ML20202J318
| ML20202J318 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 01/29/1999 |
| From: | Krich R COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9902090097 | |
| Download: ML20202J318 (17) | |
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- g. ' Commonwedth Edison Company 1400 Opus Place Downers Grove, 11. 60515 5701 l
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January 29,1999 United States Nuclear Regulatory Commission Attention: Document Control Desk '
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Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265
Subject:
1998 Performance Assessment 1
Using the criteria in "SMM Nuclear Power Plant Performance Evaluation Template," i Exhibit 1 in the NRC Handbook 8.14, " Senior Management Meetings," station and .
corporate Commonwealth Edison (Comed) Company management assessed the j performance of the Quad Cities Nuclear Power Station during 1998. This assessment 1 focused on the time since startup of both units in June,1998, after extended shutdowns that began in the latter half of 1997. We consider this to be a balanced assessment that leads us to the conclusion that the declining trend identified by the NRC in January,1998, has been arrested, although continued efforts in a number of areas is needed to achieve the level of performance that we have set for our goal. l Accordingly, the enclosed " Performance Assessment report is provided for information '
only.
If you have any questions or need additional information, please contact me at (630) l 663-7330.
Respectfully,
\
O s
m b R.M. Krich Vice President - Regulatory Services $
Enclosure cc: Chairman - NRC Regional Administrator- NRC Region 111 NRC Senior Resident inspector - Quad Cities Nuclear Power Station
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Quad Cities Nuclear Power Station Performance Assessment January 1999 )
EXECUTIVE
SUMMARY
The purpose of this paper is to summarize the performance of Quad Cities Nuclear Power Station over the past year, with emphasis on operation since restart in June {
1998 following an extended outage on both units. The station's performance is j described in five major areas: operational performance, material condition, engineering and design, human performance and self-assessment. !
Over the past year, Quad Cities has been engaged in systematic improvement efforts. l In each area, performance has shown measurable improvement over the station's past l experience. Overall, Comed believes that the decline in performance at Quad Cities has been reversed and that performance is improving. Clearly, however, challenges -
remain and our attention is on sustained and continuous improvement. Station goals through the year 2001 are clearly established in the Quad Cities Business Plan and are l set to move Quad Cities eventually to top quartile performance.
Operational Performance
. Since restart in June 1998, the station has accomplished sustained dual-unit operation with a combined unit capacity factor of 85.7%.
. The forced outage rate has declined to 4% over the past six months compared with ,
the station's historical rate of 31%.
- Safety system performance has improved, with all but one system meeting goals.
- The station completed a well-executed 28-day refueling outage on Unit 1 with no significant events, e Although the station has experienced three unplanned trips since restart, Operations personnel and management response to these events has been good.
e Improvement focus: Operations will continue to focus on improving human performance, upgrading Operation's leadership role (e.g., ownership of the work schedule), improving control room performance standards, and elimination of configuration control errors through more pervasive management involvement.
Material Condition e improved material condition has contributed to the station's gains in capacity factor and forced outage rate.
- A number of long-standing material condition issues were corrected during the 1997-1990 shutdown and recent Unit 1 refueling outage.
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e Operator challenges have been reduced - for example, operator workarounds have been reduced from 24 to 14; control room distractions have been reduced from 136 to 49, e Non-outage corrective maintenance backlog declined from 1170 to 461 by the end of the year.
. Standard, comprehensive performance reports have been established and are used by management to bring attention to problem areas and to drive corrective actions to completion.
e improvement focus: Management attention to activities supporting the improvement of the work control process is continuing. The station's plans and work schedules include specific material condition priorities to enhance equipment reliability and reduce operator challenges.
Enoineerina and Desian e Corporate-led assessments of key engineering programs were completed and improvements made.
- The quality of 10CFR50.59 screenings and evaluations has improved.
- The backlog of Engineering Requests has been reduced by more than half.
