ML20024B290

Expresses Appreciation for Outstanding Job in Conduct of Review Re Efforts,Findings & Recommendations Concerning Mgt Review of Preliminary Safety Concerns Procedure

ML20024B290
Person / Time
Site:	Crane
Issue date:	12/14/1979
From:	Roy D BABCOCK & WILCOX CO.
To:	BABCOCK & WILCOX CO.
References
TASK-02, TASK-03, TASK-2, TASK-3, TASK-GB GPU-2421, NUDOCS 8307080271
Download: ML20024B290 (12)

Text

$ -.,

..~._v...w=--..

~

GPU2V2d

'~

0 y\\b y

a Xc ; F D S /61 ;'

...J r/o THE 8t2 COCK I, 't!!LCOX CC!tPitiY

---/

,.- -. g f g., g

~ _/

u,., 3.' {j F1 },.,

PO!ER GEi. ERAT 10!! GP. CUP WbA li %

s ja -l Addressces Froa

0. H.' Roy Manager, NPC3 Engineering (2375) ees..:.a file No.

Cust.

or Ref.

Cate Subj.

December 14. 1979 7

Management Review of PSC Procedure gi....................

Addressees

[

E. V. DeCarli C. A. Ar.nontrout J. H. Taylor Reference Memo. E. V. DeCarli to A. L. MacKinney. "Recer:: tended Ch.nges to PSC Precedure IPG 1707-01 (Rev 7)". dated Cecer.ber 5.1979..

Cn December 14. 1979, the addressess met to censider disposition of the recc.mendaticns for improving the prccessing of Preliminary Safety Concerns (PSC) contained in the referenced remo. A manager.ent review of the PSC procedure and of the attitudes and experiences of personnel utilizing the smcadure was conducted-0 by C. Arrentrout of the CA Capartment and R. 0:novan of the Project f!anage-ent Department in accordance with my request to Mr. E. CeCarli. The team did an outstanding jcb in the conduct of the review and are to'ba cengratulated for their efferts and fer their findings and recer.-.endations.

Action ite:S addressing thf 'reco=endations are as followsi J. H. Taylor to prepare guidelines for use by his Licensing ranagerk in

~

1.

conducting the initial PSC review meeting.

2.

The follewup action plan will be included in the Corrective Action section of the evaluation report for the PSC; schedule and respnnsibility will be included for esch iten of the plan. The follewus action plan e.ust assure that a docurented, traceable systcm'fo'r assuring dispcsition of required actio t is pretNeed for both in-house and custcecr iten.s: the ;recedure is to be revised :s necessary to clearly define how closure is to be achieved.

3.

The final eialuation report will note cbjections to the resolution scecified ir. the report for subsc;uent conccrrence or non-ccncurrence and additional directives as aiprepriate from the Manager of QA ced Manager of Engine: ring.

4 J. H. Taylor wilt include in the guidelines to his t.icensing managers-tne.... '

c!rsctive that priority c!'ar.ges will require his approval.

5. "J. h. Tevie all t*'ste a ravie 1 of PSC's iht:rd in ths. past three veers

[

ta e:Il n; On resetrec: i n :nc Er.T + -~ ~1 n: Litpa r..........i e t- - ---.

.. o s

i s

' et. set:::

l

!:. t! c s c!! ;w; "J. Cunrtrent effered to ct....

...,..nlati.y tiw tr-

\\ l l

i 8

t

(

6

~

.e*

e 6e.

Dlo 4icW4 N

e m.

l

}

8307080271 791214

~

PDR ADOCK 05000289 p

g

..-.h.....,.

...s.....

~

' * ^

.,,,...m,

....h.....

- = - "

,.. AX. L O

1 v

O

.G Addressees 2

CecerN r 14, 1979 6.

The minutas of the front end : view ceeting should define and docu ent the

~

evaluation plan.

7.

The Managment Directive will include requirerents for issuing of status L

reports.

J. H. Taylor will establish forcat and distribution for the status report incorporacing recomendations given in itees 1.d and 1.e of the referenced ceco.

[

8.

QA will conduct a folicwup management audit to determine employee response to the f*anagement Directive. the revised procedure and the training program.

