0CAN101003, 10 CFR 50.59 Summary Report and Commitment Change Summary Report

10 CFR 50.59 Summary Report and Commitment Change Summary Report

ML102800590
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/07/2010
From:	Pyle S Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
0CAN101003
Download: ML102800590 (17)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Acting Manager, Licensing Arkansas Nuclear One 0CAN101003 October 7, 2010 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

10 CFR 50.59 Summary Report and Commitment Change Summary Report Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

Dear Sir or Madam:

In accordance with 10 CFR 50.59(d)(2), enclosed is the Arkansas Nuclear One - Unit 1 (ANO-1) 10 CFR 50.59 summary report for the time period ending October 7, 2010. This report contains a brief description of changes in procedures, the facility as described in the ANO-1 Safety Analysis Report (SAR), changes in the ANO-1 Technical Requirements Manual (TRM), and changes in the ANO-1 Technical Specification (TS) Bases, where a safety evaluation was conducted. The report also contains a description of tests and experiments conducted, if any, which were not described in the SAR, and other changes to the SAR for which a safety evaluation was conducted. A copy of each safety evaluation, both ANO-1 specific and those evaluations common between ANO-1 and ANO - Unit 2 (ANO-2), as applicable, is included in Attachment 1.

Included in Attachment 2 is the Commitment Change Summary Report for ANO-1 and ANO-2.

These changes are submitted in accordance with the guidance provided in NEI 99-04, Guidelines for Managing NRC Commitment Changes. The report lists each commitment changed since submittal of the previous report and provides a basis for each change.

If you have any questions or require additional information, please contact me.

Sincerely, ORIGINAL SIGNED BY STEPHENIE L. PYLE SLP/dbb Attachments:

1. 10 CFR 50.59 Summary Report

2. ANO-1 and ANO-2 Commitment Change Summary Report

0CAN101003 Page 2 of 2 cc: Mr. Elmo Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8 B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

Attachment 1 to 0CAN101003 10 CFR 50.59 Summary Report to 0CAN101003 Page 1 of 6 ANO 10 CFR 50.59 Summary Report 50.59 # 50.59 Summary 08-005 Engineering Change EC-2243, "Reactor Building Sump GSI-191 Compliance"

ANO 50.59 Evaluation Number 09-001

10 CFR 50.59 EVALUATION FORM Sheet 1 of 4 I. OVERVIEW / SIGNATURES1 Facility: ANO Unit 1 Evaluation # / Rev. #: 09-001 Proposed Change / Document: EC-13439 Description of Change:

For ALARA concern, this EC proposes to remove two highly radioactive hot spots: (1) ASME Class 1 pressurizer surge line drain 1CCA-13-1", including valves RBD-4 and RBD-5 and (2) Reactor Building Drain Header non-Q HSD-5-4" straight pipe containing valve RBD-25. Removal of RBD-25 is clearly below the level of details of the Unit 1 UFSAR since the function of RBD-25 is not described in any level of details in the LBDs. The function of the surge line drain is described in Section 4.2.2.4 of the UFSAR.

Therefore, the scope of this 10CFR 50.59 evaluation is to evaluate the removal of the surge line.

Is the validity of this Evaluation dependent on any other change? Yes No If Yes, list the required changes/submittals. The changes covered by this 50.59 Evaluation cannot be implemented without approval of the other identified changes (e.g., license amendment request). Establish an appropriate notification mechanism to ensure this action is completed.

Based on the results of this 50.59 Evaluation, does the proposed change Yes No require prior NRC approval?

Preparer: Raymond To/Jerry Howell / IAS signature / DE Civil / Mechanical / 06-17-09 Name (print) / Signature / Company / Department / Date Reviewer: Mark Harris / IAS signature / DE Mechanical / 06-17-09 Name (print) / Signature / Company / Department / Date OSRC: J. R. Eichenberger / ORIGINAL SIGNED BY J. R. EICHENBERGER / 06-25-09 Chairmans Name (print) / Signature / Date OSRC-09-017 OSRC Meeting #

1 Signatures may be obtained via electronic processes (e.g., PCRS, ER processes), manual methods (e.g., ink signature), e-mail, or telecommunication. If using an e-mail or telecommunication, attach it to this form.

