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| {{#Wiki_filter:Entergy Operations, Inc. | | {{#Wiki_filter:}} |
| 7003 Bald Hill Road P. O. Box 756 Port Gibson, MS 39150 Tel 601-437-7500
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| Robert Franssen Site Vice President GNRO-2021-00008 10 CFR 2.201 March 25, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
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| ==Subject:==
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| Response to An Apparent Violation in NRC Inspection Report 05000416/2020016; EA-20-125 Grand Gulf Nuclear Station Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License Nos. NPF-029
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| ==Reference:==
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| U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Operations, Inc.,
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| Grand Gulf Nuclear Station - NRC Inspection Report 05000416/2020016 and Investigation Report 4-2019-021, (ADAMS Accession No. ML21055A001),
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| dated February 24, 2021.
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| Entergy Operations, Inc. (Entergy) hereby submits the Response to An Apparent Violation EA-20-125 for Grand Gulf Nuclear Station in the Enclosure. As requested, the response contains the reason for the apparent violation, the corrective steps that have been taken and the results achieved, the corrective steps that will be taken, and the date when full compliance was achieved. Entergy further provides its enforcement perspective of the event.
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| This letter contains no new regulatory commitments.
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| Should you have any questions or require additional information, please contact Jeff Hardy Manager, Regulatory Assurance (acting) at 802-380-5124.
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| Respectfully, RF/jnn/jas
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| ==Enclosure:==
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| Response to An Apparent Violation in NRC Inspection Report 05000416/202016; EA-20-125 cc: NRC Region IV, Regional Administrator NRC Region IV Director, Division of Reactor Projects NRC Senior Resident Inspector - GGNS
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| Enclosure GNRO-2021-00008 Response to An Apparent Violation in NRC Inspection Report 05000416/202016; EA-20-125
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| GNRO-2021-00008 Enclosure Page 1 of 6 Entergy Operations, Inc.
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| Response to An Apparent Violation in NRC Inspection Report 05000416/202016; EA-20-125 Apparent Violation Reference 1 proposed an apparent violation of 10 CFR 50.120 by Entergy Operations, Inc.
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| (Entergy) at the Grand Gulf Nuclear Station (GGNS) as restated below:
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| The inspectors identified an apparent violation of 10 CFR 50.120, Training and qualification of nuclear power plant personnel, for the licensees failure to appropriately implement a training program that provides for the training and qualification of engineering support personnel. Specifically, an NRC investigation found that for six engineering support students, an exam proctor provided inappropriate assistance in the form of a drawing on a white board and verbal cues regarding their selection of answers during qualification exams in the November 2016 to July 2019 timeframe.
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| Response by Entergy Operations, Inc.
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| As previously identified, documented in the GGNS Corrective Action Program (CAP) and corrected, Entergy concurs that an engineering proctor engaged in inappropriate activity that caused a violation of 10 CFR 50.120. Entergy further concurs that the engineering proctors cited behaviors violated EN-TQ-104, Engineering Support Personnel Training Program. Upon identification of the issue in July of 2019, Entergy took prompt action to return the Engineering Support Personnel (ESP) Training program at the Grand Gulf Nuclear Station (GGNS) to full compliance and has implemented comprehensive corrective actions for long-term sustained compliance.
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| A. Entergys Identification of the Apparent Violation As stated in Reference 1, on July 11, 2019, an engineering student taking a proctored exam became concerned that the proctors behaviors were inappropriate. The student reported the issue to supervision who recognized the reported proctors behaviors as inconsistent with training policies. The supervisor took appropriate actions to notify GGNS training management of the concern. On July 12, 2019, GGNS training management initiated an internal Entergy Ethics case and initiated a condition report (CR-GGN-2019-05674). Entergys immediate actions at GGNS included removing the proctor from instructor duties, sending the matter for investigation, and manually overriding the students exam to fail pending the results of the investigation. Additionally, a site causal analysis was performed under condition report CR-GGN-2019-06074 and a fleet extent of cause and condition was performed under CR-HQN-2019-02641. The prompt actions of these Entergy employees were consistent with Entergys Training Program, Corrective Action Program, Nuclear Excellence Model and Code of Entegrity.
