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UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
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BRIEFING BY COMMONWEALTH EDISON
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PUBLIC MEETING
Nuclear Regulatory Commission
Conference Room 1F-16
White Flint Building One
11555 Rockville Pike
Rockville, Maryland
Monday, May 13, 1996
The Commission met in open session, pursuant to
notice, at 1:58 p.m., Shirley A. Jackson, Chairman,
presiding.
COMMISSIONERS PRESENT:
SHIRLEY A. JACKSON, Chairman of the Commission
KENNETH C. ROGERS, Commissioner
GRETA J. DICUS, Commissioner
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STAFF SEATED AT THE COMMISSION TABLE:
JOHN C. HOYLE, Secretary of the Commission
KAREN D. CYR, GENERAL COUNSEL
FOR COMMONWEALTH EDISON:
JAMES J. O'CONNOR, Chairman and Chief Executive
Officer
THOMAS MAIMAN, Senior Vice President, Nuclear
Division
HAROLD KEISER, Vice President, Chief Nuclear
Operations Officer
J. STEVEN PERRY, Vice President, Dresden Station
Site
TIMOTHY J. O'CONNOR, Operations Manager, Dresden
Station
PRESTON D. SWAFFORD, Maintenance Superintendent,
Dresden Station
RAJIV S. KUNDALKAR, Site Engineering Manager,
Dresden Station
ALSO PRESENT:
FRANK SPANGENBERG
STEVE BARRETT
JOHN HARLACH
BILL RAKES
TONY BRINKLEY
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P R O C E E D I N G S
CHAIRMAN JACKSON: Good afternoon. This is
Commissioner Dicus.
The purpose of this meeting is for Commonwealth
Edison to brief the Commission on the status of efforts to
improve performance at Dresden Station, but I would say the
complete system since the last briefing in November.
Your presentation is of particular interest since
the Commission continues to be concerned about
Commonwealth's nuclear facilities, particularly the progress
being made at the Dresden Station, but even at some of the
others, in establishing lasting and effective programs that
will result in sustained improved performance.
We are anxious to hear the status of your progress
in that area.
Although the staff has reported improvements in
Dresden's performance, you continue to face longstanding
challenges in several significant areas, including worker
skills, work management and planning, the backlog of
equipment deficiencies, radiation protection and material
condition.
I must say that in reviewing other stations'
performance in the system, including Quad Cities, LaSalle,
the same kinds of themes run through.
These challenges and the progress being made in
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meeting your goals for improvement are areas that the
Commission would like to have addressed at this briefing.
I understand that copies of your presentation are
available at the entrance to the meeting.
Commissioners, do you have any comments?
COMMISSIONER DICUS: No.
COMMISSIONER ROGERS: No.
CHAIRMAN JACKSON: If not, Mr. O'Connor, you may
proceed.
MR. J. O'CONNOR: Thank you very much, Chairman
Jackson, Commissioner Rogers, Commissioner Dicus.
We very much appreciate the opportunity to appear
before you this afternoon to discuss our nuclear program,
with special emphasis on activities related to our Dresden
Station.
When we were here last November, you challenged us
to make substantial step changes in our site's performance.
We did accept that challenge and have made substantial
progress. Today, we are here to address the areas of
interest that you identified in your letter of March 22,
1996.
As I mentioned last Fall, I feel very strongly,
along with our Board, in our commitment to have all of our
plants operate in a superior manner, both from a safety as
well as a reliability standpoint. We are prepared to
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support those efforts so that there will be no doubt that
all six of our sites are resourced in a manner that will
permit steady improvement.
Toward this end, our Board in March approved an
additional allocation of $73 million towards operational
support for 1996 and an additional $19 million in capital
dollars to support an accelerated schedule of improvement
across all our sites.
These expenditures followed an in depth evaluation
by all of our sites. I hope you will agree that these
actions demonstrate our willingness to walk the talk. At
the same time, we recognize that promises, programs and even
dollars are not in themselves adequate measures of
performance, that it is results that really count.
Today, we are prepared to discuss the results of
our efforts at Dresden since we last met.
Among the comment people joining me today are Tom
Maiman, Senior Vice President for the Nuclear Division. Tom
has a proven track record in nuclear and fossil stations, as
well as our commercial divisions. With Tom is Harry Keiser,
who is the Chief Nuclear Operating Officer responsible for
the day to day operation of all six of our nuclear stations,
and Harry's experience and strong record of accomplishment
and energy make him a valuable addition to our nuclear
leadership team.
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Since we have been requested to respond to a
number of issues, specifically related to Dresden, I would
now like to ask Steve Perry, who is the Site Vice President
at Dresden Station, to describe the performance at that
station.
MR. PERRY: Chairman Jackson, Commissioners, thank
you for inviting us here to talk about Dresden. I'd like to
introduce the people I brought with me.
On my immediate left here is Tim O'Connor. Tim is
the Operations Manager at the Dresden Station. He is
responsible for all reactor operations, non-licensed and
licensed operators report to him. He is also responsible
for chemistry and radioactive waste. Tim reports to the
Plant Manager.
On his left is Preston Swafford. Preston is the
Maintenance Manager at the Dresden Station. He is
responsible for the execution of all maintenance that occurs
at the station. The Commonwealth Edison as well as
contractor maintenance technicians all report to Preston.
Preston also reports to the Plant Manager.
On his left is Rajiv Kundalkar. Rajiv is the
Engineering Manager at the station. He is responsible for
engineering support of the plant, for the design control
modifications and all of the ComEd and contractor engineers
at the station report to Rajiv. Rajiv reports directly to
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me.
All of these individuals will say something about
themselves when it comes to their time to talk, but I will
tell you, in my opinion, these are first class managers.
They have excellent nuclear instincts. They are leaders at
the site. They are functioning well as a team. They bring
a lot of energy to the place which is catching. They are
changing the attitudes at the station. I think you can form
your own opinions as you hear them speak.
I also have a number of other individuals who I
brought here and I would like to introduce them. First is
Frank Spangenberg, who is responsible for external relations
with the Nuclear Regulatory Commission, with INPO and
others. Frank reports to me. Steve Barrett has been my
Radiation Protection Manager. I have John Harlach, who is
my Master Mechanic, who is in charge of all the mechanics on
the site. Bill Rakes is a General Foreman and Tony Brinkley
is a First Line Supervisor.
I brought them so they could observe firsthand and
bring back what they hear and see today, but also if the
occasion arises and you want to ask deeper into the
organization then those here at the table, they are
available.
All of us are going to try and give you a balanced
view of where we are at Dresden today. I will tell you that
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I am pleased with the significant improvement I have seen in
Dresden and particularly over the last six months. Both
units are running, running well. Overall, people
performance and attitude has been trending up for a number
of months, but in particular, it is accelerating in the last
several months.
What we talk about here and especially since we
are focusing on what we said we were going to do in this six
months will be slanted to the positive side. We also have a
pride of authorship there.
Before we start, I must say that despite this
positive report that you will hear, we fully understand the
magnitude and depth of the problems that we are still facing
at the site. Don't think that we don't understand that
because we are talking about some positive things here.
With that, if we could turn to slide five, please.
[Slide.]
MR. PERRY: This is a synopsis of the letter which
you sent to us on March 22, remembering your comments to us
several times, we are going to focus principally on the
results. That is what the bulk of what we talk about today
will be.
You also asked five other questions which I've
listed here. I will answer the second bullet and the last
bullet there, but I will do that at the end. Mr. O'Connor
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has already talked to the resources being applied at the
bottom and Preston Swafford and Rajiv Kundalkar will address
the other two issues as they go into it.
Next slide, please.
[Slide.]
MR. PERRY: Last November, we told you that we
would accomplish a number of things. We listed 23 actions
that we would accomplish and we did all 23 of those actions.
One of them was in fact a measurement. We stated that we
would conduct an error free start up of Unit 2 after the
refueling outage, and we did that. The operations
performance was flawless.
We also had 22 performance targets that we set for
ourselves, some of which measure the actions. Others were
different from that. We met 15 of those 22.
I am going to characterize what that means to me.
What I tell my people is if we set hard targets, challenging
targets, tough targets, and achieve 75 percent of those, we
have performed in an outstanding fashion. If we were to
achieve 50 percent, that would be so-so. If we were to get
much higher than 75 percent, it would bring into question
whether or not we had tough and challenging standards.
What we have done here is we have achieved 68
percent of the standards we set for ourselves. We missed 75
percent by two. It was not outstanding, but clearly, I
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think, over this period of time, a very good performance.
Of the seven that we missed, two we missed by a
hair. Two we showed improving trends over 1995, but missed
the target. On three of them, we had no discernable
improvement over our performance in 1995. We will discuss
each one of these in detail as we go through the
presentation.
I look at these performance measures, these 22, in
a different way, and I can divide them up into two types.
One type is just getting items done, working off a backlog,
for example. About half of these were of that character.
We did all of those. There are another kind that involve
changing the culture of people and then getting them to
perform and you measure their performance. There were in
fact ten of those. In seven of the ten, we either met the
goal we set for ourselves or showed measurable improvement
over our performance in 1995, seven out of ten.
I am going to have Tim O'Connor first talk about
operations and about performance measures. It is
unfortunate for Tim that we have given him most of the
performance measures that we didn't achieve, so he will be
discussing those things. If you will bear with it, we will
get through all of the three individuals that are going to
talk and you will be able to form an overall picture of
where we are.
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With that, Tim O'Connor.
MR. T. O'CONNOR: Chairman Jackson, Commissioners,
my name is Tim O'Connor. I'm the Operations Manager, as
mentioned earlier. I'm responsible for personnel associated
with operations of Unit 2 and Unit 3, the Rad Waste Group,
Fuel Handling, Chemistry and Environmental Compliance.
I've been assigned to Dresden for approximately
four years and in the last 12 months, I have seen and been
part of the most significant change while at Dresden. The
focus has been to change the habits and the practices of our
people, to change the thinking of our people by establishing
standards that are equal to or better than the industry. We
are focusing on results as a measure of performance as
individuals and as a station.
I will present today performance results in the
area of operations, human performance for the station and
radiation protection.
Next slide, please; eight.
[Slide.]
MR. T. O'CONNOR: As you may recall, Chairman
Jackson, in late 1995, you visited Dresden Station, and at
that point in time, Unit 3 had returned from a forced outage
which was focusing on repairs to our low pressure turbine
blades. Also during that period of time, we took those
occasions to resolve longstanding equipment issues and
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operator challenges.
