ML20211B060
| ML20211B060 | |
| Person / Time | |
|---|---|
| Issue date: | 03/27/1997 |
| From: | Caldwell J, Roe J NRC (Affiliation Not Assigned), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Beach A, Collins S NRC (Affiliation Not Assigned), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20211B034 | List: |
| References | |
| FOIA-97-288 NUDOCS 9709250053 | |
| Download: ML20211B060 (9) | |
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D.C. 304M4001
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March 27, 1997 MEMORANDUM 10:
Samuel J. Collins, Director Office of Nuclear Reactor Regulation A. Bill Beach, Regional Administrator Region III FROM:
Jack W. Roe, Director Division of Reactor Pr j ts Ill/IV Office of Nuclear Reactor Regulation James Laldwell, Director NTeb1 Division of Reactor Projects, Re'gion 111
SUBJECT:
COMMONWEALTH EDISON 50.54(f) RESPONSE ASSESSMENT CRITERIA AND STRATEGY FOR MONITORING PERFORMANCE As a result of NRC concerns regarding inconsistent and marginal plant performance at some of Commonwealth Edison Company's (Comed) nuclear facilities, a letter was issued to Comed on January 27, 1997, pursuant to 10 CFR 50.54(f).
The letter requires Comed to submit information within 60 days that will allow the NRC to determine what actions, if any, should be taken to assure Comed can safely operate its six nuclear stations while sustaining performance improvement at each site.
Comed was requested to provide the following information:
information explaining why NRC should have confidence in Comed's a.
ability to operate six nuclear stations while sustaining performance improvement at each site, and b,
criteria that Comed has established or plans to establish to measure performance in light of the concerns identified and Comed's proposed actions if those criteria are not met.
A joint Region 111 and Headquarters team has been established to review the Comed response and provide its assessment of the response to you.
The team has prepared two documents to aid in assessing the quality of Comed's response and monitoring future plant performance. The first attachment contains 1
assessment criteria for reviewing Comed's response.
The second attachment i
contains a draft strategy for monitoring and evaluating Comed's performance, it is important to note that since we do not know the approach Comed will take in responding to the 50.54(f) letter, the criteria in Attachment 1 is preliminary and will not be used to make a pass / fail determination on the
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s quality of the response, but will be used as a guide during the review.
Attachments 1 and 2 may need to be revised following the team's review of Comed's response.
Comed's response is due on March 29, 1997, and is expected to be received on Monday, March 31, 1997.
The team will be reviewing the response during the first week of April and plans on briefing you on April 8, 1997 (4:00 pm EST).
Following that discussion, the team will finalize its assessment and incorporate your comments.
A 00 am EST). pre-brief has been scheduled with the EDO on April 16, 1997 (11:
The Commission meeting is scheduled for April 25,1997(10:00amEST).
Please let ts know if you have any comments or questions regarding our course of action.
Attachments:
1.
Assessment criteria 2.
Strategy for Monitoring Comed Performance 2
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COMED 50.54(f) RESPONSE ASSESSMENT CRITERIA Item a of 50.54(f) Letter:
Information explaining why NRC should have confidence in Comed's ability to operate six nuclear stations while sustaining performance improvement at each site.
Criteria for Item at RQOT CAUSE IDENTIFICATION:
Does Comed understand and discuss the root causes of the cyclical safety performance of its nuclear stations?
Is there a basis for Comed's root cause assessment?
Does Comed provide an explanation of why this root cause analysis is different from past assessments? Did they factor in any lessons le..rned from past assessments?
Does Comed provide a rationale for rejecting potential root causes?
Are Comed's root causes consistent with NRC's observations and assessments?
NRC's past assessments identifying major apparent weaknesses that led to poor performance included:
a.
Lack of effective management attention and application of resources; b.
Weak corporate oversight of nuclear operations; Poor problem recognition and failure to ensure lasting corrective c.
actions; d.
Lack of adequate engineering support; and e.
An inability or reluctance to learn from experiences at Comed and other utilities.
Are Comed's identified root causes consistent with the " Fundamental &
Contributing cause Assessments" determined during Comed's recent Independent Self-Assessments (ISA) of the LaSalle and Zion Stations?
CORRECTIVE ACTION plan / STRATEGY Is-there a plan and/or strategy to specifically address the root causes, based upon Comed's understanding of the root causes of cyclical safety performance at its sites?
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- 2-Does the plan and/or strategy define objectives or goals to be achieved from implementing specific actions with scheduled milestones?
Are the proposed corrective actions clearly cross-referenced to al; ine associated root causes and causal factors they are intended to correct?
Does the plan have a method for monitoring completion of goals and effectiveness of goals?
Were the six stations, as well as corporate, involved in development of the plan and/or strategy?
Does Comed address any potential conflicts or negative consequences with implementing the corrective action plan?
Does the corrective action plan address the potential need to assess changing conditions to detennine whether the licensee must modify the f.orrective action plan?
RESOURCES & ACCOUNTABILITY Has Corrfd determined the resources necessary to sustain long-term
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performance improvement at each of the stations and have those resources been coraitted to by Comed?
Does Comed specify that an individual and organization will be designated to lead the implementation of the corrective action plan and that they clearly understand their responsibility? Does the individual have sufficient authority and resources to ensure the action will be adequately completed?
MANAG[ MENT & ORGAN 17AT10t1 Does Comed discuss the responsibility of corporate and site leadership?
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Does Comed discuss the development of high performance standards and a strong safety culture that will ensure safety and conservative decision making are placed ahead of production and cost?
Does Comed discuss its plan for engaging the work force (i.e., does Comed address its plan to gain workforce buy-in to high performance standards)?
