ML20106F383

Forwards Current Status of Maint Area Comprehensive Corrective Action Program Per Insp Rept 50-346/83-01. Performance Enhancement Program Updated on 840427,per Insp Rept 50-346/84-04 Request for Info

ML20106F383
Person / Time
Site:	Davis Besse
Issue date:	07/18/1984
From:	Crouse R TOLEDO EDISON CO.
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1-448, NUDOCS 8410300220
Download: ML20106F383 (11)

Text

-

S pgg L

s-m.

). 1, J'

3

\\

44 w

.1 & 8

{

?'

Docket,Nes -346 yotsoo EDISON

.' License'No, NPF-3 S ial No 1-44'8'A

• ~

3 -.

Vce Pmse w

July.13, 1984

'4e m 25 N'-

_i i

'/ o*)

j,t f

, \\I

~ i

.,Yt;[

V Mr. C. Norelius, Director g, j,i - {Divigion of Engineering & Technical Programs i

4 United States Nuclear Regulatory Commission 7,

jg

- pp,,4,d Region III

['I d

i 9 99 Roosevelt Road ?

' ~ ' -

' Glen Ellyn. Illinoi's 60137

!b, 4g t

u

}-

Dear hr. Noreliur:

p s

This letter,is to' provide y,ou with the current status of Toledo Edison's comprehens17e, corrective, action program in the maintenance area. This (q.

4 program rewated fr6m items of nn-compliance identified in Inspection

~

.iReport 30-346/8320 f(Log No. 1-74'7),

t'

'y g

pi

' Additionally, fin your April 18, lW4 Inspection Report 50-346/84-04 (Log M'

no.' 1,-9Ii7)dyou requested Toledo Edison describe the interim measures we hive,taketkor plan to take to improve our maintenance program. Subsequent

~

g

' to bsdithe' of Inspection Report 84-04, Toledo Edison presented, on April

+

D '. '

27',i vidl, an update of the. Performance Enhancement Program which included' l'h the 9.iterim; measures iieingtaken to improve our maintenance program.

y '-

11

*v The attachment provides additional infiraation'on the actions Toledo Edison is taking to improve the u.aintenance are'a. ;

4

\\

1; i

k e'

1 Very truly yours, 9 3 g

j}

I tj, f

"ai E, P C- /m,

'y a

~

~~

.Y. W

/

~ RPC:JAT:nif -

i.

l*

! encl.

,~\\

'5 v.

DB-l'NRC Resident Inspector *\\a b i

cc

i w

i l'

l 3

et 1,

i E

. 4;.

ly 3

8450300220 840718 4[ $

• g\\,.Sg $M i

PDR ADOCK 05000346

'g

}

{

G PDR 3.q s

'.ps s

p b

b h

y

\\*

i I

g v,

THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISOi4 AVENUE

• TCLEDO. OHIO 43652 th

\\

i 9/

4

(

/

4 3

?

Tso/

jf *

~

4

-..s h --

. i=

-v2

p -

7-M. -.i. ; Dock 1t NN.'50-346 r

. Licanta No. NPF ' Serial No. 1-448

. July'18, 1984 Page 1i g

i In'the area of maintenance control,-TED originally identified seventeen

.(17) areas of improvement- (action plans) to the NRC in our comprehensive

' ecorrective action plan. These items were detailed in our letter of

' April 129, 1983.(Serial 1-352) and updated on January 23, 1984 (Serial ~1-400).

.In October.1983, the' Assistant Station Superintendent - Outage Management assumed the. responsibility of the Maintenance Engineer on an interim

-basis.. The Assistant Station Superintendent had six years experience as

' Maintenance Engineer prior to his five' years as Assistant Station Super-

~

-intendent.with responsibilities for Maintenance and other sections. With the. change-in personnel. the actions for improving performance were expanded 'in scope to include those activities addressed in our letter of (April 29, 1983. These actions included efforts to identify and resolve underlying root cause issues contributing to the identified problems in the maintenance area.

