ML14063A276

Annual Assessment Letter for Palisades Nuclear Plant (Report 05000255/3013001)

ML14063A276
Person / Time
Site:	Palisades
Issue date:	03/04/2014
From:	Eric Duncan NRC/RGN-II/DRP/RPB3
To:	Vitale A Entergy Nuclear Operations
References
IR-13-001
Download: ML14063A276 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 March 4, 2014 Mr. Anthony Vitale Vice President, Operations Entergy Nuclear Operations, Inc.

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

SUBJECT:

ANNUAL ASSESSMENT LETTER FOR PALISADES NUCLEAR PLANT (REPORT 05000255/2013001)

Dear Mr. Vitale:

On February 12, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed its end-of-cycle performance review of Palisades Nuclear Plant. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to inspection results and enforcement actions from January 1, 2013 through December 31, 2013. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility.

The NRC determined that overall, Palisades Nuclear Plant operated in a manner that preserved public health and safety and met all cornerstone objectives. The NRC determined the performance at Palisades during the most recent quarter was within the Licensee Response Column of the NRCs Reactor Oversight Process (ROP) Action Matrix because all inspection findings had very low (i.e., Green) safety significance, and all PIs indicated that your performance was within the nominal, expected range (i.e., Green). Therefore, the NRC plans to conduct ROP baseline inspections at your facility.

On November 8, 2012, Region III received approval from the NRC Executive Director for Operations (EDO) to deviate from the ROP Action Matrix to increase regulatory oversight at Palisades for CY 2013. The approved deviation effort was anticipated to involve regional augmentation of the resident inspectors at Palisades, community outreach, and additional Problem Identification and Resolution (PI&R) inspections to include corrective action and safety culture reviews. The effort for these additional activities was estimated to require an additional 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br /> through CY 2013.

In CY 2013, slightly more than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of effort were expended in accordance with the approved ROP Action Matrix deviation. No findings of significance were identified as a result of these inspections. Due to refueling outage schedule changes, a number of inspections, that were planned to be completed in the areas identified in the deviation request, were unable to be performed in CY 2013. However, these remaining inspection activities are being accomplished within the nominal baseline inspection hours allocated to plants in the Licensee Response Column of the ROP Action Matrix during the current refueling outage.

On February 26, 2014, the NRC completed a limited-scope Problem Identification and Resolution (PI&R) inspection to focus on Safety Conscious Work Environment (SCWE) issues at Palisades Nuclear Plant after the NRC became aware of a number of concerns that suggested a chilled work environment may have impacted the willingness of some workers to raise safety concerns due to a fear of retaliation.

Based on the inspection, the NRC concluded that some employees at Palisades have the perception that they are not free to raise safety concerns using all available avenues, and that management has not been effective in encouraging employees to use all available avenues without fear of retaliation. In particular, the NRC identified a chilled work environment within the Security department. The security staff interviewed expressed reservations about raising issues or concerns for fear of retaliation. Additionally, they indicated a lack of comfort in using the Employee Concerns Program (ECP), in that, they felt it did not maintain the confidentiality of the identity of an individual who raised an issue or concern through the ECP process.

The NRC will review, as part of its May 2014 PI&R inspection, the effectiveness of actions taken to address the SCWE concerns within the Security department and in any additional Palisades identified groups with SCWE concerns; and any additional actions or changes in actions, planned and taken, to address SCWE issues at Palisades. Following the PI&R inspection, we will determine if additional NRC oversight regarding safety culture at Palisades is warranted.

As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised. All cross-cutting aspects identified during inspections conducted in Calendar Year (CY) 2014 will reflect this revision to Inspection Manual Chapter (IMC) 0310. The CY 2013 end-of-cycle assessments were conducted using the IMC 0310 guidance in effect in CY 2013 (dated October 28, 2011). Cross-cutting aspects identified in 2013 using the 2013 terminology will be converted to the latest revision in accordance with the cross-reference in IMC 0310 during the mid-cycle assessment review and evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305.

The enclosed inspection plan lists the inspections scheduled through June 30, 2015. Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last nine months of the inspection plan are tentative and may be revised at the mid-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security-related inspections, which will be sent via separate, non-publicly available correspondence.

In addition to the ROP baseline inspections, the NRC plans to conduct infrequent inspections related to Inspection Procedure (IP) 92703, Follow-up of Confirmatory Action Letters or Orders, related to the Safety Injection Refueling Water Tank (SIRWT); IP 92709, Strike Contingency Plans; and IP 92711, Continued Implementation of Strike Plans During an Extended Strike, if needed due to expiring contracts; and IP 60854.1, Preoperational Testing of ISFSIs at Operating Plants; IP 60855.1, Operation of an ISFSI [Independent Spent Fuel Storage Installation] at Operating Plants; and IP 60856.1, Review of 10 CFR 72.212(b)

Evaluations at Operating Plants, related to ISFSI inspections.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Please contact me at 630-829-9620 with any questions you have regarding this letter.

