ML20080A586
| ML20080A586 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 10/21/1994 |
| From: | Rudebusch T CAJUN ELECTRIC POWER COOPERATIVE, INC., DUNCAN, WEINBERG, MILLER & PEMBROKE, P.C. (FORMERLY |
| To: | Wetterhahn M WINSTON & STRAWN |
| References | |
| CON-#494-15853 OLA, NUDOCS 9411010195 | |
| Download: ML20080A586 (64) | |
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- HAND DELIVERY t ADMITTED IN WASHINGTON ONLY Mark J. Wetterhahn, Esq. .
I Winston & Strawn 1400 L Street, N.W.
- Washington, DC 20005 i Re: Gulf States Utilities Company, (River Bend i
Station), NRC Docket No. 50-458-OLA l
Dear Mr. Wetterhahn:
In accordance with our conversations on the telephone, .
enclosed please find Cajun Electric Power Cooperative, Inc.'s Second Supplemental Response to GSU's Discovery Request No. 9. It is again provided subject to Mr. .Elmer's second affidavit. l l
Please call if you have any questions. l l
Sincerely, i n c - _4_W Q Thomas L. Rudebusch cc: Honorable B. Paul Cotter, Jr.(by mail) l Honorable Peter S. Lam (
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Honorable Richard F. Cole ( )
Ann P. Hodgdon, Esq. ( )
Robert B. McGehee, Esq. " "
( )
John Schwab, Esq. " "
( )
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9411010195 941021 PDR G
ADOCK 05000458 PDR
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z Cajun Electric Power Cooperative, Inc.'s, Responses to First Set of Interrogatories of Gulf States Utilities Company Docket No. 50-458-OLA
- 9. Describe any systematic plan or procedure for review by Cajun or its consultants of safety matters arising at River Bend, identifying any document associated with such plan or procedure, the author of such document or plan, anyone reviewing or concurring in such document, when it was prepared, the dates of any amendments thereto, the dates on which it was implemented, and any safety matters evaluated, discovered or dispositioned in accordance with such procedure or plan.
RESPONSE SECOND BUPPLEMENTAL RESPONSE Cajun's Comprehensive Monitoring Program (" CMP") was implemented as a result of Cajun's participation in River Bend. The attached document (# 100191 - 100254) describes the CMP, and it was effective as of the date reflected on the document. It was authored in large part, although not exclusively, by Mr. Larry G. Johnson. As reflected on the document, it was reviewed and concurred in by Mr. Jack M.
Miller and Mr. Phillip G. Harris. The dates of any amendments are reflected in the attached document. The document previously supplied (# 100150 - 100190), is a draft of the attached document, which is believed to have been prepared in 1987 or 1988 by Mr. L. Johnson, under the direction of Mr. Harris. The matter discribed in response to GSU No. 1 was discovered in accordance with the CMP.
PREPARER Victor J. Elmer
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CAJUX ELECTRIC POWER COOPERATIVE, ::NC
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MON::TORING PROGRAM b
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- 100191 ,.
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k THIS COMPREHENSIVE MONITORING PROGRAM IS PROPRIETARY TO CAJUN ELECTRIC POWER COOPERATIVE, INC. REPRODUCTION OR DISSEMINATION TO THIRD PARTIES, IN WHOLE OR PART, ,
IS PROHIBITED WITHOUT THE EXPRESS WRITTEN PERMISSION OF THE VICE PRESIDENT OF i OPERATIONS, CAJUN.
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t 100192
s COMPREHENSIVE MONITORING PROGRAM I. INTRODUCTION Cajun Electric Power Cooperative owns 30% of River Bend Station, a nuclear generating station. Cajun's investment of $1.6 billion represents the single largest project in the system and 60% of total assets. An asset of this magnitude deserves considerable attention.
Cajun's rights and responsibilities regarding River Bend are defined in the Joint Ownership Participation Operating Agreement ("J0POA"). This agreement created the joint venture with Gulf States Utilities and delineates the obligations of both parties.
The administration of this agreement was charged to the newly created Joint Operations and Interconnection ("JOI") Department. The Department's responsibilities include accounting, auditing, budgeting, GSU liaison and technical monitoring for all Cajun joint venture projects.
Essential to the financial management of the asset is a Comprehensive Monitoring Program (" CMP"), whose purpose is to:
- provide timely information about the perf o rma nce of River Bend and the quality of its operations.
provide insight as to how well the facility is operating relative to its peers.
- understand the basis for all expenditures made by GSU to support plant operations.
provide guidance to GSU as to Cajun's position as it relates to plant operation.
- ensure the operation of River Bend is fully integrated into Cajun's operation.
- assist auditing, accounting and budget functions in their understanding of operations at River Bend that affect these disciplines.
- represent Cajun on site at all times.
This report will discuss the CMP in detail, including how Cajunand is organized to meet this task and the specific operations i responsibilities of J01 in its administration of this agreement.
- 11. AUTHORITY Cajun derives its authority to establish the Comprehensive Monitoring Program from Article 7 (" Cooperation and Coordination") of the J0POA, dated August 20, 1979. The relevant sections include 7-1, Cooperation; 7.2 Information; 7.4 Availability of Records and Audit Committee; and 7.5 Management Advisory Committee. In essence, these sections of the contract 100193
s permit unlimited access to information and meetings concerning plant operation and costs; unlimited personnel access provided site security procedures have been complied with; maintenance of an office; and representation on a Management Advisory Committee which meets periodically to permit formal recommendations on the part of Cajun.
III. ORGANIZATION AND PERSONNEL QUALIFICATION The CMP is managed by the Technical Operations section of JOI. The section consists of the following personnel:
Technical Operations Manager l
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\ l Site Tech Operations Analyst Representative 100194
s Ope r a t ion s ,
ClltilN Ft.P.CTRIC FUWER t'tMirF.R ATIVR, 1NC. '
JOINT UPERAtlONS & IN TERCONNE('TIONS 11EFAR tMF,NT ORCANIZAtt0 MAL CllART Joint Operations &
Interconnections Director Secretary C. L. Courtney I
I . i Terinit e n t Joint operations &
Operntinns interconnectInng AcenuntIng finnage r b & Auditing flannger i
W. C. Runte C. F. ll111 Stenographer / Clerk Vnennt I .
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Par t t r.tpn t t on Joint Operntinne Joint Operat tons Partletpatton Cnntrnet /
& Interconnections Auditing & Interennnectionn Acententing Coordinator Technic 11 Operntlong Engineer (Nuclear)
S"pervloor Supervisor Analyst D. R. Ogden Vacant J. fl. Furtle fl. T. Went I.. C. Johnson I
Participation Clerk I Sr. Participatton rsrticipation Anill t o r Aisditor Atenem t a n t V . ti . Reynolds E. H. Stenger C. W. Wright L. J, telegtine "C""
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A. Personnel The Technical Operations Manager is, in part, responsible for the CMP regarding River Bend. Reporting to this position is a site representative and an analyst. The analyst compiles statistical data from the site and from other sources of information to provide timely analysis of trends. (See below the section on plant performance indicators). The analyst also prepares budgeting information for Cajun based on input from River Bend personnel.
B. Site Representation A minority owner must have an on-site nuclear experienced person. This position is crucial for an effective ongoing monitoring program. Much of the data, reports and information available must be reviewed on a continual basis to enable a third party to be able to actively monitor the facility. This review provides up-to-date plant operational issues and last minutes meeting notices. At every opportunity, meeting attendance at almost any managerial level it, valuable.
- 1. Qualifications of Site Representative
- a. Education Bachelor's degree in an engiaeering discipline with nuclear power generation station experience. Graduate level degree in engineering or business is preferable.
- b. Experience Minimum five (5) years experience on-site at an operating nuclear power station in the areas of operation, maintenance, or quality assurance.
Experience in electrical, mechanical, or field engineering instrumentation or scheduling, as well as nuclear licensing, is desirable.
- c. Other Capable of being bonded. A Nuclear Security Clearance may be required. Must pass the General Employee Training I and II Course (River Bend).
- d. Job Knowledge A general working knowledge of nuclear power systems ,
equipment and radiation protection requirements is necessary. A general understanding of nuclear regulatory and procedural requirements is essential.
An understanding of outage planning and scheduling techniques is necessary.
- e. Abilities and Skills Must be able to communicate effectively. Ability to understanding technical drawings and specifications. i Ability to analyze technical data, plot trends and l j
write summary reports on results.
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_ Site Representative Activities 1.
Field Observations visually inspect the Radiologically Controlled facilities Areas on a regular basis available) ("RCA") (when areas and paying particular attention to anticipated pr blis access o em Review to the progress of scheduled work activities.
(further the control room status board noting operabilityinvestigate and document significant events advise supervisor). events likely to affect 2.
Attend Selected Meetings Attend the following site meetings:
- a. Daily Operational
- b. Joint Owner
- c. Outage
- d. Scheduling e.
Plant Operability and Performance Task Forc e f.
