ML20248D446

Response to NRC Diagnostic Evaluation Team Rept for Brunswick Plant & Supporting Organizations

ML20248D446
Person / Time
Site:	Brunswick
Issue date:	09/30/1989
From:	CAROLINA POWER & LIGHT CO.
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NUDOCS 8910040264
Download: ML20248D446 (120)

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l RESPONSE TO I NRC DIAGNOSTIC EVALUATION TEAM REPORT I FOR I BRUNSWICK PLANT AND I SUPPORTING ORGANIZATIONS I

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kh! ILb l Carolina Power & Light Company SEPTEMBER 1989 RM 288M 8?8 %

I I NRC DIAGNOSTIC EVALUATION REPORT RESPONSE CONTENTS Pace Executive Summary 11 Acronyms viii Section I. Introduction and Index to Section II 1 ,

Section II. Responses to Individual Findings 4 Section III. Integrated Action Plan (IAP) 56*

I Appendix 1 Integrated Action Plan Model Al-1 Appendix 2 organization Analysis Information A2-1

• IAP Document follows page 56 and is uniquely numbered beginning at page 1 of 20.

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EXECUTIVE

SUMMARY

The NRC Diagnostic Evaluation of the Brunswick Nuclear Project (BNP) and its_ supporting organizations was conducted over the period April 10-21 and May 1-5, 1989, by an 18-member NRC team.

The NRC Diagnostic Evaluation Team (DET) Report was issued on August 2, 1939.

l The CP&L corporate and Brunswick management team has carefully i reviewed each of the findings and conclusions of the NRC DET Report, with special emphasis on the five key management areas identified by the NRC. The review included the recommendations, findings, and actions resulting from the Corporate Management oversight Team assessment, the Nuclear Management Appraisal by Cresap, the corporate Organization Analysis, as well as the NRC DET Report. This review concluded that:

o the findings and conclusions of these initiatives were generally consistent; o in the aggregate, the findings and conclusions applied to all aspects of management; and o numerous major and minor corrective actions are required to achieve long-term - CP&L corporate nuclear and BNP operational excellence.

Based on these conclusions, this response addresses each of the DET Report's findings; provides an Integrated Action Plan (IAP)~ that integrates actions resulting from both the DET Report and CP&L initiatives; and groups findings and responses into their appropriate management component. This assures a comprehensive i

response. The DET findings and responses have been grouped into the following management components:

o Leadership and Direction o Organization Design o Priority Management o Process / Program Management o Performance Measurement o Human Resource Management o Desired Culture ii

1 To facilitate identification of the areas within the Integrated Action Plan that specifically address DET Report findings,' the tabulated format contained in Section I of this response shows the correlation of each finding with an action plan component.

Further,Section II provides a discussion of relevant information and improvement actions for all the DET findings. NRC-noted strengths are also listed in this section. Section III of this response contains the Integrated Action Plan, summarizing actions to be taken, responsible individuals, and target completion dates.

In addition to responding to the NRC DET Report, the Integrated Action Plan is designed to address remaining open items from the Corporate Management Oversight Team recommendations and the Cresap Nuclear Management Appraisal recommendations. Finally, appendicer I are included to illustrate our integrated management model and to summarize organizational results of the Organization Analysis.

l The NRC DET Report summarized the root causes of the basic issues that must be properly addressed to assure that the CP&L corporate nuclear program and Brunswick operate at the level of excellence expected by both CP&L and the NRC. Taken as a whole, the results being achieved from recent initiatives, and results from actions noted in the responses to the DET Report's specific findings, will ensure that we continue to move toward our goal of noclear operational excellence.

The NRC DET Report's statements of Root Causes (R.C.) and Management Attention Areas (M.A.A.), and a summary of applicable CP&L actions, are contained in the paragraphs that follow.

(1) Root Cause/Manacement Attention Area R.C. Inadequate corporate management coincident with a period of past site management weaknesses.

M.A.A. Implementation of an effective corporate oversight program to provide leadership and direction, and to accurately monitor and assess Brunswick performance.

Discussion The past management deficiencies, at both' site and headquarters, have been addressed by recent and significant changes to the senior management personnel and realignment of organizational responsibility. In addition, the processes for accountability and oversight will be further strengthened as we implement additional recommendations from cur self-initiated, and recently completed, evaluations, iii

As an e.xample, we now have all nuclear functions reporting.to a single senior officer who has extensive nuclear experience and has responsibility only for nuclear activities.

Furthermore, at Brunswick, three of the top four managers have been assigned to their positions within the past fifteen months.

We have also strengthened the processes for corporate oversight of nuclear activities by defining and communicating more clearly accountabilities and the means for continually assessing the performance of plant management. For example, the monthly managers' meeting conducted by the Senior Vice.

President - Nuclear Generation will set expectations, stress performance, and emphasize the measurement and reporting of results against planned activities and goals. We will also use this meeting to foster culture stressing timely, open, and comprehensive communications as a means of building consensus and assuring ' reasonable consistency among the three nuclear sites and the corporate support functions.

(2) Root Cause/Manacement Attention Area R.C. The failure to clearly define and communicate site goals, priorities, and expectations.

M.A.A. Definition of site safety goals, prioritien, and expectations which are effectively communicated to and understood at all levels.

Discussion CP&L acknowledges that goals, priorities, and expectations had not been fully defined and communicated to all organizational levels. Several recent recommendations and consequent CP&L actions are focused on developing a communications strategy that is methedical, highly visible, and employee centered.

l CP&L corporate nuclear goals are developed to reflect corporate expectations. We are working to ensure that goals are supported by detailed department and plant plans, to ensure that goals are understood by employees and meaningfully reflected in the employees' day-to-day work.

Both formal and informal processes will be used to reinforce commitment to goals and to identify (and overcome or mitigate) challenges and obstacles to success. These processes are being developed on the basis of feedback given us by Cresap's communications, values, and rewards survey, l iv i

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(3) Root Cause/Manaaement Attention Area R C. Cultural issues including (a) the failure of CP&L management to adequately review and understand Brunswick's level of performance, and (b) the lack of individual accountability and teamwork.

M.A.A. Implementation and monitoring the effectiveness of actions to establish the desired culture at Brunswick.

Discussion CP&L's commitment to understanding and resolving cultural issues that have led to operational difficulties has been demonstrated by our undertaking of Cresap's communications, values, and rewards methodology. This technique has provided a clear assessment of cultural obstacles that we must overcome. We have begun that process with the most important first step--communicating the results of that survey to our employees. These communications emphasized management's sincerity in listening to en.ployees and our commitment to take action on the cultural issues raised. Additional recent initiatives to address cultural issues include the establishment of new management teams (at corporate and Brunswick) and concurrent process changes to improve communications and senior management (corporate) oversight and direction. These steps will help resolve the earlier separation that gave rise to the perception of autonomous plants that owed minimal allegiance to corporate.

j We hold that communications is also the key to the improvement of teamwork and the acceptance of the concept that r_aking your peer a winner also results in making you a winner. To that I end, we are pleased that the DET noted the various human

) resource development activities underway at Brunswick, with q "the . . . managers . . . serving as role models . . .

" It l is our ultimate goal to instill thic thinking in all our l managers. We are determined that, through the communications and oversight process, we will ensure the transfer of good programs and actions among the sites.

Additionally, CP&L is committed to making more effective use of corporate assessment functions to improve the level of performance of our nuclear operations. Steps have been initiated which will result in a stronger emphasis on corporate performance assessment of plant operations.

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1 (4) Root Cause/Manacement Attention Area R.C. An ineffective root cause determination and corrective action program.

M.A.A. Implementation of an effective corrective action program having a lower threshold for problem identification and effective measures for root cause .

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! D.ingu1l:sion CP&L is developing a corrective action program that should result in the long -term, effective resolution of the full range of problems to which this technique should be applied..

Inputs and participation are being solicited from all three operating plants and supporting organizations. Also,-guidance available from the Institute of Nuclear Power Operations is being used. We are training personnel in the use of this important tool.

In the interim, Brunswick's Corrective Action Program has been revised to assure a more rigorous and thorough pursuit of root causes. A repetitive failure program, implemented in April 1989, has resulted in a .significant decline in repetitive component failures, and aggressive management attention and I emphasis to reduce the overall number of troubled components in the plant has yielded significant positive results.

(5) }Lqpt Cause/Manacement Attention Areg R.C. An ineffective engineering design and technical support program.

M.A.A. Implementation of an integrated program to correct engineering design and technical support weaknesses involving both equipment failures and support activity weaknesses such as configuration control and safety evaluations.

Discussion Prior to organizational changes made in March 1989, engineering and technical support functions for Brunswick lacked clear definition of accountability. Changes were made in the mission and organization of engineering support groups for Brunswick to remedy this situation.

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' Brunswick is ' now ' supported by two ' focuse'd and dedicated 4 engineering' organizations. . The plant Technical Support Unit' is targeted.on day-to-day plant. engineering support to plant operations and performance needs. The corporate-based Nuclear j Engineering E Department - is the. " Engineer: of Record" for . the plant and is charged with meeting the design needs of the plant.

l The managers of these organizations fully' understand their responsibility for the corrective actions necessary to both i.

satisfy the. findings of the-NRC DET and the' self-initiated.

reviews and - to fully support Brunswick management in its efforts to meet its numerous and significant challenges. ,

' _l CONCLUSION '

CP&L appreciates the opportunity ' to respond to the NRC's DET' Report, which has provided findings that both compliment and supplement those of our self-initiated evaluations. We have responded to.the NRC DET findings through our Integrated Action Plan that we believe provides appropriate emphasis on the five NRC-identified areas that require additional management attention.

As noted in our discussion of each area above, we are confident that we have the : foundation in place such that, with continual management oversight, dedication, and hard work, we can further move the performance of ~ Brunswick and the entire CP&L nuclear program toward our goal.of operational and management excellence.

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) ACRONYMS A/E ARCHITECT /E!!GINEER ALARA AS LOW AS REASONABLY ACHIEVABLE AMMS AUTOMATED MAINTENANCE MANAGEMENT SYSTEM l ASME AMERICAN SOCIETY OF MECHANICAL ENGINEERS l BIP BRUNSWICK IMPROVEMENT PROGRAM BNP BRUNSWICK NUCLEAR PROJECT BSEP BRUNSWICK STEAM ELECTRIC PLANT BWR BOILING WATER REACTOR CDO CENTRAL DESIGN ORGANIZATION CMOT CORPORATE MANAGEMENT OVERSIGHT TEAM DET DIAGNOSTIC EVALUATION TEAM ECCS EMERGENCY CORE COOLING SYSTEM EER ENGINEERING EVALUATION REPORT ENP ENGINEERING PROCEDURE EOP EMERGENCY OPERATING PROCEDURE ERFIS EMERGENCY RESPONSE FACILITIES INFORMATION SYSTEM EWR ENGINEERING WORK REQUEST FSAR FINAL SAFETY ANALYSIS REPORT GDC GENERAL DESIGN CRITERIA GL GENERIC LETTER HNP HARRIS NUCLEAR PROJECT HPCI HIGH PRESSURE COOLANT INJECTION HPES HUMAN PERFORMANCE EVALUATION SYSTEM IAP INTEGRATED ACTION PLAN IGSCC INTERGRANULAR STRESS CORROSION CRACKING INPO INSTITUTE OF NUCLEAR POWER OPERATIONS IPBS INTEGRATED PLANNING BUDGETING AND SCHEDULING ISI IN-SERVICE INSPECTION IST IN-SERVICE TESTING JCO JUSTIFICATION FOR CONTINUED GPERATION LER LICENSEE EVENT. REPORT LOR LICENSED OPERATOR RETRAINING MAC MOTOR ACTUATOR CHARACTERIZED MOV MOTOR OPERATED VALVE NCR NONCONFORMANCE REPORT NED NUCLEAR ENGINEERING DEPARTMENT .

NLS NUCLEAR LICENSING SECTION NPMP NUCLEAR PLANT MODIFICATION PROCEDURE NPSS NUCLEAR PLANT SERVICES SECTION NRC NUCLEAR REGULATORY COMMISSION NRR NUCLEAR REACTOR REGULATION NUMARC NUCLEAR MANAGEMENT AND RESOURCES COUNCIL ONS ON-SITE NUCLEAR SAFETY PAM PROCEDURES ADMINISTRATIVE MANUAL PCIV PRIMARY CONTAINMENT ISOLATION VALVE PID PROJECT IDENTIFICATION PLP PLANT PROGRAM PM PREVENTIVE MAINTENANCE .

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1 PT PERIODIC TESTING RHR RESIDUAL HEAT REMOVAL

. RNP ROBINSON NUCLEAR PROJECT RO- REACTOR OPERATOR- '

SLC' STANDBY LIQUID CONTROL SPDS SAFETY PARAMETER DISPLAY SYSTEM SRO SENIOR REACTOR OPERATOR SSFI SAFETY SYSTEM FUNCTIONAL INSPECTION STSS SURVEILLANCE TRACKING AND SCHEDULING SYSTEM SWFCG SITE WORK FORCE CONTROL GROUP

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TECHNICAL SPECIFICATION TSI TECHNICAL SPECIFICATION INTERPRETATION WR/JO. WORK REQUEST / JOB ORDER l

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I. INTRODUCTION AND INDEX TO SECTION II The CP&L corporate and Brunswick management team has carefully reviewed each of the findings and conclusions of the NRC DET Report,.and as well as related actions already taken or planned that' resulted from other CP&L-initiated performance improvement initiatives (over 200 ' items). This review included recommendations, findings, and actions resulting from the Corporate p Management Oversight Team assessment, the Nuclear Management l Appraisal by Cresap, the corporate Organization Analysis, and the NRC DET Report.- This review concluded that:

o the findings and conclusions of these initiatives were quite consistent; o in.the aggregate, the findings and conclusions applied to all aspects of the management process; and o numerous major and minor corrective actions would be required to achieve long-term Brunswick operational excellence.

