IR 05000341/1986022

Insp Rept 50-341/86-22 on 860714-17.No Violation or Deviation Noted.Major Areas Inspected:Actions on Lers, Licensed Operator Training & Nonlicensed Staff Training Effectiveness

ML20203K218
Person / Time
Site:	Fermi
Issue date:	08/01/1986
From:	Darrin Butler, Eng P, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203K217	List: IR 05000341/1986022 ML20203K213
References
50-341-86-22, NUDOCS 8608070047
Download: ML20203K218 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/86022(DRS)

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Docket No. 50-341 License No. NPF-43 Licensee: Detroit Edison Company -

2200 Second Avenue Detroit, MI 4822E Facility Name: Fermi 2 Inspection At: Fenni Site, Newport MI l Inspection Conducted: July 14-17, 1986

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Inspector: Pa ia ng Date~-

Inspector:

wkAhb David S. Butler d/ !7d Approved By: Monte '. Phillips, Chief ~

I Operational Programs Section 'D'a ttIe Inspection Summary:

Inspection on July 14-17 DRS Areas Inspec' tee D'oEth,e_,_1986 JR_eport No.I5iannounceTTn'si~eTtlin lif~ ~act50-341/8 Ticensed operator training effectiveness (IE Module 41701) and non-licensed staff training effectiveness (IE Module 41400).

Resul ts: Of the three areas inspected, no violations or deviations were identifie "

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DETAILS 1. Persons Contacted

• J. M. DuBay, Superintendent, Services

• J. D. Leman, Superintendent, Maintenance and Modifications L. Bregni, Compliance Engineer

• J. T. Coleman, Supervisor, Nuclear Training

• J. E. Conen, Licensing Engineer

• R. C. Drouillard, Nuclear Operations Project Specialist

• S. K. Ennis, Supervisor, Procedures

• G. F. Kenney, Senior Nuclear Training Specialist M. Marlin, Corrective Action Coordinator

• R. W. McLeod, Acting Assistant Director, Nuclear Training E. Muszkiewicz, Operational Assurance

• F. T. Schwartz, Supervisor, NQA Staff B. Sheffel, ISI Programs Coordinator M. Stockman, ISI Engineer

• Denotes those in attendance at the exit meeting on July 17, 1986.

During the course of the inspection, the inspectors also met and inter' viewed other members of the licensee's staf . _L_icensee Ac_ tion on_ L_ER_ 86-13 (92700)

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(Closed)LERNo.86-013: During a planned maintenance outage in May, 1986, 10 of 15 Target Rock two stage SRVs had been found to be outside Technical Specification (TS) 4.4.2.1.2 setpoint tolerance. The average setpoint lift pressure at that time was 102%. The SRVs had been last tested in mid-year, 1980. The 18 month surveillance period was begun at initial reactor startup on June 21, 1985. Previous to that time, the valves had never been subjected to normal operating conditions. During the six year period, the SRVs had drifted only 2% over their required setting. Each SRV was refurbished. Eight of the SRVs had a new pilot disc installed as recommended by the Boiling Water Reactor Owners Group SRV Setpoint Drift Conmittee. Retest of each SRV was performed and the average setpoint lift pressure was 100.1%. The plant margin of safety had not been reduced, and the setpoint drift had not presented any undue risk to the health and safety of the publi . Licensed Operator _ Training _(_4170_11

_ Training _0vervi_ew In order to determine the means by which the training function at Fermi 2 was structured, the inspector requested a copy of the Training Policy Statement. The licensee provided a copy of Nuclear Operations Program Description (N0P) 400, " Nuclear

