PNP 2016-042, Annual Status Notification in Response to Confirmatory Order, EA-14-013

Annual Status Notification in Response to Confirmatory Order, EA-14-013

ML16168A135
Person / Time
Site:	Palisades
Issue date:	06/16/2016
From:	Hardy J Entergy Nuclear Operations
To:	O'Brien K Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-14-013, PNP 2016-042
Download: ML16168A135 (4)

Text

~Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Jeffery A. Hardy Director, Regulatory Assurance and Performance Improvement PNP 2016-042 June 16, 2016 EA-14-013 Mr. Kenneth O'Brien U. S. Nuclear Regulatory Commission Director, Division of Reactor Safety 2443 Warrenville Road Lisle, IL 60532

Subject:

Entergy Nuclear Operations, Inc. Annual 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 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 an annual 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, 9h~t7 JAH/tad

Attachment:

Entergy Nuclear Operations, Inc. Annual 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. Annual Status Notification in Response to Confirmatory Order, EA-14-013 Confirmatory Order Item St atus Comments A. Verification of Training Credentials for both Staff and Management:

A.l: Complete Each Entergy site Security Conduct fleet-wide review of qualifications of each duty position in security to ensure Manager validated the that the qualifications for each position are clear and verifiable by all parties (security qualifications for each officers, security supervisors, and security manager). The initial review and applicable position are clear and procedure revisions shall be completed by November 30, 2014. verifiable by all parties A.2: Complete Revised EN-NS-221, Verify and modify, if necessary, the applicable security procedure to ensure that both ((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: Complete Training has been Following completion of A.l and A.2, training will be conducted on the changes. This conducted for all active shall be completed by June 30, 2015. security personnel. For inactive personnel, e.g.,

medical leave, etc., training will be conducted upon resumption of active duty.

B. Strengthen Safety Culture:

B.l: In-progress Quarterly meetings have Through June 30, 2016, the Palisades Security Manager shall meet quarterly (during the been held with each calendar quarter, allowing for one month grace period) with each security team: (a) to security team.

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 I I

"Security Top 10 Issues" board to reflect, among other things, the expected issues and communicated on a I resolution dates. routine basis. I I

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Entergy Nuclear Operations, Inc., Annual Status Notification in Response to Confirmatory Order, EA-14-013 Confirmatory Order Item St atus Comments B.3: Complete The third and final monthly Discuss the safety culture aspects of the event with Palisades Nuclear Plant staff, 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.

B.4: Complete EN-U-102 Revision 24, Revise procedure EN-U-I02 to ensure that the Condition Review Group (CRG) chair Section 5.4[6](d)(1) 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 The "read and sign" training dependent on a single individual. A "read and sign" will be provided to each Entergy to CRG chairs is completed.

(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: Complete Case study sessions were Conduct a case study for supervisors and above throughout the Entergy fleet that conducted by June 30, highlights safety culture aspects of the event: questioning attitude, proceeding in the 2015.

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.l: Complete NRC reviewed presentation Entergy Fleet Director of Nuclear Security shall make a presentation to an industry prior to presentation at NEI security working group on this event. The licensee will provide the NRC an opportun ity Security Working Group to review the presentation. The presentation shall be accomplished by December 31, meeting on November 5, ,

2014. 2014 C.2: Complete Presented at the winter 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 Professiona ls the desired audience. The presentations ~a!Lb~accomplished by June 30, 2015. (ECP), Februar'l}~-25, 2015 Page 2 of 3

Entergy Nuclear Operations, Inc., Annual Status Notification in Response to Confirmatory Order, EA-14-013 Confirmatory Order Item Status Comments D. Setting Standards for Security Senior Management:

Entergy shall revise procedure EN-FAP-HR-006 to include specific requirements for Complete EN-FAP-HR-006 revision 1 I Security Manager selection and development. This shall be accomplished by December issued on December 23, I I

31,2014. 2014 E. Effectiveness Review:

Entergy shall arrange for an independent effectiveness review of the actions discussed in In-progress Independent effectiveness sections A and B. The review will be conducted no earlier than one year, but less than . review started June 13, two years, from the issuance date of the Confirmatory Order. 2016 F. Notification of NRC When Actions Are Completed:

F.1: On target The one year status Unless otherwise specified, Entergy will submit written notification by letter to the NRC notification was completed staff, specifically, the Director, Division of Reactor Safety, 2443 Warrenville Road, Lisle, on June 19, 2015 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.

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