ML20202E500
| ML20202E500 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/31/1997 |
| From: | Tulon T COMMONWEALTH EDISON CO. |
| To: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9802180166 | |
| Download: ML20202E500 (4) | |
Text
t
+
Commonwealth I dimn Company tiraidwood Generating Station Houte e1. Inos Hi liracet ille. ll. 60 607%I9 17 Og, reim m -
h _ _g ps_m i
December 31,1997 bel EM UhOy NCCH Mr. A. Bill Beach 4'
Regional Administrator U.S. Nuclear Regulatory Commission Region Ill 801 Warrenville Road Lisle, IL 60532-4351
Subject:
Response to the Systematic Assessment of Licensee Performance Report Braidwood Nuclear Power Station, Units 1 and 2 l
Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Numbers: 50-456 and 50-457
References:
- 1) A. Bill Beach letter to T. J. Tulon dated October 17,1997, transmitting SALP 14 Report Number 50-456(457)/97001
- 2) SALP Public Meeting dated December 2,1997 Reference I refers to the Systematic Assessment of Licensee Performance (SALP)
Board Repon, Period 14, for Braidwood Station. The report covered the period from October 1,1995, through August 30, 1997. The information documented in the repoit was discussed during a public meeting held at Braidwood Station on Tuesday, December 2,1997. Braidwood Station concurs with the information provided in the report and appreciated being given the opportunity to discuss the SALP results with members of the NRC Staff. This letter documents information discussed during the meeting and provides additional details.
Braidwood Station is pleased to have received a Category I rating in the functional areas of Plant Operations and Plant Support. It is recognized that these ratings reflect a historical evaluation and the challenge is not merely to sustain superior peiformance in these areas but rather to aggressively work to higher, self-imposed standards of excellence.
in Operations, efforts continue to address concerns associated with the Configuration Control and Out-of-Service (OOS) processes. Some of the actions that have been implemented and continue to be pursued include:
\\
Reinforcing peer checking and observation skills through training
]o e
administered on a "SelfCheck Simulator",
f (/V
/
9002180166 971231 I
PDR ADOCK 05000456
/
i G
PDR l
l'11IlllWINIII l
e t
3 4
D A
j d k'niGHl)(NimpJn)
Mr. A. Bill Beacii Page 2 l
Decemhr 31,1997 l
Evaluating performance in both areas (Con 0guration Control and OOS) by using performance indicators established by the Opciations Managers at the six Comed nuclear stations, improving the pre job biienng process to be more standardized and e
simplined, D%chmarking performance in Operations with other Comed plants as well e
es other utilities, implementing a "One Stop Shop" during the r t recent refueling outage, e
A2R06, to promote a fully integrated Work En ution Center, Establishing a " Scorecard" program which is a performance monitoring tool utilir.ing both peer checks and supervisory monitoring.
in the Plant Support ftmetional area, Draidwood Station was plead with performance in Radiation Protection, Security, and Emergency Preparedness during the last sal.P cycle, llowever, it is recognized that improvements are necessary a enhance performance, particolarly in the Fire Protection area While we consider the.ation's f
brigade to be well trained and the oppression and detection systems are n, good riel condition, the station will continue to focus on human performance h' the Fire 1
- ction area Fire Safety tailgate sessions have been given to work group e the plant to improve awaieness. in addition, the Fire Protection stafThas been conducting increased plant walkdowns to monitor compliance with respect to fire protection policies and procedures. This group has also increased their involvement in pre-outage planning and enhanced their availability to wcrkers during the most recent outage by being present in the "One Stop Shop" In addition, Fire Protection Training has been administered to contractors, first line supervisors, and Radiation Protection zone technicians to also enhance awareness among this group of station personnel.