This will be conducted within two weeks after issuance of the Managerent

@~

Oirective.

g

/\\s p

p s

.s CHR:nw F.

,3

..7=_.

E.

b

~ 0 a

t

,L s

- ' ~ "

a..._...

g L

~

s e.

~

,i f

i l

311l,1 7 ' 7 ',t-l-

D15 4 1 5~c.

e

~

-I

.1 1

~... -._ ~... -.........

=

_..=w 1 M - 4:=i_ ' ~=- T ^.

' -- c. J :- --

~.,..

.2 x _.

=

//

'd > y/y~ :,,

TI E'.SA3C00K A ;ilLCOX CGT Y p

W PdEtt.CE!:EP.ATIC!i CliOUP D.ll. Roy.1*:n:ger. IsPC3 Engineering har*.nent-f

= - = *

• p

E.V. CeCarli :4n:ger, f;FCD C:ality Osurance Cept. (2558) ses sss.s h st.

b File No.

gg,73 4

~

or Rcf.

^

r.

soj.

p-Date P.anagement Review of Prelimir.ary Safety Concerns Decc: der 4.1973 E

r l

j....................

(--

COMPMY PROFRIETARY

_C HITED DISTRIBUTTON BACXGR0t *:3

~

E.

g.

Since I:ovceber 13. 1973. the Company has had in place a procedure for identifying and processing Preliminary Saraty Concems (PSC's).

The c.ain purpose of the procedure and the thrust of can;igement emphasis have historically been to ensure C

cc=pliance with ICCFRSO and ICCFR21. Safety concerns that were not reportable were handled thecush nor: al cperating procedures. In the vake of the Titt accicant it i

was dccced a; pre;riate to review the Ccapany's precedures in this area to dater =ine p

if any icprovements should be made regard.ing the reporti,ng and resolution of safety g.

c ncerns.

At your request a Management Review has been conducted to deter =ine the Division's ef fectiveness in the resolution of PSC's. The review was conducted by R.E. 02:'ovan r

and C.A. Arrontrout. The review concentrat d en such broader-scope subjects as respcasibility for PSC's, fundino, inorovecents that could be made 1:: handling PEC's.

the attitudes of I;FCD personnel toward PSC's, and the implerantation of resolutions.

3[

The review uss accorolished by interviewing tuanty cans <;ers and individual werkers in the Engineering. Project :*anage= nt. Cust::or Service, and Quality Assurance

~

Depart:

Intervicus ranged fro:a one half hour to two hcurs each and the 2nts.

S intervic:ers felt that with0ut exceptica each persen interviewed was opan and

' genuinely tried to assist in and centritute to the review.

In additicn to the intervic.:s the Division's procedures pertaining to FSC's were reviewed as were a nu ter of PSC's."

FIND!!;0S 1.

The reviewers reund tiat the Oivisien has been undcr;aing a subst:ntial chinge

,in attitud: ::uarc FSC's since the TMI accicent. Pre-TM1, the G recal atti tude seems to have taen that a ninfrzt of TSC's should be gcccrated consistcr.t with the rer,uirc:ents of the 1:w. Attitudes have definitely shif'ed in the dirce. tion of re;;rting r:re cencerns as PSC':: hcwever, a w!da socctres of cainten still t

crists rangin: frc i rtinimu.a to c:xime disclosure. The.?cenle intervicued ci.f not ar;:ar to te encrcn: hec in their positicas regardin;: what should and should not N rc, Ortad,as e l'5C; rather they a ecared i: c: o m to sucrestion md ii cacd of e id m e.

it is clear tni.: as tnings now st3nu tnarc is a w m s:re2a 0

w 311 1.7. t7! E 6'1 5

~__.__F..

D15

...f.

~

e e

.:.,.._-.c

. -. - ~.

1_

=* --

{

n.:..-:

- ? v..-; ; -i=;: %. _;.-i

_i.

