IR 05000341/1992011

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Insp Rept 50-341/92-11 on 920701-0824.Violations Noted.Major Areas Inspected:Action on Previous Insp Findings,Operational Safety,Maint,Surveillance,Followup of Events,Ler Followup & Review of Ti 25215/115 & Associated Allegation
ML20127D795
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 09/09/1992
From: Phillips M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20127D690 List:
References
50-341-92-11, NUDOCS 9209150175
Download: ML20127D795 (13)


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U. S. NUCLEAR REGULATORY COMMISSION ,

REGION 111 1 i

l Report No. 50-341/920ll(ORP) )

Docket No. 50-341 Operating License No. NPF-43 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 facility Name: Fermi 2 Inspection At: Fermi Site, Newport. MI inspectionLConducted: July 1 to August 24, 1992 Inspectors: S._Stasek K. Riemer M. Phillips E. Plettner R. Mendez T. Kobetz V - /

Approved By: . P. P Ii lef ~

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Reactor projects Section 28

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Date Inspection Summary laggliga on Julv~ 110 Auaust 24, 1992 (Recort No. SC-341/ 920ll(DRP)) LIeas Inioccted: Action on previous inspection findings; operational safety:

maintenance: surveillance; followup .of events; LER followup; review of Tl 25215/115 and associated' allegation, and simulator' revie Results: Overall performance of the operating crews was adequate during this inspection period. The unit continued to operate at or near full power with -

no unplanned transients to the reactor occurring, in one case it was identified that operators deviated from the turbine building HVAC system operating procedure without the_ requir:.d reviews or authorization (paragraph l 3.b). -Surveillances_and maintenance activities observed during the inspection

period appeared to be conductei in accordance with-all applicable requirements, including radiation protection controls. Two instances W re

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t again noted this period where scaffoldi.ng was inappropriately erected in

- contact ~with safety'related components (paragraph 3.c). A material storage.

L area was notLlocked when unatter.ded and therefore not properly controlled, thereby allowing-for possible entry by unauthorized individuals (paragraph

- 3. a) ,- Housekeeping was generally good throughout the plant. A review per Tl n 2515/115:t0 ensure falsification of plant records relating to rounds l activities were not occurring at Fermi was conducted with no discrepancies L noted. -Allegation Rill-92A-0049 was also reviewed relating to this area with

, again, no discrepancies noted. A review of the licensee's simulator and l

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4 9 associated emergency operating procedures (EOPs) identified no safety significant discrepancies. One violation with three examples was identified (Paragraphs 3.3, 3.b, and 3.c). No unresolved cr open items were identified during the inspectio __

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OETAILS Parign,Cpntacted [leirpit 1dison Comp 3ny C. Cassise, General Supervisor, Mechanical Maintenance R. Eberhardt, Superintendent, Radiation Protection

  • P. fessler, Director, Nuclear Training
  • D. Gipson, Vice President, Nuclear Operations
  • L. Goodman, Director, Quality Assurance
  • R. Henson, Operations Engineer
  • K. Howard, Supervisor, Mechanical and Fluid Systems, NE
  • E. Kokosky, General Supervisor, Radiation Protection J. Korte, Director, Nuclear security A. Kowalczuk, Superintendent, Maintenance and Modifications
  • R. Matthews, Assistant Superintendent, Maintenarce R. McKeon, Plant Manager, Nuclear Production
  • W. Miller, Superintendent, Technical Engineering
  • N. Mims Assistant Superintendent, Maintenance
  • R. Newkirk, General Director, Regulatory Affairr
  • J. Plona, Superintendent, Operations
  • R. Russell, Outage Manager L. Schuerman, General Supervisor, Plant Engineering
  • A. Settles, Director, licensing
  • B. Siemasz, Compliance Engineer
  • R. Stafford, General Director, Nuclear Assurance D. Stone, Supervisor, Production Quality Assurante R. Szkotnicki, Director, Plant Safety
  • J. Tibai, Supervisor, Compliance U.S. Nuclear.jlqaulatory Commitsion
  • S. Stasek, Senior Resident Inspector K. Riemer, Resident inspector E. Plettner, Senior Resident inspector (DRP)

