NL-07-070, Cynthia Carpenter Ltr. Reply to Notice of Violation EA-07-092 Regarding Failure to Meet Implementation Deadline NRC Order EA-05-190

Cynthia Carpenter Ltr. Reply to Notice of Violation EA-07-092 Regarding Failure to Meet Implementation Deadline NRC Order EA-05-190

ML071430427
Person / Time
Site:	Indian Point
Issue date:	05/23/2007
From:	Balduzzi M Entergy Nuclear Operations
To:	Carpenter C NRC/OE
Carpenter C A
References
EA-05-190, EA-07-092, NL-07-070
Download: ML071430427 (16)

Text

Michael Balduzzi Senior Vice President & COO Regional Operations - Northeast Entergy Nuclear Operations, Inc 440 Hamilton Avenue White Plains, NY 10601 Tel 914 272 3400 Fax 914 272 3205 May 23, 2007 Re: Indian Point Units 2 and 3 Dockets 50-247 and 50-286 NL-07-070 Cynthia Carpenter Director, Office of Enforcement U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

Reply to Notice of Violation EA-07-092 regarding Failure to Meet Implementation Deadline NRC Order EA-05-190

REFERENCE:

1.

NRC letter dated April 23, 2007; Notice of Violation EA-07-092 and Proposed Imposition of Civil Penalty and Additional Requirement to Provide Information.

Dear Madam:

Entergy Nuclear Operations, Inc. (Entergy) is providing the required response to the subject Notice of Violation (NOV) issued in Reference 1. The information required pursuant to the provisions of 10 CFR 2.201 is provided in Attachment I. The NOV transmittal letter also requested that Entergy provide additional information pursuant to 10 CFR 50.54(f); that information is provided in Attachment II.

Entergy has completed several actions following the unsuccessful siren operability test on April 12, 2007, which resulted in Entergy not meeting the April 15, 2007 deadline required for compliance with NRC Order EA-05-190. Actions completed include conducting a root cause investigation, establishing short and long-term corrective actions, developing a compliance matrix related to implementation of the technical requirements of the Order, and preparing a project recovery action plan, which establishes a planned approach for declaring the new siren system operable. As part of the root cause investigation and compliance matrix development, Entergy has identified several activities remaining to be completed to meet the various technical requirements of the Order.

These additional activities are underway and are projected to be completed by June 8, 2007.

Entergy has assured that appropriate levels of management are involved to assure the timely completion of these additional activities and to implement the planned approach to restore compliance with the Order.

ATTACHMENT I TO NL-07-070 REPLY TO NOTICE OF VIOLATION EA-07-092 REGARDING FAILURE TO MEET IMPLEMENTATION DEADLINE OF NRC ORDER EA-05-190 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS NO 2 AND 3 DOCKETS 50-247 AND 50-286

NL-07-070 Dockets 50-247 and 50-286 Attachment I Page 1 of 6 NOTICE OF VIOLATION EA-07-092 On April 16, 2007, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the NRC proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violation and associated civil penalty is set forth below:

The Energy Policy Act (Act) of 2005, requires in part that For any licensed nuclear power plants located where there is a permanent population, as determined by the 2000 decennial census, in excess of 15,000,000 within a 50-mile radius of the power plant, not later than 18 months after enactment of the Act, the Commission shall require that backup power to be available for the emergency notification system of the power plant, including the emergency siren warning system, if the alternating current supply within the 10-mile emergency planning zone of the power plant is lost.

NRC Confirmatory Order (Order) (EA-05-190) - Emergency Notification System (ENS) Backup Power for Indian Point Nuclear Generating Units 2 and 3, Sections IV.I and IV.II, as modified pursuant to Section IV.V of the Order by letter from J. Dyer to M. Kansler, dated January 23, 2007, required that the Licensee shall implement II.A, II.B, and II.C.1-3 by April 15, 2007, including requiring the backup power system for the ENS shall be declared operable by April 15, 2007.

Contrary to the above, the Licensee for the Indian Point Generating Station, Units 2 and 3, failed to meet the Order requirements to implement an ENS with backup power capability by April 15, 2007.

