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{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES  
                              NUCLEAR REGULATORY COMMISSION
NUCLEAR REGULATORY COMMISSION  
                                              REGION III
REGION III  
                                  2443 WARRENVILLE ROAD, SUITE 210
2443 WARRENVILLE ROAD, SUITE 210  
                                          LISLE, IL 60532-4352
LISLE, IL 60532-4352  
                                            February 9, 2009
Mr. Christopher J. Schwarz
February 9, 2009  
Site Vice President
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
Mr. Christopher J. Schwarz  
27780 Blue Star Memorial Highway
Site Vice President  
Covert, MI 49043-9530
Entergy Nuclear Operations, Inc.  
SUBJECT:         PALISADES NUCLEAR PLANT INTEGRATED INSPECTION
Palisades Nuclear Plant  
                REPORT 05000255/2008-005
27780 Blue Star Memorial Highway  
Dear Mr. Schwarz:
Covert, MI 49043-9530  
On December 31, 2008, the U. S. Nuclear Regulatory Commission (NRC) completed an
SUBJECT:  
inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection
PALISADES NUCLEAR PLANT INTEGRATED INSPECTION  
findings, which were discussed on January 22, 2009, with members of your staff.
REPORT 05000255/2008-005  
The inspection examined activities conducted under your license as they relate to safety and
Dear Mr. Schwarz:  
compliance with the Commissions rules and regulations and with the conditions of your license.
On December 31, 2008, the U. S. Nuclear Regulatory Commission (NRC) completed an  
The inspectors reviewed selected procedures and records, observed activities, and interviewed
inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection  
personnel.
findings, which were discussed on January 22, 2009, with members of your staff.  
Based on the results of this inspection, two NRC-identified violations of very low safety
The inspection examined activities conducted under your license as they relate to safety and  
significance were identified. The findings involved violations of NRC requirements. However,
compliance with the Commissions rules and regulations and with the conditions of your license.
because of their very low safety significance, and because the issues were entered into your
The inspectors reviewed selected procedures and records, observed activities, and interviewed  
corrective action program, the NRC is treating the issues as Non-Cited Violations (NCVs)in
personnel.  
accordance with Section VI.A.1 of the NRC Enforcement Policy. Additionally, one licensee
Based on the results of this inspection, two NRC-identified violations of very low safety  
identified violation is listed in Section 4OA7 of this report.
significance were identified. The findings involved violations of NRC requirements. However,  
If you contest the subject or severity of an NCV, you should provide a response within
because of their very low safety significance, and because the issues were entered into your  
30 days of the date of this inspection report, with the basis for your denial, to the
corrective action program, the NRC is treating the issues as Non-Cited Violations (NCVs)in  
U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,
accordance with Section VI.A.1 of the NRC Enforcement Policy. Additionally, one licensee  
DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory
identified violation is listed in Section 4OA7 of this report.  
Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the
If you contest the subject or severity of an NCV, you should provide a response within  
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC
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.
20555-0001; and the Resident Inspector Office at the Palisades Nuclear Plant.


C. Schwarz                                     -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
C. Schwarz  
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html
(the Public Electronic Reading Room).
                                              Sincerely,
-2-  
                                              /RA/
                                              John B. Giessner, Chief
                                              Branch 4
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its  
                                              Division of Reactor Projects
enclosure will be available electronically for public inspection in the NRC Public Document  
Docket No. 50-255
Room or from the Publicly Available Records (PARS) component of NRC's document system  
License No. DPR-20
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html  
Enclosure:     Inspection Report 05000255/2008-005
(the Public Electronic Reading Room).  
                  w/Attachment: Supplemental Information
cc w/encl:     Senior Vice President
              Vice President Oversight
              Senior Manager, Nuclear Safety & Licensing
              Senior Vice President and COO
              Assistant General Counsel
              Manager, Licensing
Sincerely,  
              W. DiProfio
              W. Russell
              G. Randolph
              Supervisor, Covert Township
/RA/  
              Office of the Governor
John B. Giessner, Chief  
              T. Strong, State Liaison Officer
Branch 4  
              Michigan Department of Environmental Quality
Division of Reactor Projects  
              Michigan Office of the Attorney General
Docket No. 50-255  
License No. DPR-20  
Enclosure:  
Inspection Report 05000255/2008-005  
  w/Attachment: Supplemental Information  
cc w/encl:  
Senior Vice President  
Vice President Oversight  
Senior Manager, Nuclear Safety & Licensing  
Senior Vice President and COO  
Assistant General Counsel  
Manager, Licensing  
W. DiProfio  
W. Russell  
G. Randolph  
Supervisor, Covert Township  
Office of the Governor  
T. Strong, State Liaison Officer  
Michigan Department of Environmental Quality  
Michigan Office of the Attorney General  


C. Schwarz                                                                 -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
C. Schwarz  
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html
(the Public Electronic Reading Room).
                                                                          Sincerely,
-2-  
                                                                          John B. Giessner, Chief
                                                                          Branch 4
                                                                          Division of Reactor Projects
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its  
Docket No. 50-255
enclosure will be available electronically for public inspection in the NRC Public Document  
License No. DPR-20
Room or from the Publicly Available Records (PARS) component of NRC's document system  
Enclosure:               Inspection Report 05000255/2008-005
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html  
                            w/Attachment: Supplemental Information
(the Public Electronic Reading Room).  
cc w/encl:               Senior Vice President
                          Vice President Oversight
                          Senior Manager, Nuclear Safety & Licensing
                          Senior Vice President and COO
                          Assistant General Counsel
                          Manager, Licensing
                          W. DiProfio
Sincerely,  
                          W. Russell
                          G. Randolph
                          Supervisor, Covert Township
                          Office of the Governor
                          T. Strong, State Liaison Officer
John B. Giessner, Chief  
                          Michigan Department of Environmental Quality
Branch 4  
                          Michigan Office of the Attorney General
Division of Reactor Projects  
DOCUMENT NAME: G:\1-Secy\1-Work In Progress\Pali 2008-005.doc
Docket No. 50-255  
  Publicly Available                         Non-Publicly Available                   Sensitive             Non-Sensitive
License No. DPR-20  
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
Enclosure:  
OFFICE                 RIII                       RIII
Inspection Report 05000255/2008-005  
  NAME                   RLerch:dtp                 JGiessner
  w/Attachment: Supplemental Information  
  DATE                   02/06/09                   02/06/09
cc w/encl:  
                                                          OFFICIAL RECORD COPY
Senior Vice President  
Vice President Oversight  
Senior Manager, Nuclear Safety & Licensing  
Senior Vice President and COO  
Assistant General Counsel  
Manager, Licensing  
W. DiProfio  
W. Russell  
G. Randolph  
Supervisor, Covert Township  
Office of the Governor  
T. Strong, State Liaison Officer  
Michigan Department of Environmental Quality  
Michigan Office of the Attorney General  
DOCUMENT NAME:   G:\\1-Secy\\1-Work In Progress\\Pali 2008-005.doc
  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  
 
   
NAME  
RLerch:dtp  
JGiessner  
   
DATE  
02/06/09  
02/06/09  
OFFICIAL RECORD COPY  


Letter to C. Schwarz from J. Giessner dated February 9, 2009
SUBJECT:       PALISADES NUCLEAR PLANT INTEGRATED INSPECTION
Letter to C. Schwarz from J. Giessner dated February 9, 2009  
              REPORT 05000255/2008-005
SUBJECT:  
DISTRIBUTION:
PALISADES NUCLEAR PLANT INTEGRATED INSPECTION  
Tamara Bloomer
REPORT 05000255/2008-005  
RidsNrrPMPalisades
DISTRIBUTION:  
RidsNrrDorlLpl3-1
Tamara Bloomer  
RidsNrrDirsIrib Resource
RidsNrrPMPalisades  
Mark Satorius
RidsNrrDorlLpl3-1  
Kenneth Obrien
RidsNrrDirsIrib Resource  
Jared Heck
Mark Satorius  
Carole Ariano
Kenneth Obrien  
Linda Linn
Jared Heck  
Cynthia Pederson
Carole Ariano  
DRPIII
Linda Linn  
DRSIII
Cynthia Pederson  
Patricia Buckley
DRPIII  
Tammy Tomczak
DRSIII  
ROPreports@nrc.gov
Patricia Buckley  
Tammy Tomczak  
ROPreports@nrc.gov  


          U.S. NUCLEAR REGULATORY COMMISSION
                          REGION III
Enclosure
Docket No:         50-255
U.S. NUCLEAR REGULATORY COMMISSION  
License No:         DPR-20
REGION III  
Report No:         05000255/2008-005
Docket No:  
Licensee:           Entergy Nuclear Operations, Inc.
50-255  
Facility:           Palisades Nuclear Plant
License No:  
Location:           Covert, MI
DPR-20  
Dates:             October 1, 2008, to December 31, 2008
Report No:  
Inspectors:         J. Ellegood, Senior Resident Inspector
05000255/2008-005  
                    T. Taylor, Resident Inspector
Licensee:  
                    J. Cassidy, Senior Health Physicist
Entergy Nuclear Operations, Inc.  
                    A. Dahbur, Senior Reactor Inspector
Facility:  
                    R. Jickling, Senior Emergency Preparedness Inspector
Palisades Nuclear Plant  
                    R. Winter, Reactor Inspector
Location:  
Approved by:       J. Giessner, Chief
Covert, MI  
                    Branch 4
Dates:  
                    Division of Reactor Projects
October 1, 2008, to December 31, 2008  
                                                                  Enclosure
Inspectors:  
J. Ellegood, Senior Resident Inspector  
T. Taylor, Resident Inspector  
J. Cassidy, Senior Health Physicist  
A. Dahbur, Senior Reactor Inspector  
R. Jickling, Senior Emergency Preparedness Inspector  
R. Winter, Reactor Inspector  
Approved by:  
J. Giessner, Chief  
Branch 4  
Division of Reactor Projects


                                        TABLE OF CONTENTS
SUMMARY OF FINDINGS ......................................................................................................... 1
Enclosure
REPORT DETAILS..................................................................................................................... 3
TABLE OF CONTENTS  
Summary of Plant Status......................................................................................................... 3
SUMMARY OF FINDINGS ......................................................................................................... 1  
  1.   REACTOR SAFETY ..................................................................................................... 3
REPORT DETAILS ..................................................................................................................... 3  
      1R04   Equipment Alignment (71111.04) ....................................................................... 3
Summary of Plant Status......................................................................................................... 3  
      1R05   Fire Protection (71111.05) ................................................................................. 4
1.  
      1R11   Licensed Operator Requalification Program (71111.11)..................................... 5
REACTOR SAFETY ..................................................................................................... 3  
      1R12   Maintenance Effectiveness (71111.12) .............................................................. 5
1R04  
      1R13   Maintenance Risk Assessments and Emergent Work Control (71111.13).......... 6
Equipment Alignment (71111.04) ....................................................................... 3  
      1R15   Operability Evaluations (71111.15) .................................................................... 6
1R05  
      1R18   Plant Modifications (71111.18) ........................................................................... 8
Fire Protection (71111.05) ................................................................................. 4  
      1R19   Post-Maintenance Testing (71111.19) ............................................................... 9
1R11  
      1R22   Surveillance Testing (71111.22)....................................................................... 10
Licensed Operator Requalification Program (71111.11) ..................................... 5  
      1EP4   Emergency Action Level and Emergency Plan Changes (71114.04) ............... 11
1R12  
      1EP6   Drill Evaluation (71114.06) ............................................................................... 11
Maintenance Effectiveness (71111.12) .............................................................. 5  
  2.   RADIATION SAFETY ................................................................................................. 12
1R13
      2OS1 Access Control to Radiologically Significant Areas (71121.01) ........................ 12
Maintenance Risk Assessments and Emergent Work Control (71111.13) .......... 6  
  4.   OTHER ACTIVITIES .................................................................................................. 16
1R15  
      4OA1 Performance Indicator Verification (71151) ...................................................... 16
Operability Evaluations (71111.15) .................................................................... 6  
      4OA2 Identification and Resolution of Problems (71152) ........................................... 17
1R18  
      4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153) .............. 22
Plant Modifications (71111.18) ........................................................................... 8  
      4OA5 Other Activities................................................................................................. 24
1R19  
      4OA6 Management Meetings .................................................................................... 25
Post-Maintenance Testing (71111.19) ............................................................... 9  
      4OA7 Licensee-Identified Violations .......................................................................... 26
1R22  
SUPPLEMENTAL iNFORMATION ............................................................................................. 1
Surveillance Testing (71111.22)....................................................................... 10  
KEY POINTS OF CONTACT .................................................................................................. 1
1EP4  
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED ....................................................... 2
Emergency Action Level and Emergency Plan Changes (71114.04) ............... 11  
LIST OF DOCUMENTS REVIEWED ....................................................................................... 3
1EP6  
LIST OF ACRONYMS USED .................................................................................................. 8
Drill Evaluation (71114.06) ............................................................................... 11  
                                                                                                                      Enclosure
2.  
RADIATION SAFETY ................................................................................................. 12  
2OS1  
Access Control to Radiologically Significant Areas (71121.01) ........................ 12  
4.  
OTHER ACTIVITIES .................................................................................................. 16  
4OA1  
Performance Indicator Verification (71151) ...................................................... 16  
4OA2  
Identification and Resolution of Problems (71152) ........................................... 17  
4OA3
Follow-Up of Events and Notices of Enforcement Discretion (71153) .............. 22  
4OA5  
Other Activities ................................................................................................. 24  
4OA6
Management Meetings .................................................................................... 25  
4OA7  
Licensee-Identified Violations .......................................................................... 26  
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 .................................................................................................. 8  


                                        SUMMARY OF FINDINGS
IR 05000255/2008-005; 10/01/2008 - 12/31/2008; Palisades Power Plant; Integrated Inspection
Report; Operability Evaluations; Follow-up of Events.
1
This report covers a 3-month period of inspection by resident inspectors and announced
Enclosure
baseline inspections by regional inspectors. Two Green findings were identified by the
SUMMARY OF FINDINGS  
inspectors. The findings were considered Non-Cited Violations of NRC regulations. The
IR 05000255/2008-005; 10/01/2008 - 12/31/2008; Palisades Power Plant; Integrated Inspection  
significance of most findings is indicated by their color (Green, White, Yellow, Red) using
Report; Operability Evaluations; Follow-up of Events.  
Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings
This report covers a 3-month period of inspection by resident inspectors and announced  
for which the SDP does not apply may be Green or be assigned a severity level after NRC
baseline inspections by regional inspectors. Two Green findings were identified by the  
management review. The NRCs program for overseeing the safe operation of commercial
inspectors. The findings were considered Non-Cited Violations of NRC regulations. The  
nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4,
significance of most findings is indicated by their color (Green, White, Yellow, Red) using  
dated December 2006.
Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings  
A.     NRC-Identified and Self-Revealed Findings
for which the SDP does not apply may be Green or be assigned a severity level after NRC  
        Cornerstone: Mitigating Systems
management review. The NRCs program for overseeing the safe operation of commercial  
    *   Green. The inspectors identified a finding of very low safety significance (Green) and
nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4,  
        an associated NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, for
dated December 2006.  
        the inadequate testing of the heat removal capacity of the Control Room Heating,
A.  
        Ventilation, and Air Conditioning (CR HVAC) system. Specifically, the licensee isolated
NRC-Identified and Self-Revealed Findings  
        refrigerant hot gas bypass flow during the test which increased the heat removal
Cornerstone: Mitigating Systems  
        capability of the chiller. The licensee entered the issue into their corrective action
*  
        program as condition report (CR) PLP-2008-3993 and re-performed portions of the
Green. The inspectors identified a finding of very low safety significance (Green) and  
        engineering basis calculation to demonstrate margin to account for the hot gas bypass
an associated NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, for  
        flow.
the inadequate testing of the heat removal capacity of the Control Room Heating,  
        The finding is more than minor because, in accordance with IMC 0612, Appendix E,
Ventilation, and Air Conditioning (CR HVAC) system. Specifically, the licensee isolated  
        Examples of Minor Issues, the inspectors determined that the finding was similar to
refrigerant hot gas bypass flow during the test which increased the heat removal  
        Example E.3.j and resulted in a reasonable doubt as to the operability of the chiller.
capability of the chiller. The licensee entered the issue into their corrective action  
        Based upon a review of the licensees revised calculation for the CR HVAC system
program as condition report (CR) PLP-2008-3993 and re-performed portions of the  
        acceptance criteria and the Technical Specification (TS) requirements, the finding
engineering basis calculation to demonstrate margin to account for the hot gas bypass  
        screens as very low safety significance (Green) using the Phase 1 SDP worksheets.
flow.  
        The inspectors determined that the finding included a cross-cutting aspect in the area of
The finding is more than minor because, in accordance with IMC 0612, Appendix E,  
        human performance, resources, and complete and accurate procedures (H.2(c))
Examples of Minor Issues, the inspectors determined that the finding was similar to  
        because the surveillance procedure unacceptably preconditioned the chiller. (1R15)
Example E.3.j and resulted in a reasonable doubt as to the operability of the chiller.
    *   Green. A self-revealed finding of very low safety significance (Green) and an associated
Based upon a review of the licensees revised calculation for the CR HVAC system  
        NCV for failure to comply with TS 3.8.1 requirements when metal fragments were found
acceptance criteria and the Technical Specification (TS) requirements, the finding  
        in the valve assembly area of the 1-2 Emergency Diesel Generator (EDG) cylinder 2L.
screens as very low safety significance (Green) using the Phase 1 SDP worksheets.
        The source of the fragments was a failed spring lock for one of the exhaust valves. This
The inspectors determined that the finding included a cross-cutting aspect in the area of  
        resulted in the EDG being inoperable for a period greater than allowed by TSs.
human performance, resources, and complete and accurate procedures (H.2(c))  
        Subsequently, the licensee inspected the remaining spring locks on the 1-2 EDG.
because the surveillance procedure unacceptably preconditioned the chiller. (1R15)
        Inspections of the 1-1 EDG spring locks are planned.
*  
        The finding is more than minor because it affected the equipment performance attribute
Green. A self-revealed finding of very low safety significance (Green) and an associated  
        of the mitigating system cornerstone and adversely affected the objective of ensuring the
NCV for failure to comply with TS 3.8.1 requirements when metal fragments were found  
        availability, reliability, and capability of systems that respond to initiating events to
in the valve assembly area of the 1-2 Emergency Diesel Generator (EDG) cylinder 2L.
        prevent undesirable consequences. A failure analysis performed by the vendor in
The source of the fragments was a failed spring lock for one of the exhaust valves. This  
                                                          1                                  Enclosure
resulted in the EDG being inoperable for a period greater than allowed by TSs.
Subsequently, the licensee inspected the remaining spring locks on the 1-2 EDG.
Inspections of the 1-1 EDG spring locks are planned.  
The finding is more than minor because it affected the equipment performance attribute  
of the mitigating system cornerstone and adversely affected the objective of ensuring the  
availability, reliability, and capability of systems that respond to initiating events to  
prevent undesirable consequences. A failure analysis performed by the vendor in  


  conjunction with an apparent cause analysis by the licensee led to an evaluation that the
  diesel could perform its safety function for at least the 24-hour Probabilistic Risk
  Assessment mission time. In consultation with the regional Senior Risk Analyst, the
2
  finding screens as Green using the significance determination process phase 1. No
Enclosure
  cross-cutting aspect was assigned because this issue is not indicative of current plant
conjunction with an apparent cause analysis by the licensee led to an evaluation that the  
  performance. (4OA3)
diesel could perform its safety function for at least the 24-hour Probabilistic Risk  
B. Licensee-Identified Violations
Assessment mission time. In consultation with the regional Senior Risk Analyst, the  
  A violation of very low safety significance that was identified by the licensee has been
finding screens as Green using the significance determination process phase 1. No  
  reviewed by inspectors. Corrective actions planned or taken by the licensee have been
cross-cutting aspect was assigned because this issue is not indicative of current plant  
  entered into the licensees corrective action program. This violation and corrective
performance. (4OA3)  
  action tracking numbers are listed in Section 4OA7 of this report.
B.  
                                                2                                    Enclosure
Licensee-Identified Violations  
A violation of very low safety significance that was identified by the licensee has been  
reviewed by inspectors. Corrective actions planned or taken by the licensee have been  
entered into the licensees corrective action program. This violation and corrective  
action tracking numbers are listed in Section 4OA7 of this report.  


                                            REPORT DETAILS
Summary of Plant Status
Throughout the inspection period, the plant operated at or near 100 percent power.
3
1.   REACTOR SAFETY
Enclosure
1R01 Adverse Weather Protection (71111.01)
REPORT DETAILS  
  a. Inspection Scope
Summary of Plant Status  
      Since extreme cold conditions were forecast in the vicinity of the facility for
Throughout the inspection period, the plant operated at or near 100 percent power.  
      December 2008, the inspectors reviewed the licensees overall preparations/protection
1.  
      for the expected weather conditions. On December 17, the inspectors walked down the
REACTOR SAFETY  
      condensate storage tanks and safety injection and refueling water tank system(s)
1R01 Adverse Weather Protection (71111.01)  
      because their safety-related functions could be affected or required as a result of the
a.  
      extreme cold conditions forecast for the facility. The inspectors observed insulation,
Inspection Scope  
      heat trace circuits, and weatherized enclosures to ensure operability of affected
Since extreme cold conditions were forecast in the vicinity of the facility for  
      systems. The inspectors reviewed licensee procedures. Specific documents reviewed
December 2008, the inspectors reviewed the licensees overall preparations/protection  
      during this inspection are listed in the Attachment.
for the expected weather conditions. On December 17, the inspectors walked down the  
      This inspection constituted one readiness for impending adverse weather condition
condensate storage tanks and safety injection and refueling water tank system(s)  
      sample as defined in IP 71111.01-05.
because their safety-related functions could be affected or required as a result of the  
  b. Findings
extreme cold conditions forecast for the facility. The inspectors observed insulation,  
      No findings of significance were identified.
heat trace circuits, and weatherized enclosures to ensure operability of affected  
1R04 Equipment Alignment (71111.04)
systems. The inspectors reviewed licensee procedures. Specific documents reviewed  
  a. Inspection Scope
during this inspection are listed in the Attachment.  
      The inspectors performed partial system walkdowns of the following risk-significant
This inspection constituted one readiness for impending adverse weather condition  
      systems:
sample as defined in IP 71111.01-05.  
      *       High Pressure Safety Injection (HPSI)-A with HPSI-B out of service for
b.  
              maintenance;
Findings  
      *       Service Water System with Service Water Pump C out of service for
No findings of significance were identified.  
              maintenance;
1R04 Equipment Alignment (71111.04)  
      *       HPSI-B with HPSI-A out of service for maintenance;
a.  
      *       1-2 EDG with the 1-1 EDG out of service for maintenance.
Inspection Scope  
      The inspectors selected these systems based on their risk significance relative to the
The inspectors performed partial system walkdowns of the following risk-significant  
      reactor safety cornerstones at the time they were inspected. The inspectors attempted
systems:  
      to identify any discrepancies that could impact the function of the system, and, therefore,
*  
      potentially increase risk. The inspectors reviewed applicable operating procedures,
High Pressure Safety Injection (HPSI)-A with HPSI-B out of service for  
      system diagrams, Updated Final Safety Analysis Report (UFSAR), Technical
maintenance;  
      Specification (TS) requirements, outstanding work orders, condition reports, and the
*  
      impact of ongoing work activities on redundant trains of equipment in order to identify
Service Water System with Service Water Pump C out of service for  
      conditions that could have rendered the systems incapable of performing their intended
maintenance;  
                                                    3                                Enclosure
*  
HPSI-B with HPSI-A out of service for maintenance;  
*  
1-2 EDG with the 1-1 EDG out of service for maintenance.  
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, Updated Final Safety Analysis Report (UFSAR), Technical  
Specification (TS) requirements, outstanding work orders, condition reports, 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
4
    parameters of equipment to verify that there were no obvious deficiencies. The
Enclosure
    inspectors also verified that the licensee had properly identified and resolved equipment
functions. The inspectors also walked down accessible portions of the systems to verify  
    alignment problems that could cause initiating events or impact the capability of
system components and support equipment were aligned correctly and operable. The  
    mitigating systems or barriers and entered them into the Corrective Action program
inspectors examined the material condition of the components and observed operating  
    (CAP) with the appropriate significance characterization. Documents reviewed are listed
parameters of equipment to verify that there were no obvious deficiencies. The  
    in the Attachment.
inspectors also verified that the licensee had properly identified and resolved equipment  
    These activities constituted four partial system walkdown samples as defined in
alignment problems that could cause initiating events or impact the capability of  
    IP 71111.04-05.
mitigating systems or barriers and entered them into the Corrective Action program  
  b. Findings
(CAP) with the appropriate significance characterization. Documents reviewed are listed  
    No findings of significance were identified.
in the Attachment.  
1R05 Fire Protection (71111.05)
These activities constituted four partial system walkdown samples as defined in  
  a. Inspection Scope
IP 71111.04-05.  
    The inspectors conducted fire protection walkdowns which were focused on availability,
b.  
    accessibility, and the condition of firefighting equipment in the following risk-significant
Findings  
    plant areas:
No findings of significance were identified.  
    *       Technical Support Center;
1R05 Fire Protection (71111.05)  
    *       1-D Switchgear Room (during/following emergent Post Maintenance Testing for
a.  
              Auxiliary Feed Water (AFW) -C power supply);
Inspection Scope  
    *       Component Cooling Water Room;
The inspectors conducted fire protection walkdowns which were focused on availability,  
    *       North and Southwest Penetration Rooms;
accessibility, and the condition of firefighting equipment in the following risk-significant  
    *       Charging Pumps Room.
plant areas:  
    The inspectors reviewed areas to assess if the licensee had implemented a fire
*  
    protection program that adequately controlled combustibles and ignition sources within
Technical Support Center;  
    the plant, effectively maintained fire detection and suppression capability, maintained
*  
    passive fire protection features in good material condition, and had implemented
1-D Switchgear Room (during/following emergent Post Maintenance Testing for  
    adequate compensatory measures for out of service, degraded, or inoperable fire
Auxiliary Feed Water (AFW) -C power supply);  
    protection equipment, systems, or features in accordance with the licensees fire plan.
*  
    The inspectors selected fire areas based on their overall contribution to internal fire risk
Component Cooling Water Room;  
    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
North and Southwest Penetration Rooms;  
    plant transient, or their impact on the plants ability to respond to a security event. Using
*  
    the documents listed in the Attachment, the inspectors verified that fire hoses and
Charging Pumps Room.  
    extinguishers were in their designated locations and available for immediate use; that
The inspectors reviewed areas to assess if the licensee had implemented a fire  
    fire detectors and sprinklers were unobstructed; that transient material loading was
protection program that adequately controlled combustibles and ignition sources within  
    within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
the plant, effectively maintained fire detection and suppression capability, maintained  
    be in satisfactory condition. The inspectors also verified that minor issues identified
passive fire protection features in good material condition, and had implemented  
    during the inspection were entered into the licensees CAP. Documents reviewed are
adequate compensatory measures for out of service, degraded, or inoperable fire  
    listed in the Attachment to this report.
protection equipment, systems, or features in accordance with the licensees fire plan.
                                                    4                                  Enclosure
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, the inspectors verified that fire hoses and  
extinguishers were in their designated locations and available for immediate use; that  
fire detectors and sprinklers were unobstructed; that transient material loading was  
within the analyzed limits; and fire doors, dampers, and penetration seals appeared to  
be in satisfactory condition. The inspectors also verified that minor issues identified  
during the inspection were entered into the licensees CAP. Documents reviewed are  
listed in the Attachment to this report.  


