NRC-89-0004, Responds to Diagnostic Evaluation Team Rept.In Aug 1988,mgt Performance Program Initiated Which Provides Monetary Awards for Achievement of Specific Levels of Performance
| ML20236E195 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/17/1989 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20236E193 | List: |
| References | |
| CON-NRC-89-0004, CON-NRC-89-4 NUDOCS 8903240002 | |
| Download: ML20236E195 (18) | |
Text
O. Resph sylvia San 4r VIC3 President 6400 North Disse Highway l
fM Ne=vport. Michigan 48166 s
% sri 5 ' (313) 586-4150 January 17, 1989 NRC-89-0004
(
I l
Mr. Victor Stello, Jr.
Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C.
20555 I
References:
- 1) Fermi 2 NRC Docket No. 50-341 l
NRC License No. NPF-43
- 2) NRC Letter, Stello to McCarthy, dated November 16, 1988 Diagnostic Evaluation Team Report
Subject:
Response to riagnostic Evaluation Team Report Dear Mr. Stellos As you requested in your letter of November 16,1988 to Mr. Walter J. McCarthy, Jr., attached hereto is the Detroit Edison Company's response to the referenced report.
I am responding, as Mr. McCarthy is recuperating from recent surgery. He has, however, reviewed the response and agrees with it.
As the Company has previously indicated, it is not satisfied with Fermi's current performance in a number of areas. You will note in the response that the Company has developed programs that will continue to improve performance at Fermi 2.
As stated in your letter j
to Mr. McCarthy, " Fermi's new management team... has a good
)
understanding of the underlying causes of Fermi's performance
{
problems". Further, in your December 16, 1988 letter you indicated
{
that the new programs "are generally addressing the causes of the I
performance problems while maintaining an acceptable level of
]
s af ety". The items f rom Section 2 of the Diagnostic Evaluation Team I
report were evaluated in addressing the 8 major areas of the report.
]
l The objective of implementing these programs and integrating them into the overall activities at Fermi is to focus our attention on improving performance. Additionally, an integrated long range living plan is being developed, as discussed in our response, which will focus the organization's attention on identified priorities.
I After you have had an opportunity to review this response we request a j
meeting with senior NRC managers to discuss these programs.
]
8903240002 890315 HO---004200 i
PDR ADOCK 05000341
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P PDC 1
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Mr. Victor Ste11o. Jr.
January 17. 1989 NRC-89-0004 Page 2 If you have any questione, please call me at (313) 586-4150 or Lyr.ne S. Goodman, Director-Nuclear Licensing at (313) 586-4211.
Since rely.
Enclosure cc:
R. W. Cooper W. G. Rogers T. k. Quay J. F. Stang USNRC Document Control Desk USNRC Region III i
i i
a.
N l
Detroit Edison Company 3
Response to Diagnostic Evaluation of Fermi 2 January 17, 1989
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Enc 1m ura to NRC-89-000ll Page 2 i
i Contents Page j
3 f
I.
Background and Introduction 1
I Responses to Areas Needing Additional Management II.
5 1.
Organizational stability 6
l Effectiveness of First and Second Line Supervisors 2.
8 3
Organizational Climate 1
9 l
4.
Fragmented / Overlapping Engineering Support l
9 j
5 Fix Known Equipment Problems
\\
11 Set Priorities According to Plant Needs/ Effective J
6.
Use of Resources 12 7
Effectiveness of Operator Training Programs i
l l
l l
Enclosura to NRC-89-0004 Page 3 I
i Detroit Edison Company Response to NRC Diagnostic Evaluation of Fermi 2 I.
BACKGROUND AND INTRODUCTION The Diagnostic Evaluation Team (DET) spent three weeks at the The functional Fermi' 2 site during August and September 1988.
areas of management, organization, operations, training, maintenance, testing, quality programs and engineering support were evaluated.
The 19 member team identified overall improvements in Fermi's However, weaknesses were performance and capabilities. identified that require additional at Actions taken during the last two Detroit Edison. management.
years represented significant accomplishments and provided the The essential elements needed to achieve future improvements.
team further concluded that the actions being implemented at Fermi generally address the cause of performance problems while The team maintaining an acceptable level of operational safety.
determined that a number of areas needed additional management attention to increase the rate of progress and assure continued success. These areas are:
Achievement of organizational stability as soon as 1.
possible.
