ML18059A996
| ML18059A996 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/12/1994 |
| From: | Morris B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Cooper R NRC |
| References | |
| NUDOCS 9405250202 | |
| Download: ML18059A996 (23) | |
Text
'.
consumers Power Michael G Morris President and POW ERIN&
lllllCHl&AN"S PRO&RESS Chief Executive Officer General Offices: 212 West Michigan Avenue, Jackson, Ml 49201 * (517) 788-1111 May 12, 1994 Mr Richard W Cooper II Diagnostic Evaluation Team Leader US Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgetown Rd Bethesda, MD 20814 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - ACTIONS TO ENHANCE THE PERFORMANCE OF PALISADES
Dear Mr Cooper:
Cpnsumers Power Company (CPCo) and its new nuclear management team is dedicated t()
the safe, cost-effective, and reliable operation of its Palisades plant. Beginning in; mid-1993, a decline in performance at Palisades was evident to CPCo top management and to NRC top Region management. We had observed a decline in performance at Palisades which was confirmed in December by the NRC's SALP report for the previous period. As a result, CPCo initiated numerous actions to improve the performance of Palisades. Some of these actions, such as our senior nuclear management changes, were initiated prior to the arrival of NRC's Diagnostic Evaluation Team (DET} at Palisades. Other actions have resulted from observations and interactions with the DET which have helped us to identify problems and further refine ou*r actions to achieve improved performance.
The purpose of this letter is to provide the DET with an overview and additional information regarding the enhancements which CPCo has initiated at Palisades. The enclosure to this letter describes in detail the actions which CPCo has taken to improve Palisades perfor-mance, and the actions which we will be taking to respond to the DET inspection. These actions are summarized below.
First, CPCo established a new executive management team for its nuclear activities. In January, David Joos was promoted to Senior Vice President of Nuclear, Rates and Market-ing. Mr Joos has a masters degree in nuclear engineering and has held a number of nuclear managerial positions, including manager in charge of the Palisades steam generator replace-ment project. In early February we replaced our Nuclear Vice President and Robert Fenech was appointed Vice President of the Nuclear Operations Department. Mr Fenech was previously the site vice president for Sequoyah and the general manager for Arkansas Nuclear One. CPCo also in Mlrch appointed a new Plant General Manager for Palisades,
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and is now actively seeking highly qualified and experienced individuals from outside CPCo
- to fill the positions of Director of the Nuclear Performance Assessment Department, and the Manager of the Nuclear Engineering and Construction Department. Further, a reverse foanee from INPO-has been installed as System Engineering Manager. This new manage;,. -
ment team has already established a higher standard of performance based upon the funda-2
. mental principles of placing quality over cost and schedule, instilling a questioning attitude in all personnel, and open communications and interactions between all levels of the organiza-tions and between the different groups within the organization. In this regard, management is stressing the need to address the following matters: planning and control of work; developing effective management information tools and processes; placing priority on support of operations by, for example, minimizing operator work-arounds; ensuring that Palisades takes into account changes in industry standards and events; and performance of effective self-assessments.
Second, CPCo has taken steps to better identify its own problems. CPCo has enhanced its self-assessments by holding employee meetings in which senior management has stressed the importance of self-assessments;_ adding individuals to its Nuclear Performance Assessment Department (NP AD) who have recent line experience, including nuclear experience outside of CPCo; modifying the Nl>AD role to focus solely on oversight, assessments, and trending; and, on March 16, establishing the Nuclear Management Safety and Review Committee (MSRC) with five experienced non-CPCo personnel (including MSRC Chairman William Conway from Arizona Public Service and James Partlow retired from the NRC) to provide for more diverse observations of performance. CPCo has also enhanced its corrective action program by establishing a single reporting system, expanding the scope of issues requiring reporting to capture non-consequential events, and requiring management review of root cause evaluations.
Third, CPCo has established a plan for restarting from the current outage at Palisades. The Restart Plan,provides the vehicle by which plant management has identified its expectations for effectively assessing the plant's readiness for heat-up and start-up. As part of the actions being conducted under the Restart Plan, CPCo is conducting multi-discipline reviews of open corrective actions and maintenance work orders to determine the safety significance of these open items and prioritize them. Additionally, system engineering has evaluated these items individually and cumulatively to determine if they could prevent any systems from perform-ing their safety functions. Additionally, previously closed and open safety system design confirmation discrepancies (i.e., discrepancies between the design basis and lower tier documents) have been evaluated to verify that appropriate actions have been taken or are planned to be taken to address these discrepancies. CPCo has also evaluated open items identified by various hardware-related programs to determine the cumulative effect of these items on plant safety. Finally, as part of its Restart Plan, CPCo is performing reviews of the
--various departments at Palisades (including-evaluations of department roles and responsibili-.
ties, processes, and resources) to provide increased confidence in our ability to safely operate the plant. The focus of the reviews being conducted pursuant to the Restart Plan is to identify critical needs to be addressed in the near term. These short-term actions are identified in a tracking system, and are the subject of daily meetings. To help complete these actions, additional resources (personnel and budget) are being committed. As discussed below, longer-term actions to achieve lasting improvements in performance are being addressed through the Palisades Performance Enhancement Program.
Fourth, in early 1994, CPCo decided to systematically evaluate areas warranting improve-
. ment, prioritize actions to achieve improvement, and to integrate these actions into a Palisades Performance Enhancement Plan (PPEP). The PPEP identifies Focus Area and 3
- Goals for improvement in the areas of I::.eadership and Management, Programmatic Improve,.