Does Comed discuss how goals and expectations will be clearly communicated to their staff?
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Does Comed address corrective actions for weaknesses observed in communications and command and control?
Does Comed address corrective actions for weaknesses observed in procedural adequacy and compliance?
MATERIAL CONDIT10f{
Does Comed address actions it is taking to assure that long-standing material condition and engineering issues are properly identified.
prioritized and addressed?
Does the response address how Comed will assure the high availability and relinbility of safety systems?
WORK CONTROL Does Comed address corrective actions for the significant weaknesses identified in tha work control process?
CONTROL Of DESIGN BASIS Does Comed address actions it is taking to assure the adequacy and availability of design basis information at its facilities?
[ Note: Responses to riRC's 10/u9/96 10 CFR 50/54(f) letter regarding this subject were submitted on 02/09/97.)
Does Comed discuss how it is addressing known weaknesses identified in the maintenance of the design and licensing basis of its facilities?
Doet Comed address what actions they have taken to ensure Comed engineers understand the design basis and are not continuing reliance on the AE.
Silf-ASSES!/"NT AND CORPORATE OVERSICHT Does response address how Comed will strengthen and utilize the result of its self-assessment process.
Does the response address how Comed will strengthen corporate oversight of:
nuclear operations, maintenance, wark control.
engineering, licensing,
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plant support, training,- and corrective action processes?
l Does the response address improvements in the effectiveness of the on-site and off-site review committees, the site quality verification (SQV) function at each site and the Nuclear Overc.ght Committee?
Does Comed address how it will improve communications to assure potentially generic problems identified at one site are effectively communicated and addressed at other affected sites?
Does the response address Comed's benchmarking of performance'and/or l
processes against good performing utilities?
TRAINING t
Loes Comed address corrective actions for weaknesses identified in the knowledge and skills of personnel in operations, maintenance and engineering?
l COMMUNICATIONS i
Does Comed address corrective actions for weaknesses identified in
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communications (e.g between departments).
EFFECTIVENESS OF INTEGRATED ACTIONS In light of Comed's past history of developing improvement plans and strategies that have been. ineffective and/or not fully implemented, does Comed's response specifically articulate why the NRC should have confidence that the actions Comed has taken and/or plans to take will be effective in ensuring safe operation at each of its facilities and will end the. spiral of inconsistent and marginal plant performance.
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. s-Item b of 50.54(f) Letter:
Criteria that Comed has established or plans to establish to measure performance in light of the concerns identified and-Comed's proposed actions 1
if-those criteria are not met.
Criteria for Item b:
Has Comed identified a systematic assessment process to identify problems, collect data,. assess performance, and monitor, meuure, and feedback results of corrective actions?
1.
Criteria developed by Comed for measuring performance should meet as many of the following guidelines as possible:
linked to the root causes Comed has identified for inconsistent a.
performance, b.
measure the effectiveness of the corrective actions that Comed has put in place to address inconsistent performance; c.
are as objective as possible; d.
are not subject to manipulation; e.
are consistent at each station; f.
are well defined and meaningful; g.
should be able to be validated by independent parties; h.
provide real time information; and, i.
should be clearly communicated to and understood by the Comed management and staff.
2.
Comed's response should also identify:
a.
how the information will be collected;.
b.
how the information will assessed:
c.
the frequency of collection and assessment; and, d.
the method of feedback to the stations and to the NRC.
3.
Comed's proposed actions, if their criteria are not met, should meet as many of the following guidelines as possible:
a.
should be specific;
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cover the complete spectrum of possible actions; c.
have a clear and well defined threshold; d,
should be clearly communicated to and understood by Comed management and staff personnel; and, should have a process to revise the corrective actions or propose e,
new corrective actions.
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RECOMMENDED STRATEGY FOR MONITORING COMED PERFORMANCE in order to assess Comed's ability to operate six nuclear stations while sustaining performance improvement at each site, a common strategy will be utilized to assure the staff is properly focused on providing a broad assessment of Comed's performance. We will utilize the curre.nt inspection and assessment programs to evaluate performance, augmented as necessary for some Comed sites based on current performance.
The strategy is designed to monitor plant performance individually and collectively such that improvement initiatives at each station can be evaluated and negative performance trends can be identified as early as possible.
in implementing this strategy, the staff will assess whether Comed's actions in response to plant events or issues at one facility are impacting performance at other sites.
The ability of Comed to manage improvement initiatives at one station and not reduce good performance at another station is critical to arresting the cyclic performance.
Comed's ability to sustain performance improvement may be demonstrated only after a significant time period.
The staff recognizes that there is not a " quick fix" to many of Comed's problems.
The strategy for monitoring Comed performance is composed of the following seven actions:
1.
Ensure a sound inspection program, tailored to performance, is implemented at each site.
2.
Continue to monitor performance improvement at LaSalle and Zion through the use of the joint Region Ill/NRR Oversight Panels and continue to close-out the Independent Safety inspection findings on Dresden as appropriate.
3.
Develop and implement a program to evaluate the effectiveness of Comed corporate and site-specific corrective action initiatives.
4.
Monitor objective performance indicators identified by Comed and the staff to assist in the identification of declining trends at an early stage.
5.
Broaden use of the current Plant Performance Review Process to integrate performance observations from each station to identify:
if there are any common areas of marginal or unsatisfactory I
performance, and if declining performance at any of the stations may be caused by the shifting of resources or lack of adequate corporate oversight.
6.
Discuss performance of all Comed plants during the Senior Management Meeting Screening Meetings and during Senior Management meetings.
7.
Conduct periodic management meetings between NRC and Comed senior management to discuss performance at all Comed plants.
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