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05000255/FIN-2015001-0531 March 2015 23:59:59PalisadesNRC identifiedFailure to Evaluate the Adverse Effects of the Use of Non-Seismic Temporary JumpersA Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, and an associated finding of very low safety significance was identified by the inspectors when licensee personnel failed to maintain a written safety evaluation that provided a basis that the use of temporary alligator clip jumpers to maintain emergency diesel generator (EDG) operability during certain maintenance activities did not require a license amendment. Specifically, the licensee did not address the adverse effects of the use of alligator jumpers on the design and qualification of the diesel generator (DG) circuit breaker used per Engineering Change 50310 and changes to procedure SPSE1, 2400 Volt and 4160 Volt Allis Chalmers and Siemens Vacuum Circuit Breaker Auxiliary Switch Adjustments, Revision 34. This issue was entered into the licensees CAP as CRPLP201404859, NRC Identified 50.59 Issue, dated October 7, 2014. The performance deficiency was determined to be more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the change that was implemented adversely affected the seismic qualification of the electrical circuit that was relied upon to ensure safety bus 1C would be loaded by the 11 DG upon a loss of offsite power. The inspectors evaluated the underlying technical issue and determined the finding was of very low safety significance. In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the finding associated with this violation was determined to be of very low safety significance. This finding had a cross-cutting aspect in the Conservative Bias component of the Human Performance cross-cutting area. Specifically, the licensee did not use all available information and relevant guidance, such as Nuclear Energy Institute 9607, to demonstrate that the proposed activity was safe and did not require a license amendment prior to implementation.
05000255/FIN-2014003-0330 June 2014 23:59:59PalisadesNRC identifiedFailure to Notify the NRC Within 30 Days of Discovering Changes in Medical ConditionsA Severity Level IV non-cited violation of 10 CFR 50.74, Notification of Change in Operator or Senior Operator Status, was identified by the inspectors during a review of licensed operator medical records. Specifically, Palisades did not notify the NRC within 30 days of discovering a change in medical condition for a licensed operator. Subsequently, the licensee submitted the required notification for the operator on April 11, 2014, and entered the issue into their CAP as CR-PLP-2014-02518, NRC Informed the Palisades Training Department that an NRC Form 396 was Not Submitted, dated April 10, 2014. The inspectors determined that Traditional Enforcement applied because a failure to make a required report impacted the regulatory process. Specifically, the licensee had not notified the NRC within 30 days of learning of a change in medical condition for a licensed operator for which a license condition was required. Based on Example 6.9.d.1 of the NRCs Enforcement Policy, the inspectors determined that the issue represented a Severity Level IV violation. No associated Reactor Oversight Process finding was identified, thus there was no associated cross-cutting aspect.
05000255/FIN-2012002-0131 March 2012 23:59:59PalisadesNRC identifiedPotential Exam Compromise During Requalification ExamA finding of very low safety significance and associated NCV of 10 CFR 55.49, Integrity of Examination and Tests was identified by the inspectors for failure to ensure there were no activities which compromised exam integrity. Specifically, the licensee failed to properly review Simulator Exam Scenario (SES) 130 and the associated Reactivity Management Briefing Sheet. Had the briefing sheet been provided to the crew being evaluated, without inspector intervention, it would have resulted in an exam compromise. The inspectors identified that a critical task was on the crew briefing sheet prior to its administration, and told the licensee of the condition. The licensee subsequently added a page break to push the critical task from the briefing sheet to the following page. There was no actual exam compromise. The licensee also entered the issue in their Corrective Action Program (CAP) as CR-PLP-2012-1001. A finding of very low safety significance and associated NCV of 10 CFR 55.49, Integrity of Examination and Tests was identified by the inspectors for failure to ensure there were no activities which compromised exam integrity. Specifically, the licensee failed to properly review Simulator Exam Scenario (SES) 130 and the associated Reactivity Management Briefing Sheet. Had the briefing sheet been provided to the crew being evaluated, without inspector intervention, it would have resulted in an exam compromise. The inspectors identified that a critical task was on the crew briefing sheet prior to its administration, and told the licensee of the condition. The licensee subsequently added a page break to push the critical task from the briefing sheet to the following page. There was no actual exam compromise. The licensee also entered the issue in their Corrective Action Program (CAP) as CR-PLP-2012-1001.
