IR 05000255/2012007

IR 05000255-12-007; on 1/30/2012 - 2/17/2012; Palisades Nuclear Plant, Routine Biennial Problem Identification and Resolution Inspection

ML12080A057
Person / Time
Site:	Palisades
Issue date:	03/16/2012
From:	John Giessner Reactor Projects Region 3 Branch 4
To:	Vitale A Entergy Nuclear Operations
References
IR-12-007
Download: ML12080A057 (23)

Text

March 16, 2012

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

SUBJECT: PALISADES NUCLEAR PLANT - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000255/2012007

Dear Mr. Vitale:

On February 17, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Palisades Nuclear Plant. The enclosed inspection report documents the inspection results which were discussed on February 17, 2012, with you and other members of your staff. This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commission's rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Palisades was adequate. Licensee-identified problems were entered into the corrective action program at a low threshold. Problems were generally prioritized and evaluated commensurate with the safety significance of the problems; however, there were examples where issues were not pursued with the appropriate rigor when they were initially identified which resulted in violations. Corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from industry operating experience were generally reviewed and applied when appropriate. Audits and self-assessments were generally used to identify problems and appropriate actions. Based on the results of this inspection, no findings were identified. However, If you disagree with a characterization of an issue 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 Regional Administrator, Region III; and the NRC Resident Inspector at the Palisades Nuclear Plant. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ John B. Giessner, Branch Chief Branch 4 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 05000255/2012007

w/Attachment:

Supplemental Information cc w/encl: Distribution via ListServ Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-255 License No: DPR-20 Report No: 05000255/2012007 Licensee: Entergy Nuclear Operations, Inc. Facility: Palisades Nuclear Plant Location: Covert, MI Dates: January 30 through February 17, 2012 Inspectors: R. Lerch, Project Engineer, DRP G. O'Dwyer, Reactor Inspector, DRS T. Taylor, Resident Inspector, Palisades S. Sheldon, Senior Reactor Inspector, DRS Approved by: John B. Giessner, Chief Branch 4 Division of Reactor Projects Enclosure TABLE OF CONTENTS 4. OTHER ACTIVITIES .................................................................................................... 2 4OA2 Problem Identification and Resolution (71152B) ............................................... 2 4OA6 Management Meetings ..................................................................................... 8 SUPPLEMENTAL INFORMATION ............................................................................................. 1 KEY POINTS OF CONTACT .................................................................................................. 1 LIST OF ITEMS OPENED, CLOSED AND DISCUSSED ........................................................ 2 LIST OF DOCUMENTS REVIEWED ...................................................................................... 3 1 Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000255/2012007; 1/30/2012 - 2/17/2012; Palisades Nuclear Plant, Routine Biennial Problem Identification and Resolution Inspection.

This inspection was performed by three NRC regional inspectors and one resident inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006. On the basis of the sample selected for review, the team concluded that implementation of the Corrective Action Program (CAP) at Palisades was adequate, but only marginally effective. The inspectors did note an overall decline in performance since the last inspection. The licensee had a low threshold for identifying problems and entering them in the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria and were properly evaluated commensurate with their safety significance. In general, causes for issues were adequately determined and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. However, frequent NRC input or self-revealing events identified issues that the plant staff failed to adequately address. In one case, a significant condition adverse to quality was not adequately addressed and this resulted in recurrence of a failure of a safety-related service water pump. Another self-revealed finding related to the failure to run on an auxiliary feedwater pump, of low to moderate safety significance, was not adequately addressed initially. NRC comments, and later review by the licensee, led to the development of a root cause analysis which revealed other significant shortfalls in the maintenance of the turbine-driven auxiliary feedwater pump. This was a finding of low to moderate safety significance. The team noted that the licensee effectively reviewed operating experience for applicability to station activities. Audits and self assessments were determined to be effectively performed at an appropriate level to identify deficiencies. Based on the surveys conducted by the licensee, interviews conducted during the inspection, and review of the employee concerns program, employee freedom to raise nuclear safety concerns without fear of reprisal was evident. Problem Identification and Resolution A. No items of significance were identified.

NRC-Identified

and Self-Revealed Findings B. No violations of significance were identified.

