ML20197F613
| ML20197F613 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/06/1988 |
| From: | Muller D Office of Nuclear Reactor Regulation |
| To: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8806140218 | |
| Download: ML20197F613 (9) | |
Text
June 6, 1988 Docket No.
50-341 MEMORANDUM FOR:
Edward G. Greenman, Director Division of Reactor Projects Region III FROM:
Daniel R. Muller, Acting Director Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects, NRR
SUBJECT:
NRR SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) INPUT FOR DETROIT EDISON COMPANY'S FERMI-2 FOR THE PERIOD APRIL 1, 1987 THROUGH MARCH 31, 1988 Enclosed is the NRR SALP input for Fermi-2.
This report is based upon direct inputs solicited from selected NRR personnel who have had substantial contact and/or involvement with Detroit Edison Company's (Deco's) activities for Fermi-2. A substantial' portion of this input has been derived from the Operational Safety Team Inspection conducted from July 27 through August 7, 1987 (Inspection Report Number 341/87030).
Aay comments concerning this input should be referred to Ted Quay (FTS 492-1325).
original signed by Daniel R. Muller, Acting Director Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects, NRR
Enclosure:
As stated cc w/ enclosure:
D. Crutchfield G. Holahan M. Virgilio R. Cooper, RIII W. Rogers, SRI P. Pelke, RIII Bj$61ggy$$00 i
el J. Stefano o
DISTRIBUTION
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GHOLAHAN EJORDAN NRC & LOCAL PDRs RINGRAM JPARTLOW PD31 GRAY FILE TQUAY ACRS (10)
DCRUTCHFIELD OGC
- See previous concurrence
- PD31/LA
- PD31/PM
- PD31/PD
- ADR RIngram TQuay DMu11er GHolahan D
field 5/24/88 5/24/88 5/26/88 5/26/88 5/T]/88
Docket No.
50-34.1 MEMORANDUM FOR:
Charles E. Norelius,' Director Division of Reactor Projects s
N Region III i
FROM:
Daniel R. Muller, Acting Director Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects, NRR s
SUBJECT:
NRR SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) INPUT FOR DETROIT EDIS0N COMPANY'S FERMI-2 FOR THE PERIOD APRIL 1, 1987 THROUGH MARCH 31, 1988 Enclosed is the NRR SALP input for Fermi-2.
This report is based upon direct inputs solicittd from selected NRR personnel who have had substantial contact
~
and/or involvement with Detroit Edison Company's (DECO's) activities for Fermi-2.
A substantial portion of this input has been derived from the Operational Safety Team Inspection conducted from July 27 through August 7, 1987 (Inspection Report Number 301/87030).
Any comments concerning this input should be referred to Ted Quay (FTS 492-1325).
Daniel R. Muller, Acting Director
'ProjectDirectorateIII-1 Division of Reactor Projects - III, IV, V & Special Projects, NRR
Enclosure:
As stated cc w/ enclosure:
D. Crutchfield G. Holahan M. Virgilio R. Cooper, RIII W. Rogers, SRI P. Pelke, RIII C. Ariano, RIII L. Kelly J. Stefano DISTRIBUTION DOCKET FILE GHOLAHAN EJORDAN NRC & LOCAL PDRs RINGRAM JPARTLOW PD31 GRAY FILE TQUAY ACRS (10)r i
DCRUTCHFIELD OGC PD31/LAju PD31/PM P'
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June 6, 1988
/
e Docket No.
50-341 MEMORANDUM FOR:
Edward G. Greenman, Director Division of Reactor Projects Region III FROM:
Daniel R. Muller, Acting Director Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects, NRR,
SUBJECT:
NRR SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) INPUT FOR DETROIT EDISON COMPANY'S FERMI-2 FOR THE PERIOD APRIL 1, 1987 THROUGH MARCH 31, 1988 f
Enclosed is the NRR SALP input for Fermi-2.
