CNRO-2021-00002, Entergy Operations, Inc. - Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L

Entergy Operations, Inc. - Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L

ML21028A782
Person / Time
Site:	Palisades, Indian Point, Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	01/28/2021
From:	Gaston R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2021-00002, EA-17-132, EA-17-153
Download: ML21028A782 (9)

Text

Entergy Operations, Inc.

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Ron Gaston Director Nuclear Licensing 10 CFR 2.202 CNRO-2021-00002 January 28, 2021 NRC Region IV Administrator U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511

Subject:

Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 are Complete, Element L Arkansas Nuclear One, Units 1 & 2 Indian Point Energy Center, Units 2 & 3 Docket Nos. 50-313 & 50-368 Docket Nos. 50- 247 & 50-286 License Nos. DPR-51 & NPF-6 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 Waterford 3 Steam Electric Station Docket No. 50-458 Docket No. 50-382 License No. NPF-47 License No. NPF-38

Reference:

U.S. Nuclear Regulatory Commission (NRC) letter to Entergy (Entergy Nuclear Operations, Inc. and Entergy Operations, Inc.), Confirmatory Order, NRC Inspection Report 05000416/2017014, and NRC Investigation Reports 4-2016-004 and 4-2017-021, dated March 12, 2018 (ACCESSION No.: ML18072A191)

Confirmatory Order EA-17-132/EA-17-153 modified the above operating licenses to include specific elements to address willful violations. As required by Section V, Element L, the enclosure provides Entergys basis for concluding the terms of this Confirmatory Order are complete. The other appropriate Regional Administrators are copied on this notification.

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 January 28, 2021.

Respectfully, Ron Gaston RWG/jjn/jas

CNRO-2021-00002 Page 2 of 2

Enclosure:

Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element L cc:

John Dinelli (ANO)

Riley Keele (ANO)

Robert Franssen (GGN)

Jeff Hardy (GGN)

Darrell Corbin (PLP)

Barbara Dotson (PLP)

Anthony Vitale (IP)

Mahvash Mirzai (IP)

Steve Vercelli (RBS)

Timothy Schenk (RBS)

John Ferrick (WF3)

Paul Wood (WF3)

NRC Region I Administrator 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 - addressee 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)

NRC Document Control Desk

Enclosure CNRO-2021-00002 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element L

Enclosure CNRO-2021-00002 Page 1 of 6 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element L The Nuclear Regulatory Commission (NRC) issued Confirmatory Order EA-17-132/EA-17-153 to Entergy (Entergy Nuclear Operations, Inc., and Entergy Operations, Inc.) as a result of a successful alternate dispute resolution (Reference 1).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 enclosure responds to Section V, Element L for License Nos. DRP-51, NPF-6, NPF-29, DPR-26, DPR-64, DPR-20, NPF-47 and NPF-38. 1 Notifications to the NRC when Actions Are Completed, Element L Upon completion, Entergy will submit in writing to the Region IV Administrator, its basis for concluding that the terms of the Confirmatory Order have been completed.

Entergy Response, Element L The following is a summary of Entergy's basis for concluding that the terms of the Confirmatory Order have been completed. 2 Communications with Site Workers, Element A Within 1 month of the issuance date of the Confirmatory Order, a licensee senior executive at each Entergy site and the corporate nuclear headquarters will communicate 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 communication will stress the importance of procedural adherence, ensuring that documents are complete and accurate, and of potential consequences for engaging in willful violations. This message will be 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.

These communications were completed between March 3, 2018 and April 11, 2018. Entergy assessed these communications for content and assignment. The NRC inspected these communications and provided observations to improve documentation of receipt and acknowledgement in future communications (Reference 6). Entergy committed to document receipt and to conduct surveys associated with the communications (Reference 4). Entergy assessed the future communications discussed in Reference 6 and found the communications and commitments properly implemented. Element A communications were closed by the NRC in the NRC Confirmatory Order (EA-17-132 and EA-17-153) Follow-up Inspection Report (Reference 7). 3 1 This enclosure does not include a response for DPR-35 based on the license transfer in August of 2019.

2 Previous year summary of actions taken are contained in Reference 3, Reference 5 and Reference 9.

3 NRC Confirmatory Order (EA-17-132 and EA-17-153) Follow-up Inspection Report (Reference 7) applies to DPR-51, NPF-6, NPF-29, NPF-47, and NPF-38.

Enclosure CNRO-2021-00002 Page 2 of 6 Communications with Site Workers, Element B Within 6 months of the completion of Element A, Entergy will conduct 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 until December 31, 2019. Starting in 2020, Entergy will conduct annual training emphasizing its intolerance of willful misconduct.

