ML20140F105

Rev 2 to Crystal River Unit 3 Mgt Corrective Action Plan (Mcap)

ML20140F105
Person / Time
Site:	Crystal River
Issue date:	04/18/1997
From:	FLORIDA POWER CORP.
To:
Shared Package
ML20140F098	List: 3F0497-02, Forwards Rev 2 to Crystal River Unit 3 Mgt Corrective Action Plan (Mcap) ML20140F105
References
PROC-970418, NUDOCS 9705020113
Download: ML20140F105 (52)

Text

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4 CRYSTAL RIVER UNIT 3 1 I

1 MANAGEMENT CORRECTIVE l 4

ACTION PLAN 4

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1 MCAPll 4

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I 1705020113 970425 PDR ADOCK0500g2

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Rev.2 April 18,1997 i

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. Florida 8 Power q, CORPORATION April 18,1997 MANAGEMENT CORRECTIVE ACTION PLAN PHASE 11 This is the Crystal River Unit 3 (CR-3) Management Corrective Action Plan, Phase 11 (MCAP 11). The purpose of this plan is to help focus our efforts on our mission of Safe, Reliab/e, Economic and Environmenta//y Sound power generation. MCAP 11 will not be an easy task to accomplish; change is never easy. But, excellence occurs one step at a time and bv focusing on making today better than yesterday, and tomorrow better than today, we will move i forward. This document is not about what meets regulations and what does not meet regulations, but rather changing our ways, changing conditions, and changing what we expect of ourselves and others, to be excellent.

Safe plant operation is our first and foremost obligation. The plant and its equipment must be operated in a manner that minimizes the potential for adverse safety consequances. Any potential problem related to safety must be promptly identified, evaluatod, communicated, and resolved.

There are two areas that are essential to our success which I would like to emphasize. First and foremost is communications - up, down, and across the organization. We :an't communicate too much; if you think information may not have been communicated or, worse yet, mis-communicated, then i expect you, personally, to seek the information and set the record straight. Don't rely on the " system" to communicate for you, particularly if the issue is important to you. The second essential element, and communication is a part of it, is teamwork. No matter what the issue, two or more minds will provide a better solution than one. Working together, we can accomplish far more than the sum of our efforts indivi. dually.

There is no success as an individual unless the plant as a whole succeeds.

CR-3 can become the best plant in the United States. We can rise to the occasion. Think of ways to improve and tell your supervisor. If you don't think you are getting through, come and talk to me. We need everyone to be a part of this effort.

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m R. . Anderson L

REVISION DATE SIGNIFICANT CHANGE MCAP 11, Rev,:0 10/31/96 Original MGAF.ll, Revtd 11/22/96 incorporates recommendations of independent Design Review Panel (IDRP) into Section C2 Configuration Management and

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Design Basis itemsidesignated.C.lD N, incorporates recommendations of Nuclear General Review Committee (NGRC) Special Subcommittee which reviewed MCAP ll November 8,1996.

MCAR y,;_Rev. 2 4/18(97 Updates action items as of. April .15,-1997, incorporates (revised.complet. ion dates'which reflect;irnpact and priority of;the restart .

effort as stated in the'.Marchi::13,;1997 lett$r to the NRCi:[Prov' ides revised introduction from;thejsenior:Vice President (Nycle'ar Opsiationsl

1. Introduction and Overview:

This document is the Florida Power Nuclear Operations Phase 11 Management Corrective Action Plan (MCAP 11). It is the follow on plan to the Management Conective Action Plan (MCAP) initiated in the Spring of 1995 to address specific performance issues arising from events that had occurred in late 1994. i The Management Corrective Action Plan Phase 11 redirectsiimprovement efforts to incorporate the results from numerous internal and external assessment and evaluation

. activities during 1996. The MCAP 11 identifies the root and contributing causes (barriers) to achievement of excellence, assigns responsibility to an appropriate management or supervisory level individual, and establishes completion dates for specific corrective actions to address the identified root and contributing causes. The original MCAP has been completed. Several individualissues have been transferred to MCAP 11 for completion.

Further, where analysis of completed MCAP issues has indicated that previous corrective actions did not achieve the desired results, additional actions have been incorporated in MCAP 11. These are shown in Appendix A.

MCAP 11 communicates management expectations and provides direction to tne entire Florida Power Corporation Nuclear Operations Organitation. It supports curLm'ission of safe; reliable 7 economic 1and en0ironmenfall/ sound povierjenefati6n lMCAP ll is predominantly directed at the safety aspects of our rnission. It is principally focused upon improvement of the safety culture of Crystal River Unit 3 using the broadest definition of safety culture.

. 1 Nuclear Operations line management has developedLMCAP 11 with two fundamental l principles in mind: (1) to identify the major issues and deficiencies in Crystal River 3's perforrnance and to (2) direct action to resolve those deficiencies. lMCAP ll consists of five major areas, all bearing directly on the safety culture, that were identified during the evaluation process @The;sel areas ~sre sslfollows!

Se'ctioWAi Leadership Oversight and involvement Sectiori B: Configuration Management / Design Basis  ;

Section C: Regulatory Compliance

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Section Dj Engineering Performance j Section E; Operations Performance '

I A specially designated subcommittee of the Nuclear General Review Committee (NGRC), ,

chaired by the NGRC Chairman, reviewed Revision 0 of MCAP 11. This group believed the '

focus prescribed in the five areas above was too narrow and did not address the four i following fundamental root causes:

Focusing more intensely on coct and production than safety.

Management not listening to or acting upon information available to them.

A strong sense of denial with regard to performance.

A family organizational culture rather than a self-critical team.

Specific root and contributing causes are identified within each area as are comiehensive action plans to correct the root and contributing causes. Specific Managers and Supervisors have been assigned completion date and content accountability. Measures of monitoring progress and effectiveness have been established.

Rev.2 1 April 18,1997

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l 2. Expected Results l'

} This plan begins the process of bringing Crystal River 3 into the community of top performing nuclear power organizations, it is a road map designed to provide the basic performance competencies which will permit rapid progress along that road. It will provide

( the fundamental foundation to enable subsequent plans to compiate the journey to  ;

excellence in all areas of ourjmisisi6n.

3. Planning Assumptions ,

Several key assumptions guide plan development, including: j e The overall objective is to reach (and maintain) top performance.  !

• The planning horizon extends through the end of FY 97 (December 31, 1997).  !

e The plan needs not only to address issues identified in assessments, it must also l 4

include strategic initiatives necessary to achieve the overall objective.

. The plan assumes that necessary resources (people and money) will be available. It ,

2 includes resources required over present level of effort to accomplish goals. J

• Meaningful measures of effectiveness are required to monitor and communicate  ;

, progress both internally and externally (e.g., NRC). j

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• Continuous improvement on the part of industry is assumed in developing where  ;

CR-3 needs to be at the end of FY 97.

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Rev.2 2 April 18,1997

SECTION A

1. Area of Concern and Management Sponsor:

Leadership Oversight and Involvement Sponsor: J.S." Baumstark II. Problem

Description:

Leadership oversight and involvement in plant issues has been inadequate in emphasizing its safety culture role. This has occurred in areas ranging from communication and reinforcement of core values and expectations l to site processes and priorities. Further, where assessments have been conducted, they have neither focused on elements from the safety culture perspective, nor have they been sufficiently self-critical to enable assessment of root or apparent causes.

d 111. Present Condition:

In response to plant events over theLtsvo} year peri.od from 1994'to;1996, several initiatives have been implemented, including:

• Establishment of a formalized self-assessment and performance monitoring program.

• Restructuring the NGRC, including an annual review of the self assessment program .

by the NGRC. l

• Establishment of a Nuclear Safety Assessment Team (NSAT).

Creation of a Co.rtec_tWe Action RevieKBoard (CARB) to review the effectiveness of

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a corrective action taken in response to more significant events (those involving NOVs, LERs, and other significant management concerns).

• Increasing the emphasis of on-shift oversight, including redefining the role of the Shift Manager and adding a position (Operations Manager) directly over the Shift Supervisor.

Despite these efforts, a difference in performance standards exists between CR-3 and INPO 1/SALP 1 plants in areas such as safety culture, procedural adherence, event investigation, root cause determination, sensitivity to operability issues, adherence to design bases, QA organizational effectiveness, and implementation of the corrective action process for emergent issues. These differences should have been determined through leadership oversight and involvement, but were not.

IV. Corrective Actions to Address the Root Causes of the Problem:

The following are the root causes of the problem and the corrective actions that have been/will be taken to achieve top performance in leadership oversight and involvement.

Rev. 2 3 April 18,1997

.a ROOT CAUSE 1:

4 Site leadership has not been effective in carrying out its safety culture role because it has a not:

1. Clearly and consistently communicated and reinforced core values and expectations j with emphasis on safety culture.

2. Implemented site processes with appropriate emphasis on safety culture. 1

, 3. Established site wide priorities with proper emphasis on safety culture. I

4. Implemented balanced accountability with respect to safety. )

5. Established constructive self criticism and self improvement as an integral way of I

doing business.

6. Fixed things that were wrong. l l

I CORRECTIVE ACTIONS:

TARGET 1 RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE A-RC1 1 a) Independently assess the senior site P.M. Beard Completed management team and determine "best fit" 1/5/97 roles for carrying out transition to the new safety culture.

b) Make changes to reflect this assessment.

A-RC1 2 Evaluate and revise mission statement, core values, J.S. Baumstark 1,0/31/97 and ppectations with emphasis on safety culture; the evaluation willinclude a review by a cross fur.::tional/ level team.

A-RC1 -3 Establish a self-critical view from the top down that RfA[Anders6n. Completed

. accepts identification of problems and takes action to 2/23./97.

address them rather than rationalizing it away.

Incorporate this attribute into supervisory / managerial performance appraisals.

