IR 05000341/1988001
| ML20153F474 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 08/30/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20153F449 | List: |
| References | |
| 50-341-88-01, 50-341-88-1, NUDOCS 8809070310 | |
| Download: ML20153F474 (2) | |
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Enclosure 1 SALP 9 APPENDIX SALP BOARD REPORT
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50 341/88001 Inspection Report No.
Detroit Edison Company hame of Licensee
_ Fermi 2 Name of Facility l
April 1,1987 thrcuch l' arch 31, 1988 6s's'essment Period
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0009070310 890830 PDR ADOCK 05000341
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Enclosure _i_
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Fermi 2 l
A.
Sumary of Meeting with Detroit Ediso_n on July 22, 1988 The findings and conclusions of the SALP Board are documented in Report No. 50-341/88001 and were discussed with the licensee on July 22, 1988, at Monroe Comunity College.
While the meeting was primarily a discussion between the licensee and NRC, it was open to members of the public as observers.
The following licensee and hRC personnel were in attendance, as well i
as the noted observers.
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Detroit Edison
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W. J. McCarthy, CEO and Chairman of the Board l
B. R. Sylvia, Senior Vice President i
W. S. Orser, Vice President, huclear Operations S. G. Catola, Vice President, Nuclear Engineering and Services i
Nuclear Regulatory Concission A. B. Davis, Regional Administrator l
E. G. Greenman, Director, Division of Reactor Projects i
W. G. Rogers, Senior Resident Inspector l
R. W. Cooper, II, Chief, Section 3B l
M. J. Virgilio, Director, Projects Directorate III-I, NRR J. H. Sniezek, Deputy Director, NRR R. L. Spessard, Director, Division of Operaticnal Assessment, NRR T. R. Quay, Project Manager, NRR L. Kelly, Backup Project Manager, NRR J. W. Clifford, Region III Coordinator E00 N. B. Le, Performance Evaluation Branch, NRR B.
Coments Received frem Licensee Detroit Edison's response to the Fermi SALP 9 Board Report dated August 17, 1988, had no convents addressing the specific centent of the report.
Because there are no coments, this Appendix contains no changes to the SALP Report.
C.
Regional Adm_i_nistrator's Conclusions Based on Consideration of Licensee Comments
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I have concluded that the overall ratings in the affected areas have not change.
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e ENCLOSURE 2
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l s. n.+8 srw sen.or vice hes.oemi
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6400 Norm Disne H.ghasy Ed.ison=="^ *"
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August 17, 1988 NIC-88-0198 U. S. tbclear Regulatory Ccanission Attention: Docunent Control Desk Washington, D. C.
20555 References:
1)
Fermi 2 NIC Docket No. 50-341 NIC License No. NPF-43 2)
NBC Region III Ietter to Detroit B51 son, SEP 9 Board Report No. 50-341/88001 (DRP), July 11, 1988 Subj ect:
Resoonse to SAIP 9 Board Reoort Detroit B5'ison has reviewed the NBC SALP 9 Board Report ard has As was provided our response to the report in the erciosure.
requested in your transmittal letter, we have provided the specific corrective actions and coupletion dates to inprove our performance in the five areas assigned Category 3 ratings. All areas rata 5 Category 2 or 3 have been individually a5 dressed in thc tesponse.
He believe that many of the corrective actions and management initiatives put in place, particularly during the second half of the assessment perio$, will inprove our perfornance not only in the Category 3 areas but in the entire Fermi 2 organization As was note $ in the SMP 9 report, our perfornance during the secord half of the assessment perico did improve. However, we agree that aS$1tional effort is needed if we are to achieve and sustain a high level of performance in all areas.
We acknowledge that the N!C intertis to shorten the current SMP 10 assessant period to nine months, which will conclude on Decenber 31, 1988. We want to assure you that Detroit 351 son is committe$ to take the necessary actions and provide the dedicated resources to ensure a better rating at the conclusion of the SMP 10 period.
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Elf AUG 251988
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August 17, 1988
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E -88-0198
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We are prepared to discuss this SMP 9 Board Report response with you at your earliest convenience.
