ACCEMW~g~~~@gggg oz+ggggggg (pz~P ACCESSION NBR:8808170119 DOC.DATE: 88/08/15 NOTARIZED: NO DOCKET ¹ FACIL:50-'250'=Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION HUDIBURG,J.J. Florida Power a Light Co. RECIP.NAME RECIPIENT AFFILIATION GRACEgJ.N. Region 2, Ofc of the Director gg.r SUBJECT: Forwards response to independent mgt appraisal (IMA) evaluation of IMA prepared by AEOD.. DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ( ENCL I SIZE: TITLE: OR Submittal: General Distribution +I SQ NOTES: RECIPIENT ID CODE/NAME PD2-2 LA EDISONiG COPIES LTTR ENCL 1 0 1 1 RECIPIENT ID CODE/NAME PD2-2 PD COPIES LTTR ENCL 5 5 „„.INTERNAL: ARM/DAE/LFMB NRR/DEST/CEB 8H NRR/DEST/MTB 9H NRR/DOEA/TSB 11 NUDOCS-ABSTRACT Ol EXTERNAL: LPDR NSIC 1 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NRR/DEST/ADS 7E NRR/DEST/ESB 8D NRR/DEST/RSB 8E NRR/PMAS/ILRB12 OGC/HDS2 RES/DSIR/EIB NRC PDR 1 1 1 1 1 1 1 1 1 ~ 0 1 1 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 19
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ACCEMW~g~~~@gggg oz+ggggggg (pz~PACCESSION NBR:8808170119 DOC.DATE: 88/08/15 NOTARIZED: NO DOCKET ¹
FACIL:50-'250'=Turkey Point Plant, Unit 3, Florida Power and Light C 0500025050-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251
AUTH.NAME AUTHOR AFFILIATIONHUDIBURG,J.J. Florida Power a Light Co.
RECIP.NAME RECIPIENT AFFILIATIONGRACEgJ.N. Region 2, Ofc of the Director
gg.rSUBJECT: Forwards response to independent mgt appraisal (IMA)
evaluation of IMA prepared by AEOD..
DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ( ENCL I SIZE:TITLE: OR Submittal: General Distribution
Dr. J. Nelson GraceRegional Administrator, Region IIU. S. Nuclear Regulatory Commission101 Marietta St., N.W., Suite 2900Atlanta, GA 30323
Dear Dr. Grace:
Re: Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251Inde endent Mana ement A raisal — Res onse
In accordance with the requirements of the Nuclear RegulatoryCommission's Order of October 19, 1987, enclosed is theresponse of Florida Power E Light Company to the IndependentManagement Appraisal (IMA) prepared by Enercon Services,Inc., and the evaluation of the IMA prepared by the NRCOffice for Analysis and Evaluation of Operational Data (AEODreport). Each recommendation in the IMA and the AEOD Reporthas been analyzed, and the response sets forth the actiontaken or planned by FPL, and where required,. provides anassociated schedule. In formulating the enclosed response,FPL has also taken into account portions of ENERCON'ssupporting information not reflected in the IMA, assuggested by the AEOD report.FPL's Senior Management, at its highest levels, followedEnercon's progress closely, meeting periodically with theEnercon Senior Evaluation Team (SET). You or the DeputyRegional Administrator attended each of the substantivemeetings. I hope you share our view that the exchange atthese meetings was candid and vigorous.
We are satisfied that the IMA meets FPL's objective ininitiating the study and the requirements confirmed by theorder. The IMA is a thorough analysis of the causes whichunderlay the problems experienced at our Turkey Pointfacility and provides a set of broadly-based recommendationswhich can serve as the foundation for .effective correctiveaction. You will note that FPL generally agrees with eachrecommendation and has completed or initiated action toresolve the problem(s) which underlay the recommendations.
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Although the majority of the IMA recommendations focus onTurkey Point, they also reflect a commensurate need forimproved leadership on the part of the corporate managementand staff. In addition, the IMA highlights the central roleof corporate management in communicating our nuclear goalsand ensuring that they are understood at every level of thenuclear organization. These matters are also identified inthe AEOD Report. Because so many of the necessaryimprovements must be driven by the corporate organization, wehave included a separate section in the response providing a"Corporate Overview" (see pp. 5-14).
