ML20012C199
| ML20012C199 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/14/1990 |
| From: | Carns N ARKANSAS POWER & LIGHT CO. |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| 0CAN039001, CAN39001, NUDOCS 9003200280 | |
| Download: ML20012C199 (296) | |
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i March 14, 1990 '
p SCAN 039001 Mr. James M. Taylor Executive Director for Operations ;
U. S. Nuclear Regulatory Commission '
A Washington, D.C. 20555 ,
SUBJECT:
Arkansas Nuclear One - Units 1 and 2 i
Docket Nos. 50-313/50-368 License Nos. DPR-51 and NPF-6 Response to Diagnostic Evaluation Team Report and to i Systematic Assessment of Licensee Performance Report (Inspection Report 50-313/89-34; 50-368/89-34)
Dear Mr. Taylor:
,^ In our letter dated January 10, 1990, we stated our plan to provide a Q
combined response to the December 21, 1989, Nuclear Regulatory Commission (NRC) Diagnostic Evaluation Team (DET) Report and the November 28, 1989, '
NRC report of the Systematic Assessment of Licensee Performance (SALP) for !
Arkansas Nuclear One (AN0), Units 1 and 2. ANO 1etter dated February 16, 1930, documented. AN0's telephone request and your subsequent approval of an i extension for submitting the DET/SALP response by March 19, 1990. Attached is our combined response which addresses each finding identified in Section ;
.2 of the DET Report and each NRC recommendation identified in the SALP Report.
We are committed to improve our overall perforiaance and level of safety at ANO. Our review of the DET and SALP Reports have concluded that the r findings do not individually or collectively adversely. impact s the plant :
response during an event. Actions already taken _have resulted in perfor- ,
mance improvements; however, our assessicent . of the nature of these deficiencies indicates that broader, pr6grammatic irrprovements are needed ,
in some areas. This response defines those acties we are taking to achieve these improvements.
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w BCANO39801 Q March 14, 1990 Page 2 The DET Report, the SALP P.cpert =d ANG's own assessments were reviewed to determine root cmes. Through these reviews, AND identified specific root casas and t' nen categorized them into five broad root cause areas: Manage-ment Involvement and Leadership; Safety Culture; Planning, Scheduling, and Resource Requirements; Assessment, Trending, and Root Cause Analysis; and '
Program Related Issues. The NRC-identified root causes included in the DET or SALP Reports were consistent with the ANO assessment of root causes.
The ANO Business Plan, which is an integral part of this response, is the comprehensive action plan that will address these root causes and provide for continuing improvement in the operation and safety of ANO. Our commit-ment is to implement a Business Plan with the main objective to enhance ,
everall safety at ANO. The Business Plan also represents AN0's actions to address each of the DET and SALP findings, as well as broader areas requiring improvement as identified in ANO self-assessments. Priorities of work have been set and an assessment of resources made. For each activity, schedules have been assigned and goals and objectives have been defined.
ANO will track action items addressed in-the AND Business Plan from their inception to completion. In addition, ANO will monitor the status and effectiveness of these action items through milestones, measurements of effectiveness, and self-assessments as appropriate. The ANO Business Plan
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represents an effective tool for establishing priorities and milestones.
Any change- in priorities or schedules reequires a specific level of V) t ,
management approval.
A number of recent actions have been taken at ANO to strengthen the manage-ment process and structure. ANO has been reorganized to improve communica-tion and increase the level of support for the plant. Also, a number of new people from outside ANO have filled management positions. In addition, effective January 1,1990, William Cavanaugh, III became the Executive Vice President and Chief Nuclear Officer of AP&L, and Donald C. Hintz became the Senior Vice President - Nuclear. These changes focus the attention of the System's most experienced nuclear executives on the improvement ',f ANO operations.
ANO anticipates that within the next few months, operation of ANO and the *
, other nuclear plants in the Middle South Electric System, will be consoli-dated under a new company, Entergy Operations, Inc. (E01). After the consolidation, Mr. Cavanaugh will be President and Chief Executive Officer of E01, and Mr. - Hintz will be Executive Vice President and Chief Operating Officer. Furthermore, the other employees of AP&L responsible for ANO operations will be transferred virtually intact to E01. Therefore, the managers responsible for ANO and for implementation of the Business Plan, and the commitment of management to significantly impreve ANO operations and safety, will continue throughout the consolidation.
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. Mr. James M. Taylor
(, , SCAN 039001 1> March 14, 1990 Page 3 i
The corrective actions currently in progress, coupled-with the implementa-tion of future actions identified in our response and in the ANO Business Plan, are designed to improve safety and performance at ANO. Effective implementation of these actions will enable us to improve the overall safety culture, performance, and material condition at ANO. We are committed to ,
making AND an industry leader and recognize that it will take significant management attention to accomplish this objective. ,
We will contact your staff to discuss the contents of this submittal.and the status of our actions. We intend to meet with your staff frequently during t the next year regarding progress toward improvements and measuring success along the way. If you have any questions, please contact me.
Sincerely, YW NSC/dkn Attachments cc: U. S. Nuclear Regulatory Commission '
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i' 4 Document Control Desk Mail Station P1-137 Washington, D.C. 20555 Regional Administrator Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 P
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. ANO DET/SALP RESPONSE St0 TABLE OF CONTENTS J! i
, Pate No.
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~ 1. ; EXECUTIVE
SUMMARY
.............................................. I s . '-
-1.1- Introduction.............................................. I
- p. 1.2 Root Cause Identification 'and Corrective Action Summary... 3 1.3: Methodology................................................ 7 L 1.4 ANO Business Plan Implementation...;...................... 8 Attachment 1 - Priorities................................. 9 1.5 Management Controls and Assessment........................ 8
- 2. RESPONSE TO DI AGit0STIC EVALUATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10.
2.1.1 Management and Organization........ .................... 12 2.1.2 Operations and Training................................. 27 gg 2.1.3 Maintenance.................... 4 . . . . . . . . . . . . . . . . . . . . . . . 45 L ;'~T 2.1.4 Surveillance and Testing.....................a........... 61' 'l
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-2;1.5 Design and Engineering Support.......................... 71 97
- 3. , RESPONSE TO SALP................................................- 94 3.1 Plant Operations..........................................- 95 t
3.2 Radiological Controls..................................... 103 3.3 Maintenance / Surveillance.................................. 106 3.4 Emergency Preparedness.................................... 113
'3.5 Security.................................................. 115 3.6 Engineering / Technical Support............................. 118 nr 3.7 ~ Safety Assessment / Quality. Verification.................... 123 '*
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[APPENDIXB(-ANOMANAGEMENT,0RGANIZATIONOVERVIEW.......;......... .137 i
9Ou.# i 6'a 4 APPENDIX C:-LAN0' BUSINESS PLAN .....................................
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1 RESPONSE TO l NRC DIAGNOSTIC EVALUATION TEAM REPORT l
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT TOR ARKANSAS NUCLEAR ONE i
1.0 EXECUTIVE
SUMMARY
1.1 INTRODUCTION
The NRC completed their SALP assessment of ANO Units 1 and 2 covering the j period July 1, 1988, through September 30, 1989. This assessment resulted in one Category 1, four Category 2, and two Category 3 ratings. Although the NRC stated that the overall performance of the plant was considered to be ;
improving near the end of the SALP period, the areas of weak root cause !
evaluations, narrow corrective actions, and ineffective communications were' i mentioned as needing further improvement.
Toward the end of the SALP period, the Executive Director for Operations of l the NRC directed that a Diagnostic Evaluation Team (DET) conduct a broadly ;
structured assessment to assess the current status of ANO performance and to determine the root causes of any performance problems identified. The DET performed its assessment in August and September 1989. The hTC concluded that recent management changes and initiatives at ANO vere having a positive effect, but a number of areas needed increased management attention. These
- included: (1) identification and resolution of equipment problems with the
/T highest safety significance and potential impact on plant operation and on [
d operator performance, (2) resolution of the plant design basis and as-built configuration problems, (3) establishment of resource commitments and priorities to more expeditiously resolve long-standing maintenance, engineering, and materials control problems, (4) implementation of better ,
performance monitoring, self-assessment, and root cause analysis efforts, and (5) increased emphasis on teamwork, communications, and accountability. among the ANO organizstions. The SALP noted similar weaknesses, especially in the area of management involvement with plant activities. In this response, ANO has addressed each of the specific issues identified in the DET and SALP Reports and other issues identified by ANO in its self assessments to improve the operations and safety of the facility. Examples of increased ANO management. attention to the specific areas identified in the DET Report are 1 discussed below:
A. The' identification and resolution of equipment problems with the highest safety importance are being - addressed by ANO. Equipment deficiencies are identified through the Condition Reporting System and corrective actions are identified, prioritized, and implemented in a consistent manner. Additionally, ANO is in the process of clearly defining and prioritizing the remaining corrective maintenance and engineering backlog associated with safety related and non-safety related equipment ,
deficiencies. Prioritization of the corrective maintenance backlog and the engineering backlog is scheduled for completion this year. Reduc-tion of these backlogs is described in the Business Plan.
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p B. The resolution of plant design basis sad as-built configuration problems ,
is proceeding on a number of f ronts. Efforts to improve the Design
- j Configuration Documentation (DCD) Program began in late 1987 and resulted in the initiation of the DCD Action plan in 1988. The DC0 Program was established to collect and verify design basis information and make it accessible to potential users. It will further assist
- engineering personnel during their ongoing support of operations. In parallel, the Configuration Management (CM) Program is designed to provide the mechanism for maintaining the plant in accordance with the verified design basis obtained from the DCD Program. Finally, the self-initiated Safety System Functional Inspections activity was
( developed to provide an effective means for thorough reviews of plant systems and is designed to validate DCD Program results and plant configuration issues. Other design control activities which have been initiated are the Isometric Update Proj ect , the Electrical Drawing Upgrade Project, and the Structural Design Program. As an added benefit, involvement of our own engineering staff will develop valuable ;
site-specific knowledge of the design basis.
C.- In keeping with our commitment to expeditiously resolve long-standing maintenance, engineering, and material control problems, the integrated ANO Business Plan is being utilized to establish resource requirements and priorities for improvement in pla.ut conditions. For 1990, a staff-ing increase of 100 positions over the previous year was approved.
Recruiting efforts are ongoing to fill these approved positions. In addition, a comprehensive staffing study is being performed to assess the current ANO organization and resources. Following the staffing (V
g) study, a staffing plan will be developed to implement the specific steps necessary to achieve the recommended staffing levels. A staffing study will be used, in part, to identify areas in which contractor support should be replaced by permanent ANO staff.
1 D. Improvements in root cause analysis and self-assessment are being accomplished through increased resources, additional training, and -
greater management attention. Line management is responsible to ensure -
the performance of root cause analyses and assessments in their areas.
However, the programmatic responsibility for root cause analysis and assessment has been assigned to the Plant Assessment group, which is
, under the direction of the General Manager, Technical Support and Assessment. This allows a more effective focusing of resources and the development of a group which performs programmatic assessments, trending, and specifically assigned root cause analyses in a timely and consistent manner. Appropriate staffing will be provided to support assessment and root cause analysis efforts. These changes, along with cur efforts at ANO to improve the safety culture, will enable management-to establish better performance munitoring, self-assessment, and root cause determinations - activities that are fundamental to the safe and efficient' operation of the plants.
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E. R c;nt canagement and organicational changes at ANO, and additional '
P changes that will be made to implement the ANO Business Plan, emphasize L the importance being placed on imprwing teamwork, communication, i accountability, and cooperation. Furthermore, ANO is studying ways to
- / better utilize its work force. A result of this initiative will be a reduction in the number of long-term contractors working at ANO. This will help assure the adequacy of ANO employees for base workload, .
thereby increasing the plant knowledge of the employees and improving accountability and ovnership for work at ANO.
Further details of the actions being taken at ANO are discussed in the ANO Business Plan. The Business Plan was designed to be the controlling ,
document for assigning priorities for various self-identified actions, as well as for issues discussed in the SALP and DET reports.
1.2 ROOT CAUSE IDENTIFICATION AND CORRECTIVE ACTION
SUMMARY
ANO has evaluated the DET and SALP Reports and has developed the ANO Business Plan which is a comprehensive integrated program to significantly improve the operation and safety of ANO and to address the concerns raised in the DET and SALP evaluations. Many of the problems identified by the NRC in the DET and SALP Reports had also been identified by ANO in its comprehensive internal performance reviews following the Unit I refueling outage in late 1988. The findings and root causes in the NRC Reports are consistent with the con-clusions of AP&L's internal reviews. The DET/SALP findings have been grouped by ANO into five root cause areas which either precipitated or contributed to the identified weaknesses. .
1.2.1 Areas The five root cause areas are as follow:
A. Management Involvement and Leadership
- Insufficient expectations and performance standards
- Insufficient accountability / ownership
- Insufficient communication of policies, guidance, and performance expectations by management
- Insufficient definition of interdepartmental _ roles, in' erf aces, and responsibilities B. Safety Culture
- Insufficient safety consciousness
- Insufficient communications and responsiveness
- Insufficient professionalism and teamwork
- Acceptance of poor material condition of the plants C. Planning, Scheduling, and Resource Requirements
- Insufficient planning
- Insufficient scheduling and prioritization
- Insufficient resource allocation p
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- Insufficient depth of assessment and root cause analysis ,
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- Insufficient monitoring, follow-up, and trending Inadequate corrective action i
E. Program-Related Issues ;
- Insufficient engineering and technical support
- Insufficient training i
- Insufficient procedures !
- Ineffective program implementation '
ANO recently initiated several significant changes to improve plant .
safety and operational performance and to correct the underlying l root causes of existing weaknesses. Actions have been assigned and priorities established within the ANO Pusiness Plan. Activities s 4 will be monitored to assure successful implementation.
1.2.2 Actions Some of the major actions initiated or planned to address these a root cause areas are summarized as follows:
A. Management Involvement and Leadership ANO has taken ection to correct the management concerns noted ;
by the NRC and by our own self-assessments. For example,
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\_J corporate management has been strengthened by 1) the addition of a new Executive Vice President and Chief Nuclear '
Officer, and a new Senior Vice President, Nuclear to AP&L management with direct responsibility for ANO operations, thus providing the benefits of increased senior management atten-tion on plant operations, safety of operations, and issues requiring prompt attention; 2) the assignment of overall responsibility for ANO operations to the Vice President, Nuclear, who is located full time at the site; 3) the restructuring of the ANO monthly Management Review Meetings to !
more ef fectively review plant status, performance improvetent ,
progress, and completion of action items; and 4) the scheduled
- relocation of the remaining nuclear personnel from the Little Rock corporate office to the site to. better support plant operation.
The organization has been futther strengthened through the recruiting of management personnel with outside nuclear industry experience, assignment of Maintenance and System Engineers to Nuclear Operations, and the unitization of ,
existing plant functions.
The management team is working toward the common goals of plant safety and efficiency of operation. Management is communicating expectations through daily plant status n meetings and corsnunications . The activities required to address the DET and SALP findings, along with their V' schedules for completion, have been factored into the ANO Business Plan, n . _ .
B. Safety Culture l
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( ) A major objective of our management realignment was to change l
the organizational culture to improve operations and safety. I This is being achieved through several means including ,
increased corporate and site management involvement, more i conservative operability determinations, and more open com-munication of goals and safety policies to all people in the ;
AN0 organization. Additional management attention has been '
focused on reportability determinations as well as increased emphasis on improved communications with the NRC and inter-departmental ccc.snunication and teamwork.
The recent organizational realignment of maintenance per-sonnel and planning and scheduling personnel into unit-specific groups will enhance the control of work activities.
Also, this realignment will help by establishing a sense of ownership in these groups for the material condition of each unit.
Examples of efforts to improve safety culture include 'the Design Lonfiguration Documentation Program; improved Condition Reporting, improved Licensee Event Report efforts, defined policies for open and candid communication with NRC, and the policy of stressing safety over legal interpretations for equipment operability determinations. Further programs have been put in place to improve root cause analysis, assessment, o and performance monitoring. These activitieh collectively
(") lay the groundwork for sustaining improvements in the safety culture at ANO.
C. planning, Scheduling, and Resource Requirements The functions and resources of planning and scheduling have been moved under the Plant Managers. Workload management and planning and scheduling have received increased management attention since the organizational realignment.
In addition to these changes, system engineers, maintenance engineers, and technicians are being assigned to the ,
individual plants under the Plant Managers as part of plant unitization. Monthly Management Review Meetings and self- t assessments will monitor this functional area, review resource allocations, and periodically assess maintenance and opera-
, tional activities with regard to the effective prioritization and scheduling of in-plant work.
Negotiations have recently been completed on an addendum to ,
the labor agreement that facilitates the completion of unitization. Unitization of craft and technical support resources enhances the ability to establish accountability and ownership, particularly in the area of unit material conditions.
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D. Assessment. Trending, and Root Cauo Analysis
, Improvements in root cause analysis and self-assessment are
(, being accomplished through the better utilization of
) personnel, training, and greater management attention.
Assessments and root cause analyses are the responsibility of the line managers and individuals in each department. ,
However, '
the programmatic responsibility for root cause analysis and assessment has been concentrated in one department under the General Manager, Technical Support and Assessment.
- This focuses our efforts and develops a group of individuals who are consistently able to perform assessments and specific ,
root cause analyses in an accurate and timely manner. These ;
changes will enable us to better perform . the monitoring, self-assessment, and root cause determinations that are ;
fundamental to safe and efficient cperation of the plants.
E. program Related Issues t
Ineffective implementation of existing programs resulted from t a lack of management involvement and led to many of the weaknesses identified by the NRC. The ANO managers of organizations providing programmatic support now fully recognize their respective responsibilities and accounta-bilities for corrective actions. They fully support the programs and will instill the necessary ownership within (g
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their organizations to assure successful implementation. '
ANO is improving its programs in many areas including ,
preventive and corrective maintenance, ISI/IST, housekeeping, hot particle identification and removal, design basis upgrade, configuration management, MOV's, spare parts, commercial grade dedication, planning and scheduling, independent verification, conduct of operations, surveillance testing and tracking, operability determination, quality control involvement, assessment and root cause analyses on significant conditions, and trending and monitoring of plant performance.
Maintenance Engineering is being unitized in the areas of maintenance and operations. Engineering and technical support problems and backlogs are. being addressed by the prioritiza-tion of actions requiring an engineering response and the relocation of design engineering to the site. Systems in the plants will receive improved engineering involvement with the implementation of the System Engineering Program which is discussed in the Nuclear Operations and Design and F.ngineering portion of the response.
The ANO Business Plan includes initiatives and directives to address each action item referred to above.
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1.3 METHODOLOGY
, 3 This response describes the actions that have been taken and that are planned
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to be taken to address the findings of the two NRC assessments and our own !
self-assessment. Section 2 of this response provides a summary description of the action plans to address the specific findings and conclusions delineated in Section 2 of the DET Report. Actions to resolve those items contained in Section 3 of the DET will be tracked, and/or implemented separately :nd are' not included in this response. Section 3 of our response provides AN0's summary of the actions needed to address those NRC SALP recommendations to improve performance. This section discusses only those topics that are not discussed with the related DET issue. Appendix C of this response is the ANO Business Plan, which contains a description of the specific issues, details of the action plans to resolve the issue, and a priority assigned to the issue based on safety importance and an implementation schedule for the actions. Because the Business Plar. is a comprehensive plan for ANO improvement, it addresses not only issues identified by the NRC in the DET and SALP reports, but also broader issues identified in ANO self-assessments as areas needing improvements or special emphasis.
The SALP issues and each of the LET Section 2.0 issues were divided lato b- areas of responsibility. When this was completed, each issue requiring a response was distributed to the appropriate department. Each department then reviewed the issue, assigned a priority using established criteria (Attachment 1), formulated an action plan and implementation schedule, and discussed those actions with other departments directly associated with its implementation. This information became part of the ANG Business Plan which ,
'.'t in turn was used to develop the response to the SALP and DET issues. The (d Business Plan not only identifies the actions but also incledes schedules ,
for implementation and completion. Also, a matrix (Appendix A) was developed to provide a cross-reference between the SALP and DET Reports and the associated ANO Businers Plan section.
After the Business Plan items were prepared, the Vice President, Nuclear, the Director of Nuclear Operations and the General Managers met to discuss the details of the ANO Business Plan, resource requirements, interfaces between the different departments, assign priorities to the ANO actions, and the response to the SALP and DET issues. This integrated ANO Business Plan is the primary reference document for the DET and SALP response. ANO will conduct periodic meetings with the NRC to discuss the status and progress of AN0's performance consistent with the ANO Business Plan.
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! I 1.4 ANO B11SINESS PIAN IMPLEMENTATION -
Each Director or General Manager, as the case may be, is responsible for the 1
(," ,[ implementation of the corrective actions for his respective areas in the J ANO Business Plan. The responsibility for the administrative aspects of the l program have been assigned to the General Manager, Nuclear Support who reports directly to the Vice President, Nuclear. He coordinated the development of the ANO Business Plan and will continue to maintain it. ANO ,
management will monitor this Plan to ensure actions are effective and ;
implemented in a timely manner. The Plan addresses long-tern performance '
objectives of the station, self-identified remedial actions, and actions responsive to the SALP and DET findings and conclusions.
1.5 MANAGEMENT CONTROLS AND ASSESSMENT Several measures have been and will be taken to insure a quality and effective implementation of actions described in the ANO Business Plan.
Some.of the more significant management controls are as follows:
A. A senior ANO manager has been assigned overall responsibility for Plan coordination, tracking, and maintenance; i.e., the Ceneral Manager, Nuclear Support.
B. The General Manager, Nuclear Support, reports directly to the Vice President, Nuclear, thus providing a close senior management working relationship for the monitoring and management oversight of the Plan's activities. This reporting relationship is part of the organizational structure already in place.
C. The Plan will be implemented and controlled in accordance with a
, definitive, approved administrative procedure. The procedure will specify, for example, steps for adding, deleting, or revising action plans and schedules. The procedure also will provide requirements for documenting completion of action items, as well as provisions for closure review.
D. Periodic management reports will be provided to responsible managers and senior management on the status of assignad items.
E. Plan status, concerns, and effectiveness will be discussed at an appropriate frequency in review meetings held with senior and executive management.
F. Implementation of the Business Plan per the administrative procedure will be audited periodically by ANO Quality Assurance.
G. Assessments of station activities will be conducted as necessary, 411 confirm that the actions taken are correcting the root cause and that the performance expectations are met.
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ATTAC}DfENT 1
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3 PRIORITIES
.) The specific ANO Business Plan activities have been qualitatively prioritized. The prioritization can be characterized as follows:
Priority - High Those items considered important to assure continued safe operation of the plant, to - reach key milestones within the ANO Business Plan, or to correct significant
.defielencies.
These activities will receive a high level of management attention and tracking of performance to ensure timely completion. Changes to the scheduled completion date or content will require the approval of the Senior Vice President, Nuclear.
Priority - Medium Those items which enhance safety by improving the performance of the operations, maintenance, or engineering functions. These include improvements directly related to plant operation.
Tracking will be employed to ensure timely completion. Changes in content or schedule requires the approval of the Vice President, Nuclear.
Priority - Il>w
- (')Those items having little or no safety impact but which will provide long-term V benefits in the areas of plant support. These include changes to programs that are ceceptable now but that could use improvement.
ANO will track and monitor the scheduled date. Changes to content or schedule require the approval of the appropriate Director or General Manager.
The prioritization of the action items will be reviewed periodically to ensure that supporting items are not holding back completion of high priority tasks. As new items are added to the ANO Business Plan, they will be prioritized. Generally, scheduling cf the ANO Business Plan items will be consistent with the item's prioritization with the exception that short-term medium and low priority items may be completed on an cxpedited schedule if they do not interfere with the completion of high priority items es scheduled.
~ NRC will be briefed periodically on the status of the ANO Business Plan activities and will be informed of any changes to content, priority, or schedule, along with the basis for the change.
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SECTION II ,
RESPONSE TO DIAGNOSTIC EVALUATION ,
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- 41 g j RESPONSES TO INDIVIDUAL FINDINGS
'g 'y The purpose 'of this section is to provide our response _ to the DET (Section 2) findings
' L/f-and-to facilitate--identification of areas within the AND Business Plan that correspond t3 these findings. .The ANO Business Plan contains perforstance indicators which will' be.
2 monitored to ensure that the respective actions are . producing .the desired results.
F- 'The. format of our response is as; follows:
I :0- Statement of the issue (and rorresponding DET section number) e
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.0 Root Cause with-(appropriate l reference to Attachment 1) o O ANO Response
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2.1.1 - MANAGEMENT AND ORGANIZATION g INTRODUCTION The DET recognized improvements resulting from our recent management changes and f initiatives, but also noted several areas needing increased management attention.
We are aggressively pursuing improvements in these areas.
The management and organization of ANO has changed substantially in the past year.
Effective January 1, 1990, Villiam cavanaugh, III was elected to the Board of Directors and Executive Vice President and Chief Nuclear Officer of Arkansas Power
& Light Company (AP&L). Concurrently, Donald C. Hintz became Senior Vice President, Nuclear - at AP&L. These senior management changes bring to focus the attention of the Middle South Electric System's most experienced nuclear execu-tives on the improvement of ANO operations. These senior management changes at AP&L are an interim arrangement pending the consolidation of nuclear operations in the System under Entergy Operations, Inc. (EOI). However, Mr. Cavanaugh and Mr. Hintz, as well as the other people responsible for ANO, will become employees of E01 af ter the consolidation and will continue to be directly responsible for ANO operations. Therefore, the increased senior management attention that is being focused on ANO will not be diminished as a result of the consolidation.
These senior management changes are an interim measure toward providing the bene-fits of senior management attention on plant operation and focusing attention of the System's most experienced nuclear executives on the improvement of ANO opera-tion until finalization of the E0I consolidation.
In order to strengthen corporate influence on site, AP&L has assigned the respon-sibility for overall site management to a corporate officer. The Vice President,
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Nuclear is the Senior Nuclear Executive with overall responsibility for the site and for the safe operation of the nuclear progran.. Along with the Vice President, Nuclear, already located on site, the remaining nuclear staff is being moved from the corporate office to the site this year, thus centralizing our nuclear resources. The ANO monthly Management Review Meetings have been restructured to include the Executive Vice President and Chief Nuclear Officer and the Senior Vice President, Nuclear. We believe that these changes have greatly enhanced corporate involvement at ANO.
Site management has been strengthened through these corporate changes as well as through the recruiting of outside management personnel to fill selected positions within the new site management team. This team is working aggressively to enhance ANO operational efficiency.
Another key organizational change made recently was to move the planning and scheduling functions from the Work Control Center to the Plant Managers.
This will facilitate more efficient planning, scheduling, and completion of work in the plants.
In addition to the realignment of planning and scheduling, a major focus of the organizational realignment (Appendix B) was the unitization of pertinent plant support functions. Chief among these were System Engineering and Maintenance.
Unitization is designed to bring about more efficient utilization of resources, development of greater expertise, and improved communications among the various departments.
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3 MANAGEMENT AND ORGANIZATION
( j DET ITEM 2.1.1.1 - STATEMENT OF ISSUE There had been weak corj state level leadership, oversight and involvement in site
- activities and in some cases corporate guidance and directives did not always L reach the supervisory and working level staff members. These weaknesses coupled with the management style of senior site management contributed to plant perfor-mance problems. Following the reorganization, the Vice President, Nuclear had become more involved in the operation of ANO and the various improvement programs including the unitization of plant functions, the recruitment of new managers, the development of station goals and objectives and the development of the Composite Action Plan following the Unit 1 1R8 outage. (Section 3.1.3)
ANO ROOT CAUSE Management Involvement and Leadership (I)
ANO RESPONSE TO DET ITEM 2.1.1.1 The reorganization which began in 1989 resulted in a major chif t in corporate focus to the ANO station. The Vice President, Nuclear is located on site. Other senior managers who were located in Little Rock have established offices on site
-m in order to facilitate enhanced performance of their management responsibilities.
It is AN0's goal to have the Little Rock nuclear staff perma.nently located on site t
i) by the end of 1990. This shift has enabled these managers to become much more involved in the daily operation of ANO and established corporate leadership on ,
site.
In addition to these changes, two new senior management positions have been created - Executive Vice President and Chief Nuclear Officer, and a Senior Vice President, Nuclear. The Executive Vice President and Chief Nuclear Officer ,
is also a member of AP&L's Board of Directors. The Executive Vice President and Chief Nuclear officer and the Senior Vice President. Nuclear have extensive nuclear backgrounds, understand the technical and financial requirements of nuclear power plants and are in posit ions to provide additional corporate direction and leadership support to the station. Monthly Management Review Meetings have been structured to include these two individuals to facilitate their cognizance of activities at the station.
The establishment of a corporate focus on site, the restructured Monthly Management Review Meetings, and the iner ned emphasis within the corporate organization on nuclear experience, are designed to prevent the decoupling between corporate and site that has occurred in the past. In addition, appropriate corporate guidance and directives will continue to be communicated to the working levels of staff members.
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the ANO Business Plan Project / Activity: .
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Top site; management had placed a limited emphasis on.high individual and organiza-tiona) standards of : performance. . It had relied. extensively on programs and-admir n>stive_ controls to accomplish its objectives and did not ensure the needed
'leve. t. "~ direct personnel communication required for success. In early - 1989, l folloung a number of- management changes, there were improveme.'ts in the quality ;
and. extent'of; management leadership and direction.. (Section 3.1.3)
ANO ROOT CAUSE
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- AN0' RESPONSE T6 DET JTEM 2.1.1.2 The management restructuring which began - in' 1989 utilized personnel, not only
, from AP&L but from other utilities as well, who . provided a wide variety of j . leadership. and' operations experience to the ANO organization. The new management team la placing. a great deal of emphasis on defining standards of performance and manaeement expectations and is communicating this to ANO personnel. Thir, is-be .ir accomplished through a variety of methods including the daily plant status #
meeting and improved daily communications.
V The management team currently in place will maintain high standards of organiza-tional performance, as,well as individual performance, thus promoting the benefits of improved, safe plant operations. The restructured Management Review Neetings
- . 'will focus on the ANO Business Plan performance measurements and implementation -
schedules as well as plant status. This allows senior corporate and site >
management to monitor plant performance and make changes where necessary.
!! Reference the AND Business Plan Project / Activity:
H.7 Supervisory Training K.3 Communications K.5 Organizational Culture i
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< i' DET ITEM 2.1.1.3 STATEMENT OF' ISSUE wi x o The licensing organization had heavily influenced operational ~ decisions whichL emphasized legalistic positions -that supported uninterrupted plant operation and minimized._the considerationc of. regulatory concerns. Management- was making "
,, progress in improving communications and cooperation with the NRC, for example, as 3
'in their efforts to emphasize safety over the regulatory aspects of equipment operability determinations. (Section 3.1.4) i ANO ROOT CAUSE- .
Management Involvement and Leadership (I)
Safety Culture (II)-
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ANO RESPONSE TO DET ITEM 2.1.1.3 In 1989, a new Licensing Manager and a new Licensing Supervisor from outside the
' Company were hired to fill vacant positions. This outside experience has resulted in the infusion of new ideas and attitudes regarding nuclear safety, compliance with' regulations, and communication with the NRC. AN0's philosophy toward ,
communicating. with the NRC is always to provide honest and accurate information '
j% and to be open in ' our ' discussions. Policies have been est'ablished providing -
G- mana'gement expectations concerning these communication goals. Training is planned-to ensure the . policies are . communicated to various levels of the organization.
Progress-in this area has been noted by the NRC. ,
,1 Periodic phone- calls with the NRC providing plant and licensing isrue status- have 3 been implemented. Frequent calls and/or meetings are conducted as the need arises. These calls provide both the NRC and ANO with an opportunity to discuss issues related to the station. ANO will continue to emphasize safety and con-
. servative. . decision-making over the strictly legal, regulatory compliance aspects "
in equipment operability determinations, as well as in other decision-making processes. I The ANO Licensing organization will continue to be the focal point for all discussions between the NRC and ANO. Licensing will ensure that the proper. level of ANO Management and technical expertise are present when interfacing with ,the NRC. . We intend to identify - plant events with potential regulatory interest as soon as possible and to contact the NRC with details and any applicable- plans for resolution. - Policies for standards of communication for licensing personnel,- as well as for ANO personnel, are being developed, and training on how to effectively communicate with the NRC will be conducted. Licensing, as well as other plant
' organizations, will take the conservative approach regarding operability
^ determinations and~overall plant safety.
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These' include: procedures - on , environmental impact and Technical Specification interpretations.- To improve support for NRC inspections,- Licensing. plans . to develop: closure packages for NRC. items and increase support for -inspections. ; A. :
proj ect is underway - to . develop a process by which ANO will conduct criticalL {
$ self-assessments-of the' areas' identified in the SALP Report.- .
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Reference the AN0' Business Plan Project / Activity: j y ,
, F .1 - Improve Image / Credibility .
~F.3 Improve Quality of Technical Specification Program ,'
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' ~ 1 DET ITEM 2.1.1.4 - STATEMENT OF ISSUE l ,
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.. Organizational culture - was in; transition. Management had begun to grasp the
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nature and extent of the cultural issues and influences and had taken steps to address _their- adverse impact ton - performance. However, there was still evidence 1
that plant staff and managers accepted deficient conditions, including equipment d aut-of-service, rather than pursuing aggressive and effective corrective actions. ,
(Section 3.1.1)
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{ NO R M CAUSE.
a' 4 Safety Culture (II) l
.ANORESPONSbTODETITEM2.1.1.4 ~i
-f Organizational culture is still in transition but improvements are already being N 'seen. Management.is stressing the policies of doing it right the first time and of open communication and cooperation at the working levels while making efforts toward leading by example. We believe. that these policies are 'the solution to changing the. organizational culture to one that is more safety conscious,-
responsive, and effective.
$(^h We are developing a = plan for self-assessments (similar to the SALP) which will V'
enable -us to monitor safety culture progress- throughout the organization. The high priority items in the ANO Business Plan include those activities designed to' improve the safety culture at ANO. ,
8 Safety-related equipment deficiencies are identified through the Condition r Reporting System and art being corrected. Additionally, ANO is in the process of prioritizing and clearly defining the remaining corrective maintenance backlog and' the engineering backlog associated with safety-related and non"afety-related equipment deficiencies. Priorities will be assigned according to' importance to 7 safety.
- In . addition, . a high level of management attention was given ~ to upgrade the material condition of the units in recent scheduled and forced outages ~ . This effectively communicated to ANO personnel that management was willing to
- address problems and pursue resolutions, k Raference the AND Business Plan Project / Activity:
C.10 Professionalism-F .1 - Improve Image / Creditability K.5 Organizational Culture !
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The restructured organization and management chan*es g which consolidated engineer-
=ing functions, unitized ~ plant activities and hired / rotated middle and upper managers were substantially complete and appeared responsive to past problems.
However, staffing issues and continuing communication / coordination problems detracted from the effectiveness of the changes. In addition, plant-wide' policies, guidance . and expectations were still not well defined or controlled.. ' (Sections-3.1.2 and 3.3.3) t ANO ROOT CAUSE
^ Management Involvement and Leadership-(1)
ANO RESPONSE TO DET ITEM 2.1.1.5 The management realignment is essentially complete and unitiza' tion efforts are on schedule. These changes have helped to clarify rer.ponsibilities and alleviate previous coordination problems among work groups. In addition, studies are currently being performed to ensure that the workloads can be accomplished e effectively. One study is designed to review areas of the organization to PT determine appropriate staffing levels. In parallel with this effort, a contractor -
d utilization study.is being performed to determine how contractor support should be '
utilized by the ANO organization. Management will use the results of these studies to. ensure that- the organization properly uses its rer.ources to safely operate ANO.
Development of station goals and obj ectives will follow from the development of - the ANO Business Plan. The management leadership is - in place to effec-tively communicate these goals and ~ associated actions throughout the ANO organization. To further assure the message is being received, daily plant status =
- meetings and Management Review Meetings are scheduled to review plant status, ANO Business Plan status, and management concerns. "
In addition, 'the Nuclear Operations Directives (NODS) promote' and provide guidance for the Nuclear Operations Department to support consistency in operating, maintenance, and outage practices. The management philosophy contained- in
- the NODS . promotes an organizational culture that fosters excellence in safe and efficient' production of electricity through utilization of good practices from -~ lessons learned from both internal and external sources. Appropriate corporate guidance and directives will continue to be communicated to the working levels of staff members, p
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L' - DFT I'ITH 2.1.1.5 (CONT'D) ,
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/ ! Reference the ANO Busiiess Plan Project / Activity:
4 G'.3 . Recruiting and Ret'ention '
. K.2 Administrative Controls Standards '
K.3. Communications--
K.4 Contractor Utilization Study 7 K.6 Staffing Plan K'. 7 Managee<.nt Processes-
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s:DET ITEM 2.1.1.6 STATEMENT OF ISSUE 9NJ -
While some segments of the. staff remained skeptical that the involvement and',
- i. responsiveness of-- the new management team would continue beyond the short term, !
many among the staf f were - optimistic and positive about the.new leadership and ?
generally supportive of their initiatives. ,(Section 3.1.3) s 5
.AN0' ROOT CAUSE Management' Involvement and Leadership (I) i t
<p ANO RESPONSE TO DET ITEM 2.1.1.6
".. The skepticism of,- some staff members rege.rding sustained new management . initia-tives is recognized. The ANO Business Plan was explicitly developed to improve
-overall staff and plant performance. The success of this plan and the achievement
- of its objectives are critical goals for ANO. Therefore, ANO management is fully committed to this plan. This will provide the necessary involvement,' oversight,
' assistance ' in problem solving, and resources to sustain the Plan's momentum and achieve its objectives. It is recognized that this involves a long-term effort and' resource commitment ~to ensure its effectiveness and success. ,
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Reference the ANO Business Plan Project / Activity:
v .'i 9 C.10sProfessionalism K.3 Communications K.5 Organizational Culture 7 . .
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. A comprehensive ' list had. not been developed of those equipment problems with the highest safety-significant and potential impact on plaat operation and_on operator j performance. Therefore, . an action plan with established priorities- and resource conmitments; to resolve thosp problems edid not exist. This contributed to a reactive approach to problem solving "which was further exacerbated by _the _large ,
7 backlog of work,_ competing priorities of major improvement programs, and emergent equipment problems. Certain issues involving questions of equipment operability had not been recognized or adequately addressed. (Section 3.1.4) k ANO ROOT CAUSE r
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Safety Culture (II)^
Planning, Scheduling, and Resource Requirements (III) '
.ANO RESPONSE TO DET ITEM 2.1.1.7-The identification and resolution of equipment problems with the highest safety significance is underway. Safety-related equipment deficiencies are identified through the Condition Reporting System and are being corrected. Additionally, ,
ANO -is in the process .of prioritizing and clearly _ defining the~ remaining corrective maintenance backlog and the engineering backlog associated with safety-f3 related and nonsafety-related equipment deficiencies. Priorities will be g assigned according to importance to safety. An Engineering Backlog Reduction .
Plan; is being developed to establish priorities and process the backlog. . This plan will be developed _ with implementation beginning in 1990. The maintenance backlog is being analyzed and segregated into general categories to enhance management's ability to prioritize and focus on the safety-significant maintenance backlog.
Engineering management provides direct input to developing the engineering 18-month plan. This plan est.ablishes priorities for those design-related -_isstes with the highest safety-significance and potential impact on plant operation and operator performance. A report is generated daily identifying principal equipment ,
!! which is out-of-service and corrective maintenance items. Jobs on this report are reviewed - ' daily by ANO management. Responsible individuals are designated and - <
dates are established by which corrective actions are to be completed. The use of I'
_these scheduling and prioritization methods will assure that priorities are established and resources committed for both the day-to-day corrective maintenance L items and the long-term equipment problems requiring engineering support.
. Completion of these activities will allow ANO to become more proactive toward re-solving equipment problems and will result in a safer, better operating facility.
Reference the ANO Business Plan Project / Activity:
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C.4 Engineered Maintenance i C.5 Engineered Operations s C.7 Maintenance Optimizatioa O. C.9 Trending V C.12.a Backlog Reduction-Corrective Maintenance g .D.1 Engineering Backlog Elimination l
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\/ ~ The Work Control' Center (WCC) had been a major obstacle to the' ef fective.
prioritization and scheduling of inplant work. Competing -priorities among .
< a operations, maintenance and the WCC management were not well managed. Since the reorganization, planning and' scheduling were assigned to the manager ;having the
-responsibility for. iglementation of maintenance activities which resulted in
' improved communications and coordination of work priorities between operations,- ,
maintenance and the planning and scheduling groups. (Section 3.1.5)
ANO ROOT CAUSE. .
c Management Involvement and Leadership (I)
Planning Scheduling and Resource Requirements (III)
"ANO RESPONSE TO DET ITEM 2.1.1.8 The functions, responsibilities, and resources .'of Planning . and Scheduling have been moved from the Work Control Center (WCC) and assigned to the Plant Managers.
Work ~1oad management and planning and scheduling receive increased management '
attention since the organizational realignment. l r 73 - In addition ;to these changes, plant unitization will result in the assignment of
']. System Engineers, Maintenance Engineers, Planning and Scheduling personnel, and I&C- technicians- to' the individual unit' Plant Managers. Monthly Management Review Meetings, daily plant status meetings, and continuing self-assessment _ will ensure that. this functional area. is performing . as expected, that appropriate resources, are. being utilized effectively, and that prudent . maintenance and
- operational decisions are being made with regard to the effective prioritization '
and scheduling of work.'
Reference the ANO Business Plan Project / Activity:
C.5 Engineered Operations 3 C.7 Maintenance Optimization
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Management. initiatives .and improvement prograr.:s existed to address 'most of the significant issues ' at ANO, but the successful implementation of these programs
' often met with delays as - a result of resource issues and/or a lack of management emphasis. (Section 3.1.6) k -
4 ANO ROOT,CAUSE Management-Involvement and Leadership-(I)
Planning, Scheduling, and Resource Re<iuirements (III) 3 l
ANO RESPONSE TO DET ITEM 2.1.1.9
! Management initiatives and improvement programs are receiving udded emphasis with i the: development of-the.ANO Business Plan. Performance measurements'and implemen-tation schedules are :being developed and will be contained in the ANO Business q Plan. These measurements and schedules will be effectively communicated to ANO. -l personnel. Recruiting efforts are ongoing to' fill approved but vacant positions. + i A' staffingc study is being performed . to assess the current ANO resources. Upon
/l j . completion : of this study, efficiencies in the utilization of manpower and addi- i
.tional resource - requirements will be addressed to ensure resources and staffing D are ' adequate. In addition, the nu:nber of 'long-term contractort, working at ANO V '
will . be - reduced. - The result of these staffing initiatives will assure adequacy. I
' of : resources for base workload, and will improve accountability and1 ownership- ~!
for work.at ANO. ~ Appropriate levels of management ~ are now involved in- review of j site ' activities to ensure that sufficient funding is allocated to mect 'these .
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.. q Reference the ANO Business Plan Project / Activity: J
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D.2 Engineering Resource Plan 6.r G.3 Recruiting & Retention K.1 -Financial Management Process _
j K.3 Communications ~l K .'4 Contractor Utilization Study
~K.6 Staffing Plan
,K.7~ Management Processes 1
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.'DETL ITEM 2.1.1.10 - ST TEMENT OF ISSUE v
Assessments by outside' organizations, had not been sufficiently critical of AN0's performance. .The licensee's weak self-assessment and root cause analysis '
capabilitiesi combined with these other assessments contributed to a sense of ,
. complacency on the part of the licensee regarding its overall performance includ-ing the adequacy of corrective actions. (Sections 3.1.4) +
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ANO ROOT'CAUSE
> Assessment,. Trending, and Root Cause Analysis Deficiencies (IV) b ANO RESPONSE TO DET ITEM 2.1.1.10 -
- ANO realides that proper and thorough root cause analysis is vitally important.
- Improvements in, root' cause analysis and plant assessment are being accomplished through. appropriate staffing, training and management attention. The
. programmatic responsibility for root cause analysis and plant assessment has been Y assigned to the General Manager, Technical Support .and. Assessment. . -The responsibility for -the root cause and, corrective action plan of individual 4 conditions rests with the responsible ANO supervisor. The dedicated personnel within plant assessment condact independent root cause ~ determinations- and q evaluate corrective . actions .for significant conditions to ensure consistency and Q to ' identify programmatic issues from the Condition Reports. These changes will enable us to bett >r -perform the monitoring, . self-assessment, and root cause *
' determinations that are fundamental to the safe, efficient operation of the plants.
SELF-ASSESSMMT.
-The recent organizational realignment created a dedicated organization to conduct performance , based self-assessments above and beyond compliance. The
. plant assessment group will be staffed with personnel who have expertise in R the areas of Maintenance, ' Operations ' and Technical Support in addition to Chemistry, Health Physics and Radwaste.
This ~ dedicated group will be responsible for . routine assessments of station activities against management's ; expectations and industry standards. ANO
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management . will use these assessments to . determine the performance: of the
- station and personnel compared to performance expectations. Assessment L information will be used to improve performance and correct the root cause f of performance deficiencies. In addition, assessments conducted by outside p organizations will be reviewed and compared with our own assessments and performance indicators to improve AN0's assessment process.
Outside expertise has been obtained to assist in the development and implementation of the enhanced self-assessment process. This individual l
>! brings with him experience in events analysis, human performance evaluations, performance assessments and broad industry experience.
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( i DET ITEM 2.1.1.10 (CONT'D)
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ROOT CAUSE' ANALYSIS
-Improvements in the condu' ct of root causes are being made through the training of .
additional personnel in root cause methodology and implementation. ,
Root. cause training will continue to be provided in subsequent years to provide plant personnel with the tools to effectively determine root causes. Additional personnel were approved in.1990 to supplement the group which administers the Condition Reporting System (CRS). These duties include a review of correc-Live actions and root cause determinations. In addition,' independent root cause determinations are conducted by this group for significant conditions.
