ML14352A286
| ML14352A286 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/18/2014 |
| From: | Vitale A Entergy Nuclear Operations |
| To: | O'Brien K Document Control Desk, Division of Reactor Safety III |
| References | |
| EA-14-013, PNP 2014-101 | |
| Download: ML14352A286 (4) | |
Text
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 1nte-r 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 201 4-1 01 December 18, 2014 Mr. Kenneth OBrien U. S. Nuclear Regulatory Commission Director, Division of Reactor Safety 2443 Warrenville Road Lisle, IL 60532
Subject:
Entergy Nuclear Operations, Inc. Six-Month Status Notification in Response to Confirmatory Order, EA-14-013 Palisades Nuclear Plant Docket 50-255 License No. DPR-20
Reference:
Confirmatory Order Related to NRC Report No. 05000255/20 14406 and 0!
Report 3-2013-018; Palisades Nuclear Plant, dated July 21, 2014 (ML14203A082)
Dear Mr. OBrien:
On July21, 2014, the Nuclear Regulatory Commission (NRC) issued the referenced Confirmatory Order, EA-1 4-01 3, to Entergy Nuclear Operations, Inc (ENO). The Confirmatory Order requires ENO to submit written notifications to the NRC on the status of each item in the Confirmatory Order at intervals of six months, one year and annually thereafter until the terms of the Confirmatory Order are completed.
The purpose of this letter is to provide the six-month status notification pursuant to Section V, Item F.1, of the Confirmatory Order. The attachment delineates progress made in implementing the requirements of the Confirmatory Order.
This letter contains no new commitments and no revisions to existing commitments.
Sincerely,
/LJ47 t/J]
ajv/tad
Attachment:
Entergy Nuclear Operations, Inc. Six-Month Status Notification in Response to Confirmatory Order, EA-14-013 cc:
Document Control Desk, USNRC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC PNP 2014-101 December 18, 2014 Mr. Kenneth O'Brien U. S. Nuclear Regulatory Commission Director, Division of Reactor Safety 2443 Warrenville Road Lisle, IL 60532 Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Anthony J. Vitale Site Vice President
Subject:
Entergy Nuclear Operations, Inc. Six-Month Status Notification in Response to Confirmatory Order, EA-14-013 Palisades Nuclear Plant Docket 50-255 License No. DPR-20
Reference:
Confirmatory Order Related to NRC Report No. 0500025512014406 and 01 Report 3-2013-018; Palisades Nuclear Plant, dated July 21,2014 (ML14203A082)
Dear Mr. O'Brien:
On July 21, 2014, the Nuclear Regulatory Commission (NRC) issued the referenced Confirmatory Order, EA-14-013, to Entergy Nuclear Operations, Inc (ENO). The Confirmatory Order requires ENO to submit written notifications to the NRC on the status of each item in the Confirmatory Order at intervals of six months, one year and annually thereafter until the terms of the Confirmatory Order are completed.
The purpose of this letter is to provide the six-month status notification pursuant to Section V, Item F.1, of the Confirmatory Order. The attachment delineates progress made in implementing the requirements of the Confirmatory Order.
This letter contains no new commitments and no revisions to existing commitments.
Sincerely, ajv/tad
Attachment:
Entergy Nuclear Operations, Inc. Six-Month Status Notification in Response to Confirmatory Order, EA-14-013 cc:
Document Control Desk, USNRC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
Entergy Nuclear Operations, Inc. Six-Month Status Notification in Response to Confirmatory Order, EA-14-013 Confirmatory Order Item I
Status Comments A. Verification of Training Credentials for both Staff and Management:
A.1:
Completed on Each Entergy site Security Conduct fleet-wide review of qualifications of each duty position in security to ensure various dates Manager validated the that the qualifications for each position are clear and verifiable by all parties (security prior to qualifications for each officers, security supervisors, and security manager). The initial review and applicable 11/30/2014 position are clear and procedure revisions shall be completed by November 30, 2014.
verifiable by all parties A.2:
Completed on Revised EN-NS-221, Verify and modify, if necessary, the applicable security procedure to ensure that both 11/06/2014 Security Department assignor and assignee validate qualifications before the assignee performs a duty Standards and position. This shall be completed by November 30, 2014.
Expectations revision 6 A.3:
In-progress Training material has been Following completion of A.1 and A.2, training will be conducted on the changes. This developed and approved shall be completed by June 30, 2015.
for use.
