ML20148D841
| ML20148D841 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/23/1997 |
| From: | Jamila Perry COMMONWEALTH EDISON CO. |
| To: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| JSPLTR-#97-0102, JSPLTR-#97-102, NUDOCS 9706020125 | |
| Download: ML20148D841 (12) | |
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':ommonwealth Edison Company Dresden Generating Station 6500 North Dresden Itoad Morris, IL 60450 Tel 814942-2920 May 23,1997 JSPLTR #97-0102 Mr. A. Bill Beach Regional Administrator U. S. Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, IL 60532-4351
Subject:
Dresden Station Units 1,2, and 3 Dresden Station Performance NRC Docket Nos.50-010. 50-237. and 50-249 c
Dear Mr. Beach:
Introductinn In 1994, the Dresden Plan was developed as our long term plan to achieve sustained improvement in Dresden Station's overall safety performance. When implementation of the Plan was completed in December 1996, we were very pleased that the assessments completed as part of the Plan closure process were consistent with the NRC Independent Safety Inspection's (ISI) conclusion that Dresden Station has improved its overall safety performance. At the same time, both our own assessments and the IS' identified some remaining weak areas. Since December, we have taken additional actions to address these remaining areas of weakness. While we clearly understand that our performance must continue to improve, these actions led to better performance in several of these areas. Summarized below are some of the key actions taken and the results we have achieved.
Operational Performance gv\\
Following lengthy shutdowns in 1996, the Dresden Units 2 and 3 achieved a sustained y period of dual unit operation in 1997. On March 8,1997, Unit 2 exceeded its previous i
record of 190 days of continuous operation. When the plant was I'mally shutdown on 0
April 10,1997. Unit 2 had set a new record of 223 consecutive days without a shutdown. )
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USNRC JSPLTR #97-0102 May 23,1997 Page 2 of 12 Unit 3 also performed well in 1997. Following an error free startup on March 29,1997 and operated for 60 days in coast down until it was shut down for its fourteenth refueling outage on March 29,1997.
The Dresden Units could not have achieved this operational record without significant improvement in the overall material condition of the plant, a corresponding reduction in the number of operator challenges, and the superior performance of the operations staff.
For example, the average number of Operations human performance events have been reduced from 3 per month during 1996, to 2 per month thus far in 1997. Since mid-1996, external inspections and evaluations have consistently recognized the Operations Department as a professional organization that is setting the pace for improvement at the site. Recent improvements in training are reflected in the recent reaccreditation of our training programs by the National Nuclear Accrediting Board. Dresden Control Room operations have been recognized as among the best in the nation on a number of recent occasions. Improvement has also been achieved in field operator performance. In 1996, 10 Operations human performance events were attributed to non licensed operators. Only one non-licensed operator human performance event has occurred to date in 1997.
However, we are not yet satisfied with the level of human performance we have achieved.
We will continue to reinforce our expectations and train our personnel to further improve j
this area.
Engineering The Independent Safety Inspection (ISI) identified a number of problems with Engineering control of the design basis, specifically in the areas of design control, calculation control and the retrievability of design basis information at Dresden Station. Because similar problems were aise observed during the LaSalle and Zion Independent Safety Assessments, Comed submitted on November 12,1996, a Nuclear Operations Division wide action plan for en.suring appropriate design control at its nuclear Stations.
Summarized below are some of the actions that have been implemented as a result of this plan as well as other Dresden-specific actions developed by the Station to address plant specific problems in the Engineering area.
t USNRC JSPLTR #97-0102 May 23,1997 Page 3 of 12 Nuclear Engineering procedures were revised in late 1996 and early 1997 to provide improved guidance for review and update of engineering calculations and to specify the actions to be taken when potential design basis discrepancies are identified or when a conflict is found between the UFSAR, design documents and the physical plant.
A group of senior, experienced Engineering Consultants was formed to identify and review key operating parameters against system calculations for the twelve most risk significant systems and to verify that the calculations supported these key parameters.
