IR 05000255/2021004

Integrated Inspection Report 05000255/2021004 and Exercise of Enforcement Discretion

ML22031A283
Person / Time
Site:	Palisades
Issue date:	02/08/2022
From:	Billy Dickson NRC/RGN-III/DRP/B2
To:	Corbin D Entergy Nuclear Operations
References
EA-21-159 IR 2021004
Download: ML22031A283 (27)

Text

February 7, 2022

SUBJECT:

PALISADES NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000255/2021004 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Corbin:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant. On January 19, 2022, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Palisades Nuclear Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Dickson, Billy on 02/07/22 Billy C. Dickson, Jr., Chief Branch 2 Division of Reactor Projects Docket No. 05000255 License No. DPR-20

Enclosure:

As stated

Inspection Report

Docket Number: 05000255 License Number: DPR-20 Report Number: 05000255/2021004 Enterprise Identifier: I-2021-004-0113 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Inspection Dates: October 01, 2021 to December 31, 2021 Inspectors: J. Cassidy, Senior Health Physicist J. Corujo-Sandin, Senior Reactor Inspector G. Hansen, Sr. Emergency Preparedness Inspector J. Havertape, Reliability and Risk Analyst P. Laflamme, Senior Resident Inspector J. Mancuso, Resident Inspector, Donald C. Cook Nuclear Plant C. St. Peters, Resident Inspector R. Trelka, Reactor Inspector Approved By: Billy C. Dickson, Jr., Chief Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Palisades Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Follow Preventative Maintenance Change Request Process Results in a Failure of Condensate Pump (P-2B) Oil Cooler and Subsequent Rapid Downpower Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [P.5] - 71152 FIN 05000255/2021004-01 Operating Open/Closed Experience A finding of green significance was self-revealed on July 28, 2021, for the licensee's failure to follow their preventative maintenance change request (PMCR) process. Specifically, a preventative maintenance activity scope was changed without processing a PMCR, resulting in a failure to perform the preventative maintenance on the condensate pump (P-2B) oil cooler. As a result, a pin hole leak developed in the P-2B oil cooler leading to an oil/water mixture discharging from the P-2B motor's upper bearing housing sight glass vent, and the subsequent need to perform a rapid downpower of the reactor to secure P-2B.

Additional Tracking Items

Type Issue Number Title Report Section Status EDG EA-21-159 Failure to Comply with 10 71124.08 Closed CFR Part 37

PLANT STATUS

The plant began the inspection period at full power and remained at or near full power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems on November 4, 2020:

Service water system Auxiliary feedwater (AFW) system

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk significant systems from impending severe weather during a Geomagnetic Storm Watch on October 30, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Left train low pressure safety injection on October 6, 2021

(2) Right train high pressure safety injection on October 1, 2021

(3) Left train AFW on October 26, 2021

(4) Right train containment spray on December 4, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Area 1: Control Room/Elev. 625' and Fire Area 33: Technical Support Center/

Elev. 625' on October 1, 2021

(2) Fire Area 22: Turbine Lube Oil Room/ Elev. 590' on October 7, 2021

(3) Fire Area 29-31: Mechanical Equipment Room/ Elev. 629'-2" & 639' on October 13, 2021

(4) Fire Area 13G: Spent Fuel Pool Heat Exchanger Room/ Elev. 590' on October 16, 2021

(5) Fire Area 6 & 8: Diesel Generator 1-2 and Fuel Oil Day Tank Room/ Elev. 590' on November 13, 2021

(6) Fire Area 59: Auxiliary Feedwater Pump P-8D Room/ Elev. 590' on November 17, 2021

(7) Fire Area 15: Engineering Safeguards Panel and Stairway/ Elev. 570'-664' on December 2, 2021

(8) Fire Area 21: Electrical Equipment Room/ Elev. 607'-6" on December 13, 2021

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Emergency Diesel Generator (EDG) rooms on October 18, 2021

71111.07T - Heat Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)

The inspectors evaluated heat exchanger/sink performance on the following:

(1) Control Room Heating, Ventilation, and Air Conditioning (HVAC) Refrigerant Condensing Units (VC-10)

(2) Control Room HVAC Refrigerant Condensing Units (VC-11)

Ultimate Heat Sink (IP Section 03.04) (1 Sample)

(1) The Ultimate Heat Sink, Specifically Sections 03.04.d and 03.04.e were completed

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during a downpower to support QO-21C (P-8C AFW pump testing) on October 25, 2021.

