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==SUBJECT:==
==SUBJECT:==
PALISADES NUCLEAR PLANT BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000 255/2014 5 02
PALISADES NUCLEAR PLANT BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000255/2014502


Dear Mr. Vitale
==Dear Mr. Vitale:==
: On October 31, 201 4 , the U.S. Nuclear Regulatory Commission (NRC) completed a n inspection at your Palisades Nuclear Plan The enclosed report documents the results of this inspection, which were discussed on October 31, 201 4, with you and other members of your staf The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your licens The inspectors reviewed selected procedures
On October 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. The enclosed report documents the results of this inspection, which were discussed on October 31, 2014, with you and other members of your staff.
, records, observed activities, and interviewed personne No findings were identified during this inspectio In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), 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).
 
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
 
The inspectors reviewed selected procedures, records, observed activities, and interviewed personnel. No findings were identified during this inspection.
 
In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's  
"Rules of Practice," a copy of this letter, its enclosure, and your response (if any), 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).


Sincerely,
Sincerely,
/RA/
/RA/  
R ichard A. Skokowski, Chief Plant Support Branch Division of Reactor Safety Docket No. 50-255 License N DPR-20  
 
Richard A. Skokowski, Chief Plant Support Branch Division of Reactor Safety Docket No. 50-255 License No. DPR-20  


===Enclosure:===
===Enclosure:===
Inspection Report 05000 255/20 1 4 5 0 2 w/Attachment: Supplemental Information
Inspection Report 05000255/2014502 w/Attachment: Supplemental Information  


REGION III==
REGION III==
Docket No: 50-255 License N o: DPR-20 Report No:
Docket No:
05000 255/201 4 5 0 2 Licensee: Entergy Nuclear Operations, In Facility: Palisades Nuclear Plant Location: Covert, MI Dates: October 2 7 - 31, 201 4 Inspectors:
50-255 License No:
R. Jickling, Senior Emergency Preparedness Inspector J. Lennartz , Acting Senior Resident Inspector J. Beavers, Emergency Preparedness Inspector K. Anderson , Physical Security Inspector R. Baker , Operations Engineer Approved by:
DPR-20 Report No:
R. Skokowski, Chief Plant Support Branch Division of Reactor Safety 2
05000255/2014502 Licensee:
Entergy Nuclear Operations, Inc.
 
Facility:
Palisades Nuclear Plant Location:
Covert, MI Dates:
October 27 - 31, 2014 Inspectors:
R. Jickling, Senior Emergency Preparedness Inspector  
 
J. Lennartz, Acting Senior Resident Inspector  
 
J. Beavers, Emergency Preparedness Inspector  
 
K. Anderson, Physical Security Inspector  
 
R. Baker, Operations Engineer Approved by:
R. Skokowski, Chief  
 
Plant Support Branch  
 
Division of Reactor Safety  


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000 255/201 4 50 2 , 10/2 7/201 4 - 10/31/201 4; Palisades Nuclear Plant
IR 05000255/2014502, 10/27/2014 - 10/31/2014; Palisades Nuclear Plant; Baseline Emergency


; Baseline Emergency Preparedness Exercise Evaluation- Hostile Action Event
Preparedness Exercise Evaluation - Hostile Action Event; Exercise Evaluation Scenario Review; and Performance Indicator Verification.
; Exercise Evaluation Scenario Review; and Performance Indicator Verification. This report covers a one-w eek period of announced baseline inspection by four regional inspectors, one resident inspector, and one emergency preparedness specialist. The significance of most findings is indicated by their color (i.e., Green, White, Yellow, and Red) using Inspection Manual Chapter 0609, "Significance Determination Process (SDP)."  Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
-1649, "Reactor Oversight Process," Revision 5 , dated February 20 14.


===A. NRC-Identified===
This report covers a one-week period of announced baseline inspection by four regional inspectors, one resident inspector, and one emergency preparedness specialist. The significance of most findings is indicated by their color (i.e., Green, White, Yellow, and Red)using Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.
and Self-Revealed Finding s
 
===NRC-Identified===
and Self-Revealed Findings


===Cornerstone: Emergency Preparedness===
===Cornerstone: Emergency Preparedness===
No findings were identified.
No findings were identified.


