ML20197G284
| ML20197G284 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/19/1997 |
| From: | Subalusky W COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9712300411 | |
| Download: ML20197G284 (10) | |
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December 19,1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Review of LaSalle County Station Performance LaSalle County Station, Units 1 and 2 Facility Operating License NPF-11 and NPF-18 NRC Docket Nos. 50 373 and 50-374
Reference:
W. T. Subalusky letter to U.S. NRC, dated November 27,1996, Transmitting Response to SALP 13 Report.
Our letter of November 27,1996, responded to the SALP 13 report and summarized our improvement efforts at LaSalle County Station. A year has passed and we have pursued a number of significant issues and implemented several key improvement programs. We thought it would be useful for you to have an update on LaSalle's performance. In that light, the attachment to this letter provid6s key examplos of improvements and indicators of results achieved, and discusses areas where continued management focus is warranted.
in summary, the Station continues to focus on implementation of our seven Restart Strategies: (1) Safe Plant Operation, (2) Human Performance, (3)
Plant Materiel Condition, (4) Effective Engineering Support, (5) Corrective j;
Action and Self Assessment, (6) Training, and (7) Process improvement.
Even though we have yet to achieve the consistent level of performance we
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require of ourselves and our equipment, we are taking extensive actions and have achieved improvements in each of these areas. For example:
,UO Human Performance is a primary focus area at LaSalle. We have
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taken a fundamental opproach to improving human performance, recognizing that accour,tability for human performance clearly rests with line managers and first line supervisors. Individual accountability for implementing Site expet,tations has played a key role in reducing 9712300411 971219 U"
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o personnel errors at the Site. Events that resulted from personnel errors have dccreasPJ. This is evident from the increase in days between events th'.st reset our station event free clock (average of 4 to average of 13), a more than 50% reduction in maintenance rework (5% to 2.2%) and no lost time accident in over two years.
Plant Materiel Condition is being substantially improved. With both units currently shut down, we are actively pursuing resolution of many long-standing equipment performance and materiel condition issues.
Since then, we have been resolving historical operator " work arounds," long-standing temporary alterations, control room deficiencies, and equipment problems. Approximately 300 design changes are be!ng made including major upgrades to ventilation systems, electro-hydraulic control and the reactor water cleanup system. The majority of these designs are complete and about a third have been constructed in the plant.
Corrective Action Program improvement actions include improving processes, clarifying expectations, increasing accountability, enhancing personnel qualifications, and establishing performance indicators. As part of this effort, we have lowered our threshold for problem reporting and have seen a corrssponding increase in the number of problems identified. In terms of results, we have achieved a reduction of repeat events of over 60% from 1996 to 1997 (26 events to 10 events).
Further details are provided in the Attachment regsrding implementation of the seven restart strategies, including additional examples where progress has been made and where further improvement is needed. Also, we have provided information on improvements in Radiation Protection.
Although we continue to face challenges to the restart of Unit 1, we have implemented many key actions needed to improve LaSalle County Station performance. In the near term, we will continue to maintain focus on the fundamentals of conservative decision making, leadership, accountability, and materiel condition. Emphasis will be on sustained improvement - not on " quick fixes." We are confident that our prese.it initiatives will meet the challenges ahead and successfully sustain improved station performance.
We will not propose to restart Unit 1 until we are satisfied that appropriate actions to achieve our station directive of a safe. uneventful startup followed by a safe, long uneventful run have been completed.
r If there are any questions or comments concerning this letter, please call me at (815) 357 6761, extension 3600.
