ML20210C162
| ML20210C162 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/28/1987 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8705060097 | |
| Download: ML20210C162 (21) | |
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GPU Nuclear
' NMCIMr 100 Interpace Parkway Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Number:
April 28, 1987 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Systematic Assessment of Licensee Performance Oyster Creek Nuclear Station Docket No. 50-219 This letter and its attachments provide our response to the Systematic Assessment of Licensee Performance (SALP) report as requested by your letter of March 12, 1937.
It summarizes, and in some areas, expands the information provided in our meeting of April 6,1987.
We believe the SALP process and the direct oiscussions it promotes between the NRC and GPU Nuclear management is of considerable value. By design, the SALP identifies areas for improvements, and GPU Nuclear takes very seriously the connents and observations in your assessment. We remain fully connitted to continually improving our nuclear activities,and I believe the attachment addresses that goal in a positive manner.
We continue to believe that SALP reports are becoming more widely known and used. Therefore, it is particularly important that they be as consistent as practical among plants and that NRC emphasize prominently in each report the manner in which they can be appropriately utilized.
P. R. Clark President PRC/MWL/pa(45859) cc: Regional Administrator U.S. Nuclear Regulatory Connission 631 Park Avenue King of Prussia, PA.
19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, N.J.
08731 8705060097 870428 PDR ADOCK 05000219 1
i G
PDR GPU Nuclear is a part of the General Public Utilities System j
PLANT OPERATIONS Two. concerns expressed in the SALP board's recommendation were in the areas of decision making on shift and operator errors.
The two areas are addressed separately below.
Decision Making on Shift:
Direction to management shift supervisors to call and discuss significant operating events has resulted in a shift of some decision-making to a higher level.
He agree this should be corrected and will take action to distinguish decision-making from notification and return proper decision-making to shift management.
Additional measures being taken in this area include:
In the Simulator Training Program, additional emphasis will be placed on shift management decision-making.
Technical Specification related discrepancies and action items will be factored into training scenarios to exercise the shift supervisors decision-making abilities.
Specific evolutions and events were discussed with each Group Shift Supervisor (GSS) during one-on-one meetings between each of them and the Plant Operations Director.
Special emphasis was placed on the GSS's role and responsibilities.
The " Command 1
Authority" memorandum was reissued and reviewed by Operations Management and the shift supervisors. During the coming year, the GSS's and Group Operating Supervisor's (GOS) will be scheduled to participate in Company sponsored management and supervisory training programs.
In addition, they will also be attending GPUN teamwork and leadership seminars.
Future interfaces in this area between Operations Management and the shift supervisors will intentionally emphasize the shift supervisors role of decision maker.
Personnel Errors:
Management recognized the continuing need for improvement (reduction) in the number of personnel errors. Operating incidents are thoroughly investigated to determine cause and develop measures to improve future performance.
A number of measures have been taken in this area:
During early 1987, the Director, Oyster Creek and Plant Operations Director met with each shift to discuss each individual's role and specific accountabilities.
Additionally, the Plant Operations Director met with each shift of GSS, GOS and Control Room Operators (CRO).
During these meetings, topics of discussion included individual's responsibilities, attention to detail, awareness, communications and attitude. Previous events were reviewed and Lessons Learned evaluated for the positive contributions that could be derived from these events.
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a The Plant Operations' Director is currently working with the Training Department to develop a revised simulator. training program.
The intent is to restructure simulator training to include additional operator evolutions that are more closely related to actual Plant evolutions and upsets that have been experienced. More attention will.be given to startups, shutdowns and low power operation utilizing manual water level control.
In addition to revising.the current training program, the Company is in the process of purchasing a full scale replica simulator.
The availability of a full scale simulator should significantly enhance operator training and result in improved response and reduction in errors. A basic principles trainer is currently being utilized _for Licensed Operator Requalification Training and is proving to be a very positive enhancement to the training program.
Technical support of plant operation has been improved.
Appropriate technical personnel are involved in plant problems at an earlier stage and tasked to provide more in-depth support.
This additional engineering attention should help reduce the number of challenges to the operators.
Procedure, hardware and equipment improvements should also significantly contribute to a reduction in personnel error.
Specifically, during the last refueling outage, there were numerous " human factors" improvements in the Control Room.
These improvements included control panel upgrade, controls and instrumentation demarcation, and reduction in annunciated alarms.
