ML20236L791
| ML20236L791 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/07/1987 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20236L768 | List: |
| References | |
| PROC-870807, NUDOCS 8708100360 | |
| Download: ML20236L791 (183) | |
Text
{{#Wiki_filter:t. j 1 (- / 1 t t, I i A ? s Peach Bottom Commitment to Excellence Action Plan i' August 7, 1987 I i
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Peach Bottom Atomic Power Station Philadelphia Electric Company
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g 8708100360 B70807 PDR ADOCK 05000277 P PDR s i
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1 i Ctmmitment to Excallenca Action Plan
, 16BLE OF CONTENTS V
1.0 EXECUTIVE
SUMMARY
..... . .. . . . . . . . . . . . . . . . . 1-1
2.0 INTRODUCTION
AND BACK0ROUND . . . . . . . . . . . . . . . . . . . 2-1 2.1 Recent Regulatory and Industry Relations . . . . . . . . . . . , 2-1 2.2 HRC Shutdown Order . . . . . . . . . . . . . . . . . . . . . . . 2-2 2.2.1 Poor Adherence to Procedures and Inattention to Duty . . . . 2-2 2.2.2 Failure of QA Program to Identify Conditions Adverse to Safety 2-3 2.2.3 Insufficient Management Involvement and Effectiveness . . . . 2-3 2.3 PE Actions as a Result of the Shutdown Order . . . . . . . . . . 2-4 2.3.1 Shutdown Activities . . . . . . . . . . . . . . . . . . . . . 2-4 2.3.2 Changes in Plant Management . . . . . . . . . . . . . . . . . 2-5 2.3.3 Establishment of Internal and External Oversight Groups . . . 2-6 2.3.3.1 Internal Management Team . . . . . . . . . . . . . . . . 2-6 2.3.3.2 Special Committee of the Board of Directors . . . . . . . 2-6 2.3.3.3 Industry Review Committee . . . . . . . . . . . . . . . . 2-7 2.3.4 Engagement of Management Analysis Company to Perform an Inde-pendent Assessment . . . . . . . . . . . . . . . . . . . . . . . . 2-7 2.3.5 Initiation of Internal Investigation . . . . . . . . . . . . 2-8 2.3.6 Review of Open Commitments Related to PBAPS . . . . . . . . . 2-8 3.0 PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIOMS TAKEN TO DATE . . . . . . . ...... . . . . . . . . . . . . . . . . . . . 3-1 (~% 3.1 Operator Behavior Assessment . . . . . . . . . . . . . . . . . . 3-1 (m,) 3.2 Conclusions Related to Root Causes for Declining Performance at Peach Bottom . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2 3.5 Management Analysis Company (MAC) Recommendations . . . . . . . . 3-4 3.4 Corrective Actions Already Taken By PE to Address Root Causes and Improve PBAPS Operations . . . . . . . . . . . . . . . . . . . . . . 3-5 3.4.1 Management Changes . . . . . . . . . . . . . . . . . . . . . 3-5 3.4.2 Licensed Operator Attitudinal Change and Training . . . . . . 3-7 3.4.3 Recruitment and Training of New Licensed Operators . . . . . 3-8 3.4.4 Changes in Operations Organization . . . . . . . . . . . . . 3-9 3.4.5 Procedural Compliance . . . . . . . . . . . , . . . . . . . . 3-12 3.4.6 Quality Assurance (QA) Program . . . . . . . . . . . . . . . 3-13 3.4.7 Personnel Policies . . . . . . . . . . . . . . . . . . . . . 3-14 3.4.8 Communications and Management Involvement . . . . . . . . . . 3-15 3.5 Preparation for Return to Power Operations . . . . . . . . . . . 3-18 4.0 ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-DUT PROCESSES . . . .. .. . . . . . . . . . . . . . . . . . . . . . 4-1 4.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.2 Project Organization . . . . . . . . . . . . . . . . . . . . . . 4-1 4.3 Overview of Action Plan Task Development and Implementation Processes 4-3 4.4 Task Identification . . . . . . . . . . . . . . . . . . . . . . 4-6 4.5 Task Planning . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7 4.5.1 Task Description . . . . . . . . . . . . . . . . . . . . . . 4-7 4.5.2 Sub-Tasks and Close-Out Acceptance Criteria . . . . . . . 4-7 4.5.3 Resource Requirements . . . . . . . . . . . . . . . . . . . 4-7 f~h 4.5.4 Initial Impact Analysis . . . . . . . . . . =. . . . . . . 4-7 \- 4.5.5 Recommended Scheduling Category . . . . . . . . . . . . . 4-8 Table of Contents ii
Commitm nt to Excs11:nce Action Plan 4.5.6 Target Completion Date . . . . . . . . . . . . . . . . . . . 4-9 (~T 4.6 Impact Analysis of Proposed Tesks . . . . . . . . . . . . . 4-11
\ s' 4.7 Approval of Tasks for Inclusion in Action Plan . . . . . . . . . 4-11 4.8 Final Integration and Scheduling of Action Plan Tasks . . . . . . 4-11 4.9 Action Plan Review and Approval . . . . . . . . . . . . . . . 4-11 4.10 Implementation of Action Plan Tasks . . . . . . . . . . . . . . 4-12 4.11 Action Plan Monitoring Process and Monitoring Responsibilities . 4-12 4.11.1 Responsible Individuals and Line Management . . . . . . . . 4-12 4.11.2 Quality Assurance . . . . . . . . . . . . . . . . . . . . . 4-12 4.11.3 CTE Project Manager . . . . . . . . . . . . . . . . . . . . 4-13 4.11.4 Project Review Group . . . . . . . . . . . . . . . . . . . . 4-13 4.11.3 Special Committee of the Board of Directors . . . . . . . . 4-14 4.11. .\ Additional Monitoring . . . . . . . . . . . . . . . . . . . 4-14 4.12 C.ase-Out Acceptance Criteria and Close-Out Process . . . . . . 4-14 4.12.1 C1oss-Out Acceptance Criteria Guidelines . . . . . . . . . . 4-14 4.12.2 -CI.osn Out Verification Process . . . . . . . . . . . . 4-14 4.12.3 hoge tiating Changes in Task Action Steps or Close-out Acceptance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-15 4.12.4 InterDsco with HRC Region 1 on Closed-Out CTE Action Plan Tasks 4-16 4.13 Action Plan Status Reporting Processes and Responsibilities . . 4-16 4.13.1 Internal Reporting . . . . . . . . . . . . . . . . . . . . . 4-16 4.13.2 External Reporting . . . . . . . . . . . . . . . . . . . 4-17 4.14 Transition of Project Management Into Line Organizations . . . . 4-17 5.0 ACTION PLAN TASKS LIST . . . . . . . . . . . . . . . . . . . . . 5-1 5.1 Organization Staffing and Structure . . . . . . . . . . . . . . 5-7 5.1.1 Licensed Operator Resource Development and Training . . . . . 5-7 h 5.1.2 Shift Organization, Staffing and Rotation Schedule . . . . . 5-8 5.1.3 Site Organizational Structures and Staffing . . . . . . . . 5-8 5.1.4 Off-Site Support Organizational Structures and Staffing . . . 5-10 5.1.5 Huclear Operations Management Structure . . . . . . . . . . . 5-11 5.2 Organization Leadership and Management . . . . . . . . . . . . . 5-11 5.2.1 Management Role Expectations, Accountabilities, and Processes 5-11 5.2.2 Corporate and Si te Plant Performance Trending . . . . . 5-13 5.2.3 Corporate / Site Communications . . . . . . . . . . . . . . 5-13 5.2.4 Station Management Involvement In Day-to-Day Station Operations 5-14 5.2.5 Site / Support Organization Work Interfaces . . . . . . . . . . 5-15 5.2.6 Personnel Policies and Practices . . . . . . . . . . . . 5-15 5.2.7 Management and Supervisory Skills Improvement . . . . . . . . 5-16 5.2.8 Attitudinal Change . . . . . . . . . . . . . . . . . . . . 5-18 5.3 Plant Procedures, Hork Management Systems and Programs . . . . . 5-19 5.3.1 Procedures Upgrade Program . . . . . . . . . . . . . . . . . 5-19 5.3.2 Management Poview and Control of Procedures . . . . . . . . 5-24 5.3.3 Administrative Support for Processing of Procedures . . . 5-25 5.3.4 Procedure Awareness and Compliance . . . . . . . . . . . . . 5-26 5.3.5 Administrative Services for Site Operations . . . . . . . . . 5-26 5 . f. 6 Blocking Permit Process . . . . . . . . . . . . . . . . . . 5-27
,5.'3.7 Surveillance Testing . . . . . . , . . . . . . . . . . . . . 5-27 5.3.8 Iqtagrated Living Schedule . . . . . . . . . . . . . . . . 5-28 5.3.9 Quality Assurance (QA) Program . . . . . . . . . . . 5-28 d 5.3.10 Corrective and Preventive Maintinence Program . . . . . . . 5-30 5.3.11 Plant Engineering Support . . . . . . . . . . . . . . . 5-31
(~' 5.3.12 Radwaste Maqagement . . . . . . . . . . . . . . . . . . . 5-32
\- 5.3.13 Radiological' Controls Program . . . , . . . . . . . . . . . 5-33 Table of Contents iii J
~ . . -
CommitmInt to Exc311snce Acticn Plan 1 5.3.14 Plant Chemistry Program .. . . . . . . . . . . . . . . . . 5-35 5.3.15 Security and Safeguards Program 5-36 O
' 5.3.16 Emergency Preparedness Program
. . . . . . . . . . . . . . . 5-37 (
5.3.17 Site Procurement . . . . . . .. . . . . . . . . . . . . . . 5-38 ) 5.3.18 Commitment Tracking . . .. .. . . . . . . . . . . . . . . 5-39 5.3.19 Fuels Management Program . . . . ... . . . . . . . . . . . 5-39 i 5.4 Plant Facilities and Plant Systems . . . . . . . . . . . . . . . 5-39 5.4.1 Site Offices and Facilities . . . . . . . . . . . . . . . . . 5-39 [ 5.4.2 Plant Equipment Lay-Up Program . . . . . . . . . . . . . . . 5-40 5.4.3 Critical Equipment Monitoring System (CEMS) . . . . . . . . . 5-40 5.4.4 Training Simulator . . . . . . . . . . . . . . . . . . . . . 5-41 5.4.5 Control Room Complex Work Control Improvements . . . . . . . 5-41 5.4.6 Plant Trip Reduction . . . . . . . . . . . . . . . . . . . . 5-41 5.5 External Relationships . . . .. . . . . . . . . . . . . . . . . 5-42 5.5.1 Review of Closed Commitments Relevant to Shut-Down Order . . 5-42 5.5.2 Management Processes for Establishing and Managing Future Commitments . . . .. . . . . . . . . . . . . . . . . . . . . . . . 5-42 5.5.3 External Communications Management and Processes . . . . . . 5-43 5 6.0 ACTION PLAN TASK SCHEDULE .................... 6-1 6.1 Commitment to Excellence - Critical Activities . . . . . . . . . 6-2 6.2 Commitment to Excellence - Category 1 Activities . . . . . . . . 6-3 Appendix A. Problem Root Cause Assessment of Peach Bottom Shutdown (MAC Report) . .............................. A-1 () Appendix B. Cross Reference of NAC Report Items with CTE Action Plan Tasks B-1 Appendix C. People - The Foundations of Excellence . . . . . . . . . . C-1 Appendix D. Commitment to Excellence for Nuclear Operations . . . . . D-1 LIST OF FIGURES FIG. 3-1 Operations Organization FIG. 4-1 Action Plan Task Development and Implementation Process FIG. 4-2 Action Plan Task Development & Implementation Flow Chart FIG. 4-3 Scheduling Categories FIG. 4-4 Task Planning Worksheet FIG. 4-5 Change Notification / Request Form FIG. 4-6 Action Plan Task Status Report FIG. 5-1 Index for CTE Project Management List for Open Commitments and Open Items O Table of Contents iv
C mmitmInt tn Exc311 Inca Action Plin 1.0 EXECUTIVE
SUMMARY
O On March 31, 1987, the Nuclear Regulatory Commission (NRC) ordered Philadelphia Electric Company (PE) to shut down the Peach Bottom Atomic Power Station (PBAPS) at Delta, Pennsylvania. The Shutdown Order stated that before PE could restart either unit at PBAPS, PE would be required to submit a detailed, comprehensive plan and schedule to assure the NRC that the facility would be operated safely and in compliance with all requirements, including station procedures. The Peach Bottom Commitment to Excellence (CTE) Action Plan is PE's response to this requirement. The concerns specified in the NRC Shutdown Order included:
- operators sleeping or being otherwise inattentive to their license obligations e a complacent attitude toward procedural compliance in plant operations e failure of the quality assurance program to identify conditions adverse to safety e ineffective plant management, as evidenced by a lack of timely management action to correct these problems, poor dissemination of management goals and policies, poor communications between different departments and g divisions, and a focus on compliance rather than acknowledgement and N correction of the root causes of problems Since the issuance of the Shutdown Order, PE has made a critical analysis of the PBAPS operation from different perspectives and with the assistance of experienced, knowledgeable company and industry personnels
- A senior PE Management Team, which is headed by the President and includes Peach Bottom co-owner representatives, has directed the root cause identification effort and has overseen the development of plans for corrective action.
- A team of senior consultants from Management Analysis Company (MAC) has conducted an independent root cause analysis and submitted a report of its conclusions and recommendations, which have been accepted by PE and are addressed in the Action Plan.
- An Industry Review Committee, comprised of five senior, experienced representatives from the nuclear industry, has provided its advice in response to PE's internal reviews and the MAC report, and has reviewed development of the Action Plan.
- A Special Committee of the Board of Directors was created to monitor the activities of the senior PE Management Team; review and approve the findings and recommendations of that team; make its own, independent evaluation of the problems and their solutions; and report its findings and conclusions to the full Board of Directors. Eugene P. Wilkinson, EXECUTIVE
SUMMARY
1-1
- _ _ - _ - _ _ = - - - - - Commitm:nt to Exc211snca Acticn PIEn Past President of the Institute of Nuclear Power Operations (INPO) serves as Consultant to this Special Committee.
- An internal investigation of licensed operator behavior and conduct has been conducted by a team of professional investigators from the PE Corporate Claims-Security Division.
As a result of these various activities, PE has concluded that declining performance at Peach Bottom was a result of the following root causes:
- poor leadership by plant management
- failure to initiate ti.mely licensed operator replacement training programs e a station culture, which had its roots in fossil and pre-TMI operations, that had not adapted to changing nuclear requirements
- slowness on the part of corporate management to recognize the developing severity of these problems and take sufficient corrective action With the total commitment of the Board of Directors, the Chief Executive Offi-cer, the President, and other PE management, PE has already made significant progress in the following areas to address the concerns identified in the NRC Shutdown Orders
- Plant Management Changes
- Licensed Operator Attitudinal Assessment and Training
- Recruitment and Training of New Licensed Operators
- Site-wide f.ttitudinal Change
- Procedure Upgrade and Procedural Compliance
- Quality Assurance Program Improvements (
- Management Involvement and Communications Each of these areas is discussed below.
Manacement Chances On May 4,1987, Dickinson M. Smith, Rear Admiral, U.S. Navy (Retired), was hired as Manager, PBAPS. He brings to this position over 25 years of nuclear expe-rience, well developed leadership abilities, and a high degree of commitment to making PBAPS one of the best run nuclear plants in the industry. All other levels of operations management at PBAPS have been replaced, or are in the I process of being replaced as soon as the selected personnel have been licensed I and/or trained. I EXECUTIVE
SUMMARY
1-2
Commitm:nt to Exc2113nca Action PIEn The Shif t Superintendents, who were the senior management present on shif t, have been informed of the disciplinary actions to be imposed upon them and know that they will not return to their positions when power operations are resumed. I A new position of Shift Manaaer, reporting directly to the Office of the Superintendent-Operations, has been established to provide a higher level of management authority on each shift. The positions will be filled prior to restart by individuals who have senior operating licenses, degrees in relevant disciplines, and identified leadership skills to ensure that shif t management has in-depth technical knowledge of plant operations and systems, as well as the required managerial ability. The Shif t Manager position will be independent of the shif t operator progression sequence and incumbents will be rotated to and from other management positions every three to five years. Placing this manager on shif t will not only address the past problem of increasing isolation of operators from management, but will also provide needed management develop-ment and career path opportunities for operations management personnel . The cross exposure to different functions (e.g., mainten'ance, outage planning, engineering) will develop increased understanding of the concerns and priori-ties of each functional organization involved in supporting station operations. In addition to the requirements that they have senior operating licenses, relevant degrees, and leadership skills, Shift Manager candidates will be selected on the basis of the excellence of their work history at PBAPS, and their demonstrated interest in being considered for the position. Independent assessments of thei r present attitudinal and managerial aptitudes for the position will be conducted by doctoral-level psychologists from the firm of Rohrer, Hibler & Replosle, Inc. (RHR). Evaluations of each candidate's mana-(Q/ gerial potential will be made by plant operations management. Each Shift Manager candidate will be personally interviewed and selected by the Manager, PBAPS, with approval by the Vice President-Nuclear Operations, and will need to successfully complete a three-week managerial and attitudinal training program prior to being assigned to this position. It should also be noted that, starting with the corporate reorganization in late 1986, there has now been a change in all corporate line management positions responsible for nuclear operations between the Offices of the Chairman and President and the Station Manager. This reorganization established Nuclear Operations as a separate organization from Electric Production, and created a new position of Senior Vice President-Engineering and Production with the Vice Presidents of Nuclear Operations, Engineering and Research, and Electric Production reporting to this position. By making these management changes, PE has focused more corporate management attention on nuclear operations, upgraded the quality of Peach Bottom operations management at all levels, and provided plant leadership dedicated to nuclear excellence. Licensed Operator Attitudinal Assessment and Trainina PE's internal investigation revealeo that, at various times and to varying degrees, all PBAPS operators were inattentive to their duties and engaged in improper control room conduct such as sleeping on duty, reading unauthorized material on shift, or playing video games. As a result, PE concluded that none of these operators are currently acceptable for power operations without atti-EXECUTIVE
SUMMARY
1-3
Ccmmitm:nt to Exc311snce Action Plan tudinal assessment and additional training. Of the 36 plant operations personnel on line assignment as of March 31, 1987, twelve will not return to their managerial positions or licensed shif t duties. These twelve, including the Manager, PBAPS, the Superintendent-Operations, the Operations Engineer, the six Shift Superintendents, two Shif t Supervisors, and one Reactor Operator have either resigned, taken early retirement, or are being reassigned with appro-priate disciplinary action. The remaining 24 licensed operators will be required to participate in an extensive assessment process to determine whether or not each individual has the potential to be successfully trained to meet new standards of operational excellence. This assessment process includes a review of past performance, independent psychological evaluations conducted by RHR psychologists, and individual interviews with the Manager, PBAPS. Those operators who are determined to be eligible for training as a result of this assessment process must then volunteer for the training program after considering the conditions and commitment involved. The conditions are that:
- 1) they are receiving a serious written reprimand for past performance in their servi,ce record;
- 2) they will have to complete the training program successfully;
- 3) they will be required to undergo follow-up independent psychological assessment;and O 4) they will be required to personally commit to a new code of professional conduct before being allowed to resume licensed duties on shift.
A 27-day attitudinal and performance improvement training program, entitled People - The Foundation of Excellence, has been developed by a team of consultants and PE instructors. The course objectives are to:
- 1) help licensed operators identify the underlying attitudes which promoted unacceptable behavior in the control room and change those attitudes;
- 2) improve control room working relationships through the development of interpersonal and group dynamics skills; and
- 3) enhance professionalism on the job.
Skills and abilities associated with effective communications, positive atti-tude, team building, and professionalism are practiced and applied to typical problem-solving and decision-making situations encountered in daily work. The Manager, PBAPS and other members of the PBAPS management staff participate in selected training activities to discuss performance expectations for operators with respect to nuclear operations excellence. The course also includes a section on effective interaction with NRC and INPO representatives. Self, peer, 1 management and instructor evaluation and feedback occur throughout the course. All eligible senior licensed and licensed ope-ators, as well as Shif t Technical Advisors, are attending this course in two class sessions. The first class will end on August 14th, and the second class will be completed on September 25th. EXECUTIVE
SUMMARY
1-4
Commitm2nt to Excs31snca Action Plan Criteria for successful completion of this course include observed positive () behavioral change (based on weekly recorded observations by the Operations Engineer and the course instructors during the course); pre- and post-course assessment of self-awareness, interpersonal and group membership c orape t en ci es by RHR; active performance in class simulations which develop decision-making, problem-solving, conflict resolution and team building skills for application to typical work situations; and understanding of management performance expec-tations with respect to shift operations, Company policies and work rules, the need for procedural compliance, and the roles of nuclear regulators and industry auditors. A summary report will be submitted to the Manager, PBAPS for further assessment of trainees and course effectiveness. This report will be used, along with the psychological evaluations, to determine whether or not each operator is effec-tively prepared to uphold the standards of excellence required to resume licensed shift duties in nuclear power operations. Recruitment and Trainino of New Licensed Operators Recruitment and training of new licensed operators have been accelerated under higher and more formalized standards of entry qualifications and testing. A continuing series of training classes for new licensed operators will be conducted until all required positions are filled and there is a substantial pool of licensed operator personnel in reserve. The current class in licensed operator training (four reactor operators and three senior reactor operators) will take their qualification examination in October. On August 3,1987, a new O licensed operator training class was started for sixteen presently non-licensed operator personnel. All members of this licensed operator training class have successfully passed an aptitude examination. In order to provide a source of personnel for future classes, fourteen new helpers have been hired by PE, all of whom have nuclear Navy experience. PE is also coordinating with Peach Bottom co owners and General Electric to obtain licensed operators to supplement PE's currently available resources until the candidates presently in training have been qualified. Site-Hide Attitudinal Chance Contributing factors to attitudinal problems at PBAPS have included: (1) a lack of effective two-way communications between Nuclear Operations management and ( employees, which resulted in employees feeling that their suggestions and I concerns were not being heard; and (2) a lack of leadership to develop employee understanding of and willingness to comply with the highest nuclear standards. The new Manager, PBAPS has already improved communications and leadership at Peach Bottom. He meets routinely with station staff, senior engineers repres-enting corporate support organizations and key vendor personnel to promote effective communications between all work groups and establish a team approach to all site work activities. He has met individually with all licensed operator personnel, held meetings with each shif t, and established routine weetings with the operators. In addition to informal discussions with other plant personnel as he " walks the plant," he has also had at least ene formal group meeting with every PE work group on site. EXECUTIVE
SUMMARY
1-5
Commitm:nt to Exc211cnce Action Plan In all of his communications and interactions with site employees, the Manager, j () PBAPS has consistently expressed the same two messages (1) he is committed to listening and being responsive to all constructive employee communications; and (2) he expects every employee on site to comply with the standards of excellence demanded by contemporary nuclear requirements. A new code of professional conduct for nuclear employees has been developed. This " Commitment to Excellence" statement is being used to communicate Peach Bottom management's performance expectations to all site personnel. Station management's authority has been strengthened in the areas of hiring, selection for promotion, and discipline to ensure that these performance standards will be maintained. Professional human resource support to assist line management with personnel management and human relations on site is being provided by the establishment of a Nuclear Personnel Specialist position. Procedural Uparade and Compliance To address past problems with procedural compliance at Peach Bottom, PE has' established a corrective action program which includes the following:
- A major procedure review and upgrade effort is being conducted.
Assessments of the need to develop and/or upgrade procedures in different categories will be completed prior to restart. All relevant Operating Procedures are being carefully reviewed to assure that they are current, C' accurate and appropriate. Those which are considered to need upgrading and to be important to safe restart of the plant will be upgraded before restart. Rewriting of selected Administrative and General Plant proce-duren is already underway.
- New management processes are being developed to ensure timely and thor-ough management control over the development and revision of plant procedures. The program will address the procedure change process from identification of the need to add a new procedure or make a procedure change, through Plant Operations Review Committee (PORC) approval, to availability in the controlled copy books.
- A new administrative support function is being established to ensure timely and efficient distribution of procedure revisions.
- Attitudes toward procedural compliance are being examined and discussed as a part of the operator training program, " People - The Foundation for Excellence."
- Additional emphasis is being placed on procedural compliance in opera-tor, technical, and craft training programs.
- Procedural compliance is being added as a job performance standard on employee performance evaluation forms.
- Indeper. dent monitoring of procedural compliance will be performed under fs
( the newly established QA Shif t Operations Monitoring Program discussed in the next section. EXECUTIVE
SUMMARY
1-6
l Commitm2nt to Exc211ance Action Plan Quality Assurance (QA) Prooram l O Improvement of PE's Quality Assurance Program is an essential foundation for l the CTE Action Plan. The role of QA is being integrated into all aspects of plant operations and support. The scope of the QA Program will be expanded to encompass the full spectrum of QA functions from compliance monitoring and commitment tracking to root cause determination and quality engineering corrective action. As a key element in PE's efforts to improve its QA Program, a PBAPS Shif t ! Oparations Monitoring Progran has been established to provide technically ! qualified, independent monitoring of control room and other plant activities on all shifts. Experienced Quality Control (QC) personnel will serve as PBAPS Shift Operations Inspectors and will report directly to the PBAPS Quality Control Supervisor. In turn, the QC Supervisor will report up through the normal management chain to ensure that the Vice President-Nuclear Operations is kept informed on a timely basis about Shif t Operations Monitoring activities and results. Once this Program is fully operational, these Shift Operations Inspectors will replace the QC personnel currently assigned to temporary duty in the control room on each shift. In addition to the Shif t Operations Monitoring Program, the role of Nuclear Operations QA will be expanded to include audits of technical and performance based activities. To impiove the quality of audits, audit team technical specialists, who have specific professional expertise in the area being audited, will receive documented orientations to enhance their auditing skills prior to conducting audits. PE will also assess the need to expand the existing scope of some-aspects of the QA Program to encompass selected balance of plant equipment, systems and operations, with emphasis on areas that most directly challenge safety systems and affect reliability. Organizational changes and work group interface issues which must be addressed to improve the QA function have been assessed and these changes will be imple-mented as specific Action Plan Tasks. Once Limerick Unit 2 has come on line, PE will assess combining all QA functions into one organization reporting to an appropriate senior-level management position. PE recognizes that assurance of quality extends far beyond improvements to the QA function per se, and includes a proactivc commitment to quality operations on the part of each PBAPS manager and employee. This philosophy is captured in the Commitment to Excellence Action Plan with its many Tasks dedicated to improvement of management systems, management skills, organizational account-ability and productivity, plant programs, and work management systems. Furthermore, it will be PE's total assurance of quality effort which will provide for continuing tracking of the CTE Action Plan commitments, assessment of the effectiveness of the Plan and eventual integration of the commitment to excellence into the line management infrastructure of PE when the Action Plan is completed. O EXECUTIVE
SUMMARY
1-7
Commitmant to Excsilsnca Action Pltn danacement Involvement and Communications l l t' Major changes are being made to promote timely and effective communications between all levels of corporate and plant management, and among all PE organ-izations involved in supporting nuclear operations. The management processes used to develop this CTE Action Plan and the processes which will be used to monitor its implementation are indicative of some of these changes. Development of the Action Plan has been under the direct supervision of the President with close overview and support from the Chief Executive Officer. The Manager, PBAPS has direct access to the President on all matters related to restart and achieving operating excellence. A CTE Project Manager position, reporting to the President, has been established and staffed by a PE line manager with strong project management and nuclear support background to ensure full-time dedicated management attention to coordinating Action Plan develop-ment. In addition to the MAC report recommendations, specific Tasks for i,clusion in the Action Plan were recommended by individuals from PBAPS, each matrix organization involved in Peach Bottom operations, and other corporate support organizations. Drafts of Action Plan Tasks were distributed to over 100 PE managers for review and recommendations. A Management Review Committee, comprised of the Vice President-Nuclear Operations, the Vice President-Engi-neering and Research, the Department Managers of Nuclear Generation, Nuclear Support and Maintenance, the Managers of PBAPS and Limerick Generating Station, the Superintendent - Nuclear Operations Quality Assurance, and the CTE Project Manager, has been closely involved in review and approval of the Action Plan Tasks List and the development of the management processes for Action Plan / implementation and monitoring. As the planning, resource loading and scheduling for each Task is developed, the individual responsible for ensuring that the Task is accomplished, reviews any Task which involves collaborative support from other departments with the key individuals involved to obtain their agreement. The Company believes that the processes used in developing the Action Plan have resulted in a " buy-in" by involved personnel, and that the end product of this planning effort is a comprehensive, well conceived, and realistic program. PE intends to manage this Action Plan effectively. Close-out acceptance criteria which define specific observable behaviors or products related directly to Task accomplishment are being carefully developed for each Action Plan Task. These criteria are being reviewed and approved by management to ensure that the Task will not be closed out until the purpose for which it was established has been accomplished. A Project Review Group, headed by the Senior Vice President-Engineering and Production, with Vice President, Department Management and Division Management level representatives from organizations involved in supporting nuclear operations, will meet regularly to monitor Action Plan progress according to schedule and resolve any interdepartmental concerns. PE is committed to maintaining these improvements in management involvement, communications and support once the CTE Action Plan has been completed. Many of the Action Plan Tasks in Section 5.2 of the Tasks List focus specifically on increasing corporate and plant management involvement in ongoing operations at the the site; clarifying organizational and managerial accountabilities for h u plant operations and support; improving interdepartmental work interfaces; and EXECUTIVE
SUMMARY
l-8
Commitmsnt to Excellence Action Plan ensuring effective two-way communication processes between Nuclear Operations management and employees. Other tasks address the need for improved trending and reporting of plant performance indicators and the establishment of routine meetings to review these indicators with Nuclear Operations management and the Senior Vice President-Engineering and Production to ensure continued timely management attention and support for PBAPS operations. These improved plant performance trending reports will also be reviewed carefully by the President, Chief Executive Officer and Special Committee of the Board to monitor and evaluate the success of CTE Action Plan implementation in correcting the root causes of past performance problems. Commitment to Excellence The CTE Action Plan extends beyond the issues raised in the Shutdown Order. From a total of over 275 Action Plan Tasks, more than C00 Tasks cover improve-ments in organizational productivity, development of new program areas, programmatic enhancements, management development, team building, and improve-ment of facilities. Some of the changes already made in areas such as the operations organizational structure and the application of personnel policies to nuclear operations are discussed in Sections 3.4.6 and 3.4.7 of this document. PE selected the name for its corrective action plan carefully: the Company is dedicated to " commitment to excellence" and is providing the management atten-tion, resources and support required for Peach Bottom to attain an excellent reputation in the nuclear industry. Organization of the CTE Action Plan The CTE Action Plan includes five major sections in addition to this Executive Summary. Section 2.0 discusses PE's regulatory history, the NRC Shutdown Order, the immediate actions taken by PE in response to the Shutdown Order, and the internal and external studies commissioned by PE to investigate the problems at PBAPS. Section 3.0 discusses PE's conclusions about the root causes of these problems. The corrective actions already taken to address these root cause concerns are also described. Section 4.0 explains the management processes which have been used to develop a carefully conceived and integrated Action Plan. The monitoring and close-out processes, which will ensure close involvement by management at all levels in Action Plan implementation, are also presented. Sections 5.1-5.5 comprise the Action Plan Tasks List, the heart of the CTE Action Plan, containing over 275 specific Tasks for improving PBAPS operations. In addition to the Action Plan Tasks List included in this submittal, PE has also established a CTE Project Management List for internal use to track all current open commitments and open items which PE has made with respect to PBAPS as a result of external or internal findings. O EXECUTIVE
SUMMARY
l-9
Commitm:nt to Excsilsnce Action Plan Section 6.0, the final section, is a schedule for the Action Plan Tasks and open O commitments / items which PE has defined as Category 1 (i.e., those Tasks and open commitments / items which the Company is committed to completing prior to restart of PBAPS). PE will supply NRC Region 1 additional scheduling information for Category 2 Tasks (those which will be started prior to restart but will not be completed until af ter power operations have been resumed) prior to restart. Scheduling information for long-term Category 3 Tasks will also be provided as these schedules are developed. Preparation for Return to Power Operations PE recognizes that there must be thorough and careful planning involved in prepa ri ng the plant and operator personnel for the return to power operations. A program is being developed for this purpose, consisting of two phanes. The first phase addresses preparation and training prior to restart and the second phase focuses on the actual power ascension restart program. The first phase commences once the Shift Managers have completed their three-week
- raining program. Each Shift Manager and his shift operators will receive training together to ensure their readiness to function as an effective team during .
restart and power operations. The training will include review of the new shif t organization structure and individual responsibilities and authorities; review of procedures; opportunities to pra ctice functioning together as a team by conducting various transient scenarios on the simulator; discussion of methods for monitoring their shift work behaviors, and sustaining a high level of team spirit; and specific training in other areas as deemed appropriate and neces-sary. For the second phase, the Power Ascension Program will consist of procedures and integrated plant operation verifications; follow-on shif t team development; and operational exercises. These will include performance of plant operational surveillance tests and certain reactor start-up exercises, prior to power ascension. During power ascension, operations will be conducted which will provide experience either through direct participation or observation by key operations personnel. PE proposes to restart power operations with only Unit 2'in operation. On or about October 15, 1987, a major reactor pipe replacement outage will begin on Unit 3. The details of the Power Ascension Program will be reviewed with NRC Region 1 prior to start-up. Conclusion In summary, PE has identified root causes of plant performance problems which did not receive sufficient attention from corporate management and intends to resolve these root causes by making permanent, quality corrections. Further, there is a strong commitment on the part of the Board of Directors, the Chief Executive Officer, the President, the Senior Vice President-Engineering and Production, and all of the PE line management involved, to establish and main-tain standards of excellence for PBAPS operation and support. EXECUTIVE
SUMMARY
1-10 ;
CommitmInt to Exc2111nca Action Plan The Commitment to Excellence Action Plan, with its carefully developed manage-I ment processes and comprehensive scope of activities, will ensure the accom-
J plishment of these goals.