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Respectfully,
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N W. T. Subalusky
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Site Vice Presiden LaSalle County Station Enclosure cc:
L. J. Callan, NRC Executive Director for Operations A. B. Beach, NRC Region lll Administrator M. P. Huber, NRC Senior Resident Inspector - LaSalle D. M. Skay, Project Manager NRR LaSalle F. Niziolek, Office of Nuclear Facility Safety - lDNS R. A. Capra, Project Director NRR M. N. Leach, NRC Region lil T. Vegel, Acting Branch Chief, Division of Reactor Projects, Region lli
N ATTACHMENT 4
SUMMARY
OF LASALLE COUNTY IMPROVEMENT INITIATIVES Strateav i - Safe Plant Operation i
Numerous materiel condition deficiencies are being corrected in the plant that impact operational performance. Operator work arounds that once burdened operators, but
- which now have been corrected include:- (1) elimination of premature degradation of the reactor recirculation and flow control valve actuators (which caused leaks and actuator drain alarms); (2) correction of diesel generator reactive power readings.
(previously inconsistent between the control room and local panels); (3) elimination of the need to manually override the circulating water pump glandwater pressure switches in order to start the pump; and (4) correction of inaccuracies in the instrument and service air piping and instrument drawings. In 1997, we corrected 12 Unit 1 work arounds and intend to correct 10 of the remaining 16 work arounds before startup.
Action plans are in place to address the other 6 work arounds in a timely manner.
Additionally, a number of long standing main control room materiel condition problems which distract operators, such as spiking of the intermediate and source range nuclear instruments and spurious alarming of the Unit i service water process radiation monitor, are being eliminated. Sixty-three distractions have been corrected to date and 26 of the remaining 32 control room distractions are planned to be eliminated before Unit 1 smrtup. The remaining distractions will be closely monitored to ensure that operator performance is not significantly impacted.
An Operations " Scorecard" program was implemented in February 1997. As part of this program, Senior Managers, Shift Managers, and Unit Supervisors observe, grade, and provide direct feedback to operators in twenty performance areas. The observation results are also trended. The Comprehensive Scorecard Error Rate has trended downward reflecting a 10% decrease in the error rate over 6 months. In August 1997, this effort was expanded to include development of a performance improvement action plan for each on-shift licensed and non-licensed operator.
Individual improvement action plans have been developed and are in progress for all operators.
Operetor shift performance has improved, especially in the areas of a questioning attitude, conservative decision-making, and command and control. This is evident from the results of the High Intensity Training (described in Strategy 6 below), and the ongoing " Scorecard" assessment program. Increased day-to-day participation in the corrective action program, Action Request initiations and Engineering Request initiations demonstrate a questioning attitude on the part of the operators.
Communications, especially operator shift briefings, have notably improved as observed by industry peers, third party reviews, visitors, inspectors, LaSalle's
. Management Team and corporate oversight personnel. The capability of our operators will continue to be enhanced through startup training just prior to restart, as well as, our improved continuing training.
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The Out of Service (OOS) error rate was unacceptably high as of August 1997. A root
'cause was completed and numerous corrective actions were put in place including the consolidation of OOS processes, and increased accountability for following existing procedures. Even though the threshold for defining significant errors has been lowered, LaSalle Station has not experienced a significant OOS error in over 3 months.
Additionally, lower level errors in the use of out of services are being trended. These include errors such as (1) component return-to-service being delayed due to an OOS being hung without notification of the operations scheduler and (2) preparing OOS packages for work not actually requiring an OOS. This area does not yet meet our expectations but, these errors show a decline cf over 25%, having dropped from 22 to 16 per month over the last 4 months.
Because an unacceptable number of lower level human performance errors by operators still occur, Operations performance still does not meet current management expectations. This remains a key challenge at LaSalle. Continuing initiatives are being implemented to upgrade the knowledge and skills of our operators, and to raise and maintain the quality of the Operator Training Programs.
Strateav 2 - Human Performance Improving human perforrnance through clear expectations and accountability has been a primary focus at LaSalle. In January 1907, we set a focused direction for the Station to achieve a safe uneventful startup followed by a safe, long uneventful run. We defined each individual's contribution to achieving that direction. Specifically, each individual's contribution, at a minimum, must include strict procedural adherence, strong use of self-checking, a questioning attitude, and a demand for issue resolution.
A few of the measures which indicate that these expectations are understood include station surveys, questions included in Training exams, and Managers quizzing shift personnel, improved overall Station performance is an indicator that expectations are being met.