    These activities constituted five quarterly fire protection inspection samples as defined in
    IP 71111.05-05.
  b. Findings
5
    No findings of significance were identified.
Enclosure
1R11 Licensed Operator Requalification Program (71111.11)
These activities constituted five quarterly fire protection inspection samples as defined in  
  a. Inspection Scope
IP 71111.05-05.  
    On November 17, the inspectors observed a crew of licensed operators in the plants
b.  
    simulator during licensed operator requalification examinations to verify that operator
Findings  
    performance was adequate, evaluators were identifying, and documenting crew
No findings of significance were identified.  
    performance problems, and training was being conducted in accordance with licensee
1R11 Licensed Operator Requalification Program (71111.11)  
    procedures. The inspectors evaluated the following areas:
a.  
    *       licensed operator performance;
Inspection Scope  
    *       crews clarity and formality of communications;
On November 17, the inspectors observed a crew of licensed operators in the plants  
    *       ability to take timely actions in the conservative direction;
simulator during licensed operator requalification examinations to verify that operator  
    *       prioritization, interpretation, and verification of annunciator alarms;
performance was adequate, evaluators were identifying, and documenting crew  
    *       correct use and implementation of abnormal and emergency procedures;
performance problems, and training was being conducted in accordance with licensee  
    *       control board manipulations;
procedures. The inspectors evaluated the following areas:  
    *       oversight and direction from supervisors; and
*  
    *       ability to identify and implement appropriate TS actions and Emergency Plan
licensed operator performance;  
              actions and notifications.
*  
    The crews performance in these areas was compared to pre-established operator action
crews clarity and formality of communications;  
    expectations and successful critical task completion requirements. Documents reviewed
*  
    are listed in the Attachment to this report.
ability to take timely actions in the conservative direction;  
    This inspection constituted one quarterly licensed operator requalification program
*  
    sample as defined in IP 71111.11.
prioritization, interpretation, and verification of annunciator alarms;  
  b. Findings
*  
    No findings of significance were identified.
correct use and implementation of abnormal and emergency procedures;  
1R12 Maintenance Effectiveness (71111.12)
*  
  a. Inspection Scope
control board manipulations;  
    The inspectors evaluated degraded performance issues involving the following risk
*  
    significant systems:
oversight and direction from supervisors; and  
    *       1-2 Emergency Diesel Generator
*  
    The inspectors assessed performance issues with respect to the reliability, availability,
ability to identify and implement appropriate TS actions and Emergency Plan  
    and condition monitoring of the system. In addition, the inspectors verified maintenance
actions and notifications.  
    effectiveness issues were entered into the corrective action program with the appropriate
The crews performance in these areas was compared to pre-established operator action  
    significance characterization. Documents reviewed are listed in the Attachment.
expectations and successful critical task completion requirements. Documents reviewed  
                                                      5                              Enclosure
are listed in the Attachment to this report.  
This inspection constituted one quarterly licensed operator requalification program  
sample as defined in IP 71111.11.  
b.  
Findings  
No findings of significance were identified.  
1R12 Maintenance Effectiveness (71111.12)  
a.  
Inspection Scope  
The inspectors evaluated degraded performance issues involving the following risk  
significant systems:  
*  
1-2 Emergency Diesel Generator  
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 corrective action program with the appropriate  
significance characterization. Documents reviewed are listed in the Attachment.  


    This inspection constitutes one quarterly maintenance effectiveness samples as defined
    in IP 71111.12-05.
  b. Findings
6
    No findings of significance were identified.
Enclosure
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
This inspection constitutes one quarterly maintenance effectiveness samples as defined  
  a. Inspection Scope
in IP 71111.12-05.  
    The inspectors reviewed the licensee's evaluation and management of plant risk for the
b.  
    maintenance and emergent work activities affecting risk-significant and safety-related
Findings  
    equipment listed below to verify that the appropriate risk assessments were performed
No findings of significance were identified.  
    prior to removing equipment for work:
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)  
    *       HPSI-B bearing oil change with hot leg injection valve breaker work and
a.  
              switchyard work (yellow risk);
Inspection Scope  
    *       Unplanned AFW right train inoperability.
The inspectors reviewed the licensee's evaluation and management of plant risk for the  
    These activities were selected based on their potential risk significance relative to the
maintenance and emergent work activities affecting risk-significant and safety-related  
    reactor safety cornerstones. As applicable for each activity, the inspectors verified that
equipment listed below to verify that the appropriate risk assessments were performed  
    risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate
prior to removing equipment for work:  
    and complete. When emergent work was performed, the inspectors verified that the
*  
    plant risk was promptly reassessed and managed. The inspectors reviewed the scope
HPSI-B bearing oil change with hot leg injection valve breaker work and  
    of maintenance work, discussed the results of the assessment with the licensee's
switchyard work (yellow risk);  
    probabilistic risk analyst or shift technical advisor, and verified plant conditions were
*  
    consistent with the risk assessment. The inspectors also reviewed TS requirements and
Unplanned AFW right train inoperability.
    walked down portions of redundant safety systems, when applicable, to verify risk
    analysis assumptions were valid and applicable requirements were met.
These activities were selected based on their potential risk significance relative to the  
    These maintenance risk assessments and emergent work control activities constituted
reactor safety cornerstones. As applicable for each activity, the inspectors verified that  
    two samples as defined in IP 71111.13-05.
risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate  
  b. Findings
and complete. When emergent work was performed, the inspectors verified that the  
    No findings of significance were identified.
plant risk was promptly reassessed and managed. The inspectors reviewed the scope  
1R15 Operability Evaluations (71111.15)
of maintenance work, discussed the results of the assessment with the licensee's  
  a. Inspection Scope
probabilistic risk analyst or shift technical advisor, and verified plant conditions were  
    The inspectors reviewed the following issues:
consistent with the risk assessment. The inspectors also reviewed TS requirements and  
    *       CR HVAC chiller capacity with hot-gas bypass isolated;
walked down portions of redundant safety systems, when applicable, to verify risk  
    *       CR HVAC fittings found not in-accordance with design;
analysis assumptions were valid and applicable requirements were met.  
    *       Containment Spray header inoperable after pressure gauge replacement;
These maintenance risk assessments and emergent work control activities constituted  
    *       EDG 1-2 due to increased load from Containment Air Coolers.
two samples as defined in IP 71111.13-05.  
    The inspectors selected these potential operability issues based on the risk-significance
b.  
    of the associated components and systems. The inspectors evaluated the technical
Findings  
                                                    6                                    Enclosure
No findings of significance were identified.  
1R15 Operability Evaluations (71111.15)  
a.  
Inspection Scope  
The inspectors reviewed the following issues:  
*  
CR HVAC chiller capacity with hot-gas bypass isolated;  
*  
CR HVAC fittings found not in-accordance with design;  
*  
Containment Spray header inoperable after pressure gauge replacement;  
*  
EDG 1-2 due to increased load from Containment Air Coolers.  
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
7
  appropriate sections of the TS and UFSAR to the licensees evaluations, to determine
Enclosure
  whether the components or systems were operable. Where compensatory measures
adequacy of the evaluations to ensure that TS operability was properly justified, and the  
  were required to maintain operability, the inspectors determined whether the measures
subject component or system remained available such that no unrecognized increase in  
  in place would function as intended and were properly controlled. The inspectors
risk occurred. The inspectors compared the operability and design criteria in the  
  determined, where appropriate, compliance with bounding limitations associated with the
appropriate sections of the TS and UFSAR to the licensees evaluations, to determine  
  evaluations. Additionally, the inspectors also reviewed a sampling of corrective action
whether the components or systems were operable. Where compensatory measures  
  documents to verify that the licensee was identifying and correcting any deficiencies
were required to maintain operability, the inspectors determined whether the measures  
  associated with operability evaluations. Documents reviewed are listed in the
in place would function as intended and were properly controlled. The inspectors  
  Attachment.
determined, where appropriate, compliance with bounding limitations associated with the  
  This inspection constitutes four samples as defined in IP 71111.15.-05.
evaluations. Additionally, the inspectors also reviewed a sampling of corrective action  
b. Findings
documents to verify that the licensee was identifying and correcting any deficiencies  
  Introduction: The inspectors identified a finding of very low safety significance (Green)
associated with operability evaluations. Documents reviewed are listed in the  
  and an associated NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, for
Attachment.  
  the inadequate testing of the heat removal capacity of the CR HVAC system.
This inspection constitutes four samples as defined in IP 71111.15.-05.  
  Specifically, the licensee isolated refrigerant hot gas bypass flow during the test which
b.  
  increased the heat removal capability of the chiller.
Findings  
  Description: On August 26, 2008, the licensee performed a surveillance test, RT-202, to
Introduction: The inspectors identified a finding of very low safety significance (Green)  
  determine the heat removal capability of the A chiller. The test assessed the capability
and an associated NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, for  
  of chiller to remove heat load during design basis conditions. The inspectors reviewed
the inadequate testing of the heat removal capacity of the CR HVAC system.
  the procedure and conduct of the test and noted that step 5.1.3.d of the procedure
Specifically, the licensee isolated refrigerant hot gas bypass flow during the test which  
  manually isolated the hot gas bypass valve of the chiller. Under normal and design
increased the heat removal capability of the chiller.  
  conditions, the hot gas bypass flow control valve regulates automatically to open and
Description: On August 26, 2008, the licensee performed a surveillance test, RT-202, to  
  bypass refrigerant from the condensing unit to maintain compressor suction pressure
determine the heat removal capability of the A chiller. The test assessed the capability  
  under low load condition. At full load conditions the valve is closed, but by design there
of chiller to remove heat load during design basis conditions. The inspectors reviewed  
  is a small amount of refrigerant that flows. Therefore, isolating the hot gas bypass
the procedure and conduct of the test and noted that step 5.1.3.d of the procedure  
  increases the heat removal capability of the chiller. Since hot gas bypass would not be
manually isolated the hot gas bypass valve of the chiller. Under normal and design  
  isolated during normal operation nor during an event, the inspectors concluded that
conditions, the hot gas bypass flow control valve regulates automatically to open and  
  isolating hot gas bypass was preconditioning. As part of the corrective actions, the
bypass refrigerant from the condensing unit to maintain compressor suction pressure  
  licensee reviewed test data going back approximately 3 years and adjusted the data to
under low load condition. At full load conditions the valve is closed, but by design there  
  account for hot gas bypass flow. For the July 2007 test on the A train of the CR HVAC
is a small amount of refrigerant that flows. Therefore, isolating the hot gas bypass  
  system, taking hot gas bypass flow into consideration would have resulted in a
increases the heat removal capability of the chiller. Since hot gas bypass would not be  
  measured capacity approximately 9200 BTU/hr below the acceptance criteria of RT-202.
isolated during normal operation nor during an event, the inspectors concluded that  
  Based on discussions with the system engineer and a review of previous revisions of
isolating hot gas bypass was preconditioning. As part of the corrective actions, the  
  RT-202, the inspectors determined that RT-202 was being performed with hot gas
licensee reviewed test data going back approximately 3 years and adjusted the data to  
  bypass flow isolated since the year 2000.
account for hot gas bypass flow. For the July 2007 test on the A train of the CR HVAC  
  In order to determine current operability of the CR HVAC system, the licensee adjusted
system, taking hot gas bypass flow into consideration would have resulted in a  
  the most recent results of RT-202 to account for hot gas bypass flow. The licensee
measured capacity approximately 9200 BTU/hr below the acceptance criteria of RT-202.
  determined that the B CR HVAC train was operable and that the A CR HVAC train
Based on discussions with the system engineer and a review of previous revisions of  
  would remain operable below an outside air temperature of 87 degrees. Upon further
RT-202, the inspectors determined that RT-202 was being performed with hot gas  
  questioning by the inspectors regarding the TS requirements, the licensee later declared
bypass flow isolated since the year 2000.  
  the A train of CR HVAC inoperable. As part of the licensees corrective actions, the
In order to determine current operability of the CR HVAC system, the licensee adjusted  
  RT-202 basis calculation was revised. By using margin included in the analysis
the most recent results of RT-202 to account for hot gas bypass flow. The licensee  
  regarding allowable control room temperature, the licensee provided a basis to restore
determined that the B CR HVAC train was operable and that the A CR HVAC train  
                                                  7                                  Enclosure
would remain operable below an outside air temperature of 87 degrees. Upon further  
questioning by the inspectors regarding the TS requirements, the licensee later declared  
the A train of CR HVAC inoperable. As part of the licensees corrective actions, the  
RT-202 basis calculation was revised. By using margin included in the analysis  
regarding allowable control room temperature, the licensee provided a basis to restore  


    the A chiller to operable status and demonstrate operability for the previous tests that
    were reviewed.
    Analysis: The inspectors concluded that the failure to properly demonstrate the
8
    capability of the chillers warranted an evaluation using the SDP. Specifically, the
Enclosure
    manual isolation of the hot gas bypass line provided an erroneous value for chiller
the A chiller to operable status and demonstrate operability for the previous tests that  
    capacity. On one occasion, isolation of the flow path masked a condition where the
were reviewed.  
    chiller would not have been able to meet surveillance requirements. Although the
Analysis: The inspectors concluded that the failure to properly demonstrate the  
    licensee was able to revise an underlying calculation to show the chiller could maintain
capability of the chillers warranted an evaluation using the SDP. Specifically, the  
    control room temperatures within the TS requirements, the failure to meet the
manual isolation of the hot gas bypass line provided an erroneous value for chiller  
    requirements prior to the calculation markup created a reasonable doubt of the
capacity. On one occasion, isolation of the flow path masked a condition where the  
    operability of the chiller. Using IMC 0612, Appendix E, Examples of Minor Issues, the
chiller would not have been able to meet surveillance requirements. Although the  
    inspectors determined that the finding was similar to Example E.3.j and was more than
licensee was able to revise an underlying calculation to show the chiller could maintain  
    minor because the error resulted in reasonable doubt as to the operability of the chiller.
control room temperatures within the TS requirements, the failure to meet the  
    This finding affects the Procedure Quality attribute of the Mitigating Systems cornerstone
requirements prior to the calculation markup created a reasonable doubt of the  
    objective of ensuring the availability, reliability, and capability of systems that respond to
operability of the chiller. Using IMC 0612, Appendix E, Examples of Minor Issues, the  
    initiating events to prevent undesirable consequences in that the licensee used
inspectors determined that the finding was similar to Example E.3.j and was more than  
    inadequate testing to demonstrate operability of the system. To further assess the
minor because the error resulted in reasonable doubt as to the operability of the chiller.
    significance of the finding, the inspectors used IMC 0609, Appendix A, Determining the
This finding affects the Procedure Quality attribute of the Mitigating Systems cornerstone  
    Significance of Reactor Inspection Findings for At-Power Situations. Based upon a
objective of ensuring the availability, reliability, and capability of systems that respond to  
    review of the licensees revised calculation for the CR HVAC system acceptance criteria
initiating events to prevent undesirable consequences in that the licensee used  
    and the TS requirements, the finding screens as very low safety significance (Green)
inadequate testing to demonstrate operability of the system. To further assess the  
    using the Phase 1 worksheets due to answering no to each of the screening questions.
significance of the finding, the inspectors used IMC 0609, Appendix A, Determining the  
    The inspectors determined that the finding included a cross-cutting aspect in the area of
Significance of Reactor Inspection Findings for At-Power Situations. Based upon a  
    human performance, resources, and complete and accurate procedures (H.2(c))
review of the licensees revised calculation for the CR HVAC system acceptance criteria  
    because the surveillance procedure unacceptably preconditioned the chiller. The finding
and the TS requirements, the finding screens as very low safety significance (Green)  
    reflects current performance because the licensee revised the steps in question in
using the Phase 1 worksheets due to answering no to each of the screening questions.
    July 2007 but failed to identify and correct the preconditioning.
The inspectors determined that the finding included a cross-cutting aspect in the area of  
    Enforcement: Appendix B of 10 CFR Part 50, Criterion XI, Test Control, requires, in
human performance, resources, and complete and accurate procedures (H.2(c))  
    part, that a test program be established to assure that all testing required to
because the surveillance procedure unacceptably preconditioned the chiller. The finding  
    demonstrate that structures, systems, and components will perform satisfactorily in
reflects current performance because the licensee revised the steps in question in  
    service is identified and performed in accordance with written test procedures which
July 2007 but failed to identify and correct the preconditioning.  
    incorporate the requirements and acceptance limits contained in the applicable design
Enforcement: Appendix B of 10 CFR Part 50, Criterion XI, Test Control, requires, in  
    documents. Contrary to this requirement, during the performance of TS Surveillance
part, that a test program be established to assure that all testing required to  
    Procedure RT-202, Control Room HVAC Heat Removal Capability in August 2008, the
demonstrate that structures, systems, and components will perform satisfactorily in  
    inspectors identified that the procedure does not adequately test the chillers to ensure
service is identified and performed in accordance with written test procedures which  
    bypass flow of refrigerant is accounted for in the capacity of the unit. In addition,
incorporate the requirements and acceptance limits contained in the applicable design  
    potential degradation in the hot gas bypass flow line is not analyzed. Because the
documents. Contrary to this requirement, during the performance of TS Surveillance  
    finding is of very low safety significance and has been entered into the licensees
Procedure RT-202, Control Room HVAC Heat Removal Capability in August 2008, the  
    CAP as CR-2008-03993, this violation of 10 CFR 50, Appendix B, Criterion XI, is being
inspectors identified that the procedure does not adequately test the chillers to ensure  
    treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy.
bypass flow of refrigerant is accounted for in the capacity of the unit. In addition,  
    (NCV 05000255/2008005 01, Inadequate Testing of Control Room Chillers)
potential degradation in the hot gas bypass flow line is not analyzed. Because the  
1R18 Plant Modifications (71111.18)
finding is of very low safety significance and has been entered into the licensees  
  a. Inspection Scope
CAP as CR-2008-03993, this violation of 10 CFR 50, Appendix B, Criterion XI, is being  
    The inspectors reviewed the following temporary modification(s):
treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy.
    *       EC-10638, Disable Fast Transfer.
(NCV 05000255/2008005 01, Inadequate Testing of Control Room Chillers)  
                                                      8                                    Enclosure
1R18 Plant Modifications (71111.18)  
a.  
Inspection Scope  
The inspectors reviewed the following temporary modification(s):  
*  
EC-10638, Disable Fast Transfer.  


    The inspectors compared the temporary configuration changes and associated
    10 CFR 50.59 screening and evaluation information against the design basis, the
    UFSAR, and the TS, as applicable, to verify that the modification did not affect the
9
    operability or availability of the affected system(s). The inspectors also compared the
Enclosure
    licensees information to operating experience information to ensure that lessons learned
The inspectors compared the temporary configuration changes and associated  
    from other utilities had been incorporated into the licensees decision to implement the
10 CFR 50.59 screening and evaluation information against the design basis, the  
    temporary modification. The inspectors, as applicable, performed field verifications to
UFSAR, and the TS, as applicable, to verify that the modification did not affect the  
    ensure that the modifications were installed as directed; the modifications operated as
operability or availability of the affected system(s). The inspectors also compared the  
    expected; modification testing adequately demonstrated continued system operability,
licensees information to operating experience information to ensure that lessons learned  
    availability, and reliability; and that operation of the modifications did not impact the
from other utilities had been incorporated into the licensees decision to implement the  
    operability of any interfacing systems. Lastly, the inspectors discussed the temporary
temporary modification. The inspectors, as applicable, performed field verifications to  
    modification with operations, engineering, and training personnel to ensure that the
ensure that the modifications were installed as directed; the modifications operated as  
    individuals were aware of how extended operation with the temporary modification in
expected; modification testing adequately demonstrated continued system operability,  
    place could impact overall plant performance.
availability, and reliability; and that operation of the modifications did not impact the  
    This inspection constituted one temporary modification sample as defined in
operability of any interfacing systems. Lastly, the inspectors discussed the temporary  
    IP 71111.18-05.
modification with operations, engineering, and training personnel to ensure that the  
  b. Findings
individuals were aware of how extended operation with the temporary modification in  
    No findings of significance were identified.
place could impact overall plant performance.  
1R19 Post-Maintenance Testing (71111.19)
This inspection constituted one temporary modification sample as defined in  
  a. Inspection Scope
IP 71111.18-05.  
    The inspectors reviewed the following post-maintenance activities to verify that
b.  
    procedures and test activities were adequate to ensure system operability and functional
Findings  
    capability:
No findings of significance were identified.  
    *       Uninterruptible power supply following installation;
1R19 Post-Maintenance Testing (71111.19)  
    *       Primary rod position indication following power supply replacement;
a.  
    *       AFW Right Train Power Supply Replacement.
Inspection Scope  
    These activities were selected based upon the structure, system, or component's ability
The inspectors reviewed the following post-maintenance activities to verify that  
    to impact risk. The inspectors evaluated these activities for the following (as applicable):
procedures and test activities were adequate to ensure system operability and functional  
    the effect of testing on the plant had been adequately addressed; testing was adequate
capability:  
    for the maintenance performed; acceptance criteria were clear and demonstrated
*  
    operational readiness; test instrumentation was appropriate; tests were performed as
Uninterruptible power supply following installation;  
    written in accordance with properly reviewed and approved procedures; equipment was
*  
    returned to its operational status following testing (temporary modifications or jumpers
Primary rod position indication following power supply replacement;  
    required for test performance were properly removed after test completion); and test
*  
    documentation was properly evaluated. The inspectors evaluated the activities against
AFW Right Train Power Supply Replacement.  
    TS, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various
These activities were selected based upon the structure, system, or component's ability  
    NRC generic communications to ensure that the test results adequately ensured that the
to impact risk. The inspectors evaluated these activities for the following (as applicable):  
    equipment met the licensing basis and design requirements. In addition, the inspectors
the effect of testing on the plant had been adequately addressed; testing was adequate  
    reviewed corrective action documents associated with post-maintenance tests to
for the maintenance performed; acceptance criteria were clear and demonstrated  
    determine whether the licensee was identifying problems and entering them in the CAP
operational readiness; test instrumentation was appropriate; tests were performed as  
    and that the problems were being corrected commensurate with their importance to
written in accordance with properly reviewed and approved procedures; equipment was  
    safety. Documents reviewed are listed in the Attachment to this report.
returned to its operational status following testing (temporary modifications or jumpers  
                                                    9                                  Enclosure
required for test performance were properly removed after test completion); and test  
documentation was properly evaluated. The inspectors evaluated the activities against  
TS, 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 three post-maintenance testing samples as defined in
    IP 71111.19-05.
  b. Findings
10
    No findings of significance were identified.
Enclosure
1R22 Surveillance Testing (71111.22)
This inspection constituted three post-maintenance testing samples as defined in  
  a. Inspection Scope
IP 71111.19-05.  
    The inspectors reviewed the test results for the following activities to determine whether
b.  
    risk-significant systems and equipment were capable of performing their intended safety
Findings  
    function and to verify testing was conducted in accordance with applicable procedural
No findings of significance were identified.  
    and TS requirements:
1R22 Surveillance Testing (71111.22)  
    *       RPS-I-7, Anticipated Transient Without Scram Calibration/Functional Test
a.  
    *       QO-1, Safety Injection Test;
Inspection Scope  
    *       RO-52, Fire Pump Capacity Test;
The inspectors reviewed the test results for the following activities to determine whether  
    *       QO-15, Component Cooling Water-B Pump In-Service Test.
risk-significant systems and equipment were capable of performing their intended safety  
    The inspectors observed in-plant activities and reviewed procedures and associated
function and to verify testing was conducted in accordance with applicable procedural  
    records to determine the following:
and TS requirements:  
    *       did preconditioning occur;
*  
    *       were the effects of the testing adequately addressed by control room personnel
RPS-I-7, Anticipated Transient Without Scram Calibration/Functional Test  
            or engineers prior to the commencement of the testing;
*  
    *       were acceptance criteria clearly stated, demonstrated operational readiness, and
QO-1, Safety Injection Test;  
            consistent with the system design basis;
*  
    *       plant equipment calibration was correct, accurate, and properly documented;
RO-52, Fire Pump Capacity Test;  
    *       as-left setpoints were within required ranges; and the calibration frequency were
*  
            in accordance with TSs, the UFSAR, procedures, and applicable commitments;
QO-15, Component Cooling Water-B Pump In-Service Test.  
    *       measuring and test equipment calibration was current;
The inspectors observed in-plant activities and reviewed procedures and associated  
    *       test equipment was used within the required range and accuracy; applicable
records to determine the following:  
            prerequisites described in the test procedures were satisfied;
*  
    *       test frequencies met TS requirements to demonstrate operability and reliability;
did preconditioning occur;
            tests were performed in accordance with the test procedures and other
*  
            applicable procedures; jumpers and lifted leads were controlled and restored
were the effects of the testing adequately addressed by control room personnel  
            where used;
or engineers prior to the commencement of the testing;  
    *       test data and results were accurate, complete, within limits, and valid;
*  
    *       test equipment was removed after testing;
were acceptance criteria clearly stated, demonstrated operational readiness, and  
    *       where applicable for inservice testing activities, testing was performed in
consistent with the system design basis;  
            accordance with the applicable version of Section XI, American Society of
*  
            Mechanical Engineers Code, and reference values were consistent with the
plant equipment calibration was correct, accurate, and properly documented;  
            system design basis;
*  
    *       where applicable, test results not meeting acceptance criteria were addressed
as-left setpoints were within required ranges; and the calibration frequency were  
            with an adequate operability evaluation or the system or component was
in accordance with TSs, the UFSAR, procedures, and applicable commitments;  
            declared inoperable;
*  
    *       where applicable for safety-related instrument control surveillance tests,
measuring and test equipment calibration was current;  
            reference setting data were accurately incorporated in the test procedure;
*  
                                                  10                                  Enclosure
test equipment was used within the required range and accuracy; applicable  
prerequisites described in the test procedures were satisfied;  
*  
test frequencies met TS requirements to demonstrate operability and reliability;  
tests were performed in accordance with the test procedures and other  
applicable procedures; jumpers and lifted leads were controlled and restored  
where used;  
*  
test data and results were accurate, complete, within limits, and valid;  
*  
test equipment was removed after testing;  
*  
where applicable for inservice testing activities, testing was performed in  
accordance with the applicable version of Section XI, American Society of  
Mechanical Engineers Code, and reference values were consistent with the  
system design basis;  
*  
where applicable, test results not meeting acceptance criteria were addressed  
with an adequate operability evaluation or the system or component was  
declared inoperable;  
*  
where applicable for safety-related instrument control surveillance tests,  
reference setting data were accurately incorporated in the test procedure;  


