The following procedure is an example of a risk based approach to change management. It applies fundamentally to any change whether it's

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1 The following procedure is an example of a risk based approach to change management. It applies fundamentally to any change whether it's organizationally or involves a process change. This approach uses a graded approach to managing change.

2 Rev. 0 Page 1 of 18 Change Management Quality Non Safety-Related Usage: Available Effective Date: Name Name Department PREPARER TECHNICAL USER COGNIZANT ORGANIZATION Table of Contents Page 1.0 Purpose Scope Definitions References Responsibility Implementation Forms Records...5 Addendum 1 - High Risk & High Complexity Change Management Checklist...6 Addendum 2 - Abbreviated Change Management Checklist...8 Addendum 3 - Transition Plan...9 Addendum 4 - Turnover Checklist Addendum 5 - Transition Plan Checklist for Transfers of Organizational Functions Addendum 6 - Team Skill/Competency Matrix Addendum 7 - Stakeholder Analysis Addendum 8 - Communication Planning Addendum 9 - Change Management Feedback Survey Addendum 10 The Strategy Change Cycle... 17

3 Rev. 0 Page 2 of Purpose 2.0 Scope 1.1 The purpose of this policy is to provide a model and tools for managing personnel, organizational, and work process changes. 2.1 This policy shall apply to STPNOC employees affected by personnel changes in organizational positions at or above supervisory level. Managers may also consider implementing this policy for other key organizational positions. 2.2 In addition, this policy applies to tooling and technology changes, process improvement projects, and reorganization efforts. 3.0 Definitions 3.1 None 4.0 References 4.1 Accreditation Self Evaluation Report 4.2 Leading Change John P. Kotter, Harvard Business School Press, Change Management Policy Entergy Corporation, Strategic Planning for Public and Nonprofit Organizations John M. Bryson 5.0 Responsibility 5.1 Station management shall be responsible for implementation of this policy. 6.0 Implementation 6.1 Change Management Model Change creates error-likely situations. Effective change reuires leaders who are capable of establishing direction, aligning people behind the change, and motivating and inspiring participation. The typical seuence of change management steps (often worked in parallel) are these: Establish a sense of urgency; make the case for the change to the people who will be expected to make it work Create a guiding coalition of leaders with enough power to make the change reality

4 Rev. 0 Page 3 of Develop a vision and strategy* Communicate the vision and strategy Empower broad-based action Generate and celebrate short-term wins Consolidate gains and produce more change Anchor the change in the culture Guidance for practical application of these steps is provided in Attachments 1 through 9 of this policy. 6.2 Impact Assessments When planning organizational changes or process improvements, managers and supervisors are expected to assess the impact of the changes on the organization. Organizational readiness for change should be included in the assessment. Change amplifies error likelihood. Other, ongoing change efforts increase the challenge. Confer with stakeholders and peers to find the best fit. NOTE See Attachment 10, The Strategy Change Cycle, for the ten steps of strategic planning If the change is high risk and highly complex, then use the High Risk and High Complexity Change Management Checklist (Attachment 1 - provided as example). Otherwise, use the optional Abbreviated Change Management Checklist (Attachment 2 - provided as example) or, if the change is low risk and low complexity, then use the existing processes, e.g., procedure revision process, purchasing process, design change process, etc. Use the Risk/Complexity Matrix (below) to decide.

5 Rev. 0 Page 4 of 18 The Risk/Complexity Matrix Attachment 2 Use Attachment 1 Attachment Managers and supervisors are expected to develop and evaluate change management action plans using the checklists (attachments) above. Action plan results should be tracked using the Corrective Action Process to ensure that actions are tracked to closure. Action planners should consider the change management model described in section 6.1 and in reference Transition Planning When organizational changes are planned or when transfers or attrition cause vacancies in the organization at or above the supervisory level, transition plans shall be developed as necessary to establish an interim chain-of-command. Transition plans should contain the information that is identified on the Transition Plan, (Attachment 3 - provided as example). The purpose of the transition plan is to provide the information needed to maintain organizational performance until a permanent replacement is selected. Transition plans shall be completed by the individual to whom the outgoing manager/supervisor reports When changes involve work groups covered by an accredited training program, Nuclear Training should be involved with the development of the transition plan.