The "critical" recommendations in the IMA (those which inEnercon's view most directly affect the likelihood ofsuccess) concern people. In the period since the issuance ofthe October 19, 1987 order, significant changes have beenmade in this regard including:
The appointment of Mr. William F. Conway, aseasoned nuclear executive, as Senior VicePresident-Nuclear. Mr. Conway reports to Mr. C. 0.Woody, who was recently appointed, Executive VicePresident of FPL. All FPL power plant resourceshave been consolidated under Mr. Woody. Mr. Conwayhas primary .responsibility for,. both corporate andsite nuclear'op'erations. He has the full support.of senior management in making such personnel andorganizational changes (including 'personneladditions) as may be necessary to improve theperformance of the corporate nuclear and siteorganizations, especially in maintenance, training,technical support, and operations. He is dedicatedto the proposition that a nuclear organization mustcontinuously strive to attain higher standards ofperformance, and we support that view.
The appointment of Mr. David A. Sager as ActingVice President-Nuclear Energy. Mr. Sager served inthe U. S. Navy nuclear program for six years andhas more than thirteen years of nuclear managerialassignments including key positions at St. Lucieand the FPL corporate nuclear organization. He hasheld an NRC Senior Reactor Operator License. Hehas been charged with the responsibility forcoordinating corporate staff activities includinglicensing, training, engineering, security,maintenance, planning and control, and othertechnical services in support of plant operations.
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The appointment of Mr. James E. Cross as PlantManager of Turkey Point. He has sixteen years ofsuccessful performance in comparable functions atanother nuclear utility. His strong technical andmanagerial background will complement themanagement skills of the Site Vice President.
The appointment of Mr. L. W. Pearce as the TurkeyPoint Operations Superintendent. He was formerlythe Operations Supervisor at FPL's St. Lucienuclear facility. His proven skills are noted inthe IMA. He has been charged with establishing theprimacy of the Operations Department in setting thepriorities for all activities necessary to supportTurkey Point operations.
The appointment of Mr. Arthur R. Cummings as theSecurity Supervisor at Turkey Point. A veterannuclear security expert, Mr. Cummings comes to FPLfrom another operating nuclear plant where he was asupervisor in a SALP-1 security program.
The appointment of Mr. John B. Hosmer to fill thenew position of Director of Nuclear Engineering.Mr. Hosmer has 15 years of experience in thenuclear field in addition to several years in theU. S. Navy nuclear program. He is responsible formanaging the design engineering efforts for thenuclear plants.
These are a few highlights of completed personnel andorganizational changes. You will note in the response toRecommendation 5.1.1 that we have identified thirty fivecritical positions at the corporate and site levels, and areestablishing new job requirements (including specific skillsand experience) for these positions. Incumbents in all ofthese positions will be evaluated against theserequirements. We anticipate completing these evaluations bySeptember 15, 1988. If incumbents do not appear to meet alljob requirements, compensatory measures may be utilizedpending a final decision. In no instance, however, willcompensatory measures be accepted on a permanent basis. Ournear-term goal (i.e. within the next 6-12 months) is to haveeach of these critical positions occupied by a well qualifiedand experienced individual. In order to realize the fullbenefits of these personnel changes, corporate management hassuspended management rotations at Turkey Point for departmentheads, and above, for a period of approximately two years.(Critical corporate nuclear staff positions are not subjectto the rotation system).
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Integral to the success of our personnel and organizationalchanges is an emphasis on management, "visibility" that youwill find reflected in many sections of the response. Ourmanagers have been instructed to spend more time "in theplant" observing work activities, communicating our goals ona daily basis to the work force and verifying the progress inmeeting our commitment to upgrade the plant materialcondition. Corporate officers will also participate in thiseffort.Corporate and site management consider the concept of"ownership" (personal accountability for the recognition andresolution of problems) to be essential. It will bestrongly emphasized during plant tours and on other occasionsby both site and corporate management. This emphasis on siteaccountability reflects our view that both the IMA and AEODreports correctly identify past corporate "overmanagement" asa contributing factor to a "passive plant culture" which didnot encourage development of the initiative and sense ofpersonal responsibility for identifying and resolvingproblems. We are taking steps to change that situation. Asthe enclosed response indicates, accountabilities are beingdelineated at every level; we are also encouraging cross-functional management across departmental lines to providethe teamwork necessary for superior plant operations. We arealready able to see progress in plant operations leadership.