(2) The inspectors observed and evaluated licensed operator performance in the Control Room during QO-1 SI Actuation Test (elevated risk evolution) - right train on November 30, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated PLSEG-LOR-21E-04, EOP 5.0, and PLSEG-LOR-21E-02, EP Static, on November 10, 2021

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Reactor protection system on October 27, 2021

(2) Primary coolant system on December 1, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Emergent issues associated with EDG 1-2 monthly surveillance, on October 6, 2021

(2) Yellow risk due to left train of service water out of service for planned maintenance and testing, on October 14, 2021

(3) Emergent work activities associated with P-55A charging pump following speed oscillations, on November 12, 2021

(4) Emergent work activities on 1-2 EDG jacket water temperature switch, on December 1, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Service water system evaluation on October 4, 2021

(2) Station Battery No. 1 and 2 system evaluation on December 13, 2021

(3) Pressurizer spray valve evaluation on December 15, 2021

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change (EC)-90291; T-2 Return Line Heat Exchanger Modification on December 6, 2021.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) EDG 1-2 timed start following check valve replacement, on October 28, 2021

(2) CVCO-4 performed on the P-55A charging pump following flow drive replacement, on December 2, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) QO-15A, Inservice Test Procedure- Component Cooling Water Pump P-52A, on October 5, 2021

(2) QO-16C, Inservice test procedure- Containment Spray Pump P-54C, on October 13, 2021

(3) QO-1, SI Actuation Test (left train), on November 30, 2021

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.

The licensee did not make any changes to the site's Emergency Action Level procedures or Emergency Plan during the period of this inspection (July 1, 2020 through June 30, 2021). The NRC inspectors independently reviewed the revisions of the site's Emergency Action Level procedures and Emergency Plan that were current for the inspection period to verify no changes were made.

This evaluation does not constitute NRC approval.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Spent Fuel Pool Ventilation - Unit 1

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (9 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Portable Ion Chamber Dose Rate Instruments "Ready for Use" at the entrance to the radiologically controlled area

(2) Extendable Geiger-Mueller Dose Rate Instruments "Ready for Use" at the entrance to the radiologically controlled area

(3) Personnel Contamination Monitors used at the exit of the radiologically controlled area

(4) Small Article Contamination Monitor used at the exit of the radiologically controlled area

(5) Shepherd Model 89 Box Calibrator used to perform functional checks of portable dose rate instruments

(6) Portable Geiger-Mueller Frisker "Ready for Use" at the Main Access Facility

(7) Personnel Gamma Portal Monitor used to exit the Main Access Facility

(8) Personnel Contamination Monitors used at the exit of East Radwaste radiologically controlled area

(9) Personnel Gamma Portal Monitor used to exit East Radwaste radiologically controlled area

Calibration and Testing Program (IP Section 03.02) (13 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Model 3030 Scaler Serial Number 334592

(2) DMC-3000 Electronic Dosimeter Serial Number A168801

(3) Telepole Serial Number 6605-002

(4) RO-20 Serial Number 1445

(5) Shepherd Model 89 Box Calibrator Serial Number 91-1134

(6) Model 3 Frisker Instrument # 238945

(7) GEM-5 Monitor 1803-091

(8) ARGOS Monitor ID 1712-184

(9) PCM-2 ID 457

(10) SAM12 Serial Number 202

(11) RADECO Model HD-29A Air Sampler UTC No 17379

(12) Protean Model WPC-1050 Serial Number 11171115

(13) FASTSCAN Whole Body Counter Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Unit 1, Liquid Radwaste Discharge Monitor, RIA-1049

(2) Unit 1, High Range Noble Gas Effluent Monitor, RIA-2327

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Radioactive Material Storage (IP Section 03.01)

(1) Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials.

(2) Inspectors evaluated the licensees performance in accounting and verification that sealed sources have been verified to be intact.

Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)

(1) Inspectors walked down accessible portions of the solid radioactive waste systems on 590' auxiliary building and evaluated system configuration and functionality.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) October 1, 2020 - September 30, 2021

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) October 1, 2020 - September 30, 2021 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) October 2020 - September 2021

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 2020 - September 2021 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) October 2020 - September 2021

71152 - Problem Identification and Resolution (PI&R)

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in equipment reliability that might be indicative of a more significant safety issue during the period of July 1, 2021, to December 31, 2021.

Annual Follow-Up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Causal evaluation for 2B condensate pump oil cooler water intrusion and subsequent reactor power reduction as documented in CR-PLP-2021-01984 on November 29, 2021.

(2) 1-2 EDG cylinder 7L crack and subsequent online maintenance and liner replacement causal evaluation as documented in CR-PLP-2021-02180 on December 16,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===71003 - Post-Approval Site Inspection for License Renewal The team conducted a partial Phase IV license renewal inspection (Section 02.02.d).

Specifically, with a focus on verifying the management of aging effects in accordance with the aging management program(s).

