IR 05000255/2019010

Reissue - Palisades Nuclear Plant - Design Basis Assurance Inspection (Programs) Inspection Report 05000255/2019010

ML19302E641
Person / Time
Site:	Palisades
Issue date:	10/29/2019
From:	Karla Stoedter NRC/RGN-III/DRS/EB2
To:	Corbin D Entergy Nuclear Operations
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ML19302E718	List:
References
IR 2019010
Download: ML19302E641 (12)

Text

October 29, 2019

SUBJECT:

REISSUEPALISADES NUCLEAR PLANTDESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000255/2019010

Dear Mr. Corbin:

The U.S. Nuclear Regulatory Commission (NRC) identified an administrative error in NRC Inspection Report 05000255/2019010 dated October 21, 2019, (ADAMS Accession Number ML19294A287). As a result, the NRC is reissuing the report in its entirety with the administrative error corrected.

On September 12, 2019, the NRC completed an inspection at Palisades Nuclear Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Palisades. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Karla K. Stoedter, Chief Engineering Branch 2 Division of Reactor Safety

Docket No. 05000255 License No. DPR-20

Enclosure:

As stated

Inspection Report

Docket Number:

05000255

License Number:

DPR-20

Report Number:

05000255/2019010

Licensee:

Entergy Nuclear Operations, Inc.

Facility:

Palisades Nuclear Plant

Location:

Covert, MI

Inspection Dates:

August 18, 2019 to September 12, 2019

Inspectors:

N. Feliz-Adorno, Senior Reactor Inspector

M. Greenleaf, Reactor Inspector

M. Jones, Reactor Inspector

Approved By:

Karla K. Stoedter, Chief

Engineering Branch 2

Division of Reactor Safety

SUMMARY

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

List of Findings and Violations

Failure to Environmentally Qualify Electric Equipment Inside Containment for the Most Severe Chemical Composition Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000255/2019010-01 Open/Closed None (NPP)71111.21N The inspectors identified a Green finding and an associated Non-Cited Violation of Title 10 of the Code of Federal Regulations, Part 50.49, "Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," Paragraph (e)(3), for the licensee's failure to base the qualification of electric equipment inside containment on a chemical composition that was at least as severe as that resulting from the most limiting mode of plant operation. Specifically, the most severe chemical composition expected inside containment would result from the containment spray injection mode. However, the qualification of electric equipment inside containment was based on the less severe chemical composition of the containment spray recirculation mode, which is borated water from the injection mode neutralized by the sodium tetraborate located inside of containment.

Additional Tracking Items

None.

INSPECTION SCOPES

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

REACTOR SAFETY

===71111.21N - Design Bases Assurance Inspection (Programs)

The inspectors evaluated the environmental qualification program implementation through the sampling of the following components:

Select Sample Components to Review - Risk Significant/Low Design (Inside/Outside Containment) (IP Section 02.01)===

(1) Shutdown Cooling Suction Valve MO-3015

(2) Low Pressure Safety Injection Pump P-67A Motor

(3) Cable 19-I29A

(4) Narrow Range Pressure Transmitter PT-0104B

(5) Component Cooling Water Heat Exchanger Control Valve Pilot Valve SV-0821

(6) Shutdown Cooling Heat Exchanger Inlet Valve SV-0937

Select Sample Components to Review - Primary Containment (Inside Containment)

(IP Section 02.01) (1 Sample)

(1) Power Operated Relief Valve PRV-1042B

INSPECTION RESULTS

Failure to Environmentally Qualify Electric Equipment Inside Containment for the Most Severe Chemical Composition Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000255/2019010-01 Open/Closed

None (NPP)71111.21N The inspectors identified a Green finding and an associated Non-Cited Violation of Title 10 of the Code of Federal Regulations (10 CFR), Part 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, Paragraph (e)(3), for the licensee's failure to base the qualification of electric equipment inside containment on a chemical composition that was at least as severe as that resulting from the most limiting mode of plant operation. Specifically, the most severe chemical composition expected inside containment would result from the containment spray injection mode. However, the qualification of electric equipment inside containment was based on the less severe chemical composition of the containment spray recirculation mode, which is borated water from the injection mode neutralized by the sodium tetraborate located inside of containment.

Description:

The containment spray system has two modes of operation. During the initial injection mode, the containment spray system draws borated water from the safety injection and refueling water tank and sprays it inside containment to alleviate pressure during large break loss of coolant accidents and to scrub radioactive particles. The sprayed borated water collects at the containment sump where it is neutralized by mixing with sodium tetraborate, which is pre-staged in baskets inside of containment. The containment spray system transitions to its recirculation mode of operation after depleting the tank, drawing suction from the containment sump and spraying the recirculated solution inside containment to continue scrubbing radionuclides.

