ML20072K774
| ML20072K774 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/15/1994 |
| From: | Fenech R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18059B167 | List: |
| References | |
| PROC-940715, NUDOCS 9408300280 | |
| Download: ML20072K774 (177) | |
Text
PALISADES .
,em "I
(7" PALISADES NUCLEARPLANT PERFORMANCE ENHANCEMENT PLAN (P2EP) l l
Consumers Power Company PALISADES NUCLEAR PLANT July 15,1994 Approved By hM/Is 7.,v . f y
% e President - Nuclear Operathms Date pg F i C-
Pglisades Nuclear Plant Performance Enhancement Plan ,
TABLE OF CONTENTS l i
l Section Description Page
1.0 INTRODUCTION
. . . ................. ...............1-1 2.0 NUCLEAR OPERATIONS DEPARTMENT AND PALISADES -
MISSION STATEM ENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.1 Nuclear Operations Department Mission and Values . . . . . . . 2- 1 2.2 Palisades Mission and Vision . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.3 Palisades Performance Enhancement Plan (P2EP) . . . . . . . . . . 2-2 3.0 PALISADES PERFORMANCE ENIIANCEMENT PLAN PROCESS . . . . . ............ ......... . . . . . . . . . . . . . . 3-1 3.1 Performance lssues . . ... .......... . . . . . . . . . . . . . . . 3-1 i 3.2 Performance Enhancement Plan Development . . . . . . . . . . . . 3 -2 3.3 Layout of the Palisades Enhancement Plan . . . . . . . . . . . . . . . 3-3 4.0 IdEP ACTION PLANS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4- 1 4.1 I dEP Action Plan Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.2 Generic Action Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.3 Department Action Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5 5.0 IdEP PROGRESS REPORTING AND TRENDING . . . . . . . . . . . 5-1 5.1 ISEP Update Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.2 Tre n d i ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . s . . 5-1 2
6.0 P EP ADMINISTRATIVE CONTROL PROCESS . . . . . . . . . . . . 6-1 Figure 1 NOD Business Planning Integration Process Figure 2 I dEP Process Flow Chart Figure 3 Generic Logic Example Figure 4 IdEP/ Department Action Plan Flow
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Palisades Nuclear Plant Performance Enhancement Plan .
Appendix A Sample Action Plans Appendix B Objective Matrix ,
Appendix C I dEP Action Plan Index '
Appendix D Generic Action Plan Template Appendix E Department Master Action Plan Template Appendix F I dEP Action Plan Summary Descriptions and Task Listing t
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W SECTION
1.0 INTRODUCTION
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Palisades Nucleg Plant Performance Enhancement Plan .
1.0 INTRODUCTION
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The Palisades Performance Enhancement Plan (P2EP) was developed to address )
identified barriers to achieving the high level of performance that we desire. Recent l performance assessments indicate that, without an integrated, plant-wide Performance !
Enhancement Plan, effective and sustained performance improvements will not be l possible. This Plan is integrated across organizational boundaries and is applicable to all organizations that perform work affecting any aspect of the Palisades Nuclear Plant.
This Plan is based on the issues and barriers that were determined to exist at the time the Plan was developed. It is recognized that changing conditions and standards require flexibility in planning and implementation of actions such as those contained in this Plan. This Performance Enhancement Plan is a living document; it will be modified as necessary to continue to focus on both current and emerging issues. Performance indicators coupled with aggressive monitoring and feedback mechanisms will ensure that performance improvements are realized. Feedback from periodic monitoring of action completion and, more importantly, results, will allow for modification of this Plan as necessary to remain on track in achieving our overall performance goals.
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I SECTION 2.0 NUCLEAR OPERATIONS l DEPARTMENT AND PALISADES I
i MISSION STATEMENTS
Epajiudes Nuclear Plant Performance Enhancement Plan .
2.0 NUCLEAR OPERATIONS DEPARTMENT AND PALISADES l MISSION STATEMENTS i 2.1 Nuclear Operations Department Mission and Values The Nuclear Operations Department (NOD) Business Plan (1994-1996) provides upper-tier direction for aligning the organizations responsible to operate and support the Palisades Nuclear Plant. The Business Plan communicates the NOD mission:
Die hilSSION of the Nuclear Operations Department is the SAFE, COST-COh!PETITIVE, and RELIABLE generation of electricityfrom nuclear poner for the well-being of our communities and employees.
The NOD Business Plan also sets forth the following Organizational Values:
- Safety (nuclear, radiation, and industrial)
- Cost-Competitiveness
- Reliable Performance
- People
-* Community This upper-tier direction is translated and communicated down the organization into department busir.ss plans and management expectations.
2.2 Palisades Mission and Vision -
The Palisades Business Plan (1994-1996) states the Palisades Mission:
7he blission of the Palisades Nuclear Plant employees is to operate, maintain, and l
modify the plant to provide safe, cost-competitive, reliable, electricity to our customers now and in thefuture. We willstrive to provide our employees with the necessary tools to optimize theirperformance while maintaining the enhancing their job satisfaction.
The Palisades Vision Statement is:
As employees, we all would like to work in an environment where our l contributions are valued, respected, recognized and rewarded. The best way to l l
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achieve this is to serve our customers better and meet our stakeholders' expectations. We will be successful when:
We are viewed by our customers as a reliable, low-cost provider of electricity, We are viewed by senior management and investors as a valued asset, 1
We are viewed by our industry peers as a leader in achieving safe, competitive performance, We are viewed by our communities as a good and desired neighbor, We are viewed by ourselves as a great place to work, and We are viewed by our regulators as an organization that does not need to be given any extra attention.
2 2.3 Palisades Performance Enhancement Plan (P EP) 2 This Palisades Performance Enhancement Plan (P EP) is necessary in order to fulfill our -
2 mission and attain our visien. P EP will provide the management and supervisory staff at Palisades the necessary management tool to focus on performance improvement.
P2 EP will be transitioned into the NOD Integrated Business Planning Process (refer to Figure 1) while cach of the Action Plans are being implemented.
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Revision 0 2-2 Dated: July 15, 1994.
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SECTION 3.0 l i
2 P EP PROCESS
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Palisades Nuclear Plant Performance Enhancement Plan .
3.0 PALISADES PERFORMANCE ENIIANCEMENT PLAN PROCESS 3.1 Performance Issues The P 2EP has been developed because there are a number of issues needing resolution to achieve the Palisades Vision and fulfill the NOD and Palisades mission. This section documents the process used to develop the Plan to ensure not only that it is comprehensive but also that the actions are appropriately monitored and implemented.
Over the past year we have had several comprehensive internal and externally performed assessments of management and plant performance. In taking an introspective and critical look at what these assessments were telling us, it became apparent that our past approach lacked a sufficient degree of recognition and acceptance of the issues we face to be successful. Additionally, our past efforts lacked the integration and focus to meet our expectations. Also, our expectations lacked clarity, follow-through, and appropriate accountability mechanisms.
Although some progress has been made, a step increase is needed in order to achieve desired results. With that end in mind, the short-term strategy for addressing the Palisades perfonnance improvement issues began with identification and validation of performance issues which led to development of the P2 EP. The P 2EP is intended to be implemented over the next six to twelve months, while an enhanced NOD business planning process is developed. Although business plan revision is occurring, it is still expected to comply with the basic process concept illustrated as follows:
Sets Vision & Direchon Busess
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(svategy) .
Capital Pr$xts Level 4 Effort O&M Initiatives > Improvements LDE l- -erwesa > < ~ man eudgeted improvements The P2EP, the NOD Business Plan, the Palisades Business Plan, and individual
! departmental Action Plans ~will be intecrated via the more detailed revised business t planning process illustrated above. It is expected the revised business plan will address Revision 0 3-1 Dated: July 15, 1994-
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Paliudes Nuclear Plant Performance Enhancement Plan .
a broader rage of issues than those included in the current set of business plans. The organizational values in the current business plans include Safety, Cost-Competitiveness, Reliable Performance, People, and Community. Most imponantly, however, is the planning process will include features designed to ensure the root causes of Palisades performance issues are corrected and a sustained level of superior performance is achieved.
3.2 Performance Enhancement Plan Development The P 2EP was developed using a process that:
- Determines and continuously validates the performance issues through the use of root cause/ common cause analyses.
- Arrives at common understanding of the most important issues, thereby resulting in a manageable agenda for performance improvement.
- Gains buy-in, enrollment, and commitment across the NOD organization.
- Supports development of meaningful Objectives and Action Plan; that, when implemented, resolve the performance issues.
- Integrates with the evolving business planning process.
- Engages NOD and Palisades senior management and provides monitoring, trending and feedback.
- Provides validation and verification by Action Plan sponsors A participative team process was used and continues to be used to develop and validate the issues (refer to Figure 2). Common understanding of the performance issues was reached through the use of workshops among a cross section of NOD personnel, representing various organizational levels and groups. The process developed Focus Areas, Goals, and Objectives necessary to reach and sustain a high level of performance in support of the Palisades Missior..
As stated before, the P2EP is a living docmnent. The plan will be updated as conditions and standards change, and as we learn and develop better tools and processes. For example, one of the high priority Objectives contained in this Plan involves the development of an integrated planning process. It is expected that development of such a process will impact how activities are prioritized, defined (scope and responsibility),
estimated, planned, scheduled and budgeted within NOD and Palisades. This, in turn, 2
will impact and enhance the implementation of the P EP. Appendix A includes two sample Action Plans. !
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Palisa les Nuclear Plant Performance Enhancement Plan ,
The Performance Enhancement Plan makes use of past business plans, current performance information, and newly developed issues, Objectives, and Action Plans. 1 While some of these activities have been done before, the current plans were developed I using participative, team techniques to foster buy-in, commitment, and enrollment. This I focused development, coupled with the commitment from the management team, l provides the foundation for our high level of confidence in the success of this program. )
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3.3 Layout of the Palisades Enhancement Plan '
l The Palisades Performance Enhancement Plan consists of Focus Areas, Goals, and l Objectives that address performance issues facing the plant. Appendix B provides a l matrix of Focus Areas, Goals and Objectives arranged as follows: l
- Leadership and Management
- Programmatic Improvement
- Human Performance ,
- Culture
- Critical Assessment
- Plant Condition Under each Focus Area is a summary of the performance issues that were determined to ;
exist in that area, followed by a bricf Goal describing the desired future state. One or l more Objectives have been identified to b eak the Goal into manageable tasks.
Collectively, fulfilling the Objectives supporting a Goal is neces::ary to attain the desired state. Additionally, the Objectives address one or more performance issues that ,were identified. Meeting the Objectives will address the performance issues in that Focus Area and the Goal will be achieved.
Finally, a comprehensive and specific P2 EP Action Plan is prepared to achieve cach Objective. Action Plans are discussed in Section 4.0.
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SECTION 4.0 P2 EP ACTION PLANS
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4.0 P2 EP ACTION PLANS 4.1 P'EP Action Plan Index Appendix C is the current Index of ISEP Action Plans 4.2 Generic Action Plan Each Action Plan uses a standard template for consistency. Action Plans contain statements of the actions taken to address performance objectives, schedule, resource needs, responsibility, deliverable products and performance indicators. Appendix D is the Generic ISEP Action Plan Templates. The Action Plan content is as follows:
4.2.1 Cover Page QljsEllysj - The assigned number and description from Appendix C Sjiblidfj - The sponsor is the single most responsible individual who must achieve the objective. This person develops and implements the Action Plan, often as a matrix project manager who draws upon a team of multiple departments for resources.
Pyyyfyj(((Qy@jjyB)) - Selected from: 1 = High,2 = Medium, or 3 = Low
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@$jjil6]p[t6j - The completion date for the last activity in the plan. Most often this is the expected completion of the validation and verification activity which assesses the degree of effectiveness of the Action Plan.
Qj[8 - The effective date for the Action Plan or subsequent revision of the Action Plan.
$!jpfl6fe~Bldbid - Approval signatures for the Action Plan by the Management Sponsor, P2 EP Manager, Plant General Manager, and Director NOD Services.
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4.2.2 1.0 Focus Area - Issue Summary The Issue Summary Section comes from the Objective Matrix, Appendix B. These summaries are a compilation of observations from the participative team process discussed in Section 3.2. The summaries describe the current state.
l 4.2.3 2.0 Goal The Goal Section is a description of the desired future state for high level performance from the Objective Matrix, Appendix B. Refer to Appendix B.
4.2.4 3.0 Focus Area - Specific Issue Statement (s)
The Specific Issue Statement (s) Section presents the specific performance issues identified by the participative team process which have been mapped for resolution by Objective.
4.2.5 4.0 Objective The Objective Section is the specific Objective from the Objective Matrix.
4.2.6 4.1 Related Objectives Frequently, other Gbjectives are related and interdependent with the subject Action Plan Objective. This Section cross-references multiple Objectives related to the same issue.
As Action Plans are developed and activities are defined, related Objectivel interface or cross-tie the activities. These interfaces are vital to the integrated planning of Action Plan activities.
4.2.7 5.0 Action Plans This section presents the summary statement of how the Objective is to be accomplished. This statement is the summary of the content of the individual activities which are stated in the following Sections.
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Egliudes Nuclear Plant Performance Enhancement Plan .
4.2.8 Section 5.1,5.2, etc. Action Plan Activities Action Plan Activities describe the logical steps required to accomplish the Objective. Activities chosen by the sponsor identify the work tasks. Activities must sequence or parallel other activities within the subject Action Plan. They must allow for interface (integration) with activities in other Action Plans. They must be understandable for outside review.
The Action Plan Section activity format includes:
A descriplign of what is being done or what the action is.
Estimstud]diatioh - the elapsed time in work days to perform the activity. A week is 5 days; a typical month is about 22 days.
$MnitedMy@p@Qp(if/A@licablc - usually externally imposed milestones, meetings, submittals, deadlines, etc.
ByEdWE@nirsd[ytitljjEstimdted Manhoufs - the estimated manhours to perform the work broken down by type of employee, department and frequently by individual.
RrijpM}@jtllit'Y - the priority for each activity. It often differs from the Priority of Objective, but still uses the same scale: 1 = High, 2 = Medium, 3 =
Low.
$@p@Mb1pyhdijiddhi - the single person responsible for getting the individual Action Plan Activity work done. This person may be different from the sponsor.
This person is the single point of accountability for providing accurate status of the activity.
i 4.2.9 6.0 Deliverables Deliverables are the measurable product or output resulting from the Action Plan ,
activities. Examples include: draft business plan, process flow chart, new or '
revised directives / procedures / guidelines, schedule of meetings or presentations, self and independent assessments, lesson plans and training mc4uler, etc.
4.2.10 7.0 lessons learned lessons Learned are insights gained during the development or implementation of .
Action Plans. Lessons learned are worthwhile experiences which can benefit the l 2
P EP process by providing feedback to management.
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4.2. I 1 8.0 References References are relevant information sources. They can be assumptions or bases for estimates, INPO research results or industry data or comparable plant data.
4.2.12 9.0 Perfonnance Indicators Performance Indicators are relevant indicators that Objectives are achieved. The indicators should show that actions are executed effectively while meeting quality requirements. Examples include plant performance: SALP, Capacity Factor, Production Expense, or safety statistics. Other examples include training head counts, test scores, closure of Action Plan Activity tasks, documented surveys, or contractor cost and schedule reports.
4.2.13 10.0 P EP Action Plan Verification Checklist 2
This section provides a checklist for the sponsor which verifies comprehensive preparation of his Action Plan. A back check is provided by the P 2EP Manager.
4.2.14 11.0 Closcout This section provides the sponsor's statement that the Action Plan activities have been executed with relevant deliverables. Where appropriate, continuing activities are dispositioned with statements that the Action Plan phase has been completed and a transition was effected for lorg term or permanent institution into directives, guidelines, or procedures.
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4.2.15 Appendices This section contains the relevant project controls tools for each Action Plan as follows:
Action Plan Activity Table (Update Report)
Action Plan Activity Bar Chart Action Plan Logic Diagram (refer to Figure 3) 4.3 Department Action Plan Extensive planning already exists in NOD and Palisades departments in addition to P 2EP Action Plans. Palisades managers prepare Department Master Action Plans to implement P2 EP initiatives and to account for and plan other improvement initiatives.
Figure 4 illustrates the Department Action Plan Flow Diagram. Appendix E is the Department Master Action Plan Template.
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SECTION 5.0 P2EP PROGRESS REPORTING AND TRENDING l
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5.0 P EP PROGRESS REPORTING AND TRENDING ;
5.1 P EP Update Process 2
l The P2EP group functions as the project controls organization to provide progress and trending information to Senior Management, Sponsors, Department Managers, and employees. Appendix F contains an Action Plan Summary Description and an Action Plan Task Listing. The update process starts with an update report being distributed to Action Plan Sponsors and Department Managers. The update is a set of questions:
- Is the plan still valid
- Which activities have actual starts and completes
- What are the remaining durations of activities not completed
- What responsible individuals or resources have changed
- What logic changes are app.opriate, especially if the plan has changed The answers to those questions are the marked-up update reports or re-drawn logic diagrams which are input to the scheduling software, processed and analyzed, and the resulting output is distributed as progress / trend reports for management. New update reports are produced and cycled again to the sponsors and responsible departments for the next update. Frequency of the update cycle is monthly.
5.2 Trending The overall progress of each Action Plan will be trended monthly by reviewing the production results or work. completed, and the forecast of completion by the Action Plan Sponsor against the target schedule (as originally or currently set by Senior Manhgement with the Action Plan Sponsors concurrence). Variances in scheduled completion, product quality, issue identification and resolution will be reported to the Action Plan Manager through Senior / Executive NOD Management by exception.
Revision 0 ' 5-1 Dated: July 15, 1994
l SECTION 6.0 P2EP ADMINISTRATIVE i CONTROL PROCESS l I
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6.0 I EP ADMINISTRATIVE CONTROL PROCESS 6.1 PURPOSE The purpose of this administrative control process is to establish the requirements for use, revision, distribution, reporting and tracking status of Palisades Performance Enhancement Plan (P2 EP) implementation.
6.2 SCOPE This administrative control applies to all personnel involved with work activities at Palisades.
6.3 CONTROL PROCESS A. Use of P2 EP 2
- 1. The P EP is a list of improvement initiatives being developed and implemented by a group of approximately two dozen specific Action Plans. Information contained in each P2EP Action Plan includes the responsible Action Plan sponsor or owner and a summary of the actions being implemented by the !
Action Plan. For each Action Plan, acdvity (task), the detailed actions to implement the Action Plan, the individual responsible for performing each activity and the resources required for each activity are listed. P2 EP is a living document IJso used to identify emergent work activities, status improvement work, and to keep management apprised of Action Plan progress. Changes to Action Plans, validation and verification, and closure of itcms in P2EP Action Plans will occur only after appropriate senior management review and approval.
Extensive work already exists in Palisades depanments in eddition to I*EP.
Department Master Action Plans are being developed to account for and plan other improvement initiatives.
- 2. P2 EP Action Plans are categorized by focus areas as follows:
- a. Leadership and Management
- b. Programmatic Improvement
- c. Human Performance
- d. Culture
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- f. Plant Condition I B. Revision to IdEP Action Plans 2
- 1. Any P EP Action Plan Sponsor or department-level or higher manager may l request a revision to P 2EP Action Plans.
- 2. This will normally occur by marking the desired changes on a copy of the ;
p2EP Action Plan and transmitting it with a signed P2 EP Input Form to the l P2 EP Manager.
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- 3. The P EP Manager will obtain any required approvals and, if the proposed ,
change is approved, arrange for the Action Plan and associated documents to l' be revised. If the proposal is not approved, he will provide feedback to the requestor.
C. Distribution of the ISEP Status and Trends
- 1. P2 EP will be updated and copies distributed to all department-level and higher managers.
- 2. Additionally, the P EP 2 may be distributed as part of the Palisades Business Plan to a controlled distribution list. The Palisades Business Plan is updated periodically to reflect accumulated P2EP Action Plan changes.
