ML073170697
| ML073170697 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/08/2007 |
| From: | Bezilla M FirstEnergy Nuclear Operating Co |
| To: | Caldwell J Region 3 Administrator |
| References | |
| 1-1511 | |
| Download: ML073170697 (15) | |
Text
FENOC FirstEnergy Nuclear Operating Company 5501 Noilh Slate Roulc 2 Oak Harbor Ohio 43449 Marh B Bezilla 419321 7b7b Vice Presriieol Nuclear Fox 4 19 ?2 1 75H1 Docket Number 50-346 License Number NPF-3 Serial Number 1-1511 November 8, 2007 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission Region 111 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352
Subject:
Submittal of the Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan for the Davis-Besse Nuclear Power Station - Year 2007, Revision 1
Dear Mr. Caldwell:
The purpose of this letter is to submit Revision 1 of the assessment plan and related information for the 2007 independent external assessment of the Davis-Besse Nuclear Power Stations (DBNPS) Organizational Safety Culture and Safety Conscious Work Environment. The original Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan was submitted on June 11,2007, via DBNPS letter Serial Number 1-1494.
In accordance with the Nuclear Regulatory Commission (NRC) letter, dated March 8, 2004, Approval to Restart the Davis-Besse Nuclear Power Station, Closure of Confirmatory Action Letter, and Issuance of Confirmatory Order, (letter Log 1-4524),
the DBNPS is submitting Revision 1 to the Organizational Safety Culture and Safety Conscious Work Environment Assessment Plan, including the idcntification and qualifications of the assessors. Revision 1 is being submitted because one of the scheduled assessors for the on-site portion of the assessment had emergent obligations to fulfill pertinent to his position with his employer.
The change to the peer assessors scheduled to participate in this assessment was discussed with Mr. Geoffrey Wright, NRC Region 111, on October 25,2007. A resume detailing the qualifications of the new peer assessor was provided to Mr. Wright for review prior to commencement of the assessment.
Docket Number 50-346 License Number NPF-3 Serial Number 1-1511 Page 2 of 2 This assessment commenced, as scheduled, on October 29,2007. The change to the peer assessor is identified with revision bars in the right hand margin of Enclosure 1, Assessment Plan, and Enclosure 2, Assessor Qualifications. Revision 1 of the Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan - Year 2007 and the attached biographies supersede the original submittal in its entirety.
If you have any questions or require hrther information, please contact Mr. Raymond A.
Hruby, Jr., Manager - Site Regulatory Compliance, at (419) 321-8000.
Sincerely yours,
&iGLd&-Q-.&
Mark B. Bezilla J
LJS Attachment Enclosures cc:
USNRC Document Control Desk DB-1 NRC/NRR Project Manager DB-I Senior Resident Inspector Utility Radiological Safety Board
Docket Number 50-346 License Number NPF-3 Serial Number 1-151 1 Page 1 of 1 COMMITMENT LIST The following list identifies those actions committed to by FENOCs Davis-Besse Nuclear Power Station (DBNPS) in this document. Any other actions discussed in the submittal represent intended or planned actions by the DBNPS. They are described only for information and are not regulatory commitments. Please notify the Manager - Site Regulatory Compliance (419-321-8000) at the DBNPS of any questions regarding this document or associated regulatory commitments.
COMMITMENTS None. Serial 1-1 51 1 contains no new commitments.
DUE DATE NIA
Docket Number 50-346 License Number NPF-3 Serial Number 1-1511 Davis-Besse Nuclear Power Station Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan - Year 2007, Revision 1 (5 pages follow)
ORGANIZATIONAL SAFETY CULTURE AND SAFETY CONSCIOUS WORK ENVIRONMENT INDEPENDENT ASSESSMENT PLAN - YEAR 2007 Revision 1 I
NUMBER:
COIA-SC-2007 ASSESSMENT AREA:
Organizational Nuclear Safety Culture, including Safety Conscious Work Environment PURPOSE:
The purpose is to provide an independent and comprehensive assessment of the status of the existing Organizational Nuclear Safety Culture, including the Safety Conscious Work Environment (SCWE), at the Davis-Besse Nuclear Power Station (DBNPS). The assessment will be performed in accordance with the requirements of the March 8,2004, Confirmatory Order Modifying License No. NPF-3, and Davis-Besse Business Practice DBBP-VP- 0009, Management Plan for Confirmatory Order Independent Assessments. The assessment will be used to identify areas for improvement requiring corrective actions with action plans and observations for other improvement opportunities. The assessment will review the areas for improvement that were identified in the 2006 Independent Assessment and it will also be used to assess the rigor, criticality, and overall quality of the DBNPS internal self-assessment activities in this performance area.
The final assessment report will provide an overall concluding statement of the effectiveness of the Organizational Safety Culture using the rating categories of DBBP-VP- 0009.
