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{{#Wiki_filter:November 20, 2012  
{{#Wiki_filter:November 20, 2012 Mr. Michael Mulligan P.O. Box 161 Hinsdale, NH 03451
 
Mr. Michael Mulligan P.O. Box 161  
 
Hinsdale, NH 03451  


==Dear Mr. Mulligan:==
==Dear Mr. Mulligan:==


You recently submitted two petitions addressed to Mr. William Borchardt, Executive Director for Operations at the U.S. Nuclear Regulatory Commission (NRC). The petitions were referred to the NRC's Office of Nuclear Reactor Regulation pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 2.206.  
You recently submitted two petitions addressed to Mr. William Borchardt, Executive Director for Operations at the U.S. Nuclear Regulatory Commission (NRC). The petitions were referred to the NRCs Office of Nuclear Reactor Regulation pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 2.206.
 
In your first petition dated June 18, 2012, as revised on June 27, 2012, you requested that the Palisades Nuclear Plant (Palisades) remain shutdown. In the petition, you were critical of Entergy Nuclear, the NRC, and the programmatic aspects of the regulatory program, including the Reactor Oversight Process (ROP). You focused on a leak of the Safety Injection Refueling Water (SIRW) tank at Palisades, but also discussed past events at both Palisades and other Entergy-owned facilities. Finally, you also discussed the lack of an adequate safety culture environment at Palisades.
In your first petition dated June 18, 2012, as revised on June 27, 2012, you requested that the Palisades Nuclear Plant (Palisades) remain shutdown. In the petition, you were critical of Entergy Nuclear, the NRC, and the programmatic aspects of the regulatory program, including the Reactor Oversight Process (ROP). You focused on a leak of the Safety Injection Refueling Water (SIRW) tank at Palisades, but also discussed past events at both Palisades and other Entergy-owned facilities. Finally, you also discussed the lack of an adequate safety culture environment at Palisades.  
You requested that the following actions be taken:
 
(1)   The shutdown resulting from the SIRW tank leak should be categorized as unplanned.
You requested that the following actions be taken:  
(2)   The NRC should move the Palisades performance indicator from Red to the next level V:
 
Unacceptable Performance.
(1) The shutdown resulting from the SIRW tank leak should be categorized as unplanned.  
(3)   An outside authority (not the NRCs Office of the Inspector General (OIG)) should determine why the NRC did not force Palisades (Entergy) to thoroughly investigate the SIRW leak when the leak first appeared.
 
(4)   Top Palisades management staff should be fired and replaced before startup.
(2) The NRC should move the Palisades performance indicator from Red to the next level V: Unacceptable Performance.  
(5)   Entergys corporate nuclear senior staff should be fired and replaced before restart.
 
(6)   The NRC should assign two additional NRC inspectors to Palisades and to the rest of the Entergy nuclear plants.
(3) An outside authority (not the NRC's Office of the Inspector General (OIG)) should determine why the NRC did not force Palisades (Entergy) to thoroughly investigate the SIRW leak when the leak first appeared.  
(7)   A local public oversight panel should be formed around every plant.
 
(8)   An emergency NRC senior official oversight panel should be convened to reform the ROP.
(4) Top Palisades management staff should be fired and replaced before startup.  
 
(5) Entergy's corporate nuclear senior staff should be fired and replaced before restart.  
 
(6) The NRC should assign two additional NRC inspectors to Palisades and to the rest of the Entergy nuclear plants.  
 
(7) A local public oversight panel should be formed around every plant.  
 
(8) An emergency NRC senior official oversight panel should be convened to reform the ROP.
 
(9) A national NRC oversight panel of outsiders (consisting of a mixture of professional and academic people, as well as lay people) should be convened to oversee and report on agency activities.
 
(10) The NRC should perform an analysis to determi ne the cause of the numerous findings of problems with Entergy plants during this inspection reporting cycle.
 
(11) The NRC should evaluate if Region III has enough personnel and resources.  


(9)    A national NRC oversight panel of outsiders (consisting of a mixture of professional and academic people, as well as lay people) should be convened to oversee and report on agency activities.
(10) The NRC should perform an analysis to determine the cause of the numerous findings of problems with Entergy plants during this inspection reporting cycle.
(11) The NRC should evaluate if Region III has enough personnel and resources.
(12) Palisades should remain shutdown until all procedures are fully updated and corrected, all technical and maintenance backlogs are updated and corrected, all training completed, and all reports and safety processes are fully completed and implemented.
(12) Palisades should remain shutdown until all procedures are fully updated and corrected, all technical and maintenance backlogs are updated and corrected, all training completed, and all reports and safety processes are fully completed and implemented.
(13) An independent outside investigation should review the insufficient process outcome of the 2008-2009 Palisades security falsification, investigation, safety survey local and fleet-wide training and safety surveys.
(13) An independent outside investigation should review the insufficient process outcome of the 2008-2009 Palisades security falsification, investigation, safety survey local and fleet-wide training and safety surveys.
(14) President Obama should fire Chairman Jazcko and the four Commissioners. In the second petition dated June 28, 2012, you requested that Palisades remain shutdown. This petition was focused on roof leaks at Palisades, but also discussed past events at both Palisades and other Entergy-owned facilities. You discussed a lack of adequate safety culture environment at Palisades, and were also critical of the NRC staff for "tolerating and covering up" very serious safety problems at Palisades and throughout the Entergy organization. This petition also included specific questions related to roof leaks.
(14) President Obama should fire Chairman Jazcko and the four Commissioners.
In the second petition dated June 28, 2012, you requested that Palisades remain shutdown.
This petition was focused on roof leaks at Palisades, but also discussed past events at both Palisades and other Entergy-owned facilities. You discussed a lack of adequate safety culture environment at Palisades, and were also critical of the NRC staff for tolerating and covering up very serious safety problems at Palisades and throughout the Entergy organization. This petition also included specific questions related to roof leaks.
This petition duplicated many of your requests discussed in the previous petition. However, in your second petition there were new requests which are provided below:
This petition duplicated many of your requests discussed in the previous petition. However, in your second petition there were new requests which are provided below:
(15) Entergy should be prevented from starting up until all the safety problems at the site have been publicly identified and the safety culture repaired.
(15) Entergy should be prevented from starting up until all the safety problems at the site have been publicly identified and the safety culture repaired.
(16) Heads need to roll in Region III and at headquarters for tolerating and covering up these very serious safety problems at Palisades and throughout the Entergy organization. This all has the potential to gravely damage our nation.  
(16) Heads need to roll in Region III and at headquarters for tolerating and covering up these very serious safety problems at Palisades and throughout the Entergy organization. This all has the potential to gravely damage our nation.
 
(17) The NRC should report on why the 2.206 petition process failed, and for the agency to hold officials accountable to the plant employees and me with not doing their jobs in trying to understand what was going on at the site and not repairing the organization at the earliest point.
(17) The NRC should report on why the 2.206 petition process failed, and for the agency to hold officials accountable to the plant employees and me with not doing their jobs in trying to understand what was going on at the site and not repairing the organization at the earliest point.  
(18) A meeting with the Palisades inspector and other inspectors to discuss the conditions of Palisades before the petition board pre-hearing.
 
(18) A meeting with the Palisades inspector and other inspectors to discuss the conditions of Palisades before the petition board pre-hearing.  