. Fire protection program improvements are being made and commitment dates are being met; and the fire-related Core Damage Frequency has been better defined and determined to be on the order of SE-5 rather than the original estimate of SE-3.
. Engineering has taken a key role in material condition improvements and the resolution of long-standing problems.
- A Design Basis initiativs is in progress to improve the quality of design basis information and the fidelity of the Updated Final Safety Analysis Report.
e improvement focus: Engineering programs continue to be assessed and upgraded.
Engineering support of plant operations and material condition will continue to be enhanced Human Performance
. Missed surveillances have been substantially reduced, with only one missed surveillance since February 1998.
- Significant human error events decreased 88% from the first six months to the last six months of 1998.
- Equipment out of service errors have trended downward, but remain an area where improvement is needed e Maintenance rework rate has remained at or below the station's goal and is a focus area for further improvement.
. improvement focus: Human performance will continue to be a focus area, with a comprehensive action plan currently being implemented to address control of system configuratiori.
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- Self-assessment
- Programmatic improvements have enhanced the station's ability to assess and improve performance on a real-time basis.
- e Problem identification remains good with an appropriately low threshold.
. Open corrective action items were reduced by 32% in 1998. '
. The effectiveness of corrective actions has improved from 88% to 92%.
. . Improvements in corrective action processes have contributed to better operational performance. For example, the Safety System Failure rate declined during 1998 to below the BWR average.
-e improvement focus: Departmental self-assessments need to be improved.
The basis for much of the improvement noted above has been the emphasis on . l fundamentals that was required by implementation of the Strategic Reform initiatives i (SR.is). The principles embodied in the SRis will continue to drive site performance and l are a solid foundation for sustaining the improvements achieved.
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CURRENT PERFORMANCE ASSESSMENT OPERATIONAL PERFORMANCE The station's focus on improved operations has resulted in sustained dual-unit operation since the June 1998 startup, with a capacity factor of 85.7% and a well-executed Unit i refueling outage. This compares to an average capacity ,
factor of 54.5% for the previous four-year timeframe. Two unplanned reactor l trips in June and one in September vhile not consistent with our performance )
expectations, demonstrated strong 3rator response and management I oversight. The root causes of these vips were identified and corrected. )
l Proorammatic initiatives l 1
A number of ongoing initiatives are in place to sustain the improved operational performance. These include the following: l 1
. Moving the Operations organization to a leadership role. l
. The station has eliminated many operator workarounds and control room distractions, with additional work planned in this area (see discussion below under Material Condition).
. The station is implementing a scram reduction effort. To date, this effort has resulted in: (1) the installation of five modifications to reduce scram risk; (2) the development of 18 revised Reactor Protection System test procedures that significantly reduce the time that the plant is in a half-scram condition; (3) the development of 401 separate line improvements on four high-risk systems; and (4) the implementation of improved training !
for maintenance on the turbine Electro-Hydraulic Control (EHC) system.
. The station is focused on reducing Configuration Control Events and Out of Service errors (see discussion below under Human Performance).
. Management involvement has been strengthened in the response to events, investigations of root causes and implementation of corrective actions (see discussion below concerning management's response to unit trips in 1998).
Imorovement Results in addition to improved capacity factor, other indications of improved operational performance include the following:
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e For the six-month period since June 1998, Quad Cities has experienced a forced outage rate of approximately 4%, compared with a rate of i approximately 31% historically.
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. Safety system performance has been better than 1998 goals (i.e.,
comparable to industry median values), except for the Unit 1 High
' Pressure Coolant injection (HPCI) system which is marginally over the goal for unavailability, e No Safety System Actuations have occurred since January 1998.
. No INPO or NRC categorized significant events occurred during 1998. j
- The number of xluipment Out of Senrice errors was reduced from nine during the first half of 1998 to four during the second half.
i e The timely performance of surveillances has improved dramatically (see discussion below ut.Jer Human Performance).