Licensee-Identified Violations

4. OTHER ACTIVITIES

REPORT DETAILS

4OA2 Problem Identification and ResolutionThe activities documented in Sections

===.1 through

=

.1 a. Assessment of the Corrective Action Program Effectiveness The inspectors reviewed the licensee's Corrective Action Program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel. Inspection Scope The inspectors reviewed risk and safety significant issues in the licensee's CAP after January 1, 2010, which was since the last Nuclear Regulatory Commission (NRC) PI&R inspection in January 2010.

The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed condition reports (CR) generated as a result of facility personnel's performance in daily plant activities. In addition, the inspectors reviewed CRs and a selection of completed investigations from the licensee's various investigation methods, which included root cause, apparent cause, and common cause investigations. The inspectors extended the review of the turbine-driven auxiliary feedwater pump back 5 years with an emphasis on issues associated with the pump room and environmental conditions. The inspectors also performed a partial system walkdowns. During the reviews, the inspectors determined whether the licensee staff's actions were in compliance with the facility's CAP and 10 CFR Part 50, Appendix B, requirements. Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the station's CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions (preventing recurrence if required by Appendix B) for selected issue reports, completed investigations, and NRC findings, including Non-Cited Violations (NCVs).

b. (1) Assessment Based on the information reviewed including generation rates and interviews, the inspectors concluded that, in general, problem identification was adequate and at an Effectiveness of Problem Identification 3 Enclosure appropriate threshold. During the assessment period, the station initiated seven to eight thousand CRs per year. The CR generation numbers appeared representative of a good problem identification ethic. The sample of issues reviewed by inspectors that were entered into the CAP indicated there was a low threshold and a steady generation of CRs.

This was consistent with the last biennial PI&R inspection. Other safety conscious work environment (SCWE) indicators such as surveys and interviews indicated willingness to identify issues and capture them in the CAP.

A negative aspect to problem identification observed by inspectors was that too often there were issues that the plant staff had identified where the significance or extent of the issue went unrecognized until the NRC, the Quality Assurance organization (QA), or a self-revealing event escalated its importance. This was an observation in the last biennial PI&R inspection as well; however, the number and significance of issues identified with this weakness had increased since the last inspection. An example of an issue with inadequate recognition/identification included lubrication of the turbine driven auxiliary feedwater (AFW) pump trip linkage which caused an unexpected AFW pump trip (a White violation, 255/2011013-01) for which NRC comments prompted more in-depth analysis which later revealed additional issues regarding maintenance of the pump. Other examples were water leakage into the double wall of the emergency diesel generator fuel oil storage tank that was not recognized as a potential age management degradation issue (a Green NCV 255/2011008-003); a visual examination of the reactor vessel head that lacked evaluation of corrosion identified by an NRC inspector (a Green NCV 255/2011-013-01); and the enclosure for the F and G bus breakers that was not maintained weatherproof and moisture intrusion caused a ground fault (An emergency classification of an Unusual Event and a Green finding 255/2011002-03). Prior to the fault occurring, a preventive maintenance task for caulking the enclosure (established in response to a similar, previous issue) was cancelled in 2002. Observations No findings were identified. Findings (2) The team found there was adequate consideration of operability and reportability requirements. However, in some instances, NRC involvement was required to ensure appropriate regulatory compliance. One example was an incorrect Technical Specifications action statement entry for loss of a reactor protection system function (Green NCV 255/2010004-02). Another example was the restoration of the direct current (DC) busses to operable status following a transient on the DC system that was the subject of a yellow finding (255/2011014-02). The NRC identified additional issues with that operability evaluation that should have been considered and were later added.

Effectiveness of Prioritization and Evaluation of Issues For the sample reviewed by inspectors, CRs were generally appropriately prioritized during initiation and screening by the Condition Review Group in accordance with the procedural guidelines. The team reviewed prioritization of issues as reflected in assigned due dates and concluded there was appropriate consideration of risk in prioritizing and evaluating issues and assignments appeared consistent with procedural requirements. Although the majority of CRs were adequately evaluated and resolved, 4 Enclosure examples of CRs that had evaluations that lacked rigor were also present. A negative aspect of licensee performance with issue evaluations was that, similar to the last biennial PI&R, too many issue evaluations lacked sufficient rigor to define the issues thoroughly and resolve them. These resulted in repeat findings and in one case a recurrence of a significant condition adverse to quality.