Sincerely,
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Enclosure cc: Mr. A. B. Davis Mr. R. C. Knop Mr. T. R. 02ay Mr. W. G. Rogers
/USt0C Region III
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Enclosure to
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A.
PLANT OPERATIONS
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As noted in the SALP report the following were identified as key areas needing improvement:
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1.
Operations personnel errors need to be reduced.
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from service.
operations personnel understanding of Technical
Specifications needs to be improved in actions required in a given condition and in the treatment of support eq'lipsent.
4.
Improvements in the area of operations administrative controls need to be sa:e.
The following actions have been taken, are underway, or are planned to improve operations performance in these key areas:
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Operstor error reduction:
In conjunction with Deviation Event Reporting, key events are 1.
investigated using the "Human Performance Evaluation System" to insure that in-depth corrective action is taken.
2.
Selected personnel errors result in accountability meetings which are held by the Plant Manager with those responsible for the event to ensure that they fully understand the
seriousness of the event and their personal responsibility.
The acetings provide feedback to all affected groups.
A series of operations Practice standards have been issued
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providing guidance to operations personnel on the framework with which they must carry out key activities. These standards emphasize principles required of a successful operation such as attention to detail, consunications and understanding of operating activities.
4.
A major procedure rewrite effort is currently under way to improve operating procedures. This project includes a priority system to ensure that operator comments are incorporated into appropriate procedures in a manner consistent with their importance. Details of the procedure upgrade effort have been communicated to the NRC in previous correspondence. We will complete this effort by December 31, 1988.
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Enclosure to NRC-88-0198 Page 2
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I Recent articles in the plant paper "The Moderator" and a
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video presentation by the Senior Vice President, Mr. Sylvia, emphasized the principles of attention to detail, and stressed the importance management places on employe performance and reducing personnel error.
Operator understanding and implementation of Technical Specifications:
A guideline is currently being developed to assist operators 1.
in assessing equipment operability requirements particularly in the area of dependance on support systems. This will be completed by September 1, 1988.
2.
A method has been developed to provide operators with These Technical Specification clarifications as necessary.
clarifications are intended to eliminate ambiguity, provide background material on specifloation intent and ensure that In operations actions are taken in a conservative manner.
some cases Technical Specification changes may be initiated through the Technical Specification Improvement program that is described in the section on Surveillance in this response.
A library of Technical Specification case histories has been
developed to support licensed operator training activities.
The case histories provide real or hypothetical plant situations that the student is asked to assess and determine required reports, applicable Technical Specification sections and required actions. The student is then provided with a detailed answer to the problem. These case histories are
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being used by training, and it is our intent to continue to
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add to thia library as experience dictates.
4.
Technical Specifications require a rapid response to some instrument failures. Therefore, preplanned instructions for placing such instruments in a tripped condition or taking other actions are currently being developed and will be issued by September 30, 1988.
Renoval and restoration of equipment from service:
1.
During outage periods turnover of Tagging Center personnel will be minimized to insure continuity of activities associated with renoval and restoration of plant equipment and improve consunications with maintenance personnel.
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Improved communications between Operations and Maintenance have been implemented to plan equipment outages a week in advance thus assuring better coordination of activities.
Additionally, a morning and afternoon meeting is held each
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i Enclosure to
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s day with representatives of each Production organisation and others as needed to review activities,
An ongoing effort to produce a library of preplanned tagging schemes is in place. This will ensure more thorough tagging research and eliminate the need to research tagging schemes each time a piece of equipment is removed from service.
4.
Procedures for removing key electrical equipment from service are currently being developed. Bose necessary to support planned activities during the first refueling outage will be complete before the start of that outage.
Administrative Controls:
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1.
Operations administrative procedures are currently being
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rewritten. A key objective of this effort is to reduce the number of procedures and consolidate information for ease of This effort will be completed by October 31, 1988.
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procedures are revised, training will be provided to ensure greater understanding of the revised procedures.
2.
The Operations Engineer is currently working closely with
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nenbers of the shift organization in an effort to review and l
audit each administrative system. Where appropriate, action
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is being taken to correct problems that are found. This review should be completed by December 31, 1938.