M. Phillips, Chief, Reactor Projects Section 2B R. Mendez, Reactor Engineer T. Kobetz, Reactor Engineer

The inspectors also interviewed others of the licensee's staff during this inspectio , &ction on_ Previous _lnspection Findinai (92701) (Closed) Open item (341/90013-02(DRP)): Hydrogen /0xygen Monitor Discrepancies. Four problems associated with the hydrogen / oxygen monitor were identified over a one month period in September 1990 necessitating certain corrective actions be taken. The inspector

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reviewed the completed Deviation Event Reports, reviewed records preceding the problems for additional occurrences, and interviewed plant personnel. The inspectors concluded that the licensee's corrective te,tions appeared to be comprehensive and effective in preventing recurrence of the problems. This item is close (Closed) Unresolved item (341/92010-Ol(DRP)): Adequacy of 10 CFR 50.59 Safety Evaluctions (SEs). A special safety inspection had previously been conducted which identified similar weaknesses (Reference inspection report 341/89017) Because the subject SEs were issued during the same timefeame, tney were considered to be further examples of the same weaknesses previously identifie Therefore, since appropriate enforcement actions and associated corrective actions taken and implemented to address these weaknesses, this matter is considered close . Op_grational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators throughout the inspection period. The inspectors verified the operability of

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selected safety-related systems, reviewed tagout records, and verified proper return to service of affected components. 1he inspectors observed a number of control room shift tu..nvers. The turnovers were conducted in a professional manner and included log reviews, panel walkdowns, discussions of maintenance and surveillance activities in progress or planned, and associated LC0 time restraints, as applicabl The inspectors conducted tours of the reactor, auxiliary and turbine buildings. During these tours, observations were made regarding plant equipment conditions, fire hazards, fire prctection, adherence to procedures, radiclogical controls and conditions, housekeeping, tagging of equipment, ongoing maintenance and surveillance activities, containment integrity, and availability of_ safety-related equipmen Walkdowns of the accessible portions of the following systems were conducted to verify operability by comparing system lineups with plant drawings, as-built configuration or present valve lineup lists; observing equipment conditions that could degrade performance; and verifying that instrumentation was properly valved, functioning and

calibrate . Standby Gas Treatment System - Divisions I and 11

. Emergency Diesel Generator No. 11-

. Emergency Diesel Generator No. 12

-. Core Spray System - Division 11

. High Pressure Coolant Injection System

. Emergency Equipment Cooling Water System - Division I Additionally, the inspector observed implementation of portions of the licensee's security program during the inspection period including:

badging of personnel; access control; security walkdowns; security

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response (compensatory actions); visitor control; se:urity staff attentiveness; and operation of security equipmen Significant observations and reviews included the following: On August 12 during discussluns with plant personnel, the inspector was informed that the lock on the material issue storage cage located on the first floor of the Office Services Building (0SB) had been removed t.. days earlier to su) port off-shift contractor activities. Materials stored in tais storage area included welding materials. Review of the licenre's administrative controls and spe:ifically Fermi Management Directive (FMD) PM3, " Shipping, Handling, and Storage" revealed that the welding materials were classified as type B items with requirements specified to protect that material from potential vandalism. Also specified as a requirement related in general to storage areas onsite included requirc.nents to control access to authorized individuals. When the inspector contacted licensee management to discuss the issue of access cor. trol to the storage area, they indicated that the lock would be replaced and accett control to the storage area appropriatoiy restored. Because the removal of the locking mechanism was in direct conflict with the licensee's administrative procedure FMD-PM3, this is considered an example of a violation of 10 CFR 50, Appendix B, Criterion V,

" Procedures, Instructions, and Drawings." (341/920ll-01A(DRP))

