ML20217D528

From kanterella
Jump to navigation Jump to search
Forwards Comed Suppl Response to 10CFR50.54(f) Ltr.Response Provides Addl Info Re Performance Indicators Comed Plans to Use at Nuclear Plants
ML20217D528
Person / Time
Issue date: 04/21/1997
From: Blaha J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Fleishman M, Lopezotin M, Virgilio M
NRC COMMISSION (OCM)
Shared Package
ML20217D413 List:
References
FOIA-97-178 NUDOCS 9710030263
Download: ML20217D528 (2)
v • d • e


Text

_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _

kI p#"%

9pf)

_Jt UNITED STATES O

p ; _) ( '}

NUCLEAR REGULATORY COMMIS$'0N s

  1. 'g WASHINGTON, D.C. 30566-4001 April 21, 1997 NOTE TO COMMISSIONER ASSISTANTS OCM/SJ OCM/KR OCM/GJD L, Marty Virgilio Myron Karman

_ Brad Jones

_ Victor dcCree L Mort Fleishman L Terence Chan

_ Karla Smith

_ Jack Sorensen

_ Anthony Markley

_ James Johnson

_ Seth Coplan

_ Joel Lubenau

_ Brian llolian Lil Van Cise

_ Torre Taylor

_ Regis Boyle

_ Ann Haikalis Donna Smith

_ Jackie Silber

_ Joanne Field Clare DeFino Janice Dunn Lee OCM/ND OCM/EM

__ Tom Hiltz Jim Smith L Maria Lopez Otin L Joe Gray

_ Laban Coblentz

_ Roger Davis Janet Schlueter Evelyn Williams

_ Charleen Raddatz

_ James Beall Gladys Ordaz-

_ Tony Hsia

_ Jeffry Sharkey

__ Judy Ledbetter Les Constable Cathy Grimes Leslie Hill

_ Harriet Karagiannis.

Linda Lewis Frances _ Marek

_ Alice Gehl

_ Vicki Bolling FROM:

James L. Blaha Assistant for Operations OEDO

SUBJECT:

COMED's SUPPLEMENT RESPONSE TO 50.54(f) LETTER Attached is Comed's supplemental response to the NRC's 50.54(f) letter.

This response provides additional information regarding performance ir<licators Comed plans to use at their nuclear plants.

If you have any questions regarding this matter, please contact Brian McCabe at 415 1721.

Attachment:

As stated cc:

J. Callan, ED0 (w/o attachment)

S. Collins, NRR (w/ attachment)

E. Jordan, DED0 (w/o attachment)

F. Miraglia, NRR (w/ attachment)

H. Thompson, DEDR (w/ attachment)

R, Zimmerman, NRR (w/ attachment) 1-P. Norry, DEDM (w/o attach.nent)

R. Capra, NRR (w/ attachment) 1 J. Blaha, AO (w/ attachment)

B. McCabe, OED0 (w/ attachment)

SECY-(w/ attachment)

OGC (w/ attachment)

OCA (w/ attachment)

OPA (w/ attachment)

,s 9710030263 970930 SAD

-178 PDR

Commons r;.ith tdoon nnnp.ml one Hr.4 tekwul Plum r.o. tiox 762 O*Jp.o II.(/WAMd67 April 15,1997 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

Subject:

Braidwml Units 1 and 2 (NRC Docket Nos. 50 456/457) nyron Units 1 and 2 (NRC Docket Nos. 50-454/455)

Dresden Units 2 and 3 (NRC Docket Nos. 50-237/249) 1.aSalle Units I und 2 (NRC Docket Nos. 50 373/374)

Quad Cities Units I and 2 (NRC Docket Nos. 50-254/265)

Zion Units 1 and 2 (NRC Docket Nos. 50-295/304)

Transmittal of Commonwealth Edison Company's (Comed)

Definitions of Performance Indicators and Associated Performance Criteria Related to 10 CFR 50.54(f) Response Dated March 28,1997 1

Reference:

(1) Commonwealth Edison Company's (Cemlid) Response to the U.S. Nuclear Regulatory Commission (NRC) Request for Information Pursuant to 10 CFR 50.54(f) Regarding Safety Performance at Comed (2)

H. Thompson letter to J.J. O'Connor, dated January 27,1997t

" Request for Information Pursuant to 10 CFR 50.54(f)

Regarding Safety Performance at Commonwealth Edism Company Nuclear Stations."

