ML20202E513
| ML20202E513 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/01/1997 |
| From: | Jamila Perry COMMONWEALTH EDISON CO. |
| To: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| JSPLTR:97-0203, JSPLTR:97-203, NUDOCS 9712080059 | |
| Download: ML20202E513 (9) | |
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(.ommunurahh 14hson (4 mpan3 Drewirn Generating Station Me Nonh Drrsicn Road
' Morns.11 nmo irmis v u 292o December 1,1997 JSPLTit: 97-0203 Mr. A.13illlleach llegional Administrator U. S. Nuclear llegulatory Conunission
" ":o n lil h.i Warrenville 1(cad Lisle IL 60532-4351
Subject:
Dresden Station Units 1,2 and 3 Dresden Station Perfonnance N1(C Docket Nos.50-010,50 237, and 50 249 Iteference:
Letter from J. S. Perry to A.11. Deach dated May 23,1997 regarding Dresden Station Perfbrmance
Dear Mr. Ileach:
The purpose of this letter is to provide a sununary of Dres6n Stat on perfbrmance during i
the past six months. As noted in the above reference, since 1994 we have improved perfbnnance, and demonstrated sustained improvement, in many areas in which Dresden perfbnnance had been weak. In the past six months, we have continued to sastain this overall improving trend. In many areas, objectis e measures show our peribnnance is now consistent with or better than the average perfbrmance of peer nuclear power plants, Nonetheless, we remain Ibcused on improvement and understand that positive perfbnnance results must continue.
Dresden Puformance Compared to Industrv Peers Dresden perfbnnance has continued to improve as measured by industry wide indicators.
In March 1997, Comlid identified seven widely used nuclear industry indicators to track progress toward meeting an overall goal of having all Comlid nuclear stations perfbrm at a level at or better than the average ofindustry peers by the year 2000. Dresden performance is expected to meet five of the seven 1997 targets for these indicators.
These include:
Automatic Scrams While Critical -- There have been no automatic scrams at Dresden during 1997 (Dresden target is less than or equal to one per unit per year). The last f'
,,Uf 7 automatic scram on Unit 2 occurred in 1991; the most recent automatic scrani on
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Unit 3 occurred in May 1996.
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4 December 1,1997 JSPLTR: 97 0203 Mr. A. Ilill lleach Page 2 of 9 Safety System Actuations -- There have been no safety system actuations in the past year (Dresden target is less than or equal to one per unit per year).
Collective Itadiation Exposure -- Exposure for 1997 is at 213 rem (average per unit) as of the end of October 1997 (Dresden target is less than or equal to 245 rem per unit for the year). Radiation exposure for all of 1997 is currently projected to be an average of 223.5 rem per unit - approximately the same as the industry average of 223 rem per unit. This continues the strong improving trend achieved in 1996, when Dresden recorded a collective radiation exposure 205 rem per unit, a reduction of more than 50% from averages during 1991-1995. The 1997 exposure level is particularly significant because in 1997, unlike 1996, Dresden conducted a refueling l
outage (on Unit 3).
Safety System Performance - Dresden has achieved a safety system performance level of.0095 as of the end of October 1997 (the Dresden target is less than or equal 10.02). Safety system performance is the sum of the unavailabilities of the trains in key safety systems divided by the number of trains in each system. This performance reDects the improved material condition of the station and improved ability to plan and implement online maintenance.
Industrial Safety Accident Rate (ISAlt)-- Dresden has continued to reduce the number and frequency ofindustrial safety accidents at the station. The ISAR for 1997 year to date is.12 (the Dresden target is.4 and the 1996 industry average was
.44). This represents a continuing improving trend: in 1996 Dresden's ISAR rate was.9, down from 1.0 in 1995 and an average of greater than 2.0 during 1990 1994.
The improvements in Collective Radiation Exposure and ISAR indicate greater care and attention to detail and safety by those performing work in the plant.
