ML20099B437

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Forwards Response to Issues Raised in Insp Repts 50-324/90-12 & 50-325/90-12.Encl Outlines Methodology & Criteria for Defining Work That Will Be Completed Prior to Startup & Details Corporate Improvement Program
ML20099B437
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 07/23/1992
From: Watson R
CAROLINA POWER & LIGHT CO.
To: Ebneter S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NLS-92-160, NUDOCS 9207310159
Download: ML20099B437 (40)


Text

CP&L Carolina Power & Light Company P. O Box 1551

  • Ra6ep N C 27602 JUL 2 31992 SERIAL:

NLS-92-160 H. A. WATSON Sener %ce Presdent Nuclear Generaten Mr. Stewart D. Ebneter Regional Administrator United States Nuclear Megulatory Commission 101 Marietta Street, N.W.,

Suite 2900 Atlanta, GA 30323 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET HOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REPLY TO NRC INSPECTION REPORT NOS. 50-325/90-12 AND 50-324/92-12

REFERENCES:

1.

Letter from Mr.

S.

D. Ebneter (NRC) to Mr. R. A. Watson (CP&L) dated May 27, 1992, Inspection Report Nos. 50-325/92-12 and 50-324/92-12.

2.

Letter from Mr.

S.

D. Ebneter (NRC) to Mr. Sherwood H.

Smith, Jr. (CP&L) dated June 23, 1992.

3.

Letter from Mr. Sherwood H. Smith, Jr. (CP&L) to Mr. James M. Taylor (NRC) dated September 27, 1989.

4.

Letter from Mr. R. A. Watson (CP&L) to Mr.

S. D. Ebneter (NRC) dated June 26, 1992.

Dear Mr. Ebneter:

This letter addresses the issues raised in your letters dated May 27 and June 23, 1992.

It is also consistent with our presentations to the NRO on May 12 and May 15, 1992 and the contents of,our letter of May 29, 1992.

Included are:

1) a statement of CP&L's commitment to improve the Brunswick Nuclear Plant, 2) a description of the Brunswick Plant startup plan, and 3) a description of the Company's long-term improvement program.

The enclosures specifically address-the four topics outlined in the enclosure to your letter of June 23, 1992.

IMPROVEMENT QQMMITMENT We are committed to the successful implementation of an improvement program for the Brunswick Plant.

This progrem ine udes our goals of higher standards l

for the maintenance and operation of the Bruntwick Plant and it establishes the foundation for sustainable levels of good performance over the long term.

Resources are being provided to achieve reductions in the backlog of work and to improve substantially the material condition of the plant and its WRC BNP.PS2 -

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Mr. Stewart D. Ebneter NLS-92-160 / Page 2 equipment.

Further, aggressive steps are being taken to establish the correct philosophy of operations and to strengthen werk control processes.

In April 1992, after the signif' nance of the structural deficiencies was apparent, CP&L voluntarily removed the plant from service.

While making the various structural inspections, we have undertaken a comprehensive review of Brunswick's improvement needs. We are pursuing a rigorous effort to identify necessary repair and modification work needed at the plant. We expect to demonstrate that the plant's material condition has been markedly improved and that the backlog of work has been reduced by completion of our structural reviews which are curren'ly targeted for October 1, 1992 for Unit 2 and November 15, 1992 for Unit 1.

As you know, substantial improvements in several areas were started before the April 1992 structural inspection outage.

For example, about 18 months ago, we began a full-scope-design basis reconstitution. Also, engineering activities were initiated during the past year to upgrade the electrical distribution system (two startup transformers and a fifth diesel generator).

Further, managerial changes were made that strength nod our corporate and site teams.

A Supervisory Development Program has been established and construction of a largo, permanent office facility on-site is well underway.

The improvement initiatives outlinad in this report, and others in place and planned, will significantly improve performance and provide the foundation to sustain the improvements.

The'improvament program at Brunswick is both an aggressive short-term effort and a comprehensive long-term effort. Successful implementation will require management commitment and follow-through. We nove demonstrated a corporate commitment by providing an additional $200 million to $225 million over the next five years for improvements, in addition to those included in our five-year business plans. We know changes in managerial effectiveness are required for a long-term solution to challenges at Brunswick. We believe the initiatives set forth in the enclosed Pre-Startup Plan and in the Corporate Improvement Program (CIP) demonstrate our total commitment to improve the material condition of the plant, our business processes and the effectiveness of our work force.

In order to assure-total corporate involvement, our improvement efforts will be directed by department heads who will be accountable to CP&L's Senior Vice President - Nuclear Generation for the full implementation of action plans and, most importantly, for the achievement of the intended benefits of improvement initiatives.

In addition to senior line management,:CP&L's Senior Nuclear Advisory Committee (which consists of the Executive Vice President - Power Supply, Executive Vice President - Financa and Administration,-Senior Vice President - Legal and Regulatory Services, and the Senior Vice President - Nuclear Generation) will receive periodic reports

'on the progress and results of the improvement initiatives.

In order to increasa the success of this improvement program as compared to the Integrated. Action Plan (IAP), a review and analysis of the IAP was conducted with the intent of identifyin? 'essons learned and applying them to the design of the Corporate Improvement agram. The results of this WRC-BNP.PS2

4 Mr. stewart D. Ebneter NLS-92-160 / Page 3 assessment will be presented along with further details of our Corporate Improvement Program by the end of August. compares car current approach with the approach used for the IAP.

We acknowles e the value of the NRC'r current ongoing monitoring of our j

s inprovement initiatives, and we will cooperate fully in establishing assessment methodologies that will meet NRC oversight needs.

EBK-$7AMTUr ELM outlines our methodology and criteria for defining the work that will be completed prior to startup. The process calla for placing identified work' efforts which are not already scheduled for completion during the current outage or new emergent so.+ items into one of seven possible categories and then applying a set of criteria to determine if the work effort should be a pre-startup condition. We have established a multi-disciplined team at the site to implement this process. Work not completed within the pre-startup period will be completed while the plant is on line or during future outages. lists specific work efforts that will be completed prior to startup. The items in the Pre-startup Plan are either commitments we have made or itemn that will be managed through application of the methodology and critoria set forth in Enclosure 2.

In addition, emerging work and needs j

identiflod during the inspections and walkdowns specified in the Pre-startup Plan will be processed according to the methodology in Enclosure 2.

We have categorized the ire-startup work efforts into the categories identified in the enclosure to your June 23, 1992 letter.