A-RC1 -4 Establish site wide priorities which emphasize a safety P.M. Beard Completed culture. 10/31/96 A-RC1 -5 Conduct a Safety Culture Index. Evaluate the Culture J.S. Baumstark Completed index at periodic intervals. 1/1/97, l

Rev. 2 4 April 18,1997

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TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE A-RC1 -6 Plan a Supervisor's workshop which emphasizes: R. C. Widell Completed a) Lessons learned from the Safety Culture 4/10/97 Index b) Manager / supervisor role in implementing a safety culture c) The relationship between accountability,  ;

authority, and responsibility  ;

d) Behavioral expectations related to a safety culture +

- Explains the seriousness of the problem [

- Explairts the benefits of self-criticism

- Provides positive reinforcement for self-identified criticism A-RC1 -7 Conduct the Supervisor's workshop discussed in 2 R4C&Widell l6/30/97 above.

A-RC1 -8 Communicate, advertise, coach, and constantly RKAnderson 10/31/07~

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reinforce our Mission Statement, Core Values and "JMCoWari' Expectations down throughout the organization. 7,SUBaumstark

a. Advertise "W.D.7 Conklin" l

b. Establish performance standards in writing for "B.d.t Hickle '

each department 33.1 Holden

c. Stand down to launch the program DAK6risemihr

d. Directors and Managers recruit each individual M.W :Marano (Core Values to a personal level and "RlC{Wklell 4 expectations to a job specific level) ]

e. Measure results j

f. Conduct periodic reinforcement sessions with employees l

g. Hold management sessions to discuss progress and problems A-RC1 -9 Conduct human error reduction training for selected RfCfWidell Completed _

site supervisors (90). 1/31/97 A-RC1-10 Conduct human error recognition and reduction R. C. Widell Completed techniques training for selected site workers (120). 4!4/97 A-RC1 -11 Ensure appropriate management level attendance at DJ$6nssm@er ' Completed NRC and QA entrances and exits. 3/6/97 A-RC1-12 Formally enhance the Operating Experience Review J. S. Baumstark Completed Program which identifies emerging industry issues 3/26/97 ,

(both equipment and organizational & programmatic). j l

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ROOT CAUSE 2:

Excessive and ineffective organizational and programmatic changes have increased human error rates.

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CORRECTIVE ACTIONS:

l TARGET l RESPONSIBLE COMP % TION l ACTION INDIVIDUAL DATE j A-RC2-1 Deveicp a change management process for significant J. S. Baumstark 10/31/97 organizational and programmatic changes to include:

• Communications plan including new standards expected.

• Evaluation of personal / personnel impacts.

• Workload assessment prior to and after the  ;

change.  !

• Monitor!ng the effectiveness of the change.

• Required training or re-training.

A-RC2-2 Monitor and control the number of significant J[SJBaumstarE 1J9/98 organizational and programmatic changes being i implemented simultaneously. l l

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ROOT CAUSE 3: l An inadequate root and common cause analysis process inhibits management from addressing the right issues in the right priority.

CORRECTIVE ACTIONS:

TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE A RC31 Redefine the corrective action process to include a J. 5. Baumstark Completed single graded approach for development of root and 11/20/96 apparent causes as well as corrective action plans.

A-RC3 2 Establish a core group of in-depth root cause analysis J. S. Baumstark Completed experts. 11/1/96 A-RC3 3 Establish apparent cause reviewers in each line J. S. Baumstark Completed j department. 11/14/96 A-RC3-4 Develop training package on corrective action program R. C. Widell Completed ~

changes for delivery by site supervisors. jj/12/96 A-RC3-5 Conduct training for site personnel on changes to J[S7 Baumstark Completed l

corrective action program. 11/12/96  ;

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Rev.2 6 April 18,1997

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CONTRIBUTING CAUSE 1:

Inadequate performance monitorint: . I trending which inhibits proactive identification of emerging issues and results iri an excessivo r. ser of investigations with little value added.

CORRECTIVE ACTION:

TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE A-CC1 -1 Estanlish centralized monitonng and trending of "real D, A. Daniels 11/26/97, time" process inputs for performance indicators and repeat events / failures. Develop methodology for measuring appropriate real time and leading indicators that preclude recurrence of significant lagging indicators.

CONTRIBUTING CAUSE 2:

Inadequate analysis of performance monitors has resulted in ineffective detection of adverse trends related to site programs, processes, and procedures.

CORRECTIVE ACTION:

TARGEI RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE l A-CC2-1 Establish a method for identifying trends needing further D.c A. Daniels 5/3D/97 )

analysis with respect to root cause.

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Rev.2 7 April 18,1997

CONTRIBUTING CAUSE 3:

An inadequate feedback process has resulted in self-assessments not being controlled by the corrective action process and consequently, missed opportunities to improve.

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CORRECTIVE ACTIONS:

TARGET 4

, RESPONSIBLE COMPLETlON ACTION INDIVIDUAL DATE

] A-CC3-1 Establish standards for self-assessment performance. R.Eg Yost Completed ,

12/.2. /9. 6. .

A-CC3-2 Formally incorporate results obtained thru self-assessments into the corrective action process for follow- ~

up, tracking, and trending. Completed

! sC., ^>][NOOj45 R. E. Yost 12/2/96 5 bs@ ;(Ch11f D. T. Wilder 11/20/96 i

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CONTRIBUTING CAUSE 4:

Inacequate adjustments (corrective acticas) have resulted in frequent ineffective changes that may cause 'i additional problems, j l

CORRECTIVE ACTIONS:

TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE A-CC4-1 Establish kne management accountability for corrective R AgA.nderson 3

Completed actions which: 4/3/97

a. Ensure changes are supported by and directly relate to root cause analysis,

t. Will reduce recurrence rate significantly and in a i timely manner without creating another undesirable condition.

c. Can be implemented within a management control.

d. Are consistent with industry standards.

e. Can be implemented cost-effectively.

Rev.2 a /pril 18,199

CONTRIBUTING CAUSE 5:

The Quality Assurance process has not effectively communicated or followed up on issues, j CORRECTIVE ACTIONS:

TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE A-CC5-1 Tstabhsh new management in QA. J. S. Baumstark Completed i t 3/4/96 I l

A-CCS-2 Provide new guidance for the conduct of audits R. E. Yost Completed l 11/15/96 A-CCS-3 Establish 18 to 24 month rotational assignments in OA R. E. Yost Completed for approximately 30% of assigned positions. 3/10/97 A-CC5-4 Recruit new talent for QA from both on-site and off-site R. E. Yost 8/29/97 assets. I l

V. Measures of Effectiveness 1

The following measures will be used to monitor progress and gauge the effectiveness of corrective actions in addressing the problem:

• Number of LERs sda NOVi attributable to human performance errors.

• Pr@drsb{fayej

• Percent of violations that a'.e not cited.

• Percent of prodursors that reflect a recurring problem.

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• Number of CR-3 NO'Vs sod LERs.

• NurnberIlof procursors obsned/ closed)

M.essQ of presursors (AZBf Ci;D)i kNurnE%Iof *ssifieritica'isfehursoislinitiated l b "departnient[orilitself)l EPoiceritfof procursorsTsubmitied tipidessrtmentsi'

• Frequspsyiof Nunisriteifddhinhe Rslatsd Cshditions .

)Oselity@tRo6t CauselEvaldatichs.

1 Rev'. 2 9 Apr110.1997

1 Appendix A Action items Carried Over from Previous MCAP Submittals and Meetings Section A: Leadership Oversight and involvement I TARGET -

RESPONSIBLE COMPLETION l

. ACTION INDIVIDUAL DATE A-FU-1 Ensure applicable elements of the Event Free Operation Program continue to be a focus of the day-to-day way we ,

do business with emphasis on:

a. Direct observation of work in progress B.J. Hickle Completed 3/27/97 i

b. Audits and surveillance J.S. Baumstark Completed j i 3/24/97 -

c. Independent review group oversight (NGRC). J.S. Baumstark Completed idlHUABC6fnnon) 4f819_7

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N 5.fridependent tevieN0roupyker,sightjPRC)! .B:Jj Hidde Cotripleted j (G,H? Halnorg 4./8/97 A-FU 2 Establish a single user-friendly action tracking system. J. S. Baumstark 9/26/97

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A-FU-3 Determine the most effective role for issue Managers. yWBaGrh$tl ark 818/97 Coordinate this effort with establishment of responsibility

,' for managing site Top 10 Priority elements.

i A-FU-4 Probabilistic Safety Analysis (PSA) -identify enhanced ylKHolderj 5/1/97 applications. (R.W{ Knoll).

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Rev.2 10 April 18,1997

l SECTION B i ENGINEERING PERFORMANCE l l

I. Area of Concern and Management Sponsor: i l

1 The Engineering Department has not supported plant operations well, particularly in maintenance and application of the plant design basis. j Sponsor: JKHolden

11. Problem

Description:

The focus of the concern in engineering is primarily on design and analytical work, configuration management, and teamwork with other departments. The systems engineering area is generally perceived to be satisfactory, although some performance problems have been noted here too.

Overall, the engineering department has had an inconsistent record of performance. Over the last ,

several SALP periods it was rated SALP 3, SALP 2, SALP 2 (and IMPROVING), and SALP 1 only to decline back to SALP 2 in 1995%n(SALP 3,10996;

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Although inspection seports identify some engineering strengths, they are overshadowed by weaknesses in the following areas: timeliness and accuracy of design and analytical support for ,

plant operation, adequacy of regulatory correspondence, quality of 10CFR50.59 evaluations, )

planning and prioritization of work load, and maintenance / communication of the plant design basis. j l

Ill. Present Condition:

The engineers were challenged to self-identify the key factors contributing to the problems described above. Their input is summarized below:

1. For the first eighteen years of plant operation there was a heavy reliance upon A/E, contractor, and NSSS resources for performance of design activities. Corporate engineering personnel served as project managers over these resources and were not intimately involved with the details. As a result, there was ineffective technology transfer from the external resources to CR3 engineers.

2. Ineffective management of change within the engineering organization had a negative affect on its performance. The combined effect of downsizing, relocation of corporate personnel to the Crystal River plant site, implementation of the business process improvement (BPI) recommendations to the design processes, and the reduction in reliance upon external engineering resources, negatively influenced productivity and product quality, frustrated personnel, and increased engineering work backlogs.