Significant management attention was applied in response to Radiation Protection events that occurred during the mast recent refuelir.g outage, i2R06. A meeting was held with Contract Radiation PnNection Technicians (CRPTs) to communicate expectations a:isociated with self checking, attention to detail, questioning attitude, and integrity / trustworthiness. In addition, a discussion was held with contractor crafl and Comed maintenance and operations personnel. This session highlighted several radiation worker events and discussed the problems that were encountered as well as the correct actions. To achieve a broader dissemination, information discussed during this meeting was also featured in the station's inspaper, the " Screaming Eagle."
The Category 2 ratings given in the functional areas of Maintenance and Engineering orovide a challenge for the Station to achieve improved ratings through stronger performance during the current SALP cycle.
Dr'tidwood is pleased that improvements were recognized with respect to plant material condition, problem identincation and resolution, conduct of maintenance and surveillance test activities, and self assessment. Improvements have been made in the j
0 hir. A.1111111cech Page 3 December 31,1997 station's ability to plan and perform work as demonstrated by the reduction in the corrective maintenance backlog. The Station intends to utilize this improved ability to plan and execute work in order to redu e the backlog to less than 1000 corrective items by January 1,1998, in addition to the effons that are underway to improve
'3 procedure adherence performance at the site, the Maintenancs 'Jepanment is working to address procedure adherence concerns v the department level. Exarr,les of actions that have been completed or are being implemented in thia area include:
l A " vertical review" of the hiechanical hiaintenance Department has been e
conducted to evaluate procedure adherence issues.
Suggestions for improvement, includir g new ideas as well as possible resolutions were discussed. As pan of a recent Corporate Safety Review Board meeting, the hiaintenance Subcommittee reviewed the hkchanical hiaintenance
" vertical review" pro.ess and expanded the review to all of the line departments in the Maintenance organization.
A " horizontal review" of Maintenance will be conducted to gather additionalinformation not revealed in the reviews specified above. This is scheduled to be completed in the Dst quarter of 1998.
During the first quaner of 1998, " Administrative / Conduct of Maintenance Training" will be conducted for personnel in the Maintenance Department.
A " Scorecard" program, similar to the one currently being used by Operations, will be implemented by Maintenance duririg the first quarter of 1998.
Performance indicators will be developed and selr. assessments will be conducted to monitor performance with respect to the long term action plan. This action is scheduled to be completed during the second quarter of1998.
Using information gathered from the actions mentioned above (reviews, training, and programs initiated), a long term action plan will be developed by Maintenance to define Mainter ance Mandards, manage the changes to procedures / work package instructions, and improve pre job walk downs /
post job feedback. This plan will also be completet during the second quarter of 1998.
11raidwood's Engineering performance has continued to improve, and personne; in these areas have provided good support to other work groups. This is evidenced by reductions in Operator Workarounds, Temporary Modifications, and resolution of severci significant equipment problems. Aggressive actions are being implemented to address problems related to attention t<> detail. For example, following recently noted problems with surveillances, ah procedures to be used in the subsequent refueling outage were reviewed and revised as necessary to enhance their clarity and case of execution.
System Engineering personnel were given additional training on the supervision of major surveillances and cirective teaming w;th licensed operators.
Training was also provided on the Generic Letter guidance foi addressing through wall leakage from ASME Code Class 1,2, and 3 systems as a result of a past violation. In addition, an improved Test Engineer training and qualification program is unJer
___ __-_ __ _ _ N
Mr.~ A. Bill Besch Page 4 December 31,1997 development to,o Safety Evaluation Training, Operability Determination training, and Human Error Reduction Training have been provided. The Test Engineering training material will be developed by September 30,1998.
Braidwood Station accepts the challenges presented during the SALP Meeting. We are pleased with the noted improvements in all four functional areas and are actively pursuing a higher level of performance. If you have any questions regarding this letter, please contact the undersigned.
Sincerely,
/
imothy J. Tulon Site Vice President
. Braidwood Nuclear Generating Station NRe>97139fh de -
cc:
A.B. Beach, NRC Regional Administrator, Region til
-0.F. Dick, Jr., Project Manager NRR C.J. Phillips, Smior Resident inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS
___._____-.___.____m._.m__.___.__m_