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 N Detroit Edison Company hame of Licensee
_ Fermi 2 Name of Facility
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l April 1,1987 thrcuch l' arch 31, 1988
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6s's'essment Period l
l 0009070310 890830 PDR ADOCK 05000341 0 PNU
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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 Colleg While the meeting was primarily a discussion between the licensee and NRC, it was open to members of the public as observer 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 repor Because there are no coments, this Appendix contains no changes to the SALP Repor C. Regional Adm_i_nistrator's Conclusions Based on Consideration of Licensee
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Comments I have concluded that the overall ratings in the affected areas have not change .
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ENCLOSURE 2 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. 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 provided our response to the report in the erciosure. As was 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 tespons 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$1tional effort is needed if we are to achieve and sustain a high level of performance in all area We acknowledge that the N!C intertis to shorten the current SMP 10 assessant period to nine months, which will conclude on Decenber 31, 1988. We want to assure you that Detroit 351 son is committe$ to take the necessary actions and provide the dedicated resources to ensure a better rating at the conclusion of the SMP 10 period.
a f&$ Elf AUG 251988
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August 17, 1988 ,
. E -88-0198 Page 2
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We are prepared to discuss this SMP 9 Board Report response with you at your earliest convenienc
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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NRC-88-0198 Page 1
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- PLANT OPERATIONS I
As noted in the SALP report the following were identified as key areas needing improvement: l
) Operations personnel errors need to be reduce Improvements are needed in removing and restoring equipment f from servic operations personnel understanding of Technical Specifications needs to be improved in actions required in a given condition and in the treatment of support eq'lipsen . Improvements in the area of operations administrative controls need to be sa: 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 investigated using the "Human Performance Evaluation System" to insure that in-depth corrective action is take . 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 responsibilit The acetings provide feedback to all affected group A series of operations Practice standards have been issued ,
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 activitie . 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 I correspondence. We will complete this effort by l December 31, 1988.
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I Recent articles in the plant paper "The Moderator" and a )
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 erro l Operator understanding and implementation of Technical ;
Specifications: 1 A guideline is currently being developed to assist operators l in assessing equipment operability requirements particularly in the area of dependance on support systems. This will be l completed by September 1, 198 . A method has been developed to provide operators with Technical Specification clarifications as necessary. These clarifications are intended to eliminate ambiguity, provide background material on specifloation intent and ensure that operations actions are taken in a conservative manner. In some cases Technical Specification changes may be initiated through the Technical Specification Improvement program that is described in the section on Surveillance in this respons A library of Technical Specification case histories has been developed to support licensed operator training activitie 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 add to thia library as experience dictate . 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, 198 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 personne . Improved communications between Operations and Maintenance have been implemented to plan equipment outages a week in advance thus assuring better coordination of activitie Additionally, a morning and afternoon meeting is held each
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Enclosure to NRC-88-0198
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day with representatives of each Production organisation and others as needed to review activities, 3 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 servic . 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 outag Administrative Controls: ,
' Operations administrative procedures are currently being rewritten. A key objective of this effort is to reduce the number of procedures and consolidate information for ease of As use. This effort will be completed by October 31, 198 procedures are revised, training will be provided to ensure greater understanding of the revised procedure . The Operations Engineer is currently working closely with [
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
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review should be completed by December 31, 193 (
f 3 Control room reference materials have been reviewed for need and status. Unnecessary material has been removed and the remainder relsbelled and updated as appropriat Management involvement in Operations activities: 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 activitie . 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
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' personnel about activities in progres 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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Enclosure to NRC-88-0198
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Page 4 4 Senior management meets with each shift while the shift is in training. The meetings provide a forus to discuss shift 7 performance and operator and management concern . An Operations Evolution program has been implemented and will be continued through completion of the startup test progra Evaluations are performed frequently by Operations management. Results of these evaluations are used to direct specific corrective action and are closely monitored by Operations management and the Plant Manage . An individual with SRO experience at another BWR has been assigned to assist the Operations Engineer in reviewing operations activities and in assisting in implementation of '
corrective action where necessar Curing periods of retraining on the simulator a sesber of
. i Operations management and sentoir management monitors and evaluates shift performance in the simulator on a weekly basis. Their consents and observations are fed back to the ,
shift during instructor critique 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 error RAD 10th01 CAL CONTROLS Four general areas of concern in the radiological controls area were noted in the SALP 9 Board Repor . Improvements to in-line chemistry instrumentation Cosaitsent to the BWR Owners Group Water Chemistry Guidelines
Radiological confirmatory analytical seasurements Nonradiological confirmatory analytical sessurements
' Regarding improvements to the on-line analyzers, an extensive detailed scope to upgrade the sample panels and monitors to All state of the art equipment is currently in desig engineering is anticipated to be complete by March, 1989 squipment needed to implement the first and most important
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Enclosure to
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design package is in procurement (feedwater corrosion product
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sample station).