Dear Mr. Callam In Reference (1) Commonwealth Edi.4nn indicated that we would provided additional information to the NRC staff regarding the performance indicators we planned to use in response te the NRC's request for additional information pmsuant to 10 CFR 50.54(f)(Reference 2)

The purpose of this letter is te provide Comed's definitions and performance criteria for each of the indicators listed in Reference (1), Section 4.7.2. Attached are the dermitions for the previously selected division-wide 25 performance indicators and associated performance criteria selected to measure our progress towards improved performance.As a result of experience gained in monitoring these indicators, the dermition of Collective Radiation Exposure has been

~

%pxns

-A?f22dih 9pf.

...-..-.-......_T

..........s U. S. Nuclear Regulatory Commission April 15,1997 Page 2 modified. Reference (1) stated that this indicator would be measured on a site basis. '!his has been subsequently changed to monitor on a unit basis.

Additionally, Jose accumulated from Dresden Unit I will nt>t be included in this indictor.

Ilope you find this infortnation useful in anticipation of our meeting with the NRC Commissioners on April 25,1997.

Sincercly.

d..W A Executive Vice resident and ChiefNuclear Officer

Enclosure:

Cornmonwealth Edison Performance Indicator Definitions and Criteria cc:

11. Thompson, Deputy Director for NRR A. Beach, Regional Administrator - R111 R. Capra, Project Directorate - NRR R. Assa, Braidwood Project Manager - NRR G. Dick, Byron Project Manager NRR J. Stang, Dremien Pmject Manager.NRR D. Skay, LaSalle County Projcet Manager NRR R. Pulsifer, Quad Cities Project Manager - NRR C. Shiraki, Zion Project Manager - NRR Braidwood, Senior Resident In' pector s

Bynm, Senior ResidentInspector Dresden, Senior Residentinspector I Alle, Senior ResidentInspector Quad Citics, Senior Resident inspector

(.

.7. ion, Senior ResidentInspector OfUce of Nuclear Facility Safety. IDNS M

Commonwealth Edison Perforinance Indicator Definitions RDd Eerformance Critgila A. INDUSTRY WIDE INDICATORS The following seven Indicators, used by the NRC and World Association of Nuclear Operators (WANO), provide a high level safety overview, an Indication of overall effeeliveness in achievinD improved perfo,mance results, and permit evaluation of whether we are reaching our overall goal of operating each site at a 6evel consistent with it's industry peers.

1. Automatic Screw While Crhical The number of unplanned auomatic scrams per yearwhile critical. Examples include scrams from unplanned transients, equip.nent failures, spurious signete, or human error. Scrams occurring during the execution of procedures in which there was a high chance of a scram occurring, but the occurrence of a scram was not planned are included.

Performance criterion: More than one scram per unit per year,

2. Safety Gystem Actuations Manual or automatic actuations of the logic or equipment of either certain Emergency Core Cooling Systems (ECCS) or, in response to an actuallow voltage on a vital bus, the Emergency AC Power System input for this indicator are derived from LERs and supplemented by 50.72 reports, in determining which events should be counted by this indicator, the following conver.tions are used:
1. Only actuations of the H:gh Pressure Iriection System, Low Pressure injection System, or Safety injection Tanks are counted for pressurized water reactors (PWRs). For boiling water reactors (BWRs), only actuations of the High Pressure Coolant injection System, l.ow Pressure Coolant injection System, High Presture Core Spray System, or Low Pressura Core Spray System are counted. Actuations of the Reactor Core isolation Cooling System are not counted.
2. Actuations of lumrgency AC Power Systems are counted only if they were in response to an cctuallow voltage condition on a vital bus. Spe,:ifically, actuations are counted only if the Emergency AC Power System's output breaker closed, or should have closed, to power a dead bus. Actuations resulting from momentary low voltage conditions that do not result in emergency output breaker closure are not counted.
3. Logic actuations of any of the equipment associated with the specific ECCS or Emergency AC Power System are considered necessary and sufficient to constitute a data count. For example, if only a valve in a system is commanded to move to its emergency operational position, this is counted as an ectuation. A pump does not have to be commanded to go to its emergency mode of operation and fluid does not need to be injected for an occurrence to be counted.