- Operations is participating in the 12-week planning process, by which j work is planned and scheduled over the 12-week period prior to j execution. This, in turn, minimizes the time the plant must enter Limiting Conditions for Operation to complete work activities. ;
l e The 1998 total radiation exposure was significantly lower than that for
- 1996, but remained high compared to other BWRs. However, source
term reduction efforts during the recent Unit i refueling outage resulted in j a 20% reduction of the drywell dose rate.
Two unplanned unit trips occurred in June and one occurred in September. ;
Although this rate is unacceptable, Operations' response to these unplanned l L trips was strong, and operators executed carefally planned, controlled, and error-free startups. '
Management response and oversight was much improved over past l performance. In particular, the site management team maintained a high level of l involvement in the efforts to return the units to service, including the l determination of root causes and implementation of corrective actions.
Continued attention to the degree of management involvernent in routine operation is called for and being applied.
- Quad Cities' performance during the recent Unit 1 refueling outage (i.e., Q1R15) l highlighted some of the improvements that have been achieved. There were no
- loss of shutdown cooling events or Licensee Event Reports (LERs) due to '
- human performance errors during the outage, and no lost-time personnel
! injuries. Extensive work was accomplished during the Q1R15 outage, including l i l 5 w 29.1999 ,
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completion of 25 plant design modifications,668 corrective maintenance tasks, 228 surveillances and 879 preventative maintenance tasks.
The success of the Q1R15 outage was due to the direct involvement of the site senior management, the engagement of first-line supervisors and craft personnel, and support by the corporate organization. The corporate organization provided substantial support in dealing with emergent work, particularly the repair of the recirculation system piping and reactor internals cracking.
Operations performance during the outage was good. The shutdown risk management plan was fully implemented and, as noted above, there were no significant human performance issues or reportable events. The subsequent Unit 1 startup was error free and as of January 27,1999, Unit 1 has run continuously for 53 days. Throughout the Unit i refueling outage, the Operations department maintained a strong focus on Unit 2 operations. Unit 2 operated during the Unit 1 outage with no significant human performance events. Early in the outage, operators detected and responded appropriately to a leak in the Unit 2 EHC system.
Onooino Initiatives / Continued Focus l
The station continues to focus on human performance in connection with the '
control of system configuration. The Unit 1 reactor trip on September 30,1998, is a recent example of a human performance-based event. Corrective actions included reinforcement of the need for pre-job briefings and improvement in their content, and additional enhancements to the equipment Out of Service process.
As discussed below under Human Performance, a site-wide action plan is being implemented to address control of system configuration. l
. Continued management attention is given to holding Operations to higher performance standards such as increased supervisor involvement in routine activities and meeting Control Room panel monitoring frequency expectations.
Increasing the leadership role of Operations, particularly in such areas as ownership of the station work schedule, is also a material condition improvement driver.
l Collective radiation exposure also remains a challenge for the station. Source l term reduction efforts in 1998 included replacement of 17 Unit 1 control blade pins and rollers with components employing low cobalt content, hydrolasing hot spots and elevated dose rate piping in the plant, chemical decontamination of the reactor recirculation system, and depleted zinc injection. The station has effectively planned and coordinated work to reduce the source term, as noted by the NRC in inspection Report No.98-022. Source term reduction efforts for 1999 include increasing the availability, and reducing the cycling, of primary system hydrogen addition and continuing to replace control rod blade pins and rollers.
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MATERIAL CONDITION Quad Cities has undertaken significant efforts to improve the material condition of systems, structures and components. These efforts have contributed to improved safety system performance and station capacity factor. The station's efforts have also successfully focused on relieving the burden that equipment problems can place on operators.
Proar2mmatic initiatives l
. Management has implemented initiotives to improve the effectiveness and efficiency of the work control process.