D. Emergent Issues
- 1. Anyone may identify an emergent item, obtain approval from responsible P2 EP Action Plan Sponsor and or department level manager, and submit the request to P2EP Manager using the P2 EP Input Form.
- 2. Such items may be added to P2EP if they meet the following criteria:
- a. The activity is designed to address a significant weakness which impacts or compromises safety and quality.
- b. The issue is complex and affects multiple organizations.
- c. The initiative is an externally identified improvement which Palisades concurs with.
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Palisades Nuclear Plant Performance Enhancement Plan ,
l E. Approval of Changes to P EP Action Plans 2
- 1. Proposed changes to P2 EP require the following approvals:
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- a. Changes to the Focus Areas or Goals require the concurrence of Palisades i Safety and Licensing Director and the P2EP Manger, or as designated by l the Vice President of Nuclear Operations (VP-NOD).
- b. Changes to P2 EP items require the approval of tne Action Plan Sponsor l and P2EP Manager. !
- c. Changes to Departmental Master Action Plans require the approval of the responsible department manager.
F. Reporting the Status of P EP 2
- 1. Action Plan Sponsors are required to provide status updates (e.g. starts, completions, deliverables) monthly to the P2 EP Manager.
- 2. The P2EP Manager updates P2EP and provides the information to Palisades department-level and higher managers and to the Action Plan Sponsors.
- 3. The P 2EP Manager provides summary information on P 2EP trends and progress to senior site management at least once a month.
2 G. Closure of P EP Action Plans
- 1. Closure of P2EP Action Plan items are documented in the Action Plan and forwarded to the P 2EP Manager for closure action.
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P2 EP INPUT FORM ,
To: P2 EP Manager From:
Subject:
P 2EP -
TYPE OF IdEP CIIANGE NEW
__. CIIANGE/ DELETION
__ VERIFICATION AND VALIDATION
_ CIASEOUT Issue for P2EP Consideration:
Root Cause Necessary to Perform _ NO _._ YES (If YES, please attach)
Action
Description:
Resources Required: ,
Priority Category: -
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' Requestor Date Action Plan Sponsor Date
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P2EP Manager Date
5 Figure 1. NOD Business Planning Integration -
Figure 2 P2EP Process Flow Chart Figure 3 Generic Logic Example Figure 4 P2 EP/ Department Action Plan Flow i
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- P2EP fn gress Transition P:EP 4 40 to Department
' Master Action Plans 3 ,
Figure 4 P2EP ACI' ION PLANS p2{p/pppgp{geng Action Plan Flow 0.0 CPCo Response to NRC DET & P:EP Development and implementation Irmiership end Managesnent
, [ ; ,
1.1 Establish Strategic Direction = . _ . _ . , _ summmes : ,
1.2 Establish Clear Roles & Responsibilities . m..,,_,._ , ,, ,
1.3 Establish Aligned Management Expectations & Standards . _ . . _ . _ ; ,
1.4 Nablish a Management Development Program 1.5 Define Management Inbnnation Needs 1.6 Enhance Control of Contractors & non-NOD CP Organizatmns
> PRIORITIZATION 7 [Z.:
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1.7 Enhance Communications with Stakeholders '
- ~ " - - ~ ' ' ' "
1.0 Enhance Community Involvement f l Programmatic In'provement 2.1 Determine Scope of Work 2.2 Establish an Improved Planning & Prioritization Process P 2.3 Improve Corrective Action Process .
2.4 Implement an Enhanced Modification Proces, Action Work ~
2.5 Establish a Management Information System Scope Logic, P2EP ACTION PLAN ACTIVITY STATUS 2.6 Enhance the Operability Determination Process Duration ^= m *"a 2.7 Establish a Root / Common Cause Program llaman Performance (Elapsed = ::
3.1 Enhance Employee Knowledge and Skills time) and ;:l :
3.2 Irnprove Site Facilities Resource "::
Culture -.
4.1 Define and Communicate the NOD Safety Itilosophy Est.imated and ;,:;
4.2 Establish a Strong Sensitivity to the Plant's Design Basic Deliverables ~l; _.
Critical Assessment g =
9 -n lllll 5.1 Establish Critical Self-Assessment as a Norm for Line Organizations 5.2 Enhance the Quality of NPAD Assessments h "!
5.3 Improve the Effectiveness of the Assessment Function %ll -
Plant Condition *:; ""
6.1 Establish a Program to Improve Plant Design Margin ;; _
ll:::
ACTION PLAN LOGIC .lber ac 'ma l u a,,m-e-n a-m l DEPARTMENT MASTER ACTION PLANS ;j; -
- ~, r ;- l7 P'EP OPEN ACTIVITY As a== -+ees**
Improvement issues / Concerns (List) "
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Q P EP Initiations (List) G Program improvements (List) l m -
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Project Improvements (List) m i -, -4 l g m -
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D h W E M i: iib iiiih ' W I J-l J :-i
i APPENDICES
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Appendix A Sample Action Plans l i
Appendix B Objective Matrix l
Appendix C P2 EP Action Plan Index Appendix D Generic Action Plan Template Appendix E Department Master Action Plan Template Appendix F P2 EP Action Plan Summary Descriptions and Task Listing i
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O APPENDIX A SAMPLE ACTION PLANS i
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PALISADES NUCLEAR PLANT .
PERFORMANCE ENHANCEMFRf ACTION PLAN -
1 1
OBJECTIVE 1.1 ESTABLISII STRATEGIC DIRECTION l SPONSOR: RAFenech -
i PRIORITY (of Objective): !
COMPLETION DATE: June 3,1994 i March 25,1994 Revision 0 ,
i Management Sponsor-A
/ _- M P2 EP-Manager: # d40A #fdfidell Plant General Manager: %WAN NECO Manager: ' /6]Tiav/
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Palisades Nuclear Plant Perfonnance Enhancement Plan 1.0 FOCUS AREA - Essue Summary Leadership and Management NOD Management has not successfully translated and communicated the NOD / Palisades Vision down through the organization. Management has not clearly established appropriate and consistent standards and expectations. Roles and responsibilities are not aligned and clearly established or com nunicated. NOD in general and Palisades specifically are not " learning" organizations and do not solicit or welcome outside criticism or perspectives. A contributing cause lack of appropriate skills and experience.
2.0 GOAL Management provides a clear vision and sets direction throughout NOD for sustained Palisades Plant performance improvement. Expectations and roles and responsibilities are clearly communicated and foster an atmosphere where functional alignment, individual accountability, and organizational understanding are achieved and performance goals are met. Management knowledge and skills are state-of-the-art and the community and regulator fully value Palisades performance.
3.0 FOCUS AREA - Specific Issue Statement (s)
There is a vision, which is ineffectively translated to the work force, and thereby provides little context for day-to-day activities. (2B)
Palisades does not manage change well, including controlling change and eliminating unnecessary changes. The organization does not cope well with changing external conditions. (5) (part)
Programs are developed but true cultural and institutional change has not occurred in many cases. (For example, Operations personnel have not accepted the performance improvement programs implemented within the department. In general, a feeling of accommodation has been assumed with the provision that "this, too, shall pass.") (C)
Related: 4.3 2
i j'plisader; Nuclear Plant Performance Enhancement Plan 4.0 OBJECTIVE 1.1: Establish Strategic Direction
)
l Establish the vision, values, and strategic focus for the organizations that perform work in support of Palisades so that they are aligned and consistent with the corporation's vision, values, and strategy. 1
[ Input from Objective 4.1]
4.1 RELATED OBJECTIVES 2.2, 4.3 5.0 ACTION PLANS The Nuclear Operations Department (NOD) strategic direction, as conveyed in the Business Plan and CPCo/ NOD guide, will be reviewed and revised by the Vice President of NOD. The draft revision will be subject to review and comment by the direct reports to the Vice President of NOD to assure buy-in of the vision, values, strategies, and focus areas by the Palisades Management Team. The revised strategic direction will be communicated to NOD employees, Non-plant CPCo employees, contractors and vendors. Verification and validation will occur on an ongoing periodic basis to assure alignment is maintained and is consistent with CPCo corporate vision.
5.1 ACTION PLAN ACTIVITY i
Review and Revise CPCo/ NOD Guide as Needed .
Estimated Duration (in days) 15 Days Required Completion if Applicable N/A Resources Required with estimated manhours 20 MH - RAFerech Priority of Activity 1 Responsible individual: RAFenech 3
Palisades Nuclear Plant Perfonnance Enhancement Plan 5.2 ACTION PLAN ACTIVITY Distribute to Direct Reports for Review and Comment Estimated Duration (in days) 5 Days Required Completion if Applicable i Resources Required with estimated manhours 2 MH for each Direct Report -
RAFenech Priority of Activity 1 Responsible individual: RAFenech i
5.3 ACTION PLAN ACTIVITY Incorporate Comments Estimated Duration (in days) 4 Days Reouired Completion if Applicable N/A Resources Required with estimated manhours 2 MH - RAFenech Priority of Activity 1 Responsible individual: RAFenech 5.4 ACTION PLAN ACTIVITY ,
Print up New Booklets Estimated Duration (in days) 5 Days Required Completion if Applicable N/A -
Resources Required with estimated manhours 0 MH - RAFenech Priority of Activity 1 Responsible individual: MAEngle e
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~
Palisades Nuclear Plant Performance Enhancement Plan 5.5 ACTION PLAN ACTIVITY Develop Communication Schedule Estimated Duration (in days) 5 Days Required Completion if Applicable N/A Resources Required with estimated manhours 2 MH:
RAFenech RRFrisch TPHagan Priority of Activity 1 Responsible individual: RRFrisch 5.6 ACTION PLAN ACTIVITY Implement Communications Estimated Duration (in days) 5 Days Required Completion if Applicable N/A Resources Required with estimated manhours 4 MH - RAFenech Priority of Activity 1 Responsible individual: RAFenech 5.7 ACTION PLAN ACTIVITY Perform Verification and Validation Estimated Duration (in days) 5 Days Required Completion if Applicable N/A Resources Required with estimated manhours 1 MH - RAFenech Priority of Activity 1 Responsible individual: RAFenech e
5
Palisades Nuclear Plant Performance Enhancement I'lan 5.8 ACTION PLAN ACTIVITY Review results and make changes as necessary.
Estimated Duration (in days) 5 Days Required Completion if Applicable N/A Resources Required with estimated manhours 4 MH - RAFenech Priority of Activity 1 Responsible individual: RAFenech 6.0 DELIVERABLES l
6.1 DELIVERABLE - Action Plan Activity 5.1 1 1
Draft revision to 1994 Business Plan.
6.2 DELIVERABLE - Action Plan Activity 5.4 Issue revised 1994 Business Plan including pocket version.
l 6.3 DELIVERABLE - Action Plan Activity 5.5 Schedule for Communication meetings to disseminate 1994 Business Plan.
6.4 DELIVERABLE - Action Plan Activity 5.6 ,
Conduct communication briefings on 1994 Business Plan.
1 7.0 LESSONS LEARNED
8.0 REFERENCES
1994 - Palisades Business Plan 1994 - CPCo Business Plan !
~
1994 - CPCo Strategic Plan l
6 l
Talisades Nuclear Plant Performance Enhancement Plan 9.0 PERFORMANCE INDICATORS 9.1 Industrial Safety Accident Rate Start Date: Ongoing Frequency: Monthly Responsible: RRFrisch 9.2 Systematic Assessment of Licensee Performance Reporting Start Date: Ongoing Frequency: Monthly Responsible: RRFrisch 9.3 Net Capacity Factor Start Date: Ongoing Frequency: Monthly Responsible: RRFrisch 9.4 Production Expense $/MWII Start Date: Ongoing Frequency: Monthly Responsible: RRFrisch 9.5 Employee Survey Results ,
Start Date: Ongoing Frequency: Monthly Responsible: JCGriggs 9.6 Community Survey Results Start Date: Ongoing Frequency: Monthly Responsible: DAMcKee e
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Palisades Nuclear Plant Perfonnance Enhancement Plan 10.0 IdEP ACTION PLAN VERIFICATION CHECKLIST ACTION PLAN NO. I.1 ACTION PLAN DESCRIPTION APS ISEP 1.0 Objective Description v' 2.0 Priority /
3.0 List of Specific Activities y
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Necessary to Accomplish Objective (including V&V and closure.)
4.0 List of Specific Deliverables t/
5.0 Duration for each Activity in c/ ~ /
Days 6.0 Resources Identified for each ,j
/ -
activity by Individual or Type and Estimated Manhours to Accomplish Activity
/
7.0 Required Duc Date (if V Applicabic) by Activity _.
8.0 Sequence, Dependencies ,,-
/
Inter-Relationships Identified (Action Plan Logic -
Sequence and Inter-Relationships lletween Action Plans) 9.0 Industry References
/ /
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l'alisades Nuclear Plant Perfonnance Enhancement Plan 1
11.0 CLOSEOUT l
1 APPENDICES Action Plan Activity Table Action Plan Activity Bar Chart Action Plan Logic Diagram Action Plan Resource Table by Activity Resource Histogram 4
O 9
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Name Scheduled Start Duration Scheduled Finish P2EP 1/1/93 8:00am 651d 7/1/95 5:00pm 1.0 Leadership and Management 1/1/93 8:00an 397d 7/11/94 5:00pm 1.1 Establish Strategic Direction 3/28/94 8:00am 50d 6/3/94 5:00pm 1.1.01 Review and Revise CPCO/ NOD Guide as Needed 3/28/94 8:00am 15d 4/15/94 5:00pm l.1.02 Distribute to Direct Reports R&C 4/26/94 8:00am 5d 5/2/94 5:00pm 1.1.03 Incorporate Comments and FRC Issues 5/3/94 8:00am 4d 5/6/94 5:00pm 1.1.04 Print up New Booklets 5/9/94 8:00am Sd 5/13/94 5:00pm 1.1.05 Develop Communication Schedule 4/18/94 8:00am $d 4/22/94 5:00pm 1.1.06 Implement Communications 5/16/94 8:00am 5d 5/20/94 5:00pm 1.1.07 Perform Verification and Validation 5/23/94 8:00am $d 5/27/94 5:00pm 1.1.08 Present Findings 5/30/94 8:00am Sd 6/3/94 5:00pm l
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, _ _ _ _ _ _ _ _ _ _ _ ~ _ _ _ _ _ - . - - - - - - - - - - - - - - - - - - - - ' ' ~ ~- ' - - __ _ - _ _ _ _ _ _ _ _
1.1 Estabfish !
Strategic Direction 3 50d 3/28 6/3
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1.1.01 Peview and 1.1.02 Distribute to 1.1.03 Incorporate 1.1.04 Print up New 1.1.06 Imp!ement 1.1.07 Perferm nevise CPCOINOD Direct Heperts R&C Comments and FRC bocktets Communicat!ons Verification and 4 l21d 5 5d 6 7 Sd l4d 9 5d 10 5d 3/28 @/25 4/26 5/2 5/3 lS/6 S/9 5/13 S/16 S/20 S/23 S/27 4
1.1.05 Develop y Communication 1.1.08 Present 8 Sd Findings 4/26 5/2 11 5d 5/30 6/3 O
Page1
VI. FOCUS AREA 6 - Plant Cowlition ACTION PLAN 6.1 -- Establish a Pmgmm to Impmve Plant Design Afargin Action Plan 6.1, Establish a Program to improve Plant Design Afargin, has been assigned to the Nuclear Engineering and Construction Manager.
Past and present evaluations of system design margins will be reviewed to determine which recommendations will provide for maximum benefit to system margin. A list of system modifications and/or engineering analysis will be provided to management for approval. Approved system modifications and/or engineering analysis will be l incorporated into each department plan. Safety system design margins, system and :
component performance margins and material condition issues will also be determined, and based upon this determination, margin recovery efforts will be identified and prioritized.
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t PALISADES NUCLEAR PLANT ;
PERFORMANCE ENHANCEMENT ACTION PLAN OIMECTIVE 2.1: DETERMINE SCOPE OF WORK SPONSOR: D J MALONE PRIORITY (of Objective): I ,
COMPLETION DATE:
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April 4,1994 i
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l Management Sponsor: - [_ .
4dW4 P2 EP-Manager: ' <Ok H L T/ Shy Plant General Manager: -' 6, '\ he > <,
NECO Manager: N N/ [8!f4 '
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Palesades Nuclear Pland Performance FA-wnent Plan l
1 1.0 FOCUS AREA - Issue Summary Certain processes are not effective in achieving desired results. The process concerns range from ineffectiveness through implementation difficulties as follows:
- 1. NOD lacks an integrated cohesive process for the functions of strategic planning, issue management, resource allocation, scheduling, completion of .
work, closcout, and performance monitoring. Emerging issues are not handled well.
2.0 GOAL Processes are clear, user-friendly, and achieve desired results throughout the organization. The processes feed into an overall formal planning and prioritization process that integrates strategic planning, budgedng, and scheduling to effectively utilize plant resources. Management has easy access to the information necessary to monitor plant performance.
3.0 FOCUS AREA - Specific Issue Statement (s)
Note: This Objective represents a quick, up-front portion of Objective 2.2.
2 I
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Palisades Nuclear Plant Performanece Enhancement Plan 4
4.0 OlUECTIVE 2.1: Determine Scope of Work Identify all existing issues, actions, and projects above a specified resource threshold.
Prioritize and rank these items. Develop and implement a manageable subset of these activities to be included in the current scope of work. Important activities that do not attain a high enough priority will be considered for future years' work; activities below a specified priority will be abandoned.
[This Objective supports 2.2]
4.1 RELATED OBJECTIVES 1.5, 2.2, 2.5 5.0 ACTION PLANS A project team will be created to collect information on major existing initiatives, process improvement activities, non-routine tasks above a specified resource, proposed plant modifications and actions planned in response to internal and external commitments. A screening procedure will be utilized to categorize and prioritize identified work items. Results will be submitted to a management forum for review and approval. Items not meeting the predetermined benefit / priority threshold will be deleted or delayed. Delayed items will be incorporated into the integrated plant business planning process. Emergent issues will be similarly categorized and prioritized until P2EP Action Plan 2.2 is completed.
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i Palisades Nudcar Plant Perfor==re Enhancement Plan 5.1 ACTION PLAN ACTIVITY Define a proixt team that consists of members from each major department.
Obtain management concurrence.
Estimated Duration (in days) 4 Days Required Completion if Applicable April 4,1994 Resources Required with estimated manhours 2 MH (one person) -
NECO Operations Radiological Svs Maintenance Systems Engg Outage Planning JJFremeau 2 MH - An NPad representative will be requested to provide oversight, 2 MH - DJMalone Priority of Activity 1 Responsible Individual: DJMalone
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Patiudes Nucicar Pland Perfonnance FAnancement 1%n 5.2 ACTION PLAN ACTIVITY Collect information from all departments on: major existing initiatives (eg, Palisades Performance Enhancement Plan), process improvement activities, non-routine tasks above a specified resource, proposed plant modifications, actions planned in response to internal and external commitments.
Estimated Duration (in days) 7 Days Required Completion if Applicable April 6,1994 Resources Required with estimated manhours 8 MH (one person) -
NECO Operations Radiological Svs Maintenance Systems Engg Outage Planning JJFremeau 8 MH ~ An NPad representative will be requested to provide oversight.
8 MH - DJMalone Priority of Activity 1 Responsible Individual: DJMalone i
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Palisades Nudear Plad Perfe--F4w Plas l
5.3 ACTION PLAN ACTIVflT Identify existing commitments for activities identified in step 2.
l Estimated Duration (in days) 8 Days Required Completion if Applicable April 7,1994 Resources Required with estimated manhours 2 MH (one person) -
NECO Opemtions Radiological Svs i Maintenance l Systems Engg Outage Planning JJFremeau 2 MH - An NPad l representative will be l requested to provide oversight.