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 inspection visit. Evaluation criteria for in-house comparison data has been changed to allow earlier detection of siellar discrepancie Actions have been taken by the Chemistry group to correct high biases observed in interlaboratory cooperisons of sodius, low level boron and coppe .i To enhance the Quality Verification Program, a new evaluation This method that is similar to the NRC nethod was implemente method will help us identify our problems quickl Discrepancies with radiological confirmatory measurements were caused principally by software problems which had beenThe observedproblem sporadically in the weeks prior to an NRC inspectio was corrected within a week after the inspection and within 2 months additional controls were implemented to provide early detection of similar problem t MAINTENANCE Significant management attention continues to be placed on the Preventive Maintenance Program. Preventive maintenance tasks for Any safety-related equipment must be completed on schedule i
which results in an Engineering sv?'uation and management revie A consultant knowledgeable in electrical circuit breakers and )
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protective relaying is currently upgrading the preventivem j the first refueling outage. We are currently pursuing further improvements to our Preventive Maintenance Progra Planning for outages has been enhanced. The Maintenance Update and Department has developed a Forced Ntage Schedule. Planning for the revision of this schedule is an ongoing effor first refueling outage has begun and an initial schedule has been
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Enclosure to
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WRC-88-0198
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c We have revised the tracking and reporting systes for the corrective maintenance backlog to provide a better management tool and to conform to INPO guidelines. Annunciators continue to receive a high level of management attention in order to sinimize the number of nuisance alara l As part of the procedure update program, the effort to rewrite Maintenance and I&C procedures continues with oospletion expected by December 31, 198 I&C is establishing a supervisors surveillance program to provide for performance evaluations of surveillance procedures 30,1988.and testing personne This program will be in place by September Test boxes to facilitate obtaining required 31, 1988,seasurements from test continuing training l
plugs will be constructed by Augustis providing reviews of pr ;
test equipment and working inside energised cabinet Prior to startup from the 1988 LLRT outage, 14C developed instrument valve lineup sheets for Technical Specification i instruments and performed a dual verification of instrument valve
position. I&C is expanding this lineup to include other The lineup will become a procedure safety-related instrument As an interia seasure, !
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for use during the first refueling outage.
- instrument lineup sheets requiring independent verification are
being added to all t,,crk packages with the potential to reposition valves not documented in existing procedure Significant managerial and Our efforts to improve are continuing.
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organizational changes have been made in order to increase our effectiveness in maintaining a safe, reliable plan 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 breakdown ;
Midway through the SALP 9 assessment period, previous efforts to leprove the Surveillance Program had not been successful in that deficiencies and violations were continuing. A Surveillance
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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 Progra I l 23, 1987 letter (NRC-87-0252). Our April 6, 1988 letter As l (NRC-88 0101) provided an update and status of this progra !
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Enciccuro to NRC-88-0198
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stated in the April 6 letter, this program will be completed by December 31, 198 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 We over are currently thirty deficiencies as a part of this progri l over 65% complete and would expect to find sore deficiencies during the remainder of the program. Most of these deficiencies were found during the initial review step to assure that our procedures fully oosply with testing requirements to meet the j Technical Specification surveillance articles. At this time, it appears that this part of our Improvement Program may be completed by November 1, 198 l Other elements of the Technical Specification Improvement Program '
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 j
changes in Technical Specifications. The effort to refine the ;
t administrative process for proper scheduling and documentation of surveillance tests and the generation of cross reference lists are administrative tools to improve compliance and reduce personnel i errors and surveillance test implementation breakdowns. The 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 surveillance test implementation breakdowns. Other measures to reduce personnel errors are addressed in Sections A and C of this l
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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 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
Nuclear Engineering organization has also provided us sore j confidence in the technical adequacy of these procedures.
l In regards to the statement in the SALP 9 report about our l
schedular cosaltaents not being met for our Technical l
l Specification Improvement Program, we informed you in our March j
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 ;
j as they were found. Thus, we actually increased the scope of the l
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KRC-88-0198 .
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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 dat FIRE PROTECTION The Category 2 rating indicates a satisfactory performance in the implementation of the fire protection progra Continuing to provide adequate training for fire brigade personnel is one aspect of this progran commitment. One of the 2 violations *
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 guideline The second violation was due to a valve not being maintained In response to locked, although it was in the correct positio this occurrence, the Functional Operating Sketch (FOS) drawings for fire protection were revised to specifically identify This action those provides an valves that are required to be locke additional source document to determine locked valves in addition to the procedure The two The two minor issues from 1984 have since been addresse 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 protectio At present, approximately 90% of these units have been tested. The testing completed to date exceeds the ainlaum number (20% per year) to be tested to meet a previous commitmen Housekeeping practices will continue to receive a high level of attention. In place procedures and work practices help to 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 maintaine , - - - _ - - - - - - - - - - -
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Encicsuro to WRC-88-0198
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Page 9 k OUTAGES Ne intend to improve our performance during outages by better defining the outage scope. For scheduled outages this will be accomplished by limiting the number of items to be worked and
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freezing the outage scope three months before the start of an outage. Having a fixed outage scope will allow detailed 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 actuations. With these activities identified, the work groups can
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factor appropriate cautions into their plans and conduct pre-job briefings with all required support group 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 abov Additionally, the planned outage process will be revised to incorporate "lessons 3 earned" in the area of operating shift work 1 dynamic l QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUA 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 '.
