ENOC-10-00030, Entergy Response for Action 6 of Confirmatory Order EA-09-060

Entergy Response for Action 6 of Confirmatory Order EA-09-060

ML102570812
Person / Time
Site:	Palisades
Issue date:	09/08/2010
From:	Mccann J Entergy Nuclear Operations, Entergy Operations
To:	Satorius M Region 3 Administrator
References
EA-09-060, ENOC-10-00030
Download: ML102570812 (13)

Text

Entergy Operations, Inc EntergV Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains N Y 10601 Tel 914 272 3 3 7 0

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John F. McCann Vice President - Nuclear Safety Emergency Planning and Licensing ENOC- 10-00030 September 8, 201 0 Mr. Mark A. Satorius Regional Administrator, Region Ill U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 21 0 Lisle, IL 60532-4352

SUBJECT:

Enterqy Response for Action 6 of Confirmatory Order EA-09-060 Palisades Nuclear Plant Docket No. 50-255 License No. DPR-20

References:

1. NRC letter dated November 10, 2009; Mark A. Satorius to Entergy Nuclear Operations, Inc; regarding Confirmatory Order EA-09-060.

Dear Sir:

Entergy is providing the attached proposed presentation in accordance with Action 6 of the Confirmatory Order (Reference 1), which states:

Entergy shall provide a lessons-learned presentation to the Regional Utility Groups for the NRC Regions in which Entergy operates nuclear facilities within one year of the date of the issuance of the Confirmatory Order. That lessons-learned presentation shall address the events which gave rise to the Confirmatory Order and the corrective actions taken. Entergy shall provide a copy of the proposed presentation to the Regional Administrator, Region I l l , for review prior to the presentation.

The attached lessons-learned presentation addresses the events which gave rise to the Confirmatory Order and the corrective actions taken. Entergy will present this information to the Regional Utility Groups (RUG I, Ill, and IV) by end of day November 10, 2010. The first presentation is scheduled for October 12, 201 0 with RUG I.

ENOC-10-00030 Page 2 of 2 There are no new commitments identified in this letter. If you have questions regarding this proposed presentation please contact Edward Weinkam, Senior Manager, Licensing at 612-840-8181.

I declare under penalty of perjury that the foregoing is true and correct. Executed on q/</aio lJFM / ew / krk

Attachment:

Proposed Presentation NRC Order EA-09-060 Lessons-Learned and Compliance with 10 CFR 50.9 cc:

Document Control Desk, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC Site Vice President, Palisades, Entergy NSA Director, Palisades, Entergy Licensing Manager, Palisades, Entergy

ATTACHMENT I TO ENOC-10-00030 PROPOSED PRESENTATION TO REGIONAL UTILITY GROUPS FOR REGIONS I, Ill, AND IV NRC ORDER EA-09-060 LESSONS LEARNED AND COMPLIANCE WITH 10 CFR 50.9 ENTERGY NUCLEAR OPERATIONS, INC PALISADES NUCLEAR PLANT DOCKET 50-255 LICENSE DPR-20

NRC ORDER EA-09-060 LESSONS-LEARNED AND COMPLIANCE WITH 10 CFR 50.9 PALISADES NUCLEAR PLANT Entergy Nuclear, Inc Presentation to RUG I, Ill, and IV PURPOSE To provide the RUG:

An understanding of the events which led the NRC to issue a Confirmatory Order to Entergy in November 2009; and An overview of the key lessons learned and corrective actions.

2

THE EVENT BACKGROUND Entergy purchased Palisades in April 2007 Security challenges noted in Due Diligence Multiple changes in Palisades Security management occurred during the transition Entergy corporate Security management increased oversight at Palisades 3

THE EVENT Chronology of Key Events Entergys Director, Nuclear Security led an informal self assessment of Palisades S e a rity in October 2007 An issue regarding a security system power supply was identified during the assessment Misunderstanding affected managements response to the issue 4

THE EVENT Chronology of Key Events (continued)

Initial response to concern:

Director ordered the Security Specialist to write a Condition Report.