05000255/FIN-2012002-0231 March 2012 23:59:59PalisadesNRC identifiedPotential Exam Compromise During Requalification ExamA finding of very low safety significance and associated NCV of 10 CFR 55.49, Integrity of Examination and Tests was identified by the inspectors for failure to ensure there were no activities which compromised exam integrity. Specifically, the licensee failed to properly review Simulator Exam Scenario (SES) 130 and the associated Reactivity Management Briefing Sheet. Had the briefing sheet been provided to the crew being evaluated, without inspector intervention, it would have resulted in an exam compromise. The inspectors identified that a critical task was on the crew briefing sheet prior to its administration, and told the licensee of the condition. The licensee subsequently added a page break to push the critical task from the briefing sheet to the following page. There was no actual exam compromise. The licensee also entered the issue in their Corrective Action Program (CAP) as CR-PLP-2012-1001. A finding of very low safety significance and associated NCV of 10 CFR 55.49, Integrity of Examination and Tests was identified by the inspectors for failure to ensure there were no activities which compromised exam integrity. Specifically, the licensee failed to properly review Simulator Exam Scenario (SES) 130 and the associated Reactivity Management Briefing Sheet. Had the briefing sheet been provided to the crew being evaluated, without inspector intervention, it would have resulted in an exam compromise. The inspectors identified that a critical task was on the crew briefing sheet prior to its administration, and told the licensee of the condition. The licensee subsequently added a page break to push the critical task from the briefing sheet to the following page. There was no actual exam compromise. The licensee also entered the issue in their Corrective Action Program (CAP) as CR-PLP-2012-1001.
05000255/FIN-2012002-0531 March 2012 23:59:59PalisadesLicensee-identifiedLicensee-Identified ViolationThe following violation of Severity Level IV was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. The licensee identified that a licensed operator did not meet vision requirements in accordance with ANSI-3.4-1983, Section 5.4.5. The operator tested 20/50 in the better eye with corrective lenses but was erroneously signed as having met the vision requirements by the site doctor in September 2010. In June 2011 the licensee submitted a license renewal for the operator. The operators license previously had a restriction for the operator to wear prescriptive lenses. However, the licensee, believing that the individual met vision requirements, submitted the renewal to the NRC without conditions. The NRC approved the renewal. In January 2012 the licensee identified the deficient condition. The operators license was placed on hold until the operators vision was retested. The operator, using the same lenses and same testing machine, tested 20/30 in the better eye. This met the ANSI-3.4-1983 vision requirements. 10 CFR 55.57 requires certification by the licensee of medical conditions and general health conducted by a physician, as part of the medical exam for renewal of an individual license. The licensee failed to ensure the operator met the vision requirements for a licensed operator. This is consistent with a Severity Level IV violation in the Enforcement policy (Section 6.4.d.1). The licensee documented this in CR-PLP-2012-00080, coached the doctor on the ANSI requirements and informed the NRC. The inspectors reviewed the licensees corrective actions and determined this to be a NCV in accordance with Section 2.3.2 of the NRC Enforcement Policy. Using IMC 0612, Appendix B, Issue Screening, the inspectors determined this issue to be of very low risk-significance since the operator met the ANSI requirements using the same lenses during a January 2012 retest; and there was no indication of the operator causing vision-induced errors in the control room.
05000255/FIN-2011005-0331 December 2011 23:59:59PalisadesLicensee-identifiedLicensee-Identified ViolationTechnical Specification 5.4.1 requires written procedures be established, implemented, and maintained for procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, of this document recommends procedures for assuring safe operation. The licensee established EN-OP-115, Conduct of Operations, Revision 9, Section 4.1.b, to address the requirement that station management is informed in a timely manner of conditions which may affect safety. Contrary to the above, on October 23, 2010, the on-duty operators did not inform station management in a timely manner when the on-duty ATC-RO left his watch station without permission or conducting a proper turnover. The licensee immediately assigned another on-shift operator to assume the vacant position; however, when the ATC-RO returned to the control room several minutes later, he was allowed to re-assume the watch without an evaluation by the licensee addressing the individuals ability to be fully focused on plant safety and the responsibilities of a licensed operator. Since Operating Department management was not informed in excess of 24 hours later, the individual was allowed to stand an on-shift watch the next night. After management was made aware of the incident, several corrective actions were taken in order to provide assurance of the individuals ability to perform license duties. This was documented in CR PLP-2010-05662 and also evaluated by an ACE CR-PLP-2010-06259. The failure to inform management in a timely manner and ensure corrective actions were implemented was a performance deficiency as defined in IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening. The inspectors determined that the finding was more than minor because if left uncorrected this could have the potential to lead to a more significant safety concern. The inspectors concluded the finding was of very low safety significance because adequate staffing was immediately available and no significant operator errors occurred.