6 Rev. 0 Page 5 of Forms 6.4 Turnovers Once an individual is selected to fill a manager/supervisor position the Turnover Checklist (Attachment 4 - provided as example) shall be completed. It is the responsibility of the incoming manager/supervisor to ensure that the checklist is completed. Ideally, the outgoing manager/supervisor will complete the turnover checklist and conduct the turnover briefing. Should this not be possible, the individual to whom the incoming manager/supervisor reports shall conduct the briefing When these changes in responsibilities involve work groups covered by accredited training program, Nuclear Training should participate in the turnover briefing. 6.5 Transfers of Organizational Functions and Responsibilities 7.1 None 8.0 Records When changes within the station organization involve transfers of responsibility for organizational functions from one manager or supervisor to another, they shall be documented to the degree necessary to clearly identify the changes in responsibility. The transferring group manager and the receiving group manager (and interfacing department representatives as needed) shall meet to jointly develop a transition plan (Attachment 5 - provided as example) for transfer of responsibilities. The resulting transition plan shall be distributed to interfacing organizations and promulgated to all levels within the affected organizations to promote a clear understanding of the new responsibilities for organizational functions When these changes in responsibilities involve functions or tasks that are covered by an accredited training program, Nuclear Training should be involved in the development of the transition plan. 8.1 There are no records generated by this policy.

7 Addendum 1 Change Management High Risk & High Complexity Change Management Checklist Rev. 0 Page 6 of 18 Page 1 of 2 Use of this checklist is recommended especially when the change involves high risk or high complexity. Worksheets, surveys and tools for facilitating various aspects of change management are included here and may be found on the Human Performance Bulletin Board on the LAN. Directions: Read entire checklist prior to answering the uestions. The Change Owner/Sponsor (or designee) should complete each section at the appropriate stage of the change. Users may wish to repeat some segments of the checklist over time. Name of the Change: Team Leader: Assessment Phase Is the change clearly defined and its basis (why) understood by all stakeholders? What is changing and what are the conseuences of not changing? What does the change look like and what are the actionable items that will help get you there, i.e., what are your vision and mission? Is self-assessment, lessons learned, OE or benchmarking information available? Does this change impact: Nuclear/Industrial Safety, Dose or Reliability? Licensing (50.59, 50.54, etc.) Training & Qualifications of Personnel? Procedures, Technical Specifications or Commitments? Business Plans? Computer applications? FSAR, E-Plan, Security Plan, or OQAP? Other Organizations? Describe potential obstacles or barriers to successful change implementation. (resource constraints, cultural resistance, etc.) As seen by the recipient(s) of the change, do the benefits of this change outweigh the problems it may cause? Does the sponsor of the change initiative have senior management support for the use of change management processes and techniues, including significant stakeholder / communication effort? Is the change initiative a performance expectation (PMR) for the appropriate change participants, including key stakeholders? Is the change initiative aligned with core values and long term plans and strategies? Planning Phase Who is the Sponsor of the change? (name, title) Has the goal of the change been identified, linked to core values & company business strategies, defined and scoped? Have key performance indicators (KPI) been established to measure the effectiveness of the change? Have assessments been planned to uncover new weaknesses and formulate follow on actions? What criteria will be used to provide a good measure of progress/success? Have ample resources (budget, skills, manpower, etc.) been allocated for successful change implementation? Do you have the right team to make it happen? Tool: Team Skill/Competency Matrix (Attachment #6) Does the team include members and stakeholders from all levels of the organization? Are they clear on their roles? Has the team completed the stakeholder analysis? Tool: Stakeholder Analysis (Attachment #7)