The reduction in reliance on external resources, although recognized by all as a potentially positive move, was performed more aggressively than the FPC team was prepared to accommodate,! given the existing level of engineering knowledge and skills.

In response, several initiatives have been implemented over the last two years, including:

a. Recombined systems engineering with design engineering, configuration management, procurement engineering, and engineering projects under a single engineering director.

Rev. 2 11 April 18,1997

< b. Increased management oversight within enginaring by creating a new manager position ,

and group to control engineenng programs linservice inspection; new/ finite term programs (e.g. GL 96-01, setpoint verificefon, tank calculations); and continuing lifa-of- the-plant programs (e.g. boron corrosion, erosion corrosion, maintenance rule, charcoal testing, and tendon inspections)).

c. Increased teamwork among departments by:

• Teaming operations and engineering personnelin calculation development, design inputs, and assessments of impact on documents and procedures,

• Teaming licensing, operations, and enginesring personnelin system and equipment operability assessments, and

• Implementing the use of Project Teams for conceptual design (alternatives), final design, construction, and startup of significant plant changes.

Despite these actions, developed as an integral part of the nuclear operation's Management Corrective Action Plan (MCAP) beginning in March of 1995, performance differences remain between CR-3 and SALP 1 plants.

The actions described above, dealt with symptoms in many cases rather than root cause(s). To

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correct this condition, s.n FPC teani conducted a structured rout cause determination of the engineering performance problem.

IV. Corrective Actions to Address the Root Causes of the Problem:

The following are the root and contributing causes determined by the FPC. team along with the respective corrective actions to achieve top performance in engineering effectiveness:

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I Rev. 2 12 April 18.1997

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4 l ROOT CAUSE 1: l i

i An appropriate safety culture was not effectively emphasized. As a result, activities were not given a level

! of safety attention commensurate with that given to production or cost priorities. This led to design basis l concerns being primarily resolved through analytical means in lieu of physical means (such as plant j modifications and equipment testing) directed at maintaining or improving design margins.

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CORRECTIVE ACT!ONS

j i TARGET I RESPONSIBLE COMPLET!ON l

. ACTION INDIVIDUAL DATE l I B-RC1-1 Implement a " stand down" in Nuclear Operations F. X. Sullivan Comp'eted 4 Engineering to emphasize the importance of improving 9/30/96 j i safety culture. Stress the need to enhance safety l

sensitivity, quality, and attention to detail in the l performance of 10CFR50.59 safety evaluations and the  !

j lessons learned from the recent USO experience.

i l B-RC1 -2 Institute an interim change to require 50.59 evaluations F. X. Sullivan Completed j be performed for engineering activities in lieu of a 10/15/96 i screening evaluation. This action is to remain in place I f until formal training and establishment of qualified . 1 reviewers for 50.59's are completed.

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i B-RC1 3 incorporate improved safety sensitivity into 50.59 R. Widell 6/30f97 i evaluation training in the Technical Staff and f Management continuing training curriculum.

j B RC1-4 Hold a special meeting with NOE (design) personnel to F. X. Sullivan Completed

! further increase safety sensitivity to 50.59 reviews. Use '10/15/96 ,

! industry experience (FP&L, Cooper, and FPC) to reinforce l

the points made. l i

l i B RC15 Extend the current outage to achieve immediate, near GKBol' d,tl Completed ,

8 term improvements in plant safety / design margins. 109/96 '

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B-RC1 6 Evaluate personnel in managerial and supervisory roles. JWHolders 8/t 6/97

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! B-RC1 -7 increase autbL#ed engineering staffing level. Seek J.KHolo.pn 8/1/92

, engineering talent from outside FPC that can bring in i fresh ideas, practices and increased design competency.

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! B-RC1 -8 Issue a directive to restore system design margins G. Boldt Completed

primarily through physical means (modification or testing) 10D/96 j as opposed to analytical means. -

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i Rev.2 13 April 18,1997 I

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ROOT CAUCE 2: '

insufficient communication of management expectations - particularly with respect to safety culture.

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COPHECTIVE ACTJO*JS:

TARG F l RESPONSIBLE COMPLETlON l ACTION INDIVIDUAL DATE I B-RC2-1 Estabhsh a clear departmental mission statement with G.L. Boldt Ccmpleted u l emphasis on plant safety, and a concise set of 12/9/96 l expectations for engineering managers. j B-RC2-2 Develop a department wide Administrative instruction J.J.{ Holden 4/30/97 l

" Conduct of Nuclear Engineering and Projects" and

, supporting instructions in each departmental group to promulgate management expectations to each engineering employee.

B RC2-3 Communicate, coach, and continually reinforce adherence J@Holdsn 10/31/97 to mission and expectations through frequent department

, wide meetings, balanced accountabfiity, and site wide I teamwork. (See A RC_1hSj)

B-RC2-4 Establish and promulgate the top ten plant priorities for 1J. }ioiden 4/30/97 Nuclear Engineering and Projects.

B-RC2-5 Ensure resources are provided to achieve quality J.J iHolden 10/1'7/97 engineering support for plant operations commensurate with established priorities, goals, and expectations.

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Rev.2 14 Apnt 18,1997

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CONTRIBUTING CAUSE 1:

! Inadequate performance monitoring, trending, and self-assessment within engineering which precludes:

• Early identification of ec;uipment reliability problems.

• Highlighting repeat failures.

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• Identification of organizational end programmatic issues.

CORRECTIVE ACTIONS

J TARGH i RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE .

l B-CC1 -1 Establish an engineenng tracking and trending program A. BgBaker S/30/97 that includes:

• Measures of the resources needed versus I workload (including that necessary to address

MAR /REA/ precursor backlog).

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• Organizational and Programmatic (0&P)

indicators.

Equipment reliability, end-of-life, and repeat i failure indicators (for human events and systerns/ components).

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B-CC1-2 Implement a program of engineering self assessments J.3[ Holden 8/21/97 1 that detects and ccrrects problems before the NRC, INPO. and other external agencies do.

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2 CONTRIBUTING CAUSE 2:

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) Inadequate deviation analysis of performance indicators which results in ineffective detection of 4 adverse trends related to O&P issues.

4 CORRECTIVE ACTION:

a TARGET

. RESPONSIBLE COMPLETION 4 ACTION INDIVIDUAL DATE j B-CC2-1 Assure the tracking and trending of measures and {Jyolden 9/30/97 i indicators established as corrective action for i Contributing Cause 1 (above) are assessed by engineering l managers to uncover: ]

• Adverse trends requiring increased management '

attention.

• Potential common causes of both equipment and  !

human performance issues.

l Rev, 2 15 April 18,1997 L - -

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1 i CONTRIBUTING CAUSE 3:

Inadequate root and common cause analysis procest, precludes enginee;ing from addressing the right

issues in the correct priority, i-4 -

CORRECTIVE ACTION:

! NOTE: Corrective action for this item is addressed under Root Cause 3 in Section A, Leadersnip l Oversight andInvolvement, of this plan. \

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l CONTRIBUT1NG CAUSE 4:

4 Inadequate communication among managers, supervisors, and engineering personnel which leads to:

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• 1.ack of common awareness of problem extent,

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• Expended effort to resolve problems at too low a level in the organization,

• Focus on inappropriate priorities,

• Denial, or rationalization, of problem existence.

l CORRECTIVE ACTIONS:

! TARGET

! RES'ONSIBLE COMPLETION l ACTION INDIVIOUAL DATE

B-CC4-1 Conduct a series of small group meetings between the 4J,yoider3 6/2/9]

i engineering director and the engineering personnel (no i

- managers or supervisors present) to discuss problems and j l concerns. l l

! B-CC4-2 Conduct a small group meeting between the engineering [J/}loideri 5/9/97 I l- director with engineering supervisors (no managers or j j non-supervisors present to discuss problems and j

? concerns). l B CC4 3 Increase the frequency of engineering staff (manager @[J@ olden 6/5/92 l level) meetings. ,

B-CC4-4 increase the use of engineering stand downs and other all-hands communication and training forums ro

?!J;Holdert 9/2]!97 )

j communicate expectations and lessons learned from '

events, B-CC4-5 increase formal and informal opportunities for improving MHolden 6/27(97 horizontal communications at each level.

Rev. 2 16 April 18,1997

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l V. Measures of Effectiveness:

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[ The following measures will be used to monitor progress and gauge the effectiveness of

! corrective actions for MCAfJigSectiofi:Blin addressing engineering performance:

• TotdOpen? Requests for!Enginsering' Assistance]REAs) ~

'.pv :iRestiri Msdifisations]6hdsr development) l Q 'jPresyrsbrs(;AU/$ipng HssolUtion ~ ~ ~ ~^

+;r quTemporary' MARS installed Qf SSystsm%6ceptance%y;:OpeistiosMndsridsyelopmsrit) i

' M ' I estsiEissue

. R Closure /MCAPiliRestsrt iters f Closuie (undsFdesslophi4nt)

~ " ~ ' ~ ^ ' ~ ' ' ~ "' ' ' ' ~

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• 2 EOpenLPjantYork Arsund lterAs~

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• ) .]Probl0$i Repoit' arid PrscursECsfiCorrsiti9sAbtioRStsps; l l

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l Rev.2 17 April 18,1997

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i Appendix A Action items Carried Over From Previous MCAP Submittals and Meetings l

l l Section B: Engineering Performsnce

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TARGET ]

RESPONSIBt.E COMPLETION i l

ACTION INDIVIDUAL DATE l B-FU-1 Complete a manager level review and pnontizauon ui all F.X. Sullivan 9/1/97

! backlogged REA's.

l B-FU-2 Revise Administrative Instructions and/or NEPs to capture K.82 Baker Completed I

the need to review design basis calculations and 3/31/97 precedures when either document is changed.

l B-FU-3 Complete the action plan for resolution of Control D.F/ KUnsemillei 3/1/98 l Complex Habitability Envelope issues. lS.Cyjfowelp l B-FU-4 Complete corrective actions resulting from the self. K.BliBaker Completed assessment perfoimed on interdisciplinary interaction in 3/31/97 l engineering.