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| Entergys prompt identification of the engineering proctor misconduct was consistent with Entergys implementation of Confirmatory Order EA-17-132 / EA-17-153 issued March 12, 2018 (Reference 2). In parallel with the events described in the apparent violation, the Entergy nuclear fleet was continuing to respond to this 2018 Confirmatory Order, which was based, in part, on willful violations by a proctor in 2015, who assisted students with General Employee
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| GNRO-2021-00008 Enclosure Page 2 of 6 Training (GET) exams. The relevant actions implemented in response to the Confirmatory Order included:
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| : 1) Element A - A senior executive at each Entergy site and the corporate nuclear headquarters communicated with workers the circumstances leading to the Confirmatory Order, that willful violations will not be tolerated, and, that as a result, Entergy undertook efforts to confirm whether others are engaging in such conduct at any of its sites. The communication stressed the importance of procedural adherence, ensuring that documents are complete and accurate, and of potential consequences for engaging in willful violations. This message was 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.
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| : 2) Element B - Entergy conducted 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. Also, starting in 2019, Entergy began conducting annual computer-based training (CBT) emphasizing its intolerance of willful misconduct.
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| : 3) Elements C and E - Relative to proctor misconduct, a GGNS root cause evaluation (RCE) on proctor misconduct and two fleet RCEs addressing willful misconduct were conducted.
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| In response to Elements A and B of the Confirmatory Order, communications and training described willful misconduct, emphasized Entergys intolerance for personnel engaging in willful misconduct, and encouraged personnel to report integrity issues when identified. These communications and training reinforced concepts from the Entergy Nuclear Excellence Model and Code of Entegrity.
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| In response to Elements C and E of the Confirmatory Order, Entergy conducted a RCE of the overall fleet willful violation trend and current station willful misconduct issues. One of the two GGNS RCEs specifically addressed the GET proctor willful misconduct. These RCEs implemented three key process changes to prevent, detect, and deter willful misconduct:
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| : 1) Starting in 2019, annual integrity training was implemented to remind nuclear personnel about the consequences of willful misconduct, share operating experience examples, emphasize willful misconduct will not be tolerated, and to encourage identification of instances of possible willful misconduct;
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| : 2) Changes were made to ensure that willful misconduct would be evaluated not just through investigations, but also in the CAP; and
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| : 3) Integrity audits were implemented to act as a willful misconduct deterrent by auditing for willful misconduct and communicating the results to the audited groups.
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| Collectively, these Confirmatory Order actions have resulted in, and continue to result in, the reporting of potential integrity issues. The actions taken by the Entergy employees who identified and took prompt action in response to the inappropriate engineering proctor behaviors in July 2019 were consistent with Entergys integrity message conveyed in these communications and training. Based on Entergys investigative interviews, although previous instances were identified, the one test-taker who observed the proctors inappropriate conduct
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| GNRO-2021-00008 Enclosure Page 3 of 6 after the Confirmatory Order training and communications, was the individual who made the July 2019 report.
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| Because of the test-takers report to supervision, Entergy conducted an investigation into the engineering proctors conduct, determined the proctor provided inappropriate assistance, and took appropriate corrective actions. Based on these actions, which are clear evidence that Entergy was self-monitoring for integrity issues, it is Entergys position that GGNS should receive credit for identification of this apparent violation.
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| B. Reasons for the Apparent Violation The primary cause of the apparent violation determined by the GGNS causal analysis was that the proctor did not comply with procedural requirements for proctoring computer-based engineering examinations.
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| The fleet common cause of the Exam Administration Integrity Trend, performed following this event, resulted in a contributing cause which determined a need for improved procedural guidance for the selection, qualifications, and oversight of proctors. This contributing cause allowed the proctors inappropriate behaviors to not have been detected before this event.
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| As discussed previously, at the time of this event, Entergy was in the multi-year process of implementing the Confirmatory Order corrective actions to prevent further integrity issues. As described in the Confirmatory Order, Entergy was to monitor the effectiveness of actions to address integrity issues, and modify its actions, as needed, based on the results of its self-reviews. Although the corrective actions had been taken under the Confirmatory Order by the time event was identified - specifically the actions put in place as a result of RCEs to address proctor issues - were reasonable, Entergy recognized additional measures were necessary to address proctor issues. These additional actions are described below.
