ML20217D546

Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission

ML20217D546
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle
Issue date:	04/18/1997
From:	Capra R NRC (Affiliation Not Assigned)
To:	Bill Dean NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20217D413	List: IA-97-178, Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission ML20217D410 ML20217D426 ML20217D438 ML20217D453 ML20217D461 ML20217D466 ML20217D476 ML20217D517 ML20217D528 ML20217D532 ML20217D539 ML20217D542 ML20217D546
References
FOIA-97-178 NUDOCS 9710030279
Download: ML20217D546 (71)

Text

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%g LIMITED OFFICIAL USt ONLY ff o 4 UNITED STATES s.,

!! NUCLEAR REGULATORY COMMISSION

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• April 18, 1997 Comission Briefina Pacer {

MEMODANDUM 10: William M. Dean, Chivf Regional Operations Staff Office of the Executive Director for Operations FROM: Robert A. Capra Director QMg;P, Project Directorate 111-2 Division of Reactor Projects - Ill/IV Office of Nuclear Reactor Regulation l

SUBJECT:

MEETING OF COMMONWEALTH EDISON COMPANY EXECUTIVES WITH THE COMMISSION l

On April 25, 1997, Mr. James O'Connor, Chairman and Chief Executive Officer, i

Hr. Tom Haiman, Executive Vice President of the Nuclear Division, and Mr.

Harry Keiser, Chief Nuclear Operating Officer will address the Commission.

Also present will be Mr. Leo F. Mullin, Vice Chairman, anti Mr. Sam Skinner, i President.

Attached is a background briefing package i preparation for the meeting.

The following items are included:

Names and Resumes of the Comonwealth Edison (Comed) Presenters e

Comed Corporate Organization Chart

• Historical Background Information on Comed a

Sumary of SALP Ratings and Current Plant Issues Staff Assessment of Comed's Response to 50.54(f) Letter

• Proposed Questions for Commission to ask Comed

• Comed's Response to 50.54(f) Letter Draft Letter to Comed Regarding Comed's Response LaSalle Independent Self Assessment Team Report

• Zion Independent Self Assessment Team Report Recent Semiannual Plant Performance Assessments for Comed Facilities Please note that the enclosed staff assessment of Comed's response to the letter is currently considered pre-decisional information. Following 50.54(f)ission the Com Meeting, it is the staff's intent to include the assessment as an enclosure to NRC's response to Comed.

Information in this record was deleted in accordance with le Freedom of Information Flh

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9710030279 970930 LIMITED OFFICIAL USE ONLY AD -178 PDit

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LIMITE0 0FFIC1/.1. 's4 ONLY

W. Dean l (

I l Should you require any additional information, please contact either me l (415-1395) orFr.GeorgeDick(415-3019). f Docket Nos. STN 50-454. STN 50-455, STN .5? 456, STN 50-457,50-010, 50-23i, 50-249, 50-J13, 50-374, 50-254, 50-265, 50-295, 50-3v4 Attachments: As Stated cc: S. Collins /F. Miraglia R. Zimerman A. Thadant J. Roe A. Beach, R-!!!

B. McCabe i

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JAMES J. O'CONNOR Chairman and Chief Exe:utive Officer EXPERIFNCE Unicom/ Commonwealth Edison Comliany Present 1980 Chairmu and Chief Executive Officer 1980 1978 hiember of Board of Directors 1978 1977 President 1977 - 1973 Executive Vice President 1973 1970 Vice President 1970 1967 Assistant Vlec President 1967 1966 Division Conunercial hianager at Chicago North 1966 1963 Statt Assistant to the Chairman of the Board and Chairman of the Executne Committee

. United States Air Force 1963 1960 Three years or active duty EDUCATION

• JD Georgetown Law School,1963 hfBA - Harvard University,1960 BS - Holy Cross College, major in economics,1958 PROFESSIONAL AFFILIATIONS -

• Director of Nuclear Energy Institute, Chairman of the Advance Reactor Cosposation Director of Edison Electric Institute, past Chairman Board of the Institute of Nuclear Power Operation, past Chairman hiember of Board of Directors of American Nuclear Energy Council karesumet wpf/86

THOh1AS Ja h1Alh1AN Senior Vice President i (

EXPERIENCE

• Commonunlth Edison Company ,

Present - 1996 Sr. Vice President, Nuclear Disision 1996 1994 Sr Vice President, Fossil Division 1994 - 1992 Sr. Vice President, Commercial Disision 1992 1990 Vice President, Corporate Engineering 1990 - 1987 Vice President, Nuclear PWR Operations 1987 1984 Vice President and General Manager, Nuclear Construction 1984 - 1982 Disisjon Vice President and General Manager, Fossil 1982 - 1980 Asst. Vice President, Engineering 1980 1978 Station Mechanical Engineering Manager 1978 - 1976 Distribution Engineering Manager 1976 - 1974 Division Operating Manager, Chicago North 1974 1973 Area Manager, Glenbard Area 1973 - 1972 Area Manager, Des Plaines Valley Area

~

1972 - 1971 Asst. Division Operating Manager, Northern Division 1971 - 1969 Division engineer, Northern Division

, 1969 - 1965 Various functional and Supenisory Engineering Positions EDUCATION MS ihuirr ~ Administration, Loyola University, Chicago, Illinois,1972 BS - EleveM1 Engineering, University of Illinois, Urbana, Illinois,1962 EROFESSIONAL AFFILIATIONS Member of tne Institute of Electrical Electronics 0ngineers (IEEE)

Edison Elcaric Institute (EEI)

Western Society of Engineers karesumel.wpf/101

l HAROLD Wa (BARRY) KEISER Chief Nuclear Operating Offi,er 4

EXPERIENCE

• Commonwealth Edison Company Present - 1996 Chief Nuclear Operating Officer 1996 - 1995 Vice President PWR Operations

• Entergy Operations, Inc.

1995 - 1993 Executive Vice President and Chief Operating Officer 1993 - 1988- Senior Vice President - Gulf States Utilities

)

• Nuclear Pennsylvania Power and Light i 1988 -1988 Senior Vice President

1988 - 1985 Vice President-Nuclear Operations, Susquehahna Steam Electric Station 1985 - 1980 Plant Manager, Susquehanna Steam Electric Station i

• Consumers Power 4

1980 - 1978 Operations and Maintenance Manager, Palisades Nuclear Station i 1977 - 1977 Operations Manager, Palisades Nuclear Station 1976 - 1976 Project Engineer, Palisades Nuclear Station

. 1975 - 1973 Various Engineering Roles, Palisades Nuclear Station

^

Military Experience

-1968 -1961 United States Navy EDUCATION ,

• MS - Nuclear EnFi neering, University of Illinois, Urbana, Illinois,1973 BS - Metallurgical Engineering, University of Illinois, Urbana, Illinois,1972

. PROFESSIONAL AFFILIATIONS .

• Certified Senior Reactor Operator License,1976 keresumel vp!/106

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. l SAMUEL K. SKIhWER ,

President l

l-l EXPERIENCE:

Present -

1993 President, Unicom/ Commonwealth Edison Company i 1993 - 1989 Staff af Pnsident George Bush President's Chief of Staff Seentary of Transponation

. 1989 .1977 Sr. Partner, Sidley & Austin

, 1977 - 1968 U.S. Attorrey for Nonhern District of Illinois

! 1968 - 1961 Several Positions, IBM l 1961 - 1960 U.S. Army l

1 i EDUCATION:

i University of Illinois,1960 l

f: DePaul University Law School,1966 L

i PROFESSIONAL AFFILIATIONS: .

!' Board cf Dimetors, Unicom Board of Dinctors, ANTEC Corporation 1

j Board of Directors,'Ibe LTV Corporation Board of Directors, Union Pacific Resources Group, Inc.

International Advisory Council, The Broken Hill Proprietary Company Ltd.

s i

4

. LEO F. MULLIN .

I

( Vice Chainnan EXPERIENCE: '

Prasent - 1995 Vice Chainnan, Unicom/ Commonwealth Edison Company . )

1995 - 1993 Chief Operating Omcer, Mrst Chicago Corporation l I

1993 - 1990 Chairman and CEO, Amedcan National Corporation .

J 1990 - 1981 Several Positions, Mnt Chicago Corporation l

1981 - 1976 Sr. Vice Pnsident for Strategic Planning, Conrall 1

EDUCATION:

AB - Harvard College MS- The Harvard Graduate School of Arts and Sciences l

l MBA - Harvard Business School 4 ,

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LIMITED 0FFICIAL USE ONLY BACKGROUND INFORMATION ON COMED Commonwealth Edison Company (Comed) underwent a rertructuring in June 1994, whereby it became a wholly owned subsidiary of Unicom. The purpose of the

-restructuring was to permit other subsidiaries of Unicom to operate in an unregulated- environment. Connonwealth Edison has 12 operating units at six sites.and one unit in SAFSTOR.

Until recently, Comed had traditionally promoted from within and as a result, benefited little from outside experience. During its ambitious plant construction program during the 1970's and early 1980's, many of the company's more talented managers were moved from site to site to-complete construction and get the units licensed and started up. Likewise, corporate attention and resources were focused on the newer units while they were in the latter stages of construction and licensing. As a result, the older. plants generally got fewer resources and less quality management attention. Plant material condition and operating standards and practices declined.

The cyclical safety-performance of the Comed nuclear stations hat, long concerned the Commission and NRC staff. LaSalle 1/2 were placed on the NRC's watch list from April 1986 to October 1986. Dresden 2/3 were placed on the <

watch list from June 1987 until December 1988 and was returned to the watch list in January 1992 and remains on the watch list. Zion 1/2 were placed on the watch list from January 1991 until January 1993. In January 1994, significant problems were noted at Dresden 1, which was permanently shut down in 1978, when a significant freezing event revealed a number of management oversight weaknesses. Due to declining performance, trending letters were issued to LaSalle 1/2 in January 1994 and June 1994 and to Quad Cities 1/2_in January 1994, June 1994 and January 1995. As a result of performance concerns discussed during the January 1997_ Senior Management Meeting (SMM), LaSalle 1/2 and Zion 1/2 were placed back.on the watch list._-In contrast to the above,.

performance at Byron'l/2 has generally been good to superior and it was identified as a Good Performer at the Januarj 1994, June 1994 and January 1995

.SMMs.

SECY-92-228, " Performance of Commonwealth Edison Company Plants," dated June 25, 1992, descriLed Comed's major weaknesses. These weakaesses were:

(1) lack of effective manage::ent attention.and application of resources; (2) weak corporate oversight of nuclear operations; (3) poor problem recognition and failure to-ensure lasting corrective actions; (4) lack of adequate engineering. support; and (5) an inability or reluctance to learn from experiences at other Comed sn es and other utilities.

Significant steps toward improved performance have been taken only within the

-last several years. 'These steps included: reorganizing to clearly establish responsibilities for 91 ant operation and oversight; increasing the company's

engineering _capabiliu; improving craft skills; benchmarking their performance against other utilities; and hiring management individuals from outside the company. Among those hired were several corporate vice presidents, site vice presidents, plant managers and various senior and mid-level plant management individuals. A number of the managers hired early in this. process had no experience in improving the performance of problem plants and were not

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LIMITED OFFICIAL USE ONLY effective in doing so at Comed. This resulted in numerous senior management changes at the poorer performing plants.

As a result, Comed continued to make organizational and management changes.

In April 1996, Thomas J. Maiman was selected to replace Michael J. Wallace as the Senior Vice President with oversight responsibilities of Comed's Nuclear i Division. He reports directly to the Chairman and CEO, Mr. James J. O'Connor.

Support functions of a planning and strategic nature report to Mr. Maiman.

, Mr. Maiman has held various senior management positions in the company's .

Fossil Division and Commercial Division. Prior management positions in the Nuclear Division included Vice President of PWR Operations and Vice President

{ and Manager of Projects for Construction of the Byron /Braidwood Stations.

The Chief Nuclear Operating Officer, Harold W. Keiser, is responsible for the day-to-day operations of all six Comed nuclear stations. Mr. Keiser joined Comed in December 1995 after serving in a similar position as Chief Nuclear Officer and Executive Vice President of Entergy Operations Inc. In March 1996, Mr. Keiser accepted the position of Chief Nuclear Operating Officer thereby eliminating the Senior Vice President for BWR and PWR Operations positions. Mr. Steve Perry, formerly tne Senior Vice President for BWR Operations, became the full-time Site Vice President at Dresden Station.

Functions that support day-to-day operations (e.g., engineering) report to Mr.

Keiser. One of Mr. Keiser's primary areas of focus is in assessing and

improving management's effectiveness at each of the six nuclear sites and bringing in outside talent where needed.

Mr. David A. Sager, previously Vice President for Florida Power and Light's St. Lucie plant, joined Comed in June 1996 as Vice President for Generation Support. Mr. Sager oversees functions that directly support plant operations, including maintenance support, regulatory assurance and health physics.

As a result of the cyclic performance of its nuclear facilities, on January 27, 1997, a letter was issued to Comed which required the submittal of information pursuant to 10 CFR 50.54(f) that will allow the NRC to determine what actions, if any, should be taken to ensure Comed can safely operate its six nuclear stations while sustaining performance improvement at each. site.

Comed response was submitted on March 28, 1997. A Commission Meeting _with Comed to discuss its response will be held on April 25, 1997.

To meet its current performance challenges, Comed is taking some noteworthy actions. It has significantly increased its allocation cf resources to address its system wide performance problems. Additional significant changes were made at senior management levels to provide better and more focused oversight and guidance to the nuclear sites. Five of six Site Vice Presidents now come from outside of the Commonwealth system and five of the six Plant Managers or General Managers, as the case may be, have also come from outside the system. More managers at less senicr positions are continuously being recruited and brought into the system.

In addition, using a team of industry peers and INP0 representatives, Comed performed an Independent Self Assessment (ISA) at LaSalle and Zion. This was a particularly noteworthy effort aimed at determining why previous pt-formance improvement initiatives were not successful at these two facilities. N

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LIMITED OFFICIAL USE ONLY licensee's effort found similar performance problems at each of the sites.

The ISA attributed the reasons for the problems to be due in part to weak management processes and a lack of management involvement. Comed's plans to address these findings are being developed. A summary of the assessment findings and an overview of the corrective actions were presented by Comed at public exit meetings at both of the facilities on February 20, 1996, in response to the findings of the NRC's Independent Safety Inspection (ISI) at Dresden and other recent NRC inspections, as well as the ISAs at LaSalle and Zion, Comed has directed that each site initiate actions to improve the quality, maintenance and accessibility of design information. Comed has also initiated a plan to upgrade the quality and accessibility of design basis information at all six of its nuclear stations. These corrective actions are delineated in correspondence to the NRC dated, November 12, 1997 and J,auary 30, 1997. Among its actions, the plan addresses design basis document manuals, critical calculation information, and UFSAR validation. The NRC issued a confirmatory action letter on November 21, 1996 to confirm the

, actions Comed is taking or will take to address the engineering deficiencies at Dresden.

In summary, Comed has brought in a number of new managers with a philosophy to focus on safety, identify issues and resolve them, and is aggressively seeking change at it's poorer performing facilities; however, the effectiveness of these recent initiatives has yet to be fully demonstrated.

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SUMMARY

OF PLANT PERFORMANCE AND ISSUES MOST RECENT S&LP SCORES I l

Elin_t SALP Period SALP Scores (1) '

Braidwood 02/94-09/95 2,2,2,1 Byron 08/94-08/96 2.1,1,2 Dresden 03/95-12/96 2,3,3,2 4

LaSalle 11/94-08/96 3,3,3,2 Quad Cities 07/95-10/96 2,3,3,2 Zion 05/94-12/95 3,2,2,2 NOTES: (1) Operations, Maintenance, Engineering, Plant Support PLANT-SPECIFIC PERFORMANCE A detailed assessment of plant-specific performance is provided in the most i,

recent " Semiannual Plant Performance Assessment" for each facility. Copies of these documents are provided in this briefing package.

LICENSING AND TECHNICAL ISSUES Byron & Braidwood Steam Generators The tubes in the steam generators (Westinghouse Model D-4) at Byron, Unit 1, and Braidwood, Unit 1, are subject to outside diameter stress corrosion cracking (00 SCC) at the tube support plates (TSPs). In addition, large numbers of circumferential crack indications were found in recent inspections in tubes in the tubesheet area in both units. All tubes with such indications were either sleeved or plugged. As a consequence, Byren, Unit 1, operating with an effective steam generator tube plugging value of 17 percent, is limited to less than 100 percent power. Braidwood, Unit I with an effective plugging value of 13 percent is also limited to slightly less than full power.

Byron, Unit 2, and Braidwood, Unit 2, have Westinghouse Model D-5 steam generators which have not shown evidence of accelerated tubt degradation.

On November 9,1995, the staff issued license amendments approving the 3-volt i interim plugging criteria (IPC) for one cycle for the Byron and Braidwood Unit I steam generators. The staff approved the 3-volt criteria based on the expansion of selected tubes into the TSPs. On August 19, 1996, Comed submitted a request to extend cpproval of the 3-volt IPC for an additional cycle for Byron, Unit I and Braidwood, Unit 1. The request is under staff review. The licensee informed the staff it found that a relatively high proportion of the Braidwood locked tubes inspected during the April 1997, refueling outage had circumferential crack indications at the top of the tubesheet. Comed will repair all 85 of the locked tubes pricr to restart.

Because Byron, Unit 1 is scheduled to operate for a longer the than Braidwood, Unit I did, the licensee is preparing an operability evaluation.

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, The licensee's long-term solution is to replace the steam generators; Byron, 4

e Unit 1, replacement is scheduled to begin in November 1997 and Braidwood, Unit 4 1, in the fall of 1998. In the short term, the licensee is taking steps to safely maintain as high a auwer output as possible with the degraded steam generators. At present, tie licensee is required to repair or remove from service those tubes that have eddy current voltages greater than 3-volts and all tubes with circumferential crack indications.

Technical Soecification Uoorades All of the Comed sites are upgrading their Technical Specifications (TS).

Dresden and Quad Cities which had custom TS were recently issued new TS which converted the plants to the old version of the Standard TS. Implementation at Quad Cities occurred in September 1996, and at Dresden in January 1997. Zion is converting to the Improved Standard Technical Specifications (ISTS) with full implementation scheduled in the second quarter of 1997. The Byron and 4 Braidwood ISTS amendment application was submitted on December 13, 1996.

Application for the LaSalle conversion to ISTS has been delayed from January

1997 to July 1997.

Status of Individual Plant Examinations (1 pes)

In a staff evaluation dated November 22, 1994, the staff informed Comed that although Zion's IPE responded to Generic letter 88-20, the process used in the IPE could mask potential vulnerabilities and lead to a false sense of security 4 with respect to the likelihood of a severe accident. In response to the staff evaluation, Comed submitted a modified IPE on September 1, 1995. In a staff 4

evaluation dated September 17, 1996, the staff informed Comed that the modified IPE met the intent of Generic Letter 88-20.

On March 14, 1996, the staff informed Comed that LaSalle's IPE submittal met the intent of GL 88-20. However, the staff identified several weaknesses in

. the method for common cause and human reliability analyses in other Comed IPE submittals and recomended that the licensee consider those concerns in the

, update of the LaSalle IPE.- Or April 18, 1996, the licensee informed the staff that it had addressed the concerns identified in the March 14, 1996, letter.

On November 9,1995, the staff informed Comed that based on the IPE submittals for Dresden and Quad Cities, the staff could not reach the conclusion that 4 Comed met the intent of GL 88-?J for those sites. Responses to the NRC's

. concerns and revisions to the IPEs were submitted for Dresden (June 28,1996) and Quad Cities (August 30. 1996). They are currently under staff review.

2 RAls were sent on February 1, 1996, for the Byron IPE and on January 26, 1996, for the_ Braidwood IPE, vnich identified plant specific concerns as well as the ones previously relayed regarding human factors and common cause. Revised IPE

! submittals for Byron and Braidwood were submitted in March 1997 and are currently under sttrf review.

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LIMITED OFFICIAL USE ONLY IPEEE-Results For Ouad Cities The Quad Cities IPEEE report dated February 17, 1997 indicated a core damage frequency (CDF) of SE-03 for internal fires. The vulnerabilities that contribute to fire risk throughout the plant are: 1) Use of non-lEEE 383 qualified cable; 2) Human factors complexities in the safe shutdown procedures; 3) Use of the opposite unit equipment; 4) Proximity of the same unit redundant division; and, 5) Stripping of circuits'in anticipation of spurious actuation. The licensee states that these potential vulnerabilities neither impact the plant's compliance with 10 CFR 50, Appendix R, nor indicate that the plant has operated outside its design basis or technical specifications.

However, as a consequence of the CDF for internal fires, Quad Cities has implemented an Interim Alternate Shutdown Method (IASM) at Unit I and will implement it nn Unit 2 before the unit returns to power after its present refueling outage scheduled to end on May 5, 1997. The IASM implementation changed the CDF from SE-03 to 9E-04. The licensee has also implemented administrative control improvements in recognition of the vulnerabilities relating to the status of the o)posites units equipment. The risk reduction task force at Quad Cities is scleduled to provide a recommendation to plant management on a safe shutdown simplification plan and resolution of other fire protection issues by November 30, 1997.

As a result of a meeting with the staff on March 31, 1997, Comed was requested to provide its rationale and basis regarding why it is acceptable to wait until November 1997 before coming to resolution of the IPEEE concerns at Quad Cities. The licensee provided their response in a letter dated April 14, 1997 which is currently under staff review.

The staff will complete a more extensive review of Quad Cities IPEEE by proceeding with a L.evel 2 evaluation. However, the staff has scheduled a fire protection visit for April 29 and 30, 1997 to look at various fire protection issues developed from the IPEEE report. The team will look at the fire hazards analysis, review the exemptions that effect the fire protection program and tour the vulnerable areas in the plant.

The licensee stated that similarities between Quad Cities and Dresden include the use of non-IEEE-383 rated cables and load stripping following a significant fire. Differences include reliance on an isolation condenser for safe shutdown, low reliance on opposite unit equipment, extensive automatic suppression coverage and the use of non-combustible cable coating and cable wraps in key areas.

Although there are some differences between Quad Cities and Dresden, the licensee was requested to provide a letter discussing why Dresden does not have the same fire protection vulnerabilities as Quad Cities. This letter is to be submitted shortly. Dresden is scheduled to complete its IPEEE evaluation by August 30, 1997 and submit the report to the NRC by December 31, 1997.

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. LIMITED OFFICIAL USE ONLY Emeraency Operations Facility (EOD l In February 1996, the staff approved the use of the corporate EOF in Comed's headquarters at Downers Grove as an interim EOF until the nearsite EOF is activated. Because the corporate EOF is more than 20 miles from any of the 1 l_ Comed sites, Commission approval was required for the change. The licensee '

now has requested approval to consolidate tiie nearsite EOFs into one single EOF located at Downers Grove. Approval of this change, if recomended by the staff, will also require Commission approval. l Use of Mixed Oxide Fuel Comed, in partnership with Duke Power, has responded to DOE's request for expression of interest related to the reactor option for disposition of excess plutonium as mixed-oxide (M0X) fuel. Comed has proposed using Byron, Braidwood, and LaSalle as sites for use of the fuel. Comed / Duke have aligned themselves with France's Cogema to study the burning of plutonium in PWRs and with British Nuclear Fucis to study burning M0X fuel at LaSalle. DOE has issued a fiaal Programmatic Environmental Impact Statement and i Record of Decision regarding its preferred method for disposition of plutonium.

Provided it is accepted by DOE, Comed plans to participate in t test program

. followed by the use of M0X fuel at its sites. If Comed uses fuel fabricated in Europe, they indicated that testing of a lead test assembly could occur as aarly as 1999.

The NRC staff has informed the industry that the use of M0X fuel in a commercial reactor will require staff review and an amendment to the license.

In addition to the normal safety analyses, licensees will have to address the sufficiency of the methods used to predict performance of M0X fuel, poter,tial for interactions of M0X fuel with low enriched uranium, and methods to identify and respond to anomalous performance of the M0X fuel, Resoonse to NRC's 50.54(f) letter on Desian Basis Commonwealth Edison responded to the NRC's October o. 1996, 10 CFR 50.54(f) letter on adequacy and availability of design basis information by providing a separate response for each of its six stations. The responses are being reviewed in a four phase process as described in the ED0's February 25, 1997 memorandum to the Commission. Phases 1 and 3 were completed for all of the Comed stations. Phase 2 was a pilot review for each Region and did not invcive a Comed station.

In phase 1, the NRR Project Managers reviewed each of the responses for general completeness and concluded that no additional information was needed at the present time. This view was confirmed, but qualified by the Phase 3 review in that the responses to item (e) from the 50.54(f) letter on oveiall effectiveness generally lacked specifics. Further, the schedules and details of proposed design reviews that were expected to be completed in 1999 were not provided. Comed's responses also referenced other documents which, because of the short turnaround time for the Phase 3 review, could not be reviewed in depth, i

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LIMITED OFFICIAL USE ONLY Highlights of the Phase 3 review for the Comed stations are as follows:

. In general, Comed responded in a non-detailed, higher tier fashion by dcscribing the processes and programs for maintaining and accessing the design basis at each of the Comed stations. This approach was similar to the responses from all other Region 111 utilities.

. For all stations, Comed concluded their processes and procedures were sufficient to maintain the design and licensing 5 asis. The responses, as was typical for all Region III licensees, generally cast events, findings, and information describing problems with the above conclusion in as favorable a light as possible. In general the review teams for each of the Comed responses identified some statements that appeared very broad or were not totally consistent with some NRC inspection findings. As a result, the Phase 3 review teams struggled with whether they could totally agree with Comed's conclusions.

4

. On the other hand, Comed's responses were more straight forward in admitting to difficulties with the effectiveness of some of their processes and procedures for maintaining design and licensing basis than were the responses from most other Region III licensees. For example:

LaSalle stated, "...we currently conclude that the existing design and configuration control processes are adequate if implemented properly.

However, our confidence in the effectiveness of past management and implementation of these processes has been reduced by the deficiencies we have encountered..."

1 In the cover letter, Zion's response stated, " Zion Station has taken additional action to strengthen two fundamenta~. areas identified as weak in recent internal audits and NRC inspections, i.e., the timeliness of implementing corrective actions and the effectiveness of the corrective actions in preventing problem recurrence." Further, in the executive summary, the response sta^ied, "...we have identified specific weaknesses in the adequacy of safety evaluations to support the 10 CFR 50.59 process."

. Comed has developed corrective actions for many of the above noted issues with quality and access to design bases information. These actions are described in two letters from T. J. Maiman (Comed) to A. B.

Beach dated November 12, 1996 and January 30, 1997.

The actions described in the above letters contain several commitments; however some of the specific actions vary from station to station. In general, however, actions being taken include: the validation and reconstitution of critical calculation information; the further development of design basis documents (primarily for the older stations); and, the verification and validation of design information in the Updated Final Safety Analysis Report.

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Chkno.ILNY M 6*

March 28,1997

! U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Subject:

Braidwood Units 1 and 2 (NRC Docket Nos. 50-456/457)

Byron Units 1 and 2 (NRC Docket Nos. 50-454/455)

Dresden Units 2 and 3 (NRC Docket Nos. 50-237/249) '

LaSalle Units 1 and 2 (NRC Docket Nos. 50 373/374)

Quad Cities Units 1 and 2 (NRC Docket Nos. 50-254/265)

Zion Units 1 and 2 (NRC Docket Nos. 50-295/304)

! . Commonwealth Edison Company's (Comed) Response to the U.S. Nuclear Regulatory Commission (NRC) Request for Information Pursuant to 10 CFR 50.54(f) Regarding Safety Performance at Comed

References:

(1) H. Thompson letter to J. J. O'Connor, dated January 27,1997;

" Request for Information Pursuant to 10 CFR 50.54(f) Regarding

. Safety Perfortnance at Commonwealth Edison Company Nuclear Stations."

Dear Mr. Callan:

I am writing tn you in my capacity as Chairman of the Commonwealth Edison Company and in response to the NRC's letter ofJanuary 27,1997. liithat letter, the NRC requests:

A. Information explaining why the NRC should have confidence in Comed's

, ability to operate six nuclear plants while sustnining performance improvement at each site.

B. Criteria that Comed has acabli=hed or plans to establish to measure .

performance in light of the concerns identified above and Comed's proposed actions if those criteria are not met. .

I know that our response to these questions will ecly be credible if we have critically mminad ourselves in providing the answers. hi% from the day we received this letter, we have engaged in a searching and challenging dialogue across the company to provide ourselves with the assurance that we can respond completely, accurately, and

confidently to the request. Our recent operational event at Zion Station unfortunately serves to reemphasize to Comed, the NRC and the public the challenge that faces our company in rimning our nuclearplants properly. We believe that we can do this. Yet, we recognize that the er==icancy and pace of our improvement efforts in recent years d

have not been what we intendeA or Pf 4

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' " As"the Commission is keenly aware, we have in the past presented plans for performance l

improvement. Those plans were keyed to people, resources and programs. and our plans .

of today, too, are dependent on people, resources and programs. Where the people were

, .. not right, they have been replaced. Today, we have' assembled one of the most

! experienced nuclear management teams in the country. Where additional resources are j ==M they are being provided. Where programs have not worked, we are changing

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The activities being undertaken to improve Nrformance' at our six facilities are explained

! in this cover letter, detailed in the appended attachments, and or- ai'ad in the following

! manner: a statement of the problem, which addresses those issues raised by the j ,,

Cc==i taa in its 50.54(f) letter, an executive summary of the major actions we have

" . undertaken or will undertake to address these issues; a detailed explanation of the j

initiatives being pursued throughout our company to improve performance; and a ,

! description of the performance indicators and criteria that we plan to use to mea:ure our j performance, and the actions we intend to take should the criteria not be satisfied.-

j L Senne of the Prehlem - OveHeal Perfar== nee l

. To begin, we fully accept the criticism that the performance at several of our plants has j ( been unacceptably cyclical. We are deeply disturbed that as of this date three of our sites (Dresden, laSalle and Zion) are on the NRC's Watch List. More recently, a significant l

operational event invohing reactivity management occurred in the Zion Station control room. These problems understandably diminish the success we have experienced in other aspects of our nuclear program. Byron has experienced excellent overall performance.

4 Bmidwood is also a good performer. Quad Cities has shovm improvement through a i three year Course of Action improvement initiative that began in early 1994. Dresden j hac also shown steady improp through the Dresden Plan.

i L At tne same time, we understand the scope and severity of the challenges we face today.

l . We recently completed a w-y.J.sive, critical, and hard-hitung asse ,sment of our

performance at the LaSalle and Zion Staions. The Independent Self Ae**== ment Team l

(ISAT) was --ydeed of senior industry experts and -a-meau by Insticae of Nuclear i .. Power Operations (INPO) personnel and utility peers. We presented the results of this

self-namination to the NRC and the public. The openness and candor of this self-

===i nation i is unpe=ad==M for our company, yet we felt that it was necessary to l

i provide a sacas foundation for future . " .y.-st.

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! Collectively, the NRC's criticism in its 50.54(f) letter and the laSalle and Zion self-

===ia=riane concluded that we need to: seengthen management oversight ofour

) nucler operations; enanianantly apply the necessary resources and management attention

' to each of the sites to ensure successful completion of our improvement plans; enforce I

l high mandards for nuclear performance, particularly in the areas of operations, i

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i engineering, and corrective action; and communicate and internalize the experiences of l other nuclear facilities within the division, as well as those outside the company.

, l In this regard '.aany actions are underway to improve our performance. Much of this change began in 1996 under our current senior nuclear leadership team and was already being implemented in January 1997 when we received the NRC's letter. Other actions have been initiated since the letter wa's received,invohing every level of the company starting with the Board of Directors and extending through the entire organization and our  :

l workforce. These actions are designed to take advantage of Comed's size and resources -

to maximin safe, reliable operations at all of our stations. ,

II.

, Executive s===.rv

,' . A detailed description of the critical initiatives that we are undertaking to improve the performance of the Nuclear Operations Division (NOD or disision)is set forth in the

.' remainder of this letter. We know that significant improvement in the performance of our nuclear operations is necessary. We cannot serve our customer and public constituencies in the rnanner which they expect - nor can we meet our responsibilities to our .

shareholders - without a safe and efficient nuclear operation. ,

I would. characterize the challenge facing our nuclear program as a turnaround effort, j ,

I am, however, encouraged by the progress that we have made to date on a number of fronts and am confident that the actions articulated in this letter will sustain consistent improvement and lead to superior performance across our nuclear program. .

In this regard, I would like to higMight the essence of our performance improvement

, programs. Our six critical strategic priorities are to:

i .

e Strenathen Overkieht ofNOD Activities-Our Board of Directors

bas approved a strong charter for the Nuclear Operating Cemittee. This Comminee will provide an independent and challenging assessment of our nucleaf operations on a continuing and critical basis.

,,- e inewenee Financini R*=nurm - Management and the Board have ,

W=.ntially increased the fin =ncini resources dedicated to our nuclear program. The $1,028 million expense budget for fiscal year 1997..y.- an increase of approximately 28% over the original expense budget approved in 1996. Management will .

cantime to review initiatives to ensure that the necessary financini insources are available to -.yyan im e vis.est.

e Fmedite Comorate Fune tinn=1 Sunnart - Critical corporate 4

functional areas, includmg Supply Management, Information Services, Human Resources, and Cow.m Security have altered A Unume Casapiny i

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their work processes to streamline and expedite the support of our

. nuclear program.

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. . Sunnnet the NOD Marmoement TgED- We have a highly- H

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experienced senior management team already in place at the sites j .

and within the division. Our eh*11-aae going forward is to support l l . . this team with additional resources in critical functional areas - '

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< r., engineering. .

. Imarove cmss Diviatan.1 h. ..= and Pmcesses - A number of eNorts are underway to substantially =nhanne the sharing of i -

exnerierce ar.d infonnation across our sites, perhaps the most

! ', important of which is the Peer Oroup offort that was launched in 1996. '

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[' . Fnforce Rionmus Standeds of Perinrmance - The continuing j . evaluation of our performance against industry standard and Comed speciSc performance measures is critical to the ongoing

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l' assessment of our pro;;ress and achieving superior performance.

I  : With that as a general background,1 will now describe the actions that we are pursuing i

across our company to meet our objectives in these six critical areas.

f E]. Actions to Sunnart Iannreved Nuclear Perfor==nce 1

The company is mobilized in support of the efforts to improve nuclear performance.

We have had constant communication throughout the company cn the importance of the

,. NRC's request and our response. Wu are focusing on reinedying not only the problems at i , individual sites, but on improving our overall nuclear program and na=ining that l improvement. We imend to make our nuclear program a benchmark for excellence in safe, reliable plant operation and we recognize that action from the very top of the corporation is necessary. The Board ofDirectors and Comed senior management will ensure that necessary resources are made available to achieve success. -

A. ne naard orni earn mad its Nudame Oneratione r'ammin.,

Simply stated, the safe and effective perfarmanaa of Comed's nuclear program is our single highest priority. As chairman of our Board ofDirectors, I fully accept the ,

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seriousness of the company's current nuclear challenge and will ensure that appropriate

! changes occur.

Last fall, we elected a new Board member who was formerly the director c,f the Naval

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Nuclear Propulsion Program for the Navy and the Dwi-cat of Energy. In February j 1997, he was appointed to serve as Chairman of the Nuclear Operations Cn==ittee j .. (Committee) of our Board ofC2m He has devoted a significant amount of time to

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• 4 visiting a!! six of our stations and ga.aing an understanding of actisities within the '

, division. . Another individual with extensive nuclear Navy expuience has also been added j ' to the Committee. We believe tiat the addition of these talented individuals to the senior -

1 oversight group for our nuclear prograrn will produce substantial benefits for the company, particularly given their collective experiences in managing large nuclear i

programs Senior corporate oversight of nuclear activities is provided by Comed's Chief ,

l j - Executive Officer, President, and Vice Chairman, who are also members of this l Committee.

To anh=ana the role ef this Committee, the' Board approved a formal charter in February i that clearly establishes its W, directs the Committee to provide aggressiu l oversight of Comed nuclear perfannanna and requires the Committee to keep the Board

. apprised of safety, performance, and resource allocation issues. To ensure sufficirt

! . involvement in nuclear activities to carry out its charter, the Committee has estakshed l an office in the Nuclear Operations Division executive area and assigned an experienced l full-time engineer to that office representing the Committee. This ..yn.watation will

. provide the Committee with a vehicle to independently gather information and to observe 1 the imprevement progrrais that are being developed and implemented at the plant sites.

The Committee will also continue to ensure that the Board receives timely and

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.. independent information conceming the nuclear program, and that line management is

[ held accountable for meeting targeted performance levels.

f The Board's active oversight will ensure that the nuclear program has the resources it needs, as well as the managerial capability it requires to achieve its objecti ves. In March j 1996, the Borid approved suostantial increases above the budget for both operating and l maintenance expenses and capital evn aditures. In 1996,it also approved changes in the i senior management leadership of the division. In January 1997, the Board approved a i .. substantial increase in nuclear operating and m@tenance expenses for this fiscal year.

l- However, in the end, the key to improving our nuclear program rests with effective j -

execution in the nuclear division itself, coupled with appropriate resource ===ietanea from the corporation.

l B. Resources t

The Board has mMny increased resources for the nuclear program. During the l carly 1990s, budgeted funds were allotted awt heavily toward sites perceived to have the

greatest current performance challenges.1 hough the m ' tent was to allot each site enough i

resour:es, as we have gained experience and assessed our performance, we hav:

d termined that more resources are necessary at all sites. In early 1996, the Board .

{ increased the initial 1996 expense budget of $402 million by more than $70 million. The l Board took this action in order to ensure that Anancial resources would be sufficient to

! support improvement initiatives at each site. Later in the year, =p-ading inci wd an

additional $54 million and ultimately totaled $926 mLn for the year.

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! The Board expanded this support for fiscal year 1997 approving a $1,028 million expense

, budget, an 11% increase over 1996 expenditures. The Board intends to proside a similar l

l level of funding in 1998 to fully resource the operation of the company's nuclear ,

l program. The Board approved these increases based upon management's l 4

' recomm-= Mons following review of the needs of each site for ongoing operations and l l , improvement initiatives. The Board is determined to ensure that all of our nuclear sites and supporting or==aintions will have the naesetary resources to sustain improvement.

' Even as Comed is addressing these ismes, deregulation is approaching the electric utility j . ,

industry. Cmaati ion t is W_ to be particularly intense in the area of generation.

We expect the low incremental costs of our nuclear power plants to be a decided b=iaad ,

l advantage to us. Low cost, however, can only be achieved where plants are operating

safely and ~=' - 9. As part of our efforts to meet the challenge of deregulation,

• Comed is examining its assets, particularly generating assets, with a view toward f , , ,

• , evaluating their investment and operating costs against their abiliy to contribute to the l

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revenues of Comed. This analysis could result in the early retirement or closure of one 1

or more of our nuclear plants. We must emphasize, however, that the plants we continue l 5 to operate will be operated in a superior fashion, fully resourced to ensure safe, efficient l -

operations. .

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! C. Cormrate Emert '

4 All parts of our company are seeking ways to support the nuclear division's improvement l

l initiatives. The company is strammlining the procurement process and providu g j additional information-pr==ing support for the nuclear division. Other areas of the j l company, such as Human Resources, Finance, and Coq.oi.m Security, are committed to providing the support necessary to assist in the effort, ,

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• In an effort to expedite work, the supply management organization is working closely i with the division to further the timely delivery of quality goods and services for each plant. A team of managers is refining the process by which goods and services are acquired for the division and designing a supply and inventory process. Additional '

, supply management gre d are being hired We plan to provide each site with procurement personnel supported by dedicated off-site material pt ing, logistics and l .

! order controlpersonnel. ,

! ' ' The information services group is increasing its staffing and adapting company-wide processes to serve specific needs of the division. Infan==&m services is also taking steps .

to ensure that the sites beve adequae support for the computers and software and to address specific concerns raised by the division. Finally, the infonnstion services group is working with the divisien imd other areas of the company, including hum:n resources,

I finane*, supply management and cargarate security,in an effort to identify and prioritize

' the system enhancement < that these groeps have requested in ordc. to better support l '

nuclear operations.

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, D. ' Nuclear Onerations Division Activitiet

• Management Team -

. Our first priority has been the creation of a strong and experienced management team l with proven ability in successful nuclear program management. Prior to 1992, Comed

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generc.!!y developed its senior nuclear management personnel, both at the sites and in the o

! division, enm within our company. In 1992, we began to recruit outside personnel for l .

both our Noa and site management teams. During 1994-19%, we recruited outside

! .- . nuclear expertise to the management positions of Vice President Ka-ia=* ing, Vice President-Nuclear Support, and Vice President 4)eneration Support, as well as several i

she executive positions. These steps were taken to ensure strength in key positions as well as to benefit imm the experience and best practices of nuclear programs outide of

.. twara j We scelerated this edort in early 1996, with the appointment of a Chief Nuclear l '

O,.: rating OfScer with experience in overseeing nuclear stations at two other nuclear j utilities, including experience overseeing multiple nuclear plant sites. Our nuclear

. executive team has substantial experience outside of CnmFA in both plant turnaround

situations and in r iaine strong performance. *Ihe Site Vice Presidents at all of our sites have had signi6 cant experience at vmsl nuclear stations or at the Institute. of i -

Nuclear Power Operations (INPO). Below the Site Vice President level, we have taken .

similar steps; for example, in the past two years we have placed experienwd Plant j Managers from outside utilities at four of our six stations. Similarly, experienced individuals have been assigned to the Malawamace, Fa-ia== ing, and Radiation

! PAtion organizations. . .

While we will continue to critically evaluate our management teams and make further i changes as &='y, we now consider these tasms capable of achieving re='aad performance improvement. Recruitment of this acasoned managerial talent brought fresh perspectives, higher standards, and the insight that adding experienced leadership alon:

would not be sufScient to efect =~ia-ful change. As gaod as these managers are, they _

are -==rily limited in number and the scope of activities they can dimetly ia==a j-

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Stronger suppocting systems are needed to sustain continued improvement across multiple sites. Thus, our M- ssi cEorts as described in this letter and its

=n=chment seek to balance the beneSts oimaman cross-site principles, sharingif j information, and measuring techniques with the need for stmng local leadership and

! accountability at the sites. -

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Enn-e-ine the L'd a_ L-- -----I Md- - r.' mad Temiaiae i

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We know the workforce's support of our improvement programs is essential to success, I

i Good communications and a beuer working relationship throughout our workforce will 1

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' "be an important part of this process. Senior management is placing greater emphasis on

) gaining workforce ownership of Comed's performance improvement iriitiatives.

We are communicatin2 to our employees through meetings, videotape presentations. and letters from executive management to ensare that they are aware of our current situation

! .. and our plans. Our ChiefNuclear Operating Officer, during his monthly Management Review Meenng: at the sites, has diWons with groups of 15-20 employees regarding l

our plans, issues of coricern, and steps for improvement. These meetings are intense, i open and productive. We also established a communications organization in the division l in 1996. With communications aparialiste at each site and with costdination by a.

! division communications director, common processes are established to share I ..

information on key issues, challenges, and improvement progress.

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". Other actions are designed to strengthen management skills and to engage the workforce

! in improving performanc'e throughout the division. These actions include: upgraded

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management development, selection, and succession-planning processes; first-line supervisor skills and leadership training; and expanded workforce skills training. The

) nuclear division is also utilidag a broad strategy known as Engaging the Foryorce, j . . This strategy allows teams of employees and managers at all levels throughout the

! division to actively participate in solving' problems, improving work processes, and

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! maintaining the performance improvements acrou the division. The objectives of the l Engaging the Workforce strategy are: to obtain overall improvement in existing work i

processes; reinforce a common language for improvement at each site; ensure that decisions to change work processes are fact-based; and maintain or accelerate the pace of change.

We have taken actions to improve communications and tlErtlationship bgaw management and the bargaining unit. Senior NOD and bargaining unit leadership meet periodically to develop mutually sponsored messages for the workforce conceming the j need for continued i-ywwasn. Managers and supervisors who interface with bargmining unit employees are undergoing Management Associated Results Con peny

(MARC) training which focuses on basic labor-management and contract melminierration

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• principles to enable them to bener manage the workforce. This training will also foster a more ea==Nent .yywach to resolution ofissues at the sites and across the division.

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4 l u.a..ement inhistives in the NnA.=e Onereiane Diviri9 n i- In March of 1996, we began a auries of maior NOD ananagement workshops to build a .

l shared view of the impovements neem in1be division. A key outcasne of this process

! was the remmemmian that safety naut be our primary focus. CamEd's senior nuclear j management team has the shared belief that a culture that values safety Srst will achieve 3 l the other business requirements ofpoduction and cost.

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j To optimize the leaming and pace ofimprovement across all six sites, we have i

established a Peer Group process. Groups of representatives from each site End nuclear division headquarters are assembled into Peer Groups to develop and implement safe, i effective, uniform processes and practices at each site. The Peer Group approach l

'- povides an opportunity for ,y . i.iives from the stations to lead, and be responsible for the performance ofprocesses across the division. Each peer group is sponsored by a

..~ senior nuclear division manager, Peer Groups provide division management with a venicle to implement site-initiated commonality across all nuclear facilities. Peer Groups

! have been er.ablished for Operations, Work Control, Outage Management, Con 6guration'

' Control, Equipment Reliability, Training and Management and Administration. Other functional workgroups are focused on improving particular work practices within the l ~

I division.

j - Also in 1996, we began to implement a more common approach to planning at our nuclear sites with a focus onbeds participation by the workforce in the pinnaing l .

process. Each month the Chief Nuclear Operating Officer conducts Management Retiew

! Meetings at all sites. These meetings focus on safety performance and the effectiveness

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ofimprovement initiatives. Site management reports on the implementation of their plans with an ==ahads on accountability for achieving performance results. These meetmas serve as a vehicle for senior division management to ensure that improvement

! l continues at each site They also enhance cross-site commonality, communications, and safety focus. -

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Fncineerino -

4 l Another key area being aggressively addressed is engineering support within the division and our nuclear stations. The nuclear division's engineering organization has become the primary source of engineering support for Comed's nuclear power plants. During 1994-1996, Comed increased the complement of engineers supporting our nuclear i

program. Moreover, design au:hority and design records were transferred from contract design engineering organizations to C FA on-site design engineering capabilities were mereased, and we are developing a series of common engineering ga and ,.

i procedures for the division.

!- In November 1996, in response to engineering shorea-i== noted at several of our stations, including the. results of the NRC 1Pt Safety la-* ion at Dresden and the NRC Fri= _ Jug and Technical SupportI a-*3cm at Zion, we initiated a broad set 1

ofinitis.tives to ensure that each of our shes has high quality engineering support to

. ==in*=in the facility design bases. F=pr Q Assurance Groups were formed at each she to improve the quality of design and technical work, with 'me foca on i maintaining the design bases. We also initiated a series ofieviews of safety sym that j include verification of conformance to the Updated Final Safety Analysis Report

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l requirements at each of our stations.

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. Our efforts to strengthen engineering support continue. Earlier this year we developed a L . set of objectives to improve engineering support during 1997-1998, We established specific plans for accompli =My each objective, along with milestones and performance measures for gauging prognes. Key objectives include

providing engineers with ready access to up to da:e design basis information; making our engineering groups proactive j in fmding and wQ problems and self critical in evaluating performance; l . . strengtheninE engineering oversight of site and contractor engineering i' '

simplifying engineering processes while strengthening controls over those processes; and

!- . strengthening the management skills of each of the site engineering organizations. Other objectives involve backlog reductions, improvements in system / component enginsedag, and management oflarge engineering projects.

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L , Actions we are t& king to achieve these objectives include: development and validation of i . , @A design and licensing basis inforpior.; reconrtitution of key calculations; j -

.. training on engineering topics arid processes; and implementatior. of new oversi& ht j -

. mechanisms. Many of these actions are described in greater detail in our January 30, j' '

1997 letter to the NRC on design basis information. We have made, and will continue to

, make, substantial commitments of financial and personnel resources to accomplish these l

objectives and ensure that strong engineering support is provided throughout the nuclear progran. '

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l Corrective Action Prnemt 1

l Corrective actions in the past have not always been fully effective and the quality of l corrective actions has varied among sites. A revised cormetive action program is being i- implemented at the sites and throughout the division which. ensures a more common i

approach to identification, internal communication, and solutions to problems that are j .

. identified within the division. This program was developed by the NOD organization and

! repm*=ives of all six sites. This program is based upon our review of ==~ -esful j corrective action programs in the industry.

! Under the revised program, thresholds and processes for problem investigation, root l cause analysis, and trending are being made uniform for all sites and in supporting

!- activities within the division.1he new program includes a human armr reduction

) methodology that utilizes problem identification, coding, trend analysis, and root cause

! analysis techniques. To support this new process, groups of root cause and trend analysis l =p-Mie= are being trained for each site and for the division. Events at our nuclear

! .. stations will be systematically reviewed for lessons that can be learned by the other -

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saations. The avised correenve action process for the nuclear division and performance l nnessures to gauge the effectivuosas of the new program will be in place in 1997.

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Audits and Amtettmente

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%e are strengthening our audit and assessment capability by developing a formal division-wide audit and assessment function. The division's audit and assessment l .

, schedule will be adjusted to include areas ===Ang improvement as highlighted by actual l perfonncoce issues (e.g., performance indicator trends) as well as industry concems. Our j . process will ensure that m'ulti site trends and lessons learned from each site are

. recognized and acted upon throughout the division.

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i E. Individuni Rite Actianc ,

i j Our actioni go beyond the programmatic changes and modification of the supporting j -

functions described above. We remain committed to pursuing the site speciSc actions

.. necessary to demonstrate tangible improvement. For example, we are standardizing the 1

' business planning process and are using site operational plans to drive key improvement

.. programs. Each site has established site performance indicators and targets which

' measure progress and determine whether targeted performance is being achieved. Each

! of the sites is currently reviewing the " causal factors" found to be applicable from the 4

Zion and LaSalle ISAT Reports to incorporate .yy. ,ydate actions into plant processes and progans.