O O i 1 i V EXECUTIVE
SUMMARY
l-11
Ccmmitmznt to Exen11snc3 Action PIEn
2.0 INTRODUCTION AND BACKGROUND
On March 31, 1987, the Nuclear Regulatory Commission (NRC) ordered Philadelphia Electric Company (PE) to shut down the Peach Bottom Atomic Power Station (PBAPS) at Delta, Pennsylvania. The order indicated that the shutdown was a result of: 1) information provided to the NRC that control room operators had been observed sleeping while on duty or were otherwise inattentive to their license obligations; 2) previous instances of inattention to duty or failure to follow procedures; and 3) an increasingly poor enforcement record. The Shutdown Order stated that neither unit at PBAPS could be restarted until PE submitted a detailed, comprehensive plan and schedule to assure the NRC that Peach Bottom would be operated safely and in compliance with all requirements, including station procedures. PE has developed such a plan and schedules the Peach Bottom Commitment to Excellence (CTE) Action Plan, which has identified the actions and resources required to resolve the problems identified in the Shutdown Order prior to restart and to initiate and continue a comprehensive approach to attaining excellence of nuclear operations at Peach Bottom. This section of the CTE Action Plan discusses PE's recent regulatory and industry relations with respect to Peach Bottom operations; the specific concerns raised in the NRC Shutdown Order; the actions which PE has taken in compliance with the Shutdown Order; and the actions taken to determine the root causes of the problems which led to the shutdown. O 2.1 RECENT REGULATORY AND INDUSTRY RELATIONS A review of PE's relations with the NRC and industry reviewers indicates that problems have been developing with respect to Peach Bottom operations over the past several years.
- INPO expressed numerous concerns about Peach Bottom performance in 1985 and PE established the Peach Bottom Improvement Program (PBIP) to address the problems identified.
- A less than satisfactory NRC Systematic Assessment of Licensee Performance (SALP) appraisal in 1986 again pointed out deficiencies in the management-of Peach Bottom, and a second, broader-based corrective action effort, the Peach Bottom Enhancement Program (PBEP), was initiated.
PE believes that some positive improvements have resulted from both of these programs, and there were some positive findings by the NRC Diagnostic Team inspection in mid-1986. However, it is now obvious to PE that these corrective actions did not adequately address the root causes of Peach Bottom performance problems. As a r es . ?. t , enforcement actions became increasingly severe as deficiencies continued to be identified in inspection findings. INTRODUCTION AND BACKGROUND 2-1
Crmmitm:nt to Exc311:nco Acticn Plan 2.2 NRC SHUTDOWN ORDER D G The Shutdown Order addressed three concerns in addition to control room opera-tors sleeping while on duty, or being otherwise inattentive to their license obligations. These included: a complacent attitude toward procedural compli-ance with numerous personnel errors; failure of tne quality assurance program to identify conditions adverse to safety; and ineffective management, as evidenced by a lack of timely management action to correct these problems, poor dissemination of management g6als and policies, poor communications between different departments and divisions, and a focus on compliance rather than acknowledgement and correction of the root causes of problems. 2.2.1 Poop Adherence to Procedures and Inattention to Duty Problems with procedural compliance and inattention to duty are described in the Shutdown Order as follows:
" Prior NRC inspections have identified ether instances of inattention to duty or failure to adhere to procedures on the part of licensed operators in the control room at Peach Bot tom."
"On June 9, 1986, the NRC issued a Notice of Violation and proposed a
$200,000 Civil Penalty for several violations that resulted from numerous personnel Orrors by several licensed operators, including the Shift
/'N Supervisor and Shift Superintendent, both of whom are licensed senior U reactor operators, and two licenLed reactor operators. These personnel errors by four licensed individuals and associated violations indicated a pattern of inattention to detail, failure to adhere to procedural requirements, and a generally complacent attitude by the operations staff toward performance of their duties at Peach Bottom. This NRC assessment was emphasized to the licensee in a June 12, 1986 lettar from Victor Stello, Jr., Executive Director for Operations, to J. L2 Everett, III, PE Chairman of the Board and Chief Executive Officer."
"On June 10, 1985, during the 11:00 p.m. to 7:00 a.m. shift, an NRC inspector was present in the Unit 3 control room and observed an on-duty Unit 3 reactor operator sitting in a chair at the Unit 3 reactor control panel with his eyes closed and his head tilted back, apparently asleep or otherwise inattentive to his duties. In response to this charge the licensed operator denied being asleep and indicated he was enticing the NRC inspector to believe he was asleep, demonstrating poor judgment and a negative attitude toward safety. An enforcement conference was held with the licensee concerning this matter on June 21, 1985."
" ... three previous civil penalties were issued for violations of technical specifications involving violations that resulted from personnel error:
March 29, 1983 (EA 83-7); June 13, 1983 (EA 83-46); June 18, 1984 (EA 84-39). In general, the enforcement history at Peach Bottom regarding adherence to procedures and attention to duty has been poor." (" INTRODUCTION AND BACKGROUND 2-2
Commitm2nt to Excellence Action Plari 2.2.2 Failure of QA Proaram to IdentifV Conditions Adverse to Safety In discussing the quality assurance program's role at Peach Bottom, the Shutdown Order states:
"10 C.F.R. 50.54(k) and Peach Bottom Technical Specification 6.2.2 prohibit sleeping or otherwise inattentive operators in the control room.
Under 10 C.F.R. Part 50, App. B, the licensee must have and implement procedures to ensure that activities affecting quality, including oper-ations of the facility, are satisfactorily accomplished. The Peach Bottom quality assurance program has failed to identify this condition adverse to safety. These conditions constitute a hazard to the safe operation of the facility." 2.2.3 Insufficient Management Involvement and Effectiveness Reference is made in the Shutdowii Order to what was naid about insufficient management involvement and effectiveness in the NRC's Systematic Assessment of Licensee Performance (SALP) report for the period April 1,1985 through January 31, 1986 as follows:
"This report concluded that management involvement and effectiveness toward improving operating activities was not evident. Indications of the lack of adequate management involvement included poor dissemination of management goals and policies; poor communications between different departments and divisions; and a focus on compliance rather than acknowl-edgement and correction of the root causes of problems."
In another section of the Shutdown Order, the following statements appear:
"The NRC investigation, which is still ongoing, to date has established:
- 1) At times during various shifts, in particular the 11:00 p.m. to 7:00 a.m. shift, one or more of the Peach Bottom operations control room staff (including licensed operators, senior licensed opeiators and shift supervision) have for at least the past five months periodically slept or have been otherwise inattentive to licensed duties.
- 2) Management at the Shif t Supervisor and Shif t Superintendent level have either known and condoned the facts set forth in Paragraph one, or should have known of these facts.
- 3) Plant management above the Shif t Superintendent position either knew or should have known the facts set forth in Paragraph one and either took no action or inadequate action to correct this situation."
At a later point in the Shutdown Order, the following statement is made
" ... it is apparent that the licensee, through its enforcement history and from what has been developed by the ongoing investigation, knew or should have known of the unwillingness or inability of its operations staff !
O to comply with NRC requirements, and has been unable to implement effective corrective action." INTRODUCTION AND BACK0ROUND 2-3
{ commitment to Excellence Action Plan 2.3 PE ACTIONS AS A RESULT OF THE SHUTDOWN ORDER O PE took a series of actions upon receipt of the NRC Shutdown Order. These actions included appropriate shutdown activities, extensive changes in plant management, the establishment of internal and external oversight groups, the initiation of an investigation into operator behavior at Peach Bottom, the retention of Management Analysis Company (MAC) to perform an independent I assessment of root cause problems leading to the Shutdown Order, and the development of a project team and process to manage the recovery effort (described in Section 4.0). , l 2.3.1 Shutdown Activities In compliance with the Order, PE shut down Unit 3 (Unit 2 was already shut down for refueling) and took several actions to assure itself and the NRC that the facility would be safely maintained in a cold shutdown condition. As described in an April 6, 1987 letter to the Administrator, Region 1 from PE's Senior Vice President-Engineering and Production, these actions included:
- 1) On a 24-hour basis at least one independent, nuclear experienced engineer or physicist per shif t is posted within the control room complex to observe licensed duties. This individual reports directly to the Superintendent of Nuclear Operations Quality Assurance Division at the Corporate Head-quarters. If it becomes necessary for this individual to leave the control room complex for a brief period, his functions are assumed by the Shift 9 Technical Advisor during his absence. The function of these individuals is to verify that licensed personnel are alert and professional in their conduct of licensed duties in accordance with NRC requirements and station procedures. This 24-hour coverage started April 11, 1987 and is ongoing.
- 2) Immediately af ter receipt of the Order, Senior Plant Management began making unannounced visits to the control room during each night shift (2300 hours to 0700 hours). This activity was continued until the additional 24-hour coverage of operations by the special monitoring team was established on April 11. Senior plant mangement continues to make unannounced visits to the control room during the night shift on a less frequent basis.
- 3) An administrative block which onsures that shutdown conditions are maintained was applied on March 31, 1987 at 1730 hours. Removal of the block requires the approval of the Manager, PBAPS or the Superinten-dent-Operations.
- 4) Beginning on March 31, 1987, meetings chaired by the Manager, PBAPS were held with control room operating shift personnel, to discuss the Shutdown Order and events leading to the Order. During these meetings, it was forcefully restated that sleeping or the appearance of sleeping at their posts was unreceptable and would result in termination of employment.
Personnel were urged to be open, frank, and candid during interviews with the NRC on this subject.
- 5) Special meetings, in addition to the above meetings, were held with Shift Superintendents and Shif t Supervisors. In these meetings Shif t Supervision INTRODUCTION AND BACKGROUND 2-4
Commitm:nt to Excs11snc3 Acticn Plan was forcefully reminded by the Manager, PBAPS that it was their r esponsi-
, bility to ensure that personnel on their shift remained attentive and alert and to take appropriate action if this were not the case. Furthermore, they were informed that if they received reports of such situations concerning other shifts or individuals, those reports should be forwarded to Senior 1
Plant Management for disposition. The new Manager, PBAPS has continued to reinforce this message.
- 6) Upon receipt, the Order was posted at the station and a summary was issued '
via a station newsletter. Subsequently, a copy of the Order was distributed to all control room personnel.
- 7) The Peach Bottom Operations Engineer was assigned to Corporate Headquarters effective April 6, 1987 and was replaced with another nuclear experienced, qualified engineer holding a senior operator license at PBAPS. l
- 8) Human factor related changes were made to the control room to make the operators more observable by the Shift Supervisor. The Shift Supervisor's post in the control room was elevated to give him a better view of the room l and the operators. Additionally, the high-back chairs in the control room were replaced with low-back chairs.
- 9) Control room operators are being required to record certain key plant parameters and the decay heat removal equipment status on an hourly basis with review and sign-off by shift supervision to ensure that the cold condition is safely maintained. The recorded data are mode switch posi-p tion, reactor water level and temperature, reactor pressure, reactor head vent valves position (not applicable if reactor head is removed), decay heat removal equipment status (in service or standby), and fuel pool temperature.
- 10) An additiona? status report to Senior Plant Management is now required of the af ternoon and night shif ts. Shortly prior to the end of these shifts, shift supervision reports to Senior Plant Management the plant status and a brief synopsis of shift activities.
- 11) All licensed control room operators have reviewed Administrative Procedure A-7, " Shift Operations," and I.E. Circular 81-02, " Performance of NRC Licensed Individuals While on Duty," and have signed a statement documenting .
that they have read and understand the material. 2.3.2 Chances in Plant Manaaement . l On May 4, 1987, PE appointed Dickinson M. Smith as Manager, PBAPS. Mr. Smith, j who recently retired from the U.S. Navy as a Rear Admiral, brings to this position over 25 years of nuclear experience. Primary responsibility for . 9 developing and executing the PBAPS restart plan at the plant is under his direct supervision, as are all other matters related to the safe and reliable operation of the plant. All other levels in the operations management chain, from the Manager, PBAPS down to and including the Shift Superintendents, have been replaced, or will be replaced before restart. These changes are discussed in more detail in Section 3.4.1. ( INTRODUCTION AND BACK0ROUND 2-5 ;
l l Commitmant to Exc211 enc 9 Action Plan 2.3.3 Establishment of Internal and External Oversicht Groups O 5/ Three oversight groups, an Internal Management Team, a Special Committee of the PE board of Directors, and an Industry Review Committee, were established to assess the situation and assure development and implementation of an effective recovery program. 2.3.3.1 Internal Management Team An Internal Management Team, comprised of senior PE managers and representatives of the co-owners of Peach Bottom, was established to investigate the problems at Peach Bottom and develop and implement corrcctive actions. Membership on the Team includes: John H. Austin, Jr., President and Chief Operating Officer John S. Kemper, Senior Vice President-Engineering and Production Joseph H. Gallagher, Vice President-Nuclear Operations Dickinson M. Smith, Manager, Peach Bottom Atomic Power Station Corbin A. McNeill, Jr., Senior Vice President - Nuclear, Public Service Electric 8 Gas Company J. T. Kelly, Vice President-Interconnection, Atlantic Electric Company H. M Hakefield, Senior Vice President, Delmarva Power and Light Company Management Analysis Company serves as consultant to the Internal Management Team. 2.3.3.2 Special Committee of the Board of Directors A Special Committee of the PE Board of Directors was created to monitor the activities of the Internal Management Teams review and approve the findings and recommendations of that team; make its own, independent evaluation of the problems and their solutions; and report its findings and conclusions to the full Board of Directors. Committee membership includesi Robert D. Harrison, Vice Chairman, John Hanamaker, Philadelphia Robert F. Gilkeson, Chairman of the Executive Committee Edithe J. Levit, MD, President Emeritus and Member of the Board, National Board of Medical Examiners l Joseph J. McLaughlin, President and Chief Executive Officer, Beneficial Mutual Savings Bank l INTRODUCTION AND BACKGROUND 2-6
u. Crmmitm:nt to Excallcnca Action P1En (' Eugene P. Hilkinson, Past President of INPO, is Consultant to . the Special Committee. 2.3.3.3 Industry Review Committee An independent Industry Review Committee, which includes experienced executives selected by INPO from its member companies, has been established to advise PE on its plans for recovery and periodically review plan implementation progress. Members of the Industry Review Committee are Claude C. Cross Assiatant to the President - INPO James Hampton Manager, Catawba Nuclear Station Duke Power Company Donald C. Hintz Vice President - Nuclear Power Hisconsin Public Service Corporation Bruce D. Kenyon Senior Vice President - Nuclear Pennsylvania Power a Light Company Edward E. Utley Senior Executive Vice President'
. Power Supply, Engineering and Construction Carolina Power 3 Light Company 2.3.4 Enaacement of Manaaement Analvsis CompanV to Perform an Independent Assessment On March 31, 1987, PE engaged MAC to conduct a root cause analysis of the problems which led to the Shutdown Order.
In addition to document review and on site observations, the MAC information gathering process included two to three hour interviews with 149 individuals knowledgeable about Peach Bottom operations and management. A total of six sets of interview questions were developed to use with different groups of interviewees. These interviewees included:
- Contractor shift engineers l
e Current and former PE Shift Technical Advisors (STAS) assigned to Peach Bottom rotating shifts (21 interviews) e All shift licensed operators from Shif t Superintendents down through () Reactor Opera tors and selected non-licensed operators (44 interviews)
' INTRODUCTION AND BACKGROUND 2-7
Commitm:nt to Exc211 nc3 Action Plan
- Nuclear Operations and key support organization management at Peach O
O Bottom (46 interviews)
- Corporate management from the Chief Executive Officer (Chief Executive Officer) down through the operations management chain including key support managers and personnel in other areas such as Mechanical and Electrical Engineering, Testing and Laboratories, Maintenance, and Personnel (29 interviews)
- A sampling of the Limerick Generating Station organization including the Plant Manager, shift operators, and selected support managers (9 interviews)
MAC's final report (Appendix A) was delivered to PE on June 17, 1987. ! 2.3.5 Initiation of Internal Investigation The PE corporate Claims-Security Division was directed to investigate operator behavior at PBAPS, with respect to operator inattention to duty as cited in the Shutdown Order, in order to provide management with a basis for appropriate corrective action. Teams of professional investigators from the Claims-Security Division questioned personnel involved with control room operations at Peach Bottom. Operators were also asked broad-based questions about other areas of control room performance to identify any additional problems that might not have been brought to PE management's attention previously. The statements A taken during the investigation were reviewed by the Manager, PBAPS and corporate V Nuclear Operations management as part of their decision-making process on corrective actions to be taken with PBAPS shif t management and licensed operator personnel. 2.3.6 Review of Open Commitments Related to PBAPS PE has also been conducting a review of open commitments which the Company has made with respect to PBAPS to determine the status of open commitments, identify areas in need of additional management attention, and establish a schedule for completion of all open commitments, including those which must be completed prior to restart. This review has included:
- Open NRC Commitments / Actions resulting from Inspection Reports Inspection & Enforcement (ISE) Bulletins Generic Letters PBAPS Licensee Event Reports (LERs)
Regulatory Guides NUREGs INTRODUCTION AND BACKGROUND 2-8
v CommitmInt to Excellencs Action Plan 59stematic Assessment of Licensee Performance (SALP) Reports
/ .
Information Notices
- Op'en INPO Commitments / Actions resulting from Significant Operating Event Reports (SOERs)
INPO Station Evaluations INP0 Corporate Evaluations
- Other Open Commitments / Actions resulting from:
American Nuclear Insurers ( ANI) Inspection Reports PBAPS Independent Safety Engineering Event Reports General Electric Service Information Letters (SILs) l
'PBAPS License Amendments PBAPS Enhancement Program (PBEP)
PBAPS Improvement Program (PBIP) Quality Assurance Audit Findings j The results of this review have been incorporated into the Action Plan as discussed in Section 5.0. l l l 1 l INTRODUCTION AND BACKOROUND 2-9
Problem Identification, O Conclusions and Corrective Actions Taken To Date O 1 1, I f O I
Commitmint to Excallenca Action Plan 3.0 PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE C As described in Section 2.0, PE has analyzed the causes leading to the Shutdown Order from different perspectives and with the assistance of experienced, knowledgeable company and industry personnel. This section of the report discusses PE's conclusions as a result of this analysis. Section 3.1 summarizes conclusions related to operator behavior specifically, while Section 3.2 discusses PE's conclusions with respect to the root causes for declining performance at PBAPS. A summary of the recommendations submitted by MAC in its independent assessment report and PE's response to the MAC report is presented in Section 3.3. Section 3.4 discusses highlights of corrective actions taken to date, and Section 3.5 presents an overview of PE's preparation program for return to power operations. 3.1 OPERATOR BEHAVIORJSSESSMENT The statements taken in the course of the internal investigation by the PE Claims-Security Division and the independent root cause assessment by MAC have been reviewed by Nuclear Operations management and by the Independent Safety Engineering Group (ISEG). The purpose of these reviews was to assess operator behavior and to discover if there were any unreported events or violations, or any additional problem areas on which PE needed to take action. Potential (] \d problems were then investigated on an individual basis. PE has concluded that these statements revealed no unreported events or violations, and no additional problem areas requiring management attention. In addition to the internal investigation conducted by the Corporate Claims-Security Division, individual interviews were conducted by the new Manager, PBAPS with every licensed operator. A comprehensive psychological / attitudinal assessment is also being performed on each operator by an independent team of psychologists from Rohrer, Hibler & Replogle, Incorporated (RHR). PE has concluded that:
- At various times and to varying degrees, all licensed operators were inattentive to their license obligations and engaged in improper control room behavior such as sleeping on duty, reading unauthorized materials, or playing video games on shift
- Shift management condoned unacceptable behavior and, on occasion, set an improper example i
- No PBAPS licensed operators are currently acceptable for power operation without attitudinal assessment, additional training and commitment to a new code of professional conduct
- Up to 24 currently licensed operator personnel have the potential to be
,.- trained to comply with standards of excellence for PBAPS operations, j based on the results of a comprehensive assessment process and their performance in the training program PROBLEM IDENTIFICATI0H, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-1 l l l _m.___._____-.__ ___
Crmmitm:nt to Exc2111nca Action Pirn
- The training program which has been developed for these eligible licensed operators, coupled with the pre- and post-testing and psychological assessment, provides a sound basis for final determination of each operator's attitudinal readiness to resume licensed shift duties Although the investigation did not extend to non-licensed operator behavior, PE believes that
- Inattentive and/or improper shift behavior was not limited to licensed operator personnel
- There is a need to provide additional supervisory direction and moni-toring of non-licensed operator personnel on shift
- There is a need to provide attitudinal training for all non-licensed operator personnel
- There is a need to involve non-licensed operator personnel, along with other site personnel, in site-wide attitudinal change efforts The changes in the PBAPS operations organization discussed in Section 3.4.3 will ensure direct supervision and monitoring of non-licensed operators. All non-licensed operating personnel will be required to participate in an attitudinal training program, and will be involved in site-wide attitudinal change efforts as these are implemented.
O V
3.2 CONCLUSION
S RELATED TO ROOT CAUSES FOR DECLINING PERFORMANCE AT PEACH BOTTOM The Company has concluded that there were four root causes of declining performance at PBAPS:
- 1) There was a lack of adeauate personal leadership and manacement skills on the part of senior manaaement at the plant.
Management goals and performance expectations had not been clearly commu-nicated to Peach Bottom employees; organizational and individual account-abilities had not been clearly established; and little effort had been made to develop a team approach to site work planning and implementation. In general, there were poor communications between site work groups and between the station and off site support groups. Much of the communication downward in the organization was handled by memos and there was a lack of open two way communications between station management and employees. This lack j of leadership had resulted in poor morale in general. The operators, who I were also feeling the results of the second root cause discussed below, had developed serious attitude problems evidenced by their lack of profession-alism ir the control room and by the hostility which they occasionally expressed toward vendor personnel brought in to assist them, other work groups, upper management, and external visitors. O PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-2 3
Commitm3nt to Excallance Action Plan
- 2) The Company failed to initiate timelv licensed operator replacement train-() ino procrams. s
)
There were not enough reserve licensed operator personnel or new replace-ments ready to take over as the existing work force became older, trans-ferred or retired. Although shif t coverage met all safety requirements and Technical Specifications, there was an inadequate supply of licensed oper-ator personnel to: provide flexibility for relief or rotational assi gn-ments; handle the shift administrative workload effectively; or assure direct supervision of all control room and floor activity. Many licensed operator personnel were complaining about the negative impact on their family lives created by their having to work extensive overtime. They were also seriously concerned about the lack of opportunities to pursue alternative career paths or to have some relief from shift work at some point in their career progression with the Company.
- 3) The station culture, which had its roots in fossil and pre-TMI operations, had not adapted to chancino nuclear requirements. .
PE operated a high temperature helium cooled reactor at Peach Bottom Unit 1 from March, 1966 until the unit was decommissioned in October, 1974. As Peach Bottom Units 2 and 3 became operational during 1974, Unit 1 personnel , were assigned to operate these new units. With few exceptions, the PBAPS management personnel and operations crews were transplanted PE fossil plant employees who had received nuclear operations training. The organizational g structure and management philosophy used to operate the units were typical (/ \_ of those in the fossil plants. In the early years of PBAPS operations, when the regulatory environment was less prescriptive than it is today, these transplanted fossil operators proved themselves to be technically competent, and PBAPS had an excellent reputation in the industry. With their roots in the pre-TMI culture, and their confidence in their own technical proficiency, the PBAPS operators did not respond adequately to l' the increasing regulatory requirements of the post-TMI nuclear ~ environment. Plant and nuclear operations management, which had developed in the same i pre-TMI environment, did not provide the leadership to adapt the PBAPS culture to these newer standards.
- 4) Corporate manaaement failed to recoonize the developina severitv of the problems at PBAPS and thus, did not take suf ficient corrective actions. /
Based on corporate reviews of plant performance and NRC and INPO reports over recent years, PE had recognized that problems were developing at Peach Bottom, and had taken substantive corrective actions. Corporate management believed that the corrective action programs -- major \; facilities improvements, the PBAPS Improvement Program, begun in 1985 in () response to INP0 findings, and the broader-based PBAPS Enhancement Pregram ( . PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN T4 DATE 3-3 I
]
** vr '
is' it' Commitm:nt to Excell:nca Acticn Plan initiated primarily in response to the NRC 1986 SALP Report -- would resolve the declining performance problems at PBAPS.
] ,
While these programs have resulted in major improvements in several areas and are progressing on schedule, PE now recognizes that they were not sufficient to address the root cause problems of poor plant leadership, a shortese of licensed operator personnel, and an increasingly obsolete plant culture. J 3.3 MANAGEMENT ANALYSIS COMPANY (MAC) RECOMMENDATIONS - The MAC Problem Root Cause Assessment of Peach Bottom Shut Down report is i included in its entirety in Appodix A. MAC indicated that, because the scope i of the task was to identify problem areas, the report does not address positive i areas of Peach Bottom operatitns. ' Their conclusions and recommendations should i be read with that understanding's. MAC's r recommendations are grouhnd in four areas: i
- Cultural and Attitudinal' influences
- Leadership and Management Issues D + Personnel Policies hdclear Operations Applications and Implementation
- External Relationships In the Cultural and attitudinal area, MAC has made three major recommendations: one directed specifically at comprehensive operator attitu-dinal training and the other two directed toward a broad scale attitudinal change effort with one focus at the Peach Bottom site and the other focus on corporate / Peach Bottom site interactions.
There are twelve comprehensive recommendations in the leadership /Manacement area covering the needs fore additional supervisory positions in the PBAPS organization, clarification of organizational accountabilities and authorities, integration of the Quality Assurance program into all aspects of plant oper-ations, improved; management review and control of procedures, improved commit-ment tracking, improved management / supervisory development programs, and an improved employee performance management program. MAC points out that PE's efforts at broad-scale attitudinal change cannot be successful without a careful realignment of management philosophy, practices, and organizational structures to support the goals of the' phange ef fort. The report suggests that an infusion of new managerial perspectives and nuclear talent into the Nuclear Operations organization will also support this change effort. NnthethirteenrecommendttionsinthePersonnelPoliciesarea, MAC points out tfie. need for PE to modify its entry level hiring, disciplinary, grievance and promotion policies as they apply to nuclear operations; establish alternative career paths for operator personnels and conduct special training sessions for PROBLEM IDENTIFICATI0H, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-4 f k
Ccmmitmxnt to Exc3112ncs Action P1En PBAPS managers and supervisors to ensure that they understand and apply all personnel policies effectively. Finally, MAC has made four recommendations in the section on External Relationships which focus on improving relations with the NRC on PBAPS oper-ations; reviewing corrective action commitments made in the recent past to ensure that they are achieving the desired results; improving trending ' and reporting of plant performance indicators 'and ensuring timely senior management review of such reports; and improving PE's management processes with respect to making future commitments. The Company believes that all of the MAC conclusions are valid and has accepted all of the recommendations in the report. Appendix B shows a cross reference between tach MAC recommendation and the corresponding Task (s) in the CTE Action Plan Tasks List which will implement that recommendation. 3.4 CORRECTIVE ACTIONS ALREADY TAKEN BY PE TO ADDRESS ROOT CAUSES AND IMPROVE PBAPS OPERATIONS PE has already made significant progress in addressing the root causes for the problems identified in the NRC Shutdown Order and improving PBAPS operations. Each of these progress areas is discussed in detail below.
) 3.4.1 Manaaemerd Channes On May 4, 1987, Dickinson M. Smith, Rear Admiral, U.S. Navy (Retired) was hired as Manager, PBAPS. He brings to this position over 25 years of nuclear expe-rience, well developed leadership abilities, and a high degree of commitment to making Peach Bottom one of the best run plants in the country. All other levels of operating management at PBAPS have been replaced, or are in the process of being replaced as soon as the selected personnel have been licensed and/or trained.