05000255/FIN-2011005-0431 December 2011 23:59:59PalisadesLicensee-identifiedLicensee-Identified ViolationTechnical Specification 5.4.1 requires that written procedures be established, implemented, and maintained for procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Section 9 of Regulatory Guide 1.33 states, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to this, troubleshooting was performed on the #1 battery charger following a DC electrical transient on September 25, 2011, which failed to identify a blown fuse that resulted from the transient. As a result, the charger was declared operable and returned to service when in fact it was still inoperable. Unusual voltage indication identified later by a member of Operations Department prompted further troubleshooting of the charger, which revealed the still-blown fuse. The licensee entered the issue into the corrective action program as CR-PLP-2011-04826 and replaced the blown fuse. The issue was more than minor because it affected the Mitigating System Cornerstone attribute of equipment performance and adversely impacted the objective to ensure the availability of equipment to respond to initiating events. The inspectors concluded the finding was of very low safety significance due to answering no to the phase 1questions in the Mitigating Systems column of Table 4a of IMC 0609 Attachment 4
05000255/FIN-2011014-0131 December 2011 23:59:59PalisadesNRC identifiedFailure to Report a 10 CFR 50.72 Notification for an 8-hour Non-Emergency ReportA Severity Level (SL) IV non-cited violation of 10 CFR 50.72(b)(3)(ii)(B) was identified by the inspectors for the failure to notify the NRC as soon as practical and in all cases within eight hours of the occurrence of any event or condition that results in the nuclear power plant being in an unanalyzed condition that significantly degrades plant safety. Specifically, the licensee failed to report on September 26, 2011, within eight hours an Appendix R noncompliance that was identified in DC shunt trip Breakers 72-01 and 72-02 for the 125-Volt DC system following the reactor trip that occurred on September 25, 2011. The licensees preliminary analysis demonstrated that if a shunt trip breaker automatically opened due to fire induced fault currents, then the licensees Appendix R credited equipment may have been lost unexpectedly, an unanalyzed condition that significantly degrades plant safety. This issue was documented in the licensees corrective action program as CR-PLP-2011-05263 and at the end of the special inspection, the licensee continued to perform a causal evaluation in order to develop corrective actions. As a remedial corrective action, the licensee made the required event notification in Event Notification Number 47322 on October 5, 2011. The inspectors determined that the finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated December 24, 2009, Block 7, Figure 2, because reporting failure violations are considered to be violations that potentially impact the regulatory process and are dispositioned using traditional enforcement. The underlying technical issue was required to be evaluated using the SDP and is assessed separately in Section 4OA5.6.b.1 of this report as a separate Green finding. In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the underlying technical issue was evaluated by the SDP and determined to be of very low safety significance. In addition, NRC Enforcement Policy, dated July 12, 2011, Section 6.9.d.9, states, in part, that an example of an SL IV violation is the licensees failure to make a report required by 10 CFR 50.72. Cross-cutting aspects were evaluated in the underlying ROP finding
05000255/FIN-2010005-0731 December 2010 23:59:59PalisadesNRC identifiedFailure to Provide Complete and Accurate InformationThe inspectors identified a Severity Level IV NCV of 10 CFR 50.9 for the licensees failure to provide information to the NRC that was complete and accurate in all material respects. Specifically, in a letter on dated October 5, 2009, the licensee inaccurately stated new couplings for a service water pump were independently tested prior to installation. The licensee provided this information as part of a request for a Notice of Enforcement Discretion (NOED). The licensee requested the NOED due to a failure of a service water pump coupling that had not been properly heat treated. The licensee subsequently informed the NRC that the tests had not been performed and entered the condition into the corrective action program. The inspectors concluded that the licensee had reasonable opportunity to foresee and correct the inaccurate/incomplete information prior to the information being submitted to the NRC. As a result, this issue was considered a performance deficiency. Using the information provided in IMC 0612, Appendix B, Issue Screening, the inspectors determined that traditional enforcement was warranted, because violations of 10 CFR 50.9 are considered to potentially impede or impact the regulatory process. Specifically, in order to determine the acceptability of granting discretion, the NRC needed assurance that the replacement couplings met hardness requirements. Using the information provided in the Enforcement Policy, Section 6.9, this issue was determined to be a Severity Level (SL) IV NCV, as it did not meet the definition for a Severity Level I, II, or III Violation. Specifically the violation was not greater than SL IV, because the inspectors concluded that the lack of hardness testing did not impact the NRCs conclusion since the licensee did not enter the period of enforcement discretion. The inspectors also evaluated the underlying performance deficiency under the ROP. Since the licensee did not enter the period of enforcement discretion and all the questions for more than minor in Appendix B were answered no, the inspectors concluded that there was no ROP finding and therefore no cross-cutting aspect. (Section 4OA5.5)