EN-LI-101-ATT-9.1, Rev. 5

10 CFR 50.59 EVALUATION FORM Sheet 2 of 4 II. 50.59 EVALUATION Does the proposed Change being evaluated represent a change to a method of Yes evaluation ONLY? If Yes, Questions 1 - 7 are not applicable; answer only Question No

8. If No, answer all questions below.

Does the proposed Change:

1. Result in more than a minimal increase in the frequency of occurrence of an accident Yes previously evaluated in the UFSAR? No BASIS:

Using the 1CCA-13-1" surge drain line to drain the pressurizer is described in Section 4.2.2.4 of the UFSAR as follows Vent and drain lines are shown on the system diagram, Figure 4-1. They are located at high and low points of the system and provide the means for draining, filling, and venting the heat transport loops and pressurizer." Removal of the drain line does eliminate a drain function described in the UFSAR. However, based on ANO-1 operational experience, this drain line only performs an infrequent maintenance function of draining the pressurizer and this design function can be accomplished by other means during an outage (refer to EC13439). Review of the Unit 1 UFSAR indicated that the surge line drain is not described or credited for any Safety Analysis or accidents depicted in Chapter 14 of the UFSAR. As such, removal of this drain line will not result in any increase in frequency of occurrence of an accident previously evaluated in the UFSAR.

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction Yes of a structure, system, or component important to safety previously evaluated in the No UFSAR?

BASIS:

The 1 diameter ANSI B31.7 Class 1 surge line drain piping is attached to a 10 schedule 140 RCS pipe (pressurizer surge line) and was previously qualified per ASME Class 2 rules (based on small size) to meet Code stress allowables, thereby maintaining the structural integrity of the RCS pressure boundary. The removed pipe will be replaced by a more robust ASME Class 1 plug and its welded attachment has been qualified (CALC-86-E-0074-93) to withstand the only significant load (pressure) with a stress margin of 10. Removing the drain pipe eliminates the high thermal expansion and stratification loads previously acting on the drain nozzle. The mass effect of this 1 diameter seismically supported drain on the RCS Loop is insignificant and the removal of this mass has negligible effects on RCL Response Spectrum analysis results. Therefore, the action of removing the surge line drain will not result in any increase in the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the UFSAR.

3. Result in more than a minimal increase in the consequences of an accident previously Yes evaluated in the UFSAR? No BASIS:

The surge line drain is not described in or credited in any Safety Analysis for mitigations of any accident depicted in Chapter 14 of the UFSAR. The change would not adversely affect on-site or offsite dose during any postulated accident. Removal of the surge line drain eliminates several highly radioactive crud traps, resulting in significant reduction of on-site dose during normal maintenance activities. Therefore, eliminating this drain line will not result in any increase in the consequences of an accident previously evaluated in the UFSAR.

10 CFR 50.59 EVALUATION FORM Sheet 3 of 4

4. Result in more than a minimal increase in the consequences of a malfunction of a Yes structure, system, or component important to safety previously evaluated in the No UFSAR?

BASIS:

Removing the surge line drain replaces several feet of piping and two manual valves that currently have accumulation of highly radioactive materials with a more robust welded plug. The new welded plug will be inserted through the entire length of the nozzle and is flush with the inside wall of the 10 diameter surge line, thus minimizing the possibility of forming a new crude trap. If the RCS pipe were to fail in the drain nozzle area, the amount of release of radioactive material would be greatly reduced with the new configuration. Therefore the dose rate from a failure of the pressure boundary would not be increased. As such, removing the drain pipe will not result in any increase in the consequences of a malfunction of a structure, system, or component important to safety previously evaluated in the UFSAR.

5. Create a possibility for an accident of a different type than any previously evaluated in the Yes UFSAR? No BASIS:

The surge line drain piping is being removed and the nozzle is being plugged. No new piping is being added and the draining function of the line is being eliminated. Since no new functions are being added, the amount of piping exposed to RCS pressure is not increased and the proposed change is qualified to ASME Section III Class 1 requirements, it is not credible that a new accident scenario is being created. Therefore, the action of removing the surge line drain will not create a possibility for an accident of a different type than any previously evaluated in the UFSAR.

