ML093090274
| ML093090274 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point  |
| Issue date: | 11/05/2009 |
| From: | Marvin Sykes NRC/RGN-II/DRP/RPB3 |
| To: | Nazar M Florida Power & Light Co |
| Shared Package | |
| ML093090264 | List: |
| References | |
| Download: ML093090274 (31) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 November 5, 2009 Florida Power and Light Company ATTN: Mr. Mano Nazar, Senior Vice President Nuclear and Chief Nuclear Officer P.O. Box 14000 Juno Beach, FL 33408-0420
SUBJECT:
PUBLIC MEETING
SUMMARY
- FLORIDA POWER AND LIGHT COMPANY -
ST. LUCIE AND TURKEY POINT NUCLEAR PLANTS - 05000335, 05000389 AND 05000250, 05000251
Dear Mr. Nazar:
This refers to the meeting conducted at our request at the Region II Office in Atlanta, Georgia on October 20, 2009. The purpose of the meeting was to discuss the Florida Power and Light Company processes for addressing employee concerns. Enclosed are a list of attendees and the presentation handouts.
The discussions focused on the following topics: Current Situation, Overview Timeline, Recent History, Root Cause Approach, Analytical Methods, Summary of Results, Causes and Corrective Actions, Effectiveness of Past Actions, Communications Plan, and Summary of Key Corrective Actions. The meeting was informative and did not result in any specific action items or decisions.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this meeting, please contact me at 404-562-4629.
Sincerely,
/RA/
Marvin D. Sykes, Chief Rector Projects Branch 3 Division of Reactor Projects Docket Nos.: 50-335, 50-389 and 50-250, 50-251 License Nos.: DPR-67, NPF-16 and DPR-31, DPR-41
Enclosures:
- 1. List of Attendees
- 2. Handout-Addressing Employee Concerns cc w/encls:
See page 2
FP&L 2
cc w/encl:
Alison Brown Nuclear Licensing Florida Power & Light Company Electronic Mail Distribution McHenry Cornell Director Licensing and Performance Improvement Florida Power & Light Company Electronic Mail Distribution Michael Kiley Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company Electronic Mail Distribution Niel Batista Emergency Management Coordinator Department of Emergency Management and Homeland Security Electronic Mail Distribution Paul Rubin (Acting) Plant General Manager Turkey Point Nuclear Plant Florida Power and Light Company Electronic Mail Distribution Abdy Khanpour Vice President Engineering Support Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mark E. Warner Vice President, Nuclear Operations South Region Florida Power & Light Company Electronic Mail Distribution Mitch S. Ross Vice President and Associate General Counsel Florida Power & Light Company Electronic Mail Distribution Marjan Mashhadi Senior Attorney Florida Power & Light Company Electronic Mail Distribution William A. Passetti Chief Florida Bureau of Radiation Control Department of Health Electronic Mail Distribution Ruben D. Almaguer Director Division of Emergency Preparedness Department of Community Affairs Electronic Mail Distribution Mano Nazar Senior Vice President and Chief Nuclear Officer Florida Power & Light Company Electronic Mail Distribution Richard L. Anderson Vice President Nuclear Plant Support Florida Power & Light Company Electronic Mail Distribution Senior Resident Inspector Turkey Point Nuclear Generating Station U.S. Nuclear Regulatory Commission 9760 SW 344th St.
Florida City, FL 33035 Attorney General Department of Legal Affairs The Capitol PL-01 Tallahassee, FL 32399-1050 Mike A. Shehadeh, P.E.
