ML20236H260

Forwards Outline for Util Commitment to Excellence Action Plan Requested at 870715 Meeting W/Nrc in Bethesda,Md

ML20236H260
Person / Time
Site:	Peach Bottom
Issue date:	07/22/1987
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20236H226	List: ML20236H222 ML20236H260
References
NUDOCS 8708050118
Download: ML20236H260 (9)

Text

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j JUL 27 '87 12:43 NRC KING OF PRUSSIA P02

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PHILADELPHIA A ELECTRIC COM PANY 2301 M ARKET STREET P O. BOX 8099 PHILADELPHIA A, PA.19101 ts tol e41.sooi J t7ht P M ww . G A LL A t$ ed P ft w,u .........

July 22 1987 Mr. William T. Runnell, Administrator Region i U. S. Nuclear Kcgulatory Cummission 631 Park Avenue King of Prunsio , PA 19106

Dear Mr. Russell:

As you requested at the meeting in Bethesda, on July l ') . 1987, I am ene)nsing an outline of the Commitment to Mxcellence Action Plan that we expect to setid to you in early August.

I hope- Ltds will he uselui to you in ullucating your manpower for review of the I'la n .

Sin cerely ,

d;.>tli -~_.

Enclosure hojBO0118870730 p DOCK 05000173 PDR

TUd27'8712:44 NRC KING OF PRUSSIA P03 Commitment to Excellence Action Plan Outline 1.0 CXECUTIVC

SUMMARY

2.0 INIR00VC110N 2.1 Regulatory History 2.2 NRC Shutdown Order 2.2.1 Poor Adherence to Procedures and Inattention to Duty 2.2.2 Failure of QA Program to Identify Conditions Adverse to Safety 2.2.3 Insufficient Manageme.nt involvement and Fffect.iveness 2.3 PECo Actions as a Result of the Shutdown Order 2.3.1 Shutdown Activities 2.3.? Changes in Plant Management 2.3.3 Establishment of Internal and External Oversight Groups 2.3.3.1 Internal Management Team 2.3.3.2 Special Committee of the Board of Directors 2.3.3.3 Industry Review Committee 2.3.4 Internal Investigation and Third Party Diagnostic Study 2.3.4.1 Internal Investigation 2.3.4.2 Management Analysis Company (MAC) Third-Party Review l J.U PHOULtM IUtN11 FICA 110N ,

4.0 AC110N PLAN TASK DEVELOPMENT IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSLS 4.1 Introduction 4.2 Project Organization 4.3 Overview of Action Plan Task Development and Implementation Processes 1

JUL 27 '87 12:44 NRC KING OF PRUSSIA PO4 Commitment to Excellence Action Plan Outilne 4.4 Task Identification 4.5 lask Planning o.5.1 Task Description and Purpose 4.5.2 Sub-Tasks and Completlun CeiLeela 4.5.3 Resource Requirements 4.5.4 Initial Impact Analysis 4.5.5 Recommended Scheduling Category 4.5.6 larget Completion Date 4.6 Impact Analysis or Proposed Tasks 4.7 Approval of Tasks for Inclusion in Action Plan 4.8 tinal Integration and Scheduling of Action Plan Tasks 4.9 Action Plan Review and Approval 4.10 Implementation of Action Plan and Related Program Elements 4.11 Acticn Plan Monitoring Process and Monitoring Responsibilities 4.12 Close-Out Acceptance Criteria and Close-out Process 4.13 Negotiating Changes in Task Action Steps or Close-out Acceptance Criteria 4.14 Action Plan Status Reporting Process 4.14.1 Internal Reports 4.14.2 External Reports 4.14.3 Status Reporting and Level of Detail - General Guide Lines 4.lb Iransition of Project Management into Line Organizations 5.0 ACTION PLAN TASKS AND SCHEDl! LING CATEGORIES 5.1 Organization Staffing and Structure 5.1.1 Licensed Operator Resource Development and Training Objective: Ensure availability of sufficient numbers of fully qualified licensed operators to restart PDAPS.