Procedure revisions are being made to reduce the administrative burden on line -
management of = the CRS process to allow plant management to more appropriately focus their attention on - the root cause and corrective actions to prevent recurrence of conditions. The realignment and unitization of support under the Plant Managers, the prioritization of plant equipment problems,- and the coordination of engineering activities with regard to safety significance will improve the timeliness of carrective actions. These activities are discussed further in response' to DET ITEMS 2.1.3.3, 2.1.2.7 and 2.1.5.5. Measurements of effectiveness will be used to monitor and assess the timeliness of Condition Report Corrective Actions, INDUSTRY AND IN-HOUSE EVENT REVIEWS
. /n3 The assessment group is involved in the review of in-house and industry-experiences. This group will be staffed as a part of the realignment with dedicated personnel who are free of the schedule and priority constraints of their duties (e.g., Shift Technical Advisors).
The issues identified through this group that are applicable to ANO and pose a potential safety question will be addressed through the CRS process to assure appropriate management attention.
Additionally, routine ' reviews of Nuclear Plant Reliability Data System (NPRDS)
Component Failure' Analysis Reports (CFAR) will be conducted to identify other recurring equipment problems.
Reference the ANO Business Plan Project / Activity:
B.1 Improve Root Cause Determination B.2 Improve Corrective Action Program B.3 Define Role and Scope Assessment B.5 Performance Monitoring (External / Internal Trending)
C.9 Trending D.5.1 Enr,fneering Improvement Programs - Corrective Action Program F.5 Liernsee Event Report (LER) and"10CFR21 Improvement Program v
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OPERATIONS AND TRAINING
-(, -DET ITEH 4 2.1.2.1 n STATEMENT OF ISSUE The experience level and number of licensed staff - for both units was con-q s sidered a strength and consisted of six crews on ' an 8-hour shift rotation, which reduced . operator overtime.. -The shift rotation allowed for one standby shift that was available most weekdays to assist in administrative and support functions. (Section 3~2.2)-
ANO R00T'CAUSE e ..
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ANO RESPONSE TO DET ITEM 2.1.2.1 + .
ANO management is. committed to maintaining. the high quality of the operating staff. As stated in the DET, the experience level and numbertof licensed staff f t,r both units was characterized as a strength; therefore, this', item is considered closed.
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- room -activities were conducted in a professional ranner. Annunciator.
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., alarms were properly announced and acknowledged. Shift relief and turnover vere performed in a thorough and disciplined manner. " Red zones were established for critical control' room areas s.nd were effective . in climiting .
personnel a'ccess and distractions to the control board operators. (Section
.3.2.3) , !
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ANO ROOT CAUSE
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'None-ANO RESPONSE TO DET ITEM 2.1.2.2 ,
' Professionalism in 1 operations will continue to be emphasized at ANO. As stated in the: DET,. control room activities were conducted in a professional manner with several examples cited to support these- observations. This W
item is considered closed.
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3 OPERATIONS AND TRAINING E T ITEM 2.1.2.3 ~ STATEMENT OF ISSUE J
{'v(J' Weaknesses in operability determinations were identified which were attributed to a general lack of knowledge by operations personnel and demonstrated a neect for training in this area. In addition, administrative, guidance provided by management to. operators for making' operability determinations was weak and in some cases appeared nonconservative. Licensing had maintained an informal handbook of previous determinations which was available for use, but these had j not -been reviewed or approved by engineering or station management. (Section 3.2.3)
ANO ROOT CAUSE Safety Culture (II)
Program Relatsd Issues (V)
ANO RESPONSE TO DET ITEM 2.1.2.3 Training. for operators in operability determinations is being provided during regularly scheduled sessions on the control' room simulators. During , this training, the. Shift Supervisors /SR0s are given a scenario in which an operability determination must be made, and the basis for the determination is discussed. In 1989, sessions were conducted to highlight and discuss n- past operability concerns on safety systems.
O The Plant Managers for both units have conducted discussions with their Shift Supervisors and crews stressing the. importance of conservatism in operability determinations. Also covered during the discussions were lessons learned from
- previous . examples of weak .' operability determinations involving items not
'> directly addressed in the Technical Specifications. The' discussions have already resulted in making conservative operability determinations. .
The procedure for operability determinations has been revised to improve the' guidance provided to operators, and Operations personnel have been scheduled for training on the revised procedure.
The Operations Department is' responsible for operability determinations, which will be properly documented in accordance with the appropriate procedures.
-The informal use of an uncontrolled handbook is no longer an accepted prac-tice. The Shift Technical Advisor, an SRO-trained engineer, is currently available to assist the shift supervisor as necessary in detennining opera-bility. Once the System Engineering Program is fully ' implemented, further ,
assistance will be readily available utilizing the System Engineer's exper- :
tise concerning the operability requirements of his/her assigned systems.
Reference the ANO Business Plan Project / Activity:
C.5 Engineered Operations C.10 Professionalism Q
V C.11.a H.1 Procedure Upgrade-Operations Operations Training Upgrade M
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j OPERATIONS AND TRAINING ,
DET ITEM 2.1.2.41- STATEMLWT 0F ' ISSUE-p3 ,
'f_ The' shi f t supervisors (SSs) demonstrated adequate leadership during control j room L and plant operations, shift turnover meetings, . and during ' simula tor '
exercises. However, ' during the day shift, the SS spent approximately 75 ,
percent of his time processing job orders, which detracted from his primary )
responsibility to supervise and monitor plant operations. (Section 3.2.3) ,
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'ANO ROOT CAUSE !
e Planning, Scheduling, and Resource Requirements (III)
ANO RESPONSE TO DET ITEM 2.1.2.4 As part of the organizati~onal. realignment of the maintenance and planning and L scheduling organizations, maintenance activities will be spread over two ,
shifts, days and evenings, to alleviate the concentration of activity on the day . shif t. This will reduce the overall burden on the day 1 Shift Supervisor
.(SS) and congestion in the. office while improving the ability to process work on both units.
. To reduce the burden on the Shif t Supervisor during scheduled outages in the -
fall of 1989, an additional Operations Supervisor was plac'ed in _ a " control O'd room' extension" to screen job orders and to ensure adequate work packages existed. This concept proved to be very successful in minimizing the impact of'the-high volume of outage job orders on the SS. <
?
Currently, an Assistant Operations Manager position- is being staffed by an
' Operations Supervisor. His duties include involvement in work planning, scheduling, . and prioritization, which- lessens some of the burden on' the
-SS.
'A second supervisor position (the Control Room Supervisor). was established two years ago as part of implementing a College Degree Program for operations b . supervisors on shift. When the degree program is completed in 1991,.an addi-tional SRQ,willi normally be available on shift to assist the= Shift Supervisor.
Additionally, the administrative dutien, of the SS associ.ated with the Condition Reporting System will be reduced when the shift engineer positions are filled.
Reference the AN0' Business Plan Project / Activity:
!C.5.a Engineered Operations-Technical Support C.7 Maintenance Optimization J.1 Reduce Administrative Burdens I
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, . DET' ITEM NO 2.1.2.5 - STATEMENT OF THE ISSUE j a >-
' 'M There was no' administrative procedural guidance for the use of station logs.
.For example, Limiting Conditions for Operation-(LCO) log entries were not made i
' for ' surveillance testing - that removed equipment from service. This could result in multiple trains of safety related equipment being simultaneously removed from service. -In addition, the standards of observation and accep-
- tance- by - the Unit 2 auxiliary and waste control operators during - the per-formance. of their i rounds were not thorough and concentrated only oni plant areas where log taking was required. (Section 3.2.3)
- ANO ROOT CAUSE i
Safety Culture (II)
Program Related Issues (V)
ANO RESPONSE TO DET ITEM 2.1.2.5
.e The conduct of operations procedure will'be revised to require LCO log entries for -surveillance testing ~ where equipment is removed from service. In addition, detailed management expectations om the type and - specificity of plant log entries will be incorporated in the revised procedure. In the n interim, memoranda placing this requirement in effect have been issued to the
- "j ' operating shifts. The Shif t Supervisors were directed tc log the surveillance and its applicable Technical Specification reference when the surveillance is performed. This-interim measure provided positive results in tracking. safety-related equipment being removed from service.
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.To further ensure adequate tracking of the status of equipment required to be y operable by Technical Specifications,-. an equipment status tracking procedure will be implemented. This ' will- provide additional assurance that equipment will not be removed from service . when required to be operable by Technical-Specifications.
Both units have new Operations Managers who have stressed conformance with procedures.to their crews. Having emphasized their expectations, the managers
( will utilize Shif t Supervisors to monitor other shif ts for proper performance of rounds and log completion. Plant Management will continue to ensure conformance to standards during plant tours.
A survey of practices in the area of > rounds and log taking is presently being conducted to provide a comparison of ANO procedural controls to those in use
-by other utilities. Practices identified which would enhance operations will be incorporated'into the appropriate procedure (s).
Reference the ANO Business Plan Project / Activity:
- l. C.10 Professionalism
- p. C 11.a Procedures Upgrade-Operations l G l
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.,- OPERATIONS-'AND TRAINING'
-s DET ITEM 2.1.2.6 -' STATEMENT.CF THE ISSUE f i Nd ' management guidance existed for ' the use - and control of the night orders ' i which ' the Operations Managers used to convey information to the operating s shifts. Thin resulted in informal communications (i.e. ,- unsigned and undated i statements) that had.the potential to be misinterpreted by the operating crews and were known toi have circumvented the standcrd operating procedures. ,
(Section 3.2.3)
ANO ROOT'CAUSE Management Involvement and Leadership (I) ~i Program Related Issues (V) i.xfi k -
o ANO RESPONSE TO DET ITEM 2.1.2.6 As an interim measure, metroranda have been ' issued to both units on the. subject of night, orders. These memoranda describe the use of night orders and their relationship to existing ANO documents. The conduct ' of operations procedure will' be. revised to provide administrative control of night. orders, as well as
.:several other issues. If a night order should conflict with plant procedures, ~
then either the function addressed in the night. order will not be performed
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or formal changes to the procedures will be accomplished,
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Reference the ANO Business Plan Project / Activity:
C.I1.a Procedure Upgrade-Operations ;
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e :DET ITEM 2.1.2;7t-; STATEMENT OF THE ISSUE-
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Mbh , Numerous problems ' with, plant equipment' had. existed for an extended ~ period.
Poor equipment reliability and availabili_ty- placed an excessive burden on the- '
operators, degraded safety margins and challenged saf ety equipment. A number
.of: examples were ', identified where plant management appeared to: live with equioment problems rather than. pursue aggressive and effective corrective
' act1<>n; (Section 3.2.4)
ANO ROOT CAUSE Safety Culture (II)' .
Planning, Scheduling, and Resource Requirements (III) !
Assessment, Trending,-and Root Cause Analysis (IV)
ANO RESPONSE TO DET ITEM 2.1.2.7 :
ANO Management is not willing .to accept deficient material conditions in the
., plantJ The past equipment problems were indicative of weaknesses identified
'W throughout the Diagnostic Evaluation-'and will be corrected through compliance ,
to the Busine:,s Plan.
. Identification of problems has been improved through the addition of a cross 19 U
section of industry personnel to plant management. Additionally, ANO per-sonnel have been sent to other plants to sensitize them to current industry standards of performance. An addendum to this section contains the current status of specific -equipment problems . identified by the Diagnostic Team and
. listed in Section 3 of the DET Report.
Plant equipment problems are being prioritized with regard to safety signifi-cance. Those problems with the greatest safety significance willibe scheduled accordingly.
' -i Corrective - main'tenance for plant equipment problems had. sometimes not' been
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scheduled appropriately due to conflicting- priorities among operations, main-tenance- and the Work Control Center. The recent organizational realignment of' maintenance personnel - and planning and scheduling personnel into unit-specific groups will further enhance the control: of work activities and the
. pursuit of resolutions' to equipment problems by helping to establish a sense l_ of ownership lu these groups for the material condition of their specific unit. 'The resolution of equipment problems will also be expedited by- the >
assignment of System Engineers on a unit-specific basis.
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, - U To improve communications between operations and the planning and scheduling group, an Operations Supervisor for each unit 'was assigned as a c.)ordinator between the two groups. The coordinator's responsibilities include providing operational input during job order planning and ensuring appropriate priori-ties are assigned to job order. This has greatly enhanced operations ability
' to schedule jobs which are considered necessary by operations personnel for the performance of their duties. It has also enabled planning and scheduling personnel to schedule jobs more . efficiently based on the input - provided regarding the plant conditions required to perform the work.
Rsference;the ANO Business Project / Activity:
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OPERATIONS AND TRAINING
- ADDENDUM TO DET ITEM 2.1.2.7 Significant improvements were made in the material condition of the plant during the Uni t - 2 Refueling Outage (September 1989), the Unit 1 Maintenance Outage. .
(November 1989), and the Unit 2 (January 1990) Forced Cutage with regard to the
. specific items identified in the DET Report Section 3.0, the following corrective actions have been taken or are being evaluated:
- 1. A large number of valve wrenches were needed to open or close many of the 7 manual valves and some motor-operated valves resulting in damage to several valves.
x The use of excessive force to open motor-operated valves has been pro-hibited. During the Unit 2 Refueling Outage (September 1898) and the Unit 1 Maintenance Outage (November 1989), manual valves were repacked to reduce the effort required in operating these valves. Operators have been instructed to submit job orders on valves which are not operating ,
properly . instead of simply " finding a larger valve wrench." Such valves will be appropriately scheduled for maintenance.
- 2. The DHR cooler outlet valves in Unit I have been inoperable and adminis-tratively locked open'since October 1988.
The operators for these valves are scheduled for replacement during the Unit I refueling outage which is pla.uted to begin October 1990.
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- 3. ' Seal injection valve CV-1207, letdown orifice bypass valve CV-1223, and RCS makeup control valve CV-1235 for Unit I would not control properly from the control room.
The letdown orifice bypass valvr. CV-1223 was repaired in June 1989 with satisfactory results. Valves CV-1207, the seal = injection valve, and CV-1235, the RCS makeup control valve, were worked during .the . Unit 1 i Maintenance Outage (November 1989) with satisfactory results on CV-1235.
Although CV-1207 is presently operating satisfactorily in automatic, L test connections have been temporarily installed due to a history of flow l fluctuations to assist in determining the root cause of the fluctuations.
- 4. The Unit 2 SG blowdown drag valves 2CV-1017 and 2CV-1067 could not be remotely controlled from the control room.
Maintenance performed on these valves restored the capability to operate them from the control room.
- 5. Recurring main feedwater control system problems on Unit 2 included erratic valve control and failure to satisfactorily operate in automatic.
Most of the problems with the Unit 2 Feedwater Control System (FWCS) '
occurred before 1985. There has been only one significant oscillation caused by a FWCS prob]em since 1985; this oscillation occurred af ter the DET inspection (Reference LER 50-368/89-024 00). The FWCS has operated
~T in automatic for nearly every shutdown since 1985. Continued attention (O will be given to this system to ensure adequate operation.
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OPERATION" AND TRAINING
']. ADDENDUM T0,DET ITEM 2.1.2.7 (CONT'D)
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- 6. . Access to the Unit 1 EDG rooms-required passage through a radiatiow area.
The source of the radiation was traced to drain lines in the overhead of
,.. the EDG room which have been subsequently flushed. The flush and the installation 'of temporary shielding in the EDG rsom next to the wall adjacent to the makeup tank have lowered the dose rate in the area and "p access to these rooms no longer requires passage through a radiation srea. The installation of permanent shielding in the makeup tank room is being evaluated and will be scheduled.
- 7. The Unit I automatic screen wash for the SW system was not being used due to equipment problems.
The normal mode of operation for the screen wash system is manual. This has been the main mode of operation since the system was first placed in operation. In addition, the manual mode of operation is described as being the normal mode of operation within the procedure for this system.
The operation of this system in the manual r. ode does not significantly.
increase the workload of-the Auxiliary Operator.
- 8. The inverter rooms for Unit I had very poor lighting.
A plant change to improve the lighting in these areas has been prepared and is currently in the final review process.
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- 9. The Unit 2 EDG had experienced three exhaust fires within the last year during monthly surveillance tests.
4 The Unit' 2 Refueling Outage (September. 1989) 18-month preventive maintenance surveillance received particular attention by Operations i and Maintenance. With . improved sealing of exhaust -header flanges and the overall quality of - the maintenance effort, no exhaust header fires have occurred since the startup from Unit - 2 Refueling Outage
.(September 1989). This item continues to be closely monitored by Operations.
- 10. . SW supplied room coolers for both Units 1 and 2 had been highly un-reliable due to a long history of coil leaks caused by the corrosion of the t.opper-nickel material of the coils.
On Unit 2, the Service Water Integrity Program is intended to resolve this issue. Long-term inoperable cooling units are being restored. For example, cooling coils for 2VUC-19A and 2VUC-19B are being replaced.
The coils for room cooler 2VUC-7B were replaced and the unit returned to service during Unit 2 Refueling Outage (September 1989). A new coil is being installed on iVUC-2C due to a coil leak identified in November 1989. The turnaround on repairs of these coolers has been significantly improved,
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4 OPERATI(,NS AND TRAINING f ADDENDUM TO DET ITEM 2.1.2.7 (CONT'D)
During Unit 1 Refueling Outage (scheduled for October 1990) a set of Reactor Building cooling coils will be replaced ("like-for-like" ;
. replacement) to allow destructive testing to be performed in an ef fort to determine wall thickness reduction. Also during Unit 1 Refueling Outage (scheduled for October 1990), the Decay Heat Room Cooler heads will be upgraded to . stainless steel as well as the new nozzle design being ;
installed. The upgrade to stainless steel will resolve the problem of ;
galvanic corrosion from the carbon-steel-to-copper interface. The lube j oil jacket coolers ' on the Decay Heat Removal Pumps and the Reactor i Building Spray Pumps will be upgraded to stainless steel when the .
materials become available, either during Unit 1 Refueling Outage !
(scheduled. for October 1990) or a subsequent outage of sufficient ,
duration. Due to a history of leakage of the Makeup Pump Room Coolers '
cooling coils, future replacements of these. coils will include an upgrade to stainless steel. '
- 11. The Target Rock solenoid valves had been unreliable and had caused problems due to failure to seat or operate.
The Target- Rock solenoids used in the Unit 1 EFW pump turbine steam supply systen and as safety injection tank vents on Unit 2 will be rep; aced. The use of Target Rock solenoid valves as RCS high point
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L.J vents is being evaluated.
- 12. The Unit 2 atmospheric steam dump valves failed to perform as designed, resulting in a remote manual mode of operation.
The two atmospheric dump valves downstream of the main steam safety valve have been placed in automatic. The material and desigi deficiencies have been corrected. Evaluations are teing performed regt rding the optimum operating mode for the two upstream valves.
- 13. The waste gas systems for both units were not fully utilized because of frequent failures of check valves, air compressors, and . system leaks.
A system evaluation has been performed by operations and engineering personnel on the Unit 1 Waste Gas System. This evaluation included equipment' operation (level cont.rol valves, vacuum pump operation, system integrity, etc.), operator interface (equipment controls and equipment, lo ca t. ions ) , and accessibility of equipment. As a result, a plant change has been initiated to enhance system performance an'd will be installed upon completion of the review and approval process. Further upgrades which require design changes will be included in the 18-month plan for resolution.
Although the issue has not been fully resolved on Unit 2, maintenance resources will be committed to correct during the next six months those deficiencies which can be corrected by maintenance activities (e.g.,
like-for-like replacement of carbon steel piping). Deficiencies which v will require design changes will be evaluated for long-term resolutions.
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hy 6 OPERATIONS AND TRAINING 7- ' ADDENDUM TO DET ITEM 2.1.2.7 (CONT'D) s j
Other problems noted in the report included repetitive Unit 1 instrument air compressors and air dryer iaflures; a diminished Unit 1 pressurizer heater ;
capacity due to ground faults; frequent Unit 1 moisture separator, reheater, distiller, and belly drain level control valve failures; _ unreliable Unit 2 charging pumps; and margin'. 'ly-sized valve operators on Unit 1 HPI valves.
Actions being taken with regard to these items are as follows:
- Maintenance engineering has been requested to investigate the availa-bility of the instrument and the service air compressors. Reliability of the compressors is being monitored, for future corrective actions or possible replacement. Corrective actions _that have been - implemented appear to have been effective.
- Pressurizer heater ground faults were cleared by realigning cable con-ductors to pressurizer heater tanks. Additional work will be conducted e during the Unit 1 Refueling Outage (scheduled for 1992).
- The level control system for the MSR distillers has been modified.
Currently, only one level control valve is on a handjack.
- The Unit 2 charging pumps will also be a high priority to be addressed by i System Engineering. The reliability of the pumps has been improved upon by more dedicated maintenance efforts, but continued improvement is
('3 necessary. Due to the three pump design, a charging pump failure does
() . not often cause entry into a Technical Specification Action Statement.
- MOVATS testing was conducted during Unit _1 Maintenance Outage (November 1989) on all four HPI block valves to justify the removal of the 100 cycle limitation. The testing on these motor operated valves proved successful with the 100 cycle limit being subsequently removed. The torque switches for each HPI motor operated valve were also reset.
The current schedule includes replacing these actuators with larger actuators during Unit 1 Refueling Outage (scheduled October 1990).
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p ;o DET ITEM 2.1.2.8 - STATEMENT OF THE ISSUE *
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9 ")' Although housekeeping practices. in visible and accessible areas of _ the plant f were generally good, less traveled areas were found considerably more clut- 3 e tered :and less organized with consumables, debris and unstowed and unsecured '
equipment very much in evidence. Many deficiency tags were observed identify-ing equipment which needed maintenance and other visible conditions which 5 required. repair. (Section 3.2.4) 0 ANO ROOT CAUSE 1
Safety' Culture (II)
Planning, Scheduling, 'and Resource Requirements (III)
Program Related Issues (V)
LANO RESPONSE TO DET ITEM'2.1.2.8~
Management is placing increased emphasis on attention to housekeeping re-quirements for specific activities, e.g., during and af ter maintenance on i equipment. The . housekeeping procedure has been revised and now assigns ,
responsibility . to appropriate plant individuals for specific areas. .These individuals have the responsibility for ensuring adherence to housekeeping-
.7 ,
requirements i.t their areas. A dedicated housekeeping _ crew has also been i t assigned to each unit. Progress has already been noted by NRC Resident M_ Inspectors (e.g., Unit I personnel access hatch). The housekeeping - crews have actively been improving the general appearance of the units. Schedules
. have been - established to bring the station up to management's expectations in this area during this SALP period. ,
e Walkdowns of 'the backlog of deficiency tags are being used on both units to e validate a.-list of open job orders. Valid. deficiencies are being verified as ,
being properly tracked in the Work Control Program. -When required, deficiency tags are placed on equipment requiring corrective maintenance. A program to reduce the backlog of corrective maintenance is being developed.
' Control room ~ deficiencies are being tracked and have been categorized in terms of status (e.g. , on hold due to materials, on hold due to engineering. evalua-
, , tion, etc.) and when they can be worked (e.g., outage required). A formal status ; report is issued weekly to unit management. Operations now sets priorities on working the control room deficiencies. This is evident by achieving the " black board" concept in both control rooms. Specific indi-viduals for each unit have been assigned the responsibility of tracking the status of the control room deficiencies.
Reference the ANO Business Plan Project / Activity:
C.3 Housekeeping C.12.a Backlog Reduction-Corrective Maintenance py
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i OPERATIONS'AND TRAINING g--
DET ITEM 2.1.2.9 - STATEMENT 0F THE ISSUE -
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Operator; adherence to procedures appeared to be adequate, and adequate control existed < to ensure - that operations personnel were being provided the correct documents for the conduct of day to day operations. ~However, several examples
- of procedural deficiencies were identified as needing correction and which were - known - by . plant personnel to exist. The apparent lack of corrective actions for these' known procedural deficiencies was considered to be an additional indication 'of a willingness by plant personnel to accept known problems. (Sections 3.2~5 and 3.2.6)
ANO ROOT CAUSE'
-Safety Culture (II)
Program Related Issues (V) q
.i ANO RESPONSE TO DET ITEM 2.1.2.9 l The NRC noted that several examples 'of procedural deficiencies were identified by plant staff; however, there appeared to be a willingness to accept _these known problems. This problem was attributed to lack of
" ownership" or professionalism by plant personnel and, in part, to A_ personnel working around problems to get the job done. Management has-( ) emphasized that identified, procedural problems are to be fixed; procedural. S v_) compliance takes precedence over productivity. l
.. j Improvements in procedural' compliance have been noted by Operations Manage- 1 cent. The Plant._ Safety Committee has seen an' increase in the number of ;
procedure temporary changes as a result of our personnel being more aware L of -the need to directly address procedural problems. ANO management will 3
continue to stress procedural compliance.
o L The procedure for Operations Department procedures revision control is _ being a revised to enhance control of temporary changes and the utilization of _ proce- i dure improvement forms. If the procedure change is required to complete a j task, a temporary. change must be used; enhancements to procedures may be identified using the procedure improvement forms. ')
Reference the ANO Business Plan Project / Activity:
C.10 Professionalism C.11.a Procedure Upgrade-operations ?
C.11.c Procedure Upgrade-Emergency Operating ]
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h OPERATIONS AND TRAINING DET ITEM 2.1.2.10 f STATEMENT OF-THE ISSUE 7
'im ) Independent' verifications' (IVs) were performed only for isolation valves in safety system major flowpaths. This did not include containment penetra-tion vent and _ drain valves . and did not appear to encompass the- intent of .
NUPIG-0737 Three' Mile Island (TMI) Action Plan Requirements, Item I.C.6, regarding IV. In addition, existing IVs contained in plant procedures only addressed the specifics that were implemented in 1980 to satisfy THI Action Plan Requirements. This would tend to negate the intent of. NUREG-0737, Item I.C.6,; in that systems added or modified af ter 1980 would not be covered by -
the IV process. (Section 3.2.6)
ANO ROOT CAUSE 1 Program Related Issues (V) ,
ANO RESPONSE TO DET ITEM 2.1.2.10 The omission of containment penetration vent and drain valves was identified by the DET in the Unit 2 Pre-Heatup and Pre-Critical Checklist Procedure. The corresponding Unit 1 procedure included the penetration vents and drains. The ,
Unit 2 pre-heatup checklist was revised to -include these valves, and this checklist was -- performed during the startup from Unit 2 Refueling Outage e (November'1989). Vr.ive lineups performed on safety systems during the startup from Unit 1 Maintenance Outage (December 1989) mid-cycle outage included a complete system alignment, not just valves in the system flowpath.
The existing station policy for independent verification requirements is being reviewed -.for '. incorporation into the conduct of operations procedure. This procedure is being revised to include 'the- requirements for independent-
. verification of safety system valve alignments, thus further assuring that i the intent of NUREG-0737 Item I.C.6 is maintained. _ Modifications to existing
- I safety systems will require the inclusion of independent verification require-l ments' in the new valve- lineups or procedure revisions needed as a result of -
the modifications.
- l. Reference the ANO Business Plan Project / Activity: -
l C.11.a Procedure Upgrade-Operations l:
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i OPERATIONS AND TRAINING a
IET ITEM 2.1.2.11 - STATEMENT OF TE ISSUE !
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t / The1 procedure for controlling temporary modifications was not being effee- i tively implemented. A majority of the temporary modifications were found to glbe in place for greater than 90 days and were not being periodically reviewed !
\ as required by procedure. (Section 3.2.6) !
I 6 ANO ROOT CAUSE
]
L Management involvement and Leadership (1) l
,.[ Safety Culture (11) .
Jg Program Related Issues (V)
J j ANO RESPONSE TO DET ITEM 2.1.2.11 The prbcsdure for controlling- temporary mouffications was not being ,
effectively implemented due to a lack of management emphasis on this issue.
More attention ic now being given to this area. ,
Temporary modifications in place for longer than ninety days have been reviewed in accordance with the Temporary Modification Procedure, and justifi-cat!nu for the extended time has been obtained and filed in the temporary modifiution. log beok as required by the procedure. The temporary modifica-8 tion log book has been reviewed and updated on both units. This procedure is being revised to . cnhance the temporary modification process and ensure that .
temporary modifications which will be installed for greater than ninety days <
are properly justified and reviewed.
Management attention to the resolution of long-standing temporary modifica-tions has' increased, and this issue is discussed during daily plant status !
meetings. The overall number of outstanding temporary modifications ' had decreased significantly by the end of 1989.
Reference the ANO Business Plan Project / Activity:
C.11.a Procedure Upgrade-Operations I
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l l' < . DET ITEM 2.1.2.12 - STATDENT OF THE ISSUE I Gi ~'
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F The integrity of valve lineups was negated because of the excessive use of ;
- j. exceptions. .This raised the potential for incorrect system lineups that could ;
impact plant and personnel safety. (Section 3.2.6)
ANO ROOT CAUSE !
Program Related Issues (V) ;
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-ANO RESPONSE TO DET ITEM 2.1.2.12 l i
f The integrity of the valve lineups for both units has been assured. Complete l l valve lineups were performed on Unit 2 during the startup from Unit 2 Refueling Outage (September 1989) and over thirty procedure changes were ;
made to reduce the number of valve lineup exceptions necessary during the startup. Although complete valve lineups on all systems were not performed ,
during the startup from Unit 1 Maintenance Outage (November 1989), the safety-related system valve alignments which were performed had few exceptions noted. ,
Guidance on the development ~ and usage of valve lineup sheets will be clarified in the revision of the conduct of operations procedure. Checklist errors en-S countered during the performance of valve lineups are now being corrected using temporary changes which will be followed up by revisions to the proce-dures. The anticipated result is a reduction in the need for exceptions resulting from the performance of lineups.
Reference the ANO Business Plan Project / Activity:
C.11. a - Procedure Upgrade-Operations f
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M T ITEM 2.1.2.13 - STATENENT OF THE ISSUE ,
) The operator training program was well organized and comprehensive, and re- !
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ceived strong management support. lioweve r , a concern was expressed by the ;
instructors regarding strained resources which could impact the overall
! quality of the training program. The repit. cement and requalification training programs were effective in developing and maintaining knowledgeable, skilled, and competent operators. Simulator improvement programs were effective in -
maintaining a high degree of simulator fidelity with that of the control rooms ,
of the respective units. (Section 3.2.7)
ANO ROOT CAUSE >
[ Planning, Scheduling, and Resource Requirements (III)
ANO RESPONSE TO DET ITEM 2.1.2.13 .
ANO is pursuing supplementing the staff with outside contract support to relieve some of the pressure on the staff and maintain the schedule and ;
quality of the upgrade program. These actions will address the concern expressed by the instructors.
Reference the ANO Business Plan Project / Activity:
e 11 . 1 Operations Training Upgrade l 0
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'" 'DET ITEM 2.1.3.1 - STATEMENT OF ISSUE i
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-) Although. some staffing increases for mechanical and instrument and control (I&C) maintenance were approved in the 1990 budget, it was not clear that sufficient !
resources would be available to address deficiencies in the technical support ;
area, reduction of the job order and modification backlog, implementation of the l preventative maintenance (PM) program, and completion of the reorganization.
(Section 3.3.1) t u ANO ROOT CAUSE i i
Management Involvement and Leadership (I) f i Planning, Scheduling and Resource Requirements (III) :
i ANO RESPONSE TO DET ITEM 2.1.3.1 Management, recognizing the need for additional resources to address deficiencies in specific areas, provided additional positions in the maintenance area for L Maintenance Engineers and I&C Technicians. This action was taken during the initial budget preparation for 1990. The maintenance staff is actively recruiting l and filling these positions. In addition, as part of our overall workload f management and Business Plan efforts, ANO is currently conducting a comprehensive 9 staf fing study to evaluate resource requirements. The staffing study is directed toward providing in-house manpower to meet baseload requirements, with no staff augmentation supplemented by defined scope contractors to meet peak loads. This plan is scheduled to be implemented over a three year period.
Improvements in the management of the maintenance backlog is one of the intended ;
benefits of station unitization. Personnel have been assigned to each unit. '
Negotiations have been concluded that will allow specific resources to be dedicat-tw ed to each unit on a rotating shift basis. This will optimize staff utilization and enhrace backlog reduction efforts. Until staffing is complete that will meet :
baseload requirements, staff augmentation will be maintained to meet workloed requirements.
We have made initial assignments of System and Maintenance Engineers to Nuclear Operations to improve the effectiveness of maintenance. activities. We recognize that these initial resources are not adequate, and we will supplement those resources with contractors as required.
\ i A number of other specific activities have been included in the ANO Business j l Plan to enhance ownership and effectiveness of the maintenance process which is expected to result in improved efficiency.
ANO will monitor the effectiveness of these initiatives through measurements of
- effectivenss, p roj ect' milestones, corrective and PM backlog reduction, and mcdification backlog reduction, 9
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[ MAINTENANCE l
DET ITEM 2.1.3.1 (CONT'D) i i
' Reference DET ITEM 2.1.3.6 for discussions on the Preventive Maintenance Program.
Reference the ANO Business Plan Project / Activity: '
j C.2 Preventive Maintenance !
C.4 - Engineered Maintenance l C.5 Engineered Operations +
, , C.7 , Maintenance Optimization !
C.12.a Backlog Reduction-Corrective Maintenance i C.22.b Backlog Reduction-Preventive Maintenance -!
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? jdM EST ITEN 2.1.3.2
. STATENDIT OF 18815: - '
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' Morale:within each' maintenance group was good, and craft and technician personnel -l n - -
' appeared to be competent and knowledgeable; in performing their jobs. (Section l 3.3.1). '
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- ANO ROOT CAUSE' None-o.
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i MAINTENANCE DET l'IT.K 2.1.3.3 - STATEMENT OF ISSUE
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Corrective maintenance was weak overall and inadequate for mach equipment, includ-ing some safety-related components. A number of areas were identified where longstanding repetitive problems existed, where corrective actions were apparently ineffective and where the licensee was unable to effect a permanent fix. In addition, there were a number of related weaknesses involving lack of tracking and trending of equipment problems, poor root cause analysis, lack of timeliness of corrective actions, lack cf effective plant engineering involvement, and poor quality and retrieval of maintenance history files which sigaificantly impacted the effectiveness of maintenance activities. (Sections 3.3.2 and 3.3.11) i ANO RO's.' CAUSE Assessment, Trending, and Root Cause Analysic (IV)
Program Rela' 4 1ssues (V)
+
ANO RESPONSE TO DET ITEM 2.1.3.3 To focus on ef fective and timely corrective maintenance, management has restruc-tured the organization to dedicate management, engineering, planning and scheduling, and maintenance craft resources to each unit. The work closure activities, including equipment history and trending, will be expanded to address O, the specific deficiencies in retrieval of equipment history and generation of i
n) trend information for root cause analysis and for making preventive maintenance enhancements. The unit system engineering resources will provide a basis for consistent and improved root cause determinations. System Engineering will also provide the appropriate unit operations and engineering interface for establishing ;
safety priorities for planning and scheduling of maintenance activities. -
Engineering support for required design changes to address deficient, long stand-ing problems is prioritized through the established 18-month Design Change Plan, which is reviewed and implemented by the appropriate Plant Manager and the appropriate Design Engineering Manager (s).
The enhancements necessary to establish an effective equipment history and trend-ing program include an assessmant of the current Station Information Management System (SIMS) and Nuclear Plant Reliability System (NPRDS) data base. Usage, report generation capabilities, and information entry and retrieval capabilities are being evaluated. Based upon this assessment, any additional features necessary to upgrade these systems to provide adequate, timely and consistent input for failure analysis and subsequent corrective action determinations vill be added in stages.
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, ';DET ITEM 2.1.3.3 (CONT'D) 3 For additional discussion, reference the following DET ITEMS:
- Root Cause Analysis - 2.1.1.10
- Tracking and Trending - 2.1.1.10
- Corrective Action - 2.1.1.10
- Engineering Involvement - 2.1.2.3 and 2.1.5.7 Reference the AND Business Plan Project / Activity: 4 B.1 Improve Root Cause Det'ermination i B.2 Improve Corrective Action Program B.5 Performance Monitoring (External / Internal Trending)
C.4 Engineered Maintenance C.5 Engineered Operations C.6 Work Closure C.9 Trending ,
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, IET ITEM 2.1.3.4 - STATEMENT OF ISSUE q r (v) The unavailability of spare parts and spare parts control were predominant contri-i butors to the existing maintenance problems. Other deficiencies identified in material management included inadequate control of shelf life for relays and l improper dedication of commercial grade components. (Section 3.3.7)
ANO ROOT CAUSE
)' ;
Management Involvement and Leadership (I)
, Program Related Issues (V) i ANO RESPONSE TO DET ITEM 2.1.3.4
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Re'cently the ANO Materfuls Management Organization was consolidated to include all support functions including materials engineering. The Project Managers '
responsible for the Materials Control Project and the Materials Line Organization now report directly to the Vice President, Nuclear. This will ensure adequate 3 management oversight of both day-to-day Materials Department operations and the [
improvement initiatives of the Materials Control Project. Further, these changes will provide for specific accountability and ownership of the various materials management functions, k ~
Furthermore, a comprehensive review of the ANO Materials Management Organization .
and procu.s was completed in 1989. This review included independent assessments in several materials related areas using both internal and external assessment resources. Several weaknesses and areas of concern were identified. As a result, temporary control measures were implemented to ensure that any spare parts or
. .ma te ri als safety concerns are -icquately addressed. For example, all materials and spare parts issued from de warehouse for safety-related applications are e reviewed by a Materials Engineering End Use Authorization Team, h However, these temporary control measures, along with other known material program deficiencies, have contributed to less-than-timely materials support for the ANO Maintenance Organization. This is manifested in the current maintenance job order backlog attributed to materials " hold", -
L Major programs have been initiated to improve the ANO Haterials Management organi-zation and process. In September 1989, all known materials problems, along with a corrective action plan, were published in a doeuroent entitled " Project Plan for Materials Control Project." The action plan has been reviewed and endorsed by ANO line management.
Several tecks are currently in-progress to address specific materials-related concerns. These include:
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i MAINTENANCE
, ') DET ITEM 2.1.3.4 (CONT'D)
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- Commercial Grade Item Procurement - A procedure implementing the EPHI NC1G-07 Commercial Grade Item Dedication Methodology was implemented at ANO in December 1989. As of January 15, 1990, all Commercial Grade Procurements at ANO are conducted using this procedure. At the present time, the ANO Materials Engineering process is under revision. k' hen l these revisions are complete, the Connercial Grade Item Dedication Process will be included in a new materials engineering procedure for implementation by the Materials Engineering Line Organization.
- Shelf Life Program - The ANO Shelf Life Program is currently in the production phase. All inventory Safety-Related, Fire-Related and .
Special Requirements (Q, F, and S) iter.m are being evaluated for Shelf Life requirements. Additional temporary measures are in place to ensure that unreviewed items are not issued for plant applications. All new ;
7rocurements are now being evaluated to establish Shelf Life require- ;
ments as appropriate. The review of Q, F, and S category items is scheduled for completion in 1990. k' hen the review phase is complete, procurement, receipt and issue procedures will be revised to ensure permanent shelf life concerns.
- Materials Engineering Restructuring -
The Materials Engineering function has been consolidated and now reports to the Materials Organization. Process revisions are under development which will
/, ,1 ensure consistency, technical integrity, and ultimately eliminate the
\d need for existing temporary control measures. This wil.t improve materials management's responsiveness to ANO plant materials needs.
- Materials Management Organization - A Materials Management Organization and Staffing Study has been developed and provided for management review. This study provides a proposal for a Materials Organization ,
that supports AN0's long-term performance goals.
Seve ral other improvement initiatives are planned for implementation in 1990-92. -
These include:
- Coordinate with maintenance, purchasing, and enginee.4ng to develop effective raterials planning pru tss.
- Revise the receipt, issue, storage and materials control procesaes to be responsive to plant needs and consistent with industry standards.
- Establish materials data standards and reformat existing materials data into the present information system.
- Evaluate the adequacy of existing ANO storage facilities.
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DET ITEN 2.1.3.4 (CONT'D) l l
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- Perform a complete inventory of warehouse contents and determine the ,
physical and documentation attributes for use in verifying accepta- l bility for plant applications. In addition, establish approprf ate l inventory levels. '
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- _ Develop bills of materials for selected plant components, identify j comen,dity specification. requirements, and build procurement technical i requirements for both. (This provides the final resolution for concerns requiring temporary control measures).
Reference the ANO Business Plan Project / Activity:
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-: u i " ,E.1 Naterials Engineering j E.2 Organization and Staffing 1 E.3 Materials Management Information System Data Base j E.4 Commercial Grade Dedication Program a a E.5 Shelf Life I E.6 Business Process Improvements '
E.7 Inventory Control / Management Improvements i E.8 -Facilities Improvements ,
E.9 Procedures r
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- . The'large number of maintenance job orders was excessive and had significantly increased within the' last eight months. The lack of concerted action by manage-ment, unavailability of spare parts, and the lack of meaningful tracking j mechanisms and clear goals for managing and reducing the backlog were significant ;
contributors to the backlog problem. (Section 3.3.4) l i
ANO ROOT CAUSE ,
Management Involvement and Leadership (I) ;
Program Related Issues (V) j ANO RESPONSE TO DET ITEM 2.1.3.5 Reference DET ITEM 2.1.3.1 for discussions on Job Order backlog reduction.
Reference DET ITEM 2.1.3.4 for discussions on unavailability of spare parts.
Reference the ANO Business Plan Project / Activity:
C.12.a Backlog Reduction-Corrective Maintenance ,
C.12.b Backlog Reduction-Preventive Maintenance r~s
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MAINTENANCE IGT ITEM 2.1.3.6 - STATEMENT OF ISSUE s Preventive maintenance was weak overall. A number of examples were found of ;
inadequate PM procedures that involved the failure to use equipment history, the absence of PM on some safety-related equipment, nonconservative maintenance g f requencies and. poor management oversight and involvement. A new PM program was being developed; however, the schedule for implementation had been extended several times and completion was at least n year away. Predictive ' maintenance ,
programs were in place for vibration and lubricant analysis; however, thermography <
analysis was only in its formative stages. (Section 3.3.3)
ANO ROOT CAUSE Management involvemeat and Leadership (1)
Planning, Scheduling and Resource Requirements (III)
Program Related 1 aues (V) (
ANO RESPONSE TO DET ITEM 2.1.3.6 Responsibility for the PM Program has been transferred from ANO Engineering to Nuclear Operations. This should enhance plant ownership of the program. The PM Program for Safety-Related, Fire-Related, and' Special Requirements (Q, F, and S)
,- procedi.res will be completed in 1930. The program will be continued to consider (w,) inclusion of other plant equipment.
Preventive Maintenance' Engineering Evaluations (PMEE) provide the ba:.is for the PM procedures. These evaluations are being performed by Maintenance Engineers.
Justification for any deviations from vendor recommendations are documented within the PMEE. Ninety percent of the PMEEs are complete. ANO will continue to review and update these as necessary. A PMEE -rsay be revised based on equipment failure history, review of vendor information, industry experience, or regulatory corm t-ments.
The adequacy and usability of procedures developed - in the program will be enhanced. Maintenance craft review of each PM procedut.' will be required and comments will be resolved prior to approval. Each new procedure will be verified
" prior to approval. The procedure will then be validated during the first perfor-mance by the craf t, and comments will be incorporated as necessary. ;
Those procedures approved prior to February 1, 1990, will be revised to enhance their usability. This effort will include correction of deficiencies identified by the craft through use or review.
Each significant deficiency identified by the Diagnostic Team will be evaluated and addressed. PMEEs and procedures will be revised as necessary, n ..
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. j MAINTENANCE ,
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l' DET ITEM 2.1.3.6 (CONT'D)- !
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i.ng . - .This program will include vibration . analysis, lubricant analysis, and i
. thermography. . The information generated by this -program will' be used to revise PM requirements. based on' actual equipment performance. ;
J Reference the ANO Business Plan Project / Activity: ^
i B.4 Upgrade Use of Industry and In-House Event Reviews ,
C.2' Preventive Maintenance ,
C.4 Engineered Maintenance C.6 Work Closure i C.8 Predictive haintenance !
C.12.b, Preventive Maintenance ;
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) Despite an extensive program for periodically inspecting and lubricating motor-operated valves (MOVs), the program for ensuring reliable MOV operation was weak due to poor root. cause analysis, inadequate conuanication between maintenance L
and engineering, and poor evaluation and incorporation of industry operating experience. In one case, plant operations continued without an engineering
- analysis, inspection or testing for potentially defective melamine torque switches in MOV operators. (Section 3.3.2)
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ANO ROOT CAUSE Management anvolvement And Leadership (I)
Assessment, Trending, and Root. Cause Analysis (IV)
Program Related Issues (V)
ANO RESPONSE TO DET ITEM 2.1.3.7 In order to enhance the maintenance organization's root cause analysis efforts, root- cause analysis training vill be provided to additional maintenance and engineering personnel. Personnel in maintenane- who perform root cause analysis will become qualifired by successfully completing this training. Management has
, clearly assigned the responsibility -for MOV Program ownership t' Design Engineer-
/ ) inF and for program implementation to the maintenant6 agancations. The respec-V :tive organizations will be held accountable for the Lifectiveness of the MOV Program.
ANO is improving the reliability of MOV operations by improving communications betweed-' organizations and by being more aggressive in monitoring operating experiences _ and improving the root cause analysis process. MOV deficiencies are being addressed as part of the effort to improve the overall material condi-tion of the plant. This will be an ongoing activity in order to minimine problems similar to those noted in DET ITEM 3.3.2.3.
ANO- has completed a detail review and analysis of melamine torque switches at ANO. This review and analysis included testing of components to prove opera-bility, replacement, or analysis to justify safe. operation until replacement could be completed. Melamine torque switches covered by the Limitorque 10CFR21 notification have been changed out for Unit I and Unit 2.
' Reference DET ITEM 2.1.1.10 for discussion on root cause analysis.
. Reference DET ITEM 2.1.1.10 and 2.1.5.8 for discussion on industry operating.
experiences.
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IET ITEN 2.1.3.7. (CONT'DI G.n '
Reference the ANO Business Plan Project / Activity: .
~y B.1 Improve Root Cause Determination '
B.4 Upgrade Use of Industry and In-House Event Reviews C.4- ' Engineered Maintenance l C.5 Engineered Operations - '
D.5.d Engineering Improvement Programs-Design Engineering Support of ANO HOV Program
, . D.9- Engineering Department Communication Plan D.11 Industry Experience X.3 Comnunications i
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, 3 MT . ITEM 2.1.3.8 - STATENENT OF ISSUE A number of weaknesses were found in the planning of maintenance and in the preparation of work packages. For example, work packages did not always contain or reference the appropriate drawings, and craf t personnel did not always verify that the correct drawings had been provided in the work packages. Drawing veriff-
- - cation ' problems had been previously documented in quality assurance (QA) audit reports. (Sections 3.3.5 and 3.3.8)
ANO ROOT.CAUSE i Management Involvement And Leadership (I)
Program Related Issues (V) l i
ANO RESPONSE TO DET ITEM 2.1.3.8 l l ANO has taken steps to improve the planning of maintenance work packages to ensure & ,
that standards for quality work packages have been defined. In order to ensure i conformance to the standards, the Planning and Scheduling Department has been moved to report directly to the Plant Managers. This will enhance accountability and maintenance feedback.
