ML20045C439
| ML20045C439 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek |
| Issue date: | 06/16/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| EA-93-129, NUDOCS 9306230118 | |
| Download: ML20045C439 (42) | |
Text
9 pRCfCo UNITED STATES 8
NUCLEAR REGULATORY COMMISSION E'
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o REGloN IV 611 RYAN PLAZA DRIVE, SUITE 400 o
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AR LINGToN, TEXAS 76011-8064 JUN I 61993 Docket: 50-482 License: NPF-42 EA 93-129 Wolf Creek Nuclear Operating Corporation ATTN:
Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839
SUBJECT:
ENFORCEMENT CONFERENCE This refers to the enforcement conference conducted on June 9, 1993, at the Region IV office in Arlington, Texas, concerning activities authorized by NRC License NPF 42 for the Wolf Creek Generating Station. The enforcement conference was attended by those on the attached Attendance List.
The subjects discussed at this enforcement conference are described in the enclosed Meeting Summary.
You will be advised by separate correspondence of the results of our deliberations concerning the number and characterization of the apparent violations identified in the inspection report.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room.
Should you have any questions concerning this matter, we will be pleased to discuss them with you.
Sincerely, tJ f.BillBeach, Director Division of Reactor Projects
Enclosure:
Meeting Summary w/ attachments cc w/ enclosure:
Wolf Creek Nuclear Operating Corp.
ATTN: Otto Maynard, Vice President Plant Operations
.P.O. Box 411 Burlington, Kansas 66839 9306230118 930616 DR ADOCK 05000482 PDR
s Wolf Creek Nuclear Operating' Corporation Shaw, Pittman, Potts & Trowbridge ATTN: Jay Silberg, Esq.
2300 N Street, NW Washington, D.C.
20037 Public Service Commission ATTN:
C. John Renken Policy & Federal Department P.O. Box 360 Jefferson City, Missocri 65102 U.S. Nuclear Regulatory Commission ATTN:
Regional Administrator, Region III
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799 Roosevelt Road Glen Ellyn, Illinois 60137 t
Wolf Creek Nuclear Operating Corp.
ATTN:
Kevin J. Moles l
Manager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 Kansas Corporation Commission ATTN:
Robert Elliot, Chief Engineer Utilities Division 1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027 0ffice of the Governor State of Kansas Topeka, Kansas 66612 Attorney General 1st Floor - The Statehouse Topeka,. Kansas 66612 Chairman, Coffey. County Commission Coffey County Courthouse Burlington, Kansas 66839-1798 Kansas Department of Health a
and Environment Bureau of Air Quality & Radiation Control ATTN: Gerald Allen, Public Health Physicist Division of Environment.
Forbes Field Building 321-Topeka, Kansas 66620 y
Wolf Creek Nuclear Operating Corporation Kansas Department of Health ano Environment ATTN: Robert Eye, General Counsel LSOB, 9th Floor 900 SW Jackson Topeka, Kansas 66612 i
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J. L. Milhoan Resident Inspector Section Chief (DRP/A)
DRP DRSS-FIPS Section Chief (RIII, DRP/3C)
RIV File SRI, Callaway, RIII MIS System Lisa Shea, RM/ALF, MS: MNBB 4503 Project Engineer (DRP/A)
Section Chief (DRP/TSS)
G. F. Sanborn, E0 J. Lieberman, OE, MS: 7-H-5 W. L. Brown
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220012
MEETING
SUMMARY
Licensee:-
Wolf Creek Nuclear Operating Corporation (WCNOC)
Facility:
Wolf Creek Generating Stations License No.:
NPF-42 Docket No.:
50-482
Subject:
Enforcement Conference 50-482/93-16 On June 9, 1993, representatives of WCNOC met with Region IV personnel in Arlington, Texas, to discuss the apparent violations identified in NRC Inspection Report 50-482/93-16. The conference was held at the request of Region IV.
