PNP 2014-069, 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
References:
Palisades Nuclear Plant Docket 50-255 License No. DPR-20 Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043 269-764-2000 Otto W. Gustafson Regulatory and Performance Improvement Director Palisades Nuclear Plant NRC Problem Identification and Resolution Report, 05000255/2014007, dated June 20, 2014 (ML14171A394)
Dear Sir or Madam:
Entergy Nuclear Operations, Inc. (ENO) hereby submits a reply to inspection report 05000255/2014007 (Reference 1). The inspection report cover letter requests that a 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. provides the response.
This letter contains no new commitments and no revisions to existing commitments. : Reply to Inspection Report 05000255/2014007 CC Administrator, Region Ill, USNRC Project Manager, Palisades, USN RC Resident Inspector, Palisades, USNRC Entergy PNP 2014-069 July 18, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Reply to Inspection Report 05000255/2014007 OWG/bed
-~ Entergy PNP 2014-069 July 18, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 269-764-2000 Otto W. Gustafson Regulatory and Performance Improvement Director
SUBJECT:
Reply to Inspection Report 05000255/2014007
References:
Palisades Nuclear Plant Docket 50-255 License No. DPR-20 Palisades Nuclear Plant - NRC Problem Identification and Resolution Report, 05000255/2014007, dated June 20,2014 (ML14171A394)
Dear Sir or Madam:
Entergy Nuclear Operations, Inc. (ENO) hereby submits a reply to inspection report 05000255/2014007 (Reference 1). The inspection report cover letter requests that a 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. provides the response.
This letter contains no new commitments and no revisions to existing commitments.
OW Gibed : Reply to Inspection Report 05000255/2014007 CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
ATTACHMENT 1 REPLY TO INSPECTION REPORT 05000255/2014007 3 pages follow ATTACHMENT 1 REPLY TO INSPECTION REPORT 05000255/2014007 3 pages follow
Actions added to the Security SCWE Action Plan:
Action Commission an independent assessment to:
(1) Gain further understanding of the current state of SCWE within Security.
(2) Gain insights regarding achievements of the recovery SCWE improvement efforts and additional actions that could be taken at Palisades to improve SCWE.
Completed Review conclusions and recommendations in independent assessment report commissioned and develop further actions to strengthen Security SCWE Action Plan as necessary.
Completed Create a Questions and Concerns book to document questions raised by the Security Officers 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 a daily basis to ensure assignment of action owners, due dates, and timely feedback.
Completed Implement a recurring activity for Security Management (Manager, Superintendent, and SOSs based on availability) to visit Security Officers in the field. The intent of the activity is to further reinforce communications previously made, provide an additional forum for concerns to be discussed in a one-on-one environment, and provide an opportunity for individual feedback. Structure the activity such that all four teams are routinely visited.
Completed Implement a Supervisor only meeting before shift to ensure proper coordination, alignment and understanding of managements expectations with all the supervisors.
Completed Establish a Security Oversight Committee monthly meeting with the Site Vice President, General Manager Plant Operations, Director Regulatory & Performance Improvement, Director of Engineering, and select Senior Managers to discuss challenges and paths to resolutions for various Security issues. This agenda will include Security Equipment Backlog, Personnel Concerns, Staffing and Training, Condition Reports of interest, and Performance Indicators.
Completed 1 of 3 Actions added to the Security SCWE Action Plan:
Action Commission an independent assessment to:
(1) Gain further understanding of the current state of SCWE within Security.
(2) Gain insights regarding achievements of the recovery SCWE improvement efforts and additional actions that could be taken at Palisades to improve SCWE.
Completed Review conclusions and recommendations in independent assessment report commissioned and develop further actions to strengthen Security SCWE Action Plan as necessary.
Completed Create a "Questions and Concerns" book to document questions raised by the Security Officers 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 a daily basis to ensure assignment of action owners, due dates, and timely feedback.
Completed Implement a recurring activity for Security Management (Manager, Superintendent, and SOS's based on availability) to visit Security Officers in the field. The intent of the activity is to further reinforce communications previously made, provide an additional forum for concerns to be discussed in a one-on-one environment, and provide an opportunity for individual feedback. Structure the activity such that all four teams are routinely visited.
Completed Implement a Supervisor only meeting before shift to ensure proper coordination, alignment and understanding of management's expectations with all the supervisors.
