IR 05000255/2012009
| ML12115A220 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/24/2012 |
| From: | Stone A M NRC/RGN-III/DRS/EB2 |
| To: | Vitale A Entergy Nuclear Operations |
| Carey Brown | |
| References | |
| IR-12-009 | |
| Download: ML12115A220 (14) | |
Text
April 24, 2012
Mr. Anthony Vitale Vice-President, Operations Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT: PALISADES NUCLEAR PLANT POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL, INSPECTION REPORT 05000255/2012009(DRS)
Dear Mr. Vitale:
On March 16, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed Phase III of the Post-Approval Site Inspection for License Renewal at your Palisades Nuclear Plant. The enclosed report documents the inspection activities, which were discussed on March 16, 2012, with Mr. B. Davis, Engineering Director, and other members of your staff. This inspection was an examination of activities conducted under your renewed license as they relate to the completion of commitments made during the renewal license application process and compliance with the Commission's rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. On the basis of the sample selected for review, no findings were identified. The NRC staff did not identify any instances of incomplete commitments with respect to timeliness or adequacy. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA by S. Sheldon for/ Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-255;72-007 License No. DPR-20
Enclosure:
Inspection Report 05000255/2012009
w/Attachment:
Supplemental Information cc w/encl: Distribution via ListServŽ Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-255 License No: DPR-20 Report No: 05000255/2012009 Licensee: Entergy Nuclear Operations, Inc.
Facility: Palisades Nuclear Plant Location: Covert, MI Dates: March 12-16, 2012 Inspectors: C. Brown, Reactor Engineer (Lead) S. Sheldon, Senior Reactor Engineer Approved by: Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety 1 Enclosure
SUMMARY OF FINDINGS
IR 05000255/2012009; 3/12/2012-3/16/2012; Palisades Nuclear Plant; Routine Post-License-Renewal Approval Site Inspection. This report covers a 1-week inspection by region based inspectors. No findings of significance were identified. The NRC's 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 No findings were identified.
B. Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA5 Other Activities
.1 Post-Approval Site Inspection for License Renewal (Phase III) - Inspection Procedure 71003
a. Inspection Scope
The inspectors reviewed the licensee's extent-of-condition and extent-of-cause investigations, and the corrective actions that resulted from the open condition reports (CRs) initiated during the previous Post-Approval Site Inspection for License Renewal (Inspection Report (IR) 05000255/2011008). Particular emphasis was placed on the five findings with three associated Non-Cited Violations (NCVs). The inspectors also reviewed the results and actions from self-assessment activities in regards to aging management. The inspectors reviewed work activities, associated with aging management programs, completed between March 2011 and this inspection; the licensee's use of operating experience (OE) related to aging management; and the integration of aging management program (AMP) into the licensee's routine programs, practices, and work activities, particularly in the corrective action program (CAP).
Due to questions on the licensee's fatigue monitoring program (FMP) requirements and activities from IR 05000255/2012007, completed on February 17, 2012, the inspectors continued reviewing the FMP during this inspection.
b. Assessment (1) Condition Reports from IR 2011008 Findings The inspectors conducted interviews and reviewed CAP actions for each finding, and associated NCV (if applicable), including supporting documents and completed surveillance records or work items for the following: (a) Failure to Assure Adequate Resolution for Remote Visual Examinations (NCV 05000255/2011008-01); (b) Test Results for Diesel Fuel Oil Tanks Not Evaluated (NCV 05000255/2011008-02); (c) Tank T-10A Not Age Managed for Effect of Identified Water (NCV 05000255/2011008-03); (d) Flow Accelerated Corrosion Program Acceptance Limits Not in Accordance with Design Standard (FIN 05000255/2011008-04); and (e) Failure to Implement Adequate Oil Sampling and Analysis Aging Management Program (FIN 05000255/2011008-05).
3 Enclosure Observations The inspectors found the assessments and corrective actions for the findings to be adequate. The licensee had taken reasonable corrective actions to ensure meeting and continuing to integrate the AMP commitments into the existing programs. Specific measures had been taken to address each of the deficiencies associated with the individual findings.
