IR 05000341/1987016

Insp Rept 50-341/87-16 on 870406-24.Violations Noted:Failure to Implement Licensed Operator Requalification Program, Failure to Provide Accurate Info in License Renewal Applications & Failure to Follow Procedures

ML20214H539
Person / Time
Site:	Fermi
Issue date:	05/19/1987
From:	Bjorgen J, Burdick T, Hasse R, Dave Hills, Hopkins J, Huber M, Love R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214H498	List: IR 05000341/1987016 ML20214H496
References
50-341-87-16, NUDOCS 8705270411
Download: ML20214H539 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/87016(DRS)

Docket No. 50-341 License No. NPF-43 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI -48224 Facility Name: Enrico Fermi Nuclear Power Plant, Unit 2 Inspection At: Enrico Fermi 2 Site, Monroe, Michigan Inspection Conducted: April 6-24, 1987 Inspectors: R E l MM Date

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Date Approved By: Philli)s hief 5// Y Operational )rogra s Section Date

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Inspection Summary Inspection on April 6-24, 1987 (Report No. 50-341/87016(DRS))

Areas Inspected: 5)ecial announced safety inspection of the ade implementation of t1e licensed operator requalification program.quacy of Results: Three violations were identified: (1) violation of 10 CFR 50.54, failure to implement licensed operator re examples (Paragraphs 2.b.(3), , 2.b.(4).(b), and 2.c.(1)qualification 2.b.(4).(a) ; pro i

license renewal applications 10CFR50, Appendix 6,Criter(ionV,failuretofollowproceduresParagraph2.).(4).(c));a (Paragraph 2.c.(2)).

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DETAILS 1. Persons Contacted Detroit Edison Company

• F. Agosti, Vice President, Nuclear Operations

• G. Overbeck Director, Nuclear Training

• W. Tucker $uperintendent, Operations

• R. McLeod,, Supervisor, Nuclear Training Programs

• J. Kepus, Licensing

• S. Frost, Licensing

• Shuhla, Licensing

• NQA Schwartz, R. Bovinet, QA Supervisor, Supervisor, Nuc lear Training J. Coleman, Supervisor, Nuclear Training U.S. NRC

• J.Stefano,ProjectManager, Fermi 2

• C. Hehl Chief, Operations Branch, Region III

• M.Phillips, Chief,OperationalProgramsSection,RegionIII Other personnel were contacted as a matter of routine during the inspectio * Participated in the exit interview held on April 24, 198 . Licensed Operator Requalification Program This inspection was prompted by a notification from the licensee that an internal QA audit had determined that two licensed operators had not completed all of the reactivity manipulations required by the requalification program for 1984/85. The notification was followed by a meeting with the licensee on April 3, 1987 in the Region III office which resulted in the issuance of a Confirmatory Action Letter (CAL) (reference Paragraph 3). The purpose of this inspection was to determine the adequacy of the licensee's implementation of the requalification program and adequacy of actions taken in response to the CA The inspection was conducted by reviewing training records internal correctiveactions,licenserenewalapplications,QAauditsandresultant and implementing procedures, Requirements Section 50.54 of 10 CFR Part 50 requires that individuals who manipulate the controls of a nuclear reactor or direct such activities be licensed by the Nuclear Regulatory Commission in accordance with 10 CFR Part 55. Section 55.33 of 10 CFR 55 requires that each licensed individual demonstrate his continued competence

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every two years in order for his license to be renewed. Competence may be demonstrated, in lieu of re-examination, by satisfactory completion of a requalification program which has been reviewed and approved by the NRC. The requirements for the requalification Section 50.54 p(rogram are given in Appendix A to 10 CFR Part 55.i-1) of 10 CFR Par as specifically authorized by the NRC, make a change in an approved operator requalification program by which the scope, time allotted for the program, or frequency in conducting different parts of the program, is decrease The licensee's Licensed Operator Requalification Program (hereinafter referred to as the Program) was submitted to the NRC on March 14 The program is implemented by Administrative Guide (02-02-00-00), ,

198 " Licensed Operator Requalification." Withoneexception(see Paragraph 2.c.(1)) the guide accurately represents the requirements of the program. Since there are slight structural differences between the program and the Guide, and records are kept in accordance with the guide, the requirements discussed below are given in the terminology used in the guid The program requirements as implemented by the guide are as follows:

(1) Ac Sixunits(cycles)ofclassroominstructioneachyear.is equivalent to app Successful completion of each cycle is determined by passing a cycle examination with a grade of > 80%.

