ML20236Y465
| ML20236Y465 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/04/1998 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-98-99, WM-98-0067, WM-98-67, NUDOCS 9808120220 | |
| Download: ML20236Y465 (7) | |
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W$LF CREEK NUCLEAR OPERATING CORPORATION Otto L. Maynard President and Chief Executrve Officer AUG 0 41338 WM 98-0067 U. S. Nuclear Regulatory Commission ATTN:
Docuraent Control Desk Mail Station P1-137 Washington, D.
C.
20555
Subject:
Docket No. 50-482:
Response to Systematic Assessment of Licensee Performance (SALP) - NRC Inspection Report 50-482/98-99 The attachlaent to this letter summarizes the issues discussed at the Systematic Assessment of Licensee Performance (SALP) public meeting held at the Wolf Creek Nuclear Operating Corporation's (WCNOC) Dwight D.
Eisenhower Learning Center on June 17, 1998.
WCNOC concurs with your finding that licensee activities are good in all functional areas.
WCNOC agrees with the NRC staff's conclusion that overall performance improved in several functional areas during the SALP period.
WCNOC is fully committed to continuous improvement to achieve superior levels of performance.
In reviewing the SALP report and reflecting on our progress during this last SALP period, WCNOC is confident that our priorities are focused in the right direction.
Our top three priorities continue to be improving: 1) our corrective action program, 2) human performance, and 3) design and licensing basis assurance and fidelity.
As discussed at the June 17, SALP meeting, correction of identified problems through development and implementation of in-depth and effective correction actions is the cornerstone to WCNOC's future success and our number one priority.
WCNOC looks forward to sharing our progress and perhaps providing a broader perspective on plant activities and condition during management meetings with the NRC staff.
If you have any questions or desire additional information regarding this response, please contact me at (316) 364-8831, ext. 4000 or Michael J. Angus, ext. 4077 Very truly yours,
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Otto L. Naynard OLM/rir I
' Attachment
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cc:
W.
D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a B. A.
Smalldridge (NRC), w/a K. M. Thomas (NRC), w/a Y
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980812O220 980804 PDR ADOCK 05000482 p
$j-7n P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 An Equal Opportunity Ernployer MFMC/ VET
Attachment to WM 98 vu67 Page 1 of 6 I.
SALP Functional Area: Plant Operations The SALP Board assigned a Category 2 rating to the SALP Functional Area of Operations noting performance was good.
Mr. Chris Younie, Manager Operations responded to the SALP Report and to comments made during the SALP Meeting regarding performance in the Operations area.
His comments are summarized below.
The challenges in the Operations area are:
Establishment and maintenance of high performance standards The focus will be on communication and reinforcement of Operation's standards through opportunities at each shift turnover, during training activities, and through performance of crew observations.
Continual improvement of procedures and surveillance Emphasis in this area started in 1996 with a letter from our Chief Operating Officer, outlining the expectations for programmatic and procedural compliance.
In support of these expectations, when a procedure is not correct, personnel must stop, place the plant in a safe condition, and correct the procedural deficiency.
This practice, along with a " literal read" of procedures and Technical Specifications, has contributed to WCNOC self-identifying literal compliance issues.
Continual improvement of corrective action standards The Operations Department has not reached its goal for successful reviews by the Corrective Action Review Board (CARB).
- However, improvement is being made by critical review of our product and implementation of the lessons learned from CARB feedback.
To help with this effort, Operations will be using the trending function of our corrective action process.
This includes assigning cause codes on Performance Improvement Requests and monitoring performance trends, through use of a data base that provides an indication of areas where improvement is needed.
Mr.
Younie concluded his statements by restating that he believes success in Operations will be achieved through clear communication, reinforcement of our expectations and continual improvement of our standards.
II.
SALP Functional Area: Maintenance The SALP Board assigned a Category 2 rating to the area of Maintenance.
Performance in this functional area continued to be good.
Mr.
David Knox, Maintenance Manager, responded to the SALP report.
The challenges in the Maintenance area are:
- Consistent high levels of procedural compliance The expectations regarding procedural compliance have been reinforced with the maintenance staff.
Reinforcement of expectations should be timely and repeated, day after day.
Procedural compliance will be reinforced by supervisors spending more time in the field with the craft personnel.
The effectiveness of the additional time in the l
u -_ _ --_-____.
Attachment to WM 98-0067 Page 2 of 6 field is being monitored through performance indicators that are showing an improving trend.
Additional training has been provided to further reduce human errors through introduction of Qualify, Verify, and Validate (OV&V) skills.
Maintenance has also provided traini g to reinforce three-way communication and Stop, Think, Act, and Review (STAR) principles.
