Entergy Response to Confirmatory Order EA-17-132/EA-17-153ML19081A270 |
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) |
|
|
---|
Category:Letter type:CNRO
MONTHYEARCNRO-2022-00015, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling Using the Consolidated Line-Item Improvement Process2022-05-26026 May 2022 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling Using the Consolidated Line-Item Improvement Process CNRO-2021-00023, Entergy Operations, Inc. - Supplement to CNRO-2021-00002, Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L2021-10-0606 October 2021 Entergy Operations, Inc. - Supplement to CNRO-2021-00002, Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L CNRO-2021-00002, Entergy Operations, Inc. - Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L2021-01-28028 January 2021 Entergy Operations, Inc. - Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L CNRO-2020-00023, Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2020 Summary2020-12-17017 December 2020 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2020 Summary CNRO-2020-00021, Response to Request for Additional Information Regarding Relief Requests GG-ISI-020 and RBS-ISI-0192020-11-0909 November 2020 Response to Request for Additional Information Regarding Relief Requests GG-ISI-020 and RBS-ISI-019 CNRO-2020-00016, Entergy Nuclear Operations, Inc - Relief Request EN-RR-20-002: Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv)2020-08-12012 August 2020 Entergy Nuclear Operations, Inc - Relief Request EN-RR-20-002: Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv) CNRO-2020-00015, Request to Update ASME Code Relief Request Safety Evaluations with NRC-Approved Revision of BWRVIP Guidelines (GG-ISI-020, and RBS-ISI-019)2020-06-0808 June 2020 Request to Update ASME Code Relief Request Safety Evaluations with NRC-Approved Revision of BWRVIP Guidelines (GG-ISI-020, and RBS-ISI-019) CNRO-2020-00009, Application to Revise Technical Specifications to Adopt TSTF-501 Relocate Stored Fuel Oil and Lube Oil Volumes to Licensee Control, Revision 12020-02-26026 February 2020 Application to Revise Technical Specifications to Adopt TSTF-501 Relocate Stored Fuel Oil and Lube Oil Volumes to Licensee Control, Revision 1 CNRO-2020-00008, Application to Revise Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR-Shutdown Cooling Subsystems Using the Consolidated Line Item Improvement Process2020-01-24024 January 2020 Application to Revise Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR-Shutdown Cooling Subsystems Using the Consolidated Line Item Improvement Process CNRO-2020-00006, Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, Revision 22020-01-24024 January 2020 Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, Revision 2 CNRO-2019-00030, Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2019 Summary2019-12-30030 December 2019 Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2019 Summary CNRO-2019-00007, Grand Gulf Nuclear Station; and Waterford 3 Steam Electric Station - Decommissioning Funding Status Report2019-03-28028 March 2019 Grand Gulf Nuclear Station; and Waterford 3 Steam Electric Station - Decommissioning Funding Status Report CNRO-2019-00006, Stations - Status of Funding for Managing Irradiated Fuel for Year Ending December 31, 2018 - 10 CFR 50.82(a)(8)(vii) - Entergy Nuclear Operations, Inc2019-03-28028 March 2019 Stations - Status of Funding for Managing Irradiated Fuel for Year Ending December 31, 2018 - 10 CFR 50.82(a)(8)(vii) - Entergy Nuclear Operations, Inc CNRO-2019-00010, Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3))2019-03-28028 March 2019 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) CNRO-2019-00005, Stations - Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) - Entergy Nuclear Operations, Inc2019-03-28028 March 2019 Stations - Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) - Entergy Nuclear Operations, Inc CNRO-2019-00013, Entergy Response to Confirmatory Order EA-17-132/EA-17-1532019-03-21021 March 2019 Entergy Response to Confirmatory Order EA-17-132/EA-17-153 CNRO-2019-00009, Stations - Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR, Revision 22019-03-0707 March 2019 Stations - Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR, Revision 2 CNRO-2019-00003, Application to Revise Technical Specifications to Adopt TSTF-529 11 Clarify Use and Application Rules, 11 Revision 42019-01-31031 January 2019 Application to Revise Technical Specifications to Adopt TSTF-529 11 Clarify Use and Application Rules, 11 Revision 4 CNRO-2019-00002, Relief Request Number EN-19-RR-1, Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 12019-01-31031 January 2019 Relief Request Number EN-19-RR-1, Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 1 CNRO-2018-00051, Grand Gulf Nuclear Station, Palisades Nuclear Plant, River Bend Station, Pilgrim Nuclear Station and Waterford 3 - Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K2018-12-28028 December 2018 Grand Gulf Nuclear Station, Palisades Nuclear Plant, River Bend Station, Pilgrim Nuclear Station and Waterford 3 - Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K CNRO-2018-00047, Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment; and Request for Exemption from 10 CFR 50.82(a)(8)(i)(A)2018-11-16016 November 2018 Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment; and Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) CNRO-2018-00039, Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element J2018-09-27027 September 2018 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element J CNRO-2018-00031, Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E2018-07-0303 July 2018 Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E CNRO-2018-00023, Request to Revise Quality Assurance Program Approval for Radioactive Material Packages No. 02402018-06-18018 June 2018 Request to Revise Quality Assurance Program Approval for Radioactive Material Packages No. 0240 CNRO-2018-00021, Response to Request for Supplemental Information Regarding Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in the Spent Fuel Pools for Indian Point Energy Center, Unit 3 and Waterford 3 Steam Electric Station2018-05-30030 May 2018 Response to