ML20211M747
| ML20211M747 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/06/1997 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-97-99, WM-97-0117, WM-97-117, NUDOCS 9710150126 | |
| Download: ML20211M747 (6) | |
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WQLF CREEK NUCLEAR OPERATING CORPORATION j
Otto L Maynard j
Presdent and Chief Executtve Officer October 6, 1997 2
i U. S. Nuclear Regulatory Commission ATTN Document Control Desk i
Mail Station P1-137 l
Washington, D. C.
20555 l
j
Reference:
Letter WM 97-0073 Dated June 20, 1997, from Otto L.
Maynard to the NRC
]
Subject:
Docket No. 50-482: August 29, 1997 SALP Focus Meeting l
l Gentlemen:
I Wolf Creek Nuclear Operating Corporation (WCNOC) met with toen,bers of the NRC staff on August 29, 1997, to update the staff on the actions taken in response to Systematic Assessment of Licensee Performance (SALP) Report 50-482/97-94 The attachment to this letter provides an overview of the presentations made
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in the areas of Corrective Action, Engineering, Operations, Maintenance and Plant Support.
i WCNOC looks forward to these focus meetings to share our progress and provide j
the current status of initiatives currently in progress at the plant.
If you have any questions or desire additional information regarding this response please contact me at (316) 364-8831, ext.
4000 or i
Richard D.
Flannigan, ext. 4500.
Very truly yours,
/YAl)'INts i
Otto L. Maynard l
OLM/jad 1
I Attachment i
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Att'achment to WM 97-0117 Page 1 of 5 I.
Corrective Action / Human Performance Clay Warren, Chief Operating Officer, discussed the current status of the corrective action program including improvement to the corrective action process, trending and human performance.
The primary irnprovements r9de during the last year to the corrective action process include the assignment of Performance Improvement Request (PIR) coordinators, formation of a Corrective Action Peview Board (CARB), and an increased focur on trending.
As a result of the irrplementation of PI R cocrdinators, a smaller group of trained individuals is perf orming root cause analyses and also receiving direct feedback from CARB.
The CARB review of PIRs challenges both the evaluator and responsible manager to provide clear links among the problem. cause, and corrective actions.
The CARB also encourages the considercion of other causes and possible generic implications.
The current CARB success rate (i.e.,
cases where CARB does not ask for additional evaluation and/or additional CARB review) is at 581, up from 33% in January 1997.
WCNOC believes the quality of root cause evaluations is improving.
A root cause quality index performed by an outside consultant shows an encouraging upward trend in the quality of root causes performed from January 1995 to March 1997 As the total number of PIRs continues to rise, projected to be close to 4000 for
- 1997, it is imperative that resources be focused on the correct priorities.
Therefore, immediate problems are solved and further analysis reserved until more data is obtained through trending.
Trending is being accomplished through corretion cause analysis, PIR review, and PIR Cuordinator topics.
WCNOC' s first common cause analysis was cornpleted in August, 1937 The analysis identified that enhancement was needed in the common cause coding of PIRs and the capture of information for the PIR database.
The results reaffirmed previous assessments and the conclusion lined up with initiatives WCNOC already has in place.
PIRs are reviewed to look for common trends and recurring problems.
The review will help determine the problem scope, identify ineffective corrective ections and require initiation of a level I or level II PIR.
Along these same lines, PIR coordinators monitor specific topics for indications that trends may be changing within their groups.
Improvement of human performance is a key initiative for WCNOC. To support personnel in this effort, two types of training have been provided.
WCNOC Management and supervision were trained by Performance Improvement International (PII) on the elements of human error reduction.
Considering the success of the management and supervision courses, classes for all employees were initiated and are currently ongoing.
In addition to the PII training, Management Analysis Results Corporation (MARC) training was conducted and provides WCNOC management with the tools to consistently implement accountability measures.
WCNOC is developing an indicator for human performance which will take into account factors such as, significant PIRs related to human error, configuration control issues, industrial safety records and Maintenance reworks.
This data will be reviewed objectively to determine if an overall trend in human performance is changing.
The future challenges for WCNOC's corrective action / human performance programs include continuing to develop the initiatives discussed above, e.g.,
- trending, and resolving issues identified through trends.