Just a couple to mention has been the restoration
of redundancy to some systems or simply restoring a defense
and depth to our non-safety related systems. One system had
been out of service for almost 15 years. Also, we took this
opportunity to resolve some operator challenges, that being
with level control with our feed water system, which we now
have automatic features during transient conditions, which
previously we had not in all cases.
We had a very deliberate error free start up back
in October of 1995, and since that period of time, we have
exceeded 180 days of continuous operation with a better than
90 percent average capacity factor since that start up.
The unit is not showing any significant signs of
material condition degradation and is demonstrating
reliability and our operators are confident in that plant.
Next slide, please.
[Slide.]
MR. T. O'CONNOR: Unit 2 has recently returned
from its refueling outage in early April of this past year,
1996. Also, during this particular refueling outage, there
was considerable focus on improving safety margin, resolving
longstanding equipment issues, and reducing operator
challenges.
Preston Swafford will mention some of those items
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in the material condition presentation. I would like to
touch on just a couple.
First is our station blackout diesel generators
are now operable on Unit 2. This restores additional AC
power in the event of a loss of off-site power. Also,
significant effort has been put to our feed water system,
both in the control system and in the valves themselves.
Thus, giving us complete automatic features which Dresden
has never had previous to this point in time.
CHAIRMAN JACKSON: Repeat that, please, what you
just said.
MR. T. O'CONNOR: Our feed water -- there has been
considerable effort put into our feed water control system
and valves, and the work that has been performed this last
outage has provided us automatic controls that we have not
had in previous years.
CHAIRMAN JACKSON: Thank you.
MR. T. O'CONNOR: This start up on Unit 2 is
significant to Dresden, not only because it is the start up
of a reactor, but also because we are now entering into dual
unit operations. Therefore, considerable effort and
controls were put in place to assure that we had error free
start up.
Assessments and overall readiness efforts were put
in place to assure physical system readiness, individual
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readiness and crew readiness, with during the start up and
critical activities, senior management oversights being
performed of our operators to assure that performance levels
were up to the highest possible levels.
Again, we had a deliberate error free start up on
Unit 2.
Next slide, please; ten.
[Slide.]
MR. T. O'CONNOR: In the area of our operations
workforce, we have had a step change in our licensed
operators. Specifically, the overall control room
professionalism and operations of our control room
personnel. That was a target in 1995 and we have been able
to achieve a higher level of performance with those
operators.
We routinely bring in outside industry peers, non-
ComEd personnel, to evaluate us, to assure that we are
meeting those standards and to bring new ideas to continue
to raise those standards. In fact, at this point in time,
we have been benchmarked not only by our ComEd stations, but
also by non-ComEd stations in terms of how our control room
is operating, because other stations wish to achieve the
same kind of results.
In the area of non-licensed operators, this is a
specific focus in 1996. The same structure and philosophies
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that were successful with the licensed operator is now being
applied to our non-licensed operators. We are seeing
improvement, although those operators are not yet at the
same standards and levels of performance as our control room
personnel.
CHAIRMAN JACKSON: What metrics do you use to
measure performance?
MR. T. O'CONNOR: The standards that I use are
performance evaluations on weekly exams, both written and
physical field observations, to determine whether those
personnel are performing to the standards in the field.
CHAIRMAN JACKSON: Commissioner Dicus, do you have
a question?
COMMISSIONER DICUS: Yes. You have achieved
improvements in the control room operators in how they are
functioning but not outside the control room, if I
understand that. You haven't gotten the same level.
Were the improvements in both groups or the
training for both groups done about the same time or did you
focus on the control room and then to the others? I'm
trying to get at why there is a difference.
MR. T. O'CONNOR: In the middle part of 1995,
human performance errors in the control room was a
predominant area of focus because of the numbers of errors,
and the focus by Dresden was specifically on the control
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room operators. The non-licensed operators at that point in
time were not showing the same kind of problems with
performance.
This year, the focus is now with the non-licensed
operators, and as you will see in a slide later, some of the
performance data dictates that is where the focus should be.
That was not at the same time.
MR. PERRY: I will just add to that, to give it a
different viewpoint. Clearly, the most important area of
the plant is the main control room. We recognized that we
had material condition problems that could challenge the
plant, and if we did not have operators who were
professional, conservative and had a good approach as to how
they solved problems, that combination is not a good
combination, so we put a lot of effort in the control room
area as a first line of defense.
MR. T. O'CONNOR: Next slide, please; 11.
[Slide.]
MR. T. O'CONNOR: In operator re-qualification
exams, a target that was established for April 30 for
ourselves was to have a pass rate greater than or equal to
95 percent. As you can see in this particular graph,
Dresden Station finished with a 97 percent pass rate. We
achieved our goal.
Next slide, please.
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[Slide.]
MR. T. O'CONNOR: In the area of Operations
Department, human performance, we had a specific target of
April 30 to be less than or equal to four events for the
first quarter of 1996. We have not achieved this goal as of
yet, although as you can see, we are seeing a declining
trend in human performance errors, but still, much needs to
be done.
CHAIRMAN JACKSON: How does that compare with
industry performance?
MR. T. O'CONNOR: My experience and in talking to
my counterparts, both in Edison and some friends of mine
external to Edison, we are still well below where the best
are. If you are looking for a specific number, in operation
space, three or four a year.
CHAIRMAN JACKSON: I guess what I am really trying
to understand is how do you set your goals, how do you know
what is a good goal and how do you benchmark yourselves with
the rest of the industry, particularly with the best
quartile of that industry.
MR. T. O'CONNOR: Clearly, I'm using those values
that I have mentioned for benchmarking myself and we are
transitioning from step change to step change to step
change, to reach those particular targets.
Next slide, please.
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[Slide.]
MR. T. O'CONNOR: An evaluation of the human
performance issues break down in these categories. I have
simply separated them from field activities to non-field
activities. I would like to point out that the biggest
dominators of our human performance issues are with our non-
licensed operators at this point in time, and our out of
service program.
Next slide, please.
[Slide.]
CHAIRMAN JACKSON: Do you feel that those issues,
that extra training and so on that you talked about, with
the non-licensed operators, are the right things to do to
bring those contributions to significant events down on the
part of the licensed, the standards training, performance
training, testing training and systems training and this
conservative decision making seminar?
MR. T. O'CONNOR: Yes, I do.
CHAIRMAN JACKSON: How do you translate the
metrics that you talked about generally in terms of
performance to how it is really going to impact this magenta
part of the circle here?
MR. T. O'CONNOR: With results that I was able to
accomplish with the licensed operators, the methodologies
that you just described are the same things that positively
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worked with the control room operators, and the issues are
very similar with the non-licensed personnel.
Therefore, I believe that I will get the same
results with the non-licensed personnel by applying those
same principles.
CHAIRMAN JACKSON: Commissioner Dicus?
COMMISSIONER DICUS: What was the time frame that
you collected these data?
MR. T. O'CONNOR: This is the first quarter of
1996.
CHAIRMAN JACKSON: At this point, you don't know
if it has all really sunk in or not, to know that you will
really get the improvement that you want to see?
MR. T. O'CONNOR: I am seeing some measure of
results in terms of improvements but additional time will be
necessary in order to prove that magenta section reduces.
Next slide, please.
[Slide.]
CHAIRMAN JACKSON: Tell me what kind of
significant events you feel that the non-licensed operators'
improvement would eliminate?
MR. T. O'CONNOR: Independent verification in out
of service tag outs in the plant, equipment manipulations.
Those are the kinds of things that we are focusing on.
Those have been the areas of weakness that we have seen in
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the last 12 months.
CHAIRMAN JACKSON: Are you able to identify any
particular plant events with those sorts of areas that need
to be improved? For instance, what I am going to ask you
later is the fact that you still do seem to have a fair
number of significant events. One could argue, and that is
true for all of you who are planning to talk today, and that
is one could argue that if you do all these things and you
say we are doing this, this and this, and we have trained
this many people, you know, people do this and they get
scores and they have had this seminar and they have done
that, but in the end, where the rubber meets the road is
just that.
I've had this kind of discussion with other
plants, where we are in the green here, we are in the green
here, we are in the green here, but we are in the red as far
as significant events.
That is really what I am trying to get at, you
know, knowing that what you are doing has a direct effect on
events in the plant, because otherwise you can train people
and that could be a metric. You can have seminars, and that
can be a metric. In the end, if the plant doesn't perform,
that is the ultimate metric, is it not?
MR. T. O'CONNOR: Yes, it is.
CHAIRMAN JACKSON: What I am trying to get at is
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trying to understand how the particular performance metrics
that you are putting into place track to what seems to cause
the significant events.
MR. KEISER: In one sense, the chart, because it
is a pie chart, it is always going to have a hole.
CHAIRMAN JACKSON: That is why I am offering you
the opportunity to fill in those holes for me.
MR. KEISER: One point he had made earlier was
that the focus on the control room operators, which in this
terminology would be the NSO, you see that is the smallest
component on the chart. He is saying the activities
embarked on with the NSO's was successful, and embarking on
the same activities with a non-licensed operator would show
a change in that chart. We would use the chart as a
feedback.
CHAIRMAN JACKSON: It is too soon to know at this
point?
MR. KEISER: Yes, ma'am.
MR. PERRY: We are seeing some effects already and
one of them you just saw and we will show you another couple
of them. I would go back to the control room operators. We
track errors and mistakes they make by crew every month. We
analyze it or Tim analyzes it and looks at it and we are
doing the same thing in the non-licensed operators.
In fact, in the one particular area here with out
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of service, we are doing that and found out what we did
wasn't good enough and we re-approached the problem and put
in different corrective actions and did make a measurable
effect. You can see that on the next chart, I believe.
CHAIRMAN JACKSON: I guess what I am trying to say
is you are looking at, for instance, you mentioned crew
performance. Are you able to track the occurrence of
certain significant events to certain performances or lapses
of performance on the part of crews of non-licensed
operators?
MR. PERRY: Yes.
CHAIRMAN JACKSON: That is what I am trying to get
you to talk to me about. It is those that you feel that are
being addressed by the various things that you delineated
earlier, to be tracking in fact whether by having this set
of improvement activities, whether that has direct impact
first on the behavior that you feel links to the significant
events, and separately on the occurrence of the significant
events themselves. You are actually doing that tracking?
Those are your ultimate performance metrics?
MR. T. O'CONNOR: Yes, Chairman Jackson.
CHAIRMAN JACKSON: All right. Thank you.
MR. T. O'CONNOR: Slide 14, please.
[Slide.]
MR. T. O'CONNOR: This is another target measure.
