U-600803, Responds to NRC & SALP Rept 6 for Sept 1985 - Aug 1986
| ML20209B212 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/30/1986 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20209B076 | List: |
| References | |
| U-600803, NUDOCS 8704280391 | |
| Download: ML20209B212 (8) | |
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U-600803 L30-86,(12-30)-L ILLINDIS POWER COMPANY IP CLINTON POWER STATION. P.O. BOX 678. CLINTON. ILLINOIS 61727 DEC 3 01986 Docket No. 50-461
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Fb Mr. James G. Keppler Regional Administrator gtg Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Systematic Assessment of Licensee Performance l
Dear Mr. Keppler:
4 I
l This is in response to your letter dated November 28, l
1986, which enclosed the Systematic Assessment of Licensee Performance (SALP) Report No. 6 for Clinton Power Station for i
the period of September 1, 1985 to August 31, 1986, and requested that Illinois Power Company (IP) respond in writing with a description of its corrective action in the areas of maintenance, and quality programs and administrative I
controls.
The SALP 6 Report covers the transition period from I
construction completion to the beginning of operation. During i
this transition period, IP has taken substantial ste.ps to increase the awareness of all CPS personnel to procedural compliance with program requirements, identify problems and develop prompt, thorough corrective action.
The corrective action plans and implementation schedules for the areas of 4
f maintenance, and quality programs and administrative controls are summarized below.
A.
MAINTENANCE Maintenance work is performed by the Plant Maintenance Department, supported ty the maintenance contractor, Stone &
Webster Engineering Corporation (SWEC).
The primary function of the maintenance contractor is to perform major plant modifications and corrective maintenance to support the Plant Maintenance Department.
Some of the maintenance aroblems encountered during the SALP period were due to pTasing out the constructor, Baldwin Associates, and shifting outage DEc 31M 8704280391 870421 PDR ADOCK 05000461 G
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maintenance work and testing suoport to the newly established maintenance contractor and tofthe Plant Maintenance Department.
IP strengthened the management oversight of the maintenance contractor by assigning Mr. H. R. Lane as Manager of the newly established Scheduling and Outage Management.
Department in March.1986.
The Maintenance Improvement Program (discussed below) improved the coordination of. work i
between the maintenance contractor and the Plant Maintenance Department.
During the later stages of and following the assessment period (August 4, 1986 to October 10, 1986) an NRC_ inspection-was conducted in the area of maintenance.
In response to the initial results of that inspection IP approved a Maintenance Improvement Program on. September 10, 1986 That program strengthened management, improved department communications, y
consolidated the Maintenance Department and maintenance l
contractor planning groups, and upgraded arocedures.
Mr. R.
D. Freeman was assigned to the newly esta311shed position of
)
Assistant Plant Manager - Maintenance.
The program provides for all SWEC and Maintenance Department condition reports and audit findings to be reviewed by one group and the corrective action is reviewed by the Assistant Plant Manager -
Maintenance.
i The details of the Maintenance Improvement Program were presented to the NRC Staff on September 19,.1986 and updated on December 18, 1986.
The NRC Staff stated in I&E Inspection Report 86053 that the Maintenance Improvement Program appeared adequate and responsive to the issues.
The SALP Report describes nine major areas of maintenance corrective action, but incorrectly noted that IP had committed to i
complete action in each area prior to exceeding 5% power.
The status of each activity and projected completion date is summarized as follows.
1.
Maintenance Work Requests.
Improve performance in the areas of maintenance work request (MWR) planning, execution, review, and scheduling.
The MWR~ procedure has been upgraded to include more detailed job stepping and to assure that MWRs have been reviewed for post maintenance testing.
The MWR closeout review has been improved and training on revised procedures has been completed.
Maintenance planning is now being performed by a separate group.
A new corporate nuclear procedure has been issued to provide guidance on nuclear program _ priorities.
This has had a positive impact on scheduling MWRs.
This activity is ongoing.
