IR 05000255/2017001
| ML17122A229 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/02/2017 |
| From: | Eric Duncan Region 3 Branch 3 |
| To: | Arnone C Entergy Nuclear Operations |
| References | |
| EA-17-029 IR 2017001 | |
| Preceding documents: |
|
| Download: ML17122A229 (43) | |
Text
May 2, 2017
SUBJECT:
PALISADES NUCLEAR PLANT-NRC INTEGRATED INSPECTION REPORT 05000255/2017001 AND NOTICE OF ENFORCEMENT DISCRETION
Dear Mr. Arnone:
On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. On April 27, 2017, the NRC inspectors discussed the results of this inspection with yourself and other members of your staff. The enclosed report represents the results of this inspection.
Based on the results of this inspection, no findings of significance were identified. A licensee-identified violation is listed in Section 4OA7 of this report. 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 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."
Sincerely,
/RA/
Eric Duncan, Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20
Enclosure:
Inspection Report 05000255/2017001
REGION III Docket No: 50-255 License No: DPR-20 Report No: 05000255/2017001 Licensee: Entergy Nuclear Operations, Inc. Facility: Palisades Nuclear Plant Location: Covert, MI Dates: January 1 through March 31, 2017 Inspectors: A. Nguyen, Senior Resident Inspector J. Boettcher, Resident Inspector J. Mancuso, Acting Resident Inspector B. Bartlett, Project Engineer T. Taylor, Resident Inspector, D. C. Cook Nuclear Plant A. Shaikh, Senior Reactor Inspector
D. Sargis, Reactor Engineer
Approved by: E. Duncan, Chief Branch 3 Division of Reactor Projects
SUMMARY
Inspection Report (IR) 05000255/2017001; 01/01/2017 - 03/31/2017; Palisades Nuclear Plant; Routine Integrated Inspection Report This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors.
The Nuclear Regulatory Commission's (NRC's) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Proc ess," Revision 6, dated July 2016. No violations of significance were identified by the inspectors. A violation of very low safety or security significance or Severity Level IV that was identified by the licensee has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensee's corre ctive action program (CAP). This violation and CAP tracking number is listed in Section 4OA7 of this report.
3
REPORT DETAILS
Summary of Plant Status The plant operated at or near full power during the inspection period until March 17, 2017, when the unit was taken offline for a forced outage to replace a leaking seal on control rod drive (CRD) mechanism 13. On March 23, 2017, the reactor was taken critical and the plant was synchronized to the grid. The reactor achieved approximately 70 percent power on March 27, 2017, where it remained for the remainder of the inspection period, in preparation for the upcoming refueling outage, 1R25.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Impending Adverse Weather Condition - High Wind Conditions
a. Inspection Scope
Since high winds were forecast in the vicinity of the facility for March 8, 2017, the inspectors reviewed the licensee's overall preparations/protection for the expected weather conditions. On March 8, 2017, the inspectors walked down the emergency diesel generators (DGs), service water sy stem (SWS), and auxiliary feedwater (AFW) system, in addition to the licensee's emergency alternating current (AC) power systems, because their safety-related functions could be affected or required as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors compared the licensee staff's preparation actions to the site's procedures. During the inspection, the inspectors focused on plant-specific design features and the licensee's procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. The inspectors also reviewed a sample of corrective action program (CAP) items to verify that the licensee identified adverse weather issues at an appropriate threshold and dispositioned them through the CAP in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment to this report. This inspection constituted one readiness for impending adverse weather condition sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.2 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- Right train control room heating, ventilation, and air conditioning system (CRHVAC);
- 1-1 emergency DG;
- 'B' and 'C' charging system trains; and
- 'B' and 'C' containment spray trains. The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization.
Documents reviewed are listed in the Attachment to this report. These activities constituted four partial system walkdown samples as defined in IP 71111.04-05.
b. Findings
No findings were identified.
