CNRO-2019-00013, Entergy Response to Confirmatory Order EA-17-132/EA-17-153

Entergy Response to Confirmatory Order EA-17-132/EA-17-153

ML19081A270
Person / Time
Site:	Palisades, Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Waterford
Issue date:	03/21/2019
From:	Jury K Entergy Nuclear Operations, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2019-00013, EA-17-132, EA-17-153
Download: ML19081A270 (5)

Text

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~ Enter~

Entergy Operations, Inc.

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5546 Keith Jury Vice-President, Regulatory Assurance EA-17-132 EA-17-153 CNR0-2019-00013 March 21, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Entergy Response to Confirmatory Order EA-17-132/EA-17-153 Arkansas Nuclear One, Units 1 & 2 Indian Point Energy Center, Units 2 & 3 NRC Docket Nos. 50-313 & 50-368 NRC Docket Nos. 50-247 & 50-286 Renewed Facility Operating Renewed Facility Operating License Nos. DPR-51 & NPF-6 License Nos. DPR-26 & DPR-64 Grand Gulf Nuclear Station, Unit 1 Palisades Nuclear Plant NRC Docket No. 50-416 NRC Docket No. 50-255 Renewed Facility Operating Renewed Facility Operating License No. NPF-29 License No. DPR-20 River Bend Station, Unit 1 Pilgrim Nuclear Power Station NRC Docket No. 50-458 NRC Docket No. 50-293 Renewed Facility Operating Renewed Facility Operating License No. NPF-47 License No. DPR-35 Waterford 3 Steam Electric Station NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 A Confirmatory Order was issued to Entergy (Entergy Nuclear Operations, Inc. and Entergy Operations, Inc.) as a result of a successful alternate dispute resolution mediation session (Reference 1). The Confirmatory Order modified the above operating licenses to include specific elements to address willful violations.

During the week of January 7, 2019, NRC Region IV conducted a status inspection of the commitments documented in the referenced Confirmatory Order that were made as part of the settlement agreement between Entergy and the U.S. Nuclear Regulatory Commission (NRC).

During the inspection, the NRC noted weaknesses in the auditability of records associated with

CN R0-20 19-00013 Page 2 of 3 Elements A and 8 of the Confirmatory Order related to integrity communications with site workers. Although the electronic communications from Entergy site and corporate nuclear headquarters contained the intended messaging, clear objective evidence was not available for inspection that validated that the messaging was received and effective.

As a result of this feedback, Entergy developed a plan to strengthen documentation of the two remaining required semiannual integrity communications. The plan includes the utilization of the Entergy Tier 2 Communication process to ensure that the communications are delivered in a timely manner. Tier 2 communications are cascaded down to employees through various meetings and forums. Entergy will record the receipt and acknowledgement of these communications for future traceability.

In addition, Element D of the Confirmatory Order requires Entergy to identify specific criteria necessary to perform annual effectiveness reviews. As part of these effectiveness reviews, Entergy will conduct surveys to ensure the integrity messages have been received and understood. Entergy will modify its corrective actions, as needed, based on the results of the effectiveness reviews.

Entergy performed causal analyses related to gaps in meeting integrity standards, which included extent of condition reviews for work groups that perform NRC regulated activities, to determine if individuals from those work groups engaged in willful misconduct. This review did not identify additional instances of workers engaging in willful misconduct. In addition, plans were developed to conduct quarterly audits of activities performed by these work groups.

Entergy understands the importance of addressing acts of willful misconduct and has and will continue to take additional actions beyond those required by the Order.

This proposed change contains new regulatory commitments, which are described in the Enclosure to this letter.

Should you have any questions or require additional information, please contact Ron Gaston, Fleet Regulatory Compliance Director at 601-368-5138.

Respectfully,

• t*Jua KJ/SLP

REFERENCES:

1) Letter from U. S. Nuclear Regulatory Commission, .. Confirmatory Order, NRC Inspection Report 05000416/2017014, and NRC Investigation Reports 4-2016-004 and 4-2017-021, .. dated March 12,2018 (ADAMS Accession No. ML18072A191)

CNR0-2019-00013 Page 3 of 3

2) Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), .. Entergy Response to Confirmatory Order EA-17 -132/EA-17 -153, Element J, ..

dated September 27, 2018 (ADAMS Accession No. ML18270A430)

3) Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), .. Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K, ..

dated December 28, 2018 (ADAMS Accession No. ML18362A251)

Enclosure:

List of Regulatory Commitments cc: NRC Region I Regional Administrator NRC Project Manager (Pilgrim Nuclear Power Station)

NRC Senior Resident Inspector (Pilgrim Nuclear Power Station)

NRC Project Manager (Indian Point Energy Center, Units 2 & 3)

NRC Senior Resident Inspector (Indian Point Energy Center, Units 2 & 3)

NRC Region Ill Regional Administrator NRC Project Manager (Palisades Nuclear Plant)

NRC Senior Resident Inspector (Palisades Nuclear Plant)

NRC Region IV Regional Administrator NRC Project Manager (Arkansas Nuclear One, Units 1 & 2)

NRC Senior Resident Inspector (Arkansas Nuclear One, Units 1 & 2)

NRC Project Manager (Grand Gulf Nuclear Station)

NRC Senior Resident Inspector (Grand Gulf Nuclear Station)

NRC Project Manager (River Bend Station)

NRC Senior Resident Inspector (River Bend Station)

NRC Project Manager (Waterford 3 Steam Electric Station)

NRC Senior Resident Inspector (Waterford 3 Steam Electric Station)

Enclosure CNR0-2019-00013 List of Regulatory Commitments

CN R0-20 19-00013 Enclosure Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Type (check one) Scheduled Commitment One-Time Continuing Completion Action Compliance Date Entergy developed a plan to strengthen documentation of the two remaining required semiannual Each integrity communications Entergy will remaining utilize the Tier 2 Communication April2019 required process to ensure that the semiannual communications are delivered in a October 2019 integrity timely manner. Entergy will record the communication receipt and acknowledgement of these communications for future traceability.

Element D of the Confirmatory Order requires Entergy to identify specific criteria necessary to perform annual effectiveness reviews. As part of these effectiveness reviews, Entergy will conduct surveys to ensure the integrity December 31, X

messages have been received and 2019 understood. Entergy will modify its corrective actions, as needed, based on the results of the effectiveness reviews.