Timeline The NRC's Petition Review Board (PRB) met internally on July 10, and July 31, 2012, to discuss your requests for immediate action associated with the two petitions. The PRB denied the requests for immediate action on the basis that no immediate safety concern was identified that would prohibit a Palisades reactor plant startup, or had an effect on the health and safety of the public. There was no new information, or information specific enough, for the NRC to further consider making an immediate action determination. You were informed on July 17, and again on August 8, 2012, of the PRB's decision to deny your request for immediate action related to the two petitions under consideration.  
Timeline The NRCs Petition Review Board (PRB) met internally on July 10, and July 31, 2012, to discuss your requests for immediate action associated with the two petitions. The PRB denied the requests for immediate action on the basis that no immediate safety concern was identified that would prohibit a Palisades reactor plant startup, or had an effect on the health and safety of the public. There was no new information, or information specific enough, for the NRC to further consider making an immediate action determination. You were informed on July 17, and again on August 8, 2012, of the PRBs decision to deny your request for immediate action related to the two petitions under consideration.
On August 8, 2012, the Petition Manager contacted you to discuss the 10 CFR 2.206 process and to offer you an opportunity to address the PRB by phone or in person. You were also informed that the two petitions under consideration would be consolidated because the petitions were submitted at or about the same time; the requested actions were against the same licensee; and, with a few unique issues, addressed essentially the same specific concerns. The Petition Manager informed you that consolidation of the petitions did not reduce the importance of the circumstances being discussed, but streamlined the NRC staffs review process and response.
On August 21, 2012, you had a discussion with members of the Regional staff regarding ongoing issues at Palisades.
On August 29, 2012, you addressed the PRB via teleconference. The official transcript of the teleconference is publicly available in the Agencywide Documents Access and Management System (ADAMS) (Accession No. ML12261A380).
On September 24, 2012, the PRB met internally to review the petitions and make an initial recommendation. The PRB rejected the petition using the criteria of NRC Management Directive (MD) 8.11, Review Process for 10 CFR 2.206 Petitions. The details of the criteria for rejection are provided in Attachment 1.
On September 27, 2012, the Petition Manager provided the PRBs initial recommendation to you and offered a second opportunity to address the PRB. On October 4, 2012, you requested an additional opportunity to address the PRB via teleconference.
On October 24, 2012, you addressed the PRB by teleconference to discuss the PRBs initial recommendation. The official transcript of the teleconference is publicly available in ADAMS (Accession No. ML12320A564).
Reactor Oversight Process The NRCs oversight and inspection of nuclear power plants is a continuous process. The NRC staff evaluates specific violations and the safety risk that these violations present. The NRC conducts these evaluations using the ROP. The NRC staff acknowledges your dissatisfaction with the ROP and many of the final determinations resulting from the process as you discussed in the petitions and during the teleconferences with the NRC. Your concerns were forwarded to the OIG.


On August 8, 2012, the Petition Manager contacted you to discuss the 10 CFR 2.206 process and to offer you an opportunity to address the PRB by phone or in person. You were also informed that the two petitions under consideration would be consolidated because the petitions were submitted at or about the same time; the requested actions were against the same licensee; and, with a few unique issues, addressed essentially the same specific concerns. The Petition Manager informed you that consolidation of the petitions did not reduce the importance of the circumstances being discussed, but streamlined the NRC staff's review process and response.
On August 21, 2012, you had a discussion with members of the Regional staff regarding ongoing issues at Palisades.
On August 29, 2012, you addressed the PRB via teleconference. The official transcript of the teleconference is publicly available in the Agencywide Documents Access and Management System (ADAMS) (Accession No. ML12261A380).
On September 24, 2012, the PRB met internally to review the petitions and make an initial recommendation. The PRB rejected the petition using the criteria of NRC Management Directive (MD) 8.11, "Review Process for 10 CFR 2.206 Petitions."  The details of the criteria for rejection are provided in Attachment 1.
On September 27, 2012, the Petition Manager provided the PRB's initial recommendation to you and offered a second opportunity to address the PRB. On October 4, 2012, you requested an additional opportunity to address the PRB via teleconference.
On October 24, 2012, you addressed the PRB by teleconference to discuss the PRB's initial recommendation. The official transcript of the teleconference is publicly available in ADAMS (Accession No. ML12320A564).
Reactor Oversight Process
The NRC's oversight and inspection of nuclear power plants is a continuous process. The NRC staff evaluates specific violations and the safe ty risk that these violations present. The NRC conducts these evaluations using the ROP. The NRC staff ack nowledges your dissatisfaction with the ROP and many of the final determinations resulting from the process as you discussed in the petitions and during the teleconferences with the NRC. Your concerns were forwarded to the OIG.
Palisades was in Column III (degraded cornerstone) of the ROP action matrix. As a Column III plant, the NRC conducted a supplemental inspection (using Inspection Procedure 95002), in addition to routine ongoing inspections. The inspection was completed on September 28, 2012, and was designed to address the following:
Palisades was in Column III (degraded cornerstone) of the ROP action matrix. As a Column III plant, the NRC conducted a supplemental inspection (using Inspection Procedure 95002), in addition to routine ongoing inspections. The inspection was completed on September 28, 2012, and was designed to address the following:
* Ensure that the root and contributing causes of the performance issue are understood.
* Ensure that the root and contributing causes of the performance issue are understood.
* Identify the extent of condition and extent of cause.
* Identify the extent of condition and extent of cause.
* Determine if safety culture components caused or significantly contributed to the individual and collective risk-significant performance issues, including unplanned shutdowns.
* Determine if safety culture components caused or significantly contributed to the individual and collective risk-significant performance issues, including unplanned shutdowns.
* Provide assurance that corrective actions are sufficient to address the root and contributing causes and prevent recurrence.  
* Provide assurance that corrective actions are sufficient to address the root and contributing causes and prevent recurrence.
 
At the start of the fourth quarter, Palisades transitioned back to Column I following the results of the supplemental inspection. The inspection identified that the licensee has appropriately addressed the Yellow and White findings.
At the start of the fourth quarter, Palisades transitioned back to Column I following the results of the supplemental inspection. The inspection identified that the licensee has appropriately addressed the Yellow and White findings.
The agency is fully aware that Palisades has had a recent number of unanticipated plant shutdowns. Based on the above actions taken by the NRC and the licensee, the agency believes that the performance deficiencies at Palisades have been identified, and that the agency has inspected these deficiencies to ensure that the licensee is taking adequate action. The NRC staff continuously verifies that plant operations are being conducted within the applicable regulatory requirements and within the terms of the operating license, and concludes that Palisades continues to remain safe to operate.  
The agency is fully aware that Palisades has had a recent number of unanticipated plant shutdowns. Based on the above actions taken by the NRC and the licensee, the agency believes that the performance deficiencies at Palisades have been identified, and that the agency has inspected these deficiencies to ensure that the licensee is taking adequate action.
 
The NRC staff continuously verifies that plant operations are being conducted within the applicable regulatory requirements and within the terms of the operating license, and concludes that Palisades continues to remain safe to operate.
Summary The PRB discussed the information you provided in the petitions and arrived at a consensus that you did not provide any additional information to support the petition requests during the teleconferences held on August 29 and October 24, 2012. The PRB's final determination is the same as its initial recommendation. The PRB's final determination is to reject your petition for review under the 10 CFR 2.206 process because it does not meet the criteria for review. provides a summary of the details for rejecting the petitions. Attachment 2 provides a list of publicly available documents and correspondence associated with your petitions. Some issues were outside the scope of the process as described in 10 CFR 2.206, and other issues were already the subject of NRC staff review or res olution had been previously determined in accordance with NRC MD 8.11.
Summary The PRB discussed the information you provided in the petitions and arrived at a consensus that you did not provide any additional information to support the petition requests during the teleconferences held on August 29 and October 24, 2012. The PRBs final determination is the same as its initial recommendation. The PRBs final determination is to reject your petition for review under the 10 CFR 2.206 process because it does not meet the criteria for review. provides a summary of the details for rejecting the petitions. Attachment 2 provides a list of publicly available documents and correspondence associated with your petitions. Some issues were outside the scope of the process as described in 10 CFR 2.206, and other issues were already the subject of NRC staff review or resolution had been previously determined in accordance with NRC MD 8.11. Finally, Attachment 1 also provides additional information as to which of your concerns have been forwarded to the OIG.
Finally, Attachment 1 also provides additional information as to which of your concerns have been forwarded to the OIG.  


Thank you for bringing these issues to the attention of the NRC.
Thank you for bringing these issues to the attention of the NRC.
Sincerely,
Sincerely,
/RA/ Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation  
                                            /RA/
 
Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255 : Table (Summary of Issues) : Documents and Correspondence
Docket No. 50-255
: Table (Summary of Issues) : Documents and Correspondence  


Thank you for bringing these issues to the attention of the NRC.
Thank you for bringing these issues to the attention of the NRC.
Sincerely,
Sincerely,
/RA/ Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation  
                                            /RA/
 
Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255 : Table (Summary of Issues) : Documents and Correspondence DISTRIBUTION: G20120443/EDATS: OEDO-2012-0364 RidsNrrDorl       RidsNrrDorlLpl3-1     RidsNrrPMPalisades           RidsNrrLABTully RidsNrrMailCenter RidsNrrOd             RidsEDOMailCenter           RidsOGCRp Resource RidsOeMailCenter RidsOiMailCenter       RidsOpaMail                 RidsRgn3MailCenter RidsOcaMailCenter PUBLIC                 LPL3-1 R/F MBanic, NRR       JGiessner, RIII       JLennartz, RIII TBeltz, NRR       CHair, OGC           RLerch, R3 Package: ML12321A017 Incoming: ML12177A278 (G20120443/OEDO-2012-0364)
Docket No. 50-255
ML12180A336 (G20120443)
: Table (Summary of Issues) : Documents and Correspondence    
ML12262A355 (G20120443)
 
