ML20133B847
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JUN 5 1585 4
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,1 MEMORANDUM FOR: William J. Dircks, Executive Director for Operations FROM:
James G. Xeppler, Regional Administrator, Region III i
SUBJECT:
STATUS OF REGULATORY PERFORMANCE AT DAVIS-BESSE i
NUCLEAR PLANT l
Following issuance of our last SALP report to Toledo Edison Company and l
a subsequent visit'to the Davis-Besse site by Commissioner Asselstine, the i
j Commissioner requested that I provide an update to him on the status of 1
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-regulatory performance at the Davis-Besse facility.
The attached memo is 2
j provided for that purpose.
Oric!nni sicntd by l
.\\. Der?. lW:1a James G. Keppler Regional Administrator I
Attachment:
Memo to Comm. Asselstine 1
cc w/ attachment:
1 H. Denton, NRR J. Taylor, IE i
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DRAFT
'l MEMORANDUM FOR:
Commissioner James K. Asselstine FROM:
William J. Dircks, Executive Director for Operations
SUBJECT:
STATUS OF REGULATORY PERFORMANCE AT DAVIS-8 ESSE NUCLEAR PLANT At the time cf your visit to the Davis Besse nuclear reactor facility last January you stated your intent to revisit the plant in approximately six months and requested an interim written report from the staff on the status of Toledo Edison Company's efforts to improve its regulatory performance.
This memorandum is in response to your request, i
Following the issuance of the SALP report, licensee management has initiated a number of actions aimed at improving their overall performance.
The Chief Executive Officer, John P. Williamson, has committed himself and his manage-ment team to achieving a " state of excellence" at Davis Besse.
A nurber of management actions have been initiated aimed at eliminating past attitudinal deficiencies, achieving better individual performance, improving communications, and establishing stronger relations with INPO.
The Company has also instituted a SALP Improvement Task Force, conducted and/or planned management visits to other plants, and pursued full implementation of the Performance Enhancement Program (developed in 1984).
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DRAFT The Region III staff has increased its surveillance of licensed activities including the conduct of a number of special inspections in functional areas where the licensee was rated a Category 3 in the last SALP appraisal.
Mr. Keppler has conducted periodic meetings with top management in an effort
.to focus management attention on issues of importance to NRC.
In addition, on May 17, 1985, senior NRC managers and I met with Mr. Williamson to hear firsthand the actions being taken to improve regulatory performance at Davis-Besse.
I am convinced utility management is dedicated to achieving a.high level of performance.
The enclosure to this memorandum identifies the problem areas identified in
..the last SAlp report, licensee corrective actions and our activities and assessment of changes in performance.
While some improvements have been noted, overall progress has been slow.
This has not been totally unexpected, given the size of the organization and the scope of the problems.
Nevertheless, we are concerned that the company may not as yet have properly addressed root causes of these problems.
Our inspection findings revealed recent events that demonstrated a lack of attention to detail and the failure to implement meaningful corrective action due to poor communications and/or a lack of appreciation of the significance of regulatory violations.
Escalated enforce-ment action is being considered.
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ORAFT We intend to continue our augmented efforts toward this licensee until their performance comes up to our expectations.
William J. Dircks Executive Director for Operations
Enclosure:
Problem Areas Identified in SALP cc w/ enclosure:
N. J. Palladino, Chairman T. M. Roberts, Commissioner F. M. Bernthal, Commissioner L. W. Zech, Commissioner i
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ENCLOSURE Plant Operations Concern:
During the SALP 4 assessment period, this area was rated a Category 2 but the performance trend was declining.
Problems identified were the large number of nuisance alarms, frequent personnel errors, and lack of knowledge of plant design basis by the plant staff.
Licensee Action:
Requirements for valve lineup verifications have been upgraded, access to the control room by non-essential personnel has been restricted, and nuisance alarms have been reduced.
Operations Engineers meet periodically with operations personnel to encourage professionalism.
A non-shift SRO was assigned to review all Maintenance Work Orders (MW0s) for system operability requirements.
A task force has been assigned to develop a plan for plant design basis reviews which was completed on May 1, 1985.
- Also, a program has been initiated to reduce the use of jumpers and lifted wires.
NRC Actions / Findings Augmented inspections of control room and plant activities were conducted on January 14 through February 15, 1985.
The inspections were conducted by a region based project inspector and three senior resident inspectors from different sites in Region !!!.
The results of these inspections and observations by the Davis-Besse resident inspectors indicate that the licensee's corrective actions are beginning to impact positively on their performance.
Additionally, nuisance alarms in the control room have been sub-stantially reduced.
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Maintenance Concern:
During the SALP 4 assessment period, this area was rated a Category 3 but the performance trend was improving.
Licensee management's attention to problems had not been totally effective.
Weaknesses in and
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adherence to procedures had resulted in frequent equipment problems.
Licensee Action:
The Maintenance Engineer position has been filled.
An increase of four additional Maintenance Foremen positions has been authorized to provide increased i
overview of maintenance activities.
A Management by Objectives (M80) program has been implemented to improve accountability of job responsibilities and define objectives in the Maintenancs Department.
A system has been developed for the prioritization of maintenance activities to improve management planning and control.
Training of maintenance personnel has been implemented to provide better understanding of design basis and job requirements.
Expansion of main-tenance coverage has been initiated to spread the 1'
work load.
A new maintenance shop facility is scheduled for completion by 1987.
NRC Actions / Findings An in-depth inspection by region-based inspectors in this area was started on March 25, 1985, and was com-plated April 25, 1985.
In addition, the resident i
1 inspectors have performed inspections concentrating on the licensee's corrective action program for improve-1 ment of their performance.
