ML20065K796
| ML20065K796 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Davis Besse |
| Issue date: | 10/30/1980 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML082180535 | List:
|
| References | |
| FOIA-82-261 NUDOCS 8210080128 | |
| Download: ML20065K796 (15) | |
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I e, j DAVIS-BESSE Evaluation Period:.11/1/79 - 10/30/80 I.
General Reference The licensee has shown significant progress toward Inspection
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W.y?.j improving the performance in the areas of reactor Report No.
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operations and security.
The company corporate 50-346/80-17
'e-structure has been arranged to separate the Nuclear f h s $y Program from the Fossil Operation activities.
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Several meetings were held between the station per-w.:. 9 sonnel and the company president and chief operating
" !:M n officer. Staffing was significantly increased, t.
especially in the operations and I & C areas. An 6;4ib. g' l outside consultant conducted a comprehensive review b:A.B.p}
of station management, operation and maintenance procedures, engineering support and training.
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A final report was issued and the recommendations
- .:.8f%::;:@'r g implemented. Another consultant conducted a review i.::A~;dh, f
of possible methods to improve plant reliability.
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Reliability has significantly improved in 1981.
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- x.1 The training program for all plant staff, directed MU'"fMi j%[.fh toward improving the job related srkills, has been in-
. 'f plemented. The Performance Appraisal Branch Inspection rated training as good (PAS Appraisal Report 50-346/
p r:
pg)g 80-03).
bd Qil The number of LER's has decreas E considerably (1978 -
[i 127, 1979 - 134, 1980 - 94, first seven months of 1981 -
- i.. i 'm.
38).
The safety implications of these LER's has also
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..c decreased.
A special corporate investigation group has been re-viewing all LER's with special emphasis on personnel errors,and repetitive equipment problems.
Two groups of engineers previously located in the cor-j porate offices have been relocated onsite to expedite the implementation of facility changes. The system of tracking, preplanning of procurement and scheduling of a
I work has been consolidated. An experienced maintenance contractor is currently onsite to supplement the main-tenance on facility modifications activities.
Maintenance personnel have been permanently assigned Inspection to the support of Security to provide a continuous Report No.
preventive maintenance program and also a repair pro-50-346/80-17 gram of the security equipment.
Daily inspections by Note: All
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the Quality Assurance group are being conducted to other cor-improve the implementation of all security measures.
respondence s
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Numerous' visits to the site by corporate management on this were conducted,to review the dialy problems of the subjectis x
1 8210000128 820712 PDR FOIA UDE_L_LB2-261 PDR
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security personnel. A self inspection program con-exempt from ducted by the site security management is being disclosure.
conducted.
II.
Specific A.
Contention:
"The Davis-Besse facility displayed.
evidence of weakness in the arece of security and plant operations."
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1.
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Security
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During the SALP period, five inspections, Inspection P :..
including one investigation, were per -
Report No.
V: 1 formed in this area.
Twelve infractions 50-346/80-17.
and eight deficiencies were identified M.jgl.,
M in the five inspections.
In addition,
. Ap.t one deficiency was identified by the 1
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resident inspectors during an operations W}g;.b inspection.
Immediate Action Letter
- Note: All
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was issued because of security concerns other reports g
identified during the inspection of exempt fros '
g fl April 30 - May 2,1980.- During the two disclosure. -'
icpE regulatory performance meetings held
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this year (February 29 and June 4,1980),
,b y;y^x licensee corporate representatives were 3
1: jam told of our concerns with the security
- j program. Our concerns included the 1;gg licensees capability to install and
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maintain all secur.ity related equipment
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in an operable condition, availability of spare parts for security related equipment, and the morale of the site security organization.
Security super-vis, ion, both corporate and site, must.
l' be more effective.
Since the regulatory meetings, we continue to question the effectiveness of the licensee's correc-tive action.
This opinion is based on
['
the results of two security inspections (June 5-6 and September 9-12, 1980) and the one operations inspection (August 1980) in which a total of six items of security noncompliance (5 infractions and one deficiency) were identified.