Based on these conclusions, an Integrated Action Plan model

'(described in Appendix 1) was developed. The purpose of the model was to provide clear focal points for improvement actions. The model's key management components are:

o Leadership and Direction o Organization Design o Priority Management o Process / Program Management o Performance Measurement o Human Resource Management o Desired Culture Once the model was established, each of the DET Report's itemized Section 2.0 findings, each of Cresap's recommendations, etc. were assigned to their appropriate management component and subgrouped by topic. i Section II addresses all of the DET Report findings--organized as described above. A tabulated format and index follows:  ;

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. TABULATED FORMAT A. Leadership and Direction D. Process /Procram Management (Cont'd)

Strength: 2.1.2 (2) Topic: Safety Evaluations / Reviews Topic Goals, Priorities, and Expectations Topic: Business Planning Findings: 2.1.1 (3), 2.1.1 (5), Findings: 2.1.1 (8), 2.1.6 (9) 2.1.2 (4)

Topic: Standardization B. Ornaniration Desian Finding: 2.1.4 (4)

Toolc Organizational Study Topic: Training Finding: 2.1.1 (1) Finding: 2.1.2 (13)

Topics Accountabilities and Topic: Work Management Responsibilities findings: 2.1.2 (7), 2.1.3 (3),

Findings: 2.1.2 (11), 2.1.3 (9), 2.1.4 (E), 2.1.4 (9),

2.1.6 (12), 2.1.6 (13) 2.1.6 (6)

Topics On-site WED - Educational Topic: Corporate Guidance Qualifications Findings: 2.1.2 (B), 2.1.4 (5)

Finding: 2.1.6 (15)

E. Performance Measurement Topic: Instructor Morale Finding: 2.1.2 (12) Topic: Control Room Log Entries Finding: 2.1.2 (3)

C. Priority Management Topic: Corporate Quality Assurance Topic: Priorities (General) Finding: 2.1.5 (3)

Findings: 2.1.1 (6), 2.1.2 (10),

2.1.3 (7), 2.1.6 (10), Topic: IST Cor,trols 2.1.6 (11) Finding: 2.1.4 (6)

Topic: Priorities (Specific) F. Ht.rnen Resource Menacement Findings: 2.1.2 (9) 2.1.6 (7) Strengths: 2.1.2 (5), 2.1.5 (1) l D. Process / Program Management topic: Career Development Finding: 2.1.1 (10)

Strengths: 2.1.2 (14), 2.1.3 (1),

2.1.3 (2), 2.1.3 (4), G. Desired Culture 2.1.3 (5), 2.1.4 (7),

2.1.5 (4) Strengths: 2.1.1 (9), 2.1.2 (1)

Topic: Surveillance Testing Topic: Safety Culture Findings: 2.1.4 (1), 2.1.4 (2), Finding: 2.1.1 (4) 2.1.4 (3), 2.1.5 (6)

Topic: Timeliness Topic: Maintenance Finding: 2.1.3 (11)

Findings: 2.1.3 (6), 2.1.3 (10),

2.1.4 (10) Topic: Ownership Finding: 2.1.1 (2)

Topic: Design Control Findings: 2.1.6 (1), 2.1.6 (2), Topic: Procedural Adherence / Attention to 2.1.6 (3), 2.1.6 (8) Detail Findings: 2.1.2 (6), 2.1.6 (4)

Topic: Corrective Action Program Findings: 2.1.1 (7), 2.1.3 (8),

2.1.5 (2), 2.1.6 (14) 2

f INDEZ DET Findina Engg IAP Component DET Findina Eagg IAP Component 2.1.1 (1)- 8 OD 2.1.5- (1) 51- HR (2) 53- DC (2) 38 P/P (3) 5 L&D (3) 48 PER' (4) 52 DC. (4) 25 P/P (5) 6 L&D (5) 40 P/P (6)- 18 PM (6) 26 P/P (7) 36 P/P -

(8)- 41 P/P ~ _2.1.6 -(1) ' 31 - P/P (9) 52 DC (2) 33 P/P L (10)- 51 HR- (3) 34 P/P L 55 (4) DC-2.1.2 (1) 52 DC. (5) 41 P/P (2)' 5- L&D- (6) 45 P/P (3) 48 PER (7) 23 PM (4) 6 L&D (8) 35 P/P (5) 51 HR (9) 42 P/P (6) 54 DC (10) 21 PM (7) 44 P/P (11) 21 PM (8) 46 P/P (12) 9 OD (9) 22 PM (13) 15 .OD (10)- 19 PM' (14) 39 P/P

.(11) 9 OD (15) 16 OD (12). 17 OD (13) 43 P/P (14) 24 P/P 2.1.3- (1) 24 P/P (2) 24 P/P

-(3) 44 P/P (4) 24 P/P (5) 24 P/P (6) 27 P/P (7) 20 PM (8) 36 P/P (9) 9 OD IAP Component Key:

(10) 28 P/P (11) 53 DC L&D - Leadership and Direction OD - Organizational Design 3.1.4 (1) ' ;2 5 P/P PM - Priority Management (2) 25 P/P P/P - Process / Program Management 1 (3) 26 P/P PER - Performance Measurement _

(4) 42 P/P HR - Human Resource Management (5) 47 P/P DC = Desired Culture (6) 50 PER (7) 24 P/P

-( 8 ) 44 P/P (9) 45 P/P (10) 30 P/P  !

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i II. RESPONSES TO INDIVIDUAL' FINDINGS The purpose of thissection is to facilitate identification of the areas within the Integrated Action Plan that specifically address DET Report - Section ' 2.0 findings. This section is formatted as follows:

1. IAP component;

2. following the IAP component, NRC findings which discuss noted 4 strengths are listed, but are not responded to; and l- 3. within the stated .IAP component (and following noted strengths), NRC findings which identify areas for improvement are grouped by general topic with a response directly below I. the finding (s).

Note: The section references at the end of each NRC finding refer to the DET Report's Section 3.0 detailed discussions.

Example: DET Report findings 2.1.1 (5) and 2.1,2 (4) are related to Brunswick managements' communication of uite goals. Therefore, they are assigned to the IAP Leadership and Direction component, and are listed together with a response directly below the last finding.

Note: Throughout this section references such as " Action Al" are'noted. These references provide a direct link to the Integrated Action Plan contained in Section III.

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-A. LEADERSHIP AND DIRECTION

'i'opic s strength-2.1.2 (2). .The Shift Operating Supervisors and Shift Foremen exercised strong leadership and control of the shift crews during both' routine and unplanned evolutions. (Section 3.2.2.1)

No response required.

Topic: Goals, Priorities, and Expectations 2.1.1 (3) Corporate oversight, leadership, and direction had been inadequate to compensate for past site management weaknesses. The corporate approach to managing site activities could generally be

described as laissez-faire. The lack of corporate involvement was

-evidenced by Quality Assurance - (QA) programmatic weaknesses, a poorly planned and implemented reorganization of engineering design and technical support, and the failure . to correct repetitive.

equipment failures. (Section 3.1.3)

Response: . Changes have been made in both corporate and site organizations to more clearly focus on accountabilities, and to improve ' the flow of communication in both directions of the management-employee channel. Personnel reassignments ..have been-made, particularly over the past fifteen months, to strengthen the exercise of ' leadership, and provide for better role models and

, improved ownership of team building processes. Increased management- involvement in day-to-day as well 'as long-range activities are producing desired results.

f Corporate Management's expectations are communicated down the I organization in a variety of manners. Specifically, on an annual basis, Corporate' Management provides a clear set of goals that are L fully measurable covering nuclear safety, achievements in the

[ regulatory arena, overall plant' performance, training, and other significant areas. Goals are set to create challenge and encourage the organization to reach for higher levels of performance.

Further, certain levels of importance are placed upon these goals to amplify Management's short-term objectives. For example, during 1989, particular importance was placed upon safety system availability. Clear progress has been made in this area.

Corporate Management communicates key expectations during the course of information exchange meetings.

The next levels of management will improve their expansion of the stated Corporate expectations into meaningful goals and targets for ,

i their functional responsibilities. Further clarifications, deeper '

into the organization, are expected. Consequently, top level l expectations will bn consistently rolled down the organization, and DET 09/27/89 5

I individuals in the various functional areas will clearly see'how they contribute to overall company and plant operational success.

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. [See responses to 2.1.5 (3) for planned improvements to the QA program; 2.1.6 (12) for discussion of the reorganization of engineering design and technical support; and 2.1.3 (7) for discussion of improvements in attacking repetitive equipment failures.)

Actions specified in the IAP, as well as the less measurable and formal actions described herein, show the Company's strong emphasis on Brunswick's success through each level of the Company -- on-site L and off-site.

2.1.1 (5) Site safety goals, priorities, and expectations were not clearly defined and communicated to all organizational levels.

However, the Total Quality (TQ) communication team recently made recommendations regarding revision and clarification of Brunswick goals that could translate general goals and policies into meaningful working goals. There were indications that teamwork and communications had recently improved. (Section 3.1.3) 2.1.2 (4) Communications practices within the individual shift crews were adequate. Communications within the operations Unit and between the operations Unit and other site units, were improving as the result of several management initiatives. Despite these initiatives, some difficulty in promoting management goals and objectives was still evident. (Section 3.2.2.4)

Response: The recognition that some management goals, priorities and expectations were not well communicated downward within the organization is a valid weakness. It confirms our prior conclusions and planned actions.

During the first quarter of 1990, formal, project-wide communications meetings will be held, to convey to project employees 1) achievements and successes from the prior year toward meeting the goals, priorities and expectations, and

2) establishment of the priorities, goals and expectations for the current year. Subsequent meetings will be held to provide project

- employees a current status on Brunswick performance relative to goals.

- Several other actions have been initiated to address this issue, and were active at the time of the NRC Diagnostic Evaluation.

Chief among these actions were:

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I o Informal meetings are normally held once per week between the Plant. General Manager and a peer supervisory level in a given organization (for example, between the Plant General Manager

'I and all first line technical support supervisors). Goals, objectives, and current challenges and issues are freely and thoroughly raised and explored.

o Informal meetings are normally held once per week between the Plant General Manager and each Operations shift crew during their regular cycle of continuing training. Goals, I objectives, challenges, and obstacles to success are candidly discussed and plant positions clearly stated.

I o Formal communication meetings are being held (approximately monthly) between each section manager and each of his units.

The intent of these meetings is to ensure consistent propagation of goals and objectives, allow direct feedback to the plant section managers of employees' concerns and uncertainties, to ensure a forum is provided for good, two-way communication between the section managers and their I employees.

Goals in support of the business plan are being developed o

I within each organizational section. Individuals representing each level are involved in the development of their respective goals and priorities. Therefore, Brunswick's goals will have

" buy-in" from the entire organization.

The actions described above are included in the communications strategy documented under Action A1. The success of our efforts be will observable during day-to-day operations, through improvements in performance indicators, feedbacP received from the Quality Check Program, and self-initiated employee surveys.

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B. ORGANIZATION DESIGN Topie: Organizational Study 2.1.1 (1) Carolina Power & Light Company had spent an excessive amount of time studying potential organizational change issues and plant performance problems such that needed changes and fixes had been unduly delayed. For example, the delayed implementation of the central design organization (CDO) at Brunswick had adversely l affected its engineering design and technical support. The OA had l

been underway for approximately 2 years, and the results and conclusions of the analysis were not to be implemented or made known to employees until fall 1989. The delay in implementation I of the conclusions of the analysis was, based upon interviews, the single most significant factor affecting employee morale, attitudes, and motivation. (Sections 3.1.1 and 3.1.2) l Response: CP&L's corporate Organization Analysis (OA) was a deliberate approach which fully utilized the knowledge and expertise of the CP&L management team, to produce the most effective and fair results. Although some organizational steps were taken in late 1987, with regard to the Nuclear Engineering functions, the OA itself actually began in late 1988. The time I spent on this important Company wide effort was necessary to allow broad management involvement and buy-in and to achieve a quality product. The effects on employee morale during the analysis were anticipated. Based on our observation of similar programs in other utilities, we have implemented the changes with a higher level of employee commitment than companies taking a less thorough and participative approach.

The central design organization (CDO) approach, making the transition from three different engineering staffs (at Robinson, Harris and Brunswick) , to the Nuclear Engineering Department (NED) ,

is discussed in the response to DET finding 2.1.6 (12).]

Currently, central design organization changes and OA actions have been completed or are in the final stages of implementation.

(Section B of the IAP contains organization design action items.)

Employee morale, attitudes and motivation should be improved by the communication, management attention, and organizational interface improvements that are the ultimate results of these actions.

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Topic: Accountabilities and Responsibilities 2.1.2 (11) The current management team was more involved in plant activities than the past management team. Operations management demonstrated an increased level of attention and support of plant activities. Improvement initiatives, although positive, in many cases lacked clear definition of responsibility and accountability and had not been effectively implemented. (Section 3.2.5.2)

Response: As noted by the DET, Carolina Power and Light has been, and is, engaged in many efforts (e.g. , CMOT, Cresap, OA, SSFIs, NRC teams, etc.) to define the problems facing Brunswick and associated Company management. These efforts, which have consumed immense quantities of management's energy and time, are resulting in actions which will lead directly to more explicitly established responsibilities and accountabilities.

Many management actions and initiatives have already occurred and, as noted by the DET, already produced positive results. Additional actions, as formally documented in the IAP, and leadership by example will assure that not only are the responsibilities and accountabilities clearly defined, but that the results lead to continual improvements. (See IAP Section B.)

2.1.3 (9) The length of time consumed in effecting repairs was often excessive, and maintenance efforts were often hampered by i slow and ineffective assistance from the Technical Support Unit.

(Sections 3.3.3 and 3.6.1)

' Response: The maintenance aspect of this DET finding is addressed in CP&L's response to DET findings 2.1.3 (6) and 2.1.2 (10).

Measures to improve the level of assistance provided to Maintenance by the Technical Support Unit are discussed in detail in CP&L's response to DET finding 2.1.6 (12) b. (Action B1 describes Technical Support Unit organizational improvements.)

2.1.6 (12) Both CP&L corporate and Brunswick site engineering organizations had undergone changes in function, size, and responsibilities within the last 2 years to become more aligned as an operating plant rather than a construction project. The environment of continuing change has had a negative impact on the l effectiveness of engineering support to the Brunswick site. For example:

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a. The transition to a CDO was poorly planned and implemented with regard to the Brunswick plant. The process had been time consuming, was still being implemented and the licensee was expected to create additional organizational and programmatic changes as various management studies and assessments were finalized. (Section 3.6.2.2.1)

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L' b. The performance of the Technical Support Unit has continued to suffer from instability and morale problems due to numerous reorganizations, indecision on the part of management to solve problems and set priorities, and phasing out the nuclear pay supplement. (Section 3.6.1.1.2)

c. The responsibilities of the Modification' Project Section of Outage Management were not well defined. (Section 3.6.1.1.3)

Despite potential drawbacks of this reorganization, once fully anc adequately implemented, the resultant engineering product should be an improvement over the fragmented and weak engineering support

.previously provided to Brunswick.

Response a. Transition of NED to a Central Desian Organization During the 1970s, regulatory responsibilities, increasing technical complexity, and associated cost increases, were causing utilities in general, and CP&L specifically, to increase in-house design capabilities, and to reduce the autonomy of contracted architect-engineers (A/E), by taking technical control of plant designs.

Additionally, the volume of work, and the field-intensive nature of that work, dictated large field staffs at both the Brunswick and Harris Projects. In 1979, Brunswick and Harris site-based design organizations were established. Robinson, having less design work, was supported by CP&L's corporate engineering organization (Nuclear Engineering Department). Each of these organizations reported to, and were supported by, CP&L's Nuclear Engineering Department (NED) located in the corporate office. Additionally, Brunswick and Harris began a controlled, seguenced process of taking over functions previously handled by their respective A/Es.