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Control room reference materials have been reviewed for need and status. Unnecessary material has been removed and the remainder relsbelled and updated as appropriate.
Management involvement in Operations activities:
1.
Both the Operations Engineer and Operations Superintendent have moved to offices located adjacent to the control room complex to provide easier access to the control room and ensure greater management involvement in ongoing operations activities.
2.
On a weekly basis the Plant Manager tours various plant areas with the Operations Superintendent or other members of the operations staff. Tours include discussion with various personnel about activities in progress.
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me Operations engineer holds special meetings with each shift as the need arises to talk about operator parforsane:
with regard to SALP, and WRC violations.
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NRC-88-0198 Page 4
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Senior management meets with each shift while the shift is in 4.
The meetings provide a forus to discuss shift training.
performance and operator and management concerns.
An Operations Evolution program has been implemented and will 5.
be continued through completion of the startup test program.
Evaluations are performed frequently by Operations Results of these evaluations are used to direct management.
specific corrective action and are closely monitored by Operations management and the Plant Manager.
An individual with SRO experience at another BWR has been 6.
assigned to assist the Operations Engineer in reviewing operations activities and in assisting in implementation of
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corrective action where necessary.
Curing periods of retraining on the simulator a sesber of
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Operations management and sentoir management monitors and evaluates shift performance in the simulator on a weekly Their consents and observations are fed back to the basis.
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shift during instructor critiques.
The above activities represent the key operations improvement activities in place and being pursued at this time. Operations management will continue to emphasize attention to detail and consistency of safe operations with emphasis on Technical Specification compliance and the elimination of personnel errors.
B.
RAD 10th01 CAL CONTROLS Four general areas of concern in the radiological controls area were noted in the SALP 9 Board Report.
Improvements to in-line chemistry instrumentation 1.
Cosaitsent to the BWR Owners Group Water Chemistry Guidelines 2.
Radiological confirmatory analytical seasurements 4.
Nonradiological confirmatory analytical sessurements Regarding improvements to the on-line analyzers, an extensive detailed scope to upgrade the sample panels and monitors to
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All state of the art equipment is currently in design.
engineering is anticipated to be complete by March, 1989 squipment needed to implement the first and most important
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design package is in procurement (feedwater corrosion product sample station).
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Although no formal consitment was made to the BWR Owner's Group Guidelines, Detroit Edison believes Fermi 2 Plant Order EFP-1094,
"Water Chemistry Guidelines", meets or exceeds the Owners Group Guidelines.
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Regarding non-radiological confirmatory measurements, analysis methods were adjusted to correct the problems noted during an Evaluation criteria for in-house comparison inspection visit.
data has been changed to allow earlier detection of siellar discrepancies.
Actions have been taken by the Chemistry group to correct high biases observed in interlaboratory cooperisons of sodius, low level boron and copper.
.i To enhance the Quality Verification Program, a new evaluation This method that is similar to the NRC nethod was implemented.
method will help us identify our problems quickly.
Discrepancies with radiological confirmatory measurements were caused principally by software problems which had been observed The problem sporadically in the weeks prior to an NRC inspection.
was corrected within a week after the inspection and within 2 months additional controls were implemented to provide early detection of similar problems.
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MAINTENANCE Significant management attention continues to be placed on the Preventive maintenance tasks for Preventive Maintenance Program.
Any safety-related equipment must be completed on schedule i
which results in an Engineering sv?'uation and management review.
A consultant knowledgeable in electrical circuit breakers and
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protective relaying is currently upgrading the preventivem j
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j the first refueling outage. We are currently pursuing further improvements to our Preventive Maintenance Program.
The Maintenance Planning for outages has been enhanced.
Update and Department has developed a Forced Ntage Schedule. Planning for the revision of this schedule is an ongoing effort.
first refueling outage has begun and an initial schedule has been
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WRC-88-0198 Page 6
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c We have revised the tracking and reporting systes for the corrective maintenance backlog to provide a better management tool Annunciators continue to and to conform to INPO guidelines.
receive a high level of management attention in order to sinimize the number of nuisance alaras.
l As part of the procedure update program, the effort to rewrite Maintenance and I&C procedures continues with oospletion expected by December 31, 1988.