As a result of January 29, 1981 management meeting the licensee forwarded a corporate level developed plan to improve security.
The six step improvement program was re-
' viewed during this inspection. The results of our inspection showed that the licensee
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. c,4 has adequately addressed the areas which were identified as causing weaknesses in the security program. The activity re-garding each of their commit;nehts is
! v.".'1, significant and the results, to'date, Mt have shown a steady, positive improve-ment in both management and equipment
- iVi si functions., Region III plans to complete
', W e two additional security inspectionvat,
. afd the fa-ility prior ts the end of 1981 to
'D monitor tha licensees continuing efforts.
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Operations '
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'(1 During the SALP peFiod, nine inspec'-c Inspection h],]l,9
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tions were performedifn this-area.
Four Report Nos.
j ig infractions and eight deficiencies were 50~346/79-29; h
identified.
None nf'tne' items involved 79-30; 80-01;
@d.h an immediate hazard to the public.
One 80-14; 80-15; M
- j infraction involved the use of anrout -
80-19; 80-23;
[.id)ip Wh dated copy of a procedure by sa control and 80-25 Md -
room operator.
One ir r'raction involved W:14, exceecing the time allowed to. change
$g. ;Q, and verify a react 6r protective system 4
setpoint when changing from t'our to ld(M infraction involved'the failure of the N
three reactor coolant pumps.
One
'b[d!
" c Corporate Nuclear Review Board to review'-
t/Q all Technical Specification violations.
$&g The fourth infraction involved out-of- ~
~ +,m.n date plant drawings. The last three infractions were identified in 1979.
The items o_f noncompliance in the opera-5 tions area do not represent a major regulatory concern, however, the Region l*
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has.been concerned aboutthe other aspects of itcensee ~ performance in,the operations l1 area. These matters were identified prior l._
4, to=the SALP appraisal period.
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Althbagh satisfactory progress has been L'
observed in most of the identified areas, continued. improvement is required in the areas of facility change requests and repetitive equipment problems.
As a direct result of concerns expressed by members of the Davis-Besse operations
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staff and NRC followup interviews, a meeting was held by Region III with plant and corporate management on February 28,
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1980, to discuss shift staffing, training of nonlicensen personnel, the ability to 3-
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l respond to emergency conditions, and the
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overall depth of the licensee's staff.
As a result of the site interviews and the management meeting, the licensee's program to upgrade the experience level of non-licensed members of the shift operating crews were confirmed by an NRC Order issued on March 5,1980. The j
licensee complied with the order.
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JD During the period of April 7,1980 through November 3, 1980, the unit was a
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shutdown for refueling, maintenance,
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and modift::ations.
During the outage the Decay Heat Removal System flow was inadvertantly interrupted a total of ten j
times. Since license amendment No. 24 l
-i was issued, which allows for the removal
.;,id of power from the Decay Heat Removal A--
isolation valves, there have been no
'{.7,$1 additional events involving the loss of W'.
Decay Heat Removal Flow.
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A large number of serious regulatory concerns existed with the Davis-Besse V~j
^ )d operation prior to the SALP period.
i$ff@d gh These concerns were such that during M96 f!<f) that time, Davis-Sesse's performance M$
in the reactor operations area was
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clearly below average'sompared with l
" 9, that of other Region III licensee's.
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Progress has been made with respect to most of the areas of concern.
- However, due to the time it has taken to resolve some of these concerns, and the lack of sufficient operating time to observe the results of the licensee's corrective actions, we do not have a meaningful basis to modify the rating for the period in question.
2.
NRC Action The licensee identified a corrective action Inspection program to resolve these concerns.
NRC Report Nos.
concerns and the licensee's ' corrective 50-346/79-08; actions were monitored in meetings with the 79-12; 79-20; licensee on April 18,1979, May 31, July 17 79-26 and 80-07.
and Spetember 19,~1979, February 29, 1980, and June 4, 1980.
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3.
Licensee Corrective Actions See discussion under Item 1, General Inspection Report No.
