ML102120045

2009/11/11-Applicant-Northard Exhibit 23-PRIDE Performance Recovery Plan

ML102120045
Person / Time
Site:	Prairie Island
Issue date:	11/11/2009
From:	Travieso-Diaz M Northern States Power Co, Pillsbury, Winthrop, Shaw, Pittman, LLP, Xcel Energy
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML102120039	List: ML102120040 ML102120041 ML102120042 ML102120043 ML102120044 ML102120045 ML102120046 ML102120047 ML102120048 ML102120049 ML102120050 ML102120051 ML102120052 ML102120053 ML102120054 ML102120055 ML102120056 ML102120057 ML102120058 ML102120059 ML102120060 ML102120061 ML102120063
References
50-282-LR, 50-306-LR, ASLBP 08-871-01-LR-BD01, RAS 18336
Download: ML102120045 (20)

Text

1 PRIDE Performance Recovery Plan VisionA strong nuclear safety culture is a key ingredient of any high performing nuclear organization. The PRIDE initiative is our platform for improving plant and organizational performance in order to recover our regulatory standing and achieve top industry performance. I need the support of every employee to embrace this plan and work with me to achieve the following vision: "We will achieve and sustain Excellence in Nuclear Safety through engagement of our people, trust in each other and our processes, and ownership of our plant". Mark Schimmel - Site Vice President ObjectivesThe primary objectives of the PRIDE Performance Recovery Plan are to achieve the following:1.Successful completion of the 95001 NRC Regulatory Inspections in the 2 nd and 4th quarter of 2009, and the 2 nd quarter of 2010.

Measures*Findings closed out as scheduled

• Achieve Column 1 for Unit 1 by 1 st Quarter 2010

• Achieve Column 1 for Unit 2 by 3rd Quarter 2010 2.Corrective Action Process Improvements completed Measures

• RCE/ACE Quality Grading Improves

• 1. of Repeat Issues drops by 50%

• A/B CAP Action Backlog is reduced by 25%

• Age of A/B action is reduced by 25%

• NOS rates CAP as meeting expectations

• No NRC Substantive Crosscutting Issues in CAP

• Additional Measures as described on GAP closure Plans 3.Human Performance Improvements completed Measures*# of Significant Events drops by 50%

• 1. of Site Clock Resets drops by 25%

• NRC Findings due to HU issues drops by 50%

• 1. of NOS Findings related to HU drops by 50%

2*No NRC Substantive Crosscutting Issues in HU

• Additional Measures as described on GAP closure Plans 4.The focus on becoming a process based organization through the Work Management Improvement (WMI) initiative remains on track 5.Issues Associated with Recovery Plan related RCEs are Closed Out Measures*RCE Effective Reviews rated as Effective 6.All NRC Substantive Crosscutting Issues are Closed Out

• SCC Issues closed in end of 2009 NRC assessment letter BackgroundIn 2008, Prairie Island received 2 greater than Green NRC Findings/Violations. These were related to the failure of the 11 TD AFW Pump following a Unit 1 reactor trip on July 31, 2008 resulting in a WHITE finding, and a radioactive material shipment which exceeded DOT package surface radiation level limits on October 31, 2008 resulting in a preliminary YELLOW finding. The first finding placed Prairie Island Unit 1 in NRC Reactor Oversight Process (ROP) Column 2, also known as the "Regulatory Response Column". The second finding, resulted in both units being placed in ROP Column 2. As a direct result of being placed in column 2 of the ROP, the NRC will schedule additional special

inspections to ensure that actions have been, or are being taken to correct the conditions that led to the greater than green violations. Additionally, there may be additional NRC inspections scheduled to ensure that the extent of condition and extent of the causes leading to the violations are also being adequately addressed to prevent similar issues from reoccurring. An additional preliminary White finding during the 3 rd quarter of 2009 was received, which was related to a HELB interaction with the Component Cooling system and affects Unit 2. This would keep Unit 2 in Column 2 until the completion of the Root

Cause Evaluation and an NRC 95001 inspection, expected in the 2 nd quarter of 2010. Root Cause Evaluations were completed for each of these regulatory issues.