Two of the 1997 industry indicator targets will not be met. These are Unit Capability Factor and Unplanned Capability 1.oss Factor. The 1997 Dresden target for Unit Capability Factor is 75.8% (average for both units). As of the end of October 1997, the Dresden units have a combined Unit Capability Factor of 69.5%, and performance for the full year is expected to approach the target. This figure represents substantial improvement from previous years: the combined unit capability factors for Dresden during 1994-1996 averaged 41.5%. Also, the average Unit Capability Factor since the end of June 1997, when Dresden Unit 3 completed its refueling outage, has been 94.9%.
Similarly, the Dresden target for Unplanned Capability Loss Factor i; 13% (as erage for both units). The Dresden Units' average Unplanned Capability Loss Factor for 1997 as of the end of October is 17.95%. While exceeding the goal, this figure is a substantial improvement from previous years: the combined Unplanned Capablity Loss Factors for Dresden during 19941996 averaged approximately 40%. The average combined
December 1,1997 JSP!Jit: 97 0203 Mr. A.11111lleach Page 3 of 9 Unplanned Capability Loss Factor for the Dresden units since the end ofJune 1997 has been 5%. The improvements in Unit Capability Factor and Unplanned Capability Loss Factor reflect improved material condition of the station and improved ability to complete work.
Overall, our industry ec.nparison indicators show that we are now either consistent with industry average performance or that strong improvement toward industry averages is occurring. We believe that Unit Capability Factor and Unplanned Capability Loss Factor are indicators that lbliow improvements in material condition, operations perfbrmance, and work completion. As noted below, we have made improvements in each of these areas in recent years and therefore expect these indicators to show continued improvement as we go Ibrward.
Operations l
Operational perfbrmance experienced some problems in late June and August 1997, but responsive action has been taken and the improving trend noted during 1996 and early 1997 has resumed in response to problems involving procedure adherence and attention f
to detail by Operations personnel, crew standdowns and training on lessons learned were conducte 1.
Most perfbrmance indicators fbr 1997 show continued improvement. Operations peribrmance indicators include:
Out-of-Service errors have been reducu. from 16 in 1996 to 2 in 1997, with none since April 1997.
There have been sixteen Personnel lirror Licensee IIvent Iteports (seven in Operations)in 1997 through the end of October. This has been above our goal, although other indications of personnel performance, such as ISAll and the rework rate, indicate improved performance. Actions to further improve performance in this area include lluman Error lieduction training and stall (Stop, Think, Act, lleview) training, which are ongoing.
Temporary Modifications have been maintained at or near planned levels. There are currently 15 temporary modifications installed at Dresden, and the year-end goal of fewer than 20 has been met.
- Operator Workaroonds have been reduced from over 70 at the end of 1994 to 34 as of the end of October 1997. During January October 1997, Operator Workarounds were reduced by 33%.
December I,1997 JSPLTR: 97-0203 Mr. A.11illlleach Page 4 of 9 Contaminated plant area has been reduced to 7.8% as of the end of October 1997.
This represents a 30% improvement since the beginning of 1997.
Overall, Operations perfbnnance results show that the improving trend has continued through 1997.
In October 1996, the Operations training programs were placed on probation by the Institute of Nuclear l'ower Operations. Following corrective action to improve those piograms, the probation was lilled in May 1997.
htclairrritig Substantial efforts continue to be fbeused on improving lingineering perfbrmance. These efforts are Ibeused on resolving weaknesses in design control, calculation control, retrievability of design infonnation. and timely lingineering support to the plant. They have included:
Nuclear lingineering procedures were revised to provide improved guidance for review and update of engineering calculations.
A group of senior, experienced engineering consultants identified and reviewed key operating parameters against system calculations fbr the twelve most risk significarn systems to verify that the calculations supported these key parameters. This effort provided additional assurance th<t the Dresden design infbrmation and calculations are consistent with the systems' functional and testing requirements. Resolution of deliciencies identified by this ieview is being tracked through the Corrective Action Program and the Design liasis initiative.
A Comed program of audits of the Nuclear Steam Supply System suppliers and primary Architect /lingineers was developed and implemented, Corrective actions have been taken in response tcJdentified deficiencies. Effbrts to ensure the quality of l!nginaring work performed by vendors and Architect / Engineers will continue.
