ML17177A344

Discusses Functions & Purpose of Dresden Oversight Team 920324-26 Site Visit

ML17177A344
Person / Time
Site:	Dresden
Issue date:	04/02/1992
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
NUDOCS 9204080086
Download: ML17177A344 (12)

Text

Docket No. 50-237 Docket No. 50-249 Commonwealth Edison Company ATTN:

Cordell Reed

• Senior Vice President

.1400 Opus Place ~ ~uite 300 Downer~ Grove, IL 60515

Dear Mr. Reed:

APR

• 2 1992

SUBJECT:

DRESDEN OVERSIGHT TEAM SITE VISIT, MARCH 24-26, 199l As you are aware, Dresden Units 2 and 3 were placed on the NRC watch list after the January 1992 NRC senior management meeting:

This,was for a variety of reasons including* inattention* to detail in. maintenance and operations, ineffective management. control, procedural inadequacies, failure to follow procedures, training inadequaci~s in maintenance,* and* hardware reliability concerns.

As a result* of Dresden being placed on the watch list, Mr. A; Bert Davis, Region III Regi~nal Administ~ator, established an oversi9ht effort o(

Dr~sden similar to what had been done ~t Zion. The Dresden Oversight Team (DOT) was formed as a result, and-I was appointed to be the chairman. The function of the DOT is to:

1.

2.

3.

4..

Provide first-hand, periodic oversight and evaluation, from an NRC management perspective' of the progress of the licensee to imp rove performance at the Dresden Statio~.

Provide feedback to the licensee on the status of their improvement programs, including the program scope, sc~edule, and whether their efforts*

are having the intended impact.

Monitor closely the NRC inspe~tion effort

~t Dresden and provide recommendations on the need to make any changes.

Provide NRC management with a written periodic update of the status of the licensee's efforts to improve their performance. This will be in the form of a trip report issued after each routine visit to Dresden by.the DOT.

The DOT made *its first onsite visit to Dresden on March 24-26, 1992.

We conducted numerous interviews and reviewed documentation in each of the areas discussed in the attached report. Many of the DOT isiues represent impressions and viewpoints derived primarily from these interviews.

The senior licensee person contacted on this visit was Mr. D. Galle, CECo Vice-President for BWR Operations.

l'/JJ.

9204080086 920402 PDR ADOCK 05000237 P

PDR

Commonwealth Edison Company 2

APR - 2 1992 During this first onsite visit, the team focused on problem identificatiori and

• internal communications. We found that the station had i dent i fi ed many areas for

{mprovement but did not fully appreciate the root cause(s) for their performance problems or the reason(s) why Dresden was placed on the NRC watch list. We were concerned that, without addressing the fundamental problems contiibuting to poor performance, the cyclical performance of Dresden may continue.

We found many problems at Dresdeni most of which your staff was already aware, including, poor planning, lack of experience in certain areas, poor procedures, and backlog of work, to name a few.

We found that management had communicated goals and expectations for improved performance.

However, there was a wait-and-see

• attitude by the plant staff on whether any changes would be long lasting.

The team was pleaied with the level of candor in our discussions and interviews with.the plant staff. There seems to be a strong appreciation on the P.art of the*

Dresden staff for the ~eed to improve performance.

• If you have any qu~stions or comments on this report or other DOT activities, please contact me at* (708) 790-5603.

The next DOT onsite visit has been.

scheduled for May 12-14, 1992.

Attachment:

As stated

. '\\P.

Riii (j'('v\\.

Marti n/lc 4/\\ /92

. '/,AA.

NRR JVv'\\.\\t:r Barrett 4/ I /92 T. 0. Martin, Deputy Director Division of R~actor Safety

Commonwealth Edison Company DIS TRI BUT I ON:

cc w/attachment:

J. M. Taylor, EDO J. H. Sniezek, DEDR T. E. Murley, NRR C. J. Paperiello, Riii E. G. Greenman, Riii H. J. Miller, Riii C. E. Norelius,. Riii

. W. L. Axelson, Riii _

J. G. Partlow, NRR B. A.

Bog~r, NRR J. A. Zwolinski, NRR R. J. Barrett, NRR E. J. Leeds, NRR M. J. Jordan, Riii

• S. Stasek, SRJ, F~rmi D. Galle, Vice Pre~ident -

BWR Operations

• T. Kovach, Nuclear Licensing Manager C, W. Schroeder, Station Manager DCD/DCB (RIDS)

OC/LFDCB Resident Inspector, LaSalle Dresd~n, Qtiad Cities Richard Hubbard J. W; Mccaffrey, Chief, Publi.c Utilities Division Robert Newmann, Asst. Director State of Illinois Licensing Project Manager, NRR State Liaison Officet 3

REPORT ON THE FIRST VISIT OF THE DRESDEN OVERSIGHT TEAM MARCH 24-26, 1992 I.