6. Create a possibility for a malfunction of a structure, system, or component important to Yes safety with a different result than any previously evaluated in the UFSAR? No BASIS:

The 1 diameter ANSI B31.7 Class 1 surge line drain piping is attached to a 10 schedule 140 RCS pipe (pressurizer surge line) and was previously qualified per ASME Class 2 rules (based on small size) to meet Code stress allowables, thereby maintaining the structural integrity of the RCS pressure boundary. The removed pipe which includes several welded joints, five pipe supports and two normally closed manual valves (RBD-4 and RBD-5) will be replaced by a more robust ASME Class 1 plug and a welded attachment design that has been qualified to ASME requirements (CALC-86-E-0074-93) to withstand the only significant load (ejection pressure) with a stress margin of 10. Removing the drain pipe also eliminates the high thermal expansion and stratification loads previously acting on the drain nozzle. The proposed modification will perform the same pressure boundary function during an event or a postulated accident and will not create a possibility for a malfunction of a SSC important to safety with a different result than previously evaluated in the UFSAR.

10 CFR 50.59 EVALUATION FORM Sheet 4 of 4

7. Result in a design basis limit for a fission product barrier as described in the UFSAR Yes being exceeded or altered? No BASIS:

The 1 diameter ANSI B31.7 Class 1 surge line drain piping is attached to a 10 schedule 140 RCS pipe (pressurizer surge line) which is a fission product barrier. This drain line was previously qualified per ASME Class 2 rules (based on small size) to meet Code stress allowable, thereby maintaining the function of acting as a fission product barrier. The removed pipe which includes several welded joints, five pipe supports and two manual valves will be replaced by a more robust ASME Class 1 plug and a welded attachment design that has been qualified (CALC-86-E-0074-93) to withstand the only significant load (ejection pressure) with a stress margin of 10. Removing the drain pipe also eliminates the high thermal expansion and stratification loads previously acting on the drain nozzle. Therefore, structurally, the new plug design is a much stronger fission product barrier than the removed drain pipe. As such, the action of removing the surge line drain will not result in a design basis limit for a fission product barrier as described in the UFSAR being exceeded or altered.

8. Result in a departure from a method of evaluation described in the UFSAR used in Yes establishing the design bases or in the safety analyses? No BASIS:

The Surge Line Drain was previously qualified using ASME Class 2 rules using the temperature range exemption criteria provided in ASME Section III, NB-3630 in CALC-86-E-0074-93. A computerized 3-D seismic analysis was performed to calculate pipe stresses and support loads for the qualification of the drain system. The drain nozzle was qualified in vendor calculation CALC E-0074-92 using ASME Section III, NB-3600 rules. With the drain pipe removed, the only remaining components are the existing 1 drain nozzle, an existing 1 6000# coupling and a new 1 welded plug. Due to the simplicity of the new configuration and the significant load reduction, the qualification approach for the two remaining surge line end pieces consisted of load comparison and a manual weld qualification. This simplified analysis approach reflects the simplicity of the new configuration and does not depart from ANO licensed methodology. The stress acceptance criteria remain the same, i.e. using the ASME Class 2 rules. As such, removal of the surge line drain does not result in a departure from a method of evaluation described in the UFSAR used in establishing the design bases of the drain line.

If any of the above questions is checked Yes, obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure EN-LI-103.

Attachment 2 to 0CAN101003 ANO-1 and ANO-2 Commitment Change Summary Report to 0CAN101003 Page 1 of 7 ANO-1 and ANO-2 Commitment Change Summary Report NUMBER DESCRIPTION REASON FOR CHANGE 15790 Conduct ultrasonic (UT) exams of The manual UT examination per procedure OP-1415.032 is no pressurizer upper level tap. This inspection longer required based on the evaluations provided by calculation allows deferral of permanent repair. UT CALC-86-E-0074-143 and CALC-86-E-0074-157. Three UT exams on the pressurizer upper level tap exams with a detection limit of 5 mils have been performed over shall be conducted in accordance with ANO the last 18 years with no evidence of degradation. As part of calculation 86E-0074-103, memorandum EC-12490, nozzle replacement, the area of concern will be ANO-92-00507, and the NRC submittal visually inspected. Should areas of wastage be indentified, a new dated August 5, 1993 (1CAN089302). condition report (CR) will be generated, along with corrective actions, to address the issue. It is no longer necessary to track the previous requirement as a commitment and, therefore, this commitment is deleted.

