ML20203N485
| ML20203N485 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/11/1986 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CAL-RIII-85-10, GP-86-0001, GP-86-1, NUDOCS 8610090141 | |
| Download: ML20203N485 (2) | |
Text
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B. R;lph Sylvb Dw~
- Group Vice President Detroit 6 Edison =400NorthDisieHighway c 2 ' e' - Segeember 11 1986 GP-86-0001 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Rd.
Glen Ellyn, IL 60137
Dear Mr. Keppler:
Reference:
- 1) Fermi 2 NRC Docket No. 50-34]
NRC License No. NPF-43
- 2) Confirmatory Action Letter, NRC Region III to Detroit Edison, dated July 16, 1985
- 3) Detroit Edison Letter, RC-LG-85-0017,
" Completion of Actions Described in Confirmatory Action Letter (Reference 2)", dated September 5, 1985.
I
- 4) Detroit Edison Letter, VP-86-0008, l
" Response to Request for Information Pursuant to 10CFR50.54(f)", dated January 19, 1986
Subject:
Approval to Exceed 5% Power I The purpose of this letter is to document Edison's compliance with its commitments and to request NRC concurrence to exceed 5% power. .
I Reference 2 listed six actions Detroit Edison would complete prior to exceeding 5% power. Reference 3 documented the actions taken to complete five of the six items. The only outstanding item is to obtain concurrence from NRC Region III Regional Administrator, or his designee, prior to exceeding l 5% power. 1 Reference 4 contains Detroit Edison's commitments prior to entering Test Condition 1 (exceeding 5% power). Attachment 5 of Reference 4 listed actions to be completed after restart, but prior to entering Test Condition 1. All but one of those actions have been completed. The status of these items was reviewed with your staff in a meeting on September 10, 1986.
The remaining item to be completed is to verify operation and performance of the Off-gas System. Successful completion of this activity is anticipated within the next few days.
8610090141 860911 i PDR ADOCK 05000341 SEP 16 SSE p PDR f
$ of
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, Mr. J. G. Kcppler September 11, 1986 GP-86-0001 Page 2 Reference 4 also listed the approvals required prior to proceeding to subsequent test conditions. Approvals to enter Test Condition 1 have been obtained from the On-site Review Organization, Plant Manager, and the Directors of Engineering, Quality Assurance and Regulatory Affairs. Also, the Independent ~ Overview Committee has concurred with the ,
recommendation to enter Test Condition 1 and has so advised me. I have informed the Chairman of the Board of these approvals and he has approved our plan to enter Test Condition 1. The Nuclear Review Committee, a committee of the Board of Directors is also aware of our plan to enter Test Condition 1.
Accordingly, to allow the logical progression of the Fermi 2 i Start-up Test Program, Detroit Edison seeks your concurrence to exceed 5% power, contingent on verbal notification from me that the operation and performance of the off-gas System has been verified by test.
Attachments Sincerely,
/ ." .
cc: Mr. M. D. Lynch Mr. W. G. Rogers Mr. G. C. Wright USNRC Document Control Desk Washington, D. C. 20555 M
. CONFIRMATORY ACTION LETTER
. UNITED STATES CAL-RIII-85-10
- j @ c82 gk, NUCLE AR REGULATORY COMMisslON
[ " r(, S* REGION lli Original: o. g, a g, !
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,3 . g g JUL 161985 W. H. JEAS Docket No. 50-341 The Detroit Edison Company ATTN: Wayne H. Jens Vice President Nuclear Operations 6400 North Dixie Highway Newport, MI 48166 Gentlemen:
This letter confirms the conversation on July 16, 1985, between Mr. E. Greenman of my staff and yourself related to the inadvertent criticality which occurred 4 and went unrecognized during the reactor startup on July 2,1985. With regard to the matters discussed, we understand you have taken or will complete the following actions:
- 1. Provide to NRC Region III the results of your evaluation of the inadvertent criticality event of July 2,1985, including corrective actions you have or will take. Include in your report the bases for not reporting this event to the NRC.
- 2. Assure that operations personnel are properly trained and understand the applicable procedure (s) for subsequent control rod manipulations.
- 3. Assure that all operations personnel are aware of the event and its poten-tial significance.
/ . 4. Verify the operability and/or validity of the program for the the Rod Worth Minimizer. ,
- 5. Verify that training programs at your simulator are consistent with the current procedures being implemented at the facility.
- 6. Af ter all actions required above are completed, obtain verbal concurrence from the NRC Region III Regional Administrator or his designee prict to exceeding Si reactor power.
~
h6-)710! !4 ~
CONFIRMATORY ACTION LETTER
CAL-RIII-85-10 The Detroit Edison Company 2 JUL 161985 l
Please let us know if ynur understanding differs from that set forth above.
h hY'h W
/'d James RegionalG. Keppler Administrator cc: L. P. Bregni, Licensing Engineer P. A. Marquardt, Corporate Legal Department DMS/ Document Control Desk (RIDS)
Resident Inspector, RIII Ronald Callen, Michigan Public Service Comission Harry H. Voigt Esq. .
Nuclear Facilities and '
Environmental Monitoring Section
)a e
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- a OAM vvi Usma8 I po.MTarn saptember 5, 1985 RC-LG-85-0017 Mr. James C. Keppler Regional Administrator Region III '
.U. 3. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois.60137 tear Mr. Keppler:
Reference:
(1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 (2) Letter, J. G. Keppler to W. H. Jens, '
dated July 16, 1985
Subject:
Completion of Actions Described in .
Confirmatorv Action Letter (Reference 21 '
Referenc'e 2 docMmented the actions to be taken by Detroit Edison prior to exceeding 52 power as a result of the control rod withdrawal event on July 1, 1985. This 1etter documents the actions taken to complete each item, J as follows:
Item 1 - Provide to NRC Region III the results of your i
evaluation of the inadvertent criticality event of July 2,1985, including corrective actions you have or will take. Include in your report the bases for not reporting this event to the NRC.
Action Taken - on July 23, 1985 Detroit Edison presented
- the results of its evaluation to members of your staff. This presentation included a discussion of root causes and
, contributing causes and identified the corrective actions prescribed to address these causes. In addition, this presentation provided the bases used to determine reporting requirements for the event. A copy of this presentation, annotated to reflect the status of
- l corrective actions, is enclosed.
Item 2 - Assure that operations personnel are properly !
trained and understand the applicable l procedure (s) for subsequent control rod I manipulations.
O e
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- RC-LG-85-0017 Page 2 Action Taken - Supplemental training on the current requirements for control rod manipulations, including the reduced #
notch worth pull concept, has been completed for all six shifts.
Item 3 - Assure that all operations personnel are aware of the event and its potential significance.
Action Taken - All licensed operators and numerous support personnel have attended a presentation conducted by Fermi 2.
management on the details and significance of this event, including the significance attached to it by the NRC and the subsequent actions taken.
Item 4 - Verify the operability and/or validity of the'
, program for the Rod Worth Minimizer.
Action Taken - Operability and validity of the Rod Worth Minimizer System (RWHS) has been verified. This system performed as designed during the subject event, and it meets its design basis for postulated control rod drop. Since the meeting of July 23, Detroit Edison has modified the RWHS program for control rod groups 3 and 4 to provide partial enforcement of the reduced notch worth concept.
Item 5 - Verify that training programs at your simulator are consistent with the current procedures being implemented at the facility.
Action Taken - Prior to this event, the sample rod pull
' sheets used at the simulator specified the withdrawal of group 3 rods to i position 48 in one step, which'was not consistent with the reduced notch worth concept in use at the plant.- This has been corrected. In addition, Detroit Edison's Nuclear Quality Assurance group has performed a surveillance on the procedures and attachments in use at the simulator. Based on this, Detroit Edison has concluded that the training at the simulator is consistent with the Fermi 2 operating procedures.