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T( ') ANO has taken steps to ensure that work packages reference the appropriate draw-U ings. A revir,fon to the conduct of maintenance procedure was approved on September: 28, 1989. The procedure instructs the craft personnel that drawings to be used shall be controlled and issued by Drawing Control.
Reference the ANO Business Plan Project / Activity:
C.6 Work Closure C.7 Maintenance Optimization C.ll.b Procedures Upgrade-Maintenance
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' IET ITEM 2.1.3.9' - STATEMENT OF ISSUE
!( In general, maintenance procedures, with the exception of PM procedures, were found to be adequate, although no specific precedures or guidelines were established for generic, post-maintenance testing. (Section 3.3.6)
AFO ROOT CAUSE Program Related Issues (V) ,
ANO RESPONSE TO DET ITEM 2.1.3.9 Maintenance Engineers and maintenance standards personnel will develop guidelines for post-maintenance test requirements and procedures. i These guidelines will be developed by using the plant experiet.ee, and input from industry experience.
Any changes identified to thece guidelines will be requested through Maintenance Engineering for review and spproval.
Maintenance Engineering will continue development of these guidelines until completion and obtain approval of procedure changes. Procedures will define the
/~') responsibilities of various organizations to maintain and implement the require-V ments.
The requirements and responsibilities for post maintenance testing will be clearly delineated in site administrat.1"e procedures. In addition, generic guidelines will be developed to aid the planners in establishing post-maintenance test requirements.
Reference.DET ITEM 2.1.3.6 for discussions on Preventive' Maintenance, t
Reference the ANO Business Plan Project / Activity:
,- C.4 ' Engineered Maintenance C.7 Maintenance Optimization C ll.b Procedures Upgrade-Maintenance
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riAINTENANCE 3 DET ITEM 2.1.3.10 - STATEMENT OF ISSUE Quality Control (QC) involvement in corrective maintenance acti'rities was weak.
. Beet.ase of minimum participation in job order preparation anj poor assessment methods for identification of equipment problems, the QC Department ef fectiveness in supporting maintenarce was significantly limited. (Section 3.3.9)
ANO ROOT CAUSE Assessment, Trending, and Root Cause Analysis (IV)
ANO RESPONSE TO DET ITEM 2.1.3.10 The NRC noted that the Quality Control (QC) involvement in corrective maintenance activities var, weak, particularly for equipment with repetitive repairs. There was an identified lack of QC review of job orders prior to field implementation.
The QC/QE Departenent has taken an active role in the review of job orders prior to issuance to the craf t personnel. This review currently is being performed under temporary guidelines approved by the QC/QE Hanager. The purpose of - this review is to improve QC involvement in corrective mafi.tenance activities. This is accomplished through the insertion of inspection holdpoints and/or notification points into selected job order documents.
- \
() Detailed QC review guidelines are being developed. These guidelines will be applicable to corrective maintenar.cc job orders in the mechanical, electrical, and instrumentation and control disciplines. These guidelines will be governed by approved Nuclear Quality Procedures. As improved maintenance history informa-tion becomes available, QC/QE will utilize the information to assist in identify-ing , recurring equipment repairs warranting QC involvement.
Reference the ANO Bubiness Plan Project / Activity:
A.I.e Japrove QA/QC Ability to Self-Identify Problems / Precursors-Quality Review of Haintenance Job Orders During Planning Phase C.6 Work Closure C.9 Trending T
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SURVEILLANCE AND TESTING x
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C-)DETITEM2.1.4.1-STATEMENTOFISSUE Inser*iice Testing (IST) was adequate and, with the exception of a few weaknesses, was a technically sound and competently executed program. (Section 3.4.1) ;
i ANO ROOT CAUSE bnagement Involvement, and Leadership (I) i Program Related Issues (V) t ANO RESPONSE TO DET ITEM 2.1.4.1 [
The DET stated that the ANO IST Program was adequate with the exception of a few ,
weaknesses. These weaknesses and their current status are as follows:
- SOER 86-03, " Check Valve Failures or Degradation" were not fully addressed. ,
A comprehensive Check Valve Inspection Program has been developed by ANO using guidance from SOEM 86-03. The inspection program has been formalized into the ANO
" Check Valve Inspection Program". This program was approved for implementation on September 29, 1989, duting the Unit 2 Refueling Outage and was utilized to coor- ,
dinate and conduct inspections, p)
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- Omission of required Unit 2 Service Water (SW) pump test This concern relates to the' omission 9f pump flow vs head criteria in the ;
surveillance test procedure for the Unit 2 SW pump. Flow inst.rumentation was '
not included in the original design of the SW system. A relief request was submitted (June 15, 1978) for the ANO ISI/IST Program. ANO rroceeded with the program and relief reque:st as submitted. NRC approved the w]ief request on June 20, 1985. An NRC letter dated November 15, 1980 transmitted a Supplemental Safety Evaluation Report (SSER) to ANO. In this SSER (Item 3.6), '
the NRC denied the previously approved relief request. Since the issuance of the SSER, ANO has established baseline curves for the SW Pumps. This work was completed on January 19, 1990. In additien, ANO has developed flow vs head curves. Those curves are incorporated into the pump testing procedures. '
- Lack _of design minimum performance criteria for pumps -
ANO realized that some of the design minimum performance criteria were not included in some of the procedures. The ANO ISI/IST group has requested Design Engineering to provide design minimum criteria for pumps in the ISI/IST Program.
This work is still ongoing and is an integral part of the Design Configuration Documentation (DCD) project. The operability determinations for the inservice testing of the subject pumps are still valid because they are based on reference values established following preoperational testing which verified design parameters, b ,
SUlWEILLANCE AND TESTING DET ITEM 2.1.4.1 (CONT'D) i
- Veak trending and test data evaluation This problem stemmed from the fact that the IST Coordinator was not receiving the test data information in a timely manner. This delay resulted in inadequate trending and testing evaluation problems. Measures wen implemented in late 1989 to provide the IST Coordinator with timely test data information. Now when a test is performed, the Maintenance History group routes the job order, including the test data, to the IST Coordinator.
This expedites the process such that the Coordinator can evaluate the data.
To further enhance the process, Operations also provides the IST Coordinator with a preliminary copy of the test data.
- e. To enhance the evaluation of the test data, ANO has purchased a computerized ISI/IST da:a base management system. This system, currently being installed, will provide more accurate and timely trending capabilities. The ISI/IST group is also revising their procedures requiring them to provide trending reports to Maintenance and Operations.
- Insufficient engineering personnel for the ASME Test Program.
As stated in other sections of the DET/SALP response, ANO is currently performing a Staffing Study. This study is based on an evaluation of the resources available vs the projected workload.
)
- History of missed surveillances The DET noted that some surveillances were missed or not performed in the required time frame. This was a. direct result of lack of ownership. No single organization was responsible to ensure this was happening. As a result, no one was verifying or cognizant of the surveillances needing to be '
performed, the time interval or plant conditions required to accomplish this.
The Technical Specification Surveillance group will have complete ownership of this process.
Reference the ANO Business Plan Project / Activity:
C.1 Surveillance Programs C.9 Trending -
D.5.z Engineering Improvement Programs-Inservice Testing (IST) Program
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i DET ITEM 2.1.4.2 - STATEMENT OF ISSUE i
/ T V Surveillance and testing program wedknesses included the omission of so'me required tests such as for the Unit 2 service water (SW) pumps, the lack of design minimum performance criteria for pumps, weak evaluation of trending data and insufficient !
engineering support. (Section 3.4.1) l
-ANO ROOT CAUSE ,
Management Involvement and Leadership (I) f Assessment, Trending, and Root Cause Analysis (IV) i Program Related Issues (V)
,p ANO RESPONSE TO DET ITEM 2.1.4.2 During the period that the SALp and DET were conducted, no single organization had the responsibility or ownership for the entire Surveillance Test Program.
This lack of ownership and continuity resulted in several surveillance tests being missed. As a result of the recent organizational realignment, the Technical Specification Group has been created and reports to the Manager, Nuclear Operations handards. The responsibility of this group is to track the Technical Specification surveillances and ensure that they are completed as scheduled.
_n This will also prc. vide a sense of ownership in this group insuing surveillances i are conducted as scheduled.
Another task this group will perform is the review of each Technical Specification (TS) surveillance requirement and verify that a procedure correctly implements the surveillance requirement and properly. documents system operability.
The implementation of the System Engineering Program will provide sufficient engineering support for evaluating trending data and assisting the. Shift Supervisor for equipment operability determinations. The System Engineer will be C responsible for evaluating the test data for their specific system (s) to ensure that the system is operating within its desigr. basis. If a problem is identified during this evaluation, the Shift Supervisor will be promptly notified in order to make a timely operability determination.
In addition to these improvements, the computerized surveillance tracking system for tracking surveillance test dates will be evaluated and, as needed, correct any ,
deficiencies necessary to improve its reliability.
The specifics outlined in the statement of issue; omission of some required tests such as for Unit 2 service water pumps, lack of design minimum performance criteria' for pumps, weak evaluation of trending and insufficient engineering-support are addressed in DET ITEM 2.1.4.1.
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h Reference DET'ITEN'2.1.3.3 for discussions on trending.
Reference DET ITEM 2.1.4.1 for discussions on SW and' design minimum performance g; criteria.
, Reference- the: ANO Business Plan Project / Activity:
h C.) Surveillance Programs-
- b C.9 Trending F D.5.n' Engineering Improvement Programs-Inservice Inspection Improvement ic .
Program
.D.S.z- Engineering Improvement Programs-Inservice Testing (IST) Program s
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) Inservice testing (IST) procedural deficiencies included a failure to document the !
cause of adverse trends, a failure to coordinatt the trending ef fort with opera-tions, errors or omissions in referencing procedures for component tests, and the ,
e lack of criteria for determining the need for revised test reference values.
(Section 3.4.2)
ANO ROOT CAUSE
!= Program Related Issues (V) l ANO RESPONSE TO DET ITEM 2.1.4.3 The IST Program needs improvements in program definition, control and administra-tion to address the identified deficiencies. Development of program documents and procedures changes will be implemented along with basis documents to improve the program. The examples stated by the NRC and their status are as follows:
Unit 2 Service Water Pumps This issue is discussed in DET ITEM 2.1.4.1. '
Omission of testing the EDG auxiliaries
..v/}
The concern with this issue was that ANO did not include testing of some EDG
& auxiliaries in the IST Program. ANO has incorporated the EDG auxiliaries in the ANO-2 IST Program upgrade to the 1986 Code; although ,
in the NRC SSER, dated November 15, 1989, the staff agreed with AN0's ,
position that the EDG auxiliaries are not required to be in the IST Program.
References to some test procedures for components are incorrect (e.g., ANO-1 HPI check valves) ;
ANO is currently revising the IST administrative procedures to incorporate ;
additional components and procedures. The HPI check valves mentioned have been tested in accordance with the IST Program requirements by the
. -implementing procedure as committed in AN0's evaluation to address the HPI bistkflow event.
No criteria for Unit 1 SW pump revised reference values or setting acceptance limits The IST Program procedures are being revised to include guidance for estab-lishing reference values.
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.i SURVEILLANCE AND TESTING
, j ef 7 e- . MT ITEM 2.1.4.3.(CONT'D)
=- -
Quarterly trending report and coordinating trending with Operations. I Reference DET ITEM 2.1.4.1 for discussions on tretiding.
. Reference the ANO Business Plan Project / Activity:
J C.1 Surveillance Programs C.9 - Trending ,
D.5.z - Engineering Improvement Programs-Inservice Testing . (IST) Program -]
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SURVEILLANCE AND TESTING DET ITEM 2.1.4.4 - STATEMENT OF ISSUE
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(/ Several TS surveills.nie tests were not performed when required during 1988. A new tracking system had even been placed in operation, but recently, tests were l again missed indicating the need for continued management attention. ,
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ANO RO0T CAUSE 3 i P Management Involvement and Leadership (I)
Program Related Issues (V) l i
ANO RESPONSE TO DET ITEM 2.1.4.4
]
Reference DET ITEM 2.1.4.1 for discussion on missed Technical Specification .
Surveillance Testing.
Reference DET ITEM 2.1.4.2 for discussion on Technical Specification Surveillance group and tracking. '
Reference the ANO Business Plan Project / Activity:
C.1 Surveillance Programs
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, 3 DET ITD! 2.1.4.5 - STATEMENT OF ISSUE
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For both units, the ASME IST program specified maximum allowable stroke times for i several valves that exceeded the normally expected stroke time and, therefore, served ' no purpose in identifying significant degradation or failure. (Section i 3.4.2) i 1
i ANO ROOT CAUSE j
,"" Management Involvement and Leadership (I)
- Program Related Issues (V) j ANO RESPONSE TO DET ITEM 2.1.4.5 ;
Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Program", noted a common industry program deficiency in that significant valve degradation or failure could occur. Upon evaluating the concerns in GL 89-04, ANO is revising the Unit 1 IST Program to provide adequately. based criteria setting
-maximum stroke times. The Unit 2 IST Program is being upgraded to the 1986 Code. '
As part of this upgrade, we will also provide the criteria for setting maximum r
stroke times in accordance with GL 89-04.
r^' Reference the ANO Business Plan Project / Activity:
N.)s D.5.z Engineering Improvement Programs-Inservice Testing (IST) Program ,
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') .LET ITEM 2.1.4.6 - STATEMENT OF ISSUE ;
Test data evaluations were weak in some instances and included nonconservative, incompletely resolved and undocumented operability determinations. (Section 3.4.6) '
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,pc ANO ROOT CAUSE j Safety Culture (II) ;
Assessment, Trending, and Root Cause Analysis (IV) '
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{t, i ANO RESPONSE TO DET ITEM 2.1.4.6 Reference DET ITEM-1.1.2.3 for discussions on operability determinations, !
Reference DET 2 TEM 2.1.4.2 for discussions on Test Data Evaluations.
Reference the ANO Business Plan Project / Activity:
L.5 Engin'ered Operations C.11.0 Procedure Upgrades-Operations H.1 Operatfora Training Upgrade c~
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Program improvements int 16ded the addition of new test instruments, the. testing of-check valves, completion of upgrading the Unit 1 ASME IST program and initia-tion of an upgraded review for the Unit 2 ASME IST program. (Section 3.4.2)
.ANO ROOT CAUSE u_
None
!ANO RESPONSE TO DET ITEM 2.1.4.7.
A review is being performed of the Unit 1 ASME IST Program. In addition, ANO is upgrading.the Unit 2 IST Program to the 1986 Code as discussed in DET ITEM 2.1.4.3
, -and 2.1.4.5.
, Reference the ANO Businesc Plan Project / Activity:
, D.5.z - Engineering Improvement Programs-Inservice - Testing (IST) Program-
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DESIGN AND ENGINEERING SUPPORT DET ITEM 2.1.5 - INTRODUCTION '
o
'l~) ' The DET recognized improvements from organization and management changes which focused upon improvements in the areas of design and engineerinF. support, capacity to address complex technical problems in a timely and conservative manner, communications between Engineering and other ANO organizations, problem identifi-cation and tracking.
'ANO recognizes'the need to strengthen its engineering programs to maintain plant design basis and support safe plant operations. Responses are provided in the key improvement areas of communications, ownership, workload management, resource recruitment and retention, system engineering training, corrective action pro-grams, progress in - major progran implementation, and design / modification process improvements. Specific actions and root causes are identified in each response.
Specific design engineering programs that are referenced to in the Design and Engineering Support response are:
The Engineering Resources Plan is a detailed resource analysis of the requirements for engineering support for routine work improvements, projects plant modifica-tions, and backlog reductions. It is utilized by management to make decisions on-staffing levels and contractor utilization.
The Backlog Reduction Program is a defined effort to identify, prioritize, and reduce the backlog of requests for engineering support, drawing changes, and close outs of modifications.
l l /D The Design Configuration Documentation Program is a comprehensive program to V improve the quality, completenuss, and retrievability of the design documentation l for ANO. The -Configuratic , Management Program is designed to maintain the l verified design basis.
The System Engineering Plan for ANO involves the dedication of engineering support
~directly to the operations group of each unit.
l l
The Individual Development Program provides a systematic job task analysis based l training program for Design Engineering. It -includes both administrative, procedural and technical training aspects.
L The- 18-month plan is a resource-loaded, scheduling system used to provide scheduling, work and resource planning, and the management analysis for projects, programs and management initiatives. The priority and schedule of individual items is routinely reviewed with the Unit Managers.
The two-week schedule is a cask . tracking system used to forecast engineering support requirements and responses for a rolling two-week period.
The Industry Experience Program provides information from industry and in-house
. experience df.rectly to Design Engineering management for dissemination to engineers. It also provides a mechanism to alert industry to ANO information.
The Electrical Drawing Upgrade Program provides for the as-built of Class IE
, switchgear, MCC and major control cabinet electrical drawings following field
]a walkdown efforts.
DESIGN ~AND ENGINEERING SUPPORT gm 1 s,_DET ITEM 2.1.5.1 - STATEMENT OF ISSUE
~-
Organizational and management changes at AP&L beginning in late 1987 had initiated broad' improvements in the previous poor design and engineering support to ANO.
Initial improvements focused on teamwork and communication between Engineering and ANO Nuclear Operations. These changes had split Nuclear and Fossil /llydro Design . Engineering, and Nuclear Design Engineering Management ' was changed to report ' to the nuclear vice president. Subsequent changes in early 1989 con-solidated Engineering at ANO '(except for Maintenance Engineering) and Nuclear l
. (~
Design Engineering at the Little Rock General Office (LRGO) under a single General Hanager reporting to the Nuclear Vir.e President. (Section 3.5)
ANO ROOT CAUSE N/A ANO RESPONSE TO DET ITEM 2.1.5.1 The DET recognized that- communications and teamwork within the Engineering Department and between Engineering and other ANO organizations has been improving since the 1987 and 1989 reorganizations. This 'has led to improved design and engineering support. This item is considered closed.
,r-(/ Reference DET ITEM 2.1.5.5.
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DET. ITEM 2.1.5.2.-' STATEMENT OF ISSUE 1
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,! _[U Engineering personnel were, for - the most part, competent and ' conscientious with '
expertise in.their discipline. There was, however, a lack of systems knowledge in ,
the system engineering group and the LRGO. Engineering had recently shown the >
capacity to. address complex technical problems in_a timely.and conservative manner. ;
once resources were. assigned and focused, as evidenced by' efforts related to the ;
high pressure injection (HPI) backflow event in early 1989. This effort was made i possible with strong contractor support. (Section 3.5.1) -
ANO ROOT CAUSE t- .
- Planning. Scheduling and Resource Requirements (III)
Program Related Issues (V)
ANO RESPONSE TO DET ITEM 2.1.5.2
- s The System Engineering Program will be fully implemented within ,the Operations !
Department. The System Engineering Program implemention was initiated within the "
Plant Engineerir.g group during January 1989. This program 'will provide a central focus on a system for all activities related to the assigned system. "0wnership" of plant systems will become focusedn and the appropriate engineering resources ;
will be involved in day-to-day activities relating to the system. =The Business ;
!'Q Plan provides a schedule to identify training needs in order to ensure that V systems have qualified engineers. System Engineering. qualification requirements are based, in part,-upon completion of this detailed systems training.
-The System Engineering Training Program will be designed to be consistent with
~INP0 Good Practices. It will focus on system-related-activities to-improve system performance, reliability and safety. The program is designed to provide an-effective method of retaining historical records on system performance and enhance individual- job satisfaction through increased- responsibility, j accountability and plant knowledge.
The Business Plan also defines improvements in the training program for
- Design Engineering. The system training for Design Engineering will become an '
integral part of the " Individual Development Plan" for Design Engineers.
. Reference the ANO Business Plan Project / Activity:
C.5 Engineered Operations D.7 ~ Training H.3' System Engineering Training s.
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' RESOURCES -
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's DET ITEM 2'.1.5.3 - STATEHENT OF ISSUE There were - a number of continuing weaknesses in design and engineering support.
The overall trend, except for staffing in Design Engineering, was improving.
Recruitment and retention of Design Engineering, staff were considered by manage-ment to be significant problems and hindrances to the success 'of improvement programs. (Section 3.5) ,
ANO h00T CAUSE. ,
Management Involvement and Leadership (I)
Planning, Scheduling and Resource Requirements (III)
ANO RESPONSE TO DET ITEM 2.1.5.3 The DET noted 'an improving- trend in Design Engineering, but recognized recruitment and retention issues as hindrances. to this trend and the. overall success of ~ Design Engineering improvement programs and support to the site.
ANO agrees that recruitment and retention issues require attention and resolution.
To this - end, Engineering and lluman Resources have begun the process to resolve A this problem by addressing root causes and implementing action to improve U recruiting, lluman Resources will support Engineering in resolving root causes for - overall retention, and recruitment issues. Appropriate actions will be implemented to resolve these problems. lluman Resources has recognized the immediate needs of Engineering to obtain and retain experienced engineers and has assigned additional resources (both site and corporate) to the task.
Engineering support to the site will -be improved by the relocation to the site of ~ Design Engineering before the end of 1990.- This will continue the trend of improvement ' noted by - the . DET, but may cause short-term impacts to personnel.
Significant = efforts are underway to minimize any potential personnel impacts due to the relocation. Much of the anxiety noted by the DET associated with this relocation was caused by the uncertainty of the relocation date and the subsequent inability to make definite plans for relocation. This was addressed by a recent announcement of a relocation date., Anxiety will be further reduced when relocation, recruitment, and retention plans are completed and communicated to affected personnel.
-Reference the ANO Business Plan Project / Activity:
D.2 Engineering Resource Plan D.3 Relocation of Design Engineering
.c G.2 Relocation Plan G.3 Recruiting and Retention K.6. Staffing Plan g
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2.1.5 4 DESIGN AND ENGINEERING SUPPORT d' ,1DET ITEM'2.1.5.4 - STATEMENT OF ISSUE y/}
'l' Morale was low among many nonsupervisory personnel. The reasons for low morale at 1
the _ LRGO included plans to move. to the site, pay scales (fossil vs nuclear and ]
contractors vs employees) and the large workload and backlog. The reasons at the '
N plant were partially due to . the large workload and backlog. .( Section 3.5.1) 3 - ANO ROOT CAUSE Management Involvement and Leadership (I)
- Plannir.g', Scheduling and Resource Requirements (III)
ANO RESPONSE TO DET' ITEM 2.1.5.4 Reduction of the engineering backlog has been identified as a project in the Business Plan. A project plan defining the extent of the backlog of different types, the prioritization (with regard to safety significance) and dispositioning methods,. the interfaces required, and the goals of reduction, is being develope,d.
Segregation of-the backlog has begun. Present plans call fot 4ditional temporary resources - to.. be. applied to this area, thus allowing ' the p manent . Engineering perform their normal functions.
staff- ts The systematic identificatidn, prioritization and resolution of the backlog, consistent with -the safety A significance- of the item, will improve the morale as' backlog pressures are
-(j relieved and routine activities are more fully resumed.
In addition, improvements in the' screening process for those items which initiate Desig'n Engineering project work have been identified and are under development.
These _ improvements will ensure that an engineering response is in fact needed to
-disposition an item.'
The DET also identified the perceived disparity of pay scales and relocation-anxiety as contributing to _ low morale in Design Engineering. Human Resources will evaluate these pay scale concerns.
The overall resources needed in Engineering to implement the Backlog Reduction
-Plan ~ and to effectivel'y address current and future workload demands are being
' developed in the Engineering Resources Plan.
ANO recognizes the problems associated with a long-term dependence on contractor expertise in terms of impact on morale and loss of project experience. However, at..the same time, there is: an appropriate role for the application of contractors
- l. - for special expertise needs, cyclic work load peaks, and emergent projects. An D overall ' Engineering Resource Plc.n has been developed to address, among other l: objectives, the reduction of dependence on contractors to an appropriate level'.
This plan - will establish work ad projections, staffing targets for full-time employees and- contractors, contractor reduction goals, and monitoring of workload / staffing requirements.
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L DESIGN AND ENGINEERING SUPPORT y_ DET, ITEM 2.1.5.4-(CONT'D)
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Refinements in and enhancements to the Engineering planning process and the required interfaces with other organizations are continuing. Roles and1 responsibilities of the organizations, a clear ~ definition of the workload priorities for the Units, and the inpact of shifting priorities are being emphasized. Proper planning of- this workload will improve the morale of non-supervisory personnel.
Reference DET ITEMS 2.1.1.10'and 2.1.5.6 for discussions on corrective actions _and trending.
Reference DET ITEM 2.1.5.3 for discussions on retention, recruitment, and relocation.
Reference the ANO Business Plan Project / Activity:
B.2 Imp'ove r Corrective Action Program D.1 Engineering Backlog Elimination D2 Eaaineering Resource Plan D.S.f -Engineering Improvement Programs-Corrective Action Program
, D.S.i Engineering Improvement Programs-Design Process Improvements G.3 Recruiting and Retention K.4 Contractor Utilization Study K.6 Staffing Plah
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. : DET ITEM 2.1.5.5 - STATEMENT OF ISSUE-
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' V )- Communications between Engineering and other AN0' organizations had improved as the 4
result; of programs such as the system engineer program, the 2-week schedule and .
the' 18_-month plan. c Communications' within Engineering and with other AN0' Depart-
ments were still weak in sorce. instances. (Section 3.5.2.)
+
.ANO ROOT CAUSE.
Safety Culture (II) 8- ANO RESPONSE TO DET ITEM 2.1.5.5 .
To provide better support an'd to facilitate ef fective, horizontal communication between the Engineering Department and other ANO organizations, the following changes have-been made, or'are planned.
Management representatives of the Engineering Jepartment participate in the
, daily plant meetings. These meetings provide a - forum for an effective exchange of information between organiza tions on a day-to-day basis.
During periods of high activity (i.e., outages, resolution of special
, issues), Engineering representative participates in the plan-of-the-day p, meeting with- operation and inaintenance management, a :
- The transfer of System Engineering to Operations will improve communication between site personnel and engineering personnel responsible for a specific system. This transfer is intended to improve and expedite engineering a support.-
- . The 2-week schedule and the' 18-raonth plan provide a mechanism to ensure proper communication and teamwork relating to .short. and long-term engineering activities. -The Engineering and Operations' interface to develop the 18-month-3 plan is explained in DET ITEMS 2.1.1'.7 and 2.'1.3.3.
- Relocation of ~ Design Engineering to the site will significantly improve communications both within Engineering - and between Engineering and other
-organizations.
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- DET ITEM 2.1.5.5 (CONT'D) f-_s
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The DET noted that communications within Engineering were still weak in some instances. To improve the vertical communications within Engineering, the follow-ing actions have been taken or are planned:
Communication of goals and objectives to ANO Engineering Department personnel u
(including the engineering elements of the Business Plan).
- Regularly scheduled and' conducted department meetings. *
- - Scheduled and conducted engineering management meetings.
Establishment of a communications committee within Engineering to supplement the normal communication. chain via line supervision.
Continued use of Design Engineering Directives to communicate management expectation to personnel.
Effective communications- between Engineering groups require constant monitoring and. management action to resolve issues as they arise. Communication of manaFe-ment expectations, discussion of trends observed and individual issues are addressed in the Engineering management meeting.
In summary, the department specific communication plan is being developed in conjunction with the overall Site Communication Plan to address these issues.
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Reference the ANO Business Plan Project / Activity:
C4 Engineered Maintenance C.5 Engineered Operations D.3 Relocation of Design Engineering D.9 Engineering Department Communications Plan K.3 Communications v
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DET[ ITEM 2.1.5.6'-STATEMENTOFISSUE The CRS initiated 11n 1988 was a significant improvement in problem identification and tracking of engineering problems. Prior to that, several systems were used that resulted. in different priorities and a lack of focus on significant safety issues.. Due in part to these problems, many events and problems were signifi-cantly late (months to years) in being reported to the NRC, and some cases went unreported. (Section 3.5.2) t Y
ANO ROOT CAUSE ,
Program Related Issues (V) 1ANO RESPONSE TO DET ITEMS 2.1.5.6 The DET roted .that the Condition Reporting System (CRS), initiated in May 1988, represented a signifi' cant improvement over the prior processes which *
. identified, reported, and tracked plant problems involvint equipment, personnel and pro: esses. . To ensure .the continued effectiveness of the CRS, ANO is committed to conservative reportability determinations and timely and quality ..,
responses through the LER process.
~
Additionally, revisions to the CRS procedure,
/~s _ which further impcoves timeliness of reporting, are currently being developed.
\j As' the CRS process evolves -'and matures, supporting; documentation for engineering evaluatione, root cause assessments, and. operability determinations.will be better-defined and established through use and monitoring, procedural revisions, and training programs. The full implementation of the System Engineering Program will also facilitate improved' quality and timeliness of CRS responses related to system
. concerns due to the consistancy of focus maintained by the System Engineer rela-tive to the-assigned systems. The completion of the Design Configuration Documen-tation (DCD) Program will also improve avallotle design basis information for use 3
in the CRS process.
Reference'DET ITEM 2.1.1.10 for discussions on Root Cause Analysis and l Condition Reporting System. l Reference DET ITEM'2.1.5.11 for discussions on DCD Program.
Reference the ANO Business Plan Project / Activity:
B.2 Improve Corrective Action Program l C.5- Engineered Operations !
D.5.f Engineering Improvement Programs-Corrective Action Program F.5 Licensee Event Report (LER) and 10CFR21 Improvement Program i
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DESIGN AND ENGINEERING SUPPORT:
- J DET ITEN 2.1.5.7 - STATENENT OF ISSUE-
- There was a- large backlog- of corrective action requests for Engineering. .The engineering staff responses to condition reports assigned to them were usually adequate except for timeliness. However, if engineering was not assigned the lead a.
for- a CR involving engineering problems, their involvement in operability determ- m.
inations , - root cause analyses and final resolution war sometimes weak due to both programmatic restraints and a lack of teamwork. (Section 3.5.2) ;
ANO ROOT CAUSE o ;
I Safety Culture (II)
. Program Related Issues (V)
'ANO RESPONSE TO DET ITEM 2.1.5.7 In' order to improve the engineering response to Condition Reporting Actions,-
programmatic enhancements to the CRS - Program -have been made.and are planned.
The full implementation of the System Engineering Program will enhance interfaces and teamwork resulting in. improved cognizance of activities not. specifically assigned to the System Engineer, but potentially impacting the assigned systems. 1 The CRS Program enhancements will 3 consist of focusing more management attention
"] - and priority on significant plant conditions, m<-re timely root ,cause determina-(V tions,'and recommended corrective actions. Thr t t actions will improve the time-liness'of the responses. The backlog of requetts for Engineering .is addressed in
' DET' ITEM 2.1,.5.4.
Reference DET ITEM 2.1.2.3 for discussion on operability determinations.
1
- Reference DET ITEM 2-1.5.4 for' discussion on Engineering backlog reduction. i
- Reference DET ITEMS 2.1.1.10 and 2.1.5.6 for discussion on corrective action, root cause, and trending, i
' RhferenceIETITEM2.1.5.5fordiscussiononcommunicationsandteamwork. -
Reference the ANO Business Plan Project / Activity:
B.2 Improve Corrective Action' Program
'C.5 Engineered Operations C.12.a Backlog Reduction-Corrective Maintenance D.1 .
Engineering Backlog Elimination D.5.f Engineering Improvement Programs-Corrective Action Program D.9 Engineering Department Communication Plan i- k. 4 6
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DESIGN AND ENGINEERING SUPPORT l
, \ DET ITEM 2.1.5.8 - STATEMENT OF ISSUE
'" t Issues identified in NPC or industry correspondence -were frequently not reviewed '
' adequately or documented in a - timely manner -by the responsible review group.
' Engineering involvement in the evaluation process was weak _due to prcgrammatic weaknesses, staffing deficiencies and lack of teamwork. ,(Section 3.512)~ ,
, s ANO ROOT CAUSE +
Management Involvement and Leadership (I)
Program Related Issues (V), '
9 t
ANO RESPONSE TO DET 11EM 2.1.5.8 ANO programs are being upgraded or revised to more effectively evaluate and utilize NRC/ industry information. The Technical Support and. Assessment Organization provides - initial review, assignment, and tracking of industry and-
- ANO operational experience to Engineering. Improvements are being implemented in the - review ~ of industry and ' in-house experience (e.g., vendor, regulatory and industry information) through critical' 'self-assessments- of performance and [
implementing , lessons learned. In . addition, r.anagement expectations with regard ,
- c. to interaction and -division of responsibility between Technical Support and {
D . Assessment and Engineering will be defined and communicated to appropriate t X,) personnel. The ANO Business Plan establishes those activities which will improve the assessments and use of this base of experience through dedicated, experienced reviewers, t
Engineering involvement in the assessment of industry experience will also improve through more active use of the Industry Experience Program. This program provides industry experience feedback within Design Engineering. The program will be-upgraded by ' the revision of design-related procedures which will' provide .direc-tions on the input and use of NRC and industry information. Additional training will be conducted to emphasize the effective evaluation and use -of this inforna-tion to improve Design Engineering programs. The. Engineering Resource Plan wiU consider resource requirements to adequately review' industry issues.
Reference DET ITE 2.1.1.10 for discussien on Industry Experience reviews.
Reference DET ITEM 2.1.5.5 for discussions on communications and teamwork.
Reference the ANO Business Plan Project / Activity:
B.4 Upgrade Use of Industry and In-House Event Reviews '
-D.2 Engineering Resource Plan D.11 Industry Experience
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!The- development- of new and- revised procedures for the coordination of-LRGO and ANO
_ activities and the' creation of the Modification Section had sigariicantly improved
'[? the =- design change and modification processes. A notable feature of the process was, a detailed critique of each campleted DCP. (Section 3.5.3) 4 ANO ROOT;CAUSE ,
N/A A: ;
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-ANO RESPONSE TO DET ITEH 2.1.5.9 This item is considered closed.
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Engineering -supervisors and' managers failed to ' fully recognize; the safety-significance of . SW ' system waterhammet < nno SW pump. snap ring problems or to
'3 -take adequate and aggressive compensatory and/or corrective actions. -(Section 3.5.4) y
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ANO ROOT CAUSE '
Safety Culture-(II)
Assessment, Trending, and Root Cause (IV)
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LANO. RESPONSE TO DET ITEM 2.1.5.10 ANO , agrees. that' the safety-significance of the potential for SW . system waterhammer was= not fully addressed in .a previous engineering study. The 1985
)
study, conducted by ANO, did not adequately address all technical details con-cerning the worst-case scenario for. system waterhammer. This study ' was also
' flawed because it concluded that no corrective action was warranted since the ,
, safety-related equipment was still capable of performing its intended function p following: a postulated waterhammer event and since no significant problems except minor mechanical joint leakage hed been experienced at 'ANO as a result of
,M lL 'waterhamder.- This deficient evaluatian and conch:: ion were the result of a lack' l U of. SW rystem knowledge in Engineering and poor communication interfaces between -
Engineering and perations.
This issue will be addressed by the development. of' improved systems training for f System and Design Engineers. The implementation of the System Engineer Program will improve communication and teamwork between. Engineering and Operations, improve- knowledge of system ' interactions and responses, and . ultimately result : in better quality-and timeliness in the development and review- of engineering studies.
y , by, Engineering, . Operations and Maintenance. Evaluation of this - specific water-
? hammer problem is ongoing.
. The' root' cause of ;the SW System snap ring problem was ANO management's failure 3 to-require an adequate technical basis for remedial action. Inadequate interfaces-u , between: Engineering and : Maintenance allowed a deficient condition to exist - and '
f remain unresolved. The improvements in - systems training and System Engineering-noted'~above will enhence.these interfaces. Also, the SW system responsibility was L turned overt to ~ the System Engineer in 1988. As . a . result, safety-significant i
a'ssessments have improved .and will continue' to simprove through enhanced system l -knowledge and accountability. The interaction of System Engineering with-L , Maintenance and Operations management will require the evaluation of. issues to the appropriate management level and will provide adequate technical basis for remedialiaction.
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Reference DET ITEM 2.1.5.12 for oeussions on SW.
Reference the ANO Business Plan Project / Activity: ,
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'. B.1 1soprove Root Cause Determination -
C.5 Engineered Operations D.7 Training D.9-- Engineering Department Communication Plan 3
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4 DESIGN AND ENGINEERING SUPPORT
), DESIGN CONTROL
' ' f DET:lTEM 2.1.5.11 - STATEMENT OF ISSUE
- i. Many- of the ongoing problems at ANO could be traced to the poor documentation and control of the design basis and associated design configurations. The deficien-cies were compounded by the lack of documentation , turnover f rom the A/E af ter construction and by- poor documentation of modifications during the first several
' years of operations. A major design basis documentation upgrade program was recently initiated. (Section 3.5.6) l ANO ROOT CAUSE l
Program Related Issues (V)
- ANO RESPONSE TO DET ITEM 2.1.5.11 L The 1990-1994 Business Plan includes _ several programs to improve the quality l , of ' design documents. A Design Configuration Documentation '(DCD) Program was !
l' initiated in , late 1987 in response to problems associated with the lack of design basis informat:.on, and a detailed DCD action plan was initiated in 1988. The
- goals of the prgram iricluded the collection and organization of design < documents, (3 preparation of system and topical descriptions, development of condensed sources
<V of design information, performance of detailed " vertical" reviews for verification i.
of accuracy and consistency, and implementation of a design configuration informa- i tion management systen to allow computerized access to all. potential users of design : information. In addition, Design Engineering involvement in the NUMARC _,
Design: Basis Issues working group assures that our program will be consistent '
with tudustry-wide' guidance, and that we will be apprised of emerging issues.
ANO recognized that as the design basis is - fully documented and upgraded, procc-dures and processes must be in place to maintain configuration control consistent with the design basis. Accordingly, a Configuration Management (CM) Program has been initiated to develop a CM policy and procedures, to verify physical config- '
urations of selected structured systems and components, and to train personnel on the importance and use of the CM procedures.
The Felf-Initiated _ Safety' System Functional Inspections (S3FI) Program provides ;
a _ means for thorough reviews of plant systems and should prove to validate DCD
' Program results and plant configuration issues.
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( ^S DET ITEM 2.1.5.11 (CONT'D)
LJ In addition to the design control programs described above, ANO has initiated several discrete programs to improve the design configuration documentation for several major systems and structures. These are identified in the Businc. s Plan as the Isometric Update Project (IUP), the Electrical Drawing Upgrade Project, and' the Structural Design Program (SDP), and the Plant Setpoint Control Program (PSCP)'.
The above-described programs to reconstitute and maintain design information are ongoing activities. Substantial resources will be dedicated, and thorough analyses will be conducted to assure proper implementation.
Reference the ANO Business Plan Project / Activity:
D.6.a Design Basis-Design Configuration Documentation D 6.b Design Basis-Isometric Drawing Upgrade D.6.c Design Basis-Electrical Drawing Upgrade ,
7- D.6.d Design Basis-Structural Design Program D.6.e Design Basis-Plant Setpoirt-Control Program D.10 Self-Assessment (SSFI)
D.12 Configuration Management & Control tT U
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~ ~ DET 1 TEM 2.1.5.12 - STATEMENT OF ISSUE
[ T The SW systems at ANO had a long history of problems. The response to some of these problems-nad been extensive, but was usually reactive in nature. The team h . identified several current examples of design and/or construction deficiencies; lack ~of design basis documentation; lack of configuration control; f ailures . to promptly evaluate industry feedback; procedural deficiencies; failures to perform root cause analyses; and a failure to fully recognize the significance of a "
safety-related issue and take prompt and eggressive corrective action. The Service Water Integrity Plan (SWIP) was a recent attempt by AP&L to address SW system problems in a ~ coordinated, - timely and proactive manner. (Section 3.5.4) ;
ANO RD3T CAUSE Management Involvement and Leadership (I)
Safety Culture (II)
'Assessmen*, Trending and Root Cause Analysis (IV)
Program Related Issues (V)
- ANO RESPONSE TO DET ITEMS 2.1.5.12 The DET identified concerns with ongoing programs relating to the Service Water (SW) systems at-ANO. In general, the NRC found that the SW improvement (3
NJ programs were reactive and prolonged. The SW Improvement Program started as an -
action >ian in 1980 as a response to clam fouling. Since that time, it has evolved t.o address other SW issues. The Service Water Monitoring Progian was added in 1984. The Service Water Integrity Program (SWIP) was initiated in 1986 and has objectives which are ongoing, partly in response to a recent NRC Generic Letter on SW - (GL 89-13), dated July 18, 2989. Hence, the program has evolved over time to review, maintain, repair, upgrade and monitor SW performance, Implementation of SWIP will ensure that SW objectives will be met. Responsibility to maintain SWIP was transferred to the System Engineer in 1988. This has assured ownership and accountability rad AN0's ability = to take prompt and effective corrective actions concerning SW 1ssues.
The DET also noted specific examples of SW problems. These problems relate to a number of issues which are addressed elsewhere in this response as follows:
- The lack of design basis documentation is addressed in DET ITEMS 2.1.5.11 and 2.1.5.14.
- The lack of configuration control is addressed in DET ITEM 2.1.5.11.
- The failure to promptly evaluate industry feedback is addressed in DET ITEM 2.1.5.8.
- The failure to perform root cause analyses for SW issues is addressed in DET E, ITEMS'2.1.5.6 and 2.1.5.10.
- The failure to fully recognize the significance of safety-related issues and I take proper corrective action is. addressed in DET ITEMS 2.1.5.10 and 2.1.5.14.
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~~., DET ITEM 2.1.5.12'(CONT'D)
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Reference DET ITENs 2.1.4.2, 2.1.4.3, and 2.1.4.7 for discussions on SW procedure deficiencies.
Reference the ANO Business Plan Project / Activity:
C.5 Engineered Operations D.6,a Design Basis-Design Configuration Documentation I
D.6.b Design Basis-Isoraetric Update Program (IUP)
D.6.c Design Basis-Electrical Drawing Upgrade D.6.d Design Basis-Structural Design Program I.1.a Chemistry-Service Water System s
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- - 'DET ITEM 2.1.5.13-- STATEMENT OF ISSUE l
2 Weaknesses in the AP&L valve program that raised operability questions included:
inadequate MOV design torque, deficient voltage calculations for direct current
- MOVs, recurrinn check valve failures, failure to perform engineering studies of check valve problems, and inadequate sizing of backup air supplies to air-operated valves. (Section 3.5.5.4)_
-~ANO ROOT CAUSE T
Program Related Issues (V)
ANO RESPONSE TO.DET ITEM 2.1.5 The DET noted that the '" Valve Program" was among the list of the licensee's improvement ' prcgrams. The DET reviewed the condition of the IEB 85-03 MOV-Program,. the SOER 86-03 check valve response, and two Generic Letter responses, GL 88-14 and GL 89-10(MOV's).
Although 1 significant efforts have resulted in a comprehensive MOV Program in response to IEB- 85-03, the DET pointed out a concern with the weaknesses in the ANO Valve' Program. ANO acknowledges these weaknesses and has initiated improve-
-m, ments as summarized below:
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The Design Engineering'- group responr.ible- for _ development of design' basis calculations of MOV. thrust and actuator setpoint limits cortinued to' expand the ;
. IEB 85-03 design scope to support Maintenance. The original 85-03 scope has been significantly expanded since mid-1986 to include several hundred valves in both Units'. ' Generic- Letter 89-10 will eff ectively add more valves to ~ the program,.
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but the existing program embraced most of the GL 89-10 requirements prior to the issuance'of the Generic Letter.
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The DET noted concerns with the delay. in modifying HPI valves to-remove them from the 100 cycle list. ~ Since ANO and Limitorque developed the 100 cycle concept in ;
1986, significant effort in testing actuators has resulted in the reevaluation )
.of nominal commercial rating of actuators by Limitorque. The 100 cycle designa-
.c tion: was viewed as a short-term condition by Design Engineering, and the number of 100 cycle ' actuators has- been reduced significantly by new Limitorque ratings, e and by. System Modifications.
As ; a . result of. the DET concern over DC MOV voltage calculations, DC MOV voltages were recalculated and no operability concerns were found to exist. Revised valve-9 specific or system-specific voltage calculations have been incorporated into the j design review of DC MOVs.
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/~'yDETITEM2.2.5.13(CONT'D)
'LJ The IO'ER 86-03 (check valve) response was noted by the DET as slow. In late 1989, work was initiated on the design review of check valves to meet SOER 86-03 requirements. The inspection part of the SOER 86-03 response has been in place for some time, and the design review scope should result in a full SOER 86-03 program by late 1990.
The Air-Operated Valve (A0V) issue was not a part of either t.he MOV Program or the SOER 86-03 Program. Since the DET, ANO has initiated through the ANO Business Plan, an action plan and schedule to address A0V issues.
Reference the ANO Business Plan Project / Activity:
D.5.a Engineering Improvement Programs-Air-Operated Valve Program (A0V)
D.S.d Engineering Improvement Programs-Design Engineering Support of ANO MOV Program D.S.m Engineering Improvement Programs-Upgrade Check Valve Program h
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('E DET ITEM 2.1.5.14 - STATEMENT OF ISSUE I
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Discrepancies existed between the circuits in a safety feature control panel and ;
the design drawings. One discrepancy would have resulted in two SW pumps failing I to restart following ESF actuation and a slow transfer from station power to offsite power. The cause of the miswiring appeared to be a failure to properly
. implement field modifications, lack of adequate QC during construction and I subsequent circuit modifications, failure to correct known wiring deficiencies J and an inadequate testing program to detect extraneous sneak circuits. No- I concerted effort existed at ANO to take effective and timely corrective actions !
to correct the as-built electrical deficiencies. (Section 3.5.5.5)
ANO ROOT JAUSE Safety Culture (II)
Program Related Issues (V)
ANO RESPONSE TO DET ITEM 2.1.5.14 As a result of the discrepancies noted in this finding by the DET, ANO expanded and accelerated its Electrical Drawing Upgrade Program. This represents an aggressive action to bring all major Class 1E electrical cabinets up to as-built
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status. Associated schematics, connection diagrams, and vendor internal wiring diagrams will be converted to a " smart" Computer Aided Drawing (CAD) System. This will make changes more efficient, improve readability and access, and minimize the potential for errors in field installations and subsequent design drawing changes.
