ML14171A394

Ir 05000255-14-007; 05/05/2014-06/11/2014; Palisades Nuclear Plant; Problem Identification and Resolution

ML14171A394
Person / Time
Site:	Palisades
Issue date:	06/20/2014
From:	Duncan E R Region 3 Branch 3
To:	Vitale A Entergy Nuclear Operations
References
IR-14-007
Download: ML14171A394 (37)

See also: IR 05000255/2014007

Text

June 20, 2014

Mr. Anthony Vitale Vice President, Operations Entergy Nuclear Operations, Inc. Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000255/2014007

Dear Mr. Vitale:

On June 11, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution Inspection at your Palisades Nuclear Plant. The enclosed inspection report documents the inspection results, which were discussed at an interim exit meeting on May 23, 2014, and a final exit meeting on June 11, 2014, with you and other members of your staff. The inspection examined activities conducted under your license as they related to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

On the basis of the samples selected for review, the inspectors concluded that the Corrective Action Program at Palisades Nuclear Plant was adequate in the areas of identifying, evaluating and correcting issues with some identified opportunities for improvement. There was a low threshold for identifying issues and entering them into the Corrective Action Program. The significance of the issues was screened using risk insights and the significance drove the prioritization of issue evaluation and resolution. Evaluations were adequate, overall, in determining the underlying cause of the issues and corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was evaluated and entered into the Corrective Action Program, if applicable. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments, audits, and effectiveness reviews were found to be conducted at a sufficient depth for all departments. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. Based on the results of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment (SCWE) at Palisades Nuclear Plant with the exception of the Security Department. Licensee staff was aware of and generally familiar with the Corrective Action Program and other station processes, including the Employee Concerns Program, through which concerns could be raised. The staff was also comfortable raising concerns without fear of retaliation. As discussed in NRC Inspection Report 05000255/2014009, dated March 6, 2014, the NRC performed a limited scope Problem Identification and Resolution inspection that identified a chilled work environment within the Security Department. In particular, the NRC concluded that staff within the Security Department perceived that: (1) recent actions to terminate the employment of two supervisors was in retaliation for their raised concerns; (2) the Corrective Action Program was ineffective at addressing equipment and other concerns raised by the Security staff; (3) Security management was unresponsive to employees' concerns; and (4) the Employee Concerns Program could not be relied upon to maintain employee confidentiality.

In response to our identification of a chilled work environment within the Security Department, you developed the Palisades Security SCWE Action Plan and the NRC planned to review the effectiveness of actions taken to implement the Action Plan. During this inspection, we reviewed your implementation of the Palisades Security SCWE Action Plan and verified that, to date, you have completed all of the actions as committed to in the Action Plan. However, we concluded that the quality of the actions implemented have been insufficient to assess and understand the cause of the chilled work environment within the Security Department and did not demonstrate a strong commitment to effectively improve the safety conscious work environment in the Security Department. Specifically, significant gaps were found to exist in the security officers' knowledge of the actions being taken to address the chilled safety conscious work environment and management's commitment to improving the overall safety conscious work environment.

For example, security officers had a limited recollection of any discussion of the results of the NRC's limited scope Problem Identification and Resolution inspection, and security officers stated that they were not informed of the site's development and implementation of a Security SCWE Action Plan or the specific actions required by the Action Plan. Also, the security officers were unaware of the establishment of the site's Security Ombudsman Program as directed in the Action Plan; the intent of the program; or their shift representatives for the Program, despite the selection and assignment of personnel to these positions at the end of March 2014. Lastly, the security officers were unaware of a significant organizational change that added the Regulatory and Performance Improvement Director to the Security Department chain of command.

Therefore, we are requesting that you provide a response to us, within 30 days of your receipt of this letter, that outlines actions that you have taken or plan to take to further enhance your Palisades Security SCWE Action Plan to improve the safety conscious work environment in the Security Department at Palisades. The NRC will continue to closely monitor Security Department safety conscious work environment and any supplemental actions that you may choose to take with a follow-up inspection.

We plan to discuss with you the results of our safety conscious work environment inspections during the upcoming End-of-Cycle assessment public meeting. The NRC requests that you be prepared to discuss: (1) the root cause of the chilled work environment within the Security Department; (2) your progress in addressing the safety conscious work environment concerns within the Security Department; and (3) any additional actions planned and/or implemented to address the safety conscious work environment at Palisades, including actions as a result of our observations during this Problem Identification and Resolution inspection. In accordance with 10 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 NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Eric Duncan, Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report No. 05000255/2014007

w/Attachment:

Supplemental Information cc w/encl: Distribution via LISTSERV Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-255 License No: DPR-20 Report No: 05000255/2014007 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Dates: May 5, 2014, through June 11, 2014 Team Leader: R. Ng, Project Engineer Inspectors: A. Scarbeary, Resident Inspector C. Zoia, License Examiner E. Sanchez-Santiago, Reactor Inspector G. Hansen, Physical Security Inspector Approved by: E. Duncan, Chief Branch 3 Division of Reactor Projects

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SUMMARY OF FINDINGS

Inspection Report 05000255/2014007; 05/05/2014 - 06/11/2014; Palisades Nuclear Plant; Problem Identification and Resolution. This inspection was performed by four region-based inspectors and the Palisades Resident

Inspector. 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. Problem Identification and Resolution On the basis of the samples selected for review, the inspectors concluded that the Corrective Action Program at Palisades Nuclear Plant was adequate in the areas of identifying, evaluating and correcting issues with some identified opportunities for improvement. The licensee had a low threshold for identifying issues and entering them into the Corrective Action Program. The significance of the issues was screened using risk insights and the significance drove the prioritization of issue evaluation and resolution. Evaluations were adequate, overall, in determining the underlying cause of the issues and corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was evaluated and entered into the Corrective Action Program, if applicable. The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments, audits, and effectiveness reviews were found to be conducted at a sufficient depth for all departments. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. Based on the results of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment (SCWE) at Palisades Nuclear Plant with the exception of the Security Department. Licensee staff was aware of and generally familiar with the Corrective Action Program and other station processes, including the Employee Concerns Program, through which concerns could be raised. The staff was also comfortable raising concerns without fear of retaliation.

Although implementation of the Corrective Action Program was determined to be adequate, the inspectors identified several issues that were either minor in nature and/or represented a potential weakness in the program.

The inspectors concluded that, to date, the site had completed all the actions as committed to in the Security SCWE Action Plan. However, the inspectors concluded that the quality of the actions implemented have been insufficient to assess and understand the cause of the chilled work environment within the Security Department and did not demonstrate a strong commitment to effectively improve the safety conscious work environment in the Security Department. Specifically, significant gaps were found to exist in the security officers' knowledge of the actions being taken to address the chilled safety conscious work environment and management's commitment to improving the overall safety conscious work environment. Based on the information reviewed during this inspection, the inspectors concluded that the control room structure continues to perform its intended safety function, and the installed modifications, if maintained, are adequate to prevent water intrusion into the control room.

Therefore, the inspectors determined that the licensee had fulfilled the Confirmatory Action Letter commitments to address the Safety Injection Refueling Water Tank (SIRWT) and Control Room concrete support structure leakage.

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A. NRC-Identified

and Self-Revealed Findings None.

B. Licensee-Identified Violations

None.

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REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of Problem Identification and Resolution as defined by Inspection Procedure 71152, "Problem Identification and Resolution."

Documents reviewed are listed in the Attachment to this report.

.1 Assessment of the Corrective Action Program Effectiveness

Inspection Scope The inspectors reviewed the procedures and processes that described the Corrective Action Program at Palisades Nuclear Plant to ensure, in part, that the requirements of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," were met. The inspectors observed and evaluated the effectiveness of meetings related to the Corrective Action Program, such as the Condition Report Prescreening meeting, the Condition Review Group meeting, and the Corrective Action Review Board meeting. Selected licensee personnel were interviewed to assess their understanding of and their involvement in the Corrective Action Program. The inspectors reviewed selected condition reports across all seven Reactor Oversight Process cornerstones to determine if problems were being properly identified and entered into the licensee's Corrective Action Program. The majority of the risk-informed samples of condition reports reviewed were issued since the last NRC biennial Problem Identification and Resolution inspection completed in February 2012. The inspectors also reviewed selected issues that were more than 5 years old. The inspectors assessed the licensee's characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significance and evaluation classes, including root cause evaluations, apparent cause evaluations, common cause evaluations, condition report responses, and human performance error reviews. The inspectors assessed the scope and depth of the licensee's evaluations. For significant conditions adverse to quality, the inspectors evaluated the licensee's corrective actions to prevent recurrence and for less significant issues, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significance. The inspectors selected the Auxiliary Feedwater Actuation System and Reactor Protection System power supply components to review in detail over a 5 year period. Both systems were safety-related and risk-significant Maintenance Rule (a)(1) systems with previously identified power supply component problems. At the time of the inspection, the Reactor Protection System was in a Maintenance Rule (a)(1) status, and the Auxiliary Feedwater Actuation System had recently returned from a Maintenance Rule (a)(1) status to a Maintenance Rule (a)(2) status. The primary purpose of this review was to determine whether the licensee was properly monitoring and evaluating the performance of risk-significant systems. The inspectors also assessed the licensee's implementation of various system monitoring programs and performed walkdowns, as needed, to verify the resolution of issues. As part of this review, the inspectors interviewed the current and previous system engineers, reviewed a sample of system health reports, condition reports, operating experience, apparent cause evaluations, and root cause evaluations. The inspectors also attended the Plant Health Committee Meeting to observe the process the licensee used for identifying, prioritizing, and resolving issues that challenged unit reliability. The inspectors reviewed Corrective Action Program and work management system procedures that provided guidance for trending. In addition, the inspectors walked down the Auxiliary Feedwater Actuation System panel area to visually inspect recent power supply-related maintenance and to verify that identified concerns were entered into the Corrective Action Program.

The inspectors examined the results of self-assessments of the Corrective Action Program completed during the review period. The results of the self-assessments were compared to self-revealed and NRC-identified findings. The inspectors also reviewed the corrective actions associated with previously identified non-cited violations and findings to determine whether the station properly evaluated and resolved those issues. The inspectors performed walkdowns, as necessary, to verify the resolution of the issues. Assessment (1) Identification of Issues Based on the results of the inspection, the inspectors concluded that, overall, the station was effective in identifying issues at a low threshold and properly entering them into the Corrective Action Program. The inspectors determined that problems were usually identified and captured in a complete and accurate manner in the Corrective Action Program. The station was appropriately screening issues from both NRC and industry operating experience at an appropriate level and entering them into the Corrective Action Program when the issues were applicable to the station. The inspectors also noted that deficiencies were identified by external organizations, including the NRC, that had not been previously identified by licensee personnel. These deficiencies were subsequently entered into the Corrective Action Program for resolution. The inspectors determined that the station was generally effective at trending low level issues to prevent more significant issues from developing. The licensee also used the Corrective Action Program to document instances where previous corrective actions were ineffective or were inappropriately closed.

The inspectors concluded that power supply-related concerns were identified and entered into the Corrective Action Program at a low threshold, and concerns were resolved in a timely manner commensurate with their safety significance.

(2) Prioritization and Evaluation of Issues Based on the results of the inspection, the inspectors concluded that the station was adequately prioritizing and evaluating issues commensurate with the safety significance of the identified issue, which included a consideration of risk.

The inspectors determined that the Condition Report Prescreening meeting, the Condition Review Group meeting, and the Corrective Action Review Board meeting were all generally thorough and maintained a high standard for evaluation quality. Members of the Condition Review Group discussed selected issues in sufficient detail and challenged the responsible department representatives regarding their conclusions and recommendations.

The inspectors performed a detailed review of issues related to the Reactor Protection System and Auxiliary Feedwater Actuation System power supplies over roughly the past 5 years. The inspectors concluded that the evaluation of design issues, along with failure analyses, provided for a thorough review of potential causes of issues. The corrective actions already implemented to evaluate the extent of condition of an issue and those being completed to revise the design of the power supplies were being implemented in a timely manner commensurate with the safety significance of the issues. The inspectors noted that the licensee generally exhibited no reluctance in placing structures, systems, and components into a Maintenance Rule (a)(1) status. Appropriate corrective actions to address identified maintenance deficiencies were prescribed and completed. A detailed review of the structures, systems, and components performance generally occurred before returning such structures, systems, and components to a Maintenance Rule (a)(2) status.

The inspectors determined that the licensee typically evaluated equipment functionality requirements adequately after a degraded or non-conforming condition was identified.

Overall, appropriate actions were assigned to correct the degraded or non-conforming condition.

Vulnerabilities in Condition Evaluations The inspectors identified several instances in which the licensee's evaluation lacked sufficient quality to address the condition such that a technically competent reviewer could understand how the corrective actions would correct the identified condition. This lack of quality could potentially impact the licensee's ability to identify adequate corrective actions. The inspectors identified the following condition reports as examples where the licensee's evaluation lacked sufficient quality:

• Foreign Material Intrusion Effectiveness Review Condition Report CR-PLP-2012-05054, "Root Cause Evaluation Report for Foreign Material Intrusion P-74, SIRWT Recirculation Pump," evaluated a foreign material intrusion event in July 2012 that affected the Safety Injection Refueling Water Tank recirculation pump. The effectiveness reviews performed by the licensee did not establish the proper threshold to identify issues at a level that could be addressed prior to the issue becoming a more significant concern. In the root cause evaluation report, the licensee documented that the foreign material intrusion event was caused by a failure to follow the foreign material excursion procedure. However, the failure threshold for the effectiveness review performed was a failure to follow procedures that resulted in foreign material intrusion. During the effectiveness review, the licensee identified failures to follow the foreign material excursion procedure. However, the licensee concluded in the effectiveness review that the corrective actions were effective because no foreign material intrusion event actually occurred.

The inspectors reasoned that the absence of a foreign material intrusion given a failure to follow the foreign material excursion procedure may have been fortuitous, rather than deliberate. Subsequently, an actual foreign material intrusion event occurred, which further demonstrated that the corrective actions might not have been effective. Specifically, when installing an inflatable bladder inside the Service Water system, on two occasions these bladders were inadvertently entrained into the return header of the Service Water system by the relative vacuum created by the system flow. It was determined that this was a result of the failure to establish adequate controls as required by the foreign material excursion procedure. This issue was documented as a non-cited violation in NRC Inspection Report 05000255/2014002.

• Vital Area Doors Alarm Evaluation While reviewing the common cause analysis for Condition Report CR-PLP-2013-4391, "Trend in Vital Area Doors Found Unsecured," the inspectors identified issues with the thoroughness of the initial evaluation for the identified trend and the methodology used for the effectiveness review of the corrective actions implemented. The common cause analysis reviewed 40 instances of unsecured vital area doors that occurred between January and October 2013. The analysis identified the departments that were responsible for the doors being found unsecured and the month the issue occurred. The evaluation identified a lack of use of appropriate human performance tools associated with verifying that security doors were properly latched and closed after use. The corrective actions resulting from this trend analysis were to reinforce with site personnel and supplemental employees the proper human performance tools to use when traversing through security doors and actions to take if a door did not properly close. This common cause analysis did not evaluate potential mechanical issues with the doors that would not allow them to close properly.

The effectiveness review for this trend reviewed 20 instances of unsecured vital area doors that occurred between January 15 and March 16, 2014. This review compared the number of times the door was used to how many times the door was found unsecured. The effectiveness review determined that a low percentage of errors occurred during this timeframe, and therefore the issue was resolved with no additional actions needed. This was a different methodology with a different acceptance standard than the initial common cause analysis used since in the identification of security door violations originally identified, the number of violations was focused on, and in the follow-up review, the failure rate was focused on. These observations were discussed with the licensee. Subsequent to the effectiveness review, the licensee identified an adverse trend station-wide for the number of security door violations that occurred and planned to re-evaluate both the human performance and the mechanical door operation components of this issue and initiate follow-on corrective actions to address them. The inspectors concluded that a lack of quality in some evaluations existed and that this was similar to what was documented in the previous biennial Problem Identification and Resolution inspection.

During this inspection, although the inspectors did not identify any findings related to the lack of quality in evaluations, a minor violation related to a Part 21 evaluation is documented in Section 4OA2.2.b of this report. Therefore, based on the samples reviewed during this inspection, the quality of evaluations, overall, appeared to be improving.

(3) Effectiveness of Corrective Actions Based on the results of the inspection, the inspectors concluded that the licensee was generally effective in addressing identified issues and that the assigned corrective actions were generally appropriate. The licensee implemented corrective actions in a timely manner, commensurate with their safety significance, including an appropriate consideration of risk. Problems identified using root or apparent cause methodologies were resolved in accordance with the Corrective Action Program procedural and regulatory requirements. Corrective actions designed to prevent recurrence were generally comprehensive, thorough, and timely. The inspectors sampled corrective action assignments for selected NRC documented violations and determined that actions assigned were generally effective and timely.

For example, the licensee received a non-cited violation in 2002 for the failure to operate the primary coolant pumps in accordance with their design operating criteria. The inspectors verified that the licensee's evaluations for the issue were comprehensive and the corrective actions completed and planned were appropriate and timely, commensurate with their safety significance.

