IR 05000341/1987023

Mgt Meeting Insp Rept 50-341/87-23 on 870609.Major Areas Inspected:Corrective Actions Taken Re Potential Violations Identified in Licensed Operator Requalification Program Insp Rept 50-341/87-16

ML20214X258
Person / Time
Site:	Fermi
Issue date:	06/12/1987
From:	Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214X251	List: IR 05000341/1987023 ML20214X250
References
50-341-87-23-MM, NUDOCS 8706160401
Download: ML20214X258 (13)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/87023(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 Meeting Location: Region III Office, Glen Ellyn, Illinois Meeting Conducted: June 9, 1987

Approved By: M. P. hillips, Chief 97 Operational Programs Section Date Meeting Sunmary .

Meeting on June 9,1987 (Report No. 50-341/87023(DRS))

Subjects Discussed: Corrective actions taken regarding the potential violations identified in the Licensed Operator requalification program inspection conducted at the Fermi Nuclear Power Station, Unit 2, and documented in Inspection Report No. 50-341/87016(DRS'. ,

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8706160401 870612 PDR ADOCM 05000341 0 PDR

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DETAILS

. Attendees Detroit Edison Company B. R. Silvia, Group Vice President, Nuclear Operations F._C. Agosti, Vice President, Nuclear Operations T. Randazzo, Director, Regulatory Affairs G. R. Overbeck, Director, Operator Training J. H. Flynn, Legal Department S. R. Frost, Licensing U. S. Nuclear Regulatory Commission C. J. Paperiello, Acting Deputy Regional Administrator C. W. Hehl, Chief, Operations Branch M. P. Phillips, Chief, Operational Programs Section T. M. Burdick, Chief, Operator Licensing Section R. S. Love, Reactor Inspector J. A. Grobe, Director, Enforcement Coordinator and Investigations Staff J. N. Kalkman, Investigator M. K. Fahey, Investigator Areas Discussed The licensee's presentation focused on the corrective actions which had been implemented to address the potential violations identified in Inspection Report No. 50-341/87016(DRS). The slides used in their presentation are attached to this report. The primary root causes for the failure to adequately implement the requalification program were identified as a lack of adequate administrative controls and a failure to recognize that cycle training was part of the requirements. The corrective actions to ensure adequate implementation of the requalification program were completed by June 3, 1987. Licensee representatives also indicated that all activities specified in the April 3,1987, Confirmatory Action Letter (CAL) had been complete The licensee noted that the text of the inspection report was in error in that cycle 5 of 1986 had been the cycle cancelled, and not cycle 4 as stated in the report. The licensee representatives indicated that this cycle would be completed prior to December 198 NRC representatives indicated that the processing of renewal applications, which had been held in abeyance based on the findings of the inspection, would now be resumed based on the amended information provided as a result of the CA NRC representatives stressed the seriousness of the problem, and stated that the programmatic changes made by the licensee would be inspected at a future date. It was stressed that there were no problems identified with the content of the requalification program, but only with its implementatio *

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In-the-discussion of the licensee's new provisions to waiver exams, a potential conflict with the regulations was identifie Fermi had adopted the provisions to only administer written tests on a biennial frequency, and had stated that a licensed instructor who prepared, administered, and graded the biennial exam could be waived from taking an exam during that time period. This waiver could only be used in one successive.requalification cycle. This practice would effectively allow the licensed instructor a four year period between taking a written requalification exam. However, the requirements of 10 CFR Part 55 indicate that a written exam will be taken during the requalification cycle (2 years). The NRC representatives indicated that this discrepancy will be forwarded to NRR for an interpretation which will then be provided to the license Attachment: DECO Presentation Regarding Potential Violations

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PGI5mtr1AL VIMJMGE ,

o Failure to inplement the requirements of 10 GR 50.54 (1-1)

(requalification program)

o Providing erroneous information on license renewal applications contrary to 10 G R 55.33 -

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o Failure to follow procedures contrary to 10 GR 50, Appendix B, Criteria V - - . . ,

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l FAIIBRE 'to DETJBERFF 'IHIt IUQUIRIBEBITS & 10 CFR 50.54 (1-1) .  !

