ML030910579

Meeting Handouts - April 1, 2003 Meeting

ML030910579
Person / Time
Site:	Davis Besse
Issue date:	04/01/2003
From:	Energy Northwest
To:	Office of Nuclear Reactor Regulation
References
Download: ML030910579 (35)

Text

Mleeting with the NVRC Date-April]1, 2003 Place - NRC Headquarters Rockville, MD Attendees - D.K. Atkinson, Vice President, Technical Services M.C. Humphreys, Manager, Engineering D. W. Coleman, Manager, Performance Assessment and Regulatory Programs ENERGY NORTHWEST People Vision Solutions

Agenda Introductions- Davis-Besse (DKA)

• Station Challenges (DKA) lAlternate Source Term Re-Submittal (MCH)

• Accuracy and Completeness of Submittals to the NRC (DKA)

PreliminaryFindingsof Team EvaluatingAccuracy and Completeness Issue (DKA)

• Columbia Oversight Board (DKA) nPlannedEnergy Northwest Submittals to the NRC (D WC) oStation Successes (DKA)

ENERGY 2 NORTHWEST People

• Vision Solutions

How Are We Addressing Davis-Besse Issue Recommendation 1 Discuss Davis-Besse Case Study

Response

1. All-Hands Briefing to Energy Northwestpersonnel (Complete)

2. TAGs review SOER and incorporatelessons learned in continuing trainingprograms (5/2003)

3. Core Davis-Besse lesson planfor use in all accreditedtraining programs(7/2003)

4. Provideformal trainingto all managers and supervisors (12/2003)

5. Incorporatea review of Issue in initialmanager/supervisor training(7/2003) ENERGY 3 NORTHWEST People

• Vision - Solutions

How Are We Addressing Davis-Besse Issue

-,Recommendation 2 Perform Self-Assessment to Determine Columbia Vulnerability

Response

1. Perform USA sponsoredRound Robin Assessment (7/2003)

2. Evaluate identifiedproblems or areasfor improvement and incorporateinto CorrectiveAction Program (7/2003)

3. IntegrateINPO guidance into existing Audit and Self-Assessment programs with focus on healthy "Safety Culture" (7/2003)

~ ENERGY 4 \ NORTHWEST People *Vision - Solutions

How Are We Addressing Davis-Besse Issue Recommendation 3 Identify and Document Abnormal Plant Conditions That Cannot be Readily Explained- Focus on Long-Term Issues

Response

1. Establish a review team to identify, review, screen, and evaluate any abnormalconditions (4/2003)

2. Evaluatepotential effects of identified items for aggregateand worst case conditions;prioritize actions (8/2003)

3. Ensure senior management is aware ofsignificant abnormal conditions (8/2003)

4. Enter significant abnormalconditions into the CorrectiveAction Programandperform root causes (8/2003)

ENERGY 5 NORTHWEST People* Vision

• Solutions

How Are We A.ddcressing Davis-Besse Issue Recommendation 3 (cont.)

Identify and Document Abnormal Plant Conditions That Cannot be Readily Explained - Focus on Long-Term Issues

Response

5. Presentidentified conditions and their status to Columbia Oversight Board (ongoing)

6. Perform Quality Review of the results of the Review Team (12/2003)

ENERGY 6 NORTHWEST People* Vision* Solutions

Station Challenges

- 1-1-11-I--

. -----l-I I .---.1- -l-.1-Fuel Concerns Security Budget Outage Equipment Reliability ENERGY 7 NORTHWEST People* Vision - Solutions

AST Re-submittal Agenda i

• Review of Submittal Issues

• Root Cause Evaluation Summary

• Scope of Re-Analysis

• Project Schedule

• Closing Remarks ENERGY 8 1 NORTHWEST People Vision Solutions

A ST Submittal Issues MeteorologicalData Errors related to datapreparationand input to ARCON96

• Incorrectcoding of missing or invalid data with 9s

• Not recognizing orientationof delta T measurement

• Incorrectwind speed unit selection

• Conversion to degrees centigradeper 100 meters

• Communication with NRC

• Control Room In-leakage Flow (Ingress/Egress)

• Status of secondary containment drawdown analysis ENERGY 9 NORTHWEST People Vision

