ML111790639

Summary of Meeting with Entergy Operations Inc

ML111790639
Person / Time
Site:	Palisades, Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Vermont Yankee, Waterford, FitzPatrick
Issue date:	06/28/2011
From:	O'Keefe N NRC/RGN-IV/DRS/EB-2
To:	Herron J Entergy Operations
References
Download: ML111790639 (33)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV Mr. John T. Herron, President and 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 16011*4125 June 28, 2011 Chief Executive Officer, Nuclear Operations Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 65251-1995

SUMMARY

OF MEETING WITH ENTERGY OPERATIONS, INC.

Dear Mr. Herron:

On June 20, 2011, representatives of Entergy Operations, Inc. met with NRC personnel at NRC's Region IV offices to discuss the implementation of the quality oversight and verification programs at Entergy sites including actions being taken to enhance effectiveness. The list of attendees and a copy of Entergy's presentation are included as Enclosures 1 and 2 respectively.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC web site at (The Public Electronic Reading Room).

Sincerely,

~~~

~

~~~i~:'ring Branch 2 Division of Reactor Safety

Enclosures:

1. Attendance List

2. Entergy's Presentation Slides

J.

Herron cc:

Distribution via Listserv for:

Arkansas Nuclear One Grand Gulf Nuclear Station Indian Point Nuclear Generating Station, U2&3 James A. FitzPatrick Palisades Nuclear Power Plant Pilgrim Nuclear Power Plant River Bend Station Vermont Yankee Nuclear Power Station Waterford Steam Electric Station

NAME Elmo Collins TonyVegel Kriss KennedL Neil O'Keefe Vincent Gadd~

Tom Farnholtz:

Ray Kellar Robert Latta Mel Gray Paul Prescott Jack Giesner Donna Jacob:;

John McCann Tommy Tankersle~

John Dent Bryan Ford Jerry Roberts Clay Turnboll SIGN-IN SHEET U.S. NRC MEETING WITH ENTERGY OPERATIONS INC.

ORGANIZATION NRC Region IV NRC Region IV NRC Region IV NRC Region IV NRC Region IV NRC Region IV NRC Region IV NRC Region IV NRC Region I NRC/NRR NRC Region III EOI EOI EOI EOI EOI EOI New England Coalition June 20, 2011

NAME Kerry Rhoades Mark Malchick Thomas Sapoorito Mike Hayse Charly Donaldson David BlakE~

Jrerry Youn~

Deborah Mercado Raym Shadas Whitney Snip,es John Kramer Dwaine Gosh~

Roy BarKer SIGN-IN SHEET U.S. NRC MEETING WITH ENTERGY OPERATIONS INC.

ORGANIZATION Dominion First Entergy EXCELON New York Attorney River Keeper New England Coalition Courier - Russellville, AR.

Cooper Nuclear Station 2

June 20, 2011

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• E::ntergy Nuclear Organization

• (,overnance and Oversight

• F'leet Procedures

• (:)versight Organization

• (:llJality Control Program Donna J(~cobs John Derlt John Derlt Tom Tclnkersley Donna J:Elcobs 2

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.!ll'leVP, MlleC"",",U S~\\lP"\\t'f Tuesday, May 31, 2011 Entergy 1~.. 1l" 1 4

The Building Blocks and Behaviors Responsibilities and Accountabilities Governance Organization Structure 6

• Objective: Created a framewc~rk that established single point accolJntability tOI implement standard processes

• Initial steps to align with indLJstry fleets included:

Corporate center established in Jackson Centralized the Oversight, Engineering &~

Operations Support organizati()ns Standardized site organizational structun3 Based on industry benchmarking, adopted ENOS / GOES model 7

• I=ntergy Nuclear Operating System (l=r~OS)

Describes how Entergy NlJclear do,e~)

business

• (30ES (Governance, Oversight, Exe(;ution, c3nd Support) Matrix Clear, single-point accountabilities b(~sed 0 the organization structure 8

• E:nhanced, structured approach to fle~et wide

(,overnance & Oversight:

Clearly identified functional areas, Corporclte~

Functional Area Managers (CFAM's) & rohas &

responsibilities of the CFAM's Structured approach to driving standardizatic)n of functional areas to industry leading practices &

maintaining pace with industry advancemE~nt Structure developed & implemented that drives effective oversight at the fleet, s~te and functional area levels 9

• P\\n Entergy Nuclear Management Manual (I\\lMM) procedure is a mandatc~ry compliance, controlled document, that provides spec:ific direction on details, instructions, or requirE3ments f()r implementation of programs or procE~s~5es Illade standard throughout the Entergy r\\llJclear fleet.

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• [)raft NMM procedures are prepared by the pn:>cedure c~wner and submitted to the site procedure CharTlpions fc)r review and comment

• Integral to the Review and Approval process, thE~ site is nequired to review the following:

~ Technical review

~ Process applicability review

~ Licensing commitments review

~ Cross-discipline review

~ On-Site Safety Review Committee (OSRC) revievv when a 10CFR50.59 evaluation is required

~ Certified Level III QC review when required

• ~)ite review comments are compiled by the sitE~

procedure champions and are comnnunicated to the procedure owner

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I:>rocedure owner compiles and addresses AL.L site C0l11ments

()nce all comments have been addressed, thE~ site procedure champions perform a final review clf the procedure

!3ite procedure champions validate all reviews have been c3dequately completed, signs completed Review and Jl\\pproval Form (RAF) and forwards to procedurE3 champion

()nce final comments are addressed and communicated the site implements the procedure and associatE3d change management

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Director, Oversight Senior Vice President, J Planning, Development 8.'