Identified discrepancies were documented and operability evaluations were performed where appropriate to ensure that the systems were capable of performing their intended safety functions. This efTort provided additional assurance that the Dresden design information and calculations are consistent with the systems' functional and testing requirements.
A Comed program of audits of the Nuclear Steam Supply System suppliers and primary Architect / Engineers (A/Es) was developed and implemented. Four audits have been performed thus far to determine the quality of design calculations, the effectiveness of their design control process, and the effectiveness of their OA program implementation. As discussed with your staff, several design control deficiencies were identified at each audited organization. Corrective actions were developed and implemented to improve the quality of engineering programs and procedures for design control as well as ensure overall calculation quality. Follow-up corrective action effectiveness reviews are planned.
The Design Engineering Assurance Group (EAG), consisting of both senior Comed and consultant engineers, was established to provide oversight and guidance for Engineering activities, with the ultimate goal ofimproving the quality of the Dresden Engineering function. The EAG has been fully functional since early February,1997, and has conducted reviews of several types of significant Engineering output documents, including: 10 CFR 50.59 evaluations developed for partially completed modifications; planned modifications for the D3R14 refueling outage; and several substantial Engineering operability evaluations. By idemifying deficiencies, the EAG not only improves product quality, it also provides real time feedback reinforcing management's expectations. The EAG has also noted that more equipment-related Performance improvement Forms (PIFs) are being written by Engineering Department personnel.
USNRC JSPLTR #97-0102 May 23,1997 Page 4 of 12 A Design Basis Review Project staffed by Comed and contract engineers has been established to provide further confidence that the plant is operating within its design basis requirements. The project is establishing consistency between the UFSAR, Upgraded Technical Specifications (TSUP), Design Basis Documents, calculations, plant procedures, and plant configuration. Participation of Comed personnel ensures that the knowledge of the design basis is retained within Comed Engineering. As we have taken these actions, we have continued to reduce our backlog of Engineering work at Dresden. We have reduced the backlog of outstanding design change and engineering support Engineering Requests from over 800 in January 1997, to 615 as of April 30,1997.
Engineering has demonstrated the ability to perform operability evaluations in a timely, effective fashion. Over 60 (most from design basis review projects) have been completed this year.
As we contemplated by the NRC's November 1996 Confirmatory Action Letter, we are continuing to keep the NRC Staffinformed of the resolution of these issues.
Corrective Action The ISI Inspectors noted that Dresden Station had achieved improvement in problem 4
identification and its Corrective Action Program. Nevertheless, the need for continued improvement at Dresden was clear. A new standardized Corrective Action Program is being implemented at each of the Comed nuclear sites. This program was developed by representatives from each site and incorporates the best aspects of the existing site programs, as well as industry best practices. The new program clearly delineates and standardizes the threshold for problem identification through Performance Improvement Form (PIF) initiation, and establishes common PIF screening criteria that provide greater flexibility and consistency in analyzing PIF data.
At Dresden, the new Corrective Action Program is being implemented in two phases.
Phase I was implemented at Dresden in April 1997, and includes the use of common site procedures, an interim database, and associated training for site personnel. Phase II, which includes the use of electronically generated PIFs and associated training, will be implemented in the summer of 1997 following completion of the Unit 3 refueling outage.
USNRC JSPLTR #97-0102 May 23,1997 Page 5 of 12 The program features standardized root ca'ise analysis, common trending codes, and common performance measures at each Comed site.
Prior to implementation of the new Comed Corrective Action Program, action was taken at Dresden to ensure that problems are reported for resolution. Late last year for example, Dresden Administrative Procedure (DAP) 02-27, "The Integrated Reporting Process" (IRP) was revised to provide clearer direction for site personnel regarding Performance Improvement Form (PIF) initiation criteria. The revised criteria lowered the threshold for PIF initiation. Similar action has recently been taken within the Engineering Department to ensure Engineering personnel understand management's expectations for PIF initiation.