50-346/80-17.
lMQ B.
Contention y
l "The security area was characterized by numerous items of noncom-pliance resulting in several enforcement conferences between the.
.i p Ji NRC and licensee management.
o 6.S.l See discussion on Contention A.
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Contention L :.4.,.
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" Weakness in both corporate and site security control contributed 35'E to difficulties in the maintenance of security related equipment."
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Basis ypp.,4 MffQ Considerable downtime of the security equip-Reports exempt y.m.
due to the lack of spare parts and maintenance from public
.T.kO technicians whose priority assignment was the disclosure.
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security equipment.
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g,g) 2.
NRC Actions yM Series of management meetings.
See NRC PAS Inspection
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[' "h Actions under Contention A.
_An inspection Report No.
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.3 conducted by the' Performance Appraisal Branch 50-346/80-03.
i subsequent to the SALP period rated the security areas as average.
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3.
Licensee Corrective Action 1
(See General Discussion)
Reports exempt The corrective action for all noncompliances from public issued have been reviewed during an inspection disclosure.
conducted in June, 1981 and found to be acceptable.
D.
Contention l
l
" Performance in the area of plant operations was variable with some l
evidence of improvement near tha end of the evaluation period."
See Contention A.
E.
Contention
" Plant operations during the evaluation period were characterized by i'nstances of personnel error and failure to follow procedures, staffing problems, repetitive equipment problems and problems in
^ managing facility chancfes and. modifications."
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1.
Basis Inspection
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Report No.
Number and Nature of Licensee Event Reports 50-346/80-33.
during SALP perica:
Type of Events:
2 (a) Personnel Error 17 s
(b) Design /Manf/Constr/ Install 23 (c) External Cause 1
(d) Procedure Deficiency 16 j',..
L -.;;r (e) Component Failure 40 f
t-W (f) Other 10
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Total 107 Q,, fj Licensee Event Reports Reviewed:
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N. 9; LER No. 50-346/79-105 through 79-134 1 > - /0 LER No. 50-346/80-01 through 80-77 n;.
A
@'g Evaluation of LER's:
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.y The licensee submitted 107 LER's during the SALP period.
f& f.3 This represents an improvement over previous years (1978-127, M e'l 1979-134, and the first ten-months of 1980-78).
For the Wi$i SALP period the licensee coded the cause of 17 LER's (16%)
3MM 33 to personnel error. Two personnel errors were attributed E
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W-M to licensed personnel (both involved missed surveillance,.
hh 80-07 and 80-39).
(Mik The other fifteen personnel' error LERs involved nonlicensed
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personnel; five were TECo employees (two resulted in loss of decay heat, 80-44 and 80-60, while the other three were of lesser significance,79-126, 80-31, and 80-56), and ten were contractor personnel (three involved loss of power to safety related equipment, 80-12, 80-20, and 80-22; one involved loss
,of decay heat, 80-58; one involved loss of negative pressure boundary,.80-66; and the other five were of lesser safety.
l significance).
If contractor personnel errors could have been eliminated the number of personnel errors would have been
. comp. arable to other facilities in Region III.
The licensee's reporting requirements differ and are much more stringent than other facilities.
Evaluation of noncompliances:
See Contention A.1.b and Contention L.
2.
NRC Actions
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Series of Management meetings.
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3.
Licensee Corrective Action
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LER review group with special effort on person-Inspection nel errors and repetitive equipment problems.
Report No.
50-346/80-17.
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,,;, j Training program improved on all station personnel.
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Procedure review group to streamline procedures.
Experience
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of maintenance contractor to help with maintenance workload.
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., Q Augment staffing in the operations and I & C groups.
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..ig..gp F.
Contention
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"This (plant operations) resulted in a series of management meetings N. %.#,3 between the NRC and licensee."
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Basis m..w dif05)
The meetings were held to discuss the liccn-Inspection
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see's programs to improve the operation of Report No.
O d
the Davis-Besse Station.
50-346/80-17.
afhMf M ib 2.