The licensee's pre-inspection review identified several instances where corrective actions were closed inappropriately and that additional actions were needed to complete the closeout of the corrective actions. The inspectors determined these discrepancies were minor compliance issues with the licensee's Corrective Action Program procedures and the licensee had taken appropriate actions to address these issues.

The inspectors also identified that there were approximately 260 open corrective action items at the time of the inspection. However, only 20 of these open corrective action items were more than 2 years old. The inspectors reviewed a sample of these corrective action items and verified that the sampled condition reports were evaluated and actions assigned appropriately. The inspectors determined that most of the remaining actions were related to a fire protection license amendment request, which was in the NRC review process. Other corrective actions were related to minor non-conformances or enhancements with low safety significance. For those corrective actions that were safety significant, the inspectors verified that the due dates were reasonable and the licensee had appropriate compensatory actions in place.

Through interviews with the licensee staff and a review of the trend of the total outstanding corrective actions over the last 5 years, the inspectors determined that the licensee had been reducing the corrective action backlog.

c. Findings

No findings were identified.

.2 Implementation of Corrective Actions Generated Following NRC Inspection Procedure

(IP) 95002 Supplemental Inspection

a. Inspection Scope

The inspectors reviewed the IP 95002 supplemental inspection action items that were implemented since the completion of an IP 95002 supplemental inspection on November 9, 2012. This supplemental inspection was related to a Yellow finding documented in NRC Inspection Report 05000255/2011019 and 0500025/2011020.

The Yellow finding was associated with the loss of the Left train of direct current (DC)power due to the failure to ensure that the work instructions on a safety-related 125-Volt DC distribution panel were adequate for the scheduled work. The results of this supplemental inspection were documented in NRC Inspection Report 05000255/2012011. b. Assessment The inspectors reviewed Condition Report CR-PLP-2011-04822, which was the overarching condition report for the issue that resulted in the Yellow finding, and found that the associated corrective actions had been planned and implemented. There were various tasks associated with this condition report that were completed subsequent to the supplemental inspection. These actions included development and implementation of training to address the deficiencies identified as part of the root cause analysis, as well as actions to review the root cause report and completed corrective actions to ensure any additional issues and/or concerns identified had already been addressed and did not invalidate the actions taken. The inspectors reviewed the completed corrective actions and found them to be adequate.

c. Findings

No findings were identified.

.3 Implementation of Corrective Actions Generated Following NRC IP 95001 Supplemental Inspection

a. Inspection Scope

The inspectors reviewed the corrective actions that were implemented and the effectiveness reviews of those corrective actions that had been conducted since the completion of an IP 95001 supplemental inspection on June 29, 2012. This supplemental inspection was related to a White finding associated with the Turbine-Driven Auxiliary Feedwater pump that was documented in NRC Inspection Report 05000255/2011013 and 05000255/2011017. The results of this supplemental inspection were documented in NRC Inspection Report 05000255/2012010. b. Assessment The inspectors reviewed Condition Report CR-PLP-2011-5723 and the associated root cause evaluation report, "Auxiliary Feedwater Pump P-8B Overspeed Trip Actuation," and found that all of the associated corrective actions had been implemented. Two effectiveness reviews had also been completed to evaluate the adequacy of the corrective actions implemented. The first effectiveness review conducted in April 2012 examined the revisions to the maintenance procedure for the Auxiliary Feedwater Pump, and identified some enhancements to be included in the procedure based on information in the root cause evaluation. The inspectors reviewed the most current revision of this maintenance procedure and found that all of those enhancements had been included in the document. The second effectiveness review examined maintenance records, condition reports generated, and operations' logs to determine if any unexpected Limiting Condition for Operation entries were made, or Limiting Condition for Operation time was extended, due to maintenance issues related to the Turbine-Driven Auxiliary Feedwater Pump. This review was conducted in April 2014 after the most recent refueling outage (refueling outage maintenance caused the issues the led to the White finding initially), and concluded that there were no maintenance-induced problems related to this pump. All corrective actions associated with the aforementioned condition report and root cause evaluation, and all effectiveness reviews had been completed for this White finding. The inspectors reviewed all of this information and determined that the actions implemented were adequate.

c. Findings

No findings were identified.

.4 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensee's implementation of the facility's Operating Experience Program. Specifically, the inspectors reviewed the Operating Experience Program implementing procedures and licensee evaluations of operating experience issues and events. The inspectors also observed meetings and daily activities for the use of operating experience information to determine whether the licensee was effectively integrating operating experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's Operating Experience Program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used operating experience information in the planning and performance of departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of operating experience, were identified and implemented effectively and in a timely manner. In addition, the inspectors interviewed the Operating Experience Program owner to obtain insights on its use. b. Assessment Based on the results of the inspection, the inspectors concluded that, overall, operating experience was effectively utilized at the station. The inspectors observed that representatives from different sites held periodic meetings to discuss recently published operating experience. Issues that were applicable to the Palisades Nuclear Plant were entered into the Corrective Action Program for resolution. Industry operating experience was effectively disseminated across plant departments through daily and pre-job briefings.

Nonetheless, the inspectors noted the following licensee identified minor violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," related to a 10 CFR Part 21 evaluation.

Deficiencies in Part 21 Evaluation On November 8, 2012, Fisher Control International submitted a Part 21 report that described certain butterfly valve parts that did not receive proper commercial grade dedication. These parts were considered essential-to-function and were required for the butterfly valve assembly to perform its safety-related function. Fisher Control International requested the recipients of the Part 21 report to review this information for applicability to their equipment and facilities and take appropriate actions, if required.

The licensee entered this issue in the Corrective Action Program on November 20, 2012.

The licensee contacted Fisher Control International and identified that two installed safety-related Component Cooling Heat Exchanger temperature control valves were affected. The licensee concluded that the valves would perform their design function, but did not clearly document the basis of that conclusion. In addition, Fisher Control International also communicated to the licensee that they had identified and notified the licensee of other components that might not have been commercially dedicated properly due to an ambiguity in the purchase orders. However, the licensee did not research this matter any further. In May 2013 during an audit, Nuclear Oversight identified that the Part 21 evaluation was inadequate to support the conclusion that it was acceptable to use the butterfly valve as-is and did not address all the issues communicated by Fisher Control International.

Subsequently, an operability evaluation was performed, which concluded that all of the equipment impacted remained operable, but were non-conforming.

The inspectors determined that this was a licensee-identified minor violation of 10 CFR 50, Appendix B, Criteria XVI, "Corrective Action." This failure to comply with the Appendix B requirement constituted a minor violation that is not subject to enforcement action in accordance with the NRC's Enforcement Policy. A replacement of the affected equipment was scheduled for the next refueling outage.

c. Findings

No findings were identified.

.5 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected self-assessments, bench markings, "Snap-shot" self-assessments, and Nuclear Oversight audits, as well as the schedule of past and future assessments. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the Corrective Action Program. In addition, the inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

b. Assessment Based on the results of the inspection, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. In many cases, these self-assessments and audits had identified numerous issues that were not previously recognized by the station. These issues were entered into condition reports as required by Corrective Action Program procedures.

c. Findings

No findings were identified.

.6 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors interviewed 19 Palisades Nuclear Plant personnel to determine if there were any indications that licensee personnel were reluctant to raise safety concerns to either their management or the NRC due to fear of retaliation. These individuals represented various departments onsite including Engineering, Maintenance, Operations, Radiation Protection, and Security. The inspectors also assessed the licensee's safety conscious work environment through a review of Employee Concerns Program implementing procedures, discussions with the Employee Concerns Program Manager, and reviews of condition reports. The inspectors reviewed selected Employee Concerns Program activities to identify any emergent issues or potential trends. The licensee's actions to publicize the Corrective Action Program and Employee Concerns Program were also reviewed. The review was performed to ensure there was a free flow of information and to determine if individuals were willing to raise nuclear safety concerns without fear of retaliation.

b. Assessment As discussed in NRC Inspection Report 05000255/2014009, dated March 6, 2014, the NRC performed a limited scope Problem Identification and Resolution inspection that focused on an assessment of the safety conscious work environment in the Chemistry Department, Security Department, and Mechanical Maintenance working group. This inspection was performed as a result of the NRC's receipt of several safety conscious work environment or safety culture-related concerns that prompted questions into the progress made in implementing the licensee's Recovery Plan regarding safety culture deficiencies that, in part, contributed to two Greater-than-Green findings identified in 2011.

The NRC identified a chilled work environment in the Security Department as documented in NRC Inspection Report 05000255/2014009. The licensee implemented a number of corrective actions to address the chilled environment in the Security Department.

During this inspection, the inspectors determined that the safety conscious work environment and overall performance related to identifying, evaluating, and resolving problems was acceptable for the site in general. However, the assessment below was not characteristic of the safety conscious work environment in the Security Department. A detailed review of the licensee's Security SCWE Action Plan is discussed in Section 4OA5.2 of this report.

