ML20237E713
| ML20237E713 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/26/1998 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BYRON-98-0244, BYRON-98-244, NUDOCS 9809010125 | |
| Download: ML20237E713 (8) | |
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Commonwealth I'dison Compan)
II)ron Generating $tation i150 North German Church Road e
11)ron !!.61010-979 i Tel Hl5 23 4 5 4 al August 26,,1998 LTR:
BYRON 98-0244 FILE:
1.10.0101 US Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk
SUBJECT:
Byron Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Numbers: STN 50-454 and STN 50-455 Response to July 13,1998 Systematic Assessment of Licensee Performance (SALP) 14 for Byron Station j
This letter provides the Byron Station response to the NRC Region Ill SALP 14 report dated July 13,1998. We have carefully reviewed the SALP 14 report. We were pleased to receive recognition of the improvements in performance that have occurred over the past year and a half. We are disappointed that our performance was not at a higher level.
We are committed to take the actions necessary to achieve further improvements. The intent of this letter is to provide a summary of the actions we are taking to address the weaknesses noted in the SALP 14 report.
Note that some of these actions may be restatements of commitments to the NRC that were made in other docketed correspondence.
OPERATIONS We agree with the need to continue to improve our adherence to procedural requirements, interdepartmental communication and coordination of plant activities, and implementation of the Out-of-Service (OOS) process to strengthen our day-to-day l
operations. Steps we have taken and continue to take are as follows.
Operations management will continue to implement the successful practice of procedure
()o place keeping and improving procedures to improve human factoring.
Operations management will re-emphasize procedure compliance associated with Operations Department Standards. There were some events identified in the SALP 14 report where coordination of work activities was weak during the refueling outages.
C 9809010125 980826 PDR ADOCK 05000454 h
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Byron Ltr: 98-0244 j
August 26,1998 Page 2 Operations management and personnel recognize the leadership role in ensuring excellent plant operations through effective interdepartmental communications and coordination of activities. Operations have assigned licensed individuals to support on-line maintenance activities. Additionally, responsibility for daily prioritization of work during refueling outages is performed by the Operations Outage Manager in the Outage Control Center.
Byron Station utilizes a weekly Performance Analysis Review (PAR) meeting where Senior Site Management meets to review the results of plant activities associated with the prior weeks' work schedule.
As stated in the SALP 14 report, Byron Station's overall performance in the OOS process i
during the SALP period was strong until late in the assessment period. Operations i
identified through the performance indicator programs, the start of a negative trend. The Station took several steps to identify and correct process weaknesses at that time which reversed the trend. In early 1998, the performance indicator program identified a second negative trend that indicated additional corrective actions were necessary. The most clear common cause identified by the new tiend was human performance weaknesses, specifically the accountability of personnel.
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A recovery plan is being developed which includes implementation of the OOS Nuclear Station Work Procedure (NSWP) A-22, " Comed Out Of Service Process," which greatly simplifies the process and includes good practices from each of the Commonwealth Edison (Comed) Company nuclear sites. The plan also includes improved training for both implementation ofindividual plan components and improved long-term training.
Station management has recognized that the greatest contributor to the OOS problems continues to be human performance errors; however, several steps have already been taken to improve the process to lessen the likelihood of human error. One example of process improvements was the human factoring of the OOS action checklist that was implemented on July 12,1998. The changes which were developed with feedback from the end users, greatly reduce the likelihood of OOS card confusion and separate DOS card HANG and LIFT activities onto separate sides of the page. Byron Station was a key contributor in development of this change that is expected to result in decreased human errors. Operations management began scheduling time with the Operators during their i
routine training, which has already indicated positive response.
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Byron Ltr: 98-0244 August 26,1998 Page 3 In July 1998, another action that Operations management has taken to improve the human performance in the OOS process was the implementation of a simple OOS Preparation and Pre-Job Brief checklist. The checklist provides a quick reminder of key elements from the OOS procedure, and summarizes the key items of a good OOS pre-job brief.