Those categories are 1) equipment corrosion problems, 2) backlogs of deferred maintenance work, 3) potential structural deficiencies related to' steel, block walls, and supports, 4) backlog of temporary work-around_ conditions,_and 5) equipment

-deficiencies discovered during walkdowns. -In addition, we have added a sixth category -- other work ef forts -- to reflect additional work not covered by the five categories.

More than 600 CP&L and contract pers nnel have been added to ensure these-initiatives are_successfully completed, Major staff augmentations are detailed belows Three (3) additional CP&L traveling maintenance crews (20 mechanics 'and e

10 I&C personnel) have returned to the Brunswick Plant following work on the H.

B.' Robinson plant outage. These crews are home-based at Brunswick, are experienced with Brunswick procedures and routine surveillance testing, and are expert on certain equipment.- They are resolving Work Requests / Job orders and performing surveillance tests.

Technical _ support has added six (6) contract engineers to support-e maintenance activities.

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Mr. Stewart D. Ebneter NLS-92-160 / Page 4 Approximately 3 60 contract personnel are either currently on-site or e

will be shortly to support mechanical, I&C and electrical maintenance, E&RC, Corrective Action Program (CAP), and Operations staff personnel.

outage management and modification resources have been augmented by e

adding approximately 200 craft workers, 34 I&C Technician and 100 general laborers.

Approximately 125 contract personnel have been brought in to date to support the Nuclear Engineering Department (NED). This supplements the normal staffing level of NED Brunswick Engineering Section personnel,'

which is approximately 190 people (site and corporate).

Many of the work items listed in Enclosure 3 have already been completed.

Also, many work items which could be performed post-startup will, in fact, be completed before startup. Completion of the work items listed in Enclosure 3 will represent a significant improvement in the material condition of the plant. Ww recognize, however, that a backlog of deferred maintenance and modification work will remain.

We will establish an organization dedleated solely to the reduction of this remaining backlog. Prior to startup from the current outage, the oncklog items to be assigned to this organization will be specifically identified, and this organization will remain in place until the i

Jork items assigned to it are satisfactorily addressed.

CQBf0 RATE IMPROVEMENT fjl2GPM Clearly, the nctions required to achieve sustained higher performance levels at the Brunswick Plant are complex and interrelated.

In order to fully address this issue, we have initiated the development of a long-term performanco improvement plan which is conceptually shown in Figure 1.

The primary purpose of the Corporate Improvement Program is to create the foundation for a sustained level of good performance.

CP&L's corporate and site management recognizes-the degree of change that must occur at the Brunswick Plant to establich this foundation for substantial improvement.

The specific _ objectives of this Corporate Improvement Program represent, in our view, the results this program must achieve. These objectives area Reduce the backlog of work at Brunswick and maintain equipment in o.

accordance.with design and operating standards so that the permanent plant staff has the opportunity to focus on managing the safe and reliable operation of the plant.

Establish.and instill a new philosophy of operations in which all employees perform to the high standards necessary to achieve an attitude of continuous improvement in performance.

Redesign work management processes in order to remove impediments to working efficiently and effectively.

hRC BNP.PS2

l Mr. Stewart D. Ebneter NLS-92-360 / Page 5 As shown on Figure 1, this program is built on four key initiatives which will guide improvements in management processes, philosophy of operations, and other actions needed to sustain improved performance of the Brunswick Plant When fully impismented, these improvements will 1) demonstrate management'.

commitment to high standards for material condition of the Brunswick Plan

2) illustrate managenent's strong leadership and support for improving pia performance, and 3) create a strong self-assessment work climate which recognizes problems and implements effective corrective action.

The four key initiatives of the improvement program are described below 1.

We will develop and implement corpoaate and site standards for the Brunswick Plant, and our other nuclear units, which are higher and more specific than current standards. We will effectively communicate these standards throughout the Nuclear Generation Group organization, integrate them into the work practices of our employees, and monitor

. performance against them.

2.

We will improve and strengthen our planning and action monitoring processes. This will provide heightened vieibility as to the accomplishment of planned work and as to the level of effort needed to perform in accordance with standards. We are modifying the processes for-identifying, planning, and monitoring improvement projects to support an Integrated Schedule Program (ISP).

The initial Brunswick ISP will be submitted in october 1992.

3.

We will strengthen the linkage between the planning and budgeting processes to ensure that resources necessary to carry out our plana, and thereby achieve our standards, are clearly identified and provided over the long term.

For 1992, we have authorized funds, in addition to the approved budget, for improvements which can proceed immediately.

For 1993, we are bttdgeting our performance improvement projects separately from our routine operations. This enables us to evaluate and fund, as appropriate, an improvement project on its own merits.

New direction for our budgeting process has encouraged identification and documentation of additional improvements.

4.

Finally,-we.are alao identifying -- and will undertake -- other actions to establish a work climate which consistently encourages effective, critical self-assessment, the identification and resolution of problems by all employees, and secures the commitment of all employees to the achievement and maintenance _of the established quality standards. -The commitment to more aggressive' identify and correct problema is illustrated by the extensive u..pections, repairs, and modifications currently underway.

The actions during this current outage are reinforcing the communications to employees that higher standards will be set and achieved, that deviations will be identified, and that resources will be provided to impicment prompt corrective actions. - In

~

addition, senio: management at the site and at corporate will communitate the importance of the timely resolution of problems, hold H C* p P.PS2

Mr. Stewart D. Ebneter NLS-92-160 / Page 6 the responsible line and support organizations accountable for meeting commitments to resolve problems, and demand increased monitoring of plant performance and ownership of identified problems by support groups.

Based on these four key initiatives, the Corporate Improvement Program (CIP) for the Brunswick Huclear Plant consists of 22 specific improvement projects.

An executive summary of these projects is presented in Enclosure 4.

We recognize that the CIP must reflect our thorough assessment of the root causes of the performance deficiencies at Brunswick.

Your reports and our orn assessments currently lead us to root causes which are addressed by the four key initiatives discussed above.

As a result, we have identified the improvement projects outlined in Enclosure 4.

We believe, however, that an additional effort must be made to verify and confirm that we have fully addressed all N M needs at Brunswick. Therefore, an improvement project to verify root causes has been included in the Corporate Improvement Program.

The objectives of this project are to ensure consensus on the root causes at the corporate and site level and to identify and enauro the development and implementation of specific strategies to address those root causes. When the verification is complete, the Corporate Improvement Program will be modified as needed to address additional root cause problems.

Other needs may be i

identified as we proceed with implementation of these projects.

We are committed to make other modifications to the improvement program when needed to ensure that we remain focused on the actions required to achieve our objectives.

The Corporate Improvement Program is a corporate initiative.