I e The station implemented systematic efforts to reduce the number of !
conditions that impose burdens on operators, including operator 1 workarounds, main control room distractions and the number of lit ;
annunciators. l l
e The station has implemented significant improvements to the Maintenance Rule program since the NRC baseline inspection. In its follow-up inspection,
)l the NRC found the program satisfactory. The station is focusing on i completion of corrective actions that can lead to a reduction in the systems i requiring corrective actions and monitoring under Maintenance Rule i paragraph (a)(1). l e During the extended two unit shutdown and the recent Unit i refueling l outage, the station corrected a number of long-standing material condition i issues. j e The station's ability to monitor material condition has also been enhanced through the implementation of the System Health Indicator Program (SHIP).
During the 1998 Engineering and Technical Support (E&TS) inspection, the l NRC recognized SHIP as an effective assessment process for keeping management informed of the material condition of the plant. I l
Improvement Results The material condition improvements have contributed to enhanced safety i system performance, with all. systems performing better than 1998 goals, except ;
the Unit 1 High Pressure Coolant injection (HPCI) system which is marginally over the goal for unavailability, improved material condition has also contributed to the reduced forced outage rate for the last six months of 1998.
A key area of focus has been to reduce conditions that impose a burden on Operations. These efforts have resulted in the following to date:
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- A decrease in control room distractions from a high of 136 in April 1998 to 49 in December 1998.
. A reduction in operator workarounds from a high of 24 in March 1998 to 14 in December 1998.
. A decrease in the non-outage corrective maintenance work request backlog from a high of 1170 in June 1998 to 461 in December 1998, surpassing the goal of less than 500.
- A reduction in open fire protection deficiencies requiring compensatory measures from a March 1998 high of 95 to three in December 1998.
- A reduction in control room Lit Annunciators from a June 1998 high of 14 to 4 in December 1998.
- A reduction in control room Caution Cards on panels from an April 1998 high of 40 to four in December 1998.
. A reduction in control room Out of Service cards greater than 30 days old from a May 1998 high of 46 to 16 in December 1998.
. The rolling three-month average for percent maintenance rework has remained at or below the site goal of 4% for 1998.
In addition, the station has seen an improving trend in the overall number of Maintenance Rule paragraph (a)(1) systems. The number of (a)(1) systems has declined from 59 systems in June 1998 to 48 as of December 1998, of which 33 systems require corrective actions and 15 systems have had corrective actions completed and are in the monitoring phase. The numbers are outside industry norms, but the drive to reduce the number of (a)(1) systems requiring corrective actions to less than 10 before the end of 1999 is on going.
I Repetitive maintenance preventable functional failures have decreased over the I last eight months, from six in May 1998 to one in December 1998. Even though I some improvement is noted, the station is experiencing one to two repetitive equipment problems per month. This does not meet management's expectations or industry standards, and emphasis on recurring equipment performance issues is ongoing.
In the recent past, the station as well as the NRC have conducted thorough assessments (i.e., the Comed Vulnerability Assessment Team (VAT) assessrnent and the NRC Diagnostic Evaluation Team (DET) inspection) and have identified poor material condition and untimely corrective action in response to the identified conditions. The majority of over 250 corrective actions g January 29,1999 I
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!v-have now been completed and the four remaining items are being tracked to t ,
completion.
l l During the extended shutdown of both units, the station corrected some long-standing material condition problems associated with the Unit 1 High Pressure Coolant injection system, the Standby Liquid Control system, and the Feedwater Heater Level Control system. The station replaced eight feedwater condensate domineralizer controllers, removed six operator workarounds, and repaired the reactor vessel drain line.
. Makr work accomplished during the 1998 Unit i refueling outage included l l
Control Rod Drive Replacements, Recirculation Pump Seal Upgrades, Drywell '
Asbestos Removal, Emergency Core Cooling Suction Strainer Upgrade, Appendix R (Fire Protection) Design Changes, Overhaul and Boot Replacement ;
of the 'C' Low Pressure Turbine, Reactor Water Cleanup Auto-isolation Design !
