ML16223A462

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Inspection Planning Considerations for ANO CAL Follow-Up Pkg
ML16223A462
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 08/09/2016
From:
NRC/RGN-IV/DRP
To:
Neil O'Keefe
References
Download: ML16223A462 (31)
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INSPECTION PLANNING CONSIDERATIONS FOR REVIEWING ITEMS ASSOCIATED WITH THE CONFIRMATORY ACTION LETTER FOR ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 August 9, 2016 Purpose This document is intended to describe considerations that will be used to schedule, plan, and conduct future NRC inspections to review Entergys progress in improving the safety performance at Arkansas Nuclear One (ANO), Units 1 and 2, including the effectiveness of actions completed from the ANO Comprehensive Recovery Plan (CRP).

Background

On March 4, 2015, in the NRCs annual assessment letter for ANO, (ML15063A499), the NRC notified Entergy that ANO Units 1 and 2 had transitioned to the Multiple/Repetitive Degraded Cornerstone Column (Column 4) of the NRCs Reactor Oversight Process Action Matrix. This change was based on having one Yellow finding in each unit involving the failure to adequately approve the design and to load test a temporary lift assembly, and one Yellow finding in each unit involving the failure to design, construct, and maintain plant design features required to protect safety-related equipment from the effects of flooding.

In early 2016, the NRC completed an independent diagnostic inspection of safety performance at ANO, documented in NRC Inspection Report 05000313/2016007 and 05000368/2016007 (ML16161B279). This inspection included a review of Entergys self-assessments and root cause evaluations for declining performance. Based on Entergys review of the causes of the performance decline, the findings from the independent Third Party Nuclear Safety Culture Assessment, and the results of the NRCs independent diagnostic evaluation, the NRC determined that Entergy had a good understanding of the depth and breadth of performance concerns associated with ANOs performance decline. The NRC also reviewed the ANO CRP and concluded that Entergys planned corrective actions should correct significant performance deficiencies and result in sustained performance improvement at ANO.

On June 17, 2016, the NRC issued a Confirmatory Action Letter (CAL) (ML16169A193) to confirm commitments made by Entergy concerning ANO, Units 1 and 2. In a letter dated May 17, 2016, ANO Comprehensive Recovery Plan, (ML16139A059), Entergy notified the NRC of its plan to perform specific actions to resolve the causes for declining performance at ANO, and provided a summary of that plan.

Inspection Planning and Scheduling Considerations The ANO CRP is comprised of 14 Area Action Plans that contain key improvement actions and scheduled completion dates for each action. NRC Inspection Report 05000313/2016007 and 05000368/2016007 described six performance areas of concern identified by the NRC, and the CAL identified the selected CRP actions that the NRC has concluded are necessary to cause performance improvements in those same six performance areas.

The attachment provides a description and planned due date for each action identified in the CAL. CRP actions that overlap or are redundant are listed together.

The NRC will perform inspections approximately quarterly to evaluate the status of performance improvement at ANO, as well as to independently review the effectiveness of CRP actions.

CRP actions will be scheduled for inspection following notification by Entergy that it has

SUNSI Review ADAMS Non- Publicly Available Keyword:

By: NFO Yes No Sensitive Non-Publicly Available Sensitive OFFICE SPE: PBE C: PBE D: DRP C: PBE NAME JDixon NOKeefe TPruett NOKeefe SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 8/2/16 8/2/16 8/4/16 8/9/16 OFFICE NAME SIGNATURE DATE Sustained Discussed in AAP Key # Description CR Action AAP Due Date Improvement 95003 Report Samples Item (Y/N) Section(s)

Significant Performance Deficiencies (i.e., Yellow Findings)

The following actions address the root and contributing causes for the Yellow findings for the stator drop and the flooding events, including plant deficiencies and problems with vendor oversight, change management, conservative decision making, and risk management, Entergy will implement the following actions by October 2017:

Develop and issue an Entergy change management procedure for C201502836 03/31/2016 planning, execution, and follow up of high risk changes. Procedure will 015 include specific expectations for reviewing effectiveness of the high risk C201502836 04/07/2016 change. Perform snapshot benchmarking to check approach for change 036 5.1 CO05 management against industry practices. C201502836 02/29/2016 Y 5.4.7 OC05 016 C201502836 03/31/2016 028 C201502836 07/31/2016 029 Establish metrics to monitor performance that would indicate that CRANOC2015 leadership focus on minimizing risk and nuclear safety results in 06/17/2016 02833015 improvement to the health of Maintenance Rule systems.

CRANOC2015 12/15/2016 DB01 02833016 Y 5.2.2 C201600614 12/31/16 023 C201502833 05/25/2017 013 Facilitate behavior change by rewarding performance that indicates C201502833 01/12/2017 leadership behaviors are focused on minimizing risk and nuclear safety by 014 DB02 N 5.2.2 incorporating Maintenance Rule Monitoring goals into the Supervisor and C201502833 08/11/2017 above Incentive Plan (SMIP). 036 Provide training to Engineering, Operations, and Planners to increase the CRANOC2014 knowledge and skills regarding passive barriers and other Design Basis 12/11/2015 00259219 Features.

CRANOC2014 01/08/2016 00259213 CRANOC2014 01/15/2016 00259214 CRANOC2014 12/11/2015 00259215 CRANOC2014 02/25/2016 00259220 Page 1 of 29

CRANOC2014 12/11/2015 00259221 DB03 Y 5.2.2 CRANOC2015 02/12/2016 02833049 CRANOC2015 02/19/2016 02833050 CRANOC2015 01/26/2016 02833051 CRANOC2015 01/08/2016 02833052 CRANOC2015 03/23/2016 02833053 CRANOC2015 01/15/2016 02833054 Establish a decision making tool for station personnel that includes 2201502879 07/21/2016 expectations for use at ANO. The intent of this action is to establish a 026 Minimum Risk Option behavior that drives the decision maker to C201502832 08/01/2016 develop multiple solutions and drive the decision that has the least risk by 023 considering the following factors: Nuclear Safety, Industrial Safety, Dose, 4.3.5 DM01 Plant Transients, Equipment Reliability, Generation Loss, and Financial. Y 5.5.2 The Minimum Risk Option concept is a risk management technique 2201500362 designed to minimize the potential risk to as low as reasonably 04/21/2016 019 achievable. The concept involves identifying potential options for performing an activity, and assessing how to effectively manage and mitigate the risk for each of the potential options.

Deliver Risk Recognition training and develop an ANO curriculum for all C201502832 DM06 09/17/17 Y 5.5.2 site personnel with unescorted access. 044 Develop and Implement training on procedures governing risk C201600522 DM07 assessment. The training is for Work Management SROs, Work Week 08/11/16 Y 5.5.2 002 Managers, Shift Managers, and Unit Coordinators.

Develop and implement a Familiarization Guide for the function of Work C201600520 DM08 Management SRO which will ensure clear understanding of job function. 06/30/16 Y 5.5.2 003 Revise On Line Risk Assessment Procedure ENWM104 to include guidance to classify, as high risk work activities involving a credible risk C201402318 4.1.2 DM10 11/26/14 Y concern with unacceptable consequences and firstofakind or firstina 014 5.5.2 while activities.