With the exception of the Security Department, the inspectors did not identify any issues that suggested conditions were not conducive to the establishment and existence of a safety conscious work environment at Palisades Nuclear Plant. Licensee staff was aware of and familiar with the Corrective Action Program and other station processes, including the Employee Concerns Program, through which concerns could be raised.

The inspectors did not review the site Safety Culture and SCWE surveys and assessments during this inspection because these documents were recently reviewed as part of the limited scope Problem Identification and Resolution inspection and the conclusions from that inspection remained valid. The results indicated that there were no impediments to the identification of nuclear safety issues.

The staff also indicated that management had been focused on promoting an environment that encourages raising issues and concerns without fear of retaliation.

The formal policy was communicated at all hands meetings, shift turnover meetings, and through other communication venues, such as newsletters and emails. Department managers and supervisors promoted a safety conscious work environment and reinforced senior management's policy. Individuals were comfortable raising issues and concerns without fear of retaliation.

Overall, they felt that condition reports were given the appropriate priority and actions taken to close condition reports were effective in addressing the identified issues.

c. Findings

No findings were identified.

4OA5 Other Activities

.1 Confirmatory Action Letter (CAL) - Palisades Nuclear Plant Commitments to Address SIRWT and Control Room Concrete Support Structure Leakage As documented in NRC Letter EA-12-155, "Confirmatory Action Letter (CAL) Revision 1 - Palisades Nuclear Plant Commitments to Address Safety Injection Refueling Water

Tank (SIRWT) and Control Room Concrete Support Structure Leakage," (ADAMS ML13177A280) the NRC concluded that the structural integrity of the Safety Injection Refueling Water Tank was sufficient to meet its intended safety function, which addressed three of the five CAL items. The remaining two CAL items associated with the control room support structure were as follows:

1. Entergy Nuclear Operations, Inc., (ENO) will continue inspections of the concrete support structure above the control room, control room hallway, and the concrete support structure ceiling as prescribed in the approved Operations Standing Order. These inspections are to ensure that the temporary modifications installed to prevent impact to safety-related structures, systems and components are performing their intended functions. 2. ENO will correct the adverse condition related to cracking of the concrete support structure around the ceiling of the control room, which could lead to water intrusion, prior to restart from the next refueling outage.

To address these items, the licensee performed a modification in the catacombs area above the control room. This modification included the installation of a waterproof membrane and a design feature to divert water away from the control room, in the event of a leak into the catacombs area. The licensee also performed inspections of the areas where SIRWT leakage could occur, including the catacombs area, until all modification activities were complete.

The inspectors performed a review of the engineering change package that documented the details of the modification and the analyses performed to determine acceptability.

The inspectors ensured that the licensee addressed the capability of this system as well as other impacts that the addition of the waterproof membrane could have on other equipment. The inspectors also performed a walkdown of the areas below the catacombs to ensure a water intrusion scenario would not impact other safety-related equipment. The inspectors reviewed the logs that described the licensee's inspections that were performed to ensure these inspections were adequate to identify any water intrusion and were performed in accordance with the CAL commitment.

Based on the information reviewed during this inspection, the inspectors concluded that the control room structure continues to perform its intended safety function, and the installed modifications, if maintained, are adequate to prevent water intrusion into the control room. Therefore, the inspectors determined that the licensee had fulfilled its commitments to address the Safety Injection Refueling Water Tank and control room concrete support structure leakage.

Separate correspondence will be issued to formally close Confirmatory Action Letter EA-12-155.

.2 Security Safety Conscious Work Environment Action Plan The inspectors performed an independent evaluation of the site's implementation of the Security Safety Conscious Work Environment (SCWE) Action Plan.

The plan was developed by the site and was being implemented in response to the NRC's identification of a chilled work environment within the Security Department during the December 2013 limited scope Problem Identification and Resolution inspection, which was documented in NRC Inspection Report 05000255/2014009 (ADAMS ML14064A569). The inspectors performed an independent review of the licensee's implementation of the Security SCWE Action Plan. The inspection included a review of the licensee's implementation and completion of SCWE Action Plan actions; two focus group meetings with 19 non-supervisory level security officers; and interviews with the Regulatory and Performance Improvement Director, Security Manager, and the Employee Concerns Program Manager.

Specific observations included the following:

• Security officers had a limited recollection of discussing the results of the NRC's limited scope Problem Identification and Resolution inspection that was completed in February 2014. Security officers recalled being told that the NRC stated there "appears to be a potential chilled work environment in Security."

The security officers stated that they believed the site did not feel there was a chilled work environment, but was only taking actions in response to the NRC's conclusions. During an interview with the Security Manager, additional details on the dissemination of the inspection results were obtained. Specifically, security officers were provided the inspection report as an email attachment in advance of the Security Manager meeting with each of the security shifts. At the meetings, hard copies of the report were available for the security officers to reference and retain, as desired. The Security Manager acknowledged discussing the NRC's conclusions, but validated the fact that security officers were told the NRC stated there "appears to be a potential chilled work environment in Security."

• Security officers stated they were never informed of the site's development and implementation of a Security SCWE Action Plan and were unaware of the specific actions required by the existing plan.

• Security officers perceived site management to be simply "putting checks in the block" to credit completion of action items and were not committed to changing the existing safety conscious work environment issues in the Security Department.

• Security officers identified a lack of interaction with supervisory and management personnel above the Security Shift Supervisor level within the Security Department and site senior management personnel external to the Security Department. Security officers did acknowledge an increase in the attendance of Security Operations Superintendents at shift turnover meetings.

• Security officers were unaware of the establishment of the site's Security Ombudsman Program and the intent of the program. Additionally, the security officers were unaware of who the security ombudsman was for their respective shift despite the selection and assignment of staff to these positions at the end of March 2014.

• Security officers were not aware of a change in the site security chain of command. Specifically, the fact that the Palisades Security Manager no longer reported to the Entergy Corporate Security Director, but reported to the Site Vice President through the Regulatory and Performance Improvement Director was not communicated. In addition, security officers were not introduced to the Regulatory and Performance Improvement Director.

• Since November 2013, the site's Aggregate Performance Review rated the Security Department as Green in the area of Nuclear Safety.

At an Aggregate Performance Review Meeting conducted on May 19, 2014, this rating was challenged by a manager outside the Security Department and, as a result of this challenge, the participants agreed the Security Department should be rated Red in this area due to the chilled work environment identified in the department.

Since November 2013, the Security Department had been rating this area as Green in the Department Performance Review and this rating was unchallenged by senior management until the May 2014 Aggregate Performance Review Meeting.

The inspectors concluded that, to date, the site had completed all the actions as committed to in the Security SCWE Action Plan. However, the inspectors concluded that the quality of the actions implemented have been insufficient to assess and understand the cause of the chilled work environment within the Security Department and did not demonstrate a strong commitment to effectively improve the safety conscious work environment in the Security Department. Specifically, significant gaps were found to exist in the security officers' knowledge of the actions being taken to address the chilled safety conscious work environment and management's commitment to improving the overall safety conscious work environment.

4OA6 Management Meetings

a. Interim Exit Meeting On May 23, 2014, the inspectors presented the preliminary inspection results to Mr. A. Vitale, Site Vice President, and other members of the licensee staff.

b. Exit Meeting On June 11, 2014, the inspectors presented the final inspection results to Mr. A. Vitale, Site Vice President and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

A. Vitale, Site Vice President

W. Nelson, Training Manager

G. Heisterman, Maintenance Manager

A. Notbohm, CA&A Manager

O. Gustafson, Regulatory and Performance Improvement Director

D. Corbin, Operations Manager

M. Seleski, Chemistry Supervisor

C. Plachta, Nuclear Oversight Manager

B. Davis, Engineering Director

E. Chetfield, Employee Concern Program Manager

D. Lucy, Planning, Scheduling and Outage Manager

J. Wright, Radwaste Supervisor

J. Ridley, Emergency Preparedness Coordinator

J. Haverly, Security Supervisor

NRC

A. Boland, Director, Division of Reactor Projects

E. Duncan, Branch Chief, Division of Reactor Projects

A. Garmoe, Senior Resident Inspector

A. Scarbeary, Resident inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None

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 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.