We also are strengthening site self assessment. All assessment and performance

! ' monitoring organi7mtions at each site are being realigned so that they report to a senior i

- quality manager at each station. Site-wide and departmental self assessments are being

! established which requin each dry huent to assess its performance. Using these i programs, each der cut will drive toward continuous improvement. We are l expanding our corrective action programs and have created 's cer v ei.ie corrective actions i

group to monitor events within the industry and at other Comed stations ao that effective j _

corrective actions can be taken to avoid futur problems,

IV. Perfor== nee Indientars and criterin to M enre Achievement

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The NRC's 50.54(f)lete requested that we define the criteria we will use to measure performance and identify proposed actions in the event that those criteria are not met.

! C~aF4 has used a variety ofperfarmans measures and oversight M=ni=== to gauge perfonnance at its nuclear plant sites, but there has not bec w ~= ia-ey berm -

! measmes used at sai site and in the division. As a resuh, differences in performance

! quality and trends have not always been clearly apparent. In response to your letter, we j .

have focused our efforts oc developing ~an integrated structure of performance indicators, i creating targets or criteria for these indicators, and e '* what actions may be j appropriate should the critaria not be satisfied.

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i As a first step in achievmg supenor performance, we have adopted a goal of operating i

1 cach of CanF4's facilities at a level better than the average of our peers in the industry.

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I l We plan to utilize a combination of the NRC's Office for Analysis and Evaluation of

. . Operational Daa (AEOD) performance indicators and those tren: led by the World l Asr.ociation of Nuclear Operators (WANO) to determine when we have accomplish:d j this goal. We expect to achieve this haal by the year 2000. The industry standard p . indicators that we are monitoring to assess our progress in achieving this goal include:

automatic scrams while critical, safety system actuations, collective radiation exposure, l ..

i

. unit capability factor, unplanned capability loss factor, safety system performance, and industrial safety accident rate. We have defined criteria that specify he level of i performance we expect to achieve for each indicator. These indicators and the crite-ia

. - ' will provide a valuable ame*==maar of overall station performance. ,

i '

, We have also adopted indicators which mo.e specifIcelly measure the progress of the

! division and indiiidual nuclear sites in daia: impmvement. These NOD-wide j , , ,

performance indicators focus on the areas of operations, maintaannea, engineering, and i .

corrective actions. These indicators will permit us to direct our resources and j -

, management attention atidentified w-ahw*=, and will demonstrate whether -

j ,

improvement is being sustained at each of our stations. We plan to discuss the criteria for the NOD-wide performance indicators in our April 25,1997 meeting with the l

Cammission. We recognize th*t, as we gain more experience with these indicators, we i '.'~ may be required to adjust their definitions and criteria.

The Nuclear Operations Committee will be provided with the industry standard and NOD-wide indicators. He Committee will also monitor other indicators it deems

! appropriate to ensure full understanding of performance trends. The sites will monitor the industry-standard and NOD wide performance indicators in a conshtent manner that

. allows comparison of performance across the division. Each site is being allowed to j' develop its own set ofindicators based upon specific site needs. Our utandardized

! . performance indicators and assoristed trending will provide systematic, formal, and l w.oyhosive oversight of the nuclear program and, most importantly, will clearly j indicate whether or not we are achieving results (Le., improvements iu overall plant

anfety). -

i We will monitor the hsusty standard and the NOD wide indicators on a monthly basb

. to ensure that our performa = criteria are satisfied. As described in Section 4.7 of the l ' Aad should we fail to. satisfy any prformance criterion, the Chief Nuclear l CW. Jog Officer (CNOO) will review the actions underway to determine what additional efforts may be wammtad. If our performance is not made to conform within j two arAs, station management will develop a written action plan to be implemented l unde <c the oversight of the CNOO. ' If performance caatinnae to lag, the Chief Nuclear Officer (CNO) and the CNOO will establish a special team to identify causes and j recommend responsive action. The CNO and CNOO will direct the division to take

appropriate actions such as

implementation of special oversight or management

observation programs, special action plans, work stoppages, and other actions which we i

believe can :-==an=hly be -- +=d to improve performance. The Nuclear Om. Jog l

A Uammen Campany l

,,, -- , .-m-. _ -. y- --- , , ,. w- ev %

L. b. hu bar Krpu& lory Commission March 28,1997 Page 13

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Committee of the Board, including the Chairman and CEO, will also be informed of ongoing actions and may direct application of additional resources and increased management anention. The recent decisions to undertake structured restart readiness programs for the LaSalle and Zion Stations da-Smne our detennination to take the necessary actions to improve perforramare in all cases, the overarching concem will be rJe nuclear plant operations.

CONCLUSION We have the apability to sustain =*iannus improvement through the combination of people, nsources, and initiatives that are underway. The Byron and Braidwood units will continue their good perf==are and take advantage of the beneSts that accrue from cross-site sharing ofinfennaden and knowledge.1be Quad Cities and Dresden Stations have made progress, and they will sustain their improvement trends through focused management attention and the application of nar**==y finmaci=1 resources. The LaSalle l .

and Zion Station management teams understand the depth of their problems as a result of

,,- their rigorous independent self assessments. laSalle's engineering issues will take time to correct and, thus, its progress must be measured over a longer period. Zion faces considerable challenges as highlighted by the ISAT Report. The plans and actions m y to address these problems are being developed and aggressively implemented.

Our entire company recognizes that we can succeed only if we restore the conSdence of the NRC and of the public in our nuclear capability. Our Board of Directors knows this.

Our officers know this. Our employees know this. We have committed substantial resources to the nuclear division and have recruited the best nuclear managers we can identify. We are confident that our people today, coupled with financial commitments and clear planning, can produce the results that are necessary: safe, well-run nelear plants at all of Comed's sites. ' We are fully comnthted to take those actions necessary to .

assure the safe performance of our operating nuclear facilities.

~

- We look forward to answering your questions rerd!ug this letter at our meeting scheduled in Washington on April 25,1997 or at any other time you may desire.

Sincerely, l .

b e i ..

Jamesi. o'Connor ca irman and ChiefEs.cmive osseer i

U. S. Nuclear Regul?'m/ Commission M arer 'S,1 M '

1 1 i I i

i -

.. STATE OF ILLINOIS COUh"IT OF COOK l Docket Nos. 50-454 50-455 i 50-456 50-457

50-237 50-249 l .

.. 50-373 50 374 50 254 50-265

., 50 295 50 304 4

IN'THE MATTER OF i

,. COMMON %TALTH EDISON COMPANY i

i I

AFFIDAVIT

I affirm that the content of this transmittal is true and correct to the best of my knowledge,information and belief.

9 /

• • k dwn lW emf")

I

. gairman/ames and ChiefExeodveJ. O' Condor OfBeer Commonwealth E4 son Subscribed and sworn to befom me, a Notary Public in and l . for the State and County above named, this ATI4 day of

, AeA .19 97 . My C=midon expires on

ale >m Jt 19 9 / -

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t taMilA A. LEIN IIstry Pdes,esas af Ebals ,

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U.S. Nudear Regulator) C:mmission March 28,16i f

l '

Enclosure:

Comed Response to NRC Request Pursuant to 10 CFR 50.54(f) i ec: H. Thorrpson, Deputy Director for NRR

.. .. A. Beach, Regional Adminisaator RHI

.. R. Capra, Project Directorate 'NRR .

R. Assa,Braidwood Pro 6ectManager NRR

.. O. Dick, Byron Project Manager NRR

, . J. Stang, Dresden Project Manager NRR

,, D. Skay, LaSalle County Project Manager NRR R. Pulsifer, Quad Cldes Project Manager NRR C. Shirsid, Zion Psoject Manager NRR Braidwood, Senior Resident Inspector Byron, Senier Resident inspector ,

Dresden, Senior Resident itspector 14alle. Senior Resident inspector Quad Cities, Senior Resident inspector ..

Zion, Senior Resident inspector Of6cc of Nuclear Facility Safety IDNS g.

8 e

N

" A Unkom Company ..

ATTACEMENT f CoasEd Response 2 NRrl g.54(f) R.,weg

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i RESPONSE TO NRC REQUEST FOR INFORM ATION l .UNDER 10 CFR 50.54(0 REGARDING SUSTAINED IMPROVEMENT AND PERFORMANCE CRITERIA l

CONTENT:i

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1.0 INTRODUCDON 2.0 MANAGEMENT TEAM AND BOARD OF DRECTORS 2.1 Nuclear Program Management Team 2.2 Board of Drectors Acsions 3.0 RESOURCES AND BUDOE1TNG 4.0 CORPORATE MANAGEhEh7 OVER$10HT AND STANDARDIZATION 4,1 Identification and Resolution of Pundsmunal Causes of Cyclic Pwformance 4.2 Eagarint she Corporation in Support of Nuclear i 4.3 Engineering Support 4.4 1mdership/ Manager-mt Developnent. Training, and Engaging the Workforce 4.5 Cometive Action Program and Response to Lassons14anud 4.6 Corporate Ovsesight 4.7 Performanet Measwes, Critaria and Actions if Criteria Are Not Met 5.0 SITE ACTIONS TO ACHIEVE SUSTAINED PERFORMANCE IMPROVEMENT 5.1 Droeden 5.2 Quad Cules 5.3 LaSalle 5.4 Zion 5.5 Braidwood 5.6 Byron 6.0 CONC 1.USIONS APPENDIX 1 Correlation of Actions to Causes e

h.

f 4

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4 A'ITACHMENT f CamEd Respean to NRC $4.5d(0 Request

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1.0 DfTRODUCTION

'!his raponse povides the taformatica requemed by its NRC in hs January 27,1997,10 CFR $0.54(O lenar e Comed. 'the rapone disaibw:

1. The desalled basis for samfkhsus dim Comed can continue e miely opermis als nuclear sations while sustaining periceanmes 5;- . -- - as each madon; and

2. The criteria that Caned has estanhed or plans to estabh to measure performance and poposed assions if shoes critaria m not met Comed has had eatensive amions udstway a haprow the performance ofits nuclear program. '! hose accons have included management reorganlaadon, acquisition of esperienced new numagement irtsn outside Caned, Z -- -* of site baprovement plans,and application of additional Anancial venourass. '!he NRC's $0.54(f)lemer has caused the Board of Directors and anscudw management to take addidonal measwes to both accelerate the pace of improvement and ensure that improvement is metained All levols of Comed m involved, from the Board of Directors, through Corporse and Nuclear -

Opernuons Division (NOD) management, to our nuclear plant workforce.

'the actions taken or underway to address the causes of cyclic and weak performance se described in the remainder of this miachment.

• Section 2.0, Management Team and Board of Directors, describes maps enken to suengthen our Corporate NOD management team and the membership and oversight provided by the Nuclear Operadng Committee (NOC) of the Board of Directors.

• Section 3.0, Resourses nas Body;tting, describes actions to increase the amount of resources available to our nuclear program and the budgedag processes being used to ense that resources provided to each site and the program as a whole m sufficient to support sumained performance improvement.

• Secties 4A, Corporate Management Oversight and Standardisation, descrious actions sken or underway to suengthen and standardine key programs and processes throughout the NOD. and to increase the new! of corporate oversight of site performance. This secsion includes discussion of the inchcanors and criteria Comed has established to measure performance and proposed smans if our performance triteria m not met e Section 5.0, She Acalens to Aebleve Sesteined performance lasprovement, describes the action being taken at each of the indivichal nuclear plant sites to achieve susanned performance traprovement. 'this includes chamasion of each site's enanagement team, available resources, signincant improvement tekistives akan and planned through site operadonal plans, and monitoring and oversight mechanisms.

• Seceles 64, Camelusions, aumenarines the basis for confidence that Comed can continue to safely operate all sia of its nuclear mancas while sumaining performance ';r m at each slie, i

2

ATTACHMENT ,

Comed keepense to NRC 80.le(f) Regnant

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Supplementing this anachment is an Appendia ccataining a matru whkh shows how Comed's aedons address each of the causes of cyclic performance idendred by Comed based on review of the Zion and Lasaue M , . - 'm Self Assessmenu (13As): the NRC's January 27.1997 $0.54(f) leser, and the Dresden Independent Safety inspeedon (151) Raport The aedoes desaibed h this anachment and Appendia reDect our cussent activides and pirms and sney be moddbed as cirewnmances warrant.

1.4 MANAGEMENT 17.AM AND BOARD OF DDLECTORS 1.1 Noelaar Program " rt Team Our hrst priority has been the cuadon of a nuclear management team with proven ability in mocessfal nuclear program managonent. Prior to 1992, Comed generauy developed tu senior nuclear management personnel, both at the shes and in the contral NOD omoes, from within the company, ln 1992, Comed

. began m recruit avoide persassel fu both our eeneal NOD and alte management teams, and during 19941996 we brought in outside talent to the positions of Vice Presidsnt . Engineering, Vice President .

Nuclear Support, and Vice President . Oeneration Support, as wou as several site saecutive posidons (see Section 5.0). Hinns these ensemal personnel provided strength in key positions and allows Comed to benefit from the esponence and practices of nuclear mations cuiside Comed.

This effort was soongly accelerated in the Arst half of 1996, when we reorganland the NOD, appointing a new Chief Nuclear Officer (CNO) with broad management esperience within Comed, and a Chief Nuclear Operanng Offloer (CNOO) with emperience in overseeing nuclear madons at two other nuclear utibtles, including esperience overseeing multiple nuclear plant sites. Our nuclear esecutive team has abmantial saperience in bth piant tumaround situations and in mstaining spong performance. While we wiu entically evaluate our new team on an ongoing basis, we now consider that team capable of achieving sumamed performance improvement.

This new management team is providing soong oversight of she activides and is focused on ensuring that our people, processes and equipment support openor performance. To reinforce these principles and answe that performance rendu are achieved, the CNOO conducu Management Review Mastmas (typicauy each memh) al each she.1hase meanngs se focused on salmy perfcemance and the effectiveness of impovement initiatives. Durks these meetmas, NOD esecutive management challenges site management on the adequacy of their plans and reinforces = t-i-h for achievhg performance sendts. These me$ tangs provide NOD eneautive management with informanon on plant performance and are a vehicle for management consol to annse that improvement continues at each site.

The new team is also implementing a broad set of initiatives to bring the level of performance at each of our sins up to the higher mandards enablished for the NOD as a whole (see Section 4.0 below).

2.2 Board of Directors Actions The Board of Duessors bas boooume more actively engaged h ensunns impovements in the performance of Comed's nuclear program. Sims sepamber 1996, Comed's Chainna VCEO, Vice Chairman, and President have been closely involved in oversight of the nuclear program, and have amended the n@ty of the NOC's bimonthly meetmas at each of our sia nuclear plant sites.

1 3

, A'ITACHMENT Comed Response to NRC 84.54(0 Request

[

I since receipt of the NRC's 50.54(f) leser ki January, the Board has revitatued its NOC. M individual with substandal U.S. Navy emperience in managing mundple reactce muts has been appointed to chair the commisse. He is suponed by several other Commines members who lme entensive nuclear management empeneses. In a special acdon, the Board approved a formal Chater for the Canminee which clearly amahlwa the Comedest's ' " , = duecas the Comminee to provide oversight of Comed nuclear pragram perfemance, and requires the Consniuse so keep the Board apprised of safety.

, Lm, md resonce ath issues, as web as ks v6ews on whosher nuclear program management actions se appropriam sid effective.

To fulfill this role, the Bond has duected the Comminee to conduct sin visits, esamine plant material and equipment, meet wkh management oversight groups and othes personnel, and review any Comed Alas, data and repons it) edges noossanry to carry out its function. The Cumminee regulariy reports to the fral Board.

l l De new leadership of the NOC has inesracted with intamal organizadons and ensemal parties to update the Board's inderstandmg of perior ance and regulatory issues. Recent actions have included meetings with senhor NOD esecutives and visits and meetings with management of each of the nuclear plant sites.

In Februry,1997, the Commiase enablished an omce in the NOD executive area, and an esperienced engines representing the Comminee is resident in that office full dme. This representation provides the Comminee with a continuous presence, enhances communication with senior NOD ananagement enables the Comminee to gather informadon b'-; latly, and places k in a position to directly observe NOD esecudve management efforts to oversee and coordmate improved performance at the sin plant sius. The NOC is regessentag the Board in ovwsoning the acdons in response to the NRC's 50.54(0 lener, including denlopment of performance indicators that wiX be used by the Board to track performance of

, the andre Comed nuclear program. De Comminee wiu condnue to answe that the Board receives timely and independent information concerning the nuclear program, and that the line management is held accountable for meeting Board expectadons.

3.4 RESOURCES AND BUDGETING De Comed Board of Director and Corporate snanagement have takan steps to tacrease the resources available to our nuclear program and to establish budgeting processo that enswe each she and the program as a whole have the resources needed to opense safely mal sustain haproved performance.

In early 1996, the Board of Directors kicreased the hidal 1996 budget of $302 million by 570 million Laser in 1996 spendmg was increased by an addidonal 554 million, and ultimately totaled $926 million for 1996, he Board took this assion ki order to answe that Anancial recomtes would be sumcient to support improvement initiatives at each sins. De Board has continued and expanded this support for 1997. In hnusy 1997, the Board approved a fwther increase of 11% over 1996 expenditures. The cannulative effect of these increases has been to raise the nuclear progren budget from $802 mittion at the beginning of 1996 to $1.028 bdbon for 1997, an approsimate 28% increase, he Board approved this increase based upcsi the recomenendadons of the NOC and NOD managenent following revlew of the needs of each alte for egoing operanons and 5,7 m ialdatives, De Board is determined to enase that an of our shes and the Corporam NOD organisation have the resources they need to operam safely while sumaning performance improvement.

t 4

j l ATTACNMENT  !

! Comed Response to NRC as.g4(f) Ragwest J

)

j Comed Corporate and NOD management have enablished a twdgcung pruss designed to ensure that resowce applicadon supports mS operanon and sustained impeved performance throughout om nuclear ,

program. Dwing the early IP90s, budgesed funds were alkwad most heavily towan! skes perceived to .

hnq the grossast cwrent perfonnance chauenges. Though the inunt was to apot each site enough resowces, as Comed has gamed espenence ad ausssed perfemance, we have doesnnised that more  !

l secources are ancesswy, I

t por 1997, at the CNO's sequest, NOD management beschussted sbnuar aussions considered to be top bdustry performers to determine rensmable ranges of sapendases. These figures were then nacreased to

account for the performam sw 9eing Comed's plant shes. la concert, each site developed a budget proposal based upon alte n$ phuy inchuhng the estbanned costs of Qw - bdtindves.

i NOD caseutive managemaWMN J proposed budget based on these effons to Cceparate ,

sannagement, she NOC to the Boro, and ultionssely the fuU Bosni of Dvoctors, which approved it.

Comed wiB consmue to ensare that the NOD and each site have the resources to sumain performance

knprovement.

4.0 CORPORATE MANAGEMD(T OVERSIGHT AND STANDARD!Z.ATION i

2 The new NOD management team is implementing a bmed set of inhiatives which demand cridcal self-j assessment, bring key programs and processes up to improved Corporate wide mandards, and subject site 1 acdvities to strong Corporsie oversight. Lassons lemmed and other informadon wiu be shared and an i hiegrated approach will be taken to solving common problems performance will be gauged by objective results, and spacine performance messwes and cruana wiU be used to menswe progress, in cases where

, performance criteria are not met, a denned set of acnon seps wiu be enken to reewn perfonnance to satisfactorylevels.

}

j In establishing this approach, the foDowing maps have been taken, are underway, or are planned-

• Identifying and resolving fundamental causes of cyclic performance through critical self. t assessment and responsive action (Secdon 4.1). , ,

• Engaging the management and resources of the fuU corporation ki support of the nuclear

! program (Section 4.2).

i e Svengthening and standarditing engineenng support and prograrns both in the Corporate NOD organization and at the sites (Section 4.3),

!

• Improving leadenhlp and management development, training, and engaging the workforce (Section 4.4).

l e improving and standarthsing conective acdon programs and response to lessons lemmed (Section 4.5).

• Espendmg and upgradas Corporane oversight activides (Seedon 4.6).

I i

• Establishing standardiaod performance indic. tors and criteria to measure results and to answe that all sites receive appropriate focus (Section 4.7).

, i j Each of these is d><-d below.

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2 l

j A1TACHMENT l

r CenEd Response to NRC S$34(f) Regeset l

d.1 Identification and Resolados of Fundamental Causes of CycEc Performance l.

! Caporate NOD management is requirhg critical self assessnents and responsive aedon to address

! fodamental cannes of performance problems. In the fall of 1996, the CNO commissioned a cornprehensive IS A of perfemance as l4Salle and Zion Stadens.1he independsat Self Asessumsat Team OSAT) ccessised of seven hdependent nuclear connahants, each wth more than 20 yees of experience in

neir respeceiw areas of aspernse. The 15 A's goed was to idatify gaps between CasaEd's performance i and that of the best nuclear plants in the Unhed Staass, with perdcolar unphasis on the fondamental causes that have pevented acidevement of best performance.

l l The IS AT concentrated a the identined performance wealmesses and their inderlying tauses.1he j 15 ATs review emphasiset probleen donnidon and idena5 cation of fundamental causes, rather than

onnetive acanas. Consenwally, the 15 AT did not focus upon the effectiveness r'f ongoing and planned j improvemet initiatives.1he 15 AT acknowledged that many correczive actions were in the pmcass of '

being developed, and some have already been isuplemensed, to address la$ alls and Zion weshnesses.

j 1he 15 AT assessed performance at LaSalle and Zion over the past two years in Ave funcdonal seat:

i Operadons and Training, Maintenance, Engineering and Technical Support, Plant Support, and Management and Organizadon. The ISAT's assessment pmcess consisted of three phases.

• In Phase 1, over a three week period, the core team performed a detailed review of salsting l performance monitoring and asemannent documentation. These documents included, but were not hmited to. NRC hspections, evaluadons, Comed assessmenu, corrective action documents l

1 and performance improvement plans. The maprity of the weaknesses desenbod in the IS A were

! idendhed in these documenu.

l In Phase 2, over a two week period at each site, the 15 AT verined the Phase 1 identified f

• weaknesses based upon laSalle and Zion observations, interviews and further document revicws. ,

l The core team members were augmented by landrute of Nuclear Power Operancas GNPO) and j industry peers at each stadon in connecdon with the Phase 2 work.

1 j

• Upon completion of the Phase I and 2 reviews, the ISAT performed a sview of the causal factors j for operations, mahnunance, enginsonng and plant support and conducted a fundamatal cause

assessment for the management and organlandon funedonal area.

} As the IS A proceeded, the NRC was kept fully informed. On November 19,1996, Comed sannagement and the IS AT briefed NRC Region Ill management concoming the process used for the assessment. NRC

representatiws amended the she debriefing at Zion on November 23,1996, and at laSalle on December

13,1996. On December 23,1996, the IS AT briefed the Regional Administrator on the l4Salle and Zion observadons, causal factors and she IS AT*s prehminary fundamental cause assessment. On February 18.

1997 Comed sebmined the finalls A Repons a the NRC, ad on February 20,1997. Comed and the 1S AT pamcipated in a public briefing at which Corporate NOD,laSalle and Zion management teviewed their responsive acaans with she IS AT.

6

ATTACIDfENT J CamEd Response to NRC 90.H(f) Roguest he CNO and CNOO emewed the 15AT Raport and agreed with hs conclusions De CNO and CNOO ,

em cpecuuans for responsh, amon by the tasalle and man site woe Pruidents and the she vice Prendents have already lamaiad astrasm amans Ahhough the !$AT focused upon fundnensatal causes .

and did not smew the esectrveness W means heprowessant issnathes, the 11AT did recognias that many of the assassary enersam amans esse already la pisse a amoes in the Ipp6 lasalle and Zion Opersaamal Plans. Addnianal corroam asecas to assure that the ! EAT fundamsonal onuses are adersoned have been incorperused in the 1997 lasalle Canary Unit 1Nait 2 Ramart Plan and the 1997 man Operational Plan.

Coadd managesset has carefully rmewed the ihadamental amuses identiSad by the ISA along with the apparaat sanses lessmaed in the NRC's January 27,1997, M.M(0 leaar, the Dresden 181, and other infonascost Based apan this emew, Comed has concluded that our Isilure to achieved sustaland perfonamnes naprovaessat is due to fear amuses e Overught . We ased to mengthen y=== overaght danclear operation

-* Manaaemen' Ansation and Rssources . We how not anaaimmatly applied ascessary resources and management anonuos to the stas to ensure moosesful complenos of our !=---v t plans.

. Standards . We have act commaandy enforced high mandards for nuclear perfonnance, parucularly in the areas of operanons, engmeering and conectNe action e 1.msons laarned . We have not an=====ly -==='* and internalized the supenences of ,

our omt nuclear facihties or those of others in the induary.

A a stnx which mannarians the assion Comed has taken or underway to address these canoes, is prmidad in Appradix 1.

The renmimag four Comed sites are smirmag their Plans sgainst the ISA ik=da== mal causes to assure that those causes will be addressed and resobod. Imag term semainable L r.a willbe the focus in ihture Comed Operational Plan:. The CNOO has relayed his arpactances to the sites on the resolution of ISA issues and will be perfonning penahe asseamosets of the progrses toward resohnson 4.2 Engaging the Corporealen in Support of Neclear Au pans of our Company = -a6 ii-d in appen of om seclear program shorey snar roompt of om NRC's M.H(O loner, Comed's Chainaan and Chief Enacutrve Od5cer met with suscutma and managers tem throughout CcanEd, and snaior represseistrus of the bargaining amit, to infona these of the grmt) of the canna maustua salia their apport in aclaenas sustmand impnmunent throughout our nuclear program, and assure thorn that Corporme apport is being pnnled. On February 3,1997, the Chainaan asevened the amnior Comed Corporate ad5cers, both within and outside NOD, to identify andons that sound be takan both lande NOD and elsewhere in the campsey to apport the nuclear program. As a samh of this mesmag, esveral amass av underway, inchshag'

• To haynm parts availability and sense procurummet and use of correct parts, addeomal supply sesources av being deployed. "Take Acuan Now" teams have base funned to forsemisse and haplement a -hort term program to impnm meserials and apply J., ---- laspection practices how been signincmatly enhanced at the sentral warsbouse to ensure that pans dehvered are those requemed. Pans analyms and procurunsat specashsts are being added to the shes to improw pans ; ?=M sontrol and the a= ti- etpescurumant acinitia.

7 j

0 A1TACHMENT CoenEd Response to NRC M.54(f) Request

• A major challenge at the slies is getdng wcrk done in a timely and tffective manner. Suppon of the sites' Electronk Work Control Systems, which are used to plan and control wcak at the nuclear stations,has bwa made the highest priwiry of the C4rporme informadon Systems ,

e orgvdzadon. The sites have also been provided viih addidonal computer hardware and the acquisidan of hardware, software, and computer services has been streamlined.

• 1he Human Resources depurunent has made several changes to hupove support of the nuclear pogram. %ese kiclude authorir.adon fcr payment of overtime to several addidonal grades of personnel, and streamlining of hiring personnel into the nuclear pmgram. In addition, profosals are being developed for improving work rules that affect quality and timeliness of work completion at the nuclear plant sites.

• Corpcrate nuclear seewiry faictions will be transfened to report to the NOD.

These are first steps. but significant because they demonstrate the commitment of the full fmancial and personnel resources of the Corporadon to our nu:lcar program. We will continue to engage the entire Corporation to help sumain impvwa.t in the nuclear program.

l l 4.3 Engineering Support A key area requiring improvement at the NOD level and at all of our stadons is engineering and technkal support. Comed is upgrading Corporate engineering support and standardizing key processes, and has initiated shnt'serm and long term corrective actions to improve the quality and timeliness of engineenng support. %e iollowing summantes actions taken to date, results achieved, and actions in.pocess and planned.

Until 1994, Comed relied heavily on outside engineering contractors to provide engineering services to the six nuclear staticns. In 1994, Comed began a three year seategic plan to transition engineering leadership to Comed, particularly in the area of design engineering. The strategy during this time was for Comed engineenng to become the design authority and pnmary provider of engineering services and thereby decrease dependence on outside engmeering suppan. During 1994 to 1996, considerable progress was achieved. Over 100 people were adda$ in Comed nuclear pogram engineering organizations.

Design records were transferred from contract desip engineering organizadons to Comed, and on site design engineering capabilities were created along with a clearer NOD Corporate engineenng role.

Dwing this time, progress was made in the development and issuance of a series of common nuclear engineering processes at the six Comed nuclear sites.

In November 1996,in response to Wats and events at the Dresden. Zion and LaSalle Stations, several conective actions were initiated at all six sites to address identified concerns whh engineenng quality, design basis, and systern readmess. These actions included,in part, establisionant of an engineering answance funcoon at each she and the NOD central offices to funher ensure the quality of design and technical work, commencement of safety sysman functional inspections, review of Technical Specification interpesations, and a review of the top sen risk significant systems for items that may impact system readmess. De rer hs of me===-its han also shown that improvement is needed in the accessibihty and quahty of design basis information. They also identified the need to strengthen the safety culture in the engineering erfarhation.

8

ATTACHMENT Comed Response to NRC M.54(f) Request longer term effwts have bem initiated that mill sipificandy knpove tu effectiveness of engineering and .

strengthen the role of Comed's engineaing organizanon as the desigbasis authority. Comed has I embarked on a significant project to develop and validate eswaial desip and licensing basis information and reconnitute essential calculanons. Over the next three to five years, Comed wW expand the scope and coverage of the desip basis document (DBD) pogrsm. Dependmg upm the particular site, this will k ciude syseesn DBDs, nopi:a! DBDs, or a ==h== of both. For Byrm and Braidwood, specific tools riopical roadmapv') will te developed to assist enganeers in obesanmg nee &d design basis information.

Training will be provided to engineers and the plani maff.

Efforts will also be undertaken n improve the quality of the calculanons necessary to support the desip bases of our plants. A nuclear engineming pocedure for this effort is bemg prepared and mill address the review and reconstitution of selected key desip basis parametas/calculadora. His pucedure will be

, used to Mrmine whether calculanons calst, and if so, whether they are adequate to support design basis requirements. Dose cakulabons determined to be signifkant will then be revised or reconstituted as appopriate.

l Comed recently performed a review for all sianons to detamine actions r-amy to asswe conformance with the UFS AR and consistency with other desip information. It was concluded that irnpovements were necessary to improve conformance and the processes for ensunng it.ture conformance. Dus, a verification and validation of the regulatory design basis information contained in the UFS AR will te performed at each site. This will include a review of the UFS AR, Technical Specificatiora, other applicable design documents, and plant pmcedures. Dese review efforts will help to ensure that UFS ARs accurately describe the desip and operation of the plants and that these requirements are I consistemly reflected in important controlled documents.

The efforts needed to funher improve engineering performance in 1997 and teyond have been formulated by a team of repesentatives from site enginecrmg. Corporate NOD nuclear engineering services, and outside consultants with espertise in strategic planning, benchmarking and pocess optimization. De team made use of benchmarking studies of other utilities which manage multiple stations. Additionally, several major inspections and assessments over the past sis months have provided further insight into the strengths and weaknesses of engineering at all six stations. As previously discussed, ae'.!ons have been initiated to address areas in need of improvement. Our objec:ives include: -

1. Improve the access, quahty, and staff understandmg of desip basis information.

De actions being taken to address the accessibility, quality, undersumdmg and adherence to design basis information are d--A above.

2. Develop a strung safety culture.

De espected roles and responsibilities within the engineerms organization will be clarified and reinforced through frequent communication and mentoring. Additional training will be conducted to address identified areas for impovement such as desip basis adherence, configuranon mannaement implementanon, operabllity deaerminations, and safety evaluation paparanon. Engineermg Assurance groups have been formed to perform technical oversight of knportent engmeenng products such as safety evaluations, operability reviews, design changes and so forth. Dese groups not only serve to better assure quality engineerms poducu, but are already providing mentoring to the engineers and are raising the level of rigor and thoroughness in engineering activities. nrough implementation of these activities, emgineenng will become a

(

more self critical organization. .

9

ATTACHMENT r Comed Response to f.RC St.54(f) Regeset 1

3. Conduct technical oversight of agineering and major contractors.

As mentioned above.Ingheering Assurance groups have been formed to perform technical .

seviews of knrertsat engineerug products. The Engmeering Assurance artasps are composed of asperienced CcenEd NI paremnel suppcried by assende espers w% satag nuclear plant angmeerms sapsrience. Corporam and siw sagineering personnel are participedng with the quabry vari 6calcm 4-4 =3 in the conduct of technical audits of vendors providing important engineering poducts and oversight of Comed inarnal engineerug products and program plans.

4. Streamhne engineering pacesses.

Engineering has inklated actions to maamhne and improve mgineering work processes and samagement controls associated whh the haplementation of engineering programs and l development of engineering products sech as plant modi 6 cations and temporary ahorntions.

Engineerms sandards and specifications are being reviewed, revised and developed as determined necessary,

5. Strengthen the managemet of engineering.

Project controls are being developed for all site agineering groups. Common safety, cost and production performance indicators have been developed and goals are being established. Periodic espectation and accenability meetings will be conducwd with senior NOD management.

, 6. Lduce engineerms backlogs.

The engineering backlogs are being defined, characterised and a plan essablished tr. educe backlogs. Contracer resources and increased Comed staffing are being retained for this effort.

7. bnprove system / component engmeerms.

Symem engineers are becoming symem managers. System managers will be responsible for assuring sysum readmess and determining the work needed for their symems. Comraon system nondag wiu be developed and knplemented. A Corporate component engmeering program will be defmed ad NOt).nevel cosnpanent technical exoerts added to the NOD staff to provide common direction and assistance to the six sites as needed.

Other objectives involve management of large sagineering projects and NOD feel and reload design services.

While we recognize that these activitiu will require a abstantial Ensacial commenent, we view this effort as essential to safe and compeutive elecaricky production.

4.4 LanderabipS' rt Deveispasent.Treaming, and Eagasing the Workforce CosnEd nanagement has kdtiated a series of actions to suengthen management and first.line superviso-development and to engage the workforce in improving performance throughout NOD. These actions bivolve: (1) management selection, development, succession, and !JperviSory skills; (2) engaging the

[ workforce and improving managemem/bargaimng unit relations and practices; (3) personnel training; and (4) a *Getting Work Done" hitiative. Through these actions, NOD is raising the mandard of leadership

- effectiveness, quahty, and engaging the e.tukforce in support of sumamed improvement.

10

, .O A'ITACHMENT CassEd Respeem to NRC 80.5d(f) Regnest

{

I 4.4.1 Management Selecsies, Dereisement, Successes, sad Sepervisory Smit h regard to management aslection, NOD has completed, and NOD senior management has approved, ,

competency madata for management. These models are used to drive selecsion, assessment and denlopment propens a put of de compensary. named NOD Husnan Resoisse "_ n: Symem. De kn;' -

• of the new NOD Pwformanos % rt Syssen CCommit for Resuks") will align individual perfwmance whh the pernment andery, poductimi mid cost surpass b that hdividual's depenmut or she operadonal plan. De NOD landersidp Planning and Development (succession

. planning) Process has adopend a competency based process to dewlop suoneesion plans for NOD senior management positions.

In regard to first line separvisor (PLS) development NOD has ' jrr : f new processes to ensee the readiness o( new PLS candidases and upgrade the sidlls of PLS incumbents. De new mots and processes put in place inchde: Assessmet Canaers (for selecaion and developmet); Pre. supervisory Trt4ning; PLS incumbent Training: PLS 360 Degree Developsnam Poseeck; and PU Development Planning, i

New PLS candidases part4tpase in the PLS Assessnent Center (for election) and are resed as " reedy" to advance home candidases identined as ready participase in agervisory armining when assigned hdependent supervisory responsihilea NOD FLS incumbents panicipate in the TOWER UP" PLS development process. De POWER UP prouess requires incumbent supervisors to participale h a twcMiay Assessment Centar (for development) l whid assenes supervisory skills through inserviews and several job-related simulations, including a 360-( degree assessmnnt ap==*1===e composeed by their boss, peers and subordinases. A cunomised Development Plan is then meated by each panicipant based on assessment onnier and 360<legree feedback reeuks.

De PLS POWER UP process also includes training to help supervisors close skill gaps identined in the developmental assessment cenaars. De POWER UP training is composency based and consias of four days of required training and two to few days of elective anining. Additionally, second-line supervisors are amending two days of eraining to lamm how to boner coach and denlop the supervisors repomns to them. Feedback on the PLS POWER UP process has been very positive. To date, approximately 250 bcumbent supervisors have panicipened h the deC --M assessment anters and over 100 supervisers have panicipated in the training.

Over 900 NOD managers ed arservison, that interface with bargaining unit members how mW i ;- rt Anaarimmt Rasuhs Company (MARC) training to enable them to becer manage the workface. Bargaining isnt leaders and repnmentatives were also inyhed to amend. His araining focuses on basic labor. management and contract adminisaation prhesples, encourages ernployee involvement and darieh-making at the lowest approprime level, and creates a culast of support among managers, their direct repons and human resource repneuntatives, his trahing has also led to estabhahment of local and bunness unit posocol groups which provide the opportunity fa more consiment resolution of inues across siens.

(

ii

6

^ '

ATTACHMENT f[ Comed kampanas to NRC St.Sd(f) Regnes*

1 d.d.3 Engaging she WerWorer and Bargaining VaJt Roansions 1ingaging the Wortfece"is a broad asasegy designed to give managws and employees the forums and mois they need to set dhession, solve priddams, baprove wat processes and maintain the gains akendy

made. His arategy is depkryed at the site level through a she Land Team which has the responsibility for j using a process kapwn as Fahey PCi- n his petuses regasus lhe Land Team to review Division j Performance Targas, analyse and lesndfy their sies's says la mesang the performance targets, then

. charge and gonxe N L uz..t Teams to use qualky tools ad techniques to close the performance gaps identified by the Land Team, Progress is monitored dwing alte Land Team meetings. De Engaging the i Wortforce effort is facdhased by she personnel sained in qualhy tools and facilitadon nacimiques as well j as by a site Quality Coach. De Quality Coach provides consukadon on the use of the quaiky spots and

==tw* so the ' ;- r = Teams and the land Team.

i

j. De Engaging the Workforce mensegy, by design,is in different sages of knplementation across the j- Division. The Quad Cuies and Byron Stadens have progressed though develophg their land Teams,

hetalths the Quality Coaches, performing Policy rg crt, training facilitators, and chartering ,

! knprovement teams. Dro9 den and Braidwood Stadons have not completed Land Team Development, but >

l have perfomwd Pelhy Deployment (Dresden only), haalled a Quality Coach, trabei fadikators, and l have char.ored improvement Teams. LaSalle Stadon pericaned a Policy :A#ent esercise in 1996, masalled a Quality Coach, has trained facilitators and has used improvement Teams, but management i

! reorganizadon will require redevelopment of the Land Team, Zion Station has participated h the Wdal Engage lhe Workforce development, however, due to the current performance situation, will defer 1 additional activities until a later time, t t l De Engaging the Workforce deployment plan for 1997 include;: delivery of an Engaging the Workforce 4

Deployment Plan: sakhs and developes land Teams at Braidwood and Dresden; training and development of facilitators sid improvement Team Landers: and conducting Policy P;'5xx: at l Braidwood, Byron, Dresden, and Quad Calies.

s bnproved management and hersaining unit relations are being lAnih through the Joint Landership Team.

which is co chaired by the CNOO and the hersaining unit President /Bunness Managa, his team meets periodically to develop mutually. sponsored messages for the workforce concoming the need for continued *

. knprovement. As the Joint Landership Team builds a foundadon for change, management and the .

l bargaimag unit are angounting %5r9 collective bargaining agreements that will enable work j practics imprmomems.

d.d.3 PersonnelTraining Corporate action is also underway to further improve the performance of personnel through maining. This divison. wide effort will upgrade the malnks materials, instruction and training facilities while promoting

, mandartbeation as approprinse. All of these effons se legended to baprove the overall level of the ananas and M"-M-m of our workforce. Recent divia6cn training initiatives include:

Y 4'

• 3 Mudmed 10 CPR 50.59 and openbihty suining has been developed and provided to Plant ,

Opcming Reyww Commione (PORC) or Safety Review Commhtee (SRC) members at five our aix sites. A similar orientanon has been provided to NOD Senior Man;gement.

1-

• Critena for direct hire niection and training of jowney level maintenance craftsmen and

. technicians are being redefined. Elevated standards are being amahliehed for completion of 1- initial training.

]

i 12

ATTACHMENT ,

Caned Raspense to NRC 80.54(f) Regment g

(

• A mandsd )b asdsnment marts is being developed for banand sonw intermedime mainianance tasks. Dis mandard maarss will help enswe that wcekers m fully quahfied io perform assigned work tasks.

• Common Corpornie Adminieradvs Procedwes governing de analyds, design, development.

'-7

= and evalundan of tralning will be haplemented in 1997.

• Poddon desenpdans have been denned for degreed.non licensed Shift Technical Advism (STAS). Training is cwready being developed to suppen the enhanced on shift engineering role of the new STA.

. opermor sidias and imowledge m zhn and tasatie m being upgraded throush focused niining as idendmed topics. lansons issued s tasalle and zien m being provided to de other few shes for coverage dwing wamung.

4.4.4 Geming Word Donelaisledre Another Carpersie initiative to raise performance to a higher NOD wide mandard is the *'Oesting Work Done" medon designed to improve Comed's ability to complete vanintenance work at the sites. De Gening Work Donc initiative includes:

• A mandard screening process has been put in place at all sin sites to enmre maintenance W is e properly ensasi5ed and pncritiand. Dis effort answes work is performed wkh the proper controls in place.

• Work planning is being evaluated to identify inefnciencies in the planning process that prevent work from being performed. All shes are currendy implementing a minimal work request process which enhances job planning for minor wo6k.

• A revised scheduling process has b:en designed and is cunently being knplemented at Braidwood. De other sites mill implement this revised scheduling process by the end of 1997.

De new scheduhng process focuses on nabilizing the work scope four weeks prior to when the work is MM Such scheduhng albws for all depenments to proport for the work and avoid last msune misappheadon of offans.

• De executk subprocess of the initissive has been evalussed and resources provided to beser accomplish work. Some suppon skills have been idennined that will assia in emergent work

[ issues being included into the work schedule when appropnate. De amount of emergent work compimed by the Pix It Now teams is mensued to determine the effecsiveness of the initisives.

• Puiarnance menses are being developed to nnonier and improve process performance in venous areas. Dese snesswes are being mandardiaod to pennk comparison of performance between sites. ,

Raouhs to date have show, tha' since August 1996, corrective maintenance backlogs at four of the sis

- shes have been reduced A red.iction of past due critical preWve maimenance tasks at four of the six sites has been observed 1

e 13

o ATTACHMENT ,

( Censed Response en NRC 88.54(f) Regeset i .

The support of our workforce is namential e success. Corporse and site management are placmg poster '

emphasis on gaining worbforce ownership of Comed's performance improvement inidadves. We have recandy canmmicased thmugh a set of messings, videotape presentadons, newdener ardeles, and loners .

bom esecumve menagemet e answe shal our ernployees se aware of our carrant situadon and our plans.

Our 0400, dt.ing les periode vieles (typussy sessuhly) e she ahes, conducts open discussions with poups of 15 20 employes regaribag our plans, issues of concern, and seps that can be taken to kaprove.

, We bebeve that thsae acdcas will help all of us pull together to sustan impovement. ,

l d.8 Correceive Aceles Program and Response se lassens Laarmed 4.5.1 Corressin Assies Progene in order to annre shat car.. cove aedons and responses to lemons Isamed are consinandy and vigorously implemensed t.Cm the NOD, a new corrective action program has been developed by representatives

. from all sis nuclew shes and the NOD cuneral of5ce. These representatives reviewed successful corrective nedan prograrns in the industry to esablish a new corrective aedon process for she entire Comed nuclear program. The new process includes several improvements over the carent program. It clearly delinemes and mandardines the threshold for problem identificadon through Problem idendficadon Form (FD9 hidadon, and assablishes common PF screening crianris 'w provide greater ability to analyse PF data.

The new concedve a: tion process will include human error reduction methodology. inchuhng mandardiaod coding, problem idendlicadon, trend analysis, and root cause analysis ^-? -C: e To implement 2 proces, Comed is training dedicated root cause analyms in foot cause analysis techniques.

Groups of these trained individuals will be masoned at each of the nuclear plant sites and in the NOD central office. Personnel will also be trained on the new corrective action procent and on human error reduedon techniques. These procedwes and the anandant computer software have been knplemented at Byron Swion in March 1997, as a pilot effort. The remaining sites have developed plans to implement this procet.s during 1997, f

in order to set and enforce management espectations relative to supponing the corrective action process, i Ihe Station Managers have been designated as the accountable group to implement Correceive Action Program improvements, monitor corrective action performance and take appropriane follow on acdons.

They have been active ki the review and approval of the newly developed pmcedwes. Inidal performance buticmars have been seiscend for each sage of the cervective acdon process and baseline data has been taken for the month of February at Byron. The information will be taken monthly and used to evaluate the effecsinness of corrective acdon process improvements as well as panicipadon by each she in the process.

Performance trubcasars have also been developed to melter the timelmees of im;' -- '=, quality of the consesive accons, and the nr.mber of significant events which are repeased. These hdi==s are being tamed at Bynr Site and NOD central management will take appropriate actions based upon perfonnance and rendts.

A NOD wide comunan cause assessment so idonafy pavaient causes of pmblems identified in the NOD

- wiB be car,apissed by tha ad of Jua,1997. This fWst analysis will be based upon kmhed data because of the akst time of ' A % of common processes, however. it is believed that useful insight can be gained by performing n earty evaluadon. Ct=nen cause analyses will kdtially be conducted on a quanerly basis, i

14

1 J

1 ATTACHMENT l

Comed Response to NRC M.5d(f) Regnest 4

?

j An overview of the new NOD root cause investigadan process has been provided at each she. A training

matrix for root cause investigators has been developed and recessary coumes are taderway to support l ';'-- "= as required by the correcdvs acem procedures. .

I

dJJ senadard Praessses and ampomar a Lassene Jasnood  ;

i j A broader effet to ensure audismity h the qualmy of pocosmos and pracdoes at our plant siens, and to j benefit from lessons lemmed,is the use of Peer Orwps across all sites. Groups of +:1Mves trom each site and a full ti ne support peer are assemblev hio Peer Groups to develop and implement safe,

! effeedve, simple, efficient nd unifcem processet and practices at each sim. Peer Groeps have bJen i

,sombhahed to knprove proceseas in the areas of Operations, Work Control, Outage !'ryt, ConAgurados Csatrol.Equipnent handlity Training, and !'r;- M and Adminiseration.

- Perfannsnce isnprovement asams are fonned by dw peer groups to develop and knplernant specinc P"% Proceskres and passicas.

Por esample, a team was formed to crease lenproved and standardised approaches for power reduction and shutdown of our PWRs. As a result, a standardised shutdown activity sequence has been developed and has bem used at Braidwood;its use will be entended to Byron and modired for use at Zion. This same

team is working on developing a mandardized saanup acivity sequence. Another team was formed in the  !

j Work Control area to improve the work process for minor maintenance. As a result, a more effective and

! efficient minor maintenance process has been knplemented at all six shes. The Outage Peer Group is l l curready developing a standard pre outage preparadon plan that defines key milestones and performance L indicators.

l These new proosenes reflect safe and effecdve best pacticos and lessons lemmed from all of our matiora.

! Other peer groups and performance inidadves in the near term include:

l

• Operations Standards and Human Performance i

• Pive. Week Work Scheduhng Process

• Periodic Mainionance and Surveillances 1

l Also, Peer Groups have been used to address egent problems. N example, when several control room i problems were identifad roomdy at Zion Station, the operations peer group convened to address act'm that could be taken prompdy at all sites. These actions are being implemated by each operadons j snanager and have been conArmed by NOD Policy.

Some other mechanisms for disseminadng lessons learned from within the NOD include the utilization of

! eleesonic bulletin boards for Nuclear Operations Notifications (NON), Comed's NOD utilises such bulletin boards for the poedng of Comed Inspection Reports and other generic commmication of mutual l

bierest for each of the sites. Such andeavors provide ready access to informanon by all organizations j within the NOD.

in l'ebruary 1997, a paceshpe was lamed for evahmhg and inhisting NOD wide acaion in response to  ;

j gating sapariance at any of the CasnEd nuclear sianons. The procedure also covers response to

apniating expenance naams from non Comed stations. The procedure provides for review and scressung

of operadng exponence items, development of responsive acdon, ad review and evaluadon of

~

offsedeness of responsive action.

l 15

ATTACHMENT

. Comed Response to NRC M.54(f) Request Speci6c recat saamples of NOD. wide response to nnesons nesned hclude use of the Droeden lS! results and the Zion Engineering and Technion! Support inspeeds results se the basis fw Corporate wide armewmg impuvernant hddatives, and the use c( the LaSalle anL Dion ISA resula and fundamental emnes to ensure that NOD and she samagement phas are ptperly argeted. Other examples include enablishing Engineering Asamenos grtaps and pwfamhg top aan syssam reviews, We intend to condnue so haprow our progrens and management involvemem to loam frora capenance at each of the Comed sites and outside akties.

4.6 Corporate Oversight Comed is -fW hs oversight of nuclear operancas at alllevols and hadtuting comme indicators by whch anfety performance can be effeedvoly monitored. Oversight at the Board level has been formalized in order to assim the Board of Dweetors in its responsibilities to provide oversight of the nuclear operations. De NOC is charged with reviewing and reporting to the Board on 'he safety, reliability, and the renowce allocanon both in the long and short term of the nuclear opmadons.

Additionally, the Commisse is to review and report on the effectiveness of the management of nuclear operadons and the symans employed for the self identincation of problans and posential poblems, along with the approprialeness ad timeliness of conective acdons. Oversight at the Corpcrate and she leveis are in the process of being revitahead to augmen: kne management's condnuous oversight of nuclear safety and ccatformance to Comed's policies and perfumance goals. In addition, oversight will povide knegrated tools for mensunna safety performance, allowing she to-site and indusry perfumance cornparisons, and providing enriier identincation of emergi'ig afety issues. performance measures and a pogram for assessment of performance in the functional anos of operations, engineering, maintenance, and conective action are being developed.