In 1982, as part of a move toward a single point control of site activity, responsibility for site design engineering was given to the Engineering & Construction organization under the Brunswick Nuclear Project (BNP) Vice President. A similar move was made for Harris Nuclear Project (HNP) in 1983. This permitted closer control of the high tempo of site directed work, and allowed NED to focus on the steam generator replacement and secondary plant redesign at the Robinson Nuclear Project (RNP) . NED continued to support BNP on those major projects not within the capacity of plant engineering resources (e.g., torus improvement program, ERFIS/SPDS, development of Appendix R alternate safe shutdown program, etc.)

Subsequently, the volume of required work was reduced, primarily due to completion of the bulk of Three Mile Island driven modifications at Brunswick and construction completion at Harris. ,

the benefits of returning required design / engineering Also, functions to a central design organization (NED), i.e.,

consistency, lessons learned, efficiency, etc., were recognized.

In March 1986, CP&L's senior management put the necessary mechanism DET 09/27/89 10

in place to begin a deliberate and orderly transition of site based engineering functions and resources to the Nuclear Engineering Department.

In 1986 and 1987, the Harris Project was progressing from design and construction through start-up and to commercial operation. The demobilization activities associated with this progress, coupled with the completed transfer of calculations and other design information/ documentation from their A/E made Harris the logical l

choice to lead this effort. Harris Plant design activities were i transferred to NED during 1986 and 1987.

In late 1987, an initial transition plan, based on the Harris plan, was finalized for the Brunswick ' Project. This Phase 1 plan transferred the responsibilities for the design of future modifications to the CDO. Further, this initial plan established that the Brunswick site engineering organization would be downsized following the 1988 Unit 2 outage. The transition in these areas was completed in accordance with the plan at the end of 1968.

The actions necessary to achieve Brunswick Phase 1 transition plan objectives were essentially completed during 1988. In mid-1988 the new Brunswick Plant Manager and the new Brunswick Department Manager evaluated the existing organization, the current state of transition, and lessons learned to date. Then, in a December 16, 1988 memorandum, the Department Manager directed the assignment of remaining design-related functions to CP&L's Nuclear Engineering Department (the CDO). This was a change from Brunswick's original transition plan; it clearly placed design accountability and responsibility in one organization. Formal organization changes were effective on March 6, 1989, and a Phase 2 transition plan was issued. Only three of the 23 activities assigned to NED in the Phase 2 plan have remaining action items. The remaining action items fall into two general categories (Action D8): 1) conversion and/or incorporation of Brunswick engineering guidelines, and related documents into NED documents, and 2) definition of some design control responsibilities in very specific areas. Completion of the remaining tasks will occur by March 31, 1990.

CP&L's transition of engineering activities has been based on sound business and safety considerations, and was a well thought out and executed plan. This plan was reviewed with Region II management in June of 1987 and the NRC Executive Director of Operations in September 1987. It has progressed over a three year period which CP&L feels is appropriate given the need to manage change in a way that minimizes confusion and employee disruptions. (Action B2 covers specific NED organizational changes.)

b. Technical Support Unit The root cause of the problems noted by the DET are attributable to lack of appropriate management direction and control within Technical Support at Brunswick.

Actions were taken to correct this deficiency beginning in July DET 09/27/89 11

l l- 1988. The improvement issues concerning Technical Support have been well documented in the 1988 CMOT study and in the 198S Cresap study. A description of the activities to be implemented to i effectively establish the BSEP System Engineering Program were outlined to the Commission in an April 28, 1989 letter (Serial NLS-89-123). Final program implementation, as described in that j letter, is targeted for March 30, 1990.

The following is a brief summary of the major Technical Suppod-t improvements in progress or planned for implementation in the near future. Our efforts recognize that the necessary improvements in the timeliness and effectiveness of Technical Support are dependent upon action in four major areas related to the IAP model components of Organization Design and Process / Program Management:

o establishment of a clear definition of Technical Support's role with clear definition of responsibility and accountability for technical assistance; o development of an organization whose structure and supervision enable it to provide r.upport which is timely and competent; o enhancement of interfaces with other organizations such that Technical Support is aware and involved with problems to the extent necessary; and o establishment of administrative processes which allow Technical Support personnel to function efficiently and focus on the most important issues.

A mission statement for Technical Support was approved in December 1988. In concert with this, a detailed evaluation of the system engineering tasks was conducted and resulted in Technical Support l

defining by procedure (PLP-06, the System Engineering Program),

approved in May 1989, the duties and responsibilities of its system engineering group. New position descriptions were developed, approved and signcd by the system engineers in August 1989, which clearly delineate accountabilities for the system engineering function. Basic work functions (how to meet accountabilities) and performance measures (how success will be measured for each work function) were developed to meet the accountabilities defined by PLP-06 and the position descriptions. This effort was completed '

in September 1989.

In addition to the improvements in defining the system engineering role, the site Maintenance Engineering Support group had been transferred (February 1989) to the Technical Support Unit to ,

consolidate the operational engineering support responsibilities in a single organization. This action clarified both the role of Technical Support and Maintenance, by eliminating duplicate functions with overlapping responsibilities.

DET 09/27/89 12 i

In June and July 1989, real time training was provided by the Manager of Technical Support to the plant operations organization to detail the Technical Support engineering functions, explain the desired means of communication, and describe the increased level of responsiveness, ownership, teamwork, and communication that Technical Support would provide. I The responsiveness of Technical Support has and continues to be improved by changes to its organization which have constantly focused on meeting its mission. With the completion of the Organization Analysis (OA), an internal realignment of the Technical Support supervisors has been completed. This realignment i resulted in increased direction and oversight through the addition of more first and second line supervisors. Site management had also added additional engineering personnel in March 1989 from the other site organizations, and the dependence on contract engineers as system engineers has been almost eliminated. The above summary of the major changes in the Technical Support organization demonstrates the efforts that have and are being made to make the Unit a more effective organization with more management oversight and involvement at all levels.

A series of new practices have been initiated to improve Technical Support involvement with site activities and communications with other organizations. The system engineering groups began reviewing the control room logs and work requests / job orders (WR/JO) on a routine basis in June 1989. This involves Technical Support in plant issues earlier in the resolution of a problem rather than after the fact. This has prompted better communications with Maintenance and Operations in obtaining statuses and providing direction for activities. Also added to the daily Technical Support routine is a morning meeting of the Technical Support managers, prior to the morning plant management meeting, to discuss  !

plant status / problems and make assignments for corrective actions.

In July 1989, Technical Support assigned two permanent Site Work Force Control Group representatives, one for each generating Unit,

) which has provided a consistent interface with the Maintenance

} planning process. Technical Support is also providing two representatives to the site Communications Team, The above areas are a few examples of how Technical Support is making progress in increasing its involvement and awareness of plant activities.

Improvements will continue to be made in 1990 vith the planned consolidation and relocation of the Technical Support Unit inside the protected area where they will be readily available to the Operations and Maintenance groups.

I Several measures were taken to improve the Technical Support Unit's j responsiveness and effectiveness of operation. In line with the mission defined for Technical Support, senior plant management has transferred (March 1989) many duties which do not fall into the role definition of Technical Support to other appropriate organizations. These changes share a common goal of bettering DET 09/27/89 13

l Technical Support's ability to support the direct day-to-day operation and maintenance of the Brunswick facility by transferring those activities not directly related to this mission.

Several administrative program changes have been made to help improve responsiveness to ether organizations. A fermal process for written communications (ENP-12.1) was implemented in April 1968. It has enabled quicker and better documented responses to the needs of other groups than previously experienced. These l changes make more man-hours available for solving plant problems by reducing the amount of man-hours required to handle the paperwork. Action is proceeding on establishing and refining efficient processes for evaluating and initiating corrective actions for obsolete equipment, repetitive failures, and miscellaneous small projects. For example, obsolete equipment needs are being identified, screened for generic / repetitive problems, prioritized, and scheduled per the Engineering Work Request procedure. Increased accountability on root cause determination and prompt resolution of action items has also been established. A corporate prioritization process will be implemented by June 1990 to provide a systematic method of assessing the relative importance of problems and projects. This process will provide a valuable tool for supervision to use in focusing Technical Support's attention on the most significant problems, and reducing abrupt changes in work schedules by sudden changes in priorities. Other changes have been made to the Engineering Work Request (EWR) and Engineering Evaluation Report (EER) processes, to provide for increased management oversight through periodic status reports and concurrence for extensions to deadlines.

Carolina Power & Light Company agrees with the DET's findings that the Brunswick Technical Support Unit must continue with the improvement efforts that have been in progress. The vast majority of these actions are targeted for completion this year, and the system engineering program improvements will be implemented by March 1990. It is noteworthy, however, that the actions taken to date have resulted in improved engineering support as evidenced in the following examples: RHR erosion problem investigation /

resolution, core spray motor failure determination, ECCS orifice plate failure investigation, and spent fuel shipping program implementation. Technical Support's thrust in the upcoming months will be in the areas of training, individual engineer development planning, and plant system performance trending and assessment.

Examples of work in progress in these areas are formation of a quality team to implement a system trending program, development of a system engineering training matrix, and establishment of individual engineer development plans. The recent structural improvements provided by the Organization Analysis, combined with working level Technical Support improvements and corporate initiatives such as the Nuclear Prioritization Process will enable Technical Support to shift its posture to one that is more DET 09/27/89 14

L 1

l. proactive and responsive. The results will be improved timeliness, ef festiveness, morale and productivity. (Action B1 covers specific Technical Support Unit organizational changes.) ]

r. Outaae Manacement The Outage Management Projects Unit is developing an organization responsible for managing outage projects. They will use the corporate Integrated Planning, Budgeting and Scheduling (IPBS) procedure and Huclear Plant Modification Procedure (NPMP) . The project managers will be 1

-responsible for coordinating all phases of a project through a matrix organization. Groups supporting this process will be Planning and Scheduling, Budget and Business Plcnning, Outage Management Modification Support Unit, Procurement, Operations, heintenance, and others as needed.

The primary responsibilities of the project managers will be development and monitoring of budget and schedule. They will also provide on-site coordination for the BNP responsibilities as defined in the Brunswick /NED interface document.

NED is the design organization and will be responsible for design in all phases of the project. This will include those items identified in the interface document unless specifically exempted based on project needs. Those exceptions will be agreed upon in writing by the managers of BNP and NED. Outage Management is responsible for modification installation, testing and overall coordination during the installation process. Modification packages will be transmitted by NED to Outage Management. The site review and approval will be coordinated by Outage Management.

i Outage Management will provide for installation documentation and

! all permanent site records associated with the installation process. Outage Management will record, track and close out all exceptions to the modifications.

The overall responsibility and accountability of this matrix organization is the Manager-Projects in the Outage Management and l Modifications Section. (Action B6) l 2.1.6 (13) Communications within the engineering groups were adversely affected by the continual changes in personnel and their assignments. The lack of communications in one instance caused an estimated delay of 14 to 32 days in completion of the Unit 1 reload outage No. 6. (Section 3.6.1.2)

Response: Several organizational changes have been initiated this year to neet a long term goal of consolidating engineering support for Brunswick. Some of the benefits expected from the consolidation of engineering functions are:

o improved individual accountability and teamwork; DET 09/27/89 15 l

l

o improved performance by the design and technical support organizations; and o improved communications within individual groups and between groups.

These organization changes were implemented as a part of recent management changes and they are having a positive effect. (Actions B1 and B2) l l

The miscommunication which occurred has been exhaustively evaluated and determined to be an isolated occurrence, not caused by any changes in personnel.

Topic: On-site NED Educational Qualifications 2.1.6 (15) Corporate Nuclear Engineering Department (NED) persc,nnel were technically competent with an adequate amount of nuclear and professional experience, however, the educational background of the on-site NED was below the industry average and may have been a contributing cause of the poor quality of work produced by NED. (Sections 3.6.1.1.1 and 3.6.2.1.1)

Response: A review of the qualifications of on-site engineering organization personnel has been performed using the same data (functional organization chart, task descriptions, etc.) provided to the Diagnostic Evaluation Team. Additional details concerning the qualifications of on-site engineering organization personnel at the time of the DET have been previously communicated to the NRC staff.

The reorganization of the Brunswick Nuclear Project and the Nuclear Engineering Department in March 1989 established NED as Engineer-of-Record for Brunswick. Functional responsibilities for the on-site NED organization were established during that reorganization. The general function for the on-site NED Unit is to provide design assistance during the design and installation phases of modifications, and to provide a focal point to plant organizations for other design related tasks. Original design work and package compilation associated with modifications is performed by Nuclear Engineering Department resources in the corporate office. (Action B2 covers specific NED organizational changes.)

The NED (corporate and on-site) organization provides an appropriate balance of degreed engineers, experienced designers, and support personnel in accordance with the nature and character of the functions performed.

DET 09/27/89 16

)

Topic: Instructor Morale 2.1.2 (12) The overall training program was of high quality and effectively implemented. However, excessively high instructor workload and a pay freeze resulted in a low instructor morale.

(Sections 3.2.6.2, 3.2.6.3 and 3.2.6.4) l l Response: CP&L salary levels are evaluated annually.

Additionally, in 1987, the Company conducted a comprehensive study of pay practices among nuclear utilities in the southeastern United l

l States. These evaluations and study form the bases for the establishment of the compensation levels- for CP&L employees.

Adjustments to salaries are made as appropriate to ensure CP&L is competitive with other nuclear utilities in the southeastern region.

The organization and staffing of the Nuclear Training Section was thoroughly reviewed during the OA process. (See Action B3 for specific Nuclear Training Section organizational improvements.)

Work backlogs will be analyzed continuously and assistance of contractor or other qualified personnel will be provided when required.

Relatively low personnel turnover rates and employee surveys do not indicate that morale is negatively impacted by the Company's salary structure. Actions to improve communication between employees and management, described elsewhere in this response, should improve understanding and concurrently morale.

DET 09/27/89 17

C. PRIORITY MANAGEMENT Topic: Priorities - General 2.1.1 (6) In the past, problem solving, decision making, and prioritization activities were largely reactive and driven by regulatory, industry, or equipment availability pressures.,

Brunswick was still largely a reactive organization and it will remain that way until more of its people, management, organizational transition, and equipment problems are corrected.

Additionally, the different organizational unit prioritization systems were ineffective and resulted in delays in completing actions. (Section 3.1.4)

Response: In December 1987 a corporate initiative was established to develop a common prioritization process for the nuclear sites

,_ and supporting departments. A Project Quality Team was formed in l' February 1988 to formulate such a process. The recommendation was presented to the Quality Team Steering Committee in April 1989, and approved by senior management in July 1989.

The Nuclear Prioritization Process provides a structured mechanism to communicate management values, and to translate these values into action plans by helping to allocate financial and human resources effectively. The prioritization process is common among the three CP&L nuclear sites and supporting departments. Since it is common, it allows the relative priority of work to be clearly communicated between units on-site, and between plant sites and affected corporate organizations. Some of the significant features include: evaluation of activities, by value, independent of source or age; characterization of backlogs for management evaluations; and ensuring management visibility of nuclear safety-related tasks.

For example, a priority one project would be one which involves an action to correct an existing or imminent condition involving nuclear safety, or one which is a threat to personnel safety.

