ML20058E360
| ML20058E360 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/30/1982 |
| From: | MANAGEMENT ANALYSIS CO. |
| To: | |
| References | |
| MAC-82-U009, MAC-82-U9, NUDOCS 8207280165 | |
| Download: ML20058E360 (154) | |
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I A MANAGEMENT DIAGNOSTIC T1E NUCLEAR ORGANIZATION I
Prepared for:
BOSTON EDISON COMPANY 800 Boylston Street Boston, Massachusetts 02199 June 30,1982 I
Management Analysis Company Project Number: MAC-82-UOO9 I
Boston Edison Company Purchase Order Number: 69693 I
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TABLE OF CONTENTS Section Pm 1.0 INTR O DUCTIO N.............................................
1-1 2.0 S UM M A R Y..................................................
2-1 3.0 O RG ANIZ ATION.............................................
3-1 3.1 Conclusions 3-1 3.2 Rec o m men da tions......................................
3-7 4.0 M ANAGEMENT CONTROLS...................................
4-1 4.1 Conclusions 4-1 4.2 R e c o mme ndatio ns......................................
4-1 5.0 STAFFING LEVELS AND CAPABILITIES 5-1 5.1 Conclusions 5-1 5.2 Recommenda tio ns......................................
5-2 6.0 TR AINING AND RETRAINING.................................
6-1 6.1 Conclusions 6-1 6.2 R ec omme n dations......................................
6-1 7.0 INTRA-AND INTER-DEPARTMENTAL COMMUNICATION 7-1 7.1 Conclusions 7-1 7.2 Re c o mmend a tio ns......................................
7-1 8.0 COMMITMENT CONTROLS 8-1 8.1 Conclusions 8-1 8.2 R ec o mm e n dat io n s......................................
8-1 9.0 STATION OPERATIONS 9-1 9.2 Conclusions 9-1 9.2 Re c o m me n d a t io n s......................................
9-1 10.0 ENGINEERING.............................................
10-1 10.1 Nuclear Engineering...................................
10-1 10.1.1 Conclusions...................................
10-1 10.1.2 Reco m mendations............................... 10-2 I
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TABLE OF CONTENTS (Continued)
Section h
10.2 Configuration Management 10-2 10.2.1 Conclusions 10-2 I
10.2.2 Rec o mmend atio ns...............................
10-4 10.3 Plant Design Change Requests 10-4 10.3.1 Conclusions 10-4 10.3.2 Recomme ndations...............................
10-5 10.4 Q-List 10-5 10.4.1 Conclusions 10-5 10.4.2 Re c o mmen da tio ns...............................
10-6 u.0 o UAL ITv ASSURA~CE.......................................
11-1 11.1 Conclusions 11-1 11.2 Recomme nda tions......................................
11-2 12.0 NUCLE AR OPERATIONS SUPPORT............................
12-1 12.1 Project Management 12-1 12.1.1 Conclusions 12-1 12.1.2 Recommendations...............................
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12.2 Licensing 12-2 12.2.1 Conclusions 12-2 12.2.2 Recommendations...............................
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12.3 Information Resource Management 12-2 12.3.1 Conclusions 12-2 12.3.2 Recomme ndations...............................
12-3 13.0 SAFETY EVALUATIONS 13-1 13.1 Conc!usions 13-1 13.2 Re c o mm end a tio ns......................................
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14.0 ORGANIZATIONAL FREEDOM IN PROBLEM IDENTIFICATION AND RESOLUTION 14-1 14.1 Conclusions 14-1 14.2 R eco mme n da tions......................................
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Appendices l
A Comparison of Issues A-1 B
MAC Personnel B-1 C
BECo Personnel Interviewees C-1 j
D Causes of Management Dysfunction and 5
Recommended Action D-1 E
Action Plan E-1 I
I Figures 1
3-3 2
3-4 3
3-5 4
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LO INTRODUCTION Boston Edison Company (BECo) was directed by the Nuclear Regulatory I
Commission (NRC) to have an independent evaluation of current organizational responsibilities, management controls, staffing levels and competence, training and retraining programs, communications, and operating practices as they relate to nuclear activities both at Pilgrim Nuclear Power Station (PtPS-1) and the corporate office.
Management Analysis Company (MAC) was employed by BECo to perform this function. It must be recognized that this evaluation was performed in the midst of a transition process already begun by BECo to identify and correct many of the conditions reported herein.
MAC utilized the diagnostic process as a means of identifying areas of dysfunction and of developing action plans for the client aimed at enhancing performance of the company relative to its nuclear organizations and projects.
The management diagnostic is a planned effort directed at understanding the many aspects of the client's Nuclear Organization.
The process utilizes observation, interviews, surveys and document and procedure review. An experienced MAC team analyzes the information gathered in this process to develop specific recommendations which are then translated into an action plan with direct client involvement.
The team consisted of seven professionals with a combined experience of over I
180 years in management of highly complex, technical operations, with 146 of those years devoted to the nuclear industry including operations, engineering, quality assurance, management, construction and regulatory experience.
The team interviewed 54 BECo management and functional personnel at BECo's offices in the Prudential Building and at the Pilgrim Station.
In addition, the team reviewed policies, procedures manuals, status reports, project plans, quality control and license commitment data, position discrip-tions, manpower and expense budgets and numerous memoranda and internal reports. This report represents the professional evaluation by the MAC team of cross-checked interview results, documentation and personal observation.
MAC's approach to the diagnosis of an organization is to pattern its investi-gation after the process by which all organizations, in a general sense, perform I
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their functions. The process of performing work consists of the synergistic interaction of people working within organizational structures, utilizing the systems in place to perform and manage the work. Hence, MAC's investigation has focused on the organizational structure, people and systems in place at BECo and how well these elements are working collectively in the process of performing the functions of the Nuclear Organization.
The scope of this diagnostic was limited to an assessment of BECO's Nuclear Organization as it relates to PNPS-1. It did not address other activities of l
BECo. MAC's findings, evaluations and recommendations from this assessment of the Nuclear Operations are reported in the body of this report under the headings of:
1.0 Introduction 2.0 Summary 3.0 Organization 4.0 Management Controls I
5.0 Staffing Levels and Capabilities 6.0 Training and Retraining 7.0 Intra-and Inter-Departmental Communication 8.0 Commitment Controls 9.0 Station Operation 10.0 Engineering 10.1 Nuclear Engineering Department (NED) 10.2 Configuration Management 10.3 Plant Design Change Requests I
10.4 Q-list 10.5 Drawing Control I
11.0 Quality Assurance 12.0 Nuclear Support Operation 13.0 Safety Evaluations 14.0 Organizational Freedom in Problem Identification and Resolution I
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SUMMARY
MAC's evaluation showed that while the Nuclear Organization includes the functions usually considered necessary to the successful management of nuclear plant operations, the management controls that are in place have not led to optimal operation of the Nuclear Organization. We find a number of promising systems under development which are not completed and have not been fully integrated into a working structure. Recent assignment of a senior I
vice president solely responsible for nuclear activities has materially increased senior management's available time and has improved responsiveness to the needs of the Nuclear Organization. Remaining to be accomplished is restruc-turing the Nuclear Organization including the assignment of a vice president, Nuclear Operations, and devising an integrated system of management controls to maintain safe and efficient operation of the station.
I This diagnostic review has included evaluation of current organizational responsibilities, management controls, staffing levels, training, intra-and inter-departmental communications, commitment controls, functions of Plant Operations, Engineering and Quality Assurance and organizational freedom in I
problem identification and solution.
The results of this diagnostic identified several causes of management dys-function as follows:
Management systems did not provide adequate control.
e Organizational charters, management roles and responsibilities were not e
I clearly defined or understood.
e Discipline in performing or accepting defined roles and responsibilities was lacking, resulting in lack of teamwork between departments.
Management had failed to act or to respond to departmental needs; e
decisions were hard to come by.
e Management style was too informal and reactive rather than proactive.
e There was inadequate allocation or utilization of resources.
These cause statements and the recommended actions to correct or alleviate the problem are covered in Appendix D.
An action plan to implement the recommended actions is Appendix E.
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3.1 CONCLUSION
S In general, the Nuclear Organization contains the essential functional elements (Figure 1); however, the organizational elements are not functioning effectively together as a team. Key organizational problems include:
e The department organizations have seemed to function more in an "us/them" mode than as a "we" team. Tensions which are above normal I
exist among departments. Frequently, conflicts are not resolved.
o Some people are uncertain about their roles, functions, responsibilities and I
authorities, The organizational roles and responsibilities, as defined in the Boston e
Edision Quality Assurance Manual (BEQAM), do not reflect how the opera-tion is actually functioning and, in a number of cases, are not consistent with other control procedures.
e Integration of the support organizations with the activities of the plant staff needs to be improved substantially. The plant staff has arbitrarily set up role boundaries for the support organizations.
The project managers in Nuclear Operations Support Department (NOSD),
e although their responsibilities are broadly defir:ad, have not been delegated the authority necessary to obtain the supporting efforts needed from other organizations so that they can effectively carry out their work. Generally, they feel unsupported by management.
e In an effort to address the organizational difficulties, revised charters have been prepared by several of the departments, but these revised charters have not been approved for implementation.
In response to the problems with the Nuclear Organization, BECo management has made several significant organizational changes which will strengthen the management of the Nuclear Organization.
The Board of Directors has established a Nuclear Operations Review Committee to strengthen the moni-toring of Nuclear Operations at the Board level. In addition, a senior vice president, Nuclear, has been assigned whose sole responsibility is to direct the management of the Nuclear Organization. The appointment of this senior vice president has already accelerated the pace of decision-making and has improved management effectiveness within the Nuclear Organization.
I The planned nuclear organizational structure identified to the NRC by BECo consists of a senior vice president with two vice presidents reporting to him.
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4006-2 3-2 As understood, the present plan for the Vice President, Nuclear Operations, would have reporting to him the Station Manager, Training and Operations Support (currently NOSD) which would include Plant Administration. The I
other vice president would have reporting to him the Engineering and Quality Assurance functions and the termination of PbPS-2. This arrangement is shown in Figure 2.
l There is an advantage to having the Nuclear Organization reporting at the l
senior vice president level since it provides full authority and management support to effect constructive change and effectively eliminates any perceived constraints to obtaining access to BECo's highest management level. However, there can be disadvantages to an organization, in which the plant and one of its most important supporting functions (Engineering) are sharply divided between two vice presidents. This can further inhibit communication because struc-I turally communication would go from the plant to its vice president, across to the other vice president and down to Engineering. While organizations rarely operate this formally, the structure provides the excuse for so doing and could aggravate the "them and us" syndrome which has already been encountered.
One alternative organizational structure would be one in which the function of Pilgrim Station Operations, Station Support, Safety Review, Quality Assurance and the Corporate Site representative all reported directly to the Senior Vice President, Nuclear. The termination of PNPS-2 could report directly or be assigned to Engineering. This broader and flatter structure would eliminate potential filters, simplify communication lines and would encourage an inte-grated team dedicated to safe and efficient operation of PNPS-1. Figure 3 is I
an organization chart showing the arrangement.
Another alternative would be to place under the Vice President, Nuclear Operations, all of the functions relating to the station including Engineering but excepting Quality Assurance and Corporate Nuclear Safety Review and the Corporate Site representative. These could report to a vice president, Safety and Quality Assurance. In this arrangement all of the services essential in operating the s:stion would be under one vice president and those essential to evaluating station performance would be under the other. The disadvantage is I
that it introduces a layer of management between these functions and the Senior Vice President, Nuclear. Figure 4 describes this arrangement.
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4006-2 3-7 An urgent task for the senior vice president is to review the nuclear organi-zation roles, responsibilities and capabilities and to define and formalize the areas of responsibility for the new positions of the Vice Presidents of Nuclear Operations and Engineering, Safety and Licensing and the Corporate site representative.
In this review, care needs to be given to eliminating unnecessary levels of management.
It is not clear that there needs to be both a vice president, Nuclear Operations, and a Corporate site representative to satisfy BECo's commitment to the NRC relative to corporate presence at the site.
3.2 RECOMMEPOATIONS A thorough review of the needs of the nuclear function should be instituted by the Senior Vice President, Nuclear. This would lead to an analysis of the current organizational structure and various alternatives of reporting lines, roles and responsibilities. Upon completion of this review, BECo should clearly communicate the charters, roles, responsibilities and what is expected of each organizational element within the nuclear mission with special attention to eliminating any ambiguity or redundancy. During the interim the senior vice president should clarify which managers are reporting directly to him and which are reporting to the Vice President, Engineering, Safety and Regulation.
The most urgently needed executive actions to improve performance of the Nuclear Organization are clarifying roles and responsibilities for all functional groups participating in the nuclear program and, in accordance with organiza-tional plans submitted to the NRC, recruiting a highly capable and experienced vice president of Nuclear Operations. BECo should analyze and correct any constraints to accomplishing these two tasks.
This, then, should be supplemented with a program to improve acceptance of all organizational roles and to improve teamwork.
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4006-2 3-3 FIGURE 1 i
0FFICE OF THE PRESIDENT PRESIDENT SR. VICE PRESIDENTS I
VICE PRESIDENT NUCLEAR NUCLEAR SAFETY REVIEW AND AUDIT COMMITTEE l
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QUALITY ASSURANCE i4UCLEAR ENGINEERING NUCLEAR OPERATIONS NUCLEAR OPERATIONS MANAGER MANAGER MANAGER - PNPS SUPPORT MANAGER DEPUTY MANAGERS (2)
(OFF-SITE)
(0FF-SITE)
(ON-SITE)
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l PLANT STAFF l
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l OPERATIONS REVIEW COMMITTEE
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k SENIOR VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT ENGINEERING AND NUCLEAR OPERATIONS QUALITY ASSURANCE OFF-SITE
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b TRAINING ENGINEERING PILGRIM 2
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UPPORT A U JCE T E
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FIGURE 3 I
EXECUTIVE OFFICE SENIOR VICE PRESIDENT NUCLEAR I
STAFF 0FF-SITE I
INDEPENDENT I
PILGRIM PILGRIM NUCLEAR SAFETY CORPORATE PLANT #2 STATION STATION REVIEW AND SITE CLEAN-UP OPERATORS SUPPORT QUALITY REPRESENTATIVE g
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FIGURE 4 I
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VICE PRESIDENT NUCLEAR 1
l VICE PRESIDENT I
VICE PRESIDENT SAFETY REVIEW &
OPERATIONS QUALITY ASSURANCE I
SITE I
0FF-SITE CORPORATE REPRESENTATIVE.,
i, PJ OH-SITE k
l STATION STATION QUALITY NUCLEAR SAFETY OPERATIONS SUPPORT ASSURANCE AUDIT COMMI TEE i___________________________________________..____________
QUALITY CONTROL I
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An urgent task for the senior vice president is to review the nuclear organi-zation roles, responsibilities and capabilities and to define and formalize the areas of responsibility for the new positions of the Vice Presidents of Nuclear I
Operations and Engineering, Safety and Licensing and the Corporate site representative.