~;% _

D.H. P.oy

• .n:gceant Review of PSC's

. a 2-Dc:(.-2;cr 4. 1979

.differer.cc of opinion reg:rding :: hat should :nd should not !d reported as a PSC.

g...., 'It was the opinion of tt.o unit ranagers in the Cc=ponent Engir.ecring that they viould not write a PSC if they determined the concern to 'ce non-reportable per Part 21 or 50.55(e). It is the opinion of the intervie ars that the new procedure, t:hich is = ore general in its definition of a PSC. will only aggravate this situation unless some specific guidance is given with regard to t.t.at should be' reported as a PSC.

2.

Another salient point that came across strongly in the interviews was that pecole do not understand ea deoree of imeert?nce tht the Divitie't management attaenes to PSC's.

It was pointed out several times that PSC's are not specifically addressed in J.H. Macflillan's August 22. 1979 cero specifying engineering priorities and as a result they tend to suffer screwhat from a 1:ck of priority. Typical ec=ents regarding PSC priority were as follows:

Unit Manager A.

"The squeaky wheel gets worked en. If no one is pushing a PSC. it doesn't get worked on."

Unit Manager B.

"PSC's don't appear to be en Don Roy's priority list, so they're not on mine."

Unit Manager C.

"PSC's do get the necessary attention, but we

' screen them first to see what ones we think deserve to be worked on new."

This cc=ent 0

leads ne to believe that the PSC priorities are detcrained by the individual working on them as judged by his self-determi..ed criteria.

3.

Most persens intervie::ed expressed a desire for additier.al training relative to PSC's. The folicwing tcpics were suggested for inclusien in the training:

a.

Managem:nt philoso:,hy relative to PSC'.s with ecphasis on changes in attitude or philoscphy.

b.

Personal legal obligations and liabilities under ICCFR21 and 10CFTs50.

• /

c.

A brief overvie., of precedural changes.

d.

Discussion of several exarples illustrating the kinds of things that should not be reported as PSC's.

4.

"Approxix.ately one third of the people interviewed expressed sc=e dissatisfaction over the nucer of PSC's being generated. 0;,intens ran cd fr:m 1) rsoole were using PSC's to get attentica or piierity on pct crojects. 2) that TSC's >:ere being uscd as a way to get additional v.ork brougnt into certain units. 3) that

~ "'

~

a number of PSC's h:d been written for in :nsequen:ial its: s.

But in soite of the fact that in the o: inion of r:ny pecple an c).cessive nt:ter of PFC's were being t:ritttn. no c:.her of the En;ir.s:rin: Oc;:rt ent *.o yas intervic ed c':uld Q

yen uith

1. .- ::4ct

'm

! t'. -'

? : ' ~;.-

r* V > ~

• '~

i.. ;,hn f,,. d.2.s e cM. s wa.

8

-1 t

l

^

31117'.7.'?

- D 15 l6

• l 6._C 1

' ' - ~

~.

l'

. - _. _. ~. -

_.4.

=..

. = - -.

L..

~

_. ~

• O.H. Roy.

I'. anger:nt Revicu of PSC's,.

Cccember 4, 1979 t

c.

u S.

A sense of frustration was detected with respect to the slew ranner that PSC's j

ant processed.

g t

.+

+e Unit Manager D.,

"Daadlines should be es.t:blished for ' resolution of

~

PSC's.

They drag on tco long.*

[

. Engineer A.

" Follow-uo action is net errhasized encuah."

['

m E'gineer B.

"_Pricrities need to be established. We have too

• h n

many outstanding PSC's new.

t._b Project Manager A.

"As we set more and core PSC's, there is a danger that we will be forced to give less thcrough F

reviews.*

0).

6.

The front end PSC review cectings were thcught to be a good idea, but several E;

People stated that they should be ore for al !ad ere tichtiv centrolled. If the one front end =ecting attended by the interviewers is typical, the E

interviewers can support that position.

{

It is' not presently possible to dele'rmine fro:s any single source whether or E-r-

7.

not all of the follow-up action on closed-out PSC's was/were accocplished.

k Furtherecre, it is not possible to determine on outstanding PSC's just what 3

action remains to be done. It is possible that the Follcw-U') actie9 91 mt t

(FAP) required by the new PSC procedure (!:PGJ-1707-01 Rev. 07) '<111 correct y-this situation, but certain details of ecchanics and forrat still need to bc a

worked out. Licensing feels resoonsible for working out these details, but

.C the procedure d:es net clearly assign respcasibility for tracking folicw-up C

actions.

p 8.

