ML17347A639
| ML17347A639 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point, 05000000 |
| Issue date: | 12/02/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Woody C FLORIDA POWER & LIGHT CO. |
| References | |
| NUDOCS 8712070318 | |
| Download: ML17347A639 (7) | |
Text
OP "~Gus Wp0 Iu 4**y 4 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 101 MARIETTASTREET, N.IN.
ATLANTA,GEORGIA 30323 Florida Power and Light Company ATTN:
Mr. C. 0.
Woody Group Vice President Nuclear Energy Department P. 0.
Box 14000 Juno
- Beach, FL 33408 Gentlemen:
SUBJECT:
INDEPENDENT MANAGEMENT APPRAISAL PROGRAM PLAN This letter summarizes the results of our review of the Independent Management Appraisal Program Plan submitted to us in a meeting in Atlanta on November 18,
- 1987, pursuant to the NRC Order issued to you on October 19, 1987.
The con-tents of this Plan were.discussed further in a
Management Meeting on November 24, 1987, at the Turkey Point site.
The following are our comments on this Plan, many of which were made during the November 24 meeting:
1.
The Plan does not appear to address directly important problems that have already been identified as principal weaknesses at the Turkey Point site.
These include the aspects of teamwork, leadership, professionalism, accountability, explicit management goals and objectives, measures of achievement, etc. -- in short, it does not address explicitly the culture needed to improve performance.
However, in your response (dated SepteIIIber 21, 1987) to our recent Systematic Assessment of Licensee Performance, you appropriately made reference to weaknesses in account-ability, employee awareness, plant and corporate goals and expectations, team involvement, and dedication.
2.
Page ll of the Plan states that the recommendations of the appraisal will be "based upon factual evidence instead of subjective opinions."
We were concerned that a narrow interpretation of "factual evidence" might pre-clude placing much weight on the very important subjective opinions that will result from the numerous personnel interviews.
We were advised that all information gathered from the interviews will be'onsidered "factual."
This should be confirmed.
3.
Page I of the Plan gives the distinct impression that numerous FPIIL initiatives have resulted in substantial improvements in operations at Turkey Point, but "NRC inspection activities have continued to identify breakdowns in communications and failures to comply with procedures and regulatory requirements."
While these are true statements, we believe that FPIEL has also identified significant problems, is greatly concerned about the "people problem" at Turkey Point, and therefore initiated the proposed Appraisal Plan.
These problems should be clearly identified as FPIIL concerns as well as NRC concerns.
8712070318 871202 PDR ADOCH, 05000250 P
Florida Power and Light Company 4,
5.
6.
7.
It is not clear how much of the Appraisal resources will be expended at the St. Lucie site.
We continue to believe that the most effective Appraisal would be obtained by (a) devoting a significant effort toward comparing St. Lucie to Turkey Point, i.e.,
what management programs and techniques have lead to success at St. Lucie; and (b) evaluating the corporate link between the two sites.
Also, how will St. Lucie and Turkey Point findings be compared.
We are concerned that the amount of the data proposed to be collected and computerized will be unmanageable.
Also; the scope of the project seems so broad that the available time and resources might be diluted so that sufficient resources would not be available to probe already identified weak areas.
This will require careful management during implementation of the program.
A process needs to be established to handle any safety matters or allegations that may be identified during the appraisal.
As stated at the November 24 meeting, we will work with you in developing an appro-priate process.
It is not clear whether the Plan includes assessment of the effectiveness of communicating both laudable and unacceptable personnel performance to the rest of the site as "lessons learned."
8.
9.
10.
12.
13.
It is not evident how evaluation of current upgrade and improvement programs are factored into the review.
They are mentioned in Section III, "Appraisal Process,"
but are not specifically followed up in the subtasks.
It is not clear how the items from Task 6 will be reviewed and correlated with Task 7 to identify trends and important relationships.
The section addressing Safety Review Committees (SRC) does not indicate that the effectiveness of the SRC will be evaluated nor if any actual SRC meetings will be attended.
The assessment of current personnel should include the effectiveness of Site and Corporate officers.
The Plan identifies the various issues to be assessed.
However, it does not discuss how the numerous assessments wi 11 be accomplished or against what criteria FPSL will be judged.
The Appraisal should include an assessment of why many of the NRC adverse inspection findings were not previously identified by FP&L.
The Plan does not contain a sufficient description of the credentials of the participants to draw any real conclusions.
- However, we did obtain resumes from Enercon on November 25.
A review of these resumes revealed that the Appraisal will use personnel with appropriate
.credentials and experience base.
There-
- fore, we have no comment on the qualifications of the individual participants.
Florida Power and Light Company It would be useful, although not mandatory, to revise the Plan to accommodate many of our comments.
- However, we would appreciate a response to our comments within the next 30 days.
We believe the Plan is comprehensive and see no fundamental reason why it should not achieve your desired objectives.
There-
- fore, we hereby approve the proposed Plan.