Additionally, WCNOC is addressing weaknesses identified in the sclf assessment program including lack of dedicated participants and final conclusions being less critical than appropriate.
,w-
Attachment to WM 97-0117 Page 2 of 5 9
II. Engineering Richard Muench, Vice President Engineering, provided an update of activities in the following areas:
Engineering support to Operations and Maintenance, Unreviewed Safety Question Determination, System functional Assessment, Design Bases / Licensing Bases, and General Activities.
Engineering Support to Operations and Maintenance
't o increase Engineering's support to Operations and Maintenance, WCNOC has irtplemented the positions of Work Week Engineer and Night Shif t Engineer.
The Work Week Engineer is a rotating position in the Work Control Center and offers immediate support to the Central Work Authority.
The Night Shift Engineer is also a rotating position that supports the Control Room during off hours.
Both of these positions help to ensure that the correct engineering resources are involved in plant activities as they arise.
WCNOC' s Preventive Maintenance Optimization Program has analyzed 112 plant systems to date and estimates that 160 systems will be reviewed by the end of 1998.
Approximately ten preventative maintenance evaluations are done per week on an ongoing basis.
As a result of the program 100 preventative l
maintenance tasks have been added, 480 have been modified or extended and 1060 were deleted.
Engineering continues to support the plant through performance of formal t
operability evaluations.
The quality of the decisions made has been good.
However, there has been a lack of consistency in the level of documentation.
To review Engineering's role, formal operability evaluations have been reviewed as part of work product evaluations and the results indicate that the quality is good.
An operability chucklist was proceduralized in December, 1996, and has helped Shift Supervisors (SS) document their initial operability evaluation.
Fifty percent of the checklists performed are being reviewed by Nuclear Safety Engineering to evaluate the quality and completeness.
The formal operability evaluations are reviewed by the Plant Safety Review Committee (PSRC). As a real time performance indicator, Engineering is now using the Engineering Assessment Request (EAR) in the Control Room.
The EAR will provide Engineering management with direct feedback on how well Engineering is supporting plant activities.
In an effort to identify and prioritize short term actions and to communicate long term action plans, System Engineering has developed system health reports.
Thirty-eight systems have been targeted for participation in this program.
The reports are issued quarterly by the system engineer.
Each participating system engineer will present one of his quarterly reports to management once per fuel cycle.
Some of the topics covered in the reports include system trends, open work items, maintenance rule activity, short term action plans and Icng term reliability plans.
Unreviewed Safety Question Determinations (USQD)
Improvements in-the USOD area include procedural enhancements which provide increased guidance on the amount of detail required for change descriptions and for answers to questions.
Improved procedural guidance also provides for answering questions when multiple issues are involved with one change.
To improve the quality of the USODs performed, the number of personnel qualified to perform USQDs was reduced by more than fifty percent.
Ongoing improvements in the area of USQDs include the planned implementation of a PSRC first-time approval rate performance indicator.
An additional evaluation is being developed when *he originating document does not have a built in process to assess the safety of a change.
To ensure that screenings are being performed adequately they are being reviewed as part of WCNOC's Design Bases / Licensing
Attachment to WM 97-0117 Page 3 of 5 Dases (DD/LD) initiative.
Results to date indicate that screen ngs are well dpne.
System Etnotional Assessments During the Essential Service Water and Auxiliary Feedwater System Functional Assessments 672 system functions were reviewed, and 3t was concluded that Wolf Creek Generating Station is designed, configured, operated, and maintained consistent with the design basis.
The assessments reviewed 695 change packages, and all associated regulatory screenings were verified.
The change package review determined that there was inconsistent updating of affected design information. The applicable sections of the Updated Safety Analysis Report (USAR) were reviewed including 1,920 statements.
Fifty Unreviewed Safety Question Determination evaluations associated with plant modifications were reviewed and all conclusions verified. Additionally, inputs and assumptions for 673 calculations were verified.
However, it was concluded that improvement is needed in the consistent updating of calculations.
To review corrective action in the systems, 600 PIRs were reviewed for adequacy.
However, it was determined that the effectiveness of corrective actions was not always adequately verified.
The assessments also concluded that industry operating experience was consistently reviewed for potential system impact.