2 MH - DJMalone Priority of Activity 1 Responsible Individual: DJMalone I
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j'alisades Nuclear Ibrd Perfonnanct Enhancement Plan 5.4 ACTION PLAN ACTIVITY Utilize the screening procedure utilized in TJP94*003 (shown below) to categorize 2md prioritize all identified work items from Step No.2. Revise the screening procedure as determined necessary by the Project Team to support prioritization. Results shall be submitted to the management forum for review and approval.
Must Complete: These are activities such as regulatory commitments and projects with due dates which are considered non-negotiable.
Should Continue: These activities typically will remedy programs / processes in need of significant efforts (i.e. reengineering).
Deferable: These activities support areas needing improvement (i.e.
streamlining), but do not contain significant weakness.
CanceuDrop: The benefit of these activities is not sufficient to warrant further action or administrative action tracking the activity. Consideration must be given to the time the action has been carried, but not undertaken.
Estimated Duration (in days) 3 Days Required Completion if Applicable April 8,1994 Resources Required with estimated manhours 8 MH (one person) -
NECO Operations Radiological Svs Maintenance ,
Systems Engg Outage Planning UFremeau 8 MH - An NPad representative will be requested to provide oversight.
8 MH - DJMalone Priority of Activity 1 Responsible Individual: DJMalone 7
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PaGsades Nacicar Ptard Performance Dihancemerd Plan 5.5 ACTION PLAN ACTIVITY For items not meeting the determined benefit / priority threshold for work in the near term, develop a strategy for deletion or delay. Delayed items should be incorporated into the integrated plant business planning process being developed through Palisades Performance Enhancement Plan action 2.2.
Estimated Duration (in days) 4 Days Required Completion if Applicable April 13,1994 Resources Required with estimated manhours 2 MH (one person) -
NECO ,
Operations Radiological Svs Maintenance Systems Engg Outage Planning JJFremeau 2 MH - An NPad representative will be requested to provide oversight.
2 MH - DJMalone Priority of Activity 1 Responsible Individual: DJMalone m
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Palisades Nuclear Plant Performance F=h=<wncat Plan ,
5.6 ACTION PLAN ACTIVITY Communicate the results of the interim prioritization effort to all stakeholders including plant staff, supporting contractors, the NRC, INPO, and/or the State of Michigan as appropriate. The communication vehicle to plant staff shall be in the form of a singular list of prioritized activities. This communication shall include the reasons for deletion or delay of issues.
Estimated Duration (in days) 4 Days Required Completion if Applicable April 12,1994 Resources Required with estimated manhours Licensing Dept support for formal commitments.
MASavage for employee communications. DWRogers, Lead Priority of Activity 1 Responsible Individual: DJMalone 5.7 ACTION PLAN ACTIVITY Continue prioritization communication (Input from 2.2 - Phase I) l Estimated Duration (in days) 90 Days ,
Required Completion if Applicable N/A Resources Required with estimated manhours 104 MH - 2 people for 2 MH every 2 weeks Priority of Activity 1 i
Responsible Individual: DJMalone e
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talisades Nuclear Plant Perfor- am F=h==-est Plan l
5.8 ACTION PLAN ACTIVITY A management forum consisting of all major plant department managers and a NECO management representative will meet biweekly to categorize and prioritize emergent issues identified in step 4 until Palisades Performance I Enhancement Plan action 2.2 is completed. An NPAD representative will be '
requested to attend each meeting. '
Estimated Duration (in days) 191 Days Required Completion if Applicable Implementation of Palisades Performance Enhancement -
Plan action 2.2 :
Resources Required with estimated manhours 4 MH (one person) -
NECO Operations Radiological Svs Maintenance Systems Engg Outage Planning ,
JJFremeau 4 MH - An NPad representative will be ;
requested to provide oversight.
2 MH - DJMalone 1 Priority of Activity 1 Responsible Individual: DJMalone i
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Pahsades Nuclear Plant Performance Fmhancement Plaa 5.9 ACTION PLAN ACTIVITY Perform validation and verification that plant staff are working on appropriate activities as determined by the prioritization effort.
Estimated Duration (in days) Ongoing until 2.2 Phase I implemented Required Completion if Applicable Implementation of Palisades Performance Enhancement Plan action 2.2. ;
Resources Required with estimated manhours 2MH-Two Project Team meetings Priority of Activity 1 i
Responsible Individual: DJMalone 5.10 ACTION PLAN ACTIVITY ,
Transition Performance Enhancement Plan 2.1 action and output into Performance Enhancement Action Plan 2.2 .
Estimated Duration (in days) 2 months prior to P2EP 2.2 implementation Required Completion if Applicable N/A Resources Required with estimated manhours DJMalone Priority of Activity 1 Responsib!* Individual: DJMalone T
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I hkades Nuclear Plaid Pesformance F4-W Plan 6.0 DELIVERABLES l 6.1 DELIVERABLE Initial work list of tasks and programs by department ,
6.2 DELIVERABLE Aligned work list with tasks and programs department including:
a) short term priority b) responsible individual c) committed completion date 6.3 DELIVERABLE Two week look ahead of aligned task & program list 6.4 DELIVERABLE Transition plan to AP 2.2 including required overlap I 6.5 DELIVERABLE Disseminate interim administrative guideline and train applicable personnel 6.6 DELIVERABLE Results of validation and verification ,
7.0 LESSONS LEARNED
8.0 REFERENCES
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i IStisades Nuclear Ihnt Perform t2cc FAtancement Ibn 9.0 PERFOIGIANCE INDICATORS 9.1. Total number of actions completed during the monitoring period Start Date: May 8,1994 l Frequency: Monthly Responsible: Planning Manager 9.2 Percentage of commitments met by due date relative to those w.ith due dates during the monitoring period.
Start Date: May 8,1994 Frequency: Monthly Responsible: Planning Manager 9.3 Percentage of commitments with due date extensions relative to those with due i dates during the monitoring period. I l
Start Date: May 8,1994 ,
Frequency: Monthly l Responsible: Planning Manager 4
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Palisades Nuclear l'12nt I'crformance Enhancement l1an 10.0 I dEP ACTION PLAN VERIFICATION CIIECKLIST ACTION PLAN NO. 2.1 ACTION PLAN DESCRIPTION A3k P'EP 1.0 Objective Description /
/
2.0 Priority -
f p
3.0 List of Specific Activities /
Necessary to Accomplisti /
Objective (including V&V and closure.)
/'[ /
f 4.0 List of Specific Deliverables f r
5.0 Duration for each Activity in ? /
Days 7/ / -
6.0 Resources Identifia5 for each / t/
activity by Inlividual or Type p '
and Estimated Manhours to '
Accomplish Activity j/
7.0 Required Due Date (if
/ -
Applicable) by Activity ,/[ '/
/
/
8.0 Sequence, Dependencies Inter-Relationships ,,'// / '
Identified (Action Plan Logic Sequence and Inter-Relationships Iletween Action Plans) i or+# 7 9.0 Industry References $k ^
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Ealisades Nirlear I' lard l'erformarre IWrarremend 11an 11.0 CII)SEOUT APPENDICES Action Plan Activity Table Action Plan Activity Bar Chart Action Plan Logic Diagram Action Plan Resource Table by Activity ,
Resource Histogram O
15
PecP ,
iD Name Scheduled Start Duration Scheduied Finish 81 2.1 Determine Scope of Work j 3/28/94 S:00pm 200d 1/2/95 S20pm 82 2.1.01 Define a project team 3/30G4 8:00am 4d 4/4/94 S$0pm 83 2.1.02 Cottect Information from su departments 3/28/94 S:00pm 7d 4/G,94 5:00pm 84 2.1.03 Identify existing commitments for actMtles 3/28/94 S:00pm 8d 4/7/94 S:00pm 85 2.1.04 Priorit!ze work items with TJP94*003 4/6/94 8:00am 3d 4/8!94 S:00pm 88 2.1.05 Develop delayed item strategy 4/8/94 820am 4d 4/13/94 S:00pm 87 2.1.06 Communicate priorinzation to stakeholders 4/7/94 8:00am 4d 4/12/94 S:00pm BS 2.1.07 Continus prioritization commun! canon 4!13/94 8:00am 90d BI16!94 S:00pm 89 2.1.08 Management fo/um prioritize emergent issues 4/11/94 8:00am 191d 1/2/95 S:00pm 90 2.1.09 Verification and Validation: plant staff working priorttles 8/16/94 8:00am 1d 8/16/94 S:00pm 91 2.1.10 Transition AP2.1 to AP2.2 S/25/94 8:00am 60d 8/16/94 S:00pm i .
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4/S/9 3 om 2.0 Process imcrevement 80 l328d
'3!1 I6/1 2.1 Deterrtnne Scope of Work B1 2OOd 3/28 1/2 2.1.01 Define a croject team i 2.1.02 Cottect 2.1.04 Prioritize 2.1.08 Management 82 4d M information from all , work items with forum prioritize 3/30 4/4 83 7d 85 3d 89 191d 3/28 4/6 4/6 4/8 4/11 1/2 mr 2.1.03 Identify 2.1.05 Develop existing delayed item 84 8d 86 4d l 3/28 4/7 4/8 4/13 mr 2.1.06 2.1.07 Continue Communicate prioritization 87 4d 88 90d 4/7 4/12 4/13 8/16 1r 2.1.09 Verification 2.1.10 Transition and Validation: plant AP2.1 to AP2.2 90 Id 91 60d 8/16 8/16 5/25 8/16 t
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APPENDIX B OBJECTIVE MATRIX 5
I
PERFORhf ANCE ENITANCEhfENT PLAN FOCUS AREAS, GOALS AND OBJECTIVES - July 8,1994 FOCUS AREA GOAL OBJECTIVES LEADERSTIIP AND MANAGEMENT h1anagement provides a clear 1.1 Establish Strategic Direction ,
vision and sets direction Establish the vision, values, and strategic focus for the organizations that perform work in NOD Management has not successfully throughout NOD for sustained support of Palisades so that they are aligned and consistent with the corporation's vision, translated and communicated the Palisades Plant performance values, and strategy.
NOD / Palisades Vision down through the improvement. Expectations [ Input from Obiective 4.1]
organization. Management has not clearly and roles and responsibilities established appropriate and consistent are clearly communicated and 1.2 Establish Clear Roles and Responsibilities standards and expectations. Rolet and foster an atmosphere where Clearly establish the roles and responsibilities for those individuals performing work in responsibilities are not aligned and clearly functional alignment, support of the Palisades Nuclear Plant. Align the organhational roles and responsibilities established or communicated. NOD in individual accountability, and and adjust the organizational structure, if necessary, to clarify understanding and improve general and Palisades specifically are not organizational understanding performance. Communicate the roles and responsibilities and monitor employee
" learning" organizations and do not solicit are achieved and performance understandmg.
or welcome outside criticism or goals are met. Management 1.3 Establish Aligned hianagement Expectations and Standards perspectives. A contributing cause includes knowledge and skills are Clearly establish in a standard format NOD Management's expectations and standards for
!ack of appropriate skills and experience. state-of-the-art and the organizations that perform work in support of Palisades. Communicate these expectations community and regulator fully and standards with periodic re-emphasis and monitoring of employee understanding. I value Palisades performance.
Ensure that safety is first over cost and schedule an3 that this principle is established, understood, and practiced.
1.4 Establish a Afanagement Development Program Establish a leadership and management development program for personnelin positions of authority, from first line supervisors to the department managers. Include an initial assessment of the incumbent's skills and abilities, a tailored management skills improvement program, a standardized leadership and management development program.
and a formalized set of performance expectations for each m magerial position.
Succession / rotation and hiring plans should be established that are consistent with corporate strategy and that have the capability to recognize the need to augment existing organizations with outside resources at alllevels.
1.5 Define afanagement Information Needs Establish a common set of performance indicators to support effective performance monitoring. Determine the information needs necessary to monitor performance and to
- track and trend actions, events, and issues affecting plant performance from the worker j level through the executive level.
IThis Obiective sutwrts Obiective 2.51 l
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, _ . - . . - , - _, . . - - =_ __ _._ - .-- . . _ . _ _ _ _ . _ - . - _ _-. _ - - ~ .- - ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
PERFORMANCE ENIIANCEMENT PLAN FOCUS AREAS, COALS AND OBJECTIVES - July 8,1994 FOCUS AREA COAL OBJECTnTS 1.6 Enhance Control of Contractors & Non-NOD CP Organizations .
Enhance CPCo control of the quality of work performed in support of Palisades by outside contractors and non-NOD CPCo organizations (i.e., work by personnel outside NOD).
t- Clearly establish and communicate expectations for the control of work performed by outside persons for both the NOD personnel overseeing the outside work and for the ,
outside employees themselves. Develop training guidelines to ensure contractors and others receive orientation and training, as applicable to the specific work being performed, on Palisades' policies, procedures, and practices important for performing error-free, quality work.
- 1.7 Enhance Communications with Stakeholders Establish plans for stakeholder communications. In particular, establish a Regulatory Communications Plan that supports clear interactions with regulatory organizations to ensure that they fully value the performance of Palisades.
1.8 Enhance Community involvement Establish a Community relations program that ensures that Palisades' employees are actively engsged in and supporting the surrounding communities. Communicate with ,
organizations within the surrounding communities to ensure that Palisades' role in the community is fully valued. ,
P i
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i PERFORMANCE ENHANCEMENT PLAN FOCUS AREAS, GOALS AND OBJECTIVES -July 8,1994 FOCUS AREA GOAL OBJECTIVES __
PROGRAMMATICIMPROFEMEVT Processes are clear, user- 2.1 Determine Scope of Work friendly, and achieve desired Identify all existing issues, actions, and projects above a specified resource threshold.
I results throughout the Prioritize and rank these items. Develop and implement a manageable subset of these Certain processes are not effective in achieving desired results. He process organization. The processes activities to be included in the current scope of work. Important activities that do not attain concerns range from ineffectiveness feed into an ove:all formal a high enough priority will be considered for future years' work; activities below a j through implementation difficulties as planning and prioritization specified priority will be abandoned.
follows: process that integrates [This Objective supports 2.2]
strategic planning; budgeting,
- 1. NOD lacks an integrated cohesive and scheduling to effectively process for the functions of strategic utilize plant resources. r planning, issue management, resource Management has easy access allocation, scheduling, comp!ction of - to the information necessary work, closcout, and performance to monitor plant performance.
monitoring. Emerging issues are not '
handled well; and
- 2. The Corrective Action Program is not well utilized and needs to ee improved; root and common cause analysis is not consistently used as part of the corrective action process; and
- 3. He Modification process is nct user-friendly and is too complex; and
- 4. Information systems are not effective in 2.2 Establish an Improved Planning and Prioritization Process supporting the monitoring and trending of Define and establish an NOD Integrated Planning Process (IPP) that uses the best practices performance indicators; and of other business units within CMS Energy and other utilities for the management of work performed at or in support of the Palisades Nuclear Plant. The purpose of establishing the
- 5. The effectiveness of the process used to IPP is to effectively manage resources in accordance with business plan objectives and make operability determinations and station performance goals. The IPP must evaluate, prioritize, plan, and link issues to communicate potential issues is v.eak and station performance and available resources to reach effective and efficient issue closure.
. not effectively implemented. [ Input from Objective 2.1]
2.3 Improve Corrective Action Process Improve the Palisades Corrective Action Process to make it more effective in identifying, trending, and monitoring corredive actions. Imtr the threshold for ireluding events in the cocctive action program so that non-consequential events are captured, analyzed, and trended. Provide clear criteria for performing human performance evaluations and root cause analyses. Provide explicit guidelines on the timeliness of corrective action imolementation and for verifyine the effectiveness of actions taken to r*revent recurrence.
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PERFORMANCE ENTIANCEMENT PLAN FOCUS AREAS, GOALS AND OBJECTIVES - July R,1994 FOCUS AREA GOAL OBJECTIVES 2.4 Implement an Enhanced Modification Process Implement the plant modification process improvement program. By employing user feedback, adjust the process to address concerns and thereby enhance overall usefulness and acceptance.
2.5 Establish a Management Information System Develop and implement a management information system to pmvide managem:nt the capability to monitor and feedback information appropriate to cech management level.
Develop and implement tracking and trending mechanisms that provide lock-ahead information, exception reponing, and adverse trend data for problems, actions, events, and other issues affecting the plant's performance. A consolidated Action Tracking and graded management reponing function should be a key pan of this system.
[ Input from Objective 1.51 2.6 Enhance the Operability Determination Process Enhance the Operability Determination Procus to ensure it is clearly defined so that safety issues are promptly and aggressively evaluated and appropriate individuals are aware of potential operability issues as they arise. Perform a performance and compliance based focused review that results in specific procedure revisions and associated training for applicable Palisades Technical Staff.
[ Input from Objectives 5.1, 5.2, 5.3, 6.1, 6,21 2.7 Establish a Root / Common Cause Process Develop a Root / Common Cause program, including resources necessary for effective implementation. Provide clear criteria for performing human performance evaluations and Root / Common Cause analyses. Enhance the overall effectiveness of the Palisades llPES program to reduce the number of recurring human performance events. Evaluate the existing resources to ensure effective implementation, formality of process and methodology.
[ Input from Objectives 2.3,5.31 HUMAN TERFORMANCE All employees are committed 3.1 Enhance Employee Knowledge and Skills to maximizing performance Improve the profusionalism, leadership and technical training to provide our employees There is no overall plan (such that called and meeting expectation. All the skills necessary to maximire performance and meet expectations.
for in SOER 92-01) to address human NOD employees have performance issues. Facilities are not appropriate facilities, tools, 3.2 Improve Site Facilities adequate to support the quality of work and processes to maximize implement the approved Site Facilitier Program to include the major Service Building expected and are an impediment to job performance and meet addition, maior renovations to existiru facilities, and the maior Support Building addition.
performance. expectations.
Objectives 1.2,1.3,1.4,4.1,4 'z also address human performance related issues t
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FERFORMANCE ENIIANCEMENT PLAN FOCUS AREAS, GOALS AND OBJECTIVES - July R,1994 FOCUS AREA GOAL OBJECTIVES CULTURE An environment exists where 4.1 Define and Communicate the NOD Nueicar Safety Philosophy all NOD employees know and Establish and nurture a strong nuclear safety culture by providing clear standards and Palisades has not established and nurtured demonstrate that safety expectations that nuclear safety and quality is a preeminent value at Palisades. This a strong nuclear safety culture that (nuclear, personnel, and includes a strong sense of professionalism, a questioning attitude, critical self-assessment encourages a questioning attitude, radiological) is paramount, is down to the worker level (self-checking), the need for continuous improvement, the need welcomes entical self assessment, values everyone's responsibility, and for procedure compliance, and a welcoming and accepting attitude toward outside suppon.
raising problems, is sensitive to stringent that teamwork and job Recognize and reward conservative actions and decisions. Develop and promulgate a protection of the design basis, stresses satisfaction are necessary for nuclear safety philosophy statement that will provide visible reenforcement of these procedural compliance, and makes achieving superior expectations and standards, conservative decisions without undue performence. [This Objective supports 1.1]
impact from cost and schedule considerations. The culture does not 4.2 Establish a Strong Sensitivity to the Plant's Design Basis encourage, recognize, or reward teamwork Establish clear ownership and responsibility for maintenance of the plant design basis in the day-to-day work place nor does it documentation. Increase management and employee awareness and understanding of the support an appropriately high level ofjob plant's design and licensing bases, Technical Specifications, reportability and operability satisfaction and quality of work life. requirements, and quality assurance requirements. Clearly establish and communicate the design authority for the plant. Instill a greater sense ofimportance for configuration control to ensure the integrity of the Palisades
- Design Basis.