4.6.1 NOD Ezecnave Maastement Owrsight he CNO is charged with responsibility for independent ovasight and managanent of human and financial re ances for the NOD. To emus that NOD standards are upheld in these areas, the CNO has directed a nonber of the oversight knprovemets described below, in addition, the CNO has brought responsibility for nuclear pogrom human and fknancial reanun es inder the consol of NOD management.

For saample, in the Human Renowcas area. NOD has taken the Niership role from the corporate office in labor relations, compensadon and personnel performance assessnent. Dis aedon has led to personnel management symems that me nuclear specific anJ tailored to achieving the goals and objectives of the nuclear division. These changes ensure that key processes upon which our nuclear program relies are drectly managed by NOD. .

De Nuclear Oversight Manager reports duectly to the CNO and is responsible for keeping the CNO appnsed on a timely basis of the performar,oe of quality programs, adequacy of NOD outral and site functions, and significant quality and safay issues. Dis organlaational reporting alignment answes that the CNO receives N ; r ' t and direct feedback on nuclear operadons performance.

The CNOO conduces F1 --- Review Moodnes at each see focused on safety performance and the eNecoveness of 4 ---- inkindves. Dese moedngs address trends of safety, performance, and cost indicanors; tesuhs of third pony (NRC and INPO) hapei=r results of she self assessements; matus of matenal condition in she plant; outage pluming and peformance; and assessments of the quality of workforce poduct and training. Dese moedngs provide esecutive management focus on continuing performance improvement, early input to the resolution of emergmg problems, awareness of performance j issues and impevyements across all sites, and the opportunity to reinforce expectations and safety culture.

16

ATTACHMENT ,

' CesaEd Response to NRC M.5d(f) Regnest dA2 NODMide Naciser Owsight

'The 15AT idendfied that oversight pograms had am effectively evalumed plant performance and Ibarefore had am suceamfupyinDusaced consruedvs management acdons for knproved performance. '

Changes e underway to smenphen the seneshand oversight Ancaion within the NOD central arssdandon and at the shes. 'the busw of sounphaned Noo wide evenight is not to dbninish the stie oversight responsildlities, but a povide independent and tensiment pyssight of te pericurnance of each site avl the division as a whole.

In order to revkalise NOD wide oversight, the staff slae is being in:vessed and the assessment and audit pograms m being formahand and onpanded. 'the NOD audit and sirvoulance program is being l developed to luegrase wkh the she oversight and genuty programs. 'this pogram wiH be h place by 4 ' 1,1997, it is being redesigned to booer enast that the requirements of the Quauty Assurance Topkm) Repon m met. In addidon, a new quabey oversight poup at the Ceneal Manerials laspection

. and Storage (C Team) facihty is behg omsbluhed.

'The increased NOD Nuclear Oversight namns levois will aspport data analysis, parfannanos motdtwing, snanagement and coordination of industy (pear) assessments, and assenuments of emerging issues or special evoludans. An integradon of data and analyses from the madon and corporate overnight organization wiu be perfemed to provide insight in regard to sadon and division perf,umance. The first pilot report focusing on safety was issued in March 1997. The pocedure deaning this program will be completed in .'une,1997. A fannalised living schedule of audit, and assessnents is being developed at the NOD level to assist in the auccasion of resources and coordmadon of audit and assessment activities.

'These actxms se designed to ensure that oversight responsiMiides and interfaces among NOD ar4 site groups a weD denned. imegreed and effective.

NOD Nuclear Oversight and $lte Quality Verincadon (SQV) are smablishing an NOD wide mandard analysis and reporting process. '!his process wiu be similar in structure to the NRC's Integrated Performance Assessment Process (IPAP). la includes performance measures for haetional seas. in each funedonal area, it evaluates Safety Focus, personnel Performance, Problem identincadon, Analysis and Resoludon, Equipment Performance, Material Condidon, Programs and Procedwes, and Quahty of Work.

'the new pocess wiu incorporate both the NOD indicasons described a Section 4,7 and additional leading, real time, and lagging perfonnance indicators. Emergent trends or issues will be repcred to the SVPs, CNOO, and CNO on a monddy basis. Quanarly, a more in depth analysis focused on NOD wide -

issues will be performed and the results will be reponed to the CNO and CNOO.

Utilising induary sapens and industry standards, peer assessments will be performed to evalunee spacine organizadons, pograms, or pmcasses. Esamples include the recent ISAs at Zion and LaSalle.

Significant deviadans from best industry practices wiu be identined and shared whh relevant orgardsations. Utihains team members from Comed shes so that lessons lemmed we shmed, as,n assemments may be performed pior to upcorning evoladons such as Unit start.ep. Assamments wul be perfonned on senergmg issues identified by other evalumina processes or perfonnance lashessces. Other assessmenes wiB be foonsed on the she quabty organisadens and their pmgrams, pecesses and poducts.

Assessment crusna win focus on specine perfonness areas, auow a comparison of perfonnance to pre-

===hl=had safety and quality sandsds, and assess the effectiveness of --4M=' performance of roles and responsibilities.

17 1

e ATTACHMENT

( Comed Respeau toNRC M.M(f)Roguest 4A.3 She Onnkht in addidon to NOD wide oversight amivides, mvoral machenisms = in place at each site. Safay -

oversigl.t u em shes by the SQV and Qualsy Caurol (QC) organhadons includs; the QC inspeede and Quainy Amaraus (Q4 anda siivisies pesciand by 10 cyR 30 Appsadas 3,ladspondent safuy ansiasseing one,(Isso) susceions of arvoinhme sad saray seriew, and evakene of die poblem idendficadon and oormeen modon pnysns. Aho poviding animy oversight a the alle hvel are dw PORC (or 3RC) and the Safay Review Board (SRB) to is implemented at all shes. Each she also has a group that evaluanes the severity of events, and desarmines whethee a foot cause malysis is warranted.

Processes se being knplemented fw evaluaaan of the sWeceiveness of surreedvs acaion.

I Whhin the SQV and QC organisadons, QC Z : ::h QA audits, and the !$50 function rumin their madmanal roles. Monitoring of performance against the indicators, Corrective Acdon Requests (CARS),

and industry saperknos, ad review of sine self assessmanas will also be conducted withh SQV.

. The $simy or Managenset Review Boards conds of senior experienced outside expens and CenEd

! personnel who review site performance and meet wish site management to discuss performance and provide comments and recommendadons. The SRBs evaluaae sendon safety performance, corrective aedons, and irnpovanent plans. The SRB Chairmen will also povide input to the NOC of the Board The she gains outside perspective and macal review of performance from this body, I

The pORC or SRC at each she is chanered to review safay related activities in order to assist management h assunng unie operanon. The Commines is composed of senior slee personnel from several disiplines and provides across the mie review of safety issues.

4.7 performance Messores, Criteria and Acalens if Crheria Are Not Met in the past CamEd has sande use of posformance indicators and other tools a ks nuclear stations to assess progress in impeoving performance and addressing weaknesses. However, these measures have been developed separatejyat each site, and have not been consimently measured or used on an NOD wide basis.

In order to provide assurance that all stadoms conthue to operat e safely while sustaining performance imptovement, Comed has unab!)shed an integrated seveture of pwformance maamsss, criuria, and actions to be taken if the performance crneria are not met. These inclede: (1) top level indicators to be used in measunng progress in achieving our overall goal of perfonnance equal to or bener than industry peer averages; (2) NOD wide bubcasars to povide more specifw menswoment of NOD and each site's pogress a susialmns performance knpovement; and (3) a process for responsive action in the event that the performance criteria enablished in (1) and (2) are not achieved.

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ATTACHMENT l

Comed Response to NRC M.H(f) Request

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%ese performance measures were selected to povide hdication of whethes we are operating safely and ,

sustalrdng perimnaru improvement. De use of NRC and World Association of Nuclear Operators  !

i (WANO)indkators provides a Ngh kvel safety evenkw and hdication of overmU effectiveness in achieving kaproved performance roeuks, and permits evaluatice of whether we are reaching our ovaaU

< goal of orestmg each sin m a level conntment wkh ks 6adiuery peers.These top Lvel indicanors art

< augmented by more detailed NOD indkaars that were selecned based upon review ofindicanors ComTA has used in the past, review of haemaars used by enhor ameneer utilides, and the experience of our management seem, many of whom lave need these indicators k other nuclear programs. They are designed to show how we are performing at a level of sensitivity and desau that timely corrective actions can be taken when performance trends surface, permitting us to resume tracking toward our overau goal. l Dey cover the imponant operations, maintenance, engineering. end corrective action areas that must

. perform weu for sumained impovement a cach site. Couectives, observed cnw time, these indicators wiu demonstrate whether we are carecting our prtMems, openting safely, and sustair 8,ng performance im;vovesnent.

i ne indkators described telow wiu be compiled mondJy by each site's SQV organization, and assembled m an NOD. wide basis t'y 11octear oversight.

As described in Section 4.7.4 below, we are also taking special measures to assess and monitor our performance to ensure that areas of weakness indicated by the 1.aSalle and Zion opert.1 mal events are not present or are addressed at all of our nuclear nations.

4.1.1 Top Lmlindustry Sundantindicators 1

, Comed has selected an overall set of indicators to measure progress in achieving the goal of all nuclear units performmg as weU or betier than the average of their peers by the year 2000, hese indicators are

, mandard measwes used by the NRC and/or WANO, and are calculated on a consistent basis throughout the industry. We have established espected performance criteria for each indicator. In any case where a criterion is not met, we win take the action described in Section 4,7.3. Dese indicators and criteria Md:

1. Automatic Scrams While Critical (NRC)

I The number of unplanned scrams per year while critical, Exarnples include scrams from espianned transumts, equipment falhtres, spurious signals, or human error. Scrams occurring l

during the execu' ion of procedens in which there was a Ngh chance of a scram occurring, but I the occurrence of a scsam was rot plannud, are included. Performance crherion: Take action if there is more than one scram per udt per year.

l 2. Safety System Acasations(NRC)

Manual or automatic actuar=< of the logic cv equrpmmt of either certain Emergency Core Cochng Systems (ECCS) or. in response to an actual now voltage on a vital bus, the Emergency AC Power System. Perfonmanor critericm: Take actxm ir there is more than one safety synem

==riari per unit pee year.

3. Couective Radiation Exposure (NRC/WANO) i ne total efrective dose equivalent received by r.!! personnel coming on site. Performance

( criterion:' Take action if projecsed or actual resulu exceed site annual year end exposure goals.

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ATTACHMENT

( Caned Responte to NRC M.64(f) Request

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4. Unit Capsbuiry Factor (WANO) 1he ratio of avauable energy generadon over a given dme perkui to reference ana'gy generadon owr the same time period, empressed as a percentage whh both energy generation terms determined relative to reference senbseed conditions. Perimmance critonore Take action if projecned a acanal performance faus below year end site gent. This criterion wul apply b 7. ion and LaSaue fobowms remart of their units.

l S. Unplanned Capabuity less Factor (WANO)

The ratio of the unplanned energy losses dwing a given period of dme to the reference energy

' genermion, apressed as a percentage. Pwfemance criteriore Take medan if projected or actual seenhs show capabuky loss > $5 above estabushed year end sie serget, This goal will apply to Zion and 1A$aue fouowmg restart of their units.

6. Safety Symem Performance (WANO)

This indicator is calculated separately is anch of the following three BWR symems and each of the fouowing PWR systems-BWRs . high prenews injeedorWest removal (high presswe coolant injection or high presswe core syny or feedwaar coolant injection, and reactor core isolation

, cooling or isoladon condemt systems)

. residualheatremovalsysum smagency ACpower symem PWRs . high presswe safety injection system

. malhary feedwater symem

. emergency ACpower synsm lhe sum of the usavailabuities of the components in each safety system linec above is divided by the number of trains in the system, Performance criteriore Take action if un.;vaumbuity exceeds two times the INPO goal for any symem.

7, Industrial Salery Accident Rate (WANO)

The nwnber of m:cidents for all utility personnel permanently assigned to the mation resuhing in one or more days away fran work (eaciuding the day of the accident), or one or more days of reatncted work (excludag the day of the accident), or wak related fatalities, per 200,000 person-hows worked. Consractor personnel we act included in this indicator, Performance criteriore Take scnon if industnal safety accidet rase exceeds amenhilahed site target.

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A1TACHMENT Comed Respoem to NRC M.54(0 Request t

We will use these indicators as the overall measure of our geogress in achieving rustained feriormance lmprovernent. We may a4ust or change these indicalm as we gain exponence and progress is made.

These in&cators will be meassrod a each sin and ia the NOD as a whole. They wiu be monitored by ow CHOO, ow CNO, asul the DOC of the Scard W Directors. The NOC is responsible for communicating any significant performance trends to the full Board, nn mMaire, as described in Section 4.7.3, we will l i

take aedon in the evant that these indkators devisse fran espemed perfwmance criteria.

i 4.1.2 Nucient Optresions Dir%n Perfenmenteladiensors 1

Beyond the top.nevel industry standard indicators, Comed is establishing a comprehensive set of NOD.

wide performance in&cators to provide more specific menswement of NOD and all sites' progress in achieving results. Along wkh the top 4evel indicmcrs, these NOD. wide indicators will be used consimently at all shes and renewed monthly dunns the CNOO's Management Review Meedng at each site. Those menswes wiU pennis compariscm of performance and idenufication of trends between sites  ;

and for the entre NOD. These ind=Ws will also be reviewed by the NOC of the Board.

Indicators that we have selected include:

• Operations Operator Workarounds Out of Service Errors Human Performance lirrw Licanee Event Repons (LERs)

Temporary Aherations Falle[ Technical Specification Pump and Valve Swvenances Unplanned Entries into LCOs Percent Contaminated Floor Space blainten&Kt Non-outage Corrective Wort Requests Percent Rewcek Outage Power Block Work Rsquests Ensinnerme I

! bgineenns Requests Overdue i

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ATTACHMENT

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Comed Respomas to NkC 50.Sd(0 Request CcE1eedve Acton Conceive Action hems hardue Correcdve Acan Aspent Events

. Number of PPs Wriaan Qlhar Overnme Hows Oned NRC Violades .

We are in the process of esuddishing consimer. dannidons and performance criteria for thsee measwes.

As with the top level indicators in the event that the espected performance orlistia are not met, we will take action as described in Secdon 4.7.3. De dermitions of these indiators, and the performance criteria l , associated with them, will be fully established by April 15,1997, and will be available for diseaselon at the brienng of the Commission on April 25,1997. Dey may be adjusted as experience is gained and cucumstances warrant.

I In addidon to striCsly quhntilative performance measures, we will mordtor Seveal qualitative W8Calors. ,

such as employee concerns, alle6adons, and the results of a periodic anfety culture sevey, pv each of these bdicasort, the absolute numbers are ines important than sends and reasons for chenre in the indicator. We will evaluate and respond to si $nificaro tmnds and changes in these maaress, d.73 Respenstre Acaen if A Crinerien is Not AcMrred Collectively, achievement of performance criteria described above over time will indict ie that sustained performance is occurring, that causes of previous failures to estain improvement have been addressed.

and that dermite posidvs performance results are being achieved. To ensure that this acces, as requemed bi the NRC $0.54(0 lener, we have enabbshed the acdons to be taken if the performance criteria are not met. Dese criistia and acdons provute answance the each of our plans will be operated safely and to a high standard.

In order to assure that effective and imely actions are taken, assomment of pcciormance bubcators and implememadan of act'.cas based on this assessment will ske place at the site, NOD, and Board levels.

Each of the perfo:: .mme indmaiors described in Sections 4.7.1 and 4.7.2 above will be messeured by the

$ lie Vice Presidents, and will be reviewed during the periodic M ; .s.t Review Messing for each madon. Beghning in May and conimming snonthly thereafter, each Site Vice President shalt submit a least to the CNOO reparung Ihe susus of each of his masion's pifonnance indicanas for the previous month. Acdon in cases where a perfonnance criterion is not met will be as follows:

• If a performance criterion is not met, a

• variance report" describing the cause of the deviadon will be presented as part of the next Management Review Moonng. '!his report will include a desenpdon of the aedens underway or planned to improve performance.

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ATTACHMENT l:

I CasaEd Response to NRC St.54(f) Regoest t

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• If a performance criterion is not achieved for two conascudve months, Ge Site Vice Proeident's j monthly report to the CNOO will irnlude a writsen aedon plan to tring performance back into j comformity wis the ctherion. Tbn CNOO or site Vice President may direcs addhional specific .

' action,includag work manMawns,Ly _ ^=F = of special work controls, appointment of root cause er inveedganism towns, assignment of ad&ount personnel, special menharing, or l asher appopriam acens up to and hcanding plant shundown. If the CNDO and Site Vice l

! President determine that the casse of the devision is not tied to esAcdont performance or that the i deviation is acceptable fw a period of skne, they may reset the performance crharion or defer j acsion for that hmlied time. Such a decision will be reponed to the CNO.

i l

• If: (1) a performance criesrim has not been met for three manihs; or (2) responsive aceirm has j achieved inadficiera progress over a sustained period, the CNN will report this to the CNO.

The CNO and CNOO shall enablish a asam, reponing to the CNOO,1his team will assess I causes and recommed: (a) furter accons to remore performance; and (b) other medans that may l

be appropiate to the sericumens of the probian, such as ssanddown, staff a.igmentation.

4 hereased ovusight,moddbed operadons or shutdown. The resuhs of the team's evaluation and

> recommended actions will be reponed in the regular bneAngs of the NOC of the Bosrd of l Direciers, which hcludes Comed's Chairman /CEO, Vice Omrman, and Proeident. The

progress and succom of this plan will be reponed at each Management Review Mass.ng for the i affected station. The NOC of the Board will also be notdied when performance has been rearned to cordormity with the criterwn.

l

!

• The CNO may request the Board to review resources availabic to resolve the performance

~

! problem that is preventing the criterion or action from being achieved, and allocate more resources or direct any other acdon which may be necesary, The NOC of the Board may also request such action at any time it determines that a prolonged and significant failure to achieve a performance criterion is occurring.

These actions will ensure that in cases where our expected performance criteria are not met. prompt and i vigorous measwes are taken to retum performance to expected levels.

I 4J.4 Assessment efterferesace in Aroes gf Washnear Wa=used 8p LaSalAr sad 2 den Koems i

In light of operatio.ul events a: LaSabe and Zion, we are placing particular focus on measurements of

) conservati> e opersuonal decision-making, using an integrated set of quantitative and qualitative i evaluaticm tools. These tools are designed to improve our capakhty for early detecdon of adverse trends in operadonal performance. Thees trols include:

The peer group that has been formed to develop improved NOD wide Operations programs, 1.

processes and mandards (see Section 4.4 above) has developed a set of kubcasars for meanmenent of the safety and quabry of control room performance. Each of these in&cators will

be used by see managemas to duennhe whosher omnol roorn operadons are being conducted 4

in accordance with managemsat aspecanons for conservasive decision-making, in addidon 49 the parfannonce sammewes alssady &scemed, these in&casors hclude sudi hems ac wrong

udt/ wrong train events; lit annecissors; control stuen caution tags; am outage equipment oub i of service; human performance P6Ts; and other in&cuors signiAcant trends in these indicators a will be reponed at the F7 rt Review Meetmg conducted by the CNOO.

{

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- , .-4..,.._,.-.-.-.,-,--,em~,-. . - - . , .-rw-,r.,rm-.,,-,.. m- . ,,,o--,,-..-. +

ATTACHMPA'T

( Comed Response to NRC M.64(f) Regeest i

2. To immediately determine whether the types of operational problems idendfied in the Zion and

!.aSalle IS A esist at other stations, the CNO has dincted that the NOD Vice President of Nuclear Support (who headed the investigada of the recent Zion event) visit each of our sites to observe contmi roarn activities ad teview casrol rocyn activities.

3 Teams of peers from the Byrta. Droeden, Quad Oties and Brandwood station will perform operades peer assessments to evaluate safay culart, cornervatism of operadonal decision.

making, and implemmtatim of operations standards. Standard tsview plans and checklists will be used during these assessments. Reports of the readts of these evaluations will be provided to the CNO, the CNOO, and the station's Site Vice President.

Collectively, three tools wRI help determine whether safe and conservadve operational pracdoes are being consistently implemented at each aise and will ensure that adverse trods in Ods area are promptly detected and conected.

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A1TACHMENT

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Comed Regosse to NRC N.54(f) Request ,

5.0 $!TE ACTIONS TO ACHIEVE SUSTAINED PERfDRM ANCE IMPROYEMEPG in the fouowing sla secdons of this response, Comed's pufremance knprovement inidadves for each of .

ha sin sites are summarised. These asnmaries are presented in a cronman format and shart the common goal of sumained pertaruusse ' _ -- ~ At the smee time, she cerrent leals of performance, management chaurates and correctin actions very a.atag the shes, ad no ihat satent, the scope and desau of the bnprovement imidadves can be expected to and do very amcas she sites. The discumulon to folkw addresses the performance ' , .. r .: initisdves for Droeden, Quad Cales, LaSalle, Zion.

Brandwood, and Byron. For each hdivkkel she, the discusman provides a summary descripdon of: (s) recent plant performance; (b) the peninent backgrounds and esperience of key slee management team l members; (c) the resources dedicaned to knprovesnent Wdatives (d) the elements of long term

! .,,.. rt plans: (e) bnpcmant future accons, including where applicable, special actions e support plant n estart or in response to esternal tasessnents: and (f) monitoring mechanisens to enmus effective implema.tadon of improvement hetiatives. The actions described in these secdons reflecs our cwront activides and plans and may be modified as circumstances warrant.

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ATTACHMINT

( CesaEd Rupeese to NRC M.Sd(f) Request 5.1 Drmdes 5.1.1 5namary <Perfemmace Dresdom Staman has been cm the NRC's Wash llas since 1992. Ptsnt safety performance was ganarally weak early h des period when plat maserial condman bepected plant rehnbuiry, and pmblems with henan , / - : sad sour key pr=== muuh d in plan evnes. .

Over the past two years, improvements have accmed bi plant maesrial condition, conduct of operations, managt.aent and the overall organisadon. Safay performance has knproved wkh programs, policies, and maff in piace to support condnued irnprovernant. The NRC 151 Inspectors recently recognised Dmaden Consol Room operadens as among the best they had observed.

i ; w.xcs have also been seen bi the working sivtronment wkh respect to radiation sapoems and conominadan canaml. These improvements can be saributed to source term reduedan i ?..r:J.

reduceion iri the contaminated ama in the plant, and sifactive implanantation of the she ALARA program.

In maintenance, we have knproved a nurnbar of malniansace processes, enhanced the knowledge, aldits

, and abitaties of maintenance personnel, and improved the ovmall matsnal condnion of the plant.

l However, the effectiveness of thcae knprovements has been reduced by the number of afety and non.

safety related emergent work acdvities. This emergent work burden has adversely knpacted our ability to conduct planned work and decrease backlogs to a desired level. Recent changes to performance I management and measumment within work control se espected to knprove work management decisions resource allocadon and = nth = tai, and the rate of work E-Ji+_

In Engineering, managanent has focused on knproving egineering experience, rapmWib. and effecoveness, Progress has been made in a number of areas. includmg the reduction of configuration management and modificadon request utags These efforts, however,hve been overshadowed by problems in design consol

• hat were highlighted in the recent NRC !$1.

Since 1994, a substantial effort has been devoted to improving human performance a the site, and positive results have been achieved. However, Stadon managanent wularmands that there is more to do in this area. Management is Manks to take aggressive amions to reduce personnel errors and impnwe procedure comphance. Acdons to knprove the comctive action progrem and root cause analysis are a necessaryenemmaof thiseffort.

Dresden performance issses se being addressed through the resource applicadon. long.earm plans aM ether medans described in Secdons 5.13,5.1.4 and 5.1.5 below.

5.1.2 Namarement Team Mstab"t_ ; a suong susagement asam has been the key e achieving and susmining performance -

kaprovement a Dresden. Over the last two years, senior management poskians at Dresden have been Sued with pmven performers from other nuclear madons both whhin and outside the Comed system.

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ATTACHMENT Comed Response to NRC M.54(f) Request

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, Dresden Stadon's management team is b:! by the Site Vice President, who has over 32 yen s of real and commercial nuclear power etfetience. Prior to Dresden Station, he served as Vice President Nucitar Operadons at an operating BWR. Our Plant Manager)oined the Dresden team in 1995, after having served ar the Ccrporate Mainanance Manager, Superinnandent of instrument and Controls, and hCanager af Pharn Mannemance sa enhor nuclear sueons, and in various posidoi in the U.S. Navy nuclear ;rogram.

i De She Engineering Manager has 27 years of emperience in keh naval ed counmercial nuclea rower.

He has held various engineerhg roles (Project Manager, Assuammi Mant Manager. Maintenance, Manager.

Nuclear Station Enoneering) with other nuclear utilities and has also wested for a national laboralory.

De Este Maintenance Mar. age has held a variory of positions at several nucicar facilities including:

Rainological Engineer Heahh Physics Svpervisca, Radwaste Supervisor, Radiation Proeseticri Maager, and Maintenance Superintendent. Additionally, he obtained Senior Reactor Operatet Certificatiert Dresderi's Opunuons Manager has 1g y ears of nt; clear plant experience, including: Chemistry / System Engineer;1.eed Oseenist: Radiation Protection Manager Operating Engineer; and assessor for the Site Vice Presidera Overall, these individuals have over 100 years of both Navy and cornmercial nuclear power experience.

Additionally, they are supponed by the remainder of the Dnesden management team which has over 200 years of eaperience in both Navy ard comrnercial nuclear power, t

S.13 Resources in order to enswe sustained improvement at Dresden Station, the new management established a

, formahted business planning process which led to the development of the 1997 Operational Plan. This Plan seis fonh inidadves to improve station performance in concat with the NOD priorities of Safery, Production and Cost performance. The 1997 Operational Plan targets the areas of human performance / error reduction. material condition, and outage execution as specific performance goal areas to ensure accountability toward performance improvement and effective execution of the plan.

For 1997, the site has established a 5175 million dollar opermdng and maintenance budget. his budget

represents an increase of approthnately 18% over the 1996 budget and an approximate 13% increase from actual 1996 expenditures. Appotimately ?9 million dollars is associated with the following significant improvements:

• Material condition improvements e Vendor. supplied Equipment Technical Information Program (VETIP) backlog reduction

• Performance Camered Maintenance (PCM) program development

. Work control / outage activities

. 1.arge motcr repairs

. Housekeeping

• 24 month fuel cycle j e Design engineenng acervides e Engineenng program initiatives 5.1.4 Lang Term JaiprevementMass

, in August 1994, a critical, sysematic review was performed to descrmine the causes of Dresden's

perfotmance problems and identify means for correcting them. Based on this review, the Dresden Plan was developed as the overall blueprint for taising the level of station performance. De Dresden Plan

( covered 1994 through 1996, and included actions to correct the most significant weaknesses in five key areas: Management and 1.cadership; Matertal Condition: Human Performance; Performance Monitoring:

l and Radiation Protection.

i 27 l

4 ATTACHMENT Comed Response to NRC 50.54(f) Request in 1996, the site completed implementation of the Dned:n Plan and transitioned to a formal bunness planning process. This process led to the devs, a.t of the 1997 Operanon Plan which forms the basis for inqplement3ng acnon to sumain bc at Dresden Station.

PWm Sepennber 1996 through Domeshoe 1996, Ibe MtC conducted an 151 at Dresden Station.1he purposes ci the 1st west to evaluse the effecnymess o' the correceive acean 3r.yranA to provide an b@p Ant. assessment of conformance to lhe design and beensing basis, to evalues the conduct and effectiveness of maintenance activi;ies, hicluding work processes, post maintenance estag, and maintenance rule activities, and to provide an independent assessment of ogerational safety performance.

The NRC inspectors noted that commitment to haprove performance is evident in plant muerial Wm conduct of operatums, and management and organissional changes.

Droeden received the 131 Report in lase December 1996 and we have completed the process of developmg a comprehensive set of actions to address the danciencies identified by the IS!. Dresden's leser to the NRC dated Pehruary 26,1997 provides our detailed response to the identified deficiencies. A nanber of theoc actions, for the key 151 Andings, have been underway for some time, while others were developed following the imerim debnefs and the public exit meetir.g held with the NRC ISI team. The following manmarnes some of the actions takenin response to the !J.

Corrective ActionProgam lhe 151 noted that while problem idennfication had generally improved and corrective actions had succeeded in resoiving several historical performance problerns, weakness remained. Several steps have been taken to improve the idemification and correction of problems, and several more art planned.

In April,1997. Dresden will implement Phase 1 of the new Comed standard corrective assion process.

Phase 1 includes the use of common site procedures, an interim databa: ., and ===ananM saining for site persor nel. Phase II of the mandard corrective acnon process will be implemented in the fall of 1997 and will include the use of the final corrective action database and associated traming for site personnel.

To clarify thresholds at which problems se to be reponed, Dresden Adminisaative Procedure (DAP) 02-27, The /netsrated Raponing Proces (/AI), has bem revuod to provide taore concise duecnon for site persor.nel regardag Performance improvement Form (PF) initiation criteria. This revision also incorporated Mamtenance Preventable Pailmes (MPF) as a crnerion for PF initiation.1his procedure revison became effective on October 25,1996. Site persoruel art being trained to ensus understanding of the revised initiation criteria.

Dessden Engmeerms maw.t has tahen several seeps no encotz: age PF inicianon wahin the Engineenns W- Engmeenng Senior h;ement met with engineering organiaanon personnel

- in order to communicase expecanons for PF initiation, and a seview of the PIF database for 1996 was

- performed. Nuclear Engswesing Procedure (NEP) 103. "Dispaaman of Design Basis Discrepancies,"

was issued on January 20,1997, so cleari f daimesse management expecanons for PF generation by Engmeenns perscanal when daugn escsepeneses are identified. Dunng the first eight (8) months of 1996, abe agineerms orsamaanon ininsand an average of 49 PFs per month. During the last four (4) momhs of 1996, the average increased to 93 PFs per monttu almost double the previous vaanber, indicating that personnel art now more sensitive to PF initiation requusments. We will conanne to monitor PFinitiation leveis to ensurr that problem identification and reponing continue.

ATTACHMENT Comed Response to NRC M.54(f) Request To ensure strong root cause analysis in Radiation Promedon (RP), a contrts Vat Cause Specialist was .

usigned from October 1996 through January 1997, in Febi,iary 1997, a pes w Comed employee with signincant Radiation Prosecdori experience was assigned to the positioti.his individual is neponsible for error sendag and jarfonmente of quality self assessments, and will be included in the aview cycle of correcove acean rAmoval his indivishm! also enseres that actions aken for NTS item closure are =arl= and an et du inneaf W she aa==%ent. his andividual will remain on maff stil RP Lv L..a.t performance is W==y in the area of root cause sad correceive assionc.

Finally, the madon PORC has been a positive influence on safety at Dres6sn Station. Reviews of root cause evaluations, operability evaluations, special procedures and start-up reviews by the PORC have been performed in a thorough, critical and conservative manner.

Design Control De 151 identined problems in design and calculanon control. On November 12,1996, Comed submined tu acnon plan fr. ensuring appropriate design comrol. His plan was confirmed by an NRC Confirmatory Action Leact on November 21,1996.

Dresden assembled a dedicated team of senior experienced engmeering personnel to identify and nyiew key operaung parameters against symem calculations for the 12 most risk signifiant symems. his action was taken as part of a commitment made to the NRC on November 8,1996 regardag actions to ensure current masas of key afety synems. Dresden's neuer to the NRC dated M,, -y 28,1997 sransmined the site's verification report of key parameters for the twelve risk significant symems.

A program of audns of the Nuclear Steam Supply Symem supplier and seleN ArtinitectMagmoers (AEs) has been established to determme the quality of design control and calculations. An audit of the principal A/E has been completed which identified instances of technical errors and admmistrative and nview process weaknesses. That A/E is innalhng improved programs and procedures for design contml and calculation quality, Several additional audits are scheduled during 1997, Ernent Work and Vrork Manaaement

- De IS) identified improvements in mantenance processes, the knowledge, skills, and abihues of maintenance personnel, and a signiframly improved overall plant material condition, but also noted that the effectiveness of many of these improvements was reduced by the msnber of emergent work activities.

Sever:tl seps have been taken to reduce the amount ad irapact of emergent work and to irnprove work management so that both emergent and planned work are s..., ' .a4 more quicidy and effectively. These sepsinclude:

. A review was performed so duermine which sysums were most frequently associaned with emergent work. Proen this review it w conciwled that. in general, symems with higher backlop of conective mainsenance work accanted for most emergent work. la particular, a significant propornon of pas emergent work was anrfbessic to the Fire protation Symem and the Off Gas Synern, both of w~ach

. have had embeennal carreceive maintenance backlogs.

.- he Station experienced a high level of emergent wait in the weeks following martup of Unit 2, in September,1996, but emergent work levels have declined since that time. In October,1996, there were a total of 140 emergent work items for the Stanon: this level was reduced to less than

/ 70 imms per month in November and December 1996. His is still an area needmg improvement.

29

A1TACHMENT

( Comed Response to NRC 56.54(f) Regnest l

e To reduce work start delays, the Operations Department in September,1996, was reorganized to provide bener focus on ampliehing Out of Services to support scheduled work activities.

Additional changes to improve operations performance and coordmation in support of scheduled work are contmems. In ademon,in hasary 1997, the Opwanons Depenment implemented a process for pre approval of start of work for specific work pachases, which works to minimize delays while waiting for work mart approval at the Work Execonon Center.

• An* mal contract support has been brought la no nevelop performance measuremmt and management tools in the area of work managemen , A new set of these tools has been designed and impuemented to provide daily informanon to i ork control and maintenance managemmt to highlight performance strengths and weaknesses. l'enefits expected include improved work management M=. becer issource allocanon and utihaancm, and an increase in the rate of work c==al--

Undenmandag of Management Expectanans he ISI determined that Dresden management efforts to reinferce individual accountabihty for safety performance and to improve the capabilities of station personnel appeared to be effective in addressmg long standing obstacles to performance improvement, and that global expectations such as accountability, strictly adhenng to procedures, and teamwork were reinforced through multiple methods of communication. At the same time, the NRC ISI team noted that, due to management, supervisory, and process changes, management expectations for the accomphshment of work were not well understood in some cases, and that communicauon of overall mandards and expectations was noticeably less visible in

, the design engineering area. Actions recently taken or planned to communicate overall standards and I

ensure that work performance capectanons are clearly understood include:

• Operanons has aan=hli=hed a fixed period of ame in normal cycle training to discuss and reinforce management expectations. Operations Shift Managers utilize rouane c ww briefs to reinforce management standards and personal accountabilities maammwl with those mandards.

Routine orders are genwated by senior operations managers

. Since September 1996, new maintenance supervisors have been pnmded training on Station and Maintenance Standards and Expectations. his has specifically included expectations in the -

RP area. Maintenmice and Station Standards and Expectations are reinforced through weekly saff moeungs, management and supervision, pre job briefings and scheduled weekly shop meetings. -

. Since June 1996. Engmeenng has conducted accesitabthey meetmgs to review the status of sysaem improvement plans, projects and programs. An engmeenng expectaticas moeung was conducted on February 7,1997, with the Sne Vice President. Site Engineermg Manager, Engineenng Chiefs and Engineerms Vice President to review and ensure common understanding of significant issues, site and Corporate T.es. -h.g delivtr. ables, goals, projects, indicators and plans. Addmonal meetags with the Engineermg Staff were conducted in March 1997, to enswe i that Engmeers clearly undersand the expecanons of sannagement with respect to performance mandards.

. To ensure radianon workers understand radiological requirements, since October 1996, a

" Greeter" has been established at the entrance to the RPA. De Greener challenges workers before they enter the plant to ensure th.2 they are famihar with the requirements of their Radiation Work Permit (RWP) and to remind workers of high radiation area control responsibihties.

30

}

2 ATTACHMENT ~

i-( Comed Response to NRC $6.54(f) Request 1

['

As noted above, Dresden has taken or has planned action to address a number of the most important issues identified by the NRC 151 team. Dresden is implementing and tracking these actions through our Nuclear Tracking Sysaem and/or the Dresden 1997 Business Plan, and are reviewing progress in the .

] monthly performance asssamment messungs.

5.1J Faer Aceiser i

Dresden adnowledges the areas for knpw_ .t idenedied in the NRC's lener of January 27.1997, and

has two broad initiatives as a resuh.

~

First, as e;plained above, the 1997 Dresden Operanonal Plan provides the foundation for improvement '

accons at the sise. It seu forth initiatives no improve senden performance, and targets humaa performance

and enor reduenon. masenal <=bm, and outage saecunon as specific areas for improvanent. The

! Operstional Plan includes specdic perfarmance goals to ensure merrumtabdity toward performance

, improvement and effective caecudon of the plan.

i Second, as described in our 151 Response dated February 26,1997, we have implemented or have l underway actions to address the root causes identified by the ISI. 'Ihese actions include a substantial l upgrade, on a Corporate basi., to our conective action program, as well as site specific trauung to ensure that problems are identified, properly analysed, and effectively resolved. In addition, we have taken action to ensure that the deficiencies, unresolved hems, and observations identified within the body of the j iS1 Report are fully addressed.

l ' For 1998, we intend to use the Opeational Plan .n,.uid. to continue addresang performance problems l and sustain performance improvement.

i 5.1A Monisorsag Mechanirnas

! Dresden Station utilizes numerous mecharusms no monitor performance and evaluate effectiveness of 4

actions taken at the Station. On a monthly basis, the site distributes a management performance repon j that clearly summarues performance for the previous month in a clear and conene format. The Dresden

^

Operanonal Plan also contains performance targets by which progress in achieving performance improvement is measured. Funher, the senior managers meet with the CNOO once per month to review i performance resulu and plan corrective action for the site.

l Site depenments also have their own internal performance measures, for example an inurnal oent free 3

performance clock, assessment resuhs, rework, ermrs per operaung crew, and persorcl exposure, i

j To ensure dl site Waa.1 are aware of performance nasues, a site newslener is distributed three times j-'

per week. Several performance measures are reponed in each issue (e.g., event free performance, radioactise masenal control problem event free days, indusinal safety performance and product cost j perfonnance). Additiossily, the She Vice President conduca an all mation meeting every month to shscuss performance results semess in resolving performance problems, and other issues of kr.;,vii.nce.

]

I 31

ATTACtfMEhT Comed Response to NetC 50.54(f) Request 5.2 Quad Cities 3.2.1 Sammary q(rerformance -

Quad Cinies innplemanned a three year Cearse of Action (COA) improvement initiative in early 1994. '!he COA was a comprehensive plan for kmg-term i , _ _-.I which included actions to .MJwe management and leadership; facnonal organizanons such as operadorts, maintenance and enginoming:

and specific areas such as corrective action, self assessment, procedural adequacy and compliance, matenal condition, and safety symem performance. The COA has been effective in achieving performance improvement in many areas, as shown ki many of the sianon's key performance indicators.

As the COA cover leser stated, the COA was initially based on performance goals which met or a*

hose accepted by the industry at the time. As the plan has evolved, petformance has knproved, the standards have been raised, such that "World Class" goals have been realisticMiy set for achievement by the end of the next three year penod. The management team in place at Quad Cities is commined to sacellence and conunues to raise the mandards as each new pesformance plassau is achieved.

, The first phase of the COA involved puuing the right management team in place to drive isnprovement in accountability and performance. The immediate strategy focused on correcting material condition deficiencies, radiation protection issues, problem identification weaknesses and human performance deficiencies.

l Matenal condition has improved, especially with respect to those areas most important to safe operation.

l Quad Cities has initiated corrective action over time; examples include: (1) reduced Control Room Corrective Maimenance Tasks by 62% (from 58 in January 1996 to 22 in January 1997); (2) reduced Operator Workarounds by 50% (from 104 in May 1995 to 51 in Janusy 1997); and (3) increased Safety Synem Reliability by 33% (unavailabdity decreased from .027% in January 1996 to .018% in December 1996).

Radiation Protection improvement initiatives have: (1) reduced the number of Personnel Contamination Events by 80% (frorn 341 in 1994 to 70 in 1996); and (27 reduced Contaminated Floor Space by 50%

(from 23.2% in 1994 to 10.9% in 1996). However, overall radiation exposure remains high and new erategies to lower dose are part of the 1997 Opersional Plan.

Problem identification has improved as the station has genermed over 9,000 PIFs over the past three (3) years. Because the threshold for problem utenuficanon has been recogruzably lowered, problem identification is trendmg in the right direction.

Human performance improvement irutiatives me also begmning to be reahzed. Operator personnel error related 1 ERs have da:reased imm eleven (11) in 1993 to three (3) in 1994, one (1) in 1995 and zero (0) in 1996. Improvement has also been noted in declining conds in operation's sigmficant out of service events, operation's component =iq=w=ung spus, operation's wrong unit / train component events and causal factors aangned to operanons. However. lower level events connnue to occur and me being addressed by operanons management.

Improvement kt the aforememnoned areas is begimdng to be reflected in overall ===i performance.

Reactor water quality is being maimained more constmantly. The number of Engmeered Safety Features Acniations has been reduced by 88%, from 16 in 1992 to 2 in 1996. The mation achieved a 122 day dual unit run on February 28,1997, when Unit 2 was shutdown for a scheduled refueling outage. Following the volumary shutdown this past summer, both units have operated well, expenencing the second longest dual unit run in the plant's himory.

32

A'!TACHMENT CeanEd Response to NRC 59.54(f) Regeest

(

While these performance trends are clearly in the right duectum and indicate our previous efforts are producing posidve results, we se not satisfied with our present performsnce. Improvement is still needed and is underway to -.p.er. masenal condition, technical apport mad corrective action program implematadon. De resource appbcation, kmg aerm plans and caber assions described below address these issues.

5.2.2 Maangement Team in 1994, the new Site Vice President immechstely began to rebuild the leadership team. Proven managers were recruined to fill key positicas including, Stadon Manager, Site Engineering Manager, Site Quality Verification Direcoor Radiological /Chesnistry Sw/_ -"e Mamianance Sg- ' '=^. Work Control St.m ;L.t and Regulatory Affairs Manager.

The Site Vice itendent joined Comed in April of 1994, after canpleting a successful surnaround of a Region 1 single unit BWR plant. Prior to biaing Comed.he was Site Vice President. Nuclear Opwations and Station Duector. He has over 32 ye;r, of combined Naval and commercial nuclear power experience.

He obtamed a Seruar Reactor Operator (SRO) bcense and has managed Nuclear Operations, Training and Plant Support Departments. De Stadon Manager came to Quad Cities with over 25 years of experience

~

at a highly regarded Region 11 utility where he was Station Manager durms the successful turnaround of a dual unit PWR. He obtamed a SRO license at both of the utility's PWR sites and spent most of his career in various operadng positions including Operations Manager, Outage Manager, Operating Shift l

Supervuor, and Senior Reactor Operator. De Operanons Manager has over 15 years expenence at Comed in Operanons. Mamtenance and Engineering, and has also obtamed a SRO License. De Maimenance Manager joined Comed in January of 1995 with over 12 years total and six (6) years experience as Mannensace Manager working with the Station Manager at the same dual unit PWR. De Engineermg Manager has over 30 years experience in commercial nuclear power, havmg worked for two (2) Nuclear Steam Supply Symem (NSSS) vendess for a total of 17 years and nearly 12 years at the same Region D utility as the station and maintenance managers, where he was Manager of Nuclear Techmcal Support. Component Support and !&s, Component Specialists, Nuclear Plant Support and Non-destructive Exammations. De Site Quality Venfication Director Supenntendem has over 23 years of nuclear power plant exponerre, including eight yars as Quality Assurance Manager of a BWR plant for a utility in Region 1.

Dree quarters of the key managers ut expenenced in plant turnarounds. De average assuor manager has over 25 years experience and the management team has over 300 years of total Navy and commercial nuclear power exponence. Dree quaners o' the semor managers have SRO heenses or cernficanes.

Nearly half of the leadership team members have completed long and successful careers in the Nuclear Navy. Dree of the senior managers were Commanding Officers. Nearly half of the seniorinanagers have completed the INPO Serdor Nuclear Plant Management Course.

Anorher important aspect of the t-am is that it includes " beach strength" and solid succession planning.

Recently when the need mose to elevate the sensure of the Trammg Organizadon, the Radiological / rummy e ,

'= was apposnied as training manager. De scruar management posman veceasd in the process was filled from witidn by the Shift Operanons S,.r, v.a.

5.2.3 Resources ne stauon has been provided with sufficient resources to continue its planned improvements in 1997.

Quad Cities has a 145 Milhon dollar Operanng and Maintenance Budget for 1997. This represents a 20%

increase over 1996. 28.5 Milhon dollars is assocsated with improvement programs. Our current plan (which may be changed as necessary) includes improvements mch as:

33

ATTACHMENT Comed Response to NRC $0.54(f) Request

• UFSAR Compharee Review

• Instrumemation and Control Calculations

• ElectricalCable Program

• Reacsor Recartalation Sysem Valve Packmg Desip Change

• Puselist

• Maner EquipmentIJst

• Drawing Update

• Engineering and Maintenance Backlog Reduction

• Control rod Drive Hydraube Control Unit Rebuilds

• Design Bases Reconstitution and Validation

• Vahdation of Design Basis Documents

• Dm4.a.; of New Sysaan Design Basis Docummts

• Development of New Topical Design Basis Documents and Safety System Funenanal Inspections The station's budget for capital ; .,,,vsments in 1997 is 25 Milhon dollars. Planned improvements include:

i 4 Reactor Rectreulating Pump and Motor Refurbishments

• Torus Suction Strainers

• Electrical Cable Replacements l

• Core instabihty Monitoring System

(

• Control Room Upgrades and

• Zine Injection 5.2.4 Long term improvement Plans Although the station is completing the three year COA a similar ongoing pmcess will be used to chart the course for improvement initiatives in virtually all aspects ofin business. Each year, the COA was translated into annual management and operanng plans. Annual operational plans will continue to be used to manage future improvements. .

Pian Develcoment The current station improvement initiatives are reflected in the W Cities Station's 1997 Operadonal Plan." This Plan is a key element of the change management process.

The Operational Plan is divided into four sections. %e Operational Planning Process secdon describes the plannmg process employed to develop the Operational Plan. Se Gap Analyses section describes the current performance of the plant's key performance measures in the areas of Safety, Production and Cost, the gap between current and desired (targeted) performance, and the analyses performed to identify strategies, strateg2c e and managemem initiativeshmprovement efforts. The Aerion Plans aecnon describes the acuens resulting from management inirWves and improvement efforts. This section is "living " as improvement efforts progress through their :malyses, the content will be updated as needed.

The discussion of fumre accons below emanarums the most impanant improvement initiatives. The Financia!Sammary section contains O&M and capital summanes for the indsated projects based upon 1997 priorities.

. i k

l I ATTACHMENT l i l' j Comed Response to NRC $6.54(f) Regnest

, As stated earlier, the frst step in the Quad Cities performanceeim vsc.t process was to build a leadership team. Next a process to set targets and monitor progress was installed. The Integrated

Quality Effort (lQE) progrun was ==hlahad in 1993, and nSned to melude lessrms learned frorn the , ,

[ first year of i ;'- *=_1he IQE data provides she managers with useful tools to monhor perfonnance, idsafy, and correct deviations frorn goals as qmckly as pourible. Performance indicator i

windows are developed and incorporised into IQE Windows performance indcating process Subsequent to initial developnent, indicators are nyiewed and revised as necessary, j Mechanisms were put in place to communicate expectations and sandards, provide feedback an

' perfamaace and receive feedback from the organtzation. Mecangs between the Site Vice President and each cogntram manager are held to nview the manager's performance during the previous month. 'Ihese i meetmas measure the effectiveneas of management in aseing standards, reinforcing defined performance l expectations, and achieving desired resuks. The Site Vice Praident typically conducts a monthly meeting l with all site personnel. The Site Vice President and Station Manager conduct a monthly meeting with all Depenmem Heads and First une Sapemsors-l

{ S.2.5 Fasure Acaions l Improvement plans are underway to improve the Station's matenal condition, technical support and corrective action program implementation.

Matenal Condmon i

l Improving the station's ability to resolve matenal condition and equipment issues is a key

• strategic" 1

component of the Quad Cities Station 1997 Operational Plan.rIm w;; .r.t initiatives include:

i m harktmg of work requests in the station backlog: aligning of system surveillances and Pnventive j Maimenance (PM) work into their respective work week windowt backlog reduction; achieving goals in i' key matenal coodition indicators; improving execution of maintenance work processes; and reduction of j equipment related Operator Compensatory measures.

l Technical Support l Substantial efforts are contamed in the 1997 Operational Plan to improve schnical support. These efforts

and additional actions to be taken include: establishment of a Planit Response Team; improved trainmg for engineers on the sianon hcensmg basis and toot cause analysis; and reduction of the station design

l. drawing backlog and open design changes.

} The quality of Root Cause Analysis (RCA) will be anproved by the h' , H of addmonal system j himorical packages and by further trauung of specific - I in RCA techniques. The historical

! packages prtmde the angmeer with eqmpment failure hissones. This information allows the engmeer to i focus the root cause effort on the t.cenpanents with the highest failure rates. This training is scheduled 2-streushout 1997. An effectiveness aview of the trainmg program will be conducted to determine future

trammg requnements and any regered changes to the program. Systems selected for hissancal package l development include Rectreulation.125 VDC,and Instrument Air.

i A substantial effort to prioritize and schedule engineenng resources is in progress so that the proper focus can be placed on the corrective action issues. The Plant Response Team will deal with day-to day j emergent issues. The mission of this team will be to deal with emergent issues in a timely manner to 4

j allow the production arms of engmeenng to focus on process, equipment reliability and longer term i initiatives.

35 i

ATTACHMENT

( CounEd Response to NRC $9.54(f) Request i

Effective Comenve Acnons Comed luts undenaken a NOD initiative to improve he Corrective Action Process in all six nuclear sites.

De imisiaives inchde the adapuan of common NOD procedures or innructions on the identification, root cause de6 sdnsom, suchng and sendag, s==na=== and measurument of effectiveness of corrective acuans. Dese procedia as and inansecons ha* e been reviewed, sypoved, and implemented at Byron and are currently being adopted by each of the respective mance management teams.