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Mr. Jones G. Kopplar
- ' September 5, 1985 RC-LG-85-0017
, Page 3 Item 6 - After all actions required above are completed, obtain verbal concurrence from the NRC Region III Regional Administrator or his designee prior to exceeding 55 reactor power.
Action Taken - All of the above actions have been completed and are available for NRC inspection. Based on the above, Detroit Edison requests concurrence to proceed with power ascension.
Sincerely, cc: P. M. Byron M. D. Lynch N h G. C. Wright USNRC,. Document Control Desk U
Washington, D.C. 20555 e
[.
I - - -
Mr. Janas G. Kapplcr S3ptonbar 5, 1985 RC-LG-85-0017 Pcgo 4 bec: F. E. Agosti L. P. Bregni W. F. Colbert -
R. R. Eberhardt -
P. Fessler J. H. Flynn F. N. Ghodsi E. P. Gritting
- 5. J. Latone J. D. Leman R. S. Lunart L. Lest.or S. H. Noetzel J. A. Nyquist G. R. Overbeck T. D. Phillips J. H. Plona J. L. Piana -
E. Preston -
T. Randazzo
. M. W. Shields G. He Trahey A. E. Wegele R. L. Woolley Region III Chron File NRC File Secretary's Office (2412 WCB) ,
Approval Control I 4
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FERMI 2 PRESENTATION T0 fRC REGION 3 ;
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PRS %TURE CRITICALITY I 0F l i
. l dlLY 2, 1985 l
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PRESENTATION OUTLINE I. INTRODUCTION ll. FERMI 2 OPERATIONS ,
Ill. DESCRIPTION OF EVENT IV. DEVIATIONS V. SAFETY SIGNIFICANCE OF THE EVENT ~
VI. 'REPORTABILITY CONSIDERAT10NS Vll. Root CAUSES AND CONTRIBUTING CAUSES Vill. CORRECTIVE ACTl0NS IX. Roo WDRTH MINIMl2ER DISCUSSION X. TRAINING XI. SumARY, CONCLUSIONS AND LESSONS LEARNED G
ee 1
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- 11. FERMI 2 OPERATIONS
' e DATE TIE 84-09-85 SHUTDOWN MARGIN TEST . )
86-21-85 FIRST STARTUP CRITICAL AT 9519 86-28-85 MANUAL SCRAM AFTER CRD PUMP TRIP 1418 POWER < 1% PRESSURE 145 PSIG D6-29-85 SECOND STARTUP CRITICAL AT 1189 l 97-01-85 SCRAM FROM FALSE REACTOR WATER LEVEL 3 1432 SENSING LINE VALVING ERROR POWER < 2% PRESSURE 140 PSIG ;
. \
l 07-91-85 THIRD STARTUP PREMATURE CRITICAL AT 2359 B7-02-85 CRITICAL AT 0050 07-05-85 SCRAM FROM REACTOR WATER LEVEL 3 1531 NAIN BYPASS VALVE PROBLEM POWER < 4% PRESSURE 630 PSls 07-06-85 FouitTH STARTUP CRITICAL AT 0107 97-09-85 SCRAM FROM REACTOR WATER LEVEL 3 2301 MAIN BYPASS VALVES IN MANUAL POWER < 5% PRESSURE 955 PSI 6 87-18-85 FIFTH STARTUP 9935
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Ill. DESIRIPTION or EVENT A. THE EVENT B. Roo Putt SHEETS AND CORE Pt.AN C. SRM CHARTS D. SHIFT COMPLEMENT e
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O 2320 STARTED SHIFT TURNOVER MEETING 2326 le RECEIVED A SPURIOUS Rkl4 BLOCK (0 2330 COMPLETED SHIFT TURNOVER MEETING -
2335 94 Rl44 BLOCK CLEARED BY REINITIALIZING '
2336 92 CONT.INUED PULLING ROD 22-31 AS PER STEP 44 2340 50 ROD 02-35 WA'S PULLED BEYOND 94 TO 48 WHICH WAS START OF ROD PULL ERROR 2359 98 COMPLETED COUPLING CHECK OF 18-51 (llTH ROD WITHDRAWN IN ERROR). R0 AND STAIT NOTICED l CONTINUED ' INCREASE IN sri 4 COUNT AND RO NOTICED THE NOD PULL ERROP.
2359 33 R0 STARTED INSERTING ROD 18-51 AND ASKED STAIT To l Go GET THE NSS 9014 14 ALL ELEVEN RODS PREVIOUSLY PULLED INCORRECTLY WERE
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. -D. SHIFT COMPLEMENT NisHT or EVENT 1+ NSS NUCLEAR SHIFT SUPERVISOR SRO 2+ NASS NUCLEAR ASSISTANT SHIFT SUPERVISOR SRO NSO(5) NUCLEAR SUPERVISING OPERATOR .
3+# IN CHARGE OF CONTROL ROOM SRO !
kW AT MAIN CONTROL (633) PANEL RD l 5+ PATROL R0 !
6 RADWASTE RO 7 TAGGING CENTER (fDN-LICENSED) 8 WPO NUCLEAR POWEn PLANT OPERATOR (NON-LICENSED) )
l 9 WPO NUCLEAR POWER PLANT OPERATOR (NON-LICENSED) 18+# SOA SHIFT OPERATIONS ADVISOR SRO 11+# STA SHIFT TECHNICAL ADVISOR (NON-LICENSED) 12 4 STAIT SHIFT TECH. ADVISOR IN TRAINING (NON-LICENSED) f' 13[STE SHIFT NUC. ENGR. (RX ENGINEER) (NON-LICENSED) 14+ LSTPE LEAD STARTUP TEST PHASE ENGINEER (NON-LICENSED) 15+ CESTO cf STARTUP SHIFT ENGINEER 16 CHEH. TECHNICIAN 17 HEALTH PHYSICS TECHNICIAN OTHERS SUCH AS isc TECHNICIANS AND MAINTENANCE CRAFT
+ DENOTES IN CONTROL ROOM AT TlHE OF EVENT
- DENOTES IN "AT CONTROLS AREA
- AT TIME OF EVENT (O Clen'tsi error. Tbe SNE was nd ,i "Af Cahls fras' ~
. 4 tiine of event l
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. IV. DEVIATIONS f
A. IMPROPER Roo Putts - OPERATon ERROR B. FAILURE To: RECOGNIZE EVENT To SToP .
To EVALUATE To DOCUMENT BEFORE ""0000;iG-Proces.On'a3 C. FAILui:E OF STAFF To RESPOND i
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lVo DEVIATioNC A. IMPROPER ROD PULL 0 lNATTENTION TO DETAIL 0 FAltuffE 70 FOLLOW ROD PULL PROCEDURE
.- NOTE: THE OPERATOR AND STA IN TRAINING DID DO A 6000 JOB .
IN RECOGNIZING AN INCREASING SR4 COUNT NATE AND THE OPERATOR EXPEDITIOUSLY INSERTED ROO TO TERMINATE THE EVENT
TO STOP, EVALUATE AND DOCUMENT BEFORE PROCEEDING 0 PERSONNEL IN 'AT CONTROLS AREA" FAILED TO RECOGNIZE OR PURSUE THE EVENT ,
O CERTAIN PEl!SONNEL AWAF.E OF A SUSPECTED CRITICAL DID NOT PURSUE O M4EN DISCOVERY OF ROD PULL ERROR WAS RECOGNIZED, l
, APPROPRIATE PERSONNEL DID NOT GET INVOLVED IN THE C'.*AL"ATION TO DETERMINE THE DETAILS OF THE EVENT !