The number of areas were initially limited to ensure effective utilization of the available resources to-the timely. improvement of quality of the maintenance area. Areas identified for improvement of productivity and cost effectiveness were' deferred until significant improvement in main-

tenance quality has.been achieved or initiated. Twelve areas were iden-tified for initial efforts for. improvements and has been increased to thirteen with the addition of an action plan on. Materials Planning and Coordination.

We recognized a need to improve; communications. This has been one of our biggest areas of emphasis'and encompassed many-things. A clearly defined

~ philosophy has been developed and is being communicated throughout the-department'from the Maintenance Engineer. This~ philosophy emphasizes 1 quality and the following. action plans are designed to assist in attaining

-that. goal.

~

I.

ORGANIZATIONAL REVIEW The Maintenance Engineer has reassigned several reporting relation-

' ships' involving staff and contractors to relieve himself of direct-involvement in specific activities which~have been delegated to other maintenance. personnel.

In conjunction with the revised reporting relationships, routine administrative responsibilities Lhave been delegated to personnel reporting directly to the Main-

'tenance. Engineer.. Meetings were held with the Lead Engineers and

~. Supervisors to discuss topics such as individual plans for the) future, performance strengths'of subordinates, department strengths and weaknesses, problems and expectations from their supervisor.

~

.The results'of theLorganizational: review and assessment identified a mismatch of individualeresponsibility and workload assignment.

5

m Dock 2t No. 50-346 Licin:s Ns. NPF-3 Serial No. 1-448 July 18, 1984 Page 2 Actions taken to corect this mismatch included:

1.. A reorganization which resulted in the Maintenance Supervisors responsibility for shop foremen and work forces reporting directly to the Maintenance Engineer. This provides a more direct communication path and relieves the Lead Engineers from the responsibility for utilization and productivity of shop person-nel, disciplinary responsibilities, etc.

2.

Eleven additional staff personnel have been added to the Maintenance Management Team. These plus 4 additional staff positions which remain to be filled with increase the maintenance technical and administrative staff significantly.

In addition, 2 permanent positions have been authoized in our outage management organi-zation. These positions will'eleviate the need to temporarily reassign full time maintenance personnel to do outage planning.

This allows for reduction of the individual's workloads which has resulted in reduced overtime and individual stress levels.

It also provides additional opprotunity for staff training.

3.

Efforts are continuing to fill the Lead Electrical dna Lead I&C Engineer positions.

Effective July 1, 1984 our Outage Manage-ment Supervisor was promoted to fill the Maintenance Engineer position. Due to the close working relationship between Outage Management and Maintenance in preparation for and execution of our 1984 Refueling Outage, a gradual transition is planned in the Maintenance Engineer position. The new engineer will assume full Maintenance Engineer responsibilities at 'the end of the refueling outage.

4.

Administrative responsibilities for Facility Change Requests have been reassigned to the Facility Modifications Department.

This further reduces the workload on the Maintenance Engineering Technical staff.

5.

Responsibility for managing and administering contracted labor efforts have been reassigned to the Facility Modification Department. This reduces the administrative and supervisory workload of the Maintenance Supervisors and Maintenance Foreman.

Additional organizational changes and responsibility assignments may result from the implementation of the MB0 Program and further assessments of the Maintenance Section's functions.

II.

MANAGEMENT BY OBJECTIVES (MBO) PROGRAM The effort to implement an MBO Program at the Section Head level has been underway since early 1983.

The Acting Maintenance Engineer has been involved as Assistant Station Superintendent in the Section

.= _~. -

4 Dockst No. 50-346i Lic n;2 No..NPF-3 l Serial-No. 1-448

[

" July 18,21984 JAttachment 1 "Page 3-Head MBO effort, and is proceeding with implementation of the MBO

' Program in the Maintenance Section.

After January 1, 1984, some MBO sessions were held with the three

. shop ' supervisors together and the lead engineers together. This enabled each of them to draw on the experiences of the others and

'also improved MBO process time. The Lead Maintenance Support

- Engineer has held initial group meetings to begin MBO implementation with his staff.