Findings No findings of significance were identified. (2) Other CRs Initiated as a Result of IR 2011008 The inspectors reviewed the resolution of CRs initiated as a result of the previous inspection. The inspectors reviewed the completed evaluations, and the corrective actions for proper prioritization, (root cause, apparent cause, and common cause) and probable effectiveness, especially as to addressing aging issues.
Findings No findings of significance were identified. (3) Self-Assessments The inspectors assessed the licensee staff's ability to identify and enter issues into the CA program, prioritize and evaluate issues, and implement effective corrective actions through efforts from self-assessments. Specifically, the inspectors reviewed Snapshot Assessment, LO-PLPLO-2010-00132 CA-1, "Palisades NRC IP71003 Phase III Inspection Readiness," dated September 11, 2011, for aging management aspects, as well as the overall self-assessment effort.
Observations The inspectors found the snapshot assessment to be thorough and insightful. The licensee identified that previous corrective actions (CAs) had not been effective and had initiated new CRs to address the deficiencies. The new CRs were detailed and addressed the aging management aspects appropriately. Findings No findings of significance were identified. (4) AMP Work Activities Completed from March 2011 to Present The inspectors reviewed the completed individual work items associated with AMPs, particularly for ties to the AMPs and for the integration of the AMP requirements into the routine planning and work order evolutions. The items reviewed included five boric acid evaluation/screenings; emergency diesel generator (EDG) jacket water and lube oil cooler inspection (and the associated CRs); a Maintenance Rule (a)(1) plan for roof structures; 2011 3rd quarter oil sampling and analysis reports; Fatigue Monitoring Program Summary Reports and Summary Cycle Reports for Cycles 19, 20, and 21; two fuel oil monitoring and maintenance work orders; and a utility water storage tank, T-91, internal inspection work order.
4 Enclosure Observations The inspectors found the work activities to be thorough and complete. However, it was not always clear that the activity was tied to an aging management commitment. For example, the lube oil sampling and analysis program was driven solely through the licensee's pre-existing preplanned preventive maintenance items (PMs). There was no clear identification that the PMs were fulfilling aging management commitments and no clear requirements to review AMP commitments before changing or eliminating the PMs. Additionally, the boric acid evaluations had no discernible connection to the associated AMPs. Based on the observations in this area, the inspectors had a concern for how the licensee ensured that aging management activities would not be delayed, changed, or cancelled without the program owner and/or management involvement. This concern is addressed in Section 4OA5.1.b(6) below.
Findings No findings of significance were identified. (5) Use of Operating Experience in Aging Management The inspectors reviewed the licensee's implementation of the facility's operating experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures and completed evaluations of aging management OE issues and events, and interviewed individuals with respect to the use of OE with respect to aging management. The inspectors' review was to determine whether the licensee was effectively integrating aging management OE into the performance of daily activities, whether evaluations of issues were proper, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors looked particularly at the licensee's handling of of the following:
- Information Notice (IN) 2011-15, "Steel Containment Degradation and Associated License Renewal Aging Management Issues";
- IN 2011-20, "Concrete Degradation Concrete Degradation By Alkali-Silica Reaction";
- Regulatory Issue Summary (RIS) 2011-05, "Information On Revision 2 To The Generic Aging Lessons Learned Report For License Renewal Of Nuclear Power Plants";
- RIS 2011-07, "License Renewal Submittal Information for Pressurized Water Reactor Internals Aging Management"; and
- RIS 2011-14, "Metal Fatigue Analysis Performed By Computer Software." Observations With one exception, the inspectors determined that the licensee was adequately reviewing and incorporating aging management OE into the plants processes, procedures, and work activities. However, the site had not evaluated RIS 2011-05.