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Operations Training Program," revision 2, dated December 14, 198 During review of N0P-400, the inspector noted that of the ten signatures apparently required, only two, the Director of Nuclear Training and the Director of Nuclear Quality Assurance, were actually present. Further investigation revealed that the N0P documents were governed by Nuclear Operations Directive (N0D) 1 The revision of N00 14 in effect at the time of the N0P revision stated that, "N0Ps are reviewed and approved by all Nuclear Operations organizational unit heads and the Manager Nuclear Operations. Final approval is required from the Vice President-Nuclear Operations." Neither the licensee nor the inspector were able to locate any provision for abbreviated review and approval for NOPs. The licensee acknowledged that the approval of NOP 400 did not agree with the statements made in NOD 14 and stated that measures would be taken to ensure that the requirements of N0D 14 would be met in the future. Review of the revision to N0P 400 revealed that the change incorporated did not change the intent or content of the program; however, it was not clear whether other N0Ps were approved in a similar manner which may significantly affect operation of the Fermi 2 facility. Further review of other N0Ps associated revisions lant operations is considered to and investigation of the effects on be an Unresolved Item. (341/86022-01 p(DRS))

The inspector noted that the licensee used a Training Work Request (TWR) which may be initiated by any Detroit Edison employee as a means of identifying potential training topics or training deficiencies to the training department. Use of the TWR is addressed by Nuclear Operations Procedure NOT 020. NOT 020 stated that evaluation of the TWR shall be completed within a maximum of ten working day During the inspection, the licensee indicated that with regards to INP0 Training Program Accreditation, Fermi 2 had obtained accreditation for four training programs: reactoroperator(RO),

shiftsupervisor(SR0),non-licensedoperator,andshifttechnical advisor (STA). The licensee also stated that an INP0 site visit to review the remaining six training programs was scheduled for the week of October 6, 198 The licensee provided the following statistics regarding their licensed operator training programs:

License Type Year Number of Exams _G_iven % Passed SR0 1984 24 96 R0 1984 21 95 SR0 (SOA) 1984 5 100 SR0(restricted) 1984 2 100 SR0 and R0 (requal- 1985 47 87 writter)

SR0andR0(requd- 1985 47 83 performance)

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The inspection effort consisted of an investigation of the effectiveness of the licensee's training program content updates based on industry events and lessons learned during the operation and maintenance of the Fermi 2 facility and did not include an assessment of the licensee's training program. The inspector reviewed roughly 800 licensee Deviation / Event Reports (DERs) generated during the period April 1,1985, through July 3, 1986, to determine the effectiveness and timeliness of the licensee's method of updating the training program content for licensed operator While reviewing selected DERs, it was noted that root causes were identified sporadically. No apparent provision to note if the DER was due to personnel error or training deficiency was found. The licensee stated that DERs and LERs were trended by the Nuclear Quality Assurance group and that repetitive deficiencies were communicated to the Training group if deemed appropriate. The effectiveness of such a method to identify repeated events was unclear as indicated by the DER list provided to the inspector b. Licensed Operator Training Pr_ogram r _Uphtes Of the approximately 800 DERs reviewed, the inspector chose five ,

for further review:

DER NUMBER DESCRIPTION NP-85-0522 Simultaneous Deinerting of Drywell and Suppression Chamber NP-86-0041 Operations Failed to Notify QC NP-86-0058 Inadequate Review of Core Spray Pump & Valve Operability Test NP-86-0144 Failure to Report Technical Specification Fire Barrier Deficiencies NP-86-0165 OSL Entry Not Completed DER NP-85-0522 dealt with the simultaneous deinerting of both the drywell and suppression chamber in violation of Fermi 2 Technical Specification 3.6.1.8. The deinerting had been performed in accordance with procedure S0P 23.406 which was ultimately determined to be inadequate; however, operations personnel had failed to realize that they were in violation of the Technical Specifications (TS). As a result of the event, LER 85-069 was issued. Corrective action specified for this event as related to training, included notification of all shift personnel via Night Orders and placement of the LER into required reading. The inspector verified that these actions had been performe DER NP-86-0041 dealt with the failure of a Nuclear Shift Supervisor (NSS) to notify Quality Control (QC) to witness valve testing as specified on work order PN-21 985818. Associated