    *       where applicable, actual conditions encountering high resistance electrical
            contacts were such that the intended safety function could still be accomplished;
    *       prior procedure changes had not provided an opportunity to identify problems
11
            encountered during the performance of the surveillance or calibration test;
Enclosure
    *       equipment was returned to a position or status required to support the
*  
            performance of its safety functions; and
where applicable, actual conditions encountering high resistance electrical  
    *       all problems identified during the testing were appropriately documented and
contacts were such that the intended safety function could still be accomplished;  
            dispositioned in the CAP.
*  
    Documents reviewed are listed in the Attachment to this report.
prior procedure changes had not provided an opportunity to identify problems  
    This inspection constituted four routine surveillance testing sample(s) and one inservice
encountered during the performance of the surveillance or calibration test;  
    testing sample.
*  
  b. Findings
equipment was returned to a position or status required to support the  
    No findings of significance were identified.
performance of its safety functions; and  
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
*  
  a. Inspection Scope
all problems identified during the testing were appropriately documented and  
    Since the last NRC inspection of this program area, Emergency Plan Revision 17 and
dispositioned in the CAP.  
    Implementing Procedure EI-1, "Emergency Classification and Actions," Revision 49,
Documents reviewed are listed in the Attachment to this report.  
    were implemented based on your determination, in accordance with 10 CFR 50.54(q),
This inspection constituted four routine surveillance testing sample(s) and one inservice  
    that the changes resulted in no decrease in effectiveness of the Plan, and that the
testing sample.  
    revised Plan as changed continues to meet the requirements of 10 CFR 50.47(b) and
b.  
    Appendix E to 10 CFR Part 50. The inspectors conducted a sampling review of the
Findings  
    Emergency Plan changes and a review of the Emergency Action Level changes to
No findings of significance were identified.  
    evaluate for potential decreases in effectiveness of the Plan. However, this review does
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)  
    not constitute formal NRC approval of the changes. Therefore, these changes remain
a.  
    subject to future NRC inspection in their entirety.
Inspection Scope  
    This Emergency Action Level and Emergency Plan Changes inspection constituted one
Since the last NRC inspection of this program area, Emergency Plan Revision 17 and  
    sample as defined in IP 71114.04-05.
Implementing Procedure EI-1, "Emergency Classification and Actions," Revision 49,  
  b. Findings
were implemented based on your determination, in accordance with 10 CFR 50.54(q),  
    No findings of significance were identified.
that the changes resulted in no decrease in effectiveness of the Plan, and that the  
1EP6 Drill Evaluation (71114.06)
revised Plan as changed continues to meet the requirements of 10 CFR 50.47(b) and  
  a. Inspection Scope
Appendix E to 10 CFR Part 50. The inspectors conducted a sampling review of the  
    The inspectors evaluated the conduct of a routine licensee emergency drill on
Emergency Plan changes and a review of the Emergency Action Level changes to  
    November 5, 2008, and a table top drill for the emergency operations facility on
evaluate for potential decreases in effectiveness of the Plan. However, this review does  
    December 17, 2008, to identify any weaknesses and deficiencies in classification,
not constitute formal NRC approval of the changes. Therefore, these changes remain  
    notification, and protective action recommendation development activities. The
subject to future NRC inspection in their entirety.  
    inspectors observed, as applicable, emergency response operations in the simulator
This Emergency Action Level and Emergency Plan Changes inspection constituted one  
    control room, technical support center, and emergency operations facility to determine
sample as defined in IP 71114.04-05.  
    whether the event classification, notifications, and protective action recommendations
b.  
                                                  11                                Enclosure
Findings  
No findings of significance were identified.  
1EP6 Drill Evaluation (71114.06)  
a.  
Inspection Scope  
The inspectors evaluated the conduct of a routine licensee emergency drill on  
November 5, 2008, and a table top drill for the emergency operations facility on  
December 17, 2008, to identify any weaknesses and deficiencies in classification,  
notification, and protective action recommendation development activities. The  
inspectors observed, as applicable, emergency response operations in the simulator  
control room, technical support center, and emergency operations facility 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
12
      staff was properly identifying weaknesses and entering them into the corrective action
Enclosure
      program. As part of the inspection, the inspectors reviewed the drill package and other
were performed in accordance with procedures. The inspectors also attended the  
      documents listed in the Attachment to this report.
licensee drill critique to compare any inspector-observed weakness with those identified  
      These emergency preparedness drill inspections constituted two samples as defined in
by the licensee staff in order to evaluate the critique and to verify whether the licensee  
      IP 71114.06-05.
staff was properly identifying weaknesses and entering them into the corrective action  
  b. Findings
program. As part of the inspection, the inspectors reviewed the drill package and other  
      No findings of significance were identified.
documents listed in the Attachment to this report.  
2.   RADIATION SAFETY
These emergency preparedness drill inspections constituted two samples as defined in  
      Cornerstone: Occupational Radiation Safety
IP 71114.06-05.  
2OS1 Access Control to Radiologically Significant Areas (71121.01)
b.  
.1   Plant Walkdowns and Radiation Work Permit (RWP) Reviews
Findings  
  a. Inspection Scope
No findings of significance were identified.  
      The inspectors reviewed licensee controls and surveys in the following radiologically
2.  
      significant work areas within radiation areas, high radiation areas, and airborne
RADIATION SAFETY  
      radioactivity areas in the plant to determine if radiological controls including surveys,
Cornerstone: Occupational Radiation Safety
      postings, and barricades were acceptable:
2OS1 Access Control to Radiologically Significant Areas (71121.01)  
      *     Auxiliary Building;
.1  
      *     Containment Building; and
Plant Walkdowns and Radiation Work Permit (RWP) Reviews  
      *     Spent Fuel Pool Area.
a.  
      This inspection constitutes one sample as defined in IP 71121.01-5.
Inspection Scope  
      The inspectors reviewed the RWPs and work packages used to access these areas and
The inspectors reviewed licensee controls and surveys in the following radiologically  
      other high radiation work areas. The inspectors assessed the work control instructions
significant work areas within radiation areas, high radiation areas, and airborne  
      and control barriers specified by the licensee. Electronic dosimeter alarm set points for
radioactivity areas in the plant to determine if radiological controls including surveys,  
      both integrated dose and dose rate were evaluated for conformity with survey indications
postings, and barricades were acceptable:    
      and plant policy. The inspectors interviewed workers to verify that they were aware of
*  
      the actions required if their electronic dosimeters noticeably malfunctioned or alarmed.
Auxiliary Building;  
      This inspection constitutes one sample as defined in IP 71121.01-5.
*  
      The inspectors walked down and surveyed (using an NRC survey meter) these areas to
Containment Building; and  
      verify that the prescribed RWP, procedure, and engineering controls were in place; that
*  
      licensee surveys and postings were complete and accurate; and that air samplers were
Spent Fuel Pool Area.  
      properly located.
This inspection constitutes one sample as defined in IP 71121.01-5.  
      This inspection constitutes one sample as defined in IP 71121.01-5.
The inspectors reviewed the RWPs and work packages used to access these areas and  
                                                    12                                    Enclosure
other high radiation work areas. The inspectors assessed the work control instructions  
and control barriers specified by the licensee. Electronic dosimeter alarm set points for  
both integrated dose and dose rate were evaluated for conformity with survey indications  
and plant policy. The inspectors interviewed workers to verify that they were aware of  
the actions required if their electronic dosimeters noticeably malfunctioned or alarmed.
This inspection constitutes one sample as defined in IP 71121.01-5.  
The inspectors walked down and surveyed (using an NRC survey meter) these areas to  
verify that the prescribed RWP, procedure, and engineering controls were in place; that  
licensee surveys and postings were complete and accurate; and that air samplers were  
properly located.
This inspection constitutes one sample as defined in IP 71121.01-5.  


    The inspectors also reviewed the licensees physical and programmatic controls for
    highly activated and/or contaminated materials (non-fuel) stored within the spent fuel
    pool or other storage pools.
13
    This inspection constitutes one sample as defined in IP 71121.01-5.
Enclosure
  b. Findings
The inspectors also reviewed the licensees physical and programmatic controls for  
    No findings of significance were identified.
highly activated and/or contaminated materials (non-fuel) stored within the spent fuel  
.2   Problem Identification and Resolution
pool or other storage pools.  
  a. Inspection Scope
This inspection constitutes one sample as defined in IP 71121.01-5.  
    The inspectors reviewed a sample of the licensees self-assessments, audits, Licensee
b.  
    Event Reports (LERs), and Special Reports related to the access control program to
Findings  
    verify that identified problems were entered into the CAP for resolution.
No findings of significance were identified.  
    This inspection constitutes one sample as defined in IP 71121.01-5.
.2  
    The inspectors evaluated the licensees process for problem identification,
Problem Identification and Resolution  
    characterization, and prioritization and verified that problems were entered into the
a.  
    CAP and resolved. For repetitive deficiencies and/or significant individual deficiencies
Inspection Scope  
    in problem identification and resolution, the inspectors verified that the licensees
The inspectors reviewed a sample of the licensees self-assessments, audits, Licensee  
    self-assessment activities were capable of identifying and addressing these deficiencies.
Event Reports (LERs), and Special Reports related to the access control program to  
    This inspection constitutes one sample as defined in IP 71121.01-5.
verify that identified problems were entered into the CAP for resolution.  
    The inspectors reviewed licensee documentation packages for all performance indicator
This inspection constitutes one sample as defined in IP 71121.01-5.  
    (PI) events occurring since the last inspection to determine if any of these PI events
The inspectors evaluated the licensees process for problem identification,  
    involved dose rates in excess of 25 R/hr at 30 centimeters or in excess of 500 R/hr at
characterization, and prioritization and verified that problems were entered into the  
    1 meter. Barriers were evaluated for failure and to determine if there were any barriers
CAP and resolved. For repetitive deficiencies and/or significant individual deficiencies  
    left to prevent personnel access. Unintended exposures exceeding 100 millirem total
in problem identification and resolution, the inspectors verified that the licensees  
    effective dose equivalent (or 5 rem shallow dose equivalent or 1.5 rem lens dose
self-assessment activities were capable of identifying and addressing these deficiencies.  
    equivalent) were evaluated to determine if there were any regulatory overexposures or if
This inspection constitutes one sample as defined in IP 71121.01-5.
    there was a substantial potential for an overexposure.
The inspectors reviewed licensee documentation packages for all performance indicator  
    This inspection constitutes one sample as defined in IP 71121.01-5.
(PI) events occurring since the last inspection to determine if any of these PI events  
  b. Findings
involved dose rates in excess of 25 R/hr at 30 centimeters or in excess of 500 R/hr at  
    No findings of significance were identified.
1 meter. Barriers were evaluated for failure and to determine if there were any barriers  
.3   Job-In-Progress Reviews
left to prevent personnel access. Unintended exposures exceeding 100 millirem total  
  a. Inspection Scope
effective dose equivalent (or 5 rem shallow dose equivalent or 1.5 rem lens dose  
    The inspectors observed the following two jobs that were being performed in radiation
equivalent) were evaluated to determine if there were any regulatory overexposures or if  
    areas, airborne radioactivity areas, or high radiation areas for observation of work
there was a substantial potential for an overexposure.  
    activities that presented the greatest radiological risk to workers:
This inspection constitutes one sample as defined in IP 71121.01-5.  
                                                  13                                  Enclosure
b.  
Findings  
No findings of significance were identified.  
.3  
Job-In-Progress Reviews  
a.  
Inspection Scope  
The inspectors observed the following two jobs that were being performed in radiation  
areas, airborne radioactivity areas, or high radiation areas for observation of work  
activities that presented the greatest radiological risk to workers:  


    *       Troubleshooting Pressurizer Heater Breaker; and
    *       Negative Reactivity Testing of the Spent Fuel Pool Racks.
    The inspectors reviewed radiological job requirements for these activities, including
14
    RWP requirements and work procedure requirements.
Enclosure
    This inspection constitutes one sample as defined in IP 71121.01-5.
*  
    Job performance was observed with respect to the radiological control requirements to
Troubleshooting Pressurizer Heater Breaker; and
    assess whether radiological conditions in the work area were adequately communicated
*  
    to workers through pre-job briefings and postings. The inspectors evaluated the
Negative Reactivity Testing of the Spent Fuel Pool Racks.  
    adequacy of radiological controls, including required radiation, contamination, and
The inspectors reviewed radiological job requirements for these activities, including  
    airborne surveys for system breaches; radiation protection job coverage, including any
RWP requirements and work procedure requirements.
    applicable audio and visual surveillance for remote job coverage; and contamination
This inspection constitutes one sample as defined in IP 71121.01-5.  
    controls.
Job performance was observed with respect to the radiological control requirements to  
    This inspection constitutes one sample as defined in IP 71121.01-5.
assess whether radiological conditions in the work area were adequately communicated  
  a. Findings
to workers through pre-job briefings and postings. The inspectors evaluated the  
    No findings of significance were identified.
adequacy of radiological controls, including required radiation, contamination, and  
.4   High Risk Significant, High Dose Rate, High Radiation Area, and Very High Radiation
airborne surveys for system breaches; radiation protection job coverage, including any  
    Area Controls
applicable audio and visual surveillance for remote job coverage; and contamination  
  a. Inspection Scope
controls.  
    The inspectors held discussions with the Radiation Protection Manager concerning high
This inspection constitutes one sample as defined in IP 71121.01-5.  
    dose rate, high radiation area, and very high radiation area controls and procedures,
a.  
    including procedural changes that had occurred since the last inspection, in order to
Findings  
    assess whether any procedure modifications substantially reduced the effectiveness and
No findings of significance were identified.  
    level of worker protection.
.4  
    This inspection constitutes one sample as defined in IP 71121.01-5.
High Risk Significant, High Dose Rate, High Radiation Area, and Very High Radiation  
    The inspectors discussed with radiation protection supervisors the controls that were in
Area Controls  
    place for special areas of the plant that had the potential to become very high radiation
a.  
    areas during certain plant operations. The inspectors assessed if plant operations
Inspection Scope  
    required communication beforehand with the radiation protection group, so as to allow
The inspectors held discussions with the Radiation Protection Manager concerning high  
    corresponding timely actions to properly post and control the radiation hazards.
dose rate, high radiation area, and very high radiation area controls and procedures,  
    This inspection constitutes one sample as defined in IP 71121.01-5.
including procedural changes that had occurred since the last inspection, in order to  
    The inspectors conducted plant walkdowns to assess the posting and locking of
assess whether any procedure modifications substantially reduced the effectiveness and  
    entrances to high dose rate, high radiation areas, and very high radiation areas.
level of worker protection.  
    This inspection constitutes one sample as defined in IP 71121.01-5.
This inspection constitutes one sample as defined in IP 71121.01-5.  
  b. Findings
The inspectors discussed with radiation protection supervisors the controls that were in  
    No findings of significance were identified
place for special areas of the plant that had the potential to become very high radiation  
                                                  14                                  Enclosure
areas during certain plant operations. The inspectors assessed if plant operations  
required communication beforehand with the radiation protection group, so as to allow  
corresponding timely actions to properly post and control the radiation hazards.  
This inspection constitutes one sample as defined in IP 71121.01-5.  
The inspectors conducted plant walkdowns to assess the posting and locking of  
entrances to high dose rate, high radiation areas, and very high radiation areas.  
This inspection constitutes one sample as defined in IP 71121.01-5.  
b.  
Findings  
No findings of significance were identified  


.5   Radiation Worker Performance
  a. Inspection Scope
    During job performance observations, the inspectors evaluated radiation worker
15
    performance with respect to stated radiation safety work requirements. The inspectors
Enclosure
    evaluated whether workers were aware of any significant radiological conditions in their
.5  
    workplace, of the RWP controls and limits in place, and of the level of radiological
Radiation Worker Performance  
    hazards present. The inspectors also observed worker performance to determine if
a.  
    workers accounted for these radiological hazards.
Inspection Scope  
    This inspection constitutes one sample as defined in IP 71121.01-5.
During job performance observations, the inspectors evaluated radiation worker  
    The inspectors reviewed radiological problem reports for which the cause of the event
performance with respect to stated radiation safety work requirements. The inspectors  
    was due to radiation worker errors to determine if there was an observable pattern
evaluated whether workers were aware of any significant radiological conditions in their  
    traceable to a similar cause and to determine if this perspective matched the corrective
workplace, of the RWP controls and limits in place, and of the level of radiological  
    action approach taken by the licensee to resolve the reported problems. Problems or
hazards present. The inspectors also observed worker performance to determine if  
    issues with planned or completed corrective actions were discussed with the Radiation
workers accounted for these radiological hazards.  
    Protection Manager.
This inspection constitutes one sample as defined in IP 71121.01-5.  
    This inspection constitutes one sample as defined in IP 71121.01-5.
The inspectors reviewed radiological problem reports for which the cause of the event  
  b. Findings
was due to radiation worker errors to determine if there was an observable pattern  
    No findings of significance were identified.
traceable to a similar cause and to determine if this perspective matched the corrective  
.6   Radiation Protection Technician Proficiency
action approach taken by the licensee to resolve the reported problems. Problems or  
  a. Inspection Scope
issues with planned or completed corrective actions were discussed with the Radiation  
    During job performance observations, the inspectors evaluated radiation protection
Protection Manager.  
    technician performance with respect to radiation safety work requirements. The
This inspection constitutes one sample as defined in IP 71121.01-5.  
    inspectors evaluated whether technicians were aware of the radiological conditions in
b.  
    their workplace, the RWP controls and limits in place, and if their performance was
Findings  
    consistent with their training and qualifications with respect to the radiological hazards
No findings of significance were identified.  
    and work activities.
.6  
    This inspection constitutes one sample as defined in IP 71121.01-5.
Radiation Protection Technician Proficiency  
    The inspectors reviewed radiological problem reports for which the cause of the event
a.  
    was radiation protection technician error to determine if there was an observable pattern
Inspection Scope  
    traceable to a similar cause and to determine if this perspective matched the corrective
During job performance observations, the inspectors evaluated radiation protection  
    action approach taken by the licensee to resolve the reported problems.
technician performance with respect to radiation safety work requirements. The  
    This inspection constitutes one sample as defined in IP 71121.01-5.
inspectors evaluated whether technicians were aware of the radiological conditions in  
  b. Findings
their workplace, the RWP controls and limits in place, and if their performance was  
    No findings of significance were identified.
consistent with their training and qualifications with respect to the radiological hazards  
                                                    15                                  Enclosure
and work activities.  
This inspection constitutes one sample as defined in IP 71121.01-5.  
The inspectors reviewed radiological problem reports for which the cause of the event  
was radiation protection technician error to determine if there was an observable pattern  
traceable to a similar cause and to determine if this perspective matched the corrective  
action approach taken by the licensee to resolve the reported problems.  
This inspection constitutes one sample as defined in IP 71121.01-5.  
b.  
Findings  
No findings of significance were identified.  


4.   OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.1   Reactor Coolant System Leakage
16
  a. Inspection Scope
Enclosure
      The inspectors sampled licensee submittals for the Reactor Coolant System
4.  
      Leakage performance indicator for the period from the fourth quarter 2007 through
OTHER ACTIVITIES  
      the third quarter 2008. To determine the accuracy of the PI data reported during those
4OA1 Performance Indicator Verification (71151)  
      periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI)
.1  
      Document 99-02, Regulatory Assessment Performance Indicator Guideline,
Reactor Coolant System Leakage  
      Revision 5, was used. The inspectors reviewed the licensees operator logs and verified
a.  
      the accuracy of a sample of calculations for the period of October 2007 through
Inspection Scope  
      September 2008 to validate the licensees submittals. Documents reviewed are listed in
The inspectors sampled licensee submittals for the Reactor Coolant System  
      the Attachment to this report.
Leakage performance indicator for the period from the fourth quarter 2007 through  
      This inspection constituted one reactor coolant system leakage sample as defined in
the third quarter 2008. To determine the accuracy of the PI data reported during those  
      IP 71151-05.
periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI)  
  b. Findings
Document 99-02, Regulatory Assessment Performance Indicator Guideline,  
      No findings of significance were identified.
Revision 5, was used. The inspectors reviewed the licensees operator logs and verified  
.2   Unplanned Transients per 7000 Critical Hours
the accuracy of a sample of calculations for the period of October 2007 through  
  a. Inspection Scope
September 2008 to validate the licensees submittals. Documents reviewed are listed in  
      The inspectors sampled licensee submittals for the Unplanned Transients per
the Attachment to this report.  
      7000 Critical Hours performance indicator for the period from the fourth quarter 2007
This inspection constituted one reactor coolant system leakage sample as defined in  
      through the third quarter of 2008. To determine the accuracy of the PI data reported
IP 71151-05.  
      during those periods, PI definitions and guidance contained in the NEI Document 99-02,
b.  
      Regulatory Assessment Performance Indicator Guideline, Revision 5, was used. The
Findings  
      inspectors reviewed the licensees operator narrative logs and NRC Integrated
No findings of significance were identified.  
      Inspection Reports for the period of October 2007 through September 2008 to validate
.2  
      the accuracy of the submittals. Documents reviewed are listed in the Attachment to this
Unplanned Transients per 7000 Critical Hours  
      report.
a.  
      This inspection constituted one unplanned transients per 7000 critical hours sample as
Inspection Scope  
      defined in IP 71151-05.
The inspectors sampled licensee submittals for the Unplanned Transients per  
  b. Findings
7000 Critical Hours performance indicator for the period from the fourth quarter 2007  
      No findings of significance were identified.
through the third quarter of 2008. To determine the accuracy of the PI data reported  
.3   Safety System Functional Failures
during those periods, PI definitions and guidance contained in the NEI Document 99-02,  
  a. Inspection Scope
Regulatory Assessment Performance Indicator Guideline, Revision 5, was used. The  
      The inspectors sampled licensee submittals for the Safety System Functional Failures
inspectors reviewed the licensees operator narrative logs and NRC Integrated  
      performance indicator for the period from the fourth quarter 2007 through the third
Inspection Reports for the period of October 2007 through September 2008 to validate  
                                                  16                                Enclosure
the accuracy of the submittals. Documents reviewed are listed in the Attachment to this  
report.  
This inspection constituted one unplanned transients per 7000 critical hours sample as  
defined in IP 71151-05.  
b.  
Findings  
No findings of significance were identified.  
.3  
Safety System Functional Failures  
a.  
Inspection Scope  
The inspectors sampled licensee submittals for the Safety System Functional Failures  
performance indicator for the period from the fourth quarter 2007 through the third  


      quarter 2008 to determine the accuracy of the PI data reported during those periods,
      PI definitions and guidance contained in the NEI Document 99-02, Regulatory
      Assessment Performance Indicator Guideline, Revision 5, and NUREG-1022, Event
17
      Reporting Guidelines 10 CFR 50.72 and 50.73," definitions and guidance, were used.
Enclosure
      The inspectors reviewed licensee event reports for the period of October 2007 through
quarter 2008 to determine the accuracy of the PI data reported during those periods,  
      September 2008 to validate the accuracy of the submittals. Documents reviewed are
PI definitions and guidance contained in the NEI Document 99-02, Regulatory  
      listed in the Attachment to this report.
Assessment Performance Indicator Guideline, Revision 5, and NUREG-1022, Event  
      This inspection constituted one safety system functional failures sample as defined in
Reporting Guidelines 10 CFR 50.72 and 50.73," definitions and guidance, were used.
      IP 71151-05.
The inspectors reviewed licensee event reports for the period of October 2007 through  
.4   Mitigating Systems Performance Index - Cooling Water Systems
September 2008 to validate the accuracy of the submittals. Documents reviewed are  
  a. Inspection Scope
listed in the Attachment to this report.  
      The inspectors sampled licensee submittals for the Mitigating Systems Performance
This inspection constituted one safety system functional failures sample as defined in  
      Index (MSPI) - Cooling Water Systems performance indicator for the period from the
IP 71151-05.  
      fourth quarter 2007 through the third quarter of 2008 to determine the accuracy of the
.4  
      PI data reported during those periods, PI definitions and guidance contained in the
Mitigating Systems Performance Index - Cooling Water Systems  
      NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
a.  
      Revision 5, were used. The inspectors reviewed the licensees operator narrative logs,
Inspection Scope  
      condition reports, MSPI derivation reports, event reports, and NRC Integrated Inspection
The inspectors sampled licensee submittals for the Mitigating Systems Performance  
      Reports for the period of October 2007 through September 2008 to validate the accuracy
Index (MSPI) - Cooling Water Systems performance indicator for the period from the  
      of the submittals. The inspectors reviewed the MSPI component risk coefficient to
fourth quarter 2007 through the third quarter of 2008 to determine the accuracy of the  
      determine if it had changed by more than 25 percent in value since the previous
PI data reported during those periods, PI definitions and guidance contained in the  
      inspection, and if so, that the change was in accordance with applicable NEI guidance.
NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,  
      The inspectors also reviewed the licensees issue report database to determine if any
Revision 5, were used. The inspectors reviewed the licensees operator narrative logs,  
      problems had been identified with the PI data collected or transmitted for this indicator
condition reports, MSPI derivation reports, event reports, and NRC Integrated Inspection  
      and none were identified. Documents reviewed are listed in the Attachment to this
Reports for the period of October 2007 through September 2008 to validate the accuracy  
      report.
of the submittals. The inspectors reviewed the MSPI component risk coefficient to  
      This inspection constituted one MSPI cooling water system sample as defined in
determine if it had changed by more than 25 percent in value since the previous  
      IP 71151-05.
inspection, and if so, that the change was in accordance with applicable NEI guidance.
  b. Findings
The inspectors also reviewed the licensees issue report database to determine if any  
      No findings of significance were identified.
problems had been identified with the PI data collected or transmitted for this indicator  
4OA2 Identification and Resolution of Problems (71152)
and none were identified. Documents reviewed are listed in the Attachment to this  
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
report.  
      Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
This inspection constituted one MSPI cooling water system sample as defined in  
      Physical Protection
IP 71151-05.  
.1   Routine Review of items Entered Into the Corrective Action Program
b.  
  a. Inspection Scope
Findings  
      As part of the various baseline inspection procedures discussed in previous sections of
No findings of significance were identified.  
      this report, the inspectors routinely reviewed issues during baseline inspection activities
4OA2 Identification and Resolution of Problems (71152)  
      and plant status reviews to verify that they were being entered into the licensees CAP at
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency  
                                                  17                                  Enclosure
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and  
Physical Protection  
.1  
Routine Review of items Entered Into the Corrective Action Program  
a.  
Inspection Scope  
As part of the various baseline inspection procedures discussed in previous sections of  
this report, the inspectors routinely reviewed issues during baseline inspection activities  
and plant status reviews to verify that 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: the complete and accurate identification of the problem; that timeliness was
18
    commensurate with the safety significance; that evaluation and disposition of
Enclosure
    performance issues, generic implications, common causes, contributing factors, root
an appropriate threshold, that adequate attention was being given to timely corrective  
    causes, extent of condition reviews, and previous occurrences reviews were proper and
actions, and that adverse trends were identified and addressed. Attributes reviewed  
    adequate; and that the classification, prioritization, focus, and timeliness of corrective
included: the complete and accurate identification of the problem; that timeliness was  
    actions were commensurate with safety and sufficient to prevent recurrence of the issue.
commensurate with the safety significance; that evaluation and disposition of  
    Minor issues entered into the licensees CAP as a result of the inspectors observations
performance issues, generic implications, common causes, contributing factors, root  
    are included in the attached List of Documents Reviewed.
causes, extent of condition reviews, and previous occurrences reviews were proper and  
    These routine reviews for the identification and resolution of problems did not constitute
adequate; and that the classification, prioritization, focus, and timeliness of corrective  
    any additional inspection samples. Instead, by procedure they were considered an
actions were commensurate with safety and sufficient to prevent recurrence of the issue.
    integral part of the inspections performed during the quarter and documented in
Minor issues entered into the licensees CAP as a result of the inspectors observations  
    Section 1 of this report.
are included in the attached List of Documents Reviewed.  
  b. Findings
These routine reviews for the identification and resolution of problems did not constitute  
    No findings of significance were identified.
any additional inspection samples. Instead, by procedure they were considered an  
.2   Daily Corrective Action Program Reviews
integral part of the inspections performed during the quarter and documented in  
  a. Inspection Scope
Section 1 of this report.  
    In order to assist with the identification of repetitive equipment failures and specific
b.  
    human performance issues for follow-up, the inspectors performed a daily screening of
Findings  
    items entered into the licensees CAP. This review was accomplished through
No findings of significance were identified.  
    inspection of the stations daily condition report packages.
.2  
    These daily reviews were performed by procedure as part of the inspectors daily plant
Daily Corrective Action Program Reviews  
    status monitoring activities and, as such, did not constitute any separate inspection
a.  
    samples.
Inspection Scope  
  b. Findings
In order to assist with the identification of repetitive equipment failures and specific  
    No findings of significance were identified.
human performance issues for follow-up, the inspectors performed a daily screening of  
.3   Semi-Annual Trend Review
items entered into the licensees CAP. This review was accomplished through  
  a. Inspection Scope
inspection of the stations daily condition report packages.  
    The inspectors performed a review of the licensees CAP and associated documents to
These daily reviews were performed by procedure as part of the inspectors daily plant  
    identify trends that could indicate the existence of a more significant safety issue. The
status monitoring activities and, as such, did not constitute any separate inspection  
    inspectors review was focused on repetitive equipment issues, but also considered the
samples.  
    results of daily inspector CAP item screening discussed in Section 4OA2.2 above,
b.  
    licensee trending efforts, departmental performance reports and metrics, and licensee
Findings  
    human performance results. The inspectors review nominally considered the 6 month
No findings of significance were identified.  
    period of July 2008 through December 2008, although some examples expanded
.3  
    beyond those dates where the scope of the trend warranted.
Semi-Annual Trend Review  
                                                    18                                  Enclosure
a.  
Inspection Scope  
The inspectors performed a review of the licensees CAP and associated documents to  
identify trends that could indicate the existence of a more significant safety issue. The  
inspectors review was focused on repetitive equipment issues, but also considered the  
results of daily inspector CAP item screening discussed in Section 4OA2.2 above,  
licensee trending efforts, departmental performance reports and metrics, and licensee  
human performance results. The inspectors review nominally considered the 6 month  
period of July 2008 through December 2008, although some examples expanded  
beyond those dates where the scope of the trend warranted.  


