L-12-310, Human Performance H.1(b) and H.2(c) Substantive Cross-Cutting Issues

Human Performance H.1(b) and H.2(c) Substantive Cross-Cutting Issues

ML12223A206
Person / Time
Site:	Perry
Issue date:	08/09/2012
From:	Kaminskas V FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-12-310
Download: ML12223A206 (18)

Text

FENOC 'i.'

Perry Nuclear Power Plant 10 Center Road FirstEnergy Nuclear Operating Company Perry Ohio 44081 Vito A. Kaminskas 440-280-5382 Vice President Fax: 440-280-8029 August 9, 2012 L-12-310 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Human Performance H.1(b) and H.2(c) Substantive Cross-Cutting Issues On June 22, 2012, via letter L-12-187, the Perry Nuclear Power Plant (PNPP) provided a written response to the NRC describing the causes, corrective actions, and performance metrics to address Substantive Cross-Cutting Issues (SCCls) in Human Performance Cross-Cutting Aspects H. 1(b), Decision-Making, Conservative Assumptions and H.2(c), Resources, Documentation/Procedures.

Metrics were established to monitor key performance attributes in H.1(b) and H.2(c) and to demonstrate that sustained improvement is achieved. A subset of these indicators that demonstrate improved performance has been included as Enclosures to this letter.

PNPP's applicable metrics are described below.

Operational Focus Index: This indicator applies to cross-cutting aspect H.1(b) and measures the success at resolving equipment problems that challenge the operator's ability to operate the plant safely and reliably. It is an indicator of PNPP's focus on using conservative assumptions in making decisions that affect an overall operational focus. The index is calculated by adding attribute values with weighting factors applied for a given month. The attributes include the number of operator workarounds, control room deficiencies, control room annunciators in alarm, open Operational Decision-Making Issues (ODMI), maintenance backlog, and open clearances. The goal is to have an index value of less than 1.0. The index has improved from January 2012 with a value of 1.88 to a current value of 1.41. This is acceptable performance in the white range.

Aoc f

Perry Nuclear Power Plant L-12-310 Page 2 of 3 Unplanned Entries into Shutdown LCOs (Limiting Conditions for Operation): This indicator is a measure of PNPP's success in using conservative assumptions in making decisions that affect the timely resolution of equipment problems that challenge the plant. This indicator also applies to cross-cutting aspect H.1(b) and measures the number of unplanned entries into Technical Specification LCOs, Operational Requirements Manual actions, and Offsite Dose Calculation Manual controls that lead to a plant shutdown if not corrected. The goal is to have no unplanned entries into shutdown LCOs and to maintain the 12-month average less than 1.0. The 12-month average of unplanned shutdown LCO entries currently stands at 0.6. This is acceptable performance in the green range.

Conservative Decision-Making Index: This new indicator, established after causal analysis for cross-cutting aspect H. I(b), measures the effective use of conservative decision-making by calculating an index from the number of station clock resets, section clock resets, precursor errors, and unsatisfactory observations. A weighting factor is applied to each element. Inputs to the observation data are taken from the R.E.A.D.E.

template which is a deliberate decision-making method to respond to uncertain situations that promotes better decision-making, more predictable results, and less risk.

Inputs are also taken from the Operator Fundamentals template and the Safety and Human Performance template. The goal is to maintain an index of greater than 90.

Performance with this indicator through July shows a three-month average at 82. This is acceptable performance in the white range.

Document Change Request (DCR) Throughput: This indicator, established for cross-cutting aspect H.2(c), measures the effectiveness of the timely processing of DCRs to provide accurate procedures and instructions for use. The number of new DCRs submitted versus the number of DCRs completed each month is recorded for the Maintenance, Operations, and Engineering organizations. The goal is to continue to complete more DCRs than those received on a monthly basis. Data has shown a steady reduction in DCR inventory. This is acceptable performance in the green range.

Document Change Request Backlog: These indicators, established for cross-cutting aspect H.2(c), reflect the effectiveness of the timely processing of DCRs for the major work groups of Maintenance, Operations and Engineering. Graphs are provided for the total DCR inventory as well as the priority DCRs. Year end goals are established for each group. The indicators demonstrate a steady improvement in the total number of DCRs for all three work groups. This reflects PNPP's efforts to improve the quality of documents to the workforce. Goals and progress of the individual departments are as follows:

• Maintenance DCRs (All) has a year end goal of 800. Current progress toward achieving the goal is acceptable performance in the green range.

Perry Nuclear Power Plant L-12-310 Page 3 of 3

" Operations DCRs (All) has a year end goal of 690. Current progress toward achieving the goal is acceptable performance in the white range.