.3 Semi-Annual Complete System Walkdown
a. Inspection Scope
During walkdowns on January 26, February 2, and February 13, 2017, the inspectors performed a complete system alignment inspection of the AFW system to verify the functional capability of the system. This system was selected because it was considered both safety-significant and risk-significant in the licensee's probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment lineups; electrical power availability; system pressure and temperature indications, as appropriate; component labeling; component lubrication; component and equipment cooling; hangers and supports; operability of support systems; and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of 5 a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the Attachment to this report. These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on the availability, accessibility, and condition of firefighting equipment in the following risk-significant plant areas:
- Fire Area 13B: charging pump rooms, elevation 590';
- Fire Area 10: east engineered safeguards room, elevation 570';
- Fire Area 23: turbine building north, elevation 590';
- Fire Area 2: cable spreading room, elevation 607';
- Fire Area 13G: spent fuel pool heat exchanger room, elevation 590';
- Fire Area 23: turbine building east and west mezzanines, elevations 607' to 612';
and
- Fire Area 23: turbine building south, elevations 584' and 590'. The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's CAP. Documents reviewed are listed in the Attachment to this report. These activities constituted seven quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R06 Flooding
.1 Internal Flooding
a. Inspection Scope
The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. The specific documents reviewed are listed in the to this report. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensee's corrective action documents with respect to past flood-related items identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant area to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:
- AFW pump room, turbine building, and elevation 570'. Documents reviewed during this inspection are listed in the Attachment to this report. This inspection constituted one internal flooding sample as defined in IP 71111.06-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On March 1 and March 15, 2017, the inspectors observed two crews of licensed operators in the plant's simulator during the Annual Licensed Operator Requalification Operating Test. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:
- licensed operator performance;
- crew's clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms; 7
- correct use and implementation of abnormal, alarm response, and emergency operating procedures;
- timely control board operation and manipulations;
- oversight and direction from supervisors;
- group dynamics involved in crew performance; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications. The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11-05 and satisfied the inspection program requirement for the resident inspectors to observe a portion of an in-progress annual requalification operating test during a training cycle in which it was not observed by the NRC during the biennial portion of this IP.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation during Periods of Heightened Activity or Risk
(71111.11Q)
a. Inspection Scope
On March 17, 2017, the inspectors observed reactor cooldown and shutdown activities in the main control room in preparation for the forced outage to replace the seal on CRD-13. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:
- licensed operator performance;
- crew's clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of procedures;
- control board and equipment manipulations; and
- oversight and direction from supervisors. The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.
b. Findings
No findings were identified.
.3 Resident Inspector Quarterly Observation during Periods of Heightened Activity or Risk
(71111.11Q)
a. Inspection Scope
On March 22 and 23, 2017, the inspectors observed reactor startup activities after the forced outage to replace the seal on CRD-13. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:
- licensed operator performance;
- crew's clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of procedures;
- control board and equipment manipulations; and
- oversight and direction from supervisors. The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- instrument air system;
- primary coolant system; and
- control room envelope boundary. The inspectors reviewed events including those in which ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance; 9
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1). The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. This inspection constituted three quarterly maintenance effectiveness samples as defined in IP 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed
prior to removing equipment for work:
- planned risk-significant maintenance on the 1-2 DG;
- emergent, elevated risk work on LS-1452, 1-2 DG control level switch, for failure to stop filling the 1-2 DG day tank;
- planned risk-significant work on the 'B' AFW pump coincident with troubleshooting activities to locate a ground on the 2400V alternating current (AC) system;
- emergent, elevated risk work on the 1-2 DG for failure to synchronize to its 2400V AC bus during surveillance testing coincident with CV-0554, reheater drain tank control valve, sticking in mid-position;
- emergent, risk significant work on the containment personnel air lock and CV-0601, feedwater heater level control valve;
- emergent, elevated risk work on reactor protection system matrix relay AD3 after it was found degraded during surveillance testing; and
- entry into TS Limiting Condition for Operation (LCO) 3.0.4.b and associated risk assessment for emergent work on CV-0823, 'A' component cooling water (CCW) heat exchanger service water outlet valve. These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the 10 plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Documents reviewed during this inspection are listed in the Attachment to this report. These maintenance risk assessments and emergent work control activities constituted seven samples as defined in IP 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functional Assessments
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- evaluation of the failure of CV-0822, service water temperature control valve, regulator;
- evaluation of leakage past CK-ES3132, 'C' safety injection tank check valve;
- past operability evaluations of issues identified during 1-2 DG maintenance window;
- evaluation of foreign material in the 1-1 DG jacket water cooler;
- evaluation of 1-2 DG after inconclusive troubleshooting for failure to synchronize; and
- evaluation of CV-0823, 'A' CCW heat exchanger service water outlet valve, open limit switch found unresponsive. The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and the UFSAR to the licensee's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sample of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the Attachment to this report. This operability inspection constituted six samples as defined in IP 71111.15-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional
capability:
- operability testing of P-66B, 'B' high pressure safety injection pump, after oil change;
- 1-2 DG test start and operability testing after jacket water cooler heat exchanger replacement and preventive maintenance (PM) window;
- 1-1 DG test start and operability testing following jacket water cooler heat exchanger replacement;
- 1-2 DG test start and operability run after troubleshooting failure to synchronize; and
- control rod exercising of CRD-13 following seal replacement. These activities were selected based upon the SSC's ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test
documentation was properly evaluated. The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report. This inspection constituted seven post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R20 Outage Activities
.1 Other Outage Activities
a. Inspection Scope
On March 17, 2017, the licensee removed the unit from service for an unplanned maintenance outage to replace the seal on CRD-13 and complete additional maintenance activities. The unit was restarted and synchronized to the electrical grid on March 23, 2017.
