ML20203B253
| ML20203B253 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/12/1998 |
| From: | Heffley J COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| JMHLTR:#98-0033, JMHLTR:#98-33, NUDOCS 9802240237 | |
| Download: ML20203B253 (9) | |
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I Drrulen Genrrating Station 6500 North Dnvien Road Wrris 1160 650 Tcl HI 5 9 62-2920 February 12,1998 JMHLTR: #98-0033 US Nuclear Regulatory Commission Washington, DC 20555 Attn.: Document Control Desk
Subject:
Response to January 2,1998 Systematic Assessment of Licensee Performance (SALP) 15 thr Dresden Station This letter provides the Dresden Station response to the NRC Region 111 SALP 15 Report dated January 2,1998. We have carefully reviewed the SALP 15 report. We were pleased to receive recognition of the improvements in performance that have occurred over the past year, especially the strengths in our quality organization and in self-assessment. We understand and agree that performance weaknesses remain, and that we must achieve further improvements. This response summarizes the actions we are taking to address the weaknesses noted in the SALP 15 report, with specific focus on Engineering issues.
A number of these actions were described during the January 16,1998 meeting at which the NRC presented the S ALP 15 results.
_Lingineering While disappointed in the SALP 3 in engineering, Dresden recognizes the need to improve in this area. A desciiption of the improvements we have recently completed and further action we plan to take is presented in Attachment A.
Operations We concur with the need to continue to improve our human performance so that we are stronger in day-to-day operations. To this end, we are taking several steps:
k We are conducting Crew Peribrmance Review Boards.
These boards formally l
evaluate the conduct of each crew on a periodic basis, and provide feedback to crew members.
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USNRC February 12,1998
, JMilLTR. #98-0033 Page 2 Ope.ations is tracking and trending Control Room challenges. This information is provided to other departments so that they can develop action plans to reduce the challenges to the Operators.
In an efron to improve human performance and reduce personnel errors:
Operations implemented the " Scorecard" program. This program pr.
des direct feedback to an individual on his/her job performance, as measurt.a against a prescribed set of competencies for the job area being observed.
Operations is reviewing human performance related Problem Identification Forms (PIF) for common areas that need attention to ensure recurring problem areas can be addressed appropriately.
Maintenance As noted in the SALP 15 report, further improvement must occur in such areas as quality of work, personnel errors, work execution, improvement of material condition, and work preparation and problem solving. Steps we are taking include:
We will implement a scorecard process similar to that which was recently used to enhance Operations performance.
This process evaluates r".tenance crews performing various tasks using a set of observation criteria to assess such iteras as procedure compliance, preparation and planning, communication, work execution, and quality of work. This process is expected to be fully in use by June 1,1998.
To improve the maintenance skills, our maintenance personnel will be provided with at least 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of continuing skills and specialty training. In addition, maintenance planners will receive over 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of training on work planning and preparation.
Material condition improvements remain a station priority. We are focused most closely on those material condition issues that may afTect plant safety or system operation. Recently, we completed work to improve the material condition of the OfTgas System, the Local Power Range Monitors (LPRMs) and the demineralizer systems. We will continue to prioritize and address material condition problems uslng the twelve-week work schedule process and the Business Review Committee.
During the spring of 1998, we will conduct a refueling outage on Unit 2 and a planned maintenance outage on Unit 3.
Key planncJ material condition improvements scheduled for these outages include:
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USNRC February 12,1998
, JhillLTR: #98-0033 Page 3 Upgrade U2 Feedwater/ Level Control System to 3 element control Refurbish / inspect Low Pressure Turbines e
Inspect various liigh Pressure Coolant injection System (llPCI) Check Valves Replace 59 Control Rod Drive (CRD) Drive Renlacement Complete Ilydraulic Control Unit (IICU) Valve Upgrades - Scram Diaphragm and Scram Pilot Outlet valves Replace Condenser Bellows (24 are plar.ned) e Replace and inspect Drywell Insulation Repair Feedwater Heater Drain Valves
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Replace ECCS Suction Strainer 24/48 VDC hiod - To Remove Safety Related Loads from 24/48 Battery Replace llPCI Drain Line and Upgrade Valve Repair Oil Leak on 2A Recirc Pump Plant Suppon We agree that weaknesses remain in radworker performance, enemistry technician procedural compliance, and security personnel errors.