The Maintenance Engineer had initial kickoff meetings during early April'with the Mechanical, I&C and Electrical. staffs and the kickoff meeting for all Foremen was held on May 22.

Kickoff meetings are scheduled in July with all shop and maintenance staff personnel.

These initial sessions will be full one-day meetings held away from the work site. They will be made up of groups of 15-20 from the same shops, so common goals and objectives can be initiated.-

4 These sessions are designed to acquaint everyone with the MB0 process and to establish a base' from which a comprehensive program can be implemented. The Maintenance. Planning Supervisor has begun MBO with the Maintenance Planning Staff. Sessions were held on

' June 13th, 18th, and the 25th. Additional dates will be scheduled in order to complete MBO for the entire group.

Results of MBO efforts to date indicate an improved understanding of job responsibilities and their relationship to achieving acceptable performance..The process assures that all responsibilities neces-

-sary for quality maintenance are assigned and fulfilled. The process clarified many misconceptions about job responsibilities and performance standards and it also identified areas for which it was felt there was no. responsibility or accountability.

C III. MAJOR REVISION OF AD 1844.00, MAINTENANCE AD_1844.00 - Revision 11 was approved and initial training com-

.pleted by April 1, 1984.- Chua make up session was held later in April for those people who were unable to attend the initial

- training. Response from those attending training was positive and

~

several constructive comments were received.

~ This procedura describes the controls for the administration of the Davis-Besse Station Maintenance Program. Since initial development, there have been changes in the systems used for control of the programs such as the Davis-Besee Maintenance Management System (DBMMS) and' changes in other tivities which affect the maintenance

- program, such as Facility Cha. ;e Request (FCR) control - AD 1845.00, records management, procurement, materials conts 1, etc.

A thorough

. analysis ~of the maintenance program and how it relates to the d

ei"

+ e

-rW'

,-e--

3-e e-e---

-- r mse w -

e erv v 9.-e m er'rt'e-b-&w +- y e w

'e-r

+g---+-g--~pw'Mrp+e

-v-pg Y~w-*

e*,p<w-S

• 7

-e-3q--

v-

s

- Dockst N2. 50-346-

- LicInsa'No. NPF - Serial No._1-448 July-18, 1984:

_Page'4

~

support activities and functions from other sections in the Station

and Departments in the Company, was completed to assure that the revision ~to AD 1844.00 properly identified the interfaces with the other Departments and administrative control procedures to insure an effective maintenance administrative procedure.

JAnother revision to this procedure to incorporate refinements should be approved in the next few weeks.

' IV.-

DAVIS-BESSE MAINTENANCE MANAGEMENT SYSTEM (DBMMS) IMPLEMENTATION This has been and continues to be another major effort, very similar to item III. It has many interfaces and requires significant analysis to assure effective implementation and utilization of the DBMMS system as a tool for not only Maintenance but the Station.

Designated personnel and an action plan are required.

The DBMMS has been essentially implemented, and it is reasonable to assume that an assessment of its adequacy-can be performed at the end of 1984. _ During 1984, considerable effort will be expended in debugging the system, training and data collection. A number of potential system enhancements have been identified at this time.

These and other enhancements must be evaluated and a determination made as to their benefit.

V.

DEFINITION OF THE ROLE OF THE MAINTENANCE PLANNING GROUP This effort is being addressed basically thru the MBO process, and will further evolve with the completion of action Items III and IV.

There have been several clarifications already developed as a result

-of the organizational review and-these_ clarifications are being established and disseminated early in the MBO process. The roles and functions of the Maintenance Planning Group fall into two major areas: 1) very closely related to DBhMS; I) the other relating more closely.to effective maintenance planning versus the scheduling and control process of DBMMS. The planning function has already been expanded to include Materials Planning and coordination and will be

~ '

further defined relative to the. coordination of maintenance planning for outage and non-outage work.