The program requires identification, evaluation and resolution of discrepancies in accordance with the existing Condition Reporting System. This will be performed in concert with ongoing efforts to improve the material condition of ANO wiring /
control panels.
This item was ' also the subject of LER-313 89-028, an NRC violation, and enforce-ment conference, and subsequent correspondence. ANO concluded that the deficiency resulting in the violation existed and embarked on an aggressive trogram to assess the root cause and safety-significance. Prompt and effective corrective actions were implemented as outlined in our response to the violation. The Electrical Drawing Upgrade Program defined in Business Plan Section D.6.c was initiated to resolve this issue.
Reference the ANO Business Plan Project / Activity:
D.6.c Design Basis-Electrical Drawing Upgrade D.12- Design Basis-Configuration Management and Control
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DESIGN AND ENGINEERING SUPPORT DET ITEM 2.1.5.15 - STATEMENT OF ISSUE
- v. The Engineering Department had initiated numerous improvement programs. Some '
initiatives suffered from a protracted schedule and a lack of priority and management attention, such as the PM and lubrication programs. The scope of a problem continued to grow in some cases and this also contributed to delays in come programs, such as resolution of the original as-built drawing and calcula-tional discrepancies for. Class 1 piping and supports. Other initiatives reflected recent- generic industry problems, such as the secondary pipe wall thinning program. Finally, some initiativer, were proactive in nature such ar. the safety system functional inspections. The resources required to support improvement programs represented approximately 18 percent of the AP&L nuclear engineering staff and 50 percent of the large engineering contractor staff. (Section 3.5.6.)
ANO ROOT CAUSE Management Involvement and Leadership (I)
Planning, Scheduling and Resource Requirements (III)
Program Related Issues (V) .
ANO RESPONSE TO DET ITEM 2.1.5.15 O ANO recognizes that some Engineering Department initiatives suffered from a
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protracted schedule and a lack of priority and management attention.
Past planning of Engineering improvement programs has not been visibly integrated into the- total Engineering workload. Other dep 3rtments could not assess the effect upon the existing Engineering workload caused by their shifting priorities or ' adding- requests for Engineering work. The ' Engineering Planning Process includes resource planning and a workload planning process (i.e., 18-month schedule and 2 week look ahead) and is being revised to require interaction among the major department managers (Operations, Maintenance, and Engineering) in set-ting priorities and assigning new work. Any shift in priorities or scope will be considered in the context of ongoing work, including the Engineering Improvement Program.
Several programs have suffered from inadequate scope definition or real scope growth as the program progressed. This manifested itself as a schedule delay.
To alleviate this problem, Engineering is requiring a firmer definition of scope and schedule, and a compatible progress reporting format of the important programs. This will allow more focused management attention to detect delays and effect changes in resources or methods to improve schedule performance.
Some efforts such as the Preventive Maintenance and Lubrication Programs had been i erroneously assigned to Engineering. This assignment created unnecessary
! organizational interfaces that were cumbersome and fostered a lack of teamwork and ownership by the ultimate user. These efforts have been reassigned
[ ,s to the appropriate organization.
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h DESIGN AND ENGINEERING SUPPORT 3j<DET ITEM 2.1.5.15 (CONT'D) t
~' The Business Plan identifies the important ongoing engineering improvement programs.
Frequent; review of program status and open issues by Department and Corporate mange-ment is scheduled. .
Reference the ANO Business Plan Project / Activity:
- ,3 . C.5 Engineered Operations '
D.2 Engineering Resource Plan D.5.1 Engineering Improvement Programs-Design Process Improvements l
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RESPONSE TO SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE SALP ITEMS l
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, 3.1 PLANT OPERATIONS );
s SALP-. ITEM IV.A.3.b.1~- STATEMENT OF ISSUE:
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Provide management guidance to operators and establish consistent policy on logs, I valve lineups, and independent verification requirements. l 1
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Reference DET ITEMS 2.1.1.2, 2.1.1.7, 2.1.2.5, 2.1.2.10. :i Reference DET ITEMS above for ANO Business Plan Project / Activity. 1 i
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r'~) SALP ITEM IV.A.3.b.2 - STATEMENT OF ISSUE- l i , l
%J Improve operations department interface with other departments. I l
l ANO RESPONSE TO SALP ITEM IV.A 3.b.2 The conduct of operations and conduct of maintenance procedures has been revised. One of the key philosophies of these- revisions was to improve communications and- interfaces among various departments. In addition, ANO has recently implemented an- organizational realignment which established an-independent, unit-specific organization. We have already seen benefits from the realignment. Communications and interface among the various departments will be enhanced.
A position designated as Assistant Operations Manager has been established.
This individual serves as the interface between Operations and Engineering.
To improve communication between Operations and the Planning and Scheduling groups, an Operations Supervisor for each unit has been designated as the working interface between Operations and Maintenance. The duties of the Operations / Maintenance Coordinator include providing operational input during job order planning, ensuring- appropriate priorities are assigned to job orders, and coordinating maintenance activities to appropriate plant conditions. Better control and coordination of work activities is being accomplished with this involvement with planning and scheduling
(~' personnel.
A>t Reference DET ITEMS 2.1.1.7, 2.1.1.8 and 2.1.2.4.
Reference DET ITEMS above for ANO Business Plan Sections in addition to the following Business Plan Project / Activity:
C.5 Engineered Operations C.7 Maintenance Optimization C.10 Professionalism D.9 Communications K.5 Organizational Culture
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A SALP ITEM IV.A.3.b.3 - STATEMENT OF ISSUE
!j l Increase the reliability of the decay heat removal system and the accuracy of RCS level indication.
l ANO RESPONSE TO SALP ITEM IV.A.3.b.3:
Increased attention has been given to reduced Reactor Coolant System (RCS) inventory operations on both units during the last year. This has resulted in significant improvements in RCS level monitoring end in the overall awareness of the special requirements of reduced RCS inventory operations.
The RCS was drained down during the Unit 1 Mid-Cycle Outage in 1989 for maintenance activities. Calibrations and cross-checks of the RCS level indicators were performed ano the evolution was well controlled. Items from Generic Letter 88-17 and enhancements for Unit I have been initiated with all pending items to be completed in the 1990 Unit 1 Refueling Outage.
During the Unit 2 1989 Refueling Outage, a plant change was performed which corrected inaccuracies in an RCS level indicator and diminished the potential for the formation of loop seals in the Tygon tubing used for RCS level indication.
Corrective maintenance was performed during three RCS drain down windows.
Calibrations and cross-checks were performed on the RCS level indicators during these evolutions.
Plant management is continuing to place emphasis .on Decay Heat Removal (DHR) operations and successful results were noted by reduced inventory operations in late 1989. Both units are evaluating the removal of the automatic closure interlock on the decay heat removal suction line valves to increase the reliability of the DHR system..-The operators on the Unit 1 DHR flow control valves CV-1428 and CV-1429 will be replaced during Unit 1 Refueling Outage scheduled for October 1990.
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(7 3.1 PLANT OPERATIONS
,s LSALP ITEM IV.A.3.b.4 - STATEMENT OF ISSUE : '
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of equipment / system operability requirements. >
i ANO RESPONSE TO SALP ITEM IV.A.3.b.4:
' Reference DET ITEM 2.1.2.3. I I Reference-DET ITEM above for ANO Business Plan Project / Activity
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yf- e SALP ITEM IV.A.3.b.5 - STATEMENT OF ISSUE t A ) '
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Establish higher. standards for' station material condition'and housekeeping.
~ANO RESPONSE TO SALP ITEM IV.A.3.b.5:
c: Reference DET ITEMS 2.3.2.7 and 2.1.2.8.
Reference-DET ITEMS above for ANO Business Plan Project / Activity C.3 Plant Material Condition / Housekeeping i C.12.a. Backlog Reduction-Corrective Maintenance i
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-}SALPITEMIV.A.3.b.6'-'STATEMENTOFISSUE.
Continue effortr. to reduce the backlog of minor deficiencies,-particularly control
' room deficiencies.
-ANO RESPONSE TO SALP ITEM IV.A.3.b.6 ,
Re'ference DET ITEM 2.1.2.8. ,
Reference DET ITEM above for ANO Business Plan Project / Activity.' ..$
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3.1 PLANT OPERATIONS
- j- ; SALP ITEM IV.A.3.b.7 - STATEMENT OF ISSUE Continue the aggressive " black board" concept, particularly.for Unit 1.
ANO RESPONSE TO SALP ITEM IV.A.3.b.7
'A " black board" was achieved in January 1990. The " black board" concept for both units will continue to be pursued. Work will be ongoing to maintain a consistent " black board" for the control room annunciators; however, this item is considered to be complete.
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("T.8ALPJITEM IV.A'.3.b.8---STATEMENT 0F ISSUE q).:
. Improve' control'of safety-related equipment status.
ANO RESPONSE TO SALP ITEM IV.A.3.b.8
-Reference'DET ITEMS 2.1.1.7, 2.1.1.8, 2.1.2.5, 2.1.2.70 and SALP ITEM <
IV.A.3.b 2.
Reference DET ITEMS above for ANO Business Plan Project / Activity.
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l 3.2 RADIOLOGICAL CONTROLS C sSALP ITEM IV.B.3.b.1 - STATEMENT OF ISSUE k,_.) ,
1 Continue ongoing efforts to improve the radiological controls area and stress continued improvement in procedural compliance and self-identification of problems.
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ANO RESPONSE TO SALP ITEM IV.B.3.b.1 l l
ANO has implemented various radiological programs that have proven to be effec- l tive. There have also been many improvements made in procedural compliance. Some '
of these efforts include: enhanced and consolidated procedures, improvements to the Radiation Worker Manual and a management awareness of ensuring ' personnel comply with procedures. ,
1 The above actions are implemented. Continuing emphasis is planned - to maintain l awareness of personnel procedure compliance. Improvements will continue to 1 be made in identifying personal performance expectations and accountability, i l
Reference the ANO Business Plan Project / Activity: '
I.2.f Health Physics-Procedure Upgrade 1
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k 3.2 RADIOLOGIC /L CONTROLS f ] SALP ITEM IV.B.3.b.2 - STATEMENT OF ISSUE
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Reduce radiation area access restrictions for areas that require routine access by operations personnel.
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ANO RESPONSE TO SALP ITEM IV.B.3.b.2 l The example given t.o- illustrate this concern was access to the Unit 1 Emergency Diesel Generator . (EDG) rooms requiring passage through a radiation area. This area now has access that does not require any radiation controls for entry.
Other areas in the turbine building have been identified which are posted as !
radiation areas and require routine operator access, such as condensate demineralizers on Unit 1. -Those areas which require routine access by operations personnel and have radiation area access restrictions will be evaluated for possible alternatives to reduce the radiation levels. Appropriate action will then be taken.
Reference the ANO Business Plan Project / Activity:
-I.2.d Health Physics-ALARA Awareness rh a
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3.2 RADIOLOGICAL CONTROLS TT) SALP ITEM IV.B.3.b.3 - STATEMENT OF ISSUE 5
v Continue efforts to reduce overall exposure and the number of skin contaminations.
ANO RESPONSE TO SALP ITEM IV.B.3.b.3 ANO has enhanced its ALARA Awareness Program. This emphasizes ma'nagement's concern about ALARA practices and also brings its concerns to the employees. The improvements have made a coticeable reduction in personnel exposure. In addition, contamination reduction efforts already in place have reduced the number of contamination events from approximately 2900 in 1988, to approximately 500 in 1989. Procedures have been revised to provide additional guidance for tracking and trending of Personal Contamination Events. ANO has dedicated cesources to implement and maintain this program. An increased effort results in identifying and correcting root causes to contamination problems. This involves cleaning up areas, changing Health Physics or radiation working practices, and using disciplinary measures as appropriate. ANO has also initiated estimating exposures for refueling outages. The estimated exposure for 1989 Unit 2 Refueling Outage was 308 rem. ANO established a more challenging goal of 270 rem for that outage.
Upon completion of the outage, the actual exposure was 288 rem, with 20 rem-attributed to work added during the course of the outage. This reduction was the recult of enhanced monitoring, awareness, planning and scheduling of the outage work.
f) ANO has implemented and revised various programs to assist in controlling
, '- exposure and contamination. The Hot Particle Program has been' revised to improve work control, establish a tracking system, and improve the dose evaluation process.
The improvements- in the Hot Spot Program . instituted flushing practices on various syste:ns to reduce radiation hot spots. In addition, an aggressive effort has been implemented to maintain decontaminated spaces in the plant. These efforts include awareness training for employees, improved radiation practices and advanced worker radiation control practices.
The programs and practices in place are effective in reducing overall exposure and the number of personnel contaminations. These programs will be monitored to ensure that they continue to meet the goals established for ALARA.
l Reference the ANO Business Plan Project / Activity:
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3.3 MAINTENANCE / SURVEILLANCE 3 ,
/SALPITEMIVC3b1 . . . -. STATEMENT OF ISSUE 1
Establish' effective corrective actions for declining trend in TS surveillance 1
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-performance. These actions should be effective. in significantly reducing the numbers of missed surveillances, as well as ensuring that procedures and personnel are sufficient for adequately implementing surveillance requirements.
ANO RESPONSE TO SALP ITEM IV.C.3.b.1 The DET and SALP both noted that there was a declining trend in Technical ;
Specification performance, such as missed surveillances, and that procedures-and. . personnel are sufficient for adequately implementing surveillance requirements.
During the period the DET- and SALP were conducted, no one organization had the sole responsibility or ownership for the entire Surveillance Tests Program. This lack of ownership and continuity resulted in _several surveillance tests being missed. As a result of the recent organizational realignment, .the Technical ,
Specification Surveillance Group has been created and reports to the Manager, Nuclear Operations Standards. The responsibility of this group is to track the Technical Specification Surveillances and ensure they are completed as scheduled. '
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~ This will also provide a sense of ownership in this group ensuring these surveil-
, lances are conducted as scheduled.
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Another task of this group is to ensure that the procedures required to implement the program are- developed and implemented. As for the plant procedures,
- management has instilled a sense of professionalism in the plant personnel.
Accepting ' the fact that a procedure may have some deficiencies is no longer a
. tolerated practice. Plant personnel have taken proactive steps to ensure procedures 'are correct prior to using them.
Reference DET ITEM 2.1.4.2 for further discussions on the Technical Specification
- Surveillance Group.
Reference DET ITEM above for ANO Business Plan Project / Activity, r
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3.3 MAINTENANCE / SURVEILLANCE SAI.P ITEM IV.C.3.b.2 - STATEMENT OF ISSUE f
Improve interface between - maintenance and other departments, particularly with the engineering department.
ANO RESPONSE TO SALP ITEM IV.C.3.b.2 The recent organizational realigan ent has provided unitization of the various line organizations. This unitization will lead to enhanced communications not only between Maintenance and Operations, but to other supporting organizations as well. Further enhancement of communications is'provided through the relocation of the Corporate Nuclear Support organizations to the plant site. This relocation will facilitate face-to-face interactions between all supporting organizations.
Reference DET ITEMS 2,1.3.3 and 2.1.5.5 for further discussions on communica-tion and interface between various departments.
Reference DET ITEM above for ANO Business Plan Project / Activity. ,
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3.3 MAINTENANCE / SURVEILLANCE
-[^\SALPITEMIV.C.3.b.'3-STATEMENTOFISSUE- l
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Implement effective equipment failure trending and improve equipment failure \
analysis capabilities.
ANO RESPONSE TO SALP ITEM IV.C.3.b.3 The work closure _ activities, including equipment _ history and trending, will be :
expanded to_ address the specific deficiencies in retrieval of equipment history, ,
generation- of trend information, and equipment failure analysis. In order to '
enhance the use. of failure trending and improve equipment failure analysis, ANO-has restructured the organization to dedicate management, Engineering, Planning iand Scheduling; and Maintenance crafts-to each unit.
Reference DET -ITEMS 2.1.1.10, 2.1.3.3, and 2.1.4.3 for . further discussions - on - i
, equipment failure trending and equipment failure analysis. '
Reference DET ITEM above for ANO Business Plan Project / Activity. !
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3.3 MAINTENANCE / SURVEILLANCE SALP ITEM IV.C.3'.b'.4 - STATEMENT OF ISSUE Improve the material control program.
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, ANO RESPONSE TO SALP ITEM IV.C.3.b.4 ANO has taken several steps to improve the Material Control Program. These improvements not only address and respond to concerns stated in the SALP and DET, but also will assist in the overall scope of backlog reduction.
Materials Management has currently undertaken the task of evaluating shelf life requirements for stocked materials. An effective Shelf Life Program is currently being implemented that includes the procurement, storage, and control of limited ,
life items. . Stock material currently in the warehouse is being reviewed to '
identify and disposition expired shelf life items, in addition to determining the shelf life applicability. The procurement process identifies and establishes shelf life requirements for safety-related equipment. This process prevents the inadvertent use of expired shelf life items.
The Commercial Grade Dedication Program has been established. Effective January 1, 1990, all commercial grade procurement at ANO is conducted using a procedure that contains proscriptive guidance consistent with the EPRI NCIG-07 Document, c\
k) Additional details concerning this ' item are discussed in DET ITEM . : . ? 4 with implementation schedules and performance measurements identified in ANO Business Plan Section E.4, " Commercial Grade Dedication Program" and E.5, " Shelf Life".
Reference DET ITEM above for-ANO Business Plan Project / Activity.
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'i 3.3 MAINTENANCE / SURVEILLANCE E: SALP ITEM IV.C.3.b.5 - STATEMENT OF ISSUE
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Reduce the backlog of maintenance work.
ANO RESPONSE TO SALP ITEM IV.C.3.b.5 ANO has taken steps to reduce the current backlog of maintenance work. Two main factors contributing to the backlog are the lack of resources and availability of spare parts. The approved 1990 budget provided additional positions in the Main-tenance area for Maintenance Engineers and I&C Technicians. Active measures have been taken to fill these positions.- In addition, an organizational realignment has taken place which now provides dedicated support organizations to each unit.
Two of these dedicated departments are Maintenance and Planning and Scheduling.
This realignment will assist in the reduction of Maintenance backlog by unit-specific priorities. Another step - that has been taken is the more efficient utilization of the Maintenance craft. During non-outage periods, the Maintenance crafts typically worked the day shifts. This created various problems and strained operations resources to support tagging and administrative needs in order for the craft personnel to perform needed work. 'This also contributed to the increased backlog problem. ANO recently successfully negotiated with the union to establish two shif ts of Maintenance crafts per day to support the plants.
- This will greatly assist in the overall goals to reduce Maintenance backlog.
s As stated in SALP ITEM IV.C.3.b.4, DET ITEM 2.1.3.4, ANO Business Plan Sections t
) E.4, and E.5, ANO has taken aggressive steps and implemented programs in Materials Management to address the spare parts issues.
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i 3.3 MAINTENANCE / SURVEILLANCE
-m SALP-ITEM IV.C.3.b.6 - STATEMENT OF ISSUE
)
Complete the maintenance organizational restructuring.
ANO RESPONSE TO SALP ITEM IV.C.3.b.6 ANO has implemented a maintenance organizational realignment which provides dedicated line organizations to each unit. The Maintenance Organization has, for- the most part, implemented this realignment. Some interface details, procedure updating to reflect the realignment responsibilities, and various cleanup issues remain. These are expected to be completed by the third quarter of 1990.
Reference DET ITEM 2.1.3.1 for additional details concerning the realignment.
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3.3 MAINTENANCE / SURVEILLANCE ThSALPITEMIV.C3.b.7-STATEMENTOFISSUE V
Complete the PMIP.
ANO RESPONSE TO SALP ITEM IV.C.3.b.7 Nuclear Operations Standards has taken actions to complete the Preventive Main-tenance Program (PM) procedures for Safety-Related, Fire-Related, and Special Requirements (Q, F, and S) Procedures. ANO made a commitment to the NRC to have' this completed in September, 1990. The PM Program will include all safety-related equipment. In developing these procedures, manufacturer recommendations and industry experience to establish maintenance frequencies for PMs were evaluated. Increased management attention and oversight, through the recent organization realignment, has been directed to ensure the commitment date is met.
In addition, ANO is currently performing a Staf fing Study. One of the areas being evaluated is the Maintenance Organization to ensure appropriate resources are available to implement required programs and activities such as the PM
. Program.
Reference DET ITEM 2.1.3.6.
1 Reference the ANO Business Plan Project / Activity:
C.2 Preventive Maintenance
(,_D K.6 Staffing Plan x_/
r)
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I 3.4 EMERGENCY PREPAREDNESS
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. r 'i SALP ITEM IV.D.3.b.1 - STATEMENT OF ISSUE The present level of management attention to the implementation of the emergency preparedness program should be maintained.
ANO RESPONSE TO SALP ITEM IV.D.3.b.1 Management's involvement in this area will continue at the present level . For example, the qualified staff for administering and implementing the plan will be maintained. Two positions in this group, one of which was the group supervisor, have recently been vacated and were promptly filled. ANO management will continue to maintain a full staffing complement and will aggressively pursue filling vacancies from within the ANO organization or _from_ outside sources, if.
necessary, to maintain a high level of competence.
The inspectors identified four exercise weaknesses during the last drill exercise (REF. NRC Inspection Report 50-313; 50-368/89-12). The following is the current status of their resolution:
- Licensee delayed notification to the State after declaration of the- Site Area Emergency.
ANO evaluators also recognized the delay as a weakness and have determined
?-s'j the root cause to be the Arkansas Department of Health's (ADH) policy for the Technical Operations Control Director (TOCD). This policy requires the TOCD-d to retain command and control while in transit to ANO. The ADH policy methodology has been revised to provide two ADH teams. One team will remain at the Little Rock facility for command and control of issues while ADH personnel are in transit to ANO. Once at ANO, the command function will be transferred as appropriate. This will ensure that communication between the State and the EOFD will be available at all times. No plan change was re-quired; however, a procedure was developed to implement the new methodology.
This procedure was implemented on November 14, 1989.
- Poor radiological practices used by the medical rescue team resulted in cross contamination of personnel. In addition, there was an uanecessary delay in notifying the medical team that the ambulance had arrived and was waiting for the victim.
Emergency medical personnel have received training or, radiological protection practices. These training sessions are one week in duration. Five of these training sessions were given during the period July - August 1989._ A two-hour session of the training was devoted to radiological protection decontamination practices.
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Additionally, training: has been completed for Security personnel which addresses escorting an ambulance on site.
- Organizational structure used in the OSC during the exercise was different than that required by EPIP Procedures in that the assistant to the OSC Superintendent is not included in the organization described in the EPIPs.
Based on this weakness, ANO evaluated the ' sta f fing levels of certain key-ERO positions to determine the need for assistant positions. Subsequently, a Radiological / Environmental Assessment Manager (REAM) Assistant position was added. The REAM Assistant position will require training similar to the REAM position. Wording changes have been made to the OSC Superintendent and Emergency Operations Facility Director (EOFD) description of duties. This change will permit the use of an assistant to these positions if deemed necessary. The assistants will typically be qualified to fill the position being assisted. In the event that additional assistant positions are needed, they will be incorporated into the appropriate EPIPs on an "as needed" basis.
- Some incongruities during the exercise were noted which detracted from the realism and free play of the exercise.
The 1990 Radiological Emergency Preparedness Exercise Scenario Development
,, Committee is addressing this item. AP&L attributes-the prompting committed "j by one exercise controller to the controller's inexperience. The 1990 Exercise Development Committee, which is responsible for controller training, will include separate introductory training for those controllers with minimal or no experience in this area.
The ANO Emergency Plan is scheduled for revision following ' the annual drill, currently scheduled for March 1990.- This revision to -the Emergency Plan will require; staffing the Emergency Operations Facility (EOF) within one hour of the declaration of an ALERT (the current revision staffs the EOF upon declaration of a Site Area Emergency). This will ensure the full Emergency Response Organization (ERO) is available earlier in the course of the emergency. The revision will also include changes to the ERO staffing including the creation of certain new positions, deletion of other positions whose functions will be incorporated into existing or new positions, and title changes for certain positions for consistency and clarity of position function. These changes will enhance the ERO's ability to-respond to emergencies at ANO and will take into consideration the relocation of Little Rock General Office personnel to the site.
. Reference the.ANO Business Plan Project / Activity:
H.10 Revise Emergency Response Organization to Reflect the New Organization 1
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3.5 SECURITY a
- )SALPITEMIV.E.3.b.1-STATEMENTOFISSUE Provide strong support to the reconstituted security prograin.
ANO RESPONSE TO SALP ITEM JV.E.3.b.1 ANO.will continue its strong support to the Security Program. Evidence of this support is the enhanced training being provided to the security contract staff.
To date, 11 of the 20 contract security supervisory personnel have completed the two-week supervisory skills training. ANO security personnel and other ANO employees will be scheduled for supervisory training in 1990 as classes are available. In addition to the supervisory training, security personnel are currently receiving defensive tactics training.
Support is also provided to becurity by ANO personnel in the area of awareness of station security requirements; e.g. , maintenance of vital area barriers. Design engineers and maintenance and modifications personnel are- aware of the potential impact of their activities on security requirements. Although two violations were cited during this SALP period for inadequate vital area barriers, the root causes were based on events that occurred in 1986 and 1980, respectively. The first violation concerned a latch that was improperly secured in 1986 and not discovered until 1988. Maintenance personnel are currently much more aware of !
security requirements, as evidenced by the incident discussed in Safe 6uards Event n Report (SER) 89-801-00 in which a maintenance craftsman found a fan housing
) improperly secured and immediately notified security. The second violation i occurred due to a design deficiency in a 1980 modification. The Shift Supervisor '
consulted the Security Department prior to taking the action which was later determined by Security te have resulted in degradation of the barrier, as dis-cussed in AN0'_s response dr.ted November 3,1989. Both instances demonstrate that there is an awareness of security barriers at ANO. Currently, awareness of station security requirements is provided by the initial General Employee Training which is given to all unescorted personnel and is enhanced by annual retraining.
Security performs vital area inspections which include inspecting vital area barriers for deficiencies / violations. Deficiencies are noted, logged, corrected and reviewed for indication of repeat problems. Root cause evaluations are performed as _ applicable and compensatory measures are implemented as required.
Security reqairements will continue to be included in the General Employee Training and the annual retraining. Current issues will be incorporeted into this training as the need for additional training is identified.
Reference the ANO Business Plan Project / Activity:
I.3.a Security Perimeter Upgrade 1
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' j SALP ITEM IV.E.3.b.2 - STATDfENT OF ISSUE Review the overall security force staffing to ensure that current staffing is adequate for implementing additional requirements such as the new fitness for duty rule.-
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ANO RESPONSE TO SALP ITEH'IV.E.3.b.2 ANO currently has fully staffed, outside of security, the necessary positions to !
implement the Fitness For Duty (FFD) rule. Prior to permanently filling - the positions,- an ANO Security- Supervisor temporarily oversaw the . upgrade and implementation of the FFD Program. As noted in the SALP, this temporarily vacated ,
a supervisory position in the security area. As a result, some deficiencies became apparent. These deficiencies focused arounc the areas of planning, -
personnel oversight, and added pressure on security operational determinations.
The Security Supervisor has returned to his security position to assume his original duties less the responsibility associated with FFD. This will return the ANO security management staff to its full complement, r
AN0's Fitness For Duty Program is fully implemented.
' Additionally the security oversight position filled in September 1987 was vacated
~due to ' turnover in March 1989. Efferts are underway to staff this position.
,-s j Re 'arence the ANO Business Plan Project / Activity:
10 6 Staffing Plan
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3.5 SECURITY
[;jISALP ITEM IV.E.3 b.3 - STATEMENT OF ISSUE Ensure that a strong maintenance program is developed to support the new physical security systems.
ANO RESPONSE TO SALP ITEM IV.E.3.b.3 ,
The Security Perimeter Improvement Project has been completed. In addition to protected area perimeter improvement, thia project involved replacement of- the CAS and- SAS consoles. Revision 17 dated January 2, 1990, to the ANO Industrial Security Plan included the maintenance guidelines which have been adopted to support security. To support the activities, a maintenance group of Instrumenta-
- tion and Control Technicians has been dedicated to perform security maintenance.
Preoperational testing has been completed and the system turned over to recurity. ,
Reference the ANO Pusiness Plan Project / Activity:
1.3.b Security Equipment Maintenance L)
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'3.6 ENGINEERING / TECHNICAL SUPPORT-
' ~SALP ITEM IV.F.3.b.1 - STATEMENT OF ISSUE
~
Prioritize efforts to ensure that-improvement programs that will make the greatest contribution to safety will be implemented first.
LANO RESPONSE TO SALP' ITEM IV.F.3.b.1 +
. Reference DET ITEM 2.1.5.4 and 2.1.5.15.
Reference DET ITEMS above for ANO Business Plan Project / Activity.
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3.6 ENGINEERING / TECHNICAL' SUPPORT-k , -)ySALP ITEM IV.F.3.b.2 - STATEMENT OF. ISSUE Establish realistic schedules for improvement programs.
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-l ANO RESPONSE TO SALP ITEM IV.F.3.b.2 Reference DET ITEM 2.1.5.15. J Reference DET ITEMS above-for ANO Business Plan Project / Activity.
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'3.6 ENGINEERING / TECHNICAL SUPPORT i
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)SALPITEMIV.F.3.b.3-STATEMENTOF-ISSUE ,
Assess the - adequacy of engineering department resources to perform the routine workload as well as support the various plant improvement programs.
ANO RESPONSE TO SALP ITEM IV.F.3.b.3 il- Reference DET ITEMS 2.1.5.3, and.2.1.5.4, and 2.1.5.15.
Reference the DET ITEMS above for ANO Business. Plan Project / Activity.
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ISALPITEMIV.F3.b.4-STATEMENTOFISSUE
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Continue to improve engineering department interface.
ANO RESPONSE TO SALP ITEM IV.F.3.b.4 Reference DET ITEMS 2.1.5.1 and 2.1.5.5.
Reference the DET ITEMS above for ANO Business Plan Project / Activity.
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--3.6 ENGINEERING /TECHN! CAL SUPPORT SALP ITEM IV.F.3.b.5 - STATEENT OF ISSUE 9
. . Fully implement the System Engineer Program during the next SALP period.
p ANO RESPONSE TO SALP ITEM IV.F.3 b.5 Reference DET ITEMS 2.1.3.1, 2.1.5.1, 2.1.5.2.
Reference the DET ITEMS above for ANO Business Plan Project / Activity.
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l 3,7 SAFET.' ASSESSMENT / QUALITY YERITICATION 1
)SALPITEMIV.G.3.b.1 STATEMENT OF ISSUE l Reduce the condition report backlog while improving the condition reporting system, with emphasis on thorough root cause determinations and thorough ;
corrective actions for significant events defined in the Licensee's Progran.. 1 1
ANO RESPONSE TO SALP ITEM IV.G 3.b.1 Efforts are ongoing to reduce the backlog associated with Condition Report Corrective Actions. The vast majority of these items is associated with opera-tions and maintenance actions (approximately 60 percent) and with engineering actions (approximately 30 percent).
Reduction of the engineering backlog is included as a project in the Business plan and encompasses the backlog associated with Condition Reports. A project ,
plan is being developed which will define the extent of the backlog, the i prioritization and dispositioning methods, the interfaces required, and the goals
- of reduction. Priorities will be established consistent with the safety significance of the item. (Reference DET ITEM 2.1.5.4.)
The operations backlog is mainly associated with procedure revisions. Most of ,
these issues will be resolved as part of the Procedures Upgrade Program, currently in progress for both units.
C/ The backlog of corrective maintenance items has been recognized as an area of concern and is being addressed by a variety of activities such as the unitization of maintenance personnel and planning and scheduling personnel, categorizing the backlog, and increasing the visibility of work on material hold and engineering hold. (Reference DET ITEMS 2.1.3.1 and 2.1.3.4.)
Actions to improve the root cause determinations and thorough corrective actions for significant events include conducting training, adding additional reviewers to ;
the In-liouse Events Analysis staff, and obtaining an INPO reverse: loanee to assist in training and establishing effective assessment practices. (Reference DET ITEM >
2.1.1.10.)
Reference ANO Business Plan Project / Activity' B.1 Improve Root Cause Determination B.2 Improve Corrective Action Program C.11.a Procedures Upgrade-Operations C.12.a Backlog Reduction-Corrective Maintenance D.1 Engineering Backlog Elimination
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3.7 SAFETY ASSESSMENT / QUALITY VERIFICATION
-(v)SALPITEMIV.G.3.b.2-STATEMENTOFISSUE Improve site departmental interfaces.
ANO RESPONSE TO SALP ITEM IV.G.3.b.2 This section of the SALP report specifically discussed the impact of interdepart-mental communication problems on the process of preparing Licensee Event Reports (LERs). To address this concern, the Condition Reporting System (CRS) procedure is being revised to include requirements for identification of the root cause and corrective actions early in the LER process. This will ensure that LER events are evaluated and submitted in a timely manner. Enhanced communications (e.g.,
through reports, reviews, groups meetings, etc.) will bring attention to upcoming LER due dates and the information required for the LERs. This will ensure that ANO personnel recognize when Condition Report actions are directly related to an LER and completion of these actions is essential to timely submittal of the LER.
The SALP report also expressed a concern involving interdepartmental communica-tions. The implementation of the System Engineering concept will provide operations with an easily identifiable point of contact with Engineering for issues (e.g., operability determinations, repetitive failures) concerning specific systems. The Maintenance Engineers provide the same type of contact for main-tenance personnel with Engineering. These engineers are involved in the work p planning process and are readily available to maintenance personnel while work is V_ in progress. This enables timely engineering support for 'ssues such as the impact of maintenance on configuration control.
Reference the ANO Business Plan Project / Activity:
C.4 Engineered Maintenance C.5 Engineered operations C.10 Professionalism D.9 Communications n
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h 3.7 SAFETY ASSESSMENT / QUALITY VERIFICATION o (a)SALPITEMIV.G.3.b.3-STATEMENTOFISSUE
' Improve the ability to track and meet internal-and external commitments.
I ROOT CAUSE Program Related Concerne (V)
ANO RESPONSE'TO SALP ITEM IV.G.3.b.3 F.
.. ANO is -planning extensive changes over the next two years in the way NRC
[- -commitments are tracked. Currently, ANO tracks only active NRC commitments.
i For long-term commitment tracking, ANO will be implementing a system based on
[. Louisiana Power and Light Company's (LP&L) current system which will enhance AN0's
. capability to comply with past NRC commitments. The computer program for this improved commitment tracking effort _is currently being developed by LP&L and will
!-' be made available to ANO within the next few months.
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Further action is needed to ensure that commitments are met and maintained
! in the' future and to provide a mechanism for identifying commitments when
[ doing reviews such as those required by 10CFR50.59. Actions, in addition to improving the Commitment Tracking System which have been identified include:
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- Develop a station-wide definition of a commitment (draf t definition is under review).
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- Revise' existing procedures to properly address commitment control and main-tenance.
- Determine if past correspondence and licensing basis documents should be reviewed to extract commitments and be entered into a commitment L tracking system.
Reference the ANO Business Plan Project / Activity:
i F.2 Commitment Control ,
F.4 Improve Integrity of Communications !
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3.7 SAFETY ASSESSMENT / QUALITY VERIFICATION l
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-(a)SALPITEMIV.G.3.b.4-STATEMENTOFISSUE l 1
Continue to improve the review of industry events and provide timely implementa- j tion of lessons Icarned. ;
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i ANO RESPONSE TO SALP ITEM IV.G.3.b.4 l
ANO programs are being upgraded to more effectively evaluate and utilize NRC and Interfaces with Engineering are being defined to improve industry information. !
the use of industry experience in design activities. The Industry Experience , !
Program will be upgraded by the revision of design-related procedures which '
will provide explicit directions on the input and use of NRC and industry ;
information. Dedicated resources are being established within Technical l Support and Assessment to ensure consistent and timely evaluations of industry l experience. ;
Reference DET ITEMS 2.1.5.8 and 2.1.1.10.
Reference ANO Business Plan Project / Activity: I B.4 Upgrade Use of Industry and In-} louse Event Reviews '
D.11 Industry Experience j
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3.7 SAFETY ASSESSMENT / QUALITY VERIFICATION (o
. c') SALP ITEM IV.O.3.b.5 - STATENENT OF ISSUE Prioritire plant improvement programs, including the establishment of realistic schedules.
ANO RESPONSE TO SALP ITEM IV.G.3.b.5 The various plant improvement programs have been incorporated into the ANO Business Plan, which also includes appropriate schedules and milestones for these programs. The focus of the ANO Business Plan is on the activities required to accomplish the goal of beccming a world-class nuclear operations facility. A
- priority. scheme was used to classify each activity as high, medium, or low priority with high priority items being those items considered important to assure the continued safe operation of the plant, to reach key milestones within the Plan, or to correct significant deficiencies.
Reference the ANO Business Plan Project / Activity:
K.7 Management Processes i
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3.7 SAFETY ASSESSMENT / QUALITY VERIFICATION l- ( j SALP ITEM IV.G.3.b.6 - STATEMENT OF ISSUE Improve the quality (technical content, scope and securacy) of submittals made to ,
~NRC. Management involvement in licensing activities should be assessed to ensure '
that adequate levels of staffing and technical resources are assigned to assure high quality responses to NRC initiatives.
ANO RESPONSE TO SALP ITEN IV.G.3.b.6 ANO is committed to ensuring that communications with the NRC are accurate, complete and submitted within the required time frame.
1he actions associated with this effort include:
- Development of methodology to ensure that documented reviews of all corres-pondence are obtained prior to submittal i
- Enhancement of licensing procedures to provide guidance on standards and '
expectations for NRC submittals
- Placement of all NRC correspondence onto the Licensing Document Research ,
System (LDRS) t t
. r' y
- Development and implementation of a policy for submitting additional corres-(_) pondence to the NRC to follow up on items completed (such as long-term actions, etc.)
- Periodic telephone communications with the NRC staff
- Improvement of the overall quality of Technical Specifications Reference DET ITEM 2.1.1.3 Reference the ANO Business Plan Project / Activity:
F.1 Improve Image and Credibility F.3 Improve Quality of Technical Specifications F.4 Improve Integrity of Communications
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l MATRIX l
-( j APPENDIX A
' Findings from the latest Systematic Assessment of Licensee Performance (SALP) report !
cod the Diagnostic Evaluation Team (DET) report have been evaluated and a Business Plan ,
action item corresponding to each finding has been developed. In cases where SALP and i DET findings overlap, there may be only one Business Plan item established. The !
Business Plan will provide the tracking mechanism for the future closeout of all SALP cnd DET findings along with other performance improvements identified by ANO. A' tatrix, identifying the individual SALP and DET findings and the corresponding Business Plan items, follows.
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! DET/SALP/ BUSINESS PLAN CROSS REFERENCE i
l i~ / ~ DET SALP BUSINESS PLAN SECTION SECTION SECTION e
2.1.1.1 IV.G.1(4) K.3 IV.G.1(13) K.5 IV.G.3.b(6) K.7
' IV.G.1(5)
IV.G.1(6)
IV.G.1(?)
2.1.1.2 IV.A.3.b(1) II. 7 K.3 K.5 2.1.1.3 IV.G.1(7) F.1 IV.G.1(2) F.3 IV.G.3.b(6) F.4 2.1.1.4 IV.A.1(3) C.10 IV.A.1(8) F.1 IV.C.1(3) K.5 IV.C.1(6)
IV.A.1(8)
,s 2.1.1.5 NRCL 2(5) G.3
() K.2 K.3 K.4 K.6 K.7 _
2.1.1.6 N/A C.10 K.3 ,
K.5 2.1.1.7 IV.A.3.b(2) C.4 IV.F.1(4) C.5 IV.A.1(5) C.7 ,
IV.F.3.b(3) C.9 IV.A.3.b(6) C.12.a IV.A.3.b(1) D.1 IV.A.3.b(8) 2.1.1.8 IV.A.3.b(2) C.5 IV.c.1(5) c.7 IV.C.3.b(2)
IV.A.3.b(8)
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.fi . ~ DET ~ , .SALP. BUSINESS PLAN- i D, J < SECTION- SECTION ,
SECTION l i
2.1.1.9 .IV.A.I.8 D.2 l IV.F.1(4) G.3 i IV.F.1(7) K.1 l IV.F.1(10): 'K.3 !
IV.F.3.b(3) .K.4 '!
IV.F.3.b(5)- K.6 !
K.7 i i
2.I'.1.10 IV.C.1(8) B.1 I IV'C.3.b(3)
. B.2 : ,l
, IV.G 1(2)' B.3 ;
IV.G.1(12) B.4 !
IV.G 3.b(1) B.5. I IV.G.3.b(4) '
C.9 F D.S.f t D.11 F.5 ] .,
J
> 2.1.2.1 -N/A N/A i 2.1.2.2 N/A N/A l-2.1.2.3 IV.A.1(5) C 5- f lf .
IV.A.3.b(4) C.10 J
') : C.11.a -i H .1. l
- 2.1.2.4 N/A .C.b.a A
-C.7 !
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. 2.1 ~. 2. 5 IV.A.3.b(1)- C.10 i' IV.A.3.b(8) C.11.a ;
. i 2.1.2.6 IV.A.3.b(1) C.11.a- ;
i
- 2.1.2.7 IV.A.3.b(5) 0.3 IV.C.3.b(5)- C.5 i IV.A.1(8) -
C.12.a l
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. 1DET- SALPE BUSINESS PLAN.
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A - s- m k se' ~ > .. ,e - -m,e ma -s -- w 4 6 APPENDIX B ANO MANAGEMENT ORGANIZATION OVERVIEW -
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p- APPENDIX B
!- d Changes in the ANO management and organization were implemented to bring new ideas j
- i. and focus into . the ANO organization. This experienced team will be implementing a ;
strategy to improve the safety culture'and leadership by E
i
'- Stressing safety and quality-regardless of cost or. schedule :l
- Communicating expectations both vertically-and horizontally
. Identifying and' resolving issues in a timely. manner ;
- Establishing accountability and ownership of issues
+
- Improving NRC interface :
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2.2.1 Vice President, Nuclear
(") The Vice President, Nuclear reports to the Senior Vice President, Nuclear and is responsible for the overall safe operation of the Arkansas Nuclear One, Units 1 and 2. Reporting to the Vice President, Nuclear are the Director, Nuclear Operations; the General Manager, Technical Support and Assessment; the General Manager, Nuclear Support; the General Manager, Engineering; the General Manager, Nuclear Quality; Materials Management; and an Executive Assistant.
2.2.2 Materials Management The General Manager, Materials reports to the Vice President, Nuclear and is responsible for coordinating Materials Management activities including stores, inventory control, procurement engineering, materials coordination and purchasing.
Reporting to the Project Manager are the Stores Supervisor; Procurement Coordina-tion Supervisor, Materials Engineering Supervisor; and the Purchasing Supervisor.
The General Manager's program responsibilities include the commercial grade item dedication program.
2.2.3 General Manager, Technical Support and Assessment The General Manager, Technical Support and Assessment reports to the Vice President, Nuclear and is responsible for Plant Assessment, Training, Emergency Planning, Licensing, and Security. Reporting to the General Manager are the (3 Manager, Plant Assessment; Manager, Training and Emergency Planning; Manager, C/ Licensing; Manager, Security; and a Technical Assistant.
The General Manager's program responsibilities include plant assessment and program oversight,_ condition reporting and root cause analysis, operator training, and the owners groups and other industry groups. Member and alternate chairman of the Safety Review Committee and Chairman of the Safety Evaluation Subcommittee of the Safety Review Committee.
2.2.4 General Manager, Nuclear Support The General Manager, Nuclear Support reports to the Vice President, Nuclear and is responsible for managing the nuclear five-year business plan and the Company's participation in various industry groups. Reporting to the General Manager are the Project Manager, Nuclear Staff Support; Project Manager, Nuclear Industry Support; Controller; Superintendent, Nuclear Planning; and Safety Review Committee (SRC) Administrative Assistant. <
The General Manager's program responsibilities include the nuclear five-year business plan (technical and financial). He is also responsibile for ensuring financial support for the Nuclear Department, technical and t.dministrative support to the Vice President, Nuclear, technical support to Corporate Communications, administrative support for the SRC and for preparing and analyzing key performance indicator reports. He serves as a member and Secretary of the SRC.
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2.2.5 Director, Nuclear Operations l
!.. {')
- v The Director, Nuclear Operations reports to the Vice President, Nuclear and is responsible for the development and administration of programs which support the j
capability of the station to meet or exceed all industry standards and regulatory j requirements. Repcrting to the Director are the three Plant Managers (Unit 1, Unit 2, and Central), the Manager Nuclear Operations Standards and an Executive Assistant.
The Director's program responsibilities include the programs associated kith plant ;
! operations, maintenance and radiation protection / chemistry functions, ALARA, planning and scheduling, system engineering support groups. Plant Safety Committee and Industrial Safety. He serves as a member of the Safety Review Committee, i I
2.2.6 General Manager, Engineering The General Manager, Engineering reports to the Vice President, Nuclear and is responsible for providing engineering design, evaluation, analysis, installation, testing, inspection and in support of operation and maintenance of the station.
Reporting to the General Manager are the Manager, Mechanical / Civil / Structural Design; the Manager, Electrical /I&C Design; the Manager, Nuclear Engineering ;
Design; the Manager, Modifications; the Manager, Engineering Support; and the ;
Manager Engineering. Standards.
The General Manager's program responsibilities include the programs associated with the Design Engineering and Modification functions, Engineering program functions, Configuration Management and Control Program, and development of
()
Design Engineering and Construction training prcgrams. He serves as a member
- of the Safety Review Committee and Chairman of the SRC Quality Assurance Subcommittee.
L 2.2.7 General Manager, Quality The General Manager, Nuclear Quality reports to the Vice President, Nuclear and ,
is responsible for the development and implementation of the Nuclear Quality Assurance Program. Reporting to the General Manager are the Manager, Quality Assurance, and the Manager, Quality Control / Quality Engineering.