The six-month communications were conducted in September/October 2018. The subsequent semi-annual communications were conducted in March/April 2019, and September/October 2019. Entergy assessed theses communications and the associated commitments made in Reference 4 and found the implementation acceptable. To address the Element B requirement for 2020 annual training, Entergy implemented a computer-based training (CBT) module in 2019. Entergy assessed this training in both 2019 and 2020 and found the implementation acceptable. Entergy Internal Audits conducted an audit of the 2020 training and found the implementation acceptable. The NRC concluded that Indian Point was complying with the requirements of the Confirmatory Order in 2018, 2019, and through September 2020 (References 10 and 11 ). Element B communications were closed in the NRC Confirmatory Order (EA-17-132 and EA-17-153) Follow-up Inspection Report (Reference 7). The annual training component was left open pending NRC inspection of the calendar year 2020 training implementation.

Causal Evaluation of Previous Corrective Actions to Deter Willful Violations, Element C Within 6 months of the issuance date of the Confirmatory Order, Entergy will perform a causal evaluation, informed by site evaluations, to determine why prior fleet-wide corrective actions from Confirmatory Orders and other willful violations issued after January 1, 2009, were not fully successful in preventing or minimizing instances of willful misconduct across the fleet. The causal evaluation will include the following elements:

1. Problem identification;

2. Root cause, extent of condition (including an assessment of work groups that perform NRC regulated activities to determine whether those workers are engaging in willful misconduct),

and extent of cause evaluation;

3. Corrective actions, with time frame for their completion; and

4. Safety culture attributes.

Entergy performed five station-level root cause evaluations and two fleet-level root cause evaluations to accomplish the objectives set forth in the Confirmatory Order. The last approval of these evaluations occurred on August 28, 2018. Entergy assessed this element in 2019 and implemented actions to address identified gaps. Entergy assessed this element in 2020 and found the implementation acceptable. The NRC concluded that Indian Point was complying with the requirements of the Confirmatory Order in 2018, 2019, and through September 2020 (References 10 and 11 ). The NRC reviewed this information in January 2020 and found the cause evaluations acceptable (Reference 7). The NRC left Element C open pending additional NRC inspection of the use of the corrective action program to evaluate willful misconduct and completion of the associated effectiveness review. The 2020 effectiveness review found action implementation effective as discussed in Element D.

Enclosure CNRO-2021-00002 Page 3 of 6 Causal Evaluation of Previous Corrective Actions to Deter Willful Violations, Element D Entergy will identify specific criteria necessary to perform annual effectiveness reviews of the corrective actions. The annual effectiveness reviews will include insights from fleet and individual site performance. Entergy will perform annual effectiveness reviews for three years.

Entergy will modify its corrective actions, as needed, based on the results of the annual effectiveness reviews.

Entergy identified the specific criteria necessary to perform the annual effectiveness reviews of the corrective actions. The first effectiveness review using these criteria to assess 2018 and first quarter 2019 data was conducted in May 2019. The second effectiveness review assessing 2019 data was conducted in December 2019. Both effectiveness reviews found gaps and actions were initiated to correct these gaps. Entergy assessed this element in both 2019 and 2020 and found implementation acceptable. The NRC concluded that Indian Point was complying with the requirements of the Confirmatory Order in 2018, 2019, and through September 2020 (References 10 and 11 ). The NRC reviewed this information in January 2020 and found the effectiveness reviews completed at that time for the specified criteria to be acceptable (Reference 7). The NRC left Element D open pending NRC inspection of the completion of the remaining Confirmatory Order effectiveness review. The third effectiveness review assessing 2020 data was conducted in October 2020. This effectiveness review found the implementation of the actions to be effective.

Causal Evaluation of Previous Corrective Actions to Deter Willful Violations, Element E For the Grand Gulf Nuclear Station, the evaluation described in Element C will address the three violations that are the subject of this ADR mediation session (refer to the NRC's letter dated November 20, 2017).

The three violations that were the subject of the ADR mediation session were addressed in two Grand Gulf Root Cause Evaluations. Entergy assessed this element in 2019 and found implementation acceptable. The NRC reviewed this information in January 2020 and found the cause evaluations acceptable (Reference 7). The NRC closed Element E in the NRC Confirmatory Order (EA-17-132 and EA-17-153) in Reference 7.

Causal Evaluation of Previous Corrective Actions to Deter Willful Violations, Element F Corrective actions identified as a result of the above evaluations will be implemented within 18 months of completion of the evaluation unless they involve a plant modification.

The actions specified by the two fleet and five station root causes were completed within 18 months. The actions taken as a result of the 2019 effectiveness reviews were completed within 18 months of identification. Entergy assessed this element in 2019 and 2020 and found the implementation to be acceptable. The NRC reviewed this information in January 2020 and found the actions to date acceptable (Reference 7). The NRC left Element F open after this inspection pending NRC inspection of any actions specified from future effectiveness reviews.

The 2020 effectiveness review was acceptable, and no additional actions were needed.

Enclosure CNRO-2021-00002 Page 4 of 6 Organizational Health Survey, Elements G, H and I G - Within 12 months of the issuance date of the Confirmatory Order, the Grand Gulf Nuclear Station, as well as all Entergy fleet sites, will conduct an organizational health survey developed by a third-party and designed, in part, to identify safety culture concerns that could contribute to willful misconduct.