At the conclusion of the inspection period, the licensee was

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evaluating viable alternatives to maintain adequate control over the types of materials store:i in the subject storage are However, the inspector was informed that the storage area would be appropriately locked whenever unattended, During a routine walkdown of control panels, the inspector noted that turbine building differential prese.'e (dp) was equal to

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zero, further discussion with contW Poom operators revealed that the reason for the zero op was that a set of roll up doors as well as a personnel access door was open to the outside to allow for greater ventilation into the building because of the warm weather condition Further review, however, determined that the Final Safety Analysis Report, in Section 9.4.4, required that

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during normal cperation a negative (unspecified) differential i pressure be maintained by the turbine buildhg HVAC (TBHVAC)

l system at all times. The FSAR description discussed the operation of the TBHVAC system. 'sch was in direct a;r flow from the least potentially contaminated to the most potentially contaminated areas,-then to the ventilation duct work, and tnen past a radiation monitor to the exhaust plenum. With no dp across the building. .the normal flow path including that past the radiation monitor could be modified and allow for other pathways to exis In addition, system operating procedure (S0P) 23.412. " Turbine Building Heating, Ventilation, ar,d Air Conditioning" specified in

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d Section 3 a limitation that Turbine Building pressure be maintained at a negative 1/4 in, of wate Because the 1BHVAC System was operated in a configuration that deviated from the approved 50P operational requirements, futther evaluation was required to assess the consequences of doing so at the time system dp was allowed to go to zero. Since the TBHVAC system was not operatad i.n accordance with the system operating procedure, this is considered a second example of a violation of 10 CFR 50, Appendix B, Criterion V, " Procedures, Instructions, and Drawings." (341/920ll-01B(ORP))

In response, the licensee initiated actions to regain the required building dp. The S0P was subsequently revised to delineate oper1 tion within the pressure band, and a night order was issued to remind all operating crew; of the necessity to maintain turbine building dp and the need to process and authorize any deviation from approved procedures. In addition, a review of the Update final Safety Anelysis Report (UFSAR) was initiated to evaluate the current descriptio On July 24, during a routine walkdown of the Southwest quadrant of the Reactor Building (RB) basement, the inspector notei that improperly erected scaffolding was in direct contact with QA 1 equipmen Specifically, int inspector observed scaffolding in contact with conduit associated with a Division 2 RHR instrument rack; other scaffolding was observe <i to be in contact with conduit associated with a Recir:u'ation Pump "B" instrument rac The inspector communicated his observations and concerns to the Nuclear Shift Supervisor (HSS) who initiated actions to correct the situation. On July 29, during subsequent walkdowns of the RB, the inspector again noted improperly erected scaf folding in contact with QA 1 equipment, in this case, scaffolding was in direct contact with instrument tuoing associated with a Division 1 PCMS pilot valve instrument rac The NSS was again informed of the inspector's concerns and o'servatiou. These occurrences of improperly erected scaffolding are sim',iar to previous instances identified by the inspectors (reference inspr.ction report 50-341/92010).

Fermi Administrative DroCedure NPP-HKl-02 (" Scaffolding"),

Enclosure B, states in the Plant Specific Scaffolding Guidelines section that " scaffold is not to be erected close to QAl plant components." Per discussion with licensee personnel, the inspector was informed that the following actions had been taken to correct the problem: all current scaffolding was inspected and/or rebuilt to comply with procedural requirements, all personnel associated with scaffolding erection and construction were retrained on the proper installation of scaffolding, and a requirement was established that a Senior Reactor Operator (SRO),

Senior Certified Operator, or a previously licensed SR0, inspect scaffolding after its installation to ensure that safety related

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equipment is not adversely impacted by the scaffold. Subsequent to-the end of the inspection period, the licensee revised procedure HPP-HKl-02 to reflect the new requirements. Since scaffolding was crected in violation of the administrative procedure, this is considered a third example of a violation of 10 CFR 50, Appendix is, Criterion V, " Procedures, instructions, and Drawings." (341/920ll-01C(DRP)) On July 26, the licensee discovered that the Division 11 RHR pump room return air damper was disconnected from its actuating mechanism. The damper, which is located in the ventilation system that provides cooling to Division 11 safety related service water pumps, was declared inoperable. TL,s Division 11 Emergency l Equipment Service Water (EESW) pump was declared inoperable which