The General Manager's program responsibilities include the programs associated with the quality assurance and quality control functions. He serves as a member of the Safety Review Committee (SRC) and the SRC Quality Assurance Subcommittee.
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- 1990-1994 BUSINESS PLAN APPENDIX
,m
(,) - A. Quality Program Lead: General Manager, Nuclear Quality Projects / Activities:
- 1. Improve QA/QC Ability to Self-Identify Problems / Precursors ;
- a. Analysis of Nuclear Quality (NQ) Resources to Focus on SALP J and DET Reported Problems J
- b. SALP Area Comparison vs Audit / Surveillance Coverage
- c. Performance Review Group
- d. Utilization of Output from 1.c to Aid in Surveillance / Audit
- e. Quality Review of Maintenance Job Orders During Planning Phase
- f. Coordination Between Nuclear Quality (NQ) and Assessment Groups
- g. Improve Nuclear Quality (NQ) Quarterly Trending Report
- 2. Improve Timeliness of Response / Resolution to Nuclear Quality (NQ)
Findings Responses
- 3. Receipt Inspection Improvements
- 4. Provide QA/QC Staff Resources to Support Utilization /
Shift Maintenance
- 5. Utilization of Craft Peer Inspectors 3
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,n 1990 - 1994 BUSINESS PLAN
( y PROJECT / ACTIVITY PLANNING RECORD
[ PROGRAM TITLE: A. Quality PROGRAM LEAD: General Manager Nuclear Quality PRIORITY: Medium PROJECT /ACTIVI1T TITLE: 1.a Improve QA/QC Ability to Self ID Problems /
Precursors DESCRIPTION: Modify QA/QC activities described within the objective section below in such a manner so as to improve the effectiveness of self-identification of problems / precursors to declining performance trends.
OBJECTIVE:
Improve the process for selection of activities for inspection / surveillance to focus upon areas within the SALP and Diagnostic reports ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE ___DATE
- 1) Analyze utilization of NQ resources in 01/15/90 03/30/90 order to ensure commensurate focus upon problem areas identified in the SALP and r
)
Diagnostic Reports. These areas includo but are not limited to:
- Operations Control of Safety-related Equipment (including operability determinations).
- Control Room Annunciators and Deficiency Tags (Control Room and Plant).
- Departmental Interfaces between Operations, Maintenance, Engineering and Planning and Scheduling. t
- Operations and Maintenance Independent Verification Program.
- Surveillance Testing /ISI/IST.
- Hot Particle and Personal Contamination
- , Events Programs.
I
- Configuration Control (including temporary mods).
- Tech Spec Procedural Weaknesses.
- Periodic Master Test Control List Surveillances. *
- Maintenance Support for Security Equipment.
- Rework / Repair (corrective maintenance).
- Preventive Maintenance.
- Isometric Update Program.
- Corrective Action Program.
, ,s
- Licensing Activities.
!
- Housekeeping.
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- Post-Maintenance Testing.
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l 1990 - 1994 BUSINESS PLAN j
-u- PROJECT / ACTIVITY PLANNING RECORD t
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PROGRAM TITLE: A. . Quality i PROGRAM LEAD: General Manager Nuclear Quality l PRIORITY: Medium f PROJECT / ACTIVITY TITLE: 1.a Improve QA/QC Ability to Self ID Problems / l Precursors !
i :
1 DESCRIPTION: Modify QA/QC activities described within the objective i L section~below in such a manner so as to improve the effectiveness of self- l identification of problems / precursors to declining peri)rmance trends. ;
.t OBJECTIVE:
{
Improvh the process for selection of activities for inspection / surveillance l to focus upon areas within the SALP and Diagnostic reports l
ACTION PLAN
SUMMARY
START COMPLETION j DATE. DATE l L
- Conduct of Operations (including operator i rounds, use of' logs, valve lineups, 100- I cycle valve control). i
~s
- Materials Control (including shelf-life i
' if ,) -. and dedication of commercial grade).
- 2) Readjust utilization of resources. 03/30/90 05/15/90 j
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I 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD I
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PROGRAM TITLE: A. Quality l PROGRAM LEAD: General Manager Nucle:r Quality PRIORITY: Medium j PROJECT / ACTIVITY TITLE: 1.b Improve QA/QC Ability to Self-ID Problems /
Precursors ;
DESCRIPTION: Modify QA/QC activities described within the objective -
section below in such a manner so as to improve the effectiveness of self-identification of problems / precursors to declining performance trends. ;
e r
OBJECTIVE: !
Realign the QA audit and surveillance programs into functional areas similar to and consistent with SALP areas !
ACTION PLAN SUhMARY:
START COMPLETION ,
ACTION DATE DATE n.
-t )
%/ '
Compare existing and planned audits /surveillances I to the seven SALP areas to ensure coverage of elements within each SALP area. Modify audit / +
surveillance identification to enable compilation and analysis by SALP area.-
- 1) Comparison to be'campleted. 01/15/90 03/30/90
- 2) Schedule of development of audits /
surveillances of areas found not to be covered to the depth desized 9111 be ,
developed. 03/30/90 04/15/90 ;
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1990 - 1994 BUSINESS PLAN
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[ 'y PROJECT / ACTIVITY PLAXXING RECORD 3 j
PROGRAM TITLE: A. Quality ;
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PROGRAM LEAD: General Manager Nuclear Quality l
PRIORITY: Medium
- l L PROJECT / ACTIVITY TITLE: 1.c Improve QA/QC Ability to Self-ID Problems / ;
Precursors l L DESCRIPTION: Modify QA/QC activities described within the objective ,
section below in such a manner so as to improve the effectiveness of self-
- identification of problems / precursors to declining performance trends.
I -- ;
OBJECTIVE:
- s Improve coordination between the Assessment and Quality organizations ACTION PLAN
SUMMARY
h START COMPLETION ACTION DATE DATE i
Establish a performance review group composed of 06/30/90
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(
a representative from QA, QE, Plant Assessments, 03/31/90 l I
IHEA, Maintenance History and Licensing. The .
function of this group will be to meet on a routine basis to assess cumulative performance .
results by analyzing indicators for adverse trends, !
precursors, and areas / items needing management attention.
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p ~_ 1990 - 1994 BUSINESS PLAN i
- /c i
} ( ,) PROJECT / ACTIVITY PLANNING RECORD j
[
- PROGRAM TITLE
- A. Quality l
PROGRAM LEAD: General Manager Nuclear Quality
~ PRIORITY: Low l
.t PROJECT / ACTIVITY TITLE: 1.d Improve QA/QC Ability to Self-ID Problems /
j Precursors i
Modify QA/QC activities described,vithin the objective .
DESCRIPTION: ;
section below in such a manner so as to improve the effectiveness of.self-identification of problems / precursors.to declining performance trends. :
OBJECTIVE:
f Improve coordination between the Assessment and Quality organizations j t
ACTION PLAN
SUMMARY
- j
( "T START COMP 7.ETION
\s / . .
ACTION DATE DATE t e
Utilize the-output from A.I.c and the output 03/31/90-06/30/90 ,
resulting from improved plant internal and external trending as input to aid in selection 1 of activities for ongoing audits / inspection /
surveillance.- Close coordination with t
- Assessments will be accomplished to optimize ,
resource utilization. This will start within ;
30 days of issue of first report from A.1.c. ;
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1990 - 1994 BUSINESS PLAN
( )l PROJECT / ACTIVITY PLANNING RECORD L
[ PROGRAM TITLE: A. Quality PROGRAM LEAD: General Manager Nuclear Quality -
PRIORITY: Medium PROJECT / ACTIVITY TITLE: 1.e Improve QA/QC Ability to Self-ID Problems /
Precursors
! DESCRIPTION: Modify QA/QC activities described within the objective section below in such a manner so as to improve the effectiveness of self-f identification of problems / precursors to declining performance trends, f OBJECTIVES:
Improve the process for selection of activities for inspection /
- surveillance ACTION PLAN
SUMMARY
START COMPLETION l'
ACTION DATE DATE f 'N Develop a method for Quality review of maintenance
() job orders during the planning stage to ensure appropriate QC inspection / surveillance coverage of work activities not currently governed by procedures or workplans. As improved maintenance history information becomes available, the information will be utilized l- to assist in identifying recurring equipmect repairs warranting QC involvement. (Referente
-Item C.9)
Complete
- 1) QC presence in P&S (interim). 01/22/90 (01/22/90)
- 2) Maintenance Job Order Inspection Guidelines development. 01/15/90 03/31/90 3)- -Mai.ntenance Job Order Inspection Guidelines implementation. 04/01/90 05/01/90
- 4) Incorporate control of inspection j e _ guidelines within Nuclear Quality procedures. 04/15/90 05/01/90 (DET 2.1.3.10) p t Q- ;
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1990 - 1994 BUSINESS PLAN
/)
- \,,/-
PROJECT / ACTIVITY PLANNING RECORD !
j PROGRAM TITLE: A. Quality f i
PROGRAM LEAD: General Manager, Nuclear Quality PRIORITY: Low I PROJECT / ACTIVITY TITLE: 1.f Improve QA/QC Ability to Self-ID Problems /
Precursors -l DESCRIPTION: Modify QA/QC activities described within the objective .
section below in such a manner so as to improve the effectiveness of self-identification of problems / precursors to declining performance trends. l OBJECTIVE:
Improve coordination between the Assessment and Quality organizations i ACTION PLAN
SUMMARY
Coordination between Assessments and Nuclear Quality will be -F improved by: i START COMPLETION ,
ACTION DATE DATE ,
- f~-};L
-1) Review of 1990 audit schedule and revisions 01/30/90 . Complete l with Assessments prior to approval. (02/15/90) t
- 2) Establish Periodic meetings with Assess-- 03/31/90 0(/30/90 i ments as outlined in action plan A.1.c.
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1990 - 1994 BUS FESS PLAN PROJECT / ACTIVITY PLANNING RECORD
,' PROGRAM TITLE:- A. Quality 7: PROGRAM LEAD: General Manager Nuclear Quality PRIORITY: Low n PROJECT / ACTIVITY TITLE: 1.g Improve QA/QC Ability to Self-ID Problems /
Precursors DESCRIPTION: Modify QA/QC activities described within the objective section below in such a manner so as to improve the effectiveness of self-identification of problems / precursors to declining performance trends.
OBJECTIVES:
Improve trending of audit / inspection / surveillance results ACTION PLAN SUM 11ARY:
START COMPLETION
- O ACTION DATE DATE
- 1) The Nuclear Quality Deficiency Trending 01/15/90 03/30/90
. Report will be analyzed for improvement by a review of trending reports utilized by selected nuclear utilities, and a self-critical analysis of the existing
, report,
, 2) Appropriate changes will be incorporated 03/30/90 05/31/90 ia the quarterly report for the first quarter 1990.
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__s 1990 - 1994 BUSINESS PLAN v v
- ( j - PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE
- A. Quality PROGRAM LEAD: General Manager Nuclear Quality PRIORITY: Medium PROJECT / ACTIVITY TITLE: 2. Improve Timeliness of response / resolution to Nuclear Quality Findings DESCRIPTION: Although progress has been made in reducing the number of open NQ findings, and the length of time findings have been open has been reduced, continued improvement is needed.
OBJECTIVES: Continue to improve timeliness of response to-Nuclear Quality Findings (excluding observations and recommendations) and time required to i
resolve the concerns such that any finding which has been >6 months is considered a timeliness concern and the total number open >6 months is $15 by year-end 1990, 310 by year-end 1991, and $5 by year-end 1992 and thereafter. '
ACTION PLAN-
SUMMARY
START COMPLETION
()
LJ ACTION DATE DATE Complete ;
L 1) Begin Monthly reporting of overdue and 02/15/89 (02/20/90) l L timeliness concerns. 4 Complete !
- 2) Start monthly meetings between NQ and 02/22/90 (03/06/90) management having overdue and timeliness j
,. concerns.
l Complete
- 3) Address overdue and timeliness concerns 02/20/90 (02/20/90) in each SRC full committee and SRC - QA Subcommittee meeting.
Complete ;
- 4) Develop 1990 Nuclear Ops goal for AFR/SFR/ 01/15/90 (03/06/90) j QCFRs open >6 months to be $15 by year-end i 1990 (Jan. 3, 1990 = 31), $10 by year-end j 1991 and 55 by year end 1992 and thereafter. -
- 5) ' Include the goal developed in .4 action plan 02/15/90 05/01/90 1 in the plant performance indicators report.
- 6) Reduce the number of AFR's/SFR/QCFR's open > 6 ,
months to: 1 a) 5 15 by year end 1990 02/01/90 12/31/90
,- s b) 5 10 by year end 1991 01/02/91 12/31/91
!ms) c) -< 5 by year end 1992 01/02/92 12/31/92 A-9
[
i-.
s 1990 - 1994 BUSINESS PLAN i-( i PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: A. Quality ll PROGRAM LEAD: General Manager Nuclear Quality PRIORITY: Medium PROJECT / ACTIVITY TITLE: 3 keceipt Inspection Improvements
_~_.#_
DESCRIPTION: Essare a hrgh probability of detection of nonconforming materials and er/aente the capability te nerform receipt inspections for dedication of ecmmeretally procured itc.as.
OBJEC;IVE:
Ensure a high degree of confidence that nonconforming materials are detected to prevent use at ANO.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
'~'T 1) Determine / procure testing equipment to enable 06/15/90 12/31/90 N._) on-site testing and inspection of materials and commercially procured items.
- 2) Develop / implement receipt inspection training 06/15/90 12/31/90 ;
which' includes, but is not limited to, fraud- j ulent material detection.
3). Evaluate through manpower analysis the 06/15/90 12/31/90 resources-required to perform receipt inspection activities anticipated as a result of enhancements to receipt inspection capab- !
I ilities described above.
- 4) Assess the frequency and breadth of vendor 03/15/90 07/01/90 l surveillance in light of nuclear industry :
and ANO experience.
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-1990 - 1994 BUSINESS PLAN .;
/~'i = PROJECT / ACTIVITY PLANNING RECORD
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PROGRAM TITLE:. A. Quality 9
. PROGRAM LEAD: General Manager Nuclear Quality PRIORITY: Medium
. PROJECT / ACTIVITY TITLE: 4. Provide QA/QC Staff Resources to Support j Unitization / Shift Maintenance ,
DESCRIPTION: . .QA/QC staff resources must be sufficient to ensure adequate 5 coverage of inspection / surveillance activities for support of restructured j
. maintenance shift work.' j l
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OBJECTIVES: Staff'the QA and QC/QE departments with sufficient personnel to address unitized / shift' maintenance work capacity due to shift I' restructuring.
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1 j.s . ACTION PLAN
SUMMARY
-("' l START COMPLETION ACTION DATE DATE -
- 1) ; Identify resources required as a 02/15/90- 03/31/90 resultlof unitization / multiple shifts.
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1990 - 1994 BUSINESS' PLAN
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-( ); PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: A. Quality PROGRAM LEAD: General Manager Nuclear Quality PRIORITY: Low PROJECT / ACTIVITY TITLE: 5. Utilization of Craft Peer. Inspectors DESCRIPTION: Determine if craft peer inspection should be utilized to supplement QC inspection resources to provide additional inspection of non-construction-like maintenance activities at ANO.
- 0BJECTIVES: Evaluate the feasibility and desirability of utilizing craft peer' inspectors to supplement regular QC inspection manpower to perform non-construction-like inspections.
ACTION PLAN
SUMMARY
- i START COMPLETION ACTION DATE DATE-
. . 1) Determine those inspections which could best 04/15/90 06/15/90
(N be performed by craf t peer inspectors.
\ /- 2) Dete'rmine training and resources required to 06/15/90 07/01/90 train / certify' personnel.
- 3) From:results of I and 2, make recommendation -07/01/90 07/30/90 regarding use of peer inspection. .
4). .If appropriate, develop an implementation 08/15/90 10/01/90 '1 l
plan / schedule.
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1990-1994 BUSINESS PLAN APPENDIX
'# B. Assessment Program Lead: General Manager Technical Support and Assessment Projects / Activities:
- 1. Improve Root Cause Determination- '
- 2. Improve Corrective Action Program
- 3. Define Role and Scope of Assessment 1
- 4. Upgrade Use of Industry and In-House Event Reviews
- 5. Performance Monitoring (External / Internal Trending) s I
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1-i 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD
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i PROGRAM TITLE: B. Assessment PROGRAM LEAD: General Manager Technical Support'and Ascessment ,
PRIORITY: High PROJECT / ACTIVITY TITLE: 1. Improve Root Cause Determination DESCRIPTION: Improve root cause determination practices through training, role models, more thorough reviews with qualified reviewers of root causes performed by plant departments (Condition Reports).
b OBJECTIVES: Improve self-assessment techniques through thorough in-house root cause evaluations.
(~) ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Conduct. Root Cause Methodology / Process 05/01/90 12/31/90 Training classes in 1990 as budgeted and in future years for plant personnel who perform root cause evaluations.
- 2) Fill budgeted additions to IHEA staff in 11/01/89 04/01/90
.1990.
- 3) Obtain outside expertise in the form of an 03/01/90 03/01/91.
INPO Reverse Loanee to train staff, help ,
organize effective assessment practices within plant assessment as budgeted.
(DET 2.1.1.10, 2.1.3.3, 2.1.3.7, and 2.1.5.10)
(SALP IV.G.3.b.1) m
)
B-1
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, 1990 - 1994 BUSINESS PLAN r e ;. . _ y
, f PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: B. Assessment PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: liigh PROJECT / ACTIVITY TITLE: 2. Improve Corrective Action Program DESCRIPTION: Revise condition reporting procedure (CRs) to remove adminis-trative burden on managers.
OBJECTI\TS: Improve the corrective action program by procedural changes which will permit managers to focus root cause and corrective action efforts on significant conditions.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
)
v'
- 1) Revise Procedure 1000.104, " Condition Reporting."
12/01/89 04/01/90
- Revise the Manager's Reportability Determination (Licensing will have the responsibility for the call with review by line manager).
- Require that prompt (within 14 days) root cause be determined prior to Corrective Action Review Board.
- Require _that significant conditions ,
receive Corrective Action Review Board and approval prior to CA Plan implementation.-
- Provide for upfront review of CRs (IKEA, Licensing, QE, etc.) during a 24-hour holdover in IHEA; should reduce the number of CRs that are processed v1.
the CRS. (i.e., cause determined, CA already taken, Admin. closed, lumping).
(DET 2.1.1.10, 2.1.3.3, 2.1.5.4, 2.1.5.6, and 2.1.5.7)
(SALP IV.G.3.b.1)
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, 1990 - 1994 BUSINESS PLAN
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PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: B. Assessment PROGRAM LEAD: . General Manager Technical Support and Assessment PRIORITY: High PROJECT / ACTIVITY TITLE: 3. Define Role and Scope of Assessment ,
1 l.
DESCRIPTION: Establish a group within Plant Assessment to conduct assessments of nuclear activities to the standards of excellence esta-blished by INF0, NRC, and ANO management and identify areas requiring improvements and attention.
OBJECTIVES: Establish self-assessment capabilities such that root causes, precursors and indicators of performance can be determined in-house and in such a manner that management can take timely corrective action.
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ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Obtain assistance in the form of a reverse 03/01/90 03/01/91 . ;
loanee to help establish and train the ,
organization. (See B.1)
- 2) Adjust the mix of talent in the Assessment- 01/30/90 06/30/90 organization to one with expertise in Opera-tions, Maintenance and Technical Support in .)
addition to Chemistry and Radiation Protection {
as STA's transition out of the organization 'I and positions are vacated. ,
- 3) Develop a practice of routine use of NPRDS, 04/01/90 07/15/90 i SIMS, and CFAR to identify recurring problems.
~
- 4) Initiate the conduct of daily, monthly, and 04/01/90 08/15/90 semiannual. assessments which identify 4 programmatic. issues, root causes, and -j provide recommendations to line management to enable performance improvement. l (DET 2.1.1.10) q
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L 1990 - 1994 BUSINESS PLAN
- j. PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: -B. Assessment 4
PROGRAM LEAD: General Manager Technical Support and Assessment' PRIORITY: Medium PROJECT / ACTIVITY TITLE: 4. Upgrade Use of Industry and In-House Event Reviews DESCRIPTION: Implement improved reviews of industry experience (SOERs, SERs, O&MRs, IE Notices, Part 21 and other vendor notices, SPIP), of in-house events-(HPES, TRIP Reports, Condition Reports) and of equipment failures at ANO (CFAR, NPRDS) through dedicated, experienced reviewers who provide a prompt assessment of applicability, safety implications and develop action plans to promptly resolve. i OBJECTIVES: Improve in-house capability to provide critical self-assessments of performance and to take advantage of lessons learned by others.
- ,,, ACTION PLAN:
SUMMARY
)
s/ START COMPLETION
-ACTION DATE DATE
- 1) As STA's and their functions are trans- 02/01/90 06/30/90 ferred to other areas of the organization, fill the resulting positions in Industry Event Review with full-time people-dedicated to industry reviews,
- 2) Assign CFAR/NPRDS review to a full-time 02/01/90 06/15/90 individual in the Assessment Group. (See B.3.3)
- 3) Eliminate backlog of' review items with regard 01/01/90 12/31/90 to industry events.
- 4) Establish an improved tracking system for 01/01/90 04/30/90 l- action items from industry event reviews.
(DET 2.1.3.7)
- 5) Develop transition plan for transition of 02/01/90 04/30/90 SPIP/TRP Program responsibility to plant managers.
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r- r n-y' 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD
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[ PROGRAM TITLE: B. Assessment PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: Medium PROJECT / ACTIVITY TITLE: 4. Upgrade Use of Industry and In-liouse Event
- Reviews ACTION PLAN
SUMMARY
- (Cont'd) ,
START COMPLETION ACTION DATE DATE
- 6) Maintain IIPES coordination function in Plant 01/01/89 Complete .t Assessment.
- 7) Define the role and interface of industry 04/01/90 06/15/90 experience with other organizations and departments (level of screening, respon-sibility operability / applicability, action plan development and prioritization).
(DET 2.1.3.6, 2.1.3.7, and 2.1.5.8) j3 -(SALP.IV.G.3.b.4)
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Il g 1990 - 1994 BUSINESS PLAN E r, PROJECT / ACTIVITY PLANNING RECORD' l,
PROGRAM TITLE: B. Assessment PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5. Performance Monitoring (External / Internal Trending)
DESCRIPTION: Establish within Plant Assessment the capability to assess indicators of performance as well as conduct analysis of internal and external trend reports.
-0BJECTIVES: Establish self-assessment capabilities such that in-house ',
capabilities exist to analyze trends in the manner that NRC and INPO ,
analysis divisions employ in order that management remains constantly and fully appraised of the performance of ANO.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Train individuals capable of performing 07/01/90 03/01/91
()
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performing the in-depth analysis required to pull related information together into a root cause analysis.
2)- Staf f existing Plant Assessment positions 02/01/90 06/30/90 with experience to perform this task. .
- 3) Begin to routinely obtain both the NRC 08/31/90 08/31/90 ;
and INP0 performance indicators, analyze these indicators, and prepare a report
.(with recommendations) for management to focus on activities that will improve performance.
(DET 2.1.1.10 and 2.1.3.3) l NM B-6
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1990-1994 BUSINESS PLAN APPENDIX V,ey C. Operations & Maintenance Programs Lead: Director Nuclear Operations Projects / Activities:
- 1. Surveillance Progrums
- 2. Preventive Maintenance
- 3. Plant Material Condition /Houseleeping
- 4. Engineered Maintenance
- 5. Engineered Operations
- a. Operations Technical Support
- 6. Work Closure
- 7. Maintenance Optimization
- 8. Predictive Maintenance
- 9. Trending
- 10. Professionalism 11.' Procedure Upgrades
- a. Operations
- b. Maintenance
- c. Emergency Operating
- 12. Backlog Reduction
- a. Corrective Maintenance b.. Preventive Maintenance 1-V -Pi l i
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i 1990 - 1994 BUSINESS PLAN
) PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: liigh PROJECT / ACTIVITY TITLE: 1. Surveillance Programs DESCRIPTION: Establish a program that ensures surveillances are properly scheduled, conducted and reviewed.
OBJECTIVES: Implement a program that prevents missed surveillances and ensures adequacy of surveillance to meet Technical Specification require-ments.
ACTION PLAN
SUMMARY
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START DATE COMPLETION DATE ACTION Complete ,
- 1) Transfer responsibility of the. program to N/A (02/01/90)
Nuclear Standards.
-2) Evaluate the surveillance program (outside con- 02/01/90 05/15/90 tractor) to identify problem areas and develop action plan to provide resolution.
- 3) Establish an oversight function with approp- 02/01/90 08/01/90 riate management involvement and adequate administrative. control to ensure surveillances are not missed or degraded.
(DET 2.1.4.2)
- 4) Reverify / revise surveillance procedures as 07/02/90 07/01/92 necessary to ensure that the procedures
~implenent the surveillance requirements and document operability while implementing related actions of (4) above.
(DET 2.1.4.1, 2.1.4.2, 2.1.4.3 and 2.1.4.4)
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1990 - 1994 BUSINESS PLAN, PROJECT / ACTIVITY PLANNING RECORD f
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PROGRAM TITLE: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: High ,
l PROJECT / ACTIVITY TITLE: 2. Preventive Maintenance DESCRIPTION: Preventive Maintenance Program OBJECTIVES:
- a. Complete PM Procedure writing by 10/31/90.
- b. Establish continuing maintenance of program procedures,
- c. Adjust preventive maintenance intervals as appropriate.
ACTION PLAN
SUMMARY
START COMPLETION -
ACTION DATE DATE
['~') 1) Take ownership of PM development from Complete
\' Engineering during January 1990 adjusting (01/02/90) resources with standards organization and maintenance organization.
- 2) Complete the development of Q, F & S PM 01/02/90 10/31/90 procedures. ,
(DET 2.1.3.6)
- 3) Evaluate the need for establishing process 07/01/90 09/04/90 for continuance of the program to include non-safety related PMs.
(DET 2.1.3.1)
- 4) Develop plan to perform validation for PM 04/02/90 07/01/90 procedures approved prior to (2/1/90).
- 5) Evaluate specific deficiencies identified in 04/02/90 08/01/90
, DET and revise PMEEs and associated pro-cedures as necessary.
l 6) Revise PH procedures to correct deficiencies 02/02/90 03/01/91 l that have been identified.
- 7) Revise PM procedures to correct deficiencies 01/02/90 Ongoing identified during use and review.
(DET 2.1.3.1 and 2.1.3.6)
(SALP IV.C.3.b.7)
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. . - 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: Medium PROJECT / ACTIVITY TITLE: 3. Plant Material Condition / Housekeeping DESCRIPTION: Improve housekeeping activities.
OBJECTIVES: Improve plant appearance and material condition an$ reduce amount of contaminated areas.
ACTION PLAN SUntARY:
START COMPLETION ACTION DATE DATE
- 1) Establish aggressive targets for reducing 02/01/90 07/01/90 contaminated areas, improving printed areas, replacing worn out furniture, improve lighting, and storage.
- 2) Evaluate size of housekeeping force. 03/01/90 05/01/90
- 3) Implement action to meet targets. 02/01/90 12/31/90 (DET 2.1.2.8)
(SALP IV.A.3.b.5)
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.1990 - 1994 BUSINESS PLAN x-
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PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: High PROJECT / ACTIVITY TITLE: 4. Engineered Maintenance i
DESCRIPTION: Provide technical resources, equipment failure analysis, equipment and tools to establish and maintain various maintenance programs such as MOV maintenance, snubber inspections, relief valve testing, rotating equipment maintenance, valve improvements, post-maintenance testing, etc.
t OBJECTIVES: Improve overall performance and reliability of plant equipment through improved maintenance methods.
ACTION PLAN
SUMMARY
START COMPLETION
's.
i ACTION DATE DATE '
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- 1) Hi Define maintenance programs and 02/22/90 06/01/90 responsibilities.
- 2) Hi Have programs fully implemented. 06/04/90 12/31/90
- 3) Hi Improve communications. 02/22/90 12/31/90 (DET 2.1.3.7, 2.1.3.8, 2.1.3.3)
- 4) Hi Root cause training for Maintenance 02/22/90 04/02/91 Engineers who perform root cause analysis.
'(DET 2.1.3.7, 2.1.3.8)
- 5) Hi Develop a transition plan to provide 02/22/90 04/02/90 sufficient maintenance engineers to allow unitization.
(DET 2.1.1.7, 2.1.3.1, 2.1.3.3, 2.1.3.6, 2.1.3.7, 2.1.3.9 and 2.1.5.5)
(SALP IV.G.3 b.2) q
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- -1990 - 1994 BUSINESS PLAN s,j PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: C. Operations & Maintenance !
PROGRAM LEAD: Director Nuclear Operations PRIORITY: High PROJECT / ACTIVITY TITLE: 5. Engineered Operations DESCRIPTION: To provide implementation of a System Engineering program ,
at ANO consistent with the guidance of INPO Good Practice, TS-413, and applications at other sites, facilitating a constancy of focus on a system basis for all activity related to the system, and resulting in a proactive and intrusive presence by engineering.
OBJECTIVES:
- a. Improve overall plant performance,
- b. . Improve communication and coordination of efforts between departments. (DET 2.1.5.5,.2.1.5.15, and SALP IV.G.3.b.2)
- c. Create a foundation of technical experts for each system.
(DET 2.1.2.3) d.- Provide consistency of resolution and documentation of system operational and performance problems. (DET 2.1.2.3 and 2.1.4.6)
- e. Instill a sense of ownership which includes intimate' knowledge of.
systems.
- f. Enhance job satisfaction through increased responsibility
., accountability and plant knowledge. (DET 2.1.5.4)
/ i d ACTION PLAN SlMMARY:
START COMPLETION ACTION DATE DATE
- 1) Hi Separate functions related to System 03/01/90 06/01/90 Engineering, Field Design Support and Maintenance Support.
- 2) Hi Establish an organization devoted and 03/01/90 09/30/90 accountable only for System Engineering.
- 3) Hi Select.a core group of System Engineers, 03/01/90 04/16/90 then recruit the remainder. (DET 2.1.3.1)
L
- 4) .Hi Establish training required for 03/01/90 07/31/90 System Engineers.
5). Hi Establish interfaces for System 05/01/90 08/01/90 Engineers.
- 6) Hi Develop a transition plan to provide 03/01/90 04/16/90 sufficient' engineers to allow System engineering to become unitized.
(DET 2.1.1.8)
(DET 2.1.1.7, 2.1.1.8, 2.1.2.3, 2.1.2.7, 2.1.3.1, 2.1.3.3, 2.1.3.7, 2.1.4.6, 2.1.5.2, 2.1.5.5, 2.1.5.6, 2.1.5.7, 2.1.5.10, 2.1.5.12 and 2.1.5.15)
(SALP IV.A.3.b.2 and IV.G.3.b.2) o C-5
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- 1990 - 1994 BUSINESS PLAN g
'd PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: C. Operations & Maintenance
' PROGRAM LEAD: _ Director Nuclear Operations PRIORI 1Y: See Action Plan PROJECT / ACTIVITY TITLE: 5.a Operations Technical Support DESCRIPTION: Provide adequate technical support for unit operations.
OBJECTIVES: Provide operational resources to provide technical oversight for training, schedule coordination, work load management, and provide on-shift engineering support.
ACTION PLAN SUMHARY:
START COMPLETION ACTION DATE DATE
-(~'T ,
- 1) Complete college degree program in 1991. In Progress 12/31/91
- 2) Establish shift engineering. 03/01/90 12/31/90
- 3) Provide assistance to Operations Manager for 03/01/90 03/30/90 monitoring equipment / hardware problems.
(DET 2.1.2.4)
- 4) Phase'Out SAA function. 01/01/91 12/31/91 (DET 2.1.2.4) w.)
C-6
1990 - 1994 BUSINESS PLAN s _/
'i PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: High PROJECT / ACTIVITY TITLE: 6. Work Closure DESCRIPTION: Establish those functions in the " Work Closure" section of the organization to enhance the usage of equipment history _and related I failure trending information for the purpose of supporting and enhancing a more effective maintenance program.
OBJECTIVES: ,
- a. Enhance NPRDS usage,
- b. Establish an effective recurrent equipment failure identification program.
- c. Establish an effective work closure and monitoring organization.
ACTION PLAN
SUMMARY
fT, START COMPLETION ,
'N_,/ _ ACTION DATE DATE '
- 1) Provide NPRDS Data to appropriate departments for review, analysis and further action:
- Provide Quarterly CFAR Reports (Interim Action). 01/15/90 01/15/91
- Procedure complete. 03/01/90 10/01/90
- *First Quarterly NPRDS Failure Report. 10/01/90 01/15/91 2). Establish SIMS Failure Analysis Flagging Criterion:
- Provide Monthly Maintenance History Report (Interim Action). 01/30/90 10/15/90
- Procedures Complete. 03/01/90 07/01/90
- First Quarterly SIMS Component Reliability Report. 07/01/90 10/15/90
- 3) Establish a Work Closure Group:
- Separate Work Closure Group from Planning and Scheduling Organization. 01/01/90 02/15/90
- Complete Staffing. 03/01/90 12/31/90
- First Annual Maintenance History Summary, 10/01/90 01/15/91
- Complete SIMS Assessment and cy Enhancements. 01/01/90 05/15/92
_ ,/ (DET 2.1.3.3, 2.1.3.6, 2.1.3.8 and 2.1.3.10)
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1990 - 1994 BUSINESS PLAN s PROJECT / ACTIVITY PLANNING RECORD
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~< PROGRAM TITLE: C. Operations & Maintenance PROGRAM ~ LEAD: Director Nuclear Operations -
PRIORITY: High PROJECT / ACTIVITY TITLE: 7. Maintenance Optimization (Unit Maint. Managar)
\
DESCRIPTION: Establish work flow procedures in the Unit Operations and Maintenance Organization to support an effective maintenance organi'zation.
Establish a second shift of maintenance and support resources to reduce control room congestion and optimize the control and management of work activities.
OBJECTIVES: '
- a. Remove-cumbersome barriers to_ effective work management,
- b. Develop effective retest program (post-maintenance test).
- c. Ensure management expectations are clearly communicated with standards.
- d. Establish standards for quality work packages.
< e. Optimize the control and management of work activities.
- f. Establish unit specific maintenance craft, craft supervision, and technical specialist.
- g. Utilize staff to accomplish base load maintenance.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE-l j) Complete q,,/ 1. Unitize maintenance and provide maintenance 02/01/90 (02/25/90) coverage by expanding shift work.
- 2. Transition Plan for Optimization of 03/01/90 06/30/90 Maintenance.
- 3. Establish goals to optimize maintain process. 03/01/90 05/01/90
- 4. Review INPO, NRC, industry standards and 03/01/90 05/01/90 recommendations.
- 5. Define management expectations for work 03/01/90 05/01/90 planning.
- 6. . Establish team to review process, modify 05/01/90 10/15/91 procedures improve methods, utilizing feedback from work force.
- 7. Develop retest control procedure. 02/01/90 06/30/90
- 8. Develop and implement self-monitoring-program 09/01/90 11/01/90 to insure needs are identificd and feed back into program.
(DET 2.1.1.7, 2.1.1.8, 2.1.2.4, 2.1.3.1, 2.1.3.8 and 2.1.3.9)
(SALP~IV.A.3.b.2) g
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t p[- 1990 - 1994 BUSINESS PLAN
,) PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: Medium PROJECT / ACTIVITY TITLE: 8. Predictive Maintenance DESCRIPTION: Establish predictive. maintenance program consisting of
- g. vibration analysis, lube oil analysis and thermography.
OBJECTIVES:
- a. Predict equipment problems prior to failure. ;
- b. Reduce corrective maintenance and plant transients. !
- c. Prioritize maintenance activities.
(DET 2.1.3.6) l ACTION PLAN
SUMMARY
'x _)$ START COMPLETION ACTION DATE DATE- l
- 1) Identify necessary equipment. 01/03/90 Complete
- 2) Purchase equipment. 11/01/90 01/31/91 i
- 3) Training complete. 01/31/91 03/01/91 j
- 4) Procedures developed. 01/31/91 03/01/91 j
- 5) Program fully implemented. 06/30/90 04/01/91 i (DET 2.1.3.6) ;
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1990 - 1994 BUSINESS PLAN
' l_ PROJECT / ACTIVITY PLANNING RECORD
-J PROGRAM TITLE: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: liigh PROJECT / ACTIVITY TITLE: 9. Trending'
[
DESCRIPTION: Establish comprehensive program for trending the performance of essential plant equipment.
OBJECTIVES: Provide vital equipment performance data trends to maintenance, operations, quality assurance and engineering personnel.
Information is necessary to determine need for maintenance and/or design changes.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE e~s
- 1 (s / 1) Develop program document. 01/03/90 03/31/90
- 2) Revise necessary procedures. 03/31/90 09/30/90
- 3) . Purchase required computer equipment. 09/30/90 12/31/90
- 4) Program fully implemented. 02/22/90 09/30/90 (DET:.2.1.1.7, 2.1.1.10, 2.1.3.3, 2.1.3.10, 2.1.4.1, 2.1.4.2 and 2.1.4.3) l
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1990 - 1994 BUSINESS PLAN 7 .
1 I PROJECT / ACTIVITY PLANNING RECORD w/
I PROGRAM TITLE: C. Operations & Maintenance l'
PROGRAM LEAD: Director Nuclear Operations PRIORITY: High PROJECT / ACTIVITY TITLE: 10. Professionalism DESCRIPTION: Change culture to ensure operations, maintenance and support activities are conducted with appropriate formality, pro-fessionalism, procedure compliance and the recognition of Technical Specification and LCO conservatism in operations.
OBJECTIVES: Promote attitudes and behavior patterns and recognize 4
individual accountability and ownership for performing' assigned tasks.
ACTION PLAN
SUMMARY
START- COMPLETION-l- ACTION DATE DATE
- 1) Establish senior management group to Complete r~N. formulate program. (01/30/90) l ( ,[ 2) Implement methods / programs to obtain and Complete maintain industry experience.
l 3) Review existing directions on logs and 04/01/90 10/01/90 watchstander rounds and implement desired.
changes (if any).
4)- Implement methods / programs to monitor, 01/01/90 03/01/92 teach and coach field activities in support of defined expectations.
l (DET 2.1.1.4, 2.1.1.6, 2.1.2.3, 2.1.2.5 and 2.1.2.9)
(SALP IV.A.3.b.2 and IV.G.3.b.2) l l
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1990 .1994 BUSINESS PLAN
. PROJECT /ACYIVITY PLANNING RECORD L
PROGRAM TITLE: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: See Action Plan !
l PROJECT / ACTIVITY TITLE: 11.a Procedures Upgrade - Operations '
DESCRIPTION: Provide improved human factor and technical content for operating procedures.
OBJECTIVES: Complete the general operating procedure upgrade effort currently underway on both units.
ACTION PLAN START COMPLETION ACTION DATE DATE
- 1) Hi Revise Operability Determination 01/15/90 Complete Procedure (1000.116), (DET 2.1.2.3)
- 2) Med Revise Temporary Modification procedure. 02/01/90 06/01/90 l (DET 2.1.2.11)
- 3) Med Complete operations department procedure 02/01/90 07/31/91 ;
upgrade to the procedure writers guide.
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(._,/ 4) Hi (DET 2.1.2.9)
Revise Conduct of Operations to: 02/01/90 07/02/90
- Require LCO log entries for surveillance testing that removes T.S. equipment from service. (DET 2.1.2.5)
- Clarify use of valve lineup /(exceptions) -
sheets. (DET 2.1.2.12)
- Include requirements for independent l verification of safety system valve lineups.
l -(DET 2.1.2.10)--
- Include the proper use of night orders.
1 c (DET 2.1.2.6)
- 5) Med Incorporate recommended enhancements in 06/07/90 09/04/90 log taking obtained from the survey being conducted by operations into the appro-priate procedure. (DET 2.1.2.5)
- 6) . Med Revise Operations Procedure Revirion 04/16/90 06/15/90
- Control procedure. (DET 2.1.2.9)
- 7) Hi Equipment status tracking procedure N/A 03/31/90 implemented.
(DET 2.1.2.3, 2.1.2.5, 2.1.2.6, 2.1.2.9, 2.1.2.10, 2.1.2.11, 2.1.2.12, and 2.1.4.6)
(SALP IV.G.3.b.1) im
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1990 - 1994 BUSINESS PLAN t PROJECT / ACTIVITY PLANNING RECORD 4
PROGRAM TITLE: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: Medium PROJECT / ACTIVITY TITLE: 11.b Procedure Upgrade - Maintenance DESCRIPTION: Improve both technical and human factors content of r maintenance procedures. ;
4 OBJECTIVES:-
- a. Complete the maintenance procedure upgrade effort.
ACTION PLAN SIR &!ARY:
START COMPLETION ACTION DATE DATE
- 1) Commence the PWG upgrade on the remaining 02/01/90 11/30/90
-s 275 maintenance procedures on 02/01/90 and
) complete the effort.
- 2) Ensure conduct of maintenance procedure 01/02/90 Complete provides appropriate steps for work package verification. (DET 2.1.3.8)
(DET 2.1.3.8 and 2.1.3.9) ,
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'1990 - 1994' BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD
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' PROGRAM TITII: C. Operations & Maintenance PROGRAM LEAD: Director Nuclear Operations-PRIORITY: High
. PROJECT / ACTIVITY TITLE: 11.c Procedure Upgrade - Emergency Operating DESCRIPTION: Improve both technical and human factors content of Emergency Operations. procedures.
OBJECTIVES: Make E0Ps more useable by operators and provide assurance !
of Technical adequacy.
4 ACTION PLAN
SUMMARY
ry
). START COMPLETION ACTION DATE DATE
- 1) Complete the upgrade of both units' E0Ps to Continuing 07/01/91 ensure operator useability.
- 2) Upgrade both units' E0Ps to reverify 04/02/90 12/31/91 technical basis is adequate.and documented.
(DET 2.1.2.9)
-r 1990 - 1994 BUSINESS PLAN
, )- PROJECT / ACTIVITY PLANNING RECORD E PROGRAM TITLE: C. Operations and Maintenance PROGRAM LEAD: Director Nuclear Operations PRIORITY: High PROJECT / ACTIVITY TITLE: 12.a Backlog Reduction - Corrective Maintenance E
DESCRIPTION: Reduce the corrective maintenance backlog to a nominal
_3 , ,
level consistent with industry standards.
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OBJECTIVES:
- a. Define Corrective Maintenance Backlog. _
- b. Reduce Corrective Maintenance Job Order Backlog to Industry !
Standards. 1 ACTION PLAN
SUMMARY
START COMPLETION; "s ACTION DATE DATE t
\_/ 1) Identify and analyze Corrective Maintenance 02/15/90- 06/15/90 backlog, d
- 2) Establish a base Corrective Maintenance: 04/01/90 08/15/90 Backlog.
- 3) Prioritize backlog. 02/15/90 06/15/90 ,
- 4) Develop action plan to reduce backlog:
a) Reduce backlog >3 months old to 40% 06/01/90 07/01/91 of total. j fl b) Reduce backlog > 3 months old to 20% of l total by 06/01/90 07/01/92 1 (DET 2.1.1.7, 2.1.2.7, 2.'.2.8, 2.1.3.1, 2.1.3.5 and 2.1.5.7) ;
(SALP IV.A.3.b.5 and IV.G.3.b.1) {
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i l$2 s 1990 - 1994 BUSINESS FLAN I
( \ " i L = i, J ; PROJECT / ACTIVITY PLANNING RECORD !
u j 7 + PROGRAM TITLE: C. Operations & Maintenance j PROGRAM LEAD: Director Nuclear Operations !
t e, PRIORITY:- 'High l
PROJECT / ACTIVITY TITLE: 12.h Backlog Reduction - Preventive Maintenance i DESCRIPTION: . Reduce the Preventive Maintenance (PM) backlog to a
~ nominal level consistent with industry standards.
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OBJECTIVES: ~ .
- a. Reduce overdue Q, S and F PM's, i
- b. Reduce overdue mandatory PM's.
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SUMMARY
START COMPLETION ,
ACTION DATE DATE' l
- 1) Evaluate PM process for tracking'and 02/01/90_04/15/90
' scheduling. .
- 2) Define PM Backlog and provide target 03/01/90 .10/30/90 .j identification schedule. ..
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- 3 (DET 2.1.3.1, 2.1.3.5 and 2.1.3.6) i
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- _ 1990-1994 DUSINESS PLAN APPENDIX [
D. Design Engineering & Modification -
Program Lead: General Manager - Engineer ,
Projects / Activities
- 1. Engineering Backlog Elimination
- 2. Engineering Resource Plan :
- 3. Relocation of Design Engineering
- 4. Performance Indicators
- 5. Engineering Improvement Programs
- a. Air Operated Valve Program (A0V)
- b. Fire Protection Probability Risk Assessment '
- c. Penetration Seal Program Assessment
- e. Response to Bulletins 79-02/79-14 Follow-up Inspection Report 50-313/89-200
- f. Corrective Action Program (Condition Reporting System) .
g.- Seismic Qualification of Equipment (SQUG)
- h. Engineering Procedure / Standards Upgrade and Maintenance t
- 1. Design Process Improvements
- k. Environmental Qualificatien Program Upgrade
- 1. Plant Life Extension q m. Upgrade AND Check Valve Program g n. Inservice Inspection Improvement Program ;
- o. ANO Welding Program Review / Upgrade
- p. Fire Protection System Code Compliance Verification Project l q. Upgrade of Secondary Pipe Wall Thinning Program l r. Upgrade Appendix J CLRT Program ;
Y. s. Program for the Removal of Fire Protection Requirements from Technical Specifications i m t. Upgrade Ventilation / Filtration Testing Program
- u. ASME Section XI Repair / Replacement Program I v. ANO-1 OTSG Secondary Side Fouling l w. Steam Generator Eddy Current Testing Program l x. Formalize Boric Acid Inspection Program l y. Steam Generator Chemistry Improvements ,
- z. Inservice Testing (IST) Program
- 6. Design Basis
- a. Design Configuration Documentation (DCD)
- b. Isometric Drawing Upgrade (IUP)
- c. Electrical Drawing Upgrade (EDU) l d. Structural Design Program (SDP)
- e. Plant Setpoint Control Program (PSCP) l 7. Training
- 8. Facilities
- 9. Engineering Department Communications Plan
- 10. Self-Assessment (SSFI)
- 11. Industry Experience
(']
- 12. Configuration Management and Control V
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i 1990 - 1994 BUSINESS PLAN -
PROJECT / ACTIVITY Pl.AhNING RECORD (O') t PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering i PRIORITY: See Action Plan i i
PROJECT / ACTIVITY TITLE: 1. Engineering Backlog Elimination Project DESCRIPTION: A significant backlog of Engineering work exists. This '
. involves a number of requests for Engineering support from groups both :
inside and outside of Engineering. The need for Engineering resolution ,
I and/or information often prevents other groups from performing needed actions.