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We had an expectation of being less than or equal to one out
of service event by April 30 of this year. As you can see,
we have seen a significant reduction and we had one month
where that was achieved. However, we did not achieve it in
April. Therefore, we are not considering this a success at
this point.
Your comment earlier about non-licensed operators
and are we tracking events, this is an example that I used
in order to formulate what types of performance training we
should be looking at in evaluating, to change the behavior
and practices of our people. At this point, we are seeing
success, at least in this area.
Next slide.
[Slide.]
MR. T. O'CONNOR: In the area of operations self
assessment, there has been a significant effort to develop
and implement ongoing self assessment programs within the
Operations Department. This did not exist 12 months ago.
Some of the items that you see below in the slide are just
specific focus areas that Dresden operating-wide managers
are doing on a routine basis.
We are finding weaknesses and the most recent one
that has been performed within the last two weeks was in the
area of the out of service program, specifically because it
has been an area of weakness, and we made substantial
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changes in the late February time frame, and we wanted to
measure effectiveness at this point.
Also, during that particular assessment, we
involved our bargaining unit employees to participate with
that evaluation, so they could get a better appreciation and
sense of what we are trying to accomplish.
CHAIRMAN JACKSON: How did that in fact go?
MR. T. O'CONNOR: It went very well. I think that
in general they saw things from a different perspective than
previously.
CHAIRMAN JACKSON: Have you seen any change as a
consequence in performance?
MR. T. O'CONNOR: I'm not sure I understand your
question. The operators -- in the individuals, yes. As a
collective group, it is a little early to tell yet.
The next couple of slides will be in the area of
station human performance. Slide 16 is personnel error
LER's. We had a specific target by April 30 for the first
quarter of this year to be at zero personnel error LER's.
We did not make this particular goal.
Next slide, please.
[Slide.]
MR. T. O'CONNOR: This slide is a station event
free clock, as we call it. It is days between events. This
is something that was generated at Dresden Station. It is a
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relatively new measure and it is something that our other
ComEd stations are also using.
We had a specific target to be at 40 days between
events. To date, we have not reached that particular goal.
We are at about 25 days at this point from the last event.
Our top so far has been about 31 days.
This is a very challenging and aggressive goal for
our people. I'd like to point out that many items that are
included in this are a very low threshold of issues. Some
can be out of service issues. Some can be material that was
found outside the protective area, items like that. These
are not all considered to be significant safety issues.
Next slide, 18.
[Slide.]
MR. T. O'CONNOR: I'd like to talk a little bit
about radiation protection. The slide you have before you
simply points to historical representation of the history of
Dresden over the last 12 years. Dresden Station is showing
an improving trend in collective radiation exposure for the
station. However, we are still in the fourth quartile by
comparison to the industry. Much work needs to be done in
this area.
CHAIRMAN JACKSON: How far are you away from the
industry mean?
MR. T. O'CONNOR: I'm sorry. I don't know the
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exact value. Steve?
MR. BARRETT: Chairman Jackson, I believe we are
about --
MR. KEISER: For BWR's, the first quartile is
around 250 man Rem, 225.
MR. BARRETT: Chairman Jackson, we are about 175
person Rem per unit away from that. This year, if we meet
our goal, we will move up to the top quartile of the bottom,
still poor performance, but we are balancing -- improving
the radiological condition against exposure. We are
cleaning up a lot of rooms that is taking a lot of person
Rem to do.
CHAIRMAN JACKSON: You have a special project or
focus on that; is that correct?
MR. BARRETT: Yes.
MR. T. O'CONNOR: Next slide, 19.
[Slide.]
MR. T. O'CONNOR: Another specific target that we
had set for ourselves for April 30 was to be less than or
equal to 25 contamination events. We have achieved that
goal. We had 17 to date. Again, you can see the historical
performance of Dresden. The last couple of years are
showing a decreasing trend.
In the area of radioactive material control, in
late 1995, there was identified material that was not
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properly controlled, which Dresden Station personnel
essentially shut down the site and did a complete survey of
the plant, utilizing personnel from other stations as well.
The collective sum of items that were identified
was in excess of 450 items. A significant effort has been
put in place with the use of a variety of levels in the
organization and as pointed out, a multi-discipline team, to
implement corrective actions to change that particular
trend.
There are continuing sweeps that are in progress.
That was one of the corrective actions in order to be
proactive and to assure that the corrective actions that we
have implemented are achieving the results that we expect.
To date, we have seen a 95 percent reduction in items that
in the past were found not properly controlled.
CHAIRMAN JACKSON: Let me ask you a question,
going back on this whole subject of station exposure history
and the distance from the goal. Have you identified some
top area or items or areas or things you must do to go down
by 175 person Rem? What do you have to do to get there and
how low do you think it is realistic for you to expect to be
able to go?
MR. BARRETT: I forgot to introduce myself last
time. I'm Steve Barrett. One of the big things that we
definitely have to do is improve the radiological material
. 28
condition. We have some rooms -- we have a target of worse
areas in the plant. We have recently taken on the reactor
building equipment drain tank room. We took over 15 person
Rem to restore that. The other major area is in the area of
refueling outages. We have to do shorter outages and less
re-work. We will fall more in line with the rest of the
industry.
CHAIRMAN JACKSON: That is not an unrealizable
goal for you?
MR. BARRETT: I do not believe it is an
unrealistic goal for us.
COMMISSIONER DICUS: Do I understand you are
assigning the responsibilities for the high exposures on
prolonged outages and contaminated areas that people were
working in?
MR. BARRETT: We have taken a very aggressive
stance in putting in lead shielding. You may recall, we re-
posted the plant from 5 millirem per hour to 2.5 millirem
per hour. Our people realized that they were standing in
what we would consider higher dose rates than they should
be. We still have maintained that. We have put up a lot
more lead shielding and we are getting a lot more
cooperation from the workers moving in and out of radiation
protection areas much faster than they did in the past.
We have established cameras in the steam sensitive
. 29
areas, where before we had sent operators in to look for
valves. We have done a lot in that area as well.
We do have a high source and Preston will talk a
little about zinc injection that we are doing and
replacement of the reactor water piping.
MR. PERRY: There are a couple of specifics that
we mentioned to you when you were at the station in
December, that we had at the beginning of 1995, 82 hot spots
and we had eliminated 42 of them and were after the rest of
them. I was particularly impressed that the insulation that
we have around the reactor recirculation piping in our dry
well, we put lead blankets inside this insulation so that it
provides shielding and it has knocked down the radiation
levels in the dry well during outages considerably.
We took a pretty good sized dose to do that, to
make that installation the first time because it is very,
very heavy to lift this. It will have a long term
beneficial effect.
We made the modifications in Unit 2 this time to
add zinc, pacified zinc, and that should reduce the amount
of cobalt activity we see in the plant as well.
We are putting a big effort in this area.
MR. KEISER: Dresden has a high source term and a
compact design, and we couple that with our material
condition items, it makes it very difficult for us to make
. 30
dramatic improvement in radiation exposure where we see any.
CHAIRMAN JACKSON: What is the source of your high
source term?
MR. KEISER: It is years of operation.
CHAIRMAN JACKSON: There are things that in the
end, you don't know that you will ever be able to totally
eliminate, is that what you are telling me?
MR. KEISER: That's correct.
MR. T. O'CONNOR: In summary, the plant material
condition is improving. That is demonstrated by our
reliable run and the regaining of confidence that our
operators are having by the plant responding as expected.
Step change has been achieved in the behavior and
the practices of our operators in the control room.
However, as I said before, we still have work to do in order
to gain the same results with our non-licensed operators.
I believe in self assessment, as a means for
essential continuous improvement, and we do have processes
in place that are functioning that have not been in the
past, our department line managers own those processes and
they are actively involved, because that is where true
change takes place.
My focus is on the leadership of driving
accountability down to the first line supervisors and the
worker level, coaching them and developing to the same
. 31
standards that I hold myself to and the expectations are a
key focus for me, and I believe that is how we will sustain
long term change at Dresden.
Thank you. Preston Swafford will now speak on
material condition.
MR. SWAFFORD: Thank you, Chairman Jackson,
Commissioners. My name is Preston Swafford. I'm the
Maintenance Superintendent at the Dresden Station. I am
responsible for all craftsmen on-site. I have been with
ComEd for approximately five months. Prior to Dresden, I
have worked with the management teams associated with
turning around three other watch list nuclear power plants.
I would like to share a few observations about the
personnel at Dresden today.
Similarities do exist with those other three
stations at their point in time where change began to occur
rapidly. The personnel are recognizing that there are
problems at Dresden. They are beginning to report these
problems as well as acting on them more aggressively.
The energy level is rising in both the management
and bargaining groups. This increase appears to be coming
from the energization of the first line supervisors. They
are responding to the responsibility and accountability
being given to them.
The skill levels within the Maintenance
. 32
Department, however, is below the industry average. This is
recognized by the management team as well as many of the
craftsmen themselves.
The individuals are expressing sincere interest in
turning this around. It is up to me to facilitate this
improvement.
Next slide, please; 22.
[Slide.]
MR. SWAFFORD: In 1996, Dresden had a focus to
significantly improve the material condition at Dresden. We
will do this through improving the work management process,
through improving the engineering support to those
processes, and by reducing re-work.
Next slide, please.
[Slide.]
MR. SWAFFORD: Recent key material condition
accomplishments. Three of the ten worst plant areas cleaned
by April 30. We met this goal. We took the Unit 3 reactor
building equipment drain tank room, as one example, and
removed 39 bags of trash from this particular room. We
reduced overall dose rates through de-conning and
hydrolysing and other maintenance activities from 2 to 400
MR general area down to 20 to 60 MR general area. We have
repaired equipment in that room that had not worked in many,
many years.
. 33
The Unit 3 high pressure coolant injection room.
We placed into model space. This room is now considered
fully functional for operations. They can do all activities
they need to do in their street clothes in this particular
area.
The Unit 2/3 acid-caustic area is another area on
both turbine buildings, where abandoned equipment had been
left in place for quite some time. We removed all that
equipment and the hazards associated with that equipment.
CHAIRMAN JACKSON: There is no more abandoned
equipment?
MR. SWAFFORD: There is no more abandoned
equipment in that particular area. Now, we have returned it
to near model space as well and Operations for the first
time can get in there and operate any valves that may be in
that particular area.
We also completed the Unit 2 core shroud repairs.
The Unit 2 reactor water clean up piping and heat exchanger
modification was completed. This entailed removing heat
exchangers and other associated piping that were
significantly contaminated and significantly degraded.
Operations now can operate that equipment in a manner they
have never been able to do or at least not for quite some
time.