    The inspectors compared and contrasted their results with the results contained in the
    licensees assessments. Corrective actions associated with a sample of the issues
    identified in the licensees trending reports were reviewed for adequacy.
19
    This review constituted a single semi-annual trend inspection sample as defined in
Enclosure
    IP 71152-05.
The inspectors compared and contrasted their results with the results contained in the  
  b. Findings
licensees assessments. Corrective actions associated with a sample of the issues  
    No findings of significance were identified.
identified in the licensees trending reports were reviewed for adequacy.  
.4   Annual Sample: Review of Operator Workarounds
This review constituted a single semi-annual trend inspection sample as defined in  
  a. Inspection Scope
IP 71152-05.  
    The inspectors evaluated the licensees implementation of their process used to identify,
b.  
    document, track, and resolve operational challenges. Inspection activities included, but
Findings  
    were not limited to, a review of the cumulative effects of the Operator Work Arounds on
No findings of significance were identified.  
    system availability and the potential for improper operation of the system, for potential
.4  
    impacts on multiple systems, and on the ability of operators to respond to plant
Annual Sample: Review of Operator Workarounds  
    transients or accidents.
a.  
    The inspectors performed a review of the cumulative effects of Operator Work Arounds.
Inspection Scope  
    The documents listed in the Attachment were reviewed to accomplish the objectives of
The inspectors evaluated the licensees implementation of their process used to identify,  
    the inspection procedure. The inspectors reviewed both current and historical
document, track, and resolve operational challenges. Inspection activities included, but  
    operational challenge records to determine whether the licensee was identifying operator
were not limited to, a review of the cumulative effects of the Operator Work Arounds on  
    challenges at an appropriate threshold, had entered them into their CAP, and proposed
system availability and the potential for improper operation of the system, for potential  
    or implemented appropriate and timely corrective actions which addressed each issue.
impacts on multiple systems, and on the ability of operators to respond to plant  
    Reviews were conducted to determine if any operator challenge could increase the
transients or accidents.  
    possibility of an Initiating Event, if the challenge was contrary to training, required a
The inspectors performed a review of the cumulative effects of Operator Work Arounds.
    change from long-standing operational practices, or created the potential for
The documents listed in the Attachment were reviewed to accomplish the objectives of  
    inappropriate compensatory actions. Additionally, all temporary modifications were
the inspection procedure. The inspectors reviewed both current and historical  
    reviewed to identify any potential effect on the functionality of Mitigating Systems,
operational challenge records to determine whether the licensee was identifying operator  
    impaired access to equipment, or required equipment uses for which the equipment was
challenges at an appropriate threshold, had entered them into their CAP, and proposed  
    not designed. Daily plant and equipment status logs, degraded instrument logs, and
or implemented appropriate and timely corrective actions which addressed each issue.
    operator aids or tools being used to compensate for material deficiencies were also
Reviews were conducted to determine if any operator challenge could increase the  
    assessed to identify any potential sources of unidentified operator workarounds.
possibility of an Initiating Event, if the challenge was contrary to training, required a  
    This review constituted one operator workaround annual inspection sample as defined in
change from long-standing operational practices, or created the potential for  
    IP 71152-05.
inappropriate compensatory actions. Additionally, all temporary modifications were  
  b. Findings
reviewed to identify any potential effect on the functionality of Mitigating Systems,  
    No findings of significance were identified.
impaired access to equipment, or required equipment uses for which the equipment was  
.5   Selected Issue Follow-Up Inspection: Criticality Controls in the Spent Fuel Pool
not designed. Daily plant and equipment status logs, degraded instrument logs, and  
  a. Inspection Scope
operator aids or tools being used to compensate for material deficiencies were also  
    In July of 2008, the licensee tested some spent fuel storage rack locations to determine
assessed to identify any potential sources of unidentified operator workarounds.  
    if the neutron poison built into the storage rack continued to meet assumptions in the
This review constituted one operator workaround annual inspection sample as defined in  
                                                      19                                  Enclosure
IP 71152-05.  
b.  
Findings  
No findings of significance were identified.  
.5  
Selected Issue Follow-Up Inspection: Criticality Controls in the Spent Fuel Pool  
a.  
Inspection Scope  
In July of 2008, the licensee tested some spent fuel storage rack locations to determine  
if the neutron poison built into the storage rack continued to meet assumptions in the  


    criticality analysis. The testing revealed that the neutron absorption capability of the
    Spent Fuel Pool racks had degraded and in some cases no longer met assumptions
    contained within the criticality analysis. The licensee implemented additional criticality
20
    controls in the spent fuel pool and informed the NRC of the controls by letter dated
Enclosure
    August 27, 2008. After reviewing the controls, the NRC issued Confirmatory Action
criticality analysis. The testing revealed that the neutron absorption capability of the  
    Letter (CAL) RIII-08-003 to confirm the commitments made by Entergy Nuclear
Spent Fuel Pool racks had degraded and in some cases no longer met assumptions  
    Operations.
contained within the criticality analysis. The licensee implemented additional criticality  
    During this inspection period, the inspectors validated that the licensee implemented the
controls in the spent fuel pool and informed the NRC of the controls by letter dated  
    requirements of the CAL. Specific actions included:
August 27, 2008. After reviewing the controls, the NRC issued Confirmatory Action  
    *         review of the licensees basis for criticality safety for proposed fuel moves;
Letter (CAL) RIII-08-003 to confirm the commitments made by Entergy Nuclear  
    *         verification that fuel moves complied with CAL requirements;
Operations.  
    *         observation of additional testing of the spent fuel pool neutron absorption
During this inspection period, the inspectors validated that the licensee implemented the  
              capability.
requirements of the CAL. Specific actions included:  
    The inspectors concluded that the licensee complied with the requirements of the CAL.
*  
    This review constituted one in-depth problem identification and resolution sample as
review of the licensees basis for criticality safety for proposed fuel moves;  
    defined in IP 71152-05.
*  
  b. Findings
verification that fuel moves complied with CAL requirements;  
    No findings of significance were identified.
*  
.6   Selected Issue Follow-Up Inspection: Deviation between Estimated and Actual Critical
observation of additional testing of the spent fuel pool neutron absorption  
    Positions for the August 9, 2008, Startup
capability.  
  a. Inspection Scope
The inspectors concluded that the licensee complied with the requirements of the CAL.
    The inspectors reviewed the data and associated procedures for the August 9, 2008,
This review constituted one in-depth problem identification and resolution sample as  
    reactor startup from a forced outage. The inspectors also interviewed licensee staff and
defined in IP 71152-05.  
    searched for relevant operating experience and past similar issues identified by the NRC
b.  
    at other plants. Corrective action documents related to the issue were reviewed for
Findings  
    appropriate categorization and action. During the August 9, 2008, reactor startup, the
No findings of significance were identified.  
    reactor attained criticality with rods withdrawn to a position of 0.28 percent delta rho
.6  
    above that predicted by the estimated critical position. Although the deviation was below
Selected Issue Follow-Up Inspection: Deviation between Estimated and Actual Critical  
    the TS limit of 1 percent delta rho and the licensee administrative limit of 0.5 percent
Positions for the August 9, 2008, Startup  
    delta rho, the deviation was abnormally high. The licensee reviewed the error in
a.  
    condition report CR-PLP-2008-3439. The cause evaluation concluded the error
Inspection Scope  
    occurred due to boron 10 depletion in the primary coolant system. B-10 depletion
The inspectors reviewed the data and associated procedures for the August 9, 2008,  
    occurs due to B-10 burnup via neutron absorption. Naturally occurring boron contains
reactor startup from a forced outage. The inspectors also interviewed licensee staff and  
    19.8 atom percent B-10 with the remainder B-11. As B-10 (which has a much larger
searched for relevant operating experience and past similar issues identified by the NRC  
    neutron absorption cross-section) absorbs neutrons, the ratio of B-10 to B-11 decreases.
at other plants. Corrective action documents related to the issue were reviewed for  
    This change alters the effective boron poison strength of the primary coolant for a given
appropriate categorization and action. During the August 9, 2008, reactor startup, the  
    boron concentration. When fresh boron is added, the effective boron concentration
reactor attained criticality with rods withdrawn to a position of 0.28 percent delta rho  
    changes. In this instance, the licensee added fresh boron during the shutdown but did
above that predicted by the estimated critical position. Although the deviation was below  
    not account for it while determining an estimated critical position. As part of the
the TS limit of 1 percent delta rho and the licensee administrative limit of 0.5 percent  
    corrective actions, the licensee identified several items to help address this issue. The
delta rho, the deviation was abnormally high. The licensee reviewed the error in  
    licensee did have some guidance in EM-04-24, their Critical Prediction and Critical
condition report CR-PLP-2008-3439. The cause evaluation concluded the error  
    Approach procedure, in regards to when to apply a B-10 correction. The licensee plans
occurred due to boron 10 depletion in the primary coolant system. B-10 depletion  
                                                    20                                  Enclosure
occurs due to B-10 burnup via neutron absorption. Naturally occurring boron contains  
19.8 atom percent B-10 with the remainder B-11. As B-10 (which has a much larger  
neutron absorption cross-section) absorbs neutrons, the ratio of B-10 to B-11 decreases.
This change alters the effective boron poison strength of the primary coolant for a given  
boron concentration. When fresh boron is added, the effective boron concentration  
changes. In this instance, the licensee added fresh boron during the shutdown but did  
not account for it while determining an estimated critical position. As part of the  
corrective actions, the licensee identified several items to help address this issue. The  
licensee did have some guidance in EM-04-24, their Critical Prediction and Critical  
Approach procedure, in regards to when to apply a B-10 correction. The licensee plans  


    to enhance this portion of the procedure for clarity and ease of conducting a B-10
    correction, if deemed necessary. In addition, the licensee benchmarked other fleet
    plants to determine an optimum isotopic sampling frequency to track the depletion of
21
    B-10. The licensee is proceeding with plans to obtain and ship samples for analysis
Enclosure
    more frequently.
to enhance this portion of the procedure for clarity and ease of conducting a B-10  
    Based on data provided by the licensee, the last time there was a deviation of this
correction, if deemed necessary. In addition, the licensee benchmarked other fleet  
    magnitude or greater was June 1998 with a 0.393 percent delta rho error. Beyond that,
plants to determine an optimum isotopic sampling frequency to track the depletion of  
    in October 1997 there was a 0.437 percent deviation. The October 1997 deviation was
B-10. The licensee is proceeding with plans to obtain and ship samples for analysis  
    determined to be mostly due to B-10 depletion. A search for relevant operating
more frequently.  
    experience and previous findings was conducted with no relevant results. The
Based on data provided by the licensee, the last time there was a deviation of this  
    inspectors reviewed the licensees reactivity management event classification guidelines
magnitude or greater was June 1998 with a 0.393 percent delta rho error. Beyond that,  
    and corrective action process procedure to validate appropriate categorization of the
in October 1997 there was a 0.437 percent deviation. The October 1997 deviation was  
    issue. No deficiencies were identified.
determined to be mostly due to B-10 depletion. A search for relevant operating  
    This review constituted one in-depth problem identification and resolution sample as
experience and previous findings was conducted with no relevant results. The  
    defined in IP 71152-05.
inspectors reviewed the licensees reactivity management event classification guidelines  
.7   Selected Issue Follow-Up Inspection: Licensee Compliance with the Station Blackout
and corrective action process procedure to validate appropriate categorization of the  
    (SBO) Rule Assumptions
issue. No deficiencies were identified.  
  a. Inspection Scope
This review constituted one in-depth problem identification and resolution sample as  
    While performing an operability evaluation on inadequate testing of the CR HVAC
defined in IP 71152-05.  
    system (discussed in Section 1R15 of this report), the inspectors noted that the
.7  
    licensees revision to the underlying calculation for the systems surveillance test may
Selected Issue Follow-Up Inspection: Licensee Compliance with the Station Blackout  
    not have taken into account SBO Rule (10 CFR 50.63) requirements. The inspectors
(SBO) Rule Assumptions  
    interviewed licensee personnel and reviewed design basis documents, the UFSAR, and
a.  
    docketed correspondence between the NRC and the licensee. The inspectors review
Inspection Scope  
    included the analysis performed by the licensee to demonstrate compliance with the
While performing an operability evaluation on inadequate testing of the CR HVAC  
    SBO rule. Based on the review, the inspectors concluded the licensee remained
system (discussed in Section 1R15 of this report), the inspectors noted that the  
    compliant with the license condition for SBO but noted weaknesses in the licensees
licensees revision to the underlying calculation for the systems surveillance test may  
    program. Noted weaknesses included:
not have taken into account SBO Rule (10 CFR 50.63) requirements. The inspectors  
    *       Lack of operations staff awareness of impacts on SBO rule compliance with
interviewed licensee personnel and reviewed design basis documents, the UFSAR, and  
            elevated temperatures in the control room
docketed correspondence between the NRC and the licensee. The inspectors review  
    *       Lack of programmatic controls for maintaining compliance with the plants SBO
included the analysis performed by the licensee to demonstrate compliance with the  
            assumptions
SBO rule. Based on the review, the inspectors concluded the licensee remained  
    The licensee generated two condition reports (CR-PLP-2008-5023 and
compliant with the license condition for SBO but noted weaknesses in the licensees  
    CR-PLP-2008-5074) to address the issue.
program. Noted weaknesses included:  
    This review constituted one in-depth problem identification and resolution sample as
*  
    defined in IP 71152-05.
Lack of operations staff awareness of impacts on SBO rule compliance with  
  b. Findings
elevated temperatures in the control room  
    No findings of significance were identified.
*  
                                                  21                                  Enclosure
Lack of programmatic controls for maintaining compliance with the plants SBO  
assumptions  
The licensee generated two condition reports (CR-PLP-2008-5023 and  
CR-PLP-2008-5074) to address the issue.  
This review constituted one in-depth problem identification and resolution sample as  
defined in IP 71152-05.  
    b.   Findings  
No findings of significance were identified.  


4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)
.1   (Closed) LER 05000255/2008-05-00, Completion of Plant Shutdown Required by TSs
      On August 5, 2008, the licensee began a planned shutdown to replace leaking Control
22
      Rod Drive Mechanism seals. At 97 percent power, a relief valve, RV-2006, in the
Enclosure
      letdown system lifted resulting in primary coolant leakage in excess of the TS limit of
4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)  
      1 gallon per minute of unidentified leakage. The licensee made a 4-hour report to the
.1  
      NRC and completed a plant shutdown as required by TSs. The licensee determined that
(Closed) LER 05000255/2008-05-00, Completion of Plant Shutdown Required by TSs  
      the relief valve lifted when a second charging pump started per the pressurizer level
On August 5, 2008, the licensee began a planned shutdown to replace leaking Control  
      control program. Historically, the licensee has experienced difficulties with control of
Rod Drive Mechanism seals. At 97 percent power, a relief valve, RV-2006, in the  
      pressure in the letdown system during operation of charging pumps due to performance
letdown system lifted resulting in primary coolant leakage in excess of the TS limit of  
      of controllers in the system. In addition, the licensee determined that the setpoint of the
1 gallon per minute of unidentified leakage. The licensee made a 4-hour report to the  
      relief valve will drift as a result of previous relief valve lifts. During the outage, the
NRC and completed a plant shutdown as required by TSs. The licensee determined that  
      licensee replaced the relief valve. In this event, leak rates of approximately 4 gallons per
the relief valve lifted when a second charging pump started per the pressurizer level  
      minute occurred when the relief valve lifted. Because the line discharged into a quench
control program. Historically, the licensee has experienced difficulties with control of  
      tank with multiple sources, the licensee treated the leakage as unidentified leakage. The
pressure in the letdown system during operation of charging pumps due to performance  
      licensee exited the Limiting Condition for Operation (LCO) when the plant entered
of controllers in the system. In addition, the licensee determined that the setpoint of the  
      Mode 5 and the LCO no longer applied. Documents reviewed as part of this inspection
relief valve will drift as a result of previous relief valve lifts. During the outage, the  
      are listed in the Attachment. The inspectors did not identify any additional safety issues.
licensee replaced the relief valve. In this event, leak rates of approximately 4 gallons per  
      This LER is closed.
minute occurred when the relief valve lifted. Because the line discharged into a quench  
      This event follow-up review constituted one sample as defined in IP 71153-05.
tank with multiple sources, the licensee treated the leakage as unidentified leakage. The  
.2   (Closed) LER 05000255/2008-06-00, Emergency Diesel Generator Inoperable in Excess
licensee exited the Limiting Condition for Operation (LCO) when the plant entered  
      of TSs Requirements
Mode 5 and the LCO no longer applied. Documents reviewed as part of this inspection  
  a. Inspection Scope
are listed in the Attachment. The inspectors did not identify any additional safety issues.
      On February 19, 2008, during performance of planned maintenance on the 1-2 EDG,
This LER is closed.  
      licensee personnel discovered foreign material (metal fragments) in the valve assembly
This event follow-up review constituted one sample as defined in IP 71153-05.  
      area of the 1-2 EDG cylinder 2L. The metal fragments were identified to be broken
.2  
      pieces of the valve seat spring lock associated with the cylinder 2L inboard exhaust
(Closed) LER 05000255/2008-06-00, Emergency Diesel Generator Inoperable in Excess  
      valve. These fragments were discovered by workers during an unrelated maintenance
of TSs Requirements  
      activity involving the snubber valves. Due to some physical interference between
a.  
      components during work, the valve cover for cylinder 2L needed to be removed to
Inspection Scope  
      complete some of the snubber valve maintenance. When the cover was removed,
On February 19, 2008, during performance of planned maintenance on the 1-2 EDG,  
      workers noted the spring lock material described above. The licensee performed an
licensee personnel discovered foreign material (metal fragments) in the valve assembly  
      apparent cause evaluation that included a failure analysis performed by Fairbanks
area of the 1-2 EDG cylinder 2L. The metal fragments were identified to be broken  
      Morse Engine. The licensee determined that the spring lock was damaged due to a
pieces of the valve seat spring lock associated with the cylinder 2L inboard exhaust  
      condition discovered in March 2000. While performing maintenance on March 21, 2000,
valve. These fragments were discovered by workers during an unrelated maintenance  
      licensee personnel discovered that the valve yoke retaining lock nut had fallen off one of
activity involving the snubber valves. Due to some physical interference between  
      the valve assemblies for cylinder 2L. The licensee determined that because of this, the
components during work, the valve cover for cylinder 2L needed to be removed to  
      adjusting screw backed out such that the valve yoke was able to strike the spring seat
complete some of the snubber valve maintenance. When the cover was removed,  
      instead of the adjusting nut striking the valve stem, as designed. This resulted in cyclical
workers noted the spring lock material described above. The licensee performed an  
      side loading of the valve assembly which initiated a fatigue crack on the inside diameter
apparent cause evaluation that included a failure analysis performed by Fairbanks  
      of the spring lock. Eventually it failed, resulting in the pieces discovered on
Morse Engine. The licensee determined that the spring lock was damaged due to a  
      February 19, 2008. The licensee inspected the other spring locks on the 1-2 EDG and
condition discovered in March 2000. While performing maintenance on March 21, 2000,  
      found no discrepancies. An extent-of-condition review was performed for the 1-1 EDG
licensee personnel discovered that the valve yoke retaining lock nut had fallen off one of  
      by the licensee. The licensee concluded that there was high assurance that a similar
the valve assemblies for cylinder 2L. The licensee determined that because of this, the  
                                                      22                                    Enclosure
adjusting screw backed out such that the valve yoke was able to strike the spring seat  
instead of the adjusting nut striking the valve stem, as designed. This resulted in cyclical  
side loading of the valve assembly which initiated a fatigue crack on the inside diameter  
of the spring lock. Eventually it failed, resulting in the pieces discovered on  
February 19, 2008. The licensee inspected the other spring locks on the 1-2 EDG and  
found no discrepancies. An extent-of-condition review was performed for the 1-1 EDG  
by the licensee. The licensee concluded that there was high assurance that a similar  


  condition does not exist on the 1-1 EDG. The licensee plans to inspect valve seat spring
  locks for the 1-1 EDG during the next scheduled preventative maintenance outage.
  The licensee reviewed the corrective actions for the March 2000 discovery of the lock
23
  nut that fell off and the associated backing-out of the adjusting screw. To resolve the
Enclosure
  issue, the nut was returned to the proper position and torqued. In addition, the other
condition does not exist on the 1-1 EDG. The licensee plans to inspect valve seat spring  
  retaining nuts were inspected and found to be acceptable. There were no documented
locks for the 1-1 EDG during the next scheduled preventative maintenance outage.  
  inspections of any other components in the valve assembly area under the valve cover.
The licensee reviewed the corrective actions for the March 2000 discovery of the lock  
  Following the discovery, the licensee did not change the routine preventative
nut that fell off and the associated backing-out of the adjusting screw. To resolve the  
  maintenance requirements. The inspectors identified one finding. This LER is closed.
issue, the nut was returned to the proper position and torqued. In addition, the other  
  This event follow-up review constituted one sample as defined in IP 71153-05.
retaining nuts were inspected and found to be acceptable. There were no documented  
b. Findings
inspections of any other components in the valve assembly area under the valve cover.
  Introduction: On February 19, 2008, a Green self-revealed finding and associated NCV
Following the discovery, the licensee did not change the routine preventative  
  of TS requirement 3.8.1.b became evident when licensee personnel discovered metal
maintenance requirements. The inspectors identified one finding. This LER is closed.
  fragments in the valve assembly area of the 1-2 EDG cylinder 2L. Subsequent
This event follow-up review constituted one sample as defined in IP 71153-05.  
  evaluation by the licensee determined that the diesel would not be able to function for its
b.  
  30-day mission time and was inoperable for a period of time greater than allowed by TS.
Findings  
  Description: While performing maintenance on the 1-2 EDG, licensee personnel noted
Introduction: On February 19, 2008, a Green self-revealed finding and associated NCV  
  metal fragments in the valve cover for the 1-2 EDG. The licensee investigated the
of TS requirement 3.8.1.b became evident when licensee personnel discovered metal  
  source of the metal fragments and discovered that the spring lock for an exhaust valve
fragments in the valve assembly area of the 1-2 EDG cylinder 2L. Subsequent  
  had failed. The licensee reviewed maintenance history for the diesel and determined
evaluation by the licensee determined that the diesel would not be able to function for its  
  that a lock nut had backed off an adjustment screw in 2000. The licensee contracted the
30-day mission time and was inoperable for a period of time greater than allowed by TS.  
  diesel vendor to evaluate the condition of the cylinder head in order to determine the
Description: While performing maintenance on the 1-2 EDG, licensee personnel noted  
  cause of the spring lock failure. The vendor concluded that the loss of the lock nut
metal fragments in the valve cover for the 1-2 EDG. The licensee investigated the  
  caused the adjusting screw to drift and allowed the yoke arm to contact the valve spring
source of the metal fragments and discovered that the spring lock for an exhaust valve  
  seat. The abnormal operating condition likely created cracks in the spring lock that
had failed. The licensee reviewed maintenance history for the diesel and determined  
  propagated even after replacement of the lock nut. In 2000, the licensee limited
that a lock nut had backed off an adjustment screw in 2000. The licensee contracted the  
  corrective actions to replacing the lock nut and checking the lock nuts on other cylinders.
diesel vendor to evaluate the condition of the cylinder head in order to determine the  
  The licensee did not evaluate potential degradation of other components due to the
cause of the spring lock failure. The vendor concluded that the loss of the lock nut  
  abnormal operation of the valve.
caused the adjusting screw to drift and allowed the yoke arm to contact the valve spring  
  The licensee evaluated the as-found condition and concluded that a sufficient amount of
seat. The abnormal operating condition likely created cracks in the spring lock that  
  the spring lock remained on the valve to assure continued operation of the EDG for at
propagated even after replacement of the lock nut. In 2000, the licensee limited  
  least 24 hours. However, the wear rates could not be determined to assure the EDG
corrective actions to replacing the lock nut and checking the lock nuts on other cylinders.
  would operate for 30 days. The licensee identified that a potential failure mode was loss
The licensee did not evaluate potential degradation of other components due to the  
  of the valve into the associated cylinder and subsequent damage to the turbo charger
abnormal operation of the valve.  
  through transport of generated debris. As corrective action, the licensee replaced the
The licensee evaluated the as-found condition and concluded that a sufficient amount of  
  spring lock and inspected the others on the 1-2 EDG. An extent of condition was
the spring lock remained on the valve to assure continued operation of the EDG for at  
  performed for the 1-1 EDG, and inspections are planned for the 1-1 EDG as well. The
least 24 hours. However, the wear rates could not be determined to assure the EDG  
  condition was entered into the licensees CAP as CR-PLP-2008-0822.
would operate for 30 days. The licensee identified that a potential failure mode was loss  
  Analysis: The inspectors determined that the inoperability of the diesel generator for
of the valve into the associated cylinder and subsequent damage to the turbo charger  
  longer than TS allowed outage time represented a performance deficiency that
through transport of generated debris. As corrective action, the licensee replaced the  
  warranted a significance determination. Through review of the condition reports related
spring lock and inspected the others on the 1-2 EDG. An extent of condition was  
  to the missing lock nut in 2000, the inspectors determined that the licensee could
performed for the 1-1 EDG, and inspections are planned for the 1-1 EDG as well. The  
  reasonably be expected to foresee and correct the condition of the cylinder/valve
condition was entered into the licensees CAP as CR-PLP-2008-0822.
  operating mechanism. In 2000, the licensee did not evaluate potential adverse effects
Analysis: The inspectors determined that the inoperability of the diesel generator for  
                                                23                                  Enclosure
longer than TS allowed outage time represented a performance deficiency that  
warranted a significance determination. Through review of the condition reports related  
to the missing lock nut in 2000, the inspectors determined that the licensee could  
reasonably be expected to foresee and correct the condition of the cylinder/valve  
operating mechanism. In 2000, the licensee did not evaluate potential adverse effects  


      on the valve and related components. Corrective actions at the time also indicated the
      remaining lock nuts were only checked hand-tight. The inspectors determined the issue
      is more than minor because it affected the mitigating system cornerstone objective of
24
      ensuring the reliability and capability of mitigating systems. The inspectors performed a
Enclosure
      phase 1 screen on the issue in accordance with IMC 0609 and determined that since the
on the valve and related components. Corrective actions at the time also indicated the  
      EDG was inoperable for greater than the TS allowed outage time, support from the
remaining lock nuts were only checked hand-tight. The inspectors determined the issue  
      region-based senior risk analyst was needed to determine risk significance. Based on
is more than minor because it affected the mitigating system cornerstone objective of  
      vendor analysis, the licensee concluded that the EDG would likely operate in excess of
ensuring the reliability and capability of mitigating systems. The inspectors performed a  
      24 hours, but not for the 30-day mission time required by the license. Since the EDG
phase 1 screen on the issue in accordance with IMC 0609 and determined that since the  
      would function for the Probable Risk Assessment mission time, the senior risk analyst
EDG was inoperable for greater than the TS allowed outage time, support from the  
      determined the issue would screen as Green using the phase 1 worksheets. No cross-
region-based senior risk analyst was needed to determine risk significance. Based on  
      cutting aspect was assigned because the review dated back to 2000, therefore, this
vendor analysis, the licensee concluded that the EDG would likely operate in excess of  
      issue is not indicative of current plant performance.
24 hours, but not for the 30-day mission time required by the license. Since the EDG  
      Enforcement: Technical Specification LCO 3.8.1 states, in part, that two diesel
would function for the Probable Risk Assessment mission time, the senior risk analyst  
      generators each capable of supplying one train of the Class 1E AC electrical power
determined the issue would screen as Green using the phase 1 worksheets. No cross-
      distribution system shall be operable. The TS action requirement requires a plant
cutting aspect was assigned because the review dated back to 2000, therefore, this  
      shutdown if the associated EDG is inoperable for greater than 7 days. Contrary to the
issue is not indicative of current plant performance.  
      required action statements, on February 19, 2008, a failed spring lock for one of the
Enforcement: Technical Specification LCO 3.8.1 states, in part, that two diesel  
      exhaust valves on the 1-2 EDG was discovered. This resulted in an EDG inoperability
generators each capable of supplying one train of the Class 1E AC electrical power  
      beyond the allowed required action times. The failure was determined to have been the
distribution system shall be operable. The TS action requirement requires a plant  
      result of an issue discovered in 2000 involving a lock nut that had fallen off of the
shutdown if the associated EDG is inoperable for greater than 7 days. Contrary to the  
      exhaust valve assembly. Further analysis led to a conclusion by the licensee that the
required action statements, on February 19, 2008, a failed spring lock for one of the  
      condition would likely allow the EDG to run for the 24-hour Probabilistic Risk
exhaust valves on the 1-2 EDG was discovered. This resulted in an EDG inoperability  
      Assessment mission time but not the 30-day mission time. Because the finding is of
beyond the allowed required action times. The failure was determined to have been the  
      very low safety significance and has been entered into the licensees CAP as
result of an issue discovered in 2000 involving a lock nut that had fallen off of the  
      CR-2008-0822, this violation of TS requirement 3.8.1.b is being treated as an NCV,
exhaust valve assembly. Further analysis led to a conclusion by the licensee that the  
      consistent with Section VI.A of the NRC Enforcement Policy.
condition would likely allow the EDG to run for the 24-hour Probabilistic Risk  
      (NCV 05000255/2008005-02 Emergency Diesel Generator Inoperable in Excess of
Assessment mission time but not the 30-day mission time. Because the finding is of  
      TS Requirements).
very low safety significance and has been entered into the licensees CAP as  
4OA5 Other Activities
CR-2008-0822, this violation of TS requirement 3.8.1.b is being treated as an NCV,  
.1   Observations of Security
consistent with Section VI.A of the NRC Enforcement Policy.
  a. Inspection Scope
(NCV 05000255/2008005-02 Emergency Diesel Generator Inoperable in Excess of  
      During the inspection period, the inspectors conducted observations of security force
TS Requirements).  
      personnel and activities to ensure that the activities were consistent with licensee
4OA5 Other Activities  
      security procedures and regulatory requirements relating to nuclear plant security.
.1  
      These observations took place during both normal and off-normal plant working hours.
Observations of Security  
      These quarterly resident inspector observations of security force personnel and activities
a.  
      did not constitute any additional inspection samples. Rather, they were considered an
Inspection Scope  
      integral part of the inspectors' normal plant status review and inspection activities.
During the inspection period, the inspectors conducted observations of security force  
  b. Findings
personnel and activities to ensure that the activities were consistent with licensee  
      No findings of significance were identified.
security procedures and regulatory requirements relating to nuclear plant security.
                                                    24                                  Enclosure
These observations took place during both normal and off-normal plant working hours.  
These quarterly resident inspector observations of security force personnel and activities  
did not constitute any additional inspection samples. Rather, they were considered an  
integral part of the inspectors' normal plant status review and inspection activities.  
b.  
Findings  
No findings of significance were identified.  