Calculation indexing and control (br Dresden Station has been transitioned from over 16 separate Architect / Engineering firms and Comed Corporate facilities into one controlled index. The site Desiga lingineering department now controls the calcutation revision process S all calculations including those perfonned by contracted companies. The improved calculation processing and indexing tools allow quicker calculation retrieval, better calculation revision control, and uniform referencing tools.
1 December 1,1997 JSPLTit: 97 0203 hir. A. Bill lleach Page 5 of 9 A Design Engineering Assurance Group (EAG) was established to provide oversight and guidance for Engineering activities, with the goal ofimproving the quality of the Dresden Engineering function. This group reviews selected Engineering products such ne calcu'.ations, safety evahiations, operability assessments, and 10 CFR 50.59 reviews, design changes, and other items.
A Design Basis Review project is underway to provide further confidence that the plant is operating within its design basis requirements. The project is confirming or establishing consistency between the UFSAR, Upgraded Tecimical Specifications, Design liasis Documents, calculations, plant procedures, and plant configuration.
Efforts in 1997 have focused en ec.mpleting reviews of six of twelve risk signilicant systems.
i l
l An Engineering Rapid Response Team (ERRT) was established in June 1997 to respond promptly to emergent work control and maintenance issues.
Resuhs of these efforts can be seen in several peribrmance measures. For example, the strong safety system performance and improving Unit Capability Factors discussed abos e indicate overall good Engineering support, as do the reduced backlogs of Operator Workarounds and corrective maintenance work requests, and achievement of goals fbr numbers of Tempomry blodilications. hlaterial condition related Licensee Event Reports have been reduced from 16 in 1996 to 5 in 1997 through the end of October.
The results of EAG reviews of Engineering work also indicate improved quality. During h1 arch through September 1997, there has i.een a ::teady decrease in the percentage of calculanons and safety evaluations that the EAG has found to require rework.
Nonetheless, we have continued to see lower level attention to-detail problems and remain very focused on ensuring the quality of Enginecting work and the adequacy of our design basis.
Progress has also been made in reducing Engineering backlogs. The Engineering Request backlog has been reduced from approximately 250 in June 1997 to 143 at the end of October 1997. Strong progress has been made in reducing the number of Engineering Requests overdue. During the first six months of 1997, an average of 27 Engineering Requests were overdue at the end of each month. Since the beginning Of July, there has been an average of four overdue at the end of each month.
Preparation of Design Change Packages to support the h1 arch 1998 Unit 2 refueling outage continues to be on the schedule established in June 1997.
December 1,1997 JSPLTR: 97 0203 Mr. A. Ililllleach Page 6 of 9 in November 1997, the Institute of Nuclear Power Operations (INPO) renewed accreditation of Drcsder's F.ngineering Support training program for another four years.
Maintturgt In Maintenance, a focus has been twofbid: (1) improving the quality of work performed in the heid; and (2) improving the ability to compka work in a timely and eflicien: manner. Iloth of these goals me designed to ensure that the material condition of the station will support safe, reliable operations. To achieve these goals, we put in place extensive training and qualification requirements in 1996 to improve the skills of our workforce and establish speciallred groups of personnel proficient in complex or deroaraling tasks. We established a Fix It Now (FIN) team to address amergent work w that work schedules would not be impacted by emergent problems. Additionally, we implemented a Five V ::k Scheduling Piocess to systematically plan, coordinate, and execute work activities and to match the work process used to the difficulty, complexity, and safety significance of the work.
Itesults of these effons include:
The level of maintenance rework has been reduced and has averaged less than 3%
1 during August, September and October 1997, compared to an average of 4.3% during l
January through July 1997 and significantly higher levels in 1996.
The non-outage corrective work request backlog has been reduced from 1622 in January 1997 to 1080 as of the end of November 26,1997, a 33% reduction. Progress in reducing thi., backlog improved substantially following introduction of the Five Week Schedule Process.