In this review, care needs to be given to eliminating unnecessary levels of management.
l It is not clear that there needs to be both a vice president, Nuclear Operations, and a Corporate site representative to satisfy BECo's commitment to the NRC relative to corporate presence at the site.
3.2 RECOMMENDATIONS A thorough review of the needs of the nuclear function shculd be instituted by the Senior Vice President, Nuclear. This would lead to an analysis of the current organizational structure and various alternatives of reporting lines, roles and responsibilities. Upon completion of this review, BECo should clearly communicate the charters, roles, responsibliities and what is expected of each organizational element within the nuclear mission with special attention to eliminating any ambiguity or redundancy. During the interim the senior vice president should clarify which managers are reporting directly to him and which are reporting to the Vice President, Engineering, Safety and Regulation.
The most urgently needed executive actions to improve performance of the Nuclear Organization are clarifying roles and responsibilities for all functional groups participating in the nuclear program and, in accordance with organiza-I tional plans submitted to the NRC, recruiting a highly capable and experienced vice president of Nuclear Operations. BECo should analyze and correct any constraints to accomplishing these two tasks.
This, then, should be supplemented with a program to improve acceptance of all organizational roles and to improve teamwork.
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4.0 MANAGEhENT CONTROLS
4.1 CONCLUSION
S Management controls have been informal in the nuclear activity. It appears that the delegation of authority and assignment of responsibility to the Vice President, Nuclear, had insufficient review of performance by his management to provide early warning of problems in the Nuclear Organization. In addition, the management style appeared to be one of avoiding confrontation and hard decisions and was reactive to problem occurrences rather than proactive to problem prevention. The appointment of the Senior Vice President, Nuclear, I
and his actions to date suggests that these problems will be eliminated. While goals and methods of measurement had been established for the Nuclear Organization for 1982, they had not been translated into departmental goals at the time of the diagnostic.
I There is evidence of past goal establishment and achievement at the nuclear station but these had not been uniformly defined at the department level.
Required reports and measurements against goals achievement and overall performance have been lacking. Lack of integrated management controls can result in lack of, or improper knowledge of, work requirements or management expectations, inability to meet commitments, inability to plan and schedule I
work effectively, lack of cost control versus results achieved, and ineffective means of correcting continuing problems. This often results in short-term fixes which could lead to additional problems. It is not evident that there has been consistency in management action to reward achievement or to measure and cause correction of poor performance.
4.2 RECOMMENDATIONS The Senior Vice President, Nuclear, and vice presidents reporting to him, should establish policies and procedures supplementing those at the corporate level. These should be transmitted downward and require the development of specific goals, milestones and control procedures including periodic reports upward not only of budget performance and plant output but also of perfor-mance against mutually acceptable goals.
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A means of providing periodic reports to the Nuclear Operations Review Committee of the Board of Directors should be developed, together with a means for that committee to interact with the Nuclear Organization.
I Controls should be extended downward to individual employees by using an objective performance appraisal system based upon mutually established goals for employee performance. Promotions and pay increases should be tied to such performance reviews. A part of the appraisal of each manager should be his constructive use of this management tool.
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5.0 STAFFIbG LEVELS AND CAPABILITIES
5.1 CONCLUSION
S The technical competence of personnel contacted was generally perceived to be more than adequate. However, management style and skills have caused some problems that need to be evaluated and corrected.
Currently, BECo relles heavily on the use of contract personnel.
Approximmately half of the engineering work utilizes non-BECo, contract personnel. The combination of BECo employees and these contract personnel I
is in excess of the Nuclear budget submittals for the year. There are several groups within the Nuclear Organization which perceive that they will be unable to achieve current commitments without additional staff. Moreover, some groups have not accomplished important assigned responsibilities with existing staff. The issue in this situation, however, is not the shortage of staff but is the proper alignment and utilization of personnel. The addition of contract employees appears to have taken place over a period of time without a well-thought-out program for their services.
It is likely that a well-planned reduction in the numbers of contract personnel and appropriate replacement with BECo employees will indicate that the budgeted numbers for this year, which are in the mid-range of personnel staffing for other single-unit BWRs, are adequate.
For the site, the staffing levels were compared with results from the recent EEI study (Reference, 'EEI Nuclear Plant Staffing Survey, October 1981").
This comparison indicates that the site complement of 240 people falls in the mid-range of the EEI study results, if the extreme high and low numbers of personnel are eliminated. This fact adds further credibility to the previous conclusion that the problems at BECO have not resulted from a lack of personnel but are more likely due to the manner in which the work force was I
utilized.
Only in the area of licensed reactor operators did the evaluation find the possibility of a lower-than-normal level of staffing. The number of personnel in this category is on the low end of the scale observed in the EEI study. This situation will be corrected by completion of the current operator training and licensing program in July 1982.
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4006-2 5-2 The utilization of the referenced study is subject to some limitations and must I
consider that there exists a wide range of special, local conditions,_such as the '
degree of support obtained from the home office and local labor situations. At Pilgrim, as well as in the rest of the industry, a number of significant factors are impacting the overall staffing requirements. These factors include:
Updating and maintaining the Final Safety Analysis Report (FSAR) and Q-e list.
o Engineering, procurement and installation of plant modifications.
e Development and implementation of improvements to the Configuration g
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e Correction of drawing problems.
Many of these activities involve use of outside, contract services.
The requirements for each of these activities need to be carefully developed in a manner consistent with their scope and milestones. It is likely that above-average staffing levels will be required until these activities are completed, the use of contract personnel is evaluated, and organizational responsibilities are clearly defined.
I 5.2 RECOMMEbOATIONS I
A detailed evaluation of each depcrtment should be made>.o eliminate any redunda;A or overlapping functions in order to optimize job content and to I
improve effe'ctiveness of personnel.
When management has completed the development of structure and approved the personnel complement associated therewith, it should approve requisitions in a timely manner to promptly initiate the long acquisition cycle for qualified personnel.
I The Senior Vice President, Nuclear, should review the plans to make certain contract personnel are released in a controlled manner. This will avoid prob-lems in accomplishment of essential work.
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6.0 TRAINING APO RETRAINDC
6.1 CONCLUSION
S The planned training program at the Pilgrim station is perceived to be above the average of most stations. Management has approved adequate staffing for this function; however, a constraint exists in the availability of people to be trained. Reactor operators are working a 60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> schedule to provide time for training; however, such schedules require careful monitoring to guard against excessive fatigue.
The planned training program includes training #or interpersonal relationships and management effectiveness which should be benef'cial.
6.1 RECOMMEPOATIONS The developing site programs, pt.rticularly the new training efforts for both licensed and non-licensed personnel, should be carefully monitored and supported as necessary to assure successful, full implementation. Careful consideration should be given to plant-specific simulation training for the licensed group.
Management should take the action necessary to provide employees time for training without using excessive overtime.
A planned program of developing interpersonal skills of nuclear personnel, including the managers and supervisors, should be expedited as a means of reducing interdepartmental friction and increasing team-building without using excessive overtime.
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4006-2 7-1 7.0 INTRA-AND INTER-DEPARTMENTAL COMMJNICATION l
7.1 CONCLUSION
S The Bulletin Book, which appears to be the repository for BECo's published corporate-level statements, contains those policies required by federal regulations for nuclear activities.
Such policies are covered in detail; however, they are not sufficient to establish direction for the Nuclear Organization and should be supplemented by lower tier documents.
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Bulletin Book policy relative to the Nuclear Organization has not been brought up-to-date with the cLrrent changes. Such updating may wait assignment of the Vice President, Nuclear Operations.
BECo management also uses a series of meetings at least at monthly intervals to inform executives and department managers of executive and Board of Directors activities.
Further, BECo requires quarterly reports from its managers reporting on the meetings held; however, it does not appear that such meetings have been effective in adequately disseminating policy. Other communications are generally informal.
I There is a lack of well defined policies and charters. Procedures intended to guide activities are sometimes duplicative, disconnected and contradictory.
The multiplicity of procedures on some topics causes confusion and may contribute to incompleted actions.
There is definite interdepartmental friction within the Nuclear Organization that inhibits communication. The quality of downward communication has been poor. Upward communication is often perceived to go into a " black hole" within the Nuclear Organization with neither management action nor response.
I 7.2 RECOMMENDATIONS The CEO should assign responsibility to assure that the Bulletin Book becomes a living document by reviewing and updating it on an annual basis and whenever any change (procedural or in personnel) is made which would result in lack of conformity between the Book and the organization or procedures.
The President or Senior Vice President should establish additional policies cpecifically designed to reflect corporate management's desires for operation
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of the Nuclear Organization. Such additional policies should include those describing the responsibilities and authorities, including those reserved authorities, for the Senior Vice President, Nuclear, and the Vice Presidents, I
Nuclear Operations and Engineering, Safety and Regulation.
A review should be made of existing procedures on the same subject in the various departments in order to eliminate duplicative and conflicting procedures, assure adequate implementation of policy and provide the simplest and most concise statements of what is required, how it is to be accomplished and by whom.
The causes of interdepartmental friction need to be assessed and corrected. A I
firm management hand in identifying and enforcing policy and organizational charters is necessary and will greatly aid in reducing frictional interfaces.
Management decisiveness and feedback to the Nuclear Organization should be provided to eliminate the " black hole" syndrome.
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8.0 CCl44ITMENT CONTROLS
8.1 CONCLUSION
S Thero has been inadequate dissemination of knowledge of commitments made by tha Nuclear Organization. The responsibility for meeting them has been diffuse. There has not been an integrated method of defining authority to make commitments or responsibility for assuring they are met. Some nuclear departtr.ents are concerned that committnents cannot be kept or that they I
have been made without adequate evaluation of the resources required to meet them.
A number of organizations have established commitment tracking activities for their individual responsibilities. An integrated computerized commitment tracking mechanism is being established. It appears that this system, when implemented, will provide adequate controls.
8.2 RECOMMENDATIONS Consolidate commitment control activities and define the process in a written and approved procedure. The procedure should address:
e Verification that the proposed computer entries identify all NRC commitments.
Requirement for a similar review for internal commitments (e.g., QA e
audits, NSRAC audits) and addition of such to the list.
Requirement for a review of all commitments versus the basis for commit-e ment, and the resources and schedule required for completion. Negotiate to eliminate, combine or reschedule commitments when possible and necessary.
I Criteria for the kind of detailed planning required for complex commit-e ments. Establishment of commitment planning for complex commitments including interim milestones by which progress can be measured.
Constraints on making new commitments. Provide written, defined author-e ity and responsibility for individual organizations authorized to make commitments. Enforce discipline on making commitments.
A method for fully evaluating and assigning adequate resources required to e
meet a commitment before it is made, including the adverse effects of interactive commitments on resources.
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Assure that computer time and programming is available and economic to I
maintain the commitment control system or adapt a dedicated mini-computer program for data entry and tracking with terminals for QA, Licensing, Engineering, Planning, Scheduling and Cost Control and Nuclear Operations.
Provide working level reports from computer output to identify required actions, schedule and responsibilities and a management level report for commitments that miss milestones prior to completion dates.
These are expected to be a product of the commitment control system which is presently being developed.
Provide a mechanism with appropriate approval requirements to make I
necessary revisions to commitments.
Enforce discipline on missed completion dates.
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4006-2 T-R 9.0 STATION OPERATICNS
9.1 CONCLUSION
S The functions assigned to the station organizations are appropriate to station operation.
The roles and responsibilities of the deputy managers and the administrative group leader, while understood at the station, are not in accordance with the published organization charts or organization charts published in the BEQAM or in the technical specification. The division of I
responsibilities between the plant staff and the supporting activities has not been clearly defined. Lacking this crucial definition, the several participating organizations have attempted to establish role boundaries and attendant responsibility assignments with varying success. Plant personnel, because of its direct license involvement, has largely defined the roles of the support groups at each of its interfaces. Much inter-group friction has resulted. A
" Pilgrim Nuclear Power Company" is said to exist with a basic philosophy of (with some justification) "If you're not a part of the solution at the station, you're a part of the problem". This approach is seen by many support group personnel as an usurpation of assigned roles, and antagonism has resulted.
The maintenance function appears to be competently manned and managed, but several important programs are in the developmental stage. In particular, the Preventive Maintenance Program (PM), an up-dated Q-list and a func-tioning configuration control system are needed for full effectiveness.
I 9.2 RECOMMEFOATIONS The goals and objectives of the station program must be established and each group's contribution thereto must be identified and accepted. In this effort, the fact must be established for all participating groups that all activities within the Nuclear Organization's purview have as their sole justification the safe and efficient operation of PNPS.
The structure of the station organization should be examined with the objec-I tives of optimizing effectiveness and clarifying reporting lines and functions.
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An integrated maintenance program under the overall cognizance of the plant staff is the safest and most efficient approach for managing plant outages.
Major modifications or additions may be individually managed, but all work at the site should be part of an integrated plan and schedule including all partici-pating functions.
I Consideration should be given to including an outage management function at the station with responsibility for planning all future station outages. Both safety and efficiency demand tight control of outage work.
Efforts to provide a PM program, as well as configuration control systems and Q-list programs, should be continued and expedited. In developing such a PM program, the staff should consider the development of standards for main-tenance tasks which include crew size, tools and materials required, planning of maintenance tasks, including work sequencing and estimated hours, so that advantage can be taken of time windows provided during various planned and unplanned plant outages.
The BECo plan that appropriate engineering disciplines will De located at the station to review and approve important actions involving plant configuration should be expedited.
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10.0 ENGREERING ma m EAa -
10.L1 Conclusions The engineering organization charter, as defined in the Engineering Procedures Manual, does not reflect the current organizational structure as defined in BEQAM. A revised organization charter has been prepared and submitted for management approval. This proposed charter needs to be assessed along with the other nuclear organizational changes being considered. There are several organizational problem areas which need to be addressed as follows:
The function of the NED project engineers relative to the function of the e
groups within NED and the project managers in NOSD.
The assignment of the Construction Management Group to NED relative to e
the outage management and plant modification functions in other depart-I ments.
