ML091760710
| ML091760710 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/01/2009 |
| From: | Schwarz C Entergy Nuclear Operations |
| To: | Carpenter C NRC/OE |
| Arrighi R, OE | |
| References | |
| 3-2005-010 | |
| Download: ML091760710 (4) | |
Text
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 269.764.2265 Christopher J. Schwarz Palisades Site Vice President Entergy Nuclear Operations, Inc June 1,2009 U. S. Nuclear Regulatory Commission Mail Stop 014E1 1 1555 Rockville Pike Rockville, MD 20852 ATTN: Cynthia A. Carpenter
SUBJECT:
Request to Relax a Confirmatory Order Condition Palisades Nuclear Plant Docket 50-255 License No. DPR-20
REFERENCES:
NRC letter to Nuclear Management Company, LLC, dated January 3, 2007, regarding Confirmatory Order (Effective Immediately) (Office of Investigation Report No. 3-2005-01 0)
Dear Sir or Madam:
By letter dated January 3,2007, a Confirmatory Order was issued to the Nuclear Management Company, LLC (NMC) and the four nuclear power plants for which it was the operator and facility operating license holder as part of a settlement agreement between NMC and the U.S. Nuclear Regulatory Commission (NRC). The Order was issued to NMC following mediation using the NRC's alternative dispute resolution (ADR) process for an apparent violation of 10 CFR 50.7, "Employee protection," at Point Beach Nuclear Plant (PBNP).
At the time the Order was issued, the operating license for PBNP was held, and PBNP was operated, by NMC. Also at that time, the operator and operating license holder for Palisades Nuclear Plant (PNP) was NMC. On April 11,2007, Consumers Energy sold PNP to Entergy Nuclear Operations, Inc (ENO) and EN0 became the owner, operator, and holder of the facility operating license.
The purpose of this letter is to request a relaxation to a section of condition 3 of the Order for PNP. The relevant section of condition 3 requires that:
New employees holding supervisory positions and higher shall be trained on SCWE principles within nine (9) months of their hire dates unless within the previous two years of their hire dates, they've had the same or equivalent SCWE training.
EN0 is requesting a change to condition 3 to permit new employees holding supervisory positions and higher be trained on Safety Conscience Work Environment (SCWE) principles within 12 months of their hire dates versus the Order-required 9 months. This change would
Document Control Desk Page 2 allow PNP to align its supervisory training program with the EN0 fleet supervisory training program for both initial and continuing training requirements.
There is good cause to relax the condition from a "within nine-month period to "within a twelve-month" period. The EN0 fleet has established programs for SCWE contained in policy EN-PL-187, "SCWE Policy," and policy EN-PL-190, "Maintaining a Strong Safety Culture.
These policies establish and nurture a robust safety culture. Because a SCWE has become a core value of ENO, principles of SCWE permeate the culture at EN0 plants, including PNP, such that new personnel are exposed to it organizationally before being introduced to it in a formal instructional setting.
Additionally, EN0 has a comprehensive Employee Concerns Program (ECP) implemented by procedure EN-EC-100 "Guidelines for Implementation of the Employee Concerns Program."
ECP Coordinators are designated as contacts for employee concerns. They are well versed in the process, and promote their availability and function throughout the organization. This ensures all employees are aware of the options available to them prior to being formally trained in SCWE.
At PNP, the ECP Coordinator has been performing monthly SCW E surveys to help assess the acceptance of the SCWE program. The survey consists of twelve questions and one or two departments are surveyed each month. During 2008,439 surveys were returned for a 68%
response rate. The ECP Coordinator has evaluated the survey results as supporting a SCWE at PNP. Additionally, in February 2009, the PhlP Site Vice President sent site personnel a communication strongly supporting the raising of safety concerns. In the communication, the Site Vice President also solicited plant supervisors to sign a statement that is a "Supervisor's SCWE Commitment" which is to be posted in the supervisor's work area. These are visible signs of the commitment by the site leadership in a SCWE.
In addition, in June 2009, Entergy will be soliciting employee feedback on the strength of its nuclear safety culture and safety conscious work environment by administering an EN0 fleet-wide nuclear safety culture assessment. The assessment will involve nuclear employees and contractors and will present EN0 with the opportunity to measure fleet progress against previous assessments. Entergy will develop and implement actions resulting from the analysis of the survey using fleet processes.
Previous survey feedback has resulted in the establishment of several new fleet processes. The Executive Review Board (ERB) is an independent body that reviews personnel actions to make sure those actions are consistent with company policies and practices and are not in any way connected to an individual's engaging in protected activity. The Executive Protocol Group (EPG), another independent body, provides general oversight of the nuclear safety culture and SCWE and provides advice and assistance to senior management in responding to issues that have the potential to adversely affect the site's nuclear safety culture or SCWE. Both of these initiatives are focused on sustaining work environment improvements and have been implemented as a direct result of previous survey feedback.
As result of these justifications, coupled with an overall positive SCWE at PNP, EN0 has concluded that extending by three months (from within 9 months of assignment to within 12 months of assignment) the required due date for the initial training of employees holding supervisory positions and higher, who have not had formal training on SCWE principles within the previous two years, is appropriate. The change is necessary to permit the alignment of initial supervisory training at PNP with that of the other nine nuclear plants in the EN0 nuclear fleet.
Document Control Desk Page 3 The proposed change to the Order is enclosed. If you have questions regarding this matter, please contact Edward Weinkam, Senior Manager, Licensing at 612-840-81 81.
Sincerely, Attachment(s):
Confirmatory Order with proposed changes to section IV, condition 3 CC Administrator, Region Ill, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
Attachment CONFIRMATORY ORDER WITH PROPOSED CHANGES TO SECTION IV, CONDITION 3 Page 1 of 1