===B. Licensee-Identified Violations===
===Licensee-Identified Violations===
 
None
None 3


=REPORT DETAILS=
=REPORT DETAILS=


==REACTOR SAFETY==
==REACTOR SAFETY==
===Cornerstone: Emergency Preparedness===
{{a|1EP7}}


===Cornerstone:  Emergency Preparedness===
==1EP7 Exercise Evaluation - Hostile Action Event==
 
{{IP sample|IP=IP 71114.07}}
{{a|1EP}}
==1EP 7 Exercise Evaluation==
 
- Hostile Action Event (71114.0 7)


===.1 Exercise Evaluation===
===.1 Exercise Evaluation===
====a. Inspection Scope====
====a. Inspection Scope====
Title 10, Code of Federal Regulations (CFR), Part 50, Appendix E, Section IV.F.2.j, requires , in part, that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their Emergency Response Organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a Hostile Action (HA)
Title 10, Code of Federal Regulations (CFR), Part 50, Appendix E, Section IV.F.2.j, requires, in part, that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their Emergency Response Organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a Hostile Action (HA) Event directed at the plant site. Palisades Nuclear Plant designed the October 28, 2014, exercise to satisfy this requirement and the NRC inspected the Palisades Nuclear Plant HA Event exercise to assess the licensees ability to effectively implement their Emergency Plan during a HA Event and adequately protect public health and safety.
Event directed at the plant site.
 
Palisades Nuclear Plant designed the October 2 8 , 201 4 , exercise to satisfy this requirement and the NRC inspected the Palisades Nuclear Plant HA Event exercise to assess the licensee's ability to effectively implement their Emergency Plan during a HA Event and adequately protect public health and safety.


The exercise evaluation consisted of the following reviews and assessments:
The exercise evaluation consisted of the following reviews and assessments:
The adequacy of the licensee's performance in the biennial exercise conducted on October 2 8 , 2 01 4, regarding the implementation of the Risk
* The adequacy of the licensees performance in the biennial exercise conducted on October 28, 2014, regarding the implementation of the Risk-Significant Planning Standards in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and Protective Action Recommendations (PARs), respectively.
-Significant Planning Standards in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and Protective Action Recommendations (PAR s), respectively.
* The overall adequacy of the licensees emergency response facilities with regard to NUREG-0696, Functional Criteria for Emergency Response Facilities, and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Alternative Emergency Response Facility, Incident Command Post, Central Alarm Station, and the Emergency Operations Facility.
* A review of other performance areas such as the licensee EROs recognition of abnormal plant conditions; command and control, including interactions with site security staff; intra and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies, including local law enforcement agencies; staffing and procedure adequacy; and the overall implementation of the Emergency Plan and its implementing procedures.
* Past performance issues from NRC inspection reports to determine the effectiveness of corrective actions, as demonstrated during this exercise, to ensure compliance with 10 CFR 50.47(b)(14).
* The adequacy of the licensees post-exercise critiques, to evaluate Palisades Nuclear Plants self-assessment of its ERO performance during the October 28, 2014, exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g.


The overall adequacy of the licensee's emergency response facilities with regard to NUREG-0696, "Functional Criteria for Emergency Response Facilities," and Emergency Plan commitments. The facilities assessed were the Control Room Simulator , Alternative Emergency Response Facility, Incident Command Post
The inspectors reviewed various documents that are listed in the Attachment to this report.
, Central Alarm Station, and the Emergency Operations Facility.


A review of other performance areas such as the licensee ERO's recognition of abnormal plant conditions; command and control, including interactions with site security staff; intra and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies, including local law enforcement agencies; staffing and procedure adequacy; and the overall implementation of the Emergency Plan and its implementing procedures.
This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.07-06.
 
Past performance issues from NRC inspection reports to determine the effectiveness of corrective actions , as demonstrated during this exerci se , to ensure compliance with 10 CFR 50.47(b)(14).
 
The adequacy of the licensee's post
-exercise critiques, to evaluate Palisades Nuclear Plant
's self-assessment of its ERO performance during the October 2 8 , 2014, exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g.
 
