ML082980456

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Letter to C. Schwarz Regarding Entergy Nuclear Operations, Inc. Response to NCV of TS 5.4.1 Regarding Guidance to Ensure Actions Required by TS 3.0.4 & Request That the NRC Engage the Industry in Discussions on TS 3.0.4
ML082980456
Person / Time
Site: Palisades  Entergy icon.png
Issue date: 10/23/2008
From: Jack Giessner
Reactor Projects Region 3 Branch 4
To: Schwarz C
Entergy Nuclear Operations
References
Download: ML082980456 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 October 23, 2008 Mr. Christopher J. Schwarz Vice President, Operations Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

ENTERGY NUCLEAR OPERATIONS, INC. (ENO) RESPONSE TO NON-CITED VIOLATION (NCV) OF TECHNICAL SPECIFICATION (TS) 5.4.1 REGARDING GUIDANCE TO ENSURE ACTIONS REQUIRED BY TS 3.0.4 AND REQUEST THAT THE NRC ENGAGE THE INDUSTRY IN DISCUSSIONS ON TS 3.0.4

Dear Mr. Schwarz:

On May 15, 2008, the Nuclear Regulatory Commission (NRC) issued the Palisades Nuclear Plant NRC Integrated Inspection Report 05000255/2008002. The report included a NCV of TS 5.4.1 for the failure to have adequate procedure guidance for the general operating procedures for mode transition to power operations. Specifically the inspectors found that the general plant operating procedure for mode transition did not have adequate guidance to ensure the actions required by TS 3.0.4 were completed prior to mode transition.

On June 16, 2008, you responded by letter (Agencywide Document Management System (ADAMS) No. ML081690051), stating that ENO did not deny the violation but that ENO believed the decision the plant made described in the NCV was appropriate based on language in the TS and relevant industry documents. In your letter, you provided the rationale for your belief and, because ENO believes the language in the TS and supporting documents can be misinterpreted, you requested the NRC to consider your input, and engage the industry in discussions on TS 3.0.4.

I am copying this response, and thus your request, to the appropriate branches in NRC headquarters, for review and action, as appropriate. You should also be aware that the Technical Specifications Task Force (TSTF) and the Nuclear Energy Institute (NEI) have subsequently engaged the NRC, addressing, among other issues, your concerns with TS 3.0.4. See ADAMS ML082001198 and ML082840103, respectively.

C. Schwarz In accordance with 10 CFR 2.390 of the NRCs Rules 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 System (PARS) component of ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John Giessner Chief, Branch 4 Division of Reactor Projects Docket No. 50-255;72-007 License No. DPR-20 cc:

Senior Vice President Vice President Oversight Senior Manager, Nuclear Safety & Licensing Senior Vice President and COO Assistant General Counsel Manager, Licensing W. DiProfio W. Russell G. Randolph Supervisor, Covert Township Office of the Governor T. Strong, Chief, State Liaison Officer, State of Michigan Michigan Department of Environmental Quality -

Waste and Hazardous Materials Division Michigan Office of the Attorney General

C. Schwarz In accordance with 10 CFR 2.390 of the NRCs Rules 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 System (PARS) component of ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John Giessner Chief, Branch 4 Division of Reactor Projects Docket No. 50-255;72-007 License No. DPR-20 cc:

Senior Vice President Vice President Oversight Senior Manager, Nuclear Safety & Licensing Senior Vice President and COO Assistant General Counsel Manager, Licensing W. DiProfio W. Russell G. Randolph Supervisor, Covert Township Office of the Governor T. Strong, Chief, State Liaison Officer, State of Michigan Michigan Department of Environmental Quality -

Waste and Hazardous Materials Division Michigan Office of the Attorney General DOCUMENT NAME: G:\\PALI\\PAL 07XX08 TS 3_0_4 Issue.doc 9 Publicly Available 9 Non-Publicly Available 9 Sensitive 9 Non-Sensitive To receive a copy of this document, indicate in the concurrence box C = Copy without attach/encl; E = Copy with attach/encl N = No copy OFFICE RIII RIII NRR NAME RTelson:cms JGiessner MChawla, per email DATE 10/22/08 10/23/08 10/23/08 OFFICIAL RECORD COPY

Letter to C. Schwarz from J. Giessner dated October 23, 2008

SUBJECT:

ENTERGY NUCLEAR OPERATIONS, INC. (ENO) RESPONSE TO NON-CITED VIOLATION (NCV) OF TECHNICAL SPECIFICATION (TS) 5.4.1 REGARDING GUIDANCE TO ENSURE ACTIONS REQUIRED BY TS 3.0.4 AND REQUEST THAT THE NRC ENGAGE THE INDUSTRY DISTRIBUTION:

Mahesh Chawla Tamara Bloomer RidsNrrDirsIrib Resource Mark Satorius Kenneth Obrien Jared Heck Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak Robert Elliott Martin Murphy Timothy Kobetz