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corrective actions related to trainir.g included re-reading the pertinent procedure and placing errphasis on the importance of hold points. In addition, a memo discussing bypassed witness hold points was sent four months after the event to all NSSs, Nuclear Assistant Shift Supervisors (NASSs) and Nuclear Shift Operators (NS0s). The inspector reviewed the memo, but was unable to locate the associated required reading package containing the pertinent procedure 12.000.1 DER NP-86-0058 dealt with lack of detailed review of the Core Spray Pump and Valve Operability Test in that Operations personnel failed to properly plot test data per procedure requirements. Corrective actions associated with training included placing the DER into required reading. The inspector verified that the DER was placed into required readin DER NP-86-0144 dealt with fire doors that during a walk down were found to be " deficient" in that they did not close and latch properly. Corrective actions associated with training included " educating plant personnel of when and how to report a

' concern on fire doors," and noted that criteria for determining fire watch requirements rests with the NSS. Aside from general employee training, the. inspector was unable to identify this item in required reading or continuing trainin DER NP-86-0165 dealt with the failure of Local Leak Rate Test (LLRT) personnel to follow procedures associated with breaching fire doors and the failure of Operations personnel to note proppedopenfiredoorsintheOutofServiceLog(0SL).

Corrective actions associated with training included educating LLRT personnel on the appropriate procedures and to provide a matrix of fire doors and other doors addressed in TS. The inspector verified the training for LLRT personnel and verified that a matrix had been developed. No' discussion of the matrix was located in any required reading package Several methods of disseminating infoimation regarding recent events, whether they occur at Fermi 2 or elsewhere, were employed by the licensee. The official means of ensuring that licensed personnel were kept current on plant status was the continuing training which was conducted every sixth week for each shift; however, other methods of disseminating information included the following: night orders, required reading, urgent required reading, and memos to personnel.

! Required reading (RR) and urgent required reading (URR) were not i proceduralized. Discussion of how these packages were to be handled by personnel was addressed in a memo dated August 17, 1983, from the l Training Coordinator to licensed personnel. The memo stated that i urgent required reading and required reading were to be read prior to

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relieving the off-going shift and within seven days of receipt, respectively. Shift turnover checklists required that the on-coming shift review the urgent required reading book only. Completion of l

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both URR and RR were indicated by signing an acknowledgement sheet included with the reading packages. The required reading packages were withdrawn after 7 days. Late sheets were issued for personnel who had not signed the original acknowledgement sheet. Review of the acknowledgement sheets revealed that the shift technical advisors (STAS) and shift operations advisors (SOAs), who were non-licensed and licensed personnel, respectively, had not completed all the required reading packages issued during 1986. Discussions with the operations training coordinator indicated that URR and RR was only required for those individuals holding a current license. With regards to the SOAs, due to the extended outage period in early 1986, personnel who normally perform the SOA task were temporarily assigned to other duties which did not require them to be in the control roo As such, RR packages were not readily available for their revie Further discussion with members of the Training staff indicated that these individuals would not maintain their license The inspector expressed concern that the licensee's method of tracking those licensed personnel who had completed required readings did not ensure that all operators had read the required material prior to performing tasks addressed in the required reading packages. During a tour of the control room, the inspector noted that the NSS on duty had not signed the sheet '

associated with an urgent required reading package although the shift turnover checklist item which required reviewing the URR book associated with the turnover on the day the URR had been placed in the control room had been initialed as being complet The licensee stated that those items deemed appropriate were added to the continuing training which was given to shift personnel one week out of every six. The criteria for topic selection for incorporation into the continuing training was not identified by the inspector, Trainin L Ef

_fectiveness In order to assess the effectiveness of training updates, the inspector interviewed several reactor operators and senior reactor operator Interviewees stated that the quality and content of the training received was appropriate and generally net their needs. Several operators complimented the training staff and noted that the recent temporary assignment of a licensed individual to the training departnent should enhance the efforts of the training staff. With respect to the deficiencies j identified in the five DERs chosen for review, those personnel l interviewed stated that emphasis had been placed on the importance of closing doors and that they were aware of the Technical Specification section addressing fire doors; however, none of the interviewees recalled any increased attention being placed on missed hold points, inservice testing data evaluation, or containment requirement I