05000255/FIN-2010004-0330 September 2010 23:59:59PalisadesNRC identifiedFailure to Make 8 hour Report Pursuant to 10 CFR 50.72The inspectors identified an NCV for failure to make an 8 hour report as required by 10 CFR 50.72. On August 23, the licensee lost the trip function associated with the Loss of Turbine Load but did not recognize that this condition was a loss of a safety function and reportable within 8 hours as required by 10 CFR 50.72. After discussions with the residents, the licensee reported the condition pursuant to 10 CFR 50.72. The licensee entered this condition into the CAP as CR-PLP-2010-3752. The inspectors concluded that the issue was more than minor because the failure to make the required report impacted the regulatory process. The finding affected the Mitigating System Cornerstone because the intent of the reporting is to capture events where there would have been failure of a safety system to properly operate. The Finding was processed through the traditional enforcement process. The inspectors concluded that the finding was of SL IV because failure to make a required 10 CFR 50.72 report is an example of a SL IV violation in the Enforcement Policy. The underlying cause of this issue is the same as the Green NCV listed in 1R15 so no additional cross-cutting aspect was assigned.
05000255/FIN-2009007-0130 September 2009 23:59:59PalisadesNRC identifiedViolation of Title 10 CFR 50.9 Completeness and Accuracy of Information Regarding in Support of 10 CFR 20.2106 Records of Individual Monitoring ResultsThe inspectors identified a Severity Level IV NCV of 10 CFR 50.9, Completeness and Accuracy of Information. The inspectors identified that the licensee, on April 17, 2008, submitted to the NRC inadequate NRC Form 5s, Occupational Dose Record for a Monitoring Period for three individuals that were involved in the demobilization of spent fuel reconstitution equipment in October 2007. The NRC Form 5s were not complete and accurate in all material respects. Specifically, the NRC Form 5s did not include pertinent information relative to the radiological implications to these individuals regarding their personal involvement in the demobilization of spent fuel reconstitution equipment under circumstances when the licensees ability to assess the workers dose was compromised. In particular, the NRC Form 5s failed to document the uncertainties associated with the workers radiation doses, as was necessary in this instance consistent with the instructions on the Form 5. When the NRC questioned the licensee on the accuracy of these NRC Form 5 submittals, the licensee submitted revised NRC Form 5s. The violation was more than minor because the missing information was material to the NRC. Specifically, this information is used by the NRC in its evaluation of the risk of radiation exposure associated with the licensed activity and in exercising its statutory authority to monitor and regulate the safety and health practices of its licensees. This Severity Level IV violation is of very low safety-significance because if the information had been complete and accurate when reviewed by the NRC, it likely would not have resulted in a reconsideration of a regulatory position or substantial further inquiry, such as an additional inspection or a formal request for information. Because this violation was of very low safety-significance, neither was it repetitive nor willful, and was entered into the licensees corrective action program (Condition Report (CR)-PLP-2009-04213), the violation is being treated as an NCV, consistent with the NRC Enforcement Policy. No cross-cutting aspects were identified with this violation
05000255/FIN-2007007-0431 December 2007 23:59:59PalisadesNRC identifiedFailure to Perform a 10 CFR 50.59 Evaluation for a Revised Dose CalculationSeverity level (SL) IV. The inspectors identified a SL IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments for the licensees failure to perform a written evaluation prior to implementing a calculation change based on raising the acceptance criteria for back leakage from valves which leak containment activity. Specifically, the change of back leakage affected the post accident dose impact to control room operators and this was not evaluated in accordance with 10 CFR 50.59. The licensee entered the item into their corrective action program. After removing margin from other components, the licensee determined the change to acceptance criteria could be implemented without prior NRC approval. The inspectors concluded this finding was more than minor since it impacted the NRCs ability to perform its regulatory function and if left uncorrected would have raised the dose to control room operators above the level requiring NRC approval. The inspectors concluded the original calculation would have required prior NRC approval. The issue screened as SL IV since the inspectors brought the issue to the attention of the licensee before plant start-up, so there was no actual impact with the plant at power. In addition, the issue was not repetitive or willful. Therefore, it was of very low safety significance. (Section 1R22)