Transcript: ML12261A380 ML12320A564 Response: ML12320A608
DISTRIBUTION: G20120443/EDATS: OEDO-2012-0364 RidsNrrDorl RidsNrrDorlLpl3-1 RidsNrrPMPalisades RidsNrrLABTully RidsNrrMailCenter RidsNrrOd RidsEDOMailCenter RidsOGCRp Resource RidsOeMailCenter RidsOiMailCenter RidsOpaMail RidsRgn3MailCenter RidsOcaMailCenter PUBLIC LPL3-1 R/F MBanic, NRR JGiessner, RIII JLennartz, RIII TBeltz, NRR CHair, OGC RLerch, R3  
* concurrence via email OFFICE LPL3-1/PM LPL3-1/LA   DPR/PM         R3/DRP/BC     LPL3-1/BC     OGC           NRR/DD NAME   TBeltz     SFigueroa
 
* MBanic
Package:   ML12321A017 Incoming: ML12177A278 (G20120443/OEDO-2012-0364)
ML12180A336 (G20120443) ML12262A355 (G20120443) Transcript: ML12261A380 ML12320A564 Response: ML12320A608
* concurrence via email  OFFICE LPL3-1/PM LPL3-1/LA DPR/PM R3/DRP/BC LPL3-1/BC OGC NRR/DD NAME TBeltz SFigueroa
* for BTully  MBanic
* JLennartz
* JLennartz
* for JGiessner RCarlson CHair * (NLO) MEvans DATE 11/16/12 11/16/12 11/16/12 11/16/12 11/19/12 11/16/12 11/20/12 OFFICIAL RECORD COPY 1  Attachment 1 Table (Summary of Issues)
* RCarlson     CHair * (NLO) MEvans for BTully                for JGiessner DATE   11/16/12   11/16/12   11/16/12       11/16/12     11/19/12     11/16/12     11/20/12 OFFICIAL RECORD COPY
Item(s) Specific Issue Raised Is This Request Outside the Scope of the 2.206 Process? Does This Meet the Criteria for Review? Does This Meet the Criteria for Rejection? (1) The Safety Injection Refueling Water tank shutdown be categorized as an unplanned shutdown Yes No. The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry and, therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.


All the specific issues raised in the support of the requested action have been the subject of NRC staff review and evaluation.  
Attachment 1 Table (Summary of Issues)
Is This Request                                                                                    Does This Specific Issue      Outside the                                                                                        Meet the Item(s)                                                              Does This Meet the Criteria for Review?
Raised          Scope of the                                                                                      Criteria for 2.206 Process?                                                                                      Rejection?
No. The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry and, therefore, this request should not be accepted for review The Safety Injection pursuant to 10 CFR 2.206.
Refueling Water tank (1)  shutdown be                  Yes                                                                                              Yes All the specific issues raised in the support of the requested action have been the categorized as an subject of NRC staff review and evaluation.
unplanned shutdown Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
No. The petitioner does not provide adequate basis and sufficient facts to warrant The NRC should move                    further inquiry and, therefore, this request should not be accepted for review the Palisades                          pursuant to 10 CFR 2.206.
performance indicator (2)  from Red to Level V          Yes      The NRC staff evaluates licensee performance and placement within the Action            Yes
[Column 5]:                            Matrix under the Reactor Oversight Process.
Unacceptable Performance                            Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
An outside authority No. The petitioner does not provide adequate basis and sufficient facts to warrant investigate why the further inquiry and, therefore, this request should not be accepted for review NRC did not make pursuant to 10 CFR 2.206.
Palisades Entergy thoroughly investigate (3)                              Yes      All the specific issues raised in the support of the requested action have been the    Yes the SIRW leak when it subject of NRC staff review and evaluation.
first appeared and ensure it was fixed Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
during the last shutdown period This issue was referred to the Office of the Inspector General (OIG).
1


Is This Request                                                                                  Does This Specific Issue      Outside the                                                                                      Meet the Item(s)                                                              Does This Meet the Criteria for Review?
Raised          Scope of the                                                                                    Criteria for 2.206 Process?                                                                                    Rejection?
No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
Top Palisades management staff                        The petitioners supporting facts are insufficient to warrant further inquiry.
(4)  should be fired and          Yes                                                                                            Yes replaced before                        This request was reviewed by the NRC in accordance with the 2.206 process for startup.                                previous petitions filed by Mr. Mulligan (Attachment 2, Documents and Correspondence, Items 2 and 3)..
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes (2) The NRC should move the Palisades performance indicator from Red to Level V
No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
[Column 5]:
Entergy corporate The petitioners supporting facts are insufficient to warrant further inquiry.
Unacceptable Performance Yes No. The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry and, therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.  
nuclear staff should be (5)                                                                                                                                Yes fired and replaced            Yes This request was reviewed by the NRC in accordance with the 2.206 process for prior to Palisades previous petitions filed by Mr. Mulligan (Attachment 2, Documents and restart.
 
Correspondence, Items 2 and 3).
The NRC staff evaluates licensee performance and placement within the Action Matrix under the Reactor Oversight Process.  
 
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes (3) An outside authority investigate why the NRC did not make Palisades Entergy thoroughly investigate the SIRW leak when it first appeared and ensure it was fixed during the last shutdown period Yes  No. The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry and, therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
No. This is not an enforcement-related action and is outside the scope of the The NRC should                         2.206 process. Therefore, this request should not be accepted for review pursuant assign two additional                  to 10 CFR 2.206.
All the specific issues raised in the support of the requested action have been the subject of NRC staff review and evaluation.
NRC inspectors at (6)                                                                                                                               Yes Palisades, and to all         Yes       This request was reviewed by the NRC in accordance with the 2.206 process for the other troubled                      previous petitions filed by Mr. Mulligan (G20110127 and G20120022)
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Entergy plants.
 
This issue was referred to the Office of the Inspector General (OIG).
Yes 2  Item(s) Specific Issue Raised Is This Request Outside the Scope of the 2.206 Process? Does This Meet the Criteria for Review? Does This Meet the Criteria for Rejection? (4) Top Palisades management staff should be fired and replaced before startup. Yes No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
 
The petitioner's supporting facts are in sufficient to warrant further inquiry.
This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (Attachment 2, "Documents and Correspondence," Items 2 and 3)..
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes (5)  Entergy corporate nuclear staff should be fired and replaced prior to Palisades restart. Yes No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.  
 
The petitioner's supporting facts are in sufficient to warrant further inquiry.
This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (Attachment 2, "Documents and Correspondence," Items 2 and 3).
 
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes (6) The NRC should assign two additional NRC inspectors at Palisades, and to all the other troubled Entergy plants.
Yes No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
 
This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (G20110127 and G20120022)  
 
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes 3  Item(s) Specific Issue Raised Is This Request Outside the Scope of the 2.206 Process? Does This Meet the Criteria for Review? Does This Meet the Criteria for Rejection? (7) Formation of a local public oversight panel around every plant.
2
Yes No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
 
This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (Attachment 2, "Documents and Correspondence," Items 2 and 3).


Is This Request                                                                                  Does This Specific Issue      Outside the                                                                                      Meet the Item(s)                                                              Does This Meet the Criteria for Review?
Raised          Scope of the                                                                                    Criteria for 2.206 Process?                                                                                    Rejection?
No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
Formation of a local This request was reviewed by the NRC in accordance with the 2.206 process for (7)  public oversight panel      Yes                                                                                            Yes previous petitions filed by Mr. Mulligan (Attachment 2, Documents and around every plant.
Correspondence, Items 2 and 3).
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes (8) An emergency NRC senior official oversight panel should be convened to reform the Reactor Oversight Process. Yes No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (Documents and Correspondence Items 2 and 3).
An emergency NRC senior official This request was reviewed by the NRC in accordance with the 2.206 process for oversight panel should (8)                              Yes      previous petitions filed by Mr. Mulligan (Documents and Correspondence Items 2       Yes be convened to reform and 3).
the Reactor Oversight Process.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
This issue was referred to the Office of the Inspector General (OIG).
This issue was referred to the Office of the Inspector General (OIG).
Yes (9) A national NRC oversight panel should be convened to oversee and report on agency activities.
No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant A national NRC                        to 10 CFR 2.206.
Yes  No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
oversight panel should (9)  be convened to              Yes      This request was reviewed by the NRC in accordance with the 2.206 process for         Yes oversee and report on                  previous petitions filed by Mr. Mulligan (Attachment 2, Documents and agency activities.                    Correspondence, Items 2 and 3).
This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (Attachment 2, "Documents and Correspondence," Items 2 and 3).  
 