John B. Cotton will become Superintendent-Operations, upon completion of his Senior Reactor Operator (SRO) qualification for PBAPS within the next two months. He is already SRO-licensed at Limerick Generating Station (LGS), where he served as Maintenance Engineer for eight years prior to being assigned as Superintendent-Plant Services at PBAPS in May, 1986. Gerald R. Rainey has replaced Mr. Cotton as Superintendent-Plant Services, PBAPS. For the last six years, Mr. Rainey has held responsible supervisory positions in the Instrumentation and Controls discipline at LGS where he was a qualified SRO. He also brings experience in coordinating Maintenance Department vendor activities to his new assignment. Frederick H. Polaski, SRO qualified at PBAPS, has been assigned as Operations Engineer, PBAPS. Prior to his appointment to this position in April of this year, Mr. Polaski had served as Outage Planning Engineer at PBAPS for four () years. PROBLEM IDENTIFICATION, CONCLUSIONS %ND CORRECTIVE ACTIONS TAKEN TO DATE 3-5
Ccmmitm3nt,to Exc311snc3 Action Pltn
^
Q. 3 i The Sbif t Superintendents, who were the senior management present on shif t, have '[ ' been informed of the disciplinary actions to be imposed upon them and know that they will not return to their positions when power operations are resumed. A new position o[ Shift Manager, reporting directly to the Office of the , Superintendent-Operations, has been establishe,d.to provide a higher level of managanent authority on each shif t. The positions will be filled by individuals who have senior operating licenses, degrees in r6 levant disciplines, and iden-tified leadership skills to ensure that shif t management has in-depth technical knoyledt e of plant operations and systems and the required managerial ability. The Shiftt Nanager position will be independent of the shif t progression sequence and h enabents will be rotated to and from other management positions every Me yt'o five years. Placing this manager on shift will not only address the ; padttproblem of increasing isolation of operators froa mana9ement, but will also ' p'rovida needed mana mnt development and career path opportunities for ) professional operations personnel. In addition, the cross exposure to differ-ent functions (e.g. maintenance, outage planning, engineering) will develop increased understanding of the concerns and priorities of each functional > organization involved in supporting station operations. l
' There are twelve senior licensed station engineers who are being considered as !
candida tes for 'the Shif t Manager positions. All twelve candidates have already heen through an assessment process conducted by Rohrer, Hibler and Replogle, Inc. (RHR) psychologists. In addition to assessing the attitudinal readiness of each candidate to establish and maintain standards of nuclear operations i exce(lence, these teams of psychologists have also assessed the managerial aptiiudes of each candidate in areas such as ability to take command, decis-O iw[ making initiative, discretionary judgment, intuition, and interpersonal skills. Each candidate will receive personal feedback from the psychologists about managerial strengths and areas in need of improvement, as well as a recommended personal development plan to improve in the areas specified. s
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S k j i The Manager, PBAPS will be using these assessments, as we;l as personal inter- I views with each candidete,'a edview of their performance history, and the j
'
- evaluations of operatior.s %anagement personnel about each candidate's potential ability to do the job, to make hh selection of the final candidates for shift
- Managers, with approval by the Vice President-Nuclear Operations. Before being 1 assigned to the position, these final candidates will have to complete a k three-week Shif t Manager training program which will include mananerial skills, q group dynamics, interpersonal communications, disciplinary issues, and manage-ment performance expecta tions to ensure nuclear operations excellence.
l 3 it should also be noted that, beginning with the corporate reorganization in t
, ete 1966, there has been a change in all corporate line management positions responsible for nuclear operations between the offices of the Chairman and President and the Plant Manager. Tnic reorganization established Nuclear Opci ations as a separate organization from Electric Production. It also created sa new position of Senior Vice President-Engineering and Production, with the Vice Presidents of Nuclear Operations, Engineering and Research, and Electric Production reporting to this position.
By making these management changes, PE believes that it has provided more focused corporate management attention on nuclear. operations, upgra ded the ; 1 3 FRDBLEM IDEN11MCA'10N, C0FCf.USIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-6 l s
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Ctmmitm:nt to Exc2110nc3 Action PIEn quality of Peach Bottom operations management at all levels, and provided plant O leadership dedicated to nuclear excellence. l O 3.4.2 Licensed Operator Attitudinal Channe and Trainina PE's internal investigation revealed that all PBAPS operators had, on occasion and to varying degrees, been inattentive to their duties and engaged in improper control room behavior such as sleeping on duty, reading unauthorized materials, or playing video games on shift. As a result, PE concluded that none of these licensed operators are currently acceptable for power operations without atti-tudinal assess:aent, additional training and personal commitment to a new code of professional conduct. Of the 36 plant operations personnel on line assign-ment as of March 31, 1987, twelve will not resume their managerial or licensed shift duties upon PBAPS return to power operations. These twelve, including the Manager-PBAPS, the Superintendent-Operations, the Operations Engineer, the six Shift Superintendents, two Shif t Supervisors and one Reactor Operator, have either resigned, taken early retirement or are being reassigned with appropriate disciplinary action. l The remaining 24 licensed operators will be required to undergo an extensive l assessment process to determine whether or not each individual has the potential to be successfully trained to meet new operator performance standards of excellence. This assessment process includes a review of past performance, individual interviews with the Manager, PBAPS and an independent psychological assessment. The independent psychological assessment is being performed by the RHR psychologists mentioned in Section 3.4.1. An in-depth assessment interview, lasting two to four hours, is conducted by a team cf two psychologists with each of the potentially eligible licensed operators to determine the operator's readiness to adapt to the shif t work environment and management expectations for excellence in nuclear operations. Following these interviews, the RHR team prepares a narrative description of the interview with conclusions about the interviewee's potential for development. A verbal review of each assessment interview is then held by the team with the Manager, PBAPS. This input is being used by the Manager, PBAPS in screening licensed operator persennel for eligi-bility to participate in attitudinal training and further consideration for return to licensed shift duty. The RHR psychologists will also meet with each operator individually to review the results of his assessment interview and discuss areas for #urther development / improvement after he has successfully completed the training program. Those operators who are determined to be eligible for training as a result of this assessment process must then volunteer for the training program after considering the conditions and commitment involved. The conditions are that:
- 1) they are receiving a serious written reprimand for past performance in their service record;
- 2) th1v will have to complete the Training program successfully;
- 3) they will be required to undergo follow up independent psychological assessment; and PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-7
Commitm:nt to Exc311tnc3 Action Plcn
- 4) they will be required to personally commit to a new code of professional 7
( conduct before being allowed to resume licensed duties on shift. A 27-day attitudinal and performance improvement trainino program, entitled People - The Foundation of Excellence, has been developed by a team of consultants and PE instructors. The course objectives are to:
- 1) help licensed operators identify the underlying attitudes which promoted unacceptable behavior in the control room and change those attitudes;
- 2) improve control room working relationships through the development of interpersonal and group dynamics skills; and
- 3) enhance professionalism on the job.
Skills and abilities associa ted with ef fective communications, positive atti-tude, team building, and professionalism are practiced and applied to typical problem solving and decision making situations encountered in daily work. The Manager, PBAPS and other members of the PBAPS management staff participate in i selected training activities to discuss performance expectations for operators with respect to nuclear operations excellence. The course also includes a section on effecte e interaction with HRC and INPO representatives. Self, peer, management and instructor evaluation and feedback occur throughout the course. A course syllabus is included in Appendix C. f} b All eligible Senior Licensed and Licensed Operators, as well as Shif t Technical Advisors, are attending this course in two class sessions. The first class will end on August 14th, and the second class will be completed on September 25th. Criteria for successful completion of this c c,u rs e include observed positive behavioral change (based on weekly recorded observations by the Operations Engineer and the course instructors); pre- and post-course assessment of self-awareness, interpersonal and group membership competencies by RHR; active performance in class simulations which develop decision making, problem solv-ing, conflict resolution and team-building skills for application to typical work situations; and understanding of management performance expectations with respect to shift operations, company policies and work rules, the need for procedural compliance, and the roles of nuclear regulators and industry audi- l tors. A summary report will be submitted to the Manager, PBAPS for further assessment of trainees and course effectiveness. This report will be used, along with additional psychological evaluations, to determine whether or not each operator is effectively prepared to uphold the standards of excellence required to resume licensed shift duties in nuclear power operations. 3.4.3 Recruitment and Trainina of New Licensed coerators Recruitment and training of new licensed operators have been accelerated under
- higher standards of entry qualifications and testing. In order to provide a
( sourco of personnel for future classes, 14 new helpers have been hired by PE, all of whom haua nuclear Navy experience. The current class in licensed oper-l PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TP DATE 3-8 l 1 l
1 l Commitm:nt to Exc211cnc3 Action Plan ator training (four Reactor Operators and three Senior Reactor Operators) will () take their examinations in October, 1987. On August 3, 1987 a new training class was started for sixteen presently non-licensed operator personnel. All members of this licensed operator training class have successfully passed an aptitude examination. PE is also coordinating with Peach Bottom co owners and General Electric to supplement PE's current resource of licensed operators until the candidates presently in training have been qualified. A continuing series of new licensed operator training classes will be conducted for several years unt21 all new licensed positions described in Section 3.4.3 are filled, and there is a substantial pool of reserve licensed personnel ready to fill temporsry and permanent vacancies so that control room overtime can be kept to a reasonable minimum. Reserve licensed personnel will serve in plant operator positions outside the control room, and will regularly be rotated to control room duty to maintain their skills and licenses. 3.4.4 Channes in operations Organization PE has analyzed the organization structure of the PBAPS Operations function and identified several areas for improvement. As a result, significant changes are planned for the PBAPS operations organization which, when fully implemented willi provida adoitional mana gerial supervision of shift operations; ensure more focused supervision of both control room and floor activities; add addi-tional reactor operator coverage on each shift to provide flexibility for rotation and relief of operators; relieve shift operators of some of their
) administrative burden while ensuring effective coordination of all administra-("'/
A- tive work associated with shif t control room activities; and provide new career path opportunities for licensed operator personnel. An organizational chart depicting these changes in the Operations organization is included in Figure 3-1 on the following page. NRC Technical Specification approval will be requested as appropriate. (") (/ PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-9
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CtmmitmInt to Excs11snes Acticn Plan Additional management attention will be provided for operations with the Q (/ establishment of an Assistant Superintendent-Operations position, reporting directly to the Superintendent-Operations. This will assure that one of these managers is always available to the shif t operations organization, and will provide an additional management development opportunity for professional operations personnel. The newly created position of Shift Manaaer, discussed in Section 3.4.1, will report directly to the Office of the Superintendent-Operations, and is in charge of shift operations. He will have authority to coordinate the work activities of all health physics, chemistry, maintenance, instrumentation and control, security, construction, and vendor personnel as these relate to operating the plant. In order to provide additional supervisory direction for control room activ-ities, on each shift there will be two SRO licensed Shif t Supervisors, with one of these serving as the lead, and the other as the assistan+. The lead Shift Supervisor will normally remain in the Control Room area, and the assistant Shift Supervisor will be available to go wherever needed to observe, s'upervise and direct activities throughout the rest of the plant. The assistant Shift Supervisor will also provide backup relief to the lead Shift Supervisor as needed. To strengthen the shif t organization and provide flexibility for rotation and relief of operators, a iourth licensed Reactor Operator will be added to the current complement of ttree reactor operators per shift. Each of the four licensed Reactor Operators will be equally qualified and able to shif t from O position to position. One of the strong needs identified by PE was for focused supervision of non-licensed operator floor activities. A new position of Floor Foreman, reporting to the Shift Supervisor, has been established on each shif t to address this need. This position will be responsible for supervising the non-licensed operators and overseeing such areas as watch standing performance, attentive-ness to duty, training and overtime. The Shift Technical Advisers, who previously received their assignments from the Operations Engineer, will be reporting directly to the Shift Manager in the new shift organization. A new daytime organization has been developed to relieve operators of some of their administrative burden and ensure effective coordination of all work associated with control room activities. This organization will be under the ! direction of a new position, Enoineer-Operations Support, reporting directly to the Superintendent of Operations. The Engineer-Operations Support will have f a well-qualified technical staff and will also have the pfp ations Support Superintendent, another new position, reporting to him. The Operations Support Superintendent will be required to have a senior oper-ating license background and experience at a shif t superintendent / shift super-visor level with an exemplary record of performance. His role will require a high degree of involvement in work planning schedules for the shift, since he O will be responsible for training and administrative matters for the Shift Supervisors. PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-11
Commitm:nt to ExcGilenco Acticn Plan l Reporting to the Operations Support Superintendent will be a third new position of Blockino Coordinator. The. Blocking Coordinator and his staf f will develop (b blocking permits for the performance of work. The Blocking Coordinator position will require current SRO qualification, and will be filled by Shif t Supervisors for a period of two to three months (to provide rotational opportunities from i shift work), after which they will return to normal shift duty. ! Also raporting to the Operations Support Superintendent will be an Electrical Supervisor. This position will be responsible for coordinating maintenance and surveillance testing of electrical equipment to support operations. Qual-ifications for this position will include senior operating license background and experience. The new daytime organizational structures and positions will provide for temporary and permanent promotions or transfers out of control room shift operations in the licensed operator career path, and will create opportunities for licensed operators to work closely with station management in their assignments. Dther career path opportunities will be apened to licensed operators through increased use of their skills in positions in training, quality assurance, outage planning, and other operating support functions. These changes to the Operations organization will not be fully implemented prior to restart, As noted in Section 3.4.2, significant efforts are underway to increase the pool of licensed operator personnel. The organizational changes r will be phased in as additional licensed operator resources become available, t s 3.4.5 Procedural Compliance To address past problems with procedural compliance at PBAPS, PE has established a corrective action program which includes the following:
- 1) A major procedure review and upgrade effort is being conducted. Assessments of the need to develop and/or upgrade procedures in different categories will be completed prior to restart. Relevant Operating procedures are being carefully reviewed for currency, accuracy and appropriateness. Those which are considered to need upgrading and to be important to safe restart of the plant will be upgraded before restart. Rewriting of selected Administrative and General Plant procedures is already underway.
- 2) New management processes are being developed to ensure timely and thorough management control over the processes associated with development and revision of plant procedures from identification of the need to make a procedure change, through Plant Operations Review Committee (PORC) approval, and availability in the controlled copy books.
- 3) A new administrative support function is being established to ensure timely and efficient distribution of procedure revisions.
- 4) Attitudes toward procedural compliance are being examined and discussed as a part of the operator " People - The Foundation for Excellence" training program.
PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-12
C!mmitmint to Exc311:nca Action Pl n
- 5) Additional emphasis is being placed on procedural compliance in operator, technical and craf ts training programs.
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- 6) Procedural compliance is being added as a job performance standard in PBAPS employee performance evaluation forms.
- 7) Independent monitoring of procedural compliance will be performed under the newly established QA Shirt Operations Monitoring Program discussed in the next section.
3.4.6 Quality Assurance (OA) Proaram Improvement of PE's Quality Assurance (QA) Program is an essential foundation for the CTE Action Plan. The role of ,QA is being integrated into all aspects of plant operations and support. The scope of the QA Program will be expanded to encompass the full spectrum of QA functions from compliance monitoring and commitment tracking to root cause determination and quality engineering corrective action. PE realizes that, in tha past, there was no responsibility formally assigned for independent monitoring of control room activities by technically qualified PE personnel . This situation has been corrected by the establishment of a PBAPS Shift Operations Monitoring Program. A team of six trained Quality Control personnel, reporting directly to the QC Supervisor, will serve as PBAPS Shift Operations Inspectors, providing independent overview of a wide spectrum of control room and plant activities on each shift. They will report directly to ,y the PBAPS Quality Control Supervisor, who will, in turn, report up the normal management chain to ensure that the Vice President-Nuclear Operations is kept informed on a timely basis about Shift Operations Monitoring activities and results. The PBAPS Shift Operations Inspector will typically begin each shift by attending the shift turnover meeting to become informed of the current status of the plant and proposed activities for that shift. The Shift Operations Inspector will also spend a portion of each shif t on a pre established tour of the plant observing certain activities within the scope of the Shif t Monitoring Program. The remainder of the shift will be spent performing monitoring activities at the discretion of the Inspector based on plant conditions. A minimum of one hour of each shift will be spent in the control room where operations will be monitored for professionalism, procedural compliance, strict adherence to all regulations, and maintenance of the standards of nuclear operations excellence established under the CTE Action Plan. The scope of activities to be monitored by the Shift Operations Inspectors includes such areas as: plant administration, plant operations, emergency preparedness, fire protection, chemistry, radiological control, radwaste oper-ations, technical specification surveillance testing, training, industrial safety, housekeeping, storage / material control, lubrication program and general monitoring. Each member of the PBAPS Shift Operations Monitoring Team will have experience in one or more of the following areas PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-13
Commitm:nt to Exc311Inc3 Acti n Plan
- nuclear Navy experience with reactor watch qualifications and BWR oper-3 ations experience with a minimum qualification of Plant Operator (d (Nuclear)
- current or past qualification as a licensed BWR Operator
- QA/QC experience with Reactor Operator equivalent training
- Associate degree with QA/QC experience at an operating BWR and BWR system training In addition to the Shif t Operations Monitoring Program, the role of Nuclear Operations QA will be expanded to include audits of technical and performance based activities. To improve the quality of audits, audit team technical specialists, who are engineers with specific expertire in the area being audited, will receive documented orientations to enhance their auditing skills prior to conducting audits.
PE will also assess the need to expand the existing scope of some aspects of the QA Program to encompass selected balance of plant equipment, systems and operations, with emphasis on areas that most directly challenge safety systems and affect reliability. Organizational changes and work group interface issues which must be addressed to improve the QA function have been assessed and these changes will be imple- , mented as specific Action Plan Tasks. Once Limerick Unit 2 has come on line, PE will reassess combining all QA fu.ections into one organization reporting to V an appropriate senior-level management position. PE recognizes that assurance of quality extends far beyond improvements to the QA function per se, and includes a proactive commitment to quality operations on the part of each PBAPS manager and employee. This philosophy is captured in the Commitment to Excellence Action Plan with its many Tasks dedicated to improvement of management systems, management skills, organizational account-ability and productivity, plant programs, and work management systems. Furthermore, it will be DE's total assurance of quality effort which will provide for continued tracking of the CTE Action Plan commitments, assessment of the effectiveness of the Plan and eventual integration of the commitment to excellence project into the PE line management infrastructure when the Action Plan is completed. 3.4.7 Personnel Policies PE has reviewed its personnel policies in the areas of hiring, supervisory promotion, discipline and grievances, and has modified the application of these policies as required to support excellence of nuclear operations. Effective immediately, all new employees hired or transferred into entry level positions leading to the licensed operator career path are required to have two years of post high school technical training, or equivalent nuclear Navy training, or l an equivalent combination of education and work experience. These new employees are paid at an advanced starting salary rate commensurate with these require-ments. PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-14
Commitment to Excellence Action Plan The requirements for higher levels of excellence in performance, responsibility and accountability for nuclear workers will extend into the process and proce-dures for promotion to first level and higher levels of supervision. In addi-tion to technical knowledge and proficiency, qualifications for promotion to any level of supervision will include demonstrated human relations skills in present job performance, an understanding of the requirements and skills involved in supervising, and, where appropriate, qualification by test to demonstrate required technical knowledge. For promotion to first level super-vision, the senior employee who has mot the qualifications for the new position will be given an opportunity to demonstrate his or her qualifications for promotion by temporary or upgrade assignments. Such temporary assignments will be increasingly important for maintaining skills and preparation for promotion. Present PE plant rules and practices governing overtime, call-out and upgrade seniority will be reviewed and modified where necessary to permit these devel-opmental assignments. Permanent promotion to any level of supervision will be made only after a candidate has demonstrated his or her qualification for the new position and has performed satisfactorily in periods of temporary or upgrade assignments. Application of the Company's Disciplinary Guidelines has been modified with respect to nuclear operations. Disciplinary infractions which might be considered minor in non-nuclear operations may, depending on the circumstances, be considered by station management to be serious or major infractions. In such cases, the first two steps in the Company's disciplinary process (oral warning and written warning) may be omitted, and a written reprimand or suspension may be imposed immediately by plant site management. Administrative reviews or O appeals will be considered during or af ter the imposition of discipline. The Employee grievance process has also been modified for nuclear operations empic,ees. Employee problems or complaints will be brought to the attention of their immediate supervision. If the employee is not satisfied with the response, the problem or complaint will be submitted to successively higher levels of supervision, up to the station manager who will give a prompt response. Where possible, this entire process will be completed within 20 days. If the response is unsatisfactory, or the process is not completed within 20 days, a written statement of the grievance may be filed with the Vice President of the employing department. If the response to the grievance is not satis-factory, the grievance may be submitted in accordance with established proce-dures, to the Vice President-Personnel and Industrial Relations. 3.4.8 Communications and Manacement Involvement PE has determined that the attitudinal problem at Peach Bottom extended beyond the operator group, and that there were two key contributing factors which needed to be addressed (1) lack of effective two way communications between nuclear operations management and employees, so that employees felt that their suggestions and concerns were not being heard; and (2) lack of leadership to develop employee understanding of and willingness to comply with the highest nuclear standards. PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-15
Commitm::nt to Exc3113nce Action Plan The new Manager, PBAPS has already taken significant steps to improve communi-r cations and leadership at Peach Bottom. He meets weekly with station staff, senior engineers of corporate support organizations and key vendor personnel to ensure effective communications between all work groups and establish a team approach to all site work activities. He has met individually with all licensed operator personnel, held meetings with each shift, and established routine weekly meetings with the day shift. In addition to informal discussions with other plant personnel as he " walks the plant", he has also had at least one formal group meeting with every PE work group on site. A "Tell it to the Manager" program has been established which solicits questions, concerns, and comments from all Peach Bottom personnel with the CoNmitment that the Manager, PBAPS will ,ersonally review all items and share his written responses with site personnel. Another innovative program involves the formation of a committee of volunteer representatives from all site organizations which will meet peri-odicelly with the Manager, PBAPS to have an ongoing dialogue about plant oper-ations and employee concerns. i l In all of his communications and actions with site employees, the Manager, PBAPS has consistently expressed the same two messages: (1) he is committed to listening and being responsive to all constructive employee communications; and l (2) he expects every employee on site to comply with the standards of excellence demanded by contemporary nuclear requirements. A new code of professional conduct for nuclear employees has been developed. (See Appendix D). This " Commitment to Excellence" statement is being used to communicate Peach Bottom management's performance expectations to all site personnel. All PE employees who are regularly assigned to work at PBAPS and O
' who are in progression which lead to the nuclear premium or who are in those job classifications which receive a higher rate of base pay due to their assignment at a nuclear facility will be required to sign this "Committment to Excellence" statement to indicate their understanding of, and commi :. ment to, professional nuclear work standards. Station management's authority has been strengthened in the areas of hiring, discipline, grievance resolution and selection for promotion to ensure that these performance standards will be maintained.
Professional human resource support to assist line management with personnel management ai,d human relations on site is Leing provided by the establishment of a Nuclear Personnel Specialist position. This position will work with PBAPS managers, supervisors and employees to ensure consistent and equitable imple-mentation of personnel policies; assist supervisors with esolution of employee performance problems; and improve employee relations. Major changes are being made to ensure timely and effective communications between all levels of corporate and station nuclear operations management, and among all PE organizations involved in supporting nuclear operations. The management processes used to develop this CTE Action Plan and the processes I which will be used to monitor its implementation are indicative of some of these changes. Development of the Action Plan has been under the direct supervision of the l President with close overview and support from the Chief Executive Officer. l The Manager, PBAPS has a direct organization "line" to the President on all matters relating to restart and operations excellence. A CTE Project Manager 1 PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-16 l
Crmmitm:nt to Excallznca Action PIEn position, reporting directly to the President, has been established and staffed
/~ by a PE line manager, with strong project management and nuclear support back-k ground, to ensure full-time dedicated management attention to coordinating Action Plan development.
In addition to the MAC report recommendations, specific Tasks for inclusion in the Action Plan were recommended by individuals from PBAPS, each matrix organ-ization involved in PBAPS operations, and other corporate support organiza-tions. Drafts of Action Plan Tasks were distributed to over 100 PE managers for review and recommendations. A Management Review Committee, comprised of the Vice President-Nuclear Operations, the Vice President-Engineering and Research, the Department Managers of Nuclear Generation, Nuclear Support and Maintenance, the Managers of PBAPS and LGS, the Superintendent - Nuclear Oper-ations Quality Assurance, and the CTE Project Manager, meet periodically to review and approve the Action Plan Task List, discuss interdepartmental responsibilities, and assign management accountability for each task. As the planning, resource loading and scheduling for each Task is completed, the designated responsible individual for ensuring that the Task is accom-plished, reviews any Task which involves collaborative support from other departments with the key individuals involved to obtain their agreement. Because of the time spent and the processes used in develors au the Action Plan, the Company believes that there has been a " buy-in" by involved personnel, and that the end product of this planning effort is a comprehensive, well conceived ' and realistic program. p PE intends to manage this Action Plan effectively. Close out acceptance d criteria which define specific, observable behaviors or products related directly to task accomplishment are being carefully developed for each Action Plan Task. These criteria are being reviewed and approved by management to ensure that the Task will not be closed out until the purpose for which it was established has been accomplished. A Proj ect Review Group, headed by the Senior Vice President- Engineering and Production, with Vice President- and Department Manager- level representatives from organizations involved in supporting nuclear operations, will meet at least monthly to monitor Action Plan progress according to schedule and resolve any interdepartmental concerns. PE is committed to maintaining these improvements in management involvement, , communications and support af ter the CTE Action Plan is completed. Many of the Action Plan Tasks in Section 5.1 of the Tasks List focus specifically on increasing corporate and plant management involvement in ongoing operations at the site; clarifying organizational and managerial accountabilities for plant operations and support; improving interdepartmental work interfaces; and ensuring effective two-way communication processes between Nuclear Operations Management and employees. Other Tasks address the need for improved trending and reporting of plant performance indicators and the establishment of routine meetings to review these indicators with Nuclear Operations management and the Senior Vice President-Engineering and Production to ensure continued timely management attention and support for PBAPS operations, ) These improved plant performance trending reports will also be reviewed care-fully by the President, Chief Executive Officer and Special Committee of the PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-17
\
I l l Cammitm nt to Exc311 Enc 3 Actitn Plin l Board to monitor and evaluate the success of CTE Action Plan implementation in _t g) correcting the root causes of past performance problems. I %, 3.5 PREPARATION FOR RETURN TO POWER OPERATIONS PE recognizes that there must be thorough and careful planning involved in preparing the plant end operator personnel for the return to power operations after this extended outage period. A program is being developed for this purpose, consisting of two phases. The first phase addresses preparation and training prior to restart and the second phase focuses on the actual power ascensior restart program. The first phase commences once the Shift Managers have completed their three-week training program. Each Shif t Manager and his shif t operators will receive training together to ensure their readiness to function as an effective team during restart and power operations. The training will include review of the new shif t organization structure and individual responsibilities and authori-ties; review of procedures; opportunities to practice functioning together as a team by conducting various transient scenarios on the simulator; discussion of methods for mor.itoring their shif t work behaviors, and sustaining a high level of team spirit; and specific training in other areas as deemed appropriate and necessary. (7 Following this team training, each shift team will begin functioning in normal shift rotation to complete prep .ation of the plant for startup and power ascension. These preparations will includes system lineups, lineup verifica-tions and required surveillance tests; the refueling outage startup checklist will be performed and verified to assure that the physical plant is fully ready for operation. For the second phase, the Power Ascension Program will consist of procedures { and integrated plant operation verifications; follow-on shif t team development; I and operational exercises. These will include performance of plant operational surveillance tests and certain reactor start-up exercises prior to . Power ascension. During power ascension, operations will be conducted which will ) provide experience, either thr ough direct participation or observation, for key ] operations personnel. PE proposes to restart power operations with Unit 2 in operation only. On or about October 15, 1987, a major reactor pipe replacement outage will begin on Unit 3. The details and schedule of the Power Ascension Program will be reviewed with , the NRC prior to start up. l PROBLEM IDENTIFICATION, CONCLUSIONS AND CORRECTIVE ACTIONS TAKEN TO DATE 3-18
ActionPlanTaskDevelopment, O Implementation, Monitoring g and Close-out Processes ! E la O O
E n CcmmitmJnt to Excellance Action PIEn 4.0 ACTION PLAN' TASK DEVELOPMENT, IMPLEMENTATION, MONITORINO AND CLOSE-0UT PROCESSES
4.1 INTRODUCTION
The Peach Bottom Commitment to Excellence (CTE) Action Plan was developed with assi=tance from departments involved in operating and supporting PBAPS, as well as contributions from Senior Management, Consultants,.a Special Committee of the Board of Directors and-an Industry Review Committee. It is intended to be a comprehensive and integrated plan which identifies the actions necessary to resolve the concerns cited in the NRC Shutdown Order and to establish nuclear operations excellence at Peach Bottom. While all corporate and station managers have general interest in and respon-sibility for the Action Plan's accomplishment, primary responsibilities have been carefully defined in order to provide focus, effective action, and dedi-cated management time to ensure that: 1) safe and reliable operations continue at both PBAPS and Limerick Generating Station (LGS) during implementation of
-the Action Plan; 2) planned outages at both stations are conducted efficiently and economically; and 3) construction of LOS Unit 2 continues on time and under the cost cap.
