PNP 2014-069, Reply to Inspection Report 05000255/2014007

Reply to Inspection Report 05000255/2014007

ML14199A559
Person / Time
Site:	Palisades
Issue date:	07/18/2014
From:	Gustafson O Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR-14-007, PNP 2014-069
Download: ML14199A559 (5)

Text

-Entergy

~ Entergy Entergy Nuclear Entergy Palisades 27780 Blue 27780 Nuclear Operations, Palisades Nuclear Blue Star Covert, MI Covert, Operations, Inc.

Nuclear Plant Plant Star Memorial Ml 49043 269-764-2000 269-764-2000 49043 Inc.

Memorial Highway Highway Otto W.

Otto W. Gustafson Gustafson Regulatory and Regulatory and Performance Performance Improvement Director Improvement Director PNP 2014-069 PNP 2014-069 18, 2014 July 18, U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

05000255/2014007 Reply to Inspection Report 05000255/2014007 Palisades Nuclear Plant Docket 50-255 License No. DPR-20

References:

Palisades Nuclear Plant - NRC Problem Identification and Resolution Report, 05000255/2014007, 05000255/2014007, dated June 20,2014 20, 2014 (ML (ML14171A394) 14171A394)

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. (ENO) hereby submits a reply to inspection report 05000255/20 14007 (Reference 1). The inspection report cover letter requests that a 05000255/2014007 response be provided within 30 days of the receipt of the letter that outlines actions taken, or planned, to further enhance the Palisades Security Safety Conscious Work Environment (SCWE) Action Plan to improve the SCWE in the Security Department.

Attachment 1 1 provides the response.

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

OWG/bed OW Gibed Attachment 1:1: Reply Reply to to Inspection Inspection Report Report 05000255/20 05000255/2014007 14007 CC CC Administrator, Region Region Ill, III, USNRC USNRC Project Project Manager, Manager, Palisades, Palisades, USN RC USNRC Resident Inspector, Palisades, USNRC Resident Inspector, Palisades, USNRC

ATTACHMENT 11 ATTACHMENT REPLY TO REPLY TO INSPECTION INSPECTION REPORT REPORT 05000255/2014007 05000255/2014007 33 pages pages follow follow

Actions added Actions added to to the the Security Security SCWE SCWE Action Action Plan:

Plan:

Action Action Commission an Commission an independent independent assessment assessment to: to:

(1) Gain (1) further understanding Gain further understanding of of the the current current state of SCWE state of SCWE within within Security.

Security.

(2) Gain insights (2) Gain insights regarding regarding achievements achievements of of the the recovery recovery SCWE SCWE improvement improvement efforts efforts and and additional actions that could additional actions that could be be taken taken at at Palisades Palisades to improve SCWE.

to improve SCWE.

Completed Completed Review conclusions Review conclusions and recommendations recommendations in in independent independent assessment assessment report report commissioned commissioned and and develop further develop further actions to strengthen Security Security SCWE Action Plan as necessary.

necessary.

Completed Completed Create aa "Questions Questions and Concerns" Concerns book to document questions raised by the Security Officers during the during the shift briefs that cannot be answered by the SSS or SOS that are present. This book will be reviewed by Security Management on aa daily basis to ensure assignment of action owners, due dates, reviewed and timely and timely feedback.

feedback.

Completed Completed Implement aa recurring activity for Security Management (Manager, Superintende Implement Superintendent,nt, and SOS's SOSs based on availability) on availability) to visit Security Officers in the field. The intent of the activity is to further reinforce communicati communications ons previously made, made, provide an additional forum for concerns to be discussed in aa one-on-one environment on-one environment, , and provide an opportunity for individual feedback. Structure the activity such that that all all four teams are routinely visited.

Completed Completed Implement Implement aa Supervisor Supervisor only only meeting meeting before before shift shift to ensure ensure proper coordination coordination,, alignment alignment and and understandin understanding g of of management management's s expectations expectations withwith all all the the supervisors.

Completed Completed Establish Establish aa Security Security Oversight Oversight Committee Committee monthly monthly meeting meeting with with the Site Vice the Site Vice President, President, General General Manager Manager Plant Plant Operations, Operations, Director Director Regulatory Regulatory & & Performance Performance Improvemen Improvement, t, Director Director of of Engineering, Engineering, and and select select Senior Senior Managers Managers to to discuss discuss challenges challenges and paths to and paths to resolutions resolutions for for various various Security issues.