Its successful implementation is the responsibility of the Senior Vice President of the Nuclear Generation Group. We recognize that to sustain a high level of system nucles serformanes, we must have a comprehensive program that is implemented consistmatly_in the organizations _ involved in CP&L's nuclear _ operations.

Thus, while the focus of this letter is on the Brunswick Plant, the Corporate Improvement Program will apply to each of our plants and to the rest of the Nuclear Generation Group.

In addition, steps will be taken to ensure that each project achieves the benefit intended. The Nuclear Assessment Department will provide independent oversight as to the effectiveness of the Corporate Improvement Program.

Further, the final step in closing out each project will be a presentation by the manager responsible for the project to the Senior Nuclear Advisory Committee. This presentation will define benefits and will identify the means for ongoing monitoring to ensure that the desired results are maintained.

One of thw improvement projects -- the implementation of the Integrated Schedule Program (ISP) -- bears special mention in this letter.

The ISP will contain the schedule and resource commitment for Level 1 regulatory commitments, Level 2 e mmitments in excess of $250,000, for plant modifications over $250,000, and for other substantial improvement efforts.

The ISP will be updated every six months and provided to the NRC.

Overall, the ISP will permit corporate management and the NRC to monitor the completion WRC SNP.P$2

Mr. Stewart D. Eoneter ML5-92-160 / Page 7 of comuitments and other initiatives. The ISP will be implemented at all three plants.

An overview of our Corporate Improvement Program is contained in Enclosure 4.

By the and of August, a comprehensive presentation will be available to you and your staff on this corporate Improvement Program.

This presentation will cover the administration of this program and will provide specific details on each of the improvement projects.

We are confident that this program will be successful in producing the results which are needed to achieve and sustain a high level of performance.

The expected results ares 1.

Communication of management expectations and standards through specific work management policies and standards and development of a disciplined oversight program to ensure that corporate management closely monitors efforts to implement and sustain these standards.

2.

Increased corporate and site management involvenent and oversight with particular emphasis on past chronic performance concerns and on improved communication between plant management and corporate management.

3.

Improved management effectiveness at the Group and Department level, especially with respect to communications, positive leadership, and the establishment of a clear hierarchy of administrative policies and procedures.

4.

Improved work. control processes resulting from the near-term implementation of recommendations of the Staff Assistance Team and the longer term redesign of the maintenance maragement process and the engineering analysis and modification process.

5.

An improved self-assessmwnt and corrective action program. The improvements will be built upon a root cause analysis to determine why the existing procedures have not been effective and the implementation of appropriate changes based upon that assessment.

6.

Improved plant material condition through the.significant reduction of existing backlogs, the establishment of an organization for further reductions of the current backlog, and the establishment of appropriate standards to facilitate the future management and control of backlogs.

7.

Improved personnel development and training which will increase-the-

-effectiveness and capability of management and non-management personnel.

This result will-flow from the implementation of a Supervisory Assessment center to identify candidates for supervisory positions, the continued implementation of a Supervisory Development program to provide supervisory candidates training in the skille needed to'bo effective, and the restructuring of the technict1 training program to increase the effectiveness of the skills _and hands-on training activities.

NRC BNP.P12

- -..~... - -. -

- ~ -..

Hr. Stewart D. Ebneter NLS-92-160 / Page 8

SUMMARY

CP&L is committed to provide the resources necessary to implement promptly and effectively the improvements which are necessary to achieve sustained, high levels of performance at the Brunswick Plant and to meet all regulatory requirements. Over the next five years, the company has corrsnitted over $200 million to improve the Brunswick Plant, over and above the substantial financial resources previously approved in the Brunswick Plant business plan for this period.

l We believe that the actions described above will enable the Brunswick Plant to achieve a long-term, superior operating performance. We look forward to meeting with you and others in the NRC to review our plans, schedules, and progress.

I l

Yours very truly, h bb YW t

R. A. Watson PS/ecc Enclosures pc NRC Document Control Desk Mr. L. W. Garner Mr. N. D. Le Hr R. H. Lo Mr. B. L. Hotafari Hr. R. L. Prevatte Hr. J. E. Tedrow Affirmed by:

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Corporcto improvamant Program esgure i Brunswick Nuclear Plant Program Overvlow rah %dg&RRurposeMW&rN k Create the Foundation for Sustalnnbic Levels of Good Petformanco 188& f7** e O b' ectivesem,k

  • Reduce backloa to mannaeable levels
  • Institutionalize A new phil5 sophy of operations
  • Remove the barriers to success M

, r mp ementlnm ywgmgy:nwxm Opprn ts? g; Pro}ectsMR@

s ve + v er s; + 2 -

1. Root Cause Verification
2. Work Mana0ement Policies and Standards
3. Communication of Work Management 4A Policios and Standards N W id!! Q M A s u / W il e

x., y ' W o g:rhuative r

! FourbyJ.pgep p +:

f =, D.c w %fhtw%xPecte s

4 imp,o,em,ni pi n,,o, Standards 9 g s sev, wn

6. First year Rev6ew of Standards e Communication of I.

Develop Higher and

8. Reporting of Standards Compliance Expectations an; More Specific Standards Expectations and
7. NGO Policy and Procedures Manuals Restructura Standards e increased Site and
8. Role Change for Nuclear Services Department Corporate Management
9. Corrective Action Assessment involvement and Overs!ght (n"dards
10. Integrated Schedule Program es e and Create Effective N
  • Improved Management
11. Business Planrang Process Review Monitoring Methods Effectiveness
12. Supervisory Assessment Center e improved Work fil. Provide Additional
13. Supervisory Development Program Control Process 6s Resources to
14. Technical Training Program
  • Improved Self.

Implement Assessment and improvements

16. Staff Assistance Team Recommendations Corrective Action Resolution Program IV.

Establish an Attitude

10. Modification Process Redesign
  • Improved Plant of Continuous 17, Maintenance Process Redesign Material Condition improvement in Performance
18. Work Control Methodology
  • Improved Personnel
19. Monthly Plant Material Condition and Tia ning Housekeeping Report
20. Long Term Dack log Reduction
21. Organlaation Effectiveness improvements
22. Nuc:sar Assessment Department Review and Evaluation l

ENCLOSURE 1 COMPARISON OF APPROACHES FOR THE INTEORATED ACTION PLAN TO THE CORPORATE IMPROVEVINT PROGRAM

ENCLOSURE 1 COKPARISON OF APPROACHES FOR THE INTEGRATED ACTION PIAN TO THE CORPORATE IMPROVEMENT PROGRAN The Inttqrated Action Plan f!AP)

The Integrated Action Plan (IAP) was developed by CP&L in 1989 to provide a plan for actions to be taken to correct e variety of issues identified by the Diagnostic Evalaation Team (DET) and by CPGL-initiated audits. While some improvaments attributable to the IAP have been noted, the continuing problems described in the NRC letters of May 27, 1992 and June 23, 1992 are evidence that the IAP has not been fully effective in achieving its objectives.