O BECAUSE OF ABOVE, DER HAD INCORRECT AND MISLEADING INFORMATION ON IT l
. O E"E!!T tia.S NOT LOGGED IN NSS LOG OR NSO LOG C. FAILURE OF STAFF TO RESPOND 0 STAFF DID NOT EXPEDITIOUSLY EVALUATE THE EVENT TO DETERMINE THAT PREMATURE CRITICAL HAD BEEN REACHED 0 THE EXACT STATUS OF THE EVENT EVALUATION SHOULD HAVE BEEN SETTER C0t44UNICATED TO lRC , ,
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. V. SAFETY SIGNIFICANCE OF THE EVENT
! THE EVENT:
' . ELEVEN GROUP 3 CONTROL RODS WERE PULLED To POSITION 48 INSTEAD OF POSITION 84 AS PER Putt SHEETS AND A PREMATURE CRITICAL WAS ACHIEVED.
A. SIGNIFICANT PROCEDURE VIOLATION. ,
B. NOT A SAFETY CONCERN. PLANT WAS IN PROCESS OF STARTUP '
AND APPROPRIATE NEUTRON MONITORING INSTRUMENTATION l OPERABLE AND BEING OBSERVED.
C. NO Strou4 114 SECOND PERIOD. MAXIMUM COUNT ON SR45 WAS 6 X 193 . NO INDICATION ON IRl45.
i D. NOT DUTSIDE DESIGN BASIS OR IN AN UNANALYZED CONDITION AT ANY TIME.
E. NO TECHNICAL SPECIFICATION VIOLATIONS.
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. VI. REPORTAB iL ITY CONS IDERAT q(Hg .
A. DEVIATION EVENT REPORT (DER) EVALUATION B. 53.72 AND 50.73 REVIEW O
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, ." A. DEVIATION EVENT REPORT EVALUATION SEQUENEF 97-01-85 2359 REACTOR OPERATOR (RO) AND STA-IN-TRAINING (STAIT) RECOGNIZED PROBLEH. R0 STARTED j
INSERTING R005 TO PROPER POSITION. M i '
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' REQUESTED STAIT TO CONTACT NUCLEAR SHIFT SUPERVISOR (NSS). STAIT ALSO INFORMED STATION 4
IAJCLEAR ENGINEER (SIE) 0F EVENT.
97-92-85 935 NSS WENT TO R0 AT CONSOLE, NOTICED THAT RODS I
WERE BEING INSERTED,.AND THAT SRMS WERE DRAWING VERTICAL LINES (CONSTANT COUNT RATE).
B7-02-85 0335 NSS TALKED TO SIE AND STAIT. NSS DECIDED 70 REACTOR HAD NOT GONE CRITICAL. BY THIS TIME .
9315 RODS WERE BACK TO CORRECT POSITION AND HAD t
BEEN VERIFIED BY STA, SfE AND RO.
87-02-85 NSS CALLED OPS ENGR AND INFORMED OPS ENGR GROUP 3 RODS HAD BEEN PULLED TO 48 OUT OF SEQUENCE, THAT THE NEACTOR DID NOI 60 CRITICAL AND THAT THEY HAD BEEN RETURNED TO THEIR r..wrc.. ruS IT ION. OPS ENGR STATED THAT A DER SHOULD BE PREPARED AND IT CAN BE DISCUSSED IN THE MORNING.
07-02-00 *23' CJ~ ..A3 DISCUSSED AT CARB NEETING AND
[.
L. EVALUATION WAS AS$1GNED TO REACTOR ENGINEERING 1
B7-93-85 1003 MEETING HELD 70 DISCUSS PRELIMINARY EVALUATION RESULTS. SRl1 CH RTS REVIEWED AND DISCUSSp.
DETERMINATION OF CRITICAL WAS NOT AGREED UPON AND FURTHER EVALUATIDN WAS REQUESTED.
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ASSISTANT SUPERINTENDENT AND OPS ENGINEER NOTIFIED RESIDENT INSPECTOR OF THE EVENT AND STATUS OF EVALUATION. ,
9 .84-85 SIE cau.ED ASST. SUPT. AT HOME AND STATED
- HESULTS OF HIS FURTHER EVALUATION INDICATED REACTOR HAD REACHED CRITICAL. IT WAS STATED THAT A MEETING WOULD BE HELD THE NEXT DAY.
97-95-85 1600 NEETING WAS HELD TO REVIEW LATEST EVALUATION DATA. AGr!EEMENT WAS REACHED THAT REACTOR HAD BEEN CRITICAL AT A PERIOD OF 114 SECONDS.
97-96-85 EVALUATION DATA WAS TURNED OVER TO ADVISOR TO SUPERINTENDENT FOR INVERVIEWING OF PERSONNEL, DETEPp.INE ROOT CAUSES AND RECOMMEND NECESSARY CORRECTIVE ACTIONS.
87-15-85 ASSISTANT SUPERINTENDENT DISCUSSED THE EVENT WITH SENIOR RESIDENT INSPECTOR.
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B. REPORTABILITY O CONSIDERED 50.72 (B)(1)(II) a 50.73 (A)(2)(li)
ANY EVENT OR CONDITION DURING OPERATION THAT RESULTS IN 2
. THE CONDITION OF THE NUCLEAR POWER PLANT, INCLUDING-ITS '
i PRINCIPAL SAFETY BARRIERS BEING SERIOUSLY DEGRADED: OR RESULTS IN THE PAJCLEAR POWER PLANT BEING: i (A) IN AN UNANALYZED CONDITION THAT SIGNIFICANTLY COMPRDHISES PLANT SAFETYJ 4
(B) IN A CONDITION THAT IS OUTSIDE THE DESIGN BASIS OF THE PLANT OR .' , , _
q (C) IN A CONDITION NOT COVERED BY THE PLANT'S OPERATING l AND EMERGENCY PROCEDURES.
1 0 THE NUCLEAR SHIFT SUPERVISOR DECIDED THAT THE EVENT WAS E A 53.72 ONE (1) HOUR OR FOUR (4) HOUR REP 0rti 0 THE CORRECTIVE ACTION REVIEW BOARD (CARB) CONCURRED WITH THE lAICLEAR SHIFT SUPERVISOR'S DETERMINATION AND ALSO DECIDED THAT THE EVENT WAS m 50.73 REPORTABLE.
1 1 0 lT WAS DECIDED THAT THE RESIDENT INSPECTOR SHOULD BE INFORMED OF THE EVENT.
O M NOW RECOGNI2E FURTHER CONVERSATION WITH REGION lll WOULD HAVE BEEN APPkOPRIATE. _
1
y Vll. Roor CAUSES AND CONTRIBUTORY CAUSEE o ,
DEVIATIONS A. FoR Roo PULL ERROR B. Fon FAILURE To o RECOGNIZE SIGNIFICANCE o To STor 9 To EVALUATE o To DoCUtENT
- c. Fon FAILURE OF STAFF To EXPEDITE REVIEW O
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Vll. Root CAUSES OF THE DEVIATIONS A. FOR IHPROPER ROD PULL OPERATOR ERROR 0 FAILURE TO ADEQUATELY MANAGE CONTROL ROOM ACTIVITIES DURING l>PORTANT PLANT ACTIVITIES O THE ROOS WERE BEING PULLED AT TOO RAPID A RATE FOR AN OPERATORS' FIRST REAL REACTOR STANTUP.
THE SHIFT TECHNICAL ADVISOR IN TRAINING
~
(STAIT) HELPING BY WATCHING THE SRM CHARTS , .
ALSO CONTRIBUTES TO FAST PULLS.
O THE OPERATOR DID NOT REVIEW AND UNDERSTAND THE PULL SHEETS Pkl0R TO SITTING DOWN AT THE CONSOLE TO PULL RODS.
1 0 FAILURE TO PROPERLY TURNOVER FUNCTION AT SHIFT
- TURNOVER.
NOTE ALTHOUGH NOT A ROOT CAUSE FOR THE OPERATOR ERROR EVENT, THE R41 BEING PROGRA>NED TO
~
PROVIDE SOME RESTRAINTS OR ENFORCEMEtiT OF REDUCED NOTCH WORTH WOULD HAVE PREVENTED THIS EVENT.