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then rendered the Division !! Emergency Equipment Cooling Water j (EECW) Jump inolerable. With the Division 11 EECW pump '

inopera)le, Hig1 Pressure Coolant injection (HPCI) was declared inoperable due to loss of HPCI room cooling. The licensee made a four-hour non-emergency notification phone call to the NRC in accordance with 10 CFR 50.72. The licensee reconnected the damper to its actuating mechanism and declared the dar..per and the associated systems operabl Subsequent to the event, the licensee performed an engineering analysis to determine the impact of the inoperable damper on the Division 11 service water pump room. Results of the analysis showed that the operability of the EESW pump was unaffected because, u.Jer worst case conditions, the motor insulation temperature would not have exceedeu its insulation class ratin Since the EESW pump operability was not affected, neither the EECW pump nor the HPCI system were inoperable due to the failed dampe The licensee, therefore, concluded that the event was not reportable to the NRC under 10'CFR 50.72 and subsequently retracted the four hour report made when the HPCI system was initially declared inoperable. The inspectors reviewed the event and addressed the analysis with licensee engineers and had no substantive concern ' The inspector accompanied the Nuclear Power Plant Operators (NPP0)

.during the performance of their duties in the reactor building and in the turbine building during the inspection period. The operators were observed to be attentive during the performance of their duties with good communications between them and the control  :

room. Note worthy was the use of rep at backs between the control

room operators and the NPP0's. The NPP0's appeared to b knowledgeable'of the plant and took appropriate actions when they noted discrepancie Three examples of one violation were identified in this are i

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i liainkaana (62703)

Station maintenance activities on safety-rt: lated systems and components listed below were observed to ascertain (nat they were cenducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiatinc the work; activities were accomplished using approved procedures and were inspected as applicable; functiona, testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; -

radiological controls were implemented; and fire prevention controls were implemente Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performanc The following maintenance activities were observed / reviewed: -

pST AC20920721 Obtain sample of inboard and outboard (EDG-13) generator bearing oil WR 000Z923359 Monitor input and output of MV/1 converter (A&B) to determine speed signal WR 000Z922870 Replacement of transmitter B21N487 following completion of maintenance on the diesel generator and the recirculation system, the inspectors verified that these systems had -

been returned to service properl No violations or deviations were identified in this are . Survenlang (61726)

The inspectors observed / reviewed the following Technical Specitication required surve'llance testin .

24.413,03 Control Room Emergency Filter Monthly Operability Test

. 24.307.16 Emergency Diesci Generator-13 Start and Load Test, Slow Start i

. 47.000.02 Mechanical Vibration Measurements For Trending ,

(EDG-13)

. 24.404.04 Standby Gas Treatment System filter Operability Test

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The following items were considered during the inspection: the testing was performed in accordance with approved procedures; that test instrumentation was calibrated; that test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test; and that any .

deficiencies identified during the testing were reviewco and resolved by appropriate managemcnt personne The inspectors also performed a record review of the completej surveillance tests listed bel w. The review was ta determine that the test was accompitshed within the required time interval, procedural steps were properly initia11ed, the procedure acceptance criteria were met, independent verificatius were accomplished by individuals other than those performing the test, and that the test was sigr.ed in and out of the control room surveillance log boo . 24.206.03 RCIC Discharge Piping Venting and Valve Verification Test

. 24.404.02 Division 1 SGIS Filter and Secondary Containment isolation Damper Operability Test

. 24.501.07 Diesel fire Pump Engine Operability Test

. 44.010.001 RPS - Reactor Steam Dome Pr9ssure, Div 1, Functional Test

. 44.160.001 Fire Detection Operability and Functional Test

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44.020.035 NSSSS - Main Steam Line Flow, Div 1, Channel functional Test