The Coroorate Improvement Proorse Fgr the Brunswick Nuclear Plant (C[El The Corporate Improvement Program (CIP) is a broad corporate initiative to address the need for an improved philosophy of operations, a strengthening of corporate involvement, and more effective work control processes to facilitate sustained improvement in operations.

The CI/ has been structured and designed and will be implemented in a manner that will overcome the identified reasons for the ineffective implementation of some of the initiatives in the IAP.

Kev Differences Btiween the IAP and CIP Listed below are the essential differences between the IAP and the CIP in their structure and in their implementation approach. CP&L expects that these dif ferences will heln to assure that the CIP is totally successful.

ImplCeentation A EI2Ach - The IAP consisted of a large number cf E

individual action plans, and theen plans were ansigned, typically, to managers within tbc Brunswick Nuclear Plant.

Status reports on implementation usually addrestod the completion of tasks but were not necessarily correlated back to the broad root issues. With respect to the CIP, there will be a significantly fewer number of individual projects than was the case foc the IAP; but these projects will be, generally, much broader in scope, with much better defined objectives. Also, the projects will be assigned to a department manager or Group Executive, and the projects will not be accepted by CP&L as complete until it has been demonstrated that the desired broad-based result has been achieved. Plant line management will be directly involved in the development of the action plans.

Corporate invo)vemeDi - Many of the IAP initiatives addressed

-Nuclear Generation Group and corporate infrastructure issues, such as policies, standard practices, and generally accepted ways of doing business.

Since the action plans were typically the responsibility of managers at the Brunswick Nuclear Plant, it was ENCL _1 El-1

difficult to create corporate-or group-level involvement in the solution to issues.

Since the CIP will be a corporate initiative with corporate officer responsibl.lity and accountability, the need for corporate involvement is addressed.

_I_ndividual Project Fundino - The individual initiatives of the IAP e

were, f ran a f unding perspective, integrated into ongoing work efforts and budgets of Brunswick Nuclear Plant.

In order to ensure that the correct level of resources is made available to support the CIP, individual projects requiring an annual investment over $250,000 will be identified and will be funded separately. This funding will be over and above the funding for normal operations.

Dedicated Staff - Implementation of the IAP action plans was, for the most part, a collateral duty for Brunswick Nuclear Plant managers and staff. Significant work efforts in the CIP will receive not only separate funding, but they will have full-time teams and dedicated project managers assigned who have the necessary time to devote to the project.

Egone, Results Drientation, and Communicati.2D - The measures of effectiveness were not defined in advance for the IAP action items.

For the CIP, the desired results will be made clear at the outset. This better definition of expected results will then provide the opportunity for improved communication as to the status of the individual improvement projects.

ENCL _1 El-2

. _. _ _. _ _.. _ _ ~. _ -

ENCLOSURE 2 i

NETHODOLOGY FOR ESTABLICHING CORRECTIVE ACTIJNS AS PRE OR POST-STARTUF

_. ~..

- ~ _ _ -.. _,

ENCLOSURE 2 NET 110DOLOGY FOR ESTABLISHING CORRECTIVE ACTIONS AS PRE-OR POST-STAR 7VP A.

Outstanding corrective actions are identified and included in a list of work items. Many of these items are scheduled for resolution during the current outage.

Some are considered mandatory and are included in the pre-startup lict. (Eraclosure 3)

B.

Items (such as maintenance, design or structural deficiencies, etc.)

which are not currently scheduled on the pre-startup list, or new emergent items, are screened and placed in one of the following seven categories (See Exhibit E2-1) 1.

Actions to meet operability requirements in Technical Specifications 2.

Actions to materially improve safety system availability 3.

Actions to restore the design bases of the plant 4.

Actions to comply with docketed commitments related to the current outage S.

Actions to address operator

  • work arounds" 6.

Actions to materially improve plant operating reliability 7.

Other C.

The screening criteria to determine whether item is pre-startup or post-startup are outlined below 1.

Pre-startup a.

Category 1 items.

b.

Category 2 through 6 action.3 are pre-startup with the following exceptions:

(1)

Refueling operational configuration (OPERATIONAL CONDITION 5) is required to implement the action.

(2)

Engineering is unavailable to support implementation within the established work closeout dates of October 1, 1992 for Unit 2 and November 15, 1992 for Unit 1.

(3)

Haterials are unavailable to support implementation within the established work closeout dates of October 1, 1992 for Unit 2 and November 15, 1992 for Unit 1.

(4)

Items which cannot be physically accomplished within the established work closeout dates of October 1, 1992 for Unit 2 and November 15, 1992 for Unit 1.

ENCL _2 E2-1

2.

Post-startup Category 7 items and Category 2 through 6 items by exceptions identified above.

D.

The Plant Nuclear Safety Committee (PNSC) reviews Category 2 through 6 exceptions to evaluate if changes in (a) plant condition, (b) engineering and/or procurement schedules, or (c) stanned start-up dates are warranted to complete the action item prier to start-up.

Recommendations from PNSC are forwarded to the site Vice President for final approval.

Category 4 recommendations which deviate from docketed commitments related to the current outages will be reviewed with NRC for concurrence.

ENCL _2 E2-2

Logic Procoss For Distinguishing Exhibit E21 Pre-and Post-Startup Work items Work List

,r items (such as inalntenance, design or structural deficiencies, etc.) which are not currently scheduled, on the pre startup list, or new emergent items.

Pre-Startup DeterminatlOn Tech.

Ye8 opec. or NR I

3 Commitment to Pro. Startup No g Safety System Availability l

+

    • 9" Does item Meet Exception Docketed C mmitment l

+

~... c.n. ~..

c,..... o...

gOperator Work Arounds l

n.. p uot A

.w.

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  • c n so worses ontM.

gOperating Reliabillty l

  • 6e.terw Not Av.s.w.