The responsibilities, authorities, reporting relationships and interfaces of e
I the two deputy manager position relative to the department manager and to the group leaders.
I The role of the Deputy Manager, Production, regarding planning and e
scheduling relative to these functions of the new Planning, Scheduling and Cost Control organization.
e The integration of the Systems and Safety Analysis Group into the safety evaluation and systems engineering processes within the department.
I e Assignment of responsibilities for maintaining the FSAR and Equipment List current.
I Assignment of responsibility for establishing a configuration management e
system.
e The functions of NED relative to the Engineering Group in Nuclear I
Operations Department (NOD).
There is a problem with excessive turnover of engineering personnel.
The engineering staff should be strengthened to permit a larger fraction of in-house engineering. Over half of the engineering staff is currently from outside contractors. Approximately 20 BECo requisitions have been approved, which, I
when filled, will help correct this problem. Additional resources are required in order to upgrade and maintain the in-house analytical tools.
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4006-2 10-2 I
10.1.2 Recommendations Review the recently proposed NED organizational charter along with the other Nuclear Organization changes being considered. This review should address the problem areas noted above. Organizational decisions should be made and implemented as soon as possible.
I The causes of the excessive engineering turnover should be Identified and
.i corrective action taken to stabilize the engineering staff.
The engineering staff should be strengthened by hiring additional engineers to replace contractor engineers. In conjunction with strengthening the staff, additional resources should be applied to upgrade and maintain in-house analytical tools.
I 10.2 CONF 1GURATION MANAGEMENT l
10.2.1 Conclusions The safa and efficient operation of a nuclear powe. plant requires a manage-ment system to control the functional and physical characteristics of the plant. The functional and physical characteristics define the configuration of the plant.
Hence, configuration management refers to the management I
systems in place to control the initial definition of the plant's functional and physical characteristics during the design and construction phase, as well as the control of changes to the plant configuration during the operational phase.
An effective configuration management system covers the preparation and control of such documents as specifications and drawings, manuals for opera-tion, maintenance and test, and activities relating to procurement, installation and construction. The configuration management system must address config-uration definition, control and status.
'I The need for a more complete and fully functioning system of configuration management has been recognized by BECo. While a number of essential key elements and controls are in place, the present system is incomplete and inadequately implemented. Some preliminary planning has begun and funds have been allocated for work in 1982 on such a system.
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Examples of the key elements which are in place include procedures, for I
control of documents, specifications, drawings, plant design changes, field revisions and performing safety evaluation and reviews. Procedures are also in I
place for acherence to technical specifications, control of maintenance work j
and procurement of hardware.
I Areas of configuration management which either are incomplete or inade-quately implemented include the description of the technical baseline, control of Plant Design Change Requests (PDCRs), drawing control, a program for maintenance of the Q-list, and procedural control of safety evaluations.
(PDCRs, Q-list, Drawings and Safety Evaluations are discussed in Sections
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10.3,10.4,12.3 and 13.0, respectively.)
The plant configuration baseline has not been adequately maintained, but work is in progress to solve this problem. For example, neither the Equipment List nor FSAR, which is a major technical document describing the plant systems and tequirements, has been kept up-to-date. There is a major effort underway to update the FSAR in response to NRC commitments. Every safety system has been walked down to provide an as-built configuration. BECo management has committed to maintain the FSAR in the future as a "living document".
I One of the major contributors to problems with effective management and control of the plant configuration is the lack of an integrated procedure system within the Nuclear Organization. Each department has its own unique procedures for configuration management processes such as PDCRs, Drawing Control, Safety Evaluation, and Field Revision Notices (FRNs).
These department procedures for the control of the same process are not necessarily consistent with one another. Management has recognized this problem and is taking corrective action. For example, a new procedure for design change control has been recently epproved by NED, NOSD, NOD and Quality Assur-ance Department (QAD) ard is being implemented.
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The configuration management systems lacks an integrated and computerized
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I system for recording and controlling changes to the technical data base which includes cross-referencing of interfacing systems, components and control documents. The lack of mch a system makes it more difficult to cover all areas impacted by a charou, I
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4006-2 10-4 10.2.2 Recommendations Prepare and implement a program to improve the system for configuration management and control. The program should start with a review of the existing elements to determine which elements can be used, which need to be revised and which new elements need to be added. Assign responsibility and provide resources for the preparation of the program and its implementation.
Consideration should be given to establishing a configuration control board, including organizations affected by or required to implement the change, as one of the elements in the improved system.
Set up Nuclear Organization procedures to replace the multiplicity of different department procedures for processes relating to configuration management and control.
I Assign responsibility, allocate resources and prepare action plans for main-taining the FSAR, Equipment List and the Q-list.
10.3 PLANT DESIGN CHANr5 REQUESTS (PDCRs)
I 10.3.1 Conclusions The PDCR is a key element in BECo's system for control of changes to the plant configuration. Several problems exist with the PDCRs including:
Preparation of several separate packages for a given modification, which o
are released at different times and not necessarily tied together. This problem makes it difficult to ensure that system effects have been I
adequately considered and that the PDCRs are complete. It also causes more work for such review functions as On-site Review Committee (ORC).
Inadequate preparation of PDCRs which leads to a significant number of I
e FRNs, which causes major inefficiencies and increases the potential for error.
e Lack of timely close out of PDCRs which impacts the ability to verify completion according to the approved package, e Inadequate definition of requirements and specifications.
Lack of requirements that PDCRs be reviewed and approved by project e
managers or reviewed by persons responsible for such areas as the Q-list or In-Service Inspection (ISI).
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4006-2 10-5 I
Cognizant engineers involved in the preparation of PDCRs do not necessarily participate in the construction, testing, start-up and maintenance phases and thereby lack important feedback.
I 10.3.2 Recommandations Implement action plans for improvement in the preparation and close-out of the PDCRs correcting the problems caused by: (1) multiple PDCR packages for a given modification, (2) Inadequate preparation, (3) lack of timely close-out, (4) Inadequate definition of requirements and specifications, and (5) !nade-quate requirements for review and approval.
Establish action plans which facilitate improved involvement of the cognizant engineers in NED with the activities of the site pertaining to construction, testing, start-up and maintenance.
10.4 Q-t_IST I
10.4.1 Conclusions The systems, components and structures to which the QA program applies are identified by use of a Q-List. The controlled Q-list has not been maintained.
Significant efforts have been made to update the Q-list utilizing re-defined criteria and appropriate analytical methods for making determinations.
Considerable effort has been directed toward revising the content of informa-tion to make the list more useful to the various user groups within the Nuclear Organization and to cormuterize the list to facilitate its maintenance.
It appears that unresolved issues among the departments regarding objectives, criteria, scope, and content for the Q-list have largely contributed to the fact that an updated Q-list has not yet been issued for controlled distribution.
Efforts have been made to resolve these differences and some progress has been made, but unresolved issues remain.
They affect several groups and departments and, therefore, need to be addressed by the organizational compo-I nents involved.
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I There are several important factors to consider in the resolution of the issues. These include the resources required in terms of manpower and budget to implement the update and compile the data. Some of the proposed features for the revised update may be quite desirable but not necessarily essential.
Furthermore some features may be more easily incorporated than others.
10.4.2 Recommendations Action should be taken by the NED Manager to resolve the issue with the departments regarding the Q-list.
The decisions on the unresolved issues should consider the impact on resources and time required to irrplement the proposed revisions and to establish priorities.
Action plans need to be prepared, establishing responsibilities, resources and schedule to accortplish the update effort.
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4006-2 11-1 11.0 QUALITY ASSURANCE
11.1 CONCLUSION
S The establishment of an effective program for assuring the quality of operating, maintaining and modifying a nuclear power station is a requirement of federal regulations. The nature of this responsibility requires that the QA organization work across and through all segments of the Nuclear Organiza-tion. To be effective, the QA program must be comprehensive yet concise, its charter must be understood and accepted, its working relationships must be constructive not antagonistic and the fact that it has the support of manage-I ment must be unquestioned.
It appears that the authority and responsibility delegations to the quality assurance function are appropriate; however, relationships with some essential interfacing organizations are hostile.
A new function, Quality Engineering, has been added with one of its activities being the review of PDCRs, but its role has not been fully defined.
I There is a disparity between the QA Manual and the QA Program Description in the Safety Analysis Report.
The QA Manual has not been updated I
comprehensively in one and a half years.
There is a question relative to the effectiveness of the quality assurance audit program.
This is identified by the number of deficiency reports where satisfactory responses have not been received and by the number still awaiting Quality Assurance verification before close-out.
I While the manpower complement for Quality Assurance has been approved as requested, the scheduled work for 1982 is significantly greater than in 1981. A new function of Quality Engineering has been added. Doubt has been expressed by Quality Assurance as to the ability to meet 1982 commitments with the approved staff. Supplier evaluations are not currently being performed.
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it was reported that requested complements of quality assurance manpower had net been approved until after the NRC Performance Appraisal Board (PAB) report. It appears, therefore, that there has been a lack of support in the past for the quality assurance function.
The problem this would present is aggravated by important organizational interfaces that are hostile to the Quality Assurance organization.
Quality Assurance has identified deficiencies in material and process controls at the station such as releasing material without traceability, by-passing hold points, and improperly moving tagged material. These evidences of ineffective controls at the station are being addressed by BECo by means which include constructing a larger warehousing with improved facilities for material I
control.
11.2 RECOMhEbOATIONS Evaluate the BEQAM and the associated FSAR Chapter to bring them into con-formance with each other and current interfacing organizational charters and procedures.
Develop a plan and schedule for completing an update of the Quality Assurance Manual and for acquisition of needed personnel.
Complete defining and staffing of the Quality Engineering function.
I Consider a Quality Assurance organization having three main sections: Quality Engineering, Quality Control, Systems Audits and Training. Quality Engineer-ing would provide the technical interface and determine the level, frequency and methods of quality verification required. Quality Control would provide I
(as it does) required inspection efforts at the station and would have the authority to control quality of assigned activities.
Systems Audits and Training would maintain the Quality Program Description in the FSAR, and the Quality Assurance Manual, perform audits and supplier evluations, and provide required training in quality assurance procedures and methods.
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Evaluate the present and planned reporting level of the Quality Assurance organization to establish clearly and maintain management's support and to provide independence from organizations under its purview.
4006-2 11-3 Evaluate the causes of inter-departmental conflict and take necessary correc-tive measures including review and definition of roles, responsibilities, and charters, team building and personnel reassignment as necessary.
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12.0 f4JCLEAR OPERATIONS SLPPORT The Nuclear Operations Support Department provides the functions of project management, licensing, information resource management, plant support, and environmental, radiological, health and safety. The MAC review focused on project management, licensing and the drawing control functions of the Information Resources group.
12.1 PROJECT MANAGEhENT 12.L1 Conclusions Effective implementation of the project management function within the nuclear organization is hampered by several critical factors:
e The project management function is not sufficiently accepted by other parts of the Nuclear Organization, including key managers in other I
departments.
e There is inadequate definition of the responsibilities and authorities in organizational charters and procedures for the project managers to effec-tively perform their role.
There are varying practices used by project managers in the performance e
of the project management functions. Accepted guidelines for implemen-tation do not exist.
12.1.2 Recommendations Management should decide how the project management function is to be performed in the Nuclear Organization and where in the Organization respon-sibility for this function should be assigned.
Charters and procedures defining the project managers' roles, responsibilities I
and authorities should be prepared. Guidelines should be prepared defining the practices to be used in the performance of the project management function.
The skills of the project managers should be strengthened through training.
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4006:2 12-2 12.2 LICENSING 12.2.1 Conclusions The licensing function is experiencing difficulties in the following areas:
e Making and meeting commitments to NRC. This problem is caused in part by inadequate consideration of the effort in resources and time required to prepare responses and by an inadequate system for tracking the status and progress of commitments. See Section 8.0 for a discussion of the commit-ment problems and recommendations.
e Problems are perceived by BECo personnel to exist with different responses to NRC being given by the licensing and plant site organization.
e Multiple organizational interfaces with NRC.
The roles, responsibilities and practices of the Licensing Organization relative to other parts of the Nuclear Organization need to be clarified in response to these problems in addition to the improvements in the commitment control area discussed under Section 8.0 of this report.
12.2.2 Recommendations Assess the roles, responsibilities and practices of the Licensing Organization relative to other functions within the Nuclear Organization.
Define and implement corrective action relative to such assessment.
Establish centralized control of licensing issues.
12.3 INFORMATION RESOURCE MANAGEfENT
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The responsibilities of Information Resource Management function include drafting and drawing control.
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12.3.1 Conclusions There are several problems with drawings and drawing control known to BECo. Corrective action is being implemented. The problems include: (1) a l
large number of drawings needing revision, (2) illegible copies of drawings, (3) incomplete sets of drawings in controlled locations, (4) inconsistent application of drafting standards, and (5) the manual sorting of drawings which introduce opportunities for error in filing. The action to correct and update drawings should be completed with the highest priority.
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4006-2 12-3 12.3.2 Recommendations Expedite the process of correcting illegible drawings. Since this is a one-time rffort, this task can be accomplished by an outside contractor to BECo-furnished drafting standards.
Attempt to obtain better reproducible documents from the architect / engineer, Nuclear Steam Supply System and i
component suppliers as an alternative to extensive redrawing.
I Review the process, instruction and training associated with drawing contro!
and distribution with the objective of reducing opportunities for error.
. I Expedite revision of the as-built drawings. Assure the BECo drafting staff is adequate to handle what appears to be a continuing work load.
Provide the computer capability for sorting drawings associated with specific systems, components and structures.
Provide and require adherence to specific drafting standards.
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4006-2 13,1 13.0 SAFETY EVALUATIONS
13.1 CONCLUSION
S An internal assessment requested by the Nuclear Safety Review and Audit Committee (NSRAC) of safety evaulations identified that different depart-ments operate to different and inconsistent procedures and to practices which permit a wide variety of quality and depth. This was demonstrated during the outage when safety evaluations were rejected by the On-site Review Committee (ORC) because all factors had not been considered. Further com-plication to effective safety evaluation results when fragmented PDCR I
packages for a modification make it difficult to do a proper safety evaluation.
The whole is not reviewed until it reaches the ORC.
In the past NSRAC has not adequately performed independent safety reviews of plant modifications.
This problem has recently been addressed and corrective action is being implemented.
I Training has been provided to ORC members in response to the PAB findings.
Overall, the ORC appears to be performing its functions effectively despite a large work load during the outage. The large number of PDCRs and associated FRNs has contributed to this work load.
A temporary modification procedure has been implemented recently at the site.
