IR 05000255/2012001

Annual Assessment Letter for Palisades Nuclear Plant (IR 05000255-12-001)

ML13063A141
Person / Time
Site:	Palisades
Issue date:	03/04/2013
From:	Casto C Region 3 Administrator
To:	Vitale A Entergy Nuclear Operations
References
IR-12-001
Download: ML13063A141 (7)

Text

arch 4, 2013

SUBJECT:

END-OF-CYCLE ASSESSMENT LETTER FOR PALISADES NUCLEAR PLANT (REPORT 05000255/2012001)

Dear Mr. Vitale:

On February 13, 2013, the NRC completed its end-of-cycle performance review of the Palisades Nuclear Plant. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to inspection results and enforcement actions from January 1, 2012, through December 31, 2012. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility.

The NRC determined that overall, Palisades Nuclear Plant operated in a manner that preserved public health and safety and met all cornerstone objectives. The NRC determined that performance at the Palisades Nuclear Plant during the most recent quarter was within the Licensee Response Column of the NRCs Reactor Oversight Process (ROP) Action Matrix because all inspection findings had very low (i.e., green) safety significance, and all PIs indicated that your performance was within the nominal, expected range (i.e., green).

Therefore, the NRC plans to conduct ROP baseline inspections at your facility. Additionally, as stated in our Assessment Follow-up Letter dated November 9, 2012 (ML12314A304), the NRC is deviating from the ROP to conduct additional inspections, above baseline, during 2013, to:

(1) follow-up on corrective actions regarding performance improvement efforts that had not been implemented when the Inspection Procedure (IP) 95002, Inspection for One Degraded Cornerstone or Any Three White Performance Inputs in a Strategic Performance Area, inspection concluded, as well as assessing the corrective actions sustainability; and (2) review a number of technical issues to verify that you determined the causes and implemented corrective actions to provide reasonable assurance that more significant safety concerns do not develop. Specifics on the reasons behind this deviation were provided in an ROP Deviation Memorandum to R. W. Borchardt, Executive Director of Operations, dated November 8, 2012 (ML12306A367).

During this assessment period the NRC closed three Greater-than-Green findings. These findings included a Yellow finding and one White finding in the Initiating Events Cornerstone, which resulted in plant performance for the first, second, and third quarters of 2012 to be in the Degraded Cornerstone Column of the NRCs ROP Action Matrix. The Yellow finding was associated with the loss of one direct current (DC) bus that occurred on September 25, 2011, which resulted in a complicated reactor trip. The White finding was associated with the failure of service water pump P-7C due to intergranular stress corrosion cracking that occurred on a pump shaft coupling on August 9, 2011. Additionally, a White finding was identified in the Mitigating Systems Cornerstone related to the Turbine Driven Auxiliary Feedwater pumps failure to run during a surveillance test on May 10, 2011.

The NRC completed a supplemental inspection using IP 95001, Inspection for One or Two White Inputs in a Strategic Performance Area, on June 29, 2012 (ML12213A225). The NRC determined that your staff performed an acceptable evaluation of the White finding in the Mitigating Systems Cornerstone. Therefore, this White finding was closed at the end of the third quarter of 2012. In addition, the NRC completed a supplemental inspection using IP 95002, Inspection for One Degraded Cornerstone or Any Three White Performance Inputs in a Strategic Performance Area, for the two findings in the Initiating Event Cornerstone (ML12314A304). The NRC determined that your actions met the inspection objectives with no significant weaknesses. As a result, the NRC determined the performance at Palisades Nuclear Plant to be in the Licensee Response Column of the Reactor Oversight Process Action Matrix as of October 1, 2012.

During this assessment period there were seven findings identified in the area of human performance (HP). In our mid-cycle performance letter dated September 4, 2012 (ML12248A318), we advised you of two substantive cross-cutting issues (SCCIs) in the area of HP with cross-cutting themes in the aspects of Conservative Assumptions (H.1(b)), and Oversight (H.4(c)). In addition, we advised you that the HP substantive cross-cutting issues would remain open until the number of findings in the H.1(b), and H.4(c) aspects were reduced and you demonstrated the implementation of effective corrective actions that resulted in sustained performance improvement in the HP area. The two SCCIs have been open for two consecutive assessment periods.

With regards to Conservative Assumptions (H.1(b)), there were only two findings in this HP aspect during the current assessment cycle, a reduction in number as it relates to our last assessment. Through our observations during supplemental and baseline inspections, we determined that your corrective actions have been effective in addressing this issue, and sustained performance improvement has been demonstrated. We noted that you have addressed the gaps in training and performance which kept the Conservative Assumptions issue open during the last assessment period. Based on these observations and our inspections, the SCCI in Conservative Assumptions (H.1(b)) is closed.

For the SCCI in Oversight (H.4(c)) there were three findings in this HP aspect during the current assessment cycle, a reduction in number as it relates to our last assessment. The effectiveness review, conducted by your staff, of corrective actions for addressing the SCCI in Oversight from the mid-cycle assessment revealed that those corrective actions to prevent recurrence (CAPRs)

were not effective and did not drive the desired behavior changes. Through observations during supplemental and baseline inspections, the inspectors came to the same conclusion that the desired changes have not transpired with those corrective actions in place. The inspectors noted that issues are still being encountered in the area of oversight and new corrective actions have recently been assigned to resolve the gaps in performance found during your effectiveness review. These actions have not yet been implemented and the sustainability of these actions will need to be reviewed when a reasonable duration of time has passed. For this reason, the SCCI in Oversight (H.4(c)) will remain open. This SCCI will remain open until the number of findings in the H.4(c) aspect is reduced and you demonstrate the implementation of effective corrective actions that result in sustained performance improvement in this area. You should plan on discussing your corrective actions to address this issue at the public end-of-cycle meeting.

The enclosed inspection plan lists the inspections scheduled through December 31, 2014.

Routine inspections performed by resident inspectors are not included in the inspection plan.

The inspections listed during the last 12 months of the inspection plan are tentative and may be revised at the mid-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security related inspections, which will be sent via separate, non-publicly available correspondence.

In addition to the ROP baseline, we plan to perform Temporary Instruction (TI) 2515/182, Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping. Additional inspections include: Inspection Procedure (IP) 92702 Follow-up on Corrective Actions for Violations and Deviations, IP 92709 Licensee Strike Contingency Plans, IP 60856.1 Review of 10 CFR 72.212 (b) Evaluation at Operating Plants, IP 60854.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants, IP 60855.1 Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants, and IP 92703 Follow-up on Confirmatory Action Letters or Orders from Alternative Dispute Resolution.

In accordance with 10 CFR 2.390 of the NRCs ARules of Practice,@ a copy of this letter 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). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Please contact Mr. John Giessner at 630-829-9619 with any questions you have regarding this letter.

Sincerely,

/RA/

Charles A. Casto, Regional Administrator Docket No. 50-255 License No. DPR-20 Enclosure: Palisades Nuclear Plant Inspection/Activity Plan cc w/encl: Distribution via ListServ