I&C is establishing a supervisors surveillance program to provide for performance evaluations of surveillance procedures and testing 30,1988.
This program will be in place by September personnel.
Test boxes to facilitate obtaining required seasurements from test 31, 1988, continuing training plugs will be constructed by Augustis providing reviews of pr l
test equipment and working inside energised cabinets.
Prior to startup from the 1988 LLRT outage, 14C developed instrument valve lineup sheets for Technical Specification instruments and performed a dual verification of instrument valve i
I&C is expanding this lineup to include other
position.
The lineup will become a procedure safety-related instruments.
As an interia seasure, for use during the first refueling outage.
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instrument lineup sheets requiring independent verification are
being added to all t,,crk packages with the potential to reposition
valves not documented in existing procedures.
Significant managerial and Our efforts to improve are continuing.
organizational changes have been made in order to increase our effectiveness in maintaining a safe, reliable plant.
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D.
SURYEI11ANCE The 5 ALP 9 analysis based on eleven violations in the functional area of Surveillance indicated (1) inadequate technical procedure content, (2) deficiencies associated with the control of surveillance activities, and (3) implementation breakdowns.
Midway through the SALP 9 assessment period, previous efforts to
leprove the Surveillance Program had not been successful in that A Surveillance deficiencies and violations were continuing.
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Procedure Upgrade Program was developed which was later incorporated into a more comprehensive Technical Specifloation This program was described in our November
!aprovement Program.
l 23, 1987 letter (NRC-87-0252). Our April 6, 1988 letter As (NRC-88 0101) provided an update and status of this program.
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NRC-88-0198 Page 7
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i stated in the April 6 letter, this program will be completed by December 31, 1988.
The Technical Specification Improvement Progr:Am is identifying and correcting the types of problems that have been occurring in regards to (1) and (2) above - inadequate technical procedure content and scheduling errors. We have found and corrected over We are currently thirty deficiencies as a part of this progrim.
over 65% complete and would expect to find sore deficiencies Most of these deficiencies during the remainder of the program.
were found during the initial review step to assure that our procedures fully oosply with testing requirements to meet the At this time, it j
Technical Specification surveillance articles.
appears that this part of our Improvement Program may be completed by November 1, 1988.
Other elements of the Technical Specification Improvement Program
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should reduce personnel errors in both scheduling and performing the survelliance tests. This includes clarifying the intent and seaning of Technical Spacifications ar.d. in some cases, requesting
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changes in Technical Specifications. The effort to refine the
j administrative process for proper scheduling and documentation of surveillance tests and the generation of cross reference lists are t
administrative tools to improve compliance and reduce personnel errors and surveillance test implementation breakdowns. The i
special Technical Specification training, case study training, and feedback training are also elements of our Technical Specification Improvement Program that will reduce personnel errors and Other measures to surveillance test implementation breakdowns.
reduce personnel errors are addressed in Sections A and C of this response.
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The rewrite of the I&C surveillsnee procedures (44. series) which
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was completed during the assest.nent period appears to have been a
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successful effort that has reduced the number of reportable events
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such as ESF actuations during conduct of these surveillances. The setpoint calculation and verification effort completed by our
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Nuclear Engineering organization has also provided us sore
confidence in the technical adequacy of these procedures.
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In regards to the statement in the SALP 9 report about our l
schedular cosaltaents not being met for our Technical Specification Improvement Program, we informed you in our March l
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31, 1988 Updated Response to SALP 8 Board Report (NRC-88-0076)
that we were planning to extend the procedure review effort j
because we considered it more appropriate to correct the probless as they were found. Thus, we actually increased the scope of the j
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KRC-88-0198 Page 8
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We also want to clarify in this response Improvement Program.that certain actions in the Technical Specification Impro Program such as actual UFSAR changes, changes to the Technical Specifications, and required procedure changes fn11owing approval of Technical Specification changes will not be evapleted by the above mentioned December 31, 19 M date.
