ML20073R261
| ML20073R261 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/30/1991 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-91-00081, GNRO-91-81, NUDOCS 9106060227 | |
| Download: ML20073R261 (8) | |
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May 30, 1991 U.S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C.
20555 Attention: Document Control Desk Gentlemen:
SUBJECT:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Response To SALP Report GNRO-91/00081 On behalf of the Grand Gulf management and staff I wish to-express-our appraciation for the exceptional recognition given to our efforts in the NRC's April 25, 1991 letter and the May'14, 1991 presentation of the initial SALP report.
We have found this recognition to be both a satisfying and humbling experience.
Satisfying, because positive recognition of the results of sustained hard work is probably the best motivation for.-continued strong performance. And humbling,_because we know'from experience that sustaining a superior level of performance 1is a greater challenge than attaining success.
We have enclosed our coments on the SALP report.
In large measure we have used this opportunity to. comment upon ourselves, ano explore the principles and activities necessary for an improved level of performance in the future.- As> the new SALP period. commences, we!
welcome and'value your_ continued feedback and insight.
Yours truly, wr&m WTC/cg-l
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GNR0-91/00081 Page 2 cc:
Mr. D. C. Hintz Mr. R. 8. McGehee Mr. N. S. Reynolds Mr. H. L. Thomas Mr. J. L. Mathis Mr. Stewart D. Ebneter
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Regional Administrator i
U.S. Nuclear Regulatory Commission Region 11 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. L. L. Kintner, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 11021 Washington, D.C.
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f SALPREII/SCHPFLR - 2 i
At:achment to GNR0-91/00081 Paje 1 ENTERGY OPERATIONS COMMENTS 1991 INITIAL SALP REPORT 1.
- General, Through recognition of the superior performance of the Grand Gulf organization, the SALP report reinforces the significant challenge facing us in the future. As we noted in our Pre-SALP self assessment presented to the NRC in January:
How well does an organization deal with success? Does it continue to mature and grow? Become self-:;atisfied? Maintain a questioning attitude?
Perhaps more than any other, these types of questions occupied Grand Gulf management attention throughout this SALP period.
We found that managing success is, in many ways, more difficult than dealing with adversity.
We continue to ask ourselves these same questions in many different forms and don't foresee an end to the process. Although we are still learning, we believe that we have identified at least some of the fundamental elements on which to base our future development:
Continuous improva:nent - Continuous improvement requires an enthusiasm for innovation, good communications, an empowered workforce and strong technical skills.
Trying to merely maintain a level of performance will eventually result b; complacency and degraded performance.
Strengthening safety culture - A healthy respect for nuclear safety coupled with a willingness to promptly identify and correct safety issues is an essential component in long-term successful operation of a nuclear facility. Grand Gulf management recognizes that a safety culture can be a fragile creaturerequiring'continuousemphasisandencouragement.
The
" care and feeding of this culture is the essence of the Safety Assessment / Quality Verification functional area.
Self-assessment - continuous improveuem. requires a strong management commitment to a self-assessmnt program that is
- effectively used to identify areashssues for imp;ovement.
Learning from the best - Although Grand Gulf has evolved many strong programs, evolution can be a lengthy and painful process.
Large performance increascs can be obtained in relatively shorter periods of time through identification, adoption and improvement of successful practices at other nuclear facilities worldwide.
SALPREII/SCMPFLR - 4
e Attachment to GNRO-91/00081 Page 2 Investment in our personnel - While it is almost a cliche to mention these days, it is a fact that the success at Grand Gulf is solely due to the dedication of our personnel --their sense of responsibility, safety consciousness and ownership for the plant.
Our degree of success in the future will a function of management's ability to provide our perst, el the training, tools and authority necessary for continuous improvement.
Good regulatory communications - Good licensee / regulator communications are based on a professional attitude, safety-consciousness and strong technical bases culminating in mutual respect.
Lack of candor and adversarial relationships only result in mistrust and wasted resources which could have been applied to constructive activities.
II.
Selected Initiatives Grand Gulf is translating the fundamentals discussed abcve into concrete programs expected to provide major contributions to future improvement.
It is worthwhile to briefly review some recent initiatives.
Total Quality Improvement - This program may be the most important initiative currently underway because it is intended to be integrated into all Grand Gulf activities.
Simply aut, Total Quality is founded on continuously improving everytling we do.
Each employee is' responsible for, and is given the training and delegated authority for, continuous process improvement.
