ML13199A350: Difference between revisions

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| docket = 05000416
| docket = 05000416
| license number =  
| license number =  
| contact person = Gavula J A
| contact person = Gavula J
| case reference number = EA-13-058, IR-13-201
| case reference number = EA-13-058, IR-13-201
| document type = Slides and Viewgraphs, Meeting Briefing Package/Handouts
| document type = Slides and Viewgraphs, Meeting Briefing Package/Handouts
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{{#Wiki_filter:Pre-decisional Enforcement Conference in response to NRC Inspection Report 05000416/2013201
{{#Wiki_filter: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
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
Opening Remarks
* Acknowledge each example to be valid
* Implemented interim corrective actions
* Finalizing causal evaluation
* Planning additional corrective actions


License Renewal Organization Corporate team focuses on:
License Renewal Organization Entergy License Renewal Structure
-Standardization of IPA, TLAA, and ER efforts.
* Corporate team focuses on:
-Standardization of LRA; incorporating latest industry lessons learned and optimized practices.
                                    -Standardization of IPA, TLAA, and ER efforts.
Site team focuses on:
                                    -Standardization of LRA; incorporating latest industry lessons learned and optimized practices.
-Confirmation of CLB, OE, DB, AMP detail. -Review of all IPA, TLAA, ER, and LRA documents before submittal to NRC. Entergy License Renewal Structure
* 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
Performance Gaps
-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
* 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


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
Causes
-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
* 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 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
Perspective on Significance NRC Enforcement Policy guidance for SL III violation
-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}}
  - 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}}

Latest revision as of 16:50, 4 November 2019

Predecisional Enforcement Conference Presentation Slides July 16, 2013
ML13199A350
Person / Time
Site: Grand Gulf Entergy icon.png
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)
v • d • e


Text

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

Agenda

  • Opening Remarks
  • 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
  • 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
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