ML20244A485
| ML20244A485 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/06/1989 |
| From: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-CR-5228 IEB-88-007, IEB-88-7, NUDOCS 8904180010 | |
| Download: ML20244A485 (23) | |
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PHILADELPHIA ELECTRIC COMPANY 9h PEACil BCilTOM ATOMIC POWER STATION "Nw 50#
Delta wnns'yI[n[a 17314 10 CFR 2.201 PEACH IKHTOM-THE POWER OF EXCELLENCE (717) 456-7014 D. M. Smith Vice President April 6, 1989 Docket Nos. 50-277 50-278 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Peach. Bottom Atomic Power Station Response to s Inspection Report Nos. 50-277/89-81'and 50-278/89-81
REFERENCE:
(1) March 6, 1989 Letter from W. F. Kane (NRC Region I) to C. A. McNeill (PECo)
(2) March 7, 1989 Letter from J. W. Gallagher (PECo) to NRC
Dear Sir:
This is in response to reference 1 letter which transmitted Peach Bottom Inspection Report Nos. 50-277/89-81 and 50-278/89-81. The inspection report stated that within the scope of the Integrated Assessment Team Inspection (IATI). review, "the team concluded with high confidence that Philadelphia Electric Company (PECo) management controls, programs, and personnel are performing at a level to support safe startup and operation of the facility... As a result of this inspection, the team concluded that there are currently no fundamental flaws in PECo's management structure, management performance, programs, or program implementation that would inhibit its ability to assure reactor or public safety during plant operation."
In addition, the inspection team identified a relatively small number of items I
for which additional actions or evaluations are needed.
Commitments made by PECo regarding these items were confirmed during the exit interview. The purpose of this j
response is to provide a status for these commitments as they are detailed in section 1
2.4 of the inspection report.
Each corrective or enhancement action is restated below, followed by a summary of its current status.
2.4.1 Prior to restart ensure new system operating (S0) procedures that are important to safe operation are implemented prior to startup or system operations.
(Section3.1.6) 8904180010 890406
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Document Control Desk April 6, 1989 Page 2 Status After the USNRC shutdown order was issued, Philadelphia Electric Company conducted a review of the System (S) Procedures. This review concluded that the S Procedures were adequate for use from a technical point of view and as a long term project, the S Procedures would 1x3 enhanced to incorporate more detail and to include human factors concepts. The long term procedure rewrite task was initiated and substantial progress has been made in developing the System Operating (S0) Procedures which will replace the existing S Procedures.
In the short term, concurrent with the procedure rewrite task, we initiated strengthened programs to enhance utilization of the S Procedures. Philadelphia Electric Company raised its standards for procedure compliance and improved the process for making temporary I
procedure changes.
In addition, Philadelphia Electric Company initiated a procedure suggestion program aimed at improving the level of detail and technical content of the existing S Procedures through recommendations from the Operators.
Furthermore, under the program for periodic review of existing procedures, many of the S Procedures were upgraded with respect to technical content and human factors during the review and revision process.
During the IATI, the NRC reviewed the product of these efforts on HPCI and RCIC procedures and found the S Procedures to be acceptable. The S l
Procedures were used extensively during simulator training. The acceptability of many of the S Procedures has been physically demonstrated as both safety related and balance of plant systems have been returned to service in support of evolutions conducted in preparation for restart of Unit 2.
During the IATI, the NRC requested that the new System Operating (S0)
Procedures be issued for safety related systems and for systems which directly impact safe operation of reactor systems prior to startup or, if after startup, prior to conducting the evolution for which the 50 Procedure is written. We have reviewed the list of S0 Procedures for 20 such systems with the USNRC Senior Resident Inspector at Peach Bottom and have agreed upon the list of S0 Procedures which meet the above criteria.
S0 Procedures for 18 of the 20 systems have been issued for use.
The S0 Procedures for the remaining 2 systems are expected to be approved by PORC by April 7, 1989, and will be distributed for use prior to restart.
2.4.2 Prior to restart provide your plans and schedule for improving the l
permit and blocking rules.