B-FU-5 Enhance the use of lessons learned to improve K.Bj Baker Coispleted performance in engineering. 3/31/97 I

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Rev.2 18 Apra 18,1997

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SECTION C l CONFIGURATION MANAGEMENT AND DESIGN BASIS  ;

1. Area of Concern and Management Sponsor: l l

l Weaknesses have existed in implementing programs for maintaining plant configuration l consistent with design basis. l l

Sponsor: UfRH61deri j i

ll. Probism

Description:

1 The NRC's expectatinn, as contained in the commission's policy statement dated August 10, I 1992, is "...the licensee willhave current design documents and adequate technical bases to j demonstrate that the plant physical and functional characteristics are consistent with the l design basis, the systems, structures and components can perform their intended functions, l

, and the plantis being operated in a manner consistent with the design basis."

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FPC has not fully met this expectation. Weaknesses that have been identified include

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• Discrepancies between the physical plant and design documentation.

• Inaccuracies in the technical content of design documents including incorrect l

- assumptions and calculaticnal errors.

• Discrepancies between operational configuration (procedures) and the supporting design documentation.

, e inconsistencies amorig design documents and between the design basis and licensing i basis.

Examples of deficiencies in these areas have been documented by FPC and the NRC. Some of

, these deficiencies date back to the original design of the plant. We are concerned with the 4 number and cumulative potential effect of these issues on continued safe plant operation. The

identification and resolution of these issues has impacted the workload and prionties of the i

entire nuclear operations organization, and in particular on engineering, operations and i

licensing. FPC has had to operate in a reactionary mode to address these issues as they arcae. i FPC's 10CFR50.59 process is also viewed as inconsistent and examples of weak 50.59 reviews have been cited in NRC inspection reports and PRC reviews. A quality 10CFR50.59 process is reliant on readily available, consistent and accurate design information.

i 111. Present Condition:

i A number of actions have been taken to date which are focused on assuring future engineering

design work is properly performed and all changes affecting plant design are appropriately documented. These actions are as follows

a. Process changes have been implemented to correct weaknesses and eliminate problems from future work.

Rev. 2 19 April 18,1997

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l I l Positive controls have been added to assure modifications are not turned over to I operations unless appropriate procedures have been revised.

• A requirement to obtain an operations signoff on inputs and assumptions tn calculations has been implemented.

• A requirement for engineering to review and sign off changes to the Emergency j Operating Procedures has been implemented.

)

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b. A review of the potential cumulative effect of design basis issues on plant safety has been completed.

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c. A review of the plant Emergency Operating Procedures has been completed to assure the accident mitigation strategies utilized have a complete and accurate technical basis.

d. The modification process has been revised to incorporate Project Teams to assure all i groups within nuclear operations have input to the project design and can more readily

, assess impact of the project on their area.

e. Utilization of the precursor card process has been increased for documenting and resolving configuration and design issues.

i

f. Design Review Panels are formed to review large modifications and piovide a critical, j questioning assessment of the design to assure all design requirements have been addressed and the design impacts are reasonable, i The above efforts are primarily forward looking, and FPC remains challenged to complete j focussed reviews of past design efforts (including the original plant design / basis). Some

problems were also identified by the NRC IPAP team with more recent engineering work. This .

! has indicated that FPC may have taken actions based on treating symptoms rather than the root cause(s) of the problems. For this reason, FPC formed a team toyoteunine' the root and j contributing causes of the configuration management-design basis concern.

IV. Corrective Action to Address the Root Causes of the Problem:

The following paragraphs describe the root causes, contributing causes, and corrective actions to address them to achieve top performance in management of plant configuration and design basis documentation / understanding.

Rev. 2 20 Aprd 18,1997

ROOT CAUSE 1 Limited emphasis on nuclear safety culture in relation to more traditional production priorities, such as capacity and cost, resulting in:

• Inadequate design margins that have not been addressed.

• Limited definition, documentation, and on-site understanding of the plant design basis.

• Lack of comprehensive plant configuration controls.

• Lack of networking with other B&W pl ants to maintain consistent designs / design margMs.

CORRECTIVE ACTIONS:

TAMEF RESPOP'SIBLE COMPLETION ACTION INDIVIDUAL DATE C-RC 1 -1 Establish an independent Design Review Panel (iDRP) to P.M. Beard Completed review the cause and extent of CR3's design basis 10/15/96 problem.

1 C-RC1 -2 Complete review, approval, and disposition of the IDRP J.Jf Heiden 71/29/97 final report recommendations (to be included inf$ectiori C-!D) .

l C-RC1 3 Improve nuclear safety culture. NOTE: This issue is being J.JdHolden 8/8/97 addressed as an integral part of Leadership Oversight and l Engineenng Performance in Sections A and B of this plan.

4 C-RC1 -4 Extend the current forced outage to improve selected G.L. Boldt Completed system design margins by physical plant modification or :1_0/7/96 equipment testing.

C-RC1 -5 Develop and implement longer lead time pians to further J.JMctden 12/31/97 improve plant des gn rrargins and restore consistency 2

with " typical" B&W plant configurations in Refuel 11.

C-RC1 -6 Establish a c ear understanding of what constitutes the J.;JfHe' den Cspleted plant "de' sign basis" which is consistent with industry 4/4/97 standards and regulatory expectations. Then promulgate through plant procedures and training.

C-RC1 -7 Estabhsh a comprehensive management control process F.X. Sul:ivan 12/1/97 i for the design basis which includes requirements for:

• Implementation (how to)

• Maintenance

• Training and qualifications

• Reportability/ operability

• Prioritization/ timely action C-RC1 8 Coordinate future design basis issues through the B&W R.C; Widell C6mpleted Owners Group. t/28/97 Rev.2 21 April 18,1997

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' CONTRIBUTING CAUSE 1: l' t

inadequate self assessment which precludes comprehensive, p;oactive identification and resolution of

design basis issues.

1 j CORRECTIVE ACTIONS:

d TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE i C CC1-1 Conduct a comprehensive failure tr. odes and effects 6/13/97 J.$ Maseda 4 analysis (FMEA) of LOCA, LOOP, and loss of DC Power

'.3 scenario.

{

C CC1-2 Include SSFl style self-assessments of safety significant 3,l.QNolden. jb/1/97 ,

1 systems in the next five CR3 annual plans. j

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V. Measures of Effectiveness

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The following measures will be used to monitor progress and gauge the effectiveness of corrective actions f6.,f,LMC. A,.*R'.l,.l[n

, n S ebtid.h,Clin addressing (shdidesiingMiniiiines.)

~ -

a R4stiftllssUs Clossid/MCAll[Rsstait;lfenilCissOfe]Uhde[desilspijissil l

, M ETemporary#ARsLinstal;4d

,' H :iRsdbisisip!BssdissseTdtsi.:C6minithients I N h'[Open)PIMthdrk^id$Wd ltiwni~ ~' '

N [C0mponent Nat}6 Expoetsd P6isitish

% i Humari;ParfofmancslEisnts impastingan(Operstion; H

~

4Ptscursorsl Awaiting Rssolutidn i Sajhequess fd[En0!n@png[Aisistariji3 REAM i

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Rev. 2 22 April 18,1997

._ _ . . _ - . _.. _ > ~ _ _ . _ . _ . _._____ _ _ _ . . _ _ . . _ _ _ . _ - . _

INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS

1. Design Basis Program

~

I TARGET -

RESPONSIBLE COMPLETION l ACTION INDIVIDUAL DATE l ~C-iD-l-1 FPC should recognize the importance of the Design Basis I and Licensing Basis and take steps to treat them as major l programs with defined scope, clearly assigned ownership, and recognition throughout the organization. (IDRP 1) l Disposition: Accepted. This recommendation willbe resolved by creation andimplementation of one or more NOD's which address ownership and control of the design basis andlicensing basis of the plant.

ai ^ (Design l Basis J:J;eHolderi 811 6197 M i[NCN15~rk. Basis Dfjor!spmillef 9/J 5/97 C-ID-I-2 Estab!ish a clear and complete definition of what K. Bl Baker Completed documents and/or sections of documents comain the 3i31/97 Design Basis for CR-3. Revise NEP-216, Plant Design Basis Documents, as required. (IDRP 2)

Disposition: Accepted. This recommendation willbe resolved by creation of the design basis NOD referred to in #1 chove and by revision to the referenced NEP. (F. X.

Sullivan)

C-ID-I 3 Establish the legal and regulatory status of the Crystal River Unit 3 Final Safety Analysis Report in relation to 1 utilizing the specific information for design engineering l purposes. Also establish what was the independent I review cycle for FSAR submittals. Review the appropriateness of page 141, Volume 1, paragraph 10 that excludes the FSAR as a design docurnent. This may unnecessarily restrict the use of information contained in the FSAR for design purposes. (IDRP 3)

Disposition: Accepted. This recommendation willbe resolved by:

a. The NOD and NEP revisions discussed in #1 and K.Bl Baker Completed

1. 2 above, ~ 3131/97

b. Creation of a nuclear licensing procedure to Dll2Kunsem.itler 1131/98 address the review cycle for FSAR submittals, (B. Gutherman)

c. An FSAR amendment to address the issue on lC_B:\ Bal$ st n/a page 141, Volume 1, paragraph 10 regarding use of the FSAR as a design document. The recommendedfchange to the FSAR is not appropriate; and..will not be.made4The. present wording correctly s_tates the conditions.for;using the FSAR.during thel design process.:

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Rev. 2 23 April 18,1997

I INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS I

1. Design Basis Program (continued)

TARGET i RESPONSIBLE COMPLETION ACTION INDlVIDUAL DATE

)

j C-ID-t 4 As.sure that the responsibility for assunng plant operation ,

is consistent with the design basis is clearly defined and '

understood. (IDRP 7)

~

Disposition: Accepted. This recommendation willbe resolved by:  ;

a. A combination of the NOD referred to in #1 J ~J [Hokfen 4/30/97 i above, a new Al " Conduct of Nuclear l Engineering and Projects", and within the NED \

standards which are sub-tier documents of the l

] Al, ,

b. Within appropriate operations departtnent Alls) 8. J. Hickle 1(31/97 and Olis). JD.M@orteQ

! C-lO-l-5 Ccnsider including all design basis documents (See IDRP K.B2 Baker 9/30/97 l Recommendation 2) at the designated plant locations for design basis documents and electronically on FulText.