INDEPENDENT ASSESSMENT TEAM:
SCOPE:
The Independent Assessment Team will evaluate the following areas associated with Organizational Nuclear Safety Culture, including the SCWE:
- 1. The Overall Organizational Nuclear Safety Culture at the DBNPS, including the following key cultural elements and sub-elements:
- a. Nuclear Safety Values, Behaviors and Practices Nuclear Safety Standards and Expectations 0
Nuclear Safety as Top Priority 0
Operational Nuclear Safety 0
Identification of Potential Nuclear Safety Issues 0
Timely Resolution of Identified Nuclear Safety Issues 0
Effective Resolution of Identified Nuclear Safety Issues 0
Continuous Improvement of Nuclear Safety Performance Confidence in the Effectiveness of the Corrective Action Program for the Identification and Resolution of Adverse Trends Adverse Effects of Workload on Nuclear Safety Page 1 of 5
- b. Safety Conscious Work Environment (SCWE)
Indicators and precursors of a potentially chilled work environment, including personal experience of receiving negative reactions for having raised potential Nuclear Safety issues or concerns.
- Influence of the General Site Environment on the SCWE
- Influence of Peers on the SCWE
- Influence of Supervision on the SCWE
- Influence of Functional Organization Management on the SCWE
- Influence of Site Senior Management on the SCWE Demonstrated willingness to Take Appropriate Action
- Willingness to Inform Supervision or to Document a Potential Nuclear Safety Issue/Concern
- Willingness to Escalate a Potential Nuclear Safety IssueKoncern to Management
- c. Employee Concerns Program (ECP) Effectiveness ECP as an Acceptable Alternative Path for ReportingiPursuing Potential Nuclear Safety Issues or Concerns Overall Employee Confidence in the ECP Bases for Employee Confidence in the ECP
- 2. The Overall Nuclear Safety Culture, including the following key cultural elements and sub-eIements, which correspond to the NRC RIS 2006-1 3 Safety Culture Components, will also be assessed:
- a. Human Performance Cross-Cutting Components Decision-Making Resources Work Control Work Practices
- b. Problem Identification and Resolution Cross-Cutting Components 0
Corrective Action Program 0
Operating Experience Self and Independent Assessments
- c. Safety Conscious Work Environment Cross-Cutting Components Environment for Raising Concerns 0
Preventing, Detecting and Mitigating Perceptions of Retaliation
- d. Other Safety Culture Components Accountability Continuous Learning Environment Organizational Change Management Safety Policies Page 2 of 5
- 3. The Nuclear Safety Culture Assessment (NSCA) will also include an assessment of key elements of the General Culture and Work Environment (GCWE) at the DBNPS, as industry experience indicates that low GCWE ratings are frequently precursors of potential future challenges to the Nuclear Safety Culture (NSC). In this regard, the NSCA will address environmental and programmatic areas that are important to overall performance and morale and that may have an interdependent relationship with the NSC.
- 4. The NSCA will also include an assessment of the following two key cultural metrics related to Leadership, Management and Supervisory Behaviors & Practices because they are indirectly related to the SCWE. Low metric ratings may be leading indicators of potential hture challenges to the SCWE.
Quality of Communications with the Workforce Environment of Trust and Mutual Respect
- 5. Evaluation of the effectiveness of the DBNPS actions to address previously-identified Areas for Improvement in the Nuclear Safety Culture, including the Safety Conscious Work Environment. This evaluation will include the Areas for Improvement and the Areas in Need of Attention that were identified in the 2006 Independent Assessment as they relate to Nuclear Safety Culture and Safety Conscious Work Environment.
- 6. Evaluation of the effectiveness of DBNPS self-assessment activities and self-identification of performance weaknesses.
INDEPENDENT ASSESSMENT TEAM:
John C. Guibert, SYNERGY Consulting, Team Leader Howard A. Levin, SYNERGY Consulting Timothy K. Snyder, SYNERGY Consulting Nuclear Plant, Peer Reviewer John Audas, TXU Power - Comanche Peak, Peer Reviewer David V. Garcia, FPL Energy (formerly Nuclear Management Company) - Point Beach I
The FirstEnergy Nuclear Operating Company (FENOC) has selected SYNERGY Consulting Services Corporation (SYNERGY) to perform the 2007 Assessment.
SYNERGY has extensive experience in conducting Nuclear Safety Cultural Assessments for the commercial nuclear industry, having performed more than 100 Nuclear Safety Cultural Assessments, including 48 nuclear power plant sites, 76 nuclear power plants and 2 gaseous diffusion plants. By virtue of the extent of SYNERGYS Nuclear Safety Culture Assessment activities, they are in a position to provide a meaningful frame of reference for the assessment results.