The direction and measure of improvement is determined through our definition of-quality:
" Improving every day in-the eyes of the customer." For us, the NRC is a customer and the SALP report is a key measure of our progress. With strong management endorsement.
and participation, we expect the Total Quality program to provide a self-sustaining culture ano drive for continuous improvement at all levels of the organization.
Human Performance Monitoring - This initiative is intended to promptly identify and correct any adverse trend _in this area.
The Quality Frograms department closely monitors the number of Quality Deficiency Reports generated at Grand Gulf and has been directed by management to initiate a detailed assessment if the number exceeds-a low threshold. Management is promptly notified of any adverse trend so that immediate corrective action maj be taken.
In addition, monitoring results are reviewed.in.nonthly management meetings with the Entergy Operations CEO as well as monthly site business meetings.
SALPREII/ScMPFLR - 5 1
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Attachment to GNRO-4/00081 Page 3 Benchmarking - To meet the Entergy Operations goal of world class excellence, we have established a set of regulatory (safety),
production and cost benchmarks derived from the best performers in the industry.
Grand Gulf performance is compared to these benchmarks on a quarterly basis with the results reported to executive management.
Associated with the identification of the best industry performers is a program to investigate and determine the source of the strong performance for adoption at Entergy Operations facilities.
Professional Management Program - This is an instructional program aimed at improving the management and communications skills of all supervisory (and higher) personnel at Grand Gulf.
Recently, plant superintendents and managers cos:pleted this program. With few exceptions, current site supervisory personnel should complete the program by the end of the year.
For new supervisors and above our goal is completion of the program within six months of their selection.
Technical Exchange Program - Grand Gulf has initiated 3 persor.nel exchange program with a goal to identify innovative approaches to the resolution of technical and operational problems.
In July, Grand Gulf will be sending a system engineer and a chemist to the Leibstadt plant for six months.
Upon their return, Leibstadt will send similar personnel to Grand Gulf for six months.
This is the first of what we intend to be a continuing technical exchange program.
Incentive Programs - Every permanent Grand Gulf employee is covered by a yearly incentive program tied to overall plant performance.
Nuclear safety, plant availability and cost control goals are used to measure effective performance in determining the payout under this program.
While a number of other initiatives are underway, we feel that these are typical of the activities necessary for Grand Gulf to continue to improve our overall level of performance.
Ill. ChalleS /,
Even though the SALP Report contained no specific recommendations, Grand 11f management as well as NRC management recognize that there are challenges remaining. The fundamental challenges and initiatives necessary to fuel continued improvement are discussed above.
Specific challenges in each functional area are reviewed below.
It is our intent that these challenges be met and overcome.
A.
In the Operations Area, the three recognized challenges are:
attention to detail, E0P's and housekeeping.
i We have addressed " attention to detail" under " Human Performance Monitoring", above, and will continue to monitor this area closely.
SALPRE11/SCMPFLR - 6
Attachment to GNRO-91/00081 Page 4 During a recent NRC inspection of the Grand Gulf emergency operating procedures several concerns and/or recommendations were identified.
The more significant issues were in the human factors area and documentation supporting the current format.
Changes will be made to the plant procedure to address this area, including a clearer definition of the Procedures Generation Package and an im) roved process for documenting / justifying changes or devic.tions.
Otler discrepancies identified during the NRC Followup Inspection on the E0Ps were addressed during the inspection and specific actions are being tracked to completion.
Grand Gulf is currently working to resolve these issues with an expected completion date of December 1991.
With regards to housekeeping, Grand Gulf is committed to maintaining the facility at the highest level possible. With this in mind, and the identification that out-of-the-way areas need more attention, we are increasing our efforts to improve housekeeping in general and will place special attention on the less accessible areas.
For instance, Supervisor inspr.ction of relatively inaccessible rooms is now conducted on at least a weekly basis.
B.
In the Radiological Controls and Chemistry Areas there are two recognized challenges.
One of the challenges, which fc,lls within the Chemistry Section, is the tritium analy3is.
The Section took a hard look at them.selves after being notified of the out-of-tolerance analysis on the last cross-check sample. Both the Inter-and Intra-Laboratory Comparison Programs were reviewed to determined ary trends in this area.
This review did not reveal any adverse trends but increased management and Chemistry Section attention to the comparison programs will continue until we are confident that any problems have been identified and corrected.
