ML20244E124

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Forwards Trip Rept of 860210-21 Site Visit Re INPO Evaluation of Util Operating Experience Program.Addl Comments on Generic Operating Experience Review Program Items Listed
ML20244E124
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 07/22/1986
From: Crooks J
NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To: Bauman J
INSTITUTE OF NUCLEAR POWER OPERATIONS
Shared Package
ML20238E398 List:
References
FOIA-87-465, FOIA-870465 NUDOCS 8607300567
Download: ML20244E124 (4)
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UNITED STATES

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  • NUCLEAR REGULATORY COMMIS$10N

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    • "* Jut tt 1ges Mr. J. R. Bauman, Manager.

Internal Training Department Institute of Nuclear power Operations 1100 circle 75 Parkway Suite 1500 Atlanta, Georgia 30339

Dear Mr. Bauman:

Per your. request as the INPO evaluation team manager, enclosed is a copy of

- the trip report covering my observation of INP0's evaluation of the operating experience program at McGuire Nuclear Station. These observations reflect sty understanding of the activities of INPO and NRC reviews in the OE area.

Overall. I found that observing the INPO plant evaluation efforts was very .

educational and a rewarding experience. The professionalism and candor with '

which the evaluation was conducted was noteworthy. Based on this example, if the utilities take responsible actions to resolve concerns that INPO has brought to their attention, your efforts should aid the safety of operations.

Below are some additional comments on generic operating experience (CE) review program items similar to those we discussed during my visit on March 24, 1986.

These comments are provided for your consideration as my peer comments as an observer of the evaluation process. My coments are provided as feedback that c may be useful when INP0's OE evaluation program is reviewed and when [NPO guidance documents undergo revision. '

(1) Evaluat(en_of OE Programs (a)

Assessment of Yield - In assessing OE programs, one item of .

major interest is a determination of program effectiveness.

In this regard, INPO currently seems to assess the effective-ness of DE feedback through its determination of whether or not a utility has satisfactorily responded to each specific INP0 recommendation in SOERs and to coments in a sampling of SERs. The statistics developed, however, do not indicate what the yield from OE feedback is in terms of changs to the plant, procedures, or training. That is, since a satisfactory response to an INP0 recommendation includes no action required, an indi-cation that 80 percent of INPO's recommendations have been addressed does not indicate a yield in terms of change. The concept of measuring a yield in terms of change at the plant seems worthwhile, but needs further development. For example,

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one measuremer.t might be the determination of tL2 percent of the OE feedback per quarter or year resulting in change.

If this can be done practically, it would seem to be useful to the utility to identify whether resources are being .

expended properly in response to OE, may be of value to INPO in assessing the type and quality of feedback that is most

! useful, and also would be an indicator of progran effective-ness. For example, it might indicate whether scfficient attention is being given to industry feedback when considered l

with the plant's age and perfonnance history (f.e., a low yield at an older plant with few problems because it has previously responded to OE may be very reasonable, while the same yield at a new plant with many problems may indicate a lack of attention to OE and may be a causal factor for recurrenceofproblems).

(b) Basis for Judgments / Documentation - You may want to reconsider the need for establishing a more consistent basis for making judgments on whether the OE performance objectives are being -

  • met, since there tre no specified minimum criteria to assess each avaluation and no requirement to assess them all each time.

I understand the desire for flexibility in the evaluations, but it seems that in most eve.luations, the overall judgments become too subjective or no judgment is made. The results of the current evaluation practices would seem to make comparisons between individual plant visits and among all plants very difficult and very sub.iective. For example, if development of a concern regarding one supporting criterion (e.g., assessing

,~ applicability of the information to the plant) consumes a large amount of time such that an equally important criterion (e.g.,

'is information appropriately disseminated) is not adequately addressed, how is meeting the per'formance objective addressed?

Presently, it would seem that only the concern would be docu-mented and little, if any, documentation addresses the areas that did not get thoroughly reviewed. The identification of a a minimum number of key criteria to be evaluated each time for )

each of the OE review areas would thus seem to be worthwhile.  !

This could provide a more consistent basis for making a judgment on whether or not the performance objective is being met. This judgment could also be explicitly documented with the necessary qualifying statements included. Your overall assessment on each performance objective would seem to be of value to the utility.

1 OE Feedback Dissemina' tion - It is sqy understnading that INP0's (c) primary interest in this area is in assuring that the OE feed-back gets to the appropriate management and technical support staff at a utility, since they are responsible'for ensuring that OE review activities are effectively implemented. It seems equally important to me that in addition to ensuring that those l l j personnel receive the information and initiate corrective j actions (i.e., plant modifications, procedure changes, increased

Mr. J. R. Bauman , 3-training, etc.), a reasonable amount of the OE should be pro-vided directly to the plant operators, trades personnel, other technicians, and non-supervisory staff. These persnnnei also need to be kept fully aware of the occurrence of unanticipated operational anomolies and of the potential consequences of '

incorrect personnel actions. More routine evaluation by INPO of the quantity and quality of information disseminated directly l to these personnel would also seen worthwhile.

(2) INPO Guidance - In the published good practices documents related ,'

to OE reviews. I did not notice any explicit guidance suggesting that each utility develop specific goals and objectives for their  ;

DE activities and connunicate them to the personnel involved in the OE efforts. The primary goal of improving safety and relta-bility of operations is clearly stated, however, there is no mention of succinct secondary items such as increasing safety system avail-ability, decreasing the frequency of recurrent safety-related events.

preventing serious incidents and increasing the plant staff's aware-ness of anomalous occurrences and frequent personnel errors. Promul-gation of generic and/or proposed plant specific items by the industry should assist the personnel involved in making judgments -

" regarding their response actions during the assessment phase of the OE review activity. In addition, they may assist in evaluating the effectiveness of the OE review activities by providing a basis for assessments. This information could be added to the _ INFO good practices documents in a revision cycle.

Several of the INPD good practice documents for the OE area might also be improved during the next revision cycle by adding intro-ductory information stating that implementing the described i

practices should promote excellence in operations and then upgrading content of the good practice documents where needed. For example,  :

the need for effectiveness reviews is not consistently addressed in the various documents related to OE activities. Some explanatory material also seemed to be in a document other than the one that you would expect to find it in. Cross-referencing seemed lacking in several documents probably because they were generated separately over time. The use of a conraon format afght also be helpful, because several documents seemed to lack pertinent sections.

The INP0 guidance also does not address the a corporate and plant staff in the OE programs.ppropriate rolethe For example, for corporate staff for utilities with multiple sites can best serve the function of ensuring consistent responses to OE feedback for the various sites and can coordinate OE feedback between sites. On the other hand, the corporate staff may not be the most knowledge-able to make the assessment of applicability of the industry-wide OE feedbach to a site, unless it has a staff that has a wealth oft very

Mr. J. R. Baumari e

<1 specific knowledge of the current syste.ms engineering details and operating practices for the. site. Some discussion of this topic might assist utilities initiating such program.s or reorganizing 4 existing programs which are judged to need Improvement.

Please contact me if you have any questions or neef further clarification of my comments. My telephone number is (301) 492-4425.

r Sincerely, - -

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1.'[/h hs e.> l onL Crooks,

. Chief 1i 1 f' Data Management Section, PTB

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Enclosure:

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