8 Addendum 1 Change Management High Risk & High Complexity Change Management Checklist Rev. 0 Page 7 of 18 Page 2 of 2 Is key management support aligned? Is there a formal communications plan? Tool: Communication Plan (Attachment #8) Have you identified your audience(s) and their key issues? Is the change goal understood? Are you able to convince stakeholders of the need for change? Have you chosen your media options? Do you have a timeline, milestones, and a feedback mechanism? Does the team have a decision-making process? Does the entire team understand it? Does the team have contingency plans? (Problems are the natural by-product of change.) Does the change involve personnel changes (supervisor or above) or transfer of organizational functions? (Use attachments 1-3 as applicable.) Has senior management committed to its role in removing roadblocks and finding necessary resources? Has a mechanism for communication with senior management been established? Has senior management identified and set expectations for individuals who are key to success? Have these expectations been communicated? Has senior management established expectations for performance and rewards? Is senior management an active participant in the communication process? Have appropriate regulatory reviews been conducted (e.g., 10CFR50.54, 50.59, 50.90)? Implementation Phase Is there a formal Implementation Plan? Does it establish roles and accountability? Does it reward and recognize success as the change moves forward? Is the communication Plan effective? Is feedback being captured to help check and adjust? Is there a process for tracking and reporting the status of your progress? Are the measures effective? Are key personnel supporting the change? Have any additional/unexpected training needs been identified? Does senior management receive updates on the progress of the change initiative? Has there been the need to activate contingency plans resulting from Implementation Plan issues? Does senior management participate in recognizing and celebrating successes? Evaluation & Reinforcement Phase Is there a method for assessing change Effectiveness? (Tool: Change Management Feedback Survey (Attachment #9) Is there a clear understanding of post-completion processes and ownership? Has the organization celebrated the completion of the change and recognized the achievements of key participants? Has senior management followed up with key individuals or groups to help anchor the change in the culture? Has there been reinforcement of desired behaviors? Has there been a celebration of the success of this change? Completed by: Date:

9 Rev. 0 Page 8 of 18 Addendum 2 Abbreviated Change Management Checklist Page 1 of 1 This checklist provides guidance for managing a change that either high risk or high complexity, but not both. It also provides adeuate documentation of the use of Change Management tools and techniues. Use of this checklist is optional. Directions: Note: Read the entire checklist prior to answering the uestions. The Change Owner/Sponsor (or designee) should complete the items as appropriate during the change process. If the Owner/Sponsor determines this checklist is inadeuate in the face of emergent information concerning risk or complexity, consider using the High Risk & High Complexity Change Management Checklist. Name of the Change: Team Leader: Make the case for the change Briefly describe the change. Give the reasons for the change and define what will change. Is the change clearly defined? What is changing and what are the conseuences of not changing? What does the change look like? What is your vision? Your mission? Assess the Impact Confirm that this change is not in the High Risk and High Complexity category Does this change impact: Nuclear/Industrial Safety, Dose or Reliability? Licensing (50.59, 50.54, etc.) Training & Qualifications of Personnel? Procedures, Technical Specifications or Commitments? Business Plans? Computer applications? FSAR, E-plan, Security plan, OQAP? Other Organizations? Identify Stakeholders Who is the Sponsor of this change? (name/title) Who (groups, departments, individuals) will this change touch? Use Stakeholder Analysis Tool (Attachment #7) Which of the stakeholders will need to reach agreement on the planned change? Plan for Contingencies Identify error-likely situations this change may create. Develop appropriate contingency plans. Does the change involve personnel changes (supervisor or above) or transfer of organizational functions? (Use attachments 1-3 as applicable.) Make a Communications Plan How will you effectively communicate to the appropriate audiences? (Communicate the change goal, what it looks like, how it benefits the company, department, individual; what you want the audience to know and what you want them to do. Formal communications? Use Communication Plan Tool (Attachment #8) Informal communications? Review Communication Plan Tool. Measure Effectiveness How will you evaluate the effectiveness of the change? (Consider using Attachment #9, Tool: Change Management Feedback Survey, to measure Change Management effectiveness.) Done Not Done Have you established key performance indicators to measure effectiveness of the change and to find and correct unintended conseuences? Done Not Done Completed by: Date:

