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:	Jack Giessner Reactor Projects Region 3 Branch 4
To:	Vitale A Entergy Nuclear Operations
References
IR-12-007
Download: ML12080A057 (23)

Text

March 16, 2012

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 Commissions 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

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. ODwyer, 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

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 NRCs 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 Resolution

The activities documented in Sections

.1 through.4 constituted one biennial sample

of Problem Identification and Resolution (PI&R) as defined in Inspection Procedure (IP) 71152.

(71152B)

.1 a.

Assessment of the Corrective Action Program Effectiveness The inspectors reviewed the licensees 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 licensees 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 personnels performance in daily plant activities. In addition, the inspectors reviewed CRs and a selection of completed investigations from the licensees 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 staffs actions were in compliance with the facilitys 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 stations 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 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, 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 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 licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE Inspection Scope 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 licensees 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 sites 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 1980s, 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 staffs 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 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 licensees 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 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 OLeary

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

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