Eranples I

.o 341/87016-01A During the time January 1,1986 to April 1, i 1987, two operators were not current with the program (missed reactivity manipulations)

o 341/87016-OlB During the period January through July 1986, there were 20 licensed operators not current with the requalification program (missed cycle 3-85)

o 341/87016-Olc 'IWo licensed operators returned to shift duties requiring a license before passing annual examinations o 341/87016-OlD One individual who failed an examination remediated to less stringent criteria Root C=ncos Inadegaate administrative controls during the requalification period Failure to recognize that cycle training coupletion was required in order to be current with the requalification progr Contributing Factors

\ Failure to adequately follow up on corrective action for reported deficiencie Failure to submit the modified program while making changes during INPO Accreditation perio Page 2

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Corrective Stana Which Have Been Taken and Bann1ts Achieved

. All missed reactivity manipulations have been coupleted. (April 1, 1 987) Additional training has been given to ensure all licensed operators are current and couplete with the 1984 - 1985 requalification program. (May 13, 1987) In conjunction with the revision to 10 CFR 55, the procedure, Requalification Program Administrators Guide, was revised and inplemented to provide the following missing administrative controls:

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o Allows use of waivers (May 26, 1987)

o Define the meaning of " current" with requalification progran (May 26,1987)

o Formalizes the couputer tracking method ard monthly report to plant operations (May 26,1987)

o Mandates senior management notification if progress is not satisfactory (June 3,1987)

o Requires annual internal training audit of conputerized system against selected hard copy training records to insure accuracy (May 26,1987)

o Establishes responsibilities and actions required when a licensed individual is found not to be "curret" with requalificatio (May 26,1987) Se Human Performance Evaluation System (HPES) was used to evaluate the missed reactivity manipulations event. The HPES report and casual factors chart was reviewed with Operator

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Training Instructor (May 25,1987) Approved and issued NOIP 11.000.116, " Training and

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Qualification" (Fermi Management Directive '10-01), (June 3, 1987)

nese steps have corrected known deficiencies ard have put in place tough administrative controls eliminating vague and conflicting requirements. Effectiveness of these steps are being monitore Corrective Stans 'Ihat Will be Taken to Avoid Further Viniations No additional corrective steps are required. NOIP 11.000.116

" Training and Qualification" will provide the inproved administrative controls for all training programs.

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PROVIDIIE ERRGEODS IEWCIORTION CII LIrmsnan jugEBEL APPDCM' IGE o 341/87-16-03 Twenty-one (21) licensee renewals were granted based on applications containing erroneous informatio Root P m ma Procedure describing how to fill out application ard assigning responsibility did not exist resulting in inadequate technical review and inconsistencie Corrective Stona Which Have Been Taken and Dannits Achieved Performed a 100% review of all applications submitted in support of license renewals submitted to Region III. (CAL item 4, April 10, 1987) Modified 27 of 46 previously submitted licenw application renewals. (April 30,1987)

'Ihese steps have corrected all known deficiencie Corrective Sten 'Ihat Will Be Taken to Avoid Furt_her Vinlation o Proceduralize the submittal process for NRC initial and renewal

license applications using NS as reviewer prior to submitta Draft has been written. (June 30,1987) .

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FAIIRHE 'to FfYHW Ppnmen3gs .

o 34/87016-04 A review of records indicated that three individuals and one staff licensee had not coupleted the less stringent eight hours per quarter requirement for period January 1, 1986 to the present. (Control Room On-Shift Time)

Root _Caus '

Organizational responsibility for tracking on-shift time not adequately identified resulting in incouplete documentatio Corrective S&mna Which Have han Taken and Dann1ts Achieved In conjunction with the revision to 10 CFR 55, the procedure Requalification Program Administrator's Guide was revised to delete the on-shift time, except where a licensee is required to be " active". (May 26,1987) Develop method within Operations to track who is on shift on any given day and maintain those records for training purposes (June 3, 1 987) .

'these steps removed an unnecessary Detroit Bilson requirenent and has significantly reduced the possibility of violation by non-shift personne Corrective Stan '1 hat Will Be Taken to Avoid Further Violation Develop method to record on-shift time reorted by operations in the conputerized tracking system (June 30, 1987).