OBJECTIVES: ,
- a. To reduce Engineering backlog to a manageable level by '
dispositioning items systematically commensurate with safety i significance. ;
r ACTION PLAN SUMMAltY:
START COMPLETION O ACTION- DATE DATE
'J
- 1) lli Define scope of project and develop a 02/01/90 04/15/90 l project plan.
- 2) lli Identify and prioritize backlog elements 04/26/90 06/01/90 considering safety significance. .
- 3) Med Set reduction goals by type and 04/05/90 04/22/90 define dispositioning methods. !
- 4) lli Formalize interaction with system 04/05/90 04/22/90 engineering. *
- 5) 11 1 Process backlog. 04/26/90 0,/26/93 (DET 2.1.1.7, 2.1.2.7, 2.1.5.4, and 2.1.5.7) ;
(SALP IV.G.3.b.1) .
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1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD
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PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: See Action Plan PROJECT / ACTIVITY TITLE: 2. Engineering Resource Planning DESCRIPTION: A detailed plan is needed to provide direction to Engineer-ing Managers and }Iuman Resources in obtaining and retaining Engineering resources necessary to accomplish the Engineering scope of work. This plan will address the manpower requirement of routine, program improvements, projects, DCP, and backlog reduction. The plan will define the approximate staffing level and contractor mix to execute the work while reducing long-term reliance on contractors for routine work and improving in-house involvement and ownership in selected projects. The plan will account for utilization of Entergy system resources as appropriate.
OBJECTIVE 5:
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- a. Recruit and retain the resources to execute the engineering programs and projects over the next five years,
- b. Reduce our dependence on contractors to an appropriate level.
- c. Recruit and retain the resources necessary to provide Engineering, support to Operation and Maintenance.
- d. Maintain the Engineering Resource plan.
ATTION PLAN
SUMMARY
- START COMPLETION ACTION DATE DATE 7
q
") 1) lli Define workload according to classifi-cation of routine, DCPs, (development 01/15/90 02/27/90 and installation), improvement projects and backlog by management unit.
(2.1.5.3, 2.1.5.4, 2.1.5.8)
- 2) lli Define historical and project resources 01/20/90 02/27/90 required by line item. (2.1.5.3, 2.1.5.4, 2.1.5.8)
- 3) Med Define recruiting issues. (DET 2.1.5.3) 01/28/90 04/15/90
- 4) Med Define retention issues and develop 01/28/90 04/15/90 actions to address each issue.
(DET 2.1.5.3)
- 5) Med Complete inventory of existing resources. 01/15/90 04/10/90 identify unique skill requirements.
- 6) 11 1 Obtain information from other system 03/01/90 03/30/90 sites relative to staffing levels, mix, contracting approach, and workloads.
- 7) lli Using all information gathered, develop 02/28/90 04/15/90 specific targets for internal staffing levels and contractor levels. (2.1.5.3, 2.1.5.4)
- 8) Med Establish mechanism and frequency for 07/15/90 08/31/90 update of the plan.
- 9) Low Obtain independent assessment of the 02/28/90 04/30/90 final plan (Staffing study, Business
/' Plan }>6).
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? ACTION PLAN
SUMMARY
- $ START COMPLETION, ACTION DATE DATE-
.y +
- 10) Ned Formalise 18 month planning process- 05/01/90' 06/01/90
' /'N defining the review, approval, update and- .;
M., _
revision method, and content as. included .i modifications and improvement projects. I t .(DET 2.1.1.9, 2.1.5.3, 2.1.5.4, 2.1.5.8 and 2.1.5.15) :
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l 1990 - 1994 BUSINESS PIAN :
/ 1 PROJECT / ACTIVITY PLANNING RECORD L _J '
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: See Action Plan [
PROJECT / ACTIVITY TITLE: 3. Relocation of Design Engineering to j the Site j i
DESCRIPTION: The ANO Design Engineering Department along with other !
LRGO Nuclear Operations personnel will be relocated to the ANO site in !
1990. A relocation plan will be established to support the objectives of ;
- i. the relocation. Appropriate facilities to support the relocated i personnel are being designed and constructed to house the individuals and [
quality related engineering records and equipment. Relocation plans to .,
allow for the orderly movement of offices from LR to the site will be '
developed. lluman Resources plans to provide relocation assistance are j discussed in section G-2. t OBJECTIVES: ;
- a. Maintain level of engineer support to ANO during the relocation. '
- b. Maintain required progress on engineering nrograms including ;
, Besiness Plan iteins. !
(' ,) c. Maintain auality of engineering work products during relocation
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ACTION PLAN
SUMMARY
START COMPLETION ACTION. -
DATE DATE !
- 1) lli Develop Engineering office relocation 02/28/90 03/15/90 !
plan and communicate to individuals.
(DET 2.1.5.3) '
- 2) 11 1 Provide input to the design and provide 01/20/90 02/15/90 Project Engineer to construction of new ,
facilities. (DET 2.1.5.3)
- 3) lli Evaluate impacts on plant support and 03/01/90 04/30/90 t prepare contingency plans to minimize i schedule impacts. (DET 2.1.5.3)
- 4) lli . Relocate office equipment, furniture 08/01/90 09/31/90 and quality records. (DET 2.1.5.3) ;
- 5) Low Perform assessment of effectiveness of 10/01/90 12/31/90 relocation. (DET 2.1.5.3)
(DET 2.1.5.3 and 2.1.5.5)
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1990 - 1994 BUSINESS PLAN i
PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: D. Design Engineering and Modifications t
PROGRAM LEAD: General Manager Engineering PRIORITY: Low PROJECT / ACTIVITY TITLE: 4. Performance Indicators e
DESCRIPTION: To focus the Engineering Managers and provide a standardized means of measuring Engineering's performance, a set of performance indicators are being developed.
OBJECTIVES:
- a. To establish a set of Performance Indicators to focus Engineering activities (including INPO indicators for Design Engineering).
- b. To establish a program to maintain the indicators and provide periodic status reports.
- c. To provide indicators consistent with Entergy system objectives.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE_
I-
- 1) Identify the indicators and source of 06/01/90 06/29/90 information which should be monitored for Design Engineering and Modifications.
Obtain information from Entergy system sites relative to indicators monitored and their experience to date.
- 2) Identify the type display for each 06/29/90 07/13/90 indicator.
- 3) Integrate those indicators into the 06/29/90 07/13/90 Department Goals and Objectives.
- 4) Obtain input from system peer groups 07/20/90 08/01/90 relative to proposed approach.
- 5) Formalize a program and assign 07/13/90 08/01/90 responsibility for maintaining the indicators.
- 6) Establish a frequency of the reports. 07/20/90 08/01/90 l
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i 1990 - 1994 BUSINESS PLAN f
, . PROJECT / ACTIVITY PLANNING RECORD i LI\_) - -
PROGRAM TITLE: D. Design Engineering and Modifications ,
i PROGRAM LEAD: General Manager Engineering l l
PRIORITY: Medium i i
PROJECT / ACTIVITY TITLE: 5.a Engineering Improvement Programs - Air ,
Operated Valve Program (A0V) j DESCRIPTION:- Develop a program similar to the existing Motor Operated ,
Valve Program designed to capture the design basis of the system and i establish a design database of vendor references, design calculations, l and field settings for valves. [;
OBJECTIVES: Improve the design basis knowledge of the A0Vs. Support -
Operations and Maintenance in their various activities. Improve the -!
performance of the valves.through maintenance or modifications based on ;
design basis evaluations.
ACTION PLAN
SUMMARY
START COMPLETION f ACTION DATE DATE l
,_ 1) Define the population of safety-related 01/01/91 02/01/91 !
l A0Vs. (DET 2.1.5.13)
-2) Develop program documents, definition 01/01/91 08/01/91 ,
of scope of evaluations, and budget /
schedule estimates. (DET 2.1.5.13)
- 3) Develop design basis evaluations and. 08/01/91 12/31/92 t databases assuring consistency with DCD l project. (DET 2.1.5.13)
(DET 2.1.5.13) !
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1990'- 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD I i
> PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Low PROJECT / ACTIVITY TITLE: 5.b Entineering Improvement Program - Fire Protection Probabilistic Risk Assessment DESCRIPTION: To assess the risk significance associated with various fire protection issues and develop fire PRAs as necessary utilizing experience from other system sites. This will be coordinated with
- overall ANO-response to a proposed Generic Letter for Individual Plant Evaluation for External Events.
OBJECTIVES:
- a. Review and quantify certain fire risk scenarios,
- b. Formulate list of fire risk issues.
- c. Assess the effectiveness of plant fire protection program implementation.
- d. Maintain consistent approach with other System sites.
('~)/.
s_s ACTION PLAN
SUMMARY
START COMPLETION ACTION _DATE DATE
- 1) Determine approach utilized by other 01/01/93 02/01/93 system sites.
- 2) Issue project plan for this project. 02/01/93 04/01/93
- 3) Assess control systems interactions. 04/01/93 08/01/93 4)' Assess manual fire fighting 08/01/93 10/01/93 effectiveness.
- 5) Assess fire / seismic interactions. 10/01/93 04/01/94
- 6) Determine total environment equipment 04/01/94 10/01/94 survival.
- 7) Issue report. 10/01/94 12/31/94 D-7
f 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering !
PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5.c Engineering Improvement Program - '
Penetration Seal Prograa Assessment DESCRIPTION: To provide assurance that installed fire penetration seals are of adequate design. (Ref. SCAN 1288$7, PCNApl8993, PCNA928929, s
$CAN@389P6, PCAN038911, PCANp98719) i OBJECTIVES:
- a. Verify physical configuration of Tech Spec. penetration seals.
- b. Perform evaluations of seal designs which deviate from tested
- configurations,
- c. Develop data base and procedures for seal configuration management.
- d. Correct deficiencies identified with seal designs considered inadequate. ,
- e. Provide approach consistent with other System sites and DCD Program. ,
ACTION PLAN
SUMMARY
r] START COMPLETION d ACTION DATE DATE
- 1) Asseas AP&L fire test reports. 01/02/90 04/02/90
- 2) Ar2emble information, procedures, and 01/02/90 01/08/90 data base designs from other system sites.
- 3) Develop procedural guidelines for seal 01/08/90 03/05/90 evaluations.
- 4) Develop computer data base for penetra- 01/02/90 04/02/90 tion seal management and control.
! 5) Validate installed penetration seal 04/02/90 12/31/91 designs.
- 6) Input verified seal information into 04/02/90 12/31/91 computer data base.
- 7) Perform engineering evaluations of 03/05/90 12/31/91 deficient seal designs as necessary.
- 8) Replace seals found unacceptable. 04/02/90 12/31/91 (3
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e 1990 - 1994 BUSINESS PLAN L PROJECT / ACTIVITY PLANNING RECORD l \
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5.d Engineering Improvement Program - Des'ign Engineering Support of AN0's MOV Program DESCRIPTION: AN0's HOV Program is to ensure that all safety-related MOVs will perform their functions against design' basis conditions.
This program is in support of NRC IE Bulletin.85-03 and General Letter 89-10. Design Engineering's support of this effort includes design basis reconstitution, development of valve data base, and field support.
OBJECTIVES:
- a. To establish the design basis conditions at which valves will be required to operate.
- b. To provide setpoint calculations to allow proper setting of these valves in the field,
- c. To provide criteria in the differential pressure testing of these valves,
- d. To review the electrical design basis of each valve (i.e., overload heater sizing, cable sizing, breaker setting, etc.).
- e. To provide a comprehensive information management and retrieval V) system for the Design Bases and Design Output Documents.
- f. To support the field testing efforts.
ACTION PLAN
SUMMARY
- COMPLETION START ACTION DATE DATE
- 1) Identify all valves in program. 02/01/90 06/28/90 (DET 2.1.5.13)
- 2) Establish schedule for testing. 05/01/90 07/01/91 (DET 2.1.5.13)
- 3) Perform design basis review (mechanical 07/01/90 03/01/93 and electrical). (DET 2.1.5.13)
- 4) Compare ANO existing program to other 05/01/90 10/01/90 system site programs and adjust as appropriate. (DET 2.1.5.13)
- 5) Perform setpoint calculations. 05/01/90 01/01/94 (DET 2.1.5.13)
- 6) Support field testing efforts. 05/01/90 06/01/94 (DET 2.1.5.13)
(DET 2.1.3.7 and 2.1.5.13) g D-9
i 1990 - 1994 BUSINESS PLAN q( PROJECT / ACTIVITY PLANNING RECORD V)
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5.e Engineering Improvement Program - Response to Bulletins 79-02 and 79-14 Follow-Up Inspection Report 50-313/89-200 DESCRIPTION: Several specific and generic concerns associated with AP&L documentation and practices were identified in Inspection Report 50-313/
89-200. AP&L needs to perform requested analysis, develop and implement requisite programs and procedures, and provide necessary technical justifications for existing design practices.
OBJECTIVES:
- a. To perform the requisite analysis,
- b. To document the necessary technical justifications,
- c. To address all concerns identified in the NRC Inspection Report.
e,
( ~ ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Perform all requisite analysis and 01/01/90 12/31/90 design work.
- 2) Implement necessary changes to 01/01/90 06/01/91 programs and procedures.
- 3) Document technical justification 01/01/90 06/01/91 of methodologies.
- 4) Submit summary report to the NRC 05/01/91 06/01/91 and schedule a follow-up inspection.
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D-10 l .
1990 - 1994 BUS 1 NESS PLAN
, PROJECT / ACTIVITY PLANNING RECORD
/ i I. ' l PROGRAM TITLE: D. T)esign Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5.f Engineering Improvement Program -
i Corrective. Action Program (Condition Reporting System)
ITESCRIPTION: The Condition Reporting System (CRS) is a system that identifies, tracks, and resolves significant conditions, events, or deficiencies that exist within plant systems, components,'or processes.
The CRS has been developed as a singular corrective action program i governing plant activities.
OBJECTIVES:
- a. Maintain.s singulac corrective action program to identify, track, control and resolve significant plant conditions.
- b. Establish management participation and visibility in corrective ;
action processes. '
?
- c. Establish a consolidated system of tracking and trending significant y conditions for input to changes in process, resource allocations, t and planning activities, t
- d. Improve the content and timeliness of corrective actions responses.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE i
- 1) Define predicted workload associated 02/01/90 04/15/90 ,,
with the CRS and plan the resources required for implementation. ,
(DET 2.1.5.4, 2.1.5.7)
- 2) Establish data base'and workload 03/01/90 07/01/90-controls to allow management of the CRS action items, heatup restraints, i and interties to various process '
tasks (DCPs, LIRs, PCs, ot.her engineering tasks). (DET 2.1.5.4, 2.1.5.6,2.1.5.7)
(DET 2.1.1.10, 2.1.5.4, 2.1.5.6 and 2.1.5.7)
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- f. 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: D. Design Engineering and Modifications
- (v)
PROGRAM LEAD: General Manager Engineering PRIORITY: High PROJECT / ACTIVITY TITLE: 5.g Engineering Improvement Program -
i Seismic Qualification of Equipment in Response to NRC_ Unresolved Safety Issue (USI) A-46 as defined in Generic Letter 87-02 DESCRIPTION: Generic Letter 87-02 identified an NRC safety concern that
, inadequate margins of safety may exist for essential equipment at 5
operating nuclear power plants to withstand a safe shutdown following an
, ea rthquake.' A nuclear industry group called the Seismic Qualification Utility Group (SQUG) was formed to demonstrate that past earthquake experience data can be used to verify the seismic adequacy of equipment at nuclear power plants and that'a generic approach to the resolution of this issue would be the most cost effective, The NRC has agreed with the SQUG position and has endorsed the development of generic criteria and guidelines to be used in the resolution of this issue.
OBJECTIVES: To evaluate the adequacy of selected equipment at ANO to withstand a safe shutdown earthquake.
Q ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Determine approach (project plan) 01/01/00 12/31/90 consistent with other Entergy system sites and maintain present Icvel of industry group involvement.
- 2) Identification of essential systems 10/01/90 03/01/92 L and electrical circuits required to provide safe shutdown.
l 3) Visual inspections of the identified 09/01/91 12/31/92 equipment by a team of engineers to verify adequate equipment anchorage and check for L spatial interaction with surrounding equipment.
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D-12
F 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineerir, PRIORITY: Mediun PROJECT / ACTIVITY TITLE: 5.h Engineering Improvement Program -
Engineering Procedure / Standards Upgrade And Maintenance DESCRIPTION: Engineering process procedure presently in existence (Generation Transmission Engineering Procedure) needs to be upgraded as identified by QA audits. The procedures are not efficient and are difficult to follow thus increasing the possibility of error. Some organizational interfaces are defined in temporary changes to procedure and few procedures are in a format consistent with existing ANO procedures.
Recent organizational changes and QA manual require that Engineering process procedure be in accordance with AND Administrative procedures and reviewed by PSC.
OBJECTIVES:
- a. To combine current Procedures / Standards Responsibility under one management group within Engineering.
- b. Integrate Engineering's Procedures with other ANO Procedures.
- c. Eliminate the overlap / redundancy that exists in the current systems.
)
.( d. Provide for the maintenance of Engineering Procedures.
V e. Provide approach / process compatible with other system sites.
ACTION PEAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Action the responsibility for 01/01/90 02/01/90 Procedures / Standards to single manager.
- 2) Identify all of the current 02/01/90 04/01/90 Procedural / Standard's Documents being used within various Engineering groups,
- 3) Assess methods utilized by other 03/15/90 05/15/90 System sites.
- 4) Standardize the Nethodology and 04/01/90 06/01/90 Program approach with the other ANO Standards' Groups. Develop the Project Plan.
- 5) Upgrade of Engineering Procedures. 06/01/90 TBD by Item 4 i
D-13
f l
1990 - 1994 BUSINESS PLAN
) PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering i
PRIORITY: See Action Plan PROJECT /ACTIVI1Y TITLE: 5.1 Engineering Improvement Program -
Design Process Improvements DESCRIPTION: Study the modifications process at the three Entergy sites (GGNS, Waterford, and ANO) and provide information in preparation for Entergy consolidation.
OBJECTIVES:
- a. Improve the Design Process by taking advantage of good practices used at other sites,
- b. Initiate comn.unication between common managers at the Entergy site.
- c. Aid in the consolidation study.
- d. Improve modification request screening process to assure management involvement in project selection and resource allocation.
- g. Provide definitive scope and consistent estegorization, prioritization, euthorization and tracking of programs / projects to (S allow more focused management attention.
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)
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Low Sort out language distinctiont,/ commonality Complete of the various. system site processes.
- 2) Low Prioritize issues in order of resolution. Complete
- 3) Low Identify distinctions in site methods / Complete processes.
- 4) Med Revise modifications procedures to 02/02/90 04/13.'90 provide senior management screening of requests. (DET 2.1.5.4)
- 5) Low Prepare a preliminary draft report for 02/19/90 04/16/90 review / comment by the three site manage-ments. (DET 2.1.5.4)
- 6) Low Prepare the final report to the team 05/15/90 08/01/90 leaders of the Plant Modifications and Construction study group.
- 7) Med Issue project / program control _ 03/05/90 06/15/90 specification guidelines. (DET 2.1.5.15) 8)- Med Establish project / plan document for each 06/20/90 12/31/90 existing project / program. (DET 2.1.5.15)
(DET 2.1.5.4 and 3.1.5.15)
,m-D-14
1990 - 1994 BUSINESS PLAN
') PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium $
PROJECT / ACTIVITY TITLE: 5.j Engineering Improvement Program -
Probabilistic Risk Assessment DESCRIPTION: In order to satisfy NRC Generic Letter 88-20, regarding severe accident issues, AP&L is performing Probabilistic Risk Assessments (PRA) for ANO-1 and ANO-2. The development of these models will provide ANO a risk-based inanagement tool to assess operation, maintenance, and engineering activities.
OBJECTIVES:
A. To create PRA modelt, suitable for addressing all regulatory issues regarding severe accidents.
B. To integrate the PRA models into routine work activities including plant design, maintenance activities, licensing, human factors, etc.
in order to improve various aspects of these work processes.
C. Develop in-house PRA expertise.
7s Q) ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Complete IPE requirements as committed 01/01/90 12/31/91 to NRC.
- 2) Implenent plan for PRA application. 06/25/90 01/30/91
- 3) Institute update / maintenance controls 06/25/90 _C6/15/91 to ensure PRAs are "living models".
- 4) Pormalize use of PRA with existing 02/01/91 09/15/91 Engineering processes.
V D-15 t-
I '
I l ,
l l i 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD J
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium s
PROJECT / ACTIVITY TITLE: 5.k Engineering Improvement Program -
Environmental Qualification Program Upgrade DESCRIPTION:
The requirements associated with the environmental qualification (EQ) regulations have impacts upon operation and maintenance, Engineering, Training and Licensing processes at ANO. Several programmatic improvements are needed to more effectively control and provide improved support relative to maintenance and operation activities.
i OBJECTIVES:
- a. To establish a dedicated program resource for the ANO EQ program to support all affected organizations,
- b. To review and upgrade as appropriate the EQ documentation, procedure and program activities,
- c. Assure approach consistent with other system sites.
ACTION PLAN
SUMMARY
(~ } START COMPLETION
ACTION DATE DATE
- 1) Assign EQ Program responsibility. 02/01/90 03/20/90
- 2) Specific performance needs assessment 02/01/90 05/01/90 of present EQ Program as it relates to maintenance and operations.
- 3) Establish specific program plan. 04/01/90 05/01/90 -
- 4) Detennine methods and approach used 03/01/90 05/01/90 by other system sites to address this issue.
- 5) Initiate and implement each special upgrade 05/01/90 06/01/90 activity.
~
D-16
C, '
1990 - 1994 BUSINESS PLAN l PROJECT / ACTIVITY PLANNING RECORD f:(h PROGRAM TITLE:
PROGRAM LEAD:
D. Design Engineering and Modifications General Manager Engineering PRIORITY: Low PROJECT / ACTIVITY TITLE: 5.1 Engineering Improvement Program -
Plant Life Extension DESCRIPTION:
This program is to provide a mechanism for extension of the operating license for each ANO plant beyond the current license duration of 40 l years. This will be accomplished by establishing a program that monitors t
those plant components that are important to safety, are subject to
[ degradation from aging and are not routinely subject to renewal during normal maintenance. The program will also evaluate the remaining life of
~
the components for possible replacement and provide documentation of the evaluation and monitor for submittal to the NRC for license renewal.
, OBJCCTIVES:
- a. Be prepared to support ANO-1 license extension application to the NRC.
- b. Be prepared to support ANO-2 license extension application to the NRC.
- c. Coordinate plant life extension activities with the other System plant sites.
ACTION PLAN
SUMMARY
START COMPLETION
[] /
ACTION DATE DATE
- 1) Participate in the B&W Owners Group 01/01/91 12/31/94 Plant Aging and Life Extension (PALEX) committee and other industry activities as needed.
+
- 2) Provide a program plan or charter for 07/01/91 12/31/93 ANO life extension activities that details the requirements for license extension, how existing plant departments or programs-interface with those requirements, and recommendations for any new support that would be needed.
, 3) Preparation of interface with Licensing 01/01/91 07/01/99 for documentation needed for submittal to the NRC.
.,m
\
D-17 I
F L
r 1990 - 1994 BUSINESS PLAN
, PROJECT / ACTIVITY PLANNING RECORD ,
PROGRAM TITLE: D. Design Engineering and Modifications ,
t PROGRAM LEAD: General Manager Engineering PRIORITY: High PROJECT / ACTIVITY TITLE: 5.m Engineering Improvement Program -
Upgrade ANO Check Valve Program
'ESCRIPTION:
D Review and update the ANO Check Valve Program, incorporating ANO and industry experience. Review will include documentation that all necessary valves are in the program.
OBJECTIVES:
- a. Provide a controlling program document for the ANO check valve program,
- b. Ensure that appropriate check valves are in the program,
- c. Develop a PC data base for check valve program.
- d. ANO check valve program will provide an approach consistent with -
ether System sites.
ACTION PLAN
SUMMARY
~, START COMPLETION tv) ACTION DATE DATE
- 1) Ensure all the necessary valves are in 04/30/90 11/30/90 the program, based on INPO recommen-dations, ANO and industry experience, NRC bulletins and notices, other System sites' experience.
i (DET 2.1.5.13)
- 2) Make necessary revisions to the check 11/30/90 12/31/90 valve inspection procedure based on the review. (DET 2.1.$.13) '
- 3) Develop and issue a program document 01/02/91 04/30/91 consistent with other System sites that contains the basis for the program content and all necessary information about how the o program functions. (DET 2.1.5.13)
- 4) Compile historical and technical 01/22/90 06/30/90 information on all program valves into a PC data base.
- 5) Complete the Design Evaluation of ANO 01/22/90 06/01/90 1 and 2 Check Valves Per INPO SOER 86-03.
(DET 2.1.5.13)
LJ ,
b D-18
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD l s PROGRAM TITLE: D. Design Engineering and Modifications I
(l PROGRAM LEAD: General Manager Engineering PRIORITY: See Action Plan PROJECT / ACTIVITY TITLE: 5.n Engineering Improvement Program - '
Inservice Inspection Improvement Program DESCRIPTION: Based on concerns identified by AP&L's Nuclear Quality and ISI group, and NRC inspections, the ISI Program h6s areas that required improvement.
OBJECTIVES:
- a. Establish a computer data base of the ISI Programs and examinations,
- b. Perform an independent review of the first 10 year programs for both units,
- c. Establish a calibration block program, identifying and performing the modifications to the blocks which are required or submitting relief requests,
- d. Review the upgrade of ANO-2 to the 1986 Edition of the ASME Code,
- e. Develop procedures, standards, and guidelines for hydrostatic and pressure tests.
- f. Upgrade of ANO-1 ISI Program required in 1994.
- g. Provide approach consistent with other System sites.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE C, 1) lli Review programs at other System sites and 02/05/90 06/01/90 determine best methods.
- 2) lli Enter computer data for ANO-2 required 01/15/90 03/26/90 examinations and performance data for completion of initial reviews of ANO-2 first 10-year program.
- 3) lli Enter computer data for ANO-1 required 03/27/90 06/30/90 examinations and performance data for completion of initial reviews of ANO-1 first 10-year program, t
- 4) lli Review of ANO-2 upgrade to 1986 Code and 06/30/90 08/15/90 data entry completion.
- 5) Med Enter ANO-1 data for 2nd 10 year 06/30/90 08/15/90 program.
- 6) 11 1 Review calibration block program and 01/01/90 05/15/90 I upgrade as required.
- 7) Med Upgrade ISI procedure. 05/01/90 12/31/90
- 8) Med ANO-1 performance data entry for 2nd 10/15/90 03/01/91 10 year program.
- 9) Med Upgrade the hydrostatic and pressure 01/01/90 12/31/90 testing program.
- 10) Med Complete program improvements with 12/31/90 12/31/94 resolution of identified problems over two refueling outages on each unit.
- 11) Med Upgrade ANO-1 ISI Program to 1986 02/01/91 12/31/91 l /
A code, if desired.
b (DET 2.1.4.2)-
D-19 1
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD
! ) -
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5.o Engineering Improvement Program -
ANO Welding Program Review / Upgrade DESCRIPTION: The present Welding Program at ANO needs improvement in program administration and technical content. The welding program needs to be revised to be more consistent with other System sites.
OBJECTIVES:
- a. Revise the Welding Administrative Program to improve efficiency of maintenance and modifications activities.
b: Elinainate programmatic problem areas through optimizating administra-tive controls and technical content and eliminating overlap / redundancy.
- c. Enhance training program for personnel who perform and monitor welding program activities.
- e. Assure administration process is compatible with other System sites.
ACTION PLAN
SUMMARY
START COMPLETION ACTION (3) DATE DATE
- 1) Define methods and approaches of 03/01/90 09/31/90 other System sites.
- 2) Review welding procedures and specifi- 01/01/91 12/31/91 cations for correctness of code required essential variables. Optimize parameters to existing supporting welding qualification and qualffy additional new procedures as required to support a broader range of plant applications.
- 3) Review overall program to ensure appro- 01/01/91 12/31/91 '
priate administrative control and consistency is maintained with other System sites and to assure technical adequacy. In addition, eliminate program deficiencies through procedural enhancement.
-4) Provide training to welding and 12/01/91 01/31/92 engineering personnel relative to the program.
/ ~'s
, U.)
D-20
r:
]
L' !
L 1990 - 1994 BUSINESS PLAN
! PROJECT / ACTIVITY PLANNING RECORD l l t t A,,/
PROGRAM TITLE: D. Design Engineering and Modifications !
PROGRAM LEAD: General Manager Engineering i i
PRIORITY: Low l PROJECT / ACTIVITY TITLE: 5.p Engineering Improvement Program -
Fire Protection System Code Compliance ,
Verification Project DESCRIPTION: To assure that required Fire Protection and Detection i Systems are installed in compliance with applicable design standards as committed to in NRC/ANO correspondence. ,
OBJECTIVES:
- a. Verify physical configuration of NRC required Fire Protection
- Systems. '
- b. Perform evaluation of those designs that deviate from design standards,
- c. Correct deficiencies which are considered inadequate, ,
s ACTION PLAN SLMMARY: '
START COMPLETION ACTION DATE DATE i fi. \_')- 1) Evaluate program content of other 01/01/91 01/15/91 i
System sites.
- 2) Assess NRC/ANO correspondence to 01/15/91 05/01/91 l determine applicable design standards. ;
- 3) Validate installed system designs 07/01/91 12/31/92 to ensure compliance.
- 4) -Perform engineering evaluations of 07/01/91 12/31/92 >
deficient system designs or correct ,
deficiencies. i 4
h
(/
D-21
F l
1990 - 1994 BUSINESS PLAN ;
PROJECT / ACTIVITY PLANNING RECORD
/ ') -
i_/
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5.q Engineering Improvement Program - Upgrade of Secondary Pipe Wall Thinning Program DESCRIPTION: Complete the computer "modeling" of both ANO units on the EPRI CHEC and CHECMATE codes and forma.lize the entire Secondary Pipe Wall Thinning Program in a controlling program document.
OBJECTIVES:
- a. Complete the CHEC and CHECMATE modeling process for ANO-1 and 2. '
- b. Consolidate the entire pipe wall thinning program into one controlling document to ensure consistency of application.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Define all technical data necessary 01/02/90 06/01/90 for the CHEC and CHECMATE "modeling"
^x process. Information such as operating
()
'~'
history, flow parameters, temperature, pressure, steam quality, etc.
- 2) Use gathered data to complete the 03/12/90 09/01/90 "modeling" process.
- 3) Develop and issue a controlling 04/01/90 12/31/90 program document that contains the basis for the proEram content and all necessary information about how the program works.
--+=
Y,)
D-22
e -
t 1990 - 1594 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD .
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Managar Engineering PRIORITY: Medium t PROJECT / ACTIVITY TITLE: 5.r Engineering Improvement Program - ,
Upgrade Appendix J CLRT Program ;
DESCRIPTION: Complete necessary actions to upgrade the ANO Appendix J Containment Leak Rate Testing Program. Areas needing improvement include: procedures, testing equipment, design / licensing basis documentation.
OBJECTIVES:
- a. Provide an updated controlling program document for each ANO unit.
- b. Purchase / fabricate up-to-date testing equipment.
- c. Upgrade CLRT procedures.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Review other System sites' programs 03/30/90 06/30/90 s for input to ANO program.
(' ) 2) Complete and close open action items from the Containment Review Group project.
02/28/90 12/31/90
- 3) Upgrade testing equipment. 03/30/90 .30/01/90
- 4) Revise test procedures, based on 06/30/90 01/10/91 plant modes, test equipment changes, and input from other System sites.
- 5) Develop and issue a program document 06/01/90 04/30/91 for each unit of ANO.
l'
?
D-23 ,
J 1990 - 1994 BUSINESS PLAN <
p - -'s PROJECT / ACTIVITY PLANNING RECORD .;
"dv .)
PROGRAM TITLE: D. Design Engineering and Modifications
- t. PROGRAM LEAD: General Manager Engineering I
PRIORITY: Low PROJECT / ACTIVITY TITLE: 5.s Engineering Improvement Program - ,
o Program for the Removal of Fire Protection !
Requirements from Technical Specifications i
DESCRIPTION: Incorporate the NRC approved Fire Protection Program within the Unit 1 and Unit 2 Safety Analysis Reports and implement the ;
new fire protection Standard License Condition as delineated in Generic Letter 88-12.
n !
, OBJECTIVES:
- a. Institute the Standard License Condition for a Fire Protection Program,
- b. Remove requirements for fire protection systems from Technical :
Specifications.
- c. Remove fire brigade staffing requirements from Technical Specifications,
- d. Establish administrative controls which are consistent with other System Sites'_ programs for program maintenance. ,
!f~s) >
ACTION PLAN
SUMMARY
START COMPLETION
-ACTION DATE ._, DATE ;
- 1) _ Streamline the Fire Protection Program 01/01/91 12/31/91 Hanual to include only ERC related items.
- 2) Incorporate all operational conditions, 08/01/91 11/01/91 remedial actions, and test requirements presently included in Technical Specifica-tions within the Fire Protection Program Manual.
- 3) Develop and implement administrative controls 01/01/92 08/31/92 to ensure that requirements associated with '
the Fire Protection Programs are maintained.
- 4) Include the fire protection Standard 03/01/92 08/31/92 License Condition in each unit's Operating License and incorporate the Fire Protection - ,
Program requirements into the FSAR.
5.,
.$v .
D-24
~. _
I 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM 11TLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Low PROJECT / ACTIVITY TITLE: 5.t Engineering Improvement Program - Upgrade Ventilation / Filtration Ter, ting Program DESCRIPTION: Perform a cos ylete assessment and update of the Ventilation / Filtration Test.ng Program. New ANSI /ASME codes have been issued that require ANO review and possible procedure revisions for testing.
OBJECTIVES:
- a. Assess physical condition of ANO air filtration units, associated ductwork, and instrumentation,
- b. Ensure that the ANO program meets tha requirements of newly released ANSI /ASME codes for filter testing.
ACTION PIAN
SUMMARY
- START COMPLETION ACTION DATE ,
DATE
,m '
i Review System sites programs and 05/01/90 07/01/90 (d
1) testing criteria.
- 2) Walkdown and inspect selected ANO air 05/15/90 06/01/90 filtration units, associated ductwork, and instrumentation..
- 3) Initiate any necessary maintenance 06/01/90 07/01/90 and/or modifications to housings, doors, filter frames, dampers, ductwork, instrumentation, etc.
- 4) Review ANO testing procedures with 06/15/90 07/01/90 respect to compliance with newly released ANSI /ASME N509 and N510 standards.
- 5) Revise testing procedures, as necessary. 07/01/90 08/01/90
- 6) Develop and issue a program document 08/01/90 10/01/90 that contains the basis for the program content and all necessary information about how the program works.
l
! n G
D-25 l
1990 - 1994 BUSINESS PIAN PROJECT / ACTIVITY Pl.ANNING RECORD
, ( PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5.u Engineering Improvement Progrem -
ASME Section XI Repair / Replacement Program DESCRIPTION: With the upgrade of ANO-2 to the 1986 Edition of ASME Section XI on March 26, 1990, the repair / replacement activities for both ANO-1 and AAO-2 will be in accordance with the 1986 Code. Revise the ASME Section XI repair and replacement program to address weaknesses in the administrative process.
~~
OBJECTIVES:
- a. To upgrade repair / replacement program to better define the responsibilities and process for maintaining ASME Code compliance,
- b. Consolidate the procedures,
- c. Develop a method for incorporating Section XI requirements into job orders during the planning stages.
- d. Upgrade of ANO-1 for the third 10 year interval,
- e. Ensure consistent approach with other System sites.
_ ACTION PLAN
SUMMARY
START COMPLETION 4
) ACTION DATE DATE
- 1) Obtain information from other sites. 02/01/90 06/01/90
- 2) Develop program document. 03/20/90 12/31/90
- 3) Develop procedure revisions. 01/01/91 12/31/91
- 4) Develop Job order planning method. 02/15/90 08/15/90
- 5) Assess the program and develop 01/01/92 12/31/92 program upgrades.
- 6) Upgrade the ANO-1 Reports to required 01/01/94 12/19/94 Code for 3rd 10 years.
1
.m D-26
7
[ i sf 0
1990 - 1994 BUSINESS PLAN 4l IROJECT/ ACTIVITY PLANNING RECORD y
)>
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering -
PRIORITY: Medium s
PROJECT / ACTIVITY TITLE: 5.v Engineering Improvement Program -
ANO-1 OTSG. Secondary Side Touling DESCRIPTION: The transport of secondary system corrosion products since "
initial startup to the OTSGs has resulted in a buildup at the tube support plates, causing an increase in OTSG 1evels and a subsequent decrease in power level. Chemical cleaning is necessary to remove the deposits and return the OTSGs to as-new condition.
OBJECTIVES:
- a. To remove the tube support plate deposits to allow the unit to operate an entire cycle without power limitation due to increased OTSG levels.
- b. Extend the need to perform a second chemical cleaning by using i mechanical means or chemistry improvements. ;
(~s.
~- ! l ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Complete qualification testing and 01/01/90 10/01/90 system design.
2)- Perform chemical cleaning. 10/01/90 12/31/90
- 3) Perform waste processing. 01/01/90 03/31/91
- 4) Conduct improved waterslap 04/01/90 12/31/91 testing.
u_ ,1 D-27
F*
L 1
1990 - 1994 BUSINESS PLAN
, PROJECT / ACTIVITY PLANNING RECORD u.2
- i. ) i PROGRAM TITLE: D. Design Engineering and Modifications j PROGRAM LEAD: General Manager Engineering ,
1 PRIORITY: Low l l
PROJECT / ACTIVITY TITLE: 5.w Engineering Improvement Program -
Steam Generator Eddy Current Program DESCRIPTION: The EPRI Steam Generator NDE Guidelines provide ;
recommendations for improvements to utilities ECT programs. These l include expanding the random sample from 3 percent to 20 percent and (
adding an extensive analyst guideline and testing program. These ;
recommendations were made in anticipation of future NRC changes to Reg. i Guide 1.83. l OBJECTIVES:
- a. Expand the random sample inspection to identify potential damage i mechanisms,
- b. Develop a program for ECT analysis to ensure a consistent '
application of technology and interpretation of plant specific damage mechanisms. -
1 ACTION PLAN
SUMMARY
START COMPLETION
[) ACTION DATE DATE
- 1) Expand the random sample to 20 10/01/90 12/31/91 l percent.
- 2) Develop guidelines for analysis. 06/01/90 12/31/90
- 3) Develop expansion guidelines for 02/01/90 10/01/90 the 20 percent random program.
- 4) Implement ECT analysts test program.. 01/01/91 06/30/91 1
Q u.)
D-28
r.
i 1990 - 1994 BUSINESS PLAN F PROJECT / ACTIVITY PLANNING RECORD 4
)
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Low
, PROJECT / ACTIVITY TITLE: 5.x Engineering Improvement Program -
t Formalize Boric Acid Inspection Program DESCRIPTION: Provide a " surveillance instruction" guide for use during Boric Acid Inspections.
OBJECTIVES: _
q
- a. Formalize the Boric Acid Inspection process. j
- b. Ensure consistency in inspection techniques, acceptance criteria, '
and scope of inspection.
- c. Review other System sites' programs for input to ANO program.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Obtain information concerning program at 06/01/90 08/01/90 other system sites, q
.fN 1
( ,) 2) Develop and issue a standard / guide 08/01/90 10/01/90 for the Boric Acid Inspection Program.
_~
The standard is to include information on ;
inspection techniques, potential leak l locations, accumulation areas, and l evaluation guidelines.
1 I
/ ~\
's_,/ !
D-29
1990 - 1994~ BUSINESS PLAN
,- PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5.y Engineering Improvement Program -
Steam Generator Chemistry Improvements DESCRIPTION: Improvements in SG secondary side chemistry-related tasks have been made through extensive research and testing by utilities and EPRI. These improvements aid in overall secondary side performance and SG integrity. (ANO-1 and 2)
OBJECTIVES:
- a. Evaluate morpholine addition for ANO-2.
- b. Improve wet-layup program,
- c. Institute a standardized sampling and inspection program,
- d. Improve secondary side chemistry.
ACTION PLAN
SUMMARY
START COMPLETION
,_s ACTION DATE DATE
'(_,) 1) Update secondary system study. 06/01/91 06/01/93
- 2) Validate use of morpholine and wet- 01/01/90 12/31/93 layup program upgrades.
- 3) Implement secondary system upgrades. 03/01/90 12/31/93 ,
1
/
D-30
1990 - 1995 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD-PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5.z Engineering Improvement Program -
Inservice Testing (IST) Program DESCRIPTION: The IST Program-for ANO-2 is upgraded to the 1986 edition of ASME Section XI. The ANO-1 IST Program is to be reviewed for possibly upgrading to the 1986 Code for consistency between the units. Bases documents which explain why components are included or not included in the IST Program are needed. (DET 2.1.4.1)
OBJECTIVES:
- a. To identify the components to be included in the IST Programs,
- b. To identify the required tests for each component.
- c. To determine necessary relief requests,
- d. To develop a program document and administrative procedure.
ACTION PLAN
SUMMARY
- l START COMPLETION ACTION DATE DATE 1
y.s ,
~
Q 1) Review other System sites' programs for 03/01/90 06/01/90 input to ANO program.
- 2) 1986 Code upgrade submittal (ANO-2). 10/01/89 01/17/90 i (DET 2.1.4.7)
- 3) Procedure revisions (ANO 1 and 2). 10/01/89 '03/26/90 4), Completion of the ANO-2 bases document. 01/15/90 06/30/90 l- 5) Completion of the ANO-1 bases document. 03/01/90 09/30/90 l
- 6) Review the ANO-2 1986 Code upgrade 06/30/90 09/30/90 against the bases document and revise-as necessary.
- 7) Complete review of ANO-1 against the 04/15/90 12/31/90 bases document and determination of ANO-1 upgrade to 1986 Code. NOTE: ANO-1 IST Program will require upgrading to the latest NRC approved Code in 1994.
(DET 2.1.4.7)
- 8) Complete IST Program document and admin- 04/15/90 12/31/90 istrative procedure. (DET 2.1.4.7)
- 9) Implement ISI/IST computer data base 04/01/90 03/01/91 management system and procedures. (DET 2.1.4.1) 10)- Provide criteria for setting max stroke 10/01/90 03/26/90 times per GL89-04. (DET 2.1.4.5)
- 11) Establish design minimum pump performance criteria for ANO-1 and 2 (DET 2.1.4.2) 02/15/90 12/15/90 (DET 2.1.4.1, 2.1.4.2, 2.1.4.3, 2.1.4.5 and 2.1.4.7)
~
J D-31
i n
1990 - 1994 BUSINESS PLAN t PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: D. Design Engineering and Modifications
! PROGRAM LEAD: General Manager Engineering PRIORITY: -High PROJECT / ACTIVITY TITLE: 6.a Engineering Improvement Program -
Design Configuration Documentation (DCD)
DESCRIPTION: Comprehensive efforts to improve the quality, completeness and retrievability of the documentation which describes all aspects of the design of Arkansas Nuclear One with emphasis on documentation necessary to support maintenance of the plant design basis.
OBJECTIVES:
- a. Improve design document quality.
- b. Assure maintenance and control of design configuration documentation,
- c. Develop condensed souro of design " bases" information.
- d. Improve access and rctrievability of design information through an appropriate infor% t2on system.
ACTION PLAN sum 1ARI: I The detailed DCD action plan was issued in 1989 with detailed schedules
,- 3 and milestones. Progress is currently tracked monthly. The principle
) steps are listed below:
a START COMPLETION ACTION DATE DATE
- 1) Collect, organize and index readily 06/01/89 07/31/90 l available design or design information source documents. (DET 2.1.5.11)
- 2) Prepare " Upper Level" design 07/01/89 12/31/94 description documents for systems and topical areas. (DET 2.1.5.11) l- 3)- Perform detailed " vertical" reviews 01/01/90 12/31/94 of design documentation for completeness, consistency and accuracy. (DET 2.1.5.11) l 4) Develop a DCD informatlon management 03/01/89 12/31/94 l system for information accessibility.
(DET 2.1.5.11)
- 5) Address specific design documentation 03/01/89 12/31/94 category weaknesses as identified.
(DET 2.1.5.11)
- 6) Integrate with Configuration Management 03/01/90 06/30/91 Program. (DET 2.1.5.11)
(DET 2.1.5.11 and 2.1.5.12) in .
J D-32
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD l'~)
%s' :
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: See Action Plan PROJECT / ACTIVITY T11LE: 6.b Engineering Improvement Program - Isometric Update Program (IUP)
DESCRIPTION: Prepare new piping isometric and support drawings based on field-verified information. New drawings are developed with CAD. Review new drawings against qualifying analyses, identify and reconcile discrepancies, and revise analyses as necessary. Scope of project includes Seismic Category I piping and supports for ANO-1 and 2.
OBJECTIVES: ,
- a. Develop improved and legible drawings.
-b. Develop a reconciliation of as-built configuration to qualifying design basis calculations.
- c. Identify and resolve existing deficiencies in the field.
- d. Meet the NRC commitment as scope and schedule of project.
- e. Upgrade the adequacy of qualifying analyses and design basis information through a redraw and reanalysis process. ,
b) v ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Med Develop process descriptions and 01/01/90 06/04/90 guidelines for the conduct of field and office operations. (DET 2.1.5.11)
- 2) Med Conduct field walkdowns based on use 01/01/90 12/31/95 of walkdown packages containing a compilation of drawings and design input data. (DET 2.1.5.11)
- 3) Hi Identify field discrepancies, track 01/01/90 12/31/95 and resolve. (DET 2.1.5.11)
- 4) Hi Reconcile field data against cal- 01/01/90' 12/31/95 culations via use of as-built drawings. (DET 2.1.5.11)
- 5) Fi Identify analytical discrepancies, 01/01/90 12/31/95 track and resolve. (DET 2.1.5.11)
- 6) Med Maintain project tracking and status 01/01/90 12/31/95 via a monthly reporting system.