Based on our PIF initiation tracking, these actions have substantially lowered the threshold for problem reporting at the site, with over a fifly percent increase in the number of PIFs initiated per month since the beginning of the year. At the same time, the timeliness of implementation of corrective actions has been significantly improved; the average time to implement corrective actions has been reduced from 94 days in the first half and 85 days in the second half of 1996, to an average of 78 days in the first four months of 1997. We have also continued to gradually reduce the total number of open corrective action items, from 631 in January 1997, to 595 at the end of April 1997.
The Station has also taken action to address the issues raised during the NRC Independent Safety Inspection (ISI). Specifically, in our January 13,1997 Interim Response and February 26,1997 Response, we described the corrective action we have taken to resolve the Deficiencies and Unresolved Items raised in the Independent Safety Inspection Report.
In addition, improvement actions are being implemented in response to numerous other NRC observations contained in the ISI Report.
Maintenance and Work Control During the Independent Safety Inspection, the inspectors noted improvement in maintenance processes, the knowledge, skills and abilities of maintenance personnel, and a significantly improved overall plant condition. However, the NRC also noted that the effectiveness of many of these improvements was reduced by the number of emergent work activities. Dresden Station has continued to act to reduce the amount and impact of emergent work and to improve work management so that both emergent and planned work are completed more quickly and effectively.
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For example, Senior Reactor Operators are assigned to the Review and Approval Team (RAT) to improve the identification and prioritization of Action Request (ARs). In addition, the "Fix It Now"(FIN) Team has been re-focused on protecting the schedule by performing emergent work. As a result of these actions, the Station's performance indicators demonstrate emergent work is no longer hampering the ability to conduct planned work. The Station is currently meeting its goal of having 80 percent of the work scheduled five weeks prior to execution-week. Improvements in Maintenance and Work Control were also noted during the NRC's April 1996 inspection of maintenance.
The Station has also demonstrated the ability to conduct the scheduled major maintenance tasks. For example, the Station recently completed a repair of the Unit 3B Recirculation Pump motor. This major maintenance task involved a number of potentially safety significant sub-tasks, including the lift of the motor over a section of non-primary coolant piping. The extensive pre-job planning and worker training j
conducted for each phase of the project were instrumental in the successful completion of this repair. Similarly, Engineering has demonstrated the ability to successfully resolve complex technical issues, such as those involving Control Room IIVAC and ECCS Net Positive Suction IIead.
Plant Material Condition We are continuing to improve material condition of the plant. For example, during the Unit 3 refueling outage, the Reactor Water Cleanup heat exchangers and piping are being replaced to renew substantial equipment that has deteriorated from Intergranular Stress Corrosion Cracking. Dresden is also completing the installation of the Unit 3 Zine Injection System that should slow the rate of future Intergranular attack. The plant is also implementing several modifications to the Off-Gas system to provide redundancy in Off-Gas trains and correct several long standing material condition problems with the system.
Finally, the material condition of nurnerous motor operated valves is being improved through the completion of the Generic Letter 89-10 upgrades. NRC inspection of the Generic Letter 89-10 program found that the program was properly implemented.
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USNRC JSPLTR #97-0102 May 23,1997 Page 7 of 12 Inservice and Suryfilhwre Testing In early 1996 Dresden Engineering initiated a comprehensive IST program basis review to verify conformance to codes, requirements, the current licensing basis and current i
NRC guidance (i.e., NUREG-1482). Initial findings from the first phase of the program basis review were reported to the NRC in LER 2-96-Oll. Subsequently, the Independent Safety Inspection also identified two concerns with the program, including the failure to properly test a Ifigh Pressure Coolant Injection check valve and the failure to take adequate corrective actions for past program deficiencies.
In early 1997, Dresden Station completed the IST program basis review. In addition to the scope described above, a review of all 1987 DET IST findings and corrective actions was included. Over three hundred review findings were identified, reviewed for potential operability issues, prioritized and included in the IST corrective action plans. No additional unaddressed issues were identified from the 1987 DET beyond those identified during the ISI.