This report is based upon direct
,(
inputs solicited from selected NRR personnel who have had substantial contact' x
and/or involvement with Detroit Edison Company's (Deco's) activities for i
Fermi-2.
A substantial portion of this input has been derived from the
/
Operational Safety Team Inspection conducted from July 27 through August 7, 1987 (Inspection Report Number 341/87030).
Any comments concerning this input should be referred to Ted Quay (FTS 492-1325).
?
_/ ff ?f]
Daniel R. Muller, Acting Director
,/
ProjectDirectorateIII-1
,/
Division of Reactor Projects - III, IV, V & Special Projects, NRR
Enclosure:
As stated
/
l cc w/ enclosure:
D. Crutchfield 4
G. He' *an t
M. V1., ilio i
R. Cooper, RIII W. Rogers, SRI P. Pelke, RIII C. Ariano, RIII E
L. Kelly J. Stefano 4
~
r
/'
F
- ' a I
4 Docket No:
50-341
[
FACILITY:
Fermi-2 LICENSEE:
Detroit Edison Company EVALUATION PERIOD:
April 1,1987,throughMarcb 31,'1988 PROJECT MANAGERS:
Theodore R. Quay / John Stefano I.
IN,TRODUCTION This report contains NRR's inht to the SA'.P report'for Fermi-2.
The assess-ment was conducted according to NR' Office ~ Letter No. 44, Revision 1, dated December 22, 1986.
This Office Lettar incorporated NRC Manual Chapter 0516, "Systematic Assessment of, Licensee Performance."
II.
ASSESSMENTbFPERFORMANCEA.TTRIBUTES The licensee's performance evaluation is based on a consideration of seven' I
'f attributes.
These are the following:
jd A.
Management involvement and control in assuring quality B.
Approach to resolution of technical issues from a safety standpoint
, C.
Responsiveness to NRC initiatives D.
Staffing E.
Enforcement F.
Training an'd Qwll fication Effectivenen i
G.
Housekeninh4 A.
ManagementInvahemNn_tandControlinAssuringQuality The licensee management's role in assuring quality in licensing related activities improved during the SALP period.
Toward the latter portion of the SALP period, the licensee hired a new licensing supervisor.
This licensing supervisor worked closely with NRR to promote a better working relationship.
,f Licensee submittal quality during the initial portion of the SALP period was less than desired.
Hawever, the quality improved toward the end of the SALP period.
Recent submittals have been generally clear and of higher quality.
Licensee submittals have been generally untimely resulting in the need for the staff to expedite sever 41 reviews.
This is due in part to some lack of planning by Deco as well as some problems identified during operation.
The licensee has, however, demonstrated a willingness to meet with NRR on short notice to better coordinate the scheduling of licensing activities.
Mu'ch of the licensing activities during this SALP period have been relathd to startup issues and a licensee initiated Technical Specification (TS) improvement
/
/
t 1,s program.
Because of the TS improvement program, the volume of TS change requests during this. period has been unusually high and is expected to re.niin high until the end of the improvement program which is scheduled for c e7 etion 1
}!
December 1988.
An audit conducted during the last SALP period (March 1987)'on the Detailed Control Room r,esign Review (DCRDR) and the Safety Parameter Display System (SPDS) identified significant deficiencies in management ove'rsight.
In particult.r, one of the findings with respect to the DCROR wa3 that there was an apparent lack of DECA management support to perform a n.aaningful and effective s DCRDR.
Meetings on Lhese two items were held during the current'SALP period in,
August and November 1%7.
As a result of these meetings,fther evidence that DECO submitted an updated Summary DCRDR Report and SPDS Report.
This is fu Deco management is demonstrating greater inpolveme t.
5 In summary, management is taking a more dir'ect o'e ir. licensing activities; however, there is still need for improvement in.ne planning for and the timely submissionoflicensingsubmittaQ.1 B.
Approachto,ResolutionofTp[hnicalIssuesfromah;WtyStandpoint The licensee's approach to resolution of technic.f issues has shown some improvement in that the licensee has usually demonstrated an understanding of the technical issues involved in licensing activities and proposed acceptable resolutions.