Sincerely, J.
Nelson Grace Regional Administrator cc:
R.
E. Talion, President and Chief Executive Officer J.
S.
Odom, Vice President C. J.
Baker, Plant Hanager L.
W. Bladow, Plant gA Superintendent J. Arias, Jr., Regulatory and Compliance Supervisor bcc:
Document Control Desk State of Florida Resident Inspector RI RI I Reyes
~ rnst 12/Q/87 12/~87
~gii aEO0, P
C O
I ch0v kg**4 Region II UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 FPOM; NRR
SUBJECT:
COMMENTS ON INDEPENDENl MAI'lAGEI',khan APPRAISAL PROGRAV, PLAN - TURkEY POINT PLANT The folilGwing are the combined Ieadquarters coiiwients arid prcposed reworc."nc cf pour drafi comments of 11/25/87.
The Plan does not appear to address directlp important probleIKs that havE already been identified as principa'. weakresses at the Turkey Point sitE.
These include the aspects of teaniwork, leadership, accountabi'.ity, explicit manageiiieri goals and objectives, measures of achievement; etc. -- iri short dGES not address exp:icitly the culture needed to achievE Excellence
~
However, iri yGul rE'sponse (dated September 21, 1967) to our recent SystE-rrztic Assessment of Licer!See Performance, you appropriately made re erence to weaknesses in accountability, emplcyee awareness, plant ard corpcratE goals and expectatioris, tear involveiiient, and dedicatior.
2.
Page 11 of the Plan states that the recoiieiendations of the appraisal wi.'e "based upon factual evidence instead of subjective opinions."
We were concernEd that a narrow interpretatiori of "factual evidence" might prec>ude placing much weight on the very important sub-:ective opinions tFiat result fror.. thE rurie)ous perscrire'i interviews.
We were advised that all inforiiiation gathered froiI; the inter views will bE considered "factual."
This should be confirmed.
Page 1 of the Plan gives the distinct impressiori i,hat nuiiierous FNL initiatives have resulted iri substantial improvemerits in operations at Turkey Point, but "NRC inspection activities have continued to ideritif~
breakdowTis iri coIIniunications and failures to comply with procedures and regulatcry requirements."
While these are true statements, we believe that FPEL has also identified significant problems, is greatly concerned abcut the "p&Gple problem" at Turkey Point, and initiated the proposed appraisal plari.
These problems should be clearly identied as FPAL concern.
as well as KRC concerns.
It is not clear how much o< the appraisal rEsources willi bE cxpendeo af the St. Lucie site.
Wie continue tc be":ieve that the most effective appraisai wou'd bE obtained hy devotino a sigrificarit effort toward coi-paring St. Lucie Iiaragerient prograris aria techniques to Turkey Point. Yore impGrtanf.
how 0 i il t ~ Lucie fifldings and TP -
L compai isons bE evaluatfd, l"e are concernec that the amourit Gf'lie cata proposed to be collected ard computerized w"ii tE uniTanageable.
Also, the scope of'he project seems so hrcao that the availablE tiIIE and resources might be diluted so that suf.iciert resources would rot he available to prohe already idertifiec'.
weak areas.
This will require careful raragement duririg implemertaticr of the program.
6.
Procedures need to be established to hardie any safevy matters or allega-tions that may be identified cur ing the appraisa',.
fs stated at. the November 24 meeting, we will wcrk with you in developing appropriate pro-cedures.
7.
Jt is rot evident how evaluat for'f current upgrade and improvement prc-grams are factored into the review.
They are mentioned ir. Section
- JJJ, "Appraisa'. Process",
but are not specifically followed up in the subtasks.
8.
It is rot clear hov. the items from Task 6 wil'. be reviewed and correlateP with Task 7 to identify trends arid important relationships.
S.
The section addressing Safety Pevie~
Committees (SkCj oces rot indicate that the effectiveriess of the SEC will be evaluated ror if ary actua'.
SRC meetings will be at. tended.
lC.
The assessmerit of the qualifications of current perscr.nel should irclude key mar agement positions at the Site and Corporate Vice P> esidert levels.
The Plan appears to discuss what wil': be done to assess the various issues.
Yowever, it ooes not, discuss ho> the numercus assessrrerts will be accor:-
plished or against what criteria FPKL will be iudged.
Various crite>ia which could be used are:
Regulatory Guides, AtlS Standards, INPG Criteria ard Gccd Practice, Industry Practice or "Ideals" developed in other situa-tions which could be applicable tc nuclear power.
1,'e propose that tt e Plan be approved sub.'ect to the above cors:cuts, that the
',pensee proceed to implement the Plari itiuediately ano provide written responses io the atcve concerns.
\\
gecument Name.~0 TO ROII FR.
NRR Requestor's ID:
GILBERT Author's Nam:
H. Berkow:bg Document Co+rents:
CGViViEVTS ON INDEPENDENl I'ANAGEtlEh7 APPRAISAL PROGRAM'. - TP