(Section3.1.7)
Status i
The primary purpose of the Permits & Blocking System is to provide for personnel and equipment safety.
Reduction in administrative burden and
t y
Document Control Desk tApril 6, 1989 Page 3 a
efficiency of the process are secondary considerations. The following actions which have been and;are being taken by Philadelphia Electric at Peach Bottom consider both the. primary and secondary concerns. The action plan and status of each action are as follows:
1.
Review and revise Administrative Procedure A-41 to require independent review of.the blocking sequence for permits which involve designated circuits in safety related equipment. These designated circuits are lifted leads, jumpers, boots, and control circuits. Also, review and revise Administrative Procedure A-41 to define more clearly the scope and content of the review which is required prior to release for the application of permits-and the reapplication of temporarily cleared permits.
These actions have been accomplished.
2.
Develop and issue administrative controls for the development, review, and approval of pre-approved blocking sequences.
Pre-approved blocking sequences are controlled documents which describe the method for isolating specific pieces of equipment for safety purposes..The intent of these pre-approved blocking sequences is to reduce the time and administrative burden required for an operator to create a permit and to obtain the necessary reviews and approval each time the equipment is blocked.
The administrative controls for this process were developed and issued on October 14, 1988.
3.
Develop and issue a set of standard methods for blocking Peach Bottom components for use by those writing current permits and those writing pre-approved blocking sequences. This action was accomplished for those writing pre-approved blocking sequences on October 14, 1988, and was accomplished for those writing current
)
permits on January, 10, 1989.
4.
Restrict the temporary clearances to one temporary clearance per l
permit except when specifically authorized.
This action was taken on September 23, 1988.
5.
Develop detailed guidance for administrative and recordkeeping provisions to be used in the Control Room for the Permit &
Blocking process.
This action was accomplished in January, 1989.
I 6.
Establish a task force to study potential improvements to the Philadelphia Electric Company Permits & Blocking process and to determine the root cause for the difficulties being experienced with the process. These actions were accomplished by the I
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Document Control _ Desk April 6, 1989 Page 4-t establishment of a task force which met for the first time on May 31, 1988, and by the issuance of a report on December. 12, 1988 which describes root causes for problems being experienced with the Permits & Blocking Program..
7.
Develop the necessary improvements in the Permits &' Blocking process. A committee, chaired by the Superintendent-0perations of-Limerick Generating Station, has been formed and includes representation from Peach Bottom. The plans and schedule for this..
committee are as follows:
April, 1989 Dev'elopment of methodology fdr evaluating
. permits and blocking systems.
May, 1989 Visit pilot plant, revise criteria as required.
May-July, 1989 Application of evaluation methodology to non-PECo permit and blocking systems during visits to plant sites recommended by INP0.
August, 1989 Collation of the results of.the evaluations (Visit. Summary Reports).
August, 1989 Preparation of a proposed model ofLa permits.
and blocking system based on the best features observed during the plant site visits.
September, 1989 Comparison of the model to the Philadelphia Electric Permits and Blocking system in order to develop requirements for a system upgrade.
September, 1989 Develop implementation plan.
October, 1989 Production of a final report with
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recommendations including a plan and schedule for implementation.
2.4.3 Prior to restart complete response to LaSalle BWR Power Oscillations NRC Bulletin 88-07.
(Section3.2.7)
Status Philadelphia Electric Company submitted a response to NRC Bulletin 88-07, Supplement 1: " Power Oscillations in Boiling Water Reactors (BWRs)"
for both the Peach Bottom Atomic Power Station and Limerick Generating Station on March 7, 1989. The response stated for PBAPS that changes to the principal procedures affected by the GE recommendations presented in the Bulletin were completed by February 3, 1989. The letter also stated that a review of additional pertinent procedures was continuing and that any required changes would be completed prior to
Document Control Desk April 6, 1989 Page 5 restart of PBAPS Unit 2.
The subject review,.which focused on Operational Transient (OT), Off-Normal (0N), and specific General Plant
_(GP) procedures, concluded that 6 OT, 2 ON, and 2 GP procedures required revision.