(2) Anannualwrittenexamination(Cycle 7). Successful completion requires a grade of > 70% on each topic with an average overall

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grade of > 80%.

(3) Reactivity mani ulations (Cycles 8-39). Each licensed individual must complete C cles 8-18 annually and Cycles 19-39 every two years using eit er the plant controls or the simulato (4) Annualsimulatorperformancedemonstration(Cycle 40). This is graded on a pass / fail basi (5) Any individual failing the annual written examination must be immediately removed from licensed activities and placed in a remedial program. In accordance with the program, successful completion of the remedial program requires a passing grade of

> 80% on the area (s) noted as failures in the annual examinatio The guide requires examination to the original criteria (see 2.a.(2) above). This discrepancy is discussed in Paragraph 2.c.(1).

As required by 10 CFR 50.54(i-1) and Appendix A to 10 CFR Part 55, each licensed operator must meet the requirements stated above to be current with the progra _ _ _ _ . _ _ _ _

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. Review of Licensee Audits The inspectors reviewed the Quality Assurance (QA) Audits that were performed on the requalification training program of Licensed Operators. The audits reviewed are listed below:

• " Audit of Nuclear Production Operators Personnel Training, Qualification and Requalification," Audit No. A-QS-P-85-09, April 10, 198 * " Quality Assurance Audit of Training Licensed Personnel and Requalification Training," Audit No. A-QS-P/TS-86-06, April 4, 198 * " Quality Assurance Audit of the Employee Nuclear Training Education anc' Verification Records Program," Audit No. A-QS-P/TS-87-05, March 31, 198 * " Quality Assurance Audit of License Renewals," Audit No. A-QS-S-87-013, April 10, 198 The audits were reviewed to determine:

• Audit findings

• Corrective actions neede * Corrective actions take * Timeliness of corrective actions take * Conformance to regulatory requirement (1) QA Audit No. A-QS-P-85-09 The scope of this audit was the evaluation of the adequacy and implementation of the minimum standards to be met in the training of specific Nuclear Production Personnel. The training, program, including requalification training, was reviewed to verify that training was being conducted in accordance with Nuclear Operations Directives Procedures. and Instruction Qualificationsof NuclearShiftSupervisors(NSS),NuclearAssistantShift Supervisors (NASS), and the Nuclear Shift Operators (NS0) were reviewed as well as the Training Program Descriptions (TPD),

Course Descriptions, Training Records, and the maintenance of requalification frequenc It was determined in the licensee's audit that the Licensed Operator requalification training was generally in accordance with requirements described in 10 CFR Part 55 Appendix A and the commitments in the FSAR Chapter 13.2. However, the audit did disclose three finding .

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(a) Audit Finding Report (AFR) A-QS-P-85-09-01 This finding noted a difference in the training requirements between TPD No. 710 "NRC License" and P0M 21.000.07