Improvement in effectiveness of first and second line 2.
supervisors.
3 Improvement of organizational climate.
Correction of fragmented and overlapping engineering 4.
support responsibilities.
5 Fixing of known equipment problems.
Setting of priorities according to plant needs.
6.
l l
l
Enciccura to
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Page 4 Allocation of resources to selected areas and better 7
utilization of existing resources.
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8.
Improv,ing effectiveness of operator training programs.
J The sections that follow describe the actions that are planned or have been taken to address the eight areas identified in the f
Please note report as requiring increased management attention.
In that Section 6 of this response combines items 6 & 7 above.
developing the response, a cross-reference matrix was used to The assure that the major findings of the DET were addressed.
other findings summarized in section 2.0, " Evaluation i:esults",
are addressed in either the Fermi Business Plan, Organizational Unit Business Plans, or are otherwise being addressed by Nuclear l
-Generation Organizational Unit heads, in accordance with their l
relative significance. The matrix referred to above will be l
i used by management to assure that all findings are being properly addressed.
Some of the major initiatives of the past year are:
Clarification of responsibility and authority of 1st and 1.
'2nd line supervision, including establishment of a comprehensive leadership training program.
I 2.
Establishment of an accountability program.
3 Implementation of a new Corrective Action System and its l
performance trending.
l 4.
Hiring of a new management team.
Performance'of the Technical Specification Improvement 5.
Program.
6.
Completion of the Procedure Upgrade Progran Implementation of key changes in personnel policies geared l
7 to the nuclear environment.
f Improvement has been identified in key performance areas by l
trend graphs developed from Deviation Event Report (DER) data.
The number of DERs due to personnel errors, procedure problems and hardware have demonstrated decreasing trends over the first 8 months of 1988 which is the rost recent period for which data analysis is completed.
The new actions addressing the issues raised in the report which l
are expected to have the most significant overall effect are:
.Enciccura to NRC-89-0004 I
Page 5
.1 1.
Establishment of an integrated planning program.
Re-clarification of the responsibility and authority of 2.
engineering support functions.
Establishment of.the System Engineering function within the 3..
Technical Engineering Section.
Improvements in the effectiveness of the Operator Training
)
4.
program.
Finally, as an integral part of the ongoing planning effort, the 1
Fermi Business Plan and organizational level business plans will f
continue to be reviewed by appropriate levels of management to l
identify key activities associated with plant and organizational 3
performance and to establish critical factors to be monitored to ensure that expected results are achieved in a timely manner.
RESPONSES TO AREAS NEEDING ADDITIONAL MANAGEMENT ATTEN j
II.
i 1.
Organizational Stability I
During the last two years many changes have occurred in the organization. These major organizational changes occurred while the plant was successfully completing the
)
These changes startup test program and warranty run.
l involved placing individuals with commercial nuclear power
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experience in key positions and redefining and realigning functional areas to achieve effective support in an l
operating plant environment.
During this period all key positions, except outage manager and one key engineering position, have been filled.
Candidates for the outage manager's position and the The engineering position are being vigorously recruited.
major reorganization activity, which was an element of the i
Fermi Business Plan in 1987 and 1988, is now complete.
Some of the most significant outcomes of this effort are:
Establishment of a strong Systeru Engineering function a.
in the Technical Engineering sectfon, providing a focal point for interface between the Operations, Maintenance and Nuclear Engineering organizations.
This function is the systems interface for performance monitoring, preventive and corrective maintenanc.e, and The development of system modification activities.
this function was initiated under the leadership of All key managers with relevant BWR experience.
established positions within the System Engineering
Encle:ura to I
NRC-89-0004 Page 6 group are expected to be filled by March 31, 1989 (18 of 24 positions are currently filled).
b.
An integrated Nuclear Material Management Organization has been established. This organization consolidates material engineering, procurement and warehousing functions for more effective support of operations, maintenance and modification activities.