Clear Station direction and personnel expectations have been key contributors to a notable reduction in personnel errors. In early 1997, personnel errors - as measured by our Station Event Free Clock -- were occurring on an average of every 3 to 5 days.
Recently, more than 40 days passed without a station event free clock reset, and, in one case we achieved over 60 days without a station clock reset. Currently, the station event free clock averages approximately 14 days between errors. This error reduction has been achieved even while the number and complexity of evolutions in the plant has increased as we undertake major maintenance and modification work. We are now focusing on identifying trends in human performance errors at a much lower level as part of our continuous goal to improve performance. As a result of our increase in management expectations, we have identified an escalatinn trend in inappropriate actions, such as entering the radiation protection area without an electronic dosimeter.
Corrective actions have included (1) two " timeouts" during which we stopped critical path work and allowed our workers to discuss and reflect on human performance, (2) a work stoppage to aggressively address a relatively minor incident thereby reinforcing our message of safety over schedule, and (3) formation of a Human Performance Team 2
l to further drive down human errors.
Individual accountability has played a key role in reducing personnel errors. in the past, personnel have not been consistently held accountable. Recognizing that discipline is only one component of accountability, a measure of disciplinary action i
taken at LaSalle over the last year highlights a contrast with our past performance. We have taken almost three times the number of disciplinary actions in 1997 as in 1996.
More notably, we have simultaneously achieved the lowest Bargaining Unit grievance rate of all Comed Nuclear Stations. This is primarily because our workers recognize the need for improvement and the involvement of union leadersnip in decision making.
Engaging the work force to safely do it right the first time and emphasizing teamwork has resulted in a positive management-bargaining unit relationship.
Other improvements in human performance,tave also been achieved, such as a reduction in maintenance rework from approximately 5% to 2.2%; and LaSalle Station not having experienced a lost time accident in over 2 years with over 4.4 million person-hours worked.
Strateav 3 Plant Materiel Condition Both LaSalle units were shut down in the Fall of 1996 - Unit i due to equipment performance issues and Unit 2 for a scheduled refueling outage. Subsequently Senior Management made the decision to not restart the units pending a thorough review and resolution of plant and equipment performance issues.
A spocific effort to identify of issues, a number of which were subsequently determined to require resolution prior to restart of the units, began immediately after the Unit 1 shutdown and continued through July 1997. The review process was formalized in a Systen Functional Performance Review. The program was conducted for 42 systems important to safe and reliable operation and included (1) determining the required system functions derived from tne design bases, (2) identifying material condition problems that affect achieving these functions and (3) ensuring periodic testing requirements adequately confirm system functions.
Resolution of the items classified as restart issues has generated approximately 300 design changes, more than 1400 Engineering Requests and over 7000 Work Requests. Field installation has been completed for about 100 design changes.
Examples of materiel condition issues being resolved include: IRM/SRM cable replacement, SBM switch replacement (591 on Unit 1 alone), major overhauls to emergency diesel generators, Klockner-Moeller relay replacement (361 on Unit 1 alone), electro-hydraulic control (turbine) valve replacement, redesign of the lake blowdown valve, scram pilot valve replacements, significant modifications to the ventilation systems, and significant redesign of the reactor water cleanup suction being changed from cold to hot suction. Additionally, some significant regulatory commitments, such as installation of higher capacity emergency core cooling system suction strainers, are being implemented ahead of the previously committed schedule.
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'These actions are being taken to improve plant and system performance, reduce the number of challenges to our operators and safety systems, and achieve the established Station directive of safe uneventful startup followed by a safe, long, uneventful run.
Strateav 4 - Effective Enaineerina Support As discussed above, a key outage activity has been the identification and technical resolution of numerous materiel condition deficiencies in the plant. The major portion of the identification effort was completed in July 1997, with the completion of the System Functional Performance Review (SFPR). It was conducted over an 8 month period and identified over 600 issues that require resolution prior to restart. SFPR also identified an apparent generic weakness in the adequacy of Technical Specification testing which resulted in the decision to expand the review of surveillance procedures to all Technical Specification systems. The SFPR utilized tho experience of over 100 independent professionals.