Revise Project Management Procedures to ensure high consequence risks are properly identified and eliminated/mitigated through a structured C201402318 03/31/2015 risk management process. 016 4.1.2 DM11 Y 413 Page 2 of 29

Y 4.1.3 VO19 5.5.2 C201402318 12/10/2014 040 Develop external flooding design basis documentation so configuration C201400259 01/29/2016 control is defined and maintained. Develop an engineering report and 010 flood protection drawings similar to fire protection drawings to clearly 2201300904 01/29/2016 document the flooding design basis and credited flood protection 114 features (credited external flood protection features and credited C201400259 06/06/2014 operator actions), and assign unique equipment ID to each flood 052 protection feature and boundary. C201400259 FP01 02/10/2016 N 4.2.3 122 C201400259 12/17/2015 131 C201400259 12/18/2015 143 C201400259 02/18/2016 227 Develop internal flooding design basis documentation so configuration C201400259 06/23/2016 control is defined and maintained. Develop an engineering report and 248 flood protection drawings similar to the fire protection drawings to C201400259 01/26/2017 clearly document the flooding design basis and credited flood protection 230 features (credited internal flood protection features and credited C201400259 01/26/2017 operator actions). Update the Flooding Upper Level Document (ULD). 231 Assign unique equipment identification to each flood protection feature C201400259 01/26/2017 and boundary. 232 C201400259 01/26/2017 233 FP02 N 4.2.3 C201400259 01/26/2017 234 C201400259 06/29/2017 235 C201400259 02/23/2017 236 C201400259 01/26/2017 237 C201400259 01/26/2017 238 Label external flood barriers in the plant to provide infield awareness of C201400259 03/11/2016 flood protection features. 011 4.2.3 FP03 N C201301304 4.2.5 07/25/2014 085 Page 3 of 29

Establish an Engineering Barrier program to include external and internal C201400259 12/08/2016 flood protection in accordance with the requirements of procedure EN 246 DC329. Assign program owner and backup Site Engineer. Establish the C201301304 07/25/2013 preventive maintenance of external and internal flood protection 017 features including scope, frequency, testing criteria, and acceptance C201301304 07/25/2013 criteria. 018 C201301304 07/25/2013 019 C201301304 07/25/2013 020 C201301304 07/25/2013 021 C201301304 08/22/2013 030 C201301304 11/14/2013 031 C201301304 08/22/2013 032 C201301304 11/14/2013 033 C201301304 09/19/2013 034 C201301304 12/05/2013 035 C201301304 12/05/2013 037 C201301304 12/05/2013 039 C201301304 12/05/2013 041 C201301304 12/05/2013 043 C201301304 12/05/2013 045 C201301304 12/05/2013 047 C201301304 12/05/2013 049 C201301304 12/05/2013 051 C201301304 12/05/2013 053 C201301304 12/05/2013 055 C201301304 4.2.3 FP04 12/05/2013 Y 057 4.2.5 C201301304 12/05/2013 059 C201301304 12/05/2013 061 Page 4 of 29

C201301304 12/05/2013 063 C201301304 12/05/2013 065 C201301304 12/05/2013 067 C201301304 12/05/2013 069 C201301304 09/19/2013 072 C201301304 12/05/2013 073 C201301304 09/19/2013 074 C201301304 12/05/2013 075 C201301304 11/06/2013 082 C201301304 02/21/2014 083 C201301304 04/11/2014 084 C201400259 07/11/2014 012 C201400259 11/07/2014 025 C201400259 12/17/2015 092 C201400259 01/11/2016 118 C201400259 01/21/2016 121 C201400259 06/23/2016 123 C201400259 12/08/2016 126 C201400259 09/15/2016 155 C201502833 03/23/2017 029 Revise procedure ENDC329, Engineering Programs Control and C201400259 Oversight, to include 12/19/2014 064 4.2.3 FP05 External and Internal Flood Protection in the Engineering Program List for N ANO. 4.2.5 C201400259 08/25/2016 Revise the flooding programmatic aspects of ENDC150, Condition 247 M it i fM i t R l St t R i EN DC 136 Page 5 of 29

Validate that all external flood gaps identified from the review of C201400259 01/15/2016 documentation for credible flood paths and the followup walk downs 014 have been resolved. C201400259 01/29/2016 017 C201400259 06/27/2014 015 C201400259 06/27/2014 016 C201400259 05/16/2014 020 C201400259 08/29/2014 031 C201400259 03/20/2014 032 C201400259 04/17/2014 033 C201400259 11/28/2014 034 C201400259 02/11/2016 037 C201400259 08/29/2014 039 C201400259 4.2.3 FP06 09/19/2014 N 040 5.2.1 C201400259 09/16/2014 059 C201400259 02/26/2015 068 C201400259 03/24/2016 069 C201400259 10/30/2015 077 C201400259 06/26/2015 142 C201400259 01/15/2016 146 C201400259 08/28/2015 202 C201400259 01/15/2016 205 C201400259 12/17/2015 206 C201400259 11/05/2015 208 C201400259 01/28/2016 209 Page 6 of 29

Perform walk downs of all credited internal flood protection features and C201400259 06/23/2016 document the results in an engineering report. 082 C201400259 FP07 06/27/2014 N 4.2.3 018 C201400259 12/31/2017 112 Validate that all internal flood gaps identified from the review of C201400259 12/31/2016 documentation for credible flood paths and the followup walk downs 250 have been resolved. C201400259 10/02/2015 019 C201400259 07/18/2014 058 C201400259 10/17/2014 070 C201400259 10/24/2014 073 4.2.3 FP08 N C201400259 5.2.1 12/17/2015 078 C201400259 12/04/2015 093 C201400259 10/30/2015 127 C201400259 12/17/2015 251 C201400259 01/29/2016 252 Establish the Program Notebook and initial Program Health Report for flood protection in accordance with ENDC143 (Engineering Health Reports) to identify, communicate, prioritize, and drive resolution of C201400259 FP09 11/17/16 N 4.2.3 issues that challenge an effective flood protection strategy including 210 performance indicators, initial color rating (Red or Yellow, and action plan Develop and conduct initial and continuing training essential to C201400259 01/08/2016 understanding and maintaining the license basis for flood barrier 213 features. Address Operations, Engineering, and Work Planning groups. C201400259 01/15/2016 214 C201400259 12/11/2015 215 C201300888 07/10/2013 016 C201300888 10/10/2013 018 C201301304 FP13 06/27/2013 N 4.2.3 027 C201400259 03/27/2015 022 C201400259 09/03/2015 136 C201400259 12/11/2015 216 Page 7 of 29