General administration, technical direction, staff support, operations, and outage management for PBAPS and LGS Unit 1 continue to be under the direction of the Vice President-Nuclear Operations. The Manager, PBAPS has full authority, responsibility and control for all work l at PBAPS. Other PE departments and all site vendor personnel provide services to the Manager in accordance with established company policy. 1 4.2 PROJECT ORGANIZATION In addition to their normal duties, additional responsibilities have been assumed by the President, the Manager, PBAPS and the Ment.uer, Nuclear Generation to ensure the success of the CTE Action Plsn. , The Action Plan has been developed and will be implemented under the direct supervision and leadership of the President and Chief Operating Officer of PE, with the overview and support of the Chief Executive Officer. 1 The Manager, PBAPS is responsible for developing and executing the Action Plan at the station, and reports directly to the President on matters relating to the Plan. The full resources of PE will be made available as required. A new position, Assistant to the Manager, PBAPS has been established to schedule and coordinate the Action Plan under the direction of the Manager. Additional staff will be drawn from site or off-site organizations as required. O
-L)
ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT l PROCESSES 4-1 L
Commitment to Excellence Action Plan The Manager, Nuclear Generation Department has responsibility for coordinating and directing special training activities in support of the Action Plan; O establishing an expanded and accelerated program of training for currently licensed operators; and establishing and executing a program to recruit and hire additional candidates for license training. A CTE Project Manager position has been established to provide centralized corporate coordination and control for all CTE Action Plan activities. The position has been staffed by a PE line manager with strong project management and nuclear support background. He reports directly to the President in this position, and draws resources and assistance from PE departments as required. The Project Manager is directly assisted by MAC consultants. The primary responsibilities of the Project Manager and his team are to
- provide coordination with and support for the Manager, PBAPS with respect to Action Plan development and implementation e provide enordination with and support for the Manager, Nuclear Gener-ation Department with respect to his CTE Action Plan responsibilities e facilitate identification of all elements and components of the Action Plan 1
- manage the assembly of all components of the Action Plan from various PE and consultant sources into an integrated and comprehensive plan e establish a project and milestone schedule, including critical path l
priorities l l
- identify and summarize significant policy decisions that must be made l by the President to meet schedule dates l
l
- assure that the appropriate p]anning, implementation, monitoring and close-out processes have been established for ef fective management and execution of the CTE Action Plan j
- assure that appropriate individual responsibility has been assigned for implementation and monitoring of each program activity
- assure that PE departments and consultants meet key project dates e monitor progress on Action Plan implementation and report on project status to the President e assure that the line managers and executive management are aware of the resources required to execute the plan workload O
ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-2
1 ! Commitm2nt to Excallsncs Action Pltn 4.3 OVERVIEW OF ACTION PLAN TASK DEVELOPMENT AND IMPLEMENTATION PROCESSES O- , In Figure 4-1, the Action Plan Task development and implementation processes are shown in outline form with primary responsibilities for each process step identified in the right-hand column. Figure 4-2 illustrates these same proc-esses in a flow chart. Each process step is discussed in more detail in Sections l 4.4 through 4.14. I I 1 I 1 I O l 9 O ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-3
FIGURE 4-1 ACTION PLAN TASK DEVELOPMENT AND IMPLEMENTATION PROCESSES
. Responsibility (Primary responsibility listed O- Process Step first or in sequence)
- 1. Identification of Action Plan 1. Line Organizations Tasks
- l. '2. Task Planning 2.
- Manager, PBAPS/line management L
- Task Description and Purpose (site activities) l
- Sub-Tasks and Close-Dut Criteria
- Project Manager /line management
- Resource Requirements (off site activities)
- Initial Impact Analysis
- Recommended Scheduling Category
- Target Completion Dates
- 3. Impact Analysis of Proposed Tasks 3. Manager, PBAPS/ Project Manager
- Impact.of Tasks on Other Tasks and Ongoing Work Activities
- Cumulative Impact of All Tasks on Resource Requirements
- Preliminary Scheduling
- 4. Approval'of Tasks for Inclusion 4.
- Manager, PBAPS/ Project Manager in Action Plan
- Management Review Committee
- Executive Management O
\_/ 5. Final Integration / Scheduling of S. Project Manager Action Plan Tasks
- 6. Action Plan Review and/or Approval 6.
- Management Review Committee
- Executive Management
- Special Board Committee
- Industry Review Committee
- 7. Action Plan Imp 19 mentation 7. Assigned Individuals in Line Organizations
- 8. Action Plan Monitoring 8.
- Line Management
- Project Management
- Senior Vice President- I Project Review Group
- Executive Management
)
- Quality Assurance
- Nuclear Review Board
- PBAPS Owners Committee
- Special Board Committee
- Industry Review Committee
- 9. Close-Out/ Verification of 9.
- Line Management / Nuclear Operations Action Plan Tasks Quality Assurance
() 10. Interface with the NRC on Closed-Out Action Plan Tasks as Required
- 10. Nuclear Operations Licensing Organization I
ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT j PROCESSES 4-4 ' I __-- . _ _ _ _ _ _ _ a
Cammitm:;nt to Excellenes Action Plen Fiaure 4-2 COMMITMENT TO EXCELLENCE PROGRAM ACTION PLAN TASK DEVELOPMENT AND IMPLEMENTATION FLOH CHART PROCESS STEP SITE TASKS OFF SITE TASKS
- 1. TASK IDENT1FICATION SITE ORGANIZATIONS OFF-SITE ORGANIZATIONS 2, TASK MNING
\I \h mANAosn, ,
pRosacT -"+ IN R6 C0el e TASK DESCRIPTION & PURPOSE peApe - uANAosR g senciAL soAno com o SUETASKS INCLUDING CLOSE OUT CRITERIA e RESOURCE REQUIREMENTS e INITIAL IMPACT ANALYSIS e RECOMMENDEDSCHEDULING ,, CATEGORY e TARGET COMPLETION DATES UNE MANAGEMENT UNE MANAGEMENT SITE ORGANIZATIONS OFF SITE ORGANIZATIONS
- 3. IMPACT ANALYSIS e tMPACT OF TASKS ON OTHER TASKS """% 8"Od8CT anosaC1 AND ONGOING WORK ACTIVITIES 9 N ,t : ;
yE'.",, *'C""'8 . e CUMULATIVE IMPACT OF ALL TASKS ON a:Tu 0FP erTs RESOURCE REQUIREMENTS / e PRELIMINARY SCHEDULING / y 4. APPROVAL OF TASKS FOR INCLUSION ",",a NT gg yg
,d IN CTE ACTION PLAN ComurrTag I
h S. FINAL INTEGRATION & SCHEDULING seosaCY T rnoJE OF ACTION PLAN TASKS g, , SCMEcuLE .)
+
WOMT. REVIEW COMM. EXECWVe momT.
- 6. ACTION PLAN REVIEW AND/OR APPROVAL sarem moAno Comm.
,,.*,e#, INDUWYRV REVIEW COMM.
NRC ,'*=gy
- 7. ACTION PLAN UNE MANAGEMENT UNE MANAGEMENT gy pM M E NTATION SITE ORGANIZATIONS OFF SITE ORGANIZATIONS LfNE MoWT.
QUAUTV ASSURANCE SPECIAL BOARD COMM.
- 8. ACTION PLAN MONITORING PRoasci uoasT. % + PaAPs owNrRs Couu-
$R V P REVIEWoROUP INDUSTRY REVIEW COMM EXECl/TIVE MoMT- NUCLE AR REVIEW BOARD i
- 9. E@SEOUT - VERIFlQATION OF ACTION PLAN TASKS NUCLEAR e CLOSE OUT CRITERIADOCUMENTED U Li l
AND VERIFIED ASSURANCE A l 10 NRC INTERF ACE ON NUCLEAR OPf RAT loNS UCE NSING CLOSECFOUT TfSW ' 1 l ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-00T l PROCESSES 4 -5 _ _ _ _ _ _ _ _ _ _ . - - - - - - - - . . _ - . - - _J
Ccmmitmsnt to Excellsnes Acticn Plan-
- 4.4 TASK IDENTIFICATION The primary responsibility for identification of the Tasks included in the CTE Action Plan resides with the relevant line organizations (i.e.,. organizations involved in' operating and. supporting PBAPS). Assistance with identification of Tasks has been provided by the.CTE Project Team and the Management Review Committee. Executive Management,- the Internal Management Team, the Special Committee of the Board of Directors and the Industry Review Committee also provided significant input and review.
In addition to the Tasks identified by the line organizations, the total iden-tification effort has ensured review and inclusion, as appropriate, of program elements from sources such asi NRC Shutdown Order Results of Internal Investigation MAC's Problem Root Cause Assessment of Peach Bottom Shutdown NRC Commitments / Actions resulting from: Inspection Findings Inspection & Enforcement (ISE) Bulletins Generic Letters PBAPS Licensee Event Reports (LERs) 1 - Regulatory Guidos NUREGs Systematic Assessment of Licensee Performance (SALP) Reports I&E Information Notices PBAPS Enhancement Program (PBEP) INPO Evaluations and Recommendations Significant Operating Experience Reviews (SOERs) Plant Evaluations " Corporate Evaluations PBAPS Ir.provement Program (PBIP) American Nuclear Insurers ( ANI) Inspections Quality Assurance / Quality Control Findings and Recommendations Independent Safety Engineering Event Reports Outstanding Modification Requests ! Planned Modifications Procedures L ) Plant Programs and Work Management Systems ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-6
CcmmitmInt to Excsilence Action Plcn 4.5 TASK PLANNINO
*O V
Once potential Action Plan Tasks are identified, specific input on each Task is obtained from the involved line organization (s), including: Task description; the sub-Tasks involved and close-out acceptance criteria to be used; resources required to plan and implement the Task; initial impact analysis of the Task on ongoing work activities; recommended scheduling category; and target completion dates. Task Planning Worksheets (Figure 4-4, following Section 4.14) are completed by individuals responsible for each task and reviewed by the Manager, PBAPS or his designee (for site Task activities), or the CTE Project Manager or his staff (for off site Task activities), to ensure that all required information has been provided. 4.5.1 Task Description Each Task is briefly described in terms of the action to be accomplished and is assigned a four-digit number in the Action Plan. Progress on the implemen-tation and completion of each Action Plan Task will be tracked using this number. 4.5.2 Sub-Tasks and Close-Out Acceptance Criteria The individual responsible for implementing the Task develops sub-Tasks, which l outline how the Task will be accomplished, and close out acceptance criteria which will later be used to verify that the Task has been accomplished effec-tively. Sub-Tasks involving other organizations are reviewed with appropriate individuals in those organizations. The close-out criteria developed by the responsible individual are reviewed by the QA organization to ensure audita-bility. l 4.5.3 Resource Requirements An estimate is made of the numbers and types of resources (e.g., managers, supervisors, engineers, manual crafts labor, clerical personnel, consultants) required to complete the Task, based on the sub-Tasks delineated to accomplish the Task. If the responsible organization does not have sufficient resources assigned to accomplish the Task, this concern is discussed and resolved with line management or brought to the attention of the CTE Project Manager. 4.5.4 Initial Impact Analysis Each individual responsible for Task planning is also asked to make an estimate of the time that will be required to complete each sub-Task and do an initial impact analysis with respect to the effect that implementation of the Task will have on his or her own work group's activities and on other Action Plan Tasks for which that work group is responsible. ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-7
Commitment to Excellence Action Plan 4.5.5 Recommended Schedulina Catenorv The responsible individual also recommends an initial scheduling category for the Task according to the following scheduling categories: Category 1- activities which must be completed prior to restart. Category 2- activities which must start prior to restart (with planning and resources defined for completion of activities) but may not be completed until after restart. lll Category 3- activities which require long-term implementation, may or may not be started prior to restart, and will not be completed until af ter restart. The criteria for each of these categories were established as follows: Catecorv 1 actions which:
- a. are essential to safe restart and ongoing operation of the plant
- b. assess the adequacy of procedures and upgrade those required for restart
- c. assure compliance with the operating license and plant technical spec-ifications
- d. increase involvement of Quality Assurance and Quality Control functions O in plant operations e, clarify management expectations
- f. address operator attitudinal concerns
- g. increase management involvement in plant activities
- h. increase the number of candidates for licensed operator training
- i. are essential to establish an effective working relationship with external regulatory agencies Cateoorv 2 actions which
- a. reduce reactor trips
- b. reduce challenges to safety systems
- c. continue procedural upgrade program for selected procedures
- d. assure personnel policies and practices are consistent with standards for nuclear operations and encourage the most effective use of human resources O
ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-8
CcmmitmInt to Excellancs Action Plen
- e. assess the need for and initiate organizational and staffing changes in the corporate and site organizations involved with day to day Peach Bottom operations
- f. initiate programs to improve management and supervisory skills
- g. broaden attitudinal change efforts Cateoorv 3 - actions which
- a. continue to enhance plant performance
- b. involve major programmatic enhancements such as management information systems
- c. complete implementation of the procedure upgrade program and the system for ongoing maintenance of procedures
- d. provide for ongoing improvements in organization and management prac-tices
- e. maintain and enhance Category 1 and Category 2 activities Decisions about scheduling categories for Tasks are made by the Manager, PBAPS (for all site activities) and by the CTE Project Manager (for all off-site activities). These decisions are then reviewed and approved by the Management
, Review Committee. Figure 4-3, illustrates the scheduling categories and their overlap. 4.5.6 Taraet Completion Date Finally, the responsible individual is asked to include a target completion uate for the Task, with the understanding that the target date might change based on the inclusion of all Tasks into the schedule. The processes described in sections 4.5.1 through 4.5.6 have been completed on Category 1 Tasks in the CTE Action Plan Tasks List (see section 5.0 of this report) and are currently being completed on all Category 2 and Category 3 Tasks. Since the CTE Plan is meant to be an ongoing, dynamic program to achieve and maintain excellence at PBAPS, additional Tasks will be identified and developed over time, and the same planning processes will be used for these Tasks as well. O ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-9
/,N se m te lp itc t a tns eys m dn d o o e m n c au T w d e s nn e cio m ioit y c nt a n r E n a a r tao od ge a hm g z c e c E h nr o ins a n t R n e fo r p ae gc H e ci n e r i Cah T e ita nt d ot c d n Y c a in arp ne R n a me r g ad O mm ae p s en na m r r g u tnnt G fo gad e ee Od E r e o r ne r u mm yr en T p pate ee A d v g oi a r ml e oa gt C t jo , p ten n a agmo c o r r pna a ia l P M (e c P I m m Cm d t e ia d s d e e it n v m u o e i r t in s p d s t e e y n g m n S o n i e ty c a ls d s h l i a O e c k o fa m d g S w W S a e y t T r g is in r s to o v f o t r Y r e fa is fo R s p r ts v O e e s r e fe g d e d p e G n a ic n u g E le r a n T g tc S l a p a la / a A h u r p n t n h C C o e c J d e ru t e n ita m e la ,N nd ae d n iz n g d in e o a s ipd uc c o s r a g n i t u r e r a t r e T r P P O M / t T R A TVi S E R I I_ l il gdl I d e a ll d l ! l l i I { 1 l l I l d r g _ - er p e d u u ru g e ll- s s d h s d s e n s E a n a s in li N s a e s s ia b n y c n d e r ta O c n o e d r t t s Y io a a it i n r e t a u h c f i d a a o R r q p n r a lp ta s O e e fude lc s r ip G p o d d e m o s n r in e p h s E a r c Cs a n e t o n u n T g n r fo s s s n Oe io c n e d io A d r t o me e t C io g d e a e io t n nc ai t a c c s n le a n a e la lvd e o wie c n fc As n p n oe v s ic l r a d a x i fOo na n t l v c e d n i r e lp ep oar it u ie r a r t t t r fo e t m S t n e n t i nc s t x r sd o p e t a en e a e r e r c ta e o me r mis et r ts ui tae e e dequ e ic m e to ee v v n t s g git d s n i r n a a a ai i a t fe c o re e c h c lolp v n a e p r niv at dnre ac fe c a r s e c f M O Ma Ci n i S Pa L T inn i E
* * *
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CommitmInt.to Excellsnce Action Plan h i 4.6 IMPACT ANALYSIS'0F PROPOSED TASKS 4 Once Task Planning Worksheets have been prepared and submitted to the CTE : Project management staff, the Manager, PBAPS and the Project Manager coordinate closely with each other, and with relevant line managers in both site and off-site organizations, to consider the cumulative impact of the Tasks on resource requirements, other Tasks, ongoing-work activities, and preliminary scheduling. a r 4.7 ' APPROVAL OF TASKS FOR INCLUSION IN ACTJON PLAN [ Upon completion of the cumulative impact analysis, the Manage 8, PBAPS, and the CTE Project Manager then present their ' final recommendations, with respect to inclusion of proposed Tasks in the CTE Plan, to the Management Review Committee. Membership on the Management Review Committee consists of Vice President-Nuclear Operations Vice President-Engineering and Research Manager, Maintenance Department Manager, Nuclear Generation Manager, Nuclear Support Manager, Peach Bottom Atomic Power Station Manager, Limerick Generating Station O CTE Project Manager ! Superintendent, Nuclear Operations Quality Assurance The Committee approves Tasks for inclusion in the Action Plan and assigns responsibility for assuring the successful implementation of each Task to appropriate individuals. Decisions of the Management Review Committee are reviewed at the Executive Management level. 1 4.8 FINAL INTEGRATION AND SCHEDULINO OF ACTION PLAN TASKS As Tasks are reviewed and approved by the Management Review Committee, the CTE scheduling group, under the direction of the Project Manager, develops an ; integrated schedule for all Action Plan Tasks. , 1 i 4.9 ACTION PLAN REVIEW AND APPROVAL To ensure the highest quality of program development, planning, scheduling, implementation and communication processes, the development of the Action Plan has been reviewed by the Management Review Committeo, the Special Committee of O ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4 ~ 'i
Committaant to Exc211gnca Acticn PIEn i,
%v , -I 1
a ro a A . N 4.10 IM &EMENTATION OF ACTION PLAN TASKS A responsible person has been designated for implementation of each Action Plan Task; This individual will be accountable for successful-completion of the Task and the quality of its implementation. The CTE Project Manager will have overall responsibility for monitoring implementation of. Action Plan Tasks in accordance with the Monitoring Processes described in Section 4.11. 4.11 ACTION PLAN MONITORING PROCESS AND MONITORING RESPONSIBILITIES o 4.11.1 Responsible Individuals and,Line Manaaement The individual who has been assigned responsibility for implementation of an Action Plan Task will' be responsible for monitoring Task progress and informing his/her immediate supervisor on a timely basis about any problems encountered or additional resources needed. If the concern cannot be resolved within two weeks by the appropriate line nmnagement, the . CTE Project Manager will be
~
notified. On a monthly basisx, the individual responsible for Task implementation will q complete an Action Plan Task Status Report Form (Figure 4-5, -following Section n 4.14) for each Task under his/her responsibility. The responsible individual will then submit the completed Form to the Project Scheduler / Coordinator for that Task'who will input relevant information into the scheduling data base and send the CTE Task Status Report Form to the Proj ect Manager. The responsible individual will' alto send a copy of the Action Plan Task Status Report Form to the QA organization. 4.11.2 Quality Assurance s . Meebers of the QA organization who have been assigned completion verification responsibilities for speci.fpc Action Plan Tasks will become familiar with the Task description, plannedraction steps and close out criteria for these Tasks at the onset of the CTE Action Plan. They will review the copies provided them of the monthly Action Plan Task Status Report Forms for these Tasks and will initiate meetings or informal check-ins with the relevant Task implementors, as required, to keep informed of Task activities and progress. M Until restart of Peach Bottom, these activities may occur on a more frequent () basis than monthly. ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0VT PROCESSES 4-12
C mmitm:nt to Exec 11cnca Acticn Plcn 4.11.3 CTE Project Manaaer The CTE Project Manager will respond, as required, to any special requests for assistance from line management. In addition, on a monthly basisM, the Project Manager wille e ensure that all responsible individuals submit Action Plan Task Status Report Forms (requesting assistance as required from appropriate line managers when responsible individuals do not submit Report Forms on time)
- ensure that a review and analysis of all submitted Report Forms is conducted to identify exceptions to anticipated progress and problem areas e report on general progress, exceptions and problem areas in meetings with the Project Review Group (see Section 4.11.4)
- report on general progress, exceptions and problem areas to the President 4.11.4 Prodect Review Group A Project Review Group has been charged with monitoring Action Plan Task implementation to assure that schedule milestones are met and to resolve any interdepartmental conflicts related to Task implementation. Membership in the Group includes:
( Senior Vice President-Engineering and Production (Chairman) Vice President-Nuclear Operations
-%-, Vice President-Engineering & Research Vice President-Electric Production Manager, Maintenance Department Manager, Nuclear Generation Department Manager, Nuclear Support Department Manager, Peach Bottom Atomic Power Station Chief Design Engineer Chief Mechanical Engineer Assistant Chief Electrical Engineer General Superintendent, Testing and Laboratories Division General Superintendent, Construction Division Superintendent, Nuclear Operations Quality Assurance CTE Project Manager Following monthlyx Project Review Group meetings, the appropriate manager (s) will take whatever actions are required to address and monitor problem areas reported by the Project Manager.
M Until restart of Peach Bottom, these activities may occur on a more frequent basis than monthly. M Until restart of Peach Bottom, these activities may occur on a more frequent O basis than monthly. ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0VT PROCESSES 4-13
I
- I e
commitment to Excellence Action Plan t 4.11.5 Special Committee of the B, gard of Directors s O The Special Committee of the Board of Directors, which has actively participated in review of CTE Action Plan development, will monitor and assess progress on 4 ' Action Plau ' implementa tion, reporting regularly on its findings to the full Board of Dirtetors. 4.11.6 Additional Monitorjng Additional monitoring and oversight will be performed by the Nuclear Review Board, the Industry Review Committee, the MAC advisory team, and the Peach Bottom-Salem Ownerr Representatives Committee. The scope of monitoring for each group will be detersined. s {t,_12 C(OSE-WT WlCfP7ANCE CRITERIA AND CLOSE-0UT PROCESS Icy order to close-out u Task in the CTE Action Plan, all close out acceptance criteria for the Task must be met. 4._) 2.1 Close-out Acceptance Critgria Guidelines In establishing close-out acceptance ~ u-steria for an Action Plan Task, the O folle ng guidelines are being used:
- 1. Close-out acceptance criteria must be specifih and measurable (i.e.,
verifiable in so/ne way) . Where appropriate, performance stLndards or l measures will also be included, a
- 2. The combined close out acceptance criteria nust cover major aspects y of the Tatk der.cription to ensure that the k oric Task purpose has been accomplished. '
3. The elese-out acceptance criteria must be amenabis to auditing by PE Quality Assurance groups and by the NRC. s
\
4.12.2 Close-Out Verification Process During the close-- ut process, the individual responsible for implementation of the Task will as>;u o that appropriate documentation. relevant to the close out criteria (e.g., copies of any written documents developed such as new direc-tives, position descriptions, policy changes, and/or written summaries of actions taken and results accomplished) are containod or referenced in the CTE Project File for that Task. Upon notification by an individual resporsihie for Task implementation that the Task is ready for close-out, 'Se QA staff member assigned verification respon-sibili.tv will, within a two week time periods
-ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MON 7TORING AND CLOSE-0UT PROCESSES 4-14 l _ _ _ _ _ . _ _ _ _ _ ___ ___ _ _
Commitment to Excellence Action Plan () e verify that Task close-out acceptance criteria have been met and that all relevant documentation is included or referenced in the Project File for that Task
- add his/her signature to the signatures of the individual responsible for implementing the Task and the individual's manager on the Task Planning Worksheet Form in the Project File 4.12.3 Necotiatina Channes in Task Action Steps or Close-out Acceptance Criteria As progress is made on Action Plan Task implementation, individuals responsible for implementation may find it necessary to revise, add or omit certain action steps (sub-Tasks) in the Action Plan Task.
When schedule or close out actentance criteria for the Task are not affected, the implementor may make any such changes with the approval of his/her manager. However, the implementor must notify the CTE Project Manager in writing, using a CTE Task Change Notification / Request Form (Figure 4-6, following Section 6.14) which has been developed for this purpose. The Project Manager will sign the form indicating acknowledgement that the change has been incorporated in the Action Plan project file, and return it to the implementor. A copy of the signed form will be sent by the Project Manager to the QA Supervisor, who will forward it to the QA Staff member assigned close-out verification responsibilities for () that Action Plan Task. When schedule or close out acceptance criteria will be affected, the following procedure will be used:
- 1. The implementor, with the approval of his/her manager, will submit to the Manager, PBAPS (for on site Tasks) or to the CTE Project Manager (for off site Tasks) a written summary of the changes proposed, justification on the changes, and the anticipated effect the changes will have on Task close-out acceptance criteria and/or Action Plan schedule. The Change Notification / Request Form discussed above will be used for this purpose.
- 2. The Manager, PBAPS and/or CTE Project Manager, together with appropriate line managers, will then discuss the changes in more detail with the implementor and his/her manager to decide whether the changes should be approved.
- 3. If the change is not approved, the Manager, PBAPS or Project Manager will l so notify the responsible implementor, using the space provided on the j CTE Task Change Notification / Request Form.
- 4. If the change is approved, the Project Manager will be responsible for
)j notifying the responsible implementor by signing in the space provided on the Form, and returning it to the implementor. The Project Manager !
will also attach a copy of the signed form to the Action Plan Task project file and send a second copy to QA. ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORINO AND CLOSE-0UT PROCESSES 4-15 l
Ccmmiternt to Exc211cnca Acticn Plan
- 5. Any changes that significantly impact the Task . or schedule will be reported by the Project Manager in his meetings with the Project Review O'
Group and the President.
- 6. Any Tasks on which the close out acceptance criteria or schedule nave
.been changed will be identified by the Project Manager in subsequent l publications of the Action Plan Tasks List as " revision 1", " revision 2", etc.
4.12.4 Interface With NRC Region 1 on Closed-Out CTE Action Plan Tasks Once QA has verified that the Action Plan Task close-out criteria have been met, the individual responsible for Task implementation will notify the C'.E Project Manager. In turn, the Project Manager will notify the Nuclea r Operations Licensing organization when each CTE Action Plan Task has been closed out. Close-out packages for each Action Plan Task will be available for NRC Region 1 inspection. 4.13 ACTION PLAN STATUS REPORTING PROCESSES AND RESPONSIBILITIES The President, the Senior Vice President, Engineering and Production, and the CTE Project Manager will provide reports on Action Plan status to internal and external groups on a regular basis. The processes and responsibilities for O status reporting are described below. 4.13.1 Internal Reportina Prior to the monthly Project Review Group meetings, members of the Project Review Group will review the status of Action Plan progress, identify any I problem areas which should be brought up at the Project Review meeting and discuss recommendations for resolutions of these concerns with appropriate staff members. The Senior Vice President-Engineering and Production, will convene the monthly Project Review Group meeting to discuss Action Plan status and resolve any significant schedule, resource and/r.r interdepartmental work concerns related to Action Plan progress. On a monthly basis, following the Project Review Group meeting, members of the Project Review Group will communicate activities of interest and expectations for any follow up actions to their direct reports with the expectation that these communications will be transmitted in turn down the chain of management so that personnel are kept informed of Action Plan status. On a monthly basis, the CTE Project Manager will provide a written report and meet with the President to review in detail progress on Action Plan implemen-tation. In turn, the President will submit a written report on a monthly basis to the Special Committee of the Board of Directors. The President and the Project Manager will be available to the Special Committee as required. ACTIDH PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-16
Crmmitm:nt to Excslienco Actirn Pltn On a regular basis, the Project Manager will coordinate with Corporate Commu-() nications to ensure that PE employees are kept informed on a timely basis about progress and significant events related to the CTE Program. 4.13.2 External Reportinn On a regular basis, beginning in September,1987, the Senior Vice President will be available to meet with the NRC Region 1 to provide a status eport on the progress of the Action Plan, including any changes or additions. On a monthly basis, beginning in September, 1987, the President will send a written report of Action Plan progress to the NRC Region 1. The Company will notify the NRC Region 1 forty-five (45) days in advance of the date by which it is expected that all Category 1 Tasks will be completed. Periodic written reports will also be sent by the President to other organiza-tions including: The Institute for Nuclear Power Operations, American Nuclear Insurers, and the Peach Bottom-Salem Owners Representatives Committee. 4.14 TRANSITION OF PROJECT MANAGEMENT INTO LINE ORGANIZATIONS (~ A strategy will be developed to ensure an orderly transition of CTE Action Plan b functions into line organizations in order to achieve and maintain a high level of plant and organizational performance. 1 l l l l l ( t ( ACTION PLAN TASK DEVELOPMEN). IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-17
CommitmInt to Excs11snca Action PIEn FIGURE 4-4 TASK PLANNING HORKSHEET (PAGE 1) TYPICAL TASK PLANNING WORK 8HEET SHEET 1 FOR PROJECT TEAM USE PEACH BOTTOM COMMITMENT ITEM NO. (CTE): TO EXCELLENCE PROGRAM COMPLETION CRITERIA (CC): 1 ACTION PLAN TASK NUMBER MEMBER: i 2 PREPARER: TELEPHONE: ORGANIZATION: 3 (NITIAL DATE: 12 COMMITMENT (INITIATING DOCUMENT): 4 UNIT: 5 CATEGORY CODE (1,2,3): 6 OPEN/ CLOSED: 13 COMMENTS: 7 DESCRIPTION: 14 START DATE(SCH/ACT):
' "^
O LO C/R T NTS: (IF BLOCKS 19,20,21,22 NOT REQUIRED): 17 OATT KEY: 18 STATUS: 11 ASSUMPTIONS: O ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-18
Commitm:nt to Excallence Action Plan FIGURE 4-4 TASK PLANNING HORKSHEET {PAGE 2) TYPICAL TASK PLANNING WORKSHEET SHEET 2 CLOSEOUT ACCEPTANCE CRITERIA SATISFACTORILY ACCOMPLISHED PEACH BOTTOM COMMITMENT Responsible Individuat Date: TO EXCELLENCE PROGRAM Responsible Supervisor. Date: OA VerWWon Date:
. TASK DESCRIPTION (FROM PAGE 1):
19 SUB-TASKS 20 RESPONSIBLE INDIVIDUAL 21 ESTIMATED 22 START /
& ORGANIZATION RESOURCES
{fNI SCH/ACT O 23 CLOSEOUT ACCEPTANCE CRITERIA: REVIEWED FOR AUDITABILITY Date APPROVED BY INDMDUAL RESPONSIBL E FOR TASK IMPLEMENTATION APPROVED BY RESPONSIBLE SUPERVISOR
~
SIGNATURE DATE SIGNATURE DATE O ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0VT PROCESSES 4-19
r-Commitm nt to'Excallancs Acticn PlEn. I FIGURE 4-5 .
