ML20149M317

Forwards Util Response to Rept of Independent Safety Assessment Team Which Presents Plans for Resolving Concerns Identified in Rept & Addresses Root Causes Described

ML20149M317
Person / Time
Site:	Maine Yankee
Issue date:	12/10/1996
From:	Frizzle C Maine Yankee
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20149M320	List: ML20149M317 ML20149M322
References
CDF-96-192, MN-96-183, NUDOCS 9612160142
Download: ML20149M317 (6)

Text

MaineYankee RE L '- B L E E L E C T RICli v SINC,E 19 7 2 329 Bath Road res dent an h ef Executive Officer f2 's December 10,1996 MN-96-183 CDF-96-192 UNITED STATES NUCLEAR REGULATORY COMMISSION Chainnan Shirley A. Jackson Mail Stop O-16 G15 One White Flint Nonh 11555 Rockville Pike Rockville MD 20852-2738

References:

(a) License No. DPR-36 (Docket No. 50-309)

(b) Letter, S. A. Jackson (USNRC) to C. D. Frizzle (Maine Yankee), dated October 7,1996 -Independent Safety Assessment

SUBJECT:

Independent Safety Assessment

Dear Chairman Jackson:

This letter and enclosures comprise Maine Yankee's response to the repon of the Independent Safety Assessment Team (ISA).

As you asked in your letter of October 7,1996, we are presenting Maine Yankee's plans for resolving the concems identified in the ISA report, and for addressing the root causes the team described. We appreciate the opportunity to respond directly to the Commission.

At the outset let me state that the ISA was a significant learning experience for me and ,

for the crganization as a whole. We appreciate the thoroughness, rigor and faimess of the )

inspection. Although the repon confirmed that Maine Yankee is operating safely, the report's l conclusions that performance is average or slightly below average and declining, and its / I documentation of significant deficiencies indicate that we need to make substantial improvements.

120016 /hDOl 1 Root Cause Assessment i

Shonly after receiving and individually reviewing the ISA the senior officers of Maine  !

Yankee met in a day long session to review, as a team, the ISA. The purpose was to make sure I we fully understood the report, especially the root causes. In that session we conducted an l assessment of the report in light of other known performance evaluations. As a result, let me say  ;

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UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-183 Attn: Chairman Shirley A. Jackson Page 2 l

plainly: Maine Yankee agrees with the ISA report, and agrees with the root-causes of 1) economic pressures and 2) weaknesses in problem identification and correction resulting from complacency and a lack of a questioning attitude. The ISA report confirms our own analyses on 1 a number ofissues that were under study shortly before the ISA team began its work and for I which we were in the process of developing improvement initiatives and underscores the need for major changes.

While safety has always been our first priority, a close second has been our concem for economical energy production. As the ISA report observes, the close focus on cost and competitive standing fostered an attitude of complacency in the sense of tolerance for non-urgent conditions that eroded our standing in the industry. That decline ultimately degraded the public l and regulatory confidence upon which this industry depends, and must be reversed. l Maine Yankee is committed to becoming an industry-leader in safety, design integrity, and equipment performance. Now, and in the months ahead, actions will support the words of 1 this letter.

Part of our response will be to address the specific concems of the ISA report. But the ISA team identified broad, corporate-culture issues that require more than a laundry list of specific remedial actions. They require a basic rethinking of Maine Yankee's operating philosophy.

Corrective Actions The following corrective actions, which are described more fully in the fomial response attached, have been developed in response to the root causes identified.

We have developed an Excellence Action Plan to address the root causes described in the ISA report and in our self-assessments. That program includes creating a Nuclear Oversight Committee at board level staffed by an independent expert advisory committee; appointing former NRC Director of Nuclear Reactor Regulation, Dr. Thomas E. Murley, to the Board of Directors; adding high-level expert staff, including a new Vice President of Licensing and R gulatory Compliance; a third party review to assess the ability of each officer and manager, and plans to make personnel changes as appropriate; and reevaluating and retraining super isors.

We are also increasing staffing in Engineering and Maintenance.

With respect to financial resources, Maine Yankee began development of an integrated Business Plan, with budgeted initiatives in August 1996. The proposed 1997 budget has been developed in parallel with the development of the Business Plan, and represents a fundamental departure from past budget development practices. In particular, the proposed 1997 budget has been developed by identifying and prioritizing activities, including corrective actions and

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UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-183 4 Attn: Chairman Shirley A. Jackson Page 3  ;

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improvements, deciding which activities should be implemented, and then providing the '

, necessary funding, rather than starting with budget targets and then identifying and prioritizing

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activities. As a result of this new process, which has been endorsed by the Board of Directors, Maine Yankee's budget for 1997 is $27 million more than would have been the case had we i j followed past practices. l 4

. Additionally, in 1995, Maine Yankee initiated a major reengineering ofits existing problem identification, task tracking, and corrective action processes. As a result the " Learning Process" was developed to improve problem identification and the corrective action programs for Maine Yankee. The Learning Process was recently comple'.3d, with implementation scheduled

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for January 1997, and as a result, Maine Yankee is consolidating its corrective action programs j into a single system for identification and tracking of problems, screening of problems for

operability and reportability, prioritizing problems for corrective actions and assigning l responsibility and accountability. We believe that this will enhance problem identification given its availability to all workers and ease of use, and improve the quality of cctrective actions.

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Maine Yankee is also making improvements in each of the principal areas of weakness identified by the ISA. For example:

i j . Margin Imorovement Procram - Maine Yankee is developing a design and

' operating margin review program to identify existing margins on important issues.

l Where margin improvements are determined to be warranted, appropriate plant i

upgrades will be provided. Plant upgrades to the containment spray and service l water systems have already begun. In light of the IS A findings regarding ,

l margins, Maine Yankee will not seek approval to return to 100 percent power operation until this margin improvementprogram has been completed.