The feedwater control units were replaced with a new type that should improve the operator's ability to control feedwater when in the manual mode.
High priority was given to the reduction of Control Room deficiencies and temporary variations. Division goals were established for both. To date, significant reductions have been realized, and continued efforts are being directed to further reduce the number of Control Room deficiencies and temporary variations. Procedure revision.and upgrade continues to receive high visibility. All these enhancements collectively should reduce the number of unnecessary challenges to:the operators and significantly reduce the number of operator errors.
Increased emphasis is planned for incident investigation, review with operating personnel and implementation of corrective / preventive measures.
This increased emphasis on reviewing events and correcting observed problems should improve performance and reduce future problems.
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RADIOLOGICAL CONTROLS He concur with the finding that the radiation protection program is fundamentally sound as noted in the SALP Report.
GPUN is aware of and understands the concerns raised with regard to the implementation of the programmatic approach to achieving control of radiation exposures to ensure that they are maintained at levels as low as reasonably achievable.
He believe that the functional ALARA program is working well.
The functional ALARA program consists of those elements of near term job planning, worker briefing, radiation and contamination monitoring and control, and the use of engineering controls.
The performance of the functional ALARA program is measured in part by the low individual external doses and virtually negligible internal dose commitments during the evaluation period.
GPUN is committed to the ALARA concept and as a result of our experience during the 10R outage, actions were taken to reduce exposure such as the following:
o As part of the 11R outage, the recirculation system was chemically decontaminated, the surface of the drywell was decontaminated and the atmosphere of the drywell was cooled.
With these actions and others, over 950 man rems were saved during the outage.
o Radiological engineers were hired by the Maintenance, Construction and Facilities and Technical Functions Divisions to provide a person knowledgeable in radiological controls within the work center.
o Considerations of radiation controls have been incorporated into the Preliminary Engineering Design Review.
With regard to continuing concerns with the programmatic ALARA at Oyster Creek, the following actions have been taken or are underway:
1.
An extensive study of ALARA performance during the 11R outage was undertaken by a group representing the Radiological Controls, Maintenance, Construction and Facilities (MCF) and Technical Functions Divisions.
Thir, study identified several areas including long range planning, work scope control, work area access control, system decontamination, and source term reduction as being responsible for the relatively large collectivo dose incurred in 1986 at the Oyster Creek plant.
Recommendations of this study are being reviewed with regard to implementation.
The dose estimation process identified in the SALP report as responsible for higher than anticipated personnel exposures is not seen as contributing to the collective dose.
However, it is clear that the process needs to be iterative and dynamic in nature as opposed to the static approach taken in recent past.
2.
A multi-disciplinary group representing all segments of the Oyster Creek community was convened on March 18, 1987.
This group is currently developing recommendations for an action plan to address the following areas related to the control and reduction of occupational radiation exposures:
4585g Scope Control Long Range Plan Management Improving Perception of Collective Dose as a Limited Resource Source Term Reduction Achieving Production Efficiencies Enhancing the Role of the Dose Reduction Working Groups Reducing the Amount of Work which must be Performed in Radiologically Controlled Areas Achieving Structured Approach to ALARA Design and Engineering Reviews These include and go beyond the elements identified in the SALP report.
Another area identified as having programmatic weakness is the conservatism in the control of radiation exposure. He believe that the record of individual doses over the past years demonstrates that the Oyster Creek plant has taken aggressive steps to control the individual worker's dose at the job site. We do note that on two occasions during the SALP evaluation period, persons did exceed station administrative dose limits although they remained well within regulatory limits.
These instances point out a need to enhance our programs for routine and special surveillance and the supervisory review of radiation survey data.
Senior Radiological Controls managers will conduct periodic formal reviews of all aspects of the field operations activities to ensure a level of-performance which meets established standards.
The SALP report concerns with regard to access control problems had also been identified on the basis of in-house reviews. A facility upgrade is under development to provide better control of personnel entering and exiting the Oyster Creek drywell - the highest work hour area and the one which suffers from the most congestion.
He anticipate the facility improvements to be in place and ready for the 12R outage which is currently scheduled for the Fall of 1988.
While we acknowledge the delays in formalizing the in-house Radiological engineering training, we do not agree it is responsible for the weakness identified in the programmatic ALARA program.