E.
FIRE PROTECTION The Category 2 rating indicates a satisfactory performance in the implementation of the fire protection program.
Continuing to provide adequate training for fire brigade personnel One of the 2 violations is one aspect of this progran commitment.
- noted in this SALP period was due to the improper scheduling of The schedule has been revised to periodic classroom instruction. ensure quarterly instructions are pro Detroit Edison commitment to regulatory guidelines.
The second violation was due to a valve not being maintained In response to locked, although it was in the correct position.
this occurrence, the Functional Operating Sketch (FOS) drawings for fire protection were revised to specifically identify those This action provides an valves that are required to be locked.
additional source document to determine locked valves in addition to the procedures.
The two The two minor issues from 1984 have since been addressed.
pressure gauges for the Reactor Building standpipes have been installed, and the energency lighting procedure revised, The revised energency lighting procedure calls for a full 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery discharge test of all lighting units required for fire At present, approximately 90% of these units have protection.
The testing completed to date exceeds the ainlaum been tested.
number (20% per year) to be tested to meet a previous commitment.
Housekeeping practices will continue to receive a high level of In place procedures and work practices help to attention.
minimize the time transient combustible materials are stored and to expedite waste removal. Periodic inspections conducted by Plant Safety, ISEG, NSRG, the Plant Manager and other management help to ensure housekeeping practices are maintained.
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WRC-88-0198 Page 9
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k E.
OUTAGES Ne intend to improve our performance during outages by better For scheduled outages this will be defining the outage scope.
accomplished by limiting the number of items to be worked and freezing the outage scope three months before the start of an
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Having a fixed outage scope will allow detailed outage outage.
schedules to be developed early in the process which in turn will allow more time to plan the work, prepare work packages and identify activities that have the potential to cause ESF l
With these activities identified, the work groups can actuations.
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factor appropriate cautions into their plans and conduct pre-job briefings with all required support groups.
For forced outages, a forced outage schedule has been developed
and is updated on an ongoing basis. Having a preplanned scope for forced outages has the same advantages as noted above.
Additionally, the planned outage process will be revised to incorporate "lessons 3 earned" in the area of operating shift work
dynamics.
l QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUA I.
he SALP 9 Board Report noted that management involvement and controls in assuring quality appeared to be minimal during the first part of the assessment period particularly in the area of
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audits and safety evaluations.
Management reviews were recognized as being weak and several f
The Nuclear changes have been made to strengthen this weakness.
I Safety Review Group (WSRG) has increased its involvement in the Nuclear Quality Assurance audit process by participating in some parts of the audits themselves, and by reviewing all audits upon
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completion. After review of the audit report, an evaluation is fed back to the audit group via NSRG Meeting Minutes. The audit group uses the input to make adjustments to the audit process.
De number of audit findings open longer than 180 days has been reduced to zero from a high of 150 in June 1986.
In an effort to
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be even more aggressive, management changed the Feral 2 Business Plan goal to be no findings open more than 90 days. At the
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present time there are only 15 audit generated DgRs older than 90 i
days.
De audit program has undergone a number of changes. De most l
significant was the change to be more performance based in the
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gnelosure to NRC-88-0198 Page 10
l More time is now spent preparing for the audit by j
audit process.
developing better checklists which have fewer items with more thought being given on how to conduct the verification in the More time is being spent by audit supervision on field.
A performance based seminar has been held to improve coaching.
the auditors' understanding of performance based auditing practices.
The checklist process has undergone several revisions during the i
In brief, the audit tsaa leader now signs off on the
completed checklist indicating that all checklist items have been last year.
accounted for and are complete or an explanation is given for not Checklist items are now prioritised, high completing the ites.
Checklist priority items must be oospleted during the audit.These checklists generally items are now more performance based.
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f consist of a series of summary statements extracted from the
f progras document rather than a cut and paste from a procedure.
Because of the effort to write more performance based audit f
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questions, the auditors are identifying more deficiencies that
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have real substance to them.