The inspectors evaluated the licensee's conduct of outage activities to assess the control of plant configuration and management of shutdown risk. The inspectors reviewed activities to ensure that the licensee considered risk in developing, planning, and implementing the outage schedule. The inspectors observed or reviewed the reactor shutdown and cooldown, outage equipment configuration and risk management, electrical lineups, selected clearances, control and monitoring of decay heat removal, control of containment activities, personnel fatigue management, startup and heat-up activities, and identification and resolution of problems associated with the outage.
In addition, the inspectors verified problems associated with the conduct of outage activities were entered into the licensee's CAP with the appropriate characterization and significance. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one other outage sample as defined in IP 71111.20-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- QO-14B, 'B' service water pump surveillance test (inservice test);
- QI-4, pressurizer low pressure surveillance test (routine);
- QO-1, safety injection actuation test (routine); and
- QI-5, containment high pressure surveillance test (routine). The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur; 13
- were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- were acceptance criteria clearly stated, demonstrate operational readiness, and consistent with the system design basis;
- was plant equipment calibration correct, accurate, and properly documented;
- were as-left setpoints within required ranges; and was the calibration frequency in accordance with TSs, the UFSAR, procedures, and applicable commitments;
- was measuring and test equipment calibration current;
- was test equipment within the required range and accuracy; were applicable prerequisites described in the test procedures satisfied;
- did test frequencies meet TS requirements to demonstrate operability and reliability; were tests performed in accordance with the test procedures and other applicable procedures; were jumpers and lifted leads controlled and restored
where used;
- were test data and results accurate, complete, within limits, and valid;
- was test equipment removed after testing;
- where applicable for inservice testing activities, was testing performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and were reference values consistent with the system design basis;
- where applicable, were test results not meeting acceptance criteria addressed with an adequate operability evaluation or was the system or component declared inoperable;
- where applicable for safety-related instrument control surveillance tests, were reference setting data accurately incorporated into the test procedure;
- where applicable, were actual conditions encountering high resistance electrical contacts such that the intended safety function could still be accomplished;
- had prior procedure changes not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- was equipment returned to a position or status required to support the performance of its safety functions; and
- were all problems identified during the testing appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report. This inspection constituted three routine surveillance testing samples and one in-service test sample as defined in IP 71111.22, Sections-02 and-05.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors evaluated the conduct of a routine licensee emergency drill on February 8, 2017, to identify any weaknesses or deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the control room simulator, 14 technical support center, and operations support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report. This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-06.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Unplanned Scrams per 7000 Critical Hours
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Scrams per 7000 Critical Hours performance indicator (PI) for the period from the first quarter 2016 through the fourth quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensee's operator narrative logs, condition reports (CRs), event reports , NRC inspection reports (IRs), and reported NRC data from the first quarter 2016 through the fourth quarter 2016 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's condition report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator. Documents reviewed are listed in the Attachment to this
report. This inspection constituted one unplanned scrams per 7000 critical hours sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Unplanned Scrams with Complications
a. Inspection Scope
The inspectors sampled licensee submittals for the Unplanned Scrams with Complications PI for the period from the first quarter 2016 through the fourth quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensee's operator narrative logs, CRs, event reports, NRC IRs, and reported NRC data from the first quarter 2016 through the fourth quarter 2016 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's condition report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator. Documents reviewed are listed in the to this report. This inspection constituted one unplanned scrams with complications sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Mitigating Systems Performance Index-Heat Removal System
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI)-Heat Removal System PI for the period from the first quarter 2016 through the fourth quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensee's operator narrative logs, CRs, event reports, MSPI derivation reports, NRC IRs, and reported NRC data from the first quarter 2016 through the fourth quarter 2016 to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, whether the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's condition report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator. Documents reviewed are listed in the Attachment to this report. This inspection constituted one MSPI heat removal system sample as defined in IP 71151-05.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensee's corrective action program at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed. Some minor issues were entered into the licensee's corrective action program as a result of the inspectors' observations; however, they are not discussed in this report. These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter.
