ML20235F620

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Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $75,000.Violations Noted:Failure of Licensed Operators to Follow Plant Operations Manual & Mode 3 Entered Although Required Diesel Generator Inoperable
ML20235F620
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 09/24/1987
From: Davis A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235F593 List:
References
EA-87-133, NUDOCS 8709290239
Download: ML20235F620 (4)


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l NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Detroit Edison Company Docket No. 50-341 Fermi 2 License No. NPF-43 EA 87-133 As a result of an inspection conducted during the period July 1-10, 1987, violations of NRC requirements were identified. In accordance with the l

" General Statement of Policy and Procedure for NRC Enforcement Actions,"  ;

10 CFR Part 2, Appendix C (1987), the Nuclear Regulatory Commissiori proposes  !

to impose a civil penalty pursuant to Section 234 cf the Atei:1c Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

A. Technical Specification 6,8.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Reguiatory Guide 1.33 recommends procedures in the following areas:

Authorities and Responsibii'ities for Safe Operations and Shutdown Shift and Relief Turnovers Technical Specification 6.8.1.a is implemented by the Detroit Edison ,

Company Plant Operations Manual (POM). Examples of failures to adhere to the POM include:

1. P0M Procedure 12.000.057, " Nuclear Production Organization," -

Revision 3, Paragraph 5.2.5, requires that the Nuclear Supervising Operator (NS0) remain continuously cognizant of the plant status.

Contrary to the above, on June 26, 1987, the NSO did not remain continuously cognizant of plant status in that, while the plant was in cold thutdowa (Mode 4), the reactor water temperature increased from 145 degrees r'. at 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> to approximately 220 degrees F. at 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />.' The reactor entered hot shutdown (Mode 3) in violation of Technical Specifications when the reactor water temperature exceeded 200 degrees F.

2. POM Procedure 12.000.057, "No. clear Production Organization," Revision 3, Paragraph 5.2.4.5, requires that the Nutlear Assistant Shift Supervisor (NASS) assist the Nuclear Shift Supervisor (NSS) in the operation of the plant and control room under all conditions, ensuring compliance with all applicable procedures a id regulations.

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.m Contrary to the above, on June 26,.1987, the NASS did not assist the NSS in ensuring compliance with applicable procedures and regulations in that he was not aware that the reactor, which was required to be in Mode 4 because of inoperable equipment, experienced an unplanned and uncontrolled heatup to 220 degrees F. and entered Mode 3 in violation of. Technical Specifications.  ;

3. P0M Procedure 21.000.01, " Conduct of Shift Operation," Revision 33, .

Paragraph 6.5.1.3.c, requires that, when it is necessary or desirable to provide a short, on-shift relief for the NSS, NASS or Control Room NSO, the oncoining operator be fully cognizant of existing plant conditions and evolutions in progress.

Contrary to the above, on June 26, 1987, the NSS relieved the NASS and the relief NSO relieved the control room NSO for a short period; however, neither the NSS nor the relief NSO were cognizant of existing l plant conditions. Neither individual was aware of the reactor water ,

temperature or aware that the reactor water temperature was approaching 200 degrees F. without appropriate controls.

B. Technical Specification 3.0.4 requires that entry into an operational mode not be made unless the conditions for the Limiting Condition for Operation (LCO) are met without reliance on provisions contained in the ACTION requirement.

Technical Specification 3.8.1.1 requires two separate and independent onsite A.C. electrical power sources, each consisting of two emergency diesel generators, in Operational Conditions (Modes) 1, 2, and 3.

Contrary to the above, at approximately 1:00 p.m. on June 26, 1987, the plant entered Mode 3 from Mode 4 and remained in Mode 3 for approximately two hours although one of the required diesel generators (EDG-13) was inoperable and the Limiting Condition for Operation was not met without reliance on provisions contained in the ACTION. requirement.

This is a Severity Level III problem (Supplement I).

(Civil Penalty - 575,000 assessed equally between Violations A and B)

Pursuant to the provisions of 10 CFR 2.201, Detroit Edison Company is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps l that will be taken to avoid further violations, and (5) the date when full l'

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Notice of Violation 3 compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, inis response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalties by letter to the Director, Office' of Enforcement, U.S. Nuclear Regulatory Commission, with l

4 check, draft, or money order payable to the Treasurer of the United States l in the amount of civil penalty proposed above, or may protest imposition of l the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil pnalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violation listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1987), should b~e addressec. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.?01, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g.,

citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c cf the Act, 42 U.S.C. 2282c.

The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and answer to a Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,

~ Notice of.' Violation 4 DC 20555 with'a copy to the Regionci Administrator, U.S. Nuclear Regulatory Commission, 799 Roosevelt Road, Glen Ellyn, Illinois, 60137, and a copy tc> the NRC Resident Inspector at Fermi.

FOR THE NUCLEAR' REGULATORY COMMISSION 1 00  %

A. Bert Davis Regional Administrator Dated a Glen Ellyn, Illinois this ay of September 1987 l'

U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-341/87027(DRS)

Docket No. 50-341 Licensee: Detroit Edison Company i

2000 Second Avenue Detroit, MI 48226 Facility Name: Fermi 2 Nuclear Power Plant Inspection At: Fermi 2 Facility, Newport Michigan Inspection Conducted: July 1-10,1987 Inspectors: . re or ^ N/2 Date

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r Date Approved By: G . Wr h i kl h7 Test Programs Section Date Inspection Summary Inspection during the period of July 1-10, 1987 (Report No. 50-341/87027(DRS))

Areas Inspected: Special inspection of the events surrounding the unplanned mode change (cold shut down to hot shut down) of June 26, 1987.

Results: Three (3) violations of Technical Specifications were identified during the review of the unplanned reactor mode change.

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  • DETAILS
1. Persons Contacted
a. Detroit Edison Company
    1. B. Ralph Sylvia, Group Vice President, Nuclear
  • F. Agosti, Vice President Operations
    1. 5. G. Catola , Chainnan,' NSRG
  • R. Lenart, Plant Manager, Nuclear Production
  • T. Randazzo, Director, Regulatory Affairs
  • G. Trahey, Director Nuclear Quality Assurance
    1. G. Overbeck, Director Operator Training ~
    1. E. Preston, Director Plant Safety
    1. 5. Frost, Licensing
  • 5. Cashell, Licensing Engineer
    1. W. Tucker, Superintendent Operations J. Clark, Nuclear Shift Supervisor R. Trimai, Nuclear Assistant Shift Supervisor M. Koralewski, Control Room Nuclear Supervising Operator R. Valdeze, Nuclear Supervising Operator in Training J. Louis, Shift Technical Advisor R. Jolley, Shift Operations Advisor T. Given, Control Room Nuclear Supervising Operator
  1. M. L. Bufalini, II, Supervisor, Media Relations
    1. P. A. Marquardt, General Attorney
b. USNRC Personnel
  1. A. Bert Davis, Regional Administrator
  1. E. G. Greenman, Deputy Dire; tor, Division of Reactor Projects
  1. C. W. Hehl, Chief, Operations Branch
    1. G. C. Wright, Chief, Test Programs Section
  1. B. Berson, Regional Counsel
  • M. Parker, RI
    1. D. Hills, Reactor Inspector
    1. J. Hopkins, Reactor Inspector
    1. L. G. McGregor, Reactor Inspector
  1. W. H. Schultz, Enforcement Coordinator
  1. P. R. Pelke, Project Inspector
  1. J. J. Stefano, Project Manager (NRR)
  • Denotes those at the July 2,1987 exit interview.
  1. Denotes those at the July 7, 1987 management meeting.

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Sequence of Events 2.

DATE TIME DESCRIPTION 6/25/87 0120 Reactor is manually scrammed from low power due to Recirculation Pump LCO.

6/25/87 1456 ESF signal received /Several systems fail to respond as expected including both LPCI divisions and E0G No. 13.

6/25/87 2106 Entered OSL 87-0465 on EDG No. 13.

