ML20199C935
| ML20199C935 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/07/1997 |
| From: | Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Boulette E BOSTON EDISON CO. |
| References | |
| 50-293-96-06, 50-293-96-6, 50-293-96-80, 50-293-97-80, NUDOCS 9711200200 | |
| Download: ML20199C935 (3) | |
See also: IR 05000293/1997080
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November 7,1997
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E. Thomas Doulette, PhD
Senior Vice President - Nuclear
Boston Edison Company
Pilgrim Nuclear Power Station
600 Rocky Hill Road
Plymouth, Massachusetts 02300 5599
SUBJECT:
NRC INSPECTION REPORT NO. 50-293/97 80 AND NOTICE OF VIOLATION
Dear Dr. Boulette:
This letter refers to your October 17,1997, correspondence, in response to our
September 17,1997, letter forwarding the subject Notice of Violation (NOV). In the
response, you provided reasons for the specified procedural violations, actions taken to
address our observations regarding the Nuclear Safety Concerne Program, and an update of
your activities related to integrated corrective action plan (NOVs from inspections 50-
293/96-06 snd 96-80), originally described in your June 17,1996, January 31, and
February 28,1997 letters. You alsc indicated an additional response wculd be submitted
in about 60 day, after your staff had sufficient time to correctly identify the root cause of
the procedural compliance issues and to determino meaningful and corrective actions to
pr'eclude recurrence.
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Based on the actions take i to dato and your multi-disciplinary task force chartered to
assess the root cause and make additional recornmendations, we find the requirements of
10 CFR 2.201 have been met. Submittel of the task force findings by December 17,1997
is acceptable.
Thank you for informing us of the corrective and preventive actions ~ documented in your
letter. We will continue to examine these actions in future inspections of your licensed
program. Your cooperation with us is appreciated.
Sincerely,
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Criginal Signed By:
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Richard J. Conte, Chief
Project Branch No. 8
Division of Reactor Projects
Docket No. 50-293
cc w/o cy of Licensee Rerponse Letter:
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L. Olivier, Vice President - Nuc. tear and Station Director
C. Goddard, Plant Department Manager
N. Desmond, Fiegulators Relations
D. Tarantino. Nuclear information Manager
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9711200200 971'107
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ADOCK 05000293
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E. Thomas Boulette, PhD
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cc w/cy of Licensee Response Letter:
R. Hallisey, Department of Public Health, Commonwealth of Massachusetts
The Honorable Therese Murray
The Honorable Joseph Gallitano
B. Abbanat, Department of Public Utilities
Chairman, Plymouth Board of Selectmen
' Chairman, Duxbury Board of Selectmen
Chairman, Nuclear Matters Committee
Flymouth Civil Defense 0; rector
P. Gromer, Massachusetts Secretary of Energy Resources
J. Miller, Senior issues Manager
J. Fleming
A. Nogee, MASSPiRG
Office of the Commissioner, Massachusetts Department of Environmental Quality
Engineering
Office of the Attorney General, Commonwealth of Massachusetts
T. Rapcae, Massachusetts Executive Office of Public Safety
Chairman, Citizens Urging Responsible Energy
Commonwealth of Massachusetts, SLO Designee
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E. Thomas Boulette, PhD
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Distribution:
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Region 1 Docket Room (with concurrences)
PUBLIC
Nuclear Safety Information Center (NSIC)
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NRC Resident inspector
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H. Miller, RA/W. Axelson, DRA
R. Conte, DRP
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M. Conner, DRP
C. O'Daniell, DRP
R. Eaton, NRR
A. Wang, NRR
K. Kennedy, OEDO
. R. Correia, NRR
F. Talbot, NRR
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DOCDESK
Inspection Program Branch, NRR (IPAS)
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-DOCUMENT NAME: G:\\ BRANCH 8\\PIL9701. REP
T3 seemius e sepy of thle document, inmoeto in the boat 'C' = Copy without ettechment! enclosure
'E' = Copy with attachnwnt/ enclosure
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DATE
11/05/97
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gjg , ] lCIAL RECORD COPY
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no.um anum
Pdgem Nuc a P er Staton
Plymouth, Massachussus 02360
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October 17,1997
E. T. Boulette, PhD
BECo Ltr. 2.97-104
Senor Vce President - Nuclear
U.S. Nuclear Regulatory Commission
Document Control Desk
Washington, D.C. 20555
Docket No. 50-293
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License No. DPR-35
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Reauest for Extension for Repiv to Notice of Violation 97-80-01
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This letter requests an extension of 60 days in the required reply to Notice of Violation
(NOV) 97-80-01. This request is made to allow sufficient time to correctly identify the root
cause of the procedural compliance issues which confront the station and, thereby, to
determine meaningful and effective corrective actions to preclude recurrence. Effectively,
this letter requests the date for a final response tc NOV 97-80-01 be extended from
October 17 until December 17,1997.