He had committed to enhance the professional skills of our Radiological Engineering staff following the previous SALP. As you noted in your report, this program has changed from an Oyster Creek to Corporate responsibility. Along with the change in responsibility, we have expanded the scope of the program so that it is more appropriately a professional enhancement program (PEP).
The program is being developed along INP0 guidelines for Training System Development 4585g L l
(TSD). While this PEP is under development, there is an on-going effort to maintain and upgrade the professional abilities of our Radiological Engineering staff.
Individual professional training is scheduled for each member of the. staff to maintain state-of-the-art competence and. enhance abilities.
In 1987 for example, members of the Oyster Creek staff have attended or are scheduled to attend programs in the following areas:
1 o Principles of Respiratory Protection Program o Management Oversight Risk Tree (MORT) Analysis l
o Advanced theory and applied gamma spectroscopy for nuclear power plant applications o Health physics theory j
o Skin dose assessment We remain committed to the PEP for Radiological Engineers.
In order to expedite this program, we have made a special assignment to one member of our staff to coordinate the multitude of administrative and technical tasks in this area.
We have relieved this staff member from routine duties while action on the PEP is pursued.
We have developed and commenced a course in ALARA techniques for managers l
and engineers.
This program has been used for the Technical Functions Division personnel. A modified program has been developed for use by our personnel in the Maintenance, Construction and Facilities Division.
l The area of communications was identified as being weak and contributing to the concerns with the ALARA program.
He concur with this assessment.
Actions have been taken at the functional and programmatic levels to improve communications. At the functional level, a work planning meeting takes place daily among the supervisors of Radiological Controls, MCF, and Plant Operations.
This meeting serves to prioritize and allocate resources to achieve the goals set in the higher tier Plan of the Day (POD) meetings.
We have found that in the short time that the work l
planning meeting has been in place, we have experienced better coordination of efforts involving work in the Radiologically Controlled Area.
l At the Programmatic level, the addition of a Radiological Engineer to our l
Technical Functions Division staff along with the Radiological Engineer l
already a member of the MCF staff has improved the lines of communications l
regarding the long range planning of radiologically significant work.
Additional staff in our Corporate Radiological Engineering Group have also I
facilitated the input of radiation protection concerns into mid and long range planning. He are continuing to upgrade the communications in these areas through development of procedures and an insistence on more frequent I
formal ~and informal contact among Radiological Engineers in the R&EC, MCF and TF Divisions.
l 45859 l
In summary, although we believe that our radiological controls program is sound, we recognize the need for improvement.
Our efforts are directed at the work planning and execution process.
This involves the elements of interdivisional communications, improved control of work scope, access control and coordination of work through improved facilities and administrative practices and better processes for the on-going estimation of exposure goals.
In addition, we are taking action to assess our radiological controls practices in our Field Operations group to reduce administrative tasks and concentrate on the surveillance and assessment elements of the program.
He have set an ambitious 1987 collective dose goal of 300 person rem for Oyster Creek Plant Operations.
Planned outage activities such as the drywell wall inspection and corrosive arrest work, and unusual forced outage work such as the drywell air cooler upgrades are not included in the 300 rem goal.
Typical forced outage activities are included in the goal.
We also are now treating radiation exposure as a resource to be budgeted and controlled with the Long Range Plan.
4585g
. MAINTENANCE Based on GPUN's review of the SALP assessment and discussions with the NRC staff at the April 6, 1987 meeting, it is appropriate to comment in three specific areas and discuss in general the results of the MC&F self evaluation.
Predictive Maintenance:
The NRC Region I, 1986 Systematic Assessment of Licensee Performance Inspection (SALP) Report #50-219/85-98 for Oyster Creek, contains on Page 20 under Section C Maintenance, a brief paragraph concerning Predictive Maintenance at Oyster Creek. Specifically, " Predictive Maintenance has not been instituted and should be investigated as a potentially useful tool, especially in light of the age of the plant". During the April 6, 1987, SALP Review Meeting held at Oyster Creek, the Resident NRC Inspector, Mr. W. Bateman, clarified that this comment referred to the fact that Oyster Creek has no program to evaluate the life time of equipment and replace same prior to its self destruction due to age, heavy usage, wear, design, etc.
This is indicative of a " Reliability Centered Maintenance Program" (RCMP) as opposed to a " Predictive Maintenance Program" (PMP).