The procedure revisions were completed on March 30, 1989. The operating shifts are scheduled to complete training on the appropriate procedure revisions by April 12, 1989.
2.4.4 By May 31, 1989 provide schedule for development and implementation of Revision 4 of the Emergency Procedure Guidelines.
(Section 3.2.9)
Status Peach Bottom Atomic Power Station personnel are currently reviewing NUREG/CR 5228, " Techniques for Preparing Flowchart-Format Emergency Operating Procedures (E0Ps)," and are planning to participate in the NRC workshop on E0Ps which is scheduled for May, 1989. Our schedule
'for development and implementation of revision 4 of the E0Ps will be submitted to the NRC by May 31, 1989.
2.4.5 Beginning in July 1989 and continuing for two years, provide semi-annual human resource status reports on progress towards meeting operator resource development and cultural related commitments.
o Career paths and off-shift rotational assignments for operations staff.
(Section 3.2.3 and 3.3.4.2) o More comprehensive operations newsletter which would include explanations for decisions on policies and programs that affect operations staff, status on resolving issues, concerns, recommendations, and other pertinent information.
(Section 3.3.3) o Improvement on quality and timeliness of communications and feedback loops.
(Section 3.3.3) o Improving consistency between shift crews in implementation of policies.
(Section 3.3.4.1) o Increasing the number of licensed operators towards the goals of 42 on shift and 85 total licensed experienced personnel.
(Section 3.2.3) o Implementing interaction training for licensed operators and non-licensed personnel.
(Section 3.3.2) o Incorporation of parts of PFE/PE training into operator progression training.
(Section3.3.2) h_
Document Control Desk April 6, 1989-Page 6 I
Status Peach Bottom Atomic Power Station will submit the first semi-annual human resource-status report covering the above list of operator resource development and cultural related commitments in July, 1989.
2.4.6 Prior to restart provide to the NRC a revised commitment regarding the schedule for implementation of follow-up Interaction Training for licensed operators and non-licensed personnel and for. incorporation of.
l parts of PFE/PE training into licensed operator progression training.
1 i
(Section 3.3.2) l Status The Interaction Management Support training program for station middle management _ commenced in February, 1989. The Interaction Management training program for the SR0 licensed operators will begin in April, 1989. The Interaction training program for non-supervisory operators (R0s, NL0s) will begin.in July, 1989. The Interaction training program for non-supervisory personnel outside the operations chain is scheduled to begin in the third quarter of 1989.
1 The effort to incorporate elements of PFE and MFE training into licensed operator training has begun. The analyses to determine the knowledge and interpersonal skills needed at each level of progression is currently being performed.
Elements of PFE and MFE training will be incorporated into licensed operator progression training during the third quarter of 1989.
Implementation of progression training with the appropriate PFE/PE curriculum elements is scheduled to be phased in during the first quarter of 1990.
2.4.7 Prior to restart provide to the appropriate HP technicians orientation and training in the area of Peach Bottom power operations experience and radiological expectations.
(Section 3.5.2)
Status PBAPS has developed and is currently implementing a training program designed to provide Health Physics technicians with a summary of the expected plant changes during start-up and subsequent power operations.
The Health Physics technicians who do not have prior operating plant experience completed the training on March 31, 1989. Some technicians with previous operating plant experience, who are currently attending other training or are on conflicting shifts, will complete the training i
during the second quarter of 1989.
2.4.8 Prior to restart review torque switch settings for Limitorque motor operated valves settings below the vendor recommended values.
(Section 3.6.2.8) l
Document Control Desk April 6, 1989 Page 7 Status In response to the NRC I.E.Bulletin 85-03, PBAPS established a procedurally governed MOV program which provides improved motor operated valve reliability through operator refurbishment, j
enhancements, and diagnostic testing. The testing portion of the program performed static diagnostic testing to set motor operated valve 1
torque switches based on valve and operator requirements. The nuclear industry has assumed that static testing results could be accurately extrapolated to confirm that the valves would operate under dynamic conditions (differential pressure conditions).