Condition Reports

CR-PLP-2007-05898 Greater than Green Security Finding Identified November 6, 2007

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

CR-PLP-2009-04028 Increasing Trend in Number of Maintenance Rule a(1) Issues and Repeat Equipment Failures at Palisades August 21, 2009

CR-PLP-2009-04831 Four New Capacitors for P/S-0110A Have Different Size Case than the Installed Ones October 16, 2009

CR-PLP-2009-05002 Declining Trend in RPS Voltage Converter +15 Vdc Output October 29, 2009

CR-PLP-2010-00315 Potential Adverse Trend with Scaffold Periodic Inspection January 22, 2010

CR-PLP-2010-00551 Additional Operability and/or Mitigating Action Guidance is Needed Regarding the Effect of Unfiltered Air In-Leakage into the Control Room Envelope February 8, 2010

CR-PLP-2010-02351 Received Alarm

EK-0601A, Variable High Power Level Channel Trip June 13, 2010

CR-PLP-2010-02551 Received Unexpected AFAS Alarms in the Control Room June 27, 2010

CR-PLP-2010-03292 P-55C, 'C' Charging Pump, Declared Maintenance Rule Unavailable August 6, 2010

CR-PLP-2010-03809 Functional Failure Determination Performed for

CR-PLP-2010-2551 Determined the Issue was a Functional Failure and Should be Re-classified September 7, 2010

CR-PLP-2010-06100 Increase in Spent Fuel Pool Liner Leakage November 14, 2010

CR-PLP-2011-02144 Received Alarms

EK-0602A and

EK-0606A April 28, 2011

CR-PLP-2011-03902 Indications of a Sheared Shaft on Service Water Pump P-7C August 9, 2011

CR-PLP-2011-04620 Primary Coolant System Unidentified Leakage Greater Than the Technical Specification Limiting Condition for Operation September 16, 2011

CR-PLP-2011-04822 Post 95002 Corrective Actions March 7, 2013

CR-PLP-2011-04822 Unplanned, Automatic Reactor Trip Occurred During Maintenance on a DC Supply Panel September 25, 2011

CR-PLP-2011-05125 ERO Staff Augmentation Test - TSC Operations Support Communicator had Not Arranged for an Alternate to Fill His Position October 6, 2011

CR-PLP-2011-05127 ERO Staff Augmentation Test - CR Operations Support did Not Satisfactorily Respond to the Test Notification October 6, 2011

CR-PLP-2011-05128 ERO Staff Augmentation Test - On Call I&C Electrical Engineer Determined to be on Medical Leave October 6, 2011

CR-PLP-2011-05723 Perform Root Cause Evaluation for P-8B, Steam Driven Auxiliary Feedwater Pump, Tripping on Overspeed October 28, 2011

CR-PLP-2011-06845 Manual Reactor Trip Due to Lowering Feedwater Suction Pressure Caused by CV-

0711, Feed Pump P-1A Recirculation Valve December 14, 2011

CR-PLP-2012-00165 PCS Leak Identified by Operating Crew January 7, 2012

CR-PLP-2012-00188 Control Room Requested Electrical Maintenance to Investigate Reduced Amps on Group 2 Pressurizer Heaters January 7, 2012

CR-PLP-2012-00361 Maintenance Rule Performance Criteria Exceeded for Main Feedwater System January 16, 2012

CR-PLP-2012-00455 No Maintenance Rule Evaluation Performed for Potential Failure of

ELU-175 January 19, 2012

CR-PLP-2012-00499 Personnel Contamination Event While Working in the Spent Fuel Pool Area for Dry Fuel Storage Activities January 20, 2012

CR-PLP-2012-00665 Placekeeping Not Performed During Monthly Communications Checks January 26, 2012

CR-PLP-2012-00728 Personnel Contamination Event While Working in the RCA to Issue M&TE January 31, 2012

CR-PLP-2012-00774 Missed Delivery of Replacement Power Supply Boards February 1, 2012

CR-PLP-2012-00860 Personnel Contamination Event While Performing a Peer Check for Chemistry Verifying Valve Positions During PCS Sampling February 6, 2012

CR-PLP-2012-00861 Personnel Contamination Event While Performing Sampling PCS and SIRWT February 6, 2012

CR-PLP-2012-00873 Fire Tours on Certain Doors Not Documented on the Fire Tour Checklist February 6, 2012

CR-PLP-2012-00895 Trend in Personnel Contamination Events. February 7, 2012

CR-PLP-2012-01073 During Annual Performance Exam Crew Failed to Accurately Classify the Event February 15, 2012

CR-PLP-2012-01775

PI-1490, K-6B Starting Air Pressure Indicator for EDG 1-2 was Reading Abnormally High March 17, 2012

CR-PLP-2012-01778 Unsatisfactory Failure Rate of New Style Diesel Generator Air Start Pressure Control Valves March 17, 2012

CR-PLP-2012-01828 Plant Drawings in Error Concerning Breakers Operated During Temporary Modification Installation March 20, 2012

CR-PLP-2012-02044 Operation of Primary Coolant Pumps with

Inadequate Net Positive Suction Head

April 2, 2012

CR-PLP-2012-02107 Tracking CR for Correcting Configuration Errors April 2, 2012

CR-PLP-2012-02384 Inappropriate Response to a Dose Rate Alarm April 10, 2012

CR-PLP-2012-02725 Review of Turbine Driven AFW Maintenance that was Performed in October 2011 Revealed Discrepancies with the Work Order and Procedures April 16, 2012

CR-PLP-2012-02730 Review of Turbine Driven AFW Maintenance that was Performed in October 2011 Revealed

Procedure

Quality Issues April 16, 2012

CR-PLP-2012-02780 QA Functional Area Rating for EP is Yellow for Trimester Report Covering November 2011

through February 2012 April 17, 2012

CR-PLP-2012-02905 Thirteen Condition Reports Generated On-Site for Losing Control of Assigned Photo Badges in the Protected Area April 19, 2012

CR-PLP-2012-03012 RPS Matrix Ladder Power Indicating Light Extinguished on Channel C RPS Cabinet July 11, 2013

CR-PLP-2012-03229 Inappropriate Response to a Dose Rate Alarm April 25, 2012

CR-PLP-2012-03313 Inappropriate Response to a Dose Rate Alarm April 27, 2012

CR-PLP-2012-03761 Fatigue Assessment Not Sent to Access Authorization for Post-Event Tests May 9, 2012

CR-PLP-2012-03782

MO-3068, Redundant HPSI Injection Valve, Would Not Move In Closed Direction May 9, 2012

CR-PLP-2012-03873 Received Control Room Alarms for SPI Trouble, 125V DC Bus Ground, and CCW Heat Exchanger Hi-Lo Temperature Unexpectedly May 14, 2012

CR-PLP-2012-03948 Could Not Locate Fatigue Assessment Paperwork May 17, 2012

CR-PLP-2012-03948 Fatigue Assessments Not Performed as Required May 17, 2012

CR-PLP-2012-04292 Two Key System Health Work Orders Moved Inside the Scope Freeze Milestone Per Engineering's Request June 5, 2012

CR-PLP-2012-04457 Radiation Protection Technician Response to Off-hours Mobilization Drill June 6, 2012

CR-PLP-2012-04690 Stop Work for Effluents for SIRW Tank Not

Recognized June 25, 2012

CR-PLP-2012-04885 SIRW Tank Observed Dripping in Main Control Room July 5, 2012

CR-PLP-2012-04921 Failure of PMT of SIRWT July 7, 2012

CR-PLP-2012-05512 CR for

MO-3068, Redundant HPSI Injection Valve, Failed to Close Not Appropriately Classified August 6, 2012

CR-PLP-2012-05832 Usable Parts Not Currently on Material Readiness List August 22, 2012

CR-PLP-2012-05849

LPIR-0101B Pressurizer Level Pressure Channel 2 Input Channel 4 Did Not Read Correctly After Modification August 23, 2012

CR-PLP-2012-05854 Emergency Planning CFAM Performance Indicator for Defense-in Depth Turned Red as of July PI Data August 23, 2012

CR-PLP-2012-05893 After Replacement of New Power Supplies, "A" Channel of RPS Failed to Pass PMT August 25, 2012

CR-PLP-2012-05894 New Power Supplies Would Not Pass PMT August 25, 2012

CR-PLP-2012-06069 An Existing Degraded Fire Barrier is Only Marginally Acceptable September, 2012

CR-PLP-2012-06382 Junction Box J91 Not Protected Against External Flooding September 25, 2012

CR-PLP-2012-06404 Potential Release of Low Level Radioactive Material September 26, 2012

CR-PLP-2012-06899 Palisades May Not Be Out of Industry Norm for Containment Work Performed Online October 25, 2012

CR-PLP-2012-07003 Shift Managers Inaccurate EP Classifications November 1, 2012

CR-PLP-2012-07010 RP Fundamental Techniques Not Followed November 1, 2012

CR-PLP-2012-07047 Steam/Water Pin Hole Leak on Inlet Socket Weld Side of

MV-MS526, E-50B ASDV

CV-0779

Inlet Drain Valve November 4, 2012

CR-PLP-2012-07140 Leaks That Impacted Plant Operations By Causing Shutdowns or Forced Outages November 8, 2012