4 The inspectors reviewed various documents that are listed in the Attachment to this report. This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.0 7-06.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1EP8}}
 
{{a|1EP}}
==1EP 8 Exercise Evaluation==


- Scenario Review (71114.08)
==1EP8 Exercise Evaluation - Scenario Review==
{{IP sample|IP=IP 71114.08}}


====a. Inspection Scope====
====a. Inspection Scope====
Prior to the inspection activity, the inspectors conducted an in
Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenarios submitted to the NRC using IP 71114.08, Exercise Evaluation - Scenario Review, to determine if the exercise would test major elements of the Emergency Plan as required by 10 CFR 50.47(b)(14). This inspection activity represents one sample on a biennial cycle. The inspectors reviewed various documents that are listed in the Attachment to this report.
-office review of the exercise objectives and scenario s submitted to the NRC using IP 71114.08, "Exercise Evaluation
- Scenario Review," to determine if the exercise would test major elements of the Emergency Plan as required by 10 CFR 50.47(b)(14). This inspection activity represents one sample on a biennial cycle. The inspectors reviewed various documents that are listed in the Attachment to this report.


This review of the exercise objectives and scenario constituted one sample as defined in IP 71114.08
This review of the exercise objectives and scenario constituted one sample as defined in IP 71114.08-06.
-06.


====b. Findings====
====b. Findings====
Line 113: Line 121:


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
===Cornerstone: Emergency Preparedness===
{{a|4OA1}}


===Cornerstone:  Emergency Preparedness===
{{a|4OA1}}
==4OA1 Performance Indicator Verification==
==4OA1 Performance Indicator Verification==
 
{{IP sample|IP=IP 71151}}
(71151)


===.1 Drill/Exercise Performance===
===.1 Drill/Exercise Performance===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP) Performance Indicator (PI) for the period from the third quarter 201 3 through the third quarter 201 4. Performance Indicator definitions and guidance contained in Nuclear Energy Institute (NEI) 99
The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP)
-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, were used to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during pre
Performance Indicator (PI) for the period from the third quarter 2013 through the third quarter 2014. Performance Indicator definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during pre-designated control room simulator training sessions, and performance during other drills. The inspectors also reviewed the Corrective Action Program (CAP) to determine if problems had been identified and corrected. Specific documents reviewed are listed in the Attachment to this report.
-designated control room simulator training sessions, and performance during other drills. The inspectors also reviewed the Corrective Action Program (CAP) to determine if problems had been identified and corrected. Specific documents reviewed are listed in the Attachment to this report
.


5 This inspection constituted one DEP sample as defined in IP 71151-05.
This inspection constituted one DEP sample as defined in IP 71151-05.


====b. Findings====
====b. Findings====
Line 135: Line 138:


===.2 Emergency Response Organization Drill Participation===
===.2 Emergency Response Organization Drill Participation===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the third quarter 201 3 through the third quarter 201 4. The PI data reported during those periods, PI definitions and guidance contained in NEI 99
The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the third quarter 2013 through the third quarter 2014. The PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used to determine the accuracy. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI; performance during the 2013 and 2014 drills; and revisions of the roster of personnel assigned to key emergency response organization positions. The inspectors also reviewed the CAP to determine if problems had been identified and corrected. Specific documents reviewed are listed in the Attachment to this report.
-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7 , were used to determine the accuracy. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI; performance during the 2013 and 2014 drills; and revisions of the roster of personnel assigned to key emergency response organization positions.
 
The inspectors also reviewed the CAP to determine if problems had been identified and corrected.
 
Specific documents reviewed are listed in the Attachment to this report.


This inspection constituted one ERO Drill Participation sample as defined in IP 71151-05.
This inspection constituted one ERO Drill Participation sample as defined in IP 71151-05.
Line 150: Line 147:


===.3 Alert and Notification System===
===.3 Alert and Notification System===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors sampled licensee submittals for the Alert and Notification System (ANS) PI for the period from the third quarter 201 3 through the third quarter 201 4. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99
The inspectors sampled licensee submittals for the Alert and Notification System (ANS)
-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7 , were used. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessin g opportunities for the PI and results of periodic scheduled ANS operability tests.
PI for the period from the third quarter 2013 through the third quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI and results of periodic scheduled ANS operability tests. The inspectors also reviewed the CAP to determine if problems had been identified and corrected. Specific documents reviewed are listed in the Attachment to this report.
 