Post-Approval Site Inspection for License Renewal ===

(1) The following aging management program was evaluated by the team:

Open Cycle Cooling Water Program

INSPECTION RESULTS

Enforcement Enforcement Action EA-21-159: Failure to Comply with 10 CFR 71124.08 Discretion Part 37

Description:

On August 2, 2016, the licensee was issued NRC Inspection Report No. 05000255/2016407, which documented a licensee identified violation of 10 CFR Part 37, Physical Protection of Category 1 and Category 2, Quantities of Radioactive Material at Facilities with a 10 CFR Part 73, Physical Protection Program. The violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52."

Subsequently, the inspectors re-evaluated this activity and found that while a violation of regulatory requirements continues to exist, the conditions remain within the criteria for enforcement discretion established within EGM 14-001.

Corrective Actions: As specified in EGM 14-001, the application of discretion is authorized until the underlying technical issue is dispositioned through rulemaking or other regulatory action. Additional corrective actions are not required.

Corrective Action References: Not Applicable.

Enforcement:

Violation: On August 2, 2016, a violation of 10 CFR Part 37 was documented in Palisades Inspection Report No.05000255/2016407. The inspectors determined that the previously identified violation remains.

Basis for Discretion: This violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52."

Failure to Follow Preventative Maintenance Change Request Process Results in a Failure of Condensate Pump (P-2B) Oil Cooler and Subsequent Rapid Downpower Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [P.5] - 71152 FIN 05000255/2021004-01 Operating Open/Closed Experience A finding of green significance was self-revealed on July 28, 2021, for the licensee's failure to follow their preventative maintenance change request (PMCR) process. Specifically, a preventative maintenance activity scope was changed without processing a PMCR, resulting in a failure to perform the preventative maintenance on the condensate pump (P-2B) oil cooler. As a result, a pin hole leak developed in the P-2B oil cooler leading to an oil/water mixture discharging from the P-2B motor's upper bearing housing sight glass vent, and the subsequent need to perform a rapid downpower of the reactor to secure P-2B.

Description:

On July 28, 2021, the control room received an unexpected alarm, EK-0162 (Condensate Pump P-2B High Temp or Overload), with the unit at full power. The licensee locally inspected condensate pump P-2B and found an oil/water mixture discharging from the motor's upper bearing housing sight glass vent. Shortly after discovering the oil/water mixture condition, the site entered Abnormal Operating Procedure (AOP) 7, "Rapid Downpower." The operators reduced power to approximately 25 percent and then secured pump P-2B. The licensee performed work order (WO) 565778. During the work, the licensee confirmed that the upper bearing oil cooler had developed a service water leak at one of the brass fittings used to connect to the service water inlet/outlet piping. The licensee cleaned and dried the upper bearing housing, then flushed the housing and bearing and installed a new bearing oil cooler. Pump P-2B was returned to service on July 29, 2021.

The licensee performed an apparent cause analysis (ACA). The ACA determined that sand entrained in the service water eroded the copper/brass cooler at a bend in the brass inlet/outlet connection, causing a pinhole leak at the brass fitting of the upper bearing oil cooler. The ACA identified that a preventative maintenance (PM) activity existed to replace the oil cooler periodically. In the ACA, the licensee noted their staff had deferred the PM activity several times, and the replacement did not occur as scheduled during the Fall 2018 refueling outage, 1R26. Instead, the PM activity was re-planned to use the 1R26 motor refurbishment work order to complete the oil cooler replacement. The licensee determined that their staff did not revise the 1R26 motor refurbishment work order to include oil cooler replacement. The ACA also noted incorrect interpretation of EN-WM-102, "Work Implementation and Closeout," and EN-DC-324, "Preventative Maintenance Program" by licensee staff. The wrong interpretation of EN-DC-324 resulted in the licensee staff changing the scope of the oil cooler replacement PM from replacement to cleaning and testing, which resulted in the oil cooler not being replaced. On the contrary, when the scope was changed, the licensee staff should have processed a PMCR per step 5.5.3 of EN-DC-324. The site also noted in the ACA that a previous leak in the P-2B motor upper oil cooler occurred on July 22, 2004, and also required a rapid downpower to remove the P-2B condensate pump.

The inspectors evaluated the licensee's emergent work, rapid downpower, post-maintenance testing, and ACA associated with this event. The inspectors determined the licensee failed to follow the PMCR process when changing the PMs scope, which resulted in the site failing to perform preventative maintenance.

Corrective Actions: The site wrote a condition report (CR) and performed an ACA. The licensee replaced the P-2B motor's upper bearing oil cooler. The site also added pre-outage refresher training to reinforce expectations. The site revised PMIDs and associated work orders to include a statement that the bearing oil cooler replacement is not to be delayed beyond the established PM due date. In addition, the licensee reinforced with staff that they cannot make changes to a work order without work order feedback or an approved PMCR.

Corrective Action References: CR-PLP-2021-1984

Performance Assessment:

Performance Deficiency: The licensee failed to follow fleet procedure EN-DC-324, "Preventative Maintenance Program," step 5.5.3. Specifically, the licensee changed the scope of the associated P-2B condensate pump oil cooler PM and failed to process a PMCR.