Request for Supplemental Information Regarding Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in the Spent Fuel Pools for Indian Point Energy Center, Unit 3 and Waterford 3 Steam Electric Station CNRO-2018-00018, Anchor Darling Double Disc Gate Valve Information and Status2018-04-16016 April 2018 Anchor Darling Double Disc Gate Valve Information and Status CNRO-2018-00012, Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)2018-03-29029 March 2018 Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) CNRO-2018-00011, Submittal of Joint Plant Access Shared Information Table2018-03-19019 March 2018 Submittal of Joint Plant Access Shared Information Table CNRO-2017-00022, Relief Request Number EN-17-RR-1 - Proposed Alternative to Use ASME Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate-Energy Class 2 or 3 Piping, Section XI, Division 12017-11-17017 November 2017 Relief Request Number EN-17-RR-1 - Proposed Alternative to Use ASME Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate-Energy Class 2 or 3 Piping, Section XI, Division 1 CNRO-2017-00012, Request to Remove James A. FitzPatrick Nuclear Power Plant from Quality Assurance Program Approval for Radioactive Material Packages No. 02402017-06-14014 June 2017 Request to Remove James A. FitzPatrick Nuclear Power Plant from Quality Assurance Program Approval for Radioactive Material Packages No. 0240 CNRO-2017-00009, Entergy Nuclear Operations, Inc. - Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)2017-03-31031 March 2017 Entergy Nuclear Operations, Inc. - Decommissioning Funding Status Report Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) CNRO-2017-00010, Entergy Operations, Inc. - Decommissioning Funding Status Report2017-03-31031 March 2017 Entergy Operations, Inc. - Decommissioning Funding Status Report CNRO-2017-00007, Nuclear Property Damage Insurance (10 CFR 50.54(w)(3))2017-03-30030 March 2017 Nuclear Property Damage Insurance (10 CFR 50.54(w)(3)) CNRO-2017-00005, and Isfsl - License Amendment Request for Administrative Change to Licensee Name2017-03-29029 March 2017 and Isfsl - License Amendment Request for Administrative Change to Licensee Name CNRO-2017-00004, Notice Regarding Third Proposed Amendment to Master Trust and Planned Distribution of Assets from FitzPatrick Unit Fund to Trust Established2017-01-20020 January 2017 Notice Regarding Third Proposed Amendment to Master Trust and Planned Distribution of Assets from FitzPatrick Unit Fund to Trust Established CNRO-2016-00023, Request EN-ISI-16-1: Use of Later Edition/Addenda of Amse Section XI Code for ISI Related Activities2016-12-0101 December 2016 Request EN-ISI-16-1: Use of Later Edition/Addenda of Amse Section XI Code for ISI Related Activities CNRO-2016-00020, Application for Order to Transfer Master Decommissioning Trust from PASNY to ENO, Consenting to Amendments to Trust Agreement, and Approving Proposed License Amendments to Modify and Delete Decommissioning .2016-08-16016 August 2016 Application for Order to Transfer Master Decommissioning Trust from PASNY to ENO, Consenting to Amendments to Trust Agreement, and Approving Proposed License Amendments to Modify and Delete Decommissioning . CNRO-2016-00017, Entergy Nuclear Operations - Request for Approval of Change to the Quality Assurance Program Manual2016-07-19019 July 2016 Entergy Nuclear Operations - Request for Approval of Change to the Quality Assurance Program Manual CNRO-2016-00016, Entergy - Response to RAI Questions and Submittal of Relief Request EN-ISI-15-1 (Updated)2016-06-0202 June 2016 Entergy - Response to RAI Questions and Submittal of Relief Request EN-ISI-15-1 (Updated) CNRO-2016-00008, Entergy - Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3))2016-03-30030 March 2016 Entergy - Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) CNRO-2016-00010, Entergy Nuclear Operations, Inc. - Decommissioning Funding Status Report, Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v)2016-03-30030 March 2016 Entergy Nuclear Operations, Inc. - Decommissioning Funding Status Report, Per 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) CNRO-2016-00009, Unit 3 - Supplement to Notice of Change in Corporate Form of Entergy Nuclear New York Investment Company I and Creditor Agreement2016-03-21021 March 2016 Unit 3 - Supplement to Notice of Change in Corporate Form of Entergy Nuclear New York Investment Company I and Creditor Agreement CNRO-2016-00006, Notice of Change in Corporate Form of Entergy Nuclear New York Investment Company I and Creditor Agreement2016-02-25025 February 2016 Notice of Change in Corporate Form of Entergy Nuclear New York Investment Company I and Creditor Agreement CNRO-2016-00005, Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM)2016-02-25025 February 2016 Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM) CNRO-2016-00004, Notice Regarding Acquisition of Title to Leased Interest2016-02-10010 February 2016 Notice Regarding Acquisition of Title to Leased Interest CNRO-2016-00002, Entergy - Relief Request Number RR EN-15-1, Rev. 1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Water Service, Secti2016-01-29029 January 2016 Entergy - Relief Request Number RR EN-15-1, Rev. 1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Water Service, Section Xl, CNRO-2015-00002, Entergy Operations, Inc. - Response to RAI Questions and Submittal of RR EN-15-2, Rev. 12015-12-0404 December 2015 Entergy Operations, Inc. - Response to RAI Questions and Submittal of RR EN-15-2, Rev. 1 CNRO-2015-00022, Entergy - Relief Request EN-ISI-15-1: Proposed Alternative to Maintain ISI-Related Activities to the 2001 Edition/2003 Addendum of ASME Section Xl Code2015-11-20020 November 2015 Entergy - Relief Request EN-ISI-15-1: Proposed Alternative to Maintain ISI-Related Activities to the 2001 Edition/2003 Addendum of ASME Section Xl Code CNRO-2015-00023, Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM)2015-11-0606 November 2015 Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM) CNRO-2015-00021, Confirmatory Order - Action H2015-11-0303 November 2015 Confirmatory Order - Action H 2022-05-26
[Table view] |
Text
-
~ 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,
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.