Change and Ultrasonic Examination of the Feedwater Nozzles.
Onooina initiatives / Continued Focus While the adherence to the work control schedule has recently shown some .
improvement and the non-outage maintenance backlog is trending downward, I the work control process is not yet meeting performance objectives. Actions are l being taken to achieve additional improvement in the number of tasks completed per week and work schedule adherence.
l The station continues to focus on material condition issues in order to enhance equipment reliability and eliminate difficulties for operators. The station's material condition priorities for 1999 include:
e improving feedwater control system performance.
- Upgrading the Unit 2 recirculation pump seals.
e implementing an Emergency Diesel Generator (EDG) reliability plan.
- Achieving reduction in the scram rate through the scram reduction program noted above, including, for example, implementation of main turbine EHC system reliability improvements.
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- Restoring the Unit i redundant offgar ain which has not been in service i for many years.
, e improving material condition of the Radwaste system.
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L (, , "1 ENGINEERING AND DESIGN The station has implemented improvements in a variety of areas designed to enhance the quality of engineering products, including calculations, plant modifications, and 10CFR50.5g safety evaluations. Improvements in the areas l of Operations support and technical programs are also in progress. In addition, i Fire Protection program improvements have been realized, and progress has been made on Engineering backlogs and equipment performance. The ongoing improvements in the Engineering area are reflected in the station's upgraded i material condition and improved operational performance.
Proorammatic initiatives l Engineering has led the station's efforts to improve the quality of plant l modifications and 10CFR50.5g safety evaluations. Training was provided in this area and enhanced procedures were developed The quality of products is measured by Engineering and the results are fed back to the organization. l Substantial improvement in the quality of engineering products such as 10 CFR l 50.5g safety evaluations has been noted. l The station is in the process of reconstituting certain calculations. The majority of the critical mechanical calculations have been reconstituted, with continuing effort at reconstituting the Heating, Ventilation and Air Conditioning calculations and heat exchanger calculations. Reconstitution of Emergenc/ Diesel ,
Generator loading and battery load profile calculations is in progress. The l electrical load and cable routing calculations are being brought under direct Comed control from the architect-engineer to promote ownership.
Quad Cities has focused on strengthening the station's sensitivity to the Operability Determination process. Detailed training has bewn conducted on the performance of Operability Determinations. The station procedures governing Operability Determinations have been upgraded. The timely closure of open l
- corrective actions associated with Operability Determinations is clor, sly )
mor)itored by management
' A Design Basis initiative (DBI) is in progress and is resulting in improved quality of design basis information. This initiative verifies anti validates that the plant's design basis is consistent between the Updated Final Safety Analysis Report (UFSAR), plant documentation, and the as-built configuration.
Risk insights from the station's Probabilistic Risk Assessment are being appropriately used by the station. For example, within the work control process, risk insights are used in performing safety assessments prior to taking equipment out of service for maintenance during both plant operation and
. shutdown conditions.
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i Engineering has contributed significantly to the previously cited reduction of burdens on operators, through the elimination of operator workarounds and control room distractions.
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Engineenng is taking action to manage equipment aging issues. For example, as part of the Equipment Qualification program, the station periodically conducts ;
- inspections and megger testing of samples of older safety-related electrical !
- cable. I i i
, Fire Protection program improvements and evaluations are in progress and l
- committed completion dates are being met. These efforts have included a i review of the fire risk-related core damage frequency to ensure that the model is
- better defined and supported by actual plant configuration.
i i Imorovement Results Results of the Engineering improvement efforts include the following:
. The quality of Engineering products has been improved. Quality reviews have not identified a significant quality deficiency of the products reviewed since May. The NRC's E&TS Inspection Report noted that I 10CFR50.59 screenings and safety evaluations were complete and comprehensive.