CR-PLP-2012-07348 Limited Repair of Underground Pipe Leak and Incomplete Risk Assessment of Underground Piping and Tanks November 21, 2012

CR-PLP-2012-07351 Reductions in Source Term and CRE Ineffective November 21, 2012

CR-PLP-2012-07430 One Member of On Duty ERO Team (TSC Security Coordinator) Did Not Respond During Quarterly Augmentation Test November 28, 2012

CR-PLP-2012-07617 Replacement Impellers for the Primary Coolant Pump Oversized December 7, 2012

CR-PLP-2012-07685 The Ratio of Oil Drained to Oil Added was Outside of Acceptance Criteria December 12, 2012

CR-PLP-2013-00158 Timeliness of the Immediate Operability for the

Small Steam Leak Discovered Near

MV-MS526,

'B" S/G Atmospheric Steam Dump Drain Isolation January 14, 2013

CR-PLP-2013-00422 Work Orders in "Finish" Greater Than 30 Days are Not Being Routed Back to the Technical Specification Surveillance Coordinator in a Timely Fashion January 30, 2013

CR-PLP-2013-00460 Critical Group Re-Investigation Expired February 1, 2013

CR-PLP-2013-00656 Entered LCO for Component Cooling Water Systems Due to Indications of a CCW Leak on

E-54A, Component Cooling Water Heat Exchanger February 14, 2013

CR-PLP-2013-01017 Changing System Software on Security Computer System Impacted the Ability to Receive Alarms March 6, 2013

CR-PLP-2013-01023 During 2013 First ERO Staff Augmentation Test the JIC Inquiry Responder Did Not Satisfactorily Respond to the Test March 7, 2013

CR-PLP-2013-01025 During 2013 First ERO Staff Augmentation Test the OSC Mechanical Coordinator Did Not Satisfactorily Respond to the Test March 7, 2013

CR-PLP-2013-01026 During 2013 First ERO Staff Augmentation Test the EOF Security Coordinator Did Not Satisfactorily Respond to the Test March 7, 2013

CR-PLP-2013-01213 Administrative Issues Identified in

EC 20082 and

EC 37737 March 20, 2013

CR-PLP-2013-01446 Track CR for Correcting Configuration Errors April 1, 2013

CR-PLP-2013-01882 Preventive Maintenance Work Will Be Performed Late for

CK-DMW400 April 26, 2013

CR-PLP-2013-02095 New +12 Vdc Test Power Supply Found to Adversely Affect the Alpha Channel Bistable Setpoints May 9, 2013

CR-PLP-2013-02158 Part 21 Evaluation Not Rigorous Enough to Support Conclusions and Not Addressing All Issues Raised May 13, 2013

CR-PLP-2013-02644 Overspeed Testing of P-8B was Not Successful with Newly Installed Parts June 15, 2013

CR-PLP-2013-02802 Fuel Oil Transfer System Delay in Discharge Pressure Increase June 25, 2013

CR-PLP-2013-02831 Quality Assurance Escalation on the Timeliness/Effectiveness of Correcting QA Identified Issues June 7, 2013

CR-PLP-2013-02959 During Quarterly ERO Staff Augmentation Test a Member of the ERO Team (OSC RAD/Chem Coordinator) Did Not Respond

July 9, 2013

CR-PLP-2013-02982 Aux Feedwater

AFAS-FOFF Subsystem Trip Unexpectedly July 9, 2013

CR-PLP-2013-02982 Received Alarm

EK-0137, Aux Feedwater

AFAS-FOGG Subsystem Trip, Unexpectedly

July 9, 2013

CR-PLP-2013-03001 Power Supply P/S-0704 was Removed Following Failure

July 10, 2013

CR-PLP-2013-03002 FIN TEAM Electrician Did Not Complete Required Computer Based Training by Due Date July 10, 2013

CR-PLP-2013-03025 RPS Matrix "CD" Power Indication Light Extinguished on C-06 July 11, 2013

CR-PLP-2013-03026 Power Supply P/S-CW8-15 was Removed From the RPS Following a Failure July 11, 2013

CR-PLP-2013-03063 Received Alarm for

AFAS-FOGG Subsystem Trip Unexpectedly July 15, 2013

CR-PLP-2013-03103 Security Force Member Failed to Shoot Qualifying Score July 17, 2013

CR-PLP-2013-03136 NRC Identified Issue - ALARA Planning for SFP Rerack Failed to Identify Alpha Level 3

Contamination

July 18, 2013

CR-PLP-2013-03137 NRC Identified Issue - Individual Working on the SFP Rerack Not Wearing a Lapel July 18, 2013

CR-PLP-2013-03155 Missing Rifle Magazine Rounds July 19, 2013

CR-PLP-2013-03298 Received Unexpected

AFAS-FOGG Alarms July 31, 2013

CR-PLP-2013-03523 Door 15, Equipment Room Missile Shield/Radiation Door, Was Unable to Be Closed August 13, 2013

CR-PLP-2013-03683 Exceeded Maintenance Rule Criteria for Auxiliary Feedwater Actuation System (AFAS) August 21, 2013

CR-PLP-2013-03838 During Third Quarter ERO Staff Augmentation Test the Designated EOF Van Buren County Liaison Failed to Respond

August 29, 2013

CR-PLP-2013-03839 During Third Quarter ERO Staff Augmentation Test the Designated TSC Reactor Engineer Provided a 45 Minute Response

August 29, 2013

CR-PLP-2013-03840 During Third Quarter ERO Staff Augmentation Test One Designated Non-traditional Radiation Protection Technic Failed to Respond to the Test

August 29, 2013

CR-PLP-2013-04246 Power Supplies Received from Vendor Had a Damaged Component September 27, 2013

CR-PLP-2013-04391 Potential Trend in Vital Area Doors Found Unsecured October 8, 2013

CR-PLP-2013-04405 Key System Health Work Order was Not Completed per the Schedule October 9, 2013

CR-PLP-2013-04462 71 Licensed Operator Requalification Tasks Selected for Continuing Training Have Not Been Trained on Within Their Prescribed Frequencies October 15, 2013

CR-PLP-2013-04802 Crack in a Turbocharger Support Weld for Emergency Diesel Generator 1-1 November 6, 2013

CR-PLP-2013-04817 Operating Experience Review Revealed Possible Secondary Fire Could Be Caused in the Cable Spreading Room By a Short in the Station Battery Room November 7, 2013

CR-PLP-2013-05166 ALARA Planning and Controls Green Finding December 6, 2013

CR-PLP-2013-05176 NRC Debriefed Three Green NCVs December 8, 2013

CR-PLP-2013-05278 Potential Multiple Leak Locations Originating from the Irrigation Header Isolation Line in the Screen House December 14, 2013

CR-PLP-2014-00022 Palisades Security SCWE Action Plan January 1, 2014

CR-PLP-2014-00687 Electronic Dosimeter Issue January 26, 2014

CR-PLP-2014-01193 Substantial Accumulation of Ooze, Sludge, and Bioslimes were Discovered Inside of Piping February 8, 2014

CR-PLP-2014-01195 Missed Inspection of Opportunity February 8, 2014

CR-PLP-2014-01359 No Materials Ordered Resulting in Delay to Perform Work Order February 14, 2013

CR-PLP-2014-02656 Violations of

EN-OM-123 Fatigue Management Program April 19, 2014

CR-PLP-2014-02856 Installed Flexitallic Style R Gasket Had Significantly Deteriorated May 1, 2014

CR-PLP-2014-02863 Gasket Supplied for Work was Incorrect May 2, 2014

CR-PLP-2014-02864 Slight Over Crush of the B/B Gasket May 2, 2014

LR-LAR-2012-00211 SIRW Tank CAL Items August 1, 2012

WT-WTPLP-2012-00425 Ensure Electrical and I&C Supervision Periodically Discuss the Importance of 30 Min Responder Responsibilities December 21, 2012

WT-WTPLP-2014-00022 Security SCWE Action Plan January 15, 2014

Apparent Cause Evaluation

CR-PLP 2012-04457

HT-ACE Insufficient Radiation Protection Technician 30 Minute Response for the Off-Hours Mobilization Drill July 12, 2012

CR-PLP-2011-06130 Operations Human Performance Standards December 7, 2011

CR-PLP-2012-00362 NRC Unplanned Scrams per 7,000 Critical Hours Indicator is White as a Result of Four Reactor Trips February 14, 2012

CR-PLP-2012-01073 Annual Operator Licensing Exam EAL Classification Failures February 15, 2012

