ML20151Y732
| ML20151Y732 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/29/1986 |
| From: | Mccarthy W DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| VP-86-0008, VP-86-8, NUDOCS 8602130115 | |
| Download: ML20151Y732 (34) | |
Text
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INIORIIY ECUTlh Caller J. McCarthy, Jr.
i 0
Chairman of ths Board fl k-k k
2000 Second Avenue
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31 3
\\ ake January 29, 198r, IIL M VP-86-0008 Mr. James G.
Keppler Regional Administrator Region III U.
S.
Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr.-Keppler:
Reference:
1)
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 2)
NRC to Detroit Edison Letter,
" Requesting Information Pursuant to 10CFR50.54(f)". December 24, 1985 3)
Detroit Edison to NRC Letter,
" Reactor Operations Improvement Plan", VP-85-0198, October 10, 1985
Subject:
Response to Request for Information Pursuant.
This letter is subm!tted in response to the Nuclear Regulatory Commission's request for information pursuant to 10CFR50.54(f) which is cited as Reference 2 above.
Detroit Edison is committed to the highest standards for both managing and operating the Fermi 2 facility.
Enhancement of management and management practices is essential to attain the operating and performance goals set for Fermi 2.
We understand what needs to be done to improve regulatory and operational performance and are prepared to take the actions necessary to effect such improvements.
The following three sections address the issues identified in Reference 2 above:
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Mr. ' James G.
Keppler January 29, 1986 VP-86-0008 Page 2 l
1.
ADEQUACY OF. MANAGEMENT, MANAGEMENT' STRUCTURES AND SYSTEMS Detroit Edison management needs to strengthen the sensitivity, discipline and. responsiveness of the Nuclear Operations organization.
In this regard, Nuclear Operations management is developing a Nuclear Operations Improvement Plan which addresses planning, accountability, attitude, communications, teamwork, follow-up and training in the entire organization.
By developing a plan directed toward eliminating deficiencies in these areas, improvements can be expected in overall management, in the ability to recognize and respond to problems which could affect plant safety and in controls to assure improved regulatory, operating, engineering, maintenance and security performance.
A plan is being developed and will be reviewed in detail by an Overview Committee prior to implementation.
The plan will be initiated no later than May 1, 1986 and fully implemented by July 1, 1986.
The role of the Overview Committee is more fully described below.
Management Detroit Edison is evaluating the key management personnel at Fermi 2 to assess performance and effectiveness.
A management change will be made on February 1, 1986 to accommodate the retirement of Wayne Jens, Vic e-P re s id en t, Nuclear' Operations.
Frank Agosti.
Manager-Nuclear Operations will succeed Wayne Jens as Vice-President beginning on that date.
Further, I recognize-that additional strengthening of the Fermi 2 management is appropriate.
Consequently, I as seeking additional officer candidates with nuclear operating experience from outside the Company to provide additional management which I feel is required to achieve the ' goal of operating excellence.
These individuals will be charged with completing reviews of the existing Fermi 2 management and making such changes as deemed desireable.
Mr. Agosti will report directly to me until the above officers have been selected.
I have directed the President and Chief Operating Officer of Detroit' Edison, Charles M.
Heidel, to assist me in monitoring the performance of the Nuclear Operations organization.
The Nuclear Quality Assurance organization will report to Mr. Heidel.
The President will also assure that any other corporate resources are
Mr. James G. Keppler January 29, 1986 VP-86-0008 Page 3 provided which are necessary to support or audit th.e Nuclear Operations organization.
'f h i s change in control
-will enhance the use of Quality Assurance as a management tool to improve regulatory and operating performance.
In addition, three other Detroit Edison officers will provide independent overview of the Fermi 2 Engineering, Security and Administrative organizations.
These-three officers will report to the President in this matter.
Further, to assist in this effort, we formed the Fermi 2 Independent Overview Committee which is comprised of recognized nuclear industry consultants.
This committee will provide Detroit Edison management with a critique of the present Fermi 2 management.
The Overview Committee has already conducted interviews with management personnel from both the site and corporate organizations.
A preliminary report has been presented
~by the Overview Committee to a committee of the Board of Directors, the Board Nuclear Review Committee. explains the role and schedule of the Overview Committee.
Detroit Edison will strongly consider the Committee's recommendations for management improvement.
Mannemment Structure The concept, structure and functione of the Nuclear Operations organization have been reviewed by independent management consultants and many of their recommendations are being implemented.
In addition, the Company has been seeking other ways of improving and the following are some examples.
Nuclear Operations is currently working with a professional organization and management consultant from the Detroit Edison Corporate Office to improve the interface between Nuclear Engineering and Nuclear Production.
Nuclear Engineering and Nuclear Production.are conducting joint sessions to clarify responsibilities, agree on work priorities and to improve communications.
In July, 1985, engineering for the Fermi plant was reorg'anized to consolidate engineering responsibilities in the Nuclear Operations organization under the leadership of an Assistant Manager.
The present engineering organization has assumed full control of engineering and is augmented by a single architect / engineer with a dedicated staff on site.
Since engineering problems hava occurred during this
f 4
Mr. James G.
Keppler January 29, 1986 VP-86-0008 Page 4 transition period, the effectiveness of the present eng in e e r ing organization and its procedures are being reviewed by management.
The architect / engineer will review the procedures currently being used by the Nuclear Engineering organization to assure that proper control of the engineering process is maintained.
The office of the Manager-Nuclear Operations was temporarily moved to the plant office building near the Plant Manager.
The purpose of this move was to permit the Manager to monitor day-to-day work to insure that the Engineering organization, the Regulation and Compli~ance organization and Nuclear Operations Service organizations are being responsive to the needs of the plant.
This effort has reinforced the operating authority of the Plant Manager and focused all nuclear operations resources toward support of Nuclear Production.