Oversioht Vice President, Oversight Executive Assistant Oversight Manager, QA - Corporate E~mployee Concerns Project Manager, SRC QA Manager (9 sites)

Sr. Admin Assistant Coordinator, Employee Concerns (11) r===------------~

( QA Senior Auditor (9 sites) J Auditor (7) - Dual Unit Sites (5) - Single Unit Sites SeniOrQAAU~

Supervisor, S:lier QA (~

QA Auditor, Supplier QA (1'~

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• Nuclear Oversight provides independent monitoring of:

.- Regulatory compliance l

.- Performance assessment

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• IKey QA program attributE~S:

-- Systematic audits

.- Performance against industry standards Rotational Assessors

...... Qualified Audit Team L.eaders

-- Technical Specialists

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• "rhe Safety Review Committee provides tI1~ eNO

""ith an independent review of rluclear slafety and activities that potentially impact nucle,ar safety

• T'he Employee Concerns Progran1 provildE~S a irldependent channel for raisin~J and adctrE~ssing employee concerns.

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• ClA Audit Program Conducts internal audits of safety related, regulatory-based, and QU4ality ASSlJrc:lnCe program applicable activities Evaluates performance of organiz8ltic)ns and programs against indlJstry starldards of excellence 19

• Jl\\udit Process Fleet audit scheduling Performance

• Assign fleet audit sponsor

• Review Master Audit Plan (MAP)

• Perform Fleet Vulnerability review Develop common fleet checklist Perform field work Fleet challenge call Audit Exit and Issue Report 20

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I ndependent Investigation T ealm I

view J Sr Manager ad Licensing

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r-Site ECP Coordinators (10)

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Site QA Support J Independent Lead I

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I Fleet manager Corporate QA ANSI Level III Maintenance Manager ExpertisE I

ANSI Level lis (2)

I Chief Engineer BWRs

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I Corp Engineering Team

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Response T ealTl Response Team

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Lead - SVP

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Independent Oversight

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Oversight and Monitoring -VP

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[ General M~

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lager Operations J upport

--1 Fleet manager Maintenance,

ANSI Level II/Ills (9 sites)

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ANSI Level III Expertise Site/I Corporate (9 sites)

QA 1

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~lfaluation Team - SVP Sr Manager licensing Engineering - VP Engineering Team (9 sites) 23

Root Cause Analysis ProblE~m StatE~nlents

• Quality Control.

QC required inspections of construction like!

activities for safety related design changE~ vvork orders were not performed per the requirE3ITlents of the Quality Assurance Prograrrl Manual ((:lj\\PM).

• Quality Assurance Aspects QA did not recognize deficienciies in the (:lC:

inspection process in 2008 and 2009. The significance of QC inspection deficiencies vvas not identified until performance was challeng~3d by an outside agency_

• Root Cause There was no inspection program document defining the process, roles, and responsibilities of the new organizational structure with sufficient detail to sustaiin performance.

• Contributing Causes The QC Inspection program's primary implementing procedure, EN-MA-102, "Inspection Program" and a primary interface procedure EN-WM-105 "Planning" are not, "written for the least-experienced qualified indiividual".

There is no defined Program Health ITlonitoring.

ANSI Level 2 Inspectors and related discipline certifications are limited.

Previous condition report corrective actions were ineffective.

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I<e~{ Corrective Actions to Prevent ReClJrrenCe Develop, institutionalize and implement a QC Inspection Program document to ensure the key elements of the functional reporting structure, roles, responsibilities, and relationship interface between QA, rll1aintenance, and Work Management organizations are defined.

• I<ey Corrective Actions for Contributing C:auses Develop a formal process map for the QC inspection process, implement in procedure using managed defense(s) for error intolerant process.

Revise EN-MA-102 and EN-WM-105 to meet specific standards for "least experienced qualified individuals".

Formalize and communicate the expectation associated with tile term "functional reporting" to the site QA and Maintenance mana~~ers.

Develop Inspection Program l1ealth Performance Indicator.

Perform a gap analysis to evaluate the number of discipline sp~3cific qualifications currently available.

CR-HQN-201 0-00123 issued to evaluate previous condition report effectiveness.

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I~oot Cause There was insufficient detail in audit checklists/instructions to ensure that the Maintenance audits in 2006 and 2008 reviewed the design and satisfactory implementation of the inspection prograrn.

• I<ey Contributing Causes The processes within Quality Assurance were not effective at

~lggregating low level issues and identifyin~~ emerging patterns or fleet Issues.

Condition Reports that identified fleet inconsistencies in the QC inspection process did not evaluate prograillmatic issues and no E~xtent of condition was performed.

Significant changes in Oversight staffing irnpacted the collective knowledge and expertise relative to the full scope of QC activities and amount of QA interaction required. Significant industry C)E pertinent to QA was not included in the training/integration of the nevv personnel.

• I<ey Corrective Actions to Prevent ReCLJrrenCe Develop detailed checklists for the Maintenance audit to provide specific direction for auditing the area of inspection hold point assignment.

Hequire for each audit the source information for the MAP be validated and detailed checklists developed for each attribute to be audit,ed.

J<ey Additional Actions Quarterly Snapshot assessment of condition reports initiated by the QA organization were initiated to aggregate lower level performance issues.

Multiple procedure revisions to strengthen the definitions of QA Identified Findings to align the Audit Process with ANSI Standards and the Corrective Action Program.

A Training Needs Analysis was completed and reviewed by the' Oversight Training Review Group. Training fnaterial on developing detailed checklists that ensure adequate attribute evaluation, has befen developed and implemented.

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