ML20236K320
| ML20236K320 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/30/1998 |
| From: | Olivier L BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-293-97-80, BECO-2.98.091, NUDOCS 9807090275 | |
| Download: ML20236K320 (3) | |
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o Boston Edison Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, Massachusetts 02360 LJ. Olivier Senior Vice President Nuclear June 30,1998 BECo Ltr. 2.98.091 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Docket No. 50-293 License No. DPR-35 Chance in Corrective Action Scope This letter is submitted to inform the NRC of a change in scope to a corrective action associated with Notice of Violation 97-80-01. Specifically, Boston Edison Company letter 2.97.132 dated December 27,1997, discussed cause and described corrective actions to preclude recurrence of procedural compliance issues. As stated in this response, the procedure adherence problem was the result of two primary root causes, a complex and confusing procedure structure and ineffective oversight and corrective action validation at the manager and supervisory level. The corrective actions to preclude recurrence, therefore, were structured to address these causes and build on past corrective actions already taken or that were stillin progress.
l One corrective action in particular was intended to build upon previous improvements made in the area of procedures process re-design. These improvements came about through the d
efforts of a team assembled to identify potential procedure process changes and implement
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and train personnel accordingly. The team's objective was to remove barriers to efficient use and adherence to procedures by improving the procedure development and change process, as well as simplifying complicated process procedures. The team evaluated the current procedure change process and developed a more streamlined and more timely process by
[b which procedures could be changed. This change required a change to Technical Specifications which is currently pending with the.NRC. Once that TS change is approved, the new process will be implemented, and controlled by a Nuclear Organization Procedure (NOP).
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e In order to build upon procedure process improvements, a follow-on team was planned to undertake an additional effort of procedure structure and content improvement. The expected outcomes were guidelines for procedure structure and content and definitions and policies for procedure compliance and adherence. The expectation was for the team members to then mentor department managers for possible cancellation, consolidation, and re-writing of procedures. After further analysis, this commitment was implemented in a different, but more effective manner than was originally envisioned for the following reasons.
As part of an ongoing station performance improvement plan, teams of Pilgrim personnel, including managers and supervisors, have visited several top performing plants to benchmark many areas of our performance. From these visits, it was observed that the structure and content of our procedures was not as complex and in need of as much work as we initially believed. More emphasis on personnel accountability for procedure adherence worked successfully at these plants. Thus, our plan to formulate a team approach to resolve procedure structure and content for the organization was reconsidered as the method for resolving our particular circumstance.
Instead, the original team was re-assembled to develop a high-level policy on procedural adherence and introduce it at the same time the above-described revised procedure change process is advanced for use within the station. Key departments are now tracking procedure non-compliances by individuals who have demonstrated repetitive compliance issues. Human performance will be trended and accountability assessed as is best suited for each department.
Also, in lieu of a large scale procedural review and revision effort, it was decided to take advantage of other procedure review and upgrade efforts that were occurring or were planned to take place as part of other planned activities associated with organization enhancements.
For example, procedure upgrades are in progress on a number of non-administrative procedures with identified format and technical errors. These include radwaste operations, operations abnormal procedures, I&C surveillance procedures, and fire protection surveillance procedures. Another opportunity for procedure review and upgrade will occur during the Design Basis Recovery (DBR) project.
In addition, as part of ongoing re-organizational efforts, five multi-disciplinary teams have been assembled to look at key PNPS processes. These processes are: Operations, Maintenance, Nuclear Services, Nuclear Assessment, and Materials. The current charter of these teams is to develop new processes and enhance existing processes for use in managing their functional responsibilities. During this process re-design effort, the adequacy of the applicable administrative procedures governing these key processes will be reviewed.
Procedures will be modified following process mapping, and the new processes implemented once training is complete. The Plant Design Change (PDC) Process and the Station Work Control Process have already been analyzed according to this format.
We have begun to see improving trends in this area of performance. We attribute this to the multitude ofimprovement initiatives we have undertaken to assess and correct this problem as opposed to singling out the effectiveness of any one particular action. Procedural adherence status and trend as well as identified procedural inadequacies are featured in the monthly Corrective Action Program (CAP) Health Index. Procedural adherence will continue to remain a feature of this report until it is no longer necessary.
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4 The management team at Pilgrim is actively monitoring and overseeing the effectiveness of corrective actions established to resolve procedure adherence. We are handling the corrective actions in a dynamic fashion, and thus, changes in implementation method have occurred and will continue to occur as determined appropriate. Changes we view as significant, such as described above, will continue to be highlighted and shared with your office. Should you desire further information or status relative to our activities associated with this issue, please j
do not hesitate to contact me or any member of my staff.
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Regional Administrator, Region 1 Mr. Alan B. Wang U.S. Nuclear Regulatory Commission Project Manager Project Directorate 1-3 475 Allendale Road Office of Nuclear Reactor Regulation King of Prussia, PA 19406 Mail Stop: OWFN 1482 U.S. Nuclear Regulatory Commission i White Flint North Senior Resident Inspector 11555 Rockville Pike Pilgrim Nuclear Power Station Rockville,MD 20852 l
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