ML20211G091

Authorizes Util to Exceed 20% Power & Proceed W/Testing Program Up to 50% Power Consistent W/Schedule & Availability of All Equipment Needed to Normally Enter Mode 1 of Reactor Operation.Readiness Assessment Encl

ML20211G091
Person / Time
Site:	Fermi
Issue date:	02/16/1987
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Sylvia B DETROIT EDISON CO.
References
NUDOCS 8702250274
Download: ML20211G091 (11)

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I fEB161987 Docket No: 50-341 Detroit Edison Company ATTN: Mr. B. Ralph Sylvia Group Vice President Nuclear 6400 North Dixie Highway Newport, MI 48166

Dear Mr. Sylvia:

On September 12, 1986, Region III authorized operation of the Fermi 2 facility at power levels up to and including 20% power. This authorization permitted you to proceed with the startup testing program as outlined in Test Condition 1.

Throughout the test program to date, the NRC has continued its evaluation of overall operations at the Fermi 2 facility. The NRC Restart Team has informed me that all testing applicable to Test Condition I has now been accomplished.

While the defined testing program was completed with few deficiencies, we noted that the facility encountered a number of other problems. These encompassed diverse areas; equipment related problems most notably the preventable damage to the condensate storage tank; a negative trend with respect to the number and types of Licensee Event Reports; and programmatic problems in the periodic surveillance testing area. Our concerns in these areas were forwarded to you by our letter dated December 12, 1986. As part of its continuing observation, the Restart Team and the resident inspectors have closely followed your resolution to the identified problems.

Our reviews indicate that your resolution of the condensate storage tank problem, steam line instrumentation piping leaks, and other equipment related matters was aggressive and thorough. We encourage an extension of this attitude to all facets of your operation. This should assure better timeliness in handling issues as they occur. We also note recent improvements in your operating experience as measured by a declining trend in the number of LERs. Based on the initiatives developed by Detroit Edison Company and a strengthening of the Nuclear Operations Improvement Program criteria we anticipate continued improvements.

Full impleinentation of the periodic surveillance program was a problem identified early in 1986 and again late in 1986. We have reviewed these issues and determined that they are not considered to be restraints to power escalation; however, an Enforcement Conference is scheduled for February 23, 1987, to discuss these issues.

Personnel errors at any level continue to concern me. In an effort to understand the problem at Fermi we have looked at your programs carefully, and concluded that they are sound.

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What is needed now, is to instill within the line organization, an appreciation of the programs, stronger Technical Specification knowledge; enhanced communication among all groups; and accountability as a philosophy of job performance.

On January 20, 1987, Region III met with the Chairman and an on-site member of the Independent Overview Committee (IOC) to explore management effectiveness and evaluate plant status in light of the IOC's conclusion that testing at power levels in excess of 20% could be safely conducted.

Subsequently, on February 6, 1987, I received your formal request to proceed to Test Condition 2. At that time the NRC staff reviewed the IOC's conclusions and recommendations. Based on our independent assessment, we concluded that additional time was needed for you to demor. strate your ability to operate the facility routinely. Since that time your operations have been acceptable, with only one routine 10 CFR 50.72 notification being made and r.o recurrence of past personnel performance problems. Further, the site team has advised me that there are no major equipment problems which would impede power escalation.

In our continuing effort to ensure safe operation of the Fermi 2 facility, we

, have evaluated various programs, goals and objectives established by the Detroit Edison Company. More importantly, we have observed and evaluated the results of these programs, and have concluded that your present level of performance is sufficient to support operation up to the next plateau.

I also note that you have improved your capabilities to evaluate problems and take corrective actions. With the recent addition of a new Vice President of Engineering and the new Chairman of the Nuclear Safety Review Group, we fully expect to see a continuation of improvements observed to date.