i 1

4 l

4

4. Only o..e ECCS actuation is counted in any one occurrence, even if multiple ECCS systems actuato during the occurrence. For example, actuation of both the High Pressure injection and the Low Pressure injection Systems at a PWR during the same occurrence couats as only a single ECCS cctuation.
5. Only one Emergency AC Power System actuation is counted in any occurrence, even if multiple cmergency pensrators actuate during the occurrence. For example, actuation of all four emergency dttel ponerators (EDGs) et a unit counts as only a single actuation for that occurrence.
6. Occurrences involving actuations of both an Emergency AC Power System to power a dead bus cnd an ECCS are given a count of two, one for the Emergency AC Power System actuation and one for the ECCS actuation.
7. At multi-unit sites that share equipment (e.g., a swing EDO or shared buses), actuations are counted and assigned to the unk at which the actuation signal or loss of power originated. If the signal s:urce cannot be associated with one unit, the actuation !s assigned to both units.

Performance criterion: More than one safety system actuation per unit per year.

3. Collective Radiation Exposure The total effective dose equivalent (TEDE) received by all personnel coming on site.

TEDE includes *unmonitored' or 4 racking

Report the total per unit value (at Dresden, exclude Unit 1).

P:rformance criterion: Projected or actual results exceed the annual year end exposure goals cxpressed on a per unit basis.

4. Unit Capability Factor The ratio of available err.rgy generation over a given time period to reference energy generation over the same time pedod, expressed as a percentage with both energy generation terms determined relative to referenca ambient conditions.

Available energy generation is the energy that could have been produced under reference conditions considering only limitations within control of plant management (i.e., plant equipment and personnel performance, and work control).

Reference energy generation is the energy that could be produced if the unit operated continuously at full power under reference ambient conditions throughout the period Reference ambient conditions cra cnvironmental conditions representative of the annual mean (or typical) ambient conditions for the unit.

P:rformance criterion: Projected or actual performance falls below year end goal. This criterion will cpply to Zion and LaSalle following restart of their units.

2

'I

5. Unplanned Capability Loss Factor The ratio of the unplanned energy losses during a given period of time to the reference energy generation, crpressed as a percentage.

Unplcnned energy loss is energy that was not prode1 during the period because of unplanned shutdowns, outage extensions, or unplanned l>ad reouctons due to causes under plant manegement control Causes of energy losses are considered to be unplanned if they are not scheduled at least four weeks in advance.

Reference energy generst'on is the energy that could be produced if the unit operated continuously at full power under reference amblent conditions thrt,ughout the period. Reference ambient conditions are environmental condidons representative of the annual mean (or typical) ambient conditlons for the

unn, Performance criterion: Projected or c:4ual results show espability loss will be > 5% above established year-end site target. This criterion will apply to Zion and LaSalle following restart of their units,
8. Safety System Performance This indicator is calculated separately for each of the following three BWR systems and each of the following three PWR systems:

BWRs high pressure injection / heat removal (high pressure coolant injection or high pressure core e

spray or feedwater coolant injection, and reactor core isolation cooling or isolation condenser systems) residual heat removal system e

emergency AC power system e

PWRs high pressure safety injection system e

auxiliary feedwater system e

emergency AC power system o

The sum of the unavailabilities of the components in each safety system listed above divided by the number of trains in the system. The component unavai' ability is the ratio of the hours the component was unavailable to the hours the system was required to be available for se vice. For the emergency AC power system, the indicator is defined as the sum of the emergency generator (diesel or gas turbine) unavailabilities divided by the number of emergency generators at a station. Fgr the emergency AC power system, the indicator is displayed for all'.tations. For the other safety systems, the indicator applies to either BWRs 4 PWRs and is displayed separately, Performance criterion: Unavailability exceeds two times the industry goal for any system, t

4.s

7. IndustrialSafety Accident Rate The number of accidents for all utility personnel permanently assigned to the station resulting in one or more days away from work (excluding the day of the accident), or one or more days of restricted work (excluding the day of the accident), or work related fatalities, per 200,000 man hours worked.