6/25/87 2206 Entered OSL 87-0466 on Divisions 1 and 2 RHR System.

6/26/87 '0330 Placed RHR System in shutdown cooling.

6/26/87 0400 RECIRC LOOP 'A' TEMPERATURE 240 F.

6/26/87 0455 Reactor in Cold Shutdown (Mode 4) at <200 degrees F.

. 6/26/87 0500 RECIRC LOOP 'A' TEMPERATURE 190 F.

6/26/87 0600 RECIRC LOOP 'A' TEMPERATURE 160 F.

6/26/87 0700 RECIRC LOOP 'A' TEMPERATURE 140 F.

6/26/87 0700-0800 Shift Turnover / Recirculation loop temperature approximately 145 degrees F. RHR HX Outlet Valve was closed by previous shift to prevent further cooldown below 140 degrees F. Oncoming shift aware of this except NSS who does not specifically remember / Relief shift is present during morning hours only/CRNSO assigns trainee to control reactor water temperature.

Understanding of trainee is that he is only responsible for logging temperature.

6/26/87 0800 RECTRC LOOP 'A' TEMPERATURE 150 F.

6/26/87 0800-1100 Temperature increases from 150 degrees F to 186 degrees F. During this time the shift is involved in surveillance, procedure change request review and maintenance activities in preparation I

for subsequent plant startup planned for the following day. Attempts to restore RWCU system in progress.

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DATE TIME DESCRIPTION 6/26/87 0900 RECIRC LOOP 'A' TEMPERATURE 165 F.

6/26/87 1000 RECIRC LOOP 'A'. TEMPERATURE 178 F.

6/26/87 1100 RECIRC LOOP 'A' TEMPERATURE 186 F.

6/26/87 1135-1205 CRNSO relieved for lunch by relief NSO.

6/26/87 1200 RECIRC LOOP 'A' TEMPERATURE 195 F.

6/26/87 1200-1225 NSS relieves NASS for lunch.

6/26/87 1300 RECIRC LOOP 'A' TEMPERATURE 205 F (Mode 3 was entered at > 200 F).

6/26/87 1400 Recirculation loop temperature log reading is not recorded.

6/26/87 1500 RECIRC LOOP 'A' TEMPERATURE 220 F Trainee informs CRNSO/CRNSO immediately takes actions to reduce reactor water temperature and informs NASS and NSS.

6/26/87 1525 Recirculation loop temperature reduced to below 200 degrees F (Enter Mode 4).

6/26/87 1600 RECIRC LOOP 'A' TEMPERATURE 168 F.

6/26/87 1700 RECIRC LOOP 'A' TEMPERATURE 158 F.

C/27/87 0433 Cleared OSL 87-0466 on Divisions 1 and 2 RHR System.

6/27/87 0705 Cleared OSL 87-0465 on EDG No. 13.

6/27/87 1600 Licensee notifies Region III Duty Officer of the heat up event.

6/28/87 1133 Commenced reactor startup.

6/28/87 1344 Reactor critical.

6/P9/87 1858 Licensee notifies NRC Operations Center of the heat up event.

3. Event Description The following is a description of the June 26, 1987 mode change event derived primarily from interviews with the individuals involved and supplemental by logs and computer data retrieval.

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1 On June 25, 1987, the reactor plant was in Hot Shutdown (Mode 3),

after having shutdown due to a failure of the Recirculation Pump "B" Motor-Generator. At approximately 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> an Engineered Safety Feature (ESF) signal was received during (I&C) testing. Several systems failed to respond as expected to the ESF signal including both divicions of the Low-Pressure Coolant Injection (LPCI) which failed to start and Emergency Diesel Generator-13 (EDG-13) which experienced voltage regulator problems during itsleutomatic start sequence. The LPCI mode of' Residual Heat Removal (RHR) and EDG-13 were declared inoperable. Unrelated to the ESF signal, the Reactor Water Cleanup System (RWCU) isolated on high' demineralized filter inlet temperature at approximately 2100 hcurs.