I intend to have Frank Agosti as Vice-President continue to occupy'that office for an interim period.
The Fermi 2 Independent Overview Committee v.ill continue to examine the management structure and pere nnel to identify further improvements which would enhance regulatory and operating performance.
Each recommendation will be considered by management for implementation.
Management Systems and Practices After the success of the Fall 85-01 Outage, it became evident that a dimilar planning and centrols effort to plan, coordinate and follow-up is necessary not only for outage work but also for day-to-day work activities.
Each organization will be evaluated to' assess the planning, coordination and completion of its activities.
Where improvement needs are identified, these will be included in the Nuclear Operations Improvement Plan.
An evaluation of Nuclear Security was conducted to identify areas for improvement in regulatory performance.
As a result, Nuclear Operations management and Nuclear Security developed a Security Improvement Plan to address the inordinate number of security plan violations which occurred in the last quarter of 1985.
The major elements of the Security Improvement Plan were presented to the NRC staff on January 17 and included aggressive immediate actions, long-term corrective
Mr. Ja=ao G.
Kappler January 29, 1986 VP-86-0008 Page 5 actions, time frames for accomplishment and performance indicators.
That Plan will be discussed with the NRC in a separate meeting.
The Security Improvement Plan will incorporate recommendations from the Independent Overview Committee where appropriate.
An evaluation of plant maintenance activities showed two areas for improvement which would enhance regulatory and operating performance. These two areas are post-maintenance test requirements and techniques for removing and placing into service critical plant equipment.
The work order process has been modified to more clearly state the post-maintenance requirements and additional documentation requirements that must be met before the shift operhting authority can accept a component or system for service.
These improved management controls have resulted in better control over work and documentation for all maintenance activities.
The procedures by which instrument repair technicians remove and place equipment back into service have undergone significant revision.
In addition, instrument repair technicians have taken additional training and on-the-job instruction regarding the proper techniques to be used.
These. efforts will reduce the chance of making errors and thereby reduce the impact maint nance activities might have on plant operations.
The need for continuous attention to management practices for improved regulatory performance is recognized.
The Detroit Edison corporate organization and management development consultant has been directed to work with Fermi 2 management to focus attention on their management practices within Euclear Operations.
As part of this effort, a survey on organizational climate and management practices has been conducted.
The results of this survey will provide data to guide both individual and group management practice improvements.
The sensitivity of the Company and Nuclear Operations, specifically, to potentially significant conditions has been substantially heightened as a result of the premature criticality incident.
Nuclear Operations management'recog'nizes the need to communicate certain events regardless of the reportability requirements.
Recognizing that communication and response improvements between Detroit Edison and the NRC are as important as.
recognizing significant conditions, a Nuclear Operations Directive has been prepared which prescribes policy
Mr. James G.
Keppler January 29, 1986 VP-86-0008 Page 6 supporting a more effective dialogue between the two organizations.
In addition, Detroit Edison has contracted with a consulting company to conduct a series of workshops with various management levels to improve their sensitivity to issues and responsiveness to the NRC.
The consultants have already conducted interviews with site personnel as the first phase of developing the workshop.
. Subsequent phases of this workshop will involve the operating staff where reportability concerns and issues will be addressed to improve sensitivity.
To enhance awareness of, and thereby sensitivity to, nuclear activities on the part of corporate management and the entire Nuclear Operations organization, a professional communications unit has been active on-site since August 1,
1985.
This unit produces three publications which provide information.to the site and corporate organizations.
These publications include the monthly Moderator, the Weekiv Moderator and daily
" Management Update" messages distributed using the site computer communications system to generate a bulletin board newsletter.
In addition, banners and other posters have been displayed at the site entrance and exit to remind all personnel of their key role in attaining the regulatory and operating performance goals set for Fermi 2.
2.
READINESS FOR RE-START AND POWER ESCALATION Detroit Edison has concentrated on correcting errors that have been made in its operations and is committed to continue the Reactor Operations Improvement Plan.
The Reactor Operations Improvement Plan was developed and implemented to improve operating performance of Fermi 2.
That plan was directed at reducing the frequency of operational occurrences and technical specification violations.
The positive trends which have been achieved.since this program was implemented are expected to continue.
The performance to date and indicators for the Reactor Operations Improvement Plan are shown in Attachment 2.
l.ny startup decision will require verification that satisfactory trends are continuing.
The Independent Overview Committee will be reviewing readiness of personnel and equipment to support restart and subsequent. modes of operation.
The progress on, and resolution of, those system and equipment problems which are. impediments to startup, or for which the progress or
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Mr.-James G. Keppler j
January 29, 1986 VP-86-0008 Page 7 resolution is. expected to result in better operating and regulatory performance-are presented in Attachment 3.
The last startup at Fermi 2 on October 3, 1985 was successful and it is in t en'd ed that similar steps and procedures be followed in preparation for the next j
startup.
The operators who will be responsible for i
reactor startup will have recently conducted reactor startup evolutions on the simulator.. Attachment 4 describes'the actions the plant staff will take to prepare the plant for startup.
The actions that will occur after startup but prior to Test Condition 1 are covered in Attachment 5.
The additional tests illustrate the retesting to verify l
performance before moving to the next Test Condition.
The tests required at other power ascension conditions are delineated in the FSAR and the Startup Phase Test Program.
The six Test Conditions have been established as hold points to assess overall plant performance.
Before startup and before proceeding to any subsequent Test Condition, approvals'will be required from plant management and Corporate management after receiving a review and recommendation from the Independent Overview Committee.
Overall plant performance will be assessed utilizing the following:
A.
Reactor Operations Improvement Plan, to assess i
plant operations; B.
Startup Test Phase results, to assess plant equipment performance; C.