~ b.- CHANGE NOTIFICATION / REQUEST FORM-l Change Nottficotton/ Request Form CTE Action Plan Task List Check here if schedule or close out Check here if schedule or close-out acceptance criteria are not affected criteria are affected Task # Add new task Delete task Revise task Changes in Change in closeout Changein Category ' subtesk acceptance criteria schedule
Description:
Resources: Schedule: Responsibility. Rational for change request: Affected other tasks: Responsible Assistant to Originator PBAPS CTE: Plant Manager. (name) (date) Accepted for incorporation Rejected - no further action - comments Project Manager (name) (date) O ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-20
CrinmitmInt' to Excellancs Action Plan FIGURE 4-6
- o TASK STATUS REPORT FORM Action Plan Task Status Report 1987 Task Category: _ Unit:
' Organization: Closed: Responsibility-Start Finish Task / Subtask Respont i bility Orig. Schedule Forecast / Actual Orig. Schedule Forecast / Actual Current or Anticipated Actions / Resources Neeoert Resp Org/ Individual Schedule Restraints Comments:
Submitted by: O ACTION PLAN TASK DEVELOPMENT, IMPLEMENTATION, MONITORING AND CLOSE-0UT PROCESSES 4-21 a
Action Plan Task List O O l O
Csmmitm nt to Excallanca Action PIEn
. 5.0 ACTION PLAN TASKS LIST O
Overview of Action Plan Tasks List The heart of 'the CTE Action Plan is the Action Plan Tasks List which contains l over 275 specific tasks for improvement of PBAPS operations. Current open commitments which PE has made, as well as other current open items, are also included. The Tasks List is organized into nine sections. The purpose of the first section, 5.1 Dreanization Staffino and Structure, is to ensure that the appro-priate organizational structures and staffing resources are in place to perform quality work . at, or in support of, PBAPS in a safe, timely, cost efficient . manner. The section includes over 30 Tasks focused on
- acquiring and training adequate numbers of licensed operator candidates, as well as attitudinal assessment and training of cutrent operators e providing increased management and licensed operator. coverage on ' all
.. shifts and using shift resources more efficiently
- determining the need for changes to the shift rotation schedule e ensuring adequate numbers of supervisory positions throughout the PBAPS f organization to direct and monitor employee work activities mor:a effec-tively
* . increasing the accountability and productivity of site and off site support organizations Section 5.2 of the Tasks 1.ist addresses the core of the management and attitu-dinal problems which PE is determined to resolve. Entitled Organization Lead-ership and Manacement, this section incorporates over 45 tasks which wills e clarify management expectations and accountabilities e ensure that effective manacement planning, problem-solving and communi-cation processes are in place to successfully support Action Plan Implementation
* ' ensure appropriate levels of management involvement in and oversight of plant operations e identify and resolve problems related to site / corporate work interfaces i
*- modify personnel policies and practices for application to nuclear operations e enhance management and supervisory skills
- promote positive change with respect to corporate and site employee attitudes toward nuclear operations excellence ACTION PLAN TASKS LIST 5-1
Commitm2nt 'to Exc211cnce Action Plan l Accomplishment of the Tasks in this section will essure success in meeting the first two objectives of the Peach Bottom Commitment to Excellence:
'?( j-
" Provide corporate and plant leadership which inspires and sustains a dedi- ;
cation to excellence on the part of every PE employee who helps operate or support PBAPS."-
" Establish a work environment which fosters open communications, collab-oration and timely responsiveness between employees and management, between all site work groups, and between all site and off site work groups dedicated to' support of PBAPS." j l
Another Commitment to Excellence objective is to:
" Assure the highest ' level of excellence in plant operations through the upgrade of work management systems, programs, procedures, and plant systems, as required, and the inteseation of the assurance of quality into all aspects of plant operations."
The third section of the Tasks List, Plant Procedures, Work Manecement Systems and Procrams is aimed at accomplishing this objective. In addition to over 65 Tasks related to the corrective action program for procedure compliance, Section 5.3 also includes over 110 Tasks to improve the following plant programs and work management systems:
- Quality Assurance
- Radwaste Management
- Radiological Controls
- Corrective and Preventive Maintenance
- Plant Chemistry
- Plant Engineering Support
- Emergency Preparedness
- Security and Safeguards
- Fuel Management
- Surveillance Testing ;
- Blocking Permit Process
- Site Procurement l
- Commitment Tracking l
- Integrated Living Schedule O
ACTION PLAN TASKS LIST 5-2
Commitm::nt to Excslienca Action Plan l The purpose of Section 5.4 of the Tasks List, Plant Facilities and Plant ( Systems, is to improve plant facilities and systems hardware through accom-plishment of over 15 Tasks which will
- provide a physical working environment which supports commitment to excellence by adding new permanent office facilities on site and modi-fying the layout of the control room complex
- ensure additional capability to monitor the status of critical equipment
- improve the labeling of plant equipment a provide a site specific training simulator for PBAPS
- reduce the number of unplanned reactor scrams Section 5.5 of the Tasks List, External Relationships, focuses on improving PE's relationsh2ps with the NRC and industry auditors with respect to PBAPS oper-ations, and will help PE accomplish another CTE objective:
"Make timely and effective responses to any concerns expressed by the NRC or industry organizations with respect to Peach Bottom operations, and achieve high ratings on all regulatory and industry assessments."
The ten Tasks in this section wills () (/ e assess the ef festiveness of corrective actions taken by PE in the recent pas t which rr. late to concerns identified in the Shutdown Order and incorporate lessons learned into the CTE Action Plan o establish more effective management processes to assure that future commitments are based on root cause analyses with appropriate involve-ment of all levels of line management in planning corrective actions e ensure appropriate management accountability for monitoring corrective actions and verifying that actions have accomplished the purpose i t.t e nde d
- improve communications about Peach Bottom operations with the NRC and industry reviewers A CTE Project Management List for Open Commitments and Open Items has been established to ensure that:
1
- 1. all specific actions which PE has previously committed to take, but has not yet completed, are reviewed and integrated as appropriate into the CTE Action Plan; and l 2. open commitments / items are tracked in a manner that permits timely l review of their status so that management action can be taken as required.
Sections 5.6 t'nrough 5.9 of the Action Plan Tasks List comprise this CTE Project Management List. ACTION PLAN TASKS LIST 5-3
C mmitmInt to Exc311cnc3 Acticn Plan Open commitments / items were identified for the Project Management List from the following sources (G") NRC Inspection Reports NRC Inspection and Enforcement (I8E) Bulletins NRC Generic Letters PBAPS Licensee Event Reports (LERs) HRC Regulatory Guides NUREGs Systematic Assessment of Licenseo Performance (SALP) Reports NRC Information Notices INPO Significant Operating Event Reports (SOERs) INPO Peach Bottom Atomic Power Station Evaluations INPO Corporate Evaluations American Nuclear Insurers (ANI) Inspection Reports ()
? ~
PBAPS Independent Safety Engineering Event Reports General Electric Service Information Letters (SILs) PBAPS License Amendments PBAPS Enhancement Program (PBEP) PBAPS Improvement Program (PBIP) The individual open commitments / items are being tracked on a separate computer data base and are not included in this document. However, an index of the CTE i Project Management List (Figure 5-1) is included at the end of this section to show how blocks of numbers in The Action Plan Tasks List have been established l for each type of open commitment / item. I Section 5.6 contains Open NRC Commitments, including those modifications which will be implemented prior to restart and significant modifications which will ! be implemented af ter start up. The following are examples of modifications that are listed: l Valve Motor Operator Testing Motor Operated Valve Actuator Testing System l (MOVATS) testing of applicable motor operated valves in the High Pressure l Coolant Injection (HPCI) system, Reactor Core Isolation Cooling (RCIC) l l system and safety related valves inside of primary containment. ACTION PLAN TASKS LIST 5-4 l l
C mmitm:nt to Exc3111nc3 Action PlIn Fire Protection and Alternate Shutdown: Relocating or encapsulating power (") (_/ and control cables to provide for alternate shutdown in the event of a fire. Hydrogen Water Chemistry: Installing piping and equipment for injection of hydrogen into reactor feedwater to reduce the incidence of intergranular stress corrosion cracking of stainless steel piping systems. Secondary Alarm Station Relocation: Constructing a new building to house the new security computer and other existing security equipment. Human Factors Enhancement of Control Room Panels: Changing panel color from green to beige; relabeling panels with a hierarchical labeling scheme; and adding initiation pushbuttons for emergency core cooling. Training Simulatori Installing a plant reference training simulator on site which replicates Unit 2 and common plant control room equipment. This will provide plant specific training for PBAPS operators in accordance with industry standards and NRC requirements. Radwaste System Improvements: Installing a radwaste dewatering system and a radwaste volume reduction system. Plant Process Computer Upgrade: Adding a safety parameter display system; enhanced capability to perform post-trip reviews; accident monitoring instrumentation; and data links to the Technical Support center and the emergency operations facility. Building Facilities Improvements: Constructing the North Auxiliary Services Building which will provide an additional 80,000 square feet of space. Also included in Section 5.6 are open commitments from the PBAPS Enhancement i Program (PBEP). These are being integrated into the CTE Action Plan, using an orderly transition process which protects the integrity of both the PBEP and the CTE Action Plan tracking systems. i i Section 5.7 contains Open INPO Commitments, while Section 5.8 contains Other l Open Commitments such as those associated with FSAR revisions, PBAPS ISEO Event j Reports and General Electric SILs. 1 Section 5.9 is reserved for Other Items such as PBAPS License Amendments, ' Emergency Plan Open Items and QA audit findings. Some of the individual commitments / items in Sections 5.6-5.9 have already been , incorporated as programmatic Tasks in Sections 5.1-5.5 of the Action Plan Tasks List. Where this is the case, these commitments / items are crose referenced with i the programmatic Tasks. The CTE Project is reviewing Sections 5.6-5.9 to identify any additional open commitments / items which should be included as programmatic Tasks. As these are identified, new Tasks will be added where appropriate in Section 5.1-5.5. b>
~- 1 l
4 ACTION PLAN TASKS LIST 5-5
Commitm2nt to Excellsnca Action Plan Regardless of whether the action is included as a Task in Sections 5.1-5.5 or an open commitment / item in Sections 5.6-5.9, the same planning, scheduling, O- monitoring and close-out processes described in Section 4.0 are applied. Those open commitments / items which have been scheduled to be completed prior to restart are included in the CTE Category 1 Activities Schedule in Section 6.0. PE is committed to maintaining backlogs of open commitments / items at minimum levels. Efforts are underway to reduce any existing backlogs in Sections 5.6-5.9. The processes that PE uses to manage its open commitments / items will be reviewed and improved as part of Tasks defined in Section 5.5. Until these processes have been improved, the CTE Project will con tinue to track open PBAPS commitments / items and monitor PE's various commitment management processes relative to PBAPS by: l
- Maintaining lists of open PBAPS commitments / items (Sections 5.6, 5.7, 5.8, 5.9)
- Reviewing the open commitments / items for inclusion as programmatic tasks in Sections 5.1 through 5.5 as appropriate, and ensuring that commitments and tasks are cross referenced accordingly
- Ensuring that a responsible person has been assigned to each t commitment / item and that a due date for completion has been determined e Ensuring that required actions are clearly delineated via sub-Tasks O and close out acceptance criteria e Monitoring progress on open commitments / items
- Ensuring that effective close out processes exist and that commitments / items are closed using the appropriate process 1
1 l 1 O ACTION PLAN TASKS LIST 5-6
Crmmitment to Excs11snc3 Acticn Plan August 7, 1987 m
- CTE ACTION PLAN TASKS LIST 5.1 ORGANIZATION STAFFING AND STRUCTURE 5.1.1 Licensed Operator Resource Development and Trainina Objective
- Ensure availability of sufficient numbers of qualified licensed operators to restart PBAPS.
Procram Elements Cateaorv 5.1.1.1 Develop and initiate plans for 1 recruitment of additional licensed operator candidates. 5.1.1.2 Establish operator performance 1 standards, including written expectations and a " Commitment to Excellence". statement, developed with input from operator personnel. 5.1.1.3 Conduct individual operator 1 attitudinal assessment and counseling program. 5.1.1.4 Design and conduct training program 1 to prepare licensed engineers for shift roles. 5.1.1.5 Design and conduct operator training 1 program People - Foundation of Excellence 5.1.1.6 Design and conduct shift manager 1 training program. 5.1.1.7 Implement training program for 2 licensed operator candidates. 5.1.1.8 Number unassigned to date 5.1.1.9 Develop and implement plans for train- 1 ing shift managers and shift operators to function as a team. 5.1.1.10 Conduct operator and staff training in () 1 upgraded procedures. ACTION PLAN TASKS LIST 5-7
Commitment to Excellence Action Plan Proaram Elements Cateaorv lh 5.1.1.11 Develop and conduct training to orient licensed operators obtained from PBAPS 2 co-owners and General Electric to CTE and People - Foundation of Excellence concepts. 5.1.2 Shift Organization, Staffina and Rotation Schedule Objective: Provide increased management and licensed operator coverage on all shifts and use shift resources efficiently. 5.1.2.1 Implement the Shift Manager concept 1 at PBAPS. 5.1.2.2 Determine additional positions needed 1 to manage and perform shift work; revise shift organization accordingly and develop job descriptions, classifications and qualifications for additional identified positions. 5.1.2.3 Determine need for any changes in 2 shift rotatio9 schedule and implement if appropriate. Ensure qualified staffing of all G 5.1.2.4 shif t positions required for safe 1 restart and operations. 5.1.2.5 Staff additional positions developed 3 in 5.1.2.2 to enhance the shift organiza tion . 5.1.3 Site Organizational Structures and Staffina Objective: Ensure appropriate organizational structures, adequate supervision, and qualified technical and administrative support to perform site functions effectively and efficiently. 5.1.3.1 Determine appropriateness of PORC 2 charter with respect to responsibilities assigned and membership; add and/or eliminate responsibilities / members as required. O ACTION PLAN TASKS LIST 5-8
Crmmitm:nt to Exc311cnc2 Action Pl n Procram Elements Cateoorv ("N 5.1.3.2 Assess effectiveness of PORC meeting 2 \~ structure and processes; identify and implement any required changes. 5.1.3.3 Assess the administrative workload 2 of senior plant management personnel to identify excessive burdens or imbalances and implement corrective actions as required. 5.1.3.4 Establish and staff a Nuclear Personnel 1 Specialist function on site. 5.1.3.5 Establish and staff.first line super- 1 visory positions in Health Phyrics. 5.1.3.6 Assess the need for additional senior 2 supervisory positions in Plant Staff; establish and staff positions as required. 5.1.3.7 Assess the organizational structure 2 and responsibility assignments for the Radwaste function at PBAPS to identify opportunitice for improved productivity and accountability; (} \_/ implement improvements ss required. 5.1.3.8 Assess the organizational structure 2 and responsibility assignments for the Chemistry function at PBAPS to identify opportunities for improved productivity and accountability; implement improvements as required. 5.1.3.9 Assess the organizational structure 2 and responsibility assignments for the Maintenance function at PBAPS to identify opportunities for improved productivity and accountability; implement improvements as required. 5.1.3.10 Assess the organizational structure 2 and responsibility assignments for the Health Physics function at PBAPS to identify opportunities for improved productivity and accountability; implement improvements as required. O) ACTION PLAN TASKS LIST 5-9
Commitment to Excellence Action Plan Procram Elements Cateoorv () 5.1.3.11 Assess the organizational structure and responsibility assignments for 2 the Administration function at PBAPS ( to identify opportunities for improved productivity and accountability; implement improvements as required. 5.1.3.12 Assess the organizational structure 2 and responsibility assignments for the Operations function at PBAPS to identify opportunities for improved productivity and accountability; implement improvements as required. 5.1.3.13 Assess the organizational structure 2 and responsibility assignments for the Technical function at PBAPS to identify opportunities for improved productivity and accountability; implement improvements as required. 5.1.3.14 Assess the organizational structure 2 and responsibility assignments for the Outage Planning function at PBAPS to identify opportunities for irwroved () productivity and accountability; implement improvements as requirsu. 5.1.4 off-Site Support Organizational Struqtures and Staffing Objective Clarify accountabilities and provide adequate supervision and technical support to perform site support functions ef fectively and efficiently. 5.1.4.1 Revise the organizational structure, 2 position descriptions, and performance evaluation process of the Radiation Protection Section to clarify site support responsibilities of each work group and increase accountability; staff new positions as required. 5.1.4.2 Number unassigned to date. 5.1.4.3 Assess reorganizing Huclear Operations 3 and Engineering and Research QA/QC functions under one manager reporting to the Senior Vice Presioent-Engineering and Production. O ACTION PLAN TASKS LIST 5-10
l l Commitment to Excellenc3 Action Plan Procram Elements Cateoorv l' t I \- 5.1.4.4 Improve management supervision of I security contractor and guard force, and establish and staff shift security l assistant position. 5.1.4.5 Assess the organizational structure 2 and responsibility assignments for the Radioactive Haste Management Section to identify opportunities for improved productivity and accountability; imple-- ment improvements as required. 5.1.5 Nuc19ar Operations Management Structure Objective: Reduce reporting levels between station managers and the President and ensure adequato managerial and technical staff support for nuclear management. 5.1.5.1 Identify and assess organizational 3 options for reducing management reporting levels in the Nuclear Operations chain between station j managers and the Chief Executivo i r"N Officer; implement any changes approved. I (v ) 5.1.5.2 Assess the need to provide additional 3 managerial and techr.ical support to Nuclear Operations management; establish and staff any positions approved as e l result of the assessment. 5.2 ORGANIZATION LEADERSHIP AND MANAGEMENT 5.2.1 Manacement Role Expectations, Accountabilities, and Processes Objective: Clarify management role expectations and accountabilities, and ensure organizational effectiveness and successful accomplishment of the CTE Program. 5.2.1.1 Establish and communicate the mission 1 statement and objectives for the CTE Program to the PE organization. O ACTION PLAN TASKS LIST 5-11
C mmitment to Exc3111ncs Acticn Plan l Proaram Elements ~ Cateaorv
/ 5.2.1.2 Conduct a one-day management planning retreat attended by the President, 1
Senior Vice President-Engineering and Production, Vice Presidents of Nuclear Operations,. Engineering and Research, Electric Production, Personnel and Industrial Relations, Purchasing and General Services, Corporate Communications, and Legal, and involved Department Managers to
'(1) clarify senior management expectations and organizational accountabilities for support of the CTE Program; and (2) ensure that effective interdepartmental problem-solving and communication processes are available to implement the Program.
5.2.1.3 Number unassigned to date. 5.2.1.4 Establish the processes to be used by 1 the Senior Vice President-Engineering and Production CTE Project Review Group to assure Action Plan implemen-tation according to schedule and resolve ; related interdepartmental problems. O 5.2.1.5 Communicate management expectations 1 l l
]
and individual accountabilities for support of the CTE Program, monitoring Action Plan progress and resolving interdepartmental and intergroup problems related to j Action Plan Task implementation to each management level down to first-line supervisors. 5.2.1.6 Clarify and document the roles and 3 responsibilities of the plant and Nuclear Support Department staff with respect to interfaces on plant j programs and work activities. , 5.2.1.7 Clarify and document the roles and- 3 responsibilities of the plant staff I and Maintenance Department staff with i respect to interfaces on plant programs ) and work activities. 5.2.1.8 Number unassigned to date. ACTION PLAN TASKS LIST 5-12 2
C:mmitm nt to Exc311cnca Action P1En Prooram Elements Cateoorv
/~ T ' 5.2.1.9 Clarify and document the responsibil- 3 ities and relationships between station management and Engineering and Research Department Chief Engineers.
5.2.1.10 Clarify and further document, as needed, 3 the responsibilities and authorities of the PBAPS system engineers and the relationship of the system engineers with engineers in Engineering and Research. 5.2.1.11 Clarify and document the roles and 3 i responsibilities of Electrical Engineer-i ing Division field engineers with respect to station operations. 5.2.2 Corporate and Site Plant Performance Trendina Objective Ensure effective trending and reporting of plant performance indi-cators for timely review by senior management. 5.2.2.1 Assess processes currently used for 2 monitoring, analyzing, trending and ("N reporting plant performance indicators
\ (including the results of NRC and INPO assessments) to management; make any appropriate changes to improve.
5.2.2.2 Establish routine meetings for trending 2 results to be reviewed and discussed by Nuclear Operations management and the Senior Vice President-Engineering and Production to ensure that appropriate corrective action is taken to address any problem areas in a timely manner. 5.2.3 Corporate / Site communications Objectives Ensure adequate input from all levels of site and support organ-izations prior to corporate decision making. 5.2.3.1 Use routine site visits by the Manager, 2 Nuclear Generation, the Vice President of Nuclear Operations, and the Senior Vice President-Engineering and Produc-tion, as an opportunity to meet inform-ally with site personnel. O ACTION PLAN TASKS LIST 5-13
CcmmitmInt to Excallincs Action Pltn Prooram Elements Cateoorv
'- 5.2.3.2 Assess the adequacy of communication 2 processes used by corporate management j to convey information to lower levels of management in site and support organiz-ations about operational, organizational or regulatory related matters in a timely manner; improve communication processes as required.
5.2.3.3 Assest the adequacy of communication 2 processes used to obtain timely input from lower levels of site and support organization management before making operational, organizational or regulatory-related decisions at the corporate or station management level; improve communication processes as required. 5.2.4 Statign Manacement Involvement In Dav-to-Day Station Operations Objective
- Increase station management involvement in day-to-day station operations and improve station management / employee communications.
5.2.4.l' Assess effectiveness of current 2 k Station management meeting str uctures and processes to plan and coordinate work activities with site and off-site work groups; revise as required. 5.2.4.2 Make random plant tours, including 1 back shift, so that plant and operations management can observe operations and communicate regularly with operations personnel. 5.2.4.3 Assess effectiveness of current 2 methods and channels used by station management to communicate directives l or information about operational and organizational concerns in writing; revise as required. 5.2.4.4 Establish additional two way 1 communication processes between Peach Bottom station management and site employees to obtain employee input and suggestions, and keep them informed about operational and organizational matters. ACTION PLAN TASKS LIST 5-14
Crmmitm:nt to Exc311cnce Acticn Plan Prooram Elements Cateoorv 5.2.5 Site / Support Organization Work Interfaggs Objective Ensure timely and responsive working relationships between all site and off-site work groups. 5.2.5.1 Review working relationships between 2 site work groups, reinforce effective performance areas, and identify and resolve any problem areas with the involvement of relevant managers. 5.2.5.2 Review working relationships between 3 site work groups and off-site support work groups, reinforce effective performance areas, and identify and resolve any problem areas with the involvement of relevant managers. 5.2.6 Personnel Policies and Practices Objectives Ensure that personnel policies and practices support nuclear personnel requirements and performance standards.
/~N . 5.2.6.1 Revise entry-level hiring policy 1 ks as required to ensure adequate flexibility for hiring experienced nuclear personnel at appropriate job classification levels.
5.2.6.2 Identify lateral transfer and alter- 2 native promotional opportunities for licensed operator personnel; communicate plans and target dates for implementing these alternative career paths. 5.2.6.3 Establish and implement alternative 2 career paths for senior non-licensed operators. 5.2.6.4 Identify major disincentives to 2 pursuing the nuclear operator job sequence through the supervisory level; develop and implement countermeasures as appropriate. i ACTION PLAN TASKS LIST 5-15
f Ctmmitm:nt to Exc3115nca Action Plan Prooram Elements Cateoorv () 5.2.6.5 Review Disciplinary Guidelines to ensure that definitions of various 1 levels of infractions and corresponding disciplinary actions are consistent with nuclear practices; if necessary, establish new definitions and/or inter-pretations of the policy to meet nuclear operations needs. 5.2.6.6 Revise the disciplinary policy to 1 permit immediate suspension of employees by supervisors in all cases where suspension is warranted. 5.2.6.7 Revise the grievance process to retain 1 final decision-making authority for all grievances within the Nuclear Operations line management organization, with the Vice President of Personnel and Industrial Relations becoming involved only if the grievance resolution is appealed. 5.2.6.8 Streamline grievance and appeals 2 processes to ensure timely resolution () of issues. 5.2.6.9 Develop written guidelines with respect 2 to management's responsibilities and authorities in the disciplinary process down to the first line supervisory level. 5.2.6.10 Conduct special training sessions for 2 all Peach Bottom managers, down to first line supervisors, in effective implementation of disciplinary policies and work rules. 5.2.7 Manaaement and Supervisors Skills Improvement Objectives Improve nuclear operations staff management and supervisory skills, and develop company-wide management awareness of nuclear operations requirements. 5.2.7.1 Develop and implement a systematic 2 process to determine nuclear operations staff management and supervisory skill training needs. ACTION PLAN TASKS LIST 5-16 j i _--_---_---_--_---_-----_----------J
Commitment to Excellence Action Plan Proorem Elements Cateoorv Evaluate capability of currently 2 O 5.2.7.2 available management / supervisory training programs and schedule (s) to meet Nuclear Operations needs (as determined in 5.2.7.1) . 5.2.7.3 Develop additional management / 3 supervisory training programs as needed; accommodate location and scheduling of such programs to Nuclear Operations needs when conducting these programs. 5.2.7.4 Appoint a nuclear representative 2 to serve on the Central Training Committee and as Management Training liaison. 5.2.7.5 Develop and implement a process to 2 ensure direct, timely input about the content and effectiveness of management / supervisory training programs between nuclear management and those responsible for designing and conducting the training. 5.2.7.6 Schedule training sessions in 2 face-to-face performance reviews and on-the-job coaching for Nuclear Operations managers and supervisors. 5.2.7.7 Issue written directive requiring 1 all Nuclear Operations managers and supervisors to conduct annual face-to-face performance reviews and to hold separate performance planning meetings, prior to the start of each performance review cycle, to establish employen performanceobjectivesforthey{4e. 5.2.7.8 Develop and use supervisory job quali- 2 fications for promotion to lead and l supervisory positions at Peach Bottom. 5.2.7.9 Use assessment of potential super- 2 visory ability in s.nlecting candidates for SLO Training; include training in supervisory skills as part of SLO Qualification Training. ACTION PLAN TASKS L1ST 5-17
i Commitm:nt to Exc311gnc3 Action PIEn [ Procram ~ El. aments Cateaory l( ) 5.2.7.10 Develop written guidelines for use in assignin's pre supervisory training 2 opportunities; making temporary class-ification assignments; and observing performance in upgraded positions before approving permanent assignments to q supervisory positions. 5.2.7.11 Design and conduct a seminar program 3
-involving notable management experts and successful nuclear utility executives to expose senior management to new manage- I ment trends and successful practices in nuclear affairs.
5.2.7.12 Assess the effectiveness of the current 3 rotational assignment program for exper-ienced engineers in Engineering and Production; identify and implement needed improvements. 5.2.7.13 Assess the need for a Nuclear Operations 3
- specific supplement to the Upgrader /
A Pre-Supervisor Program.
'. i 4
5.2.8 Attitudinal Chauge
' 0bjectivet 1
Ensure that nianagement and employee attitudes support the Peach Bottom Commitment to Excellence philosophy. 5.2.8.1 Conduct Alte-wide training about the 2 meaning of the " Commitment to Excel-lance" statement for employees who are regularly assigned to the station and who are in progressions which lead to the nuclear premium, or who are in those j ob classifications which have been receiving a higher rate of base pay due to their assignment at PBAPS. Obtain signatures from each of these employees indicatin. his/her commit-ment to upholding the statement standards in daily work activities. 5.2.8.2 Conduct a systematic organizational 3 survey to identify employee attitudinal and work concerns; follow-up with a well managed i employee involvement program which uses the results of the survey, O' work group by work group. ACTION PLAN TASKS LIST 5-18 l I
Crmmitm nt to Exc311:nc3 Acticn Plan Procram Elements Cateoorv l ( 5.2.8.3 Design a training module on the current 3
\ nuclear regulatory environment and chang-ing nuclear industry standards; include module in future training programs.
5.2.8.4 Use a survey to identify interpersonal 3 communication and performance feedback issues among members of Senior Vice President Engineering and Froduction management team down to station management level; use results of survey to enhance management team effectiveness. l 5.2.8.5 Design and conduct a training program 2 for non-licensed operators which will address attitudinal and work concerns. l l 5.3 PLANT PROCEDURES, WORK MANAGEMENT SYSTEMS AND PROGRAMS 5.3.1 Procedures Unorade Proaram Objective: Ensure that plant procedures have been reviewed and revised as O required to support safe restart and ongoing operatiens of PBAPS. 5.3.1.1 Develop evaluation methodology for 1 restructuring and revising pro- ' lures. 5.3.1.2 Evaluate the need to revise and upgrade 1 Administrative (A) procedures. Identify those Administrative procedures which must be revised prior to restart and revise as required. 5.3.1.3 Review and upgrade the remainder of the 2 Administrative (A) procedure series. 5.3.1.4 Evaluate the need to revise and upgrade 1 General Plant (GP) p-ocedures. Identify those General Plant procedures which must be revised prior to restart and revise as required. 5.3.1.5 Review and upgrada the remainder of the 2 General Plant (GP) procedures. l ACTION PLAN TASKS LIST 5-19
; s .
Conaltent to Exec 11ence Action Plan , a Proorem Elements -
,Cateocev
. 1 h 7' ) 5.3.1.6 Eviluate the need to revise ano upgrade 1 9 , System (S) procedures. Identify those System procedures which mest be revised I prior to re: start and revisd c.s required. t 5.3.1.7 Review and up.prade the remainder of the 2 h ' System (S) p re c'e du r es . l . .
\ 5.3.1.8 Evaluatu the neakto rw.uss and upgrade 1 Heal.th Physics Pedcadures. Identify those Health Physics (dP) procedures
\ -t
'which must be revised price-to restart and revise as required. ,
r. 5.3.1.9 Review and upgrade the remainder of 2 4 the Health Physics (HP) procedures. i S 3.1.10 Evaluate the need io revise and upgrade 1 Radioactive Haste (RH) procedures. Identify those Radioactive Haste
- procedures which must be revised prior te, restart and revise as required.
%1 5.3.1.11 kevieu and upgrade the remainder of the 2 P.,[4,ioa-etive Haste ( RH) procedures.
- j 5.3.1.12 Review anO morade Maintenance (M) 2 I
% procedurer..
t 4 t*eview and upgrade Instrument and 5.3.1.13 R 2
\ Control Surveillance Test (ST) procedures,
% , 4 g
5.3.1.14 Evaluate the need to revise and upgrade 1 Chemistry procedures. Identify those s Chemistry.procndures which must be g revised brior to
- restart and revise as
( required. 7 \ ' Review and upgrat% the remainder of 2
- 5. 3. L.J 5
* $ ,i the Chemistry proca-!uren.
5.3.1.16 Evalunte the need to'reviso and upgrade 1
'< Emergency (E) procedures. Identify those Emergency procedures which must be revised prior to restart and revise as required.
% i ,
5.3.1.17 Review and reviso the remainder of the 2 Emergency (Ei procedures. k
< . '\> )
Materials Program. 5.3.13.16 Upgrade the overall HP instrumentation 2 usage program. 5.3.13.17 Establish a centralized PE Health 2 Physics Data Base Management System. 5.3.13.18 Establish a total dose accountability 1 operational access control system at PBAPS. 5.3.13.19 Establish a section in the Radiation 2 Protection Manual concerning beta dosimetry and " hot particle" concepts. 5.3.13.20 Obtain NVLAP accreditation for the 3 TLD Program. 5.3.13.21 Develop a neutron dosimetry program 3 and review the feasibility of establishing a calibration facility. ( ACTION PLAN TASKS LIST 5-34
CEmmitmint t3 Exc3118nce Action Plan Procram Elements. Cateoorv 5.3.13.22 Increase worker, supervisor and 2 management involvement in all radiological work planning in order to improve radiological work practices (Ref. INPO 86/RP.4-1/4). 5.3.13.23 Evaluate the Peach Bottom internal 2 exposure control program and upgrade as required (Ref. 5.6.23.1, 5.6.22, 5.6.6.1). 5.3.14 Plant Chemistrv Procram Objective Identify and implement methods to improve plant chemistry conditions. 5.3.14.1 Analyze the revised BWR Hater Chemistry 3' Guidelines when issued to determine needed changes in plant chemistry program. 5.3.14.2 Evaluate chemistry on-line instrument- 2 ation to identify any upgrades required to provide continuous and reliable monitoring of plant chemistry; implement appropriate upgrades. 5.3.14.3 Develop and implement a comprehensive 2 chemicals control program. 5.3.14.4 Number unassigned to date. 5.3.14.5 Investigate closed cooling water 3 corrosion inhibitor for out-of-speci-fication conditions and identify i appropriate countermeasures. 5.3.14.6 Evaluate and implement chemical treatment 3 program for long term diesel fuel oil storage.