Based on your demonstrated performance and the NRC's Restart Director's recommendation, concurred in by the NRC Staff, you are authorized to exceed 20 percent power and proceed with your testing program, up to 50 percent power consistent with your schedule, and availability of all equipment needed to normally enter Mode 1 of reactor operation.

If you have any questions I will be glad to discuss them with you.

Sincerely, A. Bert Davis Acting Regional Administrator

Enclosure:

Readiness Assessment cc w/anclosure:

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H. R. Denton, NRR J. M.. Taylor, IE-J. E. Conen, Licensing Engr.

P.' A. Marquardt, Corporate Legal Department A90CS/E S M A1M P Licensing Fee. Management Branch Resident Inspector, RIII

Ronald-Callen, Michigan Public Service Comission Harry H. Voight, Esq.

Nuclear Facilities and Environmental Monitoring Section

Monroe County Office of Civil Preparedness Jennifer Puntenney, Safe Energy Coalition of Michigan Richard Petticrew, Chairman Monroe County Board of Comissioners 1

ENCLOSURE 1 ASSESSMENT OF DETROIT EDIS0N COMPANY FEBRUARY- 13, 1987 Readiness to Proceed Beyond 20% Power

1. Inspection Coverage Throughout Test Condition 1, from September 12, 1986 to January 6, 1987, the NRC Restart Staff continued to provide augmented inspection coverage for Fermi 2. The team evaluated centrol room operations, major test performance, major maintenance activities,-instrumentation and control problems, lessons learned-from events, and corrective actions. In October 1986 the team refocused its effort to provide an indepth review of surveillance testing, tagging, and the interface between the Operations Department and other departments such as-Health Physics, Chemistry, and Engineering.

The staff, during the inspection period, generally-consisted

, of a Region III restart team leader and representatives from IE and NRR, and maintained three-shift control room coverage through the majority of significant operations auring this phase. The team and the Restart

Director completed their assessment of the utility's readiness to 1

conduct power operation up to 50% power on February 13, 1987, following

receipt on February 6, 1987, of a formal request by the utility for NRC i authorization to operate in excess of 20% power.

2. Testing Program 1

!' During Test Condition 1, the licensee conducted testing to calibrate nuclear instruments, assess core performance, assess plant chemistry, L verify the ability of the RCIC system to inject to the vessel, and i demonstrate the ability to shutdown and maintain the reactor in a stable condition from outside the control room.

l The operators and test personnel were especially well-prepared for the Remote Shutdown Demonstration. A separate operating crew was identified and spent approximately one week preparing for the test demonstration.

l Equipment locations were reviewed, the procedure was walked through several

times, test engineers and operators met to discuss the procedure and its l intent, the RCIC pump was operated from the Remote Shutdown Panel for j

practice, and contingency plans were developed in case abnormal situations arose. The intensive preparation resulted in a test that was performed well. The team also noted that the utility plans to use this i approach to prepare for loss of offsite power testing and plans to go to l the Hope Creek facility to obtain lessons learned from that experience.

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'As part of the continuing data collection effort to evaluate the effectiveness of the bypass line modifications, stress measurements were made on the main steam bypass lines at 4%, 8%, and 12% power. Analysis of the data by the licensee indicated that the west bypass line has an acceptable service life if cumulative operation with bypass valve position between 30% and 45% opened does not exceed 100 days, and that the east line can be operated indefinitely. The NRR staff has concluded that the licensee properly identified the root cause of the vibration.

NRR also noted that the modifications, which were admittedly a compromise because of physical limitations and cost, appear to have been done without going significantly beyond what the ASME code (B31-1) requires.

With a commitment from the licensee to monitor and record cumulative bypass line operation with the valves in the 30% - 45% open range, the restart staff has concluded that bypass line vibration is not a restraint to power ascension.

The NRC restart team has concluded that Test Condition 1 testing was satisfactorily conducted and that the licensee was effective in identifying equipment problems.