The NRC inspection findings during the assessment period indicated NRC involvement and self-revealing events prompted more thorough licensee evaluations for issues. For example, deficiencies with control of the Offsite Dose Calculation Manual were identified with regard to the scope of sampling for radiological liquid effluents offsite (a Green NCV, 255/2010002-03). Over a year after a finding was issued by the NRC for this issue, the licensee still had not instituted the required sampling and another finding was issued (a Green NCV 255/2011003-08 with subsequent verification that the condition was then actually corrected). Other examples of inadequate rigor in evaluating issues included questions on the employment of a backup radiation monitor and the analysis of potential spills of radioactive liquids to the environment. Questions raised by the NRC regarding the employment of a single backup radiation monitor for two process streams were not pursued in-depth until a NRC walkdown revealed design issues with the backup monitor. This issue resulted in a Green Finding (255/2011003-02). For potential spills, the NRC raised questions regarding a particular tank and whether or not a postulated rupture was bounded by existing accident analyses. Months later, the NRC discovered some administrative changes had been made to licensing basis documents, but the core question of whether the tank satisfied regulatory requirements had not been answered. The NRC issued a Green finding and corrective action was taken (255/2011002-04). Weaknesses were also identified with the evaluation issues that became safety-significant findings. The failure of the 7C service water pump coupling was a self-revealing repeat event after a previous evaluation failed to look at broader failure mechanisms (a White violation, 255/2011016-01). Additionally, the initial apparent cause evaluation and failure analysis associated with the unexpected trip of the turbine-driven auxiliary feedwater pump lacked rigor (White violation, 255/2011013-01). Comments from the NRC and further review by the licensee led to a root cause evaluation and more in-depth engineering analysis. The evaluation revealed additional issues with regards to post-maintenance testing and incorporation of operating experience that had not been explored in the initial apparent cause. Finally, during the inspection, the inspectors questioned the evaluation of CR-PLP-2011-4872 for a differential temperature between the pressurizer vapor space and the cold leg which exceeded 200 degrees F. The evaluation relied on a 350 degree differential temperature limit for abnormal conditions, but upon questioning, the justification for the 350 degrees could not be produced. The plant design basis allows for numerous temperature cycles over 200 degrees, so there was no immediate concern that the applicable thermal cycle limit was exceeded. The tracking methodology for thermal cycles will be reviewed in a future inspection. Overall in this area, the inspectors concluded the licensee was marginally effective. The licensee had increased the use of the "learning organization (LO)" option of the computer tracking system to provide task reminders and to track actions for improvements or fixes for conditions that are not conditions adverse to quality (CAQ). The level of review and accountability is based on user discretion. For issues Observations 5 Enclosure determined to be important, such as the actions for the Performance Recovery Program, due dates were assigned and extension approvals were required. Inspectors did not identify any CAQs in the system, however the QA department had issued a repetitive finding for CR corrective actions closed to the LO system. Inspectors noted that the system, also, had a potential to develop a backlog. No findings were identified. Findings (3) The overall effectiveness of corrective actions was adequate. The team found, in general, that the licensee could develop and implement corrective actions and use risk insights in prioritizing corrective actions, but was impacted by the weaknesses observed with lack of rigor in identifying problems and evaluating issues. CRs routinely assigned effective corrective actions commensurate with their risk significance. As a result of an appropriately low identification threshold, most CRs have low significance. However, repeat issues such as the service water (SW) pump coupling failure, and issues re-identified by the QA department indicated that the licensee had not been effective at resolving all issues, including some that were significant. In the case of the SW pump, a significant condition adverse to quality was not adequately addressed and this resulted in recurrence of a failure of a safety related service water pump; a finding of low to moderate safety significance (White violation, 255/2011016-01).