Independent Overview Committee, to assess overall performance.
l The Overview Committee will make a recommendation to me and the Board Nuclear Review Committee regarding movement to the next Test Condition.
My approval and review by the Board Nuclear Review Committee are required before the plant can proceed.
3.
IMPROVED REGULATORY AND OPERATIONAL PERFORMANCE l'
i The plans identified in th'is response represent Detroit Edison's commitment to improving the regulatory performance, operating performance and management
Mr. James G. Keppler January 29, 1986 VP-86-0008 Page 8 performance at Fermi 2.
These plans will be monitored to assure that the improvements have been effective.
Should it become evident that these plans need modification to effect further regulatory or operating performance improvements, such changes will be made.
As an example, any development needs or weaknesses in.the radiological controls area will be addressed by the Radiological Improvement Plan.
Changes may immediately occur from the commitment to consider each recommendation received from the Independent Overview Committee.
Detroit Edison established a program called SAFETEAM in 1983.
This program was a first for the commercial nuclear power industry in that it provided a method by which anyone who is currently working or-had worked on the Fermi project could anonymously have any of their concerns about the plant or its operation investigated.
This program has been directed by the Detroit Edison Auditor and operated by Detroit Edison personnel.
The program has worked well.
However, it is our plan to provide additional independence from the Company by transferring direction of the program.to another company.
A Detroit Edison Company subsidiary, SYNDECO, is currently operating similar programs at four other nuclear power plant sites.
It is our intent to contract with them to conduct this program at the Fermi site.
It is understood that. nuclear plants with high availability, small numbers of both forced outages.and personnel errors, few unplanned scrams, few recurring events, and low personnel radiation exposures are generally well-managed overall.
Such plants are more reliable and can be expected to have higher margins of safety.
Detroit Edison is committed to such attributes for Fermi 2 and has adopted certain Institute of Nuclear Power Operations (INPO) Performance Indicators as an aid in monitoring plant performance.
Performance against these criteria has been tracked where applicable during the startup phase of operations.
Additional indicators will be added to help identify areas needing corrective action as appropriate.
The equipment problems and personnel errors have been indicative of less-than-acceptable performance.
We acknowledge that and we regret it.
Although these problems and errors have not jeopardized the health and safety of the public, we nevertheless are committed to
Mr. James G.
Keppler January 29',
1986 VP-86-0008 Page 9 correct the trends which could lead to safety-concerns if left uncorrected.
Detroit Edison believes that with the continued success of the Reactor Operations Improvement Plan, the implementation of the Security Improvement Plan, and the actions taken as specified-in and Attachment 4 the plant will be ready to resume operation up to 5% power.
Detroit Edison will meet with the NRC staff to discuss its overall performance and readiness to proceed above 5% power.
It is my intent to maintain oversight and review by the Independent Overview Committee, the Detroit Edison Board Nuclear Review Committee, and myself until we are i
satisfied that this plant with its new management, its plant operators, and its support staffs have 4
demonstrated satisfactory performance as measured against other plants and INPO performance. criteria.
Fermi 2 will only be operated in a manner which ensures I
the public Laalth and safety.
For this reason, Detroit Edison believes that the Fermi 2 license does not need to be suspended, revoked or otherwise modified.
Very truly yours,
(/ C. gQ
)
Attachments i
cc:
Mr.
P.
M.
Byron Mr.
M.
David Lynch Mr.
G.
C.
Wright USNRC Document Control Desk Washington, D.
C.
20555 E
Mr. James G. Keppler January 29, 1986 VP-86-0008 Page 10 OATH AND AFFIRMATION To the best of my knowledge and belief the statements contained herein are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Detroit Edison employes.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
[L s.'
NL M.
J.hjCart'hy, W1ter Jr.
Chairman of the Board Detroit Edison SUBSCRIBED and SWOR to before me this~
ay of Se d u M A 19 6
[/
f MM Notary Public MARCIA BUCK Notary Public, Washtenaw County, MI My Commission Enires Dec.28,1987
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TABLE OF ATTACBERTS U
EASE 1-1 Fermi 2 Independent Overview Committee 2-1 Reactor Operations Improvement Program Indicators 3-1 System & Equipment Problem. Resolution or Progress 4-1 Actions to Insure Readiness for Reactor Restart 5-1 Actions to be Completed After Restart Prior to Test Condition 1
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ATTACHMENT 1 Fermi 2 Indenendent Overview Committee Recognizing that an introspective self-examination is by its very nature a limited undertaking, Detroit Edison has sought an independent, unbiased review of its management, organization and improvement programs.
A group of recognized nuclear industry experts with a broad range of management and operating experience has been retained to operate as an Independent Overview Committee.
This Overview Committee has an initial management assessment role and then a follow-up assessment and approval role for power ascension.
The charter for this Overview is provided herein.
The committee has a specific charge from the Chief Executive Officer to report findings and make recommendations regarding the management of Fermi 2.
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f.liARIER FEEMI 2 INDEPENDENT OVERVIEW CGtMITTEE PURPOSE The purpose of the Committee is to provide corporate management and the Board of Directors of Detroit Edison an overview evaluation of the operation of Fermi 2 and the performance of Nuclear Operations management. The Committee will provide advice concerning changes in management, management systems or structures and in the operation of Fermi 2 that will assure its safe operation.
MEMBERSHIP Jack Calhoun General Physics Corporation, Chairman Harry J. Green, Consultant Leo C. Lessor, Management Analysis Company Salomon Levy, S. Levy, Inc.
Murray E. Miles, Basic Energy Technology Associates Inc.
James V. Neely, Nuclear Power Consultants, Inc.