CRITICAL ASSESSMENT Self- and independent 5.1 Establish Critical Self-Assessment as a Norm for Line Organizations assessments are used as The independent assessment function has not identified significant programmatic and There is a lack of critical self-assessment performance improvement technicalissues and has been ineffective in escalating findings to obtain resolution.
at Palisades. Management is not visible in tools and to anticipate and Integrate supervisory and management oversight activities, peer group inspection activities, the plant monitoring and overviewing plant avoid significant problems. multi-disciplinary review team efforts, and other assessment activities by personnel and activities. Supervisors do not spend organizations performing work for or at the plant in order to fully establish an environment enough time supervising activities at work that encourages undiluted input and feedback. Improve the self-assessment effectiveness of sites. The independent assessment organizations and communicate self-assessment expectations (i.e.; questioning attitude, self-function has not identified significant critical nature, zero rework, timeliness of corrective action, root cause analysis) at the programmatic and technical issues and has NOD, Palisades, and department levels. Provide training in self-assessment, human been ineffective in escalating findings to performance evalustion and root cause analysis techniques. Input should be obtained from obtain resolution from Senior / Executive outside organi-ations, including evaluating and benchmarking high-performing Management. organizations.
5.2 Enhance the Quality of NPAD Assessments Enhance the technical and assessment skills of NPAD personnel. Seek development and training opportunities through assignments with outside organizations. Obtain critical feedback from assessed organizations. Ensure that assessments are focused on true r$erformance issues by bent hmarkinc acainst industry leaders.
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PERFORMANCE ENIIANCEMENT PLAN FOCUS AREAS, GOALS AND OBJECTIVES - July 8,1994 i
! FOCUS AREA GOAL OBJECTIVES 5.3 Improve the Effectiveness of the Assessment Function Define, clarify, and strengthen the role of NPAD. Adopt the "Four Ixvels of Defense of Quality
- model as an aid in understanding and communicating the role ofindependent assessment in testing and probing the programmatic aspects of the organization. Integrate the NPAD activities with the new Management Safety Review Committee Chaner, as applicable. Strengthen the approach for resolving NPAD issues.
i l -PIANTCONDITION 6.1 Establish a Program to Improve Plant Design hfargin l ,
Plant systems and components Identify, prioritize and schedule material conditien issues, design margin issues, and long-
! There are material condition, equipment are in conformsnee with the standing equipment problems that create operator workarounds or accessibility problems.
l problems, and technical issues that design basis, maintained in Ensure that input is received from alllevels of the organization.
continue to occur in the plant as it matures. good working order, readily Issues need to be addressed to continue to and safely accessible, and j identify, maintain and improve the plant operator workarounds are at a
[ material condition. minimum.
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APPENDIX C P EP ACTION PLAN INDEX I
l Palisades Performance Enhancement Plan Action Plan Index Action Plan Action Plan Title 0.0 CPCo Response to NRC DET and P 2EP Development and Implementation 1.1 Establish Strategic Direction 1.2 Establish Clear Roles and Responsibilities 1.3 Establish Aligned Management Expectations and Standards 1.4 Establish a Management Development Program 1.5 Define Management Information Needs 1.6 Enhance the Control of Contractors & Non-NOD CP Organizations 1.7 Enhance Communications with Stakeholders 1.8 Enhance Community Involvement 2.1 Determine Scope of Work 2.2 Establish an Improved Planning and Prioritization Process 2.3 Improve Corrective Action Process 2.4 Implement an Enhanced Modification Process 2.5 Establish a Management Information System 2.6 Enhance the Operability Determination Process 2.7 Establish a Root / Common Cause Process 3.1 Enhance Employee Knowledge and Skills 3.2 Improve Site Facilities 4.1 Define and Communicate the NOD Nuclear Safety Philosophy 4.2 Establish a Strong Sensitivity to the Plant's Design Basis !
5.1 Establish Critical Self-Assessment as a Norm for line Organizations 5.2 Enhance the Quality of NPAD Assessments 5.3 Improve the Effectiveness of the Assessment Function 6.1 Establish a Program to improve Plant Design Margin j
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APPENDIX D GFJERIC ACTION PLAN TEMPLATE
t l
)
PALISADES dy em nsauami PALISADES NUCLEAR PLANT :
PERFORMANCE ENIIANCEMFRf ACTION PLAN OllJECTIVE:
SPONSOR: !
PRIORITY (of Objective):
COMPLETION DATE: !
t r
t i
July 8,1994 ;
Revision 1 l
l Management Sponsor:
ISEP-Manager:
Plant General Manager:
Director NOD Services: ;
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PalW Nuclear Plant Perforinance Enhancesneat Plan 1.0 FOCUS AREA - Issue Sununary ,
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2.0 GOAL 3.0 FOCUS AREA - Specific Issue Statement (s) 4.0 OIljECTIVE :
4.1 RELATED OllJECTIVES 5.0 ACTION PLANS l 5.1 ACTION PLAN ACTIVITY Estimated Duration (in days)
Required Completion if Applicable i Resources Required with estimated manhours Priority of Activity-Responsible individual: l 5.2 ACTION PLAN ACTIVITY Estimated Duration (in days) ;
~
Required Completion if Applicable Resources Required with estimated manhours j o
Priority of Activity Responsible individual:
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Pahsades Nuclear Pfad Performance Fahancement Plan 5.3 ACTION PLAN ACTIVITY Estimated Duration (in days)
Required Completion if Applicable :
Resources Required with estimated manhours Priority of Activity Responsible individual:
5.4 ACTION PLAN ACTIVITY Estimated Duration (in days)
Required Completion if Applicable Resources Required with estimated manhours Priority of Activity Responsible individual:
5.5 ACTION PLAN ACTIVr1T Estimated Duration (in days)
Required Completion if Applicable ,
Resources Required with estimated manhours Priority of Activity Responsible individual:
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l Meiades Nuclear Plant Performance FAancemend Ibn l
6.0 DELIVERABLES 6.1 DELIVERABLE 6.2 DELIVERABLE 6.3 DELIVERABLE 6.4 DELIVERABLE 6.5 DELIVERABLE 6.6 DELIVERABLE F
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Palisades Nuclear Plasd Performa we F=h==_. :: Plan 7.0 LESSONS LEARNED 8.0 REFERENCILS 1
9.0 PERFORMANCE INDICATORS 9.1.
Start Date:
Frequency:
Responsible:
9.2 Start Date:
Frequency:
Responsible:
9.3 Start Date:
l Frequency:
l Responsible: -
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9.4
! Start Date:
Frequency:
Responsible:
9.5 Start Date:
5
Palisades Nuclear Ptard Performance Enhancement Plan 10.0 2
P EP ACTION PLAN VERIFICATION CIIECKLIST ACTION PLAN NO.
ACTION PLAN DESCRIIrfION APS P2 EP 1.0 Objective Description 2.0 Priority 3.0 List of Specific Activitics Necessary to Acconiplish Objective (including V&V and closure.)
4.0 List of Specific Deliverables 5.0 Duration for each Activity in Days l
6.0 Resources Identified for each activity by Individual or Type and Estimated Manhours to Accomplish Activity 7.0 Required Duc Date (if Applicable) by Activity 8.0 Sequence, Dependencies Inter-Relationships i
Identified (Action Plan Logic Sequence and Inter-Relationships Between Action Plans) 9.0 Industry References 6
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l 11 ant DI_ise_%11Lutear Performance IWiancement 1%n 11.0 CLOSEOUT APPENDICES Action Plan Activity Table Action Plan Activity Bar Chart Action Plan Logic Diagram i
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APPENDIX E DEPARTWENT MASTER ACTION PLAN TEMPLATE
PA15ADES PALISADES NUCLEAR PLANT PERFORMANCE ENIIANCEMENT DEPARTMENT MASTER ACTION PLAN DEPARTMENT NUM11ER:
DEPARTMENT NAME:
MANAGER:
July 8,1994 Revision 1 .
Action Plan Sponsor:
Department Manager:
P2 EP-Manager:
i Ralisades Nuclear Pland IW Mader Action Plan I.0
SUMMARY
OF DEPARTMENT FUNCTIONS AND RESPONSIBILITIES I
2.0 DEPARTMENT MISSION i
i 3.0 DEPARTMENT SPECIFIC ISSUES ;
4.0 ISSUE SOURCE REFERENCES 4.1 FOCUS AREA: LEADERSHIP AND MANAGEMENT l i
A. Objective 1.1, Establish Strategic Direction l l
- 1. Communicate revised 1994 Business Plan to department staff. j
- 2. Communicate consistent vision, values, and strategic focus to i department staff. . l B. Objective 1.2, Establish Clear Roles & Responsibilities l l
- 1. Attend management training workshops. i
- 2. Communicate roles and responsibilities to department staff and moniter employee understanding.
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i Palisades Nuclear Piard Department Master Action Plan l i
l C. Objecdve 1.3, Establish Aligned Management Expectations & Standards l
- 1. Develop depanment Expectations & Standards document.
- 2. Communicate expectations and standards to department staff through the conduct of semi-monthly stand-down meetings.
- 3. Periodically monitor employee understanding of management expectations and standards.
- 4. Address department performance issues in department action plan.
D. Objective 1.4, Establish a Management Development Program
- 1. Develop a personal management development plan for department supervisors.
E. Objective 1.5, Define Management Information Needs
- 1. Communicate management information system performance indicator data to department staff.
F. Objective 1.6, Enhance Control of Contractors & Non-NOD CP Organizations
- 1. Communicate control of contractor process to department staff.
G. Objective 1.7, Enhance Communications with Stakeholders
- 1. Implement external communications standard.
H. Objective 1.8, Enhance Community Involvement
- 1. Implement departmental expectations for participation in community based activities.
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I Palhades Nacicar I*t.ird Departmend Master Action l'tari 4.2 FOCUS AREA: PROGRAAfAfATIC IAfPROVEAfENT l
A. Objective 2.1, Determine Scope of Work I l
- 1. Communicate results of interim prioritization effort to department staff.
- 2. Department managers, NECO representative and NPAD representative meet bi-weekly to categorize and prioritize emergent issues.
B. Objective 2.2, Establish an Improved Planning and Prioritization Process
- 1. Instruct department staff in interim work management process.
- 2. Provide department workload input to interim work management process.
- 3. Attend management meeting to validate inputs and resource estimates.
- 4. Attend management meeting to disposition current workload and excess work.
- 5. Managers and supervisors attend weekly meetings to manage the interim work management process.
- 6. Managers attend monthly meetings to validate process.
C. Objective 2.3, Improve the Corrective Action Process ,
- 1. Communicate improved Corrective Action Process to department staff.
- 2. Implement improved corrective action process.
D. Objective 2.4, Implement an Enhanced Modification Process
- 1. Communicate enhanced modification process to department staff.
- 2. Train appropriate department staff in enhanced modification process.
i Pakades Nedear Plant Decadment Mader Action Plan E. Objecuve 2.5, Establish a Management Information System
- 1. Pmvide functional feature input for management information system.
- 2. Participate in analysis of trend data.
F. Objective 2.6, Enhance the Operability Determination Process
- 1. Train appropriate staff on Generic Letter 91-18.
- 2. Train appropriate department staff on operability determination process G. Objective 2.7, Establish a Root / Common Cause Process Using HPES Program as a Basis ,
- 1. Train appropriate department staff on root / common cause process.
4.3 FGCUS AREA: HUAfAN PERFORAfANCE A. Objective 3.1, Enhance Employee Knowledge and Skills ,
- 1. Maintain appropriate department staff fully trained to perform job specific tasks.
B. Objective 3.2, Improve Site Facilities 4.4 FOCUS AREA: CULTURE ,
A. Objective 4.1, Define and Communicate the NOD Nuclear Safety Philosophy
- 1. Communicate nuclear safety philosophy to department staff.
- 2. Recognize and reward conservative actions and decisions.
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. i Enksades Nuclear Plant Ikoartment Master Action fian B. Objective 4.2, Establish a Strong Sensitivity to the Plant's Design Basis 1
- 1. Train appropriate department staff on design basis, safety margins, ;
and design basis control. i C. Objective 4.3, Establish a Strong Sense of Teamwork j l
- 1. Foster teamwork and team development amongst department staff.
l D. Objective 4.4, Enhance Job Satisfaction
- 1. Communicate the Job Well Done Program to department staff ,
(includes on-the-spot recognition and/or rewards).
- 2. Communicate achievements of department staff.
- 3. Discuss with each employee their performance semi-annually.
4.5 FOCUS AREA: CRITICAL ASSESSMENT A. Objective 5.1, Establish Critical Self-Assessment as a Norm for Line Organizations
- 1. Communicate and implement Self-Assessment Program within department.
- 2. Train appropriate department staff in self-assessment techniques.
B. Objective 5.2, Enhance the Quality of NPAD Assessments C. Objective 5.3, Improve the Effectiveness of the Assessment Function
- 1. Communicate role and responsibilities of NPAD to department staff.
e 5
Palisades &ckar Plad Ikpartmed Mader Action 1%n l l
l 4.6 FOCUS AREA: PIANT CONDITION j A. Objective 6.1, Establish a Program to Improve Plant Design Margin i
- 1. Provide input for plant design margin improvement.
B. Objective 6.2, Enhance the Quality of Design Basis Documentation
- 1. Communicate Design Basis Documentation expectations to department staff.
5.0 ACTION PLAN WORK SCOPE STATEMENTS ;
5.1 PROJECTS 5.2 PROGRAMS ,
t 5.3 LEVEL OF EFFORT i
9 6 :
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I'alisades Nuclear I'tard Departmerd Master Acti<m l' tan l
1 6.0 DEPARTMENT PERFORMANCE INDICATORS l 6.1 Start Date:
Frequency:
Responsible:
6.2 Start Date:
Frequency:
Responsible:
6.3 Start Date:
Frequency:
Responsible:
6.4 Stan Date:
Frequency: _
Responsible: ,
6.5 Start Date:
Frequency:
Responsible:
~
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a APPENDIX F P2EP ACTION PLAN SWMARY DESCRIPTIONS AND -
TASK LISTING
e P2EP ACTION PLAN
SUMMARY
DESCRIPTIONS
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L OVERVIEW The following are Action Plan Summaries for the Palisades Performance Enhancement 2
Plan (P EP). Each Action Plan identifies a single individual, usually a l Senior / Executive Manager, who has the responsibility and authority to assure the issues identified in the Action Plan are addressed by accomplishing the tasis in the Action Plan. Each Action Plan Manager also has the responsibility to verify and validate that the issues have been resolved and the Objectives in the Action Plan are being realized. Once this verification and validation activity has been accomplished, each Action Plan manager will present their findings to Senior / Executive Management for final review and appraisal. I ACTION PLAN 0.0 - Response and Close-Out of DET Action Plan 0.0, Response and Close-Out ofDET, has been assigned to the Diagnostic Evaluation Team Manager.
A DET Response Team was organized to coordinate with the Diagnostic Evaluation Team (DET) and provide tracking and response to the DET's requests for information (RFIs) and diagnostic evaluation observations (DEOs). The Palisades Performance 2
Enhancement Plan (P EP) has been developed which identifies areas for performance enhancements and Focus Areas, Goals, and Objectives for each of these areas and an Action Plan will be developed for each Objective. A root / common cause analysis will be prepared for the DEOs to ensure the resulting issues are captured within the scope of the Objectives.
The final NRC report on the DET evaluation will be reviewed, issues will be identified and classified and evaluated for root and common cause and issues will be dispositioned through either the P2 EP or other appropriate integrated tracking system such as the Corrective Action System. A response to the DET Report will be prepared, including a matrix of DET issues versus P2 EP Action Plans. The Palisades Performance Enhancement Plan will be reviewed and revised as necessary to address key issues from the root and common cause analysis and the DET Report.
Verification and assessment activities will be completed to ensure that Action Plan implementation is progressing, that none of the DET issues have been missed, and that the results meet management expectations.
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- 11. FOCUS AREA 1 - Leadership and Management ACTION PLAN 1.1 - Establish Stmtegic Direction Action Plan 1.1, Establish Strategic Direction, has been assigned to the Vice President of Nuclear Operation.;.
The Nuclear Operations Department (NOD) strategic direction, as conveyed in the Business Plan and CPCo/ NOD guide, will be reviewed and revised by the Vice President of NOD. The draft revision will be subject to review and comment by the direct reports to the Vice President of NOD to assure buy-in of the vision, values, strategies, and focus areas by the Palisades Management Team. The revised strategic direction will be communicated to NOD employees, Non-plant CPCo employees, '
i contractors and vendors. Verification and validation will occur on an ongoing periodic basis to assure alignment is maintained and is consistent with CPCo corporate vision.
ACTION PLAN 1.2 - Establish Clear Roles and Responsibilities Action Plan 1.2, Establish Clear Roles and Responsibilities, has been assigned to the Palisades Plant General Manager.
Existing role and responsibility data from plant departments and external sources will be collected and analyzed. This information will be used to propose revised organizational functions, accountabilities, and responsibilities for NOD management approval. Organizational changes will be communicated and implemented, including revised administrative procedures. Employee understanding, acceptance and support of organizational changes will be measured.
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' ACTION PLAN 1.3 - Establish Aligned Afanagement Erpectations and Staridards Action Plan 1.3, Establish Aligned Management Erpectations and Standards, has been assigned to the Director of Nuclear Services.
NOD management and department management expectations and standards for improved performance in nuclear operations will be developed. The standards,and expectations will be communicated to NOD employees through meetings and booklets.
Surveys will be conducted to assess employee understanding and compliance with the expectations and standards.
ACTION PLAN 1.4 - Establish a Afanagement Development Program Action Plan 1.4, Establish a Management Development Program, has been assigned to the Vice President Staff Assistant.
A model of management competencies and characteristics will be developed to be used as a basis for reviewing individuals in management and key technical positions.
A review ofindividuals reponing to Vice President of Nuclear Operations, Palisades Plant General Manager and key technical positions will be completed to determine extent to which these individuals meet requirements of their current positions. An assessment of all managers, supervisors and key technical persons will be completed using the Management Model.
Individual development needs of supervisors, managers and key technical persons will be identified and personal development plans generated. A managerial and key technical position curriculum to identify the expected progression of training and development activities for management and key technical positions will be developed.
ACTION PLAN 1.5 - Define Afanagement Irtfonnation Needs 4
Action Plan 1.5, Define Management Information Needs, has been assigned to the Director of Nuclear Information Management.
A set of performance indicators will be developed. Plans for broadcasting the performance indicator data will be developed and implemented. l
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ACTION PLAN 1.6 - Enhance the Control of Contractors and Non-Nuclear Operations Department Consumers Power Organizations Action Plan 1.6, Enhance the Control of Contractors and Non-Nuclear Operations Department Consumers Power Organizations, has been assigned to the Project Management Construction and Testing Manager.
A NOD directive and corresponding implementing document will be developed to provide single point accountability of contractors and non-NOD CPCo organizations performing work at Palisades. A stand-alone document for guidance on control of contractors and non-NOD CPCo organizations will be established. Technical staff training to re-enforce Plant Management expectations relative to Service Coordinators and non-NOD CPCo organizations will be implemented. Service Coordinators will be required to develop project specific goals and objectives which directly support Palisades results areas of safety, quality, reliability and economic performance. Input ;
from other utilities industries will be used to enhance the quality of the process. ,
ACTION PLAN 1.7 - Enhance Communications with Stakeholders Action Plan 1.7, Enhance Communications with Stakeholders, has been assigned to the Plant Safety and Licensing Director.
A communications plan will be developed and implemented. A process for monitoring communications will be developed, including monitoring of frequency of contacts, feedback from NRC, and reporting to the Vice President of NOD or the Plant General Manager. A daily report on n,magement and licensing issues will be developed and issued to key management and supervisory personnel. -
ACTION PLAN 1.8 - Enhance Community Involvement ,
Action Plan 1.8, Enhance Community Involvernent, has been assigned to the Senior ;
Public Information Specialist. i Opportunities for CPCo personnel to participate in community activities will be identified, and an on-going dialogue between Palisades and local officials will be created to facilitate regular meetings and foster closer ties. A citizens advisory board will be created. An outreach program for CPCo employees to provide educational presentations will be developed.
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III. FOCUS AREA 2 - Programmatic Improvement ACTION PLAN 2.1 - Determine Scope of Work Action Plan 2.1, Determine Scope of Work, has been assigned to the Palisades Plant General Manager.