Sinec suly 1997, tbc percentage of non outage maintenance activities completed within eight hours of the scheduled completion time has consistently improved, and in Octooer reached 90% achieving Dresden's 85% goal for the first time since this measure was established at the station. We believe this is attributable to implementation of the Five Week Schedule Process and support from both the FIN team and the ingineering Rapid itesponse Team.
'I he improvement in Safety System Performance, and reductions in Material Condition Licensee livent Reports, Operator Workarounds, and Control Itoom Deficiencies noted also indicate improving effectiveness of Maintenance support to the station.
i
December 1,1997 JSPLTit 97-0203 Mr.'A. Ilill lleach Page 7 of 9 in November 1997, INPO renewed accreditation of all of Dresden's Maintenance Training programs (as well as training programs for Chemistry Technicians and Radiological Protection Technicians) for another four years.
Drrective Action Dresden has also taken action to improve the quality and timeliness of corrective actions.
Like the other Comlid nuclear stations, Dresden is using the new Corrective Action Program that is being implemented throughout the Nuclear Generation Group. There has been a strong Ibcus at the site on problem identification, strong root cause analyses, and line management responsibility for timely and effective corrective actions. For example, in May 1997, we put in place an Apparent Cause !! valuation process that made cause evaluations fbr less significant events more efficient and penuitted more focus on full root cause analyses !br more significant events.
Results of these efibrts include a reduction in the number of repeat events from 127 in 1996 to 11 in 1997 through the end of October. The number of significant events (those items significant enough to warrant a root cause analysis) decreased from 269 in 1996 to 94 in 1997 through the end of October. The corrective action item backlog was reduced from 631 items to 442 items during January - October 1997. There have been no overdue corrective action items since April of 1997. These improvements were achieved despite the fact that station personnel prepared 7399 Problem identification Forms in January -
October 1997. up from 6771 for the full year in 1996, indicating continued focus and willingness to identify problems, in addition to numerical performance measures, it should be noted that Dresden has succeeded in resolving a number of significant historleal peribrmance problems. These include:
Achieving sustained improvement in operator perfbrmance and conservatism of decicion making.
Dramatically reducing incidents of contaminated material outside the Radiologically Posted Area.
Substantially improving reliability by addressing long standing material condition problems and reducing backlogs.
Reducing Collective Radiation Exposure that was for many years significantly above industry averages.
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December 1,1997 JSPLTR: 97-0203 Mr.'A. Ilill lleach Page 8 of 9 Iteducing a historically h:gh ISAR.
e Reducing the number of Out of Service events.
l Overall these results indicate tint station pen.onnel are aggress!vely identifying problems 1
and those problems are, in general, being effectively addressed. Action continues to ensure that remaining issues, such as design basis issues and human perfbnnance weaknesses, are thoroughly addressed.
l Concluslim3 Dresden has demonstrated a sustained improving trend that has been apparent for the past I
two years, lly many measures, station perfonnance is consistent with or better than industry peers.
We recognize that sustained improvement must continue, and are committed to achieving it. We intend not to be simply average, but to be outstanding -- and more progress, and clear performance results, are needed to achieve this goal. We are currently developing our plans fbr 1998, during which we plan to apply the necessary effort and resources to achieve further improvements. We will keep the NitC fully informed of our actions and progress.
Please call me should you require any additional information.
Sincerely, t Q,. - ' 7
. Stephen Peny Site Vice President JSP/WEll:ld
December 1,1997 JSPLTR: 97-0203 hir.'A.13ill 13each Page 9 of 9 cc:
USNRC Public Document Room Chairman Jackson Commissioner Diaz Commissioner Dieus Commissioner hicGaffigan L J. Callan, Executive Director for O stations S. J. Collins, Director of Nuclear Reactor Regulation hl. A. Ring,13 ranch Chief, Division of Reactor Projects, Region 111 J. F. Stang, Project hianager, NRR (Unit 2/3)
K. R. Riemer, Senior Resident inspector, Dresden Station l
Office of Nuclear Facility Safety,IDNS 1
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