REPORTING The Committee will report its findings and recommendations to the Chief Executive Officer of Detroit Edison. The President of Detroit Edison will be available to participate in the deliberations of the committee when required. The Board Nuclear Review Committee will attend some of the meetings of the committee and will remain cognizant of its findings and recommendations.
COORDINATION OF THE COMMITTEE'S ACTIVITIES The Assistant Manager, Regulation & Compliance Nuclear Operations, Detroit Edison, or his designee, will coordinate and assist where necessary in the activities of the Committee. He will provide any reports, memoranda, and letters the Committee requires and will arrange for meetings, interviews, visits to the plant, trips, etc.,
required by the Committee. He will act as contract administrator for all contracts required to carry out the Committee's activities.
ANTICIPATED MEETING SCHEDULE Week of January 6 - 11 Week of January 27 - 31
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Week of February 24 - 28 One day per month for the remainder of 1986 J
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CHARTER Fermi 2 Independent Overview Committee Page 2 SCOPE Management Evaluation Tank Prepare a report which identifies, evaluates, and analyzes any management, management structure, and system problems and root causes of these problems. This report should specifically address Item 1 Page 2 of the December 24, 1985, Nuclear Regulatory Commission letter from James G. Keppler to Wayne H. Jens.
Present the Overview Committee report to Detroit Edison senior manag emen t, and representatives of. the Detroit Edison Board of Directors in a meeting to be held on February 7,1986, or soon thereafter.
Review the Improvement Plan prepared by the Nuclear Operations management staff in response to the problems identified by the Overview Committee.
Monitor during 1986 the actions required in meeting the Nuclear Operations Improvement Plan and recommend modifications to the plan as appropriate.
Reactor Onerations Review Review the Reactor Operations Improvement Plan presented to the NRC in letters dated October 10, 1985, and November 27, 1985, and any future modifications to this plan. Address specifically our plans to restart the plant in February. Review the performance of the plant and organization during the restart of the plant af ter the Fall and Winter 1985 outage. Based on this review, recommend further action required for increasing reactor power beyond 5% to the next power plateau.
The committee will review and comment on Detroit Edison's response to the December 24, 1985, letter. Specifically, the committee should evaluate whether the plans presented in this letter adequately cover the necessary conditions that should be met prior to resuming operation. Since the management evaluation task may have uncovered management deficiencies that should be corrected prior to restart, we would like to have those pointed out to us in your response and comments to our draf t letter.
The committee will review and provide any necessary advice concerning each test condition up to and including commercial operation, warranty
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test, and full power operation. This power escalation program will be submitted to the NRC in response to the December 24, 1985, letter.
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.ATTACRMENT 2 Rome tor Onerations Imnrovement Plan Statys The Reactor Operations Improvement Plan was submitted to the NRC on October 18, 1985.
Included herein.is a status report on the commitments contained in that letter.
Sixty-one of
.the sixty-four commitments have been implemented.
Monitoring information is also provided herein to demonstrate the effect the Plan has had on plant operations. The goals identified in this plan are ones which are indicative of a mature operating plant.
Management expects positive trends to continue and will continue to monitor them. Any deviations away from the desired trend or goal will prompt management review and corrective action, as appropriate, to assure that progress toward the objectives of the Plan continues.
It is anticipated that as the Fermi 2 operating experience increases, we will move even closer to these goals. It is important to note that these goals may require adjustment, either up or down, should management determine that the goals are too limiting or are otherwise not achieving the desired results. Progress on the Plan will be reviewed with the Independent'Over Committee.
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REACTOR OPERATIONS IMPROVEMENT Pl.AN Commitment Status Action Item
- Status
- 1. Current dated LCOs are displayed in hard copy.
Complete
- 2. The DOT system of flagging control board system and Incomplete component abnormal conditions is being made more (QSF issued) visible and meaningful in correlation with the outstanding work orders.
- 3. a.
Tagging and work orders are being modified to Complete more clearly specify post-maintenance test re-quirements, b.
Indicate which documents require revision.
Complete
- 4. As a long-term action, administrative work procedures Partially Comp.
will be simplified or clarified to consistency.
(Training Req'd.)
- 5. Item 5 Deleted.
N/A
- 6. Nuclear Operations personnel have been advised to Complete consider the consequences of taking even the simplest actions.
- 7. Personnel have been advised that' it is equally Complete important that the error be communicated so that appropriate operating staff or management action can take place in a timely manner.
- 8. The reduction of open work items and increased Complete.
control by the operating staff over open work items will reduce the number of unexpected operational occurrences and violations.
- 9. The Nuclear Training organization is developing Complete and, when possible, modifying existing scenarios to exercise the requalification classes on routine plant startup and operation.
- 10. Emphasis is being placed on normal system line-up, Complete operation and responses required.
- 11. The importance of logging activities on charts at Complete shift turnover, system startup and transient initiation is stressed as is evaluation of plant conditions using the Sequence of Events Recorder.
- NOTE: All " Completes" have been verified by Nulcear Quality Assurance 2-2
.a
- 12. Thi Plcut Mnntgsr or the Supsrintsudant-0parations Co plets ora costing individually with etch NSS, NASS and Shift Operating Advisor (SOA).
- 13. To improve the quality of Control Room operations Complete logs, entries into the Nuclear Supervising Operator's (NS0) log are being made by the NASS as an interim measure.
- 14. The Operations Engineer or designee is_ reviewing Complete the NSS and NSO logs at least daily, except week-ends, to assure that they are being kept properly and that the proper entries are being recorded as the plant is being operated.
- 15. Superintendent-Operations is reviewing the NSS and Complete NSO logs on a periodic basis to provide feedback to the NSS and the Operations Engineer.
- 16. The NASS has been assigned to the Control Room Complete proper as a permanent duty station on shift.
- 17. The NASS has been placed in charge at the controls Complete area of the Control Room during planned reactivity manipulations, plant startups and shutdowns, multiple plant testing activities and outage periods when sign-ificant maintenance is in progress.
