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 K

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

ML18362A251
Person / Time
Site:	Palisades, Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Waterford
Issue date:	12/28/2018
From:	Gaston R Entergy Nuclear Operations, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2018-00051, EA-17-132, EA-17-153
Download: ML18362A251 (6)

Text

• ~ Enterpv o..J Entergy Operations, Inc.

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Ron Gaston Director, Regulatory Compliance 10 CFR 2.202 CNR0-2018-00051 December 28, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K Arkansas Nuclear One, Units 1 & 2 Indian Point Energy Center, Docket Nos. 50-313 & 50-368 Units 2 & 3 License Nos. DPR-51 & NPF-6 Docket Nos. 50- 247 & 50-286 License Nos. DPR- 26 & DPR-64 Grand Gulf Nuclear Station, Unit 1 Palisades Nuclear Plant Docket No. 50-416 Docket 50-255 License No. NPF-29 License No. DPR-20 River Bend Station, Unit 1 Pilgrim Nuclear Power Station Docket No. 50-458 Docket No. 50-293 License No. NPF-47 Renewed License No. DPR-35 Waterford 3 Steam Electric Station Docket No. 50-382 License No. NPF-38

References:

1) U.S Nuclear Regulatory Commission (NRG) letter to Entergy (Entergy Nuclear Operations, Inc. and Entergy Operations, Inc.), "Confirmatory Order, NRG Inspection Report 05000416/2017014, and NRG Investigation Reports 4-2016-004 and 4-2017-021," dated March 12, 2018

2) Entergy Nuclear Operations, Inc. and Entergy Operations, Inc. letter to the NRG, "Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element J," CNR0-2018-00039, dated September 27, 2018 Reference 1 modified the above operating licenses to include specific elements to address willful violations. As required by Section V, Element K, the attachment provides, in writing to the appropriate Regional Administrators, a summary of the actions implemented across the fleet as a result of this Confirmatory Order and the results of any effectiveness reviews performed.

CNR0-2018-00051 Page 2 of 3 Should you have any questions or require additional information, please contact John Giddens, Senior Manager, Fleet Regulatory Assurance, at (601) 368-5756.

I declare under penalty of perjury, the foregoing is true and correct.

Executed on the 281h day of December, 2018.

Respectfully, Ron Gaston Director, Regulatory Compliance RWG/jjn/gpn Attachments:

Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K

CN R0-2018-00051 Page 3 of 3 cc: Rich Anderson (ANO)

Stephenie Pyle (ANO)

Eric Larson (GGN)

Douglas Neve (GGN)

Charlie Arnone (PLP)

Jeff Hardy (PLP)

Brian Sullivan (PNP)

Peter Miner (PNP)

Anthony Vitale (IP)

Robert Walpole (IP)

Steve Vercelli (RBS)

Timothy Schenk (RBS)

John Dinelli (WF3)

John Signorelli (WF3)

NRC Region I Administrator NRC Project Manager (Pilgrim)

NRC Senior Resident Inspector (Pilgrim)

NRC Project Manager (Indian Point)

NRC Senior Resident Inspector (Indian Point)

NRC Region Ill Administrator NRC Project Manager (Palisades)

NRC Senior Resident Inspector (Palisades)

NRC Region IV Administrator NRC Project Manager (Arkansas Nuclear One)

NRC Senior Resident Inspector (Arkansas Nuclear One)

NRC Project Manager (Grand Gulf)

NRC Senior Resident Inspector (Grand Gulf)

NRC Project Manager (River Bend)

NRC Senior Resident Inspector (River Bend)

NRC Project Manager (Waterford)

NRC Senior Resident Inspector (Waterford)

ATTACHMENT TO CNR0-2018-00051 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K

Attachment CNR0-2018-00051 Page 1 of 2 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K In Reference 1, the NRC issued a Confirmatory Order to Entergy (Entergy Nuclear Operations, Inc., and Entergy Operations, Inc.) as a result of a successful alternate dispute resolution.

Section V of the Confirmatory Order modified Entergy License Nos. DRP-51, NPF-6, NPF-29, DPR-26, DPR-64, DPR-20, DPR-35, NPF-47 and NPF-38 to include Elements A through L.

This attachment responds to Section V, Element K for calendar year 2018.

Notifications to the NRC when Actions Are Completed, Element K By December 31 of each calendar year from 2018 through 2020, Entergy will provide in writing to the appropriate Regional Administrators a summary of the actions implemented across the fleet as a result of this Confirmatory Order and the results of any effectiveness reviews performed.

Entergy Response, Element K The following is a summary of the actions implemented across the fleet as a result of this Confirmatory Order.

Communications with Site Workers Between March 3, 2018 and April 11, 2018, communications about integrity were shared from the Chief Nuclear Officer (CNO) and senior site leaders with Entergy employees and contractors. The tool "Nuclear Talk" was used to share the message. A video with the CNO about integrity was also distributed across the fleet. These messages communicated with workers the circumstances leading to this Confirmatory Order, that willful violations will not be tolerated, and, as a result, Entergy will be undertaking efforts to confirm whether others are engaging in such conduct at any of its sites. The communications stressed the importance of procedural adherence, ensuring that documents are complete and accurate, and of potential consequences for engaging in willful violations. The messages were balanced with the recognition that people do make mistakes and when that happens, it is Entergy's expectation that its employees and contractors will identify and document issues accordingly.

Between September 21, 2018 and October 1O, 2018, Entergy conducted the first semi-annual communications with workers in the Entergy fleet reemphasizing its intolerance of willful misconduct and updating the workforce on the status of compliance with this Confirmatory Order.

Causal Evaluation of Previous Corrective Actions to Deter Willful Violations Between June 13, 2016 and August 28, 2018, Entergy performed five station root cause evaluations (RCEs) and two fleet level RCEs to accomplish the objectives set forth in the Confirmatory Order. This was previously communicated to the NRC via letter CNR0-2018-00039, Reference 2.

Attachment CNR0-2018-00051 Page 2 of 2 The following fleet wide actions were implemented in 2018 from the RCEs or Training Evaluations related to the Confirmatory Order.

• Implemented a periodic audit of operator rounds to detect and deter operator rounds issues

• Implemented a periodic assessment of proctoring activities to detect and deter proctoring issues

• Conducted Extent of Condition reviews fleet-wide based on the Grand Gulf, River Bend, Waterford, and fleet root causes conducted for this confirmatory order

• Implemented Extent of Cause actions in other departments which conduct periodic audits to detect and deter willful non-compliance

• Revised the Safety Culture Executive T earn governance to improve monitoring of concerns and actions involving safety culture at a fleet level

• Established a Confidential Corrective Actions Process to apply the rigors of higher level causal investigation, to willful non-compliance

• Included 10CFR 50.5, 50.7, and 50.9, Deliberate Misconduct/ Completeness and Accuracy of Information I Employee Protection" training in the 2018 Supervisor Continuing Training curricula There were no Effectiveness Reviews conducted for the Confirmatory Order in 2018. The first scheduled Effectiveness Review is in 2019.

Organizational Health Survey Entergy conducted the 2018 Organizational Health Index (OHi) Survey in July 2018. This survey was developed by a third party and designed, in part, to identify safety culture concerns that could contribute to willful misconduct. The results were received on August 3, 2018, and showed an overall improvement from 2017.