5.1.6 Monkerkng Meckenkas implementation of the COA was closely managed and periodic status reports were submined to the NRC.

The susus repcr * : were stunined in December of 19M, January of 1995, May of 1995, Mmeh of 1996 and the close.out leser will be submined in April of 1997. These reports reflect significant progress in esecutmg the COA. In nany cases, the actions taken have been judged to be effective in producing the

, destred result. In some cases, however, the actions have not been fully effective and work continues in the l 1997 Operational Plan. Specifically, we are seeking toimprove the station's masenal condaion, work management and technical support.

l De 1997 Operadonal Plan is also being closely managed. Quad Cities espects that the plan will be successfully implemented as shown by the three previous management plans. In addition to the normal implementation process, this year the nation managers have teamed together to ammhhth some short term milemones. In January, the senior managers worked together and idennfied twenty one goals for the orpimim to fr s on. The goals were selected based on their priority and included goals which sneasure progress in addressmg povious performance problems.

De manon also uses a number of other mechausms to monitor progress and mesure effectiveness. In addition to the IQE discussed above, the nation prepares a monthly status report including information from all key funcuonal areas. Informanon includes actions taken, self assessment activities, challenges and lessons leamed as well as dozens of bdividual performance indicators and nonds. - Also on a monthly basis, the Vice Prendent and CNOO meet with station manageenent and reviews manon performance and progress.

Quad Cities has enablished a solid track record of implementing its management plans over the past several years and, based on the results discussed above, the actions which have been taken are generally producing the deared unprovement.

e 36

ATTACHMENT

\

Comed Response to NRC 54.54(f) Request

[

• I .

5.3 LaSalle 4

l S.3.1 Summary nfPerformance Over the past two years,l.aSalle has experienood dochmng perfonnance. Early in :his timeframe, performance was declining as demonstraaed by *.ncifective correictive accan, degraded material conditions, human performance erors, procedure adherence deficiencies, inability to complete work and difficuhaes in bo.h configmanon management and ccrifiguranon controls. His declining performance resuhed in several instances of escalated NRC enforcement aedons, and lower S ALP and INPO performance ratings.

While attempting repairs to the service water system,in June 1996, a safety.significant event occurmd which indmated that performance weakness continues to exist in a number of areas. De CNO ininated a comprehensive ISA of performance issues at LaSalle (and Zion). De ISA, described in detail in Section 4.1 of this anachment,identi6ed four fundamental causes of performance weaknesses that needed to be addressed.

Begmnmg in the fall of 1996, a set of targeted improvernent initiatives was undenaken to reverse the performance trend and demonstrate that LaSalle could initiate and complete its improvement plan, the 1996 Operational Plan. Resources were WM o tthe identincation, prioritization, and correction of material condition deficiencies. Additional resources were allocated to ensure continuing improvements in plant conditions and program effectiveness would be reahzed.

On September 22,1996, a sticking servo caused a Unit I turbine valve to fail open. Rather than soubleshoot the servo on lme,LaSalle management decided to shut Unit I down for repairs Subsequemly, on September 24,1996, the NRC laspection of LaSalle's Semce Water System raised concems regardmg the operability of a Residual Heat Removal Semce Water heat exchanger Based on LaSalle's preliminary review, Unit I was placed in ooid shutdown on September 26,1996, pendmg resolution of this issue,1 Atte Unit 2 was shutdown on September 20,1996, for hs scheduled refueling outage.

Since that time, LaSalle managemem L u decided not to restart either unit until the material condition, operator performance and engmeenng s tpport issues are resolved. De following actions have been undenaken to address these performanca issues,

• la engmeenng, functional performmce reviews of systems important to safe and reliable operation are being performed to etsure that any deficiencies am idennfied and corrected prior to startup, %ese reviews include a fur :nonal performance compenson to the design basis. Risk significance is a key element in syn m selection. his effort will also include =te*M funcuanal testing of the systems to confirm performance capabilities. We are also performing reviews to identify modificanons that may have been pericutned outside the design change process.

• In the ama of station teamwork, progress has been made in relations between management and workforce personnet For caampic, enlarts to engage the workforce have produced Instrument Mamienance teams that idennfy and resolve problems.

• In operations, training matenals and methods are being reviewed and improved in order to provide high quality, additional trauung for operanng personnel. In addition, to improve operator performance, we are clarifying traming objectives, evaluating the efectiveness of our i trammg instructors, and upgradmg our simulator scenarios.

37

ATTACHMENT t

( Comed D=pa== to NRC $0.54(f) Request

• To improve corrective actions, we have applied additional resources and are holding penannel accountable for the quality of root cause analyses and the effectiveness of the corrective action saken. .

• To reduce challenges to the ww., we are reducing the number of operator workarounds, semporary alt r. 'ons and control room deSdencies.

• To improve human performance, we are emphasning individual accountability and focusing on communications across management ranks and vertically throughout the organization.

Many of thcae actions are i ww ed w in the LaSalle County Station (LCS) Unit 1/ Unit 2 Restatt Plan.

In January,1997,l.aSalle was placed on the NRC's Watch Ust as a result of matenal, human performance, and engineering deficiencies. The NRC recognized that a number of management and organnational changes and improvement initiatives have been made at LaSalle, but noted that their effectiveness had not been demonstrated Actions underway to address the causes of LaSalle performance problems are described in Sections 5.33,53.4, and 5,3.5 below.

5.3.2 Management Team 14Salle has developed a strong managemem team with a track record in management of nuclear power plants, including Comed plants, other commercial plants, and U.S. Navy plants. The average senior manager has over 20 years experience and the Site Vice President and his direct reports account fc a total of over 191 years of experience. Fifty.nine percent of the senior managers have SRO licenses or cenificates. Nearly 31% have completed careers in the U.S. Navy and an equal percentage have completed the INPO Senior Nuclear Plant Management course, in August of 1996, the new Site Vice President joined Comed from the Insti ute of Nuclear Power Operations (INPO), after having most recently se:ved as Vice President of Training and Education and Executive Director of the Nanonal Academy of Nuclear Training, '!he Site Vice President joined INPO after serving a 20 year career in the U.S. Navy's Nuclear Power Program, The Plant General Manager has more than 20 years experience in nuclear power."Ihe Unit 1 Plant Manager has 30 years of expenence in the snanagement and supervision of commercial, Naval and Government facilities. His experience includes positions as Plant Manager, Manager of Reactor Operations and Maintenance Recovery Manager at other nuclear power plants. The Unit 2 Plant Manager had obtained an SRO Ucense at a PWR and served as the Operations Manager, Mamtenance Manager, and Work Control Superintendent. The Engineering Manager has 29 years of nuclear experience and has been involved in many performance recovery programs On December 12,1996, the LaSalle Site Vice President araounced the decision to transform the LaSalle organizauon into a urutned organization. The unitization of the station organization enables management to be dedicated to each of the two units. 'Ihe result of the unitization transition will be more focused management attention on openeions, maintenance and work control for each unit.

The unmnt<m will also resuh in a significant increase in the number of sisgr.h and managers who will coach, mentor, train and instill a focus on the station priorities. With an increase in supervisor and worker involvement, and a clear focus, the improvement efforts should result in improved performance.

To fill the additional rnarutger and supervisor positions, the Site Vice President has rectuited a number of f experienced personnel external to Comed. Many of these managers and supervisors have demonstrated experience in turn.around situations.

38

e 9

ATTACHMENT l CeanEd Response to NRC 50.54(4 Request 5.3.3 Resources laSalle Station has identined the Snancial neources nomssary to 1.nprove the statmn's performance. -

Resources have been hd to the identincanon and prionnzation of material condition and design basis deAciecaes. This effort has resuhed he the refebishmet of severa* rnak pieces of eqwyrnent and die vosolsmon of ciber cnacal de6cioncses. Efforts to upgrade matenal condition of laSalle Station are continuing. laSalle 0404 fwidmg for 1997 has been idatined based on the Rastart Plan to apport mapr improvement initiatives as well as daily opention to mswe that the plant can be properly operated.

. maintained and improved . The curnnt O&M budget of $160 milhon is under review to assess the impact ofIS A issues and restart.related work. Our commitmmt is to provide the resources that will achieve and estam neussary improvements.

Currently planned unprovements include:

• 24 month refuel

• Design basis document improvement

• IDATA

• System functionalreviews

• Scipoint improvernents

• UFSAR upgrade

!

• 480 volt switchgear

• Improve technical specifications

• Getting work done initiatives

• Painting

• Matenal Condition improvement Plan

• Maintenance backlog reduction

• Plant labeling ,

• Operaung and maineenance rJ-

• Mixed waste disposal

• Station heat improvements

• Design reviews

• Contract work analysts

• SBM swaches Staffing accons to fiD positien vacancies and increase staff expenence levels are continuing, in addition, nsources have been budgeted for suff augmenanon on a temporary basis during peak activity periods.

The improvensuus to the physical plant, upgradmg of programs and backlog reduction siitiatives began in 1996 and will cetinue. Under leadership of the new management seam, plannmg was formahzed with development of the LCS Unit INait 2 Restm1 Plan. The resources necessary to isnplement the unprovement actions in the LCS Unit INnit 2 Resurt Plan were then esumated and reconciled agamst the 1997 O&M budget in late February 1997. Evaluauon and approval of fundmg needed for the nunamder of 1997 isin progress.

39 x U

ATTACHMENT CoenEd Response to NRC St.54(f) Request S.3.4 Current and Future Acaions Ramnanse to the ISAT -

An IS A was perfonned dwing the fall of 1996. Phal seenlu were published on February 18.1997. De results of the ISA confirmed that LaSaue had identified the mywity of their wealmesses ad had established ccmctive acnons cm the appropriase assues. One of the benefits c(the ISA was the depth of undernandag as to why the wealmesses exist. LCS Unit 1/ Unit 2 Restart Plans address the ISA issues regarmg short term focus. Long-term issues will be addressed in fuase Opwational Plans.

n=n ., to 1 Malle . hrine t u.s in NRC's !=- =v 27.19m =

De weaknesses identified as a result of the June 1996 Sesvice Water Scalant Injection Evasit have corrective actions that were incorpcrated in two improvement plans. De recommendanons fruen the root cause investiganons of this event are tracked in the Management Review Meenns report reviewed monthly by the Site Vice President and the CNOO. he completion of the LCS Unit 1/ Unit 2 Renart Plan will address all of the issues discussed wahm the Januar/ 27.1997 NRC letter. In the futwe Operational Plans will be used to connnue to build on the improvement efforts initiased from the LCS Unit 1/ Unit 2 Restart Plan, i

t Carrective Action Pronram Problems with ineffectiveness of carective actions have primariff been caused by poor corrective action process bnplementation. Corrective actions are in progress to strengthen accountability and improve implementation. IIS will adopt and implanent the new NOD wide Corrective Action Program later this Y88f-Restart Proeram Overview

• De Renart Program consists of an integrated set of complementary programs and activities that will result in the highest level of confidence that power operations will be safely initiated and LaSalle's wiits returned to taliable full power operation in a controlled manner. De initial nation focus is on Unit 1:

however, the restan process and most of the specific aedons are also appbcabic to Unit 2.

The Restan Program conasts of four phases as fouows:

• Wort to be completed prior to unit restart,

• Work compleuon:

• Restart and Operational Readiness Evaluation: and

• Unit Renart and Power Ascenmon.

Work to be CongpletedPrior so Unit Restart Comprehensive evaluanons ase being er=areadt o define the scope of work reqmrmg cornpleten yior to unit restart. He resulting work scope inciudes significat acnons relating to LaSalle's , w.s.d.

processes and plant egepment to correct idenafied deficiencies and improve opersonal safety performance, i

O

A1TACHMENT Comed av to NRC 56.54(f) Request Decisions to include specific hems in the current LaSalle Unit 1 (LIF35) outage work scope are made using a process tha: engages both senior site management and station personnel and is based on a foundation of ensurms operational safety, Poesntial work hems are being identified from many sources hicludmg she following:

e innsenal sed externalanseessaans:

• Review of backlogs (e.g., saamsenance, engmeerms, operadons, corrective acoca program PIFs);

e System functional performance reviews: ,

• Sysuun readmess reviews,

• Commirnants review,and

• Personnel and plant perfosmance trends.

Site management is responsible for enabbshing the scope of activities requiring completion prior to unit restart and for vertfymg that the work has been successfully completed. Individual work hems are evaluated by the line organizanon, and their recommendations for inclusion in the outage are sviewed by the supervisor / manager, Hardware oriented hems are evaluated by the Scope Control Comminee and kerns that are significant in scope are reviewed by the Senior Management Review Commhtee (SMRC).

The SMRC also reviews the scope of significant non-hardware work hems, e.g., desennining the scope of l

l the System Functional Performance Reviews and the need to either expand or truncate this review program.

Work Completion I Work required for unit restart is completed under the direcnon of kne management using plant processes i and procedures for execuoan and consol of work, implementation schedules are =hhnhed and unanaged by the Outage M*nart organizanon for all plant hardware criented activities and m4or non-hardware activities. Work completion is documented consistent with plant process and procedural sequirements with oversight fu effective job compleoon provided by line management and LCS oversight organizatioru.

Restart and Operational Readiness Evaluation A thorough assessment of the readiness of the 1ASalle plant, Wal, and work processes to safely begin unit restart and initiate power operation will be completed and used as input in the decision by the Site Vice President to proceed with unit resart. The self. assessment to be performed by each LaSalle organization is an element of the LCS Unit 1/ Unit 2 Restart Plan and will culmmate in r. recommendation from the Plant General Manager to the Site Vice President that unit restart be initiated. Detailed guihce for the conduct of self-assessments will be developed as part of this LCS Unit 1/Unir '2 Researt Pit.n. .sn additional element of this process will be the h * , - t and epproval of a Restart and Power Ascension Plan that summarues the key accons, mile tones, saanagement approvals and cor,tingencies that will be implemenaed during the sesamt process. Adiuaanalinput regarding the readinets of the LaSalle plant, personnel and work processes will be obtameri from the PORC, i+a-t-at oversight organuations such as the SRB, SQV and from other inputs at slu discronon of the Site Via President.

UnitRestartandPowe, Ascension Following apprtreal from the Site Vice President to initiate unit restart with'the intent to proceed to full power operation, plant operators will initiate restart and power ascension ir accordance with an approved

( Restart and Power Ascension Plan.

41

ATTACKMEhT ,

CenEd Response to NRC $0.54(f) Request 5.3.5 Long Term improvement PJans i.eng-term safety improvement at I.aSalle requires achieving significant improver 9ents in the five key performance areas. A brief summary oflaSaue's current performmee in these areas anc improvement actions in progrees at this ilme are provuled below. Many detailed acsion plans are being developed Ihroughout the manon to implernent these heprovements. The Restart Action Plans, discussed above, support knprovesnenu ki these five key areas while implesnenting the specific correceive actions required for urut restart. In addition. improvement initiatives are being refocused to ensure tha: the resuhs of the ISA described in Secuan 4.1 are also accommodated.

Manneement 1 **da thin and E&crivsun Management leadership at 1ASalle has not been effective in estabhshing the managemet systems, safety culture and performance isnprovement envronrnent necessary to simultaneously achieve excellence in

, nuclear safety, production and cost. Therefore, the following actions are being taken:

Performanteimprovement Actions:

Recruiting management personnel with industry expenence at plants that have achieved excellence in nuclear safety, have participated in significant performance improvement programs and/or who have demonstrated the ability to sustain high standards for safety performance:

I

• Implementing a limited unitization of the Station organization (Operations Mamtenance and Work Control) to bener focus management and staff resources on resolution of specific problems, improve communicanons between management and the plant staff and to speed improvements in human performance and the plant matenal condition and s

Establishing the basic fundamentals of effective management such as high standards for performance, indivihal accountability, orgamzational teamwork, monitoring of specific performance measures and regular management foUow up.

Oversicht and Awa .. ara .

The implementadon of oversight and assessment activities at LaSalle has not canamently assured that potential safety and performance problems are identified, appropriately evaluated and fully resolved in a timely manner. Therefore, the following acnons are being taken:

Perfornaanceimprovement Actions:

Cn==11da'ing safety assessment and other oversight functions to provide organizational focus and broadened oversight responsibihues A new management position has been enablisled to focus this effort and to drive safetyperformance knprovement; e bnplementing regularly arhMad department self assessment reviews with the Site Vice President and the Plant General Manager to reinforce line management responsibility to establish high mandards for performance, identify and resolve their problems and performance weaknesses, and to implement an envronment of continuous self assessment and

( improvements:

42

ATTACHMEhT Comed Response to NRC 50.54(f) Request

( Feahinhing the SRB and re-focusing the pORC to provide a higher standard for plant performance and to implement a more rigorous a .d critical review of plant activities and work products;and .

• Creatmg m Eng'meerms Assurance funcnon, ed staffing it with personnel experienced in syseen and design basis management,to ensure ties engmeermg work products meet performance expectamens and to provide the foundation for sustained improvements.

Human Performance Fundamentals of good human performance have not bem. effectively implemented at laSalle resulting in operational afety performance below industry isandards. Examplos of less than acceptable human performance at LaSalle include unclear procedures and/or not fouowing procedures as wrinen, not consistently implementag self checkms as a routme job activity, not accepting personal accountability for each and every job activity mot isnplemesang a questioning attitude that exemplifies a strong safety culture and not effectively communicating job requrements and status between or*=W1 Therefore, the following act% are being taken:

Performanceimprovement Actions:

• Implementing dermitive management actions to reinforce expectauons for human performance and to solidify the site focus on safe operanons, e.g., insistence on procedure adherence and stop work actions to focus on human performance errors and key lessons learned.

• Reauocanng personnel and reassigning nsponsibilities to ensure supervisors spend more time coachms, mentoring and reinforcing standards for performance in their work groups;

• Developing and using petformance i:xticam that higidight key areas of human performance weaknesses, e.g. mamtenance rework, operator huma performance errors, out of service errors:

i 6 Ensunng that personnel follow procedures and initiate procedure reymons to correct the pw iss in cases where they cannot be effectively fouowed as wrinen.

• performing an independent review of key engineermg work products (e.g., operabdity evaluations, safety evaluations and root cause analyses) using expenenced extemal engineering personnel as a method to both raise the job performance standards and train LaSalle personnel on how to achieve those standards; and engaging the work force in identifying and resolving the barriers in work practices, processes and procedures that can potennally lead to human errors.

Cnti::al Work Processes and Proqtrams Critical work processes and programs that are used to actueve afe and relialile operation have not been fully effective due to barners sud as cumbersome or confusmg process controls,inadequale trendu g and monitoring, poor performance measures and an insular .w AA Oct did not take advantage of i*.dustry lessons learned. Therefore, the followmg actions are being taken:

Performance 1.nprovement Actions:

• Implementing work control process improvements to aDow work to be efficiently completed in the field and to muumize the occunence of in=l~;"~ work packages; 43

ATTACNMENT Comed Response to NRC $0.54(f) Regnest Including critical work processes ar.d programs in the scope of depanment self assessmeni activities and implemendng self asessments focused on specisc programs, e.g., Outef. Service Program and the laservice Testing OST); and -

Developent perfemance asenres for critical wak processes to meanse the effectiveness of their implementanon and to highhg4 wees of posenmal wanh==en e.g., Out.of. Service Proomn.

knplementanon upgrades in the Corrective Action Program to answe problems are identified, causes are determined, corrective action imi': cf- 1 and effectiveness of corrective action is evaluated.

Plant Material Condanan The laSalle maserial enneman does not meet hdoery standards for excellence as kubcated by the size of maintenance backlogs, occunence of repetitive equipment problems, number of operator distractions (operator workarounds, s..,~,.fy alterations and control room deficiencies) and system performance history and trea.is, Therefore, the following actions are being taken:

Performanceinvrovement Actions:

+

Impir.nenting aggressive actions to fix plant deficiencies through the Malenal Condition Imp ovement Program and resolution of operator distractions through completion of the Restart Plan

- +

Using the Conective Action Program to drive identificatum and resolution of posannal plant matenal condition deficiencies through review, evaluation and trendmg of PIFs; Redefining the System Managerjob requsements and performance expectanons to exclusively focus on system management, i.e., ensunng that each system is capable of perfonning its design functions on a reliable basis; and Raising standards for acceptable plant material condition through in-plant walkdowns and -

mspections.

5.3.6 Monitann Mechanitas -

LaSalle is using a number of mechanisms to monitor progress and measure effectiveness. The Site Vice Presuhnt and Plant General Manager corukset regular self. assessment meenngs to monitor restart preparation. The sianon conducts frequent Restart Plan Review meetings. Dunng this meetmg restart action plan manas is reviewed. The manon has a monthly Pra=nt Review Meetag (MRM) at which she Sise Vice Presdent and CNOO roview the performance of key funcnonal areas. The MRM is also reviewing Restart Pian effecsiveness. The nation has MM a SRB meenng in April 1997, to review the manas and effectiveness of the LCS Unit 1/ Unit 2 Restan Plan. These reviews are targesed at measunng progress in resolving the causes of the September 1996 event and other performance problems.

1 44

w, .

- A'!TACHMENT ,

f Comed Response to NRC 50.54(f) Regenst I -

5.4 7 Joe 5.4.1 Summary ofPerforsmance Ikun 1994 to 1996, Zion's performance generally dachned, and initiatives to upgrade operator performance, suprow maserial candinon, ad efficassaly pts ad saaceae work had limited success. De bnprovement trend that had been evident in 1993 was not maintamed following the dual mit outage that ended in Spring,1994.

In February,1996, the NRC rated Zion a Category 3 station in the SALP area of Operations, citing inconsistent operator performance marked by frequent personnel errors, especially toward the and of 1995.

De opersoonal performance problems had a number of contributors, including a lack of procedural adherence and inanention to detail. Many of the errors led to 1spees in the proper control of plant .

configuranon, a problem also noted in the previous SAlf report. Operanonal errors and unplanned

, configuranan changes consmued throughout 1996. Corrective acuans were either ineffective or untimely, and as a result, the NRC issued an escalaned enforcement action to Zion in August 1996. A public meeting was held in October,1996, at the NRC's request to discuss additional operational errors. On February 21,1997, an operational event occurred involving inadequate control of reactivity changes during a reactor shutdown. In this event, problems were identified with the command and control of shift activities, crew communications, the execution of on shift . ,,,s,issilities, operator unining at maintaining the reactor at very low power levels, and inadequate corrective accons to precursor events.

Also during 1995 and 1996, numerous equipment problems adversely affected plant operanon. De maaneenance backlog problem was compounded by chronic work process deficiencies, an inadequate prevemative maintenance program, the limited effectiveness of work planning and consol processes, and the inadequate quality of routme work activities. The number of equipment workarounds was an

-,sessary challenge to operators. Efforts to make lasting improvements in this area were compliemed by a continuing failure to consistently detamine lhe root cause of problems and take effective corrective actions, in the engineerms area, a comprehensive inspecuen in July August,1996 idenafied significant deficienews in the overall execunon of engmeerms activities. A weak modtficanon process, inadequate safety and operability evaluations, lack of control of the Technical Specificanon Interpretation process, madequate resolution of recurrmg eqmpmat deficiencies, ard poor procedure adherence and quality -

reflected significant wealonesses in engmeerug support to the station. On March 12,1997, the NRC issued an escalated enforcement action as a result of these findmss, in the fall of 1996, Comed commissioned an ISA of Zion performance. De ISA described in Section 4.1 of this anachment, identified four fundamental causes of performance deficiencies. Zion's performance problems, includsg those idenafied by the IS AT and in the NRC's January 27,1997 50.54(f) lener, are being addressed as described in Sections 5.4.3,5.4.4, and 5.4.5 below.

In January,1997, the NRC placed Zion on the watch list, citing concerns with operanonal errors, plant equipment problems, wh=< in engmeenng activanes, and conunuing deficiencies in radaation protecnon and the control of radioactive matenal.

45

ATTACHMENT

( Comed Response to N8tC St.54(f) Request i

To arrest the declining perfcemance,in August,1996 Comed began to put a new management team imo place to drive improvenent in accoumability and performance, As described later in this section, essennally all of the senmar managers at Zion are now new to Comed or have new jobs at Zion. Enhanced emmunescatmn of mangemet especemons for maff performance occur at weekly performance review meetmgs for all senior managers at the deparanet head level and higher Augmented and susngthened management review and ovenght of engsmeeng work was enabhshed. Work standdowns were initiated when several significam errors occurred. Aad,isnporantly, sigmficam resources were devoted to identifying the root causes of current performance wenknesses Further short term and long-term actions so effect performance irnprovanem are addressed in mort detail in a subsequent paragraph.

S.4.2 Womattawar Team Zion Satica has acently exponenced significam changes in leadership, with the addition of many individuals with prove exponence at effecting improvements at other sites. Also, Zion has recently put in place a unitized organizanon to speed snprovement efforts. This organization change conssts of a limited unitization of the Stanon organization, focused on Operations, Maintenance and Work Control.

Unitization is a short term organizational tipproach to provide increased management oversight and to aid performance improvement initiatives. With this organizational structure, managers will spend more time in the plant obserymg operations, meeong with workers and removing barners that impede work.

DW-d unit work teams will support spectfic units, allowing workers to concentrate on issues l

specifically related to their unit. The unitization also has provided the oppornmity to bring addauonal proven leaders with fresh perspectives into the Zion organization.

New senior management positions have been creased for the Plant General Manager, Unit I and Unit 2 Plam Managers, Unit I and Unit 2 Operadon Managers, and Unir I and Unit 2 Maimenance Managers and Work Control Managers. The existing organizational structure, within the Maintenance and Operanons orgamzations will essentially be rephcated for each unit, with some few exceptions related to speciahzation of responsibilities for some individuals. 'Ihis new orgamzational structure will provide approumately 8 additional positions.

The managemem team i: led by the Site Vice Prendent who has approximately 12 years of commercial nuclear power plant expenence. His background is strong in mahnenance and opersuons. Prict to Zion Station, he was the Vice Prendent for Nuclear Energy at a utility and had previously been the Plant Manager at another utility. In his previous assignmems, he has demonstrated the leadership reqmred to effect performance improverness. He served 20 years in the United States Navy and held a SRO license.

The Plam General Manager has approumately 18 years of nuclear power plant exponence. He was appointed the Plant General Manager on March 4,1997. Prior to this recent promotion, he had served as the Zion Unit 2 Plant Manager from January 20,1997 to March 4,1997. He will retain his responsibilities as the Unit 2 Plant Manager umil the Unit 2 Plant Manager position is filled. Prior to Zion Station, he spent his entire career at another multi-plant nuclear utility, where he last served as the Manager of System Engineenng. Prior to that, he was the Manager of Operations and Maimenance and also held an SRO bcense. The Unit 1 Plant Manager has approumately 24 years of nuclear power plam expenence, and worked most recently as a utility's Division Manager of Nuclear Operanons. He had previously held positions as the Manager and Aasistam Manager at a nuclear power plant and held an SRO bcense.

Zion has a management team with strong eqerience in management of nuclear power plants. The senior managers have an average of over twenty years of expenence with nudear power plants. Twelve of the

{ sineen most semor managers have held SRO licenses or certificates. Seven have had prior experience in the United States Navy Nuclear Power Program. Four have completed the INPO Senior Nuclear Plant W9...c;a course.

46

ATTACHMENT CeesEd Respense to NRC M.54(f) Request 5.4.3 Resowces .

The station has been provided with sumenent neources to complete its planned improvements in 1997. -

De Operanns and Maineenance badget for2ica for 1997 totals $157.6 million dollan. his represents a 30% bcresee over the 1996 budget, and a 5% increase over acesal 1996 year and spendmg levels. De manon's budget for capaal '# - in 1997 is $17.7 million dollars, an increase of 15.9 milbon dollars overlast year.

Staffing levels are also being inenased, he permanent staff is expected to heroese by appenzimately 7%

over 1996 levels, so a stamng level of 931 full time equivalents. In addition, resources have been budgeted for contract personnel and statiaugmenation, on a temponry basis, durms peak activity Periods.

Among the key improvements currently funded are:

4

• Backlog Reduenon in Several Key Areas

• Work ExeevoonImprovernents

• UFSAR Reviews -

l

• Design Bases Reconstitution and Vabdation l

• Reactor Coolant Pump Motor Refurbishment

• Safety Symem Reviews

• ProcedureImprovements l

5.4.4 JarrovementPinar saaf Accoas' To specifically address cenam of the concerns with the 1995 % operational performance,in September, 1996, Zion implemented a short term inte:vention plan designed to address immedate needs for improved operational performance. Actions in this plan focused both on plant operanons and on the support necessary to the workforce in the field to climinate operanonal challenges and events. De plan had five major strategies, including: (1) improving the management and implementauon of the surveillance program: (2) improving the prioritiantion and scheduhng of work to focus anennon on actions to remove opcrr.nng challenges: (3)improvmg the ability of the opensors to use plant gG (4) improving configuration control processes: and (5) resolving high pnorny material conditim problems.

By the end of 1996, Zion had improved its performance in some areas, including significantly reducing operator workarounds by over 60%. The number of tempormy alterapons and open temporary procedure changes agamst frequently used operating procedures were submantially reduced. De matenal condition of the Radwaste System was snessur. .ly improved, ahhough much remains to be done. However, Zion contmues no experience recamng events caused by inadequate procedures, failure to foDow gw d-es, sid by ineffecove and summely corrective accons. De 1997 Operational Plan contains significant acnons so resolve these connauing perfornunce concases.

47

NITACNMENT Comed Regense to NRC St.54(f) Request f

( .

To improve performance h planning, scheduling, and conducting routine maintenance, Zion management refocused effons to more effectively implement a "12 week miling" west planning and scheduling process. Drough this process, corrective and preventadvs maineenance and planned equipment tems are integrated into a shgle schedule that maximises mainesmance effemiveness, During the 12 week planning process, each cracal planung sep is anniaored isul sacked against regular milemanes. Two new managers with proven sucas k esecudca of ane rolhng schedule process were hired to enase the process is thoroughly adq=ad by the endre samen. Some M. c occurred as seen by two esamples:

(1) ne backlog of consol room indumtors with deficiencies was reduced by 50%: and (2) the number of overdue preventative mamesnance tasks for safory relmed equipment was reduced by 80%. De 1997 Operational Plan conssins a sumained focus on offcris to bener plan, schedule, and conduct work.

To resolve the concerns mised during the 1996 inspeaton of agineering support, the Engineering Deparonent reviewed almost 200 Safety Evaluanons and au open Operability Asseannets for quality and consent reviesd the Safety Evalumnon procedtse and added addidonal checks and balances to the process.

Dey. completed the docunentadon necessary to close the work packages of several long sundmg open modificadons. The Technical Specification lmerprention pmcass was .# d and other engineerms procedwes wee revised and improved. Most bnponently, they added addaional resources and engmeers to improve their effectiveness. Nevenheless, a key area of focus for L.., ..- .t in the 1997 Operational Plan is additional improvement in engineering suppcwt. As noted in Section 4.3 of this attachment, additional actions were initiated in 1996 and will continue in 1997 at aD six shes to address concerns with engineermg quality, the accessibility and quahty of design basis biformanon, and system readiness.

l As a short term plan to improve the cornetive action process, the threshold for generstmg P!Ps was l 3 lowered, and daily line management involvement in their review and resolution was increased. Over 5000 PIFs were generated in 1996. Additional indivuluals were added to the Event Screening Commisee, and new criteria for saablishing the significance level of PIFs for root cause investigations were established.

Reviews of lower level PIFs for adverse trends were begm, and effectiveness reviews of completed corrective actions were conducted. Zion is not sansfied with performance in this mea. The 1997 Operational Plan contains additional actions to improve the effectiveness and amehness of cr;rrective acuons,in order to reduce the number of recumng events, Notably,in May,1997, Zion Station will implement the enhanced Carroedve Action Program, using the program that has been developed by tepresentmives from au six Comed sites and the corporate office as a model. This program is further described in Section 4.5 of this anachment.

De 1997 Operancmal Plan consists of 6 serasegies which provide a bmed framewont for the action plans that will implement improvements at Zion untion. The strategies are:

Conduct of Onerations -

This strategy focuses on improvmg plant operations and safety performance. In this seategy, shift crew performance wiD be improved by isnplemennng high performance standards, a management observation program to fandha performance saprovenents to Operanons and improved shift and external communicanons, in addition enhanced support wiU be provided to Operations by establishing improved support processes (surveelbace control, OOS and susus unckag, rehabihty risk management, and plant labehag) for shift opetations that wiu provide assumance to the crews in ehrnmaung personnel errors and piant challenges. Finally, a front.end process will be enahliahed to ensure quality procedure revisions are issued to the field. In addition, standards and practices for the manon radiation protection program will be

.( epgnded.

48 i

ATTACHMENT

[ CoaEd Response to NRC $0.54(f) Request Performance 1mtrovement Manmoement This strategy addresses how ascon perictmance will be assessed to assure improvement. De strategy is -

imp)emented through action plans in:reasmg management oversight of field activities, implementing an effective self assessment program, improving the PIF and root cause analysis gm, and improving the management of the station's fermal creeninnent trackmg system.

Getrine Work Done his strategy addresses fundamental work procmsses and the management of work to ehminate barriers, improve equipment availability, reduce work request bacidogs, and establish a high smie of matenal condition. Wort management prweem will be clanned and stream 1med in this strategy and training on these ga unproved. The Operanons Work Control Center concept mill be used to improve the control of work activities. Action Request and Work Request bacidogs will be screened, prioritized and reduced. Multi <hsciplined teams will physically walkdown plant structures, systms, and components to identify undoeurnented matenal deficiencies. Post maintenance tests will be more accurately identified.

Station resource urihmion and outage scliedule adherence will be improved.

Encineerint and Technical Sunnort his strategy improves engineering and plant support by prioritizing and managing the work necessary to support plant goals. It addresses long.standmg material condition isnes and provides more systematic ap;roa:hes to measunns equipment and system performance, suppornng operations and maintenance,

and correcting plant deficiencies. De strategy will establish a process to categorize and prioritize the j

backlog of open engineenng work, and will improve the overall quahty of Safety Evaluations. he System Engineering suppon program will be revtsed to be constsunt with the best industry practices,

_Mananement and Personne1 Development I

This strategy develops the capabilitics and depth of the orgamzation. his includes trammg, skills development, outside reentiting, and a substanthally increased management involvement in the accredited training program. Required management and supemsory skills will ie identified, Ha.:.cl will be evaluatad against these anributes, and appropnate development actisities will be conducted. Instructor skills and tratmng lesson plans will be upgraded De System Engmeer trainmg program will be upgraded. The strategy will also address upgradmg craft skills and qualifications.

Desien Basis Manmoement his strategy enhances the configuration framagement program to control the station design be.ws, and ensures that the UFSAR, Technical Specifications, and the stauon procedures are accurate, complete and consasunt. The processes and procedures used to control the traceability, integrity, consistency, and retrievability of design basis informanon will be improved, and periodic assessments of the program effectiveness will be conducted.

L

(

49

ATTACHMEhT

/ Comed Respcase to NRC 50.54(f) Request i

5.4.5 Future Actionr As noted in Section 4.1 of this anachment, at the end of 1996, a comprehensive review of station performance was conducted through the completion of an IS A by a team of outside experts. De ISA team reviend and v=MtM het findings from many other existing evahations (Comed SQV audits,INPO e<aluanons, and NRC inspections) and results (trend reports and self assessments). De specific findings of the IS A team were seed as a foundation from which to derive the 1997 Operational Improvemeni Plan and its six strategies. De Plan is prirvitized to implement the actions reqmred in 1997 to first arrest declining performance, and then to implement longer-term actions to achieve and sustain nuclear exec 11ence.

In January,1997, Zion was placed on the NRC Watch List. Because the IS A team reviewed and validated the findings of earlier NRC inspections, the concerns cited by the NRC in placing Zion on the Watch List were already addressed in the development of the 1997 Operational Plan Tor example, NRC concerns with W,..cl errors, operational performance, configuration control poblems, and radation protection procedures will be adaressed by the 1997 improvement strategy entitled " Conduct of Operanons."

he effectiveness of work plannmg and control pr , quality of routine work activities, and equipment problems challenging operauons will be addressed in the strategy entitled "Getung Work Done." Engineering issues will be addressed within the strategies entitled " Engineering and Technical Suppon"and " Design Basis Management."

De publication of the IS A team's report and the placement of Zion on the NRC Watch List have heightened the sense of urgency m cepleting the 1997 improvement strategies. Additional resources, particularly in the engineering area, are being provided to speed improvement efforts, ne NRC conducted an Augmented Inspection of tie events surroundmg the February 21,1997 operational event. On February 25,1997, a Confumatory Action Leuer was issued by the NRC describing their concern with apparent performance deficiencies during the event and confuming certain actions to be taken by Comed. De results of the NRC inspection, and those of a separate and independent investigation by Comed of the event, have identified numerous isstns that must be corrected and improved regarding supervisory oversight, commurucations, the eccution of onstuft crew responsibilities and other maners Comed and Zion Station manageraent have agreed ? hat this event represented a significant breakdown in fundamental areas. Comed management has commined to keep both units shutdown until corrective actions have been uken to ensure safe operanon. Dese corrective actions regarding personnel performance, along with the resuhs of the Comed investigation of the event, will be submined to the NRC in response to the Confirmatory Action 1.etter. he 1997 Operational Pian will also be modified as appopnate to address the depth of issues surroundmg this event.

5.4.6 Moaltonag MecAssirais Day-axiay management of each strasegy wnhin the 1997 Operational Plan will be assigned to a Zion manager who will be ig ==Ete for assunng satisfactory progress. Each strategy manager will manage the overall performance of the relased action plans, and report the performance results to the managernent team. The straaegy manager will also control changes, additions, and deletions no the related action plans.

De Site Vice President will establish expectations for performance results, monitor plan results, establish accoumability, and provide overall plan leadmhip.

(

N

4 ATTACNMENT

[ Comed Response to NRC M.54(f) Request Each of the acdon plans has an assigned nedon plan manager, lhe responsibilides of the action plan manager will be to develop the implementing plan and ensure that it is effective. In teviesir.g the action 4 plan, the responsible manager will verify that h can be implemented and is capable of achieving its objectives.

The Zion management team (She Vice President and Senior Managers), as assisted by the sentegy manager, will provide a fansn for review of plan effectiveness. The resulu of the serasegier, and the removal of any bemers to sumessful completion of the action plans, will be discussed at weekly review meetings.

Site Quality Verification will provide hdependent assessments of the 1997 Operadonal Plan. Their assessmenu will focus on the success in achievmg the results specified in the acsion plans and on venfymg that the resulu ultimately support the strategies and key performance measures, SQV will provide assessnent reports to management at the weekly performance review mecangs.

1he site communicadons drector will prepare graphical posters of the key elements of the p' fa and periodically post plan performance results. The intent is that all she employees will see visible, high. level resulu from the plan as progress occurs through 1997. Penodic m$r milestones and results will be communicated through intemal wrinen media.

On a monthly basis, the site presents key performance indicators to NOD senior management at the Management Review Meeting. Key site performance measures include INPO indicators, NRC inspection program performance, human performance as measured by event free operadon, industrial safety accident rate, Self Assessment activhies, matenal condition improvement effons, and outage readmess, work plan'dng and execution indiatois.

(

51

A1TACHMENT Comed Response to NRC 50.54(f) Request 5J Braidwood 5.5.1 Sammary ofPerforminace Over the rest two years, Dnedwood has apenenced genandly good performance. Early in this time frame,managemem acted a dochne in Braidwood Stana's perfonnance, taribasars of this declining performwe ircluded several walanai NRC enforcement actions and lower S ALP ad INPO ratings.

Contributing to this decline were degraded matenal ecmditions, a lack of accountability in the Corrective Action Program, procedure adherence deficiencies, and difficuines in both mnfiguration management and configuration control.

Beginning in enriy 1996, a :iet of targeted improvement initiatives was undertaken so reverse this performance trend. For example, resources were dedicated to the idenaficanon and pnarttiaanon of manmal condition deficiescaes, improvement of the corrective action program, and the reduction of pmcedure adherence events. Steps were also taken to establish an6 enforce expectanons regardmg maintaining the plant in accordance with the design. Sections 5.*J,5.5.4, and 5.5.5 below discuss our improvement initiatives more fully.

5.5.2 Maragement Team Braidwood has developed a strong management team with a track record in successful management of

, r.uclear power plants, including Comed plants, other commercial plants, and U.S. Navy plants. The average senior manager has over 22 years expenence. All of the senior managers have SRO licenses or cerufication.

In June of 1996, the new Site Vice President joened Comed after serving as Operanons Vice President at a SAlf 1/INPO 1 plant in Region I, and before that, serymg in the U.S. Navy nuclear power program over a 22. year career. The Station Manager has more than 20 years expenence at CcmEd, during which he served successively as Station Control Room Engineer (SCRE), Master Mechanic, Operations Manager, and Maintenance Superintendent. The Operations Manager has served as a SCRE,Operanng Engineer, and Shift Operations Supervisor at Byron Station over a 15. year penod. The Maintenance Manager has more than 22 years exponence which includes posmans at Braidwood as Site Construction Superintendent, Assistant Supenniendent Work Planning and Work Control Superatendent. The Engmeenns Manager spent 17 years at Sargent & Landy where he wm involved in the design of Byron and Braidwood. He joined Comed in 1994, where he sermi as Assistant Site Engineenng Manager prior to assummg his current position.

S.S.3 hearces Braidwood Station is fmancially positioned to sustam the improvement reahacd to date, and to continue buddag upon these improvements. M4;or improvement initiatives are funded, and the level of fundmg to support daily operation is sufficient to ensure that the plant can be operated, maintamed and improved acconhng to the site objectives. To illusersse, the overall site budget has increased by approximately 42%

over the 1995 budgetlevel Staffing levels are being increased based on best-performer benchmark data. Sitewide, the permanent staffing is expected to increase by approximately 10% from the 1995 budgeted levels, to a staffing level of -

925 FTEs. In addition, resources have been budgeted for staff augmentation on a wepe .ry basis during

. Peak activity penods.

52

q l

A'fTACHMENT Comed Response to NRC 50.54(f) Request i

ne physical plant improvements, program upgrades and backlog reduction initiatives begun in 19% are funded so continue throughout 1997, Dus, the operation and improvement of Braid wood Station is neourced to a level that gives high ccafidece that sumained improvements will continue to be rmHwd j 3.5.4 Imag Taras Jayrmanent PJear I in 1996, management noted a dochne h Braidwood Station's performance and took accan to arrest this 4

mend. Senior Station management conducted a gap analysis in mid 1996 which identified Material Condition, Corrective Actions Human Performance, and Outage Performance as the sahent areas for improvement. Struegies were developed to improve Braidwood's performance h each of these areas.

f he primary elements of thr imj.w.a.: strategies asul acrornpanying acnon plans for each area of l anprovement are described in short form below.

i MatenalCondition l

Dree action plans were developed.

1. De Getting Work Done (GWD) Plan used dedicased work teams (Fix it Now Team and a Work Analyst Team) to reduce werk backlogs and improve schedule adherence on work tasks. De Fix it 2 Now (FIN) Team is utilized to protect execution of the weekly wort sched21e by assuming ,

responsibility for all emergent work requirements that arise during the week. They walk down the jobs, plan and produce the work package, track receipt of matenal. schedule and execute the work.

If the job is beyond their capability, the FIN team will coordmate with the principal work group s.nd work planning to estabhsh the best plan for accomphshment of the work. De Work Analyst Tearn j has been superseded by a new team that includes Braidwood and Byron Station in a combined effort

! to model the wcrk pmetices between the two sites and develop a Standarduced Work Procedure, i

l 2. The Fix Long Standing Problems Plan implemented plant changes to rosolve and reduce temporary l aherations, operator wchuurwis, equipment focus hems and other priority issues.

l 3. De improve Work Execution initiative was creased to look at the acmal perfonnance of work and

develop ways to provide a becer work plan to the work force as well as improve lesuns leamed j ,

from the caecution phase. The initial teams ofImprove Daily Work Assignment, knprove Daily

Job St.uusing. Impiove Shift Turn Over, F=hh<h Proper Pre job Briefs, and Fehlich Proper Post-job Crmques com42d their work as of January 1997. An ongoing effort on the Improve Wort Execunon initiative is connnumg to develop the best set of indicators to track consmous 4 improvement of eaecmion of work. To date, schedule adherence is slyLoly improved with wort comed over from one vek into the next significantly reduced.

F }iuman Performat$1 De Out of Service (DOS) and Configuncon Connel efforts resuhed in improvements in the removal.

1 stana, and maimemance of the plant symmas in accordance with the plant kneups. To reduce the number of erron -W with the OOS pecess, the following actions have been taken:

l

• Re location of the OOS writers to enhance communications:

2

• Developmem and management monitoring of performance indicatc.s in the conduct of OOS i / activitier,

• Advance preparation of OOS prior to the execution week:

• Providing guidance on the bandhng of OOS requests; and 53 4

A'!TACHMENT

/ Comed Response to NRC $0.54(f) Request -

(

Dedicated Nuclear Station Operators in an OOS group to maintain their pedicia;y in OOS pr*Paradons.

The acnons haplemented to knprove the management of the plant configuration include:

• Emkhahment of the Work Execution Cour,

• Reassignmet of adminisaative duties from the Unit SphaT.

l Heightened level of communicanon with the control room regarding work planned and in progress;and Establishment of a 3 year frequency fw the performance of plant imeups for all sysems.

Dese accons have shown positive results in the decline of OOS errors and the huased msnber of cufiguration control deficiencies identified.

Acnons have been identified and inmated to resolve the problem with a6t.;.once to plant procedures, including the simplification of admmistrative requirements governing site activities, additional traimns targeting improvements in human pe formance, clearly coenmunicating management expectations regarthng procedure adherence, and the establishment of appropnate indicators to monhor peeformance j in this ama.

Corrective Action j The Corrective Action plan incorporated the following salient features:

i

• Senior Management sponsorship o(events requiring root cause investigations, with the investiganon nports reviewed and approved by the PORC comminee; Clear espectations and responsibilities for Root Cause Investigators;

• Completion dates for all Level III and sbove tomesive actions; o a

Station Manager review of overdue corrective actions, and Stathm Manager approval required for due date extensions; Effectiveness Reviews of comctive actions assocised with significant conditions adverse to quahry; and Senior Management participation b the Event Screemr.g Meeung.

These accons testored the Braidwood Corrective Program to an acceptable level of performance. De Division-wide NOD Comcove Actica Program began with the Byron program as the beschne, and ww.

- developed frorn that point. De NOD CAP will be piloted at'8yron in March and April of 1997, and BraidW will monitor this pilot closely to maximise the lessons lemmed available from the effort.

With respect to improvirgg CAP effectiveness, strong Senior Management support has been provided to isnprove the problem classification,investiganon thoroughness, and approrrinteness of the cometive actions. Effectiveness reviews for these corrective accons are routinely performed. Line management ownership of the issues is amased, and the daily semening meetag provides Senior Management the fonan to review the problems reponed on a daily basis. His meeting ala, allows the proper priority to be assigned for problem reachnion. Dese imenm measures will be maintamed tatil the NOD corrective Acnon Program is implemented in May 1997; S4

.. . - . .- - .-. ~ - . . _. . - . -- - - - _ = - - _ .

i l ATTACifMENT 1

i

(' Comed Response to NRC 50.54(f) Request Ommae Performance An action plan to improve the maneuvening of the shutdown plant was designed to knpove shutdown -

performance by chminating unnecessary activities and increasing focus cui those activities sequiring 4

cornpledon. W objective was to increase safety while cantnAhng overall outage length. Several

' miemmes of this strategy were suplemented for the Fall '96 mid cgle outage on Unit 1, with notable schedule performance. 'Ihe nrst full scale implemantatica of the action plan initiadve will be se March refueling outage for Unit 1.1he effectiveness of this strategy will be assessed after the completion of the outage.

'Ihe Planning, Scheduhng and Control initiative relies on the active involyoaant of all enernents of the work force. Dedicated planners from the three maintenance disciplines,in addition to dedicated Operanons planners, have been added to the Pianmng orgaruzation. This concentration of resources allows the schedule to be wunrucnd to a greater level of detail than prviously possible. 'Ihe objective is to be able to develop a schedule which captures the wort activities in suf6cient detail to properly sepence the activities, allocate resources, and schedule necessary support in advance of the work Improvemmts have been achieved in configuration management and controls by establisMng and

' enforcing expectations regarding maintaining the plant in accordance with the design. Operational configurational control has been improved significantly through the implementadon of the Wort Execution Center, which is a centralized wort authorizanon center under the direction of a licensed supervisor. Additionally, enhancements have been made to the work authonranon process to ensure that the control room staff maintains a high level of knowledge of all activities in progress with the potential I to affect the units, in the area of design fidelity, Braidwood has alle='ad significant resources to

, elimin= the backlog of drv.ving revisions, anhae*4t he controls over tv+iwy modifications,

• W iraming on design basis compliance, and reviewed open designs and tests for potential discrepancies. A design basis improvement initiative will validate the critical components of the design basis. Where deficiencies are noted, the impact will be promptly assessed, and the resolution prioritized and scheduled.

5.5.5 Future Acsions Braidwood Station's 1997 Operational Plan was created in a manner sunilar to the 1996 improvement action plans. Senior station management developed the actions and indicators necessary to msure success in meeting the 1997 NOD performance targets for Braidwood Station. The 1996 focus areas will continue to be focus areas for 1997. This information is currently being synthesized into departmental performance measures and being incorporated into all stadon management performance evaluadons. All individual performance criteria are expected to be identified by March of this year, 5.5.6 Monitorsng Mecksakar Performance is monitored and reported on a daily basis at the Braidwood 1.cadership Meeting. Each day, a different area's performance is highliehead. except for Wednesdays which are devoted to a review of the previous weeks performance in the areas of wort schedule performance, readmess for upcoming weeks, and dose performance Other topics measured diroughout the morth include, but are not limited to, industrial safety performance measures, outage readmess, selected reviews of backlog reduction efforts in the Maintenance, Engineermg and Plant Support area:,, Corrective Action Program performance in trend identification and resolution, management of ndiation control activitica, and Quality Verification and ov:rsight activities.