" Qualifications for Licensed Personnel," Revision 1. TPD No. 710 identified training requirements less stringent than those identified in the P0M procedure. This deficiency was corrected by May 4 1985, by revising P0M 21.000.07 tostatethatitwillbedoneinaccordance with TPD No. 709, Revision 6, " Shift Operator" which includes all requirements as well as those required by TPD No. 710. This finding was adequately corrected and closed out on July 1, 198 (b) AFR A-QS-P-85-09-02 and 03 These audit findings concerned the required reading"to be done by the operators, in accordance with EF0-8059 Required Reading Program," Revision 0. Sign-off sheets for " License Required" reading material were incomplete and the binders that enclosed the readings were incorrectly designated or complete These items were reviewed and corrected by May 29, 198 The required reading binders were updated and corrected, including full completion by the personnel required to read the material. Recurrence was arevented by requiring the review of the required reading ainders by the Operations Enginee These AFR s were closed out on October 10, 198 (2) Audit No. A-QS-P/TS-86-06 The purpose of this audit was to verify the implementation of various training programs for Licensed Operations personne No deficiencies were found in this audit. The AFR s from the 1985 audit were also reviewed and were found not to have recurre (3) QA Audit No. A-QS-P/TS-87-05 The scope of this audit was l'1 review of the Employee Nuclear Training, Education, and Verification Records Program. The audit disclosed that the program was being, implemented satisfactorily. However, there were deficiencies. AFR's A-QS-P/TS-87-05-10 and-11 identified discrepancies in the area of Licensed Operator Requalification Training. Training records for 100% of the licensed operators assigned to shift coverage, as of January 7, 1987 and five licensed trainers werereviewedtoensurethatallrequalificationtraininghad

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been administered within the required time interval. Contrary to the training recuirements, two Licensed Operators assigned to shift duties anc one trainer did not complete all of the reactivity control manipulations required by the program during the 1984/85 requalification cycle. The inspectors reviewed the corrective actions taken and found that the two individuals serving on shift com)leted the reactivity manipulations by 198 Thus, April 1, 1987, and t1e AFR was 1986 closed April 3,l 1, 1987, the to Apri during the time period January two operators were not current wi 1,th the program.The trainer was to complete the required manipulations during the next requalification cycle. This failure to implement the requirements of the program is considered a violation of 10 CFR 50.54 (i-1) (341/87016-01A). The deficiencies regarding the completion of required manipulations had been identified in an internal Training Department memorandum, on December 5, 1985 (prior to the end of the 1984/85 requalification cycle on December 31,1985). No action was taken to complete them until re-identified by the 1987 QA audi (4) Audit No. A-QS-5-87-13 This audit was conducted in response to CAL-RIII-87-03 (see Paragraph 3). The purpose was to ascertain the com)leteness and accuracy of the license renewal ap)lications su)mitted to the NRC. Several problems were found )y the QA Auditors:

(a) AFR A-QS-S-87-013-01 During review of 46 renewal applications, the following discrepancies were found:

- Requalification training Cycle 3,1985(3-85)

described in the program was not complete . Cycle 4-86 was not complete . The number of training weeks specified on the applications did not always agree with those documented in the Personnel Training History System (PTHS) for the applicable time fram . Not all required training was completed for the effective license period for some applicant Cycle 3-85 was cancelled so that operators could participate in plant valve line-ups. Twenty individuals did not complete Cycle 3-85. Equivalent training was not provided until June and July 1986. (This equivalent

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training was conducted as a result of recommendations made during an INP0 survey requested by the licensee.)

Thus, during the period January through July 1986, there were 20 licensed operators not current with the .

requalification program. This is another example of '

failure to implement the Program and is a violation of 10 CFR 50.54 (1-1) 341/84016-01B).

Cycle 4-86 was cancelled to allow operators to participate in the Cycle 3-85 equivalent training mentioned abov Cycle 4-86 will be completed during the balance of the 1986/87 requalification cycle. This will be tracked as an Open Item (341/87016-02). (The remaining deficiencies noted in this AFR are discussed further in Paragraph 2.b.(4)(c)).

(b) AFR A-QS-S-87-013-02 One individual identified as having failed the 1985 annua-1 requalification examination on November 15, 1985 returned to licensed duties on Novemb 4 29, 30, Decemoer 1 and December 6-14, 1985 prior to completing remedial training on December 18, 1985. The program requires that licensed individuals failing the annual examination be immediately removed from licensed duties until successfully completing remedial trainin Subsequent inspection revealed a second individual who failed the 1985 requalification examination had also served as a licensed operator on December 4, 1985, prior to completing remedial training. This failure to implement the requirements of the Pro exarrple of violation of 10 CFR 50.54(gram 1-1) is another (341/87016-01C).