This procedure covers conditions such as temporary valve alignment.
While this new procedure has not caused significant problems, it should be monitored closely to ensure that the system is functioning satisfactorily.
13.2 RECOMMEPOATIONS Review the procedures, instructions and practices for performing safety evaluations and independent reviews.
Eliminate redundance and conflict.
Assure that an appropriate level of attention is uniformly applied to this important work.
Prepare action plans and ensure resources to perform independent safety 1
reviews which are consistent with the requirements of the NSRAC Charter.
Evaluate and ensure the size of the trained support staff necessary to assist NSRAC in the performance of its role.
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4006-2 13-2 Review ORC's work load and performance periodically to assure that it con-tinues to discharge its responsibilities effectively. Consider providing ORC with staff help.
Monitor the implementation of the temporary modifications procedure to ensure that this process is being performed satisfactorily.
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4006-2 14-1 14.0 ORGANIZATIONAL FREEDOM IN PROBLEM IDENTIFICATION AND I
REWLUTION
14.1 CONCLUSION
S There does not appear to be any management constraint to problem identifi-cation whether nuclear safety or otherwise; however, action appears to have been directed more to identifying the owner of a problem than in identifying the responsibility and method for its resolution.
Long time lags between problem identification and problem resolution are per-ceived by MAC to have been the result of:
e Slowness of corporate response to the needs of the Nuclear Organization, Attempting to achieve decisions through consensus.
e e Management's desire to avoid confrontation.
l Where problems have been identified and not resolved by management action some organizations have independently provided their own solutions, some-times in conflict with the roles and responsibilities of other groups.
Hard choices, in some instances, have been made by default or have not been made at all.
There has been a perceived lack of management support in the past for Nuclear Engineering, Nuclear Operations Support and for Quality Assurance.
l This can lead to a lack of innovative problem solving by these organizations, e.g, short-term fixes in lieu of long-range solutions.
In general, people in the Nuclear Organization know what its problems are.
They need to know and be assured that management is prepared to take action to correct the problems.
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4006-2 14-2 14.2 RECOMhDOATIONS The CEO should encourage decision making and responsible action in terms of problem identification and solution and provide a feeling of comfort in reporting to management both good and bad news. The bearer of bad news needs to be valued as much as the bearer of good news.
The results of this diagnostic, in terms of identified problems, should be communicated to the organization along with an action plan endorsed by executive management.
1 Conflict resolution needs to replace conflict avoidance. Meetings should end j
in actions, not just in problem identification.
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1 COMPARISON OF ISSUES 1
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4006-2a A-1 What follows is a comparison of the issues considered in this evaluation with the commitments already made by BECo to the NRC.
MAC REPORT CURRENT BECo COMMITMENTS Organization Organization e Corporate on-site review e Safety organization review Systeme Systeme e Executive management systems for e Commitment status control I
disseminating policy Regulation change and compliance e
e Executive management control systems e Corrective action systems e Nuclear Organization management control systems e Correspondence review e Planning systems e Modification management systems e Reporting systems e Plant procedure and change evaluation e Accountability systems a Safety review and assessment e Commitment control systems e QA audit systems upgrade Engineering systems e
e Preventive maintenance systems Configuration Management
- PDCRs Q-List I
- Drawing control
- Safety Evaluation People People o Staffing e Improved Training Program e Training l
Process Process l
e Problem Identification, Decision-Making, and Conflict Management I
e Station Operations e Quality Assurance l
e Safety Review Engineering e
I Nuclear Operations Support e
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MAC PERSOb4EL Michael N. Donahoe Organization Development John L. French Project Manager, Operations Kenneth M. Horst Engineering William N. Mobley Management, Engineering Jack M. Norris Team Leader, Management Kenwood Perkins Operations, Management R. Wayne Rutland Quality Assurance _
Joseph C. Turnage Engineering, Operations l
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BECo PersonnelInterviewees I
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4006-2 C-1 I
INTERVEWEES Name Title ANDERSON, William L.
Records Management Group Leader ANTONOPOULOS, Petros T.
Nuclear Analysis Group Leader ARMSTRONG, William J.
Deputy Manager, Nuclear Operations ASHKAR, James W.
Deputy Manager, Nuclear Engineering I
BALFOUR, Harrison R.
Assistant Refueling, Outage, Start-up, Test Manager (Acting)
'I BRANNON, Hawley F.
Manager, Nuclear Quality Assurance BUTLER, Robert M.
Manager, Nuclear Engineering CAMPANELLA, J. F.
Plant Support Group Leader (Acting)
CLIFFORD, J.
Stocks and Stores Department CLOUGH, Robert G.
Nuclear Fuels Procurement and Economic Analyst CORRY,A.F.
Senior Vice President COUGHLIN, R. John Senior Electrical Engineer CUMMINGS, Jack Director of Corporate Training I
CUNNINGHAM, R. H.
Staff Assistant, Nuclear Administration DAILY, Cam Vice President, Steam and Electric Operations DAMRELL, C. Bruce Vice President, Engineering and Distribution DEACON, William H.
Manager, Nuclear Operations Support (Acting)
DELOACH, R. J. (Rockie)
Operational Quality Control Group Leader I
FAIRBANK, Robert V.
TMI Project Manager FALVEY, J. J.
Purchasing Manager FAMULARI, Frank, N., Jr.
Operational Quality Control Group FULTON, John M.
Senior Licensing Engineer, Licensing Group 4
GALLIGAN, T. J. Jr.
Chairman of the Board and Chief Executive Officer GREENBURG, Fred Computer Applications Group Manager I
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4006-2 C-2 INTERVIEWEES (Continued)
Name
_ Title HARRINGTON, W. D.
Senior Vice President, Nuclear HOFFMAN, James J.
Nuclear Plant Operator HOWARD, J. E.
Vice President, Nuclear HULTEEN, Carl Senior Construction Engineer KEARNEY, Edward F.
Staff Assistant, Nuclear Quality Assurance KENNEDY, R. J.
Senior Quality Assurance Engineer LEPORE, J. A.
Stores Department Superintendent MACHON, Richard D.
Manager, Nuclear Operations MATHIS, Charles J.
Deputy Manager, Nuclear Operations MC CANN, John J.
Nuclear Watch Engineer MC EACHERN, John A.
Security Supervisor, Nuclear Operations MC HUGH, George M.
Deputy Manager, Nuclear Engineering MILLS, David A.
Manager, Torus Modification Project MORISI, A. Victor Refueling, Outage, Start-up, I
Test Manager (Acting)
NICHOLSON, Joseph W.
Staff Assistant, Nuclear Operations OXSEN, Lee Corporate Site Representative PAWLAK, John Power Systems Group Leader PHINNEY, Donald M.
Senior Planning and Scheduling Engineer REGAN, Gerard K.
Manager, Planning, Scheduling and Cost Controls ROBERTS, K. P.
Maintenance Group, Nuclear Operations RUCKER, Leonard D.
Systems and Safety Analysis Group Leader I
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4006-2 C-3 INTERVEWEES (Continuan0
'l Name Title SANFORD,D.
Training Group Supervisor SEERY, James A.
Staff Assistant, Nuclear Safety SMITH, Paul D.
Chief Technical Engineer, Nuclear Operations I
SOWDON, Thomas L.
Environment and Radiological, Health and Safety Group Leader STASZESKY,F.M.
President and Chief Operating Officer TEPPER,D.
Consultant TRUDEAU, Adrien R.
Chief Radiological Engineer, Nuclear Operations WEAFER,B.
Manager, Corporate Auditing I
ZIEMIANSKI, Edward J.
Management Services Group Leader, Nuclear Operations I
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APPDOIX D
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l r=- of Menegement Dysfunctions and Recommended Actions
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6049-2 D-1 CAUSES OF MANAGDENT DYSFUNCTION APO RECOMPENDED ACTIONS I
The results of the diagnostic identified six causes of management dysfunction that
' manifested themselves in various organizations and functions. These are listed in the Summary of the report. Following is a listing of these causes of dysfunction, together with the paragraph listing for recommended action and a restatement of that action to correct the cause of the dysfunction or alleviate its results. An additional decimal has been added to the paragraph number. This identifies the sequence within the paragraph in which the specific recommendation occurs. This identification correlates with the BECo action plan for implementing these recommendations.
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Management systems did not provide adequate control.
I 4.2.2 Transmit these policies and procedures supplementing those at the corporate level downward and require the development of:
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- Specific goals 5
- Milestones
- Control Procedures 4.2.3 Require periodic reports upward, not only of budget performance and plant output, but also of performance against mutually acceptable goals.
I 4.2.4 Provide periodic reports to the Nuclear Operations Review Committee of the Board of Directors.
I 4.2.5 Develop means for the above committee to interact with the Nuclear Organization.
4 4.2.6 Extend controls of individual employees by using an objective per-formance appraisal system.
4.2.7 Tie promotion and pay.acreases to such performance reviews.
4.2.8 Appraise performance of managers by their constructive use of this management tool.
8.2.2 Define the commitment control process in written and approved pro-cedures.
8.2.4 Provide working level reports for required actions, schedules, respon-sibilities.
8.2.5 Provide management-level reports for commitments that miss milestones prior to completion dates.
6049-2 D-2 9.2.1 Estabilah goals and objectives for the station.
9.2.5 An integrated program should be established for managing plant outages.
9.2.6 Continue to expedite efforts to provider I
- A preventive maintenance program
- Configuration control systems
- Q-List publication and updating 9.2.7 Develop standards for maintenance tasks which include
- Crew size I-
- Tools and materials required
- Planning
- Work sequencing
- Estimated hours 10.1.2 The causes of excessive engineering turnover should be identified and corrective action taken.
10.2.2.1 Prepare and implement a program to improve the system for configura-tion management and control.
10.2.2.2 Review the existing elements to determine what can be used and what new revised elements can be added.
10.2.2.5 Set up Nuclear Organization procedures to replace the multiplicity of different department procedures for configuration management and control.
10.3.2.2 Correct the problems caused by:
- Multiple PDCR packages for a given modification
- Inadequate preparation
- Lack of timely close-out I
- Inadequate definition of requirements and specifications
- Inadequate requirements for review and approval 12.2.2.3 Establish centralized control of Licensing issues.
l 12.3.2.3 Review the process, instruction and training associated with drawing
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control and distribution with the objective of reducing opportunities for l
error.
12.3.2.6 Provide and require adherence to specific drafting standards.
I 13.2.1 Review the procedures, instructions and practices for performing safety I
l evaluations and independent reviews. Eliminate redundance and con-g filet. Assure that an appropriate level of attention is uniformly applied g
to this important work.
13.2.5 Review ORC's work load and performance periodically to assure that it l
continues to discharge its responsibilities effectively.
6049-2 D-3 2.
Organizational charters, management roles and responsibilities not clearly defined or understood.
3.2.1 A thorough review of the needs of the Nuclear function should be instituted by the Senior Vice President, Nuclear.
I 3.2.2 Analyze the current organizational structure and various alternatives of reporting lines, roles and responsibilties.
3.2.3 Clearly communicate the charters, roles, responsibilities and expecta-I tions to each organizational element.
3.2.5 Clarify roles and responsibilities for all functional groups participating in the nuclear program. (Interim action) 3.2.6 Recruit a highly capable, experienced vice president of Nuclear Operations.
4.2.1 The Senior Vice President and Vice Presidents reporting to him should establish policies and procedures supplementing those at the corporate I
level.
5.2.1 Evaluate each department to eliminate redundance and overlapping I
functions.
5.2.2 Optimize job content.
5.2.3 Improve effectiveness of personnel.
I Assign responsibility to assure that the Bulletin Sook becomes a living 7.2.1 document through periodic reviews and updates.
7.2.2 Establish additional policies specifically designed to reflect corporate I
management's desire for operation of Nuclear Organization.
7.2.3 Describe responsibilities and authorities (including reserved authorities) for the Senior Vice President and Vice Presidents reporting to him.
7.2.4 Review existing department procedures on the same subjects to elimi-nate duplication and conflict.
7.2.5 Assure adequate implementation of policy and provide the simplest and most concise statements of:
- What is required
- How it is to be accomplished
- By whom 8.2.1 Consolidate commitment control activities.
8.2.6 Provide mechanism with appropriate approval requirements to make or revise necessary commitments.
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6049-2 D-4 9.2.3 Establish fact that all activities within the nuclear organization's purview have as their sole justification the safe and efficient operation of PNPS-1.
I 9.2.4 Examine the structure of the Station Organization to clarify reporting lines and functions and to optimize effectiveness.
10.1.1 Review the recently proposed NED Organizational Charter; revise as necessary.
10.2.2.4 Consideration should be given to establishing a configuration control board including organizations affected by/or required to implement the change, as one of the elements in the improved system.
11.2.4 Consider a Quality Assurance Organization having three main sections:
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- Quality Engineering
- Quality Control
- Systems Audits and Training 12.1.2.1 Decide how the Project Management function is to be performed in the Nuclear Organization and where responsibility for this function should be assigned.
12.1.2.2 Prepare charters and procedures defining the project managers' roles, responsibilities and authorities.
12.2.2.1 Assess the roles, responsibilities and practices of the Licensing Organi-zation.
12.2.2.2 Define and implement corrective action relative to such assessing the roles, responsibilities and practices of the licensing organization.
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Lack of discipline in performing or accepting defined rolco at:d responsibilities.
3.2.8 Provide a program to improve acceptance of all organizational roles and to improve teamwork. (Final action) 6.2.4 Develop interpersonal skills of the nuclear organization management per-sonnel to reduce inter-departmental friction and increase team building.
7.2.6 Assess and correct the causes of interdepartmental friction. 3 I
8.2.7 Enforce discipline on missed completion dates.
9.2.2 Identify each department's contribution to the goals and objectives of the station functions and obtain acceptance of their roles.
10.2.2.6 Assign responsibility, allocate resources and prepare action plans for maintaining the FSAR, Equipment List and Q-List.
10.3.2.1 Implement action plans for improvement in the preparation and close-out of PDCRs.
10.4.2.1 Take action to resolve the issues which delay distribution of an updated Q-List.
11.2.1 Bring the BEQAM and the associated FSAR Chapter into conformance with each other and interfacing organizational charters and procedures.
11.2.2 Develop a plan and schedule for completing an update of the Quality l
Assurance Manual and develop a plan and schedule for acquisition of needed personnel.
13.2.2 Assure that appropriate level of attention is uniformly applied to the performance of safety evaluations and independent reviews.
I 13.2.3 Prepare action plans and ensure resources to perform independent safety reviews which are consistent with the requirements of the NSRAC Charter.