  .2   Implementation of Temporary Instruction (TI) 2515/176, Emergency Diesel generator
   
      Technical Specification Surveillance Requirements Regarding Endurance and Margin
      testing
25
    a. Inspection Scope
Enclosure
        The objective of TI 2515/176 was to gather information to assess the adequacy of
.2  
      nuclear power plant emergency diesel generator endurance and margin testing as
Implementation of Temporary Instruction (TI) 2515/176, Emergency Diesel generator  
      prescribed in plant-specific TSs. The inspectors reviewed the licensee's TS,
Technical Specification Surveillance Requirements Regarding Endurance and Margin  
      procedures, and calculations, and interviewed licensee personnel to complete the TI.
testing  
      The information gathered for this TI was forwarded to the Office of Nuclear Reactor
a. Inspection Scope  
      Regulation for further review and evaluation on December 17, 2008. This TI is
The objective of TI 2515/176 was to gather information to assess the adequacy of  
      complete at Palisades Nuclear Plant; however, this TI 2515/176 will not expire until
nuclear power plant emergency diesel generator endurance and margin testing as  
      August 31, 2009. Additional information may be required after review by the Office of
prescribed in plant-specific TSs. The inspectors reviewed the licensee's TS,  
      Nuclear Reactor Regulation.
procedures, and calculations, and interviewed licensee personnel to complete the TI.
    b. Findings
The information gathered for this TI was forwarded to the Office of Nuclear Reactor  
      No findings of significance were identified.
Regulation for further review and evaluation on December 17, 2008. This TI is  
4OA6 Management Meetings
complete at Palisades Nuclear Plant; however, this TI 2515/176 will not expire until  
.1   Exit Meeting Summary
August 31, 2009. Additional information may be required after review by the Office of  
      On January 22, 2009, the inspectors presented the inspection results to Thomas Kirwin
Nuclear Reactor Regulation.  
      and other members of the licensee staff. The licensee acknowledged the issues
b. Findings  
      presented. The inspectors confirmed that none of the potential report input discussed
No findings of significance were identified.  
      was considered proprietary. A follow-up phone exit meeting was held by the NRC with
4OA6 Management Meetings  
      Ms. B. Dotson and Mr. C. Sherman on February 2, 2009 to discuss additional inspection
.1  
      results.
Exit Meeting Summary  
.2   Interim Exit Meetings
On January 22, 2009, the inspectors presented the inspection results to Thomas Kirwin  
      Interim exits were conducted for:
and other members of the licensee staff. The licensee acknowledged the issues  
      *       The annual review of emergency action level and emergency plan changes with
presented. The inspectors confirmed that none of the potential report input discussed  
                the licensee's Senior Emergency Planning Coordinator, Mr. M. Sweet via
was considered proprietary. A follow-up phone exit meeting was held by the NRC with  
                telephone on December 30, 2008.
Ms. B. Dotson and Mr. C. Sherman on February 2, 2009 to discuss additional inspection  
      *       The results of the access control to radiologically significant areas inspection with
results.  
                the Plant Manager, Mr. T. Kirwin, and other members of your staff, on
.2  
                December 12, 2008.
Interim Exit Meetings  
      *       A telephone exit for TI 2515/176 was conducted with John Broschak,
Interim exits were conducted for:  
                Entergy/Engineering Director and other Licensee staff on December 2, 2008.
*  
      The inspectors confirmed that none of the potential report input discussed was
The annual review of emergency action level and emergency plan changes with  
      considered proprietary.
the licensee's Senior Emergency Planning Coordinator, Mr. M. Sweet via  
                                                    25                                    Enclosure
telephone on December 30, 2008.  
*  
The results of the access control to radiologically significant areas inspection with  
the Plant Manager, Mr. T. Kirwin, and other members of your staff, on  
December 12, 2008.  
*  
A telephone exit for TI 2515/176 was conducted with John Broschak,  
Entergy/Engineering Director and other Licensee staff on December 2, 2008.  
The inspectors confirmed that none of the potential report input discussed was  
considered proprietary.  


4OA7 Licensee-Identified Violations
    The following violation of very low significance (Green) were identified by the licensee
    and are violations of NRC requirements which meet the criteria of Section VI of the
26
    NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.
Enclosure
    *   Technical Specification 5.7.1 requires areas with dose rates greater than
4OA7 Licensee-Identified Violations  
          100 mR/hr to be posted as a High Radiation Area and barricaded. Contrary to this,
The following violation of very low significance (Green) were identified by the licensee  
          on October 18, 2008, the high radiation area posting and barricade did not provide
and are violations of NRC requirements which meet the criteria of Section VI of the  
          an adequate barricade around areas of the room having dose rates greater than
NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.  
          100 mR/hr in the west engineered safeguards room. This was identified in the
*  
          licensees corrective action program as CR-PLP-2008-04310. The finding was
Technical Specification 5.7.1 requires areas with dose rates greater than  
          determined to be of very low safety significance because it was not an ALARA
100 mR/hr to be posted as a High Radiation Area and barricaded. Contrary to this,  
          planning issue, there was no overexposure nor substantial potential for
on October 18, 2008, the high radiation area posting and barricade did not provide  
          overexposure, and the licensees ability to assess dose was not compromised.
an adequate barricade around areas of the room having dose rates greater than  
ATTACHMENT: SUPPLEMENTAL INFORMATION
100 mR/hr in the west engineered safeguards room. This was identified in the  
                                                  26                                  Enclosure
licensees corrective action program as CR-PLP-2008-04310. The finding was  
determined to be of very low safety significance because it was not an ALARA  
planning issue, there was no overexposure nor substantial potential for  
overexposure, and the licensees ability to assess dose was not compromised.  
ATTACHMENT: SUPPLEMENTAL INFORMATION


                              SUPPLEMENTAL INFORMATION
                                  KEY POINTS OF CONTACT
Licensee
1
C. Schwarz, Site Vice President
Attachment
V. Beilfuss, Project Manager
SUPPLEMENTAL INFORMATION  
J. Broschak, Engineering Director
KEY POINTS OF CONTACT
N. Brott, Emergency Preparedness Coordinator
Licensee  
J. Burnett, RETS/REMP Specialist
C. Schwarz, Site Vice President
T. Davis, Regulatory Compliance
V. Beilfuss, Project Manager  
B. Dotson, Regulatory Compliance
J. Broschak, Engineering Director  
J. Fontaine, Senior Emergency Planning Coordinator
N. Brott, Emergency Preparedness Coordinator  
J. Ford, Corrective Action Manager
J. Burnett, RETS/REMP Specialist  
T. Kirwin, Plant General Manager
T. Davis, Regulatory Compliance  
L. Lahti, Licensing Manager
B. Dotson, Regulatory Compliance  
B. Nixon, Assistant Operations Manager
J. Fontaine, Senior Emergency Planning Coordinator  
T. Shewmaker, Chemistry Manager
J. Ford, Corrective Action Manager  
C. Sherman, Radiation Protection Manager
T. Kirwin, Plant General Manager  
M. Sicard, Operations Manager
L. Lahti, Licensing Manager  
G. Sleeper, Assistant Operations Manager
B. Nixon, Assistant Operations Manager  
E. Williams, Radiation Protection Supervisor
T. Shewmaker, Chemistry Manager  
Nuclear Regulatory Commission
C. Sherman, Radiation Protection Manager  
J. Giessner, Chief, Branch 4
M. Sicard, Operations Manager  
                                                1      Attachment
G. Sleeper, Assistant Operations Manager  
E. Williams, Radiation Protection Supervisor  
Nuclear Regulatory Commission  
J. Giessner, Chief, Branch 4  


                LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000255/2008005-01   NCV   Inadequate Testing of Control Room Chillers (Section 1R15)
2
05000255/2008005-02   NCV   Emergency Diesel Generator Inoperable in Excess of
Attachment
                            Technical Specification Requirements (Section 4OA3)
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED  
Closed
Opened  
05000255/2008005-01   NCV   Inadequate Testing of Control Room Chillers (Section 1R15)
05000255/2008005-01  
05000255/2008005-02   NCV   Emergency Diesel Generator Inoperable in Excess of
NCV  
                            Technical Specification Requirements (Section 4OA3)
Inadequate Testing of Control Room Chillers (Section 1R15)  
05000255/2008005       LER   Completion of Plant Shutdown Required by Technical
05000255/2008005-02  
                            Specifications (Section 4OA3)
NCV  
05000255/2008006       LER   Emergency Diesel Generator Inoperable in Excess of
Emergency Diesel Generator Inoperable in Excess of  
                            Technical Specification Requirements (Section 4OA3)
Technical Specification Requirements (Section 4OA3)  
                                              2                              Attachment
Closed  
05000255/2008005-01  
NCV  
Inadequate Testing of Control Room Chillers (Section 1R15)  
05000255/2008005-02  
NCV  
Emergency Diesel Generator Inoperable in Excess of  
Technical Specification Requirements (Section 4OA3)  
05000255/2008005  
LER  
Completion of Plant Shutdown Required by Technical  
Specifications (Section 4OA3)  
05000255/2008006  
LER  
Emergency Diesel Generator Inoperable in Excess of  
Technical Specification Requirements (Section 4OA3)  


                                  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
3
selected sections or portions of the documents were evaluated as part of the overall inspection
Attachment
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
LIST OF DOCUMENTS REVIEWED  
any part of it, unless this is stated in the body of the inspection report.
The following is a partial list of documents reviewed during the inspection. Inclusion on this list  
1R01 Adverse Weather Protection
does not imply that the NRC inspector reviewed the documents in their entirety, but rather that  
- CR-PLP-2007-5672, 1-3 DG cold weather vent covers fall out of the vents, November 7, 2007
selected sections or portions of the documents were evaluated as part of the overall inspection  
- CR-PLP-2007-5934, The Insulating Box for SIRW Tank Level Instrument LT-0331 is Bent,
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or  
  November 21, 2007
any part of it, unless this is stated in the body of the inspection report.  
- SOP-23, Plant Heating System, Revision 27
1R04 Equipment Alignment
1R01 Adverse Weather Protection  
- Drawing M-204, Safety Injection, Containment Spray, and Shutdown Cooling System
- CR-PLP-2007-5672, 1-3 DG cold weather vent covers fall out of the vents, November 7, 2007  
- Drawing M-208, Service Water System
- CR-PLP-2007-5934, The Insulating Box for SIRW Tank Level Instrument LT-0331 is Bent,  
- Drawing M-213, Service Water, Screen Structure, and Chlorinator
November 21, 2007  
- FSAR Chapter 9.1.1, Service Water System, Revision 25
- SOP-23, Plant Heating System, Revision 27  
- Procedure No. 4.02, Control of Equipment, Revision 47
1R04 Equipment Alignment
- SOP-15, Service Water System, Revision 47
- Drawing M-204, Safety Injection, Containment Spray, and Shutdown Cooling System  
- SOP-22, Emergency Diesel Generators, Revision 45
- Drawing M-208, Service Water System  
- SOP-3, High Pressure Safety Injection System, Revision 75
- Drawing M-213, Service Water, Screen Structure, and Chlorinator  
1R05 Fire Protection
- FSAR Chapter 9.1.1, Service Water System, Revision 25  
- Fire Hazard Analysis, Palisades Plant, Revision 7
- Procedure No. 4.02, Control of Equipment, Revision 47  
1R11 Licensed Operator Requalification Program
- SOP-15, Service Water System, Revision 47  
- Procedure SEP, Site Emergency Plan, Revision 16
- SOP-22, Emergency Diesel Generators, Revision 45  
- Simulator Exercise Guide for November 17, 2008 Licensed Operator Requalification Drill
- SOP-3, High Pressure Safety Injection System, Revision 75  
1R12 Maintenance Effectiveness
1R05 Fire Protection
- CR-PLP-2007-01807, K-6B Placed in Maintenance Rule Category a(1), May 3, 2007
- Fire Hazard Analysis, Palisades Plant, Revision 7
- CR-PLP-2007-01145, K-6B exceeds Maintenance Rule Unavailability Hours, March 13, 2007
1R11 Licensed Operator Requalification Program
- CR-PLP-2008-01424, EG-30A, 1-2 Emergency Diesel Generator Alarm Panel Failure (K-6B),
- Procedure SEP, Site Emergency Plan, Revision 16  
  March 28, 2008
- Simulator Exercise Guide for November 17, 2008 Licensed Operator Requalification Drill  
- CR-PLP-2008-03141, During the Performance of MO-7A-2, Emergency Diesel Generator 1-2,
1R12 Maintenance Effectiveness
  Difficulties were Encountered in Attempting to Match Generator Output Voltage to Match Bus
- CR-PLP-2007-01807, K-6B Placed in Maintenance Rule Category a(1), May 3, 2007  
  1D Voltage, July 21, 2008
- CR-PLP-2007-01145, K-6B exceeds Maintenance Rule Unavailability Hours, March 13, 2007  
- CR-PLP-2008-03142, While Increasing Load on 1-2 Diesel Generator, the Cyclinder Petcock
- CR-PLP-2008-01424, EG-30A, 1-2 Emergency Diesel Generator Alarm Panel Failure (K-6B),  
  for 9R Came Open, July 21, 2008
March 28, 2008  
- CR-PLP-2008-03141, During the Performance of MO-7A-2, Emergency Diesel Generator 1-2,  
Difficulties were Encountered in Attempting to Match Generator Output Voltage to Match Bus  
1D Voltage, July 21, 2008  
- CR-PLP-2008-03142, While Increasing Load on 1-2 Diesel Generator, the Cyclinder Petcock  
for 9R Came Open, July 21, 2008  
- CR-PLP-2008-0822, Broken Valve Keeper (Spring Seat Lock) Found on Cylinder 2-L of the 1-
- CR-PLP-2008-0822, Broken Valve Keeper (Spring Seat Lock) Found on Cylinder 2-L of the 1-
  2 Emergency Diesel Generator, February 19, 2008
2 Emergency Diesel Generator, February 19, 2008  
- EGAD-EP-10, Maintenance Rule Scoping Document, Revision 5
- EGAD-EP-10, Maintenance Rule Scoping Document, Revision 5  
- EM-20-01, Emergency Diesel Generator Reliability Program, Revision 2
- EM-20-01, Emergency Diesel Generator Reliability Program, Revision 2  
                                                        3                              Attachment


- Emergency Diesel Generator Related Plant Operating Log Entries from May 2007 thru
  September 2008
- Emergency Diesel Generators Palisades Plant Health Report, 3rd Quarter 2008
4
- EN-DC-198, Emergency Diesel Generator Reliability Program, Revision 1
Attachment
- EN-DC-203, Maintenance Rule Program, Revision 1
- Emergency Diesel Generator Related Plant Operating Log Entries from May 2007 thru  
- EN-DC-204, Maintenance Rule Scope and Basis, Revision 1
September 2008  
- EN-DC-205, Maintenance Rule Monitoring, Revision 2
- Emergency Diesel Generators Palisades Plant Health Report, 3rd Quarter 2008  
- EN-DC-206, Maintenance Rule (a)(1) Process, Revision 1
- EN-DC-198, Emergency Diesel Generator Reliability Program, Revision 1  
- NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at
- EN-DC-203, Maintenance Rule Program, Revision 1  
  Nuclear Power Plants, Revision 2
- EN-DC-204, Maintenance Rule Scope and Basis, Revision 1  
- Palisades Plant Maintenance Rule Unavailability Performance Indicator Data thru
- EN-DC-205, Maintenance Rule Monitoring, Revision 2  
  September 2008
- EN-DC-206, Maintenance Rule (a)(1) Process, Revision 1  
1R13 Maintenance Risk Assessments and Emergent Work Control
- NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at  
- Procedure No. 4.02, Control of Equipment, Revision 47
Nuclear Power Plants, Revision 2  
- SOP-3, High Pressure Safety Injection System, Revision 75
- Palisades Plant Maintenance Rule Unavailability Performance Indicator Data thru  
- FSAR Chapter 9.7, Auxiliary Feedwater System, Revision 26
September 2008  
1R15 Operability Determinations
1R13 Maintenance Risk Assessments and Emergent Work Control
- Calculation 022-M-001, Control Room Required Cooling Load, Revision 0 and markup
- Procedure No. 4.02, Control of Equipment, Revision 47  
- CR-4580, Diesel Load Calculation, November 11, 2008
- SOP-3, High Pressure Safety Injection System, Revision 75  
- CR-PLP-2008-03993, RT-202, Control Room Heat Removal Capability Test Operability Issue,
- FSAR Chapter 9.7, Auxiliary Feedwater System, Revision 26  
  September 24, 2008
1R15 Operability Determinations
- CR-PLP-2008-04344, Control room HVAC mounting configuration of solenoid valves to their
- Calculation 022-M-001, Control Room Required Cooling Load, Revision 0 and markup  
  positioners not in accordance with design drawings, October 21, 2008
- CR-4580, Diesel Load Calculation, November 11, 2008  
- CR-PLP-2008-04580, Diesel Load Calculation did not Account for Worst Case Containment
- CR-PLP-2008-03993, RT-202, Control Room Heat Removal Capability Test Operability Issue,  
  Air Cooler Load, November 11, 2008
September 24, 2008  
- CR-PLP-2008-4431, Containment Spray Header Pressure Indicator Indicating Below
- CR-PLP-2008-04344, Control room HVAC mounting configuration of solenoid valves to their  
  Technical Specification Limit after Maintenance, October 28, 2008
positioners not in accordance with design drawings, October 21, 2008  
- DBD 1.06, Control Room HVAC System, Revision 7
- CR-PLP-2008-04580, Diesel Load Calculation did not Account for Worst Case Containment  
- DBD-2.03, Containment Spray System, Revision 7
Air Cooler Load, November 11, 2008  
- EA-SBO-1, Station Blackout Coping Evaluation for 10CFR50.63, Revision 2
- CR-PLP-2008-4431, Containment Spray Header Pressure Indicator Indicating Below  
- EC Markup EC-10988, Control Room Cooling Load, Revision 0
Technical Specification Limit after Maintenance, October 28, 2008  
- ESSO-1, Containment Spray Header Fill, Revision 12
- DBD 1.06, Control Room HVAC System, Revision 7  
- FSAR Chapter 6.2, Containment Spray, Revision 26
- DBD-2.03, Containment Spray System, Revision 7  
- FSAR Chapter 9.8, Heating, Ventilation, and Air Conditioning System, Revision 26
- EA-SBO-1, Station Blackout Coping Evaluation for 10CFR50.63, Revision 2  
- MO-29, Engineered Safety System Alignment, Revision 36
- EC Markup EC-10988, Control Room Cooling Load, Revision 0  
- RT-202, Control Room HVAC Heat Removal Capability, Revisions 3, 9, and 10
- ESSO-1, Containment Spray Header Fill, Revision 12  
1R18 Plant Modifications
- FSAR Chapter 6.2, Containment Spray, Revision 26  
- EC-10638, Disable Fast Transfer
- FSAR Chapter 9.8, Heating, Ventilation, and Air Conditioning System, Revision 26  
1R19 Post Maintenance Testing
- MO-29, Engineered Safety System Alignment, Revision 36  
- CR-PLP-2006-2485, Control Rods Failed RO-19, May 2, 2006
- RT-202, Control Room HVAC Heat Removal Capability, Revisions 3, 9, and 10  
- CR-PLP-2480, CRD-8 Failed to Drive CRD-8, May 1, 2006
1R18 Plant Modifications  
- DBD-1.03, Auxiliary Feedwater System Design Basis Document, Revision 7
- EC-10638, Disable Fast Transfer  
- FSAR Chapter 9.7, Auxiliary Feedwater System, Revision 26
1R19 Post Maintenance Testing
                                                    4                              Attachment
- CR-PLP-2006-2485, Control Rods Failed RO-19, May 2, 2006  
- CR-PLP-2480, CRD-8 Failed to Drive CRD-8, May 1, 2006  
- DBD-1.03, Auxiliary Feedwater System Design Basis Document, Revision 7  
- FSAR Chapter 9.7, Auxiliary Feedwater System, Revision 26  


- Procedure No. 9.20, Attachment 3, Process Control Sheet dtd 11/5/08 for Auxiliary Feedwater
  System 18-Month Test Procedure, Revision 24
- RO-127, Auxiliary Feedwater System, 18-Month Test Procedure, Revision 7
5
- WO #51634185, P/S-0737A, Replace Power Supply During 1R20
Attachment
- WO 00168249, MC1000-03 has Failed, October 12, 2008
- Procedure No. 9.20, Attachment 3, Process Control Sheet dtd 11/5/08 for Auxiliary Feedwater  
- WO 0019168, RO-19 Control Rod Position Verification, May 2, 2006
System 18-Month Test Procedure, Revision 24  
- WO 51631052, Control Rod Position Verification, October 12, 2007
- RO-127, Auxiliary Feedwater System, 18-Month Test Procedure, Revision 7  
- WO002981980, Control Rod Position Verification, May 3, 2006
- WO #51634185, P/S-0737A, Replace Power Supply During 1R20  
- EC-9282, Provide UPS Power for Perimeter Intrusion Detection and Monitoring Equipment,
- WO 00168249, MC1000-03 has Failed, October 12, 2008  
  October 17, 2008
- WO 0019168, RO-19 Control Rod Position Verification, May 2, 2006  
- WO 00160408, Upgrade to Security UPS System, October 17, 2008
- WO 51631052, Control Rod Position Verification, October 12, 2007  
1R22 Surveillance Testing
- WO002981980, Control Rod Position Verification, May 3, 2006  
- ASME OM Code 2001, Subsection ISTB
- EC-9282, Provide UPS Power for Perimeter Intrusion Detection and Monitoring Equipment,  
- EM-09-04, Inservice Testing of Selected Safety-Related Pumps, Revision 23
October 17, 2008  
- QO-15 Basis Document for Inservice Test Procedure-Component Cooling Water Pumps,
- WO 00160408, Upgrade to Security UPS System, October 17, 2008  
  Revision 14
1R22 Surveillance Testing
- QO-15, Inservice Test Procedure, Component Cooling Water Pumps, Revision 26
- ASME OM Code 2001, Subsection ISTB  
- RO-146, Comprehensive Pump Test Procedure, Component Cooling System Pumps P-52A,
- EM-09-04, Inservice Testing of Selected Safety-Related Pumps, Revision 23  
  P-52B, and P-52C, Revision 1
- QO-15 Basis Document for Inservice Test Procedure-Component Cooling Water Pumps,  
- RO-52, Fire Suppression Water System Functional Test; Fire Pump Capacity Test,
Revision 14  
  Revision 27
- QO-15, Inservice Test Procedure, Component Cooling Water Pumps, Revision 26  
- RPS-I-7, Anticipated Transient Without Scram (ATWS) Calibration/Functional Test,
- RO-146, Comprehensive Pump Test Procedure, Component Cooling System Pumps P-52A,  
  October 22, 2008
P-52B, and P-52C, Revision 1  
- WO 51662292, Fire Suppress Wtr Sys Pump Capacity Func, September 23, 2008
- RO-52, Fire Suppression Water System Functional Test; Fire Pump Capacity Test,  
1EP4 Emergency Action Level and Emergency Plan Changes
Revision 27  
- Attachment 9.2, 10 CFR 50.54(q) Evaluation/Screening, Revisions 17 and 49
- RPS-I-7, Anticipated Transient Without Scram (ATWS) Calibration/Functional Test,  
- EI-1, Emergency Classification and Actions, Revisions 48 and 49
October 22, 2008  
- Palisades Nuclear Plant Site Emergency Plan, Revisions 16 and 17
- WO 51662292, Fire Suppress Wtr Sys Pump Capacity Func, September 23, 2008  
1EP6 Drill Evaluation
1EP4 Emergency Action Level and Emergency Plan Changes  
- Procedure SEP, Site Emergency Plan, Revision 16
- Attachment 9.2, 10 CFR 50.54(q) Evaluation/Screening, Revisions 17 and 49  
- NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5
- EI-1, Emergency Classification and Actions, Revisions 48 and 49  
- Fourth Quarter Integrated Training Drill, November 5, 2008
- Palisades Nuclear Plant Site Emergency Plan, Revisions 16 and 17  
- Tabletop Drill, December 17, 2008
1EP6 Drill Evaluation
2OS1 Access Control to Radiologically Significant Areas
- Procedure SEP, Site Emergency Plan, Revision 16  
- CR-PLP-2007-04378, Ensure that all Requirements Associated with Control of Very High
- NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5  
  Radiation Areas are Properly Assessed, dated September 23, 2007
- Fourth Quarter Integrated Training Drill, November 5, 2008  
- CR-PLP-2007-4383, Concerns Have Been Made Regarding Use of the New Fuel Elevator,
- Tabletop Drill, December 17, 2008  
  dated September 24, 2007
2OS1 Access Control to Radiologically Significant Areas  
- CR-PLP-2008-04310, West Engineered Safeguards Room Dose Rates Warranted High
- CR-PLP-2007-04378, Ensure that all Requirements Associated with Control of Very High  
  Radiation Area Posting, dated October 18, 2008
Radiation Areas are Properly Assessed, dated September 23, 2007  
- EAR 2001-0518, Evaluate Current Mechanical Stop on New Fuel Elevator for Design
- CR-PLP-2007-4383, Concerns Have Been Made Regarding Use of the New Fuel Elevator,  
  Function, Revision 0
dated September 24, 2007  
- EN-RP-100, Radworker Expectations, Revision 2
- CR-PLP-2008-04310, West Engineered Safeguards Room Dose Rates Warranted High  
                                                  5                                Attachment
Radiation Area Posting, dated October 18, 2008  
- EAR 2001-0518, Evaluate Current Mechanical Stop on New Fuel Elevator for Design  
Function, Revision 0  
- EN-RP-100, Radworker Expectations, Revision 2  