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l O FAILURE TO OPERATE AS TRAINED / FAILURE TO TRAIN AS OPERATING ,
- 0 THE RODS WEi!E BEING PULLED AT TOO RAPID A RATE..
0 OPERATOR HAD BEEN TRAINED AT SIMULATOR USING PULL SHEETS THAT WITHDRAW GROUP 3 RODS TO 48 IN ONE STEP INSTEAD OF THE REDUCED NOTCH WORTH SEQUENCE TO BE USED AT. FERMI 2 0 POOn HUMAN FACTORED PULL SHEETS O THE ROD PULL SHEET DESIGN AND APPEARANCE FOR GROUP 3 RODS ARE THE SAME AS GROUPS 1 Ale 2 RcDS. THE WORDS " RODS FULLY WITHDRAWN" IN THE UPPER RIGHT HAND CORNER AND THE BLAfES FOR VERIFYl'4G RODS FULLY WITHDRAWN INDICATIONS MAY LEAD ONE To BELIEVE THE RODS ARE To BE FULLY
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- 8. ROOT CAUSES FOR FAILURE TO O RECOGNIZE THE EVENT AND ITS SIGNIF!CANCE O TO STOP 1
0 TO EVALUATE ,
0- TO DOCUMENT 1
o FAILURE TO ADEQUATELY MANAGE CONTROL ROOM ACTIVITIES DURING CRITICAL PLANT ACTIVITIES 0 NEITHER THE NUCLEAR SHIFT SUPERVISOR OR THE NUCLEAR ASSISTANT SHIFT SUPERVISOR WERE IN THE 'AT CONTROL 5 AREA
- DURING THE ROD PULLS.
O VARI,0US OTHER ON-SHIFT,J4R$0NNEL IN THE CONTROL ROOH DID NOT DEVOTE NECESSARY ATTENTION TO THIS
'FIRST* STARTUP Fort SOME OF THE PERSONNEL. (ONLY 3P.D PLANT STARTUP) 0 THE SOA, THE STA, AND THE N50 IN CHARGE OF THE P^""' D"' 8 SHOULD HAVE BEEN MORE VIGILANT IN RECOGNIZING THE EVENT AND AIDING IN PROPER EVALUATION OF THE EVENT.
n Tur E wtwjl D HAVE REQUESTED ASSISTANCE FROM
, AVAILABLE RESOURCES.
O ROD PULLS SHOULD HAVE BEEN TERMINATED SO THAT .
CHARTS COULD BE ROLLED BACK AND PERSONNEL RESOURCES ;
USED FOR EVALUATl0N.
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0, C. FOR FAILURE OF STAFF TO EXPEDITIOUSLY EVALUATE THE EVENT AllD INFORM APPROPRIATE PERSONtJEL O MUCH TIME AND EFFORT WAS BEING DEVOTED TO MEETINGS AND COMPLETING COMMITMENTS FOR PLANT FULL POWER LICENSE.
O STAFF DID NOT RECOGN.t2E THE IMPORTA!JCE 5F PR0f4PTLY ADDRESSING AND EVALUATING ROD PULL ERRORS.
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- ", Vill. CokhEcTivE AcTeorn A. REMEDIAL' O A SECOND QUALIFIED PERSON 15 VERIFYING GROUP 3 AND 4 ROD PULLS
'. SCHEDULE: DONE (lllGHT OnDEl:: 7-3-05, 133eB HOURS) 0 N/A IS BEING ENTERED IN " RODS FULLY WITHDRAWN" COLUMN BY REACTOR ENGINEER IF RODS ARE NOT TO BE FULLY WITtiDRAWN.
SCHEDULE: DONE O CURRENT
- FERMI 2" PULL SHEETS ARE NOW BEING USED AT 1 SIMULATOR FOR TRAINING.
SCHEDULE: DONE i
B. PLANNED ACT10NS TO PREVENT RECURRENCE OF THE R0D PULL i
ERROR 0 REVIEW THE FORMAT AND LAYOUT OF THE R0D PULL SHEETS r0k HUiWJ FACTORS CONSIDERATION. MODIFY AS APPROPRIATE.
SCHEDULE: 8-15-85 (C.mpkh) 13-IS)
O ASSUi!E THAT THE ROD PULL SHEETS ARE UNDERSTOOD BY THOSE USING THEM. PROVIDE A COVER SHEET OR INSTRUCTION WITH PULL SHEETS INCLUDING INITIALS OR
~
SIGNATURE TO DOCUMENT THIS UNDERSTANDING OR PROVIDE ,
ANOTHER SUITABLE MEANS TO ACCoteLISH THE SAME ;
OBJECTIVE. !
SCHEDULE: 8-15-85 (Cemyl.hJ i-3-9M
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SCHEDULE: DONE (REF. 7-23-85 MEMO OP-85-210)
O DO NOT PULL R005 DURING SHIFT CHANGE OR UNTIL
~
. APPROPRIATE PERSONNEL ARE READY. (REF. 7 85 MEMO IP-85-B N ITEM 2).
O ASSURE LICENSED OPERATORS ARE TRAINED AND UNDERSTAND THE INTENT AND PURPOSE OF REDUCED NOTCH NORTH PULL CONCEPT AND THE IW LEHENTING' PULL SHEETS.
SCHEDULE: DONE AND IN PROGRESS (cg4<J F-30-S5) 0 ASSUI:E LICENSED OPERATORS UNDERSTAND THE Rf1 AND PROTECTION AND RESTRAINTS THAT IT PROVIDES AND DOES NOT PROVIDE.
SCHEDULE: WITH REQUAL (, Comp lcle/ I*IO*IS.)
0 ASSURE THAT ALL LICENSED OPERATORS AND APPROPRIATE SUPPORT PERSONNEL ARE AWARE OF THis EVENT AND ITS SiGiiiF iCANCE. VIDED TAPE OF THE EVENT SCHEDULE: DONE
"" 8 "' " " b*# '"P rces n M into M.38***
- e. Intm<J ogsra l er anl numerns 0 A MDRE EXTENSIVE VIDEO TAPING OF THE REENACTMENT OF ,,
- T::C tv NT AT THE SIMULATOR 15 PLANNED. f***anef.)
SCHEDULE: 8-8-85 (CompleleJ by f-l(-#5)
- O CONSIDER MODIFYING Ril PROGRAM TO-INCLUDE SOME REDUCED NOTCH NORTH CONTROL RESTRAINTS.
SCHEDULE: 8-15-85 (fH.Jgipt;*h Qdd f-f.6-ff.)
30- ,,
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. C. PLANNED ACTIONS To PREVENT RECURRENCE IN REGARDS 70 FAILURE TO RECOGNIZE THE SIGNIFICANCE OF THE EVENT SO AS TO STOP, EVALUATE AND DOCUMENT BEFORE PROCEEDING.
-(1)0' REVIEW SHIFT PERS~ PINEL RESPONSIBILITIES AND MAKE i
~
. CHANGES AS REQUIRED TO ASSURE PROPER MANAGEMENT OF CRITICAL CONTROL ROOM ACTIVITIES.
SCHEDULE: DONE (REF. 7-19-85 MEMO fP-85-804 ITEM 1) b0 ASSURE THAT THE ROLE OF THE SOA AND STA IS UNDERSTOOD AND BEING PROPERLY FOLLOWED. ENCOURAGE NSS AND NASS TO USE THESE PERSONNEL AS WELL AS -
OTHER QUALIFIED PERSONNEL ON SHIFT.
SCHEDULE: DONE (REF. 7 -8 NEMO W-85-804 ITEM 3) 0}0 ASSURE THAT THE STE TME5 An active ROLE IN R00 PULLS / INSERTIONS AND THE EVALUATIONS OF UNPLANNED-REACTIVITY CHANGES SCHEDULE: DONE (REF. 7-20-85 MEMO (P-85-209) 0 IW ROVE LOG BOOK ENTRIES AND ASSURE EVENTS SUCH AS THIS EVENT ARE LOGGED.