The corrective actions, resulting in design changes to resolve materiel condition deficiencies identified by the SFPR and other identification processes, have been reviewed by Station Senior Management to identify those requiring completion prior to restart. Currently, about 300 design changes have been designated as required for restart. Engineering design work has been completed for all but about 60 design changes, and as mentioned under ' Plant Materiel Condition", about 100 of these design changes have been completed in the field.
The experience level of the LaSalle System Engineering work force has been improved through the hiring of experienced personnel and significantly increasing the total compliment of system engineers. As a result, the percentage of System Engineering personnel who are registered as Professional Engineers has more than doubled, having increased from 6% to 15%; Senior Reactor Operator qualified engineers increased from approximately 23% to 36%; and the number of degreed personnel increased from about 78% to 82%.
Regarding day-to-day Engineering activities, an Er gineering Assurance Group (EAG) was established in April 1997. EAG's objective is to improve the technical quality of selected engineering products. This is accomplished through in-process oversight of 10 CFR 50.59 screenings and safety evaluations, operability evaluations, and regulatory responses; and finished product oversight of design change activities such as design change packages, temporary alterations, setpoint changes, and calculations.
EAG was staffed using a combination of experienced LaSalle personnel and senior industry-experienced personnel. EAG provides feedback to individual engineers on how to improve the quality of the specific engineering product being reviewed and conveys lessons learned using coaching and tutorial techniques to improve the technical capabilities of engineering personnel.
As a measure of performance improvement, the EAG monitors product quality. This includes tha percentage of products reviewed that require rewcrk to resolve EAG 4
comments. This rework percentage has declined from 25% early in 1997 to
'approximately 10%. EAG oversight will continue until a high level of performance in this area is achieved.
Strateav 5 - Corrective Action Proaram A new corporate Corrective Action Program (CAP) was fully implemented at LaSalle on May 12,1997. This process became the underpinning of necessary programmatic improvement. A senior manager, with significant experience, was hired to provide management focus to CAP. Over 900 station personnel were trained in the new i
process and indoctrinated in the importance of the CAP. A key aspect of this training was to instill in personnel the need to write a Problem Identification Form (PIF) for all identifhd concernt
" ased sensitivity to problem identification and a lowered threshold for repo ng nave contributed to the number of PIFs being initiated by site
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personnel more t an doubling in 1997. PlFs are reviewed end dispositioned by the Event Screening Committee, currently chaired by the Operations Manager. Selected PlFs are alsn reviewed by the Plant General Manager and other senior managers.
Performance indicators monitoring CAP effectiveness have been developed and implemented. Performance Indicator data are reviewed by upper level management weekly. This, in turn, imposes strict accountability for CAP products as responsible managers must discuss overdue items, supervisory reviews, and package quality in the presence of their peers. Performance has improved in each area. For example, prior i
to improvement efforts in this area, there were 79 overdue items in February. Overdue items have been reduced to a total of 21 for the last six months.
A number of actions were taken to improve our ability to perform root cause investigations and minimize recurrence of events. These include establishing priority for root cause investigations, formation of a dedicated Root Cause Team, training of root cause investigators, and establishing a Corrective Action Review Board (CARB).
The Root Cause Team is made up of six members from the line organization including Operations, Maintenance, Engineering and Radiation Protection. This dedicated resource has resulted in increased quality of root cause investigations by improving proficiency and priority. These efforts have resulted in a decrease in repeat occurrences of similar events in 1996 compared to 1997 (26 repeat events in 1996; 10 repeat eventr in 1997 year-to-date).
The CARB is a management oversight board chaired by the CAP Manager, that ensures root cause and corrective action quality meets management expectations.
Root cause effectiveness is measured by the CARB acceptance rate of reviewed root cause reports. The acceptance rate by the CARB has improved over the past several months from 57% to 91%.
Performance indicators are monitored by management to assess the effectiveness of the program on a continuous basis, in addition, the low performance indicator thresholds that have been added for necessary action should ensure sustained 5
improvement.