Marked improvement has been i
noted in plant cleanliness and housekeeping.
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has been a decrease in personnel errors thus decreasing equipment problems.
Improvement has been made in 4
f implementation of the maintenance program, but further improvement is still needed.
Two more in-depth inspec-tions are planned within the next six months to monitor the licensee's performance, r
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Concern:
Performance in this area had declined to a Category 3 rating for the SALP 4 period.
Problems were identified in the licensee's tracking of EP activities, and l
performance of the 1984 exercise.
f Licensee Action:
Initiated actions to better coordinate Quality Assurance audits of EP.
The Activity Scheduling System is under development and will be used to identify, schedule, and track both commitments and routine acti-i vities.
These activities will include INPO and NRC commitments, QA audit findings, EP required activities (NUREG-0654), drill and exercise critique items, j
training requirements, etc.
The Vice President-Nuclear 1
or his assistant will be provided with periodic overdue I
commitment reports.
This system will be implemented j
in September 1985.
A Scenario Development Committee has been established for the 1985 exercise.
Increased i
hands-on and drill training has been initiated for both 1
corporate and station personnel having emergency l
responsibilities.
y NRC Actions / Findings:
Ouring January, February, and April 1985, three inspections were conducted by regional emergency preparedness specialists at the site to monitor ifcensee activities.
These inspections have noted j
improvements in EP training and scenario development i
for the 1985 exercise.
The inspectors also verified i
that development of the EP tracking system is on I
schedule and appears to be adequate.
A general improvement has been noted in this area.
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Quality programs Concern:
This area was rated a Category 3 and the performance l
trend was declining.
Problems were identified in I
the licensee's Audit Program and the lack of thorough-l ness in their review of design changes.
I Licensee Action:
The lic'ensee has initiated steps to improve their tracking of audit findings, deviation reports, l
supplier deviation reports, and nonconformance reports.
All audit findings and nonconformance reports will be reviewed by the Station Review Board for safety signi-ficance.
Design documents are being updated as work orders are closed to properly reflect the as-built l
status of the plant.
Conceptual design reviews and l
reviews by area specialists (equipment qualification, fire protection, etc.) have been initiated for design changes.
A standing order has been issued directing the Shift Supervisors to review changes to equipment status for effects on operability.
Management par-ticipation at QA exit interviews has been made a requirement.
QA auditors will be receiving increased technical training and technical experts are being included on audit teams when appropriate.
General Empicyee Training has been revised to meet INPO guidelines.
Quality awareness training has been initiated for non-QA personnel.
NRC Actions / Findings:
Region III has initiated a series of augmented inspec-tions to assess the quality assurance, maintenance, and corrective action programs and their implementation.
A total of four inspections have been completed.
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inspections have shown that the licensee's systems for identifying items that require corrective action are I
adequate; however, a large backlog of items still exists.
Improvement in other programs in this area has been I
observed and the programs and their implementation are now considered adequate.
We intend to assure during our future augmented inspections that TEco con-tinues to improve the ef fectiveness of the programs.
We also intend to assess the results of TEco's efforts in prioritizing and reducing the backlog of work items.
l While improvement has been noted in specific correc-i tive action programs, recent inspections indicate l
l weaknessos in the licensee's ability to provide expeditious and comprehensive communications between the plant and corporate management.
Also, these l
recent inspections indicate weaknesses in management involvement in assuring that root cause determinations l
I and corrective actions are taken in a timely manner.
A special inspection has been planned for June 9-14, 1985 at the Davis-Besse facility to assess _the licensee's systems for communication relating to i
ongoing station activities, l
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Fire Protection Concern:
This area was rated a Category 3 with an improving trend during the SALP 4 assessment period.
Problems identified in this area included inadequate testing procedures and inadequate reassessment of Appendix R issues.,
Licensee Action:
The licensee has developed specific Fire Protection procedures including upgrading of the Fire Strategy Plan to provide a room by room plan to deal with a fire.
This plan will be completed by August 1985.
A Project Management Team was formalized January 1, 1985 and will perform committed reviews and also perform conceptual engineering for fire protection modifica-tions.
A Compliance Assessment Report for a systematic area by area review for potential noncompliance with Appendix R was submitted to NRC on September 1, 1984.
NRC Actions / Findings:
Inspection of this area is currently scheduled for August 1985.
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Training l
Concern:
This area received a Category 3 rating for the SALP 4 assessment period.
Problems in this area included weakness's in the non-operator and operator training program; inadequate implementation of the retraining program for licensed operators; incomplete technical content' of the training program; lack of management oversight of contractor provided training; poor administration of SRO and RO exams; and no training of electrical and I&C personnel.
Licensee Action:
All Nuclear Training procedures have been generated j
which provide instructions for the accomplishment of l
various training functions.
The training staff has doubled since the summer of 1984.
Measures have been implemented to improve R0 and SRO requalification exams.
A program has been established to meet criteria necessary for INPO accreditation.
The operator training program will be ready for INPO accreditation by December 1985.
A Training Review Board has been established to discuss and review training issues and review quarterly revisions to the Master Training Schedule.
Laboratory and classroom training will be upgraded by August 1985.
Completion of a plant simulator is planned for December 1988.
NRC Actions / Findings:
A followup inspection of the training deficiencies identified in the Performance Appraisal Team (PAT) inspection was performed in February.
Additionally, a team inspection is planned for Summer 1985 to evaluate the licensee's training program.
The review team will include regional inspectors as well as NRC headquarters personnel from the Olvision of Human Factors Safety.
Results of these inspections will form the basis for future NRC inspection activities in this area.
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