.O ,
ACTION PLAN TASKS LIST 5-35 l
Commitment to Excellence Action Plan Procram Elements Cateaorv 5.M.13 Security and Safeauards Proaram Objectives Ensure security of access to plant vital areas in compliance with all federal, state and local laws and regulations. 5.3.15.1 Design and implement plans for 1 rearrangement of guardhouse facilities, including installation of barriers to prevent bypassing of search equipment, replacement of existing x-ray machines, and repositioning of explosive detectors, metal detectors and x ray machines. 5.3.15.2 Develop and implement plan for 3 expeditious monitoring of employees and visitors as they exit from the plant. 5.3.15.3 Design and implement temporary 1 changes on fence alarms to calibrate for peak performance; test system using new surveillance test. 5.3.15.4 Design and implement permanent 2 changes on fence alarms. 5.3.15.5 Design and implement improvements 1 on Closed Circuit Television (CCTV) and Protective Area Boundary (PAB) lighting equipment. 5.3.15.6 Identify, design and implement 1 corrective actions to establish barriers at locations where HVAC ducts penetrate vital areas. 5.3.15.7 Identify and address any additional 1 improvement needs to prepare for Regulatory Effectiveness Review (RER) Security Inspection scheduled for September 15, 1987. 5.3.15.8 Assess the Nuclear Security Staff 3 performance in support of major outages and implement methods to improve their skills as required. O ACTION PLAN TASKS LIST 5-36
Commitm:nt to Excalignes Action Plan l l Prooram Elements Cateaorv ( . 5.3.15.9 Increase guidance to contractors on 3 their screening programs; perform surveillance of contractor screening programs to reduce program deficiencies. 5.3.15.10 Improve security processes for 2 personnel accountability during emergency drills. 5.3.15.11 Increase participation by local 3 I law enforcement agencies in Security response drills. 5.3.15.12 Cross train Nuclear Security staff 3 from site to site for Limerick and Peach Bottom. 5.3.15.13 Replace card readers at PBAPS. 3 5.3.15.14 Replace explosive detectors at PBAPS. 3 5.3.16 Emercency Preparedness Pronram Objectives Ensure that the Emergency Preparedness program is consistent with current procedures and requirements ar.d is adequately staffed. 5.3.16.1 Review the PBAPS Emergency Plan to assure 2 consistency with plant procedures currently under revision and consistency with the Limerick Plan where appropriate. 5.3.16.2 Perform an analysis of the current PBAPS 2 evacuation time estimate (ETE) in response to request from PEMA to determine adequacy of the existing ETE. 5.3.16.3 Develop and implement a formal Emergency 3 Preparedness exercise controller program. Select and train a pool of dedicated, trained controllers. 5.3.16.4 Review and upgrade the Emergency Plan- 3 ning Training Program to ensure appro-priate staffing of the Emergency Response Organization; improve the formal training system; and develop a system for tracking Training status. (/ ACTION PLAN TASKS LIST 5-37
Commitm:nt to Excallance Action P11n
'Proaram Elements. Cateaorv Assess adequacy of plan for information 5.3.16.5 3 k furnished to the media and the public during emergencies and make improve-ments as required.
5.3.16.6 Increase siren coverage to include 3 entire Emergency Planning Zone to meet expected additional FEMA requirements. 5.3.16.7 Train personnel newly assigned 1 to Emergency Preparedness response positions. 5.3.17 Site Procurement Objectivet Ensure the timely procurement of services and equipment and the ! availability of spare parts for plant operations, maintenance and outage work. 5.3.17.1 Assess the effectiveness of current 3 processes used to procure routine and outage related equipment, material and services; identify and implement any needed improvements. 5.3.17.2 Assess the adequacy of current system for 2 identifying needed materials, including spare parts; identify and implement any required improvements. 5.3.17.3 Review and evaluate the process 2 by which subcomponents of Q-listed components can be obtained as commercial grade material; determine and implement improvements which will I expedite the procurement of subcomponents , while still fulfilling all safety l requirements. l 5.3.17.4 Assess the need to establish a Rarely 3 Used Equipment Inventory Control Program. l i ACTION PLAN TASKS LIST 5-38
Commitment to Excellence Action Plan Prooram Elements Cateaorv g 5.3.18 Commitment Trackina Objective: Ensure ef fective tracking of all PBAPS commitments. 5.3.18.1 Evaluate QATTS system capability to be 2 used as effective single source for all commitment tracking; design and implement any required improvements. 5.3.18.2 Identify and provide additional 2 staffing resources needed to implement the QATTS system. 5.3.18.3 Integrate the QATTS system into all 3 aspects of site operations and off-site support to use as single source for all commitment tracking. 5.3.18.4 Train site personnel to use the QATTS 2 system. 5.3.19 Fuels Mananement Proqram Objective: Ensure that fuel performance is maintained within established limits. 5.3.19.1 Complete and implement Fuel Reliability 3 Monitoring Program. 5.4 PLANT FACILITIES AND PLANT SYSTEMS 5.4.1 Site Offices and Faciliting Dojective Provide adequate permanent office space and facilities for PBAPS personnel. 5.4.1.1 Design and construct a new permanent 2 building facility adjacent to the power block O ACTION PLAN TASKS LIST 5-39 l
C:mmitmInt to Exc311sncs ActiCn Plan Proaram Elements 'Cateoorv 5.4.1.2 Determine the need for additional 2
' O* ' permanent and temporary building facilities which are not included in the five-year plan for Peach Bottom but will be required to support CTE Action Plan implementa-tion.
5.4.1.3 Design and construct additional 2 facilities to meet tha needs identified in 5.4.1.2. 5.4.1.4 Upgrade the five-year plan for 3 Peach' Bottom to include decisions made in 5.4.1.2. 5.4.2 Plant Equipment Lav-Up Procram Objective: Prevent deterioration of plant equipment status during extended non-operating periods. 5.4.2.1 Evaluate the need and develop, as 2 ; necessary, a plant equipment lay-up program. O 5.4.2.2 Take action, as appropriate, to implement a plant equipment lay-up program, 2 based on results of evaluation in CTE Task 5.4.2.1. 5.4.3 Critical Eauipment Monitorina System (CEMS) Objective: Provide capability to check critical equipment status electron-ically. 5.4.3.1 Conduct CEMS training for station 3 operation personnel. 5.4.3.2 Continue and complete tagging of 2 existing CEMS identified equipment. 5.4.3.3 Revise CEMS data base to handle HVAC 3 and control room panel equipment. ACTION PLAN TASKS LIST 5-40 1 J _ _ _ _--__m
CtemitmInt to Excellanca Action Plan Proaram Elements Catecorv Evaluate'need to revise CEMS to accom-O' 5.4.3.4 modate blocking sequence; take action 3 as required. 5.4.4 Trainina Simulator Objective Provide site-specific training simulator for PBAPS 5.4.4.1 Determine site location for site- 1 specific training simulator. 5.4.4.2 Complete planning and installation of 2 site-specific training simulator. 5.4.5 Control Room Complex Work Control Improvements Objective: Modify the layout of the Control Room Complex to better meet the needs of operating personnel. 5.4.5.1 Implement Mod 1729: Renovate existing 2 office areas and workstations in the Control Room and construct two waiting areas and a lunch room north of the Control Room. 5.4.5.2 Implement Mod 1730: Relocate the 1 Security Secondary Alarm Station from the Control Room to a new building east of the Emergency Cooling Towers, 5.4.6 Plant Trio Reduction l Objective: Reduce the number of unplanned reactor scrams. 5.4.6.1 Humber unassigned to date. 5.4.6.2 Conduct a functional evaluation of 2 the feedwater system. , 1 5.4.6.3 Complete probability risk assessment 2 of the feedwater system (Mod 2187). 5.4.6.4 Implement feedwater control system 2 improvements (Mod 1843). O ACTION PLAN TASKS LIST 5-41
Ccumitm:nt to Excsilenca Acticn Plan Proaram Elements Cateaorv EXTERNAL RELATIONSHIPS 5.5 [ 5.5.1 Review of Closed Commitments Relevant to Shut-Down Order Objectives Analyze corrective actions taken by PE in the recent past which relate to concerns identified in the NRC Shutdown Order to assess effectiveness of actions taken in addressing root'cause problems, and incorporate lessons learned into the CTE Action Plan. 5.5.1.1 Review closed commitments from 1983- 1 1987 which relate to problems cited in the NRC Shutdown Order to determine appropriateness and effectiveness of corrective actions taken in addressing root cause concerns. 5.5.1.2 Number unassigned to date. 5.5.2 Manaaement Processes for Establishing and Manauina Future Commitments Objectives Establish effective corrective action programs with involvement and commitment of all management.
. 5.5.2.1 Assess effectiveness of current 2-management' processes used to respond to regulatory and industry assessments or concerns with respect to analysis of root causes, involvement of lower levels of site and off-site management, and establishment of real-istic schedules; identify and implement required improvements.
5.5.2.2 Establish a program for improving the 2 management of commitments. 5.5.2.3 Number unassigned to date. 5.5.2.4 Incorporate all open PBAPS Enhancement 2 1 Program Action Items into the PBAPS Commitment to Excellence Program. 5.5.2.5 Reduce the backlog of Information 2 Notices. O ACTION PLAN TASKS LIST 5-42
C mmitm:nt to Excsilence Action Pitn Procram Elements Cateaorv ('l k-T 5.5.2.6 Assess the processes by which PE receives, tracks and reviews Informa-2 tion Notices; decides on appropriate actions in response to the Notices; monitors those actions; and closes them out. Identify improvement opportunities and implement appropriate improvements. 5.5.2.7 Assess the processes by which PE 2 receives, tracks and reviews GE Service Information Letters (SILs); decides on appropriate action in responses monitors those actions; and closes them out. Identify improvement opportunities and implement appropriate improvements. 5.5.2.8 Assess the processes by which PE 2 receives, tracks and reviews SOERs; decides on appropriate actions in response; monitors those actions; and closes them out. Identify improvement opportunities and implement appropriate improvements. ('%g 5.5.3 External Communication Manacement and Processes
%J Objective: Improve formal and informal communication processes about Peach Bottom operations with the NRC and industry auditors.
5.5.3.1 Analyze formal and informal I communication processes used by management to maintain effective regulatory relationships with respect to Limerick Generating Station; adopt those practices that are appropriate for Peach Bottom. 5.5.3.2 Establish specific responsibilities 1 and focal points at different levels of management for communications / liaison with NRC (region and j headquarters), INPO, and ANI. j 1 1 l ACTION PLAN TASKS LIST 5-43
Crmmitmint ta Exc3112nc3 Action P11n FIGURE 5-1 INDEX FOR CTE PROJECT' MANAGEMENT LIST FOR OPEN COMMITMENTS AND OPEN ITEMS 5.6 OPEN NRC COMMITMENTS 5.6,001 - 5.6.199 NRC Inspection Reports 5.6.200 - 5.6.249 NRC IE Bulletins 5.6.250 - 5.6.299 NRC Generic Letters 5.6.300 - 5.6.399 PBAPS Licenvee Event Reports 5.6.400 - 5.6.499 NRC Regulatory Guides 5.6.500 - 5.6.599 Code of Federal Regulations 5.6.600 - 5.6.600 SALP Reports 5.6.700 - 5.6.799 Actions resulting from NRC Information Notices 5.6.800 - 5.6.949 PBAPS Enhancement Program 5.6.950 - 5.6.999 Other NRC Commitments 5.7 OPEN INPO COMMITMENTS O 5.7.001 - 5.7.099 Actions resulting from SOERs 5.7.100 - 5.7.499 INPO Station Evaluations 5.7.500 - 5.7.599 INP0 Corporate Evaluations 5.8 OTHER OPEN COMMITMENTS 5.8.001 - 5.8.099 FSAR Revisions 5.8.100 - 5.8.199 PBAPS ISEG Event Reports 5.8.200 - 5.8.299 Actions resulting from General Electric SILs 5.9 OTHER OPEN ITEMS 5.9,001 - 5.9,099 FSAR Revisions 5.9.100 - 5.9.199 PBAPS License Amendments 5.9.200 - 5.9.299 Emergency Plan Open Items 5.9.300 - 5.9.399 QA Audit Findings l ACTION PLAN TASKS LIST 5-44 l
)
Action Plan Task Schedule O 4 i N
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I O h O
C:mmitm:nt to Exc3117nc3 Action Plan 6.0 ACTION PLAN TASK SCHEDULE n Introduction Included in Section 6.0 is a bar chart schedule for the accomplishment of all 1 Category 1 Tasks including open commitments and open items. This schedule was developed using tha processes described in Section 4.0. 3 The schedule is in two sections. The first section displays those Category 1 Tasks which have been identified as most critical from a ccheduling point of view. The second section displays all Category 1 Tasks and open commitments / items identified to date, with the bars for the critical Tasks shaded. These two sections serve as a tool for managing the completion of the Action Plan Tasks. Progress and reassessment of Task completion dates will be displayed on the schedule. The schedule will be included in the regular status reports submitted to the NRC. The schedule for the completion of all Category 2 Tasks will be submitted to the NRC as developed and completed prior to resta rj .' The Ca't'egory 3 Tasks schedule will be submitted to the NRC as tN developed. k .) { i t t O . ACTION PLAN TASK SCHEDULE 6-1 i\' t
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COMMITMENT TO EXCELLENCE ACTION PLAN O APPENDIX A Problem Root Cause Assessment of Peach Bottom Shutdown (MAC Report) O O
l O 1 PROBLEM ROOT CAUSE ASSESSMENT OF PEACH BOTTOM SHUTDOWN l l Prepared For Philadelphia Electric Company 2301 Market Street l Philadelphia, PA.19101 l June 17,1987 l Management Analysis Company 12671 High Bluff Drive San Diego, CA 92130 (619) 481-3100 O eroject Nemuer: MAC-87-1247 P.O. Number GN 271338 h Copy No. 7 I <
- EXECUTIVE
SUMMARY
k Philadelphia Electric Company (PECo) is licensed by the U.S. Nuclear Regulatory Commission (NRC) to operate two nuclear power reactors (Units 2 and 3) at the Peach Bottom Atomic Power Station (Peach Bottom) located near Delta, Pennsylvania. On March ',15 1987 the NRC issued an order suspending power operation relating to issues of operator sleeping, inattention to duties, failure to adhere to procedures, and management inaction or inadequate action. The NRC directtd PECo to bring Peach Bottom Unit 3 to a cold shutdown condition. Unit 2 was already shut down for refueling. Neither unit may be restarted without NRC approval until the issues of the shutdown order have been addressed. On March 31, 1987, PECo requested the assistance of Management Analysis Company (MAC) in addressing the shutdown order issued by the NRC. MAC met with PECo management during the af ternoon of April 1,1987. MAC was asked to assist an In-house Management Review Team and was tasked with conducting a root cause analysis of the situation which led to the shutdown order. rs O i This report to PECo presents the results of the analysis of the information obtained from interviews, observations and documents reviewed by the MAC team. The root causes identified, conclusions reached, and recommendations made represent the collective judgment of the experienced team members assigned to the project; they are solely the work of MAC. Because the scope of the task is to identify problem areas, the report does not address the positive areas with respect to Peach Bottom operations for which PECo can be justifiably proud. The root causes and recommendations discussed in the report should be read with an understanding of this cWext. There are four primary root causes identified as the major contributors to issues and events at Peach Bottom which led to the shutdown order. They are: e Poor leadership by management at Peach Bottom. e Failure to initiate an aggressive operator training program to provide a sufficient number of licensed operators in a timely manner. V
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e A transplanted PECo fossil station organization, concept of shift operation, shift O V structure, and the PECo fossil way of doing business. Peach Bottom management did not perceive the need, or take sufficient action, to adapt these to the current nuclear operating environment. e The slowness of corporate management, above the plant level, to recognize the severity of the root causes described above and to insist on stronger, more timely and appropriate corrective actions. These root causes, which have a combined and interrelated effect, are embedded in and nurtured by the traditional PECo culture. Some of the same cultural characteristics which produced operational excellence in the early years at Peach Bottom bec tme contributing influences to the primary root causes, resulting in its shutdown. Examples of the ways in which these cultural characteristics produced both positive and negative effects include: e Entry level hiring practices which produced loyal dedicated, well trained employees during the first five years of operation have also contributed to a shortage of licensed operators, minimal shift staffing flexibility, inability to use operations experienced people in other functional areas, and resulted in operators who feel trapped, distrustful, and have negative attitudet.
,, e An orientation toward hiring and promoting engineers, which produced a highly (J professional and technical staff for entry into the nuclear power business, also contributed to a reduced awareness of people performance problems and people management solutions.
e Long-term management and staff assignments that created a protective " insulating bubble" around the team during start-up and early years of operation subsequently created an " isolating bubble" around the operations team which obscured from upper management's view the negative influence of fossil / hydro operating practices, poor plant management performance, and provided a shield resistant to regulatory change. e Personnel policies and practices, which had been carefully constructed over the last half century and which have produced a satisfactory relationship with the PECo Employee Independent Group Association (IGA) and a stable personnel resource environment, contributed to resistance to rapidly changing nuclear operations personnel requirements. e PECo's pride in pioneering and achievement in nuclear operations produced leadership in the nuclear utility industry and regulatory technical standards development. Later that pride also contributed to protectionism and defensiveness to criticism of their more recent performance and to questioning of the changes to l regulatory standards.
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Limerick is a newer operation still in its start-up phase, a condition similar to Peach O Bottom's insuietins bubbie of the eerix veers. it hes hee some of the eeventeses inherent in start-up organizations over steady-state organizations (e.g., more resources supplied, more flexibility with respect to policy implementation) as well as the benefit of an effective plant management team. Over time, however, there is the potential for some of the same Peach Bottom attitudinal problems to develop at Limerick if management does not take an aggressive stance in recognizing the need for substantive change in its management philosophy and approach to nuclear operations. There are many appropriate and effective short-term actions which PECo should take to address the problems cited by the NRC and get Peach Bottom back on line. However, to ensure that problems do not recur at Peach Bottom and to prevent their occurrence in the future at Limerick, there is a need for in-depth, long-term changes. The recommendations in this report are a combination of short- and long-term actions to produce these changes. Successful implementation is dependent upon: e Increased management awareness of the root cause influences e Management's willingness, ability, and leadership to change root cause influence where possible or to address the negative impacts when. the influence cannot be O changed e Management's application of resources to correct the current acute problems O
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TABLE OF CONTENTS <-) O Section Page EXECUTIVE
SUMMARY
..................................... i 1.0 INTROD U CTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 2.0 B AC K G ROU ND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3.0 ROOT CAUSE DETERMINATIONS ............................ 3 l
3.1 Cultural and Attitudinal Influences ....................... 3 3.2 Leadership and Management Issues ....................... 6 3.3 Personnel Policies: Nuclear Operations Application and Implementation ........................ 14 3.4 External Relationships .................................. 18
4.0 CONCLUSION
S ............................................. 20 5.0 RECOMMENDATIONS ....................................... 23 p) 5.1 Cultural and Attitudinal Influences 24
- 0 .......................
3.2 Leadership and Management Issues ....................... 26 5.3 Personnel Policies: Nuclear Operations Application and Implementation . . . . . . . . . . . . . . . . . . . . . . . . . 29 5.4 External Relationships .................................. 31 5.5 Action Plan Process .................................... 32 Appendix A PERSONNEL INTERVIEWED ................................. A-1 o { v
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5160h7 .
1.0 INTRODUCTION
O Philadelphia Electric Company (PECo) is licensed by the U.S. Nuclear Regulatory Commission (NRC) to operate two nuclear power reactors (Units 2 and 3) at the Peach Bottom Atomic Power Station (Peach Bottom) located near Delta, Pennsylvania. On March 31, 1987 the NRC issued an order suspending power operation relating to issues of operator sleeping, inattention to duties, failure to adhere to procedures, and management inaction or inadequate action. The NRC directed PECo to bring Peach Bottom to a cold shutdown condition. Unit 2 was already shut down for refueling. Unit 3 was brought to cold shutdown at 12:10 a.m. on April 1,1987 under the terms of the NRC order. Neither unit may be restarted without NRC approval until the issues of the shutdown order have been addressed. On March 31, 1987, PECo requested the assistance of Management Analysis Company (MAC) in addressing the shutdown order issued by the NRC. MAC met with PECo management during the afternoon of April 1,1987. MAC was asked to assist an In-house Management Review Team and was tasked with conducting a root cause analysis of the situation which led to the shutdown order. Q In addition to document review and observations, the MAC information gathering process included two to three hour interviews with those persons knowledgeable of the operation and management of Peach Bottom as listed in Appendix A. Six sets of interview questions were developed to address the information focus of the various groups. Without exception the interviewees were cooperative and responsive, and contributed positively to assist in the determination of the root Causes. The interviews included the following: e The General Electric (GE) shif t engineers and current and former PECo shift technical advisors (STAS) assigned to Peach Bottom rotating shifts (21 interviews) e Shift licensed operators from Shift Superintendents through Reactor Operators and a few non-licensed operators (44 interviews) O 15EiE
5160h7 e Nuclear Operations and key support organization management at Peach Q Bottom (46 interviews) e Corporate management from the Chief Executive Officer (CEO) through the [ operations management chain including key support managers and personnel l in other areas such as Engineering and Research, Testing and Laboratories, Maintenance, and Personnel (29 interviews) e A sampling of the Limerick Generating Station (Limerick) organization including the Plant Manager, shift operators, and selected support managers (9 interviews) This report to management (I) presents the results of the analysis of the information obtained from interviews, observations and documents reviewed by the MAC tear- The root causes identified, conclusions reached, and { recommendations made represent the collective judgment of the experienced team members assigned to the project.
2.0 BACKGROUND
PECo has had a long-standing commitment to entry level hiring and employment security for its personnel as they progress through various job classifications. O Many technical job classifications require engineering degrees and the vast majority of company managers have an engineering background. Management succession practices emphasize engineering and technical ability; long-term assignments in a position, or series of similar positions, are not uncommon. The company uses a matrix management approach to nuclear operations and maintenance which involves three different organizations in work performance at its nuclear plants: Engineering and Research, Nuclear Operations and Electric Production (Maintenance)'. The nuclear generation organizational structure and management assignments did not change substantially until late 1985 through 1986. The factors influencing these changes were: (1) Management, as used in this report, designates the management hierarchy as a whole as it relates to the direction and operation of Peach Bottom. Where possible and appropriate, every attempt has been made to identify specific O departments and levels for clarity in the text. Recent structural reorganizations must be taken into account for full understanding.
5160h7 e Limerick Generating Station Unit I commercial operation in February 1986 V e Apparent concern and response to INPO reviews and NRC SALP reports on Peach Bottom e Attempts at improved matrix management efficiency at Peach Bottom In late 1986 upon the early retirement of the Vice President, Electric Production Department, PECo made several significant organizational and management changes. The position of Senior Vice President, Engineering and Production was established with the Vice President, Nuclear Operations, Vice President, Engineering and Research, and Vice President, Electric Production reporting to I the Senior Vice President. This reorganization provided an enhanced opportunity for matrix coordination and located responsibility for Peach Bottom and Limerick operations, maintenance, and engineering under one corporate officer. Minimal changes in management personnel were made during this period at the Peach Bottom plant level. 3.0 ROOT CAUSE DETERMINATIONS Although the root causes of the problems have a combined and interrelated effect, discussed under " Conclusions" Section 4.0, we have found it beneficial in understanding the problems to group them into four categories. The problem statements and amplifying text are presented in the following areas: o Culturai and additional influences e Leadership and management issues e Personnel policies and practices e External relationships l 3.1 CULTURAL AND ATTITUDINAL INFLUENCES l 1 Overview and History Organizational culture / environment is not an easily describable element, but it is i a very powerful determinant of employee actions and management / employee relationships. It is the unique blend of values, beliefs, attitudes, norms, O erectices, myths, history, seif imese, etc., thet becomes the wey thin 8s ere < IEEii!
5160h7 -4 m done at PECo." It creates meaning and reference points for organization members. It is also what most differentiates an organization from other organizations. PECo has developed a closely knit, almost completely homegrown, technically oriented culture. The vast majority of its members are hired at entry .tevels, and the company makes a strong commitment to employment security. Generally, only engineers progress up the mane;;ement chain and in the nuclear areas, there appears to be greater emphasis placed on technical management than on people management skills. Management succession practices and long-term manage-ment assignments in the same or successive positions result in a self-perpetuating management system. The positive effects of this culture include: e Loyal and dedicated employees e Management and employees who are very knowledgeable about PECo history and the company's way of doing business hf" e An informal network that does at times work very effectively and efficiently because personal work histories and relationships encourage accessibility among PECo management and personnel e Pride in company history and performance e Comparatively low employee turnover The negative effects of the PECo culture, as they have been identified with respect to Peach Bottom operations, include: e A lack of new managerial perspectives from outside the PECo and additionally at Peach Bottom, a lack of new perspectives from inside the company e Limited number of management role models to expand PECo's management effectiveness, especially in Nuclear Operations e Minimal infusion of professionals with nuclear industry experience into the technical and managerial ranks, resulting in a limited exposure to the critical differences between the established Peach Bottom way of doing business and the constantly evolving requirements of the nuclear business e e A tendency on the part of Nuclear Operations personnel to rest on laurels of d past technical accomplishments and competencies and to resist change
$160h7 o Management which focuses on technical problem solving without sufficient d,m attention or skill applied to organizational and people concerns e A lack of performance motivation on the part of some employees and an erosion of management control over disciplinary actions because of the widespread perception in Nuclear Operations that no one is ever effectively disciplined or fired at Peach Bottom o Employees with very long memories about past management practices and personnel concerns who find it difficult to focus on "the way things are now" rather than "the way things were then" There is a power'ul Peach Bottom sub-culture in Nuclear Operations. It has its roots in the operation of Unit i under early regulatory conditions that were less prescriptive than today's requirements. Judged by the standards of the time, the early years of Units 2 and 3 operation were regarded as models of professional nuclear operational performance.
Increased Post-Three Mile Island (TMI) operator staffing requirements and the resultant scarcity of licensed operators over the past few years have been a g negative contributing factor to the Peach Bottom operations sub-culture. V During this period of increasing licensed operator staffing requirements of Units 2 and 3 and, especially while staffing for the start-up of Limerick, a negative aspect of this sub-culture developed when PECo management made what were considered by the operators to be promises about transfer and career opportunities. When management was unable to carry out these arrangements, Peach Bottom Operations personnel began to resent and distrust both corporate and plant management. Insensitive statements about plant management's lack of intention to follow through on perceived commitments to employees, and a lack of timely responsiveness to employee concerns, contributed further to the growing hostility toward management. The fact that management is unable to replace them on a short-term basis has given operators a coercive leverage in their dealings with management. The limited licensed operator staff has contributed to operator feelings of frustration about their future career options at Peach Bottom and to operator perceptions of lack of management control. M
5160h7 n Manifestations of attitudes have impacted negatively on Peach Bottom .O operations and extend well beyond selected operator personnel to include personnel at many levels throughout the Peach Bottom organization. During our interviews and observations, we identified many symptoms of attitudinal problems. The predominant attitudes identified throughout the Peach Bottom organization include: complacency, over-confidence, arrogance, disrespect, resistance and indifference to regulation, isolationism, and an us-versus-them mentality. These attitudes include those previously expressed as concerns of the NRC in the shutdown order, meetings, and letters to PECo. Effective resolution of these and additional attitudinal concerns that may be identified is one of the most difficult and important tasks facing PECo. Comprehensive attitudinal change of all involved personnel, including management, can provide the motivation for sustained behavioral changes which will lead to improved nuclear operations at Peach Bottom. n 3.2 LEADERSHIP AND MANAGEMENT ISSUES () PECo leadership and management issues cannot easily be separated from cultural and attitudinal concerns since they are so highly interdependent (i.e., manage-ment is usually a product of the organizational culture as well as the major influence on the culture). However, this section identifies specific leadership and management practices which have contributed to the events leading to the NRC shutdown. Electric Production Department (EPD) management had not adequately monitored management performance at Peach Bottom or taken timely action in the past to address ineffective management performance by making personnel changes, regularly assessing management performance and development needs, and ensuring that such needs were met in an appropriate and timely manner. Less than optimal performance by Peach Bottom plant management has been reported in the past by both regulatory and industry observers. There has been recognition by PECo management and non-management personnel of declining () plant performance at all levels. Although Electric Production Department level organizational and management changes were recently initiated to improve the
{- 5160h7 control of nuclear operations and to address Peach Bottom management problems, they did not result in sufficient managerial and attitudinal improvements at Peach Bottom to prevent the incidents which led to the shutdown of operations. Some Peach Bottom managers reported a lack of confidence in their own management skills in areas other than technical management. Many in the plant organization complained about the lack of people management skills demonstrated by most plant management personnel. Many Peach Bottom j managers stated they have not had regular face-to-face performance appraisals which would help to address these skill development needs during their tenure ; with the company. With the exception of a few individual. managers, it appears I that almost all managerial levels in the Nuclear Operations chain have not
^
conducted or received regular performance reviews focused on assessing and developing their managerial abilities. Coaching and feedback about performance have been mainly technical in content and is reported to be infrequent and a highly informal process. O No evidence was found at Peach Bottom to indicate that any regular formalized i system exists to survey or analyze management development needs and to ensure that all management personnel participate, on a timely basis, in training programs to address those needs. Whereas other departments within PECo appear to take more advantage through the Central Training Committee of available company management training programs, Nuclear Operations and Peach Bottom managers are likely to defer such training because of the time required for licensing, requalification, technical training, and the impact of personnel shortages and critical operational events on their workload. The Nuclear Operations /EPD and Peach Bottom management process used in developing and implementing plant performance and improvement programs, such as the Peach Bottom Enhancement Program (PBEP) and the upgrading of procedures, have not ensured: l e sufficient attention to analysis of root causes and development of programs which will prevent recurrence of the symptomatic problems . O f55E
3160h7 'g e adequate involvement of all levels of line management in analyzing, h developing, , integrating, implementation. coordinating and monitoring program e effective communication of the rationale and purposes of such programs to ensure employee understanding and commitment to successful outcomes. Many of the Peach Bottom employees interviewed were not aware of the PBEP 1 and could not describe its purposes or explain its origin. Those who were aware of it described it as the product of one individual and its content as some kind of beautification or clean-up effort. From these observations, we conclude that Nuclear Operations and Peach Bottom management have not done an adequate job of involving employees in the program or communicating the program goals to the employees. The procedures upgrade effort, which focuses on a one time improvement of the content of specific procedures, will not have a lasting corrective effect on procedural problems unless more attention is paid to the root cause of the problem itself. The Peach Bottom administrative management systems are not (]- sufficient to ensure accuracy, comprehensiveness, timely review, and updating of procedures on an ongoing basis by those responsible for executing the procedure. There has been a lack of understanding and clarity about delegated authority and accountability for plant operations at different levels of the Nuclear Operations management chain down to the Shift Superintendent. In the past, management authority roles have often been blurred by EPD and Peach Bottom management. Operational decisions regarding equipment repair, day-to-day work priorities, etc., have of ten been made by EPD management. Peach Bottom personnel reported that they were unable to get firm decisions from plant management on day-to-day work until approved by EPD management. Past requests for resources by Peach Bottom management appear to have been denied by EPD management without adequate rationale. Examples were given of Expense Authorizations (EAs) making multiple round trips between Peach Bottom and Philadelphia offices with increasing justification required, and then being denied without an explanation. Senior Peach Bottom management has O. eiso used the em81 8 eity to eemv thet< eccou tediiity for certete operetiomei eae personnel decisions telling lower levels of plant management / supervision that
5160h7 ,
"23rd Street" made or must make the decision. Most interviewees acknowledged U that the new Nuclear Operations organization has improved this situation by being less involved in such day-to-day decisions.
