ML20084L272
| ML20084L272 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/29/2020 |
| From: | David Lew Region 1 Administrator |
| To: | Stoddard D Dominion Energy |
| Marjorie McLaughlin | |
| References | |
| EA-17-077 | |
| Download: ML20084L272 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406-2713 April 29, 2020 EA-17-077 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Dominion Energy, Inc.
Innsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, VA 23060-6711
SUBJECT:
CONFIRMATION OF COMPLETION OF ACTIONS TAKEN BY DOMINION ENERGY, INC. AS SET FORTH IN NRC CONFIRMATORY ORDER DATED NOVEMBER 21, 2017
Dear Mr. Stoddard:
The purpose of this letter is to acknowledge the actions Dominion Energy, Inc. (Dominion) has taken in response to the Confirmatory Order (Order) issued to you by the U.S. Nuclear Regulatory Commission (NRC) on November 21, 2017 (ML17318A216 1). The actions were taken to fulfill commitments that were made as part of a settlement agreement reached during a September 20, 2017, Alternative Dispute Resolution (ADR) mediation session between Dominion and the NRC. Dominion requested the ADR mediation session in response to a letter the NRC issued on July 20, 2017 (ML17200C967), which informed Dominion of the results of an investigation by the NRC Office of Investigations (OI) conducted at Dominions Millstone Power Station (Millstone). As described in the July 20, 2017, letter, based on the investigation, the NRC determined that a former contract security officer working as an Armorer at Millstone deliberately failed to perform assigned duties pertaining to the accountability, testing, and maintenance of site response weapons and falsified related records. The former contract security officers actions caused Dominion to be in violation of NRC regulations pertaining to maintenance and testing of firearms and requiring that information required to be maintained (i.e., records) are complete and accurate in all material respects. In the July 20, 2017, letter, the NRC informed Dominion that the NRC was considering escalated enforcement action for the violations and offered Dominion the opportunity to provide its perspectives on the matter or request ADR, and Dominion selected the latter.
As a result of the mediation, and as documented in the subject Order, Dominion agreed to take a number of actions to address the violations, including: evaluating security contractor oversight and conduct of related training; obtaining independent reviews of the safety culture and organizational effectiveness within the site security organization, evaluating implementation of the armorer function and weapons accountability process at Millstone, and communicating 1
Designation in parentheses refers to an Agency-wide Documents Access and Management System (ADAMS) accession number. Unless otherwise noted, documents referenced in this letter are publicly-available using the accession number in ADAMS.
D. Stoddard 2 about the issue to industry peers. In recognition of these actions, the NRC agreed to not issue a civil penalty and to not consider the Order to be an escalated enforcement action by the NRC for future assessment of violations occurring at Millstone.
The commitments contained in the Order, a description of Dominions actions to fulfill each commitment, and a summary of the NRC evaluation of Dominions actions are provided in the enclosed table (Enclosure). The NRC has determined that Dominion has satisfied all terms of the Order. We have no further questions at this time, and you are not required to submit any further correspondence to the NRC on these matters. However, if you have any questions or comments, please contact Marjorie McLaughlin of my staff at 610-337-5240.
In accordance with 10 CFR 2.390, of the NRC's Rules of Practice, a copy of this letter and its enclosure and your response, should you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room and from the NRCs Agencywide Document Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely, Digitally signed by David C. Lew David C. Lew Date: 2020.04.29 07:09:27
-04'00' David C. Lew Regional Administrator
Enclosure:
As stated Docket Nos. 50-336 and 50-423 License Nos. DPR-65 and NPF-49
ML20084L272 DOCUMENT NAME: S:\Enf-allg\Enforcement\ADR\Millstone Security\Confirmation of Completion of Order Actions_ML20084L272.docx X Non-Sensitive X Publicly Available X SUNSI Review/ MMM Sensitive Non-Publicly Available OFFICE RI/ORA RI/DRS RI/DRP RI/ ORA RI/ORA RI/RA M McLaughlin/ D Schroeder via B Klukan via R McKinley via F Bower via email D Lew via email MMM email email email DATE 3/24/2020 4/15/2020 4/15/2020 4/15/2020 4/15/2020 4/27/2020 OFFICE NAME DATE ENCLOSURE Completion of Actions Set Forth in the Confirmatory Order Confirmatory Order Commitment Actions by Dominion NRCs Evaluation A.1 Dominion agreed to, within 30 days of On December 5, 2017, Dominion The NRC documented its inspection the date of the Order, prepare a full completed the full inventory. confirming that Dominion completed inventory of all in-service and out-of- (Ref. ML17363A217) this action in Inspection Report No.
service weapons on site. 050-336/2018410; 050-423/2018410.