A corporate implementation schedule for the Nuclear Prioritization Process has been established as follows (Action C1):

o July 1989 -

be, gin implementation; o November 1989 -

provide feedback to improve process; and o June 1990 -

full implementation.

Existing ranking processes will be replaced by the new prioritization process, as it is phased in during the next nine months. For example, selection of the major modifications and projects for 1990 will utilize the new prioritization process.

Maintenance work orders, engineering work requests, and accompanying procurement will be phased in during the last quarter DET 09/27/89 18

of 1989. Remaining items covered by the prioritization process will be completed in early 1990.

I Implementation of the prioritization process will not result in the immediate resolution of backlogs or long standing equipment problems. However, it will document the key decisions for each project, and it will assist management in appropriately scheduling I and allocating resources to achieve the overall Organizational changes (corporate and on-site), and results.

specific l

l programmatic improvement actions addressed in other responses, will improve the timeliness and results of our problem solving efforts.

I 2.1.2 (10) Many operators had grown accustomed to operating the plant with an excessive amount of inoperable or poorly functioning equipment. Operators indicated that they did not consider the I number of outstanding work requests on plant equipment to be a problem and exhibited a complacent attitude towards equipment problems. The team concluded that the operators attitude and complacency towards equipment problems in general had been caused I by years of operation while living with undesirable conditions.

(Section 3.2.4.3)

Response: CP&L agrees that the number of inoperable or troubled components in the power plant was excessive. Further, we agree that this fostered an attitude of "living with problems or working around them."

However, since the fall of 1988, an aggressive management initiative has been underway to address this issue. As a result I of this initiative, the number of disabled or troubled components that exist within the power plant has sharply decreased. This, in turn, is promoting a changing attitude among operators (as I

evidenced by an increase in the initiation of work requests on identified problems); the new attitude being that we are not going to work around problems.

Examples of this effort are:

o Reduction in non-outage outstanding work requests. Since I early 1988 a 50% reduction in non-outage work requests have occurred from 6384 to 3284. We have an internal goal of obtaining a non-outage corrective backlog of approximately I 2,000 work requests. With nineteen craft crews, an average work request / job order (WR/JO) backlog, non-outage, of just over 100 per crew is considered optimum.

o Reduction in non-outage outstanding work requests greater than 3 months old. This number has also shown a significant decrease,. From over 2500, this number has decreased to approximately 1800, including a reduction in the number of DET 09/27/89 19 I

troubled indicators, controls, and annunciators in the main control room.

b 1 o Significant advances have been made in the past year to bring  !

- system performance into design expectations. Efforts such as safety system availability improvements and motor operated I valve (MOV) improvements are now paying dividends.

system performance is sharply improved this year to the range 97-99% and MOV reliability is much improved.

Safety In contrast, 1988 safety system performance was in the mid-80% range for b

I Unit 1 and the low-90% range for Unit 2.

o Establishment of a receptive environment and a way for operators to highlight specific concerns. This effort, noted by the DET as the "10 most wanted" effort, has given the operator a vehicle to have " irritations" addressed outside I normal prioritization methodologies. Thus, things which the operator believes to impact his ability to operate the power plant correctly (even if the belief is only a perception) can be highlighted for special attention. Management oversight I of this method of work initiation has made it a valuable tool for the operator. Further, a clear message is sent to the operators that "we care."

Implementation of the corportate Nuclear Prioritization Process will help to ensure that needed equipment repairs are accomplished on a timely basis. (Action C1)

We recognize the challenge that we face in changing attitudes of operators. We also recognize the fact that attitudes will only change through demonstration of commitment and the production of results. The management of Brunswick is committed to bringing this to pass.

2.1.3 (7) The reliability and availability of plant systems and equipment, including control room instrumentation, was poor.

I (Sections 3.3.3 and 3.3.4)

Response: This finding has been addressed in our response to findings 2.1.2 (9) and 2.1.2 (10). Further, the recently implemented Repetitive Failure Detection Program procedure (PLP-05), has achieved success in attacking and resolving I repetitive failures. Since implementation of the program in April 1989, repetitive component failures have significantly declined from 215 to 85.

Furthermore, the site corrective action program, addressed in more detail in response to DET findings 2.1.1 (7), 2.1.3 (8), and 2.1.5 (2), will also serve to provide improvement in availability and reliability of plant systems and equipment.

DET 09/27/89 20 I

2.1.6 (10) on an individual basis, plant modifications (and other projects) were properly prioritized initially using a computer

' program, although the actual scheduling of work appeared to be more dependent upon subsequent budget concerns rather than initial plant needs. (Section 3.6.7.1)

) Responset As discussed elsewhere in this response, the corporate Nuclear Prioritization Process (Action C1); business plan and goals development; establishment of management standards; organizational changes to improve. ownership, clarity and timeliness; improvements in the Corrective Action Program; and numerous other actions are collectively intended to yield a clear understanding of goals, priorities and expectations. Plant needs will thereby be better defined, budgeted, and scheduled using a consistent set of guidelines.

2.1.6 (11) Engineering personnel perceived Brunswick as always one of the last BWRs in the industry to make needed upgrades in hardware or programs. Examples include (1) closecut of Inspection and Enforcement (IE)Bulletin 79-14 which was not expected to be complete until 1992, and (2) permanent corrective actions to resolve the chronic intergranular stress corrosion cracking (IGSCC) issue have moved very slowly since the first discovery in 1976, but were expected to take place within the next two refueling outages.

(Section 3.6.7.2)

Response: _ We acknowledge that the perception noted in this finding may be held by some personnel. However, CP&L does not believe the perception that " Brunswick (is) always one of the last BWRs in the industry to make needed upgrades..." is valid. The 79-14 rework cited resulted from reacting too rapidly to I.E.Bulletin 79-14 initially, and not benefiting from the industry lessons learned as others performed this task. A plan is in place and is currently being actively worked to complete remaining engineering and modification work related to I.E.Bulletin 79-14.

Although Brunswick is one of the later plants to replace IGSCC-susceptible piping, we benefit greatly from the industry lessons learned by waiting until the phenomena had been more fully developed. At all times the Brunswick piping has been safe for operations and capable of performing its function. As evidenced by our letters (Unit 1: NLS-89-192 dated 6/28/89 and Unit 2: NLS-89-232 dated 8/21/89) which commit to a specific schedule for replacement of IGSCC-susceptible piping, we are intensifying our efforts to assure that problem areas are dealt with in a forthright manner.

DET 09/27/89 21

Several actions are described elsewhere in this response which will help to ensure that CP&L is appropriately responsive to Brunswick improvement needs and programs. Examples of such actions include clarification of organizational accountabilities, implementation of the Nuclear Prioritization Process (Action C1), and enhancement of the corrective action program.

Topic Priorities - Specific f

2.1.2 (9) There were an excessive number of control room instrumentation and plant equipment deficiencies that placed an unnecessary burden on the operators and detracted from their ability to operate the plant. This burden was further exacerbated l by a recent program to reduce the number of trouble tags in the control room. This resulted in no indication on the main control board to acknowledge the abnormal status of equipment. (Sections 3.2.4.1 and 3.2.4.2)

Response: The number of deficiencies in the control room and in the plant are more than we desire. At Brunswick we take a very rigorous approach to any condition of equipment that is not "as designed."

Since fall of 1988 the numbers of deficiencies on our main control boards have been greatly reduced -- by approximately 50% for Unit 2 and by approximately 20% for Unit 1. The larger improvement in Unit 1 is due to the benefit of a refueling outage to resolve deficiencies which required an outage. The decrease in these numbers demonstrates CP&L management's commitment to excellence.

Further, we are attempting to be more precise with what exactly is a troubled indicator. For example, at Brunswick any abnormal condition within the power plant was " ticketed" in the main control room if possible. A clogged debris filter would result in a high pressure differential; and control indications would be, in fact, valid (showing a high delta-P)--yet by practice, a deficiency tag would be placed on the correct reading indicator. This is not a good practice in that it discredits valid readings, therefore it has been discontinued.

The management at Brunswick is committed to reducing the number of deficiencies in the main control room and elsewhere in the plant.

A goal of no more than eight (8) non-outage deficiencies (trouble tags) per Unit on the Main Control Board has been established.

[Also see response to DET finding 2.1.2 (10).]

DET 09/27/89 22

i 2.1.6 (7) The licensee had not been aggressive in identifying or closing out vendor recommendations. Many General Electric- (GE) vendor recommendations were over 10 years old and were only ,

recently being dispositioned. Scheduling and implementation of corrective actions (once dispositioned) were also generally delayed to the-future. Procedures to control vendor recommendations were inadequate and had not been revised to reflect current work practices. (Sections 3.6.9, 3.6.9.1, and 3.6.9.2)

Response: Of the vendor recommendations remaining to be dispositioned, reviews have concluded that these recommendations are of low priority. They have been prioritized, scheduled, and budgeted for implementation accordingly.

In May 1989, the vendor recommendation process was incorporated into ENP-20, the Engineering Work Request procedure. A planned revision to ENP-20 will ' incorporate CP&L's new Nuclear Prioritization Process (Action'C1) which should provide for a more accurate priority for each item. These steps will allow vendor recommendations to be considered for scheduling and budgeting on an equal basis with other plant projects and improvements. [See response to DET finding 2.1.1 (6).]

I 1

l l

1 DET 09/27/89 23

4 1

D. PROCESS / PROGRAM MANAGEMENT Topic: strengths 2.1.2 (14) The Real Time Training group, which was part of the operations Unit, provided excellent training to the operators in the areas of industry concerns and plant modifications. (Section 3.2.6.6)

No response required.

2.1.3 (1) Morale within the Maintenance Unit was good and craft personnel were knowledgeable. The standardization of technical training and the use of qualification signoff cards to formalize and document the training was a program strength. (Section 3.3.1)

No response required.

2.1.3 (2) The institution of duty day and backshift maintenance coverage was a positive step toward more efficient utilization of the maintenance staff. (Section 3.3.1)

No response required.

2.1.3 (4) The Automated Maintenance Management System was an excellent system for controlling maintenance activities and maintaining maintenance records. This was a computerized work request generation, planning, scheduling, and retrieval system.

(Section 3.3.2.2)

No response required.

2.1.3 (5) The Maintenance Unit procedures were consistently formatted and well organized for, ease of use. The procedures reviewed were technically accurate and provided a high level of detail. (Section 3.3.2.3)

No response-required.

2.1.4 (7) _ Technicians and operators observed performing surveillance testing were knowledgeable and activities were coordinated with plant operation. (Section 3.4.2)

No response required.

[ DET 09/27/89 24 I

2.1.5 (4) On-site QA surveillance activities were focused on activities which provided meaningful information and an increased use of performance-based surveillance was evident. (Sectiori 3.5.4)

No response required.

Topic: surveillance Testing 2.1.4 (1)- The Surveillance Tracking and Scheduling System (STSS) was an effective method to schedule and track Technical Specification (TS) surveillance tests. The system was computerized and used for identifying, scoping, scheduling, tracking and closing all surveillance and regulatory commitments and requirements.

However, there was no schedule to verify the accuracy of the TS data base. (Section 3.4.1.1)

Response: The On-site Nuclear Safety Unit revicwed the data base prior to implementation. Although the controls are established by procedure to assure Technical Specification surveillance test changes are incorporated, a sampling program to test data base integrity will be established. (Action D1) 2.1.4 (2) The off-site to on-site electrical distribution system I

was not periodically tested as required by the TS. The licensee had never performed an analysis or test to demonstrate that the design of this distribution system met the requirements of the General Design Criteria (GDC) 17 concerning the availability of the alternate off-site electrical source. In addition, the limiting I conditions for operation of the TS were not observed when one of the two sources of off-site to on-site power were out of service.

These deficiencies were largely due to the implementation of two I ischnical Specification Interpretations (TSI) that were based on erroneous assumptions regarding GDC-17 requirements.

3.4.1.2)

(Section Response: CP&L understands the question which has been raised by the DET concerning GDC-17. However, CP&L does not agree with all aspects of the DET's conclusions concerning compliance with GDC-17 and compliance with Technical Specification requirements. A review of the Brunswick electrical distribution system documentation leads to the conclusion that Brunswick, as designed and analyzed, is in compliance with GDC-17. We will proceed to evaluate the Brunswick electrical distribution system for compliance with GDC-17, considering the DET assessment. (Action D1) When completed we will brief the appropriate NRR personnel on the results of our evaluation, t

DET 09/27/89 25 ll

l 2.1.4 (3) The licensee h'ad not performed stroke time testing for some of the containment isolation valves specified in the TS.

Although a TS change request had been submitted in 1984 to remove ]

these valves from the surveillance requirements, periodic testing had not been performed in the interim. (Section 3.4.1.2) ,

l Response: The Brunswick Plant concurs that a portion of Technical

} Specification Interpretation (TSI) 85-01, Primary Containment Isolation Valves (PCIV), was incorrectly implemented. TSI 85-01 was issued to provide a complete listing of the PCIVs. The initial compliance with this TSI was correct and exceeded the requirements of Technical Specifications.

In 1988, a modified understanding of the original TSI was established which incorrectly removed the 4 PCIVs per unit, as referenced in the DET Report, from the stroke time testing requirements of Technical Specifications. This was due to personnel error, has subsequently been reported in Licensee Event Report 1-89-016, and is being tracked per LER procedures.

(Action D1)

A review of the remaining outstanding TSIs was performed to ensure that other similar problems did not exist. No additional problems {

were identified.

2.1.5 (6) The BIP specified that QA would perform a 100 percent review of TS surveillance requirements every 3 years. This item, imposed by NRC order, was not being properly implemented. For example, initially the TS surveillance requirements had been 100 percent reviewed, but procedures were later revised to use a batch methodology which was not consistent with Item III-3 of the BIP.

(Section 3.5.4)

Response: In early 1987, after 57 months of implementation, QA analyzed the results of not only BIP Item III-3 but also Items III-1 and III-2. This review concluded that the operating plant organization had improved management controls such that the QA verification effort should be re-evaluated. This re-evaluation resulted in a letter to NRC Region II in October 1987, and was reiterated in an October 1988 request to discontinue the BIP Confirmatory Order.

In the October 1987 letter, CP&L stated that of the approximately 7000 completed surveillance test documents reviewed by QA only ten problems were identified. This was only a 0.14% problem rate and there were no significant safety problems. CP&L concluded that the objective of BIP Item III-3 could be better met by use of a ,

sampling approach and stated its intent to utilize a sampling approach. Due to a lack of formal response and through a series of informal contacts, CP&L concluded that concurrence was forthcoming in due course and decided to implement the sampling DET 09/27/89 26

program which more effectively utilized QA personnel. However, we now agree with the DET finding that the sampling plan was flawed, cnd we are taking steps to upgrade that plan. (Action D1)

CP&L considers sampling of Technical Specification surveillance testing, including in-service inspection and 10CFR50 Appendix J testing, to be the most effective method for performing the necessary overview.