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The majority of personnel interviewed expressed a concern that training on plant modifications was generally not performe Interviewees stated that changes in valve lineups due to procedure revisions were discovered during performance of valve lineup or surveillance procedures as opposed to notification that a given safety related procedure had been revise Trainee Records The licensee filed training records according to training course as opposed to by individual trainee. As such, assembling training records for a given trainee was a tedious process; however, simulator training records were reviewed for several licensed operators. As a result of the review, the inspectors noted that the licensee's definition of the term " annual" was not compatible with the definition in the Technical Specifications. The TS defines annual as being at least once every 365 days, while annual training is conducted once within a 12 month cycle. The inspectors noted that annual required control manipulations for those individual training records reviewed were often performed in excess of 12 months. In the worst case, as many as 23 months may pass before the " annual" requirement was fulfilled. The meaning of the term " annual" as it applies to licensee operator requalification and training, in general will be forwarded to NRC Headquarters for resolutio Clarification of the term " annual" will be tracked as an Open Item (341/86022-02(DRS)).

4. Non-Licensed Staff _ Trajnjng _ Effectiveness and__Quali_fication J41400)

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Approximately 800 DERs were screened for their impact on training. The inspector identified 14 for further review:

DER NUMBER DESCRIPTION NP-85-0607 Bypassed QA inspection points

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NP-85-0610

" a a a NP-85-0614

" a " a NP-85-0615

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NP-85-0621

" " " a l NP-85-0622 a a " a NP-85-0626

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NP-85-0638

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NP-85-0651 a " a "

l NP-86-0136 l

NP-85-0436 Bypassed QA review

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NP-85-0526

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NP-85-0527

" " a NP-85-0527

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NP-85-0616

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l The root causes for the above DERs were lack of communication and personnel error. The licensee had developed a QA Awareness Cours Training was conducted by the QA section for personnel reviewing completed work packages, including supervisory staff. The QA trending program indicated a downward trend in these types of occurrences. Personnel who had received the training indicated that the training was complete and beneficial to their job. Craft personnel indicated that their only training in QA was from the GET program and required reading. They expressed interest in obtaining additional QA training. The QA Awareness program should be expanded to include craft and non-Detroit Edison personnel. This would maintain the current downward trend in personnel related quality assurance error The 0JT and craft qualification programs were reviewed with maintenance and instrument and control (I & C) training coordinators. The maintenance section had developed a formal 0JT program. Junior personnel accompanied senior personnel while learning assigned tasks. The crafts were certified by their foreman, on the job, as they performed the task. The program placed enphasis on procedure compliance, efficient and cost effective maintenance, conformance to ALARA, and use of tools and test equipment. A Maintenance Training Program Development Schedule was prepared yearly. The schedule provided direction and placed emphasis on completing outage related training. A review was made of the Maintenance Metrology Lab personnel qualifications. The technician was certified on each piece of measuring and test equipment (MTE). A list was maintained in the lab for all maintenance and contract personnel qualified to use MT Only those with current MTE training were issued the equipmen The I & C section used a similar approach in performing 0JT and qualifying their personnel. The inspector observed portions of surveillance test 44.010.120, "lRM E Channel Calibration; C51-K601E and C51-K601C." The personnel were knowledgeable on the procedure and qualified to perfonn the test. The I & C program was not as well defined and scheduled as observed for the maintenance progra I & C should review the maintenance OJT and qualification guidelines for improving their own progra The in-plant training coordinators indicated the Nuclear Operations Training (NOT) personnel were responsive to their needs. They met frequently and had discussions on what additional training should be provided by the NOT Departmen Based on the above observations, the following items should be considered for improvement:

The TWR process should be trended for items that may lead to long-term training need *

NOT instructors should be provided tine to evaluate in-plant training to determine the effectiveness and ensure the quality of training is maintained at a high level

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A direct feedback path between the craft and NOT instructors should be provided to ensure training concerns of the craft are not filtered out by in-plant supervisio . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraph . Unresolved Item _s Unresolved items are matters about which more infonnation is required in order to ascertain whether they are acceptable items, open items, deviations, or violations. Unresolved items disclosed during the inspecticn are discussed in Paragraph . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

on July 17, 1986, to discuss the scope and findings of the inspectio The licensee acknowledged the statements made by the inspectors with respect to items discussed in the report. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensea did not identify any such documents / processes as proprietar L