3. Plant Status / Equipment Operability The plant has been operating at approximately 20% power for the past 12 days and as of 6:00 a.m. February 13, 1987, the plant was operating routinely at 17% power. The licensee had completed its evaluation of test data and equipment performance and was awaiting release from the NRC 20% hold point to proceed to Test Condition 2 (operation up to 45%

power). At the present time there are no plant equipment restraints on power ascension. The High Pressure Coolant Injection System (HPCI),

however, has been inoperable since February 9, 1987, placing the reactor in a 14 day Limiting Condition for Operation which will expire February 23, 1987.

Durir.g the months of September and October, the restart team's concern with the maintenance program was heightened as a result of recurring equipment problems, long-standing hardware deficiencies, and an increase in the number of deficiencies on the Main Control Panels. On

! November 6th, a manage.9ent meeting was held to discuss the licensee's

! maintenance and work process improvement program. The licensee presented a comprehensive plan which included short term improvement actions, a l

long term work process improvement strategic plan, and reorganization of the maintenance department. The restart team observed that the backlog of work requests has been reduced, the majority of the recurring equipment problems have been resolved, and that a large number of long-standing hardware deficiencies have been corrected. In addition, the increasing trend of main control room panel deficiencies was stopped, with the total number reduced by approximately 35%, and stabilized.

The licensee has been advised that continued attention is needed in this area to ensure that improving trends are continued. The team will continue to closely monitor this area. In the future, the utility should be more aggressive and timely in resolving su:h issues.

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-Equipment problems caused a number of plant shutdowns and delays during Test Condition 1. The most significant problems encountered were (1) high reactor water conductivity due to condenser tube leakage, (2) a plant transient and shutdown due to improper phase loading of a balance-of-plant instrument power supply, (3) excessive condenser air in-leakage through torn low pressure turbine exhaust boots caused by improper modifications to the condenser's internal supports, (4) damage to the Condensate Storage Tank due to a combination of an overall design problem coupled with operator error and a lack of relief capability for the affected piping system, and (5) cracking of welds that attached valves to instrument taps on the Main Steam system. The licensee's response to each of these problems has been acceptable. Further problems should be anticipated as unused systems are initially placed in service during power ascension. The team considers it imperative that the licensee's recent, proactive response to these types of problems continue to be aggressive and comprehensive. From a plant availability standpoint, the licensee also need to provide timely resolution of identified problems.

4. Operator Performance During Test Condition 1, the restart team, in conjunction with the resident inspectors, continued to assess operator performance under both routine and off-normal conditions. Five months of observations have enabled the restart staff to identify those areas where the Operations organization is strong and those areas with weaknesses.

Areas which the restart staff considers to be strong are:

Attentiveness to indications, communication between operators, awareness of plant status, procedural compliance, control room congestion, and supervisor involvement are generally satisfactory.

Following completion of the recent outage, a temporary lapse in control room decorum and congestion was noted by the team and brought to the licensee's attention. This area has now been restored to its previous satisfactory level although the team remains concerned that intervention by senior management was necessary. The impetus for such actions in the future should be fostered at the Nuclear Shift Supervisor level.

Shift turnovers and briefings are well organized, thorough, and informative. They are conducted efficiently and arranged to ensure that distraction of panel operators is minimized.

Control room and Shift Supervisor logs were generally neat, comprehensive, and accurate.

10 CFR 50.72 notifications, when required, have been timely. The restart staff has reviewed the licensee's notifications and found then to be accurate and complete.

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• - The operators' response to annunciators is careful and deliberate.

Alarms are clearly announced and if expected, identified as such.

Operators make frequent use of annunciator response procedures when alarms are unfamiliar or unexpected.

Operator performance during abnormal conditions has been consistently excellent. This is evidenced by their response to equipment related plant transients such as the Startup Level Control Valve failures, the MPU-3 failure and subsequent shutdown, the reactor scram caused by pressure regulator problems and by their performance in major evolutions and tests, most notably the Remote Shutdown test. Operator anticipatory response to a reactor water cleanup system problem on February 12, 1987, was good.

