1 

1 UNITED STATES OF AMERICA 

2 NUCLEAR REGULATORY COMMISSION 

3 + + + + + 

4 BRIEFING ON RESULTS OF THE AGENCY ACTION REVIEW 

5 MEETING (AARM) 

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7 THURSDAY, 

8 JUNE 2, 2016 

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10 ROCKVILLE, MARYLAND 

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12 The Commission met in the Commissioners' 

13 Hearing Room at the Nuclear Regulatory Commission, 

14 One White Flint North, 11555 Rockville Pike, at 8:58 

15 a.m., Stephen G. Burns, Chairman, presiding. 

16 

17 

18 

19 COMMISSION MEMBERS: 

20 STEPHEN G. BURNS, Chairman 

21 KRISTINE L. SVINICKI, Commissioner 

22 WILLIAM C. OSTENDORFF, Commissioner 

23 JEFF BARAN, Commissioner 

24 

25 ALSO PRESENT: 

26 ANNETTE VIETTI-COOK, Secretary of the Commission 
 2 

1 MARGARET DOANE, General Counsel 

2 

3 NRC STAFF: 

4 VICTOR M. MCCREE, Executive Director for Operations 

5 DANIEL COLLINS, Director, Division of Material 

6 Safety, State Tribal and Rulemaking Programs, 

7 Office of Nuclear Material Safety and 

8 Safeguards 

9 MARC DAPAS, Regional Administrator, Region IV 

10 DANIEL H. DORMAN, Regional Administrator, Region I 

11 SCOTT MORRIS, Director, Division of Inspection and 

12 Regional Support, Office of Nuclear Reactor 

13 Regulation 

14 

15 ENTERGY STAFF: 

16 CHRIS BAKKEN, Executive Vice President/Chief Nuclear 

17 Officer 

18 JEREMY BROWNING, Site Vice President-Arkansas 

19 Nuclear One 

20 JOHN DENT, Site Vice President-Pilgrim Nuclear Power 

21 Station 

22 DONNA JACOBS, Chief Operating Officer 

23 JOHN McCANN, Vice President, Regulatory Assurance 

24 TIM MITCHELL, Senior Vice President 

25 JOHN VENTOSA, Chief Operating Officer 

26 

27 P R O C E E D I N G S 
 3 

1 CHAIRMAN BURNS: Thank you. And I will 

2 ask the staff to come forward for our main part of 

3 today's meeting. We want to welcome the staff, 

4 members of the public, other external panelists who 

5 appear before us today. 

6 The purpose of today's meeting is for the 

7 NRC staff to discuss the results of the Agency Action 

8 Review Meeting or AARM and to hear from Entergy 

9 Corporation representatives on their action plans for 

10 improving performance at the Arkansas Nuclear One and 

11 the Pilgrim Nuclear Power plants. 

12 We will begin with presentations from the 

13 staff and following the staff panel, we will have a 

14 brief break and then we will hear from two panels 

15 from Entergy Corporation. 

16 I look forward to the presentations and 

17 the ensuing discussion with members of the 

18 Commission. Would any of my colleagues like to make 

19 any remarks before we begin? 

20 Okay, with that, I will turn it over to 

21 the staff to discuss the results. Vic. 

22 MR. MCCREE: Good morning, Mr. Chairman, 

23 Commissioners. 

24 Today, we are here to discuss the results 

25 of this year's Agency Action Review Meeting that we 

26 conducted on April 27th. As you know, the Agency 
 4 

1 Action Review Meeting is an opportunity for NRC senior 

2 managers to gather and evaluate the processes that we 

3 use to ensure the operational safety performance of 

4 our licensees. Next slide. 

5 The specific objectives of the Agency 

6 Action Review Meeting or AARM are to review the 

7 appropriateness of the actions that we have taken for 

8 power reactor plants, for power reactor plants under 

9 construction and/or nuclear material licensees with 

10 significant performance issues; to ensure that 

11 coordinated course of action are developed and 

12 implemented for our licensees with performance 

13 issues; to review the results of our annual assessment 

14 on the effectiveness of the reactor oversight 

15 process, including a review of all approved 

16 deviations from that process and the action matrix 

17 specifically; to review the results and assess our 

18 effectiveness of the construction reactor oversight 

19 process, including all approved deviations from the 

20 construction reactor oversight process action matrix 

21 and ensure the trends in the industry and in licensee 

22 performance are recognized and appropriately 

23 addressed. Slide 3, please. 

24 Before I turn it over to the following 

25 speakers listed on the agenda, I would like to discuss 

26 the results of this year's Agency Action Review 
 5 

1 Meeting and I would like to highlight one topic which 

2 was discussed at the AARM but is not being presented 

3 in detail at this meeting today and that is the 

4 results of the annual construction reactor oversight 

5 process self-assessment that showed that no 

6 facilities met the criteria to be discussed at this 

7 AARM Commission meeting. 

8 The process that we implemented followed 

9 the principles of good regulation and we also 

10 concluded that the staff have been effective in 

11 ensuring the new reactor units that are being 

12 constructed are being done so in accordance with the 

13 approved designs. 

14 We will discuss the construction 

15 assessment in more detail during the New Reactors 

16 Business Line Commission Meeting, which is planned 

17 for later this fall. 

18 Now, I would like to turn it over to our 

19 first speaker, Marc Dapas, to discuss the performance 

20 at Arkansas Nuclear One. Marc. 

21 MR. DAPAS: Good morning, Mr. Chairman 

22 and Commissioners. I appreciate the opportunity to 

23 be here today and discuss with you our regulatory 

24 oversight activities with respect to Arkansas Nuclear 

25 One or ANO. 

26 Regarding my presentation, I will briefly 
 6 

1 mention the yellow findings we issued that led to the 

2 staff decision to place ANO in column 4 of the reactor 

3 oversight process or ROP action matrix. Then, I will 

4 focus my remarks in five overarching areas with the 

5 first being the principle findings from our recently 

6 completed 95003 supplemental inspection. I will then 

7 discuss the causes for the significant performance 

8 decline at ANO as identified by Entergy and 

9 independently verified by the NRC. Following that, 

10 I will highlight some notable improvements in 

11 licensee performance. Then, I will describe our 

12 oversight activities and those going forward. 

13 Finally, I will share some overarching 

14 regulatory perspectives, including the basis for our 

15 conclusion that ANO continues to operate with 

16 adequate safety margin. Next slide, please. 

17 By way of background, on March 31, 2013, 

18 while moving the Unit 1 main generator stator out of 

19 the turbine building, the temporary lifting assembly 

20 failed, causing the stator to fall into the shared 

21 train bay between Unit 1 and Unit 2. 

22 Based on the risk significance 

23 determination, in June of 2014 we issued a yellow 

24 finding for both Unit 1 and Unit 2 in the initiating 

25 events cornerstone, which for ROP action matrix 

26 purposes, was effective the first quarter of 2014. 
 7 

1 As the stator fell, it damaged a fire 

2 main. The water from this fire main caused localized 

3 flooding with some of it leaking past degraded hatch 

4 seals and entering the Unit 1 Auxiliary Building. 

5 Given the flooding vulnerabilities revealed by the 

6 stator drop event, the licensee began an extent of 

7 condition review which eventually led to the 

8 identification of over 100 unsealed conduits and 

9 degraded seals. 

10 We concluded that the licensee failed to 

11 design, construct, and maintain flood barriers for 

12 certain structures in a manner that would protect 

13 safety-related equipment from flooding. 

14 Given the significance of this failure, 

15 we issued a yellow finding for both Unit 1 and Unit 

16 2 in the mitigating systems cornerstone in January of 

17 2015, which was effective the third quarter of 2014. 

18 After NRC engagement via the performance 

19 indicator or PI frequently asked question process, 

20 the licensee submitted revised PI data in March of 

21 2015, which resulted in the PI for unplanned scrams 

22 per 7,000 critical hours with respect to Unit 2 

23 turning white for the second and third quarter of 

24 2014. Next slide, please. 

25 With the completion of the 95003 

26 supplemental inspection, we have conducted a rigorous 
 8 

1 independent diagnostic assessment of the performance 

2 programs and processes at ANO. The 95003 

3 supplemental inspection, which is the inspection and 

4 assessment tool we use for column 4 plants is the 

5 most comprehensive inspection activity we conduct in 

6 the connection with the ROP and consisted of more 

7 than 3,750 direct inspection hours in the case of 

8 ANO. 

9 The results of this significant 

10 inspection provided us with insights into the breadth 

11 and depth of safety, organizational and programmatic 

12 issues that contributed to the performance decline at 

13 ANO. 

14 The subject inspection included a 

15 diagnostic review of programs and processes that are 

16 not typically inspected as part of the ROP baseline 

17 inspection program. It included an independent 

18 assessment of the safety culture at ANO, including 

19 the results of Entergy's independent, third-party 

20 nuclear safety culture assessment and associated 

21 apparent cause evaluation. 

22 The inspection also included an 

23 assessment of the completed and planned corrective 

24 actions related to the four yellow findings and the 

25 white performance indicator using inspection 

26 procedures 95002 and 95001, respectively. 
 9 

1 With respect to the white performance 

2 indicator, the 95003 inspection team concluded that 

3 the licensee adequately addressed the causes for the 

4 three unplanned scrams involving Unit 2 and as such, 

5 this performance indicator will be closed in the 95003 

6 inspection report, which I expect to sign next week. 

7 In addressing the yellow finding for 

8 degraded flood protection features, the licensee 

9 modified some 300 existing fire seals to also make 

10 them flood resistant. However, in doing so, the 

11 licensee created a number of untested configurations. 

12 The licensee has contracted to have 

13 testing performed to determine whether there are any 

14 actual degraded conditions from a fire protection 

15 standpoint. While the data is still being reviewed, 

16 preliminary results indicate a positive testing 

17 outcome. 

18 One of the root causes for the yellow 

19 finding associated with the stator drop event was 

20 inadequate control of contractors. Since the stator 

21 drop event, the licensee has implemented corrective 

22 actions to enhance station requirements for oversight 

23 of supplemental workers performing contract work 

24 activities, such as engineering and technical 

25 services. 

26 However, the 95003 inspection team 
 10 

1 concluded that corrective actions to address the 

2 extent of condition with contractor oversight 

3 problems have not been fully effective. Further 

4 action is needed because oversight plans for outage 

5 workers were inadequate. Qualification requirements 

6 for contractors to act as supervisors did not have a 

7 consistent standard and designated ANO oversight 

8 personnel lacked adequate guidance and training to 

9 effectively perform their oversight plan. 

10 The licensee has subsequently revised its 

11 comprehensive recovery plan to address these gaps. 

12 Next slide. 

13 The team concluded that the licensee did 

14 not fully evaluate safety culture weaknesses. The 

15 specific action plan focused on improving safety 

16 culture was not developed. And as such, corrective 

17 actions were not formulated for some safety culture 

18 elements that the 2015 independent safety culture 

19 assessment indicated were degraded. 

20 The causes and/or extent of problems 

21 associated with some safety culture attributes were 

22 not evaluated. In response to the team's assessment, 

23 the licensee performed appropriate causal evaluations 

24 and developed the specific action plan that addresses 

25 the full scope and causes for the identified safety 

26 culture weaknesses. The licensee did not determine 
 11 

1 the causes for the full extent of problems with risk 

2 recognition and management. Actions to improve risk 

3 management were incomplete and few actions existed to 

4 address risk recognition. 

5 The team identified several examples of 

6 where procedure guidance was not adequate and/or 

7 workers lacked training to be proficient in their 

8 respective risk management roles. 

9 The team identified that the licensee's 

10 recovery plan did not adequately consider training 

11 and benchmarking as key improvement strategies. 

12 Benchmarking outside the Entergy fleet and 

13 involvement in various industry initiatives has been 

14 limited. As Entergy's senior corporate officials 

15 have acknowledged in our discussions with them, 

16 appropriate industry benchmarking has been a gap 

17 across the Entergy fleet. Next slide, please. 

18 Problems with effectively implementing 

19 various engineering programs were more extensive than 

20 the licensee had originally concluded from its self21 assessments. 

22 While some licensee evaluations indicated 

23 performance was acceptable, the inspection team 

24 determined that the problems were more significant 

25 than the licensee had originally concluded. The team 

26 identified instances were ANO did not adequately 
 12 

1 evaluate and use internal and industry operating 

2 experience to prevent future problems. As a result 

3 some technical issues were not resolved, leading to 

4 recurrent equipment challenges. Next slide, please. 

5 Entergy identified and the NRC confirmed 

6 through the 95003 inspection the following 

7 overarching causes for declining performance at ANO. 

8 The licensee did not effectively manage the change 

9 associated with resource reduction initiatives in 

10 2007 and 2013. For example, the staffing reductions 

11 at ANO did not account for the two different unit 

12 designs and elimination of various positions resulted 

13 in significant increases in work backlogs, as station 

14 leaders attempted to prioritize work with existing 

15 resources. And starting in 2013, policy changes 

16 resulted in an unexpected increase in retirements and 

17 the licensee did not adequately manage the loss of 

18 experience.

19 Leadership behaviors were not 

20 commensurate with a strong safety culture. 

21 Monitoring of licensee performance was ineffective 

22 across the organization. For example, station 

23 performance indicators focused on completed actions, 

24 rather than on whether those actions were effective. 

25 At the corporate level, performance 

26 monitoring and safety review committee processes 
 13 

1 stopped being intrusive. As I mentioned previously, 

2 external benchmarking outside the Entergy fleet was 

3 limited. And as such, ANO performance was deemed 

4 compared to other sites within the fleet. 

5 Standards declined, which was most 

6 evident in failures to follow procedures or stop and 

7 correct unclear procedure steps. The licensee became 

8 more accepting of degraded equipment performance and 

9 reduced margins by using strategies that relied on 

10 engineering analyses or proceduralized compensatory 

11 measures, rather than fixing degraded equipment. The 

12 effectiveness of corrective action program gradually 

13 declined. For example, degraded equipment was 

14 restored without having a complete understanding of 

15 the cause for the degradation. Performance 

16 assessments were weak or nonexistent and problem 

17 trending was ineffective. Causal evaluations did not 

18 consider organizational and programmatic challenges. 

19 Next slide, please. 

20 Although the licensee is in the early 

21 stages of implementing its comprehensive recovery 

22 plan, there have been some notable improvements in 

23 station performance. Licensee management has been 

24 more rigorous and conservative in its decision25 making. For example, in response to a leaking 

26 component inside the Unit 2 containment, a well-
 14 

1 designed plan was implemented. Unit 2 was shut down 

2 before there was any significant operational impact 

3 and a permanent repair was made without any evidence 

4 of schedule pressure. 

5 Our inspectors also observed a lower 

6 threshold for addressing equipment reliability issues 

7 during the Unit 2 outage last fall. And the NRC 

8 resident inspectors have noted a number of examples 

9 that clearly indicate that the operations department 

10 is becoming a demanding customer and raising 

11 standards across the station. Shift managers have 

12 challenged work plans and operability evaluations, 

13 insisting on more complete evaluations in 

14 documentation and are verifying conditions. 

15 Discussions about potential risk are apparent across 

16 the station and corrective action program rigor has 

17 improved. There is a clear emphasis on having a 

18 greater questioning attitude and need to understand 

19 problems so that they can be addressed. Next slide. 

20 The licensee submitted its comprehensive 

21 recovery plan on the docket on May 17th. We have 

22 reviewed the plan and concluded that the constituent 

23 corrective actions are appropriate and fully address 

24 both licensee and NRC-identified performance gaps. 

25 We are developing a confirmatory action letter or CAL 

26 that captures the specific actions within the 
 15 

1 licensee's recovery plan that are necessary to 

2 address the significant performance deficiencies that 

3 led to the station being placed in column 4, as well 

4 as the key actions needed to ensure sustained 

5 improvement in safety performance. 

6 Regarding our inspection process going 

7 forward, in addition to the routine resident 

8 inspection program, we intend to conduct focused 

9 inspections at ANO on roughly a quarterly basis. The 

10 specific inspection frequency will be a function of 

11 when the licensee has completed its own assessment of 

12 corrective action effectiveness with respect to the 

13 individual CAL items and informed us that the 

14 associated results indicate that items are ready to 

15 be inspected. 

16 From our inspection activities, we will 

17 independently determine whether the licensee's 

18 corrective actions have been effective in achieving 

19 performance improvement. The CAL will remain open 

20 until we have determined that the licensee has 

21 sustained performance improvement through effective 

22 implementation of its recovery plan. Next slide. 

23 As I stated earlier, via the 95003 

24 supplemental inspection, we have conducted a rigorous 

25 independent diagnostic assessment of the performance 

26 programs and processes at ANO. Based on this 
 16 

1 assessment, we have concluded that Entergy's 

2 discovery effort was reasonably comprehensive, though 

3 as I have discussed the 95003 inspection team did 

4 identify some gaps. Based on Entergy's collective 

5 review of the causes for the performance decline at 

6 ANO, the findings from the 2015 independent third7 party nuclear safety culture assessment and the 

8 results of the NRC's 95003 supplemental inspection, 

9 we have determined that Entergy understands the 

10 breadth and depth of the performance concerns 

11 associated with ANO's performance decline. 

12 In addition, from our review of the 

13 licensee's comprehensive recovery plan, we have 

14 determined that it does address with specific planned 

15 corrective actions the performance gaps or concerns. 

16 Effective implementation of the 

17 comprehensive recovery plan supported by the 

18 allocation of adequate resources and continued 

19 oversight by Entergy leadership should lead to 

20 substantial and sustained performance improvement at 

21 ANO. 

22 Based on the results of our assessment, 

23 we are confident that the current level of regulatory 

24 oversight is appropriate and no action in addition to 

25 those prescribed in the ROP action matrix are 

26 necessary. 
 17 

1 We have also independently confirmed 

2 through our inspection and assessment processes that 

3 ANO continues to operate with adequate safety margin. 

4 While the causes for decline in performance that are 

5 described earlier do indicate that over time there 

6 had been a reduction in safety margins in terms of 

7 how effectively programs and processes were being 

8 implemented and how personnel behaved at the station, 

9 those margin reductions have not reached an 

10 unacceptable level. The robust plant design has not 

11 been compromised and there have not been any 

12 significant operational events or risk significant 

13 findings since the plant was placed in column 4. 

14 As I described earlier, a number of 

15 improvements have been noted at ANO. Two of the more 

16 significant area of improvement are operational focus 

17 and equipment reliability. Operator fundamentals 

18 have been strengthened and decision-making has been 

19 more conservative. 

20 You may recall that at last year's 

21 commission meeting I commented the NRC has been 

22 driving licensee performance. And that going 

23 forward, the thoroughness of the licensees' self24 assessment and discovery effort would be an indicator 

25 of whether that situation had changed. I suggested 

26 at that time that if our 95003 inspection team 
 18 

1 identified extensive and significant gaps in the 

2 results of the licensee's discovery effort, that 

3 would be an indicator that the NRC versus the licensee 

4 was continuing to drive things. 

5 I'm glad to see that is not what occurred. 

6 And as I said previously, we will continue to monitor 

7 and independently assess the effectiveness of 

8 Entergy's corrective actions during our continuing 

9 inspection activities. 