Director also instructed a Security Specialist to work with Palisades Engineering to obtain a technical evaluation.

5 THE EVENT Chronoloqv of Key Events (continued)

CR-PLP-2007-05448 (Oct. 24, 2007)

Condition

Description:

"Evaluate security power supplies to determine compliance with the security plan, 10 CFR, and the DBT order ."

CA2: "Initiate and track to completion an engineering analysis of the areas identified in the CR."

CA2 closed: "Engineering evaluation led security to enhance and broaden search requirements at the checkpoint."

6

THE EVENT Chronology of Key Events (continued)

CR-PLP-2007-05758 (Nov. 12, 2007)

Condition

Description:

A recent protective strategy assessment identified on enhancement to the checkpoint operation that would improve defensive strategy .

7 THE EVE Chronology of Key Events (continued) a Telephone Conference (Director, Nuclear Security / NRC Inspector) (February 2008)

Recollection of the two participants differs.

NRC questioned whether the site was in compliance with its Security Plan.

. Director indicated that it was.

Review of Security Plan revealed a survivability requirement previously unknown to the Director.

8

INVESTIGATION NRC issued a White Finding for the technical aspect 01 investigations followed for 50.5 and 50.9 aspect The Company and individuals are subject to 01 Among other things, the investigations focused on completeness and accuracy of:

Both Condition Reports; and The Directors verbal communications with the NRC Inspector.

9 ENFORCEMENT ACTION NRC initiated enforcement action against the Company and the Director, Nuclear Security (July 14, 2009)

Cited potential violation of 10 C.F.R 5 50.9 (a)

Entergy resolved its action by ADR - - Confirmatory Order (Nov. 10, 2009)

Director contested - - NRC declined to take enforcement action (Feb. 12, 201 0) 10

LESSONS LEARNED AND CORRECTIVE ACTIONS Three primary focus areas of corrective actions:

Change management and succession planning Addressing SGI in the CAP process Verbal interactions with NRC 11 LESSONS LEARNED AND CORRECTIVE ACTIONS CHANGE MANAGEMENT AND SUCCESSION PLANNING Integration of Palisades into Entergy fleet Rapid turnover in site Security management 12

LESSONS LEARNED AND CORRECTIVE ACTIONS Corrective Action: Succession Planninq Entergy conducted a self assessment of its succession planning in Q1 2010.

Entergy corporate succession planning process is in place, but written policy for Nuclear Division to be developed.

Site Security Manager was not previously identified as a key position in the succession plan.

13 LESSONS LEARNED AND CORRECTIVE ACTIONS Addressing SGI in CAP Process Existing CAP process did not specify requirements on the handling of SGI in Condition Reports Existing CAP processes and peer reviews not as effective when information is not readily available due to SGI protections Overreliance on a few individuals to determine significance and resolution of issues involving SGI 14

LESSONS LEARNED AND CORRECTIVE ACTIONS Corrective Action: CAP Enhancements Condition Report must clearly identify when an issue involves SGI Clear link / cross-reference required between CAP documents and the SGI documents Condition screening and action closures may require SGI-qualified personnel Final closure review must be by SGI-qualified personnel 15 LESSONS LEARNED AND CORRECTIVE ACTIONS Verbal Interactions with NRC Process for verbal interactions is not as rigorous or as structured as it is for NRC correspondence Opportunities for verbal interactions are much more prevalent than written interactions Employees at all levels must understand significance of complete and accurate communications with NRC 16

LESSONS LEARNED AND CORRECTIVE ACTIONS Corrective Action: Employee Training Providing training to the Entergy Nuclear workforce Instructor-based or computer-based delivery, depending upon level and specific responsibilities for communicating with NRC Addresses 10 CFR 50.9 and 50.5 17 CONCLUSION Database search indicates recent increase in 50.9-related findings Opportunities for 50.9 errors exist at all levels of the organization Nature of SGI can challenge processes that rely on info rmat ion trans parency Best defense is a knowledgeable workforce 18

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