ML041490091

0350 Panel Briefing Presentation 0350 Panel Briefing for NRC Senior Management, Davis-Besse Oversight Activities, Panel Restart Deliberation Briefing

ML041490091
Person / Time
Site:	Davis Besse
Issue date:	02/23/2004
From:	NRC/RGN-III
To:
References
FOIA/PA-2004-0140
Download: ML041490091 (24)

Text

I\\6 Slide 1 0350 Panel Briefing for NRC Senior Management Davis-Besse Oversight Activities Panel Restart Deliberation Briefing February 23,2004 L"W ~\-

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Slide 2 (M) Davis-Bsse Oerslgbt Actviti Briefing Book Contents

• Confirmatory Action Letter

• 0350 Panel Charter

• Licensee Return to Service Plan

• NRC Restart Checklist

• 0350 Panel Process Plan

• Significant Inspection Findings I End of Cycle Summary Report

• Public Interactions

• Briefings for Public Officials Vcbnmry2t14 (LIPA)

Discuss each item in the Briefing Book (Please flip to TAB B) Confirmatory Action Letter - Issued March 13, 2002 - Updated five times - 6 specific commitment areas, Quarantine, Root Cause, Extent of Condition, Repair or Replace of Head, Risk Assessment, and Meet with NRC for Restart Approval.

(Please flip to TAB C) 0350 Panel Charter- Issued in April 2002 -

Introduce each of the Panel Members (Grobe, Ruland, Lipa, Hills, Jacobson, Mendiola, Hopkins, Thomas, Sonia Burgess). Discuss breadth and depth of Regulatory experience, and continuous involvement with project.

(Please flip to TAB D) Licensee Return to Service Plan - Licensee's org chart and building blocks for their Return to Service Plan. Panel considered it a comprehensive plan. A living plan, it has been revised six times.

(Please flip to TAB E) NRC Restart Checklist - Listing of items on the checklist, categorized into seven areas. Developed using the AIT and AIT Follow-up inspection findings and the licensee's RTS plan. Used to guide our inspection and assessment activities.

(Please flip to TAB F) 0350 Panel Process Plan - Developed specifically from IMC 0350 requirements.

(Please flip to TAB G) Significant Inspection Findings - Table of colored findings identified at Davis-Besse during the extended shutdown.

(Please flip to TAB H) End of Cycle Summnary Report - Used in February 2004 EOC meetings (Please flip to TABs I thru K) Reference material - Material from Public Interactions (Specifics on Public Meetings, a copy of the Monthly Public Newsletter, and sample of correspondence with the public)

(Please flip to TAB L) Briefings for Public Officials - Reference Material on Briefings for Congressional, State, and Local Officials (Please flip to TAB M) Current copy of 0350 Procedure - dated 12/31/03, some of the DB lessons-learned was provided by the Panel to enhance this procedure. Additional insight to be used in future revisions.

Slide 3 Davis-Besse Ovenight Activiies 0350 Panel Formation

• March 2002 Discovery of Degradation

• Augmented Inspection Team

• Confirmatory Action Letter

• 0350 Decision

• Restart Checklist Febzryw25.23 (LIPA)

Discuss each item of the Background information March 2002 Discovery of Degradation - Plant shut down on 02/16/2002.

Inspection of CRDM penetrations to be done in response to NRC Bulletin 2001-01. Degradation found on 03/06/02.

Augmented Inspection Team - Sent on 03/12/02 Confirmatory Action Letter - Issued on 03/13/02 0350 Decision - Decision to initiate 0350 panel made on 04/29/02 Restart Checklist - Panel issued on 08/16/2002, developed IAW IMC 0350. Revised as necessary as panel gained insight from inspections and licensee assessments. Last updated in July 2003.