[Slide.]
. 34
MR. SWAFFORD: In addition, next slide, 24, we
installed the Unit 2 zinc addition modification. This was
just mentioned briefly. The intent of zinc is to create a
pacification layer on the piping and slough off Cobalt 60,
thus reducing station exposure. We are taking it one step
further and we are going to be using depleted zinc to again
reduce the Zinc 65 component and again reduce overall
station exposure.
We completed the Unit 2 station blackout
modification. The other part of this is tied to Unit 3 and
that will be completed in the Fall.
The 89-10 effort is complete on Unit 2, with the
exception of three valves that we need to dynamically test.
These valves will be done in June, on the next scheduled
high pressure run.
In addition, the Unit 2 feed water reg valves and
control system were upgraded as mentioned earlier.
Next slide, please; 25.
[Slide.]
MR. SWAFFORD: Work management improvements. We
are now successfully running the 12 week rolling schedule.
INPO has just exited last Friday, coming in to specifically
look at this area for us. They commented saying that the
process is functioning. However, there is much tuning to be
done.
. 35
This is not a strength at our unit, but I do
believe that the processes in place now will withstand the
time. We now need to understand them better at all levels
in the organization to get them implemented.
CHAIRMAN JACKSON: I was told you had somewhat of
a problem with work package procurement. Is that still an
issue?
MR. SWAFFORD: We have some weaknesses in that
area as well as some others. The quality of the work
packages, we are still struggling with. One of our
strategies there is to walk down the packages by the end
users, the craftsmen, and try to identify the problems two
weeks ahead of time. We are improving that area. We are
probably only averaging about three days ahead of time. We
need to get that to a full two weeks so the team has an
opportunity to respond, but we are moving to that end.
Another area is the weekly schedule adherence
accountability meeting. This is an important meeting to me.
This is a meeting I chair, which I invite my first line
supervisors to this meeting. In this meeting, they go over
all job activities that did not work per the schedule the
prior week. In addition, we invite key people that support
the process, in the Operations organization, Systems
Engineering organization, Procurement and others are there
to hear the barriers put in front of the first line
. 36
supervisors in getting their work done.
By having this meeting on accountability, I am
able to flush out those barriers and create action plans
necessary to resolve them.
Another area we attacked was the backlog. Our
approach to meet the April 30 goal was to divide that
backlog by system to individual first line supervisors.
That way, each individual again had accountability and a
measurable matrix, if you will, to their success.
CHAIRMAN JACKSON: My understanding is that there
is a level at which there may be "hidden material" condition
deficiencies. Do you feel that you really have your hands
or what are you doing to get your hands around the full
scope of the work that might be out there, that you have
these backlog items that are obviously based on identified
deficiencies. The question becomes how do you know when and
how to go about getting your hands around the full scope.
MR. SWAFFORD: I will address that in a second in
another slide, but to take part of it on right now, I
recognized when I first showed up in December, and this goal
was already made of 950, that we needed to understand what
the definition of the backlog was.
Clearly, there are more items in the backlog than
the goal was of 950. We understand that. The goal was made
on one particular bin called "corrective maintenance non-
. 37
outage WR's," so instead of changing that, we kept that
definition the same and tried to pull that all the way to
April 30, measuring that one, and leaving some of the other
definitions alone, but we would also have metrics for those
that we are tracking against as well.
CHAIRMAN JACKSON: How many such others with other
definitions?
MR. SWAFFORD: In the category of non-outage
corrective maintenance, I would say our number is about
1,530, of which that is broken down into two major areas.
One is the one number we are tracking, which is the
corrective maintenance non-outage power block WR's, and the
other one is what we call a terminology of an AR. These, of
which there are roughly 649, those particular items are
minor in nature to fix. They may have significance in terms
that they are corrective maintenance and they are power
block, but I do not need to organize the entire planning
process and spend all the dollars and time in planning that.
We worked those with a team called our WIN team,
work it now team. In order to continue to address that
number and reduce it as well, we have created a second WIN
team, and our first WIN team has been very successful. They
have reached somewhere around 120 AR's a week, give or take
a few, which is right up there with some of the plants with
benchmarks in terms of Peach Bottom and Brunswick.
. 38
They are fairly effective.
CHAIRMAN JACKSON: I guess the question becomes,
you know, there is always the incoming at the same time.
You have a work off rate. Whether you make progress also
depends on what comes in.
MR. SWAFFORD: I have another slide that may help.
CHAIRMAN JACKSON: Okay, I'll wait and let you
talk.
MR. SWAFFORD: To finish with this slide, the work
week manager de-brief with senior managers is another key
aspect. We have now currently six work week managers, fully
functioning. These people are empowered. We had them
before but frankly we didn't give them all the
responsibility and accountability and the tools to be
successful.
One of the obligations we have as senior managers
is to sit down with these people and explain what our
expectations are. We meet with them twice a week, Tim
O'Connor, myself and the work control superintendent, and
that is as much a part of mentoring the individual as it is
to actually understanding his problems and what is going on
within the schedule that week.
Another area is in the improved licensing
condition for operation procedure. As we went into the 12
week rolling schedule, have begun on our journey to take
. 39
some on-line maintenance activities. The very first one we
did was on the 2-3 diesel generator, of which we critiqued
that afterwards and out of that came some procedure changes
we thought were appropriate and we made them.
Next slide, please.
[Slide.]
MR. SWAFFORD: The non-outage corrective
maintenance backlog. As you can see, we did meet the goal.
Currently today we are at 890. I am going to move onto a
couple more before I get into your question. This one
doesn't do that.
Next slide, please.
[Slide.]
MR. SWAFFORD: In preventative maintenance and
surveillance overdue, we had a commitment by April 30 to be
at zero. We in fact made that goal. This was an ambitious
goal, scheduling of over 100 a week at times was necessary
to be able to meet this. I can say that the Engineering
organization put in place to take this on did in fact meet
this goal and it was a strong effort on their part.
Next slide, please.
[Slide.]
MR. SWAFFORD: On time schedule starts. We had a
goal of April 30 to be at 85 percent of starts within one
hour of scheduled start time. We did not meet that goal.
. 40
However, we did meet that a couple of times. After we made
it a few weeks, we found that we dropped off. Those drop
offs were tied to the error free start up of Unit 2 that
took operators away from the work control process and thus,
some maintenance activities did not go per schedule.
I would like to announce that we did this last
prior week make 87 percent and I believe we are moving back
up again in that area.
[Slide.]
MR. SWAFFORD: The next slide, 29, is the one that
I think might answer your question. This particular slide
of workoff rates is not in the traditional bins, if you
will, of the 950 that we are trying to meet by April 30.
This is an identification of total problems out in the
plant. They may mean housekeeping. They may mean
corrective in nature. It could be whatever.
In there, you can see that from the last quarter
of last year to the first quarter of this year, we have had
a significant number of AR's generated, which means people
are out there identifying problems. The systems engineers
have been doing system walk downs, identifying issues, as
well as a concerted effort on Operations' part to get out
there and identify the problem.
This became particularly complex for me as a
Maintenance Superintendent responsible of getting the
. 41
backlog down to 950, as they are doubling their efforts in
identification. I have to do more than double my effort to
work them off.
As you can see, we in fact in maintenance did
that. One other thing of note is the fact that the prior
quarter's performance, the last quarter, about a month and a
half of that period, we had over 1,000 additional
contractors on-site during the outage, that we did not have
in this last quarter. We started up Unit 2 with only
roughly around 250 additional maintenance contractors, as
opposed to 1,200 and something last Fall.
CHAIRMAN JACKSON: All AR's don't involve the same
amount of work.
MR. SWAFFORD: That's correct.
CHAIRMAN JACKSON: If you had to project how long
it is going to take you to really get this backlog down,
what would you say?
MR. SWAFFORD: We have a goal for the end of this
year to be at 800 in that one pile, that one bin of
corrective maintenance non-outage, and I expect to see a
significant increase in the rate of reduction in the other
column of AR, such that I have a goal of 500 in that area.
The end of the year performance for me would be
around 1,300, down from the 1,500. It would be more
aggressive than that but I have an outage in the Fall as
. 42
well, and typically in the outage, I go up 150 to 200 items.
I actually have to under shoot roughly around 650 to 700
before the start of that outage in order to have a chance at
the 800 at the end of the year.
CHAIRMAN JACKSON: If I were going to convert that
to some kind of number of weeks or man weeks to work things
off, what does it turn out to be?
MR. SWAFFORD: You are going to get me here.
CHAIRMAN JACKSON: You can give me the answer
later.
MR. SWAFFORD: Okay.
CHAIRMAN JACKSON: And calculate it as you are
going along.
MR. SWAFFORD: Thank you.
[Slide.]
MR. SWAFFORD: On the next slide, 30, maintenance
re-work. This relates back to the issue I started with, and
that is the skill of the craftsmen. This is directly
attributable to the knowledge base of my craftsmen.
Although this particular graph seems to have an appealing
trend to it, it is really not telling the story.
We have significant re-work problems at Dresden
and we have had significant components, too. It is not just
large numbers of small items. It has been roughly 25 to 30
significant items a month. This is of particular concern to
. 43
me and when I get into training, I will try to give you an
idea how I am addressing it.
CHAIRMAN JACKSON: Where do these fall,
electrical, mechanical, what?
MR. SWAFFORD: I would say the IM group is my
strongest performer. My construction group and my
mechanical is probably my worst performing, and my
electrical hovers between the mechanical area and the IM
area. We are not strong, I think, in three of the four main
groups.
We have had a fair number of EM issues, too, but
the number of work items they do per unit time is not as
many as the other groups.
[Slide.]
MR. SWAFFORD: Next slide, industrial safety
accident rate. This is another goal. We did not meet this
goal. We had a goal of .8. We are currently at 1.1. This
particular area, as you know, maintenance could probably
influence this more than any other group.
We have improved over time but we are
significantly above the industry. The technique we are
trying to approach now is where the plant manager is
chairing a meeting any time we have a recordable event that
affects our ISA rate. We meet with the first line
supervisor, who has a small committee of senior managers.
. 44
We sit there and we listen to the first line, understand
what happened, understand what the corrective actions are,
and understand whether or not he will be successful in
transferring that to the other groups and departments on the
station.
If it is not overly convincing, we send the
individuals back to get better prepared. We believe with
that type of heightened attention, we may start to attack
this issue.
[Slide.]
MR. SWAFFORD: Next slide, please. In the area of
maintenance training, we have completed the Phase I
training. This is something I believe we spoke to you about
six months ago.