Recent developments on j
site in conjunction with Idaho National Engineering Laboratory testing and information from the diagnostic equipment supplier (MOVATS, Inc.)
indicate an identifiable difference between these two conditions.
Recerit testing on the M0-2-6-38A indicated an approximate 30%
difference between thrust developed under static and dynamic conditions. This difference is consistent with M0 VATS, Inc. Technical Notice 89-02 " Spring Pack Response Under Differential Pressure".
A detailed review of previous MOV static test results has been performed by Nuclear Engineering and station personnel.
This review identified 31 valves that required a torque switch setting adjustment to provide sufficient margin to account for the specific differences between static and dynamic conditions. The specific operator adjustments and testing for each identified valve was completed on March 29, 1989.
2.4.9 Prior to restart provide the results of a review of instrument air tubing and support installations and show that the root cause of analysis of modifications adequately encompasses the installation deficiency.
(Section 3.7.3.1)
Status Philadelphia Electric Company has reviewed the instrument air tubing and support installation W iciency as part of an overall Modification Program Evaluation for PBAFS. The results of the evaluation are summarized in Attachment 1.
2.4.10 Prior to restart demonstrate the operability and maintainability of the Emergency Cooling Water System.
(Section3.7.4)
Status The operability and maintainability of the Emergency Cooling Water System will be demonstrated for Unit 2 by performance of Special Procedure SP 630-2, " Closed Loop Emergency Cooling System Test" and Surveillance Test ST 13.21, " Emergency Cooling Water Pump, Emergency Cooling Tower Fan, ESW Booster Pump Operability" prior to restart.
m.
- Document Control. Desk April 6, 1989 Page 8-These tests are scheduled to begin on April 7, 1989. The tests will-
' demonstrate:
The ability of the Unit 2 level control system to maintain pump bay water level when isolated from Conowingo Pond.
The ability to attain design flow through the Emergency Cooling System.
The ability of the Emergency' Service Water System to supply flow to its components while isolated from the Conowingo Pond.
The ability of the Unit 2 High Pressure Service Water System to supply flow to its componenti. while isolated from the Conowingo Pond.
The operability of the Emergency Cooling Water pump.
The operability of the ESW Booster pumps.
The operability of the Emergency Cooling Tower Fans.
The ability of the ECW pump to back up the ESW pumps.
The maintainability of the ECS is provided for by Modification 5095.
Replacement level controllers have been identified and reserved in current stock for use in the event of failure of the existing level controllers t
This response constitutes our reply to the issues raised in Inspection Report 89-81.
Please advise if you require further clarification or explanation.
Very truly yours,
]
Attachment cc:
W. T. Russell, Administrator, Region I, USNRC T.'P. Johnson, USNRC Senior Resident Inspector T. E. Magette, State of Maryland l
J. Urban, Delmarva Power l
i J. T. Boettger, Public Service Electric & Gas H. C. Schwemm, Atlantic Electric T. M. Gerusky, Commonwealth of Pennsylvania l
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ATTACHMENT 1
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NUCLEAR ENGINEERING DEPARTMENT N2-1, 2301 Market' Street MEMORANDUM
.j
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 & 3, Modification Program Evaluation In.
October 1988, the Configuration Management Task Force concluded. an assessment which determined the adequacy of the modification program at Peach Bottom Atomic Power Station (PBAPS).
In December 1988, NQA issued several audit findings pertaining. to the
- design, installation,.and inspection of PBAPS modifit7tions.
l' The number and perceived severity of the identified deficiencies, i
raised management's concern regarding the adequacy-of modifications.
To resolve this concern and to determine if the Configuration.
Management conclusion was valid, management directed the following actions'be taken:
1) a root cause analysis of the identified deficiencies, 2) an' engineering evaluation o'f the severity of the deficiencies, 3) a review to assure that NQA audit activities had encompassed all types of modification installations and, 4) to use the information gained from the above actions to develop appropr'iate remedial and preventive corrective actions to assure the adequacy of the modification program.