Sco~e and Parti~ipants The Dresden Oversight Team (DOT) made its first onsite Visit to Dresden on ~arch-24-26, 1992.

The DOT primarily focused.on whether the licerisee had identified appropriate problems for correction and whether the policy and goals of licensee management were being communicated through the organization. The following DOT members participated in this visit:

T. 0. Martin, DOT Chairman

• W. L.Axelson R. Barrett E.. Leeds M. Jordan S. Stasek Byron Siegel, the NRR Project Manager for Dresden, was also on site during this p.eriod and assisted the team by reviewing licensee activities in the area of assessments/quality. programs.

Geoff Grant from the Office of the EDO observed the DOT effort.

II.

Overview and Conclusions This report identifies ~ number of ~pec~fic positive observations and concerns which will be followed in future visits.

The principle observations arid conclusions f*ollow..

Problem Identification Many of the specific problems identified by the DOT were already identified *by the licensee, and, in most cases, some sort of correcti~e action effort was in planning or instituted for their correction. The licensee was in the protess of developing detailed plans for improvement in a number of different areas. These plans should be available for DOT review during the next plant visit in May 1992..

Root Cause of the Problems Being Experienced by Dresden Th~re d~d not seem to be a clea~ understa~ding on the part of licen~ee management for why Dresden was placed on.the problem plant list. References were made, on one hand, to a "batters slump", a piling up of everits, one too inany red telephone calls, artd, on the other hand, a general lack of appreciation for quality and procedural compliance.*

• The licensee instituted a number of programs to improve their overall performance

• and track their progress, These programs should provide, at least, short term improvement.

However, the *real effects of these programs has yet to be determined.

What was missing from this process* is a root cause, or cau~es, for why their performance has deteriorated. Dresden was first put on the NRC watch list in 1987, At that time they went through a similar process of improving 1

their performance and were removed rrom the watch list in December 1988. *The DOT was concerned that the performance of the plant may once again degrade without properly addressing this, as yet undetermined, root cause(s}.

By the end of the DOT visit, it appeared that th~ licensee had a greater appreciation for the need to identify and address the fundamental reason(s) for*

their performance prbblems.

Licensee Approach to Resolution of their Problems The licensee emb~rked on a program to "improve the team, impro~e the plant, and*

improve t~e process".

As a continuance of this approa~h they were developingc a~tion plans and were tracking improvement in 11 areas:

communications; empowerment; accountability and performance appraisal; staffing; prioritization and resource management; planning, scheduling and work control; procedure upgrade; commitment management; resolution of technical issues; and backlogs.

Spe~ific action plans were in the proces~ of developm~~t to address, in detail, each one of these 11 ~reas. Without a clear understandirig of the reason(s) for their performance problems, as discussed above, this approach* seem~d to lack.

focus.

• . Commun i cat.ion of Management Goa 1 s and Expectations In the last several months, the licensee has made a concerted effort to-conv~y some positive upper level management expectations down through the organization to the lowest levels at the plant. There was a broad appreciation at the staff level for what management expectations were, however there was also a wait~and see attitude in the 1 i censee staff as to whether these 1 ong term goa 1 s would. have any lasting impact. There was also a feeling on the part of the licensee staff that, ~ith the huge backlog of work, there did not seem to be much change in how business was conducted (business* as usual) which was frequently reactive in nature (crisis management).

lII. Plant Status During the visit, Unit 2 was operating at approximately 40% p~wer due to problems with their main feed pump seals. Unit 3 remained in a refueling outage with an.

anticipated startup about 1 week away.*

Major work activities were being conducted on main feed pump seals, MSIV repair to eliminate leakage, and the emergency diesel generators.*

IV.

Management Performance In the* Fall of 1991, the Dresden Status* Review Team (DSRT) performed an assessment of the. station's performance problems.

The group identified 11 fundamenta 1 areas for improvement, which support three overall goa 1 s: imp rove the team, improve work processes, and improve the plant. These 11 ar~as are listed above, in section I I.

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The strategies developed in these areas require tangible progress in well defined areas, such as o*utage planning, procedure upgrade and resolution of equipment issues.*

In these areas, plant management and staff recognize the need for improvement, work is in progress, and there are good quantitative indicators to measLlre progre~s.