NRC Actions r
ni"i*1h
- e. s Management meetings to monitor corrective actions were
%i@1Mj My) scheduled with the licensee.
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3.
Licensee Action gg
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~r See discussion under item 1, General t "
G.
Contention "Some of the problem areas identified prior to the evaluation
-periqd were.still in the process of being corrected by the licencee."
1.
Basis A large number of facility change requests Inspection were still showing considerable amounts of Report No.
work to be accomplished. The number of 50-346/80-17.
nuisance alarms had been reduced but not to the level expected.
Staffing goals were not reached, although improvements were made.
2.
NRC Action Conducted management meetings and continued in inspection coverage to follow progress,
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,3.
Licensee Actions k --
Continue management attention to the above mentioned areas.
H.
Contention
" Instances were identified where nonlicensed members of the plant staff had insufficient training."
1.
Basis Six experienced equipment operators (Non-licensed operators)
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were assigned regular shift work for training to become licensed operators.
The remaining equipment operators were trained only in certain zones. The training was adequate for routine operations but did not cover all safety related
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equipment such that they could be relied upon if needed in i
other work zones during an emergency.
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2.
NRC Actions 1[Db.
An order modifying the license was issued Inspection on March 5, 1980, which required additional Report No.
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personnel to be assigned to the day shift 50-346/80-09; l
ar.d to expedite a training schedule for 80-07.
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equipment. operators.
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3.
Licensee Action
, na sez-
.,}((,jj Returnedequipmentoperator(.'(non-licensed)toshiftwork.
Increased staff in operations department.
Accelerated the
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training for licensed and nonlicensed personnel during the plant ~ outage.
I.
Contention "The licensee program to upgrade the experience. level of non-licensed members of the shift operating crews was confirmed by an NRC order."
1.
Basis See Contention H.
2.
NRC Action Oroer issued on March 5,1980.
3.
Licensee Corrective Action See Contention H.
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J.
Contention "Although responsive to most NRC concerns, the licensee's responses to (a) IE Bulletin 80-06 (Engineered Safety Feature Reset Controls) and to; (b) Three Mile Island - Lessons Learned Category "A" Items, indichted a problem in management coordination and attention."
2.[1,'
(a)
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1.
Basis Toledo Edison's initial response indicated that prior
- gidisiii testing had been completed on safety systems which obviated J
the need for schematic review against actual wiring instal-
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lation.
Some testing had not actually been completed.
. 4Mg Overall response to the bulletin was inadequate indicating
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that Toledo Edison management review has been insufficient.
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2.
NRC Action n.za?:':
.$,hd).N Both IE and NRR requested further investigations and infor-A'8 h.,%.
p3 mation related to the bulletin to assure the intent of the
.1 original requests were understood by Toledo Edison.
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Licensee Action q y.,:.y 1
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~ Management attention resulted in further review and testing
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M; EE in compliance with the bulletin requests.
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1.
Basis l
t Toledo Edison's commitment schedule in response to NRR's September 13, 1979, and October 30, 1979, letters showed one of the worst agreements with our schedule.
Also, lack
, of detail in the licensee's submittals made it initially impossible to verify that their commitments would result in implementation of Category "A" requirements in accordance with NUREG-0578 criteria.
2.
NRC Actions Requests for additional information and an onsite review of implementation plans were held with Toledo Edison. Our evaluation stressed the need for complete implementation in accordance with NUREG-0578 criteria.
3.
Licensee Actions l.
i Adequate attention was given by management to provide sufficient manpcwer to devote to preparing implementation l
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plans in response to NRC requests.
Plant modifications y
required by Category "A" requirements were given high l
priority to assure completion withir. commitment schedule. --
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Contention "The responses were either incomplete or not comprehensive; there-fore requiring revisions or submittal of additional information."
1.
Basis Toledo Edison Company's responses are generally '.orough and directly responsive to the actions and information of the requesting letter. On the extremes are Emergency Planning upgrade responses, in which they excelled, and Lessons Learned Category "A" responses in which many deficiencies
,. p}i were identified in the initial response.