Maintenance is among our highest priorities. The situationat Turkey Point has not improved at a pace which meets ourexpectations. We. have taken steps outlined in the responseto Recommendation 5.3.7, including the application ofadditional resources, which we expect will lead to asignificant improvement. There will be greater emphasis onmaintenance planning and predictive maintenance. Thissituation will be monitored very closely over the next fewmonths. If our goals for improvement are not realized,further measures will be taken. Improved maintenance isessential to FPL's safety and reliability goals. As to thelatter, FPL's current operating philosophy is one whichreflects an acceptance of lower plant availability in theinterests of enhancing reliability (see response toRecommendation 5.3.3). We are prepared, for example, toaccept longer outages at Turkey Point to accomplishnecessary corrective and preventive maintenance. The IMA hasunderscored the importance of clearly restating this policyand assuring that it is understood by the entire nuclearorganization.
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Next to maintenance, our highest priority is engineering andrelated technical support. A fundamental reorganization ofengineering is underway. When completed this fall, FPL willhave a separate, dedicated nuclear engineering organizationheaded by a seasoned nuclear engineering manager. Thisreorganization will eliminate the "culture conflict" inherentin the combined nuclear and fossil engineering functionsreflected in the IMA; it will also facilitate a necessarystreamlining of corporate engineering activities in supportof plant operations. Heavy emphasis is being placed onenhancing system engineering capabilities in the sitetechnical department.
We are also upgrading our corporate and site training staffsas recommended by the IMA in order to reduce the recurrenceof errors and violations. Our plans encompass increases inthe site training staff, improvements in the qualificationsof instructors, updating of training materials, enhancementof simulator training and associated critiques, expandedclassroom training and'doption of' new set of goals andaccountabilities for training (see response to Recommendation5.1.1.d). The role of the corporate nuclear training staffis also being enhanced in the communication of good practicesbetween sites as well as the transmission ,of usefulexperience from other plants.
I have also asked Mr. Conway to take steps to consolidate ourlicensing activities which, as noted in the IMA are toodiffuse. I anticipate that this will improve our regulatoryinterface with the NRC. This is important because a goodinterface facilitates FPL's understanding and implementationof regulatory requirements and the NRC's understanding ofcorporate and site activities. I would add that, whateverelse may be implied from the IMA, FPL does not perceive theCommission as the principal source of the "external demands"which have impaired the ability of the Turkey Point staff todeal with high priority, near-term problems. The problem, inreality, stems from the acceptance of many commitmentswithout full recognition of the resources necessary toaccomplish them by the due dates. This is being addressedthrough a comprehensive re-prioritization of plant changes/modifications and improvement programs. We would, however,appreciate the opportunity to explore with you how inspectionand other regulatory activities might be better facilitatedto alleviate such concerns.
The balance of our response is directed for the most part toprogrammatic improvements which are important and desirable.As the IMA suggests, however, the likelihood of realizingsuccess through these improvements is largely a function of
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how well the "critical" recommendations in the IMA (thoseconcerned with personnel and organizational matters) aredealt with. Recognizing that improvements may not beapparent "overnight", I am confident that. we will besuccessful in this endeavor. The entire IMA effort, Ibelieve, has sharpened our ability to self-identify problems.The performance indicators which will be monitored by Mr.Conway and his staff, as well as the site organizations, willserve as self-assessment measures to gauge our success inimplementing the suggestions and recommendations of the IMAand AEOD as well as our overall progress. Mr. Conway will bereporting to senior corporate management on these matters.
Senior corporate management fully concurs with this responseand is resolved to continue its active involvement in nuclearaffairs in order to achieve and maintain excellence in plantoperations.
We recognize management's accountability for assuring thesuccessful implementation of the commitments in this responseand welcome the NRC's comments and suggestions on our plansas well as any aspect of their implementation.
Very truly yours,
J. J. HudiburgChairman of the Board
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Attachment
Mr. Victor Stello, Jr., USNRCMr. James M. Taylor, USNRCDr. Thomas Murley, USNRCMr. Edward Jordan, USNRCMr. R. Lee Spessard, USNRCMr. Steven Varga, USNRCMr. Herbert Berkow, USNRCDr. Gordon Edison, USNRCMr. Edmond Tourigny, USNRCMr. James Lieberman, USNRCDr. Zack T. Pate, INPODocument Control Desk, USNRCSenior Resident Inspector, USNRC, Turkey Point PlantSenior Resident Inspector, USNRC, St. Lucie Plant