Phase I was an example of understanding where our
fundamental skills were of our people and developing some
exams and testing methodologies to in fact prove where they
are at and find out the base knowledge level of the
individuals.
We did have some failures. We did have some
remediation and we did in fact remove their qual's and
disallowed some individuals from doing work in our power
plant until they got up to speed and could demonstrate
proficiency in their field.
In the area of Phase II, that I think will be our
. 45
next very proactive approach, is we had a heavy reliance on
contractors at the Dresden Station for years, and because of
that, we did not get some of the training and specialty
training to our fellow employees.
We are changing that. We are investing in our
individuals and we are going to start in June our very
first, if you will, specialization training. We are going
to do roto alignment of pumps, something that had been done
with contractors for many, many years.
I believe that by investing in these individuals,
this specialized training, we will be able to reduce the re-
work at the station. In addition, we are going to continue
to benchmark against strong industry maintenance training
programs.
Next page, please. In the area of maintenance
self assessment, this was not a strong point for us at the
station. We have currently completed our first self
assessment. It did involve some bargaining unit as well as
first line and management and maintenance staff personnel.
We chose to look at measurement and test equipment
and the results of the report were excellent. However, the
results of the findings were that we had significant
problems in the area of M&TE. It ranged from the database
being inaccurate to some of the personnel performing duties
in that not having up to date qualifications.
. 46
With that, we have taken some deficiencies and
placed them into our nuclear tracking system and we will be
completing the corrective actions to that to improve that
area.
Another area is in the area of weekly maintenance
coaching and assessment job overviews. This is an approach
where my general foremen level go out into the plant and
observe their work crews performing work and developing, if
you will, a critique, of how they are performing. After
that is complete, at the end of the month, I chair a meeting
where all of them are invited to one meeting, and they have
to describe the barriers and what they have seen out in the
plant.
I then take all the information at my disposal in
terms of problem deficiencies that were found, re-work
issues and all sorts of other data, to, if you will, counter
what they are seeing in the field. It is entirely possible
until we really show them how to observe out in the field,
they won't be able to be effective. This is a technique
that we believe will get them up to speed and make more
meaningful use out of their time in the plant.
We also perform management by walking around as
well as continuing to reinforce the maintenance workforce
standards.
In summary, the material condition at Dresden
. 47
Station is improving. The workforce is energized and wants
to improve. We need to sustain this continued improvement
and ensure plant equipment reliability.
Through reliable plant equipment will come the
rebuilding of confidence by our station operators in their
plant equipment and in their maintenance department.
With that, I would like to introduce Raj
Kundalkar, our Engineering Manager.
CHAIRMAN JACKSON: Let me ask you this question.
Given that even you admit that the skill of the craft is
still weak, even as you have these fairly aggressive
programs in place, should the Commission have comfort that
you have plants that are operating, that people are working
on, given the potential for events caused by maintenance or
equipment problems of various kinds, where you admit that
the skill of the craft, the people working on these
operating plants is not where it should be?
How do you give us comfort in that regard?
MR. SWAFFORD: One of the mistakes we were making
through the years is in some areas, we had some skilled
craftsmen, but through our process, we would not get them on
the right job, as an example. Even in those areas where we
had the qualities and the skills, we didn't get them on the
right job, thus, resulting in a lot of re-work.
Another example that was a large part of our re-
. 48
work was we allowed contractors to basically go unsupervised
with ComEd personnel. What I have done recently is I have
taken all contractors and have integrated them into the
crews and into the shops proper, so that I have my own
supervisors overseeing their work activities in the plant.
These two areas alone, by getting the right
workers on the right job as well as getting contractors
integrated, should ensure the minimum level if not a little
more than that, of being able to perform maintenance in
nuclear fashion.
We still have a way to go. We have some areas
where we have relied totally on contractors and we are
starting to train them ourselves. We will have to continue
to rely on contractors in those areas until we get our
people up to speed.
I think the answer is no, I am not afraid of the
overall skill level. It is just we are not where we need to
be.
CHAIRMAN JACKSON: I don't mean to pick on you and
it looks like Mr. Perry wants to jump in here, but let me
just repeat. To the extent that you told me this, but that
you still have significant re-work, which then naturally
raises the question about the skill or attention to detail
of whomever is doing the work, be it contractors or your own
people, whose skills you are trying to improve, and I
. 49
repeat, these are operating facilities we are talking about,
you know, how do we get a comfort level that somebody is not
going to cause something untoward that results in a
significant event?
MR. SWAFFORD: The PMT process is not a
particularly good answer, I don't think, but the PMT process
is our last barrier and that is a post-maintenance test,
which is our last barrier to ensure that before we turn that
equipment back over to Operations, that it in fact will do
its function. The quality of those PMT's are for the most
part laid out by the Operations staff, which is the users of
the equipment.
We are identifying the large majority of re-work
in the PMT stage or earlier. Therefore, I don't believe
when we actually turn the equipment over to Operations, we
are on a daily basis, if you will, challenging the
operators.
CHAIRMAN JACKSON: Do you agree with that, Mr.
O'Connor?
MR. T. O'CONNOR: Yes, I do. Preston is exactly
right. Our PMT process, although it does have some things
to improve, it does catch the issues that we need to assure
that the equipment is fully functional before we call it
operable, so that we are not putting our operators in the
kind of challenges -- the start ups here on the last two
. 50
units indicate and demonstrate that is working effectively.
CHAIRMAN JACKSON: What about operator work
arounds, however you define them? Whenever I ask that
question, somebody always says, well, it depends upon how
you define "operator work arounds." You define them. The
question is, you know, how many such are there and is that
number being reduced?
MR. T. O'CONNOR: There is a slide, Chairman
Jackson, that Raj Kundalkar will explain on operator work
arounds and where we are currently heading, if that is
acceptable, otherwise, I will try to answer.
CHAIRMAN JACKSON: I will wait. Mr. Perry, you
have a comment?
MR. PERRY: No. I was going to discuss where most
of the re-work comes from, and it is the testing before we
return it to operators, but they handled it very well.
CHAIRMAN JACKSON: You schooled them very well.
Thank you.
COMMISSIONER ROGERS: What is different about the
PMT process from what has been the practice in the past?
MR. T. O'CONNOR: One is we benchmarked several
other stations outside ComEd where a committed, dedicated
group of personnel from a variety of different disciplines,
Engineering, Operations and Maintenance, are now under one
collective group underneath our Engineering Manager, that
. 51
works closely with Operations. They now look at all the
different work packages, look at the surveillances, and look
at all the technical requirements in order to assure that we
meet operability to the fullest degree.
We have supplied from Operations three SRO's that
are full time to that particular group. That is
significantly different than we have had in the past.
Typically, it was relied solely on a work analyst type of
individual, to hope that he would get the right things, and
the screening process that would be done by our control room
personnel before they would actually call the equipment
operable.
MR. KUNDALKAR: Chairman Jackson, Commissioners, I
am Raj Kundalkar. I am the Engineering Manager for the
Dresden Station. I am one of the newer members of the team.
I joined the Dresden team in February of 1996.
Prior to that, I worked for the Florida Power and
Light Company for seven years and between 1992 and 1996, I
was the Engineering Manager at the Turkey Point plant, and
in that capacity, I was responsible for the engineering
team.
Today, I am going to summarize the results of some
of the key performance indicators. I am going to share the
results of the self assessment that we do in Engineering. I
am also going to show some examples of system performance
. 52
training and how we are using that information to identify
negative trends before they develop or come to surface.
Before I get to that, I will describe our efforts
and what we are doing to find out the hidden or latent
material condition problems. You had asked about this last
November and at that time, we were just starting the
project. We have recently completed the project and I will
summarize some of the results.
The latent material condition improvement project
was like the name says, go look for the hidden problems
before they come to you, implement appropriate PMT actions,
so that they do not become an issue.
We did this by assembling a team of very
experienced engineers from the industry, from General
Electric, Bechtel, Duke Engineering and also a team of
Commonwealth engineers, ComEd system engineering.
The approach the team took was review of the
systems' past performance, compare that to comparable
systems of comparable vintage in the industry, see how
failures in the past had been addressed in correcting some
of the past problems, do an extensive walk down of the
systems. Start with the operators, the systems engineers,
and also review the literature that is available from the
industry and the vendors to see if the recommendations and
the lessons learned over a period of a number of years have
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been implemented in our plant components and systems.
We have completed review of 27 systems. The first
thing we did was to review all the observations to ensure
there were no operability concerns and that indeed was the
case.
The second thing we did was we listed each one of
these observations under the individual system headings, and
then looked across the systems to see if there was any
common element or problematic issue that we needed to
address and a review of that is listed on the next page,
slide 36.
[Slide.]
MR. KUNDALKAR: The review identified two specific
areas that we needed to pay attention to, we were not doing
the right type of preventive maintenance. We were not doing
the right scope of preventive maintenance or we were not
doing it at the right frequency.
In addition, even though we were doing some
preventive maintenance, such as vibration analysis,
thermography analysis, we were not effectively using the
results of these trends into the system performance trending
and taking appropriate corrective actions.
I will address how we are going to take care of
those in the next couple of slides, but let me go on.
The next group of observations the engineers made
. 54
was that there were a number of recommendations that we had
not implemented. The team identified that from the past
failures, we had not found an appropriate root cause for a
number of problems and we needed to address those in a
timely manner.
The team identified that we needed to have a plan
to deal with the obsolete equipment, such as the electronic
cards in a number of our control systems. We needed to
develop a plan such that even if the original equipment
supplier goes out of business or does not provide support
for these components, we should have an alternate plan in
place, and we are doing something about that.
CHAIRMAN JACKSON: Where are you with respect to
that? That could get to be a big issue.
MR. KUNDALKAR: Yes. In the case of the EHC
system, these components, GE has alerted us that we are on a
last time order situation and then we are looking into other
suppliers, to come up with comparable equipment or
comparable cards for replacement. I could not give you a
numeric measure.
CHAIRMAN JACKSON: You have identified alternative
vendors?
MR. KUNDALKAR: We have identified alternative
vendors, not in all cases, but a number of critical cases,
where we can go to and then initiate a process for
. 55
replacement of these electronic cards, if you will.
Other issues the team identified was we needed to
pay attention to operator work arounds, a number of historic
problems have resulted in operator work arounds. Later on,
I will describe the results of that initiative.
We needed to pay attention to temporary
alterations, which are again a result of some portions of
equipment not working like they should. We needed to pay
more attention to configuration control of the plant.
