ML040641189

End-of-Cycle Letter. Includes Inspection Plan Which Details the Inspections Scheduled Through September 30, 2005

ML040641189
Person / Time
Site:	Palisades
Issue date:	03/04/2004
From:	Reynolds S Division Reactor Projects III
To:	Domonique Malone Nuclear Management Co
References
IR-04-001
Download: ML040641189 (8)

Text

March 4, 2004 Mr. Daniel J. Malone Site Vice President Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

ANNUAL ASSESSMENT LETTER - PALISADES NUCLEAR PLANT (REPORT 50-255/04-01)

Dear Mr. Malone:

On February 10, 2004, the NRC staff completed its end-of-cycle plant performance assessment of your Palisades Nuclear Plant. The end-of-cycle review for Palisades involved the participation of all technical divisions in evaluating performance indicators for the most recent quarter and inspection results for the period from January 1 through December 31, 2003. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.

Overall, Palisades operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter was within the Regulatory Response column of the NRCs Action Matrix, based on one White inspection finding in the Initiating Events cornerstone that was identified in the second quarter of the assessment period. Otherwise, all inspection findings were classified as having very low safety significance (Green) and all performance indicators indicated performance at a level requiring no additional oversight.

Plant performance for the previous three quarters was also within the Regulatory Response Column of the NRCs Action Matrix, based on the White inspection finding discussed above.

Otherwise, all inspection findings were classified as having very low safety significance (Green) and all performance indicators indicated performance at a level requiring no additional oversight.

In our 2002 mid-cycle assessment letter, we advised you of a substantive cross-cutting issue in the area of Problem Identification and Resolution. In particular, we identified that weak corrective action program implementation resulted in the inadequate resolution of equipment problems and the failure to recognize adverse performance trends. In our 2002 annual assessment letter, we indicated that this cross-cutting issue would remain open because we continued to identify corrective action implementation issues, and because some corrective action program improvements had only recently been implemented. In our 2003 mid-cycle

D. Malone assessment letter, this cross-cutting issue remained open due to the continued identification of examples where the corrective action program failed to promptly identify and correct conditions adverse to quality. During this assessment period, we noted that the number of findings in the area of Problem Identification and Resolution had decreased since the substantive cross-cutting issue was discussed in the 2003 mid-cycle assessment letter. Therefore, this Problem Identification and Resolution substantive cross-cutting issue was closed.

The enclosed inspection plan details the inspections scheduled through September 30, 2005.

This inspection plan includes an inspection activity to be accomplished in accordance with Inspection Procedure 95001, Inspection For One Or Two White Inputs In A Strategic Performance Area, to review the circumstances and corrective actions to address the White finding identified during this annual assessment period. In addition, we also plan to conduct inspections of your independent spent fuel storage facility. The specific dates of these inspections will be coordinated with your staff. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 12 months of the inspection plan are tentative and may be revised at the mid-cycle review meeting. As you are aware, the NRC has issued several Orders and threat advisories to enhance security capabilities and improve guard force readiness since the terrorist attacks on September 11, 2001. We have conducted inspections to review your implementation of these requirements and have monitored your actions in response to changing threat conditions. For calendar year 2004, we plan to continue inspections of order implementation combined with newly developed portions of the security baseline inspection program.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made 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).

D. Malone If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Eric Duncan, Chief, Reactor Projects Branch 6 at (630) 829-9628 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Steven A. Reynolds, Acting Director Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Palisades Inspection/Activity Plan See Attached Distribution

D. Malone If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Eric Duncan, Chief, Reactor Projects Branch 6 at (630) 829-9628 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Steven A. Reynolds, Acting Director Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Palisades Inspection/Activity Plan See Attached Distribution DOCUMENT NAME: G:\Branch TSS\EOC Ltrs\eoc 030404\Pal EOC ltr 2004.wpd To receive a copy of this document, indicate in the box "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII RIII NAME EDuncan/co SReynolds DATE 02/24/04 03/2/04 OFFICIAL RECORD COPY