The above actions have been thoroughly completed.
The information obtained and the corrective actions taken as a result of these actions have provided assurance that the modification program has not compromised the safety of the plant.
This memorandum provides a
brief description of the background and results of the actions taken.
Background - Configuration Manacement Assessment The Configuration Management Steering Committee recommended that a survey of safety-related modifications be conducted to ensure that the as-built records reflected the installed condition and that procedures be upgraded to ensure proper verification prior to restart.
In response to these recommendations, a survey of four safety-related modifications and a review of other walkdown programs was conducted by Gilbert / Commonwealth, Inc. (G/C Report 2772 S-6).
This effort "... confirmpd the existence of a programmatic problem regarding as-built drawing and installed plant configuration agreement".
However, it was concluded that "No discrepancies have been identified to date (July 1, 1988) which have a significant impact on safety system operation...".
Additionally, responsibility
.for confirming tne accuracy of the installed conditions and the design documentation has been clearly assigned to the Construction Engineers.
, Backcround - NOA Audits NOA Audit PA88-513 is the audit which in December 1988, raised management's concern regarding modifications.
NOA performed this audit as a result of tracking a number of individual problems with the installation and inspection practices of modifications.
This audit was specifically designed to be a
thorough review of modification activities with an emphasis placed on installation and inspection activities.
As a
part of the action plan to resolve the concerns raised by NQA Audit PA88-513, NQA conducted a review of its completed audits to assure that all types of modification installations had been covered.
Based on this review, NOA was not satisifed that they had performed a
sufficient audit of electrical modifications..
Therefore, NOA undertook and completed Audit PA89-05 which covered all elements of the modification process for a number of electrical modifications, and identified four (4) CARS which arc being brought to resolution in the same manner as the eleven (11) CAP.s of Audit PA88-513.
The results of NOA's review of modification areas covered by audits is shown on Attachment 1 to this menorandum.
Backaround - NRC Intecrated Assessment Team Insoectier. (IATI)
As a
part of the NRC's IATI activities, improperly installed safety-related pneumatic tubing (valve actuator supply line) was identified.
Based on a
visual examination of the identified deficie-ncy by PECo personnel, it was determined that the deficiency 4
could have had an impact on system integrity or operability.
Therefore, all other similar safety-related tubing installations were reviewed.
The NRC-identified deficiency, as well as other deficiencies which were identified by the review, are being brought to resolution in the same fashion as, and along with, the NQA audit-identified deficiencies.
Engineering Evaluation of the Hardware Discrepancies An engineering evaluation of all identified hardware discrepancies has determined that all of the discrepancies, with the exception of two
- types, were not safety significant (i.e.,
they would not have an adverse impact on system integrity or operability).
The two discrepancies which were deemed to be safety significant were the improper installation of certain flex
- hoses, and the improper installation of pneumatic tubing.
Root Cause Analysis One of the actions taken to-resc1ve management's concern regarding modifications was to perform a formal root cause analysis of the identified deficiencies.
In order to accomplish the root cause analysis, a task force was formed with representatives from various organizations involved in the modification program.
The Nuclear Group Root Cause Analysis Guidelines were employed.
Following the analysis of the individual deficiencies, the deficiencies were evaluated in an integrated fashion to determine if
-.3 there were any programmatic root causes which would have been missed by analyzing the deficiencies on an individual basis.
The root cause of the improper flex hose installation was determined to be: an insufficient emphasis on special vendor-instructions.
A sample reinspection of modifications requiring special instructions determined the flex hose deficiency to be an isolated instance.
The root cause.of the pneumatic tubing deficiencies was determined to be a lack of definitive installation and maintenance guidance.
The air supply tubing was a field-run commodity with only general installation guidance provided by
. Engineering.
l Additionally, the air tubing lines were frequently. disturbed by maintenance activities, and since the tubing was a
field-run, commodity, drawings of the installations were not available to use when reinstalling the tubing.
One hundred percent (100%) of field-run safety-related-pneumatic tubing has been walked down, and all, identified discrepancies will be resolved prior to startup.