- ment, Human Performance, Culture, Critical Assessment, and Plant Condition. In each of these areas, a number of Objectives are identified, and Actions Plans are being developed to
- achieve these objectives. To ensure that its Goals and Objectives are achieved, the PPEP includes a number of controls to provide accountability for completing the Action Plans, to verify and validate completion of the Plans, and to monitor performance to confirm that the Action Plans have been successful in achieving and sustaining improved performance. The PPEP is a living document and will be periodically updated to reflect completion of improve-ments and new developments and issues. In this regard, CPCo has been performing consultant root cause analyses of the observations of the NRC's Diagnostic Evaluation Team (DET), and additions to the PPEP have already resulted from the review of the DET observations. Given the comprehensive evaluations that were undertaken in developing the PPEP, in implementing the Restart Plan, and in analyzing the DET observations, CPCo believes that most if not all of the DET findings with generic or programmatic implications are being addressed by the PPEP or other corrective actions. To confirm that the DET findings are being appropriately addressed, CPCo will evaluate the DET Report after it is issued, and the PPEP will be expanded as warranted to address DET findings in areas that are not currently the subject of PPEP Action Plans.
In conclusion, in order to accomplish our mission of safe and reliable operation of Palisades, we have already made extensive changes to enhance our management, plant, and programs, and have further actions planned. Our ongoing enhancements are being integrated into the Palisades Performance Enhancement Plan, which is designed to achieve and maintain sustained improvements in performance. The PPEP is a living document and will be revised as necessary to reflect the findings of the DET.
While I appreciate and fully support the DET's efforts to identify and assess the plant's performance and actions that the NRC believes are needed, I hope that your report will also acknowledge the strong and significant actions of CPCo beginning in January of this year to deal with many of the problems that have been defined.
Sincerely, CC: James M Taylor Enclosures
ACTIONS TO ENHANCE THE PERFORMANCE OF PALISADES
1.0 INTRODUCTION
This enclosure is organized as follows. Section 2 below describes the short-term enhancements which Consumers Power Company (CPCo) has initiated based upon its identification of issues to date and implementation of CPCo's plan for restarting from the current outage at Palisades. Thes~ enhancements pertain to the areas of management and organization, design and plant conditions, programs, and reviews and evaluations. Section 3 below describes the fonger-tenn enhancements which have been incorporated into Palisades Performance Enhancement Program (PPEP), including actions which CPCo will be taking to revise the PPEP to reflect the findings of NRC's Diagnostic Evaluation Team (DET) inspection of Palisades. Section 4 provides the conclusions.
2.0 DESCRIPTION
S OF ENHANCEMENTS AT PALISADES 2.1 Enhancements in Management and Organization 2.l.l Management Personnel Changes CPCo has established a new executive management team for its nuclear activities.
Specifically:
o In January 1994, Michael Morris was promoted to President and Chief Executive Officer (CEO).
o In January 1994, David Joos was promoted to Senior Vice President of Nuclear, Rates and Marketing reporting to Mr. Morris. Mr. Joos has a masters degree in nuclear engineering and has held a number of managerial positions in the Nuclear Operations Department (NOD), including manager in charge of the Palisades steam generator replacement project.
o In early February 1994, Robert Fenech was appointed Vice President of NOD reporting to Mr. Joos. Mr. Fenech was previously the site vice president of the Sequoyah nuclear plant, and the general manager at the Arkansas Nuclear One nuclear plant.
To provide additional nuclear experience on the Board of Directors, John Y asinsky was elected to the Board as an outside director. He has 30 years of experience at Westinghouse, and was Westinghouse's group president with responsibility for power generation, nuclear power, process control, and environmental systems businesses.
2 Changes have*"also made been in *Palisades plant management to effect a higher standard of performance and support safe operation. Thomas Palmisano, who has 22 years of nuclear experience, was. promoted from Operations Manager to Plant General Manager in March 1994. CPCo is also actively seeking highly qualified and experienced outside individuals to fill the positions of Nuclear Performance Assessment Department (NPAD) manager, Manager of Nuclear Engineering and Construction (NECO), and Operations Manager. Further, a reverse loanee from the Institute of Nuclear Power Operations (INPO) has been installed as the Systems Engineering Manager.
Fmally, earlier this year, the outage planning and scheduling function was separated from the Operations Department. This new position reports to the Plant General Manager. The Outage Planning and Scheduling Manager position has been filled with the promotion of the Operations Department Support Superintendent. Also, the Plant Safety & Licensing Director now reports directly to the Vice President of NOD.
2.1.2 Increasing Management Direction and Oversight of Plant Activities CPCo has also taken a number of steps to increase senior management direction and oversight of plant activities. To provide close and immediate direction and oversight for Palisades activities, the Vice President of NOD, Mr. Fenech, is located at the Palisades site. Similarly, the offices of the Palisades Plant General Manager and other line managers will be relocated inside the protected area in order to enable the managers to maintain closer contact with their personnel. Additionally, Palisades has established a Management Observation Program, in which managers regularly evaluate personnel performance in the field against checklists of critical attributes and then meet once per month to collectively review the results of their observations and ensure consistency in reviews and determine the need for change.
CPCo has also established a Nuclear Management and Safety Review Committee (MSRC), which held its first meeting in March of this year. The mission of the MSRC is to advise CPCo management up to the President and CEO on the progress of actions to successfully achieve and maintain an effective safety culture and performance excellence. The Committee not only includes Messrs. Joos and Fenech and the Director of the Nuclear Performance Assessment Department, but also a number of experienced non-CPCo employees in order to provide more diversity and an outside perspective on the performance of Palisades. The MSRC includes William Conway (who, as Executive Vice President for Arizona Public Service, has been in charge of the Palo Verde nuclear pl~nt for the last five years) and James Partlow (who recently retired as the Associate Director for Projects in NRC's Office of Nuclear Reactor Regulation). Within the MSRC, subcommittees have been established which focus on operations, maintenance, engineering, plant support, and self-assessments.
3 2.1.3 Improvements-in Management Information Systems, Expectations and.