A project team will be created to collect information on major existing initiatives, process improvement activities, non-routine tasks above a specified resource, proposed plant modifications and actions planned in response to internal and external commitments. A screening procedure will be utilized to categorize and prioritize identified work items. Results will be submitted to a management forum for review and approval. Items not meeting the predetermined benefit / priority threshold will be deleted or delayed. Delayed items will be incorporated into the integrated plant business planning process. Emergent issues will be similarly categorized and prioritized until P 2EP Action Plan 2.2 is completed.
ACTION PLAN 2.2 - Establish an Impmved Planning and Prioritization Pmcess Action Plan 2.2, Establish an improved Planning and Prioritization Process, has been assigned to the Director of Nuclear Services.
NOD planning needs will be determined and a planning /prioritizing model will be developed. An work management process will be implemented that includes work management, priority setting, collection of work as either level of effort (LOE) or greater than LOE, and ' cost accounting' (time-sheets). Management will be provided with performance reports and periodic management review meetings to discuss the work management system. An information technology application will be selected and implemented to support a long term implementation of the work management system.
ACTION PLAN 2.3 - Improve Corrective Action Pmcess Action Plan 2.3, improve Corrective Action Process, has been assigned to the Plant Safety and Licensing Director.
The existing NOD Corrective Action Process will be evaluated and revised based on organizational feedback, relevant internal and external issues, and processes used by other utilities.
ACTION PLAN 2.4 - Implement an Enhanced Modification Process Action Plan 2.4, Implement an Enhanced Modfication Process, has been assigned to the Manager Nuclear Engineering and Construction.
l A process improvement team will be established to create an understandable process j for designing and controlling plant modifications which assures a quality product and I eliminates non-value added activities. A modification process improvement plan will be developed which addresses: 1) consolidation and streamlining of existing modification processes, revising affected procedures, verification and validation, and providing training on new processes and procedures; 2) mechanisms to allow for automation of the enhanced modification process; and 3) modifications performance measurement program to track and trend specific indicators. A retired-in-place l procedure will be developed which defines the controls and evaluation methoc'oi: gy I that allows in-place retention of retired equipment versus physical removal of the l equipment.
ACTION PLAN 2.5 - Establish a Management information System Action Plan 2.5, Establish a Management Information System, has been assigned to the Outage Planning and Scheduling Manager.
A management information system will be developed and implemented to provide the capability to monitor and feedback information to all levels of the Palisades and NOD organizations.
ACTION PLAN 2.6 - Enhance the Opembility Detennination Pmcess Action Plan 2.6, Enhance the Operability Determination Process, has been as, signed to the Plant Safety and Licensing Director.
A uniform process for operability determination will be developed based upon the processes used at other plants and an analysis of relevant Palisades issues. Training will be provided on operability determinations and the new process as necessary.
ACTION PLAN 2.7 - Establish a Root / Common Cause Pmcess Action Plan 2.7, Establish a Root / Common Cause Process, has been assigned to the Plant Safety and Licensing Director.
This Action Plan will be developed in concert with Action Plan 2.3. An analysis will be performed to determine why Root Cause/ Common Cause/HPES activities have not been effective. Based upon this analysis, a revised process will be developed.
Training will be developed and implemented for management, technical staff, and other identified staff.
IV. FOCUS AREA 3 - Human Perfonnance ACTION PLAN 3.1 - Enhance Employee Knowledge and Skills Action Plan 3.1, Enhance Employee Knowledge and Skills, has been assigned to the Director of Nuclear Tmining.
Management and technical training will be provided for Palisades personnel.
Management development changes will be incorporated into the Maintenance Supervisor and Shift Supervisor accredited training programs. The Engineering Support Staff training program will be completed and advanced technical training will be provided. The abilities of the Training Department staff will be enhanced.
Verification and validation will be provided through maintaining INPO accreditation in all twelve accredited training programs and post training effectiveness surveys.
ACTION PLAN 3.2 - Impmve Site Facilitics Action Plan 3.2, Improve Site Facilities, has been assigned to the Administrative Manager.
The site facility expansion project will add 33,000 square feet to the Service Building and will improve the existing Service Building and Administration Building. Space for a dedicated Technical Support Center (TSC) with space for Shift Supervisors and Auxiliary Operators to perform desk work will be provided.
V. FOCUS AREA 4 - Culture ACTION PLAN 4.I - Define and Communicate the NOD Nuclear Sqfety Philosophy Action Plan 4.1, Define and Communicate the NOD Nuclear Safety Philosophy, has been assigned to the Vice President of Nuclear Operations.
The Vice President of NOD will review and revise the current vision, strategy and objectives regarding the safety philosophy at Palisades. The direct reports to the Vice President of NOD will communicate the safety philosophy.
ACTION PLAN 4.2 - Establish a Strong Sensitivity to the Plant's Design Basis Action Plan 4.2, Establish a Strong Sensitivity to the Plant's Design Basis, has been assigned to the Manager of Nuclear Engineering and Construction.
Design Basis authority, roles and responsibilities will be defined and related work procedures will be revised. Training will also be completed on design basis, safety margins and design basis control.
V. Focus Area 5 - Critical Assessinent i
ACTION PLAN 5.1 - Establish Critical Self-Assessment as a Nonn for Line l Organizations 1 Action Plan 5.1, Establish Critical Self-Assessment as a Normfor Line Orgarrizations, has been assigned to the Palisades Maintenance Manager.
Self-assessment processes from other nuclear utilities and from within Consumers l Power Company will be reviewed. Good practices from these programs will be incorporated into the revised self-assessment program. Implementation will be achieved through an administrative procedure which defines levels of self-assessment and provides a schedule for self-assessing, a reporting plan, management expectations for critical self-assessment and a self-assessment checking technique. Training will be provided on the new self-assessment programs. Verification and validation will be performed through periodic surveys of self-assessment activities and comparison with industry leaders.
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l ACTION PLAN 5.2 - Enhance the Quality of Nuclear Performance Assessment Department Action Plan 5.2, Enhance the Quality of Nuclear Performance Assessment Department, has been assigned to the Director of Nuclear Performance Assessment.
Actions will be taken to improve the skills and enhance the qualifications of Nuclear i Performance Assessment Department (NPAD) personnel. The job descriptions, qualification criteria, and training will be upgraded. Actions will also be taken to improve the Nuclear Performance Assessment Department assessment process. ,
Assessment standards, verification and validation and trend analysis will be ,
implemented. The Nuclear Performance Assessment Department product survey program will be revised to obtain critical feedback from assessed organizations.
ACTION PLAN 5.3 - Impture the Effectiveness of the Assessment Function Action Plan 5.3, improve the Efectiveness of the Assessment Function, has been assigned to the Director of Nuclear Performance Assessment Department.
A Management and Safety Review Committee has been formed to provide an outside perspective in the assessment function. Assessment function roles and responsibilities will be clearly defined and communicated to the Nuclear Operations Department.-
Root / common cause analysis skills will be improved and a tracking system will be established at Palisades. Periodically the Nuclear Performance Assessment Department will be self-assessed to determine the effectiveness of the critical assessment function.
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 0.0 CPCo Response to NRC DET 0.0 00 Start of APO.0 0.0A Pa!isades informed of DET 0.0.01 Organtze and staff a DET response Team 0 0 02 Perform a Self Assessment to identify areas or performance enhancement 0.0.03 Develop focus areas, goals and objectives 0.0.C NRC DET First Site Msit 0.0.04 Perform a Root Cause/ Common Cause Analysis on DEO's 0.0.05 Review results from root cause/ common cause anatyses 0.0.D Second NRC DET S!!e Visit 0.0.E NRC DET Exit Meeting 0.0.F NRC DE Report issued to CPCo 0.0.06 Develop action plans to define the steps, resources, durations and inter-relataships 0.0.07 Deveiop and provide a tracking system for mortaty progress 0.0.J Rev 0 Action Plans in place 0.0.08 Evaluate NRC DET Report 0.0.09 Distribute results of review 0.0.10 Draft initial response cover letter for Sr. Management 0.0.11 Plant senior and executive management rev!en of letter 0 0.12 Upda+e the PEP with revised and new action plans 0.0.13 Action plan sponsors and NOD Steering Committee review PEP 0.0.14 Revise transmittailetter and submit to the NRC 0.0.15 DEPRT Team perforn verification and assessment of PEP 7/13/94
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Name 1.1 Estab!!sh Strategic Direction 1.1.00 start of AP1.1 1.1.01 Review and Revise CPCo/ NOD Guide es Needed 1.1.02 Distribute to Direct Reports for Review and Comment 1.1.03 hcorporate Comments 1.1.04 Print up New Booklets 1.1.05 Develop Communication Schedute 1.1.06 Implement Communications 1.1.07 Perform Verification and Validation 1.1.08 Review Results and Make Changes as Necessary 7/13/94
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 1.3 Estabtrsh Aligned Management Expectations and Standards 1.3.00 start of AP1.3 1.3.01 Write NODevel Management Expectatens and Standards booidet '
1.3 02 VP-NOD conduct NOD Ma.W Stand 4evm Meeting 1.3.03 Publish and distrtbute NOD Management E&S Book!et 1.3.04 Write and distnbute template for departnwnth standards and expectatens document 1.3.05 Write 0%t. a level ESS documents 1.3.06 Conduct Dept. Sta%$own Meetings semi-monthly 1.3.07 Publish and distribute Dept.-level ESS Booklet (s) 1.3.08 Conduct eW survey annua #y beginning 1!95 (V&V)
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 1.4 Estab!!sh a Management C x:sp wa Program !
1.4 00 start of AP1.4 1.4.01 Devebp a Management Competency Model(MCM) 1.4.02 Conduct an review of all EA&P using the Professenal Competency Model 1.4 03 Develop a management and key Technical Postion Cumculum 1.4 04 Create a V&V measure and implement 7/13/94
Palisades Nuclear Plant - Performance Enhancement Action Plan Name 1.5 Define Management Information Needs 1.5.00 Start of AP1.5 1.5.01 Draft a list of Common Performance Indicator 1.5 02 Obtain concurrence of final performance Indicator list 1.5.03 Place priority on Corr. Action & Work Orders Indicators 1.5.04 Define Sources of data to generate indicators 1.5 05 Review resource issues with the associated Dept. Manager 1.5.06 Uniquely identify each data owner and process owner 1.5.07 Conduct the departmental meeting to communkate purpose 1.5.08 Develop an informaton broadcast plan 1.5.09 Develop a strawman Project / Programs Report 1.5.10 Obtain Plant management concurrence for project' program report 1.5.11 Collect available information from project / program engineers 1.5.12 Manually assemble the initial report 1.5.13 Load at least one year of data into the database 1.5.14 Implement the broadcast plan and the performance indicator reports 1.5.15 Obtain user input to modify indicators amer three months e
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 1.6 Enhance Control of Contractors 1.6.00 start of AP1.6 1.6.01 isseta directive to Control non-NOD CPCo groups 1.6.02 Oc3ne accountability / ownership for contractors and non-NOD CPCo groups 1.6 03 Define guidance for control of contractors and non-NOD CPCo groups 1.6.04 Enhance the existing lesson plan & continue implementation of training 1.6.05 Contractors develop project spectre goa!s 1.6 06 Prepare Contractor Report Card for Refout 95 1.6.06a Issue Post EOC-11 (Outage) Report Card 1.6.07 Seek input from other utilities & industries 1.6.08 Verircation and Validation Contractor Performance l
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r Palisades Nuclear Plant - Performance Enhancement Action Plan Name 1.7 Enhance Ccmmuncations with Stakehoicers 1.7 00 S*.rt of AP1.7 1.7.01 Develop draft ccmmuncabon plan and obtain argwent from Sr. VP .
1.7.02 Bnef Department Managers and implement l 1.7.03 Create processes for facMating and monRonng communcebons
- 1.7.04 Create a vatidation ',erifcaSon measure and implement 1.7.05 Implement Mondoring Process 1.7.06 Develop daity rept at 1.7.07 dew and impisment a plan for 'rnprtmng communcatens with INPO l
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 1.8 Enhance Community involvement 1.8 00 Start of AP1.8 1.8.01 Identify opportunities for CPCo personnel to participate in community activites 1.8.02 Create departmental e@;~i for padicipation in community based actMties 1.8.03 Create an ongoing dialogue between Palisades and local officials to facilitate regular meetings 1.8.04 Create a citizens advisory board 1.8.05 Establish a local chartable event for CPCo sponsorship 1.8.06 Prepare Verification and Validation reports 7/13/94
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 2.1 Determine Scope of Work 2.1.00 Start of AP2.1 2.1.01 Define a project team 2.1.02 Collect information from alt %ti,= as 2.1.03 Identify existing w o.iruria as for actMties 2.1.04 Prioritize work items with TJP94*003 2.1.05 Develop delayed item rist, strategy 2.1.06 Communicate prioritization to stakeholders 2.1.07 Continue prioritization cornmunication 2.1.08 Management forum pnontire emergent issues 2.1.09 Verification and Vaildation: plant staff working pnorities 2.1.10 Transition AP2.1 to AP2.2 i
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 2.2 Establish an improved Planning and PriorRization Process 2.2.00 Start of AP2.2 2.2.01 Prepare the 1995-97 NOD Operating Plan 2.2.02 Establish a Work Management System 2.2.03 EstatWish a prioritization system and procedure 2204 Transfer the P2EP 2.1 woidoad into the WMS 2.2.05 InstMute a Palisades time reporting procedure 2.2.06 Pr%e reports to Mgmt and conduct periodic Mgmt review meeting (V8V) 2.2.07 Select and implement information technology i
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 2.3 Improve the Corrective Action Process 2.3.00 Start of AP2.3 2.3 01 Evaluate the NOD Corrective Action Process 2.3.02 Determine future direction of the CA System & develop a draft Project Plan 2.3.03 Revise the CAPIPP based on Palisades org. feedback 2.3.04 Identify and review intemal and external source documents 2.3.05 Identify & review CA process systems v.tiich have been obtained from other ub!ities 2.3.06 Define a modified CA process flowchart based on best industry practice and Palisades needs 2.3.07 Prepare and present to Palisades Mgt.
2.3.08 Develop Implementation Action Plans fit implem. the revised CA process 7/13/94
Palisades Nuclear Plant - Perfom1ance Enhancement Action Plan Name 2.4 Implement an Enhanced Mod (cation Process 2.4.00 Start of AP2.4 2.4.01 Establish a Process improvement Team 2.4.02 Develop an implementation Plan 2.4.03 DevelopNatidate prs Document 2.4.04 incorporate various improvements 2.4.05 Provide mechanisms to allow for automation of the enhanced rnod process 2.4.06 Establish a modification performance measurements program 2.4 07 Establish a Verifcation and Vardation function 2.4.08 Develop Retire-in-Ptace guidance 7/13/94
Palisades Nuclear Plant - Performance Enhancement Action Plan Name 2.5 Estatdish a Management information System 2.5.00 Start of AP2.5 2.5.01 Develop a database to facilitate graph sponsor data entry and secunty 2.5.02 Develop an automated graphing system 2.5 03 implement and Integrate wth site databases 2.5.04 Faciliate a managers level meeting for analysis of trend data 2.5.05 Develop a milestone / status report catabase 2.5.06 Identify long term support requirements to maintain database 2.5 07 Verircation and Va!idation l
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 2.6 Enhance the Operability Determination Process 2.6.00 Start of AP2.6 2.6.01 Prepare interim guidelines to define a uniform process 2.6.02 Communicate interim guidelines to all plant supervisory personnei 2.6.03 Conduct Training session for supervisory personnel 2.6.04 Collect information about operability 2.6.05 Provide training in Generic letter 91-18 2.6.06 Mtegrate the interim process from root cause 2.6.07 Provide training on Procedure revisions 2.6 08 Perform a V & V & Revise and Reissue any Procedures as required 7/13/94
i Palisades Nuclear Plant - Performance Enhancement Action Plan Name 2.7 Establish c Root / Common Cause Process using HPES program as a basis 2.7.00 Start of AP2.7 2.7 G1 Perform a Root Cause Anafysis using HPES 17.02 Develop an interim guideline 2.7.03 Establish an interim committee to address Root / Common Cause/HPES anafysis 2.7.04 Improve trendirg by having MRB perform cause coding 2.7.05 Implement common cause anaWis of corrective action 2.7.06 Implement improved computer software to facilitate the revised process 2.7.07 Implement Graded Root Cause Anafysis and Revise AP 3 03 2.7.08 Upgrade Staff on Root Cause Anafysis 2.7.09 Establish Dw Li m ai experts in Root Cause Analysis and HPES 2.7.10 Integrate Modificate Prionteation into the CAS Process 2.7.11 Devebp a trending report 2.7.12 Verifration and Varidation 7/13/94
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 3.1 Enhance Employee Krmdedge and Sk;lts 3.1.00 Start of AP3.1 3.1.01 Evalua'e PEP against SOER 92.01 Actions 3.1.02 Provide Mgt & Technical Training for Palisades personnel as directed by NOD Sr Mgt.
3.1.03 Incorporate Mgt. development changes into the Maint. Super. & Shift Super.
3.1.04 Complete the Engineering Support Staff training program 3.1.05 Define the role of the Training Curriculum Committees 3.1.06 Enhance the abilities of the Training Department Staff 3.1.07 Provide mock-ups Mairtenance Dept. Personnel training 3.1.08 Maintain accreditation in all 12 accredited training programs (V&V) 3.1.09 Peiform post training effectiver'ess surveys (V8V) 7/13/94
Palisades Nuclear Plant - Performance Enhancement Action Plan Name 3.2 Improve Site Facilities 3.2.00 start of AP3.2 3.2.01 Evaluate site requirements for added management personnel 3.2.02 Construct Service Building addition and perform improvements to existing 3.2.03 Improve Admin. Building office areas 3 2.04 Improve the TSC 3.2.05 Complete V8V of timely and cost effective addit;wus and improvements 7/13/94
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 4.1 Define and Commurneate the NOD Nuclear Safety Ptubsophy 41.00 Start of AP4.1 4.1.01 Develop Safety Standards and List of Expectations 4.1.02 Direct Reports Review and Varidate Expectation 4.1.03 incorporate Comments from D'sect Reports 4.1.04 incorporate into NOD Strategic DirecUon 4.1.05 Schedule Meebngs 4.1.06 Convey Communscabon Expectations to Direct Reports 4.1.07 Direct Reports incorporate Ewiam into Apphcable Docs 4.108 Review Direct Report Communication Schedule 4.1.09 Implement Actions as Required 4.1.10 Perform Verification and Varidation Dept by Dept vs Actions 4.1.11 Rev'ew Verification and Vaildation implement Changes 7/13/94
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 5.1 Establish Critical Self-Assessment as a Norm for Line Organization 5.1.00 Start of AP5.1 5.1.01 Identify and collect current Self-Assessment processes from other utilities 5.1.02 Define Self-Assessment in terms to be understood by alllevels 5.1.03 Develop new Self Assessment program 5.1,04 Develop & implement training following creation of New self assessment progmm 5.1.05 Perform Venfication and Validation Self Assessment activities 7/13/94
Palisades Nuclear Plant - Performance Enhancement Action Plan Name 5.2 Enhance the Qua!ity of NPAD Assessment 5.2.00 Start of APS2 5.2.01 improve the Skills and quattrications of NPAD personnel 5.2.01.A Reassess the current NPAD job descriptions 5.2.0tB1 Improve the NPAD training and quahfication program 5.2.01.82 Implement NPAD qualification program 5.2.01.C Conduct a competency review of existing NPAD personnel 5.2.01.D Develop a NPAD Career Planning Policy 5.2.02 Improve the NPAD Assessment process 5.2.02.A Revise the NPAD Integrated Assessment Plan 5.2.02.B Develop standards for preparing / conducting monitoring, surveillance and audits 5 2.02.C Develop Annunciator Panel Trend Anafysis Program 5.2.03 Revise NPAD product survey program to obtain critical feedback 5104 Perform Verification and Vardation 7/13/94
Palisades Nuclear Plant - Pefformance Enhancement Action Plan Name 5.3 Improve the Effectiveness of the Assessment Function 5.3.00 start of APS.3 5.3 01 Include $r Management invohrement and outside in the assessment function 5.3.02 Clanfy role and responsibilites 5.3.03 Communicate role and responsibiiPJes 5.3.04 Integrate Management Safety Revew Commrttee rok and NPAD role 5.3.05 Improve the Independent Safety Review process 5.3 06 Revise NPAD Open issues Tracking Process 5.3.07 Penodically Self Assess the effectiveness of NPAD (ongotng) i 7/13/94
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Palisades Nuclear Plant - Performance Enhancement Action Plan Name 6.1 Establish a Program to Enhance Plant Desyt Margin 6.1.00 Start of AP6.1 6.1.01 Review Past evaluations of system design margins a determine which would provide max benefit 6.1.02 Provide the list of System Mods to Mgt. for approval 6.1.03 incorporate all approved system mods into dept. work plans 6.1.04 incorporate PRA techniques, evaluate and pnontee margin enhancement projects 6.1.05 Determine Safety System Design Margins 6.1.06 Identify and prioritize margin recovery efforts for all necessary Safety Systems 6.1.07 Verification and Validation 7/13/94
ATTACHMENT 4 Consumers Power Company Palisades Plant Docket 50-255 .
