ML092440376

Palisades - Mid-Cycle Performance Review and Inspection Plan

ML092440376
Person / Time
Site:	Palisades
Issue date:	09/01/2009
From:	Khadijah West Division Reactor Projects III
To:	Schwarz C Entergy Nuclear Operations
References
FOIA/PA-2010-0209
Download: ML092440376 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 September 1, 2009 Mr. Christopher J. Schwarz Vice President, Operations Entergy Nuclear Operations, Inc.

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

SUBJECT:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -

PALISADES NUCLEAR PLANT

Dear Mr. Schwarz:

On August 20, 2009, the NRC staff completed its performance review of Palisades Nuclear Plant. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from July 1, 2008, through June 30, 2009. 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.

This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only--Security Information" will include the security cornerstone review and resultant inspection plan.

Plant performance for the most recent quarter at Palisades Nuclear Plant was within the Regulatory Response column of the NRC=s Action Matrix, based on one inspection finding in the Occupational Radiation Safety cornerstone being classified as having low to moderate safety significance (White). This White finding, from the fourth quarter of 2008, involved failure to recognize and assess the impact of radiological hazards in the work place. On August 12, we were notified by your staff of your readiness for the NRC to conduct a supplemental inspection to review the actions taken to address this White finding. We started our supplemental inspection (95001) in response to this White finding on August 31, 2009. This is an addition to the reactor oversight process (ROP) baseline inspections at your facility.

C. Schwarz In addition, we have identified a substantive cross-cutting issue (SCCI) in the area of human performance (HP) with a cross-cutting theme in the aspect of planning (H.3(a)). During this assessment period, there were 12 findings documented with cross-cutting aspects in the HP area. Four of the findings shared a common cross-cutting aspect of H.3(a) and were from different cornerstones. We have a concern with your progress in addressing this issue; specifically, you were late in identifying the cross-cutting trend.

In the 2008 End-of-Cycle assessment, we advised you of a SCCI in the area of HP with a cross-cutting theme in the aspect of documentation/procedures (H.2(c)). During this period, the number of findings with the same cross-cutting aspect of H.2(c) was reduced. However, the root cause was not completed until recently. Additionally, although you have initiated new, comprehensive measures to address this issue, many of these corrective actions have not yet been implemented, nor has enough data been gathered to gauge their effectiveness. As a result, the SCCI will remain open.

The SCCI will remain open until all cross-cutting themes have been cleared in the area of HP.

To clear each theme, we will assess whether your corrective actions have resulted in a positive sustainable improvement in the area and will consider the number of findings in the theme.

Because you have a substantive cross-cutting issue in the area of HP with the same cross-cutting aspect of H.2(c) for two consecutive assessment cycles, we are requesting you provide a response at a public meeting with your actions undertaken, those actions planned to address the concern, and a current assessment of performance. Additionally, you requested a public meeting to discuss this substantive cross-cutting issue. The meeting is scheduled for September 24 at the Region 3 office. The meeting notice was posted on August 24, 2009 (ADAMS ML092330952).

The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through December 31, 2010. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the End-of-Cycle review.

In accordance with 10 CFR 2.390 of the NRC=s ARules 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).

C. Schwarz If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact John (Jack) B. Giessner at 630-829-9619 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

K. Steven West, Director Division of Reactor Projects Docket No. 50-255;72-007 License No. DPR-20

Enclosure:

Palisades Inspection/Activity Plan cc w/encl: 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 Michigan Department of Environmental Quality Michigan Office of the Attorney General Mayor of Bangor City Manager of Bangor Mayor of Hartford City Manager of Hartford Mayor of South Haven City Manager of South Haven Administrator, Allegan County Allegan County Sheriff Allegan County Emergency Management Coordinator County Coordinator Berrien County Sheriff Director, Berrien County Emergency Management Agency Chairman, Van Buren County Board Van Buren County Sheriff Director, Van Buren County Emergency Management Agency Mayor of Watervliet Mayor of Coloma G. Mortensen, INPO

Letter to C. Schwarz from K. Steven West dated September 1, 2009

SUBJECT:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -

PALISADES NUCLEAR PLANT DISTRIBUTION:

Susan Bagley RidsNrrDorlLpl3-1 RidsNrrPMPalisades Resource RidsNrrDirsIpob Resource Cynthia Pederson Steven Orth Jared Heck Allan Barker DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource

C. Schwarz If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact John (Jack) B. Giessner at 630-829-9619 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

K. Steven West, Director Division of Reactor Projects Docket No. 50-255;72-007 License No. DPR-20

Enclosure:

Palisades Inspection/Activity Plan cc w/encl: 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 Michigan Department of Environmental Quality Michigan Office of the Attorney General Mayor of Bangor City Manager of Bangor Mayor of Hartford City Manager of Hartford Mayor of South Haven City Manager of South Haven Administrator, Allegan County Allegan County Sheriff Allegan County Emergency Management Coordinator County Coordinator Berrien County Sheriff Director, Berrien County Emergency Management Agency Chairman, Van Buren County Board Van Buren County Sheriff Director, Van Buren County Emergency Management Agency Mayor of Watervliet Mayor of Coloma G. Mortensen, INPO