Corrective actions for these deficiencies are well underway with over one hundred and fifty of the three hundred and thirty eight total items having been resolved to date. For example, twelve findings were corrected prior to the Unit 2 restart from the April 1997 forced outage. Another sixty findings were included in the Unit 3 refueling outage plan for completion during the outage. Remaining corrective actions are expected to be complete by August 1997.
i These are important accomplishments. However, as shown by the recent problems in IST of the 250 VDC batteries, further improvement must be made. In order to improve effectiveness of the IST program, the Station has developed a procedurally controlled IST program basis document describing the basis of setpoints and decisions regarding each component subject to the program. This basis document is in review and is on schedule to be issued by July 1997.
USNRC JSPLTR #97-0102 May 23,1997 Page 8 of 12 l
Procedure Ouality and AdtwEnct Actions to improve procedure quality and adherence were included in the Dresden Plan and implemented during 1994 through 1996. While progress was achieved, the need for further improvement was recognized during the Dresden Plan closure reviews conducted in late 1996. As a result, further actions were developed to improve procedure quality and convey management expectations regarding procedure compliance and included in the 1997 Dresden Operational Plan. Improvements implemented to date include:
reviewing the 1996 Performance Improvement Forms (PIFs), Licensee Event Reports (LERs), and Notices of Violations (NOVs) to develop an awareness package based on lessons learned; modifying the procedure revision process to clearly define the procedure user's role and responsibilities in procedure development; procuring a self checking simulator and developing the necessary training materials to be used in conjunction with the simulator; and evaluating training materials to improve the incorporation oflessons learned in First Line Supervisor's pre-and post-job briefs. The overall rate of human performance errors at Dresden Station is now.88 human errors per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> worked.
This rate compares favorably with our industry peers, and with the human error rate of two plants recognized by INPO as having good human performance programs ( 3.6 and 5.4 errors per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> worked).
Ilowever, we remain concerned with human performance. Our trend in Personnel Error LERs has remained relatively unchanged since 1996. Also, while our Industrial Safety Accident Rate continued to decrease (with no lost workday accidents to date in 1997), we have not yet met our goal of 40 days event-free performance. Human performance remains a central focus of Dresden Station Management. We have not succeeded in meeting our goal for event free days.
Manacement Exnectations Dresden management has continued the efforts observed during the ISI to reinforce individual accountability for safety performance and improve the capabilities of Station personnel. The NRC ISI team evaluated these actions and found them to be effective in addressing long-standing obstacles to performance improvement.
4 USNRC JSPLTR #97-0102 May 23,1997 Page 9 of 12 Specincally, the ISI team concluded that management's expectations regarding accountability, strict procedure adherence, and teamwork were being reinforced through multiple methods of communications and it appeared they would be effective at resolvicg these long-standing issues.
Since the ISI, Dresden management has continued its efforts to ensure that each employee is aware of management's expectations regarding safety performance. In addition to these gencal efforts, Station management has taken more focused actions to address recognized problem areas. For example, Engineering Department management has made an extraordinary effort to ensure that overall standards and expectations for the performance of work are communicated to Engineering personnel. An Engineering expectations meeting was conducted on February 7,1997, with the Site Vice President, Site Engineering Manager, Engineering Chiefs and the Engineering Vice President to review and ensure common understanding of signincant issues, site and Corporate Engineering deliverables, goals, project.;, indicators and plans. Additional meetings were conducted with the Engineering Staffin March,1997, to ensure that engineers clearly understand management's expectations with respect to performance standards. These expectations are further reinforced on a less formal basis during weekly staff meetings and tailgates. Recently, a new Plant Engineering Superintendent with signincant Dresden operational experience was appointed and expressly tasked with upgrading the performance standards of the Plant Engineering Department. As these efforts have been implemented, there has been an increase in the number of PIFs initiated by Engineering personnel and an improvement in the quality of engineering products has been identi6ed by the EAG.