The following is a description of these programs:
o Reliability Centered Maintenance A logical discipline for developing a PM Program that will realize the " Inherent Reliability Levels" of equipment at minimum cost.
Inherent Reliability Levels - the level of reliability of an item or equipment that is derived from its design, is characterized by a near constant conditional probability of-failure, and cannot be improved by maintenance.
o Predictive Maintenance - Methods used to analyze and predict equipment performance so that planned action can be taken'to correct abnormalities prior to equipment failure.
RCMP determines when to replace a component and PMP determines when to repair a component to avoid catastrophic failure.
Oyster Creek's Plant Materiel Department, does have a working Predictive Maintenance Program.
It includes Vibration Analysis, Lube Oil Analysis, Failure Trending, Performance Trending, Thermov!Ston, and Pipe Wall Thinning Inspection Programs that are working.
These programs are being refined and upgraded all the time as is our Preventive Maintenance Program which we use as the vehicle to schedule all the above-mentioned evolutions.
Oyster Creek does not have a formal RCMP as yet, although Plant Materiel has researched the idea.
He plan on integrating RCMP into our PMP in the future.
In this way we will assure curselves of identifying questionable equipment, particularly ITS equipment, early enough to allow advance planning and budgeting for future replacement.
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Workmanship:
o MCF Management and supervision are working hard to build up a qualified work force at OC and are committed to various programs to enhance this effort.
In the recent past we have not only emphasized a strong craft _
training program but have also instituted the use of job mock-ups, required reading items, job critiques, new procedural control for rework and recurring maintenance, and procedural control for a new PMT program.
In addition, MCF is working on improving internal and external communications and simplification of work documents and reviews.
Specialty contractors are also used for the obvious reason of getting a better end product in an area where our own work force has not been adequately trained.
o At present, all GPUN Divisions are working diligently on work simplification to overcome several concerns. The Interdivisional Work Simplification Committee is looking hard at reducing lengthy procedures, encouraging more work to be controlled by work orders (Short forms, Long forms), improving / reducing document flow paths, simplify / reduce paper tracking (via GMS/2, etc.), and simplifying some areas dealing with contractors. One of the direct benefits of the work simplification effort will be to allow Job Supervisors to spend a greater percentage of their time in the field monitoring the craft and workmanship.
o The issuance of the MCF Division Procedure, A000-ADM-7100.01 titled
" Control of Rework and Recurring Maintenance" effective February 4, 1987, formally addresses this SALP concern.
While it is too early to.
quantitatively or qualitatively evaluate improvement based upon the issuance of this procedure, it is anticipated that the existence of the-procedure will bring salutary effects in the near future.
The MCF Production Director recently gave a detailed presentation of the new procedure to all MCF management at-an expanded staff meeting.
o MCF Division Procedure A000-ADM-7175.01 was issued in December of 1986 and controls the new Post Maintenance Testing Program which is expected to have a positive affect on the workmanship issue as well as the rework and recurring maintenance issues.
Recent training of MCF planners on their new PMT responsibilities and available resources has already produced a marked improvement in PMT awareness and-establishing requirements in work packages.
PMT is also being addressed in the rewriting / upgrading of standard maintenance procedures during the required biennial reviews.
This process will continue through October 1988.
o In contrast to the prior SALP findings, today's electrician and mechanic On the Job Training (0JT) has experienced great success largely because of management involvement and management's recognition of the OJT benefits. Management is committed to the goals that 50*/. of all craft will have some OJT in 1987 and that all craft will have completed their OJT in two years.
The attached Training Program OJT sheets and Classroom Hours demonstrate, graphically, this commitment.
45859. -
GPUN MAINTENANCE CONSTRUCTION & FACILITIES-INTEGRATED TRAINING PROGRAM CLASSROOM HOURS 1987. GOAL--50% OF WORKFORCE TO COMPLETE PHASE 1&2 TRAINING S000 4000-l M
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E Procedure Compliance:
The MCF Division has established written procedures and policies concerning procedure compliance and revision.
The requirements are clear in regards to action to be taken when procedures appear not to be_implementible as written.
Division programs to minimize procedure non-compliance have and will continue to be improved to reduce the potential for a non-compliance occurring which could have an. impact on the safety of the plant.
