ML18226A085
| ML18226A085 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/09/2018 |
| From: | Brian Sullivan Entergy Nuclear Operations |
| To: | David Lew Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 1 |
| References | |
| 2.18.047 | |
| Download: ML18226A085 (9) | |
Text
- ~Entergy Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Brian R. Sullivan Site Vice President Letter Number 2.18.047 August9,2018 Mr. David C. Lew Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713
SUBJECT:
Notification of Changes to Comprehensive Recovery Plan Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35
REFERENCES:
- 1. NRC letter to Entergy, "Confirmatory Action Letter - Pilgrim Nuclear Power Station," dated August 2, 2017 (ML17214A088)
Dear Mr. Lew:
On August 2, 2017, the NRC transmitted the Pilgrim Nuclear Power Station (PNPS) Confirmatory Action Letter (CAL) (Reference 1) which confirmed the actions PNPS planned to take in accordance with our Comprehensive Recovery Plan (CRP).
An ongoing review has identified that a number of CRP action changes are appropriate to ensure the wording of the actions better align with the intent of the action and actions taken. These changes to the CRP require notification to the NRC pursuant to the CAL.
Details of the proposed changes are provided in Attachment 1.
If you have any questions or require additional information, please contact Mr. Peter J. Miner at (508) 830-7127.
Sincerely,
~
BRS/rb
Entergy Nuclear Operations, Inc. Letter No. 2.18.047 Pilgrim Nuclear Power Station Page 2 of 2 cc:
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Mr. John Lamb, Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8C2A Washington, DC 20555-0001 NRG Senior Resident Inspector Pilgrim Nuclear Power Station
Attachment 1 Letter Number 2.18.047 Notification of Changes to Comprehensive Recovery Plan
Notification of Changes to Comprehensive Recovery Plan When interim actions EOC-3 / CA- When interim actions EOC-3 / CA-15 and 4 These corrective action program mentoring and 15 and 4/ CA-16 are closed, assign / CA-16 are closed, assign a part-time (two coaching actions are performed by a team of a part-time (two weeks per month) weeks per month minimum) SME to coach three individuals. Two individuals designated as SME to coach and mentor DPIC and and mentor DPIC and CAP performance SM Es in the recovery action plan independently CAP performance and and independently review RCEs and ACAs review causal products, coach and correct independently review RCEs and to acquire the data for populating the CAP Performance Improvement Review Group (PRG)
ACEs to acquire the data for Performance Indicators. Mentoring and behaviors, and populate the CAP Performance CAP- populating the CAP Performance coaching may be performed by contracted Indicators. A third individual, designated as a 1.2 Indicators. consultants designated as SMEs or mentor in the recovery action plan, coaches and Mentors. corrects Department Performance Improvement Coordinator (DPIC) behaviors. This reflects division of work responsibilities and exceeds the intended interactions designated in the original action. Updated abbreviation of the cause analysis from ACE to ACA to match current procedure terminolog .
Generate the CAP SME monthly Generate the CAP SME status report for CAP SME status reports were initially-completed status report for July 2016 July 2016 (performed by the CAP SME on a monthly basis. A change to quarterly allows (performed by the CAP SME required in CA 74}. Also generate a new for an appropriate period to discern performance required in CA 74). Also generate a CA to require each additional report in the trends with no impact on the intent of the action.
CAP-new CA to require each additional same fashion. These status reports must 1.5 monthly report in the same fashion. continue until end of plant operating life on These monthly status reports must a frequency not to exceed quarterly.
continue until end of plant operating life.
Based upon the results of CR PNP- Based upon the results of CR PNP-2016- Entergy procedure EN-FAP-OM-016 did not have 2016-2061, CA-24, reapportion the 2061, CA-24, reapportion the workload of a requirement of 25%, rather it was a goal. The workload of the System Engineering the System Engineering Supervisors such procedure has been revised to no longer specify Supervisors such that they have an that they have an adequate amount of time any value. There is no change to the standard EP-2.2 adequate amount of time (25% is available for mentoring and supervising contained in the original action.
required by EN-FAP-OM-016} of their staff, excluding PCRS time. Work load their time available for mentoring is discussed during the EN-FAP-OM-016 and supervising their staff, excluding "Monthly Performance Management PCRS time. Meeting" process.
Letter Number 2.18.047 Attachment 1 Page 1 of 6
Notification of Changes to Comprehensive Recovery Plan
- .CAL Action** Current CAL Action Description Proposed CAL .Action Description Reason tor.Change Determine the estimated man-hours Reassess the additional resources brought This change replaces the work management required to reduce backlogs and in under CR PNP-2016-2057, CA-41. As supply and demand model with an equivalent maintain fleet performance goals part of that assessment, perform the method for resource assessment, and adds the using the CFAM work management following: requirement to provide additional staffing if ER-2.2 supply and demand model. necessary to reduce backlogs and maintain fleet Determine the estimated man-hours performance goals.
required to reduce backlogs and maintain fleet performance goals and procure additional contract resources if necessary.
