CNRO-2013-00001, Confirmatory Order EA-10-090 EA-10-248 EA-11-106 Completion of Required Actions

Confirmatory Order EA-10-090 EA-10-248 EA-11-106 Completion of Required Actions

ML13113A014
Person / Time
Site:	Indian Point, Pilgrim, Vermont Yankee, FitzPatrick
Issue date:	04/22/2013
From:	Mccann J Entergy Nuclear Operations, Entergy Operations
To:	Bill Dean Region 1 Administrator
References
CNRO-2013-00001, EA-10-090, EA-10-248, EA-11-106, ENOC-13-00002
Download: ML13113A014 (7)

Text

April 22, 2013 Re: NRC Confirmatory Order EA-10-090/EA-10-248/EA-11-106 Completion of Required Actions Attached Letter received from Entergy, dated February 1, 2013, regarding the following Region I plants:

Vermont Yankee Nuclear Power Station Docket 50-271 Indian Point Nuclear Generating Station Units 2 and 3 Dockets 50-247 and 50-286 James A. FitzPatrick Nuclear Power Plant Docket 50-333 Pilgrim Nuclear Power Station Docket 50-293 ADAMS ACCESSION NO: ML13113A014

• ---Entergy Entergy Operations, Inc Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Tel 914272 3370 John F. McCann Vice President - Nuclear Safety, Emergency Planning and Licensing CNRO-20 13-0000 1 ENOC-13-00002 February 1,2013 Mr. William M. Dean Regional Administrator - Region I U. S. Nuclear Regulatory Commission 2100 Renaissance Boulevard King of Prussia, PA 19406

SUBJECT:

NRC Confirmatory Order EA*1 0-090 / EA*10*248 / EA*11*1 06 Completion of Required Actions Arkansas Nuclear One Indian Point Nuclear Generating Station Units 1 and 2 Units 2 and 3 Dockets 50-313 and 50-368 Dockets 50-247 and 50-286 Grand Gulf Nuclear Station James A. FitzPatrick Nuclear Power Plant Docket 50-416 Docket 50-333 River Bend Station Palisades Nuclear Plant Docket 50-458 Docket 50-255 Waterford Steam Electric Station - Unit 3 Pilgrim Nuclear Power Station Docket 50-382 Docket 50-293 Vermont Yankee Nuclear Power Station Docket 50-271

REFERENCE:

NRC letter to Entergy Nuclear Operations, Inc, William M. Dean to John T. Herron; Confirmatory Order and Notice of Violation - Inspection Report No. 05000333/2011009, dated January 26,2012 (ML120260627).

Dear Mr. Dean:

Entergy Operations, Inc and Entergy Nuclear Operations, Inc (Entergy) have completed the required actions of the referenced NRC Confirmatory Order and are providing this notification in accordance with Section V.G of the Order. A summary of the actions completed is provided in Attachment I.

CNRO-2013-00001 ENOC-13-00002 Page 2 of 2 There are no new commitments identified in this letter. If you have questions please contact Mr.

David Mannai, Senior Manager, Nuclear Safety & Licensing at 802-380-1175.

I declare under penalty of perjury that the foregoing is true and correct. Executed on fit I/. 'l.? I ~

Sincerely, J FM/djm Ikrk cc: Document Control Desk, USNRC

ATTACHMENT I TO CNROM2013-00001 / ENOC-13-00002 NRC CONFIRMATORY ORDER EA-10-090 / EA-10-248/ EA-11-106

SUMMARY

OF ACTIONS COMPLETED and ENTERGY NUCLEAR OPERATIONS, INC

CNRO-2013-00001 ENOC-13-00002 Attachment I Page 1 of 3 The following summarizes the actions completed by Entergy in response to NRC Order EA-1 0-090 / EA-10-248/ EA-11-1 06 (ML120260627). Documentation regarding these actions is available for NRC review.

Required Action V.A:

Entergy will review its existing fleet-wide general employee training to ensure adequate coverage of the lessons learned from the event that formed the basis for the Confirmatory Order (CO), regarding both procedural compliance and the requirement to maintain complete and accurate records in accordance with 10 CFR 50.9. Entergy will document the results of this review of the general employee training within 60 days after the issuance of the CO. If this review reveals a need to revise the general employee training, Entergy will make the appropriate revisions within 180 days of the date of the CO.

Entergy Response for V.A:

Entergy conducted a review of the general employee training material (GET) with respect to lessons-learned from the events pertaining to this Confirmatory Order. Several enhancements were identified to reinforce the importance of following procedures and maintaining complete and accurate records. The enhancements were incorporated into Revision 17 of the Entergy's GET module, FCBT-GET-PATSS.

Required Action V.B:

Entergy will prepare a case study about the event that formed the basis of the CO, highlighting the role of those who had the opportunity to detect, report, and prevent the misconduct, as well as on the actions of the individuals who engaged in the misconduct. The Site Vice President or General Manager for Plant Operations at each of Entergy's nine commercial nuclear power plants will present the case study during two station-wide meetings to ensure that both day and night shift personnel will have the opportunity to attend. Entergy will complete these presentations within 180 days of the date of the CO. Entergy will make this case study available for NRC review before conducting these station-wide meetings, and will notify the senior resident inspectors at each of the Entergy sites regarding the dates and time of these meetings at their respective sites.