On balance, the restart staff noted that the following areas will require attention to bring about additional improvements:

Communications with the Instrument and Control department have at times been incomplete, inaccurate, or confusing. This has resulted in the RCIC flow transmitter being inoperable and an ESF actuation on Reactor Water Cleanup differential temperature due to lack of understanding of the task between the technician and the operator.

Independent verification has not been consistently effective. Errors, which thorough independent verifications could have prevented, include incorrect resetting of a RCIC flow controller and indication of the status of the closing spring on the Emergency Diesel Generator breaker.

• Operator proficiency in equipment operation and restoration needs additional attention,to prevent occurrences of inoperable or damaged equipment. Some notable examples which have occurred during Test Condition 1 include:

Failure to reset the Emergency Diesel Generator exciter following maintenance.

Inadvertent tripping of the North Reactor Feed Pump Damaging the Reactor Recirculation Pump Motor Generator Set by l

attempting to start it with the brushes lifted.

Scramming of the wrong control rod during control rod scram time l surveillance testing.

Attempting to start a condensate pump with the bypass valve open.

Overpressurization and subsequent rupture of the HPCI test return i line with attendant damage to the Condensate Storage Tank.

Two control rod manipulation errors by the same operator during the i

same shift.

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Attempting to operate the plant with the Reheater Vacuum Separator Stop Valve open. This open valve resulted in loss of condenser vacuum while attempting to load the generator and caused a one week delay in plant operation.

A licensee working group reviewed past LERs and identified a number of problem areas including deficient procedures, procedures not followed, communication, supervision, lack of knowledge or training, deficient planning and scheduling, lack of clarity in Technical Specifications, and design deficiencies. The working group report included a series of recommendations which management reviewed and assigned to specific individuals with expected completion dates. The restart staff reviewed LERs submitted since September 12, 1986. Of 22 LERs, 18 were submitted for events which occurred during Test Condition 1. Four of these events can be attributed to errors by operators. The restart team noted that the monthly rate of occurrences during 1986 was reduced significantly from the 1985 rate and that the number of occurrences during January 1987 dropped sharply from the number of December 1986. The evidence of teamwork which was apparent in support of this effort is also a positive indicator. This is an encouraging trend which the licensee must make every effort to maintain.

Although the restart team and resident inspectors have continued to observe some evidence of inexperience in routine matters, they believe that the operators have performed in a satisfactory manner and have demonstrated capability to support operation at the next test condition level.

5. Management Effectiveness During Test Condition 1, a series of LC0 violations occurred which had their roots in the surveillance program. In July of 1986, an enforcement conference was held to discuss problems identified by the NRC in the surveillance program and the licensee committed to an extensive corrective action program. As evidenced by the recurrence of surveillance related LC0 violations, the implementation of that program was not fully effective. Detroit Edison has developed a new program to correct this problem which includes improved staffing, computer system conversion, technical specification to surveillance procedure cross referencing, technical specification interpretations, and a designated reviewer list for surveillances. The failure of the first corrective i action program raised questions about the licensee managemeni.'s ability to identify and effectively correct the root cause of performance problems.

An Enforcement Conference has been scheduled to address these issues.

The licensee has decided that some streamlining of their administrative controls and restructuring of their organization are necessary to improve their performance in this area. Detroit Edison anticipates implementing the reorganization on February 16, 1987 and the streamlined controls will be phased in over the next few weeks. The restart team and resident inspectors view these changes as positive and will carefully monitor their impact.

