ML20080G949
| ML20080G949 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/08/1995 |
| From: | Querio R COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9502140235 | |
| Download: ML20080G949 (6) | |
Text
..
/N Commonwealth Edison
) kSild County Nuclear St: tion C
O rse he, il no 61341 Telephone 815/3574761 February 8,1995 l
U.S. Naclear Regulatory Comunission Washington, D.C. 20555 1
Attenties:
Document Control Desk
Subject:
LaSalle Station Unit I and 2 Response to the SALP 12 Report I
NRC Docket Nos. 50-373 and 50-374 l
Reference:
J. B. Manin letter to Mr. R.E. Querio dated December 28,1994, transmitting the LaSalle County Station SALP 12 Report Commonwealth Edison, LaSalle County Station) would like to thank you for meeting with us and presenting the SALP 12 Report on January 17,1995, as well as affording us the opponunity to provide our views on the SALP results. This letter provides our response to the SALP 12 Report.
We recognize that our ongoing programs for improvement must continue in all functional areas at LaSalle Station, panicularly in the areas ofMaintenance and Plant Support. We understand the events and issues that contributed to the decline in performance in tiw areas of Security and Emergency Preparedness and have taken the actions necessary to halt their decline and re-establish an improving trend.
Station reviews in the areas of source term reduction, radiation protection practices, root cause analysis, materiel condition, preventive maintenance weaknesses, and the self assessment process have been conducted. Actions which are in progress or planned are discussed in the attachment to this letter. To address our poor plant response to Site Quality Verification (SQV) issues, SQV has established teamwork meetings with the Radiation Protection, Operations, and Regulatory Assurance Departments. Problem i
identi6 cation Form (PIF) causal factors are now in a database, and trend chans have been developed and are currently in use.
LaSalle County Station agrees with your assessment of the strengths and I
weaknesses associated wiith our overall performance. I can assure you that I am personally
. involved in the improveme:nt processes and that everyone at LaSalle understands the necessity of accomplishing our mission ofimproved performance in all areas.
9502140235 950208 40 PDR ADOCK 05000373 Q
PDR l
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. If there are any questions or comments concerning this letter, please refir them to me i
at(815)357 6761, extension 3600.
F v 'd'y,
/.
'k. E. Querio i
Site Vice President LaSalle County Station cc:
J. B. Martin, Regional Administrator, Region III W. D. Reckley, Project Manager, NRR P. G. Brochman, Senior Resident Inspector, LaSalle D. L. Farrar, Nuclear Re damry Services Manager, NORS Central file i
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11-Attachment SALP 12 REPORT 50-373(374)/94001 OPERATIONS:
The overriding focus of Operations is on reinforcing concepts of safe and conservative plant operation, during both normal plant operations and refueling outages. A number ofinitiatives are underway and planned to aggressively promote and reinforce this philosophy among operators, including seminars to be conducted by the BWR Site Vice Presidents on conservative Maian --Wg. with cross sectional attendance by operators l
ikom all three of Comed's BWR plants. Increased involvement of Operations personnel in the Work Control Center (WCC) process will continue to enhance focus on safety and proper work prioritization.
f Materiel Condition will be a major station focus for 1995. A Top 5 List has been created, which contains a discrete number of short-term actions, to resolve materiel condition problems identified by operators and other station personnel. In addition to an overall reduction in the level of tolerance for degraded equipment, this effort is aimed at reducing the unr-y challenges encountered by operators during plant transients. A newly formed Materiel Condition Focus Team reporting to the Operations Manager will i
monitor and facilitate resolution of these top issues identified by the line organization.. A l
Scram Frequency Reduction Committee has been formed to address the high number of i
scrams experienced during the last SALP period and to address future issues through l
contact with the BWR Owner's Group Scram Reduction Committee. Operating Department personnel and SQV staff are working jointly to formulate timely and effective responses to SQV issues MAINTENANCE:
i Preventive Malatemance - A major effort is underway to improve the Preventive i
Maintenance program. A Preventive Maintenance Team consisting of maintenance and engineering personnel has been established. The initial goal of the team is to perform a comprehensive review of systems requiring preventive maintenance tasks, especially large pieces of equipment, to provide value added maintenance. The focus is clearly on component problems within plant systems to ensure the proper Engineering and Maintenance focus on equipment reliability. The recently installed Electronic Work Control System (EWCS) allows the System Engmeer to more effectively review and trend Maintenance Work History. This information will be used to compare actual performance against existing preventative maintenance practices, so that equipment reliability performance improvements can be made.
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.4 Attachment SALP12 REPORT 1
50-373(374)/94001 I
Materiel Condition - Aggressive goals have been established for reducing the Nuclear Work Request (NWR) backlog. In addition, a Radwaste Materiel Condition Improvement Group has been fonned and will continue the accelerated efforts of reducing the NWR backlog in this area. System Engineering has recently developed a maintenance work history computer program The program is being used to trend equipment performance and allow the System Engineers to initiate proper corrective actions to improve equipment reliability. The System Engineers provide Maintenance with recommendations and also report results of the review to upper station management during the System Readiness Review Board presentations.