audits and safety evaluation I Management reviews were recognized as being weak and several f changes have been made to strengthen this weakness. The Nuclear I Safety Review Group (WSRG) has increased its involvement in the Nuclear Quality Assurance audit process by participating in some
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parts of the audits themselves, and by reviewing all audits upon 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 proces 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 be even more aggressive, management changed the Feral 2 Business
' Plan goal to be no findings open more than 90 days. At the present time there are only 15 audit generated DgRs older than 90 i
day 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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l audit process. More time is now spent preparing for the audit by j developing better checklists which have fewer items with more thought being given on how to conduct the verification in the fiel More time is being spent by audit supervision on coachin A performance based seminar has been held to improve the auditors' understanding of performance based auditing practice *
The checklist process has undergone several revisions during the i last yea In brief, the audit tsaa leader now signs off on the completed checklist indicating that all checklist items have been accounted for and are complete or an explanation is given for not completing the ites. Checklist items are now prioritised, high Checklist priority items must be oospleted during the audit.These checklists generally ,
items are now more performance base f
consist of a series of summary statements extracted from the f progras document rather than a cut and paste from a procedure.
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Because of the effort to write more performance based audit f
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questions, the auditors are identifying more deficiencies that !
have real substance to the l I
As a The DER system is now used to document QA audit finding !
result, there are fewer requests for extensions to address l findings, and the extensions that are submitted are for shorter '
periods. The botton line is that the deficiencies identified 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 evaluation :
He is still under contract to conduct training, but no longer j reviews safety evaluation j i
Since the previous SALP report a number of management changes have taken place. Some of these changes include the Vice President 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 experienc 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 plan .
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In August 1988, an incentive program was put in place to improve De Nuclear Generation Management personnel performanc 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.
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the Feral Business Plan goals, Organizational Unit Business Plan goals, and individual Annual Work Plan goals. The program is directed at supervisory and management personne 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 personne Other efforts underway include the issuance of Fermi Management
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l Directives (FMDs) and the rewriting of all procedures onAsite to siallar simplify, consolidate and make then more user friendl !'
effort is also underway with the surveillance procedures utilized to verify compliance with the Technical Specifications, which is (' being coordinated with the Technical Specification Improvement Progra 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 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 Manage j Additionally, the program substantially lowers the threshold upon which deficiencies are written. Long ters this process should help to assure better documentation and timely completion of corrective actions.
' LICENSING ACTIVITIES !
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he Licensing area was rated a Category 2, the same as in the >
previous period. The SALP analysis recognised improvements during I the period, but sentioned additional improvements could still be
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achieved in the planning, timeliness and quality of submittal 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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t The Licensing necessary to achieve desired further improvement group's goals include timely NRC submittals and preparation A reduction of in accurate and thorough License Amendment requasts. Greater emphasis '
requests for additional information is especte is being placed on responsiveness to NRC initiatives and achieving a good working relationship with all NRC representative In order to direct more management attention to licensing activities, the Licensing Group has been reorganized. The 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 problem ;
position of Supervisor Compliance and Special Projects has been l added to the licensing organization. This individual will in part ,,
act to focus prompt management attention on inspectors' concern these organization changes will leprove Feral 2's responsiveness to all NRC issue DetroitEdisonappreciatestheefforkNRRhasprovidedinreview of proposed Technical Specification ohanges, especially those resulting from the Technical Specification Improvement Progra 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 activitie 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 corrective actions taken as a result of the previous SAL j j
aajor emphasis has been on tighter administrative controls and implementation of INPO accredited training program The licensed operator requalification program corrective action has been effective. Close management attention and internal 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 performanc 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 l
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our operators. De operators have been trained on the energency operating procedures based on revision four Bis of the BWR training hasOwner's increased Group esergency procedure guideline the ability and confidence of every operatir4 shift to respond to an energency, and will enhance their ability to protect the health and safety of the publio. Licensed operators have also received 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 organizatio Considerable effort is in progress to improve the technical *
quality of operator training programs. The task list uJed to 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 materia 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 proces The accredited training programs for maintenance personnel are
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being implemente In addition, environmental qualification 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 trainin A supervisory training course has been developed and will be taught beginning in early September. The course teaches
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supervisory skills but has been tailored to the special needs of personnel working in a nuclear environment. The course is
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intended to establish a nuclear attitude that is more quality
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conscious and to increase the awareness of administrative controls
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approximately 60 first line supervisors which includes maintenance
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i I ENGINEERING / TECHNICAL SUPPORT - CATEGORY 3 A Category 3 rating in this area is enacceptable performance to Detroit gdiso 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 plan l
'the SALP Board points out that Detroit gdison annagement attention ,
1s required to further integrate the engineering function into the support of plant operations, to provide consistency in the l resolution of technical issues within engineering and to encourage !