[Also see response to DET finding 2.1.5(3)]

Topic: Maintenance 2.1.3 (6) Although the maintenance work backlog had been steadilf trending downward since early 1988, it was still too large, and continued effort was needed in this area. (Section 3.3.2.4)

Response: Since early 1988, the Maintenance non-outage backlog has been reduced by approximately 50% from 6384 to 3284 work orders.

Some of the factors contributing to this reduction are:

.o formation of the Site Work Force Control Group (SWFCG) to-improve communication and coordination among site groups; o utilization of the Automated Maintenance Management System (AMMS) to identify, track, schedule, and resolve outstanding maintenance items; and o increasing the visibility and management accountability for the maintenance backlog.

Brunswick management plans to continue these efforts and strengthen them where necessary. In addition to the initiatives already undertaken, several additional actions are planned which should further help to reduce maintenance backlogs. (Action D2) These l

include:

}

o utilization of the Nuclear Prioritization Process to prioritize the maintenance backlog; o use of AMMS to produce additional management reports regarding the maintenance backlog; and o establishment of backlog goals for each work group within the Maintenance Unit.

As described in this response, existing and new initiatives will assure further backlog reductions.

l DET 09/27/89 27

l 2.1.3 (10) The Brunswick motor-operated valve (MOV) n.aintenance program had many strong provisions, but these were offset by

, significant weaknesses in program implementation. Significant l additional effort and management attention were needed to ensure the many strong provisions of the program were consistently implemented in the plant. (Section 3.3.5) '

Response: The weaknesses identified were: 1) procedure OCM-M0500 did not specify use of only Exxon Nebula EP-1 grease for Limitorque SMB-5 and SMB-5T actuator gearboxes; 2) torque switch settings are not verified every 36 months as are limit switches for Limitorque actuators; 3) a poor completion history exists for our MOV preventive maintenance activities; and 4) conflicts exist within our governing procedures dealing with Limitorque switch settings.

These weaknesses are being addressed by Brunswick management as described below. (Action D3) o Procedure OCM-M0500 Revision The DET stated that Corrective Maintenance procedure, OCM-M0500, " Repair Instructions for Limitorque Motor Operated Model Numbers SMB-5 and SMB-5T," did not specifically require the use of gearbox grease, Exxon Nebula EP-1. Specifying this grease, as is done in procedures for smaller actuators, eliminates the possibility of using an improper grease that would affect the actuator's environmental qualification.

OCM-M0500 has been revised to incorporate the specific use of Exxon Nebula EP-1 for actuator gearboxes, and is now available to support the current Unit 2 outage activities.

o Torque Switch Setting Periodicity I

' One weakness in the MOV Preventive Maintenance (PM) program, as described in the DET Report, implies that the 6-year frequency for performing MOV diagnostic testing which verifies torque switch settings should be performed more frequently.

The 36-month PMs verify the setting of the limit switches by stroking the valve and adjusting the switches based on handwheel turns. Adequately verifying torque switch settings involves the use of the MAC equipment for diagnostic testing and is most effectively done concurrent with this MAC testing.

The examples used for this finding are not appropriate since the service water valves referenced are controlled by limit switches for closing. Torque switch settings for torque-seating valves are normally verified by the MAC equipment to ensure effective seating force is applied. The torque switches for service water valves are used for safety backup to the limit switches.

The majority of the valves which have been diagnostically tested with their torque switch settings verified were found DET 09/27/89 28

to be within acceptable limits of operation. Therefore, the 6-year PM frequency for torque switch verification, 'in addition to post maintenance testing performed when necessary, is currently appropriate. However, with the recent issuance of Generic Letter 89-10, the program will be reviewed and necessary changes made to ensure compliance.

o MOV Preventive Maintenance (PM) t The MOV preventive maintenance performed at Brunswick, other I

than diagnostic testing, consists of electrical and mechanical inspections and lubrications performed at intervals recommended by the vendor for both safety-related and balance-of-plant (BOP) Limitorque actuators.

Since May 1988, most of the PMs accomplished have been completed on Brunswick Unit 1, primarily during the November 1988 Refuel Outage. A majority of the valve PMs could not be performed until that outage. A number of valves for Brunswick Unit 2 have been~done to date, but many more of the valves will receive preventive maintenance during :te current Unit 2.

refueling outage.

Electrical PMs for BOP valves primarily have been performed as a part of corrective maintenance activities. PMs for BOP valves are in the process of being validated and added in the PM program and many are anticipated to be performed during the next retueling outage on each Unit and during other outage or system " windows" where available.

The mechanical PMs for BOP and safety-related valves have been performed during the past two refueling outages and system windows where available. The valves remaining to be done are being scheduled through our Site Work Force Control Group or I will be scheduled during the upcoming refuel outages on both Units.

In summary, the goal of the MOV PM program is to inspect and lubricate BOP and safety-related valves at intervals recommended by the vendor. While progress has been made in the area of safety-related valves to date, scheduling problems have made it difficult to accomplish these PMs. The first corrective step will be to reverify the accuracy and adequacy of the MOV PM program and associated scheduling. This is targeted for completion by June 1990. During and subsequent to completion of this reverification, these MOV PMs will be aggressively pursued to take full advantage of outage and system "#iudows" where available.

DET 09/27/89 29 i

o Programmatic Conflicts The DET identified several inconsistencies within engineering procedures for administration.of Mov switch settings. These engineering procedures are currently under review to ensure consistency betwoon on-site and off-site documents. Also, the Nuclear Engineering Department (NED), which is responsible for design changes ' to the facility, is currently drafting guidelines to ensure MOV changes at the facility are i

adequately addressed and that required site procedure' l revisions are identified.

Outside of the areas discussed above, an MOV task force performed an in-depth design review of safety-related MOVs and issued their

! final report in December 1988. Shortly thereafter, a Project

. Manager was assigned to manage this effort through the

implementation phase. In mid February 1989, a meeting was held with site management and' responsibility for implementing the task force recommendations were formally assigned.

l The task force provided approximately 60 work activities (Plant I

Modifications, System Design Reviews, and Documentation Corrections). Each activity was incorporated into a long range l proj ect ' schedule and planned. To assure proper tracking, the

!- activities were then assigned Action Item numbers and entered into the site " FACTS" tracking system.

As of August 1989, 15 of the identified work activities have.been completed with an additional 23 activities scheduled to be i

completed by the end of the current Brunswick Unit 2 outage l'

(February 1990). All of the identified task force work activities are currently scheduled to be completed by 1992.

2.1.4 (10) Weaknesses existed in the maintenance work planning and performance processes that failed to ensure adequate post-maintenance testing on safety-related equipment. (Section 3.4.3.2)

Response: For components required by ASME,Section XI, weaknesses cited in the area of post-maintenance testing stem from the lack of testing as a part of a Code repair or replacement. These weaknesses had.been identified prior to the DET evaluation, and corrective actions were being addressed.

The root cause for the weaknesses is a lack of definitive guidance in the plant program for the determination of post-maintenance testing requirements for Code repairs or replacements on pressure boundary material within ISI boundaries. The format of the existing procedure does not facilitate accurate determination of the requirements by the Maintenance Planner / Analyst who has initial responsibility for this determination.

DET 09/27/89 30 1

s

Several corrective actions are being taken. Procedure ENP-16.12,

" Post Maintenance Testing Guidelines for In Service Inspection" activities, is being developed to provide definitive guidelines to f .the Maintenance Planner / Analyst for the determination of post-I maintenance testing for work activities within ISI boundaries.

This procedure will delineate the use of plant drawings to determine ISI boundaries. A second program procedure, PLP-08 Repair / Replacement Program, is being developed to define the scope and requirements for Code repairs and replacements, as specified by ASME,Section XI.- This document is applicable to any repair or replacement activity on pressure boundary material within defined ISI boundaries. Lastly, the corporate training staff has developed a training course for Maintenance Planners / Analysts in the use of the above-mentioned procedures and the requirements of ASME,Section XI which specify such a program. These actions are targeted for completion by October 15, 1989. (Action D4)

Topic: Design Control 2.1.6 (1) Numerous design and operational weaknesses were identified with the SW system that collectively challenged its operational readiness. Examples included: a vulnerability to single failure, lack of nuclear to conventional SW header leakage testing, unavailable preoperations/startup test data, improperly performed modifications, and the high potential for water hammer of the residual heat removal SW loop keep fill system. The licensee also failed to recognize existing nuclear SW system flow distribution and capacity inadequacies during the performance of SW studies and modifications. The licensee subsequently wrote a

" justification for continued operation" (JCO) which included numerous short and long-term corrective actions. (Sections 3.6.3.1 and 3.6.3.2)

Response: In response to questions raised during the Diagnostic Evaluation, CP&L immediately initiated a service water (SW) system

- project team encompassing corporate and site engineering personne?

This team developed a hydraulic model based on as-built drawings and performed system testing including cross-tie valve leakage testing to validate the model. Accident scenarios were evaluated and a Justification for Continued Operation (JCO) developed to support continued operation. This JCO implemented compensatory measures to ensure operability until design changes could be implemented. A project plan was developed to ensure appropriate short term and long term actions. This plan addressed the following key issues-o hydraulic capability of the system; o system valve leakage; and o service water pump motor reliability.

DET 09/27/89 31

Actions to date include:

• I 1 Hydraulic CaDability o~ System testing including cross-tie valve leakage testing has been completed.on both Units and hydraulic models validated.

o Modifications have been developed and installed on both Units to restore system design capability to original design.

o Performed-intake canal testing to evaluate pump sump levels l- under varying conditions. .

1

\

o- Performed factory pump ~ testing.using a typical in service SW l l- pump. l o Completed preliminary evaluation of RHR SW water hammer potential. Risk is evaluated as low; however, recommendations

for addressing this risk are under development.

System Valve Leakace o Leakage has been quantified and evaluated on each Unit.

o A preliminary assessment of valve leakage cause has been completed. Final determination will be dependent on outage inspection results.

o Modification packages replacing key cross-tie valves are in j progress and should be installed during the 1989 refueling j outage for Unit 2 and during the 1990 refueling outage on Unit i

1. j o Valve actuator adjustments were made on existing valves to minimize cross-tie leakage.

Service Water Pumo Motor Reliability o completed failure analysis for the failed SW pump motor.  !

Motor failure was associated with a turn-to-turn failure j caused by thermal aging of the insulation.

o A review of motor maintenance history has been completed and i testing performed to establish present condition of the I motors. Based on this information, a JCO was established.  !

This evaluation identified four motors recommended for rewind. j o Based on the failure analysis, a redesign of the motors was accomplished including upgrading insulation to F class, DET 09/27/89 32 l i

.___________L

installation of higher efficiency fans, and reduction of internal air flow resistance.

o Three of the four motors have been replaced with modified motors. The modified motors run approximately 60 degrees cooler and well below the insulation design temperature. The fourth modified motor is installed and targeted for operability in 1989.

Maior Activities Still in Procress o Issue final hydraulic report documenting hydraulic bases for the system and system compliance with the bases.

o Complete review of service water modifications to ensure modifications are encompassed by design analyses and test activities.

o Complete installation of upgraded cross-tie valves to reduce cross-tie valve leakage.

o Complete fourth SW pump motor upgrade. Establish motor temperature monitoring program to track remaining life for SW pump motors.

o Issue final project report addressing results of the project and providing any further recommendations for system enhancement.

With the exception of the Brunswick Unit 1 cross-tie valve modification (which is scheduled for the 1990 refueling outage),

remaining activities should be completed during 1989. (Action D6) 2.1.6 (2) In some instances, the licensee appeared to lack an understanding of the design basis of the SW system, and the necessity for traceability of design input to design output. This was caused, in part, by a general lack of hydraulic design calculations for the SW system. (Sections 3.6.3.3 and 3.6.5.2)

Response: The service water system project discussed in response to DET finding 2.1.6 (1) develops a design basis report for the service water system, documenting the basis for the hydraulic requirements of the system including calculations demonstrating compliance.

Additionally, CP&L is planning to perform a Safety System Functional Inspection (SSFI) of the Brunswick service water system in 1989. (Action D6)

DET 09/27/89 33

/

2.1.6 (3) In many instances, design basis information was not

.readily available, was in the process of being reverified, or could not be located. This situation, in combination with the SW system deficiencies just discussed, and similar deficiencies in the HPCI f system found during CP&L's 1987 self-assessment, raises questions about the reliability and operability of safety and nonsafety equipment under credible off-normal conditions. (Sections 3.6.3, 3.6.5.1 and 3.6.5.4)

Response: The CP&L program for preparation of plant modifications requires a comprehensive review to determine the impact of the anticipated design change on safety related components, systems or structures.

In recognition of the need to make original design information more readily available to engineers, and to upgrade the quality of the information to meet current standards and needs, two projects are in progress at this time. These are:

o UE&C/GE System Desian Criteria Documentation Turnover Proiect:

This project is turning over to CP&L the United Engineers and Constructors (UE&C) and General Electric (GE) design basis information for Brunswick systems. The possession and control by CP&L of the design basis information will enhance engineers' ability to retrieve information. This project is scheduled for completion by the end of 1991.

o The UE&C PiDina Desian Turnover Proiect: This project consists of two phases. Phase I is complete and involved the identification of UE&C pipe stress and pipe support calculations of record, and packaging and transmittal of such to CP&L. Phase II involves the updating of calculations to reflect as-built configurations, enhancement of calculations to resolve identified problems, and updating drawings to reflect the as-built configurations. This phase will be complete by the end of 1991.

The CP&L plan to resolve the service water system deficiencies is discussed in the response to Section 2.1.6 (1). In addition, a Safety System Functional Inspection will be performed on the service water system by the end of 1989.

Deficiencies identified during the review of the service water system highlight the need to evaluate, organize, and stabilize design basis information and identify and resolve concerns. Our plans to accomplish this are summarized below (Action D7):

o Complete the UE&C/GE System Design Criteria Documentation Turnover, the UE&C Piping Design Turnover, and the Service Water System SSFI described above and in the response to DET ,

finding 2.1.6 (2). i DET 09/27/89 34

)

l o Complete the service water modification review project plan being conducted as part of the service water flow verification project. This review is structured to determine if modifications implemented after original design may have impacted that design in an adverse manner. [See response to DET finding 2.1.6 (1).]

l' o Evaluate results of the Modification Review and SSFI findings, and the HPCI and SLC Safety System Functional Inspection results and open items, for trends, patterns and significance.

Determine by June 30, 1990, the actions and priorities for additional steps to be taken.

l o Maintain the existing DC Battery System Load Study, AC Voltage i

Analysis Study, Design Control System Computer, Motor Operated Valve Design Documents, and other ongoing initiatives contributing to improvements in design basis control. (These are on-going activities which will not be tracked under the IAP.)