This led to the licensee crediting cleaning and testing by the motor vendor versus periodic replacement of the oil cooler, resulting in the P-2B oil cooler failing and the site performing a rapid downpower.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee changed the scope of the planned PM on the condensate pump P-2B oil cooler without processing a PMCR due to incorrect interpretation of EN-DC-324. The oil cooler eventually failed due to a pinhole leak from entrained sand, and the licensee had to perform a rapid downpower in order to take the P-2B condensate pump out of service.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the finding against the Initiating Events screening questions in Exhibit 1 and answered "No" to the Transient Initiators question. This resulted in the finding screening to green.

Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. Specifically, the licensee had previous operating experience with the same event happening in 2004. This operating experience, at the site, was not captured in the preventative maintenance activity to provide background as to why the PM activity existed.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Observation: 1-2 EDG Cylinder 7L Crack Evaluation 71152 The inspectors reviewed the associated causal evaluation, "Why Staircase" analysis, equipment failure evaluation, the extent of condition, subsequent vendor analysis, and corrective actions taken for a crack in the liner of cylinder 7L on EDG 1-2 that the licensee discovered during a monthly surveillance test. Specifically, licensee personnel identified exhaust coming out of the associated crack on August 16, 2021, rendering the 1-2 EDG inoperable. After declaring the diesel generator inoperable, the licensee proceeded with a visual inspection of all cylinders on both diesel generators and subsequent liner replacement and verified that no additional cracks or exhaust leaks were present. In parallel, the inspectors performed an extent of condition walkdown of both EDGs, discussed the condition with operations, monitored liner replacement activities, and reviewed subsequent post-maintenance testing. The inspectors noted that the direct cause of the cylinder 7L liner crack was due to low-cycle fatigue. Specifically, the low-cycle fatigue resulted from preloading stress, thermal cycling, and non-uniform seating surface conditions going back to the original liner installation in 1996. The inspectors noted that both licensee and vendor review concluded the standards for seating surface conditions had been met at the time of original liner installation. Therefore, the inspectors determined that the identified crack was not within the licensees ability to foresee or prevent before identification during planned monthly testing on August 16, 2021. For corrective actions, the licensee successfully replaced the 7L liner and initiated measures to develop and implement a preventative maintenance strategy to ensure adequate seating surface conditions to lower fatigue stresses. The inspectors identified no issues of significance.

Observation: Semiannual Trend Review 71152 The inspectors' review focused on equipment reliability and considered the results of daily inspector Corrective Action Program (CAP) item screening and licensee trending efforts. The inspectors' review nominally considered the six months of July 2021 through December 2021, although some examples expanded beyond those dates when warranted by the trend's scope.

The inspectors reviewed condition reports, trend reports, and engineering calculations addressing human performance and equipment reliability at the site. During the inspection period, the NRC inspectors noted a few challenges to equipment reliability. Specifically, the inspectors observed and reviewed the steam dump control relay exceeding the vendor recommended service life, overheating, and rendering the atmospheric dump valves inoperable. The inspectors also observed and reviewed activities associated with other potential challenges to equipment reliability such as the station batteries having multiple cells with cracks, elevated control rod drive (CRD) temperatures, continued "B" primary coolant pump (PCP) seal degradation, and oil cooler replacement for the 2B condensate pump.

The inspectors noted that the licensee identified and monitored the station batteries cell cracks, including developing an adverse condition monitoring plan (ACMP) and performing more frequent inspections of the battery rooms. Also, the inspectors noted that the licensee monitored the increase in CRD 23 elevated temperatures, performed a weekly trend analysis of the seal pressures, and implemented ACMPs for the CRD temperature and for the PCP seal degradation. Regarding the oil cooler replacement, the licensee identified an unexpected alarm, recognized the potential cause, performed a rapid downpower to replace the oil cooler and reduce the potential for a transient to the plant, and completed an ACA to determine the cause of the oil cooler failure. Although these issues illustrated a challenge to equipment reliability, the inspectors reviewed the identified causes and did not identify an adverse trend during this assessment period.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 19, 2022, the inspectors presented the integrated inspection results to Mr. D. Corbin, Vice President, Operations, and other members of the licensee staff.

On December 8, 2021, the inspectors presented the radiation protection inspection results to Mr. D. Nestle, Radiation Protection Manager, and other members of the licensee staff.

On December 8, 2021, the inspectors presented the emergency plan and emergency action level changes review inspection results to Mr. D. Malone, Emergency Planning Manager, and other members of the licensee staff.