- 18. The role of the Control Room NSO has been clarified Complete to assist the NASS or NSS in directing plant act-ivities.
- 19. The duty station of the SOA is now the Control Room.
Complete
- 20. SOAs have increased their involvement in activities Complete in the Control Room.
- 21. Shif t Technical Advisor (STA) monitors for hardware-Complete related problems associated with Control Room equip-ment which may not otherwise be identified or tracked.
- 22. The STA is concerned with resolving Control Room Complete problems like nuisance annunciators and alarms in addition to normal duties.
- 23. The Reactor Engineer has increased participation in Complete reactor operations and is closely following, analyzing and reviewing significant reactor evolutions.
- 24. Operations Engineer has increased involvement in Complete operations by following and reviewing performance of shift activities against established plans and checking the quality of Control Room logs.
- 25. The NSS has been given the authority to control work Complete i
in the plant by setting priorities and work load.
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. _, _,...- _ _ _. _ ~ _ - -
- 26. Item 25 is cecomplish:d thrcugh interfcco with tha plant Corp 1sto Outtgs M:n: gem:nt orgcnisation and through dirset involvement in work planning meetings.
- 27. The Superintendent-Operations periodically and without Complete notice has been observing shif t operation activities.
- 28. The Superintendent-Operations gives feedback to the Complete Nuclear Shif t Supervisor (NSS) or Nuclear Assistant Shift Supervisor (NASS) and documents any observations.
- 29. The Superintendent-Operations observations include Complete actual plant operation's and the review of operations administrative activities such as shift turnover, log review and plant status system updates.
- 30. The advisor to the Plant Manager.is conducting more Complete frequent, regular surveillances of Control Room operations.
- 31. The advisor observes the performance of the Control Complete Room crew, reads the log kept by the Shif t Operating Advisor (SOA), discusses any problems with the SOA reads the log kept by the Nuclear Supervising Operator
~
(NS0).
- 32. In addition, the advisor observes plant parameters Complete and provides his observations to the Plant Manager.
- 33. Following turnover from the off going NSS, the NSS Complete conducts a briefing of shif t operating personnel.
- 34. Supplemental training on the current requirements for Complete control rod manipulations, including the reduced notch worth pull concept, has been conducted with all six shifts of plant operators.
- 35. Training is emphasizing the important differences Complete between the plant and the simulator during training.
- 36. The operations staff is providing on-shift training Complete regarding significant plant and procedure changes.
- 37. An interim status chart has been implemented to Complete track LCOs on equipment required by Technical Specifications which affect shif t activities.
- 38. The work order, tagging and equipment status system Complete has been modified to more clearly specify post-maintenance test requirements.
- 39. Human factors methods are being applied to the Partially administrative procedures to make them more Complete.
streamlined and more user oriented.
(Training Req'd) 2-4
- 40. LERs - cro. bsing t
- a. Tracked.
Complete
- b.. Trended so that symptoms of potential problems Complete can be diagnosed early_ to prevent recurrence.
- 41. ' Emerging trends and selected LERs are being evaluated Complete utilizing proven, systematic problem-solving methods to identify causes and remedial as well as preventive corrective action.
- 42. Corrective action taken is being~:
1
- a. ' Tracked to Completion.
Complete b.
evaluated for effectiveness.
Complete
- 43. The corrective action process is being further enhanced by:
Refinement of procedures associated with the Complete a.
proc es s.
b.
Structured training for personnel involved in the Complete evaluation and. review phases of the process.
- 44. Corrective Action Procedures have been issued for Complete implementation.
- 45. Corrective Action formal training for selected Complete personnel is scheduled to begin the week of November 4th.
- 46. Actions previously. initiated by QA organization, will Complete improve the timeliness and overall effectiveness of the corrective action process.
- 47. a.' In each one-on-one session between the Plant Complete Manager or the Superintendent-Operations and the NSS, NASS, and SOA, employes are reminded of their responsibilities; delegated authority and account-abilities; of their expected job performances and l
of their relationship with other shif t members.
i j.
~b.
Meetings with employes down to the group super-Complete visor level were held during the week of September 17 to discuss the status of the plant, the status of NRC/ Deco interactions and to remind each employe of his part in improving the performance of Fermi 2.
- 48. The NSS is responsible for ensuring that the ability Complete to provide, proper direction is not compromised by an excess of work or testing.
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- 49. Fcr this r200cn (Item 48), the NSS is centro 11ing work in the Complete plant by datercining priority and cesunts of work for the shift.
- 50. Work in the plant is identified and scheduled on a complete Plan of the Day.
- 51. Each working day, a planning meeting is held with the Complete day shift NSS in attendance.
- 52. The NSS provides input relative to anticipated plant Complete operations over the next few days so that tasks can be identified and prioritized on the schedule accordingly.
- 53. The NSS establishes work priority and provides Complete direction as to the amount of work to be scheduled.
- 54. The Plant Support Engineers review Engineering Complete Evaluation Requests (EERs) and Engineering Design Packages (EDPs) to reduce plant changes to only those necessary for safe plant' operation.
- 55. The NSS conducts status meetings at 0600, 1800, and Complete 0100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.
- 56. These meetings (Item 55) are held with representatives from Complete the various work groups to monitor progress on important items as well as to allow additions to the work schedule or review changes in course as directed by the NSS.
- 57. Goals have been established for certain key Complete operational activities.
- 58. Detroit Edison has established objective monitoring Complete criteria to determine the overall effectiveness of the Reactor Operations Improvement Plan.
- 59. Detroit Edison organizational units have been Complete assigned responsibility to track and trend perform-ance with respect to each of these criteria.