Additionally, a Common Cause Evaluation was completed on these and other important Causal Evaluations and some of the assessments conducted in 2008 including 1) Independent Human Performance Assessment, 2) Management Safety Review Committee (MSRC) comments, 3) INPO Mid-Cycle Self Assessment, 4)

NOS 3 rd Quarter Report, 5) 2006-2008 A/B CAP Trend data, and 6) USA Safety Culture Self Assessment. Some key findings from the Root Causes and the Common

Cause Evaluation are described below:

31.Radiation Protection and Chemistry procedures do not describe the methods required to successfully evaluate, package, and ship materials and the significance the site has assigned the Radioactive Material Shipping Program (RMSP) do not align with the potential adverse consequences. 2.There are inadequate configuration controls for components that have the potential to adversely impact the design function of safety related Structures, Systems and Components (SSCs) and evaluation of past recurring issues involving components that affect the function of safety related systems have not implemented corrective actions of sufficient scope to remedy problems in other safety related systems. 3.Human Performance has not been a high priority with station management. Managers and Supervisors rationalize and tolerate poor HU behavior. Plant personnel have a tolerance for risk, rationalize it away, or don't consider it. 4.Station workers, supervisors and managers lack a clear picture of Excellence in Human Performance resulting in poor application of human performance

fundamentals.5.In some cases, causal factors stop at the symptom and inadequate use of the WHY staircase has led to missed learning opportunities and development of corrective actions that may not solve the problem. 6.Ineffective or noncompliant use of processes has contributed to insufficient resolution of equipment problems and to delays in addressing emergent issues.7.Workers demonstrate low levels of discipline and accountability to follow station procedures and fail to seek clarification when procedural controls are deficient.

8.Station procedures and work instructions do not cover pertinent situations and contain all relevant information.The PRIDE Performance Recovery Plan will be the controlling document to track completion of all improvement activities essential to achieving excellent organizational performance. The PRIDE Recovery Team, working with Prairie Island Plant Staff in an integrated and coordinated manner, will ensure that all actions are completed per the schedule and are measured for effectiveness following completion.

Key contributors to the success of the plan include:

• The full commitment and cooperation of Prairie Island and fleet personnel.

• Clearly defined roles and responsibilities for PRIDE Improvement Teams

• Decision-making is timely, clear to all, and communicated to Prairie Island and fleet personnel

• Schedules for completing recovery plan actions are developed and communicated to Prairie Island and fleet personnel 4*A significant shift in safety culture, evidenced by behavioral changes among employees driving improved performance at Prairie Island

• Emergent issues that are potential barriers to success are promptly identified, prioritized and resolved.

Scope of PlanThe scope of work addressed by the PRIDE Performance Recovery Plan is outlined in the following nine (9) performance improvement areas:

• Radioactive Material Packaging and Shipping Program Improvements

• Component Labeling Improvements

• Conservative Decision-making Issue Resolution

• Thorough Evaluation of Problems Resolution

• Corrective Action Implementation Issue Resolution

• Procedure Quality Improvements

• Following Procedures (PU&A) Issues Resolution

• Human Performance (HU) Fundamentals Improvement

• Consistent Application of Station Processes and Rigorous Coaching to the Behaviors that Support Process Discipline ResponsibilitiesThe Recovery Team organization was established to develop and implement a comprehensive recovery plan to return Prairie Island to ROP Column 1 at the earliest opportunity and improve overall station safety culture to industry leading levels. This includes both the Human Performance and Corrective Action Program areas. The Performance Recovery Team Manager is responsible for the execution of the Recovery Plan and is the primary interface with the other PRIDE improvement initiatives and the plant organization. The Recovery Team is specifically responsible

for: *Overseeing the integrated implementation of the PRIDE recovery actions

• Coordinating the interfaces between improvement areas

• Ensuring that crosscutting issues are consistently addressed within each improvement areas