The inspectors also reviewed the CAP to determine if problems had been identified and corrected.
 
Specific documents reviewed are listed in the Attachment to this report.


This inspection constituted one ANS sample as defined in IP 71151-05.
This inspection constituted one ANS sample as defined in IP 71151-05.
Line 163: Line 155:
====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|4OA6}}


{{a|4OA6}}
==4OA6 Management Meetings==
==4OA6 Management Meetings==
===.1===
===Exit Meeting Summary===
On October 31, 2014, the inspectors presented the biennial exercise inspection results to Mr. A. Vitale and other members of the licensee staff. The licensee acknowledged the issues presented.


===.1 Exit Meeting Summary===
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
 
On October 31, 201 4 , the inspectors presented the biennial exercise inspection results to Mr. A. Vitale and other members of the licensee staff. The licensee acknowledged the issues presented.


The inspectors confirmed that none of the potential report input discussed was considered proprietary
ATTACHMENT:  
. ATTACHMENT:


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


SUPPLEMENTAL INFORMATION
==KEY POINTS OF CONTACT==
KEY POINTS OF CONTAC
Licensee  
T Licensee  
: [[contact::A. Vitale]], Site Vice President  
: [[contact::A. Vitale]], Site Vice President  
: [[contact::A. Williams]], General Manager, Plant Operations
: [[contact::A. Williams]], General Manager, Plant Operations  
: [[contact::D. Corbin]], Senior Operations Manager
: [[contact::D. Corbin]], Senior Operations Manager  
: [[contact::R. Craven]], Production
: [[contact::R. Craven]], Production Senior Manager  
Senior Manager
: [[contact::T. Davis]], Regulatory Assurance  
: [[contact::T. Davis]], Regulatory Assurance
: [[contact::M. Fields]], Senior Emergency Planner  
: [[contact::M. Fields]], Senior Emergency Planner
: [[contact::O. Gustafson]], Performance Improvement & Regulatory Assurance Director  
: [[contact::O. Gustafson]], Performance Improvement
: [[contact::J. Hardy]], Regulatory Assurance Manager  
& Regulatory Assurance
: [[contact::J. Haumersen]], Projects Manager  
Director  
: [[contact::T. Higinbotham]], Emergency Planner  
: [[contact::J. Hardy]], Regulatory Assurance Manager
: [[contact::D. Lucy]], Outage Manager  
: [[contact::J. Haumersen]], Projects Manager
: [[contact::T. Higinbotham]], Emergency Planner
: [[contact::D. Lucy]], Outage Manager
: [[contact::D. Malone]], Emergency Preparedness Manager  
: [[contact::D. Malone]], Emergency Preparedness Manager  
: [[contact::T. Mulford]], Operations Manager
: [[contact::T. Mulford]], Operations Manager  
: [[contact::W. Nelson]], Training Manager
: [[contact::W. Nelson]], Training Manager  
: [[contact::A. Notbohm]], Performance Improvement
: [[contact::A. Notbohm]], Performance Improvement Manager  
Manager  
: [[contact::C. Plachta]], Quality Assurance Manager  
: [[contact::C. Plachta]], Quality Assurance Manager
: [[contact::N. Pope]], Corporate Emergency Preparedness  
: [[contact::N. Pope]], Corporate Emergency Preparedness
: [[contact::J. Ridley]], Senior Emergency Planner  
: [[contact::J. Ridley]], Senior Emergency Planner
: [[contact::D. Rogers]], Site Vice President Coordinator  
: [[contact::D. Rogers]], Site Vice President Coordinator
: [[contact::J. Standridge]], Corporate Projects  
: [[contact::J. Standridge]], Corporate Projects
: [[contact::J. Tharp]], Security Manager
: [[contact::J. Tharp ]], Security Manager
Nuclear Regulatory Commission  
Nuclear Regulatory Commission
: [[contact::J. Lennartz]], Acting Senior Resident Inspector  
: [[contact::J. Lennartz ]], Acting Senior Resident Inspector
 