Key actions undenvay to address these weaknesses include.
in August 1996, Dresden Radworker performance expectations and standards were
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incorporated into the Radworker continuing training program.
We have also established a " greeter" program to remind personnel of their radiation prote-tion responsibilities and ensure they have proper dosimetry and work permits. Radiation Protection Technicians (RT) have been assigned to spot check work to ensure compliance with radiation protection requirements. We are also implementing a job observation checklist program to ensure that radivorkers adhere to procedures, properly communicate, and follow good radiation work practices.
Under this program, results of work observations by "rosers" are assembled and analyzed to identify areas for improvement and provide feedback to work groups on how to improve radiation work.
Radiation Protection supenision uses job observation checklists to evaluation RT work performance. In addition, the hianagement By Walking Around (h1BWA) Program requires all supervisors and above to observe activity in the plant including radiation protection practices.
Several steps have been taken in recent mor.ths to improve contractor control and performance in implementing radiation protection requirements.
These include reinforcement of Dresden radworker standards and expectations with the contractor workforce, providing contract employees with the Dre., den Radworker Handbook, and
USNRC February 12,1998
, JMilLTR: #98-0033 Page 4 ensuring greater Radiation Protection (RP) vendor accountability through contract provisions, performance measures, and contractor qualification requirements.
Comed Management oversight of Unit 1 RP activities has been expanded to incM a Lead Supervisor and a General Supenisor to ensure consistent standards across all three units have been initiated.
A new set of Chemistry Depanment Standards were issued in December,1997. These standards re-emphasir procedural adherence and are a major topic in the cycle one Chemistry Technician (CT) continuing training. All chemistry personnel attended the iluman Error Reduction Training program which was completed in December,1997.
Approximately 300 Task Performance Evaluations (TPEs) have been performed on the cts. This oversight provides management the opportunity io coach the cts on proper procedural adherence in a real time context.
We are taking the following steps to reduce security personnel errors: A continuing program of supenisory and management shin visits to provide coaching, reinforce standards and expectations, and evaluate personnel knowledge. Security supenisors attended liuman Error Reduction Training in the last quarter of 1997 and are applying these techniques on shin tr reduce human errors among their personnn.
lluaan Performance The SALP 15 report noted various types of human performance problems within each of the four ftmetional areas reviewed. Accordingly, in addition to specific actions to address human performance within each area, we are taking site-wide action to upgrade human performance.
Actions mderway or planed, beyond those discussed above in each functional area, include:
We have performed root cause and common cause analyses to determine the most important causes of human performance problems at Dresden. The predominant causes have been inconsistency in feedback and reinforcement of human performance standards and expectations, and the complexity and burden of administrative procedures -- procedures that make safe and efficient work completion more difficult than necessary.
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USNRC February 12,1998 JMilLTR: #98-0033 Page 5 We performed reviews of our administrat ve processes and procedures to eliminate i
unnecessary complexity. This review was initiated in early N5 and was completed in December 1997 More than 100 changes have been made to clarify requirements or eliminate unnecessary administrative burdens that do not contribute a safe and efficient work completion.
We conducted simulatar training on self-check techniques (Stop, Think, Act, Review, or STAR) for 87% of site employees in 1997. We will complete this training by August,1998.
In 1997, we conducted Human Error Reduction Training for more than 90% of our employees This training covers the ten traps which induce human errors and techniques to avoid the traps when they are recognized. We wi!! complete this training by August 1998, and an assessment of the training's effectiveness will follow.
The Scorecard program was implemented in Operations. This program is being expanded to Maintenance, Radiation Protection. and Engineering.
Under this program, standard checklists and criteria are used to evaluate the performance of a work group. This information is then analyzed and feedback is provided to the group 4
on their performance and ways to improve. This program helps to ensure consistency of feedback and reinforcement concerning human performance.
We will perform fcllow-up assessments and surveys, and monitor our objective performance indicators, to evaluate the efTectiveness of these actions.
Human perfbrmance is an area requiring continual management vigilance and action to achieve strong performance. We recognize that simply completing a set of actions will not be a " permanent fix" but that sustained efTort is required over the life of the station.
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While we are proud of our accomplishments in 1997, we know there are still weaknesses that must be addressed, many of which were noted in the SALP 15 report. We are taking action to improve in each area, and will continue to closely assess our performance to ensure that problems continue to be self-identified and corrected. Our goal is not just acceptacle or good performance, but excellent performance, and we will keep making the improvements needed to achieve it.