(Ref. ML18205A363) 2 A.2 Dominion agreed to, within 30 days of On December 11, 2017, Dominion The NRC documented its inspection the date of the Order, prepare a report prepared a report of the maintenance confirming that Dominion completed of the maintenance status of all in- status of all in-service weapons on site. this action in Inspection Report No.
service weapons on site. (Ref. ML17363A217) 050-336/2018410; 050-423/2018410.
(Ref. ML18205A363)2 B.1 Dominion agreed to, within 30 days of On November 27, 2017, the Dominion The NRC documented its inspection the date of the Order, communicate Nuclear Senior Vice President and Chief confirming that Dominion completed the issue to all personnel at Millstone Nuclear Officer issued an electronic mail this action in Inspection Report No.
and other Dominion Energy, Inc. message to all personnel at Dominion 050-336/2018410; 050-423/2018410.
nuclear sites. Energy nuclear sites that discussed the (Ref. ML18205A363)2 importance of transparency and ethics in the performance of actions, emphasized that falsification of records is unethical and will not be tolerated, and provided guidance on specific actions to take if an individual feels that he or she is unable to complete work as expected and required.
Supervisors were provided copies of the message to post for employees who may not readily have access to email themselves.
(Ref. ML17363A206) 2 Non-public due to the inclusion of security-sensitive information.
Enclosure 2 Confirmatory Order Commitment Actions by Dominion NRCs Evaluation B.2 Dominion agreed to, within 10 days of Dominion did not submit formal The NRC documented its inspection the date of the Order, ensure that documentation of completion of this item, confirming that Dominion completed Dominions records related to the but it was confirmed to have been this action in Inspection Report No.
former security officers entry in the completed via NRC inspection. 050-336/2018410; 050-423/2018410.
Personnel Access Data System (Ref. ML18205A363)2 included information related to this case.
C.1. Dominion agreed to, within 180 days On April 9, 2018, Dominion completed an The NRC documented its inspection of the date of the Order, perform an evaluation of its oversight of confirming that Dominion completed evaluation of its oversight of the the security contract organization. The this action in Inspection Report No.
security contract organization. evaluation reviewed reporting 050-336/2018410; 050-423/2018410.
relationships, licensee and contractor (Ref. ML18205A363)2 responsibilities for individual performance management, and the means in place to verify that regulatory requirements are being met. Results of the evaluation were captured in a Station Performance Improvement Report (PIR). The PIR identified recommended potential enhancements.
(Ref. ML18134A033)
Enclosure 3 Confirmatory Order Commitment Actions by Dominion NRCs Evaluation C.2 Dominion agreed to, within 90 days of On May 16, 2018, Dominion completed The NRC documented its inspection completing the evaluation described in training to Dominion Security management confirming that Dominion completed C.1, administer training to Dominion staff that focused on roles and this action in Inspection Report No.
Security management staff that expectations for managing contractor staff 050-336/2018410; 050-423/2018410.
focused on roles and expectations for and reinforced Dominions responsibility (Ref. ML18205A363)2 managing contractor staff and the for assuring regulatory compliance.
reinforced Dominions responsibility (Ref. ML18170A091) for assuring regulatory compliance.
C.3 Dominion agreed to, within 120 days Dominion retained a safety culture expert The NRC documented its inspection of the date of the Order, administer a external to the Dominion Energy Inc. confirming that Dominion completed safety culture survey to the Millstone organization. The safety culture expert this action in Inspection Report No.
security organization. Dominion reviewed the results of an organizational 050-336/2019410; 050-423/2019410.
agreed to, prior to administering the effectiveness survey implemented by (Ref. ML19057A612)2 survey, retain a safety culture expert, Dominion from November 2017 to January external to the Dominion Energy Inc. 2018 and compared the results to the organization, to review Dominions safety culture assessment in the root root cause evaluation of the issue. cause related to armorer performance.
This comparison was used to develop and implement additional safety culture survey questions for which data was collected through March 19, 2018.
