IR 05000255/2016008

NRC Temporary Instruction 2515/191, Mitigation Strategies, Spent Fuel Pool Instrumentation and Emergency Preparedness Inspection Report 05000255/2016008

ML16337A098
Person / Time
Site:	Palisades
Issue date:	12/02/2016
From:	Ann Marie Stone NRC/RGN-III/DRS/SS
To:	Arnone C Entergy Nuclear Operations
References
IR 2016008
Download: ML16337A098 (16)

Text

ber 2, 2016

SUBJECT:

PALISADES NUCLEAR PLANT-NRC TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES, SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS INSPECTION REPORT 05000255/2016008

Dear Mr. Arnone:

On November 16, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed Temporary Instruction (TI) 2515/191, "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans" inspection at your Palisades Nuclear Plant. The NRC inspection team discussed the results of this inspection with Mr. M. Lee and other members of your staff. The enclosed report represents the results of this inspection. The inspection examined activities conducted un der your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commission's rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel. The NRC inspectors did not identify any findings or violations of more than minor significance. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding,"

of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Team Leader Technical Support Staff

Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 05000255/2016008

REGION III Docket No: 50-255 License No: DPR-20 Report No: 05000255/2016008 Licensee: Entergy Nuclear Operations, Inc. Facility: Palisades Nuclear Plant Location: Covert, MI Dates: September 26 through November 16, 2016

Inspectors: J. Boettcher, Resident Inspector (Team Lead) B. Bartlett, Project Engineer J. Benjamin, Senior Reactor Inspector S. Sheldon, Project Engineer

Approved by: A. Stone, Team Leader Technical Support Staff Division of Reactor Projects 2

SUMMARY

Inspection Report 05000255/2016008, 09/26/2016 - 09/30/2016, Palisades Nuclear Plant; Temporary Instruction 2515/191 Implementation of Mitigation Strategies and Spent Fuel Pool

Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans. This inspection was performed by a resident inspector and three U.S. Nuclear Regulatory Commission (NRC) regional inspectors. No findings of significance or violations of NRC requirements were identified during this inspection. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter (IMC) 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated July 2016.

NRC-Identified and Self-Revealing Findings

None 3

REPORT DETAILS

4OA5 Other Activities (Temporary Instruction 2515/191) The objective of Temporary Instruction (TI) 2515/191, "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency

Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans," is to verify the licensee has adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (Agencywide Documents Access Management System (ADAMS) Accession No. ML15351A351), the licensee's supplement to the notification of full compliance (ADAMS Accession No. ML16083A285), and the U.S. Nuclear Regulatory Commission's (NRC's) safety evaluation (ADAMS Accession No. ML16014A318) and to verify the licensee installed reliable water-level measurement instrumentation in their spent fuel pool (SFP). The purpose of this TI was also to verify the licensee had implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure staffing is sufficient and communications can be maintained during such an event. The inspection also verifies plans for complying with NRC Orders EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML12054A736) and EA-12-051, "Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation" (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, "Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned," dated March 27, 2013, (ADAMS Accession No. ML12339A262). The inspectors discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify the strategies could be implemented as stated in the licensee's submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged.

Specific details of the team's inspection activities are described in the following sections.

.1 Mitigation Strategies for Beyond-Design Basis External Events

a. Inspection Scope

The inspectors examined the licensee's established guidelines and implementing procedures for the beyond-design basis mitigation strategies. The inspectors assessed how the licensee coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The inspectors selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios. The inspectors verified a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and periodic equipment inventories were in place and being conducted. Additionally, the inspectors examined the introductory and planned periodic/refresher training provided to the Operations staff most likely to be tasked with implementation of the FLEX mitigation strategies. The inspectors also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel. Documents reviewed are listed in the attachment. b. Assessment Based on samples selected for review, the inspectors verified the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-049. The inspectors verified the licensee satisfactorily:

• developed and issued FLEX Support Guidelines (FSG) to implement the FLEX strategies for postulated external events;

• integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;

• protected FLEX equipment from site-specific hazards;

• developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;

• trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and

• developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations. The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program as appropriate.

c. Findings

No findings were identified.

.2 Spent Fuel Pool Instrumentation

a. Inspection Scope

The inspectors examined the licensee's newly installed SFP instrumentation. Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel were physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.

b. Assessment Based on samples selected for review, the inspectors determined the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittal(s) and the associated safety evaluation and determined the licensee is generally in compliance with NRC Order EA-12-051. The inspectors verified the licensee satisfactorily:

• installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal(s)and safety evaluation;

• installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittal(s); and

• trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation. The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings were identified.

.3 Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walk downs, the inspectors verified the licensee has implemented required changes to staffing, communications equipment and facilities to support a multi-unit extended loss of alternating current power (ELAP) scenario as described in the licensee's staffing

assessment and the NRC safety assessment. The inspectors also verified the licensee has implemented multi-unit dose assessment (including releases from SFPs) capability using the licensee's site-specific dose assessment software and approach as described in the licensee's multi-unit dose assessment submittal. Documents reviewed are listed in the attachment. b. Assessment The inspectors reviewed information provided in the licensee's multi-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all alternating current power to all site units and impedes access to the site. The inspectors verified the following:

• the licensee satisfactorily implemented required staffing change(s) to support a multi-unit ELAP scenario;

• EP communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and

• the licensee implemented multi-unit dose assessment capabilities (including releases from SFPs) using the licensee's site-specific dose assessment software and approach. The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings were identified.

4OA6 Management Meeting Exit Meeting Summary On November 16, 2016, the inspectors presented the inspection results to Mr. M. Lee and other members of the licensee's staff.

The licensee acknowledged the issues presented. The inspectors confirmed none of the potential report input discussed was considered proprietary. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

C. Arnone, Site Vice President

A. Williams, General Manager Plant Operations

T. Mulford, Operations Manager

B. Baker, Operations Manager - Shift

J. Borah, Engineering Manager, Systems and Components

T. Davis, Regulatory Assurance

B. Dotson, Regulatory Assurance

J. Erickson, Regulatory Assurance

O. Gustafson, Director of Regulatory and Performance Improvement

J. Hardy, Regulatory Assurance Manager

J. Haumersen, Site Projects and Maintenance Services Manager

G. Heisterman, Maintenance Manager

M. Lee, Operations Manager - Support

D. Lucy, Outage Manager

D. Malone, Emergency Planning Manager

W. Nelson, Training Manager

D. Nestle, Radiation Protection Manager

K. O'Connor, Engineering Manager, Design and Programs

C. Plachta, Nuclear Independent Oversight Manager

P. Russell, Site Engineering Director

M. Schultheis, Performance Improvement Manager

M. Soja, Chemistry Manager

J. Tharp, Security Manager

U.S. Nuclear Regulatory Commission A. Stone, Team Leader, Technical Support Staff

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection.

Inclusion on this list does not imply the NRC inspector reviewed the documents in their entirety, but rather that