ML20203G500

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Forwards Input for Millstone Assessment Panel SE Re Two 1 Wk Insps Conducted During 920921-25 & 1026-30.Insp Involved Review of Selected Documents & Interviewing of Licensee Employees
ML20203G500
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 11/18/1992
From: Jaffe D
Office of Nuclear Reactor Regulation
To: Stolz J
Office of Nuclear Reactor Regulation
Shared Package
ML20203G108 List:
References
FOIA-97-469 NUDOCS 9803030004
Download: ML20203G500 (13)
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November 18, 1992 A

6 Docket Nos. 50-245/336/423 MEMORANDUM FOR: John Stolz, Project Director Project Directorate I-4 Division of Reactor Projects I/II FROM: D. H. Jaffe, Senior Project Manager Project Directorate 1-4 Division of Reactor Projects I/II

SUBJECT:

INPUT FOR MILLSTONE ASSESSMENT PANEL (MAP)

SAFETY EVALUATION The enclosed assessment of selected MAP concerns represents observations gaiied from two one-week inspections which took place during September 21 to September 25, 1992 and October 26 to October 30, 1992. The inspections involved the review of selected documents and the interviewing of licensee employees.

O D. H. Jaffe, Se for Project Manager Project Directorate 1-4 Division of Reactor Projects I/II

Enclosure:

As stated 9003030004 900226 iId PDR FOIA

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ENCLOSURE INPUT TO MAP SAFETY..EVALUATIOM INSPECTION OF BELECTED.. MAP TOPICS

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6 MAP ISSUE NO. 5 CUMBERSOME ADMINISTRATIVE PROCESSES CONTRIBUTED TO PROCEDURE NON-COMPLIANCE STATEMENT OF MAP lMEi MAP issue No. 5 notes that cumbersome administrative processes contributed to procedure non-compliance. The NRC's finti SALP Report, dated August 4, 1992, states that, " Vagueness in management's message to the work force on so-called ' intelligent conytiance' allowed apparently unintended latitude. This was com)ounded by cunbersome procedures and processes which were barriers to setter performance."

LICENSEE'S RESPONSE TO MAP CONCERN: The licensee's letter dated September ll, 1992 nctes that the problem of cumbersome administrative processes and non-compliances was identified prior to the PEP and was being addressed within Action Plan 2.3.5, " Procedures". Action Plan 2.3.5 calls for development of l ... policy and procedure structure within NE&O that effectively communiru es requirements in a clear, standardized and integrated manner...".

1 INSPECTION RESULTS: The licensee's procedure rewrite program represents a substantial commitment that will result in the standardization of stction procedures where such standardization is beneficial. Essentially all procedures, with the exception of Emergency Operating Procedures, will eventually be rewritten. Progress to date has mostly been in the structural areas as follows:

  • The NE&O Policy on procedure standardization has been completed.
  • Writers' Guides for Administrative Control Procedures and Technical Procedures have been completed.
  • The Process Mapping technique for procedure preparation has been integrated into the procedure writing process Process Mapping involves producing a logic flow diagram which presents a picture of how the work, to be controlled by the procedure being developed, will actually be conducted. The procedure is then developed based upor ejights gained from the process map.
  • Members of the procedure writing organizations have made contacts with other licensees to integrate industry experience into the procedure writing process.
  • Project Management and organization reporting methods have been developed to report and control procedure rewrite progress.

Project schedules for procedure rewriting are still fluid. Completion of the total procedure rewrite project for Millstone Units 1,2 and 3 is scheduled for 1998.

In addition to the procedure rewrite effort the licensee has instituted certain " individual understanding and accountability" measures. These

" software" program features are addressed in connection with MAP issue 18.

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0 C.QELUSIONS: The proced"r "ewrite effort is still in a formative stage with good arogress having b6ei sieu.sn in the formation of orge.;:ations and methods for t1e procedure rewrite effort. The larger issue of arocedural compliance on the part of the licensee s employeer, was not addressed in expectations;s the licensee response to this MAP concerns. We under;tand that this issue was addressed in meetings with employees and in directives, as part of a short term corrective measures effort following completion of the Procedure Compliance Task Fore Report. In addition, the issue of procedural non-compliance and other areas involving personnel error are addressed in Map Issue No. 18 f.QLLOW-ON ACTIVITIES . The Staff should follow the progress of the procedure rewrite effort. in addition, the effectiveness of the short term corrective measures addressing procedural compliance should be determined.

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t MAP ISSUE NO. 13 WEAKNESS IN TRAINING AND D0cVMENTATION 10 CFR 50.59 EVALUAT1031 STATEMENT OF MAP ISSUE: MAP Issue No.13 notes that the completeness of the licensee's 10 CFR 50.59 evaluations for Millstone Unit I should be improved, in addition, more uniformity should be introduced into the training program for individuals involved in the 10 CFR 50.59 evaluation process.