In reviewing the record of NRC comments and violatinns and the trends established under
our own self assessment and corrective actions processes, procedural compliance is not
meeting our expectations. The procedural violation examples cited by the NRC are
symptomatic of the overall procedural compliance issue. LimitinC Jctions to correction of
the instances cited in the NOV would not necessarily establish meaningful and effective
change. Sufficient information on the types of errors and their implications on human
performance and organizational controls is now available in our corrective action data
base. Thus, a multi-disciplinary task force has been formed to analyze these procedural
compliance data, assess root cause, correlate the relationship to the previous and current
40500 corrective action activities, and recommend meaningful solutions. This task force
is intensively engaged in the process of driving out a root cause; however, the processes
involved are romplex and require additional time for correct characterization. An
extension is necessary to allow adequate time for this process to occur.
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The reasons for the specified procedural violatics cited in NOV E -60 01 cro provided
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as Enclosure 1. The completed corrective actions which resulted and the status of
those actions to date are also included. A better understanding of the rnot cause of
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procedural compilance issues at Pilgrim Station and actions to be taken to preclude
recurrence will be dolineated in the response to the violation on er before December
17,1997.
Also, actions have been taken to nddress the NRC team's observations with respect to
the implementation of our Nuclear Safety Concerns Program. These actions are
described and included in Enclosure 2 to this response.
As noted in the inspection report, the overall implementation of the problem
identification, root cause, and corrective action processes has improved since the
NRC's previous inspection in this area. We attribute this to the integrated corrective
action plan activities described in BECo letter dated January 31,1997, submitted in
response to NRC inspections 96-06 and 96-80 (40500 Inspection). An update of these
activities is provided for information as Enclosure 3.
Should you have any questions or require further clarification, please do not hesitate to
contact me.
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. Boulette, P D
JDK/dmc/V978001
Enclosures
1. Initial Reply to Notice of Violation
2. Nuclear Safety Concerns Program Discussion
3. Update of NOV 96-06-02 Corrective Action Activities
cc w/ encl:
Regional Administrator, Region 1
U.S. Nuclear Regulatory Commission
475 Allendale Road
King c
russia, PA 19406
Senior Resident inspector
Pilgrim Nuclear Power Station
Mr. Alan B. Wang
Project Manager Project Directorate 1-3
Office of Nuclear Reactor Regulation
Mail Stop: OWF 1482
1 White Flint North
11555 Rockville Pike
Rockville, MD 20852
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ENCLOSURE 1
Initial Reply to Notice of Violation
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On September 17,1997, the NRC issued the 40500 team inspection results of the Pilgrim
Station corrective action processes (NRC IR 97-80). The NRC identified three specific
issues relating to procedural compliance at Pilgrim Station which became NRC Notice of
Violation (NOV) 97-80 01. The violation is specified as follows:
During the NRC inspection conducted from July 21 - August 1,1997, a violation of NRC
requirements was identified.
In accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR 50 Appendix B, Criterion V requires in part that activities affecting quality shall be
accomplished in accordance with procedures.
Also, Criterion XVI requires in part that
measures be established to assure conditions adverse to que.lity such as deficiencies and
nonconformances are corrected.
Contrary to the above, from July 29,1997 to August 1,1997 the corrective action procedure
measures were not accomplished as noted below:
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(1)
Procedure No.1.3.121, " Problem Report Program." revision 1, dated May 28,1997,
Step 6.6.1 [9] states that "the apparent cause analysis shall be signed by the evaluator
and the menior if the evaluator wat not formally trained in HPl methodologies."
For prob!em report PR 97.9220, trip of "B" Residual Heat Removal Pump, the individual
performing the root cause analysis was not formally trained in HPl methodology nor
was it evident that a mentor assisted in the evaluation.
(2)
Procedure No.1.3.121, " Problem Report Program" revision 1, dated May 28, 1997,
Step 6.7.[5] states that " identified corrective actions are required to be tracked to
completion according to Action items associated with the IADB (integrated AcCon Data
Base) or according to other corrective action tracking processes determined to be
appropriate by the OST (Operations Support Team)."