C201400259 12/11/2015 217 C201400259 12/11/2015 218 Designate a Subject Matter Expert (SME) to oversee implementation of C201402318 12/17/2015 the procedure for Management and Oversight of Supplemental Personnel 094 and contractor oversight for ANO. C201402318 12/17/2015 095 C201402318 01/17/2016 096 C201402318 4.1.2 VO01 02/18/2016 N 165 5.5.5 C201402318 12/17/2015 097 C201402318 02/14/2015 098 C201402318 03/20/2015 099 Establish a Vendor Oversight Team to drive continuous improvement in C201502838 VO04 03/31/16 Y 5.5.5 Vendor Oversight. 015 Develop and implement a process for monitoring of Supplemental C201502838 VO05 04/14/16 Y 5.5.5 Oversight Plan compliance. 013 Establish specific template and guidance to support consistent C201402318 VO06 07/07/16 Y 5.5.5 development of Supplemental Oversight Plans. 168 Develop and implement initial and continuing training on the procedure for Management and Oversight of Supplemental Personnel. Training is C201502838 VO07 09/08/16 Y 5.5.5 for site contract managers and project managers. 014 Develop and implement a contract management Familiarization Guide C201402318 to include determination and documentation of work scope, risk 06/01/2016 170 assessment, incentives and penalties, and performance monitoring.

VO08 Y 5.5.5 Include review of Operating Experience, such as the contractual aspects C201402318 of the stator lift rig failure and other related industry events in the 01/26/2017 171 Familiarization Guide.

Perform an organizational capacity assessment for Vendor Oversight, C201402318 VO09 including Contract Management and Administration, Critical 05/27/16 N 5.5.5 169 Procurements and departmentspecific resource impacts.

Evaluate span of control with regard to Responsible Oversight of Vendors, C201502838 VO10 and place actions to address identified weaknesses in the corrective 09/15/16 N 5.5.5 010 action program.

Revise the Supplemental Personnel Expectations Brief Checklist to include supplemental personnel receiving a Site employee handbook and C201502829 VO11 05/21/16 Y 5.5.5 a discussion by responsible management on the Site employee handbook 028 and expectations for use.

Establish a Fleet Charter Team or ANO Team to address weaknesses in the procedures for contractor oversight. Specifically, identify gaps in the C201402318 VO14 procedures to align with Industry Guide AP930 (Supplemental Personnel 07/17/16 N 5.5.5 175 Process Description). Assign additional actions as warranted to address any gaps identified.

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Review current processes in Engineering related to Vendor Oversight Fundamental Problem. Determine if additional actions are required to C201502838 VO15 address less formal interfaces with suppliers of contract services. Assign 07/15/2016 5.5.5 011 additional actions as warranted to address any gaps identified.

Revise Project Management procedures to ensure projects are organized C201402318 03/31/2015 and managed with (1) effective support by subject matter experts and (2) 015 4.1.2 VO18 Y effective vendor and technical oversight. C201402318 4.1.3 02/23/2016 193 Issued procedure for Management and Oversight of Supplemental 4.1.2 C201402318 VO20 Personnel including improvements to (1) defined responsibilities, (2) 01/05/15 Y 4.1.3 020 assessment of risk, and (3) vendor oversight plans. 4.1.5 Develop and implement recurring training for Project Management 4.1.2 VO21 C201402318 personnel on risk recognition and conservative decision making. 07/30/15 Y 4.1.3 DM09 060 5.5.2 Revise ENDC114, Project Management, to provide guidance in specifying contract language which will ensure detailed engineering VO23 calculations, quality requirements and standards are provided for internal C201300888 11/28/13 N 4.1.3 and third party review, in accordance with revised ENMA119, Material 019 Handling Program, when specially designed temporary lift assembles are to be used Revise ENMA119, to require a documented engineering response to evaluation critical lifts if using any specially designed temporary lifting C201300888 VO24 device, any lifting device that cannot be load tested per ENMA119 09/30/13 N 4.1.3 020 criteria, or any lifting device without a certified load rating name plate rating affixed to it.

Identification, Assessment, and Correction of Performance Deficiencies The following actions address improvement in the implementation and oversight of the corrective action program, self-assessment and performance monitoring, the quality of problem evaluations, and the use of operating experience, Entergy will implement the following actions by October 2017:

Sustained Discussed in AAP Key # Description CR Action AAP Due Date Improvement 95003 Report Samples Item (Y/N) Section(s)

Establish CAP content in the ANO Employee Handbook to include C201501240 5.4.1 CA01 04/06/16 Y behaviors for prompt identification of conditions into CAP. 064 5.4.5 Conduct an organizational capacity study to determine and correct staffing and proficiency needs, including needs to support CAP C201502831 CA03 05/26/16 Y 5.4.1 implementation. Establish a People Health Committee to support ongoing 021 monitoring and adjustments.

Develop and implement initial CAP training and develop continuing CAP C201501240 06/30/2016 training for station employees, ACE/RCE Evaluators, Responsible 074 Managers (including CARB and CRG), Department Performance C201501240 09/29/2016 Improvement Coordinators, OE Specialists and Points of Contact, and 075 Performance Improvement personnel. C201501240 04/28/2016 076 Page 9 of 29

C201501240 06/30/2016 077 C201501240 07/28/2016 078 C201501240 10/27/2016 079 C201501240 09/29/2016 080 C201501240 12/01/2016 081 HQN2014 11/19/2015 5.4.1 00291009 HQN2014 5.4.2 CA04 11/06/2014 Y 00291010 5.4.4 C201402698 5.4.5 01/15/2015 010 C201402698 01/29/2015 015 C201402698 07/23/2015 018 C201402698 07/30/2015 020 C201402698 06/11/2015 021 C201501240 08/06/2015 049 C201501240 06/29/2017 061 C201501240 11/17/2016 062 C201501240 11/17/2016 063 Train investigators, managers and Performance Improvement (PI) Staff on C201501240 5.4.1 12/17/2015 proper causal techniques, manager oversight expectations and 035 CA05 N 5.4.4 engagement, and conducting quality reviews of completed cause C201501284 08/14/2015 5.4.5 evaluations and corrective actions. Establish initial and refresher training 011 Implement training, benchmarking, process improvements, and C201501284 monitoring/feedback to improve the rigor, attention to detail, and overall 05/01/2016 013 quality of Operability Determinations and Functionality Assessments.

C201501284 03/10/2016 014 C201501284 03/31/2016 020 C201501284 5.4.1 CA06 07/28/2016 Y 028 5.4.5 C201500788 12/31/2015 003 Page 10 of 29

C201501284 08/01/2015 012 C201501284 11/15/2015 017 Establish/refine key CAP station and group level performance indicators. C201501240 09/24/2015 5.4.1 036 CA07 N 5.4.2 C201502836 02/06/2016 5.4.5 025 Revise the CARB process to require the Performance Improvement C201501240 5.4.1 CA09 Manager to present the status of the condition reporting process using 09/24/15 Y 034 5.4.4 established metrics to the CARB.

Improve the periodic performance reviews and oversight of CAP and OE C201501240 5.4.1 CA10 performance in Department Performance Review Meetings (DPRMs) and 05/19/16 Y 069 5.4.2 APRMs.