~

n bas (documents:-to beincluded in'thisTaction The'desig$dofinedfNOD;56f Eejthbse "ilDRP'1dj " ' '

• Disposition: Accepted. It may not be possible or y practical to include all design basis documents on FulText due to limitations of the software, however those I documents that are compatible willbe placed on FulText. 1 i Approximately 20 sets of design basis ducuments willDe

placed at designated plant locations.

C-ID-I-6 NOD-11, Maintenance of the Current Licensing Basis, DMKunsemiller 1_@ 1198 should be revised to include specific guidance for (nsuring that FSAR changes are reviewed by engineering to identify and then make any appropriate revisions to design basis documents. (IDRP 25)

Disposition: Accepted: A revision to NOD-11 will incorporate this recommendation. (B. Gutherman)

Rev.2 24 April 18,1997

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j INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS

1. Design Basis Program (continued)

TARGET RESPONSIBLE COMPT.ETiON 4 ACTION INDIVIDUAL DATE l C-ID-I-7 FPC should consider promulgating a procedure for the e

control of design / licensing basis information and documentation that applies to the entire Crystal River 3 nuclear organization. This procedure should require any change to the plant, plant documentation or procedures be evaluated for effect on design basis information and documentation. (IDRP 26) i Disposition: Acceptt.d. This recommendation will be

) incorporated intoj i ~

a (=, .:l NOD s); referred to ir[#f aboye K. Baker Completed 12/30/96 b2 WeRCPJmpWmenting; procedure}(Bl G 6therman) .

D,FfKhnsemiIler 9/30/97 C-ID-I 8 Change NOD 52, Commitment Processing and Management of Programmatic Commitments, to clearly identify Design Bases as an important element of the overall Configuration Management Program, and to require actions to ensure thorough assessment and treatment of changes, including the supporting or underlying analyses and assumptions thereto, as well as hardware issues (Structures, Systems and Components).

(IDRP 38)

Disposition: Accepted. This recommendation willbe resolved by;

a. A revision to NOD-52 to incorporate the above DjF[fUns6millfi_ 6131/9]

elements.

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b. Correhtive~ action rna heed to be broader,} K 3l Baker Combleted

'herefoie t thsabove elements wiHalso;be '12/30!96

' ~

bonsidered in developmeniof the NOD '

rnentioned irV# $ and R7;bbovai ^ ' ^ \

c3.~ , ~OCuebive actidos niay need to beW6aded..

D,E;Kunsemitter 9/30/97 l Wonsidered kidevelownehtIcf the CP nieftloned in}lla@yabov&$0thermard ~

Rev. 2 25 April 18,1997

1 INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS il. Engineering Expectotions i

TARGET RESPONSIBLE COMPLETIOld i ACTION INDIVIDUAL DATE f

C-ID-il 1 Assign owrall responsibility and ownership for

. maintaining the Design Basis te a specific manager.

] Also assign ownership of the design baris of defined systems, structures and components to specific positions within the appropriate nuclear organization. Make the

individuals in these positions responsible to provide an j- independent review to ensure that any chant,es to

procedures or hardware affecting their system or component are consistent with the design basis. This I would enhance expert knowledge within the organization of key design basis information. (IDRP 4)

Disposition: Accepted. Overall ownership of the plant f design basis willbe assigned to the Manager of Nuclear l Operations Engineering. Ownership of the design basis

{- for individual systems will be assigned to a system desigr  ;

i engineer. Design basis ownership willbe established by:

a. IOC as an interim action, hX[Sullivan Completed

! 12/20/96 N b. Changes to appropriate procedures (e.g. NOD's, F.X.} Sullivan Completed i NEP's, Al's, and/or NED standards). @ l97 l l C-ID-II 2 The Panel recommends that when dealing with design l

basis issues, FPC take greater advantage of discussions  !

with the other B&W utilities. (IDRP 12)

Disposition

Accepted. This recommendation will be

resolved by.

a Adding " design basis issues" as a standing R.Cj Widell C6mpleted g

agenda item for the B&WOG steering committee, 1/28/97 _

b. Including guidance for design engineers to F. X. Sullivan Com'pleted

discuss design basis issues or questions with the y22/97, j other B&W owners in the NED standards.

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i i INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS

11. Engineering Expectations (continued) 1 J

TARGET RESPONSIBLE COMPLETION i ACTION INDIVIDUAL DATE I C-ID-II 3 Establish additional expectations for the plant's Design F. X. Sullivan Completed Review Panel to ensure that design basis implications of ' ll22/97 '

, the modification have been adequately reviewed and considered. (IDRP 18) l Disposition: _ Accepted. Expectations for the Design 1

Review Panel willbe added to the NED standards.

i 4 C-ID-II-4 To help ensure that inaccuracies in design basis information and documentation are identified and corrected over time, establish clear expectations:

i

• that engineering personnel are accountable for reviewing and correcting design information and requirements.

• that all personnel are expected to report design i j basis deficiencies or questions so they can be j

! addressed. (IDRP 27) l Disposition: Accepted. This recommendation willbe i

, resolved by:

$ a. Incorporating the above expectations for F. X. Sullivan 311/98 4 engineering personnelin the NED standards,

, b. Incorporating regentements for allpersonnel to J. S. Baumstark Complete'd

[

report design basis deficiencies or questions in 11/20196 i CP-111, 4

l Rev.2 27 April 18,1997

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INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS f 111. Training i a

TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE C-ID-lil-1 Develop a training program for ensunng that FPC nuclear employees understand what documents constitute the design basis and the appropriate change control procedures for these documents, particularly when plant modifications are involved. In addition, the training program should cover the distinctive uses of design basis I information, licensing basis information and the impact of l non-safety SSC's on the plant's design basis. (IDRP 5) i Disposition: Accepted. This recommendation willbe resolved by:

a. Conducting interim training (for appropriate K.Bl Baker Completed personnelin engineering and other organizations) 2128197 l based on development of the definition of design 1 basis and the designation of design basis documents. (F.X. Sullivan)

b. Completion of lesson plans for initial and R.Cj Widell 6l30l97 continuing operator and technical training curricula,

c. Completion of initial training. R.C; Widell 1 213119 7 C-ID-Ill 2 The training on the design basis and the use of design R.C:j Widell 12/31197 basis information should be delivered to the appropriate individuals in organizations outside the engineering sections, and it should be covered in continuing training programs for those groups. (IDRP 13)

Disposition: Accepted. implementation of this recommendation is included in the response to #1 above.

C-ID-Ill-3 Develop a station Safety Evaluation (SE) training and qualification program that will result in a consistent understanding of SE process requirements, by all personnel who perform, review and approve SEs. (IDRP 34)

Disposition: Accepted: This recommendation willbe resolved by:

a. Establishing an interim requirement for all safety F.x. Sullivan 6130197 evaluations supporting plant modification to be reviewed by the safety analysis group,

b. Revising' procedure for performance of safety DJ Kinnsenillis( Contpl6t6d evaluations, (B[Gutherman) 3(28197

c. Conducting training for appropriate personnel R.C. Widell 6130/97 designated to perform safety evaluations.

Rev.2 28 April 18,1997

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i i INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS lit. Training (continued) f

, TARGET I RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE i C-ID-lin-4 The plan for the annual Engineenng Phase 3 (continuing) M.C.1Wideu 6/2i97 training should be broken into three or four sessions and the Curriculum Review Committee should provide topic input to each session. This would allow Phase 3 training i to be responsive to current issues. (IDRP 35) i Disposition: Accepted. Engineering continuing training will be broken into more than one session so that engineers can be kept more current on design basis and other engineering related operating experience. _\_M.O;

Tidwely F;Xg SuHiyan).  ;

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C-ID-Ill-5 The Phase 3 continuing training curriculum should be FL;CEWidell Completed more reflective of current design basis and licensing basis 3/17/97 i issues. (IDRP 36) (faket$Uthermeh)

' Disposition: Accepted,~ The~spstidng experience  :

i content of engineering continuing training willbe updated l to include the latest information on these topics. l

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C-ID-Ill-6 Rei) force engineering ownership of its design basis K.B; Baker 6/30/97 i

training program. (IDRP 37) l J Disposition

Accepted. Eng' awing ownership ofits \

t design basis training prograit moil be emphasized in I

appropriate procedure revisions.

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I Rev.2 29 April 18,1997

INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS IV. Procedures A. Nuclear Engineering Procedures TARGET RESPONSIBLE COMPLETION ACTION INDfVIDUAL DATE C-ID-IV-A-1 Performance errors identified dunng design venfication K.B. Baker Completed reviews should be monitored and remedial training and 3/31/97 corrective actions provided for repetitive problems (IDRP 17).

Disposition: Accepted. The verification process will be revised in NEP-261 to include tracking of performance errors. Lessons learned will be addressed by the curriculum committee through remedial and/or continuing training.

C-ID-IV-A 2 Develop specific guidance and training for engineering K.Bv Baker Completed personnel for conducting technical reviews of procedure 3/31/97 changes. This should include emphasis on evaluating the effect of procedure changes on design basis parameters and design requirements and on identifying possible revisions of the FSAR, technical specifications, COLR, and other design basis documents (IDRP 22).

Disposition: Accepted. This recommendation will be addressed bpfincluding speelfic guidance and checklists _.in Al-400C and.Al-400F foghejresponsibilities of Nuclear Engineering personne1 tr u@uate.the offects of procedure changes;on decagn bases and.other technicaI aspects.