Other Comed sites have proven the checklist successful, and it should begin to provide i
positive returns, as its use becomes routine at the Byron Station. Operations management has implemented additional interim actions which includes performance of equipment line-ups during return to service activities when equipment was manipulated within the l
OOS boundaries.
l Maintenance has expanded the use of" Maintenance Alterations Forms" for necessary manipulations within an OOS boundary and has significantly heightened the awareness of OOS compliance by maintenance personnel to ensure resolution to Maintenance OOS errors. OOS errors by maintenance / contractor personnel include the failure to properly j
walk-down OOS boundaries and have resulted in the performance of work on systems j
outside the actual boundary and on systems that were not entirely isolated (e.g., leaky L
valves, etc.).
Formal training is scheduled for all Maintenance personnel involved with l
the OOS process and will be completed by the beginning of October 1998. It has been l
stressed that each individual is accountable for their actions to reduce configuration l
control problems.
I MAINTENANCE We recognize that in order to continue to be effective in providing high equipment i
availability and reliability, further improvement is needed in procedural adequacy, work I
l' package improvement, corrective action effectiveness, and reduction of rework. Steps j
that we are taking include the following.
To ensure that there is effective and meaningful improvement in the credibility, usability, and. understanding of our procedures, maintenance craft is being used to help rewrite, change and validate maintenance procedures.
A clear and. concise guideline on constructing a work package that is free of non-value added information and that has clear and concise instructions for the workers have been implemented. This guideline was developed using worker feedback to ensure that worker concerns are addressed. In addition, pre-job briefs have been standardized among the Maintenance shops and revised to include previous lessons learned and potential human error pitfalls associated with the job.
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Byron Ltr: 98-0244 August 26,1998 Page 4 The Maintenance Department groups' corrective actions are being reviewed using the self-assessment process. There are three levels of self-assessment that are conducted and are as follows.
Focus area self-assessment: an in-depth review of a specific area selected by Maintenance.managemem to improve. Maintenance personnel have completed a review of the Foreign Material Exclusion (FME) program, are currently reviewing pre-job briefings, and are planning a review of the five-week work process.
Quarterly self-assessment: an individual Department selected area that needs improvement or follow-up action.
Site review: overall review of corrective actions implemented to assess their effectiveness.
Rework is currently not within the acceptance criteria of < 4% for the three month average and is being addressed by a comprehensive plan of action including specific I
milestones.
FME controls have been markedly improved using a comprehensive action plan, mock-up training, an intense awareness campaign, and field observations, all of which were overseen by a committee of subject-matter-experts. The committee remains in effect to ensure continuing compliance with FME procedures and techniques, and that sustained improvement is evident.
ENGINEERING We agree that for us to maintain excellent material condition of the plant as evidenced by the availability of safety-related equipment and plant reliability, we must address concerns relative to 10CFR50.59 safety evaluations, modification testing, and modification closure. Steps we have taken include the following.
A new modification procedure has enhanced guidance for products from the Design Engineering Department to convey testing requirements to the System Engineering Department. There is an expectation that Design Change Packages will be closed within 30 days. We are also tracking the progress of open modifications at the weekly l
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Byron Ltr: 98-0244 August 26,1998 Page 5 engineering plarming meeting. The revised modification procedure also allows for corrective minor modifications. This will allow faster response to design changes that do not meet the modification test acceptance criteria. Design changes are reviewed for
' testing' status at the weekly engineering planning meeting.
Nuclear Site Procedure (NSP)-AP-3009, "Self-Assessment Program," provides detailed instructions for performing structured self-assessments. This procedure has been implemented and some self-assessments have been completed in accordance with the procedural requirements.
Early in October 1996, while performing a surveillance on the essential service water cooling tower, it was determined that an excessive amount of silt had deposited in the tower basin. While efforts immediately commenced to make plans to remove this silt, further investigation of documentation on the tower revealed a number of discrepancies.
An investigation team, was established, to identify the root cause of the event and to provide corrective actions as appropriate.
PLANT SUPPORT We agree that weaknesses remain in radiation protection performance, emergency preparedness, Chemistry Department communications, Security personnel performance, and control of transient combustibles. We are taking the following steps to address these issues.
Radiation Protection:
The Byron Station SALP 14 report identified two areas of concern in the Radiation Protection (RP) area.
Problems associated with radiation worker practices.
Problems associated with radiological postings.
The following actions were taken with respect to the radiation worker concerns.
Awareness sessions clearly identifying expectations and proper worker practices have been developed for presentation at station department meetings and
" tailgate" meetings.