13.2.6 Monitor the implementation of the temporary modification procedure to ensure that this process is being performed satisfactorily.
14.2.1 Encourage decision making, problem identification and solution.
14.2.2 Communicate the results of do drugnostic to the organization along with an action plan endcet! y e. wutive management.
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Failure of management to act or to respond to departmental needs.
3.2.4 During transition to a final organization structure, the reporting lines and charters for any transitional structure need to be clearly defined.
3.2.7 Analyze and correct any constraints to accomplishing the clarifying of roles and responsibilities and the recruiting and hiring of a highly capable Vice President of Nuclear Operations.
7.2.8 Provide management decisiveness and feedback to the Nuclear Organiza-l tion.
11.2.5 Evaluate the present and planned reporting level of the Quality Assur-I ance Organization to establish and maintain management's support and assure independence.
11.2.6 Evaluate the causes of inter-departmental conflict and take necessary corrective measures.
14.2.4 Meetings should end in actions, not just in problem identification.
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Management style that was informal and reactive rather than proactive.
l 6.2.1 Carefully monitor and support the new training program to assure successful, full implementation.
7.2.7 A firm management hand in identifying and enforcing policy and organi-zational charters is necessary.
14.2.3 Conflict resolution needs to replace conflict avoidance.
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Inadequate allocation or utilization of resources.
5.2.4 Approve personnel requisitions in a timely manner.
5.2.5 Make certain that contract personnel are released in a controlled manner.
l 6.2.2 Carefully consider plant-specific simulation training for licensed personnel.
6.2.3 Provide time for employee training.
8.2.3 Assure that computer time and programming is available and economic to maintain the commitment control system.
9.2.8 Locate appropriate Engineering disciplines at the station.
10.1.3 Strengthen the Engineering staff by replacing contract engineers.
10.1.4 Apply additional resources to upgrade and maintain in-house analytical capabilities.
10.2.2.3 Assign responsibility and provide resources for the preparation and implementation of the configuration control program.
10.3.2.3 Establish action plans which facilitate improved involvement of the cognizant NED engineers with the activities of the site.
10.4.2.2 Establish responsibilities, resources and schedule to maintain and distribute an updated Q-List.
11.2.3 Complete defining and staffing of the Quality Engineering function.
12.1.2.3 Prcvide training to strengthen the skills of the project managers.
12.3.2.1 Expedito the process of correcting illegible drawings.
12.3.2.2 Attempt to obtain better reproducible documents from the architect /
engineer, Nuclear Steam Supply System and component suppliers.
12.3.2.4 Expedite revision of the as-built drawings. Assure the BECo's drafting staff is adequate to handle what appears to be a continuing work load.
12.3.2.5 Provide the computer capability for sorting drawings associated with specific systems, components and structures.
13.2.4 Evaluate and ensure the size of the trained support staff necessary to assist NSRAC in the performance of its role.
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i APPENDIX E BOSTON EDISON COMPANY PERFORMANCE IMPROVEMENT PROGRAM (CONTAINING BEC0/MAC ACTION PLANS ONLY) 6/28/82
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t LEAD MAC ACTION PLAN #
RESPONSIBILITY I.
INDEPENDENT REVIEW AND EVALUATION 1.
Management Analysis Company Assessment WDH 2.
Organizational Peer Group Review of Independent Evaluations II.
ORGANIZATION VPN0 (WDH) 1.
Corporate On-Site Review 2.
Safety Organization Review 4.2.4, 4.2.5 WDH 3.
Corporate Review of Nuclear Organization 3.2.1, 3.2.2, 3.2.3, 3.2.4, WDH/JEH 3.2.7, 5.2.1, 5.2.2, 5.2.3 7.2.3, 3.2.5, 3.2.6. 3.2.8, 7.2.7 A.
Determine location of functions in 12.1.2.1, 12.1.2.2, 12.1.2.3, WDH/JEH Nuclear Organization 11.2.5, 12.2.2.1, 12.2.2.2 12.2.2.3 B.
Other corporate resource decisions 8.2.3, 5.2.5 WDH/JEH 4.
Review and Revise Engineering Department 10.1.2, 9.2.8, 10.1.1, NED Organization.
10.3.2.3, 10.1.3, 10.1.4 5.
Review and Revise Operations Department 9.2.1, 9.2.2, 9.2.3 N00 Organization 6.
Review and Revise QA Department Organization 11.2.2, 11.2.3, 11.2.4 QA 7.
Review and Revise Operations Support Department Organization 8.
Organization Policies and Procedures A.
Nuclear Organization Policies & Procedures 7.2.4, 10.2.2.5, 7.2.2, 7.2.5, NOS 4.2.2 B.
BECo Quality Assurance Manual 11.2.2, 11.2.1 QA
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LEAD MAC ACTION PLAN #
RESPONSIBILITY III. MANAGEMENT SUPPORT SYSTEM 1.
Comitment Management Systems A.
Commitment Status Tracking & Exception 8.2.4, 8.2.5, 8.2.2, WDH Reporting System 8.2.6, 8.2.1 B.
Regulatory Change & Compliance System JEH C.
Corrective Action Program JEH D.
Correspondence Review JEH 2.
Safety Management Systems A.
Safety Review Assessment 13.2.1, 13.2.2, 13.2.3, JEH 13.2.4 13.2.5 3
3.
Configuration Management Systems 10.2.2.1, 10.2.2.2, NED 10.2.2.3, 10.2.2.4, 9.2.6 A.
Modification Management 10.3.2.1, 10.3.2.2, NED 12.3.2.4, 12.3.2.5 B.
Plant Procedure and Drawing Evaluation 1.
Update & Maintain FSAR, Equipment 10.2.2.6, 10.3.2.1, NED List & Q-List 10.4.2.2, 9.2.6 2.
Obtain & Maintain Legible Plant 12.3.2.1, 12.3.2.2, NOSD Drawings 12.3.2.3, 12.3.2.6 C.
Testing Program D.
PM Program 9.2.6 N0D E.
Corrective Maintenance 9.2.4. 9.2.7 NOD 4.
QA Audit Program
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RESPONSIBILITY 5.
Goals and Objectives Management System A. Corporate Goals and Objectives 9.2.3.A,7.2.1, 7.2.8 WDH/JEH Comunications Plan B. Goals and Performance Measures 4.2.3 WDH/JEH l
- 1. Monitor Temporary Modification Procedure 13.2.6 ALO l
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Outage Management System 9.2.5 N0D 7.
Procurement Management System OAD l
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PERFORMANCE 1.
Training 6.2.1, 10.3.2.1, 4.2.8, Training 6.2.4, 7.2.6, 7.2.2 2.
Policies and Practices Improving Performance 6.2.3, 14.2.3, 10.1.3, WDH.JEH 11.2.6, 7.2.6, 4.2.6, 4.2.7, 4.2.8, 5.2.4, 14.2.1, 8.2.7, 6.2.2, 14.2.4
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i LIST OF ACRONYMS BEQAM - Boston Edison Quality Assurance Manual Bulletin Book - Boston Edison Company Organizational Manual CMG - Construction Management Group CR - Change Request DNOR - Director - Nuclear Operations Review FSAR - Final Safety Analysis Report I
br's - Help Requisitions I-PIP - Integrated Performance Improvement Program MAC - Management Analysis Company I
MEL - Master Equipment List NED - Nuclear Engineering Department NEM - Nuclear Engineering Manager I
N0D - Nuclear Operations Department N0ft - Nuclear Operations Department Manager NOS - Nuclear Operations Support Department NOSM - Nuclear Operations Support Department Manager I
NSRAC - Nuclear Safety Review & Audit Comittee NUORG - Nuclear Organization ORC - Operations Review Comittee 3
PDCR - Plant Design Change Request PIP - Performance Improvement Program PM - Preventative Maintenance or Project Manager PNPS - Pilgrim Nuclear Power Station PS&CC - Planning, Scheduling & Cost Control Department QAM - Quality Assurance Manager I
RO - Reactor Operator SR0 - Senior Reactor Operator TBD - To Be Determined TNG - Training Department I
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INDEPENDENT REVIEW AND EVALUATION I.1 MANAGEMENT ANALYSIS COMPANY ASSESSMENT
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l 1.2 ORGANIZATIONAL PEER GROUP REVIEW 0F INDEPENDENT EVALUATIONS l
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ORGANIZATION II.l.
CORPORATE ON-SITE REVIEW l
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II.2 REVIEW AND REVISE SAFETY ORGANIZATION MAC 4.2.4 Provide periodic reports to the Nuclear Operations Review Comittee of the Board of Directors.
MAC 4.2.5 Develop means for the above comittee to interact with the Nuclear Organization.
Objective:
Establish process to keep Nuclear Operations Board of Directors informed.
Responsibility /
Milestones Action Plan Resources Date Status 1.
Develop charter for the Comittee.
TJG/WDH 2.
Establish schedule of meetings )f the Comittee.
WDH 3.
Implement process.
TJG 9/27/82 4.
Completion date for the action plan.
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II.3 CORPORATE REVIEW 0F NUCLEAR ORGANIZATION 5
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II.3 CORPORATE REVIEW 0F NUCLEAR ORGANIZATION MAC 3.2.1 Review of the needs of the Nuclear function should be instituted by the Senior Vice President, Nuclear.
l MAC 3.2.2 Analyze the current organizational structure and various alternatives of reporting lines, roles, and responsibilities.
MAC 3.2.3 Clearly comunicate the charters, roles responsibilities and what is expected to each organizational element.
MAC 5.2.1 Evaluate each department to eliminate redundance and overlapping functions.
MAC 5.2.2 Optimize job content.
MAC 5.2.3 Improve effectiveness of personnel.
MAC 7.2.3 Describe responsibilities and authorities (include reserved authorities) for Senior Vice President and Vice Presidents reporting to him.
Recruit a highly capable experienced vice president of Nuclear Operations.
MAC 3.2.6 4
MAC 3.2.5 Clarify roles and responsibilities for all functional groups participating in the nuclear program. (Interim action)
MAC 3.2.7 Analyze and correct any constraints to accomplishing the above two tasks.
(Hiring VP0 and clarifying roles & responsibilities of all functional groups.)
MAC 3.2.4 During transition, clarify which managers are reporting directly to the Senior Vice President and which to the Vice Presidents.
MAC 3.2.8 The above three recomendations should be supplemented with a program to improve acceptance of all organizational roles and to improve teamwork.
(Final action)
MAC 7.2.7 Provide a finn management hand in identifying and enforcing policy and organizational charters.
Objective:
Make the Nuclear Organization an efficiently organized unit.
Objective:
Clearly define charters, roles and responsibilities and become more efficient.
Objective:
Establish interim reporting lines.
Objective:
Def'ine responsibility and hire Vice President.
Milestones Action Plan Responsibility / Resources Date Status 1.
Issue interim policy statements-organization chart showing the following reporting lines:
To: Mr. J. E. Howard NED Harrington Complete QA NOSD P II
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To: Mr. W. D. Harrington N00 Training PS&CC J.E. Howard
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l Milestones Action Plan Responsibility / Resources Date Status 2.
Hire Vice President of Operations Harrington Interviews Decision made Make Offer 3.
New Vice President-Operations on board 4.
Write responsibilities and authorities Harrington
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Have Vice Presidents review and coment i
on No. 4 6.
Issue j
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Review the work of each Department to determine Harrington j
their scope.
8.
Review the structure of each Department and Harrington i
detennine if reorganization is required.
9.
Plan and discuss with Vice Presidents and Harrington Managers the reorganization.
- 10. Restructure the Organization after review of Harrington/ Dept. Mgrs.
BEQAM, FSAR, etc. to eliminate overlapping functions and make Organization more efficient.
- 11. Have each Department develop Charters for review Dept. Mgrs.
and approval.
- 12. Approve Charters for issue.
Harrington
- 13. Develop Organizational Policies SEE II.8
- 14. Completion date of the above Action Plan 3/28/83 i
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II ORGANIZATION II.3.A DETERMINE LOCATION OF FUNCTIONS IN NUCLEAR ORGANIZATION l
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M II.3.A DETERMINE LOCATION OF FUNCTIONS IN NUCLEAR ORGANIZATION MAC 12.1.'2.1 Decide how the Project Management function is to be performed in the Nuclear Organization and where responsibility for.this function should be assigned.
MAC 12.1.2.2 Prepare charters and procedures defining the project managers' roles, responsibilities and authorities.
t MAC 12.1.2.3 Provide training to strengthen the skills forthe project managers.
MAC 11.2.5 Evaluate the present and planned reporting level of the Quality Assurance Organization to establish and maintain management's support and assure independence.
MAC 12.2.2.1 Assess the roles, responsibilities and practices of the Licensing Organization.
MAC 12.2.2.2 Define and implement corrective action relative to such assessment.
MAC 12.2 Establish centralized control of Licensina issues Objective.2.3 To resolve the issue of project management to more. efficiently control the Nuclear Organization's resources as they relate to all major projects, and prepare procedures that will address these needs.
Clarify role of project management and develop Project Management skills through Project Management Training.
Objective:
To establish an organization structure which ensures independence of the QA Dept. and access to the appropriate management level to effect necessary corrective actions.
Objective:
Determine where QA should report to maintain their support.
t Objective:
Define role of Licensing.
Milestones Action Plan Responsibility / Resources Date Status PROJECT MANAGEMENT 1.
Form Task force to decide on project Dept. Managers Complete management.
2.
Develop Task force approach AYM/PM's Complete
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Evaluate organizational alternatives.
AVM/PM's Complete g
(a) Develop selection criteria.
(b) Select most suitable project management concept.
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Define project management.
AVM/PM's In progress (a) Develop charter.
(b) Define interfaces, responsibilities and authorities relative to functions of other departments.
(c) Obtain organizational approval and support.
5.
Develop and align supporting systems (infor-AVM/PM's mation control and flow, financial, perform-ance appraisal, budget, planning, and scheduling, resource allocation) to support project management.
6.
Explore alternative Project Management Morisi/
methods and recommend to W.D.H.
Task Force 7.
Formulation of Project Management System Harrington 8.
Training of organization and project AVM/PM's managers.
9.
Implement program.
AVM/PM's QUALITY ASSURANCE 10.
QA reports to Mr. J.E. Howard-monitor Harrington to assure support of QA's needs, 11.
QA prepare a written discussion of H.F. Brannan/
alternatives and advantages and input from disadvantages of each QA organi-R.J. DeLoach/
zational reporting alternative.
F.N. Famulari/
E.F'. Kearney 12.
VP & Sr. VP review, J.E. Howard/
W.D. Harrington 7'.