1883 In response to Inspection Report IR 50-313/ This commitment is almost 20 years in age and has no safety 368 91-006-00, the ANO welder training significance. The original commitment was implemented in the program is revised to ensure that the early 90's time frame with no other commitments once the ANO appropriate craft personnel are sensitized to training program/procedure was revised. Section 6.3.3.b of detecting piping defects. The revised OP-5120.119 discusses the requirement and responsibility for program will be implemented by craft welders for detecting potential material defects. This September 30, 1991. commitment deletion will not have any negative impact on the implementation nor maintenance of the ANO welding program as it relates to the commitment. Since this commitment is > 2 years old, has no safety significance and is implemented in an ANO procedure, it is no longer necessary to track this item as a regulatory commitment.

1918 Procedure 1107.001 has been revised to This commitment is proceduralized in OP-1107.001 and add a caution statement concerning 2107.001. Any changes to these instructions are subject to potential overload conditions and to prevent management approval and the 10 CFR 50.59 process. Since this cross-tie of the 480 volt load center above commitment is > 2 years old and is implemented in an ANO cold shutdown conditions without the procedure, it is no longer necessary to track this item as a approval of the Operations Manager or regulatory commitment. Therefore, this commitment is deleted.

except as required in an emergency.

to 0CAN101003 Page 2 of 7 NUMBER DESCRIPTION REASON FOR CHANGE 2169 As discussed in the exit meeting for This commitment is included in the steps of the EFIC procedures Inspection Report IR 50-313; 50-368/90- and is well ingrained into the procedures and Entergy processes.

015-00, a review of the emergency The commitment is > 2 years old and no longer needed to be feedwater instrumentation and control tracked. Therefore, this commitment is deleted.

(EFIC) calibration procedure was performed to identify steps that cause equipment actuation.

2255 As part of the corrective actions to Licensee A site / discipline specific procedure OP-5220.002 was issued on Event Report (LER) 50-313/91-008-00, 2/5/1992 for equipment/component seismic evaluation. In 1996, design review requirements for design ANO engineering standard CES-18 was issued to provide change package development will be guidelines for seismic evaluation of equipment and components.

clarified by December 31, 1991 to ensure CES-18 incorporated all the technical information provided in clear and specific instructions are provided OP-5220.002 and also referenced 1CAN019202. Since then, concerning the qualified configuration of CES-18 has been used for evaluating and qualifying seismic components or systems. components and equipment. The design change process has continued to evolve and more rigorous design review has been implemented. Fleet wide procedures such as EN-DC-134 ensure design verification for all safety related plant changes. Also, the impact screening criteria of EN-DC-115 prompts the required reviews from different disciplines for any plant change. Because the evaluation process is adequately covered within fleet procedures and the ANO engineering standard, this commitment may be deleted.

2880 As discussed in the exit meeting for Emergency planning maintains form 1903.023C, Emergency inspection report IR 50-313; 50-368 Medical Team Scene Leader Checklist, which is used by the 92-003-00, evaluate the medical team medical team scene leader to ensure actions of the medical team procedure checklists and make any are completed appropriately. This is now an expected practice by necessary improvements to facilitate the the medical team. Identifying this as a commitment is no longer medical team leaders role. needed. Therefore, this commitment is deleted.

to 0CAN101003 Page 3 of 7 NUMBER DESCRIPTION REASON FOR CHANGE 3321 Modify appropriate ANO-1 maintenance This commitment is included in the steps of the EFIC procedures procedures to include additional Regulatory and is well ingrained in Entergy processes. The commitment is Guide (RG) 1.97 instrument testing. > 2 years old and no longer need to be tracked. Therefore, this commitment is deleted.

4075 Procedure 1063.021 will be revised by The badging process (e.g., EN-NS-106 & EN-TQ-107) was 02/01/81 to require GET (General Employee revised years ago to require that anyone (e.g., Entergy, Training) annual retraining for full-time, contractor), except the NRC, requesting unescorted access to the non-AP&L (Entergy) personnel. protected area receive training both initially and periodically. The current emergency plan training procedure ENS-TQ-110 requires personnel who perform a role in the emergency response organization (ERO) inside the protected area initially complete plant access training and radiation worker training. The procedure also requires that this training must be renewed each calendar year. This requirement has been ingrained in Entergy procedures long enough that this commitment is no longer necessary. Therefore, this commitment is deleted.