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes 4  Item(s) Specific Issue Raised Is This Request Outside the Scope of the 2.206 Process? Does This Meet the Criteria for Review? Does This Meet the Criteria for Rejection? (10) The NRC should perform an analysis to determine the cause of the numerous findings of problems with Entergy plants during this inspection reporting cycle.
3
Yes No. The Petitioner refers to findings that are indicative of recurring problems at Palisades and Entergy plants. However, the information discussed in the petition does not appear to provide additional facts beyond what the NRC staff has already reviewed and documented.
The issues raised in the support of the requested action have been the subject of NRC staff review and evaluation.


Is This Request                                                                                    Does This Specific Issue        Outside the                                                                                      Meet the Item(s)                                                                Does This Meet the Criteria for Review?
Raised            Scope of the                                                                                    Criteria for 2.206 Process?                                                                                    Rejection?
No. The Petitioner refers to findings that are indicative of recurring problems at The NRC should Palisades and Entergy plants. However, the information discussed in the petition perform an analysis to does not appear to provide additional facts beyond what the NRC staff has already determine the cause reviewed and documented.
of the numerous (10)                                Yes                                                                                              Yes findings of problems The issues raised in the support of the requested action have been the subject of with Entergy plants NRC staff review and evaluation.
during this inspection reporting cycle.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes (11)  The NRC should
No. This is not an enforcement-related action and is outside the scope of the 2.206 process and, therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
 
The NRC should evaluate if Region III (11)                                Yes      This request was reviewed by the NRC in accordance with the 2.206 process for         Yes has enough personnel previous petitions filed by Mr. Mulligan (Attachment 2, Documents and and resources.
evaluate if Region III has enough personnel and resources.
Correspondence, Items 2 and 3).
Yes No. This is not an enforcement-related action and is outside the scope of the 2.206 process and, therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.  
 
This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (Attachment 2, "Documents and Correspondence," Items 2 and 3).
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes (12) Palisades should remain shutdown until procedures are fully updated and corrected; all technical and maintenance backlogs are updated and corrected; all training is completed;  
Palisades should remain shutdown until procedures are fully updated and                             No. The issues raised in the support of the requested action are subject to corrected; all technical                 continuing NRC staff review and evaluation via the Reactor Oversight Process.
and maintenance backlogs are updated                     The petitioner does not provide adequate basis and sufficient facts to warrant (12)                                  No                                                                                              Yes and corrected; all                       further inquiry.
training is completed; all reports and safety                  Therefore, this request should not be accepted for review pursuant to 10 CFR processes fully                          2.206.
completed and implemented.
4


all reports and safety processes fully completed and implemented.
Is This Request                                                                                    Does This Specific Issue      Outside the                                                                                       Meet the Item(s)                                                               Does This Meet the Criteria for Review?
No No. The issues raised in the support of the requested action are subject to continuing NRC staff review and evaluation via the Reactor Oversight Process.
Raised          Scope of the                                                                                     Criteria for 2.206 Process?                                                                                      Rejection?
The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry.
Request independent outside investigation                   No. The petitioner does not provide adequate basis and sufficient facts to warrant of the 2008-2009                        further inquiry and, therefore, this request should not be accepted for review Palisades security                      pursuant to 10 CFR 2.206.
 
falsification, investigation, safety                  This request was reviewed by the NRC in accordance with the 2.206 process as survey and local and                    discussed in a previous petition filed by Mr. Mulligan (Attachment 2, Documents fleet-wide training and                and Correspondence, Item 3).
Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206. Yes 5  Item(s) Specific Issue Raised Is This Request Outside the Scope of the 2.206 Process? Does This Meet the Criteria for Review? Does This Meet the Criteria for Rejection? (13)  Request independent outside investigation of the 2008-2009 Palisades security falsification, investigation, safety survey and local and fleet-wide training and safety surveys. It appears that the
(13)                                Yes                                                                                              Yes safety surveys. It appears that the                        All the specific issues raised in the support of the requested action have been the safety culture at                      subject of NRC staff review and evaluation.
 
Palisades has been grossly defective and                  Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
safety culture at Palisades has been grossly defective and
ineffectively for many years, along with the                  This issue was referred to the Office of the Inspector General (OIG).
 
ROP.
ineffectively for many years, along with the ROP.
No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
Yes No. The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry and, therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
Replacement of NRC The members of the Commission are Presidential appointees.
This request was reviewed by the NRC in accordance with the 2.206 process as discussed in a previous petition filed by Mr. Mulligan (Attachment 2, "Documents and Correspondence," Item 3).
(14)  Chairman and                  Yes                                                                                              Yes Commissioners This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (Documents and Correspondence Items 2 and 3).
All the specific issues raised in the support of the requested action have been the subject of NRC staff review and evaluation.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.  
 
This issue was referred to the Office of the Inspector General (OIG).
Yes (14) Replacement of NRC Chairman and Commissioners Yes  No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.  
 
The members of the Commission are Presidential appointees.
This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (Documents and Correspondence Items 2 and 3).
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Therefore, this request meets the criteria for rejection as discussed in MD 8.11.
Yes 6  Item(s) Specific Issue Raised Is This Request Outside the Scope of the 2.206 Process? Does This Meet the Criteria for Review? Does This Meet the Criteria for Rejection? (15) Entergy should be prevented from starting up until all the safety problems at the site have been publicly identified and the safety culture repaired. No  No. The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry and, therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
5
All the specific issues raised in the support of the requested action have been the subject of NRC staff review and evaluation, which meets the criteria for rejection as discussed in MD 8.11.
 
Refer to Attachment 2, "Documents and Correspondence," Items 5, 6, 8, 9, 11, 12, 14, 17, 18, 19, and 20.


Is This Request                                                                                    Does This Specific Issue        Outside the                                                                                        Meet the Item(s)                                                                Does This Meet the Criteria for Review?
Raised            Scope of the                                                                                      Criteria for 2.206 Process?                                                                                      Rejection?
No. The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry and, therefore, this request should not be accepted for review Entergy should be                        pursuant to 10 CFR 2.206.
prevented from starting up until all the                All the specific issues raised in the support of the requested action have been the safety problems at the                    subject of NRC staff review and evaluation, which meets the criteria for rejection (15)                                  No                                                                                              Yes site have been publicly                  as discussed in MD 8.11.
identified and the safety culture                            Refer to Attachment 2, Documents and Correspondence, Items 5, 6, 8, 9, 11, 12, repaired.                                14, 17, 18, 19, and 20.
This issue was referred to the Office of the Inspector General (OIG).
This issue was referred to the Office of the Inspector General (OIG).
Yes (16)
Heads need to roll in Region III and Headquarters for tolerating and covering No. This is not an enforcement-related action and is outside the scope of the up these very serious (16)                                  Yes      2.206 process. Therefore, this request should not be accepted for review pursuant      Yes safety problems at to 10 CFR 2.206.
Heads need to roll in Region III and Headquarters for tolerating and covering up these very serious safety problems at Palisades and throughout the Entergy organization.  
Palisades and throughout the Entergy organization.
6


Yes No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.
Is This Request                                                                                  Does This Specific Issue        Outside the                                                                                     Meet the Item(s)                                                                 Does This Meet the Criteria for Review?
Yes 7  Item(s) Specific Issue Raised Is This Request Outside the Scope of the 2.206 Process? Does This Meet the Criteria for Review? Does This Meet the Criteria for Rejection? (17) Report on why the 2.206 petition process f ailed so utterly for us...
Raised            Scope of the                                                                                   Criteria for 2.206 Process?                                                                                    Rejection?
for the agency to hold officials accountable to the plant employees and me with not doing their jobs in trying to understand what was going on at the site and not repairing the organization at the earliest point. The whole Entergy organization is involved and they have a huge costly hole to dig out of.
Report on why the 2.206 petition process failed so utterly for us...
It is easier digging the hole than crawling out of one. Yes No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.  
for the agency to hold officials accountable to the plant employees and me with not doing No. This is not an enforcement-related action and is outside the scope of the their jobs in trying to 2.206 process. Therefore, this request should not be accepted for review pursuant understand what was to 10 CFR 2.206.
 