As of July 29,1997 the corrective actions identified in the March 17,1997 Training
Department memorandum entitled, " Assessment of Operator Parformance During RPV
Level Transient and Subsequent Unit Trip Occurring February 15,1997 (Rev 1)," were
not entered into the ir,tegrated Action Data Base for proper implementation and
tracking (or other process determined by OST) and as such were not completed.
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(3)
Independent Oversight Team Work Instruction IOTWI 001, revision 0, dated July 15,
1996, Section G.1, states that the IOT Manager will provide a monthly report to the Site
Director summarizing the activities that were reviewed, problems that were not4 and
any proposed corrective actions that are recommended. Section 7.2 states that a
quarterly executive summary shall be provided to the Senior Vice Presidant Nuclear
identifying those areas that were reviewed during the previous month, areas for
improvement, and recommendations in effect those improvements.
The IOT Manager failed to provide a monthly or quarterly summary of IOT activities
reviewed, problems identified, or recommendations to effect improvements in the IOrs
December 1996 through January 1997 Monthly Trend Roports.
This is a Severity Level IV Violation (Supplement I).
Discussion
in this response, the reasons for each of the instances of procedural noncompliance are
addressed along with the specific corrective actions which have been taken or are
planned for each instance. The broader issue of procedural usage and why
noncompliance with procedures remains an issue at Pilgrim Station will be addressed in
the December response. The root cause analysis currently ongoing will !dentify the
overall cause of procedural compliance issues at Pilgrim Station and include the
corrective steps that will be taken to avoid further violations and the date when full
compliance will be achieved. The reasons for the specific instances of procedural
noncompliance are as follows:
(1) Failure to comply with the requirements of PNPS 1.3.121. " Problem Report Program,"
in that an apparent cause analysis was not performed by, or otherwise reviewed by a
person trained in HPl methodologies as was required. Specifically, in the instance of PR
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97.9220, trip of the "B" Residual Heat Removal (RHR) Pump, the individual who
performed the root cause analysis was not formally trained in HPl methodology nor was it
evident that a mentor assisted in the evaluation.
Reasons For The Violation
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The Problem Report Coordinator served as mentor to the evaluator and had
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attended the critique for the noted event. During the evaluation process, the
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coordinator provided guidance to the evaluator. However, the coordinator failed to
sign the evaluation response as the mentor when the problem report was submitted
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to Operat;ons Support for processing. This failure to sign as the mentor was due to
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an oversight during the paperwork closure.
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fdgective Steos Taken And Results Achieved
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The Coordinator corrected the paperwork and, because of his involvement, is
aware of the issue in its entirety. Also, the Operations Support Team Leader
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issued a notice to all personnel qualified as mentors and to all NUORG managers
to bring the circumstances of this failure to follow procedures issue to their
attention. The notice re-emphasized the requirement that mentors must cosign root
cause and common cause analyses in which they served as the mentor. It also
reminded all that regardless of the ability of the individual involved, Procedure
1.3.121 requires a minimum qualification level for performance of root cause and
apparent cause analysis. Department managers were also reminded in the notice
that they also approve the analysis documents and should take steps to assure that
personnel are qualified or mentored. A listing of qualified personnel was included
in the notice for information.
Heightening the awareness of this missed procedural element and the ramifications
associated with failure to follow all elements of the procedure has lead to
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improvement in the overall quality of apparent cause analyses associated with the
problem report process.
(2) Failure to comply with the requirements of PNPS 1.3.121, " Problem Report Program"
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in that identified corrective actions were not tracked to completion in the Integrated Action
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Data Base (IADB). Specifically, the corrective actions identified in the March 17,1997
Training Department Memorandum entitled, " Assessment of Operator Performance During
RPV Level Transient and Subsequent Unit Trip Occurring February 15,1997 (Rev.1)"
were not entered into the lADB for proper implementation and tracking and as such, post
startup action items were not completed.
Reasons Fgr The Violation
On 2/21/97, PR 97.0937 was written to document perceived nonconservative
decisions associated with feedwater level control during a planned reactor
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shutdown in preparation for RFO 11. In an effort to ensure objectivity, the
Operations Department Manager (ODM) requested that the Operations Training
Department perform an independent assessment of the operating crew's
performance; however, he did not inform the assigned training personnel that their
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response would be used to respond to the problem report. The operations training
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personnel completed the evaluation ard provided a response in a memo format
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without specifying that any corrective actions were required but rather provided
some recommendations. The noted recommendations were captured as RR
97.0030, and the problem report was closed on 3/18/97.