- 60. Management will be monitoring this performance so Complete that adjustments can be made, if necessary.
- 61. The Nuclear Quality Assurance organization of Nuclear Complete Operations will provide independent verification of effective implementation oi the program utilizing audits and/or surveillance methods.
- 62. Results will be reported to Nuclear Production and Complete Nuclear Operations Management.
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i Remetor Onerations Tenrovement Program Indicatorm Comi At o
The goal is to minimize the number of open work orders.
o The dotted line represents the expected while the solid line represents the actual results.
o As of January 26, 1986 there were 173 open work orders.
Coal Br o
The goal is to minimize the number of field complete (F.C.)
EDP's open for greater than 30 days not yet closed and signed off by the Plant Manager.
o As of January 26, 1986 there were 41 open F.C. EDP's.
Coal Cr o
The goal is to minimize the number of outstanding Control Room problem annunciators.
o The dotted line represents the expected range. The solid line represents the actual results.. A specific breakdown between engineering and broke /fix annunciators is also presented.
o As of January 26 1986 there were a total cf 39 outstanding 3
Control Rcon problem annunciators.
Goal Di o
The goal is to perform all surveillance procedures on time, including the grace period and to minimize the number requiring use of the grace period.
o For the week ending January 26, 1986 there were 100%
eurveillances completed on time including the grace period and there was one (1) surveillance not completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entering the grace period.
Goal Er o
The goal is to minimize the number of outstanding, time-sensitive LCO's.
o As of January 26, 1986 there were zero (0) outstanding, tims-sensitive LCO's.
Coal Fr o
The goal is to minimize the number of Reportable Operational Occurrences.
o For the week ending January 26, 1986 there were zero (0)
LER's.
o The four week rolling average as of January. 26, 1986 was 0.25.
2-7
GOAL A:
Minimize nn=her of open PN-21's (Work Orders)
Oh ioc t ivas :
TOTAL 150 Management Attention Level 110 Expected TOTAL N
l U
l M
400 i
B l
E l
R l
l o
300 l
P l
E l
N l
219 W
200 l\\
O l 171 173 15N0k44
- - - - /- - - - - - - - - - - - - - - - 15 0 MA L R
I%
K l
1 145
\\
l 121y37 o
100 l-------
110 R
l Expected D
l E
l R
l S
0 l
1 I
I I
I I
I I
I I
I I
I I
I I
I I
I l
December l
January l
February l March 1
1 8
15 22 29 5 12 19 26 2 9
16 23 2 9
16 23 30 6 NOTE:
Includes plant system related PN-21's (work orders) only.
During an Outage greater than one week in duration, total numbers can be increased by a factor of 2.5.
Because the trend is above the Management Attention Level, an inquiry was prompted to identify the source for the increasing trend. The trend is above the Management Attention Level due to a controlled, deliberate increase in known work items to support reactor restart.
2-8
COAL 33 Mimicino numb:r of EDP's which remsim cpen efter c:rk his been comnleted.
i.e..
field comnlete.
Objective:
EDP's open 30 days
- 15 Management Attention Level after field work 7 Expected complete
}
l l
200 l l
180 l
!! umber l
of 160 l Fic1d l
l Conclete 140 l t
EDP's l
120 l l
100 i ODen l
Pact 80 l 30 l
Days 60 l 1
40j
-38 42'4141 32 20 l l------------------------------------------------------
15 !!AT, 10 l l______________________________________________________
7 0 I Cxuected I
I I
l l
l I
l l
l l
l
[
l l-l Deconber l
January Februt.ry
!! arch l
1 8
15 22 29 5 12 19 26 1 9
15 23 ?
9 le, 23 30 6 NOTE:
This trend remains above the Management Attention Level. A management inquiry has revealed that the rate of closure has remained relatively constant due to the large number of EQ EDPs closed out during the 85-01 Outage.
2-9
'G0AL Ct' Misiciso tumbsr of issp9rtblo cr esntinuoucly alcraing annunciators in Control Room ob jec tive:
15 Management Attention Level
- 10 Expected 100 l I
Engineering Fixes = 23 I
Other Fixes
= 16 90 l Total
= 39 I
I 80 1-I Tbtal Number of Annunciators
= 1224 1
70'l l
Outstanding I
60 i Control l
I Roon 50 51 1
Problen *-
l 46 40'l l
M Annunciators I
\\
39 l
36'3C 38 -35 Requiring 30 l I
Engineering i
21 ' 2 3 20 1 Fi::
Ii____________________L5.__15
______________________________15,nt i
19 l------------------------------------------------------
10 I
': ncted i
I O l 1
I l i
J l
i I
I I
'l I
I I
I I
I I
I l
December l
.Tanuary l
February I
- arch i
1 3
15 22 29 5 12 19 26 2 0
16 23 2 0
16 23 30 C NOTE:
Problem annunciators are all inoperable, nuisance, setpoint.
logic, etc. related annunciators.
Management has requested a schedule and plan for the engineering items. Additional attention is being directed to expedite resolution of the other fixes required.