E Other 1,

Yes t

PNSC Review and Assessment Site

v. R Review

,,/\\

Y

> Post-Startup List

> Pre-Startup List Vpp,o;.i piepimlmisu uui m i1 h

...i ENCLOSURE 3 PERFORMANCE IMPROVEMENT PROGRAM SHORT TERN.%CTIONS (REQUIRED PRE-STARTUP)

W i i id

ENCLOSURE 3 PERFORMANCE IMPROVEMENT PROGRAW Sil0RT TERM ACTIONS (REQUIRED PRE-STARTUP)

The following is a list of actions which will be completed prior to start-up.

The list includes work items that are the subject of previous docketed commitments and which have been identified and w' i be managed using the methodology listed in Enclosure 2.

CP&L has idencified a significant number of work items that are not considered mandatory but will be done prior to startup.

(ENCL _3)

E3-1

ENCLOSURE 3 PERTORMANCE IMm'ROVEMENT PROGRAM SHORT TERM ACTIONS (REQUIRED PRE-STARTUP)

COMPLETION ITEM SCHEDULE DESCRIPTION NO.

l, A - Equipment Corrosion Problems Prior Coreplete corrosion repairs to existing service water lubrication water piping Al to supports.

Start-up Prior A2 Perform a third-party walkdown of non-pipe support short term structural integrity items and pipe supports in areas with high corrosion potential to to validate design assumptions. Address any identified deficiencies in accordance Start-up 1

with the methodology in Enclosure 2.

A3 Address corrosion repairs of seismic instrument racks in accordance with the Prior to methodology in Enclosure 2.

Start-up B - Deferred Equipment Maintenance Issues B1 Correct the 480 VAC emergency bus feeder breaker spring tension.

Prior to Start-up Completo B2 Repair the Unit 1 UFS primary inverter.

Complete B3 Complete the Unit 1 battery discharge testo.

B4 Complete the Unit 2 turbine exciter coupling ctsngeout and alignment.

Complete Installation Install modifications to enhance Unit 2 turbine partial arc operation.

B5 Complete Coreplete refurbishing the Unit 2 control valve power packs and changing out Complete B6 turbine electro-hydraulic control system accumulators.

EJ-2 (ENCL _3) f u

l-l

ENCLOSURE 3 PERFORMANCE IMPROVEMENT PROCRAM SHORT TERM ACTIONS (REQUIRED PRE-STARTUP)

COMPLETION ITEM SCHEDULE DESCRIPTION NO.

Cormlete B7 Complete inspection of cylinder 4L on emergency diesel generater 3.

Complete B8 Replace the 2B reactor feed pump wear ring.

Complete B9 Repair the IB control rod drive pump.

Replace current transformers in the emergency busses that would require a dual complete BlO unit outage.

Prior Bil F.odify main stack radiation monitor isokinetic sampling probe.

to Start-up l

l C - Potential Structural Deficiencies Prior C1 Complete Unit 2. and Unit 2 Drywell Phase 2 miscellaneous steel walkdowns and Unit 1 and Unit 2 Reactor Building Phase 1 Miscellaneous steel walkdowns. Complete to preliminary bounding load studies.

Address repairs, as required in accordance Start-up with the methodology in Enclosure 2.

Prior Repair of five reintorced concrete non-load bearing wall panels in the diesel C2 to generator building to restore them to their design configuration.

Start-up Prior Complete repairs to structural angle restraints for diesel generator building C3 to bicek walls to restore the walls to their design configuration.

Start-up C4 Perform a design review and a field inspection review, when necessary, of the Prior to non-safety masonry walls at the Brunswick Plant to verify the walls are app opriately classified. Address any identified deficiencies in accordance with Start-up the methodology in Enclosure 2.

E3-3 (ENCL _3)

ENCLOSURE 3 PERFORMANCE IMPROVEMENT PROGRAM SHOnT TERM ACTIONS (REQUIRED PRE-STARTUP)

COMPLETION ITEM SCHEDULE NO.

DESCRIPTION Remove accessible non-functional through-bolte and install cover plates over the Complete C5 holes in the diesel generm-tor building walls.

C6 Perform an integrity in pection (i.e.,

for cracks, general condi* ion) of Prior unreinforced masonry walls that are classified as safety-related. Address any to identified deficiencies in accordance with the methodology in Enclosure 2.

Start-up C7 Complete repairs of upgrading seismic classification walls in the control Prior to building (elevation 49 foot) that have been determined to ha required post-Start-up earthquake for control room habitability requirements.

CB Perform a review of IE Bulletin 80-11 program for the Brunswick Plant.

The Prior to review will address existing masonry wall functions including missile barrier, tornado barrier, ventilation barrier, or other functions for which it is not Start-up analyzed. Address any identified deficiencies in accordance with the methodology in Enclosure 2.

line Prior Complete long term qualification of the emetgency diesel generator exhaust C9 to supports to include tornado loading requirements.

Start-up ClO Review the IE Bulletin 79-02 (Pipe Support Anchor) Program to ensure compliance Prior to and to ensure methods of inspection used would have detected deficient bolt Start-up installation.

C11 Complete field inspections to assure that calculations supporting interim seismic Prior operability of the service water system pumps are valid.

Address any identified to deficiencies in accordance with the methodology in Enclosure 2.

Start-up Prior C12 Perform a third-party review of the short term structural integrity program to g

address evaluation techniques, field validation of critical assumptions, and a to review of communications from the Technical Support organization to the Start-up Engineering organization. Address any identified deficiencies in accordance with the methodology in Enclosure 2.

E3-4 (ENCL _3)

l ENCLOSURE 3 PERFORMANCE IMPROVEMENT PROGRAM SHORT TERM ACTIONS (REQUIRED PRE-STARTUP) l l

COMPLETION ITEM

.SCIEDULE I

DESCRIPTION NO.

Prior C13 Coeplete repairs of recirculation system ring header hangers.

to j

Start-up l

l l

C14 Complete design and installation of additional pipe supports for the service Prior 3

to water lubrication water piping.

Start-up 5

CIS Address seismic repairs of electrical motor control centers in accordance with Prior to j

the methodology in Enclosure 2.

Start-up l

I l

f D - Backlogs of Temporary Conditions and Operator Work-Arounds Prior D1 Temporary conditions involving short term structural integrity items will be to

(

reduced in accordance with the methodology in Enclosure 2.

Start-up Prior Temporary conditions other than short term structural integrity items will be D2 to reduced in accordance with the methodology in Enclosure 2.

Start-up D3 Reduce the number of operator work-around items (disabled annunciators, RTGB Prior I

indicator deficiencies, ar.d caution tags) in accordance with the methodology in to i

Start-up.

Prior D4 Reduce the outage backlog of corrective maintenance in accorda7 e with the to methodology in Enclosure 2.

Start-up Prior D5 Reduce the outage backlog of preventative maintenance in accordance with the to methodology in Enclosure 2.