10 This concludes my remarks with respect to 

11 ANO and I will now turn it over to Dan Dorman. Thank 

12 you. 

13 MR. DORMAN: Thank you, Marc. Good 

14 morning, Chairman Burns, Commissioners. This morning 

15 I plan to provide you a brief overview of the gradual 

16 performance decline at Pilgrim Nuclear Power Station 

17 which resulted in the plant being placed in column 4 

18 of the NRC action matrix. I will also discuss the 

19 enhanced oversight activities undertaken by the staff 

20 as a result and outline near-term activities. Before 

21 I get into that, I would like to acknowledge two 

22 members of our team leading the oversight of Pilgrim 

23 who are behind me to your left. Mrs. Erin Carfang 

24 is the senior resident inspector at Pilgrim Station 

25 and to her left Mr. Art Burritt is the Branch Chief 

26 in the Division of Reactor Projects who is 
 19 

1 coordinating and organizing the oversight of Pilgrim 

2 during this time. Next slide, please. 

3 Pilgrim entered column 3 or the degraded 

4 cornerstone column of the NRC action matrix in the 

5 fourth quarter of 2013, when the performance 

6 indicators for unplanned scrams and unplanned scrams 

7 with complications were both white. This resulted 

8 from four unplanned scrams in 2013, three of which 

9 involved complications. Next slide, please. 

10 In December 2014, the region performed an 

11 inspection under Procedure 95002 to review the 

12 company's corrective actions to address the issues 

13 that contributed to the multiple unplanned shutdowns. 

14 This inspection determined that Pilgrim's actions to 

15 date were not adequate to address the root and 

16 contributing causes of unplanned shutdowns. As a 

17 result, the staff opened two parallel white findings 

18 in accordance with the inspection manual and, in 

19 consequence of that, Pilgrim remained in the degraded 

20 cornerstone column for greater than five quarters. 

21 Next slide, please. 

22 On January 27, 2015, during Winter Storm 

23 Juno, Pilgrim experienced a loss of offsite power 

24 resulting in an automatic shutdown of the reactor. 

25 During the ensuing cooldown, one of the plant's four 

26 safety relief valves failed to open on demand three 
 20 

1 times. I would note that the plant was safely cooled 

2 down and depressurized using two of the remaining 

3 safety relief valves. 

4 A special inspection team from Region I 

5 discovered that a similar failure had occurred during 

6 Winter Storm Nemo two years earlier and that the 

7 company had failed to understand and correct the root 

8 cause of that failure and to take actions to prevent 

9 recurrence. This performance deficiency was 

10 determined to be of low to moderate safety 

11 significance. The resultant white finding in 

12 combination with the greater than five quarters in 

13 the degraded cornerstone led to Pilgrim being placed 

14 into column 4 of the action matrix for a repetitive 

15 degraded cornerstone on September 1, 2015. 

16 The assessment letter to Entergy 

17 identified that the focus of our enhanced oversight 

18 will be on longstanding weaknesses in the company's 

19 programs for identifying and resolving problems at 

20 the site, as well as an assessment of the safety 

21 culture that has allowed these weaknesses to persist. 

22 Consistent with the nature of the complications 

23 associated with the unplanned shutdowns in 2013 and 

24 2015, the inspection will also examine the key reactor 

25 safety attributes of equipment performance, human 

26 performance, and procedure quality. Next slide, 
 21 

1 please. 

2 As a result of the movement to column 4, 

3 Entergy has undertaken a broad scope evaluation of 

4 the site's safety culture and corrective action 

5 programs, among other things. Pursuant to Inspection 

6 Manual Chapter 305, Region I will lead diagnostic 

7 evaluation of the licensee's programs and improvement 

8 plans when the licensee has indicated readiness to 

9 receive such an inspection. At this time, we 

10 understand the licensee expects to indicate their 

11 readiness within the next couple of months. 

12 In the meantime, Region I has undertaken 

13 several targeted inspections within the baseline 

14 inspection program and also under Inspection 

15 Procedure 95003 to ensure that adequate safety 

16 margins are maintained. We have exercised 

17 flexibilities in the implementation of 95003 to move 

18 up some of the samples under the corrective action 

19 portion of the inspection to address the procedure's 

20 objectives related to the acceptability of continued 

21 operations while the company conducts its reviews and 

22 develops its recovery plan. 

23 The Phase A and B inspections were 

24 conducted to determine whether significant issues 

25 were being adequately addressed and whether 

26 additional regulatory actions were necessary to 
 22 

1 arrest decline plant performance. They serve as 

2 partial completion of this portion of the procedure. 

3 Phase A was conducted in January of 2016 

4 and reviewed open risk-significant issues and other 

5 aspects of the corrective action program. No 

6 significant issues were identified as a result of 

7 this inspection. 

8 Phase B was completed in early April and 

9 looked at overall corrective action program 

10 performance since the last biennial problem 

11 identification resolution inspection, which was 

12 completed last August. This inspection focused on 

13 progress in improving the plant's performance in the 

14 area of corrective actions. Overall, the team 

15 determined that Entergy was taking appropriate 

16 actions to address identified weaknesses in the 

17 corrective action program. The team concluded that 

18 progress has been made over the last several months, 

19 due to management's commitment to improvement. 

20 However, continued management attention is warranted 

21 to ensure sustained improvement, as the items 

22 identified in the report indicated that weaknesses in 

23 the program continued to exist. 

24 The final phase of the 95003 inspection 

25 will be scheduled for completion once Entergy 

26 indicates that it is ready. Next slide, please. 
 23 

1 We have also targeted problem 

2 identification and resolution samples within the 

3 baseline inspection program in the areas of previous 

4 performance issues. In particular, during the fourth 

5 quarter of last year, we targeted several inspection 

6 samples in the area of operator performance and 

7 procedure quality. While these inspections confirm 

8 weaknesses in the corrective program implementation, 

9 they have not revealed any additional significant 

10 performance deficiencies. To support these 

11 inspection activities, Region I has augmented our 

12 resident inspector team at the station pending the 

13 results of the 95003 inspection. We are conducting 

14 senior management quarterly performance assessments 

15 and reviews of our oversight strategy. The results 

16 of these assessments and the inspections to date will 

17 guide the planning of the final phase of the 

18 inspection 95003. 

19 Currently, the results of these 

20 activities indicate that additional regulatory 

21 actions beyond those prescribed for plants in column 

22 4 are not required. There have been no risk23 significant events, equipment failures, or inspection 

24 findings since Pilgrim's entry into column 4. Next 

25 slide, please. 

26 Successful completion of the final phase 
 24 

1 of the 95003 will ensure that Entergy understands the 

2 causes of the significant performance issues and has 

3 developed plans which are reasonably expected to 

4 result in sustained improvement in station 

5 performance. The completion of the 95003 will 

6 support the development of a confirmatory action 

7 letter and the assessment of the need for additional 

8 regulatory action. The content of the confirmatory 

9 action letter will identify the most significant 

10 elements of the licensee's recovery plan, as 

11 determined by the inspection and confirm as licensee 

12 commitments. To ensure adequate implementation of 

13 the most significant corrective action items, CAL 

14 follow-up inspections will be conducted as Entergy 

15 makes progress on its improvement plan. Exit from 

16 column 4 will occur when sustained performance is 

17 demonstrated by the inspection closeout of the 

18 elements of the CAL. Next slide, please. 

19 Notwithstanding the decline in 

20 performance at Pilgrim -- yes, next slide, please. 

21 Thank you. Notwithstanding the decline in 

22 performance at Pilgrim, the staff concludes, based on 

23 the results of our augmented oversight activities, 

24 that there remains adequate safety margin in the 

25 design and operation of the plant to support continued 

26 operation. Since placing the plant in column 4, we 
 25 

1 have undertaken specific additional inspection 

2 activities. These inspections have been aimed at 

3 determining whether the performance decline at 

4 Pilgrim indicates the existence of other significant 

5 performance deficiencies. To date, we have found 

6 none. 

7 In the meantime, the licensee has 

8 embarked on a substantial effort to evaluate their 

9 programs and processes, to identify root and 

10 contributing causes of the decline and to establish 

11 a plan to accomplish sustained performance 

12 improvement. 

13 This concludes my remarks. I look 

14 forward to your questions. And I will now turn the 

15 presentation over to Dan Collins. 

16 MR. COLLINS: Thank you, Dan. Good 

17 morning, Mr. Chairman, Commissioners. This morning 

18 I will be discussing the nuclear materials and waste 

19 program performance. 

20 The materials program includes 

21 approximately 21,000 NRC and Agreement State 

22 licensees that perform a wide variety of activities 

23 in areas such as industrial, academic, medical, and 

24 fuel cycle facilities. It is important to note that 

25 some activities involve intentional exposure of 

26 humans to radiation, particularly in diagnostic and 
 26 

1 therapeutic medical uses. 

2 The NRC 2015 Performance and 

3 Accountability Report estimated that 112 million 

4 nuclear medicine or radiation therapy procedures are 

5 performed annually, with the vast majority used in 

6 diagnostic procedures. 

7 When discussing trending, the number of 

8 reported events is small in proportion to the total 

9 number of activities carried out. That being said, 

10 the staff monitors the data and continues to look for 

11 issues or events that warrant additional NRC 

12 response, communication, or program improvements in 

13 support of the materials program. I plan to 

14 highlight some of the issues we addressed this year 

15 as part of the National Materials Program Review. 

16 Next slide, please. 

17 We collect, monitor, and evaluate 

18 industry operational data on an ongoing basis as part 

19 of our event reporting function. This information 

20 is provided in an annual assessment report to the 

21 Commission. Our performance evaluation process 

22 includes the review of operational performance 

23 trends, significant licensee performance issues, and 

24 identification of issues and gaps in the NRC program 

25 that warrant high-level management awareness at the 

26 agency action review meeting. 
 27 

1 Operational performance trends refers to 

2 what is examined in the nuclear materials event 

3 database annual report and is part of our ongoing 

4 review of events. Licensee performance issues refers 

5 to the specific criteria for identifying nuclear 

6 material licensees for discussion at the agency 

7 action review meeting. The key aspects of the 

8 criteria include licensees with events resulting in 

9 failures to meet NRC strategic goals, significant 

10 issues or events that result in escalated enforcement 

11 and where there are aspects that warrant additional 

12 oversight, repetitive significant program issues or 

13 multiple inspections also involving escalated 

14 enforcement, and licensees discussed at previous 

15 Agency Action Review Meetings, where the licensee 

16 corrective actions did not address or were 

17 ineffective in correcting the underlying issues 

18 identified. 

19 And finally, NRC program issues and gaps 

20 refers to any programmatic issued identified by our 

21 self-assessments, annual event review, and trending 

22 report, special studies, and enforcement action 

23 review. Next slide, please. 

24 The staff uses the criteria and 

25 information sources listed on this slide to assess 

26 and measure our performance, including a graded 
 28 

1 approach from high level, high consequence events to 

2 lower level precursor monitoring. This event review 

3 is conducted through our use of our nuclear materials 

4 event database, which is also referred to as NMED. 

5 We examine event information and trends for overall 

6 number of events, as well as in more narrow categories 

7 to identify any trends which may indicate 

8 programmatic changes or weaknesses. 

9 The NMED review also leads us to focusing 

10 on specific targeted segments of our program. These 

11 special studies are conducted to more closely examine 

12 the causes and potential correlation of events in 

13 generic or programmatic weaknesses. 

14 We also use the abnormal occurrences 

15 process, including the abnormal occurrence annual 

16 report, as well as a review of significant enforcement 

17 actions to identify events of high significance and 

18 identify any potential licensees with significant 

19 performance problems. 

20 Strategic performance measures, 

21 including the Agency's safety and security goals are 

22 monitored by the Materials Program Office and were 

23 addressed in the fiscal year 2015 performance and 

24 accountability report and were fully discussed as 

25 part of the Agency Action Review Meeting. Next 

26 slide, please. 
 29 

1 All safety and security goals and 

2 performance measures were met in fiscal year 2015. 

3 There were no fuel cycle facilities or materials 

4 licensees that met the AARM discussion criteria. The 

5 nuclear materials program met all strategic and 

6 performance safety and security metrics. No 

7 significant trending or programmatic issues were 

8 identified in our review of operational performance 

9 trends, licensee performance issues, or other 

10 assessments of the materials program. 

11 In the next two slides, I will discuss 

12 the results of the staff's NMED training review -- 

13 trending review, rather and a special study of lost, 

14 abandoned, and stolen source events involving 

15 category 1 and 2 sources that occurred in the last 

16 ten years. Next slide, please. 

17 During the fiscal year 2015 reporting 

18 period, there were 489 NRC and Agreement State 

19 licensee events reported NMED. To account for random 

20 fluctuations in event data from year to year the 

21 annual report reviews data for the last ten years, as 

22 depicted on this graph. 

23 For fiscal year 2015, there was no 

24 statistically significant trends in the overall data. 

25 There were, however, a few statistically significant 

26 trends identified for narrow portions of the data. 
 30 

1 These trends in the narrow data sets include a 

2 decrease in the overall number of NRC events, a 

3 decrease in NRC equipment events, and an increase in 

4 Agreement State and medical events. Contributing 

5 factors to these trends were the transfers of 

6 licensees from NRC to Agreement State jurisdiction 

7 during the ten-year time period, increased awareness 

8 of events and reporting requirements, as well as the 

9 introduction or prevalence of new medical device 

10 procedures. 

11 Regarding the number of equipment events, 

12 the NRC issued an information notice related to damage 

13 to industrial radiographic equipment due to falling 

14 equipment and improper mounting in April of 2014 in 

15 order to address a previously identified trend in 

16 radiography. We continue to assess this performance. 

17 With respect to the trend in Agreement 

18 State medical events, a large number of these were 

19 issues associated with yttrium-90 treatments for 

20 liver disease. NRC staff issued new guidance in 

21 February of 2016 that in part clarifies what 

22 constitutes a reportable event for these types of 

23 treatments. 

24 Despite the trends within the narrow 

25 portions of data, the total of events per year has 

26 been relatively stable and very small in comparison 
 31 

1 with the large number of radioactive materials uses 

2 each year. 

3 The peak in this graph from 2008 and 2009 

4 represents events from Walmart's one-time inventory 

5 of their tritium exit signs. Walmart identified a 

6 large number of lost signs. There 272 events 

7 reported in 2008 and 65 in 2009. 

8 Within the NMED events, some met the 

9 abnormal occurrence thresholds and are reported to 

10 Congress each year in NUREG-0090. There were 17 

11 abnormal occurrences identified for fiscal year 2015, 

12 15 of those were in Agreement State jurisdiction and 

13 two were NRC. All involved medical procedures, one 

14 of which was a radiation exposure to the embryo or 

15 fetus of a woman who was undergoing a treatment where 

16 the pregnancy test performed just prior to the 

17 treatment returned a false negative. 

18 The 17 abnormal occurrences for fiscal 

19 year 2015 is a number that is within the statistical 

20 variation of previous year's average of 14 since 

21 FY2006. The number of identified medical AOs is 

22 approximately 3/10,000th of a percent of the number 

23 of medical procedures performed annually. 

24 We do not believe there are presently any 

25 trends or significant safety concerns among medical 

26 licensees. We continue to monitor licensees' 
 32 

1 performance and provide prompt follow-up response 

2 when warranted. Next slide. 

3 For fiscal year 2015, the staff conducted 

4 a special study of lost, abandoned, and stolen 

5 materials events that occurred in the last ten years 

6 and found that there is not a statistically 

7 significant trend for category 1 and 2, lost, 

8 abandoned, or stolen source events over the ten-year 

9 period. The data shows a fairly steady average of 

10 three to four of these events per year. 

11 The graph on this slide displays category 

12 1 and 2 events. With regard to the category 1 events, 

13 there were two that occurred that involved the loss 

14 and recovery of a category 1 iradium-192 sources 

15 during shipment by common carrier. Not including 

16 irretrievable well logging sources, there were 32 

17 events that involved category 2 sealed sources. 

18 These included 11 events that resulted from shipping 

19 errors, where the sources or devices were temporarily 

20 lost in the common carrier system but were not 

21 actually -- never left the possession of the carriers. 

22 All of those sources were recovered. 

23 There were six events that involved the 

24 theft of a radiography device and the majority of 

25 those were either thefts of a device from a truck or 

26 theft of the truck itself. All but one of those 
 33 

1 devices were recovered. The only device that was not 

2 recovered was stolen in July of 2011 from the darkroom 

3 of a truck that was parked at a hotel. An extensive 

4 search was performed, which included a flyover survey 

5 by the Department of Energy but the device was not 

6 located. Due to the 73.8-day half-life of that 

7 radionuclide, that source would no longer be of high 

8 radiological significance. 

9 There were 12 events that resulted from 

10 errors made by radiography crews, where the device 

11 fell from a vehicle that was in transit because it 

12 was not properly secured or where the device was left 

13 at a jobsite or in one case at an airport. All of 

14 those devices were recovered, however, eight of those 

15 events occurred in the last two fiscal years, which 

16 indicates that the lessons learned process that was 

17 undertaken by the radiography industry and by 

18 regulators has not been completely effective. We are 

19 planning to perform additional outreach to 

20 radiography licensees to heighten their awareness of 

21 these issues. 

22 And then finally, there were three other 

23 events that occurred where weather contributed to the 

24 loss of the radiography device or, in one instance, 

25 where an irradiator was abandoned at a biotechnology 

26 facility during an eviction process. All of those 
 34 

1 devices were recovered. Next slide. 

2 In summary, all safety and security goals 

3 and performance measures were met in 2015. There 

4 were no fuel cycle facilities or materials licensees 

5 that met the AARM discussion criteria. The Nuclear 

6 Materials Program met all strategic and performance 

7 safety and security metrics and there were no 

8 significant trending or programmatic issues 

9 identified in our review of operational performance 

10 trends, licensee performance issues, or other 

11 assessments of the materials program. 

12 That concludes my remarks and I will now 

13 turn the presentation over to Scott Morris. 

14 MR. MORRIS: Thanks, Dan. 

15 Good morning, Mr. Chairman, 

16 Commissioners. Today I am pleased to have the 

17 opportunity to provide you with a high level overview 

18 of the status of the NRC's power reactor oversight 

19 process. Next slide, please. 

20 Specific topics I will discuss during 

21 today's briefing include the Industry Trends Program 

22 results for 2015 and our plans to sunset this program 

23 in 2016; the ROP Self-Assessment Program revisions 

24 made to improve its effectiveness; the self25 assessment results for 2015 and our future 

26 activities; and finally, recently completed ROP 
 35 

1 enhancements, as well as planned enhancement 

2 activities scheduled for completion in 2016. Next 

3 slide, please. 

4 The Industry Trends Program has been the 

5 element of the ROP designed to monitor industry-wide 

6 performance, instead of plant-specific performance. 

7 The goal of the program is to identify significant 

8 trends in the nuclear industry's overall safety 

9 performance using industry level indicators. 

10 The Industry Trends Program is comprised 

11 of several short- and long-term indicators, as well 

12 as the baseline risk index for initiating events 

13 metrics. 

14 For 2015, none of the short-term 

15 indicators exceeded their established thresholds. 