Effectiveness of Corrective Actions During review of a thermal cyclic fatigue monitoring issue, the inspectors were informed that the licensee had not approved the "FatiguePro" software and the associated "Create CDT" software for use at Palisades even though the computer programs have been in use since 2007. The FatiquePro program also had a Software Change Request (SCR-2010-131) that had not yet been incorporated. The licensee was tracking the software change by LO-WTPLP-2011-120 CA-1; however the LO-WT tracking system was not used for conditions adverse to quality and therefore, this action had not yet been accomplished. A CR, PLP-2009-0518, had also previously been written to document a needed software change, but had been closed before the change was completed. The licensee initiated CR-PLP-2012-01045 in response to the inspectors' concerns to address these untimely actions. The plant appeared to be meeting its design basis at the time of this inspection, but inspectors had questions about the adequacy of the program for assuring tracking of thermal cycles. The program will be reviewed in a future inspection. Observations No findings were identified. Findings

.2 a. Assessment of the Use of Operating Experience The inspectors reviewed the licensee's implementation of the facility's Operating

Experience (OE) program. Specifically, the inspectors reviewed implementing OE Inspection Scope 6 Enclosure program procedures and completed evaluations of OE issues and events, interviewed individuals with respect to the use of OE, attended an OE screening, and reviewed a self-assessment of the OE program. The inspectors' review was to determine whether the licensee was effectively integrating OE into the performance of daily activities, whether evaluations of issues were proper, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of the OE, were identified and effectively implemented in a timely manner. b. The inspectors noted that screening of OE was performed frequently via teleconferencing between the site, fleet, and company headquarters. The inspectors believed, in general, that OE was adequately reviewed at the site. The inspectors noted that root cause reports and apparent cause evaluations included discussions of OE. Notwithstanding the appearance of a healthy OE program, there were several previous findings that noted deficiencies incorporating OE. In these cases, use of operating experience may have prevented follow-on events. This indicated that some effort is necessary to institutionalize OE. In the case of the White finding for the SW coupling failure due to corrosion cracking, a significant contributor to the failure was the site's poor use of OE in evaluating the material and the environment it is used in. The operating experience for 416/410 stainless steel started in the 1980's, and OE was available up through 2010 from a similar failure at another plant (discussed in IR 2011016). The material of the coupling was changed to 416 stainless steel from carbon steel in 2007. The site did not adequately assess the OE which specifically stated 416 SS could be susceptible to cracking, and did not initiate any review as would have been appropriate (and discussed in the OE) to look at the fracture toughness of the metal to ensure the material was suitable for use. In addition, following the first coupling failure in 2009, the site did not re-evaluate the OE that existed, and had become available, showing additional issues with cooling water systems connected to lake or river water supplies. Finally, the licensee failed to recognize the need to evaluate age-related degradation in emergency diesel generator governors, although recent governor issues existed and should have prompted a more thorough review of operating experience. The NRC identified components that would go beyond useful life based on this OE. This resulted in a Green finding and required the site to take prompt action to address and correct the issue (255/2011002-01). Assessment c. No findings were identified. Findings

.3 a. Assessment of Self-Assessments and Audits The inspectors assessed the licensee staff's ability to identify and enter issues into the CA program, prioritize and evaluate issues, and implement effective corrective actions through efforts from departmental self-assessments and from audits performed by the QA organization.

Inspectors reviewed a sample of self-assessments by various Inspection Scope 7 Enclosure departments, QA audits, schedules of past and future assessments, and held discussions with program managers. b. Based on the sample of audits and assessments reviewed, the inspectors concluded that self-assessments and audits were typically thorough and effective at identifying issues and enhancement opportunities at an appropriate threshold level. However, since QA continued to have repeat issues, the inspectors concluded there was limited effectiveness in evaluating and correcting the QA-identified issues. Assessment A substantial self-assessment program was scheduled and tracked across station organizations and issues were captured and resolved in the CA program. Feedback from the Entergy fleet indicated to Palisades that they performed more self-assessments than other plants. The plant staff was therefore reducing the overall plan for self-assessments, using an organized approach to identify assessments to be eliminated. The inspectors reviewed the self-assessment performed on the CAP and found no issues with the overall results and conclusions drawn, although inspectors noted that the assessment failed to recognize that QA audit findings were being repeatedly identified, and failed to appropriately attribute several issues to identification by the NRC. In the case of Quality Assurance audits, there were numerous instances where the issues raised were repeat issues from previous audits. Some examples included control of non-conforming material, measuring and test equipment traceability issues, and observations that engineering-related corrective actions were being closed to processes outside of the corrective action program. This indicated a lack of effectiveness by the licensee and QA at resolving those issues. The QA organization was aware of this record and indicated they planned to escalate and pursue the resolution of issues more strongly. c. No findings were identified. Findings

.4 a. Assessment of Safety Conscious Work Environment The inspectors assessed the licensee's SCWE through the review of the employee concerns program (ECP) implementing procedures, discussions with the manager of the employee concerns program, interviews with personnel from various departments, and reviews of issue reports.

The review was done to ensure there was a free flow of information and determine if there was a reluctance to raise nuclear safety concerns. An independent review of safety culture by an Entergy-contracted group was underway at the time of the inspection in response to recent events at the site.

Inspection Scope b. The ECP was accessible to employees and dealing with employee issues. The site was performing periodic surveys in different organizations using anonymous computer questions to gauge staff attitudes. Managers took actions to address results that indicated a potential for improvement. Based on inspector observations of the CA process and discussions with approximately 30 plant staff members, the indications Assessment 8 Enclosure were that plant staff felt free to raise issues either with their supervisor, through the CAP, or through the Employee Concerns Program without fear of retaliation. c. No findings were identified. Findings

4OA6

.1 Management Meetings On February 17, 2012, the inspectors presented the inspection results to Mr. T. Vitale, Site Vice President, and other members of the licensee staff.

The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. Exit Meeting Summary On March 24, 2012, the inspectors spoke by phone with T. Davis of Palisades to convey that an unresolved item would not be carried regarding thermal cyclic fatique monitoring. This issue has been assigned to the license renewal inspection for review. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Tony Vitale Licensee Entergy/Site Vice President David Hamilton Entergy/General Mgr Plant Operations Charlie Arnone Entergy/Nuclear Safety Assurance Dir Alan Blind Entergy/Engineering Director Chuck Sherman Entergy/RP Manager John Dills Entergy/Operations Manager Bart Nixon Entergy/Training Manager Chris Plachta Entergy/QA Manager Jody Haumersen Entergy/System Engg Manager Jim Miksa Entergy/Programs Engg Manager Mike Mlynarek Entergy/Chemistry Manager Tom Reddy Entergy/MP&C Manager Ernie Chatfield Entergy/ECP Manager Bret Baker Entergy/Assistant Maintenance Mgr Bob Bees Entergy/IT Manager Dave Berkenpas Entergy/Security Manager Bob VanWagner Entergy/DFS Project Manager Neil Lane Entergy/Manager of Projects Dan Malone Entergy/EP Manager Mike Sicard Entergy/Recovery Plan Manager Otto Gustafson Entergy/Licensing Manager Tim O'Leary Entergy/Acting CA&A Manager Dale Lucy Entergy/Maintenance Superintendent Roger Smith Entergy/Maintenance Superintendent Doug Watkins Entergy/RP Superintendent Ryan Prescott Entergy/Sr. CA&A Specialist

Attachment James Dalrymple Entergy/CA&A Specialist III Barb Dotson Entergy/Licensing Specialist IV Kami Miller Entergy/CA&A Specialist II

G. Shear, Deputy Director, DRP Region III Nuclear Regulatory Commission

J. Giessner, Chief, Branch 4, DRP Region III

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

None

Attachment

LIST OF DOCUMENTS REVIEWED

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

Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report. PLANT PROCEDURES Number Description or Title Date or Revision

EN-EC-100 Guidelines for Implementation of the Employee Concerns Rev 5

EN-LI-102 Corrective Action Process Rev 17

EN-LI-102-02 CR Closure Quality Rev 3

EN-LI-104 Self-Assessments and Benchmark Process Rev 5

EN-LI-118 Root Cause Analysis Process Rev 16

EN-LI-119 Apparent Cause Evaluation Process Rev 14

EN-OE-100 Operating Experience Process Rev 13

EN-QV-136 Nuclear Safety Culture Monitoring Rev

0

EN-WM-100 Work Request Generation, Screening and Classification 7

PCS-M-8 Repairing Pressurizer Spray Valves

CV-1057 and

CV-1059 18

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number

CR-PLP- Description or Title 2003-01938 Date or Revision Dead pigeon Found in Discharge of Relief Valve Pipe 03/19/03 2007-02388 Oil Leak on AFW Pump P-8B 06/06/07 2007-02860 HELB Effect on AFW Pump Room 07/12/07 2007-05339 P-8B Oil Slinger not Turning 10/19/07 2007-05820 P-8B Packing Leakage Low 11/14/07 2008-00553 Bird debris in P-8B Steam Traps