The licensee presented a summary of the causes for the apparent violations and-their corrective actions.
The attendance list and licensee presentation are attachments to this summary.
Attachtnents:
1.
Attendance List 2.
Licensee Presentation (NRC distribution only) i
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ATTENDANCE LIST Attendance at the enforcement conference between Wolf Creek Nuclear Operating Corporation and NRC on June 9,'1993, at the Region IV office in Arlington, Texas:
WCNOC B. Withers, President and Chief Executive Officer
- 0. Maynard, Vice President, Plant Operations C. Parry, Director, Performance Enhancement K. Moles, Manager, Regulatory Services R. Smith, Manager, Corporate Communications J. Weeks, Manager, Operations T. Riley, Supervisor. Regulatory Compliance S. Austin, Shift Supervisor D. Dees, Shift Supervisor NRC J. Milhoan, Regional Administrator A. Beach, Director, Division of Reactor Projects (DRP)
I. Barnes, Acting Director, Division of Reactor Safety G. Sanborn, Enforcement Officer W. Brown,. Regional Counsel W. Johnson, Chief, DRP/A M. Satorius, Project Engineer, DRP/A G. Pick, Senior Resident Inspector, DRP/A B. Packley, Project Manager, Office of Nuclear Reactor Regulation S. Campbell, Resident Inspector, DRP/D y
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s WOLF CREEK NUCLEAR OPERATING CORPORATION I
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Enforcement conference concerning six apparent violations identified in inspection Report 482/93-16 (Special inspection of WCNOC's Entry into Mode 3 " Hot Standby" with Motor Driven Auxiliary Feedwater Pumps in Pull-To-Lock)
Date:
June 9,1993 Time:
1:00 p.m.
Location:
NRC Region IV Offices Arlington, Texas TP-1
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AGENDA L
NRC Introduction /Oper.ing Remarks NRC Region IV Personnel I
WCNOC Introduction / Opening Remarks Bart Withers / Otto Maynard
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4 Discussion of Apparent Violations and Jim Weeks inspection Report 482/93-16 Findings i
Performance Assesment of Operations, Otto Maynard Planning and Scheduling, and Summary l
of WCNOC's Positions WCNOC Closing Remarks Otto Maynard/Bart Withers t
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OVERVIEW OF WCNOC'S PRESENTATION ON SPECIFIC APPARENT VIOLATIONS
. Auxiliary Feedwater System
- System Description
- Safety Significance of Apparent Violations L
. Sequence of Events
. Categorization of Apparent Violations
. Investigation and Results - General Overview l
. Results achieved to date
. ~ Planned Long-Term Oversight Activities TP-4
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AUXILIARY FEEDWATER SYSTEM L
Auxiliary Feedwater System (AFW) provides:
Safety grade water supply to steam generators for removal of decay heat following transient or accidents in which main feedwcter is isolated or lost AFW system ensures:
Adequate makeup to steam generators to prevent reactor coolant system pressure from increasing and causing release of coolant through pressurizer safety or relief valves AFW consists of:
Two 100 percent capacity.. motor-driven pumps One 200 percent capacity steam turbine-driven pump Pumps take suction from Condensate Storage Tank (CST) with back-up supply from Essential Service Water System TP - -.
