View source for JPN-92-001, Responds to Diagnostic Evaluation Team Rept,Provided Via NRC .Five Major Initiatives Will Be Undertaken Re Capital Improvements,Mgt Changes,Engineering Organizational Changes & Nuclear Generation Business Plan

{{Adams
| number = ML20087A507
| issue date = 01/03/1992
| title = Responds to Diagnostic Evaluation Team Rept,Provided Via NRC .Five Major Initiatives Will Be Undertaken Re Capital Improvements,Mgt Changes,Engineering Organizational Changes & Nuclear Generation Business Plan
| author name = Brons J
| author affiliation = POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
| addressee name = Taylor J
| addressee affiliation = NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
| docket = 05000333
| license number = 
| contact person = 
| document report number = JPN-92-001, JPN-92-1, NUDOCS 9201090186
| title reference date = 12-03-1991
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 8
}}

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tv Authority.                                                                             %gl,0- om, January 3,1992 JPN 92 001 Mr. James M. Taylor Executive Director for Operations U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville,MD 20852

==SUBJECT:==
-         James A. FitzPatrick Nuclear Power Plant
                                 ~. Docket No. 50-333 Diagnostic Evaluation Team Report

==Reference:==
      ' NRC letter, J. M. Taylor to J. C. Brons, dated December 3,1991, providing the NRC's Diagnostic Evaluation Team Report on the FitzPatrick Nuclear Power Plant.
Dear Mr. Taylor; The New York Power Authority agrees'with the results of the Diagnostic Evaluailon Team (DET) provided with your {{letter dated|date=December 3, 1991|text=December 3,1991 letter}}. This evaluation of the                             .
Authority's James A. Fit 2 Patrick Nuclear Power Plant, performed during September and October 1991, identifies performance deficiencies at the plant, as well as insufficient headquarters management support and oversightc The DET report provides us with                           .
              . Insights into the causes of the problems.-
Senior Power Authority management and I have been aware of the decline in FitzPatrick performance and deficiencies in headquarters support during the last NRC SALP review period. We evaluated the results of the NRC's SALP report, INPO evaluations of the Fit 2 Patrick and Indian Point 3 plants and headquarters, and other studies including a staffing effectiveness study, a radiation protection program
              . assessment study and a self assassment of management effectivenessi These assessments were evaluated with the goal of determining root causes and thereby improving FitzPatrick's performanen. The FitzPatrick Results improvement Program (FRIP) and Nuclear Generation Business Plan were developed using these assessments.
The results of the DET evaluation pa allel the NYPA assessments.= The NRC report brings additiona' perspective to our findings and will help the Authority in its ongoing programs to improve performance. The detailed observations provided by the DET have been incorporated in the FRIP.
Improvements in the operation of the FitzPatrick plant will come about as a result of five major initiatives taken at the plant site and at headquarters in the Nuclear Generation department. These five major initiatives are: Capital Improvements, Management A\
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Changes, Engineering'Changos, the Nuclear Generation Business Plan, and the previously mentioned Results Improvement Program.
CAPITAL IMPROVEMENTS The DET noted several weaknossos rotated to deficiencies in the physical working environment. Thoso deficiencies includo inadoquate maintenance and laboratory facilities, insufficient office space to support headquartors personnel working at the sito, and inadequate communications and cooperation among site and headquarters personno!.
Capitalimprovements have boon planned for somo time as part of the FitzPatrick sito master plan. The master plan providos for the construction of major support facilities such as the interim radwaste storage building, the training facility including the control room simulator, three warehouses, and a sewago troatment plant, Initial construction activities for these facilities began in 1985. The next major building of the master plan to be construc'ed is the new administration / support facility. Other capital projects which will improve FitzPatrick performanco include an enhanced tolocommunication capability, and an integrated, company wide computer network.
The Authority's Trustoos provided specific approval for the administration / support facility in April,1991. Engineering has boon completed and construction is scheduled to begin in March,1992. Similarly, capital authorizations for the computer and communications systems woro made by the Trustoos in 1990 and 1991. All systems will be operational when the administration / support building is completed in 1993.
The new administration / support building wJi improve working conditions for the staN. it will bring together in r>ne location personnel and functions that had been spread throughout the site. The new facility will provide adequate working space for members of the plant staff and office space for headquarters personnel working at the plant. The new facility will include expanded electrical and mechanical maintenance facilities and new
        . I&C and radiological laboratories. Working together under one roof will increase toamwork, cooperation and communicction among the plant staff.
