ML20127A691

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Forwards EOP Insp Rept 50-341/92-18 on 921102-23.Violations Noted.Support Procedures Were Technically Correct & Useable & Specified Actions Could Be Accomplished by Operations Staff Using Existing Equipment,Controls & Instrumentation
ML20127A691
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 01/08/1993
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Orser W
DETROIT EDISON CO.
Shared Package
ML20127A694 List:
References
NUDOCS 9301120041
Download: ML20127A691 (3)


See also: IR 05000341/1992018

Text

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. .

JAN - 81ss3

-Docket No. 50-341

The Detroit Edison Company

ATTN: W. S. Orser

Senior Vice President

Nuclear Generation -i

6400 North Dixie Highway

Newport, MI 48166 ' ~

-

SUBJECT: NRC EMERGENCY OPERATING PROCEDURE (EOP) TEAM INSPECTION

(REPORT NO. 50-341/92018(DRS))

Dear Mr. Orser:

This refers to the inspection of the' Fermi Emergency Operating

Procedures (EOPs) by a Region III NRC Team led by Peggy R.

Rescheske on November.02 - 23, 1992. The inspection included a

review of activities authorized for the Fermi 2 Nuclear Power

Station. At the conclusion of the inspection, our-findings.were

discussed with Mr. D. R. Gipson and others identified in the

enclosed inspection report.

The inspection focused on your EOPs and the-programs for

-controlling and maintaining these procedures.- -Emphasis was

placed on_the July 1991 transition to flowchart format EOPs.

The enclosed' inspection report identifies areas examined during

the inspection. Within these areas, the inspection consisted of i

a selective examination 1of procedures and_ representative records, I

observations, and interviews with personnel.

The Team determined that, in general, the Fermi EOPs, including

support procedures, were technically correct and useable, and

that-the specified actions could_be accomplished-by the

operations staff using existing equipment, controls,'and

instrumentation. The Team also concluded that the EOPs-were

adequate for mitigating the accident. scenarios described in the

BWR Owners. Group Emergency Procedure Guidelines. However, given

the current Fermi EOP program, the Team could not determine

whether the quality of the EOPs would be appropriately controlled

and maintained over time. Weaknesses were identified in the

EOP Writers Guide, and in Verification and Validation-(V&V)

program implementation'for the flowcharts. These weaknesses were

primarily due to the_ lack of sufficient human factors-support

during the development and review of the EOP flowcharts and

Writers Guide.

9301120041 930108

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-.- .

The Detroit Edison Company 2 J N ' O 033

While no technical deficiencies were identified, the Team

determined that the EOP flowcharts lacked; consistent application

of the human engineering principles which support operator

performance. As a result, under a high stress emergency

condition, the potential exists that the flowcharts would prove

to be difficult to use and may not successfully minimize operator

confusion and error. In addition, based on the deficiencies

identified during the EOP support procedure walkthroughs (e.g.,

labeling weaknesses), several in-plant tasks would only be

accomplished-after some confusion or time delay.

We are concerned that the EOP program at Fermi contained

weaknesses which are similar to those identified at other~

utilities over the past few years. It appears that generic

information issued by the NRC was not effectively factored into

the revision process for_the Fermi EOPs. This information

included NUREG-0899.which discusses EOP preparation, and

NUREG-1358 which discusses lessons learned from the EOP team

inspections conducted in 1988.

While no violations of NRC requirements were identified during

the course of this inspection, we do request that you respond

within 60-days of the date of this letter to the oper. items-

identified in the attached inspection report. Your response to

the three open items shou]d include a description of the actions

_you plan to take to resolve each of the specific weaknesses

identified in the attached report.

In accordance with 10'CFR 2.790 of the Commission's regulations,

a copy of this letter, the enclosure, and your response to.this-

letter (regarding the open items) will be_placed in the NRC

_

Public Document Room. ,

The responses directed by this letter are not subject to the

clearance procedures of_the Office of Management and Budget as

required by the Paperwork Reduction Act of 1980, PL 96-511.

If you have any questions concerning this inspection, please

contact Bruce L. Burgess of my staff at (708)-790-5575.

Sincerely,

ORIGINAL SIGNED BY T. O. MARTill

T. O. Martin, Acting Director

Division of Reactor Safety

Enclosure: Inspection Report

No. 50-341/92018(DRS)

See Attached Distribution

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See Following Page-------------------------- Iiv\

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Rescheske/cg Langstaff Bielby B. Burgess Phillips Wright Martin

01/ /93 01/ /93 01/ /93- 01/ /93 01/ /93 01/4/93

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01/_/93

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The Detroit Edison Company 3 JAN - 81333

If you have any questions concerning this inspection, please

contact Bruce L. Burgess of my staff at (708) 790-5575.

Sincerely,

H. J. Miller, Director

Division of Reactor Safety

_

Enclosure: Inspection Report

No. 50-341/92018(DRS)

See Attached _ Distribution

_

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M.Phillips hs:i' b[t Martin II. Miller

01/ l/93

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01/e7/93 01/ /93 01/ /93

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. _.

,,_- a

The Detroit Edison Company _ 3- JAN - 8.199

Distribution

.cc w/ enclosure:

D. R. Gipson,JVice President

Nuclear Operations

John A._Tibal, Supervisor

of Compliance

P. A. Marquardt, Corporate

Legal Department-

DCD/DCB (RIDS)

OC/LFDCB

_ Resident Inspector, RIII

-James R. Padgett, Michigan Public

Service Commission

Harry-H. Voight, Esq.

Michigan Department of

Public Health

Monroe County Office of

civil Preparedness.

Fermi, LPM, NRR .

J. S. Wermiel, NRR/LHFB

J. A. Arildsen,.NRR/LHFB

R. S. Cain, EG&G

L. T. Ostrom, EG&G

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