engineering to become more proactive in anticipating plant !
problem i The SALP-9 report recognized that staff.tng was adequate, while approach to resolution of problems, responsiveness to Overall NRC initiatives and management involvement were mixe technical support to operations also needs further improvemen i Over the last year, several corrective actions have been taken and '
progress is being made by Nuclear Engineering in effectively supporting the operation and saintenance of Fersi. Some examples ;
include l
o In October 1987, the former flant Manager was made General !
Director - Nuclear Engineering bringing with his the knowledge of plant operations to Nuclear Engineering. This ;
t has been effective in reorienting Engineering thinking toward plant suppor l Increased the Plant Support Engineering (PSE) function by f o i doubling the size of the PSE group and providing essentially i
round-the-clock plank coverage since January 1988. The PSEs are located inside the plant and interface closely with the l
Technical, Operations and Maintenance personnel and provide I feedback to appropriate Nuclear Engineering discipline o Started daily Nuclear Engineering Staff meetings (General <
Director and all Nuclear Engineering Supervisors) reviewing I plant operational probicas and ensuring that resolutions are accurate and are completed in a timely manner. These meetings were espanded to include'all engineering supervisors in order to transmit management philosophy and desires more readily, o Self initiated Safety Syste uncti mal Ins the High Pressure Coolant Injection (HPCI)
system in the pection (SS
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Page 15 i
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later part of 1987. mis proactiva initiative confirmed the adequacy of the overal; plant design process, operations and management controls of the systes. Minor discrepancies ure l l
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identified and corrected. Current plans are to continue with ,
SSFI's on other system o Improvements were made in the performance and document 4 tion of safety evaluations ensuring consistent and proper resolution of technical issues. This was done through special training and monitorin5 o Plant modifications have been designed and installedFor to
' assist in reducing ESF actuations and other LER' example, a modification to the gaergency Equipment Cooling '
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Water (EECW) system was made which permitted shifting of the Reactor Building Closed Cooling Water (RBCCW) systes pumps without actuation of the EECW systes. Also, the delay volume of the Reactor Water Cleanup (mlCU) systaa was removed in i order to reduce the RWCU probleas being caused during reactor vessel depressurizatio j o Wuclear Engineering is working with Nuclear Production in ;
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establishing prioritization of proposed design modifications 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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j o Increased management attention on plant and inW:,try problens i f
i and NRC initiatives. Estaples include support of the Technical Specification Improvosent Program, and increased l effort in dispositioning Significant Operating Esperience ,
i l Report (30ERs), regulatory action items, DgRs, Temporary l
Modifications and Annunciators /Cf.!S-dot Administrative proce M os and training are being upgraded to f
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encourage engineering personnel to become more proactive in i
anticipating plant problems. Supervisors and techr.ioal personnel are held accountable foe up-front interface with
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Nuclear Production and ths on site A/E counterpart on plant f
l problems or concerns and to continue the interfaces while
- f proposed modification packages are developed and i I
implemented. Walkdowns on equipment and systems have been !
l' encouraged as well as review of equipment /systes performance !
history to detect degradatio ,
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t o Accountability meetings have been held to review personnel pe-formance problems. Root causes were identified and cotractive actions take o A senior Engineering supervisor is participating in SRO training program to increase knowledge of plant operatio He will complete training ma4 return to Nuclear Engineerin 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, o Consolidation of Material Engineering, Nuoisar Procurement 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, o The Technical Engir.eer position has been filled by an individual with operating experience who had an SRO licens o A Systen Engineering group is being put into effect in the 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 l
' engineering groups. A supervisor for the group has been hired with ten years of engineering and operational experience at operating reactors. The size of the group is l I l
being approximately doubled. A better definition of workscope and an expansion of Juties and responsibilities are l 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 peopl o In addition, a review of the nuclear material management process and the Nuclear Engineering / Technical Group interface is being ande by an outside consultant. The review is
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l intended to help us assess the working interface between the Nuclear Engineering and %hnical Group, and to make improvements to the an'+eiel management program The above corrective actior+ d11 continue to taprove gngineering and Technical efficiency ans effectiveness in supporting Nuclear Production.
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