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On 3/21/97, PR 97.1363 was initiated based on NRC NOV 97-01-01, which
indicated that operation of the feedwater level control system was not performed in
accordance with station procedures. This problem report was determined to be a
Significant Condition Adverse to Quality (SCAe; and was assigned to the assistant
ODM for performance of a root cause analysis. The ODM directed the assistant
ODM to utilize the training assessment in formulation of the root cause analysis. At
the same time, the ODM closed RR 97.0030 based on planned pre-startup training
and the misunderstanding that the remaining recommendations from the training
assessment would be addressed by the root cause analysis for PR 97.1363.
However, the root cause analysis failed to adequately consider the remaining
recommendations provided in the training assessment, and the Operations
manager failed to ensure the recommendations specified by the training
assessment were incorporated into the root cause response when he reviewed it
for approval."
Corrective Stoos Taken And Results Achieved
The root cause analysis for PR 97.1363 was revised to incorporate required
corrective actions as PR actions in the IADB tracking system. Operations
management and Operations Support have been directed to be more discriminating
when desc'ibing actions to be taken to correct a problem versus actions that are
recommerided for enhancement.
(3) Failure to comply with Independent Oversight Team Work Instruction OllWI.001 in
that required periodic reports were not submitted as required. Specifically, the IOT
Manager failed to provide a monthly or quarterly summary of IOT activities reviewed,
problems identified, or recommendations to affect improvements in the IOT's December
1996 and January 1997 Monthly Trend Reports as required by the work instruction.
Spasons For The Violation
The IOT assessed plant oata on a monthly basis to determine performance
indicators that related to human perfctmance at Pilgrim Station. A monthly human
performance report was routinely submiNed to the Station Director and the rest of
station management. The report identified human performance problems at the
station and made recommendations fnr improvement as appropriate. The report
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focused on how well the staff was self identifying problems, reviewed human
performance issues, and attempted to provide insight that would be of use to
management regarding human performance. The report generally satisfied the
requirements of IOTWI.001 except it failed to summarize the activities that were
reviewed by the IOT in the previous month due to an oversight on the part of LOT
management.
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A quarterly executive ste. mary was not provided to the Senior Vice-President,
Nuclear at required by IOTWI.001, it was ir correctly believed to be redundant to
the executive summary contained in the monthly report which was provided to the
Senior Vice-Prealdent. Nuclear, and that the monthly reports provided better insight
into station performance. However, the assumption that the monthly report
summaiy was redundant to the quarterly report was an error of assumption made
by IOT management.
Corrective Steps Taken And Resu;ts Achieved
The IOT work instruction was revised on 9/30/97 to clarify the information that is to
be provided to senior management on a monthly basis. In addition, the monthly
human performance report has been revised to provide more in-depth analysis of
station problems. These enhancements will continue to evolve as our ability to
analyze data improves.
Quarterly reports will be submitted as required by the work instruction commencing
with a report for the third quarter of 1997.
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ENCLOSURE 2
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Nuclear Safety Concerns Program Discussion
NRC Observation
With respect to the !mplementation of your Nuclear Safety Concems Program, the team's
observations of poor identification, organization, and tracking of issues, raises doubt on the
overall effectiveness of this piocess. As a confidential avenue and " safety net" to omployees
or contract persor;nel who feel the normal problem reporting and corrective action processes
have not satisfied their particular concem, this process's credibility appears to be severely
diminished. We request that you respond to this letter and address tho acids you ' nave
taken or plan to take related to your Nuclear Safety Concerns Program.
Discussion
The existence and function of the Nuclear Safety Concerns Program (NSCP)is
communicated to employees using at least seven different methods. The program is
designed to permit any employee or contractor to identify issues that he or she believes
warrant investigation. At the time of the 40500 inspection, only two issues had been
identified to the program during 1997. Neither of these issues had been closed at that
time. At present, eleven concems have been identified for the 1997 calendar year.
The organization of the program is such that each concern is assigned a unique
identifying number, and a file is created to capture all of the documentation submitted on
an issue. Due to the nature of some of these issues, the files used to capture potentially
relevant documentation may be large and may be difficult to understand and audit. In
addition, due to the nature of some concerns, the relationship of each piece of
documentation to the concern may be difficult to ascertain, particularly during the working
stage. All of these files have been reviewed and organized to make them more
"auditable" both before and after closure. Each current file has been placed in a separate
tabbed binder (s). tJpon closure of a concern, a complete audit of each file is performed to
ensure all key documents are present in the file and that it meets reasonable criteria for
auditability.