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The Nuclear Operations Improvement Plan (NOIP) was implemented as part of the licensee's response to the 10 CFR 50.54(f) letter issued by Region III on December 24, 1985. It incorporated quantitative goals, in areas which the Detroit Edison felt would be indicative of their performance, from the earlier Reactor Operations Improvement Plan. The goals were to minimize the number of open work requests (with respect to open work requests, the restart team does not believe that the licensee's definition of "open work request" is accurate since it only focuses on those work requests which are considered " active" and does not count those in an inactive, backlog status), minimize the number of outstanding Engineering Design Packages open 30 days after field work, minimize the number of inoperable alarming annunciators, minimize the number of surveillances accomplished using the " grace period", minimize the number of outstanding time-sensitive LCOs, and minimize the number of reportable occurrences. In an effort to improve performance, Detroit Edison has tightened these goals by reducing the allowable limits in each category with the exception of open work requests. The restart team believes that implementation of the utility's new business plan and attaining these goals will result in further improved performance.

6. Pending Major Enforcement Issues There are currently three significant enforcement issues which are under consideration:

a. Deficiencies in the implementation of the surveillance program

b. Inoperability of the hydrogen thermal recombiners

c. Inoperability of the drywell airlock during power operation Judged on a technical basis, these individual issues have only minimal safety significance due to the low power history, low fission product inventory, or availability of redundant systems. An Enforcement Conference has been scheduled for February 23, 1987, to address these issues. The team has reviewed the issues, concluded that application of -

the Enforcement Policy will be sufficient to resolve them, and determined that they should not be considered as restraints to power escalation.

7. Allegations and Office of Investigations (01) Issues A review completed on February 12, 1987, indicates there are no outstanding allegations or 01 issues which would impact power ascension up to 50% power (Test Condition 2).

8. Restart Conditions All requirements for escalation to Test Condition 2 (TC-2) have been met.

TC-1 testing has been completed, the On-Site Review Committee has reviewed the results of the testing and has recommended power escalation.

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The IOC has recommended escalation of power in a letter to the licensee dated January 6, 1987.

The material condition of the plant has been determined by the restart team to be acceptable for power escalation.

Stress measurements on the main steam bypass lines have been evaluated and indicate that the potential for bypass line cracking is not a restraint to escalation of power.

All NOIP goals are below Management Action Limits and these goals have been strengthened effective February 1, 1987.

9. Conclusions The licensee's testing program for TC-1 has been completed in conformance with their commitments and regulatory requirements. Early in the phase, the restart team detected some degradation in the material condition of the plant, however, extensive corrective action by the licensee has restored the material condition to a level which is acceptable for power escalation. Plant cleanliness was maintained in a high state throughout the period.

Operator performance was evaluated during both routine and off-normal conditions. The team has seen some evidence of inexperience but also noted exceptional performance in off-normal conditions. The restart staff has reviewed the relative strengths and weaknesses, and determined that operator performance is satisfactory for plant operation up to 50%

power.

The Restart Director and team had concerns with the effectiveness of the Detroit Edison management in identifying and correcting problem areas.

The team views the streamlining of administrative controls, restructuring of the organization, and tightening of NOIP goals as positive steps which should result in significantly improved performance.

On January 6, 1987, the Independent Overview Committee, in a letter to the group vice president, stated that Fermi 2 was ready to proceed with Test Condition 2 after operating for five to seven days at approximately 20% power. The unit was synchronized to the grid on January 31st and on February 6th the licensee submitted its formal request to raise power beyond 20%. The restart team, being aware of the IOC position, began an assessment process on February 4th and completed the initial phase just prior to receipt of the licensee's request. The team determined that, in view of the problems which had occurred during the startup, they could not approve operation above 20% power without an additional period of successful operation. As of 6:00 a.m. February 13th, the unit has completed over twelve days of continuous routine operation. During the period from February 1st through 10th the licensee completed 127 surveillances which included major activities on Reactor Water Cleanup and the Control Center HVAC systems. Major maintenance on the HPCI system was also accomplished. The restart team believes that the Fermi 2 staff is ready to conduct operation up to 50% power.

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4 Based on the above information, the restart team recommends that Fermi 2

{. be given approval to operate up to 50% power, the next NRC hold point, 4.

and to proceed to Test Condition 2.

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