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USNRC JSPLTR #97-0102 May 23,1997 Page 10 of12 Radiation Worker Performance lusden Station has implemented a number of actions to upgrade radiation worker knowledge and improve worker performance. The most effective of these actions was the implementation of the " Greeter Program" through Radiation Protection Policy Memo ADM-10. Greeters are personnel stationed at the Radiation Protection Area (RPA) access point who challenge wo:-kers entering the plant on radiological conditions at their work site and on their responsibilities as radiation workers, including their responsibility to work safely, reduce radioactive waste, and the need to return the area to the as found condition. During January - April 1997, Sixty Six percent of the PIFs involving Radiation Worker problems are identified by the Greeter prior to the Radiation Woder actually entering the RPA.
Prior to the outage, the RD Department also instituted a " Rover Program" to complemem the Greeter Program. Two RP technicians were assigned as rovers to monitor activities in the RPA, assist the radiation workers in resolving problems, and to identify and correct RP deficiencies.
Immediately prior to the outage, the Dresden RP department prepared and distributed
" Radiation Protection Guidelines" to all Radiation Workers at the site. This document was constructed as a " desk reference" that provided guidance on RP related functions at Dresder Station. Dresden ALARA personnel provided specific training for ootm contracwrs on these guidelines.
A significant effor has also been made to reduce the contaminated area in the plant. This action, when combined with the overall improved material condition of Dresden Station, contributed to the reduced number of personnel contamination events experienced over the last six months.
Finally, the Radiation Protection Manager (RPM) has established a program to track and trend both good and poor radiological work practices. When such an event is identified, a letter is provided to the worker's supervisor describing the worker's good or poor performance. Good practices are rewarded, while poor practices can result in the individual bemg locked out of the RPA until a meeting is held with the individual, his supervisor, and the RPM.
, I USNRC JSPLTR #97-0102 May 23,1997 Page 11 of 12 The NRC recognized the improvement in Radiation Protection and Radiation Worker performance during two recent inspections. Specifically, Inspection Report 97-004 recognized the Radiation Worker and Radiation Practices to be good and the April 1997 Maintenance Team Inspection recognized effective radiological controls and an improving trend in Radiation Worker Performance.
We have also continued our overall progress in Radiation Protection. We remain within our collective radiation exposure goals for both units. Personnel contamination events (PCEs) during January - April 1997, have averaged 5 per month, which is comparable to 1996 levels and a substantial improvement over previous years (the 1994 average was 25 PCEs per month and she 1995 average was 8 PCEs per month). During our current refueling outage (which is nearly completed). we have experienced less than 3 rem of exposure due to rework as compared to over 50 during our previous most recent refueling outage.
Outnee Performance Due to intensive advance planning, our current refueling outage is proceeding more smoothly than previous recent outages. We are within approximatcly five days of our schedule, and have maintained the schedule logic prepared in advance to govern outage activities. We are on target to maintain our scope growth target ofless than 20%, and there has been only one outage-related personnel error LER.
Conclusion As noted above, we have taken an number of actions in the last six months to address the remaining areas of weakness identified by our self-assessments and the ISI while at the same time sustaining the improvement achieved under the Dresden Plan. While further improvement has been achieved, we clearly recognize the need for a consistently strong level of performance. We must continue this trend to achieve our goal of operating Dresden Station at a level better than the average of our peers in the industry as expressed in Comed's 50.54(f) response.
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USNRC JSPLTR #97-0102 May 23,1997 Page 12 of12 Please call me should you have any questions or require any further information.
Sincerely, WStep en Perry Site Vice President Dresden Station JSP/ WEB: lad cc: USNRC (Public Document Room)
W. J. Kropp, Branch Chief, Division of Reactor Projects, T(egion III J. F. Stang, Project Manager, NRR (Unit 2/3)
Senior Resident Inspector, Dresden Office of Nuclear Facility Safety - IDNS File: Numerical
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