ML17199T492
| ML17199T492 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/31/1987 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Roe J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8801060203 | |
| Download: ML17199T492 (5) | |
Text
DEC a 1 *198'1 MEMORANDUM FOR:
J. W. Roe, Director, DLPQ, NRR FROM:
Charles E. Norelius, Director, Division of Reactor Projects, RIII
SUBJECT:
RESPONSE AND SCHEDULE OF STAFF ACTIONS RESULTING FROM THE DIAGNOSTIC EVALUATION AT DRESDEN NUCLEAR STATION ON AUGUST 17, 1987.THROUGH AUGUST 28,.1987 As requested by V. Stello 1s November 25, 1987, memorandum, and J. Sniezek 1s December 2, 1987, memorandum, Region III is providing the enclosed written summary of the schedule and status of each item assigned to the Region.
Our schedule, as noted in the enclosure, is dependent in part, upon the licensee's response and NRR 1s res~onse.
We plan to dedicate the needed resources to complete our responsibility.in closure of the DET findings at the earliest possible date *after the licensee has completed their response.
If you should have any questions, please contact myself or Mr. M. A. Ring at 388-5602. *
Enclosure:
As stated cc w/enclosure:
V. Ste 11 o, EDO Resident Office, Dresden L. Spessard, AEOD M. Grotenhuis, LPM~NRR
'j-)
.R~~
Jon p
~)IA It.I~' I~-....,
8801060203 871231 PDR ADOCK 05000237
.PP DCD OiIGmAL SIGNED 5T C. E. KQREUUS Charles E.
Noreli~s, Director Division of Reactor Projects w
.sZ-S
~
RI I I.
~
RIII
~i£ For s
l~
Paperi e 11 o I 1!;1 ~
( iz.,\\~\\ \\~1
\\\\:; ~
1if; I
<i0
~r
\\,
Davis rij>I
RESPONSE AND
SUMMARY
OF DIAGNOSTIC EVALUATION ITEMS ASSIGNED TO REGION III PER MR. STELLO MEMORANDUM Of the nine items assigned to the Staff by the Executive Director of*
Operations, the Region shares or has responsibility for seven.
Each of these items will appear below with an evaluation or surrmary of the item, current status and schedule of resolution by the licensee and the Region.
In general, the Region agrees with the DET summaries and conclusions; however, some of the detailed statements within the DET report require clarification. These clarifications are provided.within the response to the assigned items, as follows:
- 1.
ITEM:
Dresden did not have normal resid~nt inspector coverage for a two unit site. The Senior (acting) Resident Inspector at Dresden was detailed rather than assi~ned. In addition, the SRI had been assigned duties not related to Dresden such as review of power asce~sion test results for Perry Nuclear Station. The.Resident Inspector assigned to Dresden was not certified. The situation at Dresden warrants additional resident inspector coverage beyond a normal two unit site.
ACTION:
Evaluate and take action to resolve the insufficient resident staffing at Dresden in view of the licensee's past below average performance and extensive. improvement initiatives in progress or planned.
Consideratipn should include assignment of a third resident inspector at Dresden for a 1-2 year peri9d~
RESPONSE
The assignmen*t of an Acting Senior Re~sident Inspector at Dresden resulted from a management decision to detail the SRI to the regional office pending resolution of an issue brought to management's attention.
The individual detailed as the Acting Senior Resident Inspector at Dresden was selected because of his experience and familiarity with the resident program, with BWRs and *with Dresden (He had previously been a resident inspector at Quad Cities.) The assigned Resident Inspector was actively pursuing his certification at*the time of the Diagnostic Evaluation and has since been certified.
The Acting SRI did maintain other current assignments, including the review of power_ ascension test results for Perry, Clinton and Fenni.
However, during the 270 days of the detail, only 56 regular time man-hours had been diverted from coverage of Dresden for power ascen~ion test result review.
In addition, another 200 voluntary overtime man-hours were dedicated to test result reviews, and this did not result in any diversion of coverage from Dresden.
During special ev~nts, additional inspection coverage was provided.
For example, during
- feedwater system testing, three additional SRis and six regional, resident and headquarters personnel assist~d the Dresden Resident Staff (aboOt 350 total inspector-hours). This allowed the resident staff to.
conduct nonnal site coverage inspections and for the Acting SRI to oversee testing coverage in general.
We have considered assignment of a third resident inspector at Dresden.
We have concluded that it is better to retain two residents permanently.
assigned and supplement the residents as needed by resident inspectors from other sites and by regional project and specialist inspectors.
This flexibility provides better utilization, in our view, of our limited resources.
Frequent management meetings ~ith CECo to evaluate their program and monthly internal reviews will address* the manpower require~ent.
SCHEDULE:
The issue of the Acting Senior Resident Inspector be will resolved during February 1988.
- 2.
ITEM:
This item was assigned tti NRR.
However, we wish to provide clarification to the DET statement that "the excessive use of overtime had not been recognized by Dresden management or the Region." During May 1987, the licensee and members of the Region, Divisions of Reactor Safety and Projects, discussed the impact of the CAL on operator's working hours.
The final resolution was concurred in by the Division of Licensee Performance and Quality Evaluation.
We had followed the general use of overtime, but had not addressed the issue of a large portion of the* overtime being worked by a few people, and the impact this.
may have on operations. The-Resident Staff and the licensee had main-tained observation of operator overtime up to the feedwater transient when reactive activities warranted efforts in other areas.
We would not argue that we had not been totally effective in addressing this issue.