We are in various stages of implementing these
recommendations. The middle block, for example,
prioritizing these and scheduling these to implement in the
balance of 1996 and 1997, whether we can implement these on
an on-line basis or it will require an outage to make some
of these improvements.
CHAIRMAN JACKSON: Have you prioritized them in
terms of risk?
MR. KUNDALKAR: Yes. That is the first step the
engineers have done. The way we did that was the key system
engineers for individual systems sat down with a review team
and looked at the importance of each one of these
observations to bring the important ones to the surface and
we will then implement them in that priority; yes, ma'am.
CHAIRMAN JACKSON: None of them are such that you
feel the plant needs to shut down to do?
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MR. KUNDALKAR: That is correct. None of those
have posed any outage concern or threat to safety of the
plant.
CHAIRMAN JACKSON: If I talk to you a month from
now and you have had some significant event, then none of
these things that you have identified will be a causative
factor?
MR. KUNDALKAR: Yes, our assessment is that none
of these will be the cause.
CHAIRMAN JACKSON: I am going to keep that in
mind.
MR. KUNDALKAR: Yes, ma'am.
COMMISSIONER ROGERS: Before you leave that, do
you see this as an one time project or are there some -- it
looks to me like some of them maybe things that you will
have to continue to keep your eye on and some things you can
deal with once and then they are done.
How do you see this latent issues finding process
going on in the future?
MR. KUNDALKAR: Even though the initial effort was
based on getting help from the industry experts, one of the
goals of that effort was we train our system engineers in
that process, so the next group of systems would be done
using in-house resources. Our first effort would be to
implement what we have found to date. We would plan, based
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on the priority of the systems, approach the next group of
systems until we come to a stopping point.
Next slide, please.
[Slide.]
MR. KUNDALKAR: Long before this material
condition improvement project was completed, we recognized
that we needed to improve our preventive maintenance
program. Therefore, early last year, in 1995, we assembled
a team of senior engineers, from Maintenance and also
Operations personnel, and systematically started looking at
our PM program, using the performance centered maintenance.
There is a template that Commonwealth has prepared
that is being used and we use that template as a guideline
in establishing the right type of PM's on the right
frequency and also give guidance on preventive maintenance
and what kind of data we need to collect and how that needs
to be fed back to the system performers.
Our goal was to do approximately 14 systems by
April 30. We have completed a review of 30 systems and
implemented the recommendations for five of those 30
systems. This effort will go on. By the end of this year,
we plan to finish review of about 50 systems and I don't
remember exactly, implement an additional 15 or so. This
effort will continue in 1997.
CHAIRMAN JACKSON: When do you expect, based on
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the systems you have identified so far, to bring the
implementation to closure?
MR. KUNDALKAR: The second quarter of 1997, and
I'm speaking from memory, is roughly the time frame where we
will have implemented all the recommendations of this PM
improvement project.
CHAIRMAN JACKSON: This is based on the 90 systems
you have identified?
MR. KUNDALKAR: Yes, ma'am.
As the number of the findings indicate, we have
made a substantial number of additions to the type of PM's
we need to do and also change the frequency as appropriate.
We will do a self assessment in July to see the
effectiveness of this process and if any corrections need to
be made to the program, we will make those.
[Slide.]
MR. KUNDALKAR: The next two slides are a look at
material condition from the operator's perspective. The
first one looks at operator work arounds. When the
equipment or systems do not perform their intended function
as designed, then the operators have to take some manual
action, additional action. That is what we call operator
work arounds. That places a burden on them, obviously not a
desirable condition.
In this initiative, working closely with
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Operations and Tim O'Connor's operators, our goal was to
drive the known work arounds to a small number and also deal
with any new work arounds that get identified so the backlog
keeps coming down.
CHAIRMAN JACKSON: Is your definition of "operator
work arounds" the same as or consistent with that of the
best performers in the industry?
MR. KUNDALKAR: Yes, ma'am. In my mind, Turkey
Point is one of the best performing plants in the industry
and it was the same definition used there. In fact, our
level of threshold for saying something is an operator work
around is lower than what was used, in my experience.
MR. T. O'CONNOR: It also benchmarked two other
SELP I stations and that formed the basis of the definition
that we are currently using for our operators to identify
items that would be considered work arounds.
CHAIRMAN JACKSON: How does your goal compare to
using this consistent definition?
MR. KUNDALKAR: Again, my experience from the
other plant, approximately 25 work arounds are open. The
issue was not how many work arounds --
CHAIRMAN JACKSON: That's right, how significant.
MR. KUNDALKAR: How significant they are and
immediately addressed if there is an operator concern or a
safety concern. As long as you have established that, you
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have a sufficient amount of time to implement corrective
action, as long as you schedule those and work them out on a
priority basis.
Our goal was by April 30, to bring the backlog
down to 30. In fact, we have met that goal and exceeded
that goal. As of April 30, we were roughly at 27. We have
established an end of year goal where we plan to be at 20 or
below. I expect to meet that goal.
[Slide.]
MR. KUNDALKAR: The next slide, again, examination
of material condition from the operators' perspective. The
control center control room properly functioning is an
essential part for an operator to be effective in his job,
and therefore, if any deficiencies are identified in
monitors, controls, they need to be resolved in a timely
manner and expeditiously, so the goal of this effort was to
work closely with Operations again, establish priority, and
with the help of Maintenance, work off and resolve these
control room deficiencies, such that the operators would get
a well functioning control room, indications as well as
controls.
Before we started up Unit 2, for example, we only
had two control room deficiencies open on that particular
unit. They were of low importance, low significance. One
was a temperature indication in a heater bay and another one
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was re-calibration of a particular recorder. Operators have
complimented this effort, saying this is the cleanest they
have seen the control room in many years, in the recent
past.
We have established a new goal for the end of the
year to be 20, and I expect to meet that goal.
[Slide.]
MR. KUNDALKAR: I am on slide 40 now, and the next
slide is unplanned LCO/DATR days.
This is a major wait period for ourselves. This
is a measure to see the effectiveness of our PM program,
preventive maintenance program. If we are tracking the
performance of the system and then predict potential trouble
or a breakdown and before that occurs, take appropriate
corrective action, then we would not have to have unplanned
LCO's to take those corrective actions. If you are not
doing the right performance monitoring, then when the
equipment breaks down, we would have to enter unplanned
LCO's to take the corrective action.
DATR days are for smoke detectors, emergency
lights, things of that nature.
As the picture indicates, the heavy blue line is
the number of unplanned LCO's. It is definitely trending
down to a low number. The thin blue line, which looks like
a combination of the LCO days and DATR days, is again
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trending down. Our goal of being less than three unplanned
LCO/DATR days per unit has been met and we will continue to
track this measure to again examine the effectiveness of our
PM and preventive maintenance program.
[Slide.]
MR. KUNDALKAR: The next three slides look at
performance of our safety systems and how we compare against
the industry average. We do that by comparing the
unavailability of a system, defined as the number of hours a
system is unavailable, divided by the total number of hours
it needs to be available.
The first picture looks at high pressure coolant
injection and isolation condenser system. The industry
average there is indicated by the red dotted line and the 12
month rolling average is shown by the blue line. We beat
that goal on both units. Even though we have beat that
goal, we are not satisfied with this performance.
As you see with the yellow bars, they indicate
some corrective actions of planned maintenance activities we
are to perform. We need to do more work in this area and I
expect to further improve the performance of the system in
the upcoming six months.
The next picture is performance of our low
pressure coolant injection and the shutdown cooling system.
Again, the red dotted line is the industry average. On both
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units, we meet or exceed the goal we have set for ourselves.
The large blip you see in April of 1996 was because of a
planned corrective action for the LPCI system. That is why
you see that number.
The next picture is a similar look at our
diesel's. The industry average for unavailable days, and at
the end of April, we met that goal. The large bar you see
in the month of February was again a planned maintenance
overhaul of our diesel's. When we took a diesel apart,
there was some additional discovery items, so we decided to
take the extra time and fix the diesel's, such that they
would perform later on. We do meet our goal and we plan to
continue to monitor this goal.
The next picture is a look at temporary
alterations. These are temporary modifications when
equipment does not perform as desired or as designed. These
are temporary means of fixing them. In some cases, they are
also required to monitor certain plant parameters, so they
are not always to take care of band-aid type solutions.
These may be specific plant alteration which may require
some installation of instrumentation to monitor certain
types of performance.
Even though the picture shows the performance in
the year 1996, prior to that, which is not shown on this
curve, we have identified and resolved approximately 120
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temporary alterations. These have been as a result of the
system engineers and Operations personnel taking a proactive
role in identifying them as part of their walk downs and
then Engineering either eliminating them or implementing the
appropriate modifications so you would not have to rely on
temporary alterations.
Again, our end of April goal was to be less than
10 non-outage temporary alterations and we have met that
goal.
We established a higher goal for the end of the
year, seven or less than seven temporary alterations.
[Slide.]
MR. KUNDALKAR: Next slide, please. This is an
example of how we are tracking the performance of our
systems, the performance of our systems is tracked and
trended using a number of measures, individual performance
criteria in terms of availability or unavailability, and
then tracking if there are any unresolved operator concerns
or industry issues.
CHAIRMAN JACKSON: Is this a monthly monitoring
system or quarterly?
MR. KUNDALKAR: Yes, ma'am, it is a monthly
measure and a similar type of window is created or set of
windows are created for all systems. These are examples of
the type of criteria or performance measures that are used
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to see what is the status of that system and it is displayed
in a color format, going from green to red.
For example, in the control rod drive system,
there is a known industry issue about the SSPV's, the scram
solenoid pilot valves, and GE has identified that and we are
in the process of changing that material. Even though we
have planned and are in the process of implementing this
corrective action, the color of this window would remain
yellow until we have fully resolved the issue, which would
be sometime in June of this year.
CHAIRMAN JACKSON: You are changing them out or
changing them out again?
MR. KUNDALKAR: We are changing them out with
improvement of material that GE is trying to supply to us.
CHAIRMAN JACKSON: I thought there was an issue
having to do with going to some new material and then there
was some questions about the performance of that new
material.
MR. KUNDALKAR: The material we will be using to
change them out with will be the new improved material.
CHAIRMAN JACKSON: All right.
MR. KUNDALKAR: Again, I use this performance
indicator to assess where we need to apply more attention,
apply more resources and what kind of corrective actions we
need to take.
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CHAIRMAN JACKSON: This is monthly, you said?
MR. KUNDALKAR: Monthly indicator. It is
displayed on the wall of the Engineering hallway. It is
very visible to not only me but the plant management and
used to question us as to how we are doing in those areas.