Engineering DCRs (All) has a year end goal of 216. Current progress toward achieving the goal is acceptable performance in the green range.

" Maintenance DCRs (Priority) has a year end goal of 350. Current progress toward achieving the goal is acceptable performance in the white range.

Operations DCRs (Priority) has a year end goal of 20. Current progress toward achieving the goal is acceptable performance in the green range.

Goals for all the performance indicators will be periodically reviewed by the management team to ensure the values remain consistent with industry performance.

In addition, performance deficiencies or developing themes in any cross-cutting aspect will be entered into the corrective action program for causal evaluation and determination of appropriate corrective actions.

The enclosed metrics demonstrate improved performance in the cross-cutting aspects of conservative assumptions H.1(b) and in documentation/procedures H.2(c).

There are no regulatory commitments contained in this letter. If there are any questions, or if additional information is required, please contact Mr. Robert B. Coad, Manager - Regulatory Compliance, at (440) 280-5328.

Sincerely, Vito A. Kaminskas

Enclosures:

A Operational Focus Index B Unplanned Entries Into Shutdown LCOs C Conservative Decision-Making Index D Document Change Request Throughput E Document Change Request Backlog (All)

F Document Change Request Backlog (Priority) cc:

NRC Region III Administrator NRC Project Manager NRC Resident Inspector

Enclosure A L-12-310 Operational Focus Index

FirstEnergy Nuclear Operating Company - Perry Sponsor.

Owner:

Poor Group:

Mlonth:

Number:

D)irector Site Operations Operations Manager OP July P-OPS-03

• ~1.50 1.25-1.00 I

6.

0.75 -

Month WIEOperational Focus Index WHITE Operational Focus Index WHT 6 Month AverageII DEFINITION The Site Operational Focus Indicator is a tool that measures our success at resolving equipment problems that challenge the ability of operators to operate the plant safely and reliably. It measures the Operations Staffs ability to cope with routine or off-normal equipment conditions. This indicator also is a measure of the results from H.I(b) Conservative Decision Making actions.

The value is determined by adding all the attribute values for a given month. The following formula will be used to apply weighting to each attribute: (0.08333 times the value for the month) / The GREEN value for acceptability.

Example: Operator Burden Monthly value of 3 = 0.08333*3/2 = 0.1154 I

Operator Burdens (Non-Outage)

Ops Manager S 2 3

4 a 5 Control Room Deficiencies (Non-Outage)

Ops Manager

5 3 4 - 6 7 - 9 a 10 Control Room Annunciators Ops Manager S 3 4 - 6 7 - 9 a 10 Clearances > 90 Days Ops Manager 5 20 21 -25 26-30

? 31 Fire Impairments Fin Superintendent S5 6-10 11 - 15 a 16 Corrective Critical Maintenance Backlog Maint Manager

< 5 5-9 10- 18

> 18 Deficient Critical Maintenance Backlog Maint Manager

< 90 90 - 139 140 - 200

> 200 Temporary Modifications Plant Eng Manager 5 3 4-6 7-9 a 10 Open POD's & PFA's Ops Manager

< 2 3-4 5-6

> 7 Open Operational Decision Making Issues Ops Manager 5 2 3 - 4 5 - 6 a 7 Total Priority 200 & 300 Orders issued in the Work Mgnt Manager 5 2 3-4 5-6 a 7 month I

I I

Operational Focus Index Ops Manager

< 1.00 a 1.00 - < 2.00 a 2.00 - < 3.00 a 3.00 J ____________

.1.

i

Enclosure B L-12-310 Unplanned Entries Into Shutdown LCOs

I GREEN I

I G

I GREE

Enclosure C L-12-310 Conservative Decision-Making Index

(~nn~rv2tiwa fl~i~inn U2kinn Inrkw - PFRRV 2fl12 100.0.---

l Monthly Index 90.0

-Goal 0Three-Month Average 70.0 60.0 Monthly I I Index Good 50.0 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Month:

WHITE Three-Month Ave.:

WHITE DEFINITION -This indicator measures the effective use of Conservative Decision-Making: H.1(b) The licensee uses conservative assumptions in decision making and adopts a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action. The licensee conducts effectiveness reviews of safety-significant decisions to verify the validity of the underlying assumptions, identify possible unintended consequences, and determine how to improve future decisions. (CR corrective action 2011-03966-12)

The data listed in the table below are determined as follows:

Station Clock Resets are those reflected in MPR indicator P-SPO-03 that were a result of inadequate conservative decision-making (number of resets)