The status of each concem is tracked by periodic reviews of open or unresolved concerns
to determine whether timely and appropriate progress, in consideration of the potential
safety significance of the icsue, is being achieved. In addition, a checklist has been
implemented to ensure key actions required by the procedure are accomplished on time.
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Witti respect to specific inspection findings, the procedure governing the NSCP,
NOP93A2, defines those issues that are considered appropriate for the NSCP. This
definition is necessary to help ensure the program is not mis-used for issues and
purposes other than genuine nuclear safety issues and to ensure the NSCP does not
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undermine or circumvent existing corrective action processes. The procedure states that
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a Nuclear Safety Concern is "Any condition, practice, or event for which an individual
belicves adequate resolution has not been obtained within the line organization and which
may adversely impact nuclear safety." Our definition of nuclear st" 's the same es that
identified in 100FR50.2 under Basic component. As a result, e
oloyee concems
that do not meet this procedural requirement may be evaluatr
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safety concerns in a manner consistent with our procedure, in
Mr: 24 et issue to be
considered as a nuclear safety concern, then inust be an atte,1 * :o#
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the line organization, and the issue must be nuclear safety relatec
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or employees who request anonymity nesd not meet these requirei
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The inspection team's observation concerning ceitain procedural weakr. esses is valid.
Changes / additions have been incorporated into the soplicable procedures as a result.
The procedure dealing with employee exit interviews (procedure 1.3.77) has been revised
so that employees are only reminded of the existence of the NSCP and are not required to
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sign or otherwise indio 'o any intent to use or to not use the program, thereby, preserving
complete confidentiality. No contact names or phone numbers are included in this
procedure; hnwever, NGCP contact numbers are posted at a variety of locations
throughout the plant, and the methods for contacting the program administrator are well
publicized.
The Nuclear Safety Concem Notification Form has been incorporated as Attachment 2 to
NOP93A2 in ad :, .lon to its current availability at several convenient locations within the
organization. NUP93A2 states that use of this form is optional, and concerns may be
reported by phone, in person, via electronic mail, by Fax or through any other reliable
communication method. The NSCP Administrator creates the Nuclear Safety Concem
Notification Form if the concern is tubmitted through a different media.
The procedural requirement for a Nuclear Safety Concerns Log has been eliminated.
This log served only as an administrative tool for the purpose of keeping the Senior Vice-
President, Nuclear informed of the status of Nuclear Safety Concerns. A similar
instrument and frequent face-to-face meetings with the NSCP Administrator provide high
program visibility and ensure the Senior Vice-President, Nuclear is fully cognizant of
program status.
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ENCLOSURE 3
Update of NOV 96-06-02 Corrective Action Activities
Boston Edison Company (BECo) responded to Violation 96-06-02 by letter dated January
31,1997. That response provided a detailed description of changes taking place to the
Pilgrim Station corrective action processes and provided additional details of an
. integratad set of corrective actions established to address procedural usage and
adequacy issues identified in NRC Inspection Reports 96-06 and 93-80 (40500
Inspection).
During implementation of the various committed corrective actions, the original scope, in
some cases, has been expanded or reduced to accommodate the end results being
sought. Therefore, a status update of the specific integrated plan activities including
scope and schedule revisions is provided.
The integrated corrective action plan committed in the January 31,1997, letter included
activities to be undertaken in the following areas:
Procedures Process Redes:gn
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MOP /NOP Revisions
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Other Procedure Changes
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Modification Process Redesign
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Training
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Procedures Process Redesion
The scope of this effort is to redesign and implement the process for developing,
reviewing, and approving procedures. The new ensure will ensure revisions are produced
in a timely manner and require less effort to maintain.
A multi-functional breakout team has identified the required process changes and is
currently in the change implementation stage. The new process will streamline the review
and approval process. For example, the person modifying the procedure will retrieve all
applicable signatures and approvals prior to starting the word processing phase. Also,
the number of signatures needed for approval is being reduced. Reducing the number of
signatures and approvals prior to entering the typing and Operations Review Committee
(ORC) review stage of the process will significantly reduce the time required to process
procedures.