<2.1.6 (8) The design change program was in a state of change and not well supported by up to date site procedures. Conflicts I

between the "new" Company modification procedure and Brunswick procedures also existed. (Section 3.6.4)

Response: The state of change resulting from reorganization of on-site organizations and the transfer of design related functions to NED required several initiatives to assure orderly transfer of responsibilities. It was recognized that procedural updates and

! revi.sions would be required to reflect these changed responsibilities. The initiatives included:

! o Development of a Transition Agreement for reassigning l responsibilities between the Brunswick Nuclear Project and the Nuclear Engineering Department. This agreement, approved in April 1989, included a broad general plan, and provided direction statements necessary to complete the transfer of functions.

o Based on the broad general plan outlined in the Transition Agreement, Phase 2 of the Transition Plan was developed. (See response to DET finding 2.1.6 (12) for a description of Phase 1 and Phase 2 as they relate to the history of the formation of the central design organization.) This was completed in July 1989. The Phase 2 plan is a management and communications tool (not an absolute action items list) used for guidance during the transition process.

DET 09/27/89 35

i l )

i o Phase 2 of the Transition Plan included plans for development l of an Interface Agreement between the Brunswick Nuclear )

Project and the Nuclear Engineering Department. This  !

agreement was approved in July 1989 and included BNP procedures used in the design process.

o Also included in Phase 2 of the transition plan is a plan for document conversion. This plan provides for the conversion of specific design related sito procedures (formerly Brunswick Engineering Support Unit Instructions and design guides) to Nuclear Engineering Department procedures and guidelines.

This conversion is in progress, and is targeted for initial completion in 1990. (Action D8) o Brunswick has initiated a plan to update site procedures to reflect organizational and responsibility changes.

(Action D31) o In recognition of the need for additional procedural and programmatic enhancements, CP&L established a standing committee in June 1989 with representatives from the three nuclear sites and the Nuclear Engineering Department. This committee provides the necessary guidance to resolve conflicts between the Nuclear Plant Modification Procedure and site procedures.

l Topic: Corrective Action Program 2.1.1 (7 ) The Corrective Action Program, as discussed in paragraph 2.1.5.2 below, was inadequate. There was no focal point of root cause expertise within the Brunswick organization, the threshold criteria for formal root cause (by procedural guidance) was too l high, and training given to date, concerning the various methods l~ of root cause determination was rudimentary. Also, there had been a lack of corporate office sensitivity and ctamitment to the corrective action programs and processes throughout the Nuclear Generation Group. Additionally, Brunswick had not implemented a Human Performance Evaluation System (HPES) which could improve the analysis and evaluation of human performance problems at a low, "near-miss," threshold. (Section 3.1.4) 2.1.3 (8) Licensee development of corrective actions for chronic equipment problems was often excessively slow, root cause analysis was poor and ineffective, and expediting repairs that would reduce the burden on operators was a low priority in the Maintenance Unit.

Once resources were focused on a problem, the corrective actions were generally of high quality. (Sections 3.3.3 and 3.3.4)

Response: The recent adoption of the corporate Nuclear Prioritization Process, now being implemented at Brunswick, will DET 09/27/89 36

i establish a more correct order of priority of maintenance. '[See

response to DET finding 2.1.3 (6) for additional maintenance improvements.] It must be recognized that " burden reduction on the operator" is not.always identical to maintaining the power plant as safe and reliable as possible. To address the issue of demonstrating to the operator our concern for his/her perceiveu ease of. operation, the "10 most-wanted" effort was launched late i last fall. [See the response to DET finding 2.1.2 (10) for a complete description.] .

' Chronic equipment failures have been addressed in the response to DET finding 2.1.3 (7). This relatively new effort will, in concert with the corrective action program established in procedure PLP-04, serve to resolve this issue.

Root cause analysis is now being pursued much more rigorously under PLP-04,. " Corrective Action Program. " Implemented in November 1988, this program establishes the framework for an effective site corrective action program. Still being refined, this initiative will result in a more definitive analysis of "why something happened." Combined with important organization changes, we believe our root cause analysis will become a dynamic and successful activity. These organization changes include:

o establishment of a senior plant position explicitly charged with the responsibility for the site corrective action and root cause analysis program.

o establishment of a senior HPES coordinator to ensure human performance issues are comprehensively addressed.

Candidates for both positions have been selected, and it is anticipated that the positions will be filled by the end of 1989.

(Action D9 addresses improvements planned for the Brunswick Corrective Action Program).

It is corporate management's intent to have a corrective action program which is effective and results in the full remedy of problems that this technique is applied to. To develop this important tool and implement it consistently throughout the .

1 organization, inputs and participation will be solicited from all three operating plants and applicable supporting documents, as well as support through the Institute of Nuclear Power Operations. It is our intent to further develop this program and effectively institutionalize it throughout the corporate nuclear program during the calendar year 1990. (Action D10)

DET 09/27/89 37

2.1.5 (2) The Cor ective Action Program was inadequate due to (a) weaknesses in the roblem identification process as a result of un inconsistent and hagh threshold for determining significance, (b) an ineffective trending program, (c) investigations which often lacked sufficient depth to identify the root causes and major contributing factors, (d) untimely implementation of corrective I actions, and (e) employee perceptions concerning adverse personnel actions resulting from identification of deficiencies.

3.5.2)

(Section Response: An effective corrective action program has four levels, or tiers, of activity. The first tier is driven by the climate and culture within which work is performed. At this level the individual worker's attitudes and commitment to quality should cause even the most minor working-level problems to be identified and resolved. CP&L's General Employee Training (GET) emphasizes I CP&L's commitment to quality and states that " Quality performance is the responsibility of each person from top management to the newest employee." At Brunswick, the Plant General Manager has frequently briefed site employees on the importance of problem I identification to support this policy and to avoid even the appearance of adverse results to employees. The recent appraisal by Cresap recommended the development of a stronger "self I identification" commitment and a Brunswick Nonconformance Policy statement. (Action D9)

The second tier of an effective corrective action program is driven by corrective action and root cause determination procedures. In late 1988, it was recognized that Brunswick's corrective action program was not sufficiently integrated and coherent. Accordingly, PLP-04, " Corrective Action Program," was written and issued. As with any new procedure, fine tuning revisions are necessary for PLP-04. For instance a revision to improve the HPES (Human Performance Evaluation System) area has already been issued, and E revisions to improve trending and to lower " threshold" levels will be implemented by year end 1989. Additionally, further training in the use of PLP-04 will be completed by April 1990. Closure of DET timeliness and priority concerns will be assured through the refinement and implementation of PLP-04, implementation of the Nuclear Prioritization Process, and the clarification of I responsibilities and accountabilities achieved as a result of Organization Analysis driven improvements. (Actions B, C1, D9)

I The third tier is the formal Corporate Quality Assurance Program.

As stated in the DET Report "the CP&L Corporate Quality Assurance Program defined the terms 'significant conditions adverse to quality' and ' conditions adverse to quality' and these terms met regulatory requirements addressing nonconforming conditions for purposes of trending and corrective action to prevent recurrence" (DET Report p. 63). CP&L agrees with the finding that the I threshold for problem identification and measures for root cause determination need improvements to take them beyond strict DET 09/27/89 38

) - - _

).

w h 4 .'

regulatory requirements.. However, the appropriate place for this

, . philosophy to be manifest is-in:the first two tiers as: discussed above. Improved, worker-level attitudes and culture combined w3th

- a. coherent procedure that reflects this philosophy will essentially.

resolve'the DET Report corrective action' program concerns.

['

The ~ fourth tier of an effective corrective action program .is j' . corporate and site management oversight. In August 1989, . Brunswick

. management named a. corrective action coordinator. This is both a personnel development action and ' establishment of a counselor k,.

function. The' coordinator will' review, coach,. counsel and keep programs reviewed and on track.

~

In this capacity, the coordinator will serve as an : advisor to line management and will elevate

! problems to higher levels, as necessary. ' To ensure proper

. recognition of the importance of this . activity, the coordinator

' reports directly to the Plant General Manager. This will reinforce the existing plant management practices of " management by walking

'around."

The actions described above (Actions D9 and.D10) should adequately

- resolve'the corrective action program concerns identified in the DET Report.

2.1.6 (14) Corporate or on-site engineering-support to perform effective- root cause analysis, define corrective actions, and resolve issues to prevent recurrence of significant events depended greatly upon event visibility and was generally reactive in nature.

(Sections'3.6.8, 3.6.8.1, 3.6.8.2, 3.6.8.3, and 3.6.8.4)

Response Refer to the response to.DET findings 2.1.1 (7), 2.1.3 (8) and 2.1.5 (2) for overall Corrective Action Program improvement initiatives.

The reorganizations of the Brunswick Nuclear Project and the Nuclear Engineering Department (NED) [ discussed in responses to 2.1.6 (8), 2.1.6 (12) and 2.1.6 (13)] in March 1989, established NED as Engineer-of-Record for Brunswick. This responsibility is specified in the Transition Agreement approved in April 1989. As part of the Engineer-of-Record responsibility, NED is proactive in resolving design issues in an effort to help prevent recurrence of events.' NED is maintaining an on-site group specifically charged with furnishing discipline engineering support and remaining involved.in day-to-day plant activities. The reorganizations and definitive assignment of responsibilities and accountabilities resulting from OA, implementation of the Nuclear Prioritization Process described in response to DET finding 2.1.1 (6) along with enhanced management availability should resolve this issue.

DET 09/27/89 39

..-memenw..-imas.

l Topic: Safety Evaluations / Reviews 1

2.1.5 (5) The Brunswick safety review committees were performing j required review functions, except that On-site Nuclear Safety (ONS) I f was not reviewing industry advisories or efforts to reduce personnel errors. Prior reviews by the Plant Nuclear Safety

( Committee (PNSC) of TSI regarding minimum off-site to on-site I clectrical circuits and primary containment isolation valves were {

inadequate. (Sections 3.5.5 and 3.4.1.2) '

Response: As acknowledged in the body of the DET report (page 68, paragraph 4), ONS does review industry advisories. ONS reviews industry advisories received via the INPO SEE-IN Program and I.E. )

Notices. Review of vendor recommendations is accomplished as part {

of the vendor recommendation program (in response to GL 83-28) that l is managed by Technical Support. Vendor Recommendations that are not implemented must be approved by ONS. This assures that vendor recommendations are being incorporated by Technical Support unless sufficient justification is provided.

Technical Specification 6.2.3.2 defines ONS responsibility for maintaining surveillance of facility activities to provide independent verification and to assure that human errors are reduced as much as practical.

o In addition to industry advisories, ONS reviews modifications, procedures, events, and issues, and performs observations and special investigations. In the conduct of these activities, recommendations are provided to reduce personnel errors.

o Numerous ONS actions related to procedure changes, labeling, signs, and human factors have been made a part of the above ONS programs. However, there is no single ONS procedure or program which defines how ONS reduces human errors as much as practical.

'In recognition of the fact that prior Plant Nuclear Safety Committee (PNSC) reviews were not fully adequate, PNSC review methodology was revised in the fall of 1988. Specifically, a policy was established that items being brought before the PNSC were to be distributed several days in advance of a PNSC meeting.

Responsible PNSC members then cause proper in-depth reviews to be done by their respective units and necessary comments generated.

To the extent possible, comments are then resolved prior to the formal PNSC meeting. Meeting discussions are then centered on resolution of outstanding concerns and appropriateness of actions.

This change has resulted in both more effective and more detailed reviews.

DET 09/27/89 40 t

i 2.1.6 (5) Weak engineering safety evaluations (10CFR50.59) were noted during review of modifications. The licensee had also made -

similar conclusions regarding safety evaluations as evidenced by I nonconformance reports (NCR)88-055 and 88-056. Licensee corrective actions associated with the NCRs failed to address the concern or effect of poor, past evaluations, and the existence of potential unreviewed safety questions. (Section 3.6.5.3)

Responses A corporate task force under the direction of Corporate

). Nuclear Safety is developing a consistent method for performing l

safety reviews. The charter is to incorporate the best features from CP&L's three nuclear sites, corporate organizations, and the recent industry guidance by NUMARC on this issue. The results of this effort will be to raise the quality of CP&L's 10CFR50.59 reviews throughout the Company. The corporate program for accomplishing this will be in place by February 15, 1990.

Procedures and training necessary to implement the program at all three sites and the corporate office will follow. (Action D11)

The Independent Review (IR) Unit of the Corporate Nuclear Safety Section (CNS)- reviews those written safety evaluations of modifications and procedure changes which change the facility as described in the FSAR, change Technical Specifications, or result in unreviewed safety questions. IR additionally reviews the safety evaluations of tests or experiments not described in the FSAR. The Onsite Nuclear Safety Units (ONS) of CNS sample 10CFR50.59 reviews of selected plant modifications and procedure changes. The IR and ONS reviewc are to independently assess whether an unreviewed safety question exists.

It is CP&L's experience that the 10CFR50.59 safety evaluation weaknesses are in documentation, not in the unreviewed safety question determination. The presence of multiple level reviews, including the independent reviews by IR and ONS, give CP&L confidence that unreviewed safety questions have not been overlooked in the review of past evaluations.

Topic: Business Planning 2.1.1 (8) The process for business planning at Brunswick was ineffective because it hampered effective communication within the site organization as well as between the site and corporate office on Business Plan / Budget related matters. It also resulted in a mismatch between the Five-Year Business Plan and Budget causing a substantial lessening of site management's sense of ownership of this plan. (Section 3.1.5)

DET 09/27/89 41

2.1.6 (9) Inconsistencies existed between current and future '

(projected) modification closecut rates as documented in the Brunswick Five-Year Business Plan. The Business Plan forecasted a significant drop in the number of modifications performed on a yearly basis. If the actuel number of completed (operable) modification packages drops to be consistent with the Business

) Plan, the current modification backlog would not be reduced in a timely manner and might actually grow. (Section 3.6.7) l Response Several improvements are planned for the Brunswick l business planning process (Action D12), including:

o formalizing the process for initiating and finalizing budget and business plan targets; o enhance the business planning process to clarify the " roll down" from the long range plan and " roll into" the budget; o utilizing the business plan more effectively as a planning and management tool; and o improving consistency between the business plan, the long range plan and the backlog of modification projects.

o Budgeting and accountability for support department activities have been moved out of plant business plans to allow more focus in site management on the business of the site.

Topics Standardization 2.1.4 (4) The instrument and control surveillance testing procedures were consistently formatted and provided a high level of technical detail. The Procedures Administration Manual, intended to standardize procedures, as required by the BIP, was not being effectively implemented. As a result, the overall standardization of site procedures had not been accomplished.

(Section 3.4.1.3)

Response: The Procedures Administrative Manual (PAM) was not written to establish a rigid methodology of procedural development.

Rather, it. was meant to serve as a writer's guide.

In 1984 an evaluation of site procedural development was conducted by the Nuclear Staff Support Section. This evaluation concluded that the intent of the PAM was being met at Brunswick. Procedural development has not to our knowledge changed materially at Brunswick since establishment of the PAM. To ensure that Brunswick procedures do continue to meet the intent of the PAM, however, we will have a review conducted of recently issued procedures. This review, to be completed by January 1, 1990, will document compliance of Brunswick procedures with the PAM.

