ML20081A062
| ML20081A062 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/24/1984 |
| From: | Bernard Thomas COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 8066N, NUDOCS 8403050002 | |
| Download: ML20081A062 (11) | |
Text
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[D) one First National Plaza, Chicago, lihnois Commonwrith Edison k O
'"7 Address Reply to: Post Othce Box 767
\\j Chicago, llhnois 60690 February 24, 1984 M INCIPAL STAFF V
Mr. James G. Keppler URA
, M Stg Regional Administrator RC nug U.S. Nuclear Regulatory Commission
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Region III WA-799 Roosevelt Road ENF Glen Ellyn, IL 60137 Fi le A3
Subject:
Quad Cities Station Units 1 and 2 Performance Improvement Program NRC Docket Nos. 50-254 and 50-265
Dear Mr. Keppler:
During an enforcement conference with you and your staff on January 24, 1984, concerning a secondary containment event at the Quad Cities Station, the Commonwealth Edison Company (CECO) committed to document its specific " Regulatory Improvement Program" for the station.
This program has been instituted there in addition to those measures outlined in CECO's system-wide Regulatory Performance Improvement Plan, described by separate cover.
It encompasses the actions Ceco presented to you at the enforcement meeting and is detailed in Attachment A to this letter.
The Program was initiated by station management as a response to its 1983 regulatory performance.
CECO corporate management approved its development and made available to the station the resources necessary to achieve its objectives.
The program implements basic changes in the practices and structure of the station's operation.
It is designed to include not only specific solutions to particular problems but also to act as a broad commitment by station personnel to efficient and safe performance.
The following is a brief outline of the program, including the dates by which it is intended that the various components will be completed:
)
1 Part One - Short Term Actions 1.
Review of " Conduct of Operations" February, 1984 Directive 2.
Work Request Traveler March 31, 1984 3.
Training on Comrr.unications March 31, 1984 4.
Qualified Nuclear Engineer August 31, 1984 Coverage D
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Keppler February 24, 1984 Part Two - Long Term Actions 1.-
New Communications Center January 1, 1985 2.
Additional Shift Foremen June 30, 1984 3.
Increased Quality Control August 31, 1984 Presence 4.
Expansion of Quality Control August 31, 1984 Department Part Three - Communications (already implemented)
To provide a prospective of all the initiatives taken at the Quad Cities Station during the past year, we are also enclosing with this letter an attachment summarizing the corrective actions taken by the station in response to a control rod insertion error (Attachment B).
If there are any questions regarding this transmittal, please contact this office.
Very truly yours,
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Bide Thomas Executive Vice-President im 8066N
ATTACHMENT A The Quad Cities Regulatory Improvement Program Part One - Short Term Actions 1.
Review of " Conduct of Operations" Directive A team from Edison's corporate office has reviewed, at the station, the Quad Cities shift operations against the corporate Nuclear Station Directive " Conduct of Shift Operations".
This team spent several days observing all phrases of Shift operations, including the back shifts, and reported their findings to the Division Vice President on February 14, 1984.
The findings are being evaluated to determine if any actions are necessary.
2.
New Work Request Traveler A new " Work Request Traveler" form will be prepared and attached to each safety-related work request beginning February 29, 1984.
The traveler will provide a checklist of questions and items which need to be addressed in order to complete each safety-related maintenance activity.
The traveler will assure that every work request is uniformly reviewed before, during and after the work is performed.
l It is also intended to flag changes in the scope of work that might alter any testing requirements.
This would permit the Operating
-Engineer to reevaluate any test that he had originally requested.
In sddition to the new traveler, the Shift Engineer's, SCRE's, and Shift Foreman shall each receive additional training on the station' work request system.
This training will focus on the reviews, sign-offs, and role that the S.E., SCRE, or S.F. must
-perform to assure work is completed correctly and safely.
This training will be completed by March 31, 1984.
3.