The coordinated telecommunication and computer networks will bring together the people and data of the Power Authority into a closer knit organization and strengthen communication between the plant and headquarters staff. Capabilities of the planned network _ include video-conferencing and electronic mail / data /c'ocument exchange systems. Video-conferencing will help bridge the distance between the headquarters office and the FitzPatrick site. For example, Authority personnel could have greater participation in meetings held at facilities other than their own to resolve issues quickly and discuss courses of action on an immediate basit hhout the delays associated with travel.
The integrated computer network currently being installed will allow easier access to relevant company data from any location. Elements of the new computer system include common financial, maintenance, document control, and planning and scheduling systems for the FitzPatrick and Indian Point 3 nucicar plants as well as for headquarters.            ,
These systems will standardize and coordinate the planning, scheduling, and conduct of work activities at the three locations. Electronic mail and document exchange between
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all NYPA locations will facilitato communication betwoon the personnel at the various     l
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MANAGEMENT CHANGES                                                                         i The Authority recognized management deficiencios at the FitzPatrick plant and took the following actions to improve management effectiveness. Mr. Harry P. Salmon Jr. was selected to becomo Re3ident Manager of the FitzPatrick plant. A graduate of the U.S. Naval Academy, Mr. Salmon also earned a master's degree in personnel administration and has completed a number of other graduate-level courses. Ho retired from the Navy as a Captain after 28 years of service, during which he commanded a nuclear submarine, a squadron of 12 submarines, and served in senior maintenance and operations posts. His experience as an administrator over technically complex operations makes Mr. Salmon well suited for the duties of Resident Managor.
During Mr. Salmon's ongoing training, former Resident Manager Radford J.
Converse is serving as the interim Resident Manager. Mr. Converse will return to his permanent position of Vice President-Nuclear Support in the headquarters office when Mr. Salmon becomes Resident Manager in early 1992.
Other management and organizational changes have also been made to improve organizational efficiency. The organizational structure of both the FitzPatrick and Indian Point 3 plants have been revised such hat the wide span of control of the Superintendent of Power is now divided among three newly creat9d General M17ager positions. This will increase management focus in the three key functional areas of Operation, Maintenance, and Support Services while reducing the number of people who report directly to the Resident Manager. The Resident Manager's position, as well as the positions of General Manageo-Support Services and Radiological and Environmental Services Manager woro filled with personnot hired from outside the Authority. Bringing in people from outsido the company will bring new methods and ideas to management activities.
Under the new organizational structua, all design and project engineering is consolidated under headquarters control, with site Technical Services providing day-to-
       ' day support to operations and mintenance personnel. A dcscription of the revised engineering organization is providM in the next section of this letter.
The New York Power Authority trustees and I have authorizad 48 new permanent positions to support operation of the FitzPatrick plant f 1992. Allocation of these positions to the various plant departments are being made judiciously. To overcome deficiencies in control room staffing noted by the DET, many of these positions are allocated to the FitzPatrick Operations Department. We will add an additional Reactor Operator to each control room shift crew, reinstitute the Shift Technical Advisor (STA) as a separate position apart from the combined STA/ Assistant Shift Supervisor, and add additional auxiliary operators. Other staffing increases allocated to the Training, Maintenance, ir strument and Control, and Radiological and Environmental Services departments will be used to improve plannin0 and procedures.
In addition,20 other positions in the Nuclear Generation Department have been created for persons in training. These positions will allow the Authority to develop qualified personnel replacements prior to vacancies occurring. This will benefit the operations department at both nuclear plants greatly since tN reactor operator license replacement training programs tako approximately 18 months and formerly were not held 3-

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until vacancies existed in the licensed operator ranks. Now, future staffing needs can be i     '
anticipated and accommodated. Additional staffing will be provided as necessary to implement the FRIP and Nuclear Generation business plan.
The Authority recognizes weaknesses that existed in our management
                - development process. To address this problem, an aggressive management training program has been implemented. Formal training in situational leadership and management skills are now being provided to supervisory personnel. The management skills training program for first line supervisors has been in place for four years and has run seventeen sessions. The middle managers training program was put in place in April,1991 and has run five sessions. A training program for NYPA senior managers and executives is also being developed, in addition, the Authority's Human Resources Department is revising the performance review program to emphasize our commitment to management and leadership skills. A job rotation program within the Nuclear Generation Department is also planned to enhance the professional development of our management staff, The Authority is committed to long term management and supervisor skills training programs to enhance the leadership abilities of our management personnel.
A Nuclear Leadership Team (NLT) has been created to provide the impetus to achieve excellence in all areas related to the Authority's nuclear power pregrani. This team consists of the Executive Vice President-Nuclear Generation, the three Vice Presidents at headquarters in the Nuclear Generation Department, plus the Resident Managers of both the FitzPatrick and Indian Point 3 nuclear power plants. This team has responsibility for all aspects of the New York Power Authority's nuclear program. A significant feature of the NLT is that both plant Resident Managers now participate in decisions for both nuclear power plants. Formerly, each Resident Manager had responsibility for his plant alone. The NLT will provide guidance and establish policies -
that will result in improved operation of the Nuclea Generation Department as a whole.