I AUXILIARY FEEDWATER SYSTEM The following will cause automatic startup of motor-driven pumps:
l 2/4 low-low SIG level signals in any one steam generator 1
Trip of both main feedwater pumps Safeguards sequence signal (initiated by safety injection signal or loss-of offsite-power)
Anticipated Transient Without Scram (ATWS) Mitigating System Actuation Circuitry (AMSAC)
The following will cause automatic startup of turbine-driven pump:
2/4 low-low SIG level signals in any two steam generators Class 1E bus loss of voltage AMSAC TP-6 s
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SAFETY SIGNIFICANCE i
t-Surveillance test procedure STS AL-003 " Auxiliary Feedwater System Valve Status Verification" had been performed ensuring proper Auxiliary Feedwater valve alignment Turbine-driven pump was functional at existing 350 degrees, and l
would have auto-started to provide in excess of 600 gpm flow Motor-driven pumps available for manual actuation Established Procedures would have directed Operators to verify auxiliary feedwater flow early in any analyzed event Plant was coming out of an outage and there was 2.2 MWTh decay heat from core t
TP-8'
SAFETY SIGNIFICANCE l
l With 14 MWTh pump heat and constant 200 gpm steaming rate to maintain-RCS at 450 degrees it would have taken approximately:
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1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to SIG low-low alarm 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to dry l
i With one reactor coolant pump running:
l 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to SIG low-low alarm 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> to dry RCS could have been.depressurized and placed back on Residual Heat Removal System within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Safety Significance of this event is low i
1 SEQUENCE OF EVENTS L
Mode Ascension following extended refueling outage i
' Day shift (0700-1900) May 8,1993, Mode 4 to Mode 3 shift goal Numerous significant work activities _ ongoing Shift Supervisor signed-off GEN 00-002, step 5.30.1 (Surveillance l
Mode' Change Checklist)
Supervising Operator signed-off GEN 00-002 Step 5.31, Mode 4 to Mode 3 CKL, thinking he was signing off Surveillance Mode Change' Checklist Mode 4 to Mode 3 transition-made at 1838 i
Shift turnover-occurred at 1900 TP-10
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SEQUENCE OF EVENTS Night shift May 8,1993 Control Room work activity remained high Day shift May 9,1993 At 0753, Operators recognize error (motor-driven pump handswitches-
.in Pull-to-Lock)
Handswitches immediately returned to NORMAL Reportability Evaluation Request initiated Turbine-driven Auxiliary.Feedwater Pump taken out of service at 1350
. Review of Technical Specifications would have identified problem before turbine-driven pump was taken out of service
.TP-ll'
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CATEGORIZATION OF APPARENT VIOLATIONS
. Violation of Section 3 " Limiting Conditions for-Operation" of Wolf Creek Generating Station's Technical Specifications l
- Failure to have both Motor Driven Auxiliary Feedwater Pumps Operable l
Prior to Making Mode 4 " Hot Shutdown" to Mode 3 " Hot Standby" transition -Technical Specification 3.0.4 (9316-01)
- Failure to take actions required by Technical Specifications with both Motor Driven Auxiliary Feedwater Pumps inoperable in Mode 3 -
Technical Specification 3.7.1.2 (9316-02) l b
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i CATEGORIZATION OF APPARENT VIOLATIONS
. Violation of Section 6 " Administrative Controls" of-Wolf Creek Generating Station's Technical Specifications
- Failure to follow procedures in accordance with Technical l
Specification requirements - GEN 00-002 (9316-03)
- Failure to adequately perform procedures in accordance with requirements of Technical Specifications - ADM 02-010 and ADM 02-040 (9316-04 and 9316-05)
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- Failure to adequately perform an administrative procedure in accordance with Technical Specifications - ADM 02-105 (9316-06)
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WCNOC INVESTIGATION AND RESULTS - GENERAL 3
OVERVIEW Topical areas researched:
Why was GEN 00-002-1B (Mode 4 to Mode 3 Checklist) missed?
Why didn't turnover. process identify that Auxiliary Feedwater handswitches were in pull-to-lock?
Why was Mode change made at shift turnover time and was there~ pressure to make Mode change?
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APPARENT VIOLATION.9316-03 Failure to perform GEN 00-002-1B (Mode 4 to Mode 3 CKL) in accordance with.
Technical Specification requirement 6.8.1.a Why was GEN 00-002-1B (Mode 4 to Mode 3 Checklist) missed?
