam Installation and Removal, Revision 10
- SOP-1A, Primary Coolant System, Revision 28
- SOP-1B, Primary Coolant System - Cooldown, Revision 19
- SOP-3, Safety Injection and Shutdown Cooling system, Revision 100
- SOP-6, Reactor Control System, Revision 35
- WI-PCS-M-06, NSSS Walkdown, Revision 5
- WO# 00381087-14, N-50; Reactor Head Removal
- WO# 425-483-01, L-1/LD-1 Lift Rig NDE Inspection PM
1R22 Surveillance Testing
- Admin Procedure No. 4.19, PCS Leak Rate Monitoring Program, Revision 6
- CR-PLP-2014-01047, Steps of RT-8C, Attachment 1 Were Inadvertently Signed Off,
  February 4, 2014
- CR-PLP-2014-01099, P-54C Would Not Start During RT-8C, February 5, 2014
- CR-PLP-2014-01108, Wavebook Failed to Capture Data in RE-139-1, February 6, 2014
- CR-PLP-2014-4463, PCS Leak Rate Greater than Three Standard Deviations From the Mean,
  September 12, 2014
- CR-PLP-2014-4861, T-82B Alarm Received for Lo Level Unexpectedly, October 7, 2014
- CR-PLP-2015-02974, As Founds Were Out of Tolerance During RI-99 for Left Channel
  Nuclear Instrumentation Calibrations, June 15, 2015
- CR-PLP-2015-02979, New Circuit Board Failed Upon Installation, June 16, 2015
- CR-PLP-2015-0323, Incorrect Data Reporting for PCS Primary-to-Secondary Leakage to
  INPO, January 20, 2015
- CR-PLP-2015-03565, Minor Leaks Identified on VC-10 During RT-202 Control Room HVAC
  Heat Removal Capability Test, August 28, 2015
- CR-PLP-2015-04043, CV-30057, SIRW Tank Outlet Isolation Valve Wouldnt Fully Open
  During RO-141, September 20, 2015
- CR-PLP-2015-1501, Rising Trend in D SIT, April 12, 2015
- CR-PLP-2015-1737, Trending of PCS Indicates Measured Seal Leakage Rate for P-55A, A
  Charging Pump, Experienced a Significant Increase, April 27, 2015
- CR-PLP-2015-2626, Primary System Drain Tank Has In-Leakage, June 24, 2015
- CR-PLP-2015-2683, PCS Leak Rate had Two of Last Three Consecutive Unidentified Leak
  Rates Greater Than 2 Standard Deviations From the Baseline Mean, June 27, 2015
- CR-PLP-2015-3337, PCS Unidentified Leak Rate Exceeded Action Level 1 Deviation From
  Baseline Mean, August 11, 2015
- CR-PLP-2015-3357, PCS Unidentified Leak Rate Exceeded Action Level 1 Deviation From
  Baseline Mean, August 12, 2015
                                              14
 