16 Similarly, none of the thresholds associated with the 

17 Baseline Risk Index for Initiating Events were 

18 exceeded. 

19 Lastly, there were no statistically 

20 significant long-term trends identified that would 

21 require generic agency action. The safety system 

22 failure indicator did yield a statistically 

23 significant adverse trend in 2015 but this outcome 

24 was the result of outliers in the data set and the 

25 staff determined that no follow-up actions were 

26 warranted. Next slide, please. 
 36 

1 As part of the agency's Project Aim re2 baselining initiative, the staff proposed to 

3 eliminate the Industry Trends Program. In making 

4 this recommendation to the Commission, the staff 

5 noted while this program, which has been in place in 

6 its current form since 2001 has helped to validate 

7 broad industry performance trends. No regulatory 

8 actions have directly resulted from Industry Trends 

9 Program insights. 

10 Simply put, the value derived from the 

11 program relative to its operational cost does not 

12 support its continued implementation. The staff 

13 believes that any adverse trends in industry-wide 

14 performance that would otherwise be detected by the 

15 Industry Trends Program would very likely be 

16 identified through other agency processes. Examples 

17 of other process include ongoing licensee performance 

18 assessment activities, ongoing ROP self-assessment, 

19 annual End of Cycle Assessment Meetings, the Agency 

20 Action Review Meeting and the Robust Operating 

21 Experience Program. 

22 As you know, the Commission approved the 

23 staff's proposal to eliminate the Industry Trends 

24 Program and the program is currently in the process 

25 of being abolished. Next slide, please. 

26 I would like to now turn to ROP self-
 37 

1 assessment related activities. With the Commission's 

2 approval, the staff did not perform an ROP self3 assessment for 2014 and, instead, focused its 

4 resources on addressing the numerous ROP improvement 

5 recommendations received from multiple independent 

6 sources in 2013 and 2014 and, as part of that, 

7 developing a more efficient and effective ROP self8 assessment process. 

9 Last fall, the staff finalized the 

10 pertinent Self-assessment Program governance 

11 documents to implement the new process and an 

12 information paper was provided to the Commission in 

13 December 2015 describing the revised approach and the 

14 staff's implementation plans for 2016 and beyond. 

15 The revised approach now consists of 

16 three elements. Element 1: Assessing staff adherence 

17 using, for example, objective performance metrics to 

18 measure the effectiveness of and staff adherence to 

19 the ROP. Element 2 assesses recent ROP changes to 

20 validate that these changes achieved their desired 

21 outcomes. And Element 3 involves performing a 

22 focused in-depth evaluations of specific ROP aspects 

23 and conducting Regional Office peer reviews. 

24 Some of the key benefits of the new self25 assessment process are that it adds accountability to 

26 increase assurance that the ROP is being reliably and 
 38 

1 predictably implemented across the entire power 

2 reactor fleet. It is also a continuous year-round 

3 activity versus a once per year focused effort. And 

4 finally, it enables more in-depth evaluations of key 

5 program aspects and involves a broader engagement of 

6 internal stakeholders. Next slide, please. 

7 Because 2015 was a transition year for 

8 the new ROP Self-Assessment Program, implementation 

9 was limited to Element 1 and portions of Element 2 of 

10 the new process. Specifically, the staff completed 

11 an analysis of performance metric data, evaluations 

12 of certain ROP processes, and reviews of recently 

13 completed ROP enhancements in related ongoing 

14 activities. The more detailed aspects of both 

15 Elements 2 and 3 required more time to be effectively 

16 implemented than was possible before the new self17 assessment process was finalized. 

18 For 2016 and beyond, the staff will 

19 complete all three elements of the revised program. 

20 So, specifically under Element 2 in 2016, we will 

21 conduct comprehensive evaluations of recent changes 

22 to the security baseline inspection procedures and 

23 modifications to the ROP that address lessons learned 

24 from the staff's implementation of Inspection Manual 

25 Chapter 0350 oversight at the Fort Calhoun Station 

26 and 95003 inspection at Brown's Ferry. 
 39 

1 Under Element 3, we will perform a 

2 comprehensive review of the agency's inspector 

3 training and qualifications program, as well as an 

4 ROP implementation peer evaluation of Region II. 

5 In summary, the 2016 ROP self-assessment 

6 will include all aspects of the revised Self7 Assessment Program and will be documented in our 

8 annual SECY paper in early 2017. Assessment results 

9 will be discussed with senior NRC management at the 

10 2017 Agency Action Review Meeting and with the 

11 Commission at next year's briefing. Next slide, 

12 please. 

13 The results of the 2015 limited ROP self14 assessment were documented and provided to the 

15 Commission in an April 2016 SECY paper. Three of the 

16 26 total Self-Assessment Program metrics were deemed 

17 to be not applicable for 2015 because their supporting 

18 data was not readily available. Of the 23 remaining 

19 metrics, 22 were evaluated as green, indicating that 

20 they had met their specific criteria or specified 

21 criteria, that is that they represented expected 

22 program performance and, therefore, did not warrant 

23 further staff evaluation. No metrics were evaluated 

24 as yellow, which would demonstrate a downward 

25 performance trend that warrants further evaluation 

26 and potential staff action to reverse the trend. 
 40 

1 Only the timeliness metric associated 

2 with implementing the significance determination 

3 process was assessed as red. 

4 In 2015, 88 percent of the opportunities 

5 to implement the SDP for greater than green inspection 

6 findings were completed within 90 days versus the 

7 acceptance criterion of 90 percent. As you know, the 

8 staff is currently engaged in a comprehensive SDP 

9 streamlining effort to improve SDP timeliness, while 

10 maintaining its effectiveness. 

11 In 2015, the staff also evaluated the 

12 effectiveness of each of the four major program areas 

13 of the ROP consistent with the revised self14 assessment process. These evaluations were included 

15 in the ROP self-assessment SECY paper and encompassed 

16 the performance indicator program, the inspection 

17 program, the SDP, and the assessment program. 

18 Specifically, the staff noted that the performance 

19 indicator program continued to offer insights into 

20 plant safety and security performance. NRC 

21 inspectors independently verified that licensees 

22 operated the plant safely and securely. The SDP 

23 continued to be a generally effective tool for 

24 determining the safety and security significance of 

25 inspection findings. And the assessment program 

26 continued to ensure that the NRC took appropriate and 
 41 

1 predictable actions to address licensee performance 

2 issues commensurate with their safety significance. 

3 Lastly, with respect to the 2015 self4 assessment, the staff documented numerous but less 

5 obvious improvements to the ROP governance documents 

6 and noted substantial progress addressing the various 

7 program improvement recommendations. Again, further 

8 details are provided in the enclosures to the ROP 

9 Self-Assessment SECY paper. Next slide, please. 

10 As part of the Agency Action Review 

11 Meeting, at which the ROP Self-Assessment is 

12 discussed, the staff briefs senior NRC management on 

13 any action matrix deviations approved during the 

14 previous year, along with a description of the changes 

15 needed or made to the ROP to address any resultant 

16 lessons learned from the need to pursue the deviation. 

17 Executive Director for Operations 

18 approved one new action matrix deviation in 2015, 

19 which was associated with oversight of the Monticello 

20 Nuclear Generating Plant in Region III. 

21 Specifically, Region III management requested that 

22 Monticello be placed in the regulatory response 

23 column of the action matrix that is column 2, rather 

24 than the multiple/repetitive degraded cornerstone 

25 column, that is column 4, which would have been 

26 prescribed by the ROP assessment program. After 
 42 

1 careful consideration, the EDO approved the deviation 

2 because of the successful completion of both the 95002 

3 supplemental inspection and a biannual problem 

4 identification resolution inspection at the site, as 

5 well as a lack of evidence of any broad or systemic 

6 performance issues across plant organizational areas. 

7 In sum, the staff concluded that 

8 placement of Monticello in column 4 of the action 

9 matrix and the regulatory actions associated with 

10 column 4 were not warranted. 

11 The Monticello deviation remains open, 

12 pending the NRC staff's review of the license's safety 

13 culture assessment, which is currently scheduled for 

14 next month. 

15 Consistent with the ROP Self-Assessment 

16 process, the staff also evaluated the circumstances 

17 leading to the deviation and determined that no 

18 programmatic changes to the ROP were needed. It is 

19 worth noting that since the inception of the ROP in 

20 2000, there have only been 23 approved action matrix 

21 deviations. I would also like to point out that 

22 these deviations from the action matrix had resulted 

23 in both increases and decreases in NRC oversight 

24 relative to what would have otherwise been 

25 prescribed. In fact, only six of the 23 deviations 

26 were granted to decrease regulatory oversight 
 43 

1 relative to what the ROP would have dictated. Next 

2 slide, please. 

3 So to summarize, the staff self4 assessment results to date continue to indicate that 

5 the ROP provides effective regulatory oversight of 

6 the nation's operating power reactors by meeting 

7 established program goals and achieving its intended 

8 program outcomes. Specifically, the ROP ensured 

9 openness and effectiveness in supporting the agency's 

10 mission and its strategic goals of safety and security 

11 and it was successful in being objective, risk12 informed, understandable and predictable. The 

13 limited 2015 self-assessment using the new process 

14 confirmed that the staff had implemented the ROP 

15 predictably and reliably during 2015. Future self16 assessment activities will include all of the aspects 

17 of the revised self-assessment process including a 

18 focus on the efficacy of recent changes to the 

19 program, performing in-depth reviews of specific 

20 areas of interest and continuing to ensure staff 

21 adherence to program governance. Next slide, please. 

22 I will now provide a brief update on the 

23 numerous ROP activities in which the staff has been 

24 engaged over the past year. As a reminder, most of 

25 these activities were spawned by evaluations and/or 

26 recommendations derived from a variety of sources, 
 44 

1 including but certainly not limited to the 

2 Commission-directed independent assessment, the 

3 staff's own significance determination process 

4 Business Process Improvement Initiative, lessons 

5 learned from the Fort Calhoun 0350 oversight, and the 

6 Brown's Ferry 95003 supplemental inspection, and the 

7 San Onofre Steam Generator tube degradation event. 

8 Recommendations and feedback were also 

9 addressed based on real-time continuous feedback that 

10 we received from inspectors in the field throughout 

11 the year. 

12 Some of the more significant ROP 

13 enhancements that we completed in 2015 include 

14 revising and improving numerous baseline inspection 

15 procedures across all of the cornerstones, modifying 

16 the cross-cutting issue process, changing the ROP 

17 action matrix criteria for what performance 

18 assessments inputs constituted degraded cornerstone, 

19 and multiple repetitive degraded cornerstone, also 

20 improved several internal and external ROP-related 

21 communication tools, and redesigned the ROP self22 assessment processes I have just described. Next 

23 slide, please. 

24 The staff continues its work on several 

25 other key program enhancements, many of which are 

26 scheduled to be completed in 2016. These include 
 45 

1 revising the triennial Component Design Bases 

2 Inspection to make it less resource intensive, while 

3 maintaining its effectiveness. 

4 After several public meetings with 

5 industry, the staff began conducting pilot CDBIs at 

6 eight operating reactors sites. The pilot 

7 inspections will be completed by next month. The 

8 staff has scheduled another meeting with industry 

9 representatives in July at which the lessons learned 

10 from the pilot inspections will be discussed and soon 

11 after incorporated as appropriate into revisions of 

12 the CDBI procedures. Another enhancement to be 

13 completed this year involves clarifying the 

14 inspection findings screening process and the 

15 associated program governance documents to improve 

16 agency-wide consistency in the characterization of 

17 inspection findings. We are also piloting various 

18 SDP streamlining project proposals in an effort to 

19 improve the timeliness and predictability of SDP 

20 outcomes. The staff has solicited input from 

21 industry representatives at several public meetings 

22 and even conducted a dedicated session at the March 

23 2016 regulatory information conference on this 

24 project. 

25 We are clarifying ROP and enforcement 

26 program expectations relative to when and how to 
 46 

1 process licensee performance and/or compliance issues 

2 in the ROP, in traditional enforcement, or both. We 

3 are streamlining the inspection report development 

4 process, as well as the inspection report content to 

5 better serve internal and external stakeholders while 

6 maximizing regulatory clarity, openness, and 

7 efficiency. And finally, we are continuing to 

8 develop the ROP to incorporate new reactor 

9 technologies. Given current construction schedules, 

10 new performance indicators in a modified baseline 

11 inspection program will need to be in place in the 

12 next two years to ensure a smooth transition from 

13 construction to operation for the AP1000 reactors at 

14 Summer and Vogtle. 

15 That concludes my remarks and I look 

16 forward to your questions. I will now turn the 

17 presentation over to Victor McCree for closing 

18 remarks. Thank you. 

19 MR. MCCREE: Thanks, Scott. 

20 Chairman, Commissioners, I recognize we 

21 have covered a lot of ground in the last 54 minutes. 

22 So, I appreciate your attention. 

23 In summary, we have met the objectives of 

24 the Agency Action Review Meeting process and our 

25 discussions confirm that the actions that we have 

26 taken and the actions that we are currently 
 47 

1 implementing are appropriate and consistent with our 

2 oversight processes. 

3 Before taking your questions, I would be 

4 remiss in not recognizing that this is Commissioner 

5 Ostendorff's last Agency Action Review Meeting as a 

6 commissioner. We appreciate your insightful 

7 constructive and challenging support of our efforts 

8 to ensure that our oversight processes and the 

9 decisions that we make to implement those processes 

10 are appropriate and implemented in a manner that is 

11 consistent with our principles of good regulation. 

12 And with that, we are ready for your 

13 questions. 

14 CHAIRMAN BURNS: Thank you and thanks for 

15 the presentations. As you said we have covered a lot 

16 of ground here, both in terms on the overall program 

17 as well as the two plants that deserve particular 

18 attention. 

19 This morning we will start questioning 

20 with Commissioner Baran. 

21 COMMISSIONER BARAN: Thanks, Mr. 

22 Chairman. Thank you all for your presentations and 

23 all of your work. 

24 Dan, I want to jump right in with some 

25 questions on Pilgrim's performance. The background 

26 materials for the 2015 annual assessment letter 
 48 

1 indicated that progress at Pilgrim was very slow at 

2 that time. Inspectors weren't seeing operations 

3 management embracing the need for change and they 

4 seemed more focused on regulatory categorization than 

5 on addressing actual deficiencies. Is this still the 

6 case today or is the NRC staff seeing significant 

7 improvement at the site? 

8 MR. DORMAN: We are seeing improvement. 

9 I think from the time that we issued the assessment 

10 letter in September of 2015, you will recall that 

11 during the fall Entergy was doing their own due 

12 diligence on the future of the facility and decided 

13 later in the fall that they would close the facility 

14 in 2019 but that first they expect to recover the 

15 plant to expected levels of performance. 

16 Since that time late last year they 

17 started bringing in outside resources. They have 

18 established mentors for processes and programs within 

19 the site. Initially, we saw significant gaps between 

20 the expectations being communicated by the mentors 

21 and the level of performance from the staff and we 

22 are starting to see those gaps closing. 

23 So, I think significant leadership 

24 engagement and external resources are helping to 

25 start seeing change at the site. What we will be 

26 looking for in the 95003 later this year, hopefully, 
 49 

1 is that that is becoming engrained in the culture of 

2 the organization and becoming a sustained turnaround. 

3 COMMISSIONER BARAN: What do you see as 

4 Pilgrim's key challenges with respect to its 

5 corrective action program? 

6 MR. DORMAN: With respect to the 

7 corrective action program during the most recent 

8 assessment letter, we identified a cross-cutting 

9 theme in the area of problem identification and 

10 resolution. And you may recall in our process, that 

11 means that we had at least a dozen findings during 

12 the assessment period, which indicated weaknesses in 

13 some aspect of that program and they touch on all 

14 aspects of the program, recognizing that they have an 

15 issue and getting it into the program, doing an 

16 adequate evaluation of the causes and then such that 

17 you can develop and implement effective corrective 

18 actions so that the issues that arose during the 

19 assessment period really touch in all three areas of 

20 the program. And I think, broadly, it is a question 

21 of standards and a questioning attitude throughout 

22 the organization. And I think that is where, in 

23 particular with respect to the corrective action 

24 program, where we are seeing some impact from the CAP 

25 mentor to help the staff start realizing that there 

26 is a higher expectation than the level that they have 
 50 

1 been providing. 

2 COMMISSIONER BARAN: So, it sounds like 

3 you are seeing some progress, some change, but there 

4 is work to do. There is a ways to go still. 

5 MR. DORMAN: Yes. 

6 COMMISSIONER BARAN: Okay. Marc, for 

7 ANO, you walked through some of the key performance 

8 issues and causes in areas where you have seen 

9 improvements. As you sit here today, what are your 

10 biggest outstanding concerns for the units at ANO? 

11 MR. DAPAS: Well, I think the most 

12 important thing for the licensee to focus on is 

13 effective implementation of their comprehensive 

14 recovery plan and they need to ensure that the 

15 appropriate resources are allocated for effective 

16 implementation. 

17 The licensee has done an organizational 

18 capacity study. They understand where the gaps are 

19 to principally operations, maintenance, and 

20 engineering. I think the key is ensuring that they 

21 have staff sufficient to address those gaps. 

22 When you look at what were the causes for 

23 some of the performance declines you had staff that 

24 prioritized various actions because they did not have 

25 the staff necessary to prevent increases in work 

26 backlogs, in corrective action backlogs. 
 51 

1 I also think that there needs to be a 

2 focus on culture. I think at ANO specifically, there 

3 was in the past a bias to mitigate vulnerabilities, 

4 rather than eliminate. The staff would lock into 

5 what appeared to be the best mitigative strategies 

6 versus focusing on addressing equipment issues. And 

7 that translates to equipment reliability challenges, 

8 which then subsequently can challenge the operators 

9 when the equipment is not available. In response to 

10 any plant upset condition, you want that equipment to 

11 be reliable. So, you want to ensure there aren't 

12 latent conditions there. And that bias toward 

13 mitigative rather than eliminating the problem I 

14 think is something that Entergy understands and is 

15 addressing. 

16 So, those are some of the challenges that 

17 I see going forward with respect to Entergy. 

18 And then I guess the last thing I will 

19 mention is ensuring that they have adequate 

20 procedures, programs, processes in place and 

21 expectations that are clear regarding oversight for 

22 supplemental workforce, particularly during outages. 

23 COMMISSIONER BARAN: Okay, thank you. 

24 You both noted in your presentations that both sites 

25 had issues with their corrective actions programs. 

26 Are there other problem areas that you are seeing 
 52 

1 common to both of these sites? Are there issues that 

2 you consider to be fleet-wide for Entergy? 

3 MR. DAPAS: I will offer a perspective 

4 there. As I mentioned in my remarks, I think 

5 benchmarking has historically been limited at the 

6 Entergy sites. And Entergy needs to look at through 

7 benchmarking or they are providing what I would call 

8 the right frame of reference regarding what good looks 

9 like. And I think you achieve that, in part, through 

10 benchmarking and that also impacts the discretionary 

11 effort that you see from the workforce. 

12 And it is important that there is a clear 

13 understanding in the role of what they call the 

14 corporate functional area managers that are providing 

15 corporate oversights and that transcends across all 

16 the Entergy sites because they use those CFAMs to 

17 communicate expectations and engage management at the 

18 site. And it is part of their assessment process to 

19 look at how the various sites are performing. 