10 Rev. 0 Page 9 of 18 Addendum 3 Transition Plan Page 1 of 1 1. Predicted date that current position will become vacant: Predicted date that replacement selection will be made:. 2. Is an individual going to be appointed acting interim manager/supervisor? Yes (Go to 3) No (Go to 4). 3. Name of individual in acting interim role:. (Go to 4) 4. Below, specify the major job duties of the position to be filled by the interim personnel (this may be one individual filling all of the duties or several individuals filling portions of the duties). When complete, review the plan with the appropriate individual(s) responsible for performing the duties. Normal Duties (Briefly describe the major duties. Specifically note their impact on Reactor Safety during normal operations). Duty Responsible Individual Outage Duties (Briefly describe the major duties. Specifically note their impact on Reactor Safety during outages). Duty Responsible Individual Emergency Response Position to be filled: Training Needed? Meetings and Committees (List meetings and committees attended by this position). Meeting Time/Freuency/Location Person Attending 5. Review the plan with the individual(s) who is responsible for filling the vacant position on an interim basis. 6. Conduct an interim turnover with interim personnel using Turnover Checklist (Attachment 2). 7. Distribute copies of this plan to interfacing organizations.

11 Rev. 0 Page 10 of 18 Addendum 4 Turnover Checklist Page 1 of 1 The checklist below is to be used to brief incoming managers and supervisors Normal Job Duties (Review job duties and personnel interfaces) Contribution to reactor safety Orientation to organization (Major work groups reporting to the position, functions and interfaces) Assess Organizational Health peoples roles, strengths, and opportunities for improvement. Short term business plan goals and budget Long term business plan goals and budget Schedule/work group priorities Performance indicators and status Business plan initiatives Training Program Status and Issues (Review current status of training program) Training roles, responsibilities, organization and interfaces Training schedules, goals and budget Current Curriculum Review Committee/Technical Advisory Council issues Training related action plans and condition reports Accreditation status, issues, concerns, strengths and weaknesses Verify completion of reuired training including supervisory skills training and systematic approach to training Training Reuirements - Emergency Response Organization, mitigating core damage for operations and I&C, Continual Behavior Observation Program, (CBOP) etc. Outage Job Duties (Review outage job duties and personnel interfaces) Contribution to reactor safety Outage duties Planning status and issues of concern or risk Action Plans and Condition Reports (Review significant action plans/condition reports) Meetings and Committee Representation: (Review roles in major committees or interface meetings e.g., Condition Review Group, Plant Operations Review Committee, Training Curriculum Review Committees, Tack Forces, Etc.) Ongoing Regulatory/Agency Issues Personnel Issues (Review any open personnel issues) Review personnel folders (both supervisory and Human Resources) Review vacation schedules Interview all direct reports Review open personnel reuisitions Review organizational history - How WE got here and why Expectations and Vision - Meet with work group and establish expectations and vision Legal Issues (Review pending litigation on need to know basis only) Customer/Supplier Relationships - Meet with customer and supplier work groups to determine needs and establish expectations

12 Addendum 5 Change Management Transition Plan Checklist for Transfers of Organizational Functions Rev. 0 Page 11 of 18 Page 1 of 1 Describe the functions to be transferred or combined: Function(s) Being Transferred Or Combined Transferring Organization/ Manager/ Supervisor Receiving Organization/ Manager/ Supervisor Consider the impact these changes will have on existing training programs if any. Describe the plan for accomplishing actions to maintain or modify existing training materials and accomplishing additional training if needed. Actions needed to maintain or modify existing training materials or to accomplish needed training. Responsibility/ Due Date List the organizations that are impacted by these changes. When will these changes become effective? Describe how these changes will be communicated to the remainder of the station organizations.

13 Rev. 0 Page 12 of 18 Addendum 6 Team Skill/Competency Matrix Page 1 of 1 Skill/ Competency Team Members Credibility Open to Change Communication Skills Political Savvy Project Management Experience Team Skills Strategic / Big Picture Awareness Work Ethic Station Admin Experience Diversity Competence Change Competence Development Potential Directions: Put team member names across the top. Put needed skills down the side (The skills listed above are samples. Add or subtract as appropriate). Score team candidates or members as High, Medium, or Low in each of the categories. Analyze for team strengths / weaknesses. Use the Team Skill/Competency Matrix assessment to determine the need for replacement team members or to identify areas that will need extra management attention.