Our challenge in this area is to sustain the improvements by continua!!y encouraging our personnel to identify problems, providing feedback 'as those problems are addressed, and ensuring the effectiveness of actions taken.
Strateav 6 - Trainina An Independent Self Assessment, conducted in December 1996, identified the need to improve operating crew performance and operator training effectiveness. In response, a High intensity Training (HIT) program was developed. HIT consisted of three phases:
initial assessment, week one training, and week two training. The initial part of the training included a screening evaluation process to identify performance deficiencies that required remediation prior to attending the remaining training. The evaluation consisted of giving each crew two to four simulator drill scenarios. For Shift Managers and Unit Supervisors, this screening included a critical assessment of supervisory skills, such as their ability to identify and correct performance deficiencies on their crew.
The training content was not focused on Emergency Operating Procedures as training in the past has been. This training exercised tho operators in the performance of a significantly broadened scope of performance expectations, including Abnormal Operating Procedures, which have less esequence, but are more likely to be implemented during plant operation. Additionally, higher standards were set and enforced through the course of this training, again, contrary to past training practices.
The HIT training identified operator deficiencies in the following areas: pncedural adherence and usage, emergency plan classifications and reporting, command and control, and communications. A large number of these performance deficiencies were self-identified by the crew members, indicating that the new performance standards have been effectively communicated to the operators.
Overall, the HIT program was effective in identifying and reducing operator performance deficiencies. Elements which contributed to its effectiveness included: a demanding training schedule and productive use of training time, well identified training needs, challenging simulator exercises, high standards for measuring crew performance and senior line management involvement in the training.
The challenges remaining in this area include upgrading both the training program, and the performance of training personnel, and further increasing management involvement in training to successfully complete renewal of accreditation of our operator training programs and to ensure improvements achieved will be sustained.
Strateay 7 - Process improvement The proceduie revision process has been revised to improve the quality and timeliness 6
1 of revisions to station procedures. Twenty-one specific actions have been completed.
'For example, a central procedure group was established for both Operations and Maintenance; work coordination between procedure writers and clerical support was improved; the procedure walkdown/ validation process was enhanced; and performance indiertors were developed to monitor process performance. To date,565 of 1046 operations and maintenance procedures have been upgraded.
In addition to improved quality, these efforts have increased procedure revision productivity in the maintenance and operating areas by approximately 50 percent.
Also, changes in the procedure walkdown process, including component labeling, have improved the quality of procedure revisions effecting a reduction in procedure rework i
and work delays due to procedure deficiencies.
Radiation Protection There have been many initiativos that have improved the overall quality of the Radiation Protection Program at LaSalle. A significant effort was made to reduce the percent of contaminated floor spcce at the station. We have achieved an over 85%
reduction in the amount of contaminated floor space at LaSalle, reducing it from 22.9%
to 3A%. This is a record low during a single or double-unit outage at LaSalle. Many areas such as the Low Pressure Heater Bays, Control Rod Drive (CRD) Hydraulic Control Units, CRD pump rooms and the majority of the Steam tunnels have been released for the first time. The majority of the raceways and corner rooms (90%) were released for the first time since 1992. This has resulted in an over 50% reduction in personnel contamination events from 105 in 1996 to 50 year to date in 1997.
Additionally, it has reduced the burden on our operators by reducing the number of times protective clothing needs to be donned to access areas of the plant. These improvements have been made during dual unit shutdown with high maintenance activity in tha statiun.
Reduction of personnel exposure is also an area where resources and management attention have been devoted. We are on track for a record low persor.nel exposure year, despite 2 outages with large work scopes. The end-of-year exposure goal has been lowered to 428 person-rem. This goal is the result of all departments accepting ownership and accountability for personnel radiation exposures.
Additionally, the Plant Survey Frequency Reduction Program has reduced the Radiation Protection Technician exposure and results in significant man-hour savings.
With this change, we are projecting to save 3700 person-hours and 7.5 person-rem annually.
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