(See Item 3) 3; ITEM:
As a result of the DET evaluation, excessive use of o~ertime by licensed reactor operators was identified as a major issue. *Short term and long term corrective actions have been implemented by the licensee including revisions to Dresden Administrative Procedure 7.1 and planned licensee negotiation with the union regarding plaht staff working hours.
ACTION:
Region III to review and evaluate licensee corrective actions to resolve the excessive overtime issue. Evaluate this issue in accordance with the NRC's Enforcement Policy.
RESPONSE
The Region concluded that the issue was a violation of the NRC's Policy on Working Hours and a Severity Level IV violation of Technical Specifications, in that Administrative Procedure OAP 7.1 was inadequate to control licensed operators' overtime.
The Region issued the violation on October 22, 1987.
The Severity Level IV was based on the Enforcement Policy, 10 CFR 2, Appendix C, Supplement I, in that the violation involved a less significant violation of a Technical Specification (Secti6n 6, Administrative) and that no significant event involving safety or threat to the health or safety of the public occurred.
The Region also reviewed the licensee's corrective actions as noted above, including the implementation of extra Nuclear Station Operators to prevent back-to-back overtime between the 2
midnight and day shifts, and found them to be satisfactory.
In addition, the Region reviewed the two event~ noted in the DET report pertaining to the November 1986 inadvertent deinerting of the drywell and the February 1987 inadvertent heatup and concluded that neither of the events were caused by excessive operator overtime. Operators on over~
time did not exceed NRC guidelines in either case.
SCHEDULE:
This item is considered to be closed.
- 5.
ITEM:
The Dresden Inservice Testing Program has not been approved by th.e NRC.
During the DET evaluation, numerous errors were found in the IST
- .Program.
ACTION:
The Region is to inspect and evaluate the licensee's ~orrective actions to resolve these deficiencies. Evaluate this issue in accordance with the NRC's Enforcement Policy.
RESPONSE
The Region conducted an inspection of Dresden's IST Program on October 5 through 9, 1987, in response to the DET concerns.
At the conclusion of the inspection, several findings were unresolved pendiMg the.final DET report. It should be noted that simil~r concerns to those raised by the DET had previously been raised by both the SSOMI in 1986 and by a Regional inspection in 1985.
SCHEDULE:* The Region expects to complete all followup efforts in late 1988. depending upon the.licensee's plan to develop a complete IST Program in mid. 1988 and implement by late 1988.
This will also depend on completion of NRR review of the IST Program.
Review of the specific items for enforcement is still in progress.
- 6.
ITEM:
This item has been assigned to NRR for evaluation.
However, based*
upon that evaluation, the Region may also be required to evaluate this issue in accordance with the NRC's Enforcement Policy.
7~
ITE~: During the DET evaluations, weaknesses were identified in several areas as described in the DET report. The potential exists for developing Dresden specific performance indicators to supplement current SALP rating areas and generic performance indicators.
ACTION:
The Region and AEOD are to develop Dresden specific performance indicators to supplement other generic performance indicators.
RESPONSE
The Region is still evaluating the four major problem areas -
communications, IST Program, maintenance and training to identify objective parameter that can be used as performance indicators.
Two specific performance indicators in the maintenance area, a half-life curve for the maintenance backlog and a percentage of rework items are currently being used by INPO on an informal bases and are being developed by Dresden.
3
SCHEDULE:
The Region will meet with AEOD staff prior to January 29, 1987, to identify perfonnance indictors that can be used at Dresden.
This program will be updated in subsequent reports.
The Region will review the two above noted indicators after the licensee has implemented them in early 1988.
- 8.
ITEM:
The DET evaluation found the maintenance and IST programs to be weak at Dresden.
The DET evaluation also concluded that the overall operator training program was weak, a~d requalification was th~ ~eakest portion of the program.
Classroom instructional practices were also weak.
Additionally, the DET evaluation detennined that *co111T1unications between management and the staff were poor.
ACTION:
The Region is to evaluate the Master Inspection Plan for Dresde~
and adjust it, as appropriate, based on the findings of the.diagnosti~
evaluation.
RESPONSE
The Region has already begun followup in~pections on issues identified by the DET.
As stated in Item 5 above, an inspection of the IST program was conducted during October 1987.
An inspection to followup on the Confinnatory Action Letter, which had been issued by Region III in March 1987, relating to the licensee's requalification program was conducted September 29 through October 1, 1987.
Licensed and non-licensed operator training was inspected November 30 through December 4, 1987.
These inspections addressed some, but not all of the concerns raised by the DET.
A maintenance inspection is scheduled for M~rch.1988.
Additional followup inspections and a program to address communication~ problems still need to be developed.
SCHEDULE:
The Region will review the licensee's response to the DET
. report and.based on that review will develop a specific plan to inspect all of the concerns noted by the DET and the 1 i censee' s corrective actions.
The Master Inspection Plan is updated quarterly and the March/April update, following the licensee's response to the DET findings, will reflect the changes.
- 9.
ITEM:
As noted in the DET report, the licensee has made. coinmitments for
- corrective action and program improvements as a result.of the diagnostic evaluation. Additionally, these actions will be confinned by the
- 1 icensee' s respo*nse to my 1 etter transmitting the DET report.
ACTION:
The Region will followup on.any licensee commitments that result from the diagnostic evaluation and my transmittal letter.
SC~EDULE: The Region will review the licensee's response, and will develope a program to follow up on licensee commitments.
This effort is expected to be implemented in Fe.bruary 1988 after the licensee has provided the response to the DET.
The Region will continue to hold monthly meetings with the utility to follow progress on these commitments.
4