Informational boards are posted in high traffic areas which contain information on RP related issues.
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Byron Ltr: 98-0244 August 26,1998
,,Page 6.
Articles on current RP related issues are included in the station publication
" Focus."
Pre-Outage Awareness sessions are held which include a review of current and previous concerns.
Greeters are available to identify deficiencies prior to entry into the Radiological Protected Area (RPA) and the Containment Building during outages. They have been briefed on the heightened level of awareness for radiation worker practices.
Additional RP Technicians are available at the RPA entrance to monitor ingress and egress of personnel and equipment during non-outage periods.
Byron Letter 98-0143, " Rad Worker Practice Improvements," was issued May 22, 1998, by the Station Manager discussing management expectations and addressing worker accountability.
The following actions were taken to address radiological posting concems.
Expectations for proper radiological postings were discussed with RP Technicians and first line supervision as defined in Byron Radiation Protection procedure (BRP) 5010-1, " Radiological Posting and Labeling Requirements," during a "Line Management Expectations" presentation.
Radiation Protection Department Policy 0006D, "RPLS [ Radiation Protection Line Supervision] Plant Walkdown and Quality Control Assessment of the RPA "
provides for additional checks by first line supervision to ensure areas are properly posted and controlled. The performance frequency of the espection was increased to once per week.
Emergency Preparedness During the 1997 biennial emergency preparedness exercise two weaknesses were identified: an event was misclassified during the exercise, and a procedure and checklist were not used. Actions taken include the following.
Exercise weaknesses have been reviewed with Operations personnel, and Proper event classification and procedure use was stressed during simulator training.
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j Byron Ltr: 98-0244 l
August 26,' 1998 L
Page 7 L
l Chemistry Actions are underway to address the engineered safety feature actuation that occurred during the cavity flood up due to increased area radiation during the recent refueling l
. outage. as well as the Chemistry and Operations Departments communication.
Completion of procedure revisions for Chemistry and Operations Departments will be made that specify the reactor coolant system activity prior to cavity flood up, and identify the necessary letdown flow needed to obtain acceptable system clean up.
These procedural revisions will assure that both departments communicate using the same terms with the same understanding.
Security l
During the SALP period, failure to properly handle safeguards information was l.
~ identified. Byron Station has taken the following actions.
Awareness of station personnel was raised on how to properly handle safeguards information.
Security contractor (i.e., Burns) personnel conducted interviews with the people that normally handle safeguards information and found no weaknesses in their knowledge / understanding of how the program works.
The Corporate Security organization has concurred with these actions taken at the station.
i There have been some weaknesses identified in the testing of some of the Security' Program access control equipment / programs. The equipment / programs that were not
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l being tested have been added to the applicable Security procedures and applicable
- training has been completed.
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_ Security management is raising the level of awareness regarding the implementation of l
the Fitness for Duty Program by conducting " tailgate" meetings with site personnel.
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Byron Ltr: 98-0244 August 26,1998 Page,8 i
Fire Protection In order' to maintain better control over transient combustibles, Byron Station management has re-written transient combustible procedures to simplify and clarify l
requirements and remove ambiguity. Byron Station conducted a literal compliance l
assessment comparing all fire protection related administrative procedures to applicable provisions of 10CFR50, Appendix R. Following Byron Station Unit 2 Refueling Outage l
Cycle 7, a comprehensive cleanup was begun to effect a one-time step change reduction in long-term storage of combustible materials in areas important to safety. This included minimizing combustible storage lockers and their contents and removal of any remaining wood ~ carts and scaffold.
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Actions taken during the 1997-1998 winter season were successful in alleviating possible freezing of fire protection equipment.
' In summary, I am committed to provide the leadership to assure that Byron Station meets j
the highest of standards. Our team will continue to broaden our view of meeting excellence in site activities 1
Should you have any questions or require further information, please contact Brad Adams, Byron Station Regulatory Assurance Manager at (815) 234-5441, extension i
2280.
l Sincerely, l
K. L. Graesser
- Site Vice President
. Byron Nuclear Power Station KLG/RC/rp cc:
NRC Regional Administrator, Region III NRC Senior Resident Inspector, Byron Station NRR Project Manager, Byron Station Office of Nuclear Facility Safety, IDNS
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