The Company undertook a general review of procedure compliance in the Company during 1986.. The following excerpt is from the final report (Procedure Compliance Task Group Report, 6/31/86), of the review as pertains to the Oyster Creek Maintenance:
"In general, MCF Division Upper / Middle Managers expect their managers, supervisors and doers.to always follow procedures as written except for obvious and minor administrative issues that do not impact safety.
Some personnel did indicate that procedures shall be-followed as written or changed'lf not implementible verbatim.
Supervisory and doer personnel are familiar with the expectations of the Upper / Middle Managers. Doers generally rely on the judgement of their supervisors to resolve procedure implementation problems they encounter.
MCF Division doers generally resolve procedure implementation problems by contacting their supervision and stopping the job. All doers felt they had received appropriate responses when they have asked for procedure clarifications or reasons for procedure requirements.
Doers did generally acknowledge their own, their Supervisor's and their Manager's accountability to assure that procedures reflect what is being performed and that the procedures are implementible as written."
4 In 1985 there were 55 QDR's assigned to MCF; of those, 21 were related to procedure non-compliance.
In 1986 there were 76 QDR's assigned to MCF' of those, 30 were related to procedure non-compliance.
In the first quarter of 1987 while only 1 QDR has been assigned to MCF, it does not involve a procedure non-compliance. A large factor for the number of QDR's in 1985 and 1986 was because of numerous contractor personnel on site performing outage related work.
The OC-MCF Technical Support section has been performing a major review and upgrade to the maintenance procedures (see below for more information on this work). During the course of the review it has become clear that the content of the majority of maintenance-procedures is adequate for'the work, but needed minor upgrading in several areas. A Human Factors format which will reorganize and clarify procedures in addition to expanding Post Maintenance Testing instruction is being incorporated into the procedures.
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During 1986 the number of procedures in~which improvements were made is'as follows:
MCF maintenance procedures which were reviewed and upgraded in 1986 January 1
July 5
February 5
August 8
March 18 September 12.
April
'23 October 42 May 26 November 54
. June 10 December 28 1986 TOTAL 232 During the first quarter of 1987 an. additional 87 procedures have been upgraded, 17 of which have been reviewed and approved. ~Hith this maintenance procedure upgrade effort, procedure compliance will be improved even more.
Self Evaluation Results:
The Maintenance, Construction and Facilities (MCF) self-assessment reviewed-activities for the time period November 1985 to November 1986.
This time period included the 11R Outage.
The assessment utilized OCNGS Maintenance, Construction and Facilities personnel with inputs from representatives from the Nuclear Assurance, Radiological and' Environmental Controls, TMI-2, and Oyster Creek Divisions.
The MCF Division recognizes the need for self-evaluation and assessment to-identify areas for improvement and to exercise management. control over actions on a. continuing nature to preclude degradation of satisfactory performance previously achieved or to identify areas for improvement in the existing program.
The GPUN Maintenance Program has made substantial progress in 1986.
Future improvements in the maintenance program are necessary and will flow from plans in place or those which are being developed.
These improvements are in the following areas:
o Continue to upgrade the maintenance procedures technically and include the new Post Maintenance Testing requirement..
o Simpilfy the implementation of the Work Management system.
o Continue training program for. Company Mechanics, Electricians and I&C Techs.
o Continue to improve radiological aspects of work to reduce individual and collective exposure and properly implement ALARA concepts.
o Continue to reduce accidents and injuries.
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o Upgrade the required reading and PRIR programs.
Issue a procedure governing the PRIR process.
o Close out existing critiques and perform future critiques in.an expedient manner to get to root cause and correct problem.
- o Continue use of specialty contractors.
o-Reduce paperwork burden to enable supervisors to spend more time in the field supervising work.
4 o-Reduce corrective maintenance backlog to reasonable size.
o Formalize and implement plan to reduce rework-in maintenance activities.
o Update plant drawings.
o Implement automated systems to simplify job closeout process.
o Improve maintainability programs by providing training to engineers and planners.
o Implement corporate maintenance labeling program.
o Maintain status in all aspects of maintenance program which have improved to meet the Company's standards.
The maintenance program at OCNGS has improved in 1986.
Programs have been established to continue the improvement in 1987. Continued management attention to achieve excellence within maintenance at OCNGS continues at very high levels of management.