LICENSEE'S RESPONSE TO MAP CONCERN: The licensee's response to the NRC letter dated August 17, 1992, which was dated September 11. 1992, states that MAP Topic No. 13 was addressed prior to the advent of the PEP.

INSPECTION RESULTS: The NRC did not inspect the licensee's remedial action taken in response to MAP Issue No. 13. The NRC conducts annual 10 CFR 50.59 audits of the licensee's activities and will address the adequacy of the licensee's remedial actions during the next audit which is scheduled for December 199?.

. CONCLUSIONS: The licensee's response to MAP Topic No. 13 can be addressed outside of the PEP in the context of tne 10 CFR 50.59 audit process.

[QLLQW-0N ACTIVITIES: During the December 1992 10 CFR 50.59 audit, the NRC Staff will inspect it.e licensee's remedial actions concern completeness of Millstone Unit 1 10 CFR 50.59 evaluations and uniformity in training.

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e MAP ISSUE NO. 15 WEAKNESS IN DEFICIENCY REPORTIN: SYSTEM STATEMENT OF MAP ISSUE: MAP !ssue No. 15 not?s a need for improvement in the l area of reportability and operability determinations. As noted in the final l SALP heport dated May 28, 1991, instances of untimely determinations during i the period from June 16, 1989 to December 15, 1990 continuad to occur.

LICENSEE'S RESEQHSE TO MAP CONCERN: The licensea's response to the NRC letter '

dated August 17, 1992, which was dated September 11, 1992, states that concerns associated with promptness of the subject determinations had been largely resolved prior to the formulation of the PEP program. Specifically, the final SALP report for the period frnm December 16, 1990 to February 15, 1992, dated August 4, 1992, notes that, "During the current period the licensee implemented corrective actions addressing reportability and operability decision-making. As a result of these actions, this process has been found to be prompt, conservative, and soundly based."

INSPECTION RESULTS: No inspection activities were conducted regsrding MAP

!ssue No. 15 CONCLUSIONS: The NRC Staff concurs with the licensee's decision not to address this issue within the PEP.

FOLLOW-ON ACTIVITIES: No follow-on activities are required.

2 MAP ISSUE NO. 18 INATTENTION TO DETAIL IN ROUTINE ACTIVIllfji STATEMENT OF MAP ISSUE: MAP Issue No. 18 notes inattention to detail (aersor.nel error) in routine activities. The inspection reports referenced ir, tie NRC letter dated August 17, 1992, regarding MAP Topic No. 18 present a pattern of personnel errors that involve configuration control (mispositiened valves), work control (tagging and failure to follow procedures), operating errors, equipment surveillance errors.

LLCINSEE'S RESPONSE TO MAP CONCERN: The licensee's response to the NRC letter dated August 17, 1992, which was dated September 11. 1992, states that MAP Topic No.18 is being address within the PEP as follows:

  • Expectations of management, as embodied in the licensee's " principles of excellences" document, have been, and will be sommunicated to the licensee's personnel. Implementation of Action Series 1 is expected to impreve communications.

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  • A major commitment of the licensee's resources to the procedure upgrade effort (see MAP Topic No. 5) is expected to result in improved procedures.

INSPECTION RESULTS1 The inspector reviewed a number of "individusi understanding and accountability" initi d ves. These initiatives are designed to decrease-the incidence of personnel r eors including those associated with procedural non-compliance. The following initiatives were reviewed:

  • " Principles of Excellence"- The licensee has publ . ,hed a pocket-size document that-addresses a number of personnal-accounability issues as follows:

teamwork, safety (nuclear, industrial, radiation) quality, innovation, communication and productivity. Procedural compliance is specifically addressed under the subject of " productivity". Management expectation fc?

workers and first-line supervision. All employees at Millstone have received the " Principle of Excellance" document and have met with their management to discuss management expectations.

  • "Self Checking"- The licensee is in the process of producing a "self checking" document for distribution to Millstone employees. A draft document, produced in a pocket-size edition, states the following: "Self-checking is- not the same as ' attention to detail'. Self-checking include: distinct thoughts and actions designed to enhance an individual's attentionto detail at a specific moment before performing a task." The self-checking document develope the self-checking aspects as follows: stop, think, act and review (STAR).

In addition to the above, the licensee has instituted a work observation program. This program, defined in Millstone procedure ACP-9.10, involves direct observation of operations, I&C, and maintenance evolutions by supervisory personnel. Personnel errors detected during work observation and those identified via plant incident reports (PIRs) are reported on a monthly

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CONCLUSIONS: The licensee's response to MAP Topic No. 18 provides a plan to reduce the rate of personnel errors through the development of " hardware" (procedure revisions and improvements to tagging and work control) and

":oftware' (self checking, principles of excellence, and management initiatives). In addition, personnel errors will be subject to monitoring, via i work observation, and analysis via reporting and trend analysis. This dual l focus program should address the several causes of personnel errors nd result in a decrease in these errors.