Standarm, and Communications This year, Mr. Morris and Mr. Joos have each held meetings with plant personnel st~ing the need to place quality over schedule, to recognize that there are matters that need to be corrected, and for employees to dedicate themselves to improving. Similarly, since being appointed as Vice President of NOD, Mr. Fenech has held a number of all-employee meetings at Palisades and Big Rock Point and with the general office staff (in Jackson, Michigan) in order to communicate his standards and expectations to NOD employees. These meetings have stressed the fundamental principles of placing quality over cost and schedule, instilling a questioning attitude in all personnel, and open communications and interactions between all levels of the organizations and between the different groups within the organization. Additionally, departmental meetings have been established to improve communication of expectations and standards on a continuing basis.
CPCo has also initiated a number of actions to improve the senior management information systems. For example, CPCo is establishing a new management information system, in which performance indicators and data on various plant backlogs can be accessed. Additionally, information on the backlogs of the various plant activities are being captured and prioritized on one list, and the backlogs will be reviewed at least monthly by management to identify and remedy adverse trends.
Initiatives in this area are ongoing and have been integrated into the PPEP.
Fmally, several actions have been taken to improve internal communications. For example, the Palisades daily morning meeting structure has been changed to require department managers to make presentations in a more formal structure. Additionally, information from each department is captured and is available to employees for review.
Pre-job briermg checklists have also been established to improve directions to personnel prior to beginning a task.
2.1.4 Operations Department Improvements Substantial changes have recently been made in the Palisades Operations Department.
In order to focus the Operations Department on plant operations, the outage planning and scheduling function was separated from the Operations Department. An additional senior reactor operator (SRO) has been added to the on-shift control room staff in order
. ~o enable the Shift Supervisor to spend more time in the plant focussing on plant-wide activities and personnel affecting operation. The duties of the Shift Engineer have also been adjusted to enable the Shift Engineer to perform more of an oversight role.
Additional staff has also been added to the Operations Department to support procedure development and revisions, to perform self-assessments, and to improve the interfaces with other departments.
4 To improve the skills of managers and supervisors in the Operations Department, CPCo will provide customized individual supervisory and management skills development training. This training seeks to improve the skills of managers and supervisors in communicating standards and expectations; monitoring, evaluating, and providing feedback on personnel performance; and interpersonal relationships.
A major effort has been directed towards developing a cohesive management team within the Operations Department. An outside management consultant has been working with the shift supervisor, support staff section heads, and the department manager ~o develop a consistent and appropriate.set of expectations for the entire department. This effort is continuing and has already resulted in establishing many new standards for the organization.
2.2 Enhancements in Desi2n and Plant Condition 2.2.1 Improvements in Design Basis Documentation CPCo has been implementing an extensive design basis reconstitution program for a number of years. As part of the design basis reconstitution program, CPCo. also performed a safety system design confirmation (SSDC) vertical slice verification using the design basis documents to provide assurance that operation procedures, testing procedures, maintenance procedures, and training are consistent with the design basis.
As a result of NRC inspections and its own assessments, CPCo determined that some of the discrepancies identified by the SSDC had not been corrected in a timely manner.
CPCo has recently completed a review of all SSDC discrepancies, including those for which corrective actions had been taken, to verify that appropriate actions have been taken or are scheduled to be taken for these discrepancies. Additionally, as part of the PPEP, CPCo will be setting new standards for design basis documents (DBDs) and will be conducting reviews to conform existing DBDs with the new standards.
Additionally, CPCo has established a design basis integration effort. This effort includes the designation of specific groups within Nuclear Engineering and Construction Department (NECO) with responsibility for the ownership of the design basis for plant systems, and designating the owners as being responsible for the adequacy of design documents for their systems. Additionally, training will be provided to these owners on the design basis. This effort has been encompassed within the PPEP.
2.2.2 Improvements -in Controls of Modifications*
CPCo has taken several steps to improve the modification process. For example, more stringent standards have been established for technical reviews of engineering work.
Additionally, CPCo has established requirements for multi-disciplinary reviews of the design and quality verification plans for modifications which affect plant safety.
5 Fmally, CPCo has-raised the level of approval authority for modifications and now requires an engineering manager to approve modifications.
CPCo has taken several steps recently to prevent the maintenance process from introducing uncontrolled modifications. In this regard, the scope of activities requiring a modification package has been expanded, and the need for modification packages has been repeatedly stressed in meetings among maintenance personnel. Reviews are also being performed of completed work orders to identify any uncontrolled design changes.
2.2.3 Other Design and Engineering Improvements CPCo has initiated other improvements to its design and engineering programs.
Expectations of engineers regarding quality and ownership of engineering work are being clarified by development of more stringent standards for technical review of engineering work. The roles and responsibilities of the engineering groups are also being clarified. Additionally, managers have reinforced with their personnel the need to place quality over schedule considerations.
2.2.4 Enhancements in Hardware During the current outage, CPCo has taken a number of actions to verify the adequacy or improve the condition of hardware, including the completion of Qver 600 work orders. These actions include a modification and testing to enhance the reliability of the water supply to the Auxiliary Feedwater System, testing of the fuel consumption of the emergency diesel generators to ensure that their operation has not been degraded, walkdowns to ensure that permanent and transient plant equipment is appropriately restrained to prevent them from impacting safety systems, walk downs to evaluate the potential for items becoming dislodged and clogging the containment sump, and vWalkdowns to check plant structures and correct any degraded conditions (especially in small diameter piping and instrument tubing supports). Some of these hardware improvements were an outgrowth of observations by the DET.
CPCo has also taken steps to increase the design margin of plant structures, systems, and components. For example, a Service Water System design margin improvement program was established to identify ways and develop plans to improve operational and
- safety-margins. CPCo will also be addressing the design margins in the Emergency Diesel Generator Fuel Oil System.