• Assessing completeness and effectiveness of improvement areas

• Assessing readiness for the 95001 inspections

• Implementing the NRC 95001 Inspection Readiness Plan

• Communicating and reporting PI Site Management and staff the schedule and status of implementation Although the Recovery Team organization is largely responsible for overseeing and coordinating the implementation of the Recovery Plan, the Site Management and plant 5staff (line organization) are responsible for implementing the changes in performance and behaviors that are critical to the success of the plan. PRIDE Performance Recovery Team NRC Inspection Key Actions and MilestonesThe Recovery Plan actions and milestones are maintained in Appendix 3. Key project milestone dates are as follows: 4/3/09 Staff Recovery Plan Development Team 4/17/09 Recovery Plan Drafted 4/30/09 Complete Common Cause Evaluation 5/8/09 Train Root Cause Evaluators 6/5/09 Complete Reconstitution of Root Cause/Apparent Cause Evals 6/17/09 Update Recovery Plan based on RCE/ACE Reconstitution 8/26/09 95001 NRC Inspection for AFW Misposition Issue 12/1/09 95001 NRC Inspection for RP Shipping Issue 1/1/2010 Return Unit 1 to ROP Column 1 3/1/2010 95001 NRC Inspection for CC/HELB Issue 10/1/10 Return Unit 2 to ROP Column 1 Planning and ExecutionThe successful completion of the PRIDE Performance Recovery Plan is critical to the long term success of the Prairie Island organization. Instilling the Principles for a Strong Nuclear Safety Culture into our daily behaviors will ensure that we always

treat nuclear technology as special and unique with the highest level of respect.

"Nuclear safety must always be our top priority, and this will be demonstrated through our values and behaviors, and reflected in our actions every day."

Kevin Ryan - Plant Manager NRC 95001 Inspection ReadinessThe PRIDE Recovery Team is responsible for assessing PI's readiness for the NRC 95001 inspections. Readiness will be based upon the following:

• PRIDE Improvement teams are staffed.

6*PRIDE Improvement Team deliverables are identified.

• Corrective Actions to address the NRC 95001related root causes and common cause are identified, prioritized and scheduled.

• Corrective Actions related to management assessments are identified, prioritized and scheduled.

• Ten percent (10%) of the action item closure packages are complete and verified acceptable by the PRIDE Action Item Closure Team.

• Any identified procedures, instructions and guidelinechanges are complete and implemented.

• At least one team of Root Cause Evaluators has been trained to the revised

process.*Remedial actions for rejected closure packages, if any, are scheduled.

• Interim measures for the Common Cause are identified and established.A PRIDE Recovery Action Item Closure Team has been established to review action items related to the NRC 95001 inspection and ensure that documentation is complete and available in order to expedite NRC review during the inspection. The PRIDE Action Item Closure Team will function as a subcommittee of the PARB. The PRIDE Action Item Closure Team Charter and Action item Closure Process Flow Diagram are in Appendix 1.

Communications The PRIDE 95001 Communications Plan is attached, and will be kept up to date as we make progress in the improvement initiatives.

AttachmentsFigure 1 - Recovery Team Organization Chart Figure 2 - Strategic Plan Appendix 1 - Closure Team Charter

Appendix 2 - Recovery Plan Schedule

Appendix 3 - Actions and Milestones

Appendix 4 - Recovery Communications Plan

Appendix 5 - NRC Inspection Plan Other AttachmentsAFW Labeling Improvement Plan RP Shipping Improvement Plan Site HU Improvement Plan - Target Zero Site CAP Improvement Plan

NRC Inspection Preparation Manual 7APPENDIX 1Performance Recovery Plan Closure Board Charter PURPOSEThe purpose of this administrative instruction is to direct the process and methodology for implementing the Prairie Island Nuclear Generating Plant Performance Recovery Plan (PRIDE).