20 And the other thing I would just offer I 

21 think it is important that there is a consistent set 

22 of performance indicators across the Entergy fleet. 

23 I think there were challenges at ANO with the 

24 performance indicators not providing the information 

25 that the licensee needed to understand whether there 

26 were issues or trends at ANO and I think that 
 53 

1 potentially exists with the other sites as well. 

2 MR. DORMAN: Yes, I would just add to 

3 that I think in discussing fleet-wide issues what I 

4 see as the challenge is it is not that they have 

5 fleet-wide standards and processes that are weak, it 

6 is that they have vulnerabilities at their stations 

7 because they don't have a consistent fleet-wide 

8 standard. 

9 MR. DAPAS: I would add one additional 

10 thing. The corporate procedures provide for 

11 flexibilities. My understanding is it came as a bit 

12 of a surprise when Entergy really looked at it. The 

13 degree to which those flexibilities were being 

14 exercised so that you actually had significant 

15 differences in how elements of the various programs 

16 and processes were being implemented at the 

17 respective sites. 

18 And I can speak just for the Entergy South 

19 sites, is where we saw that. When you look at River 

20 Bend versus ANO, et cetera. 

21 COMMISSIONER BARAN: Thank you. 

22 Scott, I want to ask a couple of brief 

23 questions about the significance determination 

24 process. In 2015, as you mentioned, the staff 

25 narrowly missed the timeliness metric. Two of the 

26 17 total determinations exceed the 90-day goal. One 
 54 

1 of those is off by a matter of days, as I understand 

2 it. 

3 I am open to exploring ways to streamline 

4 the significance determination process if it makes 

5 sense but I want to make sure we are not overreacting. 

6 Can you talk a little bit about what do we see, what 

7 does the staff see as the problem we are trying to 

8 solve with these efforts? Is the staff's view that 

9 the significance determination process is generally 

10 too slow? Is the concern that there are the 

11 occasional outliers that are taking too long? What 

12 degree of consensus is there among the staff about 

13 the problem we are trying to solve? 

14 We have got a minute or two to talk about 

15 that. 

16 MR. MORRIS: Sure thing. Thanks for the 

17 question. So, there is a lot to that question. I 

18 will try to keep it brief. 

19 First and foremost, the SDP streamlining 

20 is kind of a misnomer because it is really the 

21 beginning and end of the entire issue screening 

22 process to identifying whether or not there is in 

23 fact a performance deficiency to the point where we 

24 document something in an inspection report with our 

25 preliminary assessment, followed by the more formal 

26 and rigorous application of the significance 
 55 

1 determination process, potentially a regulatory 

2 conference, and then a final issuance. 

3 So, really when we are -- the team that 

4 we have assembled looking at this is kind of looking 

5 at the entire process, not just the formal SDP piece 

6 of it, which is kind of at the back end. 

7 Given that, what is the problem we are 

8 trying to solve? We believe, based on -- and there 

9 has been, as you know, a fairly robust internal 

10 discussion about where the real challenges are and 

11 where is the low-hanging fruit -- we believe a lot of 

12 the low-hanging fruit is really on the front end, 

13 really associated with managing the issue once 

14 identified at a particular site actively and 

15 effectively in the organization at the branch chief, 

16 even the division level, to ensure that appropriate 

17 resources are being applied to the issue; that 

18 effective communications are occurring within the NRC 

19 staff, as well as with the licensee, to ensure that 

20 there is a clear understanding of what the proximate 

21 cause is; whether or not there, in fact, is a 

22 performance deficiency up to and including an 

23 understanding of how well, if it happens to be one of 

24 the SDP that is quantitative in nature using a 

25 probabilistic risk assessment tool, how well that 

26 particular tool fits that particular situation; what 
 56 

1 uncertainties do we have to address. 

2 Basically, to understand how viable is 

3 our tool early. And if there are going to be 

4 challenges recognizing that early so that we can apply 

5 the appropriate amount of NRC staff resource to go 

6 after to come to a resolution at issue in a more 

7 timely and effective manner. Those are really where 

8 we are focusing our efforts right now. There are a 

9 lot of other aspects but due to a lack of time, I 

10 won't go into all of them. Perhaps another 

11 Commissioner will have a question about it. 

12 COMMISSIONER BARAN: Okay, thanks, I 

13 appreciate that succinct response there and I am 

14 looking forward to seeing what the staff comes up 

15 with. Thank you. 

16 CHAIRMAN BURNS: Thanks. And again, 

17 thanks for the presentations. I am going to try to 

18 touch on a number of areas here, both in terms of our 

19 generic programs but also performance of the two 

20 plants that are before us today. 

21 I guess this is probably a question for 

22 both Marc and Dan but you touch on and I think in 

23 answer to Commissioner Baran's question and as well 

24 as in your presentations. Some of the issues in 

25 terms of what we look at in particular plant 

26 performance but the concern, stepping back, sort of 
 57 

1 fleet performance and I know a number of the 

2 administrators and I think Director of NRR met with 

3 the Entergy executives. What is a message or what 

4 did you see or gain from that discussion in terms of 

5 recognition of potential issues that they need to 

6 address in the fleet or where you see areas of focus 

7 that Entergy really needs to be on, given that yes, 

8 we have particular plant performance issues but we 

9 are hearing some of the same things in terms of these 

10 two plants, particularly? 

11 MR. DAPAS: From my perspective, I think 

12 one of the things that we heard at that status of the 

13 fleet meeting was the recognition by Entergy that 

14 they are an outlier in terms of performance relative 

15 to the industry. I think the performance indicators 

16 they had been using in the self-assessments that would 

17 look at one station and how they implement programs 

18 and processes relative to another station didn't 

19 provide for that assessment relative to industry 

20 performance. And that relates to the benchmarking 

21 that I mentioned. I also think there have been 

22 challenges with corrective action program 

23 implementation and that was an area of discussion or 

24 a topic of discussion. And one of the things we 

25 talked about was when you do causal assessments, are 

26 you looking at the organizational and programmatic 
 58 

1 issues that contribute to a particular issue or 

2 concern and not just focusing on the technical issue. 

3 So, I think that is an area that Entergy recognizes 

4 they need to address across the fleet. 

5 And then I think most importantly is 

6 equipment reliability challenges. And there as a 

7 discussion we had about the increased number of scrams 

8 at the various Entergy sites or trips relative to 

9 industry performance. And Entergy, as I understand 

10 it has embarked on an aggressive effort to understand 

11 where they have single point vulnerabilities and 

12 address those but equipment reliability is something 

13 that I think Entergy needs to look at very hard as a 

14 fleet. 

15 CHAIRMAN BURNS: Okay. Dan? 

16 MR. DORMAN: I agree with everything Marc 

17 said and particularly I think it was clear in that 

18 meeting that the senior leadership of Entergy has 

19 bought into that it is not just Pilgrim and ANO. They 

20 have fleet issues that they need to address. 

21 And I think equipment reliability is an 

22 issue. I spoke to Commissioner Baran's comment about 

23 the lack of a consistently applied standard, a fleet 

24 expectation. And I think one of the things that we 

25 have seen at Pilgrim I think is an issue that we were 

26 talking about 20 years ago and they didn't move past 
 59 

1 it was a reliance on skill of the craft versus a rigor 

2 of procedures. And so in the scram in January of 

3 2015, they experienced a loss of instrument air as a 

4 result of the failure to start of a diesel driven 

5 compressor. And there were challenges for the 

6 operators in that the instrument air -- the loss of 

7 instrument air procedure was not complete in 

8 addressing what functions they would lose and there 

9 was a reliance there on the skill of the craft that 

10 was not up to where it needed to be with that respect 

11 to that particular issue. 

12 So, one of our follow-up actions in our 

13 problem identification samples back in the fall was 

14 getting our operator license examiners in the 

15 simulator with their shift and observing their 

16 response to similar conditions. 

17 So, I think there is a rigor in their 

18 processes that because of a lack of benchmarking I 

19 think they have not kept up with industry standards 

20 that have changed on them. 

21 MR. DAPAS: One last thing I will add we 

22 did have some discussion regarding the degree of 

23 engineering rigor that is applied within the 

24 engineering organizations when you are looking at 

25 50.59 evaluations operability determinations. And I 

26 think there are opportunities to increase the 
 60 

1 organizational capacity in terms of the quality and 

2 capabilities of the engineering function. 

3 CHAIRMAN BURNS: Okay and one of the 

4 things I know you and I were at ANO I guess in April 

5 together and had an opportunity to visit the site. 

6 One of the points of discussion at ANO 

7 and I think you touched on it as well, Marc, is this. 

8 A relationship in terms of the safety culture at the 

9 site related in part to staffing considerations. And 

10 in fact I will use the term, these are my words, in 

11 fact starving the staffing over a period of time so 

12 that it almost seemed like I said, sort of a loss of 

13 experienced folks, greater reliance on contractors 

14 resulted in a certain culture, if you will, at the 

15 site. 

16 Can you maybe fill in the gap and sort of 

17 talk about that a little bit and how we saw that 

18 manifested and where you think they are going with 

19 that? Because it is not just a matter of going out 

20 and picking up experienced staff on the street, you 

21 know, development. That is a challenge in this 

22 industry. It is a challenge for us, as an Agency. 

23 So, if you would talk to that. 

24 MR. DAPAS: Thanks. I think one of the 

25 challenges is, as I discussed, was the various 

26 resource reduction initiatives 2007, 2013. And my 
 61 

1 understanding is that at least at ANO, and you can 

2 certainly engage them specifically when you talk to 

3 Entergy management is the view at the site was you 

4 are expected to make do with what is provided. Don't 

5 challenge whether there are inadequate resources. 

6 These are initiatives that are being implemented 

7 across the fleet and so leadership is expected to 

8 determine how to get the work done with the resources 

9 that are provided. 

10 And as I understand it, corporate would 

11 have provided additional resources but ANO didn't 

12 raise the flag say there are more folks that we need 

13 to implement the programs and processes in a 

14 comprehensive manner. And so there were decisions 

15 that were being made at lower levels of the 

16 organization regarding prioritization of work that 

17 management was not aware. They thought things were 

18 getting done like apparent cause evaluations et 

19 cetera in a quality manner and they weren't because 

20 lower levels of the organization had to make resource 

21 prioritization decisions. So, I think that was a 

22 particular challenge. 

23 And then when it comes to contractor 

24 oversight, I really just think that Entergy needs to 

25 look at the infrastructure they have in place. For 

26 example other licensees do this -- they have 
 62 

1 contractors provide supervisory oversight of other 

2 contractors. And you can do that as long as you have 

3 a procedure and have a consistent set of standards 

4 there and there is a qualification process that you 

5 go through and implementing that in a rigorous manner 

6 will provide for that effective oversight, if you are 

7 going to rely on contractor supervisor oversight 

8 versus individual licensee employees. Both will 

9 work. It is all a matter of how you implement those 

10 two different approaches. 

11 CHAIRMAN BURNS: Okay, thanks. 

12 And Dan, I want to go specifically on 

13 Pilgrim. One of the questions we sometimes get with 

14 respect to Pilgrim, given the fact that is announced 

15 that it will be shutting down in 2019, is what’s the 

16 real commitment here. What is the real commitment 

17 to address these issues? How is it NRC, in terms of 

18 your oversight program, you are really focused on the 

19 right things in ensuring that the licensee implements 

20 a safe operation, a safe program? 

21 How would you respond to that in terms of 

22 what you see in terms of our inspection program 

23 addressing monitoring this issue regarding -- in 

24 effect, what are the incentives to core improvement 

25 here, given this is a plant that is going to shut 

26 down in three years? 
 63 

1 MR. DORMAN: I think first is the 

2 investment that we see on the ground. The licensee 

3 has brought in substantial external resources. I 

4 mentioned the mentors that they have put in place to 

5 drive process improvement at the site. So, they 

6 clearly are at the leadership level bought into it. 

7 The fact that we are seeing some movement 

8 on the staff performance toward the mentor standards, 

9 I think is an indication that the staff is buying 

10 into it to a degree. 

11 I think they received a number of staff 

12 from Vermont Yankee when that station closed at the 

13 end of 2014. I think a number of those people have 

14 brought a mentality of finish strong that are a seed 

15 corn, if you will, in the culture at Pilgrim Station. 

16 So, I think there are certainly 

17 indications that leadership wants to bring it to a 

18 better place and that that buy-in is taking some hold 

19 in the staff. 

20 I think from an oversight perspective, we 

21 have the experience with Vermont Yankee of about a 

22 year and a half of operation with an announced closure 

23 to adjust our oversight to focus on ensuring that 

24 operations and maintenance focus remained on the 

25 appropriate priorities. And they did finish strong 

26 at Vermont Yankee, addressing a number of issues 
 64 

1 during that last year and a half of operation. We 

2 have -- implemented a similar oversight process for 

3 FitzPatrick and Oyster Creek, which also have 

4 announced closures. 

5 With Pilgrim, we are more focused on the 

6 column 4 response and so we have not gotten into a 

7 pre-closure oversight activities but the column 4 

8 response will address those human performance issues, 

9 those safety culture issues, the equipment 

10 reliability issues that we would focus on as they 

11 approach the announced closure. 

12 CHAIRMAN BURNS: Okay, thanks very much. 

13 Commissioner Svinicki. 

14 COMMISSIONER SVINICKI: Good morning and 

15 thank you all for your presentations. 

16 To Mr. Dapas and Mr. Dorman, I want to 

17 thank you for your presentations which were thorough 

18 and clear. So, the good news is, I probably won't 

19 have a lot of questions for you. My colleagues have 

20 asked a number of questions. 

21 You're both very capable and that's one 

22 of the reasons that your presentations were well done. 

23 But, it's also an outgrowth of the teams you lead of 

24 very capable individuals. 

25 And, I think it also has its origins in 

26 the fact that the reactor oversight process is 
 65 

1 systematic, disciplined, understood and it allows you 

2 to discuss outcomes today that have a certain level 

3 of transparency that maybe previous reactor oversight 

4 processes did not have. 

5 And, that's really one of the strengths 

6 of the ROP. I tend to make this observation at the 

7 briefing on the AARM results that the system we have 

8 now, which we look at consistently, as we heard 

9 presentations on business improvement initiatives and 

10 other enhancements to the ROP. 

11 Nothing is perfect at its origin, so we 

12 continue to look at it and to feed back in our 

13 experience with it which I think, as a learning 

14 organization, is very appropriate. 

15 But, I think we also need to proceed with 

16 some caution and discernment in terms of where the 

17 process is strong, we need to be very vigilant and in 

18 guarding those strengths of the program. 

19 I will briefly mention, since Mr. Collins 

20 has not had any questions, that the -- we also cover 

21 the materials side of our program at this meeting. 

22 And, the staff reached its conclusion this year that 

23 all strategic outcomes, safety performance measures 

24 and security and performance measures for fiscal year 

25 '15 were met and, therefore, concluded from the 

26 assessment of overall performance data. There were 
 66 

1 no discernable performance trends or generic 

2 concerns. 

3 I think I would offer, therefore, the 

4 observation that I encourage the staff in the 

5 materials program to remember that result in light of 

6 areas of regulatory action we're exploring now in 

7 ocular, dermal and other external hazards, again, in 

8 the materials area, NRC has generally acknowledged 

9 it's very important to have a graded application of 

10 things commensurate with the safety hazard and the 

11 risk significance. 

12 So, we are reporting this year, as a 

13 result of the Agency's review, that we didn't have 

14 any discernable trends or generic concerns and so we 

15 need to always be feeding that result into our 

16 consideration of new regulatory issues. 

17 Construction oversight is one of the 

18 companion papers that comes along with the package of 

19 materials for this Agency Action Review Meeting. It 

20 received a glancing blow here today, but there is, of 

21 course, the companion paper which discusses the 

22 staff's assessment in greater detail. 

23 I'd like to share an observation and 

24 encouragement on the CROP, as we call it, construction 

25 reactor oversight process. 

26 Interesting history there is that the 
 67 

1 program in the form it exists today had its origins 

2 back in a NUREG in 1996. 

3 If you look at that document of the 

4 development of what is now our construction reactor 

5 oversight process, at that time, there was a very 

6 detailed job task analysis. 

7 There were a number of mechanical 

8 structures for the program that were considered. Not 

9 all of those were adopted. 

10 But, interesting and of note to me, is 

11 that, at the time it was assessed that the entire 

12 inspection program under what became the CROP per 

13 site would be approximately 17,000 hours of 

14 construction inspection oversight. 

15 For Vogtle and Summer by the time the 

16 licenses were issued, that had risen to about 33,000. 

17 And, with our experience at the two sites to date, 

18 it's projected to be about 35,000 of construction 

19 inspection hours. 

20 So, interestingly, in 1996, to carry out 

21 the inspection program of 17,000 hours we assessed 

22 that we needed 6 to 12 resident construction 

23 inspectors at the sites. 

24 Right now, our assessment is that we need 

25 five. And, with the surged capacity out of the 

26 construction inspection program in Atlanta in our 
 68 

1 Region II office, that we will take care of this. 

2 Interesting to note, I visit the sites 

3 fairly routinely and the statistic was pointed out to 

4 me that, with six years of on-site presence, I'll use 

5 Vogtle as the example, though I think Summer is about 

6 the same, six years that the CROP has been present on 

7 the sites and in action, we're about 20 percent 

8 complete on that 35,000 hour inspection program. 

9 In approximately the next two years, we 

10 will have to complete 80 percent of the program with 

11 five people. 

12 So, what I'm seeking from the NRC 

13 leadership that I've met with on this topic is simply 

14 a commitment that we will have a very consistent 

15 attention on the needed inspection resources at 

16 Vogtle and Summer. 

17 And, I'm acquainted with the history and 

18 it made a lot of sense to me, that when I arrived and 

19 we had 28 COL applications and we thought we might 

20 have 8 to 10 construction sites in the southeast 

21 United States at any given time, the notion that you 

22 would deploy out of Atlanta, I think was very sound. 

23 We have two sites, though, and they're 

24 very close together. So, I'm simply seeking from the 

25 NRC managers a very consistent attention on this over 

26 the next 12 to 24 months. 
 69 

1 The deployment from Atlanta, I am told, 

2 becomes logistically complex because it is 

3 construction and you have a schedule, but it's more 

4 likely than not that things will not occur as at the 

5 time frame where they are listed on the schedule. 

6 So, we're looking for flights into 

7 Augusta. We're looking at shifting hotel rooms. 

8 As a practical matter, the inspectors 

9 tell me, it's a little more complicated than we 

10 thought. 

11 So, I think we need to manage that, both 

12 sites have also added a back shift which means that 

13 I've got, you know, five people, maybe not all of 

14 them are fully qualified inspectors that are trying 

15 to cover multiple shifts including the back shift. 

16 These are our boots on the ground. We 

17 call them that all the time. So, I think that I'm 

18 asking for special attention to meeting their needs 

19 and not over stressing them. 

20 In the next two years, they might also 

21 want to take an occasional family vacation or do 

22 something like that. And, I think we don't want to 

23 burn people out. 