CPCo has also embarked on a long term program to improve its office facilities at Palisades.. This program should result in an improved Technical Support Center layout in addition to improved worker productivity.
CPCo has initiated a temporary modification backlog reduction program. Additionally, the existing temporary modifications have been reviewed by Operations to confirm that
6 they do not-pose an undue burden to operations., The definition of control room deficiency has also been expanded to include equipment with an outstanding work request.
2.3 Enhancements in Pro2rams 2.3.1 Improvements in Self-~ents CPCo has taken several steps to enhance the overall effectiveness of the self-assessment function. First and foremost, the new senior management team has repeatedly stressed in employee meetings the need for a strong self-checking function. In particular, management has emphasized the following:
o Each individual must do the job right the first time. This responsibility includes the need to perform self-checking.
o Each individual must have a questioning attitude and communicate to supervision and management their concerns as they arise.
o Supervision and management must be in the field to observe work and personnel performance, and to establish two-way communications with employees on expectations, standards, barriers to improved performance, and problems being encountered by employees.
The Plant General Manager has issued a memorandum stressing that it is-the responsibility of all personnel to perform self-checking and that certain areas warrant heightened sensitivity, including safety tags, valve operations, maintenance work, and documentation and validation of engineering activities.
Second, CPCo has stressed the need for departments to self-assess their own work. In this regard, the Operations Department and NECO have or will be assigning individuals within their departments to perform self-assessments of department activities, and some of the other departments have previously done so.
Third, NPAD's role has been modified by deleting its function as a facilitator of solutions to problems and limiting NP AD's role to critical, intrusive oversight, assessment,.and trending of performance at Palisades. Additionally, the capability of the NPAD continues to be strengthened through the addition of personnel who have recent line experience, both from inside and outside of CPCo. Finally, NPAD's assessments have been strengthened through the performance of more intrusive reviews of the technical adequacy of design and engineering activities.
.f*
7 Finally, as* discussed above, CPCo has establish a Management and Safety Review Committee with experienced non-CPCo personnel to provide more diverse observations or performance.
2.3.2 Improvements in the CoITedive Action Program The Corrective Action Process has been substantially upgraded in several respects.
Fll'St, on May 7, 1994, the scope of reportable conditions was expanded in order to capture nonconsequential events. Second, a new screening group, called the Condition Review Group (CRG), has been established to identify those conditions which are significant and need plant management attention and detailed root cause analysis.
Third, completed root cause evaluations are being reviewed by a Management Review Board (MRB), which is chaired by the department manager responsible for the root cause evaluation. For events that are reportable to NRC or other significant events, the
- MRB is chaired by the_ Plant General Manager. Fourth, the Corrective Action Review Board function was improved through more structured meetings and formal presentations by individuals responsible for the corrective action. Finally, CPCo identified the need for further revisions in the Corrective Action Process to improve root cause evaluations and analysis of trend data. In this regard, CPCo has contracted with Failure Prevention, Inc. (FPI) to perform an assessment of NPAD and the root cause evaluation process at Palisades. Actions to accomplish improvements in these areas have been incorporated in the PPEP.
2.3.3 Improvements in Operability Detenninatiom Palisad~ has made several improvements in the process for making operability determinations. The Shift Supervisor has been explicitly defined as the person responsible for making operability determinations.. The new process also requires more timely operability determinations and better documentation of operability determinations, including discussion of specific factors affecting operability. Finally, training is being provided to staff personnel regarding the types of information needed in corrective action documentation in order to assist the Shift Supervisor in making operability determinations.
2.3.4 Improvements in Procedure Development and Adherence In 1993, CPCo revised its procedure development and revision process to streamline the process for issuance of procedures and t.o improve the quality and adequacy of procedures. For example, CPCo has established a method to issue urgent procedure changes and revisions. CPCo has also assigned sponsors to prepare and maintain procedures, and made them responsible for the quality and adequacy of the procedures.
Additionally, reviews are performed to ensure technical correctness and continued fulfillment of the procedure purpose each time a procedure is revised or changed.
8 Currently, CPCo is automating the procedure process, and is making procedures available for on-line review at computer terminals.
An administrative procedure is also being developed to specify requirements on procedure adherence. This procedure will incorporate management's expectations and standards of conduct on procedure adherence. In particular, the procedure will state that failure to comply with procedures or the failure to correct deficient procedures will not be tolerated, and that work must be stopped and the supervisor informed when a procedure cannot be performed as written. The procedure will also specify controls governing emergency situations in which deviations from procedural provisions are necessary in order to protect safety, personnel, or equipment.
2.3.5 Industry Experience CPCo has taken a number of actions to increase its awareness of changes in industry standards and.. events at other plants. For example, CPCo is loaning a maintenance superintendent to INPO, and continues to send personnel to other plants to participate in peer reviews. Conversely, CPCo also requests peer reviews of Palisades by personnel from other plants. As discussed above, CPCo has also filled the position of Vice President of NOD with an experienced nuclear executive, is actively seeking to fill several key plant management with personnel from outside of CPCo, and has established a Management Safety and Review Committee which includes experienced non-CPCo personnel.
2.4 Reviews and Evaluations In addition to the enhancements discussed above, a management review group (including frequent participation by the Vice President of NOD) is performing a number of reviews and evaluations to help ensure the adequacy of the existing designs, hardware, and programs at Palisades, to identify whether further enhancements should be implemented, and to communicate new standards and expectations. Some of these reviews and evaluations are being conducted as part of the restart plan for the current outage for Palisades, and others are being conducted in response to the DET. These reviews and evaluations are discussed below.
o Reviews of Systems - Reviews have been conducted of fourteen safety systems by system engineering to evaluate the individual _and cumulative effect of outstanding issues related to the system operability. The review activity included walkdowns of the systems by assigned system engineers and reviews of outstanding work orders, temporary modifications, long range operator concerns, design basis issues and safety system design confirmation discrepancies (SSDCs), planned modifications, industry issues, DET observations, and corrective action documents.