Msetings on Proposed Capital Expenditures g.
Nuclear Regulatory Commission Site Briefing s h.
Institute of Debriefings Nuclear Power Operations Briefings and The intention here is not performance, but to be able to obtain detailed knowledge of all projec t surface warning to at different meetings. to sift out problem areas that tend to unanticipated costs Such recurring issues provide an early Every opportunity to attend external or future plant operational problems.
NRC, ANI), should be taken. scrutiny exit briefings (lNPO, Any report Should problems noted in internal CSU meetings should be requested.
also appear or evaluation about which the representative is made in external criticism, alarms need to be This is a very subjective aware information areas are that needs to be conveyed to management. process of filtering f ramework ofidentified, Once problem the workinghowever, they need to be pursued within the and the appropriate CSU department. relationship betweenrepresentative the site resolution, may provide a liaison function Cajun may have suggestions as to a corporate office but as a site between the project and representative indicatesminimum, the physical presence of Cajun's continuing interest The ultimate following synthesis of this information purposes: in site activities.
must be conveyed for the
s 1
a) Immediate information needs - any site activity or action that is likely to result (or has resulted in) controlled shutdown or SCRAM (an automatic shutdown of the unit) needs to be conveyed immediately.
b) Weekly - reports of all site meetings attended, as well as informal contacts should be summarized with facts and/or impressions as to items of significance to this joint owner.
c) Monthly - general data as contemplated in monthly management reports should be collected and prepared for transmittal.
- 3. Document Reviews The site representative reviews and evaluates inf o rmation such as the following:
- a. Daily Control Room Log
- b. Daily / Weekend Reports (some meeting and visitor information provided)
- c. Plant Operability and Performance Task Force Minutes
- d. Work Scope Committee Minutes
- e. Capital Improvements / Replacements Requests
- f. Condition Reports
- g. License Event Reports
- h. Nuclear Regulatory Reports and Responses (see Publications first)
- 1. INPO Reports and Responses (see Publications first)
- j. Schedule Analysis Report
- k. Performance Monitoring and Management Report
- 1. Work Schedules
- m. Outage Schedules
- n. Proposed Project List
- o. Budgets
- p. Other as needed
- 4. Uses Documentation Matrix (Attachment A) 100198
- 5. Interviews key site personnel responsible for completing activities that may af f ect the units operating perf ormance, production costs, capital expenditures and nuclear safety performance.
- 6. Assists Cajun in preparing recommendations for improvements at River Bend.
- 7. Assists Cajun in making independent analysis of operating performance, production costs, capital expenditures, schedules and budget including forecasts.
- 8. Trends data and makes reports.
- 9. Observes nuclear fuel reloading.
- 10. Gathers data and documents necessary for the independent review and monitoring of cost and operational variances.
- 11. Provides the coordination function for site visits, meetings, etc.
IV. Statistical Analysis
- A. Plant Performance Indicators Availability is one of the more important indicators of the nuclear industry. Poor availability is related with defective equipment, operations or regulation, and has a direct impact on economics.
Availability also has a strong two-way relation with public acceptance, both directly and through economics. High availability builds confidence in the public, it gives credibility to nuclear power, and it leads to lower electricity costs. Conversely, a poor climate of opinion reflects itself through intervention and politics in those aspects of regulation that have a negative influence on availability.
1 Long term capacity factor is considered the most important performance I indicator for base load plants. However, many plants operate in the load following mode, therefore equivalent availability factor becomes a j fairer indicator of plant pe r f o rmance when both base load and load J following plants are compared. Other important perf o rmance indicators l for a nuclear power plant unit are as follows:
- 1. Equivalent Availability Factor (EAF) - The ratio of the total power a unit could have produced considering actual equipment and regulatory limits, to its rated capacity, expressed as a percentage.
- 2. Forced outage rate - Percentage of time-unit is forced off the line due to equipment failure or other unplanned conditions;
- 3. Unplanned automatic scram rates - Number of times unit is forced off line automatically.
1
- This section relies heavily on recommendations made in a recent report issued by the Atomic Industrial Forum.
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This data should be used by management in setting performance goals for their nuclear plants and as an aid in monitoring plant performance. It focuses management attention and enables them to evaluate their facilities in relation to others.
- 1. Performance Trends What should be a realistic sustained capacity factor for nuclear power plants? Assuming a twelve month refueling cycle and thirty days to refuel and plant and perform shutdown maintenance, base load plants would have a theoretical maximum capacity factor of 92%. However, a more realistic, but still quite optimistic value for sustained capacity factor is more on the order of 82%. This figure corresponds to the best performing light water reactors in the world today. The lifetime average for all plants today, however, is about 60%.
What accounts for trends and what causes the shortfalls from the optimistic maximum sustained capacity factor of 80-85%?
The shortfalls result from the following:
- a. Forced regulatory outages. This was especially burdensome during the post-TMI period of 1980-1982 when a series of new regulations required significant plant modifications. Very long outages can also occur when a plant has a large number of backfit requirements from ageing,
- b. Premature f ailure of equipment occurs because of:
- Inadequate equipment design;
- Improper selection of equipment for its application; and
- Lack of preventive and corrective maintenance effectiveness;
- c. Extended planned outages to repair some major generic plant problems. Some major contributors have included:
Boiling Water Reactors ("BWR"):
- Torus modifications to Mark I containment;
- Reactor system piping replacement or repairs; Pressurized Water Reactors ("PWR"):
- Steam generator replacement or repairs:
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l Both PWR and BWR:
- Turbine disc cracks;
- Condenser retubing;
- d. Extended refueling outages due to inadequate outage planning, excessive maintenance backlog, or unavailability of replacement parts.
- e. Forced outages from equipment failures, caused mainly by balance of plant equipment which may not receive adequate preventive maintenance.
- f. Forced outages resulting from operator errors that can be attributed to procedures, training, human factors, engineering deficiencies, or complexity of technical specification regulations.
- g. Excessive heat loss from steam leaks, etc.
- h. Deratings. Very often plants are not permitted to operate at full capacity by the NRC because the facility cannot meet technical specifications.
- 3. Operations and Maintenance Practices
- a. Reduce the incidence of scrams - Reduction of scrams requires attention to detail and understanding of each plant component and includes a root-cause analysis of each equipment failure or other event that interrupts operations. There should be a permanent feedback of operational experience toward plant improvements with high quality data acquisition, analysis and synthesis of the data, then follow-up and dissemination of information. A common goal is to reduce the scram rate to less than 2 per unit per year. Better operator training and procedures, improved equipment reliability, and relaxing certain scram set points without compromising safety usually assist in meeting such goals. g
- b. Extend the fuel cycle if practical for the situation -
Plants that have shifted from annual to 18 Often month refuelings report a better capacity factor. a portion of lost generation is caused by large extensions of refueling outages for a variety of reasons. But with fewer refueling outages, there normally is more generation time. It is important that preventive maintenance not be sacrificed during the longer operating times for the potential benefits will because of increased equipment failures.
be lost
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Although many utilities agree that the longer cycle time is beneficial, it may not always be advantageous for some plants. Unique factors such as reserve capacity, seasonal load, hydro capacity, and planned nodifications must be included in any analysis of fuel cycles.
- c. Effective primary and secondary water chemi s t ry programs - This includes such things as controlling chemistry within tight limits, not operating out of specifications, having thorough condenser and steam generator inspection programs, making extra efforts to control and scavenge oxygen; using condensate polishers (a system that maintains ultra pure water), and in most cases using All Volatile Treatment (AVT) of steam generators. Lancing of deposits on steam generator tube sheets during outages also removes a source of chemical material that causes tube corrosion.
Following these practices will improve lifetime availability factor.
- d. Foster good relationships, dialogue, and teamwork with contractors (Architects, Engineers and Nuclear Steam Supply System vendors) - Service companies in turn should have a long term commitment to the industry, have up-to-date tools and technology, and have qualified and talented people. Prompt service response time for unscheduled outages should receive top priority and requires a large pool of trained service personnel to implement.
- e. Lay out well defined objectives for improving performance -
Assess operations with performance indicators, prioritize items contributing to unreliability, and assign responsibility to resolve.
Identify potential improvements, then by cost-benefit analysis target for immediate or long term action.
Utility management also must know what is happening in the plants by looking closely, reinforcing good work habits and practices, and making corrections as needed.
- f. Improve responses time to equipment problems - Maintain an automated well-stocked inventory of replacement / repair parts. Have a highly qualified support / engineering staff on site, particularly when corporate office support is distant. Some plants have strengthened their shift teams with mechanical I&C, electrical and material personnel to perform on-line repairs. Establish communication with similar plants to provide for " borrowing" compatible material or components. The U.S. industry average for operating i plant Work Orders restrained for lack of parts is about '
l 13%. It is important to have a good understanding of how to procure and dedicate commercial grade parts for safety-related components.