DET 09/27/89 42

f 1-L t-Should it be determined that deviations of significance do exist between the PAM and Brunswick procedures, appropriate corrective actions will be initiated to bring procedure development in

! compliance with PAM intent by April 1, 1990. (Action D13)

Topic: Training 2.1.2 (13) The simulator had severe modeling deficiencies i

involving the core and the nuclear boiler models and their interface with the other simulator models. Although the licensee was aware of these deficiencies and was in the process of making improvements to the simulator fidelity, the current simulator responses were misleading to the operators and could affect their response during transients. The simulator was not certifiable in its present configuration because of these modeling limitations.

(Section 3.2.6.5)

Response: CP&L is aware of the simulator deficiencies noted by the team and acknowledges that the simulator cannet be certified in its present condition. An upgrade program has been underway since May 1986 to improve simulator operational and physical fidelity. The initial phase of the upgrade was to incorporate selected plant modifications on to the simulator, upgrade the operating computers, and upgrade the physical fidelity to have a simulated control room which matched the main control room and elsewhere in the plant.

This phase was completed in December 1987.

Since that time, emphasis has been directed toward improving software modeling. Specifically, replacements were needed for the containment, reactor thermal hydraulic (boiler), and core model and upgrades in other areas. The containment model was replaced in December 1988 and a contract was let to replace the boiler and core model December 2, 1988. Other models.are scheduled to be replaced or upgraded during 1990 to support our certification submittal currently scheduled for December 1990. Per 10CFR55.45 (b) (2) (iv) ,

the simulator must be certified by March 26, 1991. (Action D18)

Prior to each phase of Licensed Operator Retraining or the start of a Hot License RO or SRO simulator training class, the Simulator Support Subunit provides the Operator Training Subunit a listing of plant and simulator differences and outstanding deficiencies.

A listing of implemented modifications and corrected deficiencies is also provided. From this information a lesson plan is developed and delivered to the training class to reduce the impact of modeling inaccuracies on operator responses during normal operations and transients. In addition, unexplained simulator responses are discussed during training critiques to reinforce the correct plant response.

1 DET 09/27/89 43

. Topic: Work Management 2.1.2 (7) Standing Instructions were not being used effectively '

to provide instructions and were an unnecessary burden to the operators. An excessive number of miscellaneous instructions were in effect that were neither indexed nor administratively controlled. Two currently active instructions had already been incorporated into procedures, but not deleted from the Standing Instructions. (Section 3.2.3.1)

Response: Changes regarding the implementation of Standing Instructions are necessary. To ensure that Standing Instructions are administratively controlled, an index log will be developed, I to include cross-reference to action required to remove the Standing Instruction. A 90-day restriction will be tracked on this log, such that at the end of 90 days from the initiation date, the Standing Instruction will have been either removed or reissued for

(' review. The applicable procedure revisions are targeted for completion by October 27, 1989. (Action D20) 2.1.3 (3) The use of the Site Work Force Control Group process was a good work planning practice, but the low level of formalized administrative control of the group's activities was a. potential weakness. (Section 3.3.2.1)

Response: The Site Work Force Control Group (SWFCG) was first established in October 1986. Since that time the site has had several organizational changes and the SWFCG has had several leadership changes. The original charter and guidelines are still i in place. The original guidelines were written to allow maximum  ;

flexibility within approved plant procedures.

l The SWFCG charter and guidelines will be reviewed subsequent to our current organizational changes and revised as required to support current philosophy. This review and required changes will be complete by July 31, 1990. (Action D21) 2.1.4 (8) The program to correct the numerous plant labeling deficiencies was ineffective. The organization responsible for the labeling program was understaffed and a systematic and comprehensive program for the identification, evaluation, and prioritization of plant labeling deficiencies had not been developed. (Section 3.4.2)

Response CP&L concurs that the plant labeling program is not as effective as it should be. By December 31, 1989, Brunswick will centralize valve tagging and labeling efforts in the Plant Services Subunit. By February 28, 1990, a comprehensive and l definitive tagging and labeling " stand alono" document will be I approved and implemented. Subsequent labeling and tagging will be DET 09/27/89 44

to this document. At that same date, February 28, 1990, an action plan will be in place causing us to review and (as appropriate) retag or relabel power plant components. This plan will establish priorities of relabeling /retagging and an initial time line to accomplish same. The time line will be a "living" time line, however, which will recognize unplanned impacts such as unscheduled outages, resource changes, scope changes, etc. (Action D22) 1

-2.1.4 .(9) There was poor coordination between the preventive maintenance and IST vibration monitoring and testing groups within the TS Unit. The preventive maintenance vibration program had many ]

strengths and good practices which were not being transferred to l

the IST program. (Section 3.4.3.1)

Response: This situation had been identified by ISI but had not been solved due to higher priority programmatic issues. The Preventive Maintenance Vibration Program, developed by the Maintenance Support Subunit of Technical Support, will be expanded and appropriately integrated with the ASME Section XI Program.

Currently, full implementation is targeted for December 31, 1990.

(Action D23) 2.1.6 (6) A large backlog of scheduled, but unbudgeted work existed in the form of Engineering Work Requests (EWR) and Project Identifications (PID). Approximately 50 percent of the open (dispositioned) EWRs were due to material problems and obsolete parts, yet there was no program at Brunswick to resolve the obsolete parts issue with the exception of direct replacement of small obsolete valves. Also, the engineering support to complete effective corrective action of EWRs and PIDs was both untimely and inadequate in numerous instances. (Section 3.6.1.2.2)

Response: In mid-1988, CP&L management approved a program to handle the reduction of the EWR backlog in a controlled fashion, focusing on safety, reliability, and efficiency, in that order.

During the disposition process the EWR backlog was reduced from approximately 2000 to 500. In addition, the remaining 500 EWRs were prioritized considering nuclear safety as well as commercial, AIARA, etc., attributes. Due to the fact that the vast majority of open EWRs are low priority items, our 1990 multi-year business plan is incorporating the resolution of the remaining EWRs. The corporate Nuclear Prioritization Process will be used for priority determination in the future. [See response to DET finding 2.1.1 (6).] Senior management has repeatedly demonstrated flexibility in expenditure needs. Additional funding has been provided for emerging issues that were not addressed in the budget or business planning process.

The DET believes CP&L should have an obsolete parts program.

Brunswick does have such a program, however it is not contained in DET 09/27/89 45

a single program document. It is recognized by Procurement, Maintenance and Technical Support that a growing number ~f o components are obsolete. 'These components are handled individually or grouped generically, if appropriate, in an EWR. The EWR process  :

then provides the resolution.

l The third problem the DET identified involved the inadequate and

) untimely engineering on numerous EWRs and PIDs. For EWRs,

" untimely" completion has been a serious problem in the past, but has been significantly improved through efforts begun in 1988.

l Currently EWRs are being dispositioned essentially on schedule.

(See DET item 2.1.6 (12) for a description of planned. and implemented improvements in Technical Support.) Recent changes in the site and general office organizations of the Nuclear Engineering Department will also enhance the quality and timeliness of PID engineering.

s In addition, a different, more responsive approach will be taken in 1990 to the budgeting of small projects and providing engineering support. Previously budgeted separately, these projects (small modifications, direct replacements, design analyses, EWR) will be combined and budgeted as a group.

(Action D24) This approach should facilitate, within appropriate management defined boundaries, changes in a timely manner rather than waiting until the next budget year.

Topic: corporate Guidance 2.1.2 (8) The Emergency Operating Procedures (EOP) were not consistent with the BWR Owners Group Emergency Procedure Guidelines. The procedure format prioritized operator actions according to a predetermined significance and incorporated specific response strategies such as post-scram recovery and station blackout. This format caused the operators to delay implementation of accident mitigation actions during the execution of the EOPs on the simulator. (Section 3.2.3.2)

Response: The EOPs presently in place have been significantly improved since inspection reports 50-325/88-200 and 50-324/88-200 were issued. Brunswick does however plan to revise the EOPs further, to simplify them and to more accurately reflect the BWR Owners Group guidelines.

The revised EOPs will separate the post SCRAM recovery actions from the actions required by the Owners Group guideline, although some Station Blackout actions may remain in the EOPs as required by Regulatory Guide 1.155.

The revision will utilize the guidance given in NUREG - 0899 and NUREG - 1358, and will be developed using a multidisciplinary team approach including human factors involvement. The date for DET 09/27/89 46

E completion is three months after the completion of the second 1990 Licensed-Operator Retraining (LOR) simulator session, but will'be l no later than December 31, 1990. (Action D28) l l

2.1.4 (5) There was no corporate guidance provided for the  !

development of the In Service Inspection /In Service Test (ISI/IST)

I program and no formal provision to incorporate lessons learned from other CP&L facilities into the programs at each site. (Section

)

3.4.1.4)

I Response: While there is no formal corporate guidance on ISI/IST programs, representatives from the three nuclear project sites periodically meet to discuss current issues and " lessons learned."

The OA process has resulted in a revised organization and function for the Nuclear Plant Support Section, which will improve corporate During 1990 I coordination and guidance for appropriate programs.

the Nuclear Plant Support Section will work with the plants to establish an appropriate guidance position. (Action D29)

I I

I I

I I

I

^

I I

I DET 09/27/89 47 I

I E. PERFORMANCE MEASUREMENT Topic: Control Room Log Entries 2.1.2 (3) Control room log entries were rudimentary or nonexistent for many significant occurrences. The log entries frequently I lacked sufficient information to allow management assessment of operational problems for cause and correction. (Section 3.2.2.3)

Response: C2&L concurs that narrative log entries have not in all cases been as comprehensive as would be desirable. Although we do I- believe the majority of such log entries have been appropriate and sufficiently detailed, we have acted to improve the quality of all entries.

Recent explicit management direction has served to produce an I immediate improvement in log entries, appropriately reinforced by completed Real-Time training emphasizing correct log keeping. The Licensed operator Retraining continuing training program is being revised to place additional stress in this area. Revision I completion is targeted for January 1990. (Action E3)

Although we believe our actions have been fully sufficient to I produce and maintain the desired result, management reviews, ensure continued improvement.

we shall, through Topic: Corporate Quality Assurance (QA) 2.1.5 (3) Corporate QA activities were ineffective and reflected a corporate attitude of noninvolvement in site activities. There was a lack of corporate ownership to assist sites in resolving concerns identified in trend reports. The programmatic focus of I

audits performed by Corporate QA were inadequate, focused on document reviews, and were not performance based.

and 3.5.3)

(Sections 3.5.2 Response: Corporate Quality Assurance management is committed to the evolution of the corporate audit program to become more

" performance-based." In doing so, an audit program with the following features will be implemented (Action E4):

o decreased reliance on document reviews; o more effective performance monitoring and trending systems to help trigger audits and assessments in areas with incipient performance problems.;

o increased use of observation techniques; o more emphasis on verification of actual conditions versus I- verification of administrative requirements; DET 09/27/89 48 I

o- use of.the " vertical slice" concept to more effectively assess the performance effectiveness of plant programs and precedures, and the design adequacy of plant modifications; o- improved audits of the corrective action program; and o reporting detail which includes comments and recommendations going beyond those addressing minimal compliance.

o Incorporation of technical experts and experience in audit teams.

These elements will be emphasized in the audit activities currently being pla.ined by Corporate Quality Assurance, and will also be considered in the comprehensive assessment plans which will be developed by the assessment task force described below.

In recognition of the broader concerns relative to corporate leadership and direction, ownership, problem resolution, oversight, and involvement, corporate management has chartered a task force which will report to a steering committee chaired by .the Executive Vice President - Power Supply. The task force charter is to assess the company's nuclear evaluation functions currently residing primarily in the corporate Quality Assurance Department and the Corporate Nuclear Safety Section. These evaluation functions as currently structured include review, audit, and assessment activities, such as site quality control; corporate QA audits; and numerous special assessment, evaluation and independent review activities carried out by Corporate Nuclear Safety personnel. The

, task force is expected to develop recommendations to address the L

modification or deletion of non-productive assessment functions, the addition of more relevant and productive functions, and the merging of any overlapping or duplicated functions where appropriate. This task force will also develop organization and staffing recommendations to support the above functional changes.

The Company's goal in implementing these changes is to provide, on a proactive basis, more focused and useful independent assessment information to the proper levels of management. The result expected is an improvement in the processes of identification of programmatic weaknesses, determination of root causes, and initiation of corrective actions before such weaknesses manifest themselves as significant plant safety issues, regulatory issues, or performance problems.

It is expected that the implementation of initial recommendations of this task force will begin during the fourth quarter of 1989.

1 (Action E5)

DET 09/27/89 49 L

Topic: IST controls 2.1.4 (6) -Nuclear SW system IST controls were inadequate to provide standardized surveillance test conditions and permit proper evaluation of pump performance. (Section 3.4.1.4)

Response: The DET position is valid. The periodic test (PT) used for pump operability, as it is presently performed, does not consider all possible factors that affect repeatability (i.e.,

cross leakage, canal level, and other pumps operating in the building affecting vibration).

To address the inadequacies of service water system in service testing (IST) controls, improvement actions were initiated on June 2, 1989. Associated personnel from Operations, Outage Management, Technical Support and Maintenance were involved to assure full consideration of all concerns.

Immediate action was to revise PT 24.1-1 and 24.1-2 to parform the PT at a certain canal level, document additional pumps running in the building, record strainer differential pressure, and note header pressures. Proposed procedure revisions were given to Operations on June 27, 1989. Current projection for these procedure revisions to be completed is April 28, 1990. (Action E6)

Enhanced pump flow instrumentation is alsc planned which, when combined with other longer term test improvements, will result in consistent, valid test results.

DET 09/27/89 50

[ W L

F. HUMAN RESOURCE MANAGEMENT Topics strengths.

2.1.2 (5) ~The operations staff demonstrated an adequate level of knowledge'of plant systems and~ integrated plant operations. The

. Auxiliary operators exhibited a level of plant knowledge and skill higher than expected for their position. (Section 3.2.2.6)

No response required.

2.1.5 (1) The on-site QA organization consisted of experienced,-

well-qualified personnel. (Section 3.5.1)

No response required.

Topics Career Development 2.1.1 (10) Management succession plans had been developed down to the supervisory level at Brunsvick. However, little evidence of effective career planning and development existed, including job' rotation. (Seccion 3.1.6)

Response: Improved career development and job rotation processes will be developed and implemented. (Action F1) An example of an action already taken is in the Nuclear Plant Support Section (NPSS). .The NPSS has been reorganized to include positions titled Esnager - Corporate Nuclear Technical Support, Manager - Corporate Nuclear Maintenance, Manager -

C ' Nuclear Operations, Manager - Corporate Nuclear Modific,orporate ations/ Outages, and Manager -

Corporate Nuclear Security. These positions are rotational assignments that are on a peer level with their plant equivalents.

l These individuals are responsible for providing corporate level coordination and facilitation. The expected benefits 'of this action are improvements in consistency, communication and operating experience exchange between corporate organization and CP&L's three nuclear projects. See response to 2.1.4 (5) for an example.

DET 09/27/89 51

G. DESIRED CULTURE Topics Strengths 2.1.1 (9) The current management team possesses good human relations, technical, and management skills. This team was competent and capable of making the changes necessary to establish a safety culture at Brunswick and improve overall plant performance. Increased emphasis was being placed on human resource development and people-related issues. (Section 3.1.6) l No response required.