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Reviews of Departments - Reviews have been conducted of various departments at Palisades to confirm their adequacy to support continued operation of Palisades. These included reviews of the definition of the roles and responsibilities of the department, processes implemented by the departments, department resources, and the processes for monitoring the performance of the departments.
Reviews of Promms - Reviews have been conducted to determine the cumulative effect on plant safety of issues identified by the implementation of various programs. For example, reviews were conducted of issues identified by the fire protection program, the erosion/corrosion program, the inservice inspection and testing program, the environmental and seismic qualification programs, station blackout program, safety-related piping reverification program, Palisades Periodic Activity Control (PPAC) program, and the programs for motor operated valves, check valves, relief valves and air operated valves. The review considered design basis issues and SSDCs, planned modifications, industry issues, DET observations, and corrective action documents.
Review~ of Corrective Action Documents and Work Orders - Reviews have been conducted by multi-discipline teams of open deviation reports and event reports initiated prior to establishment of the current operability determination process, open work orders, SSDCs and open design basis issues in order to.
identify issues that warrant immediate resolution. These reviews included consideration of the impact of issues across system boundaries.
The focus.of these reviews is to identify critical needs to be addressed in the near term.
These short term actions are identified, tracked, subject to daily meetings, and are being implemented. To help complete these actions, additional resources (personnel and budget) are being committed.
Additionally, CPCo is performing a root cause analysis of the observations of the DET as they are being issued. These analyses look at more systems and programs than are the subject of the DET observation itself, and investigate the issue in detail. CPCo views the DET observations as an opportunity to focus and stimulate its ongoing improvement efforts. In this regard, CPCo has added several long term objectives to the PPEP, and further changes may be warranted after the DET Report is issued.
3.0 PALISADES PERFORMANCE ENHANCEMENT PROGRAM CPPEP)
The actions discussed in Section 2 above were initiated in late 1993 and early 1994, and many of these actions are still in progress or have just begun. Although these actions address essentially every area of performance at Palisades, CPCo's new management
10 desired to ensure that all matters warranting improvement are in fact being addressed.,,,
Management also wanted to ensure that the improvements are being integrated, planned, and managed such that improved performance is achieved and sustained. To accomplish these goals, CPCo established the PPEP.
The rirst step in creating the PPEP was to evaluate both internal and external issues to identify areas warranting improvement. The internal issues were identified based upon interviews of personnel and a review of plant documentation, and external issues were identified based upon a review of recent significant INPO and NRC reports, such as notices of civil penalties and the Systematic Assessment of Licensee Performance (SALP)
Report for Palisades. Through a participative team process, workshops, and management reviews, a list of six general Focus Areas and Goals were identified in the areas of Leadership and Management, Programmatic Improvement, Human Performance, Culture, Critical Assessment, and Plant Condition. Furthermore, for each Focus *Area and Goal, a number of Objectives were identified. These Focus Areas, Goals, and Objectives are listed in the attached table and are summarized below:
o Leadership and Mana2ement - Actions will be taken to establish the strategic direction, establish clear roles and responsibilities, establish aligned management expectations and goals, establish a management development program, define management information needs, enhance control of contractors. and non,.NOD personnel, enhance communications, and enhance community involvement.
o Pro2rammatic Improvement - Actions will be taken to prioritize all existing work, establish an improved planning and prioritization process, improve the corrective action process, implement an enhanced modification process, establish a management information system, enhance the operability determination process, establish a root cause program, and enhance the effectiveness of the preventive maintenance program.
o Human Perf onnance.. Actions will be taken to enhance employee knowledge and skills and to improve site facilities.
o Culture - Actions will be taken to communicate the NOD nuclear safety philosophy, establish a strong sensitivity to the plant's design basis, establish a strong sense of teamwork, and enhance job satisfaction.
o Critical Assessment - Actions will be taken to establish critical self-assessl:nenf as a norm for line organizations, enhance the quality of NPAD assessments, and improve the effectiveness of the assessment functions.
o Plant Condition - Actions will be taken to establish a program to improve the plant design margin and to enhance the quality of design basis documentation.
11 As is apparent, these Objectives encompass and correspond to many of the enhancements that were initiated in late 1993 and early 1994. To the extent that these enhancements have not yet been completed, they are being incorporated into PPEP. In total, the PPEP Objectives identify a comprehensive and integrated set of areas where action will be taken in order to reach and sustain a high level of performance.
The second step was to develop an Action Plan to achieve each Objective. Each Action Plan identifies a number of actions for accomplishing its objective. A responsible individual, priority, resource loading, and due dates are identified for accomplishing each action. The Actions Plans were reviewed to ensure that they represented a manageable set of actions, and that the actions were properly prioritized and sequenced.
To ensure that its Goals and Objectives are achieved, PPEP incorporates a number of management controls. As discussed ~hove, each Action Plan identifies responsible individuals and due dates to provide accountability for timely completion of the Action.
Plan. PPEP contains provisions for reporting and trending of progress in implementing the Action Plans, and for modifying the Action Plans based upon experience.
Additionally, the Action Plans identify verification and validation activities to ensure that the actions have been properly completed and performance indicators to help in determining whether the Action Plans have been successful in ~ccomplishing their Objectives. These controls provide a high level of assurance that PPEP will be successfully implemented and effective in achieving lasting improvement.
CPCo is still in the process of finalizing the PPEP and its associated Action Plans. After finalization, CPCo will provide the NRC with a copy of the PPEP, which includes summaries of the Action Plans, and examples of the Action Plans. It is envisioned that this information will be provided in conjunction with CPCo's response to the DET Report. The current versions of the Action Plans will be available for NRC review at Palisades.
