UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

REGION III 

2443 WARRENVILLE ROAD, SUITE 210 

LISLE, IL 60532-4352 

January 3, 2012 

EA-11-227 

Mr. Anthony Vitale 

Vice-President, Operations 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

SUBJECT: FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING WITH 

ASSESSMENT FOLLOWUP AND NOTICE OF VIOLATION 

NRC INSPECTION REPORT NO. 05000255/2011017 

PALISADES NUCLEAR PLANT 

Dear Mr. Vitale: 

This letter provides you the final significance determination of the preliminary White finding 

discussed in our previous communication dated October 28, 2011, which included U.S. Nuclear 

Regulatory Commission (NRC) Inspection Report No. 05000255/2011013. The finding involved 

the improper greasing of a knife edge on the overspeed trip mechanism which contributed to a 

failure of the turbine driven auxiliary feedwater pump (pump P-8B) during surveillance testing on 

May 10, 2011. 

In a letter dated November 28, 2011, you provided a response to the NRC staff’s preliminary 

determination regarding the finding. Your response indicated that you acknowledged the finding 

and apparent violation, but that you disagreed with the risk significance. Specifically, your 

response indicated that the failure of pump P-8B was a spurious trip and that there have been 

no other failures from 2005 up until the May 10, 2011, trip. For that reason, your staff concluded 

that the delta core damage frequency () CDF) attributable to the issue would be less than 

1 E-06/yr, resulting in a significance determination of very low safety significance. Your staff 

also determined that there were additional procedural non-compliances and that preparation 

and execution of the pump P-8B overhaul in 2010 did not ensure pump reliability. The NRC 

reviewed these additional procedural issues and determined that the issues contributed to the 

identified performance deficiency. Specifically, as noted in your response, vendor information 

developed to reduce the potential for pump trips was not incorporated into the procedure. This 

vendor information included critical guidance on inspection of the knife edge and latch plate for 

wear and periodic replacement of the trip spring. Furthermore, it was identified that the postmaintenance testing instructions in the maintenance procedure were documented as 

suggestions and, therefore, were not performed. The NRC noted that performance of these 

would have provided you an opportunity to identify the potential for a deficiency in pump 

performance prior to returning the pump to service. 

As a result, the NRC revised the performance deficiency to state that “The licensee failed to 

ensure that safety-related procedure FWS-M-6, “Auxiliary Feedwater Turbine Maintenance,” 

was appropriate to the circumstances, in that, it did not address turbine vendor critical guidance 
A. Vitale -2- 

for inspection of the knife edge and latch plate for wear and periodic replacement of the trip 

spring. Additionally, the procedure specified post-maintenance tests of the overspeed 

mechanism as guidance rather than required actions. Furthermore, during performance of the 

procedure, the licensee failed to follow a step of the procedure which required lubricating a pin 

and instead greased the knife edge of the mechanical overspeed/manual trip mechanism.” 

The NRC considered the information developed during the inspection and the additional 

information you provided in your letter dated November 28, 2011, as to whether the failure could 

be characterized as a spurious trip. This included review of the calculation of the overspeed trip 

mechanism linkage forces and the risk assessment of the turbine driven auxiliary feedwater P8B trip which were enclosed with your response. In general, the NRC agrees the grease 

alone may not have caused the trip as discussed in the force calculation. The grease did, 

however, reduce the force needed to move the hand trip lever. Because of the grease, the 

other deficiencies introduced during the pump maintenance, and the actual pump conditions at 

the time of the trip, the NRC determined that the trip cannot be considered as spurious. 

The NRC concluded that a performance deficiency existed such that the 2010 maintenance was 

reasonably the proximate cause of the pump failure on May 10, 2011. As a result, the pump trip 

was not “spurious” but rather the result of deficient licensee performance. In accordance with 

NRC Inspection Manual Chapters 0609, Appendix A, and 0308, Attachment 3, the NRC staff 

assessed the risk to the plant using the Significance Determination Process, as described in 

NRC Inspection Report No. 05000255/2011013. As your risk assessment relied upon the 

conclusion that the trip was spurious, it did not provide any additional risk information beyond 

what was considered in Inspection Report No. 05000255/2011013. Therefore, the NRC has 

concluded that the finding is appropriately characterized as White, a finding of low to moderate 

risk significance. 