I With one exception, the remaining Nuclear Engineering f
o.
Organization supervisory positions are no longer
" acting" and have been permanently filled.
d.
Personnel additions have been made to the Engineering and Technical Support Organizations which contributed significantly to the commercial nuclear operations experience base at Fermi.
Organizational stability occurs when key positions are identified, the duties and responsibilities defined, and With the the positions are filled on a permanent basis.
i actions taken to date, Detroit Edison believes thct organizational stability is well on its way to being 1
achieved.
2.
Effectiveness of First and Second Line Supervisors i
A key to achieving expected performance is effective supervisory leadership at the first and second line levels of the organization. The need for a supervisory training program designed for the unique character of the nuclear environment was identified in a study conducted in the first quarter of 1988. A comprehensive supervisory trainir.g program titled " Steps to Effective Plant Supervision" (STEPS), was jointly developed by Nuclear Training, Corporate Employe Development personnel, and key nuclear organization managers with significant nuclear experience.
The objectives of the STEPS Program include: increasing basic supervisory skills; individual and group accountability; recognition of the unique management principles of the nuclear environment; effectivo communications; and management's expectation of supervisors, including effective performance monitoring.
The STEPS Program addresses specific training needs such leadership, problem solving, clarifiestion of as:
individual responsibility, teamwork, and communication 4
paths to management.
i 1
Enc 1ccura to NRC-89-0004 Page 7 Five training groups, each consisting of about 15 individuals from a cross section of operations support functional areas, have been identified to participate in the initial program. A significant feature of the program is the extent of management ~1nvolvement and commitment.
Each workshop in the program includes management participation for reinforcement and overview. This ongoing program, which consists of multiple modules, was initiated in September of 1988 and is currently scheduled c.hrough September 1989 While some benefit of the STEPS program is already evident, the full' effects are expected to be realized during 1989 as learned skills and principles are put into practice. STEPS program participants should make a significant contribution.
to the successful completion of the refueling outage scheduled for September 1989 Several other key initiat'.ves have been undertaken which complement the STEPS program. These initiatives have._
contributed to the progress achieved to date and will help sustain and accelerate improvement in the effectiveness ot' first and second line supervision. These initiatives include:
'f In August of 1988 the management performance program 2.
was initiated. The program provides monetary awards for the achievement of specified levels of performance and is designed to motivate and stimulate employes to achieve continued improvement in individual and overall organizational performance. The program l
provides awards to eligible participants, including first and second line supervisors, based on achievement of specified levels of performance. These performance levels, or standards, are based on Fermi Business Plan, Organizational Unit Business Plans, and individual Annual Work Plan performance measures.
This program was judged to be a significant factor in the improved performance achieved in the October -
l December, 1988 time frame and will be continued in 1989 i
l b.
A focus on individuti accountability coupled with balanced application of disciplinary action and recognition of exceptional individual performance.
l Accountability meetings are held in conjunction with selected DERs, LERs, or other events that are the result of personnel error or an individual's failure i
to follow procedure or other requirements. Meetings i
I
i
'd Encle2ura to
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o NRC-89-0004 Page 8 4
x ir.volve responsible individuals, supervisors, and other levels of management as appropriate to the i
significance of the event.' The primary objective of f
accountability meetings is to prevent recurrence of the causes of the event and hold individuals and I
supervisors responsible for their performance.
Disciplinary action associated with such events will vary, depending on their significance and potential or L
actual consequences of the event, up to and including l
termination.
On the other hand, individuals and organizations who j
have demonstrated exceptional performance are recognized and their contribution acknowledged by Recognition and acknowledgement include l
management.
formal and informal recognition meetings, site and local newspapers articles, and employe of the year awards We PRIDE (People Really Involved Develop Excellence) program, initiated in late 1986, was developed to c.
provide a means for Operations personnel participation in attaining and maintaining a high level of The process involves shift crews with performance.
the aid of a facilitatory comparing their on-shift Less than performance with expected performance.
expected performance requires the shift crew to apply systematic problem solving and decision making methods to develop recommendations that correct safety, FRIDE sessions are quality and productivity concerns.
normally monitored by a management representative.