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The revised process will also provide for a broader class of field changes that allows work
to continue without waiting for the full procedure change and issue process to be
enmpleted. This will improve the usefulness of plant procedures in the work control
process. In the past, delays in the completion of some tasks have been due to procedure
interpretation and missing detail. Thess problems will be easily corrected using the new
process, thereby, permitting work to continue in a more timely fashion.
Please note, however, that current restrictive language in the Administrative Section of the
PNPS technical specifications needs to be revised to allow this field change procedure
revision capability to take place. The needed proposed technical specification changes
were submitted for NRC review and approval by BECo letter dated September 19,1997.
It is our understanding based on feedback from the NRC Project Manager that, because
this change was considered by the NRC reviewers as a partial Standard Technical
Specification conversion submittal, it would not be reviewed until the full conversion was
submitted. We are working with the Project Manager to pursue an alternative strategy.
Completion of this process redesign activity is contingent upon working out a timely
success strategy. As such, additional options for traaking out this particular portion of the
procedures process redesign and implementing various other portions are being studied.
We will update the status of this issue accordingly in the December submittal.
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The ability to modify procedures in the field, to add missing detail or change incorrect
detail will, over time, improve the quality of the procedures. All workers and their
supervisors will have the ability to make timely changes to their procedures through a
simplified process. This is expected to enhance worker ownership for procedures.
Continuous improvements in the detail and efficiency of procedures by the people
performing the work should result in higher quality procedures that are easier to follow
and comply with.
Mission Oroanization & Policies (MOP) / Nuclear Oraanization Procedures (NOP)
Revisions
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A top down review of organization procedures and policies was conducted in order to
integrate as many higher level policy and procedural elements of performance into lower
tier implementing procedures. This. effort was initiated to establish a clearer tie between
policies and implementing procedures. The MOP document has been eliminated. Certain
policies and aspects of others still considered appropriate have been revised as
necessary and consolidated into one NOP entitled, Nuclear Organization Policies.
The NOPs were reviewed to ensure a clear reflection of high management standards for
safety, compliance, error avoidance, and prevention. Elements of NOPs that could be
more effectively implemented as lower tier procedures have been restructured to achieve
tha objective. Changes to the lower tier station administrative procedures are continuing
and are still planned for completion by the end of 1997.
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Other Procedure Chanaes
This activity consisted of submitting a Boston Edison Quality Assurance Manual change
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by the end of September 1997 to the NRC to consolidate the Deficiency Report (DR) and
Non conformance Report (NCR) processes into the Problem Report (PR) process. The
_
reason for this activity was to provide the ability to more consistently capture data and
trend human performance data through the comprehensive PR data base.
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The changes to Section 16 of the Boston Edison Quality Assurance Manual (BEQAM)
were approved on September 30,1997, to retire the DR process. Concurrently, changes
were approved to the governing procedure for the PR process (PNPS 1.3.121) to address
prs issued by Quality Assurance as a result of oversight activities,
it was originally assumed such a change would necessitate prior NRC approval.
However, subsequent review of the changes concluded the changes, as approved, did not
result in a reduction in commitinent. Specifically, process changes were included to
ensure continued compliance to Regulatory Guide 1.144, as specified in BEQAM Section
2.
Also, the plan to retire the NCR process for reporting of nonconforming hardware items
has been reconsidered. Instead, prior to the start of RFO#11, Quality Assurance
instituted the practice of issuing a PR for every NCR. This practice ensures that potential
human performance errors are explored for each identified nonconforming item. This
practice fulfills our original intent to improve the quality and value of our trend reports and
ensure human performance data is consistently captured and analyzed. This corrective
action commitment is considered complete.
Modification Process Redesian
The modification process changes consist of introducing a modification team concept,
streamlining where possible, consolidating forms / paperwork, and simplifying the close-out
mechanism. The plant operations and maintenance departments will play a significantly
more effective iole now in the modification process as members of the modification team.
Completion of the procedure revisions and personnel training is expected to be completed
on or before December 31,1997.
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Additional classes in root cause analysis (RCA) training have been conducted for workers,
managers, and supervisors. More are scheduled. Personnel trained will remain cartified
as long as they demonstrate _ proficiency in RCA and complete at least one RCA every 3
years. This correctiva action commitment is considered complete. Additional classes ir.
human performance error prevention for managers and workers are ongoing.'
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Approximately 60% of the workforce hrss been trained to date. We anticipate completiun
of the remaining workforce by the end of the first quarter 1998.
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The Plant Manager is continuing to provide training to NUORG personnel on a periodic
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' basis to reinforce management expectations on procedural adherence.
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