- Direct Root Cause Supervising Operator failed to properly complete Step 5.31 in GEN 00-002002 Underlyina Root Cause Operating Crews failed to adequately. control plant work activities in Control Room before and during transition from Mode 4 to-Mode 3 TP-15'
t APPARENT VIOLATION 9316-03 Failure to ~ perform GEN 00-002-1B (Mode 4 to Mode 3 CKL) in accordance with Technical Specification requirement 6.8.1.a 1
- Contributina Factors Operating Crews' failed to thoroughly assess Mode 3 restraints and related equipment status prior to transitioning Existence of two checklists with similar titles caused completion of " Mode 4 To Mode 3 CKL" to be missed Shift Supervisor's signing Step 5.30.1 of GEN 00-002 Operators desire-to make Mode change during their shift
- Corrective Actions Taken Manager Operations, May 11,1993, memo to all Licensed Operators addressing taking necessary. time to do job right and focusing on Technical Specification requirements when Mode changes are made TP-16
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APPARENT VIOLATION 9316-03 Failure to perform GEN 00-002-1B (Mode 4 to Mode 3 CKL) in accordance with Technical Specification requirement 6.8.1.a
.Vice President Plant Operations, May 13,1993, memo to all site personnel on his expectations and support of Shift Supervisors controlling level of work activity I
Manager Operations, May 24,1993, memo to Shift Supervisors and c
interviews with Shift Supervisors and Supervising Operators reiterated importance of controlling the level of work activity.
i Manager Operations, June 4,1993, memo to all Licensed Operators
. stating the Supervising Operator should be only person signing steps in GENS i
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APPARENT VIOLATION 9316-03 Failure to perform GEN 00-002-1B (Mode 4 to Mode 3 CKL) in accordance with Technical Specification requirement 6.8.1.a Manager Operations or Supervisor Operations to review 1
Equipment Out Of Service Log, Temporary Modifications Log, Clearance Order Log, Work Request Log, Locked Valve Log and l
Surveillance Mode Change Checklist (incorporated into GEN 00-003)
Manager Operations reviewed Technical Specification requirements of Mode 2 and 1 with crew before transition from Mo'de 3 to Mode 2 during last startup Operations has re-evaluated use of pull-to-lock and will use for plant equipment or personnel safety-through a clearance order, or as directed by a procedure (Standing Order 24/8)
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APPARENT VIOLATION 9316-03 Failure to perform GEN 00-002-1B (Mode 4 to Mode 3 CKL) in accordance with Technical Specification requirement 6.8.1.a L
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- Planned Corrective Actions GEN 00-002 (Mode 5 to Mode 3) will be revised to:
Eliminate confusion between similarly named checklists Move performance steps from checklists to body of procedure -
June 30,1993 All General Operating Procedures will be reviewed for similar problems - September 30,1993 or before needed Applicable Technical Specifications which become effective
-at Mode changes will be itemized and Shift Supervisor will discuss them with Operating Crew before a Mode change is made -
September 30,1993 or before needed Responsible individual to make presentation to peens and Management regarding error and how STAR (Stop, Think, Act, Review) could. have prevented this problem TP-19
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APPARENT VIOLATION 9316-01 Mo.de change made without all requisite equipment operable as required by Technical Specification 3.0.4
- Direct Root Cause Failure to correctly perform step 5.31 of GEN 00-002 a
- Underlyina Root Cause.
Same as Apparent Violation 9316-03
- Contributina Factors Same as Apparent Violation 9316-03
- Corrective Actions Taken Same as ApparentViolation 9316-03 TP-20
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APPARENT VIOLATION 9316-04 and 9316-05 Failure to adequately perform procedures in accordance with the l
Technical Specification 6.8.1.a i
- Why didn't the tumover process identify that Auxiliary Feedwater handswitches were in pull-to-lock?