As it currently stands, PPEP is intended to be implemented over the next six to twelve months. However, PPEP is also intended to be a living document. As a result, it will be revised to reflect completion of various Action Plans, to incorporate additional actions for those Goals or Objectives that may not be fully accomplished, and to address newly arising issues.
~ particular_,. PPEP will be revised to reflect the results of the DET inspection. The PPEP was initiated prior to the beginning of the DET inspection, and therefore may not yet directly address all of the DET's findings. Given the comprehensive evaluations that were undertaken in developing the Focus Areas, Goals, and Objectives for PPEP, CPCo believes that most if not all of the DET findings with generic or programmatic implications are being addressed by PPEP or other corrective actions. CPCo has been evaluating and performing root cause analyses of the Diagnostic Evaluation Observations (DEO) as they have been issued, and has already expanded the PPEP to
12 ad~ several issues identified by the DET. To conflrm that the DET findings are being appropriately addressed, CPCo will evaluate the DET Report after it is issued and will provide the NRC with a matrix identifying whether each DET finding with generic or programmatic implications is being ad~ed by PPEP or other corrective actions.
As warranted, the PPEP will be expanded to address DET f mdings in areas that are not currently the subject of PPEP Actions Plans. Additionally, PPEP will be integrated with the strategic directions in the NOD and Palisades Business Plans, which are updated annually.
4.0 CONCLUSION
S In mid to late 1993, CPCo identified a decline in performance at Palisades and in early 1994 initiated a number of actions to enhance its performance. In particular, CPCo has established a new management team for Palisades, increased management direction and oversight of plant activities, and communicated new management standards and expectations. CPCo is also making improvements in design basis information, the control of modifications, and plant hardware. Furthermore, CPCo has made a number of improvements to its self-assessment program, corrective action process, and operability determinations. Finally, CPCo has performed reviews and evaluations of plant systems, programs, and departments to confirm their adequacy for continued safe operation.
In order to ensure that its actions addressed all areas warranting improvement, and to provide for an integrated program for achieving improvement, CPCo established the Palisades Performance Enhancement Plan. The PPEP incorporates mechanisms (such as identification of responsible individuals, due dates, verification and validation, and performance indicators) to ensure that the enhancements will be implemented in a timely manner and that the actions will be effective in achieving and sustaining improved performance. The PPEP is a living document, and CPCo has been evaluating and will continue to evaluate the findings of the NRC's Diagnostic Evaluation Team to determine whether the PPEP should be expanded. CPCo will inform the NRC of the results of these evaluations as part of its response to the DET Report.
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PERFORMANCE ENHANCEMENT PLAN FOCUS AREAS, GOALS AND OBJECTIVES* April 18, 1994 FOCUS AREA LEADERSHIP AND MANAGEMENT NOD Management has not successti.Jlly translated and communicated the NOD/Palisades Vision down through the organization. Management has rioi cl~rly established appropriate and consistent standards and expectations. Roles, and responsibilities arc not aligned and dearly.
established or communicated.
NOD in general and Palisades specifically are not
.. learning.. organizations and do not solicit or welcome outside criticism or perspeL*tives. A contributing cause includes lack of appropriate skills and experience.
GOAL Management provides a dear vision and sets direction throughout NOD for sustained Palisades Plant performance improvement.
Expectations and roles and responsibilities are clearly communicated and foster an atmosphere where functional alignment, individual accountability, and organizational understanding are achieved and performance goals are met. Management knowledge and skills an:
state-of-the-art and the community and regulator fully value Palisades performance.
OBJECTIVES I.I Establish Strategic Direction Establish the vision, values. and strategic focus for the organizations that perform work in support of Palisades so that they are aligned and consistent with the corporation's vision, values. and strategy.
[Input from Objective 4.1 I 1.2 Establish Clear Roles and Responsibilities Clearly establish the roles and responsibilities for those individuals performing work in support of the Palisades Nuclear Plant. Align the organizational roles and responsibilities and adjust the organizational structure, if necessary, to clarify understanding and improve performance. Communicate the roles and responsibilities and monitor employee understanding.
1.3 Establish Aligned Management Expectations and Standards Clearly establish in a standard format NOD Management's expectations and standards for organizations that perform work in support of Palisades. Communicate these expectations and standards with periodic re-emphasis and monitoring of employee understanding.
Ensure that safety is first over cost and schedule and that this principle is established, understood. and practiced.
1.4 Establish a Management Development Program Establish a leadership and management development program for personnel in positions of authority. from first line supervisors to the department managers.
Include an initial assessment of the incumbent *s skills and abilities, a tailored management skills improvement program, a standardized leadership and management development program, and a formalized set of performance. expectations for each managerial position.
Succession/rotation and hiring plans should be established that are consistent with corporate strategy and that have the capability to recognize the need to augment existing organizations with outside resourc.:s at a// levels.
1.5 Deline Management Information Needs Establish a common set of performance indicators to support effective performance monitoring. Determine the informatiol) needs necessary to monitor performance and to track and trend actions, events, and issues affecting plant performance from the worker level through the executive level.
[This Objective supports Objective 2.5)
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PERFORMANCE ENHANCEMENT l'LAN FOCUS AREAS, GOALS AND OBJECTIVES - April 18, 1994 FOCUS AREA GOAL OBJECTIVES 1.6 Enhance Control of Contractors & Non-NOD CP Organizations Enhance CPCo control of the quality of work perfonned in support of Palisades by outside contractors and non-NOD CPCo organizations (i.e.. work by personnel outside
- NOD). Clearly establish and communicate expectations for the control of work perfonned hy outside persons for both the NOD personnel overseeing the outside work and for the outside employees themselves. Develop training guidelines to ensure contractors and others receive orientation and training. as applicable to the specific work being perfonned, on Palisades* policies. procedures, and practices important for performing. error-free, I
4uality work.