Orininators of PSC's are not necessarily involved in tha - alutica of tha "' C.

and are not retaired to concur in.ne riral dis:esition of the PSC. Several people oojected to this, one rather strongly. Tha one individual who objected strongly stated that he did not agree with the action taken to resolve his concern.

e 9.

funding has been an obstacle to PSC resolutien in 'the past, but in sera cases r

it may have been mora of an e.tcuso than an obstacie. The procedures descrihad in E.R. Kane's October 16, 1979 meno cay have assentially. solved this problen, rc l ',',,

but it's too early to tell.

~

E

~

10.

A statistical review of PSC's criainsted ir. the last three years was rade. The total FSC's issued, total PSC's closed PSC's iss'.,cd in 1277, 197S, :nd 1079 r

and the nunter of I'SC's issued per coith are she.r. in Figura 1.

Minety-r.ine PSC's hava been issued over inc pc:t three yers.-:ith 57 issued in 1979. As can be seen in Figure 1, there was a sh:rn rise in the n :eb:e of pSC's isseed aftar the 7::: accicant. Figure'2 sheus t.te nu.t.W of PSC's issuad by the various n?CD Secticas and ind!:stes that the Plan: Cesign secti:n has issu:d core PSC's than any other s:: tion. Table 1 she.rs.r.at, :: least in 1979. r:re PSC's nave been issued for analytical probic:s t. ar. any othar reasc:. Cf ths

' nie,tygiy,, PSC's issued, only M ba te t ven closed (i.e., evalestf ea ef."50 r

0 4

g.

&xS 'kW'f bk W'.

.Y.

8 s-

^

311 I sT 8 4 D 15 ~l4 1 6' F

?---~-----

i

-.1

. ~'

~ < '

w.-

<~

s

.. L'. n.. :. ]

ILnaga,nt % view of PSC Decc.:ba? 4, 19'79

B p..,s.

r.g~.+

i completed, reportability daterrb.d' necessary folice.ep action detmined but not !=clecented). Figure 5 Udicates that only 33'. of the FSC's were closed within 5 conths of issui r '. 30C of the closFJ PSC's were r.cesidered

~

i A

to be re;ortable undar the regt..

rents of ICCFR21 or 50.55(e) and 705 required v

so::.c folleu-up action. Hovever. :s stated in finding nuder 7, it was not practical,because of tiec, duri.. this review to determine if the follow-up action had ever becn coeplcted since there is no tracking system in place to.

[

detereine this. Of the 99 PSC's issued 49 (.*7 issued in 1979) are outstancing.

Only ISC of the cutst:nding PSC's (43) have been evaluated for rerortability.

Figu*e 3 shows the conths that the PSC's have been outstanding. Ts.o PSC's have.

I r

beer. outgtanding fer alrost t..o years with the rest ranging from 1 to 9 n:enths.

IE s The tuo PSC's outstanding for almost tuo years are PCS Overara"u-a (sse m.m and M1 Cali5c n b r ~ m ( M c 7-721 They have been evaluated for reportacility Figure 1 indicates that.there is an ever enlarging' gap b'et:.cen PSC's

(

to HRC.

issued and PSC's clcsed (99 issued, 50 closed). As stated elsewhere in this

["

report is is the opinion of the review team that this gap is caused in large part by the burst'of PSC's after litI, lack of established priorities for PSC's and lack of action plans to resolve PSC's.

If priorities and action plans are L

y established, it may help to relieve this situation, but the question arises k

whether or not the Division has the resources to resolve and close this large F

number of outst:nding PSC's in a timely manner. If such an effort is made, it h

r.3y become apparent that there is a funding / manpower problem.

?

5 11.

All persons questiened felt that licensing provides a useful role in administering i

PSC's, ccordinating resciution, and determining reportshility. It was also felt that 1.icensing made a valuable and objective contribution in writing the final E

reports.

No one suggested relocation of this responsibility. There was sorre 5'

suggestion that str:ngar individuals be assigned to follow the PSC's to help s;

0

" ramrod" them through.

