ML20133C579
| ML20133C579 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/30/1996 |
| From: | Jamila Perry COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| JSPLTR#96-0247, JSPLTR#96-247, NUDOCS 9701070236 | |
| Download: ML20133C579 (10) | |
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Comm mwraith Elison Q>mpany Dresden Generating Station 6500 North Dresden Road Morris, IL NH 50 Tei siv>u2920 December 30,1996 JSPLTR #96-0247 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Dresoen Station Units 1,2, and 3 Dresden Station improvement Plans and Progress i
NRC Docket Nos.50-010. 50-237. and 50-249 1
References:
a.)
J. Stephen Perry letter (96-0068) to USNRC dated May 8,1996 regarding Dresden Station improvement Plans and Progress b.)
M.J. Wallace letter to J.M. Taylor dated August 24,1994 regarding Dresden Plan for Sustained Long Term Performance improvements The purpose of this letter is to describe the completion of the Dresden Plan, along with closure of the plan and transition of remaining improvement actions to the Dresden Station 1997 Business Plan.
In August 1994, following an extensive evaluation of the continued performt ice problems at Dresden, station management developed a comprehensive three-year plan - the Dresden Plan - for sustained long term performance improvement. The Dresden Plan identified the fundamental issues contributing i
to poor station performance and developed improvement objectives in the following five major focus areas:
Management and Leadership; 0
Materiel Condition; I
Human Performance;
[1)O Performance Monitoring; and e
Radiation Protection.
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USNRC JSPLTR #96-0247.
December 30,1996 Page 2 of 10 l
Within each focus area, the Plan prescribed actions to improve performance.
Implementation of these actions was accomplished by means of a series of near-term Focus Area plans, each covering a period of about six months, and the 1996 Business Plan. As described in previous status reports to the NRC, these implementation plans included actions from the original Dresden Plan, as well as numerous actions which augmented the original Dresden Plan actions. In some cases, these actions modified or replaced the Dresden Plan actions in order to focus more directly on the currently apparent causes of poor performance. In other cases, the Dresden Plan actions were no longer required because of 1
changing conditions. These changes have been documented in the Dresden Plan closure documentation and this process was reviewed by the NRC during the recent Independent Safety inspection.
i As part of the Dresden Plan closure process, Dresden management recently completed a series of Senior Management Review Boards to confirm the completion of the Dresden Plan actions, to assess the station's overall improvement under the Dresden Plan and to define the future actions necessary to continue the station's improving trend. In each case, responsible individuals appeared before the board and provided a summary of the improvement actions taken in their area, a current assessment of the issues and objectives identified in the Dresden Plan, and future actions to be implemented as part of the 1997 Business Plan.
Overall, the actions taken under the Dresden Plan have markedly improved station performance. At the same time, we recognize that the desired level of performance improvement was not attained in all areas and that additional actions will have to be taken. Therefore, while actions under the Dresden Plan have been closed, we will implement these additional improvement actions under the 1997 Business Plan. A brief summary of the status of each focus area is provided below.
USNRC JSPLTR #96-0247 December 30,1996 i
Page 3 of 10 1.
Management and Leadership A comprehensive set of actions has been implemented to strengthen leadership and improve station management capabilities. A new management team composed of individuals with strong performance records at other facilities was installed at the station. These individuals include the Site Vice President, Station Manager, Site Engineering Manager, Operations Manager, Maintenance Superintendent and the Site Quality Verification Director.
Actions have also been implemented to provide mentoring and coaching for the management team. For example, in October,1995 the Vice President initiated the monthly Performance Review Meeting to provide a forum to discuss issues specifically related to site performance. These monthly meetings have continued under the Chief Nuclear Operating Officer. Mentors and coaches with previous industry experience were assigned to selected operations and engineering managers. In addition, managers were deployed to selected plants to learn first hand how successful programs functioned. Finally, management accountability for station performance was reinforced through changes to the Performance Planning Review (PPR) process.
The new management team has aggressively established performance standards and communicated its expectations. A formal " standards and expectation" booklet was distributed to station employees in August of 1995. This standards and expectations booklet was supplemented by sma'l group discussions to ensure complete understanding by station employees. Employee expectations wr:e fully outlined in the Employee Performance Evaluation Program (EPEP) for hargaining unit personnel.