MATRIX 0F CPCo-IDENTIFIED ROOT CAUSES AND COMMON CAUSES, SHORT-TERM ACTIONS, AND PPEP ACTION PLANS August 11, 1994 .
I The following matrix identifies the root causes and common causes identified by CPCo's DET Response Team (DEPRT), Nuclear Performance Assessment Department (NPAD), and Failure Prevention, Inc. (FPI). For
- each of these root causes and common causes, the matrix identifies 1) relevant sections from the. Attachment 1, which describes CPCo's short-term actions for achieving improvements in performance at Palisades, and 2) relevant PPEP Action Plans. As this matrix demonstrates, each of the root causes and common causes is subject to a short-term action or PPEP Action Plan. ;
References in this matrix to Attachment I are to section numbers.
References to the PPEP are to Action Plans (two digit numbers; e.g., 2.7) ;
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i ROOT CAUSE/COMON CAUSE COMPARISON ATTACHMENT SUBJECT OF R00I CAUSE/ COMMON CAUSE DEPRT NPAD FPI 1 PPEP 2.1.3, 1.2, 1.3,
- 1. Standards and expectations / roles and responsibilities / X X X prioritization, planning & scheduling / teamwork & communications 2.3.1 2.2, 4. l_
2.1.3, 1.3, 4.1
- 2. Sensitivity to safety issues / procedure adherence / operator X X X professionalism 2.3.1 Oversight of work activities X X X 2.1.2, 1.4
- 3. 2.1.4, 2.3.1 2.1.3, 2.7, 3.1
- 4. Sensitivity to factors affecting human performance / technical X X X
~
expertise 2.3.4
- 5. Management skills / succession planning X X X 2.1.4 1.4
- 6. Independent and self-assessments / role and expertise of NPAD X X X 2.3.1 5.1, 5.2, 5.3
- 7. Corrective action system, root cause analyses, and effectiveness X X X 2.3.2 2.3, 2.7 I
of corrective actions Valuation of input from industry and regulatory sources X X X 2.1.1, 4.1
- 8. 2.1.2, 2.3.5
- 9. Adequacy and effectiveness of procedures X 2.3.4
- 10. Effectiveness of programs and processes X X X Many Many
- 11. Completeness and Accuracy of information needed to make quality X X 2.1.3 1.5, 2.5 decisions e
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ATTACHMENT 5 Consumers Power Company Palisades Plant i Docket 50-255 !
l MATRIX OF DET FINDINGS AND ROOT CAUSES, SHORT-TERM ACTIONS, AND PPEP ACTION PLANS August 11, 1994 The following matrix quotes or paraphrases each finding and root cause in the DET Report cith generic or programmatic implications. For each finding, the matrix identifies 1) relevant sections from Attachment 1, which describes CPCo's short-term actions for achieving improvements in performance at Palisades, 2) relevant PPEP Action Plans, or 3) other relevant actions to improve performance. As this matri/ demonstrates, each of the findings in question is subject to a short-term action, PPEP Action Plan, or other action.
References in this matrix to Attachment 1 are to section numbers. References to the PPEP are to Action Plans (two digit numbers; e.g., 2.7) in the PPEP. Some of the findings are not currently addressed by Attachment 1 or PPEP, but instead by other planned or completed actions. These actions are identified in the last column of the matrix. The column does not generally identify relevant Department Master Action Plans (DMAPs), if the issue is adequately addressed by a PPEP Action Plan. Additionally, several of the PPEP Action Plans which address general managemant concerns are not generally referenced for every issue in the table unless the DET issue is specifically related to that concern.
As discussed above, this matrix lists the DET findings that are programmatic in nature or have generic applicability. More specific findings (e.g., findings applicable to a i particular component, procedure, or design) are not listed in this matrix and instead are being tracked separately for corrective action. Closure packages for these findings will be available for NRC review at the site.
The matrix lists findings identified in Sections 2.0 and 3.0 of the DET Report. The matrix does not separately list the findings in the executive summary or the transmittal letter for the DET Report, because those findings are duplicates of the findings in ,
Sections 2.0 and 3.0. Similarly, the matrix does not separately list the findings in the !
introductory paragraphs throughout Section 2.0 that duplicate the findings in the body of Section 2.0.
P
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
2.1 OPERATIONS AND TRAINING 2.1.1 Poor Planning and Direction by Operations Management
- a. Operations management poorly planned or directed various 2.1.3, 1.4 plant evolutions, process controls, and job assignments. 2.1.4, 2.3.1
- b. During 1993 control room operators (CO) began periodically 2.1.4, 1.4 switching their C0-1 and 00-2 roles, and in 1991-92 2.3.1 licensed auxiliary operators (LA0s) began periodically performing C0-2 duties. Operations management failed to compensate through additional training, coaching or supervisory oversight for these personnel performing unfamiliar licensed duties.
2.1.2 Occasionally Poor Onshift Supervisory Oversight and Direction
- a. Onshift supervisors provided poor oversight and direction. 2.1.4, 1.4, 5.1 2.3.1
- b. The three onshift supervisors did not fully understand 2.1.4 1.2, 1.4 Control Room Supervision their job responsibilities. The Operations Support was restructured to Supervisor and Shift Engineer were not fully staffed on include a Shift each shift. The resulting delineation of roles and Supervisor, Control Room responsibilities among the three positions was not clear, Supervisor, and Shift especially the Shift Engineer position. Engineer. Roles and responsibilities are being addressed by the Operations DMAP.
- c. Onshift supervisors received limited supervisory training 2.1.4 1.4, 3.1 and coaching.
- d. Operations management overburdened onshift supervisors with 2.1.4 1.2 Reorganization and collateral duties that potentially distracted them from additional staffing of ,
their licensed responsibilities, support groups has relieved collateral duties from on-shift personnel 1
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS I
- e. The location of a food preparation area in the control room The kitchen and other was disruptive to onshift duties and the Shift Supervisor's distractions have been (SS's) cognizance of control room activities. Also, the removed from the control noise produced by the control room ventilation was room. A new sensitivity distracting to control room personnel. has been planned upon potentially distracting activities, which has resulted in the removal of unnecessary activities / traffic in the Control Room area.
A condition report, C-PAL-94-260, has been issued to resolve the noise produced by the HVAC.
- f. In several instances shift supervision performed only 2.1.4 1.4, 4.1, Shift Supervision cursory reviews of surveillance test results. They did not 5.1 (primarily the Shift verify that all the acceptance criteria were met. Engineer) reviews Consequently, test failures went unidentified for several surveillance test results days. to verify acceptance criteria are met.
2.1.3 Low Expectations of Performance by Operations Management
- a. Operations management established low or incomplete 2.1.3, 1.3, 2.3, standards and expectations for operators and did not 2.1.4, 2.6, 4.1 reinforce established standards and expectations including 2.3.1, procedure adherence and procedure quality, control of 2.3.3, extraneous material within containment, control of 2.3.4 transient equipment, involvement in operability decisions, material deficiency reporting by auxiliary operators, and log keeping practices.
- b. Operators occasionally mispositioned safety-related 2.1.3, 1.3, 4.1, components and damaged equipment. Also they routinely 2.3.1, 4.2 l failed to maini.in configuration control due to a lack of 2.3.4 I adherence to procedures and process controls. Furthermore, l Operations management did not foster an environment of procedural adherence.
2
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- c. The procedure change process was ineffective and not 2.1.4, The Operations DMAP integrated. Controls over operator data sheets did not 2.3.4 includes a provision to include any independent review and approval. improve the control and Responsibility for revising some of the procedures and maintenance of operator operator data sheets was assigned to enshift supervision as data sheets.
a collateral duty. Consequently, procedures and operator data sheets were occasionally incomplete or incorrect.
- d. There were substantial amounts of unrestrained and 2.2.4 5.1 Walkdowns were performed extraneous material within the containment. Containment to identify the potential tours by Operations management at the conclusion of and for dislodged items and after the 1993 refueling outage never recognized or clogging of the sump. The identified the inadequate containment closeout inspections. Operations DMAP includes a The written guidance on containment housekeeping contained project to raise vague criteria. performance standards for what is acceptable to be left in the containment.
- e. Operations supervision and personnel were generally unaware 2.2.4 Walkdowns were conducted of administrative controls involving transient equipment to verify that equipment within the facility. Consequently, the DET identified is appropriately numerous examples of unrestrained transient equipment that restrained. Admin had been present at power. Procedure (AP) 1.01 has been revised to clarify requirements for restraining equipment.
- f. Operations management expectations regarding operability 2.3.3 2.3, 2.6 decisions were inconsistently implemented and incomplete.
Occasionally, Operations management made operability decisions without consulting or informing shift supervision. Also, operability decisions were not documented because Operations management did not delineate that as an expectation.
3
i DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- g. A0s did not critically assess plant material conditions 2.1.4, 1.3, 1.4, Periodic meetings are during their rounds partially due to the lack of management 2.3.2 2.3, 4.1 being conducted between standards and expectations relative to their identifying the Operations and documenting such deficiencies. Superintendent and each operating crew to communicate expectations.
- h. Onshift personnel routinely omitted required events and 2.1.4, 1.4, 5.1 Improvements in log !
information from logs. Operations managenent routinely 2.3.1, keeping are being coached read the logs but did not correct log keeping deficiencies by Operations Management or reinforce the established expectations. as deficiencies are noted.
2.1.4 Repetitive Problems with Protective Tagging
- a. There were repetitive problems with personnel protective 2.3.4 1.3, 4.1, A memo was issued tagging. Operators hung tags on the wrong components, 5.1 clarifying the prepared deficient switching and tagging orders (STOs) for expectations on the tagout the work performed, failed to perform required independent process, and training will verifications, and made unauthorized changes to STOs. be provided on tagging.
Contributory to these repetitive problems was the poor process established by Operations management for equipment tagging and a lack of rigorous adherence by operators to procedures.
- b. Occasionally, Operations management did not provide enough The Operations DMAP has details in the STOs of the work to be performed. During assigned resources to the midnight shift when STOs were prepared, maintenance develop a Personnel personnel most cognizant of the upcoming work activity were Tagging Program not present to discuss the activity or the tagging boundaries.
- c. There were inconsistencies between the Power Control The Operations DMAP has Departnent's tagging procedure used in the switchyard and assigned resources to the stations' tagging procedure used in the rest of the develop a Personnel facility. Power Control Department's tagging procedure did Tagging Program.
not include review and approval of STOs for switchyard work by control rom supervisors. Thus, A0s wrote tags for the switchyard based on verbal instructions from C0s without supervisory review before hanging the tags.
4
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
2.1.5 Poor Support to Operations 2.1.5.1 Engineering Support Problems
- a. Occasionally, Engineering did not provide to Operations 2.1.3, 2.2, 2.6, The Safety and Licensing correct operability recommendations, effective or timely 2.2.3, 3.1, 4.2, DMAP includes a project to solutions to design or material condition deficiencies, and 2.3.3 6.1 present and explain the well written and technically correct surveillance results of the IPE to procedures. Also, Engineering did not always communicate Operations. The to Operations safety insights from the Palisades Individual establishment of System Plant Examination (IPE) for power operation or inform Engineering roles and Operations when emergency operating procedure revisions responsibilities will were needed. emohasize providing cperability recommendations.
2.1.5.2 Training Support Problems
- a. Select areas of licensed operator training were poor or The Operations DMAP ineffective. Also, training for some duties not strictly includes provisions for covered by the licensed program were poor. responsibility clarification and personnel development training.
- b. Supervisory training and coaching for Operations 2.1.4 1.4, 3.1 supervisors was limited, which contributed to poor supervisory oversight and directions.
- c. Onshift Operations supervision received limited root cause 2.7 The Operations DMAP and event investigation training even though they includes provisions for investigated the majority of the operational deviation root cause training of reports. Operations personnel.
l s
. _ _ . ._ _ _ _ - _ - _ - _ - _ _ - - _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _~ - - _ - _ _ _ - _ _ _ _ _ _ - _ - - _ - _ _
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- d. Operators received limited training and written guidance on 3.1 The Safety & Licensing NRC notification requirements, which contributed to DMAP includes a project to operators not recognizing events that should be reported to clarify definition of the NRC. reporting responsibilities and development of training programs on reporting requirements to NRC.
2.1.5.3 Licensing Support Problems
- a. Licensing provided poor support to Operations in the areas 2.6 The Safety & Licensing of technical guidance and NRC reporting. The combination DMAP includes a project to of customized technical specifications (TS) and the convert the Palisades TS supplementary technical guidance was complex and to the Standard TS format.
occasionally made conservative operating decisions by operators more difficult. Also, the combined technical guidance was occasionally incomplete.
- b. Plant and Operations management did not take aggressive The allocation of one action to fully resolve the problem with the TS. Licensing licensing engineer to this management only assigned one person to the improvement task is appropriate given effort and his collateral duties only allowed half his time its low safety to be spent on improving the TS. significance.
The revision to the Standard TS format is currently scheduled to be submitted by January 1996.
- c. Also, due to the limited knowledge of NRC reporting 2.1.3 1.3, 4.1 See No. 2.1.5.2(d) requirements and guidance, Operations relied to a significant extent on recommendations from Licensing.
These recommendations were occasionally nonconservative.
2.1.6 Weak Operations Self Assessment and Corrective Action l 6 -
l -
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- a. Operations self assessment as well as corrective actions to 2.1.4, 2.3, 2.7, The Operations DMAP problems identified by these self assessments were weak. 2.3.1, 5.1, 5.3 includes provisions for Contributing causes included (1) limited training of 2.3.2 root cause training of Operations staff in event evaluations and root cause Operations personnel and analysis, (2) the lack of independent reviewers for the added an Operations problem (onshift supervisors originally involved in the Liaison Position to problem generally dispositioned corrective action system support self-assessments, reports as a collateral duty), (3) the failure to use root cause analysis, and multiple disciplines or departments on complex problems and evaluation of industry events, (4) operators not understanding the threshold experience.
between the plant-wide corrective actica system and the lower level Operations Department's Operations Information Report (OIR) system, and (5) the lack of necessary resources and feedback mechanisms to effectively support the OIR program.
- b. Operators documented some events in the OIR system that 2.3.2 2.3 The OIR process has been should have been documented in the plant wide corrective terminated. The revised action system. Therefore, these events received a less corrective action system rigorous review, were not communicated outside of has taken its place.
Operations, were not captured in the site's corrective action trending program, and corrective action completion was not confirmed.
- c. Consecutive audits by Operations of safety tagouts in 1993 2.3.2 2.3, 2.7 The Operations DMAP identified repetitive omissions of numerous independent includes resources to valve and breaker position verifications, indicating the l develop a Personnel lack of effective corrective actions. Protective Tagging Program.
- d. The team identified that as of March 1994, 40% of the 1993 2.1.4 1.2, 2.3 See also No. 2.1.6(a).
OIRs needed to be dispositioned. One Operations The OIR process has been supervisor, the OIR program originator, dispositioned the terminated. The revised OIRs as a collateral duty. This individual, who had been corrective action system transferred to the Nuclear Performance Assessment has taken its place.
Department in February 1994, was still trying to disposition the 1993 OIRs because Operations management had not appointed a new person.
7
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- e. The dispositioned OIRs were not readily available for 2.3.2 2.3 The OIR process has been review by plant operators to allow them to improve their terminated. The revised performance and sensitize them to the kinds of problems corrective action system being identified. has taken its place.
2.2 NAINTENANCE Afe TESTING 2.2.1 Some Component Testing Was Weak
- a. Weaknesses were noted in the licensee's testing program for 2.3.3, 1.3, 2.6, demonstrating equipment operability. For example, some 2.3.4 2.7, 4.1, acceptance criteria in test procedures did not agree with 4.2 the TS, poor root cause evaluations were performed for some test failures, and there were questionable testing practices. The licensee did not demand strict procedural compliance. These weaknesses resulted in questionable operability determinations and a failure to identify potentially degraded equipment.
- b. Root cause evaluations performed by Maintenance and 2.3.2 2.7 The Management Review Engineering for slow diesel generator (DG) start times were Board (MRB) has created a superficial. more questioning attitude in addressing the evaluation, root causes, and corrective actions.
! 2.2.2 Pump and Valve Testing Weaknesses l 2.2.2.1 Acceptability of Some Inservice Pump Test Parameters and Results Not Confirmed
- a. Some Inservice Test (IST) pump flow testing parameters and An ISI/IST Program results were not confirmed to be acceptable because of Enhancement Action Pian i potentially inaccurate standards or reference values. has been developed.
- b. Several discrepancies, which the licensee had not An ISI/IST Program reconciled, also existed between vibration readings Enhancement Action Plan recorded during IST and predictive maintenance data. has been developed.
2.2.2.2 Motor-Operated Valve (MOV) Inservice Testing Weaknesses 8
l
- - _ .-~
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS I
- a. Engineering did not effectively pursue the root cause(s) 2.3.2 2.3, 2.7 An ISI/IST Program (not specifically required by Section XI, but a good Enhancement Action Plan practice) of many MOVs which experienced highly varying has been developed.
stroke times for several months, although the valves did not reach the alert range.
- b. The IST group was unaware of a modification which changed 2.4, 4.2 An ISI/IST Program operator gear ratios on some High Pressure Safety Injection Enhancement Action Plan (HPSI) MOVs.
has been developed.
- c. There was not a defined and clearly documented relationship 2.2.1 4.2 An ISI/IST Program between the safety analyses and the valve stroke times. Enhancement Plan has been developed.
- d. The MOV trending database was incomplete and not The MOV testing program integrated. Engineering could not easily determine from has been reviewed and will the trending data when a recorded stroke time was performed be revised clarify the to document a new reference test or when increased testing program, improve trending had been performed. Trend data also did not indicate data and other record whether the alert or action ranges had been exceeded. keeping.
2.2.2.3 Air-Operated Valve (A0V) Testing Weaknesses
- a. The licensee did not have a coordinated plan for the An A0V Program Plan has maintenance and testing of A0Vs. been developed. A comprehensive A0V strategy is scheduled to be implemented currently by 12/15/94.
- b. For those A0Vs that were tested in the IST program, the 2.2.1 4.2 An ISI/IST Program licensee indicated that there was not a defined and clearly Enhancement Action Plan documented relationship between the safety analyses and A0V has been developed.
2.2.2.4 Incomplete Relief Valve Testing Data
- a. Extensive information regarding relief valve design and 4.2 An ISI/IST Program testing was developed by the licensee in 1992, but the Enhancement Action Plan licensee was unable to recover this data. As a result, the has been developed licensee did not have a basis to ensure that safety-related relief valves were properly set, maintained and tested.