2-10
i COAL De Perform Surveillanc es on timo minimizing using grace neriod objective: Surveillances completed on time including grace period:
99% Management Attention Level
- 100% Expected Surveillances not completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of reaching the grace period' 7/ week Management Attention Level 5/ week Expected i
101 l l
Surveillances l
100 F100-100- 100-100-100-100
. Completed
[
99 l on Time 1
98 l Including l
97 l Graco Period l
96 l
(%)
I 95 l l
I I
I I
I I
I I
I I
I I
I I
I I
I I
I l
December i
January l
February i March 1
1 8
15 22 29 5 12 19 26 2 9
16 23 2 9
16 23 30 6 1
10 l
Survoillances l
Not 8
l Ccmpleted l------------------------------------------------------7 MAL Within 6
l 24 Hours l------------------------------------------------------
5 of entering 4 l
Expected the Grace l
Period 2
l 2
(ND./ Week) 1j g -1 2g -1 1
1
\\
0 I
I I
l l
l 1
0 1
I I
I I
I I
I I
l l
December January l
February i March l
1 8
15 22 29 5 12 19 26 2 9
16 23 2 9
16 23 30 6 2-11
GOAL Et Minimize the nu=her of outstandine. time sensitive Lco's ob jec t ive: Number of dated
- 5 Management Attention Level LCO's outstanding
- 3 Expected i
10 l 1
9 I I
Number 8l l
of 7 l 1
Dated 6l 1
5 l------------------------------------------------------ 5 MAL Lco's 1
4 l l
Outstanding 3
l------------------------------------------------------
3 l
Expected 2l 2
1 11 1
7 -1 l-0 0-0 0-0 1
I I
I I
I I
I I
I I
I I
I I
I I
I I
l December l
January l
February l March l
1 8
15 22 29 5 12 19 26 2 9
16 23 2 9
16 23 30 6 l
2-12 i
l i
GOAL F:
Minimize the number of reportable overationni oc cu rrenc es Ob iec t ive : Number of Licensee
- 2/wcek Management Attention Level Event Reports (LER's) 1.5/ week Expected i
5 l l
l l
4 I I
I Numbar i
3 l l
l 2 - Mgmt.
of I
Attention
2--------------------------------------------
Level l
l
- ------------------------------------------- 1.5 LER'c/wk i
Expected 1 i 1
1 I
I oI o
0-0-0 I
I I
- 1. I I
I I
I I
I I
I I
I I
I I
I I
December l
January l
February l March l
1 8
15 22 29 5 12 19 26 2 9
16 23 2 9
16 23 30 6 3 l Four I
i Wack 2 I I
1. 5 - Mgmt.
(f l. q-------------------------------------------
Att e nt i on Le v e l 1.25 1.25-1.25 Rolling 1 l------------\\------------------------------------------------1.0-----Expected l
.75 75 Average l
N.5#.h5725 0 1 I
I I
I I
I I
I I
I I
i 1
I I
I I
l I
(LER'G/wk)
I December i
January l
February l March l
1 8
15 22 29 5 12 19 26 2 9
16 23 2 9
16 23 30 6 NOTE:
Reportable Operational Occurrences do not include Security-related events.
2-13
ATTACHMENT 3 System and Eauin=mnt Prob l em Romolution or Progresa The information herein identifies the status of system and equipment problems which were identified as restraints to restart or which were addressed to improve regulatory and operating performance:
1.
Equipment Environmental Qualification Modifications 2.
Installation of an Alternate Shutdown Panel 3.
Main Steam Bypass Line Replacement 4.
South Reactor Feed Pump Turbine 5.
High Pressure Coolant Injection (HPCI) Pump 6.
Emergency Diesel Generator Repairs 7.
Residual Heat Removal Pump "B" Motor Replacement 8.
Reactor Auxiliary Building Embedded Plates 9.
Traversing In-Core Probe (TIP) Nitrogen Purge Line Isolation 10.
Reactor Water Clean-Up System Modifications 3 -1
7 1.
Eauin-mnt Environmental Oumlification Modifications In order to comply with the requirements of 10CFR49 and Generic Letter 85-15, an evaluation was made of all safety-related equipment to determine its environmental qualification (EQ). The Fermi 2 EQ submittal to the NRC identified which safety-related equipment in a harsh environment would require relocation or replacement. During the Fall 85-01 Outage, all equipment delineated in the submittal was relocated or replaced.
2.
Installation of Alt ernate Shutdown Panel During the 85-01 outage an alternate shutdown panel was installed to provide additional shutdown capability to satisfy License Condition 2.c.9.d. in the event of a damaging fire in the Control Center. A final design and operating procedure review was conducted in parallel with construction. Three design deficiencies were identified and are being corrected.
3.
Main Steam Bvnans Line Renlme== ant On September 15, 1985. cracks in the pipe wall of the eact main steam bypass line were discovered. Similar
. cracks were found in the west bypass line upon further investigation. The cracks developed at attachment points as a result of high frequency, flow-induced vibration. New bypass lines have been installed which incorporate heavier wall pipe to reduce stress, reduce pipe attachment stress concentration and pressure breakdown orifices to stage the pressure and reduce velocity in the pipe. Vibration and strain instrumentation has been installed on the lines to provide empirical design verification after the lines are in operation. A safety evaluation has been completed to ensure the system capacity meets the values stated in the Fermi 2 FSAR.
4.
South Reactor Feed Pn=n Turb in e ( S RFPT)
The SRFPT failed in June, 1985. The vibration on the machine was not detected in the control Room due to inaccurate instrument ind ication. The extent of the damage required the complete disassembly and repair or replacement of the turbine rotor, bearing pedestal, and miscellaneous bearings, seals and trim piping.
Additional instrumentation has been added and the turbine is ready for operation when reactor steam is available. A piping modification was made on the l
gland seal system to reduce air in leakage to the condenser.
3-2
5.
High Pressure Coolant In iec t ion (HPCI) Pumn Initial operation of the High Pressure Coolant Injection (HPCI) Pump, under load, evidenced moderate vibra tion. During the Fall 85-01 Outage, cold alignment checks and realignment was made on the pump.
No defects were found upon inspection of the booster pump internals.
Modifications to the governor and overspeed trip device were made to ensure proper operation in the future. Installation of alignment devices for hot alignment of the unit were completed. The unit is ready for testing when steam is available upon restart.
6.
