ML20150D114

Discusses Concerns Noted in Operational Safety Team Insp Rept 50-341/87-30 Re Assessment of Plant Operations.Rept Reviewed & Findings Categorized Into 20 Listed Concerns

ML20150D114
Person / Time
Site:	Fermi
Issue date:	03/16/1988
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8803230098
Download: ML20150D114 (4)

See also: IR 05000341/1987030

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M 1 6 1989

MEMORANDUM FOR: E. G. Greenman, Director, Division of Reactor Projects

FROM: R. C. Knop, Chief, Reactor Projects Branch 3

SUBJECT: DISPOSITION OF OSTI FINDINGS AT FERMI 2

During the period from July 27 to August 7,1987, NRR conducted an Operational

Safety Team Inspection (OSTI) at Fermi 2. This inspection was requested by

Region III to provide an independent assessment of plant operations. Region

III felt that such an assessment would provide additional insight into why the

licensee has encountered so many personnel and management difficulties.

Region III agreed with the general conclusions of the OSTI report. The OSTI

presentation of conclusions to Region III management.was a major input

prompting the October 9,1987, letter to the licensee. This letter is

provided as attachment I. Also, monthly management meetings were mandated .

with the licensee to access their progress, due in part to the OSTI inspection.

The OSTI Team findings were documented in IER 87030. My staff has reviewed

the report and categorized the findings into 20 concerns. These concerns were:

1. Operations did not always perform to the high standards associated

with the nuclear industry.

2. Operational attitudes were production oriented causing insufficient

attention to be paid to certain administrative aspects of plant operation.

3. Poor communication was exhibited by and between management and

shift personnel.

4. Support personnel for plant operations were not utilized to the

maximum extend possible.

5. Operators exhibited difficulty in using Technical Specifications as

a working document.

6. Operators lacked commercial BWR operating experience.

7. The DER process was of limited depth.

8. QA could be utilized in a more performance based aggressive

manner.

9. Improvements could be made in ISEG effectiveness.

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E. G. Greenman -2_ MAR 161988

.10. OSR0 conducted "walkarounds" for-their committee reviews.

11. Safety evaluations were weak.

12. The material condition of the plant.needs improvement.

13. Procedures and the procedure revision process did not effectively-

support the proper performance of quality related activities.

14. The performance to paycheck concept had not been totally

implemented.

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15. The engineering support to plant problems was weak.

16. The surveillance program needs proper management-ettention to

assure appropriate implementation.

17. Furmanite is being used in an unqualified application.

18. The MSIV control circuit design could create an unreviewed safety

question.

19. Senior staff members did not routinely tour the facility contrary

to the Group V. P.'s directives.

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20. The Operations Superintendent could improve.his effectiveness

through formal site specific training.

The following approach is recortmended to review licensee actions to these

concerns:

1. Approximately 30 days after completion of the upcoming LLRT outage

Region III DRS should perform a management overview / committee activities

inspection. The inspection will address concerns 7, 8, 9, 10, 11, and 19.

2. Approximately 60 days after completion of the upcoming LLRT outage an

OSTI type inspection should be performed by NRR (RSIB). The inspection will

be of less scope than the OSTI concentrating on shift activities, the operator

evolution evaluation program and operational communications. This inspection

will address concerns 1, 2, 3, 4, 5, 14, 6 and 15,

3. Approximately 90 days after the completion of the upcoming LLRT

outage Region III DRS will perform a surveillance program inspection. Also an

inspection shall be performed in March to assess the quality of the newly

written I & C surveillance procedures. These inspections will address concerns

16.

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E. G. Greenman -3- MAR 161988

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4. Region III DRS inspection documented in IER 87036 addressed . ~

concern 18. No unresolved safety question was identified. However, the

licensee has a design change projected for the 1st refueling outage to help

eliminate unplanned MSIV opening.

5. Resident inspection documented in IER 87031 paragraph 4 addressed

concern 17. The matter is considered resolved.

6. Concern 20 and the portion of concern 13 dealing with inadequate

procedure revisions will be pursued by the resident staff and documented in

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a future resident routine inspection.

7. In addition to the planned inspection activities Region III management

shall assess licensee progress in a number of the areas of concern. Monthly

management meetings with the licensee will provide overview or directly address

concerns 1, 12, 14, 16 and the portion of 13 dealing with too many procedures.

As stated in the cover letter to the inspection report Region III was to

evaluate the report for potential violations. This action has been completed

with the potential violations being:  !

1. Numerous failure to follow procedures during performance of quality

related activities.

2. Numerous administrative controls being out of date, having

conflicting requirements and being ignored.

3. A procedure revision associated with the thermal recombiners was

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inadequate.

4. Inadequate safety evaluations were performed.

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5. Surveillance procedure 24.139.03 did not adequately implement

Technical Specification 4.3.2.1.

6. The committee review of OSR0 was being inadequately implemented

through walkarounds.

7. Furmanite was being used in an unqualified applicable.

8. I & C personnel did not initiate procedure revisions when required.

, The following approach has been taken with these potential violations:

1. Violations 87027-01, 87027-02, 87027-03 and 87036-01 were indicative

of the problems the OSTI team observed. With operator performance the 1

corrective actions associated with these violations and the establishment of '

the operator evolution evaluation program in response to the regional l

administrators letter of October 9, 1987, address potential violation # 1. l

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E. G. Greenman -4- -

2. Currently violation 87021-01 in IER 87021 was issued for

inadequate safety evaluations. This violation addresses potential violation

1. 4.

3. Violations in IER 87044 cite other examples of inadequate

surveillance procedures. Therefore, these violations encompass the deficiency

of surveillance procedure 24.139.03 and the violation corrective actions

address potential violation # 5.

4. Violation 87031-02 of IER 87031 addressed the inappropriate use of

furmanite and potential violation # 7.

5. Potential violation # 2 will be reviewed by the resident st'aff in

detail and will be explicitly documented in a future routine resident inspector '

report.

6. Potential violation # 6 shall be evaluated by Region III DRS

inspectors at the next inspection of licensee committee activities.

7. Potential violations # 3 and # 8 involve areas subject to routine

resident inspection. Licensee performance in these areas will continue to be

monitored. Enforcement action shall be taken if future inspection findings ,

dictate. '

This memo has been written to provide a status as to those regional actions

taken in response to your inspection. Also, I would like to express my

appreciation for the OSTI and the insights gained from your inspection effort.

Sincerely,

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R. C. Knop, Chief ,

Reactor Projects Branch 3 j

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Attachment: As stated

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cc: A. Bert Davis

C. J. Paperiello ,

H. J. Miller '

R. W. Cooper

W. Rogers

C. J. Haughney

gc[. b

RIII '

Knop /pb

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