ML20056A155

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Forwards Updated Response to Address Maint/Surveillance Area of SALP for Period from Jan 1989 - Mar 1990.Overall Plant Performance During Period Acceptable & Found to Be Directed Toward Safe Operation
ML20056A155
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 07/31/1990
From: Cross J
PORTLAND GENERAL ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9008030334
Download: ML20056A155 (5)


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Porthmd W BactricCorigumy James E. Cross Vice President. Nuclear q

July 31, 1990 1

Trojan Nuclear Plant Docket. 50-344

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License NPF-1 U.S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington DC 20555

Dear Sirs:

1989 Nucicar Regulatory Commission (NRC)

Systematic Assessment of Licensee Perform.ince (SALP)

The NRC SALP Board e, valuation of safety performance at the Trojan Plant for the period from January 1, 1989 through March 31, 1990 was provided by your letter dated June 1, 1990.

Overall Plant performance during the porlod was acceptable and found to be directed toward sofo oporation, with improved performance noted in soveral functional arons. Ilowever, performance in the functional area of Maintenance /Survol11ance was evaluated as Category 3.

Our initial responso addressing the Maintenanco/Survo111ance area was provided in a letter dated July 12, 1990. An updated responso is provided in Attachment A.

Sinceroly,

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Attachments c:

Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant 9003030334 900731

/ g, FDR ADOCK 0500 0

121 SW Salmon St Portland, OR 97204 j

503/464-8897

i Trojan Nuclear Plant Document Control Desk j

Docket 50-344 July 31, 1990 i

Licenso NPF-1 Attachment A Page 1 of A MAINTENANCE / SURVEILLANCE RESPONSE Board Recommendation i

Licensco management should continuo to focus on improving the control of Plant work activities.

Specifically, the licensoo should continue to implement the l

Work Control Conter concept, improvo planning and scheduling, and improve the quality of maintenan.o and surveillanco procedures.

The licensoo should also define clear expect *.tions for middle management to the first line supervisor with respect to quality performance and individual responsibilities.

i 1

Portland General Electric Company (PCE) Responso PGE is committed to fully implementing the Work Control Contar concept und is making progress towards that end. We have recently established a centralized planning and Control organization. Wo have hired a now Mangor, Planning and Control, who reported July 30, 1990. The now manager holds a current Senior i

Reactor Operator (SRO) licenso on a Westinghouse four-loop pressurized water reactor (pWR) and is a degreed engineer.

We havo recently completed an independent study of our work control process, both outago and nonoutage, and are revising our action plan to incorporate Lho results of this study. This revision will be comploto by August 31, 1990.

As enumerated below, wo are making incremental improvements in the work control process in parallel with the overall upgrado effort and are establishing performance indicators to determino success rato. To assure teamwork across department boundarios in daily work activities, the following actions have boon taken:

1.

The Plan of the Day (POD) is reviewed and approved daily by not only the Work Control Contor and Duty Cenoral Managor, but also by the work group management responsible for the work activities.

Performance indicators have been established and posted to show Maintenanco Roquests (MRs) l completed versus MRs scheduled, surveillances completed versus l

surveillancos scheduled, and clearances hung versus clearances requestod.

2.

Currently, daily meetings are scheduled at 1 a.m. and at 12 noon to assure problems are identified and tracked to completion. Tho 7 a.m. mooting consists of the Plant staff department representativos and is led by the e

Shift Supervisor. This meeting covers activities and Plant problems from the previous two shif ts which are current concerns or have an impact on the day's upcoming work activities.

The 12 noon meeting is more widely attended and is led by the Planning and Control Department.

This mooting is designed to cover current Plant status, status of problems identified at the 7 a.m. meeting, status of current work activities, and work l

i i

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31, 1990 License NPF-1 Attachment A Page 2 of 4

'I scheduled for the following day. Action items from those meetings are

~ documented and followed to closcout. This meeting schedulo and content i

may vary dependent upon assessment of offectivonoss, Plant status, or scheduled work load.

l I

3.

