ML20082Q405

Responds to NRC 950217 Final Customized Insp Planning Process (Cipp) Assessment Repts 50-334/94-81 & 50-412/94-81 Re Program Weaknesses.Corrective Actions:Mgt Involvement in Plant Operations Has Been Strengthened

ML20082Q405
Person / Time
Site:	Beaver Valley
Issue date:	04/24/1995
From:	Cross J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9504280185
Download: ML20082Q405 (6)

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Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50 334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 CIPP Assessment Report 50-334/94-81 and 50-412/94-81 By letter dated February 17, 1995, the NRC transmitted the final Customized Inspection Planning Process (CIPP) Assessment Report for Beaver Valley Power Station.

In this letter, the NRC requested a reply to the weaknesses noted in the report including the slow response to equipment and personnel performance problems which was  !

identified as a significant program weakness. Attached is our reply which summarizes the corrective actions that have been or are being taken in the areas of management involvement, human performance, problem identification, problem analysis, problem resolution, end programs and procedures.

It is our intent to continue to utilize the results of the CIPP Assessment to enhance the efforts presently underway to improve the performance of equipment and personnel at the Beaver Valley Power Station. Results to date have shown improvement in plant reliability and refueling outage performance for both units.

If there are any questions concerning either this response or our corrective actions, please contact me at (412) 393-5255.

Sincerely, daff h Y us k James E. Cross Attachment c: Mr. L. W. Rossbach, Sr. Resident Inspector Mr. T. T. Martin, NRC Region I Administrator 00AiITY Mr. D. S. Brinkman, Sr. Project Manager ENERGY Mr. W. D. Lanning, Deputy Director, Division of Reactor Projects, Region I 9504280185 950424 PDR ADOCK 05000334 g PDR

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[ DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Power Station ATTACHMENT Reply to the Customized Inspection Plannine Process (CIPP) Assessment Report Duquesne Light Company (DLC) has performed a review of the final CIPP report -

transmitted by letter dated February 17,1995. DLC agrees with the overall conclusion of the report which indicates that both Beaver Valley units are being operated safely.

The report also noted that safety focus performance was generally good and that program strengths included emergency preparedness, effluent. and chemistry control, plant operator response and Engineering Assurance Group assessments. In addition, the self-assessment conducted by the plant review team was noted to be a thorough introspective review of management style, organization, and site programs. Corrective actions for problems identified by this self-assessment were noted to be completed or in progress at the time of the CIPP assessment.

However, overall performance in the area of problem identification, analysis, and resolution was perceived as weak. The response -to _ equipment - and personnel-performance problems was identified as being slow and a significant program weakness -

that warrants management attention.

DLC has reviewed specific weaknesses and areas for improvement noted in the CIPP-report and has established actions to strengthen or enhance performance in these program areas.

In response to the identified overall concern and significant program weakness, the actions being taken by DLC in the following areas are summarized below: Management Involvement, Human Perfonnance, Problem Identification, Problem Analysis, Problem Resolution, and Programs and Procedures.

Manacement Involvement Management involvement in plant operations at . Beaver Valley has been strengthened.

The daily meetings are now chaired by the Plant Manager with participation by site management. These meetings direct plant activities while allowing management to maintain an oversight of plant status and an awareness of specific issues. This enables the early identification and efTective resolution of emergent issues. Vice Presidents' expectations regarding management involvement in assuring timely and effective corrective actions have been, and continue to be, crmmunicated to personnel. ' The importance of maintaining work standards, along with personnel accountability for meeting these accepted standards, continues to be reinforced through plant walkdowns and management oversight of work activities. Other areas where management involvement has been strengthened are identified in the appropriate sections of this reply.

Attachment Reply to CIPP Report Page 2 To ensure that future objectives are clearly defined, the Nuclear Power Division Business Plan has been upgraded to include the identification of the Beaver Valley Power Station's top ten issues along with a five-year plan to address the Division goals and objectives. Management will be held accountable to meeting Business Plan objectives. These objectives will be reviewed periodically and, where deviations are identified, corrective actions will be applied accordingly.

