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Forwards Emergency Operating Procedure (EOP) Insp Rept 50-341/88-20 on 880705-14.Draft EOPs Represent Improvement
	ML20154A987
Person / Time
Site:	Fermi
Issue date:	09/08/1988
From:	Holahan G; Office of Nuclear Reactor Regulation
To:	Sylvia B; DETROIT EDISON CO.
Shared Package
ML20154A993	List: IR 05000341/1988020; ML20154A987;
References
	NUDOCS 8809130165
	Download: ML20154A987 (6)
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NUCLEAR REGULATORY COMMISSION

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September 8, 1988

Docket No. 50-341

Mr. B. Ralph Sylvia, Group Vice President

Nuclear Operations

The Detroit Edison Company

6400 horth Dixie Highway

Newport, MI 48166

Dear Mr. Sylvia:

SUBJECT:

EMERGEhCY OPERATING PROCEDURES INSPECTION

(INSPECTION Rn0RT 50-341/88200)

This letter forwards the report for the emergency operating procedure (EOP)

inspection performed by an NRC inspection team at the Fermi 2 nuclear power

plant during the period of July 5 through July 14, 1968. Members of the NRC

Office of Nuclear Reactor Regulation, Region !!!, and contractors conducted

this inspection. At the coriclusion of the inspection, the team discussed the

findings with you and the members of your staff identified in Appendix A of the

enclosed inspection report.

The purpose of the inspection was to verify that your emergency operating

procecures were technically correct; that their specified actions could be

physically accomplished using existing equipment, controls, and instrumenta-

tion; and that the available procedures coulo be correctly carried out by the

plant staff.

The inspection effort involved a review of your program for E0P developeent, a

valtoation and verification of issued E0Ps and an evaluation of your training

activities for E0Ps.

The inspection team accomplished these tasks through use

of your site specific simulator, walk-throughs of E0Ps with operators,

interviews with key plant staff and review of E0Ps and supporting

documentation.

Two documents are enclosed with this letter: the Executive Sumary of this

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inspection provides an overview of the inspection team's findings in each area

reviewed; the enclosed inspection report provides a more detailed explanation

of the team's findings. Although no response is required to this letter, the

report includes findings that may result in enforcement action, which would be

the subject of separate corresponcence from the hRC Region !!! Office.

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Overall, the team concluded that the craft E0Ps which have been prepared for

Fermi 2 represent a significant improvement over the procedures that were in

use 41 the tine of the inspection. Numerous deficiencies and potential areas

for improvement were noted in the presently useo procedures.

The more

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Mr. 8. Ralph Sylvia

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September 8, 1988

significant items, such as diversity of methods for containment venting;

overpressure and overtemperature strategies for protection of the containment

and standby gas treatment system; the staging, inventory, and preventive

maintenance progran for E0P-related equipment; and enhancements to your formal

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procedure place keeping trethods, should be considered on an expedited basis,

It: accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure

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vill be placed in the hRC Public Document Room.

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Should you have any questions ccncerning this inspection, please contact me or

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Mr. Ralph Architzel (302-492-0991).

Sincerely,

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Gary M. Holaha"n, Acting Director

Division of Reactor Projects !!!,

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IV, V, and Special Frojects

Office of Nuclear Reactor Regulation

Enclosures:

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Executive Summary

2.

hRC Inspection Report 5C-333/88200

cc w/ enclosures: See next page

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Mr. B. Ralph Sylvia

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September 8. 1988

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cc w/ enclosure:

Mr. Ronald C. Callen

Ms. Lynn Goodman

Adv. Plannine Review Section

Supervisor - Licensing

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MichiganPublicServiceCommission

Detroit Edison Company

6545 Mercantile Way

Fermi Unit 2

P. O. Box 30221

6400 North Dixie Highway

Lansing, Michigan 48909

Newport, Michigan 48166

Joha Flynn Esq.

INPO

Senior Attorney

1100 Circle 75 Parkway

Detroit Edison Company

Atlanta, Georgia 30339

2000 Second Avenue

Detroit, Michigan 48226

,

Nuclear Facilities and Environmental

Monitoring Section Office

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Division of Radiological Health

P. O. Fox 30035

Lansing Michigan 48909

Mr. Thomas Randazzo

Director, Regulatory Affairs

Detroit Edison Company

Femi Unit 2

6400 North Dixie Highway

Newpert, Michigan 48166

Mr. Walt Rogers

U.S. Nuclear Regulatury Comission

Resident Inspector's Office

6450 W. Dixie Highway

hewport, Michigan 48166

Monroe County Office of Civil

Preparedness

963 South Raisinville

Monroe, Michigan 48161

Regional Administrator, Region !!!