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- g. Be ready f or the unplanned outages - Have much of the shutdown planning done when this occurs. A shutdown work list should be maintained and updated weekly showing jobs in three categories: 1) those which can
- be accomplished with the plant in hot standby,
- 2) those which must be done with the plant in cold shutdown, and 3) those which require a refueling outage. Maintain these jobs on a computerized program of maintenance management which includes parts inventories, labor force scheduling, and other techniques to optimize manpower and inventory levels.
Assign responsibilities in advance, wherever possible, for the three types of outages. ALARA (as low as reasonably achievable radiation exposure) concepts should be used to reduce radiation exposures and increase worker efficiency.
- h. Aggressively review technical specifications to see which are unnecessary or redundant - A thorough analysis with sound technical backup should be done for each requested change. Streamlining technical specifications has proved to be an important measure for improving capacity factor. Reducing cold starts on diesels is a current example. Reducing the f requency of other unwarranted surveillance tests also reduces the change of inadvertent scrams.
- 1. Maintain a relationship of mutual professional respect with government authorities - The authorities keep track of plant performance indicators, too, and tend to place their inspection emphasis in the perceived weak areas. Maintaining credibility with the authorities and building a reputation as a good perf o rmer is an important factor in having high availability.
- j. Employ disciplined and formal administrative, watch j standing, and work practices - Examples: l
- Double check valve and system lineups;
- Keep an accurate status of systems including tag outs;
- Control all plant system operations from the control room;
- Perf orm a thorough watch /shif t turnover; Make frequent inspection tours of the plant;
- Use only approved operation and maintenance procedures;
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Make timely material deficiency reports; f l
- Coordinate maintenance work and surveillance; testing to eliminate scrams i caused by personnel' errors; l
- Ensure equipment is clearly labeled (color I coding helps); and
- Involve management in ongoing activities and tours of the plant.
- k. Conduct a quality assurance (QA) program for availability related systems in the balance of plant (BOP) - This need not be as rigid as required for the safety-related systems but a QA program for the BOP systems would help increase the availability factor.
The basic responsibility for achieving quality in performing a particular task rests with those assigned the task and not with those seeking to ensure by means of verification that it has been achieved. Operational quality depends above all on the effectiveness of the organizational structures established to operate the plant and the skill of the operating staff. Therefore, line management is responsible for quality workmanship and QA groups should be used to complement line management by independent and objective assessments of performance.
An example of this type of activity is the quality teams that have been established at both nuclear and fossil generating stations. These teams are responsible for implementing basic quality principles as follows:
- The applicability of quality requirements to activities and materials, and the interaction between activities, must be precisely established. Such activities and materials are termed " subject to quality requirements";
Every activity subject to quality requirements must be carried out in accordance with formal documents (procedures, etc.) prepared prior to performance of that activity, and be recorded in a written report;
- All documents subject to quality requirements must be appropriately retained and updated on a regular basis; 100204
- The quality of all activities subject to quality requirements must be verified on two levels; inspection actions (quality control); and control actions (quality assurance);
- Inspection and control activities must be strictly separate and be handled by different individuals; and Quality assurance (control actions) must be provided by a department which is totally independent of all other Division departments.
- 1. Keep a clean plant - Minimize contaminated areas, oil leaks, steam leaks, rust, and grime. Insure chemical compatibility of solvents and cleaning compounds with installed components. Perform proper lay-ups of out of service equipment and do thorough flushing of systems when called for. Paint / coat concrete in the containment building. This helps the cleaning and decontamination effort. Selectivity decontaminate systems. Good housekeeping improves safety, performance, personnel morale, and contributes to prolonging the life of the plant.
- j. Emphasize preventive maintenance to reduce time consuming corrective maintenance -
Preventive maintenance should be performed on the whole plant, not just the safety-related systems. Both scheduled (periodic) maintenance and predictive maintenance are forms of preventive maintenance. Predictive maintenance uses special equipment or techniques for monitoring and diagnosing equinment condition by such means as acoustic and vibration monitoring, motor current trends, and chemical analysis of fluids.
- k. Use robots and automated tools to speed work and reduce radiation exposure - Examples include a fully automated stepping manipulator for steam generator eddy current testing and repair; pretensioning devices for bolt loosening and tightening of reactor pressure vessel head bolts and steam generator manway cover bolts, and other automated high capability inspection systems.
Also, use mock ups when appropriate to increase worker efficiency and reduce personnel exposure. Job planning should include adequate shielding and other ALARA techniques.
- 1. Maintain effective plant configuration control (accurate plant drawings, technical manuals, procedures, and training) - This requires a good (automated) records management system in order to have efficient and accurate engineering administration.
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- m. Perform valve inspection and servicing using up-to-date valve diagnostic and servicing methods. Valve problems have been a significant cause of reduced plant performance. Valve redesign and servicing may be required for plants early in their operating life.
This is because some valves may not have been designed for their installed application,
- n. Control the maintenance backlog, preferably by tracking work orders by computer - Strive for a goal of 50%
maintenance time spent on preventive maintenance as opposed to corrective maintenance,
- o. Employ a plant engineering group, which works closely with the plant operations and maintenance groups. This engineering group, being close to the sources of information on site, should do studies and reviews of all plant technical problems.
- p. Review the published good maintenance practices and adopt these practices when appropriate.
- q. Utilize completed research and development work to improve plant maintenance and performance -
Considerable R&D has been completed or is in progress to improve LWR performance. Typical technology areas in maintenance research include:
- Preventive (including predictive) maintenance;
- Human factors in maintenance;
- Maintenance hardware and methods improvement;
- M;intenance outage improvement; and
- Innovative maintenance techniques.
Examples of recent R&D that utilities have reported using to improve availability include the following:
- Improved techniques for Eddy-current testing of steam generators;
- Improved non-destructive examination techniques;
- Turbine rotor-disc cracking research; ,
- Material procurement guidelines;
- Valve packing improvements; I
- Condenser retubing research; l
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- Fuel utilization research;
- Bolting technology:
- Condenser tube leak detection with helium;
- Acoustical monitoring of valves;
- Decontamination techniques that reduce outage time;
- Refueling techniques;
- Analysis of capacity factor losses;
- Outage planning techniques;
- Intergranulate stress corrosion cracking (IGSCC) research. This has led to such techniques as Induction Heating Stress Inducement (lHS1) for BWR piping and a shot peening method for joining tubes to tube sheets in steam generators; and
- Improved water chemistry control guidelines to reduce 1GSCC and other corrosion mechanisms.
- 4. Outage Management
- a. Plan outages carefully months in advance with detailed and complete planning - Extended ref ueling outages are the leading cause of unavailability. Modification and design change packages should be complete and at the plant before the outage begins. A computerized management program with good input should be used to determine schedules, numbers of people, hours / day for each outage activity, parts inventories, coordination of jobs, and scheduling of overhead cranes. Much of the delay in refueling outages is caused by such things as fuel handling, transfer, and storage; inspection procedures; and unique problems. Often, the unique problems that require outage extension are attributed to equipment problems not previously identified that are discovered during the outage. Therefore, testing and analysis of potentially troublesome systems should be performed early enough to reduce surprises.
- b. Apply advanced technology and a systems engineering approach to solving problems - This can be done by forming a pro-active team consisting of the utility, system designers, equipment manufacturers, and service companies. Many successful utilities maintain an ongoing relationship with the NSSS vendor, turbine-and plant designer. By generating manufacturer, 100207
fostering a team effort, the utility is more likely to get the best and most immediate response from their contractors. The utility must have an able core of engineering and maintenance personnel to oversee the contractors and lead the team.
- c. Manage the maintenance, refueling, inspection and backfit work to stay on the critical path - Computer programs should be used for daily tracking of outage work and when necessary (which is often) tasks should be reshuffled to stay on the critical path. The information fed into the computer should be checked by the Outage Manager. In so checking he generally has the tools for making daily decisions. The computerized maintenance management system should be capable of preparing system tagouts, keeping system boundaries and checking for conflicts. A good maintenance management system also aids in the use of three work shifts.
- d. Have a well defined outage organization with appropriate people responsible and accountable for each maintenance activity -
One good way to resolve interfacing problems is by use of an outage management team. This team of utility and contractor personnel, which would include the Outage Manager, should coordinate the critical path items.
- e. Plan all outage activities around a set number of days for a refueling outage - Try to keep backfits from controlling the critical path. Spread maj or maintenance activities such as "open and inspect" over a number of outages; 1.e.; levelize work load and stay on the critical path.
- f. Pay special attention to the availability of replacement parts - The supply, engineering, quality assurance, and planning departments must work closely together to assure on time delivery of parts that meet all requirements and specifications. Recognize that obtaining safety-related parts from a reduced number of qualified vendors is a major problem in the industry that requires increased efforts by utility / plant personnel.