24 So, we didn't talk much about CROP, but 

25 I think, as I've indicated to you today, it's much on 

26 my mind. And, again, I'm just asking, as I'm 
 70 

1 confident we will, to have a lot of care and attention 

2 to that. 

3 I'll close by wishing Mr. Morris well 

4 wishes. He will soon be taking on a new 

5 responsibility that the Agency has asked him to do. 

6 And so, this may be the end of our 

7 dialogue about changes to the significance 

8 determination process. You have not been able to 

9 convince me, not that you haven't given it a spirited 

10 try. 

11 I attended the RIC session that you made 

12 reference to in your presentation. And, although Mr. 

13 Lochbaum likely part company respectfully on a number 

14 of topics, I found his presentation very compelling. 

15 He looked at the timeliness statistics in 

16 a hard data driven kind of look. 

17 And, I wasn't surprised to read the 

18 staff's assessment that we were only, by a couple of 

19 determinations, made us miss the metric. One was by 

20 a few days as Commissioner Baran noted. 

21 And, it is my view that for processes of 

22 this complexity, it is not reasonable to think you're 

23 not going to have one or two particularly complex 

24 circumstances in a given year. 

25 I liked Commissioner Baran's term about, 

26 you know, we have to look at this, but we shouldn't 
 71 

1 over react. I know NRC hates missing metrics because 

2 we're regulators and so we are hard judges on 

3 ourselves. But, I think we're always going to have 

4 some outliers. 

5 Those are outliers for a reason. They 

6 pose some kind of complexity and I think short cycling 

7 the process is where we will disappoint ourselves. 

8 The other thing I'm monitoring closely is 

9 Appendix M, or as we like to call it, Appendix Mike, 

10 here. 

11 It is, for those not acquainted, I want 

12 to get the title exactly right. We've recently 

13 issued an update recently in the last couple of years 

14 to the Technical Basis for Inspection Manual Chapter 

15 0609, Appendix M, entitled Technical Basis for the 

16 Significance Determination Process Using Qualitative 

17 Criteria. 

18 Now, this is a dialogue that's been going 

19 on for a while, quantitative versus qualitative. 

20 And, although I acknowledge that there's maybe been 

21 a little bit of hyperventilating, we're always going 

22 to have a mix of both quantitative and qualitative 

23 factors. 

24 I will be suggesting and encouraging the 

25 staff to be looking at the invocation or use of 

26 Appendix M. Have we been looking at trends there? 
 72 

1 Are we becoming more comfortable in short cycling the 

2 hard work of quantitative, which I think that Dan and 

3 Mark would agree that one of the things that gives 

4 the ROP all its rigor is the fact that it has a lot 

5 of analysis and, therefore, that's a lot of hard work 

6 for us. 

7 I think it can be attractive over time to 

8 say, well, I kind of know where the outcome should be 

9 and if I could just kind of short circuit it with 

10 qualitative aspects, I might be able to get where I 

11 need to go. 

12 So, again, I can't direct, but I would 

13 encourage the staff to -- I think it may be getting 

14 to be the appropriate time to look at Appendix Mike 

15 utilization and whether or not that's having an 

16 enhancing or detrimental effect to the overall rigor 

17 and discipline of the ROP. 

18 I will just tell you, which Mr. Morris 

19 knows, but I will make clear, that as long as I am 

20 privileged to serve on this Commission, I will be 

21 very possessive and do not miscalculate the 

22 Commission's level of ownership over the ROP. We're 

23 very, very invested in this process. 

24 I will oppose anything that I assess to 

25 be making the ROP more like the systematic assessment 

26 of licensee performance which, if you don't know, 
 73 

1 preceded it, and, despite it's name, was, in my view, 

2 not terribly systematic and not, at the end of the 

3 day, a very accurate assessment of performance of 

4 licensees. 

5 So, I stand in clear opposition to moving 

6 in that direction and I've run over, so sorry if 

7 anyone wanted -- Victor, you can pull rank here and 

8 give some reaction. Just saying that all sounds good 

9 to me is fine. 

10 MR. MCCREE: You covered a lot. It all 

11 sounds good to me, Commissioner. 

12 And, some of us -- many of us at the table 

13 actually implemented the systematic assessment of 

14 licensee performance and celebrated its demise -- sun 

15 setting. 

16 Appendix M is certainly not intended to 

17 short circuit the Commission's policy on risk 

18 informing our oversight processes. In fact, we put 

19 it in place to assist in achieving that end to fill 

20 gaps, if you would, when quantitative assessments 

21 alone, although the Commission's direction has never 

22 been to conduct a risk-based oversight process. 

23 Risk informed, again, which inherently 

24 involves use of deterministic information and we look 

25 forward to further engagement on Appendix M as we've 

26 strived over the years to improve its efficacy. But, 
 74 

1 it is a good approach and we are not using it in a 

2 manner to circumvent a quantitative process. 

3 I appreciate your encouragement on the 

4 construction reactor oversight process. We look 

5 forward to a more fulsome conversation during the 

6 construction program review later this year. 

7 I'm confident that Kathy and Laura will 

8 make sure that we resource both Vogtle and Summer in 

9 a way that supports implementation and processing 

10 including forwarding -- advancing the assignment of 

11 residents at the site as the pace of construction 

12 escalates at both sites. 

13 COMMISSIONER SVINICKI: Thank you for 

14 that. 

15 Thank you, Mr. Chairman. 

16 CHAIRMAN BURNS: All right, thanks. 

17 I'm not going to defend -- so much defend 

18 SALP, although I think the important thing is, as you 

19 had indicated, ROP is sort of built on SALP, what 

20 preceded SALP was far more -- far worse which was 

21 basically five individual fiefdoms in individual 

22 regions. 

23 So, we learn by experience, that's one of 

24 the good things I think this Agency does. But, 

25 certainly, with the ROP, I would agree that we've 

26 made strides. 
 75 

1 Commissioner Ostendorff? 

2 COMMISSIONER OSTENDORFF: Thank you, 

3 Chairman and thank you all for your presentations. 

4 I want to add my comments to Commissioner 

5 Svinicki's on the ROP process. She said a lot that 

6 I agree with entirely. 

7 I just would comment that I see the 

8 evolution over the number of years, as the Chairman 

9 and Commissioner Svinicki have referred to as a 

10 positive, very positive step. I think it's a real 

11 strength to the Agency. 

12 When I looked at how the Department of 

13 Defense, where I spent 26 years and looked at unit 

14 performance, whether it be in the operation reactor 

15 safeguards examination, tactical readiness 

16 evaluations, nuclear technical proficiency 

17 inspections, across the board for the submarine 

18 force. 

19 And, I looked at how the Department of 

20 Energy, when I was an official there, we looked at 

21 the site performance in the weapons complex. 

22 I think we have a far more disciplined, 

23 mature process that serves the nation very well. 

24 And so, I think the fact that there might 

25 some inertia for further change, it's a good thing 

26 and that there needs to be a strong justification to 
 76 

1 change things. 

2 I think that the predictability and 

3 stability are real positive attributes and consistent 

4 with our principles of good regulation. 

5 And, the fact that you take ongoing looks 

6 and suggest changes where appropriate, that's a real 

7 strength, too. 

8 I want to add my thanks to Scott, to 

9 Commissioner Svinicki and Scott, to going down to 

10 Region IV. 

11 I want to acknowledge that this is, I 

12 think, Marc's last appearance before the Commission 

13 as Region IV Administrator. I want to thank Marc for 

14 his dedicated leadership of the Region IV team during 

15 your time down there. 

16 I want to thank both Marc and Dan Dorman 

17 for your ongoing communications with the Commission 

18 on Arkansas Nuclear I and Pilgram. I've visited both 

19 sites with you all last year. I think the 

20 communications you've had with the Commission on your 

21 teams' assessment of the licensee performance and 

22 your very thoughtful and careful perspectives on the 

23 significance of various findings. 

24 What was appropriate from a regulatory 

25 standpoint, I think it's been a real positive 

26 experience for me as a Commissioner to watch you all 
 77 

1 go through that and I applaud you and I know the 

2 teams, whether it be the resident inspectors on site, 

3 the regional team members and the branches, et cetera. 

4 I think it's -- I don't really have any 

5 questions on performance because I think you did such 

6 a good job on communicating with the Commission. 

7 I do have one comment the Chairman raised 

8 and I appreciated him raising this comment about the 

9 fleet meeting you had down, I think, in Jackson, 

10 Mississippi here recently. And, I believe that Cindy 

11 Peterson attended that. 

12 And, I just wanted to comment from my 

13 experience elsewhere primarily, but also here at NRC, 

14 I think Marc, your comment on, I don't recall the 

15 exact words you used, but, you know, in an environment 

16 where people were making do with what they were given, 

17 with the resources on site, that really registered 

18 with me. 

19 And, I assume you discussed that in your 

20 fleet meeting? 

21 MR. DAPAS: Yes. 

22 COMMISSIONER OSTENDORFF: I'd appreciate 

23 any other, you know, how you saw Entergy's reaction 

24 to that discussion on this particular aspects. 

25 I think the resource piece is really an 

26 important part here. 
 78 

1 MR. DAPAS: I've had some discussion with 

2 the various levels of Entergy management on that 

3 particular aspect as it applied to ANO. And, more 

4 difficult to speak, or I'm not in a position to speak 

5 to what degree is at the view associated with the 

6 other sites. 

7 But, with respect to ANO, it certainly 

8 was part of the culture there about making do with 

9 what has been provided. And, Entergy management was 

10 receptive to that. 

11 And I think, you know, INPO conducts 

12 various evaluations. They've done corporate 

13 assessments and my understanding is that that's 

14 consistent with one of the items that was identified 

15 via that corporate assessment that INPO conducted. 

16 You know, we look at that to determine 

17 whether there are any safety issues, but we did have 

18 the opportunity to review that assessment and that is 

19 something that was consistent with what INPO had 

20 identified and Entergy management has acknowledged 

21 that. 

22 The discussion at the status of the fleet 

23 meeting was more along the lines of leadership 

24 behaviors and reinforcing standards at the first 

25 level supervisor and ensuring that individuals 

26 understand what are the expectations and reinforcing 
 79 

1 those. So, that was the context to the status of the 

2 fleet discussion. 

3 COMMISSIONER OSTENDORFF: I have to tell 

4 a very quick sea story. So, I go back when I was the 

5 commander of the USS Norfolk during a time period in 

6 1995 when Department of Defense budget was -- there 

7 was some difficulty there. 

8 And, I can remember very clearly at that 

9 time, there were perhaps 16 to -- probably 18 attack 

10 submarines based out of Norfolk, Virginia. Most of 

11 them were 688s, some of them were 637 Class. 

12 But, as a routine practice, because of 

13 the shortage of money for spare parts, that every 

14 time a ship got underway that had a BQQ5-D sonar 

15 system, that we would transfer or be the recipient of 

16 spare power supplies that were about $10,000.00 a pop 

17 for the sonar system because of the shortage of money 

18 to buy spare parts. 

19 And, there's lots of discussion, and this 

20 was 21 years ago, lots of discussion about it but it 

21 just did not pass the common sense test. 

22 And, if you're going to operate anything, 

23 I'm using this very broadly, in this case, submarines, 

24 you need to provide the resources to properly do it. 

25 It was -- it set, I can tell you, it set 

26 a very poor tone for this third-class Sonarman who 
 80 

1 was maybe 21 years old saying that, well, this, you 

2 know, our work maybe is not important enough to invest 

3 in the proper power supplies to run your system at 

4 sea, you know, and we were having the cannibalization 

5 process and material transfers going on. 

6 So, it's not just the functionality of 

7 the system affected by the lack of spare parts, but 

8 also the culture, the environment, the atmosphere 

9 that it became very evident that it lowered 

10 everybody's standards and it was not helpful. 

11 So, I use that Navy example I think is 

12 what really caused me to want to comment on it. 

13 MR. DAPAS: Yes, thanks, Commissioner. 

14 I would just put my comments in full 

15 context here. My understanding of one of the real 

16 ah-ha moments for Entergy was the 2015 third-party 

17 nuclear safety culture assessment where there 

18 was -- and I had the opportunity to talk with Jeremy 

19 Browning, the site VP about the observation by that 

20 team that individuals were making decisions at lower 

21 levels in the organization regarding prioritization 

22 because they weren't sufficiently resource loaded for 

23 the activity. 

24 The more senior management did not have 

25 an awareness that those decisions were being made. 

26 So, they thought root cause evaluations, apparent 
 81 

1 cause evaluations were being conducted adequately and 

2 comprehensively when, in fact, they weren't. 

3 And so, not having that awareness so that 

4 you could engage, and that's a number of things that 

5 contribute to that, but that was the context in terms 

6 of the culture of making do with what you have and 

7 making prioritization decisions at lower levels where 

8 more senior management not being aware could not then 

9 engage to address that. 

10 And, the discussions that I've had with 

11 more senior Entergy management, you can certainly 

12 engage them. They've clearly indicated that 

13 resources will be provided at the appropriate level 

14 to recover the plant. 

15 COMMISSIONER OSTENDORFF: Thank you. 

16 Two brief comments and then I'll close. 

17 Dan Collins, thank you for your 

18 presentation. I appreciated your putting in 

19 perspective the number of events in the numerator 

20 compared to the denominator of millions. 

21 And, I think those perspectives are so 

22 important for us as a regulator to communicate 

23 externally. 

24 We had this number of issues out of this 

25 number of overall activities. And, I think that 

26 perspective is really important. So, thank you for 
 82 

1 highlighting that in your presentation. 

2 And, Scott, I'll just comment that you 

3 made a brief reference to the component design basis 

4 inspection pilot. I think that's a really important 

5 part of our oversight inspection activities. 

6 I agree with efforts to try to reduce the 

7 burden on licensees while maintaining the spirit and 

8 the intent of the intent of the inspection. So, I 

9 look forward to seeing what the Agency's results are 

10 from those pilots. 

11 Thank you all for your presentations. 

12 Thank you, Chairman. 

13 CHAIRMAN BURNS: Thank you. 

14 Anything else? 

15 Well, again, thanks to the staff for the 

16 presentations and perspectives on the overall 

17 programs as well as the two plants, Pilgrim and ANO. 

18 We'll take now a brief break, about five 

19 minutes or so and then we'll resume with the second 

20 half of the meeting. 

21 Thanks. 

22 (Whereupon, the above-entitled matter 

23 went off the record at 10:41 a.m. and resumed at 10:52 

24 a.m.) 

25 CHAIRMAN BURNS: Well, we'll come back 

26 to order and we'll begin the presentations from the 
 83 

1 first of the two Entergy panels and first discuss the 

2 action plan for Arkansas Nuclear One. 

3 And, on this panel, we have Chris Bakken, 

4 Executive Vice President and Chief Nuclear Officer 

5 for Entergy, Tim Mitchell, Senior Vice President, 

6 Donna Jacobs, Chief Operating Officer, Jeremy 

7 Browning, Site Vice President for Arkansas Nuclear 

8 One and John McCann, Vice President for Regulatory 

9 Assurance. 

10 And, Mr. Bakken, I'll turn it over to you 

11 to begin the presentation. 

12 Thanks. 

13 MR. BAKKEN: Thank you, Mr. Chairman. 

14 Good morning. My name is Chris Bakken 

15 and I'm the Chief Nuclear Officer for Entergy Nuclear. 

16 As you may know, I'm new so, as I approach 

17 the end of my second month at Entergy, I wanted you 

18 to know on behalf of the company and myself how much 

19 we respect the NRC, it's technical expertise and the 

20 perspectives and insights that you provide as we work 

21 to improve our fleet's performance. 

22 Specifically, this morning I'd also like 

23 to acknowledge and accept the feedback that was 

24 provided by Mr. Dapas and Mr. Dorman in the earlier 

25 portion of this meeting. And we share and agree with 

26 their perspectives. 
 84 

1 We are committed to full regulatory 

2 compliance at all our facilities as our minimum 

3 standard. 

4 Our top priority is to operate or 

5 facility safely, securely, and reliability and we 

6 will not waiver from that commitment. 

7 We are well aware that our nuclear fleet 

8 performance has not met expectations and is not 

9 operating at the levels of excellence that it should. 

10 We're disappointed, frankly, to be here 

11 today and to be the only fleet in the United States 

12 to have three units at two sites in column 4. 

13 And, we're absolutely determined to 

14 improve our performance. 

15 Specifically, as I said, we're committed 

16 to improving our plant's performance. We're 

17 committed to operating our plants safely and reliably 

18 and in full compliance with NRC rules and regulations. 

19 We're committed to operate as one fleet, 

20 consistent with all regulatory requirements and 

21 industry best practice so that we quickly share our 

22 learnings across our fleet and don't learn our lessons 

23 and our shortcomings one site at a time. 

24 And, finally, we're committed to being 

25 professional with all internal and external 

26 stakeholders and not being defensive nor insular. 
 85 

1 Our nuclear assets remain an important 

2 part of Entergy's utility growth strategy. I have a 

3 leadership team here at the table that is focused on 

4 improvement and we have the full support of our 

5 Chairman, Leo Denault, the Entergy senior executive 

6 leadership team, and our Board of Directors. 

7 Our goal is not just to exit column 4 at 

8 Pilgrim and Arkansas Nuclear One. It is to return 

9 our plants to sustained excellent performance and to 

10 be considered again as one of the best nuclear 

11 operators in the world. 

12 From feedback provided by the NRC, our 

13 employees and other key stakeholders, there are a 

14 number of common causes that we have determined, after 

15 careful consideration, self-reflection, and analysis 

16 over the past months. 

17 As examples, in our past, we have assumed 

18 that we knew all the answers when we were challenged. 

19 And, we've learned that we did not. We need to be 

20 more humble. 

21 As a result, we've also learned that we 

22 have not listened well and have been defensive when 

23 we've been challenged. 

24 We now have insights though have 

25 consistently set and adhered to our own high standards 

26 and, instead, were relying on others to identify our 
 86 

1 problems. 

2 We were not sufficiently self-aware of 

3 our performance shortfalls. 

4 We also now realize that we've not always 

5 been clear in roles and responsibilities, such as the 

6 role of the fleet organization, and in the 

7 prioritization of our work. 

8 We are committed to owning and fixing 

9 these issues. Today's discussion is specific to two 

10 of our sites. Rest assured that we are taking in the 

11 learnings pointed out by the NRC, the industry, our 

12 own root cause analyses, our organizational capacity 

13 study, and other stakeholders to improve our entire 

14 fleet's performance. 

15 For Pilgrim specifically, we are 

16 committed to safely operate the unit until June of 

17 2019 and then through to a successful 

18 decommissioning. 

19 The site has the full support of my 

20 leadership team, the company and its Board of 

21 Directors to achieve this objective. 

22 We will provide the necessary resources 

23 so that we can finish the station's operating life in 

24 a position of strength or finish strong as we refer 

25 to it with our employees. 

26 It's also important for you to understand 
 87 

1 that Arkansas Nuclear One is a critical long-term 

2 asset for Entergy, our fleet, and the State of 

3 Arkansas. 

4 The facility plays a key role in 

5 delivering electricity to customers across the state. 

6 It is a major employer and it's helping that local 

7 community to continue to become a better place to 

8 live, work, and raise families. 