- During Q1R15,25 plant design modifications were completed, including recirculation piping weld overlays, with no significant weaknesses noted in either design or testing.
- The station has reduced the backlog of Engineering Requests (ERs) by i nearly half since March 1998.
- Action plans for improving the effectiveness of the raw water heat j exchanger Generic Letter 89-13 performance program are being l' implemented.
e Key technical programs, such as the heat exchanger performance l program, have been reviewed and no significant problems were found. i Corrective actions to further strengthen these programs have been taken.
- Approximately 3900 specific Engineering action items were closed out j during 1998. ]
e The number of Maintenance Rule (a)(1) systems hEs declined from 59 systems in June 1998 to 48 as of December 1998, of which 33 systems require corrective isctions and 15 systems have had corrective actions l completed and are in the monitoring phase. A work down plan to reduce j 11 3==y 29.19"
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the number of (a)(1) systems requiring corrective actions to less than 10 by the end of 1999 has been implemented.
- The fire-related core damage frequency (CDF) has been determined to be on the order of 6E-5 rather than the original estimate of SE-3. This means l that the CDF due to fire-related events at Quad Cities is comparable to other BWRs.
! e in 1998, there were two LERs due to design deficiencies. This is an !
I improvement over the eight 1997 LERs due to design deficiencies.
l Onooing initiatives / Continued Focus -
L For 1999, priorities for Engineering are focused on the following areas:
e inservice inspection and inservice Testing programs. ;
1 e Continued improvement in material condition of plant structures, systems, l and components and reduction of repetitive equipment problems.
- Further reduction of issues contributing to operator challenges.
. implementation of NGG common Engineering tools, e.g., data bases, l
handbooks and templates.
HUMAN PERFORMANCE Continued improvement in the area of human performance is key to ongoing ,
safe operations and sustained improvement at Quad Cities. Improvements in i human performance since the June restart have provided the foundation for continued operational improvements. i Proarammatic initiatives e Human performance standards have been defined and communicated to the l work force.
- Consistency of human performance and compliance with high standards of excellence are being emphasized across the organization.
- As discussed below under Self-assessment, the station has implemented a management observation program known as SCORECARD in the areas of
- Operations, Maintenance and Radiation Protection.
i e Operations is taking the lead in improving the control of system configuration
! through a comprehensive site-wide action plan.
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. Improvement Results i
- Improvement has been.noted in human performance, although this remains an i area of needed focus by the station. Accomplishments to date include: '
i e There has been one missed Technical Specification surveillance since l February 1998. This compares with a total of 23 missed surveillances j from June 1997 through February 1998 due to scheduling or performance !
inadequacies. The one instance of a missed surveillance since February (
of 1998 was due to a misinterpretation of the intent of the surveillance i requirement. This was identified nnd appropriately addressed. !
. Equipment Out of Service errors have trended downward from nine during I the first half of 1998 to four during the second half of the year.
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. The station has not had a lost time accident for 453 days as of January l 19,1999.
- Maintenance rework rate, based on a 3-month rolling average, was at or below the station goal.
. Significant human error events have decreased from 42 for the period January through June 1998 to five for July through December 1998 'This represents an 88% reduction. Similarly, improvement has been seen in the number of Licensee Event Reports (LERs) attributable to human performance errors. Human performance-related LERs declined from 2.17 per month in the January to June 1998 period to 0.67 from July through December, which is still a high level compared with the rest of the Comed system and the national average. No LERs due to human performance events were generated during the Unit i refueling outage and subsequent startup.
Onooina initiatives / Continued Focus i l
Human performance errors associated with configuration control continue to be !
a priority and focus area for the station. Ongoing activities include e Continued implementation of the comprehensive action plan to address l Configuration Control Events and Out of Service errors. !
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- Continued use of the SCORECARD process.
e Corrective actions are being taken in 1999 to improve human ,
performarce in the radiation worker area.
