ML20077C660
| ML20077C660 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/15/1991 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Taylor J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20077C650 | List: |
| References | |
| C321-91-2084, NUDOCS 9105220277 | |
| Download: ML20077C660 (3) | |
Text
i GPU Nuclear Corporation
_ Uhi One Upper Pono Road Parsippany. New Je4ey 07054 201 316-7000 TELE X 136 482 Wnters Drect Dial Number April 15, 1991 C321-91-2084 Mr. James H. Taylor Executive Dire **.or for U.S. Nuclear Rwgulatory Commission Att Document Control Desk Washington, DC 20$$5 Dear Mr. Taylor
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Response to Diagnostic Evaluation GPU Nuclear (GPUN) has carefully reviewed the Diagnostic Evaluation Team (DET) report in order to understand the root cause findings of the DET and compare those findings with internal self assessments and other reviews which have been
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conducted over the last few years. As mentioned in usur February 14, 1991 letter, many of the deficiencies found by the NRC + dam had been previously self-identified.
GPU Nuclear concurs with the DET's assessment that Oyster Creek is in a state of transition and a variety of improvement initiatives have been undertaken to enhance future performance, i
GPUN recognites that response to initiatives for improvement has in some cases been untimely.
To improve timeliness, personnel at all levels of management must accept individual accountability for doing so.
GPUN intends to accomplish this through continued training, such as ongoing teamwork and leadership sessions, and development of our strong professional staff. The major focus has and will continue to be the strengthening of the organization through the development of management skills and the implementation of Deming principles.
However increased emphasis will be placed on the value and need for timeliness. GPUN encourages implementation of these skills in order to develop a culture which stresses individual accountabilitj acd empowers people to take the initiative to improve the process where such oppostunities are present.
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PDR GPU Nuclear Corporabon is a subsidiary of General Public Utilibes Corporation
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Page 2 C321-91-2084 The Plan for EJeellence was developed proactively to serve as a management tool to focus efforts needed to achieve excellence in all phases of operation. As such, it serves to capture initiatives in a structured manner conducive to implementation.
As a result of the DET, a nunber of implementation action plans will be added or revised.
Recent automation (computeriaation) efforts will f acilitate updating of the Plan and the ability of management to monitor the progress of improvement initiatives. GPUN up;*r management will identify a selected set of the highest priority items for monitoring on a continuing basis in order to improve accountability and the timeliness of implementation.
Other items will be reviewed at least monthly by department managers responsible for individual action plans. Overall progress will be assessed quarterly.
The Diagnostic Team Report noted a number of improvement initiatives that if taken to completion they expected to result in improved performance; however, they considered that the pace of improvement is hampered by weaknesses involving work practices. GPUN had also identified, during various internal and external reviews, work practices which are in need of improvement. With regard to weakness in determining root cause, since the DET exit meeting in January, a root cause standard has been developed and approved for implementation at the oyster Creek plant.
The root cause standard involves the use of a multi-disciplined team and is currently being used to review deviation reports on a daily basis. The results have been favorable and the use of this standard is being extended to general use at the station. The standard provides structured evaluation criteria to determine the level of risk and uncerttinty in order to apply a graded approach in determining root cause. The synergism of the review group provides effective decision making to determine the level of effort in response to a given occurrence.
The standard provides a systematic means to determine when corrective action is necessary and provides a framework to help assure a rigorous review. Application of the standard will help provide a consistent, thorough, risk based root cause evaluation of problem areas resulting in effective solutions to problems.
With regard to corrective actions, GPUN is improving the administrative control I
of the corrective action process. The DET rrport concluded that numerous and i
complex corrective action systems may weaken the administrative control of some l
work.
Based on a review GPUN initiated in early 1990, the corrective action process has been reviewed and measurea are being taken to establish a tier approach to all corrective action systems. The upper tier of this approach consists of the Quality Deficiency Report (QDR), the Deviation Report (DVR) and the Licensee Event Report (LER). The objective is to have all other systems (procedures) that handle deficiencies and work items contain criteria for escalation to the upper tier system based on the significance of the concern.
These measures will improve supervisory and independent verificatior f evaluations and decisions.
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The DET heport concluded that uy6ter Creek is a plant in transition with efforts und rway to improve the materiel condition of the plant as well as implementing a variety of improvement initiatives to enhance future performance.
The recent operating history of the plant and the improved performance trends indicate a significant imprcvement in materiel condition.
Resources available to the plant for materiel etndition improvement and i
maintenance have continuously increased. Additi)nally, a larger portion of these resources is devoted to materiel condition and maintenance rather than for rnodifications to systems or new installationis.
This trend is apparent in the planning for 13R and is expected to continur in the future.
your letter of February 14, 1991, requested that, within 60 days, CPUN describe those actions which address the root causes for deficiencies.