- DBD-2.09, Design Basis Document for Containment Building, Revision 4
- DRN-15-00774, SOP-30, Section 7.3.2, to Transfer from Safeguards/Station Power to Startup
  Power, Step D.7., References the Wrong Procedure Section
- DWO-1, Operators Daily/Weekly Items Modes 1, 2, 3, and 4, Revision 105
- EN-DC-161, Control of Combustibles, Revision 10
- EN-MA-134, Offline Motor Electrical Testing, Revision 5
- EN-MA-135, Online Motor Electrical Testing, Revision 5
- EN-MA-153, Use of VIPER or VOTES Infinity Air Operator Valve Diagnostics, Revision 4
- MSI-I-16, Nonintrusive Diagnostic Check Valve Test Procedure (Using Viper/UDS Platform),
  Revision 5
- Operations Daily Logs
- Operations Primary Coolant System Leak Rate Program Data Worksheet
- QO-16, Inservice Test Procedure - Containment Spray Pumps, Revision 35
- RE-139-2, Test Starting Time of Diesel Generator, Revision 12
- RI-99, Left Channel Nuclear Instrumentation Calibrations, Revision 14
- RO-105, Full Flow Test for SIT Check Valves and PCS Loop Check Valves, Revision 13
- RO-141, Containment Sump Check Valves Inservice Test, Revision 6
- RO-32-19, Local Leak Rate Test Procedure for Personnel Air Lock, Revision 9
- RT-202, Control Room HVAC Heat Removal Capability, Revision 15
- RT-8D, Engineered Safeguards System - Right Channel Basis Document, Revision 7
- SEP-CV-PLP-002, Check Valve Condition Monitoring and Inservice Testing Program,
  Revision 2
- SOP-30, Station Power, Revision 76
- SPS-E-20, Maintenance for 2400 Volt Siemens Switchgear, Revision 6
- WO #380495, RO-141; Containment Sump Check Valve Testing
- WO #419812, T-74; Operations to Troubleshoot Where In-Leakage is Coming From
- WO 419858; NI-1/3A; Source Range Reading Upscale with Detector Disconnected
- WO 52537390-01, RT-8D Engineered Safeguards Sys-Right Channel
- WO 52538538, EMA-1114 (P-54C) Perform Online Motor Testing
- WO 52544830, CK-ES3131 & CK-ES3132, Nonintrusive Check Valve Testing
- WO 52558713, EEQ-EMA-1114, Containment Spray P-54C Motor
- WO 52561654-01, RO-105 - Full Flow Test for SIT Check Valves
- WO 52623508, QO-16C - P-54C, ISI Test Procedure, Containment Spray
1EP6 Drill Evaluation
- AOP-35, Loss of Service Water, Revision 0
- AOP-38, Acts of Nature, Revision 3
- CR-PLP-2015-03549, Sentinel Radiation Work Permit Log-In Station Did Not Function
  Normally During EP Drill, August 26, 2015
- CR-PLP-2015-03554, Field Monitoring Team 2 Did Not Placekeep the Steps They Followed
  While Performing Their Drill Duties, August 26, 2015
- CR-PLP-2015-03559, Four Emergency Preparedness Drill Participants Were Observed
  Without Their Dosimetry of Legal Record During the EP Drill, August 27, 2015
- CR-PLP-2015-03567, Problems Encountered with Radio Communications
- CR-PLP-2015-03568, Cell Phones in Field Monitoring Team Vans had Dead Batteries During
  Third Quarter 2015 Drill, August 28, 2015
- EI-6.13, Protective Action Recommendations for Offsite Populations, Revision 24
- Emergency Action Level Technical Basis, Revision 7
- EOP Supplement 2, PCS Cooldown Strategy, Revision 8
- EOP-1.0, Standard Post-Trip Actions, Revision 16
                                              15
 
