CNRO-2020-00023, Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2020 Summary

Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2020 Summary

ML20352A355
Person / Time
Site:	Palisades, Indian Point, Grand Gulf, Arkansas Nuclear, River Bend, Waterford   (DPR-020, DPR-026, DPR-051, DPR-064, NPF-006, NPF-029, NPF-038, NPF-047)
Issue date:	12/17/2020
From:	Gaston R Entergy Nuclear Operations, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2020-00023
Download: ML20352A355 (8)

Text

Entergy Operations, Inc.

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Ron Gaston Director, Nuclear Licensing CNRO-2020-00023 10 CFR 2.202 December 17, 2020 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 2020 Summary Arkansas Nuclear One, Units 1 & 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 Indian Point Energy Center, Units 2 & 3 Docket Nos. 50- 247 & 50-286 License Nos. DPR-26 & DPR-64 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 Palisades Nuclear Plant Docket 50-255 License No. DPR-20 River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47 Waterford 3 Steam Electric Station Docket No. 50-382 License No. NPF-38 Confirmatory Order EA-17-132/EA-17-153 (Reference 1) modified the above operating licenses to include specific elements to address willful violations. As required by Section V, Element K, the enclosed attachment provides, in writing to the appropriate Regional Administrators, a summary of the actions implemented across the Entergy fleet as a result of this Confirmatory Order and the results of any effectiveness reviews performed for the calendar year 2020.

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 December 17, 2020.

Respectfully, Ron Gaston RWG/jjn/jas

Attachment:

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

CNRO-2020-00023 Page 2 of 3

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-2019-00030, dated December 30, 2019 (ACCESSION No.: ML19364A214)

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)

NRC Confirmatory Order (EA-17-132 and EA-17-153) Follow-up Inspection Report. NRC IR - ANO 05000313/2020010 and 05000368/2020010, ML20086J157, NRC IR - GGN 05000416/2020011, NRC IR - RBS 05000458/2020010, and NRC IR - WF3 05000382/2020011, dated March 20, 2020 (ACCESSION No. ML20086J157)

6)

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)

CNRO-2020-00023 Page 3 of 3 cc: John Dinelli (ANO)

Riley Keele (ANO)

Robert Franssen (GGN)

Jim Shaw (GGN)

Darrell Corbin (PLP)

Jeff Hardy (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 III 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 CNRO-2020-00023 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K

Attachment CNRO-2020-00023 Page 1 of 4 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K 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.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 License Nos. DRP-51, NPF-6, NPF-29, DPR-26, DPR-64, DPR-20, NPF-47 and NPF-38 for calendar year 2020.1 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 in calendar year 2020 as a result of this Confirmatory Order.2 Communications with Site Workers, Element B To address the Element B requirement for 2020 annual training, Entergy implemented a computer-based training (CBT) module. As of December 2020, more than 99% of the target population completed and acknowledged the CBT.

Causal Evaluation of Previous Corrective Actions to Deter Willful Violations, Elements C and D Element C - The two fleet causal analyses were revised in December 2019 based on observations from an NRC Inspection performed in January 2019 and the results of Effectiveness Reviews. This was previously communicated to the NRC via letter from Entergy Nuclear Operations, Inc. and Entergy Operations, Inc., Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K, December 30, 2019 (Reference 3). The revised Corrective Actions to Preclude Recurrence (CAPR)s were implemented in January 2020.

Element D - Entergy conducted two Effectiveness Reviews for the Confirmatory Order.

1) A follow up effectiveness review evaluating the use of the Corrective Action Program to address integrity issues was conducted in June 2020.

a. Corrective Action Program (CAP) use to address integrity issues was deemed effective, based on screening, evaluation quality and action implementation.

1 This attachment 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 and Reference 4.

Attachment CNRO-2020-00023 Page 2 of 4

2) The annual Confirmatory Order Effectiveness Review conducted in October of 2020 found:

a. Training was effective, based on acknowledgment by greater than 96% of the target audience and follow up survey data;

b. Trust but Verify Audits were effective, based on consistent implementation of the audit steps, treatment of anomalies, documentation and consistent communication of the audit results to plant personnel; and

c. Corrective Action Program (CAP) use to address integrity issues was effective, based on screening, evaluation quality and action implementation.