C-ID-IV-A 3 Engineering managem, should clearly communicate and K.B. Baker Completed reinforce the need to revise design basis documents 3131./97 promptly following implementation of a plant modification or procedure change. Procedure NEP-216, Plant Design Basis Documen's, should be revised to provide specific guidance for the r um time allowed to make amporary change the design basis documents and to

'rontate tem;s,<uy changes as permanent revisions.

Om ' clear plants typically require permanent revision of dess Vsis documents within 30 - 60 days of implemenu 1 a plant change. (IDRP 23)

Disposition: Accepted. NEP-216 willbe revised to reinforce the need for timely revision of the design basis documents. Dther plants willbe screened to establish appropriate and consistent revision times. NEP-210 may also require revision to address revision of the DBD's.

Rev.2 30 April 18,1997 i

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, A. Nuclear Engineering Procedures (continued) i TARGET l RESPONSIBLE COMPLETION

] ACTION INDIVIDUAL DATE j C-ID-IV-A-4 Revise procedure NEP-213, Design Analyses / Calculations, K.B. Baker Completed to provide specific guidance or a check list for ensuring ~ 3/31/37 that design basis documents are reviewed and revised as a

necessary as a result of an analysis or calculation. (IDRP i 24)

Disposition: Accepted. NEP-213 willbe revised as

, recommended.

4, C-ID-IV-A-5 Change the Modification Approval Record (MAR) process K.B; Baker 6/30197 document (NEP-210) to ensure Design Bases issues are a clearly considered, identified and thoroughly treated consistent with and similarly to NOD-52, Commitment i Processing and Management of Programmatic

\ Commitments, tnd Al-404A, Review of Technical A

Information, and Al-404B, Review ofIndustry Operating i Experience. (IDRP 40) l Disposition: Accepted. NEP-210 willbe revised as recommended.

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.1 INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS IV Procedures (continued)

B. Administrative Instructions TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE C-lD-IV-B-1 Consider revising Al-400C, New Procedures and B.J. Hickle Completed Procedure Change Requests, to require a qualified review 3/31/97 for all procedure changes by either nuclear plant technical support (system engineering) or nuclear engineering design. Alternatively, consider adding to Al-400C, New Procedures and Procer;ure Change Requests, more prescriptive conditions for when a qualified engineering review should be required. (IDRP 19) Disposition:

Accepted. A1400C willbe revised to clarify the conditions for when a technical review by engineering (systems or design) is required. (D W@utttl l

C-ID IV-B-2 Revise Al-400F, New Procedures And Procedure Change K.Bl Baker Completed  !

Processes For Emergency Operating Procedures (EOPs), 3/31/97 Abnormal Procedures (APs), and Verification Procedures (VPs), to require a qualified review by nuclear engineering design for abnormal procedures and verification procedures as well as for emergency operating procedures. (IDRP 20) Disposition: Accepted.

Al-400F will be revised to[ require sl technical revleG{py 1

Nucleeg Operations Engineering (NDE) for Abnorm _al i Procedures [(APs) as well as for Emergency; Operating l Procedures;lEOPs); (GLALBsckeq C. D-IV-B-3 Include the Enclosure 11 guidance from Al-400C, New Procedures and Procedure Change Requests, in Al-400F, New Procedures And Procedure Change Processes For Emergency Operating Procedures (EOPs), Abnormal Procedures (APs), and Verification Procedures (VPs), to assist the originator in determining if the procedure r hnqge affects design conditions or design requirements.  ;

N ider revising Enclosure 11 to be a check-off list to  !

c..z.ne consideration of design basis issues. Provide guidance to identify on the check off list the specific s6ctions of the FSAR, technical specifications, COLR, o; design basis documents that may require revision. (IDRP

21) Disposition: Accepted. Al-400C Enclosure 11 will be revised and included in Al-400F as recommended.

a[ "TAIMO0C;(K;.BJ Baker)

K.B; Baker Completed 3/31197 b' 3 Al:400F (G.A[ Becker)

B4 ;Hickle Completed 3131/97 Asv.2 32 April 18,1997

INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS IV Procedures (continued)

B. Administrative instructions TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE C-ID-IV-B-4 Change procedures Al-404A, Review of Techn/cai K.B4 Baker 6t30/97 Information, and Al-404B, Review ofIndustry Operating Experience, to ensure Design Bases issues are clearly considered, identified, and thoroughly treated. (IDRP 39) e Disposition: Accepted. Al-404A and B will be revised as recommended.

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INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS IV. Procedures (continued)

C. Compliance Procedures t.

TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE C-ID-IV-C-1 Ensure procedure CP-150, / dent /fying and Processing B.J, Hickle Completed Operability Concerns, has an appropriate " process" to 3/17/97 ensure that only appropriate items are notified and reported. (IDRP 41)

Disposition: Accepted. Revisions willbe made in CP-151, "Extemal Reporting Requirements" to incorporate this recommendation. $GNHattn60}

C-ID-IV-C-2 Ensure procedure CP-150, /dentifying and Processing Bljflisckli Completed Operability Concems, includes appropriate guidance from 3/17/97 NUREG-1022 to take advantage of the allowed time frame to evaluate an issue prior to notification. (IDRP 42)

Disposition: Accepted. This will be included in CP-151.

C-\D-IV-C-3 Revise CP-160, Identifying and Processing Operability B;J@li:kle C6mpletsd Concerns, to be consistent with industry practice for the 3/17(S7 shift supervisor to seek assistance in determining the need to make a notification. (IDRP 43)

Disposition: Accepted. This will be included in CP-151.

I.G)Hj Nainon)

Rev.2 34 April 18,1997

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) INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS I 1

V. Technical issues

~

TARGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE j W F1 FPC should complete its efforts to better %fy the bases F. X. Sullivan 6/liSB~ '

and approach to handling piping analysis and piping )

, support design basis issues. (IDRP 6)

Disposition: Accepted. Interim action taken to bring in Ed Wais to review the current piping and support j analyses.

~

C-ID-V 2 The panel recommends and CR-3 had decided to irtstall F. X. Sullivan 6/30197  !

desgn upgrades to the HPl system to enhance operating  ;

j margin in the event of certain postulated transients, l

. (IDRP 8) l k Disposition: Accepted. FPC is planning to install HPI j crossover pipss and cavitating venturis in Refuel 11.

C-ID-V-3 The panel recommends and CR-3 has decided to conduct F. X. Sullivan 6130/97 a thorough investigation to determine why similar j balance-of-plant design features are limiting at CR-3 and not at TMI-1. (IDRP 9)

Disposition: Accepted. FPC will conduct the i recommended review.

C-ID-V-4 FPC should complete their review of the July Framatome F. X. Sullivan 6/30197 Technologies (FTI) report and take any appropriate action.

(IDRP 10)

Disposition: Accepted. Review of the July report is

directly connected with recommendation #3 above. FPC i j

will enter the subject report into the vendc? information i program to control the review.

1

! C-ID-V-5 Obtain controlled copies of the Framatome/B&W type 52 J.Ej Colby 12/31/97

• reference documents for use by station engineering l personnel with appropriate proprietary inic mation 1

' protection. (IDRP 15)

Disposition: Accepted. FPC will obtain site copies of for site access to) the B&Wproprietary design documents.

There is an apparent error in the abcVe recommendation in that the type 52 documents referred to should be type 32 documents.

C-ID-V-6 The Panel encourages FPC to continue implementation of a graded approach to instrument error calculations. (IDRP 45)

Disposition: Accepted. The graded approach to setpoint calculations andinstrument error determinations is continuing, a.f l Setponts' JK,Maseda Completed 2/27/97 bl' J,RJ Masieda 7/1'97 /

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j INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS l VI. Safety Evaluations t

l TARGET

! RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE i C-ID-VI-1 Station management should consider including within the B,.4fbckle Completed i NGRC annual assessment, the Quarterly Manager 3/28/97 i Assessment, or PRC reviews an assessment of the i cumulative effect of design basis and design discrepancies on plant safety. (IDRP 29) l Disposition: Accepted. A decision willbe made as to which group is best to perform the review and the l

respective charter willbe revised.

1

} C-ID VI 2 FPC should establish a " stand alone" Safety Evaluation D.FBKunsemiller, Completed i (SE) format that requires an integrated discussion of the 3/31/97 j proposed change, its effect on safety, and the USQ 4 determination. (IDRP 31)

- Disposition: Accepted. _ (BIGuthermais) j C-ID VI-3 A subcommittee of the NGRC should review SEs after the ).S[Baumstark Codipletsd

! f act sufficiently to address quality, trends, and issues and 4/8/97

report the results to the full NGRC. (IDRP 32)

• Disposition: Accepted. The NGRC will consider establishing a subcommittee to review a sample of the SE's performed. (JM[.MscKyswirQ C-ID-VI 4 Considor limiting the number of personnel allowed to D'F{Kunsen ider'

. Complet@

perform, review, and approve SEs. This should result in 3/31/97 sustaining a level of proficiency in the process and thereby improving the overall quality of SEs. (IDRP 33)

Disposition: Accepted. FPC willmake e decision on this recommendation and factor the resulting approach into the response to Training recommendation #3 above. (B,1 '~

GUthbrisan)

Rev. 2 36 April 18.1997

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I j INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS )

! i 1

Vll. Management issues TARGET HESPONSIBLE COMPLETlON

)

l 1 l ACTION INDIVIDUAL DATE C-ID-Vil-1 FPC should take action to have the Steenng Committed ~ R.C. Widell Completed j

~

of the B&W Owners Group add the subject of Design 1/28/97 j Basis to its regular meeting agenda. Significant value could be gained by davoloping a more standardized l

, approach to this important, emerging issue of design l basis validation and control. (IDRP 11) l

, Disposition: Accepted. See Engineering Expectations 1 recommendation #2 above. i 9

C-ID-Vil-2 FPC management should revise resource planning and ]

.l work managemont practices to ensure that adequate time  !