'Now that MBO has been completed with'the Maintenance Planning Supervisor, he will be developing various action plans to define and refine the role of the Maintenance Planning Group.

Meetings are being held with Maintenance Section_and other personnel to more. clearly define the role of the Maintenance Planning Group.

The role of the group is now changing from the major effort of DBMMS

=

Dockat N2. 50-346 Licanre No.- NPF-3 Serial No. 1-448 July 18, 1984

. Attachment-1 Page 5 development to facilitators in the use of DBMMS and an expanded role in maintenance planning and scheduling.

~VI.

EVALUATE AND CORRECT DEFICIENCIES IN QUALITY CIRCLES With the concurrence of the Quality Circles (QC) Steering Committee, the Maintenance Engineer has met with the Quality Circles Team and has initiated a more timely response to QC presentations.

January 11, 1984 QC recommendations were formally responded to at the January 19, 1984 QC meeting. At this meeting, the Maintenance Engineer also initiated greater QC member involvement and partici-pation in follow up for resolution and implementation of the QC recommendations.

Initial response by the QC members indicates these two actions will be a major factor in correcting observed weaknesses in the program.

As a result of the last meeting the QC Steering Committee has reviewed all previous proposals to assure that all formal QC recommendations have been responded to.

Results of a survey of Quality Circle members indicated that the major factor affecting Quality Circle performance was untimely response to Quality Circle recommendations. Most recent involvement of the Maintenance Engineer who has initiated greater quality circle involvement in implementation of their recommendations has improved the morale in the existing Quality Circle. The Quality Circle Steering Committee is planning training for establishing additional Quality Circles. The Quality Circle Program is presently progressing very well and, we anticipate expanding the Quality Circle Program to include new circles. We are planning to conduct orientation sessions and leader selections for the prospective circles in August. Activities will be suspended during the fall months due to the 1984 Refueling Outage. Leader training, member training and meetings will resume in January, 1985.

VII.

EVALUATE THE PREVENTIVE MAINTENANCE PROGRAM Evaluation of the Preventive Maintenance Program has been factored into the MBO Program.

It involves identifying the responsibilities for the Preventive Maintenance Program in the functions of the various individuals in Maintenance. It also ties intc the imple-mentation of DBMMS because part of the program includes the schedu-ling of preventive maintenance, generation of work orders, etc.

The desire has been to make the Preventive Maintenance Program part of the overall maintenance program and include the responsibilities for assessment and analysis of preventive maintenance activities and the responsibilities for the various system cognizant individuals. We also will define the responsibilities for periodic review of the

lU-

[Dockst Ns. 50-346'

_ nLicinna No. NPF-3:

' Serial No. 1-448-July.18,.1984' cAttachment 1

'Page 6'

< nature and scope of the individual preventive maintenance work order activities.- The spare parts and materials considerations for

. preventive maintenance work will be' included in the program.

.A' meeting was' held on December 9, 1983 to evaluate the objectives of our. Preventive Maintenance Program. At'this meeting it was' agreed

to. change _the method of scheduling. Preventive Maintenance work. The criteria'for this method were discussed at varicus Maintenance Staff meetings. Special emphasis.was given to determining:

1) criteria

-to-convert to the' combination method;'and 2) potential problem analysis during the conversion process.

The first' phase of.the evaluation of the Preventive Maintenance Program has been completed. The review and conversion of some

. preventive maintenance to fixed interval scheduling has reduced the backlog of. incomplete preventive maintenance work-orders and has eliminated an unnecessary administrative burden generated when all preventive maintenance was scheduled on a fixed anniversary basis.

Another benefit of the review was the elimination of over 100 Lunnecessary activities from the-Preventive Maintenance Program.

JAdditional refinements will be made in the routine review of the scope and frequency of the preventive maintenance work in the program.

