ML14245A298

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Mid-Cycle Assessment Letter for Palisades Nuclear Plant
ML14245A298
Person / Time
Site: Palisades 
(DPR-020)
Issue date: 09/02/2014
From: Eric Duncan
Region 3 Branch 3
To: Vitale A
Entergy Nuclear Operations
References
Download: ML14245A298 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 September 2, 2014 Mr. Anthony Vitale Vice President, Operations Entergy Nuclear Operations, Inc.

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

SUBJECT:

MID-CYCLE ASSESSMENT LETTER FOR PALISADES NUCLEAR PLANT

Dear Mr. Vitale:

On August 5, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed its mid-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 July 1, 2013, through June 30, 2014. 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 was operated in a manner that preserved public health and safety and met all cornerstone objectives. The NRC determined the performance at Palisades Nuclear Plant during the most recent quarter as well as the previous three quarters of the assessment period 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.

On February 26, 2014, the NRC completed a limited-scope Problem Identification and Resolution (PI&R) inspection focused on Safety Conscious Work Environment (SCWE) issues at Palisades Nuclear Plant. Based on the inspection, the NRC identified a chilled work environment within the Security Department. The security staff interviewed expressed reservations about raising issues or concerns for fear of retaliation. Palisades subsequently developed the Security SCWE Action Plan to address the issues identified by the NRC. The NRC reviewed the effectiveness of actions taken to address the SCWE concerns within the Security Department as part of its May 2014 PI&R inspection. The PI&R inspection determined that although all the actions were being completed in accordance with the Action Plan, actions had been insufficient to understand the cause of the chilled work environment within the Security Department and did not convey a strong commitment to improving Security Department SCWE. In the associated PI&R Inspection Report, the NRC requested a written response outlining additional actions taken or planned by Palisades to improve the SCWE in the Security

Department. On July 18, 2014 you provided this information. The NRC will review the status of the SCWE within the Palisades Security Department using Inspection Procedure 93100, Safety-Conscious Work Environment Issue of Concern Followup, later this year.

In March 2014, the NRC completed an investigation of an issue involving a security manager assigning a supervisor to duties for which the supervisor was not fully qualified for a two hour period. A Confirmatory Order was developed using the Alternative Dispute Resolution process to address this issue. This order was issued on July 21, 2014, by NRC letter, Confirmatory Order Related to NRC Report No. 05000255/2014406 and OI Report 3-2013-018; Palisades Nuclear Plant, (Accession Number ML14203A082). The NRC will review the implementation of the Confirmatory Order using Inspection Procedure 92702, Followup on Corrective Actions for Violations and Deviations.

As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised. All cross-cutting aspects identified during inspections conducted in calendar year 2014 reflect this revision to Inspection Manual Chapter (IMC) 0310.

Cross-cutting aspects identified in 2013 using the 2013 terminology were converted to the latest revision in accordance with the cross-reference in IMC 0310 during the mid-cycle assessment review and evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305.

The enclosed inspection plan lists the inspections scheduled through December 31, 2015.

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

The inspections listed during the last nine months of the inspection plan are tentative and may be revised at the end-of-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.

The NRC plans to conduct infrequently performed inspection activities in accordance with Inspection Procedure 60854.1, Pre-Operational Testing of ISFSI [Independent Spent Fuel Storage Installation] at Operating Plants; Inspection Procedure 60855.1, Operation of an ISFSI at Operating Plants, related to your ISFSI; and as described above, Inspection Procedures 92702 and 93100. Following the Inspection Procedure 93100 inspection, we will determine if additional NRC oversight regarding SCWE at Palisades is warranted.

In response to the accident at Fukushima, the Commission issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, which requires licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event. Additionally, the Commission issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, which requires licensees to have a reliable means of remotely monitoring wide-range Spent Fuel Pool levels to support effective prioritization of event mitigation and recovery actions in the event of a beyond-design-basis external event. The NRC is conducting audits of licensee efforts towards compliance with these Orders. This audit includes an onsite

component in order for the NRC to evaluate licensee plans for complying with the Orders, as described in site-specific submittals, and to receive and review information relative to associated open items. This onsite activity will occur in the months prior to a declaration of compliance for the first unit at each site, and will aid staff in development of an ultimate Safety Evaluation for the site. The date for the on-site component at your site is being coordinated with your staff.

A site-specific audit plan for the visit will be provided in advance to allow sufficient time for preparations.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management 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 me at 630-829-9620 with any questions you have regarding this letter.

Sincerely,

/RA/

Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Palisades Nuclear Plant Inspection/Activity Plan cc w/encl: Distribution via LISTSERV

component in order for the NRC to evaluate licensee plans for complying with the Orders, as described in site-specific submittals, and to receive and review information relative to associated open items. This onsite activity will occur in the months prior to a declaration of compliance for the first unit at each site, and will aid staff in development of an ultimate Safety Evaluation for the site. The date for the on-site component at your site is being coordinated with your staff.