2008-00737 Turbine Bearing Oilers Drained 02/13/08 2008-00739 P-8B Bearing in Alert Range 02/14/08 2008-02118 K-8 Turbine Drive Oil Sample 05/09/08 2008-02203 AFW Pump Speed Adjustments during

QO-21B 05/15/08 2008-02256 NRC Concerns with P-8B 05/20/08 2009-02763 ACE -

CRD 21 Uncoupling Problems 05/19/09 2009-04734 Breaker Issues 10/09/09 2009-04758 Magnesium Rotor Inspection 10/13/09 2009-05765 Drawing Error 12/16/09 2010-00110

QO-5 Stroke Time Reference Change for

CV-3046 01/11/10 2010-00702 P-8B Severity Level 2 Oil Leak 02/17/10 2010-02017 Bird debris in P-8B Floor Drain 05/17/10 2010-03319 P-8B Seal Leakage Low 08/09/10

Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number

CR-PLP- Description or Title 2010-03756 Date or Revision

VT-2 Examination Performed Without Proper Lighting Verification 09/02/10 2010-03756

VT-2 Illumination Verification Inadequate 09/02/10 2010-04584 K-8 Deficiencies 10/07/10 2010-04604 AFW Power Supply Terminals Stripped 10/07/10 2010-04631 Axial Crack on K-8 Turbine Rotor 10/08/10 2010-04653 UT of Tank T-81 10/08/10 2010-05113 P-8B Overspeed Trip Test Failure 01/16/10 2010-05187 Auxiliary Feed Pump P-8C Code Repairs 10/17/10 2010-05188 Bare Metal Visual Examination Procedure 10/17/10 2010-05360 ACE - Trend in NDE Procedure Compliance 10/20/10 2010-05407 Bare metal Visual Examination Relevant Indications

2010-05722 NRC Finding on

VT-2 Examinations 10/27/10 2010-05724 NRC Finding on Bare Metal Visual Examination 10/27/10 2010-05729 NRC Finding on UT of Tank T-81 10/27/10 2010-05796 AFW Pump Would not Deliver 165 gpm Flow 10/28/10 2010-05796 P-8B Would not Deliver Flow 10/28/10 2010-06134 CCI Part 21 on Drag Valves 11/16/10 2010-06465 Part 21 - Event Number 46449 from Rosemount Nuclear 12/07/10 2010-06480

VT-2 Checklists 12/07/10 2010-06482 ASME Code Subscriptions 12/07/10 2010-01842 QA Identified-Engineering Closure of CAs to Non-CAP Processes

2010-02651 QA Identified-M&TE Trackability Issues 06/30/10 2010-02966 Audit issues with Supplemental Worker performance 07/20/10 2010-03016 Observations on Supplemental Workers and lower tier

ACE 07/23/10 2011-00104 Loss of 1F bus and Rear bus as well as P-39A Cooling Tower Pump and RCE, Rev. 0 1/08/11 2011-00336 Reactor Trip on Loss of Load 01/22/11 2011-00677

VT-2 Examiner Annual Certification 02/11/11 2011-00730 AFW Pump 8B, As Found Pump Speed Out Of Tolerance 02/14/11 2011-01019 Inconsistent Maintenance Rule Functional Failure determination and low tier

ACE 03/02/11 2011-01263 NDE Coverage Question 03/15/11 2011-01341 NRC Concern on Part 21 03/18/11 2011-01389 SAMGs and B5B procedures not reviewed as required 03/22/11 2011-02413 NRR Evaluation of Bare Metal Examination Requirements 05/13/11 2011-02491 Water Leakage in Main Control Room 05/18/11 2011-02512 SAMGs outdated due to plant design changes 05/19/11

Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number

CR-PLP- Description or Title 2011-02666 Date or Revision Boric Acid on SIRW Piping 05/27/11 2011-02978 Cross Tie not Considered in GL2008-01 Response 06/14/11 2011-03004 Void Monitoring Locations 06/15/11 2011-03005 Void Monitoring Locations 06/15/11 2011-03021 ACE - Missed Surveillances for

RT-71M 06/16/11 2011-03029 Gas Accumulation Concern 06/16/11 2011-03087 Invalid Assumption in 1918535-R-001 06/21/11 2011-03207 ACE - Service Water Leakage 06/26/11 2011-03256

ESSO-10 is Adequate For Flushing Air 06/29/11 2011-03281

ESSO-10 Minimum Flow Rate 06/30/11 2011-03356 Potential for Vortexing During Shutdown Cooling 07/07/11 2011-03422 Flashing During Shutdown LOCA 08/05/11 2011-03422 Void Size Determination 07/11/11 2011-04620 RCE - PCS Leak -

CV-1057 10/14/11 2011-04710 Turbine Low Vacuum Alarm and Manual Turbine Trip 09/20/11 2011-04872 Pressurizer to Loop Temperature Delta Exceeded 200° F during Cooldown 09/27/11 2011-04890 Pressurizer Level Band Assigned outside of Procedure Recommended Band 09/28/11 2011-04931 Potential trend in Operator Control of the Plant and high tier

ACE 09/29/11 2011-04965 Lack of Short Circuit Protection 09/30/11 2011-04978

EK-1374, LTOP pre-trip, alarm Received During Plant Heatup 09/30/11 2011-04988 50.59 Review of Temporary Modification 09/30/11 2011-05028 Turbine Started up Without Cooling to Generator 10/02/11 2011-05631 NRC identified SAMG revision still did not incorporate previous design changes 10/26/11 2011-06156 P-8B Severity Level 2 Oil Leak 11/12/11 2011-06157 P-8B Severity Level 2 Oil Leak 11/12/11 2012-00183 corrosion-induced floor deformation prevented P-50B feeder breaker from correct secondary breaker alignment 01/07/12 C-PAL-98-1694 Bird debris in P-8B Steam Traps 10/08/98

Attachment AUDITS, ASSESSMENTS AND

SELF-ASSESSMENTS Number Description or Title Date or Revision

Safety Culture Review January 1, 2010 - December 31, 2010

LO-PLP-2011-00022 FSA Pre-NRC PI&R Inspection Assessment 12/08/11

LO-PLPLO-2010-00146 FSA on Buried Piping and Tanks 10/24/10

LO-PLPLO-2010-00159 Fleet FSA of Unit Reliability Team Effectiveness. 08/25/10

LO-PLPLO-2010-00171 FSA on Managing Gas Accumulation in ECCS 10/29/10

LO-PLPLO-2010-00180 FSA of

EQ 11/03/10

LO-PLPLO-2010-00189 Containment ISI Program Self-Assessment 08/18/11

LO-PLPLO-2011-00100 Transient Snapshot Assessment of Operations Performance During the DC Bus Transient 11/09/11

LO-WTPLP-2011-00366 Actions 177-192 for the Corporate Event Review Team and Recovery Plan 10/19/11

QA-08-2011-PLP-1 Programs Engineering Audit 04/21/11

QA-10-2010-PLP-1 Maintenance Audit 08/16/10

QA-10-2010-PLP-1 QA Audit Report - Maintenance 06/21-07/15/10

QA-11-2010-PLP-1 QA Audit-MP&C Jan to Apr 2010

QA-12-18-2011-PLP-1 Operations/Technical Specifications Audit 11/17/11

QA-3-2011-PLP-1 QA Audit Report - Corrective Action Program 4/25-6/1/11

WORK ORDERS Number Description or Title Date or Revision

00270440 G1-1/DRU, Replace Digital Reference Unit 02/16/12

00270442 G1-2/DRU, Replace Digital Reference Unit 02/16/12

00232206

CV-1057, DISASSEMBLE/INSPECT/REPAIR

PM 11/29/10

CONDITION REPORTS GENERATED DURING INSPECTION Number Description or Title Date or Revision 2012-00831 2012 PI&R NRC Identified Issue associated with Emergency Boration of the PCS following the 9/25/11 reactor trip. 02/03/12 2012-0953 Test Parameters for Snubbers in