05000255/FIN-2007006-0330 September 2007 23:59:59PalisadesNRC identifiedFailure to Perform a 10 CFR 50.59 Evaluation for a Temporary Modification for Augmented Cooling of SWThe inspectors identified a severity level (SL) IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments for the licensees failure to perform a written evaluation prior to implementing a temporary modification to compensate for the absence of containment air cooler VHX-4. Specifically the modification adversely impacted the service water (SW) system and this was not evaluated in accordance with 10 CFR 50.59. The licensee entered the item into their corrective action process, added structural elements to minimize fouling of the service water system, evaluated the change in accordance with 10 CFR 50.59, and performed a written evaluation. The revised modification did not require prior NRC approval. The inspectors concluded this finding was more than minor since it impacted the NRCs ability to perform its regulatory function and resulted in a condition which reduced the reliability of the SW system, a mitigating system. The inspectors concluded the original modification may have required prior NRC approval. The issue screened green in the phase 3 assessment for the equipment degradation and therefore was of very low safety significance, and therefore, SLIV. The finding has a cross-cutting aspect in the area of human performance in that the licensee failed to use conservative assumptions in decision making and failed to identify possible unintended consequences when implementing the augmented cooling for service water modificatio
05000255/FIN-2007002-0531 March 2007 23:59:59PalisadesNRC identifiedFailure to Comply with TS 5.5.12 TS Basis Control ProgramSeverity Level IV. The inspectors identified a Severity Level IV NCV of TS 5.5.12 for the failure to comply with the TS Basis Control Program. Specifically, the licensee made a change to the TS bases for TS 3.9.5 which altered the TS definition of \\\"two SDC trains\\\" described in TS 3.9.5. The licensee changed the bases to allow a single SDC to be a member of two trains with cavity level less than 647 feet. A distinct SDCHX is required for each train. This change required prior NRC approval as a change to the TS. This issue was entered into the licensees corrective action system. The inspectors concluded this finding is more than minor since it impacted the NRCs ability to perform its regulatory function and resulted in a condition having a very low safety significance (i.e., green). Specifically, the licensee changed the TS bases in a manner that required prior NRC approval. The finding is a Severity Level IV violation consistent with the NRC Enforcement Policy. The inspectors also determined that this finding has a cross-cutting aspect in the area of human performance, because the licensee failed to use conservative assumptions in changing the TS bases. (IMC 0305 H.1(b)) (Section 4OA5.2)
05000255/FIN-2007002-0731 March 2007 23:59:59PalisadesNRC identifiedAddition of Manual Operator Action Not Evaluated in Accordance with 10 CFR 50.59Severity Level IV. The inspectors identified a finding having very low safety significance and an associated NCV of 10 CFR 50.59, \\\"Changes, Tests, and Experiments,\\\" for a failure to seek a license amendment. Specifically, when Setpoint Change 96-012 involving the low suction pressure trip of the auxiliary feedwater pumps was implemented, no safety evaluation was performed. When the evaluation was performed in December 2006 the licensee failed to evaluate known deficiencies. Because violations of 10 CFR 50.59 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the significance determination process. The performance deficiency met Supplement I.D.5, \\\"Violations of 10 CFR 50.59 that result in conditions evaluated as having very low safety significance by the SDP,\\\" for a Severity Level IV Violation. (Section 4OA5.4)
05000255/FIN-2006009-0131 December 2006 23:59:59PalisadesNRC identifiedStartup Transformer not Evaluated for Past Operability and ReportabilityThe inspectors identified a finding of very low safety significance and an associated Severity Level IV NCV of 10 CFR 50.73 (a)(2). Specifically, the licensee failed to analyze past operability and submit a licensee event report when the startup transformer 1-2 tap changer control was found to be non-operational. Once analyzed, the licensee determined that one of the two required circuits from the offsite power supply was inoperable on at least three non-consecutive occasions between May 17 and May 22, 2006. The primary cause of this violation was related to the cross-cutting area of problem identification and resolution. Because violations of 10 CFR 50.73 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the significance determination process (SDP). The performance deficiency met Supplement I.D.4, Failure to Make a Required Licensee Event Report for a Severity Level IV violation. (Section 1R21.3.b.1)
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