- EOP-5.0 Steam Generator Tube Rupture Recovery, Revision 18
- EOP-9.0, Functional Recovery Procedure, Revision 22
- Palisades Third Quarter Emergency Planning Drill, August 26, 2015
- SEP Supplement 1, EAL Wall Charts, Revision 2
2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
- 2013 Annual Radioactive Effluent and Waste Disposal Report, April 30, 2014
- 2014 Annual Radioactive Effluent and Waste Disposal Report, April 27, 2015
- CH 6.20, Radioactive Effluent Operating Procedure, Revision 3
- CH 6.21, Radioactive Liquid Release, Revision 8
- CH 6.41, Land Use Census, Revision 6
- COP-35, Groundwater Monitoring Program, Revision 5
- CR-PLP-2015-03000, RR-10-003 RETS Basis Document is Not Consistent With ODCM
  Methodology, July 16, 2015
- CR-PLP-2015-2972, Failure to Incorporate Land Use Census Data Into Required Dose Rate
  Calculations for Nearest Resident, July 15, 2015
- DWR-10, Stack Effluent Sampling and Calculations, Revision 41
- EN-CY-111, Radiological Groundwater Monitoring Program, Revision 6
- LO-PLPLO-2014-00153, 2015 RET PRE-NRC Assessment, May 26, 2015
- MR-35, Turbine Sump Collection and Calculation, Revision 16
- MR-36, Service Water Collection and Calculation, Revision 17
- ODCM, Appendix A, Relocated Technical Specifications per NRC Generic Letter 89-01 (TAC
  NO 75060), Revision 18
- ODCM, Revision 26
- REMP RETS Basis Document, Number R10-002, Demonstrating Compliance with 40 CFR,
  Part 190 Dose Limits, March 28, 2010
- RETS Basis Document, Number R09-001, Liquid Effluent Release Concentration Limit for
  Dose Calculations, November 29, 2009
- RETS Basis Document, Number R10-001, T-91 Two-Tank Volume Recirculation Time Prior to
  Sampling Justification, March 15, 2010
- RIA/RIA System Walkdown Checklist, June 30, 2015
- RIA/RIA System Walkdown Checklist, March 30, 2015
- RR 10-03, Predetermined Radioactive Liquid Releases Criteria, Revision 0
- RT-85C, Fuel Handling Area Ventilation System Filter Testing, Revision 12
- RT-85D, Control Room Emergency Ventilation Filtration Testing, Revision 16
- System Health Report, RIA-Radiation Monitoring System, Period Q1-2015
- System Health Report, RIA-Radiation Monitoring System, Period Q4-2014
- WO 52470171 01, RT-85C-SFP Ventilation HEPA & Charcoal Testing
4OA1 Performance Indicator Verification
- CR-PLP-2015-03834, NRC Resident Identified Three Errors in Data Validation Packages for
  ROPS PCS Identified Leakrate Performance Indicator, September 16, 2015
- EN-LI-114; Performance Indicator Process; Revision 6
- NRC Performance Indicator Data; Reactor Coolant System Leakage; Fourth Quarter 2014
  Through Second Quarter 2015
- NRC Performance Indicator Technique/Data Sheet, Mitigating Systems Performance Indicator,
  High Pressure Injection (MS07), July 2014 Through June 2015
- NRC Performance Indicator Technique/Data Sheet, Mitigating Systems Performance Indicator,
  Residual Heat Removal (MS09), July 2014 Through June 2015
                                                16
 
- Operations Daily Logs
- Operations Primary Coolant System Leak Rate Program Data Worksheet
- Palisades MSPI Basis Document, December 21, 2011
4OA3 Follow-up of Events and Notices of Enforcement Discretion
- CR-PLP-2015-02928, Chemical Toilet Spill During Heavy Rain, July 13, 2015
- EN-51224, Event Notification Worksheet for Chemical Toilet Spill, July 13, 2015
- MSDS-Material Safety Data Sheet for Chemical Toilet, March 12, 2013
4OA5 Other Activities
- CR-PLP-2015-3403, Inconsistency in Meeting Intent of EN-NS-300 for Non-Palisades Security
  Force Members Physical Agility Tests, August 15, 2015
- EN-NS-300, Security Training Program, Revision 5
- EN-NS-304, Security On-the-Job Training, Task Performance Evaluation, and Training
  Exemptions, Revision 6
- EN-OM-123, Fatigue Management Program, Revision 11
- Palisades Staffing Contingency Plan
                                              17
 
                          LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations
ADAMS  Agencywide Documents Access Management System
CAP    Corrective Action Program
CCW    Component Cooling Water
CR    Condition Report
ECCS  Emergency Core Cooling System
IMC    Inspection Manual Chapter
IN    Information Notice
IP    Inspection Procedure
IR    Inspection Report
LIT    Level Indicating Transmitter
MSPI  Mitigating Systems Performance Index
NEI    Nuclear Energy Institute
NCV    Non-Cited Violation
NRC    U.S. Nuclear Regulatory Commission
ODCM  Offsite Dose Calculation Manual
ORAT  Outage Risk Assessment
PARS  Publicly Available Records System
PCP    Primary Coolant Pump
PCS    Primary Coolant System
PI    Performance Indicator
RAS    Recirculation Actuation Signal
REMP  Radiological Environmental Monitoring Program
RETS  Radiological Effluent Technical Specification
RFO    Refueling Outage
SSC    Structures, Systems, and Components
TS    Technical Specification
UFSAR  Updated Final Safety Analysis Report
WO    Work Order
                                        18
 
 
 
    Publicly Available                          Non-Publicly Available                              Sensitive                  Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE              RIII                                RIII                            RIII                              RIII
NAME                EDuncan:mp
DATE                10/30/15
}}

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