55 l

1 ,

ATTACHMENT ,

Comed Respoane le NRC M.54(f) Request

[1 Also reported on a daily baslt in the stadon new$lener are key human performance indicators. Among l

I those parameters monitmed are industrial Safety indicators, LERs, personnel error 1.ERs, consequential human errors,and don perfonnance.

l On a montWy basis, the site poserts perimmance indi:stors at the Management Review Mesang conducted b) the $he Vice Premdent in conjunction with the CHOO. Key alte performance measwes include INPO TopTmind :seors.NRC inspection program performance, hunan periormance as measured by event free operadat,induurial safety,inteenal and extemal communbcadons, Self An'senent activities, material emdidon improvement efforts, outage readiness, work plantdng and asecvtion indicators, ar.d workiorte tralrdng, qualificadon, and productivity, l AdditionaUy, each Operational Plan / improvement inidative discussed in Seedon 5.5.4 above ineceparates meanrement standarda by which action plan progress and c6 jective r=timion are judged.

. Internal to the deputments at Braidwood, performance anributes specific to the department are monitored to a finer level of detall. As an cammple, the Operating department utilizas a $corecard Prognm to monitor crew performance. Each operadng crew is annessed against a set of well defined and communicated espectadons. In the Maintenance areas, an caample of the type of puformance monitoring undertaken is the tracking and analysis of rework. Rework in each department is analyzed to determine if it was caused by defective parts, rkill or knowledge deficiencies or design deficiencies, among other causes. De information gained by this detaued performance mordtoring is an input to the quanerly self assessments conducted by each department.

t 56

j ATTACNMEN'r

] / CamEd n=y==== to NRC M.5d(f) Regnem i

I

~

I l 5.4 Byres ,

, SAI .Esmema W rerfe m ance

! Ovw the pen two years, Byrom has esponenced overau sacabent performance with declines b some areas.

} INPO rued Byron as perfumance Category 1. Personnel errm h6ve boon identitled in our most recent 3 ALP as an sea of casam. While overau maistial candidca has been good, the Unit 1 Steam Genormors and the Essential Service 4 aser Symam are areas of co.ncorrt 4

One of the key material candition issues fachg Byron Station is the contirnaing degradadon of the Unit I maan generasm. AceMoss a wou underway no pina, udedule and perfonn en replassment of these j pomerases in sie Pau of 19p7, The Essential Service West Sysseen canoorns a related to sut buildup in the Cooling Tower basins and j erosion of the Essential !ervice Waner strainer elements, anowing pieces of Cooung Tower ful to enter the

! symem. A root caum invesdgade was performed and a number of performance issues were identified.

Improvements include chmging the way non Technical Specificadon esimed surveillances a scheduled, tracked and performed, knproved review of Action Requem on a dauy basis, periodic review of old Work j Requests, and improvements to the design basis knowledge of the symem engineers.

A Cultural Survey has been performed at Byron for the last two years. This survey is used as a landmg

matmn indacitor, as it is comnated with fuere SALP performance.1he Cultural Survey examines five key seas

Strong Organizational Mission and Ocais: High Level of Knowledge and Skius; Strong Lateral  !

4

Integration

Simpic Work Processes / Procedures; and Strong Self improvement Culture. An " Engage the

Workforce" amam has been put in place to address how to knprove the areas that affecs eds leading Byron

, hubcanor. Actions to improve Byron Station performance a desalbed more fuuy in Secdons 5.6 3 and l 5.6.4 below, 1

SA2 Managemear Team Bymn has a swong managemet Isam with a track record in successfu' management of nuclear and fowl power plants, hcluding Comed plants and U.S. Navy plants. The average senior manager at Byron has over 23 years esperience and the Site Vice President and his duset reports accoint for a total of over 2 hl

years of emperisnce. All of the amnior managers Imve held SRO tioenses or certincases, and 4 have i

. completed the INPO Senior Nuclear Plant Managnaent course.

. Among the senior managers at Byron satim, the Site Vice President has more than 36 years saperience at Comed and has held the posidons of Mechanical Master Mechanic, Mainaanance Engineer, and Assummt 54 M-mi of Adminierative and Technical Services. He served as the Sation Manager at Zion and than as General Manager PWR Operadons ad General Manager BWR C =E The Station Manager has more than 26 years saparience at Comed and has served successively h positions which have included Construction Engineer, Land 5dieduler in sht Osnaret OfGce, Land Consouction Engineer at Zion. 5tartup Engineer at Byron. Assiaant Superinundant of Mabtmance at Zion, and Production

Superintendent and Staden Manager at Braidwood. The Operadons Manager has over 21 years emperience at Comed, havhg haki the pannens of Nuclear Station Operssor, Shift Supervisor (SRO.

licensed), Shift Engineer, Operating Engineer, Assistant Superintendent of Work Planning, and Maintenance Superintendent. The Mainianance Manager has more than 2; years with Comed, having served as an engineer b the Corporate Nuclear Engineerms Group, Bra!dwood Technical Staff system

( engineer, Zion Special Projects Group Engineer, Technical Staff Electrical Oroup Lander, Shdi Control Room Engineer (SRO licensed), Masent Inarument Maintenance, Master Electrical Maintenance, 57 m 4, - - - .,,--..,_.__...,,r._,.,.,. -m._ , . ~ . _,_m.--,. _,,.,.,m.,,.~__.,..,,_..-_-- , , . . . . , e- . , . . _ . , -- , , _ . - . ,

, ATTACNMENT i 4

[ CassEd Response to NRC M.64(f) Regnest 4

, Mainianance Staff Supervisor, ad Byron Services Duector. The Bngineering Manager has mas than 21 ,

l years esperience whh Comed, and is a Registered Professional Engineer in Illinois He has held positions k the System Elecewal Engineering t:p n Project Managnet - 4,3 and Construction Byron. -

Eton Technical Supenneendent and Operadans Mannsw.

SA3 Assesrese Byrca Stade has been provided with sufncient fundmg in 1997 and 1993 to ansain continued i, n r Majw bddatives and projones are faded to ensure that the plant can be opereesd, maintained and knpoved accanhng to the she objectives. Sminns levels are behg insensed based on best performer bondenark dem and future resource needs for the she. Shewide, the pennensat unf5ng is espected to hcsease by 68 people troen the 1996 aonsal levels, to a maffhs level of 892 pareannel in 1997.

In addidon, resources have been budgeted for maff augmentation on a ternparary basis to suppan various i g ; ~ popects at the she.

In addition to the replacement of the Unit 1 Steam Gensensors, baprovements to the physical plant, upgrading of programs and backlog reduction initiadves are planned and faded through 1997. Key improvements cunently faded include:

• Powerblock Work Request Task Backlog reduction

• Non ensendal Service Water check valve replacement Essendal Service Waser Cookng Tower Piping upgrades

• 125 VDC Safety Renased Banery Replacements River $asen House Blowdown De ichg Line

• Rod Drive andinvens Cooling Symems e improved Teduncal SpecifiMon properadans (knplement 7/;g)

• Human Error Reduction Trairdng DRPI & CRDM Connectw and Cable Upgrades e 4 Kv and 480v Breaker refurbishments

• PuelHandung sysism upgrades

• UPSAR A Pire Safe Standown Analysis Reviews

• Solid Sinne Prosection Synom Mainamance Program

• Main ControlRoom Upgrades Byron Stadon is resourced to a level that gives high conndence that sumamed L-; ;m^3 will continue en be reahsed.

544 laag Tenn Japroewement Plear and reare Amient in 1997 and 1993, Byron will mahtnin a cancenessed focus on the performance priorities of safay .

poduction and cost. Our focus during the coune of the year will be h alignment with these arsat However, auclear afety is, and will conshut to be, the top pianty at Byron.

Ahhough Byron candnues to have above average perfonnance, the scores for 5 ALP 13, andmg August 17,1996, declined alightly from the previous sal.P period. Senior nation management conducted a gap analysis in mid 1996 to determhe areas requiring urongw ernphasis. Hurnan Performance was identified as the major element in 41 $ ALP categories that was in need of improvement. Olher areas determined to play a significant role included: idendficadon and resoludon of issues; nelf and I hdependent assessment: maistial omdition: and pacess improvement.

58 i

ATTACHMENT l

[ CenEd Raspense to NRC St.Sd f) Reneest I

lhe prknary elements of the hapovement arosegles for each sea of impovement are described below:

h ann 9erfe nsne, '

l in 1996,severalpograms were 5% " to knpove site performance in die areas of human I

performance, in 1997, thses pograms, including those desulhed below, wiu continue. Some of these pogrens include:

• #wisa Error Asdscsion Trelaing . A formal seining program was 5;" d bi 1996 to improve skills b the sens of ems povention, deaction and correctiw actions. This maining has been espanded in 1997 to inches plant personst, suosity, and consams:

• Field 06strussion Aaporting Propam . A synsm of fol.1 beurvadon rep ets was bddated to formalias the process of line managers obserymg and rc ,eng on fMar parfannance in the plant. The information ganhared is reviewed by the and training man.gsment and is analyrad -

for sends indicadng performance weaknesses.

• MAAC Tralaing . In early 1997, Supervisory personnel received four days of maining in the following seas: grievance handling. job performance connaling,iE='.,g disciplinary acsion, adminimering the collective bargaining agrooment, and rules and counpany policy. A Anal class has been scheduled for May/ June 1997, Carrective Action i

Byron recently received a Notice of Violation for maimely carrective actions ki connecdon with a long.

manding work requem assoclased with the $X Cooling Tower Trash Racks, and sitt resoludan. In spite

, of this event. overall, the Corrective Action Program effecdveness has boon good. Ongoing prooses improvements have been implemented for a number of years, including working with recogrdmod expens to knpove vending. Effectiveness review 6 for corressive acsions are performed routinely, MPs are rev6ewed daily by Senior Management. An NOD Correceive Acdon Program modeled on the Byron pogram was implemented in March f41997,1his program includes an improved cosaputer program for capturing PIF data which is aned by she persosswl for sending.

Malenal Condalan Several progrens were implemented in 1996 and will condnue to be bnproved in 1997 to unaintain and improve the material condation of the she.1hase programs include:

• The Operesor Work Around (OWA) Program .The OWA progren long.sann equipment or pogram deficiencies that provide an obmacie to asse ad efficient plant operadans. Thea are cunently 64 OWAs that impact opermor response to vansients as ds6ned in SOER 94 01,

• tat Westrial Condisjon Monisering Program .1his pogram a visible snessure of die overall maesnal condnion of symsms, spumses and components. Symams se snonhored by the Symsm Engineer and a window color (Green, White, Ystlow or Rad) is assigned based on various snaisrial condsman hiputs. Inputs that desnahe the overall Symem Window color cosne from the seas of performancs,physionieendinon dernungs,malmsmance backlog OWAs,ad design doncasacies. Signancent amandon and sation renowcas was allocased to address conoems raised through the Material Condition Monhoring pogram in the last year Work priorities in

(* 1997 will continue to be driven by this System Wtidows program. Performance standards are also ader development to sncnhor impovement.

59

ATTACHMENT

( CamEd kespamme as NRC 88.5d(f) Request

(

• Design # asis Aeview and OwnersAlp . 200 Desigr/hh Basis Reviews were hitiated in 1996 and are continuing in 1997. Completed reviewe hclude: UF3AR Section Reviews for Spent Puol Pool (9.1) ed Radweene (11.2,11.3, and 11.4): Pte Pr% Raport Self Assessmaat & Update b December,1996; and Comanhment Spray / spray Addalve Design Review (UPSAR Uphat pen 6ms). The RH Synne SaK Amessesnt is b Anal review, site

-$-4 at Byre Stadon bas transferred and maintains ownership of all archilset engineer design drawings andr*Wthe l

e rh itNow fr/N) Team . The PIN Team has been in place for 21 months at Dynm Station.

Since inception, the team has completed over 2500 work activisies whicti helude bash work requests and acehn requests. This high rate of prodeceivity has not caly been a key facsor in the Station's success but has brought them hdunry recognition in the form of an INPO arength.

The present pant of the FIN issue is so perform 50% of the emergent work.

Self Assessmenu Byron Station has an active self assessment progran that is duected by the Site Vice President. Every depenment head along with selected members of the depenment meet with the sine Vice !' resident and Station Manager on a semi annual basis to discuss depenment performance, identifying strengths and weaknesses. During each self assessnent period, four core" topics are reviewed:

.Se{fInitie edDrparsmensalToples These topics are department speel5e areas that need to be addressed Each depenment monitors a number of key performance indicators. Some (+;-u .;. have been graphing trends, while oshers use tem

• windows' approach.

Vuion sad Values Each depart'nent addresses their esppon of the ' Vision and Valms.* The following itsens are addressed.

Specific accons taken to achieve *World Class' performance Specific assions taken to promoes the philosophy of a ' Nuclear Generating Team'

• Specific actkas taken to promote the philosophy of ' Stretch' Speci6c actions enken to become more ' Cast Competitive" Training .

Training will remain a topic of high visibility tri overy depenment. Each depenment addresass the following:

The level of sunagement involvement in training within the depenment

• Assessment of the Training %, ..c.;*s support of depenment needs Departmensal GoalSneau Each depenment reports a the slams of their Strategic Business Plan goals, in N to the core hasases, special emergent issues are reviewed each assessment period.

(

eo

ATTACHMENT Comed Response to NRC M.54(f) Request Indmandent Amantment '

Fwsher krv,vs.rs.: of the SQV Departmmt's assessment capabihdes mG be pursued in 1997, he -

fellowing basic arategies will achic-c alus obpective:

• Perfwm assessments of pcendal performance issues utihaing the "arveillance process"

!

• Inenase the use of Sobject Maner Experts for audits

• Perform &acredonary audits (pogram nviews) of pountial performance issues

• Obtain pmonnel resource canmitments from the Site Vice President for assenments

• Response to department requests for specific audits.

Procen knpromments Byron Station will continue the implementation of improvements in the work ccatrol process dwing 1997. Some of these knprovements inchsde:

• Action Atgurst Scretning . Byron Station impicrnented an Action Request (AR) screening process in October of 1996. A aoss disciplined group of site personnel (Engineering, Fis it Now team, Maintenance, SRO, Work Analysts, Wat Control) review all acdon requests and wori requests which have been identified since the last screening.

• J Weik Work Control Procrst.his process is scheduled to be implemented starung March 10, 1997 and completed in July,1997, Work scope will be set based on a pnpared (90%) backlog goal and material condition priorities. Work Week Managers will be urih,M to control schedule

, changes, using tools such as the Comed standard performance indicators, up to 4 weeks prior to esecadon. he process will produce individanbrM credible schedules, that people can, and will, work to. With this common process in place at all 6 sites, the economy of scale can be applied to the work management process across the division.

5.6.5 Monkoring Mechankms he Byron Lead Team met and discussed the necessary focus anas and performance targets needed to ensure continued perfonnance improversent at the site. Dese performance indicators and targets are nflected in the 1997 Byron Station Business plan.

On a monthly basis, the site presents perfumance indicators at the Management Review Mecungs. Key site performance measures include: INPO indicators: NRC inspection program performance; human performance as measured by event fne operadon; industrial safery; internal and extemal communications, Self Assessment activities; material condition improvement efforts; outage readmeas; work planning and execution indicators; and workforce training, phon, and productivity.

APEngage the Workforce* team has been put in place to develop and implement methods of communicating key performana indacators to all site pu.c.cl to increase overall site awareness of performance. In addition, the Plan of the Day meeting is being resinsetured to communicate and discuss key performance measures and current issues at the site.

i l

61

ATTACHMENT Comed Response to NRC M.54(f) Request

6.0 CONCLUSION

Comed has extensive acti ons undervsy to impove de performance of hs nuclear program. The NRC's -

50 $4(f) lener has caused the Board of Directors and executive management to accelerate the pace of impovement offarts and answe that istgrovesneed is sustained throughout NOD and at each of Comed's six sines.

The Board of Duraors has become drectly engaged in oversight of the performmce of Comed's smclear program. Senior Corporate management has mobilized the financial and human renowces of the entire corporation to support accelerated and sustained performance improvements, and resources are being provided to support both safe operation and sumained performance.

NOD now has in place a strong senior management team with extenrive experience in twnaround situations and has seemed and will continue to secwe the financial resources to fund necessary impovements. The CNO and CNOO commissioned a critical self asussnent of Zion and LaSalle Station which is focusing future Zion and 1.aSalle improvement initiatives on the fundammtal causes of past performance, and is poviding lessons leamed and a similar focus for impovemmt inidatives at the other four sites. Major improvernent initiatives are underway to upgrade engineering and technical support throughout NOD, and to asswe that identined design bases and configuration control issues are addressed and resolved. The CNDO and CNO sre hading efforts in engage the workforce. A new corrective action portam that incorporates industry practices has been de$c oped and will be implemented throughout NOD.

' A broad range of near and long. term improvement initiatives are underway at each site and will be executed with a renewed sense of wrency. Senior managemet involvement and oversight from the Board of Directors, through the CNO and CNOO, and down to senior site management, will be imensified. .

The Board, NOD, and the sites have adopted sets of performmee criteria agairst which performance of each site and the NOD as a a hole will be measwed. These criuria enswe that our nuclear operations will be safe and that performance improvement will occw. In cases where criteria are not met, action to ensure that performance returns to acceptable levels will be taken, up to and including plant shutdown as demonstrated by ow approach to LaSalle and Zion restaru.

For these reasora. Comed concludes that h can safely operate six nuclear stations while sustaining performance improvement at each site, t

l

- o APPENDIX X

< Fandannetal Causes and Comeelw Actions

! (

Appendix 1 comlates the causes of cyclic perfcumance to the major cervective actions taken by Comed at the Caporate NOD and ww leveh. Each of shese sedans is described in desau in the body of Comed's

. fe8Ponse.

G 63

l APITNINX X .

Feedeseental Causes med Corrective Actiones Cseees Corporate Action (s) N(M) Actions Sise Actimes (we Sectines 5.1-5.6) o,ersigg 9e Board revitatired its NOC by addag The CNOO(typaJIy mmwhly)cemducts Es h siee wis seawat stendenfired gdm . x we need so a .gL management members wish essensive nuclear "__ ....~.; Review M-etengs et each sise.Focu.ing ins emeeian for senior managemem review. The overs;ght of meclear opereekms. .. _. _,,..... : esperience. incf-ding ce safety gda . and the effectroeness of periodic se,,ew process is wiHred to des icaneerese esperience sneneging mehiple reactor *.w.. a initieeives. hi..Q and erwenst espectessons for organitetions. i~ L . -- _

NRC 1/27 h Caeses The Corynesee essessme'it and medit funesion wet be week corporese oversig% of nuclear The Board specific My dersered the NOC as- J by spr8 mag the regensde resnerces and Senior eine : ._a particiresed in lhe operations. 80 provide aggressive oversight of ComF#s by esseMishina e fivwig educaule for creyneme sedits a. i,.. _aofcrereenmet ; .., _ a plass nuclear pecgramnJ.<- _ _+ end to keep end es,essmenes to be r J m..a 3 at each siee s'id which forse she foundation of car L . .  ;

the Board apprised of safety and NOD. e&rt. These piene prowMe ei .w __.: , to performance issoes. demonstrese the con =eenent to safety and To essere shot snetti-site trends and lesecas learned escenence to the siee week force.

The NOCconducts slee visits to ai.. 'x et particolar siees are tecngnized and ecsed spen, ,

medits wis be enetyred by she NOD Nuclear  ;

whether neclear progvem menestement i actions e=e sprenpriese end effective. Oversight gevep es web es the individuel slees. ,

t The NOCef she Board wiR nonnieor e set of NOD indicators and vernet to she Board at 4 Board meetings.

t 9

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64

,, T APPEP'INX t FendesmestalCsews and C.,m:*.e Actions CesnEd/NRC Causes Corpersee Actine(s) NOD Actient Slee Actions (we Sectises 5.1-54)

The new NOD sewine management seem is h Attentlee seall The Board mW senww menegewns are foces*E on remedying nrs only the estsNishing Divisinn-wide pda.._ e meneeres Each site's mxw.a : seem has been strengteiened toy she edderinn of enW Resoortes We beve sent k. ' 1 -", applied proNems at individuel sites,but on and crierie to powde stronger W. nuclear pefeseminels le key p>=visons.

, ..,. 4 she nuclear pogram es a wIsole necces,ery resources and --- ...;

ettesilion to the sites to ensere :he tiecogh the commene:it of the fell NOD end site budgets beve been." rd. based A standardleed besweess gdern.ing pacess her successfulm,*.;_ of our Tweenciel and m ..ac." resources of she opna the g,' ..._. a issues facing coch site asul been eweMished to impowe lcng range pienning

..., . ... ara piens. corporation to the nuclear program. then aggregewd to foren the NOD budget. he the esed acco eplish and seeeemn, m.ac rest. site budgets were esteNished by dividing a pe-  :.. ..__.;; ! , ,.- actions are Fssufed The Board substentielly increased dermed nuclear progeeni budget. in session t.edgets.

NRC t/27 IAger Camses tesources for the sieclear program. .

o Lect of effective ._.._,,_.."

estessaton and application of resoorces. The NOC of she Boent will provide to the Roant tienely and independent infornietione

-.. ' , the nuclear program. and ensure line . _ . _,,..m :is held arxcenteWe for meeti ig Board perfrwnsence espectorians.

Support of the nuclear slee*e Electronic Work ControlSystem (EWCS) which is used toplan sad cormal work et she nuclear stations.has been snede the highest pianty rf the Comed Infornietion Syneens organisation.

seniormanagers cuendeof NOD have become engaged in sesonger efforts to support the nuclear program resehmt in im.eovements in composer hentware.

hemoiresources and m.m .J perts i onoral and eveBehility, financial controls.

and secenty.

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t April 15,1997 U. S. Nuclear Regulatory Commission Attn: Document Contml Desk Washington, D. C. 20555

Subject:

Bruldwml Units 1 and 2 (NRC Docket Nos. 50-456/457)

Hyron Units 1 and 2 (NRC Docket Nos. 50-454/455)

Dresden Units 2 and 3 (NRC Docket Nos. 50 237/249) 1.aSalle Units 1 and 2 (NRC Docket Nos. 50 373/374)

Quad Cities Units 1 and 2 (NRC Docket Nos. 50 254Q65)

Zion Units 1 and 2 (NRC Docket Nos. 50 295/304)

Trunsmittal of Commonwealth Edison Company's (Comed)

Definitions of Performance indicators and Associated Performance Criterin Related to 10 CFR 50.34(f) Response Dated March 28,1997

Reference:

(1) Commonwealth Edison Company's (Comed) Response to the U.S. Nuclent Regulatory Commission (NRC) Request for Information Pursurat to 10 CFR 50.54(f) Regarding Safety Perfonnance at Comed (2) H. 'lhornpst, e e to J.J. O'Connor, dated January 27,1997:

" Request (c ' A.. nation pursuant to 10 CFR 50.54(f)

Regarding Safety Peribrmance at Couununwealth Edison Company Nuclear Stations."

Dear Mr. Callan:

In Reference (t) Cnmmnawealth Edivm indiented that we would provided additional information to the NRC staff regarding the performance indicators we -

pla.nned to ut.c in response to the NRC's request for additional information punuant to 10 CFR 50.54(f)(Reference 2)

The purpose of this letter is to pmvide Comed's defmitions and performance criteria for each of the indicators listed in Refertnce (1) Section 4.7.2. Attached are the definitions for the previously selected division wide 25 performance indicators and associated performance criteria selected to measure our progress towards improved perfomumce.As a result of experience gained in monitoring thew Indicators, the dermilion of Collective Radiarit a Exposure has been

/q

'TdMN ff*

11. S. Nuclear Regulatory Commission April 15,1997 Page 2 modified. Reference (1) stated that this indicator would be measured on a site basis. 'this has been subsequently changed to monitor on a unit basis.

Additionally, dose accumuisted from Dresden Unit I will not be included in this indictor.

!! ope you find this information useful in anticipation of our meeting with the NRC Commissioners on April 25,1997.

Sincercly.

homas J. h ,m Executive Vice resident and Chief Nuclear Officer l

l l

Enclosure:

Cornmonwealth Edison Performance IM!ctor Defmitions and Criteria ec: 11. Thompson, Deputy Director for NRR A. Beach, Regional Administrator - Rll! -

R. Capra, Project Directorate NRR R. Assa, Braidwood Project Manager NRR G. Dick, Dyron Project Manager NRR J. Stang, Dresden Project Manager - NRR D. Skay, LaSalle County Project Manager NRR R. Pulsifer, Quad Cities Project Manager - NRR C. Shiraki, Zion Project Manager - NRR Braidwood, Senler Resident inspector Byron, Senior Resident inspector Dresden, Senior Resident inspector LaSalle, Senior Residentinspector Quad Citics, Senior Resident hupector 7.lon, Senior Resident inspector Office of Nuclear Facility Safety - IDNS

Commonwealth Edlaon Performance IndicatotDMinitions and Performance C.titada A. INDUSTRY WIDE INDICATORS The following seven indicators, used by the NRC and World Association of Nsclear Operators (WANO) provide a high level safety overview, en indication of overali effoWeness in achieving .

improved perforrnance resuks, and permit evaluation of whether we are reaching out overall goal of cpersung each site at a level consistent with it's industry peers.

1. Automatic Sernme While Critleel

- The number of unplanned automatic scrams per year while critical. Examples include scrams from unplanned transients, equipment failures, spurious signals, of human error. Scrams occurring during the execution of procedures in which there was a high chance of a scram occumng, but the occurrence of a scram was not planned are included.

l Performance criterion: More than one scram per unit per year.

2. Safety System Actuations Manual or automatic actuations of the logic or equipment of either certain Emergency Core Cooling iystems (ECCS) or, in response to an actuallow voltage on a wtal bus, the Emergency AC Power system, input for this indicator are derived from LERs and supplemented by 50.72 reports, in

' determining which events should be counted by this indicator, the following conventions are used:

1. Only actuations of the High Pressure Irdection System, Low Pressure injection System, or Safety inhetion Tanks are counted for possurned water reactors (PWRs). For boiling water reactors (BWRs), only actuations of the High Pressure Coolant injection System Low Pressure Coolant tryoction System, High Pressure Core Spray System, or Low Pressure Core Spray System are counted. Actuations of the Reactor Core isolation Cooling System are not counted.

2. Actuations of Emergency AC Power Systems are counted only if they were in response to an actuallow voltage condrtion on a wtal bus. Specifically, actuations are counted only if the Emergency

- AC Power System's output breaker closed, or should have closed, to power a dead bus. Actuations resulting from momentary low voltage conditions that do not result in emergency output breaker coeure are not counted.

3. Logic actuations of any of the equipment assocated w6th the specific ECCS or Emergency AC Power System are considerea necessary and sufficient to constitute a data count.' For example, if only a valve in a system is commanded to move to its emergency operational position, this is counted as an octuation. A pump does not have to be commanded to go to its emergency mode of operation and fluid does not need to be tryocted for an occurrence to be counted. '

1

4. Only one ECCS actuation is counted in any one occunence, neri tt muhip'e ECOC systems actuate dunng the occurrence. For examp'e, actuation of both the High Preswre injecurn and the Low o ressure injection Systems at a PWR dunng the same occurrence counts as eng a single ECCS

(

actuation-

5. Only one Emergency AC Power System actuation n counted m any ocemence, even if multiple emergency generators actuate dunng the occurrence For example, s.*t.. won of all four emergency dssel generators (EDGs) at a unh counts as only a singb actcefioa fw that occurrence,

6. Occurrences invoMng setuations of both an Emergency AC Power System to power a dead bus and an ECCS are g ven a count of two, one for the Emergency AC Power System actuation and one for the ECCS actuation.

7. At multi-unit shes that share equ!pment (e.g., a swing EDG or shared buses), actuations are counted and assigned to the unh at which the actuation signal or loss of power originated. If the signal source cannot be associated with one unit, the actuation is assigned to both units, Performance afterion: More than one safety system actuation per urJt per year.

3. Collective Radiation Exposure -

The total effective dose equivalent (TEDE) received by all personnot con.ing on sitr,.

TEDE includes 'unmonhored' or 4 racking' dose for contractors and visitors during the quarter. TEDE a the sum of the deep dose equivalent (DDE) and committed effective dose equivalent (CEDE). These arms are defined in 10 CFR 20.1003.

Report the total per unit value (at Dresden, exclude Unit 1).

Performance criterion: Projected or actual results exceed the annual year end exposure goals expressed on a per unit basis

4. Unit Capability Factor The ratio of available energy generation over a given time oeriod to reference energy generation over the same time period, expressed as a percentage with both energy generation terms determined relative to reference ambient conditions.

Available energy generation is the energy that could have been produced under reference conditions considering only limitations within control of plant management (i.e., plant equipment and personnel performance, and work control).

Reference energy generation is the energy that could be produced if the unh operated continuously at full power unch mference ambient conditions throughout the period. Reference ambient conditions are environme.m anditions representative of the annual mean (or typical) ambient conditions for the unh.

Performance entenon: Projected or actual performance falls below year-end goal. This criterion will vpply to Zion and LaSalle following restart of their units.

2 l

\

l

5. Unplanned Capability Loss Factor

( The rato of the unplanned energy losses durinD a given penod of time to the reference energy generation, exprested as a percentage.

Unplanned energy loss is energy that was not produced dunng the period because of unplanned shutdowns, outage extensions, or unplanned load reductions due to causes under plant manngement control. Causes of energy losses are considered to be unplanned if they are not scheduled at least four weeks in advance.

I l Reference energy generation is the energy that could be produced if the unh operated continuously at l MI power under reference ambient cond:tions throughout the period. Reference ambient conditions l are environmental conditions representative of the annual mean (or typical) ambient conditions for the I unit.

Performance ertterient Projected or actual results show capability loss will be > 5% above established year-end site target. This criterion will apply to Zion and LaSalle following restart of their units.

S. Safety System Performance This indicator is calculated separately for each of the followir.g three BWR systems and each of the following three PWR systems:

BWRs e high pressure injection / heat removal (high pressure coolant injection or high pressure core spray or feedwater coolant injection, and reactor core isolation cooling or isolation condenser systems) e residual heat removal system e emergency AC power system I PWRs e high pressure safety injection system o auxiliary feedwater system e emergency AC power system The sum of the unavailabilities of the components in each safety system listed above divided by the number of trains in the system. The component unavailability is the ratio of the hours the component was unavailable to the hours the system was required to be available for service. For the emergency AC power system, the indicator is defined as the sum of the emergency generator (diesel or gas turbine) unavailabilities divided by the number of emergency generators at a station. F9 r t'.e emergency AC power system, the indicator is displayed for all stations. For the other safety systems, the indicator applies to either BWRa or PWRs and is displayed separately, Performance criterion: Unevailability exceeds two times the industry goal for any system.

3 i

7. Industrial Safety Accident Rate i

The number of accidents for all utility personne1 permanently assigneo to the station resulting in one or more days away from work (excluding the day of the accident). or one or more days of restricted work (excluding the day of the accident), or work related fatalibes, per 200.000 mamhours worked.

Contractor personnel are not includrd in this indicator.

Performance criterion: ISAR exceeds the established site target.

B. COMMONWEALTH EDISON SPECIFIC INDICATOR 8 The following eighteen Commonweatth Edison specific indicators were selected based upon review of indicators that Comed has used in the past, review of indicators used by other nuclear utilities, and the experience of our management team, many of whom have used these indicators in other nuclear programs. They will be apptied in a consistent manner across our stations and cover the important operating, maintenance, engineering , and corrective action areas that must perform well for sustained improvement et each site. They are designed to provide a level of sensitivity and detall to that timely corrective action can be taken when performance trends surface, permrtting us to resume tracking

toward our overall goal of superior performance. .

OPERATIONS

8. Operator Workarounds An equipment or program deficiency which requires that an Operator take non standard action to xmply with procedures, design requirements, or Technical SpecNications.

(# opened during tne month)(# closed during the month) (total # at end of month)

Performance criterion: Greater than a 10% deviation from the site workdown curve.

9. Out of Service Errors The total number OOS error PlFs that are designated as significant (Level 1,2, or 3 PlFs or SCAO in the new CAP process). (total # during the month)

Performance criterion: Greater than one error per month. ,

10. Human Performance Error Licensee Event Reports (LERs)

Errors of omission or commission by any indMdual dunne plant actMties leading to submission of an LER. Count all LERs that are designated as having the cause being personnel error and LERs whh a primary cause code of A. Count the LERs submitted during the month (# dunng the montn)

Performance criterion: Greater than or equal to two permonth per site.

4

11. Temporary Plant Afterations I

The total number of temporary alterations. Temporary atterations are noni:ermanent changes, mod:fications, or adjustments to the approved design configuration of a structure, system, or component. (# opened during the month)(# olosci during the month)(total # at and of month)

Performance criterlon: Greater than or equal to 10% 6eviation between the number opened and closed during a month.

12. Fa!!ed Technical SpecWication Pump and Vatve Surveillances De number of Technlos! Specification, pump and valve surveillances, including IST, whidi do not meet the Technical Specification or IST nmuired acceptance criteria for pumps and valves per month.

Does not include Administrative Technical Specification requirements. (# of ' ailed pumps and valves during the month)

Performance criterion: Trend for 6 months to establish baseline prior to selecting criterion.

13. Unplanned Entries into LCOs The number of times that the unit was in a 7 day or less required shutdown LCO that was not previously planned (# during the month)

P2rformance critenon; Trend for 6 months to establish baseline pnor to selecting criterion.

14. Percent Contaminated Floor space All areas of the plant that have smearable contamination 11000dpm/100 err,'. The only areas c:ctoded from this trending are; high radiation areas with infrequent accus, areas that are not cecessible, vaults, pits, areas routinely used for contaminated work. Areas containing grating and satellite RPAs shall be trended as part of this indicator. (% at the and of the month)

Performance criterion: Greater than 3% otal area, as defined, for each site.

MAINTENANCE

15. Non Outage Corrective Work Requests The number of corrective maintenanoe work request tasks, including degraded and action requests, that are noHutage and for power block equipment and structures. Corrective maintenance is the repair and restoration of equipment or components that have failed or are malfunctioning. (# opened during the month) (# olosed during the month) (total # at end of month)

Performance criterion: Greater than or equal to 10% rieviation from established workdown curve. -

5 m .

18. Percent Rework f

• he performance of any physical maintenance task which resutts in a loss of time or money. During analysis of the component history in which any maintenance (like in kind)is identifHed within 12 months eher maintenance has been performed on that component. The total rework per month divided by the total number of all correctrve and degraded maintenance completed by maintenance per month .

exduding surveillances and preventive maintenance. (% for the month)

Performance criterion; Greater than or equal to 4%

17. Outage Work Requests The number of work request tasks that require an outage to complete. (# at the end of the montn)

Performanoe criterion: Trend for 6 months to establish baseline prior to selectirig crMerton, ENGINEERING

18. Engineering Requesta The total number of open engineering requests that include requests for design changes and support fr:m engineering. (# opened during the month)(# closed during the month) (total # at and of month)

Performance critenon. Trend for 6 months to establish baseline prior to selecting enterion.

9. Engineering Requests Overdue The number of overdue engineering requests for design changes and support from engineering. (#

dunng the month)

Performance enterion: Trend for 6 months to establish baseline prior to selecting enterion.

CORRECTIVE ACTIONS

20. Corrective Action items Number of corrective actions resulting from NOVs, PlFs, LERs, or CARS per month that have been opened, closed and total remaining open at the end of the month. This includes NTS items with a Doc

'fype = 100,180,181,200,230, and 315. (# open during the month) (# closed during the month)

(total open at the a:G of the month)

Performance '.:rnerion; Trend for 6 months to establish basehne prior to selecting criterion.

6

. g .

21. Overdue Corrective Action

{'

Number of corrective actions resulting from NOVs, PlFs, LERs, or CARS that went overdue dunng the month. This includes NTS items with a Doc Type = 100,180.181,200,230, and 315. (total # during the month)

Performance criterion: Groater than or equal to 15 / quarter.

22. Repeat Events Monthly, the number of events that occurred during the past month whose root cause invoetigation report het been completed during the past month, that are reasonably similar in nature, to en event that oocurred during the past 24 calendar months with one or more of the same root causes. There la opproximately one month leg in reportJng this indicator due to the time to complete root cause investigations. (# during the month)

Performance criterion: Greater than or equal to 10% of totalInvestigations indicate repeat events.

23. Number of Problem identification Forma (PlFs) Written The number of PlFs written by the she. (# during the month)

Performance criterion: Trend for 6 months to establish baseline prior to selecting cnterion.

GTHER -

I J4. Overtime Hours The number of overtime hours worked by hourly and salaried personnel through grade 11 by site pe month. (total overtime hours at the end of the month)

Performanos criterion: Greater than or equal to 10% of planned overtime hours.

25. Cited NRC Violations The number of ched violations per month. The month in which the 6nspection report is issued is the month in which the cited violation is counted. (total # during the month)

Performance erherion: Trond for 6 months to establish baseline prior to selecting criterion.

7

DRAFT Mr. James J. O'Connor Chairman and Chief Executive Officer Commonwealth Edison Company P.O. Box 767 Chicago, Illinois 60690

SUBJECT:

REVIEW OF COMMONWEALTH EDISON COMPANY'S RESPONSE TO NRC'S REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING SAFETY PERFORMANCE AT COMMONWEALTH EDISON COMPANY NUCLEAR STATIONS

Dear Mr. O'Connor:

The staff received your response dated March 28, 1997, as supplemented on April 15, 1997, to the NRC's January 27, 1997 Request for Information pursuant to 10 CFR 50.54(f) regarding safety performance at Comonwealth Edison Company (Comed) Nuclear Stations. The January 27, 1997, letter requested the following information:

(a) Information explaining why NRC should have confidence in Comed's ability to operate six nuclear stations while sustaining performance improvement at each site.

(b) Criteria that you have established or plan to establish to measure performance in light of the concerns identified and your proposed actions if those criteria are not met.

As discussed in the Commission Meeting on April 25, 1997, the staff has reviewed your response to the NRC's 50.54(f) letter, including the merits of initiatives to establish performance indicators, criteria to measure effectiveness, and actions to be taken by Comed to sustain continuous improvement. The staff's report is enclosed. (INSERT ADDITIONAL INFORMATION DISCUSSED AT APRIL 25th COMMIS$10N MEETING AS APPROPRIATE)

Your resi,onse focused on its overall nuclear program and did not attempt to address in depth the details of performance improvements at each site. The staff recognizes your success is highly dependent on the ability to (1) effectively implement the programs and initiatives discussed in your response.

performance (2) perform

, and effectiveeffective (3) implement self-assessments designed followup actions to to measure sustain improvement based upon performance feedback.

Based 'n our review, we find that (1) you have established a set of performance measures and proposed actions if applicable criteria are not met and (2) the response in total provides a broadly based and reasonable set of actions that, if effectively implemented, should enhance Comed's capability to operate, monitor, and assess its six nuclear stations while sustaining performance improvement at each site. Thus, your response satisfies the NRC's January 27, 1997 Request for Information pursuant to 10 CFR 50.54(f).

i

DRAFT I

In order to assess your performance at each site, the staff will utilize the current inspection and assessment programs to evaluate performance. As you know, the NRC currently has substantial regional and headquarters staff resources a; signed to augmented oversight for the poorer performing Comed sites. Our intention is to monitor plant performance individually and collectively such that improvement initiatives at each station can be evaluated and negative performance trends can be identified as early as l possible.

In implementing this strategy, the staff will also assess whether your actions in response to plant events or issues at one facility are impacting performance at other Comed sites. Your ability to manage improvement initiatives at one station, without a corresponding decline in performanco at another station, is critical to arresting the cyclic performance.

A meeting for you to present informatiot on your performance indicators will be scheduled in the near future. In addition, we will schedule periodic management meetings between NRC and Comed senior management to discuss performance at all Comed plants, and discuss the effectiveness of Comed's corporate and site-specific corrective actions.

Sincerely, L. Joseph Callan Executive Director for Operations Docket Nos. STN 50-454, STN 50-455, STN 50-456, STN 50-457, STN 50-237, 50-249, 50-373, 50-374, 50-254, 50-265, 50-295, 50-304

Enclosure:

As stated cc w/ enc 1: See next page t

i

um q, .. ruu-n,,,nnu n u. it mm February 18,1997 United States Nudear Regulatory Comnission .

Aner6on. Document Control Desk Washington, D.C. 20555 Subject-LaSa!!e Court / Nudear Station Urdts 1 and 2 NRC DWA Numbers %373 and B374 in the fall of 1996, I deidad to corrnission a emprehensive assessment of performance at LaSalle and Zon Stations. I appointed a team cormrised of seven independent nudsar consuhants, eat with more than 20 years of experiens u operations, maintenance, engineering support, and management at bett perfoming nudear plants. During the onsite portion of its review, the team was augmented by approximately ten INPO and industry peer experts. I asked the team to identify gaps between our performary;e and that of the best nudear plants in the IA%d States, and to place particular emphasis on the fundamental causes that have i

prevented schlwement o' best performance. Endosed is the Independent Assessment Team Report for LaSalle Station.

On November 19,1996 members of my staff and the ISAT team leader visited your c60s to rwiew the process used for the assessment. CNor a period of three weeks l

the Team twiewed written periciii-r.cc rronhoring and assessment documentation l and then conducted a two week onske inspection. The Nm dehf,ded site tranagement at LaSalle on December 13,1996. !nhn~_ con irem the debrief was made available to pu during a visit to the region on Decenter 23,1996 by members of my staff and the ISAT. LaSalle management rwiewed the report, din ==ad the results in meetings with the workforce aM re-assessed our 1997 Operational Plan to assure the plans are riggersive to the insights prodded by the ISAT In addition, Comed has s6eduled a public briefing on February 20,1997 at which ISAT, the LaSa!!e management team will review their responsive actions with the I hwe personally rwieusd the ISAT Report and agree with its condusions. The Chief Nudsar Operating Officer, Many Keiser, and I have set expectations for the LaSalle Site Vice President and correctrve actions have a! ready been initiated at LaSalle County Station. ADJgh the ISAT focused upon fundamental causes and did rot review the effectiveness of our ongdng irrprovement initiatives, the ISAT did recognize that many of the rawwy corrective a:tions were already in place as A Unicom Compa ,

W& hp-  !

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U. S. Nudear Regulatory Comnission 2 February 18,1997 edions in our 1996 Opwational Plan. Addnional corredive adions to assure that the ISAT fundamental causes are addressed have boon irc.gp w.ted in the UnN 1/Unh 2 Restart Plan and will be continued as part d our 1997 Operational Plan.

Long term sustainable irmrwoment Wil be the focus in our future Operational Plans. W. Kaiser has relayed his expectations to the Wte on the effedive resolution l

of these issues and will be Ms iing periodic assessments of our progress.

The self initist td usessment tiy a respeded team of industry prdessionals was painfd, we know it would be, and we accept IL Hmover, we also know that unless we measure ourselves by the standards of the best plants, we will never asieve best-indess pwfw . ir ourselves. I hope that our willingness to publidy expose our weaknesses and to refeaJs our people and plans on excellent performanos, not just adequate p.iformance, is T.sy,!z.d as now. -

R is my mandate to operste Comikrs 12 nudear reactors in a safe manner. Wth a focus on operational excellence, coupled with the dec4i.if, of a strong self-assessing aAture, I beliwe Comed will dwcs. .ie sustainable p.fvi .,,c.

irmrovement and achieve best-in class nudear industry p.ifwi .nce.

Sincerely, '

Thomas J. Ma QG. n Executive Vice President oc: th. A Bill Beach

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IS AT - inserensent scitassessment ream l

An Assessment of LaSalle County Nuclear Station An Independent Self Assessment l

4 February 18,1997

.A?J ;g 60/0 *W _.

Mr. Huold W. Keiser Vice President, Odef Nuclear Operadnt Officer 1400 Opus One, Suite 900 Comed Company Downers Oreve, Illinois 60515

Dear Harry,

We am pleased to have completed your request for an independent assessment of the performan:e at LaSalle Station. '!he results of our auessment are summarized in the enclosed repon, and nspond to your request that we idendfy the fundamental causes or " whys" that drove declining performance.

We appreciate the spirit of openness, cooperadon and interest shown by Comed personnel with whern we interacted during the course of the assessment. We acknowledge Comed management for steadfastly maintaining our independence and their commitment to crideal self assessment.

Thtdecision to subject LaSalle County Stadon and the Nuclear Operarlons Division to an independent self assessment is an aggressive and credible step toward your goal of achievir.g superior performance. We believe that the aggressive actions you have begun will address the fundamental causes that our assessment identified. We wish you the utmost success in those efforts.

Sincerely.

The independent Self Assenment Team W kb . Yi dAAu Wanen Pupnotdl.zader HImy Kiste( ' \

A s lo r - 1% J/ o

' Sieber Ben

" st:rm _.

(ohn Durham Fred Dacimo aObr-C. W.Hendrix, Jr.

• 9

IA- INTRODUCTION 1.1 Ohlective ofIndonenden: Eelf A- x ..nl

{

1he independent Self Aasessnent Team OSAT) was assembled at the request of the Chief Nuclear Officer of the Comed Nuclear Operadons Division (NOD). The Independent self Assessment OSA) was led by a core group of seven senior nuclear consultants extemal to the Comed organi:ation, who were requested to conduct an inr'yndent assesshent of performance at LaSalle County Station (LaSalle). The assessment was intended to provide Comed management with an independent perspeedve on maLor i performance weaknesses, with pardeular emphasis on the fundamental causes of those weaknesses. The ISAT was also invited to provide insights conceming the effec.dveneas of ongoing and planned CmEd inidadves to improve identified performance lasues and to recommend post. assessment steps.

1.2 Methodelan and Etandeds for A-- ux:

The ISAT assessed performance at L.aSalle over the past two years in five functional areas:

Operadons and Training Maintenance, Engineering and Technical Support Plant Support, and Management and Organlaation. The ISAT's assessment process consisted of three phases.

in Phase 1, oser a three week period. the core team performed a detailed review of exisdng perfonnsace monitoring and assessnent documentadon. These documents included, but were not limited to, NRC inspections, evaluadons, and Comed assessments, correcdve action documents and performance improvement plans. The majority of the weaknesses described in this IS A repon were identined in these documents.

In Phase 2, over a two week period, the 1S AT veri 8ed the Phase 1.identined maknesses based upon LaSalle observations, interviews and funher document myiews. The core team members

("ere augmented by INPO and indur'ry peers in connection with the Phase 2 work .

In Phase 3 over a two week period, utilizing the results of Phases I and 2, associated causal factors for LaSalle weaknesses in four functional areas (operadons, mairdes.ers, engineering and plant support) were documened by the core team (Anachment A). _ A set of fundamental causes was then developed for the assessment of managt. ment and organization.

.a the assessment proceeded, the ISAT determined that it would deliver maximum value by ccricentrating on the performance weakneues and the undertying ceuscs.1he ISAT's emphasis was plaud on problem definidon and idendfication of fundamental causes, rather than '

corrective aedons. Consequendy, the IS AT did not focus upon the effectiveness of ongoing and planned improvement inidativu. The ISAT acknowledges that many cormedve acdons wie in the proce.s of being developed, and some have already been implemented, to address LaSalle weaknesses.

1he ISAT did not conduct detailed asseaunerds of the performance of the oversight and assessment functions within the Comed nuclear organization, nor did it assess the performance of the regulatory assurance functions at LaSalle. In the context ofits integrated nylew of management and organizaden, the ISAT esamined the end resuhs and effects of the Comed oversight and assessment functions. Those end results and effects are described in the Pundamentv Cause Assessment in Secdon 3 of this repon.

d"d SA

The MATS manQard for assessment of perfonnance reflected its collecdve experience and was intenaud to represent the performance of a best performing plant. Unless otherwise stated this

' mandard appUed to all phases of the ISA. The 15AT focused on the end results of NOD decisions he ISAT did not anempt to define the specific adons that Comed management should take to assure safery, regulatory compUance or best. performance.

De IS AT did not roevaluate Comed's historical decision making processes or the condidons under which decisions were made. De IS AT placed emphasis on communicadon of observations and causal factors to assist Comed in understanding and acceleradng its efforu to tesolve the issues which are critical to addeve and sustain excellent performance at !.aSalle.

1.3 Ana.nnment Team Mshrdile and Qggggghiggt Ri cort members of the ISAT and their respeedve assessment responsibilities and backgrounds are:

jfg]dgf Ana tement keenntihility Background Wanen Fujimoto Team 1.sader and l Former Vice President Management and Pacific Gas & Electric Co.

Organization Diablo Canyon 23 years nuclear power experience Harn Kister Maragement and Former USNRC. Region 1.!!! and Orgarutadon Headquaners1&E 36 years nuclearpowerexperience John Durham, P.E. Engineering and Technical FormerEngineering Manascr1mpell Support Corp.! Carnlina Power & Light 23 years nuclear power experience Dr. Benjamin Dow Engineering and Technical Former Manager Nuclear Services.

Support Arkansas Power & Light 23 years nuclear power experience C.W. Hendrix, Jr. Maintenance Duke Fgineering Services. Manager of

' Maintenance Engineering Services 25 years nuclear power experience Fred Dacimo Operadons Former Operadons Vice President.

Northeast Udlides 20 years nuclear power experience John Sieber Plant Suppon FormerSenior Vice President and Odef Nuclear Omcer, Duquesne IJght Company 36 years nuclear power experience 4 k Am ma

The core ISAT members were augmented by INPO evaluators and indurry peers, as fobows:

Aurmented Team Persnnnel Amnessmer@emonsibility Orennbarional Affiliation L Thibault Management & Organization INPO Gary Peet - Operations INPO Joe Kappes Maintenance INPO ,

John Maciejewskj Engmeeting INPO Paul DiRho - Operadons INPO William Gatrett Operations APS Palo Verde John Petri 11a Operations PP&L Susquehanna Dan Bost Engmeeting Entergy Grand Gulf Charles Grider Maintenance '!VA.Sequoyah Dave Barcomb Radiadon Protection Niagra Mohawk.Ni w Mile Point 2 The ISAT received support from Jim Abel, JoEllen Bums, ano Jim Gieseker of Comed, who served as haisons to the line organization and were instrumental in gaining prompt access to information, documents and individuals.