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- Direct Root Cause t
f Operators failed to properly allocate sufficient time to review
. Technical Specifications and safety-related equipment status l
- Underlyina Root Cause Operating Crews failed to adequately control plant work activities. in j
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Control Room before and during transition from Mode 4 to Mode 3 TP-21
APPARENT VIOLATION 9316-04 and 9316-05 4
Failure to adequately perform procedures in accordance with the Technical Specification 6.8.1.a l
- Contributina Factors o
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- Operators realized that handswitches were in pull-to-lock during
-turnovers and had been in this position for several weeks Operatons failed to recognize the need for operable versus available l
Operating Crews should'have taken time required to thoroughly -
assess Mode 3 restraints and related equipment status
-Inadequate shift turnover and board walkdowns allowed problem to continue for 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> i
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l APPARENT VIOLATION 9316-04 and 9316-05 Failure to adequately perform procedures in accordance with the Technical Specification 6.8.1.a
- Corrective Actions Taken Manager Operations memo to all Licensed Operators addressing the following:
Expectations regarding turnovers and controlling the number of activities allowed to proceed at one time Take necessary time to do job right; stop activity which creates i
doubt Do thorough turnovers L
Prioritize work and assure concerns with. safety related equipment are promptly dealt with Ensure knowledge of plant requirements for the Mode plant is in before doing board walkdowns L
The Vice President Plant Operations issued memos addressing:
Restricting activities which distract from Control Room. turnovers Requirement to-maintain Control Room professionalism-TP-23 i
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APPARENT VIOLATION 9316-02 Failure to take actions required by Technical Specification 3.7.1.2.b with Motor Driven Auxiliary Feedwater Pumps inoperable in Mode 3 l}
- Direct Root Cause Failure to-adequately perform ADM.02-010 and ADM 02-040 l
- Underlyina Root Cause l
Same as Violation 9316-04 and 9316-05
- Contributina Factors Same as Violation 9316-04 and 9316-05
- Corrective Actions Same asViolation 9316-04 and 9316-05 r
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TP i l
Why was Mode change made right at turnover time and was there pressure to make Mode change?
- Findinas Goal of shift was to make Mode change.
Realized next crew would have to duplicate their work if Mode change l
was not done 1
Crew felt ready for Mode change - GEN complete up to step 5.31
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Operating Crews failed to take time required to thoroughly assess
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Mode 3 restraints and related equipment status prior to transitioning Management inquiry regarding status of Mode change t
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Why was Mode change made right at turnover time and
.was there pressure to make Mode change?
- Corrective Actions Taken:
Manager Operations issued a memo to all Operations Personnel delineating his expectations in regards to turnovers and controlling number of activities allowed to proceed at one time Vice President Plant Operations issued memos addressing:
Communications from various. Managers with Control Room must be carefully worded, avoid unrealistic expectations Personnel performance expectations l
- Corrective Actions Planned:
Responsible individual to make presentation to peers and Management regarding error-and how STAR (Stop, Think, Act, Review) could have prevented this problem 4
4 TP-26
APPARENT VIOLATION 9316-06 Failure to adequately perform administrative procedure in accordance with the Technical Specification 6.8.1.a
- Intended purpose of the Equipment Out of Service Log (EOL) is to AID in tracking inoperable equipment required by Technical Specifications
- At power, only a few pages used; very effective tool
- During an outage, can become cluttered and ineffective
- No entry was necessary as GEN 00-002 ensures all surveillances current and handswitches are in Normal before the Mode change l
- Changes made to the EOL procedure to avoid ambiguity in its requirements
- WCNOC's Position
.WCNOC does not consider this to be a violation TP-27
RESULTS ACHIEVED TO DATE l
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. Turnovers
- Quiet time established and is being used
- Effectiveness and thoroughness are improving i
Conduct of Operations
- Manager Operation's questioning of Operations personnel has raised awareness of safety-related equipment status, recent plant events-1 i
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PLANNED LONG-TERM OVERSIGHT ACTIVITIES At request of Manager Operations, Quality Assurance will perform a special evaluation (Surveillance) of Operating Crew turnovers and board walkdowns -
July 1993 Quality Assurance performs routine evaluations of Control Room Activities -
As part of these routine evaluations adherence to corrective actions will be verified - evaluations will be ongoing for the next 6 months Manager Operations will perform periodic observations of Control Room Operator activities and tumovers to assure effective corrective actions -
ongoing Operations personnel are being trained during this cycle on " Shift Relief and Tumover," (ADM 02-010) - completion mid-July 1993 TP-29
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Performance Assessment Of Operations
Background:
Request for Assesment of Operations Requestor:
Otto Maynard - Vice President Plant Operations Purpose of Assesment:
- Independent Assesment of Operations to identify areas for improvement and make recommendations as appropriate
- Provide input to the Mid Term SALP t
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Performance Assessment Of Operations i
Scope:
A.