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. Backlog Reduction - Maine Yankee is developing a program to reduce i

engineering and maintenance backlogs to minimal levels within the next two cycles of operation. This program will necessarily rely on contracted resources.

Pennanent staffing increases in engineering and maintenance will be authorized to

prevent the buildup of excessive backlogs in the future.

. Licensine and Desien Basis - In May 1996, Maine Yankee initiated a

. Configuration Management Improvement Initiative to verify conformance with the licensing basis, enhance configuration management controls, and improve j 50.59 safety evaluations. Additionally, Maine Yankee has initiated a Safety

Analysis Information Document (SAID) Program to identify the bases for operator-controlled plant parameters in a single set of documents. Although I begun prior to the ISA Maine Yankee believes these efforts will address issues raised by the ISA.

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l UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-183 Attn: Chairman Shirley A. Jackson Page 4 i

. Onerations - Maine Yankee has reassessed each of the operator workarounds' individual and collective impact on operators during emergency conditions. At this time there is not a single or collective workaround interaction that would significantly challenge operators under postulated accident conditions. Of the 13 workarounds identified by the ISA, eight have been addressed to remove the burdens on the operator and five are being addressed and will be resolved no later than the 1997 refueling outage. In the future Maine Yankee will seek to keep I operator workarounds to a minimum and will routinely evaluate the single and i collected effects of necessary workarounds.

. Maintenance and Testing - Maine Yankee is taking actions to improve its testing program, including reviewing existing test procedures to ensure that they are sufficient to verify the safety functions of systems, structures, and components, and providing training in evaluation of test results. Maine Yankee is also taking j steps to improve material condition, such as issuing guidelines for identification of material condition problems and establishing teams to reduce maintenance backlogs to minimallevels.

. Eneineering - We are creating, and by December 1997 will have established, a system engineering group to increase engineering ownership and accountability and to improve resolution of problems.

We are also integrating this corrective program within the broader Maine Yankee Business Plan now being drafted. Both the Excellence Action Plan and the Business Plan will be driven by this thought: From this point forward, Maine Yankee's management focus will be on excellence which we believe is best defined as a SALP 1. We will focus on assuring that these plans are well implemented such that obvious improvement in performance is demonstrated to regain the trust and respect of the public and the regulators.

We are designing systematic protocols to measure progress and the effectiveness of our corrective actions and to identify necessary refinements as this work progresses. We are committed to open communication on these points with our regulators and other constituencies, and welcome the opportunity to hold periodic management meetings with NRC staff to review our progress.

The Board of Directors recognizes that implementing an excellence strategy will, in the near term, increase budget requests submitted to them. But they have also expressed their firm commitment to support the actions necessary to fully address the root causes. The Board shares the view that focusing on excellence is the best long-term strategy to secure safety and cost efficiency.

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UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-183 Attn: Chairman Shirley A. Jackson Page5 l

Maine Yankee is taking the ISA repon very seriously, not simply because it is a regulatory document, but because it is an accurate assessment of conditions we recognize must be addressed. Our past performance demonstrates that Maine Yankee employees are capable of I world-class achievements. The findings of the ISA repon and our self-assessments are sobering  !

reminders that we have slipped below that potential. We will not let that happen again. We will l i

not settle for being " adequate." We will strive to improve performance. SALP "1" is our goal.

The enclosed response provides a discussion of the root cause analysis, corrective actions for root causes and Maine Yankee's actions to remedy specific ISA deficiencies. The response also includes 1) the Excellence Action Plan; 2) a summary of the Business Plan; 3) Yankee Atomic's plan to correct deficiencies; 4) Maine Yankee's actions to address specific ISA findings; and 5) clarifications of statements in the repon.

We look forward to the opportunity to brief the Commission and its staff on our response  ;

and to answer any questions you may have. We also hope to provide regular progress reports on i our plans for improvement to the Region and NRC staff, as appropriate.

Yours truly, l

Charles D. Frizzle President and Chief Executive Officer CDF/ dip Enclosures

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.o .218FidOC UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-I83 Attn: Chainnan Shirley A. Jackson Page 6 c: Commissioner Kenneth C. Rogers Commissioner Greta J. Dicus Commissioner Nils J. Diaz

. Commissioner Edward McGaffigan, Jr.

Mr. Edward L. Jordan, Director, Office for Analysis & Evaluation of Operational Data Mr. James M. Taylor, Executive Director for Operations Mr. Leonard J. Callan, Regional Administration, Region IV Mr. Frank J. Miraglia, Acting Director of NRR Mr. Hugh L. Thompson, Jr., Deputy Executive Director for Nuclear Material Safety / Safeguards and Operations Supports Mr. Hubert J. Miller, Administrator, Region I ,

Mr. Ellis Mershoff, Region II, Deputy Director, Division of Reactor Projects Mr. Samuel L. Collins, Deputy Regional Administration, Region IV Mr. John A. Zwolinski, Deputy Director of Reactor Projects Mr. J. T. Yerokun, NRC Resident Inspector Mr. D. H. Dorman, NRC Project Manager Mr. Uldis Vanags, State Nuclear Safety Advisor Mr. Patrick J. Dostie, State Nuclear Safety Inspector Honorable Angus King, Governor, State of Maine Thomas M. Allen, Congressman-elect John E. Baldacci, Congressman William S. Cohen, Senator Susan Collins, Senator-elect James B. Longley, Congressman

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