.. ~

VIII'. COMMITMENT MANAGEMENT The tracking of commitments has become an inherent part of the Maintenance management effort'. A system has been designed for each individual to'be'able to status his individual commitments as well as the other activities for which he is responsible. We needed to get away from the concept that we need a specific individual to track' activities and remind others when they are late.

The system does this for us.-

We needed to'get'the attention given at the level' at which we expect the work to'be done to satisfy the commitment.

With the change in Maintenance Engineers, October 19, 1983, a complete review of all existing maintenance activities took place.

The Administrative Coordinator is assisting the Maintenance Engineer, as necessary for completion of all action items.

A commitment tracking system has been established for the entire station organization and is being utilized by the' Maintenance Staff.

This system has proven effective as a management tool for scheduling resources'for completion of commitment items.

It has also resulted in a net reduction of the outstanding commitments for which the Maintenance Section is responsible. Our Performance Enhancement Program will be making broad based recommendations in the area of Commitment Management and we will effect any changes in our present system to support these recommendations.

.)

T:

• i Dockst Nai 50-346

-Licinsa Ns. NPF-3 '

Serial No. 1-448

" July'18,'1984

-Attachment 1-(Page17 s

-(

.IX.

' EVALUATE AD 1835.00,-PLANT CLEANLINESS INSPECTION PROGRAM AD 1835.00-(Plant. Cleanliness Inspection Program) was implemented on June 23,'1983.- The effectiveness of this procedure during its first

.three months was'not up to our original expectations..Several Ldepartments charged with conducting and documenting monthly plant cleanliness tours did not do so during the refueling outage. Our

-Chemistry & Health Physics Department did conduct the monthly inspections-in their areas. The Assistant Superintendent Operations evaluated the. procedure ef fectiveness based on these limited reports

'and modified the procedure to correct deficiencies. The Station

~ Superintendent.in his October 31, 1983 staff meeting advised all departments to begin performing their inspections as outlined in the procedure.

An: inspection schedule for the Maintenance Department was developed

~

and discussed at the Maintenance staff meetings prior to implementa-tion.. Also, a contractor was retained to bring pipe insulation up

'to standard.

LAssignment of responsibility for plant cleanliness inspection and follow-up.to a Maintenance Supervisor, and the utilization of a

-contractor-for insulation upgrading, has resulted in marked improve-ment in plant cleanliness. Reestablishment of a water treatment task force will be an additional plus for plant cleanliness. Plant cleanliness is now considered a routine part of job responsibilities and continued emphasis on housekeeping at both the staff'and shop Elevel is expected to.further improve. plant material conditions.

X.'

REVISION OF AD 1844.08, JOB OBSERVATION' lu) 1844.08-(Job Observation).was-implemented on June 28, 1983.

Approximately 20 job observation assignment sheets had been initiated. In early October, 'a temporary modification to the procedure was made to clarify some minor details. With the change in' Maintenance Engineer on October.19, 1983, the final determination of follow-up responsibility was not certain.

A detailed organizational review was conducted and the job obser-vation philosophy:and forms have'been included in AD 1844.00, Maintenance. /Df1844.08, Job Observation,- will be retained as an active proceduri for a period of approximately a year to assure effective transition to utilization of AD 1844.00 Job Observation actions.

Ih e

'

• i 5 Docket.No.;50-346~

i, Lic n;a No. NPF-3 Serial No. 1-448 July 18, 1984

~

. Attachment'l Page 8~

XI.

-WATER TREATMENT TASK FORCE A-Water Treatment Task Force was reestablished with a formal charter and objectives in April.

.The' Environmental Monitoring Supervisor. was celected to chair the Task Force. The charter and objectives are as follows.

CHARTER I

The Task Force shall be comprised of five to seven members l designated by the Assistant Station Superintendent - Operations.

The Task Force Chairman shall also be designated by the Assistant Station Superintendent - Operations. For the first six months of-existence, the Task Force shall meet as determined by the Chairman and commit no less than eight hours per month to the Task Force work, not necessarily all in meetings. Monthly reports on Task Force activities shall be submitted by the Chairman to the Assistant -

~ Station Superintendent - Operations. The Task Force objectives shall be to improve plant equipment material conditions and operation to an acceptable level (as defined by the Task Force) and

.to insure that maintenance and modification work including preventive maintenance programs.are in place to maintain equipment material-condition..

