ML20042E284

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Responds to NRC Re SALP 11 Board Rept 50-341/90-01.Util Agrees W/Basic Conclusions in Rept. Operations,Maint/Surveillance,Radiological Controls,Safety Assessment/Quality Verification & Security Addressed
ML20042E284
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 04/12/1990
From: Orser W
DETROIT EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-90-0051, CON-NRC-90-51 NUDOCS 9004200527
Download: ML20042E284 (9)


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NRC-90-0051 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.

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References:

1)

Fermi 2 j

NRC Docket No. 50-341 NRC License No. NPF 2)

Detroit Edison letter to the NRC, NRC-89-0300, dated December 26, 1989 1

i 3)

NRC Region III Letter to Detroit Edison SALP 11 Board Report No. 50-341/90001.

dated, March-12, 1990

Subject:

Response to SALP 11 Board Report 3

. 1 This letter provides Detroit Edison's response to Reference 3 Ne agree with the basic conclusions in your report.

As discussed in our letter to the NRC.in Reference 2, an accountability Action Plan was established after the refuel-outage to i

address the increase in personnel errors. This' plan,-established as a result of the Management Accountability Meeting, has been discussed with your staff and is nearing completion of the required activities.

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l Detroit Edison firmly believes that the programs, procedures, and policies already in place ~at Fermi 2 are adequate to ensure continued-improvement in the areas identified. The key i,o continued improvement is proper implementation. Senior management's message to Fermi personnel in this regard is clear; that is the practice.of nuclear professionalism in implementation of individual job responsibilities is of utmost importance., Nuclear professionalism means maximizing individual'and organizational effectiveness. Such programs demand a broad commitment to excellence at all levels of the_ organization.

Fermi 2's Nuclear Generation Business Plan embraces these basic-principles, and personnel will be evaluated based upon their performance.

Generally, activities have been -implemented in a number M : Jeas to continue to improve our overall performance:-

o An Outage Critique Action Plan was issued for the first refueling outage identifying lessons learned and areas needing improvement. The actions identified are continuing to be implemented in support of the second refueling outage.

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1 U. S. Nuclcar R:gulatory Commission l

April 12, 1990:

NRC-90-0051 Page 2 j

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Management has focused additional attention on work planning.

by increasing involvement in the areas of planning and scheduling, day-to-day. interfaces and meetings, and review of job feedback and performance.

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o LFor the second refueling outage, the outage scope is being identified and fixed earlier, greater emphasis.is being placed r

on modification ownership, and mandatory Plant Modification' Review Group meetings (including member participation by NC, i

Technical,' Operations, and Maintenance and Modifications) are:

I planned for all major Engineering Design Packages (EDP) prior-to EDP: issue.-

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1 o. Consistent with the 1990-1994 Nuclear Generation Business Plan, the importance of effective communications, timeliness i

of corrective actions, and the key' elements of nuclear professionalism are being stressed. Performance will be measured by individual ~ work plan svaluations and critiqued.for

4 lessons learned, as appropriate. Poor performance will be acknowledged by supervision and personnel will be held accountable, o

Detroit Edison management firmly believes that adequate _-

measures have been established to assure Conditions Adverse to-Quality (CAQs) are promptly_ identified and corrected...

s Procedure FIP-CA1-01 fully _ prescribes-the conditions and' i

methods for reporting and resolving CAQs.. This procedure was recently revised to establish clear criteria.for evaluating the adequacy of DER responses and justification for extending-l action due dates.. The high level of management review and involvement in DER root cause analysis and corrective action determination is appropriate.-

o Training programs such as root cause analysis / Deviation Event Report (DER)-evaluations, Steps to Effective' Plant Supervision, and Technical Staff and Managers Training are showing results. The full effect of;these programs will be l

realized as more groups of site personnel successfully j

complete them.

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o As part of the implementation of broader Detroit / Edison company initiatives, the Shareholder Value' Improvement Plan l

-(SVIP) is a plan for encouragingi(from the organizational to individual levels) improvements in performance. The SVIP i

provides financial incentives to participants-on an annual basis if specified corporate management and organizational j

goals are met. This will help increase. individual q

accountability and encourage professionalism. This program will continue as long as the company considers it to be a desirable policy.