]

l and priority is provided to perform high quality 4

engineering work and reviews. This should include an 1 l effective screening process to cancel engineering work I requests of marginal value and to assign appropriate  ;

priority and schedules to all engineering work. (IDRP 16) l

Disposition

Accepted. This recommendation willbe l resolved by:

, a. Interim action to establish top ten priorities for G.L . Boldt Completed

} engineering and a revised PMRG process to ' 1212f96 reduce the backlog of plant modification work, l

b. An integrated. resource-loaded, schedule for F. X, Sullivan 12f1197 engineering work.

~ ~

C ID-Vil-3 FPC should proceed with the planned selective SSFis to J.J.; Holden 10/1/97 further assess and ensure the adequacy of the design t

basis information. (IDRP 28)

Disposition: Accepted. FPC plans to conduct 1-2 f,SFis on important safety systems per year for the next 'Ive years. jThis itens is belngjompMed aiacti;oniC4C1}23 l

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1 Rev.2 37 April 18,1997

INDEPENDENT DESIGN REVIEW PANEL RECOMMENDATIONS Vll. Management issues (continued) i i

! TARGET i RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE  !

W-Vll-4 The assessment of recent design bcsis LERs (Tanguay P. R. Tanguay Completed report) on plant safety should be revised to include an 10/28/96 >

i explicit conclusion regarding the cumulative effect of the 44 LERs reviewed. (IDRP 30)

}

Disposition: Accepted. Action complete.

C-ID-V!! 5 FPC undertake action to periodically assess the adequacy of the Design Bases Program and to report on it in a manner that is visible to management and requires .

- organizational response. (IDRP 44) 1 Disposition

Accepted. This recommendation willbe l

resolved by

l I

a. Engineering dyartment self-arsessments, Jy(Holden 812Yl97

b. Ovality Programs audits. J.Baumstark BIS 197

' C-ID-Vll-6 The Panel's charter was " Design Basis'; however, it DEJurgemiller 9/)S/97 i found that in some regards similar problems existed in the Licensing Basis. As implied in Recommendation 1, FPC

{ should take steps to improve the definition, ,

i understanding, and use of the Licensing Basis and  !

consider at least Recommendations 2,4,5 and 7 in that

} regard. (IDRP 46) l Disposition: Acet.pred  !

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! C-ID Vil-7 Develop guidance for operations' personnel tna K.B; Baker 6/20/97 1 establishes expecta. ions for their review of engineering RK Davis l analyses and calculations. It should be clear that the

, operations' review is to vahdate input assumptions related to how the plant is operated and to review

, outputs for effect on plant operation, not to provide a full

engineering verification. (IDRP 47) i Disposition: Accepted. This recommendation willbe resolved Operations Support bf0perationslSimpon Inborporatiny NED bomments on OP9fD07%1nto a ne#

l_

&ationshstruction_ (0lf4l}

i Rev.2 38 AprH 18,1997

SECTION D REGULATORY COMPLIANCE I. Area of Concern and Management Sponsor:

Regulatory Compliance Sponsor: D;f(Kunsemi.Iler

11. Problem

Description:

Crystal River Unit 3 (CR-3) does not have a sufficient understanding of NRC regulations and does not assign full compliance with the intent of NRC regulations a sufficiently high priority.

Also, there appears to be a perception that conservative decision making regarding regulatory issues is seen as secondary to plant availability.

This is supported by the following specific concerns:

A. Examples of failure to report or untimely reporting of events or conditions.

B. Examples of questionable interpretations of the regulations by both licensing and non-licensing personnel.

l I

C. Examples of not meeting commitments made in licensing correspondence. j 1

D. Examples of questionable or incorrect technical information provided in NRC submittals.

111. Present Condition The licensing organization has been modified to infuse knowledge and skills from other areas of Nuclear Operations into the department. The Assistant Director, Site Support position was created and filled by the former operations manager. This new position is dedicated to interfacing with the resident inspectors, facilitating NRC inspections, and developing licensee event reports and violation responses. This dedicated resource has improved the ability to identify and respond to regulatory issues in a more timely manner. Nevertheless, the regulatory interface in some areas of the organization is stillinconsistent and more reactive than proactive.

The Manager, Nuclear Licensing was previously a supervisor in the design engineering organization. This experience has improved the capability of the licensing department to review the technical information in NRC submittals and more fully participate in design basis issues and operability evaluations. The focus of this position is on managing the NRR interface, preparing all licensing submittals (except those noted above) and supporting teamwork throughout Nuclear Operations. However, additional improvement is necessary in at least two aspects of licensing submittals: )

l

1. Technical quality of submittals, which will require line organizations to take more of a j front-end ownership role in submittals for which they provide the technical input. j l

2. More timely and accurate root cause analyses to support LER develcpment. I 1

i Rev.2 39 April 18,1997

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3 i it is also apparent that the knowledge of regult.tions and of the general regulatory process is j not to the necessary levelin the other departments. To facilitate spreading this knowledge to

the other. organizations, the previous Licensing Manager was transferrnd to Operations Support 4

to provide the benefit of his experience to the procedure writers group and Operations Manager. Additionally, a three-day training course on the regulatory process is being offered to all managers and supervisors in Nuclear Operations. The training course provides the

information needed for non-licensing management to understand the foundation for the regulatory process. We expect a better understanding of the regulations and associated requirements governing nuclear power plant operation. This will result in improved compliance and reinforce the expectation that compliance is a fundamental aspect of nuclear safety.

4' Additional emphasis needs to be given to internal processes that assure regulatory compliance.

For example, the safety evaluation process must include regulatory compliance as a necessary condition for acceptance of an alternative. The processes that maintain the current licensing basis must have the proper checks and balances to ensure changes are consistent with the j regulations. Also, processes that do not directly change the current licensing basis, but deal with the decisions and implementing documents used in the plant, must likewise have the I

checks and balances to ensure activities are performed within the proper authorization of the I licensee. l

IV. Root Causes, Contributing Factors and Corrective Actions The following are the root and contributing causes determined by the FPC[ team along with the respective corrective actions to imprnve regulatory compliance throughout the CR 3 4 organization.

I ROOT CAUSE 1: ,

l j Inadequate communication of management expectations and priorities with respect to safety culture ,

and regulatory compliance resulting in:

• FPC positions on some regulatory issues not meeting the safety intent of regulations.

• Regulatory compliance not being considered pro-actively and with high priority when dealing i with site activities, a A perception by personnel that regulatory requiremt,nts should be addressed only from a

, perspective of minimum cost.

• Inadequate and inconsistent explanations of technical issues to the NRC.

• Imprecise or unclaar commitments to the NRC.

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i. CORRECTIVE ACTIONS:

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l TARGET 2 RESPONSIBLE COMPLETION J

- ACTION INDIVIDUA1. DATE l 4

0-HC 1 -1. Estabhsh a safety culture from the top down that clearly J_.5. . Baumstark ;10/31/97 l understands and values the relationship between safe  ;

i plant operations and regu!atory compliance. (Ratated to i A-RC12 and A RC1-4.)

J

{ 0-RC1 -2. Train managers and supervisors on the elements of B. Gutherman Completed I

'l achieving and maintaining regulatory compliance and its 3/28/97 j priority in plant activities.

~

D-RC1 -3. Establish a method which willidentify early on issues B. Gutherman

2/20/98 l l with regulatory impact and ensure these issues are appropriately integrated into site poorities for resolution. [

t l I D-RC1 -4. Develop a site issue integration matrix that parallels the DR KUfeeihiller

~ " ~ ~ ~

Completed l l NRC Resident's matrix. Make comparisons to ensure ~3(18!97

~ ~ ^ ~

i f accuracy. JEKSchruit) )

l Conduct a third party facilitated self assessment of B. Gutherman Corspisted 'l

! D-RC1 -5.

! Licensing. .12/31]96 j i- l

} D-HC1-6. Benchmark key regulatory processes against SALP 1 plants and reviss processes as necessary:

. a. Safety Evaluation Process B.EG.m.6u_s. man, .

Completed I b. Ma htaining of Current Licensing Basis Process B2 Guthe(r6att S/15/97 I (NOD-11, 52) '

i c. Conduct of the On-Site Safety Review BlJjjjchle Completed Comrnittee (Al-300) (G.KHalnon) 3/25/97 i d. FSAR Update Process (hic 7i" ~ ~ B. Gutherman 1/31/98

"~

l (G.HAHalnoni j e. OpM5SilkWocess (CP-150) BlJ@ickle 6/30/97

! (R.W.:Dairls)

{ f. Rehodabi'ity Process (CP-111 presently) B. Gutherman Completed l l

1 "4/10/97 ]

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t i ROOT CAUSE 2:

inadequate performance monitoring and trending from a regulatory compliance perspective which

. preclude:

• Focussing on the right issues in the right priority.

• Obtaining first-hand information on issue content and sensitivity.  !

.

• Obtaining real-tirne information oa emerging issues j d

a Effective implementation of the safety evaluation process.  !

l

) i

CORRECTIVE ACTIONS

TARGET l RESPONSIBLE COMPLETION i ACTION INDIVIDUAL DATE

, D-RC2-1 Ensure a Licensing representative is part of the graded B. Gutherman 5/15/97

{ precursor screening team to provide regulatory

. perspective to the corrective action program.

I Assure appropriate levels of rnanagement meet :jjas D-RC2-2 D.FfKuidoiniller 247[97_

poeded) with the SRl;at his convenience for open, candid l communication. l 1

\

! D-RC2 3

'~

Identify and monitor emerging regulatorp' issues?thioU'gh J.Sl Baumstark

" 8/1/97'~~ '

l i pe' irevieR of Indus3rlexpe6pnceMj0aniels[ Kirk)~' '~'

1

, D-RC2-4 Provide periodic case studies of regulatory issues and E. Gutherman Completed j events, both intemal and external, to help provide ' 3/28/97' a parallels to CR-3 experiences. j i l

1

! CONTRIBUTING CAUSE 1:

1. j f Inadequate root cause/ common cause analysis process which precludes resolution of long term, high j visibility regulatory issues, l l

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,i CORRECTIVE ACTIONS .