The next page is a hard look at ourselves, a self
assessment of all aspects of work that Engineering does.
Those are listed in that left-hand column. For each one of
those categories, there is a performance criteria
established. It is a numeric goal. Whether we meet or
exceed that goal determines what color window it would be.
We are doing well in the area of unplanned LCO's,
meeting critical surveillances, operator work arounds,
control room correctiveness.
In the area of engineering backlogs, the window
has been red, and I will address that in a minute. In the
case of significant events, actually these are personnel
errors, the window has been red because on the 9th of
February, there was an error made by an engineer in doing a
specific surveillance which was to examine the fuel
consumption rate for a diesel fuel oil transfer system. Our
criteria in Engineering is more stringent than the plant's
criteria. Our criteria is if an error is made, you need to
have 90 days of error free performance before you can change
the color of the window, and 120 days before a yellow window
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can become white and 150 days before it can become green.
As we sit here today, the color of that window
would be yellow, and if we continue the same trend, I expect
we will see that change to white and green.
In the case of engineering backlogs, we do have a
large number of engineering items to resolve in the backlog.
They are a combination of things. They are not necessarily
modifications awaiting engineering resolution. In a number
of these cases, these are questions asked by Maintenance for
some specific type of information and in some cases, these
are types of activities you do to help construction, such as
scaffolding requests, shielding requests, insulation
requests.
At the same time, I do have a large backlog, and
with the additional resources that have been made available
to me, we are again prioritizing and scheduling resolution
of this backlog. We plan to bring it down by the end of
this year and by the middle of next year.
CHAIRMAN JACKSON: Where do you stand relative to
design basis documentation and FSAR issues?
MR. KUNDALKAR: Let me take the design basis
documentation first. We have an initiative to improve our
design basis documents. For this year, our goal was to
complete 25 systems, to create design bases for 25 systems.
We are on track to finish that work. We have completed, I
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believe, approximately 23 systems, and by the end of the
year, we will have completed detailed design basis packages
for 25 systems.
In the case of FSAR, we have a number of
initiatives in place. Let me answer that in two parts. Our
FSAR was re-baselined in 1992/1993, and by that I mean all
the open outstanding issues, LER's, correspondence with the
Commission, and any other known issues, changes to
procedures, were incorporated in what we call a re-baselined
FSAR, and that was submitted to the Commission, again, based
on some interaction and comments we have had from you.
Recently, prior to Unit 2 start up, we undertook
an extensive look to examine if any of these backlog items
that are on the table have any impact on what is in the
FSAR, do they cause any deviation from the FSAR. We did not
only look at open engineering backlog items but also LER's,
are there PIF's, problem identification forms, open work
requests, where the work request has not been implemented,
and we have found there is some clean up needed in
approximately 30 to 35 items.
In addition, we need to do some modifications to
the plant, and I think it was on four specific occasions
where we implemented those modifications prior to restart of
Unit 2.
Starting now, to the end of the year, the
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initiative we have now in place would look at all sections
of the FSAR, working closely with Operations. The combined
team with Operations would review individual sections to see
if the operating procedures are in sync with FSAR and if
not, then take appropriate corrective action.
Some additional resources have been made available
to us, just to address this issue.
In addition, our corporate engineering group has
done a self assessment of our activities prior to start up
of Unit 2, and also how we are planning to look at the FSAR,
starting now to the end of the year.
CHAIRMAN JACKSON: Do you feel that by the end of
the year, there won't be any issues?
MR. KUNDALKAR: I expect we will be in good shape
by the end of the year as far as FSAR compliance is
concerned; yes, ma'am.
Finally, we have strengthened the training for our
engineers. It was done as a result of self assessment again
and we benchmarked it against three plants in the industry
that are considered to have strong training programs. From
those lessons that we learned, we improved the quality of
our fundamental training, which is similar to what is given
to the operators. These will be items such as reactive
theory, thermodynamics, process controls. All that training
has been completed in the last year for all the engineers.
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The second part of that training --
CHAIRMAN JACKSON: This is for the design as well
as the system engineers?
MR. KUNDALKAR: Design as well as the system
engineers and we also included engineering support
personnel.
The second part of that training was systems
training. We used the same modules the operators use for
their systems training, but then we increased the emphasis
on the design basis type information in those training
modules as opposed to the items that are normally memorized
by operators, check valve numbers and things like that.
From our perspective, it was more important to
emphasize the design basis information as far as the systems
training and the interrelationship and interaction within
the systems.
That training is on track, the portion that we
were supposed to complete by April 30 has been completed.
The last batch, as we speak, is finishing up their
examination. It is the last set of system engineers.
Our goal is to allow them to work inside the plant
only after they have met the training requirements and
successfully finished the training. In fact, I, myself,
took this training to orient myself in the plant and second,
to make sure that the training had adequate breadth and
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depth in all the aspects of system related items that I
expected the training needed to have.
In the second phase of training that we plan to do
in the latter part of this year, we will address some
specialized areas, like changes to the modifications that we
have done, station blackout, diesel installation is probably
one example, and some specialized topics, such as terminal
performance, so we can further improve our efficiency of the
secondary site.
CHAIRMAN JACKSON: You plan to keep your PRA up to
date as you modify the plan?
MR. KUNDALKAR: Yes, ma'am; absolutely. That is
correct.
In conclusion, Chairman Jackson, Engineering's
role is to support Operations and Maintenance in the plant,
based on the performance indicators we have seen, safety
system performance indicators, as well as working off the
backlogs, start up of Unit 2 and the smooth operation of
Unit 3, demonstrates that Engineering is supporting the
plant like it should.
We are not only fixing the known problems, but
like I described, we are going after the hidden problems.
We are upgrading our PM program and preventive maintenance
program. Even though we are satisfied with the goals we
have reached on April 30, that is not the end of the job and
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we have established the next level of goals to be met by the
end of the year, and with the same momentum that we have, I
expect to meet those by the end of the year.
MR. PERRY: Chairman Jackson, I have under ten
minutes to finish this.
Page 49, please. Again, this is a synopsis of
your letter. The first question I will address is the last
question on the page, will the improving trend continue.
We have been asked before about the performance at
Dresden, up and down. When we were here in November,
Commissioner Rogers and you, Chairman Jackson, asked the
same question in a slightly different form, and that was we
have heard all this before, why is it different this time.
That to me is just a restatement of the question.
I will answer this by approaching it the same way we
approach issues in the nuclear industry, and that is to
first try and identify the root causes and then we will
address the corrective action for the root causes.
I see two issues here. The first one is in years
past, Dresden has been unwilling to face the reality of
their performance. They just did not think they were that
bad. They would respond to external stimuli, either from
the NRC or from INPO, and put a program in place to deal
with it, frequently see an improvement in performance as a
result of that program, but when the stimuli was removed or
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diminished with age, there was no inner drive at the station
to continue the program, and so it would frequently languish
and performance would tail off again.
The second issue is accountability or more
accurately, lack of accountability. Managers at Dresden
didn't hold themselves accountable, didn't hold their
subordinates accountable, their peers accountable, or their
seniors accountable. As a consequence, when a program did
languish, that was okay because I didn't feel accountable
for it.
Those two issues are the basis for what I view as
the root causes for the cyclic performance in the past. How
do you address that? What we have done, I think, is the
same answer for both of them, and that was Mike Wallace
addressed it in November when he said we were changing the
leadership, and we have changed the leadership at Dresden.
We have brought in new managers. In fact, six of
the nine managers, the top managers at the site, are from
other utilities, who were all in a turnaround situation. In
fact, five of the six individuals are currently in the same
position they were at the utility they came from. There is a
lot of experience there.
Go down one level into the middle managers, 21 of
those, 11 of those are new. All of them are from either
turnaround plants or plants that were performing well.
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These individuals, when they see a mess, they
recognize it as a mess. They call it a mess and they deal
with the mess. They all were grown up with accountability.
That is how they achieved success in the places they came
from. They held themselves accountable and they held
everyone around them accountable.
These individuals here whom you have heard speak
today are representative of the people we have on the site.
Accountability is a way of life at the station, and you
heard us talk about how we are holding people who work for
us accountable and how we are trying to drive that thought
process down into the work organization, particularly
targeting the first line supervisors and encouraging them to
get it into their people in the workforce.
We are having some measures of success. We are
teaching our first line supervisors, both formally in a
classroom environment and informally, as you heard here, on
how to run their people, how to hold their people
accountable.
For example, we have given each of the first line
supervisors -- in fact, everybody who supervises anyone at
the site from me on down, we have given them four days of
training on how to deal with the bargaining unit, something
we haven't done well in the past. It has had an immediate
identifiable effect on the site that we as the first lines
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and their superiors are now running and managing the
station.
Our approach to this issue is to get the first
lines to run the plant on a day to day and week to week
basis. I would predict that in about a year to a year and a
half from now, they will be indeed running the station and
there won't be anything that I or these other managers can
do that will turn them around because once they get the
taste for running it, they won't permit me to allow cyclic
performance at the station.
The second question was does our workforce
understand and implement our standards.
[Slide.]
MR. PERRY: If we turn to the next slide, the way
I approached this problem was to commission two assessment
teams. I asked my Plant Manager to put together a team of
line managers and I also asked my quality organization to
put together a team.
The line managers consisted of a middle manager
and six others who were divided between working level
individuals and first line supervisors.
The second bullet shows the areas that they looked
at, pretty wide view of what was going on at the site, and
the results are indicated under the "Results" bullet. The
first one was what the management team came up with and they
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felt there was a strong understanding and implementation of
standards throughout the site.
Quite frankly, I think they missed the mark there.
I don't think we are as good as that. My personal opinion is
that although people understand and are aware of the
standards, they have not yet internalized it to where they
on a minute to minute basis with their hands, what they are
doing, can relate to those standards.
I think that the management team found a lot of
enthusiasm and energy to try and get better and they mistook
that for real implementation of the standards. I will give
some evidence of that a little bit later.
In fact, one piece of evidence is what the quality
organization found. I thought that was a much more balanced
look at the situation, and I will give you an example of
that, talking about self verification, which we like most
utilities in this industry in this country, use the START
program, which means to stop, think, then act and then
review what you see against what you expected to see.
What the quality organization found is that there
was widespread understanding and awareness of STAR. In
fact, they saw many examples where the supervision
reinforced those principles in pre-job briefs and tailgate
meetings and the like, but when they observed people in the
field, they found that outside of Operations, Operations
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does a very good job at this, both in the control room and
outside the control room, but the other people in the field
had inconsistent application, which is what was in my mind,
that everybody understands it, but they don't know what it
means when they are going to do this particular item
necessarily.