4 USNRC JSPLTR #96-0247 December 30,1996 Page 4 of 10 Numerous actions were also implemented to enhance management monitoring and assessment of station activities. For example a monthly monitoring report was initiated in August,1994, to provide station management performance information. This report, combined with the monthly performance reviaw meetings, are the principal means for management monitoring of overall site performance.
The new management team also icok action to improve long-range planning by establishing a formali2.ed husiness planning process. The first plan, initiated in 1996, is currently in the closure process and the 1997 Business Plan is being developed. Unlike previous plans, improvement actions in the Business Plans are specifically funded in station budgets. This business planning process will be the foundation for future improvement actions at Dresden Station.
II.
Materiel Condition A.
Imorovements to Eauipment Several substantial improvements in the material condition of Dresden Station have been achieved since 1994. Key indicators of improved material condition include:
Reduction in the backlog of non-outage corrective maintenance work requests from 1816 in December,1994 to i
945 as of November,1996.
Reduction in the number of outstanding control room work requests from 400 in 1993 to 66 as of November,1996.
Reduction in the number of temporary alterations greater than 30 days old from 60 in December,1993 to 30 as of November,1996.
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i Reduction in the number of operator workarounds opened e
from 109 in 1993 to 34 as of November,1996.
In addition to these backlog reductions, several substantial equipment repairs and/or upgrades have been made which have resolved long-standing equipment deficiencies. These include:
Overhaul of the 4KV switchgear l
Replacement of the Unit 2 Reactor Water Cleanup Piping e
Cisanout of the Unit 2 Reactor Head Bottom Drain e
improven at of the Feedwater Regulating Valve and the e
Reactor Water Levd Control System Cleanup of the Reactor Building Equipment Drain Tank Rooms Although general improvement was noted, station management i
recognizes that further action is required in this area. These future actions will be implemented through the Material Condition t
Improvement Plan and the 1997 Business Plan.
I B.
Enaineerina in the Engineering area, management focused on improving engineering experience, capabilities, products, functions, effectiveness and timeliness and configuration and system design basis information. Significant resources were also allocated to j
reduce the modification request backlog. In terms of compilation of i
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USNRC JSPLTR #96-0247 December 30,1996 Page 6 of 10 1
configuration and system design basis information, it is clear that while progress was made, significant further action is necessary.
We have described our planned further action by letter of November 8,1996, which has been confirmed by the NRC's Confirmatory Action Letter dated November 21,1996.
The Material Condition Improvement Plan (MCIP) is a program which will implement the observations and recommendations which resulted from the 1996 Latent Material Condition Review of system performance. These reviews were performed by groups of experienced individuals from outside Comed assisted by Engineering, Operations, and Maintenance personnel from Dresden Station. The recommendations have been evaluated and prioritized and are being implemented over the next four years.
Dresden is committed to improving the material condition of the station. Phases 1 & 2 of the MCIP were completed in 1996. This plan used a prioritization system that chose twenty-seven systems that most affected Safety and Production for improvement in site materiel condition, improvements in System Manager's capability to recognize and identify leading failure indicators were another aspect of the MCIP. Plans are incorporated into the 1997 Business Plan to continue phase 3 of MCIP. This phase consists of evaluations and implementation of MCIP phase 1 & 2 recommendations as part of the engineering 3 year plan.
Finally, numerous actions were implemented to improve the materiel condition of Unit 1. First, a dedicated Unit 1 management team was formed and provided with sufficient resources to address the Unit 1 issues. In addition to conducting specific training to improve knowledge, training and procedures for Dresden Unit 1 structures, systems and components, numerous specific actions l
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JSPLTR #96-0247
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December 30,1996 Page 7 of 10 j
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were taken to improve the materiel condition of the Unit 1 systems and spaces, and to increase Unit 1's independence from Units 2 and 3. In addition, a preventative maintenance program was developed for Unit 1 systems that are active, essential, or remain i
inter-connected with the operating units.
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Human Performance A substantial effort has been devoted to improving human performance at Dresden Station, and positive results have been achieved - we do, however, have more to do in this area. For example, substantial progress was achieved in improving procedure adequacy and the procedure change process. Under the new process, the procedure backlog has been eliminated and changes are processed in terms of minutes rather than days or weeks under the old system. Similar results were achieved in the industrial safety area where the stations industrial sa'ety accident rate (ISAR) was reduced from 2.2 in 1994 to 0.7 today. TI,is ISAR is the lowest since this performance measure has been used at the station.