D. Malone cc w/encl: J. Cowan, Executive Vice President and Chief Nuclear Officer R. Fenech, Senior Vice President, Nuclear Fossil and Hydro Operations D. Cooper, Senior Vice President - Group Operations Manager, Regulatory Affairs J. Rogoff, Esquire, Vice President, Counsel and Secretary A. Udrys, Esquire, Consumers Energy Company Director of Nuclear Assets, Consumers Energy Company Supervisor, Covert Township Office of the Governor Michigan Department of Environmental Quality -

Waste and Hazardous Materials Division Michigan Department of Attorney General The Honorable Norm Johnson L. Nielsen, City Manager of Bangor The Honorable Ted Johnson Y. Akinwale, City Manager of Hartford The Honorable Dale Lewis K. Anderson, City Manager of South Haven M. Lombardo, Administrator, Allegan County Courthouse B. Koops, Allegan County Sheriff B. Brunett, Allegan County Emergency Management Coordinator J. M. Henry, Berrien County Coordinator L. P. Bailey, Berrien County Sheriff M. Bradley, Berrien County Emergency Management Director D. DeLeo, Van Buren County Board Chairman D. R. Gribler, Van Buren County Sheriff Sergeant Alaine Svilpe, Van Buren County Emergency Preparedness Coordinator The Honorable A. Gagliardo, Jr.

The Honorable Charles Owen INPO

D. Malone ADAMS Distribution:

WDR DFT JHE DWW Project Director, NRR Project Mgr., NRR RidsNrrDipmlipb JLC GEG HBC RML2 SRI Palisades DRPIII DRSIII PLB1 JRK1