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Reorganization.
Restructure the Maintenance Department to separate the planning responsibility from the execution of work.
This is complete.
The Maintenance Planning group has been established and is discussed in item 4.
3.
Management.
Expand the management of the Maintenance Department.
This is complete.
Mr..R. D. Freeman has been assigned as the Assistant Plant Manager - Maintenance.
The Director - Maintenance, Mr. S. Richey the Supervisor -
Maintenance Planning, Mr. J. Carter; and the Technical Advisor Maintenance Programs, Mr. V. Harris, report to the Assistant Plant Manager - Maintenance.
4.
Maintenance Planning.
Consolidate all maintenance planning.
All maintenance planning has been consolidated under the Supervisor - Maintenance Planning, Mr. J. Carter, who reports to the Assistant Plant Manager --Maintenance.
MWR planning, scheduling interface and work statusing is performed by Maintenance Planning.
This change is complete.
S.
Communications.
Improve communications in the Maintenance Department, j
l Maintenance supervisors have been directed to spend more-time observing work in the plant.
Technicians have been briefed on giving direct feedback to supervisors when problems occur.
A monthly meeting is held with supervisors and foremen to discuss current problems and future plans.
A monthly newsletter will be distributed to all maintenance personnel highlighting department problems and current events.
Frequent meetings are held with the maintenance contractor management.
These i
activities are in progress and will be an ongoing effort.
6.
Documentation.
Ensure that prior to vaulting, the maintenance work request is a stand-alone document.
All MWRs from May 1986 to September 1986 are in the process of being audited for post maintenance test requirements.
The MWR procedure has been revised to ensure that MWRs are reviewed for post maintenance testing requirements.
This effort is still in' progress and is scheduled to be completed in 1987.
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7.
Generic Lists.
Develop generic lists for preapproved expendable maintenance items.
Work is in progress to develop generic lists for valve lubrication and packing and is scheduled to be completed late in 1987.
8.
Procedure Review.
Conduct a top-down procedure review to assure that lower tier documents fully implement upper tier documents.
This is in planning and is scheduled to be complete in 1987.
9.
Field Engineering.
Expand the field engineering group within the maintenance planning organization to ensure that maintenance work requests receive an adequate review prior to performing work.
This is in progress and is scheduled to become operational in January 1987.
Based upon discussion with the Senior Resident Inspector, Mr. T. P. Gwynn, IP intends to implement these activities as described above, and understands that these activities are not required to be completed before exceeding 5% of rated power.
B.
QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY Illinois Power has taken a number of actions during and after the SALP period to improve quality programs and administrative controls affecting quality at CPS.
Major areas of improvement are-summarized-below:
1.
Supervisory Involvement Increased monitoring of plant activities is being achieved through the following programs:
Field Supervision.
Quality Assurance and Maintenance Department supervisors have been directed to spend more time observing work activities in the plant.
Security.
Security has added'an administrative supervisor to each security shift to relieve the Security Shift Supervisor of routine administrative work.
Improved training for security supervisors is also being planned for early 1987.
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Page 5 of 8 Work Control.
Preparing for the CPS low power license required personnel to work a considerable amount of overtime.
Fatigue was one factor'in the~
mistakes that occurred during fuel load.
The pace of work was slowed and overtime minimized to reduce personnel fatigue and enhance attention to detail.
Shift Outage Managers.
Shift Outage Managers assist the Shift Supervisors by providing a single point of contact for management direction and control of scheduled production and test activities.
The purpose of the Shift Outage Manager is to improve overall schedule performance by setting production and test priorities for emergent work so that' operations personnel are not distracted by non-operational matters.
2.
Organizational Changes The positions of Assistant Plant Manager -
Operations and Assistant Plant Manager -
Maintenance were established to enhance management control of these departments.
The Startup Department has been moved under the control of the Plant Manager.
The responsibility for post maintenance testing was shifted from the Maintenance Department to t
Operations Department.