Improved Communications Training The Station Training Department will develop a training guide and train all operating personnel in proper, formal communication techniques.
This will then be incorporated into new operator training and retraining program.
Initial training will be completed by March 31, 1984.
4.
Qualified Nuclear Engineer Coverage A Qualified Nuclear Engineer (QNE) will be available in the control room during major control rod movements.
The QNE would be present during scheduled startups and shutdowns and whenever the Shift Engineer requests his presence.
This program will continue for the next six months.
At the end of the six month period the program will be evaluated and decisions made on any further continuation of the programs.
i' s ~
Part Two - Long Term Actions 1.
Communications Center The station will establish an Operating Department Communications Center.. This involves not only increasing the station's staff to man the Center but also constructing' space for ic adjacent to the present Shift Engineer's office..The Center would function similarly to a division load dispatcher's' office, coordinating operating activities associated with the station.
It is contemplated that a number of activities would be assigned to this Center, including the scheduling of all out-of-service /
return-to-service activities of the station.
Visual status of all
. major systems will'be maintained by the Center and along with
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specific plant log books and drawings.
The Center will provide space for operating personnel allowing for better communications.
2..
Additional Shift-Foremen The Station will assign-two Shift' Foremen to each shift.
Its goal is to provide each shift with enough SRO manpower to absorb some of the work load currently handled by both the Shift Engineer and SCRE.
The Shift Engineer-on each shift needs to be more involved with'all. aspects of station operation in~an " overview" capacity.
He must be more involved with Maintenance, Rad Protection, Rad Waste, and. contractor activities.
At the same time, two Shif t Foremen will alsoLallow the Station to perform a double verification of all return-to-services and valve manipulations as a result of operating surveillances.
The double-verification will be implemented in conjunction with.the two Shift Foremen on'each shift.
Assuming successful licensing of personnel, this goal will be ' accomplished by LJune 30, 1984.
3.
Increased Quality Control Presence The Quality Control' Department shall have a' representative on-site whenever maintenance activities are being performed at the Station.
This will allow input to be made on-the-spot when maintenance activities require it.
Implementation of this is expected by August 31, 1984.
I
. 4.
Expanding of Quality Control Department The Station's Quality Control Department will be staffed so as to provide for an inspector available to audit the quality of station operations.
The audit function will include items such as all operating department shift turnovers, equipment attendant rounds, surveillances, out-of-service and return-to-service work, communications and control room operations quality.
This auditing will require written reports submitted directly to the Assistant Superintendent of Operating.
It is expected to begin by August 31, 1984.
It should be noted that at the January, 1984 meeting, the Quad Cities Station had committed to Region III to increase the presence of the Operating Engineer at the plant and to provide him with assistants.
This commitment is now being met through the implementation of the Station Senior Management Overview Function which is part of the corporate Regulatory Performance Improvement Plan described under separate cover.
Part Three - Communications The station has instituted a regular series of informational meetings and job coaching sessions designed to open communication channels to all station employees.
The meetings both disseminate information to employees from management and solicit from employees their comments regarding their own performance and the plants operation.
The job coaching sessions consist of private interviews between supervisors and subordinates, where the subordinate is able to express his feelings about his job to his supervisor, and at the same time, receive guidance as to what is expected of him and how well he is performing on the job.
The goal of these exchanges is to cultivate an atmosphere of teamwork and cooperation throughout the plant.
The following is a brief description of the types of activities that are intended to take place:
1.
Each department head should attend a department meeting at least once every two weeks.
The meeting will be informational in nature; however, questions and comments on any subject will be solicited from department members.
2.
The department heads should meet with their work group leaders at least every two months.
The purpose of these meetings will 1
be to provide information as well as allow feedback from the supervisors on problems or questions.
l 1
a
-4 3.
The Assistant Superintendents should meet with their department heads at least on a weekly basis.
The purpose of these meetings will be to communicate on department problems and provide information and progress reports on department projects and goals.
4.