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SURVEILLANCE / INSERVICE TESTING In Section D, " Surveillance / Inservice Testing,";a concern was' identified that
- the Standby Liquid Control Tank Level Indicator ~1s not functional and that.
flow indication for ESH System II-is erratic.
A new level measuring system for the Standby Liquid Control-Tank is scheduled for installation in Cycle 11.
The engineering and material procurement is in
' process with a Final Design Review scheduled for May-1987.
It is anticipated Lthat engineering will be released for construction in July 1987.. Installation of,the' level sensor indicator will be accomplished during plant operation.
The remote level indicator in the Control Room will be installed during an outage.
An annubar flow measuring. system for ESW System II is scheduled for-installation during a Cycle 11 target of opportunity outage.
The installation' specification was released for construction on March 26, 1987 and-is in the planning process.
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OUTAGE MANAGEMENT / REFUELING Contingency planning at Oyster. Creek is controlled in several ways.
These are by Long Range Planning, Integrated Living Schedule, Integrated Schedule, individual job / task contingency planning, and outage work scope control.
o The GPUN Long Range Plan basically looks ahead at the next 5 years and projects the work scope for both the operating and outage cycles.
Work scope is controlled and authorized by cycle.
The Integrated Living
. Schedule is a joint effort between the licensee and the NRC to coordinate certain mandates / requests into the Long Range Plan. -The past 10M and 11R outage and the Drywell Thinning Inspection outage due in the fall of 1987 are examples of this coordination. At the Oyster Creek i
site, MCF Planning and Scheduling group develops an. Integrated. Schedule taking into account the Long Range Plan, the Integrated Living Schedule-and all the OC site needs.
This Integrated Schedule is then " fine tuned" and fed back into.the plans and schedules. A manhour contingency is " built in" to this schedule (usually 20%). Approximately 3 months prior to an outage', work scope control-is formally transferred to the V.P./ Director - OC. Any additional work scope then must be approved by the Site-Director.
o Project Task Contingency Planning is developed at the-project engineering level and ultimately becomes part of the other plans and schedules.
Examples of this type of contingency planning used at Oyster Creek are:
o Recirculation Piping Replacement - During the-llR Outage NDE was required to be performed on all recirc piping to determine the extent of Intergranular Stress Corrosion Cracking (IGSCC). A contingency plan was developed to replace 100% of the piping if required by the NDE results. As part of this contingency plan, chemical DECON of the piping system was done to minimize exposure (ALARA) for the pipe replacement or weld overlay repairs.
o Core Spray Sparger Piping - Approximately 6 years ago cracks in the sparger piping was discovered during the reactor vessel internal inspections. Special clamps were installed to correct the problem.
However, a contingency plan was developed to replace 100%
of the sparger piping if required as a result of future vessel internal inspections.
o Emergency Condenser Piping - A contingency plan was also developed to replace 100% of the Emergency Condenser Piping based on the results of the 11R inspection.
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-. ' o Individual task contingency planning is performed _by the Job Planner by
.doing a risk reduction assessment of parts inventory, reviewing-equipment history, and thoughtful study'of all the facets of the task.
-Based on.the risk reduction-assessment,the planner will ensure.that long_ lead items and adequate quantitles'of parts are available with a built in contingency in case something unforeseen develops while
-performing the task.
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_14_
-TECHNICAL SUPPORT GPUN agrees that the favorable comments in the SALP regarding our Startup and Test Group is an accurate assessment and the comments are appreciated.
We also agree with your assessment that technical support has a number of strengths and weaknesses described as inconsistent. GPUN will undertake a self-analysis to determine the root causes for the inconsistent performance.
He request that the SALP board recommendation; that is that the NRC conduct a team inspection of technical support groups to determine the causes of inconsistent performance, be delayed until GPUN has completed the self analysis and initiated corrective actions.
In addition to the above self analysis, it is appropriate to comment on four general areas mentioned in the assessment summary.
Inadequate Control of Vendors:
GPUN recognizes that greater accountability from external engineering organizations is required. We have in the past several years established various in-house control mechanisms to insure appropriate quality engineering work is performed by the various external. engineering organizations.
Institution of these control mechanisms has been effective.
However, with a multitude of external engineering organizations being utilized, the client / contractor interface, the administrative effort, and the review process becomes very burdensome and more prone to diffuse accountability.
GPUN, therefore, has recently instituted a " Core Architect Engineer" concept.