The above paragraphs comply with that request.
Specific weaknesses identified in the body of the report, although not specified in this letter, are being addressed and tracked to resolution.
GPUN is committed to continuous improvement of personnel skills and performance at all levels. The DET report states that GPU Nuclear depends on the experience and skills of individual personnel and managers.
We believe that the indiv!. dual capabilities of our staff are a strength which when supported by appropriate programs and controls will contribute to meeting company goals and objectives.
Recent performance improvements, as noted in the DET report, attest to the progress which has been made. Continued effort and management attention including the steps discussed above will be applied to making the additional needed improvements.
f very truly yours,
[
M P.R. Clark President PRC/GWBaje cci Administrator, Region 1 Senior NRC Resident Inspector Oyster Creek NRC Project Manager i
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FEB 141931 Docket No:
50-219 General Public utilities Nuclear Corporation j
ATIN:
Philip R. Clark, President and Chief Executive Officer One Upper Pond Road Parsippany, New Jersey 07054
Dear Mr. Clark:
This letter forwards the Diagnostic Evaluation Team Report for Oyster Creek Nuclear renerating Station. The team assessed the effectiveness of licensed activit'.es performed by GPUN in achieving the safe operation of Oyster Creek and determined the causes of identified performance deficiencies. The team of 15 ovaluators, led by an NRC manaaer, was onsite at the Oyster Creek station during November 5 through 16 and December 3 through 7.
Team members also conducted reviews at the corporate offices in Parsippany, New Jersey during these periods. The team's findings were discussed with you and your staff during an exit meeting held at the p' ant site on January 18, 1991.
To achieve an independent perspective, the team was staffed with individuals who did not have responsibility for the regulation of Oyster Creek.
Safety performance was evaluated in the areas of operations, maintenance, and testing, including the influence of management and engineering support.
The team concluded that, at the time of the evaluation, Oyster Creek was in a state of transition.
GPUN was still in the process of recovering the material condition of the plant and implemunting a variety of improvement initiatives to enhance future performance. Many of the performance strengths observed at Oyster Creek were primarily attributable to the experience and skills of individual personnel and managers. As a result of the effective conduct of plant operations and the improvements observed in the plant's performance indicators, continued arogress was anticipated; however, the pace of improvement was being lampered by several weaknesses involving work practices which were identified by the team.
The team concluded that some of the weaknesses in performance could be attributed to the root causes described on Page V of the Executive Summary and in Section 3 of the report. These postulated root causes should be of special interest to senior nuclear managers as they direct your Plan for Excellence in Performance to further improve Oyster Creek.
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The slow rate of imp 1 mentation of the varied and n9merous improvement initiatives indicated a need for increased managenent attention and support at all levels in the company, to address root caus0s and to produce a more,
timely resolution of plant deficiencies. GPUN had previously identified many of the deficiencies found by the team.
This fact refitets positively upen your self-assessment capability and your acknowledgtment of the need for further improvements.
I urge GPUN management to carefully review the enclosed report, with special emphasis on the areas requiring additional management attention.
I request that, within 60 days of the date of this letter, you describe the actions you intend to take to address the root causes for the deficiencies in work practices.
In particular, you should describe any changes to the Plan for Excellence in 'erformance which could enhance accountability and the timeliness of your future improvement initiatives.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room.
Should you have an.v questions concerning this evaluation, we would be pleased to discuss them with you.
Sincerely,
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Tay r ecutive Director for Operations
Enclosure:
Diagnostic Evaluation Team Report for Oyster Creek Nuclear Generating Station 1
cc w/ enc 1:
See Page 3 l
G'eneral Public Utilities Nuclear 3-cc w/ encl:
J. J. Barton, Director Oyster Creek Nuclear Generating Station E. L. Blake, Jr.
Shaw Pittman, Potts and Trowbride J. B. Liberman, Esquire Bishop, Liberman, Cook et al.
BWR Licensing Manager GPU Nuclear Corporation Mayor, Lacey Township Licensing Manager Oyster Creek Nuclear Generating Station Commissioner New Jersey Department of Energy Kent Tosch New Jersey Department of Environment Protection
General Public Utilities Nuclear 4-DISTRIBUTION (w/enel):
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EDO R/F JTaylor.
JSniezek WBateman JClifford JBlaha AEOD R/F EJordan Dross DOA R/F DEllB R/F SRubin CGrimes DET Members LSpessard TMurley JPartlow FMiraglia BBoger JStolz ADromerick WRussell TMartin, R1 WRuland,RI Ecollins, Oyster Creek SRI SEbneter, Ril ABDavis, Rlll RMartin, RIV JMartin, RV
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