Operations Management Effectiveness l
B.
Training and Preparations for Outage Evolutions C.
. Cultural issues (i.e.. PIR usage and acceptance, interfacing skills and teamwork with outside groups)
D.
On-Shift Organizational Structure (Benchmark with other plants, qualification breakdown, professionalism and demeanor)
E.
Frequency, Type and Trends of Errors within Operations (number of LERsNiolations, benchmarking with other plants)
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_ _ _ = _ - _ - _ _ _ _
L Performance Assessment Of Operations Team Members:-
Chairman R.Hagan Team Leader of Scope A & C C. Parry Team Leader of Scope B UE Personnel Team Leader of Scope D R. Flannigan Team Leader of-Scope E M. Lindsay Members of Team A B. Compton, P. Rice, R. Rideau l
Members of Team B L. Stevens, UE and CE Personnel i
Members of Team C P. Rice, R. Rideau Members of Team D UE and ~CE Personnel Members of Team E T. Riley, UE Personnel e
Methodoloav:.
Conduct per KGP-1205, Rev.0, "Self Assesment Process" t
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r Performance Assessment Of Operations-1 Results:
Findings can be documented into four categories per KGP-1205
- Strengths - Exceeds performance requirements
- Weakness - PIR to' be. initiated
- Observations - Meets standards but is neither a strength or weakness
- Recommendations - Not a PIR but needs Management Evaluation Documentation:
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- Plan development to be finalized, as outlined for members using Scope as the guide i
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- Final report to be fonnarded to P/CEO, Chairman NSRC, and others per the L
requirements of KGP-1205, from Chairman of-the Assesment Group TP-33
Performance Assessment Of Operations Schedule:
June 7-11 Detailed Scope, Collect Information, Form Teams June 14-Teams Perform Work and Research July 2 July 5-10 Write Preliminary Results I
l July.10-18 Week Off l
July 19-23 Review and Finalize Results and Findings l
July 26-30 Discuss and Get Feedback From OPS August 2-6 Report to NSRC,-President, V P Plant Operations l
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t-Planning and Scheduling Disciplined Approach Initiated Following Refuel VI
. 13. week-rolling schedule i
. Morning meetings for " Emergent Work"
. Work prioritized with Operations involvement
- Benefits 4
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. Minimize schedule changes l
. Reduce burden of Shift Supervisors
. Allows better planning for Operations and other work groups 4
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1 Summary of WCNOC's Positions Apparent Self Identification Timely and Effective Safety 1-Violations Corrective Actions Significance 9316-01 YES YES LOW (T/S 3.0.4)-
Low decay heat 9316-02 YES YES LOW (T/S3.7.1.2)
Low decay heat 9316 43 YES YES LOW
- l (GEN 00-002)
Cause of event 9316-04 YES YES LOW
- l (Turnover / Shift relief)
Turnovers done l
l-9316-05 YES YES LOW
- l (Personnel Conduct)
Walkdowns done-9316-06 N/A-N/A NIA (EOL) l
- Although the safety significance for this particular circumstance was low the same mistake made -
under different plant conditions.could result in a more safety significant condition.
l TP-36
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