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| C. Corrective Steps That Have Been Taken and the Results Achieved Not only did Entergy personnel take appropriate action by identifying the inappropriate behavior of the proctor, Entergy also took appropriate corrective actions to address the proctors behavior and ensure the integrity of the GGNS ESP Training Program was maintained. Again, Entergys prompt correction of the engineering proctor misconduct was the result of Entergys implementation of the Confirmatory Order. Consistent with the above changes implemented and based on the causal analyses required by the Confirmatory Order, as discussed in Section A above, the inappropriate proctor behaviors were correctly reported in CAP and to the internal Entergy Ethics department.
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| The event was evaluated by Entergy Ethics and in three separate causal analysis products:
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| : 1) The GGNS causal analysis considered the actions of the proctor and the process guidance, and implemented actions at GGNS;
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| : 2) A fleet causal analysis looked at the potential extent of condition and organizational or programmatic issues fleet wide; and
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| : 3) A common cause analysis looked at the fleetwide exam administration trend.
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| GNRO-2021-00008 Enclosure Page 4 of 6 The key actions taken in response to the GGNS and fleet causal analyses of the engineering proctor willful misconduct included:
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| : 1) The proctor who conducted the willful misconduct was removed from proctor duties on July 12, 2019;
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| : 2) Following the completion of the investigations resulting from the internal Ethics Case, the proctors employment was terminated; and
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| : 3) Operating Experience on willful misconduct was shared with other proctors in the fleet via a CBT module.
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| The key actions taken in response to a common cause analysis on the Exam Administration Integrity Trend, which considered this condition, included:
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| : 1) The training process in EN-TQ-217, Examination Security, EN-TQ-216, Training and Qualification Curriculum, and EN-TQ-201-04, SAT Implementation Phase was revised to improve proctor selection and training requirements; and
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| : 2) The training process in EN-TQ-217 was revised to include periodic observations of CBT proctors to maintain proctor qualifications.
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| Following these additional actions, Entergy conducted a Training Effectiveness Review and found the training actions were effective based on:
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| : 1) Process revisions to EN-TQ-217, EN-TQ-216, and EN-TQ-201-04 were completed as prescribed;
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| : 2) Proctors were required to requalify, either completing the certification/qualification process for proctors to be implemented with Revision 10 of EN-TQ-217, Examination Security, or having their qualifications removed; and
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| : 3) All certified/qualified proctors are assigned a curriculum item to be observed every two years.
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| Based on these actions, it is Entergys position that the GGNS should receive credit for corrections of this apparent violation.
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| D. Corrective Steps That Will Be Taken Other than the ongoing actions associated with the active Confirmatory Order, no additional corrective actions are planned specific to this apparent violation.
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| E. Date When Full Compliance Will Be Achieved Full compliance with 10 CFR 50.120 was achieved on July 12, 2019, when the proctor was removed from duty.
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| F. Entergys Enforcement Perspective Entergy concurs with the NRCs Performance Assessment, This issue was associated with a willful violation of the licensee's training program and did not directly affect the Cornerstones of
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| GNRO-2021-00008 Enclosure Page 5 of 6 the Reactor Oversight Process. The significance determination process does not specifically consider willfulness in its assessment of licensee performance. As a result, there was no finding associated with this violation.
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| The violation was the isolated action of a low-level employee without management involvement.
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| The engineering proctor, an individual contributor with no supervisory responsibilities and who was not a licensee, acted unilaterally. No member of Entergy management was involved in or endorsed the misconduct. To the contrary, Entergy management provided, and continues to provide, oversight of proctors. Specifically, proctors are given training on the proper methods to administer exams, a pre-exam brief is provided for both students and proctors, and periodic management observations of proctoring are conducted. In addition, Entergy conducts semi-annual integrity audits of CBT proctoring activities to assess or detect potential deliberate misconduct issues associated with proctoring exams, and to prevent deliberate misconduct by establishing a culture where workers understand integrity is paramount, and misconduct will not be tolerated. These audits include both reviews of testing and interviews with randomly selected test-takers.
