ML18158A134
| ML18158A134 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/07/2018 |
| From: | David Lew Region 1 Administrator |
| To: | Brian Sullivan Entergy Nuclear Operations |
| Dimitriadis A | |
| References | |
| EA-17-086 | |
| Download: ML18158A134 (6) | |
Text
B. Sullivan UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406-2713 June 7, 2018 EA-17-086 Mr. Brian Sullivan Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
SUBJECT:
REVISION TO CONFIRMATORY ACTION LETTER - PILGRIM NUCLEAR POWER STATION
Dear Mr. Sullivan:
On July 28, 2017, Entergy Nuclear Operations, Inc. (Entergy) submitted to the U.S. Nuclear Regulatory Commission (NRC) the Pilgrim Nuclear Power Station Recovery Plan (ML17212A5711) describing the actions Entergy is taking to resolve the causes for declining performance that led to Pilgrim being placed in the Multiple/Repetitive Degraded Cornerstone Column (Column 4) of the NRC Action Matrix. On August 2, 2017, the NRC issued a Confirmatory Action Letter (CAL) (ML17214A088) that identified a subset of actions from the Recovery Plan the NRC considers essential to address the underlying problems that resulted in Pilgrims decline in performance.
In letters dated March 14, 2018 (ML18087A041), and June 1, 2018 (ML18156A114), Entergy notified the NRC of its intent to change, in two instances, the corrective actions documented in the CAL involving operations manager mentoring visits and follow-up activities. In addition, Entergy identified several schedule changes and clarifications to corrective actions as described in the CAL. The Enclosure to this letter describes these revisions as items one through seven and the NRC staffs conclusions.
The staff concluded that the revisions do not reduce the scope or depth of actions required to complete the CAL commitments and do not impact the NRC inspection plan for independently assessing the completion of the effectiveness of these actions. Items 1, 2, 5, and 6 in the Enclosure are administrative in nature because they correct an error made in the original CAL or better describe the problems being addressed. Items 3 and 4 are enhancements intended to ensure the underlying problems are more fully addressed. Finally, item 7 involves revisions to Entergys scheduled action completion dates for several Area Action Plans. The NRC staff determined the date changes are acceptable because they provide for additional time to determine effectiveness of completed actions and the new completion dates are consistent with the NRCs planned inspections of these areas.
1 Designation in parentheses refers to an Agencywide Documents Access and Management System (ADAMS) accession number. Documents referenced in this report are publicly available using the accession number in ADAMS.
B. Sullivan 2 After consulting with the Director of the Office of Nuclear Reactor Regulation, the NRC staff agrees with your revised commitments as described in the attached Enclosure.
The original Pilgrim Nuclear Power Station CAL, EA-17-086, issued on August 2, 2017, remains in effect, except as modified in the Enclosure to this letter.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRCs Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.
If you have any questions, please contact Anthony Dimitriadis at (610) 337-6953 or e-mail at Anthony.Dimitriadis@nrc.gov.
Sincerely,
/RA/
David C. Lew Acting Regional Administrator Docket No. 50-293 License No. DPR-35
Enclosure:
Revised Confirmatory Action Letter Commitments cc: Distribution via ListServ
ML18158A134 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DRP RI/DRP RI/ORA RI/ORA RI/DRP NAME LCline ADimitriadis BBickett BKlukan MGray DATE 6/5/18 6/5/18 6/5/18 6/5/18 6/5/18 OFFICE RI/ORA NAME DLew DATE 6/6/18 Revised Confirmatory Action Letter Commitments
- 1. CAL Item ODFA-5.6:
The original CAL item stated: The actions specified in ODFA-1.4 also address deficiencies identified during the 95003 inspection. Entergy revised this item to read: "The actions specified in ODFA-5.2 also address deficiencies identified during the 95003 inspection."
The NRC staff reviewed the change and determined it was administrative because it did not change the action that Entergy committed to perform in the CAL. The change ensures the CAL item identifies the correct PNPS Recovery Plan action. The NRC concluded this change is acceptable.
- 2. CAL Items RRDM-4.1, -4.2, -4.3, -4.5, and -4.6:
Entergy moved these five CAL items that were included in the Risk Recognition and Decision-Making Area Action Plan (RRDM) to the Operations Standards and Site Leadership (OPS) Area Action Plan. The change added a new section to the OPS Area Action Plan, OPS-5, Additional Actions, and revised the designators for these items as follows:
- a. RRDM-4.1 to OPS-5.1
- b. RRDM-4.2 to OPS-5.2
- c. RRDM-4.3 to OPS-5.3
- d. RRDM-4.5 to OPS-5.4
- e. RRDM-4.6 to OPS-5.5 For this revision, no changes were made to the actions that Entergy had committed to for these items.