The inspectors noted that RIS 2011-005 was screened by the fleet OE team on July 13, 2011, and was distributed to each Entergy site. An OE Written Action (NRC-RIS-2011-05-A2-IPC-0001) was initiated and work task LO-WTIPC-2011-00029 5 Enclosure CA 116 was assigned to corporate licensing to review the RIS. The work task was subsequently closed to a headquarters condition report (CR-HQN-2011-01045). The response CA 6 to CR-HQN-2011-01045 assigned reviews of RIS 2011-005, in the Entergy OE process, to fleet license renewal personnel. At the time of this inspection, the evaluation of RIS 2011-05 had not been completed. The licensee initiated CR-HQN-2012-00333 to document the delay in the OE evaluation of RIS 2011-005. Findings No findings of significance were identified. (6) Integration of Aging Management Program Commitments into Routine Processes Due to concerns developed during the inspection (Item (4) above), the inspectors reviewed how the licensee incorporated the aging management commitments into the everyday activities; particularly as to how the review for aging concerns would become a standard review question and assimilated into the licensee's review process.
Observations The inspectors reviewed the AMP commitments and the procedures governing how aging management issues were controlled to ensure no items could be delayed, cancelled, or deferred without the program owner's, supervisor's, or manager's knowledge and concurrence. The inspectors also interviewed the AMP single point of contact and several program owners. The inspectors did not observe a clear, readily discernible tie between the implementing work items and aging management commitments. However, carefully reviewing all of the governing procedures and documents revealed that the tie to aging management was established and that AMP commitments had to be reviewed before any of the items could be revised or discarded.
During the review, the inspectors noted that a code had been established in the CAP to note aging issues on any CR reviewed by the condition review group(CRG); however, no specific item in the review process had been established to examine every CR for any possible lessons learned or impact on aging management. In response to this question, the licensee added a specific item to the CRG package checklist to ensure that CRs involving aging management are trended correctly.
Findings No findings of significance were identified. (7) Fatigue Monitoring Program The Fatigue Monitoring Program (FMP) ensures that limits on the fatigue usage are not exceeded by monitoring and tracking selected cyclic transients. The program provides cycle counting activities for confirming analytically derived cumulative usage values.
As documented in the Palisades Nuclear Plant - Problem Identification and Resolution Inspection Report 05000255/2012007, the inspectors were concerned with the timeliness of actions associated with approving the use of a software program in the Fatigue Monitoring program. The inspectors also questioned the adequacy of the program for ensuring thermal cycles tracking. Inspection of these items continued during this current inspection.
6 Enclosure Observations The inspectors consulted with the NRR staff to determine the specific commitments for the Palisades FMP. Subsequently, the inspectors interviewed personnel, reviewed the pressurizer design specification, reviewed procedures, and reviewed PLP-RPT-12-00023, "Fatigue Monitoring Program Summary Report," Revision 0, and determined that the licensee was meeting the AMP commitment for the fatigue monitoring program.
Findings No findings of significance were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary On March 16, 2012, the inspectors presented the inspection results to Mr. B. Davis and other members of the licensee staff.
The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- W. Archibald, Chemistry
