ML20148G266
| ML20148G266 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/12/1988 |
| From: | Barkhurst R LOUISIANA POWER & LIGHT CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| W3C88-0003, W3C88-3, NUDOCS 8801260456 | |
| Download: ML20148G266 (6) | |
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LOUISIANA WATERFORD 3 SES P.O. BOX B J
P O W E R & L i G H T ! KILLONA, LOUI5 LANA 70066 Cit),t64 - 330.1 NU$SIY January 12, 1988 R. P. B A RKHURST wr mserur.
NUGLAR P3C88-0003 A4.05 NQA Pride Mr. Robert D. Martin Through Regional Administrator Tearn work U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011
Dear Mr. Martin:
Enclosed is the copy of our new policy, "Excellence in Regulatory Affairs",
which you requested. As we discussed the other week, this was written by me with published guidance from the MSU Nuclear Management Committee.
It is our sincere intent to ensure all our staf f understands the importance we both place on open and timely communication with NRC Region IV and NRR.
Very truly yours, W
R.P. Barkhurst RPB/ cst Attachment cci Mr. Thomas E. Murley (Director - Of fice of NRR)
Mr. J.M. Cain 8801260456 080112 PDR AI;0CR 050003G2 p
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NUCLEAR OPERATIONS DEPARTMENT POLICY ON EXCELLENCE IN REGULATORY AFFAIRS It is the purpose of this policy ~to provide guidance and direction for all LP&L personnel on how to achieve and sustain excellence in regulatory affairs.
This policy is written with guidance from MSUS tra. lear Management Committee in order to help provide for Systemwide consistency in achieving this goal.
Handling Civil Penalty Situations One of the key ingredients in good regulatory affairs is the handling of potential Civil Penalty situations.
Of course, it is most desirable to avoid such a situation in the first place. Our Company and Systemwide goal of achieving excellence in Nuclear Operations is the key in avoiding such a situation to begin with.
When a potential Civil Penalty situation is identified, the approach needs to be timely and aggreceive.
It must be programmatic enough in nature so as to ensure confidence in both the Company and the NRC that it is being properly handled and that recurrence in similar situations or other areas is precluded. Communication with the NRC needs to he confident yet cooperative.
The confidence can only be gained through a thorough understanding of the facts.
It is important that NRC is told everything which could effect one's knowledge and judgement of the situation (candor). When theory or ideas are aired concerning the situation, tney need to be clearly labelled as such.
An acticn plan should be developed to handle the situation, and this plan should be documented. A lead person to coordinate the completion of the action plan and its communication shall be assigned.
Involvement of the Senior Vice President - Nuclear Operations, the Vice President - Nuclear, and/or the Plant Manager - Nuclear, along with advice and counsel by Licensing Management, is expected.
Resources which are nesful in these situations include Company and Washington, D.C.
legal counsel and industrywide information on past handling of related situations.
Systemwide experience and expertise should be brought to play when advisable.
To eisure that this can take place, it is necessary that all such potential escalated enforcement items be communicated to appropriate senior management within AP&L, SEul, and NMC staff.
Should similar previous exp.31ence exist, a teamwork api. roach will' preclude the nacessity of "reinventAng the wheel" and take advantage of lessons already learned elsewhere within the System.
From the start, the Senior Resident Inspector must be kept informed.
It in our policy to always involve him at this "potential problem" stage, not to wait until things are well defined and completely anderstood.
Additionally, it is our policy to keep him well informed of positive progress and initiatives.
Periodic meetings such as the monthly Senior W380078VP
e s-d Nuclear Operations Department Policy on Excellence in Regulatory Affairs Page 2 Resident's briefing of the Plant Manager can be used to acennplish this.
It is the responsibility of the Plant Manager - Nuclear tt i.sure this portion of_the policy is carried out.
Similarly, Region?.1 Mhnagement must be kept informed.
In discussions with the Resident, Plant Staff should always inquire as to Regional involvement and concern.
It shall be the lead responsibility of the Vice President.- Nuclear to ensure adequate communications with Regional Management on matters of potential escalated enforcement.
In keeping with previously established policy for routine communications, it is also the policy that in areas of potential escalated enforcement the Plant and Site Management have the lead in Regional connunications, while Licensing and Regulatory Affairs have the lead in NRR communications.
Additionally, the Senior Vice President - Nuclear Operations and the Vice Fresident - Nuclear ensure that both the Region and NRR are being similarly and accurately informed, such that conflicts and confusion do not arise.
Frequent checks should be made with both parties and with Plant end Licensing Management, to verify that they are receiving the same information and talking to each other.
Finally, it is important to obtain timely completion of the established correctivt action for the particular program plant.
This timeliness, along with adherence to the above policy and guidelines, will ensure that potential escalated enforcement items are minimizer, and that Regulatory management can gain confidence that recurrences are precluded.