CR-PLP-2012-01073

HT-ACE Annual Operator Licensing Exam EAL Classification Failures March 12, 2012

CR-PLP-2012-01482 HT Apparent Cause Evaluation Report for Chemical Control Program Cause/Corrective Action and Chemistry Department ACE Quality Issues August 25, 2012

CR-PLP-2012-01775 Higher Tier Apparent Cause Evaluation:

PI-1490, K-6B Starting Air Pressure Indicator for the Emergency Diesel Generator 1-2 was Reading Abnormally High June 18, 2012

CR-PLP-2012-03873 Level 1 Human Performance Evaluation Review:

CCW Surge Tank Fill CV Doesn't Turn On Red Light When Open (WR #271959) May 16, 2012

CR-PLP-2012-03948 Level 2 Human Performance Error Review:

Fatigue Assessment Not Performed in Post-Event Response May 24, 2012

CR-PLP-2012-04457 Insufficient Radiation Protection Technician 30 Minute Response for the Off-Hours Mobilization Drill July 12, 2012

CR-PLP-2012-06454

HT-Apparent Cause Evaluation Report for Maintenance Department Procedure Use and Adherence December 5, 2012

CR-PLP-2012-07348 Lower Tier Apparent Cause Evaluation:

Limited Repair of Underground Pipe Leak and Incomplete Risk Assessment of Underground Piping and Tanks January 16, 2013

CR-PLP-2013-00460 Lower Tier Apparent Cause Evaluation:

Critical Group Re-Investigation Expired February 20, 2013

CR-PLP-2013-02982 Lower Tier Apparent Cause Evaluation:

P/S-0704 Failure April 15, 2014

CR-PLP-2013-03063 Lower Tier Apparent Cause Evaluation:

Failure of AFAS Optical Isolator August 13, 2013

CR-PLP-2013-03650 Operations OJT/TPE Practice Issues October 15, 2013

CR-PLP-2014-00589 Level 1 Human Performance Evaluation: Security Compensatory Measures Not in Place as Required January 26, 2014

CR-PLP-2014-02461 Equipment Apparent Cause Evaluation:

E-22B; Unexpected Discovery of ID Pitting on Recently Replaced Jacket Water Heat Exchanger May 7, 2014

Common Cause Evaluation

CR-PLP-2012-02905 Negative Trend Relating to the Control of Security Keycards in Controlled Areas May 5, 2012

CR-PLP-2012-05861 Common Cause Analysis for Possible Emerging Trend for Procedural Compliance in Respiratory Protection. September 17, 2012

CR-PLP-2012-07140 Palisades Leaks That Resulted In or Extended Forced Outages in June 2012 Through November

2012 December 6, 2012

CR-PLP-2013-03457 Common Cause Analysis for Cross-Cutting Aspect H.2.c, Human Performance, NRC Findings July 28, 2013

CR-PLP-2013-03533 Unplanned Entries into TS LCO Action Statements August 13, 2013

CR-PLP-2013-04391 Trend in Vital Area Doors Found Unsecured December 17, 2013

Audit, Assessment, and Self-Assessments

LO-PLPLO-2011-0101 Effectiveness Reviews of RCE

CR-PLP-2011-5723 November 10, 2011

LO-PLPLO-2012-00037 Snapshot Assessment of DPRMs and Coaching Quality in Radiation Protection March 29, 2012

LO-PLPLO-2012-00051 Snapshot Assessment of

Use of EAL Basis Document, and Causes of Untimely or Inaccurate EAL Classifications May 8, 2012

LO-PLPLO-2012-00084 Effectiveness Review of

CR-PLP-2012-3873 (1 Year Snapshot) March 17, 2014

LO-PLPLO-2012-00084 Effectiveness Reviews for Root Cause Evaluation Completed Under CR-PLP-2012-

3873 June 12, 2012

LO-PLPLO-2012-00106 Snapshot Assessment of Power Air Purifying Respirator Issues September 10, 2012

LO-PLPLO-2012-00117 Snapshot Assessment - Plant Status and Configuration Control November 3, 2012

LO-PLPLO-2012-00121 IST Program Focused Self-Assessment May 20, 2013

LO-PLPLO-2012-00122 Electrical Work Practices May 17, 2013

LO-PLPLO-2012-00125 Snapshot Assessment on OBJ 5 (OJT-TPE) November 3, 2012

LO-PLPLO-2012-00169-00003 Chemistry Trending Program January 19, 2013

LO-PLPLO-2012-00176 Perform Crew Assessment, in Accordance with

EN-OP-117, Operations Assessments, of Shift 5 November 15, 2012

LO-PLPLO-2013-00015 Snapshot Self-Assessment:

Fatigue Assessments Due to Post Event/For-Cause Testing March 26, 2013

LO-PLPLO-2013-00028 Rework Program Snapshot Assessment July 10, 2013

LO-PLPLO-2013-00042 Tendon Selection Criteria Benchmark July 29, 2013

LO-PLPLO-2013-00069 Follow-up Snapshot Assessment for

CR-PLP-2013-4462 - Some Licensed Operator Tasks Selected for Continuing Training Were not Presented Within Required Periodicity December 12, 2013

LO-PLPPLO-2012-00003 Operations Training January 5, 2012

LO-PLPPLO-2012-00048 Snapshot Assessment Critical Steps in Operations Procedures May 5, 2012

LO-PLPPLO-2014-00076 Snapshot Assessment of Accredited Training March 5, 2014

PL-PLPLO-2012-00083 5 Year Periodic Self-Assessment November 2, 2013

QA-2012-PLP-013 Quality Assurance Surveillance Report May 4, 2012

QA-3-2013-PLP-01 Corrective Action Program August 1, 2013

QA-7-2013-PLP-01 Emergency Plan July 1, 2013

Miscellaneous

10CFR50.54(q) Evaluation for Relocation of One of the Two Emergency Van to the EOF July 26, 2012 Backshift Mobilization Drill Results Overall Response Report June 15, 2009 CCW, DG 1-1 & 1-2 and Fire Water System Report Various Dates Maintenance, Operations, and Radiation Protection Safety Culture Survey April 2014 NRC Exit Notes for RP Radiation Monitoring/Radiological Hazard Assessment/ ALARA Planning Inspection. December 6, 2013 Palisades Condition Prescreening Meeting Package Various Dates Palisades Condition Review Group Meeting Package Various Dates Palisades Correction Action Review Board Meeting Package May 8, 2014 Palisades ECP Informal Benchmark Report April 2014 Palisades Maintenance Rule Periodic Assessment October 20, 2011 Palisades Maintenance Rule Periodic Assessment June 4, 2013 Palisades Nuclear Plant Quarterly Trend Reports

1Q2012 through 4Q2013 Palisades Security SCWE Action Plan May 9, 2014 Palisades Self-Assessment Review Board Meeting Package May 6, 2014 Palisades Spent Fuel Pool Leakage Trend April 2012 - Present Plant Health Committee Meeting Package May 19, 2014 PLP CRG Summary Agenda Report Prescreen May 9, 2014 Quarterly Augmentation Tests of the NRO Notification System

(Everbridge) Various Security Work Hour Violation/Waiver Report April 1, 2013 -

May 21, 2014

BOP-UT-14-012 UT Erosion/Corrosion Examination for

HB-23-4-P1836 February 19, 2014

BOP-UT-14-012 UT Erosion/Corrosion Examination for

HB-23-116-P1827 February 19, 2014

BOP-UT-14-013 UT Erosion/Corrosion Examination for

KB-1-P176 February 19, 2014

CR-PLP-2013-04677 HUE Human Performance Evaluation - Supplemental RP Tech Left a Suspended Empty Fuel Rack in the SFP Unattended, Creating a Potential Locked High Radiation Area Condition October 29, 2013 Drawing C-38 Field Erected Tanks, Sheet 2 Revision 9 Drawing C-539 Cellular Slab Repair Plan of Control Room Roof

EL 643'-0"

Revision C Drawing E-44 Lighting Panel Schedule L-35, Sheet 115A Revision 5

EC 27632 Perform an Evaluation of Inspection Opportunities Prior to License Renewal Per Commitment LO-

LAR-2009-244-38 March 17, 2011

EC 38728 Raw Water Corrosion Program Report - Operational Cycle 22 and 2012 Refueling Outage January 14, 2014

LER 2011-004-01 Turbine-Driven Auxiliary Feedwater Pump Inoperable in Excess of Technical Specification Requirements Due to Unexpected Trip January 31, 2012

LER 2011-005-00 Service Water Pump Shaft Coupling Failure October 3, 2011

LER 2011-006 Valve Packing Failure Resulted in Reactor Trip and Auxiliary Feedwater System Actuation November 10, 2011

LER 2011-007 Direct Current Electrical System Fault Causes Reactor Trip and Multiple Safety System Actuations November 21, 2011