Human Performance Each department has developed and implemented a human performance improvement plan. Elements of these plans include self-checking, procedure compliance, and attention to detail.

A self-checking program was developed by the Instmment and Controls (I&C) section of Maintenance to reduce human performance errors. Maintenance, in conjunction with the Training Department has initiated an ongoing effort to evaluate the effectiveness of self-checking. Thus far, self-checking has resulted in a significant reduction in events involving human error by the I&C technicians. Proper use of self-checking techniques will continue to be emphasized through communications meetings and through direct supenisory interaction in order to expand on the successes achieved by the I&C self-checking program.

Emphasis will be sustained on ensuring procedure compliance through increased attention to meeting established standards and utilization of self-checking techniques. To enhance the ongoing communication and reinforcement of standards, Maintenance has instituted a Maintenance Supenisory Surveillance Program to ensure supenisory oversight and communication of standards. Additionally, Operations conducts supenisory tours which reinforce standards of performance to operators. Senior management tours of the facility are conducted on a regular basis to review conformance to expectations.

In order to monitor human performance in the Nuclear Engineering Department, Engineering Assurance performs reviews of in-process work activities to identify attention-to-detail concerns and other technical and administrative deficiencies in modification packages, procedure revisions, design analyses, technical evaluation reports, and engineering memoranda. Timely feedback from these in-process work reviews is provided to the personnel performing the work activities. The results of these efforts are being trended for Engineering management review and corrective actions where appropriate.

Management has focused attention on human performance deficiencies that have been identified by the Operations Experience Department (OED) through the tracking and trending program.

.- c' Attachment Reply to CIPP Repon Page 3 Problem Identification The threshold for the initiation of Problem Reports has been lowered to allow timely identification of precursors to more complex issues. The number of plant Problem Repons has doubled since the threshold was lowered, thus allowing improved visibility and better evaluation of equipment and human performance areas. Management monitors this system and, when appropriate, directs plant personnel to identify potential issues through the generation of Problem Reports.

The Quality Services Unit (QSU) has streamlined the method for identifying and tracking QSU-identified concerns through the use of Deficiency Repons as the sole ,

vehicle for reporting audit, M.,pection and surveillance related deficiencies. Various I types of problems are now included in one reporting system, thus improving management's ability to monitor for programmatic trends and identify potential quality ,

I issues.

Periodic plant inspections are conducted by management personnel from the Nuclear Operations Group as specified by a site administrative procedure. Results of these inspection tours are provided to personnel responsible for the specific plant areas for timely correction. This program provides a vehicle for Nuclear Operations management to communicate management standards to supervisors responsible for each area of the plant. Some of the results of these efforts to date are improved conditions in various I plant areas including the Unit Control Rooms, Unit 1 Diesel Generator Rooms, and the Turbine Basement. Supervisony involvement with work activities has also increased. (

Such involvement provides further opportunity for problem identification and standards j reinforcement. )

Problem Analysis A new root cause analysis system (Taproot) was recently implemented at Beaver Valley which is similar to the system described in NUREG/CR-5455. By replacing the multiple root cause analysis systems previously in use at Beaver Valley, the Taproot system will provide a unifonn method for conducting root cause evaluations. Personnel in various departments have been trained in this new analysis technique and additional personnel will be trained in 1995. This root cause analysis method can be used independently, or in conjunction with the Problem Repon system, and is performed for all significant plant events as defined by site administrative procedures.

Further improvements in the application of root cause analysis techniques to events involving human performance deficiencies have been identified. Management will maintain an overview of the process to ensure that human performance events are investigated adequately and analyzed in a timely manner. The results of human perfomiance event evaluations will be monitored by OED to crsure consistency and to provide recommendations for ongoing program enhancements.