2.0 FUNCTIONAL AREA CAUSAL FACTORE Tae ISAT's supporting observations and causal factors for operations, maintenance, enginegring and plant suppon are summarized below.

2.1 Qnerations and Tralnjng The IS AT found that important attributes of operadonal exceDence were not evident at LaSalle, The organization was not focused cn the vision of best performance and did not have an understanding of, and a commitment to, the principle that strtag economic performance must be driven by operadonal exceDence, The ISAT observed a gap in management and bargaining unit relations, which was reflected in a lack of bargaining unit buy in to management expectations and operational execuence. A lack of teamwork has resulted from management tumover, hmited worker input to chant management, and incomplete worker buy in to the success of the plant. Operadons managemmt has not functioned as the gatekeeper for safe operadon and nuclear excellence, Jn the aggregate the operations department training performance deficiencies, particularly those observed in simulator scenarios, led the ISAT to quesdon operanns shift crew capability. The ISAT understands that LaSalle management has been working to resolve the identified deficiencies. The IS AT and LaSalle management agree that the identified training de6ciencies need to be resolved prior to resart of the units.

2.2 Maintenane Large work backlogs, poor materiel condition and low system and equipment availability and i reliability have resulted .vom issues related to the work control process, performance standards, manag: ment expectations, first line supervisor involvement, team problem solving and the malruenance training progrra. Changes to the work control system to address the dual unit outage, Operations 1996 Plan (OP96) and emergent engineering work wert not dicesively implemented. Management has not provicki the leadership to enforce schedule accountabiliry and Mtahlich schedule control. A com@:nsive set of maintenance performance metrics, manMehmanNasetm2.de&g. 3 u

which monitorlong term performance attributes as well as production have not been developed.

First line supervisors have not been udlized as primary agents for affecting change. First line supervisors have not maintained a presence in the field and have not hela themselves or their peers accountable. Involvement of workers in problem soMng and a common worker and supervisor vision were not evident. Manarment and the bargaining urdt have not worked as a team to resolve long standing lasues that hinder maintenance department improvement. .

Trainiq has not been utilized as an effecdve change mechardsm and a means to obtam long.

term benefits.

2.3 Eneineerine and Technlent Euanen Engineering has not effectively addressed long-term engineering issues invoMng configuration management, design and hensing basis, engineering work quality, system engineering, engineering work management and system and equipment performance. Long standmg engineering issues have apparandy not been given enough priority by LaSalle and corporcle management to allocate the resources necessary to resolve these issues. Pnmary examples are the failuvas to develop, make available and assure compliance with essential design basis documentation; to maintain configuradon documeritadon current; and to upgrade serpoint calcGations to account for instrument loop uncenalnty, These examples, along

• with the large number of unauthorized design changes that have been implemerued. indicate that the ! aSalle engineering organization has not been effective as the design authority and technical conscience of the station. Engineering work has tiot always been timely, thorough and technically corrtet.

Engineering has not applied the resources, experienced personnel, training, and workload prioritizatien to effectively implement the system engineering i funct on. Engineering backlog have not been completely identified, consistently prioritized or evaluated. Engir.eering has no been effective in resolving long standmg materiel condidon and recurnng equipment ,

ptMem This led the team to conclude that LaSalle management needs to condnue to examine and breadth of these issues and to take corrective actions in order to provide additional assurance that the LaSalle units can be safely operated within their design and licensing bases. ,

2.4 Plant Sunnort Plant support orgardzadons, which consist of radiaden protection, che.nistry, emergency planning, fire protection, and security, have generally performed their assigned responsibilitie adequately. Weaknesses were noted in the areas of workerradiation exposure, contaminated plant areas, meteorological tower configuration and fire protecdon materiel condition.

3.0 FUNDAMENTAL CAUSE AREERSMENT. MANAGEMENT AND ORGANIZATION Upon completion of the Phase 1 and 2 reviews, the ISAT team performed a review of the cau for operadons, maintenance, engmeering and plant support and conducted a fundamental cause assessment for the management and orgardzation functional area. This collective review identified f fundamental causes that wert evident from the analysis of causal factors: commitment to e leadership, standards, and management skills. Under each of the fundamental causes, the cor identified a set of contributing causes. The fundamental and contributing causes art mated belo

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_ _ ______ . I

e 3.1 Commitment to Eteellence t

Comed has not consistendy mamtained focus on the vision of world class performance and a commitment to the principle that strong economic perfonnance must be driven by excellence in nuclear operadons and uncompromising safety. The following factors contributed to this fundamental cause:

There has not been sufficient and consistent appreciation of the resources needed to acNeve and sustain long term, bea plant performance. There has been an overemphasis on budget control wNch has resulted in decisions that have hindered or eliminated important improvement projects.

The organizadon has not continually pursued a safety culture ahead of produedon and budgets. Production and budget incendves appear to drive the organization.

3.2 Indershio Senior management has not consistently provided the leadersNp to acNeve excellence in nuclear operations and safety The folicwing factors contributed to this fundamental cause:

LeadersNp has not always fostered an environment that promoted high standards, shared values, personnel accountability and conservadve decision making.

Improvement initiadves have not resulted in sustained performance improvements and management has not been held accountable for results.

Accountability has ne Men consistendy understood, practiced or enforced. Accountabilit l often appears to mean discipline to the organization. To many employees, accountability perceived as punistunent rather than coaching and communicating Ngh standards and expectations.

Trauung programs have not routinely teen viewed as a means to effect change and obtain results. There has been a lack of appreciadon for the benefits that training provides.

Training his not been continuously evaluated and updated.

1.cadership has not always been able to gain bargaining unit ownership and commitment to nuclear excellence. .

3.3 Standards Senior NOD and LaSalle management have not established consistently high standards of performance for LaSalle and NOD. Standards have been accepted by management that result a tolerance of deficient conditions and nonconservative decisions. The following factors contributed to this fundamental cause:

Contetive actions have at times been slow, narrowly focused, deferred or incorrectly prioritized issues.

to resolve important process, materiel condition and configuration managem man &lahaarNesaata::.docPg. 5

o Engineering has not routinely been considered as a high priority function for the safe and rtilable operation of the station, and thertfort, resources have not been provided to corTret long standing issues.

Operations leadership has not exemplified and promulgated high standards by their tolerance of long standmg materiel condition and configuration management issues at '

1.aSalle, 3,4 Manneement Ekills 1he nuclear orgardzation did not have the required management skills to improve substandard performance, to monitor and continue improvement efforts and to implement sound oversight programs. Senior management did not have a good understandmg of the significance and depth of issues at LaSalle, The following contributed to this fundamental cause:

Nuclear oversight orgardzations have not effectively evaluated the available information on plant performance and therefore have not successfully influenced constructive management actions forimproved performance.

The budgeting prioritizadon process has not supported activites for improving station perfortnance,1.ASalle was given an annual budget amount to plan work for the year, rather than planning the work for the year and then acquiring the necessary funds.

Lessons learned were frequently not communicated, implemented and monitored within the nuclear organizadon. -

Numerous personnel changes have contributed to instability and distrust, which has hindered upward communication and delayed resoludon ofimportant issues, As a result, personnel changes have often not resulted in performance improvement.

Management personnel selection did not always match a candidate's skills and experienc with existing stadon performance issues.

Change management has been more like a trial and error process rather than a process -

which is planned, implemented, evaluated and adjusted, as necessary.1here has been a lack of understandmg of what it takes to effect change, including the buy in of personnel,

4.0 CONCLUSION

This report provides a brief summary of the IS ATs findings. The ISA1"s intent is to provide su detail in its description of dw fundamental cause assessment and the functional areai causal fact (Attachment A) so that Comed management can formulate responsive and effecdve remedial ac .

1he IS AT acknowledges the excellent cooperadon it stoelved from all elements of the Cou$d organizadon, in addition, the IS AT recognizes Comed management for understandmg the need fo independent self assessment, maintaining the independence of the Independent Self As and sustaining their commitment to the pursuit of vigorous self criticism.

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ATTACHMENT A LASALLE INDEPENDENT SELF ASSESSMENT CAUSAL FACTOR

SUMMARY

2.0 FtrNCTIONAL AREA CAUSAL FACTORS The following discussion summarizes the causal factors derived by the 15 AT for each of the functional .

areas of operadons, maintenance, engineering, and plant support. As indicated in Seedon 1.2 of the ISA report the IS AT"s standard for assessment of performance reDected its collective experience and was intended to represent the performance of a best. performing planL 1he ISAT's documentadon review was generally fecused upon the past two years and its observadons were of current performance. The ISAT did not reevaluate f'nenF#s historical decision making process or the condidons under which decisions were made. In addidon, tne IS AT was directed by Comed management to idendfy issues and make crideal observadons using a low evidendary threshold. In other words, Comed management did not expect the ISAT to defmidvely demonstrate the existence, frequency or breadth of a particular Problem. Instead. when the IS AT's observation and experience indicated the likely existence of a particular problem, it was expected to identify that problem so that Comed management could take appropriate action.

2.1 Onerations and Trainine The IS AT review of 1.aSalle operations addressed seven major areas of concem. The findings describe in boad terms "what is missing" or "what prevents"LaSalle from becoming a best-performing plant. Causal factors for each of the seven areas are provided below.

2.1.1 Onerational Emilence The amibutes utilized for assessment of operational excellence are the following:

Good procedure quality

• Strong procedural adherence Sound communicadon techniques Solid self diecking programs

• - Positive operatorbeanng with a quesdaning attitude Conservative decision making Good use and acceptance of supervisory oversight Technical competence and aue:alon to detail During the ISAT visit to LaSalle numerous signs and posters were observed which addressed being "commlned to excellence" of which operational excellence is an integral part.1his was considered a visible sign of management's commitment to excellence and a connnual reminder to employees of management's philosophy.

When individuals in operations were specifically questioned if they were personally committed to " excellence", their answer was almost invariably "yes". When funher questioned however, few individuals did a reasonable job ofidentifying any of the aforementioned eight anributes of operational excellence. Additionally, there was linie recognition as to how an individual could contribute to improving operations' performance.

In fact, personnel stated that they believed previous management was not commined to operational excellence. Imr.g.standmg materiel condition issues wert frequently cited to suppon this belief.

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2.1.1.1 Cautal Faeton

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• Individuals interviewed by the IS AT did not recognize that a bedrock commitment to operadonal excellence and nuclear safety results in long term economic performance. These individuals also did not understand that the best performing plants wert usuaUy the most cost-competitive. Little recognition caisted of the INPO study regarthng this subject.

• LaSalle was previously recognized as having sound performance, LaSalle previously had an INPO 1 rating as weU as S ALP 1 ratings in a number of areas.

Very few individuals recognized that comparative industry performance had improved dramadcaUy, Discussions with individuals indicated that plant and personnel performance had not reauy changed for several years. Complacency and acceptance of the starus quo seems to have occuned and contributed to LaSalle's declining performance and commitment to exceDence.

Many individuals did not recognize that most of the operations manager's standards simply represented current industry norms.

2.1.2 Gao Between Mananen and Barraintne Unit As previously idendfied, the IS AT also determined that bargaining unit and management issues and relations require additional attentiort Management and bargaining urdt personnel did not appear to realize that LaSalle's success requires an interdependence of action; one group cannot succeed without the other. A philosophy of"we are aU in this together" does not exist.

The gap between management and the bargaining unit is a signdicant issue confmnting LaSalle.

The IS AT is not awart of a nuclear station that has achieved high levels of performance without a fully engaged workforce, At LaSaUe, management has pointed to the bargaining unit as the source of declining performance while the bargaining unit has pointed to management.

Both sides have not taken responsibility to resolve their differences.

2.1.2.1 CanafFaeton Poor co nmunicadons exist. Issues have nc,t been corepietely shared.

expectadons have not been continuously reinforced and communicadon has not been fostered.

There was a perception of hidden agendas on the part of management and on the pan of the bargaming unit. Full disclosure of the " whys" of actions taken does not always appearto exist.

A high degree of mistrust exists between management and the bargaining unit. In some cases the barBainmg unit does not trust or believe management, and management does not appear to trust the modves of the bargaining unit in cernin instances.

High tumover in management has frequently occurred. 1here has been over a 100 %

tumoverin the stadon's middle and upper management levels over the last three years. This tumover has caused a lack of continuity in policy and direction in the operations depanment.

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o First line supervision is not fully knowledgeable about the bargaining unit c(r. tract and agreements. The centract knowledge of Ngher level managers was not assessed 2.1.3 Lack of Teamwork There is a lack of teamwork at LaSalle. Few groups and organizations work together effectively. Each group or individual appears to view issues on an individual basis and do not endeavor to ensure team success. It appears that teamwork issues exist within the shift organizations.

2.1J.1 Causal Factors There have been multiple changes in the management team and little continuity exists. This has resulted in an atmosphere of uncertainty and mistrust which has hampered teamwort Some manager and supervisor interpersonal skill deficiencies which impact teamwork were observed.

Workers have a "me first" attitude wNch is detrimental to teamwork. In some instances they seem to be more interested in the personal impact of change than the positive effect it may have on station operations. This is not conducive to teamwort 2.1.4 Shlft Manacer Performance Shift managers have not set the standards for the station. They have not functioned as the

" gatekeepers" for safe operation and nuclear excellence.

2.1.4.1 Causa1 Factors Shift managers have not felt empowered to make changes of to hold individuals to high standards.

Shift managers are not always viewed or treated as managers by the station managemern team.

Insufficient formal training and development has been provided to prepare shift managers forleadership roles.

Ihscussions with senior management at LaSalle indicated that the capability to operate at a higher performance level may be beyond the ability of some shift managers.

Wh%eehaa.doePg 9

-2.1.5 Deficient Traintne in the aggregate. rhe operadons depanment training deficiencies have led the 15 AT to question crew capabilities. The IS AT understands that management will promptly resolve these denciencies.

Training is not used as a tool to upgrade asuan pufonnw.e Training is viewed only as a ,

license requirement.

2.1.5.1 Cantal Factors Tralrung is not recognized as a vehicle to make change. Most operations management personnel have not taken a personal interest in the training program.

Instnictor proficiency appears to be a deficiency. Objectives were not adhered to or covered on a regular basis and in some cases there was a poor understanding of simulator scenanos.

Simulator fidelity concerns may impact training effectiveness.

Operations standards were inadquately enforced. For example, substandard cridques and untimely class anendance were observed. An uncooperative atmosphere was observed between instructors and shift personnel.

2.1.6 Inadenuate Channe Mananement Skills Operadons management does not fully appreciate the complexity of change management. There is not a complete undetstandmg that the organization can only accept so much change before confusion occurs. Message repetition, along with demonstrated actions by management to

" walk the talk", has not consistently occurred.

2.1.6.1 Cantal Factors Communications are inadequate at nearly t.ll levels. Managers do not appear to take ownership and champion policies and issues.

Inadequate follow through of previous improvement initiatives has resulted in the-perception and attitude that cenaln changes will eventually go away.

Early and consistent buy in by operators has not been sought to foster a change message and develop change champions.

Change is not effectively implemented. Workers' input has not always been soli::ited or included in some new and ongoing change improvement programs.

The large number of management and policy changes have overwhelmed the operations organization.

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. 2.1,7 Lack of Understandine of Aerountabilitv A lack of understanding exists fo-what accountability means. When discussed with managers, nearly all defined accountability as discipline. The elements of coaching, counseling and ownership an rarely addnssed. The lack of accountability was evident during IS AT observations of day to day operations.

2.1.7.1 Caumal Faetors Many employees do not have the benefit of broader industry experience and perspectives. Operations personnel have rxx interacted with role models that demonstrate the phuosophy of personal, team and depanmental accountab21ty.

Individuals and supervision find it difficult to confront each other in connection with weak performance: thus many oppcniunities to practice accountability are missed.

2.2 MAINTENANCE Dunng the assessment of the maintenance function five issues were raised which are impacting LaSalle's ability to identify, prioridze, plan, schedule and execute work. These issues have resulted in large work backlogs, poor materiel condition and low system and equipment availabillry and reliability. These issues involve substandard performance in the following areas:

• Work control process Performance standards and management expectations

• First line supervisor field involvement Teamwork and accountability Maintenance training program These major concerns, along with significant subar issues, art discussed in detail below.

2.2.1 Work Control Process The work concol process at LaSalle does not suppon the efficient identificadon, prioritization and execution of work.1hrte major concerns exist:

A firm scope control plan has not been implemented to deal with the large volume of work added to both unit outage schedules.

1ruerface problems between the workers and the werk analysts delay mar.y jobs.

Station leadership and direction of the overall work management prtv.ess have not supponed scheduling and coordmation of work dunng a two unit optage.

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2.2.1.1 cauent Factnrs

• LaSalle managemem has not provided the leadership required to forte schedule accountabillry for all personnel. Implementation of changes to the work control

• process to address the dual unit outage. OP96 plan and emergent engineering was weak. Management did not provide the initial direction or adequately monitor implementation. Station personnel were not held accountable for making the -

system work. De cunent dual unit outage coupled with the significant amount of emerging enginet.dng work has overloaded the system.

De station has not decided to operate as a schedule comrolled business unit. he organization is in plam and the workforce is willing to work a schedule.

Schedule control, however, has not been established and ine resultant default mode is to allow first line supervisors to select work independent of the published stadon schedule.

2.2.2 N brmance Standards and Manneement E=*entions Management has not developed a comprehensive set of maintenance performance metrics which reflect cunent industry praedces. Some standards do exist; howev:r, these have not been communicated to first line supervisors and workers in the form of cortistently enforced expectatioris, he lack of a comprehensive set of performance measures has hindered the establishment ofimprovement goals and action plans. Without performance measures progress cannot be monitored.

i 2.2.2.1 Causul Factors I

Management emphasis has been focused on short term production. De performance indicator ofimportance was the shon tenn availability of the unit.

Indicators of high quality maintenance supporting lace term performance such as low work backlogs, low rtwork, training program compliance, materiel condition improvement and staff professionalism were not emphasized. Maintenance management was not held accountable for developing or implementing standants in these areas.

2.2.3 First Line Sunervisor Field Involva.a.i First line supe 1 visor presence in the field is not sufficient to ensure that hb performance meets management expecsations. Supervisors m a key ingredient in promoting change. Rennse they a not in the field, they m not involved in coaching, quality checking, on-the job traming (OIT) and providing technical resources required to improve maintenance depanment performance. Dey a not available to help set and communicate management expctations.

2.1.3.1 CausalFactors Management has not recognized er key role that first line supenision plays in implementing the changes required to improve performance. Maintenance management has not eenhfithed nor supponed an expectation for increasing the field involvement of the supervisors. Steps have not been taken to address those problems that prevent field involvement. Problems such as work package quality and scheduling kept supervisors out of the 6 eld.

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o Supervisors have not held themselves or their peers accountable for doing their jobs. Supervisors have been content to simply do the work analysts' job rather than hold them isountab!< for providing a high quality product.

2.2.4 Teamwork and Acteuntability The maintenance management philosophy at LaSalle does not prarnote team problem solving.

The phDosophy has been to ducct work from the top down. Involvement of the workers in identificadon and resolution ofissue' has not been encouraged Maintenance does not always aMiess important issues as an integrated worker, supervision and management team with the recognition that a common vision is a prerequisite for success.

23.4.1 Canu1 Factors Bragaining unit and maintenance managemerd have not recognized that in order to succeed they must work as a team to identify and resolve problems. There is a top down phDosophy for problem identificadon and resolution at LaSalle.

Mamtenance department management and first lire supervisors do not always appropriately involve bargaining unit personnel in the identification and resolution process.

'ihere has been a reluctance on the pan of management to involve workers in developing solutions. Many managers may be uncomfonable allowing workers the freedom to solve problems themselves.

The bargaining unit has been reluctant to fully engage the workforce in taking ownership for pmblem resolution. This is due to the lack of trust between workers and management resulting in pan from the many programs of the-month, the high tumover in management and the reluctance on the pan of some employees to change.

'!he bargaining unit works to protect traditional bargaining unit contract posidans and precedents regardless of their impact on maintenarre department l

performance. Maintenance management and the hvgaining unit have not behaved as if they have a common vision for identification and resolution of problems. Taking p:rsonal responsibility for resolving problems has not been encouraged by maintenance department management and bargaining unit leadership.

2.2.5 Maintenance Trainine Procram

'Ihe cunent training program does not fuDy suppon the development and continuing improvement of the maintenance workforce. First line supervision and workers do not own this program. It was recognized that the program was not meeting the depamnent's needs yet no actions were taken. The ineffectiveness of the maintenance trauung program contributed to the high levels of rework and work backlogs.

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2.2.5.1 Cauen) Factors Management did not take full advantage of the long term benefits of an effective 4

' tmining program. The focus was on thoir artu that promoted shon tenn availabihty at minimum costs.

Trainmg was seen only as a mmmeum reouirernera to meet regulatory obligstions.

Managemern has not made a commitment to make resources available regardless of competing neu:is. Long-term benefits were sacrificed for shon term budget gains.

2.3 ENGINEERING AND TECHNICAL ELPPORT The engineering Orpudzation was assessed to determine its performance as the design authority and technical conscience of LaSalle. Also assessed was the ability of the engineering

' org nization to provide high quality and responsive engineering and schnical support to the other organizariuns.

l The IS AT confirmed % the performance of LaSalle engineering is significantly below that of <

best performing pianu. Engineering has not been effective as the design authority and technical l

conscience of1.aSaue and has not alwap provided high quality and responsive engineering suppon to other LaSalle organizations. It was found that engineering is primarily focused on l resolving shon term and emerging issues. Engineering has not effectively addressed long tenn l

engineering issues involving con 5guation management. design basis and equipment performance. The resources needed to establish and sustain good engineering performance have not been applied. The following amas were found to be in need ofimprovement:

!

• Configuration management Design andlicensing basis Engineering wort quauty

• System engmeering Engineering work management

• ~

System and equipment performance Deficiencies in each of these areas have been identified previously, were validated in this assessment and have continued to recur for a number of years. There are several reasons for this.

Past leadership of the engmeering organization has not been effective in establishing, enmmunicanng, supporung, monitorms and enforcing high standards of performance. Low standards of performance have been tolerated in that deficient conditions and less than adequ work have been ==M Corporate and LaSalle engineering management have not provided the duecdon, focus and coaching needed for the staff to be successful Cornpounding the lack of success has been the large tumover of management, supervision and group leaders within th engineering organization.

mamahnsen%naabnidnes. 34

Most imponant is the fact that corporate and LaSalle engineering leadership have not effeedvely-championed engineering issues within the Comed organi:stiort 1,ong stancing engineering issues have apparendy not been given enough priority by 1.ASalle and corporate management to allocate ine necessary resources to itsolve these issues Primary examples are the failures to develop essential design basis documentation (DBD); to assure ernpliance with the design and licensing basis; to maintain connguration docurnentation curent; and to upgrade setpoint calculations to account for vistrument loop uncensinty. These examples, along with the large .

number of unauthonzad design changes implemented thwgh work requests, indicate that the LaSalle engineeririg organizan m has not been effeedve as the design authority and technical conscience of the statioit This led the ISAT to conclude th u 14Salle management needs to contmue to examine the depth c.nd breadth of these issues in orLet to provide reasonable assurance that the LaSalle units can be safely operated within their design and licensing bases.

Related causal factors for each of these attas are discussed below.

2.3.1 Conneuration Manneement Configuration management deficiencies have occuned where the design change process has been circumvented and important configuration documentation has not been revised to be cunent with the as built plant.

2.3.1.1- Canen) Factnrs Actions had not been taken to establish and maintain a sound configuration management program at 1.aSalle. Low standards and long standing deficiencies  !

had been tolerated due to the inability to ohutin the requisite funding necessary to

- resolve known and long standmg deficiencies.

Corporate and station management had apparendy not known about or understood the significanoe and the depth of the aforementioned configuration management issues. Engineering management has not been an effective organizational champion for engineering issues and has not " driven hane" the need to address these issues in a timely and complete fashion.

LaSalle organizations did not understand or embrace the importance of maintaining con 5guration management and prohibiting unauthorized changes to .

plant design no maner how minor the changes may have seemed. Additionally. '

ott organizations had been complicit in the configuration management issues in that mey tolerated deficiencies for a significant period of time even though their work had been adversely impacted (e.g., incontet instrument data sheets and air

_ system P&. ids).

2.3.2 Demian and Licensine R==le Design and licensing basis infonnation is not always accessible, defined or documented, maintamed consistent and cunent, or understood and implemented in LaSalle activities.

Engineermg personnel have not consistently assured that the as built and as operated plant is within the design and licensmg basis.

mm . , v.. ts

2.3.2.1 rwat Facton

• . Funding has not been provided to define, develop and validate the plant desiF n basis, to develop contet setpoint calculations, and to resolve known instrument documenution de$ciencia.s F.agineering management has not effecovely served as an orNantutional '

champion for engmeering issues and " driven home" the need to address these issues in a timely and complete fashion.

Station organizatims have not understood the imponance of making available and maintaining accurate and consistent design basis informadan to suppon essendal station activides. *!hus, these issues have not received the requisite fundmg and attention needed to resolve them, 23.3 EDEH' igggina Work Oualltv Engineering work has not slways been timely, thorough and technically contet.

2.3.3.1 Cantal Factors

• Wre has been a significant amount of emerging work from L2R07 and LIF035 that has required design change packages (DCPs) to be developed on short notice, Also, the move to provide engineering in house in the 19941995 period has not been effeedve, Resources from the primary architect engineer were significantly reduced during the time period when DCPs for L1R07 and other LIR07 outage activities wert in preparation. It was believed by those interviewed that this reduction did not allow adequate dme to properly prepart for LlR07 and L2R07 and contributed to DCP quality problems.

A strong production focus has contributed to less than rigorous and incomplete engmeeting and safety evaluations, Also, the lack of concise, complete and consistent design basis information has been a contributing factor.

'!he failure to conduct proper testing appears to be due to a lack of knowledge of contet testmg methods and how to conectly interpret test results.

2.3.4 System Eneinserine -

The system engmeering funcsion has not been effectively implemented. System engmeers have not been requir:d to determine system design, operadonal and testing requirements and perform requisite monitonng and trendmg to assure that these requirements are met.

2.3.4.1 CausalFactors The roles and responsibilities of system engineers have not been effecsively communicated, supponed and enforced by managemt.nt. System engmeerms is engaged in nonsystem engineering activides such as work package preparation, initial troubleshooting, procedure preparadon and coorthnation of field activities.

System engineering has been expected by other station organizations to perform nmsystem engmeering duties.

m "' % is

i System engineenng activities art not manaye.d to anow fulfiument of a proacdve system engineering function. System engineer wordoad is not always prioritized I

AddidonaDy there are an insuf6cient number of system engineers to effeedvely implement the system engineering functort ,

i 2.3.$ Enrineerine Work Manneement ~

Engineering is not effeedvely managing their worWoad. Engineering backlogs are not completely idendfied, consistendy prioritized, or evaluated. The impact of the engineering bacuog on system readmess is unknown. Long. term engineering issues art not being resolved 2JJ.1 Eagal Factors 1he engineering organizadon has failed to effeedvely prioritize work for the angineering group. A lack of an effecove system for the prioritization cf woruoad dDutes the ability of the engineering staff to resolve imponant technical issues. Problems with the lack of an effeedve work prioridzadon process wert idendfied as early as 1993 in the LaSalle Business Development Report.

The engineering organization has not established an effective workforce management process, Engineering management has not effectively estabhshed, communicated. supponed, monitored, and enforced high expectations and standards and the correct roles and responsibilities for the engineering organization.

Management has historically established an excessively high threshold for issues needing resoludon which has thwarted efforts by system engineers to proactively purtue and resolve manyissues.

Frequent tumover in engineering management, supervision and group leads has been a major contributor to long term engineering and mueriel condition issues not being resolved 2.3.6 System and Enuinment Performane Engineering has not been effective in resolving long standmg materiel condidon and recumng equipmuu problems at LaSalle.

2.3.6.1 raml Factnrs Station and engineering management have tolerated low standards of performance.

Industry operating experience has not been effecdvely reviewed, evaluated and implemented to resolve equipment problems.

The prioritization process used to establish the budget has had too high a -

threshold to address needed improvements. This leads stadon personnel to accept and tolerate deficient conditions that have been identi5ed for correction but not funded.

m"' 4s 11

'o Until 1996, thert does not appear to have been a coordmated effon among station

, organizations to identify maletiel condition items that needed cornetiort 2.4 PLANT St&fQEI Plant suppon consists of radiation protectron, chemistry, emergerw) planning, fire protection, and security. At 1.aSalle, plant materiel condidon and housekeeping present challenges to the quality of the radiadon protection program and the fire protection program. The radiadon protecdon prograrn is also impacted by the poor practices of workers doing work within the radiologically posted area (RPA). All plant suppon funcdons art at'versely impacted by the failure of management to prioridze and aDocate the resources necessary to maintain high performance in the plant suppon areas. Notwithstanding these adverse factors, the plant suppon functions have generally performed their assigned responsibilides adequalcly.

2.4.1 Radiation Protection 2.4.1.1 Worker Radiation Emosure 2.4.1.1.1 Causal Factors The causes of this higher level of worker radiation exposure are as follows:

The radiadon source term in the plant is higher than the industry median. About 324 hot spots" exist in the plant of which about 72 are significant conuibutors to worker @se. Additional effort needs to be put toward reducing or ehminating

, these hot spots.

In addition, the cobalt reduction program, while initially making progress, has been slowed to the point that linie progress is being made.

Pinally, the use of depleted zine that has been effective in reducing source term at other bolung water reactors (BWRs), was inordmately delayed at LaSalle.

Radiation worker praedces are below median industry standards Numerous examples show that radiation worker practices need improvement. Some workers may not fully appreciate the value of good radiadon worker pracdces in reducing individual exposure and -h*n prevendng the spread of contamination and minimizing radwaste. insufficient radiadon worker training appears to contribute to improper radiation worker pracdcas. Addidonally, managers and supervisors either do not rem nin poor radiadon work practices, or do not cornet the cmes they observe. More imponandy, radiadon protection technicians do not consimently use the PIF process to riocument, track and investigate poor radiation worker practices. Radiation protection supervisors are not holdmg the radiation protection technicians accountable for using the PIF process.

Conduct of maintenance contributes to the higher worker exposure at LaSalle.

Analysis of ALARA exposure records indicates that emergent work is a major contributor to the failure to achieve ALARA goals. While it is expected that unplanned emergent work will add dose to total worker exposure, the degree of

emergent work undermines the dose goal setting process, thus reducing the c5cctiveness of the ALARA process In addition. emergent work places an mu m 3 - 7,,, gg l

_A

added burden on the radiation protection department to hurriedly prepare an ALARA analysis that might not be as effective as an analysis that was prepared in ample time before the actual performance of the job. Further, repeat work and rework unnecessarily add to worker exposure.

2.4.1.2 Contaminated niant .ren.

2.4.1.2.1 Causal Factors Relatively higher levels of radioacove contamination are caused by poor materiel wndition of LaSalle equipment.1his condidon is caused by low standards as to what constitutes an acceptable condidon of piping and components, and a maltonance program which appears unable to achieve leak tight conditions of plant systems.

2.4.1.3 L Lrr..ance indimars and Benchmarkine.

2.4.1.3.1 Causal Factors j

A lack of meaningful management performance indicators and benchmarking at 14alle contributes to management's inabiliry to fully appreciate the extent to which corrective actions must be applied to become a best performing plant. The development of extensive performance indicators to assist in managing these areas was not considered necessary.

2.4.2 Chemistry '

The chemistry laboratory. including the analytical equipment, techniques, quality control and expertise to perform accurate and consistent analysis has demonstrated good performance.

2.4.2.1 Accelerated corrosion of ninine and moninc.ar.L The station has experienced accelerated conosion and other problems amenable to '

chemical treatment. Elements of the chemistry program important to the protection of LaSalle systems and equipment are missing or have not been estabbshed in a timely manner. This has allowed equipment and systems to be damaged through corrosion and caused other undesirable conditions -ich as higher radiation levels.

2.4.2.1.1 Causal Factors .

This failure to establish proper treatment programs in a timely manner was caused by an initial failurt to appreciate that accelerated conosion could occur, and alack of aggressive treatment once this condition was rqued.

2.4.2.2 Technical knowledee of the d.nr.in,1 denart...er.t has not been fully achieved.

2.4.2.2.1 Pin =1 Faetorr Historically, the chemistry department at LaSalle received technical guidaace from the corporate demistry depanment. It was accepted that the transfer of technical knowledge would be through the f.upvis chemistry interface.

m - ,..w,

't 2.4.3 Ememenev Plannine Except as noted below, the areas examined during this assessment in emergency planning at LaSalle appear to be sadsfactory.

2.4.3.1 Doerations Sunoort Center

• J 2.4.3.1.1 Causal Factors '

Emergency plannhg personnel have provided an alternate locadon for the OSC but the alternate i.madon also does not take into account the consequences of a significant relene of airbome radioactivity during an emergency. Emergency planrung persorst are reluctant to identify and equip another alternate OSC location to prepan kr tN contingency of an emergency concunent with a major release because all ot* available shielded filtered locations have some other undesirable attributes.

2.4.3.2 Meteorolonical'!qy2 2.4.3.2.1 Can=1 Factor This reluctance to correct the nonconforming condition of the ten meter meteorological tower insuuments appears to have been caused by a lack of priority, acceptance oflow standards and a lack of aggressiveness in resolving this issue. ,

2.4.4 Fire Protection 2.4.4.1 Materiel Condition of Fire Protection Eouler..er.t

~

2.4.4.1.1 Cmunt Factor Fire protection equipment has a lower priority than station equipment used to pMuce electricalpower.

2.4.4.2 Fire Protection Prorram Human N Terinsrice Defider.cies 2.4.4.2.1 CausalFactors

'the following factors appear to dominate the human performance deficiencies in the fire protection progam.

• 'there have been insuf5cient communications to employees on spec 15c fire protection requirements. *Ihe roles and responsibilities ofindividuals accountable for various aspects of the fire protection program are not well defined and understood.

Inattention to detail.

Carelessness dunng the performance of" hot work."

m~ _ , ,3,

(

o The nation does ra assign a high priority to fire prtuction issues.

I e

The station has low performance standards for the station staff and for station .

equipment 2.4J Eggin There were no strengths or significant problems found during the assessment of stadon sec 6

9 4

e m mm ,2 mygg -

nio nm un,w. n om February 18,1997 United States N; dear Regulatory Cormission Attention: Document Control Desk WasNngton, D.C. 20555

Subject:

Don Nuclear Pcwor Station Units 1 and 2 NRC Dotiet Numbers %295 and %304 in the fall of 1996, I decided to cormission a cuivr at&she assessment of perfomance at LaSalle and Don Stations. I appointed a team comprised of seven independent nudear consuttants, each with more than 20 years of emerience in operations, maintenance, engineering support, and me.W at best foriuTiing nudear plants. During the onsite portion of its nwiew, the team was augmented by appnximately ten INPO and industry peer experts. I asked the team to identfy gaps between our performance and that d the best nudear plants in the United States, and to place particular ermhasis on the fundamental causes that have pnwented achievement of best pei10Tiem. Endosed is the independent AssesT&A Team Report for 3on Station.

) On itwember 19,1996 iTwides of my staff and the IGAT team leader visited your office to review the process used for the atta=trnent. Cher a period d three weeks -

the Team revieMed written peifei we monitoring and assessment documentation and then conducted a two week eonsite irs edisi The Team debriefed site managemert at Zon on November 23,1996. Irifvii Gon from the debnef was made available to you during a visit to the region on Doommber 23,1996 by treiriss of my staff and the ISAT. Zion reviewed the report, riam=wl the results in meetings with the and re a=W our 1997

. Operational Plan to assure the plans are responshe to the insights pn:wided by the ISAT. In addition, Comed has scheduled a p@lic briefing on FebnJary 20,1997 at which the Zon management team will review their responsive adions with the ISAT.

I have personalty reviewed the ISAT Report ard agree with its condusions The Chef Nudeer Operating Omcar, Hany Kaiser, and I have set W+ Mis for the Zion Site Vxa President and c.uidve acbons have already been inibated at Zion Staban. Although the ISAT fnmwi upon furdiTedal causes and did not ruwieu the effechveness of our ongoing improvement irvtiatrves, the ISAT did recogiue that many of the twmsry cs .ctive acbons were already in place as adions in our A Unicom Company 4%Y 9 [, .

l

U. S. Nuclear Rag _M twy Commission February 18,1997 i

1996 Operational Plan. Additional corrective adions to assure that the ISAT.

fundamental causes are addressed have been irir.epermied in our 1997 Operational Plan. Long term sustainable ir@rwoment will be the focus in our future Operational Plans. M. Kaiser has relayed his expedations to the site on the efectrve resolution of these issues and will be peifviinng penode assessments of our progress.

The self-initiated assessment by a respected team d industry prdessionals was painful, we knew it would be, and we accept it. H: wever, we also know that is11ess we measure oursehes by the standards d the best plants, we will never achieve best-indass #wT -rm ourselves. I hope that our willingnees to publicly expose our weaknesses and to refocus our peo just adequate pedeTcsm, is rary -

d asA.ple now. and plans on excellent podei.ws, not it is my mandate to operste Comed's 12 nudear reactors in a safe manner. Wth a focus on operational excellence, coupled with the develop 0=rit d a strong seN-assessing culture, I believe Comed will deiTO n ie sustainable p6,formance irmrovement and achieve best-indass nudear industry pedvi .im.

Sincerely, 9 '

( -

A l Thomas Executive Vice J. Mafy' dent cc- M. A Bill Beach s

S O

...a . --. - . _ - - - _

IS AT - inserensent seirassessment ream o =

An Assessment of Zion Nuclear Power Station An Independent Self Assessment February 18,1997 33c SW :>o pp.

Mr. Harold W. Keiser .

Vice President, Odef Nuclear Operating Officer 1400 Opus One Suite 900 crvnM Company Downers Grove, Dhnois 60515 Dear Hany. -

We are please( to have completed your request for an Mpsicd ====nent of the performance at Zion Stadon. 'Ihe results of our assessment are summarized in the enclosed report, and tespond to your request that we identify the fundamental causes or " whys" that drove declining performance.

We appreciate the spirit of openness cooperation and interest shown by Comed personnel with whom we interacted during the course of the assessment. We acknowledge Comed management for steadfastly maintaining our independence and their commitment to critical self assessment.

The decision to subject Zion Station and the Nuclear Operations Division to an independent self

{

assessment is an aggressive and cred ble step toward your goal of sustaining superior performance.

We believe that the aggressive actions you have begun will address the fundamental causes that our '

assessment identified. We wish you the utmost success in those efforts.

Sincerely,

• Ihe Independent Self Awament Team

• h  %-b dw Warren Fugotod.eader liany % r '\

As - -

fL LY w' Sieber Ad A AL, LA~ ~

fohn Durham l Fred h o f A.

C. W. He'n dris Jr.

--- J

1.0 INTRODUCTION

1.1 Objective ofIndenendent Self Ar-.. ant i

The Independent Self Assessment Team OSAT) was assembled at the request of the Chief Nuclear Officer of the Comed Nuclear Operations Division (NOD). The Independent Self Assessment OSA) was led by a core group of seven senior nucles consultants external to the Comed organization, who were requested to conduct an independent assessment of performance . -

at Zion Station (Zim). The a:sessment was intended to provide Comed management with an independent perspective on major performance weaknesses, with particular emphasis on the fundamental causes of those weaknesses The ISAT was also invited to provide insights concerning the effectiveness of ongoing and planned emFA initiadves to improve identified performance issues and to recommend post assessment steps.

1.2 Methodolon and Standards for A-- =. ant The IS AT assessed performance at Zion over the past two years in five functional areas:

Operations and Training, Maintenance, Engineering and Technical Support, Plant Support, and Management and Organization. The ISAT's assessment process consisted of thme phases.

l In Phase 1, over a three wxk period, the cost team performed a detailed review of existing performance monitoring and assessment documentation. *!hese documents included, but were not limited to, NRC inspections, evaluations, and Comed assessments, corrective action documents and performance improvement plans. Essentially all of the weaknesses described in this IS A report wert identified in these documents, in Phase 2, over a two week period, the ISAT verified the Phase 1.identi5ed weaknesses based upon Zion observadons, interviews and further document reviews. *fhe cort team members were augmented by INPO and industry peers in connection with the Phase 2 wort in Phase 3. over a two week period, utilizing the results of Phases I and 2, associated causal factors for Zion weaknesses la four functional areas (operadon, maintenance, engineering and plant support) were documented by the core team (Artehm*N A). A set of fundansental causes were then developed for the assessment of management and organization.

As the assessment prneaeded the ISATdetermined that it would deliver maximum value by concentrating on the performance wa21m*~s and the underlying causes. The ISAT's emphasis was placed on problem definition and idendfication of fundamental causes, rather than corrective actions. Crmyntly, the ISAT did not focus upon the effectiveness of ongomg and plamed improvement inidatives.' The ISAT acknowledges that many corrective actions wert in the ,

process of being developed, and some were alttady imp ==x-1 to address Zion w@"as.

The ISAT did not conduct detalled me"ments of the performance of the overf 3t and assessment functions within the enmFA meacar organization, nor did it assess the performance of the regulatory assurance functions at Zion. In the contem ofits integrated review of Management and Organization, the ISAT examined the end results and effects e of the nmFd oversight and assessment functions. Those end results and effects are described in the Fundamental Cause Assessment in Section 3 of this report.

I Mk t

'!he IS AT's standard for assessment of perform;ue reDected its collective experience and was intended to represent the performance of a best. performing plant. Unless otherwise specifically stated, this standard applied to all phases of the ISAT assessment. h ISAT focused on the end

, results of NOD decisions. 'Me 15AT did not anempt to define the specific actions that Comed

(

management should take .o assure safety, regulatory compliance or best-performance.

'The ISAT did not rec valuate Comed's historical decision making processes or the conditions under which decisions were made. '!he ISAT placed emphasis on communication of observations and causal factors to assist er nrA in understanding and accelerating its effons to resolve the issues which are critical to achievement of sustained excellent performance at Zion.

IJ Assessment Team Msra,m alo and Comoositior}

The core members of the ISAT and their respeedve assessment responsibilities and backgiounds are:

t Member Accemnent Remonsibility Background Wanen Fujimoto Team Leaderand Management Former Vice President and Organization Pacific Gas & Electric Co.

Diahlo Canyon 28 years nuclear powerexperience Harry Kister Management and Organization Former USNRC, Region I,III and Headquaners I&E 36 years nuclear powerexperience John Durham, P.E. Engineering and Technical FormerEngineering Manager Suppen Impell Corp.; Carolina Power &

Light 23 years nuclear power experience Dr, Benjamin Dow Engineering and Technical Former Manager Nuclear Services, Suppon Arkansas Power & Light 23 years nuclear powerexperience C.W. Hendrix, Jr. Maintenance Duke Engineering Services, ManagerofMaintenance Engireering Services .

25 years nuclear power experience Fred Dacimo Operations Former Operations Vice President.

Northeast Utilities 20 years nuclear powerexperience John Sieber Plant Suppon Former Senior Vice President and Chief Nuclear Officar, Duquesne Ught Cotipany 36 years nuclear power experience mon 4WesemNassaaho %.2

_-__ Y

' i The cort IS AT members were augmented by INPO evaluators and industry peers, as fotows: i Aurmented Team Persnnnel Atweement Reennricihllity - Ornniwional Affilintion

!  ! Thibault Management & Organization INPO

-Vince Roppel- Maintenance INPO Mike Bauard Engmeeting INPO George Northeun Operations INPO Jcse Riner Management & Organiza6on INPO Jim Vandergrift Matruenance Entergy ANO Bob AzzartUo Engineering Ernergy Waterford i John Hesser Engineenns APS Palo Verde 1

Joe Wald Operatiora Entergy . ANO Bob Gillespic Operations. D.C. Cook 4

' '!he ISAT received support from Jim Abel, JoEUen Burns and Bill Fitzpatrick of Comed who served as liaisons to the line organizadon and were instrumental it. gaining prompt acmss to j informadan, documents and individuals.

2.0 FUNCTIONAL AREA CAUSAL FACTORE -

the ISAT's supporting observations and causal factors for operadons, maintenance, engineering and

plant support are summanzed below.

4 2.1 Onerations and Trainina 71.e ISAT found that models for and de5nitions of conserv: live operadons decision making we i

' not in place and nonconservadve decisions wm observed. Management accepted low standards, manifested in tolerance of de5cient condidons and a lack of operadonal excellence toward improving performance. Training was not used to deliver and stinforce expectations, 1

communicate standards of performance, or prepart opemtors for organizational change.

Operadons management has not maintamed an active ownersh'p of tralrung. Operations did not have an understandmg of and a cammitment to the principle that strong economic performance

must be driven oy operadonal exceUence. '!he ISATobservr, standing reluctance to c.*>nfront substandard human

• performance. Pnvious caragement has indire4 tly promoted a culture cf inaction on human performance issues.

1here has been a lack of feedback and coaching by supervision on human performance issues. This is a result oflack of supervisory skills, lack of management support for tough decisions that address human performarce and a low understandmg of the impact of positive feedback on human performance.

2.1J Onerational Emilence lhe attributes utilized for assessment of operadonal excellence are the fouowing:

• Good procedure quality

• Strong procedurs) adherence

• Sound communication techniques Scudulfeccking pmgrams Posidve operator bearing with a questioning atdrude Conservative decision making Good use and acceptance of supervisory oversight l *

• Technical competence and anention to detail i

l Dunns the IS AT visit to Zion. numerous signs and posters were observed which addressed being " committed to world class performance" of which operational excellence is an integral part. This was considered a visible sign of management's commitment to excellence and a cmtinualremirderto employeesof management's phuosophy.

When individuals in operadens were observed it became apparent that few individuals did a reasonable job of demonstrating any of the aforementioned eight attributes of operadonal excellence. From conversadons with operators it was apparent that there was Unle recognition as to how an individual could contribute to improving performance of Zion operations.

2.1.5.1

• Causal Factors 1ruilviduals did not remgnin that a fundamental commitment to operational excellence and nuclear safety results in long. term economic performance. These individuals did not understand that the best performing plants wert invariably th:

most cost competidve, l.ittle recognidon existed of the INPO study regarding this subject.

• Operations management does not communicate consistent expectations as to what constitutes excellence.

Zion has had an tradatM culture. Individuals do not reallre that the nuclear industry has significandy changed. More importandy, in certain instuces they do not realize how much they must change just to catch up with acceptable industry practices. Mediocrity appears to have been acceptable at Zion, indicating a lack of understanding of operaticrial excellence.

" w a= M *#s1 4

2.1.6 Can Between Manamement and the Bareminine Unit As previously identified. the IS AT also determined that bargaining urdt and management

, reladons require additional anention. It amears to the IS AT that management and bargaining unit personnel do not urxlernand that the success of Lon requires interdependence of action; one group cannot succeed without the other. A phuosophy of"we are au in tNs together" cbes not etist.

The gap tetween management and the bargaining unit is a significant issue confronting Zion.

The ISAT is not aware of a nuclear staden that has acNeved Ngh levels of performance without a fully engaged workforce. At Zion, management has pointed to the bargatring urdt as the source of dechning performance whue the targaining unit has pointed to management Both sides have not taken respansibibty to resolve their differences.

2.1.6.1 Causal Factors There is a percepdan of a Ndden agenda on the part of management and on the part of the bargaining urdt. Fuu disclosure of the " whys"of sedans taken by both management and the bargaining unit does not always appear to exist.

A class synem is perceived. AU decislans appear to the workers as being made on i

the " sixth floor" by senior management.

A high degree of mistrun exists. The bargaining unit does not trust or beueve management, and management does not trust the medve., of the bargaining urut.

Poor commurdcadons exist. Issues are not completely shared expectations are not continuously reinforced and dialogue is not fostered.

2.1.7, , Bareminine Unit Pathway in Manamement A number of Nuclear Stadon Operators (NSOs) are at the upper limit of their bargaining unit career path. Most Ucensed shift supervisors (LSS) are instant serdor reactor operators (SRO) while many of the NSOs have had many years of experience in Zion operadons. 'Dds difference in experience has created an "us versus thr.m" situadon and also ampufies the difference between a supervisory posidon and an operator posidan.

2.1.7.1 Causal Factors The bargalrdng unit views the urdon as a proceedve umbrella; a promotion is viewed as aloss of this protecdon.

Inconstment standards result in confrontatioris between the NSOs and Control Ro Supervisors (CRSs). This widens the gap between the bargalrdng unit and management wNch in tum reduces the interest and modvation in being promoted to management.

The bargaining unit perceives the exining operadons standards as unclear in censin areas and unnecessary in others. If promoted into management, they would be respansible for enforcing standanis that have been poorly received.

monahtesam*sseh:2AacPg.10

- _ _ _ _ _ _ ~

o 'the adversadal relaticmship between the baryalning unit and management

~

contributes to the reluctance to pursue advancement.

2.2 MAINTENANCE Dudng the assessment of the malraenance funcslon, four lasves were raised which lepact Zion's ability to idendfy, pr.oritize, plan, schedule and execute work. 'They ism have resuhed in large work backlogs, poor m Ateriel condidon, and low system and sgupment availability and reliability. 'These issdes involve substandard priormance in the following areas:

• Work cetrolprocess

• Preversive malisenance program .

• Mainterance depanment managanent

• Change management

'These major lasues, along with significant subtier issues, are *med in detall below.

l 2.2.1 Work Control Prorwee

• The work control process at Zjon has not supported Identification, prioritizt.tlon, planning and execudon of work. 'This resuhed in significant work backlogs and hindered stadon responses to issues important to safety and produedon. There is a work request backlog of more than 2200 items and as much as fifty percent of the work on the schedule is emergent work which has not been effeedvely planned. /The problems in the work concol area may be masking other concerns such as worker sk!!) and produedvity. ,

2.2.1.1 Causal Factors

'!he primary cause for work control system deficiency issues is a lack of an effeedve change management methodology for implementadon of significant changes in Zion

, processes and proceduns. Changes to the work management system and the

' creadon of the Pit It Now (FIN) team were implemented without a fully integrated change plan. 'The impact on implementing organizations (maintenance, operadons and scheduling) and their roles in the change process were not completely considered.