Completed Establish a Security Oversight Committee monthly meeting with the Site Vice President, General Manager Plant Operations, Director Regulatory & Performance Improvement, Director of Engineering, and select Senior Managers to discuss challenges and paths to resolutions for various Security issues. This agenda will include Security Equipment Backlog, Personnel Concerns, Staffing and Training, Condition Reports of interest, and Performance Indicators.
Completed 10f3
Security Manager to reschedule SOS position such that they provide direct oversight of their respective Security Teams.
Security Manager to provide clear direction to SOS positions that any differences in team standards are to be eliminated.
Security Manager to provide clear expectations to SOS positions that clear, concise, and timely communication is a primary responsibility of that position.
Security Manager to provide clear expectations to SOS positions that it is their responsibility to ensure a Safety Conscious Work Environment (SCWE) is maintained.
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 team vs department basis.
Security Manager to administer department-specific survey tools to each Security team on 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 a 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 a project plan to capture key actions/information of importance regarding the SCWE Action Plan.
Security Manager to display project plan in the Security shift briefing room for routine communication with officers and supervisors.
Security Manager to update project plan on a monthly basis. Closure of action must include initiation of new action to repeat due end of following month.
Security Manager to establish a process for SOS review of new or revised procedures with junior Security Officers prior to implementation to ensure procedures are fully understood.
2 of 3 Security Manager to reschedule SOS position such that they provide direct oversight of their respective Security Teams.
Security Manager to provide clear direction to SOS positions that any differences in team standards are to be eliminated.
Security Manager to provide clear expectations to SOS positions that clear, concise, and timely communication is a primary responsibility of that position.
Security Manager to provide clear expectations to SOS positions that it is their responsibility to ensure a Safety Conscious Work Environment (SCWE) is maintained.
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 team vs department basis.
Security Manager to administer department-specific survey tools to each Security team on 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 a 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 a project plan to capture key actions/information of importance regarding the SCWE Action Plan.
Security Manager to display project plan in the Security shift briefing room for routine communication with officers and supervisors.
Security Manager to update project plan on a monthly basis. Closure of action must include initiation of new action to repeat due end of following month.
Security Manager to establish a process for SOS review of new or revised procedures with junior Security Officers prior to implementation to ensure procedures are fully understood.
20f3
Security Manager to share via a presentation in a training setting the results of & actions to address the independent assessment report and the June SCWE pulsing survey with the Security Force in order to validate conclusions and obtain additional feedback.
Security Manager to establish an initial and continuing training curriculum to:
Eliminate potential confusion for SCWE, chilled environment, and protected activity (SSS and Officers)
Focus on soft skills and conflict resolution (555 and above)
Use Fleet resources to develop the program and to assist with delivering the training.
Security Manager to refine and reinforce Security Liaison program (previously known as Ombudsman) to establish dedicated interface time with their respective teams in order to ensure Security Officers are familiar with their liaison and have opportunity to provide input.
Security Manager and Superintendent each to conduct one backshift work day once a month and roll up a quarterly status report to Director, Regulatory & Performance Improvement. Closure of action must include initiation of new action to repeat due end of following quarter.
Director, Regulatory & Performance Improvement to implement a 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 Management initiative.
Director, Regulatory & Performance Improvement to establish an effectiveness review of Security SCWE Improvement Actions. This assessment will be conducted within six months, by a team to include external subject matter experts, and involve a smart sample of individuals previously and not previously interviewed.
3 of 3 Security Manager to share via a presentation in a training setting the results of & actions to address the independent assessment report and the June SCWE pulsing survey with the Security Force in order to validate conclusions and obtain additional feedback.
Security Manager to establish an initial and continuing training curriculum to:
Eliminate potential confusion for SCWE, chilled environment, and protected activity (SSS and Officers)
Focus on soft skills and conflict resolution (SSS and above)
Use Fleet resources to develop the program and to assist with delivering the training.
Security Manager to refine and reinforce Security liaison program (previously known as Ombudsman) to establish dedicated interface time with their respective teams in order to ensure Security Officers are familiar with their liaison and have opportunity to provide input.
Security Manager and Superintendent each to conduct one backshift work day once a month and roll up a quarterly status report to Director, Regulatory & Performance Improvement. Closure of action must include initiation of new action to repeat due end of following quarter.
Director, Regulatory & Performance Improvement to implement a 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 Management initiative.
Director, Regulatory & Performance Improvement to establish an effectiveness review of Security SCWE Improvement Actions. This assessment will be conducted within six months, by a team to include external subject matter experts, and involve a smart sample of individuals previously and not previously interviewed.
30f3