ML18046A675

Request to Extend Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 for Tornado-Generated Missile Protection Non-Conformances Identified in Response to Regulatory Issue Summary 2015-06, Tornado Missile Protection

ML18046A675
Person / Time
Site:	Palisades
Issue date:	02/16/2018
From:	Mike Franovich NRC/NRR/DRA
To:	Hardy J Entergy Nuclear Operations
Patterson M
References
EPID L-2017-LLL-0037, RIS-15-006
Download: ML18046A675 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 16, 2018 Jeffery A. Hardy Regulatory Assurance Manager Entergy Nuclear Operations, Inc.

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

SUBJECT:

REQUEST TO EXTEND ENFORCEMENT DISCRETION PROVIDED IN ENFORCEMENT GUIDANCE MEMORANDUM 15-002 FOR TORNADO-GENERATED MISSILE PROTECTION NON-CONFORMANCES IDENTIFIED IN RESPONSE TO REGULATORY ISSUE

SUMMARY

2015-06, "TORNADO MISSILE PROTECTION" (EPID: L-2017-LLL-0037)

Dear Mr. Hardy:

By letter dated December 7, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17341A415), as supplemented by letter dated January 18, 2018 (ADAMS Accession No. ML18018A328), Entergy Nuclear Operations, Inc., requested the U.S.

Nuclear Regulatory Commission (NRC, the Commission) to extend the expiration date for the period of enforcement for Palisades Nuclear Plant, (PNP), from June 10, 2018, to June 10, 2020, in accordance with information provided in Enforcement Guidance Memorandum (EGM) 15-002, Revision 1, "Enforcement Discretion for Tornado Generated Missile Protection Non-compliance", dated February 7, 2017 (ADAMS Accession No. ML16355A286).

The NRC staff also discussed your request in a January 4, 2018, public meeting (summary of public meeting can be found at ADAMS Accession No. ML18008A230). Subsequently, the staff has reviewed your letters in accordance with Commission direction as provided in EGM 15-002, Revision 1, and staff guidance provided in NRC Interim Staff Guidance, DSS-ISG-2016-01, Revision 1, "Clarification of Licensee Actions in Receipt of Enforcement Discretion [per EGM 15-002]." dated November 2017 (ADAMS Accession No. ML17128A344).

The NRC staff reviewed the information that you have provided and finds that the compensatory measures taken are consistent with EGM 15-002, Revision 1, and with interim staff guidance found in DSS-ISG-2016-01, Revision 1. Specifically, the staff found that PNP has sufficiently described and evaluated the following six items described in DSS-ISG-2016-01, Rev. 1, Appendix B: nonconformances applicable to the EGM, prompt compensatory actions, long-term compensatory actions, assessment of compensatory measures, need for additional enforcement discretion time, and timeline for restoring licensing basis compliance. The staff has concluded that the actions taken by PNP can be effectively implemented and justify extension of the enforcement discretion date to June 10, 2020, because PNP has sufficiently described and documented compensatory measures for identified nonconforming structures, systems, and components (SSCs), provided assurance that compensatory measures will be effective and maintained through the extended period for enforcement discretion, and described an implementable plan for restoring SSCs to compliance within the extended period for enforcement discretion. Therefore, the request to extend enforcement discretion is granted.

If you are unable to meet the extended EGM expiration date, you are requested to contact the NRG staff at least 90 days in advance. Please contact Greg Casto at (301) 415-0565.

Sincerely, Michael X. Franovich, Director Division of Risk Assessment Office of Nuclear Reactor Regulation Docket No. 50-255 cc: Distribution via Listserv

ML18046A675 *Concurrence by email OFFICE NRR/DRNAPLB NRR/DSS/SL NRR/DRNAPLB/BC NRR/DSS/SCPB NAME MPatterson* JHickey* GCasto RDennig DATE 02/15/2018 P2/15t2018 02/12/2018 02/15/2018 OFFICE ()Flc:010,::; nr,r. NRRtnRNDn NAME JPeralta* LBaer<NLQ)* MFranovich DATE 02/15/2018 p211212018 02/16/2018