Track the completion of the Track the completion of the mitigation The revised wording presents no change in intent.
mitigation strategies for the 4 open strategies for the 4 open unmitigated Single The revised wording allows for the fact that one of unmitigated Single Point Point Vulnerabilities at PNPS. The the open unmitigated Single Point Vulnerabilities Vulnerabilities at PNPS. These are mitigation strategies for the 4 open was actually mitigated prior to the start of RF0-21.
scheduled to be completed during unmitigated Single Point Vulnerabilities will RF021 and include the following: be completed prior to startup from RF021
- Replace Feedwater Level A/B and include the following:
Channel Selector Switch (604-301 ),
- Replace Feedwater Level A/B Channel if required based on scheduled Selector Switch (604-301 ), if required ER-3.2 testing based on scheduled testing
- Replace Feedwater Level Control
- Replace Feedwater Level Control Single Single Element I Three Element Element I Three Element Selector Switch Selector Switch (604- 302), if (604- 302), if required based on scheduled required based on scheduled testing testing
- Perform Motor Rewind on Sea
- Perform Motor Rewind on Sea Water Water Pump B (P-1058) Pump B (P-1058)
- Perform Startup Transformer
- Perform Startup Transformer CCVT CCVT Inspections and Testing (X4) Inspections and Testing (X4)
Conduct Focused Self-Assessments Conduct crew observations for each crew CAL item OPS-2 is to "Improve the operations OPS-of Operator Fundamentals for each using EN-OP-117 "Operations Assessment department "Picture of Excellence" with regard to 2.2 shift crew using the position specific Resources" "Operator Fundamentals operations standards, ownership, and leadership".
Letter Number 2.18.047 Attachment 1 Page 2 of 6
Notification of Changes to Comprehensive Recovery Plan
.. CAil . >*
Action* * . .Current CA.tActie>n Descriptiori *. .. Proposed CAL *Action .Description Reason for Change':
"Roles and Responsibilities" Grading Sheets (IER L1-11-3)". The EN-OP-120 "Operator Fundamental Program" is a attachments in EN-OP-120, assessment teams should include program document that does not establish Operator Fundamentals Program. resources external to Pilgrim. discrete criteria necessary to assess standards, The assessment teams should ownership, and leadership. The grading sheet include industry peers. established in EN-OP-117 aligns with more effective assessment of standards, ownership, and leadership by establishing discrete observation and comment criteria for assessment teams.
Site department managers Site department managers communicate The proposed revision allows for an equivalent communicate senior management's senior management's procedure use and number of interactions while allowing for some PUA-procedure use and adherence adherence expectations utilizing a different flexibility in schedule and still meeting the intent of 1.6/5.9 expectations once per quarter for a quarter's data not less than 4 times. the action.
year.
Perform Procedure Use and Perform Procedure Use and Adherence This change clarifies that the requirement to Adherence observations using the observations using the 95003 Recovery perform Procedure Use and Adherence 95003 Recovery Human Human Performance WILL Sheet criteria observations using the 95003 Recovery Human Performance WILL Sheet concurrently with performance of HU Performance WILL Sheet criteria must continue concurrently with performance of HU observations for the assessment period of until both a successful Procedure Use and PUA-observations for the assessment not less than one year. The Procedure Use Adherence effectiveness review _has been 2.3 period of one year, June 1, 2016 and Adherence observations using the completed and no less than one year of through June 1, 2017, or until 95003 Recovery Human Performance WILL observations have been completed. This change closure of Procedure Use and Sheet criteria will continue until closure of also allows the use of recent data which is most Adherence effectiveness review. Procedure Use and Adherence indicative of current behaviors.
effectiveness review.
Communicate the PU&A Lessons Communicate the PU&A Lessons The data that provides behavior performance Learned/Results from the PU&A Learned/Results from the PU&A 95003 information is the rating of the Procedure Use and 95003 Recovery WILL sheet as Recovery WILL sheet attribute ratings Adherence attributes listed on the WILL Sheet.
analyzed in Monthly Snap Shot quarterly via L&A meetings. The phrase "in Monthly Snap Shot Assessments" PUA-Assessments quarterly via L&A has been deleted because Snap Shot 3.4 meetings. assessments have been deleted from the Entergy self-assessment procedure (EN-Ll-104). The intent of communicating lesson learned and observation results are unchanqed.