Revise ENLI102, Corrective Action Program, to require a focused self C201501240 5.4.1 CA11 assessment every 2 years focused primarily on whether staffing levels 01/26/16 N 065 5.4.4 support effective CAP implementation and oversight.

Develop metrics to evaluate and monitor the health of the OE program. C201502832 08/01/2016 028 5.4.1 CA12 N C201502832 5.4.8 08/01/2016 027 Establish an OE mentor to review OE responses and provide critical C201502832 5.4.1 CA13 12/30/16 Y feedback. 026 5.4.8 For a period of one year, establish CARB oversight of selected OE C201502834 5.4.1 CA14 09/22/17 N responses to verify program implementation meets CARB standards. 131 5.4.8 Revise the OE actions for selected responses to require a prejob brief from the OE specialist. This brief should include examples of missed C201400259 5.4.1 CA15 05/28/15 N opportunities from past OE responses and a review of the procedure 114 5.4.8 requirements for a satisfactory OE written response.

Train each OE Point of Contact (POC) at ANO on their responsibilities and C201400259 5.4.1 CA16 skills needed to recognize the applicability of OE, elevate OE and use 08/13/15 Y 115 5.4.8 search tools to locate OE for evaluation.

Revise OE Program procedure to include an annual review of the list of C201600782 5.4.1 CA17 vendors providing safetyrelated products/services to ensure new 07/21/16 N 002 5.4.8 suppliers are added.

Revise ENFAPOM002, Management Review Meetings, to prioritize C201502836 03/31/16 review of Nuclear Safety Culture status and Regulatory performance on 020 CO02 N 5.4.7 the Operational Excellence Management Review Meeting (MRM) agenda. C201502836 03/31/16 021 Align ANO and fleet key performance indicators with the industry and C201502836 CO03 establish goals that are challenging and consistent with industry practices. 03/31/16 N 5.4.7 022 Benchmark a nuclear facility outside the Entergy fleet for its ability to C201502832 DM05 recognize risk. Incorporate the learnings and develop a risk recognition 07/31/16 N 5.5.2 043 training plan to be delivered at ANO.

Conduct benchmarking of a high performing station in the area of C201502832 DM12 Operations Focus with a plan based on INPOs Principles for Effective 08/04/16 N 5.5.2 024 Operational DecisionMaking.

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Perform a benchmark on a high performing station outside the Entergy C201601348 DM15 Fleet on ODMI development, implementation, and effectiveness reviews. 08/22/16 N 5.5.2 003 Benchmark outside the Entergy fleet to capture best practices in the C201503034 5.3.3 DM22 Work Management process and develop improvement actions based 06/28/16 Y 026 5.3.7 upon the results.

Have a peer group from another plant perform a peer assist visit in Work C201503034 5.3.3 DM23 07/21/16 N Management. 027 5.3.7 Create Trending and Performance Review performance windows and aspects to improve the review of leadership performance in the areas of:

Leadership Fundamentals: (1) Vision and Values, (2) Teamwork, (3)

Accountability, (4) Employee Engagement, and (5) Resource Allocation. C201502829 5.4.6 LF11 Performance Improvement: (1) Issue identification, evaluation and 05/20/16 Y 022 5.5.1 resolution, (2) Ownership of procedures and work processes, (3) Industry participation, (4) Selfassessments and benchmarking, and (5) Operating experience. Nuclear Safety: (1) Decisionmaking, and (2) SCWE.

Create and issue an ANO specific Recovery procedure to align with ENLI 121, Trending and Performance Review Process, and incorporate a C201502829 simple tool to analyze externally identified performance issues both 05/20/16 023 individually and in aggregate to present actionable data to the APRM. 5.1 OC06 N 5.4.6 LF14 C201502831 5.5.1 06/14/2016 024 C201502831 04/13/2016 038 Conduct a benchmark of the Plant Health Committee and Plant Health Working Group (PHWG) at a recognized industry leader in identifying and C201503029 PH09 addressing equipment reliability issues. The intent of this action is to 06/23/16 N 5.3.1 008 validate the action plan for improving our Plant Health Committee and establishing a Plant Health Working Group.

The INPO Event Report (IER) Review Board will review all formal Operating Experience (OE) evaluations for 12 months and initiate C201502834 PM06 09/22/17 N 5.3.2 corrective action for any that do not meet management standards for 131 quality.

Develop metrics for the number of open craft work order feedback C201502834 PM09 08/25/16 N 5.3.2 requests. 126 Reestablish the PM Program Health Report for a period of at least 12 C201502834 PM10 04/20/17 Y 5.3.2 months. 127 Define and incorporate guidance in the Condition Report screening and C201504626 TR02 review process to prompt discussion and/or action for conditions 03/01/16 Y 5.6 007 potentially warranting a training solution.

Define and incorporate practical guidance in ENLI121, Trending and C201504626 TR03 Performance Review, to support consideration of training as a potential 04/21/16 N 5.6 010 solution for organizational performance issues.

Training Manager provides presentation(s) to Managers and Department C201504626 TR04 Performance Improvement Coordinators (DPICs) on the use of training to 08/18/16 Y 5.6 006 support organizational performance improvement.

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Factor training needs into resources for key departments, including the training department, to ensure that resources support training for C201504626 TR05 organizational performance improvement (this action refers to staffing to 06/23/16 N 5.6 009 support training beyond that necessary for accredited programs).

Benchmark an industry leader outside the Entergy Fleet to capture best C201502838 VO16 08/14/16 N 5.5.5 practices in vendor oversight. 012 Human Performance To improve human performance, leadership behaviors, organizational capacity, procedure quality, standards, and accountability, Entergy will implement the following actions by June 2018:

Sustained Discussed in AAP Key # Description CR Action AAP Due Date Improvement 95003 Report Samples Item (Y/N) Section(s)

Experienced Mentors will be assigned to the Component and Programs areas from 7/1/2016 through 7/1/2017. This Mentoring effort will focus C201600614 DB09 on behaviors, qualification and standards of the ANO Component and 09/15/17 N 5.2.2 006 Programs areas to ensure full compliance and to build the knowledge and proficiency in these areas.

An Engineering Standard will be produced to provide sustainable, consistent guidance to station engineers in the performance of their duties. This standard will incorporate best practices for developing C201502833 DB17 06/30/18 Y 5.2.2 Engineering products beyond simple procedural compliance and ensure 020 that standards and expectations for performance of Engineering duties are clearly articulated to the workforce Rebaseline expectations for supporting information for NRC License Amendment Requests or Relief Requests based on past Requests for C201600203 04/14/2016 Information (RAIs). 006 5.2.2 DB18 N 5.2.4 C201600203 05/13/2016 015 Provide Regulatory Assurance departmental training on development of C201600203 5.2.2 DB19 07/28/16 N NRC License Amendment Requests. 008 5.2.4 Assign a mentor (outside of the Entergy Fleet) to coach and mentor each C201502832 DM13 Shift Manager, emphasizing the aspect of leadership in Operational 12/30/16 Y 5.5.2 025 Focus.