- g. Manage with great care the occupational radiation exposure to individual workers and the total man-rem dose for each job and outage. Work done in a radiation environment never goes as smoothly as work done in a radiation free environment without careful planning, and rehearsal on mockups. Therefore, ALARA (as low as reasonably achievable) input in the planning stage of work package development is essential to reduce delays 100208
and increase efficiency. Every eff ort should be made to reduce hot spots and general radiation levels. In some cases it will save time and exposure to spend the first day of a refueling outage cleaning and decontaminating the containment building.
- h. Conduct post-outage critiques routinely - A " lessons learned" document should be published. Regular meetings between plant personnel and engineering support groups should begin at the end of the refueling outage to provide a coordinated approach for future modifications and changes. Visits to peer units is also beneficial in " lessons learned" activities.
- 5. System Design / Equipment Improvements
- a. Conservatism in plant design paved the way for a number of plants that have high capacity factors and efficient operations - This includes simplicity of plant design, the use of well proven components, and extra room for maintenance work. However, since the design of most plants is complete, conservatism in plant design should be practiced when installed modifications or replacing f_ ailed equipment. Examples: eliminate stellite bearing surfaces and eliminate crud traps like socket welds when the opportunity presents itself.
- b. Lessons learned from the lead unit of a series have helped improve the performance of the subsequent unit (s) -
Design improvements follow-on units have reduced flow restrictions, pipe stress, valve failures, equipment trips, and problems associated with the cores and fuel. Also, operators of replicate plants should review the operating history of lead plants to identify design problems leading to plant trips and other problems.
- c. Improvements in BOP systems and equipment have increased some plant capacity f actors significantly -
feedwater, turbine, condensate and other balance-of-plant systems have been the cause of the majority of scrams. Some specific suggestions for improvements include:
- 1. Provide coincidence trip circuits c1 more BOP j systems;
- 2. Provide improved bypass feed flow for start-ups and 1 shutdowns; and
~'7-100209
i
- d. Improvements in reactor protection systems can reduce the scram rate - Digital controls with fault tolerance, triplicate functions and self-diagnosis have contributed to reduced scram f requency in those plants where such high quality state-of-the-art equipment has been installed. Relaxing or eliminating certain scram set points for some PWR designs with analog controls will reduce the scram rate for these plants. Analysis of some specific PWR designs indicate that relaxing scram set points for steam generator level, turbine trip, and low pressure can be accomplished for these plants without compromising safety. Optimizing surveillance requirements of the protection system also reduces the scram rate.
- e. Improvements in control room ergonomics can reduce operator error. Human factors deficiencies related to the man-machine interface, particularly the layout and grouping of indicators and controls in the control room have contributed to numerous operator errors or omissions. Many times an event has been compounded because of confused controls or indications in the main control room or at local control stations. Human factor deficiencies should be identified and prioritized. The most serious deficiencies ehould be corrected expeditiously to reduce the chance of incidents. (Example: A serious incident in a plant was compounded because the operator pushed the wrong buttons in a confusing array on a panel. This had been .
identified as a human factors deficiency but had not been corrected at the time of the incident.)
- f. Modification /backfits can improve the capacity factor and reliability of plants - Notable is the Japanese industry-wide three phase improvement program where capacity factors have improved from a low of about 40%
to greater than 70%. Modifications to improve reliability and long term capacity factor should be done after a cost-benefit analysis indicate there will be long term improvements.
- g. Purchase specifications for equipment and services should be technically correct and concise -
Utility organizations should have a good understanding of and should follow up the vr.ndor capabilities in the vendor shops. The manufacturing process service / supplier organizations should have a close understanding of utility needs. Adherence to the principles of quality and improved post purchase technical support from suppliers i t. the form of training, troubleshooting and technical manual updates for site specific application would all have a positive effect.
100210
- 6. Personnel / Training
- a. Select top people - A basic ingredient to a training program that turns out well qualified operators and technicians is the calibre of the raw candidates. They must have the integrity, intelligence, and mechanical (or other technical) aptitude to be able to complete the course successfully. The attitude, morale, and stability of the qualified plant personnel have an important bearing on plant operations. Enthusiasm and alertness coupled with knowledge, skill, and teamwork, seasoned with experience equates to safe and reliable plant operations.
- b. Provide high performance training programs and facilities including plant specific simulators, computer assisted training, and maintenance training f acilities - Good basic training shouAd be provided to operators, skilled workers, technicians, and engineers.
They should gain an understanding of the basic phenomena and assumptions leading to procedures as well as learning the procedures. Usable and accurate plant procedures and instructions are essential to safe and reliable operations and must be closely coupled with the training,
- c. Use enough shifts (preferably six) such that one shift will be in training at all times - Maintaining a high level of qualification and expertise for conducting both routine and abnormal / emergency procedures reduces the chance for human error. This also assumes accurate and well-formatted procedures. Approximately half of all significant events are due to human error or other human performance problems.
- d. Assign only top quality people with the proper experience, education, training, and leadership attributes to the key management positions -
Performance at any given plant depends heavily upon having exceptional people in the key positions, particularly, the plant managers and the senior nuclear executive of the utility. The key management people should gain experience at an operating plant before they are required to make operational and engineering decisions. It is generally beneficial for the plant manager and other key utility officials who make important plant operating decisions to hold or have held a reactor operator license or equivalent certificate. If these individuals do not hold a certificate or license, it is essential that they have equivalent experience and knowledge.
-"- 100211 l
- e. First-line supervision should be strong tec'aically and receive comprehensive management and supervisory skills training prior to assuming supervisory roles, and periodically thereafter. Successful plant operation is dependent on first-line supervisors being actively involved in plant activities, and not accepting less than the best effort a worker can provide,
- f. Hold individuals responsible for their actions - Foster the worker attitude of doing the job right; by peer inspection, by keeping eyes open to problems, and by not relying on the QA/QC staf f or radiation protection technicians and safety personnel to find problems.
There should be clear and reasonable operating objectives between management and operators / workers.
Good leadership and communications, pride in the plant, team work, performance recognition and other efforts to foster high morale reduce personnel turnover and improve worker performance.
- 7. Conclusion improvement in nuclear power plant pe r f o rmance and availability will enhance the economy and safety of nuclear pcwer plants.
B. Data Ease and Analysis A characteristic of all nuclear plant if that they generate a tremendous amount of paper. It is very easy to get lost in the volumes of paperwork and not effectively monitor the nuclear project. The the joint owner naturally has limited resources to accomplish monitoring task. Therefore, computerizing the nuclear data base is an extremely important function.
The following is a list of data that should be entered into the computer data base as recommended by INPO. Cajun maintains all of this data on River Bend Station.
- 1. Operating Data
- a. Gross Electrical Generation (MWh)
- b. Net Electrical Generation (MWh)
- c. Equivalent Availability
- d. Net Capacity Factor
- e. Forced Outage Rate
- f. Planned Outage Rate I
- g. Thermal Performance (BTU /KWh) Gross Heat Rate l 1
- h. Unplanned Reactor Scrams 1 1
1()3212 l
- 2. Chemistry
- a. Reactor Water
- 1. Conductivity
- 2. Chlorides
- 3. pH
- b. Feedwater Chemistry
- 1. Conductivity
- 2. Dissolved Oxygen
- 3. Total Metals
- 3. Engineering
- a. Modification Request Status
- 1. Work Items
- 2. Paper Items
- 4. Licensing
- a. NRC Violations (1-V)
- b. Commitment Tracking Status
- c. Licensee Event Reports Status
- 5. Maintenance
- a. Corrective Maintenance (MWR) Status
- b. Preventive Maintenance Status
- 6. Material Management
- a. Annual Inventory Turnover Rate
- b. Warehouse Activity Level 100711
- 7. Operations
- a. Limiting Conditions for Operations Status
- b. Thermal Performance
- c. Surveillance Test Procedures
- d. Diesel Generator Reliability
- e. Unplanned Reactor Scrams
- f. Forced (or Unp.'anned) Outage Rate
- g. Planned Outage Rate
- h. Net Capacity Factor
- 1. Equivalent Availability
- j. Unplanned Derating Factor
- k. Planned Derating Factor
- 8. Personnel
- a. Station Staffing Status - Total
- b. Annual Personnel Turnover Rate - Total
- c. Annual Personnel Turnover Rate - Key Positions
- 1. Operations
- 2. Technicians
- 9. Projects
- a. Contract Employees on Site
- b. Subcontractor Manpower
- c. Overtime Worked
- 1. Management
- 2. Classified 10071d
- 10. Radiation Protection
- a. Collective Radiation Exposure
- b. Number of Workers Exceeding Regulatory
- c. Limits for Radiation Exposure
- d. Number of Workers with Yearly Doses Greater than 5 REM (current year)
- 11. Radwaste
- a. Volume of Solid Radiation Waste Shipped in Cubic Feet C. Comparison to Other Plants Cajun maintains the following categories of information which are routinely obtained from several other nuclear stations so that comparative analysis can be made. An example of this evaluation is shown in Attachment 2.