Sincerely,

/RA/

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

Enclosure:

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

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Please contact me at 630-829-9620 with any questions you have regarding this letter.

Sincerely,

/RA/

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

Enclosure:

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

See next page DOCUMENT NAME: Palisades Annual Assessment Letter Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" =

Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII RIII NAME EDuncan ABoland DATE 02/26/14 02/26/14 OFFICIAL RECORD COPY

Letter to Anthony Vitale from Eric Duncan dated March 4, 2014

SUBJECT:

ANNUAL ASSESSMENT LETTER FOR PALISADES NUCLEAR PLANT (REPORT 05000255/2013001)

DISTRIBUTION w/encl:

Ernesto Quinones RidsNrrPMPalisades Resource RidsNrrDorlLpl3-1 Resource RidsNrrDirsIrib Resource Cynthia Pederson Darrell Roberts Steven Orth Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley ROPassessment.Resource@nrc.gov

Page 1 of 2 02/25/2014 13:43:32 Report 22 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Palisades Inspection / Activity Plan 03/01/2014 - 06/30/2015 BI ISI

- ISI BASELINE INSPECITON 2

1 IP Inservice Inspection Activities - PWR 7111108P 01/20/2014 03/31/2014 BI OLRQ

- BIENNIAL REQUAL PROGRAM INSPECTION 2

1 IP Licensed Operator Requalification Program 7111111B 04/07/2014 04/11/2014 BI RP

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP Radiological Hazard Assessment and Exposure Controls 71124.01 04/14/2014 04/18/2014 ISFSI

- ISFSI REVIEW OF CFR 72.212(B) EVALS 3

1 IP Review of 10 CFR 72.212(b) Evaluations at Operating Plants 60856.1 05/01/2014 07/31/2014 PI&R

- BIENNIAL PI&R 7

1 IP Problem Identification and Resolution 71152B 05/05/2014 05/23/2014 ISFSI

- ISFSI PREOP TESTING - SCHEDULE DEPENDENT 1

1 IP Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants 60854.1 06/01/2014 09/30/2014 BI RP

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP Radiological Environmental Monitoring Program 71124.07 07/07/2014 07/11/2014 BI RP

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 08/11/2014 08/15/2014 1

IP Occupational Dose Assessment 71124.04 08/11/2014 08/15/2014 OL PREP

- INITIAL EXAM - 09/2014 4

1 OL - INITIAL EXAM - 2014 JUN-FEB - PALI W90308 08/18/2014 08/22/2014 ISFSI

- ISFSI OPERATION - SCHEDULE DEPENDENT 2

1 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 09/01/2014 11/30/2014 OL EXAM

- INIT EXAM FOR 09/2014 4

1 OL - INITIAL EXAM - 2014 JUN-FEB - PALI W90308 09/08/2014 09/19/2014 BI ENG

- COMPONENT DESIGN BASIS INSPECTION 7

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

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP Occupational ALARA Planning and Controls 71124.02 10/06/2014 10/10/2014 1

IP Reactor Coolant System Activity 71151-BI01 10/06/2014 10/10/2014 1

IP Occupational Exposure Control Effectiveness 71151-OR01 10/06/2014 10/10/2014 1

IP RETS/ODCM Radiological Effluent 71151-PR01 10/06/2014 10/10/2014 BI EPX

- EP EXERCISE INSPECTION / PI VERIFICATION 2

1 IP Performance Indicator Verification 71151 10/27/2014 10/31/2014 This report does not include INPO and OUTAGE activities.

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

Page 2 of 2 02/25/2014 13:43:32 Report 22 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Palisades Inspection / Activity Plan 03/01/2014 - 06/30/2015 ISFSI

- ISFSI INSPECTION - SCHEDULE DEPENDENT 1

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

- RADIATION PROTECTION BASELINE INSPECTION 1

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

- FIRE PROTECTION INSPECTION AND BAG TRIP 1

1 IP Fire Protection [Triennial]

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

- RADIATION PROTECTION BASELINE INSPECTION 1

1 IP Radiation Monitoring Instrumentation 71124.05 03/30/2015 04/03/2015 BI EPR

- EP ROUTINE INSPECTION / PI VERIFICATION 2

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

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

IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 06/01/2015 06/05/2015 1

IP Performance Indicator Verification 71151 06/01/2015 06/05/2015 This report does not include INPO and OUTAGE activities.

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