ML18352A753

Notification of Changes to Comprehensive Recovery Plan

ML18352A753
Person / Time
Site:	Pilgrim
Issue date:	12/13/2018
From:	Brian Sullivan Entergy Nuclear Operations
To:	David Lew Office of Nuclear Reactor Regulation, NRC Region 1
References
2.18.060
Download: ML18352A753 (6)

Text

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Brian R. Sullivan Site Vice President Letter Number 2.18.060 December 13, 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 U.S. Nuclear Regulatory Commission (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).

During review of Nuclear Safety Culture (NSC) closure packages in advance of the December confirmatory inspection, PNPS has determined that minor clarifications are appropriate for a number of the actions. Accordingly, clarifications to NSC-1.1, NSC-1.5, NSC-2.2, NSC-2.3 and NSC-8.9 are provided in Attachment 1.

If you have any questions or require additional information, please contact Mr. Peter J. Miner at (508) 830-7127.

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Entergy Nuclear Operations, Inc. Letter No. 2.18.060 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 0-9012 Washington, DC 20555-0001 NRC Senior Resident Inspector Pilgrim Nuclear Power Station

Attachment 1 Letter Number 2.18.060 Notification of Changes to Comprehensive Recovery Plan

Notification of Changes to Comprehensive Recovery Plan

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Implement the Individual Targeted Implement the Individual Targeted *The reference to CR-PNP-2016-Performance Improvement Plans (TPIP) Performance Improvement Plans {TPIP) 2052 CA-35 in the 1st sentence of developed from CR PNP-2016-2052, for the GMPO and Directors (Senior the CAL action has been revised to CA-35 utilizing the guidance contained Leaders) developed from CR PNP-2016- CA-36 to correct a typographical in EN-FAP-HR-006, Fleet Approach to 2052, CA-36 utilizing the guidance error.

Leadership Development & contained in EN-FAP-HR-006, Fleet Organizational Effectiveness. Document Approach to Leadership Development & The GMPO and Directors have NSC-review plan progress as determined Organizational Effectiveness. Document been added to the 1st sentence to 1.1 during the individual Monthly review plan progress as determined during clarify the intent of this action.

Performance Management Meetings to the individual Monthly Performance ensure sufficient evidence exists for Management Meetings to ensure sufficient plan closures. When a Senior Leader evidence exists for plan closures. When a has positively satisfied their TPIP Senior Leader has positively satisfied their objectives, the Site Vice President TPIP objectives, the Site Vice President SVP can close the TPIP. SVP) can close the TPIP.

Implement the Individual Targeted Develop and implement Individual The reference to CR-PNP-2016-Performance Improvement Plans (TPIP) Targeted Performance Improvement Plans 2052 CA-35 in the 1st sentence of developed from CR PNP-2016-2052, (TPI P) for Managers, Superintendents and the CAL action has been revised to CA-35 utilizing the guidance contained Supervisors using the criteria listed in CR- CA-36 to correct a typographical in EN-FAP-HR-006, Fleet Approach to PN P-2016-2052, CA-36 and utilizing the error.

Leadership Development & guidance contained in EN-FAP-HR-006, Organizational Effectiveness. Document Fleet Approach to Leadership Managers, Superintendents, and NSC- review plan progress as determined Development & Organizational Supervisors have been added to 1.5 during the individual Monthly Effectiveness. Document review plan the 1st sentence, along with the Performance Management Meetings to progress as determined during the action to develop and implement ensure sufficient evidence exists for individual Monthly Performance individual TPIPs, to clarify the intent plan closures. When a Senior Leader Management Meetings to ensure sufficient of this action. In addition, the last has positively satisfied their TPIP evidence exists for plan closures. When a sentence has been revised to objectives, the SVP can close the TPIP. leader has positively satisfied their TPIP identify that the one-up leader will objectives, the one-up leader can close the close the TPIPs.

TPIP.

Letter Number 2.18.060 Attachment 1 Page 1 of 3

Notification of Changes to Comprehensive Recovery Plan

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Rollout the PNPS Employee handbook Rollout the PNPS Employee handbook (or The word "meeting" has been (or equivalent) to site personnel. The equivalent) to site personnel. The rollout removed from the second sentence rollout meeting should include: should include: and the first bulleted phrase to

• Senior Leaders (Senior Manager or

• Senior Leaders (Senior Manager or clarify that the roll out was above) facilitating in the rollout meeting above) facilitating the rollout to ensure conducted in two steps not in a to ensure effective communications and effective communications and meeting format. The intent and NSC- understanding of the commitment to the understanding of the commitment to the actions taken to meet this CAL 2.2 handbook and its use. handbook and its use. requirement remain unchanged.

• Individuals signing for their copy of

• Individuals signing for their copy of PNPS PNPS Employee Handbook and Employee Handbook and The word "in" in the 1st bulleted acknowledgement of expectations for acknowledgement of expectations for use. sentence following the word use. "facilitating" has been removed to improve the readability of the sentence.

Conduct alignment sessions with station Conduct alignment sessions with station Change of wording from "Site Vice leadership on the content and leadership on the content and President" to "Station Senior implementation expectations on the implementation expectations on the PNPS Management" to more correctly PNPS handbook (or equivalent) based handbook (or equivalent) based on the describe the handbook roll out and on the EN-PL-100, Nuclear Excellence EN-PL-100, Nuclear Excellence Model alignment. Although the SVP was Model (PNPS's vision, mission, (PNPS's vision, mission, strategy, goals, present in the process and during strategy, goals, core values, attributes core values, attributes of leader and meetings providing his leadership, of leader and individual behaviors), and individual behaviors), and site-specific guidance and oversight of the site-specific recovery procedure EN-OM recovery procedure EN-OM XXX-PNP-RC alignment sessions, the NSC-XXX-PNP-RC (Created in CR PNP- (Created in CR PNP-2016-2052, CA-39). presentations were created and led 2.3 2016-2052, CA-39). These sessions will These sessions will be led by Station by station senior managers. CAP be led by the Site Vice President and Senior Management and focus on and ACRB closure packages focus on establishing accountability for establishing accountability for high provide documentation of the high standards of performance to align standards of performance to align station senior management behaviors in support of a strong nuclear behaviors in support of a strong nuclear presentation.

safety culture. Station Leadership safety culture. Station Leadership includes includes first line supervisor level up to first line supervisor level up to Director and Director and General Manager-Plant General Manager-Plant Operations 0 erations GMPO level. GMPO level.

Letter Number 2.18.060 Attachment 1 Page 2 of 3

Notification of Changes to Comprehensive Recovery Plan

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Reinforce the use of Entergy's Reinforce the use of the Culpability model The wording change captures the Managerial Accountability Model as (accountability) as stated in EN-PL-100 intended audience with the most stated in EN-PL-100, Attachment 3.2 with full-time, actively badged, site current accountability model from with all full-time site personnel and assigned personnel to improve consistent procedure EN-PL-100, Nuclear NSC-supplemental personnel to improve performance of Managerial and Individual Excellence Model - now called the 8.9 consistent performance of Managerial Accountability. "Culpability Model." EN-PL-100 has and Individual Accountability. been revised and attachment 3.2 no longer exists.

Letter Number 2.18.060 Attachment 1 Page 3 of 3