• Solutions

= --- -

AST Submittal Root Cause Evaluation Summary Three root causes identified

• Energy Northwest supplied meteorologicaldata to vendor that was inadequatelydocumented (units, polarity not clear)

• In this instance, Energy Northwest 's personnel did not assure (andprogram controls did not require) the vendor to provide documentation of input receivedfrom Energy Northwest, data manipulations, and data applicationin analysis

• The vendor's Appendix B calculationprogramfailed, i.e., it allowed the transmittalof inaccurateARCON96 analysis results to Energy Northwest ENERGY 10 NORTHWEST People

• Vision

• Solutions

AST Submittal Root Cause Evaluation Summary Three significant contributingcauses were identified

• In this instance, Energy Northwest 's review of the vendor deliverable was inadequate, and the governingprocedurefor submittal reviews provided inadequateguidance on the level of technical review requiredforvendor calculationsusing data provided by Energy Northwest

• The level ofEngineeringsupervision involvement was not appropriatefor the level of experience and competence of the staff involved (1999 timeframe)

• Energy Northwest management did not ensure continuity of Licensing involvement and adequateprogrammaticcontrols to precludefailuresin communication with the NRC 1 NORTHWEST People

• Vision - Solutions

AST Submittal Root Cause Evaluation Summary CorrectiveActionsfor root causes

• Establishguidance on retrieval, review, documentation, and coordinationof historicaldigitally archived data records (approximately 350 records)

• Require vendors submit plant datafor Energy Northwest approvalprior to use of data

• Vendor 's qualificationstatus has been suspendedpending re-evaluation to ensure their acceptabilityfor QC] work ENERGY 12 NORTHWEST People - Vision* Solutions

AST Submittal Root Cause Evaluation Summary

• Corrective actionsfor contributingcauses

• Clarifyproceduralrequirementsfor review of vendor submittals including adequate review of input data

• Ensureproject controls, structure, and staffing are followedfor complex projects such as AST

• Address communications with outside agencies as part of station top priority issue on "Accuracy and Completeness of Staff Work" (Note: Additional issues concerning accuracy and completeness of staff work will be addressedaspart of the associatedstation top prioritycorrective actions.)

ENERGY 13 wNORTHWEST People* Vision

• Solutions

AST Re-submittal Scope of Re-Analysis

• Meteorologicaldata

• Use datafrom 1993 - 1998 (greaterrecovery rate than 1980s data used previously)

• Re-analyze using ARCON96

• Drawdown analysis

• Previously submitted 1996 Gothic model of the building

• Updating to version 7.1 of Gothic

• Re-validating model priorto re-submittal ENERGY 14 NORTHWEST People *Vision

• Solutions

AST Re-submittal Scope of Re-Analysis

• MSLB Analysis

• Submittal will continue to be based on the bubble model currently used corrected by thefollowing:

- Gravity term added to force equation

- Drag coefficient revised

• Sensitivity case will be performed based on DG-1111 ENERGY 15 \ NORTHWEST People* Vision* Solutions

AST Re-submitta.l Scope of Re-Analysis Dose Analysis

• Use revised meteorologicaldata and updatedARCON96 analysis

• New PA VAN offsite X/Q valuesfor 1990s meteorological data

• Take no creditfor Reactor Building mixing (40% previously)

• Use AEB 98-03 approach with the 10% sedimentation velocity values (between MS isolation valves)

• Remove unfiltered inleakage uncertainty after 30 minutes (go to single train and less than 100 cfin inleakage at 30 minutes)

• Include 10 cfin ingress/egress

• Re-submit based on revised dose analysisfor each accident (LOCA, FHA, CRDA, and MSLB)

ENERGY 16 NORTHWEST People* Vision* Solutions

AST Re-submittal Schedule

. --------- -- --I-1---I .-IN - --- I--11-1-- --- ...- --. x Activity Date ProcessMeteorologicalData 8/2003 ARCON96 and PA VANAnalysis 10/2003 Dose Analysis 12/2003 Licensing Documentation Preparation 3/2004 Review and Approvals 4/2004 Submittal 4/2004 ENERGY 17 NORTHWEST People* Vision Solutions

Accuracy and Completeness of Submittals to the NVRC

• Over the past several months, some communicationsfrom Columbia GeneratingStation to the NRC contained errors,omissions, and misleadingstatements, most notably the AST submittal.