S\\:!veral other of these *areas relate to more intangible issues,. such. as communication, staff empowerment, and accountability. Acceptance of these goals

. by management and staff will clearly take time. Moreover, it will be* more difficult to define action plans to impl~ment these goals and develop indicators to track improvement. *Consequently, we expect progress in these areas to be slower.

Two positive initiatives in this area are. the CECo Vision Through Quality (VQ) program and a recently initiated program to have management.and.

staff visit other sites.

Continued management commitment will be required.in order to foster staff buy-in to these initiatives~

The plant's pro.cess for planning and evaluating these improvement initiatives was still evolving.

For instance, there were over 60 projects funded* through a specjal $12.5 million improvement budget; yet there was currently no clear statement of how these projects supported the over a 11 improvement strategies listed above.

V.

Engineering arid Technical Support Backlog and Work Planning There ~as a considerable backlog of work in the enginee~ing area.

Thi~ includes modifications, procedure changes, and re solution of equipment pro bl ems and deficiencies (DVRs).

This problem seems to be made worse by the lack of good long range work planning:_ Outage planning has not been effective at informing people when activities will be accomplished.

Daily ~ork schedules were ofteh adjusted at the last minute.

Much of the work in the tech staff area appear~ to

• be done without much prior planning (crisis management). The licensee concurred that there was a considerable backlog in many areas and that work planning was*

• not meeting its intended objectives. During f~ture visits the DOT will continue to review litensee efforts to reduce backlog and improve work planning.

(ack of Experience of Techni6al Staff Many of the personne 1 performing i.mportant system engineer functions had approximately 2 years experience. There did not seem to be a well defined career path for system engineers within the Technical Staff organization, however, many of the more experienced technical staff persons have been shifted into operator licensing traini~g. The continued movement of experienced technical staff into other areas will make it difficult for the licensee solve. their technical staff problems.

Based on a limited sample of one, it appears that the *1evel.of overtime worked by the technical staff may be excessive (in excess of 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> per year).

The licensee acknowledged the lack of experience of the technical staff.

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_Lack_ of Design Basis Information for Equipment There was a broad appreciation by all levels of technical personnel that there was a significant lack -0f readily available design basis information that m~de performing* a variety of technical acti~ities more difficult, including writing techni~al and safety evaluations, preparing maintenance instructionsi procuring replacement parts, _ performing modifications, - and making

-Operability deterrili nations.

The 1 i censee acknowledged the genera 1 1 ack of design bas is information and had several programs to address this issue including an FSAR upgrade project and a design basis document development program.

The DOT will look further into these progrlms during future visits.

Prioritization Scheme for Capital Expenditures Dresden was using a system for prioritizing capital expenditures that was consistent at all the CECO facilities.

Thi~ involved a fai~ly. complex numerical system that took into consideration a variety factors_. Line items i nvo-1 ving over

$400K were indi~iduallj approved by the CECo Board of Directors.

This system appeired to be a good means for establishing prioriti~s.

Corporate Engineering.Group Located Onsite The contribution of the onsite corporate engineering group -(ENC) was regarded by the plant as a strong positive element in assisting with modifications, resolving

- plant problems, and helping with operability determinations.

VI.

Operations and Planning Licensed Operator Staff Experienced but Limited Of the people interviewed, the -operations staff had more than 10 years experience in the operations department. - Operating crew staffing - exceeded Technfcal Specification requirements but was weak in the overall number of available 1 i censed reactor" operators and senior 1 i censed operators.

The operations departmen~ ~as prbviding licensed personal to other departments.

The licensee*

acknowledged the ~eed to continuously increase the licensed staffing for the operations department.

The use of overtime for operators will be looked at in future visits.

Communications of Management Expectations There was a large effort in communicating management expectations to the working l eve 1.

These expectations were communicated and und~rstood i _n the areas of procedure usage, repeat back of, action statements, and use of the phonic alphabet.

These were all considered to be positive initiatives.-

There was a wait-and-see attitude in the oper~tions department on whether the pressure will continue to cdndLlct this type.of communication.

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Large Backlog of P~ocedures There was a large backlog of procedure revisions and temporary procedure chang.es.

This caused some frustration with initiating* new procedure changes and thus stimulated the use of the temporary procedure changes.

See section IX, Procedu~es and Administrative Controls, for more details on procedures.

Daily and Outage Planning The planning department considered themselves the coordinating group for work effort, but the daily work schedule was not always used by the.working groups.