You have 30 calendar days from the date of this letter to appeal the staff’s determination of 

significance for the identified White finding. Such appeals will be considered to have merit only 

if they meet the criteria given in NRC Inspection Manual Chapter 0609, “Significance 

Determination Process,” Attachment 2. An appeal must be sent in writing to the Regional 

Administrator, Region III, Suite 210, 2443 Warrenville Road, Lisle, IL 60532. 

The NRC has also determined that the improper lubrication of the overspeed mechanism knife 

edge is a violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, 

Criterion V, “Instructions, Procedures, and Drawings,” as cited in the attached Notice of 

Violation (Notice). The circumstances surrounding the violation were described in detail in NRC 

Inspection Report No. 05000255/2011013. In accordance with the NRC Enforcement Policy, 

the Notice is considered escalated enforcement action because it is associated with a White 

finding. 

The NRC has concluded that information regarding the reasons for the violation, the 

corrective actions taken and planned to be taken to correct the violation and prevent recurrence, 

and the date when full compliance was achieved, is already adequately addressed on the 

docket in NRC Inspection Report No. 05000255/2011013 and in your response dated 

November 28, 2011. Therefore, you are not required to respond to this letter unless the 

description therein does not accurately reflect your corrective actions or your position. In that 
A. Vitale -3- 

case, or if you choose to provide additional information, you should follow the instructions 

specified in the enclosed Notice. 

As a result of our review of Palisades’ performance, including this White finding, we have 

assessed the plant to be in the Regulatory Response column of the NRC’s Action Matrix, 

effective the fourth quarter of 2011. Therefore, we plan to conduct a supplemental inspection 

using Inspection Procedure 95001, “Inspection for One or Two White Inputs in a Strategic 

Performance Area,” when your staff has notified us of your readiness for this inspection. This 

inspection procedure is conducted to provide assurance that the root cause and contributing 

causes of risk significant performance issues are understood, the extent of condition and the 

extent of cause are identified, and the corrective actions are sufficient to prevent recurrence. 

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 made available electronically for public 

inspection in the NRC Public Document Room or from the NRC=s Agencywide Documents 

Access and Management System (ADAMS), accessible from the NRC Web site at 

http://www.nrc.gov/reading-rm/adams.html. The NRC also includes significant enforcement 

actions on its Web site at http://www.nrc.gov/reading-rm/doc-collections/ enforcement/actions. 

Sincerely, 

/RA by Jennifer Uhle acting for/ 

Cynthia D. Pederson 

Acting Regional Administrator 

Docket No. 050-00255 

License No. DPR-20 

Enclosure: 

Notice of Violation 

cc w/encl: Distribution via ListServ 
 ENCLOSURE 

NOTICE OF VIOLATION 

Entergy Nuclear Operations, Inc. Docket No. 50-255 

Palisades Nuclear Plant License No. DPR-20 

 EA-11-227 

During a U.S. Nuclear Regulatory Commission (NRC) inspection conducted from September 26 

through October 5, 2011, a violation of NRC requirements was identified. In accordance with 

the NRC Enforcement Policy, the violation is listed below: 

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix B, Criterion V, 

“Instructions, Procedures, and Drawings,” requires, in part, that activities affecting quality 

be prescribed by documented instructions, procedures or drawings of a type appropriate 

to the circumstances and be accomplished in accordance with these instructions, 

procedures or drawings. 

Technical Specification 3.7.5 requires, in part, that two auxiliary feedwater trains be 

operable during plant operation in Modes 1, 2, and 3 with the steam driven pump 

required to be operable prior to making the reactor critical. 

Technical Specification Actions 3.7.5.A and B require, in part, that if one auxiliary 

feedwater train is inoperable in Modes 1, 2, and 3, the affected train be restored to 

operable status within 72 hours or the plant placed in Mode 3 within 6 hours and in 

Mode 4 within 30 hours. 

Contrary to the above, on October 17, 2010, maintenance on the safety-related steam 

driven auxiliary feedwater pump, an activity affecting quality, was not prescribed by 

documented instructions or procedures of a type appropriate to the circumstances and 

accomplished in accordance with the instructions or procedures. Specifically: 

a. Maintenance was not prescribed by procedures appropriate to the 

circumstances, in that procedure FWS-M-6, “Auxiliary Feedwater Turbine 

Maintenance,” failed to prescribe inspections of wear conditions on the knife 

edge and latch plate or to replace the trip spring, although these inspections and 

replacements had been identified as necessary by the turbine vendor in vendor 

technical letter ETSL-T-2012, Revision 0; and 

b. Workers performing procedure FWS-M-6 failed to follow Step 5.40.3 of the 

procedure which required lubricating a pin and instead greased the knife edge of 

the mechanical overspeed/manual trip mechanism. 