13.
H.F. Brannan/
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J.E. Howard/
W.D. Harrington 14.
Sr. VP decide.
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Milestones Action Plan Responsibility / Resources Date Status LICENSING
- 15. Mr. J. E. Howard to review Licensing J. E. Howard Complete function and submit recommendations.
- 16. Consolidate all license activities in one area.
Harrington/
Howard
- 17. Issue policy on licensing including Harrington/
reporting line to optimize effective-Howard ness.
1/ 31/83
.18. Completion date of the above Action Plan E
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II.3. B OTHER CORPORATE RESOURCE DECISIONS MAC 8.2.3 Assure that computer time and programing is available and economic to maintain the commitment control system.
MAC 5.2.5 Make certain that contractor personnel are released in a controlled manner.
Objective:
Keep staffing levels to required level.
Objective: Meet the needs of managers.
Responsibility /
Milestones Action Plan Resources Date Status 1.
Consolidate computer activities of entire company.
Strategic Management Complete Comi ttee 2.
Allocate space in main frame computer for future needs.
CIS 3.
Provide personnel for maintenance and enhancements to CIS Honeywell Task System.
4.
Install hardware for Project 2 application at Braintree PS&CC Office and install additional hardware at PNPS.
5.
Recruit computer services specialist for Braintree.
PS&CC 6.
Establish a procedure for requesting computer services.
PS&CC 7.
Issue to appropriate. personnel, computer requirements.
Dept. Mgrs.
8.
If needs not met, report to next level.
Dept. Mgrs.
9.
Request each Dept. Mgr. to submit plan to eliminate WDH Complete contractor personnel.
10.
Submit plan to Sr. Vice President.
Dept. Mgrs.
Complete
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Release personnel per approved plan and review on a periodic WDH m'
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12.
Completion date of the above action plan.
2/7/83 i
e II. ORGANIZATION II.4 REVIEW & REVISE ENGINEERING DEPARTMENT ORGANIZATION i
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11.4.
REVIEW & REVISE ENGINEERING DEPARTMENT ORGANIZATION MAC 10.1.2 Identify the causes of the excessive Engineering turnover.
MAC 10.1.1 Review the recently proposed NED Organizational Charter; revise as necessary.
MAC 10.1.3 Strengthen the Engineering staff by replacing contract engineers.
MAC 10.1.4 Apply additional resources to upgrade and maintain in-house analytical capabilities.
MAC 9.2.8 Locate appropriate Engineering disciplines at the station.
MAC 10.3.2.3 Establish action plans which facilitate improved involvement of the cognizant NED engineers with the activities of the site.
Identify the cau~ses of excessive engineering turnover and implement plan for corrective action.
Objective:
Objective:
Strengthen engineering staff through additional hiring to replace contractor engineers.
Apply additional resources to upgrade and maintain in-house analytical tools.
Objective:
Provide proper engineering support of routine stations needs.
Milestones Action Plan Responsibility / Resources Date Status 1.
Conduct survey of engineering R.M. Butler /RHR Corp.
employees who have left BECo 25K-1 man-month and provide report on results.
2.
Define organizational R.M. Butler (NE portion) responsibilities.
I man-month 3.
Improve flow of communications
- GL meetings (periodic)
R.H. Butler /NEDM's/NE GL's 0.6 m/ month
- Improved distribution of information R.M. Butler /IRMG-NOS 2 staff full-time 4.
Review application and rules for R.M. Butler /ERO Complete overtime compensation.
2 man-days
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Milestones Action Plan Responsibility / Resources Date Status 5.
Develop additional actions in response to R.M. Butler /NEDM's results from #1.
NE GL's to be determined.
6.
Review the NED organizational Charter Harrington/ Butler 1 man-day 7.
Review the functions of the NED project Morisi/ Dept. Mgrs.
l Engineers and the NOSD Project Managers 1 man-day l
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Review the assignment of the NED Construction Harrington/ Butler /Machon Management Group relative to outage 3 man-days management and plant modification functions in other departments.
9.
Review the responsibilities, authorities, Harrington/ Butler 1 man-day reporting relationships and interfaces of the deputy manager position relative to the l
department manager and group leaders.
- 10. Review the role of Deputy Manager, Production Harrington/ Butler /Regan 1 man-day l
relative to the functions of the Planning, Scheduling and Cost Control Organization.
- 11. Study the integration of the Systems and Butler Complete Safety Analysis Group into the safety evaluation and systems engineering processes within the department, i
- 13. Assign responsibility for establishing and Refer to PIP #III.3 maintaining a configuration management system.
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- 14. Clarify the functions of NED relative to the Harrington/ Butler 3 man-days Engineering group in the Nuclear Operations Machon Department.
m-15.
Issue approved Organization Charters.
Harrington 1 man-day (II.3) k 16.
Issue revised Department level Dept. Mgrs. 4 man-days organization procedures (1.01) i
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M Milestones Action Plan Responsibility / Resources Date Status
- 17. Fill approved 1982 NED complement R.M. Butler /NE GL/ERO 200 mhr/mo.
- 18. a) Review forecasted G.M. McHugh/NE GL/PSCC Complete-ongoing workload, and b) Revise 1982 requisition S. Dasgupta/ERO requirements accordingly 1 man-day 19.
Review NE personnel skill level / require-J.W. Ashkar/NE GL ments in tech. groups for compatability 1 man-day with new hires.
20.
Define requirements for in-house analytical J.W. Ashkar/NE GL tools, review existing capability, and 10 man-days identify additions to this capability.
a) Prepare plan, and J.W. Ashkar/NE GL b) Obtain resources for acquiring J.W. Ashkar/NE GL additional analytical capability
- 21. Assess needs for engineering presence W.D. Harrington with Dept.
at PNPS.
Mgrs.
2 man-weeks 22.
Relocate Nuclear Engineering staff to R.M. Butler Complete Braintree-closer to PNPS 23.
Establish Site Engineering Representatives J.ll. Ashkar 2 man-weeks Complete with functional work description.
- 24. Assess further needs for revision to Site Dept. Mgrs.
Engineering Representative role.
2S. Establish policy and planning for R.M. Butler n,
increased involvement of NE engineers do with Pilgrim Station activitie's i
26.
Completion date of the above Action Plan 3/28/83
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11.5 REVIEW AND REVISE OPERATIONS DEPARTMENT ORGANIZATION l
MAC 9.2.1 Establish goals and objectives for the station.
l MAC 9.2.2 Identify each department's contribution thereto and obtain acceptance of their roles.
MAC 9.2.3 Examine the structure of the Station Organization to clarify reporting lines and functions and to optimize effectiveness.
To assure that all participating organizations are aware of station Objective:
goals and objectives and are acting to accomplish same.
Milestones Action Plan.
Responsibility / Resources Date Status 1.
Re-evaluate and generate Division Machon Complete goals revised 2.
Approve Division goals V.P. Operations 3.
Promulgate Division goals and report Machon 4.
Review station structure Harrington/Machon 5.
Determine optimal structure Harrington/Machon 6.
Reorganize as required Harrington/Machon 3/28/83 7.
Completion of the above Action Plans m.
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M II.6 REVIEW & REVISE QA DEPARTMENT ORZANIZATION MAC 11.2.4 Consider a Quality Assurance Organization having three main sections:
- Quality Engineering
- Quality Control
- Audits MAC 11.2.3 Complete defining and staffing of the Quality Engineering function.
MAC 11.2.2 Develop a plan and schedule for completing an update of the Quality Assurance Manual.
Develop a plan and schedule for acquisition of needed personnel.
(See Sec. II.8 for Update QA Manual.
Objective: To re-define the QA Department organization and the responsibilities assigned to each group.
Milestones Action Plan Responsibility / Resources Date Status 1.
QA review activities assigned to Operations Quality Control and Inservice Inspection Groups.
oDevelop a written description R.J. DeLoach/F.N. Famulari (prepare) of the activities assigned to H.F. Brannan (approve) the group or groups decided upon.
NOTE:This effort may be used as input to the charters re-definition effort oApprove H.F. Brannan J.E. Howard W.D. Harrington 2.
QA develop written descriptions of F.L. Sche 11enger (prepare) the activities to the Quality H.F. Brannan (approve)
Engineering Group and the Auditing NOTE: This effort may be used as m
Group.
input to the charters re-h
, definition effort.
3.
QA allocate current personnel and H.F. Brannan outstanding, approved Help Requisitions.
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QA prepare a Help Requisition and H. F. Brannan (prepare) a justification memo for a Quality J. E. Howard (approve)
Engineering Group Leader.
W. D. Harrington (approve) 5.
QA seek out and interview qualified H. F. Brannan with Personnel candidates, and make employment Dept. Support offers.
6.
QA hire, and orient and indoctrinate H. F. Brannan needed personnel to file currently authorized Help Requisitions.
7.
QA review manpower needs in tems of H. F. Brannan with J. E. Howard and the approved, re-defined QA charter H. D. Harrington approval of any and QA objectives and goals.
changes. This effort depends on completion of charters re-definition; see PIP Action Plan 11.3.
8.
QA prepares additional Help Requisitions.
H. F. Brannan (prepare) if necessary.
J. E. Howard (approve)
W. D. Harrington (approve) 3/28/83 9.
Completion date of Action Plan.
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QA = 5 openings - 1 pending and 4 open by end of month = may have 3 additional open H.R.'s m
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i II.8.A NUCLEAR ORGANIZATION POLICIES & PROCEDURES j
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II.8.A NUCLEAR ORGANIZATION POLICIES AND PROCEDURES MAC 7.2.5 Assure adequate implementation of policy and provide the simplest and most concise statements of:
- What is required
- How it is to be accomplished
- By whom MAC 7.2.2 Establish additional policies specifically designed to reflect corporate management's desire for operation of Nuclear Organization.
MAC 7.2.4 Review existing department procedures on the same subjects to eliminate duplication and conflict.
MAC 10.2.2.5 Set up Nuclear Organization procedures to replace the multiplicity of different department procedures for configuration management and control.
MAC 4.2.2 Transmit these policies and procedures downward and require the development of:
- Specific goals
- Milestones
- Control Procedures MAC 4.2.1 The' Senior Vice-President and Vice-Presidents reporting to him should establish policies and procedures supplementing those at the corporate level.
Objective:
To develop a set of Nuclear Organization procedures that adequately addresses the Nuclear Organization Policies and the functional needs of the Nuclear Department.
Objective:
To establish and mala known, policies (a high level plan) which embraces the goals and procedures of the organization toward accomplishing a comon mission.
Milestones Action Plan Responsibility / Resources Date Status 1.
Review BEco's Bulletin Book Policies WDH/JEH
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Review NUORG Policy Directives WDH/JEH 3.
Develop list of additional NUORG policy HDH/JEH directives desired by management.
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Milestones Action Plan Responsibility / Resources Date Status 4.
Develop additional NUORG policies.
WDH/JEH TBD 5.
Transmit these policies downward and require the development of:
- Specific goals
- Milestones
- Control Procedures 6.
Revise Existing Procedures a.
Review Existing Departmental Procedures RMG 2mm b.
Detennine Overlapping Procedures RMG 2mm c.
Establish Rewrite Priorities Exec. Im d.
Rewrite Overlapping Procedures RMG 50 m e.
Review new Procedures with Cognizant Ind.
NED/ NOD /NOS/QA/PS&CC/TNG 2m f.
Obtain Sign-Off RMG 1 mm/wk per Proc.
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Train Personnel in New Procedures TNG and all departments i
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Develop Training Outlines 3 mm l
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Schedule Training 1 mm l
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Train Cognizant Personnel 12 m 8.
Issue New Procedures and Implement RMG 2 wks Post Signoff EA Procedure 9.
Completion date of Action Plan TBD 7/31/82 l
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II.8.B BEco QUALITY ASSURANCE MANUAL 0
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M II.8.B BECo QUALITY ASSURANCE MANUAL MAC 11.2.2 Develop a plan and schedule for completing an update of the Quality Assurance Manual. Develop a plan and schedule for acquisit, ion of needed personnel.
See Section 11.5 Resource Acquisition Plan.
MAC 11.2.1 Bring the BEQAM and the associated FSAR Chapter into Conformance with each other and interfacing organizational charters and procedures.
Objective: To reflect current organization, systens, and procedures in BEQAM II, and to achieve consistency among the QA program descriptions.
Milestones Action Plan Responsibility / Resources Date Status 1.
QA review BEQAM II to identify changes F. L. Sche 11enger required, including expected effects of the charters effort (see Item 3); prepare report.
2.
QA prepare draft BEQAM II Change Requests:
o Assign personnel to prepare CR and H. F. Brannan draft revision to each Section.
o Prepare and issue a schedule F. L. Sche 11enger (prepare) covering all CRs.
H. F. Brannan (approve) o Develop initial drafts of CR and Assigned QA Engineers: number revision to assigned Section; take to be determined; word account of current governing procedures processing personnel.
which implement the Section.
3.
WDH provide organizational charters which See PIP Action Plan II.3 result from effort to re-define them.
4.
QA identify effects of charter re-definition F. L. Sche 11enger and assigned on each BEQAM II Section; redraft CRs and QA Engineers; word processing Sections accordingly.
personnel.
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M Hilestones Action Plan Responsibility / Resources Date Status 5.
Department Managers review updated H. F. Brannan (release for review)
BEQAM II Sections and return R. M. Butler results to QA.
R. D. Machon A. V. Morisi G. K. Regan D. Sanford 6.
QA Resolve comments / concerns and H. F. Brannan, JEH, WDH as necessary;
. revise as necessary.
Assigned QA Engineers; word processing personnel.
7.
Approve and issue updated Sections.
H. F. Brannan J. E. Howard W. D. Harrington 8.
QA revise FSAR Appendix D to refer D. A. Diotalevi Complete to BEQAM II as the current QA Program description.
Note: This effort is part of the NRC-required FSAR Update.
9.
Completion date of Action Plan 1/ 31/83
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III MANAGEMENT SUPPORT SYSTEMS III.1.A COMITMENT STATUS TRACKING & EXCEPTION REPORTING SYSTEM O
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III.1.A COMMITMENT STATUS TRACKING AND EXCEPTION REPORTING SYSTEM MAC 8.2.1 Consolidate Comitment Control Activities i
MAC 8.2.2 Define the process in a written and approved procedure.
MAC 8.2.4 Provide working level reports from computer output to identify:
- Required Actions
- Schedule
- Responsibilities MAC 8.2.5 Provide management-level reports for comitments that miss milestones prior to completion dates.