On December 14, 2021, the inspectors presented the triennial heat sink and license renewal phase 4 inspection results to Mr. D. Corbin, Vice President, Operations, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71003 Corrective Action CR-PLP-2020- Framatone Indication Notification, Change in Material 09/11/2020

Documents 03380 Condition Reactor Head - Aging Example

CR-PLP-2020- QI-5 Found Terminal Block Link #2 in Poor Condition - Aging 12/03/2020

04799 Example

CR-PLP-2021- PIC-1656 Failure - Aging Example 03/17/2021

00733

Corrective Action CR-PLP-2021- SEP-RLP-PLP-001 Requirements are Difficult to Implement 12/10/2021

Documents 03130

Resulting from

Inspection

Miscellaneous LR-AM R-OCC Open Cycle Cooling Water System 3

LR-AMPBD-19- Open Cycle Cooling Water Program 2

OCCW

NDE Reports WDLC200316029 Coupon Analysis Report 03/25/2020

Procedures SEP-AMP-PLP- Palisades Aging Management Program Assessment for 4

2 Failed or Degraded Equipment Program Section

71111.01 Corrective Action CR-PLP-2021- NRC Identified: V-21F (Intake Structure Fresh Air Fan) is 12/15/2021

Documents 03171 Missing a Fastener on the Bottom Right Corner of the

Resulting from Ventilator as Viewed from the Outside

Inspection

Procedures AOP-38 Acts of Nature 20

EN-CY-122 Diesel Fuel Oil Program 004

SOP-23, Cold Weather Checklist 67

SOP-23, Cold Weather Checklist - Electrical 67

71111.04 Miscellaneous DBD-2.03 Design Basis Document for Containment Spray System 10

Procedures SOP-12, Auxiliary Feedwater System Checklist (Except K-8 Steam 88

14 Supply)

SOP-3, Engineered Safeguards Administrative Control Verification 18

18

71111.05 Fire Plans Pre-Fire Plan 1 Control Room, Elevation 625', Room 325 and Various 6

Inspection Type Designation Description or Title Revision or

Procedure Date

Rooms

Pre-Fire Plan 13G Spent Fuel Pool Heat Exchanger Room, Elevation 590', 6

Rooms 113, 113A, 114, & 115

Pre-Fire Plan 15 Auxiliary Building, Rooms 2, 16, and 121, Elevation 570' to 6

664'

Pre-Fire Plan 21 Electrical Equipment Room, Elevation 607'-6"; Room 725 6

Pre-Fire Plan 22 Turbine Lube Oil Room, Elevation 590', Room 132 6

Pre-Fire Plan 29, Mechanical Equipment Rooms, Elevation 629'-2" & 639', 6

30, & 31 Various Rooms

Pre-Fire Plan 33 Technical Support Center, Elevation 625', Room 320A 6

Pre-Fire Plan 59 Auxiliary Feedwater Pump P-8D Room, Elevation 590' 6

Pre-Fire Plans 6 Diesel Generator 1-2 and Fuel Oil Day Tank Room, 6

&8 Elevation 590', Rooms 116B & 147

71111.06 Corrective Action CR-PLP-2021- Steam Leak in the 1-2 Diesel Generator Room on 11/09/2021

Documents 02879 Condensate Return Line in the Overhead

Resulting from

Inspection

Engineering 13055 EA-C-PAL-95-1526-01: Internal Flooding Evaluation for 4

Changes Plant Areas Outside Containment

29653 EA-C-PAL-95-1526-01: Internal Flooding Evaluation for 4

Plant Areas Outside Containment

43483 EA-C-PAL-95-1526-01: Internal Flooding Evaluation for 4

Plant Areas Outside Containment

43604 EA-C-PAL-95-1526-01: Internal Flooding Evaluation for 4

Plant Areas Outside Containment

43605 EA-C-PAL-95-1526-01: Internal Flooding Evaluation for 4

Plant Areas Outside Containment

64658 EA-C-PAL-95-1526-01: Internal Flooding Evaluation for 4

Plant Areas Outside Containment

Miscellaneous DBD-7.08 Design Basis Document for Plant Protection Against 6

Flooding

Procedures AOP-39 Internal Plant Flooding 2

71111.07T Calculations 022-M-001 Control Room Required Cooling Load 1

RT-202 Basis Palisades Nuclear Plant Technical Specification Surveillance 4/30/2009

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedure Basis Document for RT-202: Control Room

HVAC Heat Removal Capability

Corrective Action CR-PLP-2015- UHS Triennial Inspection (2015) Minor Violation 11/19/2015

Documents 05765

Miscellaneous Appendix C, Heat Exchanger Data Sheet 06/01/1983

Specification

2447/054-M-

91(Q)

B, MR Design Specification for Water-Cooled Condensers 5

2447/054-M-

91(Q)

