IR 05000255/2007008

IR 05000255-07-008, on 11/26/2007 - 12/12/2007, Palisades, Evaluation of Changes, Tests, or Experiments (10 CFR 50.59) and Permanent Plant Modifications

ML080250237
Person / Time
Site:	Palisades
Issue date:	01/24/2008
From:	Dave Hills NRC/RGN-III/DRS/EB1
To:	Schwarz C Entergy Nuclear Operations
References
IR-07-008
Download: ML080250237 (16)

Text

January 24, 2008

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

SUBJECT: PALISADES NUCLEAR PLANT NRC EVALUATION OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000255/2007008(DRS)

Dear Mr. Schwarz:

On December 12, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection findings which were discussed on December 12, 2007, with you and members of your staff. Additional discussions were held with Mr. John Broschak and others via telephone conference on January 24, 2008.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of the inspection, one NRC identified finding of very low safety significance was identified, which involved a violation of NRC requirements. However, because the violation was of very low safety significance and because it was entered into your corrective action program, the NRC is treating the issue as a Non-Cited Violation (NCV) in accordance with Section VI.A.1 of the NRC's Enforcement Policy.

If you contest the subject or severity of an NCV, 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Palisades Nuclear Plant.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

David E. Hills, Chief Engineering Branch 1

Division of Reactor Safety Docket No. 50-255 License No. DPR-20

Enclosure: Inspection Report 05000255/2007006 w/Attachment: Supplemental Information cc w/encl: M. Kansler, President and Chief Executive Officer/

Chief Nuclear Officer J. Herron, Senior Vice President Senior Vice President, Engineering and Technical Services M. Balduzzi, Senior Vice President and Chief Operating Officer, Regional Operations, NE O. Limpias, Vice President, Engineering J. Ventosa, General Manager, Engineering J. DeRoy, Vice President, Operations Support Director, NSA J. McCann, Director, Nuclear Safety & Licensing E. Harkness, Director of Oversight General Manager, Plant Operations C. Faison, Manager, Licensing L. Lahti, Manager, Licensing W. Dennis, Assistant General Counsel W. DiProfio W. Russell G. Randolph Supervisor, Covert Township Office of the Governor State Liaison Officer, State of Michigan Michigan Department of Environmental Quality -

Waste and Hazardous Materials Division Michigan Office of the Attorney General

SUMMARY OF FINDINGS

IR 05000255/2007008; 11/26/2007 - 12/12/2007; Palisades Nuclear Plant; Evaluation of Changes, Tests, or Experiments (10 CFR 50.59) and Permanent Plant Modifications.

The inspection covered a two week announced baseline inspection on evaluations of changes, tests, or experiments and permanent plant modifications. The inspection was conducted by three regional based engineering inspectors. The NRC's program for overseeing the safe operati on of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.

A. Inspector-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, "Design Control" requirements. Specifically, the licensee failed to incorporate a number of uncertainties when calculating the technical specification (TS) limits for the emergency diesel generator (EDG) fuel oil volume. This resulted in a non-conservative TS value. Once identified by the inspectors, the licensee issued a standing order in the "SRO Shift Turnover Items Shift Checklist" to ensure that adequate margin existed for the EDG seven-day fuel oil requirement to account for the uncertainties and planned to address the issue further through their corrective action process.

The finding was more than minor because the uncertainties were significant enough to necessitate additional calculations to ensure adequate fuel would be maintained in the diesel fuel tank. The issue was of very low safety significance based on Phase 1 screening in accordance with IMC 609.04, "Phase 1 - Initial Screening and Characterization of Findings." Specifically, it was determined that at the time of the inspection, adequate fuel existed in the diesel fuel tank (T-10A)to meet the required mission time and the inspectors did not identify any previous instances in which the tank level had dropped too low. The inspectors determined that there were no cross-cutting aspects associated with this finding because the performance deficiency occurred greater than two years ago.

B. Licensee-Identified Violations

None

2

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R02 Evaluations of Changes, Tests, or Experiments

.1 Review of 10 CFR 50.59 Evaluations and Screenings

a. Inspection Scope

From November 26 through December 12, 2007, the inspectors reviewed seven evaluations performed pursuant to 10 CFR 50.59 to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 13 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. In regard to the changes reviewed where no 10 CFR 50.59 evaluation was performed, the inspectors verified that the changes did not meet the threshold to require a 10 CFR 50.59 evaluation. The evaluations and screenings were chosen based on risk significance, safety significance, and complexity. The list of documents reviewed by the inspectors is included as an attachment to this report. The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, "Guidelines for 10 CFR 50.59 Implementation," Revision 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments."

b. Findings

None

1R17 Permanent Plant Modifications

.1 Review of Permanent Plant Modifications

a. Inspection Scope

From November 26 through December 12, 2007, the inspectors reviewed eight permanent plant modifications that had been installed in the plant during the last two years. The modifications were chosen based upon risk significance, safety significance, and complexity. As per inspection procedure (IP) 71111.17B, one modification was chosen that affected the barrier integrity cornerstone. The inspectors reviewed the modifications to verify that the completed design changes were in accordance with the specified design requirements, and the licensing bases, and to confirm that the changes did not adversely affect any systems' safety function. Design and post-modification testing aspects were reviewed to ensure the functionality of the modification, its associated system, and any support systems. The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of 3modifications and other documents reviewed by the inspectors is included as an attachment to this report.

b. Findings

Failure to Establish Correct Tech Spec Limits.