The NLT is headed by a new Executive Vice President-Nuclear Generation. He has been given the mandate to achieve excellence in nuclear pisnt performance and the authority to implement the changes needed to accc aptish this goal. He has my full support and that of the New York Power Authority Trustees in this effort.                   -
ENGINEERING ORGANIZATIONAL CHANGES The Authority determined that a number of organizational changes were necessary to strengthen engineering support for the Authority's two nuclear power plants. The major objectives of this reorganization were t focus engineering responsibility and accountability and to increase permanent std to more effectively support nuclear plant operation. To accomplish these objectives, a single engineering design authority was established in the headquarters office, while the FitzPatrick Technical Services department was revised to focused on plant day-to-day operational issues. Key organizational changes which strengthen engineering are discussed below.
A new site engineering organization was formed which reports to the headquarters Project Engineering division. This organization relieves Technical Services of its former plant modification, designiand direct engineering support responsibilities. This organization will be enlarged to 34 persons in 1992. Among this group's responsibilities l
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r  , are reduction of the plant modification backlog, closcout of existing plant modifications, and acceleration of the pipe support evaluation program.
An engineering prioritization program is underway within the site engineering section to establish and maintain a single comprehensive listing of requested and required engineering activities. A methodology has been established to prioritize engineering activities. A work flow process consisting of an
* Engineering Prioritization Flowchart" and a questionnaire for the originator of engineering requests will be used for the initial program. The process of prioritizing the 1200 item engineering backlog has begun. A new site engineering tracking system and a process to estimate engineering and installation resources and its application to scheduling work activities is also being developed.
The FitzPatrick Technical Services t epartment will be an operational support organization. Technical Services includes the system engineer group and the plant
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performance group. The system engineering group is responsible for resolving day-to-day operational problems, reviewing and sponsoring recommendations from industry operating experience data, and reviewing proposed plant modifications and other technical evaluations. Performance engineering is responsible for the FitzPatrick thermal and vibration monitoring programs, and for the pump and valve in4crvice testing programs. Eight new engineering positions have been allocated to Technical Services for 1992. A similar Technical Services organizational structure will also be implemented at the Indian Point 3 plant.
The separate engineering and design functions within the headquarters Nuclear Generation Department were consolidated under a single manager. The Nuclear Engineering and Design (NED) section is now responsible for all design engineering for both nuclear plants, enabling us to have unified engineering practices at all taree locations. Responsibility for the fire protection programs are now under this section.
Permanent staffing within the NED section will be increased in 1992 for the following engineering disciplines: fire protection (4 positions), set point control (2 positions),
hydraulic and HVAC analyses (2 positions), structural mechanice (3 positions), and electrical engineering (4 positions), A number of other new eng!nocring and support positions will be added in 1992.
The NED organization is in the process of establishing computerized engineering modeling tools to ensure more effective and focused control for the design process.
Engineering tools being developed include the electrical distribution systein model, the cable and raceway model, and the fire protection safe shutdown (Appendix R) model.
The Authority is supplementing its engineering staff with approximately 20 contractors under direct NYPA supervision to load data into these models and prepare implementing
,        procedures.
A separate configuration management section was established within the Nuclear Engineering Division. Included in the responsibilities of this secton is the Design Basis Document (DBD) program. The objective of the DBD program is to reconstruct the design basis of selected systems in the FitzPatrick plant by retrieving the FitzPatrick design calculations and analyses from the original design organizations and consolidating this information into an easily retrievable format. In addition, Nuclear Engineering is revising procedures to ensure a uniform set of engineering, design, and configuration control procedures; developing three dimensional CAD models of plant j       systems to facilitate design within areas of the plant not normally accessible during 5-
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    ' i- ,           operation; developing a contralized common database for all plant documents; and maintaining databasos.of as-built engineering models, An addisonal group will be established to control the day to-day planning and scheduling vithin the Nuclear Engineering Division.
NUCLEAR GENERATION BUSINESS PLAN While corporate and department goals have boon used in the past, the Nuclear Generation Department did not have a unified bus' ness plan. This led to each division within Nuclear Generation and the two nuclear plants developing individual goals and operational philosophies. Development of the Nuclear Generation Business Plan began in early 1991 with the objective of establishing coordinated goa!s for the nuclear organization, The Business Plan will be our primary vr hicle to focus our efforts and ach! eve consistency between the Authority's two nuclear power plants. The Business Pan identifies key business needs and forms a basis for determining resourco needs.
