NRC-93-0024, Responds to Open Items Noted in NRC EOP Team Insp Rept 50-341/92-18.Corrective Actions:Enhancement of EOP Labeling Currently in Progress,Eop Overview Committee Formed & Milestones Established Re Administrative Controls
| ML20034H071 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/09/1993 |
| From: | Orser W DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-93-0024, CON-NRC-93-24 NUDOCS 9303150205 | |
| Download: ML20034H071 (4) | |
Text
,Y William S. orser Executive Vice President Nuclear Generabon
] (j Fermt 2 Ec ison
=400 Nortn Dixie H;ghway 6
Nuclear
=r"-
o-March 9, 1993 NRC-93-0024 t
U. S. Nuclear Regulatory Commission Attn: Document Control Desk i
Washington, DC 20555
References:
1)
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 2)
NRC Inspection Report No. 50-341/92018, dated January 8, 1993
Subject:
Reply to NRC Emergency Operating Procedure Team Inspection This letter provides the Detroit Edison's response to the Open Items contained within NRC inspection report 50-341/92018. Detroit Edison appreciates the opportunity to respond to the inspection of the Fermi 2 Emergency Operating Procedures. The enclosed attachment provides a detailed response to the open items identified by the NRC team.
If you have any questions concerning this response, please contact Mr. Joseph Pendergast, Compliance Engineer at (313) 586-1682.
j Sincerely, i
Enclosure cc:
T. G. Colburn i
A. B. Davis W. J. Kropp H
P. Phillips Region III i
150029 i
N[a. ('
9303150205 930309 PDR ADOCK 05000341 G
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4, Enclosure to NRC-93-0024 March 9, 1993 i
Page 1 Introduction The purpose of this letter is to respond to the inspection of the Fermi 2 Emergency Operating Procedures (EOPs) by a Region III NRC Team on November 2 through 23, 1992. Fermi 2 personnel found the inspection of our E0Ps and the inspection of our process for controlling and maintaining the EOPs to be extensive. Detroit Edison understands the open items and intends to address each one of the open items listed in the Inspection Report.
i We agree with the NRC that the E0Ps and support procedures are I
technically correct and useable. The actions specified by these procedures can be accomplished by operations personnel using the existing equipment, controls and instrumentation available. The EOPs are adequate for mitigating the accident scenarios described in the l
BWR Owners' Group E0P Guidelines. The usability of the DOP flowcharts has been demonstrated numerous times during license operator exams.
However, we realize that the E0P administrative controls can be enhanced so that the quality of the E0P's can be improved, controlled and maintained over time.
Detroit Edison agrees that the E0P Writers Guide and the Verification and Validation (V&V) process for flowchart implementation can be improved. We also agree that the open items discussed in the inspection report were primarily due to the lack of human factors support during the development and review of the E0P flowcharts and Writers Guide. Therefore, Detroit Edison established the E0P Overview i
Committee, consisting of managenent personnel, who will provide the oversight and direction to ensure that the open items are completely i
addressed.
Additionally, while no technical deficiencies were identified by the
.l NRC Team with the E0P flowcharts, the consistent application of human factor principles need to be applied to the E0P flowcharts. These human factor principles are intended to establish and maintain a high level of operator performance during abnormal or high stress conditions.
An Action Plan with completion date nilestones was established to resolve the EOP open items. The open items 92-018-01, 92-018-02 and 92-018-03 Identified by the NRC Team will be completely remedied by startup from the Fourth Refuel Outage.
Open Item 92-018-01a "Several minor procedure deficiencies were identified (e.g., omission of support procedure references in the flowcharts) during the desktop reviews of the E0P flowcharts and support procedures."
i Detroit Edison's Action to Resolve Open Item The procedure discrepancies identified by the NRC Team will be addressed as part of the DOP procedure enhancement effort. Revision of the E0Ps is currently in progress.
s.
Enclosura to NRC-93-0024
. March 9,1993 Page 2 Open Item 92-018-01b i
"No significant procedural deficiencies were noted during the walkthroughs of the E0P flowcharts and support procedures; the operators could generally accomplish the E0P tasks as written, and the required equipment was generally available and pre-stagged. However, several weaknesses were identified (e.g., labeling) which have the potential to cause operator delays and confusion."
Detroit Edison's Action to Resolve Open Item The labeling and possible operator delay and confusion issues identified by the NRC Team will be addressed as part of the E0P enhancements. The enhancement of E0P labeling is currently in progress. These issues will be resolved using the current labeling policy by the startup after the Fourth Refuel Outage.
Open Item 92-018-02 "The V&V program was generally adequate, however, sufficient guidance was not provided to ensure successful completion of the V&V for the flowchart E0Ps. Significant weaknesses were identified in the implementation of the V&V program, particularly for that conducted prior to E0P flowchart issuance.
In this regard, the V&V effort was both incomplete and ineffective, especially from a human factors standpoint."
Detroit Edison's Action to Resolve Open Item The V&V process discrepancies identified by the NRC Team will be addressed as part of the general E0P procedure enhancement. The_V&V effort for the E0P enhancement will conform to industry standards.
Furthermore, an independent human factors reviewer will participate in the V&V effort.
Open Item 92-018-03 "The EOP flowcharts and Writers Guide were developed and verified without appropriate consideration of human performance principles. As a result, the Writers Guide did not effectively control the presentation of information in the E0P flowcharts, and the flowcharts
- 6 were poorly organized, formatted, and written. 1te weaknesses identified in the E0Ps have the potential for affecting operator performance in high stress situations."
Detroit Edison's Action to Resolve Open Item The E0P Writers Guide and the Administrative Procedure, " Emergency Operating Procedure Development Process" will be rewritten as part of general improvements and will address the open item identified by the NRC Team. An independent human factors reviewer will be involved with the development of the Writers Guide, Administrative Procedure and the ESP flowcharts.
+
Enclosure to NRC-93-0024
. March 9, 1993 Page 3 Conclusion Detroit Edison-formed an E0P Overview Committee and the actions to resolve open items identified by the NRC Team are presently being addressed. Milestones have been established for enhancing the Fermi 2 administrative controls for 'EOP development and implementation. The milestones are: revise and enhance the Writers Guide by the,end of July 1993, revise and approve the Administrative procedure by the end of September 1993, revise the E0P flowcharts and have V&V of. the flowcharts complete by the end of February 1994, and implement the revised flowcharts and support procedures by startup from the Fourth Refuel Outage.
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