ML20203G538

Forwards Recommended Action W/Comments Recieved from 921105, Public Meeting on Northeast Utils Pep

ML20203G538
Person / Time
Site:	Millstone
Issue date:	12/03/1992
From:	Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20203G108	List: ML20203G102 ML20203G137 ML20203G151 ML20203G160 ML20203G184 ML20203G197 ML20203G215 ML20203G231 ML20203G241 ML20203G255 ML20203G272 ML20203G493 ML20203G500 ML20203G538 ML20203G549 ML20203G577 ML20203G598 ML20203G625 ML20203G643 ML20203G659 ML20203G717 ML20203G778 ML20203G811 ML20203G849 ML20203G902 ML20203G945 ML20203H005
References
FOIA-97-469 NUDOCS 9803030010
Download: ML20203G538 (5)

Text

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i MAP ISSUE NO. 21 POOR ENGINEERING SUPPORT Or PLANT OPERATION i

STATEMENT OF MAP li1ME1 MAP Issue No. 23 notes that the engineering organization has not provided adequate support for operation of Millstone Unit

3. Specifically, the NRC's, final SALP Report, dated August 4,1992 notes that, " Longstanding equipment and operational problems, which were not adequately addressed during previous cycles of operation, caused unnecessary unavailability or inoperability of safety related equipment during this period such as continued lifting of safety injection pump relief valves during operationhl tests. Once sufficient engineering resources were applied to these problem areas, adequate technical resolutions were obtained. However, the failure to address these issues in a more anticipatory manner indicated a problem with the effectiveness of Unit 3 engineering resources to monitor equipment performance and recommend appropriate action."

LICENSEE'S RESPONSE TO MAP CONCERN: The licensee's response addresses the two aspects of the MAP concern as follows:

• Action Plan 2.3.4 addresses the need to more closely monitor system performance to identify and correct degradation. This action plan provides for implementation of the " system engineer" concept at each unit. The system-engineer would have extensive design ard licensing basis knowledge and would be responsible for monitoring the assigned system and providing a point of contact for system design and remedial action changes.

• Action Plan 2.3.9 addresses the identification and elimination of the engineering backlog.

The implementation of these action plans are intended to improve engineering support for plant operations.

INSPECTION RESULTS: With regard to Action Plan 2.3.4, Millstone has historically provided engineering support for operations via engineering groupe which reported to the individual unit directors (unit superintendents).

These engineering organizations monitored unit operation and provided day-to-day support such as support for design changes, system engineering, inservice inspectic i and testing, review of NRC Bulletins and Information Notices, and review of nonconformance reports. In June 1991, a corporate reorganization resulting in the formation of the Project Services Department (PSD) within the NE&O organization. Since its formation, PSD has been providing day-to-day engineering support for unit operation. At the present time, the licensee estimates that over 80 percent of the Unit 3 engineering support is provided from PSD which maintains substantial on-site " satellite" offices. With implementation of the system engineer concept, e'.1 day-t.o-day engineering support will be provided by PSD and the unit engineering capability will be dedicated to system engineering.

With regard to system engineering, the licensee has issued the " System Engineer Manual - Rev 0", Procedure MP3-92-346, dated October 30 1992. This document is applicable to Millstone Units 1,2 and 3 and Haddu Neck. The 9803030010 980226 PDR FOIA O'MEALI97-469 PDR _.

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system engineer, as defined by the procedure, will act as an expert for system I performance, deficiencies and incident reports, surveillances, documentation, and sharing industry experience. The procedure also defines interfaces with other system engineers and other organizations and provides a proposed training program.

Action Plan 2.3.9 provides for the identification and elimination of the engineering backlog. The backlog elimination, addressed in a project completion plan approved in September 1992, defines the backlog in terms of l tasks ider.tified prior to February 12, 1993. After February 12, 1993, new engineering tasks will be handled on a day-to-day assignment rather than as backleg. The licensee's evaluation of the backlog indicates that approximrtely 350,000 of a total of 400,000 man-hours of effort are ass'gned to Millstone Unit 3. The next largest backlog contribution is Haddam Neck with approximately 30,000 man-hours.

CONCLUSIONS: The licensee had been experimenting with the system engineering approach prior to formation of the PEP without having achieved a substantial commitment to full use of the concept. Implementation of Action Plan 2.3.4 should result in change over from task to system engineering within the unit organizations by December 1995. The backlog reduction effort, Action Plan 2.3.9, will result in significant a<iditional resources being applied to reduce the engineering backlog. Taken together, the licensee's response to MAP concern No. 23 should improve day-to-day engineering support of unit operations.