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| The impact of the violation is minor because it did not result in unqualified Entergy engineering personnel at GGNS. ESP Orientation Training is a program intended to familiarize new personnel with regulations, licensing basis, codes, site drawings and major systems. The goal of orientation training is to supplement educational experience by ensuring new engineering professionals gain the knowledge and skills needed in their jobs and in other areas within the engineering organization. The exams taken are not required to qualify engineers to do independent work. The engineering qualifications of the personnel proctored by this proctor were not in question. Although the proctors inappropriate behavior, if not detected, could have resulted in the GGNS ESP Training program being compromised, the event was identified internally by Entergy and did not contribute to the NRC making an incorrect regulatory decision.
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| In this way, this case is not unlike the matter involving Susquehanna Nuclear, LLC, addressed by the NRC in its {{letter dated|date=March 4, 2021|text=March 4, 2021 letter}} (ADAMS Accession No. ML21005A317). In both instances, absent willfulness, the significance of the issue would be assessed as green because of its relatively inappreciable potential safety consequences.
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| Effectiveness reviews from the Confirmatory Order have demonstrated fleet-wide that Entergy personnel overall have exhibited a high level of integrity, and the actions from the Confirmatory Order have resulted in an improved ability to both detect and correct willful misconduct. It is recognized that previous proctor misconduct events were the subject of the Confirmatory Order and as a result, Entergy implemented the communication and training actions discussed above.
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| These Confirmatory Order actions have been successful in enabling Entergy to identify potential willful misconduct at an earlier stage and prevent more significant or widespread violations. The misconduct at issue in this apparent violation (i.e., grunts and verbal clues like, your first answer is usually your best answer) is less egregious than the conduct that was the subject of the Confirmatory Order (i.e., completing entire examinations for trainees).
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| While Entergy considers the violation to be repetitive in accordance with the definition outlined in the NRC Enforcement Policy Section 2.3.2.a.3, the violation was identified by Entergy.
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| Considering NRC Enforcement Manual, Part I, Sections 2.2.2.A.4.b and NRC Enforcement Policy Section 2.3.2.a, Entergy requests escalated enforcement action not be taken and discretion be applied. This issue meets the specific criteria set forth in these sections as captured below:
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| GNRO-2021-00008 Enclosure Page 6 of 6
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| * As discussed above, Entergy identified the violation through continued self-monitoring efforts and placed the issue into the CAP, which included actions to prevent recurrence.
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| Although not required to be reported, Entergy personnel recall providing information concerning the violation to NRC personnel including the GGNS Senior Resident Inspector and Region IV management;
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| * As discussed above, the violation was the isolated action of a low-level employee without management involvement;
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| * As discussed above, the violation was not caused by lack of management oversight, as evidenced by ongoing training, communications, and quarterly audits of proctoring activities;
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| * As discussed above, Entergy took significant remedial action commensurate with the circumstances, demonstrating the seriousness of the violation to other employees and contractors and thereby creating a deterrent effect within Entergys organization. (The Enforcement Manual provides that while removal of the employee from licensed activities is not necessarily required, substantial disciplinary action is expected. In this case, the employee was terminated.)
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| Based on Section 2.3.2.a of the Enforcement Policy and meeting the criteria as provided above, Entergy contends that this violation should be treated as a Non-Cited Violation.
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| ==References:==
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| : 1) U.S. Nuclear Regulatory Commission (NRC) letter to Entergy (Entergy Operations, Inc.), Grand Gulf Nuclear Station - NRC Inspection Report 05000416/2020016 and Investigation Report 4-2019-021, (ADAMS Accession No. ML21055A001), dated February 24, 2021.
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| : 2) 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, (ADAMS Accession No. ML18072A191), dated March 12, 2018.
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| : 3) Entergy Operations, Inc. and Entergy Nuclear Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 are Complete, Element L," (ADAMS Accession No. ML21028A782), dated January 28, 2021.}}
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