Slide 4

( i) Davis-Besse Oversight Actites 0350 Panel Process

• Focus on Safety

• Panel Process Plan

• Restart Action Matrix Restart Checklist Closure

• Internal Panel Meetings

• Communications Plans - Communication Team

• Licensing Activities Fnmary 21320014 (LIPA/AIENDIOLA)

Discuss Panel Process - SAFETY FOC Use of high standards, regulatory rigor ainta Panel Process Plan - Example - B1.4 Assessment of Licensee Performance area, Quarterly evaluation by the panel of the licensee performance indicators, evaluation by the panel of inspection findings and results, all documented in panel minutes that will become publicly available.

Restart Action Matrix - Example - over 325 items dispositioned, each one evaluated and documented and brought to panel for approval closure.

Additionally, the Panel polled the NRC staff for restart concerns and dispositioned all concerns and documented into the RAM. Incorporated all inspection attributes for Inspection procedures 95002 and 95003 into inspection activities, tracked by the RAM.

r Restart Checklist Closupi - Each inspection;it developed Sac pefibi~n P t Xihg eisting inspection modules and additional details from the RAM. Each one was brought to Panel for approval.

Internal Panel Meetings - Met on average two to three times at week, detailed panel meeting minutes to be made public.

Communications Plans - Communication Team - Example - use of communication matrix and a communication disposition rules to consistently approach communications. (GET COPY)

Cicensing Activities - Example - Use of the Restart Checklist to inform the panel and track restart licensing actions (such as Code Relief Requests) to completion.

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Slide 5

) Dvls-Bme OversightAcdvides Licensee's Assessment of Root Causes

• Reactor Pressure Vessel Head degradation caused by PWSCC and Boric Acid Corrosion

• Lack of Nuclear Safety Focus Led to Acceptance of Degraded Plant Conditions

• Other Deficiencies Determined In Corrective Action Programs, Engineering Analyses, Procedure Compliance, Quality Assurance Oversight, Operations Leadership and Safety Focus of Company Nuclear Review Board Ftbrny 23.2ft4 (MENDIOLA)

Licensee's Assessment of Root Causes Licensee's RPV degradation RC issued in April 2002 and updated in Sept 2002. NRC staff evaluated it as a plausible scenario. Uncertainties with aspects of the root cause preclude a definitive conclusion.

Licensee's Management and Human Performance RC issued in August 2002, the first of seven assessments performed from 2002 to early 2003 on Organizational Issues. The NRC has evaluated all of these seven assessments and found them to be of appropriate depth and breadth to develop actions to correct and prevent recurrence of the management and human performance deficiencies associated with the reactor head degradation.

Slide 6 l Ddls-Desse M Overight Aedyfies NRC's Most Challenging Areas

• Corrective Action Program

• Engineering Analyses

• Operations Performance

• Safety Culture - Management and Human Performance

• Ongoing Investigation Status

• Public Access and Stakeholder Involvement Fubnnry 2XM1 (MENDIOLA)

NRC's Most Challenging Areas (This is a lead-in slide for the next six slides. Details will discussed during those slides).

Corrective Action Program Engineering Analyses Operations Performance Safety Culture - Management and Human Performance Above Licensee Programs found acceptable with the need for an Order to provide for lasting improvements Ongoing Investigation Status Public Access and Stakeholder Involvement

Slide 7 Davsh-Bee Ovenlght Acwidlea Corrective Action Program

• Licensee Found Deficiencies in the Implementation of their Corrective Action Program

• 2002 SSDI Inspection found numerous system design issues which were placed in CAP

• Licensee's Program Review and Enhancements

• Corrective Action Team Inspection of Licensee's Resolution of SSDI findings and RAM Items FA~nry 23.200 7 (LIPA)

Licensee found deficiencies in the implementation of the program thru their root cause evaluation for the RPV Head degradation.

2002 SSDI inspection found numerous system design issues which were placed in CAP (30 URIs and NCVs)

NRC Inspected the Licensee's Program Review and Enhancements and found the program to be acceptable, but Panel left the Restart Checklist item open until implementation of the problem evaluated by the CATI Corrective Action Team Inspection of Licensee's Resolution of SSDI findings and RAM Items (95003 Attributes). Team found concerns with engineering analyses and resolution of design issues (Myopia of apparent cause assessments and trending program). More that 25 Violations, low significance (engineering quality, calculations and analyses).

CATI team concluded that licensee's program is acceptable for restart.

Significant 0350 Panel interaction with CATI.

Slide 8

{ ) Davs-BessE Oversight Activities Engineering Analyses

• Replacement of the Reactor Pressure Vessel Head

• High Pressure Injection Pumps, Emergency Sump, and Containment Coatings

• CATI Identified Weaknesses In Resolution of Design Issues and Engineering Analyses FV.Inmry 21104 (MENDIOLA)

Replacement of the Reactor Pressure Vessel Head To the NRC this was Unique, complex, first of its kind evaluation, involving an onsite inspection of head, and placement thnu containment and removal and storage of old head. - und licensee resolutions effectively planned and implemented MM High Pressure Injection pumps, Emergency Sump, and Containment Coatings Complex engineering evaluations performed, NRC reviewers found them to be complete and well performed. -Bttens'siBSO'iNRe-racti'f'sgbith dedicated technical reviewers on HPI pump and Emergency Sump work, including G 1 cK,:-4iiltaftsOdM~nd6r-s-g.vd en Jabo*X~at~o r iegk 1--id k'ierff-nn ste-vi

CATI identified weaknesses in dc 1 nnig , ering, resolution of design issues, and engineering analyses as evidenced by 25+ low significance violations in the CATI report 5.

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Slide 9 h-' Davls.Bese Ovesig~ht Activides Operations Performance

• September 2003 NOP Test

• December 2003 RRATI Results

• Late December Operational Challenges

• January 2004 Corrective Actions and Management Changes

• February 2004 RRATI Follow-up Yebrry2.1.210 (LIPA)

Operations Performance September 20, 2003 NOP Test - Heat up Operational Performance issues (Core Flood Tank and Cool Down Reactor Trip)

December 2003 RRATI Results - Inconsistent understanding and implementation of Operational standards and expectations Late December Operational ChAl_,egs - Technical Specification Violation and Tagout of Valves (Missed LCO)

January 2004 Corrective Actions and Management Changes - Peer Observers, improved pre-job briefs, put Operations in charge for the plan February 2004 RRATI Follow-up - Found improvements, actions successful implemented, no concerns for restart

Slide 10 Cp Davis Bees Ovenight Acvides Safety Culture - Management and Human Performance

• Review of Licensee Root Cause

• Review of Licensee's Corrective Actions

• Review of Effectiveness of Corrective Actions

• November 2003 Survey Results FYbmRury

23. 2I04 (LIPA)

Why a challenge - not a specific NRC area of Inspection, used Criterion XVI of Appendix B Review of Licensee's Root Cause Use of experienced team of Inspectors - Phase I of M&HP inspection -

concluded that the licensee actions to be of appropriate depth and breadth to correct and prevent recurrence of the management and human performance deficiencies associated with the reactor head degradation.

Review of Licensee's Corrective Actions Phase 2 - Based on review of selected corrective actions, the team concluded that corrective actions if properly implemented and monitored would address the licensee's root causes.

Review of Effectiveness of Corrective Actions Phase 3 - Concluded that the tools that licensee was using to monitor safety culture and SCWE were appropriate and provided valuable information in theses areas.

November 2003 Survey Results There were additional negative responses (in area of Production over Quality) in a number of key organizations as compared to the March 2003 Survey. M&HP team concluded that the licensee's assessment of the causes for the increased negative responses and the licensee's corrective actions was appropriate.

LEAD IN TO JACK's COMMENTS

Slide 12 (1R)- Davh-Besse Overigbt Acdvldes Public Access and Stakeholder Involvement

• Over 70 Public Meetings

• More than SO briefings for Federal, State, and Local Officials

• Davis-Besse Public Web Site More thO Davis-SeverhlT Demonstrated ou ra enhancing public confidence in the NRC

Slide 13 I@) D2viU-Bese Overlght Aedildes Panel Recommends Confirmatory Urcder at Restart 7 ,

• Ensure Performance Improvements are Lasting

• Requires Independent Outside Assessment

• Areas Include Safety Culture, Engineering, Corrective Actions, and Operations

- Wvid-cycle Outage Related Activities (MNIOLA)

Issue a onfirmatory Order to Ensure performance improvements are lasting

- Two Conditions of the immediate effective order are to provide to the a a rance that the long-term corrective actions remain las r those conditions that resulted in risk-significant encies.

- The two conditions are (1) annual independent assessments for five years in the areas of operations, engineering, corrective actions, and safety culture and (2) inspection and evaluation of the RCS pressure boundary during a mid-cycle outage.

Requires Independent Outside Assessment Areas include Safety Culture, Engineering, Corrective Actions, and Operations Mid-cycle Outage Related Activities

Slide 14 D2Ds.Des Overight Acd Oversight Should Restart Be Authorized

• Around-the-clock Inspection of Start-up Activities

• Inspections to Confirm Licensee Actions Related to the Order

• Enhanced Inspections Related to NRC Performance Indicators v Resident Inspection Staff has been Augmented

• Davis-Besse Oversight Panel will Continue to Assess Licensee's Performance and Guide NRC actions Felhmw V2fI4NU 34 (LIPA)

• Around-the-clock Inspection of Start-up Activities - Upon licensee consent to the order and before Low Power Physics testing Inspections to Confirm Licensee Actions Related to the Order Enhanced Inspections Related to NRC Performance Indicators are not Currently Informative Resident Inspection Staff has been Augmented Davis-Besse Oversight Panel will Continue to Assess Licensee's Performance and Guide NRC actions Panel Membership to be adjusted as appropriate Support post-restart oversight and inspection plans Panel has prepared and approved an inspection schedule update letter to the licensee An NRC Lead Engineering Inspector (based in Region III) will be assisting with the inspections and evaluations Special inspections to be added to verify license actions related to the order Expanded baseline inspections thru March 2005 to regularly assess effectiveness of CA program

Enhanced inspections planned to gain perspective in areas monitored NRC performance indicators to gain by sufficient insight into plant performance.

Slide 15

( DavisBense Omnslght Actvlda 0350 Panel Outcomes

• 0350 Panel Focused Agency Resources on Safety

• Used Methodical Regulatory Processes

• Effectively Monitored and Assessed Licensee Improvement Efforts

• Enhanced Public Confidence

• Achieved the Agency's Mission and Goals FAInmr7 211ti U (MENDIOLA) 0350 Panel Focused Agency Resources on Safety Used Methodical Regulatory Processes Effectively Assessed and Monitored Licensee Improvement Efforts Enhanced Public Confidencethrough Extensive Interactions with the Public)- Based on high communication standards, regulatory rigor, and numer us effective public interactions.

Achieved the Agency's Mission (protect public health and safety) and Goals (Unnecessary Regulatory Burden, Increase Public Confidence, Maintain Safety, Effective, Efficient and Realistic)

Slide 16

{M) DwsIJ-Besse OYersightAdvidies Panel Conclusions and Recommendations

• Licensee Performance is Adequate for Safe Restart and Operation

• Authorize Davis-Besse to Restart

• Issue a Confirmatory Order to Ensure Performance Improvement is Lasting

• Implement Post-Restart Panel Oversight and Inspection Plans 2N tf0 rvbrwry2 ii (LIPA)

Licensee Performance is Adequate for Safe Restart and Operation Concluded that the facility, and the licensee's staff performance is adequate to support safe restart and operation Authorize Davis-Besse to restart Issue a Confirmatory Order to ensure performance improvements are Iastin

An NRC Lead Engineering Inspector (based in Region III) will be assisting with the inspections and evaluations Special inspections to be added to verify license actions related to the order Expanded baseline inspections thru March 2005 to regularly assess effectiveness of CA program Enhanced inspections planned to gain perspective in areas monitored by NRC performance indicators to gain sufficient insight into plant performance.