Section Clock Resets are those reflected in MPR indicator P-SPO-04 that were a result of inadequate conservative decision-making (number of resets)

Precursor Errors are those reflected in MPR indicator P-SPO-04A that were a result of a weakness in conservative decision-making (number of PEs)

DevonWay Observation Data - READE template - all behaviors (number of UNSAT observations)

DevonWay Observation Data - Operator Fundamentals template - Operators have Conservative Bias behaviors (number of UNSAT observations)

DevonWay Observation Data - Safety and Human Performance template - Supervisor Oversight and Coaching - Workers Demonstrate an Understanding of Risk behaviors (number of UNSAT observations)

Self Assessment - Results of Quarterly Snapshot Self Assessment conducted in accordance with CR CA 2011-03966-2 (Overall assessment rating). This is provided as information only, and is not included in the index calculation.

Month JN FB MR APR iMAY JUN JUL AUG SEP OCT INOV DEC Station Clock Resets 1

0 0

0 0

0 I

(P-SPO-03)

Section Clock Resets 1

0 0

0 2

1 (P-SPO-04)

Precursor Errors 03 I

9 8

3 I

(P-SPO-O4A)

Observation Data - READE 0

I0 1

0I Observation Data - Operator 1

0 0

0I Fundamentals template Observation Data - Safety and Human Performance 0

I 0

2 3

I template Self Assessmen Reut 0

I 0

0 0

Monthly Index i

lg8.5 Three-Month Average 60 7

3 85 I83 86 82 Goal 90.0 900

9.

900 I

9.

9.0

9.

9.0 00 Monthly and Three-Month>90>8-<90>7-<80<0 Average index 70

<- 0<7

Enclosure D L-12-310 Document Change Request Throughput

FirstEnergy Nuclear Operating Company - Perry aponsor:

wner:

i-eer C~roup:

Mon-fl N--"umbfer:

Director Site Operations Section Mgrs July-12 N/A 350 -

300-250 -__

150 -

100 -

50 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 U DCRs Received 0 DCRs Completed Month:

n Year-end Expectancy:

DEFINITION F

I This metric depicts the number of new Document Change Requests (DCRs) submitted versus the number of DCRs completed each month for the Maintenance, Operations and Engineering Departments. This metric is linked to cross-cutting aspect H.2(c) as a station measure in producing quality documents for the workforce.

q-q-q-q-q-,-Y-.

Month May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 DCRsReceive 114 47 111 DCR.Completd 166 115 319 Maintenance Received 53 18 67 Maintenance Completed 18 50 302

• Operations Received 38 26 32 Operations Completed 31 48 8

Engineering Received 23 3

12 Engineering Completed 117 17 9

Measures Green = completing White = completing Yellow =completing Measures 11 more then 0 to 10 more than I to 10 less than received received received Red = completing 11 or less than recieved

• There was a reduction in the DCR backlog due to consolidation and elimination of old DCR enhancements

Enclosure E L-12-310 Document Change Request Backlog (All)

FirstEnergy Nuclear Operating Company - Perry I

ponsor:

Iner:

eer oroup:

onm Numer:

Director Site Maintenance Section Mgrs Maintenance July-12 N/A 1200 1100 1000 900 800 700 600 500 400 300 200 100 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Yearend Goal Mechanical Inventory 1-1'Electrical Inventory I&C Inventory

--*Goal P =

RM.0 NCE Month:

Year-end Expectancy:

DEFINITION This metric reflects the total inventory of all open DCRs for the Mechanical, Electrical, & t&C Shops of the Perry Maintenance Department. The performance rating is based on total number against the projected goals set by the department for the end of the current year. This metric is linked to cross-cutting aspect H.2(c) as a station measure in producing quality documents for the workforce.

Month Year Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 end Mechanical Inventory 185 189 187 197 202 187 140 120 Electrical Inventory 1631 153 1 164 11471 133 1 137 119 1

I&C Inventory 734 751 832 W

844 W

810 w

789 w

617 58o Measures Green =

Below goal (20+)

White =

Below goal (0 to 19)

Yellow =

Above goal (1 -19)

Red =

Above goal (20+)

• There was a reduction in the DCR backlog due to consolidation and elimination of old DCR enhancements

FirstEnergy Nuclear Operating Company - Perry aponsor:

O-tw-ner:

-reer;5roup:

4.0nl Number:

Director Site Operations Section Mgrs Operations June-12 N/A 800 -

750 700 650 600 550 500 450 400 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Year end Goal Operations Inventory Radiation Protection Inventory in Chemistry Inventory

• -Goai Month:

Year-end Expectancy:

DEFINITION F

This metric reflects the total inventory of all open DCRs for the Operations, Radiation Protection, and Chemisty sections of the Site Operations Department. The performance rating is based on total number against the projected goals set by the department for the end of the current year. This metric is linked to cross-cutting aspect H.2(c) as a station measure in producing quality documents for the workforce.