It is the opinion of the interviewers that the individuals currently pcrforming this function could produce satisfactory results with d

proper manage::.2nt clarification of the leportance of PSC res.olution.

12.

Some of our vendors probably d'o not have a very good understandin; of their f

obligations undar ICCfR21 and they ray not understand what they are ce=:iting,,_ _

to when they agree to a PO with ICCFR21 requirements in it.

L, RECC::E" CATIONS' ~. _C_ _ __.

The follcwing are the recom2ndations of the revicv team.

Note thit this list is l

steply a tabulatien of the reco r.endations and the ordar in which they appear is l'

Jnot c: ant to reflect relative priorities.

?

, 1.

Manage:cnt should clarify the importance that should be attached to b.

PSC's relative to other Olvision work.

2.

It is unlikely that all PSC's will be of equal importance. In such a case.

a PSC pricrity system cust be establisheo that defices the prioritj of PSC's

. relative to c:ch other.

This priority system cust be co=:unicated to the Division in a esence tnat has credibility and legitiescy.

Sin:e canacemnt is cocccrr:d aucut the nu:52r of PSC's cutstanding, it is desirable that as a part of this priority-dafining process we establish desclines for resolucion of PSL's and in include folloeup actions, g

..c

{

t e

a m

311 1 7' 8 li D 15 4 ~.1 6 2

...a--

. ~..,.:; :

w -. _...._ -

/---.....

. ~ - -.

.._m,m..

a _ -..

C umL

~.;

.s. u D.H. P.oy E.V. C Carli 1.'anatt cnt Review of PSC's.

Decceber 4.19M y

3.

A cethod of tracking outstanding PSC's and outstanding actions related to (i

PSC's c.sst be develo,eed. This cathod will pecbably consist in whole or in part of the Follow-tJp Action Plans (FAP) for PSC's issued under the cew f

1lhatever procedure, but the cechanical details have not yet been worked out.

0.

method is devised, it should result in a concise high visibility report that' makes clear to managerant these PSC's that still have cutstanding actions and f.

Manasccent can then determine the need to bring core attention g

the reasons.

U or resources to bear en the situaticn.

('

Since it is not possible to stata with certainty which cutstanding follcw-up 4.

actions remain ince=plete on closed-out PSC's, a review of these PSC's should Tj-be performed and the rc=sining acticns tabulated in the report suggested in "3" above. There is no other uay that could be found that providas assurancer f

that the necessary work was cc=pleted.

c Originators of PSC's should be involved in the resolutten of the PSC. originators

'5.

should concur that their concern is resolved before the PSC is cicsed.

~

N E

A training program should be conducted to eliminate as many as possible of the 2.

6.

misunderstandings described under "FlicIf.GS". Because of the cceplexity and g.

importance of this item, details of suggested coverage have been suggested to q;

Procedures Training. Personnel.

The front-end PSC =cetings should bc ore fen.alli structured with the 7.

h licensing enginece acting as chairman of the recting. An ag:nda should E

be prepared and the cognizant technical group should put en a forr.31 r

presentation. d ssignments with necd dates should be determined and publish

~

\\

w Auw up. t The Ma'nacer of the Engineering C?partment should m.cnitor the funding situstion

~

8.

to ensure that the recently'establisi.ed funding cgreements are in fact wcrking..

During rout'ine CA visits to venders. QA should investigate the level of 9.

understanding of the vendors relative to thefe cbligations under ICCFR2!

and detennine whether or not recedial action is required.

i.,

6

\\,

E.V. ;;;Carli EVD:cbh L

cc: J.C. Caddens R.E. Kosiba N

J.H. Mac:lillan

(

B.D. Nelson i.-

r h

..e r

311'1 7' 8 ' E D 1 5 _4 '-l6. r.

I 1

.c

1

-.f 1.

. 4 o

1.. !

.- l.

f t:<

w a

I*

c, 7

vs,

.~

..(.

i l

9 100

)

t 100 j;

n l, r,",

90 I

Y

,l.

,I ss t

r.

!2 80 j

u t

l 1

~*

i

.i e4

-70 i ((

3

.i. '.

i&

60

[.