SCHEDULE: DONE (REF. 7-19-85 MEMO W 803) !
J,. O Review SHIFT TURNOVER PROCEDURES TO ASSURE THEY A!E ACCEPTABLE FOR THE CURRENT MODE OF OPERATION.
SCHEDULE: 6.-13-85(fecec,9q,n,,,)
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IX. Roo lertTH Minguirra S
. Discus'stoN -
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X. TRAINING A. SPECIFIC EVENT B, Roo FDRTH MINIM 12ER C. SIMULATon TnAINING VS. PLANT k
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X. TRAINING A. SPECIFIC EVENT -
O SHORT VIDEO OF EVENT (ALL SHIFTS)
O LONG VIDEO, AS DONE Vs. AS SHOULD BE' O GIVE THis PitESENTATION TO OTHERS IN NUCLEAR l OPERATIONS B. RQD lbMTH MINIMI7ER 0 IM4EDIATE INFORMATION- '
0 - SHIFT SRIEFING 0 VIDED TAPE i
0 CURRENT ACTION l 0 NEW LESSON PLAN u slHULATOR DEMONSTRATION C. SisutATon TRAINING VS. PLANT _
- c. O SIMULATOR AUDIT - NO FINDINGS DONE JULY 18-20, 1985 0 CONTINUE TO AUDIT 10% PER MONTH OF ALL OPERATION PROCEDURES AT SIMULATOR O REVIEW LESSON PLANS DONE JULY 18-20, 1985 -
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WattIr J. McCcrthy. Jr.
Chairman of the Bwd 1
Detroit 2 Ecison =000Se:ond Avenue =-
January 29, 1986 YP-86-0008 I
Mr. James C. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Rilyn. Illinois 60137
Dear Mr. Keppler:
Reference:
~ 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPP-43
- 2) NRC to Detroit Rdison Letter.
" Requesting Information Pursuant to 10CFR50.54(f).". December 24, 1985
- 9) Detroit Rdison to NRC Letter.
" Reactor Operations Improvement Plan". VP-85-0198, October 10 1985
Subject:
Response to Request for Information Pursuant .,
This letter is submitted in response to the Nuclear ,
Regulatory Commission's request fo. irformation pursuant to 10CFR50.54(f) which is' cited as settrence 2 above.
Detroit Rdison is committed to the highest standards for both managing and operating the Fermi 2 facility.
Inhancement of management and management practicos is essential to attain the operati,ng 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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- 0 LESSONS LEARNED
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. Mr. James C. Keppler
., January 29, 1986 VP-86-0008 Fage 2
- 1. , ADEQUACY OF MANAGEMENT. MANAGEMENT STRUCTURES AND SYSTEMS Detroit Edison management needs to strengthen the sensitivity, discipline and responsiveness of the Nuclear Operations organisation. 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 eliminsting deficiencies in these areas, improvements can be expected in overall management. in the ability to recognise 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.
Manatement 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. Vice-President. Nuclear Operations. Frank Agosti.
Manager-Nuclear Operations will succeed Wayne Jens as Vice-President beginning on that date. Further. I recognise that additional strengthening of the Fermi 2 management is appropriate. Consequently. I am 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. Neidel, to assist
! me-in monitoring the performance of the Nuclear Operations organisation. The Nuclear Quality Assurance organisation will report to Mr. Neidel. The President will also assure that any other corporate resources are
"~'~'**'"T __ .- . ., , . . . _ - . - _ _ -. - _- . _ . .-
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),*
r Mr. James C. Keppler January 29, 1986 VP-86-0008 Fage 3 provided which are necessary to support or audit the Nuclear Operations organisation. This 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 organisations. 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 Cverview Committee has already conducted interviews with management personnel from both the site and corporate organisations. A preliminary report has been presented by the Overview Committee to a committee of the Board of Directors, the Board Nuclear Review Committee.
Attachment 1 explains the role and schedule of the Overview Committee. Detroit Edison will strongly consider the Committee's recommendations for management improvement.
Manne ment structure The concept, structure and functions of the Nuclear Operations organisation 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 orgenisation and management consultant from the D,etroit 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 reorganised to consolidate engineering responsibilities in the Nuclear Operations organisation under the leadership of an Assistant Manager. The present engineering organisation bas. assumed full control of engineering and is augmented by a single '
architect / engineer with a dedicated staff on site.
Since engineering problems have occurred during this
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Mr. James C. Keppler January 29, 1986 VF-86-0008 Fage 4 l
tran,sition period, the effectiveness of the present engineering organisation 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 Flant Manager. The purpose of this move was to permit the Manager to monitor day-to-day work to insure'that the Engineering organisation, the Regulation and Compliance organization and Nuclear Operatsons Service organizations are being responsive to the needs of the plant. Th i,s effort has reinforced the operating authority of the Flant 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 will continue to examine the management structura and personnel to I
identify further improvements which would enhance j regulatory and operating performance. Each recommendation will be considered by management for implementation.
I j EAnteement Evatens and Practices a After the success of the Fall 85-01 Outage, it became evident that a similar planning and controls effort to plan, coordinate and follow-up is necessary not only for outage work but also for day-to-day work activities. -
Each organisation 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 Flan.
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 Flan 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 1- .m --
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'. ',* Mr. Jameo C. Koppler January 29, 1986
. VF-86-0008 Fage 5 actions, time frames for accomplishment and performance indicators. That Plan will be discussed with the NRC in a separate meeting. The Security Improvement Flan will incorporate recommendations from the Independent Overview Committee where appropriate.
An evaluation of plant maintenance activities showed two arese 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 operating authority can accept a component or system for service. These improved management controls,have resulted in better control over l 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 maintenance activities might have on plant operations.
The need for continuous attention to management practices for improved regulatory performance is recognized. The Detroit Edison corporate organisation and management-development consultant has been directed to work with Fermi 2 management to focus attention on their management practices within Nuclear Operations.
s_- As part of this efforts a survey on organisational 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 recognises the need to communicate certain events regardless of the reportability requirements.
Recognising that communication and response improvements between Detroit Edison and the NRC are as important as recognising significant conditions, a Nuclear Operations Directive has been prepared which ptancribes policy
?. r
- Mr. James C. Keppler
. January 29 1986 VF-86-0008 l
Page 6 supporting a more effective dialogue between the two organisations. In addition. Detroit Edison has .
I 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 RRC. The consultants have stready 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 organisation, 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 organisations. These publications include the monthly Moderator, the Week 1v Moderator and daily
" Management Update" messages distributed using the site-computer communica.tions 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.
I
- 2. READINESS FOR RE-START AMD F0WER ESCALAT10B Detroit Edison has concentrated on correcting errors that have been made in its operations and is committed
.. to continue the Reactor Operations Improvement Plan.
i 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 acd technical specification violations. The positive trends which l have been achieved since this program was implemented are expected to continue. The performance to date and ,
indicators for the Resecc - Operations Improvement Flan !
are shown in Attachment 2. Any startup decision will l require verification that satisfactory trends are l continuing. j 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 l
i
.* Mr. James C. Koppiar
. January 29, 1986 VF-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 intended that similar steps and procedures be followed in preparation for the next startup. The operators who will be responsible for 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 perf ormanc e bef ore.. 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 utilising the following:
A. Reactor Operations Improvement Plan. .to assess
- plant operations;
- 3. Startur Test Phase results. to assess plant equipment performance; C. Independent Overview Committee, to assess overall performance.
, fTheOverviewCommitteewillmakearecommendation to me j and the Board Nuclear Review Committee regarding
- movement to the next Test Condition. My approval and review by the Board Nuclear Review Committee are j required before the plent can proceed.