Contractor personnel are not included in this indicator.

Performance criterion: ISAR exceeds the established site target.

B COMMONWEAL.TH EDISON SPEclFic INDICATORS The following eighteen Commonwealth Edison specific indicators were selected based upon review of indicators that Comed has used in the past, review of indicators used by other nuclear utilities, and the experience of our management team, many of whom have used these indicators in other nuclear programs. They will be applied in a consistent manner across our stations and cover the important operating, maintenance, engineering, and corrective action areas that must perform well for sustained improvement at each site. They are designed to provide a level of sensitMty and detall so that timely corrective action can be taken when performance trends surface, permitting us to resume tracking toward our overall goal of superior performance.

OPERATIONS

8. Operator Workarounds An equipment or program deficiency which requires that an Operator take non-standard action to comply with procedures, design requirements, or Technical Speelfications.

(# opened during the month)(# closed dunng the month) (total # at end of month)

Performance criterion: Greater than a 10% deviation from the site workdown curve.

9. Out of Service Errors The total humber OOS error PlFs that are designated as significant (Level 1,2, or 3 PlFs or SCAO in the new CAP process). (total # during the month)

Performance criterion: Greater than one error per month.

10. Human Performance Error Licensee Event Reporta (LERs)

Errors of omission or commission by any indNidual during plant actMties leading to submission of an LER. Count all LERs that are designated as having the cause being personnel error and LERs with a primary cause code of A. Count the LERs submitted during the month. (# during the month)

Performance criterion: Greater than or equalto two per month per site.

i

(

O

11. Temporary Plant Alterations The total number of temporary allarations. Temporary alterations are non permanent changes, modifications, or adjustments to the approved design configuration of a structure, system, or component. (# opened during the month)(# closed during the month)(total # at end of month)

Performance criterlon: Greater than or equal to 10% deviation between the number opened and closed during a month.

12. Failed Technical Specification Pump and Vahre Surveillances The number of Technleal Specification, pump and valve surveillances, including IST, which do not moet the Technical Speelfication or IST required acceptance criteria for pumps and valves per month.

Does not indude Administrative Technical Specification requirements. (# of failed pumps and valves during the month)

Performance criterion: Trend for 6 months to establish basellne prior to selecting criterion.

13. Unplanned Entries into LCOs The number of times that the unit was in a 7 day orless required shutdown LCO that was not previously planned. (# during the month)

Performance criterion: Trend for 6 months to establish baseline prior to selecting criterion.

14. Percent Contaminated Floor Space All areas of the plant that have smearable contamination 2: 1000dpm/100cm'. The only areas excluded from this trending are; high radiation areas with ir frequent access, areas that are not accessible, vaults, pits, areas routinely used for contaminated work. Areas containing grating and satellite RPAs shall be trended as part of this indicator. (% at the end of the rnonth)

Performance criterion: Greater than 3% total area, as defined, for each site.

MAINTENANCE

15. Non outage Corrective Work Requests The number of corrective maintenance work request tasks, including degraded and action requests, that are non-outage and for power block equipment and structures. Corrective maintenance is the repair and restoration of equipment or components that have failed or are malfunctioning. (# opened during the month) (# closed during the month) (total # at end of month)

Performance criterion: Greater than or equal to 10% deviation from established workdown curve.

1 5

- _... - - - - _ ~ -

- _ = - _ _ _ _ - _

s s'

0, it. Percent Rework The performance of any physical maintenance task which results in a loss of time or rnoney.

analysis of the component history in which any maintenance {like in kind) is identified within 12 months cher maintensnoe has been performed on that component. The total rework per month dividej b total number of all corrective and degraded malntenance completed by maintenance per month excluding surveillances and preventive maintenance. (% for the month)

Performance criterion: Greater than or equal to 4%.