Specifically, the radio only activation feature, the portion of the ENS for which the backup power capability was provided, did not meet its test acceptance criteria, resulting in the ENS not being fully operable by April 15, 2007.

This is a Severity Level III violation.

Civil Penalty - $130,000 ENTERGY RESPONSE

1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Entergy Nuclear Operations, Inc. (Entergy) admits to the violation regarding failure to meet the requirements of NRC Order EA-05-190 (Order) for implementation of an Emergency Notification System (ENS) with backup power capability by April 15, 2007.

2. REASONS FOR THE VIOLATION Entergy documented the test failure of April 12, 2007 and subsequent failure to meet the April 15, 2007 deadline in the Corrective Action Program (CAP). A root cause investigation team was formed and the resulting investigation report was presented to the site Corrective Action Review Board on May 15, 2007. Based on that report Entergy has identified two root causes for the failure to meet the deadline and the resultant violation of Order EA-05-190.

Root Cause 1: The Entergy siren project team did not fully understand the implications related to selection of the radio/microwave simulcast technology used in the siren system.

NL-07-070 Dockets 50-247 and 50-286 Attachment I Page 2 of 6 Entergy selected an application of simulcast radio technology which to the best of our knowledge is the first of a kind for a nuclear power plant alert notification system. In hindsight, Entergy selected this type of application without an adequate understanding of the overall lack of available industry expertise and without a plan to develop that expertise early in the project. Responsible personnel did not recognize that, with this new technology, additional time should have been built into the schedule for developing in-house expertise, performing system set up, tuning and timing, as well as for testing and troubleshooting the system.

In January 2007, Entergy requested (Reference 1) and NRC approved (Reference 2) relaxation of the Order to extend the January 30, 2007 deadline for operability to April 15, 2007. At that time, the final stages of construction activities were still underway and Entergy had not yet encountered the difficulties that would later arise regarding setup and tuning of the microwave simulcast system.

Entergy structured the project as a turn-key installation and as such over-relied on the vendors capabilities to configure the microwave simulcast system.

Root Cause 2: The process used for identifying the activities needed to implement the requirements of the NRC Order was inadequate, which resulted in an insufficient project plan.

As an example, the minimum performance criteria for declaring the siren system operable were established late, thereby not allowing time to resolve system configuration problems prior to conducting the operability test. Since specific test criteria for declaring the system operable were not described in the Order, the project team assumed that criteria would be based on the wording in the Order used for a post-operability test sequence for 3 consecutive tests testing the operability of all ENS components used during an actual activation At the time, Entergy interpreted this language to mean that the operability test would use a multi-path actuation signal which is the means that will be used in a normal actuation. Although Entergy considered this to be a reasonable approach in terms of crediting the redundancy features of the new siren system, this interpretation was not subjected to a review process that adequately focused on strict compliance with the Order. An opportunity to highlight and resolve this issue was missed in the development of the test plan submitted by Entergy (Reference 3) for NRC review and approval. The test plan established acceptance criteria for those portions of the tests related to verifying the function and capability of the backup power system. The final step in the plan stated that: An integrated test is then conducted with normal AC power supply to demonstrate satisfactory performance of all ENS components. Specific acceptance criteria were not defined for this portion of the test and the project team did not recognize that a multi-path test would not result in satisfying the intent of the Order, which focuses on the ability of the system to achieve a certain performance level using only those components that are powered by the battery backup design feature.

The project team focused on achieving system performance goals using the integrated multi-path approach up until approximately three days before the planned final operability test. At that time, the test approach was challenged and revised based on discussions with NRC. At that point in the project, there was very little time left to perform any in-depth testing needed to resolve identified problems. Preliminary testing indicated that acceptable results could be expected during the actual operability test crediting only the microwave simulcast path. However, because of the lack of expertise with the microwave simulcast technology as described in Root Cause 1, this expectation was flawed in that it was based on inadequate test data. Testing on April 12, 2007 revealed that test results based on microwave actuation did not meet the test acceptance criteria.

NL-07-070 Dockets 50-247 and 50-286 Attachment I Page 3 of 6 C.