Assign a mentor to review and improve Operations Decision Making C201601348 DM14 05/28/16 Y 5.5.2 Instructions (ODMI) until such time as proficiency is demonstrated. 002 Develop and Implement training for key personnel on ODMI C201601348 DM16 02/17/17 Y 5.5.2 development, implementation, and effectiveness reviews. 004 Develop Roles & Responsibilities for the quorum line participants in the C201503034 02/04/2016 work management process. 012 C201400259 03/24/2016 241 Page 13 of 29

C201502834 5.3.3 DM17 09/26/2017 118 5.3.7 C201502834 01/26/2017 121 C201503034 11/12/2015 005 Conduct leadership assessments for the senior lead team, managers and C201502829 LF01 superintendents and establish individual development plans to support 03/31/16 N 5.5.1 043 closing identified gaps in leader behaviors.

Establish and roll out an ANO employee handbook with attributes and C201502829 04/07/2016 behaviors supporting nuclear safety and long term strategic 025 improvement. The purpose of the handbook is to communicate and C201502829 5.5.1 LF02 06/16/2016 Y reinforce key values and behaviors. 026 5.5.1.3 C201402318 01/21/2016 172 Provide supervisory training on constructive conversation skills. C201502829 5.5.1 LF03 09/29/16 N 030 5.5.1.3 As an interim action, establish weekly leadership alignment meetings for C201502829 01/22/2016 supervisors and above to reinforce actions and behaviors needed to 033 LF04 N 5.5.1 achieve recovery objectives. C201502829 03/17/2016 038 Benchmark an external organization for Leadership Fundamentals and 201502829 08/18/2016 develop improvement actions as warranted based upon the results. 053 LF06 N 5.5.1 C201502829 04/29/2016 057 As an interim measure, establish and implement external coaching for a C201502829 sample of department and station performance review meetings in the 04/15/2016 024 Trending and Performance Review process.

LF08 N 5.5.1 C201502829 07/22/2016 040 Establish and implement an interim paired observations program for C201502829 01/22/2016 leaders to coach leaders on leadership behaviors. 034 5.5.1 LF10 N C201502829 5.5.1.3 03/16/2016 049 Implement a What It Looks Like (WILL) sheet for Nuclear Professional behaviors based on objectives in INPO 12013, Performance Objectives and Criteria. Include a continued focus on the four Primary Performance Issues identified in the Nuclear Fundamentals Area Action Plan.

Procedure Use and Adherence C201503031 NF01 Challenging Assumptions and Decision Making 04/07/16 N 5.5.3 011 Conservative Bias and Risk Recognition Low Threshold for Reporting Issues WILL sheets provide listings of the characteristics expected to be found during observation of plant activities.

Develop content for the ANO Employee Handbook that addresses C201504647 NF03 05/12/16 Y 5.5.3 Procedure Use and Adherence. 013 Page 14 of 29

Develop content for the ANO supervisor training that addresses C201504647 NF05 07/28/16 N 5.5.3 Procedure Use and Adherence. 015 Revise ENOM126, Management and Oversight of Supplemental Personnel, to ensure that supplemental employees receive the ANO C201502829 NF06 05/21/16 N 5.5.3 Employee Handbook and are provided a expectations for its use in a 028 discussion by their manager.

Develop and implement a field presence initiative that promotes and 5.5.1.2 NF09 measures leader field presence. Objective is to drive and verify field C201600748 05/27/16 Y 5.5.3 SC08 presence by leaders to engage with employees and reinforce high 012 6.2 standards.

Establish and implement a paired observation program. This is a coach C201502829 01/22/2016 the coach program to improve the quality of interactions between 034 5.5.1.2 NF10 N supervisors and those they supervise. C201502829 5.5.3 03/16/2016 049 Perform Organizational Capacity Assessments to determine staffing C201502831 05/26/2016 requirements for key departments based on experience, training needs, 021 knowledge management needs, timing of expected retirements, C201500991 10/16/2015 resignations and reassignments, and the needs for a site with two 007 OC01 N 5.1 dissimilar units. C201502831 11/27/2015 017 C201502831 12/29/2016 020 Authorize the hiring of Entergy personnel and/or contractor positions C201502831 08/25/2016 identified as immediate staffing requirements by the ANO 041 Comprehensive Recovery Plan APHC during Organizational Capacity C201502831 OC02 01/07/2016 Y 5.1 Assessment reviews. 018 C201502831 04/15/2016 019 Establish and implement an ANO Integrated Strategic Workforce Plan (ISWP) that provides a strategic longterm perspective of future staffing needs with an explicit focus on ensuring staffing is sufficient to support C201502831 OC03 05/19/16 Y 5.1 nuclear safety. The workforce planning process will look into the future at 023 least fiveyears, be updated annually, and reviewed quarterly by the APHC Establish and implement an APHC to place priority on staffing and C201502831 OC04 retention issues that are impacting ANO employees or could impact 06/29/16 Y 5.1 022 nuclear safety.

Perform a resource allocation study of the PM program that identifies C201502834 PM13 positions needed to maintain a continuously improving (living) PM 06/30/16 N 5.3.2 117 Program.

Address gaps in the PM program baseline staffing level based on the C201502834 PM14 07/29/16 N 5.3.2 current levels of experience in the departments and at the site. 116 Revise the PM procedure to require that craft work order feedback is C201502834 03/31/2017 monitored and incorporated within 90 days or Model Work Order (MWO) 129 PM19 N 5.3.2 placed in PLAN status. C201502834 09/29/2017 130 Develop and implement a Site Procedure Writer Guide based on C201503033 12/16/2015 applicable Industry standards. 010 C201503033 06/01/2016 032 Page 15 of 29

C201503033 12/16/2015 011 C201503033 12/16/2015 015 C201503033 12/16/2015 016 C201503033 5.3.7 PQ01 12/16/2015 N 017 5.5.4 C201503033 12/16/2015 018 C201503033 06/15/2016 020 C201503033 06/15/2016 021 C201503033 06/15/2016 022 C201503033 02/26/2016 028 Develop and implement a Work Order Instructions Guide based on C201503033 12/16/2015 applicable industry standards. 014 5.3.7 PQ02 N C201503033 5.5.4 06/01/2016 033 Perform scoping reviews to assess extent of procedure and work C201503033 12/16/2015 instruction quality issues. 003 C201503033 12/16/2015 004 C201503033 12/16/2015 005 C201503033 12/16/2015 006 5.3.7 PQ03 N C201503033 5.5.4 12/16/2015 007 C201503033 12/16/2015 008 C201503033 12/16/2015 009 C201503033 12/16/2015 012 Conduct a Procedure Professionals Association (PPA) Certification Course C201503033 5.3.7 PQ04 06/01/16 N for selected plant personnel. 031 5.5.4 Risk rank station procedures as safety significant, important, or normal to C201503033 5.3.7 PQ05 12/16/15 N facilitate procedure upgrade project scoping. 013 5.5.4 Upgrade procedures classified as Safety Significant. C201503033 12/30/2016 023 C201502517 5.3.7 PQ06 09/30/2015 N 004 5.5.4 C201503033 02/15/2016 019 Page 16 of 29

Upgrade procedures classified as Important. C201503033 Review of this action will utilize a sampling 06/30/2017 024 5.3.7 strategy due to the large number of procedures PQ07 N C201503033 5.5.4 06/30/2017 025 Upgrade procedures classified as Normal. Per Note 1 of the CAL, review a sample of procedures classified as "normal" risk that have C201503033 5.3.7 PQ08 06/30/18 N been upgraded by June 2018. This sample should 026 5.5.4 focus on the types of procedures listed in RG 1.33.

