ML20086L404

Forwards Comments on SALP 4 Rept & on Discussions W/Salp Board During 831214 Meeting in Glen Ellyn,Il

ML20086L404
Person / Time
Site:	Fermi
Issue date:	12/29/1983
From:	Wells D DETROIT EDISON CO.
To:	Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20086L384	List: ML20086L404
References
EF2-66-800, NUDOCS 8402080213
Download: ML20086L404 (5)

Text

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Donald A Wells g{

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December 29, 1983 EF2 - 66,800

-Mr. J. A. Hind, Chairman Region III SALP Board Director, Division of Radiological and Material Safety Program U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60107

Subject:

SALP 4 Report for Enrico Fermi Unit 2 Enclosed are Detroit Edison's written comments on the NRC's SALP 4 report and on discussions with the SALP Board during our meeting of December 14, 1983 in Glen Ellyn, Illinois.

If you have any questions, please contact me.

Sincerely, k

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cc: Mr. P. M. Byron Mr. M. D. Lynch Ohko$k PDR 9

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Detroit Edison's Comments on SALP 4 III. Summary of Results Item 10, "Other Quality Activities" Detroit Edison is rated under Category 3 with "X ". The asterisk, as stated in the footnote, indicates "... Major change in performance from previous assessment period."

However, this is in conflict with the statement made on Page 15, Item 10.(b), last sentence, which states, "...This area was not rated in the previous assessment period."

IV.

Performance Analysis 6.

Preoperational Testing Page 9, second to last paragraph states, "... Difficulties experienced by the licensee in several of these areas has resulted in withdrawal of systems from the test schedule. These have included the Primary Containment Local Leak Rate Test and on more than one occasion the Emergency Diesel Generators."

Response

The Local Leak Rate Test and Emergency Diesel Generator Testing were stopped as stated. This action was taken by management to assure quality of the testing program.

Page 9, last paragraph states, "...However, the need for the joint test group and other similar administra-tive controls was identified repeatedly to the licensee by regional and resident inspectors."

Also, Page 10, first sentence, states, "...The inspector's concern has been the reluctance of the licensee to make administrative changes until repeated difficulties are experienced."

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Performance Analysis (cont'd.)

l Response Tha.n_eed.for a coordinating function was recognized in" January, 1982. The Activities Coordination Team

,E c.(ACT) was. established by Stsrtup Instruction 5.3.2.01

. ith one of Its responsibilities being " coordinates w

.u all Startup testing, hydro testing...".

When the level.of testing activities' increased substantially and NRC licensed operating. personnel became available, T'

the Joint Testing Group (JTG)swas organized. This group was establishid to de'al~with testing and plant i 3

- operation in a mor'e controlled manner involving the

'l permanent plant operating. staff: the Assistant Plant a

t v f; Superintendent, the Plant Operations Engineer, and the

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Nuclear Shift Supervisor on shift dealing directly with the,Startup Director, his assistant, and the Shift Test Engineers.

Page 10, first paragraph, last sentence states,

...Another concern is that organizational structures are complicated and many contract personnel are placed in key positions.'"

Response

IV

,The NRC concern about contract personnel was clarified

~ on December 21, 1983. They felt'that these contract A

personnel will galb much experience:and then leave the 2

.c project impacting'" institutional menocy".

Using contractors in these positions was done intentionally to.obtain experienced talent to assist, guide, direct, or do activities related to the construction, testing,

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and startup of the plant _in areas"we could not hire permanent employes with sufficient' experience. Although t

. contract personael ;'re in key positions, we had planned and have assigned in all cases support for these indi-viduals with Detroit Edison employes who will be assigned to Nuclear Production, Nuclear Engineering, Snd other corporate' organizations which will continue to support Fermi 2 through itis operating life. These Detroit

-Edison employes include management, engineers, technicians, 1&C and' maintenance personnel. This action is intended

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to upgrade the experience of the permanent Detroit Edison 7-

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employes and to minimize the loss of " institutional memory".

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Page 3 IV.

Performance Analysis (Cont'd.)

11. Liceasing Activities Two statements in the Licensing section are of concern since they are misleading.

The first, " reluctance to perform an IDVP", is inconsistent with the facts.

After the July 15, 1982 meeting with NRR in Bethesda, attended by Mr. Denton, Detroit Edison concluded that there was no need to perfonn an IDVP. The NRR meeting minutes issued approximately two months later (September 22,1982) stated this conclusion slightly differently. After informal discussion, NRR issued a letter on October 29, 1982 requesting an IDVP. Approxi-mately one month later (December 1,1982) Detroit Edison committed to perform an IDVP and submitted a proposed scope. This is hardly reluctant.

At the Decembe' 14, r

1983 SALP meeting, it was stated that the IDVP was apparently hurried.and that Detroit Edison appeared to have pressured CYGNA to get it done quickly.

It must be remembered that the NRC requirement was to have the IDVP done 60 days before fuel load which, at the time, was scheduled to be June,1983.

It should be noted that CYGNA expended 8000 man-hours in the four month period of the review.

The second area of concern arises from the statement that

...the Licensee was perceived as lacking an understanding of issues in the I&C area and their relctive importance to the safety of the plant." As stated at the December 14, 1983 SALP meeting, Detroit Edison takes great pride in its constant concern and efforts to assure a safe plant and considers the statement invalid. The statement apparently l

arises from the " legalistic" arguments used by Detroit l

Edison while negotiating the Standby Liquid Control (SLC) issue.

Detroit Edison maintains that its position on the l

SLC issue was proper and appropriate. With that position l

formulated, it may be true that legalistic arguments were used in addition to technical ones. However, this has no i

bearing on Detroit Edison's understanding of the importance of the issue to plant safety.

In fact, since the inception of' the Fermi 2 oM0 in 1970, the System Engineers have had the responsibility to assure that proper safety standards were incorporated in system design and to also monitcr the performance of similar l

ystems in other plants. Any problems identified were investigated and the results of the investigations incorporated into the Fermi 2 design as appropriate.

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Page 4 IV.

Performance Analysis

11. Licensing (Cont'd.)

The record clearly shows that Detroit Edison's Fermi 2 PMO, the Nuclear Operations organization, and Detroit Edison man 1ement at all levels have displayed by word and action a continuing concern for all aspects of plant safety.

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