The. Station Superintendent should meet with the Assistant Superintendents and Department Heads on a weekly basis.
-5.
The Superintendent should attend a Department Head's meeting with these supervisors or group leaders at least once a quarter.
6.
The Station Superintendent should attend a department meeting at least once a month on a rotating basis.
7..
Each station management person should participate in a job-coaching session at least once a year.
This job-coaching will not coincide with annual salary review.
8.
Each station bargaining unit employee should participate in a job-coaching session with their foreman or Department Head within~the bounds of their Collective Bargaining Unit agreement.
9.
- The Station Superintendent, the Assistant Superintendents, and the Department' Heads, should make'themselves available to attend any other department's meeting as requested.
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1:0.
All available station employees will attend an annual station meeting coinciding with the annual station safety meeting.
Corporate office ~ members will be invited to attend this meeting.
The purpose of this meeting will be to promote safety, review the station's performance over the past year, and discuss station goals for the upcoming year.
Each of the meetings and job-coaching sessions will be documented by minutes or a coaching review form.
This documentation will
. include items-discussed, as well as responses or resolutions to questions and suggestions.
8066N-
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w ATTACHMENT B 1983 Initiatives:
The Response to the Control Rod Insertion Error On March 11, 1983 a Quad Cities control room nuclear engineer discovered that an error had occurred in the control rod insertion which had'been implemented the night before.
The event involved not only technical problems but raised questions about personnel performance.
This report outlines both the immediate and long term actions taken by the station to correct the error and the subsequent communication program developed by the station management during 1983 to supplement those corrective actions.
These measures reflect both station management's understanding of the significance of the deficiencies which gave rise to the incident and a firm intention to foster, in all plant personnel, conduct consistent with a safe and error free operation.
Personnel Performance Actions Upon discovery of the error station management contacted personnel on all control room shifts to inform them of the incident and emphasize the necessity of following procedures.
Within 3 weeks of the event, the Acting Lead Nuclear Engineer and the Operation Assistant Superintendent conducted several intensive training sessions for all control room personnel.
At these meetings, the Operating Assistant Superintendent discussed the significance of the incident and emphasized the serious concern over its occurrence.
He explained the role of personnel accountability for all control room actions and the necessity of maintaining complete and adequate logs.
He stressed, among other things, the necessity for complete adherence to written procedures and the_need to investigate the reasons for any deviations between the procedures and events as they actually occurred during operation.
These training sessions also included a review of the procedures pertaining to low power sequencing constraints (banked position withdrawal sequence rules),-rod drop accident considerations for startups and shutdowns, and proper use of the rod worth minimizer (RWN).
Special attention was given to the delineation of shift and technical personnel responsibilities and the importance'of adequate communication of items affecting the reactor during shift turnover.
The Station Superintendent also attended several of these meetings to add his input and enforce the importance of this effort.
On a long term basis,-these kinds of meetings were developed into-part of the Quad Cities Regulatory Improvement Prcgram, discussed in Attachment A.
As part of this program, the Station Superintendent himself conducted a series of meetings beginning in August, 1983, with various plant personnel, directed at improving employee performance.
The following are offered as examples of types of these Superintendent involved meetings:
Control Room Personnel - On August 25-26, 1983, the Superintendent met -individually with the control rod insertion error.to discuss:
=A..
Their involvement in the error B..
The importance of attention to detail 1C.
The need to closely follow procedures D.
Accountability for. actions Plant-Wide Meetings - The Superintendent also attended departmental meetings on the following dates to discuss the control rod insertion event and other items:
A.
August 25, 1983 Maintenance (Em, HM & IM)
'B.
August 31, 1983
. Clerical C.-
September 1,'1983 Rad Chem D..
September 1, 1983 Fuel Handling E.-
September 1,-1983 Stores F.-
September 1, 1983-Training t
G.
September 1, 1983
'Stationmen H.
. September 2, 1983-
' Night Shift Maintenance I.
September 6, 1983 Tech Staff J.