17. Outage Work Requests i

The number of work request tasks that require ari outage to complete. (# at the end of the month)

Performance criterion: Trend for 6 months to establish baseline prior to selectirig criterion.

ENGINEERING

18. Engineering Requests The total number of open engineering requests that include requests for design changes and support from engineering. (# opened during the month) (# closed during the month) (total # at end of month)

P;rformance criterion: Trend for 6 months to establish baseline prior to selecting criterion.

4

19. Engineering Requests Overdue I

The number of overdue engineering requests for design changes and support from engineering. (iV during the month)

Performance enterion: Trend for 6 months to establish baseline prior to selecting criterion.

CORRECTIVE ACTIONS

20. Corrective Action items Number of corrective actions resulting from NOVs, PiFs, LERs, or CARS per month that have been opened, closed and total remaining open at the end of the month. This includes NTS items with a Doc Type = 100,180,181,200,230, and 315. (# open during the month) (# closed during the month)

(total open at the end of the month)

Performance criterion: Trend for 6 months to establish baseline prior to selecting crrterion.

4 6

4 i

A 4

s

=

i i

21. Overdue Corrective Action i

Number of corrective actions resuhing from NOVs, PlFs, LERs, or CARS that went over i

month. This includes NTS items with a Doc Type =

i the month) 100,180.181. 200,230, and 315. (total # during 4

Performance criterion: Greater than or equalta 15 / quarter, j

22. Repeat Events 2

MonthY, the number of events that occurred during the past month whose root cause inv q

report has been completed during the past month, that are reasonably similar in nature, to an event j

that oocurred during the past 24 calendar months with one or more of the same root causes. There is l

approximately one month lag in reporting this indicator due to the time to complete toot cause

]

Investigations. (# during the month)

Performance criterlon: Greater than or equal to 10% of totalinvestigatJons indicate repeat events.

23. Number of Problem Identification Forma (PlFa) Written The number of PlFs written by the site. (# during the month) i Performance criterion; Trond for 6 months to establish baseline prior to selecting criterion.

I j

OTHER l

j

24. Overtime Hours The number of overtime hours worked by hourly and salaried personnel through grade 11 by s 4

. month. (total overtime hours at the end of the month)

Performanos criterion: Greater than or equal to 10% of planned overtime hours.

25. Ched NRC' Violations l

The number of ched violations per m. nth. The month in which the inspection report is issued is the j..

month in which the cited violation is counted. (total # during the month) j Performance ortterion: Trond for 6 months to establish baseline prior to selecting criterion.

i-i i

j k

]

e b

~

Commissioner McGaffican's Visitor too Organization Visitor (s)

Contact & No.

Date & Time California. LLW Program Carl Lischeske 916-323-3693 04/10/97 at 3:30PM 96 at Carolina Power & Light Company Wi as Cavanaugh III. President

{

William S. Orser. Exec. VP of Nuclear Generation Center for Nuclear Waste Wesley Patrick Sh r Fortuna 0

96 at Regulatory Analysis (OGRA)

Mr. Sagar 41 -

Mr. Russell l

Wesley Patrick Shirley Fortuna 02/25/97 at l

CMRA 415-7804 4:30PM rnemariwealth Edison Company Tom Maiman. Sr.. VP. Nuclear Irene Johnson 10/03/% at Division /CN0 630-663-20 %

10:30AM Harry Keiser. Chief. Nuclear Operating Officer John Mueller. Site VP at Zion Comed Mike Wallace. Sr. VP & CN0 Mary. Winston &

12/03/% at Jim O'Connor. CEO Strawi 11:30AM 202-371-5751 Conference of Radiation Bill Dornsife. Director 717-787-2480

/% at Control Program Directors G:\\ VISITORS OI ThdiOO May 13. 1%7 L

4 Cll LD%

.

Retrieved from "https://kanterella.com/w/index.php?title=ML20217D528&oldid=3965128"