A planned revision to our work control procedure will incorporate the following philosophy. Work packages for activities on the POD will be i

reviewed by the cognizant work groups the aftornoon prior to the scheduled l

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dato.- The work packages will then bo do11vored to the control room along 4

with the necessary clearances.

The Shift Supervisor on the 11 p.m. -

7 a.m. shift will review and authorizo the work packages, onsure the clearances are hung, and deliver the work packages back to the work groups prior to 7 a.m..

This will allow the work groups to start work immediately upon reporting to work, reduce the work load for the day Shift Supervisor, help minimize safety equipment out of service times, and l

minimize traffic in the control room.

This proposed procedural revision will be added to our Work Control Contor Action Plan by August 31, 1990.

In addition, the Plant Cenoral Manager has provided guidance to tho l

operating crews that requires work to continuo to completion for activities that requiro entry into a Technical Specification action i

statomont of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or less or for which a Special Report would bc required if not completod. Performanco indicators will be established for.

?

safety-related equipment out-of-service Limos by August 31, 1990.

4.

To aid'in proventing safety-related equipment train violations, a j

procedure revision is plenned to require the Work Control Contor to j

instit.uto designated train-related weekly scheduling.

Cross-train scheduling will be thoroughly reviewed and minimized.

This proposed procedural revision will be added to our Work Control conter Action Plan

{

by August 31, 1990.- In addillon, a scheduling system is being developed to integrato surveillances, proventivo'maintenanco tasks, and MRs.

This

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integrated scheduling tool is targeted for completion by November 30, 1990. This will not only help in proventing safety-rolated equipment' train violations but will also aid in minimizing safety-rointed equipment out-of-service times, ovaluating preventivo-to correctivo maintenanco ratios, and assessing manpower requirements.

Performanco indicators established in the area include correctivo maintenanco backlog (total) and corrective maintenance backlog trend by longth of time open. Other indicators will be estaulished to trend proventivo maintenance items

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scheduled versus proventive maintenance items complete, number of

)

proventivo maintenance items overdue, and number of cross-train components scheduled during train-related wooks.

Thoso indicators are planned to be in place by August 31, 1990.

A training program for the Planning and Scheduling personnel is currently being-developod. Tentativo curriculum guidelines are completo.

Implomontation of this training program will be in accordance with our Maintenance' Improvement Plan. This training program is designed to improve implementation of and assure consistency in our work p.anning process and i

.T e

l Trojan Nuclear plant Document Control Desk Docket 50-344 July 31, 1990 Licenso NpF-1 Attachmont A page 4 of 4 proceduros. A computorized trending system for equipment failures becamo oporational in May 1990. With now management direction and a strong focus on priorities, the foundation for further improvement is in place.

The key clomont in our plan to improvo performance in the maintenanco area is the effoetive use of supervisors.

Supervisors are attending Frontline boadership training which teaches communication, loadorship, and supervisory i

skills. The Maintenanco Manager has establishod clear guidanco for supervisory oversight of work in the plant. The establichod goal is for first-line supervisors to spend a minimum of 50 porcent of their timo in the l

field. A performance indicator is being established to track performance with respect to this goal. This indicator will be in place by August 31, 1990.

Management oversight and holding people accountable for performance will improvo the quality of work, reduce mistakes, strengthen procedural complianco, and upgrado work-sito material condition.

In a similar manner, Maletonance Department upper levol supervisors and managers are required to make frequent in-depth observallons of plant activition.

Management expectations have boon defined in the procedural compliance area and people are being hold accountable to comply with thoso expoetations.

In addition, Quality Assuranco surveillancos are being utilized to assure i

compliance with management expectations.

Actions to improve procedural i

compliance includo of fectivo use of the now proceduro specialist assigned to 1

each craft group. prompt resolution of procedural problems by the specialist l

will reinforce requiromonts to stop work in the face of uncertainty.

Tho 3

proceduro specialist will also improve the overall adequacy _of maintenanco l'

work proceduros.

An additional part of the improvouent plan is the development of now procedures for calibration of all Hagan instrument loops l

and plant instruments which provido inputs for reactor trip or Engincored Safety Features actuations.