Security issues. ThisThis agenda agenda will will include include Security Security Equipment Equipment Backlog, Backlog, Personnel Personnel Concerns, Concerns, Staffing Staffing and Training, Condition Reports and Training, Condition Reports of of interest, interest, and and Performance Performance Indicators.

Indicators.

Completed Completed 110f3 of 3

Security Manager Security Manager toto reschedule reschedule SOS SOS position position such such that that they they provide provide direct direct oversight oversight ofof their their respective Security respective Security Teams.

Teams.

Security Manager Security Manager toto provide provide clear clear direction direction toto SOS positions that SOS positions that any any differences inin team team standards are to are to be be eliminated.

eliminated.

Security Manager Security Manager toto provide provide clear clear expectations expectations to to SOS SOS positions positions that clear, concise, that clear, concise, and and timely communication isis a primary communication primary responsibility responsibility of that position.

position.

Security Manager to provide clear Security Manager clear expectations expectations to SOS positions that itit is their their responsibility to ensure aa Safety Conscious Work Environment (SCWE) is maintained.

Regulatory &

Director, Regulatory & Performance Improvement to establish performance goals for Security Management with respect to holding Security Supervision accountable for the SCWE of their respective teams.

Security Manager to develop Security department-specific survey tools to administer on a a team vs department basis.

Security Manager to administer department-specific survey tools to each Security team on a a quarterly basis. Closure of action must include initiation of new action to repeat due end of following quarter.

Security Manager to evaluate duration of SOS backshift assignment based on respective team performance.

Director, Regulatory & & Performance Improvement to assign aa mentor to the Security Department to assist the Security Manager in providing immediate feedback to improve interpersonal and communications skills and define the developmental needs of department supervision (e.g. SSS level and above).

Security Manager to create aa project project plan to capture key actions/information of importance regarding the SCWE Action Plan.

Security Manager to display project plan in in the Security Security shift briefing briefing room for routine communication withwith officers and supervisors.

Security Manager Manager toto update update project project plan on on aa monthly basis. Closure monthly basis. Closure ofof action action must must include include initiation initiation of of new new action action to repeat repeat due due end end ofof following month.

month.

Security Security Manager Manager toto establish establish aa process process for SOS review for SOS review of of new new or or revised revised procedures procedures withwith junior junior Security Security Officers Officers prior prior to to implementation implementation to to ensure ensure procedures procedures are are fully fully understood.

understood.

220f3 of 3

Security Manager Security Manager to share via to share via aa presentation presentation in in aa training training setting setting the the results of &

results of actions to

& actions to address address the independent the independent assessment assessment report report andand the the June June SCWE pulsing survey SCWE pulsing survey with with the the Security Security Force Force in in order to order validate conclusions to validate conclusions and and obtain obtain additional additional feedback.

feedback.

Security Manager Security Manager to to establish establish anan initial initial and and continuing continuing training training curriculum curriculum to:

to:

• • Eliminate potential Eliminate potential confusion confusion forfor SCWE, chilled chilled environment, environment, andand protected protected activity activity (SSS and Officers)

(SSS and Officers)

• • Focus on Focus on soft soft skills and conflict conflict resolution resolution (SSS and above)

(555 and above)

Use Fleet resources to develop the programprogram and to assist with delivering the training.

Manager to refine Security Manager refine and and reinforce Security Security liaison Liaison program (previously knownknown as Ombudsman)

Ombudsman) to establish dedicated interface time with their respective teams in order to ensure Security Officers familiar with their liaison and have opportunity to provide input.

are familiar Superintendent each to conduct one backshift work day once aa month and roll Security Manager and Superintendent up aa quarterly status report to Director, Regulatory & Performance Improvement. Improvement. Closure of action must include initiation of new action to repeat due end of following quarter.

Director, Regulatory & & Performance Improvement Improvement to implement aa Chilling Effect Mitigation Plan in accordance with EN-HR-138, Executive Review Board Process for Employees, to address perceptions regarding Security department employment decisions made during the 2013 Human Capital regarding Management initiative.

Director, Regulatory & Performance Improvement Improvement to establish an effectiveness review of Security Improvement Actions. This assessment will be conducted within six months, by aa team to SCWE Improvement include external subject matter experts, and involve aa smart sample of individuals previously and not previously interviewed.

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