- B. Davis, Engineering Director
- M. Cimock, Sr. Programs Engineer
- T. Davis, Licensing
- J. Erickson, Licensing
- J. Kuemin, Licensing
- N. Lane, Projects Manager
- J. Miksa, Programs Engineering Manager
- C. Plachta, Quality Assurance Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Discussed
- 05000255/2011008-01 NCV Failure to Assure Adequate Resolution for Remote Visual Examinations (Section 4OA5.1 b.(1)(a))
- 05000255/2011008-02 NCV Test Results for Diesel Fuel Oil Tanks Not Evaluated. (Section 4OA5.1 b.(1)(b))
- 05000255/2011008-03 NCV Tank T-10A Not Age Managed for Effect of Identified Water. (Section 4OA5.1 b.(1)(c))
- 05000255/2011008-04 FIN Flow Accelerated Corrosion Program Acceptance Limits Not in Accordance with Design Standard (Section 4OA5.1 b.(1)(d))
- 05000255/2011008-05 FIN Failure to Implement Adequate Oil Sampling and Analysis Aging Management Program. (Section 4OA5.1 b.(1)(e)) Open and Closed None
2
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of 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. CALCULATIONS AND EVALUATIONS Number Description or Title Revision
- EA-EC24931-04 Engineering Analysis of Component
- KBF-901-E350 1
- PLP-RPT-11-00013 Establishment of Alert and Action Level Thicknesses for the Aging Management of the Inner Shell of Diesel Oil Storage Tank, T-10A 1
- PLP-RPT-2010-00014 Review of Fire Protection AMP for License Renewal Implementation 0
- PLP-RPT-2011-00006 Miscellaneous Tank Minimum Wall Thickness Evaluation 0
- PLP-RPT-2011-00008 Perform an Evaluation of Inspection Opportunities Prior to License Renewal per Commitment
- LO-LAR-2009-244-38 0
- PLP-RPT-2012-00021 Fatigue Monitoring Program Cycle 21 Report 0
- PLP-RPT-2012-00023 Fatigue Monitoring Program Summary Report 0 CORRECTIVE ACTION DOCUMENTS GENERATED DUE TO THE INSPECTION Number Description or Title Date
- CR-HQN-2012-00333 Failure to Evaluate
- RIS 2011-05 03/14/12
- CR-PLP-2012-01734 NRC Identified Erroneous Assumption in Calculation
- PLP-RPT-11-00013, Revision 1 03/15/12
- CR-PLP-2012-01738 Error Discovered in
- PLP-RPT-12-00023, Fatigue Monitoring Program Summary Report, Revision 0 03/15/12 CORRECTIVE ACTION DOCUMENTS REVIEWED Number Description or Title Date
- CR-PLP-2010-04836 Documentation of NDE Reports 10/11/10
- CR-PLP-2010-05283 Inadequate Procedure Adherence Using Borescope for
- VT-1 10/19/10
- CR-PLP-2010-05624 Calibration Standard Used for Boroscopic Inspections Performed for the One Time Inspection Program is Not Appropriate for the Surface Being Inspected. 10/25/10
- CR-PLP-2011-00402 Oil Analysis Frequency Does not Match PMID
- 50083897 Frequency Requirements 01/26/11
- CR-PLP-2011-00428 Diesel Generator Fuel Oil Day Tanks T*25A and T*25B are not Sampled Quarterly for Particulate. 01/27/11
- CR-PLP-2011-Design Calculation EA*EC24931 04 Uses an Improper Design 01/28/11
- 300433 Input to Determine the Remaining Service Life of Piping Component KBF*901*E350 (Elbow). CR-PLP-2011-
- 00464 Auxiliary Feedwater Pump/Turbine Oil Sample Points are Not Specifically Identified 01/31/11
- CR-PLP-2011-00480 PM Activities for the Bottom Thickness Measurements of the Diesel Fuel Oil Tanks do not Include Limits for the UT
- Evaluation
- 01/31/11 CR*PLP-2011-00602 Determine Applicability of 10
- CFR 54.37(a) Record Keeping Requirements to Palisades and Entergy Fleet.
- 02/07/11
- CR-PLP-2011-00676 Effectiveness of Operating Experience Use by Aging Management Program Owners 02/11/11
- CR-PLP-2011-00676 NRC Questioned How Effectively Operating Experience Is Being Assimilated by Aging Management Program Owners 02/11/11
- CR-PLP-2011-00680 Failure to Evaluate the Results of NDE Inspections of the Fuel Oil Storage Tanks 02/11/11
- CR-PLP-2011-00684 Failure to Take Adequate Corrective Actions to Removal of Water From
- 02/11/11