LIST OF ITEMS OPENED, CLOSED, AND DISCUS
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
SED Opened, Closed, and Discussed
===Opened, Closed, and Discussed===
None
None  
LIST OF DOCUMENTS REVIEWED The following is a partial list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspector
 
s reviewed the documents in their entirety, but rather that selected sections or portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
==LIST OF DOCUMENTS REVIEWED==
1EP 7 Exercise Evaluation (71114.07)
-Palisades Nuclear Plant Site Emergency Plan; Revision 25
-EI-1; Emergency Classification and Actions; Revision 56
-EI-3; Communications and Notifications; Revision 31
-EI-4.3; Emergency Operations Facility Activation; revision 27
-EI-6.13; Protective Action Recommendations for Offsite Populations; Revision 23
-EI-11; Determination of Extent of Core Damage; Revision 7
-EI-12.1; Personnel Accountability and Assembly; Revision 18
-EI-14; Medical Care/Treatment of Contaminated, Injured Personnel; Revision 5
-AOP-42; Response to Aircraft Threats; Revision 1
-AOP-43; Response to
Non-Aircraft Threats; Revision 1
-AOP-44; Response to Attack on Palisades; Revision 1
-Two Years of Drill and Exercise Scenario Timelines; October 2012
- October 2014
-Two Years of Drill and Exercise Corrective Action Program Issues; October 2012
- October 2014
-CR-PLP-2014-05220; Exercise
-Did Not Implement Formal Guidance
to Reduce Onsite Protective Actions; October 30, 2014
-CR-PLP-2014-05218; Exercise
-Confusion Concerning Lack of 10 CFR 54(x)
Communications to Licensee ERFs and Notification of the NRC; October 30, 2014
-CR-PLP-2014-05196; Exercise
-Control Room Simulator Failed to Provide Accelerated Notifications
t o the NRC; October 29, 2014
-CR-PLP-2014-05195; Exercise
-Simulated Fire Truck Delayed Due To Lack in Pre
-Planning; October 29, 2014
-CR-PLP-2014-05194; Exercise
-Alternative ERF Delayed Dispatch
of a Response Team
Due to Problems with Briefings, Team Selection, a nd Coordination with ICP/LLEA; October 29, 2014
-CR-PLP-2014-05192; Exercise
-JIC Spokesperson Provided Inaccurate Information
during the Simulated Media Briefing; October 29, 2014
-CR-PLPL-2014-05191; Exercise
-AOP-44 Does Not Provide Recovery Section for Measures after an Event; October 29, 2014
1EP8 Exercise Evaluation
- Scenario Review
(71114.08)
-Palisades HAB Exercise 60 Day Scenario Submittal; August 2 6, 2014 4OA1 Performance Indicator Verification
(71151) -NRC Performance Indicator Data; Emergency Preparedness
- Drill/Exercise Performance; July 2013 - September 2014 NRC Performance Indicator Data; Emergency Preparedness
- ERO Participation;
September 2013 - September 2014 NRC Performance Indicator Data; Emergency Preparedness
- Alert and Notification System Reliability; July 2013 - September 2014
LIST OF ACRONYMS USE
D ADAMS Agencywide Documents Access and Management System
ANS Alert and Notification System
CAP Corrective Action Program
CFR Code of Federal Regulations
DEP Drill/Exercise Performance
DRS Division of Reactor Safety
ERO Emergency Response Organization
HA Hostile Action
IP Inspection Procedure
NEI Nuclear Energy Institute
NRC U.S. Nuclear Regulatory Commission PAR Protective Action Recommendation
PARS Publicly Available Records System
PI Performance Indicator
SDP Significance Determination Process