, 44.020.043 NSSSS - Main Steam Line flow, Div 1, Channel A Response Time lest

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44.020.059 NSSSS - Condenser Pressure, Div 1, Channel functional Test

. 54.000.02 Reactivity Anomalies check

. 54.000.03 Control Rod Scram Insert Time Test

. 54.000.07 Core parameter Check

. 64./13.019 Attch 1, Radiological Effluents Routine Surveillances

. 74.000.18 Attch 13, Chemistry Shiftly, 72 Hour and Situation Surveillances No viola + ions or deviations were identified in this are . Followun of Eventi (93702)

During the inspection period, the licensee experienced several events necessitating an elevated level of followup. The inspectors pursued the events onsite with licensee and/or other NRC officials. In each case, the inspectors verified that the licensee was taking prompt and appropriate actions, that activities were conducted within regulatory requirements and that corrective actions would prevent future recurrence. The specific events are as follows:

Ally _i - During troubleshooting of MSIV Leakage Control System, excess flow check valve (EFCV) B21-F502B inadvertently closed. Although the EFCV had closed, indication did not reflect the closur Consequently,

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e plant personnel were celayed in identifying the root cause of the problem. However, once identified, Technical Specification 3.3.2 Action C was invoked as req 91 red to place the associated channel in a tripped

condition. The valve was subsequently reopened and the Action statement exited. Followup of why the EFCV did not show proper indicaticn revealed the most likely caure to be related to its mode of closin ;

Because of the troubleshooting performed on related instruments, the downstream side pressure was slowly bled off which caur.cd the valve to close slowly. Because of this, the associated reed switch, providing the closed indication, did not register sufficient change to pick up the closed light. The valve operated as designed. The valve is scheduled to be tested during the upcoming refuel outago and final determination made at that point whether the anomalous indication was due to the method of valve closure or is related to a problem with the indicating circuitr The inspector will review those test results once availabl '

July 14 - Tornade funnel cloud spotted within one mile of plant. Dering a severe weather condition which included a general tornado warning for the local area near the plant, the control room received notification that a funnel cloud was spotted within one mile of the fermi Drive rat Operators subsequently performed the applicable portions of abnormal operating procedure (AOP) 20.000.01 " Acts of Nature" Actions taken ir.cluded evacuation of oersonnel from non-category I structures onsite, ,

verification that the idlR complex mechanical draf t cooling tower fans '

were operable, as well as actions taken to close or verify closed plant exterior doors. Entry into the Radiological Emergency Response Plan (RERP) was not necessitated because the RERP entry criteria requires a tornado to specifically cross the site boundary before declaring an unusual Even The inspector observed operator response from the '

control room with no substantive concerns note MLqtt}Lil - Of fgas Radiation level increase. During routine plant operation, it was noted that offgas radiation levels had increased <

slightly from the normal 0.2 mci /sec. Operations requested chemistry samples be taken to identify the root cause. Sample results subsequently indicated that offgas radiation levels had indeed increased and further review by reactor engineering and nuclear fuels group d uermined the most ' -aly cause to be 1-5 pinhole leaks in one or more fuel pins. The licenwe then entered their failed fuel Action Plan (ffAP) to control and monitor the situation. After several days, the offgas l_evels steadied out and engineering subsequently estimated that one pinhole leak could result in the observed radiation levels. The peak value observed following the initial increase was approximately 8.4

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mci /sec with the level at the end of the inspection period being 3.65 l- mci /sec-(compared to the 340 mci /sec Technical Specification limit).

i lhe licensee is currently evaluating further actions in attempts to identify which fuel bundle (s) may be tne source of the leakag No violations or deviations were identified in this are . . - - - - -. . . -

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l . Follqwp of licentee Event Rgnrit (92700)

Through direct observations, discussions with licensee personnel, and review of records, the following event report was reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification (Closed) LER 91-021 Control Center Heating Ventilation and Air Conditioning (CCHVAC) Shifts to the Recirculation Hodo During ,

Surveillance 24.413.05. The LER identified a problem associated with !