(DET 2.1.5.11)
- 7) Med Plan and control resources in 01/01/90 12/31/95 accordance with system availability, budget constraints, and regulatory V
) commitments. (DET 2.1.5.11)
(DET 2.1.5.11 and 2.1.5.12)
D-33
1990 - 1994 BUSINESS PLAN
., PROJECT / ACTIVITY PLANNING RECORD l
.[ )
LJ PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: See Action Plan >
PROJECT / ACTIVITY TITLE: 6.c Engineering Improvement Program -
Electrical Drawing Upgrade Program (EDU)
DESCRIPTION: As-build and upgrade all ANO-1 and ANO-2 Class IE switchgear, MCC and major control cabinets electrical drawings. Enhance presentation of drawing information in accordance with DCD philosophy for dissemination of design information.
OBJECTIVES:
- a. Bring all major Class 1E electrical cabinets up to as-built status. *
- b. Convert all associated schematics, connection diagrams and vendor internal wiring diagrams to a '! smart" . CAD system.
- c. Modify the Class IE electrical-drawing program to make changes more efficient, improve readability and minimize probability of errors,
- d. Complete within 3 outages per unit.
ACTION PLAN
SUMMARY
START COMPLETION
" ACTION DATE _ DATE l' 1) Med. Assess industry and system experience 01/01/90 07/01/90 with electrical dr:: wing upgrades, CAD implementation, and electrical as-building efforts. (DET 2.1.5.11, 2.1.5.14)
- 2) Ned Reach agreement with site and design 01/01/90 06/01/90 users on drawing content and presentation.
(DET 2.1.5.11, 2.1.5.14)
- 3) Med Finalize project definition and scope. 01/01/90 05/01/90 (DET 2,1.5.11, 2.1.5.14)
- 4) Med Issue necessary contracts for software, 01/01/90 07/01/90 walkdowns, evaluations and drafting.
(DET 2.1.5.11, 2.1.5.14)
- 5) Med Finalize definitive schedule. 02/01/90 08/01/90 i (DET 2.1.5.11, 2.1.5.14)
- 6) Hi Complete activities for the Refueling 01/01/90 05/30/91 outage IR9-2R8.
- 7) Hi Complete activities for the Refueling 01/07/92 12/31/92 outage IR10-2R9.
- 8) Hi Complete activities for the Refueling 01/01/93 12/31/93 outage IR11.
(DET 2.1.5.11, 2.1.5.12 and 2.1.5.14)
(
()
D-34
r p-i 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium PROJECT / ACTIVITY TITLE: 6.d Engineering Improvement Program -
Structural Design Program (SDP) , ,
DESCRIPTION: The piping and pipe support design input assumptions of ANO 1 and 2 are not fully documented. Consequently, it is difficult to verify design inputs or analysis practices and reconcile original practice to update techniques.
OBJECTIVES: The objective of the SDP is to establish a formal l engineering process which provides the basis, and direction to be used in the design and qualification of piping systems for ANO.
The SDP will provide ANO a tool to address, develop and document a position for engineering issues applicable to the design, qualification, installation, fabrication, verification, documentation, procurement, and inspection of piping systems. Additionally, the SDP shall provide means to assess emerging issues which may arise due to changing industry practices or approaches.
ACTION PLAN
SUMMARY
f']
START COMPLETION ACTION DATE DATE
- 1) Identify and prioritize topics for which 01/01/90 12/31/94 position papers / guidelines are required. '
(DET 2.1.5.11)
- 2) Select topics to be written, 01/01/90 12/31/94 (DET 2.1.5.11)
- 3) Review / Approve each position paper 01/01/90 12/31/94 and/or guidelines. (DET 2.1.5.11)
- 4) Establish a program plan which provides 01/01/90 06/01/90 a mechanism for addressing technical positions and issues. (DET 2.1.5.11)
- 5) Review systemwide structural analysis 01/01/90 12/31/90 programs for inclusion into the SDP.
(DET 2.1.5.11 and 2.1.5.12)
- c. .
D-35
L _
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD iQ)%;
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: See Action Plan PROJECT / ACTIVITY TITLE: 6.e Engineering Improvement Program.-
Plant Setpoint Control Program (PSCP)
DESCRIPTION: Document existing in-plant setpoints for selected components. Provide a procedure to control and document changes to setpoints. Establish setpoint and basis availability in accordance with DCP philosophy and objectives.
OBJECTIVES:
- b. Document-the basis for existing setpoint selection of selected i components. l
- c. Issue a Setpoint Control Procedure to provide guidelines for types j of components that require setpoints, a method of documenting that !
setpoint, criteria for setpoint selection and a method of l controlling changes to setpoints. l
- d. Use the Station Information Management System (SIMS) Component Data j Base to store and display setpoint information. !
3 ACTION PLAN
SUMMARY
START COMPLETION (O ACTION DATE DATE q l 1) Med Develop a list of components to be 01/01/90 10/01/91 l ll included in the base setpoint document, j
- 2) Med- Develop Setpoint Documentation Packages 05/01/90 10/01/91 !
for these selected components by reviewing ;
reference documents for design' basis I information. !
l 3) Med Develop calculations as needed for comp- 05/01/90 02/05/91 i onents requiring a formal documented bases.
- 4) Med -Modify the SIMS Component Data Base to 03/20/90 10/01/90 i allow input and display of setpoint 1 information.
- 5) Med Develop and issue a procedure for 10/19/89 06/25/90 Setpoint Data Control in the SIMS CDB.
- 6) Med Develop and issue a Setpoint Control 10/19/89 06/25/90 Procedure. Modify other procedures as required for consistency. I
'7) Low Integrate with DCD Project. 01/01/90 10/01/91 (DET 2.1.5.11 and 2.1.5.14) q Lj D-36
t ._-
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~
n 1990 - 1994 PUSINESS PLAN
-N .
p PROJECT / ACTIVITY PLANNING RECORD F
[J %_.
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: See Action Plan PROJECT / ACTIVITY TITLE: 7. Training DESCRIPTION: There is currently not a focused Training Program in effect for Engineering. The Individual Development Program (IDP) developed and implemented in 1988 was discontinued early in 1989 and was re-established later in 1989. The absence of a formal training program directly affects the ability of Engineering personnel in technical, systems and administrative areas.
OBJECTIVES:
- a. To reestablish the IDP.
- b. Transfer of the program to the Training Department.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) 11 1 Review systemwide training program 04/01/90 06/01/90
/'T for engineering.
m) 2) 11 1 Schedule and perform training for 01/01/90 12/31/90 Engineering staff [ incl. System Training).
(DET-2.1.5.2, 2.1.5.10)
- 3) Low Establish an IDP Committee to provide 01/01/90 02/01/90 oversight of the program. (DET 2.1.5.2)
- 4) lii - Develop transition plan for training 04/01/90 06/01/90 department to assume administration of program. (DET 2.1.5.2)
- 5) Med Assess future scope of training program 06/01/90 12/31/90 and complete transition of IDP to training 6 department. .(DET 2.1.5.2)
(DET 2.1.5.2 and 2.1.5.10) p, D-37
p F-t 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGPAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Low PROJECT / ACTIVITY TITLE: 8. Facilities DESCRIPTION: At present some office facilities at the ANO site need improvement and planning for future additions needs to be formalized.
OBJECTIVES: Perform a long-range Master Site Plan / Facilities Study to assess the needs of the site and develop a program to meet these needs.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Complete the Master Site Plan (MSP) 01/01/90 06/01/90 Study.
- 2) Review the ecommendations and develop 05/01/90 12/31/90 phased impla nentation plans.
L 3) Establish mechanisms to update the plan 05/01/90 12/31/90 ,
as conditions change. !
- 4) Establish controls to ensure that 05/01/90 12/31/90 facility additions are in accordance i('N) sj with the plan. r l
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D-38 l ,
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD-
\ )
Design Engineering and Modifications PROGRAM TITLE: D.
PROGRAM LEAD: General Manager Engineering
' PRIORITY: See Action Plan PROJECT / ACTIVITY TITLE: 9. Engineering Department Communication Plan DESCRIPTION: Communications within Engineering and between Engineering ,
and other departments have been cited as a weakness. This weakness has been seen not only as a loss in sharing of management philosophy, but has also contributed to unresolved technical issues.
OBJECTIVES:
- a. Improve. communication between Engineering and other departments,
- b. Improve communication within the Engineering sections,
- c. Improve communication between Engineering management and staff,
- d. Establish Engineering (Ref. K-3) plan in accordance with overall communication plan.
ACTION PLAN
SUMMARY
. START COMPLETION g~ ACTION DATE DATE
\_ l . 1) Med Schedule-and attend periodic meetings 01/01/90 12/31/90 with other departments. (DET 2.1.3.7, '
2.1.5.5)
- 2) Hi Develop a Communications Plan for unique 01/01/90 07/01/90 engineering issues (including elements of the Business Plan and use of Design Engineering directives to communicate management expectations). (DET 2.1.5.5) l 3) Med Implement the plan. (DET 2.1.5.5). 06/01/90 08/01/90 ;
- 4) Med Perform independent assessment of the 11/30/90 12/31/90 effectiveness of communications.
(DET 2.1.3.7, 2.1.5.5, 2.1.5.7 and 2.1.5.10)
(SALP IV.A.3.b.2 and IV.G.3.b.2) l I
if D-39 L
L
=
y
^
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD
'- si v' .
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium !
PROJECT / ACTIVITY TITLE: 10. Self-Assessment (SSFI) i I
DESCRIPTION: Inspection of selected safety significant systems ;
utilizing vertical audit techniques will be done to assess their functionality, reliability and operational readiness. This is accomplished by determining if the system has been designed, installed, modified, tested, operated, maintained and managed in accordance with the j original design basis, licensing basis and applicable regulations ;
standards and. commitments.
OBJECTIVES:
- a. Coordinate the inspections with the Design Configuration Documentation Program. !
- b. Continue to demonstrate the operational readiness, functionality and reliability of ANO safety systems. ;
i ACTION PLAN
SUMMARY
- I
, ~i) :
k_ ' START COMPLETION l ACTION DATE DATE l
- 1) Identify systems for upcoming inspections. 01/02/90 Completed j
- 2) Assign team members for first inspection. 03/01/90 05/01/90
- 3) Perform first inspection. 05/07/90 06/01/90 !
- 4) Issue final report. 06/01/90 08/30/90 l
- 5) Establish similar milestones for next SSFI. 09/03/90 10/01/90 (DET 2.1.5.11) 'j i
i i
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V D-40
t 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD i
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: Medium a
PROJECT / ACTIVITY TITLE: 11. Industry Experience DESCRIPTION: There exists an Industry Experience Program for Design Engineering and an Operations Assessment group at-ANO that provides input to the remainder of Engineering. Although training has been conducted on the Design Engineering program, and information is being circulated, there has not been significant emphasis to the program. This lack of attention at the working level has contributed to some design short-comings which could have been avoided had industry experience been-better utilized.
OBJECTJVES:
- a. To raise the visibility of the Industry Experience Feedback Program.
- b. To reduce potential for costly Engineering mistakes by taking advantage of available industry information. I
- c. Assure compatible approach with other system sites,
- d. To improve the interaction between Technical Support and
-s Assessment and Engineering with respect to Industry Experience
/
) Review.
LJ ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE j
- 1) Determine methods and approach of other 01/01/90 05/01/90 ;
System sites. 'l
,. 2) Review the existing Industry Experience :01/01/90 06/01/90 !
! Feedback for improvements. (DET 2.1.5.8) !
- 3) Revise design-related procedures to 01/01/90 06/29/90 l
provide explicit directions on the use of :
Industry Experience. (DET 2.1.3.7, 2.1.5.8) !
4)- Provide training to the design engineers 04/15/90 01/01/91 l relative to the program. (DET 2.1.5.8) ,
- 5) Define role / interface between assessment 04/01/90 06/15/90 _;
, and engineering with respect to Industry !
l . Experience Review. (DET 2.1.5.8)
(DET 2.1.3.7, and 2.1.5.8) i (SALP IV.G.3.b.4) i
/7 D-41 J
i
~
e 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD
)
PROGRAM TITLE: D. Design Engineering and Modifications PROGRAM LEAD: General Manager Engineering PRIORITY: See Action Plan l
PROJECT / ACTIVITY TITLE: 12. Configuration Management and Control l DESCRIPTION: To assure that the actual physical configuration and !
operation of the plant are consistent with and are maintained consistent '
with the. intended design.
\
OBJECTIVES: !
- a. Improve the existing methods and systems which maintain accurate l reflection of actual plant installations.
- b. Improve the ability of Design, Maintenance, and Operations to perform their functions relative to configuration control,
- c. Provide methods compatible with other System sites.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE r'T 1) Med Obtain program description from other 04/01/90 05/15/90
( ,) System sites. (DET.2.1.5.11) i
- 2) Hi Assess CM documents. (DET 2.1.5.11) 04/01/90 05/13/90
- 3) Hi- Develop CM policy document. 05/01/90 06/01/90 (DET 2.:.5.11)
- 4) Hi Develop action plan for implementation 05/01/90 06/29/90 of CM program. (DET 2.1.5.11)
- 5) Med Conduct training on CM requirements. 07/01/90 08/01/90' (DET 2.1.5.11)
- 6) Med Perform structure business analysis of 08/31/90 -05/31/91 CM processes to identify opportunities for
. improvements.
- 7) Med Train ANO personnel to definition and 06/01/91 12/31/91 importance of CM, identify duties and responsibilities relating to CM.
(DET 2.1.5.11)
- 8) Med Improve procedures and processes which 07/01/91 12/31/91 maintain configuration control.
(DET 2.1.5.11)
(DET 2.1.5.11 and 2.1.5.'14) 1 (3 J
D-42 I
n.
(j v.
1990-1994 BUSINESS PLAN APPENDIX E. -Material Management Program Lead: General Manager, Materials Projects / Activities:
- 1. Materials Engineering
- 2. Organization and Staffing.
- 3. Materials Management Information System Data base
- 4. Commercial Grade Dedication Program 3 5, Shelf Life
- 6. Business Process Improvements
- 7. Inventory Control / Management Improvements
- 8. Facilities Improvements
- 9. Procedures i
bo
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1990 - 1994 BUSINESS PLAN a.w, PROJECT / ACTIVITY PLANNING RECORD
' PROGRAM TITLE: E. Material Management PROGRAM LEAD: General Manager, Materials PRIORITY: High PROJECT / ACTIVITY TITLE: 1. Materials Engineering DESCRIPTION: This activity will provide procurement technical require-
-ments for spare parts identified to specific plant applications as well as commodity and bulk type items.
OBJECTIVES:
a.- Support the day-to-day procurement demands of the plant.
- b. Establish pre-approved procurement technical requirements for commodity and bulk type items and for inventories spare parts that are identified to-8pecific plant applications.
- c. Eliminate existing contractors and establish a permanent AN0 Materials Engineering organization, f%
'v> ACTION PLAN
SUMMARY
.: Through the material control project: ,
START COMPLETION l ACTION DATE DATE i
- 1) Develop a Materials Engineering process to 03/05/90 12/31/90 'l accommodate day-to-day plant demand. 'j'
- 2) Develop a bill-of-materials effort to 04/01/90 12/31/91 develop a spare parts listing for plant components and develop procurement tech- 4 nical requirements for those parts to be !
inventoried. l L3) Develop standing procurement technical 04/01/90 12/31/91 requirements for specified commodity and ,
bulk type items with known plant j applications. l
- 4) Develop Material Engineering procedures. 01/15/90 03/30/90 1
- 5) Establish permanent ANO Materials Engineering 02/15/90 12/31/91 organization. <
- 6) Qualify warehouse inventory to plant 04/01/90 03/31/91 !
applications. l L 7) Evaluation Measurements of Effectiveness. 02/28/90 03/15/90 L (DET 2.1.3.4) l !
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- l. E-1
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i 1990 - 1994 BUSINESS PLAN
(' PROJECT / ACTIVITY PLANNING RECORD
() PROGRAM TITLE: E. Materials Management PROGRAM LEAD: General Manager, Materials PRIORITY: Medium PROJECT / ACTIVITY TITLE: 2. Organization and Staffing DESCRIPTION: Create and staff an efficient and effective Materials Management organization to support plant operation, maintenance, and outages. Staff and manage the Materials Control Project to effectively ,
implement defined materials program upgrades. {
OBJECTIVES:
- a. Define and establish the optimum materials mar.agement structure for ANO. ,
- b. Implement the transition from contractor staff utilization to AP&L staff cuch that no interruption in plant support exists.
ACTION PLAN SUlt1ARY:
START COMPLET10N ACTION DATE DATE !
Complete -i 7-s3 1) Develop revised Materials Management 01/01/90 02/15/90 ,
,,) Organization.
- 2) Consolidate existing contractor resources 03/01/90 04/30/90 ;
into a single " Managed Tcsk". !
- 3) Define responsibilities, duties and job 02/15/90 12/31/90 i descriptions. !
- 4) Post job openings and recruit qualified staff 02/15/90 12/31/90 to replace contractors.
- 5) Develop and implement required technical 01/02/90 12/31/90 training programs. j
- 6) Implement the permanent ANO Materials. 01/02/90 12/31/91 1 organication.
- 7) Evaluation Measurements of Effectiveness . 02/28/90 03/15/90 i
(DET 2.1.3.4) l i
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7
-3 1990'- 1994 BUSINESS PLAN i
.d PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: E. Material Management PROGRAM LEAD: General Manager, Materials PRIORITY: Medium PROJECT / ACTIVITY TITLE: 3. Material Management Information System (MMIS) Database DESCRIPTION: Establish a comprehensive materials information system for warehouse items in order to support maintenance, operations, and ,
modification material needs. l OBJECTIVES: Provide a comprehensive, validated, controlled information system to support and control materials activities, including the issue of' spare and replacement parts. Ensure that physical and process controls are in place to maintain the integrity of inventory items and associated materials information system, n
) ACTION PLAN SU? DIARY:
START COMPLETION ACTION' DATE DATE l
- 1) Develop materials data standards _ and reformat 02/01/90 12/31/91 existing materials data in the present informat'.on system.
i t)- Perform inventory of warehouse items and 03/19/90 12/31/90 j.
determine items' physical and documentation L attributes.
- 3) Develop an accurate, comprehensive listing 02/26/90 12/31/91 of emergency spares
- 4) Modify MMIS database to establish data 02/26/90 12/31/91 security to support the MMIS data collec-tion effort and establish data controls.
- 5) Evaluation Measurements of Effectiveness. 02/28/90 03/15/90 (DET 2.1.3.4)
E-3
~
I 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD E
PROGRAM TITLE: E. Material Management
-PROGRAM LEAD: General Manager, Materials PRIORITT: High 3
PROJECT / ACTIVITY TITLE: 4. Commercial Grade Dedication Program DESCRIPTION: This activity will develop a program to " dedicate" items purchased as " commercial grade" to safety-related applications.
OBJECTIVES:
y.
- a. Establish and implement a commercial grade item dedication program that is consistent with NCIG-07 Guidelines and in compliance with regulatory requirements,
- b. Gather data during this project for up-load in support of a planned, I future purification of the MMIS database.
) ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE o 1) Develop a commercial grade item dedication ' Complete procedure. 11/20/89 12/25/89
- 2) Perform all new'procurements using the NSIG-07 methodology. 01/15/90 05/30/90
- 3) Develop and provide training to. user groups lin CGI dedication methodology. 12/15/89 01/30/90 l-
- 4) Establish a format for capturing CGI data 02/15/90 05/30/90
, for future up-load to MMIS, l
- 5) Revise plant procedures to support the 12/26/89 05/30/90 1 new CGI process.
- 6) Evaluation Measurements of Effectiveness. 02/28/90 03/15/90 (DET 2.1.3.4)
(SALP IV.C.3.b.4 and IV.C.3.b.5)
>J'i; i v
E-4
m 1990 - 1994 BUSINESS PLAN
) PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: E. Material Management' PROGRAM LEAD: General Manager, Materials PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5. Shelf Life DESCRIPTION:
Background
Last two (2) INPO audits have identified problems with ANO Shelf Life Program. INPO wil reevaluate June 1990.
Project Descript!~n Review / Revise Shelf Life program to enhance ability to comply with regulatory requirements and industry standards.
OBJECTIVES:
- a. Establish an effective shelf life program that includes the procure-ment, storage, issue, and control of limited life items.
- b. Review stock material to determine shelf life applicability.
-(c) c. Identify and_ disposition expired shelf life items presently stored v in the warehouse.
- d. Ensure procurement process identifies and establishes shelf life for safety related limited life items.
- e. Establish methods for identifying _and establishing shelf life for non-safety related limited life items.
- f. Ensure issue processes prevent inadvertent use of expired shelf life items.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Evaluate existing stock material (Q items) 11/20/89 08/28/90 to determine shelf life applicability.
- 2) Establish methods to identify and disposition 03/26/90 04/20/90 expired shelf life items.
- 3) . Revise procurement process to identify and 01/15/90 03/23/90 establish shelf life for all new limited
, life items.
Identify enhancements to MMIS screens / reports 01/15/90
- 4) 03/23/90 associated with shelf life program.
- 5) Develop training program for personnel 03/26/90 04/13/90 L associated with shelf life program.
- 6) Evaluation Measurements of Effectiveness. 02/28/90 03/15/90
(~x V (DET 2.1.3.4)
(SALP IV.C.3.b.4 and IV.C.3.b.5)
E-5
'1990 - 1994 BUSINESS PLAN
'~x, PROJECT / ACTIVITY PLANNING RECORD l l
PROGRAM TITLE: E. Material Management PROGRAM LEAD: General Manager, Materials PRIORITY: Low PROJECT / ACTIVITY TITLE: 6. Business Process Improvements DESCRIPTION: Implement material management processes and the Materials Management Information System in order to support materials planning and business function. Establish reporting features for management analysis ,
and monitoring. ,
OBJECTIVES:
- a. Improve responsiveness to material demands,
- b. Improve material information availability for user organization.
- c. Establish controls to ensure MMIS Data is current and controlled.
- d. Establish management reporting function.
ACTION PLAN SU.tlARY:
START COMPLETION r~s, . ACTION DATE DATE
'x- /
- 1) Define revised Material Management processes. 03/01/90 12/31/90
- 2) Revise existing processes to support the 04/01/90 12/31/90 revised process.
- 3) Establish organization to support process. 02/15/90 12/31/91
- 4) Establish internal control features to 04/01/90- 12/31/91 access materials management functions.
- 5) Evaluation Measurements of Effectiveness. 02/28/90 03/15/90 (DET 2.1.3.4)
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E-6
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1990 - 1994 BUSINESS PLAN
/ ;
PROJECT / ACTIVITY PLANNING' RECORD F \_ -)
PROGRAM TITLE: E. Material Management PROGRAM LEAD: General Manager, Materials PRIORITY: Medium PROJECT / ACTIVITY TITLE: 7. Inventory Control / Management Improvements DESCRIPTION: Implement a warehousing and inventory management program to enhance ability to comply with regulatory commitments and provide an optimized inventory from both an economic and a plant service aspect.
OBJECTIVES:
- a. Improve piece and replacement part identification process,
- b. Improve. data processing and transfer capabilities.
- c. Establish ideal inventory control processes,
- d. Optimize warehouse inventory.
(S
(/ ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Define revise inventory control processes. 03/01/90 12/31/90
- 2) Update-inventory information to support 04/01/90 12/31/91 revise process.
- 3) Establish stock control for disposition 05/01/90 12/31/91 of out-of-date stock and update existing inventory to support plant needs.
- 4) Evaluation Measurements of Effectiveness. 02/28/90 03/15/90-(DET 2.1.3.4) o E-7
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,- -1990 - 1994 BUSINESS PLAN-
\. PROJECT / ACTIVITY PLANNING RECORD s
1 PROGRAM TITLE: E. Materials Management PROGRAM LEAD: General Manager, Materials PRIORITY: Low PROJECT / ACTIVITY TITLE: 8. Facilities Improvements ,
DESCRIPTION: Evaluate and upgrade existing materials management facilities to support the materials process.
OBJECTIVES:
- a. . Improve material condition through better storage facilities and handling system.
- b. Ensure facility upgrades are evaluated and incorporated into overall site facility review activity.
/~y L.j ACTION PLAN
SUMMARY
START COMPLETION 4 ACTION DATE DATE 1)~ Evaluate existing facilities for proposed 02/01/90 06/01/90
- ~
upgrade.
- 2) Coordinate facility evaluation with ongoing 02/01/90 06/01/90 Site Master Plan Development.
- 3) Perform minimum modifications to ensure 06/01/90 12/31/90' compliance with storage and handling. ,
requirements without compensatory measures.
- 4) Propose modifications to enhance materials 07/01/90 09/30/90 processing.
- 5) Evaluation Measurements of Effectiveness. 02/28/90 03/15/90 (DET 2.1.3.4)
,.\
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1990 - 1994 BUSINESS PLAN N-[ PROJECT / ACTIVITY PLANNING RECORD l l
PROGRAM TITLE: E. Material Management 5 '
PROGRA:1 LEAD: General Manager, Materials PRIORITY: Medium PROJECT / ACTIVITY TITLE: 9. Procedures DESCRIPTION: Establish project and plant procedures and processes to implement and support a comprehensive materials management function.
OBJECTIVES:
- a. Establish model procurement and inventory control processes to meet regulatory and corporate requirements,
- b. Ensure that material processes are properly controlled to maintain i the physical documentation and database information associated with warehouse items.
O ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Define revised procurement and inventory 03/01/90 12/31/90 control processes.
- 2) Revise plant processes and procedures 04/01/90 04/01/91 ;
.necessary to implement the new processes.
- 3) Implement, document and process changes 04/01/90 12/31/91
-and controls for materials activities.
- 4) Evaluation Measurements of Effectiveness. 02/28/90 03/15/90 (DET 2.1.3.4)
(3 N,
E-9
1e
'i:-s 1990-1994 BUSINESS PLAN APPENDIX--
1, / - F. Regulatory Affairs Program Lead: General Manager Technical Support and Assessment Projects / Activities
- 1. Improve Image / Credibility i a, Procedures Upgrade '
- b. Improve support for inspections
- c. Improve Closeout Process of NRC Items
- 2. Commitment Control
- 3. Improve Quality of Technical Specification Program
- 4. Improve Integrity of Communications
- a. Improve Licensing Document Research System
- 5. License Event Report (LER) and 10CFR21 Improvement Program t
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1990 - 1994 BUSINESS PLAN c T PROJECT / ACTIVITY PLANNING RECORD N_/
PROGRAM TITLE: F. Regulatory Affairs PROGRAM LEAD: General Manager Technical Support and Assessment-PRIORITY: High PROJECT / ACTIVITY TITLE: 1. Improve Image / Credibility ,
DESCRIPTION: Change AN0's image in regulatory affairs from a legalistic, ,
compliance-based and "close to the vest" approach to an image of open, safety-conscious and strong technicel based approach to the regulator.
OBJECTIVES: Instill a sense of confidence in AN0's approach to safety and communications such that the regulator will receive complete and accurate information on ANO activities and events.
j, : ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- a. Verbal START COMPLETION
- ~'
- 1) Develop a philosophy to ensure licensing is 09/01/89 10/01/89
a focal point for discussions with NRC and, as-appropriate, management / technical leads are'present. (DET 2.1.1.3)
- 2) Establish:a practice for monitoring plant 09/01/89 10/01/89 events and identify those with potential regulatory interest; contact regulator prior to his contact with us with details and action' plans. (DET 2.1.1.3)
- 3) Develop policies for standards of communi- 12/15/89 01/30/90 cations with NRC for ANO personnel.
(DET 2.1.1.3)
- 4) Develop Licensing directives for 11/15/89 02/15/90 communicating with the NRC. (DET 2.1.1.3)
- 5) Develop training class on how to effectively 05/14/90 10/01/90 communicate with NRC staff such that complete and accurate information is provided.
- 6) Establish guidelines on use of the appro- 01/30/90 04/30/90 priate legal personnel in licensing activities.
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l 1990 - 1994 BUSINESS PLAN j
.i -
PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: F. Regulatory Affairs PROGRAM LEAD: General Manager Technical Support and Assessment 1
PRIORITY: High j i
PROJECT /ACTIY3TY TITLE: 1. Improve Image / Credibility '
ACTION PLAN
SUMMARY
- CONT'D.
START COMPLETION ACTION DATE DATE
- b. Inspection
- 1) Develop closure packages for NRC items 01/15/90 05/30/90 to better support inspections. l (DET 2.1.1.3) i
- 2) Establish a policy to provide better support 02/01/90 04/30/90 j for NRC inspections. (DET 2.1.1.3) j 4
- c. Meeting l
- 1) Establish frequent meetings (no less than 02/01/90 03/31/90 !
, C'J. every two months) with NRR Project Managers and Region IV Section Chief. (DET 2.1.1.3) ;
- 2) Establish performance meetings with NRR/ Region 02/01/90 03/31/90 i
IV management' personnel (quarterly).
(DET 2.1.1.3) ,
y 3)- Develop guidelines to improve quality of KRC 02/01/90 05/30/90 i meeting presentations. ;
- 4) Develop plan to conduct a self SALP, 03/15/90 05/30/90 (DET 2.1.1.4)
- d. Misc.
- 1) Develop environmental impact proceduie. 02/01/90 04/30/90 !
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p (DET 2.1.1.3 and 2.1.1.4)
(SALP IV.G.3 b.6) l :
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1990 - 1994 BUSINESS PLAN
- PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE
- T. Regulatory Affairs PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: High PROJECT / ACTIVITY TITLE: 2. Commitment Control DESCRIPTION: Develop a station-wide commitment control process that tracks the implementation of new commitments and ensures maintenance of past commitments.
OBJECTIVES: To ensure that commitments are met and maintained in future years by providing a mechanism which provides ready access to previous commitments with cross referer.cc to the implementing document (procedure, SAR, etc.)
O ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Develop station-wide definition of a 01/05/90 04/30/90 commitment and who can make a commitment.
- 2) Develop program plan for development and 02/12/90 05/30/90 implementation of a Commitment Tracking Program.
- 3) Revise procedures and implement computer 06/04/90 10/01/90 system for commitment tracking system.
- 4) Perform a study to determine if past 06/01/90 08/01/90 correspondence and licensing basis documents should be reviewed to extract commitments and be placed in the newly developed Commitment Tracking System. In addition, determine if commitments are implameited.
(SALP IV.G 3.b.3) r-3
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1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD ;
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PROGRAM TI1LE:. F. Regulatory Affairs l
PROGRAM LEAD: General Manager Technical Support und Assessment PRIORITY:. Hedium PROJECT / ACTIVITY TITLE: 3. Improve Quality of Technical Specification Program DESCRIPTION: Modify the technical specifications (T.S.) and implement a T.S. interpretation process to ensure consistent interpretations with
-appropriate emphasis on safety.
OBJECTIVES: Improve the existing ANO-1&2 technical specification wording and provide interpretations where necessary to ensure the requirements of the Technical Specifications are accurately and consistently interpreted.
ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
[ ~
- 1) -Develop a technical specification 02/01/90' 05/30/90 interpretation document.
- 2) Complete an assessment of Tech. Specs to 11/01/90 03/01/91
.to determine where improvements can be made.
(DET 2.1.1.3)
(SALP IV.G.3 b.6) s i
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i-i 1990 - 1994 BUSINESS PLAN
,( ) PROJECT / ACTIVITY PLANNING RECORD
- v PROGRAM TITLE: F. Regulatory Affairs PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: High L PROJECT / ACTIVITY TITLE: 4. Improve Integrity of Communications j DESCRIPTION: Establish controls over correspondence with the NRC such that thorough technical and editorial reviews are conducted prior to issuance and that subsequent reviewers have the benefit of knowing who has previously reviewed the material and what their comments were.
Reviewers will be held accountable for the accuracy of_the communication.
OBJECTIVES: Ensure that communications with NRC are accurat . complete, responsive, and are cubmitted within the required time frame.
ACTION PLAN
SUMMARY
START COMPLETION A_CTION DATE DATE
- 1) Upgrade policies and procedures to ensure 03/05/90 05/30/90 3 information submitted to the NRC is complete (V and accurate. (SALP IV.G.3.b.6)
- 2) Expand the licensing document research system 11/30/89 10/30/90 to store all correspondence to and from the NRC. (SALP IV.G.3.b.6)
- 3) Develop and implement policy for submitting additional letters to the NRC on things we complete or do well. Proactive communication. 03/05/90 05/30/90 (DET 2.1.1.3) (SALP IV.G.3.b.6)
(DET 2.2.1'.3)
L .(SALP IV.G.3.b.3 and IV.G.3.b.6) l--
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! 1990 - 1994 BUSINESS PLAN iII v- PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: F. Regulatory Affairs PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: . High PROJECT / ACTIVITY TITLE: 5. Licensee Event Report (LER) and 10CFR2h Improvement Program DESCRIPTION: Develop guidelines on how reportability determination, will be identified, reviewed and dispositioned in a timely manner. Develop guidelines to ensure LERs and 10CFR21 submittals are complete, accurate, and resolved in a timely manner.
OBJECTIVES:
- a. Conduct root cause evaluations within two weeks of identification of a CR for LERs.
- b. Ensure 10CFR21 evaluations / determinations are adcquately performed and documented.
'c. Provide LERs and 10CFR21 submittals in advance of the required due date.
ACTION PLAN
SUMMARY
.(./')~.
START COMPLETION ACTION _DATE DATE
- 1) Revise Procedure 1000.104, " Condition 11/01/87- 03/30/90 Reporting and Corrective Actions", to include LER support requirements.
- 2) Implement enhanced procedure for submittal 02/01/90 05/30'/90 of LERs.
- 3) Enhance 10CFR21 procedure. 02/01/90 05/30/90
- 4) Enhance measures to require more timely 02/01/90 05/30/90 draft information for early submittal of LERs within 30 days.
(DET 2.1.1.10 and 2.1.5.6) 1 11 1 \ '-
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l 1990-1994 BUSINESS PLAN APPENDIX
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!- G. Human Resources Program Lead: Director Human Resources (Manager Human Resources)
Projects / Activities:
- 1. Fitness For Duty Program Implementation
- . 2. Relocation Plan t 3. Recruiting and Retention
- 4. Employee Relations
- - 5. - Employee / Management Development l.
\l 1990 - 1994 BUSINESS PLAN
( i PROJECT / ACTIVITY PIE .ING RECORD w/
PROGRAM TITLE: G. Human Resources
~
PROGRAM LEAD: General Manager Tech Support & Assessment p.
PRIORITY: Med PROJECT / ACTIVITY TITLE: 1. Fitness For Duty Program Implementation DESCRIPTION: Implement a Fitness For Duty (TFD) Program that meets the requirements of 10CTR26.
i OBJECTIVES: To ensure regulatory compliance with 10CFR26 and maintain the quality FTD Program at ANO.
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ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) Issue FFD Policy and procedures.
06/01/89 03/30/90
- 2) Establish a medical facility / lab on-site. 10/15/89 Complete
- 3) . Hire appropriate staff (Lab Tech, MRO, etc.). 12/01/89 06/15/90
- 4) Obtain off-site lab (system-wide contractor). 06/01/89 Complete
- 5) Obtain EAP vendor (system-wide contractor). 06/01/89 Complete-
-6) Implement 100% random testing. 01/01/90 Complete
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I- i 1990 - 1994 BUSINESS PLAN l PROJECT / ACTIVITY PLANNING RECORD
. V)
PROGR'M TITLE: G. Human Resources i PROGRAM LEAD: Director Huinan Resources I (Manager Human Resources)
PRIORITY: High l PROJECT / ACTIVITY TITLE: 2. Relocation Plan l I
DESCRIPTION: Relocate all Little Rock based Nuclear Operations !
!~ Engineering and support personnel to ANO. ;
i 1 OBJECTIVES: )
- a. Complete the new facilities and the relocation by September 1990. ;
- b. Provide a comprehensive relocation package which will aid in !
ensuring the retention of personnel to the maximum extent possible. ]
ACTION PLAN
SUMMARY
START COMPLETION 1 ACTION DATE DATE Complete
- 1) Assemble a formal Relocation Project Team with 01/15/90 (02/01/90) an appropriate number of full-time, dedicated personnel to adequately support the new fac-r] ility completion, the office move and the V personnel relocation. ;
- 2) Utilize the Communication Committee to faci- 02/01/90 09/30/90 litate the dissemination of information from i and to the employees.
Complete
- 3) Develop a good understanding of the employees' 01/15/90 (02/01/90)
.n questions, concerns, etc. through the use of surveys, questionnaires and meetings in order to develop an appropriate relocation package, i
- 4) Publish a Relocation Newsletter as often as 01/15/90 09/30/90 ,
appropriate to formally relay information to !
the employees.
- 5) Provide and/or coordinate presentations to 02/01/90 09/30/90 L inform and educate employees about the l Russellville-area, i.e., schools, housing, .
7 medical facilities,. recreational opportunities,
. utilities, etc.
L 6) Construct a new office facility at ANO to 02/01/90 09/30/90 house the relocated personnel and equipment.
- 7) Establish / staff a " Relocation Office" to 02/01/90 09/30/90 l assist employees with their relocation problem, policy questions, etc.
NOTE: This is related to Item D.3 (DET 2.1.5.3)
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[- 1990 - 1994 BUSINESS PLAN
< 3 PROJECT / ACTIVITY PLANNING RECORD
- l. /
PROGRAM TITLE: G. Human Resources PROGRAM LEAD: Director Human Resources (Manager Human Resources)
PRIORITY: Medium
, PROJECT / ACTIVITY TITLE: 3. Recruiting and Retention DESCRIPTION: Review recruiting practices, Relocation Policy and starting salary practices to identify measures which can be taken to L rapidly fill open positions with appropriately qualified personnel.
Additionally, review the Relocation Policy to identify :hanges which can be used te minimize loss of personnel due to relocation to ANO.
OBJECTIVES:
- a. Increase staffing levels to the authorized level and mini-mize loss of corporate memory due to turnover of existing personnel.
- b. Attract sufficient, experienced new personnel into the organization
(-^g to encourage growth and new ideas.
O ACTION PLAN
SUMMARY
START COMPLETION ACTION DATE DATE
- 1) ' Examine root causes of loss of personnel 04/15/90, 06/15/90 and identify adjustments necessary to increase retention. (DET 2.1.5.3) 2)- Increase advertising and other recruiting 03/01/90 05/01/90 efforts to attract experienced personnel to ANO.
- 3) Review relocation benefits for potential 02/01/90 06/01/90 enhancements to improve retention and enhance hiring of new personnel.
(DET 2.1.1.5, 2.1.1.9, 2.1.5.3 and 2.1.5.4) i
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, l F' -c 1990 - 1994 BUSINESS PLAN !
,, j x
. Yg_):
, PROJECT / ACTIVITY PLANNING RECORD l
[. PROGRAM TITLE: G. Human Resources l
- 3 PROGRAM LEAD
- Director Human Resources {
(Manager Human Resources) l- !
PRIORITY: High !
[. PROJECT / ACTIVITY TITLE: 4. Employee Relations f+
r DESCRIPTION: Identify and implement activities to maintain good l employee relations. 1 i
i i
t OBJECTIVES: Establish and maintain a high morale in the work force, ,
increase professionalism, and reduce turnover and grievances.
ACTION PLAN SUW!ARY:
START COMPLETION ,
ACTION DATE DATE
- 1) Initiate periodic meetings of the management / 03/15/90 04/30/90 I Union Joint Cooperative Committee to improve employee / management communications. ;
- 2) Increase proactive approach to eliminate 02/01/90 12/31/92 .
potential employee work problems. .#
- 3) Initiate focus groups to identify potential 04/01/90 06/01/90- i generic employee relations problems, i r
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1990 - 1994 BUSINESS PLAN
) PROJECT / ACTIVITY PLANN'.NG RECORD PROGRAM TITLE: G. Human Resources PROGRAM LEAD: Director Human Resources (Manager Human Resources)
PRIORITY: Medium PROJECT / ACTIVITY TITLE: 5. Employee / Management Development DESCRIPTION:- Develop management and supervisory personnel through training and job assignments.
OBJECTIVES: Retain qualified personnel within ANO and encourage growth of personnel to improve ANO operation.
ACTION PLAN
SUMMARY
START COMPLETION ACTION _DATE DATE j'~') 1) Assign a individual as a loanee to INPO on 01/15/90 Complete S /1 a regular basis.
- 2) Coordinate a revision of minimum position 06/04/90 06/28/91 requirements.
- 3) Evaluate the use of management training 07/02/90 09/28/90 positions to allow selected individuals to obtain license certifications, attend management training courses and participate in special projects as training.
- 4) Identify core management training courses 05/07/90 09/28/90 to be included in the Management Development program.
- 5) Formalize the ANO employee / management 01/01/91 12/31/91 development process to include activities such as career path planning, succession planning, management training, etc.,
as appropriate.
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C 1990-1994 BUSINESS PLAN APPENDIX H. Training & Emergency Planning Program Lead: General Manager Technical Support & Assessment Projects / Activities:
- 1. Operations Training Upgrade
- 2. Manager and Technical Staff Training
- 3. System Engineering Training
- 4. Hazardous Material Training
- 5. Training System Maintenance
- 6. On-the-Job Training
- 7. Supervisory Training
- 8. Unit 1 Simulator Certification
- 9. Maintenance Basic Skills Training (INPO)
- 10. Revise Emergency Response Organization to Reflect the New Organization .'
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1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD
)
PROGRAM TITLE: H. Training and Emergency Planning PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: High PROJECT / ACTIVITY TITLE: 1. Operations Training Upgrade DESCRIPTION: The Operations Training Program will be upgraded by replacing the outdated Position Task Analysis for the operators with a Job Task Analysis (JTA) for each position and by creating an extensive JTA-based exam bank for use in testing operators.
OBJECTIVES: The objective is to bring the Operator Training Program up to industry standards and assure continued reaccreditation of the Operator Training Program and to improve operator exam (initial and-requal) performance.
, ; ACTION PLAN:
L ,)
START COMPLETION ACTION DATE DATE
- 1) Evaluate training resource requirements. 02/01/90 03/15/90
- 2) Complete Unit 2 Annual Exam Test Bank (Part 01/02/90 05/30/90 A,B.JPM and simulator scenarios) and submit to NRC.
- 3) Complete Unit I annual exam test bank and 03/15/90 11/30/90 submit to NRC.
- 4) Complete Unit I and Unit 2 Position Task 01/02/90 12/31/91 Analysis and uPErade lesson and simulator instructional material.
- 5) Provide operators operability determination 02/01/90 12/31/90 training. During this training, including Control Room Simulator, the SS/SRO are given a scenario in which an operability determina-tion must-be made, and the basis for the determination is discussed.
(DET 2.1.2.3, 2.1.2.13, and 2.1.4.6) ;
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1990 ~ 1994 BUSINESS PLAN
, PROJECT / ACTIVITY PLANNI G RECORD
- 's_/
PROGRAM TITLE: H. Training and Emergency Planning L PROGRAM LEAD: General Manager Technical Support and Assessment r-PRIORITY: Medium PROJECT /ACTIVIIT TITLE: 2. . Manager and Technical Staff Training
- - DESCRIPTION
- Provide management support for the Manager and Technical.
Staff Training Program to ensure continued accreditation through in-creasing participation of the eligible staff. 1 i=
h r
OBJECTIVES: Support'INPO accreditation of the Manager and Technical Staff Training. Program.
('h
'(_)- ACTION PLAN:
START COMPLETION ACTION DATE DATE
- 1) Establish schedule for M&TS Training classes. 02/12/90 05/30/90
- 2) Review the revised organization to ensure the 02/26/90. 05/30/90 training program targets the appropriate individuals.
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1990 - 1994 BUSINESS PLAN
} PROJECT / ACTIVITY PLANNING RECORD
'[J t
~.
PROGRAM TITLE: H. Training and Emergency Planning PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: High i
F PROJECT / ACTIVITY TITLE: 3. System Engineering Training
. DESCRIPTION:' Establish a System Engineering Training Program to train the System Engineers.
I OBJECTIVES: Implement a. System Engineering Training Program to support implementation the System Engineering Program at ANO.
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ACTION PLAN:'
START COMPLETION' ACTION DATE DATE
- 1) Develop and implement a training program 03/01/90 07/31/90 for the System Engineers.
(DET 2.1.5.2) l -.
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1990 - 1994 BUSIKESS PLAN PROJECT / ACTIVITY PLANNING RECORD c
-( ) l i
- s. ;
PROGRAM TITLE: H. Training and Emergency Planning i PROGRAM LEAD: General Manager Technical Support and Assessment i
PRIORITY: Low !
l PROJECT /ACTIVITT TITLE: 4.' Hazardous Materiel Training i
DESCRIPTION: Develop and implement-a training and retraining program to I instruct the general plant populace'and special response teams in hazar- !
dous material handling and response. l 4
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OBJECTIVES: Implement a training program in hazardous materials to meet OSHA requirements. !
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ACTION PLANT START COMPLETION ACTION DATE' DATE
{
9
- 1) . Hire a qualified trainer. .
Complete :
- 2) Develop and implement a training program 01/02/90 04/30/90 which meets OSHA requirements. ;
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i 1990 - 1994 BUSINESS PLAN !
- . .: t PROJECT / ACTIVITY PLANNING RECORD {
_ (s ; PROGRAM TITLE: M. Training and Emergency Planning ! l
- PROGRAM LEAD: General Manager Technical Support and Assessment j !- ' PRIORITY: Low ,
PROJECT / ACTIVITY TITLE: 5. Training System Maintenance l l E DESCRIPTION: .Ertablish an organization to ensure training system devel- I opment and maintenance _is conducted in accordance with established pro - j cedures and INPO standards, i
,.. -0BJECTIVES: Ensure the training programs are maintained in accordance !
with INPO standards. -l i, j' :l
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ACTION PLAN: -- START COMPLETION-ACTION DATE DATE i 1)- l Establish a group within the Training 03/15/90 '07/31/91 ! organization to' monitor all aspects of training development'and maintenance, 1 i t i 4
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; 1990 - 1994 BUSINESS PLAN i /
i :(._ ~) -
- PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: H. -Training and' Emergency Planning k PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: Medium PROJECT / ACTIVITY TITLE: ' 6. On-the-Job' Training I' DESCRIPTION: Ensure'only qualified personnel are assigned to perform tasks independently.