• Some of the communicationproblems were identifiedfromfollow-up after the NRC asked questions.

• NRC personnelhave responded to theseproblems by communicating to Energy Northwest management that they have concerns regarding the accuracyand completeness of our communications.

• This is a situation that must be corrected.

ENERGY 18 NORTHWEST People

• Vision

• Solutions

Accuracy and Completeness of Submittals to the NRC (Cont)

, Long-term measures are being developed to improve the quality of communications between Energy Northwest and the NRC.

• Until these measures are implemented, management expectations and guidelines for communicating with the NRC have been developed and communicated to Energy Northwest employees.

• We will be implementing a graded review process for written communications that contains expectations for preparers and technical reviewers, and facilitates early management comment and direction. This process is under development as we are currently benchmarkingother utilities.

ENERGY 19 NORTHWEST People *Vision

• Solutions

Accuracy an Completeneess of Submittals to the NRC (Cont)

• Two recent Problem Evaluation Requests (PERs) have been initiatedto address accuracy and completeness of submittals to the NRC.

• PER 203-0790 documents an adverse trend ofproviding information to outside regulatoryagencies that contained errors or was otherwise incomplete

• PER 203-0877 documents that the adverse trend noted in PER 203-0790 had not been identified by the corrective action program'sperormancemonitoring and trending.

ENERGY 20 NORTHWEST People *Vision Solutions

Accuracy and Completeness of Submittals to the NRC (Cont)

• Energy Northwest hired an outside team to evaluate the issue of completeness and accuracy ofEnergy Northwest staff work.

• The team focused on standardsofperformance and accountability, processes andprocedures, customer and vendor relationships, application of resources, and relevant organization/human performance observations.

ENERGY 21 NORTHWEST People

• Vision* Solutions

Team FindingsBasis

• Accuracy- values, dates, commitments, equipment status and other materialinformation arefactually correct.

• Completeness - content ofdocuments, discussions, presentations and otherforms of communication that contain all of tiefollowing (1) are based on what isfully known at the time, (2) are sufficiently detailed such that a peer or other technically capable reviewer could confidently reach the same or similarconclusion(s) based on information presentedand, (3) meet the needs of the recipient without requiringsubstantive revision to fulfill intended applicationand acceptance.

• Quality -Attribute of work products that includes both accuracy and completeness, i.e., hi§h quality work products are both accurate and complete. This includes both station specific work products and work products transmittedto external agencies.

• Validation- the process of ensuring information is both accurate and complete. ENERGY 22 NORTHWEST People *Vision

• Solutions

PreliminaryOverall Team Conclusions A t ALL levels of the organization:

• Not sufficiently employing introspection or self-checking to ensure i_

"return on investment "

Higher level ofperformance is expected - some surprise it has not been achieved

• Not leveraging the "pyramid"from all levels

• It should be OK to not know everything technically (should know status)

• More effective use of contact time and review boards

• Demand accountabilityfrom Subject Matter Experts and Points of Contact and allow them to be the experts ENERGY 23 NORTHWEST People *Vision

• Solutions

PreliminaryOverall Team Conclusions At ALL levels of the organization(cont.):

i Too often rewarding "wrong" behaviors - prioritiesare misaligned with management objectives Activity driven, want higher quality but often not rewarded

• Insufficient contact time Senior Management does not spend enough time in the field promoting its expectations lIssue goes beyond submittals to NRC Can be seen in regularstaff work (e.g., completeness of workpackages)

ENERGY 24 NORTHWEST People *Vision - Solutions

PreliminaryTeam Recommendations Some short-term actions to consider:

• Connect with the organizationmorefrequently - communicate expectations,follow-up, enable desired behaviors, emphasize quality-not schedule, accept risk (on informal basis and through review boards - both how and when)

• Use Subject MatterExperts and Points of Contact more effectively (e.g., establish clearground rules)

• Inject independent 'fresh eyes" to achieve consistent desired behaviors

• Establish regulatory interfacestrategy (e.g., formalize what "certification" means and identify owner, increasesite awarenessto regulatory needs andprocesses)