1.7 Enhance Communications with Stakeholders Establish plans for stakeholder communications. In particular, establish a Regulatory Communications Plan that supports dear interactions with regulatory organizations to ensure that they fully value the performance of Palisades.
1.8 Enhance Community I nvolvenlt'nt Establish a Community relations program that ensures that Palisades' employees are actively engaged in and supporting the surrounding communities. Communicate with nrganizatio_ns within the surrounding communities to ensure that Palisades' role in the community is fully valued.
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PERFORMANCE ENllANCEMENT PLAN FOCUS AREAS, GOALS AND OBJECTIVES - April 18, 1994 FOCUS AREA PROGRAMMATIC IMPROVEMENT Certain processes are not effective in achieving desired results.. The process concerns range from ineffectiveness through implementation difficulties as follows:
I. NOD lacks an integrated cohesive process for the functions. of strategic planning, issue management. resource allocation, scheduling. completion of
- work. doseout. and performance monitoring. Emerging issues are not handled well; and
'.!. The Corrective Action Program is not well utilized and needs to he improved; root and common cause analysis is not consistently used as part of the corrective action process: and
- 3. The Modification process is not user-friendly and is too complex: and
- 4. Information systems arc not effective in supporting the monitoring and trending of performance indicators: and
- 5. The effectiveness of the process used to make operability determinations and communicate potential issues is weak and not effectively implemented: and GOAL Processes are clear, user-friendly, and achieve desired results throughout the organization.
The processes feed into an overall formal planning and prioritization process that integrates strategic planning. budgeting.
and scheduling to effe<:tively utilize plant resources.
Management has easy access to the information necessary to monitor plant performance.
OBJECTIVES 2.1 Determine Scope of Work Identify all existing issues, actions, and projects above a specified resource threshold.
Prioritize and rank these items. Develop and implement a manageable subset of these activities to be included in the current scope of work. Important activities that do not attain a high enough priority will be considered for future years' work;* activities below a specified priority will he abandoned.
[This Objectiv.: supports '.!.:!I 2.2 Establish an Improved Planning and Prioritization Process Deline and establish an NOD Integrated Planning Process (IPP) that uses the best practices of other business units within _CMS Energy and other utilities for the management of work performed at or in support of the Palisades Nuclear Plant. The purpose of establishing the IPP is to effectively manage resources in accordance with business plan 11bjectivt:s and station performance goals. The IPP must evaluate, prioritize.
plan, and link issues 10 station performance and available resources to reach effective and efficient issue closure.
[Input from Objective 2.1 J Page 3 of 7
l'ElffOKMANCE ENHANCEMENT PLAN FOCUS AREAS, GOALS AND OBJECTIVES - April 18, 1994 FOCUS AREA GOAL OBJECTIVES 2.3 Improve Corrective Action Process Improve the Palisades Com::ctive Action Process to make it more effective in identifying, trending, and monitoring corrective actions. Lower the threshold for including events in the corrective action program so that non-consequential events are captured, analyzed, and trended. Provide clear critcria for performing human performance evaluations and root cause analyses. Providc explicit guidelines on the timeliness of corrective action implementation and for verifying the effectiveness of actions taken to prevent recurrence.
2.4 Implement an Enhanced Modification Process Implement the plant modilication process improvement program. By employing user feedback. adjust the process to address concerns and thereby enhance overall usefulness and acceptance.
2.5 Est;iblish a Management Information System Develop and implemcnl a managcmcnt information system to provide management the capability 10 monitor and fccdhack information appropriate to each management level.
Develop and implement tracking and trending mechanisms that provide look-ahead information. cxception reporting, and adverse trend data for problems, actions, events, and other issues affecting the plant's performance. A consolidated Action Tracking and graded management reporting function should be a key part of this system.
llnput from Objective 1.51 2.6 Enhance I.he Operability Determination Process Enhance the Operability Determination Process to ensure it is clearly delined so that safety issues are promptly and aggressively evaluated and appropriate individuals are aware of potential operability issues as they arise. Perform a performance and compliance hast:d focused review that n::sults in specific procedure revisions and associated training for applicable Palisades Technical Staff.
llnput from Objectives 5.1. 5.2. 5.3. 6.1, 6.2]
- 2. 7 Establish a Root/Common Cause Process Using the HPES Program as a Basis Develop a Root/Common Cause program, including resources necessary for effective implementation. Provide dear criteria.for performing human performance evaluations and Root/Common Cause analyses. Enhance the overall effectiveness of the Palisades HPES program to reduce the number of recurring human performance events. Evaluate the existing resources lo ensure effective implementation, formality of process and methodology.
llnput from Objectives 2.3. 5.31 Page 4 of 7
PERFORMANCE ENHANCEMENT PLAN FOCUS AREAS, GOALS AND OBJECTIVES - April 18, 1994 FOCUS AREA HUMAN PERFORMANCE There is no overall plan (such that called for in SOER 92-0 I J to address human performance issues. Facilities are not adequate to support the quality of work expect_ed and are an impediment to, job performance.
CULTURE Palisades has not established and nurture<l a strong nuclear safety l'Ulture that encourages a ques_tioning attitude, welcomes critical self assessment, values raising problems. is sensitive to stringent protection of the <lesign basis. stresses procedural compliance, and makes conse.rvative decisions without undue impact from cost and schedule considerations. The culture does not encourage, recognize, or reward teamwork in the day-10-day work place nor does it support an appropriately high level of job satisfaction and quality of work life.
GOAL All employees are committed to maximizing performance and meeting expectation. All NOD employees have appropriate facilities, tools, an<l processes to maximize performance and meet expectations.