14 Rev. 0 Page 13 of 18 Addendum 7 Stakeholder Analysis Page 1 of 2 Group/Org Change Topic Stakeholder Name Contacted by: Impact H M L Remarks Stakeholder Analysis directions on next page

15 Rev. 0 Page 14 of 18 Addendum 7 Stakeholder Analysis Page 2 of 2 Overview: The stakeholder analysis tool is designed to help you identify and evaluate stakeholders. It assists in answering the uestions: Who are the stakeholders, where do they stand on the change initiative issues and where do we need them to be in terms of support? It assumes that some critical mass is necessary for success, that stakeholders can be moved to a higher level of support, and that not all stakeholders will be highly supportive. This tool also helps the team identify influence relationships and begin building effective strategies for influencing each stakeholder. Timing: This tool should be used to identify the key stakeholders and then for a discussion of stakeholder support. It can also be used to analyze newly emerging/identified stakeholders later in the process. Directions for Use: (Repeat as necessary throughout the change initiative.) 1. Identify the key stakeholders. A key stakeholder may be anyone who is impacted by the change, controls critical resources, can block the initiative (directly or indirectly), who influences the thinking of other key constituents, or who owns a key work process impacted by the change. Note: The team will bog down if the list exceeds 10 to 12 stakeholders. Differentiate between essential and important. If the list is still long, you may need to prioritize and focus on near-term support needs first. 2. List stakeholders along the left side of the form. 3. If you need to contact the stakeholder(s) to develop an assessment of their level of support, enter the name of the team member who will make contact. 4. Enter your assessment of the level of stakeholder support on the -2 through +2 scale. The scale values are: -2 = strongly opposed -1 = somewhat opposed 0 = neutral +1 = somewhat supportive +2 = very supportive 5. Place a Ö mark in the box that marks the estimated current level of support. Team consensus on exact position is not reuired, but there should be general agreement on whether the stakeholder is for, against or neutral. 6. Perform an assessment of where each stakeholder must be for the change initiative to succeed. Place an X mark in the box (-2 through +2) to indicate the level of support needed. 7. Evaluate the impact (High, Medium or Low) the stakeholder can have on the change. 8. Develop strategies, as needed, to move stakeholder support to desired levels. It may be sufficient to move someone from 2 (strongly against) to 0 (neutral) to succeed. Enter appropriate comments in the Remarks section.

16 Rev. 0 Page 15 of 18 Change Management Addendum 8 Communication Planning Page 1 of 1 Good communication planning is fundamental to any change management effort. The tools below provide a framework for creating a communication plan for any type of change. Communication: Tools Who Audience Message Issues Key Issues As We See Them 1a 1b 1c 1d 1e 2a 2b 2c 2d 2e As They See Them 1a 1b 1c 1d 1e 2a 2b 2c 2d 2e Tools & Tactics Planning Written Audience Desired Outcome Responsibility Type Message Events 1-on-1 Beginning Middle End General: These tools will help in the construction of a good communication plan. When selecting a media option, remember: Written communication is: * Most permanent, binding * Least expensive * Communicates to many, uickly * Provides greater consistency * Useful when instructing * Does not usually allow feedback Events are: * Most dramatic * Signal new direction * Good for symbolism One-on-one is: * Most effective for persuasion * High receiver attention * Most labor intensive, costly * Best feedback opportunity