SAFETY CULTURE ISSUES AT THE DAVIS-BESSE NUCLEAR POWER STATION DEFINITION OF THE PROBLEM On August 21, 2002, the licensee submitted it's root cause for the reactor pressure vessel head degredation concluding that 'there was a lack of sensitivity to nuclear safety and the focus was on justifying conditions." Further, the licensee concluded that there was less than adequate nuclear safety focus" and 'there was less than adequate implementation of the corrective action program as indicated by addressing symptoms rather than causes." To address these cultural deficiencies in its past performance, the licensee created the Management and Human Performance building block in its Return to Service Plan to further identify organizational performance and cultural causal factors and identify and track implementation of corrective actions.

NRC INSPECTION AND ASSESSMENT The NRC structured it's inspection in this area in three phases; (1) inspection of the root cause evaluations; (2) inspection of the corrective action development, prioritization and implementation; and (3) evaluation of the effectiveness of the corrective actions at improving organizational effectiveness and cultural.

Phase 1 - Inspection of the Root Cause Evaluations The first phase of the inspection was the assessment of the adequacy of the licensee's root cause evaluations. This inspection was conducted by Region IlIl, NRR and contract staff expert in inspection and assessment, root cause evaluation techniques, and human and organizational performance. The licensee used MORT to perform their overall root cause assessment. The inspection team found that the principles of MORT were properly applied; however, the depth of the assessment was not sufficient to reveal all the causal factors. The licensee performed additional assessments in multiple areas including engineering, operations, oversight committees, and corporate support, among others. Review by the team revealed that the combination of assessments resulted in sufficient breadth and depth to be confident that the causal factors were identified. During the course of these reviews, many contributors were identified, including deficiencies in the licensees safety conscious work environment and employee concerns program, as well as safety culture at the facility.

Phase 2 - Inspection of the Corrective Action Development. Prioritization and Implementation The same team returned to evaluate the development of corrective actions to ensure those actions addressed all the causal factors and evaluate the implementation of.the corrective actions. The licensee developed over 125 specific corrective actions. The team concluded that each of the causal factors was addressed in the corrective action. In addition, the team concluded that the corrective actions were properly prioritized and sampled implementation of the corrective actions concluding that the actions were be implemented properly. Corrective actions ranged from corporate governance issues and executive pay structures, policy and

procedural alignment in safety culture areas, replacing the ombudsman program with a structured employee concerns program, establishing a formal safety conscious work environment program and addressing a multitude of organizational and communication issues.

Phase 3 - Evaluating the Effectiveness of Corrective Actions at Improving Safety Cultural Recognizing the key role safety culture deficiencies played in the root cause of the head degradation event, the Panel determined that it was necessary to evaluate the effectiveness of the improvement in safety culture at the facility. Recognizing that the NRC has only broadly stated expectations in cultural areas, the approach the Panel employed was not to specifically assess organizational safety culture, but to ensure that the licensee had adequate tools to self assess in the safety culture areas, that the assessments were well performed providing meaningful insights into organizational weaknesses and that the licensee was responding to those assessment results taking actions on a continuing trend of improvement.

The Panel brought together a team of experts from Region 111, NRR, RES and contractors who were highly capable and credible in performing this type of assessment. The team utilized national and international guidance and standards as a foundation for its assessment. The team concluded that the combination of licensee internal management assessments, surveys and independent assessments provided a solid foundation for understanding organizational safety performance strengths and weaknesses. The team also found that the licensee was using their corrective action program to address safety culture deficiencies. The team noted steady improvement in overall organizational performance in this area.

Recent Results of the SC/SCWE Survey In November 2003, the licensee performed their third safety culture/safety conscious work environment survey of all staff. The results of all the surveys have been presented and discussed publically. The first survey conducted in August 2002 revealed significant cultural problems in many areas of the organization, including a significant lack of confidence in facility management's focus on safety. The March 2003 survey revealed double digit percentage improvements in many areas of the organization. The November 2003 survey showed steady or slightly improving overall organizational performance; however, several critical departments including operations, system engineering and maintenance showed declines.

The NRC inspection team performed surveys of plant staff in May 2003 following the March 2003 survey to validate the veracity of the survey technique and survey performance.

Following the November 2003 survey results, the team performed a follow-up inspection to validate the licensee's cause assessment of the declines. The team found that ini all cases, staff understood and would fulfil their responsibility for identifying safety concerns and had confidence that management would place the proper priority on addressing safety concems.

However, the team identified a less positive perspective of some staff in their confidence in management's focus on quality as compared to schedule adherence when the team contrasted the NRC interview results from May 2003 with November 2003. The team concluded that the licensee had identified the contributing factors to this decline, including excessive work hours, inadequate work scheduling resulting in schedule adherence problems, and poor communication vertically in the organization on critical management decisions. The team found that licensee management had identified and implemented short term actions to address these issues and those actions were resulting in organizational improvements.

Conclusions Overall, the all phases of the inspection including the follow up inspection revealed adequate cause assessments, sufficient corrective actions, and effective assessment techniques for measuring organizational improvement.

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Davis-Besse March and November 2003 SCISCWE Survey Department Data - FENOC and Contract Employees

t x ALL OPS Plant Maint QA Blank Engr Mar Nov Mar Nov Mar Nov Mar Nov Mar Nov Mar Nov Number of suveys 1139 780 100 77 107 75 285 167 24 23 87 14 Management cares more about safety 15.2% 17.1% 6.0% 23.4% 18.7% 24.0% 21.4% 25.0% 0.0% 21.7% 18.6% 35.7%

than cost schedule I I I Management expectations on safety and 9.9% 12.5% 9.0% 11.7% 8.8% 16.0% 12.4% 16.2% .4.3% 13.0% 9.3% 8.3%

quality are reflected In appraisals, reward and discipline - - -

Resolution of nuclear safety and quality 10.2% 9.8% 6.0% 11.0% 16.9% 16.7% 11.2% 7.8% 4.2% 23.9% 11.2% 18.5%

Issues, Including Root Cause Is effective In our organization - - -

CR issues are property proritized, 13.2% 10.9% 6.0% 15.6% 16.8% 21.3% 14.4% 9.6% 4.2% 17.4% 12.8% 21.4%

evaluated and resolved In timely manner CR process Iseffectively utilzed by DB 12.1% 11.4% 7.0% 14.3% 18.9% 18.7% 13.7% 7.2% 8.3% 26.1% 14.1% 21.4%

to resolve quality Issues In timely manner I can raise nuclear safety or quality 7.1% 6.5% 3.0% 5.2% 6.8% 12.0% 9.5% 11.4% 0.0% 0.0% 15.1% 7.1%

concern without fear of retaliation ECP will keep my Identity confidential at 6.4% 9.3% 8.0% 11.8% 3.8% 12.0% 9.1% 7.2% 0.0% 13.0% 13.1% 14.3%

my request -

I am aware of SCYVERT and Its purpose 6.2% 8.5% 4.0% 11.7% 11.2% 14.7% 6.4% 10.2% 0.0% 13.0% 8.3% 14.3%

I have been subjected to HIRD within the 8.1% 3.7% 5.0% 2.6% 8.5% 8.0% 9.5% 4.2% 0.0% 4.3% 21.2 0.0%

last 6 months I am aware of others who have been 15.3% 7.3% 8.0% 13.0% 15.1% 18.7% 22.8% 4.3% 0.0% 8.7% 28.6% 7.7%

subJected to HIRD within the last 6 months- -: * *