The Management Associated Results Company (MARC) process is being used to reinforce accountability on issues dealing with procedural adherence.
Improve the quality of surveillance and procedures Many of the surveillance issues during the SALP cycle were self-identified through critical self-evaluation and a literal compliance philosophy.
Initiatives, including surveillance procedure reviews and the Generic Letter 96-01,
" Testing of Safety Related Logic Circuits" research, were successful in identifying surveillance which were not meeting Technical Specification requirements.
Further improve work management and work practices To improve work management, the fragnet concept is being used for work planning and includes areas such as ALARA and safety.
The focus will be on improving work package quality prior to the worker going out in the field, and on critiquing work performance after the work is done.
To ensure that personnel know how they are doing in relation to expectations, performance indicators are posted in the maintenance shop.
The indicators are reviewed during weekly staff meetings, monthly by WCNOC management and every four months with craft personnel.
It is important that personnel know what the performance indicators mean and where we ere in relation to our goals.
- Finally, Mr.
Knox discussed completing the transfer of the planning function to the craft personnel.
This has proven to be a good learning process for both the planners and the craft personnel, and has increased the interaction between the groups.
Planners and cruft now have increased understanding of their roles, and are wor..ing together to be successful.
III.
SALP Functional Area:
Engineering The SALP Board assigned a Category 2 rating to the area of Engineering.
Performance in this area was good.
Mr.
Ron Sims, Manager System Engineering and Ms. Donna Jacobs, Manager Support Engineering responded for WCNOC Engineering.
WCNOC Engineering is focused on improving in two areas:
consistently providing high quality routine engineering products and providing a consistent, high level of support to the Operations and Maintenance organizations.
Many of the Engineering initiatives underway will help improve performance in both challenge areas.
These initiatives are summarized below:
l Calculation Review Group The need for this group was self-identified as a result of the system functional assessments WCNOC performed on the Auxiliary Feedwater System (AFW) and Essential Service Water System (ESW).
The Calculation Review Group plan was completed by the targeted date of E___-._
Attachment to WM 98-0067 Page 3 of 6 i
1 May 1, 1998, and by June 30, 1998, a Calculation Standards Monitoring Team was established.
I The team is working to revise the calculation procedure to enhance l
the programmatic controls governing calculations.
The enhancements will include an expedient method for making minor changes to calculations and/or indicating apparent calculation discrepancies with pending corrective action, with provisions for managing the potential cumulative impact-of multiple small changes.
Subsequent to the procedure revision, the team will provide training for all engineers qualified to perform calculations on the procedural enhancements.
Engineering Information System (EIS)
To improve understanding, use and maintenance of the design basis, development of virtual electronic design basis documents is underway.
The following EIS activities have been completed to date:
development of the specification for EIS, training of personnel on the basic system, and loading of the core EIS software.
The project is on target, and the pilot Auxiliary Feedwater System information should be loaded this year.
- Work Product Evaluation (WPE)
Engineering is continuing with the WPE process as a mechanism to set and reinforce expectations for engineering work products.
- Recently, an independent review by the Nuclear Safety Review Committee (NSRC) was completed.
The NSRC confirmed that the process has improved the quality of engineering products over time.
The review also showed that due to the wide variety of documents, it is difficult to benefit from any type of trending using the scoring process.
Further improvement of the WPE process is underway.
Lessons learned from a Human Performance training course recently attended by WCNOC engineers will be included in the process.
This training, provided in April 1998 to all engineering personnel, was a corrective action to a common cause review that identified improvements needed in document accuracy and independent reviews.
Work Management Engineering continues to work to improve work management through use of the Project View scheduling tool.
Currently, engineering workload exceeds available resources.
Supplemental resources are being used to address the backlog, but engineering is also working aggressively to prioritize and reschedule work.
Engineering is accomplishing this is through joint prioritization meetings with Operations, Maintenance, and other groups that need products from Engineering.
An initial set of meetings was held in April 1998, and additional meetings are planned to ensure that workload leveling includes input from other departments.
Engineering Assessment Requests (EARS)
Engineering Assessment Requests (EARS) are providing good feedback to engineering management.
The feedback is generally positive, but operations personnel are not hesitant to point out areas for improvement when their expectations are not met.
One area that has shown need for improvement is documentation.
This has caused Engineering and Operations to look at how we address Generic Letter L
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Attachment to WM 98-0067 Page 4 of 6 91-18,
" Resolution of Degraded and Nonconforming Conditions,"
operability issues.
We are reviewing our procedures and considering enhancements that will improve documentation in this area.
System Health Reports The use of system health reports is well underway.
They are used to communicate issues to the work control organization.