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10. S. Nuclear R:gul2 tory Connicsion

' April 12, 1290

-NRC-90-0051 Page 3 As discussed during the SALP 11 meeting held March 27, 1990, there j

were specific ongoing activities / improvement identified in several functional areas:

t Operations:

o In order to improve operator performance in the area of infrequently performed events, critiques of operating events and evaluation of crew performances on the simulator are being conducted, To improve administrative controls,_ revisions to the LCO o

tracking system, revisions to the system of tracking abnormal-lineups, and continuing training are being addressed, t

E Maintenance / Surveillance:

o The PRIDE program is being expanded to include more groups in order to assist individuals in accomplishing work assignments.-

Improved work planning is being done by revising procedures to o

enhance technical content and by refining prioritization I

criteria.

o Improvements to the post maintenance. testing program are being made through revisions to procedures and by assigning' responsibility for who defines'the testing.

Radiological Controls:

o The first refueling outage fully tested the radiological protection program. Due to an aggressive shielding program and utilization of industry experience in the controlled shutdown prior to our first refuel outage, radiation exposure L

was significantly reduced in key areas of the plant. :As a result of Radiological Protection efforts, the cumulative l

i exposure during the refueling outage was:200, man-rem, l

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Security:

l o

Attention to detail involving licensing submittals has been-addressed through an increase in the_ level of-skill of l

preparation and review of licensing submittals.

An emphasis on personal accountability will also contribute to re-establishing a high quality level of submittals.

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U, S. Nuclear Reguir.thry Cosmic 2 ion y

f April-12, 1990

-NRC-90-0051 Page il-o To elevate the level of consistency of maintenance support for-security equipment, a joint planning effort involving Nuclear Security and Maintenance has been implemented. Refining of work processes, prompt accomplishment of maintenance work, and improving spare parts availability are some of the activities being addressed.

Radiological Emergency Response:

o The two weaknesses identified in FERMEX '90 will be aggressively resolved with a full report of the actions taken to be addressed in our response to the NRC.

Engineering / Technical Support:

o Management is continvica to utilize the corrective action process to identify tne problems and the associated improvements necessary for engineering support of maintenance and modification activities.

o Engineering is responsible for specifying post modification testing acceptance criteria as part of.the Engineering Design Package (EDP) and will continue to support the EDP throughout J

implementation as part of the strengthened EDP Ownership Program.

o Further improvements to training, particularily for system engineers, are underway covering-in part the areas of design basis and safety evaluations. This should enhance personnel-understanding of safety issues.-

Safety Assessment / Quality Verification:

o Management involvement in problem resolution has been increased by alertir.g department heads of-noted weaknesses in a timely manner, by Superintendent Maintenance followup with j

his staff to assure that noted weaknesses are corrected, and by the developaent of a management accountability action plan.

o Our-program to review and followup on Operating Experience Report (OERs) received aggressive management overview to make it one of the strongest programs in the industry.

Participation by all employes in the activities described above has resulted in our improved SALP 11 ratings. We are in general agreement with the assessments of the functional areas. We feel that continued attention by all employes will ensure an improving trend in our performance.

l U. S. Nuclear Regul2 tory Commis:ica -

- April.12, 1990 NRC-90-0051 Page S-- contains'a list of items for which we have provided clarification regarding statements made within the body of the NRC Initial SALP 11 Report,90-001. These_ corrections / clarifications are provided to you so that_'the final report may reflect these changes.

Should there be any questions in regards to this response', please contact Terry Riley, Supervisor, Compliance and Special Projects, at (313) 586-1864 or Barbara Siemasz, Compliance Engineer, at-(313) 586-1683 Sincerely,

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A. B. Davis R. W. DeFayette W. G. Rogers J. F. Stang Region III l

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Enclosurs to NRC-90-0051 April 12, 1990 Page 1 of 4 Detroit Edison Clarifications / Comments on NRC SALP 11 Report The following is intended to clarify statements made in the SALP 11 Report:

1.

NRC Discussion - SALP 11, page 19, paragraph 1 "The Board noted... missed emergency action levels (underlined for emphasis ]. "

Detroit Edison Clarification / Comment During FERMEX '90, there was only one missed emergency action level declaration in that an unusual event was not declared. Our corrective actions for this concern will be addressed in our response to the NRC.

2.

NRC Discussion - SALP 11, page 21, paragraph 5

" Examples of these... potential design changes (underlined for emphasis] being initiated by both system engineers and design engineers..."