Comments were *made by various licensee personnel that the schedules were not

• worth the paper they were printed on and they were changed as soon as they were

• iss~ed. *The plannirig group self-identified a number of items for impro~ement and included these actions in the Dresden Management Action Plans (DMAP).. The team will be looking at these issues in the future to see if any improvements are made in this area:

Control Room Activities The control room personnel had a professional attitude in performing activities.

Operators were attentive to their panels and alarms, the control room was properly manned, and there was no major congestion around the bperator's work stations. There were approximately eight alarm lights that were continuously lit in the operating unit for various reason~.

VII.

Maintenance Goals and Expectations Maintenance department management were bringing their staff into line with their

views for process, plant, and people initiatives.

Perso~nel down to the first.

line supervisor level were well aware of management's goals and e~pectations.

. Vertical communications were taking place through departmental meetings, tailgate sessions, and one-on-one meetings.

Initiatives Affecting Maintenance Department There were an.umber of improvement initiatives recently implemented, or in the process of being implemented, that will affect the maintenance department.

Plant-wide initiatives included the p~ocedure upgrade program, the formation of vision through quality (VQ) program, and a program to improve the plant's materiel. condition.

Improvement initiatives specific to the maintenance department were too recently implemented to assess their effectiveness.

These initiatives include programmatic post-maintenance testing improvements, implementation of a reliability cent~red maintenance program which involves the review of 15 systems for determination of appropriate preventative and predictive maintenance actions, and improvement of work packages.

The maintenance department management was also planning on initiating a program to prioritize their backlog of lo~er priority maintena~ce work requests. *The DOT will look at these plans f~rther in the future.

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Maintenance Staff View of New Program Initiatives.

Maintenance staff views management as being highly reactive (overly) to NRC and INPO concerns.

New programs were viewed as reactionary and there was a walt and see attitude toward the implementation of new init:iatives.

There was no firm sense of a*cceptance or buy-in from the staff for most of management's newer initiatives.

Materiel Condition The team did not focus heavily on assessing materiel condition of the plant on this visit. The materiel condition was noted by the team to have improved over the last couple of years however the~e was still ~uch room for improvement.

Water-leaks, oil leaks on equipment, chipped, and pealing paint we~e in evidence throughout the plant. However, there was evidence that a considerable amount of

~ork wa$ accompli~hed during the past 6 months of outages on both units. During a plant tour~ without entering anY controlled surface contamination areas, Tbm Martin, Geoff Grant, and

• the Pl ant Manager pi eked up a sma 11

• amount of contamination on their shoes.. This contamination was identified by the extremely sensitive portal radiation monitors and_ was easily removed by washi_ng.

The team was informed the next day that.the licensee had identified the source of the -

contaminations.

Duri~g the cioT visit Unit 2 was being operated at reduced power, approximately 40%, due to a chronic failure problem of the seals on the reactor main feed pumps. The DOT was concerned about the licensee's appar*ent inability to properly address this long standing equipment problem.

The licensee was planning a major initiative to improve the materiel condition of the plant.* This effort had not yet been implemented and ~ill be reviewed in future DOT visits.

VIII.

Radiation Safety and Radwaste Radwaste The team examined a 11 major radwaste backlog issues, interviewed staff,. and examined process equipment. There has been extensive planning and implementation to reduce the major radwaste backlog. The NS-I project (unit one themical decon) was operational and on schedule for completion by September 1992.

The south stock bay. project (220 waste drums from the 1980s) was approximately 33%

complete, and the u~it one "old" radwaste l~ydown ~rea was al~o scheduled for cleanup.* Overall the radwaste organization appeared to work well as a team ~ith a clear understanding of their mission.

The cleanup projects were adequately staffed, budgeted, and supported by senior management. Othet radwaste progr~ms

• (sludge tank rooms and *system upgrades) were.also progressing satisfa.ctorily.

Communication between the radwaste and radiation protettion departments has also improved. The team requested the licensee to deeply examine what lessons-learned surface from these extensive radwaste reduction efforts to deal with radwaste generated from the early 1980s and to determine what "old plant habits or traditions" may need to be changed. The team stressed that radwaste disposal for 6

the 1990s is more complicated, demanding more management attention than was previously given.

Radiation Protection The tea~ examined most majdr R~diation Protection Depa~tment issues and int~r~

viewed several staff health physicists. The department appeared to be adequately.

staffed~ however, most staff had extensive workloads. The lfcens~e was planning improvements in several major areas of radiation ~rotection, including:.

Overa11 station person-~em doses were higher than management expectations, however, the trend has been positive. General plant source term reduction initiatives were scheduled to teduce the high traffic ~rea do~es. Several process* piping systems with elevated* dose rates were located in high traffic areas in the turbine ~nd reactor building.

General station radiation worker tra*ining and attitudes need improvement as evidenced by recent events.* The corporate training produttion staff.

was improving basic radiation worker lesson plans to capture lessons-learned from recent events to. help instill a responsible attitude.for radiation protection on the part of the work.er.

Overall department procedures were overly complicated and difficult to get revised.

Th_e department was work.ing with other station departments to upg!ade and improve the ~uality of these procedures.

Operational experience (SROs or Auxiliary Operators) within the radiation protection department was weak, which impacted interdepartmental interface and the technical skills available to improve overall station ALARA engineering.

The DOT will follow up on these ar~as tn future visits..

The station was embarking on a major initiative to improve the materiel condition of the plant without a* significant contribution by radiation protection personnel. *The team felt that active participation in this. program by the Radiation Protection Department would be appropriate for consideration of thin~s such as temporary shielding, housekeeping and controlled surface contamination areas, and ALARA engineering.

IX.

Procedures & Administrati~e Controls

• Over a 11 a. commitment to procedural adherence was evident in all interviews

• conducted. It appeared that management expectations in this area were adequately communicated to al~ applicable levels of the organization.

The Time to Implement a Procedure Revision was Excessive The licensee currently had a large nu~ber of outstanding procedure changes in process.

The average turnaround time to have a procedure revised was approximately 250 days and was due, in large part, to the current review and 7

approval process. *Related to this was the large number of temporary procedure

• changes that currently exist.. Hundreds of these temporary changes were in

• effect, many more than 6 months old*and some dating back to 1989.

This problem had been recognized by the licensee with* additional manpower being arranged..

During interviews, several individuals indicated that one effect of the large backlog was that personnel would rather attempt to work around a procedural problem than initiate a pr6cedure

• change. request

~nd impact an already overburdened process~

The team considered the existence of hundreds of temporary procedure changes and the excessive amount of time required to revise a proc~dure to be significant weaknesses.

Procedure Change Process The team evaluated the procedure change process to understand how procedures were revised at Dresden,.* Certain bottlenecks were identified that significantly slowed the process. Specifically, the serial manner in which reviews were done, coupled with many interim administrative loop-back steps, increased the ti_me required to issue. revisions to procedures.

In addition, the Technical Specification review and approval req~i~ements were more restrictive ~t Dr~sden than most plants, n~cessitating additi~nal reviews that may not be necessary in all cases. The licensee was preparing a Tethnical Specification chan~e request to modify these review and *approval requirements.

• The licensee was *.al so evaluating other ways of streamlinin~ the process.

Procedure Upgrade Program

• All individuals interviewed felt the Procedure Upgrade.Program was a worthwhile endeavor with the quality of the ~rocedures much impioved.

The upgrade process has taken several years to get to the.pr~sent point with a substantial amount of work remaining.

• The licensee was confident that the current schedule was realistic with future completion dates obtainable. Bottlenecks in the procedure

• revision process has had some negative effect on this effort.

In addition, a requirement for CECo to do a 100% val idat.ion of procedures in the upgrade process prior to their issuance resulted in some delays du~ to a la~~of manpower to do the validations.

The licensee discussed with the team the posibility of validating certain procedures prior to use rather than prior to issuance. This seemed like a reasonable approach, particularly for those non-operationally ori~nted procedures that were used infrequently.

The DOT wi 11 examine the ii censee' s progress in th-is area and the over a 11 quality of procedures during future visits.

X.

Licensee Assessments/Quality Program (QA/QC)

In the areas of Nuclear Quality Progra~s (NQP) and the Orisite Nuclear Safety Group (ONSG), *which are corporate functions, good communication*s were found.to exist between corporate and counterpart org~nizations at.other sites through r~gularly scheduled phone calls and meetings.

NQP also participated in audits at other sites. This was found to be beneficial.

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}

Recent NQP i~itiatives included an audit of the licensee's materiel ev~luation of the plant~ a CECo-wjde comparative audit~ and a trending program that provided input into the corporate windows program._

In addition,* NQP was. utilizing performance based audits.

ONSG initiatives included engineering safeguards performance monitoring, an integrated reporting. program that. is under develop~ent~ and a lessons learned program that has been recently implemented.

QC was conducting regularly scheduled meetings* of QC managers and h.ad a good*

working relationship with NQP.

QC was also sending inspectors to other statidns to participate in inspections and to exchange info~mation.

The initiatives undertaken in the NQP and ONSG organizations,- although relatively new and under devel6pment, were considered positive.

The DOT will review the effect of some of these inftiatives in the future.

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