Start-up E3-5 (ENCL _3) l

~

1 P

M

ENCLOSURE 3 PERFORMANCE IMPROVEMENT PROGRAM SHORT TERM ACTIONS (REQUIRED PRE-STARTUP)

COMPLETION ITEM SCHEDULE NO.

DESCRIPTION E - Equipment Deficiencies Discovered During Walkdowns El Perform hot side walkdown inspections. Address any identified deficiencies in Walkdown accordance with the methodology in Enclosure 2.

Complete E2 Perform cold side walkdown inspections. Address any identified deficiencies in Walkdown accordance with the methodology in Enclosure 2.

Complete r - Other F1 Correct leakage on a feedwater check valve hinge pin and a main steam isolation Complete valve (MSIV) packing atotal was less than 50 percent of Technical Specification allowed limit) and a nitrogen leak on a drywell cooler, which was identified during Unit 1 drywell inspections.

F2 Complete repairs to neutron monitoring detectors in accordance with the Prior to enethodology in Enclosure 2.

Start-up F3 Complete the Unit 1 secondary containment isolation test scheduled for the next Complete refueling outage (Reload 8).

F4 Complete 4kV bus crosstie modification (part of 10 CFR 50.63 implementation).

Prior to Start-up E3-6 (ENCL _3) l MMrOM

EXECUTIVE

SUMMARY

OF THE CORPORATE IMPROVEMENT PROGRAM M

m

.-....-......m.m..sM

E!4 CLOSURE 4 EXECUTIVE SU104ARY OF THE CORPORATE IMPROVEMENT PROGRAM Fol)9 wing chis page are the first three chapters of the document setting forth the Corporate Improvement Program. Chapter I provides an overview of ths Progrer..

Chapter II describes how the Program will be administered.

Chapter III provides a summary level listing and description of the 22 improvement projects. Other chapters, including onw with action plans for each project, are under development.

The Corporate Improvement Program document in its final form will be a stand-alone document.

It will provide the basis for the administrative control for the overall improvement program.

I.

IMPROVEMENT PROGRAM OVERVIEW qp$1MITMENT TO 1.ONG-TERM IMPROVEMENT The management of CP&L is committed to the successful implementation of an improvement program for the Brunswick Plant.

We expect this ef fort to address the higher standards for the maintenance and operation of the Brunswick Plant, facilitate improvements in CP&L's other nuclear plants, and establish the foundation for sustainable levels of good performance over the long term.

Resources are being provided to achieve reductions in the backlog of work and to improve substantially the material condition of the plant and its equipment.

Further, aggressive steps are being taken to establish the correct philosophy of operations and to strengthen wor:( control processes.

The improvement program at Brunswick is both an aggressive short-term effort and a comprehensive long-term effort.

Successful implementation will require management coinmitment and follow-through.

We have demonstrated a corporate commitment by providing an additional $200 million to $225 million over the next five years for improvements, in addition to those included in our five-year business plans. We know changes in managerial effectiveness are required for a long-term solution to challenges at Brunswick.

We believe the initiatives set forth in this Corporate Improvement Program demonstrate our total commitment to improve the material condition of the plant, our business processes and the effectiveness of our work force.

The schematic in Exhibit E4-1 shows the purpose, objectives, key initiatives, implementing projects e-1 expected results of the Corporate Improvement Program. The remainder of this chapter describes the elements in the schematic.

PURPOSE AND OBJECTIVES The primary purpose of the Corporate Improvement program is to create the foundation for a sustained level of good performance. CP&L's corporate and site management recognize the degree of change that must occur to establish this foundation for substantial improvement. The specific objectives of this Improvement Program represent the results this Program must achieve.

These objectives ares Reduce the backlog of work at Brunswick and maintain equipment in e

accordance sith design and operating standards so that the permanent plant staff has the opportunity to focus on managing the safe and reliable operation of the plant.

Establish and instill a new philosophy of operations in which all employees perform to the highest standards necessary to achieve an attitude of continuous improv;;;.ent in performance.

Redesign work management processes in order to remove impediments to working efficiently and effectively.

ENCL _4 I-1

j POUR PRIMARY INITIAI1YES l

There are four primary initiatives which will guide and shape the overall Corporate Improvement Program.

These four key initiatives are described below.

I - DEVELOP HIGHER AND MOPE SPECIFIC STAf9ARDS Corporate and site standards for the Brunswick Plant, and our other nuclear units, which are much higher and more specific than current standards will be developed.

These standards will be effectively communicated throughout the Nuclear Generation Group organization, integrated into the work practices of our employees, and monitored with respuct to performance against them.

II - DEVELOP PLANS TO MEET THE STANDARDS AND MONITOR IMPLEMENTh7 ION Improved and strengthened planning and action monitoring processes will be developed. This will provide heightened visibility as to the accomplishment of planned work and as to the level of effort and priority needed to perform in accordance with standardo. The processes for adentifying, planning, and monitoring improvemont projects is being modified to support the Integrated Schedule Program (ISP).

The initial Brunswick ISP will be submitted in October 1992.

III - PROVIDE ADDITIONAL RESOURCER The linkage between the planning and budgeting processes will be strengthened to ensure that resources necessary to carry out our plans, and thereby achieve our standards, are clearly identified and provided over the long term.

For 1992, funds have been authorized, in addition to the approved budget, for improvements which can proceed immediately.

For 1993, performance improvement projects are being budgeted separately from routine operations.

This will enable.he evaluation and funding, as appropriate, of an improvement project on its own merits.

IV - ESTABLISH AN ATTITUDE OF CONTINUOUS IMPROVEMENT IN PERFORMANCE Actions will be undertaken to enoure a work climate which consistently encourages effective, critical self-assessment, the identification and resolution of problems by all employees, and secures the commitment of all employees to the achievement and maintenance of the established quality standards.

CP&L has made a commitment to more aggressively identify and correct problems as illustrated by the extensive inspections, repairs, and modifications currently underway.

Tha actions during ths outage of the summer and fall of 1992 are reinforcing our message to employeen tha ~c CP&L management intends to set and achieve high standards, identify deviations therefrom, and provide resources to implement prompt corrective actions.

In addition, senior ENCL _4 I-2

management at the site and at corporate will communicate t he importance of the timely resolution of problemn, hold the responsible line and support organizations accountable f or meeting commitments to resolve problems, and demand increased monitoring of plant performance and ownership of identified problems by support groups.