This program has contributed to improved operator The program will be expanded performance during 1988.to include the Maintenance o 3
Organizational climate In retrospect, implementation of new management philosophy, programs and personnel policies could have beenThe changes in t communicated more effectively.
year have been dramatic and much greater than in the past.
Major changes create stress and concern regardless of how Fermi management believes that progress well orchestrated.
made in achieving organizational stability in conjunction with efforts underway to improve communications, vertically and horizontally within the Nuclear organization, will help Climate and morale do improve the organizational climate.
improve with success, as was noticed following the The successful completion of the Startup Test Program.
programs discussed in the previous section will not only 1
_ Encic&ura to NRC-89-0004 Page 9
' improve the effectiveness of fin,t and second line supervisory personnel, but should also improve morale,
)
since they clarify management expectations and goals.
One measure of organizational climate is the ability of elements of the organization to work as a team to achieve i
Two of the programs discussed under effectiveness of first and second line supervisors, STEPS
.j common goals.
s and PRIDE, contain elements designed to facilitate team Functioning as a team involves working to known I
building.
common objectives, as will be established by the integrated j
plan.
I i
Fermi management will continue to monitor and provide feedback on organizational and individual performance and
'in so doing, expects to recognize and respond to positive and negative trends in the area of organizational climate.
4.
Fragmented /Overlappitig Engineering Support In October 1988, a joint Nuclear Engineering / Nuclear l
Production Task Force was established to address this The Task Force is comprised of important area.
representatives from Nuclear Engineering, Technical Engineering, Maintenance / Modifications, Quality Assurance, Nuclear Training, Technical Support and Administrative Support. The Task Force has two major objectives related to this issue:
Establish a clear definition of Nuclear Engineering / Nuclear Production Technical Engineering
'a.
l Group interface responsibilities.
j Define areas within the Technical Engineering function b.
where related design control activities might be I
shared.
Actions to achieve these objectives are planned to be completed by March 31, 1989 Task progress is being monitored by Senior Management.
Objectives 1 and 2 are currently about 855 and 75%
l complete, respectively.
5.
Fix Known Equipment Problems j
During the startup test program, equipment problems were identified that delayed the completion of testing.
Aggressive action was taken to address the identified problems and support safe operation of the plant.
1 l
J
_7-.
a Enc 1ccura to NRC-89-0004 a
Page'10
.i-4 Concentrated attention was devoted to equipment such as the Reactor Feed Pumps, Moisture Separator Reheaters, Feedwater Heater Level Controls, High Pressure Coolant Injection Systen valves and turbine speed controls, compression l-l fittings, and motor-operated valves.
With the startup testing, Technical Specification Improvement and Procedures Upgrade programs completed; and having made significant improvement in the total number of l
Licensee Event Reports (LERs) and personnel error caused LERs; equipment problems have emerged as the area requiring Fermi Management attention the most management attention.
is being focused on equipment problems, with emphasis on l
equipment problems that challenge operators.
A major strategy of the Fermi Business Plan is directed at This will result in actions such as this important area.
maintenance of an equipment problems list and management review of progress towards fixing identified equipment Other problems at weekly schedule review meetings.
strategies are directed at improving the material condition Actions associated with these strategies of the plant.
include:
Improving sparo parts availability a.
Implementation of the long range Motor Operator Valve b.
program l
Reducing out-of-service control room instruments c.
Refinement and implementation of the leakage reduction d.
program Refinement and implementation of the check valve e.
l program Continuation of the testability improvement effort f.
Improvement of technical support to maintenance by g.
implementation of a system engineer program Work has begun on some of the identified equipment For example, Main Turbine-Generator vibration and Cooling Tower freezing problems are being aggressively problems.
pursued.
Overall progress toward improving equipment performance is being monitored by the Senior Vice President - Nuclear Generation during the monthly Business Plan review
l Enclorura to
[
NRC-89-0004 Page 11 The Vice President-Nuclear Operations, Vice meeting.