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2.
NRC Actions
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M Requests for additional information to assure the intent of
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.f.7 the original requests were understood by the licensee.
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Licensee Actions
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Time and effort expanded in providing responses has been
-4 satisfactory. Minor exceptions have occurred and sufficient
'~m.)$j manpower has been devoted to provide adequate management reviews.
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Contention i,
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" Davis-Besse received a relative.ly large number of noncompliance when M
Tsi$e compared to other facilities."
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1.
Basis Number and nature of noncompliance items Noncompliance Categories Violations 1
Infractions 18 Deficiencies 21 Sanction Areas of Honcompliance Points 56 Operations Rad. Protection 128 Security 138 Construction 0
Total Points
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322
Inspection reports covered by this review (Report Numbers) 50-346/79-29 through 79-34 50-346/80-07 through 80-26 2.
NRC Actions Management meetings.
Inspection-hours onsite was three times the national average.
One of the first groups of sites with a resident inspector, August, 1979.
3.
Licensee Actions See item under General discussion.
a M.
Contention
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"The majority of the noncompliances were in the security area."
aj See Contention A and L.
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N.
Contention i
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"The licensee also received a civil penalty as a result of an individual overexposure that occurred in April, 1090."
j 1.
Basis fj
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(g[] One radiation protection inspection was per-Inspection a formed during the refueling outage. Three Report No. items of noncomplaince, one violation and 50-346/80-12. all associated with a two infractions single overexposure event were identified and resulted in a civil penalty. 2. NRC Actions Civil Penalty issued in the amount of $13,000.00. L Licensee Actions Procedures were revised to include the following requirements: (1) A health and physics canagement repre-Inspection l sentative has to accompany personnel Report No, for entry into extremely high radiation 50-346/80-12. areas. (2) Procedure changes require that two high range survey instruments of different types be used when entering all high radiation areas. (3) A permanent locked door was installed at the location to preclude a direct path between "the incore' detector housing and the personnel doorway. l
. -...u. w ( ~- O. Contention k "A performance appraisal team inspection, completed in November, 1980 but cavering the evaluation period, revealed average and above averagu performance in several areas,especially training. The inspection revealed a significant weakness only in the area of procurement of safety-realted components." 1. Basis I.~ Executive summary for this inspection: PAS Inspection Report No. 50-346/80-03 ~. ' ' ' v*,':. A tear of seven NRC Inspection Specialiscs from the Perform-g.3 ance Appraisal Section conducted an annnounced inspection at .J-the Davis-Besse site and Toledo Edison Corporate office W.- during October 27 - November 21, 1980. Management controls kN in nine areas were inspected. A summary of results of the 7.- inspection is given below. While improvements were noted ~ Gid in most of the areas examined, a number of weaknesses were "S.T identified during the appraisal. One area was considered
- /g-y good, seven average, and one poor.
6O'9 Training - Good: The effectiveness of the training program (Q was enhanced by active management support, a number of Mj A highly motivated and qualified instructors, and continuing g9 t%y program development. Improvement was needed in the area of MJ continuing training for maintenance personnel. PE: we Committee Activities - Averao : The review committees were k' composed of capable individuals who possessed positive attitudes toward improving the adequacy and effectiveness l of facility activities. Both committees, howevtir, needed to expand their review activities, increase their respon-siveness to identified problem areas, and direct management attention to needed improvements. Quality Assurance Audits - Average: Audit findings were well researched and involved substantial safety issues. However, significant weaknesses were noted regarding audit guidance, checklists, audit followup, and certain aspects of management support for the program. Design Changes and Modifications - Averare: While there were a large backlog of Facility Change f;equests and an apparent lack of safety evaluations in the interface between l construction activities and the plant during operation, the established program appeared to have been implemented in a ~ satisfactory manner. . Maintenance - Average: Most of the maintenance personnel ( were familiar with the requirements of the maintenance L program, a.nd except for some minor instances, the program.