Upgrade Critical 14 Model Work Orders with a frequency of greater than Per Note 1 of the CAL, review a sample of critical or equal to 2 years or 2 refueling outages. Include associated procedures. 14 "model" work orders that have been C201503033 5.3.7 upgraded by June 2018. This sample should PQ09 06/30/18 N 027 5.5.4 focus on work instructions that has the potential to affect safetyrelated equipment, as described in RG 1.33, section 9.A..

Review and/or validate station procedures with respect to gaps in use of 2201403507 notes and cautions, and ensure needed corrections are entered into the 04/29/2016 005 appropriate station processes for completion.

2201403507 04/29/2016 008 C201500850 11/27/2015 021 C201500850 04/29/2016 024 5.3.7 PQ10 N 5.5.4 C201501566 06/30/2016 007 C201501566 06/30/2016 008 C201501566 06/30/2016 009 C201501566 06/30/2016 010 Establish periodic review and validation of station procedures. This will also support a systematic approach to revising station procedures not C201500850 5.3.7 PQ11 03/03/16 N included in other actions to the standards contained in the new writers 055 5.5.4 guide.

Equipment Reliability and Engineering Programs To improve implementation of processes and programs that ensure key plant equipment remains available, reliable, and capable of meeting the plant design and licensing bases, including resolving specific equipment conditions, Entergy will implement the following actions by June 2018:

Page 17 of 29

Sustained Discussed in AAP Key # Description CR Action AAP Due Date Improvement 95003 Report Samples Item (Y/N) Section(s)

Resolve Standards Performance Deficiencies (SPD) from the Engineering C201502834 Per Note 2 of the CAL, review the following 12/15/2017 Program assessments completed during the Preventive Maintenance 157 sample of actions to resolve problems/findings Program Extent of Condition review. C201502834 from selfassessments of the following programs:

02/05/2018 160

  • Airoperated Valve Program C201502834
  • Heat Exchanger Program 02/05/2018 161
  • Large Motor Program DB10 N 5.2.2 C201502834
  • Obsolescence/Longterm Assessed C201502834 Management Program 07/02/2018 165
  • Microbiologically Influenced Corrosion (MIC)

C201502834 02/05/2018 Program 168 One Benchmark or one SelfAssessment will be conducted in the C201600614 Per Note 3 of the CAL, review actions to perform following Program and Component areas: (see samples) 06/30/2018 benchmarking/selfassessments for the following 008 engineering programs:

C201502833

  • Repair and Replacement Program DB11 07/16/2017 N 5.2.2 028
  • MIC Program C201600614
  • Large Motor Program 09/28/2017
  • Probabilistic Risk Assessment Program 022 Training and industry exposure will also be used to build the knowledge, proficiency and standards within the Program and Component areas as C201600614 DB12 the owners of each program listed in DB11 will participate in at least one 10/16/17 N 5.2.2 007 industry meeting or specialized training course focused in their Program area.

Develop and Implement Work Management Training for Senior C201503034 03/03/2016 Management, Managers, and each of identified Work Management 013 positions with respect to roles and responsibilities. C201503034 03/03/2016 014 5.3.3 DM18 N C201503034 5.3.7 10/30/2016 016 C201503034 10/30/2016 018 Develop and Implement Supply vs Demand model and metrics to C201503034 04/28/2016 determine and monitor resource needs to meet work load demand. The 022 5.3.3 DM20 N metrics will be used to measure resource demand and supply so that C201503034 5.3.7 02/17/2016 scheduled work has the correct resources assigned to complete the work 028 For open SIPD items, ensure Management Sponsors and Project C201502831 12/27/2016 Managers are assigned to verify database content is updated. This action 026 supports effective decision making by ensuring the accuracy and C201400089 12/29/2016 completeness of existing SIPD records 034 PH01 N 5.3.1 C201400089 12/29/2016 035 C201502831 12/27/2016 027 Page 18 of 29

Perform a review of the SIPD database from 2007 to present to identify Preventive Maintenance or Equipment Reliability Projects related to C201502834 PH02 12/28/16 N 5.3.1 Critical Equipment that have been cancelled without mitigation 138 strategies.

Review and update the current Aging/Obsolescence list, Critical Spares CRANOC2014 list, and Equipment Reliability Issues to identify equipment items that 06/29/2017 00089036 should be addressed during the 2017 and 2018 business cycles.

CRANOC2014 06/29/2017 00089037 CRANOC2015 06/27/2017 02831028 CRANOC2015 06/27/2017 02831029 CRANOC2015 06/27/2017 02831030 5.3.1 PH03 N 5.3.9.1 CRANOC2015 06/29/2017 02833042 CRANOC2015 06/29/2017 02833043 CRANOC2014 07/28/2016 00089038 CRANOC2015 06/23/2016 02832037 CRANOC2015 06/13/2016 02832039 Review and update the current site Unit Commitment List to identify C201502831 06/27/2017 Operations and Maintenance (O&M) and Capital Projects which are 031 required to be resolved by completion of refueling outages 1R27 and C201502833 06/29/2017 2R26. 044 C201503029 02/23/2017 006 PH04 N 5.3.1 C201503029 09/10/2015 002 C201503029 09/18/2015 003 C201503029 06/29/2016 004 Develop and Implement a Comprehensive Site Plan for Equipment C201502831 07/26/2017 Reliability that identifies the implementing resources (people, materials, 032 funding, and time) needed to support online and outage Unit C201502833 07/26/2017 Commitment List items that require resolution by completion of 1R27 045 Page 19 of 29

q y p and 2R26. C201402601 PH05 12/18/2014 N 5.3.1 007 C201402601 12/18/2014 008 C201402601 12/18/2014 009 Obtain an independent third party review of the selection of SIPD items C201502831 09/28/2017 that are targeted on the Comprehensive Site Plan for Equipment 034 PH06 N 5.3.1 Reliability to ensure the decisions for inclusion and exclusion are aligned C201502833 09/30/2017 with industry standards and expectations associated with timely 046 Develop educational materials for the Plant Heath process including SIPD processing. Include a detailed flowchart, workbook, and detailed presentation materials. Deliver / present the presentation to systems, C201503029 PH10 08/25/16 N 5.3.1 components, and program engineers and to selected supervisory 011 personnel. Have the workbook completed by personnel following the presentation Develop a Job Familiarization Guide for PHWG and Plant Health C201503029 PH11 Committee members and alternates. Have all members and alternates 06/02/16 N 5.3.1 012 complete the guide.

