ML051810307
| ML051810307 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/29/2005 |
| From: | Reynolds S NRC/RGN-III |
| To: | NRC/RGN-III |
| References | |
| IMC 0350 | |
| Download: ML051810307 (17) | |
Text
June 29, 2005 MEMORANDUM TO:
Davis-Besse Oversight Panel FROM:
Steven A. Reynolds, Chairman, Davis-Besse Oversight Panel
/RA/
SUBJECT:
MINUTES OF INTERNAL MEETING OF THE DAVIS-BESSE OVERSIGHT PANEL The implementation of the IMC 0350 process for the Davis-Besse Nuclear Power Station was announced on April 29, 2002. An internal panel meeting was held on March 24, 2005.
Attached for your information are the revised minutes from the internal meeting of the Davis-Besse Oversight Panel; status reports from the team leaders in the areas of Engineering, Corrective Actions, Safety Culture, and Operations; and the Open Action Items List. The minutes were revised to modify Agenda Item 12 and Action Item Table: Item No. 283.
Attachments: As stated cc w/att:
U. Shoop, OEDO H. Nieh, NRR/PD-III J. Caldwell, RIII M. Satorius, RIII G. Grant, RIII K. OBrien, EICS DB0350 DOCUMENT NAME: C:\\MyFiles\\Roger\\ML051810307.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII RIII RIII NAME FRamirez:dtp CLipa SReynolds DATE 06/28/05 06/28/05 06/29/05 OFFICIAL RECORD COPY
MEETING MINUTES:
Internal IMC 0350 Oversight Panel Meeting Davis-Besse Nuclear Power Station DATE:
March 24, 2005 TIME:
10:00 a.m. CST ATTENDEES:
C. Lipa C. Thomas M. Phillips W. Ruland A. Mohseni A. Garmoe J. Hopkins A. Stone J. Rutkowski G. Roach J. Jacobson R. Kuntz G. Suh G. Wright J. Robbins Agenda Items:
1.
Discuss/Approve Todays Agenda The Panel approved the agenda. THE APPROVED AGENDA REFLECTS THE ORDER LISTED IN THESE MINUTES.
2.
Discuss Plant Status and Emergent Issues C. Thomas discussed plant status. The plant is at 100 percent power and generating approximately 948 MWe. An EP drill is ongoing today in preparation for their evaluated EP exercise in May. There are no emergent issues to discuss.
3.
Discuss Communications R. Kuntz suggested the Panel look at the Comm. Matrix and determine what needs to be done to close out each item before Davis-Besse moves out of IMC 0350 and into IMC 0305.
Action Item #286:
C. Lipa and R. Kuntz will meet to determine actions that are needed to address open items in the Comm. Matrix. This Action Item is tentatively due on 4/8.
4.
Discuss Process Plan C. Lipa led an item-by-item discussion of the Process Plan. A. Garmoe will update the Process Plan to incorporate the changes.
Action Item #287:
C. Lipa will work with Roland Lickus on periodic communications with the Ottawa County Commissioners regarding Davis-Besses transition out of IMC 0350 and into IMC 0305.
2 5.
Discuss Readiness to Exit 0350 Regarding the Safety Culture/Safety Conscious Work Environment (Return to ROP) & Special Inspection Needs G. Wright discussed the status of the licensees performance in the area of safety culture and safety conscious work environment.
The licensee has completed most of the tasks in their Cycle 14 Improvement Plan, and internal and external safety culture assessments have been conducted since restart.
The assessments indicated that personal accountability for safety has remained high.
Ninety plus percent of the staff continue to respond that safety is their responsibility and that management wants them to raise safety concerns. This level of commitment is consistent with levels seen when the NRC authorized restart of the unit. The assessments also indicated that other areas have not responded to the licensees improvement efforts. For example, staff perceptions in the areas associated with trust, safety conscious work environment, employee concerns, and corrective actions have not improved and in a number of cases have declined.