- 1. Average Capacity Factor by Vendor
- 2. Ca egory I - All Nuclear Industry
- a. Unit Availability
- b. Capacity
- c. Forced Outage Rate
- 3. All Boiling Water Reactors (BWR)
- 4. Post Three Mile Island, Pre-River Bend BWR's 1,aSalle 1 I a.
- b. Susquehanna 1
- c. Grand Gulf I
- d. Limerick I
- e. Washington Nuclear 11
- f. River Bend 1 j997jq
Page of Attachment E CAJUN ELECTRIC POWER COOPERATIVE INC.
DETAIL ANALYSIS OF TASKS BY CONTRACT PARAGRAPH CONTRACT: -- - --
Subject:
Para Ref:
A. Description B. _ Procedure Responsible Company Div/ Dept Position (s) Tasks to Perform Frequency S
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M 100716
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- 5. Post River Bend BWR's
- a. Shoreham I
- b. Fermi Il
- c. Hope Creek I
- d. Perry I
- e. Clinton I
- f. River Bend I
- 6. The following data from these selected facilities is also maintained:
- a. Facility Name
- b. Date First Electrical Energy Generated
- c. Date of Commercial Operation
- d. Design Electrical Rating (Net MWe)
- e. Maximum Dependable Capacity (Gross MWe)
- f. Maximum Dependable Capacity (Net MWe)
- g. Report Period Hours
- h. Hours Reactor Critical
- 1. Hours Generator On-line J. Gross Electrical Energy (MWH)
- k. Net Electrical Energy (MWH)
- 1. Unit Service Factor
- m. Unit Availability Factor
- n. Unit Cap Factor, (Maximum Dependable Capacity (MDC),
net)
- o. Unit Cap Factor (Design Electrical Rating, net)
- p. Unit Forced Outage Rate
- q. Forced Outage Hours
- r. Unit Shutdowns / Reductions ICN3217
V. OFF SITE OPERATIONS A. Accounting Cajun has stipulated the type and nature of bill to be received for the power generation. Detailed analysis of GSU's accounting system and the plant cost systems is ongoing. From this analysis the strengths and weaknesses of the accounting system are identified. This information is then used to develop the type of accounting to be received. When the bill is prepared this information must be processed and stored in a data base for analysis purposes.
It is GSU's responsibility to properly account for all joint unit billing for the station and common equipment. As per the contract, all accounting should be in accordance with Generally Accepted Accounting Principles. However, many of the cost allocation principles are difficult in application. Constraints of the information systems, cost benefits of costing procedures and judgments as to overall benefit must be applied over the course of the accounting period. Further the accounts must be highly auditable and creditable to earn the trust of others who may desire to purchase part of the generation complex.
B. Auditing -
The Joint Operating Agreement provides for ongoing audits. With the size and complexity of a nuclear station, Cajun has to be highly qualified in the skills and expertise to perform this type of participation auditing. This is accomplished by an on-site auditor and others to audit the facility cost practices and the accounting records in the home office. Audit plans and programs are developed with the knowledge of GSU's accounting strengths and weaknesses to target each area of nuclear operations and accounting.
C. Budgeting The annual costs of operating a nuclear f acility are enormous. Cajun needs information not only for internal use by also to fulfill its monitoring functions. For the capital items Cajun will take an active role in the decision processes that lead to the determination of a capital expenditure. Each process / job should be monitored for the cause of the job, the cost, the cost benefit study and the necessity f or the minority owner to finance his share. This process involves an active on-site presence and knowledgeable input from an engineering as well as cost accounting prospective.. The budget data must be monitored and evaluated by in-house personnel for variances, trends, etc.
Further the information must be disseminated to the departments who need the information.
l l D. Contract Administration l A system of contract administration has been developed that employes the use of 3 forms. Form 1 is the summary of responsibilities by l contract paragraphs. Form 2 is the detailed analysis of tasks by contract paragraphs. Form 3 is the summary of tasks by responsibility with timing requirements.
100218I I
t Form 1 - Expands the contract into numbered paragraphs.
Responsible divisions / departments are assigned to each numbered paragraph.
Form 2 - Responsible departments as defined in Form 1 are given tasks and timing requirements.
Form 3 - Detailed analysis of actions indicated with timing requirements organized by positions.
Attached is a flowchart that indicated how these forms are utilized, as well as blank forms. (Attachment B)
- 1. Contract Review The most fundamental rule in interpretation of contracts, to which all others are subordinate, is that regardless of
" legalize writing" a contract should receive the interpretation which will best effectuate the intention of the parties. Individual clauses and particular words are to be construed in relation to the main purpose of the contract.
This is an extremely important rule for those involved with contract to remember. Letters of understanding, letters of instructions and similar documentation become extremely important in ascertaining the intent of the parties. Normally copies of these documents are retained to help with difficulties or misunderstandings that could follow. It will be helpful to review the files, notes, etc., to provide further insights as to the intents of the parties. This would also serve to clarify any communications misunderstanding that may have occurred during the negotiation process, however minor it might have been.
Other rules which are helpful to remember are:
- a. Words are given their plain and normal meaning; except:
- 1. Usage may vary the normal meaning of words.
- 2. Technical words are to be given their technical meaning.
- 3. Where possible, words will be given the meaning which best effectuates the intention of the parties.
Every part of a contract is to be interpreted, if possible, so 2.
as to carry out its general purpose.
- 3. The circumstances under which the contract was made may always be taken into consideration.
100219
There are, of course, other secondary rules but the above have provided a basis for the non-legal person to review a contract.
In the review process certain steps have proven to be beneficial.
These may be summarized as follows:
- 1. Read the entire contract.
- 2. Don't assume an interpretation. If it is unclear ask an attorney.
- 3. Prepare a written outline of the contract summarizing the important clauses.
4 If there are obligations for damages assume the worse could t.appen.
- 5. Keep a file of alternatives and other letters clarifying the intent of the contract.
- 6. Give particular care to "exculpatory clauses".
- a. Recognize the clauses
- b. Decide on enforceability of clauses
- c. Decide if risk is acceptable
- d. Take steps to protect yourself from the risk
- e. As a general rule courts have allowed exculpatory clauses which shift known risk, but hesitate to enforce clauses which allow a party to escape the consequences of its own wrongful actions
- f. Sometimes, legal counsel is needed to assist in the evaluation of these clauses
- 7. Review right to audit and site inspection clauses for responsibilities.
- 8. Check for rights to stop or suspend the contract.
- 9. Check for reporting and notice provisions.
l l
1 100220 l
E. Compliance Reviews Once the contract is understood by those responsible for its administration, key job records need to be reviewed by the responsible party for compliance. These records would include:
- 1. Progress Payment Requisitions: These should be checked to insure percentages comports to requisition.
- 2. Inspection Reports: These reports would be from site inspections, etc. and include adjustments, problems to be worked out, etc.
- 3. Logs: A narrative report of the key occurrences and activities.
4 Correspondence: All correspondence that relates to the intent of the contract.
- 5. Photographs / Videos: Ample and sufficient photographs / videos should be taken to establish and document particular troublesome areas. Photographs / videos should be clearly labeled, dated and annotated as to location and who took the photograph.
- 6. Minutes: Summary minutes should be maintained of meetings, key phone calls and actions to be taken as a result.
- 7. Cost Reports: All records of cost should be retained in a contract file with sufficient coordination and referencing to the cost schedule and periodic reports to management.
- 8. Internal Office Correspondence: Key internal documents should be maintained cu che c:t ent it is helpful in documenting or explaining events of the contract.
- 9. Any Analysis: Any internal analysis perf ormed with regard to ;
labor productivity, progress analysis or such related subjects should be retained.
approved, updated and any i
- 10. Schedules: The preliminary, supplementary schedules should be kept and carefully annotated as to purpose and interpretation.
- 11. Other: Any situation that is abnormal or appears not in compliance with the intent of the contract.
l l
100221
F. Management's Reviews Even when the appropriate review procedures are established and understood by the person responsible for contract compliance, it is necessary to implement these procedures through a reporting and monitoring procedure to management. Generally this process would involve the following:
- 1. Analyze the contract compliance in detail at preplanned meetings.
- 2. Schedule "on-site" report meetings to physically demonstrate and review activities.
- 3. Management should ascertain that the person (s) responsible for the contract are delivering proper reports and documentation.
4 Have associated personnel respond with memos of understanding to all oral directives.
- 5. Internal auditor should review reports and other materials to ensure they are properly maintained.
- 6. All f'ollow-up activities should be reviewed for compliance at the next scheduled meeting.
- 7. Management should be " event oriented". That is concentrate on larger issues.
- 8. A report to ma nagement should be prepared detailing time periods provided in the contract for dispute resolution, litigation or claims.
- 9. Where possible reports should be in the form of graphs and charts in order to maximum managements review and facilitate spotting troublesome areas.
V1.