The reports also help the plant focus on common objectives, and to address problems proactively before they become operability or reliability concerns.
Support of Plant Activities Engineering has found a rotating, but dedicated, Work Week Engineer to be effective in interfacing with plant departments.
This engineer addresses both scheduled and unscheduled work requiring engineering involvement.
Additionally, the assigned Work Week Engineer has been supplemented with a dedicated scheduler ensuring that we have a consistent interface for scheduled work.
The Night Shift Engineering program has also been successful.
It has not only improved response time, but has also significantly reduced the need to call in personnel to address urgent operational needs.
Engineering has designated a single point of contact for outage related issues to ensure concerns requiring engineering involvement are being addressed in our outage preparation.
Ms.
Donna Jacobs, Manager Support Engineering, provided comments regarding development and improvements made in the component and predictive maintenance groups.
The component group's vision is to implement use of design reviews, inspections,
- testing, trending and hardware failure analysis, and industry operating practices (OE) to ensure reliable equipment operation and availability.
Personnel have visited the Institute of Nuclear Power Operators (INPO) and plan to complete benchmarking with other utilities.
A process map for interfaces with other groups will then be developed.
A component trending program and database and an improved hardware failure analysis process are under development.
IV.
SALP Functional Area:
Plant Support The SALP Board assigned a Category 2 rating to the area of Plant Support.
Performance in this area remained good.
Ms.
Marcy Blow, Manager Chemistry and Health Physics and Mr.
John Johnson, Manager Resource Protection, responded to the SALP report in the area of Plant Support.
Radiation Protection The challenges fcr WCNOC's radiation protection program are:
Consistent program implementation To evaluated and correct program implementation issues recent radiation protection events were looked from a global perspective.
The common cause was determined to be human performance errors caused primarily from inadequate procedure knowledge and poor judgment errors.
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Attachment to WM 98-0067 Page 5 of 6 The procedures used by the technicians are primarily reference use, and are not carried out into the field with the technicians.
Therefore, the technicians were given an extensive closed book examination.
As a result of that examination, the Health Physics continuing training program is being modified to reinforce procedural understanding.
To address judgment errors and as an interim measure for the procedure knowledge issue, a full time field coach position was implemented.
The field coach is a first line supervisor who observes technician performance in the field.
He provides real time mentoring, correcting, and coaching to our standards.
To further provide expectations, we are developing written standards for Health Physics technicians and radiation workers.
Additionally, the HP group meets with the supervisors and Manager each morning to communicate and review error reduction techniques.
Reduction of person-rem exposure To reduce personnel exposure we have started by accepting the effects of the Axial Offset Anomaly as a challenge, not an excuse.
Health Physics develops exposure estimates for each job in the Radiologically Controlled Area (RCA).
The estimates are provided to the work groups at least two weeks in advance of the job.
Actual exposure performance is then tracked against the estimated exposure to communicate cur goals with plant personnel.
Each department now has an exposure performance indicator.
The ALARA committee was reorganized with new members.
The Manager Maintenance is now the co-chairman.
WCNOC is being self critical of the entire ALARA program and looking for oppor+ unities to improve.
Balance of Plant Support Mr.
Johnson har the following groups reporting to him as Manager Resource Protection:
- Security, Safety, Environmental Management, Emergency Planning and Fire Protection.
Mr.
Johnson addressed SALP issues in the areas of Emergency Planning, Fire Protection and Housekeeping.
Emergency Planning WCNOC is continuing to improve the overall performance of the Emergency Planing organization.
A key factor in this improvement is a planned increase in the Emergency Planning training time scheduled for the entire Emergency Response Organization.
In 1997, there were approximately 6 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of Emergency Planning training.
In comparison, approximately 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> per position is scheduled during 1998.
This schedule includes both comprehensive exercises and table top drills.
Fire Protection The challenge for Fire Protection is to ensure program requirements are appropriately recognized, evaluated and responded to in all
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cases.
The overall Fire Protection Program will be further enhanced by the completion of a self assessment currently underway that will evaluate the Fire Protection organization, structure and program ownership.
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Attachment.to WM 98-0067 l
P,, age 6 of 6 e
Plant Cleanliness In response to plant housekeeping issues, WCNOC considers cleanliness and in particular, Containment cleanliness as a high priority. WCNOC increased its efforts in this area and improved cleanliness was noted by an NRC Inspector.
This increased attention to housekeeping will continue as a priority, not only for Containment, but for the rest of the plant as well.
As indicated during responses for other areas, WCNOC agrees that there were improvements and successes in the area of Plant Support.
There are also opportunities for further improvement.
With continued clear communications and reinforcement of expectations the Plant Support organization and WCNOC will continue to improve.
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