President-Engineering and Services, and the Plant Manager will review progress during the weekly schedule review meetings to ensure appropriate management attention is given to this important area.
t.
Set Priorities According to Plant Needs/ Effective Use of 6.
Resources Detroit Edison recognizes i;ne need to establish work priorities based on plant needs and the value of integrated During work plans to make effective use of resources.
1988, requested design modifications were prioritized Priority based on plant needs and regulatory commitments.
for plant modifications is determined by the Management Detroit Review Board which meets on a regular basis.
Edison agrees that a reactive mode, which was strongly influenced by outside organizations, added substantially to the workload of the Nuclear organization.
1 However, we do not agree that the prioritization of this We believe that prioritization work loe.d was improper.
criteria applied prior to December, 1988 were proper for a plant and organization involved in conducting a startup The startup test program for Fermi 2 was test program.
Completion of the startup completed in November, 1988.
test program and having operated the plant over its full range of operating conditions has helped identify equipment With a more complete and other operating problems.
understanding of problems affecting plant operations, Fermi management will be able to refine the prioritization criteria for the full work scope at Fermi 2 as we progress further into the operational phase. New priori' ties will be Several developed based on an integrated priority scheme.
actions have been taken or are in-progress to assure the development of effective work plans. These actions include:
Fermi management has directed that an integrated, resource loaded, long range work plan be established a.
for Fermi 2.
Refined criteria for prioritization are 31, 1989 The initial to be established by January "Five Year Plan" will be established by March 31, A principal focus of this plan will be the work 1989 efforts for the first refueling outage scheduled for The five year plan will be ready to September 1989 be discussed with the NRC Staff in April 1989 In November 1988, a separate Planning and Scheduling b.
The group was established in Nuclear Engineering.
overall objectives of this group are to:
l
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EncloIura to NRC-89-0004 Page 12 1
Integrate task schedules for major work activities 1'
within Nuclear Engineering while supporting other departments such as Licensing, Procurement, Operations, Maintenance, and Outage Management.
Report to management on the performance related to 11 the plans, goals and objectives of the Nuclear Engineering organization.
111 Provide a monitoring system which enables management to identify reasons for deviations from the plan and correct them in a timely manner.
Develop resource loaded plans / schedules to iv identify the full scope of work activities and to l
appropriately prioritize, plan and schedule these activities.
These plans and schedules will be incorporated into l
the integrated five year plan.
c The First Refueling Outage Program (Schedule) was c.
distributed for management review in early December 1988. A refined version of this plan will be incorporated into the five year plan.
l Until the 5 year plan is finalized and approved, individual organizational units of the Nuclear Organization will continue to use schedules established and reviewed at daily and weekly planning / schedule review meetings.
l Typical topics reviewed at the weekly Schedule Review meeting include:
Review of important performance indicators.
a.
b.
Plant Schedules c.
Commitments Special Items (i.e., items identified for periodic d.
monitoring by plant management)
Major Actions for First Refueling Outage e.
7 Effectiveness of Operator Training Programs Detroit Edison recognizes the importance of effective A brief review operator training on operator performance.
of actions taken in the past two years will help in
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Encluura to o
NRC-89-0004 Page 13 understanding'the approach taken for actions planned during 1989 Actions taken in 1987 included:
Consolidation of Nuclear Training under an experienced a.
aanager.
Reorganization of the Training Organization to b.
eliminate one layer of supervision.
Major evaluation of the operator requalification l
c.
l program and significant upgrade to assure regulatory-compliance.
i d.
Extensive revision of Training Organization administrative procedures.
Strengthening of administrative control of training e.
materials to ensure timely and effective change control.
Actions taken in 1988 included:
Updating of the " systems" student text for operator a.
training.
Completion of Operator job / task analysis started in b.
1987 Implementation of the new NRC requalification c.
examination process for annual examinations, Revision of simulator scenarios used during annual d.
evaluations to provide position specific objectives, including implementation of Emergency Operating Procedures (EOPs).
Implementation of the simulater evolution evaluation program to enable senior management to evaluate shift e.
team performance over the full range of operation, Acquisition of five currently or previously licensed, f.
and two fully qualified non-licensed operators with shift experience as Training staff instructors.
