ML100610274

EOC Annual Assessment Letter, Inspection/Activity Plan

ML100610274
Person / Time
Site:	Palisades
Issue date:	03/03/2010
From:	Stephanie West Division Reactor Projects III
To:	Schwarz C Entergy Nuclear Operations
References
FOIA/PA-2010-0209
Download: ML100610274 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 March 3, 2010 Mr. Christopher J. Schwarz Vice President, Operations Entergy Nuclear Operations, Inc.

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

SUBJECT:

ANNUAL ASSESSMENT LETTER - PALISADES NUCLEAR PLANT (05000255/2010001)

Dear Mr. Schwarz:

On February 11, 2010, the NRC staff completed its performance review of the Palisades Nuclear Plant. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 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.

Overall, Palisades Nuclear Plant operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter at Palisades was within the Regulatory Response column of the NRCs Action Matrix based on one inspection finding of low-to-moderate safety significance (White) in the Initiating Events Cornerstone, from the fourth quarter of 2009, which involved degradation of the neutron absorption capability of the Spent Fuel Pool plates. Therefore, we plan to conduct a supplemental inspection (95001) in response to the White finding in the Initiating Events Cornerstone. Please notify us of your readiness to conduct this supplemental inspection. This supplemental inspection is in addition to reactor oversight process (ROP) baseline inspections at your facility.

Also, during this assessment period, the White finding in the Occupational Radiation Safety Cornerstone, from the fourth quarter of 2008, which involved the failure to recognize and assess the impact of radiological hazards in the work place, was closed after the successful completion of a supplemental inspection (95001) on September 25, 2009. Therefore, the White finding was no longer considered on the Action Matrix after the third quarter 2009.

C. Schwarz In the 2009 mid-cycle assessment letter dated September 1, 2009 [ADAMS Ref. ML092440376], we advised you of a substantive cross-cutting issue (SCCI) in the area of human performance (HP) with cross-cutting themes in the aspects of documentation/procedures (H.2(c)) and planning (H.3(a)). You have instituted actions to improve performance in these areas. The inspectors reviewed your cause analysis and progress to date on addressing both cross-cutting aspects.

Based on this review, the NRC has gained confidence in your ability to correct the conditions. With respect to the SCCI in the aspect of H.2(c), the NRC noted that you have developed a plan and infrastructure to revise procedures that will correct the SCCI. Even though not many procedures have been revised and some issues remain with those procedures that have been revised, over the past four quarters there have been no findings with a cross-cutting aspect in H.2(c). In addition, the inspectors have noted increased standards and sustained improvement in the use of procedures at the site.

Therefore, the NRC currently has confidence in your ability to fully resolve the issues.

With respect to the SCCI in planning, H.3(a), both the NRC and your organization noted an increase in condition reports reflective of deficiencies in your work planning and preparation process. The NRC evaluated this increase and noted some issues had causal factors associated with the planning cross-cutting aspect. Your staff has identified corrective actions that should reasonably address the SCCI. Additionally, the number of findings with a cross-cutting aspect in planning has been reduced and there have been no findings with that aspect for the previous two quarters. The NRC has confidence in your ability to correct the concerns identified and sustained improvement has been observed in the aspect. Our review of both SCCI themes is documented in Inspection Report 05000255/2009005.

Based on your performance and efforts to programmatically address the cross-cutting issues, we have gained confidence in both your planning techniques and procedure/documentation adequacy during this assessment period. As a result, the human performance substantive cross-cutting issue is closed.

The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through June 30, 2011. We also plan on performing several special and infrequently performed inspections that include: Inspection Procedure (IP) 92709, Licensee Strike Contingency Plans; IP 71003, Post-Approval Site Inspection for License Renewal (Phase 1 and 2); and IP 92702, Follow up on Traditional Enforcement Actions, Including Violations, Deviations, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Action Letters. 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 mid-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/

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: Distribution via ListServ

Palisades Inspection / Activity Plan 03/01/2010 - 06/30/2011 Planned Dates No. of Staff Start End Inspection Activity Title on Site 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 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 03/08/2010 03/12/2010 IP 71151-BI01 Reactor Coolant System Activity 03/08/2010 03/12/2010 IP 71151-PR01 RETS/ODCM Radiological Effluent STRIKE - STRIKE CONTINGENCY - OPS/MAINT 2 05/02/2010 06/01/2010 IP 92709 Licensee Strike Contingency Plans ADR - CONFIRMATORY ORDER FOR ADR 1 05/10/2010 12/10/2010 IP 92702 Followup On Corrective Actions For Violations And Deviations 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 2515/173 Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative 05/24/2010 05/28/2010 IP 71124.07 Public Radiation Safety BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 07/26/2010 07/30/2010 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 07/26/2010 07/30/2010 IP 71124.02 Occupational ALARA Planning and Controls 07/26/2010 07/30/2010 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 07/26/2010 07/30/2010 IP 71124.04 Occupational Dose Assessment 07/26/2010 07/30/2010 IP 71151-OR01 Occupational Exposure Control Effectiveness 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

Palisades Inspection / Activity Plan 03/01/2010 - 06/30/2011 Planned Dates No. of Staff Start End Inspection Activity Title on Site BI ENG - ENGINEERING INSERVICE INSPECTION 1 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 10/04/2010 10/08/2010 IP 2515/179 Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in NSTS 10/04/2010 10/08/2010 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 10/04/2010 10/08/2010 IP 71124.02 Occupational ALARA Planning and Controls RENEWAL - LICENSE RENEWAL 71003 - PHASE 2 2 01/24/2011 02/11/2011 IP 71003 Post-Approval Site Inspection for License Renewal BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 02/14/2011 02/18/2011 IP 71124.05 Radiation Monitoring Instrumentation BI ENG - COMPONENT DESIGN BASES INSPECTION 6 03/26/2011 04/29/2011 IP 7111121 Component Design Bases Inspection BI EP - EP ROUTINE INSPECTION / PI VERIFICATION 2 04/11/2011 04/15/2011 IP 7111402 Radiological Environmental Monitoring Program 04/11/2011 04/15/2011 IP 7111403 Emergency Response Organization Augmentation Testing 04/11/2011 04/15/2011 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 04/11/2011 04/15/2011 IP 71151-EP01 Drill/Exercise Performance 04/11/2011 04/15/2011 IP 71151-EP02 ERO Drill Participation 04/11/2011 04/15/2011 IP 71151-EP03 Alert & Notification System BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 04/25/2011 04/29/2011 IP 71124.04 Occupational Dose Assessment 04/25/2011 04/29/2011 IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment 04/25/2011 04/29/2011 IP 71151-BI01 Reactor Coolant System Activity 04/25/2011 04/29/2011 IP 71151-PR01 RETS/ODCM Radiological Effluent

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/

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: Distribution via ListServ DOCUMENT NAME: G:\1-Secy\1-Work in Progress\2009 EOC Letters\Palisades 2009 EOC Letter Final.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 DBetancourt- JGiessner SWest Roldan:dtp*JAG for DATE 02/23/10 02/23/10 03/03/10 OFFICIAL RECORD COPY

Letter to C. Schwarz from S. West dated March 3, 2010.

SUBJECT:

ANNUAL ASSESSMENT LETTER - PALISADES NUCLEAR PLANT (05000255/2010001)

DISTRIBUTION:

Susan Bagley RidsNrrDorlLpl3-1 RidsNrrPMPalisades Resource RidsNrrDirsIpab Resource Cynthia Pederson Steven Orth Jared Heck Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource