IR 05000346/1983023
| ML20132B710 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Davis Besse |
| Issue date: | 12/12/1983 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Gilinsky V NRC COMMISSION (OCM) |
| Shared Package | |
| ML20132B273 | List:
|
| References | |
| NUDOCS 8312230206 | |
| Download: ML20132B710 (1) | |
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MEPOPRiD"M FOR:
Canaf ssioner Gilinsky FROM:
William J. Dircks Executive Director for C,,erations SU3 JECT:
DAVIS BESSE REGULATOP.Y IP.PROVD'!hT PROGFAM Recognizing your interest in the regulatory performance of Toledo Edison Company's Davis Besse facility I am sending you a copy of a report describing a meeting held by Region III and the Office of Nuclear Rea ctor Regulation with the company. The raeting was held to launch a Regulatory Icprovement Program at this facility.
If you have any questions on this matter, we would be pleased to discuss them.
(S!;::ef Wi!! am J. Dir:ks
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William J. Dircks Executive Director for Operations Inclosure:
Ltr from Davis to Toledo Edison, 11/23/83 DISTRIBUTION
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Chairr.an Palladino cc:
Dircks Comissioner Roberts Roe Commissioner Assel.stine Rehm Co c.issioner Bernthal tello OPE Keppler OGC 0 Ut0D SECY DeYoung
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M r. Janes C. Kepple r, Regional Administrator
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United States Nuclear Regulatory Commission
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799 Roosevelt Road
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Glen Ellyn, Illinois 60137
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Dear Mr. Keppler:
Your letter of October 1,1984 (Log No. 1-1037), regarding the Perfor=ance Appraisal Inspection 50-346/84-19, identified specific weaknesses with the General Employee Training (CET) Program, at the Davis-Besse Nuclear Power I
Station, Unit No. 1.
Specifically, the Nuclear Quality Assurance Manual and AD 1807.00, Control of Conditions Adverse to Qual'ity, place a high reliance on the ability of all employees to recognize and identify conditions adverse to quality, and this topic was not covered in the GET Program.
In Toledo Edison's letter of December 14, 1984 (Serial No. 1-488), a commit-ment was made to revise the GET Quality Assurance Module by February 1, 1985.
Included in the revision to the module is a discussion on the philosophy of quality assurance, including an individual's responsibility to the Quality Assurance Program.
This portion was scheduled to be presented by the President and Chief Operating Officer of the Toledo Edison Company.
After the module script was written and approved by the President of the Company, he became unavail-able for photography and recording due to medical reasons.
This has resulted in the inability to complete the revision to the module by the schedule * date.
The revised GET Quality Assurance module will be completed by Febr'uary 28, 1985.
Very truly yours, ff,= = ^
RPC : SG'a': ni f cc:
DB-1 NRC Resident Inspector GW120+1-1-850131 PDR ADOCK 05000346
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March 4, 1985 Mr. James Regional Administrator, Region III United States Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Kepple r:
In accordance with Toledo Edison's commitment to provide supplemental information to the Davis-Besse Systematic Assessment of Licensee Performance (SALP) report response (Serial No. 1-497) submitted on February 4, 1985, I am pleased to submit this letter and its associated attachments.
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This supplemental information was requested by Messrs. W. D. Shafer and W. Rogers of your staff during a telephone conference call with Toledo Edison (TED) representatives on February 19, 1985. The enclosure lists the NRC Staff's requests and TEDS responses.
These responses have been incorporated into Attachments I, II and III of TEDS February 4, 1985, submittal. Attachments I, II and III are enclosed and the responses incorporated are identified by margin revision bars.
Attachment IV is new and lists the Performance Enhancement Program Action Plans in response to NRC Request No. 12.
I am looking forward to meeting with you on March 6, 1985 to further discuss these and other TED activities which support our commitment to improved regulatory performance.
Very truly yours, ffk= ---
RPC:DRW:lah attachments cc: DB-1 NRC Resident Inspector THE TCLECO EDISCN COMPANY ECISCN PLAZA 3C0 MACISCN AVENUE TOLECO, CHIO 43652 c> s s, o -~
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ENCLOSURE TOLEDO EDISON SUPPLEMENT TO SALP RESPONSE NRC REQUEST /TED RESPONSE NRC Request No. 1:
During the January 4, 1985, SALP presentation, TED committed to having its senior management visit the plant on an increased basis:
A.
This includes which specific TED senior management individuals?
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B.
At what frequency will these individuals visit the plant?
C.
How will visit findings identified by these individuals be documenced?
D.
What mechanism will TED use to ensure that these findings are tracked i
and resolved?
i TED Response No. 1:
See Attachment I for TEDS response.
NRC Request No. 2:
Regarding TEDS response under Serial No. 1-497, Attachment II,Section I.B.1, Plant Operations -- Adherence to Procedures, and TEDS increased efforts to ensure attention to detail by the control room operations staff through:
(1) Discouraging the access and limiting the visit duration of non-essential personnel in the control room.
(2) Encouraging professionalism by the operators.
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(3) Reducing nuisance alarms.
A.
Please discuss the measures you have taken or will take to ensure that above items (1), (2) and (3) are accomplished and continue to be ecmplied with.
B.
For above item (3), please identify the number of nuisance alarms that exist, the priority for removal and the proposed milestones for completion.
C.
In addition, please identify the mechanism for handling future nuisance alarms.
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TED Response No. 2:
See Attachment II,Section I.B.1, for TEDS rexponse.
NRC Request No. 3:
Please address personnel accountability for procedure adherence under SALP response Section I.B Adherence to Procedures.
TED Response No. 3:
See Attachment II,Section I.B.1 for TEDS response.
NRC Request No. 4:
Regarding TEDS response under Serial No. 1-497, Attachment II,Section I.B.3, Plant Operations -- Recognition of Design Basis Requirements, please discuss the following items under the USAR review:
A.
How the review really will be performed.
B.
How results will be disseminated to the rest of the Nuclear Mission.
C.
What chapters will be covered by review.
D.
What are TEDS plans for Chapter 15, " Accident Analysis".
NOTE: At a minimum, please state that these are things that TED will do in the future. TED can discuss it in the broadest of terms, i.e.,
it is not necessary to go into considerable detail.
TED Response No. 4:
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See Attachment II,Section I.B.3 for TEDS response.
NRC Request No. 5:
Your SALP response did not discuss the problem of jumper and lifted wire log entries.
Please address how TED plans to reduce the number of jumper and lifted wire log entries.
TED Response No. 5:
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i See Attachment II,Section I.B.4 for TEDS response, j
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Regarding TEDS response under Serial No. 1-497, Attachment I,Section II.B. Maintenance -- TED Corrective Actions does not describe the known backlog of Maintenance Work Orders (MW0s).
Please identify:
A.
The number of outstanding MW0s.
B.
Your proposal for reducing this number.
C.
The method to ensure the MWO backlog will be monitored by management.
Please include milestones as appropriate.
TED Response No. 6:
See Attachment II,Section II.B.1 for TEDS response.
NRC Request No. 7:
Please identify when TED plans to complete construction of the Personnel Shop Facility.
TED Response No. 7:
See Attachment II,Section II.B.1 for TEDS response.
NRC Request No. 8:
Regarding TEDS response under Serial No. 1-497, Attachment II,Section III.B, Emergency Preparedness -- TED Corrective Actions:
A.
Section III.B.1 -- Emergency Preparedness QA Audit Requirements:
TEDS Corrective Action, regarding the checklist for QA audits, may be a violation of regulations on QA independence.
If QA lacks technical understanding of the program, it should have an outside consultant perform a review or contact another utility or INPO.
Emergency Planning should not be involved with the audit checklist prior to the audit.
B.
Section III.B.2 -- Tracking Emergency Preparedness Activities.
Please provide more specificity, include specificity on the commit-ment for scheduling routine activities on the following items:
1.
General items described in the Activity Tracking System.
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2.
How will TED handle future commitments.
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3.
How will this system interface with the Licensing Commitment Tracking System.
4.
What type of items will be included as commitments and routine activities.
5.
How will TED ensure coordination between groups.
C.
Section III.B.3 -- Preparation for and Performance of 1985 Emergency Preparedness Exercise:
Discuss who is on the Scenario Development Team.
NOTE: ' TEDS responses to Request No. 8 A, B, and C, should address:
completion of corrective actions for NRC concerns, audit findings, drill or exercise identified weaknesses and disposition of audit observations or recommendations, procedure revision requiring assist-ance from other departments, disposition of training feedback recommend-ations, and drill or inventory requirements.
D.
Section III.B.4 -- Emergency Preparedness Training How will TED management assure an understanding of the material?
TED Response No. 8:
A.
See Attachment II,Section III.B.1 for TEDS response.
B.
See Attachment II,Section III.B.2 for TEDS response.
C.
See Attachment II,Section III.B.3 for TEDS response.
D.
See Attachment II,Section III.B.4 for' TEDS response.
NRC Request No. 9:
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Regarding TEDS response under Serial No. 1-497, Attachment II,Section IV.B.3, Quality programs and Administrative Controls -- Management Overview, please discuss the following:
A.
How will TED supervisors know when they are suppose to attend QA exit
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inte rviews.
B.
How does TED let senior management know if they should attend?
TED Response No. 9:
See Attachment II,Section IV.B.3 for TEDS response.
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NRC Request No. 10:
Please discuss how will TED formally control the interchange of spare parts between similar components.
TED Response No. 10:
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See Attachment II,Section IV.B.4 for TEDS response.
NRC Request No. 11:
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Please provide a commitment to accomplish the Action Plan items developed from your training diagnostic of April, 1984.
Include milestones as appropriate.
I TED Response No. 11:
See Attachment II,Section V.B.4 for TEDS response.
NRC Request No. 12:
Certain Performance Enhancement Program (PEP) Action Plans are in place, which will assist TED in improving regulatory performance.
- 4e would like to see TED. list these in Attachment IV to the SALP response in order-to give recognition to this ongoing work which has appropriate milestones, etc. in place.
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The titles and identification number of these action plans are as follows:
A-2 Integrated Approach to Goals, Objectives and Strategic Plan A-3 Management Training
B-5 Personnel Division Resources C/CM-1 Configuration Management D/FP-1 Development of Fire Protection Program
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D/L-1 Commitment Management D/QA-1 QA Awareness Program
D/QA-2 QA Procedures Review Group
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D/QA-3 QA Auditor Commensurate Training Program
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l D/SM-1 Safety Evaluations i
D/SM-2 SRB Performance Criteria D/SM-3 CNRB Meeting with Corporate Management D/SM-4 CNRB Training D/SM-5 Appointment of CNRB Sub-Committees for Review / Screening of Routine and Periodic Documents D/SM-6 Improve Preparation of CNRB Members Prie-to CNRB Meeting
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D/SM-7 Submit Appropriate Information to the CKRB for their review
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D/SM-8 Provide Procedures to Control Nuclear Safety Related Activities D/SM-9 Nuclear Industry Operating Experience ?t: gram D/SM-10 SRB Training-S-l
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D/SM-11 Evaluate the Current Program for Safety Management Improvements E/SP-2 STA Assume Interim EDO Function E/SP-3 Non-outage Work Prioritization E/SP-4 Develop a Failure Analysis Program E/SP-5 Station Procedure Error Reduction Plan E/SP-6 Generic Guidance through Standing Orders, Special Orders and Administrative Memos E/SP-8 STA Program Improvements E/SP-9 Maintenance MBO Program E/SP-10 Determine the type of permanent, non-outage backshift coverage, if any for I&C and Electrical Shops E/SP-ll Determine the type of permanent, non-outage backshift coverage, if any, for mechanical maintenance and station services E/SP-12 Select a method for updating the stock system F/TS-1 Improve the FCR process F/TS-2 Improve TED/Bechtel Communications F/TS-3 Establish Realistic Schedules and Clear Priorities -
F/TS-5 Improve the Engineers Performance
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TED Response No. 12:
These Action Plans have been listed in Attachment IV, Improving Regulatory Performance -- Performance Enhancement Program Action Plans.
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ATTACHMENT I TOLEDO EDISON
RESPONSE TO SALP 4
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IMPROVING REGULATORY PERFORMANCE IN
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' PLANT OPERATIONS, MAINTENANCE, EMERGENCY PREPAREDNESS, i
QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS, AND TRAINING
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Toledo Edison (TED) Corporate and Nuclear Mission Management are committed
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to achieving significant improvements in regulatory performance at the
Davis-Besse Nuclear Power Station Unit No. 1.
Actions completed, in progress and planned to improve our regulatory performance in the functional
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l areas of Plant Operations, Maintenance, Emergency Preparedness, Quality
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Programs and Administrative Controls, and Training are described in Attachment II. Attachment III lists, in tabular format, the,SALPs cate-
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gorized concerns, TEDS specific corrective actions and their associated
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milestone dates.
I In addition to the specific planned corrective actions in each of the five areas discussed in Attachment II and III, Toledo Edison is providing a i
broader base of actions to further improve its nuclear program through
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additional management involvement and critical self evaluation.
i A task force is being formed to review and advise senior management on the
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i scope and depth of the company's actions.
The members will be experienced in utility management, regulatory relations and communications skills.
l The members are being selected from the industry as well as from Toledo Edisen personnel. Headed by Richard Crouse, Vice President, Nuclear, this group will review and evaluate the individual corrective actions of the company to be sure they are sufficient to significantly improve the
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current conditions. Through Mr. Crouse this group will report regularly
to the Chief Executive Officer their findings and actions.
Plant visits by Senior Management have been initiated to provide overview and feedback to the management staff. The Chief Executive Officer of TED
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is making regular visito to the plant, including visits at offshift times.
The Vice President-Nuclear visits the plant or meets with plant employees at the Davis-Besse Administration Building on at least a weekly basis.
The Assistant Vice President-Nuclear's office is located at the Davis-Besse
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l Administration Building and he visits the plant on at least a weekly basis.
The Nuclear Division Directors having Davis-Besse responsibilities are visiting the plant, if their office is not located there, on at least a
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weekly basis.
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Notes should be completed by each Senior Management member documenting his visit. Visit findings are written up identifying any unusual conditions or situations and are tracked to resolution by established corrective action systems, such as Surveillance Reports or Station Work Requests.
To underline our commitment to the operations and training programs these visits will include Plant and Training Center visits.
The Performance Enhancement Program is initiating two key programs to improve the overall quality of Toledo Edison management.
These include use of performance measures in conjunction with an expanded Management By Objective program (PEP Implementation Plan A-2(1)) and a Quality Assurance Awareness Program (PEP Implementation Plan D/QA-1).
The details of these programs will be discussed with your staff at the planned February 7-8, 1985 PEP review meetings.
The expanded Management by Objectives program is the means by which we can
~ properly assign responsibility for needed corrective actions to achieve excellence.
This program also allows us to assign accouatability.
The expanded Performance Measures program is the management tool by which we will measure our performance toward achieving our objectives and goals.
Additionally, focused management attention is being placed on Toledo Edison's commitment tracking and training schedule compliance.
This will improve the direct management support in the commitment and training areas. Through use of these tools, management will hold individuals responsible to ensure that commitments are met.
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ATTACHMENT II IMPROVING REGUI.ATORY PERFORMANCE AT THE DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 I.
PLANT OPERATIONS A.
Areas of SALP Concerns 1.
Adherence to procedures.
2.
Review of equipment status changes.
3.
Recognition of Design Bases requirements.
4.
Jumper and lifted wire log reductions.
l B.
TED Corrective Actions 1.
Adherence to procedures:
Administrative Procedure AD 1839.00, Station Operations, has been revised concerning the generation and documenta-tion of valve lineup (s).
Specifically, this revision provides increased guidance concerning the valve lineup of a system or component being removed from or returned to f
service.
In addition, Plant Procedure PP 1102.01, Pre-start Checklist, was modified to impose increased requirements for valve lineup verifications being conducted following an extended outage.
Implementation of these steps will ensure that the system is properly returned to service and is in its correct lineup for operation.
Administrative Procedure AD 1659.00 has been revised to reinforce control and accountability of procedure sign-off by requiring the use of initials rather than a check mark.
Also, the determination that a specific operations procedural step is not applicable must now be made by a Senior Reactor Operator (SRO) license holder.
All operations personnel have been made aware of the serious need for strict adherence to plant procedures.
Personnel violating procedures will receive appropriate management reprimand based on the specific circumstances.
TED has increased its efforts to ensure attention to detail by the control room operations staff through:
(1) discour-aging the access and limiting the visit duration of non-essential personnel in the control room; (2) encouraging professionalism by the operators; and (3) reducing nuisance ala rms. The intent of these actions is to improve attitudes about quality of the work performed and to reduce errors.
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To discourage access to the control room and limit the visit duration of non-essential personnel, the Operations
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Engineer has issued a memorandum (dated January 9,1985) to all operations personnel explaining the rules for control room access. This memorandum was explicitly discussed with each shift.
Major items included to accomplish limited control room access and visit duration were:
1.
Moved the control room's " Restricted Zone" to prevent
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access to the panel area.
This limits unnecessary traffic into the control room area.
2.
Barred equipment operators from the restricted zone except when requested to be present by the reactor operators.
3.
Removed all the chairs from the control room except for the ones necessary for the licensed operators.
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4.
Removed hat racks and replaced with wardrobe lockers.
5.
Placed specific rules on access and use of the kitchen area by non-licensed operators.
6.
Ordered a new office for the testing shift to be installed in the turbine building adjacent to the lunchroom. This will keep testing shift operators out of the control room.
7.
Joved the procedure files to the shift administrative atsistant's office (the procedures, of course, remain in *.he control room).
8.
Restricted tours of the control room.
In addition all other station personnel were issued a memorandum from the plant manager explaining these new rules along with a copy of Standing Order No. 27 concerning
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j control room access.
Shift Supervisors, Assistant Shift Supervisors, and Reactor Operators have been told to enforce the guidelines under Standing Order No. 27.
Since the implementation of this new program, the traffic in the control room has been significantly reduced and the operators are not distracted by unnecessary personnel in the area.
To encourage professionalism the Operations Engineer has been meeting with each shift discussing the many items included in the Davis-Besse regulatory improvement programs.
In addition several hardware items have been ordered for installation to assist the operators in their duties and to foster a professional environment.
The following identifies l
specific actions taken:
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A new testing shift office has been ordered.
2.
A new equipment operator study room and office has been ordered for replacement of the cramped quarters occupied previously.
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A committee, including operators, engineering, Shift
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Supervisor and administrative assistants, has been
formed to. rework the Shift Supervisor's office and
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administrative assistant's office to make these areas more efficient and professional.
4.
All operators will receive new working uniforms to promote a more professional appearance.
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5.
A salary review is underway to make the management positions of Shift Supervisor and Assistant Shift Supervisor more appealing to union members.
6.
Implementation of the Nuclear Mission MB0 process will give the management personnel more pride of ownership
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to the goals and objectives of not only operations but the entire mission.
In order to accomplish a reduction in the number of nuisance alarms in the control room and to maintain the number at a minimum, TED has established an alarm reduction program.
This program strives to achieve the desired operating
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philosophy for the control room alarms, that being a i
" Blackboard Concept," minimizing the number of annunciator alarms in the alarmed state during normal operation.
The program is supported by a quarterly review of the
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control room annunciator panels to monitor annunciator alarms in the " alarmed" condition.
The annunciator alarms in the " alarmed" state are reviewed and assessed on an individual basis to determine the nature /cause of the alarm. When an alarm is classified as a nuisance alarm, corrective. action is then undertaken to eliminate the distraction to the control room operator.
Corrective action typically utilizes appropriate station adminis-trative procedures to extinguish the nuisance alarm.
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Corrective actions may also be undertaken for alarms which are not necessarily assessed as nuisance alarms to assist in achieving the " Blackboard Concept." An example of this would be when an alarm is assessed to be caused by an equipment failure / malfunction and the repair of the failure
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is known to be delayed for a significant period of time.
Since the alarm would be expected to be a distraction if j
left in the alarmed state for a significant period, corrective
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j action would be undertaken to extinguish the alarm.
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The nuisance alarm reduction program has already provided positive actions in the reduction of nuisance alarms.
Within the last six months, nine nuisance alarms have been extinguished. Also, numerous " alarmed" annunciator alarms have been extinguished as a result of completion of related maintenance activities.
As of February 25, 1985, there are currently 13 control room annunciator alarms (out of a total of 527 alarms) in the alarmed state.
Of these 13 alarms, 3 rjarms are considered to be nuisance alarms.
The resolution of the 3 nuisance alarms is expected to be as follows:
- One of the 3 alarms is currently expected to be resolved (extinguished) within the next 30 days.
- The remaining 2 nuisance alarms are planned to be resolved through the implementation of Facility Change Requests. The completion of the related FCRs will be dependent upon the Davis-Besse scheduling priorities developed by the Integrated Living Schedule Program.
The remaining 10 alarms should be eliminated through the completion of maintenance work activities.
If it is determined that these alarms may remain in the alarmed state for a significant period of time, actions will b'e taken to temporarily extinguish the alarm (s), using appropriate administrative procedures, to alleviate the distraction to the control room operators.
The nuisance alarm reduction program will continue to assess and assist in the resolution of future nuisance alarms as they develop.
An increase in the training of the operations staff has been scheduled for 1985. This training (including admini-strative procedures training) is reflected on the 1985 Master Training Schedule.
Further discussion of operations staff training is discussed under Section V, Training, of this attachment.
This action will enable the staff to be more technically knowledgeable and thus improve their support of the operators.
2.
Review of equipment status changes:
TED has revised procedure AD 1844.00, Maintenance, to require that an experienced non-shift SRO review all Maintenance Work Orders (MW0s).
The SRO reviews the proposed work for potential system operability impacts.
Guidance has been provided so that any proposed change in plant configuration is carefully reviewed for its impact.
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This will provide a much improved ability to recognize system operability problems.
3.
Recognition of Design Bases requirements:
In addition to the short term measures discussed in Section 2
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above, TED will institute a program to perform a system-by-system review of Design Bases contained in the Davis-Besse
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USAR.
This review, a major undertaking, will be performed
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by experienced individuals familiar with Davis-Besse
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design, operations or regulatory requirements and utilize external technical support (B&W, Bechtel, etc.) as appro-l priate. A task force has been assigned the responsibility
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for developing a specific action plan for the USAR review.
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The schedule for developing the plan, including specific
milestone dates, is listed in Attachment III,Section I.3.
This plan, including the system review schedule, will be
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submitted to the NRC by May 1, 1985.
TED's review of the
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USAR is to be performed on a system-by-system basis and will include all safety related systems and major non-safety related systems. The review is to be performed by a i
committee composed of highly experienced members of the TED Nuclear Facility Engineering and Davis-Besse Station organizations. The primary purpose of this review is to
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l extract from the USAR information on system _and component functional and operational requirements.
Each system review should include an examination of all portions of the SAR pertaining to that system, including sections of Chapter 15 where appropriate.
The operational and functional requirements for. systems and components identified during this review are to be made available to the appropriate Engineering and Operations divisions of the Nuclear Mission, i
although the format for the presentation of this information i
and the method of its distribution has not yet been identified.
Through a mechanism to be established by TED, operational I
restrictions identified for the systems and components are to be factored into appropriate system operating procedures and training.
4.
Jumper and lifted wire log reductions:
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TED plans to reduce the number of outstanding jumper and lifted wire log entries.
Operations has generated a list
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identifying FCRs with jumper and lifted wires.
Nuclear
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Facility Engineering (NFE) will review this list for work
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j prioritizing and scheduling by April 15, 1985.
By April 15, 1985, NFE will also establish a goal to significantly reduce the number of jumpers installed and lifted wires by the end of 1985.
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II.
MAINTENANCE A.
Areas of SALP Concerns
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1.
Management overview.
2.
Strengthening of and adherence to procedures.
B.
TED Corrective. Actions
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1.
Management overview:
The key Maintenance Department Head position, Maintenance
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Engineer, has been filled with an individual who has the
,
leadership and experience to provide increased management-control of maintenance activities.
TED has authorized an-increase in 1985 of four (4) additional Maintenance Foremen to provide increased overview of maintenance activities and provide more field supervision which will lead to improved performance. These positions will be filled by July 5,1985.
In addition, a Corpotate
Recruiting Task Force has been established to recruit key
"
personnel, one of which is the identified critical position
of Lead Instrument and Control engineer.
.
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A Management by Objectives program to improve account-I ability of job responsibilities and defined objectives has been initiated within the Maintenance Department.
The MBO
program will provide employees with a clear understanding of desired actions and results (i.e., define responsiblities
'
and accountability).
Du] has developed a system for the prioritization of non-outage maintenance activities to improve management planning and control. The process is designed to provide.
for completion of the most important work first and is based on a weighted rating system.
i In January, 1985, 420 more corrective Maintenance Work Orders (MW0s) were closed out than were written, illustrating
',
that TED has made recent progress on reducing the MWO
backlog. As of February. 25,1985,1,250 corrective MW0s were open. To continue reducing the MWO backlog, TED will use its system for prioritization of non-outage maintenance
'
activities which includes the prioritization of MW0s, i.e.,
i the most important MW0s ste scheduled first.
In addition, TED will review under its prioritization program, MW0s
.
i which have been open for some time to determine both the i
reason and the appropriate disposition. The system for prioritization (PEP Implementation Plan E/SP-3) will be implemented by June 1, 1985.
Monthly tracking of the
l number of MW0s written versus those closed out is reviewed l
by TED management to ensure that an acceptable level of
!
progress is maintained in reducing the MWO backlog.
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Maintenance has two shifts per day coverage in effect
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(except for weekends and holidays) and the backshift will be expanded in 1985 to increase the tag-outs being performed to support day shift corrective maintenance and increase
'
backshift surveillance. testing.
Construction of the Personnel Shop Facility, which.will provide improved facilities for maintenance activities, is scheduled for completion in the first quarter of 1987.
,
A quality circle program has been implemented in one of the
,
maintenance areas with favorable results, and has been
'
expanded into five other skill areas. This program provides
,
valuable information about problems and ways to solve those problems from the employees, who may have a better perspective
,
j on a problem than management.
2.
Strengthening of and adherence to procedures:
TED has modified procedures AD 1844.00, Maintenance, AD 1845.00, Changes, Tests and Experiments, and IC 2001.00 Instrument Calibration, to better control nuclear safety-related work. The maintenance procedures have been modified
to require use of controlled drawings and vendor manuals in j
the field.
Compliance with these procedures will ensure i
that field maintenance activities are using the most current and accurate information available.
" Info rmation only" vendor manuals may now only be used to assist in the i
planning, inspection, and monitoring of conditions for
<
informational purposes.
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Procedure AD 1845.00 will be modified to ensure all required
work is complete for a specific Facility Change Request
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(FCR) prior to conducting the related testing.
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A.
Areas of SALP Concerns
't 1.
Emergency Preparedness (EP) QA audit requirements.
!
2.
Tracking Emergency Preparedness activities.
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3.
Preparation for and performance of 1985 EP exercise.
4.
Emergency Preparedness training.
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I B.'
TED Corrective Actions
!
l 1.
Emergency Preparedness QA audit requirements:
This SALP concern has been addressed by the development of
,
j a process whereby both Emergency Planning (EP) and Quality j
Assurance (QA) review the checklist for QA audit requirements i
.
QA-(with or without a consultant)
prior to audit initiation.
prepares the audit checklist.
EP reviews this list during i
j the QA entrance interview for completeness, clarity and i
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t understanding. EP.is not allowed to remove any-items from
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the list'at any time.
EP may request QA to add items if EP feels such items are needed for completeness of detail for
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the 10CFR50.54(q) review. This review will be documented
in the entrance interview notes.
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2.
. Tracking Emergency Preparedness activities:
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The Activity Scheduling System is. currently under development which will be used to identify, schedule and track required
. activities, both commitments and routine activities. The Activity Scheduling System will include NRC and INPO cannitments, QA Audit Finding Report (AFR) commitments, all
.
EP required activities (NUREG-0654), periodic tests, drill
l and exercise critique items, training requirements, procedure
i and plan revision due dates, recommendations from training sessions as appropriate, and audit observation items.
All
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commitments will be entered into the system per a specific
'
proceduralized method and will show required due dates.
The procedure will utilize forms to enter-commitments.
The commitment portion of the Activity Scheduling System will duplicate pertinent information on the Licensing Commitment i
Tracking System and EP will be responsible to both~ systems.
Commitments for inclusion into the Activity Scheduling
>
System are commitments to.the NRC from Inspection Report responses, commitments to INPO from the annual review and
assistance visit, and QA AFR response commitments.
Routine
'
i activities for-inclusion are monthly communication tests, j
semi-annual shift augmentation drills, periodic tests,
inventories, complete training requirements from Chapter 8 of the Davis-Besse Emergency Plan Manual, and procedure i
revision items. The Activity Scheduling System will be used as a tool for coordinating EP activities between TED departments. The Activity Scheduling System will utilize a j
form, similar to that of the Licensing Commitment Tracking i
System, for assigning other departments' responsible individuals. Division directors will receive monthly
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commitment reports. The Vice President-Nuclear or Assistant.
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Vice President-Nuclear will receive an overdue commitment l:
' report.
i Through appropriate use of this system, management can assure all required activities will be completed on time.
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i Use of the system and its procedures on a trial basis will.
be done prior to formal implementation.
This system will i
be formally implemented for all future commitments by
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September 30, 1985.
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3.
Preparation for and performance of 1985 Emergency Preparedness exercise:
A schedule for the next annual EP exercise has been established with the State of Ohio and Ottawa County.
Under TED manage-ment endorsement, an internal-TED Scenario D;velopment Committee was established in January,1985 which includes members with technical expertise.
The Scenario Development (
Committee includes the Operations Engineer, Emergency Preparedness Coordinator, Facility Modification Manager,
,
l Nuclear Support Training Supervisor, Environmental Monitoring
.
Supervisor, Chemical and Radiological Supervisor, Computer Systems Technical Programmer, Electrical & Control Systems
Engineer, Nuclear Energy Information Administrator, Security Supervisor, two NUTECH engineers (consultants), and two Reed Products and Services consultants.
These items will
!
improve the timely establishment of exercise objectives and ensure technical accuracy of the exercise scenario.
The EDO program is being modified to establish a full-time
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Emergency Planning Supervisor / Emergency Duty Officer (EDO)
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position. This will significantly upgrade the technical experience of the EDO position and will result in-improved performance.
4.
Emergency Preparedness training:
l The Emergency Preparedness training format has been improved j
by including more hands-n training and the 1985 Training Schedule has been. prepared for all Emergency Response
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Programs, both Corporate and Station.
This schedule was developed in conjunction with the Nuclear Training Department.
The station schedule has been issued as part of the Nuclear i
f Training Department's Master Training Schedule. Also, controller training classes will be provided for the 1985 annual exercise controllers.
Understanding of the material is verified through satisfactory completion of examinations,
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table top exercises and the annual exercise.
IV.
QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS
.
A.
Areas of SALP Concerns
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1.
Review of nuclear safety-related temporary facility changes.
2.
Consistency of design documents with as-built conditions.
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3.
Management overview.
4.
Quality Assurance effectiveness.
B.
TED Corrective Actions 1.
Review of nuclear safety-related temporary facility changes:
The Station Review Board's (SRB) charter has been modified to require review of Nonconformance Reports (NCR) which constitute nuclear safety-related (NSR) temporary facility i
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D changes.
The NCR procedure has also been modified so that now all NSR NCRs that are dispositioned "use-as-is", "use-as-is-temporarily", or " repair" require a written Safety Evaluation.
Additionally, the Jumper and Lifted Wire (J&LW) Control procedure, AD 1823.00, has been modified to require a written Safety Evaluation for any J&LW that is not removed from a NSR system when maintenance has been completed.
Compliacce with these procedures will provide the required review for changes made to the plant in the cases which didn't fall under the provisions of procedure AD 1845.00, Changes, Tests and Experiments.
2.
Consistency of design documents with as-built conditions:
An extensive effort was employed during 1983-1984 to assess work completed on all modification work packages released for implementation.
Design documents were updated to reflect all work completed.
Currently TED is updating design documents as work orders are closed so that the documents properly reflect the as-built status of the plant.
3.
Management overview:
Standing Order 39 has been issued directing the Shift Supervisor to carefully review any changes to equipment status for any potential effects on operability.
If a clear determination cannot be made the Shift Supervisor is required to consult Station management for a determination.
Station management personnel can be contacted using a paging system, if necessary.
A Surveillance Report system has been implemented to identify potential quality concerns.
QA Audit Finding Reports and Nonconformance Reports authoriz-ing temporary changes are sent to the Station Review Board for their review.
The rate of resolution of Audit Finding Reports and Nonconformance Reports are monitored by performance measures to encourage prompt resolution.
Attendance by the immediate supervisor of the audited area is required at QA exit interviews to ensure adequate management participation.
In addition to the direct
,
supervisor of the activity being audited, his supervisor may also be requested by the audit team leader to attend the exit interview. Furthermore, when the results of the audit
. warrant, the audit team leader also requests higher level management attendance at the exit interview.
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4.
Quality Assurance effectiveness:
The effectiveness of Quality Assurance is being enhanced through increased technical training of auditors (PEP Implementation Plan D/QA-3), the implementation of area-
specific QA training for Station and appropriate support personnel, and supplementing audit teams with individuals possessing area-specific technical expertise.
Consistent with INPO recommendations, the expansion of QA coverage into the non-nuclear portions of the plant (Balance of Plant) is being developed.
TED will determine an initial list of those Balance of Plant systems and/or components to which a Quality Program should be applied.
The initial list will be completed by August 29, 1985.
The requirements of the quality program to be applied to the Balance of Plant, systems and/or components will be developed by July 31, 1985.
QA awareness will be integrated into training. The QA segment of General Employee Training (GET) will be revised to meet INPO guidelines by February 28, 1985.
This GET segment will be expanded into a QA indoctrination and training package by May 1, 1985. Also, schedules will be initiated by June 1,1985 for development of individual training plans covering QA requirements appropriat-to each Nuclear Program Division and/or Department.
To control the cannibalization of spare parts between identical items, Administrative Procedure AD 1847.00, Station Materials Control, is being revised to require Quality Control to be contacted to perform an inspection when a portion of a cannibalized item or component will be used as a spare part.
V.
TRAINING A.
Area of SALP Concerns 1.
QA program requirements within Nuclear Training.
2.
Non-operater and operator training and retraining areas.
3.
Management overview.
B.
TED Corrective Action 1.
QA program requirements within Nuclear Training:
Nuclear Training procedures, the last of which was approved in December, 1984, have been generated which address QA requirements. A training schedule has been developed and implemented consistent with the 1985 Master Training Schedule. These procedures provide instructions for the accomplishment of the various training functions.
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2.
Non-operator and operator training and retraining areas:
The training staff has been doubled since the summer of 1984. At the end of January,1985, the Training staff numbered thirty people.
This increase in the Training
'
staff has significantly reduced self-study requirements.
For this remaining self-study, guidance for a systematic program is.being provided by Nuclear Training based on each
'
' individuals needs.
Measures will be implemented by May 31, 1985 for the
,
improvement of Reactor Operator (RO) and Senior Reactor
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Operator (SRO) requalification exams. Non-operator training program improvements are being implemented through the use of the Action Status List within Nuclear Training. This list provides milestones for accomplishing program improve-ments as they are identified.
This list was developed as a
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management tool for implementing and. tracking training program improvements.
Two Nuclear Training procedures, NSP/NT-007, Training Program Implementation, and NSP/NT-008, Training Program Evaluation, have been implemented which proceduralize the
analysis of examinations and provide feedback of that analysis into the training programs.
The 1985 Requalifi-cation Training Schedule has been developed based on
,
knowledge weaknesses in a particular examination subject
'
area identified through the analysis of the 1984 requalifi-cation exams.
3.
Management overview:
.
Nuclear Training procedures will require that vendor lesson
.
plans be reviewed and approved by the Nuclear Training Department prior to their use.
Following completion of each Nuclear Training class provided by a vendor, the class
is evaluated by both the students and vendor for the i
appropriateness of scope and presentation.
A procedure will be developed by April 15, 1985 to provide for an evaluation by the Nuclear Training staff (on a
random sampling basis) of contractor-delivered training,
'
i.e..by sitting in on the class and evaluating the training.
The Training Diagnostic conducted by a third party in late 1983 identified problems in the areas of Management, Organization, Needs Analysis, Program Design, Program Development, Program Implementation, Program Evaluation, Staff Qualification and Development, and Facility.
Some
>
identified problems required specific short term actions to resolve. These types of items were incorporated into the Performance Enhancement Program (PEP) as Interim Actions.
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W The majority of the problems identified and the recommended actions were broad training process-related items that necessitated being incorporated into a long-term, more encompassing plan with a single objective.
That single objective is provided by the industry (including TED)
commitment to the establishment of performance based training programs meeting the critaria necessary to be awarded INP0 accreditation. Accreditation not only incorporates the identified diagnostic items, but includes other training elements not addressed by the diagnostic and provides an iterative process of evaluation and feedback that insures updating and continued improvement.
Utilizing TED's accreditation plan, all aforementioned criteria are individually addressed and incorporated into the training programs for INP0 Accreditation Board review.
TED's accreditation plan will prepare all INPO-identified training programs for accreditation. The first milestone
,
is to have the Non-Licensed Operator, Licensed Operator, and Requalification Training Programs ready for INPO Board review by December 31, 1985.
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ATTACHMENT III ACTIONS AND MILESTONE DATES FOR IMPROVING REGULATORY PERFORMANCE SALP FUNCTIONAL AREA:
I. PLANT OPERATIONS Area of Milestone SALP Concern TED Corrective Action Date 1.
Adherence to A.
Revise Station procedure AD 1839.00 Completed procedures.
to govern generation and documenta-tion of valve lineup (s).
B.
Modify Plant procedure PP 1102.01 Completed to impose increased requirements for valve lineup verifications following an extended outage.
C.
Revise Station procedure AD 1839.00 Completed to reinforce control of operations procedure signoff by requiring use of initials rather than check marks.
D.
Determination that a specific Completed procedural step is not applicable, must be made by a SRO license holder.
E.
Schedule increased training of Completed Station staff in 1985.
F.
Provide more explicit direction Completed concerning limited control room access and visit duration.
G.
Eliminate one of three remaining 4/1/85 nuisance alarms.
, 2.
Review of equip-A.
Require review of all Maintenance Completed cent status Work Orders (MW0s) by SRO qualified changes.
individuals.
3.
Rscognition of A.
Develop plan for system-by-system 4/15/85 D: sign Bases review of the USAR.
Raquirements.
1.
Draft plan.
3/22/85 2.
Management approval of plan.
4/15/85 B.
Submit plan and system review 5/1/85 schedule to NRC.
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SALP FUNCTIONAL AREA:
I. PLANT OPERATIONS (Continued)
Area of Milestone SALP Concern TED Corrective Action Date 4.
Jumper and Lifted A.
Generate a list identifying FCRs Completed Wire Log Reductions with jumpers and lif ted wires.
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B.
Prioritize, schedule work, and 4/15/85 establish goals for significantly
,
reducing number of jumper and lif ted wires by end of 1985.
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SALP FUNCTIONAL AREA:
II. MAINTENANCE Area of Milestone SALP Concern TED Corrective Action Date
- 1.
M:nagement A.
Fill Maintenance Eagineer position.
Completed Ove rview.
B.
Fill four additional Maintenance 7/01/85 foremen positions.
C.
Maintenance Supervisor Management 7/01/85 By Objectives (MBO) program in place (PEP Impicmentation Plan E/SP-9).
D.
Develop a system for prioritization Completed of non-outage maintenance activities (PEP Implementation Plan E/SP-3).
E.
Implement the system for 6/01/85 prioritization of non-outage maintenance activities (PEP Imple-mentation Plan E/SP-3).
F.
Implement a quality circle program.
Completed
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G.
Complete Personnel Shop Facility 3/31/87 construction.
2.
Strengthening A.
Modify procedures AD 1844.00, Completed of and AD 1845.00 and IC 2001.00 to better adherence to control nuclear safety-related work.
procedures.
B.
Modify maintenance procedures to Completed require use of controlled drawings in the field.
C.
Modify procedure AD 1845.00 to 3/15/85 ensure that all required work is complete for a specific Facility
.
Change Request prior to conducting the related testing.
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SALP FUNCTIONAL AREA:
III. EMERGENCY PREPAREDNESS Area of Milestone SALP Concern TED Corrective Action Date 1.
Emergency A.
Develop 1984 audit checklist.
Completed Preparedness (EP)
QA audit B.
Develop 1985 audit checklist.
10/01/85 r:quirements.
2.
Tracking Emergency A.
Develop Activity Scheduling System.
3/01/85 Preparedness cctivities.
B.
Formally implement EP Activity 9/30/85 Scheduling System for future commitments.
3.
Preparation for A.
Establish EP exercise schedule with Completed t.nd performance State of Ohio and Ottawa County.
of 1985 Emergency Preparedness B.
Establish Scenario Development Completed Exercise.
Committee, with technical expertise.
C.
Establish permane'nt Emergency Duty 3/15/85 Officer position.
4.
Emergency A.
Improve training format.
Completed Preparedness training.
B.
Establish training schedule Completed on 1985 Master Training Schedule.
C.
Implement controller training 7/01/85 classes.
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SALP FUNCTIONAL AREA:
IV. QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS Area of Milestone SALP Concern TED Corrective Action Date 1.
R view of nuclear A.
Modify Station Review Board (SRB)
Completed ssfety-related Charter to require review of NSR temporary facility Nonconformance Reports (NCRs).
changes.
B.
Modify NCR procedure to require Completed Safety Evaluation for all NSR NCRs t
dispositioned "use-as-is", "use-
'
as-is-temporarily", or " repair".
C.
Modify procedure AD 1823.00 to Completed require a Safety Evaluation for any J&LW not removed from a NSR system when maintenance is completed.
2.
Consistency A.
Require the updating of design Completed of design documents as work orders are closed.
d:cuments with as-built conditions.
3.
Mtnagement A.
Issue Standing Order 39 directing Completed
,
Overview.
Shift Supervisor to review any changes to equipment status for any potential effects on operability and if necessary, consult with Station management.
B.
Implement a Surveillance Report Completed system to identify potential quality Concerns.
C.
Implement requirement for performance Completed performance monitoring of NCR j
resolution.
D.
Require sending QA Audit Finding Completed Reports and NCRs authorizing temporary facility changes to SRB for review.
E.
Implement requirement for performance Completed monitoring of the rate of resolution of audit finding reports.
F.
Require immediate supervisor Completed attendance at QA audit exit inter-views.
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SALP FUNCTIONAL AREA:
IV. QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS (Continued)
Area of Milestone SALP Concern TED Corrective Action Date 4.
Quality A.
Require increased technical train-Completed Assurance ing for auditors (PEP Implementation effectiveness.
Plan D/QA-3).
B.
Require supplementing of audit teams Completed
.with area-specific technical expertise.
C.
Balance of Plant Quality Program:
1.
Determine an initial list of 8/29/85 those Balance of Plant systems and/or components to which a Quality Program should be applied.
2.
Develop the Quality Program 7/31/85 requirements to be applied to the Balance of Plant systems and/or components.
3.
Commence implementation of a 8/29/85 Balance of Plant Quality Program.
D.
QA Awareness Training 1.
Revise the QA segment of General 2/28/85 Employee Training to meet INP0 guidelines.
2.
Expand the General Employee 5/01/85 Training segment on Quality Assurance into a Quality Awareness indoctrination and training package (PEP Imple-mentation Plan D/QA-1).
3.
Initiate schedules for develop-6/01/85 ment of ihdividual training plans covering the Quality Assuranee requirements appropriate to each Nuclear Program Division and/or Department.
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SALP FUNCTIONAL AREA:
V. TRAINING Area of Milestone SALP Concern TED Corrective Action Date 1.
QA program A.
Generate Nuclear Training procedures Completed requirements which address QA requirements.
within Nuclear Training.
B.
Develop and implement a training Completed schedule.
2.
Ncn-operator A.
Reduce significantly self-study Completed cnd operator requirements.
training and retraining B.
Provide self-study guidance.
Completed areas.
C.
Implement measures for the improve-5/31/85 ment of R0 and SRO requalification examinations.
D.
Implement an Action Status List for Completed non-operator training programs.
E.
Develop procedure to identify Completed deficiencies in licensed operator knowledge and address in requalification training.
3.
Management A.
Develop procedure to provide an 4/15/85 Overview.
evaluation on a random sampling basis of contractor delivered training.
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B.
Have ready Non-Licensed Operator, 12/31/85 Li6ensed Operator and Requalifi-cation Training Programs for INP0 Board review.
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ATTACHMENT IV IMPROVING REGULATORY PERFORMANCE PERFOR M CE ENHANCEMENT PROGRAM ACTION PLANS In addition to the specific items discussed in Attachments 1, 2 and 3, certain Performance Enhancement Program Action Plans are ir. place which
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will assist TED in improving regulatory performance.
The identification and titles of these action plans are as follows:
A-2 Integrated Approach to Goals, Objectives and Strategic Plan A-3-Management Training B-5 Personnel Division Resources C/CM-1 Configuration Management D/FP-1 Development of Fire Protection Program
D/L-1 Commitment Management D/QA-1 QA Awareness Program D/QA-2 QA Procedures Review Group D/QA-3 QA Auditor Commensurate Training Program D/SM-1 Safety Evaluations D/SM-2 SRB Performance Criteria D/SM-3 CNRB Meeting with Corporate Management D/SM-4 CNRB Training i
D/SM-5 Appointment of CNPB Sub-Connittees for Review / Screening of Routine and Periodic Documents D/SM-6 Improve Preparation of CNRB Members Prior to CNRB Meeting D/SM-7 Submit Appropriate Information to the CNRB for Their Review D/SM-8 Provide Procedures to Control Nuclear Safety Related Activities D/SM-9 Nuclear Industry Operating Experience Program D/SM-10 SRB Training D/SM-11 Evaluate the Current Program for Safety Management Improver.ents-1-
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E/SP-2 STA Assume Interim EDO Function E/SP-3 Non-Outage Work Prioritization E/SP-4 Develop a Failure Analysis Program E/SP-5 Station Procedure Error Reduction Plan E/SP-6 Generic Guidance through Standing Orders, Special Orders and Administrative Memos E/SP-8 STA Program Improvements E/SP-9 Maintenance MBO Program E/SP-10 Determine the Type of Permanent, Non-outage Backshift Coverage, if any, for I&C and Electrical Shops
,
E/SP-11 Determine the Type of Permanent, Non-outage Backshift Coverage, if any, for Mechanical Maintenance and Station Services E/SP-12 Select a Method for Updating the Stock System F/TS-1 Improve the FCR process F/TS-2 Improve TED/Bechtel Communications F/TS-3 Establish Realistic Schedules and Clear Priorities F/TS-5 Improve the Engineer's Performance Further information on the specifics and milestone dates of each action
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i plan are contained within the respective plan.
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k UNITED STATES g
NUCLEAR REGULATORY COMMISSION
WASWNGTON, D. C. 20555
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Docket No. 50-346 License No. NPF-3 EA 84-95 Toledo Edison Company ATTN: Mr. John P. Williamson Chairman and Chief Executive Officer Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:
This will acknowledge receipt of your letter dated January 14, 1985 and your check dated February 25, 1985 for Ninety Thousand Dollars ($90,000) in payment for the civil penalties proposed by NRC in a letter dated November 21, 1984. We will continue to examine, during future inspections,
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the corrective actions describeo in your letter.
Sincerely, ((b L&:
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i Jane A. Axelrad, Director
' Enforcement Staff Office of Inspection and Enforcement CC:
T. D. Murray, Station Superintendent Harold W. Kohn, Ohio EPA
James W. Harris, State of Ohio
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Robert H. Quillin, Ohio
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Department of Health
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Toledo Edison Company Distribution
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SECY ACRS CA JTaylor, IE RVollmer, IE JAAxelrad, IE ABBeach, IE JKeppler, RIII JLieberman, ELD
Enforcement Coordinators RI, RII, RIII, RIV, RV VStello, DED/ROGR FIngram, PA SConnelly, DIA BHayes, OI JCrooks, AE00 HDenton, NRR RStark, NRR Project Manager, NRR Resident Inspector State Attorney General IE:ES File IE:EA File
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Decket No. 50-346 Tottoo
%sm EDISON License No. WPF-3 A -,. : r ca..o Serial No. 1-490
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January 14, 1985 PRICRITY ROUTIEG 1g p oi p -- 2i_,
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4E Mr. James M. Taylcr, Deputy Director CW[Y
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Office of Inspectien and Enforcecent y
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United States Nuclear Regulatory Coccission k'ashington, D.C.
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Dear Mr. Tayler:
On Novecher 21, 1984, the NRC transmitted te the Toledo Edison Company a Notice of Violation and Proposed Imposition of Civil Penalties (EA 84-95)
for violations reported in Inspection Report No. 50-346/84-15 (DRP) (Leg 1-1062). This letter and attachment represent the Toledo Edison Cocpany's respense under 10 CFR 2.201, to the five items of violation identified by the NRC in the Notice of Violation.
Toledo Edison has elected not to protest the Proposed Imposition of Civil Penalties as provided by 10 CFR 2.205.
A check f or the full $90,000 has been sent under separate rever
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to the Treasurer of the United States (see attached photocepy).
Tellowing an exacination of the Notice of Violation and an investigation into the circumstances surroundinE the identified itees of violatien, the Attachment 1 enclosed provides Tolede Edison's assesscent of the violations.
Toledo Edison reaffires its ccc=iteent to proper adcinistrative centrol of equipeent in accordance with Technical Specifications.
Through the ceasures described in the enclosed attachment, we believe that the recur-rence of these incidents and similar incidents vill be prevented and the operation of the Davis-Besse Nuclear Power Station can centinue with full assurance cf plant safety.
Very truly yours, f
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RPC:RTP:nif encl.
cc:
Mr. J. G. Keppler, Regional Administrator, Region III N
DB-1 NRC Resident Inspector g 10 i
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ATOMIC ENERGY ACT OF 1954 SECTION 182
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SUBMITTAL IN RESPONSE FOR Tile DAVIS-BESSE NUCLEAR POWER STATION
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UNIT NO. 1 FACILITY OPERATING LICENSE NPF-3 This letter is submitted in conformance with the Atemic Energy Act of 1954 Section 182 in response to Inspection Report Ec. 50-346/84-15 (Log Nc.1-1062).
By
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R.~P. Crouse Vice President - Nuclear
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Sworn to and subscribed before me this 14th day of January,1985.
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My Commission Expires May 16, 1986
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Docket No. 50-346
' License No. EPF-3 Serial No. 1-490 i
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Page 1
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I.A. Violation:
Technical Specification 3.7.6.1. "Contrei Room Eeerr-ency Ventilatten System," requires that two independ-ent control root emergency ventilation systems shall be cperable.
A system is censidered cperable when it is capable cf performing its specified functien(s).
Technice) Specification 6.8.1.a requires that written procedures be established, icplemented and maintained
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cevering the activities specified in Appendix A ef Regulatory Guide 1.33. November 1972.
Appendix A speci-
fies typical safety-related tetivities that shculd be i
covered by written procedures.
This includes procedures j
for operation of the control rece emergency ventilation i
systems.
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l Aduinistrative Procedure (AD) 1839.00 " Station Opera-tions" requires that, prior te receval of safety-related
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equipment f ree service, operability of redundant sr.fety-related equipment must be verified by inspection.
In
additien, this procedure requires that the applicable technical specification action statements be evaluated prier to the recoval of the safety-related equip =ent
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from service.
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I Centrary to the above, both trains of the Contr'o1 Roce Emergency Ventilatien System were removed f rom service i
en April 23, 1964 through May 7, 1964 without verifying the operability cf the redundant equiptent or evaluating i
applicable technical specification action statemente.
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This rendered the Control Reet Emergency Ventilation System ineperable in violatten ef technical specifica-tion requirements.
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1.A. Response: (1)
Admission or denial of the alleged violation.
Toledo Edison admits Violatice 1.A.
I (2) The reasons for the violation, if admitted.
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On thy 7,1964, during the performance of ST 5076.01, i
Control Roce Emergency Ventilation Monthly Test, it
was found that both Control Room Emergency Ventilation
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Chiller Control Power Switches were in the "0FF" l
position. This rendered the cooling function for both
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Control Room Energency Ventilation System (EVS) Trains inoperable.
The previous monthly rurveillance test had been performed on Control Room TVS Channel 1 on April 9, 1984 and on Channel 2 on April 23, 1984.
Toledo Edison's investigation cf this incident dis-
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Docket No. 50-346 License Ne. NPF-3 Serial No. 1-490 January 14, 1985 Attachment 1
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Page 2 closed nething to indicate that the switches had been left in the "OFF" pesition after these tests and concluded that the cause of the event was a personnel
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error of an undetermined origin.
A further contri-buting factor may have been the inadequate labeling of the chiller switches themselves.
(3)
Corrective steps taken and results achieved.
When ne apparent reason was fcund for the Control Roce Emergency Ventilation Chiller Control Pever Switches being in tl+ "0FF" position, the operator was instructed to place ti.e switches to the "0N" position.
Surveillance Test ST 5076.01 was then successfully run on both Control Room EVS units.
(4) Corrective action taken to avcid further noncompliance.
Identification labels were put next to the Control Rocm Emergency Ventilation Chiller Control Power Switches to clarify their purpose and to alert personnel that the Shif t Supervisor must be notified prior to
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turning the svitches to "0FF".
Also, the panels en which the switches are located were more clearly labeled.
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Surveillance Test ST 5076.01 was modified to identify the significance of these switches on Control Recc EVS operability.
The preventative maintenance verk order was modified to identify the potential effects of preventive maintenance on Control Room EVS operability and to require that the switches be verified to be in the
"0N" position following maintenance.
Personnel performing maintenance of the Centrol Room EVS vele counseled regarding the seriousness of this incident.
A program has been established to review maintenar.ce work orders for their effect on system operability.
The review conducted by a Senior Reactor Operator qualified individual consists of verifying system operability requirements prior to conducting maint-enance and verifying that pest maintenance testing is adequate for returning the system to service.
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Docket No. 50-346 License No. NPT-3 Serial No. 1-490 January 14, 1925 Attachment 1
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Page 3
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(5) Date when full compliance vill be achieved.
Full compliance with cerrective actiens has been achieved.
1.B. Violaticn:
Technical Specification 6.8.1 requires that written procedurer be (sic) estchlished. inplemented and maintained cevering the activititt specified in Appendix A of Regulatory Guide 1.33, Nevember 1972.
The activities specified in Appendix A, Section A, Administrative Precedures, include precedure adher-ence, shift and relief turnevers and leg entries.
Apperdix A, Sectien C, "Precedures for Startup, Operatien, and Shutdown of Safety Related Fk'R Systems." list the feedwater syster as requiring instructions for energiring startup and shutdovr.
of the system.
Centrary to the above, en June 24, 1984, the licensee failed to start the startup feed pucp in accordance
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with the appliccble sections cf the appreved proce-
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durer (SP 1105.27 and SP 1106.27) for operation of the startup feed pump; failed te log the starting of the startup feec pump in the reacter operater's log; l
and ieproperly initialed the trip recovery procedure (PP 1102.03) indicating that the startup feed pu=p was started per an approved precedure (SP 1106.27).
In addition, en June 25, 1964, the licensee failed to shutdown or restore the startup feed pump t e ne rta l l
in accordance with the applicable sectiens of the approved procedures (SP 1105.27 and SP 1106.27);
improperly initialed the plant startup procedure (PP 1102.2) indicating the startup feed pump was stopped per the approved precedure (SP 1106.27);
f ailed te perf erm an adequate turnever regarding the statuF ef the startup feed p""P FVstem; and failed to properly sign off the cocpletion of Section 6 ef the startup procedure (PP 1102.2).
1.B. Response: (1)
Admission or denial of the alleged violation.
Tolede Edison admits to Violatien 1.B.
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Decket No. 50-346 License No. NPF-3 Serial No. 1-490 January 14, 1985 Attachment 1
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Page 4 Thereasonsfortheviolation,ifadmitted$
(2)
At the time the violation occurred, Davis-Besse procedures required the use of the Main Feedvater Pumps (MFWP) to support the plant startup and shutdown feedwater needs.
This procedural requirement was in place due to the potentici line break hazard which use of the Startup Feedwater Pump (SUFP) would present to the Auxiliary Feedwater Systet (AFU). Thus, as per
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procedural requirements, the MFWF were being utilized in the recovery process from a reactor trip on June 24, 1984. As trip recovery proFressed, problems
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developed with the controls which resulted in oscilla-tions in both steam generator level and feedwater
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pressure. These oscillations, ccupied with a steam supply problem related to the auxiliary boiler, led to the decision to utilize the SUFP f or trip recovery despite the line break hazard.
The SUFP was placed in operation in parallel with No. 1-2 Main Feedwater Pumps (MTP).
Starting of the
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SUFP was inadvertently not logged in the Reacter Operator's log.
PP 1102.03. Trip Recovery Procedure.
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was, however, initialed signifying the pump was in se rvice.
It is important te note that the SUFP was placed in service ccrrectly, even though the procedure i
was not completely signed eff.
Proper initiation was i
verified by observing pump conditions such as feedvater flow and pump motor current.
During the subsequent plant startup on June 25, 1984, a main feedvater pump was placed in service and the SUFP was shut down.
As is required by previous Tolede Edison ccmmitments to the NRC, isolation of the SUFP was initiated. The guidance provided to the operator for isolating the SUFP was, hewever, informal in that it consisted of a handwritten list of valve position changes and control power fuse removals, instead of the use of the appropriate procedure which contained this guidance.
Before the isolation task could be completed, the cperator was directed to perform a higher priority evolution.
He informed his supervisor (the Assistant Shif t Supervisor) that the SUFP suction valve FW32 had not been closed.
The Assistant Shift Supervisor inadvertently failed to pass this inf ormation to the relieving shift.
Later in the day on June 25, the on-duty Assistant Shif t Supervisor requested an independent verification of the SUFP isolation.
The verification was performed with the exception of the
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Docket No. 50-346 License No. NPF-3 Serial No. 1-490 January 14, 1985 Attachment 1
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Page 5 verification of FW32 closure. The operat'or mistakenly identified FW33, a similar valve located in close proximity to FW32, as FW32 and, therefore, did net note that FW32 was in the open position rather than the required closed position. Therefore, the SUFP was not isolated properly and remained in this condition until July 1, 1984, when ancther operater discovered FW32 open during a routine observation tour.
He immediately closed the valve and netified the Shift Supervisor of this event.
(3)
Corrective steps taken and results achieved.
On July 1, 1984, after finding the SUFP suction valve, TV32, open, the Operations Engineering Superviser directed the Shift Supervisor tc reverify the re=aining I
isolation valves closed and fuses for the SUFP removed.
Additienally, "De Ect Operate" tags were placed on these components to prevent future inadvertent cperation.
All Operations shif t persennel were cautioned by the Operations Engineer about the need to operate the
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plant in accordance with approved procedures, and that it is imperative to properly utilize applicable.
procedures.
Additienslly, the Shif t Supervisor and
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Assistant Shift Supervisor involved with this incident were counseled on the importance cf their direct supervision cf plant activities and of the necessity i
te retain cognizant of all engeing activities, especially during plant startups and reactor trips.
Specifically, it was stressed that simultanecus performance of plant evolutions must be limited to a number that could be appropriately controlled, and that coeplete and accurate shift turnovers are essential to safe plant operation.
(4)
Corrective action taken/to be taken to avoid further noncomplicnce.
Procedure AD 1839.00, Station Operations, has been modified to reinforce the requirement of signint-procedural steps and an additional new requirement that a Senior Reactor Operator (SRO) evaluate any procedural steps which are determined not applicable for the plant conditions has been initiated.
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Docket No. 50-346'
License No. NPF-3 Serial No. 1-490 January 14, 1965 Attachment 1
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I (5) Date when full coepliance vill be achieved.
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Full compliance with corrective actions has been achieved.
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l 11.
Violation:
10 CFR 50.59(a)(1) states that the-licensee may make l
changes in the facility as described in the Safety Analysis Report... without prier Com=ission approval
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provided that the preposed change...does not invelve a change in the Technical Specifications incorrerated in the license or an unreviewed safety questien.
10 CFR 50.59 requires that the licensee maintain records of changes in it; facility tc the extent that such changes constitu.c cha.2et te the facility as described in the Safe y Analysis Repert.
These records shall include t written safety evaluation
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which provides the bas.s for the determination that
I the change does not involve an unreviewed safety I
question.
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Contrary to the abeve, in the fellowing instances, the licensee made changes in the facility as described in
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j the Safety Analysis Report witheut preparing a written
safety evaluatice of whether the change involved a change in the Technical Specificatiens or an unreviewed
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safety question.
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(1) On November 1,1983, the licensee removed one of twe j
Emergency Diesel Generator (EDG) ventilation supply f ans f rom service without preparing a written safety evaluation and without realizing this action repre-
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sented a change in the facility as described in the Updated Safety Analysis Report (USAR). The USAE de-
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scribes the EDG ventilation supply er containing twe 50% capacity fans.
(2) On December 19, 1982, the licenset initiated a Facility
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Change Request (FCR) that was impismented on May 24,
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1983 which chansed the positten (to open) of the Start-I up Feedwater Pump (SUFP) suction *:alve during power operation without preparin; e written safety evaluation.
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The USAR describes the valve as closed durina tower operation.
(3)
On March 8, 1984 and May 4 1984 lead shielding was
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hung on decay heat system piping channing the leading of the safety system as described in the FSAR and
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Docket No. 50-346 License No. NPF-3 Serial No. 1-490 January 14, 1985
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Attachment 1
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Page 7
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without preparing a written safety evaluation.
II.1. Response: (1) Admission or denial of the alleged violation.
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Toledo Edison admits to Violatien 11.1.
I (2) Reason for the violatien, if admitted.
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On November 1, 1983
- 1 Emergency Diesel Generator (EDG) Room Ventilation Fan was taken out of service for maintenance.
The individual preparing the Mcint-
enance Work Order (MWO) had reviewed the Updated
Safety Analysis Repcrt (USAR).
Based on that review, he incorrectly concluded that the maintenance activity wculd not affect the operability of the EDC.
In
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accordance with AD 1844.00, Maintenance, the Shift Superviser reviewed the MWD.
This review aise
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incorrectly resulted in a drtermination that this maintenance activity would not affect EDG operability.
Based on these determinations, no written safety
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evaluation was performed since nene of the 10 CFR 50.59
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criteria requiring safety evaluation were met.
(3)
Corrective steps taken and results achieved.
l Maintenance was performed and the f an was placed back j
in service prior to determining that a violation had occurred.
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(4)
Corrective action taken to evcid further noncompliance.
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j Procedure SP 1107.11 Emergency Diesel Generator i
Operating Procedure, was modified to include the l
requirement that both EDG Room Ventilation Fans are
required to maintain the EDG in an operable condition.
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A majer revisien was issued to AD 1844.00, Maintenance, on March 31, 1984.
Enclosures 12 and 13 of AD 1844.00,
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which provide instructions for Technical Specification l
equipment operability were expanded to provide addi-tional guidance on equipment operability to support
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the operation of certain Technical Specification
equipment.
Training was provided to Maintenance Staff
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personnel on AD 1844.00, and emphasized the importance
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of proper use of Enclosures 12 and 13, i
Additionally, as identified in response to Violation
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I.A. a program has been established whereby Maintenance
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Docket No. 50-346 License No. NPF-3 Serial No. 1-490 January 14 1985
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Attachment 1 Page 8
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Work Orders receive an independent review by a Senior Reactor Operator (SRO) qualified individual to verify operability requirements are satisfied and post
mainte-nance testing is appropriate.
(5) Date when full compliance vill be achieved.
Full compliance with corrective actions has been achieved.
11.2. Response:(1)
Admission or denial of the alleged violation.
Toledo Edisen admits to Violation 11.2.
(2) Reason for violatien, if admitted.
It should be noted that the only reference to the SUFP suction valve (FW32) in the Davis-Besse Updated Safety Analysis Report (USAR) is its placement on plant Piping & Instrument Diagrac (P&ID) M006B.
On this drawing the valve was shown as nertally closed.
Normal plant cperation in the 1962-1983 time frace
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utilized FW32 in the open position.
For this reason a drawing change was initiated to P&ID M006B to show
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FW32 as a normally open valve consistent with plant operation.
Although P&ID M006B was contained in the USAR, the Toledo Edison interpretation of the 10 CFR
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50.59 term "as described in the Safety Analysis Report", being used at the time this violation occurred, did not include such non-Q-list components.
Since
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FW32 was not a Q-list component and was not referenced in any text portion of the USAR, no written safety evaluation was performed prior to initiating the i
drawing change.
(3)
Corrective action taken and results achieved.
Procedure SP 1106.27 Startup Feed Pump Operating Procedure, has been modified to require that FW32 be
maintained in the closed position when the SUFP is not being used.
Also a drawing change has been initiated by FCR 84-218 to change P&lD M006B to reflect the normally closed condition for FW32.
(4)
Correction action taken to avoid further noncompliance.
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A revision to the Davis-Besse Facility Change Request
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(FCR) procedure will be mede such that changes to I
components showns on USAR drawings will require
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Docket No. 50-346 License No. NPF-3 Serial No. 1-490 January 14, 1985 Attachment 1
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Page 9 evaluation under 10 CFR 50.59 prior to implementation whether the component is on the Q-list or not.
(5) Date when full compliance will be achieved.
The drawing change to P&ID M-006B tc reflect the normally closed conditien f or FW32 will be cc=pleted by January 31, 1985.
Revisions to the FCR procedures will be completed by March 29, 1985.
11.3. Respense:(1) Adcission or denial of the alleged violatien.
Toledo Edisen admits to Violatien 11.3.
(2)
Reasons for violation, if admitted.
Lead shielding is placed on pipes in order to keep radiation exposures as low as reasonably achievable.
In the course of previous placecent of lead shielding.
Toledo Edison was advised by Bechtel, in letter
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BT-13024 of May 14, 1962, that generic guidelines for use of lead blankets was not feasible because of the many variables involved.
Bechtel, therefore, advised that a case-by-case safety review be performed prior to long term use of lead blankets.
As a result of this guidance. Toledo Edison interpreted that shcrt ter= use of lead shielding did net require a written safety evaluation.
(3)
Corrective steps taken and results achieved.
Tolede Edison received lE Information Notice 83-64 on
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October 3, 1983.
Evaluation of this Information Notice was not completed until 12y 1, 1984.
On May 22, 1984, af ter the evaluation of IE Infor=atien Notice 83-64, all locations where terporary shieldinF was being used were identified and field walkdowns conducted and documented on Nonconformance Reports (NCR's 84-0070, 84-0071, 84-0073, 84-0074), for each installation.
These NCR's were then forwarded to Nuclear Facility Engineering for review and disposition.
During the Performance Appraisal Inspection of July 30, 1984 through August 24, 1984, when this potential enforcement action was identified, the NRC identified short term use of lead shielding to be a failure to perform a safety evaluation pursuant to 10 CFR 50.59.
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Docket No. 50-346 License No. NPF-3 Serial No. 1-490 January 14, 1985 Attachment 1
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Page 10 As a result, Toledo Edison removed all temporary lead shielding and halted maintenance activities in these areas until written safety evaluations were conducted.
The safety evaluation for the lead shielding hung on the decay heat system piping on March 8, 1984 and May 4, 19E4, was completed on December 14, 1984.
The analysis indicated that all stress levels are within the IE Bulletin 79-14 interim criteria.
(4)
Cerrective action taken/to be taken to avoid further noncompliance.
On December 18, 1984, an internal memorandum was distributed to all Chemistry & Health Physics per-sonnel emphasizing that lead shielding cannot be applied to any safety related or Q-Syste= without a 10 CFR 50.59 vritten safety evaluation.
Procedures for controlling the use of temporary shielding are being developed.
Until~these procedures are developed, Toledo Edison vill use Nonconformance
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Reports in the interim for providing a safety evalua-tion for application and removal of temporary s.hielding.
A nonconformance report is submitted and dispositioned prior to actual use of lead shielding and the process of dispositioning requires the preparation cf a safety evaluation.
Permanent lead shielding is being handled by the Facility Change Request process.
Safety evaluations have been performed for all lead shielding currently in use at Davis-Eusse.
(5)
Date when full compliance vill be achieved.
Development and implementation of a procedure for controlling temporary shielding vill be completed by g
March 29, 1965.
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TOLEDO EDISON SALP PRESENTATION REGION 111 MARCH 6,1985
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AGENDA Introduction J. P. Williamson
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Management Initiatives R. P. Crouse improvement Actions in
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Specific SALP Areas Operations T. D. Murray l
Maintenance T. D. Murray Training T. D. Murray
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j OA & Administrative Controls R. P. Crouse
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Fire Protection R. P. Crouse
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Emergency Planning R. P. Crouse
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Conclusion R. P. Crouse
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MANAGEMENT INITIATIVES 1. Elimination Of Attitudinal Deficiencies 2. Improvement Of Communications With Our Own
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Staff And NRC l
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4. SALP Improvement Task Force j
5. Management Visits To Other Plants l
6. Salary Evaluation Program i
7. Performance Measures And Goals 8. PEP Interim Action Program
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ELIMINATION OF ATTITUDINAL DEFICIENCIES
'
HUMAN PERFORMANCE o Cannot Dictate By Memo / Decree
o Must Instill By Action / Example
'
IMPROVING ENVIRONMENT i
l 0 Personnel Shop Facility To Reduce Overcrowding And j
Eliminate Temporary Facilities o Station Office Improvements
!
o Shift Supervisor's Office Improvements I
o Control Room improvements
- Relocate CAS - 12/31/85
.
o Equipment Operators' Room
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- Moved To Plant Area
-
l oGeneral Plant Clean up
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oTraining Building improvements
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I ELIMINATION OF ATTITUDINAL DEFICIENCIES l
(Continued)
i l
SETTING THE TONE I
o Mr. Williamson Speech To Nuclear Mission Management -
!
February 5,1985 i
o Mr. Crouse Employee Meetings
'
o Mr. Murray Meeting With Staff February 21,1985 o Mr. Murray Meetings With All Employees
i TAKING ACTION l
o Reward / Recognition J
- Plant Manager Use Of Daily Status Report I
- Executive Management Actions i
o Penalty / Discipline I
- Director Demotion September,1984 i
!