Addition of Emergency Response Information System / Safety Parameter Display System (ERIS/SPDS) g.
capability to the simulator to improve simulator fidelity and operator EOP response.
Encic'sure to NRC-89-0004:
Page 14 Initiation of the use of Technical Sp6cification case h.
histories in requalification training.
With the actions taken in 1987 and 1988 in mind, and consideration of the results of internal and external evaluations, including the DET, the following actions are
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planned for 1989 and beyond:
Improvement of classroom and simulator ins'tructor's a.
This is an on-going activity during 1989 skills.
Development of more specific course objectives based b.
on recently completed Job and Task Analyses by December 1989 Incorporate results~into revised lesson plans, test banks, etc., by December 1990.
Improvement of simulator exercise guides and their use c.
by instructors. This action includes:
Review of formats prior to use for requalification i
l training.
Establishment of a requalification training 11 schedule to include a week break before each During this week, requalification cycle.
simulator training instructors will prepare for the upcoming instruction, revise simulator exercise guides and conduct instructor training.
i iii Use of a third person in the simulator to run the instructor's station and handle communications during evaluated simulator sessions.
)
Development of an Operation's Training Guide on simulator scenarios describing their content and j
iv use by March 31, 1989 A plan is in place d.
Improvement of Simulator Fidelity.The plan consists of to improve simulator fidelity.
upgrading the control logic models, the dynamic These process models, and the instructor station.
changes will require upgrading of the existing The schedule of major milestones for the i
computers.
simulator upgrade effort are as follows:
The procurement specification for the upgrade of 1
process models, instructor station, and the simulator computers, was issued in December 1988.
l
,4
.g j
Encle:ura to.
NRC-89-0000 Page.15 J
11 The contract for the simulator upgrade will be I
awarded by March 1989 j
111 The dynamic process models upgrade is scheduled l
for completion by September 1990.
l The control logic models upgrade is scheduled for iv completion by September 1990.
Hardware and software integration is scheduled for q
l v
completion by December 1990.
I
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vi The simulator performance test and certification
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is scheduled for completion by June 1991.
Improvement of licensed operator performance in e.
controlling plant casualties during emergency scenarios conducted in the simulator. Specific items associated with this action are Establishment of an operator requalification i
training schedule that provides a one week break between requalification cycles. The break will be j
used to prepare for the upcoming instruction, revise simulator exercise guides, upgrade lesson i
plans and conduct instructor training.
1 Use of a third individual in the simulator to run 11 the instructor's stations and to handle theUse of communications during evaluated sessions.
the third individual will allow two simulator instructors to concentrate on evaluating performance of control board manipulations and E0P procedural compliance.
iii Emphasis and reinforcement of the use of place keeping methods described in Appendir D, j
" Emergency Procedures", of the Fermi Writer's I
Guide during the first requalification training cycle of 1989 I
Refinement and reinforcement of EOP training l
iv during the first cycle of 1989 requalification l
i This training will include specific l
training.
training on weaknesses identified during the EOP l
evaluations and the 1988 year end simulator le j
performance examinations.
l i
Covering of E0P procedure steps and their bases in v
the classroom during the remainder of the 1989 l
l
l.y o
s.
Enclexura to NRC-89-0004 Page 16 l
This.
licensed operator requalification cycles.
l training will include containment control and ATWS Simulator sessions will be supported by events.
COP subject matter experts from the Operations Support Group.
l Improvement of instructor audits to assess technical and instructional skills. Steps associated with this f.
action are:
Development of a method.to evaluate simulator 1
instructors in the simulator by March 1989 Incorporation of instructor classroom audits into 11 appropriate individual's Annual Work Plans (AWP) and initiate quarterly monitoring of performance by February 1989 Continuation of participation as a peer evaluator for INPO station accreditation team visits at other g.
plants.
Use of a portion of the break period between l
h.
requalification cycles discussed. earlier for classroom
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presentation preparation to facilitate more effective use of Technical Specification case studies.
Re-evaluation of accredited operator training program 1.
by the Institute of Nuclear Power Operations.
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