A dodicated team was established in February 1990 i

to accomplish this task wlth completion expoeted by September 30, 1990.

1 PCE's plan to improve root cause analysis, understanding of technical issuos, and implementation of correction actions is based on managomont attention-and offectivo use of supervisors. The new Maintenanco Equipment Tracking System (METS) providos an additional tool for analyzing equipment failuros. The now proceduro specialists are availabio to assist the craft supervisors in investigating and ovaluating problems.

As established in the Maintenanco Improvement program, the Maintenanco Manager is holding ongoing discussions with supervisors to evaluate plant events and correctivo actions.

As shown by the NRC noted improvement, pCE has established increased management oversight to ensure timely and proper response to NRC concerns.

Improved commitment control and prioritization programs, which are currently being developed, will provido additional improvement in this area. Thoso two programs are scheduled to be in placo by December 1, 1990.

OpC/5301W 1

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Trojan Nuclear plant Document Control Desk Docket 50-344 July 31, 1990 License WpF-1 AttacPment A page 2 of 4 scheduled for the following day.

Action itens from these meetings are documented and followed to closcout. This meeting schedule and content may vary dependent upon assessment of effectiveness, plant status, or scheduled work Joad.

3.

A planned revision to our work control procedure will incorporate the following philosophy. Work nackages for activities on the p0D will be reviewed by the cognizant work groups the afternoon prior to the scheduled date. The work ptekages will then be delivered to the control room along wit). the necessary clearances.

The Shift Supervisor on the 11 p.m. -

7 a.m. shift will review and authorize the work packages, ensure the a'

clearances are hung, and deliver the work packages back to the work groups prior to 7 a.m..

This will allow the work groups to start work immediately upon reporting to work, reduce the work load for the day shift Supervisor, help minimize safety equipment out of service times, and minimize traffic in the control room.

This proposed procedural revision will be added to our Work Control Center Action plan by August 31, 1990.

In addition, the plant General Manager has provided guidance to the operating crews that requires work to continue to completion for activities that require entry into a Technical Specification action statement of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or less or for which a Special Report would be required if not completed.

performance indicators will be established for safety-related equipment out-of-service times by August 31, 1990.

4.

To aid in preventing safety-related equipment train violations, a procedure revision is planned to require the Work Control Centor to instituto designated train-related wookly scheduling. Cross-train scheduling will be thoroughly reviewed and minimized.

This proposed procedural revision will bu added to our Work Control Center Action plan by August 31, 1990.

In addition, a scheduling system is being developed to integrate survelliances, preventivo maintenanco tasks, and MRs. This integrated scheduling tool is targeted for completion by November 30, 1990. This will not only help in preventing safety-colated equipment train violations but will also aid in minimizing safety-related equipment out-of-service times, evaluating preventive to corrective ceintenance ratios, and assossing manpower requitomonts.

performance indicators established in the area includo corrective maintenanco backlog (total) and corrective maintenance backlog trend by length of time open. Other e

indicators will be catablished to trend preventive maintenance Atoma scheduled versus preventive maintenance items complete, number of preventivo maintenanco items overdue, and number of cross-train ecmponents scheduled during train-related wooks. These indicators are planned to be in place by August 31, 1990.

A training program for the Planning and Scheduling personnel is currently being developod. Tentativo curriculum guidelines are complete.

Impicmentation of this training program will be in accordance with oue Maintenanco Improvement plan.

This training program is designed to improve implementation of and assure consistency in our work planning procera und l

1 4

A l

1 Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31, 1990 License NPF-1 Attachment A Page 3 of 4 will include auch areas as parte procurement, safety-related determination, format of work instructions, and uniformity of post-maintenance testing.

Training is tentatively scheduled to begin by January 1, 1991.

In response to a Corrective Action Request (CAR) corrective action and in an effort to upgrade our surveillance program, we are revising our surveillance administrative procedure.

This revision will provide more definitive guidance for organizational responsibility within the surveillance program. The survelliance administrative procedure is currently scheduled to be revised by September 1, 1990.

In addition, by November 1, 1990 we will evaluate a i

long-term program for procedural upgrade of the technical content of surveillance procedures.