0BJECTIVES

-f '

Identify problems'in Water Treatment material condition and operation.

Identify root causes of problems utilizing the Kepner-Tregoe i

decision making process.

-- Recommend. resolutions to problems to the Assistant Station Superintendent - Operations.

Develop action plans for problem resolution and submit to Assistant Station Superintendent - Operations.

Following action plan approval by the Assistant Station Super-

.intendent - Operations, monitor action plan implementation to assure effective and timely completion.

A number.of task force meetings have been conducted. Thus far the members, using Kepner-Tregoe problem analysis techniques, have identified and prioritized'a list of. concerns in the water treatment area. These concerns have been grouped into major categories of Management Controls; Instrument and Control; pumps, piping and

. tanks; physical environment; and water' quality.

g;.

T.m c.7,g.Dockat N2.-50-346 4Licsnss'N3.-NPF-3' 4-

?-

-Serial No. 1-448 TJuly 18,'1984 Attachment'l

Page 9 XII. TRAINING IN SHOPS AND FOR THE STAFF DThis' area still requires a lot of. attention and clearer definition of the objectives and responsibilities of the various individuals.

' We. want to more clearly define who has 'the lead responsibility for developing and administering programs. In the shop training, we

.want to make sure that the apprenticeship programs are being effec-tively administered and providing effective training in developing

journeymen.. We also will be assuring that there is a program for continued training for all journeymen. The definition of responsi-bilities between the maintenance staff and the Training Department for the continual-training program also needs to be defined and assigned..The training for the shop personnel also must include administrative 'and supervisory functions we expect the Group Leaders

.to perform. Shop training needs to have increased emphasis and

.possibly some special training sessions for building team work.

Training:for the Staff will address all training needs for personnel

from the entry leve1' positions up to the lead positions. When we

'have.an effective MBO Program, training becomes an integral part of that. effort _and can be addressed on an individual basis utilizing the in-house and special training programs that are;available.

The Maintenance Engineer has responsibility-for identifying. training needs for Maintenance Staff personnel and the development'of a long range training program. Contained in this training program will be the identification of qualifications required for the various maintenance staff activities. Mechanical maintenance has parti-

'cipated in the training diagnostic performed by Nuclear Training Department and the other shops will also be included in the diag-nostic performed by the Nuclear Training Department.

XIII. MATERIALS PLANNING AND COORDINATION Efforts in this area are not as fruitful and the results are not as expedient as we could reasonably expect. There are numerous areas of' activities that. appear to be uncoordinated or improperly tied together. _These efforts by nature need to involve Materials Manage-ment, the~onsite Procurement'and Stores Group, as_well'as Maintenance. The Bill of Material (BOM) process has provided some improvements _in the procurement phase ~of materials management, however, at the implementation level, significant improvements can be made to support productivity enhancements for the Maintenance staff.and the shop personnel. This total effort is broad enough that it^cannot.be encompassed in the MBO program with the Maintenance Section. Objectives in this area are to implement a

' process which eliminates lost time, both in schedule and in manpower, awaiting materials at the job level (implementation phase). The process must start with the identification of the material needs. They must have a more direct and simpler L

Docket'N). 50-346 Licin s N3. NPF-3 Serial No. 1-448 July 18, 1984 Page 10 communication path for serving the material needs when materials are available in the warehouse or on a shelf of a local supplier. We must have a system for initiating, tracking, expediting the process of purchasing non-stock items, and those items not available through

-the Blanket P.O. utilization.

Activity in this area requires the joint efforts of the Nuclear and Administrative Services Missions.

The Material Control Operations Supervisor will be serving as the lead in this area, and he will be striving to identify and resolve the issues in Material Management.

l 4

1

.. -.... -.