TWENTY-TWO IMPLFMENTING PPOJEq11 To implement these four key initiatives, the Corporate Performance Improvement Program consists of 22 specific improvemont projects. Each of these projects will be the responsibility of a CP&L department manager or higher level executive. To the extent required, they will be separa*aly funded and provided with the staff necessary to execute the project plan.

In addition, effectiveness audits will be conducted to ensure that the intended results of the project have been achieved.

Chapter III contains a brief description of each project as well as

'dules and responsibilities.

The twenty-two projects are listed below.

+ E7b 1

Root Cause Verification 2

Work Management Policies and Standards 3

Communication of Work Hanagement Policies and Standards 4

Improvement Plans for Standards 5

First-year Review of Standards 6

Reporting of Standards compliance 7

NGO Policy and Procedures Manual Restructure 8

Role Changs for Nuclear Services Department 9

Corrective Action Asowsoment 10 Integrated Schedule Program 11 Business Planning Process Review 12 Supervisory Assessment Center 13 Supervisory Dev=lopment Program 14 Technical Training Program 15 Staff Assistance Team Recommendations Resolution 16 Modification Process Redesign 17 Haintenance Process Redesign 18 Work Control Hethodology 19 Honthly Plant Material Condition and Housekeeping Policy Report 20 Long-Term Backlog Reduction at Brunswick 21 Organization Effectiveness Improvemente 22 Nuclear Assessment Department Review and Evaluation ENCL _4 I-3

RESULTING CHANCES This program, when fully implemented, will be successful in producing the results which will be needed to achieve and sustain a high level of performance. the expected results are:

1.

Communication of management expectations and standards through specific work management policies and standards and development of a disciplined oversight program to ensure that corporate management closely monitors efforts to itaplement and sustain these standards.

2.

Increased Corporate and Site management involvement and oversight with particular emphasis on past chronic performance concerns ana on improved communication between plant management and corporate management, 3.

Improved management effectiveness at the Group and Department level, especially with respect to communications, positive leadership, and the establishment of a clear hieracehy of administrative policies and procedures.

4.

Improved work control processes resulting from the near-term implementation of iacommendations of the Staff Assistance Team and the longer term redemi(. of the maintenance management process and the engineering analysio and modification process.

5.

An improved self-assessment and corrective action program. The improvements will be built upon a root cause analysis to determine why the existing procedures have not been effective and the implementation of appropriate changes based upon that assessment, 6,

Improved plant material condition through the significant reduction of exist ing backloge, the establishment of an organization for further reductions of the current backlog, and the establishment of appropriate standards to facilitate the future management and control of backlogs.

7.

Improved personnel development and training which will increase the effectivoness and capability of management and non-management personnel.

This resuic will flow from the implementation of an Supervisory Assessment Center to identify candidates for supervisory positions, the continued implementation of a Supervisory Development Program to provide supervisory candidates training in the skills needed to be effective, and she restructuring of the technical training program to increase the effectiveness of the skills and hands-on training activities, ENCL _4 I-4 j

Corporato improvamont Program exhiunt e<.,

Brunswick Nuclear Plant Program Overview wan@aRurposels!mme Create the Foundation for Sustainable Levels of Good Performance ruimencOb ectivesmewsk R

  • Reduce backloa to manageable 1 y

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  • institutionalize 5 new philosoph) ni of operations
  • Remove the barriers to succe%

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1. Root Cause Verification
2. Work Management Policies and Standards
3. Communication of Work Management

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@@j; Policies and Standards q}$.ww k$

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4. Improvement Plans for Standards
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5. First-year Review of Standards Communication of 1.

Develop Higher and

6. Reporting of Standards Compliance Expectations and More Specific Standards Expectations and
7. NGG Policy and Procedures Manual 6 Restructura Stradards
  • Increased Site and 8, Role Change for Nuclear Services Department Corporate Management
9. Corrective Action Assessment involvement II. Develop Plans to and Oversight Meet the Standards
10. Integrated Schedule Program and Create Effective N

Improved M'nagement 11, Business Planning Process Review Monitoring Methods Effect'veness

12. Supervisory Assessment Center Improved Work ill. Provide Additional
13. Supervisory Development Program Control Processes Resoueces to
14. Technical Training Program e improved Sett, implement Assessment and improvements
15. Staff Assistance Team Recommendations Corrective Action Resolution Program IV. ' Estab.ish an Attitude
16. ModificaUon Process Redesign
  • 1m roved Plant of Contmuous
17. Maintenance Process Redesign Material Condition improvement in Performance
16. Work Control Methodology
  • Improved Personnel rafn'ing P '" "
19. Monthly Plant Material Condition and Housekeeping Report
20. Long Term Back-log Reduction
21. Organization Effectiveness improvements
22. Nuclear Assessment Department Review and Evaluation

~

II.

IKPROVEMENT PROGRAM ADMINISTRATION The Corporate Improvement Program is a long-term effort.

Performance improvements have already begun,.but the full implementation and change effort will require a number of years

  • complete.

All levels of CP&L management are committed to overseeing this Program to its successful completion. The definition of improvement initiatives and

.the establishment of action plans have involved the top managers in the NGG i

and line management up to the CEO.

In addition, there has bean active collaboration with other members of CP&L's top management that have rolen to play in supporting these improvement initiatives.

In recognition that other improvement programs have not been fully effective, there will be a new approach for implementation and effectiveness monitoring for Corporate Improvement Program, the specific features of which are outlined below.

Overall Improvement Procram Resoonsibility The Senior Vice President of the Nuclear Generation Group has overall responsibility and accountability for the Corporate Improvement Program.

This responsibility extends to the implementation of changes at the other nuclear plants in order to achieve the appropriate degree of consistency and comparability of processes and organization structure. The Senior Vice President will have a special Executive Assistant who will have the responsibility to orchestrate and coordinate the various projects that make up the Corporate Improvement Program. CP&L Management will ensure that this program is fully funded.

The Senior Vice President will administer the allocation of funds.

~

The Executive Assistant will' monitor implementation progress and perform basic reporting and accounting responsibilities.

A monthly status report will be prepared and submitted to the department heads I

in the Nuclear Generation Group and the members of the Senior Nuclear Advisory Committee.

genior Manaaement oversicht and Control All levels of management from the site vice pree.dente up to the CEO d

will receive a monthly report on implementation and status from the Executive Assistant to the NGG.

The distribution of these reports will be the responsibility of the Senior Vice President.

In addition, two new initiatives will provide for a more an extensive degree of senior management oversight and control.

The Nuclear Assessment Department will conduct independent audits of the

. implementation results.

These audits will be conoucted at a maximum interval of every six months,.and they will be structured to reflect the performance-based auditing philosophy of the Nuclear Assessment Department.