)

-l PSC CunlLATIVE TOTAL-t r3 l

(1977-1979) t i

TOTAL.

30 SC CLOSED d

(1977-1979)

& PSC IN.

1979 20 PSC's IN 1978 10

,a.

U

'/\\.

w,.......,.NTil s

PSC's PER MO

'.'s i

C.

N,- M S,-

)

i

'u"'n

~ ~ ~

~ ^ ' -

JF H AH J J A S 0N D J F H A H J J A 5 0 N O J F M A H J J A S 0 ft -

t V';

1977 1978 1979 YEAR /MONTil O

JJfyRQ (m),

't 7

y w

g arr",=yaq-y

' tu

'n*

%"' 77 P T 1

.]

'I

~3

'.'m b [ #.. ' 7 I'

l a

g

i. !!

i.,'

I r

t

s s'

i-ii

!~ 1l; r

l' I!

a i

W

_O s

D 4

I

'I H

!=CIIC1 1977 1978 197q a

l H

.[

l'LAflT' OESIGil

_,[.

aj

.._a i

.I ig C'itTROLS & IflSTRUMENTATION 1

3 J,

J

.i (D F'UID NID 11ECil. SYSTEMS.

Q 3

3

(%

r c;."P0nErlT EUGINEERING a

.9,1, LICEllSillG

. fuel EXG!!iEERING

]

{

g Ii

/

TECilillCAL SIAFF s

' >. ~

l i

l lit 000CT DEVELOP > LENT j

iII:LO Ef4GR. '& SERVICES d

a*

i t

-a

'I

' i:iAlf!!ilG SERVICES a

e

.'.iER'tICE IllSPECTIO.1 a

ff.!

i

'ALITY ASSUPAitCE u

a I

I1RCHASli;G i

g f JECT tlAtlACEMEriT

]

- i j.

2 4'('8 10 2 '4 6 8 10 2 4 6 8 10 12 14 16 18 20 f

g NUMBER OF PSC'S ISSUED (AS OF NOVEMBER 21,1979) s (D

(' W'. 'j e

1 FICURE 2 l

~

}

IOo i

.fnl t

i e

?

e

i,,,,_,_

1.,

.s.

... u... - 9., ;

'l~:.;-

.;=. '

- ?=';. i.:..~, :--.

. w.

~

13 h

9 1.2 3

-u.

I1 84a..M 10 a-e.a o

VO J

,C >=

s 46 %

W ao 44 7

o.M 3

6 5

4 7

1

. 1 2 3 4 5 6 7 8 9 23 AGE OF OUTSTA: Cit;G PSC (liC:ITE)

~~

g 10

'9

~o 8

r e

3 7

.r,--

.M

=

M*

5

a. o

>=

4 o

ap %

• O 3

,o,

v-2 I

~

p 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 'i6.

AGE 0F PSC AT Ct.05URE (:r/iTHS)'

I'.

l r

311 I.7:'845 D 15 4 41 6.. ' 6' c-w

_~

.l

_[

A - =..

e

. = *

,.ne-

1

,e_~...--...-- - - -.... - - - - - - - - - -. - - - - - - -

- * ~'

n

=...

k

)*

4 r

.. - - - -.. o, i

T:Bl.E i Catcsory of PSC !ssued

'1977 1973 1979 Total I

Analytical Probic:s 7

6

~40 53 Hard are."reblems 16 8

17 41 Plant Procedure Preblems 3

2 0

5 ir t

lL

(

-..:.~...... - --..

v E

y r -

4 u

. 1

~

/

td l-a.

I l

311

1..7 ' 8 ' 6 D 15 l6 l._6 ;1 2~~

I 1

~._

4-^

_m

,m--

w

e-

.~ -

0 O

Ph C,u,

-s

-O f,-

.t

c e -a kr*

'.7'.

. =...

l a

t..,

• u or.

J

'y. z X.

L. '.

g-g.

p.

Y r

O

?. -

n.

.L.

g.

= _ -. -

(A.

p

!4 1 s t

S.

~.

4 ei e.oo.. me,

1 6

L 1

311 o.7'8 0 D15 4.1. 6 u:

1 i_.

P@.

,