MAC 8.2.6 Provide mechanism with appropriate approval requirements to make necessary comitments.
Objective:
Develop procedures and a commitment status tracking and exception system that implementsthe Nuclear Organization's policy to effectively control the scheduling and tracking of commitments made to regulatory agencies.
Milestones Action Plan Responsibility / Resources Date Status Organization Policy 1.
List all personnel authorized to make WDH/JEH 1 man-day commitments to NRC and establish limits on their authority.
2.
Prepare and issue NRC correspondence AVM/JMF 1 man-week control procedure.
3.
Prepared and issue NUORG policy on NRC WDH/JEH 1 man-day commitment deviation reporting requirements.
Systen Development 4.
PS&CC develop a computerized NRC Commitment T
Status Tracking and Exception Reporting M
System that meets the recomendation.
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Milestones Action Plan Responsibility / Resources Date Status System Development (Cont.)
Develop a system and establish' D.M. Phinney/J.M. Fulton data base of all known licensing 1 Computer Services Specialist Comitments 1 Planning & Scheduling Engineer 1 Planning & Scheduling Analyst 1 Data Entry Clerk part-time for 2 months Establish System Status (i.e. Working D.M. Phinney/J.M. Fulton Complete level) Report fomat 1 Computer Services Specialist 1 Planning & Scheduling Engineer for 2 months 1 Data Entry Clerk part-time Review data base and Status Report D.M. Phinney/J.M. Fulton PS&CC & Licensing fomat with Department Managers complete 1 Planning & Scheduling Engineer 2 Planning & Scheduling Analyst for 2 months NED complete NOSD complete QA complete Issue Project Control Group internal D.M. Phinney/J.M. Fulton Complete computerized comitment control 1 Planning & Scheduling Engineer procedure for review and comment for 2 weeks Issue Licensing Commitment Status D.M. Phinney Complete Report including unreviewed N0D commitments 1 Planning & Schedulina Engineer 1 Computer Services Specialist m
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i Milestones Action Plan Responsibility / Resources Date Status
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System Development (Cont.)
Issue draft Licensing Commitment D.M. Phinney Exception Report (i.e. Management 1 Planning & Scheduling Engineer level report) for review and coment 1 Computer Services Specialist (Note: excludes N0D comitments) 1 Data Entry Clerk Incorporate initial comments and revise D.M. Phinney/J.M. Fulton Licensing Comitment Exception Report 1 Planning & Scheduling Engineer fomat as necessary 1 Computer Services Specialist 1 Data Entry Clerk Issue Licensing Commitment Exception D.M. Phinney/J.M. Fulton Report in approved fomat 1 Planning & Scheduling Engineer 1 Computer Services Specialist 1 Data Entry Clerk 5.
PS&CC develop a computerized Quality Assurance Deficiency Report monitoring system Develop a computer report format G.K. Regan/H.F..Brannan which duplicated infomation provided 1 Quality Assurance Engineer on an existing Manual System 1 Computer Services Specialist Complete for 15 months Fomat reviewed and accepted by G.K. Regan/H.F. Brannan Complete Management 1 Computer Services Specialiit Entered data from April 30, 1982 G.K' Regan Complete Deficiency Status Report into 1 Computer Services Specialist computer 1 Data Entry Clerk Update status report as of May 31, 1982 H.F. Brannan m
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M Milestones Action Plan Responsibility / Resources Date Status Enter data and provide reports to G.K. Regan/D.M. Phinney Quality Assurance for distribution 1 Computer Services Specialist 1 Data Entry Clerk 9
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Completion date of the above Action Plan l
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III.2.A SAFETY REVIEW ASSESSMENT MAC 13.2.1 Review the procedures, instructions and practices for performing safety evaluations and independent 13.2.2 reviews.
Eliminate redundance and conflict. Assure that an appropriate level of attention is uniformly applied to this important work.
MAC 13.2.3 Prepare action plans and ensure resources to perform independent safety reviews which are consistent with the requirements of the NSRAC Charter.
l Evaluate and ensure the size of the trained support staff necessary to assist NSRAC in the performance ll MAC 13.2.4 of its role.
MAC 13.2.5 Review ORC's workload and performance periodically to assure that it continues to discharge its responsibilities effectively.
To assure the safe operation of Pilgrim Nuclear Power Station through periodic review of results achieved i
Objective:
I by organizational safety evaluation processes and procedures, evaluating these results against regulatory and design base requirements and causing corrective actions to be implemented if necessary.
1 Responsibility /
Milestones Resources Date S tatus Action Plan 1.
Document NRC requirements for Safety Evaluation and Review LDR activities.
2.
Review current organizational roles and procedures for LDR/ Task Force safety evaluation and review activities.
The NSRAC and ORC will be included.
3.
Clarify organizational roles and accountability definitions ALO/ Task Force to eliminate overlapping and duplicative assignments and to achieve effective implementation of NRC requirenents.
4.
Issue organizational policy on Safety Evaluation and Review.
WDH/JEH 5.
Issue organizational procedure for Safety Evaluation JEH/ Task Force and Review.
6.
Establish indoctrination and training program.
DES / Task Force
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Review workloads and staffing levels of organizational Dept. Mgrs, fr units who perform safety evaluation and review activities.
TBD 7/31/82 8.
Completion date for the action plan l
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M PIP III.3 CONFIGURATION MANAGEftENT MAC 10.2.2.1 Prepare and implement a program to improve the system for configuration management and control.
Review the existing elements to determine what can be used MAC 10.2.2.2 and what new revised elements can be added.
MAC 10.2.2.3 Assign responsibility and provide resources for the prepara-tion and implementation of the configuration control program.
MAC 10.2.2.4 Consideration should be given to establishing a configuration control board including organizations affected by/or required to implement';the change, as one of the elements in the improved system.
Continue to expedite efforts to provide a configuration control MAC 9.2.6 system.
Integrate and improve existing configuration control system into a single, effective system.
OBJECTIVE:
Milestones Date Status Action Plan Responsibility / Resource 1.
Presentation to Dept. Hgr's J. W. Ashkar, Dept. Managers on general concepts and 2 man-days plus K. M. Horst resource requirements 2.
Establish'a task force and W. D. Harrington, division of responsibility Dept. Managers involving NED, NOSD, N0D, QA,.
PS&CC, Purchasing, Stores and Computer Services, to define program requirements, scope and interfaces.
3.
Define conceptual scope in a Task Force Chairman /
m system, description document 6 man-weeks 1,
including regulatory and BEco management requirements with program elements and inter-faces described.
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Milestone Action Plan Responsibility / Resource Date Status 4.
Identify and review existing Task Force Chairman /
program elements; confirm 10 man-weeks acceptability and/or develop recommended program element revisions with implementation plan.
5.
Review and approve plan for W. D. Harrington/
implementation and assign Dept. Managers responsibilities and resources for full implementation.
I Project Manager 6.
Implement plan, including comprehensive procedures assigned individual conforming to the #3 above.
7.
Provide training as required.
D. Sanford 2/7/83 8.
Completion date of the above action plan 8
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PIP III.3.A MODIFICATIONS MANAGEMENT MAC 10.3.2.1 Implement action plans for improvement in the preparation and close-out of PDCR's.
MAC 10.3.2.2 Correct the problems caused by:
Multiple PDCR packages for a given modification Inadequate preparation Lack of timely close-out Inadequate definition of requirements and specifications Inadequate requirements for review and approval MAC 12.3.2.4 Expedite revisihn of the as-built drawings. Assure the BECo's drafting staff is adequate to handle what appears to be a continuing work load.
MAC 12.3.2.5 Provide the computer. capability for sorting. drawings associated with specific systems, components and structures.
Objectivs:
To improve the overall quality, coordination and control of the design change process, g
Objective:
To assist in the development and implementation of an effective PDCR System.
C h etive:
To provide ^a timely plant design change process which optimizes preparation and control of design packages, compliance with regulatory and design base requirements during implementation, and close-out features which update design base and operating require-ments accurately.
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' Close-out of Open P_0CR's Milestones Action P1an_
Responsibility / Resource Date Status
_ 1.
Prepare fonctional diagram.
D. Whitney / input from
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of a close-out procese and designated N0D, NOSD, QA approve.
representation and CMG.
l 2 man-weeks 2.
Prepare consolidated procedure D. Whitney / input from for close-out of back-log.
designated N05, NOSD Procedure to be basis of a QA representative and segment of future Organization CMG.
I man-week procedures on design change close-out.
3.
Compile list of PDCR's (plant D. Phinney/ input from design change request) in N0D,NED,NOSD,QA.
close-out phase and establish 1 man-week status.
Issue status reports periodically.
4.
Assign personnel responsible Dept. Managers for PDCR close-out functions.
2 man-days 5.
Establish scope of work with Dept. Managers schedules and resource require-2 man-days ments. Assign work priority consistent with integrated work plan / priority system.
6.
Perform close-out.
Assigned individuals 7.
Monitor progress.
D. Phinney, Dept. Mgrs.
8.
Take corrective actions as T
necessary.
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II.
Design Change Process improvement Milestones Action Plan Responsibility / Resource Date Sta tus 1.
Issue Organization policy W. D. Harrington Complete regarding completeness of 1 man-week PDCR's prior to approval for implementation, t
2.
Prepare functional diagram for J. W. Ashkar Complete plant systems design change 1 man-week process.
" Projects" review at conceptual AVM/PM's stage of PDCR' Project Manager review / approval AVM/PM's participation for all phases of PDCR revisions Enhancement of records processing AVM/WLA and timely NOS review of FRN's 3.
Prepare Nuclear Organization D. A. Whitney procedure for plant system 2 man-weeks design change process which ties together all elements of a PDCR.
4.
Review, revise and approve #3.
Dept. representatives (to be assigned) 4 man-weeks 5.
Revise Department Procedures Dept. representatives 4 man-weeks 6.
Conduct training program D. Sanford for revise procedures.
2 man-weeks "l
7.
Establish a PDCR tracking f
and reporting system a-manual D. Phinney/2 man-weeks computerized D. Phinney/2 man-weeks
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Milestones Action Plan Responsibility / Resource Date Status _
8.
Establish plant system design J. W. Ashkar
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change criteria document which 2 man-weeks identifies specified requirements for system design change, including procedure preparation.
9.
Establish plant systems Design J. W. Ashkar Change Review Board, including 2 man-weeks affected procedure revisions.
10.
Review selected design basis J. W. Ashkar documents for possible revision NE Group Leader 4 man-weeks planning.
- 11. Assigns Plant System responsi-J. W. Ashkar bility with NED/NOSD Group Leader 1 man-week 12.
Monitor implementation and J. W. Ashkar identify need for further 2 man-weeks action.
13.
Implement Records Backfit AVM/WLA l
I Project ASAP 14.
Corporate Infonnation Systems JEH/AVM/WLA A.
Raise priority for improving i
Records Management Systems software.
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Provide the computer capability l
for sorting drawings associated with specific systems, components, and structures.
15.
Completion date of the above TBD 8/30/82
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M PIP III.3.B.1 UPDATE & MAINTAIN FSAR, EQUIPMENT LIST AND Q LIST MAC 10.2.2.6 Assign responsibility, allocate resources and prepare action plans for maintaining the FSAR, Equipment List and Q-List.
l MAC 10.4.2.1 Take action to resolve the issues which delay distribution of an updated Q-List.
MAC 10.4.2.2 Establish responsibilities, resources and schedule to maintain l
and distribute an updated Q-List.
MAC 9.2.6 Continue to expedite efforts to provide Q-list publication & updating l
OBJECTIVE:
Develop System to Update and Maintain the FSAR and Equipment List OBJECTIVE:
Identify and resolve issues regarding Q-List, update, and issue Milestones Action Plan Responsibility / Resource Date Status 1.
Identify, review and evaluate J. W. Ashkar, with all Depts.
status of existing equipment designated representative /
lists for PNPS.
2 man-weeks 2.
Select equipment lists and format J. W. Ashkar, G. M. McHugh to be maintained, updated and revis4d all Dept. representatives /
to support configuration management.
2 man-weeks Scope revisions requirements and plan with resource allocations.
3.
Approve scope & implementation plans.
Dept. Managers Assign responsibilities and 2 man-days priorities.
4.
Revise listings and include Assigned individuals required descriptive material resources according to to be current and accurate.
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Milestones Action Plan Responsibility / Resource Date Status 5.
Review procedures for revising D. A. Whitney, Dept.
FSAR and equipment lists and revise.
representatives /
2 man-weeks 6.
Approve procedures in #5.
Dept. Managers 7.
Training in procedures and bases D. Sanford/
as needed.
2 man-weeks
, 8.
Integrate with configuration Configuration Management management system as described responsible individuals by item III.3 (see 10.2.1 item #6) 9.
Identify and resolve Q-List R. M. Butler with problems concerning application Dept. Mgrs., L. D. Rucker, and present content.
J. E. Howard/
1 man-week 10.
Udate the current list per L. D. Rucker/
current criteria, if applicable.
20 man-weeks Engineering support 11.
Issue controlled copies and W. L. Anderson with maintenance procedures.
D. A. Whitney, L. D. Rucker i
12.
Interface Q-List with Configuration L. D. Rucker/To be determined l
Control System.
(see item 10.2.1) 13.
Develop long Term update programs L. D. Rucker, Dept. Managers if criteria re-defined in #1.
J. E. Howard/
3 man-weeks 14.
Completion date of the above TBD 9/20/82 action plan
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PIP III.3.B.2 OBTAIN & MAINTAIN LEGIBLE PLANT DRAWINGS MAC 12.3.2.1 Expedite the process of correcting illegible drawings.
MAC 12.3.2.2 Attempt to obtain better reproducible documents from the architect / engineer, Nuclear Steam Supply System and component suppliers.
MAC 12.3.2.3 Review the process, instruction and training associated with drawing control and distribution with the objective of reducing opportunities for error.
MAC 12.3.2.6 Provide and require adherence to specific drafting standards.
OBJECTIVE:
To obtain and m'aintain accurate, legible flies of all plant drawings Milestones Action Plan Responsibility / Resource Date Status 1.
NOS Generate drafting standards Compile existing RMG standards W. L. Anderson - Support required from NED Engineers and NOS Draftsmen-2 man months Generate formal drafting W. F. Ryan - Drafting Supervisor In Progress l
i standards as part of RMG 1 man month work instructions Train drafting technicians Continuing weekly sessions until on standards all covered 2.