During the SALP period significant progress was made on the DCRDR and SPDS.
/
The licensee is drjonstrating far greater inter ^st in resolving technical issues and has tden the initiative in contacting NRC.
Licensee submittal quality can still be improved.
(
C.
Responsiveness to NRC Initiatives The licensee's respansiveness to NRC initiatives improved during the SALP 1
period.
Illustrtticas of this were the efforts relative to the deficiencies in the SPDS and DLER that were identified during an audit at the very end of the last SALP po 'od.
Licensee efforts during this SALP period have these issues on the path toward resolution.
During the latter portion of the SALP period, the licer.i.ee has responded promptly and accurately to information requested by the staff.
D.
Staffing The licensee has provided appropriate members of their organization at meetings with the staff.
In addition, the licensee has hired a new plant manager and licensing supervisor. The licensing supervisor has extensive background and experience in licinling.
These, individuals have improved the licensee's perform-ance in licensing.ctivities.
The DECO licensing staff is located in the Nuclear Operations Center (NDC).
The NOC is located on the Fermi-2 site and consequently, the proximity of the' licensing staff to the plant is a significant advantage.
'e
, i
)
f
/
e 4:
i t E.
Enforcement There das no input specifically directed toward enforcement for the licensing area.
\\
F.
Training and Qualification Effectiveness There was no input specifically directed toward this item for the licensing area.
H.
Housekeeping Observations made during the Operational Safety Team Inspection (OSTI) indicated that a number of areas appeared to be maintained above average, including the control room, auxiliary building, turbine building and cable spreading room.
The reactor building and relay room contained some extraneous items, such as tools and portable equipment, that were not in use.
III.
ASSESSMENT OF OTHER FUNCTIONAL AREAS i
NRR observatiens relating to the other functional areas are included.
These observations we.ke gained principally from the OSTI during the period July 27 -
August 7, 1987 and visits to the plant by the Project Management staff.
The OSTI findings are given as they relate to specific areas.
Plant Operations:
Operators did not appear to understand the use of the TS as a "working" document bybeinyintimatdlyfamiliarwithrequirementsforoperabilityofsystemsand time limitatior s:
Operators appeared to have a good classroom knowledge of the TS but appeared'to have difficulty identifying and complying with its many requirements.
The operations staff did not use the Fermi licensing staff as a resource for TS interpretttions.
t T :a operators' generally good knowledge level did not always translate into the broad understanding of system interrelationships necessary for a "big picture" grasp o'f integrated plant operation.
The OSTI team regarded this weakness as a major contributor to the human errors the team observed in the control room.
Six significant events occurred during the OSTI inspection period which provided an opportunity for team members to observe operator actions.
In general, the team found examples of operator inattentiveness, instances of unfamiliarity with equipment and system operating characteristics, and the absence of a questioning, problem oriented attitude that asked "what if" questions in an effort to identify and prevent aroblems.
Failure to follow procedures and ineffective communication also contriLuted to the observed examples of poor performance.
4 i
F j
1
. The OSTI team found evidence of poor communication between management and shift personnel.
A perception of management unresponsiveness, little one-on-one exchange, and the workload demands on management all contributed to the communication dysfunction.
Management was visible in the control room regularly, but the thrust of these visits appeared to be to obtain plant status rather than to communicate meaningfully with the shift personnel.
Operations had a production orientation that regularly resulted in the licensee taking the path of least resistance in resolving administrative and materials problems which had the potential to delay progress toward commercial operation.
Examples included failure to administratively pro;ess temporary modifications, the extensive use of temporary changes to procedures, a reluctance to initiate hardware changes as a part of corrective action and performance of technical reviews of reportability questions by ormrations personnel without involving the technical support staff.
The licensee paid insufficient attention to certain administrative aspects of plant operation, including temporsry modifications and caution tagging systems intended to show the operating status of equipment.