H - A second organizational health survey will be conducted within 18 months of completion of the survey in Element G.

I - If safety culture concerns are identified through the survey, Entergy will document and initiate corrective actions within 2 months of the concern identification to mitigate the likelihood of willful misconduct occurring.

Entergy conducted the two organizational health surveys as specified. Entergy assessed Elements G, H and I in 2019 and 2020 and found the implementation to be acceptable. The NRC concluded that Indian Point was complying with the requirements of the Confirmatory Order in 2018, 2019, and through September 2020 (References 10 and 11). The NRC reviewed this information in January 2020 and found the survey data acceptable. The NRC closed Elements G, Hand I in the NRC Confirmatory Order (EA-17-132 and EA-17-153) in Reference 7.

Notifications to the NRC When Actions Are Completed, Element J Within 1 month of completion of Element C, Entergy will submit written notification to the appropriate Regional Administrators.

Entergy provided the specified notification via Reference 2. Entergy assessed this element in 2019 and found it acceptable. The NRC reviewed the 2018 and 2019 notifications in January 2020 and found the 2018 and 2019 notifications acceptable. Refer to the NRC Confirmatory Order (EA-17-132 and EA-17-153) Follow-up Inspection Report (Reference 7).

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 provided the specified notifications for 2018 and 2019 via References 3 and 5. Entergy assessed this element in 2019 and 2020 and found it acceptable. The NRC reviewed the 2018 and 2019 notifications in January 2020 and found the 2018 and 2019 notifications acceptable.

Refer to the NRC Confirmatory Order (EA-17-132 and EA-17-153) Follow-up Inspection Report (Reference 7). This element remains open pending NRC inspection of Entergy's 2020 notification. Entergy provided the 2020 notification via Reference 9.

Enclosure CNRO-2021-00002 Page 5 of 6 Notifications to the NRC when Actions Are Completed, Element L Upon completion, Entergy will submit in writing to the Region IV Regional Administrator its basis for concluding that the terms of the Confirmatory Order have been completed.

This notification provides the Element L basis for concluding the terms of the Confirmatory Order are complete.

References:

1) U.S. Nuclear Regulatory Commission (NRC) letter to Entergy (Entergy Nuclear Operations, Inc. and Entergy Operations, Inc.), "Confirmatory Order, NRC Inspection Report 05000416/2017014, and NRC Investigation Reports 4-2016-004 and 4-2017-021," dated March 12, 2018 (ACCESSION No.:

ML18072A191)

2) Entergy Nuclear Operations, Inc. and Entergy Operations, Inc. letter to the NRC, "Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element J," CNRO-2018-00039, dated September 27, 2018 (ACCESSION No.: ML18270A430)

3) Entergy Nuclear Operations, Inc. and Entergy Operations, Inc. letter to the NRC, "Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K," CNRO-2018-00051, dated December 28, 2018 (ACCESSION No.: ML18362A251)

4) Entergy Nuclear Operations, Inc. and Entergy Operations, Inc. letter to the NRC, "Entergy Response to Confirmatory Order EA-17-132/EA-17-153,"

CNRO-2019-00013, dated March 21, 2019 (ACCESSION No.:

ML19081A270)

5) Entergy Nuclear Operations, Inc. and Entergy Operations, Inc. letter to the NRC, "Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K," CNRO-2019-00030, dated December 30, 2019 (ACCESSION No.: ML19364A214)

6) NRC Confirmatory Order (EA-17-132 and EA-17-153) Follow-up Inspection Report. NRC IR-ANO 05000313/2019014 AND 05000368/2019014, NRC IR- GGN 05000416/2019012, NRC IR- RBS 05000458/2019013, NRC IR-WF3 05000382/2019012, dated April 4, 2019 (ACCESSION No.:

ML 19098867)

7) NRC Confirmatory Order (EA-17-132 and EA-17-153) Follow-up Inspection Report. NRC IR-ANO 05000313/2020010 and 05000368/2020010, NRC IR

- GGN 05000416/2020011, NRC IR- RBS 05000458/2020010, and NRC IR-WF3 05000382/2020011, dated March 20, 2020 (ACCESSION No.:

ML20086J157)

Enclosure CNRO-2021-00002 Page 6 of 6

8) NRC letter to Entergy Operations, Inc., River Bend Station - NRC Inspection Report 05000458/2020012, Investigation Report 4-2019-013 and Notice of Violation, dated September 29, 2020 (ACCESSION No.: ML20273A235)

9) Entergy Nuclear Operations, Inc. and Entergy Operations, Inc. letter to the NRC, "Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K," CNRO-2020-00023, dated December 17, 2020 (ACCESSION No.: ML20352A355)

10) Indian Point Entergy Center, Units 2 and 3 - Integrated Inspection Report, 05000247/2019004 and 05000286/2019004 dated February 10, 2020 (ACCESSION No.: ML20042E476)

11) Indian Point Entergy Center, Unit 3 - Integrated Inspection Report, 05000286/2020003 dated October 28, 2020 (ACCESSION No.:

ML20303A069)