The only other type of commodity which could have been'adversaly, affected by the same root cause is field-run electrical cable (for separation requirements).
A sample review of safety-related cable has been performed, and no discrepancies were found.
Root causes were also identified for each'of the discrepancies determined to not be safety significant.
Targeted reinspection were performed to confirm that these root causes had not resulted in safety significant deficiencies.
An integrated analysis of all the discrepancies identified that the rooification program was not sufficiently rigorous and stringent to prevent the type of discrepancies identified.
Although thorough corrective actions have oeen completed to assure the integrity of physical installations, and snort term preventive actions are being implemented to assure the adequacy of modifications currently underway; a
large effort still remains to bring the modification.
program to the level of excellence' which has been demanded by management.
to this memorandum is a letter from the Executive Vice President -
- Nuclear, which expresses management's concerns' and. expectations in this area.
To achieve the necessary
. improvement, long term efforts are underway to provide clarification of responsibilities, restructuring of modification
- workflow, improved coordination during all
- stages, procedural enhancements, improved
- training, and improved specificity of installation and inspection requirements.
Modification Procram Effectiveness Assurance to this memorandum describes the logic used to integrate the many individual investigations,
- analyses, and corrective actions into a
program for assuring the adequacy of l
modifications.
All actions required to assure the adequacy of installed Jod ongoing modifications are either completed or will be completed prior to restart.
to this memorandum describes each of tne issues and discrepancies wnich have been addressed and resolved by the recent actions, the root causes for
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each discrepancy,
-the specific and generic remedial actions which have been taken, and the short term corrective actions to prevent recurrence.
Conclusion Since December 1988, when NQA Audit PA88-513 identified several deficiencies in modifications installed at
- PBAPS, a
significant effort has been made to assure.the adequacy of installed and. ongoing PBAPS modifications.
The resu'lts have provided assurance that, with the recently completed corrective actions, the. adequacy of these.
modifications is assured.
- However, it' is -recognized that-a considerable effort is still required to attain the level of excellence that management demands of the modification. program.
.Long term efforts are underway to improve the entire modification
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process.
Prepared by:
D.
R.
Helwig F.
J. Coyle March 27, 1989 FJC/mvf'032389 J
.. ' 'T EQUIPMENT INCLUDED IN COMPLETED MODIFICATION AUDITS & SURVEILLANCE.
INCLUDED HARDVARE SOFTVARE COMMODITY' IN AUDIT EVALUATED EVALUATED REMARXS (NOTE 1)
S. B. Pipe Yes X
X I
L. B. Pipe Yes*
X X
Part of Pipe Replacemen:
& ESU Audit-S. B. Hangers Yes
'X X
L. B. Hangers Yes*
X-
'X Part of Pipe Replacemen:
Audit Instruments Yes.
X X
Ins:. 'ltbing Yes*
X
. Par: of Mod 1316'and related reinspection activities e
-Elec:. Equip.
'Yes X
X Limited sample in,-Audi addressed primarily in P".-
program.
S.-B. Valves Yes X
X L. B. Valves Yes*
X X
Part of. Piping Repla' cement g
otherwise limited scope Pu=ps Yes*
X X
Par: cf Piping Replacement otherwise limited. scope.
Included in STs for Fire Dampers No*
ongoing verifications Raceway Yes*
X X
Par of Elect. Sep. Audi:
Cable Yes X
X Ter=inations Yes X
X Internal Wiring Yes*
X X
Par of Elect. Sep. Audi:
Cable Splices Yes X
X Raceway Seals Yes*
X X
Part of surveillance l
4 Ant r Bolts Yes X
X Part of surveillance Core bores-Yes X
X Part of surveillance Grout Yes*
X X
Par: of Mod 2371 Surv l
AC ACHMENT 1 1
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.INCfUDED HARDUARE-SOF'IUARE
' CO20f0DITY IN AUDII EUALUA'5ED E?A1.UATED
.PIliAPJJ Strue. Steel Yes*'
X X
Par: of Mod 842 Surv.