As a result, the steam driven auxiliary feedwater pump P-8B was inoperable from 

October 29, 2010, to May 11, 2011, a period greater than 72 hours. Because the 

licensee was not aware of the inoperability, the required actions in Actions 3.7.5.A 

and B were not followed. 

This violation is associated with a White Significance Determination Process finding. 
Notice of Violation -2- 

 ENCLOSURE 

The NRC has concluded that information regarding the reasons for the violation, the corrective 

actions taken and planned to be taken to correct the violation and prevent recurrence, and the date 

when full compliance was achieved, is already adequately addressed on the docket in NRC 

Inspection Report No. 05000255/2011013 and in your response dated November 28, 2011. 

However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201, 

if the description therein does not accurately reflect your corrective actions or your position. In that 

case, or if you choose to respond, clearly mark your response as a “Reply to a Notice of Violation, 

EA-11-227,” and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control 

Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region III, 

2443 Warrenville Road, Suite 210, Lisle, IL 60532, and a copy to the NRC Resident Inspector at 

the Palisades facility, within 30 days of the date of the letter transmitting this Notice of Violation 

(Notice). 

If you contest this enforcement action, you should also provide a copy of your response, with the 

basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory 

Commission, Washington, DC 20555-0001. 

If you choose to respond, your response will be made available electronically for public 

inspection in the NRC Public Document Room or from the NRC’s Agencywide Documents 

Access and Management System (ADAMS), accessible from the NRC Web site at 

http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response 

should not include any personal privacy, proprietary, or safeguards information so that it can be 

made available to the public without redaction. 

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working 

days of receipt. 

Dated this 3rd day of January 2012
A. Vitale -3- 

case, or if you choose to provide additional information, you should follow the instructions 

specified in the enclosed Notice. 

As a result of our review of Palisades’ performance, including this White finding, we have 

assessed the plant to be in the Regulatory Response column of the NRC’s Action Matrix, 

effective the fourth quarter of 2011. Therefore, we plan to conduct a supplemental inspection 

using Inspection Procedure 95001, “Inspection for One or Two White Inputs in a Strategic 

Performance Area,” when your staff has notified us of your readiness for this inspection. This 

inspection procedure is conducted to provide assurance that the root cause and contributing 

causes of risk significant performance issues are understood, the extent of condition and the 

extent of cause are identified, and the corrective actions are sufficient to prevent recurrence. 

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 made available electronically for public 

inspection in the NRC Public Document Room or from the NRC=s Agencywide Documents 

Access and Management System (ADAMS), accessible from the NRC Web site at 

http://www.nrc.gov/reading-rm/adams.html. The NRC also includes significant enforcement 

actions on its Web site at http://www.nrc.gov/reading-rm/doc-collections/ enforcement/actions. 

Sincerely, 

/RA by Jennifer Uhle acting for/ 

Cynthia D. Pederson 

Acting Regional Administrator 

Docket No. 050-00255 

License No. DPR-20 

Enclosure: 

Notice of Violation 

cc w/encl: Distribution via ListServ 

DISTRIBUTION: 

See next page 

* See previous concurrence 

FILE NAME: G:\ORAIII\EICS\ENFORCEMENT\Enforcement Cases 2011\EA-11-227 Palisades 

TDAFW\EA-11-227 Palisades final determination letter.docx 

 Publicly Available, non-sensitive 

OFFICE RIII RIII RIII OE RIII RIII 

NAME Lougheed* Kunowski for 

Giessner* 

Shear for 

West* 

Zimmerman1 Heller for 

Orth 

Uhle for 

Pederson 

DATE 12/22/11 12/23/11 12/23/11 12/22/11 12/28/11 01/03/12 

OFFICIAL RECORD COPY

 

1 OE concurrence received via e-mail from L. Casey on December 22, 2011. 
Letter to Anthony Vitale from Cynthia D. Pederson dated January 3, 2012 

SUBJECT: FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING WITH 

ASSESSMENT FOLLOWUP AND NOTICE OF VIOLATION 

NRC INSPECTION REPORT NO. 05000255/2011017 

PALISADES NUCLEAR PLANT 

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