An environment exists where all NOD employees know and demonstrate that safety
- (nuclear. personnel, and radiological) is paramount. is everyone's responsibility, and that teamwork and job satisfaction are necessary for achieving superior performance.
OBJECTIVES
.3.1 Enhance Employee Knowledge and Skills Improve the professionalism, leadership, work management, and technical training to provide our employees the skills necessary to maximize performance and meet expectations.
.3.2 I mp rove Site Facilities Implement the approved Site Facilities Program to include the major Service Building addition. major renovations to existing facilities, and the major Support Building addition.
Objectives I.:!, 1.3, 1.4, 4.1, 4.2, 4.3, 4.4 also address human performance related issues 4.1 Define and Communicate the NOD Nuclear Safety Philosophy Establish and nurture a strong nuclear safety culture by providing clear standards and expectations that nuclear safoty and quality is a preeminent value al Palisades. This includes a strong sense of professionalism, a questioning attitude, critical self-assessment down 10 the worker level (self-checking), the need for continuous improvement, the need for procedure compliance. and a welcoming and accepting attitude toward outside support.
Recognize and reward conservative actions and decisions. Develop and promulgate a nuclear safety philosophy statement that will provide visible reenforcement of these expectations and standards.
[This Objective supports I. I]
4.2 Establish a Strong St>nsitivity to tht' Plant's Design Basis Establish clear ownership and responsibility for maintenance of the plant design basis documentation. Increase management and employee awareness and understanding of the plant's design and licensing bases, Technical Specifications, reportability and operability requirements, and quality assurance requirements. Clearly establish and communicate the design authority for the plant. Instill a greater sense of importance for configuration control lo ensure the integrity of the Palisades' Design Basis.
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PERFORMANCE ENHANCEMENT PLAN FOCUS AREAS, GOALS ANO OBJECTIVES - April 18, 1994 FOCUS AREA GOAL
. CRITICAL ASSESSMENT Self-and independent assessments arc used as There is a lack of critical self-assessment performance improvement at Palisades. Management is not visihlc in tools and to anticipate and the plant monitoring and *ovcrviewing avoid significant prohkms.
plant activities. Supervisors do not spend enough time supervising activities at work sites.. The independent assessment function has not identified significant programmatic and technil*al issues and has b.:en ineffective in escalating findings to obtain r.:solution from Senior/Executive Management.
OBJECTIVES 4.3 Establish a Strong Sense of Teamwork Develop and enhance teamwork skills. Establish management expectations and provide positive reenforcement (recognition and rewards) to create an environment in which NOD einployees can and do effectively utilize teamwork in accomplishing their daily work.
Ensure that union relationships are an important and integral part of the teamwork culture.
4.4 Enhance Joh Satisfaction Establish and implement a program that will improve job satisfaction within the Palisades site. This should include recognition for jobs well done and the identification of key opportunities for improvement. Encourage frequent communication and feedback leading to a greater sense of importance.
5.1 Establish Critical Self-Assessment as a Norm for Line Organizations The independent assessment function has not identified significant programmatic and technical issues and has been inefkctive in escalating findings to obtain resolution.
Integrate supervis1>ry and management oversight activities, peer group inspection activities, multi-disciplinary review team efforts, and other assessment activities by personnel and organizations pi:rforming work for or at the plant in order to fully establish an environment that encourages undiluted input and feedback. Improve the self-assessment effectiveness of organizations and communicate self~assessment expectations (i.e.; questioning attitude, self-critical nature, zero rework, timeliness of corrective action.
root cause analysis) al the NOD, Palisades, and department levels. Provide training in self~assessment. human performance evaluation and root cause analysis techniques. Input should be obtained from outside organizations, including evaluating and benchmarking high-performing organizations.
5.2 Enhance the Quality of NPAll Assessments Enhanc.e the t.:chnical and assessment skills of NPAD personnel. Seek development and training opportunities through assignments with outside organizations. Obtain critical feedback frrim assessed organizations. Ensure that assessments are focused on true performance issues hy benchmarking against industry leaders.
5.3 Improve the Effl'Ct.iveness of the Assessment Function Deline, clarify. and strengthen the role of NPAD. Adopt the "'Four Levels of Defense of Quality"' model as an aid ih understanding and communicating the role of independent assessment in testing and probing the programmatic aspects of the organization. Integrate the NPAD activities with the new Managell)ent and Safety Review Committee Charter, as applicable. Strengthen the approach for resolving NPAD issues.
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PERFORMANt:E ENHANt:EMENT t*LAN FOCUS AREAS, GOALS ANO OBJECTIVES - April 18, 1994 FOCUS AREA GOAL OBJECTIVES PLANT CONDITION 6.1 Establish a Program to Improve Plant Design Margin Plant syslems and components Identify, prioritize and schedule material condition issues, design margin issues, and long-There arc material condition. equipment arc in conformance with lhe standing equipment problems thal create operator workarounds or accessibility problems.
prohlems, and technical issues that design basis, maintained in Ensure that input is received Ii-om all levels of the organization.
continue to occur in the plant as ii good working order. readily matures. Issues need to be addressed to and safely accessible. and continue to identify, maintain and improve operator workarounds arc al a 6.2 Enhanct' the Qualit)' of l>t'Sign Basis Documentation 1he j1lant material condition.
minimum.
Complete the development of a retrievable set of design basis documentation for all safety-I related and selected non-safely-related structures, systems, and components at Palisades.
This documentation must include the principal design criteria, which establish the neces~ary design, fabrication, construction, testing, and performance requirements for structures,1systems. and t*omponcnts that provide reasonable assurance that the facility can be operated without undue risk tn the health and safety of the public. Put in place the necessary controls to assure that the design basis documentation meets expectations with regard to quality and completeness and is kept current.
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