ML13199A350

Predecisional Enforcement Conference Presentation Slides July 16, 2013

ML13199A350
Person / Time
Site:	Grand Gulf
Issue date:	07/16/2013
From:	Robinson C Entergy Operations
To:	Office of Nuclear Reactor Regulation
Gavula J
References
EA-13-058, IR-13-201
Download: ML13199A350 (11)

Text

Pre-decisional Enforcement Conference in response to NRC Inspection Report 05000416/2013201

Agenda

• Opening Remarks

• License Renewal Organization

• Performance Gaps

• Causes

• Corrective Actions

• Perspective on Significance

• Closing Remarks

Opening Remarks

• Acknowledge each example to be valid

• Implemented interim corrective actions

• Finalizing causal evaluation

• Planning additional corrective actions

License Renewal Organization Entergy License Renewal Structure

• Corporate team focuses on:

-Standardization of IPA, TLAA, and ER efforts.

-Standardization of LRA; incorporating latest industry lessons learned and optimized practices.

• Site team focuses on:

- Confirmation of CLB, OE, DB, AMP detail.

- Review of all IPA, TLAA, ER, and LRA documents before submittal to NRC.

Performance Gaps

• Failure to address all attributes of the RAI

• Failure to adequately describe the use of Moderate Energy Piping Procedure

• Failure to differentiate FAC and non-FAC wall-thinning mechanisms

• Ambiguous FAC procedure

• Failure to initiate CRs for significant wall thinning

Causes

• Insufficient engagement, coordination, and oversight of Grand Gulf license renewal activities

• Inadequate and ambiguous guidance in FAC procedure

• Insufficient RAI response guidance in LRA Maintenance procedure

Corrective Actions Completed Actions

• Returned to the normal LRA business practice

• Reinforced NRC communication guidance

• Revised procedures for FAC and LRA Maintenance

• Conducted department stand-downs

Corrective Actions Planned Actions

• Establish an escalation process

• Present OE and lessons learned at NEI License Renewal Task Force meeting

• Present OE to licensees who utilize Entergy License Renewal services

• Finalize Root Cause Evaluation

• Complete extent of condition

Perspective on Significance No impact during the period of extended operation Errors in LRA program descriptions No missing site aging management activities

Perspective on Significance NRC Enforcement Policy guidance for SL III violation

- Our errors should not result in the NRC changing a regulatory position

- Substantial further inquiry should not be required

Conclusion

• Acknowledge each example to be valid

• Recognize that providing complete and accurate information is essential

• GGNS will ensure the fleet and industry learn from our mistakes