Based on the amount of inoperable equipment and the time frames in which they had to be returned to service, plant management decided.to place'the unit in Cold Shutdown (Mode 4). A cool down was started at approximately midnight on June 26 and the reactor was in Mode 4 (less than 200 degrees F) at 0445 hours0.00515 days <br />0.124 hours <br />7.357804e-4 weeks <br />1.693225e-4 months <br /> that same day. Reactor water temperature had been reduced using the shutdown cooling mode of RHR in accordance with POM 23.205,

" Residual' Heat Removal System."

The shift' complement consisted of the Nuclear Shift Supervisor (NSS),

Nuclear Assistant Shift Supervisor (NASS), Control Room Nuclear Supervising Operator (CRNS0) and a trainee assigned to the CRNSO. Additionally, there were three Nuclear Station Operators (NS0) from the relief crew to assist _

in the work load, a Shift Operations Advisor (SOA) and a Shift Technical Advisor (STA). The STA also served as the General Electric Start-up Tests Operation observer (STO). The shift planned to be involved in normal surveillance for Mode 4 in addition to surveillance and maintenance activities in preparation for a planned start-up the following day.

Shif t turnover was conducted at approximately 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> on June 26, 1987, at which time the plant was in Mode 4 with reacter water temperature at 145 degrees F, recirculation loop 'A' had full shutdown cooling flow and loop IB' had.5% flow, RHR pump 'C' was operating for shutdown cooling and the RHR Heat Exchanger (RHR HX) Outlet Valve E11-F048A was shut to prevent reactor cooldown below 140 degrees F. Interviews with shift personnel indicated that with the exception of the NSS, the entire control room shift including the trainee understood that the RHR Heat Exchanger (HX) Outlet Valve was shut.

Immediately following the shift turnover an apparent misunderstanding between the CRNSO and trainee resulted in the CRNSO believing that the trainee understood he had been assigned the responsibility of logging i

and controlling reactor water temperature. Whereas the trainee believed he was only to log the temperatures.

Shift routine had both the CRNSO and trainee involved in surveillance required for Mode 4 and the planned start up. The NASS was involved in procedure change requests (PCR), reviewing surveillance for Mode 4 and i

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'l maintenance activities. The CRNSO was also assisting in restoring the j RWCU system to service as reactor water level was increasing with no d means of rejecting water.

From 0800 to 1200 houn , the trainee logged recirculation loop temperatures I hourly from 150 to 195 degrees F (approximately 10 degrees per hour heat up rate). At approximately 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br /> the CRNSO was relieved for a 30 minute lunch break by an MSO from the relief crew. At approximately noon  ;

the NASS was relieved by the NSS for a 25 minute break. The trainee logged ]

the recirculation loop temperature of 205 degrees F at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />. The  !

1400 hour0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> log readings were not taken. At approximately 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> the trainee nWeed the recirculation loop temperature was 220 degrees F and informed 6he CRNSO. The CRNSO immediately started to cool the primary  ;

system and notified the NASS and NSS. The reactor ' A' recirculation' loop temperature was logged at 170 degrees F at 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />.

On Saturday, June 27, 1987 at 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, the licensee notified i the Region III Duty Officer of the event. At 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> on Monday, i June 29, 1987, the licensee notified the NRC Operations Center of the event.

4. Results of Special Inspection

. Region III inspectors conducted a special inspection of the event on July 1 and 2, 1987. The inspection consisted of interviews with pertinent shift personnel involved in the inadvertent heatup of June 26, 1987 and other licensee staff personnel. In addition, the inspectors reviewed shift logs, strip chart recordings, procedures, Emergency Response Information System (ERIS) data, and other pertinent documentation.

It was determined that a number of contributing factors were evident in the event. The first and most serious is the lack of attention to ar< essential plant parameter (reactor water temperature) by the on-shift personnel. Review of the data showed an easily identifiable upward trend in reactor water temperature. This lack of attention and identification occurred even though the increasing trend was expected when the Residual Heat Removal System Heat Exchanger Outlet Valve is closed during shutdown cooling. Interviews with shift personnel indicate that they were aware of these expectations. Licensed personnel available in the control room included the CRNSO and the NASS. At different times the NSS relieved the NASS and another NSO relieved the CRNSO.

During tne morning hovs, the routine shift was augmented by three NS0s from the relief crew who were in the control room assisting in various activities. The Shift Operations Advisor (SOA), licensed as a Senior Reactor Operator, and the Shift Technical Advisor (STA), who is not licensed, were also in the control room at various times. The STA and the SOA are not required to be present in Mode 4. These personnel had been awigned other duties by the NASS including procedure changes, l

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maintenance activities and surveillance such that they were not in a position nor were they responsible for monitoring reactor water temperature.

As a result of the normal shift personnels failure to monitor a critical plant parameter, reactor water temperature was allowed to exceed the 200 degree F Technical Specification limit and the reactor entered Mode 3 for a period of approximately two hours. Entry into Mode 3 represented a violation of Technical Specification 3.0.4 in that equipment required to be operable prior to entry into this operational condition was inoperable (341/87027-01(DRS)). The inoperable equipment included Emergency Diesel Generator No.13 for inspection of the voltage regulator, Divisions I and II of the Low Pressure Coolant Injection (LPCI) mode of RHR which was

" administrative 1y" inoperable to investigate.its apparent failure to automatically start on an ESF signal (the system was never functionally inoperable), and Division II of the Main Steam Isolation Valve Leakage Control System.

The inspectors determined that various procedural inadequacies also contributed to this event. A review of procedures Plant Operations Manual (POM) 22.000.10 " Shutdown From Rated Power To Cold Shutdown,"

Revision 5, POM 22.000.12 " Reactor Heatup, Cooldown and Temperature Vs. Pressure Monitoring" Revision 6, and P0M 23.205 " Residual Heat

- Removal System" Revision 15, identified a lack of guidance for proper maintenance of a cold shutdown condition. In particular, no direction was given as to the proper temperature band to maintain reactor water temperature within or what action (s) to take to restore reactor water temperature. Failure to provide this type of guidance resulted in a i lack of definitive and consistent methods to maintain cold shutdown. ]

l A review of POM 21.000.01 " Conduct of Shift Operations" Revision 33 J identified a lack of specific guidance concerning allowable usage and l control of nonlicensed operators in training for a Reactor Operator (RO) {

or Senior Reactor Operator (SRO) license. Step 6.3.5 of the procedure indicated that " manipulations of reactor controls must be under the direction of a licensed operator and with the cognizance of the control room NSO." However, this statement is considered vague in that it i neither defines what controls would fall under this requirement nor the method of supervision that constitutes "under the direction of."

Interviews with various licensee personnel showed that plant management ,

had not provided specific guidance in this regards and therefore the l philosophy of these individuals on training varied considerably. As a result, the NSO improperly turned over complete responsibility for '

maintaining a cold shutdown condition to the trainee in that he did not ensure or remain cognizant of the activity. Due to miscommunication between the trainee and the NSO, the trainee was only logging and not actually controlling reactor water temperature. Further the NASS indicated during the interviews that he relied upon the NSO to inform him of changing l

plant conditions durirg routine operations. Neither philosophy is consistent with what the NRC expects as a proper method for the NSO or NASS to monitor and remain cognizant of plant conditions. This is l

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Y 4l in part due to a failure of plant management to adequately define methods of. accomplishing this responsibility in either procedures or other directives and is a failure on the part of the individuals to execute

.to provisions of their licenses.

C The procedural inadequacies are considered examples of a violation of 10 CFR 50, Appendix B, Criterion V-(341/87027-02(DRS)).

A' review was con' ducted to determine whether personnel actions on June 26,

.1987, were in accordance with existing plant administrative procedures.