PGE recognizes the need for more comprehensive outage planning and has already issued the 1991 Preoutage Milestones. These milestones clearly define the I

outage planning schedule and responsibilities to ensure timely work planning and material availability.

Management oversight and personnel accountability will be utilized to assure these milestones are accomplished.

Trojan's Leadership Team, consisting of the Senior Vice President - Generating Division, the Vice President - Nuclear Division, and the Divlsion General Managers, has selected the Corrective Action Program (which includes event investigation) as one of eight items on the Leadership Team agenda.

PGE's goal for the Corrective Action Program is that it promptly identifies problems, efficiently corrects them, and effectively prevents them from j

recurring. A number of actions have been compinted in support of the goal, several more are planned, and it is recognized that others will be required as necessary adjustments are identified.

The Nuclear Division has recently implemented revised procedures to addresP corrective actions (including event reviews). The revised corrective action procedures are designed to eliminate duplicatian cnd confusion, shorten the processing time for corrective action documents, increase the use of trending, and capture corrective action / event report information in a single data base to enhance trending.

An ongoing self-assessment plan is in place to identify additional areas for improvement in the Corrective Action Program. These include meetings with managers, supervisors, and employees to obtain feedback, biweekly surveillances of the program (this frequency may be adjusted depending on results), and the establishment of a number of performance indicators to assist in determining if measurable expectations are met.

The Maintenance Department has been making steady progress in implementing the Maintenance Improvement Plan. One result has been increased staffing at all levels of management and supervision. Additional personnel are in place to improve preventive maintenance and surveillance activities.

Each craft group now has a designated position for a specialist to improve the quality of j

,z l

e Trojan Nuclear plant Document. Control Desk Docket 50-344 July 31, 1990 License NpF-1 Attachment A page 4 of 4 procedures. A computerized trending system for equipment failures became operational in May 1990. With new management direction and a strong focus on t

priorities, the foundation for further improvement is in place.

I The key element in our plan to improve performance in the maintei. nce area is the effective use of supervisors.

Supervisors are attending Frontline i

Leadership training which teaches communication, leadership, and supervisory skills.

The Maintenance Manager has established clear guidance for supervisory oversight of work in the plant. Th9 established goal is for first-line supervisors to spend a minimum of 50 percent of their time in the field. A performance indicator is being established to track performance with respect to this goal. This indicator will be in place by August 31, 1990.

Management oversight and holding people accountable for performance will improve the qualit.y of work, reduce mistakes, strengthen procedural compliance, and upgrade work-site material condition.

In a similar manner.

Maintenance ;epartment upper icvel supervisors and managers are required to make frequent in-depth observations of plant activities.

Management expectations have been defined in the procedural compliance area and people are being held accountable to comply with theso expectations.

In addition, Quality Assurance surveillances are being utilized to assure compliance with management expectations.

Actions to improve procedural compilence include effective use of the new procedure specialist assigned to each craft group.

prompt resolution of procedural problems by the specialist will reinforce requirements to stop w)rk in the face of uncertainty.

The procedure specialist will also improve the overall adequacy of maintenance work procedures. An additional part of the improvement plan is the development of new procedures for calibration of all Hagan instrument loops and Plant instruments which provide inputs for reactor trip or Enginecred Safety Features actuations. A dedicated team was established in February 1990 to accomplish this task with completion expected by September 30, 1990, t

PCE's plan to improve root cause analysis, understanding of technical issues, and implementation of correction actions is based on management attention and effective use of supervisors.

The new Maintenance Equipment Tracking System (METS) provides an additional tool for analyzing equipment failures.

The new procedure specialists are available to assist the craf t supervisors in investigating and evaluating problems.

As established in the Maintenance Improvement program, the Maintenance Manager is holding ongoing discussions with supervisors to evaluate plant events and corrective actions.

As shown by the NRC noted improvement., pCE has established increased management oversight to ensure timely and proper response to NRC concerns.

Improved commitment control and prioritization programs, which are currently being developed, will provide additional improvement in this area.

These two programs are scheduled to be in place by December 1, 1990.

DPC/5301W