- 3. IMPROVED REGULATORY AND OPERATIOEAL PERPORMARCE The plans identified in this response' represent Detroit Edison's commitment to improving the regulatory performance, operating performance and management l
m__. _ __
. . . . 'r Mr. James G. Reppler
. January 29 1986 VP-86-0008 Fage 8 l
! perf'ormance 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 vill 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. Bowever, 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 recutting 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 (INFO) Forformance 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 jeopardised the health and safety of the public, we nevertheless are committed
I, Mr. Jcseo C. Keppler
, January 29, 1986 VP-86-0008 )
Page 9 i correct the trends which could lead to safety concerne if left uncorrected. Detroit Edison believes that with the continued success of the Reactor Operations Improvement Flan, the implementation of the Security Improvement Plan. and the actions taken as specified in Attachment 3 and Attachment 4. the plant will be ready l to resume operation up to 5I 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 usintain oversight and review by the l Independent Overview Committee, the Detroit Edison Board Nuclear Review Committee, and myself until we are satisfied that this plant with its new management, its l P l ant operators, and its support staffe have ;
demonstrated-satisfactory performance as measured against other plants'and INFO performance criteria.
Fermi 2 will only be operated in a manner which ensures l the public health and safety. For this reason, Detroit !
Edison believes that the Fermi 2 license does not need to be suspended, revoked or otherwise modified. ;
Tory truly yours.
1 ?
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Attachments -
cc: Mr. F. M. Byron
, Mr. M. David Lynch Mr. G. C. Wright .
USNRC Document Control Desk Washington. D. C. 20555
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Nr. James G. Keppler I ' January 29 1986
+ VP-86-0008 Page 10 I
DATH AND AFFIRMATION To th's best of my knowledge and belief the statements contained herein are true and correct. In some respects these statiments are not based on my personal knowledge but upon infornstion furnished by other Detroit Edison employes. Such information has been reviewed in accordence with Company practice and I believe it to be reliable.
o , I ,
Walter J. hc Cart'hy. Jr.
~
Chairman of the Board d
Detroit Edison SUBSCRIBED and SWOR to be is ay of e ,
/ELcAEu &
Notary Public MARCIA BUCK platary Public, Washtenaw County. M1 My Commission Empires Dec.EISE Mcb b
. A
!.. .- na a .. . . . . . - , . . . . . . . . .-. . . . . . .
Mr. James C..Keppler January 29, 1986 VP-86-0008 Page 11 bec: F. E. Agosti L. F. Bregni L. S. Cohan W. F. Colbert J. E. Conen J. H. Flynn E. F. Griffing C. M. Beidel W. B. Jens J. D. Leman R. 8. Lenart W. J. McCarthy, Jr.
F. A. Marquardt L. Martin S. B. Noetzel C. R. Overbeck A. Papadopoulos J. L. Piana T. Randazzo L. J. Simpkin C. M. Trahey M. L. Vermeulen A. E. Wegele R. L. Woolley Approval Control NRC Follow-up Book /NRC File
, Region III Chron File Secretary's Office 2412 WCB Licensing File l
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TABLR OF ATTACEMENTS g .
Attachment 1 1-1 Fermi 2 Independent Overview Committee Attachment 2 2-1 Reactor Operations Improvement Program Indicators Attachment 3 3-1 System & Equipment Froblem Resolution or Progress Attachment 4 4-1 Actions to Insure Readiness for Reactor Restart Attachment 5 5-1 Actions to be Completed Af ter Restart Frior to Test Condition 1 e
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.. e ATTACBMENT 1 Fermi 2 Indenendent Overview Committee Recognising that an introspective self-examination is by its very nature a limited undertaking. Detroit Edison has sought an independent, unbiased review of its management, organisation and improvement-programs.
A group of recognised 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 reconnendations j regarding the management of Fermi 2. l i
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l CHARTER FERMI 2 INDEPENDENT OVERVIEW CG041TTEE 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 Nucles'r Operations management. The Consnittee 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. Gener.el Phycles Corporation. Chairman Earry J. Creen. Consultant Leo C. Lessor. Management Analysis Company Salonon Levy. S. Levy. Inc.
Murray E. Miles. Basic Energy Technology Associates. Inc.
James Y. Neely. Nuclear Power Consultants. Inc.
REPORTING The Comunittee 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 comunittee and will ree ain cognisant of its findings and recommendations.
COORDINATION OF THE COMMITTEE'S ACTIVIZZZ1 The Assistant Manager. Regulation & Compliance. Nuclear Operations.
Detroit Edison, or his designee, will coordinate and assist where necessary in the activities of the Coussittee. He wi13 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. Be will act as contract administrator for all contracts required to carry out the Committee's activities.
ANTICIPATED NEITING SCHEDULE Week of January 6 - 11 Week of January 27 - 31
- Week of February 24 - 28 One day per month for the remainder of 1986 1-2 i
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CRARTER
. Fermi 2 Independent Overview Committee Page 2 SCOPE Nanneerent Evaluation Task Frepare a report which identifies, evaluates, and analyses 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 C. Keppler to Wayne E. Jens.
Present the Overview Committee report to Detroit Edison aenior management, and representatives of the Detroit Edison Board of Directors in a meeting to be held on February 7.1986, or soon thereafter.
Review the Impro'vement 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 Operations Review Review the Reactor Operations Improvement Flan 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 organisation during the restart of the plant after 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 bave 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 draft letter.
The committee will review and provide any necessary advice concerning each test condition up to and including commercial operation, warranty test, and full power operation. This power escalation program will be submitted to the ERC in response to the December 24, 1985, letter.
1-3
7-
. ATTACNMENT 2 Reactor coerations_ImpIgygment Plan Sta,tys The Reactor Operations Improvement Plan was submitted to the NRC on October 18. 1985. Included herein is a status report l 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 PLAN
'. Commitment Status Action Item *Statu t
- 1. Current dated LCOs are displayed in hard copy. Conglete
- 2. The DOT system of flagging control board system and Inc omplete 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-saintenance test re-
' quirements.
- b. In'dicate which documents require revision. Complete
- 4. As a long-ters action, administrative votk procedures Partially Comp, will be simplified or clarified to consistency. (Training Reg'd.)
1
- 5. Item 5 Deleted. N/A j i
- 6. Nuclear Operations personnel have been advised to Complete ,
consider the consequences of taking even the ;
simplest actions. l
- 7. *xrptsui! have been advised that it is equally Complete important that the error be communicated so that apprey-f;*e operating staff or management action rati LA e 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 j and, when possible, modifying existing scenarios i to exercise the requalification classes on l routine plant startup and operation. J
- 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. ,
- EDII: All " Completes" have been verified by Nulcear Quality Assurance 2-2
, 12. The F1snt Manager er th2 Superictandsnt-0paratiens Coaplete
," , , cre seating individually with ecch MSS. NASS cod 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,0perations 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 j the plant is being operated. j
- 15. Superintendent-0perations 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 shif t.
- 17. The NASS has been placed in charge at the controls Complete area of the Control' Room during planned reactivity manipulatio6s. 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 l l
- 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.
analysing and reviewing significant reactor evolutions.
- 24. Operations Engineer has increased involvement in Complete )
operations by following and reviewing performance of shif t activities against established plans and checking the quality of Control Room logs.
- 25. The MSS 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 accomplishsd thrcush interfces with tha plcst Complete
, Outegs M:nege:asnt orgcnizatico cnd thrcugh dircct involvement in vsrk piconics twetings.
- 27. The Superintendent-0peraticas periodically and without Complete notice has been observing shift 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 l actual plant operations and the review of operations administrative activities such as shift turnover. los 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). -
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- 32. In addition, the advisor observes plant parameters Complete and provides his observations to the Plant Manager.
conducts a briefing of shif t operating personnel. l l
- 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. ,
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- 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.