POM 12.000.057 " Nuclear Production Organization" Revision 3 described-

-the following responsibilities:

a. -The NSO has shared responsibility with the NSS to maintain proficient and current knowledge of plant and system status.
b. The NSO shall remain continuously cognizant of the reactor power level and plant status,
c. The NASS assists the NSS in the operation of the plant and control room under all conditions, ensuring compliance with all applicable procedures and regulations.

, POM 21.000.01 indicated that in conjunction with short on-shift relief for the NSS, NASS or control room NSO, the oncoming operator is to be fully cognizant of existing plant conditions and evolutions in progress.

During the 7:00 a.m. to 4:00 p.m. shift on June 26, 1987, various individuals filled these positions. It is clear that the normal shift crew failed to properly discharge their responsibilities. Furthermore two individuals who provided short-term relief during the event did not become fully cognizant of existing plant conditions as evidenced by their lack of action to suspend the heatup.

These' items are considered a violation of Technical Specification 6.8.1.a in that the personnel did not properly implement established procedures governed by Regulatory Guide 1.33, Revision 2, February 1978 in regards to these administrative requirements (341/87027-03(DRS)).  ;

The inspectors reviewed deportability requirements to ensure satisfactory conformance of licensee reports associated with the event with applicable  ;

regulations. It was determined that the event did not correspond to an J Emergency Classification in the licensee's approved Emergency Plan and i thus did not require immediate notification of the NRC Operations Center j in accordance with that provision of 10 CFR 50.72. Review of 10 CFR 50.36 and 10 CFR 50.72 did not identify any requirements to notify the NRC within one or four hours. A determination on the effect that specific statements l in the facility operating licensee and technical specifications have upor, J deportability remains to be completed. The deportability aspect of the event is considered an Unresolved Item pending further NRC review (341/87027-04(DRS)).

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i The event, from a plant status / transient aspect, is considered to be of minor safety significance from the technical aspect. However, a managerial breakdown is clearly evident which represents a more serious reflection on the ability to properly control activities and safely operate the plant. j Indicative of this breakdown was plant management's tolerance or '

unawareness of an attitude which would allow numerous on-shift licensed personnel to neglect their responsibility of remaining cognizant of plant status in favor of performing other activities in preparation for a subsequent plant startup.

Actions taken during the event and interviews with personnel clearly indicate a lack of appropriate management direction and emphasis given to the plant licensed operators regarding operational conduct including:

proper controls and methods of supervision for trainees, appropriate short-term relief turnover responsibilities, appropriate definitions and methods to adequately fulfill responsibilities of remaining cognizant of plant status, and adequate direction as to maintaining cold shutdown.

5. Management Meeting On July 7, 1987, a management meeting, at Detroit Edison Company's request, was held at the Region III office in Glen Ellyn, Illinois. Detroit Edison Company presented the Region III staff with the results of the Deco

. investigation into the unplanned heatup of June 26, 1987. Detroit Edison then discussed actions being taken to correct the identified deficiencies including:

a. Examination of all control room shift personnel on their prescribed duties and responsibilities.
b. Define relationship between the control room NSO and trainees.
c. Clarify procedure (s) for short-term relief turnovers of control room NS0s and NASS'.
d. Augmentation of shifts during periods of high work activity.
e. Reduce to the minimum the administrative activities of the shift personnel.
f. Emphasize to all shift persannel the importance of remaining  ;

cognizant of plant conditiuns.

6. Interim Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) on July 2, 1987, and summarized the scope and findings of the inspection activities to the date including:
a. Lack of guidance to operations personnel on the relationship of trainee's to the shift.

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b. Procedural inadequacy
c. Short term relief turnovers
d. Relationships between shift members as to the conduct of operations i.e., assignment of activities which distract from an individual's ability to stay abreast of the overall plant status.
e. Deportability of the June 26, 1987 event -
f. Inconsistencies between individuals recollections of control  !

l room workload.

g. Inconsistencies between the trainee's account of his activities around 12:00 (noon), on July 26, 1987, and the relief NSO's -

description of that time.

The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors duving the inspection. The licensee did not identify any such documents / processes as proprietary. The licensee acknowledged the findings ,

of the inspection.

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