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- Attachment Reply to CIPP Report l Page 4 1 The analysis of Problem Report trends has been enhanced to improve identification of ,

! equipment and human performance areas requiring additional attention. Corrective actions are evaluated and assigned as appropriate. Trend reports will be issued quaderly l l

for management review beginning with the first quarter of 1995. In addition, Deficiency Reports are also trended by Quality Services. These trends are monitored by management and ORC subcommittees as part of their evaluation of overall performance.

Self-assessments of specific programmatic or work activity areas are being used to I l improve performance. A self-assessment administrative procedure has been developed  !

to provide guidance on conducting self-assessments and follow-up resolutions. A site- I wide schedule for self-assessments was developed and implemented in 1994. This has  !

I resulted in an increased number of self-assessments being performed. These self-  :

assessments have identified areas requiring improvement, enabling appropriate actions to be taken. 1 An effectiveness review of the implementation of the Taproot analysis methodology is planned by Quality Services during the last half of 1995. Also, QSU has incorporated  ;

the effective utilization of problem reports and self-assessments into current audits being conducted as part of the ongoing QA audit program.  !

Problem Resolution Management has stated its increased expectations regarding the timeliness and effectiveness of corrective actions, and these expectations will continue to be emphasized to site personnel. Administrative procedures have been revised to reflect management's expectations by requiring senior management approval for proposed long tenn due dates or extension requests for due dates relating to responses to QSU Deficiency Reports. Increased emphasis has been placed on the timely close-out of l overdue corrective actions.

l Appropriate performance indicators are being established for key areas of plant support responsibilities. Examples include corrective and preventive maintenance, operating perfonnance trends, and Nuclear Engineering plant support effectiveness. Also, QSU is providing performance indicators on the timeliness and effectiveness of responses to QA l Deficiency Reports and evaluating performance indicators for site groups during the l audit process. Preliminary results for the first quarter of 1995 indicate improvements in the timeliness and effectiveness of responses to Deficiency Reports.

As a result of monitoring performance indicators, the status of various work activities is receiving greater attention by station groups. When performance indicators show undesirable results, corrective actions are identified and implemented. Management will continue to monitor backlogs to ensure that efforts are effective in addressing problems and maintaining backlogged items at an acceptable level. As an example, the Maintenance Programs Unit (MPU) has recently focused an effort to reduce commitment

f . ,o c Attachment Reply to CIPP Report Page 5 open items backlogs. Corrective actions associated with QA and OEb action items are receiving increased attention for evaluation and action. Progress toward completion of these corrective actions is being monitored by MPU management.

To reduce the backlog of industry and site operating experience open items, OED is

issuing a monthly open items report. This report is being used to manage the resolution of operating experience activities. A self-assessment to monitor the effectiveness of this program has recently been completed by OED, and an action plan is being established to address the identified areas for improvement.

l Programs and Procedures To address areas of weak program performance, upgrades have been or are being made to the following programs: motor operated valves (Generic Letter 89-10), inservice testing, erosion / corrosion, river water / service water (RW/SW), and heat exchanger monitoring. Improvements to these programs have already been observed as evidenced by the completion of several modifications to the river water system, extensive inspections of RW/SW piping, and completion of the Unit 1 GL 89-10 MOV testing program during the Unit I tenth refueling outage.

An MPU supervisor has been assigned to chair a task force established to provide increased attention to the review of RW/SW problems and ensure prompt and effective close-out of identified issues. This group is also performing a review of RW/SW corrective action., being taken in response to the SWOPI self-assessment conducted at Beaver Valley. A final overview of SWOPI issues resolution is planned by QSU following the implementation of corrective actions.

Specific deficiencies noted in the areas oflube oil analysis, maintenance work requests, clearances, cold weather protection and Recirculation Spray Heat Exchanger problems 4 have also received increased attention and corrective actions are complete or in progress.

I Beaver Valley continues to focus attention on improving procedure content through the established procedure review and revision process. This includes the ongoing Procedures Upgrade Program (PUP) which has resulted in the revision of over 4,500 procedures. Current PUP actions are concentrated on revising the most significant  ;

procedures from a plant reliability standpoint.  !

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