EM-09-07 need to be Reevaluated 2/9/2012 2012-1045

SCR 10-131 not Completed or Submitted to Records per

EN-IT-104 2/13/2012 2012-1046 Incorrect Revision of

LR-TR-014-TLAA was provided to NRC 2/13/2012 2012-1072

No Basis Found for 350 F Limit on Delta T Between Pressurizer Spray and Pressurizer Vapor Phase as 2/14/2012

Attachment CONDITION REPORTS GENERATED DURING INSPECTION Number Description or Title Date or Revision Specified in

SOP-1B 2012-1185

GL 2008-01 FSA Action not Initiated 2/21/2012

OPERATING EXPERIENCE Number Description or Title Date or Revision

CR-PLP-2010-01734 NRC Information Notice 2010-09 05/11/10

CR-PLP-2010-06134 Part 21 on CCI Drag Valves 11/26/10

CR-PLP-2010-06631 Fuel Assembly Alignment

CR-PLP-2010-06634 NRC Information Notice 2010-21

CR-PLP-2010-06764 NRC Information Notice 2010-26

CR-PLP-2011-01713 NRC Information Notice 2011-02 04/06/11

CR-PLP-2012-00255 Alkali-Silica Reaction 01/12/12

OE-2010-00202 NRC Part 21 2010-03 05/03/10

OE-2010-00522 NRC Part 21 2010-20 09/14/10 OE34226*OE33673

20110917 Missing Reactor Building Weld Channel Test Connection 01/06/12

CR-PLP-2011-04209 NRC Information Notice 2011-12

OE-2011-0917 Missing Reactor Building Weld Channel Test Connection Caps 9/19/11

MISCELLANEOUS Number Description or Title Date or Revision

2010-2012 SCWE Survey Results

CARB Meeting Agenda 2/14/12

CRG Screening Package 2/14/12

Nuclear Safety Culture Monitoring Panel Minutes and Report 12/15/11

OE Screening Sheet 02/01/12

Operations Department Safety Culture Survey January 2012

Palisades Performance Recovery Plan various

Quarterly Trend Report 02/17/12

SARB Meeting Agenda 2/14/12

SARB Meeting Agenda 2/17/12

Second Quarter 2011 Trend Report

System Health Report-AFW 02/15/12 FWS170 AFW Turbine Gland Seal Inspection 05/17/01 L0-WTPLP-Enhancements for

CR-PLP 2010-06259 Operations 01/27/11

Attachment

MISCELLANEOUS Number Description or Title Date or Revision 2011-37 SCWE Issues L0-WTPLP-2012-00088 Develop a plan for addressing the January 2012 Orations SCWE survey results. 2/3/12

Attachment

LIST OF ACRONYMS

USED [[]]

ACE Apparent Cause Evaluation

ADAMS Agencywide Document Access Management System

AFW Auxiliary Feedwater

CAP Corrective Action Program

CAQ Condition Adverse to Quality

CR Condition Report

DC Direct Current

DRS Division of Reactor Safety

EACE Equipment Apparent Cause Evaluation

ECP Employee Concerns Program

EIT Emergent Issue Team

FSA Focused Self-Assessment

LO Learning Organization

IP Inspection Procedure

NCV Non-Cited Violation

NRC U.S. Nuclear Regulatory Commission

OE Operating Experience

PARS Publicly Available Records System

PI&R Problem Identification and Resolution

QA Quality Assurance

RCE Root Cause Evaluation

SCWE Safety Conscious Work Environment

SW Service Water WO Work Order

A. Vitale -2- In accordance with 10

CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records System (

PARS ) component of NRC's Agencywide Document Access and Management System (ADAMS).

ADAMS is accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA/

John

B. Giessner, Branch Chief Branch 4 Division of Reactor Projects Docket No. 50-255 License No.

DPR-20

Enclosure: Inspection Report 05000255/2012007 w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ

DOCUME NT NAME: G:\DRPIII\PALI\Pal 2012 007 PI&R.docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE [[]]

RIII [[]]

RIII [[]]

NAME RLerch:dtp JGiessner

DATE 03/15/12 03/16/12

OFFICI AL

RECORD [[]]

COPY Letter to

A. Vitale from J. Giessner dated March 16, 2012.

SUBJEC T: PALISADES NUCLEAR

PLANT -

PROBLE M IDENTIFICATION

AND [[]]

RESOLU TION INSPECTION REPORT 05000255/2012007