4111 Procedure 1063.021, Emergency Response The training procedure was first revised to require minimum Training Program, will be revised to functional training prior to qualification and additional training enhance the training requirements for within the first year of assignment. The program now requires personnel assigned to the ERO. multiple essential training courses, position-specific courses, walkthroughs, and drills in order to qualify to perform an ERO role. These requirements have long been ingrained in Entergy procedures. Therefore, this commitment is deleted.

4175 Provide training and retraining of personnel Procedure 1063.021 was revised to describe the assignment of that are responding to an ANO facility in an specific responsibilities for training duties, the initial and annual emergency. retraining of ANO site personnel, annual training of offsite personnel, and the conduct of drills and exercises. These requirements have been maintained in the training procedure for well over and above the current two-year requirement stated in EN-LI-110. Because these requirements have long been ingrained in Entergy procedures, this commitment is deleted.

to 0CAN101003 Page 4 of 7 NUMBER DESCRIPTION REASON FOR CHANGE 4179 Evaluate the status of offsite response Offsite agency team training as performed by the Arkansas personnel training. Nuclear Planning & Response Program was specifically identified in Attachment 3 of training procedure 1063.021 as required by this commitment. This attachment contains a list of the specific courses taught with a synopsis of the course content. This requirement has been maintained in the training procedure for well over and above the current two-year requirement stated in EN-LI-110. Because this requirement has long been ingrained in Entergy procedures, this commitment is deleted.

4822 Additional requirements for training offsite Offsite monitoring team training requirements for completion of monitoring teams have been identified. various computer-based training (CBT) courses, lectures, and a These requirements largely consist of position specific walkthrough are contained in the training practical training sessions for the monitoring procedure. The initial emergency response training requirements team members. must be completed prior to initially receiving a letter of assignment to the emergency response organization. In addition, the procedure requires semi-annual health physics field monitoring drills. The procedure also requires that a person either attend classroom training or complete a position workbook and participate in at least one drill or facility walkthrough each year for periodic retraining. These requirements have been maintained in the training procedure for well over and above the current two-year requirement stated in EN-LI-110. Because these requirements have long been ingrained in Entergy procedures, this commitment is deleted.

5432 A corrective action review board (CARB) has Commitment is well established in ANO and Entergy processes been established to review significant CR and has been in place for many years. Because this requirement root cause determinations and proposed has long been ingrained in Entergy processes, this commitment is corrective actions. The CARB is chaired by deleted.

the affected unit's General Manager, or designee.

to 0CAN101003 Page 5 of 7 NUMBER DESCRIPTION REASON FOR CHANGE 5635 Add field and vendor weld identifiers to This commitment is almost 20 years in age and has no safety piping isometric drawings. significance. Corrective actions were taken which corrected the condition and engineering standard SES-19, Documentation of Heat Numbers, Material Traceability and Weld Numbers, was established for the control of plant drawings. Control of field weld numbers on controlled plant drawings is currently implemented in accordance with ANO procedure OP-5120.120, Attachment 11.

Because this requirement has long been ingrained in Entergy procedures, this commitment is deleted.

7016 Revise plant cooldown procedure to require The procedure has been changed to close the MFW isolation closing containment MFW isolation valves to valves prior to less then 800 psia in the SG. This will ensure the Steam Generators (SG) prior to plant valves are closed prior to reaching condensate pump shutoff cooldown. head. Because this requirement has long been ingrained in Entergy procedures, this commitment is deleted.

7332 Change Core Protection Calculator (CPC) This commitment is included in the steps of the CPC procedures.

test and calibration, and Control Element It is well ingrained into the procedures and Entergy processes.

Assembly Calculator (CEAC) calibration The commitment is > 2 years old and no longer needs to be procedures to require placing CPCs in tracked. Therefore, the commitment is deleted.

INOP.

8771 Develop calibration procedure to input test This commitment is included in the steps of the EFIC procedures.

signals to EFIC control module and verify It is well ingrained into the procedures and Entergy processes.

appropriate control module responses. The commitment is > 2 years old and no longer needs to be tracked. Therefore, the commitment is deleted.