The most severe chemical composition expected inside containment would result from the containment spray initial injection mode. However, in 2004, the licensee discovered the environmental qualification of electric equipment inside of containment was based on the chemical effects of the containment spray recirculation mode. This condition was captured in the Corrective Action Program as CR-PLP-2004-1616. As a result, the licensee evaluated the effects of the initial spray pH. However, the inspectors noted the licensee did not evaluate the chemical compatibility of the initial spray with each exposed material composing the electric equipment required to be environmentally qualified. During this inspection period, the licensee determined this concern affected 17 systems such as low pressure injection, high pressure injection, and shutdown cooling.

Corrective Actions: The licensee was still evaluating its planned corrective actions at the time of the inspection. However, the continued non-compliance does not present an immediate safety concern because the licensee reasonably determined the affected equipment remained capable of performing their safety functions. Specifically, the licensee identified all material in environmentally qualified components inside containment and located an evaluation from a similar nuclear power plant addressing boric acid interaction with all but one of the materials located inside of Palisades containment. The licensee determined this evaluation reasonably demonstrated the evaluated materials were compatible with the initial borated water spray. Similarly, the licensee located industry information for the material that was not addressed by the evaluation (i.e., chlorinated polyethylene) and reasonably determined it was compatible with the initial borated water spray.

Corrective Action References: CR-PLP-2019-3692, CR-PLP-2019-3693, CR-PLP-2019-3694, CR-PLP-2019-3695, CR-PLP-2019-3697, CR-PLP-2019-3698, CR-PLP-2019-3699, CR-PLP-2019-3700, CR-PLP-2019-3702, CR-PLP-2019-3703, CR-PLP-2019-3704, CR-PLP-2019-3705, CR-PLP-2019-3706, CR-PLP-2019-3707, CR-PLP-2019-3708, CR-PLP-2019-3709, and CR-PLP-2019-3710.

Performance Assessment:

Performance Deficiency: The failure to base the qualification of electric equipment inside containment on a chemical composition that was at least as severe as that resulting from the most limiting mode of plant operation was contrary to 10 CFR 50.49(e)(3) and was performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to demonstrate qualification of electric equipment inside containment for the most severe chemical effects does not ensure the equipment would be capable of providing its accident mitigating functions.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as of very low safety significance (Green) because it did not result in the loss of operability or functionality of mitigating systems. Specifically, the licensee reasonably determined the affected equipment remained capable of performing their safety functions based on an evaluation from a similar nuclear power plant and industry information addressing boric acid interaction with the affected materials.

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 CFR 50.49(e)(3) requires The electric equipment qualification program must include and be based on, in part, Chemical Effects, and that The composition of chemicals used must be at least as severe as that resulting from the most limiting mode of plant operation (e.g., containment spray, emergency core cooling, or recirculation from containment sump).

Contrary to the above, as of September 16, 2019, the licensees electric equipment qualification program failed to include and be based on the chemical effects of the most severe composition of chemicals resulting from the most limiting mode of plant operation. Specifically, the most severe chemical composition expected inside containment would result from the containment spray injection mode. However, the qualification of electric equipment inside containment was based on the chemical composition of the containment spray recirculation mode, which was less severe due to the borated water from the injection mode being neutralized by the sodium tetraborate located inside of containment.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On September 12, 2019, the inspectors presented the design basis assurance inspection (programs) inspection results to Mr. Darrell Corbin and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.21N Corrective Action