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JUL 27 '87 12845 NRC KING OF PRUSSIA P05 Commitment tu Excellence Action Plan Outline 5.1.2 $hift Organization, Staffing and Rotation Schedule Ohjer.tive: ProviriP inrrFMPd fMnagement and licen5ed oper'ator Coverage on

{ all shifts and use shift resources efficiently.

f 5.1.3 Site Organizational Structures and Staffing Objective: Ensure appropriate organizational structures, adequate super-

. vision, and qualified technicei and noministrative support to perform site functions effectively and efficiently.

4 5.1.4 Off-Site Support Organizational Structures and Staffing T

2 Objective: Clarify accountabilities and provide adequate supervision and ter.hnical ';uppnrt to perfnem site s.spport functions effec-tively and efficiently.

5.1.5 Nuclear Operations Management Structure Objective: Roduce reporting levels betwaan station managers and thu Pres-ident and ensure adequate managerial and technical staff 5.upport for nuclear management.

! B.2 Organization I.eadership and Management ji

-} 5.2.1 Management Role Expectations, Accountabilities, ar.d Processes o.

Objective: Clarify management role expectations and accountabilities, and ensure organizational effectiveness and successful accomplish-nent of the CTE Program.

. 5.2.2 Corporate and Site Plant Performance Trending Objectivet Ensure effective trending and reporting of plant performance indicators for timely review by senior management.

5.2.3 Corporate / Site Communications Objective: Ensure adequate input from all levels of site and support I

organizations prior to corporate decision making, '

h b.P.4 Station Management involvement in Day-to-Day Station Operations i^ Objective:

j Increase station management involvement in day-to-day station operations and improve station management /cmployee communi-n r cations.

$ S.2.5 Site / Support Organization Work Interfaces D Objective: Ensure timely and responsive working relationships between all site and off-site work groups. l I

s 3

IJUL 27 '97'12:45- NRC KING OF PRUSSIA P06 2

J Commitment to Excellence Action Plan Outline 5.2.6 Personnel Policies and Practices Objective: Ensure that personnel policies and practices support nuclear  ;

personnel requirements and performance standards.  ;

5.2.7 Management and Supervisory Skills Improvement  !

Objective: Improve nuclear management and supervisory skills, and develop operations company-wide management awareness nf nut. lear  ;

l requirements.

5.2.8 Attitudinal Change Objective: Ensure that management and employee attitudes support the j Peach'Buttua Commitment to Exco11 onco philosophy. .,

5.3 Plant Procedures, Work Management Systems and Programs 5.3.1 Procedures Upgrade Program Objective: Ensure that plant procedures have been reviewed and revised as required to support safe restart and ongoing operations of PBAPS.

b.3.2 Management Review and Control of Procedures Objective: Ensure effective management and control of the process for creation and rey 1sion of plant procedures.

5.3.3 Administrative Support for Processing of Procedares l

l Objective: Establish efficient administrative support systems for procc-I dure development, revision, reproduction, distribution, main-tenance and control.

f

, 5.3.4 Procedure Awareness and Compliance Objen.t i ve : Ensure site-wide employee awareness of management's expecta-tions with respect to procedural compliance.

5.3.5 Administrative Services for Site Operations Objective: Ensure that site operations are provided with comprehensive, timely and efficient administrative services.

5.3.6 Blocking Permit Process Objective: Improve efficiency of the blocking pernit process while main-taining all safety precautions.

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I EL27'87.12:46. NRC KING OF PRUSSIA P07 Commitment to Excelicnce Action Plan Outitan b.3.7 Surveillance Testing Objective: Ensure efficient use of shift resources for surveillance test-ing.

l b.3.8 Integrated Living Schedule Objective: Improve cowdination and efficiency of operations, maintenance and outage work planning and activities by establishing an Integrated Living Schedule.