8968 Provide training and periodic retraining on The requirement is greater than 2 years old and is ingrained into department of transportation (DOT) and procedures and the qualification matrix. Plateau provides details NRC regulatory requirements concerning on the training requirements and qualification status of personnel low-level radwaste. who are qualified to ship radioactive material. No further tracking of this commitment is required. Therefore, the commitment is deleted.

to 0CAN101003 Page 6 of 7 NUMBER DESCRIPTION REASON FOR CHANGE 9186 CPC surveillance procedures changed to This commitment is included in the steps of the CPC procedures.

require verification of channel operability It is well ingrained into the procedures and Entergy processes.

prior to removing channel from bypass. The commitment is > 2 years old and no longer needs to be tracked. Therefore, the commitment is deleted.

9420 Provide additional controls on the use of This commitment is included in the steps of the CPC procedures.

addressable constant disks and It is well ingrained into the procedures and Entergy processes.

develop/revise procedures accordingly. The commitment is > 2 years old and no longer needs to be tracked. Therefore, the commitment is deleted.

9423 Generate new Type II addressable constant This commitment is included in the steps of the CPC procedures.

disks prior to approach to criticality following It is well ingrained into the procedures and Entergy processes.

refueling. The commitment is > 2 years old and no longer needs to be tracked. Therefore, the commitment is deleted.

9460 Procedure 1903.023 revised to advise Shift Form 1903.0238, Personnel Emergency Checklist - Shift Supervisor or designee to use plant paging Manager, contains instructions to make a plant page to notify system to activate medical team. medical team members when a medical event occurs. This is a common practice by the Operations personnel for not only medical emergencies, but for other emergences. Tracking this commitment in the procedure is no longer needed. Therefore, the commitment is deleted.

10866 Complete emergency response lesson plans Lesson plan series beginning ASCBT-EP and ASLP-EP have by 12-31-82 and implement emergency plan been developed and used for years to provide the necessary training for response personnel. training to personnel assigned to the ERO. These requirements have been ingrained in procedures long enough that this commitment should no longer be necessary. Therefore, the commitment is deleted.

13216 Revise Log OPS-B6 taken using hand held The process of checking for out of tolerance log readings against computer to automatically compare readings tolerance bands is a part of the electronic log process. This and flag an out of tolerance reading. Logs to eliminates human error. Therefore, the commitment is deleted.

be reviewed shiftly.

to 0CAN101003 Page 7 of 7 NUMBER DESCRIPTION REASON FOR CHANGE 13850 Procedure 5120.119, control of plant welding This commitment is almost 20 years in age and has no safety was developed and revised to require the significance. The current location where this is addressed is in use of calibrated ammeters. ANO procedure OP-5102.119, Section 6.4.5.c. Since this commitment is > 2 years old and is implemented in an ANO procedure, it is no longer necessary to track this item as a regulatory commitment. Therefore, the commitment is deleted.

14914 Revise EFIC test procedures to standardize This commitment is included in the steps of the EFIC procedures.

conditional statements and to separate It is well ingrained in the procedures and Entergy processes. The portions to be performed during plant commitment is > 2 years old and no longer needs to be tracked.

shutdown and power operations. Therefore, the commitment is deleted.

15650 Develop and implement an instrumentation This commitment is included in the steps of the CPC procedures.

and control (I&C) directive to require 2nd It is well ingrained in the procedures and Entergy processes. The person review. commitment is > 2 years old and no longer needs to be tracked.

Therefore, the commitment is deleted.

15666 Develop and implement I&C directive This commitment is included in the steps of the CPC procedures.

containing expectations for taking credit for It is well ingrained in the procedures and Entergy processes. The steps in one procedure that were conducted commitment is > 2 years old and no longer needs to be tracked.

in another. Therefore, the commitment is deleted.

16228 Procedure changes were implemented to This commitment is included in the steps of the EFIC procedures.

clearly specify depressing the reset toggle It is well ingrained in the procedures and Entergy processes. The switch when resetting the Emergency commitment is > 2 years old and no longer needs to be tracked.

Feedwater (EFW) trip modules. Therefore, the commitment is deleted.