Correctise action documents were initiated for all issues disclosed during the assessments; 75% of those documents are closed.
Design Basis / Licensing Basis Review WCNOC Engineering currently has a detailed DD/LB basis review underway.
The program includes not only review of plant information but the deve lopment of new processes.
The following activities are currently being pursaed:
USAR fidelity, Engineering Information System, Irnproved Technical Specifications, Margin Management, Generic Letter 96-01 Review, DB/LB process review, Post-modification testing assessment, and a DB/LB clearinghouse.
This program is only discussed in general here as it is a potential topic for a future focus meeting.
General Activities During 1996, WCNOC Engineering initiated work product evaluations
'.W P Es ) on engineering work products.
The results have been positive in that the WPEs provide a mechanism for supervisors to give examples of management's expectations for level of detail and technical rigor.
The WPEs are currently performed monthly on a third of the personnel in each group.
To correctly allocate and schedule personnel resources, WCNOC engineering init iated a tracking and scheduling system last year, and wall complete an upgrade to Artemis Projectview/Trackview by the end of 1999.
To date, seven engineering groups are fully converted and schedules are in place.
The seven romaining groups are planned to be converted by the end of 1997 To help allocate the additional work associated with these new initiatives additional supervisors have been added to Engineering.
At t achment to WM 97-0117
'page 4 of 5 111. Operations, Maintenance and Plant Support Britt McKinney, Plant Manager discussed inprovements made in the areas of operations, Maintenance and Plant Support.
Operations Operations' response during non-routine and complex events was further irnproved through continuing use of poison pill and complex scenarios.
Site-wide usage of the codeword " timeout" and implementation of three-way connunication rtethods have both cuntributed to personnel improvement.
To further support the operators during non-routine events, key procedures have been streamlirmd and real time.,imulator training is perf ormed f or inf requent evolutions.
Additionally, essay style questions are used for written requal tests and systems training now enphasites seas 7nal lineups.
Objective results of the initiatives underway indicate that operators are proactively using lessons learned and are exhibiting good board awareness.
The con plex scenarios are viewed as a best practice by industry peers.
To further identify areas of improvement Shift Supervisor's have implement ad a tracking mechanism where they document items for crew improvement.
In response to concerns with literal compliance and questioning attitude, WCNOC management discussed their expectations during site wide meetings.
Executive management also met with the operating crews to reinforce the need for a good questioning attitude.
Operations personnel are exhibiting an increasingly questioning attitude as indicated by an increase in requests for reportability evaluations which in August of 1997 exceeds the total for 1996.
It is evident that personnel are questioning ongoing practices by an increase in Licensee Events Reports (LERs) for issues with historical origins.
Additionally, operators have questioned plant activities such as the procurement of non-Appendix D certification gas f or saf ety-related components and performance of certain Technical Specifications at shutdown.
Both of these issues resulted in LERs and program changes.
The standards for procedure usage and documentation in the Control Room logs are reinforced at each shift turnover.
A computerized logging system.
"Autolog" is now in place in the Control Room, and the quality of log entries is improving.
The number of formal operability evaluations is decreasing due to the ability of the SS to review and receive informction.
Additionally, the operabilLty checklist provides the SS with a consistent approach to each operability issue.
To improve and monitor personnel accountability, Operations and the site have adopted and implemented the MARC methodology.
MARC will be reinforced in 1998 to encourage consistent application of the methods across the site.
Maintenance In response to concerns about adherence to procedures, Maintenance has implemented "standdowns" and " quality time" for craft personnel.
The MARC process is used to respond to personnel accountability issues.
To assess performance, Maintenane; personnel are involved in an increased number of self assessments and, at the request of Maintenance management, Quality Evaluations has increased their audits in the maintenance area.
Increased craft involvement in work planning and walkdowns is helping to increase understanding for both planners and craft.
Maintenance supervisors are spending more time in the field critiquing and providing real time feedback.
Maintenance activities at the plant have reduced online corrective maintenance work packages by 50 percent f rom April, 1996.
Additionally, sefety related pcNer block work packages greater than six months old are currently below 20, down from 80 in July, 1996, and schedule adherence is trending close to 80 percent.
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