Perform observations of leadership Perform observations of leadership This action is equivalent to the previous action RRDM-performance against the leadership performance against the leadership and the change provides the proper clarity of the 1.1 expectations established in CAPR-1 expectations established in CAPR-1 and documentation of observations and the audience Letter Number 2.18.047 Attachment 1 Page 3 of 6
Notification of Changes to Comprehensive Recovery Plan
,CAL
- Action Current CAL Action Description Proposed CAL Action Description Reason for Change and provide feedback to that document the observations in Leadership to which the feedback is communicated. No leader's Manager or Director. WILL Sheets. Roll these observations up changes were made to the actions originally Provide a summary of the into a periodic report and share this report committed.
observations of leadership with key site leadership personnel including performance to the site vice applicable managers or directors. Provide a president at a frequency agreed to summary of the observations of leadership by the site vice president and the performance to the SVP on a once every subject-matter expert. This action two week basis, or at a frequency agreed to will remain in place until the end of by the SVP and SME. This action will plant operating life or the remain in place until the end of plant effectiveness reviews determine that operating life or the effectiveness reviews leadership behaviors are meeting determine that leadership behaviors are established expectations and are meeting established expectations and are self-sustaininq. self-sustaininq.
Augment the station staff with an Augment the station staff with an external This action is equivalent to the previous action in external subject matter expert (SME) subject matter expert (SME) in the area of that SME observation, assessment, and feedback in the area of risk assessment as a risk assessment as a full-time equivalent is being done on a shared basis with other focus full-time position to mentor and position to mentor and assess individual areas closely linked to risk recognition and assess individual leadership leadership behaviors and performance decision-making. This is considered a clarification behaviors and performance against against the leadership expectations of the established SME role and acknowledges the leadership expectations established in CAPR-1. The position will be that a team approach is used to broaden diversity RRDM- established in CAPR-1. part of the overall Recovery mentor team of the independent evaluations. No changes were 1.2 covering RRDM, Equipment Reliability, made to the actions originally committed. Added Operations Standards, and Leadership the termination criteria from RRDM-1.1 for clarity.
Behaviors. This action will remain in place until the end of plant operating life or the effectiveness reviews determine that leadership behaviors are meeting established expectations and are self-sustaining.
Letter Number 2.18.047 Attachment 1 Page 4 of 6
Notification of Changes to Comprehensive Recovery Plan CAL Action. Current CAL Action Description Proposed CAL Action Description Reason for Change Management T-week sponsors to The T-week management sponsors CR-PNP-2017-6767 ACE was performed in July provide management oversight and complete a 'PNPS T-Meeting Observer 2017 when the WM Problem Area previous coaching for work week preparation Familiarization Guide' which requires work actions were deemed not being fully effective to meetings. The sponsors/designees management process discussions for the T- improve WM performance. This action provides attendance and coaching will be week process, guiding principles, desired steps for ensuring consistent management documented using the meeting WILL and undesired behaviors, and the risk oversight and reinforcement of desired behaviors WM- sheets. assessment overview. The 'PNPS T- such as, key roles and responsibilities supporting 1.1 Meeting Observer Familiarization Guide' the WM process. The action improves also provides scorecard guidelines for sustainability by using a standard approach for management sponsors use when coaching WM T-week desired behaviors.
performing T-meeting observations and coaching. Demonstrate effectiveness by sampling completed WM scorecards/WILL sheets for T-meetinQ performance.
For the time period of 11/01/16 The T-week management sponsors CR-PNP-2017-6767 ACE was perform~d in July through 4/30/17 the T-week meeting complete a 'PNPS T-Meeting Observer 2017 when the WM Problem Area previous management sponsors or designees Familiarization Guide' which requires work actions were deemed not being fully effective to will be required quorum members for management process discussions for the T- improve WM performance. This action provides a the meeting. This will be week process, guiding principles, desired more effective process for ensuring consistent documented using the meeting WILL and undesired behaviors, and the risk management oversight and reinforcement of WM- sheets. assessment overview. The 'PNPS T- desired behaviors as key roles and responsibilities 1.3 Meeting Observer Familiarization Guide' supporting the WM process. The action improves also provides scorecard guidelines for sustainability by using a standard approach for management sponsors use when coaching WM T-week desired behaviors.
performing T-meeting observations and coaching. Demonstrate effectiveness by sampling completed WM scorecards/WILL sheets for T-meeting performance.
Letter Number 2.18.047 Attachment 1 Page 5 of 6
Notification of Changes to Comprehensive Recovery Plan CAL
,Action '... C:um~htCAL Actiori Descripticin , Proposed CAL Action
Description:
'
- Beason for Change~ .
- ' . :=' ., ' ' ' ' .. *c, ' '
Reassess the additional resources Reassess the additional resources brought This change replaces the work management brought in under CR PNP-2016- in under CR PNP-2016-2057, CA-41. As supply and demand model with an equivalent 2057, CA-41. As part of that part of that assessment, perform the method for resource assessment, and adds the assessment, perform the following: following: requirement to provide additional staffing if Design and implement a resource- necessary to reduce backlogs and maintain fleet loading plan for maintenance shops Determine the estimated man-hours performance goals.
WM- based on the workload expectations required to reduce backlogs and maintain 3.3 for the remaining 2 years of plant fleet performance goals and procure life. additional contract resources if necessary.
Determine the estimated man-hours required to reduce backlogs and maintain fleet performance goals using the CFAM work management supply and demand model.
Letter Number 2.18.047 Attachment 1 Page 6 of 6