( ..-. w.... I l was being satisfactorily implemented. Two significant ( weaknesses were noted during the inspection. Some routine safety related maintenance activities, which were beyond the skill of the crafts, were being performed usiag unreviewed maintenance instructions. There was also an excessive backlog of outstanding maintenance work. L Review and Control of Licensed Activities - Average: The l licensee had an effective operating organization. Improve-ments were need in equipment operator staffing snd control of procedures. Weaknesses were noted in certain Control s Room operations such as the tolerance of excessive numbers E l'- of alarm indications. 'e Corrective Actions Systems - Average: The licensee had not J.'d. established a system to prioritize the different methods used to identiij deficiencies. Engineering activities had @j been redirected to reduce an existing backlog of these iden-f tified deficiencies. t ij Physical Protection - Average: Management involvement .N has been increasing to minimize the items of noncompliance, resolve equipment problems, and improve the overall effec-M tiveness of the security program. However, additional [d management attention was needed=in the areas of personnel ?? screening,' search procedures, the number of persons granted access to the vital areas, and equipment problems. ? Procurement - Poor: Numerous vi.olations of regulatory h requirements were observed in the area of material storage Wl and handling. These are detailed in the body of the report. Procurement should be recoginized as an activity in which i 1 both impacts and is affected by the full range of utility organizations: Operations, engineering, quality assurance, s quality control, administration, security and training. i Effective p ocurement is directly related to safety of operations as well as plant reliability. Eil ' There appeared to be three root causes of the nonconforming l conditions found in procurement: (1) an indifferent attitude on the part of upper management toward Quality Assurance in procurement activities, (2) the failure of middle management to control procurement actions and storeroom personnel activity, and (3) the failure to train procurement personnel i in the basics of quality assurance and ANSI standards. i As documented in previous NRC correspondence, the past regulatory and operating performance of the Davis-Besse Nuclear Power Plant has been less that desired. However, it was the Performance Appraisal Section's judgment tnat actions initiated by Toledo Edison Company since late 1979, partly in response to the inspec-tion and enforcement efforts of Region III, have been responsive ( to identified concerns and should provide for improved future performance. The. Davis-Besse site has received the best appraisal
4 of all facilities visited by the Performance Appraisal Team thus i far. These actions included a corporate reorganization which has increased emphasis on activities affecting the Davis-Besse Plant. 2. NRC Actions Management meetings - see previous items. 3. Licensee's Corrective Actions The licensee has intiated a program to improve Inspection the area of procurement which was rated " poor" Report No. during the PAS inspection. A response to the 50-346/81-03. PAS Findings was documented in TECo letter Serial No. 694, dated March 6, 1981, to the IE Director. The program cons Tats of: (1) Direct Corporate Management Attention h (a) Increase management attention ] (b) Improve training and reduce personnel error (c) fesure adequate manning 1 r 1 (2) Provide and maintain adequate storage of safety related e ?) components and materials. (a) Correct deficiencies on Class "A" storage facilities (b) Correctdeficiencies04 Class"B"storagefacilities L (c) Segregation of flammable material (d) Segregation of chlorides / caustics (e) Provide food and drink preparation area (f) Correct deficiencies on Class "C" storage facilities (3) Control the storage of safety related materials. (a) Controlled access l. (b) Provide proper parts and material identification l and legible tags i (c) Identify parts and materials with storage levels L as appropriate l (d) Procedures for shelf life control (4) Provide for handling equipment inspection and certification. (a) Inspection program (b) Certification l The licensee is currently doing a feasibility study l , for long-term improvement of the storage facilities. i
On October 22-24, 1980, the TEco QA conducted an Audit (NO. 719) of the procurement activities of the company. As a result of the audit, 23 audit finding reports were issued. The areas covered by the QA findings reflect the concerns expressed by PAS. On November 20, 1980, as a result of discussions between the QA Director and the PAS team members, a stopwork notice (80-01) was issued preventing issuance of any safety related material which had not been properly packaged and stored until the material had been inspected and the quality verified. e e e f l 1. ,I O 4 i e d 15 - ..~ -. - . m. ,.}}