Mr. John C. Guibert will serve as SYNERGYS project manager for the Independent Assessment. He will be assisted by Mr. Howard A. Levin and Mr. Timothy K. Snyder. All three of these individuals are principals of SYNERGY Consulting Services Corporation. Mr. David Garcia and Mr. John Audas will serve as industry peer members of the Independent Assessment Team.
Biographies of the Assessment Team members are attached.
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SCHEDULE:
June 11,2007: Develop, review and submit assessment plan to the NRC.
September 4 through September 21,2007: Administration of the Nuclear Safety Culture Assessment Survey to DBNPS employees and long-term contractors.
October 29 through November 2, 2007: Personnel interviews and behavioral observations conducted onsite.
December 14,2007: Draft Assessment Report provided to FENOCDBNPS management and conduct of final debrief (marking completion of the assessment).
December 21,2007: Final Assessment Report provided to FENOUDBNPS management.
Final Assessment Report and action plans (if required by findings) will be submitted to the NRC within 45 days of the completion of the on-site assessment.
ASSESSMENT METHODS:
The Assessment Team will utilize the following methods for the conduct of the Independent Assessment. The information obtained through each method will be integrated to reach conclusions and to identify potential Areas of Strength, Areas for Improvement (AFIs), Areas in Need of Attention (ANAs) or other opportunities for continued improvement.
1, A Nuclear Safety Culture Assessment survey developed by SYNERGY will be used. The survey questionnaire will be very similar to that used for the 2006 Independent Assessment in order to ensure coverage of all of the necessary cultural attributes and to provide a sound basis for 2006-2007 direct trending information. All DBNPS employees and long-term contractors will be provided the opportunity to participate in this survey.
SYNERGY will utilize cultural assessment models and reporting formats to analyze and report the numerical results of the written survey. Results will be provided at various organizational levels. Individual Functional Organizations that are considered to be organizational outliers will be identified.
- 2. The Nuclear Safety Culture Assessment survey will include several opportunities for participants to provide write-in comments. The write-in comments will be analyzed by SYNERGY to validate the numerical survey results, to identify recurring themes, to obtain additional insights related to the underlying reasons for the numerical survey ratings and to identify (if applicable) additional issues not previously identified through the survey ratings.
- 3. The Assessment Team will conduct confidential personnel interviews of selected (by the Assessment Team) DBNPS personnel. These interviews will support a variety of assessmcnt objectives, including the following:
To obtain information to support an assessment of the effectiveness of corrective actions taken by DBNPS to address the AFIs and ANAs identified through the 2006 Independent Assessment of the NSC and SCWE.
To obtain information to support an assessment of the rigor, criticality, and overall quality of the DBNPS internal self-assessment activities related to the NSC/SCWE.
To obtain information on RIS 2006-13 attributes that are not amenable to being assessed through an all hands survey of the workforce.
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To validatdobtain information on the underlying reasons for low numerical survey ratings provided by individual Functional Organizations identified by SYNERGY as 2007 outliers with respect to industry norms criteria.
To validate that the numerical survey ratings provided by individual Functional Organizations with low survey participation are representative for those organizations.
- 4. The Assessment Team will conduct documentation reviews. Documents that will be reviewed include, but are not limited to, the following categories:
0 Policies and programs related to the Nuclear Safety Culture and the Safety Conscious Work Environment.
Information related to the effectiveness of corrective actions taken by DBNPS to address the AFIs and ANAs identified through the 2006 Independent Assessment of the NSC and SCWE.
Information to the rigor, criticality, and overall quality of the DBNPS internal self-assessment activities related to the NSCISCWE.
Information related to RIS 2006-1 3 attributes that are not amenable to being assessed through an all hands survey of the workforce.
These documentation reviews will be complemented by personnel interviews with personnel responsible for the implementation and oversight of such policies, programs and activities.
- 5. The Assessment Team will observe selected DBNPS activities to supplement information obtained from the above methods.
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Docket Number 50-346 License Number NPF-3 Serial Number 1-1511 Davis-Besse Nuclear Power Station Organizational Safety Culture and Safety Conscious Work Environment Independent Assessment Plan -Year 2007, Revision 1 Assessors and Qualifications (5 pages follow)
Biographies of Independent Assessment Team Members The following biographies are summary in nature. Additional details will be provided upon request.
Mr. John C. Guibert Independent Consultant SYNERGY Consulting Services Corporation Mr. Guibert will serve as SYNERGYS Project Manager for the Independent Assessment of the Organizational Nuclear Safety Culture at DBNPS. He served as Project Manager for the 2006 Independent Assessment of the Organizational Nuclear Safety Culture at DBNPS. He has previously served in this capacity for more than fifty similar Cultural Assessments.