Documents

CR-PLP-2004-

01616

PRE-NRC SSDI, RB Spray pH Considerations Title: FSA

Pre-NRC SSDI, RB Spray pH Considerations

03/02/2004

CR-PLP-2015-

00583

EQ replacement dates occur before 1R24 begins

2/19/2015

CR-PLP-2017-

01007

VOP-3015 Gear Box Grease Degraded

03/18/2017

CR-PLP-2018-

238

EMA-1206 oil was identified with higher than expected

viscosity

01/12/2018

Corrective Action

Documents

Resulting from

Inspection

CR-HQN-2019-

01982

The NRC identified that EN-MA-141, Attachment 1 does not

contain any reference to potential EQ implications during

grease evaluation

09/06/2019

CR-PLP-2019-

03371

Boric acid leak on P-67A

08/27/2019

CR-PLP-2019-

03409

Corrective action document written for unsat oil viscosity for

EMA-1206 did not address EQ or past-operability

08/29/2019

CR-PLP-2019-

03463

Unable to locate auxiliary feedwater pump P-8C motor oil

analysis for 2013

09/04/2019

CR-PLP-2019-

03464

Auxiliary feedwater pump P-8C had unsat oil viscosity

09/04/2019

CR-PLP-2019-

03559

DBD-7.01 contain misleading information regarding what

containment spray density is required for EQ Qualification of

equipment inside containment

09/10/2019

CR-PLP-2019-

03692

Qualification of CIS did not consider chemical effects

09/16/2019

CR-PLP-2019-

03693

Qualification of CLP did not consider chemical effects

09/16/2019

CR-PLP-2019-

03694

Qualification of CRS did not consider chemical effects

09/16/2019

CR-PLP-2019-

03695

Qualification of CSW did not consider chemical effects

09/16/2019

CR-PLP-2019-

03697

Qualification of CVC did not consider chemical effects

09/16/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR-PLP-2019-

03698

Qualification of ESS did not consider chemical effects

09/16/2019

CR-PLP-2019-

03699

Qualification of FWS did not consider chemical effects

09/16/2019

CR-PLP-2019-

03700

Qualification of HPI did not consider chemical effects

09/16/2019

CR-PLP-2019-

03702

Qualification of LPI did not consider chemical effects

09/16/2019

CR-PLP-2019-

03703

Qualification of MFW did not consider chemical effects

09/16/2019

CR-PLP-2019-

03704

Qualification of NMS did not consider chemical effects

09/16/2019

CR-PLP-2019-

03705

Qualification of PCS did not consider chemical effects

09/16/2019

CR-PLP-2019-

03706

Qualification of PZR did not consider chemical effects

09/16/2019

CR-PLP-2019-

03707

Qualification of RIA did not consider chemical effects

09/16/2019

CR-PLP-2019-

03708

Qualification of SDC did not consider chemical effects

09/16/2019

CR-PLP-2019-

03709

Qualification of SIT did not consider chemical effects

09/16/2019

CR-PLP-2019-

03710

Qualification of VAS did not consider chemical effects

09/16/2019

Drawings

VEN-E48

Install Conduit/Component Seals

Engineering

Changes

EC-7083

Equivalent Replacement and/or Substitution of Nebula EP0

Grease with MOV Long Life Grade 0 Grease

Engineering

Evaluations

E48-EMA-01

EQ File - Louis-Allis Model COGX Motors

E48-EMA-07

EQ File - Reliance Electric 2300 Vac motor

E48-SV-01

EQ file: Automatic Switch Company (ASCO) Model 206-381

and

NP 8320 solenoid valves

E48-VOP-03

EQ File - Limitorque Valve Operators with RH Motor

Insulation Systems Located in Containment

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

E48-XMTR-01

EQ File: Rosemount Series 1153B and 1153D Transmitters

E48-XMTR-02

EQ File: Rosemount Series 1154 Transmitters

Miscellaneous

DBD-7.01

Electrical Equipment Qualification Program

DBD-7.02

EQ Master Equipment List

E48-CABLE-19

Samuel Moore EPDM Insulated and Hypalon Jacketed

Instrumentation Cable

E48-SV-08

ASCO Model NP 8316 and NP 8321 Solenoid Valves

E48-SV-24

Target Rock Power Operated Relief Valves for Pressurizer

Pressure

NUREG/CR-6095

Aging, Loss-of-Coolant Accident (LOCA), and High Potential

Testing of Damaged Cables

04/01/1994

Procedures

EN-DC-303

Lubrication Program

EN-DC-310

Predictive Maintenance Program

EN-MA-141

Limitorque Valve Operator Model SMB/SB/SBD-000

Through 5 MOV and HBC Periodic Inspection

EOP-4.0

Loss of Coolant Accident Recovery

MSE-E-41

Refurbishment of Limitorque Type SMB-0 Though SMB-3

Actuators

SEP-EQ-PLP-001 Environmental Qualification of Electrical Equipment

SEP-LUB-PLP-

001

Lubrication Analysis and Monitoring

WI-SPS-E-02

Insulation Resistance Testing of Electrical Equipment

Self-Assessments LO-PLPLO-2019-

00013

Environmental Qualification (EQ) Program Assessment

05/28/2019

Work Orders

WO00262884

PRV-1042B; VT-2 NOP/NOT (CR-PLP-2011-00191)

01/31/2011

WO00325740

MO-3015 Burnish Torque Switch Contacts

2/09/2014

WO51591547

PRV-1042B; Replace PRV-1042B EC-20196

08/19/2011

WO51591548

PRV-1043B; Replace PRV-1043B EC-20196

11/08/2010

WO52435844

• EEQ* REPLACE SV-0821

01/27/2014

WO52436138

EEQ Maint. - PM VOP-3015

2/09/2014

WO52537816

RI-59C - LTOP Pessure Transmitter Cals

10/19/2015

WO52544964

PT-0104B, EEQ Replace Transmitter

09/28/2015

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

WO52608846

P-67A MTR/PMP Oil Change

04/08/2016

WO52610930

EEQ Maint.-PM VOP-3009

06/28/2016

WO52650632

EEQ - EMA-1206 LPSI Pump P-67A Motor

03/27/2017

WO52681040

EEQ Maint. - PM VOP-3015

03/18/2017

WO52681204

EEQ Maint.-PM VOP-3012

07/25/2017

WO52753971

EEQ - EMA-1206 LPSI Pump P-67A Motor

09/18/2018

WO52765497

Thermalscan Equip.- P-67A Motor/Breaker

06/20/2018

WO52778170

RI-59C - LTOP Pressure Transmitter Cals

11/08/2018

WO52779578

QO-2X - Recirculation Actuation System

2/19/2014

WO52785113

P-67A MTR/PMP Oil Change

03/25/2019

WO52827608

Thermalscan Equip.- P-67A Motor/Breaker

06/18/2019