Contributing Causes Contributing causes were also identified in the root cause analysis. These include:

contractor, sub-contractors and Entergy not being technically qualified on the radio simulcast sections of the system; overconfidence in the technology by the vendor and Entergy, which led to a lack of vendor oversight; underestimation of the time for stakeholder interface; inadequate up-front project planning and engineering; and inadequate middle management involvement in the project.

3. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED Many of the corrective steps taken are addressed in the referenced root cause report. The more significant steps are discussed below:

A.

Regarding use of microwave simulcast technology Following the test of April 12, 2007 when unexpected results were obtained during the microwave actuation scenario, Entergy discovered a foreign particle between two connector pins of a computer chip located in the microwave transceiver that is in the communication path associated with a group of sirens that did not actuate. The as-found condition showed that the transceiver was operating intermittently. During a pre-test performed earlier on April 12, 2007, the transceiver worked because the sirens of interest did function for that test. When the foreign particle was removed, the transceiver operated normally. An extent-of-condition visual inspection was performed for other electronic components.

A review of test data indicated that other factors, in addition to the microwave transceiver, were also adversely affecting reliable and repeatable performance of the microwave communication paths. Therefore, Entergy initiated a troubleshooting and testing program to improve system performance. Activities were coordinated through our siren vendor with the assistance of an expert radio consultant as summarized below.

The initial follow-up step involved point-to-point checks of the interconnection wiring and a review of the system settings at the four communication towers. This activity has been completed. Silent actuation tests were then performed over a period of approximately two weeks during which the consultant made and implemented various recommendations based on observation and data collection during these tests to tune system performance.

These silent actuation tests were also the means of monitoring the effectiveness of the changes implemented. Examples of system optimization activities during this time period include:

• Relocation and tuning of Putnam County Emergency Operations Center radio antenna to improve radio reception

• Adjustment of control station antennas to reduce reflective power and improve reception

• Adjustment of microwave signal strength at each of the four simulcast towers

• Adjustment of software settings in the simulcast transceivers to address truncated responses from siren radios

NL-07-070 Dockets 50-247 and 50-286 Attachment I Page 4 of 6

• Revision of polling algorithm to alleviate post-actuation data collection interferences from multiple simultaneous polling for the four counties

• Increasing of the size of the polling buffer at all 12 control stations to allow improved logging of message data packets The above changes were made to enhance the radio signal transmission that occurs among the various control stations, the simulcast towers, and the individual sirens. Initial efforts concentrated on ensuring that the actuation signals were reliably transmitted to and received by the sirens for actuation. Subsequent activities concentrated on establishing reliable transmission of the feedback signal from the sirens, through the towers, and then to the control stations, which provide siren actuation data to the emergency response personnel located in facilities where siren actuation can be initiated (Emergency Operation Centers and Warning Point Centers).

The above changes were completed by May 9, 2007 and a series of silent actuation tests using microwave actuation was conducted. A total of 52 tests was performed over a period of 8 days with siren actuations initiated from the county Emergency Operation Centers and Warning Point Centers. The results demonstrate that the current system configuration is capable of meeting the previously established test acceptance criteria for microwave actuation.

B.

Regarding implementation of Order requirements Entergy assigned an independent reviewer to conduct a detailed review of the implementation of the technical requirements of the Order, including testing of design features such as battery backup power capability and battery charger capability. A detailed compliance matrix was developed which provided for a systematic approach to confirm and document Entergys compliance with the technical requirements of the Order, including design and testing requirements. As a result of this review, several items were identified that require additional work and/or documentation to demonstrate compliance. Actions are underway to address these items and following completion, another series of silent actuation tests will be performed. Entergy expects the results of these tests to be available by June 8, 2007.

Entergy also initiated an effort to develop a comprehensive project recovery action plan in response to the observation in Root Cause 2. The project recovery plan provides a systematic approach to address the remaining actions needed to declare the system technically ready and operable and includes additional actions required, post-operability, consistent with requirements specified in the Order.

Based on the work completed or in progress and results achieved as described in Sections A and B above, Entergy anticipates that all technical requirements of the Order will be met by June 8, 2007. This milestone includes an investigation and data collection effort undertaken by Entergy regarding the sound pressure level (SPL) output of the new siren design. Details regarding this effort are provided in Section A of Attachment II.