I
- 37. An interim status chart has been implemented to complete I i 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. Numan factors methods are being applied to the Partially administrative procedures to make them more Complete.
streamlined and more user oriented. (Training Reg'd) l 2-4 l l
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- 40. LERs are bairg:
- 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.
i 42. Corrective action taken is being:
- a. Tracked to Completion. Complete
- b. evaluated for effectiveness. Complete
- 43. The cerrective action process is being further enhanced by:
- a. Refinement of procedures associated with the Complete proc es s.
I
- 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 pre vi asly initiated by QA organisation, will Complete improve the -ineliness 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
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NSS, NASS, and SOA, employes are reminded of their-responsibilities; delegated authority and account-abilities; of their expected job performances and of their relationship with other. shift members.
- 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 RSS is responsible for ensuring that the ability - Complete i to provide proper direction is not compromised by an !
excess of werk or testing.
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,' 49. For this recses (Item 48), tha NSS is centrolling work in ths Completo
, plcnt by determining pricrity cad c= unts of work fer
. 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 USS conducts status meetings at 0600, 1800, and Complete
-0100 hours.-
- 56. These meetings (Item 55) are held with representatives from complete the various work groups to monitor progress on mportant items as well as to allow additioes to the work schedule or review changes in course as directed by the RSS.
t
- 57. Coals 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.
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- 59. Detroit Edison organisational units have been Complete I assigned responsibility to track and trend perform- !
J- ance with respect to each of these criteria.
i 60. Management will be monitoring this performance so complete I that adjustments can be made, if necessary. '
- 61. The Nuclear Quality Assurance organisation of Nuclear complete Operations will provide independent verification of effective implementation of 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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Reactor Operations Ymprovement Pro o_rar Ind ic a t ora I I
i Comi At 1
o The goal is.to minimise the number of open work orders.
o The dottre line represents the expected while the solid line repense i a the actual results.
o As 4 ayjr;ry 26, 1986 there were 173 open work orders. I 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 minimise the number of outstanding Control Roon problem annunciators. i
-o The dotted line represetts the expected range. The solid l line represents the actual results. A specific breakdown {
between engineering and broke /fiz annunciators is also pres ent ed.
o As of January 26, 1986 there were a total of 39 outstanding Control Room problem annunciators.
Coal De o The goal is to perform all surveillance procedures on time.
including the grace period and to minimise the number requiring use of the grace period.
o For the week ending January 26, 1986 there were 100%
surveillances 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.
Coal Er !
o The goal is to minimise the number of outstanding, time-sensitive LCO's.
o As of January 26, 1986 there were sero (0) outstanding, time-sensitive LC0's.
Coal Fe o The goal is to minimise the number of Reportable Operational Occurrenc es.
o For the week ending January 26, 1986 there were sero (0)
LER's.
o The four week rolling average as- of January 26, 1986 was 0.25.
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l JL T :::- - --
.:-- _ L --
C0AL At Minimize number of open PN-21's (Work Orderal Objectivant TOTAL -
150 Managenent Attention Level TOTAL -
110 Expected N l u I ,
M 400 l a l E I :
R l l l l O 300 l l P I E I N l ,
219 . !
W 200 l\ l O 1 171 73 )
R l%15d6 ----- - - - - - - - - - -
.- - - - -150 MAL l E I 144 145 N
i 2 2 33 1 .[ 1 0 100 1------- ----------------- 110 R I Expected D i E l R I s 0 l I I I I I I I I I I I I I I I I i 1 I l December i January i February i March l 1 8 15 22 29 5 12 19 26 2 9 16232 9 1623306
, \
NOTE: Includes plant system related FN-21's (work orders) only.
During an Outage greater than one week in duration, total stimbers 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 la known work items to support reactor restart.
2-8
. .. . )
+ COAL ):
l Objective: EP's open 30 days - 15 Management Attention Level after field work -
7 Expected complete l l
\
l l
200 I I
180 1 1
!! umber l I of 160 1 Field l Connlete 140 l EDP's l 120 1 -
l 100 l Ooen l Pact 80 l 30 l .
Days 60 l I
U 41 40 j% P -38b5'4Y 32 20 1 10 l l------------------------------------------------------15'1%
l______________________________________________________ 7 l 0 l Excactad t I __l l l l I I l __J _ l l I I I I I I l Deconber l January l Februt.ry l 11 arch 1 1 8 1522295 12 19 26 9 9 15 23 2 9 la 23 30 G 30TE: This trend remains above the Management Attention Level. A management inquiry has revealed that the rate of closure bas remained relatively constant due to the large number of SQ DPs closed out during the 85-01 Outage.
2-9
C0AL.Ct Mininiso nutbsr cf insp?rtblo er centinuously clermirs
,}* , , , annuncistors in control Room Objectiva: -
15 Management Attention Level
- 10 Expected 100 I I Engineering Fixes = 23 I' Other Fixes = 16 90 I , - Total = 39 I
I 80 I j i 'Ibtal Number of Annunciators = 1224 !
l 70 I I
outstan$ing l l Ec l Control l I
Roon 50 51 1 -
Problen
- I 46 f
40 l J1 Annunciators I / 4( 39
)
l 36'3 38 ,33 R2 quiring 30 l l
Ingineering 1 y 23 20 l TL 1 l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _______________________________23,,,t
_ _ _ _1!i.,_,15 _
i 19 l-----------------------------_-------_'-----------_--_ 10 1 a,2 te.1 1
I OI
.. I I l i I I I I I I _I I I I I I I I I I Decenber l .Tanuary l February l '" arch l 1 3 15 22 211 5 12 In 26 2 P 16 23 2 9 16 23 30 f EDTE: Frobles 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 ,
l
- ~.... . . . . , . . . --. . . . - . _ . . . . . . . . . . . . . -
, C0AL 0 , Perform surveillances on time minimirine usine ermee period Ob jec t ive: Surveillances completed on time including grace period:
991 Management Attention Level
- 2001 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 periods 7/ week Management Attention Level 5/ week Expected i
101 l 1
Surveillances '
l 100 F100-100-100-100-100-100 Completed l 99 l cn Time 1 98 l Including I 97 l -
Grace Period l 96'l (t) I 95 l '
l I I I I I l' I I I I I I I I I I I I I l December l January l February i March l 1 8 15 22 29 5 12 19 26 2 9 16 21 2 9 1623306 I
10 l Survoillances l Not 8 l Completed l------------------------------------------------------ 7 MAL Within 6 1 24 Bours l------------------------------------------------------ 5
'- of ontering 4 l Expected tha Grace I Porlod 2 2 (ND./ Week) 1 17 \-1 2g1 -1 -
0 1 I I I I I l\ 0 I I I I I I I I I I l December i 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 2-11
- ~ ' ~ ~ -
~: :' ~ L a : ' - ~ ' *
- L._ 7:
.C0AL.ht$ MInfefre the number of outstandine. tim, mensitive LCO's Dblective: Number of dated - 5 Management Attention Level LCO's outstanding - 3 Expected I
10 l I
9I I
Number 8l 1
of 7l I
Dated 6I I
5 l------------------------------------------------------ 5 MAL LCO's 1 4I I
Dutatanding 3 l------------------------------------------------------ 3 1 Expected 21 2 I
o/
I 0-0
~
0-0 1 I I I I I I I I I I I I I I I I l 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 e
2-12
., _ f _ _
, . , , . - - . . - - -- - - - ' - - ' - - ~ ' ~
e
~
COAL *Tt Minfrire the numb r of reportable operational occurrences Ob fectives Number of Licensee - 2/veek Management Attention Level i Event Reports (LER's) 1.5/ week Expected a
5l 1 -
1 I
4I I
I Rumb3r l 3l l
l 2 - Mgmt.
of l Attention
-------------------------------------------- Level I -
g ------ - --------_---------------------------------- 1.5 LER'c/wk I ! Expected 1i 1 .1 1
I oI o o- 0-0 1 1 1 1. I I I I I I I I I I I I I I I l December i . January l February i March l 1 8 15 22 29 5 12 19 26 2 9 16 23 2 5 16 23 30 6 3i Frur l I
WaGk 2l l
Lrl . Q- -- - - - -- - - -- --- -- - - - - -- -- -- - - -- ------- - - - - - - - - - - - - 1. 5 - Mg mt . .