- Operator Discharged February,198'5
r
- l&C Mechanics Suspended February,1985
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IMPROVEMENT OF COMMUNICATIONS
.
WITH STAFF AND NRC
!
PLANTITRAINING CENTER VISITS
!,
- Mr. Williamson Regularly i
e Mr. Crouse Weekly
- Mr. Murray And Nuclear Staff Weekly
,
NRC COMMUNICATIONS e Reassignment Of Licensing Activities i
- Designated Primary Interf aces
- Meetings With Region 111 Personnel
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STRONGER RELATIONS WITH INPS i
i ASSIST VISITS
0 Training October,1984 O Emergency Preparedness - June,1985
.
!
SRO PEER EVALUATOR PROGRAM
OOperations Engineer
!
OShift Supervisor EXECUTIVE PARTICIPATION IN CORPORATE EVALUATIONS i
OVice President, Nuclear April,1985
.
!
LOANED EMPLOYEE PROGRAM o Assistant To Vice President, Nuclear -
l Completed June,1984
!
TRAINING AND EDUCATION INDUSTRY REVIEW GROUP
.
I OAssistant Vice President Nuclear Operations
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I SALP IMPROVEMENT TASK FORCE
PURPOSE
,
oAssist Corporation in Davis Besse improvement Program
!
olmprove Performance And Plant Image in Eyes Of Industry,'
!
Public, And NRC
!
CHARTER o Review Adequacy Of Existing Programs
!
- Performance Enhancement
.
!
- Training Accreditation l
- Fire Protection
- Maintenance
l o Develop Program To improve Communications
'
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o Develop Programs To improve Attitude And Strive For
!
Excellence
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o Assess Quality, Quantity, And Schedules o Monitor Progress, Accomplishments, And Problems i
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SALP IMPROVEMENT TASK FORCE (Continued)
i
ORGANIZATION oSteering Committee
,
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- Region 111 Industry Representative
]
- National Industry Representative l
- Regulatory Agency Representative
-
OWorking Group
i
- Six Members
'
- Non Nuclear Mission
- Expertise Areas l
Nuclear Engineering j
Electrical Engineering i
Industrial Engineering
Accounting
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Communications
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MANAGEMENT VISITS TO OTHER PLANTS MR. WILLIAMSON o Fermi December,1984 o Beaver Valley February,1985 o Brunswick February,1985
,
MR. CROUSE o Brunswick February,1985 o Planned
'
- Fermi
- Callaway
- Kewaunee
- Prairie Island f
MR. MURRAY
.
o Fermi January,1985
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MANAGEMENT INITIATIVES
! 1. Elimination Of Attitudinal Deficiencies l 2. Improvement Of Communications With Our Own
)
Staff And NRC j 3. Stronger Relations With INPO
i 4. SALP Improvement Task Force
! 5. Management Visits To Other Plants
'
- 6. Salary Evaluation Program el MJ
,
j 7. Performance Measures And Goals u
.J rs--y
{ 8. PEP Interim Action Program
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PLANT OPERATIONS
'
Category Performance Over SALP Period
!
Declining
!
IDENTIFIED PROBLEM AREAS l
1. Procedural Weakness l
2. Knowledge Of The Plant Design Basis
!
3. Attention To Detail 4. Personnel Errors
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PROCEDURAL WEAKNESS i
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AD 1839.00 STATION OPERATIONS j
O Reinforced Control of Procedure Sign Off l
olncreased Valve Lineup Guidance
- All Shift Supervisors Trained February 1985 l
- 4 Of The 6 Shifts Trained Presently l
- Remaining 2 Shifts To Be Trained March 31,1985
!
PP 1102.01 PRE START CHECKLIST
'
I oincreased Valve Lincup Verification l
PEP ACTION PLAN ON STATION PROCEDURE ERRORS REDUCTION (E/SP 5)
,
!
oldentification Of Procedures To Be Reviewed Completed
)
oReview Of Procedures To Be Completed December 31,1985 l
- 10% Of Review Completed
'
l ATOG IMPLEMENTATION i
l oSymptom Oriented Emergency Procedures
- Licensed Operators Trained Prior To Start up From 1984
,
Refueling Outage I
,
]
- Incorporated into The 1984 Simulator Training Program
'
- Incorporated into The Requalification Program 1985 l
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l KNOWLEDGE OF THE PLANT DESIGN BASIS
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- UPDATED SAFETY ANALYSIS REPORT (USAR) REVIEW
- OSystem By System Review
] outilizes Knowledgeable Project Personnel j
- Process identification March 1,1985 i
j
- Review Of First System March 31,1985
[
l
- Final Plan And Schedule May 1,1985
- SRO REVIEW OF MAINTENANCE WORK ORDERS (MWOs)
j OReduces Number Of Incorrect MWOs That Reach The Shift
l Supervisor l
- 5 SROs On Operations Staff i
!
- 1 SRO On Loan To Maintenance For Pre Review
! USE OF JUMPER AND LIFTED WIRE SYSTEM TO
l DOCUMENT TEMPORARY MECHANICAL MODIFICATIONS l olmplemented May,1984
! OPERATIONS STAFF TRAINING
! oincrease Design Basis Knowledge Of Operations Staff -
j
- System Training To Begin April,1985 l
- Administrative Procedures Training l
- 1 Engineer To Complete Reactor Operator License
Training September,1985
- 1 STA To Complete SRO License Training Early 1986
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KNOWLEDGE OF THE PLANT DESIGN BASIS
'
! STATION REVIEW BOARD TRAINING
l oSpecific Training will Be Provided in 1985 In Four Areas
- SRB Function, Responsibility, Authority
)
- SRB Charter l
- Unreviewed Safety Question,50.59 Safety Evaluation j
- Conditions Adverse To Quality, Corrective Action System j oThis Training Will Also Be Given To The Deviation Report l
Subcommittee i
STA TRAINING l oEntire Program Has Been Re structured
l OFormal Training Complete March,1985 j
OSix Weeks in Class Six Weeks On Shift
{ oTraining Provided By Operations Staff
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ATTENTION TO DETAll REINFORCED NEED FOR STRICTER PROCEDURE ADHERENCE o Disciplinary Action Will Be Taken, When Necessary VALVE LINEUP CONTROL UPGRADES ORequire Independent Verification Of Valve Lineups Of Designated Systems oRequire Independent Verification Of Valve Position Following Tagouts oFull Valve Lineups Run On All Systems Prior To Startup From 1984 Refueling Outage ENCOURAGE PROFESSIONALISM BY OPERATORS o Shift Meetings Held By Operations Engineer c#"
olmplementation Of The MBO Process.
O Environment Upgrade Planned
- Shift Supervisor Office Upgrade July,1985
- Improve Appearance Of Control Room June,1985 RESTRICTED ACCESS TO CONTROL ROOM oimplemented January,1985
-
- Expanded Control Room " Restricted Zone"
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j PERSONNEL ERRORS STA TO ASSUME INTERIM EDO RESPONSIBILITY
'
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ORelieves Shift Supervisor Of Interim EDO Burden
During An Emergency I
- Training Of STAS To Be Completed April 15,1985
'
{
- To Be implemented For Evaluation On A Trial l
Basis During Annual Drill Activities And During
Table Top Exercises
NUISANCE ALARM REDUCTION
!
OReduces Possible Operator Confusion Due To l
Unnecessary Annunciator Alarms
- Reduce Number Of Currently identified Nuisance
.
l Alarms To 3
)
e 1 Alarm To Be Resolved April 1,1985
!
e Remaining 2 To Be Resolved Through The FCR i
l Process l
l PEP ACTION PLAN ON GENERIC GUIDANCE UPGRADE l
(E/SP 6)
OProvides More Usable Generic Guidance Format
-
- Delete Redundancies l
- Incorporated into Procedures Where Appropriate l
- Reformatting Of Remaining Guidance To Be
Completed April 1,1985 i
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MAINTENANCE
Category Performance Over SALP Period
'
Improved IDENTIFIED PROBLEM AREAS
,
1. Adherence To Procedures 2. Attention To Detail 3. Personnel Errors 4. Management Overview
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ADHERENCE TO PROCEDURES
!
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l AD 1844.00, MAINTENANCE, AD 1845.00 CH ANGES, TEST AND EXPERIMENTS,IC 2001.00. INSTRUMENT
l CAllBRATION OProvide improved Control Of Nuclear Safety Related
l Maintenance Activities o Requires Use Of Controlled Drawings And Vendor Manuals I
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In The Field
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l ATTENTION TO DETAll
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l MAINTENANCE STAFF ADDITIONS
{
o Reduce Work Lead On Individuals /Get Staff into Field i
- 4 New People Hired
!
- 2 Modification Coordinators On Loan To Maintenance For 1985
- Offer Extended To Lead l&C Engineer Candidate
February 25,1985
'
EXPANDED MAINTENANCE COVERAGE l
o Addition of 16 Maintenance Shop Positions To Spread i
.
j Work Load
{
- 6 Personnel Requisitions Approved l
1 Person Hired ll 5 Positions To Be Filled By April 1,1985 l
- Interview / Selection Process For Remaining 10 Positions To Begin July 1,1985 j
PERSONNEL AND SHOP FACILITY l
0 Provide A Larger Maintenance Shop Area And Additional
!
Office Space
'
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- Ground Breaking Scheduled For June,1985
- Scheduled Completion Date April,1987
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PERSONNEL ERRORS
,
l MAINTENANCE STAFF TRAINING
!
oBetter Understanding Of Design Basis And Job
Requirements
!
- 4 Weeks Of System Training To Be Completed-July,1985 I
- 20 Hours Of Administrative Procedure Training To Be j
Completed July,1985
!
l
- 10% Of Staff Time Reserved For Training
.
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MAINTENANCE SHOP PERSONNEL TRAINING
'
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o Better Understanding Of Plant Design And Job l
Requirements
!
- 20% Of Maintenance Shop Time Allocated For Training 10% Formal Training
-
l 10% In shop Training
!
- 20% Of In shop Training Instructor's Total Time is l
Allocated For Training And Preparation
'
10% Actual Training 10% Lesson Plan And Material Preparation
!
- Requirement To Attend Training l
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MANAGEMENT OVERVIEW
,
MBO PROGRAM INPLEMENTED IN MAINTENANCE
'
DEPARTMENT j
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O Improved Understanding Of Job Responsibilities And l
Accountability
'
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- Implemented in Mechanical Maintenance Area 1984
- Begin implementation For Remaining Areas Of
'
Maintenance March,.1985 l
- Goal is 100% Participation To Supervisor Level in 1985 QUALITY CIRCLE PROGRAM (VOLUNTARY)
j o improve Quality Of Work Place And Performance j
- Pilot Program implemented in 1983
- 5 Additional Groups To Begin l
Leader And Assistant Leader Training Completed i
January 3,1985
-
First Group Meeting Held February,1985
,
Each Group To Meet Once Per Week
PEP ACTION PLAN FOR NON OUTAGE WORK
PRIORITIZATION (E/SP 3)
'
l 0 Provide For Completion Of Most important Work First
!
By Utilization Of A Prioritization Process l
- In Place On A Trial, Manual Basis February,1985 l
- Fully implemented By June,1985
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MANAGEMENT OVERVIEW
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ADDITION OF FOUR ADDITIONAL MAINTENANCE FOREMEN
oincreased Overview Of Maintenance Activities oincreased in Field Supervision
- 2 Foremen Currently identified To Be Promoted -
i April 1,1985
!