17 Rev. 0 Page 16 of 18 Addendum 9 Change Management Feedback Survey Page 1 of 1 The final phase of a thorough change management effort is determining the effectiveness of the change. The primary source of information for this determination will be the measures established at the beginning of the change management planning. The degree to which the success measures or goals were reached should provide data to support change effectiveness. Timing: Due to the wide range of time frames that could apply to change, thought should be given to the timing of effectiveness evaluations. For example, it might be appropriate to check for the effectiveness of preliminary communication (i.e., is customer readiness where it needs to be?) early in a change evolution, then check again for the effectiveness of support during implementation. Like contingency planning, effectiveness measurement needs to be considered throughout the entire change process. At completion of the change process, a survey of those who were involved in the change is a valuable tool for determining change effectiveness. The survey below is an example of such a survey. Note that it provides for a numerical scoring of the change. It also allows for feedback specifically aimed at improving change processes. Change Management Feedback How did our change affect your area? Please take the time to provide feedback in the following areas: Affected Organization: Area of Review Needs Improvement Excellent Communications With Your Group Change Met Your Expectations Support Provided to Your Organization Overall Quality of Change Management Did you have any significant problem with the Change Management process we used? Description of the Problem: Yes No What processes/tasks should be added to improve Change Management? What is one thing we could do to improve your level of satisfaction? Directions for Use: Distribute the survey to participants in the change. Collect the feedback, compile the scores, compare them to the targets established during planning, and adjust as indicated.

18 Rev. 0 Page 17 of 18 Addendum 10 The Strategy Change Cycle Page 1 of 2 1. Initiate and agree upon a strategic planning process: The purpose of the effort Preferred steps in the process The form and timing of reports The role, functions, and membership of any group or committee empowered to oversee the effort The role, functions, and membership of the strategic planning team The commitment of necessary resources to proceed with the effort (Important limitations or boundaries on the effort should be made clear.) 2. Identify organizational mandates: What are we reuired to do in order to comply with regulations, technical specifications, policies and procedures, etc.? What self-imposed boundaries or limitations exist that we may alter at need? 3. Clarify organizational mission and values: Explain the fit of the change effort with the company vision. Explain how the change will further the company mission while serving the interest of stakeholders. 4. Assess the organization s external and internal environments: Explore the environment outside the organization to identify both opportunities and threats. Explore the environment inside the organization to identify both strengths and weaknesses. 5. Identify the strategic issues facing the organization: Describe the issue(s) succinctly; frame each as a uestion that the organization can do something positive to answer. List the factors that make the issue a fundamental challenge. (That is, in terms of the organization s mandates, mission, values, internal strengths and weaknesses, and external opportunities and threats, what makes this a strategic issue for the organization?) Prepare a statement of the conseuences of failing to address the issue. There are three kinds of strategic issues: NOTE 1. Those for which no action is reuired at present, but which reuire continuous monitoring. 2. Those that are coming up on the horizon and are likely to reuire some action in the future and perhaps some action now. (These usually can be handled as part of the organization s regular strategic planning cycle.) 3. Those that reuire an immediate response and therefore cannot be handled in a more routine way.

19 Rev. 0 Page 18 of 18 Addendum 10 The Strategy Change Cycle Page 2 of 2 6. Formulate plans and strategies to manage the issues: Identify practical alternatives (phrased with action verbs such as do get buy, etc.) List the barriers to achieving each alternative. Develop proposals for achieving alternatives. Formulate short-term (six months) and long-term plans to implement major proposals. 7. Review and adopt the strategies and plan: Include stakeholders in the review. Enlist skilled negotiators to sponsor and present the plan for approval. 8. Establish an effective organizational vision: Develop a description of what the organization will look like once it has successfully implemented its strategies. Communicate the vision widely within the organization. 9. Develop an effective implementation process (action plans): Define roles and responsibilities of oversight bodies, organizational teams, and individuals. Define specific objectives and expected results and milestones. List specific action steps and relevant details. Publish schedules. List resource reuirements and sources. Develop a communication plan. Define in-process reviews, progress monitoring plans, and midcourse correction procedures. Communicate accountability procedures. NOTE It is important to build in enough sponsors, champions, and other personnel along with enough time, money, and other resources to ensure successful implementation 10. Reassess strategies and the strategic planning process: Once the implementation process has been under way for some time, review the strategies and the strategic planning process as a prelude to a new round of strategic planning.

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