City Manager City of Homestead Electronic Mail Distribution cc w/encl. (continued next page)
FP&L 3
cc w/encl. (continued)
County Manager of Miami-Dade County 111 NW 1st Street, 29th Floor Miami, FL 33128 Rajiv S. Kundalkar Vice President - Fleet Organizational Support Florida Power & Light Company Electronic Mail Distribution Gordon L. Johnston Site Vice President St. Lucie Nuclear Plant Electronic Mail Distribution Robert J. Hughes Plant General Manager St. Lucie Nuclear Plant Electronic Mail Distribution Mark Hicks, Operations Manager St. Lucie Nuclear Plant Electronic Mail Distribution Eric Katzman, Licensing Manager St. Lucie Nuclear Plant Electronic Mail Distribution J. Kammel Radiological Emergency Planning Administrator Department of Public Safety Electronic Mail Distribution Senior Resident Inspector U.S. Nuclear Regulatory Commission St. Lucie Nuclear Plant U.S. Nuclear Regulatory Commission P.O. Box 6090 Jensen Beach, FL 34957-2010 Faye Outlaw, County Administrator St. Lucie County Electronic Mail Distribution Jack Southard, Director Public Safety Department St. Lucie County Electronic Mail Distribution
LIST OF ATTENDEES Nuclear Regulatory Commission (NRC)
L. Reyes, Regional Administrator, Region II (RII)
V. McCree, Deputy Regional Administrator, RII L. Wert, Director, Division of Reactor Projects (DRP), RII K. Kennedy, Director, Division of Reactor Safety (DRS), RII O. DeMiranda, Senior Allegation Coordinator, EICS, RII L. Jarriel, Agency Allegation Advisor, Office of Enforcement M. Sykes, Chief, Reactor Projects Branch 3 (RP3), DRP T. Hoeg, Senior Resident Inspector, St. Lucie, RII
- S. Stewart, Senior Resident Inspector, Turkey Point, RII
- J. Hamman, Project Engineer, RP3, DRP, RII M. Checkle, Allegation Coordinator, EICS, RII J. Dymek, Reactor Inspector, DRS, RII D. Merzke, Acting Branch Chief, RP7, RII Florida Power and Light (FP&L)
M. Nazar, Senior Vice President Nuclear and Chief Nuclear Officer, FP&L G. Johnston, Site Vice President, St. Lucie, FP&L M. Kiley, Site Vice President, Turkey Point, FP&L R. Kundalkar, Vice President, Fleet Organizational Support, FP&L D. Lowens, Director Nuclear Assurance, FP&L G. Hollinger, Manager Projects, FP&L H. Casper, Senior Staff Engineer, FP&L M. Ross, Vice President, General Counsel - Nuclear, FP&L R. Anderson, Vice President, Nuclear Plant Support, FP&L Public Attendance Two members of the Public *
- Teleconference call
Addressing Employee Concerns October 20, 2009
2 Mano Nazar Chief Nuclear Officer Gordon Johnston Vice President, St. Lucie Mike Kiley Vice President, Turkey Point Raj Kundalkar Vice President, Fleet Organizational Support Dave Lowens Director, Nuclear Assurance Gary Hollinger Manager Projects Hugh Casper Senior Staff Engineer Mitch Ross Vice President, General Counsel - Nuclear FPL Attendees
3 Opening Remarks Current Situation Overview Timeline Recent History Root Cause Approach Analytical Methods Summary of Results Causes and Corrective Actions Effectiveness of Past Actions Communications Plan Summary of Key Corrective Actions Closing Remarks Agenda
4 Current Situation
- Employees have respect for nuclear safety
- FPL is committed to safe and reliable operation of our nuclear plants
- Current activities did not identify any nuclear safety issues requiring immediate action
5 Overview Timeline 1995 - 2007 Cyclic ECP Performance 2008 Employee Engagement Survey 2008 Survey Analysis and Corrective Actions NRC Allegations Continue, Internal Avenues Bypassed 2009 Root Cause
6 Recent History
- 2008 employee engagement survey issues
- Ability to challenge management decisions
- Management expectation for nuclear safety v. performance reward system
- Effectiveness of the corrective action program
- Effectiveness of the employee concerns program
- Action plans established for St. Lucie, Turkey Point, and ECP
- Action plans reviewed by SCWE industry expert (Rail - 8/09)
- Implementation of actions still in progress
7 Root Cause Approach
- FPL developed a charter to complete a root cause evaluation investigating recent feedback on employee concerns
- The root cause evaluation focused on the following areas:
- Effectiveness of the corrective action program
- Effectiveness of the employee concerns program
- Effectiveness of senior management
8 Root Cause Approach
- The root cause team composition included:
- Root cause team Juno Beach lead, with site support teams representing both bargaining/non-bargaining employees, and contract personnel at St. Lucie and Turkey Point Supported by three independent root cause experts
- Internal oversight FPL executive team to monitor progress of the root cause activities