S.3.9 Quality Assurance (QA) Program in plant oper-Objective: Expand and turther integrate the role of QA ations to ensure a comprehensive Quality program.

S.3.10 Maintenance and Preventive Maintenance Program l

"' Objective: Establich and maintain excellent plant v.unditions through timely and comprehensive maintenance prograns.

5.3.11 Plant Engineering Support Obje: Live: Imptove collaboration between Station and Engineering Research personnel to ensure timely identification, resolution and implementation of plant modification needs. ,

5.3.12 Radwaste Management Objective: Reduce genere. tion of radwaste and expedite removal of 'Adwaste  !

from site.

o.J.13 Kaoiolugital Cunti'ols Program Objective: Ensure highest levels -of employee and public safety through the establishment of comprehensive and effective radiological controls. .

5.3.14 Plant Chemistry Program f

Objective: Identify and implement methods to improve plant chemistry Conditions.

/

5.3.15 Security and Safeguards Program Objective: Ensure security of access to plant vital areas in comMiance with all federal, state and local laws and regulations.

5.3.16 Fmergency Preparedness Program f

. e _-

215 337 5368 fnmmitanntinIIrnllanrnArtinnHiln-vu o i s i e 5.3.11 Site Procurement l'

! Objective: Ensure timely procurement of services and equipment and avail-ability of spare parts for plant operations, maintenance and outage work.

5.3.18 Commitment Tracking Objective: Ensure effective tracking of all PBAPS commitments.

! 5.3.19 Fuels Management Program Objective: Ensure that fuel performance is maintained within established limits.

5.4 Plant Facilities and Plant Systems 5.4.1 Site Offices and Facilities Objective: Provide adequate permanent office space and facilities for PDAPS personnel.

5.4.2 Plant (quipment t.ay-Up Program Objective: Prevent deterioration of plant equipment status during extended non-operating periods. 1 5.4.3 Critical Equipment Monitoring System (CtMS) ei J ei n i , e31si, i e a ti r 1 , t, a e i 1 t*0niCally.

3.4.4 li o s s a s..y 3 tauu lutus i Objective: Provide site-specific simulator for PBAPS b.4.b Control Room Complex Work Control Improvements Objective: Modify the layout of the Control Room Complex to better meet the needs of operating personnel.

5.4.6 Plant Trip Reduction Objective: Redute the riuitber uf uriplaritied r eactorscrams.

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]*JUL'27'8712:51 NRC KING OF PRUSSIn P02 Commitment to Excellence Action Plan Outline f I

I b.5 Extcrnal Relationships 5.5.1 Review of Closed Commitments Relevant to Shut-Down Order Objective: Analyze corrective actions taken by PECo in the recent Order past i which relate to concerns ideniIfied in the NRC Shutdown to assess effectiveness of actions taken in addressing root cause problems, and incorporate itssons learned into the CTF Action Plan. .;

5.5.2 Management Processes for Establishing and Managing Future Commitments  :;

Objective: Establish effective corrective action programs with involve-ment and commitment of all-Inanagement.

5.5.3 External Communications Management and Processes Objective: Improve formal and informal communication processes about Peach lillllIHl100 liith thA F 00d 10fj $f[y H[ $[h 0.6 Open Item >

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lillillElllEli 11llll llill lill 1111ll lilil il i l 1155 : Ill I i Objective: Ensure that all open items are reviewed for appropriate disposhion/ integration into the CTE Action Plan and monitored effectively until verification of close-out.