,

U.S. Nuclear Regulatory Comissiori

799 Roosevelt Road

Glen Ellyn, Illinois 60137

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Mr. B0 Ralph Sylvia

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September 8, 1988

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EXECUTIVE SUMMARY

INSPECTION REPORT 50-341/88200

FERMI 2 NUCLEAR POWER PLANT

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A team of NRC inspectors and contractor personnel inspected the Femi 2

Nuclear Power Plant to evaluate the licensee's program for development and

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implementation of emergency operating procedures (EOPs) as required by Generic

Letter 82-33. The inspection team performed this evaluation by:

Reviewing the E0P development process as described in the procedure

generation package submitted to the NRC.

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Comparing the emergency procedure guidelines to the E0Ps and deviation

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documentation.

Validating the E0Ps using the site specific simulator and through plant

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walkdowns of E0P appendices.

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Independently verifying selected E0Ps and appendices for conformance with

the procedure generation package.

Reviewing operator requalification training on the E0Ps.

Fermi 2 was in the final stages of implementing symptomatic-based E0Ps based

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on Revision 4 of the BWR Owners' Group Emergency Procedure Guidelines.

The

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team thus inspected draft procedures that were nearly in final form and that

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had been mostly verified, validated and for which the operator training had

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been almost completed. A significant conclusion of the team was that the draft

procedures represented an enhanced method to control the plant under emergency

operations as compared with the approved E0Ps. Nonetheless, several problems

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were identified relative to the draft E0Ps and the implementation process.

Some of these problems are highlighted below; more details are provided in the

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inspection report. The team did conclude that the draft E0Ps could be bsed to

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adequately control emergency operating conditions and that early implementation

of the revised E0Ps would be a safety enhancement.

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The team noted that E0P provisions for containment venting were not

comprehensive.

For example, the licensee had not evaluated all possible paths

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to vent the contairment or assessed the integrity of the standby gas treatment

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. systert under the planned release paths.

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The simulator training that was conducted was not integrated and only mercised

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mild transients. The licensee stated the reason for the lack of chalienge

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during simulator sessions was simulator limitations in modelling complex

transients. The team did observe excellent control of the simulator during the

conduct of th ee scenarios developed for this inspection.

Several problems were noted with plant material conditions during plant

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walk-downs. These problems included emergency access paths that were blocked,

E0P equipment boxes that were poorly configured for equipment removal, and the

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need to dress-out for normal access to general areas of the reactor building

due to recent leaks in the reactor water cleanup system.

The team concluded

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that certain material conditions should be evaluated and addressed. These

included the use of tygon tubing to vent the potentially hot and high pressure

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fluid for the control rod drives, the use in the E0Ps of normal power supplies,

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and the lack of inventories, prestaging, and planned preventive maintenance of

E0P tools and equipment.

The team identified a significant deviation from the Owners' Group Guidelines

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in the draft E0Ps that had not been addressed by the licensee.

The E0P entry

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conditions used technical specification allowable values, versus the actual

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trip setpoints as specified by the Owner's Group. The licensee revised the

E0Ps during the inspection to use trip setpoints for entry conditions, where

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conservative.

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In the human-factors area, the team noted that some calculations required

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during performance of the E0Ps were difficult to perform. There was a marked

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need to define and enhance procedure place-keeping methods.

The lack of flow

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charts was considered detrimental.

Such charts would represent a significant

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place-keeping enhancement.

A general revision to the E0P Writer's Guide was

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considered necessary.

In addition;the procedures needed a general editing

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review to be sure the Writer's Guide editorial directions were followed and the

logic statements were properly formulated,

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The team noted several strengths during the inspection. Overall, the quality,

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legibility and readability of the draft E0Ps was very good. The licensee had

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developed an excellent system to control jumpers and safety system defeats.

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The shif t crew assigned to perform simulated E0P execises handled the emergency

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operations in an accomplished, professional canner.

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ML20154A987

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