B. Strengthen Safety Culture:
B.1:
In-progress 3
rd and 4 th quarter 2014 Through June 30, 2016, the Palisades Security Manager shall meet quarterly (during the quarterly meetings have calendar quarter, allowing for one month grace period) with each security team: (a) to been completed.
reinforce the importance of a healthy SCWE and managements intolerance for retaliation, and (b) to discuss security concerns and issue resolution.
B.2:
In-progress Security Top 10 issues and Through June 30, 2016, Palisades security management shall maintain and update a resolutions are maintained Security Top 10 Issues board to reflect, among other things, the expected issues and communicated on a resolution dates.
routine basis.
B.3:
Completed on The third and final monthly Discuss the safety culture aspects of the event with Palisades Nuclear Plant staff, 11/06/2014 tailgate meeting material including long-term contract staff, in three monthly tailgate meetings. The tailgate was distributed on meetings shall include employee rights, licensee expectations with respect to raising November 6, 2014.
issues, methods to raise issues, and the right to contact the NRC. The tailgate meetings will be completed by December 31, 2014.
Page lof 3 Entergy Nuclear Operations, Inc. Six-Month Status Notification in Response to Confirmatory Order, EA-14-013
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Completed on Each Entergy site Security Conduct fleet-wide review of qualifications of each duty position in security to ensure various dates Manager validated the that the qualifications for each position are clear and verifiable by all parties (security prior to qualifications for each officers, security supervisors, and security manager). The initial review and applicable 11/30/2014 position are clear and procedure revisions shall be completed by November 30, 2014.
verifiable by all parties A.2:
Completed on Revised EN-NS-221, Verify and modify, if necessary, the applicable security procedure to ensure that both 11/06/2014 "Security Department assignor and assignee validate qualifications before the assignee performs a duty Standards and position. This shall be completed by November 30, 2014.
Expectations" revision 6 A.3:
In-progress Training material has been Following completion of A.1 and A.2, training will be conducted on the changes. This developed and approved shall be completed by June 30, 2015.
for use.
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B.1:
In-progress 3ra and 4th quarter 2014 Through June 30, 2016, the Palisades Security Manager shall meet quarterly (during the quarterly meetings have calendar quarter, allowing for one month grace period) with each security team: (a) to been completed.
reinforce the importance of a healthy SCWE and management's intolerance for retaliation, and (b) to discuss security concerns and issue resolution.
B.2:
In-progress Security Top 10 issues and Through June 30, 2016, Palisades' security management shall maintain and update a resolutions are maintained "Security Top 10 Issues" board to reflect, among other things, the expected issues and communicated on a resolution dates.
routine basis.
B.3:
Completed on The third and final monthly Discuss the safety culture aspects of the event with Palisades Nuclear Plant staff, 11/06/2014 tailgate meeting material including long-term contract staff, in three monthly tailgate meetings. The tailgate was distributed on meetings shall include employee rights, licensee expectations with respect to raising November 6, 2014.
issues, methods to raise issues, and the right to contact the NRC. The tailgate meetings will be complet~d~y December 31, 2014.
Page 1 of 3
Entergy Nuclear Operations, Inc., Six-Month Status Notification in Response to Confirmatory Order, EA-14-013 Confirmatory Order Item Status Comments B.4:
In-progress EN-Ll-102 Revision 24 Revise procedure EN-Ll-102 to ensure that the Condition Review Group (CRG) chair completed. A read and considers whether the person assigned is sufficiently independent. This applies to sign document was condition reports that have challenges to a decision or a resolution that is highly developed and distributed dependent on a single individual. A read and sign will be provided to each Entergy for signatures.
(fleet-wide) CRG chair to inform them of the procedure revision. The procedure will be revised by November 30, 2014, and the read and sign training will be completed by January 31, 2015.
B.5:
In-progress The case study developed Conduct a case study for supervisors and above throughout the Entergy fleet that was approved for training highlights safety culture aspects of the event: questioning attitude, proceeding in the on 12/8/2014 face of uncertainty, procedure compliance, and responsiveness to employee concerns.
The case study will be developed and conducted by June 30, 2015.
C. Recognition by the Reactor Community:
C.1:
Complete on NRC reviewed presentation Entergy Fleet Director of Nuclear Security shall make a presentation to an industry 11/5/2014 prior to presentation at NEI security working group on this event. The licensee will provide the NRC an opportunity Security Working Group to review the presentation. The presentation shall be accomplished by December 31, meeting on November 5, 2014.
