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

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 Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Brian R. Sullivan Site Vice President

REFERENCES:

1. NRC letter to Entergy, "Confirmatory Action Letter -Pilgrim Nuclear Power Station," dated August 2, 2017 (ML 17214A088)

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.

Sincerely, BRS/rb Attachment 1 : Notification of Changes to Comprehensive Recovery Plan t,<DAJDI jr!)bl ;Jf__f_ /!_~tJ-£ 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 0-9012 Washington, DC 20555-0001 NRC Senior Resident Inspector Pilgrim Nuclear Power Station Letter No. 2.18.060 Page 2 of 2 Attachment 1 Letter Number 2.18.060 Notification of Changes to Comprehensive Recovery Plan Notification of Changes to Comprehensive Recovery Plan NSC-1.1 NSC-1.5 Implement the Individual Targeted Performance Improvement Plans (TPIP) developed from CR PNP-2016-2052, CA-35 utilizing the guidance contained in EN-FAP-HR-006, Fleet Approach to Leadership Development

& Organizational Effectiveness.

Document review plan progress as determined during the individual Monthly Performance Management Meetings to ensure sufficient evidence exists for plan closures.

When a Senior Leader has positively satisfied their TPIP objectives, the Site Vice President SVP can close the TPIP. Implement the Individual Targeted Performance Improvement Plans (TPIP) developed from CR PNP-2016-2052, CA-35 utilizing the guidance contained in EN-FAP-HR-006, Fleet Approach to Leadership Development

& Organizational Effectiveness.

Document review plan progress as determined during the individual Monthly Performance Management Meetings to ensure sufficient evidence exists for plan closures.

When a Senior Leader has positively satisfied their TPIP objectives, the SVP can close the TPIP. Letter Number 2.18.060 Attachment 1 Implement the Individual Targeted Performance Improvement Plans {TPIP) for the GMPO and Directors (Senior Leaders) developed from CR PNP-2016-2052, CA-36 utilizing the guidance contained in EN-FAP-HR-006, Fleet Approach to Leadership Development

& Organizational Effectiveness.

Document review plan progress as determined during the individual Monthly Performance Management Meetings to ensure sufficient evidence exists for plan closures.

When a Senior Leader has positively satisfied their TPIP objectives, the Site Vice President SVP) can close the TPIP. Develop and implement Individual Targeted Performance Improvement Plans (TPI P) for Managers, Superintendents and Supervisors using the criteria listed in PN P-2016-2052, CA-36 and utilizing the guidance contained in EN-FAP-HR-006, Fleet Approach to Leadership Development

& Organizational Effectiveness.

Document review plan progress as determined during the individual Monthly Performance Management Meetings to ensure sufficient evidence exists for plan closures.

When a leader has positively satisfied their TPIP objectives, the one-up leader can close the TPIP. .. :~4:)iJSO:

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• The reference to CR-PNP-2016-2052 CA-35 in the 1st sentence of the CAL action has been revised to CA-36 to correct a typographical error. The GMPO and Directors have been added to the 1st sentence to clarify the intent of this action. The reference to CR-PNP-2016-2052 CA-35 in the 1st sentence of the CAL action has been revised to CA-36 to correct a typographical error. Managers, Superintendents, and Supervisors have been added to the 1st sentence, along with the action to develop and implement individual TPIPs, to clarify the intent of this action. In addition, the last sentence has been revised to identify that the one-up leader will close the TPIPs. Page 1 of 3 Notification of Changes to Comprehensive Recovery Plan *.:CAL.> " .. , * ,, , . * , , Actionr ', *.~urr:e!1l',CAL':Ac~ion Deshriptiori , , " #,, , , , ' ~* ' NSC-2.2 NSC-2.3 Rollout the PNPS Employee handbook (or equivalent) to site personnel.

The rollout meeting should include:

• Senior Leaders (Senior Manager or above) facilitating in the rollout meeting to ensure effective communications and understanding of the commitment to the handbook and its use.

• Individuals signing for their copy of PNPS Employee Handbook and acknowledgement of expectations for use. Conduct alignment sessions with station leadership on the content and implementation expectations on the PNPS handbook (or equivalent) based on the EN-PL-100, Nuclear Excellence Model (PNPS's vision, mission, strategy, goals, core values, attributes of leader and individual behaviors), and site-specific recovery procedure EN-OM XXX-PNP-RC (Created in CR PNP-2016-2052, CA-39). These sessions will be led by the Site Vice President and focus on establishing accountability for high standards of performance to align behaviors in support of a strong nuclear safety culture. Station Leadership includes first line supervisor level up to Director and General Manager-Plant 0 erations GMPO level. Letter Number 2.18.060 Attachment 1 ::. '""* "" ?Pfo~o*~~~.*CAl:A~tiJ~

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• f,:' : '."\,' c', , ~;,:* '* "'} *:) ! **~ Rollout the PNPS Employee handbook (or equivalent) to site personnel.

The rollout should include:

• Senior Leaders (Senior Manager or above) facilitating the rollout to ensure effective communications and understanding of the commitment to the handbook and its use.

• Individuals signing for their copy of PNPS Employee Handbook and acknowledgement of expectations for use. Conduct alignment sessions with station leadership on the content and implementation expectations on the PNPS handbook (or equivalent) based on the EN-PL-100, Nuclear Excellence Model (PNPS's vision, mission, strategy, goals, core values, attributes of leader and individual behaviors), and site-specific recovery procedure EN-OM XXX-PNP-RC (Created in CR PNP-2016-2052, CA-39). These sessions will be led by Station Senior Management and focus on establishing accountability for high standards of performance to align behaviors in support of a strong nuclear safety culture. Station Leadership includes first line supervisor level up to Director and General Manager-Plant Operations GMPO level. The word "meeting" has been removed from the second sentence and the first bulleted phrase to clarify that the roll out was conducted in two steps not in a meeting format. The intent and actions taken to meet this CAL requirement remain unchanged.

The word "in" in the 1st bulleted sentence following the word "facilitating" has been removed to improve the readability of the sentence.

Change of wording from "Site Vice President" to "Station Senior Management" to more correctly describe the handbook roll out and alignment.

Although the SVP was present in the process and during meetings providing his leadership, guidance and oversight of the alignment sessions, the presentations were created and led by station senior managers.

CAP and ACRB closure packages provide documentation of the station senior management presentation.

Page 2 of 3

,**,CAL ,Ac:tion .#, NSC-8.9 Notification of Changes to Comprehensive Recovery Plan Reinforce the use of Entergy's Managerial Accountability Model as stated in EN-PL-100, Attachment 3.2 with all full-time site personnel and supplemental personnel to improve consistent performance of Managerial and Individual Accountability.

Reinforce the use of the Culpability model (accountability) as stated in EN-PL-100 with full-time, actively badged, site assigned personnel to improve consistent performance of Managerial and Individual Accountability.

Letter Number 2.18.060 Attachment 1 :j=~e,s9ri)or c;:h~~gi.

• "~ ,\ ,-" *s ', ;;' . ' ' 'i The wording change captures the intended audience with the most current accountability model from procedure EN-PL-100, Nuclear Excellence Model -now called the "Culpability Model." EN-PL-100 has been revised and attachment 3.2 no longer exists. Page 3 of 3