9 We are committed to returning Arkansas 

10 Nuclear One to one of the industry's strongest 

11 performers and the flagship of our fleet. 

12 I will now turn the discussion over to 

13 Arkansas Nuclear One Site Vice President, Jeremy 

14 Browning, who will be followed in due course by 

15 Pilgrim Site Vice President, John Dent. 

16 So, Jeremy? 

17 MR. BROWNING: Thanks Chris. 

18 Good morning. I'm Jeremy Browning, Site 

19 Vice President, Arkansas Nuclear One. I appreciate 

20 the opportunity, Mr. Chairman, Commissioners, to 

21 share Arkansas's current performance and the basis of 

22 the comprehensive recovery plan and our actions 

23 moving forward. 

24 Starting with the development of the 

25 comprehensive recovery plan, when we first entered 

26 into this, we sought benchmark data for other stations 
 88 

1 that had undergone similar, got the learnings from 

2 that. 

3 We also recognize that we needed to have 

4 a dedicated team of not only Entergy personnel, but 

5 industry folks that had participated in similar 

6 efforts. So, we wanted to leverage that. 

7 The ANO assessments were comprehensive 

8 and very broad. The causal analysis that we 

9 performed were rigorous and developed corrective 

10 actions or produced corrective actions that, not only 

11 address the contributors that led to the findings 

12 that Mr. Dapas spoke to, but also our 

13 institutionalizing learnings that will sustain our 

14 performance and drive us to excellence. 

15 During the implementation or development 

16 of the comprehensive recovery plan, we demonstrated 

17 bias for action. We were taking interim actions to 

18 try to improve performance. And, as Marc stated in 

19 a couple of areas, those interim actions did not hit 

20 the mark completely, primarily in the areas of the 

21 safety culture and the area of vendor oversight as 

22 it's been presented. 

23 When we looked at that and tried to learn 

24 from that and as we incorporated that into the 

25 comprehensive recovery plan, one of the areas that we 

26 felt like we had not done an adequate job was the 
 89 

1 full engagement of the workforce. 

2 We had an intentional bias towards trying 

3 to make sure that the station stayed focused on the 

4 operation of the facility. Other utilities that have 

5 entered into these kind of endeavors have been 

6 distracted in the operation of the plant, so we tried 

7 to insulate a little bit and make sure that the 

8 station stayed focused and we probably went too far 

9 in that effort and didn't engage. 

10 We did have some employment 

11 engagement -- employee engagement. However, I think 

12 we didn't have sufficient. 

13 Some of the insights that were provided 

14 to us by the 95003 inspection did point out that the 

15 causal analysis that we did in the area of safety 

16 culture didn't hit the mark. 

17 We thought that we could address that 

18 though kind of some corrective actions that were 

19 scattered throughout the plant and not make that a 

20 central point of the corrective action plan. 

21 So, we restructured the plan and, after 

22 going through that evolution, I recognized that that 

23 needed to be at the forefront of the plan to paint 

24 the picture that the culture changes at ANO were going 

25 to be the driving force for the plants. So, that 

26 became the catalyst for us and I do appreciate that. 
 90 

1 The causal analysis, what it did for me 

2 and what it did for the senior leadership team is it 

3 really made us focus a little deeper on the values 

4 that we have at ANO. 

5 The behaviors that you heard in here 

6 about folks maybe letting resource limitations not 

7 intentionally, but unintentionally, maybe bound the 

8 extent of cause or condition. They were allowing 

9 that limitation to maybe cloud what our core values 

10 are, and that would be nuclear safety as our top 

11 priority. 

12 So, when you go to the value system and 

13 that is defining how we behave, that is how we're 

14 intending our supervisors to coach. 

15 The effectiveness measures that were put 

16 into the comprehensive recovery plan were based on 

17 benchmark data of excellence. The effectiveness 

18 measures that we have in place and the oversight 

19 structure that we have put in place, not 

20 just -- aren't just limited to ANO. 

21 There's an oversight review board for ANO 

22 that consists of both Entergy executives and industry 

23 executives so that we have a balanced approach to 

24 making sure that we're getting the right level of 

25 challenge. 

26 The process is twofold. It measures 
 91 

1 timeliness and the rigor in which those actions are 

2 being implemented but just the measure of activity 

3 isn't good enough. We have to see objective evidence 

4 that performance is improving. 

5 Other stations, as we have benchmarked, 

6 have put too much emphasis on just measuring levels 

7 of activity and feeling good about themselves because 

8 they're getting things done with rigor and quality. 

9 However, they're not getting the intended outcome of 

10 performance improvement. 

11 So, our process is twofold. We want the 

12 rigor, we want the timeliness. But, if those actions 

13 aren't giving us the performance improvement, we need 

14 to make those course adjustments. 

15 Approximately 80 percent of our 

16 comprehensive recovery plans will be -- actions will 

17 be completed this year with the balance to be 

18 completed in the following years. 

19 As I stated, workforce engagement and a 

20 focus of our core values is at the heart of the 

21 comprehensive recovery plan. 

22 Next slide, please, if I could? 

23 The commitment that we are making is to 

24 the safe and reliable -- continued safe and reliable 

25 operation of ANO and the rigorous implementation of 

26 the comprehensive recovery plan. 
 92 

1 And, in order to do that, we recognize 

2 that we need to ensure that our leaders recognize 

3 risk and mitigate that risk appropriately with a bias 

4 for action to eliminate as opposed to mitigate. 

5 Validation of organizational capacity 

6 really has four scope elements and there is a process 

7 that's in place to validate that. It's called a 

8 People Health Committee modeled very similar after 

9 the Equipment Health Committee that we have at the 

10 station and have had for a while. 

11 It doesn't just look at an individual 

12 component deficiency like the -- if it's a 

13 vulnerability that you see in a department, what is 

14 the vulnerability of that human resource's impact on 

15 the overall system? And then, what's that system's 

16 overall impact on the site? 

17 So, it takes a more holistic look at the 

18 station. 

19 It also looks at the, as we've discussed, 

20 some our problems, whereas, a senior workforce left 

21 and newer employees and one for one ratio doesn't 

22 occur from a knowledge transfer standpoint. 

23 So, it's a more forward looking, making 

24 sure that, as attrition if forecasted, that that 

25 knowledge transfer is conducted in a timely manner. 

26 It also has a forward look at things that 
 93 

1 might be on our horizon. When we did our recovery 

2 plan development, we recognized that certain 

3 initiatives came to Arkansas like the NFP-805 

4 initiative in the Fukushima initiative. 

5 So, you're seeing a changing of a 

6 workforce on the horizon, some increased volume of 

7 work. The new process would identify new volume of 

8 work is on the horizon and what is your workforce's 

9 ability to actually implement that and do the two 

10 match? 

11 So, you can be making those proactive 

12 adjustments to your resources. So, it's not just 

13 about the volume of the resources, it's about the 

14 knowledge, skill and proficiency of those resources 

15 and then what are those resources actually working on 

16 today? And, what are those resources going to need 

17 to focus on tomorrow and in the years to come to make 

18 sure that we are prepared to deal with ongoing 

19 challenges. 

20 And, that concludes my comments. 

21 CHAIRMAN BURNS: Okay. All right, 

22 thanks. 

23 We'll start again with a question from 

24 Commissioner Baran. 

25 COMMISSIONER BARAN: Thanks, Mr. 

26 Chairman. 
 94 

1 Thank you all for being here. 

2 I think this is really one of the most 

3 important Commission meetings we have each year. 

4 Chris, I very much appreciated your 

5 comments and your frank acknowledgment of the 

6 problems at ANO and in other parts of the Entergy 

7 fleet. 

8 Marc Dapas detailed his assessment of the 

9 situation at ANO and you indicated that you were in 

10 agreement with his comments. 

11 Is there anything from his presentation 

12 you disagreed with or you thought was unfair? 

13 MR. BAKKEN: No, I think Marc gave a very 

14 accurate analysis of the situation. I'd also 

15 acknowledge, Commissioner, as you said, that the 

16 problem that we have at ANO, we have elements of it 

17 across the fleet and we need to work very hard to 

18 take our lessons that we've learned there an ensure 

19 that we apply them across the fleet and we're doing 

20 a good bit of work on that through the balance of the 

21 year to strengthen our ability to do that. 

22 COMMISSIONER BARAN: Marc highlighted 

23 the decisions about resources were one of the root 

24 causes for ANO's performance decline and this 

25 manifested itself in different ways, staffing levels 

26 that were lower than what they needed to be, what was 
 95 

1 needed. 

2 Contractor oversight wasn't adequate. 

3 Equipment maintenance and repairs weren't as prompt 

4 or thorough as they should have been. 

5 What has Entergy done and what are you 

6 doing to address these resource issues at ANO? 

7 MR. BAKKEN: Well, from an ANO 

8 standpoint, I guess I'd like to talk about some of my 

9 lessons from an ANO standpoint and then I'll let 

10 Jeremy amplify it. 

11 But, he talked about the Plant Health 

12 Committee, but, to me, organizational capacity is a 

13 good way of framing up the discussion. And, it's got 

14 to be a forward looking organizational capacity 

15 assessment. And, that's what I believe the Plant 

16 Health Committee does. 

17 But, what I'm talking about is it 

18 includes staffing. Do we have the right staffing in 

19 order to perform the workload that is in front of the 

20 organization? 

21 So, depending on variabilities in that 

22 workload, staffing and organizational capacity have 

23 to be adjusted accordingly. 

24 In addition, though, it's experience. 

25 It's proficiency, it's leadership. It's 

26 prioritization to make sure that the work is done 
 96 

1 with the highest quality. So, it is a much bigger 

2 element. 

3 So, we're doing organizational capacity 

4 studies across the entire fleet including the fleet 

5 resources. I think Marc or Dan one brought up some 

6 of the CFAMs. I think Mr. Dapas actually brought up 

7 the corporate foundational area managers. 

8 Well, they're part of the ongoing 

9 organizational capacity study that's going on right 

10 now. So, we're looking at it not just at ANO, even 

11 though ANO got started first, or they did start first, 

12 but we're expanding that across the entire fleet. 

13 MR. BROWNING: So, specifically, what was 

14 done at ANO is the capacity study was done in the 

15 third quarter of last year. Capacity study says, 

16 based on benchmark data and some of things that Mr. 

17 Dapas spoke to which is we're dual unit 18-month cycle 

18 dissimilar plant. What does that need to look like 

19 if you're not in a column 4 condition? 

20 So, that base load, what does that need 

21 to look like? The results of that came to us in the 

22 first quarter of this year and, through the 

23 corporation, we actually raised the base load target 

24 size of ANO to meet that capacity study results. So, 

25 we now know what we need to look like. 

26 In addition to that, we did what we call 
 97 

1 deep dives into the department. What do you need 

2 today based on today's demands. And, that study has 

3 just recently been completed and we're comparing the 

4 comprehensive recovery plan resource requirements to 

5 the current stations resources. 

6 And, that's not just volume, it's the 

7 skills, the knowledge, the proficiency of that 

8 resource and making sure that those two match. 

9 We do have a couple of challenges, as 

10 Marc spoke to, in the engineering area and 

11 maintenance. Although the maintenance area and the 

12 engineering area gaps have been closing and we're 

13 close to having that finalized. 

14 But, those were our two most challenged 

15 areas based on the first quarter results. 

16 COMMISSIONER BARAN: As you're 

17 evaluating the rest of the fleet and looking at 

18 potential issues including resource questions, what 

19 are you finding? Is this a resource problem 

20 occurring at other plants in the Entergy fleet? 

21 MR. BAKKEN: We've launched a very 

22 comprehensive organizational capacity review using a 

23 known industry consultant that has a considerable 

24 amount of benchmarking data. 

25 That study will conclude in the next 

26 several weeks. But, sitting here today, I have a 
 98 

1 broad view of the outcome of that study. 

2 Mr. Dapas comments are directly on. So, 

3 we are below industry benchmarks in terms of 

4 operational staff, maintenance staff, and engineering 

5 staff. 

6 I think one of the things, you know, Tim's 

7 mentioning in terms of the corporate functionality 

8 managers, we need to look quite hard at the capability 

9 and competence of the fleet support organization. 

10 Our numbers and our strength in that area is less 

11 than some of the other fleet operators in the country 

12 and we believe that's one of the things that we need 

13 to correct to continue to have sustained excellence 

14 in performance in the long-term. 

15 So, we'd be looking to increase our 

16 technical capability, our design conscious, our 

17 licensing basis understanding, design basis 

18 understanding and look to bring more of that work in 

19 house and do less of it externally through 

20 contracting. 

21 COMMISSIONER BARAN: Okay, thank you. 

22 MR. BAKKEN: So, that's what we've found 

23 and those are our intentions. 

24 COMMISSIONER BARAN: Thank you, Mr. 

25 Chairman. 

26 CHAIRMAN BURNS: Thank you, 
 99 

1 Commissioner. 

2 Again, I appreciate the presentations 

3 and, in fact, the journey that you're on in terms of 

4 addressing some of the issues that have been raised 

5 both at ANO and we'll talk in a few minutes at Pilgrim 

6 and the perspective from what does that mean in terms 

7 of overall fleet performance. 

8 One of the things and one question I had 

9 and one thing I think I heard during my visit a couple 

10 months ago was that, frankly, the operating staff was 

11 one of the strengths in the organization. And, 

12 what -- and really, a real asset to the plant. 

13 And, I think what I heard, too, is 

14 there's, in terms of taking some attempt to sort of 

15 leverage that both experience and quality in terms of 

16 the improvement initiatives. 

17 And, maybe you could talk a bit about, 

18 anybody, talk a bit about that and how you see 

19 building upon that? Because I think, looking for 

20 places where there are pockets of good performance or 

21 excellence to try to drive other areas. So, I'd be 

22 interested in hearing how you're trying to do that. 

23 MR. BROWNING: Yes, there's a couple of 

24 examples that I could provide to you as we have taken 

25 some of our senior leadership, the pipeline of 

26 operators that ANO has been fairly healthy, so we are 
 100 

1 able to bring some leadership out of that department. 

2 And, one of the areas that we were 

3 struggling was the corrective action program. So, 

4 we took a senior shift manager and he is now the 

5 department manager of that group. 

6 We went through a change management 

7 process so we've got a very operationally focused 

8 corrective action program manager who's now the 

9 conscious of our corrective action program. 

10 And then, as far as the fleet's 

11 concerned, the Ops Manager that had been in place for 

12 a couple of years is now the engineering director at 

13 the Grand Gulf facility. So, I think there is a lot 

14 of opportunities for the learnings that he had at ANO 

15 and the journey that led to where we were and the 

16 foundation that was built in ops and to take that to 

17 another station and to implant that. 

18 So, it's through this People Health 

19 Committee where the succession planning and the 

20 knowledge transfer of where our vulnerabilities are 

21 and where our strengths are and how do we develop the 

22 people today for that person that's going to leave or 

23 that area and start working that. 

24 We do have a succession planning process, 

25 but it's more about the implementation of that process 

26 that we're focused on. 
 101 

1 MR. MITCHELL: And, I think more 

2 fundamentally even, you have to back up to the do we 

3 have the right on shift, and I believe we do. And, 

4 they've got to be setting the standards for the entire 

5 organization because they are there 24/7 and they've 

6 got to set those standards so not just -- 

7 I agree with Jeremy and that is an 

8 important aspect of being able to get that experience 

9 out within the rest of the organization. But, 

10 Jeremy's also, and so is the plant manager at Arkansas 

11 Nuclear One, been very focused on making sure that 

12 the shift manager and the control room supervisors, 

13 the reactor operators are all operating at the highest 

14 standards of performance. 

15 But then, also, providing that influence 

16 upon to the rest -- on to the rest of the 

17 organization. 

18 MR. BAKKEN: I'd just add, Mr. Chairman, 

19 I think behind your comment is something I believe 

20 quite strongly which is that for a plant to be 

21 successful, the operations department and the 

22 operations team have got to be the leaders on the 

23 site. 

24 You know, they're the people that we 

25 license. They have the best understanding of the 

26 site, the best capability to make risk judgments, 
 102 

1 safety judgments, et cetera. 

2 So, I think one of the things that you 

3 did sense and was discussed in your visit is that the 

4 facility at Arkansas Nuclear One, that is occurring. 

5 We have other facilities where it's not 

6 to the level of strength that it needs to be. So, 

7 when we look at the organizational capacity and our 

8 workforce planning, we'll be looking to reinforce 

9 those departments in the rest of our fleet so that we 

10 can be in operations to that organization at the sites 

11 and use that team to preserve the safety and the 

12 reliability margins of the plant. 

13 CHAIRMAN BURNS: Okay, thanks. 

14 And, I want to -- last question I'll ask 

15 and you talked and addressed, you know, developing 

16 organizational capacity, evaluating resources, you 

17 know, the organizational effectiveness, how things 

18 are carried out. 

19 And, you also talked about safety culture 

20 which is one of those things that's more ephemeral. 

21 It's, you know, you can't say my wife has a story or 

22 father used to say, you know, going to some family 

23 event, you will attend and you will enjoy. 

24 And, that doesn't quite work that way in 

25 terms of safety culture. But, tell me a little bit 

26 more about the initiatives you're undertaking, just 
 103 

1 to foster that? 

2 Because I realize that's not just 

3 assessing, you know, do I have the right number of 

4 staff? Do I have, you know, the right contractor 

5 balance and all. It's a more difficult thing to 

6 address. So, I'd appreciate hearing about that, a 

7 little more detail on what you're trying to do in 

8 that area. 

9 MR. BROWNING: So, one the -- I know 

10 it's -- it looks simple, but this book right here is 

11 called the ANO Standards and Expectations book and on 

12 this page is, at the top of it, it defines our core 

13 values. 

14 And, the very first value is, we always 

15 keep nuclear safety first. And so, what we do is how 

16 do we translate that into a tangible example? 

17 If, for example, we see someone that's 

18 not necessarily adhering to a procedure the way they 

19 should be, start with what is our standard when it 

20 comes to procedure, use and adherence. 

21 And, you know, the standard would be 

22 clear and then we would talk to, do we believe that 

23 procedures lead to consistent outcome and results and 

24 that's why they're in place? And, the answer to that 

25 would be yes. 

26 Then, we'd say, do we really value 
 104 

1 nuclear safety because those deviations, although 

2 minor, can lead to nuclear safety problems. So, 

3 really talk to these. 

4 And, the other core values are we fix and 

5 maintain our plant. We operate as a team. We 

6 continuously learn and seek to improve from people 

7 that are doing it better. 

8 So, those are some of the things -- and, 

9 every time we see a deviation from behavior, we go 

10 back to these values and say, we can't behave this 

11 way if we say we value these things. And we have 

12 those very candid discussions with our staff. 

13 MS. JACOBS: I think maybe I can broaden 

14 that back, too, Chairman. If we look at the entire 

15 fleet, so part of our root cause analysis was to take 

16 a look at nuclear safety culture and do a nuclear 

17 safety culture review for the fleet itself. 

18 And so, supplementing our team with some 

19 very experienced industry executives coming in and 

20 looking at what we're doing, putting it in terms of 

21 the NUREG-2165, the common culture traits that we 

22 have. 