1.1 ApplicabilityThis instruction is applicable to the Prairie Island Nuclear Generating Plant Performance Recovery Plan (PRIDE). 2.0 PRIMARY RESPONSIBILITIES2.1 A Closure Board, consisting of independent outside industry experts and corporate executive management, will provide oversight of the implementation and effectiveness of the Performance Recovery Plan (PRIDE).. This board will meet on an as needed basis upon completion of the focus areas (level one) associated actions (attachment 1). 2.2 The Nuclear Oversight organization will provide independent review and assess the adequacy and effectiveness of level two actions (attachment 2) completed as part of the Performance Recovery Initiative. This organization will review all completed improvement actions every 8 - 10 weeks initially or when requested by the Recovery Team Manager or Closure Board Chairman. 2.3 The Site Vice President provides direction and oversight of the Performance Recovery Plan (PRIDE). 2.4 The Recovery Team Manager is responsible for overall direction and management of the Performance Recovery Plan (PRIDE) and provides oversight to the station Recovery Team.

82.5A station Recovery Team has been established to oversee the implementation of the Performance Recovery Plan Initiatives and to assist the line organization in the completion of their assigned tasks as requested. The recovery team owns the plan and is solely authorized to modify the plan elements and structure, including but not limited to oversight, and approval for the action plan goal(s), scope, actions, metrics, implementation timeframes, and completion effectiveness. The organization will also update the Senior Leadership Team on routine assessments of the actual progress and effectiveness of actions within the Performance Recovery Plan (PRIDE). 2.6The responsibilities of the Management Owner are to ensure that the actions are completed and produced the desired results prior to presentation for closure. 2.7 The Assigned Individual for each action will be responsible to ensure that the action is completed in accordance with the defined scope and timeframe. Any questions on scope, timeframe, or intent should be referred to the recovery team. Assigned individuals or management owners require the approval of the recovery team to change either scope or due date for assigned actions. The assigned individual will partner with the Management Owner to ensure action effectiveness.

9 10APPENDIX 4 Pride Initiative - Recovery Plan Internal Communications PlanOBJECTIVE: Communicate the Prairie Island's Recovery Plan to Prairie Island employees, the Nuclear Department, Xcel Energy employees and our regulators. Educating and aligning management and workforce on 95001 inspection:

o What is the NRC Reactor Oversight Process?

o What is a 95001 inspection?

oWhy is it taking place; how did we get into this situation (root cause, contributing causes) oWhat are the 95001 inspection objectives?

oWhat are we doing to fix the situation?

oWhat is the role of all employees on site regarding the inspections? Educating and aligning management and workforce on the site's recovery plan.

oIntroduce the Recovery Plan team oWhat is the Recovery Plan?

oWhat are we doing to recover?

oWhat is the role of all employees on site regarding the Recover Plan?

What Start date End date Owner Who Delivers Method Venue Complete Frequency 95001/95002 inspection introduction to managers and supervisors 5/1/095/15/09 Scott Northard Communications DepartmentPresentation Leadership &

Alignment Meeting Once Managers hold departmental briefings prior to inspections -how to communicate w/ NRC -what to expect -scope of inspection 6/099/09 Communications Department Department ManagersFace-to-FaceDepartment All Hands Meetings Once for each inspection95001/95002 inspection updates to managers and supervisors 5/1/099/09 Scott Northard Scott Northard Presentation Leadership & PI Alignment Meeting At least once per month 95001/95002 inspection: Series of articles from Scott Northard March 11: RO Process 03/11/09 9/09 Scott Northard/ Communications DepartmentCommunications Department Print and

Face-to-FaceTeam Notes Face-to-

Face/D-15 meetings 11 What Start date End date Owner Who Delivers Method Venue Complete Frequency Action Matrix What is a 95001 inspection/objectivesWhy is PI in Column 2? What are we doing? What is employee's role? Progress Updates during inspectionPublish link to entire 95001/95002 article series document on Pride Initiative Sharepoint webpage 4/0909/09 Communications DepartmentCommunications Department Print and

Electronic MediaLink on PI Net webpage Duration of inspection phase Partnership to Xcellence Information Guide 8/098/09 Communications DepartmentCommunications DepartmentPrint Media Booklet for all site employees Create bulletins with 95001/95002 inspection notices 6/099/09 Communications DepartmentCommunications Dept creates &

publishes at PI Electronic

MediaVisix site monitors As needed Recovery Plan organization introduction to managers and supervisors 4/094/09 Scott Northard Scott Northard Presentation Leadership &