2.1.2 (1) The operators' conduct within the control room was professional. Control room access and noise level were well i

controlled by the Shift Foremen. Shift relief turnovers and crew briefings were performed in a thorough and disciplined manner.

(Sections 3.2.2 and 3.2.2.2)

No response required.

Topic: Safety Culture 2.1.1 ( 4 ) Current senior site managers were substantially involved in day-to-day plant activities and one of the most .significant actions initiated by this team had been to increase the amount of time managers spent in the plant. Additionally, these managers were sensitive to cultural issues and had implemented some corrective action measures, such as communications and teamwork quality teams. However, there was not an overall effective means to respond to people issues. Despite existing programs and l

methods, the prevalent culture at Brunswick was still largely I comprised of the traditional culture characteristics. (Sections 3.1.2 and 3.1.3)

Response: Site management is increasingly involved in day-to-day plant activities, and continues to seek opportunities to address people issues. Several recent management initiatives have opened new channels of communication at Brunswick. Both the Department Manager and the Plant General Manager are periodically hosting informal luncheons with first line supervisors to discuss employee concerns. As a direct result of a readership survey, the Department Manager now periodically contributes a column for the Brunswick weekly newsletter, in which he shares his views on key topics with plant employees. Five new Total Quality Steering Committees have been formed to support the Quality Teams at Brunswick. These new Steering Committees are working closely with team leaders, providing management direction, needed resources, and positive reinforcement for producing quality improvements.

Employee information meetings are now being held regularly DET 09/27/89 52

I throughout the plant, to provide a forum for open discussion of employees' questions and problems. These site management efforts have expanded the positive trend in responsiveness to people issues at Brunswick.

In addition to the above, Brunswick is planning a prototype suggestion program for implementation in late 1989. This program will encourage employees to make suggestions for improvements i directly to site management. (Action Gl)

Further, the corporate focus on Total Quality and post-OA management criteria are providing additional impetus towards a more open, interactive culture.

Topic: Timeliness 2.1.3 (11) Better communications and teamwork among organizational units were needed to recognize, analyze, and correct problems in a timely manner. (Sections 3.3.3 and 3.3.4)

Response: As discussed elsewhere in the DET Report response,

'several other actions are collectively intended to improve I communications and teamwork. Specifically, emphasis on Total Quality Program objectives; the corporate Ndclear Prioritization Process; business plan and goals development; organizational changes to improve ownership, clarity and timeliness; improvements I- in the Corrective Action Program; employee information meetings and working lunches; etc. These actions will also provide a clear understanding of goals, priorities and expectations. Recognition, analysis and timely correction of identified problems should be one of the positive results from these actions.

Topic: Ownership A lack of a sense of ownership was evident throughout I 2.1.1 (2) the organization (corporate and site), and there was a lack of a commitment to "do it right the first time." However, improvements were beginning in these areas. Employee morale at Brunswick was typical of a company going through major reorganization and transition, except for the technical support group where it was lower. (Section 3.1.2)

Response: The sense of ownership throughout the nuclear organization is essential for the culture we are striving for.

Corporate Management must be the role model to achieve this change I in culture. Corporate Management must assume the ownership and responsibility for all plant problems irrespective of where they originate. This culture must domino down the organization such I that everyone in the management chain in which a problem occur.s senses that ownership which in turn creates incentive to take the DET 09/27/89 53

necessary corrective action to remedy the problem as well as place into effect the necessary preventive measures to preclude its recurrence. It is Corporate Management's expectation that this ownership rule is a fundamental piece in establishing clear accountability within the organization.

At Brunswick, specific actions are continuing to improve employees' feelings of " ownership." Some of these actions include (Action G3):

o communication, through employee information meetings, working f lunches, and other forums, of management's emphasis on individual accountability; o clear assignment of leadship responsibility (" head on the horse") for specific initiatives. that involve multiple organizations; o continual reinforcement of the notions that (1) individual success is closely related to the success of the Brunswick Nuclear Project as a whole, (2) all employees involved at Brunswick therefore share " ownership" of Brunswick, and (3) only through effective teamwork can we make Brunswick truly successful; and o Pride in being a part of the Brunswick organization.

Topic: Procedural Adherence / Attention to Detail 2.1.2 (6) Procedures were generally adequate to perform the required tasks, although some were cumbersome. While observed, the operators adhered to procedures during plant evolutions with the exception of minor deviations. However, several operators did not exhibit an attitude of strict procedural adherence. (Section 3.2.3)

Response: To reduce the cumbersome aspects of the procedures, action will be taken to process the current backlog of procedure revision requests that have been initiated by the operators in accordance with procedure OI-28 " Preparation and Review of Operations Procedures." With respect to the DET Report's specific example concerning the routine evolution of valve stroking following maintenance on a single valve, action will be taken to revise or develop procedural guidance on post-maintenance valve stroking.

A clear definition of simple evolutions, and the requirements for use of procedures during routine, repetitive evolutions, process adjustments, and during emergencies has been provided in a September 1989 revision to Operating Instruction (OI)-1, " Operating Principles and Philosophy," incorporating recommendations made by DET 09/27/89 54

i l

l an Operations Quality Team. A survey of the operators concerning their attitudes on procedure compliance will be conducted 'by October 6, 1989, and a follow-up survey will be. conducted by June 30, 1990, to measure attitude changes. (Action G3) 2.1.6 (4) Plant modifications contained an excessive number of ff eld revisions, marginal installation instructions, and failed to address known discrepancies between design requirements and as-built conditions, indicating a lack of attention to detail or competence by the original design engineers and the design checkers / verifiers. (Sections 3.6.6, 3.6.6.1, and 3.6.6.2)

Response: CP&L is not satisfied with the numbers of field revisions to plant modifications. However, to assure appropriate understanding of root cause, CP&L recently performed a statistical evaluation of Brunswick plant modification field revisions, to characterize the type of changes and their related frequencies included in the field revisions.

From the review of the sample field revisions, it was determined that 34 percent are design related and 66 percent are non-design related. The design related field revisions were further divided to determine the relative frequency of root causes for the document changes. The results were:

Design errors 9%

Insufficient design details 10%

Additional design required 14%

for added scope Redesign required due-to 1%

area inaccessibility during design phase 34%

CP&L plans to implement a program by the end (February 1990) of the Brunswick Unit 21989 refueling outage which initiates actions from lessons learned from reviews of plant modification field revisions and other indicators. It is expected that one benefit of this type of program is a reduction in the overall number of field revisions.

l DET 09/27/89 55

i III. INTEGRATED ACTION PLAN (IAP)

The CP&L corporate and Brunswick management team has reviewed each of the recommendations / findings identified, as well as related actions already taken and/or planned that resulted from other recent improvement initiatives. This review included recommendations, findings and actions resulting from the Corporate f

i Management Oversight Team (CMOT), the Nuclear Management Appraisal by Cresap, and the NRC Diagnostic Evaluation Team Report.

Additionally, using the Integrated Action Plan (IAP) model described in Appendix 1, related recommendations / findings were assigned to the appropriate IAP component and grouped by topic.

The actions shown on the following Integrated Action Plan are the Level I results of our review of the findings and recommendations.

This Level I version represents a summary of the actions planned.

This approt :h allows the presentation of the most significant actions without the distraction and volume which would result from inclusion of numerous detailed actions. A more detailed Level II version of this Integrated Action Plan will be used in tracking the specific tasks required for accomplishment of the Level I action items.

The IAP includes cross references to DET, Cresap, and other assessments. All DET findings, except for those which cited strengths, and DET findings 2.1.5 (5) for which corrective actions were completed prior to DET Report issuance, are referenced to one or more IAP actions. The target completion dates shown in the Level I version represent the dates for completion of the final task associated with the stated action. Many of the tasks contained in the more detailed Level II version will be completed before the targeted final completion date shown in the Level I version. Cresap recommendations which are to be implemented, or otherwise dispositioned, are also referenced to one or more IAP actions. The other assessments which are cross referenced are the CMOT and the corporate Organization Analysis. The three CMOT recommendations for which implementation is still underway, are noted in the IAP cross reference "Other" column. The IAP actions that were substantially accomplished through the Organization Analysis, are also noted in the IAP cross reference "Other" column.

The IAP is intended to document those actions being taken to provide ". . .the most rapid and sustained improvement in Brunswick's safety performance." (DET Report) Monthly progress reports for management will be prepared to track implementation progress and document updates to the plan. As stated in our transmittal letter, the Integrated Action Plan is results focused. It is a tool to coordinate actions planned and will be used by management to meet expectations of improved performance. It is recognized that the management process will be interactive, and changes to the IAP are expected. As management reviews the progress being made, adjustments will be made to the plan.

Subsequent to full initial implementation of the identified actions, tracking, statusing, and maintenance of this plan as an entity will be discontinued.

DET 09/25/89 56

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I APPENDIX 1 DESCRIPTION OF THE INTEGRATED ACTION PLAN MODEL The CP&L corporate and Brunswick management team has carefully reviewed each of the findings and conclusions of the NRC DET Report, as well as related actions already taken or planned that resulted from other CP&L-initiated performance improvement

) initiatives (over 200 items). This review included I

recommendations, findings, and actions resulting from the Corporate Management Oversight Team assessment, the Nuclear Management Appraisal by Cresap, the corporate Organization Analysis, and the NRC DET Report. This review concluded that:

o the findings, and conclusions of these initiatives were i quite consistent.

o in the aggregate, the findings and conclusions applied to all aspects of the management process.

o numerous major and minor corrective actions would be required to achieve long-term Brunswick operational excellence.

Based on these conclusions, an Integrated Action Plan model (Exhibit 1) was developed. The model is a management tool that, by showing the relationship of the key management components, effectively reflects the way a large organization works. The purpose of the model was to provide clear focal points for improvement actions. The key management components were then defined as shown on Attachment 1.

Once the model and definitions were established, the DET Report's itemized Section 2 findings, the recommendations from cresap's appraisal, etc. were assigned to their appropriate management component. Placement with a component was determined using the previously referenced definitions and managements' judgment as to the types of action (s) that would yield the most desirable and sustainable improvement results.

For instance, DET finding 2.1.1 (5) states " Site safety goals, priorities, and expectations were not clearly defined and communicated to all organizational levels." And, Cresap recommendation number CRC 5 states " Develop a comprehensive communications strategy that is methodical, highly visible, and employee-centered." The objective of both of these items is to improve leadership and direction; therefore, they were placed with the Leadership and Direction management component. Then, the items within each management component were subgrouped by topic. For instance, within the Desired Culture ma 7agement component there are four subgroups - Safety culture, Timeliness, Ownership, and Al-1

' Procedural.-Adherence / Attention to Detail. (A complete tabulated index is contained in Section I of this response.)

Finally, each subgroup was reviewed to determine the one specific set of outstanding action (s) required to comprehensively address the whole topic. These actions, the persons responsible for implementation, and targeted completion dates are centained within

.the Integrated Action Plan contained in Section'III of this response.

l The benefits of the use of this model are:-

l o Management. components that are facilitating or obstructing the achievement of excellence in Brunswick's operational performance are readily identifiable. t l o A more comprehensive review and analysis of repetitively identified issues.

o A major reduction in administrative tracking and statusing requirements which leaves more time .for accomplishment.

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ATTACHMENT 1 IAP COMPONENT DEFINITIONS Leadership and Direction establishes strategic vision, goals, l priorities, and expectations either formally or informally. I l Effective Leadership and Direction sets the tone for desired I cultural attributes, such as nuclear safety and cost effectiveness; provides a role model and attitude from which necessary actions are identified or developed and/or taken; and provides the bases for the management of our work.

Desired Culture is the framework within which we work. Desired Culture is a result of effective leadership and direction. Desired Culture is both the driver of and driven by how we manage our work.

" ... culture is the unique blend of attitudes, values, beliefs, practices, and self-image that employees have about their work environment." (DET Report p. 19)

Strategic vision, goals, priorities, and expectations dictate Organizational Design. Organizational Design is the structure from which work will be accomplished. Organizational Design includes assignment of accountabilities, evaluation and definition of required expertise (qualifications) and equipment / facility requirements, and resource loading (numbers and types -

CP&L/ contractors). A clearly defined and visible Organizational Design facilitates work management.

Priority Management is the methodology used to set the scope and schedule of work to be performed within assigned accountabilities.

Priority Management includes evaluating the necessity of an identified action or project, specifying the boundaries of acceptability (safety impact, quality level and cost), planning and scheduling (resource load and budget). Effective Priority Management formalizes decision making which results in organizational understanding of why specific actions are taken/ choices are made (buy-in). Effective Priority Management is the key factor in the accomplishment of goals.

Process / Program Management defines "how" accountabilities will be achieved. It is applicable to ongoing processes / programs such as maintenance, and special initiatives such as innovative recommendations for ALARA or cost effectiveness. Effective Process / Program Management is facilitated by a clearly defined and visible Organizational Design and, in turn, assures appropriate interfaces (teamwork), effective utilization of resources and comprehensive regulatory compliance--Right Things Right.

Performance Measurement is the identification and tracking /

monitoring of the components of goals, priorities, and expectations that are objectively measurable. Performance Measurement provides the means for evaluating accomplishment trends and making Al-4

appropriate adjustments to the applicable process / program or management direction.

Human Resource Management directly feeds Organizational Design.

Effective Human Resource Management is the appropriate utilization end development of individuals such that available resources meet organizational needs. Career development actions such as training and rotational assignments; performance appraisal methodologies; and recognition programs are a part of Human Resource Management.

1 Al-5 1

APPENDIX 2 ORGANIZATION ANALYSIS INFORMATION Beginning in late 1988, with the assistance of the Temple, Barker, and Sloan consulting firm, CP&L conducted a comprehensive organization analysis. The objective of this analysis was to focus on improvement of the nanagement process and to apply resources appropriately.

The result of this analysis were announced cp August 28, 1989, and implementation of resultant actions was begun immediately. One result is a number of structural changes in the nuclear program to enhance performance. Significant among these changes are reduced management levels to improve communications, clarified individual accountabilities, and a much stronger corporate focus on individual plant programs such as operations, maintenance, and technical support. Notably these changes have also completed previously initiated organizational changes designed to clearly define the accountabilities, and organization of CP&L's engineering and technical support functions.

All nuclear functions, with the exception of QA, have been realigned to report to a senior nuclear officer who has no non-nuclear assignments. Six guiding principles of organization were used:

o Focus managers on managing o Keep nanagement layers to a minimum o Concentrate on key activities o Define organizational roles clearly o Group activities that depend on each ocher o Direct the organization (s) based on a common expectation of goals.

Mr. R. A. Watson, Senior Vice President-Nuclear Generation, and the quality assurance function each report directly to Mr. L. W. Eury, Executive Vice President-Power Supply. A summary of the key Nuclear Generation Group organization information (related to the Organization Analysis results) is contained in the following table and "new/old" organization charts.

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