Work Practices - Planning, scheduling,and execution weaknesses are being addressed through the recently irr.plemented Work Control Initiatives and Maintenance Strategies.
Work teams walkdown ui review work packages three weeks prior to execution to improve the quality of the planning effort and to reduce work delays. The Work Control Center (WCC) is now monitoring maintenance work milestones.
First Line Supervisors and other managers have recently been involved with estabhshing and implementing higher standards involving their responsibility for maintaining the training programs associated with good maintenance performance Foreign Material - A Foreign Material Exclusion (FME) program manager position has been established. The FME procedure has been revised to identify clear expectations and responsibilities. The FME program manager and first line supervisor (FLS) routinely walk downjobs in progress to evaluate performance. FME guidelines have been developed and provided to all Work Analysts. The pre-job briefmg attachment includes a FME discussion section for use by the FLS with the crew.
Engineering:
Materiel Condition - The Top Technical Issues provides long term system action plans Creation of the Materiel Condition Group combines trending, problem detection, root cause evaluation, and effectiveness review in one functional area. A facilitative task force i
for materiel condition improvement has been formed to accelerate the pace of accomplishing work and resolving long standing materiel condition problems.
Corrective Actions - The Engineering culture is changing to no longer accept the status quo on issues and to move forward to World Class problem solving. Engineering no longer tolerates overdue items. An aggressive approach to addressing all NRC Generic Letterissues has been taken.
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e Attachment SALP12 REPORT 50-373(374)/94001 Plant Support:
Radiation Worker pesforniance - Increased management emphasis on high radworker standards, and an extended NGET course that includes mockup training, have been implemented to correct the inconsistent performance in radiation worker practices. An ongoing effort to upgrade and clarify radiological postings in the plant is in progress.RP h'-- ;w is interacting with work groups, in informal settings, to identify their concerns and to clarify radworker expectations.
Source Term Reduction - The chemical decontamination of reactor recirculation piping, the L2RO6 RHR chemical decontamination, zinc injection, and the hydrotazing oflines that contribute to general area dose rates are part ofour ongoing efforts,to reduce and control the high radiation source term that has plagued LaSalle in recent years.
Dose Control /Alara - Additional information is being placed in the plant to assist workers in maintaining dose ALARA. An increased use of cameras and remote monitoring devices has resulted in a substantial dose reduction. The successful chemistry pilot program to reduce worker dose during routine tasks has been extended to the Operating and Security groups. Reduced exposure has been achieved for operators doing rounds and routine surveillances. An ALARA planner has been assigr.ed to the Maintenance Group to assist Maintenance Supervisors in identifying opportunities for dose reduction.
3 Eanergency Preparedness - An ongoing upgrade of the emergency response facilities has resulted in significant improvements. An action plan to correct outstanding SQV identified weaknesses has been initiated with many items completed. A dedicated individual has been assigned to the EP Group with single ownership of the EP training program and tracking ofpersonnel qualifications.
Chemistry - Self-assessment has been augmented by the chemistry department writing departmental field monitoring reports and problem identification forms. They are being tracked and trended in a work assignment database.
Post Accident Sampling System (PASS) priorities have been raised and maintenance has been performed on long standing problems.
Plant water chemistry continues to be maintained below historical values and i
approaches industry average value during steady state operations. New resins in Radwaste have improved recycle water quality, Make-Up Demineralizer(hmD) resin has been
4 Attachment SALP 12 REPORT 50-373(374)/94001 r"M to improve eSluent quality, and Condensate Polisher (CP) resin replacement is now based on reactor water quality. Seventy condenser tube leaks were plugged during the last refuel outage and the scope of condenser eddy current testing during future refuel outages will be consistent with industry practices Seemdty - An assessment of Fitness for Duty oversight weaknesses was conducted by the Corporate Fitness for Duty and Site Quality Veri 6 cation departments. All identified weaknesses have been corrected. The security check - in form has been revised and an independent verification of all background screening information is performed prior to badging an individual. Control of specimen samples has been changed to use a dedicated Airborne Express deposit box and specimen mailers specifically designed for this box.
Fitness for Duty lab technicians have been instructed in the chain of custody procedure and the use of the new box and mailers.
LaSalle recognizes there were some significant communication problems between the Station and the Security Force regarding the implementation of the watchman j
program. The LaSalle Security Administrator's office is now communicating with the j
Resident NRC Insper tor and Region III Safeguards Inspectors on a regular basis.
The revision to LAP 100-26, "Special Investigation Guidelines" ensures both the ShiA Engineer and the Lgalle Operations Duty Officer immediately notify the Security l
Administrator whenever the appearance of tampering or willful misconduct is identified. In l
addition, the procedure was further revised to include NRC guidelines on investigating events which involve tampering or willful misconduct.
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