A number of the areas which have not responded to the licensees corrective actions had the most positive staff responses in early 2003 with a declining trend in the November 2003 and October 2004 surveys. While improvement initiatives have not been fully effective to date, the licensees response to the October 2004 survey is marked by a more integrated approach and involvement of staff members in identifying areas for improvement and actions to improve the identified areas.
The licensee has developed appropriate initiatives to improve safety culture at the site, but they have yet to effectively implement them. At times, management does not appear to fully appreciate the importance of improving safety culture at the site. C. Thomas added that CY2004 presented many challenges to improving safety culture due to layoffs, contract negotiations, and transitional assignments. He noted that senior management has demonstrated improved performance when dealing with staff in the past few months.
G. Wright questions whether the licensee can effectively manage their own safety culture; the licensee needs to demonstrate steady or improving performance first. A followup inspection is scheduled for April 2005 and the results will be documented in IR 2005-006. Additionally, the NRC should continue to monitor the safety culture at the site when Davis-Besse returns to the Reactor Oversight Process using additional inspections. The additional inspections have been added to the deviation memo.
6.
Discuss Readiness to Exit 0350 Regarding Engineering Effectiveness (Return to ROP) &
Special Inspection Needs J. Jacobson discussed the status of the licensees performance in the area of engineering effectiveness.
The licensee is on the way to completing new qualifications for all engineers at the site.
Engineering quality at the site has shown improvement and the engineering programs are effective. Backlog reductions had been going well but were put on hold for the
3 mid-cycle outage. The engineering self-assessments are somewhat lacking in depth and scope, this is an area to monitor in the future.
The NRC needs to continue to monitor the licensees Calculation Improvement Program.
The licensee has identified calculations with unacceptable margins and is moving forward to revise those calculations. Hardware changes will be made if necessary.
The licensee is ready to return to the Reactor Oversight Process in the area of engineering. J. Jacobson will provide recommendations for future special inspections in the engineering area.
7.
Discuss Readiness to Exit 0350 Regarding Operations (Return to ROP) & Special Inspection Needs C. Thomas discussed the licensees performance in the area of operations.
Day-to-day performance by the licensee has improved. The tracking and resolution of issues has been done in a timely manner. There is still a large backlog of items but the licensee has a plan in place for backlog reduction. All actions in Initiative 2 of the licensees long-range improvement plan have been completed.
There have been no significant Operations issues since restart. Mid-cycle outage inspections went well. No leakage was found during the upper and lower head inspections or the Alloy 600 Pressurizer inspection and no outer gasket leakage was discovered during the Reactor Coolant Pump case-to-cover inspection.
The licensee is ready to return to the Reactor Oversight Process in the area of operations. C. Thomas will request the necessary deviations for special inspections.
8.
Discuss Readiness to Exit 0350 Regarding the Corrective Action Program (Return to ROP) & Special Inspection Needs J. Rutkowski discussed the licensees performance in the area of corrective actions.
The CY2004 independent assessment results showed that the Corrective Action Program was marginal. However, a return visit by the NRC discovered better performance in the implementation of the Corrective Action Program. The licensees trending has shown improvement and a plan is in place for reduction of backlogs. The most recent Problem Identification & Resolution inspection found no greater-than-green findings.
The licensee is ready to return to the Reactor Oversight Process in the area of corrective actions. J. Rutkowski and C. Thomas will request deviations for special inspections to monitor CY2005 Order required Independent Assessment.
4 9.
Discuss Text of Transition Letter to Licensee and Deviation Letter to EDO C. Lipa discussed the status of the deviation letter and the transition letter. For the deviation letter, we need to determine which column of the Action Matrix Davis-Besse should return to, and what additional inspections are needed based on the requirements of the column. The transition letter is in draft.
10.
Discuss New/Potential Licensing Issues (Standing Item)
J. Hopkins is continuing discussions with the licensee regarding their November 2004 submittal of corrected information in response to Generic Letter 95-07. Also, NRR sent a letter to the licensee notifying them that we accept their withdrawal of a request for extended power uprate.
11.
Discuss Action Items, Including Methodology to Solicit NRC Staff for Comments or Concerns on Exit from 0350 (Standing Item)
The Panel discussed the open Action Items.
Action Item #266:
on hold Action Item #269:
closed at a previous meeting Action Item #282:
closed at this meeting Action Item #283:
ongoing Action Item #284:
ongoing Action Item #285:
letter will go out soon, item can be closed once that happens 12.
Discuss Enforcement Actions M. Phillips briefed the Panel on enforcement actions regarding the Davis-Besse head issue. The Panel discussed the different options for Enforcement Actions and decided l
that the NRC should develop the necessary documentation for Enforcement Action and l
move forward on the violations.
l 13.
Discuss/Update Timeline and Milestones and Commitments Undine Shoop will be attending the Perry End-of-Cycle meeting as well as traveling to Davis-Besse the following day AARM meeting May 4, Commission AARM Meeting May 25 PI & R inspection in August 2005 next public meeting date TBD 14.
Topics for Upcoming Panels The next Panel meeting will tentatively be the week of April 11.
12:05 p.m. CST: Meeting adjourned.
5 Status of Davis-Besse Performance in the Area of Engineering in Consideration of Readiness to Transition From 0350 Oversight to the Reactor Oversight Process During 2004, the Permanent Plant Modifications and 50.59, Triennial Fire Protection, Biennial Heat Sink, and TI 2515/159 (Service Water System Problems Affecting Safety Related Equipment) inspections were conducted. In addition, a senior engineering inspector reviewed the quality of engineering activities, including progress on the licensees Performance Improvement Initiatives and backlog reduction, throughout the cycle.
Engineering product quality as measured by the licensees Engineering Assessment Board (EAB) has shown an improving trend with performance goals met. Completion of the licensees Improvement Initiatives has generally been effective and completed as scheduled with some exceptions. Most notably, backlog reduction continues albeit at a slower pace than anticipated.
Also, preparations for the next refuel outage, electrical coordination improvements, masonry block wall analysis, and service water margin improvement initiatives are progressing but are behind schedule.
The Order-required independent assessment of Engineering was conducted during the fourth quarter. The independent assessment team did not identify any discrepancies that were considered significant in terms of the validity of the work product, or indicative of a systematic deficiency in engineering work performance or management. The Assessment Team identified a number of areas where changes could be made to enhance Engineering performance with a focus on management efficiency.
In summary, no significant issues associated with Engineering performance were identified by NRC or the independent assessment team. Considerable progress has been made with respect to engineering product quality and the significant engineering backlog has been steadily reduced. Based on the performance of Engineering since the plant was restarted in March of 2004, the licensee is performing at a level which could be adequately monitored under the Reactor Oversight Program.
Recommendation: additional inspection requirements would be warranted associated with the review of the Confirmatory Order required self assessment.
6 Status of Davis-Besse Performance in the Area of Operations in Consideration of Readiness to Transition From 0350 Oversight to the Reactor Oversight Process The Operations Lead Inspector and the Davis-Besse resident staff have assessed the current performance of the Davis-Besse Operations Department using the 0350 Panels approved exit criteria as the basis for their evaluation:
1.
Demonstrate Safe Plant Operation and Overall Improving Performance Based on resident inspector observations, the Operations Department appears to understand that they are the lead organization on site and are acting accordingly.
This has not always been the case at Davis-Besse and the support organizations are still adjusting to this new dynamic.
The day to day performance of the Shift Managers has improved. This has been demonstrated by improved enforcement of standards and expectations in the control room, their active participation in the risk classification of work activities, establishment of contingencies for risk significant activities, and their participation in the scheduling of daily work activities.
The Operations Department has typically been the driving force in involving other site departments in the resolution of emergent equipment issues.
The Operations Department has been identifying, tracking, and resolving in a timely manner, safety significant control room deficiencies, operator workarounds, and temporary modifications. The Operations Department Management, including the Plant Manager, actively supported resolving these issues.
The movement of key Senior Reactor Operators to the training department has significantly strengthened Operations Department training. One notable result has been the improvement in quality of several of the integrated plant operational procedures.
The Operators have generally prepared for and executed high profiled evolutions in a safe and conservative manner. They continue to be challenged periodically with operator errors during more routine evolutions. The licensee has corrective actions in place to address these errors, and these errors are occurring on a less frequent basis.
Although the Operations Department is still challenged with a relatively large backlog of corrective action items, they do have a plan to address the backlog, and the number of backlog items has decreased since restart.
Through the daily observation of the Operations department staff, the resident inspectors have not observed any behaviors that would be associated with a significant Safety Culture/SCWE concern at Davis-Besse.
7 2.
Implement an Effective Long Range Improvement Plan To ensure continued improvements and sustained performance in the areas of Nuclear Safety and Plant Operation, the licensee developed and has begun to implement the Davis-Besse Nuclear Power Station Operational Improvement Plan for Operating Cycle 14. Initiative 2 of this plan covers Operations Improvement and contains six specific Actions, which are comprised of eleven sub-actions. As of January 2005, the licensee had completed all Actions associated with Initiative 2. The inspectors have evaluated several corrective actions associated with Initiative 2 and determined them to be adequate.
The inspectors have continued to assess the performance of the licensee in implementing all ten of the Improvement Initiatives which are outlined in the licensees Operational Improvement Plan.
Since restart, there have been no issues associated with the performance of the Operations Department with greater than very low safety significance.
There have been no significant Operational cross-cutting issues.
3.
Compliance With the Requirements of the March 8, 2004, Confirmatory Order No significant issues were identified during the performance of the first Davis-Besse Independent Operations Assessment (August 16, 2004, to August 25, 2004). The NRC inspectors determined that the Teams assessment activities were of sufficient depth and scope and that the licensee had developed appropriate Action Plans to address identified Areas for Improvement.
No reactor coolant leakage was discovered during the visual examination of the reactor pressure vessel upper head bare metal surface, including the head-to-penetration interfaces; the reactor pressure vessel lower head bare metal surface, including the head-to-penetration interfaces; and the control rod drive mechanism flanges.
4.
Confirmation of No Reactor Coolant Pressure Boundary Leakage During the Mid-Cycle Outage In addition to the Order required inspections of the upper and lower reactor vessel head nozzles, the licensee completed an inspection for NRC Bulletin 2004-01, associated with pressurizer penetrations. No reactor coolant pressure boundary leakage was identified during these inspections.
The inspectors did not identify any active case to cover joint leakage for reactor coolant pumps 2-1 and 2-2 that would be indicative of case to cover outer gasket leakage.
Based on the performance of the Operations Department since the plant was restarted in March of 2004, the Davis-Besse resident staff has determined that the licensee is performing at a level which could be adequately monitored under the Reactor Oversight Program.
8 Recommendation: Additional inspection requirements would be warranted associated with the review of the Confirmatory Order required assessment inspections.
9 Status of Davis-Besse Performance in the Area of Corrective Actions in Consideration of Readiness to Transition From 0350 Oversight to the Reactor Oversight Process The Davis-Besse resident staff, in conjunction with the assigned NRC Lead for the Corrective Action Program, have assessed the current performance and status of the Davis-Besse Corrective Action Program, using the 0350 Panels approved exit criteria as the basis for their evaluation:
1.
Davis-Besse established and is implementing an effective long-range improvement program.
Based on resident inspector observations and the results from a PI&R inspection (IR2004017), completed in December 2004, the Davis-Besse organizations implementation of the corrective action program is safe for continued operation of the plant.
The licensee has made commitments intended to improve the long range quality of the corrective action program. As documented in the PI&R report, the commitments, reported to be closed by the licensee, and sampled by the inspectors, had been properly implemented.
The PI&R report documented that past weaknesses in the corrective action trending program had begun to show improvement.
While the PI&R report did identify some violations of regulatory requirements, none of the inspection findings were classified as greater than green.
The licensee, on a weekly basis, reviews the status of backlogged work items including the number of open condition reports and open corrective actions.