DBD-1.06 Design Basis Document for Control Room HVAC System 9

Fall 2020 Fall Cleaning Intake Structure Inspection: 11/12/2020

Spec M-91 Technical Specification for Condensing Units 7

Spring 2021 Spring Cleaning Intake Structure Inspection 2021 04/28/2021

SW Bay Fall 2015 Palisades Inspection Report for all Activities August 2015 11/30/2015

through November 2015 UCC Project Number -

2-07-203.81

SW Bay Fall 2018 2018 Mixing Basin 2018 Service Water Bay UCC Project 11/17/2018

Number 02-07-203.101

Vendor Manual Operation, Maintenance, and Service Manual for 10

M0091-SH-0093 Condensing Units VC-10 & VC-11

Procedures DWO-1 Operator's Daily/Weekly Items Modes 1, 2, 3, and 4 112

EN-DC-184 NRC Generic Letter 89-13 Service Water Program 6

RO-216 Service Water Flow Verification 24

SEP-SW-PLP- Raw Water Corrosion Program 2

001

SOP 15 Service Water System 72

SOP-24 Ventilation and Air Conditioning System 84

Work Orders 00393862 P-7A Preservice Test (Vibration Data) 09/12/2020

00397938 01 BS-1319; Bolt That Holds Swing Washer is Broken Off - 04/14/2016

MDM

00443415 01 F-2A; Remove Cover & Inspect Basket Strainer 10/23/2019

51629058 Diver Inspection/Cleaning of Intake Bay (Fall) 12/10/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

2774007 Divers to Clean/Inspect Service Water Pump Bay 11/15/2018

2788631 VC-10 Condenser Overhaul PM 04/17/2019

2803545 VC-11, Condenser Overhaul PM 05/09/2019

2834811 RT-202B, VC-10 CR HVAC "B" Train Heat Removal 08/28/2019

Capability

2836067 RT-202A, VC-11 CR HVAC "A" Train Heat Removal 01/30/2020

Capability

2871596 P-7B & P-7C Vibration Data RO-144 09/14/2020

2876336 Diver Inspection/Cleaning of Intake Bay (Spring) 05/04/2020

2896339 RT-202A, VC-11 CR HVAC "A" Train Heat Removal 08/06/2020

Capability

2898372 RT-202B, VC-10 CR HVAC "B" Train Heat Removal 07/29/2020

Capability

71111.11Q Miscellaneous PLSEG-LOR- Emergency Planning Static 1

21E-02

PLSEG-LOR- Emergency Operating Procedure 5.0 3

21E-04

Procedures QO-21 Inservice Test Procedure Auxiliary Feedwater Pumps 57

71111.12 Corrective Action CR-PLP-2018- PCP P-50A DC Oil Lift Pump did not Satisfy the Oil Pressure 03/27/2018

Documents 01523 Interlock

CR-PLP-2019- PCS Leak Rates Since Start Up from the Refuel Outage 01/09/2019

00130 Have Been Elevated

CR-PLP-2020- The Lower Stage of the Seal has a Lowering Trend 11/03/2020

04494

CR-PLP-2021- Change to the P-50B, Primary Coolant Pump, Middle and 01/13/2021

00080 Upper Seal Pressures

CR-PLP-2021- NI-6-RM10, Remote Power and VHPT Setpoint Meters, has 10/09/2021

2596 Lower than Expected Indication

CR-PLP-2021- Primary Coolant Pumps 10/11/2021

2605

CR-PLP-2021- Received EK-0926 Primary Coolant Pump P-50B Oil Level 10/14/2021

2642 Hi-Lo Unexpectedly

CR-PLP-2021- PY-0102B, B Channel Thermal Margin Monitor 10/14/2021

2644

Inspection Type Designation Description or Title Revision or

Procedure Date

CR-PLP-2021- The Display Screen for the 'B' Thermal Margin Monitor Went 10/17/2021

2662 Black for About 4 Seconds

CR-PLP-2021- "B" TMM Screen Briefly Goes Blank and then Displays 10/18/2021

2671 Normal

Miscellaneous System Health Report PCS - Primary Coolant System 04/01/2019 -

06/30/2019

System Health Report PCS - Primary Coolant System 04/01/2020 -

06/30/2020

System Health Report PCS - Primary Coolant System 04/01/2021 -

06/30/2021

System Health Report PCS - Primary Coolant System 10/01/2019 -

2/31/2019

System Health Report PCS - Primary Coolant System 10/01/2020 -

2/31/2020

System Health Report RPS - Reactor Protection System 04/01/2019 -

06/30/2019

System Health Report RPS - Reactor Protection System 10/01/2019 -

2/31/2019

System Health Report RPS - Reactor Protection System 04/01/2020 -

06/30/2020

System Health Report RPS - Reactor Protection System 10/01/2020 -

2/31/2020

System Health Report RPS - Reactor Protection System 04/01/2021 -

06/30/2021

Maintenance Rule Performance Indicators Reactor 02/08/2021

Protection System

PLP-RPT-12- Maintenance Rule Scoping Document Primary Coolant 4

00025, System

PLP-RPT-12- Maintenance Rule Scoping Document Reactor Protection 4

00026 System

Procedures EN-MA-156 Compression Fitting Installation, Disassembly, Inspection 7

and Reassembly

EN-MA-158 Maintenance Configuration Control 03/26/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