b. Findings
No findings were identified.
.2 Annual Follow-Up of Selected Issues:
Corrective Actions for Hourly Fire Tour Discrepancies
a. Inspection Scope
The inspectors selected the following condition report for an in-depth review:
- CR-PLP-2016-2650, Discrepancies Identified During Hourly Fire Tours. As appropriate, the inspectors verified the following attributes during their review of the licensee's corrective actions for the above condition report and other related condition reports:
- complete and accurate identification of the problem in a timely manner commensurate with its safety significance and ease of discovery;
- consideration of the extent of condition, generic implications, common cause, and previous occurrences;
- evaluation and disposition of operability/functionality/reportability issues;
- classification and prioritization of the resolution of the problem commensurate with safety significance;
- identification of the root and contributing causes of the problem; and
- identification of corrective actions, which were appropriately focused to correct the problem;
- completion of corrective actions in a timely manner commensurate with the safety significance of the issue;
- effectiveness of corrective actions taken to preclude repetition; and
- evaluate applicability for operating experience and communicate applicable lessons learned to appropriate organizations.
17 The inspectors discussed the corrective actions and associated evaluations with licensee personnel. This review constituted one in-depth problem identification and resolution inspection sample as defined in IP 71152. b. Observations During this quarterly inspection period, the inspectors completed an interim review of the licensee's corrective actions associated with the root cause evaluation performed under CR-PLP-2016-02650, Discrepancies Identified during Hourly Fire Tours. This review focused on the licensee's identification of the root and contributing causes to the event and the corrective actions established to address those causes. Specifically, the corrective actions were reviewed to ensure they were appropriate to preclude repetition for the root causes and correct the identified deficiencies of the contributing causes; were being implemented in a timely manner commensurate with safety significance; and were effective in addressing the identified causes. The inspectors also reviewed the extent of condition and extent of cause aspects of the issue, and corrective actions that were implemented to address those aspects. The licensee determined that the root causes of the issues associated with the conduct of fire tours were: 1) standards for implementation of the fire tours had not been sufficiently developed, which allowed programmatic, training, and organizational gaps to go unnoticed and uncorrected; and 2) other patrols unrelated to fire tours were co-mingled with the fire tours, which resulted in missed checks (a root cause identified during the extent of condition review). Through the review of the root cause evaluation, the inspectors did not identify any gaps in the evaluation process to determine the root causes.
Corrective actions to prevent recurrence for these root causes included revising fleet and station procedures to specifically outline the standards and responsibilities for the conduct of fire tours. Additional corrective actions for the root causes included creating and requiring computer-based and in-person training to the pertinent departments on the standards and responsibilities outlined in the revised procedures and creating checklists that were required to be used in the conduct of the tours. Interim corrective actions added a requirement for security shift leaders to validate the proper conduct of tours by printing out badge reports and confirming that the badge reports matched the completed check lists, ensuring oversight of the patrols/tours as they were being conducted. The inspectors independently reviewed the licensee's revised procedures, new training, and documentation of completed fire tours to determine if the corrective actions were appropriately addressing the identified causes and that the patrols/tours were being conducted as required. The inspectors shared minor observations with the licensee related to these reviews. The licensee also documented in their CAP a few instances where human performance issues led to minor gaps in the conduct of the tours. The licensee planned to incorporate this information into future effectiveness reviews. The licensee also determined that there were two contributing causes for the discrepant fire tours. The first contributing cause identified that security management did not provide sufficient oversight for the conduct of fire tours, which led to the propagation of incorrect behaviors. The second contributing cause determined that the Palisades staff did not appropriately evaluate operating experience from a similar issue at another plant identified in 2014, which would have enabled them to identify vulnerabilities within their 18 own program. The inspectors did not find any gaps in the licensee's root cause evaluation process for identifying these contributing causes and agreed that there was a missed opportunity for the station to have identified issues within their fire tour program sooner through a more thorough review of the related operating experience in 2014. The licensee was aware of and did review the operating experience when the issue first occurred; however, the review was not sufficiently in-depth or probing in nature to identify discrepancies at Palisades.