1

! See corrective actions for Root Cause 3 of Leadership Oversight and Involvement section. I 4

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Rev.2 42 April 18,1997 i

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) V. Measures of Effectiveness:

! The following measures will be used to monitor progress and gauge the effectiveness of 4

corrective actions in addressing the problem:

l

• Sutimittaf Qualit9'andJimelinsas .

• Ucensind BasielDissrepericiesj {negatise indicutbr)  !

• Ratio of Non-Cited / Total Violations

• CR-3 Licensee Event Reports (LERs) jersus3.FR5 requiritig S6pplem_erits I

si;S'Mimelinsaslof Corninishsnticompletion i

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4 Appendix A Action items Carried Over from Previous MCAP Submittals and Meetings

Section D: Regulatory Compliance 4

i TARGET '

RESPONSIBLE COMPLETION

. ACTION INDIVIDUAL DATE

D-F U- 1 Review the CR-3 5C.59 Prograrn and associated B. Gutherman Completed, processos to ensure it is consistent with the 50.59 rule, 348/97 industry guidance., and current regulatory feedback.

D-FU-2 Review the FSAR system chapters and compare the BS@ickle Completed

- description information to the implementing plant 3/12/97 documents to ensere they are consistent. 1GMalrion) l D-FU 3 Provide training to managers and supervisors on the R.C[Widelj 5/30/97

overall regulatory process. Customize course for 3 days 4

of training by outside professionals with regulatory

{ expertise, facilitated by in-house Licensing personnel to j answer plant-specific ouestions. jH.L.3WalkeQ,M.lDj j bdheIS i i I

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Rev.2 44 April 18,1997

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4 SECTION E OPERATIONS PERFORMANCE

l. Area of Concem and Management Sponsor:

)

• 1 Operations Performance j

! Sponsor: B.J. Hickle 1

Problem

Description:

1 11.

i The Operations Department has not attained a level of performance equivalent to those measured as excellent by INPO and the NRC. Recent outside and internal audits have detailed I several areas in need of improvement in order to attain operational excellence.

i e

Ill. Present Condition:

f Although Operations has some noted strengths such as the conduct of shift turnovers, the use

of STAR by control board operators and the use of alarm response procedures, additional effort is needed to address areas needing improvement. A number of initiatives have been l

undertaken since March 1995, as part of MCAP I and in response to the MUT event to address J j these areas. These have included. ,

I e implementation of the Event Free Operations Program. I I

]

• Establishment of a mentoring program for NSSs and individuals selected for the SRO upgrade program.

• Creation and staffing of a work controls position for day shift.

'

• Creation of an additional level of management to improve management oversight of day i to day operations; especially in the control room.

• Additional staffing with seven engineers including outside hires to infuse new talent into the Operations Department.

• Performance of an outside team self-assessment to enhance operators questioning i attitude and self critique behaviors. j i

1 Notwithstanding these efforts, some problem areas have not been fully corrected as evidenced i by:

• Component mispositioning events.

• Failure to follow procedure events. l

• Inconsistent tog keeping practices. l

• Failure to properly self-identify mistakes with the problem reporting process.

Consequently, MCAP 11 actions to address root and contributing causes of Operations problems have been developed as described in the following.

l IV. Corrective Actions to Address the Root Causes of the Problem: j The following are the root and contributing causes with the corrective actions to upgrade Operations performance.

Rev'. 2 45 April 18,1997

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l ROOT CAUSE 1:

1 Inadequate implementation of established standards. Supervision has not consistently reinforced '

operating standards and this has resulted in:

1. Challenges to plant safety. ,

2. Inadequate work practices.  !

3. Failure to follow operational and administrative procedures. j CORRECTIVE ACTIONS:

l TARGET j l

RESPONSIBLE COMPLETION 1 ACTION INDIVIDUAL DATE  !

E-RC1-1 Present a two hour class in Event Free Operations which R. W. Davis Cornpleted focuses on safety culture to all shifts. Specific items to 2/7.@7.  ;

be covered included: self-disclosure of problems, the i need for self assessments, conservative decision making, ,

importance of increasing margin of safety and the fuel  !

handling event from 10R.

E-RC1 -2 Develop and implement a recurring training class on Event R.CfWidet! 6/30/97 l Free Operations with a major focus on safety culture and j self-assessment to be given annually to NL0s, ROs, SROs i and Operations management. Special attention will be  !

given to the need to be self critical, self-disclosing, and to l do self-assessments. Ofi[i.ind)_ l l

E-RC1-3 Develop and haplement a scheduling / tracking program R. W. Davis 7/30/97 1 that will ensure increased management observation of )

daily shift activities.

)

i E-RC1 -4 Develop structured program for benchmarking by R. W. Davis Completed j Operations personnel to ensure awareness of current 3/27/97 1 industry best practices. I E-RC1 -5 Develop structured and recurrent program for self D.Wl Kurtz Completed ,

assessment. 3/26/9.7 l I

E-RC1 -6 Ensure administrative procedures are included in required R.Cf Widell Completed j reading program and in the licensed ocorator 4/15!97 l requalification program. U.A.?Und)

E-RC1 -7 Fine tune performance indicators which will monitor shift R. W. Davis 6130/97 to shift performance consistency.

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Rev. 2 46 April 18,1997

)

1

CONTRIBUTING CAUSE 1

:

! Inadequate resources within Operations.

! CORRECTIVE ACTIONS:

l TARGET {

4 RESPONSIBLE COMPLETION

. ACTION INDIVIDUAL DATE 1

, E-CC1-1 lmplement changes .(such as establishing an STA/SHO.

R. W. Davis 11/30/97 '

Work Control Supe'rvisor'.and assigning Emergency ,

Codrdinator$$ponsibilities:tolthe NOclear Shift Maria'ger) l

, jhai enable' the dontdlyoom(sEperUlso[to foci.A solelyjri l comfpand an(pontrol ofJhe.operat'ing;crswjjjMcKee) j E-CC1 -2 Reduce the operating procedure backlog to less than 25 R. W. Davis 12/31/97

outstand;ng comments through the use of contract 4

procedure writers. I i

j E-CC1 -3 Improve Operations ability to support Engineering by R. W. Davis Completed; j adding additional resources to Operations Engineer 3/27/97 section.

I i E-CC1 -4 Reduce the abnormal procedure backlog to less than 10 R. W. Davis ;3/30/98  !

outstanding comments through the use of contract l procedure writers. (SpecifiKAPgrequiredLfor psstarilhaVe l dontiftedjand 'are beinitrack'ed yslRestart issue,Oly i

, E-CC1 -5 increase lby;12 the' number;of(Sehlor Reactor 10perator.

R. W. Da<is 5/31J99 licensespAccorppish_ this change by recruiting.and

qualifying license; candidates selecied from,.;otherfPC departments 1and/orlextemat to FPCj 4

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1 CONTRIBUTING CAUSE 2:

r Vague and unclear operating expectations or standards have resulted in operating short falls.

l l CORRECTIVE ACTIONS:

lhlGET RESPONSIBLE COMPLETION ACTION INDIVIDUAL DATE E-CC2-1 Benchmark through plant visits and INPO contacts, those R. W. Davis Completed )

plants noted for strengths in clear, concise expectations 3/25/97 l and standards. l E-CC2 2 Review and revise Operations administrative procedures R. W. Davis Completed J to reflect the information gained through benchmarking. 3/25/97 i

E-CC2-3 Ensure Operations standards reflect the core values and R. W. Davis 10/31/97 l pnncipe!s for conducting business of Nuclear Operations. l

@e[A+RC1j8) i 4

CONTRIBUTING CAUSE 3:

4 Inadequate root and common cause analysis resulting in management failure to address the right issues with proper priority.

CORRECTIVE ACTION:

i E-CC3 See Management oversight and involvement.

f 4

i CONTRIBUTING CAUSE 4:

Inadequate performance monitoring and trending which precludes proactive identification of emerging issues.

f CORRECTIVE ACTION:

E-CC4 See Management oversight and involvement.

V. Measures of Effectiveness:

The following measures will be used to monitor progress and gauge the effectiveness of corrective actions in addressing the problem:

• Cor4rnent[Aisaiting Procedure Rev,isi6ti(CR-3 Monthly 1Perfoidiance Trend)

• Component Not in Expected Position (CR-3 Mo'nthly Performance Trend) '

P1 ) OperatoriPerfortnanc6l(O~peratio'ris Ot@artnient.'in'dicated ' ~ ~ ' ' '"

h PrecursorLCards Generateds1997 (Operations Depariment indicator)

$l Management Assessrnent Index10perations De'partmbnt ' Indicator)

N M n SROfAssessment index.j0perat' ions Department;lsdicatbr)

Rev. 2 48 Arrd 18,1997

1 i

Appendix A 4

Action items Carried Over from Previous MCAP a Submittals and Meetings 1

Section E: Operations Performance TARGET RESPONSIBLE COMPLETION

' ACTION INDIVIDUAL DATE E-FU-1 Nuclear Shift Supervisor (NSS), targeted NSSs, and SRO R. W. Davis J/31/97 upgrade mentor program established.

i E -FU 2 Implement l1997 NSS annual performance goals that D.deMontfort Completed

! address weal ne'sses identified by FPC/NRC/INPO. 3/27/97 E -FU-3 Address allidentified EOP weaknesses. R.W{D. avis 8n5/97 E -FU-4 Operations weaknesses are evident in work practices R. W. Davis 12/31/97 outside the control room, self-critical attitude, and operating procedure backlogs. Operability assessments require increased sensitivity.

E -FU-5 Mentor Program meetings are continuing, mentors R. W. Davis 7/31/97 1

receiving more frequent communications from operations j personnel regarding on-shift concerns. (Related;t6 E-FU2 j J jjompletioridocumsntspoR1;orL E-FU9 j witifstiry(if document l completion;forjthis; action 4 i

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Rev.2 49 April 18,1997

. ,