(Ref. ML18226A084)
Enclosure 4 Confirmatory Order Commitment Actions by Dominion NRCs Evaluation C.4 Dominion agreed to, within 240 days On July 16, 2018, Dominion completed an The NRC documented its inspection of the date of the Order, perform an organizational effectiveness evaluation of confirming that Dominion completed organizational effectiveness the Millstone security organization. The this action in Inspection Report No.
evaluation of the Millstone security evaluation team included four members, 050-336/2019410; 050-423/2019410.
organization. two of which were external to Dominion (Ref. ML19057A612)2 Energy Inc., including the safety culture expert from Item C.3. The evaluation reviewed results of the safety culture survey developed in Item C.3, including trending within the Millstone security organization and benchmarking with other Dominion nuclear sites, along with the root cause evaluation of armorer performance, with particular emphasis on the traits of a healthy nuclear safety culture. The evaluation also reviewed the clarity for the security staff about lines of responsibility and reporting, and the performance and quality of how individual job performance results are evaluated, documented, and communicated. Based on conclusions identified in the evaluation, an action plan that includes measures of effectiveness was developed and entered into the Station's corrective action program.
(Ref. ML18226A084)
Enclosure 5 Confirmatory Order Commitment Actions by Dominion NRCs Evaluation D.1 Dominion agreed to, within 180 days of On March 9, 2018, Dominion completed its The NRC documented its inspection the date of the Order, evaluate its evaluation of the implementation confirming that Dominion completed implementation of the Armorer function of the Armorer function at Millstone. The this action in Inspection Report No.
at Millstone. evaluation included a comparison of the 050-336/2018410; 050-423/2018410.
Millstone processes to other Dominion (Ref. ML18205A363)2 Energy and non-Dominion Energy nuclear stations. Results of the evaluations were captured in a Station Performance Improvement Report (PIR). The PIR identified strengths and recommended potential enhancements.
(Ref. ML18094A117)
D.2 Dominion agreed to, within 90 days of On March 23, 2018, Dominion The NRC documented its inspection completing the evaluation described in communicated the results of the evaluation confirming that Dominion completed Item D.1, communicate to Dominion of the armorer function to security this action in Inspection Report No.
Security management staff at Millstone personnel. 050-336/2018410; 050-423/2018410.
the results of the evaluation of the (Ref. ML18109A041) (Ref. ML18205A363)2 armorer function and any completed or pending corrective actions.
E.1 Dominion agreed to, within 180 days of On March 9, 2018, Dominion completed its The NRC documented its inspection the date of the Order, review its process evaluation of the process for performing confirming that Dominion completed for performing and recording in-service and recording in-service and out-of-service this action in Inspection Report No.
and out-of-service weapons inventory. weapons inventory. The evaluation 050-336/2019410; 050-423/2019410.
included a comparison of the Millstone (Ref. ML19057A612)2 processes to other Dominion Energy and non-Dominion Energy nuclear stations.
Results of the evaluations were captured in a Station Performance Improvement Report (PIR). The PIR identified strengths and recommended potential enhancements.
(Ref. ML18094A117)
Enclosure 6 Confirmatory Order Commitment Actions by Dominion NRCs Evaluation F.1. Dominion agreed to, within 90 days of On February 15, 2018, Dominion The NRC documented its inspection the date of the Order, complete the first completed the first quarterly review. confirming that Dominion completed of four quarterly reviews of the (Ref. ML18075A326) this action in Inspection Report No.
effectiveness of the weapons 050-336/2019410; 050-423/2019410.
maintenance program and corrective (Ref. ML19057A612) actions implemented in response to this issue.
F.2 Dominion agreed to make the Dominion reiterated its commitment to The NRC documented its inspection effectiveness reviews available to the make the effectiveness reviews available confirming that Dominion completed NRC for review for a period of one to the NRC for inspection for a period of this action in Inspection Report No.
year. one year after completion of the final 050-336/2019410; 050-423/2019410.
review. (Ref. ML19057A612)2 (Ref. ML18075A326)
G.1 Dominion agreed to, by December 31, On March 19, 2019, Dominion completed The NRC documented its inspection 2019, discuss the issue to the Nuclear a presentation to the Nuclear Security confirming that Dominion completed Security Working Group and the 2019 Working Group. On August 20, 2019, this action in Inspection Report No.
National Nuclear Security Conference. Dominion completed a presentation to the 050-336/2019411; 050-423/2019411.
2019 National Security and Emergency (Ref. ML19263B953)2 Preparedness Summit (previously called National Nuclear Security Conference).
The presentations included a discussion of the issue, the results of the evaluations performed, including organizational weaknesses that contributed to the issue, and the resulting corrective actions taken.
(Ref. ML19109A108 & ML19260D632)