The other challenge falls within the Radiological Controls and Maintenance Area.
This challenge is to reduce and to maintain the contaminated floor area to the lowest possible size.
The Raf a v gical Controls Section, Plant Services Section, and Grand Gu. management recognize the importance of this parameter and continuously monitor its status. An ambitious goal for the amount of contaminated floor space has been set (2% of the RCA) against which performance is judged.
Grand Gulf's desire to achieve this goal was demonstrated recently through our willingness to reduce power to make leaking secondary system valves accessible for repair.
Additionally, during a recent scheduled outage for replacement of recirculation pump seals, special attention was given to stop additional leaks.
These efforts have led to achieving reduced radwaste influx comparable to those achieveo during the first cycle of operation, and have made available more space for decontamination.
Radwaste influx goals have been explicitly included in the yearly incentive programs for Operations and He.lth Physics management.
SALPREII/SCMPFLR - 7
1.
Attachment to GNRO-91/00081 Page 5 C.
Recognized challenges for the Maintenance / Surveillance functional Area are:
attention to detail, reliability centered maintenance (RCM) and systems important to safety.
We have addressed " attention to detail" under " Human Performance Monitoring," above, and will continue to monitor this area closely.
In regards to the RCH Program, System Engineering is actively pursuing the implementation of this concept. Systems already evaluated include Standby Service Water and Instrument Air.
Plans are to perform the RCM evaluation next on the Feedwater and Turbine Building Ventilation Systems.
System Engineering is also using this opportunity to prioritize those systems important to safety for the RCM process. By combining the need to pay more attention to systems important to safety and the RCM process, improved performance is expected with minimal impact on personnel resources, j
As we become more familiar with using and applying RCH concepts, we expect additional benefits as well.
For instance, we may find that RCM can provide us with a useful tool to assess the safety effect of voluntary entry into LCOs for the purpose of elective maintenance activities.
D.
For the Emergency Preparedness Area, drill scenario development is a recognized challenge.
2 Drill scenario development has been given the highest attention by the Emergency Preparedness Organization.
Improved scenarios are expected through the assignment of an experienced plant SR0 to the organization and the change in philosophy from contracting the development of the scenarios to doing it in house.
During the developmental phase for the 1991 Emergency Exercise, Emergency Preparedness personnel drafted a scenario early in the process and recently met with Region II personnel to discuss.the drill.
Based on this di,cussion, we now feel we have a better understanding of the expectations of Region II.
Grand Gulf will use this understanding to improve future scenarins while ensuring that the 1991 Exercise Scenario demonstrates significant improvement.
Increased management involvement will continue to ensure this challenge is met.
E.
In the Security Functional Area, control of_ vital area doors is a recognized challenge.
To meet this challenge will require the attention of all plant staff employees.
Increased management involvement will be given until an acceptable level of performance is obtained.
Continued monitoring and trending by the Security Department will be utilized to keep management informed of the status while we are assessing-the long-term corrective actions necessary to fully resolve this issue.
SALPREII/SCMPFLR - 8
Attachment to GNRO-91/00081 Page 6 l,.
-7 F.
For the Engineering / Technical Support functional Area, two recognized challenges are reliability centered maintenance and-i systems important to safety.
I The methods for meeting these challenges are addressed under the
[
Maintenance / Surveillance Functional Area.
).
G.
In the Safety Assessment / Quality. Verification Functional Area, the NRC has identified two challenges: support for Technical Specification changes and improved 10CFR50.59 Reviews.
Grand Gulf and the NRC have been engaged in extensive discussions over most of the last year concerning the generation, review and -
approval of Technical Specification changes. -Numerous i
disagreements and misunderstandings (such as the Technical Specification.-support issue. raised in the SALP report) have been successfully addressed. As we look_to the future, we are encouraged by the continuing convergence of vietpoint in resolving 4
these issues through a more-focused attention to the safety issues involved.
In the area of 10CFR50.59 reviews, Grand Gulf _is continuously-_
striving to improve. The 50.59 procedure and guidelines have been significantly upgra hd to incorporate lessons learned and NSAC 125, and address previous problem areas. An improved training program based on the upgraded procedure / guidelines is currently being delivered, including detailed instructions.on the license basis-and safety analysis basics, and challenging examples, workshops and examinations. Once sufficient time has elapsed to provide enough data points, Nuclear Licensing in conjunction with Quality _.
Programs, will perform an assessment of _50.59's for improved quality.
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