  • Unit 1 NI501 Detector replacement (WO 2201502879 411197, 00406600) Fall 2016 06/30/2016
  • Unit 2 Instrument Air Compressor replacement 2201302242 (WO402561, 00402559) complete 11/13/2014
  • Fire Suppression System Reliability 050 improvement (CRANOC2015761 CA21) 1Q17 The following list contains equipment reliability issues in systems or
  • Unit 2 CCW Heat Exchanger (2E28B) components necessary for the safe and reliable operation of the unit(s) 4.3.2 C201400259 replacement (SIPD4203) spring 2017 PH12 that will be resolved over the next two unit operating cycles. The intent of 12/17/2015 N 5.2.1 130
  • Service Water and Circulating Water Chemical this action is to demonstrate improved equipment reliability by resolving 5.3.1 Treatment System upgrade (SIPD7970) 4Q17 longstanding equipment issues.
  • Perform Startup transformer #2 inspections (CR C201502832 ANOC20153029 CA38) 4Q17 12/01/2016 033
  • Perform Startup Transformer #3 inspections (CRANOC20153029 CA35) spring 2017
  • Complete design of Unit 1 ICS system reverse C201502832 engineered modules (CRANOC20153029 CA 03/31/2016 034 41) 1Q18
  • Implement planned SPV mitigation and elimination efforts (CRANOC2016187) spring C201502832 03/31/2016 2018 035 Page 20 of 29

The following list contains equipment reliability issues that are being C201503029 12/20/2018 evaluated by the Plant Health Committee for resolution commensurate 034 PH13 N 5.3.1

  • Samples TBD with their potential impact on safe and reliable operation of the unit(s) by C201502832 03/20/2016 December 20, 2018. For any items not resolved by that date, the Plant 038 Track and audit the completion of the following equipment reliability 2201302242 06/19/2014 issues related to the White Finding and the potential for additional 022 unplanned plant trips. 2201400707 07/28/2016 014 4.3.3 PH14 N C201503029 5.3.1 07/21/2017 035 2201400707 05/15/2017 032 Create a site specific procedure for component classification that will C201502834 PM01 ensure appropriate classification of equipment for PM based upon risk 06/20/16 N 5.3.2 111 and safety.

Create a site specific preventive maintenance program procedure that C201502834 PM02 includes lessons learned from the PM Fundamental Problem root cause 06/20/16 N 5.3.2 102 related to critical input to PM changes.

Transfer responsibility for PM evaluations of all Maintenance Rule components and critical system redundancy components to Engineering C201502834 PM04 06/23/16 N 5.3.2 to ensure that appropriate expertise is brought to bear on these 122 evaluations.

The PM Oversight Group will review all PM change requests for a C201502834 05/02/2017 minimum of 12 months and initiate corrective action for any that do not 103 PM05 N 5.3.2 meet management standards for quality. C201502834 01/31/2017 104 The Planning Quality Review Team (PQRT) will perform an enhanced C201502834 03/31/2017 review of critical Work Orders for a minimum of 12 months and feedback 119 PM07 N 5.3.2 the results to the Planning staff. C201502834 04/20/2017 120 Implement a new qualification card for Maintenance personnel who C201502834 06/30/2016 perform PM Evaluations. 124 PM11 N 5.3.2 C201502834 10/20/2016 125 Implement training for all personnel who are qualified to establish PM C201502834 PM12 03/31/17 N 5.3.2 requirements. 110 Review a sample of component criticality classifications to validate that C201502834 PM15 03/29/18 N 5.3.2 risk significant equipment is classified correctly. 137 Develop mitigation strategies to address cancelled projects in the Site C201502834 07/07/2017 Integrated Planning Database (SIPD) including embedded subcomponent 128 PM18 N 5.3.2 projects. C201502834 12/28/2016 138 Page 21 of 29

Safety Culture To improve nuclear safety culture values and behaviors to ensure commitment by leaders and individuals to emphasize safety over competing goals, Entergy will implement the following by December 2016:

Sustained Discussed in AAP Key # Description CR Action AAP Due Date Improvement 95003 Report Samples Item (Y/N) Section(s)

Revise ENFAPOM011, Corporate Oversight Model, to include station C201502836 03/31/2016 Nuclear Safety Culture output from the nuclear safety culture monitoring 018 panel as inputs to the Oversight Analysis Meeting (OAM) and Oversight C201502836 03/31/2016 Review Board (ORB). 019 HQN2014 12/17/2015 00291011 HQN2014 CO01 03/26/2015 N 5.4.7 00291012 HQN2014 06/25/2015 00291013 HQN2014 07/17/2014 00291014 HQN2015 10/08/2015 00530003 Revise procedures that govern Nuclear Oversight Performance Assessments to include nuclear safety culture trend codes. Apply relevant CO04 safety culture trend code(s) during the trending process. Based on report C201502836 03/31/16 N 5.4.7 frequency, roll up codes to provide a perspective on nuclear safety 023 culture and include in established reporting processes.

Establish a decision making Nuclear Safety Culture Observation form to include the top Leader Behaviors to be demonstrated and reinforced at C201502832 DM02 ANO meetings. The form should include decision making practices that 03/24/16 N 5.5.2 041 emphasize prudent choices over those that are simply allowable.

Establish Decision Making and Risk Management content in the ANO Employee Handbook to include behaviors for making effective decisions C201502832 DM03 and appropriately managing risk with the expectation for both employees 05/04/16 N 5.5.2 018 and leaders to use the book in communicating, demonstrating and reinforcing appropriate behaviors.

Provide supervisory training on NSC and SCWE. C201502829 LF05 06/30/16 Y 5.5.1 029 Develop content for the NSC observation process that addresses C201504647 NF04 06/24/16 N 5.5.3 Procedure Use and Adherence. 014 Improve the performance review process for leadership fundamentals C201502834 PM20 06/21/16 5.3.2 supportive of long term strategic improvement. 105 Revise the procedure Nuclear Safety Culture Monitoring to define the C201600748 06/10/2016 role and responsibilities of the ANO NSC Manager. 008 SC02 N 6.2 C201502829 02/26/2016 032 Page 22 of 29

Revise the procedure Nuclear Safety Culture Monitoring to add Nuclear Safety Culture Monitor Orientation training for Nuclear Safety Culture C201600748 SC03 06/10/16 N 6.2 Monitoring Panel (NSCMP) and Safety Culture Leadership Team (SCLT) 013 members.