going on at the site and (17)                                    Yes                                                                                            Yes not repairing the organization at the This issue was referred to the Office of the Inspector General (OIG).
This issue was referred to the Office of the Inspector General (OIG).
earliest point. The whole Entergy organization is involved and they have a huge costly hole to dig out of.
Yes (18) Request a meeting with the Palisades inspectors and other inspectors to discuss the conditions of Palisades before the PRB pre-hearing.
It is easier digging the hole than crawling out of one.
N/A  On August 21, 2012, the Petitioner had a phone call with members of the Regional staff to discuss ongoing issues at Palisades.
Request a meeting with the Palisades inspectors and other On August 21, 2012, the Petitioner had a phone call with members of the Regional (18)    inspectors to discuss          N/A                                                                                            Yes staff to discuss ongoing issues at Palisades.
Yes 1  Attachment 2 DOCUMENTS AND CORRESPONDENCE
the conditions of Palisades before the PRB pre-hearing.
: 1. Letter dated January 10, 2012, from Mike Mulligan to R. William Borchardt re:  10 CFR 2.206 Petition (G20120022/EDATS:  OEDO-2012-0028) Associated with a Request for Emergency Palisades Shutdown (ADAMS Accession No. ML12012A212).
7
: 2. Closure letter dated April 20, 2011, from Thomas Blount to Mr. Michael Mulligan re:  Palisades 2.206 Petition (G20110127/EDATS:  OEDO-2011-0156) Associated with a Request for Immediate Shutdown of Palisades and Other Entergy Plants (ADAMS Accession No. ML111010414).
: 3. Closure letter dated May 21, 2012, from Michael Cheok to Mr. Michael Mulligan re:  Palisades 2.206 Petition (G20120022/EDATS:  OEDO-2012-0028) Associated with a Request for Emergency Palisades Shutdown (ADAMS Accession No. ML111010487).
: 4. Letters dated June 18, 2012, and June 27, 2012 (Rev. 1), from Mike Mulligan to R. William Borchardt re:  10 CFR 2.206 Petition Associated with a Request for Emergency Palisades Shutdown (ADAMS Accession No. ML12177A278 and ML12180A336).
: 5. Letter dated June 22, 2012, from Represent ative Edward J. Markey to Chairman Jaczko re:  Shutdown of Palisades Nuclear Power Plant - Leak in Water Storage Tank (ADAMS Accession No. ML12178A446).
: 6. Letter dated June 26, 2012, from Gary L. Shear to Anthony Vitale re:  Request for Information on Safety Culture Issues at Palisades Nuclear Plant (ADAMS Accession No. ML12179A155).
: 7. Letter dated June 28, 2012, from Mike Mulligan to R. William Borchardt re:  10 CFR 2.206 Petition Associated with Palisades Numerous Roof Leaks (ADAMS Accession No.
ML12262A355).
: 8. Letter dated July 12, 2012, from Anthony J. Vitale to U.S. NRC Document Control Desk re:  Safety Injection Refueling Water Tank Leakage and Corrective Actions (ADAMS Accession No. ML12194A573).
: 9. Confirmatory Action Letter dated July 17, 2012, from Charles A. Casto to Anthony Vitale re:  Palisades Nuclear Plant Commitment to Address Safety Injection Refueling Water Tank and Control Room Concrete Support Structure Leakage (ADAMS Accession No.
ML12199A409).
: 10. Closure letter dated July 29, 2012, from Allen Howe to Thomas Saporito re:  10 CFR 2.206 Petition (G20120149/EDATS:  OEDO-2012-0127) Associated with the Palisades Nuclear Plant (ADAMS Accession No. ML12173A481).


2 11. Letter dated July 31, 2012, from John B.
Attachment 2 DOCUMENTS AND CORRESPONDENCE
Giessner to Anthony J. Vitale re: NRC Supplemental Inspection Report 05000255/2012010, and Assessment Follow-up Letter (ADAMS Accession No. ML12213A225).
: 1. Letter dated January 10, 2012, from Mike Mulligan to R. William Borchardt re: 10 CFR 2.206 Petition (G20120022/EDATS: OEDO-2012-0028) Associated with a Request for Emergency Palisades Shutdown (ADAMS Accession No. ML12012A212).
: 12. Letter dated August 8, 2012, from John B. Giessner to Anthony J. Vitale re: Palisades Nuclear Plant Integrated Inspection Report 05000255/2012003 (ADAMS Accession No. ML12221A340).
: 2. Closure letter dated April 20, 2011, from Thomas Blount to Mr. Michael Mulligan re:
: 13. Letter dated August 15, 2012, from Chairman Macfarlane to Representative Edward J. Markey re: Response to Specific Requests for Information Regarding the Recent Shutdown of the Palisades Nuclear Plant Resulting from a Leak in a Water Storage Tank (ADAMS Accession Package No. ML12191A401).
Palisades 2.206 Petition (G20110127/EDATS: OEDO-2011-0156) Associated with a Request for Immediate Shutdown of Palisades and Other Entergy Plants (ADAMS Accession No. ML111010414).
: 14. Letter dated August 30, 2012, from John B. Giessner to Anthony J. Vitale re: Notification of NRC Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area and Request for Information (ADAMS Accession No. ML12243A409).
: 3. Closure letter dated May 21, 2012, from Michael Cheok to Mr. Michael Mulligan re:
: 15. Transcript from August 29, 2012, Teleconference re: 10 CFR 2.206 Petitions Submitted by Mike Mulligan Related to the Palisades Nuclear Plant (ADAMS Accession No.
Palisades 2.206 Petition (G20120022/EDATS: OEDO-2012-0028) Associated with a Request for Emergency Palisades Shutdown (ADAMS Accession No. ML111010487).
ML12261A380).
: 4. Letters dated June 18, 2012, and June 27, 2012 (Rev. 1), from Mike Mulligan to R.
: 16. Transcript from October 24, 2012, Teleconference re: 10 CFR 2.206 Petition Submitted by Mike Mulligan Related to the Palisades Nuclear Plant (ADAMS Accession No.
William Borchardt re: 10 CFR 2.206 Petition Associated with a Request for Emergency Palisades Shutdown (ADAMS Accession No. ML12177A278 and ML12180A336).
ML12320A564).
: 5. Letter dated June 22, 2012, from Representative Edward J. Markey to Chairman Jaczko re: Shutdown of Palisades Nuclear Power Plant - Leak in Water Storage Tank (ADAMS Accession No. ML12178A446).
: 17. Letter dated October 24, 2012, from Stephanie Coffin to Ms. Bette Pierman, et. al., re: Palisades Continued Safety Issues 2012 (ADAMS Accession No. ML12275A151).
: 6. Letter dated June 26, 2012, from Gary L. Shear to Anthony Vitale re: Request for Information on Safety Culture Issues at Palisades Nuclear Plant (ADAMS Accession No. ML12179A155).
: 7. Letter dated June 28, 2012, from Mike Mulligan to R. William Borchardt re: 10 CFR 2.206 Petition Associated with Palisades Numerous Roof Leaks (ADAMS Accession No. ML12262A355).
: 8. Letter dated July 12, 2012, from Anthony J. Vitale to U.S. NRC Document Control Desk re: Safety Injection Refueling Water Tank Leakage and Corrective Actions (ADAMS Accession No. ML12194A573).
: 9. Confirmatory Action Letter dated July 17, 2012, from Charles A. Casto to Anthony Vitale re: Palisades Nuclear Plant Commitment to Address Safety Injection Refueling Water Tank and Control Room Concrete Support Structure Leakage (ADAMS Accession No. ML12199A409).
: 10. Closure letter dated July 29, 2012, from Allen Howe to Thomas Saporito re: 10 CFR 2.206 Petition (G20120149/EDATS: OEDO-2012-0127) Associated with the Palisades Nuclear Plant (ADAMS Accession No. ML12173A481).
1
: 11. Letter dated July 31, 2012, from John B. Giessner to Anthony J. Vitale re: NRC Supplemental Inspection Report 05000255/2012010, and Assessment Follow-up Letter (ADAMS Accession No. ML12213A225).
: 12. Letter dated August 8, 2012, from John B. Giessner to Anthony J. Vitale re: Palisades Nuclear Plant Integrated Inspection Report 05000255/2012003 (ADAMS Accession No. ML12221A340).
: 13. Letter dated August 15, 2012, from Chairman Macfarlane to Representative Edward J.
Markey re: Response to Specific Requests for Information Regarding the Recent Shutdown of the Palisades Nuclear Plant Resulting from a Leak in a Water Storage Tank (ADAMS Accession Package No. ML12191A401).
: 14. Letter dated August 30, 2012, from John B. Giessner to Anthony J. Vitale re: Notification of NRC Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area and Request for Information (ADAMS Accession No. ML12243A409).
: 15. Transcript from August 29, 2012, Teleconference re: 10 CFR 2.206 Petitions Submitted by Mike Mulligan Related to the Palisades Nuclear Plant (ADAMS Accession No. ML12261A380).
: 16. Transcript from October 24, 2012, Teleconference re: 10 CFR 2.206 Petition Submitted by Mike Mulligan Related to the Palisades Nuclear Plant (ADAMS Accession No. ML12320A564).
: 17. Letter dated October 24, 2012, from Stephanie Coffin to Ms. Bette Pierman, et. al., re:
Palisades Continued Safety Issues 2012 (ADAMS Accession No. ML12275A151).
: 18. Memorandum dated November 8, 2012, Request for Deviation to the Reactor Oversight Process Action Matrix to Provide Heightened NRC Oversight at the Palisades Nuclear Plant (ADAMS Accession No. ML12306A367).
: 18. Memorandum dated November 8, 2012, Request for Deviation to the Reactor Oversight Process Action Matrix to Provide Heightened NRC Oversight at the Palisades Nuclear Plant (ADAMS Accession No. ML12306A367).
: 19. Letter dated November 9, 2012, from Kenneth O'Brien to Anthony J. Vitale re: NRC Supplemental Inspection Report 05000255/2012011; and Assessment Follow-Up Letter (ADAMS Accession No. ML12314A304).
: 19. Letter dated November 9, 2012, from Kenneth OBrien to Anthony J. Vitale re: NRC Supplemental Inspection Report 05000255/2012011; and Assessment Follow-Up Letter (ADAMS Accession No. ML12314A304).
: 20. Letter dated November 13, 2012, from John B. Giessner to Anthony J. Vitale re: Palisades Nuclear Plant Integrated Inspection Report 05000255/2012004 (ADAMS Accession No. ML12319A093).}}
: 20. Letter dated November 13, 2012, from John B. Giessner to Anthony J. Vitale re:
Palisades Nuclear Plant Integrated Inspection Report 05000255/2012004 (ADAMS Accession No. ML12319A093).
2}}