Basically the " Core Engineering Concept" will limit the number of external etgineering organizations performing work for the Oyster Creek facility.
Currently we are contracting with two (2) A/E organizations and expect that in the future, one of these organizations will be chosen to perform all the external design engineering needed by GPUN. The expected advantages of the concept are:
l 1.
The organization will become thoroughly familiar with Oyster Creek.
2.
The working procedures, personnel interfaces, QA expectations, l
documentation required, etc. will be accomplished more effectively and efficiently.
3.
Continuity of personnel at the A/E's firm 4.
An improved concept of organizational accountability 1
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Backlog of Work:
There are several factors and actions GPUN has taken which should reduce and make more manageable the backlog of technical support work.
- Oyster Creek's cycle 10 and cycle 11 refueling outage included major plant upgrades and satisfied many regulatory required modifications.
The level of effort expended on the initial compliance of major programs such as Appendix R, NUREG 0737 items, Environmental Qualification of Electrical Equipment, etc.-has been largely completed.
New controls, procedures and program awareness will preserve and maintain compliance in these areas for existing plant; equipment as well as new modifications.
Future refueling outages can-be devoted to reducing the backlog of work, provided new regulatory required items are not excessive.
- For 1986, goals for the reduction of the backlog were established and efforts, including working on an overtime basis, were made to meet those goals. Some degree of success was realized during this time frame.
However, the established goals were not met.
The goals for reduction of backlog have been set for 1987 with additional emphasis being placed by upper management on attaining the goals.
- GPUN's long range planning and prioritization process is making more effective use of available resources. Although a reduction in the backlog is not an immediate benefit from this process, it insures that GPUN is addressing the "important" tasks.
- GPUN submitted the Integrated Living Schedule concept as a Technical-Specification Change Request on January 27, 1987.
He believe that'upon approval by NRC, efforts needed to accomplish NRC driven work will become more manageable.
The majority of late engineering for the cycle 11 refueling outage was NRC driven.
Technical Expertise:
In discussion during the NRC SALP meeting on April 6, 1987, NRC clarified that the statement in the SALP inspection regarding " weak technical expertise" referred to insufficient technical expertise allocated to some projects rather than the quality of technical expertise within GPUN.
GPUN agrees with the concern as expressed at the SALP meeting.
Proper prioritization, adequate control of vendors, improved communications and the self-analysis committed to, should result in the proper level of technical expertise being allocated.
4585g Communication:
He recognize'that a functional organization structure such as GPUN's demands-that emphasis be placed on proper communication channels being established and maintained.
GPUN has established several major interface programs that address the
. communication concern.
For example, a large percentage of management personnel has attended a Team Building and Leadership Program".
This particular program emphasizes team work and mutual support for more effective results. 'We have received very encouraging feedback from employees who have attended'this course and plan to. extend.the course to
' lower levels of management.
Another example is the Divisional Interface meetings that have been formally initiated. Upper management'(Division Directors _and those personnel that report directly to them) from two_ divisions meet to discuss how working relationships between them can be improved.
Recently, on April 20, 1987, a meeting between the Technical Functions Division and the Maintenance, Construction and Facilities Division took place.
GPUN regards the area of technical support to be a significant program element in the safe and efficient operation of the Oyster Creek facility.
He believe the specific actions described above and the self-analysis will serve to correct any inconsistent performance within this functional area.
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O ASSURANCE OF QUALITY One of the SALP board's recommendations was to redu'a the number of trivial QA/QC findings that other divisions must respond to and continue to upgrade the professionalism in QA/QC.
GPUN QA management have for several years been putting emphasis on identifying and correcting minor problems by on the spot action without the need for the more formal and administratively demanding QDR process.
Much progress has been made in this area over the last three years but continued attention and refinement is warranted.
To assist in this, site QA will analyze the specific QDR's reviewed by the NRC resident and get feedback from the resident on his particular concerns.
Based on the results, QA will define and implement any additional specific actions which appear appropriate.
With regard to the professionalism of the QA/QC staff, GPUN is committed to an ongoing program of excellence in all aspects of its operation.
In this regard, QA management are continually striving for improvement in human performance and professionalism.
These actions are implemented through the department's goals and objectives program, employee performance evaluation program, internal and external training programs, and reaction to findings and recommendations of internal and external reviews and audits.
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