It is an area that we are going to continue to
work on. I did bring one piece of anecdotal evidence, if I
may. In early April, we had a licensee event report occur
on Unit 2, which was shut down at the time, when we were
doing maintenance and had expected an alarm. The operator
was briefed on what to do, which was basically to silence
the alarm. He in fact pushed the wrong button. He pushed
the manual Scram button, which was an event that reset our
clock and also prompted our licensee event report.
Several days after that, in the Dresden Daily
News, which is published fairly independent of me, this
article appeared that he conjoled the Editor into including
in this, without any management prompting, this individual
is a reactor operator, bargaining unit individual -- I'd
like to read the paragraph to you.
"A few days ago, I placed Unit 2 through an
unnecessary transient. It was a mistake on my part. My
attitude toward mistakes has been that honest mistakes will
happen. My mistake was 100 percent avoidable. I now
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realize that in itself makes it a selfish act on my part.
Like many of you, this job is my livelihood. I depend on
it. The success of this station will be determined by the
success of its people. I let all of you down by committing
this selfish act and I cost the station a black eye. The
concept of STAR when practiced might not catch an honest
mistake, but it will prevent avoidable ones."
He goes on for about five paragraphs explaining
the STAR process and winds up saying "In closing, I wish to
extend my apology to everyone here at the station."
This is at least one individual that fully
understands what the standards are we are trying to impose
throughout the site.
If we could go to the next slide, please.
[Slide.]
MR. PERRY: This is just a wrap up of all of the
performance targets that we said we were going to achieve
and I want to make some points here. The top six items
there, the goals we set for ourselves, were all significant
improvements over performance in 1994 and earlier. The
bottom two were new measurements that we created at the
site, so there is no history on those.
If you go down to the fifth one where it says zero
preventive maintenance past critical. "Past critical" means
beyond the grace period and usually 25 percent of the
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interval that the PM is performed. We had over 150 of these
that were past the critical date.
In fact, when we went back, we decided that we
were going to make this applicable to all PM's, whether they
were beyond the critical date or not, and we had about 480
of those.
When we presented this to the preventive
maintenance coordination group that schedules and
coordinates these things, their response to us was
impossible, and yet we achieved it. The point of my giving
you that little story was just to establish the credentials
of these being tough goals, because that was a tough goal.
Similarly on the next page, we went through our
safety system performance and the industry's national
average, which is much lower than the goals that the
industry had set for itself, the industry is performing very
well in here, and for us to meet the national average as
good performance, and we are better than the national
average in all five of these.
Similarly, we discussed at some length the
Operations events. These goals that we set for ourselves
were much better than 1995 performance. We didn't achieve
them but the goals were tough goals.
Finally, on the last page, again, I want to single
out one in particular. It is the zero overdue corrective
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actions. We hadn't prior to this point addressed that one.
In the Summer of 1995, we had several hundred corrective
actions that were overdue, beyond the due date. We put an
effort into that and did drive those down to zero by the
month of October. We set a goal, a perpetual goal, in
effect, to have zero overdue corrective actions. We wanted
to achieve that, to have none between October and April 30.
We didn't achieve that goal. We had four overdue
actions and we extended it beyond just corrective actions to
everything that was in our tracking system, the bulk of
which is corrective actions, but not completely.
We did over that seven month period, we closed
1,900 items, four of them were overdue. That means they
missed by one day. That is all it takes to get the bean
counted.
I think it is clear that, too, is a very tough
goal. We viewed all of these as tough goals. Just to
reiterate what I said in the beginning, to achieve 68
percent of them is clearly a good performance in my mind.
You can form your own opinion, of course.
I will finish up by saying the following; talking
to a reactor operator in a control room a month or so ago,
he made a comment, I've never seen that work before. It
struck a cord with me. I collected the never seen before's.
These are from the control room operators who have been at
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Dresden for 10 to 15 years, and in that 10 to 15 years,
these individuals have never seen these things before.
The feed water control system working, three
element control and automatic. We are still on Unit 2 in
the middle of testing it, but we have been operating it
automatic in three element control for many months on Unit
3. Never seen before.
Two steam generator rejector and off gas trains
working on each unit. We have had one operating for as long
as any memory exists on this site and we have put both of
them back in operation.
Unit 2 reactor vessel drain, which has been
clogged up. We showed you the pictures when you were there
in December and probably some construction days. That is
now clean and operable.
The booster pump, feed water booster pump minimum
flow valve is now operable from the main control room area.
Operators have never seen that before.
The Unit 1 fuel storage pool. You can see the
bottom of the pool. Never been able to see that before.
Service water radiation monitors work properly.
Hydrogen analyzers, which monitor the hydrogen in the
containment, work properly. You already heard Raj say that
the main control room panels on Unit 2 have never been so
clean in terms of deficiency tags.
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To provide a balanced view, after a week of this,
I decided to ask the operators what they had not seen yet,
and the predominant answer, in fact, almost exclusive
answer, is we have yet to see an outage performed for the
plant. That is what we have to work on.
That concludes my statement.
CHAIRMAN JACKSON: Thank you very much for a
comprehensive briefing. Do you have any further questions?
COMMISSIONER ROGERS: I have one question. I
thought this was very helpful and very informative. One
matter that nobody touched on was your IPE. We had a
briefing a few days ago on the status of all the IPE's. I
noticed that ComEd had several IPE submissions that didn't
meet the intent of the NRC's generic letter.
I wonder if one of you would care to comment on
the Dresden one, but Quad Cities and Zion also did not meet
the NRC's intent of the generic letter, and I wondered
whether you had something to say on those matters.
MR. KEISER: We have met with the staff on the
issue and have plans in place to resolve the discrepancy,
the differences, if you will, and resubmit. It has been an
agreed to plan with the Commission. It is actively on the
way. It has to do with how we treated the human performance
or human errors within the IP.
COMMISSIONER ROGERS: That is a common factor for
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all of those?
MR. KEISER: Yes, sir.
COMMISSIONER ROGERS: Human factors?
MR. PERRY: Right.
COMMISSIONER ROGERS: You feel comfortable that
you can do that?
MR. PERRY: I think the commitment now for Dresden
is in June, as I recollect, that we will have it submitted.
MR. KUNDALKAR: June of 1996; that is correct.
CHAIRMAN JACKSON: Commissioner Dicus?
COMMISSIONER DICUS: One quick question. You
identified what you thought were two root causes of problems
that you have been having and some fixes for those. I was
curious, for this get well plan and for where you hope to
be, what do you think is the major obstacle you face?
MR. PERRY: Any time you try to change the culture
of people who have grown up in that culture for 15 or 20
years, it is a big effort to change people's mind about
things. I believe that the way you do that is with energy
and enthusiasm at the top and getting the first line
supervisors to accept their role as managing the site, which
I have described in some detail, and hopefully with
enthusiasm, that is where we are driving. That is our
obstacle, to get everybody to change how they grew up.
CHAIRMAN JACKSON: I have a question for you, Mr.
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O'Connor. It is not one that CEO's like people to ask them.
Let me ask you this. You have various initiatives to deal
with deregulation and competition. Can you assure us that
these initiatives will not compromise your ability to
continue the improvement path you have started on at
Dresden, as well as to improve the performance of a number
of other plants?
I guess the question essentially becomes how do
you avoid such impact, given the resources that may be
required and given the amount that you have already put into
the plants this year, the figure that you talked about
earlier.
MR. J. O'CONNOR: Chairman Jackson, having read a
number of the things that you have said recently on this
subject of deregulation, I would just simply like to say
that we believe that to succeed in the competitive
marketplace going forward will require that we have safe and
reliable and high capacity factor nuclear power plants.
In order to get to that level, we are going to
have to apply the resources that are required. The two do
go hand in hand. We understand that. We have a Board that
is committed to do that. I think there is no
misunderstanding on the part of the people in the nuclear
line organization in being responsive to their requests,
that we are prepared to do that going forward.
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CHAIRMAN JACKSON: I would like to thank you again
for briefing the Commission. Your presentation today has
provided the Commission with a clearer idea of the path that
you are following and the status of your efforts to improve
station performance at Dresden.
You appear to be on a progress path. I will say
that. I can't stress enough the importance the Commission
places on the need for continued progress and focused
management attention to prove to yourselves as well as to us
that your efforts are effective.
Everyone here practically is new in these key
areas. I know that Mr. Maiman is new in this position and
Mr. Swafford mentioned he had only been in the job for five
months, and Mr. Kundalkar mentioned he had been at Dresden
since February.
It seems that you finally are really dealing with
self assessment and accountability. It is important that
the response to the issues at the lower levels is clear.
I urge you not to rest on the fact that you have
gotten started, because really what you are doing is you are
struggling up the hill to get to industry norm's. I
remember when you were here before and I talked about that a
little bit. There were comments that, well, you have
improved but the industry is going on. Now we are entering
more and more a period of deregulation and competition.
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It is kind of a colloquialism but it is true that
if you are going to play on the field, if you are going to
come play in the game, you have to play with the teams on
the field.
If you are struggling up the hill to get to
industry norm's, then that says that sustained performance
is important.
Just from some previous experience, I would say
that unless significant events and re-work is reduced, that
your chain of improvement is questionable. You have had a
focus on Dresden since my letter to you, but you do have the
rest of the system, which is also of concern to the
Commission. For example, Quad Cities. One issue, as an
example, is unknown material condition problems at other
plants.
I would just throw that out. Again, that is why I
asked you the question, Mr. O'Connor, and that Commonwealth
Edison has to devote sufficient resources to not only
maintain the trajectory at Dresden over a longer term than
we have had a chance to see so far, but to maintain the safe
operation and make step change improvements at the other
facilities that you have.
Based upon the Commission's concerns with Dresden,
the performance of Dresden and the other Commonwealth Edison
plants, we will be continuing to monitor closely the
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performance of Dresden and your other plants and assess them
as we go along, because if the improvement trends are not
sustained, you have to consider yourselves, perhaps shutting
yourselves down to get your hands, if you can't do it --
that is why I asked the question about while the plants are
operating, and you have significant events, that you need to
just figure a methodology perhaps to shut yourselves down to
get your hands around the issue once and for all.
We can't have it go on. As I say, you appear to
be on an improvement trajectory. I will put it that way.
"Trajectory" means an initial velocity and a direction.
We have to see how it all comes out. Again, I
thank you for the comprehensive review that you have given
the Commission.
If there are no further comments, we are
adjourned.
[Whereupon, at 3:50 p.m., the briefing was
concluded.]
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