Inventory Drawing Data Base Inventory new vault to detennine W. F. Ryan - Drafting Supervisor In Progress precise number of illegible 3 man months drawings Separate restorable drawings Same as above In Progress j
from redraws m:
h' Call ap-cards from A/E's for W. L. Anderson Manager RMG In Progress l
drawings requiring redraw 1-h man months 3.
NOS Initiate Redraw / Restoration
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M Photo restore illegible were Contractor Manpower - to possible be determined Create new masters from A/E master and update as required Redraw remainder 4.
NED Review and Approve Redrawn R. Butler / Discipline Engineers Masters To be determined 5.
Completion date of Action' flan.
TBD 7/31/82 l
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III.3.0 P.M. PRDGRAM MAC 9.2.6 Continue to expedite efforts to provide:
- A preventive maintenance program
- Configuration control systems See Section III.3
- Q-List publication and updating See Section III.3.B.1 Objective:
To assure the development and implementation of an effective Preventive Maintenance Program for Pilgrim Station equipment and structures Milestones Action Plan Responsibility / Resources Da t'e Status Develop Plan. Obtain approval & funding N00 Complete Draft Master Equipnent List (MEL)
NOD Canplete.
Develop Master Scheduling System and Implement N0D Develop Equipment Data Form with P.M.
N0D Requirements Implement Pilot Program N0D Implement full MEL Program N0D Completion date of the above Action Plan 3/28/83 D'
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III MANAGEMENT SUPPORT SYSTEM l
III.3. E CORRECTIVE MAINTENANCE l
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4 III.3.E CORRECTIVE MAINTENANCE MAC 9.2.4 Provide an integrated maintenance program under the overall cognizance of the plant staff.
MAC 9.2.7 Develop standards for maintenance tasks which include:
Crew size Tools and materials required Planning Work sequencing Estimated hours Objective:
To improve the quality of station maintenance Milestones Action Plan Responsibility / Resources Date Status 1.
Review the existing refueling outage Planning Procedure R0-1 2.
Prepare revised plan for development of an integrated maintenance program 3.
Completion date of above action plan TBD 10/18/82
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III.5 G0ALS & OBJECTIVES MANAGEMENT SYSTEMS 1
III.5.A CORPORATE GOALS & OBJECTIVES COMMUNICATION PLAN 1
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III.5.A CORPORATE GOALS & OBJECTIVES COMMUNICATION PLAN MAC 9.2.3.A Establish that all activities within the Nuclear Organization's purview have as their sole justification the safe and efficient operation of PNPS-1.
MAC 7.2.1 Assign responsibility to assure that the Bulletin Book becomes a living document through periodic reviews and updates.
MAC 7.2.8 Provide management decisiveness and feedback to the Nuclear Organization.
Objective:
Keep Bulletin Book up to date.
Objective:
Open lines of communication.
. Milestones Action Plan Responsibility / Resources Date Status 1.
Request a review of Bulletin Book Galligan 2.
Request appropriate revisions to be Galligan submitted.
3.
Issue revised bulletins.
Galligan 4.
Assign Vice-President to keep book current.
Galligan l
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Establish weekly meetings and publish Harrington minutes of meetings.
6.
Require periodic reports upward, not only JEH/WDH of budget performance and plant output, but also of perfonnance against mutually acceptable goals. See III.S.b 7.
Establish monthly meetings with Executive Harrington/Galligan Office and rotate departmental attendance.
12/6/82 8.
Completion date of the above Action Plan
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III.5.B GOALS AND PERFORMANCE MEASURES MAC 4.2.3 Require periodic reports upward, not only of budget performance and plant output, but also of performance against mutually acceptable goals.
Objective:
To clarify organization objectives and goals and provide for making performance to goals known to management Milestones Action Plan Responsible / Resources Da te Status 1.
Generate specific goals & milestones All Managers Complete and promulgate l
2.
Generate appropriate reporting system All Managers Complete 3.
Measure performance against official All Managers goals and report 4.
Completion date of the above Action All Managers Complete Plan and l
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III.S.B.1 MONITOR TEMPORARY MODIFICATION PROCEDURE MAC 13.2.6 Monitor the Implementation of the temporary modifications procedure to ensure that the process is being performed satisfactorily.
Objective: To ensure the procedure is used properly.
Responsibility /
Milestones Action Plan Resources Date Status 1.
Change DNOR functions and responsibilities.
WDH 2.
Have DNOR, as a daily function, monitor use of the ALO
' procedure during preceding audit period.
3.
Inform operators of importance to review this item as they RDM make their rounds.
4.
Completion date of the above action plan, 11/29/82 M
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III.6 0UTAGE MANAGEMENT SYSTEM MAC 9.2.5 Consideration should be given to including an outage management function at the Station with responsibility for planning all future station outages.
Objective:
To develop and implement an effective program of outage management Milestones Action Plan Responsibility / Resources Date Status 1.
Define outage management function Machon Harrington Machon Harrington Machon Harrington l
Machon 2.
Develop contml systems and tools Machon 3.
Implement program Machon 12/6/82 T
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IV.1 TRAINING Master Objective: To provide training for the attached MAC Action Plans as appropriate.
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M IV.1 MAC 4.2.8 Appraise managers by their constructive use of this management tool. (Performance Appraisals)
Objective:
Provide Managers and Supervisors informative skills necessary to effectively conduct performance appraisals.
l Milestones l
Action Plan Responsible / Resources Date Status 1
1.
Schedule perfomance D. Sanford Complete l
Appraisal Training sessions 2.
Conduct workshops on the BECo D. Sanford /J. Cummings performance appraisal and merit salary review systems.
3.
Infom all Nuclear Organization D. Lange
/ Jackson personnel of how BEco merit salary system works as part of the Know Your Company Series.
9/1/82 4.
Completion date of the above Action Plan m
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MAC 6.2.4 Develop interpersonal skills of the nuclear organization management personnel to reduce inter-departmental friction and increase team building.
MAC 7.2.6 Assess the causes of interdepartmental friction and correct.
Objectives:
Deyelop team work concept through conduct Team Building Training for Department Managers and Group Leaders emphasizing interfaces and conflict resolution.
Milestones Action Plan Responsible / Resources Date Status 1.
Schedule initial team work and interface D. Sanford Complete i
exercise as part of the Foundations of l
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Conduct initial team work exercise.
V. Pembroke/D. Sanford Complete 3.
Conduct initial interface exercise
. L. Feersey/D. Sanford -
Completc I
4.
Develop conceptual outline for major D. Sanford l
workshop and submit to W. Harrington S.
Review, revise, approval of major W. Harrington j
concepttfal design 6.
Select consultant to facilitate D. Sanford/W. Harrington
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Workshop 7.
Establish dates for Workshop and D. Sanford/W. Harrington announce to participants 8.
Conduct Major Workshop D. Sanford/ Consultant 9.
Extend workshop through 1st supervisory level DT Sar> ford / Consultant 7
2/l/84
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Completion date of the above action plan.
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IV.1 MAC 7.2.2 Establish additional policies specifically designed to reflect corporate management's desire for operation of Nuclear Organi-zation.
i Objective:
All Nuclear personnel to understand Nuclear Organization Level Policies and Procedures.
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Action Plan Responsible / Resources Date Status 1.
Develop Plan and Schedule to train on D. Sanford
. Organizational Level Policies and Procedures 2.
Conduct briefing of all Department D. Sanford Managers, Group Leaders, Chief Engineers and Supervisors on these Policies 3.
Incorporate inforretion concerning D. Lange organizational policies into General Employee Orientation Training Program 4.
Non Supervisory employees to be briefed D. Lange on these policies through the Know Your Company Series 5.
Canpletion date of the above Action Plan 3/28/83 1
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M IV.1 MAC 6.2.1 Carefully monitor and support the new training program to assure successful, full implementation.
Objective:
To ensure the availability of quality training Milestones Action Plan Responsible / Resources Date Status 1.
Have. training issue weekly report D. Sanford Complete of training activities 2.
Have Sr. Vice President and Vice W. Harrington/J. Howard Presidents occasionally attend training sessions 3.
Continue with Hot License Class W. Olsen for R0 and SR0 candidates 4.
Conduct Audit Exam of license W. Olsen/PQS candidates to ensure they are prepared for the NRC exam 5.
Simulator training of the NRC W. Olsen/GE Simulator Exam at the GE Simulator 6.
NRC Exam administered W. Olsen/NRC 7.
Completion date of above Action Plan 8/2/82 i5
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POLICIES AND PRACTICES IMPROVING PERFORMANCE MASTER OBJECTIVE: To enhance perfonnance through promulgation and adherence to fundamental performance standards.
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IV.2 MAC 10.1.3 Strenghten the engineering staff by replacing contract engineers.
I Objective:
Establish and implement a long term Career Path Development Program designed to fill the majority of positions in the Nuclear Organization with personnel with PNPS plant experience.
Responsibility /
Milestones Action Plan Resources Date Status 1.
Develop conceptual paper and present to Department Mgrs.
D. Sanford/SDA for review.
2.
Revise and present development plan and schedule.
SDA/R. Vanstry 7/31/83 3.
Completion of Action Plan.
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MAC 4.2.6 Extend controls of individual employees by using an objective performance appraisal system.
MAC 4.2.7 Tie promotion and pay increases to such performance reviews.
MAC 4.2.8 Appraise managers by their constructive use of this management tool.
I Obj;ctive: Develop personnel and improve communications.
I Responsibility /
Milestones Action Plan Resources Date Status
- 1.. Instruct all vice presidents and managers that performance WDH Complete reviews are required.
2.
Adopt objective review method and train in use.
WDH 3.
Review on a sample basis performance review forms.
WDH 4.
Do not issue merit budgets until confinnation that performance WDH review interviews are complete.
5.
Completion of action plan.
Complete and Ongoing Ts
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IV.2 MAC 11.2.6 Evaluate the causes of interdepartmental conflict and take necessary corrective measures.
Obj:ctive:
Eliminate interdepartmental friction and hostility between QA and each other department.
Responsibility /
Milestones Action Plan Resources Date Status I
I 1.
QAM attend audit exit meetings and review draft Deficiency HFB Reports.
(Committed in response to PAB Report.)
2.,
QA revise the BEQAM II to improve policies and procedures HFB/RJK for reporting and responding to DR's.
(Comitted to in response to PAB Report.)
3.
Training Department provide training to all BECo Nuclear Organization and contractor personnel in BECo QA Program:
o Develop program.
Gilbert Assoc./ D.
Sanford (TD) & W.
Babineau (QAD) o Present to current personnel.
o Incorporate in training for future personnel.
D. Sanford (TD) &
(Comitted to in response to PAB Report.)
W. Babineau (QAD) 4.
Training Department train BECo management and supervisory D. Sanford personnel in management skills, interpersonal relationships, i
and team-building; course: "Results Management and Practice."
5.
QA investigate availability of audit or training in interpersonal W. Babineau l
relationships and team-building.
6.
QA hire audit personnel with operating plant experience HFB l
to the extent candidates are available in the time required.
(In conjunction with Action Plan 11.2.3.)
.5 7.
QA review auditing and audit reporting methods to identify F. L. Schellenger/
potential changes to enhance auditor-auditee relations, C. Oland, confidence, and respect.
D. A. Diotalevi w/ auditors
Responsibility /
Milestones IV.2 Action Plan Resources Date Status o Document results D. A. Diotalevi o Implement changes decided upon, if any.
D. A. Diotalevi 8.
QA consult with psychologist concerning availability HFB of courses / methods for auditor behavior conditioning /
modification.
9.
Completion of Action Plan.
9/27/82 8
IV.2 MAC 6.2.3 Provide time for employee training.
Objective: Give training the proper attention.
Responsibiltty/
Milestones Action Plan Resources Date Status 1.
Issue training policy memo related to currently scheduled WDH training.
2.
Training Manager to issue attendance sheets for all courses D. Sanford Complete
. to Vice President level.
3.
Upper levels of management take appropriate action.
4.
Completion of Action Plan.
8/30/82 I
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IV.2 MAC 14.2.3 Replace conflict avoidance with conflict resolution. Meetings s'iould end in actions, not just in problem 14.2.4 identification.
MAC 14.2.1 Encourage decision making, problem identification and solution.
Objective: To establish a NUORG Policy regarding meetings to aid in the resolution of problems addressed at NUORG meetings.
Objective:
Establish'who has action.
Responsibility /
Milestones Action Plan Resources Date Status 1.
Sr. Vice President-Nuclear issued Policy Statement on conduct WDH/ Dept. Mgrs, of meetings within the Nuclear Organization which will preclude meetings ending in problem identification without action assign-ments.
2.
Where necessary, issue minutes of meetings with actions listed.
WDH/JEH 3.
Sr. Vice President-Nuclear should issue Policy Statement directing NUORG personnel to elevate conflicts to next level of authority for resolution. This escalation should be implemented expeditiously to allow for timely resolution.
4.
Conduct training sessions on meetings.
D. Sanford 5.
Completion of Action Plan.
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l IV.2 MAC 5.2.4 Approve requisitions in a timely manner.
Objective:
Keep complement to authorized level.
Responsibili ty/
Milestones Action Plan Resources Date Status 1.
Review all personnel requisitions to budget ceiling in a timely WDH Complete manner.
2.
Personnel requisitions either approved or returned to appropriate WDH manager.
3.
In 1983, departments can maintain approved complement.
All Dept. Mgrs.
4.
Completion of Action Plan.
Complete and Ongoing 4
IV.2 MAC 8.2.7 Enforce discipline on missed commitment date Objective:
Provide a management system to provide adequate control.
Responsibility /
Milestones Action Plan Resources Date Status 1.
Design tracking system to give sufficient notice.
GKR/WDH 2.
Written explanation required for any missed date.
WDH 3.-
Completion of Action Plan.
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LV.2 MAC 6.2.2 Carefully consider plant-specific simulation training for licensed personnel.
Objective:
Detennine if plant specific simulator expense is justifiable Milestones j
Action Plan Responsible / Resources Date Status 1.
Review what is available on market.
Sanford/Harrington 2.
Review results of survey Sanford/Harrington
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3.
Determine if simulator is required Dept. Mgrs.
12/27/82 4.
Completion date of the above Action Plan 8
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IV.2 MAC 7.2.6 Assess the causes of interdepartmental friction and correct.
Obj ctive: Develop teamwork concept through conduct of Team Building Training for Department Managers and Group Leaders emphasizing interfaces and conflict resolution.
l Responsibility /
Milestones l
Resources Date Status Action Plan WDH 1.
Have weekly meetings of all managers.
WDH 2.
Reorganize to increase effectiveness.
WDH 3.
Take corrective action.
3/30/83 4.
Completion date of the above Action Plan l
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