ENERGY 25 PeopleNORTHWEST

-Vision* Solutions

PreliminaryTeam Recommendations Some long-term actions to consider:

• Improve quality considerationsfor key plantprocesses (e.g.,

vendor transmittals, FA Q preparation,CAP)

• Reflect on investments - identify and implement opportunities forfurther leverage

• Invert incentive approach -focus on quality and accountability ENERGY 26 NORTHWEST People *Vision Solutions

Columbia Oversight Board a Purpose i Provide a Forumfor Senior Management to Monitor and Challenge Key Aspects of Station Activities and Performance Membership VP. Nuclear Generation VP. Technical Services Plant GeneralManager Freg uency Bi- Weekly ENERGY 27 NORTHWEST People

• Vision- Solutions

Columbia Oversight Board ai Sample Topics Safety Security OutageReadiness Equipment Reliability Effective MaintenancePlanningand Execution Emergency Plan ENERGY 28 l NORTHWEST People

• Vision Solutions

PlannedEnergy Northwest Submittals to NRC

• Voluntary update on SW-A wall thinning

• LOCA Analysis Methodology Changes

• Submit Results of the Root Cause Analysis on AST Errors

• LER to report completion of a plant shutdown that was requiredby Technical Specifications and to report that a NOED was requiredto avoid exceeding the completion time of Technical Specification condition 3.8.1 .B -April, 17, 2003

• ISFSI Security OrderResponse - April 24, 2003 ENERGY 29 NORTHWEST People

• Vision* Solutions

PlannedEn ergy Northwest Submittals to NRC (Cont)

U

• TSTF-359, Flexible Mode Restraints - September 2003

• License Amendment to extend DG AOT to 14 days -

March 2004

• Licensing Renewal - Expect to start budgetingfor license renewal in FY-05

• Projectedsubmittal 2OXX

• Projectedapproval 2OXX

• Current license expiration 2023 ENERGY 30 NORTHWEST People *Vision Solutions

Station Successes ISFSI

• Constructionproject completed on schedule and under budget

• Five casks loaded

• Ten more casks to be loaded over next two fiscalyears to restore full core offload capability eAwarded "Projectof the Year" by ProjectManagement Institute Security lImplemented security order on schedule

• NRC inspection completed with no findings

• Begun implementation ofAccess Authorization Order oRevised outage worker in-processing ENERGY 31 INORTHWEST People -Vision* Solutions

Station Successes M Station Generation Priorto diesel outage, plant had exceeded its previous recordrun by over 100 days Columbia Generating Station CapabilityFactor 100%

90%

80%

, 70%

IL 60%

. 50%

M 40%

°~ 30%

0 20%

10%

0% M 0 0 0 0 0 0 U,0 FY94 FY95 FY96 FY97 FY98 FY99 FY00 FY01 FY02 ENERGY 32 NORTHWEST People -Vision* Solutions

SS Station Successes Columbia Generating Station Net Generation I n Net Electrical Generation (MW-hrs)

• Dispatch Credit (MW-hrs) I 10,000,000 9,000,000 I

8,000,000

}- I I, 7,000,000

'a E 6,000,000

r PE l- t -l 5,000,000 4a 4,000,000

,: l I FltIttIf AU 3.000,000 2.000.000 M ll 1,000,000 0

FW5 FY86 FY37 FY88 FY89 FM0 FY91 FY92 FW3 F4 FY95 FY96 FW7 FY98 FW9 FY00 FYOI FY02 i f'i ENERGY 33 NORTHWEST People 'Vision ' Solutions Ce'

Station Successes Columbia Generating Station IN PO Performance Indicator Index 4th Qu arter 1991 - 4th Quarter 2002 100 I

90 80 70 M 60 80 I 40 I I I 30 I II I II 10 I III n

I III r 9 s9 , 9 9 9 MonthlYear 34 NORTHWEST People -Vision -Solutions

Station Successes I-11 Projects Organization

• Company taking a project orientation wManpower Loading and ProjectPlanningreceived an INPO strength

• Otherplants benchmarkingprocess (e.g., Diablo Canyon)

• Providingassistanceto plants adopting methodology ENERGY 35 NORTHWEST People Vision - Solutions