Month Year Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 end Operations Inventory 599 559 579 540 551 547 562 550 Radiation Protection 41 46 49 5213315 54 Inventory I

I i

i Chemistry Inventory 101 106 109 107 109 110 111 I 90 Green =

Measures Below goal (20+)

White =

Below goal (0 to 19)

Yellow =

Above goal (1 to 19)

Red =

Above goal (20+)

FirstEnergy Nuclear Operating Company - Perry ponsor.

ner eer roup:

O urn er:

Director Site Engineering Section Mgrs Engineering July-12 NIA 200 -

Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Year end Goal Design Eng Inventory Plant Eng Inventory Reactor Eng Inventory 2Technical Eng Inventory -*--Goall PERFORM ANC Month:

Year-end Expectancy:

DEFINITION This metric reflects the total inventory of all open DCRs for the Design, Plant, Reactor, and Technical Services sections of the Perry Engineering Department. The performance rating is based on total number against the projected goals set by the department for the end of the current year. This metric is linked to cross-cutting aspect H.2(c) as a station measure in producing quality documents for the workforce.

Month Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Goal Actual 328 347 318 326 220 208 212 2121 Design Eng Inventory 18 29 31 31 28 28 28 20 Plant Eng Inventory 170 176 147 146 115 112 117 150 Reactor Eng Inventory 39 39 37 41 31 25 26 225 Technical Eng 101 103 103 108 46

• 41 41 2

In v e n to r I...I.

II Green =White

=Yelltow

Red

Measures Below goal Below goal Above goal Above goal (20+)

(0 to 19 )

(1 to 19)

(20+)

• There was a reduction in the DCR backlog due to consolidation and elimination of old DCR enhancements

Enclosure F L-12-310 Document Change Request Backlog (Priority)

FirstEnergy Nuclear Operating Company - Perry Sponsor:

owner.

Peer (roup:

MonLtf1.

Numer:

Director Site Maintenance Section Mgrs.

Maintenance July-12 N/A 475 425 --

375 325 275 -

225 175 125 75 25 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Yearend Goal Mechanical Inventory

=Electrical Inventory I&C Inventory

-i-Goal Month: I WhiteI Year-end Expectancy:

DEFINITION I

This metric reflects the total number of priority DCRs for the Mechanical, Electrical, & I&C Shops of the Perry Maintenance Department. Priority DCRs are described as requests from the following categories: Corrective Actions (CA), Restraints, DCR (not including enhancements), and Engineering Change Packages (ECP). The performance ranking is based on total number against the projected goals set by the department for the end of the current year. This metric is linked to cross-cutting aspect H.2(c) as a station measure in producing quality documents for the workforce.

Month Year Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 end III( lI Mechanical Inventory 81 80 76 82 85 77 73 1501 Electrical Inventory

[44 38 44 39 [

32 J33 139 30 1J1 1

I&C Inventory 322 W

303 w

274 284 279 270 Measures Below goal B

Below goal Above goal Above goal (20+)

1 (0-19)

(1-19)

(20+)

FirstEnergy Nuclear Operating Company - Perry sponsor:

wner:

Peer (`MUp:

1910i 11 Numbmer:

Director Site Operations Section Mgrs Operations July-12 N/A 30-------

29 28 27 26 -

25 2 4 -

1 -

23 22 --

21 20 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Year end Goal Operations Inventory Radiation Protection Inventory Chemistry Inventory G

PERFORMANCE Month:

Year-end Expectancy:

DEFINITION I

This metric reflects the total number of priority Document Change Requests (DCRs) for Operations, Chemistry and Radiation Protection sections of the Site Operations Department. Priority DCRs contain requests associated with one of the following categories: Corrective Actions (CA), Restraints, DCR (not including enhancements). The performance Rating is determined by comparing the number of priority DCR's to the monthly goals established by the Department Managers. This metric is linked to cross-cutting aspect H.2(c) as a station measure in producing quality documents for the workforce.

Month Year Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 end Operations Inventory 24 1

20 1

Radiation Protection Inventory 0

Chemistry Inventory 2

I oI

,.,reen =

Measures Below goal (2+)

vvnte =

Below goal (0 to 1)

YellOW =

Above goal (1 or 2)

Kea =

Above goal (3+)

I