There were four Effectiveness Reviews conducted for the root causes associated with the Confirmatory Order.

1) An Effectiveness Review completed in January 2020, for the fleet root cause addressing why, from 2015-2017, there have been multiple instances in which site personnel violated integrity standards found integrity training implementation effective based on.

a. High rate of training completion; and

b. Interview and survey data demonstrating personnel received and understood the training.

2) An Effectiveness Review completed in August 2020, for the fleet root cause addressing why, from 2015-2017, there have been multiple instances in which site personnel violated integrity standards found Operations audits were effective based on:

a. Operations integrity audit requirements to conduct audits and communicate to the operators were consistently implemented; and

b. Anomalies were adequately explained or evaluated.

3) An Effectiveness Review completed in August 2020, for the fleet root cause addressing why, from 2015-2017, there have been multiple instances in which site personnel violated integrity standards found Training audits effective based on:

a. Training integrity audit requirements to conduct audits and communicate to proctors were implemented; and

b. Potential Integrity issues were not identified in the audits.

4) An Effectiveness Review for the fleet root cause on why fleet-wide corrective actions from NRC Confirmatory Orders since 2009 have not been effective in preventing or minimizing instances of integrity issues across the fleet, completed in November 2020, found the CAPRs effective based on consistent use of CAP to address integrity issues.

Organizational Health Survey, Elements H and I The analysis for the 2019 Organizational Health Index (OHI) Survey was completed in January 2020 and follow up actions for specific sites were completed in February and March 2020. No safety culture concerns that could contribute to willful misconduct were identified.

Attachment CNRO-2020-00023 Page 3 of 4 Notifications to the NRC When Actions Are Completed, Element K 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.

Other Actions The following actions were taken to address observations provided in NRC Confirmatory Order (EA-17-132 and EA-17-153) Follow-up Inspection Report (Reference 5).

1) Assessed the OHI process used to provide insights for the Elements H and I and determined no changes were needed.

2) Added guidance for NRC notification of integrity issues to the Entergy communications with the NRC process.

3) New audit guidance for checking integrity of qualification card conduct was created and implemented.

4) Conducted the Effectiveness Reviews discussed under Element D to confirm effectiveness of the causal analysis actions.

5) Perform a second Operating Experience Self-Assessment.

6) The effectiveness of contributing causes associated to the Element C causal analyses was assessed as part of the 2020 Confirmatory Order Self-Assessment.

7) The scope and intent sections of operations procedures associated with rounds were assessed to determine if changes were needed to emphasize the priority of rounds and it was determined that no changes were needed.

8) A periodic report of willful violations was implemented which is provided to corporate and site senior management, the Safety Culture Executive Team and the Safety Culture Monitoring Panels. This report allows the organization to review willful violation trends in aggregate.

The following fleet wide actions were taken to address a related Notice of Violation EA-20-58 (Reference 6).

1) The River Bend Station Causal Analysis included a Fleet Extent of Condition.

2) Periodic Integrity Audits were implemented for conduct of qualification cards as part of the training integrity audits.

The Corrective Action Program was used to evaluate and address potential integrity issues.

The trend of substantiated integrity issues observed is consistent with the trend expected based on the actions taken to address the Confirmatory Order root causes.

Periodic Integrity Audits of targeted departments and processes were conducted for the last quarter 2019 and first three quarters of 2020. These audits and the communication of the results are serving as a deterrent to integrity issues in the targeted populations.

Attachment CNRO-2020-00023 Page 4 of 4 A Self-Assessment on Confirmatory Order compliance was completed in October 2020. The Self-Assessment found the Confirmatory Order action implementation acceptable.

Entergy Internal Audit group conducted an Audit of Integrity Audit Process and Training, in November of 2020. This audit found both the Integrity Audit Process and Integrity Training acceptable.