NL-07-070 Dockets 50-247 and 50-286 Attachment I Page 5 of 6

4. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A.

Regarding use of microwave simulcast technology Since Entergy does not currently have in-house expertise with setup and configuration of a microwave simulcast system, Entergy will retain the services of a radio microwave consultant to ensure that technical support is available. Since the system configuration has been established to provide for reliable operation, technical support from the consultant is not expected to be needed for routine operation, surveillance, and preventative maintenance. However, if an off-normal condition occurs, the support will be available for troubleshooting and repair.

Prior to declaring the system operable, Entergy will have a maintenance and testing program in place, as required by Section IV.II.A.6 of the Order, to support ongoing reliable operation of the system. In addition, the as-built software version will be maintained under the Entergy SQA program and appropriate equipment settings will be maintained. System configuration will be maintained through Entergys design control and configuration management processes.

B.

Regarding implementation of Order requirements The corrective actions taken, as described in Section 3B, regarding development of a compliance matrix and a project recovery action plan are sufficient to avoid future violations for the balance of activities associated with the implementation of NRC Order EA-05-190.

In addition, Entergy is planning to establish a process improvement which will provide better guidance and administrative controls for the implementation of any future NRC Order.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED OVERVIEW:

Entergy is committing to declare the new siren system operable by August 24, 2007, thereby restoring compliance with NRC Order EA-05-190. The approach planned by Entergy is summarized below:

Entergy expects to complete activities by June 8, 2007 such that the new siren system will meet the technical requirements of the Order at that time. Latest results of silent actuation tests indicate that the system is now meeting the established microwave actuation performance criteria required for the operability test. Entergy recognizes that additional issues involving other stakeholders such as FEMA and the emergency planning zone counties need to be addressed prior to declaring the system operable and placing it in service. Therefore Entergy is planning an approach to address those issues. The intermediate milestones for this approach are listed in Attachment III and result in an anticipated state of operability readiness by July 18, 2007. Because of potential schedule uncertainties related to coordinating these additional activities with external organizations, Entergy is including contingency time in the schedule for achieving compliance. The date Entergy is committing to for restoring compliance with the Order is by August 24, 2007.

NL-07-070 Dockets 50-247 and 50-286 Attachment I Page 6 of 6 PLANNED APPROACH:

Entergy has completed several tuning adjustments to the radio/microwave simulcast system with the assistance of an expert radio system consultant. Based on work completed to date, and the results of a baseline series of silent tests performed from May 9 to May 16, Entergy believes that the system is now capable of meeting the previously established siren actuation test acceptance criteria for an operability test. Overall average siren actuation performance, using the microwave actuation signal is consistently exceeding 97%. Entergy also believes, based on siren volume data collected from May 1 to May 10 that the input assumption used in the siren system acoustic model is valid. Based on investigations by Entergy following the April 12, 2007 test, actions are underway which will assure that the technical requirements of the Order are met. Entergy anticipates these activities to be completed by June 8, 2007. However, Entergy recognizes that additional issues, including those related to stakeholder confidence need to be addressed prior to declaring the system operable and placing it in service.

Entergy is aware of several regulatory and technical issues that need to be resolved with FEMA including: individual siren volume output with respect to acoustic model assumption, the ability of the total system to achieve required sound pressure levels in the field, and tree trimming requirements in the vicinity of individual sirens. Entergy is currently in the process of discussing these issues with FEMA and expects to provide written notification to NRC by June 15, 2007, regarding the status of these issues, including the identification of any additional action items.

In order to improve stakeholder confidence, Entergy plans to meet with the four-county emergency planning representatives regarding the status of the FEMA issues as soon as practicable after providing the written notification to NRC. Entergy has also formally requested (Entergy letter dated May 21, 2007) that emergency planning representatives from the four counties identify any additional training needs associated with operation of the new siren system by May 25, 2007.

Entergy will conduct the requested training as soon as practicable after receiving notification from the counties, but in any case prior to declaring the system operable.

Following completion of the specific activities described above and completion of other reasonable actions which may be identified through the issue resolution process, Entergy will inform NRC of our intent to perform observed full volume testing followed by declaring the system operable. Entergy anticipates that these actions can be completed to support declaration of operability by July 18, 2007.