The NRC staff reviewed this change and concluded it is administrative because it does not change the actions that Entergy committed to perform in the CAL. This specific change only moves actions from one Area Action Plan to another. The NRC concluded this change is acceptable.
- 3. CAL Item OPS-5.2 (formerly RRDM-4.2 as described in Item 2 above):
The original wording for this item in the original CAL was: Schedule three operations manager mentor visits to Pilgrim in 2017, following RFO-21, with former Indian Point Entergy Center Operations Manager. Entergy revised this item to read: "Conduct a Leadership Effectiveness Assessment to assess leadership and management capabilities of the Operations Department. Entergy revised this CAL item to account for changes in Operations Department Management and to more broadly assess departmental leadership.
The NRC staff determined that the new action will use an experienced corporate team to assess the leadership and management capabilities of the Operations department instead of multiple site visits by a single individual mentor with operations management experience.
The NRC concluded that this change is an enhancement to the original CAL item and is acceptable.
- 4. CAL Item OPS-5.3 (formerly RRDM-4.3 as described in Item 2 above):
The original wording for this item in the original CAL was: Issue additional actions based on the results and insights from the mentor visits conducted per CR-PNP-2017-2003 CA-04 Enclosure
2 and CR-PNP-2017-2003 CA-05. Entergy revised this item to read: "Issue additional actions based on the results and insights from the Assessment performed in OPS-5.2."
The NRC staff determined that this change is an enhancement needed due to the change to CAL Item OPS-5.2 described above. The change to OPS-5.3 ensures the additional actions issued are based on insights from the leadership assessment conducted in accordance with the revised OPS-5.2 not the originally proposed mentor visits. The NRC concluded that this change is an enhancement to the original CAL item because the additional actions are based on a broader and more in-depth review of the Operations Department leadership and is acceptable.
- 5. CAL Item RRDM-4.8:
The original wording for this item was: The action specified in RRDM-1.2 also address deficiencies identified during the 95003 inspection. Entergy revised this item to read:
RRDM-4.8 addresses the NRC 95003 observation that based on interviews and a review of current open corrective action program items generated by the subject matter experts, the NRC team noted resistance to the improvement recommendations of the subject matter experts by some station managers. For example, in reference to CR-PNP-2016-07486, subject matter experts identified that numerous outage preventive maintenance activities were extended without sufficient technical justification and without conducting a risk review in accordance with procedure 1.3.142, PNPS Risk Review and Disposition.
The NRC staff reviewed this item and concluded that the revised wording provides clarification that accurately describes the applicable 95003 deficiencies to be addressed.
No changes were made to the actions that Entergy committed to for this item. The NRC concluded this change is acceptable.
- 6. CAL Item RRDM-4.9:
The original wording for this item was: The action specified in RRDM-1.3 also address deficiencies identified during the 95003 inspection. Entergy revised this item to read:
"RRDM-4.9 addresses the NRC 95003 observation that some station leaders (managers and first-line supervisors) from across multiple departments appeared to be lagging in their demonstration of the new decision-making principles and implementation of procedure 1.3.142, PNPS Risk Review and Disposition, and the NRC 95003 observation that the current action plans allow the station the flexibility to remove the SMEs and mentors following a successful effectiveness review of the related area. Implementation of the SMEs and mentors should continue until a positive change in safety culture is sustained and verified by NRC inspection."
The NRC staff reviewed this item and concluded that the revised wording provides clarification that accurately describes the applicable 95003 deficiencies to be addressed.
No changes were made to the actions that Entergy had committed to for this item. This change is acceptable.
- 7. Area Action Plan Completion Commitment date adjustments:
Entergy requested to revise multiple Area Action Plan completion dates to align with the current NRC CAL inspection schedule. The details of the requested changes were included in Attachment 2 to Entergy letter dated March 14, 2018, letter.
For each affected Area Action Plan, the NRC determined that the requested Area Action Plan completion date extensions support completion of activities intended to support
3 Entergys assessment of the effectiveness of the associated Area Action Plan. The NRC further notes these changes do not affect the NRC CAL inspection schedule described in our letter dated February 28, 2018 (ML18058A025). The NRC finds the revised completion date changes acceptable. The revised completion dates for the affected Area Action Plans are listed below:
Original AAP Revised AAP Area Action Plan (AAP) Action Completion Action Completion Commitment Date Commitment Date Procedure Use and Adherence 02/28/18 05/18/18 Corrective Action Program 03/30/18 05/18/18 Nuclear Safety Culture 05/31/18 11/23/18 Operational Standards and Leadership 05/31/18 08/24/18 Risk Recognition and Decision Making 05/31/18 08/24/18 Engineering Programs 06/28/18 08/24/18 Equipment Reliability 06/28/18 08/24/18 Work Management 06/28/18 08/24/18