the Control Room Emergency Filter Auto Transfer Test. The rcot causes ;

of the problem were associated with the test mathods used in the procedure and a personnel error which occurred during the performance of the procedure. The inspector verified by document review and personnel interview that the currective actions to prevent recurrence, as stated in the LER, were accomplished and completed in a timely manner. Safety significance was minimal _ since the test placed the CCHVAC in the designed safety mode. This item is close No violations or deviations were identified in this are . Ec.yley_of Temocrary instruction ?.1L51J15. " Verification of Plant RKorjs" and AJ1gaation Rul-92A-0QQ A review of a representa ive sample of required room entries against security' access records was conducted by the in:pector during the inspection period. This sample included entries into the reactor building, auxiliary building, and residual heat removal (RHR) complex for individual members of the operations, fire watch, and maintenance -

groups, to verify that required entries were made consistent with the

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documented-records of such entries and associated activities. conducted within those areas. No inconsistencies between the entries made and the records of activities were identified. All entries appeared to be appropriately made with the associated timeframes to conduct the specified activities also appearing appropriat In addition, the inspector determ ned that the licensee had conducted several QA audits of individual work groups onsite including operations, radiation protection, and security personnel, to verify appropriate entries had been made by individuals performing required work. The

. audits revealed no cases in which individuals had completed records without making appropriate entr_ies to those subject area A program to assure future conformance was being developed by the licensee at the end of the inspection period. The draft requirements will include tho' periodic monitoring at the department level (with some QA verification) on a sample basis:and will include both a check of

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entries into required areas as well as a walkdown by a technically

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Associated with this area of review was a recently received allegation (reference Rlll-92A-0049) concerning the completion of operator rounds sheets. The concern specifically addressed whether licensed operators were appropriately documenting data during specified rounds activitie As part of the review per the TI, the inspector also reviewed a sample of licensed operator in-plant rounds and verified that required entries were appropriately made via a random selection of security keycard transactions for those areas of concern. No discrepancies were noted and, therefore, this allegation was determined to be unsubstantiated and is considered close No violations or deviations were identified in this are . 11mul ator/Proced9Eg_ Evaluation (42001)

On July 21-23, 1992, the resident inspection staff, the Region 111 projects section chief, and two reactor inspectors who had emergency response duties associated with the fermi Nuclear Plant evaluated Fermi's control room simulator and selected procedures, including the Emergency Operating Procedures (E0Ps). The selected procedures and simulator operations were used to familiarize the NRC team with plant behavior during certain normal and abnormal conditions including those conditions necessitating the use of E0Ps. Additionally, the effectiveness of those procedures during application was assesse Licensee su] port consisted of three professional staff trainers and access to t1e simulator for approximately 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />. The training aersonnel opercted the simulator scenarios and provided guidance on both 1ardware and procedures during those scenario The inspectors found the E0Ps were capable of mitigating all of the ac.cident scenarios that were conducted on the simulator. Although the E0Ps were for the most part clear, operators were required to remember a significant number of " overrides" in order to perform them satisfactorily. One concern was identified with step R/L 4.1, where the flow charts stated " inject with ..." and the text procedure said

" initiate the ..." Since reactor pressure at that point in the procedure would be too high to utilize any of the systems listed, no actual injection would be capable of occurring. In addition, several problems were encountered with the simulator's ability to mimic actual plant performance. For example, during the station blackout scenario, the combustion turbine generators (CTGs) could he started, but the simulator did not recognize attempts to load several of the associated electrical busses, in another case, apparently due to the residual heat removal (RHR) pump C suction valve being closed, the A RHR pump could not be started, in response to the inspectors' observations, the licensee indicated that appropriate followup would be mad No significant safety concerns were noted with the procedures utilized during the inspection including the E0P No violations or deviations were identified in this are I

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l 1 Exit Interview i

The inspectors met with licensee representatives (denoted in paragraph 1) on August 24, 1992, and informally throughout the inspection period-and summarized the scope and findings of the inspection activities. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any .

such documents / processes as proprietar The licensee acknowledged the findings of the inspectio l l

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