Key decisions about responses to regulatory and industry reports have continued to be made by Nuclear Operations and other department management without adequate Peach Bottom plant management involvement or concurrence. Commitments are made, and plant management is then expected to carry them out, often without sufficient consideration of the impact on plant resources or other work priorities. Nuclear Operations /EPD and Peach Bottom management have not used effective two-way communication processes to keep employees informed or to obtain and respond in a timely manner to employee input about organizational and operational concerns. Although formal written substantiation is often required in the nuclear power o industry, plant management appears to have relied heavily on written J communications, such as memos and notes, with subordinates. Examples of such memos reviewed were perfunctory, failed to cover important points or provide helpful rationale, and were ineffective as a means of communications to implement substantive organizational and policy changes. Operations shift personnel reported that when Nuclear Operations or Peach Bottom management attended shift meetings it was usually to read a letter from upper management or give a pro forma pep talk, without much attempt at genuine interaction or interest in employee response. Nuclear Operations and senior Peach Bottom management rarely attend back shift meetings. Peach Bottom plant management has not maintained control over organizational performance by communicating performance standards and providing adequate performance feedback to employees. l l Following the management performance evaluation precedent established in Nuclear Operations, Peach Bottom management / supervision also has not (a effectively implemented PECo's performance evaluation program by conducting
5160h7 e regular face-to-face performance reviews with employees and communicating k performance expectations directly and explicitly. Many Peach Bottom personnel knew that reviews were done on an annual basis, but they had never seen one of their reviews or received performance feedback in any formal manner from their supervisor. Some did not know if performance evaluations had been completed. A few could recall only one or two performance review meetings during their 5-to 10-year histories with the company. These meetings appear to have been conducted by the same shift superintendent. In day-to-day performance feedback, plant management did not respond in an appropriate and timely manner to serious breakdowns in respect for management authority on the part of many Operations personnel. This disrespect was demonstrated by operator personnel who refused to allow authorized personnel with legitimate business into the control room, and failed to follow appropriate operational orders from their supervisors. There is a serious lack of adequate first line supervision for Peach Bottom o ,d personnel which results in problems with work control and a lack of direction and monitoring of employee job performance. There are not enough supervisory positions designated for adequate span of control in some areas at Peach Bottom, particularly in the Health Physics area. Other supervisory positions in Operations are not fully staffed (e.g., Outside Supervisor), or are being held in abeyance pending determination of job classification (e.g., Floor Coordinator). In addition to not having sufficient numbers of supervisory positions in some areas, there is an overall concern about the supervisory skills of first line supervision. At Peach Bottom inadequate attention has been paid to establishing supervisory skills qualifications. Peach Bottom managers have not used performance evaluations or temporary assignments effectively to assess the supervisory capabilities of personnel in the upgraded positions. Promotions to Operations shift supervisory positions are based almost exclusively on candidates' seniority status and technical ability. There is no evidence of a systematic O O M
5160h7- approach to early assessment of' supervisory potential or provision of pre-O sug-vis-y treinins to identaied cendidetes pri- to their beins moved w upgraded positions. Personnel are scheduled to participate in the company supervisory training program efter being placed in upgraded or supervisory positions. However, nuclear superdsors interviewed stated that work demands have frequently prohibited their t imely participation in this core training program. Training records confirmed tbt the backlog for management and supervisory training is larger for Nuclear Operations than for other departments. Another factor contributing to the supervisory problems at Peach Bottom is that current personnel practices act as disincentives to pursuing the licensed operator progression to the supervisor level. Employees are concerned that there is no alternative to shift work throughout their careers as licensed operators; there are no lateral transfer opportunities and few promotional opportunities; and there is less nuclear differential pay for supervisors because differential compensation is computed on the basis of percentage of fixed monthly salary O rather than on the basis of percentage of actual hours worked, as in the case of non-exempt personnel. The Quality Assurance / Quality Control (QA/QC) Program, which is managed by separate organizational groups et Peach Bottom, has not been fully integrated into the plant operations and does not address personnel performance parameters. The role of quality assurance in day-to-day operations was examined within the context of the statement in the NRC order which said, "The Peach Bottom quality assurance program has failed to identify this condition which is adverse to safety." Management systems have not adequately incorporated the quality program into plant operations so that it would be in a position to assist in identifying and resolving problems. Nuclear Operations management has not assured that an appropriate level of operations expertise has been established in the QA/QC organization or fully 0' supported this separate QA function as a credible entity in the control room.
5160h7 Surveillance and monitoring are used by QA at Peach Bottom, but the imple- /_N t/ mentors do not appear to be sufficiently experienced or trained in various nuclear operations functions to use surveillance effectively as one of the tools for assuring quality operations. The function's integration into plant operations has been improving but QA/QC personnel are still not fully accepted as a part of the team, particularly by Operations which tolerates QA/QC because it was mandated to do so. The plant started operation when QA/QC was almost nonexistent as a separate function designed to provide additional assurance of a quality operation. It was therefore considered an unnecessary intrusion into the Operations routine. QA, from the operators perspective, was already being provided by technically competent operators and supervisors. With the two separate charters now in existence, gaps and overlaps in responsibilities are a potential problem. Several examples of overlap were stated. Adequate management systems are not in place to ensure accuracy, com-prehensiveness, timely review and updating of administrative and work U procedures. At the Peach Bottom plant, many concerns were expressed regarding accuracy and updating of procedures. These problems were quoted as a major reason or excuse for inadequate support of procedural compliance historically. Although there have been improvements in the content of some work procedure areas and in the temporary procedure change process, there still are not adequate mechanisms in place to integrate and control temporary procedure changes into the permanent procedure program. There ,are no administrative controls on the life of a temporary change. They do not expire if not made into a permanent change. i Approximately 15 percent of all procedures are on a centralized computer, but most appear to be manually typewritten for changes and rewrites. The periodic review requirement for Peach Bottom $rocedures is five years, compared to a nominal industry norm of two years. No systematic method of flagging needed fs procedure changes was found. There also appears to be no requirement to ! U i l
5160h7 annotate or track prior commitments incorporated into a procedure during O subsequent updates or changes. The matrix management strw ture does work within PECo, but it has not been working well at Peach Bottom. Many Peach Bottom employees and management personnel appear to use the matrix system as an excuse for lack of performance. The project-type team, necessary for effectiveness in a matrix system, has not been developed at Peach Bottom where the matrixed functions appear to work to their own priorities instead of the team's, and relationships are frequently adversarial between Operations and some of the support groups. A Limerick site team led by the plant manager at Limerick has been much more successful in implementing the same structure under similar conditions. r The matrix can be an effective arrangement when similar functional activities are performed at several sites. It provides flexibility and efficient use of resources, but requires careful management of the workplace, effective G- teamwork and definition of interface responsibilities. Several years ago PECo V EPD produced a comprehensive set of vice presidential policy documents. This set of 50 plus documents was intended to establish a single way of doing business for all of EPD (including Peach Bottom and Limerick) and defined EPD's interface responsibilities with other PECo organizations. The documents were distributed for limited trial use, but there did not appear to be a concerted effort to monitor their effectiveness and formalization for permanent use. The procedures were distributed for wider use prior to the last corporate evaluation. Thirty-three of approximately fifty-eight titles were issued for official use between April and October 1986. Seventeen are still in the trial use category, and five are in the deferred category, leaving over one-third of the organizational policy areas still not formalized vand thus, open to individual interpretations. (
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s I
3160h7 3.3 PERSONNEL POLICIES: NUCLEAR OPERATIONS APPLICATION AND O' IMPLEMENTATION The application of some personnel policies in Nuclear Operations and the implementation of personnel policies by Nuclear Operations and Peach Bottom management base had negative impacts on Peach Bottom operations, in terms of: e limiting the available supply of licensed operator and other technical resources. e restricting the effective utilization of Nuclear Operations personnel. e imposing perceived limits to management control over disciplinary concerns. e reducing line management's involvement with, and responsiveness to, employee personnel concerns. Past EPD human resource planning practices and strict adherence to the company entry-level hiring policy has contributed to a shortage of licensed operators and shortages of other Nuclear Operations personnel. All Peach Bottom licensed operators have been hired as entry level helpers and n U progressed through the non-licensed operator ranks before becoming licensed. A recent exception to this practice was the hiring of 12 Navy nuclear operators who were brought in at F. job level above the normal helper entry level in 1986. The progression from entry level helper to the point where an individual can begin licensed training takes approximately five years. As a result of tria long pipeline for licensed operators / senior licensed operators development, individual personnel actions (transfers, resignations, and retirements) over the last ten years, and increases in licensed staff requirements, there are insufficient licensed operators to fully staff a six-shift rotation in all positions and simultaneously to provide necessary licensed operator support for other shift activities such as processing permits and Maintenance Request Forms (MRFs). This shortfall in shift coverage has resulted in significant amounts of overtime being worked by licensed operators, including unexpected overtime when the i relieving shift operator does not show up. Many reactor operators (ROs) expressed concern about the impact of the unplanned overtime on their personal lives and acknowledged that this overtime work requirement contributed to their negative attitudes. Although the overtime wor %ed appears to be within O prescribed safety limits, some ROs stated that the amount of overtime worked at
m u - m j x to 5160h7 ,( ' , . f, .e . s p \. ; some points in the past had a negative impect on their ability to sustain high
~
'e performance levels. .-
. Without full rix shift coverage, there hay been minimal meitoring and follow-up for the on-the-job-training qualification process for trainees following their e completion .of, the classroom training phase.
The limited pipeline of licensed operators has also resulted in licensed operators not being allowed to bid out to other jobs. Except under extenuating circum- ; stances, no lateral transfers have been permitted for licensed personnel into Training, Outage Pbnning, QA, and other functional areas in which operations-experienced raersonnel are needed. This situation has demotivating impacts on both licensed and non-licensed personnel. The entry level hiring policy and the base level staffing philosophy of PECo have re:uited in other shortaget of Nuclear Operations personnel, in addition to lice:ue'd operators. Many Peach Bottom supervisory personnel interviewed ccmmented en the need to hse outside contractors to meet the increased base workicad demands. _ ; 1 Job qualification requirements and the lack of alternative career paths have severely restricted the mosd$ffective utilization of Peach Bottom operations
, e ~
personnel. In some inswx:es. tlwy have served as disincentives to pursuing the
.!icensbd operator career progr'ession. 1
~
r hJob y'utlif!cetion ., criteria are not always well matched to job performance requirements,. particularly with respect to the requirement that all candidates for imployment M promotion in certain job classifications must hold an engineering degrde., TMs prevents cperations-experienced personnel without i engineering degrees from moving into some positions in operations supervision / management, cutage planning, maintenance / construction coordination, ALARA, and other areatiwhere nuclear operations experience and perspectives are needed. Nuclear Operations practices and Independent Group Association (IGA) resistance
-Q have thus far also prevented utilizing licensed engineers on shift in a line role as i ',
l
5160h7 supervisors or superi; tendents. The PECo fossil / hydro philosophy that operators [ h operate and engineers engineer has created this invisible wall which has restricted the flexil,ility of using engineers on shift and further restricted ! opportunities for operators to move into management / individual contributor j
\
roles. 1 I I The lack of alternative career paths for operator personnel has also resulted in
" frozen" senior plant operators (i.e., those who have not passed the licensing exam or have chosen not to pursue licensing qualification). These frozen senior plant operators occupy a large number of plant operator (PO) positions. This makes it difficult for newly qualified POs to become fully experienced in the PO position since they work as an assistant plant operator (APO) except or, a daily upgrade basis until a permanent position becomes available. PO qualified APOs therefore can progress to RO positions without the benefit of cornprehensive I floor operations experience to help them function more effectively in the control room.
Peach Bottom management has not assumed accountability and adequate decision mrking authority to resolve disciplinary problems and employee concerns. The J lack of clearly defined management guidelines with respect to implementation of disciplinary guidelines and the grievance process contribute to this problem. There is a widespread perception among Peach Bottom management and supervisory personnel that they are powerless to take prompt and appropriate disciplinary action in cases where it is warranted. This perception is based on a number of factors:
~
e Generalizations have been made by Peach Bottom management about the lack of support for management disciplinary actions by the Personnel and Industrial Relations Department based on exceptional incidents in the past. e There is a lack of written guidelines for management about how to implement disciplinary policy effectively. s e Fewer nuclear supervisors than other department supervisors have i participated in management training programs where these issues are l addressed. l 1 e Current applications of the PECo's disciplinary guidelines do not consistently g support professional nuclear performance standards (e.g., ignoring the proper directives of a supervisor is defined as a serious infraction, but first-time s
5160h7 occurrence is disciplined by a written reprimand as opposed to a more severe Q action; refusing to obey a proper directive in a nuclear control room is viewed as a very serious performance issue within the nuclear industry). e The company's discipline process is not well defined in You and Your Company and is often a very time consuming process extending over months; yet the company's policy is to hold suspensions in abeyance when employees appeal the suspension. (Although there has only been one such case involving Peach Bottom, it is common for management to generalize about the lack of support for discipline from singular incidents.) Another contributing factor to disciplinary concerns at Peach Bottom is that management has not applied the work rules and disciplinary guidelines in a consistent, equitable manner. Examples from interviews included not disciplining non-compliance with procedures, differences in disciplinary actions related to misuse of the company's sick day policy, inconsistency in applying overtime work rules, and contradictions in management memos attempting to clarify work rules. The employee complaint (pre-grievance) process is worked informally (i.e., no written documentation required) up through three successive supervisory levels to the employing officer (plant manager). The lack of documentation makes it k more difficult to hold managers accountable for the proper execution of their responsibilities in this regard. If an employee still does not feel that the complaint has been adequately addressed by the employing officer, he or she can file a grievance through the IGA with the Vice President, Personnel and Industrial Relations. The Vice President, Personnel and Industrial Relations forwards a copy of the grievance to the vice president of the involved department who then investigates the grievance and gives input back to the Vice President, Personnel and Industrial Relations. The Vice President, Personnel and Industrial Relations then prepares a response to the grievance, discusses the response with the involved department (usually with the vice president) and, when agreement is reached, sends the grievance response to the President of the IGA. This process relies heavily on communications at the vice president level and does not appear to adequately involve line managers at the plant level when the grievance involves supervisory l actions or inactions. O Giiiii , l
5160h7 Peach Bottom management tends to rely too heavily on the IGA to identify and 'h resolve employee concerns. This has resulted in a lack of management involvement in and responsiveres to personnel matters. The process used by the IGA in soliciting and reporting employee input with respect to personnel concerns is impressive. Peach Bottom management has neglected some of its responsibilities for developing and improving employee relations by not playing a more proactive role in this area. Minimal management involvement and responsi.veness in identifying and addressing personnel matters contributes significantly to the perception of many Peach Bottom employees that management does not care about their concerns or recommendations. It has been widely recognized throughout the industry that company personnel policies must sometimes be adapted to meet nuclear safety and regulatory requirements. At Peach Bottom there is no nuclear personnel specialist reporting to the plant manager to assist with interpretations and application of current personnel policies or to represent the special needs of Nuclear Operations to corporate personnel management when policy changes or exceptions are required. 3.4 EXTERNAL RELATIONSHIPS Repetitive patterns of performance findings since 1981 demonstrate poor performance by management at all levels with respect to adequate root cause analysis and effective corrective actions. A review of PECo relations with the NRC and other external reviewing organizations over the past several years provides extensive insight into the significance of the growing problems at Peach Bottom. This review indicates that management at all levels was not aware of or did not sufficiently understand how the post-TMI regulatory environment and changing industry . standards were affecting Peach Bottom personnel performance. PECo's formal responses to regulatory and industry assessments were not effective in solving long-standing personnel performance problems. Since 1981, NRC/INPO reviews have identified significant findings of a repetitive nature in the following areas: O Hiiiii !
5160h7 a ten findings regarding lack of procedure adherence. O- e four findings in Radiological Control. e three findings in Emergency Preparedness. Since 1983, NRC enforcement actions have been increasingly severe since 1983. Although there were some recent positive indications, deficiencies continued to be identified in NRC and INPO findings. The misperception of the severity of NRC concerns in correspondence and in meetings over the past year, along with the continued display of defensiveness in responses to NRC and INPO findings at Peach Bottom, have contributed to diminished credibility with the regulatory and industry reviewers. Electric Production management has not ensured adequate involvement of all levels of the organization in developing and carrying out commitments. Interviews at the corporate and site levels indicate that in some cases appropriate line and staff members are not involved in problem analysis and O deveiogmeet of corrective ection resgenses. in other ceses, when ther ere esked to provide input it is not always utilized in the company's response, and the reason for deleting the input is not communicated back to the authors. In either case, Peach Bottom management and other key personnel feel less ownership and responsibility to implement commitments made to regulators. This has also impeded the effectiveness of corrective action programs. The total and cumulative resource requirements have not been adequately considered when the company commits to new programs and other corrective actions. The management philosophy often appears to be that the existing resources should just work harder to accomplish corrective action programs, no matter how comprehensive they are. Until the recent establishment of the Quality Assurance Tracking and Trending System (QATTS), there was no single corporate-wide source for commitment listing and tracking, which made it difficult for any management level to understand the full impact of cumulative commitments involved. QATTS is not yet widely implemented or resource loaded fisiE
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5160h7 and thus does not yet provide the required management control in this important A area. This has caused frustration for all organizations involved in tracking and implementing commitments. Nuclear Operations and Peach Bottom management were not effective in addressing the increasingly negative attitude of the plant staff toward the changing regulatory environment and the impact of this attitude on Peach Bottom relationships with the NRC, INPO and ANI. Most senior operations-experienced employees have been working at Peach Bottom since before the TMI-2 accident and have, for the most part, maintained a negative attitude toward post-TMI regulatory requirements and clarifications. There was apparent disregard for NRC Circular 81-02 dated February 9,1981, which reinforced NRC's position regarding the meaning of 10CFR50.54(k) as it relates to licensed operator conduct in the controi room. This was re-emphasized to the Peach Bottom licensed operators on June 20,1985 in a letter from the Peach Bottom plant manager after the June 10,1985 incident regarding Q an inattentive operator. However, this management by memo effort appears to have had little or no effect on operator attitudes regarding control room behavior. Some operators have the wrong opinion that they are there to back up the safety systems. Sitting back in the chair with their feet up in an apparent inattentive mode, therefore, was not considered to be wrong because the plant was on automatic.
4.0 CONCLUSION
S There are fcur primary root causes identified as the major contributors to issues and events at Peach Bottom which led to the shutdown order. They are: o Poor leadership by management at Peach Bottom. e Failure to initiate an aggressive operator training program to provide a sufficient number of licensed operators in a timely manner. e A transplanted PECo fossil station organization, concept of shift operation, shift structure, and the PECo fossil way of doing business. Peach Bottom management did not perceive the need, or take sufficient action, to adapt these to the current nuclear operating environment. I E
5160h7 e The slowness of corporate management, above the Peach Bottom plant level, O to recosatze the severity or the root causes describee ebove ema to tasist oa stronger, more timely and appropriate corrective actions. Indicators of poor lea'dership at Peach Bottom and the slowness of department management's response include: e Ineffective implementation of the Company's performance evaluation program, with most Peach Bottom and Nuclear Operations managers not conducting face-to-face annual reviews e Improvement programs which addressed symptoms rather than root'causes-did not involve appropriate line management levels, and were not communicated effectively to ensure employee commitment to success e Poor understanding by Peach Bottom management' of their authority and accountability e Poor two-way communication between Nuclear Operations / Peach Bottom management and employees e Poor first-line supervision training and inadequate numbers for proper span of control e QA/QC programs not fully integrated into operations 9 fnadequate management systems for proper procedure update and control e Ineffective implementation of matrix management teamwork e Inconsistent implementation of disciplinary policy e Management over-reliance on the IGA to respond to employee concerns Resolution of these problems depends upon: e Increased management awareness of the root cause influences e Management's willingness, ability, and leadership to change root cause influence where possible, or to address the negative impacts when the influence cannot be changed j e Management's application of resources to correct the current acute problems These root causes, which have a combined and interrelated effect, are embedded in and nurtured by the traditional PECo culture. Some of the same cultural O charac: eristics which produced operational excellence in the early years at Peach Bottom became contributing influences to the primary root causes, I t l E
5160h7 resulting in its shutdown. Examples of the ways in which these cultural O cherecteristics produced both positive end ne8etive effects inciude: e Entry level hiring practices which produced loyal, dedicated, well trained employees during the first five years of operation have also contributed to a shortage of licensed operators, minimal shift staffing flexibility, inability to use operations experienced people in other functional areas, and resulted in operators who feel trapped, distrustful, and have negative attitudes. e An orientation toward hiring and promoting engineers, which produced a highly professional and technical staff for entry into the nuclear power business, also contributed to a reduced awareness of people performance problems and people management solutions. e Long-term management and staff assignments that created a protective
" insulating bubble" around the team during start-up and early years of operation subsequently created an " isolating bubble" around the operations team which obscured from upper management's view the negative influence of fossil / hydro operating practices, poor plant management performance, and provided a shield resistant to regulatory change.
e Personnel policies and practices, which had been carefully constructed over the last half century, and which have produced a satisfactory relationship with the PECo Employee Independent Group Association (IGA) and a stable personnel resource environment, contributed to resistance to rapidly changing nuclear operations personnel requirements. O e PECo's pride in pioneering and achievement in nuclear operations produced leadership in the nuclear utility industry and regulatory technical standards development. Later that pride also contributed to protectionism and defensiveness to criticism of their more recent performance and to questioning of the changes to regulatory standards. Limerick is a newer plant still in its early operation phase, a condition similar to Peach Bottom's " insulating bubble" of the early years. It has had some of the advantages inherent in start-up organizations over steady-state organizations (e.g., more resources supplied, more flexibility with respect to policy implementation) as well as the benefit of an effective plant management team. Over time, however, there is the potential for some of the same Peach Bottom l attitudinal problems to develop 't Limerick if management does not take an l aggressive stance in recognizing the need for substantive change in its management philosophy and approach to nuclear operations. There are many appropriate and effective short-term actions which PECo should take to address the problems cited by the NRC and get Peach Bottom back on line. However, to ensure that problems do not recur at Peach Bottom and to f5Ere
3160h7 i prevent their occurrence in the future at Limerick, there is a need for in-depth, h long-term changes. The recommendations in the following section are a combination of short- and long-term actions to produce these changes. 5.0 RECOMMENDATIONS The recommendations have been grouped in the same manner as the root causes in the areas of: o Cultural tr$ attitudinal influences e Leadership and management issues i e Personnel policies: Nuclear Operations applications and implementation e External relationships Additionally, a number of recommendations for the action plan process have been made at the end of this section. g it is important to note that at this time no effort has been made to prioritize the recommendations made in this report. It is expected that in preparing the action plan to respond to the NRC shutdown order, PECo will combine these recommendations with the recommendations of others and develop an integrated priority system to ensure that all recommendations are addressed in a coherent and logical manner. It is not intended, nor is it implied, that all of the recommendations in this report must be completed prior to restarting either unit at Peach Bottom. The recommendations themselves fall into two general categories. First, those that deal with the acute problems that are the result of the pressure of long-term root causes and require direct action. Second, those that deal with the longer term chronic root cause problems to prevent reoccurrence of problems at Peach Bottom and potential manifestation of these problems at Limerick. The impact and visibility of the shorter term actions appear to overwhelm the more difficult longer term solutions; however, it is essential that PECo make g plans now for accomplishing the more broad based changes in organizational attitudes, leadership and management practices, policy implementation, and
5160h7 external relationships so that Peach Bottom's recovery efforts are sustained over d time. 3.1 CULTURE AND ATTITUDINAL INFLUENCES Attitudinal change is a difficult undertaking since attitudes are a key element of , the complex entity known as " organizational culture." If the attitudinal problem l l resides in only a small group of individuals, it can be addressed through a strategy of attitudinal assessment, counseling and training of each individual. l When attitudinal change is needed on a large scale, as is the case with Peach Bottom nuclear operations, this strategy is not sufficient. The change in Peach Bottom plant management which has resulted in the establishment of a new managerial perspective on site will contribute significantly to a broader scale attitudinal change among Peach Bottom management and employees, at least in the short term. However, to ensure long-term attitudinal change, additional l steps must be taken. Psychological research about attitudinal change in organizations indicates that a O v disciplinary approach (i.e., management enforcement of new behavior) is not as effective or as quick to produce results as a participatory approach (i.e., providing opportunities for employees to identify work-related problems which have negative influence on their attitudes and to recommend appropriate solu-tions to those problems). MAC recommends that PECo implement a broad scale attitudinal change effort with one aspect focused specifically at the Peach Bottom site and another aspect focused on corporate / Peach Bottom site transactions.
- 1. Complete an organizational survey at Peach Bottom using an accepted instrument which identifies employee attitudinal issues, as well as work productivity and quality concerns, followed up by a well-managed employee involvement program which uses the results of the survey in an organized manner. This should be accomplished work group by work group. An example of this kind of program is the Employee involvement Program instituted at Rancho Seco by the Sacramento Municipal Utility District.
- 2. Initiate a team development process from the President down to shift management which involves Nuclear Operations, Engineering and Research, Electric Production, and other corporate organizations which support Peach
,S Bottom. Include in this process:
L)
5160h7 e Commitment to excellence from the President down to and including (T each level of management v e Clarification of roles, accountabilities and authorities at each management level with respect to nuclear organizational and plant performance e Improvement of communication processes both vertically and hori-zontally within management chains and between corporate line management and employees e Identification of management processes to be used to ensure integrated planning and implementation of operational goals, including how prior-ities will be established or changed, and how work-related conflicts will be resolved e Coaching in how to ask for and give honest, effective management performance feedback e Resolution of inter-departmental conflicts related to work flow man-agement, lack of responsiveness, or support between work groups The process could be implemented in a phased manner, starting with senior corporate management, progressing to the corporate / senior plant manage-ment level, and then to plant management, with appropriate levels of top and middle management involvement in the process as it cascades down (~3 through the organization. v j Implementation of these recommendations requires careful planning and ! facilitation, usually with external assistance, to be effective.
- 3. Establish a comprehensive operator retraining program to address at least the following areas:
e The impact of the traditional PECo culture and Peach Bottom sub-culture to ensure that all participants understand and are committed to the attitudinal requirements for safe nuclear plant operation e Operator behavior which is consistent with the requirements of 10CFR50.54K e Emphasis that the operator's responsibility is to proactively operate the plant and that safety systems are in place to back up the operator
- e Strict adherence to all plant and operational procedures l
l e Operator responsiveness to, and positive attitude toward, the levels of detail and attention required for safe, professional control room operations, e.g., exception reporting, systems monitoring, etc. i
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i ) pd ! 1 l
'5160h7 e Effective communications, . teamwork, and ability to manage the Q interpersonal processes involved in control room operations e Understanding and acceptance of all of the roles in the safe and efficient operation of a nuclear generating station, e.g., Operations, QA/QC, Health Physics, Maintenance, etc.
5.2 LEADERSHIP AND MANAGEMENT ISSUES PECO's efforts at broad-scale attitudinal change in Nuclear Operations cannot be successful without careful realignment of management philosophy and practices and organizational structures to support the goals of the change effort. The infusion of new managerial perspectives and nuclear talent into the Nuclear Operations organization will also support this effort. MAC recommends the following:
- 1. Replacement of Peach Bottom Plant Manager, Operations Superintendent and Operations Engineer is supported. The impact of the loss of cumulative Peach Bottom-specific experience currently represented in these positions must be taken into account in replacing personnel, making any future i organizational changes, and retaining these personnel in contributing staff positions.
- 2. Assess the adequacy and effectiveness of the current Peach Bottom shift organization, supervision, and staffing with consideration given to: ;
e Strengthening management presence on shift by establishing the shift manager concept. e Implementing a day shift supervisor concept (general supervisor of operators or operator support). e Adding another licensed operator (LO) in the control room. e Providing back bp relief capability for control room supervision. e Redefining the outside shift supervisor responsibilities to strengthen and include direct supervision of outside tasks and relief of the control room shif t supervisor. e Assigning senior licensed operator (SLO) qualified engineers to sele % supervisor /superintentendent positions for hands on experience, training for future management positions, and removal of the " wall." o Completing the ongoing study of shift rotation at Limerick with involvement and participation of Peach Bottom operators and supervision. Give due consideration of alternatives to current Peach O Bottom shif t rotetioa scheduies beeed on this stuex. siiii
5160h7 3. Increase direct supervision by ensuring sufficient numbers of supervisory A positions to effectively supervise and direct activities. Expeditiously fill V vacant supervisory positions where clear need exists.
- 4. Establish a Nuclear Personnel Specialist positioa at the nuclear reporting to the plant manager, with adequate experienceadvise to: (1) all plant site, levels of plant management on personnel policy matters and employee relations; and-(2) represent the special needs of Nuclear Operations to corporate personnel management when policy changes or exceptions are required.
- 5. Reduce' one management layer, and strengthen the organizational changes made in establishing the Vice President, Nuclear Operations position by having plant managers report directly. Add strong direct support staff for that position.
- 6. Establish and/or clarify specific accountabilities and authority levels for each management and supervisory level in Nuclear Operations. This should be done as part of the team development process recommended in Section 5.1, Cultural and Attitudinal Influences. Hold managers and supervisors accountable for appropriate exercise of responsibility and authority.