- CR-PLP-2011-00745 Buried Piping Opportunistic Inspections, Report to Address the Last 10 years' Worth of Inspections was not Comprehensive and does not Meet the Documentation Requirements of 10
- CFR 54.37(a). 02/15/11
- CR-PLP-2011-00887 Palisades Oil Sampling and Analysis not in Accordance with FSAR Section 1.9.1.24 02/23/11
- CR-PLP-2011-00916 Documentation of Main Feedwater Pump Oil Analysis for Elevated Particle Count Could not be Provided to the
- NRC 02/24/11
- CR-PLP-2011-00983 Incorporate T-926 into the Buried Services Corrosion Monitoring Aging Management Program as a Tank that Could be Exposed to Soil/Sand on its Exterior 02/28/11
- CR-PLP-2011-01109 During Eddy Current Testing of E-31B, DG 1-2 Lube Oil Cooler, Two Tubes Were Identified as Having Dents 03/07/11
- CR-PLP-2011-01110 During Eddy Current Testing of E-22B, Five Tubes did not Meet Acceptance Criteria 03/07/11
- CR-PLP-2011-00676, CA 7 Issue a Training Evaluation for Aging Management, Aging Lessons Learned, and Evolving Aging Program Requirements
- 03/09/11
- CR-PLP-2011-01270 Revise
- EM-27 to List Internal Oil Coolers as Separate Components for the Purpose of Aging Management
- 03/15/11
- CR-PLP-2011-01331 Administrative CR to Document that Certain Valid Information Submitted in 2005 Could Now be Viewed as Inaccurate 03/18/11 MISCELLANEOUS Number Description or Title Date
- 12-PAL-0002 Evaluation/Screening of Boric Acid Leakage for
- CR-PLP-2012-00094/CR-PLP-2012-00114 02/09/12 12-PAL-0020 Evaluation/Screening of Boric Acid Leakage for
- CR-PLP-2012-00122 02/08/12 12-PAL-0025 Evaluation/Screening of Boric Acid Leakage for
- CR-PLP-2012-00256 02/09/12 12-PAL-0027 Evaluation/Screening of Boric Acid Leakage for
- CR-PLP-2012-00729 03/12/12 12-PAL-0032 Evaluation/Screening of Boric Acid Leakage for
- CR-PLP-2012-00736 03/12/12
- 4Number Description or Title Date or Revision
- CR-PLP-2011-05603 Maintenance Rule (a)(1) Action Plan for Roof Structures 0
- CA 46 Ensure a Snapshot Assessment for the Renewed License Program in the 2014 CA&A Assessment Calendar 03/16/12
- LR-AMPBD-19-OCCW Open Cycle Cooling Water Program 2 PROCEDURES Number Description or Title Revision M 1-L-A Engineering Specification For A Pressurizer Assembly 3
- EN-DC-324 Preventive Maintenance Program 7
- EN-FAP-OU-104 Refueling Outage Scope Identification and Control 0
- EN-WM-101 On-Line Work Management Process 7
- EN-OE-100 Operating Experience Program 14
- EM-32-02 Fatigue Monitoring Program 1
- EM-09-24 Service Water and Fire Protection Inspection Program 3
- EM-27 Lubrication Analysis and Monitoring 12
- EM-09-16 Heat Exchanger Condition Assessment Program 9
- EM-09-15 Raw Water Corrosion Program 7
- COP-22A Diesel Fuel Oil Testing Program 16
- SEP-AMP-PLP-002 Aging Management Assessment for Failed or Degraded Equipment 0
- SEP-LUB-PLP-001 Lubrication Analysis and Monitoring 0
- SEP-RLP-PLP-001 Palisades Renewed License Program Section
- 0
- SOP-1B Primary Coolant System - Cooldown 11 3.26 Implementation of Palisades Renewed License Requirements 3 10.41 Site Procedure and Policy Processes 46 WORK DOCUMENTS Number Description or Title Date or Revision
- 51630153-01 Model
- WO-OPS D/G DY
- TKS 03/10/08
- 52038838 01 T-926, FWP Fuel Oil Tank, Clean, Inspect, and Perform
- NDE 05/12/11
- 52276276 01 T-40, Diesel Fire Pump P-41 Day Tank
- PM 03/09/12
- 52337039 08 T-91, Utility Water Storage Tank Internal Inspection 02/16/12 PMID 26363 SYENG084 000 AUDITS, ASSESSMENTS AND
- SELF-ASSESSMENTS Number Description or Title Revision
- LO-PLPLO-2010-00132 Palisades NRC IP71003 Phase III Inspection Readiness 09/15/2011
- 5
LIST OF ACRONYMS
- USED [[]]
- NRC [[]]
URI Unresolved Item
- CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the
- PARS ) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the
- NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /
RA by S. Sheldon for/
Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-255;72-007 License No.