See Previous Concurrences DOCUMENT NAME: G:\Branch TSS\ALL MOC\midcycle 2008 to 2009/Mid-cycle letters/

Palisades 2009 MOC Letter.doc G Publicly Available G Non-Publicly Available G Sensitive G 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 RIII NAME Tran:dtp* JGiessner* KSWest DATE 08/26/09 08/26/09 08/30/09 OFFICIAL RECORD COPY

Palisades Inspection / Activity Plan 09/01/2009 - 12/31/2010 Planned Dates No. of Staff Start End Inspection Activity Title on Site RP SUP - SIUPPLEMENTAL FOR RP ISSUES 2 08/31/2009 09/04/2009 IP 95001 Supplemental Inspection For One Or Two White Inputs In A Strategic Performance Area BI EP - EP ROUTINE INSPECTION / PI VERIFICATION 1 10/19/2009 10/23/2009 IP 2515/175 Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review 10/19/2009 10/23/2009 IP 7111402 Alert and Notification System Testing 10/19/2009 10/23/2009 IP 7111403 Emergency Response Organization Augmentation Testing 10/19/2009 10/23/2009 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 10/19/2009 10/23/2009 IP 71151-EP01 Drill/Exercise Performance 10/19/2009 10/23/2009 IP 71151-EP02 ERO Drill Participation 10/19/2009 10/23/2009 IP 71151-EP03 Alert & Notification System BI ENG - ENGINEERING MODIFICATIONS / 50.59 INSP. 4 11/02/2009 11/20/2009 IP 7111117T Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 12/14/2009 12/18/2009 IP 2515/173 Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative 12/14/2009 12/18/2009 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems PI&R - BIENNIAL PROBLEM IDENTIFICATION AND RESO 5 01/11/2010 01/29/2010 IP 71152B Identification and Resolution of Problems BI OL - LIC. OPERATOR REQUAL. PROGRAM EVALUATION 2 02/08/2010 02/12/2010 IP 7111111B Licensed Operator Requalification Program BI EP - EP EXERCISE INSPECTION / PI VERIFICATION 3 03/01/2010 03/05/2010 IP 7111401 Exercise Evaluation 03/01/2010 03/05/2010 IP 71151-EP01 Drill/Exercise Performance 03/01/2010 03/05/2010 IP 71151-EP02 ERO Drill Participation 03/01/2010 03/05/2010 IP 71151-EP03 Alert & Notification System BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 03/08/2010 03/12/2010 IP 7112202 Radioactive Material Processing and Transportation BI ENG - TRIENNIAL HEAT SINK INSPECTION 2 05/24/2010 05/28/2010 IP 7111107T Heat Sink Performance BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 05/24/2010 05/28/2010 IP 7112203 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 07/26/2010 07/30/2010 IP 7112101 Access Control to Radiologically Significant Areas 07/26/2010 07/30/2010 IP 71151-BI01 Reactor Coolant System Activity 07/26/2010 07/30/2010 IP 71151-OR01 Occupational Exposure Control Effectiveness 07/26/2010 07/30/2010 IP 71151-PR01 RETS/ODCM Radiological Effluent

Palisades Inspection / Activity Plan 09/01/2009 - 12/31/2010 Planned Dates No. of Staff Start End Inspection Activity Title on Site OL PREP - PALISADES INIT PREP - JULY 2010 3 07/26/2010 07/30/2010 W90222 OL - INITIAL EXAM - AUG 2010 - PALI RI ENG - TRIENNIAL FIRE INS INFOR GATHERING TRIP 5 08/02/2010 08/06/2010 IP 7111105T Fire Protection [Triennial]

BI ENG - TRIENNIAL FIRE PROTECTION INSPECTION 5 08/16/2010 09/03/2010 IP 7111105T Fire Protection [Triennial]

OL EXAM - PALISADES INIT EXAM - AUG. 2010 3 08/16/2010 08/27/2010 W90222 OL - INITIAL EXAM - AUG 2010 - PALI BI ENG - ENGINEERING INSERVICE INSPECTION 1 10/04/2010 10/29/2010 IP 2515/172 Reactor Coolant System Dissimiliar Metal Butt Welds 10/04/2010 10/29/2010 IP 7111108P Inservice Inspection Activities - PWR RENEWAL - LICENSE RENEWAL 71003 - PHASE 1 2 10/04/2010 10/29/2010 IP 71003 Post-Approval Site Inspection for License Renewal BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 10/18/2010 10/22/2010 IP 7112101 Access Control to Radiologically Significant Areas 10/18/2010 10/22/2010 IP 7112102 ALARA Planning and Controls