Because of potential schedule uncertainties related to coordinating with external organizations, Entergy is allowing some contingency in the committed schedule for achieving compliance. The date being committed by Entergy for restoring compliance with the Order is by August 24, 2007.

REFERENCES:

1. Entergy letter (NL-07-014) dated January 11, 2007; regarding Relaxation Request for Implementation Date for Emergency Notification System Backup Power.

2. NRC letter dated January 23, 2007; regarding Relaxation of Implementation Date for NRC Confirmatory Order EA-05-190.

3. Entergy letter (NL-06-076) dated July 5, 2006; regarding Test Plan for Indian Point Emergency Notification System.

ATTACHMENT II TO NL-07-070 REPLY TO NOTICE OF VIOLATION EA-07-092 ADDITIONAL INFORMATION REQUIRED UNDER 10CFR50.54(f)

PLANS TO ACHIEVE COMPLIANCE WITH NRC ORDER EA-05-190 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS NO 2 AND 3 DOCKETS 50-247 AND 50-286

NL-07-070 Dockets 50-247 and 50-286 Attachment II Page 1 of 2 The following provides additional information requested in the Notice of Violation transmittal letter from NRC pursuant to 10 CFR 50.54(f). This information is discussed in more detail in the Siren Project Recovery Action Plan, which is available for inspection upon request.

A.

Sound Volume Test Plan to Validate System Design Report Entergy contracted with Blue Ridge Research and Consulting (BRRC), an acoustical engineering firm, to perform measurements of siren sound pressure levels (SPL) in the near field according to ANSI Standard S12.14-1992 and in the far field. In March 2007, BRRC took a total of 27 ground level measurements accompanying nine elevated measurements made in accordance with ANSI S12.14. In May 2007 BRRC made measurements of 14 sirens at siren height in accordance with ANSI S12.14.

Measurements in March 2007 recorded the maximum and average sound pressure levels, but did not record peak sound pressure levels. Sound pressure level measurements in May 2007 recorded peak, maximum and average sound pressure levels. The distinctions between peak, maximum, and average sound pressure levels are important. The peak sound pressure level is used as an input to the sound propagation model that is used to predict the average sound pressure levels that will occur in the far field. The far field average sound pressure levels are those used to compare to the values in FEMA REP-10 section E.6.2.1.

Entergy supplied the raw data from the March 2007 measurements to FEMA but did not make clear that the measurements at siren centerline elevation represented maximum sound pressure level rather than the peak level used in the sound propagation model. The maximum sound pressure levels were approximately 5 dBC less than peak sound pressure levels, as would be expected. As a result of this exchange of data between Entergy and FEMA, which did not carefully distinguish between the units being applied to sound pressure values, FEMA raised questions about the capability of the sirens with respect to the information provided in the design report. The project recovery action plan includes activities directed at resolving this matter with FEMA.

The average peak sound pressure levels determined in May 2007 support the 122 dBC (peak) value used in the acoustic model presented in the design report. Furthermore, an analysis performed by Acoustic Technology, Inc (i.e., the siren manufacturer) of the ground level data taken in March 2007 by BRRC demonstrated that the measured far field average sound pressure levels show good agreement with the predicted average sound pressure levels.

After declaring the new siren system operable, and in conjunction with future selected full volume tests, Entergy will make measurements of far-field average sound pressure levels at a sampling of locations within the emergency planning zone for validation of the acoustic model output compared to the FEMA REP-10 section E.6.2.1 criteria.

B.

Test Plans to Demonstrate System Functionality and Reliability Entergy has completed a series of testing as described in Attachment I, Section 3A which supports Entergys conclusion that the system is now adjusted to support system operability. In addition, Entergy is planning to conduct an additional series of silent tests after making an adjustment of the radio gain at two of the simulcast towers. Entergy expects this adjustment to further improve the performance of the radio actuation path. Multiple silent test actuations will be initiated from various control stations and using different actuation modes. Entergy expects that the results of these tests will be available by June 8, 2007.