MI-43 Reactor Vessel Level Monitoring System Channel Check 03/26/2020

Work Orders 5277252-01 P-50D Oil Level Transmitters 11/16/2018

28935-04 LT-0146B P/S Replacement 09/12/2020

541946-02 CV-1911; Ops PMT 02/24/2021

71111.13 Procedures EN-MW-104 On-Line Risk Assessment 23

Work Orders 565744-06 P-55A; Repair Sticking Poppet Valves (Contingency) 11/03/2021

568221-01 ASM-2B (K-6B); Replace CK-DE401, CK-DE423, RV-1485, 10/04/2021

RV-1486

568221-06 CK-DE401, Test Removed Check Valve 10/04/2021

568221-07 CK-DE421/CK-DE423 Test Removed Valve 10/04/2021

568221-08 RV-1485 Test Removed Valve 10/04/2021

568221-09 RV-1486 Test Removed Valve 10/04/2021

568221-13 RV-1486, Adjust Fuel Oil Relief Valve 10/04/2021

570079-01 P-55A; Adjust Crosshead Bearings 11/03/2021

571166-01 TS-1471 Replacement 11/30/2021

571166-02 TS-1471 Replacement (Prep Work) 11/29/2021

571166-03 TS-1471 Replacement 12/01/2021

71111.15 Corrective Action CR-PLP-2021- Service Water Leak Between Mechanical NPT Fitting and 09/21/2021

Documents 02433 Outlet of MV-SW602

CR-PLP-2021- CV-1059, Pressurizer Spray Valve from Loop 2A 12/15/2021

03174

Drawings M-201 Piping & Instrument Diagram Primary Coolant System 90

VEN-M-107 Stress Isometric Pressurizer Spray 3

Engineering 91126 Operability Input for Service Water Leak Near Threaded 0

Changes Fitting Downstream of MV-SW602

EC-34881 Pressurizer Spray Valve CV-1057 and CV-1059 Revised 1

Packing Arrangement with Live Load Set

Miscellaneous DBD-2.04 Primary Coolant System 8

DBD-2.11 Pressurizer Pressure Control 4

ODM Packing Leakage on Pressurizer Spray Valve, CV-1059 12/02/2021

Implementation

Plan Template

71111.18 Corrective Action CR-PLP-2021- Inboard Pump Bearing Oil Bubbler for P-52B Component 12/06/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents 03087 Cooling Water Pump Nearly Empty

Corrective Action CR-PLP-2021- Steam Leak in the 1-2 Diesel Generator Room on 11/09/2021

Documents 02879 Condensate Return Line in the Overhead

Resulting from CR-PLP-2021- NRC Resident Found a Puddle of Water Surrounding E-924 12/06/2021

Inspection 03082

Drawings M-208 Piping & Instrument Diagram Non-Critical Service Water 108

System

Miscellaneous Emergent Issue Service Water Supply Line to T-2 Return Line Heat 11/11/2021

Update Template Exchanger

Failure Modes T-2 Return Line Heat Exchanger / EC-90291 09/20/2021

and Effects

Worksheet

Work Orders 563541-26 E-924, Condensate Return Heat Exchanger Bypass Hex 10/15/2021

563541-43 E-924; Install New SWS Tie-In D/S of MV-SW939 11/18/2021

71111.19 Procedures CVCO-4 Periodic Test Procedure - Charging Pumps 12

Work Orders 568221-10 ASM-2B (K-6B); Started Outside of Acceptable Start Time of 10/06/2021

9.5

71111.22 Work Orders 52977575-01 QO-15A-P52A ISI Test Procedure, Component Cooling 09/16/2021

Pump

2978204-01 QO-16C-P54C, ISI Test Containment Spray Pump 09/27/2021

2983287-01 QO-1 Safety Injection Actuation System Test 11/30/2021

71114.04 Procedures EAL Basis Emergency Action Level Technical Bases 8

EN-EP-305 Emergency Planning 10CFR50.54(q) Review Program 8

SEP Palisades Nuclear Plant Site Emergency Plan 32

71124.03 Work Orders 52810325 01 RT-85C SFP Ventilation HEPA & Charcoal Testing 08/21/2019

71124.05 Calibration 2021 Recalibration of The Mirion ABACOS -2000 Fastscan 06/16/2021

Records Counting System at the Entergy - Palisades Power Plant

21-B2.28- Model 3030 Scaler Calibration Serial Number 334592 01/27/2021

CALDAT-00645

21-B2.28- DMC-3000 Calibration Sheet S/N A168801 01/28/2021

CALDAT-00747

21-B2.28- WR Telepole S/N 6605-002 Calibration Data Sheet 02/05/2021

CALDAT-00920

21-B2.28- RO-20 S/N 1445 Calibration Data Sheet 02/10/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