- EN-RP-101, Access Control For Radiologically Controlled Areas, Revision 4
- EN-RP-108, Radiation Protection Posting, Revision 7
- EN-RP-141, Job Coverage, Revision 4
6
- EN-RP-151, Radiological Diving Revision 2
Attachment
- QA-14-2008-PLP-01, Quality Assurance Report, Radiation Protection, dated May 14, 2008
- EN-RP-101, Access Control For Radiologically Controlled Areas, Revision 4  
- Radiation Work Permit 20080015 and Associated ALARA File, Containment Activities During
- EN-RP-108, Radiation Protection Posting, Revision 7  
  Power Operations, Revision 3
- EN-RP-141, Job Coverage, Revision 4  
- Radiation Work Permit 20080108 and Associated ALARA File, Badger Testing in the Spent
- EN-RP-151, Radiological Diving Revision 2  
  Fuel Pool, Revision 0
- QA-14-2008-PLP-01, Quality Assurance Report, Radiation Protection, dated May 14, 2008  
- SC-91-095-07, New Fuel Elevator Travel Limit Switch and Control Console Modification,
- Radiation Work Permit 20080015 and Associated ALARA File, Containment Activities During  
  Revision 1
Power Operations, Revision 3  
- Snapshot Assessment, Incorporation of Radiation Protection Hold Points and Radiation
- Radiation Work Permit 20080108 and Associated ALARA File, Badger Testing in the Spent  
  Protection Notification into Palisades Operation Procedures, June 13, 2008
Fuel Pool, Revision 0  
4OA1 Performance Indicator Verification
- SC-91-095-07, New Fuel Elevator Travel Limit Switch and Control Console Modification,  
- Cooling Water System Mitigating System Performance Indicator Validation Packages, Fourth
Revision 1  
  Quarter 2007 thru Third Quarter 2008
- Snapshot Assessment, Incorporation of Radiation Protection Hold Points and Radiation  
- DWO-1, Operators Daily/Weekly Items Modes 1,2,3, and 4 Basis Document, Revision 53
Protection Notification into Palisades Operation Procedures, June 13, 2008  
- DWO-1, Operators Daily/Weekly Items Modes 1,2,3, and 4, Revision 84
4OA1 Performance Indicator Verification
- MSPI Margin Report for Cooling Water System, Period ending September 2008
- Cooling Water System Mitigating System Performance Indicator Validation Packages, Fourth  
- LER 05000255/2008-002-00, Breaker Cubicle Failure Results in High Pressure Safety
Quarter 2007 thru Third Quarter 2008  
  Injection Pump Inoperability
- DWO-1, Operators Daily/Weekly Items Modes 1,2,3, and 4 Basis Document, Revision 53  
- LER 05000255/2007-007-00, Fuel Handling Area Ventilation System Inoperable
- DWO-1, Operators Daily/Weekly Items Modes 1,2,3, and 4, Revision 84  
- LER 05000255/2007-008-00, Auxiliary Feedwater Pump Inoperable in excess of technical
- MSPI Margin Report for Cooling Water System, Period ending September 2008  
  Specification Limits Due to a Postulated steam Line Break
- LER 05000255/2008-002-00, Breaker Cubicle Failure Results in High Pressure Safety  
- Log Entries associated with Cooling Water System Equipment, 1 October 2007 thru 30
Injection Pump Inoperability  
  September 2008
- LER 05000255/2007-007-00, Fuel Handling Area Ventilation System Inoperable  
- Selected Palisades Plant Operating Logs from Fourth Quarter 2007 thru Third Quarter 2008
- LER 05000255/2007-008-00, Auxiliary Feedwater Pump Inoperable in excess of technical  
- NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5
Specification Limits Due to a Postulated steam Line Break  
4OA2 Problem Identification and Resolution
- Log Entries associated with Cooling Water System Equipment, 1 October 2007 thru 30  
- 06-01 OWA, Auxiliary Feedwater Pumps P-8A, B, C Suction Source, May 23, 2008
September 2008  
- 07-02 OWA, 2400VAC Busses 1C, 1D, 1E, May 14, 2007
- Selected Palisades Plant Operating Logs from Fourth Quarter 2007 thru Third Quarter 2008  
- 08-01 OB, 2400/4160VAC MOC Switch Required Inspections, May 14, 2008
- NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5  
- 08-01 OWA, Condensate Pump P-2B Degraded Pressure, December 6, 2007
4OA2 Problem Identification and Resolution
- Corrective Action X, Basis for Fuel Assembly Moves in Palisades Spent Fuel Pool,
- 06-01 OWA, Auxiliary Feedwater Pumps P-8A, B, C Suction Source, May 23, 2008  
  November 6 2008
- 07-02 OWA, 2400VAC Busses 1C, 1D, 1E, May 14, 2007  
- CR-PLP-2008-3439, The Estimated Critical Position, although Well Within Acceptance
- 08-01 OB, 2400/4160VAC MOC Switch Required Inspections, May 14, 2008  
  Criteria, was not as Accurate as Typical for Palisades, August 9, 2008
- 08-01 OWA, Condensate Pump P-2B Degraded Pressure, December 6, 2007  
- CR-PLP-2008-01748, 1-1 Diesel Fuel Oil Supply Line Rubbing, April 19, 2008
- Corrective Action X, Basis for Fuel Assembly Moves in Palisades Spent Fuel Pool,  
- CR-PLP-2008-01749, 1-1 Diesel Fuel Oil Supply Line Rubbing, April 19, 2008
November 6 2008  
- CR-PLP-2008-05023, NRC has questioned the basis, justification, and control of initial control
- CR-PLP-2008-3439, The Estimated Critical Position, although Well Within Acceptance  
  room temperature assumption in the heatup analysis of the Palisades station blackout (SBO)
Criteria, was not as Accurate as Typical for Palisades, August 9, 2008  
  event, December 12, 2008
- CR-PLP-2008-01748, 1-1 Diesel Fuel Oil Supply Line Rubbing, April 19, 2008  
- CR-PLP-2008-05074, An Administrative Issue was Identified During Review of Documents
- CR-PLP-2008-01749, 1-1 Diesel Fuel Oil Supply Line Rubbing, April 19, 2008
  Provided to the NRC Related to Palisades Compliance with SBO Rule, December 17, 2008
- CR-PLP-2008-05023, NRC has questioned the basis, justification, and control of initial control  
- EA-APR-95-023, Room heatup after loss of ventilation under Appendix R scenario in the
room temperature assumption in the heatup analysis of the Palisades station blackout (SBO)  
  control room, 1C and 1D switchgear rooms, battery rooms, containment area, and EDG rooms
event, December 12, 2008  
- EM-04-24, Palisades Critical Prediction and Critical Approach, Revision 8
- CR-PLP-2008-05074, An Administrative Issue was Identified During Review of Documents  
                                                    6                              Attachment
Provided to the NRC Related to Palisades Compliance with SBO Rule, December 17, 2008  
- EA-APR-95-023, Room heatup after loss of ventilation under Appendix R scenario in the  
control room, 1C and 1D switchgear rooms, battery rooms, containment area, and EDG rooms  
- EM-04-24, Palisades Critical Prediction and Critical Approach, Revision 8  


- EN-LI-102, Corrective Action Process, Revision 10
- EN-OP-103, Reactivity Management Program, Revision 3
- FSAR Chapter 8.1.5, Station Blackout, Revision 25
7
- Letter to Gerald Slade, Palisades Plant Station Blackout Analysis, Safety Evaluation
Attachment
  (TAC No. 68578), May 20, 1991
- EN-LI-102, Corrective Action Process, Revision 10  
- Letter to Gerald Slade, Palisades Plant-Station Blackout Analysis-Safety Evaluation
- EN-OP-103, Reactivity Management Program, Revision 3  
  (TAC No. M68578), June 25, 1992
- FSAR Chapter 8.1.5, Station Blackout, Revision 25  
- Letter to John Ellegood, Notification of Fuel Moves Planned -Palisades Spent Fuel Pool
- Letter to Gerald Slade, Palisades Plant Station Blackout Analysis, Safety Evaluation  
  Region 1 to Region 2, November 6, 2008
(TAC No. 68578), May 20, 1991  
- Letter to the NRC, Palisades Plant-Station Blackout Analysis, Safety Evaluation
- Letter to Gerald Slade, Palisades Plant-Station Blackout Analysis-Safety Evaluation  
  (TAC No. 68578), August 1, 1991
(TAC No. M68578), June 25, 1992  
- NET-299-01, BADGER Test Campaign at Palisades Nuclear Plant, October 8, 2008
- Letter to John Ellegood, Notification of Fuel Moves Planned -Palisades Spent Fuel Pool  
- NUMARC 87-00, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station
Region 1 to Region 2, November 6, 2008  
  Blackout at Light Water Reactors, Revision 1
- Letter to the NRC, Palisades Plant-Station Blackout Analysis, Safety Evaluation  
- ODMI Implementation Action Plan, P-2B Condensate Pump Degraded Performance,
(TAC No. 68578), August 1, 1991  
  November 18, 2007
- NET-299-01, BADGER Test Campaign at Palisades Nuclear Plant, October 8, 2008  
- Operator Work Arounds / Burdens, October 14, 2008 Index
- NUMARC 87-00, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station  
- Palisades Administrative Procedure 4.12, Operator Work-Around Program, Revision 5
Blackout at Light Water Reactors, Revision 1  
- Palisades Operator Aggregate Index Reports, July through October 2008
- ODMI Implementation Action Plan, P-2B Condensate Pump Degraded Performance,  
- CR-PLP-2006-04702, Adverse Trend in Power Supply Reliability, October 3, 2006
November 18, 2007  
- EN-LI-121, Entergy Trending Process Third Quarter Report, Revision 7
- Operator Work Arounds / Burdens, October 14, 2008 Index  
- CR-PLP-2008-04279, Adverse Trend in Power Supplies, October 16, 2008
- Palisades Administrative Procedure 4.12, Operator Work-Around Program, Revision 5  
- CR-PLP-2008-03203, Emerging Trend in Control of Equipment Positioning, July 25, 2008
- Palisades Operator Aggregate Index Reports, July through October 2008  
- SOP-24, Ventilation and Air Conditioning System, Revision 52
- CR-PLP-2006-04702, Adverse Trend in Power Supply Reliability, October 3, 2006  
- Letter to NRC, Commitments to Address degraded Spent Fuel Pool Storage Rack Neutron
- EN-LI-121, Entergy Trending Process Third Quarter Report, Revision 7  
  Absorber, August 27, 2008
- CR-PLP-2008-04279, Adverse Trend in Power Supplies, October 16, 2008  
- Spent Fuel Pool Shuffle Sequence, November 7, 2008
- CR-PLP-2008-03203, Emerging Trend in Control of Equipment Positioning, July 25, 2008  
- Letter to John Ellegood, Notification of Fuel Moves Planned -Palisades Spent Fuel Pool
- SOP-24, Ventilation and Air Conditioning System, Revision 52  
  region 1 to region 2, November 17, 2008
- Letter to NRC, Commitments to Address degraded Spent Fuel Pool Storage Rack Neutron  
4OA3 Follow-up of Events and Notices of Enforcement Discretion
Absorber, August 27, 2008  
- CR-PLP-2008-03328, Plant Exceeded Technical Specification Limit for Unidentified Leak
- Spent Fuel Pool Shuffle Sequence, November 7, 2008  
  Rate, August 5, 2008
- Letter to John Ellegood, Notification of Fuel Moves Planned -Palisades Spent Fuel Pool  
- LER 05000255/2008-05-00, Completion of Plant Shutdown required by Technical
region 1 to region 2, November 17, 2008  
  Specifications, Revision 0
4OA3 Follow-up of Events and Notices of Enforcement Discretion
- LER 05000255/2008-06-00, Emergency Diesel Generator Inoperable in Excess of Technical
- CR-PLP-2008-03328, Plant Exceeded Technical Specification Limit for Unidentified Leak  
  Specification Requirements, Revision 0
Rate, August 5, 2008  
- CR-PLP-2008-00822, Broken Valve Keeper (Spring Seat Lock) Found on Cylinder 2L of the
- LER 05000255/2008-05-00, Completion of Plant Shutdown required by Technical  
  1-2 Emergency Diesel Generator, February 19, 2008
Specifications, Revision 0  
- CR-PLP-2000-00556, EDG 1-2 Valve Yoke Retaining Nut on Cylinder 2L Was Not Attached,
- LER 05000255/2008-06-00, Emergency Diesel Generator Inoperable in Excess of Technical  
  March 21, 2000
Specification Requirements, Revision 0  
- EPS-M-14, Diesel Generator Periodic Maintenance, Revision 17
- CR-PLP-2008-00822, Broken Valve Keeper (Spring Seat Lock) Found on Cylinder 2L of the  
- EPS-M-15, Diesel Generator 1-2 Refueling Frequency Maintenance, Revision 1
1-2 Emergency Diesel Generator, February 19, 2008  
4OA5 Other Activities
- CR-PLP-2000-00556, EDG 1-2 Valve Yoke Retaining Nut on Cylinder 2L Was Not Attached,  
- Procedure No. RO-128-1; Diesel Generator 1-1 24 Hour Load Run; Revision 13
March 21, 2000  
- Procedure No. RO-128-2; Diesel Generator 1-2 24 Hour Load Run; Revision 12
- EPS-M-14, Diesel Generator Periodic Maintenance, Revision 17  
- Calculation No. EA-ELEC-LDTAB-005; Emergency Diesel Generator 1-1 & 1-2 Steady State
- EPS-M-15, Diesel Generator 1-2 Refueling Frequency Maintenance, Revision 1  
  Loading; Revision 8
4OA5 Other Activities  
                                                    7                                Attachment
- Procedure No. RO-128-1; Diesel Generator 1-1 24 Hour Load Run; Revision 13  
- Procedure No. RO-128-2; Diesel Generator 1-2 24 Hour Load Run; Revision 12  
- Calculation No. EA-ELEC-LDTAB-005; Emergency Diesel Generator 1-1 & 1-2 Steady State  
Loading; Revision 8  


                          LIST OF ACRONYMS USED
AFW     Auxiliary Feed Water
CAL     Confirmatory Action Letter
8
CAP     Corrective Action Program
Attachment
CFR     Code of Federal Regulations
LIST OF ACRONYMS USED  
CR     Condition Report
AFW  
CR HVAC Control Room Heating, Ventilation and Air Conditioning
Auxiliary Feed Water  
EDG     Emergency Diesel Generator
CAL  
HPSI   High Pressure Safety Injection
Confirmatory Action Letter  
IMC     Inspection Manual Chapter
CAP  
LCO     Limiting Condition for Operations
Corrective Action Program  
LER     Licensee Event Report
CFR  
MSPI   Mitigating Systems Performance Index
Code of Federal Regulations  
NEI     Nuclear Energy Institute
CR  
NCV     Non-Cited Violation
Condition Report  
NRC     U.S. Nuclear Regulatory Commission
CR HVAC  
PI     Performance Indicator
Control Room Heating, Ventilation and Air Conditioning  
RWP     Radiation Work Permits
EDG  
SBO     Station Black Out
Emergency Diesel Generator  
SDP     Significance Determination Process
HPSI  
TS     Technical Specification
High Pressure Safety Injection  
UFSAR   Updated Final Safety Analysis Report
IMC  
                                          8                  Attachment
Inspection Manual Chapter  
LCO  
Limiting Condition for Operations  
LER  
Licensee Event Report  
MSPI  
Mitigating Systems Performance Index  
NEI  
Nuclear Energy Institute  
NCV  
Non-Cited Violation  
NRC  
U.S. Nuclear Regulatory Commission  
PI  
Performance Indicator  
RWP  
Radiation Work Permits  
SBO  
Station Black Out  
SDP  
Significance Determination Process  
TS  
Technical Specification  
UFSAR  
Updated Final Safety Analysis Report
}}
}}

Latest revision as of 13:19, 14 January 2025

IR 05000255-08-005; Entergy Nuclear Operations, Inc., on 10/01/2008 - 12/31/2008; Palisades Power Plant; Integrated Inspection Report; Operability Evaluations; Follow-up of Events
ML090400437
Person / Time
Site: Palisades Entergy icon.png
Issue date: 02/09/2009
From: Jack Giessner
NRC/RGN-III/DRP/RPB4
To: Schwartz C
Entergy Nuclear Operations
References
IR-05-005
Download: ML090400437 (40)
v • d • e


See also: IR 05000255/2008005

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

February 9, 2009

Mr. Christopher J. Schwarz

Site Vice President

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT:

PALISADES NUCLEAR PLANT INTEGRATED INSPECTION

REPORT 05000255/2008-005

Dear Mr. Schwarz:

On December 31, 2008, the U. S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection

findings, which were discussed on January 22, 2009, with members of your staff.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this inspection, two NRC-identified violations 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 issues as Non-Cited Violations (NCVs)in

accordance with Section VI.A.1 of the NRC Enforcement Policy. Additionally, one licensee

identified violation is listed in Section 4OA7 of this report.

If you contest the subject or severity of an 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.

C. Schwarz

-2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html

(the Public Electronic Reading Room).

Sincerely,

/RA/

John B. Giessner, Chief

Branch 4

Division of Reactor Projects

Docket No. 50-255

License No. DPR-20

Enclosure:

Inspection Report 05000255/2008-005

w/Attachment: Supplemental Information

cc w/encl:

Senior Vice President

Vice President Oversight

Senior Manager, Nuclear Safety & Licensing

Senior Vice President and COO

Assistant General Counsel

Manager, Licensing

W. DiProfio

W. Russell

G. Randolph

Supervisor, Covert Township

Office of the Governor

T. Strong, State Liaison Officer

Michigan Department of Environmental Quality

Michigan Office of the Attorney General

C. Schwarz

-2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html

(the Public Electronic Reading Room).

Sincerely,

John B. Giessner, Chief

Branch 4

Division of Reactor Projects

Docket No. 50-255

License No. DPR-20

Enclosure:

Inspection Report 05000255/2008-005

w/Attachment: Supplemental Information

cc w/encl:

Senior Vice President

Vice President Oversight

Senior Manager, Nuclear Safety & Licensing

Senior Vice President and COO

Assistant General Counsel

Manager, Licensing

W. DiProfio

W. Russell

G. Randolph

Supervisor, Covert Township

Office of the Governor

T. Strong, State Liaison Officer

Michigan Department of Environmental Quality

Michigan Office of the Attorney General

DOCUMENT NAME: G:\\1-Secy\\1-Work In Progress\\Pali 2008-005.doc

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

NAME

RLerch:dtp

JGiessner

DATE

02/06/09

02/06/09

OFFICIAL RECORD COPY

Letter to C. Schwarz from J. Giessner dated February 9, 2009

SUBJECT:

PALISADES NUCLEAR PLANT INTEGRATED INSPECTION

REPORT 05000255/2008-005

DISTRIBUTION:

Tamara Bloomer

RidsNrrPMPalisades

RidsNrrDorlLpl3-1

RidsNrrDirsIrib Resource

Mark Satorius

Kenneth Obrien

Jared Heck

Carole Ariano

Linda Linn

Cynthia Pederson

DRPIII

DRSIII

Patricia Buckley

Tammy Tomczak

ROPreports@nrc.gov

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No:

50-255

License No:

DPR-20

Report No:

05000255/2008-005

Licensee:

Entergy Nuclear Operations, Inc.

Facility:

Palisades Nuclear Plant

Location:

Covert, MI

Dates:

October 1, 2008, to December 31, 2008

Inspectors:

J. Ellegood, Senior Resident Inspector

T. Taylor, Resident Inspector

J. Cassidy, Senior Health Physicist

A. Dahbur, Senior Reactor Inspector

R. Jickling, Senior Emergency Preparedness Inspector

R. Winter, Reactor Inspector

Approved by:

J. Giessner, Chief

Branch 4

Division of Reactor Projects

Enclosure

TABLE OF CONTENTS

SUMMARY OF FINDINGS ......................................................................................................... 1

REPORT DETAILS ..................................................................................................................... 3

Summary of Plant Status......................................................................................................... 3

1.

REACTOR SAFETY ..................................................................................................... 3

1R04

Equipment Alignment (71111.04) ....................................................................... 3

1R05

Fire Protection (71111.05) ................................................................................. 4

1R11

Licensed Operator Requalification Program (71111.11) ..................................... 5

1R12

Maintenance Effectiveness (71111.12) .............................................................. 5

1R13

Maintenance Risk Assessments and Emergent Work Control (71111.13) .......... 6

1R15

Operability Evaluations (71111.15) .................................................................... 6

1R18

Plant Modifications (71111.18) ........................................................................... 8

1R19

Post-Maintenance Testing (71111.19) ............................................................... 9

1R22

Surveillance Testing (71111.22)....................................................................... 10

1EP4

Emergency Action Level and Emergency Plan Changes (71114.04) ............... 11

1EP6

Drill Evaluation (71114.06) ............................................................................... 11

2.

RADIATION SAFETY ................................................................................................. 12

2OS1

Access Control to Radiologically Significant Areas (71121.01) ........................ 12

4.

OTHER ACTIVITIES .................................................................................................. 16

4OA1

Performance Indicator Verification (71151) ...................................................... 16

4OA2

Identification and Resolution of Problems (71152) ........................................... 17

4OA3

Follow-Up of Events and Notices of Enforcement Discretion (71153) .............. 22

4OA5

Other Activities ................................................................................................. 24

4OA6

Management Meetings .................................................................................... 25

4OA7

Licensee-Identified Violations .......................................................................... 26

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 .................................................................................................. 8

1

Enclosure

SUMMARY OF FINDINGS

IR 05000255/2008-005; 10/01/2008 - 12/31/2008; Palisades Power Plant; Integrated Inspection

Report; Operability Evaluations; Follow-up of Events.

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. The findings were considered Non-Cited Violations of NRC regulations. The

significance of most findings is indicated by their color (Green, White, Yellow, Red) using

Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings

for which the SDP does not apply may be Green or be assigned a severity level after NRC

management review. The NRCs program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4,

dated December 2006.

A.

NRC-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green. The inspectors identified a finding of very low safety significance (Green) and

an associated NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, for

the inadequate testing of the heat removal capacity of the Control Room Heating,

Ventilation, and Air Conditioning (CR HVAC) system. Specifically, the licensee isolated

refrigerant hot gas bypass flow during the test which increased the heat removal

capability of the chiller. The licensee entered the issue into their corrective action

program as condition report (CR) PLP-2008-3993 and re-performed portions of the

engineering basis calculation to demonstrate margin to account for the hot gas bypass

flow.

The finding is more than minor because, in accordance with IMC 0612, Appendix E,

Examples of Minor Issues, the inspectors determined that the finding was similar to

Example E.3.j and resulted in a reasonable doubt as to the operability of the chiller.

Based upon a review of the licensees revised calculation for the CR HVAC system

acceptance criteria and the Technical Specification (TS) requirements, the finding

screens as very low safety significance (Green) using the Phase 1 SDP worksheets.

The inspectors determined that the finding included a cross-cutting aspect in the area of

human performance, resources, and complete and accurate procedures (H.2(c))

because the surveillance procedure unacceptably preconditioned the chiller. (1R15)

Green. A self-revealed finding of very low safety significance (Green) and an associated

NCV for failure to comply with TS 3.8.1 requirements when metal fragments were found

in the valve assembly area of the 1-2 Emergency Diesel Generator (EDG) cylinder 2L.

The source of the fragments was a failed spring lock for one of the exhaust valves. This

resulted in the EDG being inoperable for a period greater than allowed by TSs.

Subsequently, the licensee inspected the remaining spring locks on the 1-2 EDG.

Inspections of the 1-1 EDG spring locks are planned.

The finding is more than minor because it affected the equipment performance attribute

of the mitigating system cornerstone and adversely affected the objective of ensuring the

availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences. A failure analysis performed by the vendor in

2

Enclosure

conjunction with an apparent cause analysis by the licensee led to an evaluation that the

diesel could perform its safety function for at least the 24-hour Probabilistic Risk

Assessment mission time. In consultation with the regional Senior Risk Analyst, the

finding screens as Green using the significance determination process phase 1. No

cross-cutting aspect was assigned because this issue is not indicative of current plant

performance. (4OA3)

B.

Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been

reviewed by inspectors. Corrective actions planned or taken by the licensee have been

entered into the licensees corrective action program. This violation and corrective

action tracking numbers are listed in Section 4OA7 of this report.

3

Enclosure

REPORT DETAILS

Summary of Plant Status

Throughout the inspection period, the plant operated at or near 100 percent power.

1.

REACTOR SAFETY

1R01 Adverse Weather Protection (71111.01)

a.

Inspection Scope

Since extreme cold conditions were forecast in the vicinity of the facility for

December 2008, the inspectors reviewed the licensees overall preparations/protection

for the expected weather conditions. On December 17, the inspectors walked down the

condensate storage tanks and safety injection and refueling water tank system(s)

because their safety-related functions could be affected or required as a result of the

extreme cold conditions forecast for the facility. The inspectors observed insulation,

heat trace circuits, and weatherized enclosures to ensure operability of affected

systems. The inspectors reviewed licensee procedures. Specific documents reviewed

during this inspection are listed in the Attachment.

This inspection constituted one readiness for impending adverse weather condition

sample as defined in IP 71111.01-05.

b.

Findings

No findings of significance were identified.

1R04 Equipment Alignment (71111.04)

a.

Inspection Scope

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

systems:

High Pressure Safety Injection (HPSI)-A with HPSI-B out of service for

maintenance;

Service Water System with Service Water Pump C out of service for

maintenance;

HPSI-B with HPSI-A out of service for maintenance;

1-2 EDG with the 1-1 EDG out of service for maintenance.

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, Updated Final Safety Analysis Report (UFSAR), Technical

Specification (TS) requirements, outstanding work orders, condition reports, 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

4

Enclosure

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.

These activities constituted four partial system walkdown samples as defined in

IP 71111.04-05.

b.

Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05)

a.

Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

Technical Support Center;

1-D Switchgear Room (during/following emergent Post Maintenance Testing for

Auxiliary Feed Water (AFW) -C power supply);

Component Cooling Water Room;

North and Southwest Penetration Rooms;

Charging Pumps 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 had implemented

adequate compensatory measures for out of service, degraded, or inoperable fire

protection equipment, systems, or features in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to impact equipment which could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event. Using

the documents listed in the Attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees CAP. Documents reviewed are

listed in the Attachment to this report.

5

Enclosure

These activities constituted five quarterly fire protection inspection samples as defined in

IP 71111.05-05.

b.

Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11)

a.

Inspection Scope

On November 17, the inspectors observed a crew of licensed operators in the plants

simulator during licensed operator requalification examinations to verify that operator

performance was adequate, evaluators were identifying, and documenting crew

performance problems, and training was being conducted in accordance with licensee

procedures. The inspectors evaluated the following areas:

licensed operator performance;

crews clarity and formality of communications;

ability to take timely actions in the conservative direction;

prioritization, interpretation, and verification of annunciator alarms;

correct use and implementation of abnormal and emergency procedures;

control board manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate TS actions and Emergency Plan

actions and notifications.

The crews performance in these areas was compared to pre-established operator action

expectations and successful critical task completion requirements. Documents reviewed

are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator requalification program

sample as defined in IP 71111.11.

b.

Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12)

a.

Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk

significant systems:

1-2 Emergency Diesel Generator

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 corrective action program with the appropriate

significance characterization. Documents reviewed are listed in the Attachment.

6

Enclosure

This inspection constitutes one quarterly maintenance effectiveness samples as defined

in IP 71111.12-05.

b.

Findings

No findings of significance 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 the appropriate risk assessments were performed

prior to removing equipment for work:

HPSI-B bearing oil change with hot leg injection valve breaker work and

switchyard work (yellow risk);

Unplanned AFW right train inoperability.

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.

These maintenance risk assessments and emergent work control activities constituted

two samples as defined in IP 71111.13-05.

b.

Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a.

Inspection Scope

The inspectors reviewed the following issues:

CR HVAC chiller capacity with hot-gas bypass isolated;

CR HVAC fittings found not in-accordance with design;

Containment Spray header inoperable after pressure gauge replacement;

EDG 1-2 due to increased load from Containment Air Coolers.

The inspectors selected these potential operability issues based on the risk-significance

of the associated components and systems. The inspectors evaluated the technical

7

Enclosure

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 also reviewed a sampling 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.

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

b.

Findings

Introduction: The inspectors identified a finding of very low safety significance (Green)

and an associated NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, for

the inadequate testing of the heat removal capacity of the CR HVAC system.

Specifically, the licensee isolated refrigerant hot gas bypass flow during the test which

increased the heat removal capability of the chiller.

Description: On August 26, 2008, the licensee performed a surveillance test, RT-202, to

determine the heat removal capability of the A chiller. The test assessed the capability

of chiller to remove heat load during design basis conditions. The inspectors reviewed

the procedure and conduct of the test and noted that step 5.1.3.d of the procedure

manually isolated the hot gas bypass valve of the chiller. Under normal and design

conditions, the hot gas bypass flow control valve regulates automatically to open and

bypass refrigerant from the condensing unit to maintain compressor suction pressure

under low load condition. At full load conditions the valve is closed, but by design there

is a small amount of refrigerant that flows. Therefore, isolating the hot gas bypass

increases the heat removal capability of the chiller. Since hot gas bypass would not be

isolated during normal operation nor during an event, the inspectors concluded that

isolating hot gas bypass was preconditioning. As part of the corrective actions, the

licensee reviewed test data going back approximately 3 years and adjusted the data to

account for hot gas bypass flow. For the July 2007 test on the A train of the CR HVAC

system, taking hot gas bypass flow into consideration would have resulted in a

measured capacity approximately 9200 BTU/hr below the acceptance criteria of RT-202.

Based on discussions with the system engineer and a review of previous revisions of

RT-202, the inspectors determined that RT-202 was being performed with hot gas

bypass flow isolated since the year 2000.

In order to determine current operability of the CR HVAC system, the licensee adjusted

the most recent results of RT-202 to account for hot gas bypass flow. The licensee

determined that the B CR HVAC train was operable and that the A CR HVAC train

would remain operable below an outside air temperature of 87 degrees. Upon further

questioning by the inspectors regarding the TS requirements, the licensee later declared

the A train of CR HVAC inoperable. As part of the licensees corrective actions, the

RT-202 basis calculation was revised. By using margin included in the analysis

regarding allowable control room temperature, the licensee provided a basis to restore

8

Enclosure

the A chiller to operable status and demonstrate operability for the previous tests that

were reviewed.

Analysis: The inspectors concluded that the failure to properly demonstrate the

capability of the chillers warranted an evaluation using the SDP. Specifically, the

manual isolation of the hot gas bypass line provided an erroneous value for chiller

capacity. On one occasion, isolation of the flow path masked a condition where the

chiller would not have been able to meet surveillance requirements. Although the

licensee was able to revise an underlying calculation to show the chiller could maintain

control room temperatures within the TS requirements, the failure to meet the

requirements prior to the calculation markup created a reasonable doubt of the

operability of the chiller. Using IMC 0612, Appendix E, Examples of Minor Issues, the

inspectors determined that the finding was similar to Example E.3.j and was more than

minor because the error resulted in reasonable doubt as to the operability of the chiller.

This finding affects the Procedure Quality attribute of the Mitigating Systems cornerstone

objective of ensuring the availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences in that the licensee used

inadequate testing to demonstrate operability of the system. To further assess the

significance of the finding, the inspectors used IMC 0609, Appendix A, Determining the

Significance of Reactor Inspection Findings for At-Power Situations. Based upon a

review of the licensees revised calculation for the CR HVAC system acceptance criteria

and the TS requirements, the finding screens as very low safety significance (Green)

using the Phase 1 worksheets due to answering no to each of the screening questions.

The inspectors determined that the finding included a cross-cutting aspect in the area of

human performance, resources, and complete and accurate procedures (H.2(c))

because the surveillance procedure unacceptably preconditioned the chiller. The finding

reflects current performance because the licensee revised the steps in question in

July 2007 but failed to identify and correct the preconditioning.

Enforcement: Appendix B of 10 CFR Part 50, Criterion XI, Test Control, requires, in

part, that a test program be established to assure that all testing required to

demonstrate that structures, systems, and components will perform satisfactorily in

service is identified and performed in accordance with written test procedures which

incorporate the requirements and acceptance limits contained in the applicable design

documents. Contrary to this requirement, during the performance of TS Surveillance

Procedure RT-202, Control Room HVAC Heat Removal Capability in August 2008, the

inspectors identified that the procedure does not adequately test the chillers to ensure

bypass flow of refrigerant is accounted for in the capacity of the unit. In addition,

potential degradation in the hot gas bypass flow line is not analyzed. Because the

finding is of very low safety significance and has been entered into the licensees

CAP as CR-2008-03993, this violation of 10 CFR 50, Appendix B, Criterion XI, is being

treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy.

(NCV 05000255/2008005 01, Inadequate Testing of Control Room Chillers)

1R18 Plant Modifications (71111.18)

a.

Inspection Scope

The inspectors reviewed the following temporary modification(s):

EC-10638, Disable Fast Transfer.

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Enclosure

The inspectors compared the temporary configuration changes and associated

10 CFR 50.59 screening and evaluation information against the design basis, the

UFSAR, and the TS, as applicable, to verify that the modification did not affect the

operability or availability of the affected system(s). The inspectors also compared the

licensees information to operating experience information to ensure that lessons learned

from other utilities had been incorporated into the licensees decision to implement the

temporary modification. The inspectors, as applicable, performed field verifications to

ensure that the modifications were installed as directed; the modifications operated as

expected; modification testing adequately demonstrated continued system operability,

availability, and reliability; and that operation of the modifications did not impact the

operability of any interfacing systems. Lastly, the inspectors discussed the temporary

modification with operations, engineering, and training personnel to ensure that the

individuals were aware of how extended operation with the temporary modification in

place could impact overall plant performance.

This inspection constituted one temporary modification sample as defined in

IP 71111.18-05.

b.

Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19)

a.

Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

Uninterruptible power supply following installation;

Primary rod position indication following power supply replacement;

AFW Right Train Power Supply Replacement.

These activities were selected based upon the structure, system, or component's 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

TS, 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.

10

Enclosure

This inspection constituted three post-maintenance testing samples as defined in

IP 71111.19-05.

b.

Findings

No findings of significance were identified.

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:

RPS-I-7, Anticipated Transient Without Scram Calibration/Functional Test

QO-1, Safety Injection Test;

RO-52, Fire Pump Capacity Test;

QO-15, Component Cooling Water-B Pump In-Service Test.

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, demonstrated operational readiness, and

consistent with the system design basis;

plant equipment calibration was correct, accurate, and properly documented;

as-left setpoints were within required ranges; and the calibration frequency were

in accordance with TSs, the UFSAR, procedures, and applicable commitments;

measuring and test equipment calibration was current;

test equipment was used within the required range and accuracy; applicable

prerequisites described in the test procedures were satisfied;

test frequencies met TS requirements to demonstrate operability and reliability;

tests were performed in accordance with the test procedures and other

applicable procedures; jumpers and lifted leads were controlled and restored

where used;

test data and results were accurate, complete, within limits, and valid;

test equipment was removed after testing;

where applicable for inservice testing activities, testing was performed in

accordance with the applicable version of Section XI, American Society of

Mechanical Engineers Code, and reference values were consistent with the

system design basis;

where applicable, test results not meeting acceptance criteria were addressed

with an adequate operability evaluation or the system or component was

declared inoperable;

where applicable for safety-related instrument control surveillance tests,

reference setting data were accurately incorporated in the test procedure;

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Enclosure

where applicable, actual conditions encountering high resistance electrical

contacts were such that the intended safety function could still be accomplished;

prior procedure changes had not provided an opportunity to identify problems

encountered during the performance of the surveillance or calibration test;

equipment was returned to a position or status required to support the

performance of its safety functions; and

all problems identified during the testing were appropriately documented and

dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted four routine surveillance testing sample(s) and one inservice

testing sample.

b.

Findings

No findings of significance were identified.

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

a.

Inspection Scope

Since the last NRC inspection of this program area, Emergency Plan Revision 17 and

Implementing Procedure EI-1, "Emergency Classification and Actions," Revision 49,

were implemented based on your determination, in accordance with 10 CFR 50.54(q),

that the changes resulted in no decrease in effectiveness of the Plan, and that the

revised Plan as changed continues to meet the requirements of 10 CFR 50.47(b) and

Appendix E to 10 CFR Part 50. The inspectors conducted a sampling review of the

Emergency Plan changes and a review of the Emergency Action Level changes to

evaluate for potential decreases in effectiveness of the Plan. However, this review does

not constitute formal NRC approval of the changes. Therefore, these changes remain

subject to future NRC inspection in their entirety.

This Emergency Action Level and Emergency Plan Changes inspection constituted one

sample as defined in IP 71114.04-05.

b.

Findings

No findings of significance were identified.

1EP6 Drill Evaluation (71114.06)

a.

Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on

November 5, 2008, and a table top drill for the emergency operations facility on

December 17, 2008, to identify any weaknesses and deficiencies in classification,

notification, and protective action recommendation development activities. The

inspectors observed, as applicable, emergency response operations in the simulator

control room, technical support center, and emergency operations facility to determine

whether the event classification, notifications, and protective action recommendations

12

Enclosure

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 corrective action

program. As part of the inspection, the inspectors reviewed the drill package and other

documents listed in the Attachment to this report.

These emergency preparedness drill inspections constituted two samples as defined in

IP 71114.06-05.

b.

Findings

No findings of significance were identified.

2.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

.1

Plant Walkdowns and Radiation Work Permit (RWP) Reviews

a.

Inspection Scope

The inspectors reviewed licensee controls and surveys in the following radiologically

significant work areas within radiation areas, high radiation areas, and airborne

radioactivity areas in the plant to determine if radiological controls including surveys,

postings, and barricades were acceptable:

Auxiliary Building;

Containment Building; and

Spent Fuel Pool Area.

This inspection constitutes one sample as defined in IP 71121.01-5.

The inspectors reviewed the RWPs and work packages used to access these areas and

other high radiation work areas. The inspectors assessed the work control instructions

and control barriers specified by the licensee. Electronic dosimeter alarm set points for

both integrated dose and dose rate were evaluated for conformity with survey indications

and plant policy. The inspectors interviewed workers to verify that they were aware of

the actions required if their electronic dosimeters noticeably malfunctioned or alarmed.

This inspection constitutes one sample as defined in IP 71121.01-5.

The inspectors walked down and surveyed (using an NRC survey meter) these areas to

verify that the prescribed RWP, procedure, and engineering controls were in place; that

licensee surveys and postings were complete and accurate; and that air samplers were

properly located.

This inspection constitutes one sample as defined in IP 71121.01-5.

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Enclosure

The inspectors also reviewed the licensees physical and programmatic controls for

highly activated and/or contaminated materials (non-fuel) stored within the spent fuel

pool or other storage pools.

This inspection constitutes one sample as defined in IP 71121.01-5.

b.

Findings

No findings of significance were identified.

.2

Problem Identification and Resolution

a.

Inspection Scope

The inspectors reviewed a sample of the licensees self-assessments, audits, Licensee

Event Reports (LERs), and Special Reports related to the access control program to

verify that identified problems were entered into the CAP for resolution.

This inspection constitutes one sample as defined in IP 71121.01-5.

The inspectors evaluated the licensees process for problem identification,

characterization, and prioritization and verified that problems were entered into the

CAP and resolved. For repetitive deficiencies and/or significant individual deficiencies

in problem identification and resolution, the inspectors verified that the licensees

self-assessment activities were capable of identifying and addressing these deficiencies.

This inspection constitutes one sample as defined in IP 71121.01-5.

The inspectors reviewed licensee documentation packages for all performance indicator

(PI) events occurring since the last inspection to determine if any of these PI events

involved dose rates in excess of 25 R/hr at 30 centimeters or in excess of 500 R/hr at

1 meter. Barriers were evaluated for failure and to determine if there were any barriers

left to prevent personnel access. Unintended exposures exceeding 100 millirem total

effective dose equivalent (or 5 rem shallow dose equivalent or 1.5 rem lens dose

equivalent) were evaluated to determine if there were any regulatory overexposures or if

there was a substantial potential for an overexposure.

This inspection constitutes one sample as defined in IP 71121.01-5.

b.

Findings

No findings of significance were identified.

.3

Job-In-Progress Reviews

a.

Inspection Scope

The inspectors observed the following two jobs that were being performed in radiation

areas, airborne radioactivity areas, or high radiation areas for observation of work

activities that presented the greatest radiological risk to workers:

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Enclosure

Troubleshooting Pressurizer Heater Breaker; and

Negative Reactivity Testing of the Spent Fuel Pool Racks.

The inspectors reviewed radiological job requirements for these activities, including

RWP requirements and work procedure requirements.

This inspection constitutes one sample as defined in IP 71121.01-5.

Job performance was observed with respect to the radiological control requirements to

assess whether radiological conditions in the work area were adequately communicated

to workers through pre-job briefings and postings. The inspectors evaluated the

adequacy of radiological controls, including required radiation, contamination, and

airborne surveys for system breaches; radiation protection job coverage, including any

applicable audio and visual surveillance for remote job coverage; and contamination

controls.

This inspection constitutes one sample as defined in IP 71121.01-5.

a.

Findings

No findings of significance were identified.

.4

High Risk Significant, High Dose Rate, High Radiation Area, and Very High Radiation

Area Controls

a.

Inspection Scope

The inspectors held discussions with the Radiation Protection Manager concerning high

dose rate, high radiation area, and very high radiation area controls and procedures,

including procedural changes that had occurred since the last inspection, in order to

assess whether any procedure modifications substantially reduced the effectiveness and

level of worker protection.

This inspection constitutes one sample as defined in IP 71121.01-5.

The inspectors discussed with radiation protection supervisors the controls that were in

place for special areas of the plant that had the potential to become very high radiation

areas during certain plant operations. The inspectors assessed if plant operations

required communication beforehand with the radiation protection group, so as to allow

corresponding timely actions to properly post and control the radiation hazards.

This inspection constitutes one sample as defined in IP 71121.01-5.

The inspectors conducted plant walkdowns to assess the posting and locking of

entrances to high dose rate, high radiation areas, and very high radiation areas.

This inspection constitutes one sample as defined in IP 71121.01-5.

b.

Findings

No findings of significance were identified

15

Enclosure

.5

Radiation Worker Performance

a.

Inspection Scope

During job performance observations, the inspectors evaluated radiation worker

performance with respect to stated radiation safety work requirements. The inspectors

evaluated whether workers were aware of any significant radiological conditions in their

workplace, of the RWP controls and limits in place, and of the level of radiological

hazards present. The inspectors also observed worker performance to determine if

workers accounted for these radiological hazards.

This inspection constitutes one sample as defined in IP 71121.01-5.

The inspectors reviewed radiological problem reports for which the cause of the event

was due to radiation worker errors to determine if there was an observable pattern

traceable to a similar cause and to determine if this perspective matched the corrective

action approach taken by the licensee to resolve the reported problems. Problems or

issues with planned or completed corrective actions were discussed with the Radiation

Protection Manager.

This inspection constitutes one sample as defined in IP 71121.01-5.

b.

Findings

No findings of significance were identified.

.6

Radiation Protection Technician Proficiency

a.

Inspection Scope

During job performance observations, the inspectors evaluated radiation protection

technician performance with respect to radiation safety work requirements. The

inspectors evaluated whether technicians were aware of the radiological conditions in

their workplace, the RWP controls and limits in place, and if their performance was

consistent with their training and qualifications with respect to the radiological hazards

and work activities.

This inspection constitutes one sample as defined in IP 71121.01-5.

The inspectors reviewed radiological problem reports for which the cause of the event

was radiation protection technician error to determine if there was an observable pattern

traceable to a similar cause and to determine if this perspective matched the corrective

action approach taken by the licensee to resolve the reported problems.

This inspection constitutes one sample as defined in IP 71121.01-5.

b.

Findings

No findings of significance were identified.

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Enclosure

4.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1

Reactor Coolant System Leakage

a.

Inspection Scope

The inspectors sampled licensee submittals for the Reactor Coolant System

Leakage performance indicator for the period from the fourth quarter 2007 through

the third quarter 2008. To determine the accuracy of the PI data reported during those

periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI)

Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 5, was used. The inspectors reviewed the licensees operator logs and verified

the accuracy of a sample of calculations for the period of October 2007 through

September 2008 to validate the licensees submittals. 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 of significance were identified.

.2

Unplanned Transients per 7000 Critical Hours

a.

Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Transients per

7000 Critical Hours performance indicator for the period from the fourth quarter 2007

through the third quarter of 2008. To determine the accuracy of the PI data reported

during those periods, PI definitions and guidance contained in the NEI Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 5, was used. The

inspectors reviewed the licensees operator narrative logs and NRC Integrated

Inspection Reports for the period of October 2007 through September 2008 to validate

the accuracy of the submittals. Documents reviewed are listed in the Attachment to this

report.

This inspection constituted one unplanned transients per 7000 critical hours sample as

defined in IP 71151-05.

b.

Findings

No findings of significance were identified.

.3

Safety System Functional Failures

a.

Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures

performance indicator for the period from the fourth quarter 2007 through the third

17

Enclosure

quarter 2008 to determine the accuracy of the PI data reported during those periods,

PI definitions and guidance contained in the NEI Document 99-02, Regulatory

Assessment Performance Indicator Guideline, Revision 5, and NUREG-1022, Event

Reporting Guidelines 10 CFR 50.72 and 50.73," definitions and guidance, were used.

The inspectors reviewed licensee event reports for the period of October 2007 through

September 2008 to validate the accuracy of the submittals. Documents reviewed are

listed in the Attachment to this report.

This inspection constituted one safety system functional failures sample as defined in

IP 71151-05.

.4

Mitigating Systems Performance Index - Cooling Water Systems

a.

Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance

Index (MSPI) - Cooling Water Systems performance indicator for the period from the

fourth quarter 2007 through the third quarter of 2008 to determine the accuracy of the

PI data reported during those periods, PI definitions and guidance contained in the

NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 5, were used. The inspectors reviewed the licensees operator narrative logs,

condition reports, MSPI derivation reports, event reports, and NRC Integrated Inspection

Reports for the period of October 2007 through September 2008 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 issue report database to determine if any

problems had been identified with the PI data collected or transmitted for this indicator

and none were identified. Documents reviewed are listed in the Attachment to this

report.

This inspection constituted one MSPI cooling water system sample as defined in

IP 71151-05.

b.

Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152)

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

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Physical Protection

.1

Routine Review of items Entered Into the Corrective Action Program

a.

Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities

and plant status reviews to verify that they were being entered into the licensees CAP at

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Enclosure

an appropriate threshold, that adequate attention was being given to timely corrective

actions, and that adverse trends were identified and addressed. Attributes reviewed

included: the complete and accurate identification of the problem; that timeliness was

commensurate with the safety significance; that 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 attached List of Documents Reviewed.

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 of significance 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 condition report 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.

b.

Findings

No findings of significance were identified.

.3

Semi-Annual Trend Review

a.

Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to

identify trends that could indicate the existence of a more significant safety issue. The

inspectors review was focused on repetitive equipment issues, but also considered the

results of daily inspector CAP item screening discussed in Section 4OA2.2 above,

licensee trending efforts, departmental performance reports and metrics, and licensee

human performance results. The inspectors review nominally considered the 6 month

period of July 2008 through December 2008, although some examples expanded

beyond those dates where the scope of the trend warranted.

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Enclosure

The inspectors compared and contrasted their results with the results contained in the

licensees assessments. Corrective actions associated with a sample of the issues

identified in the licensees trending reports were reviewed for adequacy.

This review constituted a single semi-annual trend inspection sample as defined in

IP 71152-05.

b.

Findings

No findings of significance were identified.

.4

Annual Sample: Review of Operator Workarounds

a.

Inspection Scope

The inspectors evaluated the licensees implementation of their process used to identify,

document, track, and resolve operational challenges. Inspection activities included, but

were not limited to, a review of the cumulative effects of the Operator Work Arounds on

system availability and the potential for improper operation of the system, for potential

impacts on multiple systems, and on the ability of operators to respond to plant

transients or accidents.

The inspectors performed a review of the cumulative effects of Operator Work Arounds.

The documents listed in the Attachment were reviewed to accomplish the objectives of

the inspection procedure. The inspectors reviewed both current and historical

operational challenge records to determine whether the licensee was identifying operator

challenges at an appropriate threshold, had entered them into their CAP, and proposed

or implemented appropriate and timely corrective actions which addressed each issue.

Reviews were conducted to determine if any operator challenge could increase the

possibility of an Initiating Event, if the challenge was contrary to training, required a

change from long-standing operational practices, or created the potential for

inappropriate compensatory actions. Additionally, all temporary modifications were

reviewed to identify any potential effect on the functionality of Mitigating Systems,

impaired access to equipment, or required equipment uses for which the equipment was

not designed. Daily plant and equipment status logs, degraded instrument logs, and

operator aids or tools being used to compensate for material deficiencies were also

assessed to identify any potential sources of unidentified operator workarounds.

This review constituted one operator workaround annual inspection sample as defined in

IP 71152-05.

b.

Findings

No findings of significance were identified.

.5

Selected Issue Follow-Up Inspection: Criticality Controls in the Spent Fuel Pool

a.

Inspection Scope

In July of 2008, the licensee tested some spent fuel storage rack locations to determine

if the neutron poison built into the storage rack continued to meet assumptions in the

20

Enclosure

criticality analysis. The testing revealed that the neutron absorption capability of the

Spent Fuel Pool racks had degraded and in some cases no longer met assumptions

contained within the criticality analysis. The licensee implemented additional criticality

controls in the spent fuel pool and informed the NRC of the controls by letter dated

August 27, 2008. After reviewing the controls, the NRC issued Confirmatory Action

Letter (CAL) RIII-08-003 to confirm the commitments made by Entergy Nuclear

Operations.

During this inspection period, the inspectors validated that the licensee implemented the

requirements of the CAL. Specific actions included:

review of the licensees basis for criticality safety for proposed fuel moves;

verification that fuel moves complied with CAL requirements;

observation of additional testing of the spent fuel pool neutron absorption

capability.

The inspectors concluded that the licensee complied with the requirements of the CAL.

This review constituted one in-depth problem identification and resolution sample as

defined in IP 71152-05.

b.

Findings

No findings of significance were identified.

.6

Selected Issue Follow-Up Inspection: Deviation between Estimated and Actual Critical

Positions for the August 9, 2008, Startup

a.

Inspection Scope

The inspectors reviewed the data and associated procedures for the August 9, 2008,

reactor startup from a forced outage. The inspectors also interviewed licensee staff and

searched for relevant operating experience and past similar issues identified by the NRC

at other plants. Corrective action documents related to the issue were reviewed for

appropriate categorization and action. During the August 9, 2008, reactor startup, the

reactor attained criticality with rods withdrawn to a position of 0.28 percent delta rho

above that predicted by the estimated critical position. Although the deviation was below

the TS limit of 1 percent delta rho and the licensee administrative limit of 0.5 percent

delta rho, the deviation was abnormally high. The licensee reviewed the error in

condition report CR-PLP-2008-3439. The cause evaluation concluded the error

occurred due to boron 10 depletion in the primary coolant system. B-10 depletion

occurs due to B-10 burnup via neutron absorption. Naturally occurring boron contains

19.8 atom percent B-10 with the remainder B-11. As B-10 (which has a much larger

neutron absorption cross-section) absorbs neutrons, the ratio of B-10 to B-11 decreases.

This change alters the effective boron poison strength of the primary coolant for a given

boron concentration. When fresh boron is added, the effective boron concentration

changes. In this instance, the licensee added fresh boron during the shutdown but did

not account for it while determining an estimated critical position. As part of the

corrective actions, the licensee identified several items to help address this issue. The

licensee did have some guidance in EM-04-24, their Critical Prediction and Critical

Approach procedure, in regards to when to apply a B-10 correction. The licensee plans

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Enclosure

to enhance this portion of the procedure for clarity and ease of conducting a B-10

correction, if deemed necessary. In addition, the licensee benchmarked other fleet

plants to determine an optimum isotopic sampling frequency to track the depletion of

B-10. The licensee is proceeding with plans to obtain and ship samples for analysis

more frequently.

Based on data provided by the licensee, the last time there was a deviation of this

magnitude or greater was June 1998 with a 0.393 percent delta rho error. Beyond that,

in October 1997 there was a 0.437 percent deviation. The October 1997 deviation was

determined to be mostly due to B-10 depletion. A search for relevant operating

experience and previous findings was conducted with no relevant results. The

inspectors reviewed the licensees reactivity management event classification guidelines

and corrective action process procedure to validate appropriate categorization of the

issue. No deficiencies were identified.

This review constituted one in-depth problem identification and resolution sample as

defined in IP 71152-05.

.7

Selected Issue Follow-Up Inspection: Licensee Compliance with the Station Blackout

(SBO) Rule Assumptions

a.

Inspection Scope

While performing an operability evaluation on inadequate testing of the CR HVAC

system (discussed in Section 1R15 of this report), the inspectors noted that the

licensees revision to the underlying calculation for the systems surveillance test may

not have taken into account SBO Rule (10 CFR 50.63) requirements. The inspectors

interviewed licensee personnel and reviewed design basis documents, the UFSAR, and

docketed correspondence between the NRC and the licensee. The inspectors review

included the analysis performed by the licensee to demonstrate compliance with the

SBO rule. Based on the review, the inspectors concluded the licensee remained

compliant with the license condition for SBO but noted weaknesses in the licensees

program. Noted weaknesses included:

Lack of operations staff awareness of impacts on SBO rule compliance with

elevated temperatures in the control room

Lack of programmatic controls for maintaining compliance with the plants SBO

assumptions

The licensee generated two condition reports (CR-PLP-2008-5023 and

CR-PLP-2008-5074) to address the issue.