,, RD111ng 1.25 1.25-1.25 Attention Level 1 l------------\-------------------------------------------------------Expected Avarcge l .
0l .
5-25 I I I I I I I I I I I 'I I I I I I I I (LER'O/wk) 1 December i January l February 1 March 1 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
- :-- _ -- - . = ~ _ _ _; -
w~ .
1 1
- * * *
- ATTACHMENT 3
, . System and Eouipment Problem Resolut ion or Proeream The information berein identifies the status of system and l 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. Eigh Pressure Coolant Injection (EPCI) Fump
- 6. Emergency Dissel Generator Repairs
- 7. Residual West Removal Fump "B" Motor Replacement
- 8. Reactor Auxiliary Building Embedded Plates
- 9. Traversing In-Core Probe (TIF) Witrogen Purge Line Isolation
- 10. Reactor Water Clean-Up System Modifications t
3-1 r- > - - , - -- - - - -w1.- --w- ,--
, - - - , _ , . . . _ . . , - __ s . _ . _ , _ _ _ _ , , , , _ _ , , _ . _ , _ _ , _ . - , , , , , , , _ _ . . . , _ , , , - . , _
, .,,' 1. Eaul_nment {nvironmental Oualification Modificatlana In order to comply with the requirements of 10CFR49 and Generic Letter 85-15. an evaluation was made of i
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 Afternate 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 correc ted.
- 3. Main Eteam Evemas Line Renlac ement on September 15, 1985. cracks in the pipe wall of the east 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 vibra tion. Rev bypass lines have been installed which incorporate heavier well 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 4
, completed to enrure the system capacity meets the values stated in the Fermi 2 FSAR.
- 4. Santh Remeter Tend Puma Turbine (SRFFT) i The SRFFT failed in June,1985. The vibration on the machine was not detected in the Control Room due to inaccurate instrument indication. The extent of the damage required the complete disassembly and repair or replacement of the tutbine rotor, bearing pedestal.
and miscellaneous bearings, seals and tria piping.
Additional instrumentation has been added and the
! turbine is ready for operation when reactor steam is I
available. A piping modification was made on the i gland seal system to reduce air in leakage to the condenser.
3-2 l
l - : -_ : -: . . . , . -
~
, 5. Eigh Pressure Coolant Tni.ction (RFCI) F-n
. e Initici aparation cf ths Righ Frcosuro Coolcat o
Injection (HPCI) Fump, under load, evidenced moderate vibration. 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 etcan is available upon
. restart.
- 6. n==rgence Diesel cenermeer menafra The diesels have undergone extensive analysis to determine the cause for the bearing problema 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 con'tributing causes. In addition, a
, slow-start feature has been added. A reliability dessonstration is planned for two diesels. A presentation was made to the NRC staff on January 24, 1986, outlining this program. A femal submittal of the program will be made to the NRC.
- 7. R.=Idust Bane n.= oval Pu== 'n' Moenr m. 1me.=.ne On November 25. 1985 RRR 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.
- 3. memeenr An-111 rw su11 din. w k.dd.d Fine.g
. 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 after construction completion to ensure no overloading.
3-3 t'
w-....... - - - . . . . .. . . .
A esneervativa castysis h:d btsa parfarnsd to idsstify 8* i-I thsee cabsd=ents which pstostictly could ba
. cvarloedad. Novavar. subsaguzat dstoilsd revisw Ef
+
tha pstentially cvarloedad embsdseats is es go!=g cad will be coupleted prior to restart.
k
- 9. Traversing In-Core Probe (TIP) Nitrogen Furge Line Isolation Recent correspondence from the NRC reveals the TEF
{
nitrogen purge line should conform to Ceneral . Design Criteria 56 (CDC56). An interim design to meet the intent of CDC56 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 Vater cleanup System Modifications During initial operations. sumerous unnecessary
. Reactor Water Cleanup System (RWCU) isolations occurred. These isolations have been attributed primarily to the Steam Leak Detection System and to the differential flow (Leak Detection) isolation i signals. Instrument and control modifications were made on this system to prevent recurrence of the problem and to provide the operators Control Room information.
( l l
l l
i I
i l
i .
3-4
(
e
~ -
. . .. ATTACHMENT 4 l 3 i.
Actions to Yeaure Readinema for Reactor Restart Following are the items which were completed for the I last reactor startup prior to the fall 85-01 Outage. l Because this startup was successful, these items will be l repeated for the next startup. l l
- 1. Lineups and independent verification of lineups l will be completed on Engineered Safety Feature l (ESP) Systems designated by the Operations !
Engineer within 30 days of the planned reactor i l
startup date.
- 2. Existing lineups will be reviewed by Operations i Supervision for all plant systems.
- 3. D e lineups of primary containment manual isolation valves outside the dryvell will be verified and independently reviewed.
- 4. A random sample of fire barriers will be walked down and verified for compliance with Technical Specifications.
- 5. Security barriers will be walked down and verified for compliance with the Physical Security Plan.
- 6. De accuracy of the "Coutrol 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 J. applicability.
Additlanal Itama AAAnd to Yeaura RamAlmaan far Rantart he following additional items will also be completed to
, insure readiness for restarts
- 1. D e Reactor Operators responsible for reactor startup will have recently conducted reactor startup evolutions on the simulator.
l 4-1 l
yn _ - ..
- ~.
s Attechme2t 4 3 ,,
e, . . . .
- 2. Outstanding Technical Specification change requests will be reviewed by Operations Supervision to ensure full compliance with Technical Specifiestions.
- 3. The Technical Engineer will review Deviation Event
. Reports identified by Nuclear Froduction 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 (ROIF) goals listed below are either being met or show a trend toward the established goal. These goals
- are:
- a. Minimise the number of Control Room nuisance alarms.
- b. Minimise the number of Engineering Design j Packages (EDF) which are field complete for greater than 30 days but require paperwork closure.
- c. Minimise the number of time-sensitive Limiting Conditions for Operation (LCO).
- d. Minimise the number of " signed on" active work orders (FN-21's).
- e. Complete all surveillances within the grace period and minimise the use of the grace period.
- f. Minimise 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.
4-2
. ~ - . . . . . . . . . . . . . ~ . , , , . ..
4
, c .., ATTACHMENT 5 l
.. s .. e. ,
Actions To Be Completed After Restart Frfor to Test Condit{an f
' The following listing are the items which must be e completed prior to exceeding 52 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 i
4 power ascension. Upon successful completion of these itema the plant will have met all the technical requirements to exceed 51 power and will be ready to commence Test Condition 1.
- 1. High pressure coolant injection will be ratested and declared operable.
- 2. Reactor Core Isolation Cooling system will be l verified operable.
- 3. The Main Steam Relief Yalve and Automatic Depressurisation System will be verified operable.
- 4. Main Steem byp'ess 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 (Ro1F) goals listed below are being met or show a trend toward the established goals:
- a. Minimise the number of Control Room nuisance alarms.
- b. Minimise the number of Engineering Design
- Fackages (EDF) which are field complete for l greater than 30 days but require paperwork closure.
- i~
- c. Minimise the number of time-sensitive Limiting i Conditions for Operation (LCO).
- d. Minimise the number of " signed on" active work orders (PN-21's).
- e. Complete all surveillances within the grace period and minimise the use of the grace period.
- f. Minimise the number of Licensee Event Reports (LER) .
5-1 4
9 e
T
. . ~ . . . _ . _ . . ~ _ _ , .-.~--.--....._.......,...~;__,_.
. .__: . m .e--...., _ _ _ . . _ . _ _ , _ . _ , _ .