- Consultation with ex-nuclear executive
- Consultation with former senior NRC official
- Employee concerns program expert report used in root cause evaluation
9 Analytical Methods
- Root cause evaluation used:
- Management oversight and risk tree (MORT)
Management oversight and risk tree questions Safety culture supplement to MORT questions NRC Inspection Manual Chapter 0305
- Why staircase analysis
- Barrier analysis
10 Analytical Methods
11 Summary of Results
12 Causes and Corrective Actions Root Cause 1 Management has missed opportunities to correct early indications of a decline in work environment resulting in allegations made directly to the NRC where internal problem resolution processes were bypassed 1.1 A comprehensive, integrated process for routine monitoring of all the essential elements for a healthy nuclear safety culture currently does not exist a) Create a comprehensive, integrated nuclear safety culture process, including key NSC metrics b) Design and conduct training on NSC process to employees and senior/executive management team Contributing Causes Key Corrective Actions
13 Causes and Corrective Actions 1.2 Inconsistent prioritization of nuclear safety culture issues a) Establish an oversight group to monitor NSC issues b) Review total work order backlog for proper prioritization c) Review backlogs of procedure change requests, condition report actions, and preventive maintenance change requests for proper prioritization consistent with NSC aspects d) Conduct periodic employee focus group meetings to assess progress on safety culture feedback Contributing Causes Key Corrective Actions Root Cause 1 Management has missed opportunities to correct early indications of a decline in work environment resulting in allegations made directly to the NRC where internal problem resolution processes were bypassed
14 Causes and Corrective Actions 1.3 Corrective actions have not fully resolved nuclear safety culture issues a) Ensure any NSC/SCWE evaluations/analyses and corrective actions are captured in corrective action program with special emphasis for resolution b) Develop trending for NSC issues Contributing Causes Key Corrective Actions Root Cause 1 Management has missed opportunities to correct early indications of a decline in work environment resulting in allegations made directly to the NRC where internal problem resolution processes were bypassed
15 Causes and Corrective Actions 1.4 Oversight organizations do not consistently monitor
/evaluate essential elements of a nuclear safety culture in aggregate a) Incorporate key NSC elements into oversight group charters b) NSC oversight group to review employee exit interviews c) NSC oversight group to present the content and conclusions of this root cause evaluation at a CNRB meeting d) NSC review included as a standing agenda item for CNRB meetings Contributing Causes Key Corrective Actions Root Cause 1 Management has missed opportunities to correct early indications of a decline in work environment resulting in allegations made directly to the NRC where internal problem resolution processes were bypassed
16 1.5 There is no alternative process for documenting and addressing dissenting or differing perspectives on key management decisions a) Develop and implement a process for differing professional opinions (DPO) b) Assign an NSC executive sponsor to periodically meet with senior leadership team to identify and discuss any NSC issues and reinforce expectations to challenge issues that could threaten NSC Contributing Causes Key Corrective Actions Causes and Corrective Actions Root Cause 1 Management has missed opportunities to correct early indications of a decline in work environment resulting in allegations made directly to the NRC where internal problem resolution processes were bypassed
17 Causes and Corrective Actions Improve Effectiveness a) Move ECP offices into the protected area at each site b) Require a documented and approved formal investigation plan for ECP investigations of a complex nature c) Revise the process for out-of-scope referrals to ensure thorough issue resolution d) Implement a process to obtain face-to-face feedback from concernees on adequacy of service provided Improve Perception of Independence a) Reinvigorate ECP by increasing program visibility (employee outreach meetings, workforce presentations, developing and posting new ECP communications) b) ECP to meet regularly with senior management team to discuss program status, training, and outreach 1.6 The ECP is perceived to lack effectiveness.
