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 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 Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Brian R. Sullivan Site Vice President
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.
Pilgrim Nuclear Power Station 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 Letter No. 2.18.047 Page 2 of 2 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-15 and 4/ CA-16 are closed, assign a part-time (two weeks per month)
SME to coach and mentor DPIC and CAP performance and independently review RCEs and ACEs to acquire the data for CAP-populating the CAP Performance 1.2 Indicators.
CAP-1.5 EP-2.2 Generate the CAP SME monthly status report for July 2016 (performed by the CAP SME required in CA 74). Also generate a new CA to require each additional monthly report in the same fashion.
These monthly status reports must continue until end of plant operating life.
Based upon the results of CR PNP-2016-2061, CA-24, reapportion the workload of the System Engineering Supervisors such that they have an adequate amount of time (25% is required by EN-FAP-OM-016} of their time available for mentoring and supervising their staff, excluding PCRS time.
Letter Number 2.18.047 Attachment 1 When interim actions EOC-3 / CA-15 and 4
/ CA-16 are closed, assign a part-time (two weeks per month minimum) SME to coach and mentor DPIC and CAP performance and independently review RCEs and ACAs to acquire the data for populating the CAP Performance Indicators. Mentoring and coaching may be performed by contracted consultants designated as SMEs or Mentors.
Generate the CAP SME status report for July 2016 (performed by the CAP SME required in CA 74}. Also generate a new CA to require each additional report in the same fashion. These status reports must continue until end of plant operating life on a frequency not to exceed quarterly.
Based upon the results of CR PNP-2016-2061, CA-24, reapportion the workload of the System Engineering Supervisors such that they have an adequate amount of time available for mentoring and supervising their staff, excluding PCRS time. Work load is discussed during the EN-FAP-OM-016 "Monthly Performance Management Meeting" process.
These corrective action program mentoring and coaching actions are performed by a team of three individuals. Two individuals designated as SM Es in the recovery action plan independently review causal products, coach and correct Performance Improvement Review Group (PRG) behaviors, and populate the CAP Performance Indicators. A third individual, designated as a mentor in the recovery action plan, coaches and 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.
CAP SME status reports were initially-completed on a monthly basis. A change to quarterly allows for an appropriate period to discern performance trends with no impact on the intent of the action.
Entergy procedure EN-FAP-OM-016 did not have a requirement of 25%, rather it was a goal. The procedure has been revised to no longer specify any value. There is no change to the standard contained in the original action.
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 ER-3.2 if required based on scheduled Selector Switch (604-301 ), if required 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)
OPS-Conduct Focused Self-Assessments Conduct crew observations for each crew CAL item OPS-2 is to "Improve the operations 2.2 of Operator Fundamentals for each using EN-OP-117 "Operations Assessment department "Picture of Excellence" with regard to 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 *.
PUA-1.6/5.9 PUA-2.3 PUA-3.4 RRDM-1.1 "Roles and Responsibilities" attachments in EN-OP-120, Operator Fundamentals Program.
The assessment teams should include industry peers.
Site department managers communicate senior management's procedure use and adherence expectations once per quarter for a year.
Perform Procedure Use and Adherence observations using the 95003 Recovery Human Performance WILL Sheet concurrently with performance of HU observations for the assessment period of one year, June 1, 2016 through June 1, 2017, or until closure of Procedure Use and Adherence effectiveness review.
Communicate the PU&A Lessons Learned/Results from the PU&A 95003 Recovery WILL sheet as analyzed in Monthly Snap Shot Assessments quarterly via L&A meetings.
Perform observations of leadership performance against the leadership expectations established in CAPR-1 Letter Number 2.18.047 Attachment 1
.. Proposed CAL *Action.Description Grading Sheets (IER L1-11-3)". The assessment teams should include resources external to Pilgrim.
Site department managers communicate senior management's procedure use and adherence expectations utilizing a different quarter's data not less than 4 times.
Perform Procedure Use and Adherence observations using the 95003 Recovery Human Performance WILL Sheet criteria concurrently with performance of HU observations for the assessment period of not less than one year. The Procedure Use and Adherence observations using the 95003 Recovery Human Performance WILL Sheet criteria will continue until closure of Procedure Use and Adherence effectiveness review.
Communicate the PU&A Lessons Learned/Results from the PU&A 95003 Recovery WILL sheet attribute ratings quarterly via L&A meetings.
Perform observations of leadership performance against the leadership expectations established in CAPR-1 and Reason for Change':
EN-OP-120 "Operator Fundamental Program" is a program document that does not establish discrete criteria necessary to assess standards, ownership, and leadership. The grading sheet 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.
The proposed revision allows for an equivalent number of interactions while allowing for some flexibility in schedule and still meeting the intent of the action.
This change clarifies that the requirement to perform Procedure Use and Adherence observations using the 95003 Recovery Human Performance WILL Sheet criteria must continue until both a successful Procedure Use and Adherence effectiveness review _has been completed and no less than one year of observations have been completed. This change also allows the use of recent data which is most indicative of current behaviors.
The data that provides behavior performance information is the rating of the Procedure Use and Adherence attributes listed on the WILL Sheet.
The phrase "in Monthly Snap Shot Assessments" has been deleted because Snap Shot assessments have been deleted from the Entergy self-assessment procedure (EN-Ll-104). The intent of communicating lesson learned and observation results are unchanqed.
This action is equivalent to the previous action and the change provides the proper clarity of the documentation of observations and the audience 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
'. :='., '
.. *c, Reassess the additional resources brought in under CR PNP-2016-2057, CA-41. As part of that assessment, perform the following:
Design and implement a resource-loading plan for maintenance shops WM-based on the workload expectations 3.3 for the remaining 2 years of plant life.
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
, Proposed CAL Action
Description:
Reassess the additional resources brought in under CR PNP-2016-2057, CA-41. As part of that assessment, perform the following:
Determine the estimated man-hours required to reduce backlogs and maintain fleet performance goals and procure additional contract resources if necessary.
- Beason for Change~.
This change replaces the work management supply and demand model with an equivalent method for resource assessment, and adds the requirement to provide additional staffing if necessary to reduce backlogs and maintain fleet performance goals.
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