The Deviation Event Report (DER) system that formed the heart of the operational corrective action process was found to have limited depth in the associated root cause analyses.
The OSTI team found evidence of nonconservative or deferred corrective actions in several narrowly focused DER evaluations.
A reluctance to delay the startup process was evident through the emphasis of administrative corrective actions when a hardware problem was involved.
This weakness in implementing the DER system was disappointing, for the system itself appeared to be capable of developing and implementing effective problem resolutions.
Quality Programs & Administrative Controls Affecting Quality:
The OSTI team considered the site QA as a strength, although QA at times failed to grasp the fundamental causes of problems and instead emphasized statistical tabulations.
Corrective action too often involved on-the-spot procedure changes without addressing generic issues or pursuing a diagnostic approach to deficiency resolution.
At the time of the OSTI, management had not been successful at clearly conveying the goals of the various remedial programs to operators in terms of specific expectations for individual performance.
Plans had existed since l
June 1986 to integrate individual performance into the annual performance evaluations, thus relating performance to paycheck.
At the time of the OSTI, that new approach had not yet started.
All plant departments, including operations, are struggling in attempting to use the estimated 6000 procedures at the facility.
Although first identified as a major contributor to human error and production delays in 1985, limited progress has been made in streamlining administrative controls.
The licensee's newest target date was December 1988.
. Training and Qualification Effectiveness:
Although many of the operators had a naval nuc' ear background, commercial BWR experience among shift crews was minimal.
For this reason, operators did not have a reference point gained from operating a BWR that would make them aware of the requisite standards of performance required.
Based on the examination given to operators by the licensee as a result of the mode change incident and on interviews and observations, the OSTI team concluded that operators were not fully knowledgeable in the duties and responsibilities of their individual positions.
Operators, instrument technicians, and maintenance personnel did not seem to grasp the significance of how their actions had the potential to place the plant at risk.
Surveillance:
The licensee continued to encounter difficulty with the surveillance program.
At the time of the OSTI, the licensee's plan to minimize missed surveillances remained unfulfilled after several attempts.
Earlier efforts to address this deficiency had not been effective, apparently because of a failure to devote sufficient resources to program improvements.
Successful surveillance per formance was complicated by temporary modifications and temporary procedure changes, resulting in continued high error rates.
IV.
SIGNIFICANT OCCURRENCES A. NRR/ Licensing Meetings - The licensee's presentations were generally well structured.
The licensee was generally well prepared for meetings with the NRC staf f and generally handled all the staff's quei,tions adequately.
A list of NRR/ Licensee meetings is shown below:
Date Purpose August 1987 SPDS and DCRDR October 30, 1987 Compensatory measures in support of GDC-56 exemption request November 17, 1987 Progress on the SPDS February 17, 1988 Discuss interpretations of certain Technical Specifications B.
Commission Meeting - None C.
Schedular Extensions Granted - None
.. D.
Reliefs Granted September 28, 1987 Inservice Testing October 6, 19C/
ASME Code,Section XI E.
Exemptions Granted November 13, 1988 Exemption to GDC-56 for Primary Containment Radiation Monitor F.
Orders Issued - None G.
Emergency Technical Specifications Issued October 9, 1987 TS Table changes for leakage testing January 6, 1988 Setpoints for reactor coolant system interface H.
License Amendments Issued Amendment Number Description Date 8
Editorial corrections to TS 7/17/87 9
APRM setpoint action statement and control rod 7/21/87 block instrumentation 10 Leakage test requirements for containment 10/9/87 isolation valves 11 Administrative controls 10/22/8/
12 Emergency diesel generator lube oil surveillance 12/16/87 program 13 Battery surveillance requirements 1/11/88 14 Reactor coolant leakage 1/12/88 15 LPCI cross-tie valve 3/14/88 16 Primary containment isolation valves 3/21/88 17 Addition of isolation valves for the primary 3/29/88 containment radiation monitor
.