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o 341/87016-02 Cycle 5/86 was cancelled to allow operators to participate in Cycle 3-85 equivalent training. Cycle 5-86 will be coupleted during the balance of the 1986/87 requalification cycl Se training subjects cancelled with Cycle 5/86 will ba irorporate$

into the remaining 1987 requalification period. (December 31, 1987)

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smens e CGFIEOs5 TEE ACTIM IEETWt ,

s. Ihbmit to lac, Region III, by April 7,1987, an analysis of the substituted training which verifies that the learning objectives for cycle 3 of your 1984-1985 Requalification Program have been met for all licensed operators that were required to have this trainin Status: Complete. Reference Letters IOC-87-0026 dated April 7, 1987 and Isc-87-0030 dated April 10, 198 b. Complete the Cycle 3 training of your 1986-1987 Requalification Program for all licensed operators by May 15, 198 Status: Complete. Reference Letters luc-87-0072 dated May 15, 198 .

c. Certify to isc, Region III, that all licensed operators performing licensed duties are current with respect to the Requalification Progra Status: Complete. Reference Letter E -87-0037, dated April 15, 198 d. Perform a 1004 review of all applications submitted to the 100 in support of license renewals. Submit to Region III by April 10, 1987, the results of this revie Status: Complete. Reference Letters 10C-87-0032, dated April 10,1987 and 10C-87-0045, dated April 30, 198 AIL ACTI M CGWLE15 i

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EEIFFICIE 'IO IEEPETIGE IEWCItr

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4 o 341/87016-01D One individual who failed an examination

. remediated to less stringent criteri In this instance, 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%. 'Ihe individual was passed on the remedial examination

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with an overall score of greater than 80% and a score of greater than 1

70% on all categorie l o Mr. Harold Denton's letter of March 28, 1980 specified:

'the criteria for regairing a licensed individual to i participate in apoelerated regualification shall be undified to be consistant with the new passing grade for issuance of a license; 80% overall and 70% each categor o NJREG 1021 Revision 3 of Septer:ber 1,1986 specified:

If a candidate fails one category of the written exam

(<704), but has an overall grade of >004 an1 satisfactorily completed the operating esams (if administered), the Region any waive those three categories of the written esam for which the candidate received >704 and the oral and si=nlator esaminations. 'this standard waiver is only appilcable for the first retake esa ! o Fermi's Submitted Requalification Program of March 14, 1984 specified:

Much licensed individual shall take an annual asas. A minimum overall grade of 806 with all individual category grades greater than oc egaal to 704 is require A licensed individual who receives an overall grade of less than 80% on the annual asam, oc receives a grade of less than 70% on any category of the annual exam shall be immediately relieved of all licensed duties and placed in an accelerated regnalification progra He may return to his licensed duties following suooessful completion of those areas noted as failures on the written esam. Completion of this accelerated repalification training aha11 require a grade of not less thm 80% on

esamination given over the area (s) noted as failure (s). .

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o Detroit Blison contends that the individual did fall the '

examination over the areas noted as failures. An overall score of greater than 80% was achieved. 'the individual was not tested to a less stringent requirenent but the most stringent, a full examination. 'Ihe written words in our submitted program and our administrative guide were not intended to be interrupted to be more restrictive than the requirements of Mr. Denton's letter nor as inplemented by NURBG 102 I I l Remedial Examination Selection , I l Criteria l l Overall l l l l Examination l Individual Category l l l Score l ficore l Darnifred Damarlial Rwamination l

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I I . I I l >80s l <70s l Category Examination l ;

I I I (>80s) 1 I I I I l <80s I >70s i New Examination l l

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<80s I <70s ! New Examination l l l l (>80s, >70%) l I I I I s

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Enemur .

/' o Detroit Edison agrees with the items identified in the inspection

. report 341/87016 except Item 341/87016-02, should be cycle 5-86 instead of cycle 4-8 , , ,

' Item 341/87016-01D (less stringent examination criteria)

/ / o / Detroit Edison's requalification program a5 ministration has been weak and lacked sufficient management attention.' Steps taken and 1 planned will strengthen the administrative controls and management attention include: Conpleted conprehensive review of hard copy operator training record . Corrected known deficiencie . Inplemented the revised procedure, Requalification Program Administrator's Guid I Drafted a procedure for coupleting license application < Assignment of an individual with operating experience to direct operator training activitie o 'Ihe content of the training program is excellent and has not been changed. 1 (

. Approximately 94 of 111 (or 85%) of those examined have passed Detroit Eison and NIC administered requalification examinations on their first attenp . ,Before it was mandated, Detroit Edison had always given an annual Operating Test because it is the best measure of an operator's ability to perfor o All action specified in the Confirmatory Action Letter dated April 3,1987 is couplet t

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o All licensed individuals are " current" with respect to their requalification progra /

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