Alignment Meeting at PI Once Recovery Plan: Series of articles from Scott NorthardRecovery Plan organization Recovery Plan basics Role of employees 4/0912/31/09 Scott Northard/ Communications

Department Print and Face-to-FaceTeam Notes Face-to-Face/D-15 meetings Establish weekly Recovery Plan updates including 95001 inspection updates to the workforce-under Scott Northard's name 4/0912/31/09 Scott Northard/ Communications DepartmentComm Dept writes articles/

Supervisors deliver in D-15 meetings Print and

Face-to-FaceTeam Notes Face-to-

Face/D-15 meetings Weekly Create Recovery Plan web page 4/094/09 Scott Northard/ Communications IT (Debbie Eppen)Electronic

MediaNuclear Dept internetCompleted 4/09 12 What Start date End date Owner Who Delivers Method Venue Complete Frequency Department Communicate the existence and location of the Recovery Plan Web page 5/095/09 Communications DepartmentCommunications DepartmentPrint Media Team Notes Once and include information

on the web site in each monthly Team Notes

update Posters 5/0912/31/09 Communications DepartmentCommunications

DepartmentPrint Media Posters As needed Recovery updates to workforce through site-wide all hands meetings 04/30/09 08/09 Scott Northard Scott Northard Face-to-FaceAll Hands Meeting Once in April 2009 &

August 2009 Include a discussion of recovery plan in the monthly 2Cs meetings 5/0912/31/09 Scott Northard Brad Sawatzke Face-to-Face2Cs meetings Monthly Include a discussion of recovery plan at Leadership Forum 5/0912/31/09 Scott Northard Scott Northard Face-to-FaceLeadership Forum Monthly Updates to managers at PERG meetings 5/0912/31/09 Scott Northard Scott Northard Face-to-FacePERG meetings Weekly Update NRC Resident Inspectors 6/0912/31/09 Scott Northard Scott Northard &

Jon Anderson Face-to-FaceFace to face meetings Bi-weekly Update NRC Branch Chief (Jack Geisner)6/0912/31/09 Scott Northard Scott Northard &

Jon Anderson Telephone conferenceConference calls Monthly Update NRC Regional Management (Steve West & Cindy Peterson) 6/0912/31/09 Scott Northard Scott Northard &

Mike Wadley Telephone conferenceConference calls Monthly UpdatesUpdate NRC (Mark Satorious) Drop in visits: -introduce plan 6/0912/31/09 Scott Northard Scott Northard, Mike Wadley &

Dennis Koehl Face-to-FaceDrop in visit @

Regional Office Once 7/09 &

12/09 13 What Start date End date Owner Who Delivers Method Venue Complete Frequency -update on actions complete & open -effectiveness measures -behaviors that changed Updates to community stakeholders - PI Indian Community & local officials 6/0912/31/09 Scott Northard Mike Wadley Face-to-Face

& emails Informal meetings Quarterly INPO communications Brad Swatzke & Kevin Ryan Face-to-FaceDrop in visits Quarterly 14APPENDIX 5NRC INSPECTION 95001 INSPECTION READINESS PLANPRAIRIE ISLAND INSPECTION OBJECTIVES The primary objective of the NRC 95001Readiness Plan is to demonstrate the effective implementation of CAP and Human Performance. Specifically, demonstrate that corrective actions to prevent recurrence have been identified and are being implemented for conditions that resulted in the FNP degraded cornerstone. Success is defined as satisfying NRC inspection objectives such that the inspected areas contain no significant weaknesses.

RESPONSIBILITIES The Management Sponsor is the Site Vice President and will provide overall responseand team direction. In addition, the Recovery Team Manager is responsible for identifying response team members and obtaining commitments from appropriate management for continued timely participation in accordance with the inspection

schedule.PRIDE 95001 Recovery Team is the lead organization and is responsible for coordinating inspection activities, The Recovery Team is responsible for:

Coordinating a mock inspection in the style of an NRC inspection.

Developing the NRC 95001Inspection Communication Plan.

Developing the NRC 95001 Inspection Schedule.

