ML20070D905

Discusses Interim Activities for Procedures Upgrade Program & Forwards Summary of Program

ML20070D905
Person / Time
Site:	River Bend
Issue date:	07/06/1994
From:	James Fisicaro ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RBG-40699, NUDOCS 9407130103
Download: ML20070D905 (4)

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Po. Box 220 St Franc) syme, LA 70775 i

July 6,1994 U.S. Nuclear Regulatory Commission Document Control Desk Washington D.C. 20555

Subject:

Interim Activities for the Procedures Upgrade Program

Reference:

RBG-40630 File Nos.:

Gl.5, G4.13, G9.5 RBG-40699 i

Gentlemen:

I Please find attached a summary of Entergy Operations, Inc's near term activities to improve River Bend Station procedures. These activities are being implemented in accordance with our Long Term Performance Improvement Plan and are intended to j

provide an immediate focus on procedure improvements. This information is submitted as committed in the referenced River Bend Station letter concerning Inspection Report 94-06.

Entergy is aware of the problems associated with River Bend Station (RBS) procedures and has implemented the necessary corrective actions. During the merger related assessments of RBS and the development of the Near Term Performance Improvement Plan, Entergy identified problems with the adequacy of station procedures and implemented immediate corrective actions. These corrective actions consisted of emphasizing management expectations to site personnel for strict adherence to procedures and the significance of identifying and correcting procedural problems.

Other corrective actions were implemented including adding resources to address the backlog of procedure changes, revising the change process, developing a standard procedure writers guide to ensure consistency in procedures and holding supervision accountable for identifying and resolving procedure problems.

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Int'erim Activities for the Procedures Upgrade Program July 6,1994 RBG-40699 Page 2 of 2 In parallel with the immediate corrective actions, a procedure improvement plan was established as part of the RBS Long Tenn Perfonnance Improvement Plan (LTPIP).

This plan implements comprehensive initiatives to solve the root cause of the issues and -

establish permanent improvements. Inherent within the LTPIP is a check and adjust.

philosophy that trends plan perfonnance and allows en.phasis to be placed where -

needed. As a result of this check and adjust philosophy, station management established interim actions to provide an immediate focus on procedure improvements and provide a foundation to accelerate implementation of the long term corrective

- 1 actions. These interim actions are described in the attachment and will be discussed at our meeting scheduled for July 8,1994.

Should you have any questions, please contact Mr. O. P. Bulich at (504) 336-6251.

Sincerely, Mh ames J.

1sicaro Director -' Nuclear Safety RMM

--enclosures cc:

U.S. NRC Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011

. NRC Senior Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 t

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i PROCEDURE UPGRADE PROGIbut INTERIM MEASURES

SUMMARY

The River Bend Station Procedures Upgrade Project (PUP) Plan is being developed to implement Long Term Perfonnance Improvement Plan (LTPIP) procedure improvement initiatives. The PUP is a long tenn plan that reflects the procedural goals and commitments identified in the LTPIP and provides additional details and specinc program requirements penaining to improvement of River Bend Station procedures.

i To increase focus on procedure improvements, interim actions have been developed to provide near tenn procedure improvements. The objectives of thece interim actions are to improve human perfonnance in the near term and ensure continued safe operation by focusing on immediate improvement of procedures governing work activities. In 1

addition, these activities will provide a foundation from which to begin PUP implementation. Key elements of these interim actions include:

1.

Organization The " Interim Procedures Group" consisting of appropriate technical specialists and an administrative support staff has been established under the direction of the Plant Projects and Support Department. This interim group incorporated the Procedures Group that was under the direction of the Administrative Services Depadment. Station technical personnel are being evaluated to augment the new group. In addition, on-site facilities are being modified to provide a centralized procedures upgrade group location.

2.

Establish Priorities River Bend Station is identifying those procedures which require near-tenn revision based on implementation history and safety factors. The specific factors considered are:

a.

Impact on nuclear safety.

b.

Impact on personnel safety.

c.

Implementation of regulatory requirements.

d.

Frequency of use.

A group consisting of five technical specialists has verified and validated those procedures.dentified as needing immediate attention. The intent of this review was to reduce the burden of procedure related problems by providing immediate improvement to high priority procedures. The procedures group will begin revising procedures based on this assessment by August 1,1994.

3.'

Streamline Procedure Chance Process.

To ensure that resolution of technical issues remains the focus of this effort, methodology is being developed to separate technical issues affecting the quality of procedures from minor editorial changes. Editorial changes will be clearly defined; those changes that are strictly editorial in nature will be addressed through a simplified process. Editorial changes will still include a change review similar to changes impacting technical quality but will not require immediate procedure revision as perfonned for technical changes. These change process improvements will be implemented by August 1,1994.

4.

Implement Procedure-Related Database Improvements.

There were several site databases that contained different types of procedural information. This infonnation was centralized into a single location within the River Bend Station Nuclear Operations Records Management System (NORMS)

Database which previously included procedure change information. This database now includes the following additional infonnation 1) Quality Class of procedures,2) frequency of perfonnance,3) related condition reports, and 4) procedure related regulatory commitments. This added infonnation, along with the existing procedure change infonnation, provides information necessary to continually prioritize and mvise procedun:s.

5.

Develop Nuclear Management Manual To comply with standard Entergy Operations practice, new River Bend Station

" Policy Statements and Directives" (RBNP-020) will be incorporated into the Nuclear Management Manual. This policy manual is the upper tier procedural document and follows the hierarchy established at other Entergy nuclear sites.

6.

Fonnalize the River Bend Station Procedure Compliance Poliev.

The philosophy of strict procedural compliance has been previously communicated to River Bend Station personnel through management meetings and memoranda fmm the Vice President - Operations. A site directive on procedure compliance is being developed to incorporate this philosophy as site policy. The compliance policy is being drafted in conjunction with development of the Nuclear Management Manual and will be completed by August 1,1994.

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