Significance and Consequences of Civil Penalties The policy on excellence in regulatory affairs sets the framework for avoiding the necessity for escalated enforcement and the civil penalties l
which may result.
The accumulation of such civil penalties has been the final indicator of low performing plants elsewhere in the iadustry. Once the momentum of such a situation has been attained, it is very difficult to turn around. Such a situation can have a negative impact en the perceived and actual performance of a Nuclear Operations team, its members, and the plant. For this reason the importance of the preventative approach of this policy cannot be overemphasized.
Basic instruction on enforcement regulations and policy is to be regularly included in General Employee Training and Basic Management training given l
to all site employees and new management employees, respectively. Alco, relevant NRC escalated enforcement actions are to be included in required reading for potentially affected department personnel.
It is the responsibility of the Nuclear Operations Support and Assessment to pick out examples of such industry experience, and of the haclear Operations Training Department to include them in continuing and initial training as appropriate.
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Nuclear operations Department Policy on Excellence in Regulatory Affairs Jage 3 our normal progressive disciplinary approach applies to civil per alty situations. We consider it important that discipline be fair and evnsistent, and applied in such a manner as to encourage forthright reporting of problems.
Our basic management training will include a discussion of LP&L/Waterford 3 disciplinary policy.
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A Attachment A MSU Nuclear Policy Excellence in Regulatory Affairs
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Nuclear Operations Department Policy within LP&L.
Jection A - Covered by new policy attached.
i Section B - Improving Operations and Maintenance Credibility with NRC Paragraphs 1 and 2 - Goals, Objectives, Performance Factors,-
and SALP Goals, objectives, and performance factors are prepared using a management procedurt, NOAP-014 Revision 0, "Preparation of Nuclear Operations Goals and Objectives", under the guidance of i
Section II of the NOMM titled "Mission and Goals".
The SALP, paragraph 2, is a goal under paragraph 1.
Being such, the various categories are subaccigned to individual managers and will be part of their performance gcals and appraisals.
Meetings with tne NRC are discussed in paragraph 5.
Section B - Paragraph 3
.NPO The INPO evaluation is a part of the goals process also.
The INPO report and evaluation are assigned to responsible persons for implementation of needed corrective actions. The Site Director has the lead responsibility for the assignment and corrective actions.
Section B - Paragraph 4 - Sensitivity to Regulatory Concerns Executive Directive ED-049 Revision 0, "Excellence in Regulatory Affairs", contains or will contain requirements j
regarding this paragraph.
Also, sensitivity to regulatory concerns is part of management training described in Sect. ion C.
Section B - Paragraph 5 - Communications with NRC Periodic visits and regular telephone conversations are being j
performed. The visits will be coordinated in the future with the NMC efforts in visiting the NRC.
Daily (weekday) information is sent to the NRR regarding plant activities via our liaison in Washington.
The NRC Resident Inspector is invited to attend the daily planning meetings. The Resident Inspector is visited by the Senior Vice President - Nuclear Operations and the Vice President - Nuclear routinely to discuss any concerns that he may have, rurther, the Director of Division of Reactor Projects, Region IV, will be invited to attend a monthly Operational Review Meeting with the Company's President about twice a year.
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Attachment A MSU Nuclear Policy Excellence in Regulatory Affairs Page 2 Section B - Paragraph 6 - Trending The Events Analysis Section is being restructured to include a systematic and consistent root cause determination, trending, tracking, and closure of LERs and NRC IE Inspection findings.
Further, it will be responsible for Part 21 evaluation.and closure.
Section B - Paragraph 7 - Oversight / Effectiveness of Safety Review A review of the PSRC/SRC/ quality programs will be conducted to determine their effectiveness to identify and surface problems.
This effort will be done by April 1, 1988.
Section B - Paragraph 8 - Management Training All first line supervisors will be trained by a new Company strategic thrust in 1988.
Further, candidates are being selected for INPO's Management Training Course and MSU Middle Management Course.
Section B - Paragraph 9 - Keep Informed on Areas of NRC Concern The items in this paragraph are being done in various ways. We have a comprehensive industry experience review process in which Senior Management is kept informed. We al-.
belong to tne Region IV Utility Group and attend the NRC/ Utility Communications meetings.
Our nuclear legal representative attends the Company President's monthly Operations Review meeting and shares issues with the Senior Management. Also, our Licensing Manager periodically visits the NRR, it. part to keep abreast of upcoming concerns and issu6s.
Section B - Paragraph 10 - Characteristics of Utilities Achieving Excellence l
We are aware of the utilities that do very badly and also have the list of the 10 conditions leading to a problem plant.
It appears that a systemwide approach to looking at both good and bad plants may be in order.
From this process, good practices either to enhance pe formance or prevent problems could be developed. This would save duplicating this effort by each plant.
Goals were discussed in Section B, paragraphs 1 and 2.
Section C - Significance and Consequence of Civil Penalties covered by new policy attached.
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