SUMMARY
This CMP is designed to provide guidelines to codify JOI's discharge of its responsibilities. It does not represent a complete "how to" manual for the management of joint operations but is intended to be a living document that will grow and mature with time. As more experience is gained, more detailed standard operating procedures will be developed, refined and incorporated into the document.
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JOI Prepares Form 3 100226
MP-001 REV.1 CAJUN ELECTRIC POWER COOPERATIVE, INC.
COMPREHENSIVE MONITORING PROGRAM OPERATIONAL PLANT PERFORMANCE JOINT OPERATIONS DEPARTMENT PROCEDURE NO. MP-001 REV.1 1
AUGUST 22, 1989
+
Approved: -- -7a f Tec Operations Manager Date Approved:
/ Y f f
)
Director of Joint Operations baM
^ ~
Appr ved VicePres[identofOperations Date
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100227
- .. - . .- _ = . ~ - . - - = - . .. --- .
KEY PRINCIPLES Although Cajun is not responsible for operating River Bend Nuclear Station, as a large investor, Cajun wants to maximize power production (cacacity factor) and the return on investment which helps both owners. Cajun has already developed a respected professional relationship with GSU by utilizing recognized expertise and displaying a genuine concern for River Bend to be a cost efficient and productive plant.
Capacity factor is the most important power production economic performance indicator. Cajun may impact River Bend capacity _ factor by: 1) staying abreast of daily operating conditions and trends, 2) anticipating problem areas that, if not corrected appropriately, will result in less power production and 3) asking management questions in a timely manner.
PROGRAM
SUMMARY
The objective of this program is to provide the appropriate Cajun management with early indicators that can be used for assessing operating performance so management assistance can be exerted to attempt to improve performance. Comparison of :
performance data to recognized goals can be an excellent means of promoting pride, motivation, and improvement.
This program includes the following elements that are considered important to an effective joint owner operations performance monitoring program:
-Selection of the data that most effectively monitors economic ope, rating performance.
-Regular reports of the selected data to key managers and executives, with an explanation of any unusual results and ,
significant trends.
-Comparison of operational strategic performance to predetermined goals. t
-Review and inspection of selected data to ensure that significant problems are being identified in a timely manner, and corrective actions effectively implemented.
-Periodic management review' meetings to promote goals and ensure that management support is sufficient.
100228
, 1 I
i
-Utilize an operationally-experienced, independent ,
consultant. When necessary, he will assist in making l objective evaluations, recommendations and provide !
program guidance.
l 100225:
OPERATIONAL PERFORMANCE MONITORING Table of Contents Page 4
- 1. PURPOSE.............................................
4
- 2. SCOPE...............................................
4
- 3. RESPONSIBILITIES....................................
4
- 4. PROCEDURE...........................................
Daily Plant Operations Monitoring.............. 5 4.1 4.2 Correspondence / Document........................ 6 4.3 Chronic / Deteriorated Plant Conditions.......... 6 Monitoring 4.4 Executive / Management Monitoring................ 7 Management Advisory Committee Meeting.......... 7 4.5 Independent Experienced Consultant............. 8 4.6 100230 4 i
r OPERATIONAL PERFORMANCE MONITORING
- 1. PURPOSE The purpose of this program is to maximize River Bend Power Production by assuring operating conditions are monitored, reported and reviewed in a timely and efficient manner.
- 2. SCOPE Periodic data that reflects the operating performance are provided to the Vice President of Operations. When the reported data indicates a potential decrease in power production, additional inquiry and further management involvement may be warranted.
- 3. RESPONSIBILITIES 3.1 The Vice President of Operations has overall management responsibility for this program.
3.2 The Director of Joint Operations is responsible for the implementation of this program.
3.3 The Technical Operations Manager is responsible for day to day on site implementation of the procedures, review of the data, and providing periodic reports.
- 4. PROCEDURE Operational monitoring performance requires plant accessibility and the cooperation of GSU management.
Understanding of plant operations and the ability to interpret data are essential. Monitoring of a nuclear operation requires the ability to identify priorities and concentrate efforts in areas that will have the largest impact on power production.
Monitoring is performed on four basic levels:
- 1. Daily Plant Operations
- 2. Correspondence / Documents
- 3. Chronic Plant Conditions
- 4. Executive / Management Responses 100231
r 4.1 Daily Plant Operations Monitoring Requires a review of the daily parameters to discern changes in operability of the plant. This data is obtained from daily meetings, control room status board, control room log and discussions with various members of plant staff. Meetings attended, but not limited to, are:
- 1. Maintenance Staff
- 2. Plant Manager's Staff
- 3. Operations Status Attendance of these meetings gives an indication of changes in plant parameter status for the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> such as, but not limited to:
Unidentified Drywell Inleakage Reactor Power Level Various Area / System Limiting Temperatures Shutdown Limiting Conditions of Operation (LCO's)
~ Surveillance Procedure Status Maintenance Work Order (MWO) Status General Plant Conditions From this data, an overall status of the plant is formed and is put into proper prospective, Problems affecting plant operability are identified. The important issues are further evaluated and daily communication made to the Director of Joint Operations to provide the current plant status. If a unit shut down is imminent, a call to the Cajun dispatcher is made to allow time to make any arrangements as necessary. ;
4.2 Correspondence / Document Monitoring l
)
This level of monitoring goes in hand with the daily ;
plant operability monitoring. Documents such as the :
daily plant status report, condition reports, l Independent Safety Evaluation Group (ISEG) reports, outqning and incoming plant correspondence, int <coffice memos, monthly operating reports from several departments, federal register documents, and ,
j several nuclear related commercial documents are l
-s-100232 l 1
I
revieved to identify items that may affect River Bend power production. An assessment is made of management's response to concerns, conditions and/or problems, and, externally, with regulators, commissions and with " lessons learned" from other utilities. Pertinent issues are brought to the attention of the appropriate Cajun Management.
4.3 Chronic / Deteriorated Plant Conditions Monitoring The data from the daily plant operability and document monitoring is tracked to identify any chronic or deteriorating plant conditions over a period of time. Pertinent data is compiled, and if warranted, a special report generated for Cajun Management. Some items become agenda items for the Management Advisory Committee Meetings (MAC) between GSU and Cajun. Issues addressed in the MAC meetings, make GSU VP level fully aware of Cajun's concern and may prompt GSU management to respond appropriately. A two week report is generated to document on-going concerns and conditions.
This level of monitoring includes periodic attendance of Design Engineering Staff Meetings, Facility Review Committee (FRC) Meetings, Nuclear Review Board (NRB) Meetings, Nuclear Regulatory Commission (NRC) Meetings, Project Work Scope Meetings, Special Planning Meetings, etc. Data pertinent to Cajun's interests at River Bend are compiled and reported.
4.4 Executive / Management Monitoring This level of monitoring involves observing how GSU management addresses problems and concerns that will affect River Bend's capacity factor. This monitoring includes a review of the Institute of Nuclear Power Operations (INPO) evaluations, NRC evaluations, Authorized Nuclear Inspector (ANI) evaluations and the Professors Meetings. An overall view of management's ability to address plant problems and identification of GSU's priorities are determined. This data is compiled and sorted. Data pertinent to Cajun's interest is forwarded to the appropriate Cajun Management.
100233
4.5 Management Advisory Committee Meetings Periodically Cajun and GSU management hold a MAC meeting. GSU management addresses Cajun's concerns as requested via agenda. Cajun management asks questions that have been prepared in advance by the Technical Operations Manager, to assure that concerns are properly identified and addressed.
4.6 Independent Experienced Consultant On an as-needed basis, Cajun utilizes the expertise of an experienced, independent consultant to provide Operational Performance Monitoring Program guidance and support as follows:
-Evaluate the impact of technical issues on power production
-Review outage planning, performance and make recommendations for minimizing duration.
-Influence site management to minimize outage duration and maximize power production.
-Recommend MAC agenda items, corresponding questions and attend meeting.
-Make independent evaluations and report on special issues affecting the River Bend investment.
An independent review of the River Bend Operations Monitoring Program is performed periodically and adjustments implemented to improve the effectiveness in achieving Cajun's overall goals.
1 I
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~
100234
MP-002 REV.2 L
CAJUN ELECTRIC POWER COOPERATIVE, INC.
COMPREHENSIVE MONITORING PROGRAM REFUELING OUTAGE PEdFORMANCE JOINT OPERATIONS DEPARTMENT PROCEDURE NO. MP-002 REV.2 l
AUGUST 22, 1989
. 1i WH Approved: Y M ' x .-
- n.
S c
Techni,al Operations Manager Date Approved: hY Y VS f -
rector of Join Operations bate Approved:- es f -
fl20/C 9 Vice President of Operations Date 100235
MP-002 REV.2 CAJUN ELECTRIC POWER COOPERATIVE, INC.