Detroit Edison Clarification / Comment There were two Potential Design Changes that were initiated by both system engineers and design engineers on the issue of actuators on testable check valves. This represents an example of both organizations aggressively attempting to actively support the plant.

The duplication of PDCs did not adversely affect prculem resolution.

3 NRC Discussion - SALP 11, page 23, paragraph 2

" Subsequent to the NRC's Diagnost:.c Evaluation Team (DET) inspection conducted during the previous assessment period, the 1:.censee developed a comprehensive training improvement program to address the specific issues of the inspection. NRC follow-up inspection found that all of these had been acceptably corrected.

However, programmatic weakness still existed for ensuring that training was conducted on procedure r0 Visions [ underlined for emphasis]."

Enclosura to NRC-90-0051 April 12, 1990 Page 2 of 4 Detroit Edison Clarification / Comment We believe that the training on procedure revisions was corrected after the Diagnostic Evaluaticn Team (DET) inspection. Subsequent to the DET finding, Procedure Change Notices disseminated site wide identified training requirements. Procedure FIP-PR1-01 requires training ~be evaluated and established as part of the procedure change implementation plan. This was approved on September 1, 1989 L

4.

NRC Discussion - SALP 11, page 26, last paragraph -

"This breakdown...; OER follow-up did not improve following the' ap_o7e events (underlined for emphasisJ."

Detroit Edison Clarification / Comment Our response to this was made during the SALP 11 meeting on March 27, 1989 We believe we have expended significant resources and-management overview to resolve the issue of timely review of OERs.

In fact, we have been rated' by the Institute of' Nuclear Power Operations as having one of the strongest programs in the

' industry.

5.

NRC Discussion - SALP 11, PLge 27, paragraph 2 "A Level I plant. specific probabilistic assessment...was completed near the end of the assessment period; [ underlined for emphasis]

q' however..."

Detroit Edison Clarification / Comment' The Level I plant specific probabilistic risk assessment was completed in Augast, 1989.

6.

NRC Discussion - SALP 11, page 27, paragraph 2:

I "However, NRC staff required additional-information obtained through repeated correspondence [ underlined for emphasisj to support the review of these responses as exemplified in the reviews : for...CL-89-21,... " '

Detroit Edison Clarification / Comment We have determined that there was no repeat correspondence on GL-89-21.

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Enclosuro to NRC-90-0051 April12, 1990 Page 3 of 4 7.

NRC Discussion - SALP 11, page 27,-paragraph 2 "Also, the licensee was not forthright (underlined for emphasis) in initially informing the NRC, and subsequently justifying,-the use of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts."

Detroit Edison Clarification / Comment Deiroit Edison management was forthright in inferming the NRC regarding the use of 12-hour shifts.

Initially, discussions were held with the NRC Senior Resident Inspector staff. Followup discussions, in response to NRC questions,_were held with the:

'NRC/NRR Project Manger.

It was noted that this action is being-done on a trail basis.-

8.

NRC Discussion - SALP'11, page 27, last paragraph "A large number of license amendment applications"were submitted to the NRC during this assessment period.- The majority of the amendment packages required additional information to allow the.

NRC staff to make final decision on the applications (underlined for emphasis]."

Detroit Edison Clarification / Comment The majority of amendment packages submitted in 1989 did not require additional information to be submitted-to the NEC, although some required ~ followup discussions. Only one 1989 submittal required an additional submittal to the NRC.

9.

NRC Discussion - SALP 11, page 27, last paragraph "In one case, the Cycle 2 Reload.TS change, the. licensee failed to provide accurate TS pages, which led to the need~for an emergency TS change. The TS change was issued in such a manner that the plant would have been operated in'an unanalyzed-condition

, underlined for emphasisj had it not been found by a nuclear engineer."

Detroit Edison Clarification / Comment Even though the Tech. Spec. change was in error, this did not mean the plan would have been. operated.in an unanalyzed condition.

Information loaded into the plant computer was correct and during a required check of the process computer vs. the Tech Spec, the error was discovered.

e Enc 1ccura to NRC-90-0051 April 12, 1990 Page 4 of 4 j

10. NRC Discussion - SALP 11, page 30, paragraph 2 "On December 16, 1989, Fermi synchronized the Turbine generator to the grid, thus ending its first refueling outage on day 98 of a planned 56-day outage [ underlined for emphasisJ."

Detroit Edison Clarification / Comment The-first refuel outage original schedule was-75 days from breaker to breaker.

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