Entergy Response for V.B:

Entergy developed a proposed case study and notified NRC via letter ENOC-12-018, dated May 23, 2012 (ML12229A157) regarding the availability of the case study. The station-wide meetings for Entergy's nine nuclear power plant sites were held in June and July 2012, where the Site Vice President or General Manager for Plant Operations presented the final Case Study materials.

Required Action V.C:

Within 90 days of the date of the CO, Entergy will add a commitment to the commitment tracking system to ma intC1.in thesaf~tY9LjltLjre. monitorino. Qrocesse~~g.~,~des~ribedin NEL 09-07 "Fost§'ring a~?trQDq ........ ~

.........~.~.~cn:;tear~Bre1y CurfCife,"(rrslmTJaTproc~sses~~aIEnfer97s~riln'ecommercIarnucle'ar power plantS'.

Entergy Response to V. C:

Entergy added a new commitment in the tracking system at each of Entergy's nine nuclear power plant sites, for maintaining the safety culture monitoring processes as described in NEI 09-07, or a similar process.

CNRO-2013-00001 ENOC-13-00002 Attachment I Page 2 of 3 Required Action V.D:

Within 90 days of the date of the CO, Entergy will review its procedure EN-QV-136, Nuclear Safety Culture Monitoring, which implements the safety culture monitoring pmcesses in NEI 09-07 "Fostering a Strong Nuclear Safety Culture," to determine whether the procedure (if that procedure had been in effect at the time of the violations) would have detected the safety culture weaknesses that led to the misconduct that formed the basis for the CO. If the review indicates that the implementation of that procedure may not have detected the weaknesses, Entergy will develop enhancements to the NEI process that would improve the ability to detect tho$e weaknesses and revise the Entergy procedure accordingly. Entergy will complete this procedure revision, if needed, within 120 days of the completion of that review. Additionally, within 30 days after revising its procedure, Entergy will provide the results of its review to NEI for its consideration in revising NEI document 09-07 "Fostering a Strong Nuclear Safety Culture." Entergy will make the results of this review available for NRC review.

Entergy Response for V.D:

Entergy conducted a review of EN-QV-136 using the snapshot self-assessment process and a six-person team consisting of four Entergy personnel, a utility peer, and an industry consultant with prior experience in safety culture monitoring processes. The review identified several proposed enhancements including an increased focus on the use of intuition and observation for 'faint signals' by station managers and a reduced emphasis on the collection and collation of hard data. Entergy revised EN-QV-136 to incorporate the recommendations from the assessment and issued the revised procedure with an effective date of July 11,2012. Entergy notified NRC and NEI regarding this review by letters dated August 3, 2012.

Reguired Action V.E:

Within 360 days of the date of the CO, Entergy will deliver a presentation to Regional Utility Groups (RUG) or Plant Managers Meetings at Regions I, II, III, and IV, which will discuss the events that led to this CO, the lessons learned, and actions taken. If any of the RUGS or Plant Managers Meetings schedules will not support completion of this action, Entergy will contact the Regional Administrator, Region I, to provide notice and to resolve the scheduling issue.

Entergy Response for V.E:

Entergy developed presentation materials suitable for the audience that attends the Regional Utility Groups (RUG) meetings regarding the Confirmatory Order and Entergy's lessons-learned and actions taken. The information was presented at the RUG meetings on the following dates:

RUG I June 26, 2012 RUG II August 28, 2012 RUG III June 26, 2012 RUG IV June 5, 2012 Required Action V.F:

Within 360 days of the date of the CO, Entergy will develop an assessment plan and conduct an assessment consistent with that plan of the RP Departments at the nine Entergy commercial nuclear power plants. That assessment will review the rigor with which members of the RP Departments perform and document routine department activities. If those assessments identify performance or documentation issues, Entergy will enter those issues into its Corrective Action Programs. Prior to the conduct of the first assessment, Entergy will make the assessment plan available to the NRC for review.

CNRO-20 13-0000 1 ENOC-13-00002 Attachment I Page 3 of 3 Entergy Response for V.F:

Entergy developed an assessment plan using the guidance in Entergy's internal procedure for the self-assessment and benchmarking process. Following review of the proposed plan by Entergy's Self Assessment Review Board, Entergy notified NRC via letter ENOC-12-021, dated June 21,2012 (ML12229A150) regarding the availability of the proposed assessment plan. Assessments at each of Entergy's nine nuclear power plant sites were conducted and documented during the period September 2012 to January 2013. Several assessments resulted in site-specific corrective actions to address areas for improvement and two fleet-wide action items were created for procedure improvements. In addition to the issues identified in the assessments, on January 30,2013, a contract worker at Arkansas Nuclear One mentioned a potential issue regarding a respirator fit test he had recently received at Waterford 3.

This issue has been entered into Entergy's corrective action program.