Latest revision as of 10:33, 6 February 2020

Closure Letter Associated Petitions Submitted by Mr. Michael Mulligan Pursuant to Title 10 of the Code of Federal Regulations (10 Cfr), Section 2.206
ML12320A608
Person / Time
Site: Palisades Entergy icon.png
Issue date: 11/20/2012
From: Marilyn Evans
Division of Operating Reactor Licensing
To: Mulligan M
- No Known Affiliation
Beltz T
Shared Package
ML12321A017 List:
References
G20120443, OEDO-2012-0364, TAC ME8927, TAC ME9070
Download: ML12320A608 (15)
v • d • e


Text

November 20, 2012 Mr. Michael Mulligan P.O. Box 161 Hinsdale, NH 03451

Dear Mr. Mulligan:

You recently submitted two petitions addressed to Mr. William Borchardt, Executive Director for Operations at the U.S. Nuclear Regulatory Commission (NRC). The petitions were referred to the NRCs Office of Nuclear Reactor Regulation pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 2.206.

In your first petition dated June 18, 2012, as revised on June 27, 2012, you requested that the Palisades Nuclear Plant (Palisades) remain shutdown. In the petition, you were critical of Entergy Nuclear, the NRC, and the programmatic aspects of the regulatory program, including the Reactor Oversight Process (ROP). You focused on a leak of the Safety Injection Refueling Water (SIRW) tank at Palisades, but also discussed past events at both Palisades and other Entergy-owned facilities. Finally, you also discussed the lack of an adequate safety culture environment at Palisades.

You requested that the following actions be taken:

(1) The shutdown resulting from the SIRW tank leak should be categorized as unplanned.

(2) The NRC should move the Palisades performance indicator from Red to the next level V:

Unacceptable Performance.

(3) An outside authority (not the NRCs Office of the Inspector General (OIG)) should determine why the NRC did not force Palisades (Entergy) to thoroughly investigate the SIRW leak when the leak first appeared.

(4) Top Palisades management staff should be fired and replaced before startup.

(5) Entergys corporate nuclear senior staff should be fired and replaced before restart.

(6) The NRC should assign two additional NRC inspectors to Palisades and to the rest of the Entergy nuclear plants.

(7) A local public oversight panel should be formed around every plant.

(8) An emergency NRC senior official oversight panel should be convened to reform the ROP.

(9) A national NRC oversight panel of outsiders (consisting of a mixture of professional and academic people, as well as lay people) should be convened to oversee and report on agency activities.

(10) The NRC should perform an analysis to determine the cause of the numerous findings of problems with Entergy plants during this inspection reporting cycle.

(11) The NRC should evaluate if Region III has enough personnel and resources.

(12) Palisades should remain shutdown until all procedures are fully updated and corrected, all technical and maintenance backlogs are updated and corrected, all training completed, and all reports and safety processes are fully completed and implemented.

(13) An independent outside investigation should review the insufficient process outcome of the 2008-2009 Palisades security falsification, investigation, safety survey local and fleet-wide training and safety surveys.

(14) President Obama should fire Chairman Jazcko and the four Commissioners.

In the second petition dated June 28, 2012, you requested that Palisades remain shutdown.

This petition was focused on roof leaks at Palisades, but also discussed past events at both Palisades and other Entergy-owned facilities. You discussed a lack of adequate safety culture environment at Palisades, and were also critical of the NRC staff for tolerating and covering up very serious safety problems at Palisades and throughout the Entergy organization. This petition also included specific questions related to roof leaks.

This petition duplicated many of your requests discussed in the previous petition. However, in your second petition there were new requests which are provided below:

(15) Entergy should be prevented from starting up until all the safety problems at the site have been publicly identified and the safety culture repaired.

(16) Heads need to roll in Region III and at headquarters for tolerating and covering up these very serious safety problems at Palisades and throughout the Entergy organization. This all has the potential to gravely damage our nation.

(17) The NRC should report on why the 2.206 petition process failed, and for the agency to hold officials accountable to the plant employees and me with not doing their jobs in trying to understand what was going on at the site and not repairing the organization at the earliest point.

(18) A meeting with the Palisades inspector and other inspectors to discuss the conditions of Palisades before the petition board pre-hearing.

Timeline The NRCs Petition Review Board (PRB) met internally on July 10, and July 31, 2012, to discuss your requests for immediate action associated with the two petitions. The PRB denied the requests for immediate action on the basis that no immediate safety concern was identified that would prohibit a Palisades reactor plant startup, or had an effect on the health and safety of the public. There was no new information, or information specific enough, for the NRC to further consider making an immediate action determination. You were informed on July 17, and again on August 8, 2012, of the PRBs decision to deny your request for immediate action related to the two petitions under consideration.

On August 8, 2012, the Petition Manager contacted you to discuss the 10 CFR 2.206 process and to offer you an opportunity to address the PRB by phone or in person. You were also informed that the two petitions under consideration would be consolidated because the petitions were submitted at or about the same time; the requested actions were against the same licensee; and, with a few unique issues, addressed essentially the same specific concerns. The Petition Manager informed you that consolidation of the petitions did not reduce the importance of the circumstances being discussed, but streamlined the NRC staffs review process and response.

On August 21, 2012, you had a discussion with members of the Regional staff regarding ongoing issues at Palisades.

On August 29, 2012, you addressed the PRB via teleconference. The official transcript of the teleconference is publicly available in the Agencywide Documents Access and Management System (ADAMS) (Accession No. ML12261A380).

On September 24, 2012, the PRB met internally to review the petitions and make an initial recommendation. The PRB rejected the petition using the criteria of NRC Management Directive (MD) 8.11, Review Process for 10 CFR 2.206 Petitions. The details of the criteria for rejection are provided in Attachment 1.

On September 27, 2012, the Petition Manager provided the PRBs initial recommendation to you and offered a second opportunity to address the PRB. On October 4, 2012, you requested an additional opportunity to address the PRB via teleconference.

On October 24, 2012, you addressed the PRB by teleconference to discuss the PRBs initial recommendation. The official transcript of the teleconference is publicly available in ADAMS (Accession No. ML12320A564).

Reactor Oversight Process The NRCs oversight and inspection of nuclear power plants is a continuous process. The NRC staff evaluates specific violations and the safety risk that these violations present. The NRC conducts these evaluations using the ROP. The NRC staff acknowledges your dissatisfaction with the ROP and many of the final determinations resulting from the process as you discussed in the petitions and during the teleconferences with the NRC. Your concerns were forwarded to the OIG.