Conduct a structured offsite meeting among the ANO Senior Leadership Team to align on what a Strategic Commitment to Safety looks like at C201600748 SC04 05/19/16 N 6.2 ANO and the leader behaviors that will demonstrate that commitment. 007 Create an ANO Employee Handbook that includes NSC, Safety Conscious C201501240 04/06/2016 Work Environment (SCWE) and CAP standards and expectations, and 064 provide orientation and expectations to ANO personnel on the contents C201502829 SC05 04/07/2016 Y 6.2 and use of this handbook as a daily tool for communicating, reinforcing, 025 and demonstrating NSC and CAP expectations. C201502829 05/21/2016 027 Conduct meetings facilitated by members of the site management to C201502829 SC06 rollout the ANO Employee Handbook to ANO personnel and expectations 06/16/16 N 6.2 026 for its use.

Establish a small group meeting schedule to facilitate facetoface C201600748 05/26/2016 interaction between ANO senior leadership and station employees. This 019 activity should span a minimum period through the end of 2016 and C201501445 04/28/2016 include the following attributes: (1) purpose is open dialogue on safety 099 performance with emphasis on employee questions and feedback, and (2) C201501445 05/05/2016 schedule should be coordinated to facilitate broad exposure, with 100 emphasis on workers on shift rotation who cant routinely participate in C201501445 06/09/2016 other communication forums. 102 C201501445 02/11/2016 103 C201501445 06/16/2016 105 C201501445 02/11/2016 106 SC07 N 6.2 C201501445 06/09/2016 107 C201501445 02/18/2016 108 C201501445 03/17/2016 109 C201501445 07/07/2016 110 C201501445 02/11/2016 111 C201501445 06/09/2016 112 C201501445 05/05/2016 116 Page 23 of 29

Develop and provide training to ANO leaders, including supervisory C201502829 06/30/2016 training on NSC and SCWE, constructive conversation skills. 029 SC09 C201502829 09/29/2016 Y 6.2 NF07 030 C201501445 05/31/2016 120 Develop and present training to ANO workforce to include case studies that illustrate the right picture of Nuclear Safety Culture. Include what C201502829 it means to be an engaged and thinking individual nuclear worker as per 04/15/2016 024 SC10 recommendation 3.a. of Significant Operating Event Report (SOER) 102, Engaged, Thinking Organizations. Y 6.2 NF08 C201600748 12/30/2016 010 C201501709 06/01/2016 009 Page 24 of 29

Implement priority group specific action plans to address safety culture C201501445 12/23/2015 issues. 044 C201501445 12/23/2015 047 C201501445 12/23/2015 050 C201501445 12/23/2015 053 C201501445 01/14/2016 056 C201501445 01/14/2016 059 C201501445 12/23/2015 062 C201501445 01/14/2016 065 C201501445 12/23/2015 068 C201501445 01/26/2017 132 C201501445 01/26/2017 133 C201501445 01/26/2017 134 C201501445 01/26/2017 135 C201501445 01/26/2017 136 C201501445 01/26/2017 137 C201501445 01/26/2017 138 C201501445 01/26/2017 139 C201501445 01/26/2017 140 C201501445 08/21/2015 008 C201501445 08/21/2015 009 C201501445 08/14/2015 010 C201501445 11/12/2015 018 C201501445 07/28/2016 019 C201501445 02/05/2016 020 C201501445 07/28/2016 021 Page 25 of 29

C201501445 12/11/2015 023 C201501445 12/10/2015 024 C201501445 12/23/2015 025 C201501445 12/23/2015 026 C201501445 12/11/2015 027 C201501445 12/11/2015 028 C201501445 12/11/2015 029 C201501445 12/11/2015 030 C201501445 12/11/2015 031 C201501445 12/10/2015 032 C201501445 12/10/2015 033 C201501445 12/10/2015 034 C201501445 12/11/2015 036 C201501445 12/11/2015 037 C201501445 12/11/2015 038 C201501445 01/14/2016 039 C201501445 12/18/2015 040 C201501445 SC11 01/15/2016 Y 6.2 041 C201501445 01/14/2016 045 C201501445 07/29/2016 046 C201501445 01/14/2016 048 C201501445 07/29/2016 049 C201501445 01/14/2016 051 C201501445 07/29/2016 052 C201501445 01/14/2016 054 Page 26 of 29

C201501445 07/29/2016 055 C201501445 01/14/2016 057 C201501445 07/29/2016 058 C201501445 01/14/2016 060 C201501445 07/29/2016 061 C201501445 02/04/2016 063 C201501445 07/29/2016 064 C201501445 01/14/2016 066 C201501445 07/29/2016 067 C201501445 01/15/2016 069 C201501445 07/29/2016 070 C201501445 01/21/2016 071 C201501445 01/07/2016 072 C201501445 01/07/2016 073 C201501445 01/14/2016 074 C201501445 01/14/2016 075 C201501445 04/15/2016 076 C201501445 08/04/2016 077 C201501445 04/07/2016 078 C201501445 04/29/2016 079 C201501445 05/19/2016 080 C201501445 03/30/2016 082 C201501445 01/29/2016 083 C201501445 12/30/2016 084 C201501445 12/21/2016 085 Page 27 of 29

C201501445 06/23/2016 086 C201501445 02/04/2016 088 C201501445 02/25/2016 089 C201501445 03/10/2016 090 C201501445 06/16/2016 093 C201501445 01/13/2016 094 C201501445 06/16/2016 101 C201501445 12/30/2016 104 C201501445 12/30/2016 113 C201501445 06/16/2016 114 Establish and implement a Nuclear Safety Culture Observation process 5.4.1 SC14 including elements of Leaders Behaviors, NSC, and SCWE. The observer C201502829 5.4.4 LF09 05/26/16 Y monitors leader performance on a daily basis and provides feedback to 031 5.5.1 CA02 correct adverse trends in behaviors. 6.2 Raise the priority and visibility of NSC at the fleet level by revising the C201502836 03/31/2016 Corporate Oversight Model to include station NSC output from the 018 SC15 Y 6.2 nuclear safety culture monitoring panel as input to fleet Oversight C201502836 03/31/2016 Analysis Meetings and Oversight Review Boards. 020 Service Water System Self-Assessment To ensure conditions adverse to quality are identified and resolved, ANO will conduct a focused self-assessment of the Units 1 and 2 service water systems in accordance with station procedures and NRC Inspection Procedure 93810, Service Water System Operational Performance Inspection, by December 2016.

Page 28 of 29

Average per Quarter 6.17 6.17 Quarter SPDs due 6.17 Significant Performance Deficiencies by Quarter 3Q16 and prior 28 6.17 4Q16 3 6.17 30 1Q17 1 6.17 2Q17 2 25 3Q17 2 4Q17 1 20 15 SPDs due 10 Average per Quarter 5

0 3Q16 and 4Q16 1Q17 2Q17 3Q17 4Q17 prior Quarter # of CAs due

  1. of CAs due 1Q16 14 2Q16 42 45 3Q16 21 4Q16 12 40 1Q17 2 35 2Q17 7 3Q17 9 30 4Q17 1 25 1Q18 1 2Q18 5 20 3Q18 0 4Q18 2 15 10 5

0 1Q16 2Q16 3Q16 4Q16 1Q17 2Q17 3Q17 4Q17 1Q18 2Q18 3Q18 4Q18 Page 29 of 29

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