COMPREHENSIVE MONITORING PROGRAM REFUELING OUTAGE PENFORMANCE JOINT OPERATIONS DEPARTMENT PROCEDURE NO. MP-002 REV.2 AUGUST 22, 1989
- M' x 'D S Approved.. - -
Techni' cal Operations Manager Date VS Approved: f rector of Joint Operations Date 1 Approved:
S:%4 k j ehoh9 Date Vice President of Operations l
l l
100235
l l
KEY PRINCIPLES Although Cajun is not responsible f or operating P.iver Bend Nuclear Station, as a large investor, Cajun wants to p_aximize power oroduction (capacity factor) and the return 2D investment which helps both owners. Cajun has already developed a respected professional relationship with GSU by utilizing recognized expertise and displaying a genuine concern to enhance the cost efficient and productive operation.
Capacity factor is the most important power production economic performance indicator. Extended refueling outages are the leading cause of low capacity factors. Cajun recog-nizes that they may impact the length of the refueling outage by follouing well planned steps to encourage GsU to "orenare for" and " minimize the duration of" the refueling outage. Potential impacts on outage schedule and costs are identified early. By asking management questions in a timely manner Cajun may cause GSU Site Management to take they actions to correct potential problem areas before impact outage duration and cost.
PROGRAM
SUMMARY
The objective of this program is to provide the appropriate used for Cajun management with indicators that can be assessing refueling outage performance and efficiency.
Comparison of performance data to recognized goals can be an excellent means of promoting pride, motivation, and desire to improve.
includes the following elements that are This program considered important to an effective joint owner outage performance monitoring program:
-Selection of the data that most effectively monitor !
outage performance in key areas.
-Regular reports of the selected data to key managers and executives, with an explanation of unusual results l and significant trends. 1
-Comparison of outage performance to recognized goals.
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-Review and inspection of selected data to ensure that ,
critical path (or near critical path) activities are l being identified in a timely manner, and corrective actions effectively implemented.
-Periodic outage review meetings.
nuclear
-Utilize an outage experienced independent consultant when necessary.
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i REFUELING OUTAGE PERFORMANCE MONITORING Table of Contents Page
- 1. PURPOSE............................................. 4 SCOPE............................................... 4 1 2.
4
- 3. RESPONSIBILITIES....................................
4
- 4. PROCEDURE...........................................
4.1 Pre-outage Monitoring Plan..................... 5 4.1.1 Activities Monitored.................... 5 4.2 Outage Monitoring Plan......................... 6 4.2.i Activities Monitored.................... 6 4.2.2 Independent Consultant.................. 7 Evaluation Analysis..................... 7 4.2.3 7
4.3 Outage Reports.................................
8 4.4 Performance Review Meetings....................
ATTACHMENT A - Cajun Refuel Outage Monitoring Report.... 9 1
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REFUELING OUTAGE PERFORMANCE MONITORING
- 1. PURPOSE The purpose of this program is to minimize the dura-tion and cost of River Bend's refueling outages.
- 2. SCOPE Periodic data that indicates River Bend refueling outage progress, critical path activities and areas of' concern regarding outage duration are provided to the Vice President of Operations. When the reported data indicates a potential outage extension or adverse trends, additional inquiry and further man-agement involvement may be warranted.
- 3. RESPONSIBILITIES 3.1 The Vice President of Operations has overall management responsibility for this program.
3.2 k'he Director of Joint Operations and Interconnections is responsible for the implementa-tion of this program.
3.3 The Technical Operations Manager is responsible for day to day on site implementation of the proce-dures, review of the data and providing periodic reports.
- 4. PROCEDURE The shift from operational Performance Monitoring to l Refueling Outage Performance Monitoring is accom-plished by a gradually phasing into the outage mode over a period of time, usually six months prior to the start of the outage. The daily outage monitor-ing is performed in an ever increasing amount until :
the start of the actual outage. l Outage work consists of two distinct phases. and The the first phase is the pre-outage planning, ,
second phase is the actual outage work. Monitoring of both phases is absolutely critical to the minor-ity owner for financial reasons. Each of these phases will be discussed separately.
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4.1 Pre-outage Monitoring Plan River Bend pre-outage' monitoring starts with an i initial transitional phase. The first ' series of meetings are usually held six months.in advance of the planned - outage date. These early meetings ' are held to discuss conceptual workscope and costs. It i is at this stage that modifications, ' fuel . receipt logic, and refuel floor work is initially discussed.
Cajun will start monitoring at this stage for input ,
on the front end. ,
t As the workscopa is finalized, schedules produced, !
fuel receipt planned etc., Cajun's involvement shall- ;
i increase. As the outage planning progresses, the individual workscopes become more defined. ,
The . Technical Operations Manager monitors the progress.of the activities and identifies the "hard spots" that are not developing adequately to meet the outage planning schedule. Such problem areas are discussed-with Cajun management and a strategy developad to exert influence-in getting.the problems i resolved. ;
The Cajun representative anticipates problem areas and discusses them with the independent consultant.
The Cajun Evaluation Specialist identifies' cost and schedule impacts associated with these problem areas. These problem areas are then discussed with f Cajun management. A- strategy is developed to influence GSU management to focus their attention on !
corrective actions.
4.1.1 The Technical Operations' Manager maintains a strong site presence by actively monitoring the following activities:
i
-Outage Planning Schedule 2 j
-Scope of Work
-Schedule Development l
-Schedule controls ]
-Budget Controls
-Trending l
-Fuel Receipt Activities
-Engineering and Design
-Material and Equipment
-Manpower and Tool Requests
-GSU Management Involvement 100239
4.2 Outage Monitoring Plan Outage progress meetings are held three times a day.
Daily schedule updates are made to show actual progress. Weekly cost meetings are held to update outage estimates. The Cajun representative and Evaluation Specialist watch these updates closely to determine any impact on the critical path and over-all cost of the outage.
Although The Technical Operations Manager has little affect on the daily physical work in progress, he attempts to identify those critical areas in the and suggests schedule where delays could occur appropriate management attention to the concern.
In the nuclear industry, paperwork can be as important as the physical work because a station cannot restart until the paperwork is up to date with the actual configuration of the plant. The Technical Operations Manager monitors paperwork progress right up to and including the initial rod The Technical Operations Manager pull and startup.
also monitors physical plant outage work in the field.
4.2.1 The Cajun representative maintains a strong site following presence by actively monitoring the activities:
-Outage Progress Meetings
-schedules
-Status Reports
-Fuel Handling
-Local Leak Rate Testing
-Inservice Inspections
-Modifications
-Paperwork Close Out
-Turbine / Generator Work
-Diesel Generator Work
-Surveillance Testing
-Cost Controls
-Preventative Maintenance 4.2.2 Cajun's independent outside nuclear consultant may provide guidance, support and a strong sitemonitoring presence to both the pre-outage and outage activities. During the six month pre-outage period, Cajun historically utilizes the consultant an average of four days per month to provide guidance in developing and implementing the Outage Monitoring Program. This includes telephone consultation with Cajun team members and support at Cajun /GSU outage performance review meetings.
100240
During the refueling outage period Cajun may utilize the consultant an average of ten days per month to provide support in achieving the objective of mini-mizing the outage duration.
This may include a strong site presence during regular and extended work hour coverage, assistance with critical path evaluations and recommendations as well as telephone consultations.
4.2.3 The Cajun Evaluation Specialist provides cost and schedule monitoring and data assimilation support to the Technical operations Manager. During the six month pre-outage period, the Evaluation Specialist meets with site cost and schedule personnel once per week to monitor schedule preparation and outage cost estimates.
During the refueling outage period, the Evaluation Specialist meets with site personnel two or three days per week to review updated schedule and cost estimates.
4.3 outage Reports The report is concise and contains the outage critical path activities. The activities reported on will change as the outage critical path changes.
As appropriate, an explanation of unusual results and significant trends will be included. A summary of outage progress including any recommendations to Cajun management will be included in the report.
ATTACHMENT A is an example of the report format.
4.4 Performance Review Meetings Periodically Cajun and GSU management teams convene a meeting to review refueling outage planning progress. The Cajun team prepares, reviews and asks GSU management questions designed to encourage GSU to take actions to minimize the outage duration and cost.
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I ATTACEMENT A r CAJUN REFUELING OUTAGE NONITORING REPORT RIVER BEND NUCLEAR STATION Outage Week No. O Report Date: 00/00/00 to 00/00/00 I. Critical Outage Activities !
A. Engineering / Design Status B. Fuel Handling C. LLRT'S: ,
D. Modification Requests:
E. Diesel Generator Work:
F. Turbine / Generator Work: ,
II. Projected Incremental Cost:
III. Outage Progress Summary and Recommendations:
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A MP-003 REV.2 l
CAJUN ELECTRIC POWER COOPERATIVE, INC.
NOTIFICATION PROCEDURE.FOR !
EMERGENCY RESPONSE JOINT OPERATIONS DEPARTMENT PROCEDURE NO. MP-003 REV.2 i AUGUST 22, 1989
' N Approved: - j M. f- -
__ ~
Date Technical Operations Manager Approved:
e a Yh , .
f ENf $ j 1 rector of Joint parations Dat6 '
AiEhlA . & F 30 /b'?