2014 C.2:
On target Currently planned for a Entergy shall make a related presentation at a broad industry meeting aimed at an meeting of the National audience beyond the security organizations and covering all four NRC regions. It is Association of Employee acceptable to make the presentation at multiple meetings, if deemed necessary to reach Concerns Professionals the desired audience. The presentations shall be accomplished by June 30, 2015.
Feb 2015 D. Setting Standards for Security Senior Management:
Entergy shall revise procedure EN-FAP-HR-006 to include specific requirements for In-progress Security Manager selection and development. This shall be accomplished by December On target 31, 2014.
Page 2of3 Entergy Nuclear Operations, Inc., Six-Month Status Notification in Response to Confirmatory Order, EA-14-013
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8.4:
Revise procedure EN-U-102 to ensure that the Condition Review Group (CRG) ch~ir considers whether the person assigned is sufficiently independent. This applies to condition reports that have challenges to a decision or a resolution that is highly dependent on a single individual. A "read and sign JJ will be provided to each Entergy (fleet-wide) CRG chair to inform them of the procedure revision. The procedure will be revised by November 30, 2014, and the "read and sign JJ training will be completed by January 31, 2015.
8.5:
Conduct a case study for supervisors and above throughout the Entergy fleet that highlights safety culture aspects of the event: questioning attitude, proceeding in the face of uncertainty, procedure compliance, and responsiveness to employee concerns.
The case study will be developed and conducted by June 30, 2015.
Status In-progress In-progress Comments EN-U-102 Revision 24 completed. A "read and sign" document was developed and distributed for signatures.
The case study developed was approved for training on 12/8/2014
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Entergy Fleet Director of Nuclear Security shall make a presentation to an industry security working group on this event. The licensee will provide the NRC an opportunity to review the presentation. The presentation shall be accomplished by December 31, 2014.
Complete on 11/5/2014 NRC reviewed presentation prior to presentation at NEI Security Working Group meeting on November 5, 2014 C.2:
I On target Currently planned for a meeting of the National Association of Employee Concerns Professionals Feb 2015 Entergy shall make a related presentation at a broad industry meeting aimed at an audience beyond the security organizations and covering all four NRC regions. It is acceptable to make the presentation at multiple meetings, if deemed necessary to reach the desired audience. The presentations shall be accomplished by June 30, 2015.
r:-O.-SettingStaa,dards for'Secu,rity ~$eniorYM~n~gement: ¥~~J4~WBh<@~'=-]
Entergy shall revise procedure EN-FAP-HR-006 to include specific requirements for Security Manager selection and development. This shall be accomplished by December 31, 2014.
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Entergy Nuclear Operations, Inc., Six-Month Status Notification in Response to Confirmatory Order, EA-14-013 Confirmatory Order Item I
Status Comments E. Effectiveness Review:
Entergy shall arrange for an independent effectiveness review of the actions discussed in On target sections A and B. The review will be conducted no earlier than one year, but less than two years, from the issuance date of the Confirmatory Order.
F. Notification of NRC When Actions Are Completed:
F.1:
In-Progress 6-month status notification Unless otherwise specified, Entergy will submit written notification by letter to the NRC completed.
staff, specifically, the Director, Division of Reactor Safety, 2443 Warrenville Road, Lisle, IL, 60532, at intervals of six months, one year, and annually thereafter until the terms of the Confirmatory Order are completed, providing a status of each item in the Confirmatory Order.
F.2:
On target Upon completion of all terms of the Confirmatory Order, Entergy will provide the NRC with a letter discussing its basis for concluding that the Order has been satisfied.
Page 3of3 Entergy Nuclear Operations, Inc., Six-Month Status Notification in Response to Confirmatory Order, EA-14-013 E. Effectiveness Review: x ~ a2.
Entergy shall arrange for an independent effectiveness review of the actions discussed in I On target sections A and B. The review will be conducted no earlier than one year, but less than two years, from the issuance date of the Confirmatory Order.
, F.
- NotifiQl~ion ~f NRCJNhen Actions,Are Completed:
F.l:
lin-Progress Unless otherwise specified, Entergy will submit written notification by letter to the NRC staff, specifically, the Director, Division of Reactor Safety, 2443 Warrenville Road, Lisle, IL, 60532, at intervals of six months, one year, and annually thereafter until the terms of the Confirmatory Order are completed, providing a status of each item in the Confirmatory Order.
F.2:
I On target Upon completion of all terms of the Confirmatory Order, Entergy will provide the NRC with a letter discussing its basis for concluding that the Order has been satisfied.
Page 3 of 3 6-month status notification completed.