The plan will provide everyone in the Nuclear Generatica department with a single clear set of goals, and will identify each orgelzational unit's role in achieving the goa's.
The five objectives of the business plan are: nucloar and industrial safety, professionalism, performance, regulatory compliance, and cost management. Work groups addressing each objective were made up of representatives from both nuclear power plants and headquarters, and included individuals from Nuclear Generation, Training and Development, Human Resources, Budgets Audits, and Management Information Services Departments.
The Business Plan, consisting of strategies and action items, will be distributed in early January,1992. During 1992, the Nuclear Generation staff willimplement the action items while the Nuclear Leadership Team tracks progress and provides feedback. The plan will be reviewed and revised annually, taking in account factors such as performance, goals and objectives, and expc.anco. The Business Plan will also p ovide a foundation to determine the Nuclear Generation budget for the following year, FITZPATRICK RESULTS IMPROVEMENT PROGRAM The FitzPatrick Results improvement Program (FRIP) is an action plan for upgrading the performance of the FitzPatrick and headquarters staff as a result of specific issues ralr.ed in the NYPA and DET assessments. Tho goal of the FRIP is to go beyond correcting deficiencies by improving operations to the extent that the FitzPatrick plant becomes one of the best run nuclear power plants in the country. In all, the program identifies more than 600 specific actions, each linked to the root causes and contributing factors of the deficiencies. The program assigns responsibilities and schedules for completing each of the actions. The Nuclear Leadership Team will review and assess the progress towards meeting the objectives of the FRlP.
The 600 items of the FRIP have been classified into eight root cause categories:
Management Oversight, Direction and Support; Resources; Standards; Communications and Teamwork; Industry Experience; Leadership and Monitoring; Accountability and Attention to Detail; and, Planning and Scheduling for Maintenance and Engineering.
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i i    ,                               The FRIP was provided to the NRC's Region i Regional Administrator, Thomas T.
Martin, by FitzPatrick Resident Manager, Radic ' J. Converse, on December 19,1991 (JAFP 910834). Submittal of this letter in additi n to the FRIP constitutes the Authority's response to your request that the Authority "detsrmine the actions needed to assure timely resolution of performance ''oficiencies including your determination of root causes and your plans to address them.' This letter also addresses the actions taken to strengthen tha engineering support for our nuclear plants as you requested.
The DET report makes note of a number of positive attributes concerning the FitzPatrick plant staff. The plant operators are noted as having high level of experience and knowledge of the plant and good manipulation of the controls. The maintenance staft is described as experienced, knowledgeable and professional, leading to good performance in the conduct of maintenanco activities. The DET also recognizes initiatives taken in Engineering including the Design Basis Document and Drawing improvement programs. I am encouraged by these observations in that our people will form the basis for improved performance.
NYPA senior management is committed to improving the operation of the James A. FitzPatrick Nuclear Power Plant. Plant performance observed by the Authority through 1990 and 1991 was inconsistent with the standards the Authority sets for all its operations. The DET report accurately and appropriately confirms the problem areas.
The Chairman and Trustees of the New York Power Authority and I will provide the leadership and resources necessary to return the FitzPatrick plant to a high level of performa' ice and to make FitzPatrick and indian Point 3 industry leaders. I recognize our quest for excellence will not be easy and that it will not be accomplished overnight. The DET report acknowledges that the Authority has taken the first steps along this path, if you have any qwstions, please contact me.
Very truly yours, b
hohn C. Brons President and Chief Operating Officer New York Power Authority JCB/JG cc:                                           See next page i

cc:  U.S. Nuclear Regulatory Commission Mr. James H. Sniczek, Deputy Executive Director Mr, Thomas. T. Martin, Regional Administrator- Region l Mr. Thomas E. Murley, Director-Nuclear Reactor Regulation Mr. Edward L Jordan, Director-Office for Analysis and Evaluation of Operational Data Mr. James G. Partlow, Assoc' ate Director for Projects Mr. William T. Russell, Associate Director for inspection and Technical Assessment Mr. Jos6 A. Calvo, Assistant Director for Region i Reactors, Division of Reactor Projects-l/II Mr. Luis A. Reyes, Director, Division of Reactor Projects, Regico il Mr. Steven A. Varga, Director, Division of Reactc Projects-l/ll Mr. Robert A. Capra, Project Director, Division of Reactor Projects-l/II Mr. Brian C. McCabo, Projou Manager, Division of Reactor Prcjects-l/ll Mr. William Cook, Resident inspector
                . Document Control Desk New (ork Power Authority Mr. Richard M. Flynn, Chairman William D. Cotter, Trustee Hyman M. Miller, Trustee Robert T. Waldbauer, Trustee Rolland E. Kidder, Trustee i
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