OBJECTIVES: To support INPO accreditation of Maintenance Training Program.
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ACTION PLAN: i START COMPLETION ACTION DATE DATE
/
- 1) -Revise " Conduct of Maintenance Procedure" Complete.
(1025.03) to address qualification of personnel.
- 2) Conduct an evaluation of implementation to 04/01/90 04/15/90-ensure that procedural requirements are being met.
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h I _ 1990 - 1994 BUSINESS PLAN l( y w ) PROJECT / ACTIVITY PLANNING RECORD L PROGRAM TITLE: H. Training & Emergency Planning PROGRAM LEAD: General Manager Technical Support and Assessment [ PRIORITY: Medium l PROJECT / ACTIVITY TITLE: 7. Supervisory Training
;.. DESCRIPTION: Expand the supervisory training program to provide basic and advanced management principles training to ANO management personnel on an ongoing basis.
OBJECTIVES: Ensure ANO management personnel are provided adequate managements skills training to perform their assigned duties. t ACTION PLAN: i START COMPLETION i ACTION DATE DATE , [~') 1) Conduct a management principles training 09/30/88 12/31/91 d
\s / program for.ANO management personnel emphasizing high individual and r organizational standards of performance. ;
- 2) Determine appropriate performance measures. 03/01/90 03/31/90 l (DET 2.1.1.2) !
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,E I 1990 - 1994 BUSINESS PLAN r" ; PROJECT / ACTIVITY PLANNING RECORD
~
PROGRAM TITLE: H. Training & Emergency Planning PROGRAM LEAD:- General Manager Technical Support and Assessment PRIORITY: High~ PROJECT / ACTIVITY TITLE: 8. Unit 1 Simulator Certification DESCRIPTION: Complete upgrade of Unit 1 simulator and perform ANS 3.5 Simulator certification tests. Submit certification package to NRC lt - ~~,. for approval. I L' OBJECTIVES: Certify Unit I simulator to ANS 3.5 standards. F- -ACTION PLAN: START COMPLETION ACTION DATE DATE
/~') - 1) ' Complete upgrade of Unit I simulator. 1985 12/31/90
\'I 2) Conduct simulator certification test. 10/01/90 12/31/90-h 4
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f, f 1990'- 1994 BUSINESS PLAN
,- y-1 PROJECT / ACTIVITY PLANNING RECORD n - (d .
M PROGRAM TITLE: H. Training & Emergency Planning [ PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: Low PROJECT / ACTIVITY TITLE: 9. Maintenance Basic Skills Training I DESCRIPTION: Develop training materials and conduct maintenance basic skills training classes for all maintenance personnel who have not-j; received basic skills training. g OBJECTIVES: Provide basic skills training for maintenance personnel. ACTION PLAN: START COMPLETION
.< s ACTION DATE DATE
+ \
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- 1) Develop and implement maintenance 01/08/90 06/30/90 basic skills course.
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,... 1990 - 1994 BUSINESS PLAN i jy,)
6 PROJECT / ACTIVITY PLANNING RECORD j
.. i PROGRAM TITLE:- H. Training & Emergency Planning i i
. PROGRAM LEAD:~ General Manager Technical Support and Assessment L. ' ' PRIORITY: Low V
1 PROJECT / ACTIVITY TITLE: 10. Revise ERO to Reflect New Organization ! t I [ DESCRIPTION: Revise the Emergency Response Organization (ERO) to reflect : the most recent ANO organization. i i OBJECTIVES: Provide qualified personnel to serve in the Emergency [ Response Organization. ; i i pq ACTION PLAN: I? () _ i START COMPLETION
- ACTION DATE DATE I i
- 1) Revise current emergency response to reflect 02/01/90 06/01/90 /;
the new organization. .I 2)- Provide training as necessary to qualify new 04/02/90 06/01/90 - ERO members. j i (SALP IV.D.3.b.1) r -- e l I' . I I P f
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H-10
e. 1990-1994 BUSINESS PLAN APPENDIX i ) I. Technical Support
, 1. Chemistry Program Lead: Director Nuclear Operations Projects / Activities: -,
- a. Service Water System
- b. Chemistry Control
- c. Surveillance
- d. Post Accident Sampling System
- e. Monitoring Equipment Upgrade (Both Units)
- f. Secondary System Layup
- g. On-line Monitoring (Unit 2)
- h. Condensers (Both units)
- 1. Facilities and Equipment
- j. Procedure Upgrade
- k. Chemical Control (Bulk Chemicals QC)
- 1. Hazardous Waste Management
- 2. Health Physics Program Lead: Director Nuclear Operations Projects / Activities:
f]
- a. Radiation Exposure Management
- b. Radioactive Waste (include High and Low Level)
- c. Contaminated Areas Reduction
- d. ALARA Awareness
- e. Facilities and Equipment
- f. Procedure Upgrade
- 3. Security l
Program Lead: General Manager Technical Support and Assessment Projects / Activities:
- a. Perimeter Upgrade
- b. Equipment Maintenance
- 4. Industrial Safety Program Lead: Director Nuclear Operations Projects / Activities:
- a. Consistent Enforcement of Industrial Safety Requirements a b. Site-Specific Safety Manual (f
l i l
- . . f- 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD l
- .i PROGRAM TITLE: 1. Technical Support i i
f PROGRAM LEAD: Director Nuclear Operations l PRIORITY: High i L' PROJECT / ACTIVITY TITLE: 1.a Chemistry - Service Water System
.l l
DESCRIPTION: Upgrade service water systems with regard to chemistry, f material and safety margins. ! i 1
-l OBJECTIVES: Improve service water system performance and safety margins. j i
a i ACTION PLAN: ,
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ACTION START DATE COMPLETION DATE
- 1) Evaluate Bromine. System. 03/01/90 12/15/90 l
- 2) Conduct chemical cleaning for 10/30/90 12/15/90 Unit I during the next Refueling i Outage.
Evaluate and implement 12/15/90
.3) 04/01/90 ;
chemical treatment'of ; service water systems. 4). Support SWIP. 03/01/90 12/15/90 : (DET.2.1.5.12) i e I L). , 1-1 4 ..g- - -p .- - , .,n-... - - . . - . , _,- , . . , .,
1990 - 1994 BUSINESS PLAN t I ' ~ / 's - PROJECT / ACTIVITY PLANNING RECORD
-Q)
PROGRAM TITLE: 1. Technical Support
- PROGRAM LEAD
- Director Nuclear Operations ;
PRIORITY: Medium , PROJECT / ACTIVITY TITLE: 1.b Chemistry - Chemistry Control ; n > DESCRIPTION: Through the use of improved chemistry controls reduce the the material degradation of the primary and secondary systems. , i OBJECTIVES: 'f F a. Reduce steam generator tube degradation.
- b. Minimize- transport of chemical contaminants to the steano generator, Minimize hours cut of specification due to coordinated boron / lithium c.
chemistry on both units primary systems,
- d. Meet best quartile INPO indicators.
+
t'~'s 3 i O ACTION PLAN: START COMPLETION _ ACTION DATE DATE t
- 1) Evaluate air In-Leakage 08/01/90-10/31/90 L improvements.
L 2) Develop study to determine 02/01/91 06/30/91 root cause of Unit 2 resin - degradation.
- 3) Evaluate Condenser Leak 04/01/91 08/31/91 .
Detection Systems (both units).
- 4) Develop program for acceptance 04/01/91 05/31/91 of bulk chemicals. -
- 5) Implement revised program. 10/01/91 06/30/92 ,
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It i. L 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD O)- 1 v PROGRAM TITLE: I. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: Medium PROJECT / ACTIVITY . TITLE.- 1.c Chemistry - Surveillances DESch1PTION: To enhance the existing surveillance requirements in the area of laboratory QA/QC. 4 OBJECTIVES:
- a. Meet existing surveillance schedule.
- b. Surveillance program to meet or exceed industry standards.
()
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ACTION PLAN: SfART COMPLETION ACTION DATE DATE 1)- Evaluate current QA/QC 03/01/90 06/30/90 program against industry practices and vendor recommendations.
- 2) Develop-any identified 10/01/90 02/28/91
- l. changes to the QA/QC surveillance program.
- 3) Implement revised QA/QC 06/01/91 09/30/91 surveillance program, if needed.
'4)- Evaluate effectiveness of 01/01/92 04/01/92 new program, if needed.
l-l 1 I' p~ A s / I-3
i l l 1990 - 1994 BUSINESS PLAN LJ
) PROJECT / ACTIVITY PLANNING RECORD l
l PROGRAM TITLE: I. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY:. Medium ; PROJECT / ACTIVITY TITLE: 1.d Chemistry - Post Accident Sampling System ' DESCRIPTION: To improve the quality of individual components within l the PASS system to enhance the overall reliability of the system. j i
] ,
OBJECTIVES:
- a. Improve material reliability of PASS components.
- b. Decrease number of reportable occurrences. ;
ACTION PLAN: START COMPLETION : ACTION DATE DATE
- 1) Complete study of 02/01/90. 06/30/90 PASS components. '
- 2) --Initiate actions. 07/01/90 10/31/90
- 3) Purchase recommended 12/01/90 03/31/91 new equipment.
- 4) Implement new changes. 05/01/91 10/31/91
- 5) Evaluate effectiveness of 01/01/92 04/30/92 new system.
[ \ ( I-4
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I' , l l i 1990 - 1994 BUSINESS PLAN l [' ) PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Support PROGRAM LEAD: Director Nuclear Operations 3 1 PRIORITY: Medium < PROJECT / ACTIVITY TITLE: 1.e Chemistry - Monitoring Equipment Upgrade (Both / Units) l DESCRIPTION: To improve analytical capabilities to allow the department to meet the increasing requirements to detect lower levels of contaminates, while increasing the number of analysis required. l OBJECTIVES: To better quantify materials transported to the steam generators. a.
- b. Achieve lower limits of detection in the lab,
- c. Provide capabilities to increase analytical output.
- d. Implement additional testing capabilities.
(~) C/ ACTION PLAN: START COMPLETION ACTION DATE DATE
- 1) Develop program for evaluation 07/01/90 11/01/90 of chemistry lab equipment.
- 2) Corrosion Froduct Samplers 06/01/90 12/15/90 installed.
- 3) Evaluate monitoring equipment 10/01/91 03/01/92 '
for air in-leakage detection.
**'N Y
I-5
7 i 5 t 3 1990 - 1994 BUSINESS PLAN , 1 ,! PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1._ Technical Support
, PROGRAM LEAD: Director Nuclear Operations PRIORITY: Low PROJECT / ACTIVITY TITLE: 1.f Chemistry - Secondary System Lay-up DESCRIPTION: To improve the internal conditions of the secondary system g during periods of outage.
OBJECTIVES:
- a. Minimize corrosion of secondary systems internal surfaces during outages.
- b. Decrease feedwater cleanup time required.
- c. Minimize corrosion transport to steam generators.
<^s, d. Minimize fouling of secondary resins.
l~ J ACTION PLAN: START COMPLETION ACTION DATE DATE
- 1) Evaluate use of dehumidifiers 04/01/91- 07/01/91 during outages.
- 2) Lay-up. implementing procedures 03/01/90 09/01/90 written for system lay-up.
- 3) Develop lay-up evaluation program. 08/01/91 12/01/91
- L )
N: i I-6
7- s 1990 - 1994 BUSINESS PLAN V PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Support . PROGRAM LEAD: Director Nuclear Operations PRIORITY: Low PROJECT / ACTIVITY TITLE: 1.g Chemistry - On-line Monitoring (Unit 2) . DESCRIPTION: To provide quick identification of chemistry trends which would have adverse affects on system components. Also, to provide bistorical documentation of trends. OBJECTIVES:
- a. Provide improved continuous monitoring of important chemistry parameters,
- b. Minimize out of specification conditions-secondary,
- c. Provide historical data trends,
- d. Minimize impurities ingress into the systems.
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ACTION PLAN: START COMPLETION ACTION DATE DATE
-1) Install purchased in-line 06/01/90 08/01/90
. analyzers.
- 2) Evaluation of data acquisition 08/01/90 11/01/90 systems for sample rooms.
- 3) Evaluate addition of on-line 12/15/90 02/01/91 ,
analyzert to primary.
- 4) Install in-line analyzers to 01/01/91 06/01/91 condensate makeup systems.
5). Installation of data acquisition 05/15/91 10/01/91
, systems for sample rooms, if deemed'necessary by evaluation. ;9 b
I-7
c s 1990 - 1994 BUSINESS PIAN PROJECT / ACTIVITY PLANNING RECORD f PROGRAM TITII: 1. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: Medium F PROJECT /ACliVITY TITLE: 1.h Chemistry - Condensers (both units) DESCRIPTION: To minimize transport of chemical contaminants to the steam ! i generators and to provide adequate protection to the circulating water systems. OBJECTIVES:
- a. Minimize degradation of the condenser tubes.
- b. Prolong life of circulating water equipment.
,~
ACTION PLAN: l START COMPLETION ! ACTION. DATE DATE , l Installation of Unit 2 turning 02/15/91 05/01/91 ! 1) vanes.
- 2) Install equipment to _
02/15/91 05/01/91 ! prolong tube life for Unit 2 ! Condenser. 4
- 3) Evaluate adequacy for 02/15/91 05/01/91 l cathodic protection both units. l 1
I a i
-1 i
i N._) I-8 L
o l 'y 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: I. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: Low PROJECT / ACTIVITY TITLE: 1.1 Chemistry - Facilities and Equipment DESCRIPTION: To provide the facilities and resources necessary to improve operation of the plant and its capabilities to meet regulatory requirements. OBJECTIVES:
- a. To provide sufficient work area for analytical testing.
- b. Material improvements to plant systems to increase efficiency of ooerations.
- c. Provide adequate storage of plant chemicals. '
- d. To improve capabilities of obtaining samples,
- e. To provide facilities to allow meeting regulatory requirements.
gs
- 4 /
ACTION PLAN: i START COMPLETION ACTION DATE DATE I
- 1) Evaluate existing lab 06/01/90 08/01/90 facilities. .
- 2) Evaluate hazardous waste 02/01/90 03/01/90 j storage facilities.
- 3) Evaluate plant auxiliary 04/01/90 07/01/90 i systems for Unit 2 upgrade.
- 4) Evaluate. plant auxiliary 07/15/90 09/11/90 systems for Unit I upgrade.
- 5) Evaluate existing NPDES 12/01/90 02/01/91 )
facilities for 1991 permit renewal. j
- 6) Construct hazardous materials 10/11/90 02/01/91 l storage facilities.
- 7) Evaluate diesel fuel 02/01/91 07/01/91
; storage facilities.
- 8) Evaluate Radiological 07/01/91 10/01/91 i Environment Sampling Points.
- 9) -Evaluate low-level counting 12/01/91 02/01/92 facility.
- 10) Implementation of the 02/15/92 09/11/92 '
'( results of these evaluations.
1 ~ Q], ' I-9
i~ 1990 - 1994 BUSINESS PLAN 7s i l PROJECT / ACTIVITY PLANNING RECORD
./
PROGRAM TITLE: I. Technical Support PROGRAM LEAD: Director Nuclear Operations , l PRIORITY: Low PROJECT / ACTIVITY TITLE: 1.j Chemistry - Procedure Upgrade DESCRIPTION: Establish a program to improve and maintain chemistry l procedures to provide quality instructions for the newly combined department by implementing detailed procedures. OBJECTIVES:
- a. To provide excellent chemistry procedures.
- b. To provide uniform departmental procedures,
- c. To provide detailed guidance in procedures. i
- d. To implement new regulatory reporting requirements.
!q l sj ACTION PLAN:
START COMPLETION ACTION DATE _ DATE l
- 1) Develop a procedure writer's 01/01/91 06/30/92 guide (2/25/90) and complete procedure upgrade.
- 2) Combine QC procedures. 01/01/91 04/01/91 ,
- 3) Combine departmental procedures. 01/01/91 06/30/92 ,
l
- 4) Implement new regulatory guidelines 01/01/91 06/30/92- -i as appropriate by.
l L : I L) I-10 l
( , 4
,"; 1990 - 1994 BUSINESS PLAN \ 'I PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: Low PROJECT / ACTIVITY TITLE: 1.k Chemistry ~ Chemical Control (Bulk Chemicals QC)
DESCRIPTION: Improve the efficiency of plant systems through the effective use of chemical controls, while minimizing the cost of operation. OBJECTIVES:
- a. Improve effectiveness of chemical control of circulating water systems - Unit 2.
- b. Reduce cost of operating plant through savings in bulk chemical purchases,
- c. Improve effectiveness of biological controls.
- d. Minimize impurity ingress into the systems.
Ik.
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- e. Reduce maintenance by deleting requirements for heat tracing of Boric Acid Addition piping.
ACTION' PLAN: START COMPLETION ACTION DATE DATE (Complete)
- 1) Evaluate cooling tower 02/01/90 03/01/90-
- chemicals.
- 2) Submit new chemical usage plan 06/01/90 07/01/90 for EPA approval.
- 3) AVT installation. 11/01/90 02/01/91
- 4) Implement new biocide program. 12/01/90 02/01/91
- 5) Develop bulk chemical QC program. 07/01/90 02/01/91
- 6) Evaluate usage of enriched boric acid. 02/01/91 07/01/91
- 7) Evaluate use of Lithiated Resin in the 10/01/90 02/01/91 primary system.
q v. 1-11
1990 - 1994 BUSINESS PLAN
. PROJECT / ACTIVITY PLANNING RECORD l PROGRAM TITLE: I. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: Medium ,
PROJECT / ACTIVITY TITLE: 1.1 Chemistry - Hazardous Waste Management DESCRIPTION: Complete the hazardous waste management program. OBJECTI\IS:
- a. Ensure regulatory compliance with hazardous waste regulations.
- b. Minimize hazardous waste generation.
- c. Improve hazardous waste identification, storage, and disposal.
ACTION PLAN: START COMPLETION ACTION DATE DATE 1)- Develop administrative procedures. 05/01/90 06/30/90
- 2) Develop implementing procedures. 07/01/90 08/31/90
- 3) Implement drum control program. 02/15/91 08/15/91
- 4) Develop waste sampling plan. 09/01/91 12/31/91
- 5) Implement waste sampling plan. 03/01/92 09/30/92 O
I-12
. 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD-PROGRAM TITLE: I. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: Low PROJECT / ACTIVITY TITLE: 2.a llealth Physics - Radiation Exposure Management DESCRIPTION: Implement a radiation dose management system capable of providing real-time control of occupational dose. The system must be fast.enough to not impact RCA entry and exit time. It must verify all regulatory and RWP requirements for each individual entry. It must maintain dosimetry records and generate reports as deemed necessary. It must be reliable and capable of error recovery with minimal impact on data integrity.
OBJECTIVES: At the end of the project, a system will be in place which hae been validated and verified to provide real-time access control assuring compliance with regulations and administrative controls. The system will serve as a tool in the management of occupational radiation exposure by providing meaningful access to its O; data. ACTION PLAN: START COMPLETION ACTION DATE DATE
- 1) Perform study to identify scope of REM upgrade: 03/01/90 06/01/90 A) Speed of real time access.
B) Enhance RUP writing and survey tracking. C) _ Increase user access to system.
- 2) Identify what REM upgrades are feasible to 06/01/90 '06/15/90 implement by 01/01/92.
- 3) Develop updated functional technical 05/01/90 07/01/90 specification.
- 4) Select vendor and. finali::e contract. 08/01/90 01/01/91
- 5) Complete system installation. 01/02/91 01/15/92 (SALP IV.B.3.b.3)
- O I-13
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRA11 TITLE: 1. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: Medium PROJECT / ACTIVITY TITLE: 2.b Health Physics - Radioactive Waste DESCRIPTION: It is the goal of the radwaste group to continue the implementation of new techniques in volume reduction to maintain radwaste volumes generated (buried) to less than 125m 8/ unit / year through 1992. OBJECTIVES:
- a. Repair of ventilation system to make trash compactor operable.
- b. Monitor and maintain an aggressive volume reduction program (i.e.,
trash segregation, waste decontamination, waste packaging, etc.) to reduce final volumes of radioactive waste requiring disposal.
- c. Switch to incinerable materials inside controlled areas.
- d. Improved material release facility,
- e. Continue efforts to reduce unnecessary materials from entering RCA's contaminated areas,
- f. Evaluate the feasibility of constructing and operating on-site laundry facility.
ACTION PLAN: START COMPLETION ACTION DATE DATE
- 1) Feasibility-study for on-site 03/01/90 09/30/90 laundry. Provide schedule for the following:
Proposal for purchase of-anti-C clothing.
- Purchase Anti-C clothing.
On-site laundry complete including staffing.
- 2) Complete DCP 88-2104 01/01/90 09/30/90 for box compactor operations.
- 3) Complete low-level waste monitoring 10/30/90 12/31/91 facility study and develop implementation schedule.
- 4) Switch to incinerable materials. 03/30/90 12/31/92 0
I-14
~
ll. 1990 - 1994-BUSINESS PLAN PROJECT / ACTIVITY PLANNINO RECORD
.q -
PROGRAM TITLE: 1. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: High PROJECT / ACTIVITY TITLE: 2.c Health Physics - Contaminated Area Reduction DESCRIPTION: Planned programmatic reduction of contaminated areas outside of the Reactor Building. OBJECTIVES:
- a. Reduce contaminated areas outside of the Reactor Building to <3% of the total square foot area (does not include high radiation or access areas). _ .
- b. Systematically reduce contaminated areas during 1990, 1991 and 1992.
,o . ACTION PLAN: i v7 START COMPLETION ACTION DATE DATE
- 1) Prioritize contaminated areas 03/01/90 07/01/90 for free release.
Identify Engineering support and 03/01/90 07/01/90- l
- 2) _ . maintenance support to repair =
contaminated system leaks.
- 3) Decon areas and free release as- !
maintenance activities are- l completed: i
- 20 Percent 04/01/90 10/01/90 l
- 40 Percent 04/01/90 01/01/91 )
- 60 Percent 04/01/90 07/01/91 l
=* 80 Percent 04/01/90. 01/01/92
- Achieve Objective 04/01/90 12/30/92 ,
_(SALP IV B.3.b.3) i i er k J I-15
- 1990 - 1994 BUSINESS PLAN
! .- ..- PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: Medium PROJECT / ACTIVITY TITLE: 2.d Health Physics - ALARA Awareness DESCRIPTION: Implement program improvements to evaluate aspects of
. operation and maintenance in regard to managing personnel radiation exposure As Low As Reasonably Achievable (ALARA).
OBJECTIVES:
- a. Reach upper quartile INPO ratings by 4th quarter 1992.
- b. Integrate ALARA into work planning.
- c. Insure RWP program complies with INPO guidelines,
- d. Involve all personnel at ANO.
- e. Establish radiological historical data base,
- f. Complete selection of RWP writing system,
- g. Reduce PCE's to 200/ unit / year.
- h. Reduce the number of areas requiring access level controls.
ACTION PLAN: START COMPLETION ACTION DATE DATE
- 1) Continued U 2 02 flush prior N/A Refueling to refueling outages to assist in the Outage reduction of areas in radiation levels. Dates
- 2) Obtain adequate engineering 02/15/90 01/30/91-support to evaluate source terms and (Ongoing) evaluate / implement source term reduction.
- 3) Increase ANO ALARA awareness. 03/03/90 04/30/90 4)- Provide incentive-for ALARA ideas 03/30/90 05/30/90 (will continue on permanent basis).
- 5) . Evaluate high-tech equipment which 03/01/90 06/30/91-is ALARA.
- 6) Work to improve general worker 03/01/90 06/30/91 radiation practices.
- 7) Develop a program to reduce access level 03/01/90 09/01/90 controls.
- 8) Track / trend number of radiologically 03/01/90 06/01/90 controlled areas (hot spots /RCAs).
(SALP IV.B.3.b.2 and IV.B.3.b.3) O I-16
I i 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Support PROGRAM LEAD: Director Nuclear Operations PRIORITY: Medium PROJECT / ACTIVITY TITLE: 2.e Health Physics - Facilities and Equipment' DESCRIPTION: Redesign CA-1/CA-2/ Count Room to optimize the efficient and effective use of all available space. The optimization shall provide positive control of the release of radioactive material and-provide for streamlined use of HP/ Dosimetry facilities. i i OBJECTIVES: When this project is complete, CA-1 and CA-2 will be arranged such that only those functions essential to day-to-day operation will be located there. The count room will be located and designed to support both instrument / respirator issue and radioactive sample analysis. Sufficient numbers of the proper types of survey
-instruments will be available to support routine operations and outages as well as non-routine analytical tasks. Offices presently located in the area will be moved to other locations where they do not occupy space .
f"'j_ . critically needed to support CA-1/CA-2/ Count Room functions. l u ,/- ACTION PLAN: START COMPLETION l ACTION DATE DATE j 9
- 1) Evaluate CA-1/CA-2/ Count Room Traffic 05/01/90 09/01/90 Patterns.
- 2) Evaluate analytical instrumentation 03/01/90 05/01/90 j needs. i
- 3) Evaluate survey instrumentation 03/15/90 05/01/90 i needs. i
- 4) Obtain new analytical / survey 05/20/90 11/30/90 j equipment. ~!
- 5) Evaluate relocation of office space 05/20/90 01/01/91 and coantroom: currently at :
CA-1/CA-2. ! 7 '6) Submit proposed facility changes 04/01/90 06/01/91 , for primary / secondary guard l house access / egress upgrade. $ i f
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I-17 J
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Standards PROGRAM LEAD: Director Nuclear Operations PRIORITY: Low 4 PROJECT / ACTIVITY TITLE: 2.f Health Physics Procedures DESCRIPTION: Establish a program to improve and maintain health physics procedures. l OBJECTIVES: To provide excellent health physics procedures. This will i provide the llealth Physics Department with the administrative and I procedural guidance to become a world class operation by 1993. 1 h l' ACTION PLAN: s'~'/ = START COMPLETION l ACTION DATE DATE { t a
- 1) Develop an procedure writer's guide 01/31/90 _ Complete .j for health physics. (02/25/90)- !
- 2) Upgrade the procedures to 01/31/91 12/31/92 l incorporate changes from 10CFR~20, ;
49CFR173 and procedure writer's j guide, j (SALP IV.B.3.b.1) l i m l~
, ,)
y j; V l'~ u , 1990 - 1994 BUSINESS PLAN
'\'~~ )
PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Support PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: High PROJECT / ACTIVITY TITLE: 3.a Security - Perimeter Upgrade DESCRIPTION: Complete the perimeter upgrade for the security system including upgrading the CAS/SAS consoles and elimination of the Emergency Pond from the system. OBJECTIVES: Improve performance of security to a SALP rating of 1, eliminate compensatory posts on the perimeter and ensure that alarm
-circuits and cameras are coordinated, y-Q h l' \,_/ '
ACTION PLAN: START COMPLETION ACTION DATE DATE
- 1) Complete DCP for upgrade 01/01/89 Complete of perimeter.
- 2) Complete 50.90 change to remove 11/01/89 03/30/90 ECP from Security Plan.-
3): Replace CAS/SAS consoles. 11/01/90 Complete
- 4) Complete testing and checkout 02/01/90 Complete for system.
- 5) . Train CAS/SAS officers on 01/30/90 Complete new system.
(SALP IV.E.3.b.1) *
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I-19
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Support PROGRAM LEAD: General Manager Technical Support and Assessment PRIORITY: Medium PROJECT /ACTIVlTY TITLE: 3.b Security - Equipment Maintenance DESCRIPTION: Improve maintenance and reliability of the security system by locating a suitable replacement for the current, obsolete card readers, identifying changes needed in security lighting to eliminate deficiencies and through dedicated maintenance ensure that equipment is properly maintained. OBJECTIVES: Improve SALP performance to 1, improve the performance of the security program at ANO and reduce compensatory posts for doors, lighting and other equipment deficiencies. ACTION PLAN: START COMPLETION ACTION DATE DATE
- 1) Conduct a study-and identify . 05/18/90-04/03/91' a suitable replacement card reader.
- 2) Conduct an engineering study of 04/23/90 01/31/91 security. lighting and implement design changes to correct deficiencies.
- 3) Dedicate maintenance crews to security 02/01/90 Complete equipment and monitor' performance.
(SALP IV.E.3.b.3) O 1 I-20
_1990 - 1994 BUSINESS PLAN
; PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Support PROGRAM LEAD: Manager Nuclear Operations Standards PRIORITY: Low PROJECT / ACTIVITY TITLE: 4.a Industrial Safety - Consistent Enforcement of Industrial Requirements
. DESCRIPTION: Encourage consistent enforcement of safety requirements by management.
OBJECTIVES: Ensure a safe working environment with clear expectations and accountability for safety by developing a 1000.xx series station admin, procedure by 6/1/90. O
-ACTION PLAN:-
START COMPLETION ACTION DATE DATE
- 1) -Include the-following items in the Station 03/01/90 06/01/90 administrative procedure on industrial safety:
- Review and revise safety-requirements to ensure they are clear and, enforceable.
- Focus management attention on enforcement of rules.
- Frequent safety communications to employees from the Safety Department and line-management.
I-21
p. t
-.. 1990 - 1994 BUSINESS PLAN
-s ) PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: 1. Technical Support PROGRAM LEAD: Manager Nuclear Operations Standards PRIORITY: Low ,
PROJECT / ACTIVITY TITLE: 4.b Industrial Safety - Site-Specific Safety Manual DESCRIPTION: Develop a site-specific Safety Manual. OBJECTIVES: The site-specific Safety Manual will be a small booklet which can be carried by each employee and which will replace the AP&L Safety Manual at ANO.
<s !
c ! l ACTION PLAN: l START COMPLETION ] ACTION DATE DATE -j 1
- 1) Develop and publish a' 03/01/90 08/01/90. j L site-specific, pocket-sized safety' manual.
1. I
.: 4 .
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I-22 ;
-;G:
lY 1990-1994 BUSINESS PLAN APPENDIX J. Administrative Support Program Lead: General Manager Nuclear Support i Projects / Activities:
- 1. Reduce Administrative Burdens
- 2. Enhance Administrative Support
- 3. Enhance Information Systems Support
- 4. Clerical Support Study i'
l l 1' 4 l i
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l 1_._.________._______,... . . _ _ . ~ . , . __
1990 - 1994 BUSINESS PLAN ()q);. PROJECT / ACTIVITY PLANNING RECORD PROGRAM-TITLE: J. Administrative Support PROGRAM LEAD: General Manager Nuclear Support PRIORITY: Medium ., PROJECT / ACTIVITY TITLE: 1. Reduce Administrative Burdens t DESCRIPTION: Identify sources of administrative burden that decrease the time-that line management can devote to direct involvement in their day-to-day operations. Develop and implement strategies to minimize this administrative burden on line management. OBJECTIVES:
- a. Identify and eliminate unnecessary administrative activities,
- b. Utilize Nuclear Support personnel to prepare reports, analyses, or other output to facilitate decision making or approval by line management.
- c. Coordinate administrative burden reduction activities with other projects in the administrative support and management systems L .
and resources programs.
- d. Reduce the administrative burden on the operations shift
.G x,,/ - supervisor. ACTION PLAN: START COMPLETION ACTION DATE DATE 1). Identify actions required to 03/01/90 12/31/91 reduce, transfer or eliminate administrative burden to the maximum extent possible. 2)- Evaluace administrative workload 03/20/90 09/30/90 of operations department shift supervisors. (DET 2.1.2.4) es
- 3) Revise work processes and procedures 09/01/90 06/30/92-where appropriate.
NOTE: This item is closely related to Items J.2 and J.3. (DET 2.1.2.4) q o N~/ J-1
~
b p_ . 1990 - 1994 BUSINESS PLAN
.y PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: J. Administrative Support PROGRAM LEAD: General Manager Nuclear Support 9
PRIORITY: Medium PROJECT / ACTIVITY TITLE: 2. Enhance Administrative Support DESCRIPTION: Remove administrative / clerical burdens from supervisory / management personnel by examining programs in effect that may be causing additional burden. OBJECTIVES: Ensure the administrative support resources are utilized such that administrative burden on line management is minimized while productivity is enhanced. ACTION PLAN: Analyze areas where changes in current support could increase the efficiency and everyday operation of supervisors and managers. These areas include: START COMPLETION ACTION DATE DATE .t
- 1) Mail Services - Evaluate 09/01/90 12/31/90
/ 'N ~
distribution need and the most
\_-) effective methods of providing ;
mail services to all areas of ANO.
- 2) Document Control - Evaluate needs 02/01/91 06/30/91 to place documents in the areas of use. Evaluate the method to more efficiently control and track technical documents and plant proceu res,
- 3) Word Processing - Evaluate need to 08/01/90 10/15/90 place word processing personnel in the areas for production typing needs instead of in one central area (now 5th floor). Evaluate needs for desktop publishing, including training and other PC' software.
- 4) Copy / Printing needs - Evaluate needs 07/01/90 10/15/90 for copying and printing services to establish whether manned copy centers should be utilized for ANO copying and printing requirements.
-5) Ensure the administrative support 05/01/90 12/31/90 needs are adequately addressed ,
in the Master Site Plan (e.g., records vault, records management computer facility, etc.). [See D.8-2] _ry , j' J-2
1990 - 1994 BUSINESS PLAN
.s8 ,.! ' PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: J. Administrative Support PROGRAM LEAD: Director Corporate Services (Hanager ANO Information Services)
PRIORITY: Medium PROJECT / ACTIVITY TITLE: 3. Enhance Information Systems Support
. DESCRIPTION: -Provide enhanced ANO Information Systems Support ,
consistent with the goals and objectives set forth in the Business Plan ' and the IS Strategic Plan. OBJECTIVES:
- a. Implement strategic systems on a limited set of hardware platforms (IBM and Digital). Adopt an applications development methodology which facilitates migration of applications to multiple processing tiers,
- b. Assure common data is shared, data integrity can be maintained and duplicate applications are minimized.
- c. Provide an on-going computer training program for IS support staff and tnd users to obtain maximum benefits from information systems.
- d. Assure the IS Strategic Plan is integrated with the Business Plan and-communicated to IS users and management. -
,- ~4 e. Ensure that telecommunications activities are closely tied to IS.
- f. The IS support organization must have appropriate staff and authority
( 'J - to ensure proper implementation of directives from the Strategic.IS Plan. ACTION PLAN: START COMPLETION ACTION DATE DATE
- 1) Develop ANO Information Systems Plan. 04/01/90 .12/31/90
- 2) Identify and prioritize 08/15/90 ~ 11/15/90 supporting projects and tasks, such as:
SIMS Enhancements. Tandem Study Project. Action Tracking Consolidation.
. MMIS Phase II.
- AS400/ Word Processing. !
EMAIL. DCIMS. i Accounts Payable. Time Reporting System. Performance Indicators. NPRDS Uploads, etc.
- 3) Develop appropriate measurements 07/01/90 09/30/90 of effectiveness for IS activities, 7.x i )
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J-3
.s . ?-;
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: J. Administrative Support PROGRAM LEAD: General Manager Nuclear Support PRIORITY: Low i PROJECT / ACTIVITY TITLE: 4. Clerical Support Study DESCRIPTION: Conduct a study of clerical support for ANO to identify the most effective means of meeting the clerical needs for all site personnel. OBJECTIVES: Improve the effectiveness of the organization by ensuring the proper clerical support is provided to each area and eliminate the long-term use of contract clerical help in-areas needing permanent clerical support. ACTION PLAN: START COMPLETION ACTION- DATE DATE
- 1) Staff Contract Clerical 01/01/90 Complete Support Supervisor position in Office Services.
- 2) Identify needs surveys '05/01/90 10/15/90 throughout the organization.
- 3) Review non-clerical staffing 10/15/90 11/15/90 and recommend clerical staffing levels and locations based on the needs surveys.
4)- Obtain appropriate reviews and 11/15/90 12/15/90 approvals and adjust cler<ical staffing as approved.
- 5) Provide method for continued 09/15/90 11/15/90 monitoring and adjustment of clerical staffing levels.
4: J-4
- = - - - _ _ _ _ _ _ . . _ . . . . .
- 1. 1990-1994 BUSINESS PLAN APPENDIX Management Systems & Resources
~
K. Program Lead: General Manager Nuclear Support Projects / Activities:
- 1. Financial Management Activities
- 2. Administrative Controls Standards
, 3. Communications
- 4. Contractor Utilization Study
- 5. Organizational Culture
- 6. Staffing Plan
- 7. Management Processess i
f 11 0
, _ . . q 1990 - 1994 BUSINESS PLAN
[ PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: K. Management Systems and Resources PROGRAM LEAD: General Manager Nuclear Support
~ PRIORITY: Medium l l
PROJECT / ACTIVITY TITLE:- 1. Financial Management Activities i DESCRIPTION: Improve processes in the areas of monitoring, planning. and forecasting of financial resources. , I OBJECTIVES: q
- a. Provide management with accurate and timely information as to: j
- Utilization of financial resources. _
- Forecast of resources required for current year as well j as for future periods. j
- b. Establish a process for assessment and reallocation of financial .;
resources based on changing needs. !
- c. Reduce the administrative burden for cost management from line j
-organization.
ACTION PLAN: j \ 73j 1 START COMPLETION j ACTION
~
DATE DATE l
.b
- 1) Development / Implementation of 01/01/90 06/01/90 1 Comprehensive Ofdl Cost Program,
- 2) Refine and proceduralize cost programs. 06/01/90 06/30/91 1
- 3) ' Implement additional cost engineering 06/01/90 08/01/90 support to Design Engineering.
- 4) Implement additional performance 04/01/90 06/01/90 l, l analysis / cost engineering support !
to comply with proposed Bechtel contract. l
- 5) Implement adequate level of cost management 04/01/90 06/01/90 i support for projects included in the l Business Plan, j (DET 2.1.1.9) .l i
K-1
~1990 - 1994' BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD L( )
PROGRAM TITLE: K. Management Systems and Resources PROGRAM LEAD: General Manager Nuclear Support PRIORITY: Medium a PROJECT / ACTIVITY TITLE: 2. Administrative Controls Standards DESCRIPTION: Develop and maintain guidance which clearly defines the administrative control practices for the nuclear organization. OBJECTIVES:
- a. Reduce redundancies, inconsistencies and conflicting guidance in administrative control practices and documents,
- b. Improved consistency in administrative processes between departments.
- c. Provide a means to formally assess administrative practices and documents at various levels in the organization.
- d. Provide an administrative process which is more efficient to update for a reorganization.
- e. Provide a means to-quickly identify the responsible authority for a department's administrative processes.
-1 f. Provide a means to assure corporate guidance and directives are disseminated to the appropriate working IcVel.
ACTION PLAN: START COMPLETION ACTION DATE DATE-
- 1) Propose an improved administrative 12/01/89 06/01/90 controls document numbering system.
- 2) Propose document definitions.. 12/01/89 06/01/90
- 3) Develop a restructuring plan for 12/01/89 06/01/90 each group of documents.
- 4) Rewrite the Station Administrative 06/01/90 10/01/91 Procedures in accordance with the approved restructuring plans.
- 5) Rewrite the Department Administrative 06/01/90 10/01/91
. Procedures in accordance with the approved restructuring plan.
- 6) Implement the station administrative 10/01/91 12/31/91
~ documents.
- 7) Implement the Department Administrative 10/01/91 12/31/91 documents.
- 8) Update document index. 10/01/91 12/31/91 g (DET 2.1.1.5) i K-2
1990 - 1994 BUSINESS PLAN _ PROJECT / ACTIVITY PLANNING RECORD l PROGRAM TITLE: K. Management Systems & Resources PROGRAM LEAD: General Menager Nuclear Support PRIORITY: Medium PROJECT / ACTIVITY TITLE: 3. Communications DESCRIPTION: Publish and periodically update'a communications plan for ANO which identifies both the issues to be communicated (e.g., management expectations for standards of performance, emphasis on safety, etc.) and the potential communications vehicles to be used (e.g., newsletter, personal communication, or media center). OBJECTIVES:
- a. Improve performance through effective communications through all supervisory and working levels.
- b. Assure consistent communication of key issues so that all personnel
- receive the same message in a timely manner.
- c. Utilize of a variety of communication vehicles to improve the effectiveness of the communication.
ACTION PLAN: START COMPLETION ACTION DATE DATE
- 1) Update the ANO Communications Plan 02/01/90 03/30/90 developed and implemented in 1989 on a semiannual basis.
- 2) Develop department specific 02/01/90 06/30/90 communications plans as-appropriate.
NOTE: This item is related to Item D.9 (DET 2.1.1.1, 2.1.1.2, 2.1.1.5, 2.1.1.6, 2.1.1.9, 2.1.3.7 and 2.1.5.5)
.O K-3
= _ - _ _ _ - __________ - __ - __-__ ________-_-_______ _____,___________-_____ ___________ ____________-____ _ _ _ _ _ _ - _ _ _ _ _ _ _ -
g: m 1990 - 1994 BUSINESS PLAN fui ;/ w I~ PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: K. Management System & Resources PROGRAM LEAD: General Manager Nuclear Support PRIORITY: Medium PROJECT / ACTIVITY TITLE: 4. Contractor Utilization Study DESCRIPTION: Develop guidelines for utilization of Contractor Support for ANO. OBJECTIVES: Proper utilization of contractor support (e.g., scope of work cont racts instead of staff augmentation).
. ,, - ~
i )
%/
ACTION PLAN: START COMPLETION ACTION DATE DATE I 1
- 1) Identify functions for which 02/01/90 04/01/90 contractor support will be utilized (e.g., security and maintenance /
modification. support).
- 2) Identify general requirements for 02/01/90 04/01/90 contractors providing support for ANO (e.g., sufficient company size and expertise to ensure ability to adequately accomplish
-the contracted task / activity).
- 3) Coordinate with staffing plan 02/01/90 05/01/90 (Item K.6) to ensure-these guidelines are incorporated into the plan.
- (DET 2.1.1.5, 2.1.1.9, and 2.1.5.4) (~). u K-4
t.
/ll 1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: K. Management Systems & Resources PROGRAM LEAD: Vice President Nuclear PRIORITY: High PROJECT / ACTIVITY TITLE: 5. Organizational Culture DESCRIPTION: Initiate improvements to redirect the ANO organizational culture consistent with the three' year objective of becoming a world class nuclear operations facility. This culture should place emphasis on high individual and organizational standards of performance and should encourage and reward good practices such as conservative operations, professionalism, critical self-assessment, and candor with the regulator.
OBJECTIVES: An organizational culture which supports management's stated organizational objectives and goals.
.- ACTION PLAN:
START COMPLETION ACTION DATE DATE
- 1) Establish appropriate measures of 02/20/90 06/01/90 effectiveness and baseline values for future comparisons. ,
- 2) Define specific organizational behavior 03/19/90 05/31/90 expectations related to targeted culture i change.
- 3) Define individual behavior expectations 06/04/90 10/01/90'
. supportive of desired organizational behaviors.
- 4) Define and implement methods of recognition 09/03/90 09/21/90 and reward for individual / organizational performance reflective of the targeted culture change.
(DET 2.1.1.1, 2.1.1.2, 2.1.1.4, and 2.1.1.6) (SALP IV.A.S.b 2) O K-5
1990 - 1994 BUSINESS PLAN PROJECT / ACTIVITY PLANNING RECORD PROGRAM TITLE: K. Management Systems & Resources PROGRAM LEAD: Director llaman Res,ources (Manager lluman Resources) PRIORITY: High PROJECT / ACTIVITY TITLE: 6. Staffing Plan DESCRIPTION: Conduct a staffing study to determine the staff levels necessary for each work group to accomplish its assigned mission consistent with stated organizational goals and objectives. Develop a staffing plan to accomplish the recommended staff levels from the staffing study within a three-year period. This effort must be coordinated with the destaffing which will result from the contractor utilization study (Item K.4). OBJECTIVES: a, Adequate staffing levels by organizational work group and type of employee (engineer, technician, etc.).
- b. Transition plan for achieving the desired permanent staf f levels,
- c. Adequate permanent staff to achieve organizational goals and objectives.
O d. Reduce depeniince on Contractors. ACTION PLAN: START COMPLETION ACTION _DATE DATE
- 1) Conduct a staffing study, including 01/22/90 04/15/90 interviews with management representatives for each work group, as needed, to determine:
- Current and anticipated workload.
- Current and anticipated staff size.
- 2) Review and finalize staff level 02/12/90 04/15/90 recommendations.
- 3) Prepare and implement a staffing 03/12/90 06/01/90 plan for recruitment of additional staff in conjunction with destaffing of contractor personnel.
(DET 2.1.1.5, 2.1.1.9. 2.1.3.1, 2.1.5.3 and 2.1.5.4) (SALP IV.E.3.b.2 and IV.C.3.b.7) O K-6
/kn~
1990 - 1994 BUSINESS PLAN :
> PROJECT / ACTIVITY PLANNING RECORD ! %_) .
L PROGRAM TITLE: K. Management Systems & Resources ! s PROGRAM LEAD: General Manager Nuclear Support ! [ PRIORITY: Nedium i
). ! PROJECT / ACTIVITY TITLE: 7. Management Processes t l
DESCRIPTION: Implement and enintain processes to facilitate and improve ( management and decision making. 'l OBJECTIVES: ! l a. Utilize a comprehensive plan for site betterment-activities, i.e., t ! the ANO Business Plan. i
- b. Ensure the processes to. support management and decision making .
maximize the effectiveness of the ANO management team. ; f ACTION PLAN: 3 n START COMPLETION ! ACTION DATE DATE [
- 1) Implement the ANO Bnsiness Plan 09/01/89 03/31/90- '
/*)
( -including prioritization of new programs. Review and update on i a routine basis. ; I > -2) Determine how to best utilize the collective
. 09/01/89 06/30/90 l expertise of the senior management team to !
effectively evaluate all aspects of critical ! I l issues prior to a decision. '
- 3) Identify department goals and 01/19/90 04/15/90 obj ectives '.
- 4) Restructure Monthly Management Review 01/02/90 Complete l
. Hectings-to provide senior Executive
, Managers with appropriate knowledge of ANO activities. !
(DET 2.1.1.1, 2.1.1.5 and 2.1.1.9) ; (SAT.P IV.G.3.b.5) i h L!v[ ; h K-7
. - .- .-. ~ . ,}}