FOLLOW-ON ACTIVITIES: The NRC Staff should continue to monitor engineering backlog to assure that it does not reappear.

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DEC 0 31992 MEMORANDUM FOR:- James T. Wiggins, Deputy Dinctor, DRP FROM: A. Randolph Blough, Chief, Projects Branch No. 4, DRP

SUBJECT:

RECOMMENDED ACTION WITH COMMENTS RECFlVED FROM THE NOVEMBER 5,1992, PUBLIC MEETING ON NU'S PERFORMANCE ENHANCEMENT PROGRAM Rami on my staff's detailed review, we have identified the following commer.ts from the transcript (see attached) of the November 5,1992, public Mng on NU's PEP which warrant attention, along with recommended action for each.

A. Comunents from Paul Blanch:

1

1. "The solution to NU's problems is not a paper exercise.... It must be an entire culture change...reinstill the morale, faith, and trust in management." (pgs.19-

20) "Some people I have talked to am feeling that they are, again, pursuing a lot of meaningless paperwork...." (pg. 27)

2. "We have a regulatory organization (the NRC) concerned only about providing an illusion of action....(pg. 20) Mr. Russell eventually called a meeting on July 29th,1992 (on the BWR vessel level issue)...and stated that he just became aware of the magnitude of this issue nine days prior to the Mag - this is a material false statement (pg. 22). ....to further demonstrate the ineffectiveness and total disregr.-d for miclear safety by the NRC, ...it is the NRC that desperately needs a program to improve management performance...." (pg. 25)

Recommended Actions; h

y A.1. Refer the comments to NU to evaluate the issues and, if pertinent, explain how PEP will address them. _ Hold a followup MAP meeting with NU in which we ask them to present their evaluation and explanation.

A.2. Inform the IG's office of these accusations; the accusations have already been informally provided to Mr. Russell.

(78630300 FD ,

James T. Wiggins 2 B. Coaunents from Joe Carter:

... you are not doing a ... thing except covering your tracks and trying to sound impressive...(description of incident involving the handling of his concern)...that is how inept your whole outfit is." (pg.16)

Recommended Action:

The IG's office was previously informed of the same accusations by memo from NRC Region I on October 9,1992; the applicable transcript excerpts should also be sent to the IG.

C. Comments from Don DelCort:

1. "I have, as Mr. Sullivan so eloquently pointed out, wa'ched the Nuclear Regulatory Commission sit on its hands. ...I think the Performance Enhancement Program needs to be applied to the Nuclear Regulatory Commission...." (pg. 30)

2. "...once you start bringing back the trust in people, the rest of the programs will take care of themselves...(related to Blanch's comments on PEP effectiveness)."

l Pg. 32) l l 3. " And there are going to be changes in personnel if those people can't get the plant l (Unit 2) on the line by 22nd of December." (pg. 33) 1

4. "The ensuing investigation that is conducted on that person's behah oy your organization (OI) further intimidates...the ir.dividuals who are at that particular site, because essentially they are questioned at the site." (pg. 68)

Recommended Actions:

C.I. Inform the IG's office of these statements, along with Paul Blanch's similar comments (A.2).

C.2. Handle similarly to Paul Blanch's similar comments (see Recommendation A.I.)

C.3. Discuss with NU senior management. Also, augment resident inspection coverage during Unit 2 restart from the ongoing outage (already planned).

C.4. Refer this comment to Barry Letts as it is applicable to Ol's practices es a whole.

A +

James T. Wiggins 3 D. Comments from Ray Fontaine:

J "I think that if you try and cut down some of the paperwork...." (pg. 50) degommended Action:

Same as Recommendation A.I.

E. Comments from Jay Sullivan:

1. "How the heck do I get out down by Ocean Beach when the wind is blowing out of the southwest if there is an accident? ...I can't image going to Vethersfield on an evacuation plan and finding out they did something else with my kids."

(pg. 35)

2. "(siren inaudible) Flanders Road by Travel lodge. neve they fired it off l on Saturday. I could hear it from where I v1.- ..terford, but over there I couldn't hear it." (pg. 54)

ETC0mmended Actions:

E.1. Discuss concern with DRSS and, if necessary, FEMA and provide Mr. Sullivan a written response on the evacuation plans for that area.

E.2. DRP has taken some action already to follow-up this concern with local officials; continue efforts to resolve this concern and provide a response to Mr. Sullivan.

Based upon naff review of the transcript, I think this list of actions encompasses all actions necessary by the NRC in response to the co:nments received.