FOLLOW-ON ACTIVITIES: The NRC Staff should continue to monitor the contribution of personnel error as it relates to plant incident causes at H111 stone.

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MAP ISSUE NO. 20 WEAKNESS IN PREVENTIVE MAINTENANCE PRACTICES FOR SAFETY-RELATED

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STATEMENT OF MAP ISSUE: MAP issue No. 20 notes weaknesses in the preventive maintenance practices at Millstone Unit 1. The inspection reports referenced in the NRC's letter dated August 17, 1992, regarding MAP concerns, identifies the following illustrative examples:

  • Inspection Report 91-13. Unannunciated trip of a safety-related 125 VDC station battery charger as a result of a lack of preventive maintenance on the charger.
  • Inspection Report 91-16. A station battery cell was charged without a procedure for safety-related station battery single cell charging.

The NRC's final SaLP Report dated August 4,1992 concludes the following with regard to preventive maintenance for Millstone Unit 1: "Many of the equipment problems during the period resulted from surveillance and maintenance program weaknesses. Examples include a lack of programs to inspect the windings of the i emergency diesel generator, overhaul valve motor operators, and the lack of a l surveillance to demonstrate operability of main station battery chargers.

l These problems indicate weak preventive maintenance practices and a need to assure that all equipment important to safety is periodically tested."

LICENSEE'S RESPONSE TO MAP CONCERN: The licensee's response to this MAP concern is based upon two element, as follows:

  • Implementation oi Action Plan 2.3.68, " Reliability Centered Maintenance (RCM)", would provide a method to identify and optimize preventive maintenance tasks.
  • Implementation of Action Plan 2.3.6A, " Maintenance Rule", would prov' a framework to meet the Maintenance Rule requirements for goal setting, '-end assessments, and measuring maintenance effectiveness.

INSPECTION RESULTS: The NRC Staff reviewed project completion plans for Action Plans 2.3.6A and 2.3.6B and interviewed managers involved in the Millstone preventive maintenance programs. While it is clearly the intent of the licensee to develop preventative maintenance programs that will comply with the NRC's Maintenance Rule, it-is not within the scope of the MAP review to

' determine compliance to the Maintenance Rule.

Based upon our review, we find that-implementation of Action Plans 2.3.6A and

-2.3.6B should accomplish the following:

  • Preventive Maintenance programs will be developed for Millstone Units 1,2 and 3 based upon uniform methods which should improve intra-unit communication \ cooperation.

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  • Use of PRA\fMEA should provide a rational basis for selecting components for preventive maintenance.

Reliability Centered Maintenance provides a vehicle for directing limited maintenance funds to the most important structures, systems and components.

  • Project schedules are intended to provide for completion of key program elements to achieve compliance with the Maintenance Rule by July 10, 1996 as required by the Rule.  !

Compliance with the Maintenance Rule will be determined by a subsequent inspection.

CONCLUSIONS: Action Plans 2.3.6A and 2.3.6B appear to be responsive to the concerns expressed in MAP issue 20.

FOLLOW-0N ACTIVITIES: Regional and NRR based maintenance inspections should include a follow-up on the progress that the licensee is making on implementation of Action Plans 2.3.6A and 2.3.6B.

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MAP ISSUE NO. 22 SURVEILLANCES WERE MISSED DUE TO POOR COORDINATION AND PLANNING STATEMENT OE_ MAP ISSUE: MAP Issue No. 22 Isote: that surveillances were missed due to poor coordination and planning. The final SALP Report, dated August 4, 1992 specifically identified this issue as related 'o three instances, at Millstone Unit 2, where surveillances were missed due to poor coordination between operations and engineering organizations.

LICENSEE'S RESPONSE TO MAP CONCERN: The licensee's response to MAP Issue No.

22 indicates that the licensee has addressed the subject concern via changes

' to procedures and processes. The response further indicated tnat the larger issues of station organization, such as work planning and control, would be addressed within Action Plan 4.2.1, "MP Station Organization".

INSPECTION RESML111 The issues of work planning and control were discussed with the licensee's Vice President, Millstone Station. The licensee indicated that the problem of work planning and control would be resolve in the upgraded station organization associated with Action Plan 4.2.1 Specifically, a shift-supervisor -level individual, responsible for work control would be identified in each Unit Operations department. The designated work control individual would coordinate unit-specific work with a designated Planning Supervisor who would be appointed to each unit functional organization which performs such work (e.g. Maintenance, Instrumentation and Control, Generation Test).

CONCLUSIONS: The licensee's plan to improve coordination between unit operations and the work groups, in order to resolve work control / planning issues appears to be responsive to the MAP concern.

FOLLOW-ON ACTIVITIES: The NRC staff should review documents which establish ft.nctional organization descriptions and associated position descriptions as they relate to Action Plan 4.2.1.

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