Emerganev Diesel Generator Renairs The diesels have undergone extensive analysis to determine the cause for the bearing problems experienced to date. Contributing causes include misalignment, long-term storage environment, misassembly, lack of pre-lube, and particulate in the oil. Several corrective actions have been taken to address the contributing causes. In addition, a slow-start feature has been added. A reliability demonstration is planned for two diesels. A presentation was made to the NRC staff on January 24, 1986, outlining this program. A formal submittal of the program will be made to the_NRC.
7.
Raniduni Hear Ramoval Pumn
'B' Motor Ren1meament On November 25, 1985, RHR pump motor "B" failed during operation in the shutdown cooling mode. Investigation shows the failure to be caused by lack of process control during manufacture followed by low-amplitude, cyclic stress during operation. A replacement motor has been obtained from the Browns Ferry plant and is now installed. Another motor is being investigated to assure that this was an isolated failure.
8.
Ram-ior Anvilimrv Buildino F=hedded Pinten Standard embedded plates were incorporated in the design of the Reactor Building as a means to anchor loads to the concrete structure. Generic load capacities were established for these embedments with the intention of performing specific load reconciliation af ter construction completion to ensure no overloading.
3 -3
T
~
A coacsrvativa caslycia h:d bzcn parformed to idsntify thssa embedments thich pstantially cculd ba overload ed.
However, subsequent detailed review of the potentially overloaded embedments.
9.
Traversing In-Core Pro'be (TIP) Nitrogen Purge Line Isolation Recent correspondence from the NRC reveals the TIP nitrogen purge line should conform to General Design criteria 56 (GDC56). An interim design to meet the intent of GDC56 is being implemented which incorporates two QAI seismically-mounted ball valves outside containment. This change will be installed prior to starting from the present outage.
10.
Reactor Water Cleanun System Modifications During initial operations, numerous unnecessary Reactor Water Cleanup System (RWCU) isolations oc curred. These isolations have been attributed primarily to the Steam Leak Detection System and to the differential flow (Leak Detection) isolation signals.
Instrument and control modifications were made on this system to prevent recurrence of the problem and to provide the operators Control Room information.
s i
3 -4
r e
ATTACHMENT 4 Ac tions to Insure Readinema for Rmactor Rantart Following are the items which were completed for the -
last reactor startup prior to the fall 85-01 Outage.
Because this startup was successful, these items will be repeated for the next startup.
1.
Lineups and independent verification of lineups will be completed on Engineered Safety Feature (ESF) Systems designated by -the Operations Engineer within 30 days of the planned reactor startup date.
2.
Existing lineups will be reviewed by Operations Supervision for all plane.ystems.
3.
The lineups of primary con.ainment manual isolation valves outside the drywell will be verified and independently reviewed.
4.
A random sample of fire barriers will be walked down and verified for compliance with Technical Spec ifications.
5.
Security barriers will be walked down and verified for compliance with the Physical Security Plan.
6.
The accuracy of the " Control Room Status File" will be verified by Operations Supervisor.
7.
All required Operational Condition 2 surveillances will be completed.
-8.
Temporary modifications will be verified for applicab ility.
Additional Itamn Added to Insure Read inem a for Restart The following additional items will also be completed to insure readiness for restart:
1.
The Reactor Operators responsible for reactor startup will have recently conducted reactor startup evolutiens on the simulator.
4-1
.Attcchmeat 4 2.
Outstanding Technical Specification change requests will be reviewed by Operations Supervision to ensure full compliance with Technical Specifications.
3.
The Technical Engineer will' review Deviation Event Reports identified by Nuclear Production management to ensure that they are closed or, if not closed, that they have been determined to not contribute to repetitive events.
4.
Nuclear Quality Assurance will ensure that actions assigned as a result of Licensee Event Reports (LER) are completed or adequately planned.
5.
The Reactor Operations Improvement Plan (ROIP) goals listed below are either being met or show a trend toward the established goal. These goals are:
- a. Minimize the number of Control Room nuisance alarms.
- b. Minimize the number of Engineering Design Packages (EDP) which are field complete for greater than 30 days but require paperwork closure.
- c. Minimize the number of time-sensitive Limiting Conditions for Operation (LCO).
- d. Minimize the number of " signed on" active work orders (PN-21's).
- e. Complete all surveillances within the grace period and minimize the use of the grace period.
- f. Minimize the number of Licensee Event Reports (LER).
6.
Operational Assurance will conduct an audit or surveillance of committed reactor startup readiness tasks within 30 days of the planned reactor startup date.
1 4-2
ATTACHMENT 5 Actions To Be Completed After Restart Prior to Test Condition I The following listing are the items which must be completed prior to exceeding 5% power. These items are either the completion of testing which requires the reactor be in operation at low power levels or actions taken to ensure readiness of the facility to support power ascension. Upon successful completion of these items the plant will have met all the technical requirements to exceed 5% power and will be ready to commence Test Condition 1.
1.
High pressure coolant injection will be retested and declared operable.
2.
Reactor Core Isolation Cooling system will be verified operable.
3.
The Main Steam Relief Valve and Automatic Depressurization System will be verified operable.
4.
Main Steam bypass line expansion will be monitored during testing.
5.
South Reactor Feed Pump performance will be verified by-test.
6.
Operation and performance of the Off Cas system will be verified by test.
7.
Reactor Operations Improvement Plan (ROIP) goals listed below are being met or show a trend toward the established goals:
- a. Minimize the number of Control Room nuisance y gg alarms.
- b. Minimize the number of Engineering Design Packages (EDP) which are field complete for greater than 30 days but require paperwork closure.
- c. Minimize the number of time-sensitive Limiting Conditions for Operation (LCO).
- d. Minimize the number of " signed on" active work orders (PN-21's).
- e. Complete all surveillances within the grace period and minimize the use of the grace period.
- f. Minimize the number of Licensee Event Reports
( LER).
5-1