Mr. Anthony Vitale
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway
Covert, MI  49043
-953 0 SUBJECT:  PALISADES NUCLEAR PLANT
BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION
REPORT 05000 255/2014502 Dear Mr. Vitale
: On October 31, 201 4, the
: [[contact::U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. The enclosed report documents the results of this inspection]], which were discussed on October 31, 2014, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. No findings were identified during this inspection.
In accordance with 10
CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, and your response, if any, 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).
Sincerely,  /RA/  Richard
: [[contact::A. Skokowski]], Chief
Plant Support Branch
Division of Reactor Safety
Docket No. 50
-255 License No.
DPR-20 Enclosure:
Inspection Report 05000255/2014502  w/Attachment:  Supplemental Information
cc w/encl:  Distribution via LISTSERV  DOCUMENT NAME:
PALISADES 2014 502 (RDJ).docx
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 RJickling:
ls DFunk RSkokowski
DATE 1 1/10/14 1 1/12/14 1 1/13/14  OFFICIAL RECORD COPY
Letter to Anthony Vitale
from Richard
: [[contact::A. Skokowski dated November 13]], 2014 SUBJECT:  PALISADES NUCLEAR PLANT
BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000255/2014502 DISTRIBUTION
: John Jandovitz
RidsNrrPMPalisades Resource
RidsNrrDorlLpl3
-1 Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
Darrell Roberts
Steven Orth
Allan Barker
Carole Arian
o Linda Linn
DRPIII DRSIII Jim Clay Carmen Olteanu
ROPreports.Resource@nrc.gov
}}
}}

Latest revision as of 15:52, 10 January 2025

IR 05000255/2014502, 10/27/2014 - 10/31/2014; Palisades Nuclear Plant; Baseline Emergency Preparedness Exercise Evaluation Hostile Action Event; Exercise Evaluation Scenario Review; and Performance Indicator Verification
ML14317A335
Person / Time
Site: Palisades Entergy icon.png
Issue date: 11/13/2014
From: Richard Skokowski
Plant Support Branch II
To: Vitale A
Entergy Nuclear Operations
Robert Jickling
References
Download: ML14317A335 (12)
v • d • e


Text

November 13, 2014

SUBJECT:

PALISADES NUCLEAR PLANT BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000255/2014502

Dear Mr. Vitale:

On October 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. The enclosed report documents the results of this inspection, which were discussed on October 31, 2014, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures, records, observed activities, and interviewed personnel. No findings were identified during this inspection.

In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's

"Rules of Practice," a copy of this letter, its enclosure, and your response (if any), 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).

Sincerely,

/RA/

Richard A. Skokowski, Chief Plant Support Branch Division of Reactor Safety Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 05000255/2014502 w/Attachment: Supplemental Information

REGION III==

Docket No:

50-255 License No:

DPR-20 Report No:

05000255/2014502 Licensee:

Entergy Nuclear Operations, Inc.

Facility:

Palisades Nuclear Plant Location:

Covert, MI Dates:

October 27 - 31, 2014 Inspectors:

R. Jickling, Senior Emergency Preparedness Inspector

J. Lennartz, Acting Senior Resident Inspector

J. Beavers, Emergency Preparedness Inspector

K. Anderson, Physical Security Inspector

R. Baker, Operations Engineer Approved by:

R. Skokowski, Chief

Plant Support Branch

Division of Reactor Safety

SUMMARY OF FINDINGS

IR 05000255/2014502, 10/27/2014 - 10/31/2014; Palisades Nuclear Plant; Baseline Emergency

Preparedness Exercise Evaluation - Hostile Action Event; Exercise Evaluation Scenario Review; and Performance Indicator Verification.

This report covers a one-week period of announced baseline inspection by four regional inspectors, one resident inspector, and one emergency preparedness specialist. The significance of most findings is indicated by their color (i.e., Green, White, Yellow, and Red)using Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Emergency Preparedness

No findings were identified.

Licensee-Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Emergency Preparedness

1EP7 Exercise Evaluation - Hostile Action Event

Main article: IP 71114.07

.1 Exercise Evaluation

a. Inspection Scope

Title 10, Code of Federal Regulations (CFR), Part 50, Appendix E,Section IV.F.2.j, requires, in part, that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their Emergency Response Organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a Hostile Action (HA) Event directed at the plant site. Palisades Nuclear Plant designed the October 28, 2014, exercise to satisfy this requirement and the NRC inspected the Palisades Nuclear Plant HA Event exercise to assess the licensees ability to effectively implement their Emergency Plan during a HA Event and adequately protect public health and safety.