LER 2011-008 Reactor Protection System and Auxiliary Feedwater System Actuation February 3, 2012

LER 2012-002-00 Technical Specification Required Shutdown Due to Un-isolable Secondary Side Drain Valve Leak December 20, 2012

LER 2013-001 Technical Specification Required Shutdown Due to a Component Cooling Water System Leak April 15, 2013

LER 2013-003-01 Both Control Room Ventilation Filtration Trains Declared Inoperable October 11, 2013

LER 2013-004-00 Discovery of Latent Design Deficiency Results in Non-Compliance with 10CFR50 Appendix R

January 6, 2014

PL-ERO-NTRP010 Lesson Plan - RPT ERO Duties

Revision 0

PLLP-LOR-12B-03 Emergency Event Classification Revision 0

PNP 2013-044 License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times June 25, 2013

RWP 2012-0319 Repair of

CRD-24 Housing Various Revisions Work Order

177025 P-52C, Remove/Inspection Inboard Pump Bearing Outer Flinger June 3, 2014 Work Order

318169

PI-1489 Indicated 238 psig August 8, 2012 Work Order

342442 Perform Exterior Inspection of the

MV-FP707, FPS Header Isolation Piping July 13, 2013

Work Order

347562 J-91, Install Flood Barrier Within Conduits March 27, 2014 Work Order

355289 P-18A, Troubleshoot and Correct Air In-Leakage May 1, 2014 Work Order

356432 P/S-0704 Power Supply Failure July 11, 2013 Work Order

362248

MV-CVC2157 Exhibiting Leak-By June 4, 2014 Work Order

367426 K-6A, Cracked Turbo Charger Support May 19, 2014 Work Order

51623737 P/S-0110A Aux Hot Shutdown Panel Capacitor Replacement April 15, 2010 Work Order

52357830

CK-DMW400 Non-Intrusive Check Test April 26, 2013 Work Order

52432007

CK-DMW400 Non-Intrusive Check Test June 10, 2013

Operating Experience

CR-ANO-C-2007-01862 All Positions Required by Table B-1 of the ANO Emergency Plan Not Filled During an Annual ERO Staffing Drill Dated 2007 CRG OPEX Report Database of CRG Reviews of Operating Experience January 2012 -

May 6, 2014

CR-PLP-2007-06343 Potential Staffing Problem for the RP Department to Meet Site Emergency Plan ERO Obligations. December 20, 2007

CR-PLP-2009-04527 Internal OE - Improper Classification of the Event During an Emergency Preparedness Drill

September 29, 2009

CR-PLP-2012-01245

IER-L2-12-14 - Automatic Reactor Scram Resulting From a Design Vulnerability in the

4.16-kV Bus Undervoltage Protection Scheme February 23, 2012

CR-PLP-2012-01827

NRC-IN-2012-03 - Design Vulnerability in Electric Power System March 20, 2012

CR-PLP-2012-05719

NRC-IN-2012-14 - Motor Operated Valve Inoperable Due to Stem-Disc Separation August 16, 2012

CR-PLP-2012-05721

NRC-IN-2012-11 - Age Related Capacitor Degradation August 6, 2012

CR-PLP-2012-07334

NRC-21-2012-48-00 - Commercial Grade Dedication Not Properly Applied to Type 9200

Butterfly Valves November 20, 2012

CR-PLP-2013-02674

NRC-RIS-2013-05 - NRC Position on the Relationship Between General Design Criteria and Technical Specification Operability June 17, 2013

CR-PLP-2023-01678

NRC-IN-2013-06 - Corrosion in Fire Protection Piping Due to Air and Water Interaction April 15, 2013 eB OPEX Report Completed OE Reviews Assigned Through eB January 2012 -

May 5, 2014

LO-PLP-2011-00338 MOV Program WT September 15, 2011

OE-31777 External OE - Human Performance Errors Contributed to Less than Expected Emergency Response Organization Team Performance May 26, 2010

OE-2013-000026

NRC-21-2012-55-00 - Adequacy of Design Change in AM Magne-Blast Circuitry Breakers January 8, 2013

OE-2013-000144

NRC-IN-2013-01 - Emergency Action Level Thresholds Outside the Range of Radiation Monitors February 26, 2013

OE-2013-000388

NRC-21-2012-55-01 - Update Report - Adequacy of Design Change in AM Magne-Blast Circuitry Breakers June 12, 2013

OE-2013-000533

NRC-RIS-2013-09 - Guidelines for Effective Prevention and Management of System Gas Accumulation August 23, 2013

OE-2013-000651

NRC-21-2013-50-00 - Rosemount Model 710DU Trip Units May Not Meet Established Post-

Exposure Radiation Performance Criteria September 20, 2013

OE-2013-000711

NRC-21-2013-68-00 - Interim Report - Inability to Complete 10CFR Part 21 Evaluation Regarding Cracking in

KCR-13 Standby Battery Jars December 20, 2013

OE-2014-000061

NRC-IN-2014-03 - Turbine-Driven Auxiliary Feedwater Pump Overspeed Trip Mechanism Issues February 25, 2014

Procedures

Administrative Procedure No 4.00 Operations Organization, Responsibilities and Conduct Revision 53

EI-16.1 Maintenance of Emergency Equipment Revision 30

EN-DC-336 Plant Health Committee Revision 7

EN-EC-100 Guidelines for Implementation of the Employee Concerns Program Revision 7 Revision 8

EN-EP-305 Emergency Planning 10CFR50.54(q) Review Program Revision 3

EN-EP-306 Drills and Exercises Revision 5

EN-EP-310 Emergency Response Organization Notification System Revision 2

EN-FAP-LI-001 Condition Review Group (CRG) Revision 4

EN-FAP-LI-003 Corrective Action Review Board (CARB) Process Revision 13

EN-HU-102 Human Performance Traps &Tools Revision 13

EN-HU-103 Human Performance Error Reviews Revision 7

EN-LI-100 Process Applicability Determination Revision 15

EN-LI-102 Corrective Action Process Revision 23

EN-LI-104 Self-Assessment and Benchmark Process Revision 10

EN-LI-115 Apparent Cause Evaluation (ACE) Process Revision 15

EN-LI-118 Cause Evaluation Process Revision 17, 18, 19 and 20

EN-LI-118-06 Common Cause Analysis Evaluation Revision 4

EN-LI-121 Trending and Performance Review Process Revision 15

EN-MA-118 Foreign Material Exclusion Revision 8

EN-MA-125 Troubleshooting Control of Maintenance Activities

Revision 4

EN-MA-125 Troubleshooting Control of Maintenance Activities Revision 17

EN-NS-221 Security Department Standards and Expectations Revision 5

EN-OE-100 Operating Experience Program Revision 20

EN-OP-117 Operations Assessments Revision 6

EN-RP-115 BRAC/SRMP Survey Program Revision 0

EN-WM-107 Post-Maintenance Testing Revision 4

FPIP-1 Fire Protection Plan, Organization and Responsibilities Revision 22

FPSP-SO-3 Fire Suppression Water System Fire Hydrant Flush Revision 8

FWS-M-6 Auxiliary Feedwater Turbine Maintenance Revision 28

SEP-SW-PLP-002 Service Water and Fire Protection Inspection Program Revision 3

Root Cause Evaluations

CR-PLP-2011-05723 Root Cause Evaluation:

Auxiliary Feedwater Pump P-8B Overspeed Trip Actuation April 23, 2012

CR-PLP-2012-03873 Root Cause Evaluation:

Ground Connected to DC Circuit on CCW Tank Level Switch August 15, 2012

CR-PLP-2012-05054 Root Cause Evaluation Report for Foreign Material Intrusion P-74, SIRWT Recirculation Pump July 12, 2012

CR-PLP-2012-07047 Steam Leak in

MV-MS526 Upstream Weld Results in Plant Shutdown November 27, 2012

CR-PLP-2013-00885 Root Cause Evaluation Report:

Main Generator Disconnect

MOD 26H5 Hotspot March 28, 2103

CR-PLP-2014-00738 Root Cause Evaluation:

Unattended Pathway Leads to One Hour Reportable Safeguards Event to the NRC February 24, 2014

LIST OF ACRONYMS

CAL Confirmatory Action Letter

CFR Code of Federal Regulations

DC Direct Current

ENO Entergy Nuclear Operation

IP Inspection Procedure

NRC Nuclear Regulatory Commission

SCWE Safety Conscious Work Environment

A. Vitale -3-

In accordance with

10 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

NRC Public Document Room or from the Publicly Available Records (

PARS) component of the

NRC 's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the

NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, /RA/ Eric Duncan, Chief

Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure: Inspection Report No. 05000255/2014007

w/Attachment: Supplemental Information cc w/encl: Distribution via

LISTSE RV