IR 05000255/2014502

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
Issue date:	11/13/2014
From:	Skokowski R A Plant Support Branch II
To:	Vitale A J Entergy Nuclear Operations
Robert Jickling
References
Download: ML14317A335 (12)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUIT E 210 LISLE, IL 60532

-4352 November 13, 2014 Mr. Anthony Vitale Vice President, Operations Entergy Nuclear Operations, In 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 255/2014 5 02 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

, 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).

Sincerely,

/RA/

R ichard A. Skokowski, Chief Plant Support Branch Division of Reactor Safety Docket No. 50

-255 License N DPR-20 Enclosure:

Inspection Report 05000 255/20 1 4 5 0 2 w/Attachment: Supplemental Information cc w/encl: Distribution via LISTSERV Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-255 License N o: DPR-20 Report 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:

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 2

SUMMARY OF FINDINGS

IR 05000 255/201 4 50 2 , 10/2 7/201 4 - 10/31/201 4; Palisades Nuclear Plant

Baseline Emergency Preparedness Exercise Evaluation- Hostile Action Event

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

and Self-Revealed Finding s

Cornerstone: Emergency Preparedness

No findings were identified.

B. Licensee-Identified Violations

None 3

REPORT DETAILS

1EP 7 Exercise Evaluation

- Hostile Action Event (71114.0 7)

.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 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 adequacy of the licensee's performance in the biennial exercise conducted on October 2 8 , 2 01 4, 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 (PAR s), respectively.

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

, 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.

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

No findings were identified.

1EP 8 Exercise Evaluation

- Scenario Review (71114.08)

a. Inspection Scope

Prior to the inspection activity, the inspectors conducted an in

-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

-06.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

(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 201 3 through the third quarter 201 4. 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 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

-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.

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 201 3 through the third quarter 201 4. 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 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.

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 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

-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.

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, 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:

SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTAC

T 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 DISCUS

SED Opened, Closed, and Discussed

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.

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

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

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

A. Skokowski dated November 13, 2014 SUBJECT: PALISADES NUCLEAR PLANT

BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000255/2014502 DISTRIBUTION

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