This review constituted one in-depth problem identification and resolution sample as

defined in IP 71152-05.

b. Findings

No findings of significance were identified.

22

Enclosure

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)

.1

(Closed) LER 05000255/2008-05-00, Completion of Plant Shutdown Required by TSs

On August 5, 2008, the licensee began a planned shutdown to replace leaking Control

Rod Drive Mechanism seals. At 97 percent power, a relief valve, RV-2006, in the

letdown system lifted resulting in primary coolant leakage in excess of the TS limit of

1 gallon per minute of unidentified leakage. The licensee made a 4-hour report to the

NRC and completed a plant shutdown as required by TSs. The licensee determined that

the relief valve lifted when a second charging pump started per the pressurizer level

control program. Historically, the licensee has experienced difficulties with control of

pressure in the letdown system during operation of charging pumps due to performance

of controllers in the system. In addition, the licensee determined that the setpoint of the

relief valve will drift as a result of previous relief valve lifts. During the outage, the

licensee replaced the relief valve. In this event, leak rates of approximately 4 gallons per

minute occurred when the relief valve lifted. Because the line discharged into a quench

tank with multiple sources, the licensee treated the leakage as unidentified leakage. The

licensee exited the Limiting Condition for Operation (LCO) when the plant entered

Mode 5 and the LCO no longer applied. Documents reviewed as part of this inspection

are listed in the Attachment. The inspectors did not identify any additional safety issues.

This LER is closed.

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

.2

(Closed) LER 05000255/2008-06-00, Emergency Diesel Generator Inoperable in Excess

of TSs Requirements

a.

Inspection Scope

On February 19, 2008, during performance of planned maintenance on the 1-2 EDG,

licensee personnel discovered foreign material (metal fragments) in the valve assembly

area of the 1-2 EDG cylinder 2L. The metal fragments were identified to be broken

pieces of the valve seat spring lock associated with the cylinder 2L inboard exhaust

valve. These fragments were discovered by workers during an unrelated maintenance

activity involving the snubber valves. Due to some physical interference between

components during work, the valve cover for cylinder 2L needed to be removed to

complete some of the snubber valve maintenance. When the cover was removed,

workers noted the spring lock material described above. The licensee performed an

apparent cause evaluation that included a failure analysis performed by Fairbanks

Morse Engine. The licensee determined that the spring lock was damaged due to a

condition discovered in March 2000. While performing maintenance on March 21, 2000,

licensee personnel discovered that the valve yoke retaining lock nut had fallen off one of

the valve assemblies for cylinder 2L. The licensee determined that because of this, the

adjusting screw backed out such that the valve yoke was able to strike the spring seat

instead of the adjusting nut striking the valve stem, as designed. This resulted in cyclical

side loading of the valve assembly which initiated a fatigue crack on the inside diameter

of the spring lock. Eventually it failed, resulting in the pieces discovered on

February 19, 2008. The licensee inspected the other spring locks on the 1-2 EDG and

found no discrepancies. An extent-of-condition review was performed for the 1-1 EDG

by the licensee. The licensee concluded that there was high assurance that a similar

23

Enclosure

condition does not exist on the 1-1 EDG. The licensee plans to inspect valve seat spring

locks for the 1-1 EDG during the next scheduled preventative maintenance outage.

The licensee reviewed the corrective actions for the March 2000 discovery of the lock

nut that fell off and the associated backing-out of the adjusting screw. To resolve the

issue, the nut was returned to the proper position and torqued. In addition, the other

retaining nuts were inspected and found to be acceptable. There were no documented

inspections of any other components in the valve assembly area under the valve cover.

Following the discovery, the licensee did not change the routine preventative

maintenance requirements. The inspectors identified one finding. This LER is closed.

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

b.

Findings

Introduction: On February 19, 2008, a Green self-revealed finding and associated NCV

of TS requirement 3.8.1.b became evident when licensee personnel discovered metal

fragments in the valve assembly area of the 1-2 EDG cylinder 2L. Subsequent

evaluation by the licensee determined that the diesel would not be able to function for its

30-day mission time and was inoperable for a period of time greater than allowed by TS.

Description: While performing maintenance on the 1-2 EDG, licensee personnel noted

metal fragments in the valve cover for the 1-2 EDG. The licensee investigated the

source of the metal fragments and discovered that the spring lock for an exhaust valve

had failed. The licensee reviewed maintenance history for the diesel and determined

that a lock nut had backed off an adjustment screw in 2000. The licensee contracted the

diesel vendor to evaluate the condition of the cylinder head in order to determine the

cause of the spring lock failure. The vendor concluded that the loss of the lock nut

caused the adjusting screw to drift and allowed the yoke arm to contact the valve spring

seat. The abnormal operating condition likely created cracks in the spring lock that

propagated even after replacement of the lock nut. In 2000, the licensee limited

corrective actions to replacing the lock nut and checking the lock nuts on other cylinders.

The licensee did not evaluate potential degradation of other components due to the

abnormal operation of the valve.

The licensee evaluated the as-found condition and concluded that a sufficient amount of

the spring lock remained on the valve to assure continued operation of the EDG for at

least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, the wear rates could not be determined to assure the EDG

would operate for 30 days. The licensee identified that a potential failure mode was loss

of the valve into the associated cylinder and subsequent damage to the turbo charger

through transport of generated debris. As corrective action, the licensee replaced the

spring lock and inspected the others on the 1-2 EDG. An extent of condition was

performed for the 1-1 EDG, and inspections are planned for the 1-1 EDG as well. The

condition was entered into the licensees CAP as CR-PLP-2008-0822.

Analysis: The inspectors determined that the inoperability of the diesel generator for

longer than TS allowed outage time represented a performance deficiency that

warranted a significance determination. Through review of the condition reports related

to the missing lock nut in 2000, the inspectors determined that the licensee could

reasonably be expected to foresee and correct the condition of the cylinder/valve

operating mechanism. In 2000, the licensee did not evaluate potential adverse effects

24

Enclosure

on the valve and related components. Corrective actions at the time also indicated the

remaining lock nuts were only checked hand-tight. The inspectors determined the issue

is more than minor because it affected the mitigating system cornerstone objective of

ensuring the reliability and capability of mitigating systems. The inspectors performed a

phase 1 screen on the issue in accordance with IMC 0609 and determined that since the

EDG was inoperable for greater than the TS allowed outage time, support from the

region-based senior risk analyst was needed to determine risk significance. Based on

vendor analysis, the licensee concluded that the EDG would likely operate in excess of

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, but not for the 30-day mission time required by the license. Since the EDG

would function for the Probable Risk Assessment mission time, the senior risk analyst

determined the issue would screen as Green using the phase 1 worksheets. No cross-

cutting aspect was assigned because the review dated back to 2000, therefore, this

issue is not indicative of current plant performance.

Enforcement: Technical Specification LCO 3.8.1 states, in part, that two diesel

generators each capable of supplying one train of the Class 1E AC electrical power

distribution system shall be operable. The TS action requirement requires a plant

shutdown if the associated EDG is inoperable for greater than 7 days. Contrary to the

required action statements, on February 19, 2008, a failed spring lock for one of the

exhaust valves on the 1-2 EDG was discovered. This resulted in an EDG inoperability

beyond the allowed required action times. The failure was determined to have been the

result of an issue discovered in 2000 involving a lock nut that had fallen off of the

exhaust valve assembly. Further analysis led to a conclusion by the licensee that the

condition would likely allow the EDG to run for the 24-hour Probabilistic Risk

Assessment mission time but not the 30-day mission time. Because the finding is of

very low safety significance and has been entered into the licensees CAP as

CR-2008-0822, this violation of TS requirement 3.8.1.b is being treated as an NCV,

consistent with Section VI.A of the NRC Enforcement Policy.

(NCV 05000255/2008005-02 Emergency Diesel Generator Inoperable in Excess of

TS Requirements).

4OA5 Other Activities

.1

Observations of Security

a.

Inspection Scope

During the inspection period, the inspectors conducted observations of security force

personnel and activities to ensure that the activities were consistent with licensee

security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities

did not constitute any additional inspection samples. Rather, they were considered an

integral part of the inspectors' normal plant status review and inspection activities.

b.

Findings

No findings of significance were identified.

25

Enclosure

.2

Implementation of Temporary Instruction (TI) 2515/176, Emergency Diesel generator

Technical Specification Surveillance Requirements Regarding Endurance and Margin

testing

a. Inspection Scope

The objective of TI 2515/176 was to gather information to assess the adequacy of

nuclear power plant emergency diesel generator endurance and margin testing as

prescribed in plant-specific TSs. The inspectors reviewed the licensee's TS,

procedures, and calculations, and interviewed licensee personnel to complete the TI.

The information gathered for this TI was forwarded to the Office of Nuclear Reactor

Regulation for further review and evaluation on December 17, 2008. This TI is

complete at Palisades Nuclear Plant; however, this TI 2515/176 will not expire until

August 31, 2009. Additional information may be required after review by the Office of

Nuclear Reactor Regulation.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

.1

Exit Meeting Summary

On January 22, 2009, the inspectors presented the inspection results to Thomas Kirwin

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. A follow-up phone exit meeting was held by the NRC with

Ms. B. Dotson and Mr. C. Sherman on February 2, 2009 to discuss additional inspection

results.

.2

Interim Exit Meetings

Interim exits were conducted for:

The annual review of emergency action level and emergency plan changes with

the licensee's Senior Emergency Planning Coordinator, Mr. M. Sweet via

telephone on December 30, 2008.

The results of the access control to radiologically significant areas inspection with

the Plant Manager, Mr. T. Kirwin, and other members of your staff, on

December 12, 2008.

A telephone exit for TI 2515/176 was conducted with John Broschak,

Entergy/Engineering Director and other Licensee staff on December 2, 2008.

The inspectors confirmed that none of the potential report input discussed was

considered proprietary.

26

Enclosure

4OA7 Licensee-Identified Violations

The following violation of very low significance (Green) were identified by the licensee

and are violations of NRC requirements which meet the criteria of Section VI of the

NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.

Technical Specification 5.7.1 requires areas with dose rates greater than

100 mR/hr to be posted as a High Radiation Area and barricaded. Contrary to this,

on October 18, 2008, the high radiation area posting and barricade did not provide

an adequate barricade around areas of the room having dose rates greater than

100 mR/hr in the west engineered safeguards room. This was identified in the

licensees corrective action program as CR-PLP-2008-04310. The finding was

determined to be of very low safety significance because it was not an ALARA

planning issue, there was no overexposure nor substantial potential for

overexposure, and the licensees ability to assess dose was not compromised.

ATTACHMENT: SUPPLEMENTAL INFORMATION

1

Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

C. Schwarz, Site Vice President

V. Beilfuss, Project Manager

J. Broschak, Engineering Director

N. Brott, Emergency Preparedness Coordinator

J. Burnett, RETS/REMP Specialist

T. Davis, Regulatory Compliance

B. Dotson, Regulatory Compliance

J. Fontaine, Senior Emergency Planning Coordinator

J. Ford, Corrective Action Manager

T. Kirwin, Plant General Manager

L. Lahti, Licensing Manager

B. Nixon, Assistant Operations Manager

T. Shewmaker, Chemistry Manager

C. Sherman, Radiation Protection Manager

M. Sicard, Operations Manager

G. Sleeper, Assistant Operations Manager

E. Williams, Radiation Protection Supervisor

Nuclear Regulatory Commission

J. Giessner, Chief, Branch 4

2

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened 05000255/2008005-01

NCV

Inadequate Testing of Control Room Chillers (Section 1R15)05000255/2008005-02

NCV

Emergency Diesel Generator Inoperable in Excess of

Technical Specification Requirements (Section 4OA3)

Closed 05000255/2008005-01

NCV

Inadequate Testing of Control Room Chillers (Section 1R15)05000255/2008005-02

NCV

Emergency Diesel Generator Inoperable in Excess of

Technical Specification Requirements (Section 4OA3)

05000255/2008005 LER

Completion of Plant Shutdown Required by Technical

Specifications (Section 4OA3)

05000255/2008006 LER

Emergency Diesel Generator Inoperable in Excess of

Technical Specification Requirements (Section 4OA3)

3

Attachment

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.

1R01 Adverse Weather Protection

- CR-PLP-2007-5672, 1-3 DG cold weather vent covers fall out of the vents, November 7, 2007

- CR-PLP-2007-5934, The Insulating Box for SIRW Tank Level Instrument LT-0331 is Bent,

November 21, 2007

- SOP-23, Plant Heating System, Revision 27

1R04 Equipment Alignment

- Drawing M-204, Safety Injection, Containment Spray, and Shutdown Cooling System

- Drawing M-208, Service Water System

- Drawing M-213, Service Water, Screen Structure, and Chlorinator

- FSAR Chapter 9.1.1, Service Water System, Revision 25

- Procedure No. 4.02, Control of Equipment, Revision 47

- SOP-15, Service Water System, Revision 47

- SOP-22, Emergency Diesel Generators, Revision 45

- SOP-3, High Pressure Safety Injection System, Revision 75

1R05 Fire Protection

- Fire Hazard Analysis, Palisades Plant, Revision 7

1R11 Licensed Operator Requalification Program

- Procedure SEP, Site Emergency Plan, Revision 16

- Simulator Exercise Guide for November 17, 2008 Licensed Operator Requalification Drill

1R12 Maintenance Effectiveness

- CR-PLP-2007-01807, K-6B Placed in Maintenance Rule Category a(1), May 3, 2007

- CR-PLP-2007-01145, K-6B exceeds Maintenance Rule Unavailability Hours, March 13, 2007

- CR-PLP-2008-01424, EG-30A, 1-2 Emergency Diesel Generator Alarm Panel Failure (K-6B),

March 28, 2008

- CR-PLP-2008-03141, During the Performance of MO-7A-2, Emergency Diesel Generator 1-2,

Difficulties were Encountered in Attempting to Match Generator Output Voltage to Match Bus

1D Voltage, July 21, 2008

- CR-PLP-2008-03142, While Increasing Load on 1-2 Diesel Generator, the Cyclinder Petcock

for 9R Came Open, July 21, 2008

- CR-PLP-2008-0822, Broken Valve Keeper (Spring Seat Lock) Found on Cylinder 2-L of the 1-

2 Emergency Diesel Generator, February 19, 2008

- EGAD-EP-10, Maintenance Rule Scoping Document, Revision 5

- EM-20-01, Emergency Diesel Generator Reliability Program, Revision 2

4

Attachment

- Emergency Diesel Generator Related Plant Operating Log Entries from May 2007 thru

September 2008

- Emergency Diesel Generators Palisades Plant Health Report, 3rd Quarter 2008

- EN-DC-198, Emergency Diesel Generator Reliability Program, Revision 1

- EN-DC-203, Maintenance Rule Program, Revision 1

- EN-DC-204, Maintenance Rule Scope and Basis, Revision 1

- EN-DC-205, Maintenance Rule Monitoring, Revision 2

- EN-DC-206, Maintenance Rule (a)(1) Process, Revision 1

- NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at

Nuclear Power Plants, Revision 2

- Palisades Plant Maintenance Rule Unavailability Performance Indicator Data thru

September 2008

1R13 Maintenance Risk Assessments and Emergent Work Control

- Procedure No. 4.02, Control of Equipment, Revision 47

- SOP-3, High Pressure Safety Injection System, Revision 75

- FSAR Chapter 9.7, Auxiliary Feedwater System, Revision 26

1R15 Operability Determinations

- Calculation 022-M-001, Control Room Required Cooling Load, Revision 0 and markup

- CR-4580, Diesel Load Calculation, November 11, 2008

- CR-PLP-2008-03993, RT-202, Control Room Heat Removal Capability Test Operability Issue,

September 24, 2008

- CR-PLP-2008-04344, Control room HVAC mounting configuration of solenoid valves to their

positioners not in accordance with design drawings, October 21, 2008

- CR-PLP-2008-04580, Diesel Load Calculation did not Account for Worst Case Containment

Air Cooler Load, November 11, 2008

- CR-PLP-2008-4431, Containment Spray Header Pressure Indicator Indicating Below

Technical Specification Limit after Maintenance, October 28, 2008

- DBD 1.06, Control Room HVAC System, Revision 7

- DBD-2.03, Containment Spray System, Revision 7

- EA-SBO-1, Station Blackout Coping Evaluation for 10CFR50.63, Revision 2

- EC Markup EC-10988, Control Room Cooling Load, Revision 0

- ESSO-1, Containment Spray Header Fill, Revision 12

- FSAR Chapter 6.2, Containment Spray, Revision 26

- FSAR Chapter 9.8, Heating, Ventilation, and Air Conditioning System, Revision 26

- MO-29, Engineered Safety System Alignment, Revision 36

- RT-202, Control Room HVAC Heat Removal Capability, Revisions 3, 9, and 10

1R18 Plant Modifications

- EC-10638, Disable Fast Transfer

1R19 Post Maintenance Testing

- CR-PLP-2006-2485, Control Rods Failed RO-19, May 2, 2006

- CR-PLP-2480, CRD-8 Failed to Drive CRD-8, May 1, 2006

- DBD-1.03, Auxiliary Feedwater System Design Basis Document, Revision 7

- FSAR Chapter 9.7, Auxiliary Feedwater System, Revision 26

5

Attachment

- Procedure No. 9.20, Attachment 3, Process Control Sheet dtd 11/5/08 for Auxiliary Feedwater

System 18-Month Test Procedure, Revision 24

- RO-127, Auxiliary Feedwater System, 18-Month Test Procedure, Revision 7

- WO #51634185, P/S-0737A, Replace Power Supply During 1R20

- WO 00168249, MC1000-03 has Failed, October 12, 2008

- WO 0019168, RO-19 Control Rod Position Verification, May 2, 2006

- WO 51631052, Control Rod Position Verification, October 12, 2007

- WO002981980, Control Rod Position Verification, May 3, 2006

- EC-9282, Provide UPS Power for Perimeter Intrusion Detection and Monitoring Equipment,

October 17, 2008

- WO 00160408, Upgrade to Security UPS System, October 17, 2008

1R22 Surveillance Testing

- ASME OM Code 2001, Subsection ISTB

- EM-09-04, Inservice Testing of Selected Safety-Related Pumps, Revision 23

- QO-15 Basis Document for Inservice Test Procedure-Component Cooling Water Pumps,

Revision 14

- QO-15, Inservice Test Procedure, Component Cooling Water Pumps, Revision 26

- RO-146, Comprehensive Pump Test Procedure, Component Cooling System Pumps P-52A,

P-52B, and P-52C, Revision 1

- RO-52, Fire Suppression Water System Functional Test; Fire Pump Capacity Test,

Revision 27

- RPS-I-7, Anticipated Transient Without Scram (ATWS) Calibration/Functional Test,

October 22, 2008

- WO 51662292, Fire Suppress Wtr Sys Pump Capacity Func, September 23, 2008

1EP4 Emergency Action Level and Emergency Plan Changes

- Attachment 9.2, 10 CFR 50.54(q) Evaluation/Screening, Revisions 17 and 49

- EI-1, Emergency Classification and Actions, Revisions 48 and 49

- Palisades Nuclear Plant Site Emergency Plan, Revisions 16 and 17

1EP6 Drill Evaluation

- Procedure SEP, Site Emergency Plan, Revision 16

- NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5

- Fourth Quarter Integrated Training Drill, November 5, 2008

- Tabletop Drill, December 17, 2008

2OS1 Access Control to Radiologically Significant Areas

- CR-PLP-2007-04378, Ensure that all Requirements Associated with Control of Very High

Radiation Areas are Properly Assessed, dated September 23, 2007

- CR-PLP-2007-4383, Concerns Have Been Made Regarding Use of the New Fuel Elevator,

dated September 24, 2007

- CR-PLP-2008-04310, West Engineered Safeguards Room Dose Rates Warranted High

Radiation Area Posting, dated October 18, 2008

- EAR 2001-0518, Evaluate Current Mechanical Stop on New Fuel Elevator for Design

Function, Revision 0

- EN-RP-100, Radworker Expectations, Revision 2

6

Attachment

- EN-RP-101, Access Control For Radiologically Controlled Areas, Revision 4

- EN-RP-108, Radiation Protection Posting, Revision 7

- EN-RP-141, Job Coverage, Revision 4

- EN-RP-151, Radiological Diving Revision 2

- QA-14-2008-PLP-01, Quality Assurance Report, Radiation Protection, dated May 14, 2008

- Radiation Work Permit 20080015 and Associated ALARA File, Containment Activities During

Power Operations, Revision 3

- Radiation Work Permit 20080108 and Associated ALARA File, Badger Testing in the Spent

Fuel Pool, Revision 0

- SC-91-095-07, New Fuel Elevator Travel Limit Switch and Control Console Modification,

Revision 1

- Snapshot Assessment, Incorporation of Radiation Protection Hold Points and Radiation

Protection Notification into Palisades Operation Procedures, June 13, 2008

4OA1 Performance Indicator Verification

- Cooling Water System Mitigating System Performance Indicator Validation Packages, Fourth

Quarter 2007 thru Third Quarter 2008

- DWO-1, Operators Daily/Weekly Items Modes 1,2,3, and 4 Basis Document, Revision 53

- DWO-1, Operators Daily/Weekly Items Modes 1,2,3, and 4, Revision 84

- MSPI Margin Report for Cooling Water System, Period ending September 2008

- LER 05000255/2008-002-00, Breaker Cubicle Failure Results in High Pressure Safety

Injection Pump Inoperability

- LER 05000255/2007-007-00, Fuel Handling Area Ventilation System Inoperable

- LER 05000255/2007-008-00, Auxiliary Feedwater Pump Inoperable in excess of technical

Specification Limits Due to a Postulated steam Line Break

- Log Entries associated with Cooling Water System Equipment, 1 October 2007 thru 30

September 2008

- Selected Palisades Plant Operating Logs from Fourth Quarter 2007 thru Third Quarter 2008

- NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5

4OA2 Problem Identification and Resolution

- 06-01 OWA, Auxiliary Feedwater Pumps P-8A, B, C Suction Source, May 23, 2008

- 07-02 OWA, 2400VAC Busses 1C, 1D, 1E, May 14, 2007

- 08-01 OB, 2400/4160VAC MOC Switch Required Inspections, May 14, 2008

- 08-01 OWA, Condensate Pump P-2B Degraded Pressure, December 6, 2007

- Corrective Action X, Basis for Fuel Assembly Moves in Palisades Spent Fuel Pool,

November 6 2008

- CR-PLP-2008-3439, The Estimated Critical Position, although Well Within Acceptance

Criteria, was not as Accurate as Typical for Palisades, August 9, 2008

- CR-PLP-2008-01748, 1-1 Diesel Fuel Oil Supply Line Rubbing, April 19, 2008

- CR-PLP-2008-01749, 1-1 Diesel Fuel Oil Supply Line Rubbing, April 19, 2008

- CR-PLP-2008-05023, NRC has questioned the basis, justification, and control of initial control

room temperature assumption in the heatup analysis of the Palisades station blackout (SBO)

event, December 12, 2008

- CR-PLP-2008-05074, An Administrative Issue was Identified During Review of Documents

Provided to the NRC Related to Palisades Compliance with SBO Rule, December 17, 2008

- EA-APR-95-023, Room heatup after loss of ventilation under Appendix R scenario in the

control room, 1C and 1D switchgear rooms, battery rooms, containment area, and EDG rooms

- EM-04-24, Palisades Critical Prediction and Critical Approach, Revision 8

7

Attachment

- EN-LI-102, Corrective Action Process, Revision 10

- EN-OP-103, Reactivity Management Program, Revision 3

- FSAR Chapter 8.1.5, Station Blackout, Revision 25

- Letter to Gerald Slade, Palisades Plant Station Blackout Analysis, Safety Evaluation

(TAC No. 68578), May 20, 1991

- Letter to Gerald Slade, Palisades Plant-Station Blackout Analysis-Safety Evaluation

(TAC No. M68578), June 25, 1992

- Letter to John Ellegood, Notification of Fuel Moves Planned -Palisades Spent Fuel Pool

Region 1 to Region 2, November 6, 2008

- Letter to the NRC, Palisades Plant-Station Blackout Analysis, Safety Evaluation

(TAC No. 68578), August 1, 1991

- NET-299-01, BADGER Test Campaign at Palisades Nuclear Plant, October 8, 2008

- NUMARC 87-00, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station

Blackout at Light Water Reactors, Revision 1

- ODMI Implementation Action Plan, P-2B Condensate Pump Degraded Performance,

November 18, 2007

- Operator Work Arounds / Burdens, October 14, 2008 Index

- Palisades Administrative Procedure 4.12, Operator Work-Around Program, Revision 5

- Palisades Operator Aggregate Index Reports, July through October 2008

- CR-PLP-2006-04702, Adverse Trend in Power Supply Reliability, October 3, 2006

- EN-LI-121, Entergy Trending Process Third Quarter Report, Revision 7

- CR-PLP-2008-04279, Adverse Trend in Power Supplies, October 16, 2008

- CR-PLP-2008-03203, Emerging Trend in Control of Equipment Positioning, July 25, 2008

- SOP-24, Ventilation and Air Conditioning System, Revision 52

- Letter to NRC, Commitments to Address degraded Spent Fuel Pool Storage Rack Neutron

Absorber, August 27, 2008

- Spent Fuel Pool Shuffle Sequence, November 7, 2008

- Letter to John Ellegood, Notification of Fuel Moves Planned -Palisades Spent Fuel Pool

region 1 to region 2, November 17, 2008

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

- CR-PLP-2008-03328, Plant Exceeded Technical Specification Limit for Unidentified Leak

Rate, August 5, 2008

- LER 05000255/2008-05-00, Completion of Plant Shutdown required by Technical

Specifications, Revision 0

- LER 05000255/2008-06-00, Emergency Diesel Generator Inoperable in Excess of Technical

Specification Requirements, Revision 0

- CR-PLP-2008-00822, Broken Valve Keeper (Spring Seat Lock) Found on Cylinder 2L of the

1-2 Emergency Diesel Generator, February 19, 2008

- CR-PLP-2000-00556, EDG 1-2 Valve Yoke Retaining Nut on Cylinder 2L Was Not Attached,

March 21, 2000

- EPS-M-14, Diesel Generator Periodic Maintenance, Revision 17

- EPS-M-15, Diesel Generator 1-2 Refueling Frequency Maintenance, Revision 1

4OA5 Other Activities

- Procedure No. RO-128-1; Diesel Generator 1-1 24 Hour Load Run; Revision 13

- Procedure No. RO-128-2; Diesel Generator 1-2 24 Hour Load Run; Revision 12

- Calculation No. EA-ELEC-LDTAB-005; Emergency Diesel Generator 1-1 & 1-2 Steady State

Loading; Revision 8

8

Attachment

LIST OF ACRONYMS USED

AFW

Auxiliary Feed Water

CAL

Confirmatory Action Letter

CAP

Corrective Action Program

CFR

Code of Federal Regulations

CR

Condition Report

CR HVAC

Control Room Heating, Ventilation and Air Conditioning

EDG

Emergency Diesel Generator

HPSI

High Pressure Safety Injection

IMC

Inspection Manual Chapter

LCO

Limiting Condition for Operations

LER

Licensee Event Report

MSPI

Mitigating Systems Performance Index

NEI

Nuclear Energy Institute

NCV

Non-Cited Violation

NRC

U.S. Nuclear Regulatory Commission

PI

Performance Indicator

RWP

Radiation Work Permits

SBO

Station Black Out

SDP

Significance Determination Process

TS

Technical Specification

UFSAR

Updated Final Safety Analysis Report

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