Palisades was in Column III (degraded cornerstone) of the ROP action matrix. As a Column III plant, the NRC conducted a supplemental inspection (using Inspection Procedure 95002), in addition to routine ongoing inspections. The inspection was completed on September 28, 2012, and was designed to address the following:

  • Ensure that the root and contributing causes of the performance issue are understood.
  • Identify the extent of condition and extent of cause.
  • Determine if safety culture components caused or significantly contributed to the individual and collective risk-significant performance issues, including unplanned shutdowns.
  • Provide assurance that corrective actions are sufficient to address the root and contributing causes and prevent recurrence.

At the start of the fourth quarter, Palisades transitioned back to Column I following the results of the supplemental inspection. The inspection identified that the licensee has appropriately addressed the Yellow and White findings.

The agency is fully aware that Palisades has had a recent number of unanticipated plant shutdowns. Based on the above actions taken by the NRC and the licensee, the agency believes that the performance deficiencies at Palisades have been identified, and that the agency has inspected these deficiencies to ensure that the licensee is taking adequate action.

The NRC staff continuously verifies that plant operations are being conducted within the applicable regulatory requirements and within the terms of the operating license, and concludes that Palisades continues to remain safe to operate.

Summary The PRB discussed the information you provided in the petitions and arrived at a consensus that you did not provide any additional information to support the petition requests during the teleconferences held on August 29 and October 24, 2012. The PRBs final determination is the same as its initial recommendation. The PRBs final determination is to reject your petition for review under the 10 CFR 2.206 process because it does not meet the criteria for review. provides a summary of the details for rejecting the petitions. Attachment 2 provides a list of publicly available documents and correspondence associated with your petitions. Some issues were outside the scope of the process as described in 10 CFR 2.206, and other issues were already the subject of NRC staff review or resolution had been previously determined in accordance with NRC MD 8.11. Finally, Attachment 1 also provides additional information as to which of your concerns have been forwarded to the OIG.

Thank you for bringing these issues to the attention of the NRC.

Sincerely,

/RA/

Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255 : Table (Summary of Issues) : Documents and Correspondence

Thank you for bringing these issues to the attention of the NRC.

Sincerely,

/RA/

Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255 : Table (Summary of Issues) : Documents and Correspondence DISTRIBUTION: G20120443/EDATS: OEDO-2012-0364 RidsNrrDorl RidsNrrDorlLpl3-1 RidsNrrPMPalisades RidsNrrLABTully RidsNrrMailCenter RidsNrrOd RidsEDOMailCenter RidsOGCRp Resource RidsOeMailCenter RidsOiMailCenter RidsOpaMail RidsRgn3MailCenter RidsOcaMailCenter PUBLIC LPL3-1 R/F MBanic, NRR JGiessner, RIII JLennartz, RIII TBeltz, NRR CHair, OGC RLerch, R3 Package: ML12321A017 Incoming: ML12177A278 (G20120443/OEDO-2012-0364)

ML12180A336 (G20120443)

ML12262A355 (G20120443)

Transcript: ML12261A380 ML12320A564 Response: ML12320A608

  • concurrence via email OFFICE LPL3-1/PM LPL3-1/LA DPR/PM R3/DRP/BC LPL3-1/BC OGC NRR/DD NAME TBeltz SFigueroa
  • MBanic
  • JLennartz
  • RCarlson CHair * (NLO) MEvans for BTully for JGiessner DATE 11/16/12 11/16/12 11/16/12 11/16/12 11/19/12 11/16/12 11/20/12 OFFICIAL RECORD COPY

Attachment 1 Table (Summary of Issues)

Is This Request Does This Specific Issue Outside the Meet the Item(s) Does This Meet the Criteria for Review?

Raised Scope of the Criteria for 2.206 Process? Rejection?

No. The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry and, therefore, this request should not be accepted for review The Safety Injection pursuant to 10 CFR 2.206.

Refueling Water tank (1) shutdown be Yes Yes All the specific issues raised in the support of the requested action have been the categorized as an subject of NRC staff review and evaluation.

unplanned shutdown Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

No. The petitioner does not provide adequate basis and sufficient facts to warrant The NRC should move further inquiry and, therefore, this request should not be accepted for review the Palisades pursuant to 10 CFR 2.206.

performance indicator (2) from Red to Level V Yes The NRC staff evaluates licensee performance and placement within the Action Yes

[Column 5]: Matrix under the Reactor Oversight Process.

Unacceptable Performance Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

An outside authority No. The petitioner does not provide adequate basis and sufficient facts to warrant investigate why the further inquiry and, therefore, this request should not be accepted for review NRC did not make pursuant to 10 CFR 2.206.

Palisades Entergy thoroughly investigate (3) Yes All the specific issues raised in the support of the requested action have been the Yes the SIRW leak when it subject of NRC staff review and evaluation.

first appeared and ensure it was fixed Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

during the last shutdown period This issue was referred to the Office of the Inspector General (OIG).

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Is This Request Does This Specific Issue Outside the Meet the Item(s) Does This Meet the Criteria for Review?

Raised Scope of the Criteria for 2.206 Process? Rejection?

No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.

Top Palisades management staff The petitioners supporting facts are insufficient to warrant further inquiry.

(4) should be fired and Yes Yes replaced before This request was reviewed by the NRC in accordance with the 2.206 process for startup. previous petitions filed by Mr. Mulligan (Attachment 2, Documents and Correspondence, Items 2 and 3)..

Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.

Entergy corporate The petitioners supporting facts are insufficient to warrant further inquiry.

nuclear staff should be (5) Yes fired and replaced Yes This request was reviewed by the NRC in accordance with the 2.206 process for prior to Palisades previous petitions filed by Mr. Mulligan (Attachment 2, Documents and restart.

Correspondence, Items 2 and 3).

Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

No. This is not an enforcement-related action and is outside the scope of the The NRC should 2.206 process. Therefore, this request should not be accepted for review pursuant assign two additional to 10 CFR 2.206.

NRC inspectors at (6) Yes Palisades, and to all Yes This request was reviewed by the NRC in accordance with the 2.206 process for the other troubled previous petitions filed by Mr. Mulligan (G20110127 and G20120022)

Entergy plants.

Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

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Is This Request Does This Specific Issue Outside the Meet the Item(s) Does This Meet the Criteria for Review?

Raised Scope of the Criteria for 2.206 Process? Rejection?

No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.

Formation of a local This request was reviewed by the NRC in accordance with the 2.206 process for (7) public oversight panel Yes Yes previous petitions filed by Mr. Mulligan (Attachment 2, Documents and around every plant.

Correspondence, Items 2 and 3).

Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.

An emergency NRC senior official This request was reviewed by the NRC in accordance with the 2.206 process for oversight panel should (8) Yes previous petitions filed by Mr. Mulligan (Documents and Correspondence Items 2 Yes be convened to reform and 3).

the Reactor Oversight Process.

Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

This issue was referred to the Office of the Inspector General (OIG).

No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant A national NRC to 10 CFR 2.206.

oversight panel should (9) be convened to Yes This request was reviewed by the NRC in accordance with the 2.206 process for Yes oversee and report on previous petitions filed by Mr. Mulligan (Attachment 2, Documents and agency activities. Correspondence, Items 2 and 3).

Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

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Is This Request Does This Specific Issue Outside the Meet the Item(s) Does This Meet the Criteria for Review?

Raised Scope of the Criteria for 2.206 Process? Rejection?

No. The Petitioner refers to findings that are indicative of recurring problems at The NRC should Palisades and Entergy plants. However, the information discussed in the petition perform an analysis to does not appear to provide additional facts beyond what the NRC staff has already determine the cause reviewed and documented.

of the numerous (10) Yes Yes findings of problems The issues raised in the support of the requested action have been the subject of with Entergy plants NRC staff review and evaluation.

during this inspection reporting cycle.

Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

No. This is not an enforcement-related action and is outside the scope of the 2.206 process and, therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.

The NRC should evaluate if Region III (11) Yes This request was reviewed by the NRC in accordance with the 2.206 process for Yes has enough personnel previous petitions filed by Mr. Mulligan (Attachment 2, Documents and and resources.

Correspondence, Items 2 and 3).

Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

Palisades should remain shutdown until procedures are fully updated and No. The issues raised in the support of the requested action are subject to corrected; all technical continuing NRC staff review and evaluation via the Reactor Oversight Process.

and maintenance backlogs are updated The petitioner does not provide adequate basis and sufficient facts to warrant (12) No Yes and corrected; all further inquiry.

training is completed; all reports and safety Therefore, this request should not be accepted for review pursuant to 10 CFR processes fully 2.206.

completed and implemented.