(c) AFR A-QS-S-87-013-03 Two licensee renewal applications (NRC Form 398) were found which stated that the applicants had successfully completed the requalification program when, in fact, they had not at the time the applications were submitte Both applications were signed by the Director of Nuclear Training on November 13, 1985, and by the Vice President of Nuclear Operations on November 15, 1985. One applicant had failed the 1985 annual requalification examination on October 18, 1985 and did not successfully complete remedial training until December 20, 1985. The second applicant failed the annual simulator performance demonstration and walk through exam on November 8,1985 and did not successfully complete remedial training until

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December 19, 1985. Both licenses were renewed on December 10, 1985 based on the erroneous informatio However, the effective dates for the renewals were December 23 and 27, 1985, after successful remediatio In addition, as noted in Paragraph 2.b.(4)(a), a total of 26 renewal applications (including the two noted above)

submitted from June 1985 through March 1987 claimed credit for completion of requalification training cycles which could not be substantiated by the licensee's training records. Ir. total, 21 licensee renewals were granted based on applications containing erroneous informatio Section 55.33 of 10 CFR 55 requires that the application for renewal of a license contain a statement that during the effective term of his current license the application has satisfactorily completed the requalification progra Providing erroneous information supporting this claim for the 26 applications in considered a violation of 10 CFR 55.33 (341/87016-03).

c. Li_ censed Operator Requalification Training Program Implementation The inspectors conducted a review of the program against the implementing procedures to determine if all of the program commitments were addressed and the program properly implemente (1) Remediation Requirements AdministrativeGuide(02-02-00-00),"LicensedOperator Requalification," had remedial passing grade requirements that were less stringent than those stated in the progra The program stated that a licensed individual who received less than 80% on the annual exam, or less than 70% on any category of the annual exam shall be placed in an accelerated requalification program. He may return to his licensed duties following successful completion of those areas noted as failures on the written exam. Completion of this accelerated requalification training shall require a grade of not less than 80% on the examination given over the area (s) noted as failure (s). Contrary to the above, the Guide states "the trainee will be reexamined to the original criteria."

Subsequently, this difference resulted in one individual having remediated to the less stringent criteria. The individual had failed the examination with an overall score of less than 80% and failed one category with a grade of less than 70%. The individual was passed on the remedial exam with an overall score greater than 80%, but a score of less than 80%

on the previously failed category. This failure to implement the requirements of the program is considered another violation of 10 CFR 50.54(1-1) (341/87016-01D).

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(2) Staff Licenses A staff license as used here is defined as an operator license issued to an individual not normally performing the duties of a licensed operator; however, the individual is licensed to perform these duties at any time. Administrative Guide (02-02-00-00) requires in Section II.I that such staff licensees spend eight hours per month on shif t to maintain their familiarity with shif t operations. Further, a letter submitted to NRC Region III on February 25, 1986, requesting the renewal of three staff licenses noted that the individuals had not completed this on-shift time. It further stated that beginning in January 1986 all non-shift license holders would be required to spend a minimum of eight hours per quarter on-shift and that the three applicants would meet this requirement during the terms of their renewal license. A review of records indicated that these three individuals and one other staff licensee had not completed even the less stringent eight hours per quarter requirement for the period January 1,1986 to the present. Two had not completed the requirement for the third quarter 1986, one had not completed the requirement for the second, third, and fourth quarters of 1986 and the first quarter of 1987, and one had missed the third and fourth quarters of 1986. This failure to follow procedures is considered a violation of 10CFRPart50,AppendixB,CriterionV(341/87016-04).