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EFFECTWENESS OF LICENSEE SELF-ASSESSMENT l l
l Programmatic inwc;;x,eide have been made to strengthen the station's self-assessment and corrective action programs. These have enhanced the !
station's ability to review and improve performance on a real-time basis, and i have improved the identification of problems as well as the timeliness and l l offectiveness of corrective actions. !
i 1 l Proarammatic initiatives f
Programmatic improvements in the area of self-assessment and corrective l actions have included: j e The oversight function ~ carried out by the Nuclear Oversight organization !
and the Nuclear Safety Review Board has been significantly ;
l strengthermd. ;
i e _ implementation of the Continuous Assessment Process by Nuclear ;
, Oversight. This process incorporates industry best methods to improve !
l the oversight area and provide management a clearer assessment of real-_ l time performance, j t.
e implementation of a management observation program known as I SCORECARD in the areas of Operations, Maintenance and Radiation ,
Protection. - This process assists in conducting first-line supervisor ;
l observations and direct interaction with workers in the field. l e . Significant progress has also boon achieved in strengthening corrective )
action processes. As noted by the NRC during the E&TS inspection, the ;
Corrective Action Review Board (CARB) and Plant Operations Review l Committee (PORC) processes are thorough and adequately address the I issues presented to these committees.
Imorovement Results improvement has been achieved in both the input into the corrective action process as well as the timeliness and offectiveness of the corrective actions.
L Results achieved to date include:
. . Improved timeliness of corrective actions has been seen in an overall
. reduction in open corrective action items from 2296 in January 1998 to
[ 1563 in December. Furthermore, there has been an improvement in the i percentage of Maintenance Rule (a)(1) corrective action steps completed j on time. The percentage improved from an average of 86% in the April to June period to 100% in the October to December period.
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, e Corrective action effectiveness reviews performed by the station have 4
shown that the effectiveness of corrective actions increased from 80% for
- . the period of April through August 1998 to 92% for the period of i September through November. This shows an improvement in the extent l to which corrective actions taken are effective in preventing recurrence of j the problem.
i e increased management and station focus on completion of corrective actions for Maintenance Rule systems has resulted in an improving trend
- in the overall number of Maintenance Rule (a)(1) systems and those with
! open corrective actions.
- A healthy and ongoing problem identification process is in place with an i appropriately low threshold. Some 5700 separate problems were l identified in the station's problem identification process during 1998.
! The improvement achieved in the area of root cause analysis and corrective actions has also been noted by the NRC. For example, the troubleshooting j efforts in determining the root cause of the Unit 2 HPCI turning gear failure and j repairing this failure were identified as thorough by the NRC in inspection Report 98-013. Furthermore, NRC cited violations due to ineffective corrective actions (i.e., repeat occurrences of a previously identified problem) decreased from six in 1997 to zero in 1998.
- Enhancements in this area have also contributed to improved plant material i condition and better operational performance. The safety system failure rate for the station has declined from 4.5% in January 1998 on a rolling 12-month average to 2.0% in December 1998, compared with a BWR average of slightly over 3.0%. Significant human error events have decreased from 12 for the period January through June 1998 to six for .!aly through December 1998.
Audits and assessments conducted by Nuclear Oversight have improved in identifying and promoting the resolution of station issues. For example, enhancements to the implementation of the Maintenance Rule and more effective use of the system material condition metric, i.e., the System Health indicator Program, occurred in part due to Nuclear Oversight assessment findings.
Onooina initiatives / Continued Focus e To help maintain a !ow threshold for problem identification and improve the usefulness of Probiera identification Forms (PIFs), station management continues to reinforce the need to generate PlFs for adverse conditions.
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e The station is continuing the implementation of the Continuous Assessment ,
Process and SCORECARD.
l e Corrective action effectiveness reviews are continuing.
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. The effectiveness of the on-going departmental self-assessments and .
program reviews is being improved through heightened management i attention. j i
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