5.6.1 Generic Letters 5.6.2 SOERs 5.6.3 ANI S.6.4 Event Reports S.6.5 Bulletins 5.6.6 Sils I

5.6.7 LERs 5.6.8 NRC Inspection Reports b.6.9 Nuregs 5.6.10 Regulations S.6.11 SALP b.6.12 Information Notices 5.6.13 INPO 7

Enclosure 2 Candidate Areas For Diagnostic Team Inspection Team

1. Management Systems Establish a stable management team

- Demonstrate effective management attention in ensuring resolution of identified problems (assurance of quality)

?. Operation Readiness Continue implementation of licensed operator rehabilitation and recruiting Review and updating of procedures Provide Restart Readiness Report

3. Tc,t Programs to Support Restart Demonstrate systems adequacy for restart by an integrated functional test program Develop test program and power escalation milestones and schedule

. 4. Radiological Controls 1; -

Demonstrate increased management attention and involvement in di -

radiological controls improvements

- Continue decontamination efforts

.f' -

Demonstrate implementation of radiological controls corrective actions

5. Maintenance Demonstrate maintenance planning improvements Reduce backlog Improve material condition of plant Assure technical adequacy of procedures

6. Security and Safeguards Continue upgrading of security program (Regulatory Effectiveness Review, September 28 to October 2)

7. Fire Protection Resolve Appendix R program review including any Exemption Request Reviews r

8.

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Staffing Demonstrate staffing shortfalls are being resolved and program for long-term staffing is adequate Show that a staff whose performance was inadequate in the past has now become adequate and that it is properly supervised.

~ -r

.... e Commitment to Excellence Action Plan Outline 6.5 External Relationships

'b.5.1 Review of Closed Commitments Relevant to Shut-Down Order Objective: Analyze corrective actions Ltaken by PECo'in the recent puSL Order which relate to concerns: identified in the NRC Shutdown to assess effectiveness of actions taken in addressing root CTT cause problems, and incorporate itssons learned into. Lhe Actfun Plan.

5.5.2 Management Processes for Establishing and Managing Future Commitments Objective: Establish effective corrective action programs with involve--

mont and commitment of all manggement.

5.b.3 External Communications Management and Processes Objective: Improve formal and informal communication processes about Peach IllI!Is6f nen li' th thn NR~ apd ind 5try )Wg' )prir 0.6

]II I

Open Items ll lll11185111Ell 11 lll lll11 lill lillil Illil lli I .155 III il Objective: Ensure that all open items are reviewed for appropriate disposition / integration into the CTE Action Plan and monitored effectively until verification of close-out.

5.6.1 Generic letters 5.6.2 SOERs 5.6.3 ANI S.6.4 Event Reports S.6.5 Bulletins 5.6.6 Sils 5.6.7 LERs 5.6.8 NRC Inspection Reports S.6.9 Nuregs 5.6.10 Regulations 5.6.11 SALP b.6.12 Information Notices 5.6.13 INPO 7

Enclosure 2 Candidate Areas For Diagnostic Team Inspection Team

1. Management Systems 4

- Establish a stable management team {

Demonstrate effective management attention in ensuring resolution of >

identified problems (assurance of quality)

2. Operation Readiness Continue implementation of licensed operator rehabilitation and recruiting Review and updating of procedures Provide Restart Readiness Report j i

l

3. Test Programs to Support Restart j l

Demonstrate systems adequacy for restart by an integrated functional test program i Develoo test program and power escalation milestones and schedule i

4. Radiological Controls i i

Demonstrate increased management attention and involvement in J radiological controls improvements  ;

Continue decontamination efforts '

Demonstrate implementation of radiological controls corrective actions  ;

5. Maintenance Demonstrate maintenance planning improvements Reduce backlog Improve material condition of plant Assure technical adequacy of procedures

6. Security and Safeguards Continue upgrading of security program (Regulatory Effectiveness Review, September 28 to October 2) 1 7. Fire Protection Resolve Appendix R program review including any Exemption Request Reviews ,

~

r

8. _ Staffing Demonstrate staffing shortfalls are being resolved and program for long-term staffing is adequate l

Show that a staff whose performance was inadequate in the past has now become adequate and that it is properly supervised.

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