9
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
2.2.2.5 Instances of Check' Valve Testing and Maintenance Scope Weaknesses
- a. Check valves in the reactor cavity drain lines and in the 2.2.1 4.2 An ISI/IST Program Auxiliary Feedwater (AFW) and DG rooms were shown on Enhancement Action Plan drawings, but none had equipment ID numbers, or were has been developed.
included in the Check Valve Program. Debris prevented full seating of valves in reactor cavity drain lines. No preventive maintenance (PM) or testing had been done on these valves to ensure their continued reliability or to verify that they would function as designed. The licensee also identified that the DG floor drain check valves were not previously tested.
2.2.2.6 Many Important Manual Valves Not Periodically Tested
- a. Seventeen manual valves that were relied on in Emergency 4.2 An ISI/IST Program Operations Procedures (EOPs) were not tested to verify they Enhancement Action Plan would function. has been developed.
2.2.3 ~ Weak Maintenance Work Practices
- a. Oversight of maintenance activities by supervisors and 2.1.2, 1.3, 1.4, managers through observing in-process work was consistently 2.1.3, 4.1, 5.1 low. This contributed to procedural adherence problems by 2.3.1, personnel performing maintenance activities and a failure 2.3.4 to acquire engineering assistance to evaluate problems in some instances.
l l
l 10
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS I
- b. Poor support from Engineering contributed to inadequate 2.2.3, 2.3, 2.7 AP 5.01 has been revised maintenance work procedures and poor root cause 2.3.2, significantly to include evaluations. 2.3.4 the guidance for addressing root cause in the summary of work performed. Training for Maintenance Department employees has been conducted in AP 5.01.
System Engineers are being i involved in root cause determinations. '
Additionally, ownership of the maintenance procedures '
is being transferred to the maintenance department.
2.2.4 Some Material Condition Deficiencies Not Identified and Documented .
- a. Several material deficiencies existed due, in part, to not 2.1.3, 1.3, 2.3, communicating performance standards and expectations. 2.3.2 4.1
- b. The licensee did not fully implement work processes, the 2.3.4 1.3, 2.3, corrective action program, and the Maintenance policy 4.1 guidance requiring area walkdowns.
- c. There were multiple hanger deficiencies including loose or 2.2.4 1.3, 2.3 Refer to 2.2.4.d.
missing hanger fasteners, loose base plate bolts, cracks in a wall caused by embedded support bolts, and missing fasteners on large structural supports in the Component Cooling Water (CCW) room.
11
__m _ _ _ _ _
- __ . ~, . ,,m._ -
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- d. Some spring can hanger supports were loose, did not have 2.2.4 1.3, 2.3 The Safety Related Piping
- cold and hot settings marked on the can, or appeared Reverification Program improperly set. (and a follow on program for small bore piping) is being conducted to identify piping deficiencies.
Additionally, a training program will be conducted to increase the sensitivity of plant personnel to identify such deficiencies.
- e. The Vendor Information Program did not ensure that updated Training was provided to vendor information was routinely requested, evaluated, or engineering on procedural incorporated into maintenance activities. requirements on the need to complete formal reviews of vendor information per AP 9.45. Also, AP 3.16 '
has been revised to require Systems Engineering to control vendor recommendations, vendor information from trip reports, phone calls, and other vendor information.
2.2.5 Poorly Controlled Warehouse Storage of Safety-Related Material-
- a. Numerous fundamental weaknesses were identified regarding 2.1.2, 1.4, 5.1 The Maintenance Department material control and supply of parts from the warehouse 2.3.1 DMAP provides for because of a lack of adequate management oversight of the enhancements to material warehouse facility. control including t preparation of a new material storage and control procedure. '
12
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- b. The licensee did not properly segregate and secure safety- The Maintenance Department related, nonsafety-related, and nonconforming items, DMAP provides for an including clearly identifying the latter items. improved process for storage and control of safety-related material.
The new " Material Storage and Control procedure will:
- clearly describe the use of tags to segregate material,
- provide guidance for packaging and storage, and
- define use of physical segregation.
A walkdown has been conducted of storeroom to identify or repackage improperly protected electrical and electronic items.
- c. The licensee did not dispose of components at the end of The Maintenance Department their shelf life, did not specify shelf life of certain DMAP provides for components, and did not perform engineering evaluations to development of a shelf extend the shelf life of other components. life program. A new procedure, "Shel f Life
! Control," has been drafted and will be implemented.
l A review of DET shelf life issues did not reveal i specific safety concerns.
13
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- d. The licensee did not correctly store components in the The Maintenance Department warehouse, including allowing protective packaging to be DMAP provides for the breached and inappropriately protecting components to formalization of material ensure foreign material was excluded, control and storage. An evaluation of the material control program has been conducted by an outside contractor. The resolution of their comments and the DET issues have been incorporated in the storeroom work procedures and activities. Interim actions were taken to walkdown, identify, clean and repackage if necessary storeroom material. Long term corrective actions are prescribed on Corrective Action System documents.
t i
l l 14 l
r DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1 _
- e. The licensee did not properly control material control tags The Maintenance Department ,
prior to use or when material was returned to the DMAP provides for the warehouse. development and implementation of procedures to control the use of tags to control and segregate safety related material. Uncontrolled material tags have been i
removed from storeroom and salvage material. Safety-related material has been verified to be properly tagged. Weekly storeroom tours are conducted to verify the proper use of tags.
- f. Three different computer databases and a hard copy manual The Maintenance Department process were used to access requested information regarding DMAP provides for stocked items, purchase order items, and shelf life combining logs and concerns. information systems into a single database.
- g. Inaccuracies were also noted between actual stock The Maintenance Department inventories and database information. DMAP provides for improvements in inventory accuracy. Inventories are l continually monitored through the company inventory process and daily on " stock-out" sheets.
15
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- h. Replacement part unavailabilities resulted in several The Maintenance Department temporary modifications remaining installed for extended DMAP provides for longer periods, and work order (WO) planning delays. term maintenance planning (13-15 weeks) and an improved PPAC program.
Engineering support to the maintenance planning work will be provided by System Engineers to assist procurement in obtaining acceptable replacement parts.
2.2.6 Poor Support for Preventive Maintenance Impacted Equipment Performance
- a. Poor support for PM activities was evidenced by identified A preventive maintenance equipment problems and lack of control of the licensee's optimization will be program. The licensee's program lacked the rigor needed to performed on three pilot prevent future similar problems. Severai failures or systems, focusing on degraded conditions, a number of them recently identified, defining Maintenance Rule occurred because PM was not performed on the equipment or system functions. An the PM performed was ineffective. evaluation of the effectiveness of PM Optimization will be performed before proceeding with optimization on other Maintenance Rule scoped systems. See also 2.2.6(b) 16
- -_- -.------.--___._--_. - -__ _ -_ - _ _ _ - - - - - _ _ _ _ _ _ _ _ _ _ _ - - _ _ . - .- . __ ~ - -- -___ _ . _ _ - -
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- b. The Periodic and Predetermined Activity Control (PPAC) 2.1.3 2.5 A PPAC Enhancement Action program experienced significant weaknesses because of Plan is being implemented insufficient management support including: (1) about one- as part of the Maintenance "
third of the PM activities were not formally controlled Department DMAP.
within the PPAC program, which included approximately 50 Additionally, AP 5.14 has percent of "Q-List" components, (2) certain PPAC PMs which been revised to provide were not performed while their deletion was pending, (3) better direction and many Instrumentation & Control (I&C) PPAC PMs which did not greater control in the have an established interval, (4) PPAC PMs which were areas of weakness deferred and deleted without system engineer and Operations identified by the DET.
concurrence, (5) PPAC PMs which were not accomplished on Training on the above has schedule, resulting in regular reliance on performing the been conducted.
PPAC PM within the 25% grace period, (6) vendor information which was not routinely incorporated, and (7) the lack of management reporting of PM status. The licensee had not evaluated the need for periodic pump disassembly and inspection, and had not included several DG support system components in its PM program. Additionally, some PPAC durations did not have sufficient supporting i information.
2.2.7 Weak Maintenance Work Order Tracking and Reporting
- a. The licensee's work control process exhibited weaknesses in 2.1.3, 1.5, 2.2, New performance indicators tracking and reporting. In some instances, these 2.3.4 2.5 have been developed to weaknesses were caused by undefined or poorly defined portray work order program elements and unclear procedure guidance. backlog.
- b. Some work requests were not entered into the Advanced 2.5 Reviews were performed to Maintenance Management System (AMMS) in a timely manner as ensure that work requests required. were entered into the system. AP 5.01 has been revised to provide more direction on when a work request can be used and to require prompt notification to the Systems Engineer when a Work Request is initiated.
17
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- c. More than two-thirds of the WO backlog (approximately 1650) 2.1.3, 1.3, 2.2, A multi-discipline team were not ready to be worked. Until requested by the team 2.2.4, 2.4 2.5 will conduct quarterly the licensee had not made an overall safety / reliability reviews of the safety assessment of the maintenance backlog. significance of work orders. A 13-week rolling maintenance schedule is to be used to provide visibility to upcoming and past-due work.
- d. The number of PM activities was actually lower than 2.5 Recent revisions to identified in the management information system because the AP 5.01 have defined AMMS licensee considered many corrective maintenance (CM) work types. Performance activities on degraded (but not failed) equipment as PM. Indicators have been This resulted in a more favorable PM-to-CH ratio that what developed to clarify and was actually occurring. focus management on key WO backlogs. One of the new indicators measures " Ratio of PPAC Work Orders to Total Maintenance Man-Hours, Actual."
2.3 ENGINEERING AND TECHNICAL SUPPORT
- a. The roles and responsibilities of the two onsite 2.2.1, 1.2, 1.3, engineering organizations and the interfaces between them 4.1, 4.2 were not well defined. Authority was not clear and accountability was not maintained. Some system engineers assumed total ownership of their systems, while others exercised very little. Standards and expectations were not effectively developed and communicated.
2.3.1 Plant Support from Engineering Often Weak
- a. Causes of weak plant support by Engineering were 2.1.3, 1.3, 4.1, historically incomplete design basis information, and a 2.2.1, 4.2, 6.1 tendency to perform evaluations and institute 2.2.3, administrative controls as corrective actions instead of 2.2.4, 2.4 correcting plant hardware deficiencies.
18
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
2.3.1.1 Evaluations in Support of Operability Determinations Untimely and of Poor Quality in Several Instances
- a. Factors which contributed to poor engineering evaluations 2.2.3, 2.3, 2.6, were a poorly defined operability process and engineers' 2.3.3 3.1, 4.2 lack of understanding of the design bases. Many engineering personnel had only recently become aware of their roles in determining equipment and system operability. Some engineering managers had only recently become familiar with NRC guidance on operability determinations contained in Generic Letter 91-18. There was a general weakness at all levels concerning training of engineers in evaluating degraded equipment for operability.
2.3.1.2 Root Cause Analyses Often Weak or Untimely
- a. Multiple repeat failures of safety-related equipment often 2.3.2 2.2, 2.3, occurred before the root cause was identified. In some 2.7 cases, several attempts at corrective action were not effective because the root cause was not determined. A lack of training on root cause analyses and a lack of emphasis and resource allocation by management were contributing causes for weak or untimely root cause analyses.
2.3.1.3 Poor Support for Procedures and Instructions
- a. Engineering support for revising the plant operating and 2.2.3, 1.3, 4.1 Responsibility for the maintenance procedures was poor. Management expectations 2.3.4 maintenance procedures are on procedural compliance and reporting of inadequate to be transferred to the procedures were unclear and inconsistent. Maintenance Department to provide more appropriate control of the contents.
- b. The engineering controls for assuring that operating 2.2.2 2.4 procedures were appropriately revised following plant modifications were weak. Certain modifications were installed and placed in service without the development of the associated operating procedures.
19
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
2.3.1.4 Poor Contractor Control by Engineering
- a. There was often poor oversight over contractors' work, 2.2.3 1.6, 3.1 including ineffective technical reviews of their work products. A lack of training for engineers on contractor control was a cause for these problems.
2.3.2' Resolution of Some Equipment and System Problems untimely and Ineffective
- a. Engineering was often slow to evaluate problems, recognize 2.2.3 1.3, 2.3, their safety significance and effectively resolve them. In 2.7, 4.1 some cases, even after the safety significance was 4.2 recognized, engineering was slow to act.
- b. Management standards and expectations were not well defined 2.1.3, 1.3, 2.2, or enforced, barriers to resolving problems existed in the 2.2.2, 2.3, 2.6, corrective action process, there was an ineffective 2.3.2, 4.1, 4.2 prioritization process, and there was weak training of 2.3.3 Engineering personnel in the operability determination process.
- c. Current plant operating conditions and some postulated The Safety & Licensing accident scenarios were not reflected in the licensee's DMAP requires the l Individual Plant Examination (IPE). resolution of these issues r
in the IPE.
l 2.3.3 Over-Reliance on Operator Actions to Compensate for Some Design Conditions i a. There was an over-reliance on operator actions to meet 2.1.3, 1.3, 2.4, l design basis accident requirements in some cases. The DET 2.2.3 4.1, 4.2, found instances in which Engineering did not provide a 6.1 balanced view to plant management and endorse modifications when they believed that a mcdification was the most effective way to resolve a problem.
l 2.3.4 Control and Quality of Plant Modifications Sometimes Deficient
- a. The design, implementation and control of plant 2.2.2, 2.4, 3.1, l
modifications were sometimes deficient, which occasionally 2.2.3 4.2 resulted in modifications that did not achieve the intended result.
l 20
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1 i
- b. The causes for the weaknesses in the modification process 2.2.1, 1.2, 2.4, included a historical lack of design basis information, 2.2.2, 4.2 lack of. clearly defined roles and responsibilities between 2.2.3 NECO and System Engineering, ineffective technical reviews ;
(quality verification), and an ineffective process to assure' documents, processes, and activities affected by the modification were appropriately revised.
- c. There were instances where the temporary modification 2.2.2 1.3, 4.1, process should have been used but was not. 4.2 ,
2.3.5 Ineffective Configuration' Control by Engineering -
- a. Weaknesses existed in the configuration control program. 2.1.2, 2.4, 4.2, Insufficient management attention, and lack of attention to 2.2.2 5.1 details, contributed to these performance problems.
- b. The DET noted several weaknesses in the implementation of 2.2.2 2.4, 4.2, Plant procedures will be the licensee's program to control electrical load growth. 6.1 evaluated to improve load growth control.
- c. The licensee's fuse control program was found to have 2.2.1 2.2, 4.2 A plan will be developed several weaknesses and was still -incomplete. The to determine the scope of weaknesses included incorrect fuse types and labelling, fuses which need lack of design basis short circuit calculations for DC calculations to support size and types.
circuits, and lack of control of vendor supplied fuses inside vendor supplied cabinets (e.g., inverter). Administrative Procedures will be revised to clarify control of fuses inside vendor equipment.
- d. Weak control and maintenance of vendor manuals (VM) caused 2.2.3 1.3 A new vendor manual
, problems while performing plant work. Probable causes for control procedure (AP these deficiencies were attributed to weaknesses in: 9.45) has been issued and Engineering procedural requirements, Engineering work is being implemented. ;
practices regarding maintenance and use of vendor manuals, and understanding of expectations by Engineering personnel for use of controlled information.
21
____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _m _ _ _ . -_ -..c-;--m. - - _ - _ .-,,- . - 4 . - 1-w., _ .m.-- __ ___._ _ ____
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- e. The Vendor Information Program did not ensure that updated The 70 plus EDG Bulletins vendor bulletins were routinely requested. Approximately are being evaluated per 70 DG vendor bulletins which were informally received by the Industry and the DG system engineer were not formally reviewed for site- Experience review process.
specific applicability or introduced into the Operating An investigation intended Experience Review (OER) program for review. to identify additional unreviewed vendor information has been performed. Revised vendor manual control (AP 9.45) and Industry Experience (AP 3.16) procedures have been issued.
- f. The OER program did not require NECO be involved in An action has been decisions regarding applicability of vendor established in the Safety recommendations. and Licensing DMAP to ensure the appropriate level of NECO involvement in decisions regarding vendor recommendations.
2.4 MANAGEMENT AND ORGANIZATION 2.4.1 Ineffective Management Oversight and Control
- a. Management oversight and control was ineffective because of 2.1.2, 1.1, 1.2, PPEP in general addresses a lack of integrated programs and processes and clearly 2.1.3, 1.3, 4.1, this issue.
defined roles and responsibilities. Fragmented systems, 3.0 5.1 poorly defined programs, and lack of or conflicting expectations prevented successful implementation of performance improvement initiative.
- b. Managers failed to maintain a broad perspective and accept 2.1.1, 4.1, 5.1 recommendations from outside sources, which obstructed good 2.1.2, performance at Palisades. 2.3.5
- c. Managers often did not recognize broader performance issues 2.1.1, 1.3, 1.4, and associated consequences. Many events were caused or 2.1.2, 1.5, 2.5, exacerbated by a lack of guidance and clear direction from 2.1.4, 4.1 all levels of management. 2.3.1 22
I DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS l
1 I
- d. Management addressed tagging errors as individual personnel 1.3, 2.7 See No. 2.1.4(a).
performance issues and did not recognize that repetitive Operations DMAP will
- tagging problems resulted in overall configuration control address tagging issues.
issues.
t l e. Management did not consider the cumulative effect of 2.2.3, 1.3, 2.6, See also No. 2.2.7(c)
! multiple design and equipment deficiencies on system 2.4 6.1 operability, plant performance and degraded safety margins.
- f. There were numerous examples of degraded material 5.1 See Nos. 2.1.3(d) and conditions and poor housekeeping. 2.2.4(a), (b), (c), (d)
- 9. There was a lack of outside perspective. Useful 2.1.1, 1.3, 4.1 information and recommendations from outside industry and 2.1.2, regulatory groups had often not been accepted and utilized 2.3.5 at Palisades. A somewhat confrontational relationship existed between CPCo personnel and these outside groups.
2.4.1.1 Lack of Integrated Programs and Processes
- a. Fragmented systems or processes in planning, corrective 2.1.2, 1.3, 1.5, PPEP in general addresses actions, configuration control, and management information 2.1.3, 2.2, 2.4, this issue.
systems (MIS) coupled with poor communication produced a 2.2.2, 2.5, 4.2 lack of functional integration between departments which 2.3.2, resulted in poor performance and a lack of teamwork. 3.0
- b. Poorly defined programs and policies resulted in plant 2.1.2, 1.1, 1.3, PPEP in general addresses operations and events that challenged safety systems and 2.1.3, 1.4, 2.2, this issue.
equipment. In several instances, managers did not 3.0 4.1 completely plan and develop programs and processes, nor fully train plant staff, before implementation.
23
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- c. The licensee had not integrated many site activities into 2.1.2, 1.1, 2.2 PPEP in general addresses an organized plan; to scope, schedule, and resource load 2.1.3, this issue.
these activities; to provide for overall oversight and 3.0 control; to accomplish activities to a recognized time table; and to require follow up, closecut reporting and accountability. Each department had a separate listing of planned or proposed activities. Accomplishment of these activities was dependent on available resources, which fluctuated because of emergent work and changing priorities in response to external influences. This situation fostered a station-wide reactive approach to planning and resulted in significant delays and in some cases, incomplete or abandoned projects and corrective actions.
- d. Lack of an integrated configuration control process 2.2.2 2.4 resulted in significant engineering issues and events. For example, poor programmatic guidance resulted in operating procedures, plant drawings and vendor manuals that were not properly updated following modifications and changes to safety-related systems and components.
- e. The licensee failed to appropriately address long-standing 1.3 See No. 2.1.4(a).
equipment tagging problems which resulted in configuration Operations DMAP will control issues and contributed to numerous events. identify improvements in tagging.
- f. MISs were not integrated and lacked compatibility. Each 2.1.3 1.5, 2.5 department maintained its own MIS and associated data base.