(3) Maintenance of Requalification Status and Records The inspectors reviewed the licensed operator qualification status maintained by the Operations Department. During this inspection, the following documents and/or procedures were reviewed: N0P-400, " Nuclear Operations Training Program";

P0M-12.000.57, " Nuclear Production Organization"; "QA Audit of Training-Licensed and Non-Licensed Personnel and Requalification Training" Audit No. A-QS-P/TS-86-06; and

"QA Audit of the Employee Nuclear Training, Evaluation and Verification Records Program," Audit No. A-QS-P/TS-87-0 The inspectors attempted to trace the flow of information concerning licensed operator requalification status from the Trainir.9 Department to the Operations Departmen Section II.B.10 of N0P-400 delegates to Nuclear Training the responsibility for providing reports of individual and organizational unit training status and monthly projections of continuing training schedule requirements. Section 5.2.3.2 of P0M-12.000.57 states that the Assistant Operations Engineer (Staff) is responsible for ensuring prcper documentation of all licensed operator courses and requalification courses, for meeting regularly with Nuclear Training to review individual and class progress, to keep the Operations Engineer informed

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of licensed operator training and qualification status and to provide work direction to the Operator Training Coordinator to assure training requirements for licensed operators are me This flow of information was initially carried out in weekly or biweekly meetings between Nuclear 0]erations - Nuclear Training and Nuclear Production. A scledule and generic agenda for these meetings was distributed via internal memo. From April 1986 to the present, the information was transmitted using a weekly training status matri There was no procedural requirement to maintain records on the and meetingsbetweenNuclearOperations,NuclearTraining00 Nuclear Production. However, Section 11.8.9 of N0P-4 states that Nuclear Training is responsible for maintaining individual training records in the Personnel Training History System (PTHS).

The inspector reviewed QA Audits No. A-QS-P/TS-86-06 and A-QS-P/TS-87-05 to determine the status of any findings concerning the record retention of licensed operator requalification maintained by the Nuclear Operations Department. The scope of QA Audit 86-06 was to verify the implementation of various training non-licensed operations personne programs Checklist Itemfor licensed and No.11 reviewed the requirements of Section 5.2.3.2 of P0M-12.000.57 which described the Assistant Operations Engineer (Staff)

responsibilities for maintaining documentation of licensed operator requalification courses. The QA audit finding, based on an interview with the Assistant Shift Supervisor (NASS)assignedasTrainingCoordinatorandaNASSassigned as Operations Specialists, noted that the requirements appeared to have been covere The scope of QA Audit 87-05 was to assess the im)lementation of recuired training for Fermi 2 personnel and tie required recorcs to support the validity of training and job qualifications P0M-12.000.57 was not audited due to a lack of tim Discussions with licensee representatives revealed a lack of procedures to periodically review the requalification status of licensed personnel. This information is contained in the PTHS and is accessible by requesting a special repor Individuals in the Training Department currently send status reports to the Operations Department on a personal initiative basis. The licensee representatives indicated that they would correct these deficiencies in the revision to Administrative Guide (02-02-00-00), currently in preparatio _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ .

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3. Status of Confirmatory Action Letter As noted in Paragraph 1, a Confirmatory Action Letter (CAL) was issued as a result of a April 3,1987 meeting with the licensee. The status of these actions are given below: Submit to NRC, Region III, by April 7, 1987, an analysis of the substitutedtrainingwhichverifiesthatthelearningobjectivesfor Cycle 3 of your 1984-1985 Requalification Program have been met for all licensed operators that were required to have this trainin Status: Complet Reference Letters NRC-87-0026 dated April 7, 1987 and NRC-87-0030 dated April 10, 198 Complete the Cycle 3 training of your 1986-1987 Requalification Program for all licensed operators by May 15, 198 Status: On schedule, Certify to NRC, Region III, that all licensed operators performing licensed duties are current with respect the Requalification Progra Status: Complet Reference Letter NRC-87-0037, dated April 15, 198 Perform a 100% review of all applications submitted to the NRC in support of license renewals. Submit to Region III by April 10, 1987, the results of this revie Status: Complet Reference Letter NRC-87-0032 1987, Letter NRC-87-0045, datedApril30,datedApril10, 1987 and Paragraph 2.b.(4) of this repor . 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 An O on the part of the NRC or licensee or both.theinspectionisdiscussedinParagr a).

5. Exit Interview The inspectors held an exit interview with licensee representatives (denoted in Paragraph 1) on April 24, 1987. The inspectors summarized the purpose, scope and findings of the insaection. The licensee stated that the likely informational content of tie report would contain no proprietary informatio _ _ - _ _ _ _ _ _ _ - .