PNP 2016-016, Reply to Request for Information EA-16-011

Reply to Request for Information EA-16-011

ML16063A165
Person / Time
Site:	Palisades
Issue date:	03/03/2016
From:	Gustafson O Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-16-011, PNP 2016-016
Download: ML16063A165 (2)

Text

• ~* Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Otto W. Gustafson Regulatory and Performance Improvement Director PNP 2016-016 EA-16-011 March 3, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Reply to Request for Information EA-16-011 Palisades Nuclear Plant Docket 50-255 License No. DPR-20

References:

1. Letter from Nuclear Regulatory Commission to Entergy Nuclear Operations, Inc. dated February 11, 2016, "Results of the U.S.

Nuclear Regulatory Commission Discrimination Investigations and Request for Information Regarding the U.S. Department of Labor Findings of Discrimination"

Dear Sir or Madam:

On February 11, 2016, the Nuclear Regulatory Commission (NRC) issued the referenced letter to Entergy Nuclear Operations, Inc (ENO). The letter is regarding allegations of discrimination made by two former Palisades Nuclear Plant (PNP) employees to the NRC in December 2013. The NRC investigated the employee's claims and did not substantiate those allegations. The NRC conducted a follow-up investigation in April 2015 and confirmed that the allegations were not substantiated.

The former employees also filed claims of discrimination with the U.S. Department of Labor (DOL) Occupational Safety and Health Administration (OSHA). OSHA found that there was reasonable cause to believe that ENO had discriminated against the complainants, but ENO has appealed this conclusion and is currently seeking review through the DOL's administrative hearing process.

The NRC has been closely monitoring the work environment at PNP since 2013 by performing inspections and reviewing the Safety Conscious Work Environment (SCWE) action plan developed as a result of safety culture issues identified at that time. In December 2014, the NRC concluded that these actions were effective and that the work environment at PNP was conducive to raising safety concerns. Monitoring of the progress at PNP is ongoing.

Document Control Desk PNP 2016-016 Page 2 Although the NRC recognizes that ENO is taking actions to mitigate the potential effect that may have resulted from the publication of OSHA's finding, the referenced letter requests that PNP provide a response that describes the actions already taken or those planned, in order to assure that the initial OSHA finding is not having an adverse impact on the willingness of employees to raise safety and compliance concerns.

As a result of the OSHA finding, ENO took additional actions to re-emphasize various aspects of SCWE and related personnel responsibilities. In particular, ENO conducted face-to-face briefings with security personnel from February 22 to 24, 2016, and briefings with personnel from the remaining site departments on March 3, 2016. These briefings reiterated that all personnel have a responsibility to raise safety issues, reminded personnel of the alternate means available for raising safety concerns, and reinforced expectations that harassment, intimidation, retaliation, and discrimination against raising safety concerns will not be tolerated and must be immediately reported.

No further actions in response to Reference 1 are planned at this time. ENO continues to monitor the health of the safety culture at PNP.

This letter contains no new commitments and provides no revisions to existing commitments.

If you have questions about the content of this letter, please contact me at (269) 764-2049.

Sincerely, OWG/bed CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

• ~* Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Otto W. Gustafson Regulatory and Performance Improvement Director PNP 2016-016 EA-16-011 March 3, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Reply to Request for Information EA-16-011 Palisades Nuclear Plant Docket 50-255 License No. DPR-20

References:

1. Letter from Nuclear Regulatory Commission to Entergy Nuclear Operations, Inc. dated February 11, 2016, "Results of the U.S.

Nuclear Regulatory Commission Discrimination Investigations and Request for Information Regarding the U.S. Department of Labor Findings of Discrimination"

Dear Sir or Madam:

On February 11, 2016, the Nuclear Regulatory Commission (NRC) issued the referenced letter to Entergy Nuclear Operations, Inc (ENO). The letter is regarding allegations of discrimination made by two former Palisades Nuclear Plant (PNP) employees to the NRC in December 2013. The NRC investigated the employee's claims and did not substantiate those allegations. The NRC conducted a follow-up investigation in April 2015 and confirmed that the allegations were not substantiated.

The former employees also filed claims of discrimination with the U.S. Department of Labor (DOL) Occupational Safety and Health Administration (OSHA). OSHA found that there was reasonable cause to believe that ENO had discriminated against the complainants, but ENO has appealed this conclusion and is currently seeking review through the DOL's administrative hearing process.

The NRC has been closely monitoring the work environment at PNP since 2013 by performing inspections and reviewing the Safety Conscious Work Environment (SCWE) action plan developed as a result of safety culture issues identified at that time. In December 2014, the NRC concluded that these actions were effective and that the work environment at PNP was conducive to raising safety concerns. Monitoring of the progress at PNP is ongoing.

Document Control Desk PNP 2016-016 Page 2 Although the NRC recognizes that ENO is taking actions to mitigate the potential effect that may have resulted from the publication of OSHA's finding, the referenced letter requests that PNP provide a response that describes the actions already taken or those planned, in order to assure that the initial OSHA finding is not having an adverse impact on the willingness of employees to raise safety and compliance concerns.

As a result of the OSHA finding, ENO took additional actions to re-emphasize various aspects of SCWE and related personnel responsibilities. In particular, ENO conducted face-to-face briefings with security personnel from February 22 to 24, 2016, and briefings with personnel from the remaining site departments on March 3, 2016. These briefings reiterated that all personnel have a responsibility to raise safety issues, reminded personnel of the alternate means available for raising safety concerns, and reinforced expectations that harassment, intimidation, retaliation, and discrimination against raising safety concerns will not be tolerated and must be immediately reported.

No further actions in response to Reference 1 are planned at this time. ENO continues to monitor the health of the safety culture at PNP.

This letter contains no new commitments and provides no revisions to existing commitments.

If you have questions about the content of this letter, please contact me at (269) 764-2049.

Sincerely, OWG/bed CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC