ML20137C876
| ML20137C876 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/20/1997 |
| From: | Jamila Perry COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| JSPLTR-#97-0058, JSPLTR-#97-58, NUDOCS 9703250154 | |
| Download: ML20137C876 (18) | |
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Dresden Generating Mation 6500 North Dresden Itoad Morris 11.60150 Tcl 819)12 2920 March 20,1997 JSPLTR #97-0058 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Dresden Station Units 1,2 and 3 Systematic Assessment of Licensee Performance (SALP 14)
NRC Docket Nos. 50-10,50-237 and 50-249
Reference:
(1)
A. Bill Beach letter to J.S. Perry of February 10,1997, 4
transmitting Dresden Station SALP 14 Report 50-010, 237, 249/96001 (2)
J. S. Perry letter to H. L. Thompson of January 13, 1997, Interim Response to Dresden Independent Safety Inspection Report 50-237/96-210, 50-249/96-201 (3)
J. S. Perry letter of February 28,1997, Dresden Station's Verification of Key Parameters for Twelve Risk Significant Systems (4)
A Bill Beach letter to J.S. Perry of November 21,1996.
4 Confirmatory Action Letter (5)
J. S. Perry letter of December 30,1996, Dresden Station Improvement Plans and Progress.
(6)
J. S. Perry letter to A. Bill Beach of November 8,1996.
(7)
J. S. Perry letter of February.26,1997, Dresden Station Response to Independent Safety Inspection Report 50-237/96-210,50-249/96-201 The purpose of this letter is to respond to reference (1), the SALP 14 Report.
Reference (1) covered the period of March 19,1995 through December 28,1996. In a public meeting on February 21,1997, held at the Dresden Training Facility, NRC and Comed management met to discuss the report.
Dresden management is pleased that the SALP Board recognized that the improvement initiatives implemented during the SALP 14 period had resulted in overall improved C3003G performance, and significantly improved performance in the Operations area. For example, the Board attributed the significant improvement in the Operations area to f(
the implementation of effective performance standards, improved procedural adherency by control room operators, and strong management support of conservative decision making by keeping the plant shutdown on several occasions until root causes and
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'USNRC Page 2 March 20,1997 corrective actions could be implemented. Similarly, we were pleased that the Board acknowledged that good performance in chemistry, emergency preparedness, and fire protection, and improved performance in the control of personnel exposures and contaminated areas were indicative of successful improvement initiatives in the Plant Support area. The Category 2 ratings in these areas accurately reflect Dresden's performance in these two areas.
The SALP Board also noted improvement in engineering support to plant operations, particularly the support from system engineers, the engineers' capabilities, and the allocation of resources to improve material condition and reduce backlogs. However, a number of weaknesses remain that led the Board to a Category 3 rating in the Engineering area. These weaknesses include: (1) the adequacy of plant design basis documents and calculations; (2) the inconsistent quality of engineering work; (3) the inability to resolve some long-standing design problems; and (4) the lack of aggressive resolution of some nonconforming conditions. The plans to meet these challenges were provided to you in references (2) and (3) and the status meetings that resulted from reference (4), the Confirmatory Action Letter (CAL), and reference (5), the Dresden Improvement Plans. These initiatives are summarized in Attachment B to this letter. We will continue to keep you advised of our progress in the Engineering area through the meetings and letters specified in the CAL.
While Dresden accepts the comments in the SALP Report related to our performance in Operations, Plant Support, and Engineering, we believe our overall performance in Maintenance area merited a Category 2 rating, particularly when considering the Category 2 rating received in SALP 13 and the performance improvement achieved throughout the SALP 14 period. We discussed this conclusion at the public meeting and committed to provide the basis for our position.
Dresden believes that while challenges remain, overall performance improvement was achieved in the Maintenance area during the SALP period. For example, the progress reflected in objective performance indicators such as Control Room Work Deficiencies, the percentage of rework activities and the industrial safety accident rate provide direct evidence that our maintenance related improvement initiatives have been successful. Indirectly, many improvements in plant material condition contributed to improved performance in other SALP areas, including upgrades to the feedwater level control system, installation of the station blackout modifications, reductions in operator work arounds and temporary alterations, replacement of the Unit 2 reactor water cleanup system piping and heat exchanger, and opening of the bottom head drain after numerous years of operation on Unit 2. These improvements, described in detail in Attachment A, could not have been achieved without improved maintenance support.
Accordingly, Dresden requests the NRC to reconsider its rating in the Maintenance area.
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4 USNRC Page 3 March 20,1997 In making this request, we fully understand and acknowledge that Dresden's performance in the Maintenance area is not as strong as the operating area and that continued improvement is necessary to achieve and maintain our performance goals that we have set for ourselves. Therefore, we are progressing in the implementation of actions to ensure continued improvement in the Maintenance area. For example, because the volume of emergent work has reduced the effectiveness of our other maintenance related improvement initiatives, a review was performed to identify the systems most frequently contributing to emergent work. This review concluded that a significant portion of the emergent work was attributable to two systems, Fire Protection and Off-Gas. Based on this result, resources can be allocated directly to these systems, thus increasing the effectiveness of our actions. We have also initiated changes to improve work management and the Inservice and Post Maintenance Test Programs. These efforts will ensure continued improvement in the Maintenance area.
In summary, we appreciate the recognition by the SALP Board that Dresden has sustained overall improved performance through the SALP period. We believe that this improvement was broad based, including the Maintenance area. As a result, the SALP rating for the Maintenance area should not have decreased from that received in SALP 13. At the same time, we clearly understand that we need to devote additional attention, particularly to maintenance and engineering, in order to fulfill our commitment to long term performance improvement.- As described in the attachment, initiatives to fulfill this commitment are underway.
If you have any questions concerning this issue please contact me at (815) 942-2920, ext. 3600 i
Sincerely, J: Stephen Perr}y l
Site Vice President Dresden Station Attachments (2) cc:
A. Bill Beach, Administrator USNRC Region III J. F. Stang, Project Manager, NRR 1
D. Roth Acting Senior Resident Inspector, Dresden Station Office of Nuclear Facility Safety -IDNS i
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ATTACHMENT A DRESDEN STATION SALP 14 RESPONSE MAINTENANCE / WORK CONTROL i
While the SALP Board noted that many improvements in plant materiel condition were made over the SALP period, the Board concluded that a Categerv 3 rating in the Maintenance area was appropriate because overall plant performance conticued to be challenged by persistent weaknesses rooted in materiel condition, work control, test control, and the quality of some maintenance activities.
While Dresden accepts the comments in the SALP Report, we believe our performance in the Maintenance area merited a Category 2 rating, particularly when considering the Category 2 rating received in SALP 13 and the performance improvement in the Maintenance area achieved during the SALP 14 period. We discussed this conclusion at the February 21,1997, public meeting and committed to provide the basis for our position. We were also requested in the SALP Report to provide a response describing the planned corrective actions to improve performance in the Maintenance area.
i Below are described the performance results and material condition improvements that we believe warrant assigning a Category 2 rating for Maintenance. However, we also understand that weaknesses remain, particularly in the area of Work Control, Materiel Ccndition, Surveillance and Test Control, and the overall quality of maintenance activities. Our actions to address these areas are also discussed.
A.
SUMMARY
OF PERFORMANCE IMPROVEMENTS l
General Maintenance related performance measures provide objective evidence which demonstrates that Maintenance performance improved substantially from the SALP 13 period. Specifically, the non-outage corrective maintenance backlog was reduced from 1816 tasks in 1994 to 946 tasks at the end of 1996; the rework rate was reduced from 4.13 percent in 1995 to 3.5 percent in 1996; and total unplanned LCO and DATR days was reduced from 13.8 in 1995 to 9.8 in 1996.
Non-maintenance related performance measures that depend on Maintenance performance provide confirmation of Maintenance performance improvements.
Specifically, the Comed employee industrial safety accident rate decreased from 2.2 in 1994 to 0.9 in 1996; total LERs were reduced from 55 in 1994 to 38 in 1996; materiel condition LERs were reduced from 30 in 1994 to 19 in 1996; personal contamination events was reduced from 300 in 1994 to 60 in 1996; and collective radiation exposure was reduced from 833 person-Rem in 1994 to 412 person REM in 1996. Inasmuch as Maintenance activity accounts for nearly 90% of the total exposure, significant strides 1
ATTACHMENT A DRESDIN STATION SALP 14 RESPONSE MAINTENANCE / WORK CONTROL were made by Maintenance in the area of exposure control. All of these performance improvements could not have been achieved without corresponding improvement in maintenance performance.
f Operator Work-Arounds and Control Room Deficiencies SALP 14 reports a significant reduction in the control room deficiencies and Operator work-arounds. Specifically, new operator work-arounds were reduced from 109 in 1994 to 55 in 1996. Dresden closed 80 operator work-arounds in 1995 and an additional 44 in.1996.
While a number of work-arounds remain, it must be noted that the threshold for work-arounds has been substantially reduced during the period. A number of the current work-arounds identified by plant personnel would not have been recognized as such during the previous SALP period.
Control room work deficiencies was reduced from 218 in 1994 to 25 in 1996 by completion of 880 control room work requests during the period of March 1995 to September 1996. This included the correction of many long standing deficiencies.
The number of temporary alterations was reduced by 65 in 1996.
Materiel Condition While materiel condition continues to challenge the station, significant progress was made in improving materiel condition during the period in comparison to SALP 13. In comparison, SALP 13 described, " Limited material condition improvements.. "
As noted in the SALP 14 report, "Many improvements in plant material condition were made over the assessment period..." These included:
Overhaul of the 4kv switchgear breakers and cubicles.
Cleanup of the Reactor Building Equipment Drain Tank Rooms.
Clean out of the Unit 2 Reactor Bottom Head Drain.
Upgrade of the instrument air compressors.
Clean up of the Unit 2 Low Pressure Heater Bay.
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ATTACHMENT A DRESDEN STATION SALP 14 RESPONSE MAINTENANCE / WORK CONTROL Installation of clean demineralized water diesel pumps for isolation condenser make-up.
New design for the Reactor Recirc Pump Seds.
Overhaul of the Crib House Travelling Screens Upgrade of the Lift Station.
Installation of the Zinc addition Modification on Unit 2.
Installation of the shielded reflective insulation to Unit 2 Recirculation System piping.
Upgrade of the Control Room Heating Ventilation and Air Conditioning System.
Upgrade of Control Rod Drive Gallery steel on both units.
Repairs to Unit 2 core shroud.
Cleaning and desludging of the Unit 2 torus.
Removal of the Unit 2 Recirc Pump Discharge Valve bypass lines.
Upgrade to the LPCI Corner Room Steel on each unit to meet the UFSAR stress limits.
Cleaning and inspection of all Unit 2 Condenser tubes.
Improvements to housekeeping throughout the plant.
As a result of these improvements, Dresden Unit 2 has been on-line over 200 days, which is a record for that unit.
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ATTACHMENT A DRESDEN STATION SALP 14 RESPONSE MAINTENANCE / WORK CONTROL Preventative Maintenance The Station reduced the backlog of past critical preventive maintenance items from 447 on January 8,1996, to zero by April 30,1996. In addition, a process is in place to authorize and track extensions. Over 5000 recommendations have been generated as the result of a bottom-up review of the preventative maintenance program, and the Station is currently acting upon them.
Programs and Procedures The SALP 14 report also notes the continuing challenges facing the work control and maintenance processes, but the OOS violations or wrong unit / wrong train events noted in the previous SALP period have been reduced over the past two years. A review of the PIF database and trend data for 1996 reveals only one instance in which a maintenance individual self-identified that he started work on the wrong component (a temperature element). In addition, there have been no violations of the OOS program by Maintenance in the last six months.
Communications While the SALP 13 report noted numerous problems caused by informal communication; SALP 14 noted, significant improvement in control room l
communications from all station personnel.
Instrument Mechanics (IMs) now use three-way communications with Operations personnel during their plant activities. In all of 1996, there was only one Performance Improvement Form (PIF) in which an unexpected alarm was received as a result of IMD work in the field.
Problem Identification During 1996, Maintenance personnel wrote 1830 PIFs, nearly one-third of the Station total. The SALP 14 Report was critical of the problems with Control Room Ventilation, deficiencies in the Inservice Testing (IST) Program, including failure to test the IIPCI 2/3-2300-20 valves, and failures of the 4KV breakers. All of these conditions were self-identified by Station personnel through the PIF process.
Of 532 Maintenance Department corrective actions and commitments tracked by the Nuclear Tracking System (NTS), only one was late.
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ATTACHMENT A DRESDEN STATION SALP 14 RESPONSE MAINTENANCE / WORK CONTROL Self Assessments The Maintenance Department conducted self assessments in the following areas:
Rework Measuring and Test Equipment Procedure Adherence Foreign Material Exclusion (FME)
These assessments have been extremely valuable because they identified numerous performance improvement initiatives for these programs. For instance, despite the fact that no FME events occurred during the last five months of 1996, numerous actions were identified to strengthen the program.
Testing
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While a number of testing deficiencies were noted during the SALP period, it was a rigorous testing program during the 4KV breaker outage, which resulted in Dresden's identification of the design deficiency associated with not only the original actuating mechanism for the breaker auxiliary contacts, but also with the vendor's upgraded model as well. As a result, actuating mechanisms from a new vendor were placed in all the breakers.
Conclusion In summary, the Maintenance Department improved in a number of important areas.
At the same time, the improvement in Maintenance performance directly supported the improvement in Operations and other plant areas noted in the SALP 14 report. The significant upgrade in materiel condition, notable reductions in operator work-arounds, control room deficiencies, and temporary alterations, improved adherence to procedures and vastly irnproved communications, all contributed to the significant performance improvement that Operations achieved. The numerous Maintenance related improvement initiatives implemented during the SALP period were effective and resulted in substantially improved Dresden's overall safety performance over the SALP 13 period. The Maintenance related performance measures and actions demonstrate that overall performance in the Maintenance area improved during the SALP 14 period. While deficiencies continue to exist, Dresden's programs and 5
ATTACHMENT A DRESDEN STATION SALP 14 RESPONSE MAINTENANCE / WORK CONTROL procedures are providing the necessary control of activities to sustain performance improvements. Self assecsments have been good, and their evaluation of the root causes of problems have resulted in numerous improvement initiatives. Although some corrective actions are not complete, they are usually effective as demonstrated by the objective performance measures. Therefore, the Maintenance area should be rated as Category 2.
B.
PLANNED ACTIONS TO ADDRESS WEAKNESSES IN MAINTENANCE AREA The following summary of planned actions to address weaknesses in the Maintenance area is provided in response to the SALP Report.
Maintenance / Work Control While we believe sigui6 cant improvements have been achieved, as described in the SALP 14 report, many challenges remain.
The following actions were taken to improve implementation of the twelve-week schedule:
Craftsmen now walk down the work packages prior to starting work.
When possible, work packages are pre-approved by Operations.
Supervisors are assigned specific work packages on the schedules Ove weeks prior to the execution week.
Weekly accountability meetings ensure that expectations for planning and schedule adherence are clearly understood.
Senior Reactor Operators are now involved in the planning process to ensure that scheduled work does not con 6ict with current plant con 6guration.
Life cycle planning has been initiated to ensure that all preventive maintenance and surveillance items during the cycle are captured on the schedule.
Daily and weekly schedule adherence is now tracked.
Schedule non-compliances are identiGed and tracked.
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ATTACHMENT A DRESDEN STATION SALP 14 RESPONSE MAINTENANCE / WORK CONTROL Monitoring tools have been developed to analyze the twelve week work process.
The Work Control and Maintenance peer group, representing all sites, meets periodically to define roles and responsibilities for the twelve week work process.
i A Nuclear Station Work Procedure (NSWP) has been implemented to prioritize emergent work and to establish tools to track emergent work.
Goals and monitoring tools have been established to equalize resources.
The key to effective work control is schedule adherence. This will be realized when scope stability is achieved from week 5 to week 1. Additional rigor has been added to the process to be sure that only jobs which are ready in all respects remain on the schedule after week 5.
Emergent work is always the critical element in maintaining schedule adherence. The Fix It Now (FIN) team has been refocused to address emergent work. This will allow the Maintenance shops to concentrate on scheduled work, except for emergent work beyond the capability of the FIN team.
Quality of Maintenance Activities While the SALP 14 Report noted improvement compared to SAL ~P 13, the quality of work and rework remain a significant issues. The Maintenance Department has embarked on a major training initiative to change the culture of the Department and to significantly upgrade the skill and knowledge of all members of the Department. In the past, Maintenance had little operations experience and continuing training was not meeting the needs of Maintenance personnel. As a result, the following actions were taken:
The Department training task matrix has been revalidated.
The task analysis for each matrix has been reperformed.
The frequency of continuing training has been determined for each task.
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ATTACHMENT A DRESDEN STATION SALP 14 RESPONSE MAINTENANCE / WORK CONTROL l
Each craftsman is enrolled in a four-cycle training program with a total of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> minimum per person (significant increase over prior years).
The supervisors attend training with their crews.
Supervisors now attend Management Action Requirements Checklist (MARC) training, a training prograin to improve the supervisors' interaction with bargaining unit personnel..
A plant certification course has been developed for Maintenance first line supervisors.
Maintenance Superintendents are attending an SRO certification course.
First line supervisors meet weekly with the Maintenance Manager to review standards and expectations.
A comprehensive, specialized training program has been developed to limit the amount of rework and to reduce the Stations dependence on vendor representatives and contractors. The following training is included in this effort:
1 Diesel Engines Air operated valves: flow scenning n
Freeze seals Turbine supervisory equipment n
Feedwater logic control Electro-hydraulic control systems (EHC) n VOTES testing of motor operated valves n
Heating ventilation and air conditioning (HVAC) n Valve Maintenance.
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f ATTACHMENT A DRESDEN STATION SALP 14 RESPONSE 4
MAINTENANCE / WORK CONTROL Surveillance and Test Control t
A number of changes were made to test control which are listed below:
1.
The modification control procedure was revised to include a requirement that the Design and Plant Engineering Superintendents agree on the assignment of Test Engineers for complex modifications.
2.
The Test Engineer role requires a formal qualification based on a certification guide.
3.
The qualification card for the Test Director includes the position of Test Engineer.
4.
A procedure was developed to provide guidance on modification testing.
Surveillance tests and preventative maintenance activity are included in the twelve week work schedule.
Changes to the surveillance schedule are controlled by Station procedure.
j Materiel Condition Materiel condition improvement remains a key to the success of the Station.
Although the SALP identified this as a Maintenance responsibility, improvement of the materiel condition involves several departments. The increased standards of Plant Operations in recognizing and demanding resolution of deficient conditions is important. The plans of Engineering to assure the quality of Engineering work and resolve long standing problems contribute to this effort. As noted in this attachment, the plans of the Maintenance Department to improve the work control process and schedule adherence are important the ultimate improvement of plant materiel condition. The PIF process, which requires screening of all PIFs by senior management, provides assurance that even subtle precursors of major problems will be recognized. Finally, the " conservative decision making process" keeps everyone at the Station focused on finding the root cause of problems and effectively correcting them.
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ATTACHMENT B DRESDEN STATION SALP 14 RESPONSE ENGINEERING While the SALP Board noted improvement in engineering support to plant operations, a number of weaknesses were identified that led the Board to a Category 3 rating in the Engineering area. As a result, Dresden was requested to provide the NRC with a response to the SAI.P Report that describes the planned corrective actions to improve performance in the Engineering area. This Attachment constitutes that response.
Despite the Category 3 rating, Engineering made significant contributions to the materiel improvement at Dresden.
Engineering was closely involved with the substantial reduction in operator work-arounds, control room deficiencies, and temporary alterations previously noted.
The backlog of"old Modifications" was reduced from 239 in September 1995 to 21 at the end of the SALP period.
The configuration management, drawing revision, and Engineering Request backlogs were considerably reduced.
Engineering played a leading role in the materiel condition improvem' :s noted in Attachment A. Additionally, other noteworthy accomplishment are as follows:
A new testing methodology was developed for testing the main n
generator stator rotor during the leak repair project.
Engineering led the major repair effort for the Unit 3 turbine blade replacements in the summer of 1995.
Engineers were the Project Manager and Team Leaders for the 4KV breaker and cubicle overhauls.
Engineering prepared a very conservative 50.59 safety evaluation for the n
Unit 3 recirculation Pump Motor repair.
The Colored Window Report was developed by the Department to graphically illustrate key plant status indicators and communicate this information to station management.
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ATTACHMENT B DRESDEN STATION SALP 14 RESPONSE ENGINEERING The weaknesses in the Engineering area discussed in the SALP report were generally identified or confirmed during the Independent Safety Inspection. The plans to meet these challenges were provided to you in reference (2) and (3) and the status meetings that resulted from references (4) and (5). These initiatives are summarized below:
PLANNED ACTIONS TO ADDRESS WEAKNESSES IN ENGINEERING Maintenance of Design Base Documents Maintenance of the design base documents (DBD) is recognized as a key element of safe plant operation. Reference (6) committed to a number of actions to improve control of the DBDs and ensure their accuracy. These actions have been u viewed in some detail with your staff on a monthly basis since December 1996 These actions include the following:
1.
A screening of the key parameters of the twelve systems most critical from a risk perspective was completed in February 1997 and the results communicated to you by reference (3).
2.
Design basis and calculation validation or reconstitution will be performed on six of the twelve systems by the end of 1997 and the others by the end of 1998.
3.
DBDs for the twelve systems will be revised and/or updated in parallel with the validation / reconstitution efforts for the systems. The remaining DBDs will be revalidated and revised in accordance with reference (6).
4.
The Updated Safcty Analysis Report (UFSAR) requirements will be compared to the DBDs.
5.
A Nuclear Engineering Procedure on control of calculations has been revised to provide explicit directions for review, control, reconstitution, or verification of calculations affected by new modifications in accordance with reference (2).
6.
Indices are being developed for the new population of AE generated calculations.
7.
Dresden will take control of calculations identified as "Important to Safety" 8.
Enhanced indices of calculations identified as "Important to Safety" will be developed.
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ATTACHMENTB DRESDEN STATION SALP 14 RESPONSE ENGINEERING Assurance of the Quality Work i
A number of actions are underway to upgrade the quality of engineering work. These items are described in detail in references (2), (6), and (7). These include the following actions; i
1.
The Dresden Engineering Assurance Group is now in operation.
2.
A number of Architect Engineers (AE), vendors, and Nuclear Steam Suppliers are being audited to determine the quality of DBDs and the systems in place to control them.
I 3.
The weekly performance review meetings for Engineering which begun in June 1996 will be continued. These meetings review the status of system improvement plans, projects, and programs.
4.
Engineering Performance Improvement training will be implemented in 1997 for the purpose of reinforcing improved standards and expectations for i
engineers.
5.
A three year plan, which will focus on activities to improve responsibility, responsiveness, and professionalism of the Engineering Department,is being I
developed.
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An Engineering Standards and Expectations Handbook will be issued this year.
It will clearly describe standards and management expectations for Engineering Department personnel.
7.
The Nuclear Division has developed a new procedure to standardize the safety evaluation and screening process across the Division.
8.
Manuals controlled by the Vendor Technical Information Program (VETIP) will be placed under control of Central Files later this year.
Resolution of Long Standing Problems Despite significant improvement in plant materiel condition as described in reference (1), many challenges remain for Engineering in this area. There are three phases to the resolution of long standing problems. The problems need to be identified, the root cause of the problems must be determined, and the corrective actions must be taken.
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ATTACHMENT B DRESDEN STATION SALP 14 RESPONSE ENGINEERING l
Identification of the Problem 1.
Refinement of the PIF process is continuing. A standardized corrective action program is being implemented throughout the Nuclear Operations Division.
This program contains uniform criteria for PIF initiation.
2.
The Materiel Condition Improvement Program (MCIP) is a specific program to identify latent materiel condition problems for Engineering.
3.
Increased attention to the preventative maintenance program ensures timely identification of potential deficiencies. The backlog of preventative maintenance items is currently zero.
4.
Elimination of control room deficiencies, operator work-arounds, and temporary alterations has a direct impact on plant operations.
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Continued concentration on Engineering Request backlog reduction is another important element of problem identification.
Determination of Root Cause 1.
Increased emphasis and refinement of the root cause determination process is ongoing. Only those with specific training will be permitted to perform root cause determinations.
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Upgrade of the safety analysis and review process permits only specifically qualified personnel to conduct safety reviews and requires that they be reviewed by designated individuals.
Implementation of Correctlye Action 1.
Once a project to correct a deficiency is approved, it will be integrated in the Operational Plan (Business Plan) for the Station. This ensures that resources will be budgeted for that project.
2.
Vigorous Management oversight of the Nuclear Tracking System (NTS) ensures that corrective actions are completed on schedule.
3.
The standardized Corrective Action Program contains specific provisions to ensure the overall effectiveness of corrective actions.
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P ATTACHMENT B DRESDEN STATION SALP 14 RESPONSE ENGINEERING Identification of Performance Deficiencies and Technical Errors The following initiatives to enhance identification of deficiencies and errors are described in reference (2). These were revised following the ISI to correct deficiencies in these programs. Additional improvements are now being made to the first four items listed below:
1.
A new Corrective Action Program will be implemented in April 1997.
2.
The Station self assessment procedure has been revised.
3.
The Integrated Reporting Process Procedure has been revised to provide concise direction for site personnel regarding PIF initiation.
4.
The Corrective Action Effectiveness Review Procedure has been revised to ensure that ineffective corrective actions recci ve appropriate management attention and follow-up.
5.
The applicable Engineering Department procedures have been revised to clearly describe management expectations for the generation of PIFs within the Engineering Department. This includes specific guidance regarding potential design basis discrepancies.
6.
Several Senior Engineering Department people have been designated to conduct in-line reviews of all safety evaluations.
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Conclusion:==
Engineering has made major contributions to the materiel condition improvement of the Station. It is recognized that challenges remain, but comprehensive plans are in place to address this.
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' USNRC Page 4 March 20,1997 bec:
Regulatory Services Manager (Hard Copy)
Nuclear Licensing Administrator Comed Document Control Desk Licensing (Hard Copy) l Comed Document Control Desk Licensing (Electronic Copy)
Dresden Regulatory Assurance, CHRON File Dresden Regulatory Assurance, Subject File, SALP Dresden Regulatory Assurance, SALP 14 Regulatory Commitment Book SVP Numerical file Russ Freeman Preston Swafford Steve Barrett Terry Riley i
Gary Abrell i
El Carrol i
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i Illinois Department of Nuclear Safety Attn: Mr. Frank Niziolek Division of Engineering I
Illinois Department of Nuclea Safety 1035 Outer Park Drive Springfield, IL 62704
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