Management support during implementation was weak. 'the aluion for the FIN -

team was not clearly defined and communicated. '!he process owner, who initiated the change for the work connel system, was moved two months after implementadon began. A new process owner was not assigned until five months later. This change management approach ha resulted in a lack of ownership of the work control system by Zion perunnel and misdirection of the FIN team. Persconel have no faith in these processes and consequendy do not support those activities that would make tem funcdon propedy.

==Aw==w.w.we .s I t

2.2.2 Preventive Malntenance (PM) Prorram De PM program is rvat tving properly implemented. Dert are numerous FM tasks past their due date. In addition, tiert are over 100 PMs past their critical date. This has teen a long*

mandmg problem and has teen previously identified. A NOD program to standardize and areamline the PM programs at all Comed nations is tving implemented at Zion. At present.

protnems with work plarming, scheduhng and extuition are nullifying the impact of these improvement etions.

2.2.2.1 rwamt Factors Management has not prvvided the leadership and clear communicadon of expectadons regr%d to ensure that an effective PM program hAs been developed l and impicmented.

The PM program is given a lower pnority than issues related to productien. PM tasks have been routinely delayed due to resource unavailabillry or grid condidons.

Management has not viewed the PM program as a key factor in maintaining Zion rsliabilfry and availability.

2.2.3 Maintenance Decartment Manneement The overall management of the maintenanc,. department has not met high sumdards in a numter of areas. Mairnenance management has not clearly and consimently communicated expectadons and standards.

Holdmg first line supervisors and workers accournable for meeting challenging nandards has not been a pan of Zion's culaart. Supervisors art not in the field to the extent required to ensure that main'enance work meets accepted mandards. De training program for supervisors and workers is wealr.

his has resulted in maintenance department performance that is below industry standards.

Significant work backlogs exist. Rework, when measured, has been significant. The PM program is not being implemented, equipment reliability is low and phnt materiel condition is poor. Overall, worker skills appear to be weak.

2.2.3.1 CausalFactors Wert has not been a maintenance depanment practice of holding workers perscrully accountable for identification and resolution of problems.

Maintenance management has tolerated now standards. As a result, those acdvities which catablish performance at or above industry standards and long term improvement art not supponed. Dese irr.hde: developing and implementing challenging capectadons: tracking expectation implementadon with the appropriate performance indicators; holding supervisors and workers accountable; developing and implementing effecdye training programs; and challenging those corponue, station and department policies that hinder achieving top performance in maintenance.

m w wen s

o Malmenan:e management and bargairdng unit leadership have not rec:grdzed that in on$er to succeed they must work as a tearn to address long stardng issues.

l 2.2.4 Chance Manneement 1he inability to create and implement effective change management plans has impacted maintenance department performance. The implemergadon of the Electronic Work Control System (EWCS) and twelve week schedule offer clear examples, There are numerous examples of process, procedure and methodology changes undertaken without considering the impact on other departments and processes. Action plans are not always documented and,if they art, implementadon is typically not tracked Firm 11ne supervisors and workers are not engaged in or held accountable for making the changes required to achieve top performance.

2.2.4.1 CausalFactors The changes required to improve maintenance department performance at Zion involve problems with long stardng, fundamernal policies, processes and procedures. They involve addressing bargaltung unit and management relations. A key element that ha: been missing in previous change plans is the selection, tndrdng, empowerment and suppon of first line rupervisors as the principal implementors of required changes.1his has been a significant barrier to implementing change, l

• Maintenance management has set standards of performance that are below those typically set by industry. There has been no accountability for changing these standards. As a result, there is no driving for::e for resolving the difficult challenges associated with implementing the changes needed to achieve best performance in the maintenance department.

l l

2.3 ENGINEERING AND TECHNICAL StrPPORT The engineering orgardzation was amessed to determine its performance as the design and technical conscience of Zion, The ability of the engineering organization to provide high quality and responsive engine 6 ring and technical support to other stadon orgardzadons was also assessed 1he ISAT determined that the performance of Zion's engineering is significantly below that of best performing plants. Engineering has primar0y focused on resolving short term emerg '

issues. Engineering has not effectively addressed long manding equipment issues, nece programs and issource issues needed to establish and sustain good performance. This has been demonstrated by repeated equipment failures, inadequate design and licensing basis documentation, incitasing backlogs and inadequate safety evaluadans. The following artes found to be inneed ofimprovement:

• Work management Engineering work quality System engineering function Long starvitng equipment ard materiel condition Design basis and con 5guradon management

==&wa==*=ad=2 wes13

, DeSciencies in these areas have been identified in the past, wre confinned in tNs assessment and have existed for several years. The reasons for these deficiencies are discussed below.

Past leadership of the engineering organization has not beer: effective in establishing, commurdcating, and enforcing Ngh sandards of performance. l.ow standards of performance have been tolerated, and less than adequate work products have been accepted. Corporate and Lon engineering management have not provided the direction, focus and coaching needed for the maff to be successful. Contributing to this has been the large turnover of supervisors and smup leads within the engmeeting organization.

Lon engineering is a reasonaNy young organization. Prior to 1993, the majority of design engineering was performed by arcNiect engineers. The Lon engineering organization was developed without a weU<iefined implementation plan.

Engineering has generaUy supponed day to day operadons but has failed to plan for and manage

' its long. term responslN1 ides. Resource constraints in engineering were not effectively communicated to other stadon groups and support of other depanments for wuk priorldzadon l

was not obtained. A lack of engineering teamwork was noted during the evaluation. Engineering teamwork with the station for work prioritization was lacking. Strong teamwork was not exNbited during engineer!ng meetings or in meedngs with other stidon departments.

Performance goals and measurement indicators have not been established and consistendy implemented to improve engineering performance. Corporate and Don management have not committed the appropriate resources to acNeve engineering exceDence. Engineering has not been a self crideal teaming orgardzadon. It has rxx implemented conecdve ac6ons known to be important. An environment exists where individuals do rvat bring errors or problems forward for '

the purpose of improving performance. FinaDy, Don engineering has not postured itself to be the technical conscience of the station wNeh is needed to acNeve and sustain exceDence in operadons.

The perfonnance of engineering in each area noted above is AumeW below:

2.3.1 Work Mannr..r.:

'!here has been inadequate identification and control of englneering work activities, There has

also been ineffective screening and prioritizadon c(requested engineering work by operadons, maintenance and engineering Priorities frequently change and engineering is not always working high priority items with the proper individuals to support Zion's'needs. The lack of effective .

work management inhlNts engineering fmm being proacsive and having the abliity to self identify and conecs problems in a timely fashion.

1.3.1.1 Causal Factors Engineering lacks an effective wM control sysem to manage its workload.

1here is clearly too much wont to do with the resources available. Resource constraints in engineering have not been effectively communicated to other site groups.

Engineering management has not been an efrecdvc champion for engmeeting issues and " driven home" the need to address important engineering work in a timely and complete fasNon.

men &hhnauNassaha2,emefg. I4

• 2.3.2 - Enmineerine Work Dualltv Past engineering evaluadons and safety evaluadons have often been inadequate. In some inmances the design basis was not well understood.

2.3.2.1 Egliallastata The impanance and significance of anfety evaluadons and assessmwis have not been fully appreciated by the engineering staff.

na anfety culare within ensinowing is weak. The engineering saff has ta recognized the need to make changes to improve the safety culture. -

Design and Ikansing basis infonnadan has not always been maintained up to date.

e

' in some cases, the technical knowledge of the engineering saffis deficient. Past training has not been sufficient to improve performance.

2J.3 Evatem Enmineerine A promedve system engineering funcdon is not being implemented. Symem engineers m mainly reacting to dauy requests for suppon and m frustrated by constantly changing priorides.

2J.3.1 CausalFactors System engineers have not been able to fulfill their roles and responsibuides.

System engineers m often engaged in nonsystem en61neering activides such as project management, wcut package preparadon and routine pom maintenance

.- testing. There is a lack of task prioridaation and system engineers are mainly c .reacdngbdat<urm crises.'

I Trs.ning has not been effeedvely used to improve symem engineering performance.

Sysse engineers have s.x been required to determine symem design, operational 4

and testing requirements and assure these requirements a met.

2.3.4 1mne Standine F= Inni==* ==d M:^ -. L' Fe+'ta is 1he identification and resolution of kms standing equipment ph have not always been rigorously pursued by engineering. A number oflong4:anding and recurring equipment problems have not been moolved.

2.3.4.1 CausalFactors Mn r. has not peovided sufficient resources or minforced the timely resolutiot, of many equipment problems. The cause of equipment problems is not always determined unless there is an immediate impact on Zion operadon.

Proper root cause analysis has not always been utilized.

Conecsive actkm programs to address equipment problems have been developed and planned but notimplemented.

n a= ~: ns

)

. 2.3.5 Dealen Ratl< and Confieuration Manneement Lack of design tusis information and configuration management contml have been idendfied on a number of occasions. Discrepancies between the Updated Final Safety Analysis Review (UFS AR). Technical Specifications, plant drawings, and as built condidons have been identified.

2.3.5.1 Causal Factors

• Zicri design and licensing bases documentadon has not been completely defined, has not been updated and is svat casuy accessible. Existing Design Basis Documents (DBDs) do not contain sufficiert informadon and are not maintained 1

current.

• Budget constmints have affected the completeness of design informadon documents.

• ZJan engireering has not postured itself to be the design authority and technical conscience of the stadon. Engineering management has not effectively i championed configuration management issues and " driven home" the need to address these issues in a timely and complete fashlort i 2.4 PLANT SUPPORT Plant support consists of radiadon protecdon, chemistry, fitt protecdon, security and emergency planning. At Zion, plant materiel condadon and housekeeping present challenges to the quality of the radiation protecdon program and the fire protection program. The radiadon protection program is alsoimpacted by the practices of plant workers doing wort within the radiologically posted area (RPA). All plant suppon functions are adversely impacted by the failurt of management to prioritize and allocate the resour;es necessary to maintain Idgh performance in the plant suppon areas. Notwithstanding these adverse factors, the plant support functions have beenimplemented Wr'aly.

• 2.4.1 Radiation Protaction -

2.4.1.1 _ Worker. Radiation Fmosure 1

2.4.1.1.1 Causal Factors -

• The radiation source term in the plant is higher than the industry median. Over sixty five " hot spots" exist in the plant. Additional effort is needed to reduce cr ehminate these hot spots. A prime example of major hot spots in contunment is the itsistance temperature detector (RTD) manifolds in each reactor coolant loop.

Most utilities removed the RTD manifolds some years ago.

The cobalt reduction program, whDe inidally maldng progress, has slowed recently to the point that little progress is being made.

• Early boration, commonly used during major shutdowns at pressurized water reacsors that have been effective in reducing the source term, have only recendy been adopted at Zion.

= = w m 24me .is s

, o Radiation worker praesices contribute to Ngher radiadon eorker dose.

Observadons and reconis of worker praedces include: workers awaiting work

!!ngering in mas other than the low dose area. a worker not fouowing the radiation work permit (RWP) and wort instructions, resuldng in a significant uptake of airbome radioactivity; and numerous examples of poor hcnisekeeping pracdces. On the positive side, a tralrdng program called " enhanced N GET' was developed which has been successful in significandy reducing personal contaminad(en events (PG). However, cannent plans are to discontinue the program.

Conduct of maintenance contributes to the Ngher worker exposure at ilon.

Analysis of ALARA exposure records indicates that espergent work is a major contributor to the failure to achieve A1. ARA goals. While it is expecsad that unplanned emergent work will add dose to tctal worker exposure, the degree of emergent work undermines the dose goal setting pnxess, thus reducing the effectivenes of the ALARA process. In addition this places added burden on the i

radiation protection deparanent to huniedly prepare an ALARA analysis that l might not be as effective as an analysis that was prepared in ample time befort the l actual performance of the job. Funher, repeat work and rework unnecessarily add j to worker exposure.

Pull management suppon for the ALARA Program has not existed and ownership of dose by depanments ard sections is not consiment. For example, the chairman and several key members of the ALARA review commluee failed to show up for a scheduled rmmittee meedng. In response, the new site vice president appointed Nmself the new chairman. He rescheduled the meedng for laser in the day and required the attendance of senior Zion management.

L 2.4.1.2 Contaminated Plant Area 2.4.1.2.1 Causal Factors '

'the app n:nt cause of the large number of ccetaminated areas is the materiel condition of plant equipment.1.4aks and drips imm piping and cornponents cause widespread contaminadcm. Accumulation ofleakage p.wfucts and chemical deposits have caused the contaminadon levels of these areas to become Ngher, Contmoed neglect of the buildup of contamination in the RPA will condne to cause inetScient operatian and maltsanance of Zion. -

Poor housekeeping in some areas (l. e.. :.nd C clothing, mop heads, ladders, loose plastic, a detached catch basin, nome buckets, SS gallon drums and caustic were scanered on the floor) exacerbates the -%adon issue.

2.4.1.3 Radiation Worker Prqkgg 1.4.1.3.1 Causal Factors Poor radiation worker practices are due in part to a low level of mentoring and coaching by supervision of their wakers in the field. Many workers report that their supervision is seldom seen at the job site.

n w w.uno.we.t7 s

o Workers sekkan write MPs on the activities cf other workers, so the oppommities Oleam the estant of radiation worker problems and to develop specific remedies to conect those problems are alssing, 2.4.1.4 Performance Indicators and Benchmarking 2.4.1.4.1 Quest Fmints -

A lack of meaningful management performance irdicators and benchmarking at Zion contributes to management's inability to fully apprectale the esters to which conective aculons must be applied to become a best. performing plant. Therefore, development of extensive performance indicators to help to manage these areas was not consideredimponant.

i 2.4.2 EbglIngE2 1he analytical equipment, techniques, quality ccentrol and expertise to perform accurate and consistent analysis has been demonstrated by the csismistrj staff. The bases for chemical treatment programs at ZJon have been consistent with industry practice.

I 2.4.3 Emergenev Mannine i

Except as noted below, the performance of emergency planning at the station is satisfactory.

2.4J.1 Onerations Sunor.iggggggt 2.4J.1.1 Causal Factors 1he location of the OSC is not shielded nor does it have a filtered breathing air supply and would thetsfore not be habitable during a significant release from the plant. It Nd be a best piactics to change the locatice of the OSC to a shielded, Sheredlocadon.

2.4.4 Mrs Protection 2.4.4.1 - hense t'--'%n of Mrw h :=lan Fmlarr.t 2.4.4.1.1 Caumi Factors Cognhant personnel indicase that the reason for thr, large number of outstanding work orders is the now priority given to saltaananca of fht protectial equipment.

{

2.4.4.2 Mre Protection Emulament 2.4.4.2.1 Eauallaagt2 1he root causes of the high rate of emergency lighting failures was determined to be:

A failure to rw.inue that the failure rate was excessive.

No root cause analysis was perfonned Inadequale surveillance procedure.

, q i,

PRE-DECIS!0NAL INFORMATION SEMIANNUAL PLANT PERFORMANCE ASSESSMENT BRAIDWOOD Assessment Period: November 1996 to March 1997

$ ALP Period: October 1, 1995 through August 30, 1997 Previous SALP Ratings: OPERATIONS 2 MAINTENANCE 2 ENGINEERING 2 PLANT SUPPORT 1

1. Performance Overview Overall, activities at Braidwood continued to be conducted in a safe manner.

During this assessment period, improvements were noted in following procedures by the non-licensed operators (a weakness in the previous seriod) however, weaknesses were noted in licensed operator performance. T1e most significant issue identified was the inadvertent opening of the Unit 1 p essurizer PORV during a cooldown. Procedure adherence problems were noted in maintenance and weaknesses were noted with un-timely corrective actions in engineering and maintenance. System engineering was effective in problem identification.

Additional problems were noted in engineering activitics related to post maintenance testing and understanding of regulatory requirements. Plant support activities were effective and the licensee was effective in identifying problems in fire protection.

D9 ting this period, Units 1 and 2 were o>erated at or near full power with the exception of a Unit 1 shutdown from Octo)er 12, to December 3, 1996, for steam generator tube examinations.

11. Functional Area Assessments A. Operations

1. Current Performance Overall, operations were conducted in a safe manner. In the previous period there were several examples of non-licensed operators failing to follow procedure, in this period there was only one example identified by the inspectors where a non-license operator did not follow a procedure. However, there were still weaknesses identified with the use of procedures.

2. Assessment / Issues Overall, operations were conducted in a safe manner.

The inspectors observed several plant evolutions including: changing reactor coolant filters, clearing out-of-service tags, operator rounds, I

and a startup from a maintenance outage and concluded the evolutions were conducted in a safe, well controlled manner. (11/30/96 to 1/10/97)

• The inspectors observed several shift turnovers and heightened level of l awareness meetings and concluded that the meetings were well conducted and that the licensee was in compliance with the appropriate station -

i procedures. (1/11/97 to 2/21/97)

Weaknesses in operator use of procedures.

+

The Unit 1 pressurizer PORY lifted inadvertently due to failure to have a procedure for bypassing the charging flow control valve. (10/12/96)

The^ inspectors identified that during a turbine valve exercise, control room operators demonstrated poor performance ini reactivity control and management, annunciator alarm procedure adherence, and team work between the NSO, the Unit Supervisor, and the Shift Engineer. (11/18/96)

• The inspectors identified that operators added lube oil-to the 2B emergency diesel generator without the use of a procedure and did not-know a procedure existed. (12/19/96)

3. Actions / Recommendations Continue with the core inspections with emphasis on procedure adequacy and adherence.

B. Maintenance

1. Current Performance Maintenance activities overall were conducted in a manner supporting safe plant operation. However, a trend was evident in poor procedure adherence.

Several weaknesses were identified in corrective actions.

2. Assessment / Issues Overall maintenance activities were conducted in a manner supporting safe plant operation.

The inspectors observed that surveillances performed were conducted in a competent and well controlled manner. (2/21/97, 1/10/97, and 11/29/96)

The inspectors observed the performance of low voltage closure testing and lubrication of a 480 volt DS series breaker. The inspectors concluded that the maintenance was performed in accordance with the procedure and was closely supervised. (11/96)

The inspectors observed portions of maintenance on the 1A safety 1 injection system during a scheduled maintenance outage. The inspectors 2

1

=_

concluded that the maintenance performed was conducted in a well organized manner in accordance with prescribed maintenance procedures.

(1/11/97to2/21/97)

A trend was evident in poor procedure adherence.

The inspectors observed that mechanical maintenance workers failed to follow a procedure while installing manways and diaphragm plate in the IC steam generator. (11/18/96)

The licensee identified that cpent fuel assemblies were mispositioned in the spent fuel pool. The inspectors identified that fuel handlers did not follow the procedure.that required triple verification on fuel moves. (12/1/96)

The inspectors observed that no quality assurance tag was attached to safety-related replacement HEPA filters installed in the auxiliary building ventilation inaccessible plenum as required by ;rocedure.

(12/5/96)

The inspectors identified that a work package was not present at the work site for the 1C heater drain pump and the procedure was not followed. Also, the foreman could not explain the purpose of the procedure steps. (1/2/97)

Significant weaknesses were noted in corrective actions.

The inspectors identified several examples where equipment carts were found secured to safety-related equi > ment. In one case the licensee failed to correct the problem 1 monti after it was identified by the inspectors. (12/9/96)

The inspectors identified unacceptable amounts of loose debris on the auxiliary and fuel handling building roofs. Loose debris on roof tops had resulted in a loss of offsite power to Unit 2 in January 1996. The licensee narrowly focused on the initial inspector finding and failed to look at an adjacent roof until the inspectors identified additional loose material. (2/19 and 2/97)

3. Actions / Recommendations ,

Continue with the core inspection program with emphasis on procedure adherence and corrective actions.

3 J

C. ENGINEERING I

i 1. Current Performance The tem)orary alterations and post modification testing (PMT) program have not always seen effective. In the last 2 years, there have been 8 other examples .

of inadequate PMT. There were three exam >1es where the licensee did not demonstrate a complete understanding of tae regulatory requirements. However, there was a demonstrated questioning attitude exhibited by system engineering as evident by the identification of problems.

2. Assessment / Issues The following weaknesses were identified in temporary alterations and post modification testing activities:

The post modification test (PMT) was inadequate to determine that control relay contacts for the ESF Switchgear Room were configured incorrectly. The inspectors identified that the licensee performed the testing without an approved procedure. There have been several examples of inadequate PMT over the last two years. (10/3/96)

Twenty two examples including numerous fire doors, of failure to perform PMT were identif'.ed in 1994 and were reidentified in 1996 without appropriate corrective action. (10/18/96)

The high number (14) of temporary alterations installed for greater than 18 months. (10/96)

The following were three examples where the licensee did not demonstrate a complete understanding of the regulatory requirements:

A lack of complete understanding of the 10 CFR 50.59 and GL 91-18 requirements when returning the unit to service with the Unit i cold leg reactor coolant stop valve degraded without documenting a 10 CFR 50.59 safety evaluation or by an operability evaluation. (9/6/96)

Poor engineering practice was evident when an acceptance criteria change made to a RHR pump surveil 16nce procedure was not incorporated at the same time into all other prtacedures that were affected by the change.

(10/18/96)

Understanding of the ASME code, and the applicable generic letter guidance, was poor. When a through wall flaw was identified in the 1A essential service water system the train was not removed from serm.a nor were any corrective actions taken or relief for taking no actions sought from the NRC. (12/23/96)

There have been examples where system engineering used a questioning attitude to identify several problems, f 4 c

• The licensee's efforts to evaluate steam generator tube integrity by assessing growth rates for this type of cracks by historical eddy current data reviews / comparisons and in-situ pressure testing was indicative of an aggressive program. (10/25/96)

• A system engineer's questioning attitude identified an inconsistency ,

between the control and instrumentation drawing and external wiring diagram for two control room dampers during a review of disconnected power leads. (11/11/96)

• A systein engineer demonstrated a knowledge of expected system performance and a questioning attitude to detect electronic noise effecting vibration readings on a diesel oil transfer pump since the vibration measurements initially obtained met the acceptance criteria.

(11/14/96)

3. Actions / Recommendations Continue with the routine core inspections for the Engineering area focusing

, on engineering programs (e.g. operability evaluations, testing activities, and i design basis validation). The last E&TS inspection was in the fall of 1995.

Another E&TS inspection is recommended before the end of the SALP period (August 97).

I No deviations occurred from the previously planned inspection activities.

l D. PLART SUPPORT

l. Current Performance Performance in radiation protection (RP), chemistry, and emergency preparedness (EP ALARA planning, pre-job ALARA briefings, and RP job coverage were) was good. effective in minimizing dose; however, some weaknesses in radiological postings and control of contamination boundaries were evident.

Primary and secondary water chemistry control programs were effectively implemented and reviewed. Problems in laboratory quality control (QC) indicated that oversight of that program was not as effective. The 1996 EP exercise evaluation identified personnel performance to be very good. The fire protection program was adequately implemented. The licensee identified significant fire protection issues and was taking appropriate corrective actions for those issues.

2. Assessment / Issues Radiation Protection The licensee's ALARA planning and pre-job briefings were effective in minimizing dose to workers. Radiation protection technician (RPT) job oversight was excellent.

5

The inspectors observed good ALARA practices in decontaminating the spent fuel transfer canal. The two RPTs were remotely monitored and in continuous communications. Good use of engineering controls and respiratory protection was observed. (1/97)

The RP staff provided effective support for work involving the 1A safety .

injection cubical cooler essential service water outlet valve. The RPis 1

identified and discussed potential, radiological hazards and monitored i the evolution. (1/97) l kPis ensured that personnel were properly briefed and continuously monitored during tle replacement of a reactor coolant filter. (12/96)

Access to plant areas was well maintained and relatively unencumbered.  ;

However, some radiological postings and contamination boundaries were not well l controlled. i The licensee implemented zone RP coverage which improved the coverage in the Auxiliary Building. RPTs were assigned to specified areas and were responsible for activities and coverage of work in those areas. (2/97)

Inspectors identified weaknesser, in the licensee's control of hoses crossing contaminated area boundaries. On two separate occasions, the same unsecured hose was crossing the contamination boundary, potentially spreading contamination. (1/97)

Inspectors identified that the Unit 1 Moderating Heat Exchanger Room was not posted as a radiation area even though radiation levels exceeded 5 mrem /hr. (1/97)

Some examples were identified demonstrating that instrument calibration and setpoints were not well controlled.

Inspectors found a personnel frisker in the plant which was not within the labeled calibration due date. (2/97)

The licensee identified that the alarm setpoints for the fuel handling incident radiation monitors were not in accordance with the technical specifications (i.e. 10 mrem /hr). The as found setpoints were 100 mrem /hr (alert) and 2000 arem/hr (high alarm). (12/96) chemistry Primary and secondary systems water chemistry program was a strength.

Effective control of chemical intrusions and secondary system additives reduced the potential for system corrosion and decreased radiological source term.

During 1996, the concentrations of chloride and fluoride in the primary systems were well maintained. (2/97) 6

The licensee continued to use all-volatile treatments (AVT) chemistry in the secondary system. Since March 1996, favorable results have resulted in reduced oxygen concentrations, iron transport and concentration, and pH control. (2/97)

The licensee experienced some circulating water intrusions in July 1996 (Unit 1) and February 1996 i term increases in the concen(Unit 2),of trations which corresponded sodium to minor, and chloride short in the steam generators. However, the licensee mitigated the effects in a timely manner. (2/97)

Chemistry technician (CT) performance and the quality of chemistry training were strengths.

During routints primary system sampling, cts demonstrated good analytical l techniques and knowledge of procedure recuirements and references. The l CT was also knowledgeable of the expectec concentrations found in the l coolant and the licensee's limits for a variety of specific analyses.

(2/97)

Inspectors observed that the chemistry PASS training was very interactive and the discussions were thorough. (2/97) l Although laboratory quality control (QC) was acceptable, NRC identified problems indicated some weaknesses in program oversight.

The inspectors identified two aluminum (A1) standards which were improperly labeled with respect to the procedure required shelf-life.

(2/97)

Inspectors identified statistical biases in fourth quarter 1996 and first quarter 1997 laboratory QC data which were not resolved in a tirrely manner. Biases may indicate minor problems concerning the instrument calibration, the calibration standard, or an instrument problem. (2/97)

Weaknesses in the interlabor4 tory program were identified by inspectors.

Aaalytical results were not compared and reported in a timely manner.

In addition, the licensee did not always resolve analysis results which were not in agreement with program acceptance criteria. (2/97)

Inspectors identified that some QC procedures and PASS surveillance procedures were inadequate in that they did not contain acceptance criteria te tetemine the acceptability of surveillance results and the validity of counting room calibrations. (2/97)

Inspectors observed cts verifying QC performance tests for laboratory instruments with an uncontrolled aid containing acceptance criteria.

The chemistry supervisors did not perform a periodic review to ensure that the aid was consistent with the data base as required in BwAP 550-

25. (2/97) 7

The licensee corrected some previously identified problems concerning PASS procedures and maintenance, but remaining problems required additional attention.

• The inspectors identified some unresv i PASS maintenance items. A -

long standing problem remained uncr ..ed since June 1,95 (greater than ,

18 mos.) The licensee identified a o sampling panel disablement of a(CASP) circuitry radiation monitor.

which ad sometimes blem resulted in thewith the containmen

(/97)

Security No regional security inspections were conducted during the assessment period.

Pu formance has been consistent.

Emergency Preparedness improved personnel performance was noted during the 1996 EP exercise.

Personnel performance during the 1996 exercise was very good.

(12/13/96)

Performance by the crew in the control room was very good; the crew was focused and effective throughout the exercise. Excellent communications were maintained with personnel in the plant. (12/13/96)

The TSC staff's performance was excellent. Emergency action levels were proactively reviewed to determine conditions which could lead to escalating the emergency classification. (12/13/96)

OSC staff performance was very good. Command and control was i effectively maintained by the facility director as indicated by the I staff's organization and efficient performance of their duties.

(12/13/96)

Performance by the Corporate Emergency Operations Facility, the Mazon Emergency Operations Facility staff, and the Field Monitoring Team was good. (12/13/96)

Fire Protection The Aopendix R Braidwood Enhancement _ Plan was implemented to resolve discrepancies and questions noted during the Themo Science Institute (TSI)

Resolution Plan. A 100% cable routing verification was performed. Two significant issues were identified by the licensee that are being considered for escalated enforcement.

The licensee identified a number of fire zones in which a fire could result in damage to redundant safe shutdown equipment to the extent that safe shutdown could not be assured.

8

The licensee identified a number of deficiencies including the

. procurement, installation and testing of roll-up fire doors affecting

( numerous fire areas containing redundant safe shutdown equipment.

The licensee failed to correctly implement Braidwood Station hot work permit requirements. (proposed violation)- -

The lack of timely corrective action for impaiments, the extensive use of fire watches for compensatory measures, and the lack of fire watch knowledge of existing impaimants were considered program weaknesses.

Fire brigade drills included an excessive number of participants (12 to 14) with the majority of participants having little drill participation. Brigade critiques identified very few problems or areas where brigade performance '

could be improved.

The control of combustibles was good with very few transient combustibles noted in the plant.

Thste was a low number of hot work fires during the past year.

Ill L'ture insoection Activities foutine Resident Inspections

. Ro' tine EP Inspection (March 3-7,1997)

. Sec/rhy Core Inspection (March 10-14,1997)

. Radiation Protection (April 17-25, 1997; and October 27-31,1997)

. Radioactive Waste Processing (June 23-27,1997)

IV. Attachments

1. Plant Issues Matrix

2. AEOD Performance Indicators

3. Average Daily Power Level 4

9 i

PREDEC1510NAL INFORMATION SEMIANNUAL PLANT PERFORMANCE ASSESSMENT BYRON Assessment Period: November 1996 to March 1997 SALP Period: August 18, 1996 through April 25, 1998 Previous SALP Ratings: OPERATIONS: 2 MAINTENANCE: 1 ENGINEERING: 1 PLANT SUPPORT: 2

. 1. Performance Overview Overall, the conduct of operations cor.tinued to be good with activities generally conducted in a conservative manner. However, poor operating practices in radwaste resulted in over pressurizing and significant damage to a regen-waste drain tank, i Engineering and maintenance performance was mixed. Frequently good i

performance was observed on routine issues. However, several significant deficiencies or problems were identified in both areas. The overshadowing occurrence during this period was the identification of excessive silt buildup in the essential service water CSX) cooling tower basins and the related circumstances. This was primartly related to poor maintenance and engineering practices, and resulted in a $100k civil penalty. Continuing issues with foreign material intrusion during the conduct of r.;aintenance activities and periodic noted, ineffectiveness of the licensee's corrective action program were t

Radiation protection continues to show strong performance and chemistry has made a significant improvement, but some weaknesses still exist.

During this assessment period, Unit I was shutdown on February 14, 1997, to investigate SX flow problems with the reactor containment fan cooler heat exchangers. The plant was started up on March 5, 1997. Otherwise, both Units were operated at or near full power with occasional power reductions for equipment changes, control rod moves or main turbine valve tests.

!!. Functional Area Assessment ,

A. Operations

1. Current Performance Performance in operations continued to show good safety perspective overall with fewer personnel errors, and conservative operations appeared to have improved as described below. One exception was the failure of operations to recognize the degraded operability of the essential service water system from I

i Le

damaged grates and strainers. SQV audits were noted as a positive contiibutor to management oversight. However, poor radwaste caerations resulted in over

ressurization of the regenerative waste drain tanc resulting in extensive tank damage.

2. Assessment / Issues .

Operations were performed in a conservative manner.

The station auxiliary transformer switching and restoration operations were carefully planned and professionally executed with appropriate risk considerations. (11/96)

An operator showed a good questioning attitude in the identification of low essential service water (SX) flow in the SX pump room coolers.

(12/30/96)

• While one motor driven feedwater pump [MFP) was out-of-service for maintenance, one of the remaining runntng pumps experienced an increase in vibration. A conservative decision was made to reduce power and secure the MFP with increased vibrations until the out of service MFP could be returned to service. (1/2/97)

Unit I startup disslayed strong command and control, and a slow and deliberate approac1 to criticality. (3/5/97)

One exception to conservative operations.

Operations failed to recognize the significance of the reduced operability of the SX system due to the degraded trash screens in the SX cooling tower basins. This was even with the evidence of the damaged SX strainers caused by transported cooling tower fill material. (7/93 -

10/96)

Radwaste operations were performed in a non-conservative manner.

While transferring water from a release tank to the regen waste drain tank, the tank was over filled and pressurized to where significant damage occurred to the tank. The operator did not monitor tank level during the transfer. Operations in radwaste routinely allowed process, such as filling a tank, to go until an alarm came in. The failure to anticipate and take action in advance resulted in this tank over-fill and over pressurization. An earlier low level alarm had not uen reset and over rode the the high level alam. This issue is also discussed in the plant support section. (2/17/97)

Operator licensing activities were good overall with a few weaknesses.

The applicant's effective use of communications during dynamic scenarios enhanced good teamwork. (10/96) 2

The lack of formal controls to limit. examination material overlap was a weaknes'i. (10/96)

. The licerad validation of examination material lacked comprehensive reviews as evident by errors detected during examination administration.

(10/96) .

The operator requalification feedback system was good. (11/96)

Safety Assessment and Quality Verification SQV audits were positive contributors to oversight of station operations. eg. operations department assessment operations department j operabilityassessmentprocess,integratedreportIngtrendingmechanism i

program, and chemistry assessment. (1/97)

3. Actions / Recommendations Continue with the core inspections. The resident inspectors and project engineer will continue to focus on operations and surveillance activities.

B Maintenance

1. Current Perfor m gg Overall, maintenance and surveillance activities generally continued to be good. Work observed was completed thoroughly and professionally, No problems were identified this period as compared with the last period, with configuration controls during surveillances and more attention was given to scheduling of risk significant maintenance tasks as compared to the last period.

In the previous PPR, FME weaknesses were discussed. During this period, FME practices appeared acceptable early in the evaluation period. However, some weaknesses with FME were identified late in this period in unattended areas and others resulted in significant rework to two containment spray pumps.

A significant occurrence was identified related to excessive silt buildup in the essential service water (SX) cooling tower basins, which rendered the SX system inoperable under certain conditions. Inadequate surveillance procedure acceptance criteria as.well as an apparent willingness to live with known degraded conditions was identified. Significant NRC involvement was required to identify all of the issues and ensure adequate corrective action by the licensee.

Maintenance personnel _ exhibited poor attention to detail-in the reassembly of a SX room cooler when flow divider plates were incorrectly aligned resulting

=in low SX flow. There were several examples of ineffective corrective actions.

3

2. Assessment / Issues .

Routine maintenance and survelliance activities observed continued to be good. .

Comprehensive maintenance activities significantly improved the weather .

protection of the Unit 2 station auxiliary transformer. (9/96)

Mair.tenance and surveillance activities were completed thoroughly and professionally. (11/96)

FME practices were acceptable early in the assessment period. Some weaknesses were identified in unattended areas and others resulted in significant rework late in the period.

The control of FME in unattended areas was weak. Open and unattended systems had no postings indicating the need for FME control. (1/2/97)

Two CS pumps required significant rework due to FME intrusio" during maintenance. (3/3/97)

Failure to identify silt buildup in the essential cooling water tower basins resulted in two severity level !!! violations with multiple examples where there were opportunities for earlier identification, eg. wood, debris etc.

found in essential service water strainers.

Surveillance test for obtaining silt levels in the SX cooling tower basins contained inadequate acceptance criteria to determine SX system operability. (10/96)

The licensee failed to fully appreciate or understand the importance of the SX surveillance test with respect to the SX system operability.

Previous surveillances documented silt accumulation outside the acceptance criteria and degraded trash racks since 1993 with no operational assessment perfonned. (10/96)

Corrective Actions were ineffective.

Maintenance failed to properly use matchmarks for r6 assembly of a SX room cooler. This was a second occurrence where a safety-related cooler had not been assembled correctly. (12/30/96)

A water tight, fire barrier door was left open and unattended during maintenance activities. This is also addressed under fire protection.

(1/97)

Identified high silt levels and degraded trash grates were not resolved in a timely manner. (10/96) 4

, 3. Actions /Recommendatient Continue with the core inspections with continued emphasis on surveillances and maintenance activities.

C. Engineering

1. Current Performance Enginearing performance was good in conjunction with maintenance in support of the day to day operations of the plant. However, there was some decline compared with the previous semiannual assessment period, which had evaluated the engineering performance as very good. During this assessment period, l significant engineering issues related to weak understanding of system design were apparent. Two examples of failure to take timely conservative actions were identified.

2. Auessment/ Issues The weak understanding of design and surveillance acceptance criteria for the SX systen' and the failure to implement a safety evaluation for the containment leak detection system by the engineering organization was apparent during this assessment period.

System Engineering failed to appreciate or understand the importance of the surveillance test with respect to SX systet.. operability. System operability since 1993 was questionable based on previous surveillances that documented silt accumulations outside the acceptance criteria.

There were also other opportunities to identify these problems such as debris found in the essential service water strainers. This was an example of a severity level !!! violation. (10/15/96)

The Engineering Department was not fully knowledgeable of the SX system design as it was documented in the UFSAR. Also, the UFSAR was not adequately updated.' This was an example of a severity level !!!

violation for failure to update the UFSAR. (10/15/96)

The licensee identified that the design input used in calculating the ultimate heat sink cooling tower basin makeup did not reflect the SX

-system design features since initial plant operation. The 1991-1992 design-basis reconstitution failed to identify this error. This was an example of a severity level Ill violation. (11/12/96)

'Two examples of_ failure to take timely conservative actions.

The analysis results of the neutron attenuation _ test for the spent fuel pool (SFP) Boraflex, indicated shrinkage and gaps greater than that assumed in the current SFP criticality analysis. The licensee notified the NRC promptly; however, the licensee's corrective action submittal, regarding SFP Boraflex degradation and the decision to checkerboard the 5

1

=

SFf', were not pursued in a timely manner until after discussions with

, the NRC. (11/12/96)

• The inspectors identified that a surveillance procedure for the containment floor drain leak detection system [lRF008) was implemented to compensate for the loss of alarm function w< thout declaring the system inoperable or performing a 10 CFR 50.59 safety evaluation. Two violations were issued for failure to place IRF008 on the degraded equipment list and failure to conduct a 10 CFR 50.59 analysis.

(12/30/96)

Some good examples of engineering activities:

• The licensee identified that silt levels in the SX cooling tower basin did not meet the surveillance acceptance criteria. Based or excessive silt found in the cooling towers on October 15, 1996, engin6; ring determined that the SX system was inoperable when the plant relied on the deep well pumps for makeup capability. (10/15/96)

The engineering organization identified and aggressively pursued the motor control center spacer issue with Westinghouse. The operability assessment and corrective actions to install the spacers were timely and thorough. (12/17/96)

3. Actions /Recomendations Continue with routine core inspections for the engineering area, with some additional emphasis in design control.

D. Plant Support

1. Current Performance Radiation protection was effective in identifying and resolving program issues. However, problems in radioactive waste operations performance continued to be evident. The chemistry staff has made some iraprovement in self assessant activities, but pt ocedural adherence problems continued to be evident. Security performance was very good and consistent. Access auth-ization and vehicle barrier programs were effectively implemented. No real 1 emergoney preparedness or fire protection inspections were performed

, this lod and resident inspections indicated that performance had remained conn e in these areas.

2. Assessment / Issues Radiation Protection:

During this assessment period, no regional inspections of radiation protection performance were performed. Based on resident inspector observations and findings, performance was consistently good.

6 I

Identification and resolution of radiation' protection program issues continued to be effective.

The licensee identified a series of radiological posting problems. On four occasions, either the high radiation area posting or the contamiuted area posting for the Unit I volume control tank room was ,

found to be on the. valve aisle door. The licensee conducted a thorough investigation which found that a contract individual admitted to finding and replacing postings which had fallen and moving postings which he '

believed were incorrect. (10/96)

Radioactive waste operations problems continued to occur.

A radioactive waste operator transferred water from one of the release

' t a ks to the regen waste tank, over-filling it. This is discussed in greater detail in the operations section. The water being transferred contained very low levels of radioactivity and the resulting spill was collected by the floor drains without a significant effect on radiological conditions in the tank room. (2/97)

Chemistry:

l Self a=sessments of chemistry indicated an improvement in problem identification. However, procedural adherence problems continued to be evident concerning routine chemistry sampling and training.

Some improvements were observed in the licensee's self assessment capablitity.

Surveillances and audits were identifying program weaknesses.

In 1996, the chemistry line organization began a surveillance program to identify weaknesses in the chemistry program. (3/97)

During 1995 and 1996, the licensee's SQV organization, vendors, and corporate representatives conducted assessments of the chemistry

. organization. The chemistry staff were tracking the findings and taking appropriate actions to correct and improve the program. (3/97)

Although plant water chemistry and laboratory quality control were well implemented,- a number of procedural adherence problems were identified by the NRC concerning routine chemistry sampling and post accident sampling training.

On March 5, 1997 NRC inspectors identified that chemistry technicians (cts) failled to adequately-follow chemistry procedures. Prior to tranferring a stripped gas sample, the CT did not evacuate a gas vial, as required by chemistry procedures. (3/97)-

During routine reactor coolant sampling and analyses en March 4 and 5, 1997, NRC inspectors had to question and prompt cts to prevent several errors in following routine chemistry procedures. (3/97)

On March 7, 1997, NRC inspectors identified that the licensee had not conducted training on the post accident sampling system (PASS) in 7

-accordance with program procedures. Since 1994, the licensee had been

conducting annual re-training on the PASS; however, the PASS program procedure requires a six month re-training frequency. (3/97)

Security:

• The Access Authorization Program was effectively implemented.

Procedural guidance for adjudicating derogatory information was a program strength (10/96).

Training provided for the behavior observation program was a program strength (12/96)

Administrative weaknesses were noted.

i Part of the UFSAR and security plan required revision (12/96).

Security performance has been very good and consistent with searches for contraband items effective (10/96).

l Emergency Preparedness:

No regional inspection were conducted during the assessment period.

Fire Protection:

No regional inspections were conducted during the assessment period.

One finding related to an unattended open water tight fire door resultad in an NOV. This is discussed above in maintenance.

C. Actions / Recommendations The core inspection program should continue as scheduled. However, based on the numerous chemistry procedure adherence issues, an additional chemistry inspection is planned to review corrective actions in this area and to review licensee's actions to correct a prior issue concerning the interface between the operations and chemistry departments.

8 ,

III. Future Insoection Activities Routine Resident Inspections EP Evaluated Exercise (April 14,1997) '

. Radioactive Waste Processing and REMP (May 12-16,1997)

. Security Core Inspection (June 16-20,1997) .

Radioactive Effluents (July 14-18,1997)

Chemistry Inspection (Regional Initiative) (September 2-5,1997)

. Radiation Protection Inspections (October 6-10, 1997; and November 17-20, -

1997) 50P1 (Systems Operational Performance Inspection) (November 1997)

IV. Attachments

1. Plant Issues Matrix -

2. AEOD Perfomance Indicators

3. Average Daily Power Level 9

PRE-DECISIONAL SEMIANNUAL PLANT PERFORMANCE ASSESSMENT (Dresden)

Assessment Period: September 30 through March 7, 1997 SALP Period: End of SALP 14 - Start of SALP 15 (3/19/95-12/28/96) - (12/29/96-04/25/98)

SALP 13 SALP 14 Previous SALP Rating: OPS 3 12 MAINT 2 13 ENG 3 3 PS 2 2 I. Performance overview Doerations performance has been good. Conservative decision making was shown during event investigations. Plant material condition continues to affect availability; the units have been shut down or limited in power due to equipment problems (e.g., a recirc pump motor short, multiple problems with condensate demineralizer service units). In Maintenance, significant deficiencies were identified in the surveillance and test programs this assessment period. Inspections of Enoineerino identified significant errors in maintaining the design basis of .he containment cooling strvice water system and in the adequacy of some plant design basis calculations. In olant succort, good control of personnel exposures and contaminated areas was noted.

However examples of radworker performance deficiencies were observed 7

during this assessment period, and some minor problems in security were identified.

During this period, the NRC conducted an Independent Safety Inspection (ISI). This 21-person team was on site from September 30 to October 11, and from October 28 to November 8. The results were presented in a public exit meeting on December 12, and the report (50-237/96-201; 50-249/96-201) was published December 24. The cover letter to the report stated,

... Safety performance has significantly improved in plant operations while the level of improvement in engineering has not yet resulted in fully effective problem identification and resolution as evidenced by the failure to identify significant weaknesses in design control and maintenance of design basis calculations, and the failure to resolve a number of longstanding problems affecting safety-systems. The results of improvement initiatives in radiological protection, maintenance, testing, and self-assessment were mixed.

... the ISI identified significant weaknesses in the areas of radiation

Dresden PPR 10/96 - 3/97 protection, maintenance and testing, engineering, and in the implementation of the corrective action prograr. ....

Corrective actions to resolve the lack of control and maintenance of design basis calculations (only started; after the problem was brought to the attention of Dresden Station sen'or managers by the ISI. . . .

• l The ISI also identified that significant challenges to continued improvement exist. First, the level of emergent work continues to hamper the ability to perform planned work consistently, which is preventing the reduction of the corrective maintenance backlog to the desired level and is unnecessarily challenging plant safety systems and plant operators. Second, corrective actions that have been' implemented for programatic and hardware problems have not been effective in a number of areas, resulting in repetitive problems. Finally, the full implications of the lack of design control and maintenance of design basis calculations have not yet been determined, pending Comed's continuing reviews in this area.

Because of the significance of the engineering and design basis issues, Comed, in a letter dated November 8,19M, comitted to several actions l to provide further confidence in the adequacy of the design basis and engineering activities at Dresden Station. The short-term actions were confirmed by an NRC Confirmatory Action Letter (CAL), dated November 21, 1996, that required the licensee to review key parameters for the 12 systems most important from a risk perspective to. verify that calculations supported those parameters. The CAL also required improved engineering oversight, procedures, and audits. The NRC was to be notified immediately if critical parameters on any of the 12 systems were discovered outside normal acceptance values. The NRC and the licensee meet monthly to discuss the schedule, results, and proposed actions concerning the audits.

Operatina History for the Past Six Months In September 1996 both units were restarted from forced outages and were

. at full power dual unit operation at the beginning of October. During the period, Unit 2 experienced several power reductions due to equipment problems; however, Unit 2 has operated in excess of 220 days. On October 26, Unit 3 entered a forced outage due to a recirculation pump motor fault and was restarted on January 30, 1996. Dual unit operation continued until Unit 3 started a refueling outage on March 29, 1997.

II. Functional Area Assessments Ita Me 7 ext means that the data are from draft, unpublished reports.

1. Operations 2

>w __

Dresden PPR 10/96 - 3/97 Pre-Decisional A. Current Performance .

A consistent level of good perfomance was noted in operations during a the period. There have been some events of low safety-significance that showed the need for continuing focus on attention-to-detail.

1 B. As.sessments/ Issues Recent observations of operations personnel revealed good performance.

However, there were some performance problems for which the licensee took corrective actions.

The inspectors observed that the operators were attendant to the panels, knowledgeable of the reasons for lit annunciators, and aware of activities in the plant. (DRAFT 97004)

Overall, the licensee completed the startup of Unit 3 safely.

Most connunications and connand and control were good. The procedures were adequate. Some decrease in the level of performance was noted, and the licensee implemented corrective 1

actions. (DRAFT 97004)

• Operations performance was nixed. The inspectors noted examples of good performance, such as ensuring other departments were reaay to perforn work correctly, but the inspectors also noted examples

' of poor connunications, failing to follow through on questions, and errors in maintaining a big-picture of plant operations. This was a notable decrease from the previously observed level of performance. plant nanagement recognized this decrease and took steps to restore the conduct of operations. However, soon after the reinforcement of operations standants, a unit supervisor became distracted from his big-picture duties and left the control room. (DRAFT 97004)

The site quality verification (SQV) department identified a decrease in overall station performance during this inspection period. The head of each auditing function discussed the findings with the inspectors. SQV indicated that the decline was being discussed with each department. Also, the licensee was attempting to bring in a root-cause assessment contractor. The inspectors considered the SQV identification to be tinely and the actions to be appropriate. A long-tern evaluation of station performance will be naeded to determine the effectiveness of corrective actions. (DRAFT 97004)

An initial operator, license exan was cancelled by the ifcensee due to poor candidate perfornance. (Draft 97004)

=

Overall, the conduct of operations was safe and in accordance with 3

4 Dresden PPR 10/96 - 3/97 procedures. The inspectors observed that the control room ,

operators were attendant to the panels, knowledgeable of the reasons for lit annunciators, and aware of activities in the -

plant. (96016)

Operators used a conservative approach to evaluate a turbine control valve (TCV) which was stuck closed. The plant operations review comittee (PORC) performed a thorough review of the TCV test plan. (96016)

The licensee's assessment of the acceptability of scaffolding in the reactor building near the Unit 3 spent fuel pool following identification by the inspectors on January 8 was not timely. No engineering assessment had been performed when the action request was generated in December 1996. Also, the failure to generate a performance improvement form (PIF) was not in accordance with management expectations. (96016) l Overall, operator performance was a noteworthy strength. (96201 sumary)

Control room operators properly controlled operational activities, such as surveillance tests, strictly followed procedures in most circumstances, and comanicated effectively. (96201 sumary)

Several recent issues demonstrated the need to maintain high attention-to-detail. In some cases, the inspectors identified problems and in others, operations management noted the problems and took corrective actions. Examples of poor attention to detail included:

=

Following a nispositioned control rod issue operations annagement did an assessment and concluded that the control rod afspositioning, when viewed with other recent events, indicated a decline in operations performance. Management did not increase power until corrective actions were initiated. (Draft 97004 Section 04.1)

The facility was operated in a safe manner with good comunication. Minor discrepancies continue to occur and attention to detail type issues were observed.

The Unit 3 low pressure heater bay had improved accessibility and housekeeping; however, minor material deficiencies were identified by the inspectors. (96014 Section 01.2) 4

t Dresden PPR 10/96 - 3/97 t Pre-Decisional Operators cantinued to perform well during plant events and transients, ,

however, equipment failures continue to challenge ope. ' ors.

• A manual reactor trip was initiated in response to a loss of the 3B reactor recirculation motor generator set. The control room operators followed procedures and conducted an orde-ly shutdown.

(96014 Section 02.1)

• Operators properly respond te the annual fish migration that challenged the facility's service water system. Operators reacteo in a controlled and conservative manner that minimized the transient on the facility. Material deficiencies evident included service water strainers backwash function in manual instead of automatic moda (an operator work around), and an inadequate traveling screen wash nozzle spray pattern allowing for some fish i carry-over that entered the service water system. (96013 Section l 04.1) l C. Recommended Insoection Focus

• Continue with current routine resident inspections.

• Provide augmented coverage of refueling activities. A maintenance team inspection will be conducted in April during the Unit 3 outage. This team will be in lieu of a revisit by members of the 151 team.

2. Maintenance A. Current Performance Work activities were generally well performed. Adequate performance was noted in maintenance during the PPR period. Much of the work was reactive, so resources were diverted from planned maintenance. Some maintenance personnel did not consistently display an understanding of management expectations or procedural requirements for the conduct of work or identification of maintenance issues. Testing weaknesses resulted in the failure to detect degraded systems and components.

B. Assessment / Issues Work off of the backlog of non-outage maintenance work requests was hampered by diversion of the licensee's resources due to emergent work.

• The work planning and scheduling processes were continually challenged by emergent work activities that precluded or delayed the implementation of scheduled work and diverted resources away from meeting the schedule. Notably, four examples involved emergent work activities associated with the control room heating, 5

i

Dresden PPR 10/96 - 3/97 Pre-Decisional ventilation and air conditioning (HVAC) system, Unit 2 and 3 HPCI system problems experienced during surveillance testing, EDG 2/3 and EDG 3 concurrent failures, and the Unit 2 recirculation pump trip (96201 Section 4.1.1)

• Station's backlog of outstanding work and action requests recoded to remove most of the planned corrective work. (96013 Section M3.1)

Material condition of facility, including presence of foreign materials, affects availability of systems.

• Unit 3 high pressure coolant injection system material condition and configuration control problems (e.g., auxiliary oil pump trip and high area temperature readings) affect surveillance performance. (96013 Section M2.2)

Root cause for the B recirculation pump motor failure was foreign material intrusion into the stator windings. (96014 Section M2.1)

Construction era rag was found ir. side the Unit 3 high pressure coolant injection (HPCI) lube oil cooler water box. Tube leaks were repaired and the system was restored to service. (96014 Section M2.2)

Work performance was mixed. Some workers did not follow or understand management expectations or procedural requirements.

The work reviewed was perforned correctly. Workers followed the work packages. Good radiological practices were noted. Some inattention to detail and lack of questioning attitude was noted.

(DRAFT 97004)

=

The inspectors

• review indicated that the licensee *s inittal response, inmediate corrective actions, and prompt investigation for a licensee identified TS violation were good. However, this was the second licensee-identified TS violation caused by transposing data durirg equipnent surveillance tests within 3 months. (DRAFT 97004)

• The inspectors concluded that, in general, PIFs for maintenance activities were being written as-necessary. (DRAFT 97004)

Some calculaticnal issues raised during torus pitting inspection remained unresolved. (97003 Section M2.1)

Several surveillance activities were observed with no significant concerns with operator performance, equipment operation, or test data identified (96016 Section M1.1).

6

__- J

Dresden PPR 10/96 - 3/97 Pre-Decisional +

• Control rou ventilation project personnel completed significant .

repairs with good coordination between the ventilation group and those involved in other plant activities. Also, personnel -

involved-in the re> air and testing of the ventilation system were knowledgeable of tie system operation and design and work documents. All observed work was performed well (96016 Section M2.3).

• The thoroughness of the licensee's review to identify potential conflicts among emergency diesel generator surveillance tests was weak and the licensee's corrective actions concerning an earlier violation were narrowly focused. Additionally, training conducted to reemphasize the need for attention to detail was not entirely effective (96016 Section M3.1).

All four pressure switches for the Unit 2 turbine first stage l

pressure 45 percent scram bypass switches were identified by the

! -licensee as being miscalibrated due to personnel error. The inspectors' preliminary review indicated the licensee's initial response, imediate corrective actions, and prompt investigation were good (96016 Section M3.2).

• Repair of the reactor recirculation pump motor was completed successfully. The inspectors concluded that the licensee performed the repair of a major piece of equipment in a well -

controlled manner (96016 Section M2.4).

Significant repair work on the 3B reactor recirculation pump motor was well executed and managed. (96014 Section M2.1)

Usually, maintenance activities were well controlled; however, two work stoppages were issued due to non-safety related parts control and contractor work practices. (96014 Section M1.1)

Longstanding testing weaknesses were present, and were not promptly recognized or evaluated when re-identified.

Testing weaknesses resul .d in the failure to detect degraded-systeus and components. Longstanding-programatic problems with the in service test (IST) program were not comprehensively

, addressed from 1987 to 1996. Relief valve setpoints differed significantly,'in some cases, from design pressures established for safety-related systems. Opportunities to address the IST program deficiencies, early in 1996, were not promptly recognized and evaluated. (96201 Sumary)

Because of_the NRC's findings, the licensee determined that the revised peak loading of the duty cycle was' not reflected in the battery service tests performed during the D2R14 (1995-1996) and 7

Dresden PPR 10/96 - 3/97

( Pre-Decisional D3R13 (1994) outages, and the testing was inconsistent with the ,

design peak loading. (Deficiency 50-237(249)/96201-22)

The procedures used to test the control room HVAC system and boundaries were not appropriate. (Deficiency 50-237(249)/96201-20)

The licensee failed to do post-modification testing on the Unit 2/3 main control room (HVAC) system. This was an apparent violation. (96014 Section E2.1) Enforcement conference held on February 28, 1997. Under OE review.

Maintenance personnel were not always using the station's integrated reporting process. Examples included:

PIFs were not written when required after the results of the oil sample exceeded the acceptance criteria; or when the Unit 3 ECCS keep fill pump discharge check valve failed open during post-maintenance testing (Deficiency 50-237(249)/96201-09).

In general, FIFs were written for maintenance activities. One exception was noted. The licensee will change its station reporting processes to follow a corporate reporting process.

(Draft 97004 Section M7.1)

C. Recommended Insoeetion Focus Continue with current routine resident inspections.

i Provide augmented coverage of refueling activities. A maintenance team inspection will be conducted during the Unit 3 outage in April. This team will be in lieu of a revisit by members of the

! ISI team.

3. Engineering A. Current Performance While the overall quality of engineering support to plant operations improved, particularly support from system engineers,. continued improvements are needed in other areas of engineering. The NRC identified some significant errors in maintaining the design basis of the containment cooling service water system and in the adequacy of

! several plant design basis calculations.

B, Assessment / Issues All significant issues related to the MOV program were resolved, therefore the review of the 61. 89-10 program was closed.

8

Dresden PPR 10/96 - 3/97 Pre-Decisional

• - Documentation and data support conclusion that MOVs perform under ,

accident conditions. (96015 Section El.1)

• Knowledge of MOV site engineering team was good, as was corporate interfaces. (96015 Section El.1)

• Self-assessi.*nts in the MOV area provided good technical findings and were bene'icial in improving the MOV program. However, the tracking of corrective actions, was not formalized until after the MOV self-assessment. (96015 Section E7.1)

Performance regarding root cause dete :sination, timely resolution of issues, quality of reviews of industry initiatives and attention to detail was mixed.

The inspectors reviewed several open operability evaluations for both units with licensee management. The evaluations, equipment status, and schedule to restore the system or component to fully l operable appeared reasonable (96016 Section El.2).

Design Engineering response to isolation condenser support and feedwater anchor issues was good. (96013 Section E2.2)

Unit 2/3 emergency diesel generator ventilation fan Unit 2 power supply breaker troubleshooting was poor. (96013 Section E2.4)

• An engineer failed to enter vendor technical information into the vendor equipment technical information program (VETIP) as required by plant procedures. (96014 Section E4.1)

A more thorough OPEX program review of industry initiatives may-have identified the hardened grease issue before Dresden's 3A LPCI pump breaker failed. (96012 Sumary)

The ISI team identified instances in which: (1) the licensee failed to maintain control of calculations; (2) tne licensee failed to maintain calculations retrievable;-(3) the licensee made errors in calculations or made nonconservative design assumptions; (4) TS, UFSAR, DBD, and drawing discrepancies existed; (5) engineering evaluations were technically weak or not performed (including 10 CFR 50.59 evaluations);

and (6) the licensee failed to resolve a number of safety issues promptly. (96201 Section 5.1)

The NRC identified that the licensee was unable to maintain the design basis of the containment cooling service water system under

-certain conditions, and identified significant weaknesses in the licensee's control of design basis calculations, including a number of errcrs and nonconservative design assumptions. (96201 9

)

Dresden PPR 10/96 - 3/97 Pre-Decisional Summary)

• The NRC's review of the DBD, UFSAR, and ECCS calculations showed that the licensee did not have Net Positive Suction Head Available (NPSH ) calculations that reflected the licensed plant confi,guration (i.e., one LPCI pump /two CCSW pumps). The NRC's review of the existing calculations, which provided some information about the NPSH , showed a number of errors in the design control of assumpti,ons and inputs. (95201 Section 5.1.1.1)

The NRC identified numerous examples of the failure to translate the design into drawings, specifications and procedures. Examples included omission of electrical loads in the 125 VDC battery sizing calculation, incorrect cable lengths and resistances, and nonconservative 250 VDC battery sizing calculation. (Deficiency 50-237(249)/96201-22)

The failure to resolve the standby liquid control (SBLC) vulnerabilities identified by the Vulnerability Assessment 'leam (VAT) in 1992. (Deficiency 50-237(249)/96201-14) l l C. Recommended Insoection Focus Confirmatory Action Letter was issued on November 21, 1996, which details the actions taken to assure engineering deficiencies are being identified and corrected. Monthly management meetings have been held during which the licensee has provided status of their actions. Engineering inspections are in progress to independently I

verify and validate the licensee's results.

I Followup inspection (IR-97005) will review licensee's response to deficiencies raised in the ISI report.

Provide augmented coverage of refueling activities. A maintenance team inspection will be conducted during the Unit 3 outage in April. This team will be in place of a revisit by members of the ISI team.

In service Testing and Inspection (Engineering) during upcoming Unit 2 Refueling outage.

Augment routine resident inspections with a dedit:ated regional engineering specialists.

4. Plant Support A. Current Performance In radiation protection, overall performance has been good, however the 10 i

Dresden PPR 10/96--3/97 Pre-Decisional NRC team-identified multiple examples of radiation protection personnel and radiation workers failing to follow basic radiation protection practices, procedures, and department expectations. No serious radiological consequences resulted from these deficiencies during this period.

In security, overall perfomance was good. The NRC identified some weaknesses.

B. Assessment / Issues RADIATION PROTECTION:

Radiation exposure and contamination control vere improved.

Briefs given to personnel performing woti in high radiation and high contamination areas were thorough. 'ersonnel working in the radiation protection area had a good unders bnding of radiation work permit requirements (96016 Section RI.1).

l-l

• From January 1,1996 to November 7,1996, the licensee reduced the I

number of hot spots from 84 to 42 and planned to reduce this number to about 20 by the end of the Unit 3 1997 refueling outage.

(96201 section 3.1)

The 1996 exposure goal of 440 person-rem was the lowest exposure goal established at Dresden Station. As of November 7, 1996, the station accrued 376 Rem. (96201 section 3.I' Some radiation protection personnel were not following basic procedures and requirements.

Failure to survey the work area (the Unit 2 hot well, Unit 3 reactor building overhead) and assess-the potential radiological hazards. (Deficiency 50-237(249)/96201-02)

Failure to specify a maximum stay time on a radiation work permit and maintain locked high radiation doors. (Deficiency 50-237(249)/96201-03)

Failure to maintain control of radioactive material. Contaminated stanchion found in uncontrolled area. (Deficiency 50-237(249)96201-06)_

Some radworkers were not following basic radworker practices.

The NRC identified that some licensee workers were not aware of the radiological conditions in their work areas and that these work areas were not restored to prework conditions after 11 4

.h

Dresden PPK 10/96 - 3/97 Pre-Decisional completing the work. (96201 Section 3.3)

SECURITY:

Generally security performance was good, but some weaknesses were identified.

• Generally security performance was good. Security management has taken action to improve comunications and performance effectiveness throughout the security organization. Those actions have resulted in a reduction of personnel errors and have reduced procedural adherence problems. Security force members showed a good working knowledge of security requirements and team work between different organizational levels within the security organization. (97002 Sumary)

Security intrusion equipment was observed to be working as designed. A good working relationship existed between the security organization and maintenance groups. (97002 Sumary) l A weakness in the security program was identified involving protected and vital area personnel access control. A violation involving a failure-properly to limit personnel access

authorization to a vital area was identified by the inspector.

I Also, a non-cited violation involved a failure to cancel a security badge in a timely manner was identified by the licensee.

This failure showed weak coordination between corporate and site security in assuring that security badges are terminated in a timely manner. (97002 Sumary)

A recent tampering event was reported via ENS and involved a security guard.

EMERGENCY PREPAREDNESS:

Computer accounting system failed at the beginning of the plant assembly drill causing confusion. A thorough drill critique identified deficiencies and corrective actions (96014 Section P4.1).

An assembly drill was successfully run. (96016 Section RI.2)

C. flecomended Insoection Focus

• Continue with current routine resident inspections.

• Provide augmented coverage of refueling activities. A maintenance team inspection, including HP, will be conducted during the Unit 3 outage in April. This team will be in place of a revisit by 12

Dresden PPR 10/96 - 3/97 members of the ISI team.

111. Future Insnection Activities Operations ,

Routine core inspection program.

Maintenance Maintenance Team Inspection During Unit 3 Refueling Outage Engineering Dedicated Rill Engineering Specialist for Verification and Validation of Licensee Efforts Regarding CAL 1ssued for Engineering Deficiencies Plant Support Routine program

~

IV. Attachments

1. Plant Issues List .

2. AEOD Performance Indicators

3. Power History Charts 13 i A --

PRE-DECISIONAL SEMIANNUAL PLANT PERFORMANCE ASSESSMENT (Quad Cities)

Assessment Period: October 1996 to March 1997 '

SALP Period: October 27, 1996 Through June 20, 1998 Previous SALP Rating: Ops 2

• Maint 3 Eng 3 PS 2 I. Performance Overview Doeration performance was good during the period. Self assessment activities within the operations department continued as a strength.

Physical improvements to the control room and new policies designed to minimize noise and distractions from unnecessary personnel appeared effective in improving the control room environment near the end of the period. Operator caused events were relatively few and minor, and both '

units experienced relatively long runs (over 100 days) simultaneously at the end of the period. Some minor events indicated that the generally ,

good ' control room performance may be declining. Barriers designed to prevent these events such as mandatory panel walkdowns and shift turnover status lists failed. Operations management's focus on degraded equipment, plant risk and system operability was not always commensurate with system importa.nce and potential impact on operations.

Maintenance performance was adequate. Efforts to reorganize maintenance into multi-disciplined teams, and to improve work control have had some success in improving maintenancs quality and efficiency. Some corrective maintenance backlog reduct ons were made. Material condition challenges pointed to training, trending, root cause and corrective action problems. Parts control and quality issues have also detracted from maintenance effectiveness. The station was dealing with large amounts of emergent work throughout the period. Problems with surveillance testing included scheduling deficiencies, work control disconnects and inadtquacy nf tests to meet requirements.

Enaineerina performance remained adequate. Engineering has focused on several efforts to improve performance such as improved resource tracking and utilization, root cause training, and improvements in tracking, trending and corrective action. However, these efforts were just beginning to be implemented as part of the 1997 Operational Plan.

Problems with poor root cause analysis efforts and poor operability determinations were identified this period. In addition, the large amount of emergent work pointed towards the need for more comprehensive engineering solutions.

Plant sucoort remained good overall. Radiological performance was constant this assessment period. Overall dose expended continued to be 1

l O

Quad Cities PPR 10/96 - 3/97 Pre-Decisional

-high due to efforts to address plant material condition problems and a .

poot work planning process; however, effective ALARA initiatives and control of these work activities kept the dose at a reasonable level -

considering the amount of_ work that is occurring at- the station.

• Continuing problems were also observed with radiological work practices and contaminated area control and the oversight of radiation monitors was weak. A second occurrence of contaminated material generated at Quad Cities but found offsite was being investigated at the end of the period. Security performance declined somewhat because of inattention to detail for. activities relating to vehicle searches, security barriers and fitness for duty. Security performance remained satisfactory.- Fire protection activities were considered adequate. The station remained in 3 fire protection LCOs continuously due to inadequate fire pump capacity, and other planned maintenance further increased overall risk in this area. A new IPEEE study showed fire to be a major contributor -

to external risk (SE-3).

Doeratina History for the Past Six Months Both reactors were on line simultaneously for runs of greater than 120 I

days. Near the end of the assessment period, Unit 2 was shut down about 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> earlier than planned for entry into the current refueling outage l

when four of five power-operated relief valves (PORVs) were declared inoperable after failing to meet closing time criteria during a surveillance test. Unit 1 operated reasonably well over the past six months, exceeding 200 days on line, until a SCRAM relay failure during 4 testing resulted in a conservative decision to enter a forced outage for repair. Unit I was restarted in late March.-

II. Functional Area Assessments itaMc Text means that the data are from draft, unpublished reports.

1. Operations A. Current perfors g u Operations performance has remained good.- Self assessment activities within the operations department continued as a strength. A control room modification improved information presentation and procedure storage. New policies designed to minimize noise and distractions from unnecessary personnel appeared effective near the end of the period.

Operator caused events were relatively few and minor, and both units experienced relatively long runs simultaneously at the end of the period. Some indications 'that the generally good control room performance was-declining included a standby gas treatment. switch misposition event-and a control rod misposition event. Barriers designed to catch these issues such as mandatory panel walkdowns and 2

Quad Cities PPR 10/96.- 3/97 Pre-Decisional I

shift turnover status lists also failed. Operations management focus un degraded equipment, plant risk and system operability was not always comensurate with system importance and potential impact on operations. -

Examples included poor overview of shared diesel generator operability determination following a failure to start, poor consideration of ultimate heat sink during maintenai.ce, and poor planning for a fire pump limited condition for operation which led to the pump being out-of .

service for over 19 days of a 7 day LCO.

B. Assessment / Issues Operator response to unexpected transients was generally good. However, several operator errors during more routine act'vities showed a lack of '

i attention to detail, inadequate self check, and poor communications, Operator response to an inadvertent high pressure coolant injection (HPCI) system initfation was good. (2/97)

Operators mispositioned a control rod by using the wrong switch l during cortrol rod exercising. (1/97)

A control room operator mispositioned a standby gas treatment switch, rendering the train inoperable. Operators performing panel checks failed to identify the discrepancy for several hours.

During a subsequent shift turnover panel check, an operator indicated on the panel check sheet that the switch was in the operable position when it was not. (12/96)

Panel monitoring by control room operators was good in detecting that the Unit Two number 1 combined intermediate valve was not fully open, but monitoring could have been better in detecting generator swings produced during troubleshooting activities.

(10/96)

Operations exhibited some weaknesses in performing scheduled tasks.

Surveillance testing problems included poor coortlination of the electronic work control system with the daily schedule. (2/97)

• Operations failed to ensure a surveillance test for HPCI operability was performed in a timely manner. (12/96)

Operations schedoling failed to ensure cold weather preparations were completed before the onset of cold weather. (11/96)

Operations management focus on degraded equipment, plant risk, and system operability was not always comensurate with system importance and potential impact on operations.

3

Quad Cities PPR 10/96 - 3/97 Pre-Decisional I

• Management oversight was not always adequate to ensure consistent quality operability evaluations were being performed and validated for key systems. (2/97) -

• Several unit transients and safety system failures were due to repeat issues, and indicative of a lapse of operations management focus on improving material condition (2/97.)

• Operations failed to fully evaluate the effect a degraded check valve would have had on the LPCI system during an accident.

Operations had not initially characterized the degraded check valve as a significant operator workaround. (12/96)

• Operations exhibited good control of switchyard work. (11/96)

• Operators showed poor risk perspective and poor prioritization in taking out of service one of two pathways for water to safety systems from the ultimate heat sink. (11/96)

C. Recomended Insoettion Focus Continue core inspections enhanced by operator licensing. Supplement project engineer support when available. Areas of focus should include operability evaluations, operations focus on improving material condition, conservative decision making and risk perspective, personnel errors, and out of service errors - especially during the Unit Two refueling outage. A 40500 inspection should be performed by mid 1997.

2. Maintenance A. Current Performance Maintenance performance was adequate. The reorganization of maintenance into a number of "Fix It Now" type teams helped improve teamwork, but did not solve problems of training, supervisory oversight and personnel errors. Work control improvement efforts have made some progress, especially in trending and analyzing where problems exist, but have not solved all the scheduling end work control problems. The end of 1996 and early 1997 were characterized by a large amount of emergent work which made schedule adherence and backlog reduction goals impossible to meet. The reasons for the large amount of emergent work were not well understood by the licensee, but included poor root cause efforts, poor equipment performance trending, poor rotating equipment maintenance, and lack of adequate preventive maintenance. Problems with procedure adherence and weak supervisory oversight were seen. The licensee was addressing these issues with programs to improve training and root cause, reliability monitoring improvements and other longer term efforts. Problems with surveillance testing included scheduling deficiencies, work control disconnects and inadequacy of tests to meet 4

4 Quad Cities PPR 10/96 - 3/97 Pre-Decisional requirements. Parts control and quality issues have detracted from maintenance effectiveness.

B. Assessment / Issues Some maintenance activities were performed well. Other activities were problematic due to parts, procedure adherence, poor supervisory oversight, or skill of the craft errors.

The *2A" control rod drive (CRD) pump was rebuilt twice in 1996, and is still out of service for high vibration and seal leakage.

(2/97)

Numerous rotating equipment problems exist including the 1A reactor feed pump which has been out of service for over 3 months, the 2B reactor feed pump which has a seal leak after just being overhauled, the 1A reactor or cleanup pump and the 2A CRD pump.

l (2/97)

IC and ID RHR5W pump overhaul activities were performed well.

(2/97)

Mechanical maintenance workers failed to follow procedures while t working on an emergency diesel generator air start motors. Rework was required. and the supervisor was not informed. (10/96)

Inspectors found unqualified workers supervised by vendor representatives during repairs on the shared emergency diesel generator. (10/96)

Initial work on the 2D RHR5W pump seal resulted in the seal housings being installed improperly. (10/96)

Weaknesses in the licensee's work control process were addressed and some improvement was noted. However, emergent work continued to affect the planned work schedule.

• Repeat problems with feedwater heater level cent ol valves and gland steam condenser level control valves necessitated increased operator intervention, caused increased personnel radiation exposure, redirected previously scheduled maintenance activities, and impacted unit operation. (11/96)

Maintenance work on the IC RHR5W pump and shared standby diesel generator were well coordinated and executed according to schedule. (10/96)

(

5

Quad Cities PPR-10/96 - 3/97 Pre-Decisional

• ' The liceh:,ee showed some progress in the implementation of the work control process, as evidenced by some corrective maintenance backlog reduction and improved schedule adherence. (10/96) -

Parts problems hindered effective maintenance performance and led to rework.

The NRC issued a violation for failure to maintain design control after vendor supplied parts used for RHRSW pump repairs rendered the pumps inoperable. (12/96) e-Improper bolt material was installed in the 1C and 2C RHRSW pumps due to inadequate control of vendor processes. A violation was issued. (11/96)

• Quad Cities put a hold on all parts received from the Comed Central Re:eipt Inspection and Test (CRIT) facility based on a number of problems with parts received. (10/96)

Surveillance testing and scheduling problems have been identified.

\

• Unit Two HPCI inadvertently started, with possibility of l

injection, due to a problem with automatic depressurization system surveillance testing. (2/97)

The licensee failed to ensure that control room ventilation was adequately tested using RHRSW. (2/97)

The licensee issued a trend PIF regarding problems in the seneduling of Technical Specification required surveillances.

(2/97)

The NRC identified that Technical specification requirements to test control room ventilation-dampers were not being performed. A violation was cited. (2/97)

A test control violation was issued following NRC identification of a failure to test a charcoal adsorber canister in the control-room ventilation systemi (12/96)

A test control apparent violation was identified regarding the

-failure to adequately test control building ventilation ability to maintain a positive pressure. (11/96)

The licensee continued to devote sf gnificant resources to correct material condition deficiencies. and improvements have been made.

However, equipment material condition remained a key problem and continued to burden the station. Material condition problems affected 6=

~

Quad Cities PPk 10/9E.- 3/97 Pre-Decisional several important systems. Thess included:

• Combined intermediate valve problems resulted in removing unit 1 -

turbine generator from service and several secondary plant disturbances. (10/96)

Unit Two turbine generator was tripped due to moisture separator drain tank level control problems. (10/96)

Unit Two power was reduced due to reactor water cleanup valve packing leak. (11/96)

A Unit Two shutdown was required due to four of five power operated relief valves failing to meet inservice testing closing time requirements specified by plant procedures. (2/97)

The shared EDG experienced a failure to stop and a failure to start. The stop failure was attributed to a failed governor solenoid, and the failure to start was an air start motor problem.

Both failed components were repeat problems with the EDG system.

1 (1/97)

The 1A react 9r feed pump (RFP) was out of service for the entire inspection period awaiting rotating element and seal replacement.

(1/97)

The 2A control rod drive (CRD) pump developed a seal leak. The pump remained in service for limited use only. (1/97)

C. Recommended Insoection Focus Rcutine inspections should focus on procedure adherence, contractor control, and the adequacy of surveillances. Maintenance rule inspection efforts should be finalized, and should focus on safety systems which have show. repeated problems such as HPCI and EDGs.

3. Engineering A. Current Performance Engineering performance remained adequate. Engineering has focused on several efforts to improve performance such as improved resource tracking and utilization, root cause training, and improvements in deficiency tracking, trending and corrective action. However, these ,

efforts are just beginning to be implemented as part of the 1997 Operational Plan. Problems with poor root cause analysis efforts and poor operability determinations and ineffective corrective actions were identified this period, although some examples of improvement were noted. In addition, the large amount of emergent work on components 7

, Quad Cities PPR 10/96 - 3/97 Pre-Decisional i

such as control rod drive pumps, reactor water cleanup pumps and valves, feedwater pumps and other components point towards the need for more comprehensive engineering solutions. Some engineering evaluations and .

calculations were found to be weak.

l 8

Quad Cities PPR 10/96.- 3/97 Pre-Decisional B. -Assessment / Issues Due to a weak root cause analysis and corrective action process, -

addressing material condition issues remains slow and ineffective.

However, occasional examples of improved effort were observed.

Identification of design discrepancies in the emergency core cooling system (ECCS) suction strainers was good. Also, training provided to the operators on potential ECCS pump cavitation was timely and effective. The inspectors identified potential problems with credit taken by the licensee for containment over-pressure in the associated safety evaluation, since values used were not included in the licensing basis (1/97).

Engineering failed to fully evaluate the effect a degraded check valve would have had on the LPCI system during an accident.

Operations had not initially characterized the degraded check valve as a significant operator workaround. (12/96)

The inspectors identified a violation for failure ti incorporate Technical Specification requirements into station surveillance l procedures for the control room emergency filtration system charcoal adsorber (12/96).

The identification of weaknesses in the trending of RHR cooler differential pressure testing was an example of trending problems and a deviation from corrective actions committed to in LERs 50-254/92008 and 50-265/92007 (11/96).

The self-assessment in the MOV area provided good technical findings and was beneficial in improving the MOV program.

However, site quality verification had not completed any recent MOV program assessments and none were planned. (11/96)

The inspectors identified a program weakness where there was no formal review process for the Rising Stem MOV Data Sheets when a valve's available thrust was identified outside the design bases thrust windows. This was a generic concern for all Comed plants.

(11/96)

The inspectors identified weaknesses in the licensee's approach for determining control roc. operability for post accident conditions (10/96). .

Control room ventilation original design errors led to system inoperability. A good questioning attitude by a system engineer led to identification and subsequent repair of a design deficiency in the safety-related portion of the control room ventilation system-(10/96).

9 1

~

Quad Cities PPR 10/96 - 3/97 Pre-Decisional

• A thorough root cause analysis by engineering staff helped to resolve problems associated with improper venting of the HPCI system (10/96).

En91neerin; evaluations and calculations continued to be weak.

The inspectors identified weaknesses in the licensee's operability evaluation of the shared emergency diesel generator (EDG) start failure and probleas with the methodology for determining diesel generator reliability data (1/97).

The inspectors concluded that an initial operability assessment for the safe shutdown makeup system was weak, because the assessment failed to verify the ability to take manual actions (1/97).

Lack of engineering rigor (non-conservatism) regarding the safety-related function of the reactor building exterior panels resulted in escalated enforcement for inadequate design control and 50.59 review. (11/96)

A licensee calculation concerning RHR room cooler operability assumed a non-conservative cooler inlet temperature. However, other conservative assumptions in the calculation coupled with the l

age of the problem and actions being taken to inspect the coolers every refueling outage led the inspectors to conclude that a further review of the calculations was not warranted. (11/96) i C. Recommended Insoection Focus Review the licensee's 1997 Operational Plan improvement efforts. A System Operational Performance Inspection (SOPI) or E&Ts inspection is scheduled for the fall of 1997. Routine inspections should continue to focus on system performance in accordance with design basis, and operability evaluations performed when design basis is not met.

4. Plant Support A. Current Performnce Plant Support remained good overall. In radiological protection, the most significant challenge was continued high station dose due to material condition improvement efforts. For example, in 1996, total dose was about 1000 rem, including 730 rem for outage activities. About 200 rem of the outage total was attributed to material condition issues.

In 1997, the estimated dose was 1200 rem, including about 900 rem for the outage. Some problems were also noted with radworker performance, specifically regarding control of contaminated areas, and with the oversight of radiation monitors. Additionally, an occurrence of 10

Quad Cities PPR 10/96 - 3/97 Pre-Decisional contaminated material generated at Quad Cities, but found offsite, was being investigated at the end of the period. Security performance declined somewhat, because of inattention to detail for activities related to vehicle searches, security barriers and fitness for duty.

However,- overall security performance was satisfactory. Fire protection activities were considered adequate. The station remained in 3 fire protection LCOs continuously due to inadequate fire pum) capacity, and other planned maintenance further increased overall ris( in this area.

A new IPEEE study showed fire to be a major (SE-3) contributor to external risk.

B. Assessment / Issues Radiation Protection Station dose continued to be high, as the plant addressed material condition problems. However, effective ALARA measures and control of work activities kept dose expended reasonable.

Station dose was about 1000 rem in 1996, including 730 rem for outage activities. About 200 rem of the outage total was attributed to emergent material condition issues. In 1997, the estimated dose was 1200 rem, including about 900 rem for the outage, primarily to address material condition (Inspection Observation,1/27/97).

Continuing efforts to address deficient material condition issues or to continue unit operation with these issues resulted in additional radiation exposure (IR 96017; 12/6/96)

A licensee post outage task force identified several weaknesses l with the work planning process that were similar to past NRC observations. Specifically, pred ous station and industry experience was not effectively used to identify emergent work and some known work was not appropriately identified (IR 96011; 10/10/96)

Radiological protection response ~to a spill was good (IR 96012; 9/14/96)

Some problems were noted with radworker performance, specifically in control of contaminated areas.

About 500000 dpm fixed contamination was found on scrap metal shipped to the Illinois Railway Supply Company from the Quad Cities plant. Additional contaminated material was also found on scrap metal sent to the North Star Steel Company in Wilton, IA.

This event was still being investigated by the licensee at the end of the assessment period (Inspector Observation, 2/24/97) 11

Quad Cities PPR 10/96 - 3/97 Pre-Decisional

• Several examples of failure to follow radiological procedures for posting / control of contaminated areas and radioactive material (IR 97003; 2/5/97) -

A licensee task force identified that poor radworker skills, a complicated work process and ineffective past root cause evaluations caused the majority of observed radworker performance events (IR 96011; 10/10/06)

• Owing to inattention to detail, a refueling crane operator

• snagged" an LPRM bringing it near the pool surface and alarming nearby area radiation monitors (Resident observation; 9/6/96)

Overall management oversight of the area radiation and continuous air monitors was in need of improvement (IR 97003; 2/5/97)

The Radiological Enviro.wnental Monitoring Program was well implemented (IR 96011; 10/10/96)

Emergency Preparedness Based on the observations of the Resident Inspectors and Phone Calls l with the EP coordinators performance has remained constant Security Security performance wts constant, but performance was challenged by personnel errors and weak oversight activities in the areas of fitness for duty, vehicle search and security barrier integrity.

A violation regarding an inadequate search of a vehicle. (IR 97004; 1/97)

A non-cited violation involving a failure to utilize the FFD call-in procedure by several supervisors. (IR 97004; 1/97)

A non-cited violation involving an inattentive security officer.

(IR 97004; 1/97)

A violation regarding an inadequate security barrier (IR 97004; 1/97)

Fire Protection Fire protection activities were considered adequate. the station remained in 3 fire protection LCOs r.ontinuously due to inadequate fire pump capacity. A new IPEEE study shoed fire to be a major contributor to external risk (SE-3). The station is addressing the high IPEEE contributor with short term modification to improve the overall risk to 12

, Quad Cities PPR 10/96 - 3/97 Pre-Decisional the E-4 level, however the station opted to perfonn travelling screen work which took one of tow fire pumps out of service for 20 days of a day LCO before the IPEEE modifications were completed. -

C. Future insoection Activities Continue with routine inspection program for radiation protection and security functional areas. Perform a fire protection inspection in mid 1997. Routine EP inspection is scheduled for March 30-April 3,1998.

Integrated Training Drill is scheduled for October 1,1997. Biennial EP Exercise is scheduled for the week of August 26, 1998.

111. future Insnection Activities Operations l Routine core inspection program.

Perform 40500 inspection.

l Maintenance Maintenance Rule inspection.

Engineering System Operational Performance Inspection (SOPI) or E&TS - May 1997.

Plant Support Routine program IV. Attachments

1. Plant Issues List

2. AE03 Performance Indicators

3. Power Hi. story Charts 13

PRE DECISIONAL SEMI-ANNUAL PLAkT PTRFORMANCE ASSESSMENT LASALLE STATION Assessment Period: October 1996 through March 1997 SALP Period: 08/04/96 - 11/22/97 Previous SALP Ratirg: OPS 3 ,

MAINT 3 ENG 3 PS 2 l 1. Performance overview Both LaSalle County Station units have remained shut down since '

Seatember 1996. Unit 2 had been shut down on September 20 for a scieduled refueling outage and Unit 1 shut down on September 22 due to a failed turbine control valve. In November the licensee decided to keep both u.its down to address equipment and human performance issues.

The licensee continues to struggle with operations drformance problems, an ineffective maintenance program, engineering wea(nesses, and a decline in radiological performance. Human performance weaknesses have been an obstacle that the licensee has been unable to correct, with poor procedures and a lack of procedural adherence the primary contributors to the problem. The licensee has not been effective at completing work i

to improve the plant material condition in a timely manner because of the existing procedural problems and human performance failures.

Subsequently, the inability to resolve material condition problems impacted some operator's perceptions to the point that problems were no longer being identified. Also compounding the problems at LaSalle are the failings of the corrective action program; LaSalle station has not consistently demonstrated the ability to fix known problems.

In addition, the design-basis has not effectively been maintained by the engineering organization, in some cases, the design change process was bypassed entirely and in others, design discrepancies were not understood or corrected. ,

Although the licensee has implemented performance improvement programs, their impact has not been evident. During recent interviews of plant persorinel, there seems to be a recognition of the problems and a willingness to improve performance. However, additional time is necessary to determine to what extent the improvement plans have addressed the problems.

l

• i

!!, Functional Area Assessments

]

A. OPERATIONS

1. Current Performance ,

i The licensee's perfomance in the operations area continues to be consistent

! with respect to the performance problems identified during the previous plant

performance review period. Operators continue to make errors, especially with i regard to procedural compliance and the out-of-service process. An initial

improving trend in control room operator performance is no longer discernable. i

Corrective action for plant problems may not always be initiated due to the l t

reluctance of operators to report problems while material condition problems

! continue to impact operators. Although the licensee has attempted to change

=

operator perfomance standards, problems continue to be identified. Outages  !'

J initiated in September 1996, were extended on both units to address material j condition, equipment design, and human performance problems.

l 2. Assessment /Issuas

! Degraded material condition continued to challenge operators until both units ,

were shut down in late September 1996, and to even some extent after the shutdown.

• On February 6, 1997, operator action was required to prevent over-4

. pressurization core spray system. of waterleg)

(96020 pump discharge piping on the high pressure

• In October 1996, inadequate cold weather preparations caused freezing ,

and the resultant rupture of several station heat supply coils on i reactor building ventilation, turbine building ventilation, and radwaste '

building ventilation. The ability to maintain heat to the buildings was a challenge throughout the winter months while replacement equipment was procured and installed. (96018)

• On September 17, 1996, a spurious reactor water cleanup isolation on high differential flow occurred. Reactor water cleanup (RWCU) isolations were a recurring problem that have not been resolved.

(96013) .

• On September 7, 1996, a reactor building ventilation control system . -

malfunction caused difficulty in maintaining required reactor building difforential pressure. -(96010)

• On September 6,1996, a failed strainer backwasti valve for emergency diesel generator '0' was a challenge to operators. (96010) i The quality of operations procedures continue to be a problem. Operator ,

errors were still occurring, especially in regard to procedural adherence and I the equipment out-of-service (005) process. Maprovement continues to be l limited. J

• On February 2, 1997, an operator failed to follow a fire protection surveillance procedure, resulting in a deluge of an unit auxiliary transformer. (96020)

• On January 31, 1997, ali uncontrolled waste sludge tank level increase occurred when an operator did not self-check and skipped steps in the procedure. (96020)

• Prior to January 21, 1997, operators failed to install and tighten bolts that helped secure cubicle doors to Division 3 switchgear frames, contrary to procedure. (96020)

• On December 27, 1996, an operator removed the wrong breaker from service while isolating a battery charger for maintenance. The operator failed to question a discrepancy between the 005 and the plant labeling.

(96020)

• On November 26, 1996, an operator did not have the procedure at the work site during testing of emergency diesel generator auxiliaries, contrary to licensee administrative requirements. (96018)

• On October 12, 1996, c)erators did not follow 005 instructions resulting in the wrong battery c1arger being de-energized. (96013)

• On September 28, 1996, an inadequate review of an 005 checklist resulted in a violation of Technical Specifications. When operators cleared an 005 ca an inoperable emergency diesel generator, they also lifted a portion of the 005 covering the primary containment vent and purge downstream isolation dampers to purge air filters. These dampers were required to remain deactivated. (LER 96008)

• On December 27, 1996, a control room operator was not using the most current revision of a procedure attachment to record surveillance test data. (96020)

• On October 30, 1996, the 480 Volt switchgear supply breakers to Unit 1, Division !! motor control centers (MCC) 136XI and 136X2 were in a degraded condition. Among other causes, operating procedures did not ensure that the mechanical trip interlock was disengaged when a breaker is racked into its cubicle. (96018)

Although some improvements in operator performance in the control room were

( identified during the previous PPR period, this area continues to be a concern. Late in the PPR period the licensee initiated performance improvement plans. However, additional time will be required to asses the impact of these improvement plans, 4

• On February 6, 1997 a control room operator and unit supervisor were unawareofactionsImplementedduringaresidualheatremoval(RHR) surveillance and did not expect a resulting alarm that was received. A control room operator was also not aware of the RHR configuration and its basis when questioned by an inspector. (96020)

• On February 6,1997, perfonnance of a non-licensed operator did not meet  ;

l licensee management expectations during a control room shift briefing.

The operator was unable to comunicate work priorities, equipment status, or problems to be resolved. (96020)

• On January 22, 1997, during interviews some operators stated that they l did not have confidence in the ability of the licensee's formal problem identification and resolution process to fix identified problems. As a result, these operators did not use the process. (96020)

On September 19, 1996, control room operators failed to follow the general procedure for unit shutdown and to initiate a procedure change reflecting the actual shutdown process used. Operators shifted recirculation pumps to slow speed using the instrument sueveillance procedure versus the applicable operating procedure. (Fo013)

3. Actions / Recommendations Continue with the core inspections for the operations area, with increased f emphasis on field observations of control and auxiliary 21 ant operator performance. Continue to monitor outage activities as tiey impact-the operations area. Perform restart assessment inspection before startup of either unit.

B. MAINTENANCE

1. Current Performance Licensee efforts to improve the work control process following the June 1996, service water tunnel event have not been effective. Maintenance personnel have bypassed formal work controls, failed to follow procedure on multiple occasions, and demonst. rated poor work practices. Both surveillance and maintenance procedures / packages continued to be problematic.

i

2. Assessment / Issues Poor surveillance procedures have caused problems, in some cases resulting in i eculpment being declared inoperable when testing requirements were not acequately incorporated into procedures.

• On February 6,1997, the NRC identified that the residual heat removal pump inservice test surveillance procedure did not ensure that a repeatable reference flow rate was used as required by the ASME code.

(96020)

• On November 26, 1996, the NRC identified that no acceptance criteria for evaluating a potentially degraded air start motor existed in the monthly emergency ciesel generator slow start surveillance . (96018) '

On November 27, 1996, the licensee declared the diesel fire pumps inoperable because surveillances were not performed at required frequencies due to a procedural problem. (Special Report)

• On October 10, 1996, the licensee determined that emergency diesel generator fuel oil was not analyzed in accordance with Technical Specifications due to procedure deficiencies. Verification of kinematic viscosity for new fuel was not dc,ne on-site and analysis of old fuel not always done at the correct frequency. (LER96013)

The quality of maintenance procedures and work packages continues to be satisfactory for most jobs, although in some cases poor procedures cause inoperable equipment or delays in completing work.

• In February 1997, the licensee temporarily suspended General Electric (GE) electrical control switch replacement due to inconsistent work methods, testing procedure problems, and receipt inspection deficiencies.

On October 30,1996, the 480 Volt switchgear supply breakers to Unit 1 Division !! MCCs 136XI and 136X2 were in a degraded condition. Among other causes, the electrical maintenance procedure did not ensure that the mechanical trip interlock was disengaged when a breaker is racked into its cubicle. (96018)

• On October 23, 1996, GE performed liquid-penetrant examination on the incorrect high pressure. core spray safe end to reactor nozzle weld due poor lighting and a work sackage which did not specify the weld location. As a result, tie licensee conducted a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inservice inspection standdown. (96017)

• On October 10. 1996, workers identified that a freeze seal maintenance procedure did not contain sufficient information to perform the task. A maintenance first line supervisor attempted to resolve the problem by explaining the intent of the procedure rather than seeking 7 formal work package clarification or procedure revision. (96013)

• On October 2, 1996, documentation in the rework package for the reassembly of the '0" emergency diesel generator service water strainer was not thorough, representing an impediment to good root cause analysis. (96013) .

personnel performance errors, including failures to follow procedure and poor -

work practices by maintenance personne', continue.

• On October 10, 1996, the NRC identified several plant housekeeping conditions that had the potential to adversely impact plant operations, such as the use of duct tape where it eculd interfere with valve operation. (96013)

• On October 9,1996, a failure to follow work request instructions resulted in installation of jet pump plugs in the wrong reactor

. recirculation loop. A fuel handling supervisor continued with jet pump plug installation even though he was aware that a required drawing was missing from the work package. ( Also has potential radiation l protection connections) (96013)

• On October 2,1996, a failure to follow procedure during reassembly of the "0" emergency diesel generator service water strainer resulted in excessive leakage of a strainer backwash valve, necessitating rework.

(96013)

• On September 29, 1996, maintenance workers failed to follow work practices required by fire protection procedures for ensuring a safe welding environment. The NRC identified combustibles in the welding work area. (96013)

Corrective actions continue to be weak for the maintenance work process and specific equipment problems. The site Quality Verification organization has had a Corrective Action Recuest open on the ineffective corrective action program since late 1993 anc the station has not demonstrated the ability to fix the problem.

On February 4,1997, site quality verification personnel determined that an improperly disabled . fire door demonstrated continued programmatic deficiencies with the work control process, similar to those noted during the service water tunnel event. Licensee corrective actions had not been etfactive in addressing the work control process issue.

(96020)

On October 30,1996, the 480 Volt switchgear supply breakers to Unit 1, Division 11 MCts 136X1 and 136X2-were in a degraded condition. The licensee had failed to take timely corrective action for a similar event in July 1995. (96018)

• On October 16, 1996, the licensee identified substantial foreign

-( material in the silt layer of the Unit 2 suppression pool that hPd the potential to clog emergency core cooling system strainers. Previous cleaning of the suppression pool in response to NRC Bulletin 95-02 had .'

not been adequate. (96013/95018)

3. Actions /Recomendations Continue to perform routine core and regional initiative inspection with emphssis on work planning and control. Place increased emphasis on direct observation of maintenance and surveillance activities.

C. ENGINEERING l

1. Current Perfomance A decline in engineering performance became evident during the previous assessment period following a service water event in which foam sealant was inadvertently injected inte the safety-related service water tunnel.- In-addition, problems identified by the NRC in the previous period during a service water system operational performance inspection indicated significant problems existed in the engineering area. A Comed-sponsored Independent Self Assessment bolstered this(ISA)iew.

- v conducted by a group of nuclear experts and industry peers On September 20.-1996, the licensee shut down Unit 2 for a planned refueling outage. On September 22, the licensee shut down Unit 1 and initiated a forced outage due to a fatiure of the No. 4 turbine control valve. On November 19, the licensee decided to keep both units shut down to address equipment and human performance problems.

During this assessment period, the licensee implemented a Restart Plan to address recent problems, identified as a result of the service water event.-

NRC inspection activities, and the ISA. At the end of the period, a dedicated region-based NRC inspector was assigned to review the implementation of the engineering aspects of this plan as well as monitor and assess overall engineering performance.

2. Assessment / Issues Additional examples cf probisms identified in the last period continued to occur and are discussed below.

Engineering problem-identification and documentation were poor.

• In March 1996, the licensee discovered that certain air-operated valves (A0V) would not close under design basis dynamic loads. However, the inspectors determined that the problem had not been formally documented by a PIF and had not received a formal operability assessment as required by plant procedures. As a result, 1icensee actions to adequately recognize the significance of Land address this problem were not initiated until recently. (96016 - included in last PPR)

'I Some positive examples were identified during the assessment period.

• On February 2, 1997, the licensee identified a potential unantlyzed condition regarding snow accumulation on control room (CR) and auxiliary .

electric equ'pment room (AEER) filters rendering control room ventilation (VC) and AEER ventilation (VE) inoperable. (ENS)

~

• In January 1997, the licensee identified crack indications on two Unit 2 jet pump risers.

• On December 17, 1996, the licensee identified that residual heat removal service water failure of the(RHRS'J) division 2 was nonsafety-related dikeoutside its design could lower lake basis level because i sufficiently to cause a water hammer and render RHRWS inoperable.

• On November 4, 1996, the licensee identified that RHR pump seal coolers failed to meet design pressure requirements.

Weak and inadequate root cause analysis and inadequate and untimely corrective actions continued to be a problem.

• An apparent violation was identified for the licensee's failure to take appropriate corrective action for degradation of safety-related-single block module (SBM) electrical control switches due to hydrocarbon exposure and excessive age. Although concerns were identified in 1979, -

1990, and 1995, adequate corrective actions were not initiated until problems were encountered during a downshift of a reactor recirculation pump in 1996. (9c018)

The design control process was not always properly used to control design changes.

From late 1995 until October 1996, minor modifications were performed on

-systems and components using Nuclear Design Information Transmittal (NDIT) forms rather than the process defined in station procedures.

Some of.these minor modifications did not have written safety screening evaluations as required by station procedures. (96019)

• The licensee recently identified that a modification to the actuation logic for the Main Control Room Atmospheric Control System (MCRACS) in 1993 introduced a unrFiewed safety question since the system no longer met single failure c t eria. (96020)

Multiple differences between plant equipment and the system descriptions in the UFSAR were not identified and corrected.

The licensee failed to conduct adequate testing to demonstrate that the control room and auxiliary electrical equi ment room (AEER) ventilation systems would operate as specified in the JFSAR and TSs following a design basis accident. Three apparent violations were identified for this condition which existed since initial plant startup. Two of the apparent violations regarded inadequate tests (pre-cperational and 1984 J

4 post-modification) which resulted in missed opportunities to identify

, this problem earlier. The third apparent violation regarded an inadequate ventilation system surveillance which failed to verify that the control room ventilation system could maintain all areas adjacent to the control room at a positive pressure. (96018)

Engineering operability evaluations were poor and contained inaccuracies.

• The inspectors identified that the licensee's implementation of Gl. 91-18 guidance was overly reliant on Technical Specification (TS) surveillance test results for operability determinations. (96016 - included in last PPR)

3. Actions / Recommendations Continue to perform routine core and regional inspection of engineering.

Utilize the dedicated region-based engineering inspector to monitor and assess l the effectiveness of the licensee's engineering organization, including the implementation of the engineering aspects of the restart plan. Perform restart assessment inspection before startup of either unit.

D. PLANT SUPPORT

1. Current Performance Plant support performance remained constant. In Radiation Protection, a decline was noted as issues were identified with problem identification and resolution and with radiation worker practices, in particular, the failure to take adequate corrective actions for well known industry concerns associated with the removal of irradiated components from the reactor vessel and with work in high noise areas resulted in increased radiological risk to workers on two separate occasions. Station dose for 1996 was 819 rem, including about 154 rem for emergent material condition issues. Although this dose was reasonable for the work performed, there were some problems identified with ALARA planning and worker self-check which resulted in additional dose.

Additionally, there continued to be examples of poor radworker performance.

Although individually these events were of a minor nature, their recurrence  !

indicated that corrective actions have not been sufficient to ensure long tem improvement. In Security, performance was constant and considered good.

Although there were no inspections in the Fire Protection and Emergency Preparedness areas, resident observations indicated that performance was constant and good in these areas.

t