ML20095A454
| ML20095A454 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/13/1984 |
| From: | Fogarty D SOUTHERN CALIFORNIA EDISON CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8408210479 | |
| Download: ML20095A454 (6) | |
Text
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Southern California Edison Company g6 P O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CAurORNIA 91770 7ggg,gogg DAveo J. FooARry anscutivs vecs entseoaset 213 572-2796 August 13, 1984 Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. R. C. DeYoung. Director
Dear Sir:
Subject:
Docket No. 50-362 Additional Response to Notice of Violation and Proposed Imposition of Civil Penalties San Onofre Nuclear Generating Station, Unit 3
References:
(1)
Letter, Mr. J. B. Martin (NRC) to Mr. D. J.
Fogarty (SCE), " Notice of Violation and Proposed Imposition of Civil Penalties,"
dated May 16, 1984 (2)
Letter, Mr. D. J. Fogarty (SCE) to Mr. R. C.
DeYoung (NRC), " Response to Notice of Violation and Proposed Imposition of Civil Penalties," dated June 15, 1984 (3)
Letter, Mr. R. A. Scarano (NRC) to Mr. K. P.
Baskin (SCE), dated July 25, 1984 Referenced letters (1) and (2) provide, respectively, a Notice of Violation and proposed imposition of civil penalty and a response thereto which includes Southern California Edison Company's request for remission of the proposed civil penalty.
The purpose of this letter is to provide additional information concerning corrective action that has been or is being taken by SCE to address management's responsibility to ensure against continuing errors in operating performsnce, d
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i Mr. R. C. DeYoung Page 2 August 13, 1984 Reference (2) briefly noted that SCE has devoted considerable attention to remarks made by Mr. DeYoung and Mr. Martin at a May 9, 1984. Enforcement Conference concerning the need for management and supervision to become more consis-tent and effective in ensuring that management controls are being properly implemented in all areas.
The letter noted that a multiple action plan had been developed in this regard, and had been provided to the NRC Senior Resident Inspector for information, but it did not include a description of the plan or a discussion of its objectives.
At a subsequent Enforcement Conference held on August 8, 1984, at the SCE General Offices in Rosemead, action taken in response to the need for core effective management and supervision of operational activities was described, and a status report was provided.
This action is summarized in an enclosure hereto.
These actions include: increased management presence in the plant by conducting routine system walkdowns and in plant inspections; increased management communication in plant operation; and improved management attention to detail.
During the meeting on August 8, Mr. Martin emphasized the importance of SCE performing tough, critical self-appraisals of performance on a continuing basis.
Similarly, Reference (3) discussed the importance the NRC places on intro-spective assessments by SCE of operating incidents.
SCE agrees that this is our responsibility, and we are committed to ensure that such appraisals and assessments are conducted consistently and that appropriate corrective actions are taken promptly in all areas.
While due attention will be given to deficiencies i
in operator performance and in procedures for operation, special emphasis will be given to the need for detection of deficiencies in management and supervisory monitoring and control systems.
Included in the actions described in the l
enclosure are items to specifically address this responsibility.
l Finally, as we indicated at the August 8 meeting, SCE welcomes the constructive comments and insights we have re-I ceived from NRC oversight of our activities.
We recognize our obligation to identify and correct deficiencies ourselves, and we will continue to pursue that obligation aggressively.
If there are any questions or comments in this regard, please let me know.
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Mr. R. C. DeYoung gE Page 3 August 13, 1984 Subscribed on the l/I day of 006/167 1984.
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Enclosure cc:
J. B. Martin (USNRC Regional Administrator. NRC Region V)
A. E. Chaffee (USNRC Senior Resident Inspector. Units 1, 2 and 3)
J. P. Stewart (USNRC Resident Inspector. Units 2 and 3)
A. J. D'Angelo (USNRC Resident Inspector. Unit 1)
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Enclosure SUIGtARY OF ACTIONS TAKEN TO IMPROVE MANAGEMENT AND SUPERVISORY EFFECTIVENESS RNQUIREMENT Essential to operational excellence at San Onofre is a comunitment by management and supervision to ensure through direct, personal contact and observation that activities are conducted properly and in strict compliance with requirements. This comunitment must be maintained consistently throughout the responsible organizations.
IMPLEMENTATION Although this requirement has previously been responded to in a variety of ways, in order to achieve significant additional effectiveness, a consensus process was used to identify and implement specific actions by the site organization as a whole, some actions are refinements of prior practices, and others represent new initiatives.
ACTIONS Actions have been or are being taken in six broad areas. The areas and examples of the actions being taken, are as follows:
1.
Actions to Increase Management Awareness of Performance Objective Provide for broader scope and greater depth of each manager's personal awareness of operational performance.
Exasples:
a.
Implemented a systematic management monitoring and feedback program to identify and correct deficiencies and to facilitate comununication of observations leading to improvements in operation.
b.
Established a management forum, separate from the safety comunittees, to regularly and critically evaluate specific incidents and performance, generally and to identify areas and means of achieving improvement.
Improved regular communication concerning plant operations c.
with respect to detail, timeliness and audience, both upward and downward.
2.
Actions to Focus Appropriate Management / Supervisory Attention on Highest Priorities objective Remove distractions and roadblocks preventing full management and supervision attention to, and involvement in, operational activities.
i Examples:
a.
Evaluate, and modify if necessary, the role and performance of supporting organizations to the Station.
b.
Systeistically identify and remove specific roadblocks for each individual manager and supervisor.
3.
Actions to Improve Management / Supervisory Performance Objective: Systematically correct both supervisory skills deficiencies and operational skills deficiencies.
Examples:
a.
Evaluate, and modify as necessary, organizational and individual descriptions of responsibilities and authorities.
' clarify individual understandings of these descriptions, b.
- Implement a formalized management and supervisory skills development program specific to San Onofre.
c.
Review, and adjust as required, supervisory spans of control, d.
Affirm the status and authority of the Plant and Shift Superintendents.
e.
Continue to increase the use of licensed persons in operations support and management roles.
4.
Action to Improve Organizational Integration and Two-Way Communication objective: Ensure that, management and supervision are fully involved in effective group and individual communication processes to identify and implement actions to improve performance.
Examples:
a.
Increase use of interactive communication techniques.
b.
Utilize independent audit and evaluation resources to l
identify areas and means of improvement.
i l
l S. ' Actions to Improve Effectiveness of, and Management Participation in Training l
l Objective: Use Training and Management resources together to more directly l
address performance requirenents as well as basic knowledge requirements.
Examples:
a.
Increase training specifically directed to professionalism, including formality and attention to detail, b.
Increase the systematic involvement of management and supervision in the formal training process.
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. o c.
Provide dedicated, licensed supervision of operational on-the-job training.
d.
Implement a qualification and bonus program for nonlicensed technical personnel which is based on demonstrated knowledge of the administrative controls.
6.
Actions to Independently Evaluate Supervisory Roles in Operations Objective: Determine if additional actions to improve performance in the area of Operations can be identified based on INFO experience.
Examples:
a.
Implement modifications to the Units 2 and 3 control room area to relocate supervision closer to the activities for which they are responsible.
b.
Increase the extent to which supervisors actively coach and critique the performance of their assigned operators.
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