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Is This Request Does This Specific Issue Outside the Meet the Item(s) Does This Meet the Criteria for Review?

Raised Scope of the Criteria for 2.206 Process? Rejection?

Request independent outside investigation No. The petitioner does not provide adequate basis and sufficient facts to warrant of the 2008-2009 further inquiry and, therefore, this request should not be accepted for review Palisades security pursuant to 10 CFR 2.206.

falsification, investigation, safety This request was reviewed by the NRC in accordance with the 2.206 process as survey and local and discussed in a previous petition filed by Mr. Mulligan (Attachment 2, Documents fleet-wide training and and Correspondence, Item 3).

(13) Yes Yes safety surveys. It appears that the All the specific issues raised in the support of the requested action have been the safety culture at subject of NRC staff review and evaluation.

Palisades has been grossly defective and Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

ineffectively for many years, along with the This issue was referred to the Office of the Inspector General (OIG).

ROP.

No. This is not an enforcement-related action and is outside the scope of the 2.206 process. Therefore, this request should not be accepted for review pursuant to 10 CFR 2.206.

Replacement of NRC The members of the Commission are Presidential appointees.

(14) Chairman and Yes Yes Commissioners This request was reviewed by the NRC in accordance with the 2.206 process for previous petitions filed by Mr. Mulligan (Documents and Correspondence Items 2 and 3).

Therefore, this request meets the criteria for rejection as discussed in MD 8.11.

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Is This Request Does This Specific Issue Outside the Meet the Item(s) Does This Meet the Criteria for Review?

Raised Scope of the Criteria for 2.206 Process? Rejection?

No. The petitioner does not provide adequate basis and sufficient facts to warrant further inquiry and, therefore, this request should not be accepted for review Entergy should be pursuant to 10 CFR 2.206.

prevented from starting up until all the All the specific issues raised in the support of the requested action have been the safety problems at the subject of NRC staff review and evaluation, which meets the criteria for rejection (15) No Yes site have been publicly as discussed in MD 8.11.

identified and the safety culture Refer to Attachment 2, Documents and Correspondence, Items 5, 6, 8, 9, 11, 12, repaired. 14, 17, 18, 19, and 20.

This issue was referred to the Office of the Inspector General (OIG).

Heads need to roll in Region III and Headquarters for tolerating and covering No. This is not an enforcement-related action and is outside the scope of the up these very serious (16) Yes 2.206 process. Therefore, this request should not be accepted for review pursuant Yes safety problems at to 10 CFR 2.206.

Palisades and throughout the Entergy organization.

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Is This Request Does This Specific Issue Outside the Meet the Item(s) Does This Meet the Criteria for Review?

Raised Scope of the Criteria for 2.206 Process? Rejection?

Report on why the 2.206 petition process failed so utterly for us...

for the agency to hold officials accountable to the plant employees and me with not doing No. This is not an enforcement-related action and is outside the scope of the their jobs in trying to 2.206 process. Therefore, this request should not be accepted for review pursuant understand what was to 10 CFR 2.206.

going on at the site and (17) Yes Yes not repairing the organization at the This issue was referred to the Office of the Inspector General (OIG).

earliest point. The whole Entergy organization is involved and they have a huge costly hole to dig out of.

It is easier digging the hole than crawling out of one.

Request a meeting with the Palisades inspectors and other On August 21, 2012, the Petitioner had a phone call with members of the Regional (18) inspectors to discuss N/A Yes staff to discuss ongoing issues at Palisades.

the conditions of Palisades before the PRB pre-hearing.

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Attachment 2 DOCUMENTS AND CORRESPONDENCE

1. Letter dated January 10, 2012, from Mike Mulligan to R. William Borchardt re: 10 CFR 2.206 Petition (G20120022/EDATS: OEDO-2012-0028) Associated with a Request for Emergency Palisades Shutdown (ADAMS Accession No. ML12012A212).
2. Closure letter dated April 20, 2011, from Thomas Blount to Mr. Michael Mulligan re:

Palisades 2.206 Petition (G20110127/EDATS: OEDO-2011-0156) Associated with a Request for Immediate Shutdown of Palisades and Other Entergy Plants (ADAMS Accession No. ML111010414).

3. Closure letter dated May 21, 2012, from Michael Cheok to Mr. Michael Mulligan re:

Palisades 2.206 Petition (G20120022/EDATS: OEDO-2012-0028) Associated with a Request for Emergency Palisades Shutdown (ADAMS Accession No. ML111010487).

4. Letters dated June 18, 2012, and June 27, 2012 (Rev. 1), from Mike Mulligan to R.

William Borchardt re: 10 CFR 2.206 Petition Associated with a Request for Emergency Palisades Shutdown (ADAMS Accession No. ML12177A278 and ML12180A336).

5. Letter dated June 22, 2012, from Representative Edward J. Markey to Chairman Jaczko re: Shutdown of Palisades Nuclear Power Plant - Leak in Water Storage Tank (ADAMS Accession No. ML12178A446).
6. Letter dated June 26, 2012, from Gary L. Shear to Anthony Vitale re: Request for Information on Safety Culture Issues at Palisades Nuclear Plant (ADAMS Accession No. ML12179A155).
7. Letter dated June 28, 2012, from Mike Mulligan to R. William Borchardt re: 10 CFR 2.206 Petition Associated with Palisades Numerous Roof Leaks (ADAMS Accession No. ML12262A355).
8. Letter dated July 12, 2012, from Anthony J. Vitale to U.S. NRC Document Control Desk re: Safety Injection Refueling Water Tank Leakage and Corrective Actions (ADAMS Accession No. ML12194A573).
9. Confirmatory Action Letter dated July 17, 2012, from Charles A. Casto to Anthony Vitale re: Palisades Nuclear Plant Commitment to Address Safety Injection Refueling Water Tank and Control Room Concrete Support Structure Leakage (ADAMS Accession No. ML12199A409).
10. Closure letter dated July 29, 2012, from Allen Howe to Thomas Saporito re: 10 CFR 2.206 Petition (G20120149/EDATS: OEDO-2012-0127) Associated with the Palisades Nuclear Plant (ADAMS Accession No. ML12173A481).

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11. Letter dated July 31, 2012, from John B. Giessner to Anthony J. Vitale re: NRC Supplemental Inspection Report 05000255/2012010, and Assessment Follow-up Letter (ADAMS Accession No. ML12213A225).
12. Letter dated August 8, 2012, from John B. Giessner to Anthony J. Vitale re: Palisades Nuclear Plant Integrated Inspection Report 05000255/2012003 (ADAMS Accession No. ML12221A340).
13. Letter dated August 15, 2012, from Chairman Macfarlane to Representative Edward J.

Markey re: Response to Specific Requests for Information Regarding the Recent Shutdown of the Palisades Nuclear Plant Resulting from a Leak in a Water Storage Tank (ADAMS Accession Package No. ML12191A401).

14. Letter dated August 30, 2012, from John B. Giessner to Anthony J. Vitale re: Notification of NRC Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area and Request for Information (ADAMS Accession No. ML12243A409).
15. Transcript from August 29, 2012, Teleconference re: 10 CFR 2.206 Petitions Submitted by Mike Mulligan Related to the Palisades Nuclear Plant (ADAMS Accession No. ML12261A380).
16. Transcript from October 24, 2012, Teleconference re: 10 CFR 2.206 Petition Submitted by Mike Mulligan Related to the Palisades Nuclear Plant (ADAMS Accession No. ML12320A564).
17. Letter dated October 24, 2012, from Stephanie Coffin to Ms. Bette Pierman, et. al., re:

Palisades Continued Safety Issues 2012 (ADAMS Accession No. ML12275A151).

18. Memorandum dated November 8, 2012, Request for Deviation to the Reactor Oversight Process Action Matrix to Provide Heightened NRC Oversight at the Palisades Nuclear Plant (ADAMS Accession No. ML12306A367).
19. Letter dated November 9, 2012, from Kenneth OBrien to Anthony J. Vitale re: NRC Supplemental Inspection Report 05000255/2012011; and Assessment Follow-Up Letter (ADAMS Accession No. ML12314A304).
20. Letter dated November 13, 2012, from John B. Giessner to Anthony J. Vitale re:

Palisades Nuclear Plant Integrated Inspection Report 05000255/2012004 (ADAMS Accession No. ML12319A093).

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