Corrective actions for these contributing causes included creating behavioral observation check sheets for supervisors to use while performing in-field observations of the tours, requiring supervisors to complete a specified number of observations over a six month period, and briefing security management on the lessons learned from the ineffective operating experience review. The inspectors performed an independent review of the completed behavioral observation check sheets to ensure supervisors were performing oversight responsibilities as required and that the observations yielded a critical review of personnel performance to identify incorrect behaviors and address them appropriately. While the observations were being conducted as required, the inspectors noted a lack of critical feedback related to the conduct of the tours. This was discussed with the licensee as a potential weakness in the process which could aid in identifying behavioral issues before more significant, programmatic issues arose.
At the end of this inspection period, effectiveness reviews had not yet been completed to ensure that the corrective actions for the root causes and contributing causes adequately addressed the identified gaps discussed above. The inspectors planned to review these effectiveness review results after they were completed. The licensee continued to have some interim corrective actions in place, as well as corrective actions that had yet to be implemented. The inspectors planned to continue their review of the implementation and effectiveness of these actions in the future.
c. Findings
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 (Closed) Licensee Event Report 05000255/2010003-00; Unanalyzed Condition Due to Non-Compliance with 10 CFR 50 Appendix R On October 1, 2010, during a corrective action program extent of condition review,
a postulated Appendix R fire scenario was identified in three fire areas that could potentially result in the loss of safety-related 2400 volt alternating current (VAC) bus 1C and/or 1D, with subsequent loss of equipment credited for Appendix R compliance to support safe shutdown in the event of such a fire. 10 CFR 50, Appendix R, Section III.G.2 requires, in part, that where cables or equipment of redundant trains of
systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one means of ensuring that one of the redundant trains is free of fire damage shall be provided. At the time that the licensee identified this non-compliance in 2010, Palisades was required to meet the requirements of 10 CFR 50, Appendix R.
The licensee documented the non-compliant manual actions in their CAP and implemented fire watches as a compensatory measure. Enforcement aspects of this 19 Licensee Event Report are discussed in Section 4OA7. Documents reviewed as part of this inspection are listed in the Attachment. This Licensee Event Report is closed.
This event follow-up review constituted one sample as defined in Inspection Procedure 71153-05.
4OA5 Other Activities
.1 Institute of Nuclear Power Operations Plant Assessment Report Review
a. Inspection Scope
The inspectors reviewed the final report for the World Association of Nuclear Operators Peer Review conducted in July 2016. The inspectors reviewed the report to ensure that issues identified were consistent with the NRC perspectives of licensee performance and to determine if any significant safety issues were identified that required further NRC follow-up.
b. Findings
No findings were identified.
.2 (Closed) NRC Temporary Instruction 2515/192, Inspection of the Licensee's Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems
a. Inspection Scope
The objective of this performance-based Temporary Instruction (TI) was to verify implementation of interim compensatory measures associated with an open phase condition (OPC) design vulnerability in electric power systems for operating reactors.
The inspection determined whether the licensee had implemented the following interim compensatory measures. These compensatory measures were to remain in place until permanent automatic detection and protection schemes were installed and declared operable for the OPC design vulnerability. The inspectors verified the following:
- The licensee identified and discussed with plant staff the lessons learned from the OPC events at the US operating plants including the Byron Station OPC event and its consequences. This included conducting operator training for promptly diagnosing, recognizing consequences, and responding to an OPC event.
- The licensee updated plant operating procedures to help operators promptly diagnose and respond to OPC events on offsite power sources credited for safe shutdown of the plant.