From September 1, 2004, to March 15, 2005, the number of open conditions reports has been reduced from approximately 1950 to 960. The number of open corrective actions has been reduced, during the same time period, from approximately 4590 to 3070.
Based on resident review of the progress in reducing the number of open corrective action condition reports and open corrective actions, and the review of status, the backlog reduction plan appears reasonable.
2.
Demonstrated safe plant operation and overall improving performance.
The licensee had no specific commitments for Criterion 2 that specifically addressed the implementation and performance of the corrective action program.
However, as identified in the PI&R report, overall the licensee was effective in identifying problems and characterizing them in the corrective action program.
There were no greater than green findings or issues or NRC performance indicators related to the failure of corrective actions intended to address the causes of the extended outage.
10 3.
Compliance with Confirmatory Order and effective self-assessment program.
The licensee conducted its first Independent Assessment of Corrective Action Program during the time period of September 12 to October 1, 2004. The report was submitted to the NRC by letter dated November 15, 2004. NRC review, as documented in the PI&R report, concluded that the assessment activities were of sufficient depth and scope, were adequately documented, and that the licensee had complied with the requirements of the March 8, 2004, Confirmatory Order.
No significant issues were identified during the performance of the first Davis-Besse Independent Assessment of Corrective Action Program. The NRC inspectors determined that the Teams assessment activities were of sufficient depth and scope and that the licencee had developed appropriate Action Plans to address identified Areas For Improvement.
As stated in the PI&R report, areas for improvements, identified in the Independent Assessment of the Corrective Action Program, were captured in condition reports and were generally timely.
The PI&R team reviewed the Nuclear Quality Assurance Audit Report issued on November 14, 2004, which rated the corrective action evaluation area. The inspectors noted that the assessment was consistent with that of the NRC and other organizations that have reviewed Davis-Besses corrective action program.
4.
Confirmation of no reactor coolant pressure boundary leakage during the mid-cycle outage.
The licensee had no specific commitments for Criterion 4 that specifically addressed the implementation and performance of the corrective action program.
5.
Adequate controls in place to prevent the issues that led to the significant degradation in the reactor vessel head.
The NRC previously determined that improvements in the corrective action program were sufficient to resolve various issues contained in the Davis-Besse restart checklist and restart action matrix and were sufficient to lift restriction on Davis-Besse restart.
The PI&R inspection team concluded, in December 2004, that the implementation of the licensees corrective action program was safe for continued operation of the plant.
The PI&R inspection team concluded that the licensee was effective in identifying and characterizing problems and that, in most cases, identified issues were appropriately evaluated and prioritized. Additionally the inspectors concluded that the threshold for entering issues into the program was appropriate.
Inspectors determined that the licensees audits and assessments of the corrective action program were of appropriate depth and scope and that
11 findings and recommendations were appropriately captured.
Based on the performance of the Davis-Besse staff in implementing the corrective action program since the plant was restarted in March 2004, the Davis-Besse resident staff has determined that the licensee is implementing the program at a level which could be adequately monitored under the Reactor Oversight Program.
Recommendation: Additional inspection requirements would be warranted associated with the review of the Confirmatory Order required annual self assessments of the corrective action program.
12 Status of the Davis-Besse Performance in the Area of Safety Culture in Consideration of Readiness to Transition From 0350 Oversight to the Reactor Oversight Program The Management & Human Performance (M&HP) Lead Inspector along with members of the M&HP Team have assessed the current status of management & human performance using the 0350 Panels approved exit criteria as the basis for their evaluation.
1.
Demonstrate Overall Improving Performance in Safety Culture (SC) and Safety Conscious Work Environment (SCWE).
After an initial improvement between mid 2002 and March 2003, SC/SCWE survey results in November 2003 and October 2004, exhibited declines in positive responses by staff and supervisors, in key organizations, to a number of survey questions.
The 2004 survey results declined sufficiently to cause three of the four SCWE pillars to become Yellow, by the licensees definitions.
Following the less positive results from key organizations in November 2003, the M&HP team noted that the licensee had taken actions to improve staff/supervisory perceptions. While the actions were appropriate, implementation was not sufficiently thorough to appropriately address a number of significant issues, e.g., FW 780 valve, FENOC reorganization, I&C tech.
Through survey results and interviews, the staff raised a number of issues as examples of senior management not performing appropriately and not taking responsibility for their actions.
2.
Implement an Effective Long Range Improvement Plan.
The licensee has developed an Action Plan based on the results from the external assessment and two internal survey/assessments.
While not being able to make a positive statement regarding the effectiveness of the long range plan, the M&HP Team did note that it contained a number of activities which should improve the staffs perceptions of management if implemented thoroughly.
3.
Compliance with the Requirements of the March 8, 2004, Confirmatory Order.
The Davis-Besse independent Safety Culture/Safety Conscious Work Environment assessment was conducted as planned. The assessment concluded that no improvement in the safety culture or safety conscious work environment had taken place since the first quarter 2003. Further, declines in the staffs perceptions in various areas were identified. The results from the indepe ndent assess ment were
13 consist ent with the results of the license es Nuclea r
Oversi ght assess ment and the Emplo yee Concer n
Progra ms survey.
In reviewing the three assessments, the M&HP team concluded that the activities were of sufficient depth and scope to properly evaluate SC/SCWE and that the licensee had developed an Action Plan to address identified Areas for Improvement.
Recommendation: The M&HP team recommends that an abbreviated inspection be conducted at the facility to gain better insights into the licensees Action Plan. The team also recommends that staff interviews, as previously recommended, not be conducted at this time. The interviews should be conducted after the elements of the Action Plan have had time to take affect. The staff interviews should be conducted in late August or in September.
DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST - Current as of 3/24/05 Mtg.
Item No.
Action Item (Date generated)
Assigned to Comments Due Date 266 Draft memorandum from the Panel to NRR addressing the Lessons Learned to be considered for the next revision to IMC 0350 based on the entire 0350 process and transition back to ROP.
(4/13)
Lipa/Suh 4/13 - Discussed, comments should be forwarded to C. Lipa/
A. Mendiola; 4/27 - Discussed, need to base on specific line items from the Process Plan. 10/14 -
Discussed, comments provided to D. Passehl for incorporation into memo. 11/10 - Discussed. 1/6 -
Letter with Caldwell for issuance.
2/25 - The panel decided to hold this item open, and modify it to address lessons learned throughout the 0350 process, including the process to transition back to the ROP.
one month after DB placed in ROP program.
283 Establish a plan (to discuss at Jan. 6 Panel) for addressing GL 95-07 since the document will go public in ADAMS.
Lipa/
Hopkins Due to unavailability, postponed to 02/25/05 panel meeting. 2/25 -
The licensees response to GL 95-07 is acceptable; however, it contained a potential 50.9 violation. Mr. Hopkins will provide a feeder to C. Thomas for the next inspection report discussing the issue in detail and dispositioning it l
in accordance with the l
Enforcement Policy. In addition, l
C. Thomas will review the related Condition Report for the item.
3/24 - J. Hopkins has requested information from the licensee and is awaiting a response.
04/25/05 284 Set up OCA briefing after mid-cycle outage.
Ruland 2/25 - W. Ruland will arrange for this to occur despite being on rotation away from panel.
3/24 - W. Ruland will send summary e-mail to OCA.
03/20/05 285 Write letter to Riccio, Lochbaum, et. al. to take them off standard distribution list.
Hopkins 03/19/05 286 Look through the Comm.
Matrix and determine the actions to be taken on all open items before Davis-Besse is removed from 0350.
Lipa/Kuntz 4/8/05
DAVIS-BESSE OVERSIGHT PANEL OPEN ACTION ITEM LIST - Current as of 3/24/05 Mtg.
Item No.
Action Item (Date generated)
Assigned to Comments Due Date 287 Work with Roland Lickus on periodic communications with the Ottawa County Commissioners regarding Davis-Besses transition out of 0350.
Lipa