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As a The DER system is now used to document QA audit findings.
result, there are fewer requests for extensions to address l
findings, and the extensions that are submitted are for shorter
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The botton line is that the deficiencies identified periods.
during audits are being resol,ved such more rapidly than in 1987 To address weaknesses in the safety evaluation review and approval process, a consultant was hired to conduct additional classes in safety evaluations. The consultant was to continue until management ras satisfied as to the quality of safety evaluations.
He is still under contract to conduct training, but no longer j
reviews safety evaluations.
j Since the previous SALP report a number of management changes have i
Some of these changes include the Vice President taken place.
Wuclear Operations who was formerly the engineering Vice President, a new Plant Manager, Maintenance and Technical Superintendents, I&C Supervisor, QA and Licensing Directors and Vice President gngineering & Services (who is also NSRG chairman)*. All of these personnel have previous nuclear With the esperience and many have previous BWR experience.
addition of these new and experienced annagement personnel there has been renewed emphasis on more direct management involvesent in the day-to-day operations of the plant.
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NRC-88-0198 Page 11
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i In August 1988, an incentive program was put in place to improve De Nuclear Generation Management personnel performance.
Performance Progran provides monetary awards for the achievement of specified levels of performance and is designed to activate and stimulate employes to achieve continued improvement in individual performance and overall operation. The progran provides awards These seasures are based on achievement of performance measures.
the Feral Business Plan goals, Organizational Unit Business Plan
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goals, and individual Annual Work Plan goals. The program is directed at supervisory and management personnel.
Accountability is also emphasized up and down the line with
"accountability meetings" being held within Nuclear Operations and Nuclear Engineering for personnel errors and the use of Annual Work Plans and Performance Appraisals for across-the-board accountability of management and supervisory personnel.
include the issuance of Fermi Management
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Other efforts underway l
Directives (FMDs) and the rewriting of all procedures on site to A siallar simplify, consolidate and make then more user friendly.
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effort is also underway with the surveillance procedures utilized
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to verify compliance with the Technical Specifications, which is being coordinated with the Technical Specification Improvement (
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Program.
A new process using the Deviation Event Reporting (DER) systen has also been initiated to provide a single means to document, assign, evaluate, correct, verify, status, track and maintain all internally and externally identified deficiencies and industry
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issues including NBC, INPO, ANI, GE and others. h is process, not only allows all of these deficiencies to be identified on one document, but also establishes priorities for the evaluations and corrective measures as determined by the Plant Manager.
Additionally, the program substantially lowers the threshold upon j
which deficiencies are written. Long ters this process should help to assure better documentation and timely completion of corrective actions.
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LICENSING ACTIVITIES
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he Licensing area was rated a Category 2, the same as in the
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The SALP analysis recognised improvements during
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previous period.
the period, but sentioned additional improvements could still be I
achieved in the planning, timeliness and quality of submittals.
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Fermi 2 management recognises that not only does the improved l
performance have to be maintained, but that sustained efforts are
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NRC-88-0198 Page 12
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t The Licensing necessary to achieve desired further improvements.
group's goals include timely NRC submittals and preparation of A reduction in accurate and thorough License Amendment requasts. Greater emphasis
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requests for additional information is espected.
is being placed on responsiveness to NRC initiatives and achieving a good working relationship with all NRC representatives.
In order to direct more management attention to licensing The activities, the Licensing Group has been reorganized.
Director, Nuclear Licensing now reports directly to the Vice President level of management. 2 1s facilitates more insediate The upper level management attention to licensing problems.
position of Supervisor Compliance and Special Projects has been
added to the licensing organization. This individual will in part l
act to focus prompt management attention on inspectors' concerns.
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these organization changes will leprove Feral 2's responsiveness to all NRC issues.
DetroitEdisonappreciatestheefforkNRRhasprovidedinreview of proposed Technical Specification ohanges, especially those resulting from the Technical Specification Improvement Program.
Fermi 2 personnel are willing and eager to meet with the NRC to resolve any questions that arise on Technical Specifications or other matters and on a routine basis for discussion of licensing activities.
E.