At St. Lucie the ECP is perceived to be too closely aligned with site management Contributing Causes Key Corrective Actions Root Cause 1 Management has missed opportunities to correct early indications of a decline in work environment resulting in allegations made directly to the NRC where internal problem resolution processes were bypassed
18 Root Cause 2 Certain management actions have negatively impacted employee trust and resulted in a perception that production often takes precedence over safety 2.1 There is an organizational perception of inconsistent accountability for senior management, both in terms of performance and behaviors, that has eroded employee trust Contributing Causes Key Corrective Actions Causes and Corrective Actions a) Establish an oversight group to monitor NSC b) HR to monitor expected management behaviors for improving employee trust c) Develop and implement a procedure for on-boarding new senior/executive managers to include attributes of NSC, union history, corporate culture, SCWE culture, and key historical division events and station operations
19 2.2 Many operational and other management decisions have been perceived to place emphasis on production at the expense of safety Contributing Causes Key Corrective Actions a) Revise operational decision-making process to include enhanced:
- Risk criteria
- Communication requirements
- Effectiveness review
- Criteria for management deviation from recommendation b) Implement a procedure for DPO Causes and Corrective Actions Root Cause 2 Certain management actions have negatively impacted employee trust and resulted in a perception that production often takes precedence over safety
20 2.3 Employees perceive that management has created an urgency to implement change and react immediately to issues without considering resources and work environment impact Contributing Causes Key Corrective Actions a) Implement a structured process to frequently evaluate competing priorities b) Review and implement a long and short term strategic plan aligning business objectives and major initiatives consistent with available resources Causes and Corrective Actions Root Cause 2 Certain management actions have negatively impacted employee trust and resulted in a perception that production often takes precedence over safety
21 2.4 The reward and recognition system is perceived to be heavily weighted toward production over safety Contributing Causes Key Corrective Actions a) Re-evaluate current reward system to ensure measures of NSC are considered Causes and Corrective Actions Root Cause 2 Certain management actions have negatively impacted employee trust and resulted in a perception that production often takes precedence over safety
22 2.5 There is evidence that a lack of vertical and horizontal alignment between management and supervision on key decisions is having a negative impact on trust Contributing Causes Key Corrective Actions a) Establish a program/process for supervisor/manager alignment meetings b) Develop a plan to communicate on-going progress c) Reinforce the importance of open communications for all personnel d) Administer a station cultural assessment in 2010 and establish corrective actions based on the results Causes and Corrective Actions Root Cause 2 Certain management actions have negatively impacted employee trust and resulted in a perception that production often takes precedence over safety
23 Effectiveness of Past Actions Past actions on SCWE/NSC issues were narrowly focused Sites were asked to assess their areas individually Corrective actions were low-level and site-specific New approach involves a comprehensive, corporate/site approach
- Use of formal root cause methodology
- Multiple industry root cause experts
- Focus groups, individual interviews provided real-time input
- Broader NSC scope of investigation
- Monitoring of comprehensive NSC metrics
- Leveraged industry operating experience
24 Communications Plan
- Communicated formation and purpose of the root cause team to employees
- Site-specific communications and engagement plans
- SVP/PGM to frequently attend department meetings; increase frequency of all-hands meetings and walk arounds to engender trust
- Integrate key safety culture messages into all site communications
- Communicate lessons learned from root cause, actions to close gaps
- Reinforce messages through executive communications, all-hands meetings, newsletters, small employee meetings
- Refresh ECP identity through updated posters, handouts, outreach meetings, and workforce presentations
- Issue regular updates on status of program implementation, key milestones met, and issues resolved
25 Summary of Key Corrective Actions Reinvigorate the ECP by increasing program visibility Aggressive close-out of personnel safety work orders at St. Lucie Define the essential elements of a comprehensive, integrated nuclear safety culture process Enhance operational decision-making process Review major initiatives to align resources Re-evaluate current reward system to ensure measures of NSC Use surveys and focus groups to monitor safety culture Status update to NRC in mid-summer 2010
26 Questions?
F=PL
NSC Indicators Workforce willingness to raise concerns using normal problem resolution process Action requests distribution by general work environment category Industrial safety work orders - burn off Operator aggregate index Change management Key management turnover Modification backlog Management effectiveness at resolving concerns using normal problem resolution process Effectiveness of the alternate resolution process Management effectiveness at detecting and preventing retaliation General work environment Total action requests initiated by month Condition report initiation Action requests with GWE code for less than adequate actions Correct condition/prevent recurrence (CC/PR) backlog Quality of corrective actions Condition report correct condition/prevent recurrence related actions overdue Condition report timeliness - age of open condition reports Employee concerns Contacts Hotline reports Allegations Labor grievances Nuclear safety culture cause codes for significant condition reports Anonymous concerns Harassment, intimidation, retaliation, discrimination (HIRD)
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