-Establishing and maintaining an NRC Q&A database to track inspector requests for information and issues.

The NRC 95001 Inspection Response Team consists of the following members: - Technical lead - Scott Northard- Recovery Team Staff

- PRIDE Recovery Improvement Team Staff

- Performance Assessment (P1) staff

- Station Licensing representative

- Fleet representative

- Root Cause Evaluation (RCE) leads for AFW Mispo and RP Shipping Issues

- Common Cause lead

- Engineering representative 15APPENDIX 5 NRC INSPECTION 95001 INSPECTION READINESS PLAN - Operations representative- Maintenance representative

- Administrative support - IT support, as neededThe NRC 95001 Inspection Response Team (IRT) responsibilities include: -Coordinate NRC 95001 Inspection task assignments -Coordinate NRC 95001Inspection related meetings -Coordinate NRC information requests

-Coordinate assignment, response development and issue resolution to NRC questions-Provide daily status to management during the conduct of the NRC 95001 inspection-Ensure timely documentation of NRC 95001 Inspection issues in CAP -Coordinate post NRC 95001 Inspection critiquePRE-INSPECTION ACTIVITIES PRIDE Recovery Inspection Team Logistics Coordinate site access, badging and dosimetry for NRC 95001 Inspectors through the site NRC senior residentProvide NRC 95001 Inspector facility setup, support, and equipment needs Designate central location for the NRC 95001/95002 Inspection Response Team, and ensure location has appropriate equipment (e.g., telephones, computers, printers)

Management Sponsor Select and assign members of the NRC 95001 Inspection Response Team 16APPENDIX 5 NRC INSPECTION 95001 INSPECTION READIN1SS PLAN PRIDE Recovery Team Preparation Coordinate the collection of technical and reference information requested by the NRC prior to the inspection (e.g., ARs, closure packages). Perform quality checks of the information collected. Ensure documents containing proprietary information are marked in accordance with 10CFR2.390.Perform independent assessment of all white findings. The purpose of the independentassessments is to verify the completion and adequacy of Root Cause Evaluations and corrective actions.Brief NRC 95001Inspection Response Team members on the NRC Reactor Oversight Process (ROP), NRC Inspection Procedures, and FNP protocol and communication expectations (attached). Cover the following NRC related items: 1ROP Cornerstones and Objectives 2Inspection elements (baseline, supplemental, generic safety issues, special/infrequent)

3. Relationships between Inspection Findings and Performance Indicators (PIs),

including:

ROP Cornerstones PIs ProblemIdentification and Resolution (PI&R) Safety Culture INSPECTION ACTIVITIES PRIDE Recovery Team Notify senior management (e.g., Vice President and Plant Manager) of the dates, times, and locations for the entrance and exit meetings. The expectation is that senior management will attendthe entrance and exit meetings.

17APPENDIX 5 NRC INSPECTION 95001INSPECTION READINESS PLAN Track NRC comments and questions. Issue a daily Outstanding Issue Report including the issue owner and status.

NRC 95001 Inspection Response TeamCoordinate assignment, response development and issue resolution to NRC questions.NOTE: Every attempt should be made to resolve inspection issues before the close of the inspection.

Daily Debriefs with NRC Inspectors.Provide daily status to management during the conduct of the NRC 95001 Inspection. Ensure timely documentation of inspection issues in CAP.Promptly notify management of outstanding disagreements and unresolved issues. For significant issues, debrief senior management prior to the NRC 95001 Inspection exit.POST-INSPECTION ACTIVITIES NRC 95001 Inspection Response Team/Line Organization Coordinate post NRC 95001 Inspection critique.Within 30 days of receiving an NRC 95001 Inspection Report:

Ensure that ARs are/were initiated for NRC findings and Prairie Island actions taken to address NRC concerns during the inspection.

Coordinate the development of written responses for each finding. If a response is not available within 30 days, provide a schedule when a response will be sent to the NRC.

Identify any new Prairie Island commitments.

Correct or clarify inaccuracies in the NRC Inspection Report.

18FIGURE 1 Recovery Team Organization Chart 19 FIGURE 2 20