TRAINING AND QUALIFICATI0W DTECTIVENESS Detroit Edison accepts the analysis and conclusions of the SALP 9 Board. During the evaluation period, Detroit Edison's training and qualification programs have improved, building on the The j
corrective actions taken as a result of the previous SALP.
aajor emphasis has been on tighter administrative controls and j
implementation of INPO accredited training programs.
The licensed operator requalification program corrective action Close management attention and internal has been effective.
program reviews provide assurance that the training program is being implemented as required. In addition, all administrative procedures in this area have been revised to provide standardisation and the control nochanian to ensure cortsistency in performance.
Significant effort has gone into improving the technical quality of operator training programs. The simulator model has been enhanced based on plant events and operators retrained. This form of corrective action has been very effective and well received by
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NRC-88-0198 Page 13
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our operators. De operators have been trained on the energency operating procedures based on revision four of the BWR Owner's Bis training has increased Group esergency procedure guidelines.
the ability and confidence of every operatir4 shift to respond to an energency, and will enhance their ability to protect the health Licensed operators have also received and safety of the publio.
training on the licensing and engineering basis behind technical specifloations. hese improvements have been monitored by plant and senior management during routine simulator performance evaluation. R is management overview has provided additional guidance to the operating shifts and inJtant feedback to the training organization.
Considerable effort is in progress to improve the technical
The task list uJed to quality of operator training programs.
develop operator treining programs is presently under review, and will be completed by hecember 31, 1988. ne job task analysis associated with this effort will result in some modification to the operator training program. Modifications to the operator training program will be implemented by April 30, 1989 These enhancements should significantly improve the training material.
In addition, systems training material is being reviewed and updated as the training material is placed into our new training document inder systen to control that material. Also, steps have been taken to convert licensed operator testing methods to conform with the new requalification examination process.
The accredited training programs for maintenance personnel are being implemented.
In addition, environmental qualification
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progran requirements were added to two courses; "Information and Retrieval", and "Prints, Records and Drawings". Maintenance craft and first line supervisors are enrolled in the Maintenance accredited training.
A supervisory training course has been developed and will be taught beginning in early September. The course teaches supervisory skills but has been tailored to the special needs of
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personnel working in a nuclear environment. The course is intended to establish a nuclear attitude that is more quality
conscious and to increase the awareness of administrative controls
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that affect quality and safety.
Initially, it will be offered to approximately 60 first line supervisors which includes maintenance i
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general and assistant foreaan, j
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NRC-88-0198 Page Ill
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ENGINEERING / TECHNICAL SUPPORT - CATEGORY 3 A Category 3 rating in this area is enacceptable performance to Detroit gdison.
Improvements in the Pgf %ering area have been
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made and will continue in order to prav M effective technical i
support to the plant.
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'the SALP Board points out that Detroit gdison annagement attention 1s required to further integrate the engineering function into the
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support of plant operations, to provide consistency in the resolution of technical issues within engineering and to encourage l
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engineering to become more proactive in anticipating plant
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problems.
i The SALP-9 report recognized that staff.tng was adequate, while approach to resolution of problems, responsiveness to NRC Overall initiatives and management involvement were mixed.
technical support to operations also needs further improvement.
Over the last year, several corrective actions have been taken and i
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progress is being made by Nuclear Engineering in effectively supporting the operation and saintenance of Fersi. Some examples
include l
In October 1987, the former flant Manager was made General
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o Director - Nuclear Engineering bringing with his the This
knowledge of plant operations to Nuclear Engineering.
t has been effective in reorienting Engineering thinking toward plant support.
Increased the Plant Support Engineering (PSE) function by f
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doubling the size of the PSE group and providing essentially round-the-clock plank coverage since January 1988. The PSEs i
are located inside the plant and interface closely with the l
Technical, Operations and Maintenance personnel and provide
I feedback to appropriate Nuclear Engineering disciplines.