September; 6,11983-Quality Control K.
October 4-5, 1983 Operating
- Department Head Meeting 3 - The-Superintendent held 10 sessions
.with his-department. heads.to discuss:
i.
A.
Responsibility for changes to non-safety related mod drawings (August 15,11983)
B.-
Unit 2 Refueling Outage (August.22, 1983)
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C.
Control of chemicals-within the plant (August 29, 1983) 1D.. Categories of chemicals inLplant (September 12, 1983)
E.
- NRC meetings and the need for improving communications in station
-(October;24, 1983)
.F.
Improving station parformance (October-31, November 1, and November 7,11983):
-G.
Programs for new employees-(November 14, 1983)-
H._-Implementation of programs for chemical control (November 28, 1983)
Union ~ Meetings - The Superintendent conducted three meetings with union
[
officials including sessions;with the Unior President, the Union
- Vice-President.and Chief Steward, and meetin93'with all the stewards.
At these meetings he sought the union's help'in improving the station's performance, employee; attitude, and moral.
. The above items are' examples of. meetings.by the Superintendent He
- also. conducted ' numerous one-on-one meetings with his assistants, Department. Heads, and other station. employees.
. In parallel to the Superintendents activities, his assistants and their Department Heads have held their own department and group meetings.
These are now part of the sessions scheduled under the Quad Cities Regulatory Performance Improvement Program.
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l PROCEDURE REVISIONS INVOLVING EQUIPMENT The incident renewed the Station's concern about the functioning of the RWM during startup and shutdown periods.
Both the NRC and the Edison investigations disclose that on account of the unreliability of the RWM in the past, control room personnel during the incident discounted indications it provided that the rod sequencing order may have been incorrect.
To prevent such misinterpretations and the strengthen the reliability of~the RWM, procedures for the use and bypass of the RWM have been revised.
Other existing procedures, such as startup, shutdown and associated checklists, were expanded to reference the new RWM operability and rod insertion steps.
In addition to these procedural changes, the Station has initiated an investigation into the design and operation of the RWM by Edison's corporate Station Nuclear Engineering Department
-(SNED).
On a short term basis, SNED is examining indications which identify the operability and non-operability of the RWM in all of its required roles.
On a long term basis, the investigation will recommend improvements in RWM hardware and/or software.
8195N
i PROCEDURE REVISIONS INVOLVING CONTROL ROOM CONDUCT In analyzing the events of the control rod insertion incident, two areas of concern were ascertained.
The first involved general concepts of control room conduct; the second dealt with specific practices and methods of operation pertaining to systems
' evolution and control rod movement.
Procedures relating to both these areas were examined to determine the kinds of revisions which could forestal'. the recurrence of this or other incidents.
Several of the procedural changes implemented at Quad Cities were later adopted, at all operating stations.
In terms of general control room conduct, procedures and practices were reviewed and rewritten to improve the quality of interpretation, to foster adherence to all procedures and to enhance communication among control room personnel during shift turnovers.
A new " Conduct of Shift Operations" procedure has been devised to provide an authoritative reference on general standards for responsibilities of control room personnel, communication of information during and between shift operations and procedure interpretation.
This station procedure was reviewed by corporate management and led to the development of a corporate directive for all CECO stations.
The station also revised the shift turnover procedures for Shift Engineers, SCRE/ STAS, and Operators to clarify and define the shift turnover responsibilities of each.
Concurrently, Edison's General Office required all stations to review such procedures to ensure the existence of guideline " checklists", explicitly listing the kinds of data to be communicated between shifts and establishing minimum levels for the exchange of information.
Again this, review led to the development of a corporate directive for all CECO Stations.
Extensive procedural changes were also implemented at Quad Cities to improve procedures governing those aspects of control rod insertions which gave rise to the incident.
As a result, a completely new procedural system for control rod movements and sequences and their documentation is being instituted which totally revised rod insertion sequence procedures.
8195N
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