- The licensee established and implemented periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power circuits to detect a visible OPC.
- The licensee ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained. As part of the maintenance 20 and testing activities, the licensee assessed and managed plant risk in accordance with 10 CFR 50.65(a)(4) requirements.
b. Findings and Observations
The inspectors reviewed the interim corrective actions that the licensee had implemented since the Byron Station OPC event, as described in a letter to the NRC dated January 30, 2014, and verified those actions remained in place. In general, the inspectors determined that the corrective actions described in the letter were being appropriately implemented. The inspectors noted one observation during the review of the corrective actions. In the letter, the licensee stated that bus transfer procedures were verified to ensure voltages were checked prior to bus transfers and after transfers were completed. The inspectors reviewed these procedures and observed that while the procedures required a check of bus voltages, they did not require a check of voltages across all phases. The inspectors discussed this observation with the licensee. The licensee entered this observation into their CAP and planned to evaluate the current procedures for bus transfers. No findings of significance were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary On April 27, 2017, the inspectors presented the inspection results to Mr. C. Arnone, 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.
4OA7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements.
This issue met the criteria of the NRC Enforcement Policy for being dispositioned as a Non-Cited Violation (NCV) and an issue warranting enforcement discretion (EA-17-029), respectively. The licensee identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR 50, Appendix R, Section III.G.2, which requires, in part, that where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one means of ensuring that one of the redundant trains is free of fire damage shall be provided. Contrary to the above, as of October 1, 2010, the licensee failed to ensure that one of the redundant trains was free of fire damage in areas where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment. Specifically, the licensee failed to analyze a fire scenario in the 1-C switchgear room, screen-house room, and component cooling water pump room that could potentially damage the control cable before the load cable, and therefore result in the loss of safety-related 2400 volt alternating current (VAC) bus 1C and/or 1D, with subsequent loss of equipment credited for Appendix R compliance to support safe shutdown in the event of such a fire. The licensee's failure to analyze an Appendix R fire scenario for the three fire areas described above was a performance deficiency.
21 The performance deficiency was more-than-minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding was determined to be of very low safety significance (Green) because it did not impact the licensee's ability to reach hot shutdown because operator manual actions would have allowed operators to shut down the plant following a fire.
The licensee identified this issue during the transition to NFPA 805, entered the issue into their CAP as CR-PLP-2010-04255, and implemented compensatory measures, including fire watches. The violation was not willful and routine licensee efforts, such as normal surveillance or quality assurance acti vities, were not likely to have previously identified the violation due to the specific sequence of fire cable damage required for such an Appendix R fire scenario. As a result, the inspectors concluded that the violation met all four criteria for exercising enforcement discretion established by Section 9.1 of the NRC's Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues; therefore, the NRC is exercising enf orcement discretion to not cite this violation.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- C. Arnone, Site Vice President
- D. Corbin, General Manager Plant Operations
- T. Mulford, Operations Manager
- B. Baker, Operations Manager - Shift
- J. Borah, Engineering Manager, Systems and Components
- D. Lucy, Production Manager
- T. Davis, Regulatory Assurance
- B. Dotson, Regulatory Assurance
- J. Erickson, Regulatory Assurance
- O. Gustafson, Director of Regulatory and Performance Improvement
- J. Hardy, Regulatory Assurance Manager
- J. Haumersen, Site Projects and Maintenance Services Manager
- G. Heisterman, Maintenance Manager
- M. Lee, Operations Manager - Support
- N. DeMaster, Outage Manager
- D. Malone, Emergency Planning Manager
- W. Nelson, Training Manager
- D. Nestle, Radiation Protection Manager
- K. O'Connor, Engineering Manager, Design and Programs
- C. Plachta, Nuclear Independent Oversight Manager
- P. Russell, Site Engineering Director
- M. Schultheis, Performance Improvement Manager
- M. Soja, Chemistry Manager
- J. Tharp, Security Manager
- U.S. Nuclear Regulatory Commission E. Duncan, Chief, Reactor Projects Branch 3
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
- 05000255/2010003-00 LER Unanalyzed Condition Due to Non-Compliance with 10 CFR 50 Appendix R (4OA3.1)
LIST OF DOCUMENTS REVIEWED
The following is a partial list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspector reviewed the documents in their entirety, but rather that