- Expected Promotion Date For Remaining 2 Foremen -
July 1,1985 l
PEP ACTION PLAN FOR STOCK SYSTEM UPGRADE (E/SP 12)
,
o Provide More Appropriate Spare Parts Stocking i
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TRAINING Catego_ry, Performance Over SALP Period
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Declining IDENTIFIED PROBLEM AR$AS 1. Staffing And Tools 2. Management Oversight 3. Operator And Non Operator Training
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STAFFING AND TOOLS TRAINING STAFF INCREASES oincludes Both Instructors And Support Positions i
- 39 Positions Currently Authorized
)
- Current Training Staff Level - 30 j
16 Positions Have Been Filled Since August,1984
j 1 Person Has Accepted But Not Yet Arrived 3 Offers Have Been Extended With Responses Pending 1 Position is Being Filled By A Temporary Employee
Expect To Reach Full Staffing July,1985 l
l INSTRUCTOR TRAINING PROGRAM l
o Provide All Training instructors With Appropriate Skills
To Perform Their Jobs
~
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- 3 Part instructor Training Program (P'erformed To INPO l
Guidelines)
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STAFFING AND TOOLS (Continued)
l TRAINING LABORATORY AND CLASSROOM UPGRADE
'
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- Provide More Classroom Space And Better Training Lab Facilities
,
'
'
- Office And Classroom Upgrade To Be Completed -
August 1,1985
)
- Lab Construction To Follow Completion Of
!
Classroom Upgrade Labs To Be Located in Current Classroom Area i
PLANT REFERENCED SIMULATOR PROJECT
- Provide For On-site Simulator To Enhance Training
,
Program
- $13 Million Project l
- Specifications Contract To Be Let' April 1,1985 j
- Simulator Scheduled To Be Operable -
!
December,1988 l
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STAFFING AND TOOLS (Continued)
MASTER TRAINING SCHEDULE
,
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o Procedure Approved - December,1984 o Schedule in place - January,1985 o First Quarterly Update - March,1985
.
o Distributed Weekly ACTION STATUS LIST o Tracks Appropriate items From Training Diagnostic, Training Commitments To NRC, Individual Requests For Training Action, Specific Milestones From Accreditation Plan -
,
in-place And Operational November,1984 TRAINING INFORMATION MANAGEMENT SYSTEM (TIMS)
o Assists The Overall Coordinator Of Lesson Plans, Exam Bank, Procedures (Plant-Related), INPO Data Base, Training
,
Procedures o In-place And Operational February 1,1985 i
i o Data Base Upgrade Ongoing o Communication With INPO Data Base
.
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MANAGEMENT OVERSIGHT TRAINING REVIEW BOARD oDiscuss/ Resolve Training issues And Review Quarterly Revisions To The Master Training Schedule
- Plant Manager is The Chairman
- Station Section Heads Are Members
- Training Manager And Supervisors Are Members
- First Meeting Scheduled March,1985
- Meeting Frequency - Quarterly And As Necessary
'
REVIEW OF VENDOR PROVIDED TRAINING o Provide For TED Evaluation Of Vendor Training Services
- Procedure To Monitor Vendor Conducted Training Classes To Be Completed - April 15,1985
- Scope And Presentation Evaluation'is Performed By
Students l
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i MANAGEMENT OVERSIGHT (Continued)
DIAGNOSTIC RESOLUTION
'
oProvide Resolution Of Problems identified in The 1983 Third Party Evaluation Of The Training Program
- Resolution
Short term Actions incorporated AsPEPInterim Actions
.
Incorporation into The INPO Accreditation Process Long-term Actions Tracked On Action Status List l
Determined To Be Inappropriate
'
INPO ACCREDITATION PROGRAM
'
o Provide Program To Comply With NUMARC CommitmentTo Be Ready For INPO Accreditation Of Our Nuclear Training
'
Programs By Decemt er 31,1986 t
- 10 Specific Areas To Be Accredited
,
- 3 Areas To Be Completed - December 31,1985 Licensed Operator Training Non-Licensed Operator Training Requalification Training
- INPO Site Visit Occurred - October,1984
- NRC Division Of Human Factors Visit Scheduled -
,
'
Spring,1985 i
_. - - _
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OPERATOR AND NON OPERATOR TRAINING LICENSED OPERATOR TRAINING oReduced Self Study Time
'
oProvide More Structured Guidance For Self-Study Time OReduce Required Reading For On-Shift Operators By Direct Training oincreased Monitoring Of B&W Supplied Training At The Simulator implemented in 1984 oBegan Development Of An Examination Question Bank l
'
NON-LICENSED OPERATOR TRAINING
!
o Upgraded The Substance Of The Non Licensed Operator
'
Training Program olncreased Use Of Structured in-Plant S.ystem i
Walk Throughs 052 System Lesson Plans Have Been Completed o Remaining 15 System Lesson Plans Will Be Completed Prior To The Scheduled Training For The Specific System l
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QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS
'
Category Performance Over SALP Period 3,
Declining
,
IDENTIFIED PROBLEM AREAS 1. Resolution Of QA Findings And Open items 2. Management Oversight 3. Technical Expertise Of Auditors
,
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RESOLUTION OF QA FINDINGS AND OPEN ITEMS TRACKING OF QA FINDINGS AND OPEN ITEMS l
O All Audit Finding Reports (AFRs), Deviation Reports (DVRs), Supplier Deviation Reports (SDRs) And Non-Conformance Reports (NCRs) Are Tracked Utilizing The Davis Besse Maintenance Management System (DBMMS)
i o All AFRs And NCRs Are Reviewed By The Station Review Board (SRB)
DEVIATION REPORT (DVR) MONITORING PROGRAM
,
oSRB Subcommittee To Develop Corrective Action Commitments For DVRs Formed February,1985 o Quarterly Reports On DVR Status Sent To SRB For Review
-
OStation Technbal Section Has Two People Administering The DVR Tracking Program
,
CLOSEOUT MONITORING OF AFRs, DVRs, SDRs AND NCRs o Mission Performance Measures in Place To Monitor Closeout
,
- - -., - - -
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MANAGEMENT OVERSIGHT ATTENDANCE AT AUDIT EXIT MEETINGS oSupervisors Of Audited Areas Have Been Directed To Attend Exit Meetings o At The Discretion Of The Auditor, Higher Level Supervision Can Be Requested To Attend Exit Meetings BALANCE OF PLANT (BOP) QA PROGRAM OTED Management Has Approved A Proposal For An Expanded QA Program
- Nuclear Facility Engineering Has Been Tasked With identifying Appropriate Equipment Classifications
.
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TECHINCAL EXPERTISE OF AUDITORS
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AUDITOR TECHNICAL TRAINING PROGRAM l
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oAll Auditors To Receive Some Form of Technical i
Training In 1985 i
- Provided By Outside Contractors And By Nuclear
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Training Department oOA Personnel Receiving STA Training
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- Improve Plant Knowledge Within OA Division
l 1 Staff Member Completed Training November,1984 l
1 Staff Member To Begin Training - March,1985
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USE OF TECHNICAL EXPERTS ON AUDIT TEAMS oProvides Subject Matter Expertise For Specific Audits f
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- 32 People Have Received Auditor Training l
- Further Training Scheduled For Early 1985 l
- 7 Audits Have Been Performed Utilizing Technical
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l Experts
- TED Goal is To Utilize Technical Experts On l
Every Internal Audit in 1985 And Beyond
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SPECIALIZED AREA AUDIT EXPERTISE l
oFunds Are Authorized To Contract Outside Expertise j
For Specialized Audits
. _ _., _ _ _.. _ _ _ _ _.. _. _,,. _. - - - _ _. _... _ _ - _ _. _.
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FIRE PROTECTION Category Performance Over SALP Period
Improving IDENTIFIED PROBLEM AREAS
1. Procedural Weakness 2. Compliance With 10 CFR 50 Appendix R
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PROCEDURAL WEAKNESS
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FIRE PROTECTION PROCEDURE DEVELOPMENT 03 Specific Fire Protection Procedures Have Been
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Implemented
- Serious Control Room Or Cable Spread Room Fire
- Serious Fire Other Than Control Room Or Cable
- General Fire Procedure
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FIRE STRATEGY PLAN UPGRADE OProvide A Room By Room Plan To Deal With A Fire
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0 Fire Strategy Plans Will Be Completed August 1,1985 t
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COMPLIANCE WITH 10CFR50 APPENDIX R
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FIRE PROTECTION PROJECT TEAM
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l OProject Management Team Formalized January 1,1985
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- 4 People Full Time l
- 4 People Part-Time I
oTwo Qualified Fire Protection Engineers i
oPerforming Committed Reviews oPerforming Conceptual Engineering For Fire Protection Modifications l
COMPLIANCE ASSESSMENT REPORT (CAR)
j OSystematic, Area By Area Review For Potential Non-Compliance With Appendix R oSubmitted To NRC September 1,1984
oCurrently Awaiting Review By NRC
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EMERGENCY PLANNING Category Performance Over SALP Period
Declining l
lDENTIFIED PROBLEM AREAS 1. Tracking 2. Scenario Weakness 3. Exercise Weakness
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TRACKING
ACTIVITIES SCHEDULING SYSTEM l
O Provide A Tool For Tracking Open items And Activities Within The Emergency Planning Group OTracks items Such As
- NRC Commitments
- INPO Commitments
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- QA Audit Finding Reports
- Drill And Exercise Critique items
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o Used in Conjunction With Mission Commitment Tracking
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System o Fully Operational By September 30,1985
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l SCENARIO WEAKNESS
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I SCENARIO DEVELOPMENT COMMITTEE
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oMembership Includes The Following Positions Plus Eight Other Professionals From The Nuclear Mission And i
i Outside Organizations
- Operations Engine'er (Chairman)
- Engineering Section Head
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- Nuclear Training Supervisor
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- Security Supervisor
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- Environmental Supervisor i
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- Chemistry And Health Physics Supervisor l
- Nuclear Project Manager I
oFirst Meeting Was Held February 15,1985 And The Second Meeting Was Held March 4,19,85
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EXERCISE WEAKNESS i
EMERGENCY PLAN TRAINING UPGRADE
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Olncreased Use Of Hands On Training
- Activating Emergency Planning Facilities During Training
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- Use Of Communications Equipment
l
- Use Of Status Boards And Logs
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- Security Training - January,1985 o Use Of Table Top Exercises
- Technical Support Center Training February,1985 l
- Emergency Control Center Training March,1985 l
l
- Full Emergency Responco Facility o Full Scale Exercise Dry Run l
- Will Involve Toledo Edison, Ottawa County And
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State Of Ohio
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- Will Be Monitored And Evaluated By INPO l
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l MANAGEMENT COMMITMENT TO EMERGENCY PLANNING l
o Guidance Momoranda Issued By Assistant Vice President, i
Nuclear Operations
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- Reinforced Management Commitment To Emergency
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l Planning Program January,1985
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- Required Attendance At Emergency Plan Training -
February,1985
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COMPLETED ACTIONS
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e Doubled Training Staff
- Tripled Licensing Staff eMaintenance Staff increased By 5 e Adopted 39 Performance Measures
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e Adjusted 39 Engineers Salaries
- Completed 126 Of 159 PEP Interim Actions e Exercised Significant Disciplinary Action e ATOG Training e Procedure Training
- For 128 Station Services And Maintenance Personnel eTrained 35 People in MBO Process
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- 10 Quality Circle Leaders Trained e Established 1985 Master Training Sc'hedule i
eimplemented TIMS e Auditor Training For 32 Technical Experts e EP Security Training
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COMPLETED ACTIONS (Continued)
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l o Operator Requal Classroom Training Time Doubled
o Developed Accreditation Schedule l
o Wrote 58 New Non Licensed Operator Lesson Plans 0 Established Training Review Board o Established DVR Subcommittee Of SRB
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I o increased Management Visits i
o Directed QA Audit Exit Attendance
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o Plant Clean up j
o Established New Equipment Operators Room i
i o Control Room Appearance improvements i
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o Operating Shift Discipline improvements l
o Regular Mission Staff Meetings
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o Employee Meetings t
l o Mission Management Meetings o Regular Section/Section Head Meetings
l o Regular TED NRC Meetings l
0 Reassignment Of Licensing Activities i
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