CALDAT-00965

Inst Serial #91- 130 Milli Curie Source Data Sheet 10/08/2020

1134

Inst Serial# 91- 400 Curie Source Data Sheet 10/08/2020

1134

Instrument # Ludlum Model 3 07/28/2021

238945

Monitor 1803-091 GEM-5 Calibration Data Sheet 06/08/2021

Monitor ID 1712- ARGOS Calibration Data Sheet 07/19/2021

184

PCM-2 ID#457 PCM-2 Calibration Data Sheet 01/08/2021

SAM12 Serial SAM12 Calibration Data Sheet 12/25/2020

Number 202

UTC No 17379 RADECO Model HD-29A Certificate of Calibration 02/11/2021

WPC-1050 Serial Protean Model WPC-1050 Calibration Coversheet 05/10/2021

Number

11171115

Procedures EN-RP-313 Operation and Calibration of the ARGOS-5AB Personnel 3

Contamination Monitor

Self-Assessments LO-PLPLO-2021- RP Radiation Monitoring Instrumentation Pre-NRC 08/12/2021

00054 Self-Assessment

Work Orders 52907495 01 RR-9B Radwaste Discharge Monitor RIA-1049 Calibration 05/10/2021

2925326 01 RR-84C - Hi Range Noble Gas Effluent Mon RIA-2327 Cal 09/15/2021

71124.08 Miscellaneous Part 37 Security Plan for the Protection of Category 1 and 2

Category 2 Quantities of Radioactive Material

Training - 10 CFR Part 37 The Physical Protection of 0

Category 1 and Category 2 Quantities of Radioactive

Material

PLLP-RPCT-152- 10CFR37 0

Procedures SIP 39 Protection of Category 1 and Category 2 Quantities of 5

Radioactive Material

Self-Assessments LO-PLPLO-2021- 10CFR Part 37 Transportation, Security Review, and 06/02/2021

00031 Self-Assessment

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders 52867088 01 Perform Annual Rad Source Inventory 01/15/2020

2916544 01 Perform Annual Rad Source Inventory 01/14/2021

2958379 01 Semiannual Sealed Source Leak Test 07/19/2021

71151 Miscellaneous Occupational Exposure Control Effectiveness Performance Various

Indicator Validation Package

Reactor Coolant System Specific Activity Performance Various

Indicator Validation Package

RETS/ODCM Radiological Effluent Occurrence Performance Various

Indicator Validation Package

NRC Performance Indicators Mitigating Systems 10/01/2020 -

Performance Indicator Cooling Water Support 09/30/2021

(MS10 CWS-2)

NRC Performance Indicators Mitigating Systems 10/01/2020 -

Performance Indicator Emergency AC Power (EDG) 09/30/2021

(MS06)

71152 Corrective Action CR-PLP-2021- Received EK-0162, Condensate Pump P-2B High Temp or 07/28/2021

Documents 01984 Overload, Unexpectedly

CR-PLP-2021- Emergency Diesel Generator 1-2 Cylinder Liner 7L Cracked 10/15/2021

2180

Miscellaneous Apparent Cause Analysis Equipment Issues Over the 0

Cycle

Nuclear Independent Oversight Functional Area 3

Performance Report June 2021 - September 2021

Procedures EN-DC-324 Preventative Maintenance Program 22

EN-DC-324 Preventative Maintenance Program 21

EN-DC-324-DP Decommissioning Plant Preventive Maintenance Program 008

EN-WM-102 Work Implementation and Closeout 13

Work Orders 52436159-06 P-2B; Pump Motor (EMA-2205) Removal 10/10/2018

565778-01 EMA-2205/P-2B; Replace Upper Oil Cooler - E-908B 07/28/2021

565778-02 EMA-2205/P-2B; Stancion Installation/Grating Removal 07/28/2021

565778-04 Bench Test New Bearing Oil Cooler Coil 07/28/2021

565778-05 EMA-2205/P-2B; Instrument Interference Removal 07/28/2021

565778-06 EMA-2205/P2B; Drain Cooler Reservoir 07/28/2021

565778-07 EMA-2205/P2B; Ops PMT 08/11/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

565778-08 EMA-2205/P-2B; Instrument Interference Reinstall 07/29/2021

565778-10 EMA-2205/P-2B; Vibration Measurement 07/29/2021

565778-11 EMA-2205 (P-2B) Perform Megger Testing 07/29/2021

24