- g. Communication problems were widespread. Both vertical and 2.1.3, 1.3 CPCo is developing a horizontal communicatica were ineffective and were 2.1.4 communications strategy to previously identified as a root cause of poor performance improve internal by the licensee. communications.
24
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS' I
- h. Only one paragraph in Administrative Procedure 3.03, 2.1.3, 1.3, 2.3,
" Corrective Action," gave guidance for operability 2.3.3 2.6, 4.1 determinations. Operations personnel were expected to make an immediate operability determination; however, in some cases, Operations managers were not aware of operability concerns until a corrective action document was presented at the Corrective Action Review Board (CARB) meeting.
Operations rarely documented operability decisions or the basis for these decisions. Engineering personnel performed the analyses; however, Licensing personnel performed the final review. During CARB meetings, Licensing arguments-often prevailed over engineering and safety performance Concerns.
- i. Frequently, managers did not completely plan and develop 3.0 1.4, 2.2 PPEP in general addresses programs and processes, nor fully train plant staff, before this issue.
implementation.
J. The licensee often did not transfer ownership of the task 1.2, 1.3, force's solution back to the line organization. Thus, some 2.2 action items and recommendations produced by task forces were not acted on when the task force was completed or disbanded.
l l
s 25
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
2.4.1.2? Lack of Clearly Defined Roles and Responsibilities
- a. Lack of clearly defined roles and responsibilities coupled 2.1.3 1.1, 1.2, See also No. 2.4.1.l(g) with ineffective communication and conflicting expectations 1.3, 4.1 led to poor performance and unsuccessful implementation of performance improvements.
- b. Confusion regarding the role of NPAD resulted in weak 2.3.1 1.2, 5.2, assessments that were directed at minor industrial safety 5.3 and schedular conformance issues, rather than uncovering existing program and process deficiencies, human performance problems, and safety concerns.
- c. Unclear guidelines and expectations concerning the roles 2.2.3 1.2 and responsibilities between System Engineering and NECO resulted in issues generated by design basis document reviews, such as the increase in DG fuel oil consumption, remaining unresolved.
- d. System engineers did not communicate effectively with NECO 2.1.3, 1.3 See No. 2.4.1.1.(g) engineers, whose input was often not sought when needed. 2.2.3
- e. Management communicated conflicting expectations. 2.1.3 1.3, 1.4, Consequently, attention to safety was weak in some cases. 4.1 Management's stated objective was safety; however, personnel performance evaluations were based on meeting financial and schedular goals. Front line supervisors often recounted during interviews with the team that management gave highest priority to meeting schedules.
2.4.1.3 - Problems During Normal Operations Continued Through Outage Periods
- a. Ineffective communication, coordination, scheduling, 2.1.2, 1.1, 1.3, See also No. 2.4.1.l(g) planning, supervisory oversight, project management, and 2.1.3, 1.4, 1.6, poor implementation of lessons learned, along with weak 2.1.4, 2.2, 2.3, oversight of work performed by contractors and CPCo 2.2.2, 2.4, 2.7, organizations, contributed to the problems during normal 2.3.1, 4.1, 4.2, operations and outages. Problems during normal operations 2.3.2, 5.1 that continued under outage management included procedure 2.3.4 adherence, lack of configuration controls, human performance issues, and lack of a questioning attitude.
26
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- b. The competing requirements of Outage and Operations roles 2.1.1, 1.2 caused a span of control problems which was recognized by 2.1.4 licensee senior management.
- c. The position of Outage Manager remained unfilled as of 2.1.1 April 1994. Consequently, planning for the 1995 outage was behind schedule.
- d. NPAD audit found that the licensee missed the broader root 2.3.2 2.7 NECO reviews corporate cause for the poor plant and corporate reviews of the weld weld procedure procedure specification that affected welding parameters specifications for use at and examinations. The broader issue was a potential Palisades.
programmatic change to ensure appropriate reviews were performed on corporate procedures and used at Palisades.
- e. Lack of supervisory control over onsite contractor 2.3.4 1.6 activities caused many problems ar.d events, particularly when the contractors did not comply with site procedures and practices. For example, contractors missed procedural hold points and double verifications incorrectly used load cells to lift the upper guide structure during refueling, incorrectly installed some pipe hangers, ineffectively accomplished technical calculations, and improperly terminated wires. The licensee did not complete corrective actions, which included training responsible contract project mangers in contractor oversight. The licensee last performed training in this area in August 1992.
- f. The licansee did not formally implement outage management 2.2 Formal written guidelines guide' <. t ;7 increase the defense-in-depth and reduce risk are being prepared for durit.3 'r es ss . The documents describing the licensee's shutdown risk management.
program contained numerous undefined terms and conditions which were subject to interpretations. The licensee had not fully executed an outage shutdown risk program, and had not addressed all of the findings from its own 1993 self-assessment of the outage shutdown risk program.
27
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
~
2.4.1.4 ' Poor Resource Allocation and Utilization
- a. The poor planning, allocation, and utilization of resources 2.1.3, 1.1, 1.4, PPEP in general addresses and a lack of succession planning and defense-in-depth 2.1.4, 1.5, 2.2, this issue.
resulted in strained staffing and large backlogs in some 2.3.1 2.3, 2.5, key areas. MIS and budget processes did not provide 2.7 Mangers with effective decision-making tools to adjust resources. Staffing shortages in several areas were not addressed despite indications of performance degradation.
The lack of staff in corrective actions and human performance evaluation areas impeded effective implementation of these programs.
- b. Strained staffing and management's failure to recognize the 2.1.4, 1.2 problems with large procedure change backlogs resulted in 2.3.4 several examples of deficient and confusing operating procedures. Operations procedure writers routinely postponed non-emergency changes to coincide with required biennial reviews because of heavy work loads resulting from excessive collateral duties. Operations supervisors were also assigned procedure revision responsibilities requested procedure changes, some more that 2 years old, were not incorporated.
- c. A large safety-related work request backlog was awaiting 2.1.3, 2.1, 2.2 A work order reduction planning. Some work requests had awaited planning since 2.2.4 program will be developed.
1989 and a few high priority work requests from 1990 had Implementation of a 13-yet to be planned. week rolling maintenance schedule will provide visibility to upcoming and past due maintenance activities.
- d. Management did not plan for the replacement of some key 2.1.1 1.4, 3.1 personnel, which delayed resolution of safety concerns.
Vacancies existed in key program oversight positions, or experienced supervisors were replaced with junior or marginally qualified personnel .
28
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
~
2.4.2 Inadequate Attention to Human Performance
! a. Plant management failed to address and correct human 2.1.2, 1.3, 1.4, performance problems. 2.1.3, 2.3, 2.7, 2.3.1 3.1, 4.1, 4.2
- b. The licensee's implementation of the Human Performance 2.7 Evaluation System (HPES) had neither identified the underlying causes for repetitive human errors nor directed senior management's attention and resources on reducing the organizational barriers to enhance performance.
- c. The effectiveness of HPES was constrained by the assignment 2.7 of a large number of evaluations without a commensurate increase in staffing or resources. A single HPES Coordinator was assigned to complete a steadily increasing number of evaluations which substantially reduced the amount of time being spent to review and analyze each event and decreased the quality of the evaluation.
- d. Management did not appreciate the importance of clearly 2.3.4 Resolution of other DET written procedures, and did not encourage taking immediate issues includes provisions corrective action when a procedure did not support the to revise and upgrade required task. Operators and technicians stated that they procedures and processes.
were given the latitude to compensate for procedural inadequacies if they understood the intent and were able to comply with the objectives. Therefore, plant personnel routinely substituted individual knowledge, skill-of-the-craft, and training for poorly worded or inaccurate procedural steps. Consequently, procedural adherence continued to be a problems at Palisades and resulted in numerous events.
29
DET STATEMENT ATTACHMENT PPEP OTHER ACT10NS 1
- e. Management and supervisory skills had not been methodically 2.1.4 1.4 taught or formally developed despite the occurrence of numerous events where weak management skills were identified as a direct or contributing causal factor. The problem was particularly acute in the Operations Department. Few Operations personnel had taken any management or supervisory courses after their initial shift supervisory training.
- f. The IPE model did not reflect the heavy reliance on The Safety & Licensing operator actions to compensate for degraded equipment or DMAP includes a project to weaknesses in plant design. resolve NRC comments on the IPE.
2.4.3 Ineffective Corrective Action Process
- a. The licensee established a high threshold for identifying 2.3.2 2.3 deficiencies.
- b. The licensee did not recognize and document problems, 2.3.1, 2.3, 2.7, performed shallow root cause analysis, and performed 2.3.2 5.1, 5.2, ineffective or untimely corrective actions. 5.3
- c. Many conditions that met the procedural criteria for the 2.3.2 2.3 site-wide deficiency reporting system were never reported under this system. Several departments had separate deficiency reporting systems that were intended to track problems that did not meet the threshold of the deficiency report (DR). Supervisors throughout the organization frequently did not elevate deficiencies into the site-wide corrective action tracking system.
- d. Several interviewees stated that when they identified a 1.3, 2.3 problem, they were assigned the responsibility to correct the identified problem. As a result, operators stated that there was a general reluctance to report problems unless they resulted in equipment damage or were discovered by Operations supervisors.
30
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- e. Even after problems were identified, management 2.1.1, 1.3, 1.4, occasionally did not recognize the safety significance of 2.1.3, 2.3, 2.7, issues. Additionally, the CARB did not facilitate problem 2.3.2 3.1, 4.1, identification or resolution. Plant Safety and Licensing 4.2 personnel often dispositioned identified problems by making restrictive and nonconservative interpretations of the current license bases without stating or considering the safety bases for their conclusions. Plant management facilitated and encouraged this situation.
- f. Root cause analysis efforts often did not distinguish the 2.3.2 2.7 underlying causes of events and deficiencies. The root cause sections of the corrective action reports were often superficial and contained only cursory insight into the underlying causes of the performance deficiency. Root cause determinations were limited to shallow descriptions of events or individual errors and often failed to provide insights to station mangers regarding programmatic weaknesses and human performance hindrances. Root cause evaluators had often not completed formal training and as a result, conducted event investigations inconsistently or ineffectively.
- g. Senior management did not hrve a conservative perspective 2.1.1, 1.3, 2,4, on the limited safety mareic.s in the original design. Many 2.1.3, 4.1, 4.2, of the problems that were identified by the team and 2.2.1 6.1 discussed in other sections of this report were directly related to previous modifications and early decisions that were not well conceived or poorly designed.
2.4.4 Ineffective Quality Oversight and Self Assessment
- a. NPAD and departmental self assessment groups often did not 2.3.1 5.1, 5.2, perform detailed, effective technical assessments. 5.3
- b. Persons in certain key positions within NPAD were 2.1.1, 5.2 marginally qualified in the area being assessed. 2.3.1 31
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- c. Even when NPAD and departmental assessments contained 2.1.1, 5.1, 5.2, NPAD is developing a trend insightful findings, line mangers frequently did not 2.1.3, 5.3 program to focus respond effectively to the observations and 2.3.1 management attention to
, recommendations. issues. Management and the Management Safety Review Committee (MSRC) will review these trends.
The MSRC will provide feedback to Corporate "
Management on these trends and other critical issues.
1
- d. The methods of measuring performance were subjective and 2.1.3 1.5, 2.5 ill-defined, it. some cases.
- e. Many of the NPAD assessments lacked the depth, detail and 2.3.1 5.2
< insight required to fulfill the quality oversight role.
Many NPAD assessors made findings and observations that 4 were primarily focussed on issues that had little, if any, safety significance.
- f. NPAD assessors lacked the experience and background 2.3.1 5.2, 5.3 NPAD has three individuals i necessary to evaluate plant operations, which resulted in with current or former minimal findings. operator's licenses.
l g. NPAD was ineffective in raising problems and concerns to 2.3.1 5.2, 5.3 the appropriate managers to ensure adequate resolution.
- h. Managers often did little to resolve assessment findings in 2.1.1, 1.3, 1.4, such key areas as weak human performance, poor adherence to 2.1.3, 2.3, 2.7, work instructions, policies and plant practices, and loss 2.3.1, 4.1, 5.1, of skilled plant personnel without trained replacement. 2.3.2, 5.2, 5.3 2.3.4 l
- i. The Operations Department performed limited and ineffective 2.1.4, 5.1, 5.3 self assessments. The Maintenance and site Engineering- 2.3.1 Departments had not recently performed self assessments.
i 32
DET STATEMENT ATTACHMENT PPEP OTHER ACTIONS 1
- j. The quality verification (QV) program was not uniformly 2.3.1 5.1, 5.3 The NPAD DMAP will include integrated except within the Maintenance Department. QV an action item for was inconsistently implemented in the Operations and developing QVP Engineering Departments where operators and plant personnel requirements and often incorrectly completed QV activities. methodology for the site.
- k. The measurement and analysis of performance indicators was 2.1.3 1.5, 2.5 inconsistent and potentially misleading. Consequently, site managers were not fully cognizant of actual daily performance trends and lacked the information needed to assess and resolve problems.
- 1. Some corrective maintenance activities were incorrectly Work types and backlog reported as preventive maintenance. reporting categories have been redefined.
Additionally, a review and application of all existing WO work types will be performed. The goal will be to reduce the number of work types and eliminate the possibilities of deficiencies being reported as preventative maintenance.
- m. NPAD did not have valid performance indicators to verify 1.5, 2.5, yearly goals and objectives were met. 5.2 33
DET ROOT CAUSE ATTACHMENT PPEP OTHER 1 ACTIONS 3.1 Acceptance of Low Standards of Performance
- a. Prior to Spring 1994 most managers and staff at Palisades had been long-term 2.1.1, 4.1 employees of CPCo and did not have commercial nuclear experience outside the 2.1.2, company. In addition, neither corporate nor site management encouraged the 2.3.5 review of industry programs and performance standards and comparison of those to Palisades. Consequently, managers did not have or use outside perspectives to judge plant performance.
- b. The effects of low performance standards were evident throughout the 2.1.3, 1.3, 1.6, organization. Operations management failed to recognize or accepted lack of 2.1.4, 2.3, 3.1, rigorous adherence to procedures, inconsistent procedure quality, test results 2.2.3, 4.1, 4.2, that did not always meet acceptance criteria, and poor material condition of 2.3.1, 6.1 the plant. Site and Engineering management failed to recognize or accepted 2.3.4 poor timeliness and quality of engineering evaluations and support to the plant, and recurring lack of control of engineering contractors. Maintenance management failed to recognize or accepted poor maintenance practices.
3.2 Failure to Integrate Processes and Clarify and Communicate Roles and Responsibilities
- a. Management did not clearly identify and communicate to plant staff and 2.1.3, 1.2 department heads the roles and responsibilities of organizational components. 2.2.3 PPEP in This, coupled with a lack of integrated programs and processes across the general organization, resulted in confusion and lack of ownership of problems.
- b. Lack of clearly defined roles and responsibilities between Nuclear Engineering 2.2.1, 1.2, 4.2 and Construction Organization (NECO) engineers and system engineers often 2.2.3 resulted in weak support of Operations and Maintenance in resolving operational problems and evaluating degraded plant conditions. Also, NEC0's responsibility for this important function was unclear and sometimes was abrogated to Systems Engineering or engineering contractors.
- c. The unclear roles and responsibilities of the Nuclear Performance Assessment 2.3.1 1.2, 5.1, Department (NPAD) relative to the line organization resulted in problems not 5.2, 5.3 being identified by either organization in many instances.
- d. When problems were identified, they were not always acted upon by the line 2.3.2 2.3, 5.2 organization, nor were they rigorously tracked by NPAD to ensure that they were satisfactorily resolved.
34
DET ROOT CAUSE ATTACHMENT PPEP OTHER 1 ACTIONS
- e. Certain groups and individuals heavily influenced decisions without plant 2.1.2, 1.3, 1.4, management's providing effective oversight and challenging the soundness of 2.3.2 2.1, 2.2 those decisions. 4.1, 3.3 Failure to Ensure Effective Self Assessment and Quality Oversight
- a. Self assessment by the line organization was ineffective for several reasons. 2.1.3, 1.3, 4.1, Site management did not promote a questioning attitude among the staff, 2.3.1 5.1, 5.3 accountability at many levels of the organization was weak, and implementation of the self checking and independent verification functions under the Qutfity Verification Program (QVP) was inconsistent within and among several departments.
- b. Independent quality oversight by NPAD was ineffective because its interface 2.3.1 1.2, 5.2, with the line organization and its role were not clearly defined by site 5.3 management.
- c. NPAD was staffed with individuals not well qualified in the development and 2.3.1 5.2 conduct of performance based technical audits and assessments, which resulted in poor quality findings.
- d. NPAD did not assert itself to require accountability by the plant to respond to 5.2, 5.3 its findings, and site management did not fully endorse NPAD's role to ensure that this occurred.
3.4 Failure to Develop and Implement an Effective Corrective Action Program
- a. The corrective action process was ineffective because of weaknesses in problem 2.3.2 2.3 identification, resolution, and corrective action implementation.
- b. The high threshold for problem identification, the frequent assignment of 2.3.2 1.3, 2.3 problem resolution to the individual who identified it, and the lack of 4.1 rigorous corrective action implementation management in some cases provided a message to the staff that management did not want to find and resolve problems.
l c. The high threshold for problem identification also resulted in the development 2.3.2 2.3 I
and use of fragmented department-level corrective action systems that used i
different databases and priorities and which were not integrated into the l
plant-wide system.
35
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1 DET ROOT CAUSE ATTACHMENT PPEP OTHER
- l. 1 ACTIONS
- d. Problems were not effectively resolved in many instances because management did 2.1.3, 1.3, 2.3, not promote a questioning attitude in the staff. 2.3.1, 4.1, 2.7 2.3.2
- e. Plant staff was provided limited _ training in root cause analysis and event 2.7 investigation techniques, resulting in many instances of poor quality root cause determinations.
- f. Corrective actions were not rigorously tracked and prioritized across the plant 2.3,' 2.3 because site management had not developed and implemented an integrated corrective action system.
l g. Management information systems were not designed and appropriately reviewed by 2.1.3 1.5, 2.5 management to provide useful feedback on the status of implementation of corrective actions.
i 4
1 36
- - - , _ - - - - _ - - - - . , - - . ,--.,r - ,r. e- - --.. - v - - . ,... a- .r - ~ -- ~ . , - - + - , +
ATTACHMENT 6 Consumers Power Company Palisades Plant Docket 50-255 ACRONYMS August 11, 1994 4
-r -
ACRONYMS AFW Auxiliary Feedwater AMMS Advanced Maintenance Management System A0V Air Operated Valve AP Administrative Procedure CARB Corrective Action Review Board CCW Component Cooling Water CM Corrective Maintenance ;
CO Control Room Operator J l
CPCo Consumers Power Company DEPRT DET Response Team DET Diagnostic Evaluation Team DG Diesel Generator DMAP Department Master Action Plan DR Deficiency Report E0P Emergency Operating Procedure FPI Failure Prevention, Incorporated HPES Human Performance Evaluation System HPSI High Pressure Safety Injection I&C Instrumentation and Controls ID Identification IPE Individual Plant Examination ISI Inservice Inspection IST Inservice Test LA0 Licensed Auxiliary Operator MAG Management Advisory Group MIS Management Information System MOV Motor Operated Valve MRB Management Review Board MSRC' Management Safety Review Committee NEC0 Nuclear Engineering and Construction NPAD Nuclear Performance Assessment Department NRC Nuclear Regulatory Commission OER Operating Experience Review OIR Operations Information Report ,
PM Preventive Maintenance PPAC Periodic and Predetermined Activity Control PPEP Palisades Performance Enhancement Program QV Quality Verification QVP Quality Verification Program l SALP Systematic Assessment of Licensee Performance SS Shift Supervisor !
ST0 Switching and Tagging Order l
TS Technical Specifications VM Vendor Manual ,
WO Work Order l l
l