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A. Randolph Blough, Chief Projects Branch No. 4 Division of Reactor Project:

Enclosure:

Transcript cc w/o encl:

MAP Members R. Barkley, DRP w

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• • • • • [ FING oF PRUSSIA PENNSYLVANIA 19406 1415 DEC 1 o m2 MEMORANDUM FOR: Millstone Assessment Panel Members FROM: James T. Wiggins, MAP Chairman

SUBJECT:

SIXTH MAP MEETING HELD ON NOVEMBER 5,1992 The sixth Millstone Assessment Panel (MAP) meeting was held in the Millstone Resident inspector's Office from 2:00 p.m. - 4:00 p.m. The attendees at the meeting were:

Atte) Membits:

Ar,dra Asars, Resident Inspcctor, Millstone (Acting for Paul Swetland)

Randolph Blough, Chief, DRP Branch 4 Lawrance Doerflein, Chief, DRP Section 4A Jacque Durr, Chief, Engineering Brancl.

i David Jaffe, Senior Project Manager, NRR -

James Wiggins, Deputy Director, DRP I Other Attendees: 1 l!

Richard Barkley, Project Engineer, DRP Section 4A I

Plant Status:

f The meeting started with a discussion by Andra Asars of the status of each of the Millstor e Units. Currently, Unit 1 is operating at 100% power with no major operational concerns Unit 2 is scheduled to remain shutdown until late December for refueling and steam gene rator replacement. NU has several outstanding safety concerns which require resolution nrior ta plant start-up, most particularly the technical resolution of the design deficiencies noted in the '

July 6,1992, Loss of Normal Power Event. Unit 2 is also the subject of an ASLB hearing regarding the safety of the spent fuel storage pool. An ASLB pre-hearing on the matter was conducted on November 5,1992. Finally, Unit 3 has remained shutdown since September

.30, 1992, due to the inoperability of both trains of the Supplementary Leak Collection and Release System (SLCRS), but was expected to restart in the very near future.

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$ y l RECENT MAP ACTIVITIES: @ l Salus eveloDment and ImDiementallon:

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Rich 12udenat of NU madu ;. presentation and answered questions regarding the PEP--

verification and validation program. In particular, Mr.12adenat stated that in light of the team's findings, NU will be providing the PEP Action Plan managers with a document regarding how to develop validation criteria. Mr.12udenat stated that there would not be I validation of a significant numbet of Action Plans until the 2nd quarter of 1993. Further, he indicated that NU estimated there would not be any demonstrable effect of the PEP on performance until mid 1993. NU is currently working on a communication plan to explain to the bulk of the NU staff and management why the PEP is needed and what is in it for them (the team's interviews with employeer found this element of the PEP implementation lacking). When asked by the MAP about who in NU management and staff are committed to the PEP, Mr. Laudenat stated that the department heads at the site and corporate offices are receptive to the program; however, buy-in below that level is not where NU wants it. Also, MU has some additional work to do on buy-in at Haddam Neck. Finally, based on the discussions, it remained unclear how emerging issues such as the tecent requalification failures at Unit I are being assessed for impact on the PEP.

The MAP received a presentation from Rich Barkley regarding the findings of the Performance Enhancement Program (PEP) Review Team. The team, consisting of Richard Barkley (team leader), Dave Jaffe, Pete Habighorst, Suresh Chaudary, and Catherine Thompson, performed the second week of a planned two week review of the PEP at NU's corporate office and at the Millstone and Haddam Neck sites during the week of October 26-30, 1992. The principal focus of the PEP Review Team dming this week was on the procedural aspects of the verification and validation (V&V) effort for the PEP as well as the conduct of a series of employee interviews regarding the perceived atmosphere at NU for raising safety concerns as well as recent ch mges to key aspects of their d9y-to-day work.

The team also followed-up on open issues from the first week of their review regarding NU's plans to address M AP issues in the performance areas of procedure compt mee, personnel errors and inattention to detail.

The team found that the V&V process was comprehensive with adequate management oversight and provisions for independent oversight of the effort. However, no validation criteria were available for review nor was there a significant understanding on the part of the l Action Plan managers as 'to what these criteria should be. The results of the employee interviews indicated that the vast majority of employees felt comfortable raising safety concerns through their managemant chain and were knowledgeable of alternate methods for

raising these concerns. The 7eriults of the interviews regarding key changes to aspects ,f the workers' day-to-day work environment indicated that

1) a majority feh that nrocedure qsahty was improving; 2) a majority had seen little or no noticeable iniprovemei t in procedure

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