- 7. Refine the role and authority of QA/QC, particularly as it relates to surveillance and audits for verification of technical and performance based activities. Take into account current NRC and INPO philosophy in this area. Assure that an appropriate level of ex (Operations, r- Instrumentation and Controls, Health Physics, etc.)pertise is available in the QA/QC organization.
e Consider grouping all Operations, Maintenance and Construction QA/QC functions under one manager reporting to the Senior Vice President, Engineering and Production. e Communicate and support the further integration of QA's role throughout the organization. e Establish a quality deficiency reporting program which addresses each issue reported to it from any source. e Require plant management and shift management to include the QA function as an integral part of all operational work planning, decision-making and problem-solving processes. Hold meetings between QA management and personnel and management and personnel from Operations, Maintenance, H.P., Technical Engineering, I&C, Testing & Laboratories, Chemistry, Construction, Rad Waste Management and other relevant functions to discuss QA's role in their work activities and address any related concerns.
- l. 8. Establish an administrative management system for procedures to ensure i
accuracy, comprehensiveness, timely review and updating of corporate, l plant, and operational procedures which includes the following: O e Complete the implementation process for developing, formalizing and distributing Nuclear Operations Requirements and Guidelines. C____________________
5160h7 e Input all plant procedures into a common automated data base to assure () efficiency and accuracy when typing plant procedure changes. e Establish a two-year review cycle for department procedures as opposed to the current five-year cycle; provide additional resources as needed to l complete such reviews. i e Establish an automatic expiration date for temporary procedure changes to ensure comprehensive review before the change becomes permanent. e Consider alternatives to the use of the full PORC committee for review of all procedural changes in order to decrease the backlog on procedure revisions and allow the PORC to focus on additional matters related to plant operations. l e Establish a written process for flagging needed procedural changes to l management's attention. e Ensure more effective use of the references section of procedures to l keep track of previous commitments during subsequent procedure updates.
- 9. Assure that the QATTS system is appropriately resource loaded and )
integrated into all aspects of nuclear operations so that commitments may be tracked effectively. 3 10. Develop and implement a comprehensive management / supervisory leadership (d irnprovement program for Nuclear Operations including: e Evaluation of supervisory leadership skills needs at all levels from first line (including " lead" or other defacto supervisor levels) up to manage-ment. e Development and implementation of training programs to address identified needs with careful attention paid to the skills required at each level of management / supervision in the organization so that the i skills targeted for development at each level build on those achieved at previous levels. In scheduling training modules, particular attention should be paid to the most effective means of making the training accessible to all Nuclear Operations supervisory personnel (e.g., offering short training modules on-site at a variety of times). e Provision of more supervisory training opportunities for non-supervisory personnel who have been identified as having supervisory potential; emphasize the importance of such training in consideration of candi-dates for supervisory openings. e Additional emphasis on a supervisory / leadership curriculum in the S1.0 training program. Make supervisory capability evaluation a mandatory element in selecting candidates for training and SLO qualification. C) v
5160h7 e Emphasis in management training programs on how to coach and support h subordinate levels of supervisors, including; identification of their training needs, on-the-job coaching, and assessment of training program effectiveness, by observing behavior on the job following such programs. Institute a process to ensure that training program management receives regular input from plant management at different levels about supervisory training needs and the effectiveness of training programs. e Inclusion in training programs of the rationale for personnel policies and how to implement them effectively, especially in areas such as employee performance evaluation and discipline. e For upper level management, exposure through seminar format to notable management experts and practitioners and successful nuclear utility managers. I1. Consider establishment of a rotational management assignment process so that key Nuclear Operations and Peach Bottom managerial personnel are exposed to the functional realities of dif ferent departments within PECo and thus acquire a broader base of experience and do not become isolated at a plant location for extended periods of time.
- 12. Require all levels of Peach Bottom management and supervision to conduct formal face-to-face performance reviews with their direct reports on an annual basis as a minimum. To ensure the effectiveness of these performance reviews, participation in performance appraisal training g sessions should be required for all management and supervisory personnel.
The Nuclear Personnel Specialist should monitor the quality of written performance reviews, and initiate or recommend necessary actions for improvement as required. 5.3 PERSONNEL POLICIES: NUCLEAR OPERATIONS APPLICATION AND IMPLEMENTATION PECo has always emphasized company-wide uniformity of personnel policies, which is, basically, a sound management philosophy. The task facing corporate management is to become more aware of the special requirements involved in managing its nuclear business. In some cases, personnel policies will require modifications and/or different applications to address Nuclear Operations needs. Nuclear Operations management must also monitor and ensure more effective implementation of personnel policies by Peach Bottom managers and supervisors. MAC recommends the following:
- 1. Initiate an aggressive recruiting program to bring in technically qualified
$ personnel, including licensed operator candidates, at other than entry levels (i.e., at levels appropriate to their qualifications and experience and
3160h7 comparable to the levels at which they would be hired in at other nuclear h plants).
- 2. Design and implement required training programs for new licensed operator candidates over the next 12-15 months to supplement available licensed operator resources. Consider vendor training personnel for this purpose if required.
- 3. Design and implement an immediate training program to prepare SLO 3
licensed engineers for shif t positions.
- 4. Consider non-degreed licensed operators for promotion to positions in operations management, outage planning, QA training and other functional areas on the basis of merit.
- 5. Establish alternative career paths in the immediate future for senior non-licensed operators so that they can be more fully utilized in positions such as floor coordinator and training instructor.
- 6. Conduct a survey to identify those personnel practices, e.g., no way off shift; no lateral transfers; amount of nuclear differential pay, which serve as major disincentives for personnel to pursue the nuclear operator job progression up through supervisory levels. Use a task force approach (with representation from licensed and non-licensed operator personnel, the Personnel Department and the IGA) to make recommendations to management about how these disincentives could be addressed.
O 7. Ensure that definitions of various levels of infractions and corresponding disciplinary actions in the disciplinary guidelines are congruent with nuclear performance standards; if necessary, identify special applications and/or interpretations of the policy to meet Nuclear Operations needs.
- 8. Permit plant managers to suspend employees for reasonable cause at the time of the infraction, even when the suspension is appealed by the employee, rather than holding such suspensions in abeyance until the appeals process has been completed.
- 9. When grievances involve individual employee disciplinary action, process these grievances formally up through successive supervisory levels documenting each step. The employing officer and the Vice President, Nuclear Operations should meet together with appropriate Personnel Department and IGA representatives to resolve the grievance, with the Vice President, Nuclear Operations having ultimate line management decision-making authority with respect to disciplinary actions. The role of Personnel and Industrial Relations Department management should be reserved to serve as an appeals source only in those cases where the grievance solution is appealed by the IGA.
- 10. Streamline the grievance resubmittal/ appeals process to ensure timely responsiveness and resolution.
- 11. Establish written guidelines for managers and supervisors on management O responsibilities and authorities for implementing the company's Disciplinary Guidelines.
( 5160h7 , 1 l l
- 12. Mandate special training sesshns for all Nuclear Operations management and supervisory personnel to ensure their understanding and consistent (L ') implementation of disciplinary policies, the grievance process and work rules.
- 13. Build into the Peach Bottom employee involvement program an ongoing process for management to solicit and respond to employee concerns and suggestions.
3.4 EXTERNAL RELATIONSHIPS PECo management must demonstrate to the NRC its awareness of the serious-ness of the root cause issues which led to the shutdown of Peach Bottom as well as its sincere dedication to a change in management philosophy and approach at all levels with respect to its nuclear operations. This awareness and dedication forms the keystone for an acceptable action plan. In addition, management must assure that the appropriate processes are i1 place to maintain open and effective ongoing relationships with its regulators and industry auditors. MAC recommends the following:
- 1. Evaluate and correct the management practices which have resulted in (l ineffective relationships with the NRC regarding the concerns at Peach d Bottom. The evaluation should pay close attention to the successful program established at Limerick and at other utilities.
- 2. Review commitments made since 1983 to the NRC/INPO/ANI, etc. for desired results to ensure that corrective actions taken were appropriate and are achieving the desired results. Include in this review any subsequent actions taken in the recovery plan.
- 3. Reinforce internal monitoring of nuclear plant performance (NRB, ISEG, PORC) by ensuring that specific responsibility has beer. assigned to evaluate, analyze, characterize and trend performance indicators from external sources (NRC, INPO, ANI, etc.). Conduct periodic meetings with senior management (corporate and plant) to review results and provide recom-mendations to address problems, or potential problems.
- 4. Assure that future commitments / responses are based on:
e sound, thorough analysis with explicit consideration regarding reactor safety, not just compliance. e consideration of current regulatory philosophy, recognized problems at other facilities, and the NRC's viewpoint. e emphasis on the role of personnel and personal actions to nuclear safety. p)3 L 5
3160h7 i e realistic schedules based on safety significance and available resources O 1 wita ePropriete moaitories or miiestomes e#e of o#8eins pro 8ress to assure desired results are achieved. 5.5 ACliON PLAN PROCESS l It is also critically important that PECo management pay as much attention to l the use of effective management processes in developing and implementing the Peach Bottom recovery plan as they do to the content of the plan itself. These ! processes must be thoughtfully applied if PECo management is to assure itself that the recovery plan will result in operational excellence and will assure the l NRC both of the company's awareness of the need to change and its sincere commitment to making the change happen. MAC recommends the following with respect to developing and implementing an l effective Peach Bottom recovery plan:
- 1. Provide full-time leadership, management, and attention to detail to suc- ,
cessfully plan and execute the recovery plan. This will require additional staff dedicated to this project to ensure the least disruptive impact on l normal, ongoing operations of Peach Bottom outages and Limerick ! operations and outages.
- 2. Integrate ongoing improvement plans into the recovery plan in order to assess the total resource requirements and commitments. These plans should include the significant plant improvement projects, the PBEP, and l
improvements with respect to administrative management ar.d work control i systems (e.g., procedures, Radiation Work Permit (RWP) system automation, exposure records, nuclear records). Assign responsibilities and incorporate a system for measuring results which involves both Peach Bottom and Nuclear Operations management.
- 3. Provide overview of the recovery plan independent of line management, to monitor and to assess program effectiveness.
O Hiiiii
O APPENDIX A INTERVIEWED PERSONNEL O l O ) Y l
5160h7- A-1 PERSONNEL INTERVIEWED .O NAME TITLE OR POSITION W. Alden ' Licensing, Engineer in Charge M. Alderfer- STA E. Allwood Shitt Superintendent C. Anderson Branch Engineer
- 3. W. Austin Construction Superintendent
- 3. H. Austin, Jr. President
- 3. Baldwin ACO
- 3. Ballantyne CO B. Barnshaw Shift Superintendent - Limerick R. Betz Electrical Supervisor
- 3. Birney, Director Nuclear Records
- D. Blasy Shif t Superintendent !
M. Brown APO
- 3. Budzynski Reactor Engineer (Supervisory) g B. Bulmer T. Cabrey NTS Superintendent - Limerick Former STA "
B. Carr STA W. Casey Superintendent, Station Maintenance Division M. Cassada Director, Radiation Protection A. Clark Shif t Supervisor B. Clark Director Administration
- 3. Clupp !&C Engineer (Supervisory)
E. Collins GE Shif t Eningeer 3.Cooney Manager, Support Services R. Costagliola Superintendent, Nuclear Station Section
- 3. Cotton Director Plant Services P. Cromwell CO E. Cromwell Shift Supervisor
{ ' J. Davenport Supervisor, Engineering Maintenance P. Davidson Computer Applications, Engineer in Charge C. Dawson Senior Engineer, Maintenance , Q 3. Deni CO IHiiii
5160h7 A-2 PERSONNEL INTERVIEWED (Continued) NAME TITLE OR POSITION J. Doering Operations Manager - Limerick T. Donnell QA Supervisor D. Duane Shif t Supervisor W. Eagles CO J. Everett Chairman and CEO D. Falcone CO D. Felts APO D. Fleischmann Station Manager J. Franz Plant Manager - Limerick C. Fritz VP, Personnel and Industrial Relations A. Fulvio T. chnical Engineer J. Gallagher VP, Nuclear Operations N. Gazda Physicist, ALARA (Supervisory) G. Geiirich Test Engineer T. Geyer Engineering Maintenance (Former STA) B. Gleaves Radwaste Supervisor M. Gribble ACO S. Grosh Former IGA Committeeman D. Harrington Shift Typist R. Hart ACO
- 3. Hesler Former STA B. Hinkle Superintendent, Maintenance Services Section R. Hoopes Shif t Supervisor L. Hopkins Operations Engineer - Limerick J. Hufnagel . Assistant Outage Engineer G. Hunger Nuclear Safety Engineer K. Iepson Former STA
- 3. Jordan Results Engineer (Supervisory)
R. Kankus Director, Emergency Preparedness D. Kauf fman PO D. Keene I&C Engineer Q D. Kemper Maintenance Area Supervisor : Ei5ii l 1 - - - - - -
5160h7 A-3
,s PERSONNEL INTERVIEWED (Continued) b NAME TITLE OR POSITIOff J. Kemper Sr. VP, Engineering and Production C. Kerr STA R. Kirkhof f ACO W. Knapp Director, Radiation Protec+. ion C. Koehler Shift Supervisor E. Kohler Staff Engineer
- 3. Kovalchick STA S. Kowalski VP, Engineering & Research 3.Lange IGA Chairman K. Lathrop GE G. Leitch Manager, Nuclear Generation Department
- 3. Lindinger STA R. Logue Assistant to Manager, Nuclear Support T. Love GE Shift Engineer f')
w, L. MacEntee ACO R. Maldonado ACO S. Mannix Assistant Operations Engineer (Supervisory)(Former STA) M. Manski Former STA F. Mascitelli Modifications Coordinator G. McCarty Physicist, Support HP (Supervisory) M. McCormick, Jr. Maintenance Department
- 3. McElwain QC Site Supervisor D. McRoberts Shift Supervisor H. Metz Shif t Superintendent C. Miller GE Operations Engineer
- 3. Mitman Senior Radwaste Engineer R. Monacho Shif t Operator - Limerick R. Moore Superintendent, QA P. Navim STA S. Nelson Physicist (Supervisory)
T. Niessen Assistant Operations Engineer (Supervisory) (] M. Norman
- 3. Oddo AO Nuclear Security Specialist
3160h7 A-4 PERSONNEL INTERVIEWED (Continued) l NAME TITLE OR POSITION D. Oltmans, Sr. Chemist A. Parry, Jr. VP, Purchasing G. Paton Shif t Supervisor - Limerick F. Pfender Shif t Superintendent B. Pieper Shift Superintendent W. Pinnel Engineer (Supervisory), Maintenance F. Polaski Operations Engineer D. Potocik Senior Health Physicist M. Restaino STA L. Rhodes PO S. Roberts Operations Engineer
- 3. Rogenmuser PM Activities Coordinator M. Ryan Compliance Engineer B. Saxman CO O R. Seseietes Segerintendent, Mohiie Section R. Sheetz Shift Supervisor D. Smith Superintendent Operations F. Solis General Superintendent, Testing and Laboratories
- 3. Spencer Superintendent of Services - Limerick B. Stambaugh CO T. Stone IGA Executive Committeeman S. Suillvan APO G. Swayne ACE S. Tharpe Chief Security Coordinator W. Tharpe ACO C. Townsend GE Shift Engineer R. Truax CO T. Ullrich Plant Manager, Limerick 2
- 3. Valinski STA L. Vernacchio Test Engineer H. Walters Project Management, Engineer in Charge O D. Werfei Assistent Meintenence Engineer A. Wargo Shift Supervisor
3160h7- A-5 PERSONNEL INTERVIEWED (Continued) O. NAME TITLE OR POSITION A. Weigand VP, Electric Production R. Weindorfer Director, Security R. Weingard I&C Engineer, Susquehanna Branch B. Widener Shif t Superintendent H. Wiegel Testing and Laboratories, Engineer in Charge P. Wilson GE Shift Engineer T. Winters ACO J. Winzenried Staff Engineer D. Woodrow Shift Supervisor S. Wookey Former STA N. Yost Shift Supervisor J. Zellmer AO O
COMMITMENT TO EXCELLENCE ACTION PLAN O APPENDIX B l Cross Reference of MAC Report Items With CTE Action Plan Tasks O O
i
-Ccmmitmsnt To Excellance Action Plan ,
APPENDIX B. CROSS REFERENCE OF MAC REPORT ITEMS WITH CTE ACTION ' PLAN TASKS A MAC ITEM CTE ACTION PLAN TASK CA 1 5.2.8.2 CA 2 5.2.1.1 5.2.1.7 5.2.3.2 5.2.4.4 5.2.1.2 5.2.1.9 5.2.3.3 5.2.5.1 5.2.1.4 5.2.1.10 5.2.4.1 5.2.5.2 5.2.1.5 5.2.1.11 5.2.4.2 5.2.8.4 5.2.1.6 5.2.3.1 5.2.4.5 i CA 3 5.1.1.2 5.1.1.9 . 5.1.1.3 5.1.1.10 5.1.1.5 5.1.1.11 i LM 1 See Section 3.4.1 Manaaement Chances LM 2 5.1.2.1 5.1.2.4 5.1.2.2 5.1.2.5 5.1.2.3 O LM 3 5.1.3.5 5.1.3.6 o LM 4 5.1.3.4 (' o LM 5 5.1.5.1 5.1.5.2 LM 6 5.2.1.6 5.2.1.E 5.2.1.10 5.2.1.7 5.2.1.9 5.2.1.11 9 LM 7 5.1.4.3 5.3.9.2 5.3.9.8 5.3.9.12 5.3.9.1 5.3.9.3 5.3.9.11 5.3.9.13 , t LM 8 5.3.1.46 5.3.2.3 5.3.2.6 5.3.4.2 5.3.2.1 5.3.2.4 5.3.3.1 5.3.2.2 5.3.2.5 5.3.3.2 LM 9 5.3.18.1 5.3.18.3 , 5.3.18.2 5.3.18.4 LM 10 5.2.7.1 5.2.7.4 5.2.7.7 5.2.7.10 5.2.7.2 5.2.7.5 5.2.7.8 5.2.7.11 5.2.7.3 5.2.7.6 5.2.7.9 5.2.7.13 , I LM 11 5.2.7.12 l Appendix B. CROSS REFERENCE OF MAC REPORT ITEMS WITH CTE ACTION PLAN TASKS B-1
/
-k_J
Commitm:nt To Exco11cnce Action Plan LM 12 5.2.7.6' }lI - l 5.2.7.7 PP 1 5.1.1.1 s 5.2.6.1
-s - PP 2' ' 5.1.1 ' 1
'W 5.1.1.7 4-
"% FP 3 5.1.1.4 i)
;\
Yi PP 4 5.2.6.2 i PP 5 5.2.6.3 I
- PP 6 5.2.6.4 PP 7 5.2.6.5 4 PP 8 5.2.6.6 ,
" PP 9 5.2.6.7 PP 10 5.2.6.8 3- PP'll 5.2.6.9 PP 12 5.2.6.10
.PP 13 5.2.8.2 ER 1 5.5.3.1 5.5.3.2 ER 2 5.5.1.1 1 ER 3 5.2.2.1 5.2.2.2 /
1 ER 4 5.5.2.1 5.5.2.5 5.5.2.7 5.5.2.2 5.5.2.6 5.5.2.8 0-ol Appendix B. CROSS REFERENCE OF MAC REPORT ITEMS WITH CTE ACTION PLAN TASKS B-2
COMMITMENT TO EXCELLENCE ACTION PLAN O APPENDIX C People-The Foundation of Excellence O O l l
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<, : , 'f PHILADELPHIA ELECTRIC COMPANY Nuclear Operations Nuclear Ceneration Department Nuclear Training Section SITE LOCATION: Peach Bottom Atomic Power Station DOCTYPE #: _ , _ __ _ _ _
DOCUMENT TITLE: COURSE PLAN PROG / COURSE TITLE: Peoole -The Foundation of Excellence CODE NO: _ _ _ _ . . __ _ . _ _ ITEM NO: _ _ COMPONENTS OF COURSE Unit Titlem Unit 1 - Personal Insicht Unit 2 - Interpersonal Processes Unit 3 - Grouc Dynamics Unit 4 - Working with Differences Recommended: I ptr top - b Q ((_ Date Approval: __ _ 7 Traini - Coordinator /Branc d D' ate Approval: _______________ _ d, /_( [] _ __ _ _ ,_NTS_ __ Superintendent Date Acceptance: ___ _ ___ t n M nager [ /[![7 b te ' Acceptance: + _ _ _
/[
Depart nt Manager _____Da e O l j
O COURSE TITLE: People - The Foundation of Excellence PURPOSE: To identify develop and practice skills to improve interperso.. 1 and group dynamics to develop excellence on the job. In addition, this course is designed to contribute to professionalism in the control room and Nuclear Operations. TARGET POPULATION: Senior Reactor Operators, Reactor Operators and other designated Shift personnel. PP.E-REQUISITES: Management selection process SCOP." AND DESCRIPTION: This course is designed for improving individual and group process skills. The course consists of four units of instruction beginning with personal insight and interpersonal skills, and O concluding with group dynamics differences. and working with Skills and abilities associated with effective communication, positive attitude, and professionalism are practiced and applied to Beneral and specific problem solving and decision making situations. Moreover, the plant manager along with other members of the PBAPS management staff will participate in selected activities. The training will occur primarily in the classroom / workshop setting. Other training settings may be identified through ongoing course feedback. Emphasis will be placed on providing shift workers with opportunities to function as a team and to build personal relationships that carry over to work situations. CONTENT: The course is sequenced into four interconnected and progressive units of study. The topics and skills learned and practiced in earlier units are used to develop more diversified interpersonal processes in later units, In essence, the content of this course is the O Processes and sk111s needee te i Preve indivieue1
O and group interaction. Typical content areas include communication skills, change process models, behavior observation skills, listening skills, organizational behavior, positive reinforcement, coaching, group membership skills, group development and observation processes, task and maintenance roles, team building, contracting, and creating culture. Other topics, such as Kepner-Tregoe, Human Performance Evaluation System, and Work Rule Consistency have been incorporated into the course. These latter topics will be used to facilitate interpersonal and group interactions relevant to control room operations. DURATION: This course is 27 days. EVALUATION CRITERIA: Self, peer, management and instructor evaluations and feedback will occur throughout the course. A summary report will be submitted to management for further assessment of trainees and course effectiveness. ATTACHMENTS: (A) Unit Goals, Objectives and Activities / Topics O l
l' I')T UNIT 1 PERSONAL INSIGHT GOAL: Provide methods for individuals to learn more about themselves. OBJECTIVES:
- 1. Identify preferred individual approaches.
- 2. Identify sources of individual behavior.
- 3. Assess personal relevance of ins ', gh t s gained from analysis of responses to social and psychological measurement instruments for individual behavior.
4 Test levelt of effectiveness / appropriateness of individual behavior in different situations.
- 5. Identify and describe perceptions of self and others in terms of observable behavior.
f*h f s 6. Make decisions about possible changes in interpersonal behavior. ACTIVITIES AND TOPICS: The unit on Personal Insight reflects the need for individuals to learn more about themrelves. Individuals will identify preferred personal approaches and hence, sources of individual behavior. The assessment of personal relevance to insights gained from the analysis of responses to social and psychological measurement becomes a working tool fo.r personal growth and development. With this personal insight individuals
- will be able to choose levels of effectiveness and j appropriateness for their own behavior in different situations. After identifying personal behaviors individuals are able to make decisions about possible changes in interpersonal behavior to reflect the effectiveness of relations in the work place.
- 1. Learning Style Inventory (SDI) - Understanding personal strengths and weaknesses as a learner and applying
() insights to learn more about self.
O
- 2. Myers -
Briggs Type Indicator (MBTI) - Understanding preferences and strengths of self and others and then relating to interpersonal differences.
- 3. Social Style Profile -
Effective communications and interpersonal relations - enhance productive interpersonal relations in the work place through the use of social style profiles.
- 4. Keeping journals -
Understanding, developing and reiterating personal strengths and weaknesses, insights and growth. O O
l 3) UNIT 2 INTERPERSONAL PROCESSES COAL: Provide methods for individuals to learn more about themselves in relation to others. OBJECTIVES:
- 1. Identify individual preferences in interactions with others.
- 2. Identify potential barriers to effective communication.
- 3. Develop communication / interpersonal skills.
- 4. Assess effectiveness of working relationships.
ACTIVITIES AND TOPICS: J Interpersonal relationships reflect the preferences that individuals have for interacting with one another. Once identified, individual preferences can be modified or reinforced to reduce barriers to effective communication. With practice, individuals can learn to select communication techniques that tend to promote mutual understanding and positive working relationships. The overall effectiveness of people working together will be stressed through the use of informal job evaluation which includes coaching, feedback, and self-disclosure.
- 1. Communication Skill Development A series of activities to build confidence and trust in what we and others hear and say.
- 2. Managing Performance Based on the principles of the "One Minute Manager",
the trainees will practice ways to help one another achieve better work habits throt.gh be t t e r communication and interpersonal relations.
L O
- 3. Fundamental Interpersonal Relations Orientation-Behavior (FIRO-B)
The instrument measures the degree to which an individual expresses anA wants o To include people o To lead people o To involve people \ O l l
(v') UNIT 3 CROUP DYNAMICS COAL: Provide methods for individuals and groups to examine group dynamics. OBJECTIVES:
- 1. Identify individual roles and sets of role relationships in group activities.
- 2. Analyze and describe group activity in behavior terms.
- 3. Devise methods to improve the ways the group works.
ACTIVITIES AND TOPICS: Activities during this unit of training will focus on identification of group dynamics and effective utilization of group problem solving and decision making processes. An integrated approach is used to accomplish () the objectives. Specifically, group dynamics will be related to personal insight and interpersonal processes. Lessons learned in previous activities will provide a format to examine and practice processes that occur within and between groups.
- 1. Group Characteristics and Group Development Leadership /Meabership Style; What are the characteristics of a good / effective group? This question will be examined and processed.
Communications and Motivation; inter-group and intra-group feedback will be practiced and analyzed for its effect on motivation and group effectiveness. Stages of Group Development; " forming", " storming",
"norming" and " performing" and "adj ourning" will be examined, observed and applied towards group effectiveness.
- 2. Group Process Observations The dynamics of group activity are examined and discussed. Specific topics include: Task Maintenance (wg Behavior, Decision-Making, Leadership, Communications
(,/ and Membership. I 1
O ; Group Task Behavior Decision Making and Problem Solving; observe and apply group processes that effect decisions and solutions. l Kepner - Tregoe training vill be used as a foundation ! for this portion of training. O I i 1 i O
r b) UNIT 4 WORKING WITH DIFFERENCES GOAL: Provide methods for individuals and groups to use differences in constructive ways. OBJECTIVES:
- 1. Select appropriate / effective approaches to interpersonal differences.
- 2. Manage and resolve group differences.
- 3. Assess inter / intra group relations.
ACTIVITIES AND TOPICS: Activities utilized in this unit will focus on managing differences and creating effective group norms for the transition back to the work. place. Participants f% will apply awareness and skills learned in this unit to (_) become a more effective work team. While PBAPS specific items such as; consistency of shift operations, communications, work rules, policy, .ork system / procedures meetings will have been addressed throughout the course, attention will be paid to integration ef each of these items prior to re-entry on shift.
- 1. Dynamics of Differences This topic will focus on the merits of both ,
competitive and collaboration models within the context ) of intragroup and intergroup relations. The impact of win-lose situation will be examined and processed. l Specific activities which highlight these dynamics I include: Win as much as you can, Abilene Paradox and Pfisoners Dilemma. They are designed as an experiential approach to the dynamics of win-lose situations. 4
- 2. Conflict Resolution / Collaboration This topic covers (1) the nature of conflict, (2) strategies for managing conflict, and (3) creative
/'T k/ fighting. Participants will integrate their Thomas Kilman Conflict Mode scores on the dimensions of
l l (O v (A) Competing, (B) Collaborating, (C) Compromising, (D) l Avoiding, and (E) Accommodating to analyze t h e i,r l behavior in relation to others during conflict situations. Methodologies include here and now settings as well =s actual problem - solving situations. l
- 3. Team Building Team Building is the introduction of a systematic, leng -
range plan to improve interpersonal relations among those workers with whom they are functionally l interdependent. Approaches to team building at this stage of the team's development include actual agreements between team members, which will assist in diagnosing and changing group norms. Skills developed in decision-making, leadership, comuunicatior. and membership will provide a basis for examining norms.
- 4. Building High Performance Work Teams Building high performance work teams rest on the ability and willingness of team members to work with each other in such a way that they consume resources, i.e. time, money, materials, human energy at a level less than what they contribute back to the organization.
This requires awareness, skills and commitment to behavior in the areas of (1) Interacting, (2) Appreciative Understanding, (3) Integrating and (4) , Implementing. This topic focuses on integrating the I learnings of the other units to produce " synergistic" working relations, where 1 + 1 is greater than 2. The result is more productive output than might have been expected if the two "1"'s had worked independently. Participants will sur ey their work team along the dimensions nf (1) Interacting, (2) Appreciative Understanding. (3) Integrating and (4) Implementing for the purpose of creating a more effective work team.
- 5. Transition /Re-Entry Activities designed for transitions and re-entry will focus on the integration of learnings and the O practice of skills developed in all four units.
COMMITMENT TO EXCELLENCE ACTION PLAN O APPENDIX D Commitment To Excellence For Nuclear Operations O O l l
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I APPENDIX D. COMMITMENT TO EXCELLENCE FOR NUCLEAR OPERATIONS
/ T D'
We, as Nuclear Professionals, recognize our continuing responsibility to public and employee health and safety. We, therefore, dedicate ourselves to maintain our highest standards and principles of excellence in the performance of our duties and responsibilities as set forth in the Commitment of Excellence. I. Remain diligent in maintaining plant and personnel safety by identi-fying and actively pursuing resolution of safety concerns. II. Constantly remain alert and maintain awareness of plant status, anticipating conditions that could adversely effect plant reliabil-ity. III. Cooperate with independent organizations, recognizing the need for monitoring and review of nuclear operations. IV. Be governed by and adhere to applicable Federal law by complying with Technical Specifications, procedures, and policies. V. Recognize the importance of maintaining and expanding professional g qualifications and detailed plant knowledge by active participation (s in all aspects of training. VI. Demonstrate an attitude of professionalism through demeanor, personal appearance, and attention to detail. Manifest a sense of pride in all facets of the work environment. VII. Foster the concept of teamwork among all groups. Mutual support, courtesy, and flexibility are essential to achieve cooperation and unity. VIII. Understand the necessity of effective communications. Ensure all communications, including logs and records, are timely, accurate, and concise. The achievement of excellence and professionalism is predicated upon mutual respect, support, and trust throughout our organization. O d Appendix D. Commitment to Excellence for Nuclear Operations D-1}}