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'* 7, NUCLEAR REGULATORY COMMISSION O
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799 ROOSEVELT ROAO GLEN ELLYN. ILLINOIS 60137
,o January 9, 1985 MEMORANDUM FOR: William J. Dircks, Executive' Director for Operations FROM:
James G. Keppler, Regional Administrat r, Region III
SUBJECT:
DAVIS BESSE REGULATORY PERFORMANCE This is to inform you regarding Toledo Edison Company's (TECo) regulatory performance in connection with the Davis Besse nuclear plant and the NRC's actions to improve that performance.
In 1979, as a result of an increasing trend in noncompliance, personnel errors, and repetitive equipment problems, Region III persuaded Toledo Edison to initiate actions to improve the Davis Besse regulatory performance.
The utility was responsive to the co'ncerns raised and established and implemented a program aimed at improving its management controls, staffing, training, and correction of equipment problems.
Region III monitored that program through periodic meetings with the licensee and an expanded inspection program. Measurable improvements were observed subsequently in the Davis Besse regulatory performance and Region III reverted back to its normal inspection program in early 1981. At that time, I would describe Davis Besse's performance as average and that performance level was sustained through 1982, although some areas of concern were being identified by NRC inspections.
In early 1983 we started to notice a decline in the utility's regulatory performance, and we held several meetings with the utility aimed at shoring up the identified weaknesses.
Comissioner Gilinsky's visit in November of 1983 prcmpted us to initiate additional efforts to upgrade the performance at Davis Besse.
Region III and NRR management met with senior TEco officials in November and urged them to initiate a comprehensive Regulatory Improvement Program for Davis Besse.
At the conclusion of the meeting TEco management commit.ted to conducting a full diagnostic evaluation of its nuclear program aimed at determining the weak areas and to defining a Regulatory Improvement Program.
A number of ensuing meetings have been held aimed at defining the Regulatory Improvement Program and monitoring the status of that program.
But, while a comprehensive program has been developed, implementation of the program has been slow --- and improvement in overall regulatory performance has not been observed to date.
In fact, a number of operational events have occurred during 1984 which reflected adversely on the utility's management controls.
Additionally, a PAT inspection in the sumer of 1984 reenforced a number of Region III identified concerns and highlighted a lack of formality in control room operations.
0510070138 050717 PDR COMMB NRCC I L 7 1%$
CORRESPONDENCE PDR
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William J. Dircks January 9, 1985 As a result of the Region III and PAT inspection, the following actions were taken:
j 1.
Mr. DeYoung and I met with top corporate management last October to impress upon the utility the need for prompt corrective action.
I 2.
A proposed $90,000 civil penalty was issued to the utility on November 21, 1984.
In addition to the above, the recently completed SALP appraisal gave the utility a Category 3 rating in five functional areas.
This appraisal has generated considerable negative publicity for the utility, which may prove to be the most decisive factor in convincing licensee management of the 1
need for prompt, lasting action.
During the SALP meeting, which was attended by the media, state and local officials, and members of the public, i
j I told utility management that "a continuance or further decline of this performance level at Davis Besse is unacceptable to me" and that improved i
performance must be realized.
Utility management stated they were comitted to improving regulatory performance and outlined a number of actions being undertaken to accomplish the Regulatory Improvement Program.
I have requested a written response to the SALP report describing planned corrective actions.
(As a direct result of the SALP ' appraisal, Comissioner Asselstine plans to visit the Davis Besse site on January 11,1985.)
I have met recently with the CEO of TECo and believe we now have the company's attention in dealing with this issue.
I plan to follow the licensee's performance closely, including periodic management meetings to monitor Regulatory Improvement Program commitments, and will be augmenting our inspection activities to assure improved site performance.
Special inspection attention will be devoted to the licensee's effectiveness in strengthening training and improving control room behavior.
l, I will keep you informed of our progress in bringing about improved regulatory t
performance at Davis Besse and will not hesitate to recommend further NRC action should I consider that appropriate.
I e,
-Ae l
[JamesG.KeppYef J
Regional Administrator cc:
H. R. Denton, NRR l
R. C. DeYoung, IE i
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