23 And really stepping back and 

24 acknowledging that, across the fleet, we need to have 

25 a stronger focus on nuclear safety. 

26 And so, it really starts with the leaders 
 105 

1 of what is most important for us and how we pull that 

2 out of the organization. 

3 We heard an example about when we needed 

4 to take the unit down at ANO and we did that and that 

5 was probably different focus than what we would have 

6 done before. 

7 We're seeing the same types of examples 

8 at our other sites where, if we've got an equipment 

9 issue, we're going after the equipment issue. If we 

10 need to bring the unit down, we're also asking 

11 ourselves, what other work is the right work to do? 

12 Mr. Dapas talked about a recognition of 

13 our single point vulnerabilities and we've had a 

14 tendency to always want to mitigate instead of go 

15 eliminate. And, that's been a real focus for us. If 

16 we need to bring a unit down, we'll go through the 

17 complete list of a single point vulnerabilities and 

18 what can we go fix at this opportunity? 

19 And, I think that's a lot different from 

20 the past where we might have been more focused on 

21 bringing the unit back up immediately instead of 

22 saying, we have an opportunity to make some 

23 corrections in our facilities. 

24 So, while we've done that nuclear safety 

25 culture review, we're putting in more formalized 

26 corrective actions. I think the first step you have 
 106 

1 to see is how we internalize it as leaders and we 

2 carry that across our fleet. 

3 CHAIRMAN BURNS: Okay, thanks very much. 

4 Commissioner Svinicki? 

5 COMMISSIONER SVINICKI: Well, thank you 

6 for your presentations. 

7 When I visited ANO, one of the things 

8 that struck me that I took away from there was a 

9 strong sense of almost family between the women and 

10 men who work at the station and there was a real 

11 community spirit, but that carried over into the plant 

12 itself. 

13 And, while employees looking out for each 

14 other is a very positive attribute, a site vice 

15 president, maybe I'll direct this to you, Mr. 

16 Browning, how do you assure yourself that employees 

17 are willing to challenge each other as will be 

18 necessary in order to have success on the recovery 

19 plan? Challenge each other’s actions and to really 

20 move forward on the changes that are necessary? 

21 MR. BROWNING: That wasn an absolute. 

22 One of the five key insights that came out of our 

23 nuclear safety culture highlighted the fact that 

24 we're very close. We're a very tight team and almost 

25 family. 

26 But then, the safety culture survey went 
 107 

1 on to -- or assessment went on to say, and as a 

2 result, you tend to not want to intrusively challenge 

3 each other or you trust without verification. 

4 So, we have to institutionalize some 

5 forcing functions to force ourselves to do this. 

6 So, in some of our key meetings, we have 

7 brought in external people from ANO. This would be 

8 like in our Plant Health Committees, our people health 

9 committees, the challenge meetings that we do before 

10 we conduct maintenance called a critical evolution 

11 meeting. 

12 And, these people from an external point 

13 of view are using the attributes of leadership and 

14 watching the managers. And, when they don't see 

15 those examples where we've challenged sufficiently, 

16 they will either interject during the meeting or 

17 provide a critique. 

18 All that information is also rolled up 

19 into a product that we review on a frequency to see, 

20 are we seeing improvement in those behaviors over 

21 time? And we have been and these have been in place 

22 for, in some cases, a year. 

23 COMMISSIONER SVINICKI: Yes, I think one 

24 other thing that goes along with that is when we look 

25 at closing out actions, how do we really challenge 

26 them to make sure we've been effective and the 
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1 implementation of the action closure review board, 

2 which is a team that that is their sole purpose is to 

3 go in and challenge that. 

4 We're actually using that at other sites 

5 as well, not just at ANO. But, it's a very good 

6 opportunity for us to go through and make sure that 

7 the actions we're putting place are effective so that 

8 we can continue to move our improvement performance. 

9 MR. MITCHELL: There's also a corporate 

10 role in addressing your question and that corporate 

11 role includes a corporate function of area managers 

12 but others. So the improvements that we're making 

13 from a fleet recovery standpoint are very focused on 

14 making sure that we have the right view of are those 

15 corrections, are those behaviors, are those 

16 improvement opportunities being recognized and acted 

17 upon? 

18 MR. BROWNING: And so, a recent learning 

19 from a Waterford Station in the way they implement a 

20 management review meeting is, it had in the past been 

21 more of a fleet challenge of our performance, but 

22 we're changing that format to where it's more of a 

23 departmental challenge of each other’s performance 

24 with the fleet's role to make sure that challenge is 

25 adequate. 

26 So, it's a little bit of a change in the 
 109 

1 mind set. The material's the same, but it's shown 

2 to be real effective at Waterford, so that's just 

3 another tool that we're using to make sure that the 

4 corporation has the ability to see us do that external 

5 to ANO. 

6 COMMISSIONER SVINICKI: Another 

7 observation over the course of time in looking at 

8 U.S. industry performance is that, certain fleets or 

9 particular sights have cycles of performance over the 

10 decades. 

11 Do you feel that you, as you developed 

12 your recovery process, have designed in long-term 

13 sustainment of the measures and different changes 

14 that you're making? Has that been something that was 

15 designed in up front? 

16 MR. MITCHELL: That would -- absolutely 

17 our intent to make sure that that was our focus, not 

18 just a -- and that kind of leads back to Mr. Bakken's 

19 initial comments. 

20 Our objective and our focus is not to 

21 exit column 4. Our objective is to restore 

22 performance at a level of excellence that ensures the 

23 sustainability that you're talking about. 

24 But -- and that applies to Arkansas 

25 Nuclear One as well as the fleet. So, our everyday 

26 motto or mantra is to go focus them on, what do we 
 110 

1 need to go do, not for today, but what do we need to 

2 do for the long-term health of the organization? 

3 MR. BROWNING: And, technically, at ANO, 

4 what that looks like is before any one of the focus 

5 areas gets closed out, it's about the execution, 

6 quality execution. Did you see the performance 

7 improvement that you expected and then what are the 

8 sustainability tools? 

9 So, those three scope elements have to be 

10 satisfied before any one of our focus areas will get 

11 closed. And, it's not just ANO says that, it's ANO 

12 says that and then is challenged by not only fleet 

13 but also industry folks to say we believe that you've 

14 met the mark. 

15 MR. BAKKEN: Just a follow on from 

16 Jeremy's last thought and an answer to your question, 

17 I think we have a piece of work to do in terms of 

18 strengthening the capability of the fleet governance 

19 organization, the team that work in echelon to make 

20 sure that we have a proper vision of industry 

21 excellence, that we have sufficient benchmarking from 

22 our peers in the industry and that we keep that fresh. 

23 One of the things we discussed in the 

24 meeting we had at the end of March was our ability as 

25 an organization to recognize excellence today. 

26 We have bene insular, I mentioned in my 
 111 

1 opening remarks. We tended to benchmark within our 

2 fleet and we've missed some of the improvements that 

3 others have made in the industry. So, when we look 

4 forward, I think part of the sustainability is to 

5 keep that alive, keep that benchmarking going. 

6 One of the things I've been very pleased 

7 to find in taking this responsibility is the response 

8 from my peers in the industry who are very willing to 

9 try to help us and to allow us those opportunities to 

10 benchmark and to learn from them and their successes 

11 in doing things similar to what we're trying to 

12 achieve. 

13 So, I think that part is really 

14 instrumental to us continuing to improve and then 

15 sustaining that over time is to keep that very fresh 

16 and current. 

17 COMMISSIONER SVINICKI: Thank you. 

18 Thank you, Mr. Chairman. 

19 CHAIRMAN BURNS: Thank you. 

20 Commissioner Ostendorff? 

21 COMMISSIONER OSTENDORFF: Thank you all 

22 for your presentations. 

23 I'm going to maybe pick up where you were 

24 leaving off, Commissioner Svinicki. I appreciate 

25 your candor as the Chief Nuclear Officer. I know 

26 you've been then a short time. Thanks for coming by 
 112 

1 to see the Commission here earlier a few weeks ago. 

2 You know, you've got a strong background 

3 in the nuclear industry in the United States and 

4 overseas. What was the biggest surprise you had 

5 coming into Entergy? And, my question's not about 

6 ANO but just about the overall fleet? Because I 

7 think the fleet issue is one that certainly has the 

8 Commission's attention here. 

9 MR. BAKKEN: I don't know if I'd frame 

10 as a surprise but I think the one thing where we have 

11 the largest opportunity for improvement is to 

12 strengthen how we operate as a fleet. 

13 Because, my vision of Entergy was a 

14 decade old and I had a very different perspective. 

15 When we were in England, it was actually Entergy 

16 people that were there helping us turn the fleet's 

17 performance around. 

18 So, the clear roles and responsibilities 

19 and mission statement of the fleet organization is 

20 the area where I think we have a very large 

21 opportunity to improve and then consequentially 

22 improve our whole fleet's performance. 

23 So, that would be my answer to the 

24 question. 

25 COMMISSIONER OSTENDORFF: Okay. I'll 

26 ask this question and I'll let you decide who wants 
 113 

1 to answer. 

2 The question is, how do you assess morale 

3 at ANO? You can figure out who you want to have 

4 answer that question, it could be multiple people. 

5 MR. BROWNING: Well, there's a couple of 

6 different ways we're doing that at ANO. 

7 One is, we're doing pulse surveys every 

8 quarter targeting specific things. So, we're getting 

9 direct feedback from the employees. 

10 We just finished a major survey where we 

11 had about 80 percent of the site participate in that. 

12 So, we get those learnings. 

13 The other way is by being with your people 

14 in different settings. I call them 2C's meetings. 

15 People meet with me, they meet with the plant manager, 

16 a broad spectrum of the site. 

17 They meet, I guess you could say, 

18 independently with some facilitators and then I would 

19 enter the room and then we discuss their comments and 

20 their feedback and then we address those. 

21 So, those are some of the ways, but it's 

22 the best way that I know is to be with your people 

23 where they're doing their work and have meaningful 

24 interactions with them while they're doing it. 

25 And then, you also can measure the 

26 results of that by the discretionary effort that you 
 114 

1 see in the results that you see from your performance 

2 improving. That's the only way that I know. 

3 MR. MITCHELL: I think there's another 

4 element to the morale at Arkansas Nuclear One. I 

5 think they are encouraged by the actions that are 

6 being taken, but there's still a question on their 

7 part of, are we committed to the long-term 

8 sustainability of those actions or is this just a 

9 short-term? 

10 And, we have to demonstrate to them that 

11 it is a long-term commitment that we are after. 

12 COMMISSIONER OSTENDORFF: Okay. Thank 

13 you all. 

14 Thank you, Mr. Chairman. 

15 CHAIRMAN BURNS: Thank you. 

16 And, I guess what we'll do now is switch 

17 out to have the folks who addrss Pilgrim come forward. 

18 And, again, thanks. 

19 Well, welcome. And, again, we'll proceed 

20 with the presentation from Entergy with respect to 

21 Pilgrim. 

22 MR. BAKKEN: I did not intend to repeat 

23 my opening remarks. I'm sure you're happy to hear 

24 that. 

25 CHAIRMAN BURNS: Thank you. 

26 MR. BAKKEN: So, I'll let -- we've been 
 115 

1 joined by John Ventosa who's the Chief Operating 

2 Officer for the northern portion of our fleet and 

3 John Dent, the Site Vice President. So, I'll hand 

4 over to John. 

5 MR. DENT: Thank you. 

6 Good morning. My name's John Dent, 

7 again, I'm the Site Vice President at Pilgrim. I 

8 very much do appreciate the opportunity to be here to 

9 talk with you this morning. 

10 Before I jump into the presentation, I 

11 first of all wanted to say that, on behalf of Pilgrim, 

12 on behalf of myself, completely align with Mr. 

13 Dorman's comments, the NRC's perspective of our 

14 performance. 

15 We agree that we're safe to operate. We 

16 do recognize, however, that we have work to do, a lot 

17 of work to do to continue to improve our margins to 

18 safety and we are 100 percent committed in doing so. 

19 So, with that said, what I intended to 

20 cover this morning is some questions that I thought 

21 may be of most interest. 

22 So, first of all, what I'd like to talk 

23 about is why Pilgrim's in column 4. And, I know Mr. 

24 Dorman talked about the ROP perspective of why we're 

25 in column 4, I wanted to take it just a little bit 

26 further. 
 116 

1 Additionally, I wanted to talk about how 

2 we're addressing our performance problems, what our 

3 fundamental problems are and what a fundamental 

4 problem is, kind of a definition of what a fundamental 

5 problem is, and then, finally, how we're driving our 

6 recovery. 

7 And then, when I'm finished I'd be more 

8 than happy to try to answer any questions that you 

9 might have. Okay? 

10 First of all, why we're in column 4, as 

11 Mr. Dorman talked about, 2013 we had a combination of 

12 unplanned SCRAMS and SCRAMS with complications that 

13 resulted in our entering the column 3. 

14 The latter part of 2014, we were 

15 unsuccessful with our 95002 inspection. Subsequent 

16 to that, we identify an issue with a safety relief 

17 valve that we misdiagnosed in 2013 which, obviously, 

18 resulted in a white finding, the third white finding 

19 and our entry into column 4. 

20 So, I would characterize that as the 

21 direct cause or the nuts and bolts from the ROP 

22 mechanics of why we're in column 4. 

23 But, the real reason, the underlying 

24 reason that we're in column 4 is because of us. It's 

25 because of our culture. And, at the heart of our 

26 cultural issues, I would tell you, is our 
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1 implementation of the corrective action program. 

2 We've lacked the reverence, that deep 

3 appreciation for finding and fixing our problems. 

4 Now, I'm not here to tell you that's our only problem, 

5 but I would argue that, had we been implementing the 

6 corrective action program to the spirit by which it's 

7 intended, there's a pretty good possibility I 

8 wouldn't be sitting here talking to you today about 

9 why we're in column 4. 

10 So, we're doing a lot of work in that 

11 area. We, as we talked about earlier, we think we're 

12 making progress. We recognize we have a long way to 

13 go and a lot of work to do to really instill the 

14 cultural changes that we need to instill to be where 

15 we need to be which is aligned with industry 

16 excellence. 

17 So, that's the why we're in column 4. 

18 How we're addressing our performance 

19 problems? There is a very systematic and 

20 comprehensive process that's been very successful in 

21 the industry. We've taken the opportunity to 

22 benchmark plants such as Fort Calhoun, Brown's Ferry, 

23 Palo Verde and, obviously, ANO. ANO's kind of an 

24 ongoing benchmark for us. 

25 They are, obviously, further along in 

26 their efforts. We've taken the opportunity to 
 118 

1 leverage the pluses and deltas and will continue to 

2 do so through our efforts. 

3 I did want to touch on from a very high 

4 level how we're going about this. There's 

5 three -- kind of three parallel activities, if you 

6 will, going on right now. 

7 There's a team of industry experts, a 

8 company that does this for a living and is being very 

9 successful. We've hired that company. So, this team 

10 of nuclear professionals working with the Pilgrim 

11 team in concert. 

12 Essentially, what they do from time zero, 

13 which was the latter part of 2015 to the beginning of 

14 2016, they take a look at our performance. 

15 Basically, turn over every rock going back in time to 

16 a point in time when performance at the station was 

17 considered to be healthy or strong. 

18 So, all that data is pulled together and 

19 then, in parallel with that, there's a separate part 

20 of the team that's doing observations in the field, 

21 whether it be in the plant, the control room, meeting 

22 settings, training settings or whatnot. 

23 And, they're gathering information so you 

24 have a combination of a historical perspective for 

25 our performance, coupled with a contemporary or 

26 current perspective of our performance. 
 119 

1 All that information comes together, it 

2 goes through a very rigorous structured process and 

3 what comes out of that process is what's termed, one 

4 of the key outputs is our fundamental problems. 

5 And, a fundamental problem is, by 

6 definition, it is your cultural problems, it is your 

7 systemic organizational issues. And, it's typically 

8 that the fundamental problems are the drivers for 

9 your other problems. And, I'm going to talk about 

10 those in just a minute. 

11 So, in parallel with that, we have five 

12 issues of concern or five focus areas, very -- we're 

13 very clear on what those focus areas are. 

14 So, from the onset, what we've done is 

15 we've implemented interim actions and the intent of 

16 the interim actions that address those five areas is 

17 to ensure we're managing risk throughout the process. 

18 So, we understand what our fundamental 

19 problems are, our organizational drivers. We 

20 understand what the causes are. We understand what 

21 the corrective actions are to fix the problems. 

22 We implement the corrective actions and 

23 then we assure ourselves that the corrective actions 

24 have effectively fixed our problems. Then and only 

25 then will be back off of the interim actions. So, 

26 that's the second piece. 
 120 

1 The third piece is augmented staff. 

2 We've talked a lot about staffing and organizational 

3 capacity. But, what we've learned from benchmarking, 

4 what we've learned from our own experience and going 

5 through the 95002 inspection was that, to safely 

6 operate the plant is it takes a lot of effort. It 

7 takes a lot of attention from the site, from the 

8 leadership team, from the workforce to safely operate 

9 the plant. 

10 That's the price of admission. We have 

11 got to operate the plant safely 24 hours a day, seven 

12 days a week. That's a foregone conclusion. 

13 Equally as important, we have to recover. 

14 We have to understand what our fundamental problems 

15 are and we have to implement a recovery plan to 

16 improve performance. 

17 So, to do that, we know that we've needed 

18 to augment the staff. So, key leadership positions, 

19 we've created shadow or assistant level full-time 

20 positions. And, in certain departments within the 

21 organization, we've augmented the staff as well. 

22 And, to be clear, this augmented staff 

23 isn't just here from now until we get through recovery 

24 and when we return to column 1, this augmented staff 

25 are completely funded and resourced all the way to 

26 the end of plant life. So that's the third piece. 
 121 

1 So, it's big picture, analytical approach 

2 to understanding our problems. We've got interim 

3 actions in place to manage the risk until we solve 

4 those problems. 

5 And, from an organizational capacity 

6 standpoint, we have the staffing necessary to support 

7 safely operating the plant and recovery. 

8 Okay? So, that's how we're addressing 

9 our problems at a very high level. 

10 Our fundamental problems, just as 

11 analysis or analytical approach I talked about is 

12 referred to as the collective evaluation process. 

13 And, for us, at Pilgrim, the collective 

14 evaluation process has determined that we had three 

15 fundamental problems. 

16 Not surprising is CAP, corrective action 

17 program. In fact, we didn't wait for the collective 

18 evaluation process to complete. Very early on in the 

19 process, we made the decision that we have a 

20 fundamental problem in the implementation of the 

21 corrective action program. 

22 So, we went right into the root cause 

23 evaluation. We've been in the process of 

24 implementing those corrective actions and we are 

25 seeing improvement in our efforts. 

26 Again, a long way to go, but we are seeing 
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1 improvements in that area. 

2 The next two fundamental problems, risk 

3 recognition and decision making is a fundamental 

4 problem for us. 

5 And then, finally, in the area of safety 

6 culture, a specific focus in three areas, leadership, 

7 resources or organizational capacity and then, 

8 finally, oversight. 

9 So, they are our three fundamental 

10 problems. 