1 3.
Improved Communications 1
Greater emphasis has been placed on improving the
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i reporting of problems to management.
%e following J
activities were initiated to achieve this objective:
Reporting Significant Problems.
Site-wide briefings have been held on identifying and reporting significant problems to management and following up on those problems after they have been 1
reported.
Managers' Meetings.
Managers meet daily to discuss current problems and establish priorities for upcoming work.
t Plant Staff and QA Department Management Meetings.
Quality Assurance Department and Plant Staff directors and managers meet frequently to improve the communication between the two departments and to resolve current problems.
These frequent meetings began in December 1986.
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Page 6 of 8 Personnel Briefings.
Personnel have been briefed on following procedures, attention to detail and doing the job right the first time._ Briefings are also held on Licensee Event Reports (LERs), fuel load incidents and other significant events.
l 4.
Problem Identification The following programs and activities were implemented to improve problem identification:
Operations Monitoring.
The Operations Monitoring Program was fully implemented in March 1986, to-evaluate and improve plant performance.
This program identifies and highlights potential problem areas to managers so that early action may be taken to prevent problems and to correct minor problems before they become significant.
The reporting mechanism provides CPS managers direct feedback of observations of plant conditions.
Approximately twenty attributes from observation reports, such as procedural compliance, procedure adequacy, and supervision, are trended and issued in monthly and quarterly reports.
The Operations Monitoring Program looks beyond the compliance-based QA programs to improve plant performance.
Trend Analysis.
A separate program was initiated to perform trend analysis of LERs.
The QA Department has enhanced their trend analysis program to include LERs and to trend the root causes of conditions adverse-to quality.
Lessons Learned.
Industry lessons learned are being reviewed for applicability to-CPS.
IP is an active member of the BWR-6 Technical Information Exchange Group.
Representatives from each of the four BWR-6 plants meet and discuss problems experienced during startup and how the problems j
were solved.
I QA Audits.
The QA Department is placing additional emphasis on assuring that the intent.of the requirements is being met and that IP is applying high standards to the various programs at CPS.
i Trend Identification Training.
QA personnel have been trained to look for repetitive problems which j
may be indicative of an adverse trend and to notify management when adverse trends are identified.
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1 Root Cause Analysis.
The Licensing and Safety Department procedure on Licensee Event Reports is being revised to include a more detailed analysis of the root cause of the event.
i 5.
Corrective Action The effectiveness of corrective action has been improved by the following activities:
One Hour Reporting.
The Condition Report procedure has been revised to require that management be notified within one hour of conditions requiring a Condition Report. Management can make an initial assessment of the significance of the problem, initiate the appropriate corrective action, and adjust the priority accordingly.
Significant Event Critique.
Immediately following a,significant operating event a critique is held to determine the sequence of events and formulate the 4
initial corrective action to focus the S
investigation of the event.
LER Briefings.
All departments brief their personnel on CPS Licensee Event Reports to ensure that there is a widespread understanding of the lessons learned and the root cause of each event.
l Overdue Corrective Action.
The Manager - Quality Assurance is informed of all overdue corrective action to QA findings.
The Manager - QA meets with the responsible department manager to expedite closure of the corrective action.
Audit Findings.
The departments responsible for addressing audit findings are now given one hour to inform the Quality Assurance Department of their corrective action plan and five days to provide QA with a written response to the finding.
This system ensures that QA is involved early in assessing the adequacy of the corrective action.
Stop Work Authority.
QA Department personnel have been briefed and QA procedures have been revised to clarify the authority that QA personnel have to immediately stop unsatisfactory work.
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In summary, IP has taken significant actions to improve performance.
These actions are indicative of IP's commitment to a safe and deliberate startup test program and excellence 1
in plant operations.
Sincerely yours, j
. Hall Vice President PJT/bsa cc:
B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Director, Office of I&E, USNRC, Washington, D.C. 20555 Illinois Department of Nuclear Safety
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