Mr. Guibert has over 35 years of nuclear experience. He is a graduate of the United States Naval Academy and Catholic University (MSNE). Currently, he is a principal and founder of SYNERGY Consulting Services Corporation (founded in 1992). He co-developed SYNERGYS Comprehensive Cultural Assessment methodology - a process that establishes objective measures of nuclear safety and general culture based upon models of high performing enterprises.
He was formerly Senior Vice President and Chief Operating Officer of a major technical and management consulting firm serving the commercial nuclear power industry. Prior to that, he was responsible for the development and management of a nuclear consulting practice focused on improving the performance of operating nuclear power plants. His other previous experience includes management positions with another major nuclear consulting firm, technical and management positions with the Nuclear Regulatory Commission and service as an officer in the Navys nuclear power program.
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Mr. Howard A. Levin Independent Consultant SYNERGY Consulting Services Corporation Mr. Levin has over 30 years of commercial nuclear experience. He is a graduate of Massachusetts Institute of Technology. Currently, he is a principal & founder of SYNERGY Consulting Services Corporation (founded in 1992) where he is involved providing organizational development, cultural and leadership assessment services including diagnostic, remedial and performance enhancement consultation. He co-developed SYNERGY'S Comprehensive Cultural Assessment methodology - a process that establishes objective measures of nuclear safety and general culture based upon models of high performing enterprises. SYNERGY has applied this methodology in more than a hundred assessments covering the majority of the U.S. commercial nuclear power plants and several others worldwide.
Over the last several years, Mr. Levin developed enhanced 360 degree leadership evaluation models for use in mentoring and equipping leaders. He was formerly, Chief Operating Officer of a large technical and management consulting firm. He was with the Nuclear Regulatory Commission in the1970's where he was involved in both operating reactors and new plant licensing.
In the 1980's, he was involved in providing services to management including independent technical reviews, organizational and programmatic consultation, business process enhancement, and other advisory and analytical services. In his early career, he held positions with an architect-engineering firm where he was involved in the analysis, design and construction of nuclear power plants.
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Mr. Timothy K. Snyder Independent Consultant SYNERGY Consulting Services Corporation Mr. Snyder has over 35 years of experience in providing management and engineering consulting services to the nuclear power and other industries. He is a graduate of the University of California - Berkeley. In January of 2006, he became a principal of SYNERGY Consulting Services Corporation.
During the preceding eight years, Mr. Snyder worked as an Associate of SYNERGY, participating in the performance of comprehensive cultural assessments and improvement projects at more than twenty nuclear power and fuel processing facilities. In his consulting practice, he has specialized in management consulting focused on producing significant organizational performance improvements. His areas of management expertise include operational performance, safety and workplace culture, effective management practices, work process analysis and design, information system management, and procedure effectiveness. Mr.
Snyder has also worked as an Associate of Little Harbor Consultants in the performance of safety culture assessment and improvement projects for a nuclear facility, a major oil pipeline, and a DOE nuclear waste management contractor. In his early career, he held positions with two major nuclear consulting firms.
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Mr. David V. Garcia Manager, Industrial Health and Safety FPL Energy (formerly Nuclear Management Company)
Point Beach Nuclear Plant Mr. Garcia is presently the Manager of Industrial Health and Safety at the Point Beach Nuclear Plant, responsible for support and counsel in matters of industrial health and safety as they relate to the compliance with regulatory agencies. Mr. Garcia was peer team lead with Nuclear Management Company and a member of the Point Beach Nuclear Culture Survey Team. Other positions during his employment with Nuclear Management Company (NMC) include Maintenance SupervisorlPlanneriScheduler, Work Week Manager - Production Planning, and Corrective Actions Specialist in the Performance Assessment Group. Prior to his employment with NMC, Mr. Garcia was an electrical auxiliary operator at the Zion Nuclear Power Plant.
Mr. Garcia served as a Weather Specialist-Electronics Technician in the United States Air Force and will graduate from Silver Lake College in Wisconsin, with a Bachelor of Science Degree in Business Management.
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Mr. John W. Audas Industry Peer Reviewer TXU Power - Comanche Peak John W. Audas has been employed by TXU since 1985 and is currently the SAFETEAM Manager (Employee Concerns Program Manager) at the Comanche Peak Station.
Mr. Audas has over 30 years of nuclear power industry experience and five years experience in the petro-chemical industry. Prior to joining TXU, he held engineering positions at two nuclear Architect Engineering firms and performed as Engineering supervisor at a nuclear facility.
Previous positions held while employed at TXU include Licensing Engineer and Project Manager.
Mr. Audas is one of the founding members of the Employee Concerns Program Forum and a member of the forums Board of Directors.
Mr. Audas is a graduate of Georgia Institute of Technology and has a Bachelor of Science and Masters Degrees in Physics.
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