Introduction:

Green. The inspectors identified an NCV of 10 CFR 50 Part 50, Appendix B, Criterion III, "Design Control," requirements in that the licensee failed to incorporate a number of uncertainties when establishing the technical specification (TS) limits for the diesel generator seven-day fuel oil volume requirements.

Description:

On December 10, 2007, the inspectors identified through the review of a modification package (EC9610) regarding operation of the EDGs with low sulfur content fuel, that the licensee had failed to incorporate various values of uncertainty into the calculations that determined the TS seven-day diesel fuel storage volume requirements.

The uncertainties included values associated with fuel variability (such as heat content),

level instrumentation, transfer pump vortexing, unusable volume within the storage tank, and others. The failure to include uncertainty resulted in a TS value for the volume of diesel fuel which was less than that required to operate the EDG for the required mission based upon the licensee's fuel consumption data.

The licensee was aware that they did not include some of these uncertainties in the calculation of the EDG fuel oil TS limit, but believed that surveillance procedure "Proc No DWO-1" required EDG fuel oil tank T-10A level to be maintained at a level that provided adequate margin to address those uncertainties, including unusable volume. The inspectors reviewed Proc No DWO-1, revision 80, "TS Surveillance Procedure" and noted that the controls the licensee was relying on did not ensure that a level was maintained in tank T-10A to provide the uncertainty related margin, and did not take into consideration the 725 gallons of unusable volume in the tank.

After further review, the licensee concurred that insufficient controls were in place to preclude reducing tank level below that required to account for the uncertainties or unusable volume. As a result, the licensee added a standing order in the "SRO Shift Turnover Items Shift Checklist" to account for the uncertainties. The licensee opted to address this issue through an existing condition report (CR-PLP-2007-04259). Although, the existing condition report had already captured some limited aspects of the calculation uncertainty, it did not address much of the inspectors' concern noted above.

As a result, implementation of additional controls was necessary after the inspectors identified the issue.

Analysis:

The inspectors determined that the failure to establish adequate TS limits for emergency diesel fuel oil volume was a performance deficiency warranting a significance determination. The inspectors concluded that the finding was greater than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Disposition Screening," because the finding met the criteria in IMC 0612, Appendix E, "Examples of Minor Issues," Example 3j. Specifically, there was reasonable doubt on the operability of a system or component in that the uncertainties were significant enough to necessitate additional calculations to ensure adequate fuel would be maintained in the diesel fuel tank. The finding was determined to be of very low safety significance (Green) based on a Significance Determination Process (SDP)4Phase 1 determination that the finding was a design deficiency issue that did not result in a loss of operability of the EDG's because it was determined that at the time of the inspection, adequate fuel existed in the diesel fuel tank (T-10A) to meet the required mission time and the inspectors did not identify any previous instances in which tank level had dropped too low. The inspectors determined that there were no cross-cutting aspects associated with this finding because the performance deficiency occurred

greater than two years ago.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control" requirements states, in part, that "The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplifi ed calculation methods, or by the performance of a suitable testing program.

Contrary to the above, the licensee's design control measures (calculations) failed to consider uncertainties associated with fuel variability, level instrumentation, transfer pump vortexing, and unusable volume within the storage tank. This resulted in the potential to have an insufficient fuel volume to support the seven-day mission Because of the very low safety significance of this finding and because the issue was entered into the licensee's corrective action program (CR-PLP-2007-04259), it is being

treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000255/200700x-XX).

4OA2 Identification and Resolution of Problems

.1 Routine Review of Condition Reports

a. Inspection Scope

From November 26 through December 12, 2007, the inspectors reviewed eleven Corrective Action Program (CAP) documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions (CA) related to permanent plant modifications and evaluations for changes, tests, or experiments issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the team are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

54OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. C. Schwarz and others of the licensee's staff, on December 12, 2007. Licensee personnel were asked to identify any documents, materials, or information provided during the inspection that were considered proprietary. No proprietary information was identified. In addition, a telephone re-exit was conducted on January 24, 2008 with Mr. John Broschak to discuss the NCV.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

C. Schwarz, Site Vice President

A. Blind, Design Engineering Manager

L. Lahti, Licensing Manager

B. Kemp, Design Supervisor

J. Erickson, Design Engineer

B. Dotson, Technical Specialist

Nuclear Regulatory Commission

J. Ellegood, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000255/2007008-01 NCV EDG Fuel Adequacy Calculation

Closed

05000255/2007008-01 NCV EDG Fuel Adequacy Calculation

Discussed

None

2

LIST OF DOCUMENTS REVIEWED

The following is a list of licensee documents reviewed during the inspection, including