The exercise evaluation consisted of the following reviews and assessments:

  • The adequacy of the licensees performance in the biennial exercise conducted on October 28, 2014, regarding the implementation of the Risk-Significant Planning Standards in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and Protective Action Recommendations (PARs), respectively.
  • The overall adequacy of the licensees emergency response facilities with regard to NUREG-0696, Functional Criteria for Emergency Response Facilities, and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Alternative Emergency Response Facility, Incident Command Post, Central Alarm Station, and the Emergency Operations Facility.
  • A review of other performance areas such as the licensee EROs recognition of abnormal plant conditions; command and control, including interactions with site security staff; intra and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies, including local law enforcement agencies; staffing and procedure adequacy; and the overall implementation of the Emergency Plan and its implementing procedures.
  • Past performance issues from NRC inspection reports to determine the effectiveness of corrective actions, as demonstrated during this exercise, to ensure compliance with 10 CFR 50.47(b)(14).
  • The adequacy of the licensees post-exercise critiques, to evaluate Palisades Nuclear Plants self-assessment of its ERO performance during the October 28, 2014, exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g.

The inspectors reviewed various documents that are listed in the Attachment to this report.

This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.07-06.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation - Scenario Review

Main article: IP 71114.08

a. Inspection Scope

Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenarios submitted to the NRC using IP 71114.08, Exercise Evaluation - Scenario Review, to determine if the exercise would test major elements of the Emergency Plan as required by 10 CFR 50.47(b)(14). This inspection activity represents one sample on a biennial cycle. The inspectors reviewed various documents that are listed in the Attachment to this report.

This review of the exercise objectives and scenario constituted one sample as defined in IP 71114.08-06.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstone: Emergency Preparedness

4OA1 Performance Indicator Verification

Main article: IP 71151

.1 Drill/Exercise Performance

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP)

Performance Indicator (PI) for the period from the third quarter 2013 through the third quarter 2014. Performance Indicator definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during pre-designated control room simulator training sessions, and performance during other drills. The inspectors also reviewed the Corrective Action Program (CAP) to determine if problems had been identified and corrected. Specific documents reviewed are listed in the Attachment to this report.

This inspection constituted one DEP sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Emergency Response Organization Drill Participation

a. Inspection Scope

The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the third quarter 2013 through the third quarter 2014. The PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used to determine the accuracy. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI; performance during the 2013 and 2014 drills; and revisions of the roster of personnel assigned to key emergency response organization positions. The inspectors also reviewed the CAP to determine if problems had been identified and corrected. Specific documents reviewed are listed in the Attachment to this report.

This inspection constituted one ERO Drill Participation sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Alert and Notification System

a. Inspection Scope

The inspectors sampled licensee submittals for the Alert and Notification System (ANS)

PI for the period from the third quarter 2013 through the third quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI and results of periodic scheduled ANS operability tests. The inspectors also reviewed the CAP to determine if problems had been identified and corrected. Specific documents reviewed are listed in the Attachment to this report.

This inspection constituted one ANS sample as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1

Exit Meeting Summary

On October 31, 2014, the inspectors presented the biennial exercise inspection results to Mr. A. Vitale and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

A. Vitale, Site Vice President
A. Williams, General Manager, Plant Operations
D. Corbin, Senior Operations Manager
R. Craven, Production Senior Manager
T. Davis, Regulatory Assurance
M. Fields, Senior Emergency Planner
O. Gustafson, Performance Improvement & Regulatory Assurance Director
J. Hardy, Regulatory Assurance Manager
J. Haumersen, Projects Manager
T. Higinbotham, Emergency Planner
D. Lucy, Outage Manager
D. Malone, Emergency Preparedness Manager
T. Mulford, Operations Manager
W. Nelson, Training Manager
A. Notbohm, Performance Improvement Manager
C. Plachta, Quality Assurance Manager
N. Pope, Corporate Emergency Preparedness
J. Ridley, Senior Emergency Planner
D. Rogers, Site Vice President Coordinator
J. Standridge, Corporate Projects
J. Tharp, Security Manager

Nuclear Regulatory Commission

J. Lennartz, Acting Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and Discussed

None

LIST OF DOCUMENTS REVIEWED

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