NL-07-070 Dockets 50-247 and 50-286 Attachment II Page 2 of 2 Note that silent testing is not literally silent. This test mode verifies operation of the same system components as is accomplished during a full volume test. The difference is that for a silent test, the actuation signal transmitted to the sirens energizes the speaker drivers to deliver a test tone for approximately 1 - 2 seconds. During a full volume test, the actuation signal energizes the speaker drivers to deliver the tone that is normally used for the public alerting function, 550 Hz for a period of 4 minutes. Therefore, the series of silent tests described above is appropriate to demonstrate system functionality and reliability. However, Entergy will also conduct full volume testing as stated in Section 5 of Attachment I with observers stationed at individual sirens.

After declaring the system operable, Entergy will also perform the test sequence specified in Section IV.II.C.5 of the Order. This test sequence will be performed using the microwave actuation path based on microwave synchronization to demonstrate that the desired level of performance is achieved taking credit only for the communication path that is designed with the battery backup power feature.

C.

Training Plans and Procedure Enhancements to Ensure, With High Reliability, the Capability to Activate the Sirens from the Counties Entergy conducted training of personnel at the county Emergency Operation Centers and Warning Point Centers during January and February 2007, with training for one Warning Point performed in April 2007. The training, which consisted of two parts (a presentation followed by hands-on demonstrations at the control consoles), provided an overview of the new siren system, instructions on how to perform the siren actuation, and a question and answer period. Entergy has provided a written outline of training topics to county officials to facilitate future training sessions and will provide retraining on these topics as requested. Entergy has also provided a written operator aid which details the 5-step process involved with siren actuation. Entergy generally received positive feedback from those county personnel who participated in the training.

There have been some changes to the control console software since these training sessions were conducted; however, Entergy has determined that those changes do not affect the training already provided and do not alter the instructions provided for users performing the siren actuation function. On April 20, 2007, Entergy requested that the four counties assess whether their training needs have been met. Based on feedback received, Entergy is proposing to offer additional training for those county locations that feel additional training is desirable. On May 21, 2007, Entergy provided written notification of the availability of the additional training, and requested a response from the four counties by May 25, 2007. Although the scope of the training is not different from that previously provided, Entergy has prepared an updated lesson plan that will be made available to the counties. The updated lesson plan also includes a new version of the user guide, with improved organization and layout of information.

ATTACHMENT III TO NL-07-070 MILESTONE

SUMMARY

FOR ENTERGYS PLANNED APPROACH TO RESTORING COMPLIANCE WITH NRC ORDER EA-05-190 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS NO 2 AND 3 DOCKETS 50-247 AND 50-286

NL-07-070 Dockets 50-247 and 50-286 Attachment III Page 1 of 1 The following is a summary of milestone dates associated with Entergys planned approach to declare the new siren system operable and restore compliance with NRC Order EA-05-190.

DESCRIPTION OF ACTIVITY SCHEDULE (see Note A)

Four-county emergency planning officials provide feedback to Entergy regarding the need for additional training to support actuation of new siren system May 25, 2007

• Conduct additional training if requested by county officials ASAP after receiving county feedback but prior to July 18, 2007

• Complete corrective actions to assure compliance with the technical requirements of the Order June 8, 2007 Provide letter to NRC regarding status of FEMA issues June 15, 2007

• Meet with four-county emergency planning officials regarding status of FEMA issues ASAP after June 15, 2007

• Projected readiness date for declaring the new siren system operable July 18, 2007

• Entergy committed date for declaring the new siren system operable August 24, 2007 Note A: Dates marked by an asterisk indicate those that are contingent upon interactions with third-party organizations.

ATTACHMENT IV TO NL-07-070 COMMITMENT ASSOCIATED WITH ENTERGYS REPLY TO NOTICE OF VIOLATION EA-07-092 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS NO 2 AND 3 DOCKETS 50-247 AND 50-286

NL-07-070 Dockets 50-247 and 50-286 Attachment IV Page 1 of 1 ID COMMITMENT DESCRIPTION COMMITMENT TYPE SCHEDULE COMPLETION DATE 01 Entergy is committing to declare the new siren system operable by August 24, 2007, thereby restoring compliance with NRC Order EA-05-190.

One-time action Aug 24, 2007