As noted by Mr. Kingsley during the January 16,1998 SALP meeting, Comed Quality and Safety Assessment in conjunction with Corporate Licensing has reviewed the SALP report. Issues have been identified for review at Comed's other nuclear sites and for review at corporate for generic impf. cations.
The results of this review will be communicated in the future to you in a meeting such as the ongoing Commonwealth Performance Oversight Panel meetings
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USNRC February 12,1998 JMHLTR: #98 0033 Page 6 Please call me or Frank Spangenberg, the Dresden Station Regulatory Assurance f.ianager, should y. 'u have any questions or require further information.
Sincerely,
.1.
1 S' e Vice Pres dent Dresden Station Attachment (1) cc: A. Bill Beach, Administrator USNRC Region til J. F. Stang, Project Manager, NRR K. Reimer, Senior Resident Inspector, Dresden Station Omce of Nuclear Facility Safety - IDNS
Attachment A Dresden Station Engineering improvement Actions.
Summarized below are the improvement initiatives taken or p anned to address weaknesses noted in the SALP 15 Report.
Quality of Engineerine Work and Attention to Detail Dresden will continue use of the DEAG to review the quality of Engineering products.
DEAG will provide periodic feedback to Engineering personnel and management, and make necessary improvements. In addition, Dresden will continue to train Engineering First Line Supervisors (FLS) via the Comed FLS training program and will support INPO Engineering Profe malism Supervisor training courses.
Design Control Initiatives During 1998 Dresden will complete the reconstruction of the Design Basis of the 12 Most Risk Significant Systems as committed in the Confirmatory Action Letter of November 1996. Additionally, Dresden will complete the reviev of the UFSAR in consonance with l
the Comed Design Basis initiative Program.
Matgrial Cendition Engineering has identified many materiel condition upgrades for implementation 1998.
Examples include:
1IPCI Wlve Refurbishment 24/48 VDC Battery Replacement 3 Element Control of U2 FWLCS OfTGas System Restoration Fire Protection System Upgrades 59 CRDs on Unit 2 Ten Feedwater Valves Extraction Steam Bellows in U2 Condenser E.nergency Core Cooling System (ECCS) Suction Swiners Installation U2 Attachment A Page1of3 JMHLTR: #98-0033
Btetirring Material _CmLdition Issues To address Recurring Material Condition issues, management is developing the following plan. A list of the Top 10 Recurring Material Condition issues has been identified to focus the energy of the station to solve those issues, once and for all. In addition, an Equipment Root Cause fligh Impact Team is being formed. Using Root Cause techniques, each member of this group will coordinate cross-functional teams to develop plans to fully resolve issues from the Top 10 list. A Trouble Shooting Board is being formed to review these plans, as well as other shorter term issues identified by management. The Bor.rd will use prints, manuals, vendor contacts and industry OPEX events to ensure the plans are thorough and that a success path exists to fully resolve the issue. Upon approval, the plans will be implemented through the management ftmding and work control process.
Co.nimuedfriiphasis oILC_onsemtivtpecisiortMiLking To reinforce conservative decision making within the Engineering department, and to support a generally conservative approach to operation of Dresden, the following steps will be taken during 1998:
Continuing training will include operating experience (OPEX) which illistrates conservative operations.
Engineering Management Standards and expectations will continue to be emphasized frequently.
Work Managemer't and Prioritintion Dresden will fully participate in the Comed initiatives to improve the Engineering Work Control Processes. Dresden will implement a Station " Top 25" Technical Issues list in order to focus Engineering resources on the appropriate issues. The list will be developed with input from Operations and Maintenance and will be reviewed periodically with senior management.
The Site Engineering Manager will continue to stress accountability for performance during weekly Engineering Accountability sessions where project plans and improvement initiatives are reviewed in detail. Engineering will continue to develope an Engineering scheduling group to facilitate control of Engineering activities.
Attachment A Page 2 of 3 JMHLTR: #98-0033 1
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CEnatute involvement P
The Dresden Site Engineering Manager will continue to chair the Engineering Peer Group with the Engineering Vice President. This Group sets Engineering Policy, defines, and aligns common process improvements within Comed.
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Attachment A Page 3 of 3 JMHLTR: #98-0033
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