Results of these audits will be communicated to senior nuclear line managemunt, the Executive Vice President - Power Supply, and the Senior Nuclear Advisory Committee.(SNAC).

The Senior Nuclear Advisory Committee (SNAC) will review:

1) the progrens of implementation and 2) the degree to which desired results are ENCL _4 II-l L

being achieved. The SNAC will receive fofmal monthly reports from the Senior Vice President of the Nuclear Generation Group.

Further, the SNAC will receive formal reports from the organizations that conduct the follow-up/ effectiveness audits. The membership of SNAC includes the Executive Vice Prenident of Finance and Corporate Services, the Executive Vice President of Power Supply, and the Senior Vice President, and Regulatory Services.

Proiect Closecut An independent effectiveness follow-up audit will be conducted for applicable projects. This audit will be focused upon the results achieved to ensure that the intended purpose of the project has been satisfied. The Senior Vice President - Nuclear Generation will make the final decision on project closecut.

ENCL _4 II-2

l III.

IMPROVEMENT PROJECT

SUMMARY

The following schedule provides a summary description of each of the twenty-two improvement projects. Also included is the title of the department or group head responsible for the project and the date by which the project will be completed.

COMPLETION NUMBER PROJECT DESCRIPTION SCHEDULE RESPONSIBILITY Undertake at the December 31, 1992 Senior Vice 1

corporate and site President, Nuclear management level a Generation Group rigorous effort to identify the root cause of tne problem identified by the NRC, NAD and others and then build the commitment to resolve these problems permanently and to reflect lessons learned in the Corporate Improvement Program.

2 Develop Work Management September 30, 1992 Vice President, Policies and Standards Nuclear Services for application at all three of CP&L's nuclear plants.

3 Integrate Work Management December 31, 1992 Vice re.cident, Policies and Standards Nuclear Services into the conduct of Nuclear Operations Manual (CONOM) and provide briefing roviews of the CONOM to all NGG employees.

4 Define the status Complete status Each NGG Department relative to the Work determination at Manager Management Policies and BNP by December 31, (Development)

Standards at each of the 1992 three nuclear plants and Sr. VP of NGG develop improvement Complete status (Approval) action plans, and determination at establish a line other departments management tracking by February 28, method.

1993 ENCL _4 III-1 1

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COMPLETION NUMBER PROJECT DESCRIPTION SCHEDULE RESPONSIBILITY 5

Perform a review one-year Initiated in fourth Vice President, after deployment of Work quarter 1993 Nuclear Services Management Policies and Standards to incorporate lest.ans learned and to revolidate the standards and the ways they are useo.

6 Provide a method for the Begin monitoring in Manager, Nuclear independent monitoring, January 1993 Assessment auditing and reporting of plant status relative to Work Management Policies and Standards.

7 Upgrade the hierarchy of complete by October Vice President, management and 31, 1992 the Nuclear Services administrative policies, initial assessment procedures and guidelines and preparation of to provide for an improvement plan administrative governance structural consistent among each of the nuclear plants and NCG departments in the corporate office.

8 Revise mission, role and End of second Vice President, responsibilities of the quarter 1993 Nuclear Services Nuclear Services Department to reflect greater responsibility for assuring beneficial consistency among the

)

plants and conformance to the expectations of the Senior Vice President.

9 Perform a detailed review Complete study, Vice President, to determine why prepare Nuclear Services corrective action and implementation self-assessment have not plan, and begin been effectively applied.

implementation during second quarter 1993 10 Develop and implement the Submit initial Manager, Nuclear Integrated Schedule Brunswick Plant ISP Business Operation Program.

in October 1992 ENCL _4 III-2 l

COMPLETION NUMBER PROJECT DESCRIPTION SCHEDULE RESPCNSIBILITY 11 Revise the Business Implement for 1993 Manager, Nuclear Planning process and Business Planning Business operations format to ensure that the Process (with support from resources necessary to the Corporate achieve and maintain Management Services standards are reflected Department) in the Business Plan.

12 Establish a long-term Complete during Vice President, plan for the on-going second quarter 1993 Employee Relations effective ut.'.lization of the Supervisory Assessment Center approach for identifying candidates for supervisory positione.

13 Complete the All eligible Vice Presidort, implementation of the supervisors through Employee Relations Supervisory Development academy by end of Program and establish it 1995 as an on-going training program that is tc be attended by all first and l

second-level supervisors in the Nuclear Generation Group.

14 Establish an Complete by end of Vice President, implementation plan to 1992 Nuclear Services address the improvement initiatives identified in the recently-completed assessment of the technical training program.

15 Complete the Prepare final Vice President, implementation of actions implementation Brunswick Nuclear necessary to address and plan by November Plant and Vice resolve each of the 71 30, 1992 President, Nuclear recommendations developed Services by the Staff Assistance Team (ST.T) and agreed to b3 the Brunswick Nuclear Power Plant management.

ENCL _4 III-3

~,

.~..-.

-w COMPLETION NUMBER-PROJECT DESCRIPTION SCHEDULE RESPONSIBILITY i

16 Undertake a long-term Schedule under Manager, Nuclear initiative to process developrnent Business Operations redesign the engineering analysis / modification process.

17 undertake a long-term Schedule under Manager, Nuclear initiative to process development Business Operations redesign maintenance management.

If Define a common approach Schedule under Vice President, for managing work development Nuclear Services (planning and scheduling of modifications, maintenance and ethers) and for work control at each of the three nuclear plants.

19 Develop a methodology Begin inspections Vice President, that will provide for the in December 1992 Nuclear Services monthly inspection and reporting to the Senior Vice President of NGG as to visible plant material condition and housekeeping.

20 Establish y separate-Establish special Vice President, project group that will project prior to Brunswick Nuclear be responsible for startup.

Project addressing that portion of the backlog that should not--De the responsibility of the permanent plant staff in the areas of corrective maintenance, procedure rewrites and_

modifications.

21 Unuertake=a broad, Schedule under Senior Vice comprehensive management development President, Nuclear effectiveness improvcment Generation Group program aimed at and Vice President, establishing an attitude Employee Relations of continuous improvement in performance.

ENCL _4 III-4

COMPLETION NUMBER PROJECT DESCRIPTION SCHEDULE RESPONSIBILITY 22 Evaluate and strengthen Complete by end of Executive Vice the offectiveness of the second quarter, President, Power Nuclear Assessment 1993 Supply Department to ensure that it effectively carries out its oversight responsibilities.

Automhu ENCL _4 III-5

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