Management also aggressively implemented actions to reduce personnel errors and improve procedure compliance. For example, specific programs were developed to increase management attention to personnel errors, and foster management and worker accountability for those errors.
Information was obtained from plants recognized for their outstanding procedure compliance record and the lessons learned incorporated into the Dresden procedures. As a result, for the first time since the Station began tracking personnel errors, Dresden achieved its goal of forty days of personnel error event free days of operation on December 2,1996. As of the date of this letter we are currently at sixty-four event free days. At the same time, we need continued improvement in this area. Therefore, management will continue to act through the 1997 Business Plan.
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I USNRC JSPLTR #96-0247 i.
December 30,1996 Page 8 of 10 1
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IV.
Performance Monitoring i
i improvement actions in the Performance Monitoring area concentrated on i
the corrective action program, the quality verification (QV) function and on the self-assessment process. Corrective action program related actions included improving the knowledge and skill of root cause investigators and requiring Plant Operations Review Committee (PORC) review of all root cause evaluations. In addition, a tracking program to ensure timely implementation of corrective actions was established.
Numerous actions were also implemented to improve the QV function.
For example, technical experts are now used to enhance the i
effectiveness of audit teams and the QV presence in the field was i
increased to improve monitoring effectiveness. To improved the quality of oversight, the QV staff was reinforced with operating and QA experienced j
personnel.
i Finally, numerous actions were implemented to improve the self-assessment process. A site-wide'self-assessment process was i
developed and major site departments now conduct self-assessments of their activities. Moreover, a standard set of performance indicators was i
developed and the results distributed to key management personnel on a monthly basis. Since 19S4, the average age of Performance Improvement Forms (PlFs) has been reduced from 104.5 days to 30.6 days currently, and the number of overdue Nuclear Tracking System (NTS items has been reduced from 80 to 10.
i V.
Radiation Protection Substantial progress has been made towards achieving the Dresden Plan j
objectives in the Radiation Protection focus area. For example, numerous j
actions were implemented to reduce the worker's collective radiological i
dose at the station from 833 Rem in 1994 to 416 Rem to date in 1996. As a result, the station is on track to achieve the lowest collective annual
USNRC JSPLTR #96-0247 December 30,1996 Page 9 of 10 i
dose in station history during a time when the man-hours worked in the plant have increased. The ALARA program and the station's source term reduction initiatives were described as " strong" during the recent NRC Independent Safety inspection (ISI).
t Part of the reduction in personnel exposure was the result of actions to reduce the contaminated area in the plant and to reduce the number of personnel contamination events. Specifically, a decontamination crew was formed and reduced the contaminated area in the plant from 11.24%
to 8.8% in September 1996 (calculation methodology changed in October 1996). Nearly all of the remaining contaminated area is in the Torus basement areas. Personnel contamination events have trended downward and are on track for a record low number of events this year l
(58 YTD vs. approx. 220 in 1994).
Numerous actions were also implemented to improve radiological work practices at the station and some progress was achieved. For example, i
the number of events attributable to poor work practices have decreased since 1994. However, management is not satisfied with the level of radiation worker knowledge and procedure adherence by RP Technicians at the site and will continue to implement actions as part of 1997 Business Plan to achieve further improvements in this area.
1 Although the Dresden Plan has been closed, a detailed audit of the closure documentation will be conducted to verify completeness of the closure records and an separate effectiveness review of the Dresden Plan actions will be l
conducted to identify future improvement actions. These actions will be l
complete by March 1997.
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USNRC JSPLTR #96-0247 December 30,1996 Page 10 of 10 in summary, Dresden Station has completed the implementation of the actions to achieve the improvement objectives identified in the Dresden Plan. Detailed records of the completion of Dresden Plan actions are available on-site for NRC review. Overall, there has been a marked improvement in overall station i
performance. However, it is also clear that additional improvement actions are required in some areas. As we complete the closure process and develop 1
further improvement actions, they will be added to the improvement actions already included in the 1997 Dresden Business Plan.
Please call me should you have any questions cr require further information.
Sincerely, i
. Stephen Perry Site Vice President Dresden Station l
JSP/ lad cc:
A. Bill Beach, Regional Administrator, Region ill P. L. Hiland, Branch Chief, Division of Reactor riupets, Region lll J. F. Stang, Project Manager, NRR (Unit 2/3)
C. L. Vandemiet, Senior Resident inspector, Dresden Office of Nuclear Facility Safety - IDNS i
File: Numerical t
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