Welds / Piping
.Yes X-
.X Welds / Hangers Yes X
X the particular commodicy noced was verified by aud'ics NOTE 1:
The'* indicaces that or' surveillance other than FA 513 "Maj or Mods Audit. "
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FROM:
C. A. McNeill, Jr.
Personnel Involved With Modification Activities TO:
SUBJECT:
Compliance With Procedures l
As you are aware, we have recently completed both PBAPS 1
comprehensive examinations of modification activities at These reviews have underscored the need for significant j
and LGS.
improvements in all aspects of the modifications process - Design, i
Accomplishing these Engineering, Installation and Inspection.
l needed improvements will be a major organizational challenge over j
several years requiring a significant cultural change.
t the next e
One major insight f rom these reviews requires your i
immediate. attention - there were numerous instances of procedural i
non-conpliance and inattention to detail noted in each involved While no single oversight was of grave concern functional area.
individually, they are of major significance when viewed collectively. As a result, we have had to seriously consider whether we have had a quality program breakdown and have expanded considerable time and effort to justify the acceptability of 0
completed modification activities.
I am writing to each of you about this issue to underscore its importance and to ensure that the same guidance is received by all involved personnel in the various Nuclear Group Please remember that it is your responsibility to Departments.
j thoroughly understand your procedures, to follow them explicitly, and to identify procedural inadequacies and weaknesses to In the modifications arena the concept of procedural supervision.
compliance encompasses ensuring that the design meets all requirements and ensuring that the installation is in strict In this regard, I call your attention conformance with the design.
once again to the Nuclear Group Management Philosophy for Assurance of Quality which is attached.
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Executive Vice Presiden Nuclear attachment i
l ATTACHMENT 4
1 x-NUCLEAR GROUP MANAGEMENT PHILOSOPHY FOR ASSURANCE OF QUALITY DLfinition Assurance of cuality is' paramount in all nuclear acovices. Assurance of cuality involves a commitment to EXCELLENCE in one's own work pedormance and an acceptance of personal responsibility for tne overall safety and cuality of nuclear f
activives.
Nuclear Group Management Commitment to the Nuclear Employee Team The Nuclear Grouc is committed to the assurance of quality as Philadelphia Electric Company's approacn to nuclear acuvices.
To provide leaoersnip in, and support for, assurance of quality, we will:
- 1. Estaolish performance gotis wnicn contnoute to acnieving and maintaining EXCELLENCE in our nuclear acavities.-
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- 2. Comenunicate witn you aoout tnese goals to assure your understanding and support.
- 3. Use etfecove performance reporung systems. so snat we can monitor progress toward meeting our goats artd identify and resolve potential preolem areas on a omely casts.
- 4. Support procedural compliance oy assunng tnat procedures are accurate, up-to.cate and " user friendly."
- 5. Develop and maintain effecuve prootem reporung processes so that you can report ooserved ouality proolems or -
deficiencies quickly and easily.
- 6. Encourage your involvement in tne pursuit of EXCELLENCE by responding quickly and constructively to good suggestions for improving tne cuality and efficiency of work.
- 7. Encourage open ctammunicacons aoout all areas that affect tne safety and quality of nuclear activines.
- 8. Recognize escn employefs success in pursuit of assurance of ouality in performance evaluations.
Nuclea-Group Management Expectations for the Nuclear Employee Team in tum we nave expectations for a commitment from each Nuclear employee to assurance of puality.
Eacn of you will ce nefd accountable to:
- 1. Suoport tne accomplishment of your work group's per.'ormance goals Inrougn tne quality and omeliness of your work acavities.
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- 2. Supply accurate and timely data as required for performance tracking and reparang.
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- 3. Adnere to estaclisned procedures in tne performance of your work.
- 4. Notify your management in a omely manner of any proolems with procedural compliance, using estaclisned administrative processes.
E. Report ooserved quali y proolems or deficiencies in a timely manner. u:.ing estaolisned acmintstrative processes.
- 6. Make recommendations to your management for improving tne cuality and effi rency of work.
Sicned;
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