Page 1 of 2 Palisades 03/01/2004 08:02:40 Inspection / Activity Plan Report 22 03/01/2004 - 09/30/2005 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type PI&R - PI&R INSPECTION 4 1 IP 71152B Identification and Resolution of Problems 02/23/2004 03/05/2004 Baseline Inspections IP 71122 - RP RAM PROCESS/TRANSPORTATION INSP 1 1 IP 7112202 Radioactive Material Processing and Transportation 03/01/2004 03/05/2004 Baseline Inspections ISFSI - ONSITE FAB AND CONSTRUCTION OF ISFSI 1 1 IP 60853 On-Site Fabrication Of Components And Construction On An ISFSI 03/01/2004 05/31/2004 Other Routine IP 95001 - IP 95001 INSPECTION FOR WHITE FINDING 1 1 IP 95001 Supplemental Inspection For One Or Two White Inputs In A Strategic Performance Area 03/08/2004 04/09/2004 Supplemental Progra SSDI - SAFETY SYSTEM DESIGN 6 1 IP 7111121 Safety System Design and Performance Capability 03/22/2004 04/09/2004 Baseline Inspections 71111.11 - LIC OPERATOR REQUAL PROGRAM EVALUATION 2 1 IP 7111111B Licensed Operator Requalification Program 03/22/2004 03/26/2004 Baseline Inspections IP 71121 - RP INSTRUMENTATION INSPECTION 1 1 IP 7112101 Access Control to Radiologically Significant Areas 05/17/2004 05/21/2004 Baseline Inspections 1 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 05/17/2004 05/21/2004 Baseline Inspections ISFSI - PREOP TEST OF ISFSI 1 1 IP 60854 Preoperational Testing Of An ISFSI 06/01/2004 06/30/2004 Other Routine ISFSI - OPERATION OF ISFSI 1 1 IP 60855 Operation Of An ISFSI 07/01/2004 07/31/2004 Other Routine IP 71121 - RP PROT EQUIP/ACCESS CTRL INSPECTION 1 1 IP 7112101 Access Control to Radiologically Significant Areas 07/12/2004 07/16/2004 Baseline Inspections 1 IP 7112102 ALARA Planning and Controls 07/12/2004 07/16/2004 Baseline Inspections 1 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 07/12/2004 07/16/2004 Baseline Inspections 1 IP 71151 Performance Indicator Verification 07/12/2004 07/16/2004 Baseline Inspections 71114 - BASELINE EP EXERCISE INSP 4 1 IP 7111401 Exercise Evaluation 08/16/2004 08/20/2004 Baseline Inspections 1 IP 71151 Performance Indicator Verification 08/16/2004 08/20/2004 Baseline Inspections ISI/TI - INSERVICE INSPECTION & TI-150 3 1 IP 2515/150 Reactor Pressure Vessel Head and Vessel Head Penetration Nozzles (NRC Bulletin 2002-0 09/20/2004 10/15/2004 Safety Issues 1 IP 7111108P Inservice Inspection Activities - PWR 09/20/2004 10/15/2004 Baseline Inspections IP 71121 - RP OUTAGE ALARA & ACCESS CONTROL INSP 1 1 IP 7112101 Access Control to Radiologically Significant Areas 09/27/2004 10/01/2004 Baseline Inspections 1 IP 7112102 ALARA Planning and Controls 09/27/2004 10/01/2004 Baseline Inspections IP 71121 - RP POST-OUTAGE ALARA & ACCESS CNTRL INSP 1 1 IP 7112101 Access Control to Radiologically Significant Areas 12/13/2004 12/17/2004 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Palisades 03/01/2004 08:02:40 Inspection / Activity Plan Report 22 03/01/2004 - 09/30/2005 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type IP 71121 - RP POST-OUTAGE ALARA & ACCESS CNTRL INSP 1 1 IP 7112102 ALARA Planning and Controls 12/13/2004 12/17/2004 Baseline Inspections 1 IP 71151 Performance Indicator Verification 12/13/2004 12/17/2004 Baseline Inspections FPI - TRIENNIAL FIRE PROTECTION INSPECTION 3 1 IP 7111105T Fire Protection 01/10/2005 01/28/2005 Baseline Inspections FY 2005 - PALISADES INIT PREP 04/2005 3 1 W90126 OL - INITIAL EXAM - PALISADES - APR/MAY 2005 04/25/2005 04/29/2005 Not Applicable IP 71121 - RP ACCESS CTRL/ALARA INSPECTION 1 1 IP 7112101 Access Control to Radiologically Significant Areas 04/25/2005 04/29/2005 Baseline Inspections 1 IP 7112102 ALARA Planning and Controls 04/25/2005 04/29/2005 Baseline Inspections 1 IP 71151 Performance Indicator Verification 04/25/2005 04/29/2005 Baseline Inspections FY 2005 - PALISADES INIT EXAM 05/2005 3 1 W90126 OL - INITIAL EXAM - PALISADES - APR/MAY 2005 05/23/2005 06/03/2005 Not Applicable 71114 - BASELINE EP INSPECTION 1 1 IP 7111402 Alert and Notification System Testing 06/27/2005 07/01/2005 Baseline Inspections 1 IP 7111403 Emergency Response Organization Augmentation Testing 06/27/2005 07/01/2005 Baseline Inspections 1 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 06/27/2005 07/01/2005 Baseline Inspections 1 IP 71151 Performance Indicator Verification 06/27/2005 07/01/2005 Baseline Inspections IP 71121 - RP ACCESS CTRL/ALARA INSPECTION 1 1 IP 7112101 Access Control to Radiologically Significant Areas 06/27/2005 07/01/2005 Baseline Inspections 1 IP 7112102 ALARA Planning and Controls 06/27/2005 07/01/2005 Baseline Inspections MAINT - BIENNIAL MAINTENANCE RULE INSPECTION 1 1 IP 7111112B Maintenance Effectiveness 08/29/2005 09/02/2005 Baseline Inspections IP 71122 - RP REMP/RAM CONTROL INSPECTION 1 1 IP 7112203 Radiological Environmental Monitoring Program 08/29/2005 09/02/2005 Baseline Inspections 1 IP 71151 Performance Indicator Verification 08/29/2005 09/02/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.