Started daily Nuclear Engineering Staff meetings (General o
Director and all Nuclear Engineering Supervisors) reviewing
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plant operational probicas and ensuring that resolutions are These accurate and are completed in a timely manner.
meetings were espanded to include'all engineering supervisors in order to transmit management philosophy and desires more readily, the High Pressure Coolant Injection (HPCI) pection (SS Self initiated Safety Syste uncti mal Ins o
system in the
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NRC-88-0198 Page 15
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i later part of 1987. mis proactiva initiative confirmed the
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adequacy of the overal; plant design process, operations and management controls of the systes. Minor discrepancies ure l
identified and corrected. Current plans are to continue with l
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SSFI's on other systems.
Improvements were made in the performance and document 4 tion o
of safety evaluations ensuring consistent and proper resolution of technical issues. This was done through special training and monitorin5 Plant modifications have been designed and installed to o
For assist in reducing ESF actuations and other LER's.
example, a modification to the gaergency Equipment Cooling
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Water (EECW) system was made which permitted shifting of the
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Reactor Building Closed Cooling Water (RBCCW) systes pumps
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without actuation of the EECW systes. Also, the delay volume of the Reactor Water Cleanup (mlCU) systaa was removed in order to reduce the RWCU probleas being caused during reactor i
vessel depressurization.
Wuclear Engineering is working with Nuclear Production in j
o establishing prioritization of proposed design modifications
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l up to and including the first refueling outage in order to ensure Nuclear Engineering is applying resources where plant aansgesent and regulatory comaltaents will best be served.
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Increased management attention on plant and inW:,try problens j
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and NRC initiatives. Estaples include support of the o
Technical Specification Improvosent Program, and increased i
l effort in dispositioning Significant Operating Esperience
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l Report (30ERs), regulatory action items, DgRs, Temporary i
l Modifications and Annunciators /Cf.!S-dots.
Administrative proce M os and training are being upgraded to f
encourage engineering personnel to become more proactive in j
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anticipating plant problems. Supervisors and techr.ioal i
i personnel are held accountable foe up-front interface with f
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Nuclear Production and ths on site A/E counterpart on plant l
problems or concerns and to continue the interfaces while
f proposed modification packages are developed and
i implemented. Walkdowns on equipment and systems have been I
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encouraged as well as review of equipment /systes performance
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history to detect degradation.
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t Accountability meetings have been held to review personnel o
pe-formance problems. Root causes were identified and cotractive actions taken.
A senior Engineering supervisor is participating in SRO o
training program to increase knowledge of plant operation.
He will complete training ma4 return to Nuclear Engineering.
A Chief Engineer was hired and will begin in September 1988 as General Director. He was in a leadership position in the Engineet'Ing organisation of an operating plart. He will bring with him the skills to laprove timely and consistent resolutions to plant and engineering probless, Consolidation of Material Engineering, Nuoisar Procurement o
and Warehousing into one organisation, Nuclear Material Management, to improve the spare and replacement I
parts / equipment management. This was completed in June i
1988. The Director of this group reports directly to the l
Vice President, Nuclear Engineering and Services, The Technical Engir.eer position has been filled by an o
individual with operating experience who had an SRO license.
A Systen Engineering group is being put into effect in the o
plant Technical Engineering section, this group will provide engineering services to all Feral organisations in regard to the correct operation of systems. The group is being modeled after INPO guidelines and other plants with successful systes engineering groups. A supervisor for the group has been l
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hired with ten years of engineering and operational l
experience at operating reactors. The size of the group is l
being approximately doubled. A better definition of I
l workscope and an expansion of Juties and responsibilities are l
also being made. These actions will crc. ate a group of experts on Fermi systems who are committed to support all groups in the safe operation and maintenance of the plant, as well as serve as the dedicated interface between Operations, Maintenance, and Nuclear Engineering. The goal is to have the group staffed by December 31, 1988, dependent on the availability of qualified people.
In addition, a review of the nuclear material management o
process and the Nuclear Engineering / Technical Group interface is being ande by an outside consultant. The review is intended to help us assess the working interface between the
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l Nuclear Engineering and %hnical Group, and to make improvements to the an'+eiel management programs.
The above corrective actior+ d11 continue to taprove gngineering and Technical efficiency ans effectiveness in supporting Nuclear Production.
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