Approved: r i Vice President of Operations Date i
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t KEY PRINCIPLES AND PROCEDURAL
SUMMARY
As_a co-owner, it is important that Cajun be notified in the !
event of an accident. Cajun does not operate River Bend, therefore, proper notification is the essence of this i procedure.
The objective of this procedure is to provide an appropriate guideline to the notification process and to explain the series of events involved with emergency response and notification, t
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4 100244
NOTIFICATION OF EMERGENCY RESPONSE Table of Contents Page
- 1. PURPOSE............................................. 3 2 SCOPE............................................... 3
- 3. RESPONSIBILITIES.................................... 3
- 4. PROCEDURE........................................... 3 L 4.1- Notification................................... 4 4.1.1 Who Is Notified......................... 4 4.1.2 Notification Actions Required........... 4 ATTACHMENT - Four Emergency Classifications.............,5 ,
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NOTIFICATION OF EMERGENCY RESPONSE
- 1. PURPOSE The purpose of this procedure is to provide adequate notification to Cajun management in the event of an emergency response at River Bend Nuclear Station.
- 2. SCOPE Periodic drills and associated responses are performed at River Bend Nuclear Station to provide adequate training to personnel. Critiques and eval-untions are performed to reflect weak points for improvement. This practice is to provide proper training in the unlikely event of an emergency at River Bend. A portion of this response is notifica-tion of appropriate agencies such as Cajun.
- 3. RESPONSIBILITIES 3.1 The Vice President of Operations has overall manage-ment responsibility and responsibility to notify, as deemed necessary, other departments and the General Manager in the event of an emergency.
3.2 The Director of Joint Operations is responsible for the implementation of this procedure and supplying additional support as necessary. He is also respon-sible for notification of the Vice President of Operations.
3.3 The Technical Operations Manager or his designee is responsible for responding to the GSU notification and providing notification and information to the Director of Joint Operations in an urgent and timely manner.
- 4. PROCEDURE I
River Bend, as a Nuclear Facility, is required by law to have a proven emergency response procedure.
This procedure is to protect the public in the event I of an accident whereby a radiological release is l deemed possible.
Cajun, as co-owner of River Bend, should be notified in the event of a potential radiological release to the public. River Bend activates its Joint Information Center (JIC) at the Alert Level.
100246
.. . l The four classifications of emergency to any nuclear facility are: Notification of Unusual Event, Alert, Site Area Emergency and General Emergency. The description, characteristics and examples of each of these classifications are attached.
4.1 The JIC activation is the point at which Cajun is notified. The liaison coordinator is a member of the JIC team whose responsibilities include notifi-cation of appropriate state and federal agencies along with other agencies that have a direct interest in River Bend, ie; Cajun. The individual to be notified will have backup individuals in case that the primary contact cannot be reached. The five individuals within Cajun to be notified are as follows:
4.1.1 1. Bill Curran - Nuclear Monitoring Specialist
- 2. Larry Johnson - Technical Operations Manager
- 3. Jack Miller - Director, Joint Operations
- 4. Phil Harris - VP Operations
- 5. Gary Hall - VP & Corporate Controller Notification will be attempted in the order shown, ie; Bill Curran first, Larry Johnson second, Jack Miller third, Phil Harris fourth, and Gary Hall last.
4.1.2 Once notification is established, that individual should make every attempt to notify the other individuals listed. Notification to Cajun upper management will be delineated by Jack Miller and/or his designee as the situation warrants. The primary Cajun Representative notified should immediately proceed to the JIC, located at the training center at River Bend. The Cajun Representative will have access to information and communications at this location. This individual will make all informa- ,
1 tion, when received, available to Cajun management.
It should be noted, however, that GSU is the primary contact for news releases and information provided Cajun is for Cajun's internal use oniv.
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The-four classifications of emergency to any nuclear facility are: Notification of Unusual Event, Alert, Site Area Emergency and General Emergency. The description, characteristics and examples of each of these classifications are attached.
4.1 The JIC activation is the point at which Cajun is notified. The liaison coordinator is a member of the JIC team whose responsibilities include notifi-cation of appropriate state and federal agencies along with other agencies that have a direct interest in River Bend, ie; Cajun. The individual to be notified will have backup individuals in case that the primary contact cannot be reached. The five individuals within Cajun to be notified are as follows:
4.1.1 1. Bill Curran - Nuclear Monitoring Specialist
- 2. Larry Johnson - Technical Operations Manager
- 3. Jack Miller - Director, Joint Operations
- 4. Phil Harris - VP Operations
- 5. Gary Hall - VP & Corporate Controller Notification will be attempted in the order shown, le; Bill Curran first, Larry Johnson second, Jack Miller third, Phil Harris fourth, and Gary Hall last.
4.1.2 Once notification is established, that individual should make every attempt to notify the other individuals listed. Notification to Cajun upper management will be delineated by Jack Miller and/or his designee as the situation warrants. The primary Cajun Representative notified should immediately proceed to the JIC, located at the training center at River Bend. The Cajun Representative will have access to information and communications at this location. This individual will make all informa-tion, when received, available to Cajun management.
It should be noted, however, that GSU is the primary contact for news releases and information provided Cajun is for Cajun's internal use oniv.
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MP-004 REV.0 CAJUN ELECTRIC POWER COOPERATIVE, INC.
COMPREHENSIVE MONITORING PROGRAM JOINT OPERATIONS EVALUATIONS JOINT OPERATIONS DEPARTMENT PROCEDURE NO. MP-004 REV.0 AUGUST 24, 1989 V
,'8. _^-.
Approved: D -
Technical Operations Manager Date SS Approved: f f Director of Joint Operations Date
~
Approved:
Vice [
Prerident of Operations Date 100248
KEY PRINCIPLES The Joint Operations Department is responsible for the coordination of all data flow between Cajun and other com-panies that jointly own generating facilities with Cajun.
The Technical Operations group within the Joint operations Department is responsible for coordinating and monitoring all site related data of jointly owned facilities. This i data is reported to Cajun management to assist in making decisions in regards to jointly owned units.
PROGRAM
SUMMARY
The objective.of this program is to accumulate technical and financial data pertaining to all jointly owned facilities and report this data to Cajun management, with an explana-tion of unusual results, trends and significant implications. The data utilized in this program include:
-Budget and budget variance reports
-Facility performance reports
-Industry reports and statistical data
-Information obtained from co-owner management review meetings 6
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JOINT OPERATIONS EVALUATIONS Table of contents PAGE 3
- 1. PURPOSE..........................................
3
- 2. SCOPE............................................
3
- 3. RESPONSIBILITIES.................................
4
- 4. PROCEDURE........................................
4.1 Budget Preparation and Variance Analysis.... 4 4.2 Monitoring of Cost and Schedule Programs.... 5 Statistical Performance Analysis............ 5 4.3 4.4 Oversight and Industry Interface............ 6 100250
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TECHNICAL OPERATIONS EVALUATION PROGRAM
- 1. PURPOSE The primary purpose of this program is to prepare and evaluate celected operations, budget and cost data, and identify significant changes for management to assist in decision making.
- 2. SCOPE The Joint Operations Evaluations Program include for each jointly owned generating facility: monitoring of performance data; budget development, control, and variance reporting; monitoring cost, financial control, and project scheduling performance; and providing an independent overview of economic impact.
- 3. RESPONSIBILITIES 3.1 The Vice President of Operations has overall management responsibility for this program.
3.2 The Director of Joint Operations is responsi-ble for the implementation of this program.
3.J The Technichl Operations Manager is responsi-ble for day to day implementation of the procedures, review of the data and providing direction and guidance for ongoing tasks.
3.4 The Evaluations Specialist is responsible for the day to day assimilation, analysis, and reporting of data associated with each jointly owned facility.
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- 4. PROCEDURE The evaluation of power plant performance and budget variances requires an understanding of power plant (fossil and nuclear) operations and the ability to data.
interpret both technical and financial Evaluating the performance and cost contrci of a facility which Cajun is a non-operating, joint owner, and requires the ability to identify priorities concentrate efforts in areas that will have the most favorable economic impact for Cajun.
The Evaluation Program is performed in four basic areas:
- 1. Budget Preparation and Variance Analysis
- 2. Monitoring of Cost and Scheduling
- 3. Statistical Performance and Comparative Analysis
- 4. Oversight and Industry Interface 4.1 Budget Preparation and Variance Analysis Requires a review of jointly owned facility total budgets and determining Cajun's share of these budgets. The Joint Operations departmental budget is also established.
This data is communicated to Cajun's Finance Department for incorporation into the corpo-rate budget.
Budget variance analysis is performed on a monthly basis, identifying to Cajun manage-ment variances and potential variances to jointly owned f acility and departmental bud-requires a gets. This type of analysis thorough knowledge of Cajun's and Joint owner's budget proceaa, accounting system and i billing procedures, 1
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