11 It is noteworthy, I just want to make a 

12 point here, since 2013, we've been working hard to 

13 improve our performance. We implemented a 

14 comprehensive improvement plan in 2013. 

15 Objectively, subjectively, we've been 

16 seeing performance improve. Again, we've got a long 

17 way to go and we've got plenty of work to do in front 

18 of us. We're not where we need to be, I just want 

19 to be clear about that. 

20 But, the reason I bring it up, this is 

21 really important in our process. As we go through 

22 the analytical portion and the causal analysis, it's 

23 very important to us that, for example, if we identify 

24 six drivers to a problem in say, CAP, if three of the 

25 drivers had been adequately addressed from the 

26 beginning of the assessment or the beginning of the 
 123 

1 improvement efforts, we need to be clear that these 

2 drivers have been addressed. 

3 And, the reason I tell you that, it's 

4 really important to us from a focus standpoint of the 

5 organization that we're not putting corrective 

6 actions in place and diverting the organization's 

7 attention to fixing things that don't need to be 

8 fixed, we need to be fixing the drivers that will 

9 improve our margins to safety. So, that's the reason 

10 I tell you that and that's a focus for us. 

11 It sounds simple, it sounds basic, but 

12 it's a bit more complicated than it may sound. 

13 So, that's the fundamental problems for 

14 us and then, finally, how we're driving our 

15 performance recovery efforts. 

16 The root cause is the apparent cause. Of 

17 all that causal analysis work will come together in 

18 corrective action plans. 

19 We have interim correction actions in 

20 place. We have an improvement plan that's in place. 

21 So, all that comes together and that'll be combined 

22 into what we talk about as the comprehensive recovery 

23 plan. 

24 And, I'll tell you, that's the mechanics 

25 of how that comes together. But, the magic for us 

26 here, since 2013, we've been working very, very hard 
 124 

1 to build the trust and transparency and openness and 

2 engagement of the entire workforce. 

3 A key element of that in 2013 was the 

4 engagement of the workforce and helping us build the 

5 comprehensive improvement plan. Big dividends for 

6 us back then. 

7 The ownership, the buy-in, the 

8 understanding, the knowledge. The knowledge of my 

9 role in a recovery, the knowledge of my role as a 

10 worker, what it means to be in column 4, what that 

11 means to us in terms of margins and safety and what 

12 my role is. 

13 They are the dividends we're looking for. 

14 So, we're literally weeks away to implementing that 

15 portion of the process. 

16 Again, we've been talking to the 

17 workforce a tremendous amount throughout the effort 

18 and the workforce knows that we're in the process and 

19 will be pulling together. 

20 So, all that said, the way this is going 

21 to play out as we move forward here in the coming 

22 weeks, when we've got the comprehensive plan in place, 

23 when we're confident that our actions are being 

24 effective and we're seeing performance move in the 

25 right direction, when we're confident that the 

26 organization's completely aligned around where we're 
 125 

1 going, then and only then will we pick the phone up 

2 and let the NRC know that we're ready for the 

3 inspection. 

4 So, and, Mr. Mitchell alluded to it here, 

5 and I talk incessantly to the workforce about this 

6 and I want to be clear today, this 95003 inspection 

7 is very, very important to us. There's no doubt 

8 about it. 

9 But, this isn't about passing an 

10 inspection. That's not what this is about. What 

11 this is about is an organization understanding what 

12 our fundamental problems are, what those cultural 

13 issues are, understanding what behaviors we need to 

14 change, not just to improve the margins to safety but 

15 to drive us to industry excellence. That's what this 

16 is all about for us. 

17 So, that's what we're doing to drive 

18 recovery. And then, just very briefly to close 

19 things out here, as far as safe and reliable 

20 operation, there's a lot I can say in that area. 

21 But, I keep coming back to engagement, 

22 continuing to engage and build on what we've 

23 accomplished with the workforce at Pilgrim and 

24 continue to leverage the workforce. 

25 Our workforce to align top to bottom, 

26 horizontally, vertically, that's what's going to 
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1 carry the day for us and lead to our success in terms 

2 of, like I said, not just improving margins to safety, 

3 but driving our site's performance to excellence. 

4 And, the last thing I wanted to just touch 

5 on is finishing strong. I have a board in the 

6 presentation that talks about finishing strong. 

7 There's an elephant in the room we really 

8 haven't talked about a whole lot. We're shutting the 

9 plant at the end of May 2019. That's going to happen. 

10 I know these are just words, I like to 

11 think our actions and our words mesh up. From our 

12 perspective, and when I say we here, when I say we, 

13 I mean the site leadership team, I mean the workforce, 

14 Entergy Nuclear, Entergy Corporation are 100 percent 

15 committed, not just to improve in our margins of 

16 safety, but we're a 100 percent committed to driving 

17 right through the end of the plant life here. 

18 Somebody sitting in the room right now 

19 made a comment to me about a week ago and it really 

20 resonated with me. This organizational vision of 

21 running through the tape at the finish line, I really 

22 like that vision. 

23 We've got the organization aligned around 

24 leaving a legacy of excellence. We've got a proud 

25 New England workforce and I think this workforce is 

26 completely aligned around finishing strong at the end 
 127 

1 here. 

2 So, I said a lot. I said a lot fast. 

3 I'd be more than happy to answer any questions that 

4 you may have. 

5 Thank you. 

6 CHAIRMAN BURNS: Okay, thanks. Is that 

7 it? 

8 Okay, thanks very much. Again, we'll 

9 start with Commissioner Baran. 

10 COMMISSIONER BARAN: Thanks. 

11 Mr. Dent, I appreciate your 

12 acknowledgment that Dan Dorman's assessment of the 

13 issues at Pilgrim is fair. I think that's really 

14 helpful to have kind of a common understanding of the 

15 problems to address there. 

16 I asked Dan about the Region's 

17 observation at the end of 2015, that’s a few months 

18 ago now and that operations management wasn't 

19 embracing the need for change. It was more focused 

20 on regulatory characterization than on addressing and 

21 fixing problems. 

22 I'm interested in your thoughts on -- he 

23 also mentioned that he's seen improvement, but 

24 there's a way to go. So, I'm interested in your 

25 thoughts on that and I'm interested in Chris's 

26 thoughts on that coming on those issues coming in and 
 128 

1 new to the fleet. 

2 MR. DENT: Yes, I think, first of all, 

3 we've made some organizational changes in ops, 

4 promotional across the board. But, nonetheless, 

5 we've some changes and I think the, at least I'll 

6 give my perspective, I won't speak on behalf of our 

7 residents or Mr. Dorman. 

8 But, I think the lines of communications 

9 have opened considerably. I think the focus on, for 

10 example, shift managers driving performance at the 

11 station is a focus for us. 

12 We're not an industry leader as far as 

13 shift managers driving performance and that's 

14 something that the operations leadership team as well 

15 as the senior leadership team are focusing on. And, 

16 I think we're seeing improvement within that area. 

17 So, that is very much a focus for us and 

18 it is important to us. 

19 MR. BAKKEN: And, just to follow on in 

20 the point I commented on it a bit earlier, but, you 

21 know, in my experience tells me that strong 

22 operational leadership leads you to have a 

23 successfully and well run site. 

24 I think the other piece that we need to 

25 look at, which we really haven't discussed, is 

26 succession planning and workforce planning. 
 129 

1 Because, the other thing that makes an 

2 organization successful is a pipeline through the 

3 operations organization. It's then used as a feed 

4 stock for the rest of the organization, be it 

5 maintenance, engineering, licensing, et cetera. 

6 We have some of our facilities that do 

7 that very well and we have others where we need to 

8 improve. And, I think that role of the path through 

9 the shift manager and then out into the broader 

10 management responsibilities and fleet 

11 responsibilities is key to our success. So, that'll 

12 be a focus area for us in the coming years. 

13 COMMISSIONER BARAN: Mr. Dent, you 

14 mentioned that one of the steps you're taking at 

15 Pilgrim is to augment the staffing and that that's 

16 something you intend to maintain over the next few 

17 years in a run up to shutting down in 2019. 

18 How are you going to make sure that any 

19 necessary capital improvements are made to the plant 

20 even though it's only going to be operating for a few 

21 more years? 

22 And, I guess this is a question also for 

23 the senior leadership of the fleet. How is the fleet 

24 going to make sure, fleet management going to make 

25 sure that, if there are investments that need to be 

26 made at a plant that's going to be shutting down in 
 130 

1 three years, those investments are made? 

2 MR. DENT: Yes, the timing, if you heard 

3 the safety culture comment I made around risk 

4 recognition and decision making, that decision making 

5 aspect, there are things we've done in terms of 

6 structure processes to make sure decisions that we're 

7 making are rigorously vetted out and challenged. 

8 So, timing wise, we have one outage left, 

9 one refuel outage. We just finished scoping that 

10 outage. And, that is -- you have two years left to 

11 operate and from a making the decision what scope 

12 goes into the outage or not, what we did is we 

13 expanded it beyond the site. 

14 We took our shot at scoping the outage 

15 and we thought were absolutely positively necessary 

16 for the efficient operation of the plant through plant 

17 life. 

18 And, what we did is, we've had 

19 independent challenges at a fleet level to make sure 

20 that there wasn't anything we were missing or we 

21 weren't getting blind to it in terms of being too 

22 close to it. 

23 So, we're including third-party or kind 

24 of independent help in that area to make sure we're 

25 not missing anything. 

26 COMMISSIONER BARAN: Okay. 
 131 

1 MR. VENTOSA: The only thing to add to 

2 that, I mean there's a significant kind of fleet 

3 corporate piece of that from an oversight piece, John. 

4 And, I think we looked at it a little bit 

5 differently in the past. Not the probability of the 

6 piece of equipment failing because you could 

7 rationalize then two years, you know, probability 

8 time, but what's the consequence? 

9 And, let's focus on consequence when 

10 we're making scoping decisions. And, we are 

11 committed, from a resource standpoint, and when you 

12 look at the outage scope coming up in this next 

13 outage, it's commensurate with consequence, not 

14 necessarily probability. 

15 There's a little nuance there, but that's 

16 kind of how we've focused, I think, the organization 

17 that it was important for us. 

18 COMMISSIONER BARAN: Thank you very much. 

19 CHAIRMAN BURNS: Thank you, 

20 Commissioner. 

21 One of the things, Mr. Dent, you touched 

22 on it and I think in the presentations, but perhaps 

23 you can elaborate some. 

24 You have, I think, what you have going is 

25 you, in effect, have two things in one. You have the 

26 notion of finishing strong apart from whether you're 
 132 

1 being, you know, or Pilgrim was in column 4, it would 

2 have that challenge in terms of communication, in 

3 terms of the workforce, you know, the workforce 

4 commitment, enthusiasm, whatever in terms of getting 

5 across, as you say, getting across the finish line in 

6 May 2019. 

7 The same token now we have in terms of 

8 the improvement processes, improvement initiatives 

9 that need to -- that focus on the column 4 status. 

10 Can you tell me, how is that sort of 

11 integrated or how is that finish strong sort of 

12 influencing, in effect, the corrective actions taken 

13 with respect to the column 4? 

14 Can you give me some sort of picture of 

15 how one influences the other or sort of absorbed or 

16 put together? 

17 MR. DENT: If I could just step back for 

18 a minute to answer -- 

19 CHAIRMAN BURNS: Sure. 

20 MR. DENT: -- that question in terms of 

21 speaking on behalf of the workforce. 

22 Prior to March of this year, there was 

23 anxiety within the workforce. 

24 CHAIRMAN BURNS: Yes. 

25 MR. DENT: Frankly, because we hadn't 

26 made the decision whether we were shutting down in 
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1 '17 or '19 and the other variable out there was the 

2 workforce didn't understand what their retention was 

3 going to be. 

4 So, what does this mean to me and family 

5 and my life? So, that was a distraction to the 

6 workforce. We're past all that now. 

7 So, there's an interesting, I don't know 

8 that I can completely explain it, but the workforce, 

9 maybe it's the demographic. I think 2019 fits into 

10 a large portion or a large demographic of the 

11 workforce life's plans, if you will. 

12 So, there's this sense of positive -- a 

13 positive energy within the workforce that is really 

14 heartening. It's really, I hate to say surprising, 

15 but given the circumstances, it's surprising. But, 

16 it's very, very encouraging. 

17 So, you couple that with running -- we're 

18 running multiple initial classes right now, three 

19 initial maintenance classes, initial license class, 

20 initial non-license class. We're bringing in folks 

21 from Fitzpatrick. 

22 We're actually able to attract people 

23 from within the industry that are at a different part 

24 in their career, at the end of their career because 

25 of the retention. So, we're able to draw that 

26 experience in. 
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1 So, you couple all that and there is an 

2 organizational momentum right now and this, like I 

3 said, this New England, there's a sense of this New 

4 England pride and this leaving a legacy of excellence 

5 resonates. 

6 I forgot who it was mentioned the folks 

7 from Vermont Yankee coming in with the spirit of 

8 finishing strong. Fitzpatrick has the same kind of 

9 a presence about them as an organization. And, 

10 that's kind of the groundswell that's coming up 

11 through the organization. 

12 So, we're, as far as the column 4 recovery 

13 is concerned, we're recovering. We've had 

14 independent, outside of Entergy, multiple 

15 organizations and individuals come in and say, you'd 

16 never know this plant's shutting down. You wouldn't 

17 be able to tell by the behaviors of the workforce. 

18 You just, in casual conversation, the organization we 

19 used Marathon to help us with recovery efforts, they 

20 were astonished by how positive and how engaged -- how 

21 the leadership team and workforce is interested in 

22 fostering more of that spirit of continuous learning. 

23 So, I know I said a lot, I'm not sure if 

24 I answered your question. 

25 CHAIRMAN BURNS: No, no, I think that's 

26 helpful. That's helpful, it does help elaborate. 
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1 One of the other things you talked about 

2 in terms of both in the initiative on finishing strong 

3 in terms of transparency, communication with the 

4 workforce, Pilgrim is, quite honestly, one of those 

5 plants that gets a lot of attention from the local 

6 community. 

7 How are you communicating what you're 

8 doing in the local community in Massachusetts? 

9 MR. DENT: Yes, we worked fairly 

10 extensively with the Selectmen in the township. We 

11 work a lot. Our recovery director, a guy by the name 

12 of Dave Noyes, is very engaged. Chip Perkins sitting 

13 behind me. 

14 So, we have a lot of engagement with the 

15 Selectmen. 

16 We're working on setting up an advisory 

17 committee that's more tailored towards going into the 

18 phase of decommissioning. So, there's a lot of work 

19 that goes on at that level and I think it's fairly 

20 effective. 

21 We've brought in just recently, it was 

22 just announced within the last day or two, another 

23 individual that had been at Pilgrim before that's 

24 responsible for that public relations kind of 

25 approach with the various stakeholders. 

26 So, we've got a few different prongs that 
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1 we're working through in terms of the outreach and 

2 engagement. So EWC, Entergy Wholesale Commodities, 

3 has a whole division that's basically dedicated to 

4 exactly that, not just with us, but with Fitzpatrick 

5 and Vermont Yankee and Indian Point as well. 

6 CHAIRMAN BURNS: Okay. Thanks very 

7 much. 

8 Commissioner Svinicki? 

9 COMMISSIONER SVINICKI: Well, thank you 

10 for your presentation and for your responses to my 

11 colleagues’ questions. 

12 We have covered quite a bit. I will ask 

13 one question, maybe I should have asked this also of 

14 the ANO, you've made very clear that your recovery 

15 plan does not begin and end at passing an inspection 

16 or exiting column 4. 

17 But, if I were to narrow my question and 

18 say, in terms of approaching significant inspection 

19 milestones or other regulatory milestones, is it 

20 clear to you what you need to do and what the 

21 expectations are? 

22 I guess I'm asking for some feedback in 

23 terms of our communications on regulatory 

24 expectations and the scope and intent of how we're 

25 going to assess various things as those milestones 

26 approach. 
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1 MR. DENT: Absolutely. So, I'll talk 

2 about something internally we're doing and my 

3 accountability to the guy sitting to my right. 

4 But, in terms of the, you know, all the 

5 way up to Mr. Dorman, and I hadn't gotten into this 

6 when I said I was aligned with his comments, the 

7 relationship that we have with the regulatory is very 

8 transparent and open and clear in terms of our 

9 communications. 

10 There wasn't one comment that Mr. Dorman 

11 made that surprised me or because we have that 

12 dialogue. We have that open communication channels 

13 at all levels, from the resident's office all the way 

14 up to Mr. Dorman. 

15 So, as far as the inspections coming 

16 down, we've had a lot of them, as we talked about, 

17 not just the phase alpha and bravo, but a lot of 

18 supplemental inspections. 

19 Not one of them have we not been crystal 

20 clear on what's expected and I don't expect that to 

21 change going forward. 

22 MR. VENTOSA: Just to add a little bit, 

23 I mean, because the Pilgrim experience was somewhat 

24 unique in that it was limited attributes. 

25 COMMISSIONER SVINICKI: That's true. 

26 MR. VENTOSA: So, the dialogue, from my 
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1 perspective, and the open communication is really 

2 critical from the very beginning and I have no 

3 negative feedback. It's been open both at a regional 

4 Branch Chief when they have a concern, they bring it 

5 up. And, we made sure that that dialogue is open 

6 from the beginning because there isn't a lot of 

7 precedent in that particular piece of column 4 for 

8 Pilgrim. 

9 So, feedback is, I believe, it's working 

10 well. 

11 COMMISSIONER SVINICKI: Okay. 

12 Thank you, Mr. Chairman. 

13 CHAIRMAN BURNS: Okay, thank you. 

14 Commissioner Ostendorff? 

15 COMMISSIONER OSTENDORFF: Thank you for 

16 your candid presentations. I was listening intently 

17 with respect to the morale, the shutdown in 2019 and 

18 it's good to hear that you're encouraged. 

19 But, my human nature experience indicates 

20 that that road will get tougher in the coming months, 

21 not easier. 

22 And so, I'm not saying I'm a skeptic, I 

23 believe what you're telling me, but I've seen a lot 

24 of organizations approaching end of life or outside 

25 the nuclear industry and I just would encourage 

26 constant vigilance in that area. I know it's going 
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1 to get -- I think it's going to get more difficult 

2 for you than -- as the 2019 approaches. 

3 That's all I have, thank you very much. 

4 CHAIRMAN BURNS: Okay. 

5 Well, thank you. Again, thanks for 

6 the -- thank you for the presentations. This has, 

7 as some of my colleagues have noted, this is one of 

8 the most important meetings we hold during the year 

9 to go over the assessment of performance within the 

10 industry, both. 

11 And we've spent a lot of time on in the 

12 reactor fleet, but also for the materials -- licensees 

13 that we have a responsibility for, both directly as 

14 NRC but also in cooperation with our colleagues in 

15 the Agreement States. 

16 I'm also pleased we've had this 

17 opportunity to hear from Entergy to address the plans 

18 for seeking improvement at both ANO and at Pilgrim. 

19 And, we're pleased to hear about the plans for 

20 improvement at those sites. 

21 Thank you all again and, with that, we 

22 are adjourned. 

23 (Whereupon, the above-entitled matter 

24 went off the record at 11:56 a.m.) 

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