A site-specific audit plan for the visit will be provided in advance to allow sufficient time for preparations.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management 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 me at 630-829-9620 with any questions you have regarding this letter.

Sincerely,

/RA/

Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket No. 50-255 License No. DPR-20

Enclosure:

Palisades Nuclear Plant Inspection/Activity Plan cc w/encl: Distribution via LISTSERV DISTRIBUTION w/encl:

Anthony Bowers RidsNrrPMPalisades Resource RidsNrrDorlLpl3-1 Resource RidsNrrDirsIrib Resource Cynthia Pederson Darrell Roberts Steven Orth Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Carmen Olteanu ROPassessment.Resource@nrc.gov DOCUMENT NAME: Palisades MOC Letter Publicly Available Non-Publicly Available Sensitive 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 RIII NAME EDuncan:rj DATE 08/25/14 OFFICIAL RECORD COPY

Page 1 of 2 08/29/2014 08:51:51 Report 22 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Palisades Inspection / Activity Plan 09/01/2014 - 12/31/2015 BI ENG

- COMPONENT DESIGN BASIS INSPECTION 6

1 IP Component Design Bases Inspection 7111121 09/08/2014 10/10/2014 BI EPX

- EP EXERCISE INSPECTION / PI VERIFICATION 2

1 IP Exercise Evaluation - Scenario Review 7111408 08/27/2014 10/31/2014 1

IP Exercise Evaluation - Hostile Action (HA) Event 7111407 10/27/2014 10/31/2014 1

IP Performance Indicator Verification 71151 10/27/2014 10/31/2014 ISFSI

- ISFSI REVIEW OF CFR 72.212(B) EVALS 3

1 IP Review of 10 CFR 72.212(b) Evaluations at Operating Plants 60856.1 09/01/2014 11/28/2014 OL EXAM

- INIT EXAM FOR 09/2014 3

1 OL - INITIAL EXAM - 2014 JUN-FEB - PALI W90308 09/08/2014 09/12/2014 FOLLOWUP - SAFETY CONSCIOUS WORK ENVIRONMENT FOLLOW 1

1 IP Safety-Conscious Work Environment Issue of Concern Followup 93100 11/17/2014 12/12/2014 ISFSI

- ISFSI INSPECTION - SCHEDULE DEPENDENT 1

1 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 11/01/2014 11/30/2014 BI RP

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP Occupational ALARA Planning and Controls 71124.02 12/01/2014 12/05/2014 1

IP 71151-BI01 12/01/2014 12/05/2014 1

IP 71151-OR01 12/01/2014 12/05/2014 1

IP 71151-PR01 12/01/2014 12/05/2014 BI RP

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 71124.08 01/12/2015 01/16/2015 ISFSI

- ISFSI PREOP TESTING - SCHEDULE DEPENDENT 1

1 IP Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants 60854.1 03/01/2015 05/30/2015 BI FIRE

- FIRE PROTECTION INSPECTION AND BAG TRIP 3

1 IP Fire Protection [Triennial]

7111105T 03/16/2015 04/17/2015 BI RP

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP Radiation Monitoring Instrumentation 71124.05 03/30/2015 04/03/2015 ISFSI

- ISFSI OPERATION - SCHEDULE DEPENDENT 2

1 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 05/01/2015 06/30/2015 BI EPR

- EP ROUTINE INSPECTION / PI VERIFICATION 2

1 IP Alert and Notification System Testing 7111402 06/01/2015 06/05/2015 1

IP Emergency Preparedness Organization Staffing and Augmentation System 7111403 06/01/2015 06/05/2015 1

IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 06/01/2015 06/05/2015 This report does not include INPO and OUTAGE activities.

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

Page 2 of 2 08/29/2014 08:51:51 Report 22 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Palisades Inspection / Activity Plan 09/01/2014 - 12/31/2015 BI EPR

- EP ROUTINE INSPECTION / PI VERIFICATION 2

1 IP Performance Indicator Verification 71151 06/01/2015 06/05/2015 BI RP

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP Radioactive Gaseous and Liquid Effluent Treatment 71124.06 07/13/2015 07/17/2015 1

IP 71151-BI01 07/13/2015 07/17/2015 1

IP 71151-OR01 07/13/2015 07/17/2015 1

IP 71151-PR01 07/13/2015 07/17/2015 BI ISI

- ISI INSPECTION 1

1 IP Inservice Inspection Activities - PWR 7111108P 09/15/2015 10/15/2015 BI RP

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP Radiological Hazard Assessment and Exposure Controls 71124.01 10/05/2015 10/09/2015 BI ENG

- TRIENNIAL HEAT SINK INSPECTION 3

1 IP Heat Sink Performance 7111107T 11/16/2015 11/20/2015 This report does not include INPO and OUTAGE activities.

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